### August 17, 2015

Exemption No. 12484 Regulatory Docket No. FAA

–2015

–1909

Mr. James A. Johnson Counsel Legal EZE Technology, Inc. 9251 Irvington BLB Highway, #1210 Irvington, AL 36544

Dear Mr. Johnson:
This letter is to inform you that we have granted your request for exemption. It transmits our decision, explains its basis, and gives you the conditions and limitations of the exemption, including the date it ends.
By letter dated May 13, 2015, you petitioned the Federal Aviation Administration (FAA) on behalf of Legal EZE Technology, Inc. (hereinafter petitioner or operator) for an exemption

. The petitioner requested to operate an unmanned aircraft system (UAS) to conduct aerial photography and videography services for surveying, evidence collection, and closed set filming

. See Appendix A for the petition submitted to the FAA describing the proposed operations and the regulations that the petitioner seeks an exemption

. The FAA has determined that good cause exists for not publishing a summary of the petition in the Federal Register because the requested exemption would not set a precedent, and any delay in acting on this petition would be detrimental to the petitioner

.
Airworthiness Certification

The UAS proposed by the petitioner are the DJI Inspire 1 and DJI Phantom 3

.

### 2

In accordance with the statutory criteria provided in Section 333 of Public Law 112

−95 in reference to 49 U

.S

.C

. § 44704, and in consideration of the size, weight, speed, and limited operating area associated with the aircraft and its operation, the Secretary of Transportation has determined that this aircraft meets the conditions of Section 333. Therefore, the FAA finds that relief from 14 CFR part 21
, Certification procedures for products and parts, Subpart H

— Airworthiness Certificates, and any associated noise certification and testing requirements of part 36, is not necessary.

The Basis for Our Decision
You have requested to use a UAS for aerial data collection1 

### and closed set motion picture and filming

. The FAA has issued grants of exemption in circumstances similar in all material respects to those presented in your petition. In Grants of Exemption Nos

. 11062 to Astraeus Aerial (see Docket No. FAA−2014−0352), 11109 to Clayco, Inc. (see Docket No. FAA

−2014

−0507), 11112 to VDOS Global, LLC (see Docket No. FAA−2014−0382), and 11213 to Aeryon Labs, Inc. (see Docket No. FAA−2014−0642), the FAA found that the enhanced safety achieved using an unmanned aircraft (UA) with the specifications described by the petitioner and carrying no passengers or crew, rather than a manned aircraft of significantly greater proportions, carrying crew in addition to flammable fuel, gives the FAA good cause to find that the UAS operation enabled by this exemption is in the public interest.
Having reviewed your reasons for requesting an exemption, I find that

—

 They are similar in all material respects to relief previously requested in Grant of Exemption Nos. 11062, 11109, 11112, and 11213 ;

 The reasons stated by the FAA for granting Exemption Nos. 11062, 11109, 11112, and 11213 also apply to the situation you present; and

 A grant of exemption is in the public interest.

Our Decision
In consideration of the foregoing, I find that a grant of exemption is in the public interest. Therefore, pursuant to the authority contained in 49 U.S.C. 106(f), 40113, and 44701, delegated to me by the Administrator, Legal EZE Technology, Inc. is granted an exemption from 14 CFR §§ 61.23(a) and (c), 61.101(e)(4) and (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) and (2), and 91.417(a) and (b), to the extent necessary to allow the petitioner to operate a UAS to perform aerial data collection and closed set motion picture and filming

. This exemption is subject to the conditions and limitations listed below.

1 Aerial data collection includes any remote sensing and measuring by an instrument(s) aboard the UA. Examples include imagery (photography, video, infrared, etc.), electronic measurement (precision surveying, RF analysis, etc.), chemical measurement (particulate measurement, etc.), or any other gathering of data by instruments aboard the UA.

### 3

Conditions and Limitations

In this grant of exemption, Legal EZE Technology, Inc. is hereafter referred to as the operator.
Failure to comply with any of the conditions and limitations of this grant of exemption will be grounds for the immediate suspension or rescission of this exemption.

1. Operations authorized by this grant of exemption are limited to the DJI Inspire 1 and DJI Phantom 3when weighing less than 55 pounds including payload. Proposed operations of any other aircraft will require a new petition or a petition to amend this exemption

.
2. Operations for the purpose of closed

-set motion picture and television filming

are permitted.

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 operated at airspeeds greater than the maximum UA operating airspeed recommended by the aircraft manufacturer.

4. The UA must be operated at an altitude of no more than 400 feet above ground level (AGL). Altitude must be reported in feet AGL.

5. The UA must be operated within visual line of sight (VLOS) of the 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.

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 capability. 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 of the flight. The PIC must ensure that the VO can perform the duties required of the VO.

7. This exemption and all documents needed to operate the UAS and conduct its operations in accordance with the conditions and limitations stated in this grant of exemption, are hereinafter referred to as the operating documents. The operating documents must be accessible during UAS operations and made available to the

### 4

Administrator upon request. If a discrepancy exists between the conditions and limitations in this 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 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 or any law enforcement official upon request. The operator must also present updated and revised documents if it petitions for extension or amendment to this grant of exemption. If the operator determines that any update or revision would affect the basis upon which the FAA granted this exemption, then the operator must petition for an amendment to its grant of exemption. The FAA’s UAS Integration Office (AFS−80) may be contacted if questions arise regarding updates or revisions to the operating documents.

8. Any UAS that has undergone maintenance or alterations that affect the UAS operation or flight characteristics, e.g.
, replacement of a flight critical component, must undergo a functional test flight prior to conducting further operations under this exemption. Functional test flights may only be conducted by a PIC with a VO and must remain at least 500 feet from other people. The functional test flight must be conducted in such a manner so as to not pose an undue hazard to persons and property.

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

10. 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, items, 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.

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

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

13. 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 issued 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 certificate.

### 5

14. 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 maintaining 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 (training, 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 operations 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, and the PIC must operate the UA with appropriate distance from nonparticipants in accordance with 14 CFR § 91.119.

15. UAS operations may not be conducted during night, as defined in 14 CFR § 1.1. All operations must be conducted under visual meteorological conditions (VMC). Flights under special visual flight rules (SVFR) are not authorized.

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

-published aeronautical chart, unless a letter 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.

17. The UA may not be operated less than 500 feet below or less than 2,000 feet horizontally from a cloud or when visibility is less than 3 statute miles from the PIC.

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

-determined location within the private or controlled

-access property.

19. The 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 forecast weather conditions) there is enough available power for the UA to conduct the intended operation and to operate after that for at least five minutes or with the reserve 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

.

### 6

22. All aircraft operated in accordance with this exemption must be identified by serial number, registered in accordance with 14 CFR part 47, and have identification (N−Number) markings in accordance with 14 CFR 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 f eet 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 persons are not considered nonparticipating persons under this exemption.

27. All operations shall be conducted over private or controlled

-access property with permission from the property owner/controller or authorized representative. Permission from property owner/controller or authorized representative will be obtained for each flight to be conducted.

28. Any incident, accident, or flight operation that transgresses the lateral or vertical boundaries of the 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

.

### 7

If this exemption permits operations for the purpose of closed

-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 exemption;

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 operator 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 operations 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.
Unless otherwise specified in this grant of exemption, the UAS, the UAS PIC, and the UAS operations must comply with all applicable parts of 14 CFR including, but not limited to, parts 45, 47, 61, and 91.

### 8

This exemption terminates on August 31, 2017, unless sooner superseded or rescinded.
Sincerely, /s/ John S. Duncan Director, Flight Standards Service

EnclosuresU.S. Depmi1nent of Transportation Docket Manage1nent Syste1n 1200 New Jersey Ave., SE Washington, DC 20590 ATTORN[YS AT LAW

May 13, 2015

Re: Petition ofLegal EZE Teclu1ology, Inc. for Exen1ption Pursuant to Section 333 of the FAA Modernization and Refonn Act of 2012.

To Whon1 It May Concern:

Pursuant to Section 333 ofthe FAA Modernization and Reforn1 Act of2012 (FMRA) and 14 CFR Part 11, Legal EZE Teclu1ology, Inc. (Legal EZE), hereby applies for an exe1nption fro1n Federal Aviation Regulations (FARs) identified below and any other rules necessary to allow the co1n1nercial operations of sn1all un1nmu1ed aerial syste1n (i.e., UAS) under the conditions set forth in this petition. FMRA Section 3 3 3 grants the FAA authority to allow the operation of ce1iain UAS within the national airspace.
Legal EZE is a litigation support co1npany owned and operated by a licensed attorney with a private pilot ce1iificate. It is conte1nplated that Legal EZE will use aerial photography and videography services for surveying and evidence collection.
Granting this request co1npo1is with the Secretary ofTransportation's (FAA Adn1inistrator's) responsibilities and authority to not only integrate UAS's into the national airspace syste1n, but to "

...establish require1nents for the safe operation of such aircraft syste1ns [UAS's] in the national airspace syste1n" under Section 333(c) ofthe Refonn Act specific to the

use ofUAS's for co1n1nercial purposes. Further Legal EZE will conduct its operations in co1npliance with the protocols described herein or as otherwise established by the FAA.

Legal EZE Teclu1ology, Inc., Page 1

21 N. Florida Street· Mobile, AL 36607 • 251-473-1800 • 866-473-1800 Toll Free· 251-473-1805 Fax www.jamesajohnsonpc.comI. Contact Information

Legal EZE Teclu1ology, Inc. c/o 

### Jan1es A. 

### Jolu1son 9251 Irvington BLB Hwy. #1210 Irvington, AL 36544 (251) 473-1800 e-n1ail: jjohnson@jan1esajohnsonpc.con1

II. Relevant Statutory Authority:

This petition for exen1ption is subtnitted to fulfill Congress' goal in passing Section 333(a) tlu·ough (c) ofthe Refonn Act. Congress has directed the FAA "to safely accelerate the integration of civil unn1mu1ed aircraft systen1s into the national airspace systen1." Pursuant to Section 33 3 ofthe Refonn Act, the FAA Adn1inistrator is to consider whether cetiain u1unmu1ed aircraft syste1ns may operate safely in the National Airspace ("NAS") before cmnpletion ofthe forn1al UAS rulen1aking, based on the following considerations:

The UAS's size, weight, speed, and operational capability;

Operation ofthe UAS in close proxi1nity to airports and populated areas; and

Operation ofthe UAS within the visual line of sight ofthe operator.3

Ifthe Secretary detennines that such vehicles "1nay operate safely in the National Airspace Systen1, the Secretary shall establish require1nents for the safe operation of such aircraft in the National Airspace Syste1n".

Additionally, the FAA Adtninistrator has general authority to grant exe1nptions fro1n its

.safety regulations and 1ninilnun1 standards when the Adn1inistrator decides a requested exe1nption is in the public interest. A pmiy requesting an exen1ption must explain the reasons why the exe1nption: (1) would benefit the public as a whole, and (2) would not adversely affect safety (or how it would provide a level of safety at least equal to the existing rules).

The Federal Aviation Act expressly grants the FAA the authority to issue exetnptions. This statutory authority, by its tenns, includes exetnpting civil aircraft, as the tennis defined under 40101 ofthe Act, frotn the requiretnent that all civil aircraft n1ust have a current airworthiness cetiificate and those regulations requiring conunercial pilots to operate aircraft in cmnmercial service:

The Adtninistrator tnay grant an exetnption frotn a requirement of a regulation prescribed under subsection (a) or (b) ofthis section or any of sections.

Legal EZE Teclu1ology, Inc., Page 2III. Qualifications for Approval Under Section 333 of the Reform Act

The proposed operations in this petition for exen1ption qualify for expedited approval under Section 3 3 3 ofthe Refonn Act. Each ofthe statutory criteria and other relevant factors are satisfied.

The proposed operations would pern1it Legal EZE the use of sn1all UAS under controlled conditions in airspace that is: (1) predetennined; (2) controlled as to access; and that (3) provides an Increased level of safety beyond that existing when fixed or rotor wing re used to accon1plish the san1e purpose.
Legal EZE uses UASs that are 1ntlltirotor and airplanes, weighing less than 55 pounds including payload. They operate, under nonnal conditions, at speeds not to exceed 50 n1ph. The n1ultirotor has the capability to hover and n1ove in the vertical and horizontal plane. Legal EZE's UASs will operate in line of sight, during daylight hours, a safe distance away fron1 persons and obstructions. Legal EZE will operate at or below 500 feet AGL and will advise the applicable Air Traffic Control (ATC) facility for each flight operated in controlled airspace that as required.

Given the s1nall size ofthe UAS involved and the restricted sterile enviro1unent within which they will operate, this Legal EZE's exe1nption falls within the zone of safety and de1nonstrate an equivalent level of safety, in which Congress desired the FAA to pern1it co1nmercial UAS and the confined area in which the UAS will operate, approval ofthe application presents no hazard in the NAS.

Considering the clear direction in Section 333 ofthe Reforn1 Act, the authority contained in the Federal Aviation Act, as mnended, the equivalent level of safety surrounding the proposed operations, and the significant public benefit, the grant ofthe requested exemptions is also in the public interest.



### IV. Description of Proposed Operations

Below is a sum1nary of operationallilnitations and conditions that will ensure an equivalent or higher level of safety to operations conducted under current regulatory guidelines:

1. The proposed operations ofLegal EZE will be lilnited to the DJI Inspire 1 and DJI Phanto1n 3 when weighing less than 55 pounds including payload.

2. Any operations for the purpose of closed-set 1notion picture and television fihning will be conducted pursuant to the regulations 29-30 below.

3. The UA will not be operated at a speed exceeding 87 knots (1 00 1niles per hour) based upon either groundspeed or calibrated airspeed to determine co1npliance with the 87 knot speed restriction. In no case will the UA be operated at airspeeds greater than the 1naxilnu1n UA operating airspeed reconunended by the aircraft 1nanufacturer.

Legal EZE Teclmology, Inc., Page 34. The UA will be operated at an altitude ofno 1nore than 500 feet above ground level (AGL) as repotied in feet AGL.

5. The UA will be operated within visual line of sight (VLOS) ofthe PIC at all titnes. The PIC will be able to use hun1an vision unaided by any device other than corrective lenses,

as specified on the PIC's FAA-issued airn1an 1nedical certificate or U.S. driver's license.

6. All operations will utilize a visual observer (VO). The UAS will be operated within the visual line of sight (VLOS) ofthe PIC and VO at all titnes. The VO n1ay be used to satisfy the VLOS requiren1ent as long as the PIC always 1naintains VLOS capability. The VO and PIC 1nust be able to con1n1unicate verbally at all tin1es; electronic n1essaging or texting is not pennitted during flight operations. The PIC n1ust be designated before the flight and cannot transfer his or her designation for the duration ofthe flight. The PIC 1nust ensure that the VO can perforn1 the duties required ofthe VO.

7. Legal EZE will insure the operating documents are accessible during UAS operations and 1nade available to the Adn1inistrator upon request. The operator will follow the procedures as outlined in its operating docun1ents. The operator 1nay update or revise its operating docun1ents. The operator will track such revisions and present updated and revised docun1ents to the Adtninistrator or any law enforcetnent official upon request.

8. Legal EZE will perforn1 a functional test on any UAS that has undergone n1aintenance

or alterations that affect the UAS operation or flight characteristics, e.g. replacetnent of a flight critical cotnponent, prior to conducting operations. Functional test flights will only be conducted by a PIC with aVO and n1ust ren1ain at least 500 feet from other people. The functional test flight 1nust be conducted in such a 1natu1er so as to not pose an undue hazard to persons and property.

9. The operator will be responsible for n1aintaining and inspecting the UAS to ensure that it is in a condition for safe operation prior to every flight.

10. Prior to each flight, the PIC will conduct a pre-flight inspection and detennine the UAS is in a condition for safe flight. The pre-flight inspection 1nust account for all potential discrepancies, e.g. inoperable cotnponents, itetns, or equipn1ent. Ifthe inspection reveals a condition that affects the safe operation ofthe UAS, the aircraft is prohibited fro1n operating until the necessary n1aintenance has been perfonned and the UAS is found to be in a condition for safe flight.

11. The operator will follow the UAS manufacturer's 1naintenance, overhaul, replacetnent, inspection, and life litnit requiretnents for the aircraft and aircraft cotnponents.

12. The operator will comply with all UAS manufacturer safety bulletins.

13. The PIC will hold either an airline transport, cotnmercial, private, recreational, or sport pilot certificate. The PIC 1nust also hold a current FAA ainnantnedical certificate or a valid

Legal EZE Teclu1ology, Inc., Page 4U.S. driver's license issued by a state, the District of Colun1bia, Puerto Rico, a territory, a possession, or the Federal govenu11ent. The PIC n1t1st also n1eet the flight review requiren1ents specified in 14 CFR § 61.56 in an aircraft in which the PIC is rated on his or her pilot certificate.

14. The operator will not pennit any PIC to operate unless the PIC den1onstrates the ability to safely operate the UAS in a n1mu1er consistent with how the UAS will be operated under this exen1ption, including evasive and e1nergency 1naneuvers and 1naintaining appropriate distances fro1n persons, vessels, vehicles and structures. PIC qualification flight hours and currency will be logged in a 1nanner consistent with 14 CFR § 61.51 (b). Training operations will only be conducted during dedicated training sessions. During training, proficiency, and experience-building flights, all persons not essential for flight operations are considered nonparticipants, and the PIC n1t1st operate the UA with appropriate distance fro1n nonparticipants in accordance with 14 CFR § 91.119.

15. UAS operations will not be conducted during night, as defined in 14 CFR § 1.1. All operations 1nust be conducted under visual n1eteorological conditions (VMC). Flights under special visual flight rules (SVFR) will not be conducted.

16. Legal EZE will not operate a UAS within 5 nautical1niles of an airport reference point (ARP) as denoted in the current FAA Airpo1i/Facility Directory (AFD) or for airports not denoted with an ARP, the center ofthe airport sy1nbol as denoted on the current FAA- published aeronautical chart, unless a letter of agree1nent with that airpo1i' s 1nanagen1ent is obtained or otherwise pennitted by a COA issued to the exe1nption holder. The letter of agree1nent with the airpo1i 1nanage1nent must be made available to the Adn1inistrator or any law enforcen1ent official upon request.

17. The UAS will not be operated less than 500 feet below or less than 2,000 feet horizontally frmn a cloud or when visibility is less than 3 statute 1niles fron1 the PIC.

18. Ifthe UAS loses co1nn1unications or loses its GPS signal, it is progrmn1ned to return to a pre- detennined location within the private or controlled-access property.

19. The PIC will abo1i the flight in the event ofunpredicted obstacles or emergencies.

20. The PIC will not begin a flight unless (considering wind and forecast weather conditions) there is enough available power for the UA to conduct the intended operation and to operate after that for at least five 1ninutes or with the reserve power reco1nn1ended by the 1nanufacturer if greater.

21. Air Traffic Organization (ATO) Cmiificate of Waiver or Authorization (COA). All operations will be conducted in accordance with an ATO-issued COA.

22. All aircraft will be identified by serial nu1nber, registered in accordance with 14 CFR part 47, and have identification (N- Number) markings in accordance with 14 CFR part 45, Subpart C. Markings 1nust be as large as practicable.

Legal EZE Teclmology, Inc., Page 523. Docmnents used by the operator to ensure the safe operation and flight ofthe UAS and any docu1nents required under 14 CFR §§ 91.9 and 91.203 will be available to the PIC at the Ground Control Station ofthe UAS any tin1e the aircraft is operating. These doctnnents will be n1ade available to the Adn1inistrator or any law enforcen1ent official upon request.

24. The UAS will re1nain clear and give way to all1nam1ed aviation operations and activities at all ti1nes.

25. The UAS will not be operated by the PIC fron1 any n1oving device or vehicle.

26. All Flight operations will be conducted at least 500 feet fron1 all nonparticipating persons, vessels, vehicles, and structures unless:

a. Barriers or structures are present that sufficiently protect nonpmiicipating persons fron1 the UA and/or debris in the event of an accident. The operator will ensure that nonpmiicipating persons re1nain under such protection. If a situation arises where nonpmiicipating persons leave such protection and are within 500 feet of the UA, flight operations will cease i1nn1ediately in a n1anner ensuring the safety of nonpmiicipating persons; and

b. The owner/controller of any vessels, vehicles or structures has granted pern1ission for operating closer to those objects and the PIC has 1nade a safety assess1nent of the risk of operating closer to those objects and detennined that it does not present

an undue hazard.

27. All operations will be conducted over private or controlled-access prope1iy with pennission from the property owner/controller or authorized representative. Pern1ission frmn prope1iy owner/controller or authorized representative will be obtained for each flight to be conducted.

28. Any incident, accident, or flight operation that transgresses the lateral or vertical boundaries ofthe operational area as defined by the applicable COA will be reported to the FAA's UAS Integration Office (AFS-80) within 24 hours. Accidents 1nust be reported to the National Transpo1iation Safety Board (NTSB) per instructions contained on the NTSB Web site: www.ntsb.gov.

29. Any operations for the purpose of closed-set n1otion picture and television filming will be conducted pursuant will require the operator to have a 1notion picture and television operations 1nanual (MPTOM).

30. At least 3 days before aerial fihning for closed-set 1notion picture and television filn1ing
, the operator ofthe UAS will sub1nit a written Plan ofActivities to the local Flight Standards District Office (FSDO) withjurisdiction over the area ofproposed filming. The plan of activities will include at least the following:

Legal EZE Technology, Inc., Page 6a. Dates and titnes for all flights; b. Nan1e and phone nun1ber ofthe operator for the UAS aerial fihning conducted under this grant of exen1ption;

c. Nan1e and phone nun1ber ofthe person responsible for the on-scene operation of the UAS; d. Make, n1odel, and serial or N-Ntnnber ofUAS to be used;

e. Nmne and certificate ntnnber ofUAS PICs involved in the aerial fihning; f. A staten1ent that the operator has obtained pern1ission fron1 propetiy owners and/or local officials to conduct the fihning production event; the list ofthose who gave pennission tnust be tnade available to the inspector upon request; g. Signature ofexen1ption holder or representative; and h. A description ofthe flight activity, including tnaps or diagran1s of any area, city, town, county, and/or state over which filn1ing will be conducted and the altitudes essential to accotnplish the operation.

31. Flight operations on closed-set tnotion picture and television filn1ing will not be conducted closer than 500 feet fron1 participating persons consenting to be involved and necessary for the fihning production, as specified in the exetnption holder's MPTOM.

V. Regulations From Which Exemption is Requested

A. 14 CFR § Pali 61.113 (a) and (b) Private Pilot Privileges and Litnitations; Pilot in Cotntnand B. 14 CFR § 91.103: Preflight Action C. 14 CFR § 91.113: Right-of-Way Rules D. 14 CFR 

### § 91.119 (c): Minitnutn Safe Altitudes

E. 14 CFR § 91.121: Altilneter Settings F. 14 CFR § 91.151(b): Fuel Requiretnents for Flight in VFR Conditions G. 14 CFR § 91.405(a), 91.407(a)(1), 91.409(a)(2); 91.417(a) and (b): Maintenance Inspections H. Others as tnay be applicable

A. 14 CFR §Part 61.113 (a) and (b) Private Pilot Privileges and Limitations Pilot in Command

Section 61.113(a) & (b) litnit private pilots to non-cotnmercial operations. Unlike a conventional aircraft that carries a pilot, passengers, and cargo, the UAS are retnotely controlled with no passengers or propetiy of others on board. Legal EZE respectfully proposes that the FAA should take into account the characteristics and procedures ofthe paliicular UAS.

Legal EZE proposes the following requiretnents:

Legal EZE Technology, Inc., Page 7The PIC will hold either an airline transport, coininercial, private, recreational, or spo1i pilot ce1iificate. The PIC 1nust also hold a current FAA ainnan n1edical certificate or a valid U.S. driver's license issued by a state, the District of Coltnnbia, Puerto Rico, a territory, a possession,

or the Federal govern1nent. The PIC n1ust also 1neet the flight review requiren1ents specified in 14 CFR 

### § 61.56 in an aircraft in which the PIC is rated on his or her pilot certificate.

The operator will not pennit any PIC to operate unless the PIC de1nonstrates the ability to safely operate the UAS in a 1nanner consistent with how the UAS will be operated under this exe1nption, including evasive and e1nergency 1naneuvers and n1aintaining appropriate distances fron1 persons, vessels, vehicles and structures. PIC qualification flight hours and currency will be logged in a manner consistent with 14 CFR § 61.51 (b). Training operations will only be conducted during dedicated training sessions. During training, proficiency, and experience-building flights, all persons not essential for flight operations are considered nonpmiicipants, and the PIC 1nust operate the UA with appropriate distance frmn nonpmiicipants in accordance with 14 CFR § 91.119.

The UA will be operated within visual line of sight (VLOS) ofthe PIC at all tin1es. The PIC will be able to use htunan vision unaided by any device other than corrective lenses,

as specified on the PIC's FAA-issued airn1an n1edical certificate or U.S. driver's license.

All operations will utilize a visual observer (VO). There will be no special ce1iification required for the VO except that they will be over the age of 18 years old and capable of observing the operation ofthe UAS and co1nn1unicating with the PIC. The UAS will be operated within the visual line of sight (VLOS) ofthe PIC and VO at all tin1es. The VO 1nay be used to satisfy the VLOS requirement as long as the PIC always 1naintains VLOS capability. The VO and PIC n1ust be able to co1n1nunicate verbally at all tilnes; electronic n1essaging or texting is not pennitted during flight operations. The PIC 1nust be designated before the flight and cmu1ot transfer his or her designation for the duration ofthe flight. The PIC must ensure that the VO can perfonn the duties required ofthe V0.



### B. 14 CFR § 

### 91.103: Preflight Action

Legal EZE requests an exe1nption fro1n the preflight actions require1nents of 14 CFR 91.113 that prescribes the preflight actions under which aircraft n1ay operate:

Each pilot in comn1and shall, before begi1ming a flight, beco1ne fmniliar with all available infonnation concerning that flight.

(a) Flight under IFR or a flight not in the vicinity of an airport, weather reports and forecasts, fuel requirements, alternatives available ifthe plmu1ed flight cmu1ot be co1npleted, and any known traffic delays ofwhich the pilot in co1n1nand has been advised by ATC;

(b) For any flight, runway lengths at airports of intended use, and the following takeoff and landing distance inforn1ation:

Legal EZE Teclu1ology, Inc., Page 8(1) For civil aircraft for which an approved Airplane or Rotorcraft Flight Manual containing takeoff and landing distance data is required, the takeoff and landing distance data contained therein; and

(2) For civil aircraft other than those specified in paragraph (b)(l) ofthis section, other reliable inforn1ation appropriate to the aircraft, relating to aircraft perfonnance under expected values of airport elevation and runway slope, aircraft gross weight, and wind and ten1perature.

Legal EZE will not operate sUAS's under IFR conditions or when the ceilings are below 1000 feet and the visibility is below 3 statute 1niles. The DJI's UAS for which thsi exen1ption is sought (Inspire 1 and Phanton1 3) do not have published approved Airplane or Rotorcraft Flight Manual containing takeoff and landing distance data.

Legal EZE will insure the operating docun1ents (including operator's n1anual and safety instructions which are attached hereto for the DJI Inspire 

### 1 and Phanton1 3 U.P

...S) are accessible during UAS operations and 1nade available to the Ad1ninistrator upon request. The operator will follow the procedures as outlined in its operating doctnnents. The operator n1ay update or revise its operating docu1nents. The operator will track such revisions and present updated and revised docu1nents to the Ad1ninistrator or any law enforce1nent official upon request.
Legal EZE will perforn1 a functional test on any UAS that has undergone maintenance or alterations that affect the UAS operation or flight characteristics, e.g. replacen1ent of a flight critical co1nponent, prior to conducting operations. Functional test flights will only be conducted by a PIC with aVO and n1ust re1nain at least 500 feet from other people. The functional test flight n1ust be conducted in such a 1nanner so as to not pose an undue hazard to persons and property.

The operator will be responsible for n1aintaining and inspecting the UAS to ensure that it is in a condition for safe operation prior to every flight.

Prior to each flight, the PIC will conduct a pre-flight inspection and determine the UAS is in a condition for safe flight. The pre-flight inspection 1nust account for all potential discrepancies, e.g. inoperable co1nponents, ite1ns, or equip1nent. Ifthe inspection reveals a condition that affects the safe operation ofthe UAS, the aircraft is prohibited fro1n operating until the necessary n1aintenance has been perforn1ed and the UAS is found to be in a condition for safe flight.

The operator will follow the UAS 1nanufacturer's n1aintenance, overhaul, replace1nent, inspection, and life lilnit requirements for the aircraft and aircraft co1nponents.

The operator will con1ply with all UAS 1nanufacturer safety bulletins



### C. 14 CFR 91.113: Right-of-Way Rules

Legal EZE Technology, Inc., Page 9Legal EZE request an exe1nption fro1n 14 CFR 91.113 Right-of-way rules, requiring vigilance by each person operating an aircraft so as to see and avoid other aircraft. When a rule of this section gives another aircraft the right-of-way, the pilot shall give way to that aircraft and n1ay not pass over, under, or ahead of it unless well clear.

The operators of stnall pilotless UAS cmu1ot c01nply with these rules as they have been written. However, Legal EZE proposes to operate its UAS at or below an altitude of 500 feet AGL, well below the nonnal operating altitude of other aircraft. A Visual Observer (VO) will be used to assist the PIC with operations and the avoidance of aircraft and obstacles.

D. 14 CFR. 

### § 91.119: Minimum Safe Altitudes

Legal EZE requests an exetnption fro1n the 1ninin1un1 safe altitude requiretnents of 14 CFR 91.119 that prescribes the n1inilnun1 safe altitudes under which aircraft 1nay operate:

Over any congested area of a city, town, or settlen1ent, or over any open air assetnbly ofpersons, an altitude of 1,000 feet above the highest obstacle within a horizontal radius of2,000 feet ofthe aircraft.

Over other than congested areas at an altitude of 500 feet above the surface, except over open water or sparsely populated areas. In those cases, the aircraft 1nay not be operated closer than 500 feet to any person, vessel, vehicle, or structure.

Section 91.119 (d) allows for a helicopter to operate at less than those 1ninitnun1 altitudes when it can be operated "without hazard to persons or property on the surface," provided that "each person operating the helicopter cotnplies with any routes or altitudes specifically prescribed for helicopters by the FAA."

To provide the intended operations, the sUAS is norn1ally operated below 400 feet AGL. Additionally, due to the nature ofthe proposed operations, the sUAS willtnaintain a lateral distance of at least 1 00 feet fro1n inhabited structures, buildings, vehicles, and vessels, and fro1n people not associated with the operation.

Cotnpared to flight nonnal aircraft, Legal EZE's 1nulti-rotor aircraft weigh a 1naxin1un1 of 55 pounds, and given the lack offlmntnable fuel, any risk associated with these operations is far less than those that presently exist with conventional aircraft. An equivalent level of safety will be achieved given the size, weight, and speed ofthe UAS, as well as the location where it is operated.

Legal EZE proposes that:

A. The UAS will retnain clear and give way to all mmu1ed aviation operations and activities at all tilnes.

Legal EZE Teclu1ology, Inc., Page 10B. The UAS will not be operated by the PIC fron1 any n1oving device or vehicle.

C. All Flight operations will be conducted at least 500 feet fron1 all nonpmiicipating persons, vessels, vehicles, and structures unless:

1. Barriers or structures are present that sufficiently protect nonpmiicipating persons fron1 the UA and/or debris in the event of an accident. The operator will ensure that nonparticipating persons ren1ain under such protection. If a situation arises where nonparticipating persons leave such protection and are within 500 feet ofthe UA, flight operations will cease in11nediately in a n1mu1er ensuring the safety of nonparticipating persons; and

2. The owner/controller of any vessels, vehicles or structures has granted pennission for operating closer to those objects and the PIC has n1ade a safety assesstnent ofthe risk of operating closer to those objects and detern1ined that it does not present an undue hazard.

D. All operations will be conducted over private or controlled-access property with pern1ission frotn the prope1iy owner/controller or authorized representative. Pennission fro1n property owner/controller or authorized representative will be obtained for each flight to be conducted

Futihennore, by operating at such lower altitudes, the UAS will not interfere with aircraft that are subject to the tninin1u1n safe altitude regulations. Finally, the successful safety record of the DJI UAS detnonstrates that the UAS can be safely used at these lower altitudes and closer operating envirmunents.

E. 14 C.F.R. § 91.121: Altimeter Settings

Legal EZE seeks an exetnption frotn 14 CFR 91.121, which requires a person operating

an aircraft to 1naintain cruising altitude or flight level by reference to an altitneter that is set to the elevation ofthe departure airport or baron1etric pressure. An exetnption is required because the UAS does not have a barotnetric altin1eter capable ofbeing calibrated or set by the PIC. It has a syste1n that uses a con1bination oftwo ultrasonic sensors, a 1nonocular cmnera, and GPS to detennine altitude. (See Operator's Manual attached hereto)

Legal EZE proposes to following the procedures set forth in the Operations Manual for calibration ofthe GPS cotnpass and operation ofthe UAS. Legal EZE will confinn the altitude of the launch site shown on the GPS altitude indicator before flight by cotnparing the reading to the known altitude ifpractible. Moreover, the PIC will use the GPS altitude indicator to constantly tnonitor the UAS's height, thus ensuring operation at safe altitudes.

Legal EZE Teclu1ology, Inc., Page 11F. 14 CFR 91.151(a): Fuel Requirements for Flight in VFR Conditions

Legal EZE requests an exen1ption fron1 14 CFR § 91.151 (a)'s fuel requiren1ents for flight in VFR conditions. Section 91.151 states: (a) No person n1ay begin a flight in an airplane under VFR conditions unless (considering wind and forecast weather conditions) there is enough fuel to fly to the first point of intended landing, and assun1ing norn1al cruising speed

-
(1) During the day, to fly after that for at least 25 n1inutes; or (2) At night, to fly after that for at least 45 1ninutes.

In order to n1eet the 30 1ninutes reserve requiren1ent in 14 CFR 91.151, UAS flights could
not be conducted with the UAS' proposed to be operated by Legal EZE. Given the lin1itations on the UAS's proposed flight area and the location ofits proposed operations within a predetern1ined
area, a safety n1m·gin based on a reserve mnount ofbattery life is needed.

The batteries powering Legal EZE's UAS' provide between 18-25 n1inutes ofpowered flight depending upon which UAS. They each have a battery level warning that will alert the PIC before the battery is discharged to the extent that the UAS cmmot be safely returned to the point
at which the flight was initiated. The UAS also have a Return to Hon1e (RTH) function which will bring the UAS back to the point at which the flight was initiated ifit loses contact with the controller or the battery level becotnes critically low. The UAS will return to hotne at 20 1neters AGL and the PIC has the ability to adjust the altitude upon initiating the RTH in order to avoid obstacles.

Legal EZE will not be conducting any sUAS flights at night.

Legal EZE proposes that the PIC will not begin a flight unless (considering wind and forecast weather conditions) there is enough available power for the UA to conduct the intended operation and to operate after that for at least five tninutes or with the reserve power reco1nn1ended by the 1nanufacturer.

G. 14 CFR § 91.405(a), 91.407(a)(l), 91.409(a)(2); 91.417(a) and (b): Maintenance Inspections

Legal EZE also seeks an exetnption fro1n the 1naintenance inspection requiretnents contained in 14 CFR 91.405(a), 91.407(a)(l), 91.409(a)(2), 91.417(a) and (b). These regulations specify 1naintenance and inspection standards in reference to 14 CFR Pmi 43. 14 CFR 91.405(a) (stating that each owner or operator of an aircraft "shall have the aircraft inspected as prescribed in subpmi E ofthis part and shall between required inspections

...have discrepancies repaired as prescribed in pmi 43 ofthis chapter"). An exetnption to these regulations is needed because Part 43 and these sections only apply to aircraft with an airwotihiness certificate, which the UAS will
not have.

Legal EZE willtnaintain the UAS as provided in the Operator's Manual, the operator will

Legal EZE Teclu1ology, Inc., Page 12ensure that the UAS is in working order prior to initiating flight, perfonn required maintenance, and keep a log of any n1aintenance perfonned. The operator will be responsible for n1aintaining and inspecting the UAS to ensure that it is in a condition for safe operation prior to every flight.

Prior to each flight, the PIC will conduct a pre-flight inspection and detern1ine the UAS is in a condition for safe flight. The pre-flight inspection tnust account for all potential discrepancies, e.g. inoperable con1ponents, itetns, or equipn1ent. Ifthe inspection reveals a condition that affects the safe operation ofthe UAS, the aircraft is prohibited fron1 operating until the necessary n1aintenance has been perforn1ed and the UAS is found to be in a condition for safe flight.

The operator will follow the UAS tnanufacturer's n1aintenance, overhaul, replacetnent, inspection, and life lin1it requiretnents for the aircraft and aircraft con1ponents.

The operator will con1ply with all UAS tnanufacturer safety bulletins.



### VI. PUBLIC INTEREST

Granting Legal EZE Teclu1ology, Inc. an exetnption furthers the public interest. National policy set by Congress favors early integration ofUAS into the national airspace in controlled, safe working enviro1u11ents such as those propose in this petition. By lawfully operating its UAS pursuant to FAA policies Legal EZE will help facilitate safe integration ofUAS' s into tnainstreatn USA in the following areas:
Training. To ensure that UAS Operators are properly trained and certified to safely operate they're particular type ofUAS aircraft. Also, training will be conducted in the type ofoperations they will be using their aircraft.

Movies and Videography. Whether the shot requires unique views and expansive panning

or extren1e altitude with radical views, the UAS is designed to hold up under demanding conditions. Because ofthe autopilot feature with pre-designed 1nission managetnent and RIC control interrupt, the pilot and can1era operator can easily create the ultilnate shot with HD video or HD still photos. When working close in on a closed set the hazards to the actors are greatly reduced due to the size ofthe UAS.

News Gathering. Silnilar to 1novies and videography, each news assignn1ent n1ay require

a cotnpletely different shot or view of a scene. With budgets for traditional helicopter use being greatly reduced, the UAS is the perfect solution to allow for easy news gathering for a fraction ofthe cost. The UAS can and will be operated in a sterile area away frotn the public, while the traditional helicopter tnust hovers over persons and propetiy Increasing the danger to individuals.

Real Estate. The UAS can be used in all areas ofreal estate, Including comn1ercial, residential and industrial properties. Using a UAS, real estate professionals can create
Legal EZE Teclu1ology, Inc., Page 13pron1otional videos, photos and unique shots that nonnal can1era aspects cannot capture.

Fire and Rescue. The ability to offer real tin1e HD and IR video facilitates placing perso1u1el and equipn1ent in the right places safely out ofharn1';s way.
Agriculture and Conservation. UAS can aid cmnn1ercial agriculture, land n1anage1nent and conservation efforts by assessing crops, n1apping flood zones, n1easuring snow pack and n1ore. The UAS can fly pre-saved 1nissions via the fully auton1ated ground station, which allows for tin1e-lapse photos of fields, crops and known land tracts. It also can accurately recreate the san1e pattern during all seasons, providing invaluable data for land and soil n1anagen1ent. Using HD video, HD photos, and IR can1eras allows for detailed analysis and recording. With photo rendering software, 3D n1aps and topography can be used in conjunction with tin1e-lapse photos to create highly detailed n1aps for erosion, flood n1apping and other critical aspects ofland n1anagen1ent.

Law. UAS can be very helpful in gathering evidence and infonnation useful in a legal setting. Insurance co1npanies have already recognized the potential value ofusing UAS
to assess prope1iy dmnage after accidents and catastrophes and the video and photographs obtained will be very helpful in detennining the extent and value of dmnage during the claims process. UAS can be used to video accident scenes and to define real property boundries and features. UAS will be instnnnental in evidence collection and preservation.



### VII. Privacy

Legal EZE will not operate its UAS where there is a reasonable expectation ofprivacy without pennission ofthe owner/occupier ofthe property above which the UAS is being operated.



### VIII. Federal Registry Summary

Pursuant to 14 CFR Pmi 11, the following sun11nary is provided for publication in the Federal Register, should it be detennined that publication is needed:

Legal EZE Teclu1ology, Inc. seeks an exen1ption from the following rules:

14CFRPart61.113 (a)and(b); 14CFR91.103; 14CFR91.113; 14CFR91.119; 14 CFR 91.121; 14 CFR 91.151(a); 14 CFR 91.405(a); 14 CFR 91.407(a)(l); 14 CFR; 91.409(a)(2); 14 CFR 91.417 (a) & (b).

Approval ofthis exe1nption request allows Legal EZE to conduct co1n1nercial operations with s1nall and lightweight u1U11a1u1ed aerial systen1s. Legal EZE is in the legal suppo1i business and uses uses UAS, weighing less than 55 pounds and powered by batteries. This eli1ninates vi1iually all ofthat risk given the reduced n1ass and lack of large mnounts of co1nbustible fuel carried on board as co1npared 1nam1ed aircraft. The UAS will carry no passengers or crew and,

Legal EZE Technology, Inc., Page 14therefore, will not expose then1 to the risks associated with n1mu1ed aircraft flights.

The operation ofthis s1nall UAS will provide an equivalent level of safety, supporting the grant ofthe exe1nptions requested herein, Including exe1npting the applicant fron1 the require1nents of several regulations and allowing con1n1ercial operations. These lightweight UAS's operate at slow speeds, close to the ground, and in a sterile enviro1unent. As a result, they

are far safer than conventional aerial survey and inspection operations conducted with fixed wing aircraft or helicopters.

Please let 1ne know ifyou require any additional infonnation.

Sincerely,

# J~~WV\

enc. DJI Phanto1n 3 Professional User Manual DJI Phanto1n 3 Professional Safety Guidelines DJI Inspire 1 User Manual DJI Inspire 1 Safety Guidelines

Legal EZE Teclu1ology, Inc., Page 15