UNITED STATES OF AMERI CA DEPARTMENT OF TRANSPORTATION FEDERAL AVIATION ADMINISTRATION

WASHI NGTON, DC

Regulatory

Docket No. _______________

**IN T HE**  **MATTER OF THE PETITION FOR EXEMPTION OF:**

T HAYER ENTERTAINMENT **FOR AN EXEMPTION SEEKING RELIEF FROM THE REQUIREMENTS OF**

**TITLE 14 OF THE CODE OF FEDERAL REGULATIONS SECTIONS**  **6 1.113(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) CONCERNING COMMERCIAL OPERATION O**  **F DJI PHANTOM**  **2 VISION**  **+ UNMANNED AIRCRAFT SYSTEM**  **PURSUANT TO SECTION 333 OF T**  **HE FAA MODERNIZATION AND REFORM ACT OF 2012** 

**(PUBLIC LAW 112-95)**

Submitted on M ay 24 , 2015 Robert Thayer Thayer Entertainment 25290 Calvert Dr Greensboro, MD 21639 (443) 253-17162 **TABLE OF CONTENTS** Page GLOSSARY OF ABBREVIATIONS.

.. ........................................................................... . ....3 SUMMARY.

.. ........................................................... .............................................................4 IN TRODUCTION AND INTERESTS OF PETITIONER... .................................................4 BACKGROUND

... .................................................................................. ...............................4 BASI S FOR PETITION...

... ...................................................................................................5 NAME AND ADDRESS OF PETITIONER....

.................................................... .. ...7 THE SPECI FI C SECTIONS OF 14 C.F.R. FR OM WHI CH T H AYER ENTERTAINMENT SEEKS EXEMPTI ON.

....... .................................................. .......8 THE EXTENT OF RELIEF THAYER ENTERTAINMENT SEEKS AND THE REASON THAYER ENTERTAINMENT SEEKS THE RELIEF...

............ . .........11 THE REASONS WHY GRANTING THAYER ENTERTAINMENT's REQUEST WOUL D BE IN THE PUBLIC INTEREST

......... ...................................... ..... .....15 THE REASONS WHY GRANTING THE EXEMPTI ON WOULD NOT ADVERSEL Y AFFECT SAFETY

....... ..................... ..............................................19 SUMMARY THAT CAN BE PUBLISHED IN THE FEDERAL REGI STER...... 34 ANY ADDITIONAL INFORMATION, VIEWS, OR ARGUMENTS AVAILABLE TO SUPPORT THAYER ENTERTAINMENT's REQUEST... ......34 CONCL USION

... ...................... ............................................................. ..............................35 APPENDI CES........................................................................................373 **GLOSSARY OF ABBREVIATIONS** AGL Above Ground Level AOI Area of Interest ATC Air Traffic Control ATO Air Traffic Organization AV Aerial Vehicle CFR Code of Federal Regulations COA Certificate of Authorization FAA Federal Aviation Administration FAR Federal Aviation Regulation GCS Ground Control Station GPS Global Positioning Sy stem LOL Loss of Link NAS National Airspace Sy stem NOTAM Notice to Airman PI C Pilot I n Command Section 333 FAA Modernization and Reform Act of 2012 (FMRA) Section 333 SO Safety Observer SOP Standard Operating Procedures UA Unmanned Aircraft UAS Unmanned Aircraft Sy stem VFR Visual Flight Rules VLOS Visual L ine of Site VMC Visual Meteorological Conditions VTOL Vertical Takeoff and Landing4 **SUMMARY** THAYER ENTERTAINMENT seeks exemption from the requirements of 14 C.F.R §§ 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), to operate an Unmanned Aircraft Sy s tem pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (FMRA). This exemp tion will permit THAYER ENTERTAINMENT to operate an Unmanned Aircraft Sy stem ( UAS) for the commercial purpose of conducting aerial v ideo and photography of construction sites, real e state, and landscape o v er certain areas of the United States.

**INTRODUCTION AND INTERESTS OF TH E PETITIONER**  THAYER ENTERTAINMENT provides its clients with expertise and knowledge in advanced technologies and solutions to increase efficiency, p roductivity and effectiveness. THAYER ENTERTAINMENT is experienced in all aspects of aerial video and photograph y. The objective of THAYER ENTERTAINMENT's aerial video and photography operations is to p rovide low cost, high quality imaging for a variety o f

comme rcial and residential customers

. **BACKGROUND** Unmanned Aircraft Sy stem : DJI Phantom 2 Vision+ UAS THAYER ENTERTAINMENT seeks an exemption to operate a DJ I Phantom 2 Vision+ unmanned aircraft s ys tem ( UAS) f o r compensation or hire within the NAS. The DJ I P hantom 2 Vision + is a v ertical takeoff and landing (VTOL) Unmanned Aircraft (UA) with a Ground C o ntrol Statio n ( GC S) utilizing electronic tablet o r smart phone sy stems

. The D J I Phantom 2 Vision + has a maximum g ross weigh t o f approximately 2 pounds 11 ounces, while having a len gth of 16 inches width of 16 in ch es , height of 8 inches, and a maximum speed of5

approximat ely 29 knots. The DJI Phantom 2 Vision+ UA is equip ped with f our main

r otors; driven by L ithium Poly mer battery powered electric motor s.

The DJ I P hantom 2 Vision+ UA that will be operated b y THAYER ENTERTAINMENT will be registered in accordance with 49 U.S.C. 44103, Registration

o f Aircra ft , 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

. **BASIS FOR PETITION** Petitioner, THAYER ENTERTAINMENT , p ursuant to the p rovisions of the Federal Aviation Regulation s (14 C.F.R. § 11.61) and the FAA Modernization and Reform Act of 2012 (FMRA), Section 333, S p ecia l Rules for Certain Unmanned Aircraft S ystems , hereby p etitions the Administrator to commercial ly operate the DJ I Phan tom 2 Vision+ UAS in the National Airspace S ys tem (NAS), and for an exemption from the requirements of 14 C.F.R § § 61.113(a) & (b), 91.7(a), 9 1.121, 91.151(b), 91.405(a), 91 .407(a)(1), 9 1

. 4 0 9 ( a)(1) & (a)(2), and 91.41 7(a) & (b). In consider atio n o f the speed, weight, size, and limited operating area associated with the unmanned aircraft and its operation, THAYER ENTERTAINMENT's operation of DJ I Phantom 2 Vision + UAS meets the conditions of FMRA Sectio n 333 and therefore, will not require an airworthiness certificate in accordance with 14 C.F.R. Par t 2 1 , Subpart H.6 Accordingl y, THAYER ENTERTAINMENT requests relief from Sections 91.405(a), 91.407(a)(1), 91

. 409(a)(1) & (a)(2), and 91

. 4 1 7(a) & (b), as these sections set f o r th r equirements for

maintenance that onl y app l y to aircraft with an airworthiness certifica te THAYER ENTERTAINMENT su b mits that the requested relief is proper since an equivalent level of safet y will be ensured. THAYER ENTERTAINMENT will

u se experienced personnel or technicians to perfor m maintenance, alteration s, or p r eventive maintenance on the UAS using the methods, techniques, and practices prescribed in the operating do cuments (i.e., the THAYER ENTERTAINMENT Aerial Op erations Manual , M ont h ly Main ten ance Lo g , a nd DJI Phantom 2 Vision+ Instruction Manual). Furthermore, THAYER ENTERTAI NMENT will document and maintain all maintenance records fo r the DJ I P hantom 2 Vision + UAS

. Relief from certain requirements of Section 61.113(a) and (b), entitled Private pilot privileges and limitations: Pilot in comman d , is requested by THAYER ENTERTAINMENT to the extent necessary to allow a Pilot in Command (PI C) holding a
p rivate pilot or h igh er level certificate, as well as an airman medical certificate, and who has demonstrated, by meeting minimum flig h t

- h o u r and currency req uir ements, that the
PI C is able to safely o p er ate the DJ I P hantom 2 Visio n + UAS in a manner consist ent with this exemption, including e vasive and emer gency maneuvers and maintaining appropriate distances from people, vessels, vehicles an d structures. THAYER ENTERTAINMENT seeks relief from Section 91.7(a), entitled Civil

a ircraft airworthiness , be cause th e DJ I P han tom 2 Vision+ UAS do not require an airworthiness certificate in accordance with 14 C .F.R. Part 21, Subpart H. As such, THAYER ENTERTAINMENT submits that it will ensure that the DJ I P hantom 27

Vision+ UAS are in a n airworth y condition, prior to every flight, b y determining that th e UAS s are in compliance with the operating documents (i.e., the THAYER ENTERTAINMENT Aerial Operations Manual, Monthly Maintenance Lo g, and DJI Phantom 2 Vision+ I nstruct ion Manual) , and that the aircraft are in a condition fo r safe flight. THAYER ENTERTAINMENT also seeks an exemption from the requirements of Section 91.121, entitled Altimeter Settings , as the DJ I P hanto m 2 Vision+ UA will not h ave a ty pical barometric altimeter onboard. However, altitude information of the DJ I Phantom 2 Visio n + UA will be p r o v ided to the PI C via Global Positio ning Sy stem (GPS) equipment and radio communications telemetry data link, wh ich downlinks from the UA to the GCS for active monitori n g of the flig h t p ath. This altitu de informatio n, combined with THAYER ENTERTAINMENT's operation of the DJI Phantom 2 Vision+ UAS within

v is ual line of sight, at or below 5 0 0 feet AGL, will en sure a leve l of safety equivalent to Section 91.121. Additionally , THAYER ENTERTAINMENT seek s an exemption from th e

r eq uirements of Section 91.151(b), entitled Fuel requirements for flight in VFR conditions

. THAYER ENTERTAINMENT submits that safety will not be affected b y operation of th e DJ I Phantom 2 Vi sio n + UA d u ring day light hours in visual meteorological conditions (V MC) under visual flight rules (VFR), with enough battery power to fly for a total d u ration of approximately 1 3 .5 minutes to the first point of intended landing and, assuming no r mal cruising speed, to fly after that for at least 4.5 min utes

.8 In accordance with 14 C.F.R. § 11.81, THAYER ENTERTAINMENT p rovides the following information in support of its petition for exe mption: **A. Name And Address Of The Petitioner.**  The name and address of the Petitioner and point of contact is:
R obert Thayer D.B.A. THAYER ENTERTAINMENT 25290 Calvert Dr Greensboro, MD 21639 Tel: (443 ) 253

- 1716 Email: r cth ayer@comcast.net
**B .**  **T he**  **Spec ific Sections Of 14 C.F.R.**  **From Which**  THAYER ENTERTAINMENT **Seeks Exemption.**  **1.** T HAYER ENTERTAINMENT **Seeks Exemption 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: (a) No person who holds a private pilot certificate may act as a pilot in command (PI C) of an aircraft that is carry ing passengers or propert y 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 an y business or emp loy ment if

— (1) The flight is only

incidental to that business or employ ment; and (2) The aircraft does not carry passengers or property

for compensation or hire.

**2.** T HAYER ENTERTAINMENT **Seeks Exemption From The Requirements 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.9 **3.** T HAYE R ENTERTAINMENT **Seeks Exemption From The Requirements Of**  **Section 91.121.** Section 91.121, entitled Altimeter 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, b y 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)(1)(i ) of this section, the current reported altimeter setting of an appropriate available station; or (iii) I n the case of an aircraft not equipped with a radio, the elevation of the departure airport or an appropriate altimeter setting available before depar ture. **4.** T HAYE R ENTERTAINMENT **Seeks Exemption From The Requirements Of**  **Section 9**  **1 .**  **151(b).** Section 91.151, entitled Fuel requirements for flight in VFR conditions , subsection (b), states the following: (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.** T HAYE R ENTERTAINMENT **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 provided in paragraph (c) of this section, have discrepancies repaired as prescribed in part 43 of this chapter[.]10 **6.** T HAYER ENTERTAINMENT **Seeks Exemption From The**  **Requirements Of Section 91.407(a)(1)**  Section 91.407, entitled Operation after maintenance, preventive maintenance, rebuilding, or alteration , subsection (a)(1), states the following: (a) No person may

operate any

aircr aft that has undergone maintenance, preventive maintenance, rebuilding, or alteration unless

-- (1) It has been approved for return to service b y a person authorized under § 43.7 of this chapter[.]
**7.** T HAYE R ENTERTAINMENT **Seeks Exemption From The Requirements Of**  **Sections 91.409(a)(1) 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 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 b y 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.** T HAYE R ENTERTAINMENT **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: (a) Except for work performed in accordance with §§ 91.411 and 91.413, each registered owner or operator shall keep the following records for th e 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 (i ncluding the airframe) and each engine, propeller, rotor, and appliance of an aircraft. The records must include

--11 (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 aircraft for return to service. (2) Records containing the following information: (i) The total time in service of the airfram e, 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 ov erhauled 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 safet y directive number and revision date. If the AD or safety directive involves recurring action, the time and date when the next acti on is required. (vi) Copies of the forms prescribed b y § 43.9(d) of this chapter for each major alteration to the airframe and currentl y installed engines, rotors, propellers, and appliances. (b) The owner or operator shall retain the following records f or the periods prescribed: (1) The records specified in paragraph (a)(1) of this section shall be retained until the work is repeated or superseded b y other work or for 1 ye ar 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 air craft is approved for return to service.12

**C. The Extent Of Relief** THAYER ENTERTAINMENT **Seeks And The Reason T**  HAYER ENTERTAINMENT **Seeks The Relief.**  **1. E**  **x t**  **ent Of Relief** THAYER ENTERTAINMENT **Seeks And The Reason** THAYER ENTERTAINMENT **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 PI C holding a private pilot or higher level certificat e, 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 i n Section 61.113(a) and (b) state that a private pilot may, for compensation or hire, act as PI C of an aircraft in connection with an y business or emplo ym ent if: (1) The fl ig ht is only incidental to that business or employ

ment; and (2) The aircraft does no t carry passengers or propert y for compensation or hire. As set forth more full y below, THAYER ENTERTAINMENT submits th at an equivalent level of safety will be maintained because no PI C will be allowed to operate the DJ I Phantom 2 Vision+ UAS unless th at PI C has met certain flight-h o u r an d currency requirements, demonstrating th at the PI C is able to safely op erate either the D JI Phantom 2 Vision+ UAS in a manner consistent with the operations specifications as d escribed in th is exemption, including evasive and emergency maneuvers, as well as maintaining appropriate distances from people, vessels, vehicles and structures.Fu rther, THAYER ENTERTAINMENT submits that all flights of the DJ I Phantom 2 Vision+ U A S,

co n ducted b y the PI C pursuan t to the grant of this13

Petition: (1) will be incidental to THAYER ENTERTAINMENT's business; and (2) will

n o t carry p assengers or property f o r compensation or hire. **2. E**  **x t**  **ent Of Relief** THAYER ENTERTAINMENT **Se eks And The Reason**  THAYER ENTERTAINMENT **Seeks Relief From Section 91.7(a).**  Relief from Section 91.7(a) entitled Civil aircraft airworth iness , is requested to the extent required to allow THAYER ENTERTAINMENT to determine that the DJ I Phantom 2 Vision+ U AS are in airworthy condition prior to every flight by ensuring that the UAS is in compliance w ith the operating documents (i.e., the THAYER ENTERTAINMENT Aerial Operations Manual, Monthly Maintenance Lo g, and DJI Phantom 2 Vision+ I nstruction Ma nual)

. THAYER ENTERTAINMENT seeks the requested relief because the DJ I Phantom 2 Vision+ U AS do not require an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H. Therefore, THAYER ENTERTAINMENT will ensure that the DJI Phanto m 2 Visio n + UAS is in n airworth y condition based u p o n its compliance with the operating documents (i

. e., the THAYER ENTER TAINMENT Aerial Operations Manual, Monthly Maintenance Log, and DJI Phan to m 2 Vision+ Instr uction Manual)
p rior to every flight, and further, determin e that the aircraft are in con ditio n for safe f ligh t,

as stated in the **3. Ext**  conditions and limitations below. **ent Of Relief** THAYER
E NTERTAINMENT **Seeks And T**  **he Rea**  **son** T HAYER

E NTERTAINMENT **Seeks Relief From Section 91.121.**  Relief from Section 91.121, entitled Altimeter settings , may be requ ired to allow flight operatio ns of the DJI Phantom 2 Vision+ UAS , which utilize a barometric pressure sensor, GPS equipment, and a radio communications telemetry data link to downlink altitude information from the UA to the PIC at the ground control station (GCS). Since the FAA requires that an y altitude information concerning UAS op erations14

be reported to air traffic control (ATC) in feet above gr ound level ( AGL), THAYER ENTERTAINMENT seeks the requested relief because the DJ I P hantom 2 Vision + UA ’s altimeter may b e s et o n th e g round to zero f eet AGL, rather than the local barometric pressure or field altitude, before each flight. Considering the limited altitude of the pro p osed operatio n s, relief from 14 CFR 9 1

. 121 is sought to the extent necessary to comply with the applicable conditions and limitations stated below . As more full y set forth herein, an equivalent lev el o f safet y will b e maintained since the DJI Ph an tom 2 Vision+ UA is equipped with a barometric pressure sensor and GPS equ ipment, which automaticall y ensu res that a ground level
p r ess u r e setting will be established prior to each flight, and provides the PI C with altitud e in f o rmation of the UA on the heads -u p d isplay of the GCS. **4. E**  **x t**  **ent Of Relief** THAYER ENTERTAINMENT **Seeks And The Reason** THAYER ENTERTAINMENT **Seeks Relief From Section 91. 151(b).**  Relief from Section 91.151(b) entitled Fuel requiremen ts for flig h t in VFR conditions , is requested to the ex tent required to allow flights of the battery powered DJ I Ph antom 2 Vision+ UA d u ring day light hours in v isu al meteoro logical conditions (VMC), under visual flight rules (VFR), for a total duration of 13.5 minutes to t h e f ir st
p o in t of intended landing and, assuming normal cruising speed, to f ly after that for at least 4.5 min utes. THAYER ENTERTAINMENT seeks the requested relief because without an exemption from Section 91. 1 5 1(b), the flight time duration of the battery po wered DJ I Ph antom 2 Vision+ UA will severel y constrain the practicality of any aer ial video or still
p h o to flight operations that THAYER ENTERTAINMENT pr oposes to co nduct pu rsu ant to this Petition.15 Significantl y, as set forth below, the technical specifications of the DJ I P h anto m 2 Vision+ UAS , t he D J I P hanto m 2 Vision+ o perating documents, an d THAYER ENTERTAINMENT's proposed operating limitations, ensure that THAYER ENTERTAINMENT will safely o perate the battery po wered DJ I P han tom 2 Vision+ UAs d u r ing day light hours in v isu al meteorological conditions (VMC), under visual flight

r u les ( VFR) , with enough battery power to fly f or a total duration of 13.5 minutes to the first point of intended landing and, assuming normal cruising speed, to fl y after that for at least 4.5 minutes

. **5. E**  **x t**  **ent Of Relief** THAYER ENTERTAINMENT **Seeks And The Reason** THAYER ENTERTAINMENT **Seeks Relief From Sections 91.405(a), 91.407(a)(1),**  **91.409(a)(1) & (a)(2), And 91.417(a) & (b).** Since Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b)

o nly ap p l y to aircraft with an air worthiness certificate, THAYER ENTER TAINMENT

r equests relief from these Sections because the DJ I P h antom 2 Vision+ UAS do n o t require airworthiness certificate s. As set forth more fully b elo w, th e DJI Phantom 2 Vi sion+ U AS meet the conditions o f FMRA Section 333 for operation without an airworthiness certificate . Accordingl y, THAYER ENTERTAINMENT will use trained technicians to perform maintenance, alterations, or preventive maintenance on the UASs

u sin g th e methods, techniques, and practices pres cribed in the UAS operating documents (i .e. , th e THAYER ENTERTAINMENT Aerial Operations Manual, Month ly Maintenance Log, an d DJ I P hantom 2 Vision+ Instructio n Manu al). Furthermore, THAYER ENTERTAINMENT will document and maintain all maintenance reco rds for the DJ I Ph antom 2 Vision+ UAS

. **Public Interest; That Is, How It Would Benefit The Public As A Whole. D. The Reasons Why Granting**  THAYER ENTERTAINMENT's **Request Would Be In The** 16 Grant ing the p r esen t Petition will f u r ther th e public in terest by allowing THAYER ENTERTAINMENT to safel y, efficiently, and economically p erform aerial v ideo and
p h o tography of construction sites, real estate, and landscape over certain areas of the United States. Additionally , use of the DJI Phantom 2 Vision + UAS will decrease congestion of the NAS, reduce pollution, and provide significant benefits to the e conom y. Notabl y, the benefits of THAYER ENTERTAINMENT's proposed operation of the D J I Pha ntom 2 Vision+ UAS will be realized without implicating any p r ivacy issues.

**1 . The Public Will Benefit From Decreased Congestion Of The NAS.**  The DJ I P hantom 2 Vision+ UA is battery p o wered and serve as a safe, effic ient, 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 DJ I P hantom 2 Vision+ UA would reduce the amount of manned air craft in the NAS, reduce noise and air pollution, as well as increase the safet y

o f life and propert y in the air and on the ground. Furthermore, b y reducing the number of manned aircraft operating in the NAS, congestion ar ound airports caused b y arriving and departing aircraft will be reduced. The DJI Phantom 2 Vision+ UA do es not require an airport to takeoff or land. Likewise, a reduction of manned aircraft conducting aerial v ideo and photography missions would result in fewer aircraft that must be handled b y 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**  **Pha ntom 2 Vision+**  **UAS .** 17 Conducting aerial acquisition s with the DJI Ph antom 2 Vision+ UAS , instead of manned aircraft, will greatl y benefit th e publi c by drastically reducing the levels of air and noise pollution generated during traditional aerial v id eo and still photogr aph y f light

o p erations. By u sin g battery p o wer an d electric motors, the DJ I Phantom 2 Vision+ UAS
p r o duce n o air p ollution, and is the most viable environmen tall y conscious alternative to the cabin class, six cyl in d er internal comb u stio n en g in e aircr aft that are t yp icall y utilized f or aerial v ideo and photography , w h ile burning approximately 20-3 0 gallo n s per hour of leaded aviation fuel. The DJ I Phantom 2 Vision+ UA , wh ile reducing the carbon footp r int of aerial acquisitions, also eliminates noise pollution, as the UA is p r o p elled by battery
p owered electric motors, rather than an internal combusti on engine.

B y using the DJ I P hantom 2 Vision+ a UAS to perform aerial acquisitions, the substantial risk to life and property in the air and on the ground, which is u sually associated with traditional manned aircraft flight operations, w ill be su bstantially reduced

o r completel y elimin ated. Aside from the lack of f light crew members located onbo ard the aircraft, the DJI Phan to m 2 Visio n + UA (w eighing approximately 2 pounds 11 o un ces , at its maximum gross weight s with len gth o f 16 inches , width of 16 inches , and with no fuel

o n board), has less phy sical potential for collateral damage to life and pr op ert y on the
g r ound, and in the air, co mp ared to the manned aircraft that ty pically conduct s imilar

o p erations ( weighing app r o x imately 6,00 0 pounds with a win g sp an o f approximately 42 f eet, a length of 3 4 f

eet, and a fuel capacity of 180 gallon s).18 **3. Performing Aerial Video and Photography**  **Operations With The DJI**  **Pha ntom 2 Vision+**  **UAS sW**  **ill Benefit The Economy.** In addition to being safe and efficient, the DJ I P hantom 2 Vision+ UA S are also an economical alternative to using ma nned aircraft to conduct similar aerial operations . As such, operation of the DJ I Phantom 2 Vision+ a UA S will allow United States based companies, like THAYER ENTERTAINMENT , to remain competitive and contribute to
g r o wth of the U.S. economy . Specificall y, with the rising cost of aviation fuel and the Environmental Protection Agency ( “EPA”) regulatory actions phasing out leaded aviation fuels, U.S. owned and operated companies must adopt new and a lternative technology in order to remain competitive. Operating th e battery p o wered DJ I Phantom 2 Vision+ UAS is

o n e such technology that not only allows companies greater operational flexibility compared to manned aircraft, but provides such flexibility without the high operation al cost of a traditional manned aircraft.
B y operating the DJ I P h antom 2 Vision+ UAS , companies such as THAYER ENTERTAINMENT , can remain competitive and profitable, and therefore, provide
gr eater job stability to employ ees and contractors, wh ich will ultimately contribute to
g rowth of the U. S. economy . Improved financial performance of U.S. companies, through co mmercial use of the DJI Phantom 2 Vision+ UAS , provides a stable workforce that increases consumer spending; improves local, state, and federal tax revenu es; and allows companies to invest in res earch and development in order to remain comp etitive b oth 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 d ecades, THAYER ENTERTAINMENT's proposed operati o n o f the DJ I Phantom 2 Vision+ UAS will not implicate any privacy issues.19

T he DJI Phantom Vision+ UAS will be operated only in compliance with operating documents (i.e., the THAYER ENTERTAINMENT Aerial Operations Manual, Monthly Maintenance Log, and DJI Phantom 2 Vision+ Instruction Manual) which requires property owner inv o lvement 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. The 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 Which**  THAYER ENTERT AINMENT **Seeks Exemption.** 

**1. Reasons Why The**  **DJI Phantom 2 Vision+ UA Meet**  s **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, THAYER ENTERTAINMENT's operation of the DJI Phan tom 2 Visio n + a UAS meet s 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 threat to national securit y. Specificall y, FMRA Section 333 states the following, in part: (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.20 (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 sys tem 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, 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. In seeking this exemption, THAYER ENTERTAINMENT submits that the DJ I P h antom 2 Vision+ UAS can operate safely in the NAS pursuant to FMRA Sect ion 3 33, as demonstrated b y: ( a) the characteristics of the DJ I P h antom 2 Vision+ UAS ; (b) the pilot certification requirement; and (c) the specific operating limitations.

**a. T**  **he Specifications Of The**  **DJ I Phantom 2 Vision+**  **UAS Demonstrat**  **e Its Safe Characteristics.**  The DJ I P h antom 2 Vision+ UAS do n o t create a hazard to users of the NAS or the public, or otherwise pose a threat to national securit y considering its size, weight, speed, and operational capability

.

**i. Technical Specifications Of The**  **DJI Phantom 2 Vision+ UAS**  **.**
The technical specifications of the DJ I P hantom 2 Vision+ UAS are set forth b y the DJ I P h antom 2 Vision+ Specifications and Data Sheet, attache d hereto as Exhibit A

.21 **ii. The D**  **J I Phantom 2 Vision+**  **UAS Autonomous**  **Flight And Nav**  **igat ion Modes Enable The UAS**  **s To Remain Within**  **A Defined Operational Area.**  The DJ I P h antom 2 Vision+ UAS may b e operated in both manual and fu ll y autonomous fligh t modes. A complete description o f the flight and navigational modes of the D J I P hantom 2 Vision+ UAS is provided at pages 25-35 of the D J I P hantom 2 Vision+ and pages 12-1 6 , attached hereto as Exhibit B.

**iii. The**  **DJI Phantom 2 Vision+ UAS**  is **Designed For Automatic**  **Return To Home Point Or Hover In The Event Of**  **Loss Of The Control Link Or Navigation.**  When the Co n trol L ink is lost, the DJI Phantom 2 Vision+ UA will remain stationary , in fligh t, for 3 seconds or more. If, after 3 seconds, the D J I P h antom 2 Vision+ UA s do not reacquire control link data from the GCS, the UA will assume that the Control
L ink is lost and the UA s will return to the home position (i.e., f ailsafe mode) via GPS, and will descend to the takeoff p osition and shutdown. A complete description of the Failsafe Functions of the DJ I P hantom 2 Vision+ UAS are set forth at p ages 27 through 29 of the DJ I Phantom 2 Vision + User Manual , attached hereto as Exhibit B in a Seperately Attached PDF

.

**iv. T**  **he DJI Phantom 2 Vision+**  **GCS And Its Operation.**  A complete description of the operation and specifications of the DJ I P hantom 2 Vision+ GCS and flight control software is provided at pages 32 through 43 of the DJ I Phantom 2 Vision+ User Manual attached h ereto as Exhibits B.22 **b. Flight Operations Of**  **DJI Phantom 2 Vision+ UAS**  i s **Limited To The L**  **ine Of Sight Of A Cer tificated**  **Pilot in Comma nd**  **Wi th**  **A Sa f**  **ety Observer.**  THAYER ENTERTAINMENT will only u tilize certificated pilots who possess a
current and valid airman medical certificate to a ct as a p ilot in command (PI C) of th e DJ I Ph antom 2 Vision+ UAS

. Additionally , a safet y obse rver will assist all pilots during flight time.

**c. Flights Of DJI Phantom 2**  **Vision+ UAS**  **W ill Be**  **Conducted Pursuant To Specific Operating Limitations.**  In seeking this exemption, THAYER ENTERTAINMENT pr op oses to commercially o p erate DJ I P hantom 2 Visio n + UAS for the special purpose of

co nducting aer ial v ideo and photography o v er certain areas of United States, pursuant to the following specific ope rating limitations: 1. Operations authorized by this g r an t o f ex emp tio n w ill be limited to the following aircraft described in the operating documents, rotorcraft UAS s weighing less than 55 pounds maximum gr o ss weig h t: DJ I P h antom 2 Vision+ Unmanned Aircraft S ys tem . Proposed operations of an y other aircraft w ill 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 photograph y. 3. The UA s may

not be flown at an indicated airspeed exceedin g 20 knots. 4. The UA must be operated at an altitude of no more than 5 00 feet above ground level (AGL), as indicated by the procedures specified in the operating documents unless a special request is made and approved b y ATC . All altitudes reported to ATC must be in feet AGL. 5. The UA must be operated within visual line of sight (VLOS) of th e PI C at all times. This requires the PIC to be able to u se human vision unaided by an y device other than corrective lenses, as sp eci fied on the PI C ’ s FAA

- issued airman medical certificate.23 6. The use of first person view (FPV) b y the PI C or safet y observer (S O) is not permitted. 7. All operations must utilize a safet y observer (SO). The S O may be used to satisfy the VLOS requiremen t as long as the PIC alway s maintains VL OS capability

. The S O and PI C 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 tran sfer his or her designation for the duration of the flight . The PI C must ensure that the S O can perform the functions prescribed in the operating documents. 8. The S O must not perform any other duties bey ond assisting the PI C 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 gran t of exemption must be accessible during UAS operations and made available to the Administrator upon request. If a discrepancy

exists between the conditions and limitations contained in the grant of exemption and the procedures outlined in the operating do cuments, the conditions and limitations contained 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 doc uments. 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 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, then the operator must petition for amendment to its grant of exemption. The FAA’s UAS I ntegration Office (AFS

- 80) m ay be contacted if questions arise regarding updates or revisions to the operating documents. 10. Prior to each flight the PIC must inspect the UAS to ensure that it is in a condition for safe flight. If the inspection reveals a condition that affects th e 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. Al l maintenance and alterations must be properl y 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 un dergo a functional test flight. The PI C 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 equipment, not a lread y covered in the relevant sections of the operating documents.24 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, inspections, and record keeping requirements, in accordance with the operating documents. 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 the authorized person returning the UAS to service. 15. Each UAS s operated under this exemption must comply with all manufacturer Safety Bulletins. 16. The authorized person must make an e ntry in the aircraft record of the corrective action taken against discrepancies discovered between inspections. 17. The PI C must possess at least a private pilot certificate and at least a current t hird - class medical certificate. 18. The operator may not permit any PIC to operate unless the PI C meets the operator’s qualification criteria and demonstrates the ability to safel y operate the UAS in a manner consistent with how the UAS will be operated under the exemption, including evasive and emergency m aneuvers 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. § 61.51(b). Flights for the purposes of training the operator’s PICs are perm itted under the terms of the exemption. However, training operations may only be conducted during dedicated training sessions. During training, proficiency , and experience -building flights, all persons not essential for flight operations are considered non participants, and the PI C 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. § 1.1. All operations must be conducted unde r visual meteorological conditions (VMC) . If flight at night is required, a special request will be made at the FAA office closest to proposed area of operations. Flights under special visual flight rules (SVFR) are not authorized. 20. The UA may

not operate within 5 nautical 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 must be made available to the Administrator upon request.25 21. The UA may

not be operated less than 500 feet below or less than 2,000 feet horizontally

fro m a cloud or when visibility is less than 3 statute miles from the PI C.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. The PI C must abort the flight in the event of unpredicted obstacles or emergencies in accordance with the operating documents. 24. The PI C is prohibited from beginning 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 Organization (ATO) issued Certificate of Waiver or Authorization (COA) prior to conducting an y operations under the grant of exemption. T his COA will also require the operator to request a Notice to Airman (NOTAM) not more than 72 hours in advance, but not less than 48 hours prior to the operation. All operations shall be conducted in accordance with airspace requirements in the ATO issued COA including class of airspace, altitude level and potential transponder requirements. 26. All aircraft operated in accordance with the exemption must be identified by serial number, registered in accordance with 14 C.F.R. part 47, and have identificati on (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 frequency spectrum used for operation and control of the UA must comply with the Federal Commun ications Commission (FCC) or other appropriate government oversight agency requirements. 28. The documents required fewer than 14 C.F.R. 91.9 and 91.203 must be available to the PIC at the Ground Control Station of the UAS an y 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 yi eld the right of way to all manned aviation operations and activities at all times. 30. The UAS may

not be oper ated by the PIC fro m any moving device or vehicle. 3 1. Flight operations must be conducted at least 500 feet from all nonparticipating person s (persons other than the PI C, S O, operator trainees or essential persons), vessels, vehicles, and structures unle ss:26 a. Barriers or structures are present that sufficiently protect nonparticipating persons from the UA and/or debris in the event of an accident. The operator must ensure that nonparticipating persons remain under such protection. If a situation arises where nonparticipating persons leave such protection and are within 500 feet of the UA, flight operations must cease immediately

and/or; b. The aircraft is operated near vessels, vehicles or structures where the owner/controller of such vessels, vehicles or s tructures has granted permission and the PI C has made a safet y 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 PI C, SO, operator trainees or essential p ersons do not present an undue hazard to those persons 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 representative. Permission from land own er/controller or authorized representative will be obtained for each flight to be conducted. 3 3 . Any incident, accident, or flight operation that transgresses the lateral or vertical boundaries of the operational area as defined by the applicable COA mus t be reported to the FAA's UAS Integration Office (AFS

- 80) within 24 hours. Accidents must be reported to the National Transportation Safet y 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.** THAYER ENTERTAINMENT submits that the equivalent level of safet y established by Section 61.113 (a) and (b) will be maintain ed because no PI C wil l be allowed to operate the DJ I Ph antom 2 Vision+ UAS u n less that PI C has d emonstrated, b y meeting minimum flig ht -ho ur and currency r equirements, that the PI C is able to safely

o p erate th e DJ I P hantom 2 Vision+ UA S in a manner consistent with the ex emption, including evasiv e and emergency maneuvers and maintaining ap p ropriate dis tances from people, vessels, vehicles and structures. C onsidering THAYER ENTERTAINMENT's p r o posed area of operations, and the operating l imitations set fo rth -above; the parallel nature of private pilot aeronautical27

knowledge requirements to those of commercial pilot requirements ( See Exemption No. 1 1062); and the airmanship skills necessary to safely o p erate the DJ I Phantom 2 Vision+ UAS, THAYER ENTERTAINMENT submits that the additional manned air manship experience of a co mmercially certificated pilot would not co rr elate to the airmanship skills necessary for THAYER ENTERTAINMENT's spec ific 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, 11065, 11066, 11067, 11080, 11109, 11110, 11112, 11136, 11 138, 11150, 11153, 11156, 11158, 11159, 11160, 11161). THAYER ENTERTAINMENT will not allow any PIC to operate the DJ I P hantom 2 Vision+ U AS unless that PI C has demonstrated, by meeting minimum flight -hour requirements or the D J I P hantom 2 V ision+ UAS train ing and currency requ irements, that the PI C is able to safely operate the DJ I Ph antom 2 Vision+ UAS in a manner consistent with this exemption, including evasive and e mergency maneu vers and main taining
ap p r opriate distances from peo ple, v essels, veh icles and structures.

Specificall y, the PI C must have 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 operating the same make and model of UAS to be used for operations under the exemption). In addition to the hour requirements, the PI C must accomplish 3 takeoffs and landings in the preceding 90 day s (for currency
purpose s).28 As in Ex emption Nos. 11062, 11138, and 11153, prior documented flight experience that was obtained in compliance with applicable regulations will ensure an equivalent level of safet y during THAYER ENTERTAINMENT's proposed operations. The Administrator has 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 have accumulated and logged, 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 ope rations under Exemption No. 11062, the PI C must also have 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 FAA considers these minimum hour requirements to be inclusive rather than additive; i.e. 5 hours make and model time may be included in the 10 hours of multi

- rotor time and the 10 hours may be included in the total 25 hours of UAS rotorcraft time. In addition to the hour requirements , the PI C must accomplish 3 takeoffs and landings in the preceding 90 day s (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 necessa ry

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 experience

- building flights the PI C is required to operate the UA with appropriate distances in accordance with 14 C.F.R 91.119. Exemption No. 11138 at page 15. Accordingl y, THAYER ENTERTAINMENT will ensure safe operations by not allowing
any PIC to operate the DJI Phantom 2 Vision+ UAS unless that PI C has demonstrated, b y meeting minimum flight

- hour and currency requirements, that the PI C is able to safel y operate the DJI Ph antom 2 Vision+ UAS in a manner consistent with the exemption, including evasive and emergency maneuvers and maintaining appropriate distances from people, vessels, vehicles and structures.29 **3. Reasons Why An Exemption From The Requirements Of Section 91.7(a) Would Not Adversely Affect Safety.**  The equ iv alen t level of safet y established b y Section 91.7(a) will b e maintained b ecause prior to every f

light, THAYER ENTER TAINMENT will ensure that the DJI Phantom 2 Vision+ U AS is in an airworth y condition based upon the UAS’s compliance with its operating documents and as stated in the condi tio n s and limitations herein

. Additionally , the FAA has 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 eq u iv alen t level of safet y estab lished b y Section 9 1

. 1 2 1 will be maintained because the altitude information of the DJ I P h antom 2 Vision+ UA will be provided to the
PI C via GPS equipmen t and a radio commu nications telemetry d ata link, which d own links from the UA to th e GCS for active monitoring of the flight p ath and altitude. This altitude information, combined with THAYER ENTERTAINMENT's opera tion of the DJ I Phanto m 2 Vision+ U A within vis ual line of sight, at or below 500 feet AGL, will ensure a level

o f safet y equivalent to Section 91.121. The altitude i nformation will be generated b y GPS equipment installed o nboard the air craft. Prior to ea ch f ligh t, a zero altitude initiation point is au to matically established b y th e UAS s at gr ound level.

The FAA has previously

granted relief from Section 91.121 specific to UAS, in circumstances similar, in all material respects, to those presented herein (e.g. Exemption30

Nos. 11062, 11063, 11064, 11065, 11066, 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 91.151(b) as a result of (1) the technical specifications of the DJ I Phantom 2 Vision + UAS ; ( 2) the limitatio ns on the proposed flight operations; and (3 ) the location o f the proposed flight operations. Accordingl y, THAYER ENTERTAINMENT will ensure that it will safely o perate the battery p o wered DJ I Phantom 2 Vision+ UA d uring day light hours in V FR conditions, with enough b attery p o wer to fly f o r a total duration of 13.5 minutes to the first point of intended land ing and, assuming normal cruising speed, to fly after that for at least 4.5 minutes. Here, as in Exemption No. 11109, the technical spec ifications of the DJ I P h antom 2 Vision+ UAS ; the limitations on the proposed flight operations; and the l o cation of the proposed operations, will ensure an equivalent level of safety established b y 14 C.F.R. Section 91.151(b). Furthermo re, safety will b e ensured as the DJI Phantom 2 Vi sion+ UAS provide audible and visual warnings to th e PI C at the GC S when the UA s experiences low battery v oltage, the f irst warning occurring at approximately 33% r ema in in g battery p o wer, and again at ap p r oximately 10% remaining battery power. A t the critically low battery level, the DJ I Phantom Vision+ UAS will descend and la n d au tomatically

.

Significantl y, previous exemptions granted b y the FAA concerning Section 91.1 51 establish that safet y is not adversel y affected when the technical characteristics and operating limitations of the UAS are considered. Relief has been granted for manned31

aircraft to operate at less than the minimums prescribed in Section 91.151, includ ing 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, 110 62, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 11136, 11138, 11150, 11153, 11156, 11157, 11158, 11159, 11160, 11161). **6. Reasons Why An Exemption 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, THAYER ENTERTAINMENT submits that the equivalent level of safety with regard to the regulatory maintenance an d alter ation

r equirements established by Sections 91.405(a), 91.407(a)(1), 91.4 09 ( a)(1) & (a)(2), and 9 1.417(a) & (b) will be met because THAYER ENTERTAI NMENT will use trained technicians to perform ma in tenance, alterations, or preventive maintenance on the UAS using the methods, te ch niques, and practices prescribed in the operating d ocumen ts (i. e., the THAYER ENTERTAINMENT Aerial Operations Manual, Monthly Maintenance Lo g, and DJI Ph antom 2 Vision+ I nstr u ction Manual)

. Fu rth ermore, THAYER ENTERTAINMENT will document and maintain all maintenance records for the DJ I P hanto m 2 Vision+ UAS

. Sin ce the DJ I Phan

t om 2 Vision+ UAS will be inspected as p rescrib ed b y the

o p erating documents, THAYER ENTERTAINMENT will main tain the equivalent level of safet y estab lished by Sections 91.405(a) , 91.40 9(a)( 1 ) , and 9 1.409(a)(2). A cop y of th e DJ I P hantom 2 Visio n+ User Manual are attached hereto as Exhibit B ; a cop y of the DJI Phan tom 2 Vision + UAS Maintenance LOG is attached hereto as Exhibit C

.32 Likewise, the exemption sought will not adversel y affect safety because THAYER ENTERTAINMENT will use trained technicians to perform maintenance, alterations or preventive maintenance on the UAS using the methods, techniques, and practices prescrib ed by the operating documents. Furthermore, the exemption sought would maintain an equivalent level of safet y established by Sections 91.407, 91.417(a) and 91.417(b), because all maintenance of the DJI Phan tom 2 Visio n + UAS will be pe r formed b y trained technicians. Maintenance will b e d ocument ed and maintained utilizing the monthly maintenance log. Significantl y, previous exemptions granted b y the FAA concerning Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & ( b) establish that safet y is not adversel y affected when the technical characteristics and operating limitat ions of the UAS are considered. In consideration of THAYER ENTERTAINMENT's proposed operating limitations, the operating docu ments, and the technical aspects of the D J I P hanto m 2 Vision+ U AS , THAYER ENTER TAI NMENT submits that safety will not be ad versel y affected by granting exemption from 14 C. F.R. Sections 9 1 .405(a), 91.407(a)(1) and (a) (2), 91. 409(a)(2), and 91.417(a) an d (b)

. Th e FA A h as previously granted relief 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). **7 .**  **The FAA May Prescribe Any Other**  **Conditions For Sa**  **fe 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 , THAYER ENTERTAINMENT33

requests that the FAA prescribe special conditions for the intended operation of the DJ I Ph antom 2 Vision+ UAS , which contain such safet y stand ards that the Ad min istrator finds

n ecessary to establish a lev el of safet y equiv alent to that established b y 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)(1), 91.409( a)(1) & (a)(2), and 91.417(a) & (b). Such special conditions will permit safe operation of the UA s for the limited pu rpose of conductin g aer ial v id eo and photography over certain areas of the United States for

co mp ensation or hire. FMRA Section 333 sets forth the requirements for con sider ing whether a UAS will create a hazard to user s of the NAS or the public, or otherwi se pose a th r eat to national security; and further, provides the authority f or such UAS to op erate without airworthiness certification in accordance with an y requirements that must be established for the safe o peration 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 DJ I P h antom 2 Vision+ UAS , since the airworthiness regulations of 14 C.F.R. Part 21 do not contain adequate or appropriate safet y standar ds, 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 safet y standards for an aircraft, aircraft engine, or propeller because of a novel or unusual design feature of the aircraft, aircraft engine or p ropeller, 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 find s necessary

to establish a level of safety equivalent to that established in the regulations. See 14 C.F.R. § 21.16.34 Ther ef o r e, in accordance with FMRA Section 333 and 14 C.F.R. § 21.16, the FA A
may p r escribe special conditions for THAYER ENTERTAINMENT ’s intende d operation

o f the DJ I Phantom 2 Vision+ UAS , which contain such safet y standards that the Administrator finds necessary to establish a level of safet y eq u ivalent to that establish ed b y 14 C.F.R. Part 21, Subpart H, and 14 C.F.R Sections 6 1 .113(a) & ( b ) , 91.7(a), 91.121, 91.151(b), 91 .405(a), 91.407(a)(1), 91.40 9 (a)(1) & (a) ( 2 ), and 91.417(a) & (b).
**F. A Summary That Can Be Published In The**  **Federal Register, stating: The Rules**  **From Which** THAYER ENTERTAINMENT **Seeks Exemption:** THAYER ENTERTAINMENT seeks exemption from the requirements of 14 C.F.R Sections 61.113(a)& (b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 9 1.409(a)(1) & (a)(2), and 91.417(a) & (b). **A Brief Description Of The Nature Of The Exemption** THAYER E NTERTAINMENT **Seeks:** This exemption will permit THAYER ENTERTAINMENT t o commercially o p era te an Unmanned Aircraft System (UAS) for the purpose of conducting aerial video and photograp hy over certain areas of the United States. **G. Any Additional Information, Views, Or Arguments Av**  **ailable To Support** T HAYER ENTERTAINMENT's **R equest.**  This Petition is made pursuant to the FAA Modernization and Reform Act of 2012 (F MRA) Section 333, which directs the Secretary of Transportation to determine if certain UAS may operate safely in the NAS. As such, THAYER ENTERTAINMENT'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 considering whether a UAS will create a hazard to users of the NAS or the public, or otherwise pose a threat to national securit y; and further, provides the authority for such UAS to operate witho ut airworthiness certification.35 As discussed in detail above, THAYER ENTERTAINMENT will operate the DJ I Phantom 2 Vision+ UAS safel y in the NAS, without creating a hazard to users of the NAS, or the public, or otherwise pose a threat to national securit y. **CONCLUSION** As set forth herein, THAYER ENTERTAINMENT seeks an exemption C.F.R. pursuant to 14 § 11.61 and Section 333 of the FAA Modernization and Reform Act of 2012 (FMRA), which will permit safe operation of the DJI Phantom 2 Vision+ UAS commercially, without an airworthiness certificate, for the limited purpose of conducting aerial video and photography over certain areas of the United States. By granting this Petition, the FAA Administrator will be fulfilling the Congressional mandate o f the FAA Modernization and Reform Act of 2 0 12, while also advancing the interests o f the p ublic, by allowing THAYER ENTERTAI NMENT to safel y, efficientl y, an d economically operate th e DJ I P hantom 2 Vision+ UAS commercially within the NAS. **WHERE FORE**  , in

acco rdance with the Fed eral Aviation Regulations and the FAA Modernization a nd Reform Act of 2012, Section 333, THAYER ENTERTAINMENT respectfull y req uests that the Ad min istr ator grant this Petition for an exemption from the requirements of 14 C.F.R Sections 61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 91 .4 05 (a), 91.407( a) (1 ), 91.409(a) (1) & ( a)(2), an d 91.417(a) & (b), and permit L eading Edge to operate the DJ I Phantom 2 Vision+ UAS commerciall y for the purpose of conducting aerial video and photography

o v er certain areas of th e United States. Dated: Ma y 2 4 , 201536 Respectfully submitted, THAYER ENTERTAINMENT /s/ Ro b ert G. Thayer

_________________________ Robert Thayer 2 5290 Calvert Dr Greensboro, MD 21639 Tel: ( 44 3) 25 3

- 1716

Appendic es : A

– DJ I Phan tom 2 Vision+ Specification s Data Sheet B – DJI Phantom 2 Vision+ Manufacturer’s User Manual C – Monthly Maintenan ce Log37 APPENDIX – A **DJI PHANTOM 2 VISION+ TECHNICAL SPECIFICATIONS**  THAYER ENTERTAINMENT only utilizes safe and reliable UASs. DJI is an ind ustry leader in small UAS production. DJI UASs are loaded with ground breakin g software enabling the u ser

to set p arameters which will not allow flight into contr olled airspace. Parameters can also be set to limit flight to no higher than a predetermined and set altitude as well as limit flight to a predetermined and set distance. In addition, DJI software provides real

- time altitude and location information to the PI C via the linked monitor (smart phone/tablet devices) 1.1 DJI Phantom 2 Vision+ 1.1.1 Aircraft 1.1.1.1 Supported Battery

– DJ I 5200mAH LiPo Battery 1.1.1.2 Weight (Battery

& Propellers Included)

– 2lbs 11.810oz (1242g) 1.1.1.3 Hover Accuracy

(Ready to Fl y)

– Vertical: .8m; Horizontal: 2.5m 1.1.1.4 Max Yaw Angular Velocit y - 200 0 /s 1.1.1.5 Max Tilt Angel - 35 0 1.1.1.6 Max Ascent Speed

– 6m/s 1.1.1.7 Max Descent Speed

– 2m/s 1.1.1.8 Max Flight Speed – 15m/s (NOT RECOMMEND ED) 1.1.2 Gimbal 1.1.2.1 Working Current

– Static: 750mA; Dy namic: 900mA 1.1.2.2 Control Accuracy

- ±0.03 0 1.1.2.3 Controllable Range

– Pitch: -90 0 - 0 0 1.1.2.4 Maximum Angular Speed

– Pitch: 90 0 /s 1.1.3 Camera 1.1.3.1 Operating Temperature Range - 32 0 F - 104 0 F (0 0 C - 40 0 C) 1.1.3.2 Sensor Size

– 1/2.3” 1.1.3.3 Effective Pixels – 14M 1.1.3.4 Resolution – 4384x3288 4.1.3.5 HD Video Recording

– 1080p30 & 720p 4.1.3.6 Recording Field of View - 110 0 /85 0 1.1.4 Transmitter 1.1.4.1 Operating Frequency

– 5.728GHz

– 5.85GHz 1.1.4.2 Communication Distance (unobstructed) – FCC Compliance: 800m 1.1.4.3 Receiver Sensitivity (1%PER)

- - 93dBm 1.1.4.4 Transmitter Power – FCC Compliance: 100mW 1.1.4.5 Working Voltage

– 120mA@3.7V 1.1.5 Range Extender38 1.1.5.1 Operating Fre quency

– 2412

- 2462MHz 1.1.5.2 Communication Distance (unobstructed)

– 500

- 700m 1.1.5.3 Transmitter Power

– 20dBm 1.1.5.4 Power Consumption

– 2W41 APPENDIX

–

B DJI Phantom 2 Visio n + Manufacturer ’s User Manual

See Seperate Attached PDF43 APPENDIX

–

C

m o n t h :

_ _ _ _ _ _ _ _ _ ( y e a r :

_ _ _ _ _ _ _ _ **UAS$#:$___________** Date(Issue( Discovered Date(Issue(

Addressed Software(Updates
Airframe(
Engines
Propellers
Camera(Gimbal
Landing(Gear
Vibration(Dampening

Other: **M O**  **N T**  **H L**  **Y $**  **M A**  **I N**  **T E**  **N A**  **N C**  **E $** 

**L O**  **G**

Issue(Description(&(Maintenance(Conducted M a i n t e n a n c e ( P e r f o r m e d ( B y : ( ( ( Print(&(Sign