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 collection1and 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 feet from all nonparticipating 

persons, vessels, vehicles, and structures unless:

a. Barriers or structures are present that sufficiently protect nonparticipating persons 

from the UA and/or debris in the event of an accident. The operator must ensure 

that nonparticipating persons remain under such protection. If a situation arises 

where nonparticipating persons leave such protection and are within 500 feet of 

the UA, flight operations must cease immediately in a manner ensuring the safety 

of nonparticipating persons; and

b. The owner/controller of any vessels, vehicles or structures has granted permission 

for operating closer to those objects and the PIC has made a safety assessment of 

the risk of operating closer to those objects and determined that it does not 

present an undue hazard.

The PIC, VO, operator trainees or essential 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

Enclosures
U.S. Depmi1nent of Transportation 

Docket Manage1nent Syste1n 

1200 New Jersey Ave., SE 

Washington, DC 20590 

ATTORN[YS AT LAW 

May 13, 2015 

Re: Petition of Legal 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 of the 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 of Transportation'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) of the 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.com 
I. Contact Information 

Legal EZE Teclu1ology, Inc. 

c/o J an1es A. J olu1son 

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 3 3 3 of the Refonn Act, the FAA Adn1inistrator is to consider whether cetiain u1unmu1ed 

aircraft syste1ns may operate safely in the National Airspace ("NAS") before cmnpletion of the 

forn1al UAS rulen1aking, based on the following considerations: 

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

Operation of the UAS in close proxi1nity to airports and populated areas; and 

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

If the 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 of the 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) of this section or any of sections. 

Legal EZE Teclu1ology, Inc., Page 2 
III. 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 of the Refonn Act. Each of the 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 of the 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 U AS and the confined area in which the U AS will operate, approval of the 

application presents no hazard in the NAS. 

Considering the clear direction in Section 333 of the 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 of the 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 of Legal 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 3 
4. The UA will be operated at an altitude of no 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) of the 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) of the 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 of the flight. The PIC 1nust ensure that the VO can perforn1 the 

duties required of the 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 U AS 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. If the inspection reveals a 

condition that affects the safe operation of the 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 4 
U.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 of the 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 of unpredicted 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 A TO-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 5 
23. Docmnents used by the operator to ensure the safe operation and flight of the U AS 

and any docu1nents required under 14 CFR §§ 91.9 and 91.203 will be available to the PIC at the 

Ground Control Station of the 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 of the 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 of the UAS will sub1nit a written Plan of Activities to the local Flight 

Standards District Office (FSDO) with jurisdiction over the area of proposed filming. The plan of 

activities will include at least the following: 

Legal EZE Technology, Inc., Page 6 
a. Dates and titnes for all flights; 

b. Nan1e and phone nun1ber of the operator for the UAS aerial fihning conducted 

under this grant of exen1ption; 

c. Nan1e and phone nun1ber of the 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 of those who 

gave pennission tnust be tnade available to the inspector upon request; 

g. Signature of exen1ption holder or representative; and 

h. A description of the 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 of the paliicular U AS. 

Legal EZE proposes the following requiretnents: 

Legal EZE Technology, Inc., Page 7 
The 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) of the 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 of the UAS and co1nn1unicating with the PIC. The UAS will be operated within the 

visual line of sight (VLOS) of the 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 of the flight. The PIC must ensure that the VO can perfonn the 

duties required of the V 0. 

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 if the plmu1ed flight cmu1ot be 

co1npleted, and any known traffic delays of which 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) of this 

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. If the inspection reveals a 

condition that affects the safe operation of the UAS, the aircraft is prohibited fro1n operating 

until the necessary n1aintenance has been perforn1ed and the U AS 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 9 
Legal 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 of persons, an altitude of 1,000 feet above the highest obstacle within a 

horizontal radius of2,000 feet of the 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 of the 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 of flmntnable 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 of the UAS, as well as the location where it is 

operated. 

Legal EZE proposes that: 

A. The U AS will retnain clear and give way to all mmu1ed aviation operations and 

activities at all tilnes. 

Legal EZE Teclu1ology, Inc., Page 10 
B. 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 of the 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 of the 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 of the departure airport or baron1etric pressure. An exetnption is required because 

the UAS does not have a barotnetric altin1eter capable of being calibrated or set by the PIC. It 

has a syste1n that uses a con1bination of two 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 of the GPS cotnpass and operation of the 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 if practible. 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 11 
F. 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 3 0 1ninutes reserve requiren1ent in 14 CFR 91.151, U AS 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 of its proposed operations within a predetern1ined 

area, a safety n1m·gin based on a reserve mnount of battery life is needed. 

The batteries powering Legal EZE' s U AS' provide between 18-25 n1inutes of powered 

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 U AS back to the point at which the flight was initiated if it 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 s U AS 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 U A 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 of this part and shall between required inspections ... have discrepancies repaired as 

prescribed in pmi 43 of this 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 12 
ensure 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. If the inspection reveals a 

condition that affects the safe operation of the 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 U AS 

pursuant to FAA policies Legal EZE will help facilitate safe integration of UAS' 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 of operations 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 of the 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 of the 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 of the 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 of real estate, Including comn1ercial, 

residential and industrial properties. Using a UAS, real estate professionals can create 

Legal EZE Teclu1ology, Inc., Page 13 
pron1otional 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 of land 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 of using 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 of privacy 

without pennission of the owner/occupier of the 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 of this 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 of that risk given the reduced n1ass and lack of large mnounts of co1nbustible fuel 

carried on board as co1npared 1nam1ed aircraft. The U AS will carry no passengers or crew and, 

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

The operation of this s1nall UAS will provide an equivalent level of safety, supporting the 

grant of the 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 if you 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