## PETITION FOR EXEMPTION VIA SECTION 333

for White Rose Production

Alex Hsiao 1308 Factory Pl #311 Los Angeles, CA 90013 EMAIL: info@whiteroseproduction.com

I, Alex Hsiao, am applying for a petition for an exemption via Section 333, in accordance with the statutory criteria provided in Section 333 of Public Law 112

− 95 in reference to 49 U.S.C. § 44704, and in consideration of the size, weight, speed, and limited operating area associated with the aircraft and its operation,

The UAS to be operated is a DJI Phantom 3 and the purpose is for aerial data collection

. Because the nature of this operation is similar to other circumstances in its category, this petition is requesting for a grant of exemption based on Grants of Exemption Nos. 11062 to Astraeus Aerial (see Docket No. FAA

− 2014

− 0352), 11109 to Clayco, Inc. (see Docket No. FAA

− 2014

− 0507), 11112 to VDOS Global, LLC (see Docket No. FAA

− 2014

− 0382), 11213 to Aeryon Labs, Inc. (see Docket No. FAA

− 2014

− 0642), and 12645 to Allied Drones (see Docket No. FAA-2014-0804)

. There is good cause to find that the UAS operation is enabled by this exemption because it is in the public interest that this is a safer alternative than a manned aircraft of significantly greater proportions, carrying crew in addition to flammable fuel . The UAS that will be operated requires no passengers or crew.

TYPE of sUAS: DJI Phantom 3

CHARACTERISTICS:

• Automatic flight height limiters are set to comply with FAA regulations

• GPS system keeps aircraft stable and in place without human intervention; also allows for tracking and mapping to allow for safe flight route planning

• It can fly back to a designated home point in event that radio signal is lost

• Under 55 lbs

• Maximum speed < 35mph

REQUESTED Operation/ Mission: Aerial surveying, videography, and photography.Regarding the Unmanned Aircraft System

1. PETITIONERS SHOULD DESCRIBE HOW THE PROPOSED UAS OPERATION WILL BE SAFELY CONDUCTED TO MINIMIZE RISK TO THE NAS OR TO PERSONS AND PROPERTY ON THE GROUND. SPECIFICALLY, PETITIONERS SHOULD DESCRIBE THE DESIGN AND OPERATIONAL CHARACTERISTICS FOR THE TYPE(S) OF UAS THEY INTEND TO OPERATE, E.G. AIRCRAFT PERFORMANCE AND PERFORMANCE LIMITATIONS, OPERATING PROCEDURES, AND AIRCRAFT LOADING INFORMATION IN AS MUCH DETAIL AS POSSIBLE. THIS COULD BE PROVIDED IN THE PETITION OR IN AN AIRCRAFT FLIGHT MANUAL OR SIMILAR DOCUMENT.

AIRCRAFT TYPE:

Currently we are flying the DJI Phantom 3, which has built in safety features and limitations that are designed to minimize risk to persons and property on the ground. Maximum height and maximum distance can be set in software to comply with FAA regulation. The Phantom 3 has built in GPS so that it can stabilize itself and remain in one place without requiring the operator’s input. It also has cameras on the bottom of it’s body to help determine it’s position and guide it’s flight. The software can also automatically take o ff and land the quadcopter. In case radio contact is lost with the remote control, a safety feature allows it to return to a home point that can be designated safely by the operator. In addition, the software allows the operator to monitor progress and health of the battery, and automates a warning for the operator to land at 30% battery capacity.

OPERATING PROCEDURES.

The operator will observe the following:

1. Inspect condition of aircraft and determine if it is in a condition for safe flight.

2. Scout location, assess geography/weather conditions and identify potential obstacles/hazards.

3. Plan the safest route to fly and identify safest takeo ff /landing zones. Safety is the number 1 priority.4. Observe current FAA airspace requirements. Fly below 400 ft, within line of sight. Do not fly over people, stadiums or sports events, near
emergency response e ff orts, near aircraft or airports, nor under the influence.

5. Always keep aircraft in visual line of sight.

2. PETITIONERS SHOULD DESCRIBE ANY PROCEDURES THEY WOULD IMPLEMENT, SUCH AS PRE-FLIGHT INSPECTIONS, MAINTENANCE, AND REPAIR, TO ENSURE THAT THE UAS IS IN A CONDITION FOR SAFE FLIGHT. THIS COULD BE PROVIDED IN THE PETITION, AN AIRCRAFT FLIGHT MANUAL, A MAINTENANCE AND INSPECTION MANUAL, OR SIMILAR DOCUMENT.

MANDATORY PREFLIGHT CHECKLIST

1. Check to see that firmware and software is up to date.

2. Check to see that the propellors are undamaged. If damaged, replace propellors. Spares are always kept on hand.

3. Inspect aircraft for visual signs of damage. If there is substantial damage that may impact the ability of the aircraft to fly safely, do not fly. This includes visible damage to the rotors, landing structure, or other elements necessary to takeo ff /fly or land.

4. Turn on Quadcopter and controller. Check status of GPS signal, battery health, and radio control signal. Local maps are loaded to track flight records and also provide operator with geographical knowledge of the location. Be aware of warning messages.

5. Fly when it is safe to do so.

MAINTENANCE

1. Aircraft will undergo regular maintenance to ensure safe operation.

3. THE PETITIONER SHOULD DESCRIBE THE RADIO FREQUENCY (RF) SPECTRUM USED FOR CONTROL OF THE UAS AND ASSOCIATED EQUIPMENT THAT IS PART OF THE UAS (I.E., SENSORS, CAMERAS, ETC.), AND WHETHER IT COMPLIES WITH FEDERAL COMMUNICATIONS COMMISSION (FCC) OR OTHER APPROPRIATE GOVERNMENT OVERSIGHT AGENCY REQUIREMENTS.

The radio frequency and spectrum used by the sUAS (DJI Phantom 3) is in compliance with FCC or other appropriate government oversight agency requirements.4. PETITIONERS SHOULD DESCRIBE THE QUALIFICATIONS REQUIRED OF ANY PIC(S) WHO WILL BE DIRECTLY RESPONSIBLE FOR THE OPERATION OF THE UAS, INCLUDING INFORMATION SUCH AS: THE LEVEL OF AIRMAN CERTIFICATE HELD; ANY APPLICABLE TRAINING RELATED TO THE OPERATION; AND ANY MINIMUM HOURS OF FLIGHT EXPERIENCE REQUIRED BY THE PIC(S), BOTH TOTAL FLIGHT TIME AND THE TIME WITH THE PARTICULAR UAS. IF THE OPERATION WOULD USE VISUAL OBSERVERS, PETITIONERS SHOULD DESCRIBE THEIR ROLES AND QUALIFICATIONS.

We have a 60 hour training program so operators understand all safety procedures, protocol, and FAA regulations before flying. Operators familiarize themselves with all aspects of the aircraft, radio control, and software applications. During operation, we utilize a buddy system. The operator controls the craft from the ground while using his monitor as a reference. A second visual observer provides visual contact with the aircraft at all times, provides navigational information and relays observations that would be

imperative to the operator’s safe control of the aircraft.

Operators will keep current with FAA laws and regulations.

5. PETITIONERS SHOULD DESCRIBE THE MEDICAL STANDARDS AND CERTIFICATION OF THE PIC(S) DIRECTLY RESPONSIBLE FOR THE OPERATION OF THE UAS.

Operators should be in good health and standing in order to operate. They shall not operate under the influence.

6. PETITIONERS SHOULD FULLY DESCRIBE THEIR INTENDED UAS OPERATION(S). PETITIONERS SHOULD DESCRIBE HOW THE PROPOSED OPERATION(S) WOULD NOT ADVERSELY AFFECT SAFETY, OR HOW THEY WOULD PROVIDE A LEVEL OF SAFETY AT LEAST EQUIVALENT TO THAT PROVIDED BY THE RULE FROM WHICH EXEMPTION IS SOUGHT. PETITIONERS SHOULD ADDRESS ANY PLANS TO IMPLEMENT CLEARLY DEFINED OPERATIONAL BORDERS AND PROCEDURES TO ENSURE PUBLIC SAFETY, WHICH INCLUDES PERSONS AND PROPERTY BOTH IN THE AIR AND ON THE GROUND. THIS CAN BE DESCRIBED IN THE PETITION, IN AN OPERATIONS MANUAL, OR SIMILAR DOCUMENT. NOTE: THE FAA WILL CLOSELY EXAMINE THE PROPOSED OPERATION(S) WITH RESPECTTO SAFETY OF FLIGHT, NAS SAFETY CONSIDERATIONS, AND THE SAFETY OF THE NONPARTICIPATING PERSONS AND PROPERTY DURING THE OPERATIONAL PERIOD AND WITHIN THE OPERATIONAL AREA.

Operators will observe the operating procedures.

OPERATING PROCEDURES.

The operator will observe the following:

1. Inspect condition of aircraft and determine if it is in a condition for safe flight.2. Scout location, assess geography/weather conditions and identify potential obstacles/hazards. Determine whether or not potential obstacles and hazards pose a threat to safe operation. Do not fly if determined unsafe.

3. Plan the safest route to fly and identify safest takeo ff /landing zones. Safety is the number 1 priority.

4. Observe current FAA airspace requirements. Fly below 400 ft, within line of sight. Do not fly over people, stadiums or sports events, near
emergency response e ff orts, near aircraft or airports, nor under the influence.

5. Always keep aircraft in visual line of sight.

6. Respect local laws.

7. If possible, have an additional person observe the aircraft and oversee aircraft operation to ensure safe execution.

8. It’s recommended to land the aircraft before the battery is fully depleted, to ensure that there is enough time to land safely and to minimize the occurrence of emergency landings.

7. PETITIONERS SHOULD SPECIFY THE PROPOSED MAXIMUM OPERATING SPEED AND ALTITUDE, AND DESCRIBE MINIMUM FLIGHT VISIBILITY AND DISTANCE FROM CLOUDS FOR THEIR INTENDED OPERATION(S). PETITIONERS SHOULD DESCRIBE POTENTIAL HAZARDS AND SAFETY MITIGATIONS ASSOCIATED WITH THESE PROPOSED CONDITIONS. THESE ISSUES CAN BE ADDRESSED IN THE PETITION, AN OPERATIONS MANUAL, OR SIMILAR DOCUMENT.

The maximum operating speed the sUAS can achieve is less than 35 miles per hour. Maximum altitude is less than 100m Above Ground Level (software limit) which is less than the maximum limit of 400 ft AGL.

The sUAS will not fly close to clouds, birds, vehicles and other physical objects that present potential hazards to minimize the chance for accidents. We plan to do most operations during the day and good weather conditions. We will avoid flying at night and only when deemed necessary and safe.

8. PETITIONERS SHOULD DESCRIBE THE CHARACTERISTICS OF THE AREA OF INTENDED OPERATION(S) AND THE ASSOCIATED POTENTIAL HAZARDS, IN ACCORDANCE WITH THE STATUTORY MANDATE UNDER SECTION 333

The area of intended operation will vary, but will be mostly in the state of CA. Potential hazards include clouds, birds, trees, and other physical objects. Weather is commonly good for operation, but we will avoid rainy days, high winds, and other bad weather. We will also avoid tall structures and infrastructure and stay at a safe distance when operating.9. PETITIONERS SHOULD DESCRIBE IF THEY INTEND TO OPERATE IN THE PROXIMITY OF ANY AIRPORTS, IN ACCORDANCE WITH THE STATUTORY MANDATE UNDER SECTION 333 REGARDING PROXIMITY TO AIRPORTS.

No, we shall not operate in proximity of any airports, in accordance with the statutory mandate.

10. THE UAS MUST BE OPERATED WITHIN VISUAL LINE-OF-SIGHT (VLOS), IN ACCORDANCE WITH THE STATUTORY MANDATE UNDER SECTION 333(B)(1). PETITIONERS SHOULD DESCRIBE HOW THEY INTEND TO COMPLY WITH HIS MANDATE.

The operator will find the clearest takeo ff /landing point that allow the greatest visibility for the planned flight route. The remote has a tracking system that maps the current position of the aircraft and measures the distance and height it can travel. Operator will be aware of the maximum flight distance it can travel before losing visibility. To ensure maximum safety, operator will try to utilize a buddy system when possible. A second “co-pilot” will have a pair of binoculars and his sole responsibility is to visually track the aircraft and identify/report potential hazards and obstacles during the operation.

11. PETITIONERS SHOULD DESCRIBE ANY PROCEDURES THEY WOULD IMPLEMENT FOR CONDUCTING A PREFLIGHT SAFETY RISK ASSESSMENT TO DETERMINE THAT THE UAS IS IN A CONDITION FOR SAFE FLIGHT (14 CFR § 91.7(B)) AND THAT THE PLANNED OPERATION CAN BE COMPLETED SAFELY. THESE PROCEDURES CAN BE ADDRESSED IN THE PETITION, AN AIRCRAFT FLIGHT MANUAL, OPERATIONS MANUAL, OR SIMILAR DOCUMENT.

The Phantom 3 has built-in safety features that the operator can utilize.

MANDATORY PREFLIGHT CHECKLIST

1. Check to see that firmware and software is up to date.

2. Check to see that the propellors are undamaged. If damaged, replace propellors. Spares are always kept on hand.

3. Inspect aircraft for visual signs of damage. If there is substantial damage that may impact the ability of the aircraft to fly safely, do not fly. This includes visible damage to the rotors, landing structure, or other elements necessary to takeo ff /fly or land.

4. Turn on Quadcopter and controller. Check status of GPS signal, battery health, and radio control signal. Local maps are loaded to track flight records and also provide operator with geographical knowledge of the location. Be aware of warning messages.

5. Fly when it is safe to do so.12. IF PETITIONERS INTEND TO CONDUCT OPERATIONS WHICH HAVE EXISTING REQUIREMENTS TO NOTIFY FLIGHT STANDARDS DISTRICT OFFICES (FSDOS) PRIOR TO OPERATIONS – SUCH AS MOTION PICTURE AND TELEVISION FILMING, OR PIPELINE AND POWERLINE PATROL – PETITIONERS SHOULD DESCRIBE THEIR INTENDED COORDINATION IN THIS REGARD FOR THEIR PROPOSED OPERATION(S).

We do not intend for filming to be done for motion picture and television filming, or pipeline and power line patrol.

13. THE FAA INTENDS TO REQUIRE ENTITIES WHO OBTAIN AN EXEMPTION UNDER THIS PROCESS TO ALSO OBTAIN A CERTIFICATE OF WAIVER OR AUTHORIZATION (COA) FROM THE FAA AIR TRAFFIC ORGANIZATION PRIOR TO CONDUCTING OPERATION(S) IN THE NAS. THE COA APPLICATION IS AVAILABLE HERE.



## Conditions and Limitations

The operator will comply with the following conditions and limitations.

Failure to comply with any of the conditions and limitations of this grant of exemption will be grounds for the immediate suspension or rescission of this exemption.

1. Operations authorized by this grant of exemption are limited to the DJI Phantom 3 when weighing less than 55 pounds including payload. Proposed operations of any other aircraft will require a new petition or a petition to amend this exemption.

2. Operations for the purpose of closed-set motion picture and television filming are not permitted.

3. The UA may not be operated at a speed exceeding 87 knots (100 miles per hour). The exemption holder may use either groundspeed or calibrated airspeed to determine compliance with the 87 knot speed restriction. In no case will the UA be operated at airspeeds greater than the maximum UA operating airspeed recommended by the aircraft manufacturer.

4. The UA must be operated at an altitude of no more than 400 feet above ground level (AGL). Altitude must be reported in feet AGL.

5. The UA 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 or U.S. driver’s license.

6. All operations must utilize a visual observer (VO). The UA must be operated within the visual line of sight (VLOS) of the PIC and VO at all times. The VO may beused to satisfy the VLOS requirement as long as the PIC always maintains VLOS capability. The VO and PIC must be able to communicate verbally at all times; electronic messaging or texting is not permitted during flight operations. The PIC must be designated before the flight and cannot transfer his or her designation for the duration of the flight. The PIC must ensure that the VO can perform the duties required of the VO.

7. This exemption and all documents needed to operate the UAS and conduct its operations in accordance with the conditions and limitations stated in this grant of exemption, are hereinafter referred to as the operating documents. The operating documents must be accessible during UAS operations and made available to the Administrator upon request. If a discrepancy exists between the conditions and limitations in this exemption and the procedures outlined in the operating documents, the conditions and limitations herein take precedence and must be followed.

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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 or any law enforcement o ffi cial upon request. The operator must also present updated and revised documents if it petitions for extension or amendment to this grant of exemption. If the operator determines that any update or revision would a ff ect the basis upon which the FAA granted this exemption, then the operator must petition for an amendment to its grant of exemption. The FAA’s UAS Integration O ffi ce (AFS

− 80) may be contacted if questions arise regarding updates or revisions to the operating documents.

8. Any UAS that has undergone maintenance or alterations that a ff ect the UAS operation or flight characteristics, e.g., replacement of a flight critical component, must undergo a functional test flight prior to conducting further operations under this exemption. Functional test flights may only be conducted by a PIC with a VO and must remain at least 500 feet from other people. The functional test flight must be conducted in such a manner so as to not pose an undue hazard to persons and property.

9. The operator is responsible for maintaining and inspecting the UAS to ensure that it is in a condition for safe operation.

10. Prior to each flight, the PIC must conduct a pre-flight inspection and determine the UAS is in a condition for safe flight. The pre-flight inspection must account for all potential discrepancies, e.g., inoperable components, items, or equipment. If the inspection reveals a condition that a ff ects the 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.11. The operator must follow the UAS manufacturer’s maintenance, overhaul, replacement, inspection, and life limit requirements for the aircraft and aircraft components.

12. Each UAS operated under this exemption must comply with all manufacturer safety bulletins.

13. Under this grant of exemption, a PIC must hold either an airline transport, commercial, private, recreational, or sport pilot certificate. The PIC must also hold a current FAA airman medical certificate or a valid U.S. driver’s license issued by a state, the District of Columbia, Puerto Rico, a territory, a possession, or the Federal government. The PIC must also meet the flight review requirements specified in

14 CFR § 61.56 in an aircraft in which the PIC is rated on his or her pilot certificate.

14. The operator may not permit any PIC to operate unless the PIC demonstrates the ability to safely operate the UAS in a manner consistent with how the UAS will be

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operated under this exemption, including evasive and emergency maneuvers and maintaining appropriate distances from persons, vessels, vehicles, and structures. PIC qualification flight hours and currency must be logged in a manner consistent with

14 CFR § 61.51(b). Flights for the purposes of training the operator’s PICs and VOs (training, proficiency, and experience-building) and determining the PIC’s ability to safely operate the UAS in a manner consistent with how the UAS will be operated under this exemption are permitted under the terms of this exemption. However, training operations may only be conducted during dedicated training sessions. During training, proficiency, and experience-building flights, all persons not essential for flight operations are considered nonparticipants, and the PIC must operate the UA with appropriate distance from nonparticipants in accordance with 14 CFR § 91.119.

15. UAS operations may not be conducted during night, as defined in 14 CFR § 1.1. All operations must be conducted under visual meteorological conditions (VMC). Flights under special visual flight rules (SVFR) are not authorized.

16. The UA may not operate within 5 nautical miles of an airport reference point (ARP) as denoted in the current FAA Airport/Facility Directory (AFD) or for airports not denoted with an ARP, the center of the airport symbol as denoted on the current FAA-published aeronautical chart, unless a letter of agreement with that airport’smanagement is obtained or otherwise permitted by a COA issued to the exemption holder. The letter of agreement with the airport management must be made available to the Administrator or any law enforcement o ffi cial upon request.

17. The UA may not be operated less than 500 feet below or less than 2,000 feet horizontally from a cloud or when visibility is less than 3 statute miles from the PIC.

18. For tethered UAS operations, the tether line must have colored pennants or streamers attached at not more than 50 foot intervals beginning at 150 feet above the surface of the earth and visible from at least one mile. This requirement for pennants or streamers is not applicable when operating exclusively below the top of and within 250 feet of any structure, so long as the UA operation does not obscure the lighting of the structure.

19. If the UAS loses communications or loses its GPS signal, the UA must return to a pre-determined location within the private or controlled-access property.

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

21. The PIC is prohibited from beginning a flight unless (considering wind and forecast weather conditions) there is enough available power for the UA to conduct the intended operation and to operate after that for at least 5 minutes or with the reserve power recommended by the manufacturer if greater.

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23. All aircraft operated in accordance with this exemption must be identified by serial number, registered in accordance with 14 CFR part 47, and have identification (N

− Number) markings in accordance with 14 CFR part 45, Subpart C. Markings must be as large as practicable.

24. Documents used by the operator to ensure the safe operation and flight of the UAS and any documents required under 14 CFR §§ 91.9 and 91.203 must be available to the PIC at the Ground Control Station of the UAS any time the aircraft is operating.

These documents must be made available to the Administrator or any law enforcement

o ffi cial upon request.

25. The UA must remain clear and give way to all manned aviation operations and activities at all times.

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

27. All Flight operations must be conducted at least 500 feet from all nonparticipating persons, vessels, vehicles, and structures unless:a. Barriers or structures are present that su ffi ciently 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 in a manner ensuring the safety of nonparticipating persons; and

b. The owner/controller of any vessels, vehicles, or structures has granted permission for operating closer to those objects 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.

The PIC, VO, operator trainees or essential persons are not considered nonparticipating persons under this exemption.

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

29. Any incident, accident, or flight operation that transgresses the lateral or vertical boundaries of the operational area as defined by the applicable COA must be reported

22. Air Tra ffi c Organization (ATO) Certificate of Waiver or Authorization (COA). All operations shall be conducted in accordance with an ATO-issued COA. The exemption holder may apply for a new or amended COA if it intends to conduct operations that cannot be conducted under the terms of the enclosed COA.

to the FAA's UAS Integration O ffi ce (AFS

− 80) within 24 hours. Accidents must be reported to the National Transportation Safety Board (NTSB) per instructions contained on the NTSB Web site: www.ntsb.gov.

If this exemption permits operations for the purpose of closed-set motion picture and television filming and production, the following additional conditions and limitations apply.

30. The operator must have a motion picture and television operations manual (MPTOM) as documented in this grant of exemption.

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31. At least 3 days before aerial filming, the operator of the UAS a ff ected by this exemption must submit a written Plan of Activities to the local Flight Standards District O ffi ce (FSDO) with jurisdiction over the area of proposed filming. The 3- day notification may be waived with the concurrence of the FSDO. The plan of activities must include at least the following:a. Dates and times for all flights;

b. Name and phone number of the operator for the UAS aerial filming conducted

under this grant of exemption;

c. Name and phone number of the person responsible for the on-scene operation of

the UAS;

d. Make, model, and serial or N

− Number of UAS to be used;

e. Name and certificate number of UAS PICs involved in the aerial filming;

f. A statement that the operator has obtained permission from property owners

and/or local o ffi cials to conduct the filming production event; the list of those

who gave permission must be made available to the inspector upon request;

g. Signature of exemption holder or representative; and

h. A description of the flight activity, including maps or diagrams of any area, city,

town, county, and/or state over which filming will be conducted and the altitudes essential to accomplish the operation.

32. Flight operations may be conducted closer than 500 feet from participating persons consenting to be involved and necessary for the filming production, as specified in the exemption holder’s MPTOM.

Unless otherwise specified in this grant of exemption, the UAS, the UAS PIC, and the UAS operations must comply with all applicable parts of 14 CFR including, but not limited to, parts 45, 47, 61, and 91.