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

Regulatory Docket No.

_



### IN THE MATTER OF THE PETI TION FOR EXEMPTION OF: Thomas Hall 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)(l), 91.409(a)(l) & 

### (a)(2), AND 91.417(a) & 

### (b) CONCERNING COMMERCIAL OPERATION OF DJI PHANTOM 2 VI SION+ AND DJI IN SPIRE 1 UNMANNED AIRCRAFT SYSTEMS PURSUANT TO SECTION 333 OF THE FAA MODERNIZATION AND REFORM ACT OF 2012 <PUBLIC LAW 112-95)

Submitted on April 14, 2015

Thomas Hall 850 Caroline Street Billi ngs, MT 59105 406-694-35842 TABLE OF CONTENTS

Page

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

SUMMARY .......................................................................................................................

......... 4

INIRODUCTION AND INTERESTS OF P ETITIONER .................................................... 4

BACKGROUND ....................................................................................................................

..... 4

BASIS FOR PETITION ......................................................................................................... 5

NAME AND ADDRESS OF PETITIONER ............................................................. 7

THE SPECIFIC SECTIONS OF 14 C. F.R. FROM WHICH THOMAS HALL SEEKS EXEM PTION .................................................................... 8

THE EXTENT OF RELIEF Thomas Hall SEEKS AND THE REASON THOMAS HALL SEEKS THE RELI EF .................................... 11

THE REASONS WHY GRANTING THOMAS HALL’S REQUEST WOULD BE IN THE PUBLIC IN TEREST ............................................................ 15

THE REASONS WHY GRANTING THE EXEMPTION WOULD NOT ADVERSELY AFFECT SAFETY .......................................................................... 19

SUMMARY THAT CAN BE PUBLISHED IN THE FEDERAL REGISTER ....... 34

ANY ADDITIONAL INFORMATION, VIEWS, OR ARGUMENTS AVAILABLE TO SUPPORT THOMAS HALL’S REQUEST.........................................................................34

CONCLUSION ....................................................................................................................

...... 35

APPENDICES ....................................................................................................................

...... 373 GLOSSARY OF ABBREVIATIONS

AGL
AOI
ATC
ATO
AV
CFR
COA

FAA
FAR

GCS
GPS
LOL
NAS
NOTAM
PIC
Section 333 SO

SOP
UA
UAS

VFR
VLOS


## VMC
VTOL Above Ground Level
Area of Interest
Air Traffic Control Air Traffic Organization
Aerial Vehicle Code of Federal Regulations
Certificate of Authorization
Federal Aviation Administration
Federal Aviatio n Regulation
Ground Control Station Global Positioning System
Loss of Link National Airspace System
Notice 

### to Airman
Pilot In Command
FAA Modernization and Reform Ac t of 2012 (FMRA) Section 333 Safety Observer Standard Operating Procedures
Unmanned Aircraft Unmanned Aircraft System Visual Flight Rules
Visual Line of Site Visual Meteorological Conditions Vertical Takeoff and Landing4 

### SUMMARY

Thomas Hall seeks exemption fro m the requirements of 14 C.F.R §§ 61.113(a) &

(b), 91.7(a), 91.121, 91.lSl(b), 91. 405(a), 91.407(a)(l), 91.409(a)(l) & (a)

(2), and 91.417(a) & (b), to operate an Unmanned Aircraft System pursuant to Section

333 of the FAA Modernization and Reform Act of 2012 (FMRA). This exemption will

permit Thomas Hall to operate an Unmanned Aircraft System (UAS) for the commercial

purpose of conducting aerial video and photography of construction sites, real estate, and

landscape over certain areas of the United States.



### INTRODUCTION AND INTERESTS OF THE PETITIONER

Thomas Hall provides his clients with expertise and knowledge in advanced

technologies and solutions to increase efficiency, productivity and effectiveness. Thomas

Hall has over 10 years of professional experience in project management and Land

Surveying. He has over 6 years recreational/hobby experience in all aspects of aerial video

and photography. The objective of Thomas Hall aerial video and photography operations

is to provide high quality imaging for a variety of commercial, public, and residential uses,

specifically targeting:

• Construction sites before and after

• Appraisals

• Real-estate marketing

• Aerial acquisitions used for inspections of public and private structures.

• Aerial Mapping/Land Surveying5 

### BACKGROUND
Unmanned Aircraft Systems: DJI Ph antom 2 Vision+. DJI Inspire 1 UASs

Thomas Hall seeks an exemption to operate DJI systems for compensation or hire

within the NAS. The DJI Phantom 2 Vision+ and DJI Inspire 1 are vertical takeoff and

landing (VTOL) Unmanned Aircraft (UA) w ith a Ground Control Station (GCS) utilizing

electronic tablet, laptop or smart phone systems. The DJI Phantom 2 Vision+ has a

maximum gross weight of approximately 2 po unds 11 ounces, while having a length of 16

inches width of 16 inches, height of 8 inch es, and a maximum speed of approximately 29

knots. The DJI 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 DJI Phantom 2 Vi sion+ and DJI Inspire 1 UAs are equipped

with four main rotors; driv en by Lithium Polymer batter y powered electric motors.

The DJI Phantom 2 Vision+ and DJI Insp ire 1 UAs that will be operated by

Thomas Hall 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, Thomas Hall, 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, hereby
petitions the Administrator to commercially operate the DJI Phantom 2 Vision

+, DJI Inspire 1 UASs in the National Airs pace System (NAS), and for an exemption

from the6 Requirements of 14 C.F.R §§ 61.113(a) & (b), 91.7(a), 91.121, 91. lSl(b), 91.405(a),

91.407(a)(l), 91.409(a)(l) & (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 oper ation, Thomas Hall’s operation of DJI Phantom 2

Vision+ and DJI Inspire 1 UASs meets th e conditions of FMRA Section 333 and

therefore, will not require an airworthines s certificate in accord ance with 14 C.F.R. Part
21, Subpart H.

Accordingly, Thomas Hall requests relief from Sections 91.405(a), 91.407(a)(l),

91.409(a)(l ) & (a)(2), and 91.417(a) & (b), as these sections set forth requirements for
maintenance that only apply to aircraft with an airworthiness certificate.

Thomas Hall submits that the requested relief is proper since an equivalent level

of safety will be ensured. Thomas Hall will use experienced personnel or technicians to

perform maintenance, alterations, or preventive maintenance on the UASs using the

methods, techniques, and practices prescribed in the operating documents (i.e., Monthly

Maintenance Log, and DJI Phantom 2 Vision+ and DJI Inspire 1 Instruction Manual).

Furthermore, Thomas Hall will document and maintain all maintenance records for the

DJI Phantom 2 Vision+ and DJI Inspire 1 UASs.

Relief from certain requirements of Section 61.113(a) and (b), entitled Private pilot
privileges and limitations: Pilot in command, is requested by Thomas Hall to the extent
necessary to allow a Pilot in Command (PIC) holding a private pilot or higher level

certificate, as well as an airman medical certificate, and who has demonstrated, by meeting

minimum flight- hour and currency requirements, that the PIC is able to safely operate the

DJI Phantom 2 Vision+ and DJI Inspire 1 UASs in a manner consistent with this7 

### exemption,including evasive and emergenc y maneuvers and maintaining appropriate
distances from people, vessels , vehicles and structures.

Thomas Hall seeks relief fr om Section 91.7(a), entitled Civil aircraft airworthiness,


### because the DJI Phantom 2 Vision+ and DJI Inspire 1 UASs do not require an

airworthiness certificate in accordance with 14 C.F .R. 

### Part 21, Subpart H. As such,

Thomas Hall submits that he will ensure that the DJI Phantom 2 Vision+ and DJI Inspire

1 UAS ’ s are in an airworthy condition, prior to every flight, by determining that the UASs

are in compliance with the operating doc uments (i.e., Monthly Maintenance Log, and DJI
Phantom 2 Vision+ and DJI Inspire 1 Instru ction Manual), and that the aircraft are in a
condition for safe flight.
Thomas Hall also seeks an exemption from the requirements of Section 91.121,

entitled Altimeter Settings, 

### as the DJI Phantom 2 Vision+ an d DJI Inspire 1 UAs will not
have a typical barometric altimeter onboar d. However, altitude information of the DJI
Phantom 2 Vision+ and DJI Inspire 1UAs will be provided to the PIC via Global
Positioning System (GPS) equipment and ra dio communications telemetry data link,

which downlinks from the UA to the GCS for active monitoring of the flight path. This

altitude information, combined with Th omas Hall's operation of the DJI Phantom 2
Vision+ and DJI Inspire 1 UASs within visual line of sight, at or below 500 feet AGL,
will ensure a level of safety equivalent to Section 91.121.
Additionally, Thomas Hall seeks an exemption from the requirements of
Section 91.15l(b), entitled Fuel requirements for flight in VFR conditions. 

### Thomas
Hall submits that safety wi ll not be affected by op eration of the DJI Phantom 2 Vision+
and DJI Inspire 1 UAS ’ during daylight hours in visual meteorological conditions

(VMC)8 under visual flight rules (VFR ), with enough battery power to fly for a total duration of
approximately 13.5 minutes to the first point of intended landing and, assuming normal
cruising speed, to fly after that for at least 4.5 minutes.

In accordance with 14 C.F.R. 

### § 11.81, Thomas Hall provides the following

information in support of its petition for exemption:

A. 

### Name And Address Of The Petitioner.

The name and address of the Pe titioner and point of contact is:

Thomas Hall 850 Caroline Street, Billings, MT 59105 406-694-3584 Email: ecstomh@gmail.com



### B. The Specific Sections Of 14 C.F.R. From Which Thomas Hall Seeks Exemption.

1. Thomas Hall Seeks Exemptio n From The Requirements Of Section

61.113(a) And (b).

Section 61.113, entitled Private pi lot privileges and limitations: Pilot in command,

subsections (a) and (b) prescribe the following, in relevant part:
(a) No person who holds a private pilot ce rtificate may act as a pilot in command (PIC) of an aircraft that is carrying passengers or property for compensation or hire; nor may that person, for compensation or hire, act as PIC of an aircraft.

(b) A private pilot may, for compensation or hire, act as PIC of an aircraft in connection with any business or employment if-

(1) The flight is only incidental to that business or employment; and

(2) The aircraft does not carry passengers or property for compensation or hire.



### 2. Thomas Hall Seeks Exemption From The Requirements Of Section 91.7(a).9 

### 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. Thomas Hall Seeks Exemption From The Requirements Of Section 91.121. 

### Section 91.121, entitled Altimeter settings, s ubsection (a), states the following, in

part:
(a) Each person operating an aircraft shall maintain the cruisi ng altitude or flight level of that aircraft, as the case may be, by reference to an a ltimeter 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)( l)(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. Thomas Hall 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:
(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. Thomas Hall Seeks Exemption From The Requirement Of Section 91.405(a).

### 1 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 inspection s, except as provided in paragraph (c) of this section, have discrepancies repaired as prescribed in part 43 of this chapter[.]

6. Thomas Hall Seeks Exemption From The Requirements Of Section 91.407(a)(l)

Section 91.407, entitled 

### Operation after maintenance, preventive maintenance,
rebuilding, or alteration, subsection (a)(l), 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 by a person authorized under § 43.7 of this chapter[.]

7. Thomas Hall Seeks Exemption From The Requirements Of Sections 91.409(a)(l) And 91.409(a)(2).

Section 91.409, entitled 

### Inspections, subsection (a), stat es 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 acco rdance with part 43 of this chapter and 

### has been approved for return to service by a person authorized by § 43.7 of this chapter; or

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

8. Thomas Hall 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 accorda nce with §§ 91.411 and 91.413, each registered owner or operator shall keep the following reco rds for the periods specified in paragraph 

### (b) of this section:

### 1 (1) Records of the maintenance, preventive maintenance, and alteration and records of the 100-hour, annual, progre ssive, and other required or approved inspections, as appropriat e, for each aircraft (including the airframe) and each engine, propeller, roto r, and appliance of an aircraft. The records must include--

(i) A description (or re ference 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 num ber 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 overhau l of all items installed on the aircraft which are required to be overhauled on a specified time basis.

(iv) The current insp ection status of th e aircraft, including the time since the last inspection required by the in spection program under which the aircraft and its applia nces are maintained.

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

(vi) Copies of the forms prescribed by § 43.9(d) of this chapter for each major alteration to the airframe and currently installed engines, rotors, propellers, and appliances.

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

(1) The records specified in paragraph (a)( l) of this section shall be retained until the work is repeated or superseded by other work or for 1 year after the work is performed.

### 1 (2) The records specified in paragraph (a)(2 ) of this section shall be retained and transferred with th e 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.



### C. The Extent Of Relief Thomas Hall Seeks A nd The Reason Thomas Hall Seeks The Relief.

1. Extent Of Relief Thomas Hall Seeks And The Reason Thomas Hall Seeks Relief From Section 61.113(a) And (b).

Relief from Section 61 .113(a) and (b) entitled Private pilot privileges and

limitations: Pilot in command, is requested to the extent nece ssary to allow a PIC 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 requirem ents, to conduct the

proposed UAS flight operatio ns for compensation or hire.

This relief is requested since the limitatio ns set forth in Section 61.113(a) and (b)

state that a private pilot may, for compensation or hire, act as PIC of an aircraft in

connection with any business or employment if: (1) The flight is only incidental to that

business or employment; and (2) The aircraft does not carry passengers or property for

compensation or hire.

As set forth more fully below, Thom as Hall submits that an equivalent level of
safety will be main tained because no PIC will be allowed to ope rate the DJI Phantom 2

Vision+ UAS or DJI Inspire 1 UAS unless that PIC 

### has met certain flight-hour and

currency requirements, demonstr ating that the PIC is able to safely operate either the DJI
Phantom 2 Vision+ or DJI 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 approp riate distances from people, vessels, vehicles and structures.

### 1 Further, Thomas Hall submits that al l flights of the DJI Phantom 2 Vision
+ and DJI Inspire 1 UASs, conducted by the PIC pursuant to the grant of this Petition: (1)

will be incidental to Thomas Hall's business; and (2) will not carry passengers or property
for compensation or hire.



### 2. Extent Of Relief Thomas Hall Se eks And The Reason Thomas Hall Seeks Relief From Section 91.7(a).
Relief from Section 91.7(a) entitled Civil aircraft airworthiness, is requested to the

extent required to allow Thomas Hall to determine that the DJI Phantom 2 Vision

+ and DJI Inspire 1 UASs are in airworthy condition prior to every flight by ensuring that

the UAS is in compliance with the operati ng documents (i.e., Monthly Maintenance Log,

and DJI Phantom 2 Vision+ and DJI Inspire 1 Instruction Manual).

Thomas Hall seeks the requested relief because the DJI Phantom 2 Vision
+ and DJI Inspire 1 UASs do not require an airworthiness cer tificate in accordance with 14

C.F.R. Part 21, Subpart H. Therefore, Thomas Hall will ensure that the DJI Phantom 2

Vision+ and DJI Inspire 1 UAS’s are in airworthy condition based upon its compliance

with the operating documents (i.e., Monthly Maintenance Log, and DJI Phantom 2 Vision+

and DJI Inspire 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 Of Relief T homas Hall Seeks And The Reason Thomas Hall Seeks Relief From Section 91.121.
Relief from Section 91.121, entitled Altimeter settings, may be required to allow

flight operations of the DJ I Phantom 2 Vision+ and DJI Inspire 1 UAS s, which utilize a

barometric pressure sensor, GPS equipment, and a radio communications telemetry data

link to downlink altitude information from the UA to the PIC at the ground control station

### 1 (GCS). Since the FAA requires that any altitude information concerning UAS operations be

reported to air traffic control (ATC) in feet above ground level (AGL), Thomas Hall seeks

the requeste d relief because the DJI Phanto m 2 Vision+ and DJI Inspire 1 UA's altimeter

may be set on the ground to zero feet AGL, rather than the local barometric pressure or
field altitude, befo re each flight.

Considering the limited altit ude of the proposed opera tions, relief from 14 CFR

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

limitations stated below. As more fully set forth herein, an equivalent level of safety will

be maintained since the DJI Ph antom 2 Vision+ and DJI Inspire 1 UAs are equipped with a

barometric pressure sensor and GPS equipmen t, which automa tically ensures that a ground

level pressure setting w ill be established prio r to each flight, and provides the PIC with

altitude information of the UA on the heads-up display of the GCS.



### 4. Extent Of Relief Thomas Hall Seeks And The Reason Thomas Hall Seeks Relief From Section 91.lSl(b).
Relief from Section 91.15l(b) entitled Fuel requirements for flight in VFR

conditions, is requested to the extent required to allow flights of the battery powered DJI

Phantom 2 Vision+ and DJI 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 cruising speed, to fly after that for

at least 4.5 minutes. Thomas Hall seeks the requested relief because without an exemption

from Section 91.151(b), the flight time duration of the battery powered DJI Phantom 2

Vision+ and DJI Inspire 1 UAs will severe ly constrain the practicality of any aerial video or

still photo flight operations that Thomas Hall proposes to conduct pursuant to this Petition.

### 1 Significantly, as set forth below, the technical specifications of the DJI Phantom 2

Vision+ and DJI Inspire 1 UASs, the DJI Phantom 2 Vision+ and DJI Inspire 1 operating

documents, and Thomas Hall's proposed operating limitations, ensure that Thomas Hall

will safely operate the battery powered DJI Phantom 2 Vision+ and DJI Inspire 1 UAs

during daylight hours in visual meteorological conditions (VMC), under visual flight rules

(VFR), with enough battery power to fly for a total duration of 13.5 minutes to the first

point of intended landing and, assuming normal cruising speed, to fly after that for at least

4.5 minutes.



### 5. Extent Of Relief Thomas Hall S eeks And The Reason Thomas Hall Seeks Relief From Sections 91.405(a), 91.407(a)(l), 91.409(a)(l) & 

### (a)(2), And 91.417(a) & 

### (b).
Since Sections 91.405(a), 91.407(a)(l), 91.409(a)(l) & (a)(2), and 91.417(a) & 

### (b)

only apply to aircraft with an airworthiness certificate, Thomas Hall requests relief from

these Sections because the DJI Phantom 2 Vision+ and DJI Inspire 1 UASs do not require

airworthiness certificates. As set forth more fully below, the DJI Phantom 2 Vision+ and

DJI Inspire 1 UASs meet the conditions of FMRA Section 333 for operation without an

airworthiness certificate. Accordingly, Thomas Hall to perform maintenance, alterations,

or preventive maintenance on the UASs using the methods, techniques, and practices

prescribed in the UAS operating documents (i.e., the Monthly Maintenance Log, and DJI
Phantom 2 Vision+ and DJI Inspire 1 Instruction Manual). Furthermore, Thomas Hall will

document and maintain all maintenance records for the DJI Phantom 2 Vision+ and DJI

Inspire 1 UAS’s.



### D. The Reasons Why Granting Thomas Ha ll Request Would Be In The Interest; That Is, How It 

### Would Benefit The Public As A Whole.

### 1 Granting the present Petition will further th e public interest by allowing Thomas
Hall to safely, efficien tly, and economically perform aerial video and photography of

construction sites, real estate, and landscape over certain areas of the United States.

Additionally, use of the DJI Phantom 2 Vision+ and DJI Inspire 1 UAS’s will

decrease congestion of the NAS, reduce pollu tion, and provide sign ificant benefits to

the economy. Notably, the benefits of Th omas Hall's proposed operation of the
DJI Phantom 2 Vision+ and DJI Inspire 1 UASs will be realized without implicating any privacy issues.


### 1. The Public Will Benefit From Decreased Congestion Of The NAS.

The DJI Phantom 2 Vision+ and DJI Inspire 1 UAs are battery powered and serve

as a safe, efficient, and economical alternativ e to the manned aircraft traditionally utilized

to obtain aerial imagery. By reducing the amo unt of manned aircraft needed to perform

aerial acquisitions, an exemption allowing the use of a DJI Phantom 2 Vision+ or DJI

Inspire 1 UAS would reduce the amount of manned aircraft in the NAS, reduce noise and

air pollution, as well as increase the safety of life an d 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

DJI Phantom 2 Vision+ and DJI Inspire 1 UAS’s do not require an airport to takeoff or

land. Likewise, a reduction of manned aircra ft conducting aerial video and photography

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 Phantom 2 Vision+ and DJI Inspire 1 UASs.

### 1 Conducting aerial acquisitions with the DJI Phantom 2 Vision+ and DJI Inspire 1

UASs, instead of manned aircraft, will greatly benefit the public by dr astically reducing the

levels of air and noise pollution generated during traditional aerial video and still

photography flight operations . By using battery power and electric motors, the DJI

Phantom 2 Vision+ and DJI Inspire 1 UASs produce no air pollution, and is the most

viable environmentally conscious alternative to the cabin class, six cylinder internal

combustion engine aircraft that are typically utilized for aerial video and photography,

while burning approximately 20-30 gallons per hour of leaded aviation fuel. The DJI

Phantom 2 Vision+ and DJI Inspire 1 UAs, while reducing the carbon footprint of aerial
acquisitions, also eliminates noise pollution, as the UAs are propelled by battery powered

electric motors, rather than an internal combustion engine.
By using the DJI Phantom 2 Vision+ an d DJI Inspire 1 UASs to perform aerial

acquisitions, the substant ial risk to life and pr operty 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 flight crew members located
onboard the aircraft, the DJI Phantom 2 Vision+ and DJI Inspire 1 UAs (weighing
approximately 2 pounds 11 ounces and 6 pounds 7.5 ounces respectively, at their
maximum gross weights with lengt hs of 16 inches and 17.3 in ches respectively, widths of

16 inches and 17.7 inches respectively, and with no fuel on board), has less physical
potential for collateral damage to life and prop erty on the ground, an d in the air, compared
to the manned aircraft that typically cond uct similar operations (weighing approximately
6,000 pounds with a wingspan of approximately 42 feet, a length of 34 feet, and a fuel

capacity of 180 gallons).

### 1 3. Performing Aerial Video and Photography Operations With The DJI Phantom 2 Vision+ and DJI Inspire 1UASs Will Benefit The Economy.
In addition to being safe and efficient, the DJI Phantom 2 Vision+ and DJI Inspire

1 UASs are 

### also an economical alternative to using manned aircraft to conduct similar

aerial operations. As such, operation of the DJI Phantom 2 Vision+ and DJI Inspire 1
UASs will allow United States based companies, like Thomas Hall’s, 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. Operating the battery powered DJI

Phantom 2 Vision+ and DJI Inspire 1 UASs 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 DJI Phanto m 2 Vision+ and DJI Inspire 1 UAS’s, companies such

as Thomas Hall’s, can rema in competitive and profitabl e, and theref ore, provide greater job
stability to employees and contr actors, which will u ltimately contribute to growth of the
U.S. economy. Improved financial perf ormance of U.S. companies, through commercial

use of the DJI Phantom 2 Vision+ and DJI In spire 1 UASs, provides a stable workforce

that increases consumer spending; improves local, state, and federal 

### tax revenues; and

allows companies to invest in research and development in order to remain competitive

both in the United States and abroad.



### 4. There Are No Privacy Issues.

Similar to the manned aerial acquisition flight operations that have been conducted for
decades, Thomas Hall's proposed op eration of the DJI Phantom 2 Vision+ and DJI

### 1 Inspire 1 UASs will not implicate any priv acy issues. Specifica lly, the DJI Phantom 2
Vision+ and DJI Inspire 1 UASs will be oper ated only in complia nce with operating
documents (i.e., the Monthly Maintenance Log, and DJI Phantom 2 Vision+ and DJI

Inspire 1 Instruction Manual)

which requires property owner involvement as well as local law enforcem ent notification,

and in accordance with the Federa l Aviation Regulations, in cluding the minimum altitude

requirements of 14 C.F.R. 

### § 91.119.
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 Thomas Hall Seeks Exemption.

1. Reasons Why The DJI Phantom 2 Visi on+ and DJI Inspire 1 UAs Meet The Conditions Of The FAA Modernizati on and Reform Act of 2012 (FMRA) Section 333.
In consideration of the size, weight, speed, and limited operating area associated

with the unmanned aircraft and its opera tion, Thomas Hall operation of the DJI Phantom

2 Vision+ and DJI Inspire 1 UASs meet the conditions of FM RA Section 333, and will

not require an airworthiness ce rtificate in accordance with 14 C.F.R. Part 21, Subpart 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 security.

Specifically, FMRA Section 333 st ates the following, in part:

(a) In General.--Notwithstanding any other requirement of this subtitle, and not later than 180 days after the date of en actment of this Act, the Secretary of Transportation shall determine i f 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.

### 20 (b) Assessment of Unmanned Aircraft System s.--In making the determination under subsection (a), the Secretary s hall determine, at a minimum--
(1) which types of unmanned aircraft systems, if any, as a result of their size, weight, speed, operational capa bility, proximity to airports and populated areas, and operation within visual line of sight do not create a hazard to users of the national airs pace 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 sectio n 44704 of title 49, United States Code, is required for the opera tion of unmanned aircraft systems identified under paragraph (1).
(c) Requirements for Safe Operation.--lf the Secretary determines under this section that certain unmanned aircraft systems may operate safely in the national airspace system, the Secretary s hall establish requirements for the safe operation of such aircraft system s in the national airspace system.
In seeking this exemption, Thomas Hal submits that the DJI Phantom 2 Vision+

and DJI Inspire 1 UAS’s can operate safely in the NAS pursuant to FMRA Section 333, as
demonstrated by: (a) the characteristics of the DJI Phantom 2 Vision+ and DJI Inspire 1

UASs; (b) the pilot certification require ment; and (c) the specific operating limitations.



### a. The Specifications Of The DJI Phantom 2 Vision+ and DJI Inspire 1 UASs Demonstrate Its Safe Characteristics.

The DJI Phantom 2 Vision+ an d DJI Inspire 1 UASs do not create a hazard to

users of the NAS or the public, or otherwise pose a threat to national security considering

its size, weight, speed, and operational capability.

i. 

### Technical Specifications Of The DJI Phantom 2 Vision+ and DJI

Inspire 1 UASs.
The technical specifications of the DJI Phantom 2 Vision+ and DJI Inspire 1 UASs

are set forth by the DJI Phan tom 2 Vision+ and DJI Inspire 1 Specifications and Data

Sheet, attached hereto as Exhibit A and B.

### 21 ii 

### The DJI Phantom 2 Vision+ and DJI Inspire 1 UASs Autonomous Flight And Navigation Modes En able The UASs To Remain Within A Defined Operational Area.
The DJI Phantom 2 Vision+ and DJI Insp ire 1 UASs may be operated in both

manual and fully autonomous f light modes. A complete description of the flight and

navigational modes of the DJI Phantom 2 Vi sion+ and DJI Inspire 1 UASs is provided at

pages 25-35 of the DJI Phantom 2 Vision+ and pages 12-16 and 45-50 of the DJI Inspire 1

User Manuals, attached hereto as Exhibit C and D.

iii. 

### The DJI Phantom 2 Vision+ and DJI Inspire 1UASs Are Designed For Automatic Return To Home Point Or Hover In The Event Of Loss Of The Control Link Or Navigation.
When the Control Link is lost, the DJI Phantom 2 Vision+ and DJI Inspire 1 UAS’s

will remain stationary, in flight, for 3 seconds or more. If, after 3 seconds, the DJI

Phantom 2 Vision+ and DJI Inspire 1 UAS’s do not reacquire control link data from the

GCS, the UAs will assume that the Control Link is lost and the UAs will return to the home

position (i.e., failsafe mode) via GPS, and will descend to the takeoff position and

shutdown.

A complete description of the Failsafe Functions of the DJI Phantom 2 Vision+

UAS are set forth at pages 27 through 29 and for the DJI Inspire 1 at pages 13 through 15

of the DJI Phantom 2 Vision+ an d DJI Inspire 1 User Manuals, attached hereto as Exhibit

C and D.


### iv. The DJI Phantom 2 Vision+ and DJI Inspire 1GCS And Its Operation.
A complete description of the operation and specifications of the DJI Phantom 2

Vision+ and DJI Inspire 1 GCS and flight contro l software is provided at pages 32 through

43 of the DJI Phantom 2 Vision + User Manual and pages 40 th rough 47 of the DJI Inspire

### 22 1 User Manual. DJI Phantom 2 Vision+ an d DJI Inspire 1User Manuals are attached

hereto as Exhibits C and D.

b. Flight Operations Of DJI Phantom 2 Vision+ and DJI Inspire 1 UASs Are Limited To The Line Of Sight Of A Certificated Pilot in Command With A Safety Observer.
Thomas Hall will only utili ze certificated pilots who possess a current and valid

airman medical certificate to act as a p ilot in command (PIC) of the DJI Phantom 2

Vision+ and DJI Inspire 1 UASs. Additionally, a safety observer w ill assist all pilots

during flight time.

c. Flights Of DJI Phantom 2 Vision+ and DJI Inspire 1 UASs Will Be Conducted Pursuant To Specific Operating Limitations.
In seeking this exemption, T homas Hall proposes to commercially operate DJI
Phantom 2 Vision+ and DJI Inspire 1 UASs for the special purpose of conducting aerial

video and photography over 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: DJI Phantom 2 Vision+ and DJI Inspire 1 Unmanned Aircraft Systems. 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 operations for the purpose of aerial video and photography.

3. The UAs may not be flown at an indi cated airspeed ex ceeding 20 knots.

4. The UA must be operated at an altitude of no more than 500 feet above ground level (AGL), as indicated by the procedures specified in the operating documents unless a special request is made and approved by ATC. All altitudes reported to ATC must be in feet AGL.
S. The UAS’s must be operated within visual line of sight (VLOS) of the PIC at all times. This requires the PI C to be able to use human vision unaided by any device other than corrective lenses, as specified on th e PIC's FAA-issued airman medical certificate.

### 23 6. The use of first person view (FPV) by th e PIC or safety observer (SO) is not permitted.

7. All operations must utilize a safety observ er (SO). The SO may be used to satisfy the VLOS requirement as long as the PIC always maintain s VLOS capability. The SO and PIC must be able 

### to communicate verbally at all times. Electronic messaging or texting is not permitted du ring flight operations. The PIC must be designated before the flight and cannot transfer his or her designation for the duration of the flight. The PIC must ensure that the SO can perform the Functions prescribed in the operating documents.

8. The SO must not perform any other duti es beyond assisting the PIC with seeing and avoiding other air tra ffic and other ground based ob stacles/obstructions and is not permitted 

### to operate the camera or other instruments.

9. The operating documents and the grant of exemption must be accessible during UAS operations and made available to the Administrator upon request. If a discrepancy exists between the conditions and limitations contained in the grant of exemption and the procedures outlined in the operating documents, the conditions and limitations contained in the grant of exemption take precedence and must be followed. Otherwise, the operator must follow the procedures as outlined in its operating documents. The operator may update or revise its operating documents. It is the operator's responsibility to track such revisions and present updated and revised documents to the Administrator upon request. The operator must also present updated and revised documents if it petitions for extension or amendment to the grant of exemption. If the operator determines that any update or revision would affect the basis upon which the FAA granted the exemption, then the operator must petition for 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.

10. Prior to each flight the PIC must inspect the UAS to ensure that it is in a condition for safe flight. If the inspection reveals a condition that affects the safe operation of the UAS, the aircraft is prohibited from operating until the necessary maintenance has been performed and the UAS is found to be in a condition for safe flight. The Ground Control Station must be included in the preflight inspection. All maintenance and alterations must be properly documented in the aircraft records.

11. Any UAS that has undergone maintenan ce or alterations that affect the UAS operation or flight characteristics, e. g. replacement of a flight critical component, must un dergo a functional test flight. The PIC who conducts the functional test flight must make an entry in the aircraft records.

12. The pre-flight inspection must account for all potential discrepancies, e.g. inoperable components, items, or e quipment, not already covered in the relevant sections of the operating documents.

### 24 13. The operator must follow the UAS manufacturer's aircraft/component, maintenance, overhaul, replacement, inspection, and life limit requirements.

14. The operator must carry out its mainte nance, inspections, and record keeping requirements, in accordance with th e operating documents. Maintenance, inspection, alterations, and status of replacement/overhaul component parts must be noted in the aircraft records, in cluding total time in service, description of work accomplished, and the signature of the authorized person returning the UAS to service.

15. Each UASs operated under this exemptio n must comply with all manufacturer Safety Bulletins.

16. The authorized person must make an entry in the aircra ft record of the corrective action ta ken against discrepancies discovered between inspections.

17. The PIC must possess at least a private pilot certificate and at least a current third- class medical certificate.

18. The operator may not permit any PIC to operate unless the PIC meets the operator's qualification crit eria and demonstrates the ability to safely operate the UAS in a manner consis tent with how the UAS will be operated under the exemption, including evasive and em ergency maneuvers and maintaining appropriate distances from persons, ve ssels, vehicles and structures. PIC qualification flight hours must be logged in a manner consistent with 14 C.F.R. § 61.Sl(b). Flights for the purposes of training the operator's PICs are permitted under the terms of the exemption. However, training operations may only be conducted during dedicated tr aining sessions. During training, proficiency, and experience-building fli ghts, all persons not essential for flight operations are considered nonparticipants, and the PIC must operate the UA with appropriate distance from nonparticipants in accordance with 14 C.F.R. 

### § 91.119.

19. UAS operations may not be conducted during night, as defined in 14 C.F.R. § 19.1. All operations must be conducted under visual meteorological conditions (VMC). If flight at night is required, a special request will be made at the FAA office closest to proposed area of operations. Flights under special visual flight rules (SVFR) are not authorized.

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

### 25 21. The UA may not be operated less than 500 feet below or less 

### than 2,000 feet horizontally from a cloud or when visibility is less than 3 statute miles from the PIC.

22. 

### If the UA loses communications or loses its GPS signal, it must return to a predetermined location within the planned operating area and land or be recovered in accordance with the operating documents.

23. The PIC must abort the flight in th e event of unpredicted obstacles or emergencies in accordance with the operating documents.

24. The PIC is prohibited from beginning a flight unless (considering wind and forecast weather c onditions) there is enough power to fly at normal cruising speed to the intended landing point and land the UA with 25% battery power remaining.

25. The operator must obtain an Air Traffic Organization (ATO) issued Certificate of Waiver or Authorization (COA) prior to conducting any operations under the grant of exemption. This COA will also require the operator to request a Notice to Airman (NOTAM) not more than 72 hours in advance, but not less than 48 hours prior to the operation. All operations shall be conducted in accordance with airspace requirements in the ATO issued COA including class of airspace, altitude level and potential transponder requirements.

26. All aircraft ope rated in accordance with the exemption must be identified by serial number, registered in accordanc e with 14 C.F.R. part 47, and have identification (N- Number) markings in accordance with 14 C.F.R. part 45, Subpart C. Markings must be as large as practicable.

27. Before conducting operations, the radio frequency spectrum used for operation and control of the UA must comply with the Federal Communications Commission (FCC) or other appropria te government oversight agency requirements.

28. The documents required fewer 

### than 14 C.F.R. 91.9 and 91.203 must be available to the PIC at the Ground Control Station of the UAS any time the UAS is operating. These documents must be made available to the Administrator or any law enforcement official upon request.

29. The UA must remain clear and yield the right of way to all manned aviation operations and activities at all times.

30. The UAS may not be operated by the PIC from any moving device or vehicle.

31. Flight operations must be conducted at least 500 feet from all nonparticipating persons (persons other 

### than the PIC, SO, operator trainees or essential 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 ensu re 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 and/or;

b. The aircraft is operated near vessels , vehicles or structures where the owner/controller of such vessels, vehicles or structures 

### has granted permission and the 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, and;

c. Operations nearer 

### to the PIC, SO, operator trainees or essential persons do not present an undue hazard to those persons per § 91.119(a).

32. All operations shall be co nducted over private or controlled-access property with permission from the land owner/cont roller or authoriz ed representative. Permission from land owne r/controller or authori zed representative will be obtained for each flig ht to be conducted.

33. Any incident, accident, or flight opera tion that transgress es the lateral or vertical boundaries of the operational ar ea as defined by the applicable COA must be reported to the FAA 1 s UAS Integration Office (AFS-80) within 24 hours. Accidents must be reported to the National Transportation Safety Board (NTSB) per instructions cont ained on the NTSB Web site: www

. ntsb

. gov

. 2. Reasons Why An Exemption From The Requirements Of Section 61.113(a) And (b) Would Not Adversely Affect Safety.
Thomas Hall submits that the equiva lent level of safe ty established by Section

61.113(a) and (b) will be ma intained because no PIC will be allowed to operate the DJI

Phantom 2 Vision+ and DJI Inspire 1 UAS s unless that PIC has demonstrated, by

meeting minimum flight-hour an d currency requirements, that the PIC is able to safely

operate the DJI Phantom 2 Vision+ or DJI Inspire 1 UAS in a manner consistent with

the exemption, including evasive and emerge ncy maneuvers and ma intaining appropriate

distances from people, vessels, vehicles and structures.

Considering Thomas Hall ’ s proposed area of operations, and the operating

limitations set forth-above; the parallel nature of private pilot aeronautical knowledge

26

### 2 7 requirements to those of co mmercial pilot requirements (S ee Exemption No. 11062); and

the airmanship skills necessary to safely operate the DJI Phantom 2 Vision+ or DJI

Inspire 1 UAS, Thomas Hall submits that the additional mann ed airmanship experience

of a commercially certificated pilot would no t correlate to the airmanship skills necessary

for Thomas Hall's specific proposed flight operations.

The FAA 

### has previously granted relief from Section 61.l 13(a) and 

### (b) specific to

UAS, in circumstances similar, in all material respects, to those presented herein (e.g.

Exemption Nos. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11 110, 11112,

11136, 11138, 11150, 11153, 11156, 11158, 11159, 11160, 11161).
Thomas Hall will not allow any PIC to operate the DJI Phantom 2 Vision+ or DJI

Inspire 1 UAS unless that PIC has demonstrated, by meeting minimum flight-hour

requirements or the DJI Phantom 2 Visi on+ or DJI Inspire 1 UAS training and currency
requirements, that the PIC is able to safely operate the DJI Phantom 2 Vision+

or DJI Inspire 1 UAS in a manner consistent with this exemption, including evasive and

emergency maneuvers and ma intaining appropriate dist ances 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 rotorcraft pilot (with a

minimum of 5 hours of those hours as a UAS pilot operating the sa me make and model of
UAS to be used for operations under the exemption). In add ition to the hour requirements,
the PIC must accomplish 3 takeoffs and landi ngs in the preceding 90 days (for currency
purposes).

### 2 8 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 Thomas Hall's proposed operations. The Administrator



### has held that prior documented flight experience that 

### was obtained in compliance with

applicable regulations would ensure safe operations, stating as follows:

In Exemption No. 11062, the FAA required that prior to conducting operations for the purpose of motion picture filming (o r similar operations), the PIC must have accumulated and logged, in a manner consistent with 14 CFR 61.51(b), 25 hours of total time as a UAS rotorcraft pilot including at least 10 hours logged as a UAS pilot with a multi-rotor UAS. Prior to oper ations under Exemp tion No. 11062, the PIC must also have accumulated and logg ed 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 co nsiders 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 takeoffs and land ings in the preceding 90 days (for currency purposes). The FAA finds that at a minimum, the flig ht-hour requirements in Exemption No. 11062 are appropriate to practice and build proficiency in the skills necessary to safely conduct the petitioner's proposed operations. The FAA also finds that prior document ed flight experience that 

### was obtained in compliance with applicable regulations would satisfy this requirement. Training, proficiency, and experience-building flight s can also be conducted u nder the grant of exemption to accomplish the required flight tim e. During training, proficiency, and experience-building flights the PIC is requ ired to operate the UA with appropriate distances in accordance with 14 C.F.R 91.119.
Exemption No. 11138 at page 15.

Accordingly, Thomas Hall will ensure safe operations by not allowing any PIC to operate
the DJI Phantom 2 Vision+ or DJI Inspire 1 UAS unless that PIC 

### has

demonstrated, by meeting minimum flight-hour and currency requirements, that the PIC is

able to safely operate the DJI Phantom 2 Vision+ or DJI 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.

### 2 9 3. Reasons Why An Exemption From Th e 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, Thomas Hall will ensure that the DJI Phantom 2 Vision+ or

DJI Inspire 1 UAS is in an airworthy 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, 11 110, 11112,

11136, 11138, 11150, 111 53, 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 by Section 91.121 will be maintained

because the altitude information of the DJI Phantom 2 Vision+ and DJI Inspire 1 UAs will

be provided to the PIC 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 Thomas Hall's operation of the DJI
Phantom 2 Vision+ and DJI 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 in stalled onboard the aircraft. Prior to each flight, a

zero altitude initiation point is automa tically established by the UASs at ground level.
The FAA has previously granted relief from Section 91.121 specific to UAS, in
circumstances similar, in all material respects, to those presented herein (e.g. Exemption

Nos. 11062, 11063, 11064, 11065, 1106 6, 11067, 11080, 1110 9, 11112, 11136, 11138,

11150, 11153, 11156, 11157, 11158, 11159, 11160, 11161).

### 30 5. Reasons Why An Exemption From The Requirements Of Section 91.151(b) Would Not Adversely Affect Safety.
A grant of this exemption would ensure an equivalent level of safety established by

14 C.F.R. Section 91.151(b) as a result of (l) the technical specifications of the DJI

Phantom 2 Vision+ and DJI Inspire 1 UASs; (2 ) the limitations on the proposed flight

operations; and (3) the location of the propos ed flight operations. Accordingly, Thomas

Hall will ensure that it will safely operate the battery po wered DJI Phantom 2 Vision+ and

DJI 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 first point of intended landing and, assuming
normal cruising speed, to fly after that for at least 4.5 minutes.

Here, as in Exemption No. 11109, the tec hnical specifications of the DJI Phantom 2

Vision+ and DJI Inspire 1 UASs; the limitations on the propos ed flight operations; and the

location of the proposed operations, will ensure an equivalent level of safety established by

14 C.F.R. Section 91.151(b). Furthermore, sa fety will be ensured as the DJI Phantom 2

Vision+ and DJI Inspire 1 UASs prov ide audible and visual warnings 

### to the PIC 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 critically low battery level, the DJI Phantom Vision+ and DJI Inspire

1UASs will descend and land automatically.

Significantly, previous exemptions granted by 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

aircraft to operate at less 

### than the minimums prescribed in Section 91.151, including

Exemption Nos. 2689, 5745, and 10650. Moreover, the FAA has previously granted relief

### 31 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, 11 080, 11109, 11110, 11136, 11138, 11150, 11153, 11156,

11157, 11158, 11 159, 11160, 11161).



### 6. Reasons Why An Exemption From The Requirements Of Sections 91.405(a), 91.407(a)(l), 91.409(a)(l) & 

### (a)(2), And 91.417(a) & 

### (b) Would Not Adversely Affect Safety.
In seeking this exemption, Thomas Ha ll submits that the equivalent level of safety

with regard to the regulatory maintena nce and alteration requirements established by

Sections 91.405(a), 91.4 07(a)(l), 91.409(a)( l) & (a)(2), and 91.417(a) & (b) will be met
because Thomas Hall will use trained technicians to perform maintenance, alterations, or

preventive maintenance on the UASs us ing the methods, techniques, and practices

prescribed in the operatin g documents (i.e., the Monthly Maintenance Log, and DJI

Phantom 2 Vision+ and DJI Inspire 1 Instruction Manual). Furthermore, Thomas Hall

will document and maintain all maintenance records for the DJI Phantom 2 Vision+ and

DJI Inspire 1 UASs.

Since the DJI Phantom 2 Vision+ and DJI In spire 1 UAS’s will be inspected as

prescribed by the operati ng documents, Thomas Hall w ill maintain the equivalent level of

safety established by Sections 91.405(a), 91.409(a)( l), and 91.409(a)(2). A copy of the

DJI Phantom 2 Vision+ and DJI Inspire 1 User Manuals are attached hereto as Exhibit C

and D; a copy of the DJI Phantom 2 Visi on+ and DJI Inspire 1 UAS Maintenance LOG

is attached hereto as Exhibit 

### E.

Likewise, the exemption sought will not adversely affect safety because Thomas

Hall will use trained technicians to perform maintenance, alterations or preventive

### 32 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

DJI Phantom 2 Vision+ and DJI Inspire 1 UAS’s will be performed by trained

technicians. Maintenance will be documented and maintained utilizing the monthly

maintenance log.

Significantly, previous exemptions gr anted by the FAA concerning Sections

91.405(a), 91.407(a )(l ), 91.409(a)(l) & (a)(2), and 91.417(a) & (b) establish that safety is

not adversely affected when the technical characteristics and operating limitations of the

UAS are considered.

In consideration of Thomas Hall's proposed operating limitations, the operating

documents, and the technical aspects of the DJI Phantom 2 Vision+ and DJI Inspire 1

UASs, Thomas Hall submits that safety will not be adversely affected by granting exemption

from 14 C.F.R. Sections 91.405(a), 91.407(a)(l ) 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 Othe r Conditions For Safe Operation.

In accordance with Section 333 of the F AA Modernization and Reform Act of 2012

(FMRA) and 14 C.F.R. 

### § 21.16 entitled Spec ial Conditions, Thomas Hall requests that the

FAA prescribe special conditions for the intended operation of the DJI Phantom 2 Vision+
and DJI Inspire 1 UASs, which contai n such safety standards that the

### 33 Administrator finds necessary to establish a leve l of safety equivalent to that established by
14 C.F.R. Part 21, Subpart H, and 14 C.F.R 

### §§ 61.l 13(a) & (b), 91.7 (a), 91.121,

91.151(b), 91.405(a) , 91.407(a)(l), 91.409(a)(l ) & (a)(2), and 91.417(a) & (b). Such

special conditions will permit safe opera tion of the UAs for the limited purpose of

conducting aerial video and p hotography over certain areas of the United States for

compensation or hire. FMRA Section 333 se ts forth the requirements for considering

whether a UAS will create a haza rd to users of the NAS or th e public, or otherwise pose a

threat to national security; an d further, provides the auth ority for such UAS to operate

without airworthiness certific ation in accordance with any requirements that must be

established for the safe oper ation of the UAS in the NAS.

Likewise, the Administrator may prescribe special conditions pursuant to 14 C.F.R.



### § 21.16, for operation of the DJI Phantom 2 Vision+ and DJI Inspire 1 UASs, 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 propeller, he prescribes special conditions and amendments thereto for the product. The special conditions are issued in accordance with Part 11 of this chapter and contain such safety standards for the aircraft, aircraft engine or propeller as the FAA finds necessary to establ ish a level of safe ty equivalent to that established in the regulations.

See 14 C.F.R. 

### § 21.16.

Therefore, in accordance with FMRA Se ction 333 and 14 C.F.R. § 21.16, the FAA
may prescribe special conditions for Leadi ng Edge's intended operation of the DJI

Phantom 2 Vision+ and DJI Inspire 1 UASs, wh ich contain such safety standards that the

### 34 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 Sections 61.113(a) & (b), 91.7(a), 91.121,

91.15l(b), 91.405(a), 91. 407(a)(l), 91.409(a)(l) & (a)(2), and 91.417(a) & (b).

F. A Summary That Can Be Published In The Federal Register, stating: The Rules From Which Thomas Hall Seeks Exemption:
Thomas Hall seeks exempt ion from the requiremen ts of 14 C.F.R Sections 61.113(a)&(b), 91.7(a), 91 .121, 91.15l(b), 91.405(a), 91.407(a)(l), 91.409(a)(l) & (a)(2}, 

### and 91.417(a) & (b).

A Brief Description Of The Nature Of The Exemption Thomas Hall Seeks:
This exemption will permit Thomas Hall to commercially operate an Unmanned Aircraft System (UAS)for the purpos e of conducting aerial video and photography over certain ar eas of the United States.

G. Any Additional Information, Views, Or Arguments Available To Support Thomas Hall's Request.
This Petition is made pursua nt to the FAA Modernizatio n and Reform Act of 2012

(FMRA) Section 333, which dire cts the Secretary of Transporta tion to determine if certain

UAS may operate safely in the NAS. As su ch, Thomas Hall's request for exemption may be

granted pursuant to the authority 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 th e NAS or the public, or otherw ise pose a threat to national

security; and further, provides the authority for such UAS to operate without airworthiness

certification.

As discussed in detail above, Thomas Hall will operate the DJI Phantom 2
Vision+ and DJI Inspire 1 UAS’s safely in the NAS, without creating a hazard to users

of the NAS, or the public, or otherwise po se a threat to national security.

### 36 Thomas Hall 850 Caroline Street, Billings, MT 5 9105 406-694-3584 Email: ecstomh@gmail.com

Appendices:
A -DJI Phantom 2 Vision+ Sp ecifications Data Sheet B -DJI Inspire 1 Specifications Data Sheet C -DJI Phantom 2 Vision+ Manufacturer's User Manual D -DJI Inspire 1 Manufacturer's User Manual E -Monthly Maintenance Log

### 37 APPENDIX -A

DJI PHANTOM 2 VISION+ TECHNICAL SPECIFICATIONS
Thomas Hall only utilizes safe and reliabl e UASs. DJI is an industry leader in small UAS production. DJI 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, DJI software provides real-time altitude and location information to the PIC via the linked monitor (smart phone/tablet devices) 1.1 DJI Phantom 2 Vision+

1.1.1 Aircraft 1.1.1.1 Supported Battery -DJI 5200mAH Li-ion Battery 1.1.1.2 Weight (Battery & Propellers Included) -2lbs 11.810oz (1242g) 1.1.1.3 Hover Accuracy (Ready to Fly) -Vertical: .S m; Horizontal: 2.5m 1.1.1.4 Max Yaw Angular Ve locity - 200°/s 1.1.1.5 Max Tilt Angel - 35 ° 1.1.1.6 Max Ascent Speed -6m/s 1.1.1.7 Max Descent Speed -2m/s 1.1.1.8 Max Flight Speed - 15m/s (NOT RECOMMENDED)

1.1.2 Gimbal 1.1.2.1 Working Current - Static: 750mA; Dynamic: 900mA 1.1.2.2 Control Accuracy - ±0.03 ° 1.1.2.3 Controllable Range -Pitch: -90 – 0 ° 1.1.2.4 Maximum Angular Sp eed -Pitch: 90°/s

1.1.3 Camera 1.1.3.1 Operating Temperature Range - 32 ° F - 104 ° F (O ° C - 40 ° C) 1.1.3.2 Sensor Size - 1/2.3" 1.1.3.3 Effective Pixels - 14M 1.1.3.4 Resolution -4384x3288 4.1.3.5 HD Video Recording - 1080p30 & 720p 4.1.3.6 Recording Field of View - 1100 ° /85 °

1.1.4 Transmitter 1.1.4.1 Operating Frequency - 5.728GHz - 5.85GHz 1.1.4.2 Communication Distance (unobstr ucted) -FCC Compliance: 800m 1.1.4.3 Receiver Sensitivity (1%PER) - -93dBm 1.1.4.4 Transmitter Power -FCC Compliance: l00mW 1.1.4.5 Working Voltage - 120mA@3.7V

1.1.5 Range Extender 1.1.5.1 Operating Freque ncy -2412-2462MHz

### 38 1.1.5.2 Communication Distance (unobstructed) - 500-700m 1.1.5.3 Transmitter Power -20dBm 1.1.5.4 Power Consumption -2W40 

### APPENDIX-B

DJI INSPIRE 1 TECHNIC AL SPECIFICATIONS

Thomas Hall only utilizes safe and reliable UASs. DJI is an industry leader in small UAS production. DGI UASs are loaded with ground breaking software enabling the user to set parameters which will not allow flight into controlle d 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, DJI software provi des real-time altitude and location information to the PIC via the linked monitor (smart phone/tablet devices)
2.2 DJI Inspire 1

2.2.1 Aircraft 2.2.1.1 Model T600 2.2.1.2 Weight (Battery Included) – 6lbs 7.5291oz (2935g) 2.2.1.3 Hoveri ng Accuracy (GPS Mode) – Vertical: 0.5m; Horizontal: 2.5m 2.2.1.4 Max Angular Velocity – Pitch: 300 ̊ /s; Yaw; 150 ̊ /s 2.2.1.5 Max Tilt Angle – 35 ̊ 2.2.1.6 Max Ascent Speed – 5m/s 2.2.1.7 Max Descent Speed – 4m/s 2.2.1.8 Max Speed – 22m/s (ATTI mode, no wind – NOT RECOMMENDED) 2.2.1.9 Max Flight Altitude – 4500m 2.2.1.10 Max Wind Resistance – 10m/s 2.2.1.11 Max Flight Time – Approximately 18 minutes 2.2.1.12 Motor Model – DJI 3510 2.2.1.13 Propeller Model – DJI 1345 2.2.1.14 Operating Temperature Range - 14 ̊ F to 104 ̊ F (-10 ̊ C to 40 ̊ C) 2.2.1.15 Dimensions – 17 1⁄4” x 17 3⁄4” x 12”

2.2.2 Gimbal 2.2.2.1 Model ZENMUSE X3 2.2.2.2 Output Power (with camera) – Static: 9W; In Motion: 11W 2.2.2.3 Operating Current – Static: 750mA; In Motion: 900mA 2.2.2.4 Angular Vibration Range - + 0.03 ̊ 2.2.2.5 Mounting – Detachable 2.2.2.6 Controllable Range – Pitch; -90 ̊ to +30 ̊ ; Pan: +320 ̊ 2.2.2.7 Mechanical Range – Pitch; -125 ̊ to 45 ̊ ; Pan: + 330 ̊ 2.2.2.8 Max Controllable Speed – Pitch: 120 ̊ /s; Pan: 180 ̊ /s

2.2.3.1 Camera 2.2.3.1 Name – X3 2.2.3.2 Model – FC3 50 2.2.3.3 Total Pixels – 12.76M40 2.2.3.4 Effective Pixels -12.4M 2.2.3.5 Image Max Size - 4000x3000 2.2.3.6 ISO Range -100-3200 2.2.3.7 Field of View - 94° 2.2.3.8 CMOS - Sony EXMOR 1 /2.3" 2.2.3.9 HD Video Recording - UHD(4K): 4096x2160p24/2S, 3840x2160p24/25/30; FHD: 192 0x1080p24/25/30/48/50/60; HD: 1280x720p24/25/30/48/50/60 2.2.3.10 Operating Temperature Range - 32°F - 104°F (o 0 c - 40°C)

2.2.4 Transmitter 2.2.4.1 Name –C1 2.2.4.2 Operating Frequency - 5.728-5.850GHz; 2.400-2.483GHz 2.2.4.3 Communicating Distance (unobstructed) - 2000m 2.2.4.4 Output Power - 9W 2.2.4.5 Operating Temperature Range - 14°F to 104°F (-10°c to 40°C) 2.2.4.6 Battery - 600mAh Li-ion 2S

### 4 APPENDIX -C



### DJI Phantom 2 Vision+ Manu facturer's User Manual

### 4 APPENDIX -D

DJI Inspire 1 Manufacturer's User Manual

### 4 APPENDIX -E

MONTHLY MAINTENANCE SHEET morrth· (year· UAStJ- .t Date/Issue( Di5r;overed O..te055ue( AdDJIo55ed l55ue(Description(&(Maintenance(Conducted Malntenance(Performed(By:(U Prlrrt(&Slg n)

Softwara(Updata•

Airframe(

En1lnas

Propellers

Camera/Gimbal

Landing(Gear

Vlbratlon(Dampenlng

Other: