1 December, 29 2015 Attn: U. S. Department of Transportation Docket

Operations West Building Ground Floor, Room w12

- 140 1200 New Jersey Ave, SE Washington, DC 20590 RE: The Hover Bureau

REQUEST AN EXEMPTION FROM THE REQUIREMENTS OF TITLE 14 OF THE CODE OF FEDERAL REGULATIONS SECTIONS 61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), AND 91.417(a) & (b) CONCERNING COMMERCIAL OPERATION OF UNMANNED AIRCRAFT SYSTEMS DJI Inspire 1 PURSUANT TO SECTION 333 OF THE FAA MODERNIZATION AND REFORM ACT OF 2012 (PUBLIC LAW 112

- 95)

Robert Borges Partner, The Hover Bureau 6809 Pine Street, Longboat Key, FL 34228 619

- 618

- 9481 robert@thehoverbureau.com 2 TABLE OF CONTENTS Page 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 o f Authorization FAA Federal Aviation Administration FAR Federal Aviation Regulation GCS Ground Control Station GPS Global Positioning System LOL Loss of Link NAS National Airspace System NOTAM Notice to Airman PIC Pilot In Command Section 333 FAA Modernization and Reform Act of 2012 (FMRA) 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 VTOL Vertical Takeoff and Landin g 4 The Hover Bureau seeks exem ption 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 System (DJI Phantom 3) pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (FMRA). This exemption will permit The Hover Bureau to operate an Unmanned Aircraft System (UAS) for the commercial purpose of conducting aerial video and photography of residential and commercial real estate, over certain areas of the United States. INTRODUCTION AND INTERESTS OF THE PETITIONER The Hover Bureau has an expertise and knowledge in video and mul timedia marketing, and advertising. The objective of The Hover Bureau and our Unmanned Aircr aft System (DJI Inspire 1 ) aerial operations is to provide a more affordable, high

- quality production system for a variety of real estate marketing activities.The Hover Bureau UAV will be operated always within eyesight of the

operator who is in the pro cess of taking FAA approved flight safety classes. Capturing video of real estate properties requires that the UAV is operated slowly and at a relatively low altitude as to capture all the amenities and features of said properties for prospective buyers to view.

The Hover Bureau seeks an exemption to operate DJI Inspire 1 system for

com pensation or hire within the NAS. The DJI Inspire 1 is vertical takeoff and landing (VTOL) Unmanned Aircraft (UA) with a Ground Control Station (GCS) utilizing electronic tablet or smart phone systems. The DJI Inspire 1 is equipped with four main rotors; driven by Lithium Polymer battery powered electric motors. 5 The DJI Inspire 1 that will be operated by The Hover Bureau 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, The Hover Bureau , pursuant to the provisions of the Federal Aviation Regulations (14 C.F.R. § 11.61) and the FAA Modernization and Reform Act of 2012 (FMRA), Section 333, Special Rules for Certain Unmanned Aircraft System s, hereby petitions the Administrator to commercially operate the DJI Inspire 1 , UAS in the National Airspace System (NAS), and for an

exem ption from

the requirem ents 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). In consideration of the speed, weight, size, and limited operating area associated with the unmanned aircraft and its operation, The Hover Bureau operation of DJI Inspire 1 UAS meets the conditions of FMRA Section 333 and therefore, will not require an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart THE HOVER BUREAU . Accordingly, The Hover Bureau 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. The Hover Bureau submits that the requested relief is proper since an equivalent level of safety will be ensured. The Hover Bureau will use experienced personnel or technicians to perform maintenance, alterations, or preventive maintenance on the UAS using the methods, techniques, and practices prescribed in the operating documents (i.e., Monthly Maintenance Log, and DJI Inspire 1 Instruction Manual). Furthermore, The Hover Bureau will document and maintain all maintenance records for the DJI Inspire 1 UAS. Relief from certain requirements of Section 61.113(a) and (b), entitled Private pilot privilegesand li mi tations: Pilot in command, is requested by The Hover Bureau to the

extent necessary to allow a Pilot in Command (PIC) holding a private pilot or higher level certificate, as well as an airman medical certificate, and who has demonstrated, by meeting mini mum flighthour and currency requirements, that the PIC is able to safely operate the DJI Phantom UAS in

a manner consistent with this exemption, including evasive and emergency maneuvers and maintaining appropriate distances from people, vessels, vehicles and structures. The Hover Bureau seeks relief from Section 91.7(a), entitled Civil aircraft airworthiness, because the DJI Inspire 1 UAS do not require an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart THE HOVER BUREAU . As such, Th e Hover Bureau submits that they will ensure that the DJI Inspire 1 UAS is in an airworthy condition, prior to every flight, by determining that the UAS are in compliance with the operating documents (i.e., Monthly Maintenance Log, and DJI Inspire 1 Instru ction Manual), and that the aircraft are in a condition for safe flight. 6 The Hover Bureau also seeks an exemption from the requirements of Section 91.121, entitled Altimeter Settings, as the DJI Inspire 1 UAS will not have a typical barometric altimeter onboard. However, altitude information of the DJI Inspire 1 UAS will be provided to the PIC via Global Positioning System (GPS) equipment and radio communications telemetry data link, which downlinks from the UA to the GCS for active monitoring of the flight path. This altitude information, combined with The Hover Bureau operation of the DJI Inspire 1 UAS within visual line of sight, at or below 400 feet AGL, will ensure a level of safety equivalent to Section 91.121. Additionally, The Hover Bureau seeks an exemption from the requirements of Section 91.151(b), entitled Fuel requirements for flight in VFR conditions. The Hover Bureau submits that safety will not be affected by operation of the DJI Inspire 1 UAS during daylight hours in visual meteorological c onditions (VMC) under visual flight rules (VFR), with enough battery power to fly for a total duration of approximately 18 mi nutes. Battery power indicators are also able to show exactly how much battery power is left, as well as how much time is needed to return safely back to point of take off. In accordance with 14 C.F.R. § 11.81, The Hover Bureau provides the following information in support of its petition for exemption: A. Name And Address Of The Petitioner.

The nam e and address of the Petitioner and point of contact is: Robert Borges Partner of The Hover Bureau LLC 6809 Pine Street, Longboat, Key, FL 34228. 619

- 618

- 9481 robert@thehoverbureau.com The Specific Se ctions Of 14 C.F.R. From Which The Hover Bureau Seeks Exemption. 1. TheHover Bureau 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) an d (b) prescribe the following, in relevant part: (a) No person who holds a private pilot certificate may act as a pilot in command (PIC) of an aircraft that is carrying passengers or property for compensation or hire; nor may that person, for

com pensation or hire, act as PIC of an aircraft. (b) A private pilot may, for

com pensation 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 em ploym ent; and (2) The aircraft does n ot carry passengers or property for compensation or hire. 2. The Hover Bureau 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 c ivil aircraft unless it is in an airworthy condition. 3. The Hover Bureau 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 airc raft 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. 8 4. The Hover Bureau 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 l anding and, assuming normal cruising speed, to fly after that for at least 20 minutes. 5. The Hover Bureau 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. The Hover Bureau 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

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. The Hover Bureau Seeks Exem

ption From

The Requirem ents 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

mo nths, it has had

-- (1) An annual inspection in accordance with part 43 of this chapter and has been approved for return to service by a person authorized by § 43.7 of this chapter; or (2) An inspection for the issuance of an airwo rthiness certificate in accordance with part 21 of this chapter. 9 8. The Hover Bureau 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 the periods specified in paragraph (b) of this section: (1) Records of the maintenance, preventive maintenance, and alteration and records of the 100

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

-- (i) A description (or reference to data acceptable to the Administrator) of the work performed; and (ii) The date of completion of the work performed; and (iii) The signature, and certificate number of the person approving the aircraft for return to servic e. (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 p rogram under which the aircraft and its appliances are maintained. (v) The current status of applicable airworthiness directives (AD) and safety directives including, for each, the method of compliance, the AD or safety directive number and revision date. If the AD or safety directive involves recurring action, the time and date when the next action is required. (vi) Copies of the forms prescribed by § 43.9(d) of this chapter for each major alteration to the airframe and currently installed engines, rotors, propellers, and appliances. 10 (b) The owner or operator shall retain the following records for the periods prescribed: (1) The records specified inparagraph (a)(1) of this section shall be retained until the work is repeated or

superseded by other work or for 1 year after the work is performed. (2) The records specified in paragraph (a)(2) of this section shall be retained and transferred with the aircraft at the time the aircraft is sold. (3) A list of defects furnished to a registered owner or operator under § 43.11 of this chapter shall be retained until the defects are repaired and the aircraft is approved for return to service. C. The Extent Of Relief The Hover Bureau Seeks And The Reason The Hover Bureau Seeks The Relief. 1. Extent Of Relief The Hov er Bureau Seeks And The Reason The Hover Bureau 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 hold ing a private pilot or higher level 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 i s requested since the limitations set forth in Section 61.113(a) and (b) state that a private pilot may, for compensation or hire, act as PIC of an aircraft in connection with any business or employment if: (1) The flight is only incidental to that busines s or employment; and (2) The aircraft does not carry passengers or property for compensation or hire. As set forth more fully below, The Hover Bureau submits that an equivalent level of safety will be maintained because no PIC will be allowed to operate th e DJI Inspire 1 UAS unless that PIC has met certain flight

- hour and currency requirements, demonstrating that the PIC is able to safely operate either the DJI Inspire 1 UAS in a manner consistent with the operations specifications as described in this exem

ption, including evasive and emergency maneuvers, as well as maintaining appropriate distances from people, vessels, vehicles and structures. Further, The Hover Bureau submits that all flights of the DJI Inspire 1 UAS, conducted by the PIC pursuant to the grant of this Petition: (1) will be incidental to The Hover Bureau business; and (2) will not carry passengers or property for compensation or hire. 11 2. Extent Of Relief The Hover Bureau Seeks And The Reason The Hover Bureau 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 The Hover Bureau determine that the DJI Inspire 1 UAS are in airworthy condition prior to every flight by e nsuring that the UAS is in compliance with the operating docum ents (i.e., the Hover Bureau Aerial Operations Manual, Monthly Maintenance Log, and DJI Inspire 1 Instruction Manual). The Hover Bureau seeks the requested relief because the DJI Inspire 1 UAS d o not require an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart THEHOVER BUREAU . Therefore, The Hover Bureau will ensure that the DJI

Inspire 1 UAS are in airworthy condition based upon its compliance with the operating documents (i.e., Monthly Maintenance Log, and DJI Inspire 1 ) 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 The Hover Bureau Seeks And The Reaso n The Hover Bureau Seeks Relief From Section 91.121. Relief from Section 91.121, entitled Altimeter settings, may

be required to allow flight operations of the DJI Inspire 1 UAS, which utilize a barometric pressure sensor, GPS equipment, and a radio commun ications telemetry data link to downlink altitude information from the UA to the PIC at the ground control station (GCS). Since the FAA requires that any altitude information concerning UAS operations be reported to air traffic control (ATC) in feet above ground level (AGL), The Hover Bureau seeks the requested relief because the DJI Inspire 1 UA’s altim eter may

be set on the ground to zero feet AGL, rather than the local barom etric pressure or field altitude, before each flight. Considering the limited alt itude of the proposed operations, relief from 14 CFR 91.121 is sought to the extent necessary to comply with the applicable conditions and limitations stated below. As more fully set forth herein, an equivalent level of safety will be maintained since the DJI Inspire 1 UAS are equipped with a barom etric 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 h eads

- up display of the GCS. 4. Extent Of Relief The Hover Bureau Seeks And The Reason The Hover Bureau 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 re quired to allow flights of the battery powered DJI Inspire 1 UAS during daylight hours in visual meteorological conditions (VMC), under visual flight rules (VFR), for a total duration of 18 mi nutes. The Hover Bureau seeks the requested relief because witho ut an

exem ption from

Section 91.151(b), the flight time duration of the battery powered DJI Inspire 1 UAS will severely constrain the practicality of any aerial video or still photo flight operations that The Hover Bureau proposes to conduct pursuant to t

his Petition. Significantly, as set forth below, the technical specifications of the DJI Inspire 1 UAS, the DJI Inspire 1 operating docum ents, and The Hover Bureau’s proposed operating limitations, ensure that The Hover Bureau will safely operate the battery powered DJI Inspire 1 UAS during daylight hours in visual meteorological conditions (VMC), under visual flight rules (VFR), with enough battery power to fly for a total duration of 18 mi nutes. 5. Extent Of Relief The Hover Bureau Seeks AndThe Reason The Hover Bureau 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) only apply to aircraft with an airworthiness certificate, The Hover Bureau requests relief from these Sections because the DJI Inspire 1 UAS do not require airworthiness certificates. As set forth more fully below, the DJI Inspire 1 UAS meet the conditions of FMRA Section 333 for operati on without an airworthiness certificate. Accordingly, The Hover Bureau 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 The Hover Bureau Aerial Operations Manual, Monthly Maintenance Log, and DJI Inspire 1 Instruction Manual). Furthermore, The Hover Bureau will document and maintain all maintenance records for the DJI Inspire 1 UAS. D. The Reasons Wh y Granti ng The Hover Bureau Request Would Be In The Public Interest; That Is, How It Would Benefit The Public As A Whole. Granting the present Petition will further the public interest by allowing The Hover Bureau to safely, efficiently, and economically perform a erial video and photography of real estate, events and civic landscape over cer tain areas of the United States will enable real estate professionals to showcase their properties in a compelling manner helping to facilitate real estate transactions which wi ll ultimately generate tax revenue for the state of Florida.

Additionally, use of the DJI Inspire 1 UAS will decrease congestion of the NAS, reduce pollution, and provide significant benefits to the economy. Notably, the benefits of The Hover Bureau’s pr oposed operation of the DJI Inspire 1 UAS will be realized without implicating any privacy issues. 1. The Public Will Benefit From Decreased Congestion Of The NAS. The DJI Inspire 1 UAS is battery powered and serve s as a safe, efficient, and

economical alternative to the manned aircraft traditionally utilized to obtain aerial imagery. By reducing the 13 amount of manned aircraft needed to perform aerial acquisitions, an exemption allowing the use of a DJI Inspire 1 UAS would reduce the amount of manned aircraft in the NAS, reduce noise and air pollution, as well as increase the safety of life and property in the air and on the ground. Furthermore, by reducing the number of manned aircraft operating in the NAS, congestion around airports caused by arriving and departing aircraft will be reduced. The DJI Inspire 1 UAS do not require an airport to takeoff or land. Likewise, a reduction of manned aircraft conducting aerial video and photography missions would result in few eraircraft that must be handled by air traffic control during the ground, takeoff,

departure, arrival, and landing phases of flight operations. 2. The Public Will Benefit From The Safety And Efficiency Of The DJI Inspire 1 UAS. Conducting aerial acquisiti ons with the DJI Inspire 1 UAS, instead of manned aircraft, will greatly benefit the public by drastically reducing the levels of air and noise pollution generated during traditional aerial video and still photography flight operations. By using battery po wer and electric

mo tors, the DJI Inspire 1 UAS produce s no air pollution, and is the most viable environmentally conscious alternative to the cabin class, six cylinder internal com

bustion engine aircraft that are typically utilized for aerial video and pho tography, while burning approximately 20

- 30 gallons per hour of leaded aviation fuel. The DJI Inspire 1 UAS, while reducing the carbon footprint of aerial acquisitions, also eliminates noise pollution, as the UAS are propelled by battery powered electric m otors, rather than an internal

com bustion engine. By using the DJI Inspire 1 UAS to perform aerial acquisitions, the substantial risk to life and property in the air and on the ground, which is usually associated with traditional manned aircraft flight
ope rations, will be substantially reduced or completely eliminated. Aside from the lack of flight crew members located onboard the aircraft, the DJI Inspire 1 UAS (weighing approximately 2.8 pounds at their maximum gross weight with diagonal dimension of 23.2 inches, and with no fuel on board), has less physical potential for collateral damage to life and property on the ground, and in the air, compared to the manned aircraft that typically conduct similar operations (weighing approximately 6,000 pounds with a wingspan of approximately 42 feet, a length of 34 feet, and a fuel capacity of 180 gallons). 3. Performing Aerial Video and Photography Operations With The DJI Inspire 1 UAS Will Benefit The Economy. In addition to being safe and efficient, the DJI Inspir e 1 UAS are also an economical alternative to using manned aircraft to conduct similar aerial operations. As such, operation of the DJI Inspire 1 UAS will allow United States based

com panies, like The Hover Bureau , to remain competitive and contribute to
g rowth of the U.S. economy. Specifically, 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 alternative technology in order to remain com petitive. Operating the battery powered DJI Inspire 1 UAS is one such technology that not only allows companies greater operational 14 flexibility compared
to manned aircraft, but provides such flexibility without the high operational cost of a traditional manned aircraft. By operating the DJI Inspire 1 UAS,

com panies such as The Hover Bureau , can remain competitive andprofitable, and therefore, provide greater job stability to employees and

contractors, which will ultimately contrib ute to growth of the U.S. economy. Im proved financial performance of U.S. companies, through commercial use of the DJI Inspire 1 UAS, provides a stable workforce that increases

consum er spending; improves local, state, and federal tax revenues; and allows companies to invest in research and development in order to remain

com petitive 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, The Hover Bureau’s proposed operation of the DJI Inspire 1 UAS will not implicate any privacy issues. Specifically, the DJI Inspire 1 UAS will be operated only in compliance with operating docum ents (i.e., the Hover Bureau’s Aerial Operations Manual, Monthly Mainten ance Log, and DJI Inspire 1 Instruction Manual) which requires property owner involvement as well as local law enforcement notification, and in accordance with the Federal Aviation Regulations, including the mi nim um altitude requirements of 14 C.F.R. § 91. 119. E. The Reasons Why Granting The Exemption Would Not Adversely Affect Safety, Or How The Exem ption Would Provide A Level Of Safety At Least Equal To That Provided By The Rule From Which The Hover Bureau Seeks Exemption. 1. Reasons Why The DJI Inspire 1 UAS Meet The Conditions Of The FAA Modernization and Reform Act of 2012 (FMRA) Section 333. In consideration of the size, weight, speed, and limited operating area associated with the unmanned aircraft and its operation, The Hover Bureau’s operation of the DJI Inspire 1 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 THE HOVER BUREAU . Section 333 provides authority for a UAS to operate without airwor thiness 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. Specifically, FMRA Section 333 states the following, in part: (a) In Ge neral.

-- 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 air space system before com

pletion of the plan and rulemaking required by section 332 of this Act or the guidance required by section 334 of this Act. 15 (b) Assessment of Unmanned Aircraft System s.

-- In m aking the determination under subsection (a), the Secret ary shall determine, at a minim um

-- (1) which types of unmanned aircraft system s, if any, as a result of their size, weight, speed, operational capability, proximity to airports and populated areas, and operation withinvisual 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 airsp ace system, the Secretary shall establish requirements for the safe operation of such aircraft systems in the national airspace system. In seeking this exemption, The Hover Bureau submits that the DJI Inspire 1 UAS can operate safely in the NAS pursuant to FMRA Section 333, as demonstrated by: (a) the characteristics of the DJI Inspire 1 UAS; (b) the pilot certification requirement; and (c) the specific operating limitations. a. The Specifications Of The DJI Inspire 1 UAS Demonstrate Its Safe Characteristics. The DJI Inspire 1 UAS does not create a hazard to users of the NAS or the public, or otherwise pose a threat to national security considering its size, weight, speed, and operational capability. The DJI Inspire 1 UAS Global Positioning Modes Enable The UA S To Remain Within A Defined Operational Area. The DJI Inspire 1 UAS may be operated in both manual and global positioning flight modes. The DJI Inspire 1 UAS Are Designed For Automatic Return To Home Point Or Hover In The Event Of Loss Of The Control Link Or Navigation. When the Control Link is lost, the DJI Inspire 1 UAS will remain stationary, in flight, for 3 seconds or more. If, after 3 seconds, the DJI Inspire 1 UAS does not reacquire control link data from the GCS, the UAS will assume that the Contro l Link is lost and the will return to the home position (i.e., failsafe

mo de) via GPS, and will descend to the ta keoff position and shutdown. 16. Flight Operations Of DJI Inspire 1 UAS Is Limited To The Line Of Sight Of A Certificated Pilot in Command With A Safety Observer. The Hover Bureau video production staff will be the only persons to act as a pilot in command (PIC) of the DJI Inspire 1 UAS. c. Flights Of DJI Inspire 1 UAS Will Be Conducted Pursuant To Specific Operating Limitations. In seeking this e xem ption, The Hover Bureau proposes to commercially operate DJI Inspire 1 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

exem ption will be limited to the following aircr aft described in the operating docum ents, rotorcraft UAS weighing less than 55 pounds maximum gross weight: DJI Inspire 1 Unm anned Aircraft Systems. Proposed operations of any other aircraft will require a new petition or a petition to amend thisgrant. 2. UAS operations under this exemption will be limited to conducting

operations for the purpose of aerial video and photography. 3. The UAS may not be flown at an indicated airspeed exceeding 20 knots. 4. The UA must be operated at an altitude of no more tha n 400 feet above ground level (AGL), as indicated by the procedures specified in the operating documents unless a special request is made and approved by ATC. All altitudes reported to ATC

mu st be in feet AGL. 5. The UAS must be operated within visual line of sight (VLOS) of the PIC at all times. This requires the PIC to be able to use human vision unaided by any device other than corrective lenses, as specified on the PIC’s FAA

- issued airman medical certificate. 6. The use of first person view (FPV) by the PIC or safety observer (SO) is not permitted. 17 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 verb ally at all tim es. Electronic messaging or texting is not permitted during flight operations. The PIC must be designated before the flight and cannot transfer his or her designation for the duration of the flight. The PIC must ensure that the SO can perform the functions prescribed in the operating documents. 8. The SO m

ust 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 instrum ents. 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

exem ption take precedence and must be followed. Otherwise, the operator

mu st follow the procedures as outlined in its operating docum ents. The operator may

update or revise its operating documents. It is the operator’s responsibility to track such revisions and present updated and revised docum ents to the Administrator upon request. The operator must also present updated and revised documents if it petitions for extension or

am endm ent to the grant of exemption. If the operator determines that any update or revision would affect the basis upon which the FAA granted the

exem ption, then the operator must petition for amendment to its gr ant of

exem ption. 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 PIC must inspect the UAS to ensure that it is in a condition for safe fl ight. If the inspection reveals a condition that affects the safe operation of the UAS, the aircraft is prohibited from operating until thenecessary maintenance has been performed and the UAS is found to be in a

condition for safe flight. The Ground Control Station m ust be included in the preflight inspection. All maintenance and alterations must be properly docum ented in the aircraft records. 11. Any UAS that has undergone maintenance or alterations that affect the UAS operation or flight characteristics, e.g. replacement of a flight critical component, must undergo a functional test flight. The PIC who conducts the functional test flight must make an entry in the aircraft records. 12. The pre

- flight inspection must account for all potential discrepancies, e.g. inoperable components, items, or equipm ent, not already covered in the relevant sections of the operating docum ents. 13. The operator must follow the UAS manufacturer’s aircraft/component, maintenance, overhaul, replacement, inspection, and life limi t requirements. 18 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 replacem ent/overhaul component parts must be n oted 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 Bu lletins. 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 private pilot certificate and at least a current thirdclas s m edical certificate. 18. The operator may

not permit any PIC to operate unless the PIC meets the operator’s qualification criteria and demonstrates the ability to safely operate the UAS in a manner consistent with how the UAS will be operated under the e xem ption, 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 purpos es of training the operator’s PICs
are permitted 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 essenti al for flight operations are considered nonparticipants, and the PIC

mu st 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 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 conduct ed in accordance with a NOTAM as required by the operator’s COA. The letter of agreement with the airport
managem ent m

ust 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 h orizontally from a cloud or when visibility is less than 3 statute miles from the PIC. 22. If the UA loses communications or loses its GPS signal, it must return to a predetermined location within the planned operating area and land or be recovered in acco rdance with the operating documents. 19 23. The PIC must abort the flight in the event of unpredicted obstacles or

em ergencies in accordance with the operating documents. 24. The PIC is prohibited from beginning a flight unless (considering wind and foreca st 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 Auth orization (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 operati ons 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

exem ption m ust be identified by serial number, registered in accordance with 14 C.F.R. part 47, and have identification (NNumber) 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 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 PI C at the Ground Control Station of the UAS any time the UAS is operating. These documents must be made available to the Administrator or any law enforcement official upon request. 29. The UA must remain clear and yield the right of way to all manned aviati on 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 arepresent that sufficiently protect nonparticipating persons from the UA and/or

debris in the event of an accident. The operator must ensure that nonpartic ipating 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 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; 20 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 o wner/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 bou ndaries of the operational area as defined by the applicable COA must be reported to the FAA's UAS Integration Office (AFS

- 80) within 24 hours. Accidents must be reported to the National Transportation Safety Board (NTSB) per instructions contained on the NTSB Web site: The Hover Bureau .ntsb.gov. 2. Reasons Why An Exem ption From

The Requirem ents Of Section 61.113(a) And (b) Would Not Adversely Affect Safety. The Hover Bureau submits that the equivalent level of safety established by Section 61.113(a) and (b ) will be maintained because no PIC will be allowed to operate the DJI Phantom 3 UAS unless that PIC has demonstrated, by meeting minimum flight

- hour and currency requirements, that the PIC is able to safely operate the DJI Inspire 1 UAS in a manner consist ent with the exemption, including evasive and emergency maneuvers and maintaining appropriate distances from people, vessels, vehicles and structures. Considering The Hover Bureau’s 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 Inspire 1 UAS, The Hover Bureau submits that the ad ditional manned airmanship experience of a commercially certificated pilot would not correlate to the airmanship skills necessary for The Hover Bureau’s specific proposed flight operations. The FAA has previously granted relief from Section 61.113(a) and (b) specific to UAS, in circum stances similar, in all material respects, to those presented herein (e.g. Exem ption Nos. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 11112, 11136, 11138, 11150, 11153, 11156, 11158, 11159, 11160,11161). The Hover Bureau will not allow any PIC to operate the DJI Inspire

1 UAS unless that PIC has demonstrated, by meeting minimum flight

- hour requirements or the DJI Inspire 1 UAS training and currency requirements, that the PIC is able to safely operate the DJI Inspire 1 UAS in a manner consistent with this exemption, including evasive and emergency maneuvers and maintaining appropriate distances from people, vessels, vehicles and structures. Specifically, the PIC must have accumulated and logged, in a

manner con sistent 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 21 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 PIC must

accom plish 3 takeoffs and landings in the preceding 90 days (for currency purposes). As in Exemption Nos. 11062, 11138, and 11153, prior docum ented flight experience that was obtained in compliance with applicable regulations wi ll ensure an equivalent level of safety during The Hover Bureau’s proposed operations. The Administrator has held that prior docum ented flight experience that was obtained in compliance with applicable regulations would ensure safe operations, stating as f ollows: In Exem ption No. 11062, the FAA required that prior to conducting operations for the purpose of motion picture filming (or similar operations), the PIC

mu st have accum

ulated 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 operations under Exemption No. 11062, the PIC must also have accumulated and logged a minim

um of 5 hours as a UAS pilot operating the same make and

mo del 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 ti me and the 10 hours may be included in the total 25 hours of UAS rotorcraft time. In addition to the hour requirements, the PIC must accomplish 3 takeoffs and landings in the preceding 90 days (for currency purposes). The FAA finds that at a mi nim um , the f light

- hour requirements in Exemption No. 11062 are appropriate to practice and build proficiency in the skills necessary to safely conduct the petitioner’s proposed operations. The FAA also finds that prior docum ented 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

exem ption to accomplish the required flight time. During training, proficiency, and expe rience

- building flights the PIC is required to operatethe UA with appropriate distances in accordance with 14 C.F.R 91.119.

Exem ption No. 11138 at page 15. Accordingly, The Hover Bureau will ensure safe operations by not allowing any PIC to operate the DJ I Inspire 1 UAS unless that PIC has demonstrated, by meeting minimum flight

- hour and currency requirements, that the PIC is able to safely operate the DJI Phantom 3 UAS in a manner consistent with the exemption, including evasive and emergency maneuvers an d maintaining appropriate distances from people, vessels, vehicles and structures. 3. Reasons Why An Exem ption From

The Requirem ents Of Section 91.7(a) Would Not Adversely Affect Safety. 22 The equivalent level of safety established by Section 91.7(a) will be maintained because prior to every flight, The Hover Bureau will ensure that the DJI Inspire 1 UAS is in an airworthy condition based upon the UAS’s compliance with its operating documents and as stated in the conditions and limitations herein. Addition ally, the FAA has previously granted relief from Section 91.7(a) specific to UAS, in circum stances similar, in all material respects, to those presented herein (e.g. Exem ption Nos. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 11112, 11136 , 11138, 11150, 11153, 11156, 11157, 11158, 11159, 11160, 11161). 4. Reasons Why An Exemption From The Requirements Of Section 91.121 Would Not Adversely Affect Safety. The equivalent level of safety established by Section 91.121 will be maintained because the altitude information of the DJI Inspire 1 UAS will be provided to the PIC via GPS equipm ent and a radio communications telemetry data link, which downlinks from the UA to the GCS for active monitoring of the flight path and altitude. This altitude info rmation, combined with The Hover Bureau’s operation of the DJI Inspire 1 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 inst alled onboard the aircraft. Prior to each flight, a zero altitude initiation point is
automatically established by the UAS at ground level. The FAA has previously granted relief from Section 91.121 specific to UAS, in circum stances similar, in all material respects, to those presented herein (e.g. Exem ption 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 DJI Inspire 1 UAS; (2) the limitations on the p roposed flight operations; and (3) the location of the proposed flight operations. Accordingly, The Hover Bureauwill ensure that it will safely operate the battery powered DJI Inspire 1 UAS

during daylight hours in VFR conditions, with enough battery powe r to fly for a total duration of 18 mi nutes. Here, as in Exemption No. 11109, the technical specifications of the DJI Inspire 1 UAS; the limitations on the proposed flight operations; and the location of the proposed operations, will ensure an equivalent l evel of safety established by 14 C.F.R. Section 91.151(b). Furthermore, safety will be ensured as the DJI Inspire 1 UAS provide audible and visual warnings to the PIC at the GCS when the UAS experiences low battery voltage, the first warning occurring at approximately 33% remaining battery power, and again at approximately 10% rem aining battery 23 power. At the critical ly low battery level, the DJI Inspire 1 UAS will descend and land automatically. Significantly, previous

exem ptions granted by the FAA concerning Section 91.151 establish that safety is not adversely affected when the technical characteristics and operatin g limitations of the UAS are considered. Relief has been granted for manned aircraft to operate at less than the minimums prescribed in Section 91.151, including Exemption Nos. 2689, 5745, and 10650. Moreover, the FAA has previously granted relief from Sec tion 91.151 specific to UAS, in circum stances similar, in all material respects, to those presented herein (e.g. Exem ption Nos. 8811, 10808, 10673, 11042, 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 11136, 11138, 11150, 11153, 11156, 111 57, 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 exem ption, The Hover Bureau 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 The Hover Bureau will use trained technician s to perform maintenance, alterations, or preventive maintenance on the UAS using the methods, techniques, and practices prescribed in the operating documents (i.e., the Hover Bureau Aerial Operations Manual, Monthly Maintenance Log, and DJI Inspire 1 Instruction Manual). Furthermore, The Hover Bureau will document and maintain all maintenance records for the DJI Inspire 1 UAS. Since the DJI Inspire 1 UAS will be inspected as prescribed by the operating documents, The Hover Bureau will maintain the equivalent level of safety established by Sections 91.405(a), 91.409(a)(1), and 91.409(a)(2). Likewise, the exemption sought will not adversely affect safety because The Hover Bureau will use trained technicians to perform maintenance, alterations or preventive mai ntenance on the UAS using the methods, techniques, and practices prescribed by theoperating 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 Inspire 1 UAS will be perform ed by trained technicians. Maintenance will be documented and maintained utilizing the monthly maintenance log. Significantly, previous

exem ptions granted by the FAA 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. 24 In consideration of The Hover Bureau’s proposed operating limitations, t he operating documents, and the technical aspects of the DJI Inspire 1 UAS, The Hover Bureau 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) an d (b). The FAA 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, 11109, 11110, 11112, 11136, 11138, 11150, 11153 , 11156, 11157, 11158, 11159, 11160, 11161). 7. The FAA May Prescribe Any Other Conditions For Safe Operation. In accordance with Section 333 of the FAA Modernization and Reform Act of 2012 (FMRA) and 14 C.F.R. § 21.16 entitled Special Conditions, The Hove r Bureau requests that the FAA prescribe special conditions for the intended operation of the DJI Inspire 1 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 THE HOVER BUREAU , 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 UAS for the limited purpo se 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 the public, or otherwise pose a threat to national security; and further, provides the authority for such UAS to operate without airworthiness certification in accordance with any requirements that must be established for the safe operation of the UAS in the NAS. Likewise, the Administrator may prescribe special conditions pursuant to 14 C.F.R. § 21.16, for operation of the DJI Inspire 1 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 FAA finds that the airworthiness regulations of this subchapter do notcontain adequate or appropriate safety standards for an aircraft, aircraft

engine, or propeller because of a novel or unusual design feature of the aircraft, aircraft engine or propeller, he prescribes special conditions and

am endm ents thereto for the product. The special conditions are issued in accordance with Part 11 of this chapter and contain such safety standards for the aircraft, aircraft engine or propeller as the FAA finds necessar y to establish a level of safety equivalent to that established in the regulations. See 14 C.F.R. § 21.16. Therefore, in accordance with FMRA Section 333 and 14 C.F.R. § 21.16, the FAA may prescribe special conditions for Leading Edge’s intended operation of the DJI Inspire 1 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 THE HOVER BUREAU , and 14 C.F.R Sections 25 61.113(a) & (b), 91. 7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b). • A Summary That Can Be Published In The Federal Register, stating: The Rules From Which The Hover Bureau Seeks Exem ption: The Hover Bureau seeks exem ption from the requirem ents 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). A Brief Description Of The Nature Of The Exemption The Hover Bureau Seeks: This exem

ption will permit The H over Bureau to commercially operate an Unm anned Aircraft System (UAS) for the purpose of conducting aerial video and photography over certain areas of the United States. • Any Additional Information, Views, Or Arguments Available To Support The Hover Bureau’s Request. This Petition is made pursuant to the FAA Modernization and Reform Act of 2012 (FMRA) Section 333, which directs the Secretary of Transportation to determine if certain UAS may operate safely in the NAS. As such, The Hover Bureau’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 otherwi se pose a threat to national security; and further, provides the authority for such UAS to operate without airworthiness certification. As discussed in detail above, The Hover Bureau will operate the DJI Inspire 1 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. CONCLUSION As set forth herein, The Hover Bureau seeks an exemption pursuant to 14 C.F.R. § 11.61 and Section 333 of the FAA Modernization and Reform Act of 2012 (F MRA), which will permit safe operation of the DJI Inspire 1 UAS commercially, without an airworthiness certificate, forthe 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 FAA Modernization and Reform Act of 2012, while also advancing the interests of the public, by allowing The Hover Bureau to safely, efficiently, and economically operate the DJI Inspire 1 UAS commercially within the NAS. 26 WHEREFORE, in accordance with the Federal Aviation Regulations and the FAA Modernization and Reform Act of 2012, Section 333, The Hover Bureau respectfully requests that the Administrator grant this Petition for an

exem ption from

the requirem ents 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 The Hover Bureau to operate the DJI Inspire 1 UAS commercially for the purpose of conducting aerial video and photography over certain areas of the United States. Dated: December 29

, 2015 Respectfully submitted, Robert Borges, Partner The Hover Bureau LLC

, 6809 Pine Street, Longboat Key, FL 34228 619

- 618

- 9481 robert@thehoverbureau.com