Aviator Cinema for Exemption Page 1

From: Darl D Hanna Aviator Cinema 3715 E Adobe Drive Phoenix Arizona 85050 Tel: 480-699-9606 Email: Houzful@gmail.com

To: Docket Operation Room W12-140 Of the West Wing Ground Floor !200 New Jersey Avenue, Se Washing DC, 20590

PETITION FOR EXEMPTION OF : UAV Aerial Video FOR A N EXEMPTION SEEKING RELIEF FROM THE REQUIREMENTS OF

TITLE 14 OF THE CODE OF FEDERAL RE GU L A T IONS P A R T 21, SUB P

A R T H AN D SECTIONS §§ 61.113(a) & (b), 91.109, 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 COMM E RCIA L OPERATION OF DJI PHANTOM 2 VISION+ UNMANNED AIRCRAFT SYS TE MS PURSUANT TO SECTION 333 OF THE F AA MODERNIZATION AND REFORM ACT OF 2012

(PUBLIC LAW 112-95)

Submitted o n June 04 , 2015Aviator Cinema for Exemption Page 2 TABLE OF C O N T EN TS

GLOSSARY OF

ABBREVIATIONS.........................................................................................3

SUM MA RY.................................................................................................................................4

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

BACKGROUND.........................................................................................................................4

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

NAME AN D ADDRESS OF PETITIONER...............................................................................7

THE SPECIFIC SECTIONS OF 14 C.F.R. FROM WHICH UAV AERIAL VIDEO SEEKS

EXEMPTION..............................................................................................................................8

THE EXTENT OF RELIEF UAV AERIAL VIDEO SEEKS AND THE

REASON UAV AERIAL VIDEO SEEKS THE RELIEF................................................... 11
THE REASONS WHY GRANTING UAV AERIAL VIDEO REQUEST

WOULD BE IN THE PUBLIC INTEREST ...........................................................................15

THE REASONS WHY GRANTING THE EXEMPTION WOULD NOT

ADVERSELY AFFECT SAFETY.............................................................................................19

SUMMARY TH AT CAN BE PUBLISHED IN THE FEDERAL REGISTER.........................33
ANY ADDITIONAL INFORMATION, VIEWS, OR ARGUMENTS

CONCLUSION.........................................................................................................................33Aviator Cinema for Exemption Page 3 GLOSSARY OF

A BBRE VI A

T IONS

AGL Above Ground Level
AOI Area of Interest
A TC Air T ra ffic Control
ATO Air T ra ffic Organization
AV Aerial Vehicle
CFR Code of Federal Regulations
COA Certificate of Authorization
F AA Federal A vi ation Administration
F AR Federal Aviation Regulation
GCS Ground Control Station
GPS Global Positioning System
LOL Loss of Link
NAS National Airspace System
NO T AM Notice to Airman
PIC Pilot In Command
Section 333 F AA Modernization and Reform Act of 2012 (FMRA) Section 333
SO Safety Observer
SOP Standard Operating Procedures
UA Unmanned Aircraft
UAS Unmanned Aircraft System
VFR Visual Flight Rules
VLOS Visual Line of Site
VMC Visual Meteorological Conditions
VT OL Vertical Takeoff and LandingAviator Cinema for Exemption Page 4 SUMM A RY Aviator Cinema ( Darl D Hanna and George Houston Hanna) seeks exemption from the requirements of 14 C.F

.R §§ 61.113(a) & (b), 91.109, 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 System pursuant to Section 333 of the F AA Modernization and Reform Act of 2012 (FMRA). This exemption will permit Aviator Cinema to operate an Unmanned Aircraft System (UAS) for the commercial purpose of conducting aerial video and photography of Real Estate Properties (for homeowners, realtor's , home builders, home contractors and / or home inspectors for real estate marketing and inspection of home exteriors) as well as filming of special events, film sets, scripted and unscripted television sets and landscape, conducting power line inspection, aerial

m apping, surveying and search and rescue over certain areas of the United States.

INTRODUCTION AND INTERESTS OF THE P ETITI O NER

Aviator Cinema is a production company based in Phoenix Arizona specializing in real estate videography

, photography, music video production, special event production and film

. The principals of Aviator Cinema have been in the video and entertainment production business for

one year; Aviator Cinema's objective is to conduct aerial photography and videography in order
to provide high quality digital imaging and video content t o its clients, in particular to homeowners, real estate agents, realtor's , home builders, home contractors, and/or home inspectors for real estate marketin g and inspections of home exteriors as well as filming of special events, film sets, scripted and unscripted television sets and landscape, conducting power line inspection, aerial mapping, surveying and search and rescue utilizing DJI Phantom 2 Vision +. More specifically, UAV Aerial Video aerial video and photography operations will serve in the following areas:

• Ae rial photography of houses / residential and commercial buildings and power lines

• Aerial videography of houses / residential and commercial buildings and power lines

• Aerial event photography

• Aerial event filming

• Aerial Film & Television productionAviator Cinema for Exemption Page 5

• Aerial search and rescue and safety in spections

• Increase public knowledge of UAS and promote safe UAS operations.Aviator Cinema for Exemption Page 6

The proposed aerial filming will be conducted over private property with controlled access in the NA S and with the knowledge and permit of the private property ’ s owner.

Unmanned Ai rcraft Systems: DJI Phantom 2 Vision+, Phantom 3 Professional UAS

Aviator Cinema seeks an exemption to operate DJI systems DRONES for compensation or hire within the NAS. The DJI Phantom 2 Vision+ are vertical takeoff and landing (V TOL) Unmanned Aircrafts (UAS) with a Ground Control Station (GCS) utilizing electronic tablet or smart phone systems. The DJI Phantom 2+, have a maximum gross weight of approximately 2 pounds 11 ounces, while ha ving a length of 16 inches width of 16 inches, height of 8 inches, and a maximum speed of approximately 29 knots. The DJI Phantom 2 Vision+,are equipped with four main rotors; driven by Lithium Polymer battery powered electri c motors.

The DJI Phantom 2 Vision+, that will be operated by Aviator Cinema are (trained professional), 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.

BASIS FOR PETITION

Petitioner, Aviator Cinema , pursuant to the provisions of the Federal Aviation Regulations (14 C.F.R. § 11.61) and the F AA Modernization and Reform Act of 2012 (FMRA), Section 333, Special Rules for Certain Unmanned A i rcraft Systems , hereby petitions the Administrator to commercially operate the DJI Phantom 2 Vision+ in the National Airspace System (NAS), and for an exemption from the requirements of 14 C.F

. R

§§ 61.113(a) & (b), 91.109, 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).

In consideration of the speed, weight, size, and limited operating area associatedUAV Aerial Video for Exemption Page 7

with the unmanned aircraft and its operation, Aviator Cinema operation of DJI Phantom 2 Vision+, meets the conditions of FMRA Section 333 and therefore, will not require an airworthiness certificate in ac cordance with 14 C.F.R. Part 21, Subpart H. Accordingly, Aviator Cinema requests relief from Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b), as these sections set forth requirements for maintenance that only apply to aircraft with an airworthiness certificate. Aviator Cinema submits that the requested relief is proper since an equivalent level of safety will be ensured. Aviator Cinema will use experienced personnel or technicians to perform maintenance, alterations, or preventive maintenance on the UAS ’ s using the methods, techniques, and practices prescribed in the operating documents (i.e., Monthly Maintenance Log, and DJI Phantom 2 V ision+, Instruction Manual). Furthermore, Aviator Cinema wi ll document and maintain all maintenance records for the DJI Phantom 2 Vision+

.
Relief from certain requirements of Section 61.113(a) and (b), entitled Private pilot privileges and limitations : Pilot In Command, is requested by Aviator Cinema to the extent necessary to allow a Pilot in Command (PIC) holding a Supplemental Pilot Certificate, and who has demonstrated, by meeting minimum flight- hour and currency requirements, that the PIC is able to safely operate the DJ I Phantom 2 V ision+, in a manner consistent with this exemption, including evasive and emergency maneuvers and maintaining appropriate distances from people, vessels, vehicles and structures.

Aviator Cinema seeks relief from Section 91.7(a), entitled Civil aircraft airworthiness , because the DJI Phantom 2 Vision+, do not require an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H. As such, Aviator Cinema submits that it will ensure that the Phantom 2 Vision+UAS are in an airworthy condition, prior to every flight, by determining that the UAS ’ s are in compliance with the operating documents (i.e., Monthly Maintenance Log, and DJI Phantom 2 V

ision+, Instruction Manual), and that the aircraft are in a condition for safe flight. Aviator Cinema also seeks an exemption from the requirements of SectionAviator Cinema for Exemption Page 8

91.121, entitled Altimeter Settings , a s the DJI Phantom 2 Vision+, UAS will not have a typical barometric altimeter onboard. However, altitude information of the DJI Phantom 2 V ision+, will b e provided to the PIC via Global Positioning System (GPS) equipment and ra dio communications telemetry data link, which down-links from the UA to the GCS for active monitoring of the flight path. This altitude information, combined with Aviator Cinema s operation of the DJI Phantom 2 Vision+, within visual line of sight, at or below 200 feet AGL, will ensure a level of safety equivalent to Section 91.121.

Additionally, Aviator Cinema seeks an exemption from the requirements of Section 91.151(b), entitled Fuel requirements for flight in VFR conditions. Aviator Cinema submits that safety will not be affected by operation of the DJI Phantom 2 V ision+ , 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, UAV Aerial Video provides the following information in support of its petition for exemption:

A. Name And Address Of The Petitioner.

The name and address of the Petitioner and point of contact is: Darl D Hanna Aviator Cinema 3715 E Adobe Drive Phoenix Arizona 85050
T el: 480-699-9606 Email: houzful@gmail.comAviator Cinema for Exemption Page 9

B. The Specific Sections Of 14 C.F.R. From Which UAV Aerial Video Seeks Exemption. 1. Aviator Cinema 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 certifica te 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 ma y, 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. Aviator Cinema 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.

3. Aviator Cinema 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 , 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)(1)(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.Aviator Cinema for Exemption Page 10

4. Aviator Cinema Seeks Exemption From The Requirements Of Section 91.151(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. Aviator Cinema 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[.]

6. Aviator Cinema 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) N o 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. Aviator Cinema Seeks Exemption From The Requirements Of Sections 91.409(a)(1) An d 91.409(a)(2). Secti o n 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 ac cordance with part 43 of this chapter and hasAviator Cinema For Exemption Page 11 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. Aviator Cinema 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 §§ 91.41 1 and 91.413, eac h 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) a nd

eac h 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 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 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 theAviator Cinema for Exemption Page 12 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 reta in the following records for the periods prescribed: (1) The records specified in paragraph (a)(1) of this section shall be retained until the work is repeated or superseded by other work or for 1 year after the work is performed. (2) The records specifi ed 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 defec ts are repaired and the aircraft is approved for return to service.

C. The Extent Of

Relief UAV Aerial Video Seeks And The Reason UAV Aerial Video Seeks The Relief. 1. Extent Of Relief Aviator Cinema Seeks And The Reason UAV Aerial Video

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 Supplemental Pilot Certificate, 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 ma y , for compensation or hire, act as PIC of an aircraft in connection with any business or employment if: (1) The flight is onlyAviator Cinema f or Exemption Page 13 incidental to that business or employment; and (2) The aircraft does not carry passengers or property for compensation or hire. As set forth more fully below, UAV Aerial Video submits that an equivalent level of safety will be maintained because no PIC will be allowed to operate the DJI Phantom 2 Vision+, Phantom 3 Professional UA 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+, Phantom 3 Professional 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 , UAV Aerial Video submits that all flights of the DJI Phantom 2 Vision+, Phantom 3 Professional UAS, conducted by the PIC pursuant to the grant of this Petition: (1) will be incidental to UAV Aerial Video business; and (2) will not carry passengers or property for compensation or hire.
UAV Aerial Video believes that though UAS are not traditional aircrafts, a PIC operating the UA

must have knowledge of

Airman rules, basic Airspace and comply with all the rules proposed by the FAA. However, considering the fact that a UA is almost like a to y, weighing less than a skinny person, the PIC may be except from obtaining a Private Pilot Certificate, a Sports Certificate, a Recreational Certificate considering these certificates require flight hours of several thousand tons weighing aircrafts. The operation of UAS by UAV Aerial Video is strictly for entertainment / informational purposes, thus the operators of the UAS have a career and / or freelance employment as a Camera Operator and Cinematographer and will be not be entertaining a career as a pilot. Lastly, UAV Aerial Video PICs will operate the UAS no higher than 2 00 feet, consequently causing no danger do any other aircraft in the NAS. However , UAV Aerial Video Proposes PIC Certification as a Supplemental pilot and a minimum requirement of successfully completed private pilot ground school. Additionally, supplemental pilots without a current F AA private pilotAviator Cinema for Exemption Page 14 certificate must have successfully passed the private pilot, commercial pilot, or airline transport pilot knowledge test within the past 24 calendar months. 2. Extent Of Relief Aviator Cinema Seeks And The Reason UAV Aerial Video Seeks Relief From Section 91.7(a). Relief from Section 91.7(a) entitled Civil aircraft airworthiness, is requested to the extent required to allow UAV Aerial Video to determine that the DJI Phantom 2 Vision+, are in airworthy condition prior to every flight by ensuring that the UAS is in compliance with the operating documents (i.e., the Aviator Cinema Operations Manual, Monthly Maintenance Log, and DJI Phantom 2 Vision+, Instruction Manual). Aviator Cinema seeks the requested relief because the DJI Phantom 2 Vision+ do not require an airworthiness certificate in accordance with 14 C

. F .R. Part 21, Subpart H. Therefore, Aviator Cinema will ensure that the DJI Phantom 2 V

ision+ is in airworthy condition based upon its compliance with the operating documents (i.e., Monthly Maintenance Log, and DJI Phantom 2 V ision+, 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 Aviator Cinema Seeks And The Reason Aviator Cinema 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 V ision+, UAS, which utilize a barometric pressure sensor, GPS equipment, and a radio communications telemetry data link
to down link altitude information from the UA to the PIC at the ground control station (GCS). Since the F AA requires that any altitude information concerning UAS operations be reported to air traffic control (ATC) in feet above ground level (AGL), Aviator Cinema seeks the requested relief because th e DJI Phantom 2 Vision+, UA ’ s altimeter may be set on the ground to zero feet AGL, rather than the local barometric pressure or fieldAviator Cinema for Exemption Page 15

altitude, before each

flight.Considering the limited altitude of the proposed operations, relief from 14 CFR 91.121 is so ught 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+, 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-u p display of the GCS.

4. Extent Of Relief Aviator Cinema Seeks And The Reason Aviator Cinema Seeks Relief From Section 91.151(b). Relief from Section 91.151(b) entitled Fuel requirements for flight in VFR conditions, is requested to the extent required to allow flights of th e battery powered DJI Phantom 2 V ision+, 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. UA V Aerial Video 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+ will severely constrain the practicality of any aerial video or still photo flight operations that Aviator Cinema proposes to conduct pursuant
to this Petition. Significantly, as set forth below, the technical specifications of the DJI Phantom 2 Vision+ UAS operating documents, and Aviator Cinema proposed operating limitations, ensure that Aviator Cinema will safely operate the battery powered DJI Phantom 2 Vision+ UAS during dayligh t 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.Aviator Cinema for Exemption Page 16

! ! 5. Extent Of Relief Aviator Cinema Seeks And The Reason Aviator Cinema

Seeks Relief From Section 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), And 91.417(a) & (b). Since Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b) only apply to aircraft with an airworthiness certificate, Aviator Cinema requests relief from these Sections because the DJI Phantom 2 Vision +, UAS do not require airworthiness certificates. As set forth more fully below, the DJI Phantom 2 Vision+, meet the conditions of FMRA Section 333 for operation without an airworthiness certificate. Accordingly, Aviator Cinema will use trained technicians to perform maintenance , alterations, or preventive maintenance on the UAS using the methods, techniques, and practices prescribed in the UAS operating documents (i.e., the Aviator Cinema Aerial Operations Manual, Monthly Maintenance Log, and DJI Phantom 2 Vision+, Instruction Manual). Furthermore, Aviator Cinema will document and maintain all maintenance records for the DJI Phantom 2 Vision+.

D. The Reasons Why Granting Aviator Cinema Request W ould Be In The Public Interest; That Is, How It W ould Benefit The Public As A Whole. Granting the present Petition will further the public interest by allowing UA V Aerial Video to safel y , efficientl y , and economically perform aerial video and photography of real estate, special events, film sets, and landscape over certain areas of the United States. Additionally, use of the DJI Phantom 2 Vision+, will decrease congestion of the NAS, reduce pollution, and provide significant benefits to the economy. No tably, the benefits of Aviator Cinema' s proposed operation of the DJI Phantom 2 Vision+, will be realized without implicating any privacy issues.

1. The Public W

ill Benefit From Decreased Congestion Of The NAS.Aviator Cinema for Exemption Page 17 The DJI Phantom 2 Vision+, is battery powered and serve as a safe, efficient, and economical alternative to the manned aircraft traditionally utilized to obtain aerial imagery. B y reducing the amount of manned aircraft needed to perform aerial acquisitions, a n exemption allowing the use of a DJI Phantom 2 V ision+ 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+ 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 Wi ll Benefit From The Safety And Efficiency Of The DJI Phantom 2 Vision+. Conducting aerial acquisitions with the DJI Phantom 2 Vision+, 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. B y using battery power and electric motors, the DJI Phantom 2 Vision+ 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 leade d aviation fuel. The DJI Phantom 2 Vision+ , 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+ to perform aerial acquisitions, the substantial risk to life and property in the air andAviator Cinema for Exemption Page 18 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+(weighing approximately 2 pounds 11 ounces ) at its maximum gross weights with lengths of 16 inches and 17.3 inches and with no fuel on board), has less physical potential for collateral damage to life and property on the ground, and in the ai r, 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+, Wi ll Benefit The Economy. In addition to being safe and efficient, the DJI Phantom 2 Vision+, is also an economical alternative to using manned aircraft to conduct similar aerial operations. As such, operation of the DJI Phantom 2 V ision + will allow United States based companies, like Aviator Cinema , to remain competitive and contribute to growth of the U.S. economy. Specifically, with the rising cost of aviation fuel and the Environmental Protection Agency (“E P A”) regulatory actions phasing out leaded aviation fuels, U.S. owned and operated companies must adopt new and alternative technology in order to remain competitive. Operating th e battery powered DJI Phantom 2 Vision+, is one such technology that not only allows companies greater operational flexibility compared to manned aircraft, but provide s such flexibility without the high operational cost of a traditional manned aircraft. By operating the DJI Phantom 2 V ision, companies such as Aviator Cinema , c an 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 financialAviator Cinema for Exemption Page 19 performance of U.S. companies, through commercial use of the DJI Phantom 2 Vision + , 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, Aviator Cinema proposed operation of the DJI Phantom 2 Vision+ will not implicate any privacy issues. Specifically, the DJI Phantom 2 Vision+, will be operated only in compliance with operating documents (i.e., the Aviator Cinema Aerial Operations Manual, Monthly Maintenance Log, and DJI Phantom 2 Vision+, Instruction Manual) which requires property owner involvement as well as local law enforcement notification, and in accordance with the Federal A

viation Regulations, including the minimum altitude requirements of 14 C.F.R. § 91.119.

E. The Reasons Why Granting The Exemption W ould Not Adversely Affect Safet y , Or How The Exemption W ould Provide A Level Of

Safety At Least Equal T

o That Provided B y The Rule From Which UAV Aerial Video Seeks Exemption.

1. Reasons Why The DJI Phantom 2 V ision+, UAS Meet The Conditions Of The F AA 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, Aviator Cinema operation of the DJI Phantom 2 Vision+,UAS meet the conditions of FMRA Section 333, and will not require an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H. 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 security.Aviator Cinema for Exemption Page 20

Specifically, 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 ma y operate safely in the national airspace system before completion of the plan and rule-making required by section 332 of th is 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 an y, as a result of their size, weight, speed, operational capability, proximity to airports and populated areas, and operation within visual line of sight do not create a hazard to users of the national airspace system or the public or pose a threat to national security; and (2) whether a certificate of waiver, certificate of authorization, or airworthiness certification under section 44704 of title 49, United States Code, 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, Aviator Cinema submits that the DJI Phantom 2 Vision +, UAS can operate safely in the NAS pursuant to FMRA Section 333, as demonstrated by: (a) the characteristics of the DJI Phantom 2 Vision+, UAS;
(b) the pilot certification requirement; and (c) the specific operating limitations.

a. The Specifications Of The DJI Phantom 2 Vision+ UAS Demonstrate Its Safe Characteristics.Aviator Cinema for Exemption Page 21 The DJI Phantom 2 Vision+, UAS does not create a hazard to users of the NAS or the public, or otherwise pose a threat to national security considering its size, weight, speed, and operational capability.

i. T echnical Specifications Of Th e DJI Phantom 2 Vision+, UAS. The technical specifications of the DJI Phantom 2 Vision+, UAS is set forth by the DJI Phantom 2 Vision+, Specifications and Data Sheet, attached hereto as Exhibit A.

ii. The DJI Phantom 2 V

ision+, UAS Autonomous Flight And Navigation Modes Enable The UAS T o Remain Within A Defined Operational Area. The DJI Phantom 2 V

ision+,UAS may be operated in both manual and fully autonomous flight modes. A complete description of the flight and navigational modes of the DJI Phantom 2 V ision+, UAS is provided at pages 25-35 of the DJI Phantom 2 V ision+, User Manual, attached hereto

as

.

iii. The DJI Phantom 2 Vision+, UAS A re D e s igne d For Automatic Return T o Home Point Or Hover In The Event Of Loss Of The Control Link Or Navigation. When the Control Link is lost, the DJI Phantom 2 V ision+ UA will remains stationary, in flight, for 3 seconds or more. If, after 3 seconds, the DJI Phantom 2 Vision+ UA does not reacquire control link data from the GCS, the UA will assume that the Control Link is lost and the UA 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 atAviator Cinema for Exemption Page 22 pages 27 through 29 of the DJI Phantom 2 V ision+

.

iv. The DJI Phantom 2 Vision+ GCS And Its Operation. A complete description of the operation and specifications of the DJI Phantom 2 Vision+, and flight control software is provided at pages 32 through 43 of the DJI Phantom 2 Vision+, Professional User Manual. DJI Phantom 2 Vision+ User Manual is attached hereto as Exhibit B & D.

b. Flight Operations Of DJI Phantom 2 Vision+, UAS Are Limited T o The Line Of Sight Of A Certificated Pilot in Command With A Safety Observer. Aviator Cinema will only utilize ce rtificated pilots who possess a current and valid airman medical certificate to act as a pilot in command (PIC) of the DJI Phantom 2 Vision+, UAS. Additionally, a safety observer will a ss i s t all pilots during flight time.

c. Flights Of DJI Phantom 2 Vision+, UAS Wi ll Be Conducted Pursuant T o Specific Operating Limitations. In seeking this exemption, proposes to commercially operate DJI Phantom 2 Vision+ UAS 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, rotor craft UASs weighing less than 55 pounds maximum gross weight: DJI Phantom 2 Vision+, Unmanned Aircraft System. Proposed operations of any other aircraft will require a new petition or a petition
to amend this grant.Aviator Cinema for Exemption Page 23

2. UAS operations under this exemption will be limited to conducting operations for the purpose of aerial video and photography for homeowners, Realtors, home builders, contractors, home inspectors for use in real estate marketing and real estate inspections. Additionally, aerial video and photography may be conducted on occasional basis for film and television sets, special events and landscape photography, conducting power line inspection, aerial mapping, surveying as deemed necessary.

3. The UAS may not be flown at an indicated airspeed exceeding 29 knots (15 m/s).

4. The UAS must be operated at an altitude of no more than 200 (500 per the User Manual) 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 A

TC 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 F AA -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 du ration of the flight. The PIC must ensure that the SO can perform the functions prescribed in

the operating documents.Aviator Cinema for Exemption Page 24

8. The SO must not perform any other duties beyond assisting the 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 limitations contained in the grant of exemption and the procedures outlined in the operating documents, the conditions and limitations contained in the grant of exemption take precedence and must be followed. Otherwise, th e operator must follow the procedures as outlined in

its operating documents. The operator may update or revise its operating documents. It is the operator ’ s responsibility to track such revisions and present updated and revised documents to the Administrator 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 F AA granted th e exemption, 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.

10. Prior to each

flight the PI C must inspect the 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 and t he 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 theAviator Cinema f or Exemption Page 25 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 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, 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 operated under this exemption must 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 discovered between inspections.

17. The PIC must possess at least a Suplemental Pilot certificate and at least a current third- class medical certificate. Supplemental pilots must have, at a minimum, successfully completed private pilot ground school. Additionally, supplemental pilots without a current F

AA private pilot certificate must have successfully passed the private pilot, commercial pilot, or airline transport pilot knowledge test within the past 24 calendar months.

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 operateAviator Cinema for Exemption Page 26

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. § 61.51(b). Flights for the purposes of training the operator ’ s PICs are permitted under the terms of the exemption. However, tr aining operations may only be conducted during dedicated training sessions. During training, proficiency, and experience-building flights, all persons not essential for flight operations are considered nonparticipants, and the PIC must operate the UA with appropriate distance from nonparticipants in accordance with 14 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 under visual meteorological conditi ons (VMC). If flig ht at night is required, a special request will be made at the F AA 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 F

AA -published aeronautical chart unless a letter of agreement with that airport ’ s management is obtained, and the operation is conducted in

accordance with a NO T

AM as required by the operator ’ s COA. The letter of agreeme nt with the airport management must be made available to the Administrator upon request.

21. The UA

may not be operated less than 500 feet below or less than 2,000 feet horizontally from a cloud or when visibility is less than 3 statute miles from the
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 recoveredAviator Cinema for Exemption Page 27

in accordance with the operating documents.

23. The PIC must abort the flight in the event of unpredicted obstacles or emergencies in

accordance with the operating documents.

24. The PIC 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 T ra ffic Organization (AT O) issued Certificate of Waiver or Authorization (COA) prior to conducting any operations under the grant of exemption. This 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 identification (N - Number) markings in accordance with 14 C.F.R. part 45, Subpart C. Markings must be as la rge as practicable.

27. Before conducting operations, the radio frequency spectrum used for operation and control of the UA

must comply with the Federal Communications 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 any time the UAS is operating. These documents must be made available to the Administrator or any law enforcement official upon request.Aviator Cinema for Exemption Page 28

29. The UAS 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 su fficiently 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 situatio n 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 structures 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 essential persons 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 owner/controller or authorized representative will be obtained for each flight to be conducted.

33. Any incident, accident, or flight operation that transgresses the lateral or vertical boundaries of the operational area as defined by the applicable COA must be reported to the FAA's UAS Integration Office (AFS-80) within 24 hours. Accidents must be reported to the National Transportation Safety Board (NTSB) per instructions contained on the NTSB W eb site: ww w.ntsb.gov

.Aviator Cinema for Exemption Page 29

2. Reasons Why An Exemption Fr om The Requirements Of Section 61. 1 13(a) And (b) W

ould Not Adversely Affect Safety.

Aviator Cinema submits that the equivalent level of safety established by Section 61.113(a) and (b) will b e maintained because no PIC will be allowed to operate the DJI Phantom 2 Vision + 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 V ision + UAS in a manner consistent with the exemption, including evasive and emergency maneuvers and maintaining appropriate distances from people, vessels, vehicles and structures. Considering Aviator Cinema proposed area of operations, and the operating limitations set forth-above; the parallel nature of private pilot aeronautical knowledge requirements to those of commercial pilot requirements (See Exemption No. 11062); and the airmanship skills necessary
to safely operate the DJI Phantom 2 Vision+, UAS, Aviator Cinema submits that the additional manned airmanship experience of a commercially certificated pilot would not correlate to the airmanship skills necessary for Aviator Cinema specific proposed flight operations. The F AA 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, 11 109, 1 1 110, 11 1 12, 1 1 136, 1 1 138, 1 1 150, 1 1 153, 11 156, 1 1 158, 11 159, 1 1 160, 11 161).

3. Reasons Why An Exemption Fro m The Requirements Of Section 91.7(a)
W ould Not Adversely Affect Safety. The equivalent level of safety established by Section 91.7(a) will be maintained because prior to every flight, Aviator Cinema will ensure that the DJI Phantom 2
Vision+ 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 F AA has previously granted relief from Section 91.7(a) specific

to UAS, in circumstances similar, i n all material respects, to those presented herein (e.g.Aviator Cinema for Exemption Page 30

Exemption Nos. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11 109, 1 11 10, 11 1 12,
1 1 136, 1 1 138, 1 1 150, 11 153, 11 156, 1 1 157, 11 158, 1 1 159, 11 160, 11 161).

4. Reasons Why An Exemption Fr om The Requirements Of Section 91.121
W ould Not Adversely Affect Safet y . The equivalent level of safety established by Section 91.121 will be maintained because the altitude information of the DJI Phantom 2 Vision+, UA will be provided to the PIC via GPS equipment and a radio communications telemetry data link, which down-links from the
UA to the GCS for active monitoring of the flight path an d altitude. This altitude information, combined with UAV Aerial Video’s operation of the DJI Phantom 2 Vis ion+ UAS within visual line of sight, at or below 500 feet AGL, will ensure a level of safety equivalent to Section 91.121. The altitude information will be generated by GPS equipment installed on board the aircraft. Prior to each flight, a zero altitude initiation point is automatically established by the UASs at ground level.

The F AA has previously granted relief from Section 91. 121 specif ic to UAS, in circumstances similar, in all material respects, to those presented herein (e.g. Exemption Nos. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11 109, 1 11 12, 11 136, 11 138,
1 1 150, 1 1 153, 1 1 156, 11 157, 11 158, 1 1 159, 11 160, 1 1 161).

5. Reasons Why An Exemption Fr om The Requirements Of Section 91.151(b) W ould Not Adversely Affect Safet y . A grant of this exemption would ensure an equivalent level of safety established by 14 C.F.R. Section 91.151(b) as a result of (1) the technical specifications of the DJI Phantom 2 Vision+, UAS; (2) the limitations on the proposed flight operations; and (3) the location of the proposed flight operations. Accordingly, Aviator Cinema will ensure that it will safely operate the battery powered DJI Phantom 2 Vision+ UA during daylight hours in VFR conditions, with enough battery power to fly for a total durati on 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. 11 109, the technical specifications of the DJI Phantom 2Aviator Cinema for Exemption Page 31

Vision+, UAS; 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+, UAS provide audible and visual warnings to the PIC at the GCS when the UAS experiences low battery voltage, th e 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+, UAS will descend and land automatically. Significantly, previous exemptions granted by the F

AA 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 F AA has previously granted relief from Section 91.151 specific to UAS, in circumstances similar, i n all material respects, to those presented herein (e.g. Exemption Nos. 8811, 10808, 10673, 11042, 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11 109, 11 1 10, 1 1 136, 11 138, 11 150, 1 1 153, 11 156, 1 1 157, 1 1 158, 1 1 159, 1 1 160, 11 161).

6. Reasons Why An Exemption Fro m The Requirements Of Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), And 91.417(a) & (b) W ould Not Adversely Affect Safety.
In seeking this exemption, Aviator Cinema submits that the equivalent level of safety with regard to the regulatory maintenance and alteration requirements established by Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b) will be met because Aviator Cinema will use trained technicians to perform maintenance, alterations, or preventive maintenance on the UAS using the methods, techniques, and practices prescribed in the operating documents (i.e., the Aviator Cinema Aerial Operations Manual, Monthly Maintenance Log, and DJI Phantom 2 Vision+ Instruction Manual). Furthermore, Aviator Cinema wi ll document and maintain all maintenance records for the DJI Phantom 2 Vision+, UAS. Since the DJI Phantom 2 Vision+, UAS will be inspected as prescribedAviator Cinema for Exemption Page 32

by the operating documents, Aviator Cinema will maintai n the equivalent level of safetyAviator Cinema for Exemption Page 33

established by Sections 91.405(a), 91.409(a)(1), and 91.409(a)(2). A copy of the DJI Phantom 2 Vision+ User Manual is attached hereto as Exhibit B & D; a copy of the DJI Phantom 2 Vision+, UAS Maintenance LOG is attached hereto as Exhibit C. Likewise, the exemption sought will not adversely affect safety because Aviator Cinema w ill 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 equivalent level of safety established by Sections 91.407, 91.417(a) and 91.417(b), because all maintenance of the DJI Phantom 2 V

ision+, UAS will be performed by trained technicians. Maintenance will be documented and maintained utilizing the monthly maintenance log. Significantly, previous exemptions granted by the F AA concerning Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b) establish that safety is not adversely affected when the technical characteristics and operating limitations of the UAS are considered. In consideration of Aviator Cinema proposed operating limitations, the operating documents , and the technical aspects of the DJI Phantom 2 V ision +, UAS, Aviator Cinema submits that safety will not be adversely affected by granting exemption from 14 C.F.R. Sections 91.405(a), 91.407(a)(1) and (a)(2), 91.409(a)(2), and 91.417(a) and (b). The F AA has 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, 11 109, 1 11 10, 111 12, 11 136, 1 1 138, 11 150, 1 1 153, 1 1 156, 1 1 157, 11 158, 11 159, 1 1 160, 11 161).

7. The F AA May Prescribe Any Other Conditions For Safe Operation. In accordance with Section 333 of the F AA Modernization and Reform Act of 2012 (FMRA) and 14 C.F.R. § 21.16 entitled Special Co nditions, Aviator Cinema requests that the F AA prescribe special conditions for the intended operation of the DJI Phantom 2 Vision
+, UAS, which contain such safety standards that the Administrator finds necessary to establish a level of safety equivalent to that established by 14 C

. F .R. Part 21, Subpart H, and 14 C.F

. R §§ 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 safeAviator Cinema for Exemption Page 34

operation of the UAS for the limited purpose of conducting aerial video and photography 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 t h e 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 th e NAS. Likewise, the Administrator may prescribe special conditions pursuant to 14 C.F.R. § 21.16, for operation of the DJI Phantom 2 Vision+, UAS, 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 F AA 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 propelle r, h e 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 F AA 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 F

AA may prescribe special conditions for UAV Aerial Video’s intended operation of the DJI Phantom 2 Vision+, , which contain such safety standards that the Administrator finds necessary to establish a level of safety equivalent to that established by 14 C.F.R. Part 21, Subpart H, and 14 C.F

. R Sections 61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a) (1) & (a)(2), and 91.417(a ) & (b).

F
. A Summary That Can Be Published In The Federal Registe r , stating: The Rules Fro m Which UAV Aerial Video Seeks Exemption: Aviator Cinema 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), 91.409(a)(1) & (a)(2), and 91.417(a) & (b).Aviator Cinema for Exemption Page 35

A Brief Description Of The Nature Of The Exemption Aviator Cinema Seeks: This exemption will permit Aviator Cinema to commercially operate an Unmanned Aircraft System (UAS) for the purpose of conducting aerial video and photography over certain areas of the United States.

G. Any Additional Information, Views, Or Arguments A vailable T

o Support Aviator Cinema Request. This Petition is made pursuant to the F AA 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, Aviator Cinema 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 security; and further, provides the authority for such UAS to operate without airworthiness certification. As discussed in detail above, Aviator Cinema will operate the DJI Phantom 2 Vision +, UAS safely in the NAS, without creating a hazard to users of the NAS, or the public, or otherwise pose a threat to national security.

C O NCLUSI O N

As set forth herein, Aviator Cinema seeks an exemption pursuant to 14 C.F.R. § 11.61 and Section 333 of the F AA 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 F AA Administrator will be fulfilling the Congressional mandate of the F AA Modernization and Reform Act of 2012, while also advancing the interests of the public, by allowing Aviator Cinema to safely, efficiently, and economically operate the DJI Phantom 2 Vision+, UAS commercially within the NAS.

WHEREFORE, in accordance with the Federal A viation Regulations and the F AAAviator Cinema for Exemption Page 36

Modernization and Reform Act of 2012, Section 333, Aviator Cinema respectfully requests that the Administrator 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), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b), and permit Aviator Cinema to operate the DJI Phantom 2 Vision +, Phanto m 3 Professional UAS commercially for the purpose of conducting aerial video and photography of Real Estate Properties (for homeowners, realtor's , home builders, home contractors and / or home inspectors for real estate marketing and inspection of home ex teriors) as well as filming of special events, film sets, scripted and unscripted television sets and landscape as well as conducting power line inspection, aerial m apping, surveying and search and rescue over certain areas of the United States.

Dated: June 04 , 2015 Respectfully submitted by , Darl D Hanna

Darl

Hanna Aviator Cinema 3715 E Adobe Drive Phoeni,x Arizona 85050 T el: 480-699-9606 Email: houzful@gmail.comUAV Aerial Video for Exemption Page 37

Appendixes: A

– DJI Phantom 2 Vision+ Specifications Data Sheet B

– DJI Phantom 2 Vision+ Manufacturer ’ s User Manual C C

– Monthly Maintenance Log

APPENDIX

– A

DJI PHANT OM 2 VISION+ TECHNICAL SP E CIFICA T IONS
UAV Aerial Video only utilizes safe and reliable UASs. DJI is an industry leader in

small UAS production. DJI UASs are loaded with ground breaking software enabling the user to se t parameters which will not allow flight into controlled 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 PIC via the linked monitor (smart phone/tablet devices)

1.1 DJI Phantom 2 Vision+

1.1.1 A ircraft 1.1.1.1 Supported Battery

– DJI 5200mAH LiPo Battery 1.1.1.2 Weight (Battery & Propellers Included)

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

– Vertical: .8m; Horizontal: 2.5m 1.1.1.4 Max Y

aw Angular Velocity - 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 RECOMMENDED)

1.1.2 Gimbal 1.1.2.1 Working Current

– Static: 750mA; Dynamic: 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

–

14MAviator Cinema for Exemption Page 38 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 Extender 1.1.5.1 Operating Frequency

– 2412 -2462MHz 1.1.5.2 Communication Distance (unobstructed)

– 500 -700m 1.1.5.3 Transmitter Power

– 20dBm 1.1.5.4 Power Consumption

– 2WAviator Cinema for Exemption Section 333 FAA APPENDIX-B DJI Phantom 2 Vision+ Manufacturer's User Manual

(uploaded in a separate attachment, a 72-page document)Coastal Luxury Films Petition for Exemption Section 333 F AA ! 38 APPENDIX

– C

DJI PHANT OM 3 TECHNICAL SP E CIFICA T IONS

AIRCRAFT


### Weight (Including Battery And Propellers) 1280 g Diagonal Size (Including Propellers) 590 mm

Max Ascent Speed 5 m/s

Max Descent Speed 3 m/s Hover Accuracy

• V ertical: +/ - 10cm

• Horizontal: +/ - 1m

Max Speed 16 m/s (ATTI mode, no wind)

Max Altitude Above Sea Level 6000 m Operating Temperature 0°C to 40°C Gps Mode GPS/GLONASS

GIMBAL


### Controllable Range Pitch -90° to +30°

Stabilization 3 -axis (pitch, roll, yaw)Coastal Luxury Films Petition for Exemption Section 333 F AA ! 39 REMOTE CONTROLLER


### Operating Frequency 2.400 GHz-2.483 GHz

Max Distance 2000m (outdoors and unobstructed) Video Output Port USB
Operating Temperature 0°C- 40°C Battery 6000 mAh LiPo 2S

Mobile Device Holder For tablet or phone

Receiver Sensitivity (1%Per) -101 dBm ±2 dBm

Transmitter Power (Eirp)

• FCC: 20 dBm

• CE: 16 dBm

Working Voltage 1.2 A @7.4 V

BA TTE RY CHARGER


### Voltage 17.4 V

Rated Power Phantom 3 Professional 100 WCoastal Luxury Films Petition for Exemption Section 333 F AA ! 40 INTELLIGENT FLIGHT BA TTE RY


### Capacity 4480 mAh
Voltage 15.2 V Battery Type LiPo 4S Energy 68 Wh

Net Weight 365 g

Max Flight Time App roximately 23 minutes Operating Temperature -10°C to 40°C

Max Charging Power 100 WAviator Cinema for Exemption Section 333 F AA ! 41 APPENDIX

– D DJI Phantom 3 Professional Manufactur er ’ s User

M anual (uploaded in a separate attachment, a 58-page document)Aviator Cinema for Petition for Exemption Section 333 F AA ! 42 APPENDIX

– E

MONTHLY MAINTENANCE LOG

mon t h : yea r: UAS # Date Issue

Discovered Date Issue

Addressed Issue Description &

Maintenance Conducted Maintenance Performed By: Print & Sign
Software Updates
Airframe Engines Propellers
Camera Gimbal Landing Gear
V ibration Dampening
Other:

Darl Hanna Aviator Cinema 3715 E Adobe Drive Phoenix, Arizona 85050 T el: 480-699-9606 Email: houzful@gmail.com