July

7, 2015
Attn: U. S. Department of Transportation Docket Operations West Building Ground Floor, Room w12

- 140 1200 New Jersey

Ave, SE Washington, DC 20590
RE: HANSEN PRODUCTION SERVI CES REQUEST S AN EXEMPTION FROM THE REQUIREMENTS OF TITLE 14 OF THE CODE OF FEDERAL REGULATIONS SECTIONS 61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), AND 91.417(a) & (b) CONCERNING COMMERCIAL OPERATI ON OF DJ I In spire 1 UN MANNED AIRCRAFT SYSTEMS PURSUANT TO SECTI ON 333 OF THE FAA MODERNIZATION AND REFORM ACT OF 2012 (PUBLIC LAW 112

- 95)
Peter Hansen President Hansen Production Services 11 L ake Valley

Ct Simpsonville, SC 29681 864

- 525

- 5724 hps@hansenproductionservices.com**SUMMARY**

HANSEN PRODUCTION SERVI CES seeks exemption from the requirements of 14 C.F.R §§ 61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b), to operate an Unmanned Aircraft Sy stem (DJ I Inspire 1 ) pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (FMRA). This exemption will permit HANSEN PRODUCTION SERVI CES to operate an Unmanned Aircraft Sy stem (UAS) for limited commercial purpose s of conducting aerial video and photograph y of manufacturing plants , residential and commercial real estate, civil landscapes and events over certain areas of the United States.

**INTRODUCTION AND INTERESTS OF THE PETITIONER**
HANSEN PRODUCTION SERVI CES has for over twent y ye ars provided its clients (which includ e private sector businesses, non - profits, and ministries ) with expertise and knowledge in video and multimedia marketing, advertising, public relations and training using advanced technologies and solutions. HANSEN PRODUCTION SERVI CES has worked on hundreds of productions over the past 20 ye ars in all t ypes of locations with a perfect client and employee safet y record. In the p ast we have supplied our clients aerial video and photography using commercial aircraft. The objective of HANSEN PRODUCTION SERVICES and our Unmanned Aircraft Sy stem (DJI Inspire 1 ) aerial operations is to provide a more affordable, high

- quality production sy stem for a variet y of manufacturing , commercial, public, and residential uses, specificall y targeting

• Views of commercial and manufacturing facilities

• Facilities of non

- profit organizations

• Real

- estate marketing

• Economic development

• Civic landmarks

• Special event coverage
S taff has safel y flown small RC electric quadcopters recreationall y for approximately 1 year without incident.**BACKGROUND** Unmanned Aircraft Sy stems: DJIInspire 1, UAS
HANSEN PRODUCTION SERVI CES seeks an exemption to operate DJI Inspire 1 sy stem for compensation or hire within the NAS. The DJ I Inspire 1 is vertical takeoff and landing (VTOL) Unmanned Aircraft (UA) with a Ground Control Station (GCS) utilizing electronic tablet or smart phone s ys t ems. The DJ I Inspire 1 has a maximum gross weight of approximately 6.5 lb. while having a diagonal dimension of 20 inches , a maximum speed of approximately 22 mps and a maximum flying height of 400'. The DJ I Inspire 1 is equipped with four main rotors; dri ven b y Lithium Poly

mer battery

powered electric motors.
The DJ I Inspire 1 that will be operated b y HANSEN PRODUCTION SERVI CES will be registered in accordance with 49 U.S.C. 44103, Registration of Aircraft, as well as 14 C.F.R Part 47, Aircraft Registrat ion, and marked in accordance with 14 C.F.R. Part 45, I dentification and Registration Marking.
**BASIS FOR PETITION** Petitioner, HANSEN PRODUCTION SERVICES , pursuant to the provisions of the Federal Aviation Regulations (14 C.F.R. § 11.61) and the FAA Modernization and Reform Act of 2012 (FMRA), Section 333, Special Rules for Certain Unmanned Aircraft Sy stems, hereby petitions the Administrator to commercial ly operate the DJ I In spire 1 , UAS in the National Airspace Sy stem (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 conside ration of the speed, weight, size, and limited operating area associated with the unmanned aircraft and its operation, HANSEN PRODUCTION SERVICES’ operation of DJ I Inspire 1 UAS meets the conditions of FMRA Section 333 and therefore, will not require an ai rworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H. Accordingl y, HANSEN PRODUCTI ON SERVICES 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 fo r maintenance that only appl y to aircraft with an airworthiness certificate.
HANSEN PRODUCTION SERVI CES submits that the requested relief is proper since an equivalent level of safety will be ensured. HANSEN PRODUCTION SERVICES will use experienced personnel or technicians to perform maintenance, alterations, or preventive maintenance on the UAS using the methods, techniques, and practices prescribed in the operating documents (i.e., Monthly Maintenance Log, and DJ I Inspire 1 Instruction Manual). Furthermo re, HANSEN PRODUCTI ON SERVICES will document and maintain all maintenance records for the DJ I Inspire 1 UAS. Relief from certain requirements of Section 61.113(a) and (b), entitled Private pilot privileges and limitations: Pilot in C ommand, is requested b y HANSEN PRODUCTION SERVI CES 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, b y meetingminimum flight

- hour and currency requirements, that the PI C is able to safely operate the DJ I Inspire 1 UAS in a manner consistent with this exemption, including evasive and emergency maneuvers and maintaining appropriate distances from people, vessels, vehicles and structures.
HANSEN PRODU CTION SERVI CES seeks relief from Section 91.7(a), entitled Civil aircraft airworthiness, because the DJ I Inspire 1 UAS do es not require an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H. As such, HANSEN PRODUCTION SERVI CES submits that they

will ensure that the DJ I Inspire 1 UAS is in an airworth y condition, prior to every flight, by determining that the UAS are in compliance with the operating documents (i.e., Monthly Maintenance Log, and DJ I Inspire 1 Instruction Manual), and that the aircraft are in a condition for safe flight.
HANSEN PRODUCTION SERVI CES also seeks an exemption from the requirements of Section 91.121, entitled Altimeter Settings, as the DJI Inspire 1 UAS will not have a t ypical barometric altimeter onboard. However, altitude information of the DJ I Inspire 1 UAS will be provided to the PI C via Global Positioning System (GPS) equipment and radio communications telemetry data link, which downlinks from the UA to the G P S for active monitoring of the flight path. This altitude information, combined with HANSEN PRODUCTI ON SERVI CES’ operation of the DJ I Inspire 1 UAS within visual line of sight, at or below 400 feet AGL, will ensure a level of safety equivalent to Section 91.121. Additionally , HANSEN PRODUCTI ON S ERVICES seeks an exemption from the requirements of Section 91.151(b), entitled Fuel requirements for flight in VFR conditions. HANSEN PRODUCTI ON SERVICES submits that safety will not be affected by

operation of the DJ I Inspire 1 UAS during daylight hours in visual meteorological conditions (VMC) under visual flight rules (VFR), with enough battery power to fly

for a total duration of approximately 20 minutes. Battery

power indicators are also able to show exactly how much battery

power is left, as well as how much time is needed to return safely back to point of take off. In accordance with 14 C.F.R. § 11.81, HANSEN PRODUCTI ON SERVICES 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:
Peter Hansen President Hansen Production Services 11 L ake Valley

Ct Simpsonville, SC 29681 864

- 525

- 5724 hps@hansenproductionservices.com**B. The Specific Sections Of 14 C.F.R. From Which HANSEN PRODUCTION SERVICES** 

**Seeks Exemption.**
**1. HANSEN PRODUCTION SERVICES**  **Seeks Exemption From The Requirements Of Section 61.113(a) And (b).**  Section 61.113, entitled Private pilot privileges and limitations: Pilot in command, subsections (a) and (b) prescribe the following, in relevant part: (a) No person who holds a private pilot certificate may act as a pilot in command (PI C) of an aircraft that is carrying passengers or property for compensation or hire; nor may that person, for compensation or hire, act as PI C of an aircraft. (b) A privat e pilot may , for compensation or hire, act as PIC of an aircraft in connection with any business or employ

ment if

— (1) The flight is only

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

for compensati on or hire.
**2. HANSEN PRODUCTION SERVICES**  **Seeks Exemption From The Requirements Of Section 91.7(a).**  Section 91.7, entitled Civil aircraft airworthiness, subsection (a), states the following: (a) No person may

operate a civil aircraft unless it is in an airworth y condition.
**3. HANSEN PRODUCTION SERVICES**  **Seeks Exemption From The Requirements Of Section 91.121.**  Section 91.121, entitled Altimeter settings, subsection (a), states the following, in part: (a) Each person operating an aircraft shall maintain the cruising altitude or flight level of that aircraft, as the case may be, by reference to an altimeter that is set, when operating

-- (1) Below 18,000 feet MSL , to

-- (i) The current reported altimeter setting of a station along the route and within 100 n autical miles of the aircraft; (ii) If there is no station within the area prescribed in paragraph (a)(1)(i) of this section, the current reported altimeter setting of an appropriate available station; or (iii) In the case of an aircraft not equipped with a radio, the elevation of the departure airport or an appropriate altimeter setting available before departure.
**4. HANSEN PRODUCTION SERVICES**  **Seeks Exemption From The Requirements Of Section 91.151(b).** Section 91.151, entitled Fuel requirements for fli ght in VFR conditions, subsection (b), states the

following: (b) No person may

begin a flight in a rotorcraft under VFR conditions unless (considering wind and forecast weather conditions) there is enough fuel to fly to the first point of intended landing and, assuming normal cruising speed, to fl y after that for at least 20 minutes.
**5. HANSEN PRODUCTION SERVICES**  **Seeks Exemption From The Requirement Of Section 91.405(a).**  Section 91.405, entitled Maintenance required, subsection (a), states the following: Each owner or operator of an aircraft

— (a) Shall have that aircraft inspected as prescribed in subpart E of this part and shall between required inspections, except as provided in paragraph (c) of this section, have discrepancies repaired as prescribed i n part 43 of this chapter[.]
**6. HANSEN PRODUCTION SERVICES**  **Seeks Exemption From The Requirements Of Section 91.407(a)(1)**  Section 91.407, entitled Operation after maintenance, preventive maintenance, rebuilding, or alteration, subsection (a)(1), states th e 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 b y a person authorized under § 43.7 of this chapter[.]
**7. HANSEN PRODUCTION SERVICES**  **Seeks Exemption From The Requirements Of Sections 91.409(a)(1) And 91.409(a)(2).**  Section 91.409, entitled Inspections, subsection (a), states the following: (a) Except as provided in paragraph (c) of this section, no person may operate an aircraft unless, within the preceding 12 calendar months, it has had

-- (1) An annual inspection in accordance with part 43 of this chapter and has been approved for return to service b y a person authorized by § 43.7 of this chapter; or (2) An inspection for the issuance of an airworthiness certificate in accordance with part 21 of this chapter.
**8. HANSEN PRODUCTION SERVICES**  **Seeks Exemption From The Requirements Of Sections 91.417(a) And 91.417(b).**  Section 91.417, entitled Maintenance records , subsections (a) and (b), state the following:(a) Except for work performed in accordance with §§ 91.411 and 91.413, each registered

owner or operator shall keep the following records for the periods specified in paragraph (b) of this section: (1) Reco rds of the maintenance, preventive maintenance, and alteration and records of the 100

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

-- (i) A description (or reference to data acceptable to the Administrator) of the work performed; and (ii) The date of completion of the work performed; and (iii) The signature, and certificate number of the person approving the aircraft for return to service. (2) Records containing the following information: (i) The total time in service of the airframe, each engine, each propeller, and each rotor. (ii) The current status of life

- limited parts of each airframe, engine, propeller, rotor, and appliance. (iii) The time since last overhaul of all items installed on the aircraft which are required to be overhauled on a specified time basis. (iv) The current inspection status of the aircraft, including the time since the last inspection required by the inspection program under which the aircraft and its appliances are maintained. (v) The current status of applicable airworthiness directives (AD) and safet y directives including, for each, the method of compliance, the AD or safet y directive number and revision date. If the AD or safety directive involves recurring action, the time and date when the next action is required. (vi) Copies of the forms pre scribed b y § 43.9(d) of this chapter for each major alteration to the airframe and currentl y installed engines, rotors, propellers, and appliances. (b) The owner or operator shall retain the following records for the periods prescribed: (1) The records s pecified in paragraph (a)(1) of this section shall be retained until the work is repeated or superseded b y other work or for 1 ye ar after the work is performed.(2) The records specified in paragraph (a)(2) of this section shall be retained and transferre d with the aircraft at the time the aircraft is sold. (3) A list of defects furnished to a registered owner or operator under § 43.11 of this chapter shall be retained until the defects are repaired and the aircraft is approved for return to service.
**C. The Extent Of Relief**  **HANSEN PRODUCTION SERVICES Seeks And The Reason**  **HANSEN PRODUCTION SERVICES Seeks The Relief.** 
**1. Extent Of Relief HANSEN PRODUCTION SERVICES**  **Seeks And The Reason HANSEN PRODUCTION SERVICES**  **Seeks Relief From Section 61.113(a) And (b).** Relief from Section 61.113(a) and (b) entitled Private pilot privileges and limitations: Pilot in command, is requested to the extent necessary to allow a PI C holding a private pilot or higher level certificate, as well as a current and valid airman medical certificate, and who has met certain flight

- hour and currency requirements, to conduct the proposed UAS flight operations for compensation or hire. This relief is requested since the limitations set forth in Section 61.113(a) and (b) state that a privat e pilot may , for compensation or hire, act as PI C of an aircraft in connection with any business or employ

ment if: (1) The flight is only incidental to that business or employ ment; and (2) The aircraft does not carry passengers or property

for compensation or hire. As set forth more full y below, HANSEN PRODUCTI ON SERVI CES submits that an equivalent level of safety

will be maintained because no PI C will be allowed to operate the DJ I Inspire 1 UAS unless that PI C has met certain flight

- hour and currency requ irements, demonstrating that the PI C is able to safel y operate either the DJ I Inspire 1 UAS in a manner consistent with the operations specifications as described in this exemption, including evasive and emergency maneuvers, as well as maintaining appropri ate distances from people, vessels, vehicles and structures. Further, HANSEN PRODUCTION SERVICES submits that all flights of the DJ I Inspire 1 UAS, conducted b y the PIC pursuant to the grant of this Petition: (1) will be incidental to HANSEN PRODUCTI ON SE RVICES’ business; and (2) will not carry passengers or propert y for compensation or hire.
**2. Extent Of Relief HANSEN PRODUCTION SERVICES**  **Seeks And The Reason The HANSEN PRODUCTION SERVICES**  **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 HANSEN PRODUCTION SERVI CES to determine that the DJ I Inspire 1 UAS are in airworth y condition prior to every flight by ensuring that the UAS is in compliance with the operati ng documents (i.e., Monthly Maintenance Log, and DJ I In spire 1 Instruction Manual).
HANSEN PRODUCTION SERVI CES seeks the requested relief because the DJ I Inspire 1 UAS do es not require an airworthiness certificate in accordance with 14 C.F.R. Part 21, Sub part H.Therefore, HANSEN PRODUCTION SERVICES will ensure that the DJ I Inspire 1 UAS are in

airworth y condition based upon its compliance with the operating documents (i.e., Monthly Maintenance Lo g, and DJI Inspire 1 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 HANSEN PRODUCTION SERVICES**  **Seeks And The Reason HANSEN PRODUCTION SERVICES**  **Seeks Relief From Section 91.121.** Relief from Section 91.121, entitled Altimeter settings, may be required to allow flight operations of the DJ I Inspire 1 UAS, which utilize a barometric pressure sensor, GPS equipment, and a radio communications telemetry data link to downlink altitude information from the UA to the PI C at the ground control station (GCS). Since the FAA requires that any altitude information concerning UAS operations be reported to air traffic control (ATC) in feet above ground level (AGL ), HANSEN PRODUCTION SERVI CES seeks the requested relief because the DJ I Inspire 1 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 extent necessary

to comply

with the applicable conditions and limitations stated below. As more fully

set forth herein, an equivalent level of safet y will be maintained since the DJ I In spire 1 UAS are equipped with a barometric pressure sensor and GPS equipment, which automaticall y ensures that a ground level pressure setting will be established prior to each flight, and provides the PI C with altitude information of the UA on the heads

- u p display of the GCS.
**4. Extent Of Relief HANSEN PRODUCTION SERVICES**  **Seeks And The Reason HANSEN PRODUCTION SERVICES**  **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 DJ I Inspire 1 UAS during daylight hours in visual meteorological conditions (VMC), under visual flight rules (VFR), for a total duration of 20 minutes. HANSEN PRODUCTION SERVI CES seeks the requ ested relief because without an exemption from Section 91.151(b), the flight time duration of the battery powered DJ I Inspire 1 UAS will severel y constrain the practicality of any aerial video or still photo flight operations that HANSEN PRODUCTION SERVI CE S proposes to conduct pursuant to this Petition. Significantl y, as set forth below, the technical specifications of the DJ I Inspire 1 UAS, the DJ I Inspire 1 operating documents, and HANSEN PRODUCTION SERVICES ’s proposed operating limitations, ensure that HANSEN PRODUCTION SERVI CES will safel y operate the battery powered DJ I Inspire 1 UAS during daylight hours in visual meteorological conditions (VMC), under visual flight rules (VFR), with enough battery power to fl y for a total duration of 20 minutes.
**5. Extent Of Relief**  **HANSEN PRODUCTION SERVICES Seeks And The Reason**  **HANSEN PRODUCTION SERVICES 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) onl y appl y to

aircraft with an airworthiness certificate, HANSEN PRODUCTION SERVICES requests relief from these Sections because the DJ I Inspire 1 UAS do not require airworthiness certificates. As set forth more full y below, the DJ I Inspire 1 UAS meet the conditions of FMRA Section 333 for operation without an airworthiness certificate. Accordingl y, HANSEN PRODUCTION SERVI CES will use trained technicians to perform maintenance, alterations, or preventive maintenance on the UAS using the meth ods, techniques, and practices prescribed in the UAS operating documents (i.e., Monthly Maintenance Log, and DJ I Inspire 1 Instruction Manual). Furthermore, HANSEN PRODUCTI ON SERVICES will document and maintain all maintenance records for the DJ I Inspire 1 UAS. **D. The Reasons Why Granting HANSEN PRODUCTION SERVICES**  **Request Would Be In The Public Interest; That Is, How It Would Benefit The Public As A Whole.**  Granting the present Petition will further the public interest b y allowing HANSEN PRODUCTI ON SERVICES to safely , efficientl y, and economically perform aerial video and photograph y of commercial and manufacturing facilities , real estate, events and civic landscape over certain areas of the United States. Additionally , use of the DJIInspire 1 UAS will decrease congestion of the NAS, reduce pollution, and provide significant benefits to the economy . Notably , the benefits of HANSEN PRODUCTI ON SERVICES ’s proposed operation of the DJ I Inspire 1 UAS will be realized without implicatin g any privacy issues. **1. The Public Will Benefit From Decreased Congestion Of The NAS.** The DJ I Inspire 1 UAS are battery powered and serve as a safe, efficient, and economical alternative to the manned aircraft traditionally utilized to obtain aerial ima gery . By reducing the amount of manned aircraft needed to perform aerial acquisitions, an exemption allowing the use of a DJ I Inspire 1 UAS would reduce the amount of manned aircraft in the NAS, reduce noise and air pollution, as well as increase the safety of life and property in the air and on the ground. Furthermore, b y reducing the number of manned aircraft operating in the NAS, congestion around airports caused by arriving and departing aircraft will be reduced. The DJ I Inspire 1 UAS do not require an airport to takeoff or land. Li kewise, a reduction of manned aircraft conducting aerial video and photography missions would result in fewer aircraft that must be handled by air traffic control during the ground, takeoff, departure, arrival, and landing ph ases of flight operations. **2. The Public Will Benefit From The Safety And Efficiency Of The DJI Inspire 1**  **UAS.** Conducting aerial acquisitions with the DJIInspire 1 UAS, instead of manned aircraft, will greatl y ben efit the public by drasticall y 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 DJIInspire 1 UAS produce no air pollution, and is the most viable environmentally

con scious alternative to the cabin class, six cylinder internal combustion engine aircraft that are ty

picall y utilized for aerial video and photograph y, while burning approximately 20

- 30 gallons per hour of leaded aviation fuel. The DJIInspire 1 UAS, while r educing the carbonfootprint of aerial acquisitions, also eliminates noise pollution, as the UAS are propelled b y

battery powered electric motors, rather than an internal combustion engine. By using the DJ I Inspire 1 UAS to perform aerial acquisitions, th e substantial risk to life and propert y 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 DJ I Inspire 1 UAS (weighing approximately 6.5 pounds at their maximum gross weight with diagonal dimension of 20 inches, and with no fuel on board), has less ph ys ical potential for collateral damage to life and property on the gr ound, and in the air, compared to the manned aircraft that typicall y conduct similar operations (weighing approximately 6,000 pounds with a wingspan of approximately 42 feet, a length of 34 feet, and a fuel capacity of 180 gallons). **3. Performing Aerial V ideo and Photography Operations With The**  **DJI Inspire 1 UAS Will**  **Benefit The Economy.** In addition to being safe and efficient, the DJ I Inspire 1 UAS are also an economical alternative to using manned aircraft to conduct similar aerial operations. As such, operation of the DJ I Inspire 1 UAS will allow United States based companies, like HANSEN PRODUCTION SERVI CES , to remain competitive and contribute to growth of the U.S. economy . Specifically , with the rising cost of aviation fuel and the Environmental Prot ection 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 DJ I Inspire 1 UAS is one such technology that not onl y allows companies greater operational flexibility

compared to manned aircraft, but provides such flexibility without the high operational cost of a traditional manned aircraft. By operating the DJ I Inspire 1 UAS, companies such as HANSEN PRODU CTION SERVI CES , 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 comm ercial use of the DJI Inspire 1 UAS, provides a stable workforce that increases consumer spending; improves local, state, and federal tax revenues; and allows companies to invest in research and development in order to remain competitive both in the United States and abroad. **4. There Are No Privacy Issues.** Similar to the manned aerial acquisition flight operations that have been conducted for decades, HANSEN PRODUCTION SERVI CES ’s proposed operation of the DJ I In spire 1 UAS will not implicate any

privacy i ssues. Specificall y, the DJ I Inspire 1 UAS will be operated onl y in compliance with operating documents (i.e., Monthly Maintenance Log, and DJIInspire 1 Instruction Manual) which requires propert y 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 Wou ld 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**  **HANSEN PRODUCTION SERVICES Seeks Exemption.**  **1. Reasons Why The DJI Inspire 1**  **UAS Meet The Conditions Of The FAA Mod ernization**  **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, HANSEN PRODUCTION SERVICES ’s operation of the DJIInspire 1 UAS meet the conditions of FMRA Section 333, and will not require an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H. Section 333 provides authority for a UAS to operate without airworthiness certification and sets forth requirements for con sidering 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 an y other requirement of this su btitle, and not later than 180 day s after the date of enactment of this Act, the Secretary of Transportation shall determine if certain unmanned aircraft sy stems may operate safely

in the national airspace sy stem before completion of the plan and rulemakin g required b y section 332 of this Act or the guidance required b y section 334 of this Act. (b) Assessment of Unmanned Aircraft S ys tems.

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

-- (1) which ty

pes of unmanned aircraft s ys tems, 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 s ys tem or the public or pose a threat to national security ; and (2) whether a certificate of waiver, certificate of authorization, or airworthiness certification under section 44704 of title 49, United States Code, is required for the operation of unmanned a ircraft s ys tems identified under paragraph (1). (c) Requirements for Safe Operation.

-- If the Secretary determines under this section that certain unmanned aircraft sy stems may operate safely

in the national airspace s ys tem, the Secretary shall establish r equirements for the safe operation of such aircraft sy stems in the national airspace s ys tem. In seeking this exemption, HANSEN PRODUCTION SERVI CES submits that the DJ I Inspire 1 UAS can operate safel y in the NAS pursuant to FMRA Section 333, as demonstrat ed b y: (a) the characteristics of the DJ I Inspire 1 UAS; (b) the pilot certification requirement; and (c) the specific operating limitations. a. The Specifications Of The DJ I Inspire 1 UAS Demonstrate Its Safe Characteristics. The DJ I Inspire 1 UAS does n ot create a hazard to users of the NAS or the public, or otherwise pose a threat to national security considering its size, weight, speed, andoperational capability

. i. Technical Specifications Of The DJ I Inspire 1 UAS. The technical specifications of th e DJ I Inspire 1 UAS are set forth by the DJ I Inspire 1 User Manual. ii. The DJ I Inspire 1 UAS Global Positioning Modes Enable The UAS To Remain Within A Defined Operational Area. The DJ I Inspire 1 UAS may be operated in both manual and global positioning flight modes. A complete description of the flight and navigational modes of the DJ I Inspire 1 UAS is provided in the DJ I Inspire 1 User Manual attached hereto as Appendix A. iii. The DJIInspire 1 UAS Are Designed For Automatic Return To Home Point Or H over In The Event Of Loss Of The Control Link Or Navigation. When the Control L ink is lost, the DJIInspire 1 UAS will remain stationary , in flight, for 3 seconds or more. If, after 3 seconds, the DJ I Inspire 1 UAS does not reacquire control link data fro m the GCS, the UAS will assume that the Control L ink is lost and the 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 DJ I Inspire 1 UAS are set forth at pages 12 through 14 of the DJ I Inspire 1 User Manual, attached hereto as Appendix A. iv. The DJ I Inspire 1 GCS And Its Operation. A complete description of the operation and specifications of the DJ I Inspire 1 GCS and flight control software is provided at pages 23 through 29 of the DJ I Inspire 1 User Manual. DJ I Inspire 1 User Manual is attached hereto as Appendix A. b. Flight Operations Of DJIInspire 1 UAS I s L imited To The L ine Of Sight Of A Certificated Pilot in Command With A Safety Observer.
HANSEN PRODUCTION SERVI CES’ video production staff will be the only persons to act as a pilot in command (PI C) of the DJIInspire 1 UAS. Additionally , a safet y observer will assist him at all times during flight time. c. Flights Of DJ I Inspire 1 UAS Will Be Conducted Pursuant To Specific Operating Limitations. In seeking this exemption, HANSEN PRODUCTION SERVI CES proposes to commerciall y operate DJI Inspire 1 UAS for the special purpose of conducting aerial video and photography over c ertain areas of United States, pursuant to thefollowing specific operating limitations. 1. Operations authorized by this grant of exemption will be limited to the following aircraft described in the operating documents, rotorcraft UAS weighing less than 55 pounds maximum gross weight: DJ I Inspire 1 Unmanned Aircraft Sy stems. Proposed operations of any other aircraft will require a new petition or a petition to amend this grant. 2. UAS operations under this exemption will be limited to conducting operatio ns 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 400 feet above ground level (AGL), as indicated b y the procedures speci fied in the operating documents unless a special request is made and approved b y ATC. All altitudes reported to ATC must be in feet AGL

. 5. The UAS must be operated within visual line of sight (VLOS) of the PI C at all times. This requires the PI C to be able to use human vision unaided b y an y device other than corrective lenses, as specified on the PI C’s FAA

- issued airman medical certificate

. 6. The use of first person view (FPV) b y the PI C or safet y 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 alway s maintains VLOS capability . Th e SO and PI C must be able to communicate verbally at all times. Electronic messaging or texting is not permitted during flight operations. The PIC must be designated before the flight and cannot transfer his or her designation for the duration of the flight. The PI C must ensure that the SO can perform the functions prescribed in the operating documents. 8. The SO must not perform any other duties beyond assisting the PI C with seeing and avoiding other air traffic and other ground based obstacles/obstructio ns and is not permitted to operate the camera or other instruments. 9. The operating documents and the grant of exemption must be accessible during UAS operations and made available to the Administrator upon request. If a discrepancy

exists between the co nditions and limitations contained in the grant of exemption and the procedures outlined in the operating documents, the conditions and limitations contained in the grant of exemption take precedence and must be followed. Otherwise, the operator must follo w the procedures as outlined in its operating documents. The operator may update or revise its operating documents. Itis 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 an y update or revision would affect the basis upon which the FAA granted the exemption, then the operator must petition for amendment to its grant of exemption. The FAA’s UAS Integration Office (AFS

- 80) may

be contacted if questions arise regarding updates or revisions to the operating documents. 10. Prior to each flight the PI C must inspect the UAS to ensure that it is in a condition for safe flight. If the inspection reveals a condition that affects the safe operation of the UAS, the aircraft is prohibited from operating until the necessary

maintenance has been performed and 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 properl y documented in the aircraft records. 11. Any UAS that has undergone maintenance or alterations that af fect the UAS operation or flight characteristics, e.g. replacement of a flight critical component, must undergo a functional test flight. The PI C who conducts the functional test flight must make an entry in the aircraft records. 12. The pre

- flight inspec tion must account for all potential discrepancies, e.g. inoperable components, items, or equipment, not already covered in the relevant sections of the operating documents. 13. The operator must follow the UAS manufacturer’s aircraft/component, maintenanc e, overhaul, replacement, inspection, and life limit requirements. 14. The operator must carry out its maintenance, inspections, and record keeping requirements, in accordance with the operating documents. Maintenance, inspection, alterations, and status of replacement/overhaul component parts must be noted in the aircraft records, including total time in service, description of work accomplished, and the signature of the authorized person returning the UAS to service. 15. Each UAS operated under this exe mption must comply with all manufacturer Safet y Bulletins. 16. The authorized person must make an entry in the aircraft record of the corrective action taken against discrepancies discovered between inspections.
1 7 . The operator may

not permit any

PIC to operate unless the PI C meets the operator’s qualification criteria and demonstrates the ability to safely operate the UAS in a manner consistent with how the UAS will beoperated under the exemption, including evasive and emergency maneuvers and maintaini ng 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

building flights, all persons not essential for flight operations are considered nonparticipants, and the PI C must operate the UA with appropriate distance from nonparticipants in accordance with 14 C.F.R. § 91.119.
1 8 . UAS operations may

not be conducted during night, as defined in 14 C.F.R. § 1.1. All operations must be conducted under visual meteorological conditions (VMC). If flight at night is required, a special request will be made at the FAA office closest to proposed area of operations. Flights under special visual flight rules (SVFR) are not authorized.
19 . The UA may

not operate within 5 nautical m iles 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 b y the operator’s COA . The letter of agreement with the airport management must be made available to the Administrator upon request.
2 0 . The UA may

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

from a cloud or when visibility is less than 3 statute miles from the PI C.
2 1 . If the UA loses communications or loses its GPS signal, it must return to a pre

- determined location within the planned operating area and land or be recovered in accordance with the operating documents.
2 2 . The PI C must abort the flight in the event of unpredicted obstacles or emergencies in accordance with the operating documents.
2 3 . The PI C is prohibited from beginning a flight unless (considering wind and forecast weather conditions) there is enough power to fl y at norma l cruising speed to the intended landing point and land the UA with 25% battery power remaining.
2 4 . The operator must obtain an Air Traffic Organization (ATO) issued Certificate of Waiver or Authorization (COA) prior to conducting any operations under th e 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 operationsshall be conducted in accordance with airspace requirem ents in the ATO issued COA including class of airspace, altitude level and potential transponder requirements.
2 5 . All aircraft operated in accordance with the exemption must be identified by

serial number, registered in accordance with 14 C.F.R. part 47, and have identification (N

- Number) markings in accordance with 14 C.F.R. part 45, Subpart C. Markings must be as large as practicable.
2 6 . Before conducting operations, the radio frequency spectrum used for operation and control of the UA must comply wi th the Federal Communications Commission (FCC) or other appropriate government oversight agency

requirements.
27 . The documents required fewer than 14 C.F.R. 91.9 and 91.203 must be available to the PIC at the Ground Control Station of the UAS an y time th e UAS is operating. These documents must be made available to the Administrator or an y law enforcement official upon request.
2 8 . The UA must remain clear and yi eld the right of way to all manned aviation operations and activities at all times.
29 . The UAS may

not be operated b y the PIC from any moving device or vehicle.
3 0 . Flight operations must be conducted at least 500 feet from all nonparticipating persons (persons other than the PIC, SO, operator trainees or essential persons), vessels, vehicles, and structures unless: a. Barriers or structures are present that 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 PI C has made a safety assessment of the risk of operating closer to those objects and determined that it does not present an undue hazard, and; c. Operations nearer to the PI C, SO, operator trainees or essential per sons do not present an undue hazard to those persons per § 91.119(a).
3 1 . All operations shall be conducted over private or controlled

access propert y with permission from the land owner/controller orauthorized representative. Permission from land owner/ controller or authorized representative will be obtained for each flight to be conducted.
3 2 . Any incident, accident, or flight operation that transgresses the lateral or vertical boundaries of the operational area as defined b y the applicable COA must be reported to the FAA's UAS Integration Office (AFS

- 80) within 24 hours. Accidents must be reported to the National Transportation Safety Board (NTSB) per instructions contained on the NTSB Web site: www.ntsb.gov. **2. Reasons Why An Exemption From The Requi rements Of Section 61.113(a) And (b)**  **Would Not Adversely Affect Safety.**
HANSEN PRODUCTION SERVI CES submits that the equivalent level of safet y established b y Section 61.113(a) and (b) will be maintained because no PI C will be allowed to operate the DJ I In spire 1 UAS unless that PI C has demonstrated, by meeting minimum flight

- hour and currency requirements, that the PIC is able to safel y operate the DJ I Inspire 1 UAS in a manner consistent with the exemption, including evasive and emergency maneuvers and ma intaining appropriate distances from people, vessels, vehicles and structures. Considering HANSEN PRODUCTION SERVICES ’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 safel y operate the DJIInspire 1 UAS, HANSEN PRODUCTION SERVI CES submits that the additional manned airmanship experience of a commerc iall y certificated pilot would not correlate to the airmanship skills necessary for HANSEN PRODUCTI ON SERVICES ’s specific proposed flight operations. The FAA has previously

granted relief from Section 61.113(a) and (b) specific to UAS, in circumstances si milar, 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, 11158, 11159, 11160, 11161).
HANSEN PRODUCTION SERVI CES will not allow any PIC to operate the DJ I Inspire 1 UAS unless that PI C has demonstrated, by meeting minimum flight

- hour requirements or the DJ I Inspire 1 UAS training and currency requirements, that the PI C is able to safely operate the DJ I Inspire 1 UAS in a manner co nsistent with this exemption, including evasive and emergency maneuvers and maintaining appropriate distances from people, vessels, vehicles and structures. Specificall y, the PI C must have accumulated and logged, in a manner consistent with 14 C.F.R. § 61 .51(b), 25 hours of total time as a UAS rotorcraft pilot (with a minimum of 5 hours of those hours as a UAS pilot operating the same make and model of UAS to be used for operations under the exemption). In addition to the hour requirements, the PI C must ac complish 3 takeoffs and landings in the preceding 90 day s (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 safet yduring HANSEN PRODUCTION SERVI CES’ 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 Exemptio n No. 11062, the FAA required that prior to conducting operations for the purpose of motion picture filming (or similar operations), the PI C must have accumulated and logged, in a manner consistent with 14 CFR 61.51(b), 25 hours of total time as a UAS roto rcraft pilot including at least 10 hours logged as a UAS pilot with a multi

- rotor UAS. Prior to operations under Exemption No. 11062, the PI C must also have accumulated and logged a minimum of 5 hours as a UAS pilot operating the same make and model of UAS to be used for operations under the exemption. For clarification, the FAA considers these minimum hour requirements to be inclusive rather than additive; i.e. 5 hours make and model time may be included in the 10 hours of multi

- rotor time and the 10 hours may be included in the total 25 hours of UAS rotorcraft time. In addition to the hour requirements, the PIC must accomplish 3 takeoffs and landings in the preceding 90 day s (for currency purposes). The FAA finds that at a minimum, the flight

- hour requirem ents in Exemption No. 11062 are appropriate to practice and build proficiency in the skills necessary

to safely conduct the petitioner’s proposed operations. The FAA also finds that prior documented flight experience that was obtained in compliance with ap plicable regulations would satisfy

this requirement. Training, proficiency , and experience

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

- building fli ghts the PIC is required to operate the UA with appropriate distances in accordance with 14 C.F.R 91.119. Exemption No. 11138 at page 15. Accordingl y, HANSEN PRODUCTI ON SERVICES will ensure safe operations by not allowing any PIC to operate the DJIInspi re 1 UAS unless that PI C has demonstrated, by meeting minimum flight

- hour and currency requirements, that the PI C is able to safely operate the DJ I Inspire 1 UAS in a manner consistent with the exemption, including evasive and emergency maneuvers and maint aining 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 b y Section 91.7(a) will be maintained because prior to every flight, HANSEN PRODUCTION SERVICES will ensure that the DJIInspire 1 UAS is in an airworth y 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, 1111 2, 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 b y Section 91.121 will be maintain ed because thealtitude information of the DJ I Inspire 1 UAS will be provided to the PI C via GPS equipment

and a radio communications telemetry data link, which downlinks from the UA to the GCS for active monitoring of the flight path and altitude. This al titude information, combined with HANSEN PRODUCTION SERVI CES ’s operation of the DJ I Inspire 1 UAS within visual line of sight, at or below 500 feet AGL, will ensure a level of safety equivalent to Section 91.121. The altitude information will be generated by GPS equipment installed onboard the aircraft. Prior to each flight, a zero altitude initiation point is automatically established by the UAS at ground level. The FAA has previously

granted relief from Section 91.121 specific to UAS, in circumstances si milar, 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 Requ irements Of Section 91.151(b) Would Not**  **Adversely Affect Safety.** A grant of this exemption would ensure an equivalent level of safety established by

14 C.F.R. Section 91.151(b) as a result of (1) the technical specifications of the DJ I Inspire 1 UAS; (2) the limitations on the proposed flight operations; and (3) the location of the proposed flight operations. Accordingly , HANSEN PRODUCTION SERVI CES will ensure that it will safely operate the battery

powered DJ I Inspire 1 UAS during daylight hours in VFR co nditions, with enough battery

power to fly

for a total duration of 20 minutes

. Here, as in Exemption No. 11109, the technical specifications of the DJ I In spire 1 UAS; the limitations on the proposed flight operations; and the location of the proposed operations, will ensure an equivalent level of safety established b y 14 C.F.R. Section 91.151(b). Furthermore, safet y will be ensured as the DJ I Inspire 1 UAS provide audible and visual warnings to the PI C at the GCS when the UAS experiences low battery voltag e, the first warning occurring at approximately

33% remaining battery

power, and again at approximately 10% remaining battery power. At the criticall y low battery level, the DJ I Inspire 1 UAS will descend and land automatically

. Significantl y, previous ex emptions granted b y the FAA concerning Section 91.151 establish that safet y 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 tha n 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 those 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 Of Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), And 91.417(a) & (b) Would Not Adversely Affect Safety.**  In seeking this exemption, HANSEN PRODUCTION SERVI CES submits that the equivalent level of safety

with regard to the regulatory maintenance and alteration requirements establishedby

Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b) will be met because HANSEN PRODUCTION SERVICES wi ll use trained technicians to perform maintenance, alterations, or preventive maintenance on the UAS using the methods, techniques, and practices prescribed in the operating documents (i.e., Monthly Maintenance Log, and DJ I Inspire 1 Instruction Manual). F urthermore, HANSEN PRODUCTI ON SERVI CES will document and maintain all maintenance records for the DJ I Inspire 1 UAS. Since the DJ I Inspire 1 UAS will be inspected as prescribed b y the operating documents, HANSEN PRODUCTION SERVI CES will maintain the equiv alent level of safet y established by Sections 91.405(a), 91.409(a)(1), and 91.409(a)(2). A copy of the DJ I Inspire 1 User Manuals are attached hereto as Appendix A and B; a cop y of the DJ I Inspire 1 UAS Maintenance LOG is attached hereto as Appendix C.
Li kewise, the exemption sought will not adversel y affect safety because HANSEN PRODUCTI ON SERVICES will use trained technicians to perform maintenance, alterations or preventive maintenance on the UAS using the methods, techniques, and practices prescribed b y the operating documents. Furthermore, the exemption sought would maintain an equivalent level of safety established b y Sections 91.407, 91.417(a) and 91.417(b), because all maintenance of the DJIInspire 1 UAS will be performed b y trained technicians. M aintenance will be documented and maintained utilizing the monthly

maintenance log. Significantl y, previous exemptions granted b y the FAA concerning Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b) establish that safety is not adversel y affected when the technical characteristics and operating limitations of the UAS are considered. In consideration of HANSEN PRODUCTI ON SERVI CES ’s proposed operating limitations, the operating documents, and the technical aspects of the DJ I Inspir e 1 UAS, HANSEN PRODUCTI ON SERVICES submits that safety will not be adversel y affected b y 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 previousl y 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, HANSEN PRODUCTION SERVI CES requests that the FAA prescribe spec ial conditions for the intended operation of the DJ I Inspire 1 UAS, which contain such safety standards that the Administrator finds necessary to establish a level of safety

equivalent to that established by 14 C.F.R. Part 21, Subpart H, and 14 C.F.R §§ 61 .113(a) & (b), 91.7 (a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b). Such special conditions will permit safe operation of the UAS for the limited purpose of conducting aerial video and photography over certain areas of the United States for compensation or hire. FMRA Section 333 sets forth the requirements for considering whether a UAS will create a hazard to users of the NAS or the public, or otherwise pose a threat to nationalsecurit y; and further, provides th e authority for such UAS to operate without airworthiness certification in accordance with an y requirements that must be established for the safe operation of the UAS in the NAS. Likewise, the Administrator may prescribe special conditions pursuant to 14 C.F.R. § 21.16, for operation of the DJ I Inspire 1 UAS, since the airworthiness regulations of 14 C.F.R. Part 21 do not contain adequate or appropriate safety standards, due to the novel or unusual design features of the aircraft. Section 21.16, entitled S pecial 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 aircraft, aircraft engine, or propeller because of a novel or unusual design feature of the aircraft, aircraft engine or propeller, he prescribes special conditions and 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, ai rcraft 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 accordance with FMRA Section 333 and 14 C.F.R. § 21.16, the FAA may prescribe spe cial conditions for Leading Edge’s intended operation of the DJIInspire 1 UAS, which contain such safety standards that the Administrator finds necessary to establish a level of safet y 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). **• A Summary That Can Be Published In The Federal Register, stating: The Rules From Which**  **HANSEN PRODUCTION SERVICES Seeks Exemption:** 
HANSEN PRODUCTION SERVICES 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 T he Exemption**  **HANSEN PRODUCTION SERVICES**  **Seeks:** This exemption will permit HANSEN PRODUCTION SERVICES to commercially operate an Unmanned Aircraft System (UAS) for the purpose of conducting aerial video and photography over certain areas of the United States. **• Any Additional Information, Views, Or Arguments Available To Support HANSEN**  **PRODUCTION SERVICES ’**  **Request.** This Petition is made pursuant to the FAA Modernization and Reform Act of 2012 (FMRA) Section 333, which directs the Secretary of Transport ation to determine if certain UAS may operate safel y in the NAS. As such, HANSEN PRODUCTION SERVICES ’s request for exemption may

be granted pursuant to the authority of FMRA Section 333 and 14 C.F.R. Part11, as set forth above.

FMRA Section 333 sets forth the requirements for considering whether a UAS will create a hazard to users of the NAS or the public, or otherwise pose a threat to national security; and further, provides the authority for such UAS to operate without airworthiness certification. As d iscussed in detail above, HANSEN PRODUCTI ON SERVI CES will operate the DJ I Inspire 1 UAS safel y in the NAS, without creating a hazard to users of the NAS, or the public, or otherwise pose a threat to national security. **CONCLUSION** As set forth herein, HANS EN PRODUCTI ON SERVI CES 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 DJ I Inspire 1 UAS commerciall y, without an airworthiness certificate, fo r 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 Reform Act of 2012, while a lso advancing the interests of the public, by allowing HANSEN PRODUCTI ON SERVI CES to safel y, efficientl y, and economically operate the DJIInspire 1 UAS commercially within the NAS.
**WHEREFORE** , in accordance with the Federal Aviation Regulations and the FAA Modernization and Reform Act of 2012, Section 333, HANSEN PRODUCTION SERVI CES respectfull y requests that the Administrator grant this Petition for an exemption from the requirements of 14 C.F.R Sections 61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 91.4 05(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b), and permit Leading Edge to operate the DJIInspire 1 UAS commerciall y for the purpose of conducting aerial video and photograph y over certain areas of the United States. Dated: July

7 , 2015 Respectfully

submitted,
Peter Hansen President Hansen Production Services 11 L ake Valley

Ct Simpsonville, SC 29681 864

- 525

- 5724 hps@hansenproductionservices.com
Appendices: A

– Link to DJIInspire 1 Manual: Click on link below http://download.dji

innovations.com/downloads/inspire_1/en/Inspire_1_User_Manual_v1.2_en.pdf