1 UNITED STATES OF AMERI CA DEPARTMENT OF TRANSPORTATION FEDERAL AVIATION ADMINISTRATION

WASHI NGTON, DC

Regulatory

Docket No. _______________

**IN THE MATTER OF THE PETITION FOR EXEMPTION OF: ANDREW ADAM**  **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 THE**  **DJI INSPIRE 1 UNMANNED AIRCRAFT SYSTEMS**

**PURSUANT TO SECTION 333 OF THE FAA MODERNIZATION AND REFORM ACT OF 2012** 

**(PUBLIC LAW 112**
**- 95)** 

Submitted on November 30 , 2015

Andrew Adam 2382 Chad Crossing St. Charles, MO 63303 636

- 600

- 17112 **TABLE OF CONTENTS**  Page GLOSSARY OF ABBREVIAT IONS.................................................................................

........................... 3
SUMMARY.................................................................................................. .......................4
IN TRODUCTION AND INTERESTS OF PETITIONER.................................................4
BACKGROUND................................................................................................................5
BASI S FOR PETI TI ON..................................................................................................................... ......5
NAME AND ADDRESS OF PETITIONER.......................

........................................... ....6 THE SPEC IF IC SECTIONS OF 14 C.F.R. FROM WHI CH ANDREW ADAM SEEKS EXEMPTION........................................................................

.................................... ..........7 THE EXTENT OF RELIEF ANDREW ADAM SEEKS AND THE REASON ANDREW ADAM SEEK S THE RELIEF....................

............................................................. ......10 THE REASONS WHY GRANTING ANDREW ADAM’ s REQUEST WOULD BE IN THE PUBLIC INTEREST .../.......................

....................................... ............................1 3 THE REASONS WHY GRANTING THE EXEMPTI ON WOULD NOT ADVERSELY AFFECT SAFETY.................................................................

................................... ........15 CONCLUSION..............................

..................................................... .............................. 25 APPENDIX.....................................................................................................................

.. 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 Federal 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 In Command Section 333 FAA Modernization and Reform Act of 2012 (FMRA) 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 Conditions VTOL Vertical Takeoff and Landing4 **SUMMARY** Andre w Adam 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 333 of the FAA Moderniz ation and Reform Act of 2012 (FMRA). This exemption will permit Andrew Adam to operate an Unmanned Aircraft Sy stem (UAS) for the commercial purpose of conducting aerial video and photography of to be used in weddings, special events, sporting events, inspe ction purposes, real estate and news reports over certain areas of the United States.

**INTRODUCTION AND INTERESTS OF THE PETITIONER** My name is Andrew Adam, Iam 38 ye ars old, with a background in Mechanical Engineering, photography and videography . I currently freelance my

photography

and video services as well as work as a manager over a large generator repair facility . In addition to this Ihold a private pilot's license and a professional engineering license. M y areas of interests include photograph y, videography

. The objective is to offer services that will give customers additional option s when shooting video and photo s. Iwill strive to provide high qualit y imaging for a variet y of commercial and public uses, specifically targeting: ● Video for real estate purposes. ● Special events (weddings, concerts, private functions). ● Video and photos for business advertizing. ● Additional photo and video needs for design projects for m ys elf and contracted UAV needs for 3 rd part y design agencies.5 **BACKGROUND** Unmanned Aircraft Sy stems: DJIInspire 1 UAS Andrew Adam seeks an exemption to operate DJI sy stem for compensation or hire within the NAS. The DJIInspire 1 is a vertical takeoff and landing (VTOL) Unmanned Aircraft (UA) with a Ground Control Station (GCS) utilizing electronic tablet or smart phone s ys tems. 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 approximately 42 knots. The DJIInspire 1 UA is equipped with four main rotors; driven b y Li thium Poly mer battery

powered electric motors. The DJ I Inspire 1 UA that will be operated b y Andrew Adam will be registered in accordance with 49 U.S.C. 44103, Registration of Aircraft , as well as 14 C.F.R Part 47, Aircraft Registration , and marked in accordance with 14 C.F.R. Part 45, Identification and Registration Marking

. **BASIS FOR PETITION** Petitioner, Andrew Adam, pursuant to the provisions of the Federal Aviation Regulations (14 C.F.R. § 11.61) and the FAA Modernization and Reform Act of 2012 (FMRA), Section 333, Special Rules for Certain Unmanned Aircraft Systems , hereb y petitions the Admi nistrator to commerciall y operate the DJ I Inspire 1 UAS in the National Airspace Sy stem (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), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417 (a) & (b). In consideration of the speed, weight, size, and limited operating area associated with the unmanned aircraft and its operation, Andrew Adam operation of DJI Inspire 1 UAS meets the conditions of FMRA Section 333 and therefore, will not require an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H. Accordingl y, Andrew Adam requests relief from Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b), as these sections set forth requirements for mainten ance that onl y appl y to aircraft with an airworthiness certificate. Andrew Adam submits that the requested relief is proper since an equivalent level of safet y will be ensured. Andrew Adam will use experienced personnel or technicians to perform maintenan ce, alterations, or preventive maintenance on the UAS using the methods, techniques, and practices prescribed in the operating documents (i.e ., Monthly Maintenance Lo g, and DJIInspire 1 Instruction Manual). Furthermore, Andrew Adam wi ll document and maint ain all maintenance records for the and DJ I Inspire 1 UAS

. Relief from certain requirements of Section 61.113(a) and (b), entitled Private pilot privileges and limitations: Pilot in command, is requested b y Andrew Adam to the extent necessary

to allow a P ilot in Command (PIC) holding a private pilot or higher level certificate, as well as an airman medical certificate, and who has demonstrated, b y meeting minimum flight

- hour and currency requirements, that the PI C is able to safel y operate the DJ I Inspire 1 UAS in a manner consistent with this exemption, including evasive and emergency

maneuvers and maintaining appropriate distances from people, vessels, vehicles and structures.6 Andrew Adam seeks relief from Section 91.7(a), entitled Civil aircraft airw orthiness , because the DJ I Inspire 1 UAS does not require an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H. As such, Andrew Adam submits that he will ensure that the DJ I Inspire 1 UAS are in an airworth y condition, prior to every flight, b y determining that the UASs are in compliance with the operating documents (i.e., Monthly Maintenance Lo g, and the DJ I Inspire 1 Instruction Manual), and that the aircraft are in a condition for safe flight. Andrew Adam also seeks an exemption from the requirements of Section 91.121, entitled Altimeter Settings , as the DJ I Inspire 1 UAs will not have a ty pical barometric altimeter onboard. However, altitude information of the DJ I Inspire 1 UAs will be provided to the PI C via Global Positioning S ys tem (GPS) equipment and radio communications telemetry data link, which downlinks from the UA to the GCS for active monitoring of the flight path. This altitude information, combined with Andrew Adam’s operation of the DJ I Inspire 1 UAS within visual line of sight, at or below 500 feet AGL, will ensure a level of safety equivalent to Section 91.121. Additionally , Andrew Adam seeks an exemption from the requirements of Section 91.151(b), entitled Fuel requirements for flight in VFR condi tions . Andrew Adam submits that safety

will not be affected by

operation of the DJ I Inspire 1 UAs during daylight hours in visual meteorological conditions (VMC) under visual flight rules (VFR), with enough battery power to fl y for a total duration of approximately 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. In accordance with 14 C.F.R. § 11.81, Andrew Adam provides the following information in support of its petition for exemption:
**A. Name And Address Of The Petitioner.**  The name and address of the Petitioner and point of contact is: Andrew Adam 2382 Chad Crossing St. Charles, MO 633037

**B. The Specific Sections Of 14 C.F.R. From Which Andrew Adam Seeks Exemption.**  **1. Andrew Adam Seeks Exemption From The Requirements Of Section 61.113(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 carrying passengers or propert y for compensation or hire; nor may

that person, for compensation or hire, act a s 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 pa ssengers or property

for compensation or hire. **2. Andrew Adam Seeks Exemption From The Requirements Of Section 91.7(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. Andrew Adam Seeks Exemption From The Requirements Of Section**  **91.121.** 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 aircraft; (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) In 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. Andrew Adam Seeks Exemption From The Requirements Of Section**  **91.151(b).** Section 91. 151, entitled Fuel requirements for flight in VFR conditions , subsection (b), states the following:8 (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. Andrew Adam Seeks Exemption From The Requirement Of Section**  **91.405(a).** Section 91.405, entitled Maintenance required, subsection (a), states the following: Each owner or operator of an aircraft

— (a) Shall have that aircraft inspected as prescribed in subpart E of this part and shall between required inspections, except as provided in paragraph (c) of this section, have discrepanci es repaired as prescribed in part 43 of this chapter[.] **6. Andrew Adam Seeks Exemption From The Requirements Of Section 91.407(a)(1)**  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. Andrew Adam Seeks Exemption From The Requirements Of Sections 91.409(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 inspec tion for the issuance of an airworthiness certificate in accordance with part 21 of this chapter. **8. Andrew Adam Seeks Exemption From The Requirements Of Sections 91.417(a) And 91.417(b).**  Section 91.417, entitled Maintenance records , 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 aircraf t. The records must include

--9 (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 number of the person approving the aircraft for return to service. (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 cur

rent 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 safe ty directives including, for each, the method of compliance, the AD or safet y directive number and revision date. If the AD or safet y directive involves recurring action, the time and date when the next action is required. (vi) Copies of the forms 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 records speci fied 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 transferred wi th 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 service.10

**C. The Extent Of Relief Andrew Adam Seeks And The Reason Andrew Adam Seeks The Relief.**  **1. Extent Of Relief Andrew Adam Seeks And The Reason Andrew Adam Seeks Relief From Section 61.113(a) And (b).**  Relief from Section 61.113(a) and (b) entitled Private pi lot privileges and limitations: Pilot in command, is requested to the extent necessary to allow a PI C holding a private pilot or higher level certificate, as well as a current and valid airman medical certificate, and who has met certain flight

- hour and currency requirements, to conduct the proposed UAS flight operations for compensation or hire. This relief is requested since the limitations set forth in 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 not carry passengers or propert y for compensation or hire. As set forth more full y below, Andrew Adam submits that an equivalent level of safet y will be maintained because no PIC will be allowed to o perate the DJ I In spire 1 UAS unless that PI C has met certain flight

- hour and currency requirements, demonstrating that the PIC is able to safel y operate either the DJ I Inspire 1 UAS in a manner consistent with the operations specifications as described in this exemption, including evasive and emergency maneuvers, as well as maintaining appropriate distances from people, vessels, vehicles and structures. Further, Andrew Adam submits that all flights of the DJ I Inspire 1 UASs, conducted b y the PIC pursuant to the grant of this Petition: (1) will be incidental to Andrew Adam’s business; and (2) will not carry passengers or property

for compensation or hire.
**2. Extent Of Relief Andrew Adam Seeks And The Reason Andrew Adam**

**Seeks Relief From Section 91.7(a).**
R elief from Section 91.7(a) entitled Civil aircraft airworthiness , is requested to the extent required to allow Andrew Adam to determine that the DJ I Inspire 1 UASs are in airworth y condition prior to every flight b y ensuring that the UAS is in compliance w ith the operating documents (i.e., the Andrew Adam Aerial Operations Manual, Monthly Maintenance Log, and DJ I Inspire 1 Instruction Manual). Andrew Adam seeks the requested relief because the DJ I Inspire 1 UAS do not require an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H. Therefore, Andrew Adam will ensure that the and DJIInspire 1 UASs are in airworthy condition based upon its compliance with the operating documents (i.e ., Monthl y Maintenance Lo g, and DJIInspire 1 Instruction Manual) prior to every flight, and further, determine that the aircraft are in condition for safe flight, as stated in the conditions and limitations below.
**3. Extent Of Relief Andrew Adam Seeks And The Rea son Andrew Adam**  **Seeks Relief From Section 91.121.** Relief from Section 91.121, entitled Altimeter settings, may be required to allow11

flight operations of the DJIInspire 1 UASs, which utilize a barometric pressure sensor, GPS equipment, and a radio commun ications telemetry data link to downlink altitude information from the UA to the PI C at the ground control station (GCS). Since the FAA requires that an y altitude information concerning UAS operations be reported to air traffic control (ATC) in feet above ground level (AGL), Andrew Adam seeks the requested relief because the DJ I Inspire 1 UA altimeter may be set on the ground to zero feet AGL, rather than the local barometric pressure or field altitude, before each flight. Considering the limited altitude of the proposed operations, relief from 14 CFR 91.121 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 safety will be maintained since the DJIInspire 1 UAs are equipped with a barometric pressure sensor and GPS equipment, which automatically ensures that a ground level pressure setting will be established prior to each flight, and provides the PI C with altitude information of the UA on the heads

- up display of the GCS.
**4. Extent Of Relief Andrew Adam Seeks And The Reason Andrew Adam 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 a llow flights of the battery powered DJ I Inspire 1 UAs during daylight 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 cruisin g speed, to fly after that for at least 4.5 minutes. Andrew Adam seeks the requested relief because without an exemption from Section 91.151(b), the flight time duration of the battery powered DJ I Inspire 1 UAs will severel y constrain the practicalit y of any aerial video or still photo flight operations that Andrew Adam proposes to conduct pursuant to this Petition. Significantl y, as set forth below, the technical specifications of the DJ I Inspire 1 UAS, operating documents, and Andrew Adam proposed operat ing limitations, ensure that Andrew Adam will safel y operate the battery powered DJ I Inspire 1 UAs during daylight hours in visual meteorological conditions (VMC), under visual flight rules (VFR), with enough battery power to fl y for 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. Extent Of Relief Andrew Adam Seeks And The Reason Andrew Adam Seeks Relief From Sections 91.405(a), 91.407(a)(1), 91.409(**  **a)(1) & (a)(2), And 91.417(a) & (b).**  Since Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b) only appl y to aircraft with an airworthiness certificate, Andrew Adam requests relief from these Sections because the DJ I Inspire 1 UA Ss do not require airworthiness certificates. As set forth more fully below, DJ I In spire 1 UASs meet the conditions of FMRA Section 333 for operation without an airworthiness certificate. Accordingl y, Andrew Adam will use trained technicians to perform mai ntenance, alterations, or12

preventive maintenance on the UASs using the methods, techniques, and practices prescribed in the UAS operating documents (i.e., the Andrew Adam Aerial Operations Manual, Monthly

Maintenance Log, and DJ I Inspire 1 Instruction Manu al). Furthermore, Andrew Adam will document and maintain all maintenance records for the DJIInspire 1 UAS

.13

**D. The Reasons Why Granting Andrew Adam Request Would Be 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 Andrew Adam to safel y, efficiently, and econo mically perform aerial video and photograph y of construction sites, real estate, and landscape over certain areas of the United States. Additionally , DJ I Inspire 1 UASs will decrease congestion of the NAS, reduce pollution, and provide significant benefit s to the economy . Notably , the benefits of Andrew Adam’s proposed operation of the DJ I In spire 1 UASs will be realized without implicating an y privacy

issues. **1. The Public Will Benefit From Decreased Congestion Of The NAS.** The DJ I Inspire 1 UAs are battery powered and serve as a safe, efficient, and economical alternative to the manned aircraft traditionally utilized to obtain aerial imagery . By

reducing the amount of manned aircraft needed to perform aerial acquisitions, an exemption allowing the use o f a DJIInspire 1 UAS would reduce the amount of manned aircraft in the NAS, reduce noise and air pollution, as well as increase the safet y of life and property in the air and on the ground. Furthermore, b y reducing the number of manned aircraft operating in the NAS, congestion around airports caused b y arriving and departing aircraft will be reduced. The DJIInspire 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 by air traffic 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 Inspire 1 UAS.**  Cond ucting aerial acquisitions with the DJIInspire 1 UAS , instead of manned aircraft, will greatl y benefit the public by drastically

reducing the levels of air and noise pollution generated during traditional aerial video and still photography flight operatio ns. By using battery

power and electric motors, the DJIInspire 1 UAS produce no air pollution, and is the most viable environmentall y conscious alternative to the cabin class, six cylinder internal combustion engine aircraft that are t ypically utilized fo r aerial video and photograph y, while burning approximately 20

- 30 gallons per hour of leaded aviation fuel. The DJ I Inspire 1 UAs, while reducing the carbon footprint of aerial acquisitions, also eliminates noise pollution, as the UAs are propelled by batt ery powered electric motors, rather than an internal combustion engine. By using the DJ I Inspire 1 UAS to perform aerial acquisitions, the substantial risk to life and propert y in the air and on the ground, which is usually associated with traditional manned aircraft flight operations, will be substantially reduced or completel y eliminated. Aside from the lack of flight crew members located onboard the aircraft, the DJIInspire 1 UAs (weighing approximately 6 pounds 7.5 ounces , at maximum gross weight with length of 17.3 inches, widths of 17.7 inches, and with no fuel on board), has less phy sical potential for collateral damage to life and propert y on the ground, and in the air, compared to the manned aircraft that typicall y conduct similar operations (weighing14

approximately

6,000 pounds with a wingspan of approximately 42 feet, a length of 34 feet, and a fu el capacity

of 180 gallons). **3. Performing Aerial Video and Photography Operations With The DJI**  **Inspire 1 UAS Will Benefit The Economy.**  In addition to being safe and efficient, the DJ I Inspire 1 UAS are also an economical alternative to using manned ai rcraft to conduct similar aerial operations. As such, operation of the DJI Inspire 1 UAS will allow United States based companies, like Andrew Adam, to remain competitive 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 powered DJ I Inspire 1 UAS is one such technology that not only

allows companies greater operational flexibility compared to manned aircraft, but provides such flexibility without the high operational cost of a traditional manned aircraft. By operating the DJ I Inspir e 1 UASs, companies such as Andrew Adam, can remain competitive and profitable, and therefore, provide greater job stability to employees and contractors, which will ultimately contribute to growth of the U.S. econom y. Improved financial performance of U.S . companies, through commercial use of the DJ I Inspire 1 UAS , 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 compe titive both in the United States and abroad. **4. There Are No Privacy Issues.** Similar to the manned aerial acquisition flight operations that have been conducted for decades, Andrew Adam’s proposed operation of the DJ I Inspire 1 UASs will not implicate any

privacy issues. Specificall y, the DJ I Inspire 1 UAS will be operated onl y in compliance with operating documents (i.e., the Andrew Adam Aerial Operations Manual, Monthly Maintenance Log, and DJ I Inspire 1 Instruction Manual) which requires propert y owner involvement as well as local law enforcement notification, and in accordance w ith the Federal Aviation Regulations, including the minimum altitude requirements of 14 C.F.R. § 91.119.15

**E. The Reasons Why Granting The Exemption Would Not Adversely Affect Safety, Or How The Exemption Would Provide A Level Of Safety At Least**  **Equal To That Provided By The Rule From Which Andrew Adam Seeks Exemption.**  **1. Reasons Why The DJI Inspire 1 UAs Meet The Conditions Of The FAA Modernization and Reform Act of 2012 (FMRA) Section 333.**  In consideration of the size, weight, speed, and lim ited operating area associated with the unmanned aircraft and its operation, Andrew Adam’s operation of the DJ I Inspire 1 UAS meet the conditions of FMRA Section 333, and will not require an airworthiness certificate in accordance with 14 C.F.R. Part 21, S ubpart H. Section 333 provides authority for a UAS to operate without airworthiness 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 General.

--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 determi ne if certain unmanned aircraft systems may operate safely in the national airspace 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 hazard 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). (c) Requirements for Safe Operation.

--If the Sec retary 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 in the national airspace system.
In seeking this exemption, Andrew Adam submits that the DJ I Inspire 1 UAS can operate safel y in the NAS pursuant to FMRA Section 333, as demonstrated by : (a) the characteristics of the D JIInspire 1 UASs; (b) the pilot certification requirement; and (c) the specific operating limitations.

**a. The Specifications Of The DJI Inspire 1 UAS Demonstrate Its Safe Characteristics.** 16 The DJ I Inspire 1 UAS do es not create a hazard to users of the NAS or the public, or otherwise pose a threat to national security consid ering its size, weight, speed, and operational capability

.

**i. Technical Specifications Of The DJI Inspire 1 UAS.** The technical specifications of the DJ I Inspire 1 UAS are set forth b y the DJI Inspire 1 Specifications and Data Sheet, attached hereto as Appendix A

.

**ii. The DJI Inspire 1 UAS Autonomous Flight And Navigation Modes Enable The UAS To Remain Within A Defined Operational Area.**  The DJ I Inspire 1 UAS may be operated in both manual and full y autonomous flight modes. A complete description of the flight and navigational modes of the DJ I Inspire 1 UASs is provided at pages 12

- 16 and 45

- 50 of the DJ I Inspire 1 User Manua ls, attached hereto as Exhibit A

.

**iii. The DJI Inspire 1 UAS is**  **Designed For Automatic Return To Home Point Or Hover In The Ev**  **ent Of Loss Of The Control Link Or Navigation.**  When the Control L ink is lost, the DJIInspire 1 UAs will remain stationary, in flight, for 3 seconds or more. If, after 3 seconds, the DJ I Inspire 1 UAs do not reacquire control link data from the GCS, the UAs will assume that the Control L ink is lost and the UAs will return to the home position (i.e., failsafe mode) via GPS, and will descend to the takeoff position and shutdown. A complete description of the Failsafe Functions of the DJ I Inspire 1 at pages 13 through 15 of the DJ I Inspire 1 User Manuals, attached hereto as Exhibit A

.

**iv. The DJI Inspire 1 GCS And Its Operation.** A complete description of the operation and specifications of the DJ I Inspire 1 GCS and flight control software is provided at pages 40 through 43 of the DJIInspire 1 User Manual. The DJ I In spire 1 User Manual are attached hereto as Exhibits B

.

**b. Flight Operations Of the**  **DJI Inspire 1 UAS Are Limited To The Line**  **Of Sight Of A Certificated Pilot in Command With A Safety Observer.** Andrew Adam will only

utilize certificated pilots who possess a current and valid airman medical certificate to act as a pilot in command (PI C) of the DJ I In spire 1 UAS

. Additionally , a safet y observer will assist all pilots during flight time.

**c. Flight s**  **of the DJI Inspire 1**  **UASs Will Be Conducted Pursuant To Specific Operating Limitations.** 17 In seeking this exemption, Andrew Adam proposes to commerciall y operate the DJIInspire 1 UAS for the special purpose of conducting aerial video and photography ov er certain areas of United States, pursuant to the following specific operating limitations: 1. Operations authorized by this grant of exemption will be limited to the following aircraft described in the operating documents, rotorcraft UASs weighing less than 55 pounds maximum gross weight: DJ I Inspire 1 Unmanned Aircraft Sy stems. Proposed operations of any other aircraft will require a new petition or a petition to amend this grant. 2. UAS operations under this exemption will be limited to conducting op erations for the purpose of aerial video and photograph y. 3. The UA may

not be operated at a speed exceeding 43.5 knots (50 miles per hour). The exemption holder may use either groundspeed or calibrated airspeed to determine compliance with th e 43.5 knot speed restriction. In no case will the UA be operated at airspeeds greater than the maximum UA operating airspeed recommended by the aircraft manufacturer.
4. . The UA must be operated at an altitude of no more than 400 feet above ground level (AGL). Altitude must be reported in feet AGL. 5. The UA must be operated within visual line of sight (VLOS) of the PI C at all times. This requires the PIC to be able to u se human vision unaided by an y device other than corrective lenses, as specified on the PI C’s FAA

- issued airman medical certificate or U.S. driver’s license. 6. All operations must utilize a visual observer (VO). The UA must be operated within the visual line of sight (VLOS) of the PI C and VO at all times. The VO may be used to satisfy

the VLOS requirement as long as the PI C alway s maintains VL OS capability . Th e VO and PIC must be able to communicate verball y at all times; electronic messaging or texting is not permitted during flight operations. The PIC must be designated before the flight and cannot transfer his or her designation for the duration of the flight. The PI C must ensure that the VO can perform the duties required of the VO. 7. This exemption and all documents needed to operate the UAS and conduct its operations in accordance with the conditions and limitations stated in this grant of exemption, ar e hereinafter referred to as the operating documents. The operating documents must be accessible during UAS operations and made available to the Administrator upon request. If a discrepancy exists between the conditions and limitations in this exemption an d the procedures outlined in the operating documents, the conditions and limitations herein take precedence and must be followed. Otherwise, the operator must follow the procedures as outlined in its operating documents. The operator may update or revise i ts18 operating documents. It is the 4 operator’s responsibility to track such revisions and present updated and revised documents to the Administrator or an y law enforcement official upon request. The operator must also present updated and revised documents if it petitions for extension or amendment to this grant of exemption. If the operator determines that an y update or revision would affect the basis upon which the FAA granted this exemption, then the operator must petition for an amendment to its grant of exemption. The FAA’s UAS Integration Office (AFS −80) may be contacted if questions arise regarding updates or revisions to the operating documents. 8. Any UAS that has undergone maintenance or alterations that affect the UAS operation or flight characte ristics, e.g., replacement of a flight critical component, must undergo a functional test flight prior to conducting further operations under this exemption. Functional test flights may only be conducted by a PIC with a VO and must remain at least 500 feet from other people. The functional test flight must be conducted in such a manner so as to not pose an undue hazard to persons and propert y. 9. The operator is responsible for maintaining and inspecting the UAS to ensure that it is in a condition for saf e operation. 10. Prior to each flight, the PI C must conduct a pre

- flight inspection and determine the UAS is in a condition for safe flight. The pre

- flight inspection must account for all potential discrepancies, e.g., inoperable components, items, or eq

uipment. 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 UAS is found to be in a condition for safe flight. 11. The ope rator must follow the UAS manufacturer’s maintenance, overhaul, replacement, inspection, and life limit requirements for the aircraft and aircraft components. 12. Each UAS operated under this exemption must comply with all manufacturer safet y bulletins. 13. Under this grant of exemption, a PI C must hold either an airline transport, commercial, private, recreational, or sport pilot certificate. The PIC must also hold a current FAA airman medical certificate or a valid U.S. driver’s license issued by a st ate, the District of Columbia, Puerto Rico, a territory , a possession, or the Federal government. The PIC must also meet the flight review requirements specified in 14 CFR § 61.56 in an aircraft in which the PI C is rated on his or her pilot certificate. 14. The operator may

not permit any

PIC to operate unless the PI C demonstrates the ability

to safely operate the UAS in a manner consistent with how the UAS19 will be operated under this exemption, including evasive and emergency maneuvers and maintaining ap propriate distances from persons, vessels, vehicles and structures. PIC 5 qualification flight hours and currency must be logged in a manner consistent with 14 CFR § 61.51(b). Flights for the purposes of training the operator’s PI Cs and VOs (training, prof iciency , and experience

building) and determining the PIC’s ability to safely operate the UAS in a manner consistent with how the UAS will be operated under this exemption are permitted under the terms of this exemption. However, training operations may on ly be conducted during dedicated training sessions. 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 fro m nonparticipants in accordance with 14 CFR § 91.119. 15. UAS operations may

not be conducted during night, as defined in 14 CFR § 1.1. All operations must be conducted under visual meteorological conditions (VMC). Flights under special visual flight rul es (SVFR) are not authorized. 16. The UA may

not operate within 5 nautical miles of an airport reference point (ARP) as denoted in the current FAA Airport/Facility Directory

(AFD) or for airports not denoted with an ARP, the center of the airport s ymbol as denoted on the current FAA

- published aeronautical chart, unless a letter of agreement with that airport’s management is obtained or otherwise permitted b y a COA issued to the exemption holder. The letter of agreement with the airport management must be made available to the Administrator or an y law enforcement official upon request. 17. 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. 18. If the UAS loses communications or loses its GPS signal, the UA must return to a pre

- determined location within the private or controlled

- access property

. 19. The PI C must abort the flight in the event of unpredicted obstacles or emergencies.
20. T he PI C is prohibited from beginning a flight unless (considering wind and forecast weather conditions) there is enough available power for the UA to conduct the intended operation and to operate after that for at least five minutes or with the reserve powe r recommended b y the manufacturer if greater. 21. Air Traffic Organization (ATO) Certificate of Waiver or Authorization (COA). All operations shall be conducted in accordance with an ATO

- issued COA. The exemption holder may appl y for a new or amended COA if it intends to conduct operations that cannot be conducted under the terms of the20 attached COA. 22. All aircraft operated in accordance with this exemption must be identified by serial number, registered in accordance with 14 CFR part 47, and have ide ntification (N −Number) markings in accordance with 14 CFR part 45, Subpart C. Markings must be as large as practicable. 6 23. Documents used b y the operator to ensure the safe operation and flight of the UAS and an y documents required under 14 CFR §§ 91. 9 and 91.203 must be available to the PIC at the Ground Control Station of the UAS an y time the aircraft is operating. These documents must be made available to the Administrator or an y law enforcement official upon request. 24. The UA must remain clear and give way to all manned aviation operations and activities at all times. 25. The UAS may

not be operated b y the PIC from any moving device or vehicle. 26. All Flight operations must be conducted at least 500 feet from all nonparticipating persons, v essels, vehicles, and structures unless: a. Barriers or structures are present that sufficiently protect nonparticipating persons from the UA and/or debris in the event of an accident. The operator must ensure that nonparticipating persons remain under suc h protection. I f a situation arises where nonparticipating persons leave such protection and are within 500 feet of the UA, flight operations must cease immediatel y in a manner ensuring the safet y of nonparticipating persons; and b. The owner/controller of an y vessels, vehicles or structures has granted permission for operating closer to those objects and the PI C has made a safet y assessment of the risk of operating closer to those objects and determined that it does not present an undue hazard. The PI C, VO , operator trainees or essential persons are not considered nonparticipating persons under this exemption. 27. All operations shall be conducted over private or controlled

- access property with permission from the propert y owner/controller or authorized r epresentative. Permission from propert y owner/controller or authorized representative will be obtained for each flight to be conducted. 28. Any incident, accident, or flight operation that transgresses the lateral or vertical boundaries of the operationa l area as defined by the applicable COA must be reported to the FAA's UAS Integration Office (AFS −80) within 24 hours. Accidents must be reported to the National Transportation Safety Board (NTSB) per instructions contained on the NTSB Web site: www.ntsb.g ov. **2. Reasons Why An Exemption From The Requirements Of Section 61.113(a) And (b) Would Not Adversely Affect Safety.** 21 Andrew Adam submits that the equivalent level of safety established by Section 61.113(a) and (b) will be maintained because no PIC will be allowed to operate the DJ I Inspire 1 UAS unless that PI C has demonstrated, by meeting minimum flight

- hour and currency requirements, that the PI C is able to safely operate the DJ I Inspire 1 UAS in a manner consistent with the exemption , including e vasive and emergency maneuvers and maintaining appropriate distances from people, vessels, vehicles and structures. Considering Andrew Adam’s proposed area of operations, and the operating limitations set forth

- above; the parallel nature of private pilot aeronautical knowledge requirements to those of commercial pilot requirements (See Exemption No. 11062); and the airmanship skills necessary to safel y operate the DJ I Inspire 1 UAS, Andrew Adam submits that the additional manned airmanship experience of a commercially certificated pilot would not correlate to the airmanship skills necessary for Andrew Adam’s specific proposed flight operations. The FAA has previously

granted relief from Section 61.113(a) and (b) specific to UAS, in circumstances similar, i n 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, 11158, 11159, 11160, 11161). Andrew Adam will not allow any PIC to operate the DJ I Inspire 1 UAS unless that PI C has demonstrated, by meeting minimum flight

- hour requirements or the DJ I Inspire 1 UAS training and currency requirements, that the PI C is able to safely operate the DJ I Inspire 1 UAS in a manner consistent with this exemption, including evasive and emergency

maneuvers and maintaining appropriate 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 tot al time as a UAS rotorcraft pilot (with a minimum of 5 hours of those hours 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 PIC must accomplish 3 takeoffs and landings in the preceding 90 day s (for currency

purposes). As in Exemption Nos. 11062, 11138, and 11153, prior documented flight experience that was obtained in compliance with applicable regulations will ensure an equivalent level of safet y during Andre w Adam’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 pr ior to conducting operations for the purpose of motion picture 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 ho urs 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 hour s of UAS rotorcraft time. In addition to the hour requirements, the PIC must accomplish 3 takeoffs and landings in the preceding22 90 day s (for currency

purposes). The FAA finds that at a minimum, the flight

hour requirements in Exemption No. 11062 are appro priate to practice and build proficiency

in the skills necessary

to safel y 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 th is requirement. Training, proficiency , and experience

- building 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, Andrew Adam will ensure safe operations by not allowing an y PI C to operate the DJ I Inspire 1 UAS unless that PI C has demonstrated, by meeti ng minimum flight

- hour and currency

requirements, that the PIC is able to safel y operate the DJ I Inspire 1 UAS in a manner consistent with the exemption, including evasive and emergency

maneuvers and maintaining appropriate distances 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 equivalent level of safety established b y Section 91.7(a) will be maintained because prior to every

flight, Andrew Adam will ensure that the DJ I Inspire 1 UAS is in an airworth y condition based upon the UAS’s compliance with its operating documents and 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, 11112, 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 safety established b y Section 91.121 will be maintained because the altitude information of the DJ I Inspire 1 UAs wi ll be provided to the PI C via GPS equipment and a radio communications telemetry data link, which downlinks from the UA to the GCS for active monitoring of the flight path and altitude. This altitude information, combined with Andrew Adam’s operation of th e DJ I Inspire 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 altitude information will be generated by 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 No s. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11112, 11136, 11138,23

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 o f 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 specifications of the DJ I Inspire 1 UASs; (2) the limitations on the proposed flight operations; and (3) the location of the proposed flight operations. Accordingly , Andrew Adam will ensure that it will safel y operate the battery powered DJ I Inspire 1 UAs during daylight hours in VFR conditions, with enough battery power to fly

for a total duration of 13.5 minutes to the fi rst point of intended landing and, assuming normal cruising speed, to fl y after that for at least 4.5 minutes. Here, as in Exemption No. 11109, the technical specifications of the DJ I In spire 1 UASs; the limitations on the proposed flight operations; and the location of the proposed operations, will ensure an equivalent level of safety established b y 14 C.F.R. Section 91.151(b). Furthermore, safet y will be ensured as the DJ I Inspire 1 UASs provide audible and visual warnings to the PI C at the GCS when the UAs experiences low battery voltage, the first warning occurring at approximately 33% remaining battery

power, and again at approximately

10% remaining battery

power. At the criticall y low battery level, the DJ I Inspire 1 UASs will descend and land automat ically

. Significantl y, previous exemptions granted b y the FAA concerning Section 91.151 establish that safety is not adversely

affected when the technical characteristics and operating limitations of the UAS are considered. Relief has been granted for manned aircr aft 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, 11150, 11153, 11156, 11157, 11158, 11159, 11160, 11161). **6. Reasons Why An Exemption From The Requireme nts 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, Andrew Adam submits that the equivalent level of safet y with regard to the regulatory maintenance and alteration requirements established by Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b) will be met because Andrew Adam will use trained technicians to perform maintenance, alterations, or preventive maintenance on the UASs using the methods, techniques, and practices prescribed in the operating documents (i.e., the Andrew Adam Aerial Operations Manual, Monthly Maintenance Log, and the DJ I Inspire 1 Instruction Manual). Furthermore, Andrew Adam will document and maintain all maintenanc e records for the DJ I Inspire 1 UASs. Since the DJ I Inspire 1 UAS will be inspected as prescribed b y the operating documents, Andrew Adam will maintain the equivalent level of safety established by24

Sections 91.405(a), 91.409(a)(1), and 91.409(a)(2). A cop y of the DJ I Inspire 1 User Manuals are attached hereto as Exhibit A ; a copy of the DJ I Inspire 1 UAS Maintenance LOG is attached hereto as Exhibit B

. Likewise, the exemption sought will not adversel y affect safety because Andrew Adam will use trained tec hnicians to perform maintenance, alterations or preventive maintenance on the UAS using the methods, techniques, and practices prescribed by the operating documents. Furthermore, the exemption sought would maintain an equivalent level of safety established by

Sections 91.407, 91.417(a) and 91.417(b), because all maintenance of the DJIInspire 1 UASs will be performed by trained technicians. Maintenance will be document ed and maintained utilizing 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 safety is not adversel y affected when the technical characteristics and operating limitations of the UAS are considered. In consideration of Andrew Adam’s proposed operating limitations, the operating documents, and the technical aspects of the DJ I In spire 1 UASs, Andrew Adam submits that safet y will not be adversel y affected b y granting exemption from 14 C.F.R. Sections 91.405(a), 91.407(a)(1) and (a)(2), 91.409(a)(2), and 91.417(a) and (b). The FAA has previously

granted 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 Conditions For Safe Operation**
**.** 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, Andrew Adam requests that the FAA prescribe special conditions for the intended operation of the DJIInspire 1 UAS, which contain such safet y standards that the Administrator finds necessary to establish a level of safet y equivalent to that established by 14 C.F.R. Part 21, Subpart H, and 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). Such special conditions will permit safe operation of the UAs for the limited purpose of conducting aerial video and photography over certain areas of the United States for compensation or hire. 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 security ; and further, provides the authority

for such UAS to operate without airworthiness certificat ion in accordance with any 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 DJ I Inspire 1 UAS, since the ai rworthiness regulations of 14 C.F.R. Part 21 do not contain adequate or appropriate safety standards, due to the novel or unusual design features of the aircraft. Section 21.16, entitled Special Conditions, states the following:25 If the FAA finds that the airworthiness regulations of this subchapter do not contain adequate or appropriate safety 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 sp ecial conditions and amendments thereto for the product. The special conditions are issued in accordance with Part 11 of this chapter and contain such safet y standards for the aircraft, aircraft engine or propeller as the FAA finds necessary to establish a level of safet y equivalent to that established in the regulations. See 14 C.F.R. § 21.16. Therefore, in accordance with FMRA Section 333 and 14 C.F.R. § 21.16, the FAA may prescribe special conditions for Leading Edge’s intended operation of the DJ I Ins pire 1 UAS, which contain such safet y standards that the Administrator finds necessary to establish a level of safet y equivalent to that established by 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), 91.409(a)(1) & (a)(2), and 91.417(a) & (b).

● **A Summary That Can Be Published In The Federal Register, stating: The Rules From Which Andrew Adam Seeks Exemption:**  Andrew Adam seeks exemption from the requirements of 14 C.F.R Sections 61. 113(a)&(b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b). **A Brief Description Of The Nature Of The Exemption Andrew Adam Seeks:** This exemption will permit Andrew Adam to commercially operate an Unmanned Aircraft System (UAS) for the purpose of conducting aerial video and photography over certain areas of the United States.

● **Any Additional Information, Views, Or Arguments Available To Support Andrew Adam’s Request.**  This Petition is made pursuant to the FAA Modernization and Reform Act of 2012 (FMRA) Section 333, which directs the Secretary of Transportation to determine if certain UAS may

operate safel y in the NAS. As such, Andrew Adam’s request for exemption may

be granted pursuant to the auth ority of FMRA Section 333 and 14 C.F.R. Part 11, as set forth above. 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, Andrew Adam will operate the DJ I Inspire 1 UAS safel y in the NAS, without creating a hazard to users of the NAS, or the public, or oth erwise pose a threat to national securit y.26 **CONCLUSION** As set forth herein, Andrew Adam seeks an exemption pursuant to 14 C.F.R. § 11.61 and Section 333 of the FAA Modernization and Reform Act of 2012 (FMRA), which will permit safe operation of the DJ I Inspire 1 UAS commerciall y, without an airworthiness certificate, for the limited purpose of conducting aerial video and photograph y over certain areas of the United States. By granting this Petition, the FAA Administrator will be fulfilling the Congressio nal mandate of the FAA Modernization and Reform Act of 2012, while also advancing the interests of the public, by allowing Andrew Adam to safel y, efficientl y, and economically operate the DJ I Inspire 1 UAS commerciall y within the NAS. **WHEREFORE** , in accord ance with the Federal Aviation Regulations and the FAA Modernization and Reform Act of 2012, Section 333, Andrew Adam respectfull y requests that the Administrator grant this Petition for an exemption from the requirements of 14 C.F.R Sections 61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b), and permit Leading Edge to operate DJ I Inspire 1 UAS commercially for the purpose of conducting aerial video and photograph y over certain areas of the Unit ed States.

Dated: November 30 , 2015 Respectfully submitted, Andrew Ada

m

_________________________ Andrew Adam Andrew Adam 2382 Chad Crossing St. Charles, MO 63303 636

- 600

- 1711 Appendices: Appendix A

- DJIInspire 1 Specifications Data Sheet Attachments: Exhibit A

- DJIInspire 1 Operating and Instruction Manual Exhibit B

- Maintenance Log for the DJ I Inspire 127

Appendices : Appendix A

– DJIInspire 1 Specifications Data Sheet
APPENDIX

– A **DJI INSPIRE 1 TECHNICAL SPECIFICATIONS**  Andrew Adam only

utilizes safe and reliable UASs. DJIis an industry leader in small UAS production. DJ I UASs are loaded with ground breaking software 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 flight to a predetermined and set distance. In addition, DJIsoftware provides real

- time altitude and location information to the PI C via the linked monitor (smart phone/tablet devices) **DJI Inspire 1**
**Aircraft** ● Model

– T600 ● Weight (Battery Included)

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

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

– Pitch: 300 0/s; Yaw: 1500/s
● Max Tilt Angle

- 35 0
● Max Ascent Speed

– 5m/s
● Max Descent Speed

– 4m/s
● Max Speed

– 22m/s (ATTI mode, no wind

– NOT RECOMMENDED) ● Max Flight Altitude

– 4500m ● Max Wind Resistance

– 10m/s
● Max Flight Time

– Approximately 18 minutes ● Motor Model

– DJI 3510 ● Propeller Model

– DJI 1345 ● Operating Temperature Range

– 14 0F to 1040F (

- 10 0C to 400C)
● Dimensions

– 17 1⁄4” x 17 3⁄4” x 12”
**Gimbal** ● Model

– ZENMUSE X3 ● Output Power (with camera)

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

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

- ±0.03 0
● Mounting

– Detachable ● Controllable Range

– Pitch:

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

– Pitch:

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

– Pitch: 120 0/s; Pan: 1800/s28 **Camera** ● Name

– X3 ● Model

– FC350 ● Total Pixels

– 12.76M ● Effective Pixels

– 12.4M ● Image Max Size

– 4000x3000 ● ISO Range

– 100

- 3200 ● Field of View

- 94 0
● CMOS

– Sony EXMOR 1/2.3”
● HD Video Recording

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

- 32 0F

- 104 0F (00C

- 40 0C)
**Transmitter** ● Name

– C1 ● Operating Frequency

– 5.728

- 5.850GHz; 2.400

- 2.483GHz ● Communicating Distance (unobstructed)

– 2000m ● Output Power

– 9W ● Operating Temperature Range

- 14 0F to 1040F (

- 10 0C to 40 0C)
● Battery

– 600mAh LiPo 2S