UNITED STATES OF AMERICA

DEPARTMENT OF TRANSPORTATION

FEDERAL AVIATION ADMINISTRATION WASHINGTON, DC

IN THE MATTER OF THE PETITION FOR EXEMPTION OF: QuadCam LLC FOR AN EXEMPTION SEEKING RELIEF 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 DJI PHANTOM 2 VISION+ , DJI PHANTOM 3 UNMANNED

AIRCRAFT SYSTEMS

PURSUANT TO SECTION 333 OF

THE FAA MODERNIZATION AND REFORM ACT OF 2012 (PUBLIC LAW 112

- 95)

Submitted on August 16 , 2015

QuadCam LLC Zachary David Marhafer

1331 Saddle Ct Palm Harbor, FL 34683

727

- 510

- 0559

FA A Airman Certificate ATP3232267! 2 GLOSSARY OF ABBREVIATIONS

AGL Above Ground Level

AOI Area of Interest

ATC Air Traffic Control

ATO Air Traffic Organization

AV Aerial Vehicle

CFR Code of Federal Regulations

COA Certificate of Authorization

FAA Federal Aviatio n 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 Moder nization 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

VTOL Vertical Takeoff and Landing! 3 SUMMARY

QuadCam LLC seeks exemption from the requirements of 14 C.F.R §§ 61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b), to operate an Unmanned Aircraft System pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (FMRA). This exemption will permit QuadCam LLC to operate an Unmanned Aircraft System (UAS) for the commercial purpose of conducting aeria l video and photography of construction sites, real estate, landscape , search and rescue, as well as perform over video certain areas of the United

States.

INTRODUCTION AND INTERESTS OF THE PETITIONER

QuadCam LLC provides its clients with expertise and k nowledge in advanced technologies and solutions to increase efficiency, productivity and effectiveness. QuadCam LLC has over 10 years of professional experience in aviation . He has over 10 years recreational / hobby experience in all aspects of aerial vid eo and photography. The objective of QuadCam LLC aerial video and photography operations is to provide high quality imaging for a variety of commercial, public, and residential uses, specifically targeting:

• Construction sites before and after

• Appr aisals

• Real

- estate marketing

• Motion Picture Filming

• Aerial event photography/videography

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

• Search and Rescue operations

BACKGROUND

Unmanned Aircraft Systems: DJ I Phantom 2 Vision+, DJI Phantom 3 UASs

QuadCam LLC seeks an exemption to operate DJI systems for compensation or hire

within the NAS. The DJI Phantom 2 Vision+ and DJI Phantom 3 are vertical takeoff and landing (VTOL) Unmanned Aircraft (UA) with a Ground Control Station (GCS) utilizing electronic tablet or smart phone systems. The DJI Phantom 2 Vision+ has a maximum gross weight of approximately 2 pounds 11 ounces, while having a length of 16 inches width of 16 inches, height of 8 inches, and a maximum sp eed of approximately 29 knots. The	DJI	Phantom	3	has	a	maximum	gross	weight	of	2	pounds	13.1	ounces,	a	length	of 16.2	inches,	width	of	16.6	inches,	height	of	10.5	inches,	and	a	maximum	speed	of approximately	31.1	knots! 4 The DJ I Phantom 2 Vision+ and DJI Phantom 3 UA s that will be operated by QuadCam

LLC 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, QuadCam LLC , 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 Rul es for Certain Unmanned Aircraft Systems , hereby petitions the Administrator to commercially operate the DJI Phantom 2 Vision+, DJI

Phantom 3 UASs in the National Airspace System (NAS), and for an exemption from the requirements of 14 C.F.R §§ 61.113(a) & (b), 91.7(a), 91.121, 91.151(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, QuadCam LLC operation of DJI Phantom 2

Vision+ and DJI Phantom 3 UASs meets the conditions of FMRA Section 333 and therefore, will not require an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H.

Accordingly, QuadCam LLC 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.

QuadCam LLC submits that the requested relief is proper since an equi valent level of safety will be ensured. QuadCam LLC will use experienced personnel or technicians to perform maintenance, alterations, or preventive maintenance on the UASs using the methods, techniques, and practices prescribed in the operating documents (i.e., Monthly Maintenance Log, and DJI Phantom 2 Vision+ and DJI Phantom 3 Instruction Manual). Furthermore, QuadCam LLC will document and maintain all maintenance records for the

DJI Phantom 2 Vision+ and DJI Phantom 3 UASs.

Relief from certain requirem ents of Section 61.113(a) and (b), entitled Private pilot privileges and limitations: Pilot in command , is requested by QuadCam LLC 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 minimum flight

- hour and currency requirements, that the PIC is able to safely operate the

DJI Phantom 2 Vision+ and DJI Phantom 3 UASs in a manner consistent with this exemption, including evasive and emergency maneuvers and maintaining appropriate distances from people, vessels, vehicles and structures.

QuadCam LLC seeks relief from Section 91.7(a), entitled Civil aircraft airworthiness

, because the DJI Phantom 2 Vision+ and DJI Phantom 3 UASs do not require an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H. As such, QuadCam LLC submits that they will ensure that the DJI Phantom 2 Vision+ and DJI

Phantom 3 UASs are in an airworthy condition, prior to every flight, by determining that

the! 5 UASs are in compliance with the operating documents (i.e., Monthly Maintenance Log,

and DJI Phantom 2 Vision+ and DJI Phantom 3 Instruction Manual), and that the aircraft are in a condition for safe flight.

QuadCam LLC also seeks an exemption from the requirements of Section 91.121, entitled Altimeter Settings , as the DJI Phantom 2 Vision+ and DJI Phantom 3 UAs will not have a typical barometric altimeter onboard. However, altitude information of the DJI Phantom 2

Vision+ and DJI P hantom 3 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 Q uadCam LLC operation of the DJI Phantom 2

Vision+ and DJI Phantom 3 UASs within visual line of sight, at or below 500 feet AGL,
will ensure a level of safety equivalent to Section 91.121.

Additionally, QuadCam LLC seeks an exemption from the requirements of Section 91.151(b), entitled Fuel requirements for flight in VFR conditions

. QuadCam LLC submits that safety will not be affected by operation of the DJI Phantom 2 Vision+ and DJI

Phantom 3 UAs during daylight hours in visual meteorological conditions (V MC) 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, QuadCam LLC 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: Zachary Marhafer QuadCam LLC
1331 Sad dle ct Palm Harbor, FL 34683

727

- 510

- 0559

Email: quadcamus@gmail.com

B. The Specific Sections Of 14 C.F.R. From Which QuadCam LLC Seeks Exemption.

1. QuadCam LLC Seeks Exemption From The Requirements Of Section 61.113(a) And (b).

Section 61.113, entitled Private pilot privileges and limitations: Pilot in command

, subsections (a) and (b) prescribe the following, in relevant part: (a) No person who holds a private pilot certificate may act as a pilot in command (PIC) of an aircraft that is carrying passenge rs or property for compensation or hire; nor may that person, for compensation or hire, act as PIC of an aircraft.! 6 (b) A private pilot may, for compensation or hire, act as PIC of an aircraft in connection with any business or employment if

—

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

2. QuadCam LLC Seeks Exemption From The Requirements Of Section 91.7(a).

Section 91.7, entitled Civil aircraft airwo rthiness , subsection (a), states the following:

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

3. QuadCam LLC Seeks Exemption From The Requirements Of Section

91.121.

Section 91.121, entitled Altimeter settings, subsect ion (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 sett ing of an appropriate available station; or

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

4. QuadCam LLC Seeks Exemption From The Require ments 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 weathe r 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.! 7 5. QuadCam LLC Seeks Exemption From The Requirement Of Section 91.405(a).

Section 91.405, enti tled 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. QuadCam LLC Seeks Exemption From The Requirements Of Section 91.407(a)(1)

Section 91.407, entitled Operation after maintenance, preventive maintenance,

rebuild ing, 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 autho rized under § 43.7 of this chapter[.]

7. QuadCam LLC Seeks Exemption From The Requirements Of Sections 91.409(a)(1) And 91.409(a)(2).

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

(a) Except as provided in paragraph (c) of this section, no person may operate an aircraft unless, within the preceding 12 calendar months, it has had

--

(1) An annual inspection in accordance with part 43 of this chapter and has been approved for return to service 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. QuadCam LLC Seeks Exemption From The Requirements Of Sections 91.417(a) And 91.417(b).

Section 91.417, entitled Mainte nance 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 sectio n:

(1) Records of the maintenance, preventive maintenance, and alteration and

records of the 100

- hour, annual, progressive, and other required or approved! 8 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 certifica te 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 pa rts 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, in cluding the time since the last inspection required by the inspection program under which the aircraft and its appliances are maintained.

(v) The current status of applicable airworthiness directives (AD) and safety directives including, for each, the met hod of compliance, the AD or safety directive number and revision date. If the AD or safety directive involves recurring action, the time and date when the next action is required.

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

(b) The owner or operator shall retain the following records for the periods prescribed:

(1) The records specified in paragraph (a)(1) of this section s hall 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 i s sold.! 9 (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 QuadCam LLC Seeks And The Reason QuadCam LLC Seeks

The Relief.

1. Extent Of Relief QuadCam LLC Seeks And The Reason QuadCam LLC 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 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 f light operations for compensation or hire.

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

or hire.

As set forth more fully below, QuadCam LLC submits that an equivalent level of safety will be ma intained because no PIC will be allowed to operate the DJI Phantom 2
Vision+ UAS or DJI Phantom 3 UAS unless that PIC has met certain flight

- hour and currency requirements, demonstrating that the PIC is able to safely operate either the DJI

Phantom 2 Visio n+ or DJI Phantom 3 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.

Furthe r, QuadCam LLC submits that all flights of the DJI Phantom 2 Vision+ and DJI

Phantom 3 UASs, conducted by the PIC pursuant to the grant of this Petition: (1) will be

incidental to QuadCam LLC business; and (2) will not carry passengers or property for

comp ensation or hire.

2. Extent Of Relief QuadCam LLC Seeks And The Reason QuadCam LLC 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 QuadCam LLC to determine that the DJI Phantom 2 Vision+ and DJI

Phantom 3 UASs are in airworthy condition prior to every flight by ensuring that the UAS is in compliance with the operating documents (i.e., DJI Phantom 2 Vision+ and DJI

Phantom 3 Instruction Manual).

QuadCam LLC seeks the requested relief because the DJI Phantom 2 Vision+ and

DJI Phantom 3 UASs do not require an airworthiness certificate in accordance with 14! 10 C.F.R. Part 21, Subpart H. Therefore, QuadCam LLC will ensure that the DJI Phantom 2

Vision+ and DJI Phant om 3 UASs are in airworthy condition based upon its compliance with the operating documents (i.e., Monthly Maintenance Log, and DJI Phantom 2 Vision+

and DJI Phantom 3 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 QuadCam LLC Seeks And The Reason QuadCam LLC

Seeks Relief From Section 91.121.

Relief from Section 91.121, entitled Altimeter settings, may be required t o allow flight operations of the DJI Phantom 2 Vision+ and DJI Phantom 3 UASs, which utilize a barometric pressure sensor, GPS equipment, and a radio communications telemetry data link to downlink altitude information from the UA to the PIC at the ground c ontrol 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), QuadCam LLC seeks the requested relief because the DJI Phantom 2 Vision+ and DJI Phantom 3 UA’s altimeter may be set on the ground to zero feet AGL, rather than the local barometric pressure or field altitude, before each flight.

Considering the limited altitude of the proposed operations, relief from 14 CFR 91.121 is sought to the e xtent necessary to comply with the applicable conditions and limitations stated below. As more fully set forth herein, an equivalent level of safety will be

maintained since the DJI Phantom 2 Vision+ and DJI Phantom 3 UAs are equipped with a barometric pre ssure sensor and GPS equipment, which automatically ensures that a ground level pressure setting will be established prior to each flight, and provides the PIC with

altitude information of the UA on the heads

- up display of the GCS.

4. Extent Of Relief Qua dCam LLC Seeks And The Reason QuadCam LLC 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 the battery powered DJI Phantom 2

Vision+ and DJI Phantom 3 UAs during daylight hours in visual meteorological conditions (VMC), under visual flight rules (VFR), for a total duration of 13.5 minutes to the first point of intended landing and, assuming normal cruising speed, to fly after t hat for at least
4.5 minutes. QuadCam LLC seeks the requested relief because without an exemption from Section 91.151(b), the flight time duration of the battery powered DJI Phantom 2

Vision+ and DJI Phantom 3 UAs will severely constrain the practicality o f any aerial video or still photo flight operations that QuadCam LLC proposes to conduct pursuant to
this Petition.

Significantly, as set forth below, the technical specifications of the DJI Phantom 2 Vision+

and DJI Phantom 3 UASs, the DJI Phantom 2 Visi on+ and DJI Phantom 3 operating documents, and QuadCam LLC proposed operating limitations, ensure that QuadCam LLC will safely operate the battery powered DJI Phantom 2 Vision+ and DJI Phantom 3 UAs during daylight hours in visual meteorological conditions (VMC), under! 11 visual flight rules (VFR), with enough battery power to fly for a total duration of 13.5 minutes to the first point of intended landing and, assuming normal cruising speed, to fly

after that for at least 4.5 minutes.

5. Extent Of Relief Quad Cam LLC Seeks And The Reason QuadCam LLC 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 airw orthiness certificate, QuadCam LLC requests relief from

these Sections because the DJI Phantom 2 Vision+ and DJI Phantom 3 UASs do not require airworthiness certificates. As set forth more fully below, the DJI Phantom 2

Vision+ and DJI Phantom 3 UASs meet the conditions of FMRA Section 333 for operation without an airworthiness certificate. Accordingly, QuadCam LLC will use trained technicians to perform maintenance, alterations, or preventive maintenance on the UASs using the methods, techniques, and pract ices prescribed in the UAS operating documents (i.e., the QuadCam LLC Aerial Operations Manual, Monthly Maintenance Log, and DJI

Phantom 2 Vision+ and DJI Phantom 3 Instruction Manual). Furthermore, QuadCam LLC

will document and maintain all maintenance re cords for the DJI Phantom 2 Vision+ and

DJI Phantom 3 UASs.

D. The Reasons Why Granting QuadCam LLC 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 intere st by allowing QuadCam LLC to safely, efficiently, and economically perform aerial video and photography of construction sites, real estate, and landscape over certain areas of the United States.

Additionally, use of the DJI Phantom 2 Vision+ and DJI Phan tom 3 UASs will decrease congestion of the NAS, reduce pollution, and provide significant benefits to the economy. Notably, the benefits of QuadCam LLC ’s proposed operation of the DJI Phantom 2

Vision+ and DJI Phantom 3 UASs will be realized without implic ating any privacy issues.

1. The Public Will Benefit From Decreased Congestion Of The NAS.

The DJI Phantom 2 Vision+ and DJI Phantom 3 UAs are battery powered and serve as a safe, efficient, and economical alternative to the manned aircraft traditionally utilized to obtain aerial imagery. By reducing the amount of manned aircraft needed to perform aerial acquisitions, an exemption allowing the use of a DJI Phantom 2 Vision+ or DJI Phantom 3 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 w ill be reduced. The DJI Phantom

2 Vision+ and DJI Phantom 3 UAs do not require an airport to takeoff or land. Likewise, a reduction of manned aircraft conducting aerial video and photography missions would! 12 result in fewer aircraft that must be handled by a ir traffic control during the ground, takeoff, departure, arrival, and landing phases of flight operations.

2. The Public Will Benefit From The Safety And Efficiency Of The DJI

Phantom 2 Vision+ and DJI Phantom 3 UASs.

Conducting aerial acquisitions with the DJI Phantom 2 Vision+ and DJI Phantom 3 UASs, instead of manned aircraft, will greatly benefit the public by drastically reducing the levels of air and noise pollution generated during traditional aerial video and still photography flight operations. By using battery power and electric motors, the DJI Phantom 2 Vision+

and DJI Phantom 3 UASs produce no air pollution, and is the most viable environmentally conscious alternative to the cabin class, six cylinder internal combustion engine aircraft

that ar e typically utilized for aerial video and photography, while burning approximately

20

- 30 gallons per hour of leaded aviation fuel. The DJI Phantom 2 Vision+ and DJI
Phantom 3 UAs, while reducing the carbon footprint of aerial acquisitions, also eliminates noise pollution, as the UAs are propelled by battery powered electric motors, rather than an internal combustion engine.

By using the DJI Phantom 2 Vision+ and DJI Phantom 3 UASs to perform aerial acquisitions, the substantial risk to life and property in the air and on the ground, which is usually associated with traditional manned aircraft flight operations, will be substantially reduced or completely eliminated. Aside from the lack of flight crew members located onboard the aircraft, the DJI Phantom 2 V ision+ and DJI Phantom 3 UAs (weighing approximately 2 pounds 11 ounces and 6 pounds 7.5 ounces respectively, at their maximum gross weights with lengths of 16 inches and 17.3 inches respectively, widths of 16 inches and 17.7 inches respectively, and with no fuel on board), has less physical potential for collateral damage to life and property on the ground, and in the air, compared to the manned aircraft that typically conduct similar operations (weighing approximately 6,000 pounds with a wingspan of appro ximately 42 feet, a length of 34 feet, and a fuel capacity of 180 gallons).

3. Performing Aerial Video and Photography Operations With The DJI

Phantom 2 Vision+ and DJI Phantom 3 UASs Will Benefit The Economy.

In addition to being safe and efficient, the DJI Phantom 2 Vision+ and DJI Phantom 3 UASs are also an economical alternative to using manned aircraft to conduct similar aerial operations. As such, operation of the DJI Phantom 2 Vision+ and DJI Phantom 3 UASs will allow United States based companies, like QuadCam LLC , 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 (“EPA”) 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 the battery powered DJI Phantom 2

Vision+ and DJI Phantom 3 UASs is one such technology that not only allows companies greater operational flexibility co mpared to manned aircraft, but provides such flexibility without the high operational cost of a traditional manned aircraft.! 13 By operating the DJI Phantom 2 Vision+ and DJI Phantom 3 UASs, companies such as QuadCam LLC , can remain competitive and profitable , and therefore, provide greater job stability to employees and contractors, which will ultimately contribute to growth of the U.S. economy. Improved financial performance of U.S. companies, through commercial

use of the DJI Phantom 2 Vision+ and DJI Phant om 3 UASs, provides a stable workforce that increases consumer spending; improves local, state, and federal tax revenues; and allows companies to invest in research and development in order to remain competitive

both in the United States and abroad.

4. Th ere Are No Privacy Issues.

Similar to the manned aerial acquisition flight operations that have been conducted for decades, QuadCam LLC ’s proposed operation of the DJI Phantom 2 Vision+ and DJI

Phantom 3 UASs will not implicate any privacy issues. Specifi cally, the DJI Phantom 2

Vision+ and DJI Phantom 3 UASs will be operated only in compliance with operating documents (i.e., the QuadCam LLC Aerial Operations Manual, Monthly Maintenance Log, and DJI Phantom 2 Vision+ and DJI Phantom 3 Instruction Manual) w hich requires property owner involvement as well as local law enforcement notification, and in accordance with the Federal Aviation Regulations, including the minimum altitude requirements of 14 C.F.R. § 91.119.

E. The Reasons Why Granting The Exemption W ould Not Adversely Affect Safety, Or How The Exemption Would Provide A Level Of Safety At Least Equal To That Provided By The Rule From Which QuadCam LLC Seeks Exemption.

1. Reasons Why The DJI Phantom 2 Vision+ and DJI Phantom 3 UAs Meet

The Conditions O f 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, QuadCam LLC ’s operation of the DJI Phantom
2 Vision+ and DJ I Phantom 3 UASs meet the conditions of FMRA Section 333, and will not require an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H.

Section 333 provides authority for a UAS to operate without airworthiness certification

and sets f orth requirements for considering whether a UAS will create a hazard to users of the NAS or the public, or otherwise pose a threat to national security. Specifically, FMRA Section 333 states the following, in part:

(a) In General.

-- Notwithstanding any oth er requirement of this subtitle, and not later than 180 days after the date of enactment of this Act, the Secretary of Transportation shall determine if certain unmanned aircraft systems may operate safely in the national airspace system before completion of the plan and rulemaking required by section 332 of this Act or the guidance required by section 334 of this Act.! 14 (b) Assessment of Unmanned Aircraft Systems.

-- In making the determination under subsection (a), the Secretary shall determine, at a minimum

- -

(1) which types of unmanned aircraft systems, if any, as a result of their size, weight, speed, operational capability, proximity to airports and populated areas, and operation within visual line of sight do not create a hazard to users of the national airspace system or the public or pose a threat to national security; 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 o f 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, QuadCam LLC submits that the DJI Phantom 2 Vision+ and

DJI Phantom 3 UASs can operate safely in the NAS pursuant to FMRA Se ction 333, as demonstrated by: (a) the characteristics of the DJI Phantom 2 Vision+ and DJI Phantom 3 UASs; (b) the pilot certification requirement; and (c) the specific operating limitations.

a. The Specifications Of The DJI Phantom 2 Vision+ and DJI Pha ntom 3

UASs Demonstrate Its Safe Characteristics.

The DJI Phantom 2 Vision+ and DJI Phantom 3 UASs do not create a hazard to users of the NAS or the public, or otherwise pose a threat to national security considering its size, weight, speed, and operation al capability.

i. Technical Specifications Of The DJI Phantom 2 Vision+ and DJI

Phantom 3 UASs.

The technical specifications of the DJI Phantom 2 Vision+ and DJI Phantom 3 UASs are set forth by the DJI Phantom 2 Vision+ and DJI Phantom 3 Specifications a nd Data Sheet,

attached hereto as Exhibit A and B.

ii. The DJI Phantom 2 Vision+ and DJI Phantom 3 UASs Autonomous Flight And Navigation Modes Enable The UASs To Remain Within A Defined Operational Area.

The DJI Phantom 2 Vision+ and DJI Phantom 3 UASs m ay be operated in both manual and fully autonomous flight modes. A complete description of the flight and navigational

modes of the DJI Phantom 2 Vision+ and DJI Phantom 3 UASs is provided at pages 25

- 35
of the DJ I Phantom 2 Vision+ and pages 11

- 15 of the DJI Phantom 3 User Manuals,
attached hereto as Exhibit C and D.! 15 iii. The DJI Phantom 2 Vision+ and DJI Phantom 3 UASs 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 i s lost, the DJI Phantom 2 Vision+ and DJI Phantom 3 UAs will remain stationary, in flight, for 3 seconds or more. If, after 3 seconds, the DJI Phantom 2

Vision+ and DJI Phantom 3 UAs do not reacquire control link data from the GCS, the UAs

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

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

set forth at pages 27 through 29 and for the DJI Phantom 3 at pages 11 through 15 of the

DJI Phantom 2 Vision+ and DJI Phantom 3 User Manuals, attached hereto as Exhibit C

and D.

iv. The DJI Phantom 2 Vision+ and DJI Phantom 3 GCS And

Its Operation.

A complete descr iption of the operation and specifications of the DJI Phantom 2 Vision+

and DJI Phantom 3 GCS and flight control software is provided at pages 32 through 43 of the DJI Phantom 2 Vision+ User Manual and pages 40 through 47 of the DJI Phantom

3 User Manual. DJI Phantom 2 Vision+ and DJI Phantom 3 User Manuals are attached

hereto as Exhibits C and D. b. Flight Operations Of DJI Phantom 2 Vision+ and DJI Phantom 3 UASs Are Limited To The Line Of Sight Of A Certificated Pilot in Command With A Safety Observer.

QuadCam LLC will only utilize certificated pilots who possess a current and valid airman medical certificate to act as a pilot in command (PIC) of the DJI Phantom 2

Vision+ and DJI Phantom 3 UASs. Additionally, a safety observer will assist all pilots

duri ng flight time.

c. Flights Of DJI Phantom 2 Vision+ and DJI Phantom 3 UASs Will Be Conducted Pursuant To Specific Operating Limitations.

In seeking this exemption, QuadCam LLC proposes to commercially operate DJI

Phantom 2 Vision+ and DJI Phantom 3 UASs for the special purpose of conducting aerial video and photography over certain areas of United States, pursuant to the following specific operating limitations:

1. Operations authorized by this grant of exemption will be limited to the following

aircraft described in the operating documents, rotorcraft UASs weighing less than 55 pounds maximum gross weight: DJI Phantom 2 Vision+ and DJI

Phantom 3 Unmanned Aircraft Systems. Proposed operations of any other aircraft will require a new petition or a petition to amend this grant.! 16 2. UAS operations under this exemption will be limited to conducting operations for the purpose of aerial video and photography.

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

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

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

- issued airman

medical certificate.

6. The use of fi rst 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 b e able to communicate verbally at all times. Electronic messaging or texting is not permitted during flight operations. The PIC must be designated before the flight and cannot transfer his or her designation for the duration of the flight. The PIC must ens ure that the SO can perform the functions prescribed in the operating documents.

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 permi tted 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 limita tions 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, the 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 FAA granted the exemption, then the operator must peti tion 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 PIC must inspect the UAS to ensure that it is in a condition for safe flight. If the inspection reveals a condition that affects the! 17 safe operation of the UAS, the aircraft is prohibited from operating until the necessary maintenance has been performed and the UAS is found to be in a

condition for safe flight. The Ground Control Station must be included in the preflight inspection. All maintenance and alterations must be properly

documented in the aircraft records.

11. Any UAS that has undergone maintenance or alterations that affect the UAS

operat ion 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 f or 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, replac ement, 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/over haul 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 UASs 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 private pilot certificat e and at least a current
third

- class medical certificate.

18. The operator may not permit any PIC to operate unless the PIC meets the operator’s qualification criteria and demonstrates the ability to safely operate

the UAS in a manner consistent with how the UAS will be operated under the exemption, including evasive and emergency maneuvers and maintaining appropriate distances from persons, vessels, vehicles and structures. PIC qualification flight hours must be logged in a manner consistent with 14 C.F. R. § 61.51(b). Flights for the purposes of training the operator’s PICs are permitted under the terms of the exemption. However, training operations may only be conducted during dedicated training sessions. During training, proficiency, and experience

- buil ding 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.! 18 19. UAS operations may not be conducted duri ng 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 s pecial visual flight rules (SVFR) are not authorized.

20. The UA may not operate within 5 nautical miles of an airport reference point as

denoted on a current FAA

- published aeronautical chart unless a letter of agreement with that airport’s management is obtained, and the operation is conducted in accordance with a NOTAM as required by the operator’s COA. The letter of agreement with the airport management must be made available to the Administrator upon request.

21. The UA may not be operated less than 5 00 feet below or less than 2,000 feet horizontally 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 pre

determined location within the planned opera ting area and land or be recovered 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 f light unless (considering wind and forecast weather conditions) there is enough power to fly at normal cruising speed to the intended landing point and land the UA with 25% battery power remaining.

25. The operator must obtain an Air Traffic Organization (ATO) issued Certificate of Waiver or Authorization (COA) prior to conducting 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 wit h 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 large as practicable.

27. Before conduc ting 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.! 19 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.

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

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

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

pe rsons (persons other than the PIC, SO, operator trainees or essential persons), vessels, vehicles, and structures unless:

a. Barriers or structures are present that sufficiently protect nonparticipating persons from the UA and/or debris in the event of an accident. The operator must ensure that nonparticipating 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 determi ned 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 controll ed

- 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 oper ation 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 Saf ety Board (NTSB) per instructions contained on the NTSB Web site: www.ntsb.gov

.

2. Reasons Why An Exemption From The Requirements Of Section 61.113(a) And (b) Would Not Adversely Affect Safety.

QuadCam LLC submits tha t 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 2 Vision+ and DJI Phantom 3 UASs unless that PIC has demonstrated, by meeting minimum flight

- hour and cur rency requirements, that the PIC is able to safely operate the! 20 DJI Phantom 2 Vision+ or DJI Phantom 3 UAS in a manner consistent with the exemption, including evasive and emergency maneuvers and maintaining appropriate distances from people, vessels, vehic les and structures.

Considering QuadCam LLC ’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 Phantom 2 Vision+ or Phantom 3 UAS, QuadCam LLC submits that the additional manned airmanship experience of a commercially certificated pilot would not correlate to the airmanship skill s necessary for QuadCam LLC ’s specific proposed flight operations.

The FAA has previously granted relief from Section 61.113(a) and (b) specific to UAS, in circumstances similar, in all material respects, to those presented herein (e.g. Exemption

Nos. 110 62, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 11112, 11136, 11138, 11150, 11153, 11156, 11158, 11159, 11160, 11161).

QuadCam LLC will not allow any PIC to operate the DJI Phantom 2 Vision+ or DJI

Phantom 3 UAS unless that PIC has demonstrate d, by meeting minimum flight

- hour requirements or the DJI Phantom 2 Vision+ or DJI Phantom 3 UAS training and currency requirements, that the PIC is able to safely operate the DJI Phantom 2 Vision+ or DJI

Phantom 3 UAS in a manner consistent with this exem ption, 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 consistent with 14 C.F.R. § 61.51(b), 25 hours of tot al time as a UAS rotorcraft pilot (with a minimum of 5 hours of those hours as a UAS pilot operating the same make and model of UAS to be used for operations under the exemption). In addition to the hour requirements, the PIC must accomplish 3 takeoffs and landings in the preceding 90 days (for currency purposes).

As in Exemption Nos. 11062, 11138, and 11153, prior documented flight experience that was obtained in compliance with applicable regulations will ensure an equivalent level of safety during QuadC am LLC ’s proposed operations. The Administrator has held that prior documented flight experience that was obtained in compliance with applicable regulations would ensure safe operations, stating as follows:

In Exemption No. 11062, the FAA required that pr ior to conducting operations for the purpose of motion picture filming (or similar operations), the PIC must have accumulated and logged, in a manner consistent with 14 CFR 61.51(b), 25 hours of total time as a UAS rotorcraft pilot including at least 10 ho urs 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 minimum of 5 hours as a UAS pilot operating the same make and model of UAS to be used for operations under the exemption. For clarification, the FAA considers these minimum hour requirements to be inclusive rather than additive; i.e. 5 hours make and model time may be! 21 included in the 10 hours of multi

- rotor time and the 10 hours may be included in

the total 25 hour s of UAS rotorcraft time. In addition to the hour requirements, the PIC must accomplish 3 takeoffs and landings in the preceding 90 days (for currency purposes). The FAA finds that at a minimum, the flight

- hour requirements in Exemption No. 11062 are appro priate to practice and build proficiency in the skills necessary to safely conduct the petitioner’s proposed operations. The FAA also finds that prior documented flight experience that was obtained in compliance with applicable regulations would satisfy th is requirement. Training, proficiency, and experience

- building flights can also be conducted under the grant of exemption to accomplish the required flight time. During training, proficiency, and experience

- building flights the PIC is required to operate t he UA with appropriate

distances in accordance with 14 C.F.R 91.119. Exemption No. 11138 at page 15.

Accordingly, QuadCam LLC will ensure safe operations by not allowing any PIC to operate the DJI Phantom 2 Vision+ or 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 Phantom 2 Vision+ or DJI Phantom 3 UAS in a manner consistent with the exemption, including evasive and emergency maneuvers and

maintain ing appropriate distances from people, vessels, vehicles and structures.

3. Reasons Why An Exemption From The Requirements Of Section 91.7(a) Would Not Adversely Affect Safety.

The equivalent level of safety established by Section 91.7(a) will be maintai ned because prior to every flight, QuadCam LLC will ensure that the DJI Phantom 2 Vision+ or DJI

Phantom 3 UAS is in an airworthy condition based upon the UAS’s compliance with its operating documents and as stated in the conditions and limitations herein.

Additionally, the FAA has previously granted relief from Section 91.7(a) specific to UAS, in circumstances similar, in all material respects, to those presented herein (e.g. Exemption Nos. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 11 112, 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 mainta ined because

the altitude information of the DJI Phantom 2 Vision+ and DJI Phantom 3 UAs will be provided to the PIC via GPS equipment and a radio communications telemetry data link, which downlinks from the UA to the GCS for active monitoring of the fligh t path and altitude. This altitude information, combined with QuadCam LLC ’s operation of the DJI

Phantom 2 Vision+ and DJI Phantom 3 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 onboard the aircraft. Prior to! 22 each flight, a zero altitude initiation point is automatically established by the UASs at ground level.

The FAA has previously granted relief from Section 91. 121 specific to UAS, in circumstances similar, in all material respects, to those presented herein (e.g. Exemption 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 speci fications of the DJI Phantom

2 Vision+ and DJI Phantom 3 UASs; (2) the limitations on the proposed flight operations; and (3) the location of the proposed flight operations. Accordingly, QuadCam LLC will ensure that it will safely operate the battery power ed DJI Phantom 2 Vision+ and DJI

Phantom 3 UAs during daylight hours in VFR conditions, with enough battery power to fly for a total duration of 13.5 minutes to the first point of intended landing and, assuming normal cruising speed, to fly after that for at least 4.5 minutes.

Here, as in Exemption No. 11109, the technical specifications of the DJI Phantom 2

Vision+ and DJI Phantom 3 UASs; the limitations on the proposed flight operations; and the location of the proposed operations, will ensure an equival ent level of safety established by 14 C.F.R. Section 91.151(b). Furthermore, safety will be ensured as the DJI Phantom 2

Vision+ and DJI Phantom 3 UASs provide audible and visual warnings to the PIC at the GCS when the UAs experiences low battery voltage, the first warning occurring at approximately 33% remaining battery power, and again at approximately 10% remaining battery power. At the critically low battery level, the DJI Phantom Vision+ and DJI

Phantom 3 UASs will descend and land automatically.

Sign ificantly, previous exemptions granted by the FAA concerning Section 91.151 establish that safety is not adversely affected when the technical characteristics and operating limitations of the UAS are considered. Relief has been granted for manned

aircraft to operate at less than the minimums prescribed in Section 91.151, including Exemption Nos. 2689, 5745, and 10650. Moreover, the FAA has previously granted relief from Section 91.151 specific to UAS, in circumstances similar, in all material respects, to

t hose presented herein (e.g. Exemption Nos. 8811, 10808, 10673, 11042, 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 11136, 11138, 11150, 11153, 11156, 11157, 11158, 11159, 11160, 11161).

6. Reasons Why An Exemption From The Requirements O f Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), And 91.417(a) & (b) Would Not Adversely Affect Safety.

In seeking this exemption, QuadCam LLC submits that the equivalent level of safety with regard to the regulatory maintenance and alteration r equirements established by Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b) will be met! 23 because QuadCam LLC will use trained technicians to perform maintenance, alterations, or preventive maintenance on the UASs using the method s, techniques, and practices prescribed in the operating documents (i.e., the QuadCam LLC Aerial Operations Manual, Monthly Maintenance Log, and DJI Phantom 2 Vision+ and DJI Phantom 3 Instruction Manual). Furthermore, QuadCam LLC will document and maintai n all

maintenance records for the DJI Phantom 2 Vision+ and DJI Phantom 3 UASs.

Since the DJI Phantom 2 Vision+ and DJI Phantom 3 UASs will be inspected as prescribed by the operating documents, QuadCam LLC will maintain the equivalent level of safety

est ablished by Sections 91.405(a), 91.409(a)(1), and 91.409(a)(2). A copy of the DJI

Phantom 2 Vision+ and DJI Phantom 3 User Manuals are attached hereto as Exhibit C and D; a copy of the DJI Phantom 2 Vision+ and DJI Phantom 3 UAS Maintenance LOG is

attached hereto as Exhibit E.

Likewise, the exemption sought will not adversely affect safety because QuadCam LLC will use trained technicians to perform maintenance, alterations or preventive maintenance on the UAS using the methods, techniques, and practices pr escribed 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 Vision+ and DJI Phantom 3 UASs will b e performed by trained technicians. Maintenance will be documented and maintained utilizing the monthly maintenance log.

Significantly, previous exemptions 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.

In consideration of QuadCam LLC ’s proposed operating limitations, the operating documents, and the technical as pects of the DJI Phantom 2 Vision+ and DJI Phantom 3 UASs, QuadCam LLC 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 FAA has pre viously 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, QuadCam LLC requests that

th e FAA prescribe special conditions for the intended operation of the DJI Phantom 2

Vision+ and DJI Phantom 3 UASs, which contain such safety standards that the Administrator finds necessary to establish a level of safety equivalent to that established by

1 4 C.F.R. Part 21, Subpart H, and 14 C.F.R §§ 61.113(a) & (b), 91.7 (a), 91.121,! 24 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 purpose of

conduct ing 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 m ay prescribe special conditions pursuant to 14 C.F.R. § 21.16, for operation of the DJI Phantom 2 Vision+ and DJI Phantom 3 UASs, since the airworthiness regulations of 14 C.F.R. Part 21 do not contain adequate or appropriate safety standards, due to the n ovel or unusual design features of the aircraft. Section 21.16, entitled Special Conditions, states the following:

If the FAA finds that the airworthiness regulations of this subchapter do not contain adequate or appropriate safety standards for an aircra ft, aircraft engine, or propeller because of a novel or unusual design feature of the aircraft, aircraft engine or propeller, he prescribes special conditions and amendments thereto for the product. The special conditions are issued in accordance with Part 11 of this chapter and contain such safety standards for the aircraft, aircraft engine or propeller as the FAA finds necessary to establish a level of safety equivalent to that established in the regulations.

See 14 C.F.R. § 21.16.

Therefore, in accordanc e 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 Phantom 2

Vision+ and DJI Phantom 3 UASs, 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 Register, stating: The Rules

From Which QuadCam LLC Seeks Exemption:

QuadCam LLC 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).

A Brief Description Of The Nature Of The Exemption QuadCam LLC

Seeks:

This exemption will permit QuadCam LLC to commercially operate an Unmanned Aircraft System (UAS) for the purpose of conducting aerial video and photography over certain areas of the United States.! 25 G. Any Additional Information, Views, Or Arguments Available To Support QuadCam LLC ’s Request.

This Petition is made pursuant to the FAA Modernization and Reform Act of 2012 (FMRA) Section 333, which directs the Secreta ry of Transportation to determine if certain UAS may operate safely in the NAS. As such, QuadCam LLC ’s request for exemption may be granted pursuant to the authority of FMRA Section 333 and 14 C.F.R. Part 11, as

set forth above.

FMRA Section 333 sets fort h 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 d iscussed in detail above, QuadCam LLC will operate the DJI Phantom 2

Vision+ and DJI Phantom 3 UASs safely in the NAS, without creating a hazard to users of the NAS, or the public, or otherwise pose a threat to national security.

CONCLUSION

As set forth herein, QuadCam LLC seeks an exemption pursuant to 14 C.F.R. § 11.61 and Section 333 of the FAA Modernization and Reform Act of 2012 (FMRA), which will permit safe operation of the DJI Phantom 2 Vision+ and DJI Phantom 3 UASs commercially, without an airwo rthiness certificate, for the limited purpose of conducting aerial video and photography over certain areas of the United States. By granting this Petition, the FAA Administrator will be fulfilling the Congressional mandate of the FAA

Modernization and Ref orm Act of 2012, while also advancing the interests of the public, by allowing QuadCam LLC to safely, efficiently, and economically operate the DJI

Phantom 2 Vision+ and DJI Phantom 3 UASs commercially within the NAS.

WHEREFORE , in accordance with the Fed eral Aviation Regulations and the FAA Modernization and Reform Act of 2012, Section 333, QuadCam LLC 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), 91.1 21, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b), and permit Leading Edge to operate the DJI

Phantom 2 Vision+ and DJI Phantom 3 UASs commercially for the purpose of conducting aerial video and photography over certain are as of the United States.! 26 Dated: August 16 , 2015 Respectfully submitted,

QuadCam LLC Zachary Marhafer

QuadCam LLC Zachary Ma rhafer

1331 Saddle Ct Palm Harbor, FL 34683

727

- 510

- 0559

Appendices :

A

– DJI Phantom 2 Vision+ Specifications Data Sheet

B

– DJI Phantom 3 Specifications Data Sheet

C

– Link to DJI Phantom 2 Vision+ Manufacturer’s User Manual

D

– Link to DJI Phantom 3 Manufacturer’s User Manual! 27 APPENDIX

– A

DJI PHANTOM 2 VISION+ TECHNICAL SPECIFICATIONS

QuadCam LLC 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 set 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 Aircraft 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 Yaw Angular V elocity

- 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

– 14M

1.1.3.4 Resolution

– 4384x3288 4.1.3.5 HD Video Recording

– 1080p30 & 720p 4.1.3.6 Recording Field of View

- 110 0 /85 0

1.1.4 Transmitter 1.1.4.1 Operating Frequency

– 5.728GHz

– 5.85GHz 1.1.4.2 Communication Distance (unobstructed)

– FCC Compliance: 800m 1.1.4.3 Receiver Sensitivity (1 %PER)

- - 93dBm

1.1.4.4 Transmitter Power

– FCC Compliance: 100mW 1.1.4.5 Working Voltage

– 120mA@3.7V! 28 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

– 20dB m 1.1.5.4 Power Consumption

– 2W! 29 APPENDIX

– B

DJI PHANTOM 3 TECHNICAL

SPECIFICATIONS

QuadCam LLC 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 set 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 softwar e provides real

- time altitude and location information to the PIC via the linked monitor (smart phone/tablet devices)



### 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 ·	Vertical:	+/

- 0.1	m	(when	Vision	Positioning	is	active)	or	+/

- 0.5	m ·	Horizontal:	+/

- 1.5	m

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/G LONASS 

### Camera

SENSOR Sony	EXMOR	1/2.3”	Effective	pixels:	12.4	M	(total	pixels:	12.76	M)

LENS FOV	94°	20	mm	(35	mm	format	equivalent)	f/2.8,	focus	at	∞

ISO	RANGE

100

- 3200	(video)	100

- 1600	(photo)

SHUTTER	SPEED

8s

- 1/8000s

IMAGE	MAX	SIZE

4000	x	3000

STILL	PH OTOGRAPHY	MODES ·	Single	Shot ·	Burst	Shooting:	3/5/7	shots ·	Auto	Exposure	Bracketing	(AEB):	3/5

·	Bracketed	Frames	at	0.7EV	Bias

·	Time

- lapse! 30 VIDEO	RECORDING	MODES 

### Phantom	3	Professional

·	UHD:	4096x2160p	24/25,	3840x2160p	24/25/30 ·	FHD:	1920x1080p	24/2 5/30/48/50/60 ·	HD:	1280x720p	24/25/30/48/50/60 

### Phantom	3	Advanced

·	FHD:	1920x1080p	24/25/30/48/50/60 ·	HD:	1280x720p	24/25/30/48/50/60

SUPPORTED	SD	CARD	TYPES

Micro	SD Max	capacity:	64	GB.	Class	10	or	UHS

- 1	rating	required

MAX	BITRATE	OF	VIDEO	STORAGE 

### Ph antom	3	Professional

60	Mbps 

### Phantom	3	Advanced

40	Mbps

SUPPORTED	FILE	FORMATS ·	FAT32/exFAT ·	Photo:	JPEG,	DNG ·	Video:	MP4,	MOV	(MPEG

- 4	AVC/H.264)

OPERATING	TEMPERATURE

0°C	to	40°C 

### Gimbal

CONTROLLABLE	RANGE

Pitch

- 90°	to	+30°

STABILIZATION

3

- axis	(pitch, roll,	yaw) 

### Vision Positioning

MAX	VELOCITY Less	than	8	m/s	(when	2	m	above	ground)

ALTITUDE	RANGE

30	cm

- 300	cm

OPERATING	RANGE

30	cm

- 300	cm

OPERATING	ENVIRONMENT Surface	with	clear	pattern	and	adequate	lighting	(Lux	>	15) 

### Remote

Controller

OPERATING	FREQU ENCY

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! 31 TRANSMITTER	POWER	( EIRP)

·	FCC:	20	dBm

·	CE:	16	dBm

WORKING	VOLTAGE

1.2	A	@7.4	V 

### Battery Charger

VOLTAGE

17.4	V

RATED	POWER 

### Phantom	3	Professional

·	100	W 

### Phantom	3	Advanced

·	57	W

CAPACITY

4480	mAh

VOLTAGE

15.2	V

BATTERY	TYPE

LiPo	4S

ENERGY

68	Wh

NET	WEIGHT 365	g

MAX	FLIGHT TIME Approximately	23	minutes

OPERATING	TEMPERATURE

- 10°C	to	40°C

MAX	CHARGING	POWER

100	W 

### App	/	Live

View

MOBILE	APP DJI	Pilot

EIRP

100mW LIVE	VIEW	WORKING	FREQUENCY

2.4GHz	ISM LIVE	VIEW	QUALITY 720P	@	30fps	(depending	on	conditions	and	mobile	device)

LA TENCY 220ms	(depending	on	conditions	and	mobile	device) REQUIRED	OPERATING	SYSTEMS

·	iOS	8.0	or	later

·	Android	4.1.2	or	later

RECOMMENDED	DEVICES ·	iOS:	iPhone	5s,	iPhone	6,	iPhone	6	Plus,	iPad	Air,	iPad	Air	Wi

- Fi	+	Cellular,	iPad
mini	2,	iPad	mini	2	Wi

- Fi	+	Cellular,	iPad	Air	2,	iPad	Air	2	Wi

- Fi	+	Cellular,	iPad mini	3,	and	iPad	mini	3 Wi

- Fi	+	Cellular.	This	app	is	optimized	for	iPhone	5s,
iPhone	6,	and	iPhone	6	Plus ·	Android:	Samsung	S5,	Note	3,	Sony	Xperia	Z3,	Google	Nexus	7	II,	Google	Nexus
9,	Mi	3,	Nubia	Z7	mini ·	*Support	for	additional	Android	devices	available	as	testing	and	dev elopment	continues! 32 !

!

APPENDIX

– C

DJI Phantom 2 Vision+ Manufacturer’s User Manual

http://download.djiinnovations.com/downloads/phant

om_2/en/PHA NTOM2_User_Manual_v1.4_en.pdf! 33 APPENDIX

– D

DJI Phantom 3 Manufacturer’s User Manual

http://download. djiinnovations.com/downloads/phantom_3/en/Pha

ntom_3_Advanced_User_Manual_v1.2_en.pdf

!