UNITED STATES OF AMERICA DEPARTMENT OF TRANSPORTATION FEDERAL AVIATION ADMINISTRATION WASHINGTON, DC

Regulatory Docket No. _______________

**IN THE MATTER OF THE PETITION FOR EXEMPTION OF:**  **DFS A UTONOMOUS SYSTEMS,**  **LLC ,**  **FOR AN EXEMPTION**  **SEEKING RELIEF FROM**  **THE REQUIREMENTS OF TITLE 14 OF THE**  **CODE OF FEDERAL**  **REGULATION S**  **SECTIONS 61.23(a) & (c), 61.101(e)(4) & (e)(5),**  **61.113(a) ,**  **61.315(a), 91.7(a),**  **91.119(c), 91.121**  **, 91.151(**  **a )**  **(1) ,**  **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 AND DJI PHANTOM 2**  **UNMANNED AIRCRAFT SYSTEM S**  **PURSUAN T**  **TO SECTION 333**  **OF THE F**  **AA MODERNIZATION AND**  **REFORM ACT OF 2012**  **( PUBLIC LAW**  **112**

**- 95)** 

Submitted on July 20
, 201 5

G REGORY S

. W INTON , E SQ

. T HE A VIATION L AW F IRM 1997 Annapolis Exchange Parkway Suite 300 Annapolis, Maryland 21401 Tel: (301) 294

- 8550 Fax: (866) 568

- 9886 Attorney for Petitioner2 **TABLE OF CONTENTS** 
Page

GLOSSARY OF ABBREVIATIONS

................................ ................................ ................. 3

SUMMARY

................................ ................................ ................................ ......................... 4

INTRODUCTION AND INTERESTS OF PETITIONER

................................ ................. 4

BACKGROUND

................................ ................................ ................................ ................. 5

BASIS FOR THE PETITION

................................ ................................ .............................. 5

NAME AND ADDRESS OF THE PETITIONER

................................ ........................ 6

THE SPECIFIC SECTIONS OF 14 C.F.R. FROM WHICH DFS AUTONOMOUS SYSTEMS, LLC SEEKS EXEMPTION

................................ ................................ ....... 6

THE EXTENT OF RELIEF DFS AUTONOMOUS SYSTEMS, LLC SEEKS AND THE REASON DFS AUTONOMOUS SYSTEMS, LLC SEEKS THE RELIEF

........ 7

THE REASONS WHY GRANTING THE EXEMPTION WOULD NOT ADVERSELY AFFECT SAFETY

................................ ................................ .............. 10

THE REASONS WHY GRANTING DFS AUTONOMOUS SYSTEMS, LLC 'S REQUEST WOULD BE IN THE PUBLIC INTEREST

................................ ............ 23

SUMMARY THAT CAN BE PUBLISHED IN THE FEDERAL REGISTER

.......... 27

ANY ADDITIONAL INFORMATION, VIEWS, OR ARGUMENTS AVAILABLE TO SUPPORT DFS AUTONOMOUS SYSTEMS, LLC 'S REQUEST

.................... 27

CONCLUSION

................................ ................................ ................................ ................. 283 **GLOSSARY OF ABBREVIATIONS**

AGL Above Ground Level
AOI Area of Interest
ATC Air Traffic Control
ATO Air Traffic Organization
C.F.R. Code of Federal Regulation s
COA Certificate of Authorization

FAA Federal Aviation Administration

FAR Federal Aviation Regulation
FCC Federal Communications Commission
GCS Ground Control Station
GPS Global Positioning System
NAS National Airspace System
NOTAM Notice to Airmen
OEM Original Equipment Manufacturer
PIC Pilot I n Command

RTH Return To Home
Section 333 FAA Modernization and Reform Act of 2012 (FMRA) Section 333
UA Unmanned Aircraft
UAS Unmanned Aircraft System

VFR Visual Flight Rules
VLOS Visual Line of Sight
VMC Visual Meteorological Conditions
VO Visual Observer
VTOL Vertical Takeoff and Landing4 **SUMMARY**

DFS AUTONOMOUS SYSTEMS, LLC (hereinafter “DFS”) seeks exemption from the
requirements of 14 C.F.R

. §§ 61.23(a) & (c), 61.101(e)(4) & (e)(5), 61.113(a), 61.315(a),
91.7(a), 91.119(c), 91.121, 91.151( a ) (1)
, 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and
91.417(a) & (b) , to operate t wo ( 2 ) Unmanned Aircraft System s (UAS) pursuant to Section 333

of the FAA Modernization and Reform Act of 2012 (FMRA)

. This exem ption will permit DFS

to operate the Unmanned Aircraft System s for the commercial purpose s of aerial data collection

and establishing a UAS flight instruction program

.
**INTRODUCTION AND INTERESTS OF THE PETITIONER** 

DFS Autonomous Systems
, LLC is a new firm within t he Diplomat Group of Companies
that is focused upon providing UAS training. The Diplomat Group, which has 30+ years of
history and a demonstrated track record, has several entities engaged in international aviation,
logistics
, and construction. DFS Autonomous Systems has full benefit of the deep seated
relationships and well established market position held by its siste r Companies with in the Group.
With a tradition that began in the early 1980s
, The Diplomat Group of Companies has been a
leader in responding globally to complex logistical challenges through employing innovative

solutions
, backed by qualified individuals. With this bac kdrop, DFS Autonomous Solutions will
respond to the ever increasing demand for UAS based solutions within the marketplace.
Recogni zing the fledgling nature of the UAS industry at the commercial level, DFS
Autonomous Systems will build a product offering that is founded upon solid training and

c entered upon safety and compliance. DFS Autonomous Systems will be based at the Diplomat
Group’s Headquarters in Annapolis
, Maryland
, with an initial fi el d site in West Virginia and a
view to expand to other locati ons as required. DFS Autonomous Solutions will target a client5 base that include s the Oil and Gas Industry, Select Government Contractors, Construction firms,
Security Companies engaged with Duty of Care
, and other entities engaged in non

- combative

activi ties globally.

**BACKGROUND**
Unmanned Aircraft System s : DJI Inspire 1 and DJI Phantom 2

DFS seeks an exemption to operate the DJI Inspire 1 UAS ( Inspire 1 ) and DJI Phantom 2
UAS (Phantom 2) for compensation or hire within the NAS

. The Inspire 1 and Phantom 2 are
comprised of a vertical takeoff and landing (VTOL) Unmanned Aircraft (UA) and a Remote

Controller , with the Inspire 1 being capable of connecting to a Mobile Device . The Inspire 1 has
a maximum gros s weight , with payload, of approximately 7 .5 pounds ; m easures approximately

17.2 in. x 17.8 in. x 11.9 in. ; and ha s a maximum speed of approximately 4 2.8 knots

. The
Phantom 2 has a maximum gross weight, with payload, of approximately 2.7 pounds; measures
13.8 in. x 13.8 in. x 13.8 in.; and has a maximum speed of approximately 29.2 knots. The
Inspire 1 and Phantom 2 UA s are equipped with four rotors mounted in a quad

- copter
configuration
, each driven by a Lithium Polymer b attery powered electric motor.

The Inspire 1 and Phantom 2 (collectively “the subject UAS”) that will be operated by

DFS 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
, Identificat ion and Registration Marking

.
**BASIS FOR THE**  **PETITION**
DFS, by and through undersigned counsel, pursuant to the provisions of the Federal
Aviation Regulations (14 C.F.R. § 11.61) and the FAA Modernization and Reform Act of 2012,

Section 333, Special Rules for Certain Unmanned Aircraft Systems , hereby petitions the6 Administrator to operate the subject UAS within the National Airspace System (NAS), and for
an exemption from the requirements of 14 C.F.R. §§ 61.23(a) & (c), 61.101(e)(4) & (e)(5),
61.113(a), 61. 315(a), 91.7(a), 91.119(c), 91.121, 91.151(a)(1), 91.405(a), 91.407(a)(1),
91.409(a)(1) & (a)(2), and 91.417(a) & (b). In consideration of their size, weight, speed, and
limited operating area, DFS’ operation of the Inspire 1 UAS and Phantom 2 UAS meets th e

conditions of FMRA Section 333.

In accordance with 14 C.F.R. § 11.81, DFS provid es the following information in support
of its petition for exemption:

**A. Name A**  **nd Address Of**  **T he**  **Petitioner**

**.**
The name and address of the Petitioner is:

DFS Autonomous Systems, LLC 25 Shaw S treet Annapolis, MD 21401
The point of contact for this P etition and specific contact information is as follows:
Gregory S. Winton, Esq. The Aviation Law Firm 1997 Annapolis Exchange Parkway
, Suite 300 Annapolis, Maryland 21401 Tel: (301) 294

- 8550 | Fax: (866) 568

- 9886 Ema il: Greg@aviationlawexperts.com

**B. The Specific Sections Of 14 C.F.R. From Which**  **DFS Seeks Exemption.** 
DFS seeks exemption from the following sections of Title 14 of the C ode of F ederal

R egulations:

 **61.23(a) & (c)** , entitled Medical certificates: Requirement and durat ion

 **61.101(e)(4) & (e)(5)** , entitled Recreational pilot privileges and limitations

 **61.113(a)**
, entitled Private pilot privileges and limitations: Pilot in command7  **61.315(a)** , entitled What are the privileges and limitations of my sport pilot certificate

 **91.7 (a)**  , entitled Civil aircraft airworthiness

 **91.119(c)** , entitled Minimum safe altitudes: (c) Over other than congested areas

 **91.121** , entitled Altimeter settings

 **91.151(a)(1)** , entitled Fuel requirements for flight in VFR conditions

 **91.405(a)** , entitled Maintenance required

 **91.407(a)(1)** , entitled Operation after maintenance, preventative maintenance, rebuilding, or alteration

 **91.409(a)(1) & (a)(2)** , entitled Inspections

 **91.417(a) & (b)** , entitled Maintenance records

**C**

**. The Extent Of Relief**  **DFS Seeks And The Reason**  **DFS Seeks The**  **Relief**

**.**
**1. Extent of Relief**  **DFS Seeks And The Reason**  **DFS Seeks Relief From Section**  **61.23(a) & (c).**
Relief from Sections 61.23(a) & (c) entitled Medical certificates: Requirement and

duration
, is requested to the extent necessary to allow an adequately certificated PIC holding an

FAA

- issued medical certificate or U.S. issued driver’s license , to conduct the proposed UAS
flight operations for compensation or hire

. This relief is requested since the limitations set forth in Section 61.23(a) state that the
holder of a recreational pilot, private pilot, commercial pilot, or airline transport pilot certificate,
or flight instructor certificate must also hold the appropriate FAA

- issued medical certificate to

exercise the privileges of the pilot certificate. The relief is further requested since the limitations
set forth in Section 61.23(c) state that the holder of a sport pilot certificate must also hold a U.S.
issued driver’s license when exercising the privileges o f the certificate in a light sport aircraft.8 **2. Extent of Relief**  **DFS Seeks And The Reason**  **DFS Seeks Relief**  **From Sections 61.101(e)(4) & (e)(5), 61.113(a), and 61.315(a).** 
Relief from Sections 61.101(e)(4) & (e)(5), entitled Recreational pilot privileges and

limitations ; Section 61.113(a)
, entitled Private pilot privileges and limitations: Pilot in

command ; and Section 61.315(a), entitled What are the privileges and limits of my sport pilot

certificate
, is re quested to the extent necessary to allow a PIC holding a sport pilot, recreational
pilot, or private pilot certificate , as well as an airman medical certificate or U.S. issued driver’s

license, and who has met certain flight

- hour and currency requirements , to conduct the proposed

UAS flight operations for compensation or hire , subject to the conditions and limitations below.
This relief is requested since the l imitations set forth in Sections 61.101(e)(4) & (e)(5)
state that no person who holds a recreational pilot certificate may act as pilot in command of an
aircraft for compensation or hire or in furtherance of a business. Relief is requested from
61.113(a) since the limitations set forth in that section state that no person who holds a private
pilot certificate may act as pilot in command of an aircraft that is carrying passengers or property
for compensation or hire; nor may that person, for compensation or hire, act as pilot in command

of an aircraft

. Relief is requested from 61.315(a) since the limitations set forth in that section
only allow a person who holds a sport pilot certificate to act as pilot in command of a light

- sport

aircraft.

**3. Extent of Relief**  **DFS Seeks And The Reason**  **DFS 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 DFS to determine that the subject UAS are in an airworthy condition prior to
every flight by ensuring that the subject UAS are in compliance with their operating documents

.9 DFS seeks the requested relief because the subject UAS do es not require an airworthiness

certificate in accordance with 14 C.F.R. P art 21, Subpart H.

**4. Extent of Relief**  **DFS Seeks And The Reason**  **DFS Seeks Relief From Section**  **91.119(c).**
Relief from Section 91.119(c), entitled Minimum safe altitudes: (c) Over other than

congested areas , is required because all proposed operations of the subject UAS will take place
at an altitude at or below 400 feet AGL. This relief is requested since the limitations set forth in
Section 91.119(c) state that no person may operate an aircraft below 500 feet above the surface.
Additionally, relief from Section 91.119(c) is requested to the extent necessary to allow
operations to be conducted closer than 500 feet to persons, vessels, vehicles, or structures, under
certain conditions. This relief is requ ested since the limitations set forth in Section 91.119(c)
prohibit operating an aircraft closer than 500 feet to a person, vessel, vehicle, or structure.

**5. Extent**  **O f Relief**  **DFS Seeks And The Reason**  **DFS Seeks Relief**  **From Section 91.**  **121**

**.** Relief from Section 91.121, entitled Altimeter settings , may be required to allow flight
operations of the subject UAS
, because the subject UA S’ altitude reporting equipment may be

set on the ground to zero feet AGL, rather than local barometric pressure or field altitude, before
each flight. Considering the limited altitude of the proposed operations, relief from 14 C

. F

. R

. §

91.121 is sought to the extent necessary to comply with the applicable conditions and limitations

stated below.

**6. Extent Of Relief**  **DFS Seeks And The Reason**  **DFS Seeks Relief**  **From Section**  **91.151(a)(1).**

R elief from Section 91.151( a ) (1) entitled Fuel requirements for flight in VFR conditions
, is requested to the extent required to allow flights of the battery powered subject UAS during
daylight hours in visual meteorological conditions (VMC)
, under visual flight rules (VFR)

.10 DFS seeks the requested relief because without an exemption from Section 91.151(a)(1), the
flight time duration of the subject UAS will severely constrain the practicality of any aerial
acquisition and research flight operations that DFS prop oses to conduct pursuant to this Petition.

**7**

**. Extent O**  **f Relief DFS**  **Seeks And The Reaso n**  **DFS Seeks**  **Relief From**  **Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2),**  **A nd 91.417(a) & (b).** 

DFS requests relief from Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and
91.417(a) & (b) to the extent necessary to allow the proposed operations in accordance with the

co nditions and limitations set forth below. Since the aforementioned Sections only apply to

aircraft wit h an airworthiness certificate, DFS requests relief from these Sections because the
subject UAS do not require an airworthiness certificate.

**D. 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**  **DFS Seeks Exemption.** 

**1. Reasons Why The**  **Subject UAS Meet**  **The Conditions Of The FAA**  **Modernization and Reform Act of 2012 (FMRA) Section 333.**
In consideration of the size, weight, speed, and operating limitations associated with the
unmanned aircraft and their operation, DFS ’ operation of the subject UAS meets the conditions
of FMRA Section 333, and will not require an airworthiness certificate in accordance with 14
C.F.R. Part 21, Subpart H. In seeking this exemption, DFS submits that the Inspire 1 UAS and

Phantom 2 UAS can operate s afely in the NAS pursuant to FMRA Section 333, as demonstrated
by: (a) the characteristics of the Inspire 1 UAS and Phantom 2 UAS; (b) the pilot certification
requirement; and (c) the specific operating limitations. Additionally, the UAS and proposed

oper ations requested in this petition are similar in all material respects to relief previously
requested in Grant of Exemption Nos. 11062, 11109, 11112, 11213, 11394, 11977 , and 11982,11 and the reasons stated by the FAA for granting those Exemptions also apply to the present

situation.

**a. The Subject UAS**  **Are Safe For Use Based Upon**  **Their Size, Weight, Speed,**  **And Operational Limitations.**
The technical specifications of the Inspire 1 UAS are set forth at page s 5 7 through 60 of

the Inspire 1 User Manual, attached hereto as Exhibit A . Exhibit A contains proprietary
information and is to be held in a separate file. A complete description of the operation and
specifications of the Inspire 1 UAS Remote Controller and its s oftware is provided at pages 23
through 3 3 of the Inspire 1 User Manual , attached as Exhibit A

. The technical specifications of the Phantom 2 UAS are set forth at page 35 of the

Phantom 2 User Manual, attached hereto as Exhibit G . Exhibit G contains proprietar y
information and is to be held in a separate file. A complete description of the operation and
specifications of the Phantom 2 UAS Remote Controller and its s oftware is provided at pages 14
through 18 of the Phantom 2 User Manual , attached as Exhibit G

. Both UAS are compliant with
all Federal Communications Commission (FCC) requirements

.
**i. The**  Subject UAS’ Autonomous Flight **Modes and Failsafes**  **Enable Them**  **To Remain Within A Defined Operational**  **Area.**

The subject UAS are enabled to enter autonomous flight under certain contingency

situations or at the command of the PIC

. The subject UAS ’ autonomous features include the
following: a GPS Position and Altitude Hold when initiated by the Remote Controller ; a Return

To Home (RTH) function ; and Flight Limit ation ( i.e. , pre

- set limits that restrict t he distance and
height o f the UA S flight operations)

. A complete description of the autonomous features and

failsafes of the Inspire 1 UAS is provided at page s 12 through 1 6 and pages 45 through 48 of the
Inspire 1 User Manual, attached hereto as Exhibit A. A complete description of the autonomous12 features and failsafes of the Phantom 2 UAS is provided at pages 2 4 through 30 of the Phantom 2

User Manual, attached hereto as exhibit G.

**b. Flight Operations Of The**  **Subject UAS Are Limited To The**  **Line Of Sight Of A Certificated**  **Pilot In Command With A**  **Safety Observer.**

DFS will only utilize appropriately certificated p ilots who possess a current and valid

FAA issued airman m edical c ertificate or valid U.S. issued driver’s license to act as a pilot in

command (PIC) of the subject UAS. Additionally, a safety observer will assist all pilots during
flight operations.

**c. Flights**  **Of The Subject**  **UAS Will Be Conducted Pursuant To Specific**  **Operating Limitations.**

In seeking this exemption, DFS proposes to commercially operate the subject UAS for
the special purpose of conducting aerial acquisitions within the NAS , pursuant to the following
specific operating limitations:
1. Operations authorized by this grant of exemption are limited to the DJI Inspire 1 and DJI Phantom 2 Unmanned Aircraft System s when weighing less than 55 pounds including payload. Proposed operations of any other aircraft will require a new petition or a petition to amend this grant.

2. Operations for the purpose of closed

- set motion picture and television filming are not perm itted.

3. The UA may not be operated at a speed exceeding 87 knots (100 miles per hour). The exemption holder may use either groundspeed or calibrated airspeed to determine compliance with the 87 knot speed restriction. In no case will the UA be operate d 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 PIC at all times. This requires the PIC to be able to use human vision unaided by any device other than corrective lenses, as specified on the PIC’s FAA

- issued airman medical certificate or U.S. driver’s license

.13 6 . All operations must utilize a visual observer (VO). The UA must be operated within the visual line of sight (VLOS) of the PIC and VO at all times. The VO may be used to satisfy the VLOS requirement as long as the PIC always maintains VLOS cap ability

. The VO and PIC must be able to communicate verbally 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 o f the flight. The PIC must also 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, are 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 t his exemption and 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 up date or revise its operating documents. It is the operator’s responsibility to track such revisions and present updated and revised documents to the Administrator or any law enforcement official upon request. The operator must also present updated and revi sed documents if it petitions for extension or amendment to this grant of exemption. If the operator determines that any update or revision would affect the basis upon which the FAA granted this exemption, then the operator must petition for an amendment t o 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 fl ight characteristics, e.g. replacement of a flight critical component, must undergo a functional flight test 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 le ast 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 or property.

9

. The operator is responsible for maintaining and inspecting the UAS to ensure that it is in a conditi on for safe operation.

1 0

. Prior to each flight, the PIC 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, ite ms, or equipment. 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.

1 1 . The operator must follow the UAS manufacturer’s maintenance, overhaul, replacement, inspection, and life limit requirements for the aircraft and aircraft components

.14 1 2

. Each UAS operated under this exemption must comply with the manufacturer safety bulletins

.
1 3

. Under this grant of exemption, a PIC 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 iss ued by a state, 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 PIC is rated on his or her pilot cert ificate.

1 4

. The operator may not permit any PIC to operate unless the PIC demonstrates the ability to safely operate the UAS in a manner consistent with how the UAS will be operated under this exemption, including evasive and emergency maneuvers and main taining appropriate distances from persons, vessels, vehicles and structures. PIC 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 PICs and VOs (traini ng, proficiency, 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 operation s may only be conducted during dedicated training sessions. During training, proficiency, and experience

- building flights, all persons not essential for flight operations are considered nonparticipants in accordance with 14 CFR § 91.119.

1 5 . UAS operation s 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). Flights under special visual flight rules (SVFR) are not authorized.

16 . The UA may not operate within 5 na utical miles of an airport reference point (ARP) as denoted on a current FAA Airport/Facility Directory (AFD) or for airports not denoted with an ARP, the center of the airport symbol as denoted on the current FAA

- published aeronautical chart, unless a let ter of agreement with that airport’s management is obtained or otherwise permitted by a COA issued to the exemption holder. The letter of agreement with the airport management must be made available to the Administrator or any law enforcement official upon request

.
1 7 . 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 PIC.

18 . If the UA loses communications or loses its GPS signal, the UA must re turn to a pre

determined location within the private or controlled

- access property.

19 . The PIC must abort the flight in the event of unpredicted obstacles or emergencies

.
20 . The PIC is prohibited from beginning a flight unless (considering wind and for ecast weather conditions) there is enough power for the UA to conduct the intended operation15 and to operate after that for at least five minutes or within the reserve power recommended by 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 apply for a new or amended COA if it intends to conduct operations that cannot be conducted under the terms of the attached COA.

2 2 . 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 wit h 14 C

. F

. R

. part 45, Subpart C. Markings must be as large as practicable.
23. Documents used by the operator to ensure the safe operation and flight of the UAS and any documents required under 14 CFR §§91.9 and 91.203 must be available to the PIC at the Ground Control Station of the UAS any time the aircraft is operating. These documents must be made available to the Administrator or any 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 by the PIC from any moving device or vehicle.

26

. All Flight operations must be conducted at least 500 feet from all nonparticipating persons , vessels, 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 such protection. If a situation arises where nonparticipating persons leave such protection and are within 500 feet of the UA, flight operations must cease immediately in a manner ensuring the safety of nonparticipating persons; and
,
b. The owner/controller of any vessels, vehicles or structures has granted permission for operating closer to those objects and the PIC has made a safety assessment of the risk of operating closer to those objects and determined that it does not present an undue hazard.
The PIC, VO, operator trainees or essential pe rsons are not considered nonparticipating persons under this exemption.

27 . All operations shall be conducted over private or controlled

- access property with permission from the property owner/controller or authorized representative. Permission from the land owner/controller or authorized representative will be obtained for each flight to be conducted.16 28 . 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 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.gov.
If this exemption permits clos ed

- set motion picture and television filming and production, the following additional conditions and limitations apply.
29. The operator must have a motion picture and television operations manual (MPTOM) as documented in this grant of exemption.

30. At least 3 days before aerial filming, the operator of the UAS affected by this exemption must submit a written Plan of Activities to the local Flight Standards District Office (FSDO) with jurisdiction over the area of proposed filming. The 3

- day notification may be waived with the concurrence of the FSDO. The plan of activities must include at least the following:
a. Dates and times for all flights; b. Name and phone number of the operator for the UAS aerial filming conducted under this grant of exemptio n; c. Name and phone number of the person responsible for the on

- scene operation of the UAS; d. Make, model, and serial or N

- Number of UAS to be used; e. Name and certificate number of UAS PICs involved in the aerial filming; f. A statement that the o perator has obtained permission from property owners and/or local officials to conduct the filming production event; the list of those who gave permission must be made available to the inspector upon request; g. Signature of exemption holder or representative; and h. A description of the flight activity, including maps or diagrams of any area, city, town, county, and/or state over which filming will be conducted and the altitudes essential to accomplish the operation.
31. Flight operation may be conducted closer than 500 feet from participating persons consenting to be involved and necessary for the filming production, as specified in the exemption holder’s MPTOM.

**2. Reasons Why An Exemption From The Requirements Of Sections 61.23(a) &**  **(c) Would Not Adversely Affect Safety.**

DFS submits that an equivalent level of safety established by Sections 61.23(a) & (c) will
be maintained because no PIC will be allowed to operate the subject UAS unless that PIC holds

either a valid FAA

- issued medical certificate or a valid U.S. issued dr iver’s license.17 Additionally, no PIC will be allowed to operate the subject UAS unless that PIC has
demonstrated, by meeting minimum flight

- hour and currency requirements, that the PIC is able
to safely operate the subject UAS in a manner consistent with the exemption, including evasive
and emergency maneuvers and maintaining appropriate distances from people, vessels, vehicles,

and structures.
Considering DFS ’ proposed area of operations, the relatively small size of the subject
UAS, and the operating li mitations set forth in this Petition, as well as the parallel nature of sport
pilot, recreational pilot, and private pilot medical requirements, relating to the proposed
operations, DFS submits the additional requirements of at least a third

- class airman m edical

certificate would not correlate to DFS ’ proposed operations.

**3. Reasons Why An Exemption From The Requirements Of Section**  **s 61.101(e)(4) & (e)(5), 61.113(a), and 61.315(a)**  **Would Not Adversely Affect Safety.** 

DFS submits that an equivalent level of safety established by Section s 61.101(e)(4) &
(e)(5), 61.113(a), and 61.315(a ) will be maintained because no PIC will be allowed to operate t he
subject UAS unless that PIC has demonstrated, by meeting minimum flight

- hour and currency
requirements, that the PIC is able to safely operate the subject UAS in a manner consistent with

th e exemption, including evasive and emergency maneuvers and maintaining appropriate
distances from people, vessels, vehicles
, and structures.
Specifically, the PIC 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 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 un der
the exemption). In addition to the hour requirements, the PIC must accomplish 3 take

- offs and
landings in the preceding 90 days (for currency purposes).18 Considering DFS ’ proposed area of operations, and the operating limitations set forth
above; the parallel nature of sport pilot, recreational pilot, and private pilot aeronautical
knowledge requirements, with respect to the proposed operations, to those of commercial pilot
requirements ( See Exemption No s . 11062 and 11213 ); and the airmanshi p skills necessary to
safely operate the subject UAS, DFS submits that the additional manned airmanship experience
of a commercially certificated pilot would not correlate to the airmanship skills necessary for

DFS ’ s spec ific proposed flight operations.
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 safety
during DFS ’ 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 c onducting 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 hours logg ed as a UAS pilot with a multi

- rotor UAS. Prior to operations under Exemption No. 11062, the PIC 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 exemptio n. 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 requirements, the PIC must accomplish 3 take

- offs and landings in the preceding 90 days (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 necessary to safely conduct DFS ’s proposed operations. The FAA also finds that prior documented flight experience that was obtained in compliance with applicable regulations would satisfy this requirement. Tr aining, 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 PIC is required to operate the UA with appropr iate distances in accordance with 14 C.F.R 91.119.
Exemption No. 11138 at page 15.19 Accordingly, DFS will ensure safe operations by not allow ing any PIC to operate the
subject UAS unless that PIC has demonstrated
, by meeting minimum flight

- hour and currency
requirements
, that the PIC is able to safely operate the subject UAS in a manner consistent with

the exemption, including evasive and emergency maneuvers and maintaining appropriate
distances from people, vessels, vehicles and structures.

**4**

**. Reasons Why An Exemption From The Requirements Of Section 91.7(a)**  **Would Not Adversely Affect Safety.**
The equivalent level of safety established by Section 91.7(a) will be maintained because
prior to every flight, DFS will ensure that th e subject UAS is in an airworthy condition based
upon the its compliance with its relevant operating documents , and as stated in the conditions

and limitations herein.

**5. Reasons Why An Exemption From The Requirements Of Section 91.119(c)**  **Would Not Adversely Affect Safety.**
The equivalent level of safety established by Section 91.119(c) will be maintained
because in any operation to be conducted closer than 500 feet from any nonparticipating persons,
barriers or structures will be present to sufficiently protect any nonparticipating persons from
debris in the event of an accident during operation of the subject UAS, which weigh less than
eight (8) pounds and wil l be operated below an altitude of 400 feet AGL. The nonparticipating
persons will be required to remain in the area of protection, and if any nonparticipating person
leaves the area of protection and is within 500 feet of the subject UAS, flight operation s will
cease immediately.
Additionally, any operation to be conducted closer than 500 feet from persons, vessels,
vehicles, and structures would first require the permission of the land owner/controller and a
safety assessment of the risk of operating clo ser to those objects by the PIC.20 **6. Reasons Why An Exemption From The Requirements Of Section 91.121**  **Would Not Adversely Affect Safety.**
The equivalent level of safety established by Section 91.121 will be maintained because

the altitude of the subject UAS will be reported to air traffic control (ATC) in feet above ground
level (AGL), and DFS will operate the subject UA S within visual line of sight, at or below 400

feet AGL. Furthermore, the altitude information of the Inspire 1 UAS will be provided to the

PIC via a barometric pressure sensor , GPS equipment , a Visual Positioning System using
ultrasonic and image data, and a radio communications telemetry data link, which downlinks

from the UA to the Remote Controller for active monitoring of the flight path and altitude

. The
altitude information of the Phantom 2 UAS will be provided to the PIC via a barometric pressure
sensor, GPS equipment, and a radio commu nications telemetry data link, which downlinks from
the UAS to the remote controller for active monitoring of altitude. Prior to each flight, a zero
altitude initiation point is automatically established by the UAS at ground level.

**7**

**. Reasons Why An Exemption From The Requirements Of S**  **ection 91.151(a)(1) Would Not Adversely Affect Safety.** 
A grant of this exemption would ensure an equiv a lent level of safety established by 14
C.F.R. Section 91.151(a)(1) as a result of (1) the technical specifications of the subject UAS ; (2)
the limitations on the proposed flight operations ; and (3) the location of the proposed flight
operations

. Accordingly, DFS will ensure that it will safely operate the battery p owered subject

UA S during daylight hours in visual metrological conditions (VMC) under visual flight rules
(VFR) , with enough battery power for the subject UA S to fly after th e first point of intended
landing for at least five (5) minutes

. In addition to the level of safety established by the technical specifications of the UAS;
the limitations on the proposed flight operations; and the location of the proposed operations, the21 subject UAS provide audible and visual warnings to the PIC at the Remote Controller when the
UA has low battery power remaining. Together, these factors will ensure an equivalent level of
safety established by 14 C.F.R. Section 91.151(a)(1).
Previous exemptions granted by the FAA concer ning Section 91.151, establish that safety
is not adversely affected when the technical characteristics and operating limitations of the
subject UAS are considered. Relief has also been granted for manned aircraft to operate at less
than the minimums pres cribed in Section 91.151, including Exemption Nos. 2689, 5745, and

10650.

**8**

**. 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, DFS submits that the equivalent level of safety 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 a ll maintenance,

alterations, and preventive maintenance of the subject UAS performed by DFS will be in

accordance with the methods, techniques, and practices prescribed in the operating documents

. Furthermore, only the O riginal Equipment Manufacturer (OEM) or qualified OEM maintainers
will perform higher level inspections and maintenance per the operating documents and OEM

standards. DFS will document and maintain all maintenance records for the subject UAS.
Since the subject UAS will be inspected as prescribed by the operating documents,

DFS will maintain the equivalent level of safety established by Sections 91.405(a), 91.409(a)(1),
and 91.409(a)(2). The following operating documents are attached hereto, identified as the
following Exhibits: (A ) The Inspire 1 User Manua l; (B) The Inspire 1 Quick Start Guide; (C)

The Inspire 1 Safety Guidelines ; (D) The Inspire 1 Intelligent Flight Battery Safety Guidelines ;22 (E) The Inspire 1 Maintenance Manual; (F) The Inspire 1 Charging Hub User Manual; (G) The

Phantom 2 User Ma nual; (H) The Phantom 2 Quick Start Guide; and (I) The Phantom 2 Flight
Battery Safety Guidelines

. The foregoing exhibits contain proprietary information and are to be
held in a separate file pursuant to 14 C.F.R. § 11.35(b).
Additionally , a n equivalent level of safety established by Sections 91.407 (a)(1)
, 91.417(a)
, and 91.417(b) will be maintained because DFS will document and maintain all of the

maintenance records for the subject UAS

.
**9. The FAA May Prescribe Any Other Conditions For Safe Operation.** 

In accordance with Section 333 of the FAA Moderni zation and Reform Act of 2012
(FMRA) and 14 C.F.R. § 21.16 entitled Special Conditions
, DFS requests that the FAA prescribe
special conditions for the intended operation of the subject UAS, which contain such safety
standards that the Administrator finds necessary to establish a level of safety equivalent to that
established by 14 C.F.R. Part 21, Subpart H, and 14 C.F.R. §§ 61.23(a) & (c), 61.101(e)(4) &
(e)(5), 61.113(a), 61.315(a), 91. 7(a), 91.119(c), 91.121, 91.151(a), 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 subject UAS for the limited purpose of conducting aerial acquisitions and establishing a

UAS flight instruction program within the NAS 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 otherwi se pose a threat to national security; and further, provides the
authority for such UAS to operate without airworthiness certification 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.23 § 21.16, for operation of the Phantom 3 UAS, since the airworthiness 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:
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 p ropeller, 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 aircraft, aircraft engine or propeller as the FAA find s necessary to establish a level of safety 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 DFS ’ intended operation of the subject UAS, which contain such
safety standards that the Administrator finds necessary to establish a level of safety equivalent to
that established by 14 C.F.R. Part 21, Subpart H, and 14 C.F.R Section s 61.23(a) & (c),
61.101(e)(4) & (e)(5), 61.113(a), 61.315(a), 91.7(a), 91.119(c), 91.121, 91.151(a), 91.405(a),
91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b).

**E**

**. The Reasons Why Granting**  **DFS** ’ 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 by allowing DFS to safely,
efficiently, and economically perform aerial acquisitions and research within the NAS
, commercially, in support of the Oil and Gas Industry, Select Government Contractors,
Construction firms, Security Companies engaged with Duty of Care
, and other entities engaged

in non

- combative activities globally

. A Grant of Exemption for the present petition would also
further the public interest by allowing DFS to safely, efficiently, and economically instruct
individuals on how to operate UAS within the NAS

. Permitting DFS to utilize UAS in a flight
instruction program would allow for a safe and controlled environment in which to help guide24 those with an interest in the fast developing UAS industry on how to comply with the continuing
guidance provided by the FAA and th e industry best practices. Additionally, use of the subject
UAS will decrease congestion of the NAS, reduce pollution, and provide significant benefits to
the economy. Notably, the benefits of DFS ’ proposed operation of the subject UAS will be
realized without implicating any privacy issues.

**1. The Public Will Benefit From**  **Having Trained UAS Pilots Available For Commercial Operations.** 

DFS submits this Petition in part to commercially operate the subject UAS in order to
instruct individuals on how to operate a UAS within the NAS and help ensure that there are well
trained and qualified pilots available to perform commercial operations in the fast developing
UAS industry. This will help provide those conducting operations such as geospatial data
collection, aerial photography, and infrastructure inspection with individuals specifically trained
to fly UAS and that are familiar with the safety procedures and how they differ from those of

traditional manned aircraft

. As UAS regulations and standards are being developed by the FAA,
allowing companies such as DFS to conduct operator instruction under an FAA approved Grant
of Exemption will provide the aviation community with a means to promote safe UAS operation
in the interim period prior to a final FAA rule governing UAS. Further, these proposed
operations are similar in all material respects to those in Grant of Exemption Nos. 11983, 11404,

and 11394.

**2. The Publi**  **c Will Benefit From Decreased Congestion Of The NAS.**

The subject 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 use25 of the subject UAS wou ld reduce the amount of manned aircraft in the NAS, reduce noise and air
pollution, and increase the safety of life and property in the air and on the ground.
Furthermore, by reducing the number of manned aircraft operating in the NAS,
congestion around airports caused by arriving and departing aircraft will be reduced. The subject

UAS do not require an airport to takeoff or land. Likewise, a reduction of manned aircraft
conducting aerial survey missions would result in fewer aircraft that must be ha ndled by air
traffic control during the ground, takeoff, departure, arrival, and landing phases of flight
operations.

**3**

**. The Public Will Benefit From The Safety And Efficiency Of The**  **Subject UAS.** 
Conducting aerial acquisitions with the subject UAS , instead of manned aircraft, will
greatly benefit the public by drastically reducing the levels of air and noise pollution generated
during traditional aerial survey flight operations. By using battery p ower and electric moto r s , the
subject UAS produc e no air pollution, and are the most viable environmentally conscious
alternative to the cabin class, six cylinder internal combustion twin engine aircraft that are
typically utilized for aerial acquisitions
, and burn approximately 20

- 30 gallons per hour of leaded

aviation fuel. The subject UAS , while reducing the carbon footprint of aerial acquisitions , also

reduce s noise pollution, as the y are propelled by battery powered electric motors, rather than

i nternal combustion engine s

. By using the subject UAS to perform aerial acquisitions, the substantial risk to life and
property in the air and on the ground, which is usually associated with traditional manned aircraft
flight operations, will be substantially reduced or completely eliminated. Aside from the lack of
flightcrew members located onboard the aircraft, the subject UAS , ha ve less physical potential for
collateral damage to life and property on the ground, and in the air, compared to the manned26 aircraft that typically conduct aerial acquisitions (weighing approximately 6,500 pounds with a
wingspan of approximately 40 feet, a length of 34 feet, and a fuel capacity of 180 gallons).
Additionally, using the subject UAS to perform aerial acquisitions will increase the level
of safety and efficiency for DFS’ employees, associated contractors, and public employees by
minimizing exposure to a number of hazards typically encountered in a field environment, such as
bridges, wetland areas, and steep terrain, as well as lowering the number of incidents and
associated costs, such as maintaining a certain level of insurance, that normally coincide with
operations in a hazardous field environment.

**4**

**. Performing Aerial Acquisition Operations With The**  **Subject UAS**  **Will Benefit The Economy.** 
In addition to being safe and efficient, the subject UAS are also an economical alternative
to using manned aircraft to conduct aerial acquisitions . As such, operation of the subject UAS
will allow United States based companies, like DFS , to remain competitive and contribute to
growth of the U.S. economy. Specifically, 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. Operati on of UAS such as those in this petition is one such technology that
not only allows companies greater operational flexibility compared to manned aircra ft, but
provides such flexibility without the high operational cost of a traditional manned aircraft.
By operating UAS , companies such as DFS
, can remain competitive and profitable, and
therefore, provide greater job stability to employees and c ontractors, which will ultimately
contribute to growth of the U.S. economy. Improved financial performance of U.S. companies,
through commercial use of the subject , provides a stable workforce that increases consumer27 spending; improves local, state, and f ederal tax revenues; and allows companies to invest in
research and development in order to remain competitive both in the United States and abroad.

**5**

**. There Are No Privacy**  **Issues**

**.** Similar to the manned aerial acquisition flight operations that have been conducted for

d ecades, DFS ’ proposed operation of the subject UAS will not implicate any privacy issues.
Specifically, the subject UAS will only be operated pursuant to the specific conditions and

limitations set forth herein , and in accordance with the Federal Aviation Regulations, including
the minimum altitude requirements of 14 C.F.R. § 91.119. Most significantly, the subject UAS
will not be operated closer than 500 feet to any person, vessel, vehicle, or structure, that is not
directly involved in the operation unless specific conditions are met

.
**F. A**  **S ummary**  **That C an**  **Be P ublish**  **ed In T he**  Federal Register, **stating: The Rules From Which**  **DFS Seeks Exemption:** 

DFS Autonomous Systems , LLC seeks exemption from the requirements of 14 C.F.R

. Sections 61.23(a) & (c), 61.101(e)(4) & (e)(5), 61.113(a), 61.315(a), 91.7(a), 91.119(c), 91.121, 91.151(a), 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 DFS**  **Seeks:**

This exemption will permit DFS Autonomous Systems , LLC to commercially operate two Unmanned Aircraft System s (UAS) for the purpose s of conducting aerial acquisitions and establishing a UAS flight instruction program within the National Airspace System (NAS)

.
**G. Any Additional Information, Views,**  **Or Arguments Available To Support DFS**  ’ **Request.**

This Petition is made p ursuant 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 safely in the NAS

. As such
, DFS ’ request for exemption may be granted pursuant
to the authority of FMRA Sec tion 333 and 14 C.F.R. Part 11, as set forth above.28 FMRA Section 333 sets forth the require ments for considering whether a UAS will create

a hazard to users of the N AS or the public
, or otherwise pose a threat to national security; and
further, provides the authority for such UAS to operate without airworthiness certification.

As discussed in detail above
, DFS will operate the subject UAS safely in the NAS
, without creating a hazard to users of the NAS
, or the public
, or otherwise pose a threat to
national security

.
**CONCLUSION**

As set forth herein
, DFS Autonomous Systems, LLC 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 Inspire 1 UAS and Phantom 2 UAS commercially
,
without an airworthiness certific ate , for the limited purpose s of conducting aerial acquisitions
and establishing a UAS flight instruction program within the National Airspace System ( NAS )

. By granting this Petition, the FAA Administrator will be fulfill ing the Congressional mandate of

the FAA Modernization and Reform Act of 2012, while also advancing the interests of the
public
, by allowing DFS to safely, efficiently, and economically operate the subject UAS
commercially with in the NAS

.
**WHEREFORE** , in accordance with the Federal Aviation Regulations and the FAA

Modernization and Reform Act of 2012, Section 333, DFS Autonomous Systems, LLC
respectfully requests that the Administrator grant this Petition for an exemption from the
requirements of 14 C.F.R Sections 61.23(a) & (c), 61.101(e)(4) & (e)(5), 61.113(a), 61.315(a),
91.7(a), 91.119(c), 91.121, 91.151(a), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and

91.41 7(a) & (b)
, and permit DFS Autonomous Systems, LLC to operate the DJI Inspire 1 UAS29 and DJI Phantom 2 UAS for the commercial purposes of aerial data collection and establishing a
UAS flight instruction program.

Dated: July 20 , 2015 Respectfully submitted,

**The Aviation Law Firm**

/s/ Gregory S. Winton

____________________________ Gregory S. Winton, Esq. 1997 Annapolis Exchange Parkway Suite 300 Annapolis, Maryland 21401 Tel: (301) 294

- 8550 Fax: (866) 568

- 9886 Attorney for Petitioner