UNITED STATES OF AMERICA DEPARTMENT OF TRANSPORTATION FEDERAL AVIATION ADMINISTRATION WASHINGTON, DC

Regulatory Docket No. _______________

IN THE MATTER OF THE PETITION FOR EXEMPTION OF: Narrate Studios LLC FOR AN EXEMPTION SEEKING RELIEF FROM THE REQU IREMENTS 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+ UNMANNED AIRCRAFT SY STEMS PURSUANT TO SECTION 333 OF THE FAA MODERNIZATION AND REFORM ACT OF 2012 (PUBLIC LAW 112

- 95)

Submitted on March 31 , 2015
Andrew W. Fischer Narrate Studi os LLC 211 North 1st S treet #240 Minneapolis, MN 55401 Tel: (320)491

- 7280 Email: awfisch@gmail.com2 TABLE OF C ONTENTS Page
GLOSSARY OF ABBREVIATIONS...................................................................................3
SUMMARY......................................................................................................................

..... 4
INTRODUCTION AND INTERESTS OF PETITIONER....................................................4
BACKGROUND................................................................................................................... .4
BASIS FOR PETITION........ .................................................................................................5
NAME AND ADDRESS OF PETITIONER.............................................................7
THE SPECIFIC SECTIONS OF 14 C.F.R. FROM WHICH NARRATE STUDIOS LLC SEEKS EXEMPTION.................................................................8
THE EXTENT OF RELIEF NARRATE STUDIOS LLC SEEKS AND THE REASON NARRATE STUDIOS LLC SEEKS THE RELIEF.........................11
THE REASONS WHY GRANTING NARRATE STUDIOS LLC ’ S REQUEST WOUL D BE IN THE PUBLIC INTEREST .........................................................15
THE REASONS WHY GRANTING THE EXEMPTION WOULD NOT ADVERSELY AFFECT SAFETY..........................................................................19
SUMMARY THAT CAN BE P UBLISHED IN THE FEDERAL REGISTER......34 ANY ADDITIONAL INFORMATION, VIEWS, OR ARGUMENTS AVAILABLE TO SUPPORT NARRATE STUDIOS LLC ’ S REQUEST.........34
CONCLUSION.................................................................................................. ..................35
APPENDICES........................................................................................373 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 Regulat ions COA Certificate of Authorization FAA Federal Aviation Administration FAR Federal Aviation Regulation GCS Ground Control Station GPS Global Positioning System LOL Loss of Link NAS National Airspace System NOTAM Notice to Airma n PIC Pilot In Command Section 333 FAA Modernization and Reform Act of 2012 (FMRA) Section 333 SO Safety Observer SOP Standard Operating Procedures UA Unmanned Aircraft UAS Unmanned Aircraft System VFR Visual Flight Rules VLOS Visual Line of Site VMC Visual Meteorological Conditions VTOL Vertical Takeoff and Landing4 SUMMARY
Andrew W. Fischer 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
Narrate Studios LLC to operate an Unmanned Aircraft System (UAS) for the commer cial purpose of conducting aerial video and photography of construction sites, real estate, special events, film sets, and landscape over certain areas of the United States.
INTRODUCTION AND INTERESTS OF THE PETITIONER
Narrate Studios LLC provides its cli ents with the highest quality digital content for use in their commercial, personal, and non

- profit multimedia projects. Narrate LLC has established itself as a technological innovator in experiential multimedia and is recognized
as a leader in providing a quality product. Narrate LLC has over 2 years recreational/hobby experience in all aspects of aerial video and photography. The objective of Narrate Studios
LLC aerial video and photography operation s is to provide high quality imaging for a variety of co mme rcial, public, and residential uses, specifically targeting:

• Aerial event photography

• Aerial event filming

• Film production

• Aerial location scouting and safety inspection

• Increase public knowledge of UAS and promote safe UAS operations.
BACKGROUND5 Unmann ed Aircraft Systems: DJI Phantom 2 Vision UAS
Narrate Studios LLC seeks an exemption to operate DJI systems for compensation
or hire within the NAS. The DJI Phantom 2 Vision+ is a vertical takeoff and landing (VTOL) Unmanned Aircraft (UA) with a Ground Con trol 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 speed of approximately 29 knots.
The DJI Phantom 2 Vision+ UA is equipped with four main rotors; driven by Lithium Polymer battery powered electric motors.
The DJI Phantom 2 Vision+ UA that will be operated by Narrate Studios LLC will be registered in accordanc e 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, Narrate Studios LLC , pursuant to th e 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 Systems , hereby petitions the Administrator to commercially operate the D JI Phantom 2 Vision UAS 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, Narrate Studios LLC operation of DJI6 Phantom 2 Vision+ UAS meets the conditions of FMRA Section 333 and therefore, will not require an airworthines s certificate in accordance with 14 C.F.R. Part 21, Subpart H. Accordingly, Narrate Studios 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 tha t only apply to aircraft with an airworthiness certificate.
Narrate Studios LLC submits that the requested relief is proper since an equivalent level of safety will be ensured. Narrate Studios LLC will use experienced personnel or technicians to perform m aintenance, 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+ Instruction Manual). Furthermore,
Narrate Studios LL C will document and maintain all maintenance records for the DJI
Phantom 2 Vision+ UAS

. Relief from certain requirements of Section 61.113(a) and (b), entitled Private pilot privileges and limitations: Pilot in command , is requested by Narrate Studios 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 a ble to safely operate the
DJI Phantom 2 Vision+ UAS in a manner consistent with this exemption, including evasive and emergency maneuvers and maintaining appropriate distances from people, vessels, vehicles and structures.
Narrate Studios LLC seeks relief from Section 91.7(a), entitled Civil aircraft
airworthiness , because the DJI Phantom 2 Vision+ UAS do not require an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H. As such, Narrate Studios LLC7 submits that it will ensure that t he DJI Phantom 2 Vision+ UAS are in an airworthy condition, prior to every flight, by determining that the UASs are in compliance with the operating documents (i.e., Monthly Maintenance Log, and DJI Phantom 2 Vision+ Instruction Manual), and that the aircr aft are in a condition for safe flight.
Narrate Studios LLC also seeks an exemption from the requirements of Section 91.121, entitled Altimeter Settings , as the DJI Pha ntom 2 Vision+ UA will not have a typical barometric altimeter onboard. However, altitu de information of the DJI Phantom 2
Vision+ UA 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 alt itude information, combined with Narrate
Studios LLC’s operation of the DJI Phantom 2 Vision+ UAS within visual line of sight, at or below 500 feet AGL, will ensure a level of safety equivalent to Section 91.121. Additionally, Narrate Studios LLC seeks an exemption from the requirements of Section 91.151(b), entitled Fuel requirements for flight in VFR conditions

. Narrate Studios
LLC submits that safety will not be affected by operation of the DJI Phantom 2 Vision+
UA during daylight hours in visual meteor ological conditions (VMC) under visual flight rules (VFR), with enough battery power to fly for a total duration of approximately 13.5 minutes to the first point of intended landing and, assuming normal cruising speed, to fly
after that for at least 4.5 mi nutes. In accordance with 14 C.F.R. § 11.81, Narrate Studios 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:8 Andrew Fischer Narrate Studi os LLC 211 North 1st S treet #240 Minneapolis, MN 55401 Tel: (320)491

- 7280 Email: awfisch@gmail.com B. The Spec ific Sections Of 14 C.F.R. From Which Narrate Studios LLC Seeks Exemption.
1. Narrate Studios LLC Seeks Exemption From The Requirements Of Sectio n 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 passengers or property for compensation or hire; nor may that person, for compensation or hire, act as PIC of an aircraft. (b) A private pilot may, for compensation or hire, act as PIC of an aircraft in connection wi th any business or employment if

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

2. Narrate Studios LLC Seeks Exemption From The Requirements Of Sect ion 91.7(a). Section 91.7, entitled Civil aircraft airworthiness , subsection (a), states the following: (a) No person may operate a civil aircraft unless it is in an airworthy condition.
3. Narrate Studios LLC Exemption From The Requirements Of Section 91.121. Section 91.121, entitled Altimeter settings , subsection (a), states the following, in part:9 (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 altim eter that is set, when operating

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

-- (i) The current reported altimeter setting of a station along the route and within 100 nautical miles of the aircraft; (ii) If there is no station within the area prescribed in paragraph (a)(1)(i) of this section, the current reported altimeter setting of an appropriate available station; or (iii) In the case of an aircraft not equipped with a radio, the elevation of the departure airport or an appropriate altimeter setting available bef ore departure.
4. Narrate Studios LLC Exemption From The Requirements Of Section 91.151(b). Section 91.151, entitled Fuel requirements for flight in VFR conditions , subsection (b), states the following: (b) No person may begin a flight in a rotorcraf t under VFR conditions unless (considering wind and forecast weather conditions) there is enough fuel to fly to the first point of intended landing and, assuming normal cruising speed, to fly after that for at least 20 minutes.
5. Narrate Studios LLC Exem ption 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 an d 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. Narrate Studios LLC From The Requirements Of Section 91.407(a)(1) Section 91.407, entitl ed Operation after maintenance, preventive maintenance, rebuilding, or alteration , subsection (a)(1), states the following:10 (a) No person may operate any aircraft that has undergone maintenance, preventive maintenance, rebuilding, or alteration unless

-- (1) It has been approved for return to service by a person authorized under § 43.7 of this chapter[.]
7. Narrate Studios 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. Narrate Studios LLC Exemption From The Requirem ents Of Sections 91.417(a) And 91.417(b). Section 91.417, entitled Maintenance records , subsections (a) and (b), state the following: (a) Except for work performed in accordance with §§ 91.411 and 91.413, each registered owner or operator shall keep the following records for the periods specified in paragraph (b) of this section: (1) Records of the maintenance, preventive maintenance, and alteration and records of the 100

- hour, annual, progressive, and other required or approved inspections, as appropria te, 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 o f completion of the work performed; and (iii) The signature, and certificate number of the person approving the aircraft for return to service.11 (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 s pecified 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 airw orthiness directives (AD) and safety directives including, for each, the method of compliance, the AD or safety directive number and revision date. If the AD or safety directive involves recurring action, the time and date when the next action is required. (vi) Copies of the forms prescribed by § 43.9(d) of this chapter for each major alteration to the airframe and currently installed engines, rotors, propellers, and appliances. (b) The owner or operator shall retain the following records for the periods prescribed: (1) The records specified in paragraph (a)(1) of this section shall be retained until the work is repeated or superseded by other work or for 1 year after the work is performed. (2) The records specified in paragraph (a)(2) of this section sh all be retained and transferred with the aircraft at the time the aircraft is sold. (3) A list of defects furnished to a registered owner or operator under § 43.11 of this chapter shall be retained until the defects are repaired and the aircraft is approv ed for return to service.
C. The Extent Of Relief Narrate Studios LLC Seeks And The Reason Narrate Studios LLC Seeks The Relief.
1. Extent Of Relief Narrate Studios LLC Seeks And The Reason Narrate Studios LLC Seeks Relief From Section 61.113(a) And (b).12 Reli ef 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

ce rtificate, and who has met certain flight

- hour and currency requirements, to conduct the proposed UAS flight operations for compensation or hire. This relief is requested since the limitations set forth in Section 61.113(a) and (b) state that a private pi lot may, for compensation or hire, act as PIC of an aircraft in connection with any business or employment if: (1) The flight is only incidental to that business or employment; and (2) The aircraft does not carry passengers or property for compensation or hire. As set forth more fully below , Narrate Studios LLC submits that an equivalent level of safety will be maintained because no PIC will be allowed to operate t he DJI
Phantom 2 Vision+ UAS UA unless that PIC has met certain flight

- hour and currency

requ irements, demonstrating that the PIC is able to safely operate eith er the DJI Phantom 2
Vision+ UAS in a manner consistent with the operations specifications as described in this exemption, including evasive and emergency maneuvers, as well as maintaining appropriate distances from people, vessels, vehicles and structures. Further, Narrate Studios LLC submits that all flights of the DJI Phantom 2 Vision+
UAS , conducted by the PIC pursuant to the grant of this Petition: (1) will be incidental to
Narrate Studios LLC business; and (2) will not carry passengers or property for compensation or hire.
2. Extent Of Relief Narrate Studios LLC Seeks And The Narrate Studios LLC Seeks Relief From Section 91.7(a).13 Relief from Section 91.7(a) entitled Civil aircraft airwo rthiness , is requested to the extent required to allow Narrate Studios LLC to determine that the DJI Phantom 2 Vision+
UAS are in airworthy condition prior to every flight by ensuring that the UAS is in compliance with the operating documents (i.e., the Na rrate Studios LLC Aerial Operations Manual, Monthly Maintenance Log, and DJI Phantom 2 Vision+ Instruction Manual).
Narrate Studios LLC seeks the requested relief because the DJI Phantom 2 Vision+
UAS do not require an airworthiness certificate in accorda nce with 14 C.F.R. Part 21, Subpart H. Therefore, Narrate Studios LLC will ensure that the DJI Phantom 2 Vision+
UAS are in airworthy condition based upon its compliance with the operating documents (i.e ., Monthly Maintenance Log, and DJI Phantom 2 Vision+ 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 Narrate Studios LLC Seeks And The Reason Narrate Studios LLC Seeks Relief From Section 91.121. Relief from Section 91.121, entitled Altimeter settings , may be required to allow flight operations of the DJI Phantom 2 Vision+ UAS , which utilize a barometric pressure sensor, GPS equipment, and a radio communications telem etry data link to downlink altitude information from the UA to the PIC at the ground control station (GCS). Since the FAA requires that any altitude information concerning UAS operations be reported to air traffic control (ATC) in feet above ground level ( AGL), Narrate Studios LLC seeks the requested relief because the DJI Phantom 2 Vision+ 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.14 Considering the limited altit ude of the proposed operations, relief from 14 CFR 91.121 is sought to the extent necessary to comply with the applicable conditions and limitations stated below. As more fully set forth herein, an equivalent level of safety will
be maintained since the DJ I Phantom 2 Vision+ UAs are equipped with a barometric pressure sensor and GPS equipment, which automatically ensures that a ground level pressure setting will be established prior to each flight, and provides the PIC with altitude
information of the UA on the heads

- up display of the GCS.
4. Extent Of Relief Narrate Studios LLC Seeks And The Narrate Studios LLC 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+ 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, as suming normal cruising speed, to fly after that for at least 4.5
minutes. Narrate Studios 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+ UA will seve rely constrain the practicality of any aerial video or still photo flight operations that Narrate Studios proposes to conduct pursuant to this Petition. Significantly, as set forth below, the technical specifications of the DJI Phantom 2
Vision+ UAS , the DJI Phantom 2 Vision+ operating documents, and Narrate Studios
LLC’s proposed operating limitations, ensure that Narrate Studios LLC will safely operate the battery powered DJI Phantom 2 Vision+ UAs during daylight hours in visual meteorological conditions (VMC), under visual flight rules (VFR), with enough battery15 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 Narra te Studios LLC Seeks And The Reason Narrate Studios 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 aircr aft with an airworthiness certificate, Narrate Studios LLC requests relief
from these Sections because the DJI Phantom 2 Vision+ UAS do es not require airworthiness certificates. As set forth more fully below, the DJI Phantom 2 Vision+ UAS

meet s the conditi ons of FMRA Section 333 for operation without an airworthiness certificate. Accordingly, Narrate Studios LLC will use trained technicians to perform maintenance, alterations, or preventive maintenance on the UASs using the methods, techniques, and practice s prescribed in the UAS operating documents (i.e., the Narrate
Studios Aerial Operations Manual, Monthly Maintenance Log, and DJI Phantom 2 Vision+ Instruction Manual). Furthermore, Narrate Studios will document and maintain all
maintenance records for the DJI Phantom 2 Vision+ UAS

. D. The Reasons Why Granting Narrate Studios 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 interest by allowing Narrate
Studios LLC to safely, efficiently, and economically perform aerial video and photography
of special events, film sets, and landscape over certain areas of the United States. Additionally, use of the DJI Phantom 2 Vision + UAS will decrease congestion of
th e NAS, reduce pollution, and provide significant benefits to the economy. Notably, the
benefits of Narrate Studios LLC’s proposed operation of the DJI Phantom 2 Vision+ UAS will be realized without implicating any privacy issues.16 1. The Public Will Benefi t From Decreased Congestion Of The NAS.
The DJI Phantom 2 Vision+ UA 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 ai rcraft needed to perform aerial acquisitions, an exemption allowing the use of a DJI Phantom 2 Vision+ UAS would reduce the amount of manned aircraft in the NAS, reduce noise and air pollution, as well as increase the safety of life and property in the air and on the ground. Furthermore, by reducing the number of manned aircraft operating in the NAS, congestion around airports caused by arriving and departing aircraft will be reduced. The
DJI Phantom 2 Vision+ UA do not require an airport to takeoff or lan d. Likewise, a reduction of manned aircraft conducting aerial video and photography missions would result in fewer aircraft that must be handled by air traffic control during the ground, takeoff, departure, arrival, and landing phases of flight operations. 2. The Public Will Benefit From The Safety And Efficiency Of The DJI Phantom 2 Vision+ UAS
. Conducting aerial acquisitions with the DJI Phantom 2 Vision+ UAS , instead of manned aircraft, will greatly benefit the public by drastically reducing the levels of air and noise pollution generated during traditional aerial video and still photography flight operations. By using battery power and electric motors, the DJI Phantom 2 Vision+ UAS produce no air pollution, and is the most viable environmentally consci ous alternative to the cabin class, six cylinder internal combustion engine aircraft that are typically utilized for aerial video and photography, while burning approximately 20

- 30 gallons per hour of
leaded aviation fuel. The DJI Phantom 2 Vision+ UA , whi le reducing the carbon footprint17 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+ UAS to perform aerial acqu isitions, 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 mem bers located onboard the aircraft, the DJI Phantom 2 Vision+ UA (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 approximately 42 feet, a length of 34 feet, and a fuel capacity of 180 gallons). 3. Performing Aerial Video and Photography Operations With The DJI Phantom 2 Vision+ UAS Will Benefit The Economy. In addition to being safe a nd efficient, the DJI Phantom 2 Vision + is also an economical alternative to using manned aircraft to conduct similar aerial operations. As such, operation of the DJI Phantom 2 Vision+ UAS will allow United States based companies, like Narrate Studios 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+ UAS is one such technology that not only allows companies greater operational flexibility compared to18 manned aircraft, but provid es such flexibility without the high operational cost of a
traditional manned aircraft. By operating the DJI Phantom 2 Vision+ UAS , companies such as Narrate Studios
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+ UAS , provides a stable workforce that increases consumer

spe nding; 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 acquisiti on flight operations that have been conducted for decades, Narrate Studios LLC proposed operation of the DJI Phantom 2 Vision+ UAS will not implicate any privacy issues. Specifically, the DJI Phantom 2 Vision+ UAS will be operated only in compliance with o perating documents (i.e., the Narrate Studios LLC Aerial Operations Manual, Monthly Maintenance Log, and DJI Phantom 2 Vision+ Instruction Manual) which requires property owner involvement as well as local law enforcement notification, and in accordance wi th the Federal Aviation Regulations, including the minimum altitude requirements of 14 C.F.R. § 91.119. E. The Reasons Why Granting The Exemption Would Not Adversely Affect Safety, Or How The Exemption Would Provide A Level Of Safety At Least Equal To Tha t Provided By The Rule From Which Narrate Studios LLC Seeks Exemption. 1. Reasons Why The DJI Phantom 2 Vision+ UA Meet The Conditions Of The FAA Modernization and Reform Act of 2012 (FMRA) Section 333.19 In consideration of the size, weight, speed, and limited operating area associated with the unmanned aircraft and its operation, Narrate Studios LLC operation of the DJI
Phantom 2 Vision+ UAS meet the conditions of FMRA Section 333, and will not require
an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H. Section 333 provides authority for a UAS to operate without airworthiness certification and sets forth requirements for considering whether a UAS will create a hazard to users of the NAS or the public, or otherwise pose a threat to national security. Specifically, FMRA Section 333 states the following, in part: (a) In General.

-- Notwithstanding any other requirement of this subtitle, and not later than 180 days after the date of enactment of this Act, the Secretary of Transportat ion 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. (b) Assessmen t 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, proxim ity 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 au thorization, or airworthiness certification under section 44704 of title 49, United States Code, is required for the operation of unmanned aircraft systems identified under paragraph (1). (c) Requirements for Safe Operation.

-- If the Secretary determines under this section that certain unmanned aircraft systems may operate safely in the national airspace system, the Secretary shall establish requirements for the safe operation of such aircraft systems in the national airspace system. In seeking this exem ption, Narrate Studios LLC submits that the DJI Phantom 2
Vision+ UAS can operate safely in the NAS pursuant to FMRA Section 333, as20 demonstrated by: (a) the characteristics of the DJI Phantom 2 Vision+ UAS ; (b) the pilot certification requirement; and (c) the specific operating limitations. a. The Specifications Of The DJI Phantom 2 Vision+ UAS Demonstrate Its Safe Characteristics. The DJI Phantom 2 Vision+ UAS do es not create a hazard to users of the NAS or the public, or otherwise pose a threat to nati onal security considering its size, weight, speed, and operational capability. i. Technical Specifications Of The DJI Phantom 2 Vision+ UAS
. The technical specifications of the DJI Phantom 2 Vision+ UAS is set forth by the
DJI Phantom 2 Vision+ Specific ations and Data Sheet, at tached hereto as Exhibit A

. ii. The DJI Phantom 2 Vision+ UAS Autonomous Flight And Navigation Modes Enable The UAS To Remain Within A Defined Operational Area. The DJI Phantom 2 Vision+ UAS may be operated in both manual and fully autonomous flight modes. A complete description of the flight and navigational modes of
the DJI Phantom 2 Vision+ U AS is provided at pages 25

- 35 of the DJI Phantom 2 Vision+
User Manual , attached hereto as Exhibit B

. iii. The DJI Phantom 2 Visio n+ UAS Are Designed For Automatic Return To Home Point Or Hover In The Event Of Loss Of The Control Link Or Navigation. When the Control Link is lost, the DJI Phantom 2 Vision+ UA will remain stationary, in flight, for 3 seconds or more. If, after 3 seco nds, the DJI Phantom 2 Vision+
UA do es not reacquire control link data from the GCS, the UA will assume that the
Control Link is lost and the UA will return to the home position (i.e., failsafe mode) via GPS, and will descend to the takeoff position and sh utdown.21 A complete description of the Failsafe Functions of the DJI Phantom 2 Vision+ UAS are set forth at pages 27 through 29 of the DJI Phantom 2 Vision+ User Manual , attached hereto as B

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

. b. Flight Operations Of DJI Phantom 2 Vision+ UA S Are Limited To The Line Of Sight Of A Certificated Pilot in Command With A Safety Observer. Narrate Studios 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+ UAS . Additionally, a safety observer will assist all pilots during flight time. c. Flights Of DJI Phantom 2 Vision+ UAS Will Be Conducted Pursuant To Specific Operating Limitatio ns. In seeking this exemption, proposes to commercially operate DJI Phantom 2
Vision+ UAS for the special purpose of conducting aerial video and photography over certain areas of United States, pursuant to the following specific operating limitations:
1. Operations authorized by this grant of exemption will be limited to the following aircraft described in the operating documents, rotorcraft UASs weighing less than 55 pounds maximum gross weight: DJI Phantom 2 Vision+ Unm anned Aircraft System . Proposed op erations 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 operations for the purpose of aerial video and photography. 3. The UAs may not be flown a t an indicated airspeed exceeding 20 knots.22 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 sp ecified on the PIC’s FAA

- issued airman medical certificate. 6. The use of first person view (FPV) by the PIC or safety observer (SO) is not permitted. 7. All operations must utilize a safety observer (SO). The SO may be used to satisfy the VLOS require ment as long as the PIC always maintains VLOS capability. The SO and PIC must be able to communicate verbally at all times. Electronic messaging or texting is not permitted during flight operations. The PIC must be designated before the flight and cannot t ransfer his or her designation for the duration of the flight. The PIC must ensure that the SO can perform the functions prescribed in the operating documents. 8. The SO must not perform any other duties beyond assisting the PIC with seeing and avoiding other air traffic and other ground based obstacles/obstructions and is not permitted to operate the camera or other instruments. 9. The operating documents and the grant of exemption must be accessible during UAS operations and made available to the Admi nistrator upon request. If a discrepancy exists between the conditions and limitations contained in the grant of exemption and the procedures outlined in the operating documents, the conditions and limitations contained in the grant of exemption take prece dence 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 update d 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 affec t 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 doc uments. 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 safe operation of the UAS, the aircraft is prohibited from operating until the neces sary 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 the23 preflight inspection. All maintenance and alterations must be properly documented in the aircraft records.
1 1. Any UAS that has undergone maintenance or alterations that affect the UAS operation or flight characteristics, e.g. replacement of a flight critical component, must undergo a functional test flight. The PIC who conducts the functional test flight must m ake an entry in the aircraft records. 12. The pre

- flight inspection must account for all potential discrepancies, e.g. inoperable components, items, or equipment, not already covered in the relevant sections of the operating documents. 13. The operator must follow the UAS manufacturer’s aircraft/component, maintenance, overhaul, replacement, inspection, and life limit requirements. 14. The operator must carry out its maintenance, inspections, and record keeping requirements, in accordance with the ope rating 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 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 disco vered between inspections. 17. The PIC must possess at least a private pilot certificate 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 crite ria 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 str uctures. 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 condu cted 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 nonpartic ipants in accordance with 14 C.F.R. § 91.119. 19. UAS operations may not be conducted during night, as defined in 14 C.F.R. § 1.1. All operations must be conducted under visual meteorological conditions (VMC). If flight at night is required, a special re quest will be made at the FAA24 office closest to proposed area of operations. Flights under special visual flight rules (SVFR) are not authorized. 20. The UA may not operate within 5 nautical miles of an airport reference point as denoted on a current FAA

- published aeronautical chart unless a letter of agreement with that airport’s management is obtained, and the operation is 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 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. 22. 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. 23. The PIC must abort the flight in the event of unpredicted obstacles or emerg encies in accordance with the operating documents. 24. The PIC is prohibited from beginning a flight unless (considering wind and forecast weather conditions) there is enough power to fly at normal cruising speed to the intended landing point and land th e 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 oper ator 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, a ltitude level and potential transponder requirements. 26. All aircraft operated in accordance with the exemption must be identified by serial number, registered in accordance with 14 C.F.R. part 47, and have identification (N

- Number) markings in accorda nce with 14 C.F.R. part 45, Subpart C. Markings must be as large as practicable. 27. Before conducting operations, the radio frequency spectrum used for operation and control of the UA must comply with the Federal Communications Commission (FCC) or other appropriate government oversight agency requirements. 28. The documents required fewer than 14 C.F.R. 91.9 and 91.203 must be available to the PIC at the Ground Control Station of the UAS any time the UAS is operating. These documents must be made avail able to the Administrator or any law enforcement official upon request.25 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 de vice or vehicle. 31. Flight operations must be conducted at least 500 feet from all nonparticipating persons (persons other than the PIC, SO, operator trainees or essential persons), vessels, vehicles, and structures unless: a. Barriers or structures ar e 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 le ave 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 permis sion and the PIC has made a safety assessment of the risk of operating closer to those objects and determined that it does not present an undue hazard, and; c. Operations nearer to the PIC, SO, operator trainees or essential persons do not present an und ue hazard to those persons per § 91.119(a). 32. All operations shall be conducted over private or controlled

- access property with permission from the land owner/controller or authorized representative. Permission from land owner/controller or authorized representative will be obtained for each flight to be conducted. 33. Any incident, accident, or flight operation that transgresses the lateral or vertical boundaries of the operational area as defined by the applicable COA must be reported to the FAA's U AS 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 F rom The Requirements Of Section 61.113(a) And (b) Would Not Adversely Affect Safety. Narrate Studios LLC submits that the equivalent level of safety established by Section 61.113(a) and (b) will be maintained because no PIC will be allowed to operate the
DJI Phantom 2 Vision+ UAS unless that PIC has demonstrated, by meeting minimum flight

- hour and currency requirements, that the PIC is able to safely operate the DJI26 Phantom 2 Vision+ UAS in a manner consistent with the exemption, including evasive and

eme rgency maneuvers and maintaining appropriate distances from people, vessels,
vehicles and structures. Considering Narrate Studios LLC proposed area of operations, and the operating
limitations set forth

- above; the parallel nature of private pilot aeronaut ical knowledge requirements to those of commercial pilot requirements ( See Exemption No. 11062); and the airmanship skills necessary to safely operate the DJI Phantom 2 Vision+ UAS, Narrate
Studios LLC submits that the additional manned airmanship experien ce of a commercially certificated pilot would not correlate to the airmanship skills necessary for Narrate Studios
LLC specific proposed flight operations. The FAA has previously granted relief from Section 61.113(a) and (b) specific to UAS, in circumstan ces 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, 11158, 11159, 11160, 11161).
Narrate Studios LLC will not allow any PIC to operate the DJI Phantom 2 Vision+ UAS unless that PIC has demonstrated, by meeting minimum flight

- hour requirements or
the DJI Phantom 2 Vision+ UAS training and currency requirements, that the PIC is able to safely operate the DJI Phantom 2 Vis ion+ UAS in a manner consistent with this exemption, including evasive and emergency maneuvers and maintaining appropriate distances from people, vessels, vehicles and structures. Specifically, the PIC must have accumulated and logged, in a manner consist ent 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 of27 UAS to be used for operations under the exemption). In addition to the hour requir ements, 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 ens ure an equivalent level of safety during Narrate Studios LLC 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 prior 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 hours logged as a UAS pilot with a multi

- rotor UAS. Prior to operations under Exemption No. 11062, the PIC must also have accumulated and logged a minimum of 5 hours as a UAS pilot operating the same make an d 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 an d the 10 hours may be included in the total 25 hours of UAS rotorcraft time. In addition to the hour requirements, the PIC must accomplish 3 takeoffs and landings in the preceding 90 days (for currency purposes). The FAA finds that at a minimum, the flight

- hour requirements in Exemption No. 11062 are appropriate to practice and build proficiency in the skills necessary to safely conduct the petitioner’s proposed operations. The FAA also finds that prior documented flight experience that was obtained in comp liance with applicable 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 experienc e - building flights 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. Accordingly, Narrate Studios will ensure safe operations by not allowing any PIC to operate the DJI P hantom 2 Vision+ UAS unless that PIC has demonstrated, by meeting minimum flight

- hour and currency requirements, that the PIC is able to safely operate the DJI Phantom 2 Vision+ UAS in a manner consistent with the exemption, including evasive28 and emergency maneuvers and maintaining 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 maintained because prior to every flight, Narrate Studios LLC will ensure that the DJI Phantom 2 Vision+ UAS is in an airworthy condition based upon the UAS’s compliance with its operating documents and as stated in the conditions and limi tations 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, 1 1109, 11110, 11112, 11136, 11138, 11150, 11153, 11156, 11157, 11158, 11159, 11160, 11161). 4. Reasons Why An Exemption From The Requirements Of Section 91.121 Would Not Adversely Affect Safety. The equivalent level of safety established by Section 91.12 1 will be maintained
because the altitude information of the DJI Phantom 2 Vision+ UA will be provided to the PIC via GPS equipment and a radio communications telemetry data link, which downlinks from the UA to the GCS for active monitoring of the flight p ath and altitude. This altitude information, combined with Narrate Studios LLC’s operation of the DJI Phantom 2
Vision+ UA within visual line of sight, at or below 500 feet AGL, will ensure a level of safety equivalent to Section 91.121. The altitude infor mation will be generated by GPS equipment installed onboard the aircraft. Prior to 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 t o UAS, in circumstances similar, in all material respects, to those presented herein (e.g. Exemption29 Nos. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11112, 11136, 11138, 11150, 11153, 11156, 11157, 11158, 11159, 11160, 11161). 5. Reasons Why An Exemption From The Requirements Of Section 91.151(b) Would Not Adversely Affect Safety. A grant of this exemption would ensure an equivalent level of safety established by 14 C.F.R. Section 91.151(b) as a result of (1) the technical specifications of the DJI
Phantom 2 Vision+ UA s; (2) the limitations on the proposed flight operations; and (3) the location of the proposed flight operations. Accordingly, Narrate Studios will ensure that it will safely operate the battery powered DJI Phantom 2 Vision+ UA during daylight hours in VFR conditions, with enough battery power to fly for a total 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+ UAS ; the limitations on the proposed flight operations; and the location of the proposed operations, will ensure an equivalent level of safety established by 14 C.F.R. Section 91.151(b). Fu rthermore, safety will be ensured as the DJI Phantom 2 Vision+ UAS provide audible and visual warnings to the PIC at the GCS when the UAs experiences low battery voltage, the first warning occurring at approximately 33% remaining battery power, and again a t approximately 10% remaining battery power. At the critically low battery level, the DJI Phantom Vision+ UAS will descend and land automatically. Significantly, previous exemptions granted by the 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, including30 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 Affec t Safety. In seeking this exemption, Narrate Studios LLC submits that the equivalent level of safety with regard to the regulatory maintenance and alteration requirements established by Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417( a) & (b) will be met
because Narrate Studios LLC will use trained technicians to perform maintenance, alterations, or pr eventive maintenance on the UAS using the methods, techniques, and practices prescribed in the operating documents (i.e., the Narrate St udios Aerial Operations Manual, Monthly Maintenance Log, and DJI Phantom 2 Vision+ Instruction Manual). Furthermore, Narrate Studios LLC will document and maintain all maintenance records for
the DJI Phantom 2 Vision+ UAS.
Since the DJI Phantom 2 Vision+ UAS will be inspected as prescribed by the operating documents, Narrate Studios LLC will maintain the equivalent level of safety established by Sections 91.405(a), 91.409(a)(1), and 91.409(a)(2). A copy of the DJI
Phantom 2 Vision+ User Manuals are attache d hereto as Exhibit B ; a copy of the DJI
Phantom 2 Vision+ UAS Maintenance LOG is attached hereto as Exhibit C

. Likewise, the exemption sought will not adversely affect safety because Narrate
Studios LLC will use trained technicians to perform maintenance , alterations or preventive31 maintenance on the UAS using the methods, techniques, and practices prescribed by the operating documents. Furthermore, the exemption sought would maintain an equivalent level of safety established by Sections 91.407, 91.417(a) and 91.417(b), because all maintenance of the
DJI Phantom 2 Vision+ UAS will be performed by trained technicians. Maintenance will be documented and maintained utilizing the monthly maintenance log. Significantly, previous exemptions granted by the FAA c oncerning 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 Narrate Stud ios LLC proposed operating limitations, the operating documents, and the technical aspects of the DJI Phantom 2 Vision+ UAS , Narrate Studios 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 previously granted relief specific to UAS in circumstances similar, in all material respects, to those presented herein (e.g. Exemption Nos. 11062, 11063, 11064, 11065, 11066, 11067, 11 080, 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 1 4 C.F.R. § 21.16 entitled Special Conditions , Narrate Studios LLC requests that the FAA prescribe special conditions for the intended operation of the DJI Phantom 2
Vision+ UAS , which contain such safety standards that the Administrator finds necessary32 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 perm it 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 hazar d to users of the NAS or the public, or otherwise pose a threat to national security; and further, provides the authority for such UAS to operate without airworthiness certification in accordance with any requirements that must be established for the safe operation of the UAS in the NAS. Likewise, the Administrator may prescribe special conditions pursuant to 14 C.F.R. § 21.16, for operation of the DJI Phantom 2 Vision+ UAS , since the airworthiness regulations of 14 C.F.R. Part 21 do not contain adequate o r appropriate safety standards, due to the novel or unusual design features of the aircraft. Section 21.16, entitled Special
Conditions , states the following: If the FAA finds that the airworthiness regulations of this subchapter do not contain adequate o r 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 c onditions 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 accordance with FMRA Section 333 and 14 C.F.R. § 21.16, the FAA may prescribe special conditions for Leading Edge’s intended operation of the DJI
Phantom 2 Vision+ UAS , which contain such safety standards that the Admin istrator finds necessary to establish a level of safety equivalent to that established by 14 C.F.R. Part 21,33 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 Narrate Studios LLC Seeks Exemption:
Narrate Studios 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 Narrate Studios LLC Seeks: This exemption will permit Narrate Studios 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.
G. Any Additional Information, Views, Or Arguments Available To Support Narrate Studios LLC Request. This Petition is made pursuant to the FAA Modernization and R eform Act of 2012 (FMRA) Section 333, which directs the Secretary of Transportation to determine if certain UAS may operate safely in the NAS. As such, Narrate Studios LLC request for exemption may be granted pursuant to the authority of FMRA Section 333 and 14 C.F.R. Part 11, as
set forth above. FMRA Section 333 sets forth the requirements for considering whether a UAS will create a hazard to users of the NAS or the public, or otherwise pose a threat to national security; and further, provides the author ity for such UAS to operate without airworthiness
certification. As discussed in detail above, Narrate Studios LLC will operate the DJI Phantom 2 Vision+ UASs safely in the NAS, without creating a hazard to users of the NAS, or the public, or otherwise po se a threat to national security.
CONCLUSION34 As set forth herein, Narrate Studios 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 Phan tom 2 Vision+ UAS commercially, without an airworthiness certificate, for the limited purpose of conducting aerial video and photography over certain areas of the United States. By granting this Petition, the FAA Administrator will be fulfilling the Congre ssional mandate of the FAA Modernization and Reform Act of 2012, while also advancing the interests of the public, by allowing Narrate
Studios LLC to safely, efficiently, and economically operate the DJI Phantom 2 Vision+
UAS commercially within the NAS.
WHEREFORE , in accordance with the Federal Aviation Regulations and the FAA Modernization and Reform Act of 2012, Section 333 , Narrate Studios 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), 91.121, 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+ UAS commercially for the purpose of conducting aerial video and ph otography over certain areas of the United States.
Date d: March 31 , 2015 Respectfully submitted,
Andrew Fischer

_________________________ Andrew W. Fischer Narrate Studi os LLC 211 North 1st S treet #240 Minneapolis, MN 55401 Tel: (320)491

- 7280 Email: awfisch@gmail.com35 Appendic es :
A

– DJI Phantom 2 Vision+ Specifications Data Sheet B

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

– Monthly Ma intenance Log

APPENDIX

– A DJI PHANTOM 2 VISION+ TECHNICAL SPECIFICATIONS
Narrate Studios 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 f l ight to a predetermined and set distance. In addition, DJI sof tware 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 Velocity

- 200 0 /s 1.1.1.5 Max Tilt Angel

- 35 0 1.1.1.6 Max Ascent Speed

– 6m/s 1.1.1.7 Max Descent Speed

– 2m/s 1.1.1.8 Max Fl ight 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 Op erating 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

– 5.85GHz36 1.1.4.2 Communication Distance (unobstructed)

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

- - 93dBm 1.1.4.4 Transmitter Power

– FCC Compliance: 100mW 1.1.4.5 Working Voltage

– 120mA@3.7V
1.1.5 Ran ge Extender 1.1.5.1 Operating Frequency

– 2412

- 2462MHz 1.1.5.2 Communication Distance (unobstructed)

– 500

- 700m 1.1.5.3 Transmitter Power

– 20dBm 1.1.5.4 Power Consumption

– 2W37 APPENDIX

– B
DJI Phantom 2 Vision+ Manufacturer’s User Manual38 A PPENDIX

– C

Andrew W. Fischer Narrate Studi os LLC 211 North 1st S treet #240 Minneapolis, MN 55401 Tel: (320)491

- 7280 Email: awfisch@gmail.com month:_________(year:________ UAS$#:$___________ Date(Issue( Discovered Date(Issue( Addressed Software(Updates

Airframe(

Engines

Propellers

Camera(Gimbal

Landing(Gear

Vibration(Dampening

Other: MONTHLY$MAINTENANCE$LOG

Issue(Description(&(Maintenance(Conducted Maintenance(Performed(By:((( Print(&(Sign39