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

Regulatory Docket No

.

_

IN THE MATTER OF THE PETITION FOR EXEMPTION OF:
CHAD BROWN
FOR AN EXEMPTION SEEKING RE LIEF FROM THE REQUIREME N TS OF
TITLE 14 OF THE CODE OF FEDERAL REGULATIONS SECTIONS 61.113(a) & (b), 91

. 7(a)

, 91.121

, 91.151(b)

, 91.405(a)

, 91.407(a)(l), 91.409(a)(l) & (a)(2), AND 91.417(a) & (b) CONCERNING COMMERCIAL
OPERATION OF DJI PHANTOM 2 VISION+ AND DJI INSPIRE 1 UNMANNED
AIRCRAFT SYSTEMS
PURSUANT TO SECTION 333 OF
THE FAA MODERNIZATION AND REFORM ACT OF 2012 (PUBLIC LAW 112-95)

Submitted on July 10, 2015

CHAD BROWN
2354 Fairview Lane Mound, MN 55364OAP Petition for Exemption Page 2 TABLE OF CONTENTS

Page

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

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

....... 4

INTRODUCTION AND INTERESTS OF PETITIONER. ............................................................. 4

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

.......... 4

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

NAME AND ADDRESS OF PETITIONER. ............................................................... 6

THE SPECIFIC SECTIONS OF 14 C.F.R. FROM WHICH CHAD BROWN
SEEKS EXEMPTION ................................................................................................... 6

THE EXTENT OF RELIEF CHAD BROWN SEEKS AND THE REASONS FOR
THAT RELIEF ............................................................................................................ 15

THE REASONS WHY GRANTING CHAD BROWN’S REQUEST WO UL D BE
IN THE PUBLIC INTEREST ................................................................................... 17

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

SUMMARY THAT CAN BE PUBLISH E D IN THE FEDERAL REGISTER ....... 30

ANY ADDITIONAL INFORMATION, VIEWS, OR ARGUMENTS
AVAILABLE TO SUPPORT CHAD BROWN’S QUEST .................................. 34

CONCL U SION ........................................................................................................................ 30

APPENDICES

.............................................................................................................................. . 31

### GLOSSARY OF ABBREVIATIONS

AGL

AOI

ATC

ATO

AV

CFR

COA

FAA



### FAR

GCS

GPS

LOL

NAS

NOTAM

PIC

Section 333



## so

SOP

UA

UAS

VFR

VLOS

VMC

VTOL Above Ground Level

Area of Interest

Air Traffic Control

Air Traffic Organization

Aerial Vehicle

Code of Federal Regulations

Certificate of Authorization

Federal Aviation Administration

Federal Aviation Regulation

Ground Control Station

Global Positioning System

Loss of Link

National Airspace System

Notice to Airman

Pilot In Command

FAA Modernization and Reform Act of 2012 (FMRA) Section 333

Safety Observer

Standard Operating Procedures

Unmanned Aircraft

Unmanned Aircraft System

Visual Flight Rules

Visual Line of Site

Visual Meteorological Conditions

Vertical Takeoff and Landing

CHAD BROWN Petition for Exemption 

### Page 34 CHAD BROWN Petition fo r Page 

### SUMMARY

CHAD BROWN doing business as CHAD BROWN ("CHAD BROWN") seeks exemption from the require ments of 14 C.F.R §§ 61.113(a) & 

### or alternatively an exemption from C.F.R §§ 61.113, 91.7(a), 91.121, 91.151(b), 91.405(a)

, 91.407(a)(l), 91.409(a)(l) & 

### (a)(2), and 91.417(a) & (b), 

### to operate an Unmanned Aircraft System pursuant to Section 333 of the FAA Moderniza tion and Reform Act of 2012 (FMRA). This exemption will permit CHAD BROWN to operate an Unmanned Aircraft System (UAS) for the commercial purpose of conducting aerial video and photography of construction sites, real estate, and landscape over certain areas of the United States.

INTRODUCTION AND INTERESTS OF THE PETITIONERs

Chad Brown has over 5 years recreational/hobby experience in all aspects of aerial flight and 2 years of aerial video and photography. The objective of CHAD
BROWN 's aerial video and photography operations is to provide high quality imaging for a variety of commercial, public, and residential uses, specifically targeting:

• Construction sites before and after

• Appraisals

• Real-estate marketing

• Motion Picture Filming

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

• Search and Rescue operations



## • Public events and news gathering 

### BACKGROUND

Unmanned Aircraft Systems: DJI Phantom 2 Vision+, DJI Inspire 1 UASs

CHAD BROWN seeks an exemption to operate DJI systems for compensation or
hire within the NAS. The DJI Phantom 2 Vision+ and DJI Inspire 1 are vertical takeoff and landing (VTOL) Unmanned Aircraft (UA) with a Gr ound Control Station (GCS) utilizing
electronic tablet or smart phone systems. The DJI Phantom 2 Vision+ has a maximum gross weight of approximately 2 pounds 11 ounces, while having a length of 16 inches width of 16 inches, height of 8 inches, and a maximum speed of approximately 29 knots. The DJI Inspire 1 has a maximum gross weight of 6 pounds 7.5 ounces, a length of 17.3 inches, width of 17.7 inches, height of 11.8 inches, and a maximum speed of approximately 42 knots. The DJI Phantom 2 Vision+ and DJI Inspire 1UAs are equipped with four main rotors; driven by Lithium Polymer battery powered electric motors.

The DJI Phantom 2 Vision+ and DJI Inspire 1 UAs that will be operated by
CHAD BROWN will be registered in accordance with 49 U.S.C. 44103, Registration of Aircraft, 

### as well as 14 C.F.R Part 47, Aircraft Registration, 

### and marked in accordance with 14 C.F.R. Part 45, Identification and Registration Marking.5 CHAD BROWN Petition fo r Page BASIS FOR PETITION



### Petitioner, CHAD BROWN , pursuant to the provision s of the Federal Aviation Regulations (14 C.F.R. § 11.61) and the FAA Modernization and Reform Act of 2012 (FMRA), Section 333, Special Rulesfor Certain Unmanned Aircraft Systems, 

### hereby petitions the Administrator to commercially operate the DJI Phantom 2 Vi sion+, DJI Inspire 1 UASs in the National Airspace System (NAS), and for an exemption from the requirements of 14 C.F.R §§ 61.113(a) & 

### (b), 91.7(a), 91.121, 91.15l(b), 91.405(a) , 91.407(a)(l ), 91.409(a)(l) & 

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

### (b).

In consideration of the speed, weight, size, and limited operating area associated with the unmanned aircraft and its operation, CHAD BROWN ’s operation of DJI Phantom 2
Vision+ and DJI Inspire 1 UASs meets the conditions of FMRA Section 333 and therefore, will not require an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H.

Accordingly, CHAD BROWN requests re li e f from Sections 91.405(a), 91.407(a)(l ), 91.409(a)(l) & 

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

### (b), as these sections set forth requirements for maintenance that only apply to aircraft with an airworthiness certificate.

CHAD BROWN submits that the requested relie f is proper since an equivalent level of safety will be ensured. CHAD BROWN will use experienced personnel or technicians to perform maintenance, alterations, or preventive maintenance on the UASs using the methods, techniques, and practices prescribed in the operating documents (i.e., Monthly Maintenance Log, and DJI Phantom 2 Vision+ and DJI Inspire 1 Instruction Manual). Furthermore, CHAD BROWN will document and maintain all maintenance records for the DJI Phantom 2 Vision+ and DJI Inspire 1 UASs.

Relief from certain requirements of Section 61.113(a) and (b), entitled Private pilot privileges and limitations: Pilot in command, 

### is requested by CHAD BROWN to the extent necessary to allow a Pilot in Command (PIC) is able to safely operate the DJI
Phantom 2 Vision+ and DJI Inspire 1 UASs in a manner consistent with this exemption, including evasive and emergency maneuvers and maintaining appropriate distances from people, vessels, vehicles and structures. Alternatively, CHAD BROWN request that the requirement of private pilot licensing for commercial UA use required of previous exemptions be lifted in this particular request pursuant to CHAD BROWN’S argument herein.

CHAD BROWN seeks relief from Section 91.7(a), entitled Civil aircraft airworthiness, 

### because the DJI Phantom 2 Vision+ and DJI Inspire 1 UASs do not require an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H. As such, CHAD BROWN submits that he will ensure that the DJ I Phantom 2 Vision+ and DJI Inspire 1UASs are in an airworthy condition, prior to ever y flight, by determining that the UASs are in compliance with the operating documents (i.e., Monthly6 CHAD BROWN Petition fo r Page 

### Maintenance Log, and DJI Phantom 2 Vision+ and DJI Inspire 1 Instruction Manual), and that the aircraft are in a condition for safe flight.

CHAD BROWN also seeks an exemption from the requirements of Section 91.121, entitled Altimeter Settings, as the DJI Phantom 2 Vision+ and DJI Inspire 1 UAs
will not have a typical barometric altimeter onboard. However

, altitude information of the
DJI Phantom 2 Vision+ and DJI Inspire 1 UAs will be provided to the PIC via Global Positioning System (GPS) equipment and radio communications telemetry data link

, which
downlinks from the UA to the GCS for active monitoring of the flight path. This altitude information, combined with CHAD BROWN’S operation of the DJI Phantom 2 Vision+ and DJI Inspire 1 UASs within visual line of sight, at or below 400 feet AGL, will ensure

a level of safety equivalent to Section 91.121. Additionally, CHAD BROWN seeks an exemption from the requirements of Section 91.15l(b)

, entitled Fuel requirements for flight in VFR conditions. CHAD
BROWN submits that safety will not be affected b y operation of the DJI Phantom 2
Vision+ and DJI Inspire 1 UAs during daylight hours in visual meteorological conditions (VMC) under visual flight rules (VFR), with enough battery power to fly for a total
duration of approximately 13.5 minutes to the first point of intended landing and, assuming normal cruising speed, to fly after that for at least
4.5 minutes

.

In accordance with 14 C

. F

.

R. 

### § 11.81, CHAD BROWN provides the following
information in support of his petition for exemption:



### A. NAME AND ADDRESS OF THE PETITIONER.

The name and add ress of the Petitioners and point of contact are: CHAD BROWN
2354 Fairview Lane Mound, MN 55364
Email: cb4email@yahoo.com



### B. THE SPECIFIC SECTIONS OF 14 C .F. R. FROM WHICH CHAD BROWN SEEKS EXEMPTION.

1. CHAD BROWN SEEKS EXEMPTION FROM THE REQUIREMENTS OF SECTION 61.113.

CHAD BROWN’S ARGUMENT FOR EXEMPTION FROM 14 C.F.R. §61.113: PRIVATE PILOT PRIVILEGES AND LIMITATIONS: PIC.

CHAD BROWN requests an exemption from 14 C.F.R. §61.113 so that the PIC of
the UA will not b e required to possess a private or commercial pilot's licen se. As the FAA
and numerous other national airspace regulators have recogni zed, UA operations conducted by persons who do not hold a pilot's license can still achieve the equivalent level of safety of current operations by manned aircraft w ith pilots holding a private or commercial pilot's license

.7 CHAD BROWN Petition fo r Page Although it recogni zes that a pilot's licens e is unnecessary for safe UA operation

, the
FAA has to date declined to allow grant exemptions under Section 333 that would permit individuals who possess neither a pr ivate nor a commercial pilot's cert i ficate to conduct
commercial UA operations. It has specified two r easons for declining to do so. First

, it
has stated that it does not possess the aut hority under Section 333 to exempt individuals from the requirement under 49 U.S.C. §44711 to hold an airman certificate authorizing the airman to serve in the capacity for which the certificate was issued. Exemption No

. 11110 at 14. Second, the FAA has concluded that the Department of Homeland Security (DRS) security screening required of all certified airmen meets the statutory requirement in Section 333 that operations not pose a threat to national security. Exemption No. 11110 at 15

.

CHAD BROWN respectfully requests that the F AA reconsider its position. There
is no dispute that it is unnecessary for an operator of a UA to go through the rigorous process

of becoming a certified pilot in order to sa fely operate a UA. In addition

, the FAA does have the authority to exempt UA operators from the requirement in 49 U.S

. C

. §4471l to
hold an airman certificate for " serv[ing] in the capacity for which the certificate was
issued. " Indeed

, it has exercised that authority repeatedly in the Section 

### 333 process. Finall y, the FAA ' s security concerns can be addressed by a variety of methods involving operator backgr ound checks to be conducted by government agenci es.



### 2. THE FAA AND FOREIGN REGULATORS RECOGNIZE THAT
OBTAINING A MANNED AIRCRAFT PILOT LICENSE IS
UNNECESSARY FOR SAFE OPERATION OF A UA

The FAA, like th e other national airspace regulators that have considered the issue,

has concluded that UA operations co nducted by persons who do not hold a pilot ' s license

can still achieve the equivalent level of safety of current operations by manned aircraft with pilots holding a private or commercial pilot ' s license

. In its recent UAS NPRM

, the FAA
stated :

"While these airman certification requirements are necessary 

### for manned aircraft operations, they impose an unnecessary burden 

### for many small UAS operations. This is because a person typically obtains a private or commercial pilot certificate by learning how to operate a manned aircraft. Much of that knowledge would not be applicable to small UAS operations because a small

UAS is operated differently than manned aircraft. n addition

, the knowledge currently necessary to obtain a private or commercial pilot certificate would not equip the certificate holder with the tools necessary to safely operate a
small UAS... Thus

, requiring persons wishing to operate a small UAS to obtain a private or commercial pil o t certificate imposes the cost of certification on those persons

, but does not result in a significant safety benefit because the process of obtaining the certificate does not equip those persons with the tools necessary to m itigate the public risk posed by small UAS operations. " Operation and Certification of Small Unmanned Aircraft

, 80 Fed. Reg. 9543 at 9550 (proposed Feb

. 23, 2015 (to be codified at 14

C.F.R

. Parts 21

, 43

, 45

, et al .) ).8 CHAD BROWN Petition fo r Page The FAA's conclusion that manned aircraft flying experience i s unnecessary for the operation of a UA is supported by research by the FAA and the Army Research Laboratory

. They demonstrate that UAs

, even those much larger than the sUAS proposed by CHAD
BROWN

, can be safely flown by non-certificated pilots with a small amount of training. For example, one Arm y Research Laboratory study concluded:

"[T]he specific motor skills needed to control the radio-controlled UAV would have to be learned by aviators independently of the motor skills learned in flying an aircraft. In particular, the somatic and visual cues that pilots use during aircraft landings would not be useful (and perhaps even counter-productive) for the different skill sets and perceptual viewpoint necessary for radio-controlled landings." 1

Additional research reports lend further support for the exclusion requested. For example, a report sponsored by the FAA concluded that "We know that certain systems, like
the U

. S

. Army Hunter and Shadow systems

, are successfully flown by pilots with no manned aircraft experience.” 2

In addition, foreign government airspace regulators that have examined the issue have consistently recognized that the skills requi red to fly a manned aircraft are irrelevant to operating a UA. For that reason

, they have concluded that UA operators do not need to have

a private or commercial pilot's license. Canada, for example, does not require a pilot's

license to operate a UA. Transport Canada requires training of UA operators, but that training

is limited to pilot ground school and flight operation training on UAs, not manned aircraft. 3

Moreover, Canada allows this training to be "provided by other pilots

, manufacturers

, [UA] flight training organizations or

.. . self-taught." 4

1 Michael J

. Barnes, Beverly G

. Knapp

, Barry W

. Tillman, Brett A. Walters & Darlene

Veliki

, 

### Crew systems analysis of unmanned aerial vehicle (UA V) 

### future job and tasldng environments, Technical Report ARL-TR-2081, Aberdeen Proving Ground

, MD: Army Research Laboratory, page 12 (2000), 

### available at http: // www

. dtic

. mil/dtic / tr / fulltext/u2 / a374230.pdf.

2 Kevin W. Williams, 

### Unmanned Aircraft Pilot Medical Certification Requirem e nts, Report DOT/FAA/AM-07/3, FAA Civil Aerospac e Medical Institute, page 2, (2007)

, 

### available at http: // fas.org/iro/program / collect / ua-pilot.pd f. While the authors speculated that UAS use in populated areas may change this assessment, indicating further research was needed to
address this concern, this concern is inapplicable as Helios ' s flights will not be in congested

areas. 

### See also Jason S

. McCarley & Christopher D. Wickens, 

### Human Factors Implications of UAVs in th e National Airspac e, Institute of Aviation, Aviation Human Factors Division

, University of Illinois at Urbana-Champaign, 13 (2004)

, 

### available at http :// www

. tc.faa.gov/logistic s / grants / pdf / 2004 / 04-G-032.pdf

3 

### See Civil Aviation, Standards

, Transport Canada, Advisory Circular: Guidance Material

for Operating Unmanned Air Vehicle Systems under an Exemption at 14 and 18-22, (Nov. 27, 2014) 

### available at http: // www.tc.gc.ca/media/documents / ca-opssvs / ac-600-004.pdf.

4 

### Id

. at 14

.CHAD BROWN Petition for Exemption Page 9 Similarly, the United Kingdom's C iv il Aviation Authority (CAA) recognized that determining "Remote Pilot qualification requirements on the same basis as manned aircraft may yield requirements that are too inflexible, too onerous and inappropriate for UAS operations." 5 As a result, the CAA only requires UA operators to demonstrate UA operator
competence. 6 While there are a variety of ways to demonstrate competence, the most common is to complete a course that will lead to a ground exam and flight test. Australia, too, requires only passage of a UA-specific ground school program in lieu of a private pilot

license. 7 Finally, more than a dozen countries, including Germany, Italy, France, Spain and the Netherlands, have adopted the National UAS Certificate for Small Unmanned Aircraft (BNUCMS) Standard for UA pilot certification. 7 This standard results in a type-specific UA certificate and does not require the operator to have a pilot's license. The process involves taking a short ground school course, passing a ground school test and then passing a practical test on commercial operation of the specific UAS per the UAS manufacturer's operations
manual.

All of this experience and evidence indi cates that the proposed exemption will provide a greater level of safety than operations under 14 C.F.R. §61.113. In this instance, the PIC has years of UA experience. He has focused his training and education on UAs generally, and in particular on the aircraft to be operated, rather than taking on the cost, additional time and risk to train on a manned aircraft, weighing several thousand pounds and carrying highly flammable fuel.

The FAA has concluded in th e NPRM that such DA-specif ic training is more than sufficient to provide an equivalent level of safety for UA operations. Sometime in the next 18 to 24 months, that position will be ensh rined in a valid regulation. However, in the meantime, the FAA claims it lacks the authority to relax the requirement to possess a pilot certificate. As described infra, that position is both incorrect and contradicted by the FAA's
recent decisions.

3.THE FAA HAS ALREADY EXERCISED THE AUTHORITY TO
EXEMPT APPLICANTS FROM THE AIRMAN CERTIFICATE REQUIREMENT

5 Civil Aviation Authority, Safety Regulation Group, Unmanned Aircraft System Operations in UK Airspace
- Guidance, Section 2, Chapter 5, Page 2 (Aug. 10, 2012), available at https: // www.caa.eo.uk/docs/33/CAP722. pdf.

6 Civil Aviation Authority, Unmanned Aircraft and Aircraft Systems,
available at http: // www.caa.co.uk/default.aspx?catid= 1995&pagetype=90

7 Australian Government Civil Aviation Safety Authority, available at http: / /www.casa.gov.au/scripts / nc.dll?WCMS: STAND ARD: :pc=PC 1003
74.

7 See EuroUSC Interna tional, "Pilot Qu alification, “available at http://eurousc.com/services/pilot-qualifications/.CHAD BROWN Petition fo r Exemption Page 10 The FAA claims that it lacks authority to exempt UA operators from the requirement
of 49 U.S. §44711 to hold an airman certificate authorizing the airman " to serve in the capacity for which the certificate was issued." See, e.g., Exemption No. 11110 at 14. This
claim is inconsistent with both (i) the statutory language of that section and Section 333, and (ii) numerous recent FAA decisions.

The operative part of 49 USC §44711 provides that a "person may not

. . . serve in

any capacity as an airman with respect to a civil aircraft, . . . used, or intended for use, in air

commerce - (A) without an airman certificate authorizing the airman to serve in the capacity for which the certificate was issued

. . . " 

### If the FAA' s interpretation were

correct

, this language would require that any person wishing to operate a UA for
commercial operations have an airman certificate authorizing the person to serve as an airman in commercial operations.

However, in all of its recent grants of Section 333 petitions, the FAA has -without explicitly acknowledging the fact - exempted commercial UA operators from the §4471 l(A) requirement that they hold an airman certificate authorizing them "to serve in the capacity
for which the certificate was issued." It has done so by allowing them to operate a UA so long as they hold a private pilot’s or sport pilot's authorization, even though such a certificate
does not permit commercial operations. Exemption No. 11062 at 15-18; Exemption No. 11110 at 14-16; Exemption No. 11191 at 3-5; and Exemption No

. 11229 at 3 and 8.

The FAA argues that it cannot exempt applicants from the requirements of §44711 because, while the specific language of Section 333 grants it limited statutory flexibility
relative to 49 U.S.C. §44704 for the purposes of airworthiness certification, Section 333 does

not provide flexibility relative to §44711 and other sections of Title 49. Exemption No.
11110 at 14. This argument ignores the plain language of the statute

. The relevant language of
Section 333 is:

(a) IN GENERAL-Notwithstanding any other requirement 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,
at 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; andCHAD BROWN Petition for Exemption Page 1 1 (2) whether a certificate of waiver, certificate of authorization, or
airworthiness certification under section 44704 of title 49

, United States Code, is required for the operation of unmanned aircraft systems 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.

The language of Section 333(b) is permissive: it requires that the Secretary "determine, at a minimum

. . . whether a certificate of waiver, certificate of authorization, or airworthiness certification under section 44704 of title 49, United States Code, is required for the operation of unmanned aircraft systems identified under paragraph (1)." Nothing in (b) precludes the Secretary from determining whether or not a pilot's license is required for operation of a UA identified under paragraph (b )(1).

Indeed, the FAA has implicitly conceded the point by granting exemptions from the requirement that commercial UA operators hold a commercial pilot certificate. From an analytical standpoint, there is no difference between granting an exemption from the
commercial pilot's license requirement and granting an exemption from the private or sport pilot's license requirement. Both are clearly exemptions from a specific statutory requirement in 49 U.S.C. §44711. If the FAA has the statutory authority under Section 333(b) to do the former

, it has the same authority to do the latter. 8

For the reasons set forth above, the FAA should reconsider its position and exercise its full authority to grant an exemption from all the requirements of 49 

## use §44711, so that
CHAD BROWN serving as a commercial UA operator need not have a

pilot's license

. Alternatively:



### 1. CHAD BROWN SEEKS EXEMPTIO N FROM THE REQUIREMENTS OF SECTION 61.113(a) and (b).

Section 61.113, entitled Private pilot privileges and limitations: 

### Pilot in command,
subsections (a) and (b) prescribe the following, in relevant part:

8 The FAA has not specifically identified the statutory provision that underpins its authority

to grant the exemptions from the commercial pilot's license requirement. Whether the
statutory basis is Section 333 or some other provision makes no difference

. Ifthere is a basis for a partial exemption from in 49 U.S.C. § 44711, that basis also justifies an exemption
from the entire provision.CHAD BROWN Petition for Exemption Page 

### 1 2 (a) No person who holds a private pilot certificate may act as a pilot in command (PIC) of an aircraft that is carrying passengers or property for compensation or hire; nor may that person, for compensation or hire, act as PIC of an aircraft.

(b) A private pilot may

, for compensation or hire

, act as PIC of an aircraft in
connection with any business or employment if-

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



### 2. CHAD BROWN SEEKS EXEMPTION FROM THE REQUIREMENT
OF SECTION 91.7(a).

Section 91.7, entitled 

### Civil aircraft airworthiness, subsection (a), states the following: (a) No person may operate a civil aircraft unless it is in an airworthy condition

.



### 3. CHAD BROWN SEEKS EXEMPTION FROM THE REQUIREMENTS
OF SECTION 91.121.

Section 91.121, entitled A ltimeter settings

, subsection (a), states the following, in
part: (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 reported altimeter setting of a station along the route and
within 100 nautical miles of the aircraft;

(ii) If there is no station within the area prescribed in paragraph (a)(l)(i) of
this section, the current reported altimeter setting of an appropriate available station; or

(iii) In the case of an aircraft not equipped with a radio, the elevation of the departure airport or an appropriate altimeter setting available before departure

.



### 4. CHAD BROWN SEEKS EXEMPTION FROM THE REQUIREMENTS
OF SECTION 91.lSl(b).

Section 91.151, entitled 

### Fuel requirements for flight in VFR conditions, subsection

(b ), states the following :

### P age CHAD BROWN Petition fo r Exemption 13 (b) No person may begin a flight in a rotorcraft under VFR conditions unless (considering wind and for ecast weather conditions) there is enough fuel to fly to the first point of intended landing an d, assuming normal cruising speed, to fly after that for at least 20 minutes.

5. CHAD BROWN SEEKS EXEMPTION FROM THE REQUIREMENT OF SECTION 91.405(a).

Section 91.405, entitled Maintenance required, subsection (a), states the following: Each owner or operator of an aircraft- (a) Shall have that aircraft inspected as prescribed in subpart E of this part and shall between required inspections, except as prov ided in paragraph (c) of this section, have discrepancies repaired as prescribed in part 43 of this chapter[.]

6. CHAD BROWN SEEKS EXEMPTION FROM THE REQUIREMENTS OF SECTION 91.407(a)(l)

Section 91.407, entitled Operation after maintenance, preventive maintenance, rebuilding, or alteration, subsection (a)(l), states the following: (a) No person may operate any aircraft that has undergone maintenance, preventive maintenance, rebuilding, or alteration unless--

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

7. CHAD BROWN SEEKS EXEMPTION FROM THE REQUIREMENTS
OF SECTIONS 91.409(a)(l) and 91.409(a)(2).

Section 91.409, entitled Inspections, subsection (a), states the following:

(a) Except as provided in paragraph (c) of this section, no pe rson 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 § 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. CHAD BROWN SEEKS EXEMPTION FROM THE REQUIREMENTS
OF SECTIONS 91.417(a) and 91.417(b).

Section 91.417, entitled Maintenance records, subsections (a) and (b), state the following:

### P ag e 

### 14 CHAD BROWN Petition for E x emption (a) Except for work performed in accordance with §§ 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 maintenance, 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 aircraft. 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 certificat e number of the person approving the aircraft
for return to service.

(2) Records containing the following information: (i) The total time in service of the airframe, each engine, each propeller, and
each rotor.

(ii) The current status of life-limited parts of each airframe, engine, propeller, rotor

, and appliance.

(iii) The time since last 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
directives including, for each, the method of compliance, the AD or safety
directive number and revision date

. 

### If the AD or safety directive involves recurring action, the time and date when the next action is required.

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

, propellers, and appliances.

(b) The owner or operator shall retain the following records for the periods prescribed:CHAD BROWN Petition for Exemption Page 

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

(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 § 43.11 of this chapter shall be retained until the defects are repaired and the aircraft is approved for return to service

.



### C. THE EXTENT OF RELIEF CHAD BROWN SEEKS AND THE REASON
CHAD BROWN SEEKS THE RELIEF

1. EXTENT OF RELIEF CHAD BROWN SEEKS AND THE
REASON CHAD BROWN SEEKS RELIEF FROM SECTION 61.113(a) and (b).

Relief from Section 61.113(a) and (b) entitled 

### Private pilot privileges and
limitations: Pilot in command, is requested to the extent necessary to allow a PIC holding a FAA airman certificate or in the alternative an unmanned aircraft operator certificate with a small UAS rating (like existing pilot airman certificates) as well as a current and valid airman medical certificate, and who has met certain flight-hour and currency requirements, to conduct the proposed UAS flight operations for compensation or hire

.

This relief is requested since the limitations set forth in Section 61.113(a) and (b) state that a private pilot may, for compensation or hire, act as PIC of an aircraft in connection with any business or employment if: (1) The flight is only incide ntal to th at business or employment; and (2) The aircraft does not carry passengers or property for compensation or
hire.

As set forth more fully below

, CHAD BROWN submits that an equivalent level of safety will be maintained because no PIC will be allowed to operate the DJI Phantom 2
Vision+ UAS or DJI Inspire 1 UAS unless that PIC has met certain flight-hour and currency requirements

, demonstrating that the PIC is able to safely operate either the DJI
Phantom 2 Vision+ or DJI Inspire 1 UAS in a manner consistent with the operations specifications as described in this exemption, including evasive and emergency maneuvers,
as well as maintaining appropriate distances from people

, vessels, vehicles and structures.

Further

, CHAD BROWN submits that all flights of the DJI Phantom 2 Vision+ and DH Inspire 1 UASs, conducted by the PIC pursuant to the grant of this Petition: (1) will be
incidental to CHAD BROWN’S business; and (2) will not carry passengers or property for compensation or hire.



### 2. EXTENT OF RELIEF CHAD BROWN SEEKS AND THE
REASON CHAD BROWN SEEKS RELIEF FROM SECTION 91.7(a).CHAD BROWN Petition fo r Exemption Page 24 Relief from Section 91.7(a) entitled Civil aircraft airworthiness, is requested to the extent required to allow CHAD BROWN to determine that the DJI Phantom 2 Vision+
and DJI Inspire 1 UASs ar e in airworthy condition prior to every flight by ensuring
that the UAS is in compliance with the operating documents (i.e

. the CHAD BROWN Aerial Operations Manual, Monthly Maintenance Log, and DJI Phantom 2 Vision+ and DJI Inspire 1 Instruction Manual).

CHAD BROWN seeks the requested relief because the DJI Phantom 2 Vision+ and DJI Inspire 1 UASs do not require an airworthiness certificate in accordance with 14
C .F. R. Part 21, Subpart H

. Therefore, CHAD BROWN will ensure that the DJI Phantom
2 Vision+ and DJI Inspire 1 UASs are in airworthy condition based upon its compliance
with the operating documents (i.e., Monthly Maintenance Log, and DJI Phantom 2 Vision+ and DJI Inspire 1 Instruction Manual) prior to every flight, and further

, determine that the
aircraft are in condition for safe flight, as stated in the conditions and limitations below.



### 3. EXTENT OF RELIEF CHAD BROWN SEEKS AND THE
REASON CHAD BROWN SEEKS RELIEF FROM SECTION
91.121.

Relief from Section 91.121, entitled Altimeter settings

, may be required to allow flight operations of the DJI Phantom 2 Vision+ and DJI Inspire I UASs, which utilize a barometric pressure sensor, GPS equipment, and a radio communications telemetry data
link to downlink altitude information from the UA to the PIC at the ground control station (GCS). Since the FAA requires that any altitude information concerning UAS operations be reported to air traffic control (ATC) in feet above ground level (AGL), CHAD BROWN seeks the requested relief because the DJI Phantom 2 Vision+ and DJI Inspire 1 UA's altimeter may be set on the ground to zero feet AGL, rather than the local barometric pressure or field altitude, before each flight.

Considering the limited altitude of the proposed operations

, relief from 14 CFR
91.121 is sought to the extent necessary to comply with the applicable conditions and
limitations stated below

. As more fully set forth herein, an equivalent level of safety will be
maintained since the DJI Phantom 2 Vision+ and DJI Inspire I UAs are equipped with a barometric pressure sensor and GPS equipment

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



### 4. EXTENT OF RELIEF CHAD BROWN SEEKS AND THE
REASON CHAD BROWN SEEKS RELIEF FROM SECTION 91.lSl(b).

Relief from Section 91.l Sl(b) entitled Fuel requirements for flight in VFR conditions, is requested to the extent required to allow flights of the battery powered DJI
Phantom 2 Vision+ and DJI Inspire 1 UAs during daylight hours in visual meteorological
conditions (VMC), under visual flight rules (VFR), for a total duration of 13.5 minutes to the first point of intended landing and

, assuming normal cruising speed, to fly after that for

at least 4.5 minutes

. CHAD BROWN seeks the requested relief because without an exemption from Section 91.151(b), the flight time duration of the battery powered DJI
Phantom 2 Vision+ and DJI Inspire 1 UAs will severely constrain the practicality of any

### P age 23 CHAD BROWN Petition fo r Exemption aerial video or still photo flight operations that CHAD BROWN proposes to c onduct pursuant to this Petition.

Significantly, as set forth below, the technical specifications of the DJI Phantom 2
Vision+ and DJI Inspire 1 UASs, the DJI Phantom 2 Vision+ and DJI Inspire 1 operating documents, and CHAD BROWN’S proposed operating limitations, ensure that CHAD
BROWN will safely operate the battery powered DJI Phanto m 2 Vision+ and DJI Inspire 1 UAs during daylight hours in visual meteorological conditions (VMC)

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



### 5. EXTENT OF RELIEF CHAD BROWN SEEKS AND THE
REASON CHAD BROWN SEEKS RELIEF FROM SECTIONS 91.405(a), 91.407(a)(l), 91.409(a)(l) & 

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

### (b).

Since Sections 91.405(a), 91.407(a)(l), 91.409(a)(l ) & (a)(2), and 91.417(a) & (b) only apply to aircraft with an airworthiness certificate, CHAD BROWN requests relief from
these Sections because the DJI Phantom 2 Vision+ and DJI Inspire 1 UASs do not require
airworthiness certificates. As set forth more fully below, the DJI Phantom 2 Vision+ and DJI Inspire 1 UASs meet the conditions of FMRA Section 333 for operation without an airworthiness certificate

. Accordingly, CHAD BROWN will use trained technicians to perform maintenance, alterations, or preventive maintenance on the UASs using the methods, techniques, and practices prescribed in the UAS operating documents (i.e.,
the CHAD BROWN Aerial Operations Manual, Monthly Maintenance Log, and DJI Phantom 2 Vision+ and DJI Inspire 1 Instruction Manual). Furthermore, CHAD
BROWN will document and maintain all maintenance records for the DJI Phantom 2
Vision+ and DJI Inspire 1 UASs.



### D. REASONS WHY GRANTING CHAD BROWN’S REQUEST WOULD BE
IN THE PUBLIC INTEREST.

Granting the present Petition will further the public interest by allowing CHAD
BROWN to safely, efficiently

, and economically perform aerial video and photography of
construction sites, real estate, and landscape over certain areas of the United States.

Additionally, use of the DJI Phantom 2 Vision+ and DJI Inspire 1 UASs will
decrease congestion of the NAS, reduce pollution, and provide significant benefits to the

economy

. Notably, the benefits of CHAD BROWN’S proposed operation of the DJI
Phantom 2 Vision+ and DJI Inspire 1 UASs will be realized without implicating any privacy issues.



### 1. THE PUBLIC WILL BENEFIT FROM DECREASED CONGESTION
OF THE NAS

.

The DJI Phantom 2 Vision+ and DJI Inspire 1 UAs are battery powered and serve as a safe, efficient, and economical alternative to the manned aircraft traditionally utilized to
obtain aerial imagery. By reducing the amount of manned aircraft needed to perform aerial acquisitions, an exemption allowing the use of a DJI Phantom 2 Vision+ or DJI Inspire 1CHAD BROWN Petition fo r Exemption Page 24 UAS would reduce the amount of manned aircraft in the NAS, reduce noise and air pollution,

as well as increase the safety of life and property in the air and on the ground.

Furthermore, by reducing the number of manned aircraft operating in the NAS, congestion around airports caused by arriving and departing aircraft will be reduced. The DJI Phantom 2 Vision+ and DJI Inspire 1 UAs do not require an airport to takeoff or land.
Likewise

, a reduction of manned aircraft conducting aerial video and photography missions would result in fewer aircraft that must be handled by air traffic control during the ground

, takeoff

, departure, arrival, and landing phases of flight operations.

2. THE PUBLIC WILL BENEFIT FROM THE SAFETY AND
EFFICIENCY OF THE DJI PHANTOM 2 VISION+ AND DJI
INSPIRE 1UASS.

Conducting aerial acquisitions with the DJI Phantom 2 Vision+ and DJI Inspire 1 UASs, instead of manned aircraft, will greatly benefit the public by drastically reducing the levels of air and noise pollution generated during traditional aerial video and still photography flight operations

. By using battery power and electric motors, the DJI Phantom
2 Vision + and DJI Inspire 1 UASs produce no air pollution, and is the most viable environmentally conscious alternative to the cabin class, six cylinder internal combustion engine aircraft that are typically utilized for aerial video and photography, while burning approximately 20-30 gallons per hour of leaded aviation fuel. The DJI Phantom 2 Vision+ and DJI Inspire 1 UAs, while reducing the carbon footprint of aerial acquisitions, also eliminates noise pollution, as the UAs are propelled by battery powered electric motors, rather than an internal combustion engine.

By using the DJI Phantom 2 Vision+ and DJI Inspire 1 UASs to perform aerial 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
reduced or completely eliminated. Aside from the lack of flight crew members located onboard the aircraft, the DJI Phantom 2 Vision+ and DJI Inspire 1 UAs (weighing approximately 2 pounds 11 ounces and 6 pounds 7.5 ounces respectively, at their maximum gross weights with lengths of 16 inches and 17.3 inches respectively, widths of 16 inches and 17.7 inches respectively

, and with no fuel on board), has less physical potential for collateral damage to life and property on the ground

, and in the air, compared to the manned aircraft that typically conduct similar operations (weighing approximately 6,000 pounds with a wingspan of approximately 42 feet, a length of 34 feet, and a fuel capacity of 180 gallons).

3. PERFORMING AERIAL VIDEO AND PHOTOGRAPHY
OPERATIONS WITH THE DJI PHANTOM 2 VISION+ AND DJI
INSPIRE 1 UASS WILL BENEFIT THE ECONOMY.

In addition to being safe and efficient, the DJI Phantom 2 Vision + and DJI Inspire 1
UASs are also an economical alternative to using manned aircraft to conduct similar aerial operations. As such, operation of the DJI Phantom 2 Vision+ and OJI Inspire 1 UASs will allow United States based companies

, like OAP

, to remain competitive and contribute to growth of the U.S

. economy. Specifically

, with the rising cost of aviation fuel and the

### P age 23 CHAD BROWN Petition fo r Exemption Environmental Protection Agency ("EPA") regulatory actions pha s ing out leaded aviation fuels, U.S. owned and operated companies must adopt new and alt e rnative technology in order to remain competitive. Operating the battery powered DJI Phantom 2 Vision+ and

DJI Inspire I UASs is one such technology th at not only allows companies greater operational flexibility compared to manned aircraft, but provides such flexibility without the high operational cost of a traditional manned aircraft. By operating the DJI Phantom 2 Vision+ and DJI Inspire 1 UASs, companies such

as CHAD BROWN , can remain competitive and profitable, and therefore, provide greater job stability to employees and contractors, which will ultimately contribute to growth of

the U

. S. economy. Improved financial performance of U.S

. companies, through

commercial use of the DJI Phantom 2 Vision+ and DJI Inspire I UASs, provides a

stable workforce that increases consumer spending; improves local, state, and federal tax revenues; and allows companies to invest in research and development in order to remain competitive both in the United States and abroad.



### 4. THERE ARE NO PRIVACY ISSUES.

Similar to the manned aerial acquisition flight operations that have been conducted for decades, CHAD BROWN’S proposed operation of the DJI Phantom 2 Vision+ and DJI Inspire 1 UASs will not implicate any privacy issues. Specifically, the DJI Phantom 2 Vision+ and DJI Inspire 1 UASs will be operated only in compliance with operating documents (i.e., the CHAD BROWN Aerial Operations Manua l, Monthly Maintenance Log, and DJI Phantom 2 Vision+ and DJI Inspire 1 Instruction Manual) which requires property owner involvement as well as local law enforcement notification, and in
accordance with the Federal Aviation Regulations, including the minimum altitude requirements of 14 C.F.R. § 91.119.



### E. REASONS WHY GRANTING THE EXEMPTION WOULD NOT
ADVERSELY AFFECT SAFETY, OR HOW THE EXEMPTION WOULD
PROVIDE A LEVEL OF SAFETY AT LEAST EQUAL TO THAT
PROVIDED BY THE RULE FROM WIDCH CHAD BROWN SEEKS
EXEMPTION.

1. REASONS WHY THE DJI PHANTOM 2 VISION+ AND DJI
INSPIRE 1 UAS MEET THE CONDITIONS OF THE FAA
MODERNIZATION AND REFORM ACT OF 2012 (FMRA)
SECTION 333.

In consideration of the size, weight, speed, and limite d operating area associated with

the unmanned aircraft and its operation, CHAD BROWN’S operation of the DJI Phantom

2 Vision+ and DJI Inspire 1 UASs meet the conditions of FMRA Section 333, and will not require an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H.

Section 333 provides authority for a UAS to operate without airworthiness
certification and sets forth requirements for considering whether a UAS will create a hazard to users of the NAS or the public, or otherwise pose a th reat to national security. Specifically,

FMRA Section 333 states the following, in part:



### (a) In General.

-- Notwithstanding any other requirement of this subtitle

, and not laterCHAD BROWN Petition fo r Exemption Page 24 

### than 180 days after the date of enactmen t of this Act, the Secretary of Transportation shall determine 

## if certain unmanned aircraft syst e ms may operate safely in the national airspace system befor e 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 th e determination under
subsection (a), the Secretary shall determine, at a minimum--

(1) which types of unmanned aircraft systems, 

## if any, as a result of their size, weight, speed, op e rational c apability, 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 certificat e of waiver, certificate of authorization, or airworthiness certification under section 44704 of title 49, United States Code, is required for the operation of unmanned aircraft systems identified under paragraph (I).

(c) Requirements for Safe Operation.--If the Secretary determines under this section
that certain unmann ed aircraft systems may operate safely in the national airspace system, the S ec r et

ary shall establish requirementsfor the safe operation of such aircraft systems in the national airspace system.

In seeking this exemption, CHAD BROWN submits that the DJI Phantom 2
Vision+ and DJI Inspire 1 UASs can operate safely in the NAS pursuant to FMRA
Section 333, as demonstrated by: (a) the characteristics of the DJI Phantom 2 Vision + and DJI Inspire 1 UASs; (b) the pilot certification requirement; and (c) the specific operating limitations.



### a. THE SPECIFICATIONS OF THE DJI PHANTOM 2 VISION+ AND
DJI INSPIRE 1UASS DEMONSTRATE ITS SAFE
CHARACTERISTICS.

The DJI Phantom 2 Vision+ and DJI Inspire 1 UASs do not create a hazard to users of the NAS or the public, or otherwise pose a threat to national security considering its size, weight, speed, and operational capability.



### i. TECHNICAL SPECIFICATIO NS OF THE DJI PHANTOM
2 VISION+ AND DJI INSPIRE 1UASS.

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

are set forth by the DJI Phantom 2 Vision+ and DJI Inspire 1 Specifications and Data Sheet,
attached hereto as Exhibits A and B.



### ii. THE DJI PHANTOM 2 VISION+ AND DJI INSPIRE 1
UASS AUTONOMOUS FLIGHT AND NAVIGATION MODES
ENABLE THE UASS TO REMAIN WITHIN A DEFINED
OPERATIONAL AREA.

### P age 23 CHAD BROWN Petition fo r Exemption The DJI Phantom 2 Vision+ and DJI Inspire 1 UASs may be operated in both manual and fully autonomou s flight modes

. A complete description of the flight and navigational
modes of the DJI Phantom 2 Vision + and DJI Inspire 1 UASs is provided at pages 31-
34 of the DJI Phantom 2 Vision + and pages 12-16 and 45-50 of the DJI Inspir e 1 User Manuals, attached hereto as Exhibit C and D.

iii. 

### THE DJI PHANTOM 2 VISION+ AND DJI INSPIRE 1UASS
ARE DESIG NED FOR AUTOMATIC RETURN TO HOME
POINT OR HOVER IN THE EVENT OF LOSS OF THE
CONTROL LINK OR NAVIGATION.

When the Control Link is lost

, the DH Phantom 2 Vision + and DJI Inspire 1 UAs
will remain stationary, in flight

, for 3 seconds or more. If, after 3 seconds, the DJI Phantom

2 Vision+ and DJI Inspire 1 UAs do not reacquire control link data from the GCS

, the UAs
will assume that the Control Link is lost and the UAs will return to the home position (i.e.,
failsafe mode) via GPS, and will descend to the takeoff position and shutdown.

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

are set forth at pages 32 - 34 and for the DJI Inspire 1 at pag es 13 through 15 of the DJI

Phantom 2 Vision+ and DH Inspire 1 User Manuals, attached hereto as Exhibit C and D.

iv. 

### THE DJI PHANTOM 2 VISION+ AND DJI INSPIRE 1GCS
AND ITS OPERATION.

A complete description of the operation and specifications of the DJI Phantom 2
Vision+ and DJI Inspire 1 GCS and flight control software is provided at pages 31 through

41 of the DJI Phantom 2 Vision+ User Manual and pages 40 through 51 of the DJI Inspir e I

User Manual. DJI Phantom 2 Vision+ and DJI In s pire 1 User Manuals are attached hereto

as Exhibits C and D.



### b. FLIGHT OPERATIONS OF DJI PHANTOM 2 VISION+ AND
DJI INSPIRE 1 UASS ARE LIMITED TO THE LINE OF SIGHT OF A CERTIFICATED PILOT IN COMMAND WITH
A SAFETY OBSERVER.

CHAD BROWN will only utilize certificated pilots to act as a pilot in command (PIC) of the DJI Phantom 2 Vision+ and DJI Inspire 1 UASs. Additionally, a safety
observer will assist all pilots during flight time

.

c. 

### FLIGHTS OF DJI PHANTOM 2 VISION+ AND DJI INSPIRE
1 UASS WILL BE CONDUCTED PURSUANT TO SPECIFIC
OPERATING LIMITATIONS.

In seeking this exemption, CHAD BROWN proposes to commercially operate DJI
Phantom 2 Vision+ and DJI Inspire 1 UASs for the special purpose of conducting aerial
video and photography over certain areas of United States, pursuant to the following specific operating limitations:

1. Operations authorized by this grant of exemption will be limited to the following
aircraft described in the operating documents, rotorcraft UASs weighing less thanCHAD BROWN Petition fo r Exemption Page 24 55 pounds maximum gross weight: DJI Phantom 2 Vision+ and DJI Inspire 1 Unmanned Aircraft Systems

. Proposed operations of any other aircraft will require a new petition or a petition to amend this grant.



### 2. UAS operations under this exemption will be limited to conducting operations for the purpose of aerial video and photography.

3. The UAs may not be flown at an indicated airspeed exceeding 20 knots.

4. The UA must be operated at an altitude of no more than 500 feet above ground level (AGL), as indicated by the procedures specified in the operating documents unless a special request is made and approved by ATC. All altitudes reported to
ATC must be in feet AGL.

5. The UAs 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.

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

7. All operations must utilize a safety observer (SO). The SO may be used to satisfy the VLOS requirement as long as the PIC always maintains VLOS capability. The
SO 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 SO can p erform the functions prescribed in the operating documents.

8. The SO must not perform any other duties beyond assisting th e PIC with seeing
and avoiding other air traffic and other ground based obstacles / obstructions and is not permitted to operate the camera or other instruments.

9. The operating documents and the grant of exemption must be accessible during UAS operations and made available to the Administrator upon request. If 

### a discrepancy exists between the conditions and li mitations contained in the grant of exemption and the procedures outlined in the operating documents, the
conditions and limitations contain e d in the grant of exemption take precedence
and must be followed. Otherwise, the operator must follow the procedures as
outlined in its operating documents. The operator may update or revise its operating document s. It 

### is the operator's responsibilit y to track such revisions
and present updated and revised documents to the Administrator upon request. The operator must also present updated and revised docum e nts if it petitions for extension or amendment to the grant of exemption. If 

### the operator
determines that any 

### update or revision would affect the basis upon which the
FAA granted the exemption, and then the operator must petition for
amendment to its grant of exemption. The FAA 's UAS Integration Office (AFS-80) may be contacted if questions arise regarding updates or revisions to the operating documents.

### P age 23 CHAD BROWN Petition fo r Exemption 

### 10. Prior to each flight the PIC must inspect th e UAS to ensure that it is in a condition
for safe flight. If the inspection reveals a condition that affects the safe operation of the UAS, the aircraft is prohibited from operating until the

necessary maintenance has been performed an d the UAS is found to be in a
condition for safe flight. The Ground Control Station must be included in the preflight inspection. All maintenance and alterations must be properly
documented in the aircraft records.

11. Any 

### UAS that has undergone 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. The PIC who conducts the functional test flight must make an entry in the aircraft records.

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

13. The operator must follow the UAS manufacturer’s aircraft/component

, maintenance, overhaul; replacement, inspection, and life limit requirements.

14. The operator must carry out its maintenance, inspect ions, and record keeping requirements, in accordance with the operating doc uments. Maintenance, inspection

, alterations, and status of replacement/overhaul component parts must be noted in the aircraft records, including total time in service, description of
work accomplished, and the signature of th e authorized person returning the UAS
to service.

15. Each UASs operated under this exemption mu st comply with all manufacturer Safety Bulletins.

16. The authorized person must make an entry in the aircraft record of the corrective
action taken against discrepancies di scovered between inspections.

17. The PIC must possess at least a private pilot certificate and at least a current thirdclass medical certificate.

18. The operator may not permit any PIC to operate unless the PIC meets the operator's qualification criteria and demonstrates the ability to safely operate the
UAS in a manner consistent with how the UAS will be operated under the exemption, including evasive and emergency maneuvers and maintaining appropriate distances from persons, vessels, vehicles and structures. PIC qualification flight hours must be logged in a manner consistent with 14 C.F.R. § 61.Sl (b). Flights for the purposes of training the operator's PICs are permitted
under the terms of the exemption. However, training operations may only be
conducted during dedicated traini ng sessions. During training, proficiency, and experience-building flights, all persons not essen tial for flight operations areCHAD BROWN Petition fo r Exemption Page 24 

### considered nonparticipants, and the PIC must operate the UA with appropriate distance from nonparticipants in accordance with 14 C.F.R. § 91.119.

19. UAS operations may not be conducted during night

, as defined in 14 C.F.R. §
19.1. All operations must be conducte d under visual meteorological
conditions (VMC). If 

### flight at night is required; a special request will b e made

at the FAA office clos e st to proposed area of opera tions. Flights under special
visual flight rules (SVFR) are not authorized.

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

21. Th e UA may not be operated less than 500 feet below or l es s than 2,0 00 feet horizontally from a cloud or wh e n visibility is less than 3 statute miles from the
PIC

.

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

23. Th e PIC must abort the flight in the event of unpredi cted obstacles or

em erg encies in accordance with the operating documents.

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

25. The operator must obtain an Air Traffic Organiza tion (ATO) issued Certificate
of Waiver or Authorization (COA) prior to conducting any operations under the grant of exemption. This COA will also require the operator t o request a N otice
to Airman (NOT AM) not more than 72 hours in advance, but not less than 4 8 hours prior to the operation. All operations shall be conducted in accordance with airspace requirement s in 

### the ATO issued COA including class of airspace, altitude level and potential transponder requirement s.

26. All aircraft operated in accordance with the exemption mu st be identified b y serial number, registered in accordance with 14 C.F.R. part 47, and ha v e identification (N- Number) markings in accordance with 14 C.F.R. part 45

, Subpart C. Markings must be as large as practicable

.

27. Before conducting operations, the radio frequenc y spectrum used for operation
and control of the UA must comply with the Federal CommunicationsCHAD BROWN Petition fo r Exemp t ion Pa ge 

### 2 5 Commission (FCC) or other appropriate government oversight agency requirements.

28. The documents required fewer than 14 C.F

. R. 91.9 and 91.203 mu s t be available

to the PIC at the Ground Control Station of the UAS any time the UAS is operating. These documents must be made available to the Administrator or any law enforcement official upon request.

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

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

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

persons (persons other than the PIC

, SO, operator trainees or essential persons)

, vessels, vehicles, and structures unless:

a. Barriers or structures are present that sufficiently protect nonparticipating persons from the UA and / or debris in the event of an accident. The operator must ensure that nonparticipating pe rsons remain under such protection

. If a situation arises where nonparticipating persons leave
such protection and are within 500 feet of the UA, flight operations must

cease immediately and/or;

b. The aircraft is operated near vessels, vehicles or structures where the

owner /c ontroller of such vessels

, vehicles or s tructure s has granted permission and the PIC has made a safety assessment of the risk of operating closer to those objects and determined that it does not present an undue hazard

, and;

c. Operations nearer to the PIC

, SO, operator trainees or es sen tial persons do not present an undue hazard to those person s per § 91.119(a).

32. All operations shall be conducted over private or controlled-access property with permission from the land owner / controller or authorized representati ve. Permission from land owner/controller or authori zed representative will be
obtained for each flight to be conducted.

33. Any incident

, accident, or flight operation that transgresses the lateral or vertical
boundarie s 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 cont a ined 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.CHAD BROWN Petition for Exemption Page 26 CHAD BROWN submits that the equivalent level of safety established by Section 61.113(a) and (b) w ill be maintained because no PIC will be allowed to operate the DJI
Phantom 2 Vision + and DJI Inspire 1 UASs unless that PIC has demonstrated, by meeting minimum flight-hour and currency requirements

, that the PIC is able to safely operate the DJI
Phantom 2 Vision+ or DJI Inspire 1 UAS in a manner consistent with the exemption

, including evasive and emergency maneuvers and maintain ing appropriate distances from people

, vessels, vehicles and structures.

Considering CHAD BROWN’S proposed area of operations, and the airmanship skills necessary to safely operate the DJI Phantom 2 Vision+ or DJI Inspire 1 UAS

, CHAD BROWN submits that the additional manned airmanship experience of a certificated pilot would not correlate to the airmanship skills necessary for CHAD
BROWN’S specific proposed flight operations.

The FAA has previously granted relief from Section 61.113(a) and (b) specific to
UAS

, in circumstances similar, in all material respects

, to those presented herein (e

. g

. Exemption Nos. 11062, 11063, 11064, l 1065, 11066, 11067, 11080, 11109, 11110, 11112, 11136, 11138, 11150, 11 153, 11156, 11158, 11159, 11160, 11161)

.

CHAD BROWN will not allow any PIC to operate the DJI Phantom 2 Vision+ or DJI Inspire 1 UAS unless that PIC ha s demonstrated

, by meeting minimum flight-hour requirements or the DJI Phantom 2 Vision + or DJI Inspire 1 UAS training and currency requirements, that the PIC is able to safely operate the DJI Phantom 2 Vision+ or DJI Inspire
1UAS in a manner consistent with this exemption

, including evasive and emergency
maneuvers and maintaining appropriate distances from people, vessel s, vehicles and

structures

.

Specifically, the PIC must hav e accumulated and logged, in a manner consistent
with 14 C.F.R. § 61.51(b), 25 hours of total time as a UAS rotorcraft pilot (with a
minimum of 5 hours of those hours as a UAS pilot op erating the same make and model of
UAS to be used for operations under the e x emption)

. In addition to the hour requirements

, the PIC must accomplish 3 tak e offs and landings in the preceding 90 days (for currency purposes).

As in Exemption Nos. 11062

, 11138

, and 11153, prior documented flight experience that was obtained in compliance with applicable regulations will ensure an equivalent le v el of safety during CHAD BROWN’S proposed operation s . The Administrator ha s held that prior documented flight experience that was obtained in compliance with applicable regulations would ensure safe operations, stating as follows:

In Exemption No

. 11062, the FAA required that prior to conducting operations for the purpose of motion picture filming (or similar operations), the PIC must ha v e accumulated and logg ed, in a manner consistent with 14 CFR 61.51(b), 25 hours of total time as a UAS rotorcraft pilot including at least 10 hours logged as a UAS pilot
with a multi-rotor UAS

. Prior to operations under Exemption No

. 11062, the PIC
must also ha v e accumulated and logged a minimum of 5 hours as a UAS pilot operating the same make and model of UAS to be used for operations under the exemption. For clarification, the F AA considers these minimum hour requirements
to be inclusive rather than additive ; i.e

. 5 hours make and model time may beCHAD BROWN Petition fo r Exemp t ion Pa ge 

### 2 5 included in the 10 hours of multi-rotor time and the 10 hours may be included in theCHAD BROWN Petition for Exemption Page 28 total 25 hours of UAS rotorcraft time. In addition to the hour requirements

, the PIC

must accomplish 3 takeoffs and landings in the preceding 90 days (for currency purposes). The FAA finds that at a minimum, the flight-hour requirements in Exemption No. 11062 are appropriate to practice and build proficiency in the skills
necessary to safely conduct the petitioner's proposed operations. The FAA also finds that prior documented flight experience that was obtained in compliance with applicable regulations would satisfy this requirement. Training, proficiency, and experience-building flights can also be conducted under the grant of exemption to accomplish the required flight time. During training, proficiency, and experiencebuilding flights the PIC is required to operate the UA with appropriate distances in
accordance with 14 C.F.R 91.119.

Exemption No. 11138 at page 15.

Accordingly, CHAD BROWN will ensure sate operations by not allowing any PIC
to operate the DJI Phantom 2 Vision+ or DJI Inspire 1 UAS unless that PIC has demonstrated, by meeting minimum flight-hour and currency requirements, that the PIC is
able to safely operate the DJI Phantom 2 Vision+ or DH Inspire 1 UAS in a manner consistent with the exemption, including evasive and emergency maneuvers and maintaining appropriate distances from people

, vessels, vehicles and structures

.



### 3. REASONS WHY AN EXEMPTION FROM THE REQUIREMENTS
OF SECTION 91.7(A) WOULD NOT ADVERSELY AFFECT SAFETY.

The equivalent lev e l of safety established by Section 91.7(a) will be maintained
because prior to every flight, CHAD BROWN will ensure that the DJI Phantom 2 Vision + or DJI Inspire 

### 1 UAS is in 

### an airworthy condition based upon the UAS's compliance with
its operating documents and as stated in the conditions and limitations herein

.

Additionally, the FAA ha s previously granted relief from Section 91.7(a) specific to UAS, in circumstances similar, in all material respects, to those presented herein (e.g. Exemption Nos. 11062

, 11063

, 11064

, 11065

, 11066

, 11067

, 11080

, 11109

, 11110, 11112

, 11136, 11138

, 11150

, 11153

, 11156

, 11157

, 11158

, 11159, 11160

, 11161).



### 4. REASONS WHY AN EXEMPTION FROM THE REQUIREMENTS
OF SECTION 91.121 WOULD NOT ADVERSELY AFFECT SAFETY.

The equivalent level of safety established by Section 91.121 will be maintained
because the altitude information of the DJI Phantom 2 Vision+ and DJI Inspire 1 UAs will
be provided to the PIC via GPS equipment and a radio communications telemetry data link,
which downlinks from the UA to the GCS for acti ve monitoring of the flight path and
altitude. This altitude information, combined with CHAD BROWN’S operation of the
DJI Phantom 2 Vision+ and DJI Inspire 1 UAs within visual line of sight, at or below
500 feet AGL, will ensure a level of safety e quivalent to Section 91.121. The altitude
information will be generated by GPS equipment installed onboard the aircraft. Prior to each flight, 

### a z ero altitude initiation point is automatically established by the UASs at ground level.CHAD BROWN Petition fo r Exemption 

### P age 27 The FAA has previously granted relief from Section 91.121 specific to UAS

, in circumstances similar, in all material respects, to those presented he rein (e.g. Exemption

Nos. 11062

, 11063, 11064, 11065, 1106 6, 11067, 11080, 11109, 11112, 11136, 11138, 11150, 11153, 11156, 11157, 11158, 11159, 11160, 11161).



### 5. REASONS WHY AN EXEMPTION FROM THE REQUIREMENTS
OF SECTION 91.151 (B) WOULD NOT ADVERSELY AFFECT
SAFETY.

A grant of this exemption would ensure an equivalent level of safety established by
14 C.F.R. Section 91.15l(b) as a result of (1) the technical specifications of the DJI Phantom
2 Vision+ and DJI Inspire 1 UASs; (2) the limitations on the proposed flight operations; and (3) the location of the proposed flight operations. Accordingly, CHAD BROWN will

ensure that it will safely operate the battery powered DJI Phantom 2 Vision+ and DJI Inspire 1 UAs during daylight hours in VFR conditions, with enough battery power to fly
for a total duration of 13.5 minutes to the first point of intended landing and, assuming
normal cruising speed, to fly after that for at least 4

. 5 minutes.

Here, as in Exemption No. 11109

, the technical specifications of the DJI Phantom 2
Vision+ and DJI Inspire 1 UASs; the limitations on the proposed flight operations; and the location of the proposed operations

, will ensure an equivalent level of safety established by
14 C.F.R. Section 91.151 (b). Furthermore, safety will be ensured as the DJI Phantom 2
Vision+ and DJI Inspire 1 UASs provide audible and visual warnings to the PIC at the GCS
when the UAs experiences low battery voltage

, the first warning occurring at approximately
33% remaining battery power, and again at approximately 10% remaining battery power. At the critically low battery level, the DJI Phantom Vision+ and DJI Inspire 1 UASs will
descend and land automatically.

Significantly, previous exemptions granted by the FAA concerning Section 91.151
establish that safety is not adversely affected when the technical characteristics and operating limitations of the UAS are considered. Relief has been granted for manned aircraft to operate at less than the minimums prescribed in Section 91.151, including Exemption Nos

. 2689, 5745, and 10650. Moreover, the FAA has previously granted
relief from Section 91.151 specific to UAS

, in circumstances similar, in all material respects, to those presented herein (e.g. Exemption Nos. 8811, 10808, 10673, 11042, 11062, 11063, 11064

, 11065, 11066

, 11067

, 11080, 11109

, 11110, 1 1136, 11138, 11150, 11153, 1 1156, 11157, 11158, 11159, 11160, 11161)

.



### 6. REASONS WHY AN EXEMPTION FROM THE REQUIREMENTS OF SECTIONS 91.405(a), 91.407(a)(l), 91.409(a)(l) & 

### (a)(2), And 91.417(a) and (b) WOULD NOT ADVERSELY AFFECT SAFETY.

In seeking this exemption

, CHAD BROWN submits that the equivalent level
of safety with regard to the regulatory maintena nce and alteration requirements established by Sections 91.405(a), 91.407( a){l),91.409(a)(l) & (a)(2), and 91.417(a) & (b)
will be met because CHAD BROWN will use trained technicians to perform maintenance, alterations, or preventive maintenance on the UASs using the methods, techniques

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

. , the CHAD BROWN Aerial Operations Manual

, Monthly Maintenance Log, and DJICHAD BROWN Petition fo r Exemption Page 30 Phantom 2 Vision+ and DJI Inspire 1 Instruction Manual). Furthermore, CHAD BROWN
will document and maintain all maintenance records for the DJI Phantom 2 Vision + and DJI Inspire 1 UASs.

Since the DJI Phantom 2 Vision+ and DJI Inspire 1 UASs will be inspected as prescribed by the operating documents, CHAD BROWN will maintain the equivalent
level of safety established by Sections 91.405(a), 91.409(a)(l), and 91.409(a)(2)

. A cop y of the DJI Phantom 2 Vision+ and DJ! Inspire 1 User Manuals are attached hereto as Exhibit C and D; a copy of the DJI Phantom 2 Vision+ and DJI Inspire 1 UAS Maintenance
LOG is attached hereto as Exhibit E.

Likewise, the exemption sought will not adversely affect safety because CHAD
BROWN will use trained technicians to perform maintenance, alterations or preventive
maintenance on the UAS using the methods, techniques

, and practices prescribed by the operating documents.

Furthermore

, the exemption sought would maintain an e quivalent level of safety established by S e ctions 91.407, 91.417(a) and 91.417(b), because all maintenance of the DJI Phantom 2 Vision+ and DJI Inspire 1 UASs w ill be performed by trained technicians

. Maintenance will be documented and maintained utili z ing the monthly maintenance log.

Significantly, previous exemptions granted by the FAA concerning Sections 91.405(a), 91.407(a)(l), 91.409(a)(l) & (a)(2)

, and 91.417(a) & (b) establish that safety is

not adversely affected when the technical characteristics and operating limitations of th e UAS are considered.

In consideration of CHAD BROWN’S proposed operating limitations, the operating documents

, and the technical aspects of the DJI Phantom 2 Vision+ and DJI Inspire 1 UASs, CHAD BROWN submits that safety will not be adversely affected by granting exemption from 14 C.F.R. Sections 91.405(a)

, 91.407(a)(l) and (a)(2), 91.409(a)(2), and 91.417(a) and (b). The FAA has previously granted relief specific to

UAS in circumstances similar, in all material respects, to those pr esented herein (e.g. Exemption Nos. 11062, 11063, 11064

, 11065

, 11066

, 11067

, 11080

, 11109, 11110,

11112

, 11136

, 11138

, 11150, 11153, 11156

, 11157

, 11158

, 11159, 11160

, 11161).



### 7. THE FAA MAY PRESCRIBE ANY 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. § 21.16 entitled Special Conditions, CHAD BROWN reque s ts
that the FAA prescribe special conditions for the intended operation of the DJI Phantom 2
Vision+ and DJI Inspire 1 UASs, which contain such safety standards that the
Administrator finds necessary to establish a level of safety equivalent to that establi s hed by

14 C.F.R. Part 21, Subpart H, and 14 C.F.R §§ 61.113(a) & (b)

, 91.7 (a)

, 91.121, 91.151(b), 91.405(a), 91.407(a)(l), 91.409(a)(l) & (a)(2)

, and 91.417(a) & (b). Such special
conditions will permit safe operation of the UAs for the limited purpose of conducting aerial video and photographyCHAD BROWN Petition fo r Exemption Page 29 over certain areas of the United States for compensation or hire. 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 authority 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 C.F.R. 

### § 21.16, for operation of the DJI Phantom 2 Vision+ and DJI Inspire 1 UASs, since the airworthiness regulations of 14 C.F

. R. Part 21 do not contain adequate or appropriate safety
standards

, due to the novel or unusual design features of the aircraft. Section 21.16, entitled Special Conditions, states the following:



### If the FAA finds that the airworthiness regulations of this subchapter do not
contain adequate or appropriate safety standards for an aircraft, aircraft engine, or propeller because of a novel or unusual design feature of the aircraft

, aircraft engine or propeller

, he prescribes special conditions and amendments thereto for the product. The special conditions are issued in accordance with Part 11 of this chapter and contain such safety standards for the aircraft:

, aircraft engine or propeller
as the FAA finds necessary to establish a level of safety equivalent to that
established in the regulations.

See 14 C.F.R. § 21.16.

Therefore, in accordance with FMRA Section 333 and 14 C.F.R. 

### § 21.16, the FAA may prescribe special conditions for CHAD BROWN’S intended operation of the DJI
Phantom 2 Vision+ and DJI Inspire 1 UASs, which contain such safety standards that the
Administrator finds necessary to establish a le ve l 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.l5l(b), 91.405(a), 91.407(a)(l ), 91.409(a)(l ) & (a)(2), and 91.417(a) & (b).



### F. A SUMMARY THAT CAN BE PUBLISHED IN THE FEDERAL REGISTER, STATING: THE RULES FROM WHICH CHAD BROWN
SEEKS EXEMPTION:

CHAD BROWN s eeks exemption from the requirements of 14 C.F. R Sections 61.l 13(a)&(b), alternatively 14 C.F.R S ectio n 61.113, and 91. 7 (a), 91.121, 91.15l(b), 91.405(a), 91.407(a)(l), 91 .409(a)(l) & (a )(2), and 91.417(a) & (b).



### A BRIEF DESCRIPTION OF TH E NATURE OF THE EXEMPTION
CHAD BROWN SEEKS:

This exemption will permit CHAD BROWN to com m ercia ll y operate an Unmanned Aircraft System (UAS) for the purpose of conducti n g aerial video and photography over allowed areas of the United Stat es.



### G. ANY ADDITIONAL INFORMATION, VIEWS, OR ARGUMENTS
AVAILABLE TO SUPPORT CHAD BROWN’S REQUEST.CHAD BROWN Petition fo r Exemption Page 30 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 the NAS. As such, CHAD BROWN’S request for exemption may be granted pursuant to the authority of FMRA Section 333 and 14 C.F.R. Part 11, as
set forth above. FMRA Section 333 sets forth the requirements for c o nsidering whether a UAS will
create a hazard to users of the NAS or the public

, or otherwise poses a threat to national security ; and further

, provides the authority for such UAS to operate without airworthiness
certification.
As discussed in detail above

, CHAD BROWN will operate the DJI Phantom 2
Vision + and DJI Inspire 1 UASs safely in the NAS, without creating a hazard to users of
the NAS

, or the public, or otherwise pose a threat to national security.

CONCLUSION

As set forth herein, CHAD BROWN seeks an exemption pursuant to 14 C.F.R. §
11.61 and Section 333 of the FAA Moderni z ation and Reform Act of 2012 (FMRA), which will permit safe operation of the DJI Phantom 2 Vision + and DJI Inspire 1 UASs commercially, without an airworthiness certificate, for the limited purpose of c o nducting aerial video and photography over certain areas of 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,
b y allowing CHAD BROWN to safely, efficiently, and economically operate the DJI Phantom 2 Vision+ and DJI Inspire 1 UASs commercially within the NAS.

WHEREFORE, in accordance with the Federal Aviation Regulatio ns and the FAA
Modernization and Reform Act of 2012, Section 333, CHAD BROWN respectfull y request s that the Administrator grant this Petition for an exemption from the requirements of 14 C

. F

.

R Sections 61.l 13(a) & 

### (b) or alternatively 14 C.F.R Sections 61.113, 91.7(a), 91.121, 91.151(b), 91.405( a), 91.407(a)(l)

, 91.409(a)(l ) & (a)(2), and 91.417(a) & (b)

, and perm i t OAP to operate the OJI Phantom 2 Vision + and DJI Inspire 1 UASs commercially for the purpose of conducting aerial video and photography over cert a in area s of the United States

.

Dated: July 10, 2015

Respectfully submitted by:

CHAD BROWN
2354 Fairview Lane Mound, MN 55364