UNITED STATES OF AMERI CA DEPARTMENT OF TRANSPORTATION FEDERAL AVIATION ADMINISTRATION

WASHI NGTON, D. C.

**IN THE MATTER OF THE PETITION FOR EXEMPTION OF:**

SkySalt Aerial, LLC **FOR AN EXEMPTION SEEKING RELIEF FROM THE REQUIREMENTS OF**

**TITLE 14 OF THE CODE OF FEDERAL REGULATIONS**  **SECTIONS 61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 91.405(a) , 91.407(a)(1),**  **91.409(a)(1) & (a)(2), AND 91.417(a) & (b) CONCERNING COMMERCIAL OPERATION OF**  **D J**  **I** PHANTOM 3 **AND DJI** INSPIRE 1 **UNMANNED AIRCRAFT SYSTEMS**  **PURSUANT T**  **O SECTION 333 OF T**  **HE FAA MODERNIZATION AND REFORM ACT OF 2012**

**(PUBLIC LAW 112-95)**

Submitted on June 11 , 2015

Tyler D. McCarty SkySalt Aerial, LLC 2 626 Harney St Omaha, NE 68131 Tel: ( 402 ) 677

- 24422 **TABLE OF CONTENTS**

Page

GLOSSARY OF ABBREVIATIONS...................................................................................3

SUMMARY...................................................................................................................... .....4

IN TRODUCTI ON AND INTERESTS OF PETITIONER....................................................4

BACKGROUND................................................................................................................... .4

BASI S FOR PETITION...................... ...................................................................................5

NAME AND ADDRESS OF PETITIONER.............................................................6

THE SPECI FI C SECTIONS OF 14 C.F.R. FROM WHI CH SKYSALT AERIAL, LLC SEEKS EXEMPTI ON.................................................................6

THE EXTENT OF RELIEF SKYSALT AERIAL, LLC SEEKS AND THE REASON SKYSALT AERIAL, LLC SEEKS THE RELIEF..................

.................................................. .............................................8

THE REASONS WHY GRANTING SKYSALT AERIAL, LLC'S REQUEST WOUL D BE IN THE PUBLIC INTEREST ........... ...........................12

THE REASONS WHY GRANTING THE EXEMPTI ON WOULD NOT ADVERSEL Y AFFECT SAFETY.... ......................................................................14

SUMMARY THAT CAN BE PUBLISHED IN THE FEDERAL REGI STER......24

ANY ADDITIONAL INFORMATION, VIEWS, OR ARGUMENTS AVAILABLE TO SUPPORT SKYSALT AERIAL, LLC'S REQUEST....... ........................................................................................................25

CONCL USION................................................................................................................... .25

APPENDI CES...................................................... ..................................263 **GLOSSARY OF ABBREVIATIONS**

AGL Above Ground Level

AOI Area of Interest

ATC Air Traffic Control

ATO Air Traffic Organization

AV Aerial Vehicle

CFR Code of Federal Regulations

COA Certificate of Authorization

FAA Fe deral Aviation Administration

FAR Federal Aviation Regulation

GCS Ground Control Station

GPS Global Positioning Sy stem
LOL Loss of Link

NAS National Airspace Sy stem
NOTAM Notice to Airman

PI C Pilot I n Command
Section 333 FAA Modernization and Reform Act of 2012 (FMRA) Section 333

SO Safety Observer

SOP Standard Operating Procedures

UA Unmanned Aircraft

UAS Unmanned Aircraft Sy stem
VFR Visual Flight Rules

VLOS Visual L ine of Site

VMC Visual Meteorological C onditions

VTOL Vertical Takeoff and Landing4 **SUMMARY**

SkySalt Aerial, LLC seeks exemption from the requirements of 14 C.F.R §§ 61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407( a)(1), 91.409(a)(1) & (a) (2), and 91.417(a) & (b), to operate an Unmanned Aircraft Sy stem pursuant to Section 3 3 3 o f the FAA Modernization and Reform Act of 2012 (FMRA). This exemp tion will permit SkySalt Aerial, LLC to operate an Unmanned Aircraft Sy stem (UAS) for the commercial purpose of con ducting aerial video and photography for wedding

v ideograph y, real estate p hotograph y, corporate marketing, s p ecial events, film sets, and landscape over certain areas of the United States.

**INTRODUCTION AND INTERESTS OF THE PETITIONER** SkySalt Aerial, LLC provides its c lients with expertise and knowledge in advanced technologies and solutions to increase efficiency, productivity and effectiveness. SkySalt Aerial, LLC also provides its clients with the highest quality digital content for use in their commercial, per sonal, and non -p rofit multimedia projects. SkySalt Aerial, LLC and it's sister c ompanies ha ve over 7 y e ars of professional experience in video production and photography and is recognized as an expert this field

. SkySalt Aerial, LLC has over 3 ye ar s of recreational/hobby experience in all aspects of aerial video and photography . The objective of Sky Salt Aerial, LLC's aerial video and photography operation s is to provide high quality imaging for a variety of wedding, comme rcial, public, and resid ential uses, specificall y targeting :

 Wedding Videograph y and Photograph y

 Motion Picture Filming and Commercial Cinematography

 Real Estate Photograph y

 In crease public knowledge of UAS and promote safe UAS operations.

**BACKGROUND** Unmanned Aircraft Sy stems: DJI Phantom 3 , DJ I I n spire 1 UASs

SkySalt Aerial, LLC seeks an exemption to operate DJ I systems fo r compensation or hire within the NAS. The DJ I P h antom 3 and DJ I In spire 1 are ver tical takeoff and landing (VTOL) Unmanned Aircraft (UA) with a Ground Control Station ( GCS) utiliz ing electronic tablet or smart phone systems. The DJ I P h an tom 3 has a

max imum gross weight of approximately 2 pounds 1 3 ounces, while having a length of 1 8 inches
, width of 1 3 inches, height of 8 in ches, and a maximum speed o f approximately 30 k nots. The DJ I Inspire 1 has a maximum gross weight of 6 pounds 7.5 ounces, a length of 17.3 inches, width of 17.7 inches, height of 11.8 inches, and a maximum speed of ap p r ox imately 4 2 k

nots. The DJ I P hantom 3 and DJI I nspire 1UAs are equipped with four main rotors; d riven b y Li thium Poly mer battery p owered electric mo tors. The DJ I P h antom 3 and DJI I nspire 1 UAs that will be operated by SkySalt Aerial, LLC will be registered in accordance with 49 U.S. C. 44103, Registra tion of Aircraft , as well as 14 C.F.R Part 47, Aircraft Registration , and marked in acco rdance with 14 C.F.R. Part 45, Identification and Registration Marking

.5 **BASIS FOR PETITION** Petitioner, SkySalt Aerial, LLC , pursuant to the provisio n s of the Federal Aviation Regulations (14 C.F.R. § 11

. 61) and the FAA Modernization and Reform Act of 2012 (FMRA), Section 333, S

p ecial Rules for Certain Unmanned Aircraft Systems , hereb y p etitions the Administrator to commercial ly operate the DJ I Phantom 3 , DJI I n spir e 1 UASs in the National Airspace S ys tem (NAS), and for an exemption from the requirements of 14 C.F.R §§ 61.113(a) & (b ) , 91.7(a), 91.121, 91.151(b), 91.405(a), 9 1

. 4 0 7 (a)( 1 ), 91.409(a)(1) & (a)(2), and 91.41 7(a) & (b). In consideration of the speed, weight, size, and limited operating area associated with the unmanned aircraft and its operatio n, SkySalt Aerial, LLC's operatio n of DJI Phantom 3 and DJ I Inspire 1 UASs meets the conditions of FMRA Section 33 3 and therefore, will not require an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H. Accordingl y, SkySalt Aerial, LLC r eq uests relief from Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 9 1 .417(a) & (b), as these sections set forth requir emen ts f

o r maintenance that onl y app l y to aircraft with an airworthiness cer tif icate. SkySalt Aerial, LLC submits that the requested relief is proper since an equivalent level of safet y will be ensured. SkySalt Aerial, LLC will use experienced personnel or technicians to p erform mainten ance, alterations, or preventive maintenance on the UASs using the methods, techniques, and practices prescribed in the o p erating documents (i.e., Mo n th ly Maintenance Log , and DJ I P h antom 3 and DJI I nspir e 1 I n struction Manual). Furthermor e, SkySalt Aerial, LLC will d ocument and maintain all main tenance records for the DJ I P hantom 3 and DJI I nspire 1 UASs. Relief from certain requirements of Section 61.113(a) and (b), entitled Private pilot privileges and limitations: Pilot in comma n d , is requested by SkySalt Aerial, LLC to the extent necessary to allow a Pilot in Command (PI C) holding a private pilot or higher l evel

cer tif icate, as well as an airman medical certificate, and who has demo nstrated, by meeting minimum flight

- h o u r an d cu rrency requirements, that the PI C is ab le to safel y operate the DJ I Phantom 3 and DJI I n sp ir e 1 UASs in a manner consistent with this exemption, including evasiv e and emergency man euvers and maintaining appropriate distances from people, vessels, vehicles and structures. SkySalt Aerial, LLC seeks relief from Section 91.7(a), entitled C ivil aircraft

a irworthiness , b ecau se the DJ I P h antom 3 and DJ I I n spir e 1 UASs do not require an airworthiness certificate in accordance with 14 C.F.R. Par t 21, Subpart H. As such, SkySalt Aerial, LLC submits that t he y will ensure that the DJI Phan tom 3 and DJI In spir e 1 UASs are in an airworth y condition, prior to every flight, by determining th at the UASs are in compliance with the operating documents (i.e., Monthly Maintenance Lo g, an d DJ I Phantom 3 and DJI I nspire 1 Instructio n Manual), and th at the aircr aft are in a condition f o r safe flight. Sk ySalt Aerial, LLC also seeks an exemption from the requirements of Section 91.121, entitled Altimeter Settings
, as th e DJI Phantom 3 and DJ I I n spir e 1 UAs will not h av e a ty pical barometric altimeter onboard. However, altitude informati on of th e DJI Ph antom 3 and DJ I I n sp ir e 1 UAs will be provided to the PI C via Global Positioning Sy stem (GPS) equipment an d radio communicatio n s telemetry data link, wh ich downlinks from the UA to the GCS for active monitoring of the flight path. This altitude information, comb ined with SkySalt Aerial, LLC ’s operation of the DJ I Phanto m 3 and DJ I6

Inspire 1 UASs within visual line of sight, at or below 5 00 feet AGL, will ensure a level of safet y equivalent to Section 91.121. Additionally
, SkySalt Aer ial, LLC seeks an exemption fr om the requ irements of Section 91.151(b) , en titled Fuel requirements for flight in VFR conditions

. SkySalt Aer ial, LLC su b mits th at safety will not be affected by operation of the D JI Phantom 3 and DJ I Insp ir e 1 UAs during day light hours in visual meteorological conditions (VMC) u nd er

v isu al f light rules (VFR), with enough battery power to fly for a total duration of ap p r o ximately 13.5 minutes to the first p oint of intend ed landing and, assuming normal cruising speed, to fl y af

ter that fo r at least 4.5 minutes. In accor d an ce with 14 C.F.R. § 11.81, Sk y Salt Aerial, LLC p r ovides the follo wing information in support of its petition for exemption:

**A. Name And Address Of The Petitioner.**  The name and address of the Petitioner and point o f contact is: SkySalt Aerial, LLC c/o Tyler McCarty 2 626 Harney St Omaha, NE 68131 Tel: ( 402 ) 677-2442 Email: in fo@ skysaltaerial .com

**B**

**. T**  **he Spec**  **if**

**ic Sections Of 14 C. F.**  **R. f rom**  **W hich**  SkySalt Aerial, LLC **Seeks Exemption.**

**1.** SkySalt Aerial, LLC **Seeks E**  **xemption From The Requirements Of Section**  **6 1** 

**. 1**  **1 3(**  **a) And (b).** 

Section 61.113, entitled Private pilot privileges and limitations: Pilot in command
, subsections (a) and (b) prescribe the following, in relevant part: (a) No person who holds a private pilot certificate may act as a pilot in command (PI C) of an aircraft that is carry ing passengers or propert y for compensation or hire; nor may

that person, for compensation or hire, act as PIC of an aircraft.

(b) A private pilot may , for compensation or hire, act as PIC of an aircraft in connection with an y business or emplo ym ent if

— (1) The flight is only

incidental to that business or employ ment; and (2) The aircraft does not carry passengers or property

for compensation or hire.

**2.** SkySalt Aerial, L LC **Seeks Exemption From The Requirements Of Section**  **9 1.7(a).** 

Section 91.7, entitled Civil aircraft airworthiness , subsection (a), states the following: (a) No person may

operate a civil aircraft unless it is in an airworthy condition. **3.** SkySalt Aerial, LLC **Seeks E**  **xemption From The Requirements Of Section 91.121.** 7 Section 91.121, entitled Altimeter settings , subsection (a), states the following, in part: (a) Each person operating an aircraft shall maintain the cruising altitude or flight level of that aircraft, as the case may be, b y reference to an altimeter that is set, when operating

-- (1) Below 18,000 feet MSL , to

-- (i) The current reported altimeter setting of a station along the route and within 100 nautical miles of the air craft;

(ii) If there is no station within the area prescribed in paragraph (a)(1)(i) of this section, the current reported altimeter setting of an appropriate available station; or

(iii) I n the case of an aircraft not equipped with a radio, the elevation of the departure airport or an appropriate altimeter setting available before departure.

**4.** SkySalt Aerial, LLC **Seeks E**  **xemption From The Requirements Of Section**  **9 1** 

**. 1**  **5 1**  **(b).**

Section 91.151, entitled Fuel requirements for flight in VFR conditions , su bsection

(b), states the following:
(b ) No person may begin a flight in a rotorcraft under VFR conditions unless (considering wind and forecast weather conditions) there is enough fuel to fly to the first point of intended landing and, assuming normal cruising speed, to fly after that for at least 20 minutes.

**5.** SkySalt Aerial, LLC **Seeks E**  **xemption From The Requirement Of Section**  **9 1** 

**. 405(a).** 

Section 91.405, entitled Maintenance required , subsection (a), states the following: Each owner or operator of an aircraft

— (a) Shall have that aircra ft inspected as prescribed in subpart E of this part and shall between required inspections, except as provided in paragraph (c) of this section, have discrepancies repaired as prescribed in part 43 of this chapter[.]

**6.** SkySalt Aerial, LLC **Seeks E**  **xemption From T**  **he Requirement s Of**  **Section 9**  **1.407(a)(1)**8 Section 91.407, entitled Operation after maintenance, preventive maintenance, rebuilding, or alteration
, subsection (a)(1), states the following: (a) No person may

operate any

aircraft that has undergone maintenance, preventive maintenance, rebuilding, or alteration unless

-- (1) It has been approved for return to service b y a person authorized under § 43.7 of this chapter[.]

**7.** Sky Sa lt Aerial, LLC **Seeks Exemption From The Requirem ents**  **Of Sect**  **ions 9**  **1**

**. 4**  **0 9**  **(a)(1) And 91.409(a)(2).**

Section 91.409, entitled Inspections , subsection (a), states the following:

(a) Except as provided in paragraph (c) of this section, no person may operate an aircraft unless, within the preceding 12 calendar months, it has had

-- (1) An annual inspection in accordance with part 43 of this chapter and has been approved for return to service b y a person authorized by § 43.7 of this chapter; or

(2) An inspection for the issuance of an airworthiness certificate in accordance with part 21 of this chapter.

**8.** SkySalt Aerial, LLC **Seeks Exemption From The Requirements Of Sections**  **91.417(a) And 91.417(b).**

Section 91.417, entitled Maintenance re cords , subsections (a) and (b), state the following: (a) Except for work performed in accordance with §§ 91.411 and 91.413, each registered owner or operator shall keep the following records for the periods specified in paragraph (b) of this section:

(1) Records of the maintenance, preventive maintenance, and alteration and records of the 100

- hour, annual, progressive, and other required or approved inspections, as appropriate, for each aircraft (including the airframe) and each engine, propeller, rotor, and appliance of an aircraft. The records must include

-- (i) A description (or reference to data acceptable to the Administrator) of the work performed; and

(ii) The date of completion of the work performed; and

(iii) The signature, and certificate numb er of the person approving the aircraft for return to service.9 (2) Records containing the following information: (i) The total time in service of the airframe, each engine, each propeller, and each rotor.

(ii) The current status of life- limited parts of each airframe, engine, propeller, rotor, and appliance.

(iii) The time since last overhaul of all items installed on the aircraft which are required to be overhauled on a specified time basis.

(iv) The current inspection status of the aircraft, including the time since the last inspection required by the inspection program under which the aircraft and its appliances are maintained.

(v) The current status of applicable airworthiness directives ( AD) and safety directives including, for each, the method of compliance, the AD or safet y directive number and revision date. If the AD or safety directive involves recurring action, the time and date when the next action is required.

(vi) Copies of the f

orms prescribed b y § 43.9(d) of this chapter for each major alteration to the airframe and currentl y installed engines, rotors, propellers, and appliances.

(b) The owner or operator shall retain the following records for the periods prescribed:

(1) The r ecords specified in paragraph (a)(1) of this section shall be retained until the work is repeated or superseded b y other work or for 1 ye ar after the work is performed.

(2) The records specified in paragraph (a)(2) of this section shall be retained and tr ansferred with the aircraft at the time the aircraft is sold.

(3) A list of defects furnished to a registered owner or operator under § 43.11 of this chapter shall be retained until the defects are repaired and the aircraft is approved for return to servi ce.

**C. The Extent Of Relief** Sky Sa lt Aerial, LLC **Seeks And The Reason** Sky Sa lt Aeria l, LLC **Seeks The Relief**

**.**10 **1. E**  **x t**  **ent Of Relief** SkySalt Aerial, LLC **Seeks And The Reason** SkySalt Aerial, LLC **Seeks Relief From Section 61.113(a) And (b).**

Relief from Section 61.113(a) and (b) entitled Private pilot privileges and limitations: Pilot in command , is requested to the extent necessary to allow a PI C holding

a private pilot or higher level certificat e, as well as a current and valid airman medical certificate, an d who has met certain flight -h our and currency requirements, to conduct the proposed UAS flight operations for compensation or hire. This relief is requested since the limitations set forth i n Section 61.113(a) and (b) state that a private pilot may, for compensation or hire, act as PI C of an aircraft in connection with an y business or emplo ym ent if: (1) The flight is only incidental to that business or employ

ment; and (2) The aircraft does no t carry passengers or propert y for compensation or hire. As set forth more full y below, SkySalt Aerial, LLC submits that an equivalent level of safet y will be main tained because no PI C will be allowed to operate the DJI Phantom 2 UAS or DJI I nspire 1 UAS unless that PI C has met certain flight-h our and currency requirements, demonstrating that the PIC is able to safely operate either the DJ I Phantom 2 or DJI I nspire 1 UAS in a manner consistent with the operations specifi cations as described in this e xemption, includin g evasive and emergency maneuvers, as well as maintaining appropriate dist ances from people, vessels, vehicles and structures. Further, Sk y Salt Aerial, LLC submits that all flights of the DJ I P hanto m 3 and DJ I Inspire 1 UASs, conducte d b y the PI C p u r su ant to the grant of this Petition: (1) will be incidental to SkySalt Aerial, LLC ’s b usiness; and (2) will not carry p assenger s or p r o p erty for compensation or hire.

**2. E**  **x t**  **ent Of Relief** SkySalt Aerial, LLC **Seeks And The Reason** SkySalt Aerial, LLC **Seeks Relief From Section 91.7(a).**
Relief from Section 91.7(a) entitled Civil aircraft airworthiness , is requested to the extent required to allow SkySalt Aerial, LLC to determine that the DJ I Phantom 3 and DJ I Inspire 1 UASs are in airworth y condition prior to every flight b y ensuring that the UAS is in compliance with the operating documents (i.e., the SkySalt Aerial, LLC Aerial Operations Manual, Monthly Maint enance Log, and DJ I Phantom 3 and DJ I Inspire 1 I n struction Manual). SkySalt Aerial, LLC seeks the requested relief because the DJ I P hantom 3 and DJ I Inspire 1 UASs do not require an airworthiness certificate in accordance with 14 C .F.R. Part 21, Sub p art H. Therefore, SkySalt Aerial, LLC will ensure that the DJI Phantom 3 and DJ I I n spire 1 UASs are in airworthy condition based upon its compliance with the operating documents (i.e.
, Monthly Maintenance Log, and DJI Phantom 3 and DJI I nspire 1 In struction Manual) prior to every flight, and further, d etermine that the aircraft are in condition for safe flight, as stated in the conditions and limitations below.

**3. E**  **x t**  **ent Of Relief** SkySalt Aerial, LLC **Seeks And The Reason** SkySalt Aerial, LLC **Seeks Relief From Section 91.121.**11 Relief from Section 91.121, entitled Altimeter settings , may be requ ired to allow flight operations of the DJI Phantom 2 and DJ I I n sp ire 1 UASs, which utilize a barometric pressure sensor, GPS equipment, and a radio communications telemetry data link to d ownlink altitude information fro m the UA to the PI C at the ground con trol station (GCS). Since the FAA req uires that any altitude informatio n concerning UAS operations be reported to air traffic control (ATC) in feet ab o v e gro un d level (AGL), SkySalt Aerial, LLC seeks the requested relief because the DJ I P h antom 2 and DJ I I n spire 1 UA’s altimeter may b e set on the ground to zero feet AGL , rather than the local barometric pressure or field altitude, before each fl ight. Considering the limited altitude of the proposed operations, relief from 14 CFR 9 1

. 121 is sought to the extent necessary to comply with the applicable conditions and limitations stated below. As more full y set forth herein, an equivalent level of s afet y will b e maintained since the DJI Phantom 3 and DJ I Inspire 1 UAs are equipped with a barometric pressure sensor and GPS equipment, which auto maticall y ensu r es that a ground lev el pressure setting will be established prior to each flight, a nd provides the PI C with altitude information of the UA on the heads

- u p d isp lay o f the GCS.

**4. E**  **x t**  **ent Of Relief** SkySalt Aerial, LLC **Seeks And The Reason** SkySalt Aerial, LLC **Seeks Relief From Section 91.151(b).**
Relief from Section 91.151(b) entitled Fuel requirements for flight in VFR conditions , is requested to the extent required to allow flights of the battery powered DJI Phantom 3 and DJI I nspire 1 UAs durin g day light hours in visual meteorological conditions (VMC), under visual flight rules (VFR) , for a total duration of 13.5 minutes to the first point of intended landing and, assuming normal cruising speed, to fly after that for at least 4.5 minutes. SkySalt Aerial, LLC seeks the requested relief because without an exemption from Section 91

. 151(b), the flight time duration of the battery powered DJ I Phantom 2 and DJI I nspire 1 UAs will severel y constrain the practicalit y of any aerial video or still photo flight operations that SkySalt Aerial, LLC proposes to conduct pursuant to this Pe tition. Significantl y, as set forth below, the technical specifications of the DJ I P hantom 3 and DJ I Inspire 1 UASs, the DJI P hantom 3 and DJI I nspire 1 operating documents, and SkySalt Aerial, LLC ’s proposed operating limitations, ensure that SkySalt Aerial, LLC will safely operate the battery p o wered DJ I P hantom 3 and DJI I nspire 1 UAs during d ay light hours in visual meteorological conditions (VMC), under visual flight rules ( VFR), with enough battery power to fly f or a total duration of 13. 5 minutes to the first point of intended landing and, assuming normal cruising speed, to fl y after that for at least 4.5 minutes.

**5. E**  **x t**  **ent Of Relief** SkySalt Aerial, LLC **Seeks And The Reason** SkySalt Aerial, LLC **Seeks Relief From Sections 91 .405(a),**  **91.407(a)(1), 91.409(a)(1) & (a)(2), And 91.417(a) & (b).** 12 Since Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b)

o nly appl y to aircraft with an airworthiness certificate, SkySalt Aerial, LLC requests relief f r o m these Sections because the DJ I Phantom 3 and DJI I nspire 1 UASs do not require airworthiness certificates. A s set forth more fully b elow, the DJI Phantom 3 and DJ I Inspire 1 UASs meet the conditions of FMRA Section 333 for operation without a n airworthine ss certificate. Accordingl y, SkySalt Aerial, LLC will use trained technicians to perform maintenance, alter ations, or preventive maintenance on the UASs using the methods, techniques, and practices prescribed in the UAS operating documents ( i.e., the SkySalt Aerial, LLC Aerial Operations Manual, Monthly Maintenance Lo g, and DJ I Phantom 3 and DJ I I n spire 1 Instruction Manual). Furthermore, SkySalt Aerial, LLC will document and maintain all maintenance records for the DJI Phantom 3 and DJ I In spire 1 UASs.

**D. The Reasons Why Granting** SkySalt Aerial, LLC **’s Request Would B**  **e In The Public Interest; That Is, How It Would Benefit The Public As A Whole.** 
Granting the present Petition will further the public interest b y allowing SkySalt Aerial, LLC to safel y, efficientl y, and economically perform aerial video and photograph y for wedding films, r eal estate, special events, film sets, and landscape over certain areas of the United States. Additionally , use of the DJI Phantom 3 and DJ I Inspire 1 UASs will decrease congestion of the NAS, reduce pollution, and provide significant benefits to the economy

. Notably , the benefits of SkySalt Aerial, LLC ’s proposed operation of the DJ I Phan tom 3 and DJI I nspire 1 UASs will be real ized without implicating any privacy issues.

**1. The Public Will Benefit From Decreased Congestion Of The NAS.** The DJ I P hantom 3 and DJI I nspire 1 UAs are battery po wered and serve as a safe, efficien t, and economical alternative to the manned aircraft t raditionally utilized to obtain aerial imagery . By reducing the amount of manned aircraft needed to perform aerial acquisitions, an exemption allowing the use of a DJI Phantom 3 or DJI Inspire 1 UAS would reduce the amount of manned aircraft in the NAS, re duce noise and air pollution, as well as increase the safety of life and propert y in the air and on the ground. Furthermore, b y reducing the number of manned aircraft operating in the NAS, congestion ar ound airports caused b y arriving and departing aircra ft will be reduced. The DJI Phantom 3 and DJ I Inspire 1 UAs do not require an airport to takeoff or land. Likewise, a reduction of manned aircraft conducting aerial video and photograph y missions would result in fewer aircraft that must be handled b y air t raffic control during the ground, takeoff, departure, arrival, and landing phases of flight operations.

**2. The Public Will Benefit From The Safety And Efficiency Of The**  **DJI Phantom**  3 **and DJI Inspire 1 UASs.**

C onducting aerial acquisitions with the DJI Phantom 3 and DJ I In spir e 1 UASs, instead of manned aircraft, will greatl y benefit the public by drasticall y r educing the levels13

o f air and noise pollution generated during traditional aerial vid eo and still photography f light operations. By u sing battery power and electric motors, the DJ I P hantom 3 and DJ I Inspire 1 UASs produce no air pollution, and is the most viable environmentally conscious alternative to the cabin class, six cy linder internal combustion engine aircraft that are ty picall y utilized for aerial video and photograph y, while burning approximately 20-30 gallons per hour

of leaded aviation fuel. The DJ I Phantom 3 and DJI I nspire 1 UAs, while reducing the carbon footprint of aerial acquisitions, also eliminates noise pollution, as the UAs are p ropelled by battery powered electric motors, rather than an internal combustion engine. By using the DJI P h antom 3 and DJ I Inspire 1 UASs to perform aerial acquisitions, the substantial risk to life and propert y in the air and on the ground, which is usu ally associated with traditional manned aircraft flight operations, will be substantially reduced or completel y eliminated. Aside from the lack of fligh t crew members located onboard the aircraft, the DJ I P h antom 3 and DJ I Inspire 1 UAs (weighing approximat ely 2 pounds 1 3

o u n ces and 6 pounds 7.5 ounces respectively, at their maximum gros s weights with lengths of 1 8 inches and 17.3 inches respectively, widths of 1 3 inches and 17.7 inches respectivel y, and with no fuel on board), has less physical potential f or collateral damage to life and propert y on the ground, and in the air, compared to the manned aircraft that ty picall y conduct similar operations (weighing approximately 6
, 0 0 0 pounds with a wingspan of appro ximately 42 feet, a length of 34 feet, and a fue l capacity of 180 gallons).

**3. Performing Aerial Video and Photography Operations With The DJI**  **Phantom** 3 **and DJI Inspire 1 UASs Will Benefit The Economy.**
In addition to being safe and efficient, the DJ I P hantom 3 and DJI I nspire 1 UASs are also an economical alternative to using manned aircraft to conduct similar aerial operations. As such, operation of the DJ I P hantom 3 and DJ I I nspire 1 UASs will allow United States based compa nies, like SkySalt Aerial, LLC , to remain competi tive and contribute to growth of the U.S. econom y. Specificall y, with the rising cost of aviation fuel and the Environmental Protection Agency (“EPA”) regulatory actions phasing out leaded aviation fuels, U.S. owned and operated companies must adopt new and alternative technology in order to remain competitive. Operating the battery p o wered DJI Phantom 3 and DJ I I n spire 1 UASs is one such technology that not only allows companies greater

o p erational flexibility compared to manned aircraft, but provides suc h flexibility without the high operational cost of a traditional manned aircraft. By operating the DJ I P hantom 3 and DJI I nspire 1 UASs, companies such as SkySalt Aeria l, LLC , can remain competitive and profitable, and therefore, p rovide greater job stability to employ ees and contractors, which will ultimately contribute to growth of the U.S. economy . Improved financial performance of U.S. companies, through commercial use of the DJ I P hantom 3 and DJI I nspire 1 UASs, provides a stable workforce that increases consumer spending; improves local, state, and federal tax revenues; and allows companies to invest in research and development in order to remain competitive both in the United States and abroad.
**4. There Are No Privacy Issues.**14

Similar to the man ned aerial acquisition flight operations that have been conduct ed for d ecades, SkySalt Aerial, LLC ’s proposed operation of the D J I Phantom 3 and DJI I n spire 1 UASs will not implicate any privacy issues. Specificall y, the DJ I Phantom 3 and D JI I nsp ire 1 UASs will be operated only in compliance with operating documents (i.e., the SkySalt Aerial, LLC Aerial Operations Manual, Monthly Maintenance Log, and DJ I Phantom 3 and DJI I nspire 1 Instruction Manual) which requires propert y owner involveme nt as well as local law enforcement notification, and in accordance with the Federal Aviation Regulations, including the minimum altitude requirements of 14 C.F.R. § 91.119. **E. The Reasons Why Granting The Exemption Would Not Adversely Affect Safety, Or H**  **ow The Exemption Would Provide A Level Of Safety At Least Equal To That Provided By The Rule From Which**  SkySalt Aerial, LLC **Seeks Exemption.** 

**1. Reasons Why The**  **DJI Phantom** 3 **and DJI Inspire 1 UAs Meet The**  **Conditions Of The FAA Modernization and Ref orm Act of 2012 (FMRA)**  **Section 333.**
In consideration of the size, weight, speed, and limited operating area associated with the unmanned aircraft and its operation, SkySalt Aerial, LLC ’s operatio n o f the DJ I Phantom 3 and DJI I nspire 1 UASs meet the conditions of FMRA Section 333, and will not require an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H

. Section 333 provides authority for a UAS to operate without airworthi ness certification and sets forth requirements for considering whether a UAS will create a hazard to users of the NAS or the public, or otherwise pose a threat to national securit y. Specificall y, FMRA Section 333 states the following, in part: (a ) In Gene ral.

-- Notwithstanding any other requirement of this subtitle, and not later than 180 days after the date of enactment of this Act, the Secretary of Transportation shall determine if certain unmanned aircraft systems may operate safely in the national airsp ace system before completion of the plan and rulemaking required by section 332 of this Act or the guidance required by section 334 of this Act.

(b ) Assessment of Unmanned Aircraft Systems.

-- In making the determination under subsection (a), the Secretary shall determine, at a minimum

-- (1 ) which types of unmanned aircraft systems, if any, as a result of their size, weight, speed, operational capability, proximity to airports and populated areas, and operation within visual line of sight do not create a ha zard to users of the national airspace system or the public or pose a threat to national security; and
(2 ) whether a certificate of waiver, certificate of authorization, or airworthiness certification under section 44704 of title 49, United States Code, is required for the operation of unmanned aircraft systems identified under paragraph (1).15 (c) Requirem ents for Safe Operation.

-- If the Secretary determines under this section that certain unmanned aircraft systems may operate safely in the national airspace system, the Secretary shall establish requirements for the safe operation of such aircraft systems i n the national airspace system.
In seeking this exemption, SkySalt Aerial, LLC submits that the DJI Phantom 3 and DJI I nspir e 1 UASs can operate safely in the NAS pursuant to FMRA Section 3 3 3 , as demonstrated b y: ( a) the characteristics of the DJ I P h anto m 3 an d DJ I Inspire 1 UASs; (b) the pilot certification requirement; and (c) the specific operating limitations.

**a. T**  **he Specifications Of The**  **DJI Phantom** 3 **and DJI Inspire 1 UASs Demonstrate Its Safe Characteristics.** 

The DJ I P h an tom 3 and DJI I nspire 1 UASs do not create a hazard to users of the N AS or the public, or otherwise p o se a th r eat to nation al security considering its size, weight, speed, and operational capability

.

**i. T**  **echnical Specifications Of The DJ**  **I Pha**  **nt o**  **m** 3 **a nd DJI I**  **nspire 1 UASs.** 
The technical specifications of the DJ I P h an tom 3 and DJ I I n spire 1 UASs are set f orth by the D J I P h an to m 3 and DJ I I nspire 1 Specifications an d Data Sheet, attached h ereto as Exhibit A and B.

**ii. The D**  **J I**  **Pha nt**  **o m**  3 **and DJI Inspire 1 UASs**  **Aut o**  **nom ous Flight And**  **Navigation Modes Enable The UASs To Remain Within A Def**  **ined Operational Area.** 

The DJ I P h an tom 3 and DJI I nspire 1 UASs may be operated in both manual and f ully autonomous flight modes. A complete description of the flight and navigational modes of the DJ I P h an to m 3 and DJ I Inspire 1 UASs is provided at p ages 11-17 an d 40 -46

o f the DJ I Phantom 3 and pages 12 -1 6 and 45 -5 0 of the DJ I I n spir e 1 User Manuals
, attached hereto as Exhibit C and D.

**iii. T**  **he DJI Phantom**  3 **and DJI Inspire 1 UASs Are Designed For**  **Automatic Return To Home Point Or Hover In The Event Of Loss Of The Control Link Or Naviga**  **tion.**

When the C o n trol L ink is lost, the D JI Phantom 3 and DJ I Inspire 1 UAs will

r emain stationary , in flight, for 3 seconds or more. If, after 3 seco nd s, the DJI Phan tom 3 a nd DJ I Inspire 1 UAs do not reacquire control link data from the GCS, the UAs will assume that the Control Link is lost and the UAs will return to the home position (i.e., failsafe mode) via GPS, and will descend to the takeof f p osition and shutdown. A complete description of the Failsafe Functions of the DJI P hantom 3 UAS are set forth at pages 12 through 14 and for the DJ I I nspire 1 at pages 13 through 15 of the DJ I Phantom 3 and DJI I nspire 1 User Manuals, attached hereto as Exhibit C and D.

**iv. T**  **he DJI Phantom** 3 **and DJI Inspire 1 GCS And Its Operatio**  **n.**16 A complete description of the operation an d specifications of the DJ I P hantom 3 and DJ I Inspire 1 GCS and flight con trol software is provided at pages 23 through 38 of th e DJ I Phant om 3 User Man u al and pages 4 0 through 47 of the DJ I I n spire 1 User Man ual. DJ I P h antom 3 and DJ I In spire 1 User Manuals are attached hereto as Exhibits C and D. **b. Flight Operations Of**  **DJI Phantom** 3 **a nd DJI Inspire 1**  **UASs Are**

**L im**  **it ed To The Line Of Sight Of A Certificat**  **ed Pilot in Command With A**  **Sa fety Observer.** 
SkySalt Aerial, LLC will o n ly u tilize certif icated pilots who possess a current and valid airman medical certificate to act as a pilot in command (PIC ) o f the DJ I Phantom 3 and DJI I nspire 1 UASs. Additionally , a safet y observer will assist all pilots d uring flight time.

**c. Flights Of**  **DJI Phantom** 3 **and DJI Inspire 1 UASs Will Be Conducted**  **Pursuant To Specific Operating Limitations.**
In seeking this exemption, SkySalt Aerial, LLC pr oposes to commerciall y operate DJ I Phantom 3 and DJI I nspire 1 UASs for the special purp ose of conducting aerial v ideo and photograph y over certain areas o f United States, pursuant to the following sp ecific

o p erating limitations: 1. Operations authorized by this grant of exemption will be limited to the following aircraft described in the operating documen ts, rotorcraft UASs weighing less th an 55 pounds maximum gross weight: DJ I P h antom 3 and DJI I nspire 1 Un manned Aircraft Sy stems. Proposed oper ations of any o ther aircraft will require a new petition or a petition to amend this grant.

2. UA S operations under this exemption will be limited to conducting operations for the purpose of aerial video and photograph y. 3. The UAs may

not be flown at an indicated airspeed exceeding 20 knots.
4. The UA must be operated at an altitude of no more than 500 feet above ground level (AGL), as indicated by the procedures specified in the operating documents unless a special request is made and approved b y ATC. All altitudes reported to ATC must be in feet AGL.
5. The UAs must be operated within visual line of sight (VLOS) of the PI C at all times. This requires the PIC to be able to use human vision unaided by an y device other than corrective lenses, as specified on the PI C’s FAA

- issued airman medical certificate.
6. The use of first person view (FPV) b y the PI C or safet y observer (SO) is not permitted.
7. All operations must utilize a safet y observer (SO). The SO may be used to satisfy the VLOS requirement as long as the PIC alway s maintains VL OS capability

. The SO and PI C must be able to communicate verbally at all times. Electronic messaging or texting is not permitted during flight operations. The PIC must be17 designated before the flight and cannot transfer his or her designation for the duratio n of the flight. The PI C must ensure that the SO can perform the functions prescribed in the operating documents.
8. The SO must not perform any other duties bey ond assisting the PI C with seeing and avoiding other air traffic and other ground based obsta cles/obstructions and is not permitted to operate the camera or other instruments.
9. The operating documents and the grant of exemption must be accessible during UAS operations and made available to the Administrator upon request. If a discrepancy

exist s between the conditions and limitations contained in the grant of exemption and the procedures outlined in the operating documents, the conditions and limitations contained in the grant of exemption take precedence and must be followed. Otherwise, the ope rator must follow the procedures as outlined in its operating documents. The operator may update or revise its operating documents. It is the operator’s responsibility to track such revisions and present updated and revised documents to the Administrator u pon request. The operator must also present updated and revised documents if it petitions for extension or amendment to the grant of exemption. If the operator determines that any update or revision would affect the basis upon which the FAA granted the exe mption, then the operator must petition for amendment to its grant of exemption. The FAA’s UAS I ntegration Office (AFS

- 80) may be contacted if questions arise regarding updates or revisions to the operating documents.
10. Prior to each flight the PI C mus t inspect the UAS to ensure that it is in a condition for safe flight. If the inspection reveals a condition that affects the safe operation of the UAS, the aircraft is prohibited from operating until the necessary maintenance has been performed and the UA S is found to be in a condition for safe flight. The Ground Control Station must be included in the preflight inspection. All maintenance and alterations must be properl y documented in the aircraft records.
11. Any UAS that has undergone maintenance or a lterations that affect the UAS operation or flight characteristics, e.g. replacement of a flight critical component, must undergo a functional test flight. The PI C who conducts the functional test flight must make an entry in the aircraft records.

12. Th e pre

- flight inspection must account for all potential discrepancies, e.g. inoperable components, items, or equipment, not alread y covered in the relevant sections of the operating documents.
13. The operator must follow the UAS manufacturer’s aircraft/component, maintenance, overhaul, replacement, inspection, and life limit requirements.
14. The operator must carry out its maintenance, inspections, and record keeping requirements, in accordance with the operating documents. Maintenance, inspection, alt erations, and status of replacement/overhaul component parts must be noted in the aircraft records, including total time in service, description18 of work accomplished, and the signature of the authorized person returning the UAS to service.
15. Each UASs operated under this exemption must comply with all manufacturer Safety Bulletins.
16. The authorized person must make an entry in the aircraft record of the corrective action taken against discrepancies discovered between inspections.

17. The PI C must possess at least a private pilot certificate and at least a current third

- class medical certificate.
18. The operator may

not permit any

PIC to operate unless the PI C meets the operator’s qualification criteria and demonstrates the ability to safel y operate the UAS in a manner consistent with how the UAS will be operated under the exemption, including evasive and emergency maneuvers and maintaining appropriate distances from persons, vessels, vehicles and structures. PIC qualification fligh t hours must be logged in a manner consistent with 14 C.F.R. § 61.51(b). Flights for the purposes of training the operator’s PICs are permitted under the terms of the exemption. However, training operations may only be conducted during dedicated training s essions. During training, proficiency , and experience -building flights, all persons not essential for flight operations are considered nonparticipants, and the PI C must operate the UA with appropriate distance from nonparticipants in accordance with 14 C.F .R. § 91.119.
19. UAS operations may

not be conducted during night, as defined in 14 C.F.R. § 1.1. All operations must be conducted under visual meteorological conditions (VMC). If flight at night is required, a special request will be made at the FAA office closest to proposed area of operations. Flights under special visual flight rules (SVFR) are not authorized.
20. The UA may

not operate within 5 nautical miles of an airport reference point as denoted on a current FAA- published aeronautical chart un less a letter of agreement with that airport’s management is obtained, and the operation is conducted in accordance with a NOTAM as required by the operator’s COA. The letter of agreement with the airport management must be made available to the Administra tor upon request.
21. The UA may

not be operated less than 500 feet below or less than 2,000 feet horizontally

from a cloud or when visibility is less than 3 statute miles from the PI C.
22. If the UA loses communications or loses its GPS signal, it mus t return to a pre

determined location within the planned operating area and land or be recovered in accordance with the operating documents.19 23. The PI C must abort the flight in the event of unpredicted obstacles or emergencies in accordance with the op erating documents.

24. The PI C is prohibited from beginning a flight unless (considering wind and forecast weather conditions) there is enough power to fly at normal cruising speed to the intended landing point and land the UA with 25% battery power
rema ining.
25. The operator must obtain an Air Traffic Organization (ATO) issued Certificate of Waiver or Authorization (COA) prior to conducting an y operations under the grant of exemption. This COA will also require the operator to request a Notice to Airm an (NOTAM) not more than 72 hours in advance, but not less than 48 hours prior to the operation. All operations shall be conducted in accordance with airspace requirements in the ATO issued COA including class of airspace, altitude level and potential tran sponder requirements.
26. All aircraft operated in accordance with the exemption must be identified by serial number, registered in accordance with 14 C.F.R. part 47, and have identification (N - Number) markings in accordance with 14 C.F.R. part 45, Subp art C. Markings must be as large as practicable.
27. Before conducting operations, the radio frequency spectrum used for operation and control of the UA must comply with the Federal Communications Commission (FCC) or other appropriate government oversigh t agency requirements.
28. The documents required fewer than 14 C.F.R. 91.9 and 91.203 must be available to the PIC at the Ground Control Station of the UAS an y time the UAS is operating. These documents must be made available to the Administrator or an y law enforcement official upon request.

29. The UA must remain clear and yi eld the right of way to all manned aviation operations and activities at all times.
30. The UAS may

not be operated b y the PIC from any moving device or vehicle.
31. Flight operations must be conducted at least 500 feet from all nonparticipating persons (persons other than the PI C, SO, operator trainees or essential persons), vessels, vehicles, and structures unless:
a. Barriers or structures are present that suf ficiently protect nonparticipating persons from the UA and/or debris in the event of an accident. The operator must ensure that nonparticipating persons remain under such protection. If a situation arises where nonparticipating persons leave such protectio n and are within 500 feet of the UA, flight operations must cease immediately

and/or;20 b. The aircraft is operated near vessels, vehicles or structures where the owner/controller of such vessels, vehicles or structures has granted permission and the PI C h as made a safet y assessment of the risk of operating closer to those objects and determined that it does not present an undue hazard, and;
c. Operations nearer to the PI C, SO, operator trainees or essential persons do not present an undue hazard to those persons per § 91.119(a).
32. All operations shall be conducted over private or controlled

- access property with permission from the land owner/controller or authorized representative. Permission from land owner/controller or authorized representative wil l be obtained for each flight to be conducted.
33. Any incident, accident, or flight operation that transgresses the lateral or vertical boundaries of the operational area as defined by the applicable COA must be reported to the FAA's UAS Integration Off ice (AFS

- 80) within 24 hours. Accidents must be reported to the National Transportation Safet y Board (NTSB) per instructions contained on the NTSB Web site: www.ntsb.gov

. **2. Reasons Why An Exemption From The Requiremen ts Of Section 61.113(a)**  **And (b) Would Not Adversely Affect Safety.**
SkySalt Aerial, LLC submits that the equivalent level of safet y established by Section 61.113(a) and (b) will be maintained because no PIC will be allowed to operate the DJ I P h antom 3 and DJI I nspire 1 UASs unless that PI C has demonstrated, by meeting minimum flight-h our and currency requirements, that the PI C is able to safely o p erate the DJI Phantom 3 or DJ I In spire 1 UAS in a manner consistent with the exemption, including evasive and emergency maneuvers and maintaining appropriate distances from people,

v essels, vehicles and structures. C onsidering SkySalt Aerial, LLC ’s proposed area of operations, and the

o p er ating limitation s set forth -above; the parallel nature of private pilot aeronautical knowledge requirements to those of commercial pilot requirements (S ee Exemption No. 11062); and the airmanship skills necessary to safely o perate the DJ I Phantom 3 or DJ I Inspire 1 UAS, SkySalt Aerial, LLC submits that the additional manned a irmanship experience of a commercially certificated pilot would not correlate to the airmanship skills necessary for Sky Salt Aerial, LLC ’s specific proposed flight operation s.
The FAA has previously

granted relief from Section 61.113(a) and (b) specific to UAS, in circumstances similar, in all material respects, to those presented herein (e.g. Exemption Nos. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 1111 2, 11136, 11138, 11150, 11153, 11156, 11158, 11159, 11160, 11161). SkySalt Aerial, LLC will not allow any PI C to operate the DJI P han tom 3 or DJ I Inspire 1 UAS unless that PI C has demonstrated, by meeting minimum flight-ho u r
r equirements or the DJ I Phantom 3 or DJI I n spire 1 UAS training and currency
r equirements, that the PIC is able to safel y operate the DJ I P hantom 3 or DJI I n spire 1 UAS in a manner consistent with th is exemption, in clu ding evasive and emergency21

maneuvers and maintaining appropria te distances from people, vessels, vehicles and structures. Specificall y, the PI C must have accumulated and logged, in a manner consistent with 14 C.F.R. § 61.51(b), 25 hours of total time as a UAS rotorcraft pilot (with a minimum of 5 hours of those hour s as a UAS pilot operating the same make and model of UAS to be used for operations under the exemption). In addition to the hour requirements, the PI C must accomplish 3 takeoffs and landings in the preceding 90 day s (for currency purposes). As in Exempti o n Nos. 11062, 11138, and 11153, prior docu men ted flight

ex p erience that was obtained in compliance with applicable regulat ions will ensure an equivalent level of safet y during SkySalt Aerial, LLC ’s proposed operations. The Administrator has held that prior documented flight experience that was obtained in compliance with applicable regulations would ensure safe operations, stating as follows: In Exemption No. 11062, the FAA required that prior to conducting operations for the purpose of motion pictu re filming (or similar operations), the PIC must have accumulated and logged, in a manner consistent with 14 CFR 61.51(b), 25 hours of total time as a UAS rotorcraft pilot including at least 10 hours logged as a UAS pilot with a multi

- rotor UAS. Prior to operations under Exemption No. 11062, the PI C must also have accumulated and logged a minimum of 5 hours as a UAS pilot operating the same make and model of UAS to be used for operations under the exemption. For clarification, the FAA considers these minimum hour requirements to be inclusive rather than additive; i.e. 5 hours make and model time may be included in the 10 hours of multi

- rotor time and the 10 hours may be included in the total 25 hours of UAS rotorcraft time. In addition to the hour requiremen ts, the PI C must accomplish 3 takeoffs and landings in the preceding 90 day s (for currency purposes). The FAA finds that at a minimum, the flight- hour requirements in Exemption No. 11062 are appropriate to practice and build proficiency in the skills neces sary

to safely conduct the petitioner’s proposed operations. The FAA also finds that prior documented flight experience that was obtained in compliance with applicable regulations would satisfy this requirement. Training, proficiency
, and experience

- buildi ng flights can also be conducted under the grant of exemption to accomplish the required flight time. During training, proficiency , and experience

- building flights the PI C is required to operate the UA with appropriate distances in accordance with 14 C.F.R 91.119.
Exemption No. 11138 at page 15. Accordingl y, SkySalt Aerial, LLC will ensure safe operatio ns by not allowing an y P IC to operate the DJ I P h an to m 3 or DJI I nsp ire 1 UAS unless th at PI C has d emonstrated, b y meeting minimum f

light -h o u r an d cu rrency requirements, that the PI C is able to safel y
o perate the DJI Phantom 3 or DJ I I n spire 1 UAS in a manner consistent with t he

ex emp tio n , including evasive and emergency maneuvers and maintaining ap p r opriate d istan ces from people, vessels, vehicles and structures. **3. Reasons Why An Exemption From The Requirements Of Section 91.7(a) Would Not Adversely Affect Safety.** 
The eq u iv alen t level of safet y estab lished b y Section 91.7(a) will be maintained b ecause prior to every f

light, SkySalt Aerial, LLC will ensure that the DJ I22

Phantom 3 or DJI I nspire 1 UAS is in an airworthy condition based upon the UAS’s compliance with its operating documents an d as stated in the conditions and limitations herein. Additionally , the FAA has previously granted relief from Section 91.7(a) specific to UAS, in circumstances similar, in all material respects, to those presented herein (e.g. Exemption Nos. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 1111 2, 11136, 11138, 11150, 11153, 11156, 11157, 11158, 11159, 11160, 11161). **4. Reasons Why An Exemption From The Requirements Of Section 91.121 Would Not Adversely Affect Safety.** 
The equivalent level of safet y established b y Section 91.121 will be maintai ned because the altitude information of the DJ I P hantom 3 and DJ I Inspire 1 UAs will be p r ovided to the PI C via GPS equipment and a radio communications telemetry d ata link, which downlinks from the UA to the GCS for active monitoring of the flight path an d altitude. This altitude information, combined with SkySalt Aerial, LLC ’s operation of the DJ I Phantom 3 and DJI I nspire 1 UAs within visual line of sight, at or below 500 feet AGL, will ensure a level of safety equivalent to Section 91.121. The alt itude information will be generated b y GPS equipment installed onboard the aircraft. Prior to each flight, a zero altitude initiation point is automatically established by the UASs at ground level.

The FAA has previously

granted relief from Section 91.121 specific to UAS, in circumstances similar, in all material respects, to those presented herein (e.g. Exemption Nos. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11112, 11136, 11138, 11150, 11153, 11156, 11157, 11158, 11159, 11160, 11161). **5. Reasons Why An Exemption From The Requirements Of Section 91.151(b) Would Not Adversely Affect Safety.** 
A grant of this exemption would ensure an equivalent level of safety established by 14 C.F.R. Section 91.151(b) as a result of (1) the technical specifi cations of the DJ I Phantom 3 and DJI I nspire 1 UASs; (2) the limitations on the proposed flight operations; and (3) the location of the proposed flight operations. Accordingl y, SkySalt Aerial, LLC will ensure that it will safely operate the battery po wered DJ I Phantom 3 and D JI I nspire 1 UAs during day light hours in VFR conditions, with enough battery p o wer to fly for a total duration of 13.5 minutes to the first point of intended landing and, assuming n o r mal cruising speed, to fly after that for at le ast 4.5 minutes. Here, as in Exemption No. 11109, the technical specifications of th e DJ I P h antom 3 and DJ I Inspire 1 UASs; the limitations on the proposed flight operations; and the location of the proposed operations, will ensure an equivalent level of safet y established by 14 C.F.R. Section 91.151(b). Furthermore, saf et y will be ensured as the DJ I P hantom 3 and DJI I nspi r e 1 UASs provide audible and visual warnings to the P I C at the GCS when the UAs experiences low battery v o ltage, the first warning occur ring at approximately 3 3 % remaining battery p o wer, and again at appr o x imately 1 0 % r emaining battery po wer. At the

cr i tically low battery level, the DJ I P han tom 3 and DJI I nspire 1 UASs will descend and land a utomatically

. Significantl y, previous exemptions granted b y the FAA concerning Section 91.151 establish that safet y is not adversel y affected when the technical chara cteristics and operating limitations of the UAS are considered. Relief has been granted for manned23

aircraft to operate at less than the minimums prescribed in Section 91.151, including Exemption Nos. 2689, 5745, and 10650. Moreover, the FAA has previously granted relief from Section 91.151 specific to UAS, in circumstances similar, in all material respects, to those presented herein (e.g. Exemption Nos. 8811, 10808, 10673, 11042, 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 11136, 11138, 1 1150, 11153, 11156, 11157, 11158, 11159, 11160, 11161). **6. Reasons Why An Exemption From The Requirements Of Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), And 91.417(a) & (b) Would**  **Not Adversely Affect Safety.**
In seeking this exemption, SkySalt Aerial, LLC submits that the equivalent l evel of safety with regard to the regulatory maintenan ce and alteration requirements established by Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b) w ill be met b ecause SkySalt Aerial, LLC will use trained technicians to p erform maintenance, alterations, or preventive maintenance on the UASs using the methods, t echniqu es, and p r actices prescribed in the operating documents (i.e., the SkySalt Aerial, LLC Aerial Operatio ns Manual, Mo nthly Maintenance Lo g, and DJI Phantom 3 and DJ I I nspire 1 Instruction Manual). Furthermore, SkySalt Aerial, LLC will document and maintain all maintenance records for the DJI P hantom 2 an d

DJI I nspire 1 UASs.

Sin ce the DJ I Phantom 3 and DJ I In spire 1 UASs will be inspected as prescribed by the operating documents, SkySalt Aerial, LLC will maintain the equivalent level o f saf et y establish ed

b y Sections 91.405(a), 91.409(a)(1), and 91.409(a)(2). A cop y o f t he DJI Phantom 3 and DJ I Inspire 1 User Manuals are attached hereto as Exhibit C and D; a copy o f the DJ I P hantom 3 and DJ I Inspire 1 UAS Maintenance LOG is attached hereto as Exhibit E. Likewise, the ex emption sought will not adversel y affect safety beca use SkySalt Aerial, LLC will use trained technicians to perform maintenance, alterations or preventive maintenance on the UAS using the methods, techniques, and p r actices p r escribed b y t

he operating documen ts. Fu r th ermore, th e exemption sought would maintain an equivalent level of safet y established by Sections 91.407, 91.417(a) and 91.417(b), because all maintenance of the DJI Phantom 3 and DJ I I nspire 1 UASs will be performed b y trained technicians. Maintenance will be documented and maintained uti lizing the monthly maintenance log. Significantl y, previous exemptions granted b y the FAA concerning Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b) establish that safet y is not adversel y affected when the technical characteri stics and operating limitations of the UAS are considered. In consideration of Sk y Salt Aerial, LLC ’s proposed operating limitations, the

o p erating documents, and the technical aspects of the DJ I P hantom 3 and DJI I nspire 1 UASs, Sk y Salt Aer ial, LLC submits that safety will not be adversely affected by g r anting exemption from 14 C.F.R. Sections 91.405( a), 91.407(a)(1) and (a)(2)
, 9 1

. 4 0 9( a)(2), and 91.417(a) and (b). The FAA has previously gran ted relief specific to UAS in circumstances similar, in all material respects, to those presented herein (e.g. Exemption Nos. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 11112, 11136, 11138, 11150, 11153, 11156, 11157, 11158, 11159, 11160, 11161). **7. The FAA May Prescribe Any Other Condit ions For Safe Operation.** 24 In accordance with Section 333 of the FAA Modernization and Reform Act of 2012 (FMRA) and 14 C.F.R. § 21.16 entitled Special Conditions
, SkySalt Aerial, LLC r equests that the FAA prescribe special conditions f or the intend ed o p eration of the DJ I Phantom 3

an d DJI I nsp ir e 1 UASs, which contain such safety stan d ar d s th at the Administrator finds

n ecessary to establish a lev el of safet y equ iv alent to that established b y 14 C.F.R. Part 21, Subpart H, and 14 C.F.R §§ 6 1.113(a) & (b ), 9 1

. 7 (a), 91.121, 91.151(b), 91.405(a), 91.407( a)(1), 91.409( a)(1) & (a)(2), and 91.417(a) & (b). Such special conditions will permit safe operation of the UAs for the limited purpose of conducting aerial video and photograph y over certain areas of the United States for

co mp ensation or hire. FMRA Section 333 sets forth the requirements for con sider ing whether a UAS will create a hazard to users of the NAS or the public, or otherwise pose a threat to natio n al security; and further, provides the authority for such UAS to o p erate without airworthiness certification in accordance with an y requirements that must be established for the safe operation of the UAS in the NAS. Likewise, the Administrator may prescribe special conditions pursuant to 14 C.F.R. § 21.16, for operation of the DJI P h antom 3 and DJI I nspire 1 UASs, since the airworthiness regulations of 14 C.F.R. Part 21 do not contain adequate or appropriate safet y standards, due to the novel or unusual design features of the aircraft. Section 21.16, ent itled Special Conditions , states the following: If the FAA finds that the airworthiness regulations of this subchapter do not contain adequate or appropriate safet y standards for an aircraft, aircraft engine, or propeller because of a novel or unusual design feature of the aircraft, aircraft engine or propeller, he prescribes special conditions and amendments thereto for the product. The special conditions are issued in accordance with Part 11 of this chapter and contain such safety

standards for the aircr aft, aircraft engine or propeller as the FAA finds necessary

to establish a level of safety equivalent to that established in the regulations.

See 14 C.F.R. § 21.16. Ther ef o r e, in accordance with FMRA Section 333 and 14 C.F.R. § 21.16, the FA A may prescri b e special conditions for SkySalt Aer ial, LLC ’s intended operation of

th e DJ I Phantom 3 and DJI I nspire 1 UASs, wh ich co ntain such safety standards that the Administrator finds n ecessary to establish a level of safet y eq u ivalent to that establish ed b y 14 C.F.R. Part 21, Subpart H, and 14 C.F.R Sections 61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 91 .405(a), 91.407(a)(1), 91.40 9 (a)(1) & (a)(2), and 91.41 7 ( a) & (b).

**F. A Summary That Can Be Published In The**  **Federal Register, stating: The Rules**  **From W**  **hich** Sky Sa lt Aerial, LLC **Seeks Exemption:**
SkySalt Aerial, LLC seeks exemptio n from the req uirements of 14 C.F.R Sectio n s 61.113(a)&(b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1 ) & ( a ) (2), and 91.417(a) & (b).25 **A Brief Description Of The Nature Of The Exemption** SkySalt Aerial, L LC **Seeks:**

Th is exemption will permit SkySalt Aerial, LLC to commercially operate an Unmanned Aircraft System (UAS) for the purp ose of cond u cting aerial video and photography o ver certa in a rea s of the United States.

**G. Any Additional Information, Views, Or Arguments Available To Support**  SkySalt Aerial, LLC **’s Request.** 
This Petition is made pursuant to the FAA Modernization and Reform Act of 2012 (FMR A) Section 333, which directs th e Secretary o f Transportatio n to determine if certain UAS may o p erate safely in the NAS. As such
, SkySalt Aerial, LLC ’s request for exemption may b e g r anted pursuant to the authority of FMRA Section 333 and 14 C. F.R. Part 11, as set forth ab o ve. FMRA Section 333 sets forth the requirements for considering whether a UAS will create a hazard to users of the NAS or the public, or otherwise pose a threat to national securit y; and further, provides the authority for such UAS to operate without airworthiness certification. As discussed in detail above, SkySalt Aerial, LLC will operate the DJI Phan tom 3 and DJI I nsp ire 1 UASs safely in the NAS, without creating a hazard to users of t he NAS, or the public, or otherwise pose a threat to national securit y.

**CONCLUSION**

As set f orth herein, SkySalt Aerial, LLC seeks an exemptio n pursuant to 14 C.F.R. § 11.61 and Section 3 33 of the FAA Modernizatio n and Reform Act of 2012 ( FMRA), which will permit safe operation of the DJI Phantom 3 and DJ I Inspire 1 UASs

co mmerciall y, without an airworthiness certificate, for t he limited purpose of conducting aerial video and photography o v er certain areas of the United States. B y gr anting this Petition, the FAA Administrator will be fulfilling the Congressional mandate of the FAA Modernization and Reform Act of 2012, while also adv ancing the interests of the public, b y allowing Sk y Salt Aerial, LLC to safely , efficientl y , and economically operate the DJ I Phantom 3 and DJI I nspire 1 UASs commerciall y within the NAS. **W HEREFORE**  , in accor d ance with the Fed eral Aviation Reg ulat ions and th e FAA Modernization and Reform Act of 2012, Section 333, SkySalt Aerial, LLC resp ectfull y requests that the Administrator grant this Petition for an exemption from the r equirements

o f 1 4 C

. F. R Sections 61.113(a) & (b), 91.7(a), 91.121, 91. 151(b), 91 .4 05(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b), and permit SkySalt Aerial, LLC to o p er ate the DJ I Phantom 3 and DJI Inspire 1 UASs commerciall y for the purpose of conducting aerial video and pho tography over certain areas o f the Unite d States. Date d: June 11 , 201526 Respectfully Submitted SkySalt Aerial, LLC

_________________________ Tyler D. McCarty SkySalt Aerial, LLC
, President 2 626 Harney St Omaha, NE 68131 Tel: ( 402 ) 677-2442

EXHIBITS :

A

– DJ I Phantom 3 Specifications Data Sheet B – DJ I I nspire 1 Specifications Data Sheet C – DJI Phantom 3 Manufacturer’s User Manual D

– DJ I I n spire 1 Manufacturer’s User Manual E

– Mo n th ly Maintenance L o g F – DJI Inspire 1 Maintenance Manual

EXHIBIT

– A

**DJI PHANTOM** 3 **TECHNICAL SPECIFICATIONS** 
SkySalt Aerial, LLC only u tilizes safe and reliable UASs. DJ I i s an industry leader in small UAS production. DJI UASs are loaded with ground breaking software e nabling the user to set para meters which will not allow flight into controlled airspace.27

Parameters can also be set to limit flight to no higher than a predetermined and set altitude as well as limit f

l ight to a predetermined and set distance. In addition, DJI software provides real

- time altitude and location information to the PI C via the linked monitor (smart phone/tablet devices)

1

. 1 DJI Phantom 3

1.1.1 Aircraft 1

. 1

. 1.1 Supported Battery

– DJ I 4480 mAH LiPo 4S 15.2V Batter y 1 .1.1.2 Weight (Batter

y & Propellers I n cluded)

– 1 2 80g 1 .1.1.3 Hover Accuracy ( Ready to Fl y)

– Vertical: . 1 m; Horizontal: 1 .5m 1.1.1.4 Max Yaw Angular Velocit y
- 200 0 /s 1.1.1.5 Max Tilt Angel - 35 0 1.1.1.6 Max Ascent Speed

– 5 m/s 1 .1.1.7 Max Descent Speed

– 3 m/s 1.1.1.8 Max Flight Speed – 1 6 m/s

1.1.2 Gimbal 1

. 1 .2.1 Working Current

– Static: 750mA; Dy n amic: 900mA 1.1.2.2 Control Accuracy - ±0

. 03 0 1

. 1.2.3 Controllable Range

– Pitch: -90 0

- +3 0 0 1 .1.2.4 Maximum Angular Speed

– Pitch: 90 0 /s

1.1.3 Camera 1.1.3.1 Operating Temperature Rang e

- 32 0 F

- 104 0 F (0 0 C - 40 0 C) 1 .1.3.2 Sensor Size

– 1/2 .3” 1.1.3.3 Effective Pixels – 1 2.4 M 1

. 1 .3.4 Resolution

– 4 000 x3 000 4.1.3.5 HD Video Recording

– 4 096x2160 MAX 4

. 1 .3.6 Recording Field of View

- 110 0 /8 5 0

1.1.4 Transmitter 1

. 1 .4.1 Operating Frequency

– 2 .400 GHz-2.483 GHz 1 .1.4.2 Communication Distance (unobstructed)

– FCC Compliance: 2000 m 1 .1.4.3 Receiver Sen sitivity (1%PER)

- - 1 0 1 dBm 1.1.4.4 Transmitter Power – FCC Compliance: 20dBm 1 .1.4.5 Working Vo ltage

– 120mA@ 7.4 V28 EXHIBIT

– B

**DJI INSPIRE 1 TECHNICAL SPECIFICATIONS**  SkySalt Aerial, LLC only u tilizes safe and reliable UASs. DJ I i s an industry leader in small UAS production. DJI UASs are loaded with ground breaking software29

enabling the user to set parameters which will not allow flight into controlled airspace. Parameters can also be set to limit flight to no higher than a predetermined and set altitude as well as limit f

l ight to a predetermined and set distance. In addition, DJI software provides real

- time altitude and location information to the PI C via the linked monitor (smart phone/t ablet devices)

2.2 DJI Inspire 1

2.2.1 Aircraft 2.2.1.1 Model

– T600 2.2.1.2 Weight (Battery Included)

– 6lbs 7.5291oz (2935g) 2.2.1.3 Hovering Accuracy (GPS Mode)

– Vertical: 0.5m; Horizontal: 2.5m 2.2.1.4 Max Angular Velocity

– Pitch: 300 0/s; Yaw: 150 0/s 2.2.1.5 Max Tilt Angle

- 35 0 2.2.1.6 Max Ascent Speed

– 5m/s 2.2.1.7 Max Descent Speed

– 4m/s 2.2.1.8 Max Speed

– 22m/s (ATTI mode, no wind

– NOT RECOMMENDED) 2.2.1.9 Max Flight Altitude

– 4500m 2.2.1.10 Max Wind Resistance

– 10m/s 2.2.1.11 Max Flig ht Time

– Approximately 18 minutes 2.2.1.12 Motor Model

– DJI 3510 2.2.1.13 Propeller Model

– DJI 1345 2.2.1.14 Operating Temperature Range

– 14 0F to 1040F (

- 10 0C to 400C) 2.2.1.15 Dimensions

– 17 1⁄4” x 17 3⁄4” x 12”

2.2.2 Gimbal 2.2.2.1 Model

– ZENMUSE X3 2 .2.2.2 Output Power (with camera)

– Static: 9W; In Motion: 11W 2.2.2.3 Operating Current

– Static: 750mA; In Motion: 900mA 2.2.2.4 Angular Vibration Range

- ±0.03 0 2.2.2.5 Mounting

– Detachable 2.2.2.6 Controllable Range

– Pitch:

- 90 0 to +300; Pan: ±3200 2.2.2.7 Mechanical Range

– Pitch:

- 125 0 to 450; Pan: ±3300 2.2.2.8 Max Controllable Speed

– Pitch: 120 0/s; Pan: 1800/s

2.2.3 Camera 2.2.3.1 Name

– X3 2.2.3.2 Model

– FC350 2.2.3.3 Total Pixels

– 12.76M 2.2.3.4 Effective Pixels

– 12.4M 2.2.3.5 Image Max Si ze
– 4000x3000 2.2.3.6 ISO Range

– 100

- 3200 2.2.3.7 Field of View

- 94 0 2.2.3.8 CMOS

– Sony EXMOR 1/2.3”30 2.2.3.9 HD Video Recording

– UHD(4K): 4096x2160p24/25, 3840x2160p24/25/30; FHD: 1920x1080p24/25/30/48/50/60; HD: 1280x720p24/25/30/48/50/60 2.2.3.10 Op erating Temperature Range

- 32 0F

- 104 0F (00C

- 40 0C)

2.2.4 Transmitter 2.2.4.1 Name

– C1 2.2.4.2 Operating Frequency

– 5.728

- 5.850GHz; 2.400

- 2.483GHz 2.2.4.3 Communicating Distance (unobstructed)

– 2000m 2.2.4.4 Output Power

– 9W 2.2.4.5 Operating Temper ature Range

- 14 0F to 1040F (

- 10 0C to 400C) 2.2.4.6 Battery

– 600mAh LiPo 2S31 EXHIBIT

– C

DJI Phantom 3 Manufacturer’ s User Manual32 EXHIBIT

– D

DJI I nspire 1 Manufacturer’s User Manual33 month:_________year:________

**UAS:___________** Date Issue Discovered Dat e Issue

Addressed

Sof tware Updates

Airframe

Engi nes

Propellers

Camera Gimbal

Landing Gear

Vibration Dampening

Other: **MONTHLY MAINTENANCE LOG**

Issue Description & Maintenance Conducted Maintenance Performed By: Print & Sign EX H I BIT

– E

EXHIBIT

– F

DJI Inspire 1 Maintenance Manu al