U.S. Department of Transportation Docket Management System 1200 New Jersey Avenue, SE Washington, D.C. 20590

Flame4Ensics Consulting and Investigations LLC.

William Tweedy, Owner

BASIS FOR PETITION

Petitioner, Flame4Ensics Consulting & Investigations (hereinafter “Flame4Ensics”), 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+, in the National Airspace System (NAS), and for an exemption from the requirements of:

14 C.F.R §§ 61.113(a) & (b) 14 CFR 45.23(b) 91.7(a), 91.109,

91.119, 91.121, 91.151, 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b)Name and Address of the Petitioner:

The name and address of the Petitioner and Point of Contact

is: FLAME4ENSICS CONSULTING AND

INVESTIGATIONS LLC ATTN: William Tweedy

103 Los Santos Ct. Vallejo, Ca. 94590-3521

CELL: 707-333-8433 EMAIL: tweedyvfdpio@aol.com

PREFACE: The Federal Aviation Act expressly grants the FAA the authority to issue exemptions. This statutory authority by its terms includes exempting civil aircraft, as the term is defined under §40101 of the Act, that includes UAS, from the requirement that all civil aircraft must have a current

airworthiness certificate.

The Administrator may grant an exemption from a requirement of a regulation prescribed under subsection (a) or (b) of this section or any sections 44702 - 44716 of this title if the Administrator finds the exemption in the public interest. 49 U.S.C. §44701(f) See also 49 USC §44711(a); 49 USC §44704; 14 CFR §91.203 (a) (1).Flame4Ensics proposes to use one UAS: one (1) DJI PHANTOM 2+ for the following purposes:

1. Aerial photography and/or videography for public and/or private use including real estate, architecture, land surveying, engineering and other related professional activities.

2. Aerial photography, videography and/or providing live video feed for public and/or private use including television, public events, videography and news gathering.

3. Aerial inspection/photography of residential/

commercial structures under contract with the owners or local government authority.

4. Aerial video/photography or providing live video feed (so as long as all other parameters are met contained herein) to assist with search and rescue operations in cases of an emergency or natural disaster only when the local authorities or government has requested it by contract or donation.

5. The ability to offer training to persons individually or belonging to both private and/or public organizations that have interests in the use and application of a UASfor the purpose of the safe operation of a UAS to enhance the safety of the National Airspace System (NAS) as well as for the protection of the persons and
property. UAS is a quadcopter with four rotors and four motors and are only capable of vertical take-off and landing. These UAS weigh less than 55 pounds including payload. The Phantom 2+ can reach a maximum airspeed of 36 mph (16 meters/second) in non-GPS mode with similarly perfect flight conditions. NOTE: Flame4Ensics does not fly the UAS in non-GPS mode or anywhere near top speed. It can hover and move simultaneously in both the vertical and horizontal plane.The DJI Phantom 2+ also equipped with GPS and autoreturn function to the predetermined safe landing area as well as allowing reading of magnetic interference that can cause loss of GPS signal.

Flame4Ensics will operate the UAS only in visual line of sight and in such a manner as to ensure the UAS will “not create a hazard to users of the national airspace system or the public.” (Reform Act Section 333 (b)).

This exemption application is expressly submitted to fulfill Congress’ goal in passing Section 333(a) through (c) of the Reform Act. This law directs the Secretary of Transportation to consider whether certain unmanned aircraft systems may operate safely in the national airspace system (NAS) before completion of the rule making required under Section 333 ofthe Reform Act. In making this determination, the Secretary is required to determine which types of UAS do not create a hazard to users of the NAS or the public or pose a threat to national security in light of the following:

• The UAS’s size, weight, speed and operational capability; • Operation of the UAS in close proximity to airports and populated areas; and • Operation of the UAS within visual line of sight of the
operator.

Reform Act § 333 (a). Secretary determines that such vehicles “may operate safely in the national airspace system, the Secretary shall establish requirements for the safe operation of such aircraft in the national airspace system.” Id. §333(c).

The Federal Aviation Act expressly grants the FAA the authority to issue exemptions. This statutory authority by its terms includes exempting civil aircraft, as the term is defined under §40101 of the Act, that includes UAS, from the requirement that all civil aircraft must have a current

airworthiness certificate.

The Administrator may grant an exemption from a requirement of a regulation prescribed under subsection (a) or (b) of this section or any sections 44702 -44716 of this title if the Administrator finds the exemption in the public interest. 49 U.S.C. §44701(f) See also 49 USC §44711(a); 49 USC §44704; 14 CFR §91.203 (a) (1).

RELIEF OVERVIEW:

Given the small size of the UAS involved and the restricted sterile environment within which they will operate, the applicant falls squarely within that zone of safety (an equivalent level of safety) in which Congress envisioned that the FAA must, by exemption, allow commercial operations of UASs to commence immediately. Also due to the size of

the UAS and the restricted areas in which the relevant UAS will operate, approval of the application presents no national security issue.

Given the clear direction in Section 333 of the Reform Act, the authority contained in the Federal Aviation Act, as amended; the strong equivalent level of safety surrounding the proposed operations, and the significant public benefit, including enhanced safety, reduction in environmental impacts, including reduced emissions associated with allowing UAS for aerial inspections, surveying and photography and videography, the grant of the requested exemptions is in the public interest. Accordingly, the applicant respectfully requests that the FAA grant the requested exemption without delay.

AIRCRAFT AND EQUIVALENT LEVEL OF SAFETY: Flame4Ensics proposes that the exemption requested hereinapply to civil aircraft that have the characteristics and that operate with the limitations listed herein. These limitations provide for at least an equivalent or even higher level of safety to operations under the current regulatory structure because the proposed operations represent a safety enhancement to the already safe aerial inspections, surveying and photography and videography operations conducted with

conventional aircraft.

These limitations and conditions to which Flame4Ensics agrees to be bound when conducting commercial operations under an FAA issued exemption include:

1. The UAS will weigh less than 55 lbs. 2. Flights will be operated within visual line of sight of a pilot and/or observer. 3. Maximum total flight time for each operational flight will

be 20 minutes or less.

Flights will be terminated at 25% battery power reserve should that occur prior to the 20 minute limit. 4. Flights will be operated at an altitude of no more than 400

feet AGL. 5. Minimum crew for each operation will consist of the UAS

Pilot and the Visual Observer.

6. The UAS will only operate within a confined sterile closed-set area with a set safety perimeter, the boundaries ofwhich will be determined by the UAS PIC based on the sitespecific activities and speed of the UAS required for theoperation, and coordinated with the jurisdictional FAA FSDO and local government officials as applicable.

7. Visual Observer and PIC will at all times be able to communicate by voice and/or 2-way hands-free radio or wireless communication system. 8. Written and/or oral permission from the relevant property

holders will be obtained.

9. If applicable, all required permissions and permits will be obtained from territorial, state, county or city jurisdictions, including local law enforcements, fire, or other appropriate governmental agencies. 10. If the UAS loses communications or loses its GPS signal,the UAS will have the capability to return to a predetermined safe location and land safely.

11. The UAS will have the capability to abort flight in case of unpredicted obstacles or emergencies.

14 C.F.R. Part 21, Subpart H: Airworthiness Certificates 14 C.F.R. §91.203 (a) (1) Subpart H, entitled Airworthiness Certificates, establishes the procedural requirements for the issuance of airworthiness certificates as required by FAR §91.203 (a) (1). Given the size and limited operating area associated with the aircraft to be utilized by the Applicant, an exemption from Part 21 Subpart H meets the requirements of an equivalent level of safety under Part 11 and Section 333 of the Reform Act. The Federal Aviation Act (49 U.S.C.§44701 (f)) and Section 333 of the Reform Act bothauthorize the FAA to exempt aircraft from the requirement for an airworthiness certificate, upon consideration of the size, weight, speed, operational capability, and proximity to airports and populated areas of the particular UAS. In all cases, an analysis of these criteria demonstrates that the UAS operated without an airworthiness certificate, in the restricted environment and under the conditions proposed will be at least as safe, or safer, than a conventional aircraft (fixed wing or rotorcraft) operating with an airworthiness certificate without the restrictions and conditions proposed. In

consideration of the speed, weight, size, and limited operating area associated with the UAS and its operation, Flame4Ensics operation of the DJI Phantom 2+ UAS meets

the conditions of FMRA Section 333 and therefore will not require an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H.

Accordingly, Flame4Ensics requests relief from Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b), as these sections set forth requirements for maintenance that only apply to aircraft with an airworthiness certificate. Flame4Ensics submits that the requested relief is proper since an equivalent level of safety will be ensured. Flame4Ensics will use experienced personnel or technicians as needed to perform maintenance, alterations, or preventive maintenance on the UAS using the methods, techniques, and practices prescribed in the operating documents (i.e., Monthly Maintenance Log, and DJI Phantom 2+ InstructionManuals). Furthermore, Flame4Ensics will document and

maintain all maintenance records for the DJI Phantom 2+

UAS.

Relief from certain requirements of Section 61.113(a) and (b), entitled Private pilot privileges and limitations: Pilot in command, is requested by Flame4Ensics the extent necessary to allow a Pilot in Command (PIC) to meet or exceed the described requirements of operations set by manufacturer, and who has demonstrated, that the PIC is able to safely operate the DJI Phantom 2+ UAS in a manner consistent with this exemption, including evasive and emergency maneuvers and maintaining appropriate distances from people, vessels, vehicles and structures.

Flame4Ensics relief from Section 91.7(a), entitled Civil aircraft airworthiness, because the DJI Phantom 2+ UAS does not require an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H. As such, Flame4Ensics

submits that the PIC will ensure that the DJI Phantom 2+ UAS is in an airworthy condition, prior to every flight, by determining that the UAS are in compliance with the operating documents (i.e., Monthly Maintenance Log, DJI Phantom 2+ Instruction Manuals), and that the aircraft are in a condition for safe flight.

Flame4Ensics also seeks an exemption from the requirements of Section 91.109, titled Flight Instruction. This regulation provides that "No person may operate a civil aircraft that isbeing used for flight instruction unless that aircraft has fully functioning dual controls." The controls for a UAS do not currently have a set of fully functioning dual controls. If a UAS pilot is being trained, the pilot performing the training would be directly supervising and could take over the controls from the pilot in training if the need arose. This would be similar to the technique of a "throw-over type" control wheel in some fixed wing aircraft. This technique meets the intent 91.109 and provides an equivalent level of safety. In addition, any training would be performed in a designated RC aircraft flying area or similar area with no spectators or other people in the area and following all safety guidelines to ensure the safety of the pilot, observer and trainee(s).

In addition, Flame4Ensics requests an exemption from the requirements of Section 91.119, titled Minimum safe altitudes. This regulation provides that over sparsely populated areas the aircraft cannot be operated closer than 500 feet to any person, vessel, vehicle, or structure. Since the proposed uses would include flights involving photography, videography or survey of persons, vessels, vehicles or structures, it would be necessary to operate closer than 500 feet to the items listed. Operations will only be flown over property or persons where permission has been obtained, and careful pre-planning has been performed including taking weather conditions and wind speeds into account, identifying potential obstacles or threats and aggressive use of the visualsafety observer to maintain safe distances and flight paths. Further, UAS aircraft operate at a very slow airspeed, and a low mass, and do not need as much space to operate safely,

as outlined in 91.119. Flame4Ensics asserts that the slower speed, smaller mass and careful pre- planning would provide an equivalent level of safety. Furthermore, Flame4Ensics can place warning signs, barriers and/or structures to sufficiently protect nonparticipating person from the UAS or debris in

the event of an accident.

Flame4Ensics also seeks an exemption from the requirements of Section 91.121, titled Altimeter Settings, as the DJI Phantom 2+ will not have a typical barometric altimeter onboard. However, altitude information of the DJI Phantom 2+ will be provided to the PIC via Global Positioning System (GPS) equipment and radio communications telemetry data
link, which downlinks from the UAS to the GCS for active monitoring of the flight path. This altitude information, combined with Flame4Ensics operation of the DJI Phantom 2+ UAS within visual line of sight, at or below 400 feet AGL, will ensure a level of safety equivalent to Section
91.121.

Additionally, Flame4Ensics seeks an exemption from the requirements of Section 91.151, entitled Fuel requirements for flight in VFR conditions. This regulation provides that no person may begin a flight in an airplane under day-VFR conditions unless there is enough fuel to fly to the first point of intended landing and to fly after that for at least 30minutes, the intention of this paragraph being to provide a reasonable reserve of energy to plan for a safe landing should there be a delay in landing. Given the close proximity to the ground station, the ability for the UAS to land in a very small space and the built in energy level monitoring of the UAS there is a resulting equivalent level of safety if the flight is planned to be completed with 20% battery energy remaining. Flame4Ensics requests an exemption to the word "fuel" and ask for an equivalent interpretation with the word "energy".

REASONS FOR RELIEF FROM THE LISTED SECTIONS

ABOVE: 1. Section 61.113(a) & b). Relief from Section 61.113(a) and (b) entitled Private pilot privileges and limitations: Pilot in command, is requested to the extent necessary to allow a PIC meet all requirements as

described in the DJI Phantom 2+ owner’s manual to conduct the proposed UAS flight operations for compensation or hire. This relief is requested since the limitations set forth in Section 61.113(a) and (b) state that a private pilot may, for compensation or hire, act as 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, Flame4Ensics submits that an equivalent level of safety will be maintained because no PIC will be allowed to operate the DJI Phantom 2+ UAS unlessthat PIC has demonstrated that the PIC is able to safely operate either the DJI Phantom 2+ UAS in a manner consistent with the operations specifications as described in this exemption, including evasive and emergency maneuvers, as well as maintaining appropriate distances from people, vessels, vehicles and structures.

Furthermore, Flame4Ensics submits that all flights of the DJI Phantom 2+ UAS, conducted by the PIC pursuant to the grant of this Petition: (1) will be incidental to Flame4Ensics’s business; and (2) will not carry passengers or property for compensation or hire.

2. 91.7(a). Relief from Section 91.7(a) entitled Civil aircraft airworthiness, is requested to the extent required to allow

Flame4Ensics to determine that the DJI Phantom 2+ UAS is in airworthy condition prior to every flight by ensuring that the UAS is in compliance with the operating documents (i.e., the Monthly Maintenance Log, and DJI Inspire 1 and DJI Phantom 3 Instruction Manuals).

Flame4Ensics seeks the requested relief because the DJI Phantom 2+ UAS do not require an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H. Therefore,

Flame4Ensics will ensure that the DJI Phantom 2+ UAS are in airworthy condition based upon its compliance with the operating documents (i.e., the Monthly Maintenance Log, DJI Phantom 2+ Instruction Manuals) prior to every flight,and further, determine that the UAS are in condition for safe flight, as stated in the conditions and limitations below.

3. 91.121. Relief from Section 91.121, entitled Altimeter settings, may be required to allow flight operations of the DJI Inspire 1 and DJI Phantom 3 UAS, 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 (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), Flame4Ensics seeks the requested relief because the DJI Phantom 2+ UAS altimeter may be set on the ground to zero feet AGL, rather than the local barometric pressure or field altitude, before each flight.

Considering the limited altitude of the proposed operations, relief from 14 CFR 91.121 is sought to the extent necessary to comply with the applicable conditions and limitations stated below. As more fully set forth herein, an equivalent level of safety will be maintained since the DJI Phantom 2+ UAS are equipped with a barometric pressure sensor and GPS equipment, which

automatically ensures that a ground level pressure setting will be established prior to each flight, and provides the PIC with altitude information of the UAS on the heads-up display

of the GCS.4. 91.151(b). Relief from Section 91.151(b) entitled Fuel requirements for flight in VFR conditions, is requested to the extent required to allow flights of the battery powered DJI Phantom 2+ UAS during daylight hours in visual meteorological conditions (VMC), under visual flight rules (VFR), for flights planned to be completed with 20% battery energy remaining. Flame4Ensics seeks the requested relief because without an exemption from Section 91.151(b), the flight time duration of the battery powered DJI Phantom 2+ UAS will severely constrain the practicality of any aerial video or still photo flight operations that Flame4Ensics proposes to conduct pursuant to this Petition. Significantly, as set forth below, the technical specifications of the DJI Phantom 2+ UAS, the DJI Phantom 2+ operating documents, and Flame4Ensics’s proposed operating limitations, ensure that Flame4Ensics will safely operate the battery powered DJI Phantom 2+ UAS during daylight hours in visual meteorological conditions (VMC), under visual flight rules (VFR), with flights planned to be completed with 20% battery energy remaining.

14 CFR 45.23(b) Marking of the Aircraft; Applicable codes of Federal Regulation require aircraft to be marked according to certain specifications. Flame4Ensics UAS are, by definition, unmanned. They therefore do not have a cabin, cockpit or pilot station on which to markcertain words or phrases. Further, two inch lettering is difficult to place on such small aircraft. The FAA has previously issued exemptions to this regulation through Exemptions No 10167 and 10700.

5. 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), And 91.417(a) & (b). Since Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a) (2), and 91.417(a) & (b) only apply to aircraft with an airworthiness certificate, Flame4Ensics requests relief from

these Sections because the DJI Phantom 2+ UAS do not require airworthiness certificates. As set forth more fully below, the DJI Phantom 2+ UAS meet the conditions of FMRA Section 333 for operation

without an airworthiness certificate. Accordingly Flame4Ensics will use trained technicians to perform maintenance, alterations, or preventive maintenance on the UAS using the methods, techniques, and practices prescribed in the UAS operating documents (i.e., the Monthly Maintenance Log, and DJI Phantom 2+ Instruction Manuals). Furthermore, Flame4Ensics will document and

maintain all maintenance records for the DJI Phantom 2+

UAS.PUBLIC BENEFIT TO GRANTING RELIEF UNDER

PETITION: Granting the present Petition will further the public interest by allowing Flame4Ensics to safely, efficiently, and economically perform aerial photography, videography, surveys and inspections of real estate, construction sites, undeveloped natural areas, and other locations where such work is appropriate and necessary, in support of Public Safety Agencies and other businesses attempts to develop and grow their opportunities for commerce. This exemption application is expressly submitted to fulfill Congress’ goal in passing Section 333(a) through (c) of the Reform Act. This law directs the Secretary of Transportation to consider whether certain unmanned aircraft systems may operate safely in the national airspace system (NAS) before completion of the rule making required under Section 332 of the Reform Act. In making this determination, the Secretary is required to determine which types of UAS do not create a hazard to users of the NAS or the public or pose a threat to national security in light of the following:

• The UAS’s size, weight, speed and operational capability; • Operation of the UAS in close proximity to airports and populated areas; and • Operation of the UAS within visual line of sight of the
operator.
Reform Act§ 333 (a). Lastly, if the Secretary determines that such vehicles “may operate safely in the national airspace system, the Secretary shall establish requirements for the safe operation of such aircraft in the national airspace system.” Id. §333(c).

Given the small size of the UAS involved and the nature of their intended use, the applicant falls squarely within that zone of safety (an equivalent level of safety) in which Congress envisioned that the FAA must, by exemption, allow commercial operations of UASs to commence immediately. Also due to the size of the UAS and their intended use, approval of the application presents no national security

issue. Given the clear direction in Section 333 of the Reform Act, the authority contained in the Federal Aviation Act, as amended; the strong equivalent level of safety surrounding the proposed operations, and the significant public benefit, including enhanced safety, reduction in environmental impacts, including reduced emissions associated with allowing UASs for aerial photography and videography, the grant of the requested exemptions is in the public interest.

Accordingly, the applicant respectfully requests that the FAA grant the requested exemption without delay.REASONS FOR PUBLIC BENEFIT: 1. The Public Will Benefit From Decreased Congestion Of

The NAS. The DJI Phantom 2+ UAS are battery powered and serve as a safe, efficient, and economical alternative to the manned aircraft traditionally utilized to obtain aerial imagery. By reducing the amount of manned aircraft needed to perform such aerial photography and videography, an exemption allowing the use of a DJI Phantom 2+ UAS would reduce the amount of manned aircraft in the NAS, reduce noise and air pollution, as well as increase the safety of life and property in the air and on the ground.

Furthermore, by reducing the number of manned aircraft operating in the NAS, congestion around airports caused by arriving and departing aircraft will be reduced. The DJI Phantom 2+ UAS do not require an airport to takeoff or land. Likewise, a reduction of manned aircraft 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+ UAS. Conducting aerial photography and videography with the DJI Phantom 2+ UAS, instead of manned aircraft, will greatly benefit the public by drastically reducing the levels of air and noise pollution generated during traditional aerialphotography and videography flight operations. By using battery power and electric motors, the DJI Phantom 2+ UAS produce no air pollution, and are 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+ UAS, while reducing the carbon footprint of aerial photography and videography, also eliminate noise pollution, as the UAS are propelled by battery powered electric motors, rather than an internal combustion engine.

By using the DJI Phantom 2+ UAS to perform aerial photography and videography, the substantial risk to life and property in the air and on the ground usually associated with traditional manned aircraft flight operations will be substantially reduced or completely eliminated. Aside from the lack of flight crew members located on-board the aircraft, the DJI Phantom 2+ UAS (weighing respectively about 2.8 pounds with diagonal lengths of about 23 inches and carrying no fuel or other combustibles on board), has less physical potential for collateral damage to life and property on the ground, and in the air, compared to the manned aircraft that typically conduct 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).3. Performing Aerial Photography, Videography, Surveys, Inspections, and Other Operations With The DJI Phantom 2+ UAS Will Benefit The Economy. In addition to being safe and efficient, the DJI Phantom 2+ UAS are also an economical alternative to using manned aircraft to conduct similar aerial operations. As such, operation of the DJI Phantom 2+ UAS will allow U.S.-based companies, like Flame4Ensics, 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+ UAS is one such technology that not only allows companies greater operational flexibility compared to manned aircraft, but provides such flexibility without the high operational cost of a traditional manned aircraft. By operating the DJI Phantom 2+ UAS, companies such as Flame4Ensics can remain competitive and profitable, and therefore, provide greater job stability to employees and contractors, which will ultimately contribute to growth of the U.S. economy. Improved financial performance of U.S. companies, through commercial use of the DJI Phantom 3 UAS, provides a stable workforce that increases consumer spending; improves local, state, and federal tax revenues; and allows companies to invest in research and development in order to remain 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, Flame4Ensics’s proposed operation of the DJI Phantom 2+ UAS will not implicate any privacy issues. Specifically, the DJI Phantom 2+ UAS will be operated only in compliance with operating documents (i.e., the Flame4Ensics Standard Operating Procedures, the Monthly Maintenance Log, and DJI Phantom 2+ Instruction Manuals) which require property owner involvement as well as local law enforcement notification, and in accordance with the Federal Aviation Regulations, including the minimum altitude requirements of 14 C.F.R. § 91.119.

REASONS WHY GRANTING THE EXEMPTION

WOULD NOT ADVERSELY EFFECT SAFETY: Reasons Why The DJI Phantom 2+ UAS Meet The

Conditions Of The FAA Modernization 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 operation, Flame4Ensics operation of the DJI Phantom 2+ UAS meet the conditions of FMRA Section 333, and will not require an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H. In seeking this exemption,

Flame4Ensics submits that the DJI Phantom 2+ UAS can operate safely in the NAS pursuant to FMRA Section 333, as demonstrated by the characteristics of the DJI Phantom 2+ UAS. Both UAS are designed to hover and/or return to a safehome point in the event of loss of the control link with the

GCS.

During all flights of either the DJI Phantom 2+ UAS, the PIC will be assisted by a visual safety observer to maintain safe visual line of sight tracking and control of the UAS. All flights will be conducted solely for the purpose of performing aerial photography, videography, surveys and inspections, not to carry passengers or cargo for hire.

Due to the design of the DJI Phantom 2+ UAS, neither UAS is able to exceed the maximum allowed airspeed under prior FAA exemptions. The UA may not be flown at an indicated airspeed exceeding 35 knots. The UAS does not reach the 55 pound threshold since it weighs under 10 pounds including battery and camera payload. The maximum operating altitude is set at 400 feet in the navigation software for both UAS and the software provides both a visual and audio warning regarding the approaching maximum altitude.

PERSONAL STATEMENTS AND BACKGROUND: William Tweedy is operating Flame4Ensics Consulting and Investigations a limited liability company operating as Flame4Ensics Consulting and Investigations LLC. The owner is a retired Public Safety Officer, (Police and Fire) and has a great interest in photography, videography and RC aircraft. Located in the Northern California, Flame4Ensics operates mostly in rural and suburban areas and occasionally (if they are lucky) by the beach.As a company, Flame4Ensics has commercial liability Insurance. I am willing to take additional coursework and pay licensure fees to be able to operate their UAS commercially. My main focus is safety during flight operations, both for myself and others as well as their equipment and others’ property. I am very familiar with the DJI Operator Manuals for the DJI Phantom 2+ and work hard to stay on top of developments in the industry as well as how UAS are being used in the community.

I have already met with local police and Fire Departments and municipal code inspectors regarding how UAS could be valuable in promoting public safety and ensuring compliance with local conservation and land use ordinances. Obtaining this exemption will be a major step forward in making this dream a reality.

Respectfully submitted,

William Tweedy Flame4Ensics Consulting and Investigations LLC.