## Petition fo r Exemption 14 CFR § 11.81

If you have completed your research and determined you need an exemption, you must send a petition for exemption 120 days before you need the exemption to take effect. Your petition for exemption must
include

— A.) Your name and mailing address. You may include other contact information such as a fax number, telephone number, or email address; Bryan Stewart Media Stew, LLC
PO Box 5048 Incline Village, NV 89450
775

- 721

- 9714 bryan@mediastew.tv

B.) The specific section or sect ions of 14 CFR from which you seek an exemption;

1. Section 61.113 , entitled Private pilot privileges and limitations: Pilot in command
, subsections (a) and (b). (a) No person who holds a private pilot certificate may act as pilot in command of an aircraft that is carrying passengers or property for compensation or hire; nor may that person, for compensation or hire, act as pilot in command of an aircraft. (b) A private pilot may, for compensation or hire, act as pilot in command of an
aircraft in connection with any business or employment if:

1. The flight is only incidental to that business or employment; and
2. The aircraft does not carry passengers or property for compensation or
hire.

2. Section 91.7, entitled Civil aircraft airworthiness , subsection (a)

. (a) No person may operate a civil aircraft unless it is in an airworthy condition.

3. Section 91.121, entitled Altimeter settings , subsec tion (a). (a) Each person operating an aircraft shall maintain the cruising altitude or flight level of that aircraft, as the case may be, by reference to an altimeter that is set, when operating

– 1. Below 18,000 feet MSL, to

– (i) The current repor ted altimeter setting of a stat ion along the route and
within 100 nautical miles of the aircraft ; (ii) If there is no station within the area prescribed in paragraph (a)(1)(i) of this section, the current reported altimeter setting of an appropriate available st ation; or (iii) In the case of an aircraft not equipped with a radio, the elevation of the departure airport o r an appropriate altimeter setting available before departure;4. Section 91.151, entitled Fuel requirements for flight in VFR conditions , subsection (b). (b) No person may begin a flight in a rotorcraft under VFR conditions unless

(considering wind and forecast weather conditions) there is enough fuel to fly to the first point of intended landing and, assuming normal cruising speed, to fly
after that for at least 20 minutes.

5. Section 91.405, entitled Maintenance required , subsection (a) Each owner or operator of an aircraft

- (a) Shall have that aircraft inspected as prescribed in subpart E of this part and shall between required inspections

, except as provided in paragraph (c) of this section, have discrepancies repaired as prescribed in part 43 of this chapter.

6. Section 91.407, entitled Operation after maintenance, preventive maintenance, rebuilding or alteration , subsection (a)( 1). (a) No person may operate any aircraft that has undergone maintenance, preventive maintenance, rebuilding or alteration unless

– (1) It has been approved for return to service by a person authorized under Section 43.7 of this chapter.

7. Section 91.409, entitled Inspections , subsection (a)(1) and (a)(2). (a) Except as provided in paragraph (c) of this section, no person may operate an aircraft unless, within the preceding 12 calendar months, it has had

– (1) An annual inspection in accordance with part 43 of this chapter and has been approved for return to service by a person authorized by Section 43.7 of this chapter; or (2) An inspection for the issuance of an airworthiness certificate in accordance with part 21 of this chapter.

8. Section 91.417, entitled Maintenance records , subsection (a) and (b). (a) Except for work performed in accordance with Section 91.411 and 91.413, each registered owner or operator shall keep the following records for the periods specified in paragraph (b) of this section:
1. Records of the maintenan ce, preventive maintenance, and alteration and
records of the 100

- hour, annual, progressive and other required or approved inspections, as appropriate, for each aircraft (including the airframe) and each engine, propeller, rotor, and appliance of an aircra ft.
The records must include

— (i) A description (or reference to data acceptable to the Administrator) of the work performed; and(ii) The date of completion of the work performed; and (iii) The signature, and certificate number of the person approving the air craft for return to service.

2. Records containing the following information:

(i) The Total time in service of the airframe, each engine, each propeller, and each rotor. (ii) The current status of life

- limited parts of each airframe, engine, propeller, ro tor and appliance. (iii) The time since last overhaul of all items installed on the aircraft which are required to be overhauled on a specified

time basis. (iv) The current inspection status of the aircraft, including the

time since the last inspection required by the inspection program under which the aircraft and its appliances are

maintained. (v) The current status of applicable airworthiness directives (AD) and safety directions includi ng , for each, the method of compliance, the AD or safety directive number and revision date. If the AD or safety directive involves recurring action, the time and date when the next action is required. (vi) Copies of the forms prescr ibed by Section 43.9(d) of this chapter for each major alteration to the airframe and currently installed engines, rotors, propellers and appliances. (b) The owner or operator shall retain the following records for the periods

prescr ibed:
1. The records specified in paragraph (a)(1) of this section shall be retained until the work is repeated or superseded by other work or for 1 year after the work is performed.
2. The records specified in paragraph (a)(2) of this section shall be retained
and transferred with the aircraft at the time the aircraft is sold.
3. A list of defects furnished to a registered owner or operator under Section 43.11 of chapter shall be retained until the defects are repaired and the aircraft is approved for return to s ervice.

C.) The extent of relief you seek and the reason you seek the relief;

1. 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 holding a private pilot certificate, a third

- class airman medical certificate and has completed the minimum hours and cycles as a UAS rotorcraft pilot to conduct theproposed UAS flight operations for co mpensation. The 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, Media Stew , LLC submits that an equivalent level of safety
will be maintained because no PIC wil l be allowed to operate the DJI Inspire I UAS unless that PIC has demonstrated that the PIC is able to safely operate the DJI Inspire I
UAS in a manner consistent with the DJI Inspire I Flight Manual and operations specifications as described in this exemp tion, including evasive and emergency maneuvers, as well as maintaining appropriate distances from people, vessels, vehicles
and structures.

Further, Media Stew , LLC submits that all flights of the DJI Inspire I UAS

, conducted by the PIC pursuant to the grant of this Petition

– (1) will be incidental to Media Stew’s business; and (2) will not carry passengers or property for compensation or hire.

2. Relief from Section 91.7(a) entitled Civil aircraft airworthiness
, is requested to the extent required to allow Media Stew , LLC to determine that the DJI Inspire I UAS is in an airworthy condition prior to every flight by ensuring that the UAS is in compliance with the DJI Inspire I F light M anual, and that the aircraft i s in a condition for safe flight.

Media Stew, LLC seeks the requested relief because the DJI Inspire I UAS does not require an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H. Therefore, Media Stew, LLC will ensure that the DJI Inspire I UAS is in an airworthy condition based upon its compliance with the operating documents (i.e., the DJI Inspire I Flight Manual) prior to every flight, and as stated in the conditions and limitations below.

3. Relief from Section 91.121 entitled Altimeter settings
, may be required to allow flight operations of the DJI Inspire I UAS, which utilizes GPS equipment and a radio communications telemetry data link to downlink altitude information to the PIC from the UA to the Ground Control System. As more fully set forth below, safety will be maintained
as a result of the DJI Inspire I UA ’s altitude readout via GPS equipment, and Media Stew
LLC’s operation of the DJI Inspire I UA within visual line of sight, a t or below 400 feet
AGL.

4. 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 Inspire I UA during daylight hours in vis ual mete o r o logical conditions (VMC), under visual flight rules (VFR) conditions , to co ntinue for a total duration of 10 minutes, which will
ensure tha t the UA will l and with five minutes of batter power remaining. Media Stew, LLC seeks the requested relief because without an exemption from Section 91.151(b), the flight time duration of the battery powered DJI Inspire I UA will severely constrain thepra cticality of any aerial industrial video footage acquisition that Media Stew, LLC proposes to conduct pursuant to this Petition.

Significantly, as set forth below, the technical specification of the DJI Inspire I UAS, it’s flight manual, and Media Stew, LLC ’s proposed operating limitations, ensure that Media Stew, LLC will safely operate the battery powered DJI Inspire I UA during daylight hours in VFR conditions, for a total flight duration of 1 0 minutes, landing with five minutes of batter power remaining.

5. Relief from Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b), S ince 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 airwo rthiness certificate, Media Stew LLC requests relief
from these Sections because the DJI Inspire I UAS does not require an airworthiness certificate. As set forth more fully below, the DJI Inspire I UAS meets the conditions of
Section 333 of the FMRA for o peration without an airworthiness certificate. Accordingly, Media Stew, LLC will use authorized technicians to perform maintenance, alterations, or preventive maintenance on the UAS using methods, techniques and practices prescribed
in the manufacturer’s m aintenance manual. Furthermore, Media Stew, LLC will
document and maintain all maintenance records for the DJI Inspire I UAS.

D.) How your request would benefit the public as a whole;

Granting the present Petition will further the public interest by allowing Media Stew, LLC to safely, efficiently, and economically acquire aerial industrial video , commercially, in support of industrial
video production. Additionally, use of the DJI Inspi re I UAS will decrease congestion of the
N ational A ir S pace , reduce pollution, and provide significant benefits to the economy. Notably, the benefits of Media Stew, LLC’s proposed operation of the DJI Inspire I UAS will be realized without implicating any privacy issues.

1. Media Stew, LLC submits this Petition to commercially operate the DJI Inspire I UAS with the intention of acquiring aerial footage to be used in industrial video production. The DJI Inspire I UAS will provide a safe, efficient and economical way to acquire this footage, by having a licensed private pilot, who meets all the necessary qualification s , flying within the guidelines set by the FAA. This would allow access , to small and medium sized business owners, of high quality footage not normally accessible to these business owners who are looking to increase their reach and customer base with marketing
materials.

2. The Public will benefit from decreased congestion of the National Air Space. The DJI Inspire I UAS is battery powered and serves as a safe, efficient, and economical alternative to the manned aircraft traditionally utilized to obtain aerial footage. By reducing the amount of manned aircraft needed to acquire aerial footage, an exemption allowing the use of a DJI Inspire I UA S would reduce the amount of manned aircraft in the National Air Space, reduce the noise and air pollution, as well as increase the safetyof life and property in the air and on the ground. Furthermore, by reducing the number of manned aircraft operating i n the National Air Space, congestion around airports caused by arriving and departing aircraft will be reduced. The DJI Inspire I UAS does not require an airport to takeoff or land. Likewise, a reduction of manned aircraft would result in fewer
aircraft th at must be handled by air traffic control during the ground, takeoff, departure, arrival and landing phases of flight operations.

3. Conducting video acquisitions with the DJI Inspire I UAS, instead of manned aircraft, will greatly benefit the public by dra stically reducing the levels of air and noise pollution generated during traditional aerial video footage acquisition flight operations. By using battery power and electric motors, the DJI Inspire I UAS produce s no air pollution, and is the most viable environmentally conscious alternative to the cabin class, six cylinder internal combustion twin engine aircraft that are typically utilized for aerial acquisitions, while burning approximately 20

- 30 gallons per hou r of leaded aviation fuel. The DJI Inspire I UA, while reducing the carbon footprint of aerial video footage acquisitions, also eliminates noise pollution, as the UA is propelled by battery powered electric motors, rather than an internal combustion engine

.

By using the DJI Inspire I to perform aerial video footage acquisitions, the substantial risk to life and property in the air and on the ground, which is usually associated with traditional manned aircraft flight operations, will be substantially reduce d or completely eliminated. Aside from the lack of flight crew members located onboard the aircraft, the DJI Inspire I UA (weighting approximately 6.5 Pounds at it s maximum gross weig ht with a
diameter of 18 inches, and with no fuel on board), has less phy sical potential for collateral damage to life and property on the ground, and in the air, compared to the manned aircraft that typically conduct aerial acquisitions (Weighting approximately 6,500 pounds with a wingspan of approximately 40 feet, a length of 34 feet, and a fuel capacity of 180 gallons).

4. Performing a erial video f ootage a cquisition with the DJI Inspire I will benefit the economy. In addition to being safe and efficient, the DJI Inspire I UAS is also an economical alternative to using manned aircraft to conduct aerial footage acquisitions. As such, operation of the DJI Inspire I UAS will allow Media Stew, LLC to remain competitive and contribute to the growth of the US economy. Specifically, with the rising cost of aviation
fuel and the EPA re gulatory actions phasing out leaded aviation fuels, US owned and operated companies must adopt new and alternative technology in order to remain competitive. Operating the battery powere d DJI Inspire I UAS is one such technology that not only allows compan ies 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 Inspire I UAS, companies such as Media Stew, LLC can remain competitiv e and profitable, and therefore, provide greater job stability to employees and contractors, which will ultimately contribute to growth of the US economy. Improvedfinancial performance of US companies, through commercial use of the DJI Inspire I UAS, prov ides 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.

5. There are no Privacy Issues. Similar to the manned aerial acquisition flight operations that have been conducted for decades, Media Stew, LLC’s proposed operation of the DJI Inspire I UAS will not implicate any privacy issues. Specifically, the DJI Inspire I UAS will be operated only in accordance with all Federal Aviation Regulations, including the minimum altitude requirements of 14 C.F.R. Section 91.119. Most significantly, the DJI Inspire I UA will not be operated closer than 500 feet to any person, ves sel, vehicle, or structure, which is not directly involved in the operation

.

E.) Reasons why the exemption would not adversely affect safety, or how the exemption would provide a level of safety at least equal to the existing rule;

1. Reasons why the DJI Inspire I UAS meets 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, Media Stew LLC’s operatio n of the UAS meets the conditions of FMRA Section 333, and will not require an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H.

Section 333 provides authority for a UAS to operate without airworthiness certification
and sets for th requirements for considering whether a UAS will create a hazard to users of the NAS or the public, or otherwise pose a threat to national security. Specifically, FMRA Section 333 states the following, in part: (a) In General.

— Nothwithstanding any other requ irement of this subtitle, and not later than 180 days after the date of enactment of this Act, the Secretary of Transportation shall determine if certain unmanned aircraft systems may operate safely in the national airspace system before completion of the plan and rulemaking required by Section 332 of this Act or the guidance required by
section 334 of this Act. (b) Assessment of Unmanned Aircraft Systems.

— In making the determination under subsection (a) the Secretary shall determine, as a minimum

— (1) Which types of unmanned aircraft systems, if any, as a result of their size, weight, speed, operational capability, proximity to airports and populated areas, and operation within visual line of sight do not create a hazard to users of the national airspace system or the public or pose a threat to national security; and (2) Whether a certificate of waiver, certificate of authorization, or airworthiness certification under section 44704 of title 49, United States Code, isrequires for the operation of unmanned aircraft

sys tems identified under paragraph (1). (c) Requirements for Safe Operation.

– If the Secretary determines under this section that certain unmanned aircraft systems may operate safely in the national airspace system, the Secretary shall establish requirements for the safe operation of such aircraft systems in the national airspace system.

In seeking this exemption, Media Stew, LLC submits that the DJI Inspire I UAS can operate safely in the NAS pursuant to FMRA Section 333, as demonstrated by : (a) the
characteristics of the DJI Inspire I UAS; (b) the pilot certification requirement; and (c) the specific operating limitations. (a) The DJI Inspire I UAS does not create a hazard to users of the NAS or the public, or otherwise pose a threat to national security considering its size, weight speed and operational capability. The UAS Flight and Navigation Modes Enable the UAS to remain within a Defined Operational Area. The UAS is designed for Automatic return to launch in the event of loss of the
control link or navigation (b) Flight operations of the UAS are limited to the Line of Sight of a certificated PIC with a safety observer. Media Stew, LLC will only utilize certificated pilots who possess a valid airman medical certificate to act as a pilot in command of the UAS. Additionally, a safety observer will assist all pilots. (c) Flights of the DJI Inspire I UAS will be conducted pursuant to specific operating limitations. In seeking this exemption, Media Stew LLC proposes to commercially operate the DJI Inspire I UAS for the special purpose of obtaining industrial aerial footage pursuant to the following specific operating
limitations: (1) Operations authorized by this grant of exemption are limited to a quad rotor aircraft weighting less than 10 pounds. Proposed oper ations of any other aircraft will require a new petition or a petition to amend this grant. (2) The UA may not be flown at an indicated airspeed exceeding 43.4 knots. (3) The UA must be operated at an altitude of no more than 400 feet above ground level (AGL).
All altitudes reported to ATC must be in feet
AGL. (4) 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.(5) All operations must utilize a visual observer (VO). 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. The PIC must be designated before the flight and cannot transfer his or her designation for the duration of the flight. (6) The operator’s manual and this gran t of exemption must be maintained and made available to the Administrator upon request. If a discrepancy exists between the conditions and limitations in this exemption and the procedures outlined in the operator’s manual, the conditions and limitations herein take precedence and must be followed. Otherwise, the operator must follow the proc edures as outlined in its operator’s manual. The operator may update or revise its operator’s manual. It is the operator’s responsibility to track such revisions and present updated and revised documents to the Administrator upon request. The operator must also present updated and revised documents if it petitions for extension or amendment. 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 amendment t o their exemption. The FAA’s UAS Integration Office (AFS

- 80) may be contacted if questions arise regarding updates or revisions to the operator’s manual. (7) Prior to each flight the PIC must inspect the UAS to ensure it is in a condition for safe flight. If t he inspection reveals a condition that affects the safe operation of the UAS, the aircraft is prohibited from operating until the necessary maintenance has been performed and the UAS
is found to be in a condition for safe flight. The
Ground Control Station must be included in the preflight inspection. All maintenance and alterations must be properly documented in the
aircraft records. (8) Any UAS that has undergone maintenance or alterations that affect the UAS operation or flightcharacteristics (e.g. replacement of a flight critical component), must undergo a functional test flight in accordance with the operator’ s manual. The PIC who conducts the functional test flight must make an entry in the UAS aircraft records of the flight. The requirements and procedures for a functional test flight and aircraft record entry must be added to the operator’s
manual. (9) The preflight inspection must account for all discrepancies, i.e. inoperable components, items, or equipment, not covered in the relevant preflight inspection sections of the operator’s
manual. (10) The operator must follow the manufacturer’s UAS aircraft/component, maintenance, overhaul, replacement, inspection, and life limit requirements, with particular attention to flight
critical components that may not be addressed
in the manufacturer’s manuals. (11) Media Stew, LLC must carry out their maintenance, inspections, and record keeping requirements in accordance with the operator’s
manual. Maintenance, inspection, and
al terations must be noted in the aircraft logbook, including total flight hours, description of work accomplished, and the signature of the authorized UAS technician or PIC returning the
UAS to service. (12) Each UAS operated under this exemption must comply with all manufacturer System and Safety
Bulletins. (13) The PIC must possess at least a private pilot
certificate and a third

- class airman medical
certificate

. (14) The operator may not permit any PIC to operate unless that PIC has demonstrated, through the training and currency require ments set forth in the operator’s manual, that the PIC is able 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 appropriatedistances from peop le, vessels, vehicles and

structures. (15) UAS operations may not be conducted during night, as defined in 14 C.F.R. Section 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 the airport reference point as denoted on a
current FAA

- published aeronautical chart. (17) The UA may not be operated less than 500 feet below or less than 2,000 feet horizontally from a
cloud o r 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 and land, or be
recovered in accordance w ith the operator’s
manual. (19) The PIC must abort the flight in the event of unpredicted obstacles or emergencies in accordance with the operator’s manual. (20) The PIC is prohibited from beginning a UAS flight unless (considering wind and forecast
weather conditio ns and assuming normal cruising speed) there is enough power to fly to the first point of intended landing prior to utilizing battery reserve power. (21) All aircraft operated in accordance with this exemption must be identified by serial number, registered in accordance with 14 C.F.R. Part 47, and have identification (N

- Number) markings in accordance with 14 C.F.R. Part 45, Subpart C. Markings must be as large as practical. (22) Before conducting operations, the radio frequency spectrum used for operation and

contro l of the UA must comply with the Federal Communication Commission (FCC) or other appropriate government oversight agency requirements. (23) The documents required under 14 C.F.R. 91.9
and 91.203 must be available to the PIC at theGround 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 yield the right of way to all other 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) The UA may not be operated over congested or densely populated areas. These areas include but are not limited to the yellow areas depicted on World Aeronautical Chars (WAC ), Sectional Aeronautical Charts (Sectionals), or Terminal Area Charts (TAC). However, aeronautical charts may not reflect pertinent local information. Ultimately it is the PIC’s responsibility to maintain the minimum safe altitudes required by
Section 91. 119. (27) Flight operations must be conducted at least 500
feet from all non

- participating persons (persons other than the PIC or VO), vessels, vehicles,
and structures unless:

a. Barriers or structures are present that sufficiently protect nonparticipating persons from 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 opera tions must cease immediately and/or;
b. The aircraft is operated near vessels,
vehicles or structures where the land owner/controller has granted permission and the PIC has made a safety assessment of the risk of operating closer to those objects and;

c. Operati ons near the PIC or VO do not present an undue hazard to the PIC or VO, per Section 91.119(a). (28) All operations shall be conducted over private or
controlled

- access property with permission fromthe land owner/controller or authorized representative. Permis sion from land owner /controller or authorized representative will be obtained prior to the beginning of every flight. (29) 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 repor ted to the National Transportation Safety Board (NTSB) per
instructions contained on the NTSB Web site: www.ntsb.gov

2. Reasons why an exemption from the requirements of Section 61.113(a) and (b) would not adversely affect safety. Media Stew LLC submits that the equivalent level of safety established by Section 61.113(a) and (b) will be maintained because no PIC will be allowed to operate the DJI Inspire I UAS unless that PIC has demonstrated th at the PIC is able to safely operate the DJI Inspire I UAS in a manner consistent with this exemption, including evasive and emergency maneuvers and maintaining appropriate distances from people, vessels, vehicles and structures.

Considering Media Stew LLC’s proposed area of operatio ns, and the operating limitations
set forth

- above ; the parallel nature of private pilot aeronautical knowledge requirements to those of commercial pilot requirements; and the airmanship skills necessary to safely operate the DJI Inspire I UAS, Media Stew, LLC submits that the additional manned airmanship experience of a commercially certified pilot would not correlate to the airmanship skills necessary for Media Stew, LLC’s specific proposed flight operations.

3. Reasons why an exemption from the requirement s of Section 91.7(a) would not adversely affect safety: The equivalent level of safety established by Section 91.7(a) will be maintained because prior to every flight, Media Stew, LLC will ensure that the DJI Inspire I UAS is in an airworthy conditions based upon the DJI Inspire I UAS’s compliance with its operating documents, and as stated in the conditions and limitations
herein.

4. Reasons why an exemption from the requirements of Section 91.121 would not adversely
af fect safety. The equivalent level of safety established by Section 91.121 will be
maintained because the altitude information of the DJI Inspire I UA will be provided to the PIC via GPS equipment and a radio communications telemetry data link, which downli nks from the UA to the GCS for active monitoring of the flight path. This altitude information, combined with Media Stew LLC’s operation of the DJI Inspire I UA within visual line of sight, at or below 400 feet AGL, will ensure a level of safety equivalent to Section 91.121.The altitude information will be generated by GPS equipment installed onboard the aircraft. Prior to each flight, a zero altitude initiation point will be established and confirmed for accuracy by the UAS PIC.

5. Reasons why an exemptio n from requirements of Section 91.151 (b) would not adversely affect safety: A grant of this exemption would ensure an equivalent level of safety established by 14 C.F.R. Section 91.151(b) as a result of (1) the technical specifications
of the DJI Inspire I UAS; (2) the limitations on the proposed flight operations; and (3) the location of the proposed flight operations. Accordingly, Media Stew, LLC will ensure that it can safely operate the battery powered DJI Inspire I UA during daylight house, in VFR
cond itions, for a total f light duration of no more than 1 0 minutes, resulting in a landing
with five minutes o f battery power remaining.

In the event that the UAS should run out of power, it would simply land within the access controlled operating area. Given its weight and construction material, the risks are less than contemplated by the current regulation. The DJI Inspire I provides a battery failsafe that commands the UA’s return to the launch point when critical minimum voltage is
reached. The UAS b atteri es provide approximately 1 5 minutes of powe red flight. Given the limitations on its proposed operations and the location of those proposed operations

, a reduced minimum power reserve for flight in daylight VFR conditions is reasonable

.

6. Reasons why an exem ption from the requirements of Sections 91.405 (a), 91.407 (a)(1), 91.409 (a)(1) & (a)(2), and 91.417 (a) & (b) would not adversely affect safety: In seeking this exemption, Media Stew LLC submits that the equivalent level of safety with regard to the regu latory maintenance and alteration requirements established by Sections 91.405 (a), 91.407 (a)(1), 91.409 (a)(1) & (a)(2), and 91.417 (a) & (b) will be met because Media Stew LLC will use trained technicians to perform maintenance, alterations, or preventi ve maintenance on the unmanned aircraft system. Furthermore, Media Stew, LLC will
document and maintain all maintenance records for the DJI Inspire I UAS.

Since the DJI Inspire I UAS will be inspected as prescribed by the manufacturer’s
maintenance manua l, Media Stew, LLC will maintain the equivalent level of safety established by Sections 91.405(a), 91.409(a)(1), and 91.409(a)(2). The flight manual for
the DJI Inspire I UAS sets forth airworthiness requirements for the UA, including preflight and post fl ight inspections, as well as scheduled maintenance in four categories: daily, weekly, monthly and yearly. Likewise, the exemption sought will not adversely affect safety because Media Stew, LLC will perform maintenance, alterations or preventive
maintenanc e on the UAS using the methods

, techniques, and practices prescribed by the manufacturer’s maintenance manual. The Flight manual for the DJI Inspire I UAS details procedures for each component of the UA, including the components of the propulsion system, avionics system and payload system.

In consideration of Media Stew, LLC’s proposed operating limitations , the most recentDJI Inspire I Manual, and the technical aspects of the DJI Inspire I UAS, Media Stew, LLC submits that safety will not be adversely a ffected by granting exemption from 14 C.F.R. Sections 91.405 (a), 91.407 (a)(1), 91.409 (a)(1) & (a)(2), and 91.417 (a) & (b). The FAA has previously granted relief specific to UAS in circumstances similar, in all material respects, to those presented here in.

7. The FAA May Prescribe Any other conditions for safe operation. In accordance with Section 333 of the FAA Modernization and Reform Act of 2012 (FMRA) and 14 C.F.R.
Section 21.16 entitled Special Conditions, Media Stew, LLC requests that the FAA prescri be special conditions for the intended operation of the DJI Inspire I UAS , which contain such safety standards that the Administrator finds necessary to establish a level of safety equivalent to that established by 14 CFR Part 21, Subpart H, and 14 CF R
Sec tions 61.113 (a) & (b), 91.7 (a), 91.121, 91.151(b), 91.405 (a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417 (a) & (b). Such special conditions will permit safe operation of the UA for the limited purpose of conducting aerial industrial footage acquisi tions over certain areas of the United States . FMRA Section 333 sets forth the requirements for considering whether a UAS will create a hazard to users of the NAS or the public, or otherwise pose a threat to national security; and further, provides the

aut hority for such UAS to operate without airworthiness certification in accordance with any requirements that must be established for the safe operation of the UAS in the NAS.

Likewise, the Administrator may prescribe special conditions pursuant to 14 CFR S ection 21.16, for operation of the DJI Inspire I UAS , since the airworthiness regulation s of 14
C FR Part 21 do not contain adequate or appropriate safety standards, due to the novel or unusual design features of the aircraft. Section 21.16, entitled Special Conditions, states the following: If the FAA finds that the airworthiness regulations of this subchapter do not contain adequate or appropriate safety standards for an aircraft, aircraft engine, or propeller because of a novel or unusual design fea ture of the aircraft, aircraft engine or propeller, he prescribes special conditions that amendments thereto for the product. The special conditions are issued in accordance with Part 11 of this chapter and contain such safety standards for the aircraft, a ircraft eng in e or propeller as the FAA finds necessary to establish a level of safety equivalent to that established in the regulations. See 14 C.F.R.
S ection 21.16.

Therefore, in accordance with FMRA Section 333 and 14 CFR Section 21.16, the FAA

may pres cribe special conditions for Media Stew, LLC intended operation of the DJI Inspire I UAS , which contain such safety standards that the Administr a tor finds necessary to establish a level of safety equivalent to that established by 14 C.F.R. Part 21, Subpart H, and 14 C.F.R. Sections 61.113(a) & (b), 91.7 (a), 91.121, 91.151 (b), 91.405 (a), 91.407(a)(1), 91.409 (a)(1) & (a)(2), and 91.417 (a) & (b).F.) A summary we can publish in the Federal stating

— The Rules from which Media Stew LLC seeks exemption: Media Stew, LLC seeks exemptio n from the requirements of 14 C FR Sections 61.113(a) & (b), 91.7 (a), 91.121, 91.151(b), 91.405 (a), 91.407(a)(1) , 91.409(a)(1) & (a)(2), and 91.417 (a) & (b).
A. Brief Description of the nature of the Exemption Media Stew, LLC s eeks: This exemption will permit Media Stew LLC to commercially operate an Unmanned Aircraft System ( UAS ) for the purpose of acquiring aerial industrial video footage , commercially, in support of small to medium sized business to be used in marketing materials over specific property in the United States.

G.) Any additional information, views, or arguments availa ble to support your request; This Petition is made pursuant to the FAA Modernization and Reform Act of 2012 (FMRA) Section 333, which directs the Secretary of Transportation to determine if certain UAS may operate safely in NAS. As such, Media Stew, LLC’s request for exemption may be granted pursuant to the authority of FMRA Section 333 and 14 C.F.R. Part 11, as set forth above.
FMRA Section 333 se ts forth the requirements for considering whether a UAS will create a hazard to users of the NAS or the public, or otherwise pose a threat to national security; and further, provides the authority for such UAS to operate without airworthiness certification . As discussed in detail above, Media Stew, LLC will operate the DJI Inspire I UAS safely in the NAS, without creating a hazard to users of the NAS, or the public, or otherwise pose a threat to national security.

As set forth herein, Media Stew, LLC seeks an exemption pursuant to 14 CFR Section 11.61 and Section 333 of the FAA Modernization and Reform Act of 2012 (FMRA), which will permit safe operation of the DJI Inspire I UAS commercially, without an airworthiness certificate , for the limited purpose of conducting aerial industrial footage acquisitions , commercially, in support of small to medium sized business to be used in marketing materials over specific property in the
United States . By granting this petition, the FAA Administrator will be fulfilling the congressional
mandate of the FAA Modernization and Reform Act of 2012, while also advancing the interests of the public, by allowing Media Stew, LLC to safely, efficiently, and economically operate the DJI Inspire I commercially within the NAS.

Where fore, in accordance with the Federal Aviation Regulations and the FAA Modernization and Reform Act of 2012, Section 333, Media Stew, LLC respectfully request that the Administrator grant this Petition for an exemptio n from the requirements of 14 C FR Sections 61.113(a) & (b), 91.7 (a), 91.121, 91.151(b), 91.405 (a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417 (a) & (b) and permit Media Stew, LLC to operate the DJI Inspire I UAS commercially for the purpose of conducting aerial industrial footage acquisitions , commercially, in support of small to medium sized business to be used in marketing materials over specific property in the United States

.

H.) If you want to exercise the privileges of your exemption outside the United States, you
must state the reason. N/A