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

Regulatory Docket No.

__________________
IN THE MATTER OF THE PETITION FOR EXEMPTION OF: Jeffrey Brock FOR AN EXEMPTION SEEKING RELIEF FROM THE REQUIREMENTS OF TITLE 14 OF THE CODE OF FEDERAL REGULATIONS SECTIONS 61.101(e)(4) & (5), 61.23(a), 61.315(a), 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 INSPIRE 1 AND DJI PHANTOM 2 UNMANNED AIRCRAFT SYSTEMS PURSUANT TO

SECTION 333 OF THE FAA MODERNIZATION AND REFORM ACT OF 2012 (PUBLIC LAW 112

- 95)

Submitted on 19 October 2015

Jeffrey Brock | 206 Oconee Dr | C ohutta, Georgia 30710 | 706

- 264

- 1568

Email: jeff@webmizer.com

TABLE OF CONTENTS

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 JEFFREY BROCK SEEKS EXEMPTION..........

........... ....... 8

THE EXTENT OF RELIEF Jeffrey Brock SEEKS AND THE REASON JEFFREY BROCK SEEKS THE RELIEF.......... . . 11

THE REASONS WHY GRANTING JEFFREY BROCK ’S REQUEST WOULD BE IN THE PUBLIC INTEREST ......

.. .... 15

THE REASONS WHY GRANTING THE EXEMPTION WOULD NOT ADVERSELY AFFECT SAFETY.......

................. ...... 19

SUMMARY THAT CAN BE PUBLISHED IN THE FEDERAL REGISTER. ....

..................................................... ............. 34

ANY ADDITIONAL INFORMATION, VIEWS, OR ARGUMENTS AVAILABLE TO SUPPORT JEFFREY BROCK ’S REQUEST....

...................................................................................................................... .................. ........ ............ .......... ........ 34

CONCLUSION ................................................................................................................

............................ ............ 35

APPENDICES....................................................................................

................................................... ............................... ....37

2

GLOSSARY OF ABBREVIATIONS

 AGL Above Ground Level

 AOI Area of Interest

 ATC Air Traffic Control

 ATO Air Traffic Organization

 AV Aerial Vehicle

 CFR Code of Federal Regulations

 COA Certificate of Authorization

 FAA Federal Aviation Administration FAR Federal Aviation Regulation

 GCS Ground Control Station

 GPS Global Positioning System

 LOL Loss of Link

 NAS National Airspace System

 NOTAM Notice to Airman

 PIC Pilot In Command

 Section 333 FAA Modernization and Reform Act of 2012 (FMRA) 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 Takeof f and Landing

3

SUMMARY

Jeffrey Brock seeks exemption from the requirements of 14 C.F.R §§ 61.101(e)(4) and (5), 61.315(a), 61.23(a), 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 Unma nned Aircraft System pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (FMRA). This exemption will permit Jeffrey Brock to operate an Unmanned Aircraft System (UAS) for the commercial purpose of conducting aerial video and photography of construction sites, building inspections, agricultural lands, outdoor recreational facilities, real estate, special events, and landscapes within the United States.

INTRODUCTION AND INTERESTS OF THE PETITIONER

Jeffrey Brock will provide its clients wit h high quality digital content for use in their commercial, personal, and non

- profit multimedia projects. Jeffrey Brock has years of film making and photography experience and will use state

- of

- the

- art technology to make high quality video and photo produc tions for any client. Jeffrey Brock has over 3 years recreational/hobby experience in all aspects of aerial video and photography. The objective of Jeffrey Brock aerial video and photography operations is to provide high quality imaging for a variety of co mmercial, public, and residential uses, specifically targeting:

 Aerial event filming and photography

 Promotional videos for businesses, non

- profits & government entities

 Photo and video production for real estate marketing

4

BACKGROUND

Unmanned Aircraft Systems: DJI Inspire 1 UAS & DJI Phantom 2

Jeffrey Brock seeks an exemption to operate DJI systems for compensation or hire within the NAS. The DJI Inspire 1 (Inspire 1) and DJI Phantom 2 are vertical takeoff and landing (VTOL) Unmanned Aircraft (UA) with a Ground Contro l Station (GCS) utilizing electronic tablet or smart phone systems. The Inspire 1 and Phantom 2 are electric powered rotary wing UAS that is capable of transmitting live airborne video images and location information to a Ground ControlStation (GCS). Both the Phantom and Inspire store the photographs and data on board and makes them available for
download after completion of the flight. The Inspire is 22 in x 22 in x 8 in and weighs 6.4 pounds, and the Phantom 2 is lighter at 2.2 pounds. 14 in x 14 in x 6 in. Both are well under the 55 lbs mandated in the FMRA. The Inspire has a maximum cruising speed of 42 knots while the Phantom has a maximum cruising speed of 29 knots. Both are battery powered, have a flight endurance of 22 minutes and can operate in tem peratures ranging from 0° to 40° C. Both the Inspire and the Phantom 2 have omni

- directional antenna with a range of 2.1 km and operating in the 2.420

– 2.483 GHz frequency range.

The Inspire 1 and Phantom 2 that will be operated by Jeffrey Brock will be r egistered in accordance with 49 U.S.C. 44103, Registration of Aircraft, as well as 14 C.F.R Part 47, Aircraft Registration, and marked in accordance with 14 C.F.R. Part 45, Identification and Registration Marking.

5

BASIS FOR PETITION

The petitioner, Jeffrey Brock , 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 Systems, hereby petitions the Administrator to comm ercially operate the DJI Inspire 1 & Phantom 2 in the National Airspace System (NAS), and for an exemption from the requirements of 14 C.F.R §§ 5 61.101(e)(4) and (5), 61.315(a), 61.23(a), 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 li mited operating area associated with the unmanned aircraft and its operation, Jeffrey Brock ’ s operation of the DJI Phantom 2 and Inspire 1 UAS meets the conditions of FMRA Section 333

a nd therefore, will not require an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart

H.

Accordingly, Jeffrey Brock requests relief from Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & ( b), as these sections set forth requirements for maintenance that only apply to aircraft wit h an airworthiness certificate.

Jeffrey Brock submits that the requested relie f is proper since an equivalent level of safety will be ensured. Jeffrey Brock will use experienced personnel and technicians to perform maintenance, alterations, or pre ventive maintenance on the
UASs using the methods, techniques, and practices prescribed in the operating documents (i.e., Monthly Maintenance Log, Phantom 2 Instruction Ma n ual and DJI Inspire 1 Instruc tion Manual). Furthermore, Jeffrey Brock will docume nt and
maintain all maintenance records for the DJI Inspire 1 UAS & DJI P hantom 2 UAS

. Jeffrey Brock also seeks an exemption f rom the requirements of Section 91.121, entitled Altimeter Settings, as the DJI Inspire 1 an d Phantom 2 UAs will not have a typical barometric altimeter onboard. However, altitude information of the DJI Inspire 1 and Phantom 2 UAs will be provid ed to the PIC via Global Positioning System (GPS) equipment and radio communications telemetry data link, which downlinks from the UAs to the GCS for active monitoring of the flight path.
This altitude information, combined with Jeffrey Brock ’s skilled ope ration of the DJI Insp ire 1 UAS & Phantom 2 within
visual line of sight, at or below 4 00 feet AGL, will ensure a level of safety equivalent to Section 91.121.

Jeffrey Brock also seeks an exemption f rom the requirements of Section 91.151(b), entitled Fuel requirements for flight
in VFR conditions. Jeffrey Brock submits that safety will not be affected by operation of the DJI Inspire 1 and Phantom 2 UAs during daylight hours in visual meteorological condi tions (VMC) under visual flight rules (VFR), with enough battery

po wer to fly for a tot al duration of approximately 15 minutes to the first point of intended landing and, assumin g normal cruising speed, to fly after that for at least 5 minutes.

7

In accordance with 14 C.F.R. § 11.81, Jeffrey Brock provides the following information in support of its petition for exemption:A. Name & Address Of The Petitioner. The name and address of the Petitioner and point of contact is:

Jeffrey Brock
206 Oconee Dr Cohutta, Ga 30710
Tel: 706

- 264

- 1568
Email: jeff@webmizer.com

8

B. The Specific Sections Of 14 C.F.R. From Which Jeffrey Brock Seeks Exemption.

3. Jeffrey Brock Seeks Exemption From The Requirements Of Section 61.315(a).

(2) For compensation or h ire.

(3) In furtherance of a business.

- (ci) Jeffrey Brock 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 airworthy condition.

5. Jeffrey Brock 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 cruis ing altitude or flight level of that aircraft, as the case may be, by reference to an altimeter that is set, when operating

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

-
(i) The current reported altimeter setting of a station along the route and within 100 nautical
miles of the aircraft;

(ii)If there is no station within the area prescribed in paragraph (a)(1)(i) of this section, the current reported altimeter setting of an appropriate available station; or

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

9

6. Jeffrey Brock Exemption From The Requirements Of Section 91.151(b).

Section 91.151, entitled Fuel requirements for flight in VFR conditions, subsection

(b), states the following: (b)No person may begin a flight in a rotorcraft under VFR conditions unless (considering wind and forecast weather conditions) there is enough fuel to fly to the first point of intended landing and, assuming normal cruising speed , to fly after that for at least 20 minutes.

7. Jeffrey Brock 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 tha t aircraft inspected as prescribed in subpart E of this part and shall between required

inspections, except as provided in paragraph (c) of this section, have discrepancies repaired as prescribed in part 43 of this chapter[.]

8. Jeffrey Brock From The Requ irements Of Section 91.407(a)(1)

Section 91.407, entitled Operation after maintenance, preventive

maintenance, rebuilding, or alteration, subsection (a)(1), states the following:

(a) No person may operate any aircraft that has undergone maintenance, preven tive maintenance, rebuilding, or alteration unless

-
(1)It has been approved for return to service by a person authorized under § 43.7 of this chapter[.]

(b) Jeffrey Brock Seeks Exemption From The Requirements Of Sections 91.409(a)(1) and 91.409(a)(2).

Sect ion 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 acco rdance 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 airworthine ss certificate in accordance 10 with part 21 of this chapter.

10. Jeffr ey Brock Exemption From The Requirements Of Sections 91.417(a) and 91.417(b).

Section 91.417, entitled Maintenance records, sub sections (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 ap proved inspections, as appropriate, for each aircraft (including the airframe) and each engine, propeller, rotor, and appliance of an aircraft. The records must include

-
(i)A description (or reference to data acceptable to the Administrator) of the work performed; and

(ii)The date of completion of the work performed; and

(iii)The signature, and certificate number of the person approving the aircraft for return to 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 b e 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 o f applicable airworthiness directives (AD) and safety directives including, for each, the method of compliance, the AD or safety directive number and revision date. If the AD or safety directive involves recurring action, the time and date when the next ac tion is required.(vi) Copies of the forms prescribed by § 43.9 (d) of this chapter for each 11 major alteration to the

airframe and currently installed engines, rotors, propellers, and appliances.

(b) The owner or operator shall retain the following record s 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 t his section shall be retained and transferred with the
aircraft at the time the aircraft is sold.

(3)A list of defects furnished to a registered owner or operator under § 43.11 of this chapter shall be retained until the defects are repaired and the aircra ft is approved for return to service.

C. The Extent Of Relief Jeffrey Brock Seeks And The Reason Jeffrey Brock Seeks The Relief.

1.Extent Of Relief Jeffrey Brock Seeks And The Reason Jeffrey Brock Seeks Relief From Section 61.113(a) and (b).

Relief from Section 61.113(a) and (b) entitl ed Private pilot privileges and limitations: Pilot in command, is requested to
the extent nec essary to allow a PIC holding a private pilot or higher level certificate, as well as a c urrent and valid airman
medical certifica te, and who has met certain flight

- hour and curren cy 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 pilot may, for compensation or hir e, act as PIC of an aircraft in connection with any business or employment if: (1) The fl ight 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, Jeffrey Brock s ubmits that an equivalent level of safety will be maintained because no PIC
will be allow ed to operate the DJI Inspire 1 or Phantom 2 UAS unless that PIC has met certain flight

- hou r and currency requirements, 12 demonstrating that the PIC is able to safely operate either the DJI Inspire 1 or Phantom 2 UAS in a manner consistent with the operations spec ifications as described in this exemption, including evasive and emergency

ma neuvers, as well as maintaining appro priate distances from people, vessels, vehicles and structures.

Further, Jeffrey Brock submits that all f lights of the DJI Inspire 1 and Phantom 2 UAS, conducted by the PIC pursuant to the grant of this Pe tition:

(1) will be incidental to Jeffrey Brock b usiness; and (2) will not carry passengers or property for compensation or hire.

( 2 ) Extent Of Relief Jeffrey Brock Seeks And The Reason Jeffrey Brock Seeks Relief From Section 61.23(a).

Relief from Section 61.23(a), entitled Operations requiring a medical certificate:

Requirements and duration, is requested to the extent requi red to necessary to allow a PIC holding a sport pilot certificate or higher level certificate, as well as a current and valid driver’s license, to conduct the proposed UAS flight oper ations for compensation or hire.

This relief is requested since the limitations set fort h in Section 61.23(a) otherwise require the PIC of any flight for compensation or hire to hold a comprehe nsive FAA issued medical certificate. In Exemption No. 11213 to Aeryon L abs, Inc., the FAA “finds that, because of the risk mitigations established in the con ditions and limitations of this exemption, a person that holds a U.S. issued driver’s license who is operating a UAS will not adversely affect safety. The FAA is granting relief fro m § 61.23(a) to allow any pilot that holds one of the pilot’s certificates discussed ab ove to operate a UAS under this exemption with a U.S. issued driver’s license, in lieu of an FAA

- issued medical certificate.14

4. Extent Of Relief Jeffrey Brock Seeks And Jeffrey Br ock 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 Jeffrey Brock to determine that the DJI Inspire 1 UAS & Phantom 2 are in airworthy condition prior to every flight b y ensuring that the UAS is in compliance with the operating documents (i.e., the DJI Inspire 1 Maintenance Manual, Monthly Maintenance Log, and DJI Inspire 1 Instruction Manual & DJI Phantom 2 Instruction Manual ).

Jeffrey Brock seeks the requested relief b ecause the DJI Inspire 1 UAS & DJI Phantom do not require an airworthiness
certificate in accordance wit h 14 C.F.R. Part 21, Subpart H. Therefore, Jeffrey Brock will ensure that the DJI Inspire 1 UAS are in airworthy condition based upon its compliance with the ope rating documents (i.e., Monthly Maintena nce Log, and DJI Inspire 1 Instruction Manual) prio r to every flight, and further, determine that the aircraft are in condition for safe flight, as stated in the conditions and limitations below.

5. Extent Of Relief Jeffrey Brock Seeks And The Reason Jeff rey Brock Seeks Relief From Section 91.121.

Relief from Section 91.121, entitled Altimeter set tings, may be required to allow flight operations of the DJI Inspire 1 UAS, which utiliz e a barometric pressure sensor, GPS equipment, and a radio communications telemetry data link to
downlink altitude information from the UA to the PIC at the ground contr ol station (GCS). Since the FAA requires that any altitude information concerning UAS operations be reported to air traffic control (ATC) in feet above ground le vel (AGL), Jeffrey Brock seeks the requested relief because the DJI 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.

15

Considering the limited altitude of the proposed operations, relief from 14 CFR 91.121 is sought to the extent necessary to comply wit h the applicable conditions and limitations stated below. As more fully set forth herein, an equivalent level of safety will be maintained since the DJI Inspi re 1 UAs & DJI Phantom are equipped wi th a barometric pressure sensor and GPS equipment, which automatically ensures that a gro und level pressure setting will be established prior to each flight, and provides the PIC w ith altitude information of the UA on the heads

- up d isplay of the GCS.

6. Extent Of Relief Jeffrey Brock Seeks And Jeffrey Brock 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 Inspire 1 and Phantom 2 UAs during daylight hours in visual meteorological conditions (VMC), under visual flight rules (VFR), for a total duration of 15 minutes to the first point of intended landing and, assuming normal cruising speed, to fly after that for at least 5 minutes. Jeffrey Brock seeks the requested relief because without an exemption from Section 91.151(b), the flight time duration of the battery powered DJI Inspire 1 and
Phantom 2 UA s will severely constrain the practicality of any aerial video or still photo flight operations that Jeffrey
Brock proposes to conduct pursuant to this Petition.

Significantly, as set forth below, the technical spec ifications of the DJI Inspire 1 and Phantom 2 UAS, the DJI Inspire 1 and
Phantom 2 o perating documents, and Jeffrey Brock ’s proposed operating limitations, ensure that Jeffrey Brock will safely operate the battery powered DJI Inspire 1 and Phantom 2 UAs during daylight hours in visual meteorological
conditions

(VMC), under visual flight rules (VFR), with enough b attery power to fly for a total duration of 15 minutes to the first point of intend ed landing and, assuming normal cruising speed, to fly after that for at least 5 minutes.

16

7. Extent Of Relief Jeffrey Brock Seeks And The Reaso n Jeffrey Brock Seeks Relief From Sections 91.405(a), 91.407(a) (1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b).Since Sections 91.405(a), 91.407(a)(1), 91.409(a)(1 ) & (a)(2), and 91.417(a) & (b) only apply to aircraft with an airworthiness certificate, J effrey Brock requests relief from these Sections because the DJI Inspire 1 and Phantom 2 UAS does not require airworthiness certificates. As set forth more fully below, the DJI Inspire 1 and Phantom 2 UAS meets the conditions of FMRA Section 333 for ope rat ion without an airworthiness certificate. Accordingly, Jeffrey Brock will use highly trained technicians to perform maintenance, alterations, or preventive maintenance on the UASs using the methods, techniques, and practices prescribed in the UAS operating d ocuments (i.e., the DJI Inspire 1 Maintenance Manual, Phantom 2 Maintenance Man ual, Maintenance Log, Phantom 2 Instruction Manual, and DJI Inspire 1 Instruction
Manua l). Furthermore, Jeffrey Bro ck will document and maintain all maintenance records for the DJI Inspire 1 UAS.

D. The Reasons Why Granting Jeffrey Brock Request Would Be In The Public Interest; That Is, How It Would Benefit
The Public As A Whole.

Granting the present Petition will furth er the publ ic interest by allowing Jeffrey Brock to safely, efficiently, and economically conduct aerial video and photography of outdoor recreational facilities, real estate, special events, and
lands capes over certain areas of the United States.

Addition ally, use of the DJI Inspire 1 and Phantom 2 UAS will decrease congestion of the NAS, reduce pollution, and provide significant benefi ts to the economy. Notably, the benefits of Jeffrey Brock ’s proposed operation of the DJI Inspire 1 and Phantom 2 UAS will be realized without implicating any privacy issues.

17

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

The DJI Inspire 1 and Phantom 2 UAS are battery powered and serve as a safe, efficient, and economical alternative
to the manned aircraft traditio nally utilized to obtain aerial imagery. By reducing the amount of manned aircraft
needed to perform aerial acquisitions, an exemption allowing the use of a DJI Inspire 1 and Phantom 2 UAS would
reduce the amount of manned aircraft in the NAS, red uce 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 opera ting in the NAS, congestion around airports caused by arriving and departin g aircraft will be reduced. The DJI Inspire 1 and Phantom 2 UAS do not require an airport to takeoff or land. Likewise, a reduction of manned aircraft conducting aerial video and ph otography missions would result in fewer aircraft that must be handled by air tra ffic control during the ground, takeoff, departure, arrival, and landing phases of flight operations.

2.The Public Will Benefit From The Safety And Efficiency Of The DJI Inspire 1 and Phantom 2 UAS.

Conducting aerial acquisitions with the DJI Inspire 1 and Ph antom 2 UAS, instead of manned aircraft, will greatly benefit the public by drastic ally reducing the levels of air and noise pollution generated during traditional aerial video and still photography flight operations. By using battery power and electric mo tors, the DJI Inspire 1 and
Phantom 2 UAS produce no air pollution, and is the most viable environmentally conscious alternative to the cabin class, six cylinder internal comb ustion engine aircraft that are typically utilized for aerial video and photograp hy,
wh ile burning approximately 20

- 30 gallons per hour of leaded aviation fuel. The DJI Ins pire 1 and Phantom 2 UAS,
while reducing the carbon footprint of aerial acquisitions, also eliminates noise pollution, as the UASs are propelled by battery powered electric motors, rather than an internal combustion engine.

18

By using the DJI Inspire 1 and Phantom 2 UAS to p erform aerial acquisitions, the substantial risk to life and property in
the air and on the ground, w hich is usually associated with traditional manned aircraft flight operations , will be substantially reduced or completely eliminated. Aside from the lack of flig ht crew members located onboard the aircraft, the DJI Inspire 1 and Phantom 2 UAS ( Inspi re 1 weighing approximately 6.5 pounds maximum gross weights with a length of 17.3 in ches, width of 17.7 inches, and with no fuel on board, and Phantom 2 even smaller a nd lighter), haveless physical potential for collateral damage to life and property on the g round, and in the air, compared to the manned aircraft that typically conduc t similar operations (weighing approximately 6,000 pounds with a wingspan of

approx imately 42 feet, a length of 34 feet, and a fuel capacity of 180 gallons).

3.Performing Aerial Video and Photography Operations With The DJI Inspire 1 and Phantom 2 UAS Will Benefit The Economy.

In addition to being safe and efficient, the DJI Inspire 1 and Phantom 2 are economical alternatives to using manned
aircraft to conduct simi lar aerial ope rations. As such, operation of the DJI Inspire 1 and Phantom 2 UAS will allow United
States based companies, like Jeffrey Brock , to remain competit ive and contribute to growth of the U.S. economy. Specifically, with the rising cost of avia tion fuel and the Environmental Protection Agency (“EPA”) regulatory actions phasing out leaded aviation fuels, U.S. owned and operated companies must adopt new and alt ernative technology in
order to remain competitive. Operating the battery powered DJI Inspire 1 and Phant om 2 UAS allows companies greater operational flexibility c ompared to manned aircraft, and provides such flexibility without the high operational cost of a
traditional manned aircraft.

By operating the DJI Inspire 1 and Phantom 2 UAS, companies such as Jef frey Brock , can remain competitive and profitable, and therefore, provide greater job stability to employees and contractors, which will ultimat ely contribute to growth of the U.S. economy. Improved financial performance of U.S. companies, through commerci al use of the DJI Inspire 1 and Phantom 2 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 operatio ns that have been conducted for decades, Jeffrey Brock proposed operation of the D JI Inspire 1 and Phantom 2 UAS will not implicate any privacy issues. Specifically, the DJI Inspire 1 and
Phantom 2 UAS will be operated only in compliance with the condit ions set forth in any exemption granted under this petition.

E. The Reasons Why Granting The Exemption Would No t Adve rsely Affect Safety, Or How The Exemption Would Provide A Level Of Safety At Least Equal To That Provided By The Rule From Which Jeffrey Brock Seeks Exemption.

1. Reasons Why The DJI Inspire 1 and Phantom 2 UAs Meet The Conditions Of The FAA Moderni zation and Reform Act of 2012 (FMRA) Section 333

. In consideration of the size, weight, sp eed, and limited operating area associated with the unmanned aircraft and its operatio n, Jeffrey Brock operation of the DJI Inspire 1 and Phantom 2 UAS meet the cond itions 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 t o operate without airworthiness certification and sets forth requirements for consider i ng 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 Transportation shall determine if certain unmanned aircraft systems may operate safely in the national airspace system before completion of the plan and rulemaking requ ired by section 332 of this Act or the guidance requi red by section 334 of this Act.

(b) Assessment of Unmanned Aircraft Systems.

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

-(1) which types of unmanned aircraft systems, if any, as a result of their size, weight, speed, operational capability, proximity to airports and populated areas, and operation within visual line of sight do not create a hazard to users of the national air space system or the public or pose a threat to national security; and

(2) whether a certificate of waiver, certificate of authorization, or airworthiness certification under section 44704 of title 49, United States Code, is required for the operation of u nmanned 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 es tablish requirements for the safe operation of such aircraft systems in the national airspace system.

In seeking this exemption, Jeffrey Brock sub mits that the DJI Inspire 1 and Phantom 2 UAS can operate safely in the NAS pursuant to FMRA Section 3 33, as d emonstrated by:

(a) the characteristics of the DJI Inspi re 1 and Phantom 2 UAS;

(b) the pilot certification requirement; and

(c) the specific operating limitations.

a.The Specifications Of The DJI Inspire 1 and Phantom 2 UAS Demonstrate Its Safe Characteristics.

The DJI Inspire 1 and Phantom 2 UAS do not crea te a hazard to users of the NAS or the public, or otherwise pose a threat
to national securit y considering its size , weight, speed, and operational capability.

i. Technical Specifications Of The DJI Inspire 1 and Phantom 2 UAS

.

The technical specifications of the DJI Inspire 1 and Phantom 2 UAS are set forth by the DJI Inspire 1 and Phantom 2 Specifications and Data Shee t, attached hereto as Exhibit A.
ii. The DJI Inspire 1 and Phantom 2 UAS Autonomous Flight And Navigation Modes Enable The UAS To Remain Within A Defined Operational Area.

The DJI Inspire 1 and Phantom 2 UAS may be operated in both manual and fully autonomou s flight modes. A complete description of the flight and navigational modes of the DJI Inspire 1 and Phantom 2 UAS is provided in the DJI Inspire 1 21

User Manual, attached hereto as Exhibit B.1, and Phantom 2 User Manual, attaches hereto as Exhibit B.2

iii. T he DJI Inspire 1 and Phantom 2 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 Inspir e 1 and Phantom 2, the UAs will remain stationary, in flight, f or 3 seconds or more. If, after 3 seconds, the DJI Inspire 1 or Phantom 2 UA does not reacquire control link data from t he GCS, the UA
will assume that the Control Link is lost and the UA will return to the home pos ition (i.e., failsafe mode) via GPS, and will descend to the takeoff position and shutdown.

A complete description of the Failsafe Functions o f the DJI Inspire 1 and Phantom 2 UAS are set forth in the DJI Inspire 1 User Manual, att ached hereto as B.1 and Phantom 2 User Manual, attached hereto as B.2

iv. The DJI Inspire 1 GCS And Its Operation. A complete description of the operation and specifications of the DJI Inspire 1 GCS and flight control software is provided in the DJI Inspire 1 User Manual. DJI Inspire 1 User Manual is attached hereto as
Exhi bit B.b. Flight Operations Of DJI Inspire 1 and Phantom 2 UAS Are Limited To The Line Of Sight Of A

Certificated Pilot in Command With A Safety Observer.

Jeffrey Brock 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 Inspire 1 and Phantom 2 UAS. Additionally, a safety observer will assist all pilots during flight.

c. Flights Of DJI Inspire 1 and Phantom 2 UAS Will Be Conducted Pursuant To Specific Operating
Limitations. In seeking this exemption, proposes to commercially operate DJI Inspire 1 and Phantom 2 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 Inspire 1 and Phantom 2 Unmanned Aircraft System.

Propo sed 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 operations for the purpose of aerial video and photography.

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

4. The UAs must be operated at an altitude of no more than 4 00 feet above ground level (AGL), as indicated by the procedures specified in the operating documents unless a special request is made and approved by ATC. All altitudes reported to ATC must be in feet AGL.

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

- issued airman medical certificate.

6. The use of 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 o ther 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 Admini strator 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 precede nce and must be followed. Otherwise, the operator must follow the procedures as outlined in its operating documents. The operator may update or revise its operating documents. It is the operator’s responsibility to track such revisions and present updated and revised documents to the Administrator upon request. The operator must also present updated and revised documents if it petitions forextension or amendment to the grant of exemption. If the operator determines that any update or

revision would affect the basis upon which the FAA granted the exemption, then the operator must 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 docum ents.

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 necessar y maintenance has been performed and the UAS is found to be in a condition for safe flight. The Ground Control Station must be included in the preflight inspection. All maintenance and alterations must be properly documented in the aircraft records.

11.An y UAS that has undergone maintenance or alterations that affect the UAS operation or flight characteristics, e.g. replacement of a flight critical component, must undergo a functional test flight. The PIC who conducts the functional test flight must make a n 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 fol low 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 operating docu ments. 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 t he UAS
to service.

15.Each UASs operated under this exemption must comply with all manufacturer Safety Bulletins.

16.The authorized person must make an entry in the aircraft record of the corrective action taken against discrepancies discovered between i nspections.

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
criteria and demonstrate s the ability to safely operate the UAS in a manner consistent with how the UAS will be operated under the exemption, including evasive and emergency maneuvers and maintaining appropriate distances from persons, vessels, vehicles and structures. PIC qualif ication 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 dedicate d training sessions. During training, proficiency, and experience

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

19. UAS operations may not be conducted during night, as defined in 14 C.F.R. § 19.1. All operations
must be conducte d under visual meteorological conditions (VMC). If flight at night is required, a special request will be made at the FAA office closest to proposed area of operations. Flights under special visual flight rules (SVFR) are not authorized.

20. The UA may not operate within 5 nautical mi les 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’sCOA. 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 stat ute miles from the PIC.

22. If the UA loses communications or loses its GPS signal, it must return to a predetermined location within the planned operating area and land or be recovered in accordance with the operating
documents.

23. The PIC must abort t he flight in the event of unpredicted obstacles or emergencies 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 c ruising speed to the intended landing point and land the UA with 25% battery power remaining.

25. The operator must obtain an Air Traffic Organization (ATO) issued Certificate of Waiver or Authorization (COA) prior to conducting any operations under the g rant of exemption. This COA will also require the operator to request a Notice to Airman (NOTAM) not more than 72 hours in advance, but not less than 48 hours prior to the operation. All operations shall be conducted in accordance with airspace requirement s in the ATO issued COA including class of airspace, altitude 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 accordance with 14 C.F.R. part 45, Subpart C. Markings must be as large as practicable.

27.Before conducting operations, the radio frequency spectrum used for operation and control of the UA must comply with th e 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 available to the Administrator or any law enforcement official upon request.

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

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

31.Flight operations must be conducted at least 500 feet from all nonparticipating 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 ve ssels, vehicles or structures has granted permission and the PIC has made a safety assessment of the risk of operating closer to those objects and determined that it does not present an undue hazard, and; c. Operations nearer to the PIC, SO, operator train ees or essential persons do not present an undue hazard to those persons per § 91.119(a).32.All operations shall be conducted over private or controlled

- access property with permission from

the land owner/controller or authorized representative. Permissi on 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 appl icable 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 Requirements Of Section 61.113(a) And (b) Would Not Adversely Affect Safety.

Jeffrey Brock submits that the equivalent level o f safety established by Section 61.113(a) and (b) will be maintained
because no P IC will be allowed to operate the DJI Inspire 1 or Phantom 2 UAS unless that PIC has d emonstrated, by meeting minimum flight

- hour and currency requirements, that the PIC is able to safely operate the DJI Inspire 1 and
Phantom 2 UAS in a manner consistent w ith the e xemption, including evasive and emergency maneuvers and maintaining appropriate distances from people, vessels, vehicles and structures.

Considering Jeffrey Brock proposed area of operations, and the operating limitations set forth

- above; the para llel nature of spo rt pilot aeronautical knowledge requirements to those of commercial pilot requirements (See Exemption No. 11062); and the airmanship skills necessary to safely operate the DJI Inspire 1 and Phantom 2 UAS, Jeffrey Brock submits
that the ad ditional ma nned airmanship experience of a commercially certificated pilot would not correlate to the airmanship skills necessary for Jeffrey Brock specific proposed flight operations.

The FAA has previously granted relief from Sectio n 61.113(a) and (b) sp ecific to UAS, in circumstances similar, in all material respects, to those presented herein (e.g. Exemption Nos. 11062, 11063, 11064, 11065, 11066, 110 67, 11080, 11109, 11110, 11112, 11136, 11138, 11150, 11153, 11156, 11158, 11159, 11160, 11161).

Jeffrey Brock will not allow any PIC t o operate the DJI Inspire 1 and Phantom 2 UAS unless that PIC has demonstrated, by meeting minimum flight

- hour requirements or the DJI Inspire 1 and Phantom 2 UAS trai ning and currency requirements,
that the PIC is able to saf ely operate the DJI Inspire 1 and Phantom 2 UAS in a manner consistent with this exemption, including evas ive and emergency maneuvers and maintaining appropriate distances from people, vessels, vehicles and

structures.

Specifically, the PIC must have accum ulated 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 exem ption). In add ition to the hour requirements, the PIC must accomplish 3 takeoffs and landings in the preceding 90 days (for currency purposes).

As in Exemption Nos. 11062, 11138, and 11153, pri or documented flight experience that was obtained in compliance with applic able regulations will ensure an equivalent level of safety during Jeffrey Brock 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 C FR 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 U AS 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 days (for currencypurposes). The FA A 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 compliance 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 experience

- 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, Jeffrey Brock will ensure safe operat ions by not all owing any PIC to operate the DJI Inspire 1 and Phantom 2
UAS unles s that PIC has demonstrated, by meeting minimum flight

- hour and currency requirements, that the PIC is able to safely operate the DJI Inspire 1 and Phantom 2 UAS in a manner consistent with the exemption, including evasive and emergency maneuvers and maintai ning 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, Jeffrey Brock will ensure that the DJI Inspire 1 and Phantom 2 UAS is in an airworthy condition based upon the UAS’s compliance with its operating d ocuments 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. 1 1062, 11063, 11064, 11065, 11066, 110 67, 11080, 11109, 11110, 11112, 11136, 11138, 11150, 11153, 11156, 1115 7, 11158, 11159, 11160, 11161).

4. Reasons Why An Exemption From The Requirements Of Section 91.121 Would Not Adversely Affect Safety.

The equivalent level of safety established by Section 91.121 will be maintained because the altitude information of the DJI Inspire 1 and Phanto m 2 UAS will be provided to the PIC via GPS equipment and a radio communicat ions telemetry data link, which downlinks from the UAS to the GCS for active monitoring of the flight path and altitude. This altitude information, combined with Jeffrey Brock ’s operation of the DJI Inspire 1 and Phantom 2 UAS within visual line of sight, at or below 500 feet AGL, will ensure a level of sa fety equivalent to Section 91.121. T he altitude information will be generated by GPS equipment installed onboard the aircraf t. Prior to each flight, a zero altitude initiation point is automatically established by the UASs at ground level.

The FAA has prev iously granted relief from Sec tion 91.121 specific to UAS, in circumstances similar, in all material respects, to those p resented herein (e.g. Exemption Nos. 11062, 11063, 11064, 11065, 11066, 11067, 110 80, 11109, 11112, 11136, 11138, 11150, 11153, 11156, 11157, 11158, 11159, 11160, 11161).

5. Reasons Why An Exemption From The Requirements Of Section 91.151(b) Would Not Adversely Affect Safety.

A grant of this exemption would ensure an equivalent level of safety established by 14 C.F.R. Section 91.151(b) as a result of (1) the technical specifications of the DJI Inspire 1 and Phantom 2 UAs; (2) the limitations on the prop osed flight operations; and (3) the location of the proposed flight operations. Accordingly, Jeffrey Brock will ensure that it will safely

o perate the battery powered DJI Ins pire 1 and Phantom 2 UAs during daylight hours in VFR conditions, with enough battery power to fly for a total duration of 15 minutes to the first point of intended landing and, ass uming normal cruising speed, to fly after that for at least 5 minutes.

Here, as in Exemption No. 11109, the technical spec ifications of the DJI Inspire 1 and Phantom 2 UAS; the limitations on the proposed flight operation s; and the location of the proposed operations, will ensure an equivalent level of safety established by 14 C.F.R. Section 91.151(b). Furthermore, safety will be ensured as the DJI Inspire 1 and Phantom 2 UAS provide audible and visual warnings to the PIC at the GCS when the UAs experiences low battery voltage, the firstwarning occurring at approximately 30% remaining battery power, and again at approximately 15% remaining battery power. At the critically low battery level, the DJI Inspire 1 and Phantom 2 UAS will descend and la nd automatically.

Significantly, previous exemptions granted by th e FAA concerning Section 91.151 establish that safety is not adversely
affected when th e technical characteristics and operating limitations of the UAS are considered. Rel ief has been grante d
for manned aircraft to operate at less than the minimums prescrib ed in Section 91.151, including Exemption Nos. 2689, 5745, and 10650. Moreover, the FA A has previously granted relief from Section 91.151 specific to UAS, in circumstances
simila r, in all m aterial respects, to those presented herein (e.g. Exemption Nos. 8811, 108 08, 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, Jeffrey Brock submi ts that the equivalent level of safety with regard to the regulatory
maintena nce and alte ration 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 Jeffrey Brock will use trained tech nicians to perform maintenance, alterations, or preventive maintenance on the UAS usi ng the methods, techniques, and practices prescribed in the operating documents (i.e. , the DJI Inspire 1 Maintenance Manual, Phantom 2 Maintenance Manual, Mon thly Maintenance Log,
Phantom 2 Instruction Manual, and DJI Inspire 1 Instruction Manua l). Furthermore, Jeffrey Brock will document and
maintain all maintenance re cords for the DJI Inspire 1 and Phantom 2 UAS.

Since the DJI Inspire 1 and Phantom 2 UAS will be inspected as prescribed by the operating documents, Jeffrey Brock will
maintain the eq uivalent level of safety established by Sections 91.405(a), 91.409(a)(1), and 91.409(a)(2). A copy of the

DJI Inspire 1 User Manuals are attached hereto as Exhibit B. 1; a copy of the Phantom 2 User Manual is attached hereto as Exhibit B.2, a copy of the DJ I Inspire 1 Maintenance Manual is attached hereto as Exhibit C; a copy of the DJI I nspire 1
UAS Maintenance LOG is attached hereto as Exhibit D.

Likewise, the exemption sought will not adversely affect safety because Jeffrey Brock will use trained technici ans to perform mainten ance, alterations or preventive maintenance on the UAS using the methods, techniques, and practices prescribed by the operating documents.

Furthermore, the exemption sought would maintai n an equivalent level of safety established by S ections 91.407, 91.417(a) and 91.417(b), because all maintenance of the DJI Inspire 1 and Phantom 2 UAS will be performed by t rained
technicians. Maintenance will be documented and maintained utilizing the monthly maintenance log.

Significantly, previous e xemptions granted by the FAA concerning Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b) establish that safety is not adversely affected when the technical characteristics a nd operating
limitations of the UAS are considered.

In consideration of Jeffrey Brock prop osed operating limitations, the operating documents, and the technical aspects of
the D JI Inspire 1 and Phantom 2 UAS, Jeffrey Brock 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 her ein (e.g. Exemption Nos. 11062, 11063, 1106 4, 11065, 11066, 11067, 11080, 11109, 111 10, 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 Moder nization and Reform Ac t of 2012 (FMRA) and 14 C.F.R. § 21.16 entitled Special Conditio ns, Jeffrey Brock requests that the FAA prescribe special conditions for the intended operation of the DJI Inspire 1 and Phantom 2 UAS, which contain such safety standar ds that the Administrat or finds necessary to establish a level of safety equivalent to that es tablished 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 specia l conditions will permitsafe 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. FMR A Section 333 sets forth the requirements for considering whe ther a U AS
will create a hazard to users of the NAS or the public, or otherwise pose a threat to national securit y; and further, provides the 32 authority for such UAS to operate without airworthiness c ertification 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 c onditions pursuant to 14 C.F.R. § 21.16, for operation of the DJI Inspire 1 and Phantom 2 UAS, since the airworthiness regulations of 14 C.F.R. Par t 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 subcha pter 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, aircraft engine or propeller as the FAA finds necessary to establish a level of safety equivalent to
that esta blished 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 intende d operation of the DJI Inspire 1and Phantom 2 UAS, which contain su ch safety

s tandards that the Administrator finds necessary to establish a level of safety equivalent to that established by
14 C.F.R.

Part 21,

Subpart H, and 14 C.F.R Sections 61.113(a) & (b), 91.7(a) , 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b).

F. A Summary That Can Be Published In The Federal Register, stating: The Rules From Which Jeffrey Brock Seeks Exemption:

Jeffrey Brock seeks exemption from the requirements of 14 C.F.R Sections 61.101(e)(4) and (5), 61.315(a), 61.23(a), 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 Jeff rey Brock Seeks:

This exemption will permit Jeffrey Brock 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 Jeffrey Brock’s Request.

This Petition is made pursuant to the FAA Modernization and Reform Act of 2012 (FMRA) Section 333, which directs the Secretary of Transportation to determine if certain UAS may operate safely in the NAS. As such, Jeffrey Brock request for exemption may be granted pursuant to the authority of FMRA Sectio n 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 use rs of the NAS or the public, or othe rwise pose a threat to national security; and further, provides the authority for such UAS t o operate without airworthiness certification.

As discussed in detail above, Jeffrey Brock will operate the D JI Inspire 1 and Ph antom 2 UASs safely in the NAS, without
creatin g a hazard to users of the NAS, or the public, or otherwise pose a threat to national security.

CONCLUSIONAs set forth herein, Jeffrey Brock seeks an e xemption pursuant to 14 C.F.R § 11.61 and Section 333 of the FAA
Moder nization and Reform Act of 2012 (FMRA), which will permit safe operation of the DJI Inspire 1 and Phantom 2 UAS commercially, without an airworthiness certificate, for th e 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
C ongressional mandate of the FAA Modernization and Reform Act of 2012, while also advanci ng the interests of the public, by allowing Jeffrey Brock to safel y, efficiently, and economically operate the DJI Inspire 1 and Phantom 2 UAS 34 commercially within the NAS.

WHEREFORE , in accordance with the Feder al Aviation Regulations and the FAA Modernization and Reform Act of 2012,
Secti on 333, Jeffrey Brock respect fully requests that the Administrator grant this Pet ition for an exemption from the requirements of 14 C.F.R Sections 61.101(e)(4) and (5), 61.315 (a), 61.23(a), 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 Jeffrey Brock to operate the DJI Inspire 1 and
Pha ntom 2 UAS commercially for the purpose of conducting aerial video and photography over areas of the United
States.

Dated: 20 October , 2015

Respectfully submitted,

Jeffrey Brock
206 Oconee Dr
C ohutta, Ga 30710
706

- 264

- 1568
email

– jeff@webmizer.com

Exhibits:

Exhibits:

A

– DJI Inspire 1 and Phantom 2 Specifications Data Sheet
B.1

– DJI Inspire 1 Manufacturer’s User Manual B.2

– DJI Phantom 2 Manufacturer’s User Manual
C

– DJI Inspire 1 Maintenance Manual

D

– Monthly Maintenance Log

# EXHIBIT

– A

DJI Inspire 1 and Phantom 2 Specifications Data Sheet

DJI INSPIRE 1 TECHNICAL SPECIFICATIONS

Aircraft Model
T600 Weight (Battery Included) 2935 g Hovering Accuracy (GPS Mode) Vertical: 0.5 m Horizontal: 2.5 m Max Angular Velocity Pitch: 300°/s Yaw: 150°/s Max Tilt Angle35° Max Ascent Speed 5 m/s Max Descent Speed 4 m/s Max Speed 22 m/s (ATTI mode, no wind) Max Flight Altitude
4500 m Max Wind Speed Resistance 10 m/s Max Flight Time Approximately 18 minutes Motor Model
DJI 3510 Propeller Model
DJI 1345 Indoor Hovering Enabled by default Operating Temperature Range

- 10° to 40° C Diagonal Distance
559 to 581 mm Dimensions
438x451x301 mm

Gimbal Model
ZENMUSE X3 Output Power (With Camera)
Static: 9 W
In Motion: 11 W Operating Current Station:
750 mA Motion: 900 mA Angular Vibration Range ±0.03° Mounting Detachable Controllable Range Pitch:

- 90° to +30°
Pan: ±32 0° Mechanical Range Pitch:

- 125° to +45° Pan: ±330° Max Controllable Speed Pitch: 120°/s Pan: 180°/s

Camera Name
X3 Model
FC350 Total Pixels
12.76M Effective Pixels12.4M Image Max Size
4000x3000 ISO Range
100

- 3200 (video)
100

- 1600 (photo) Electronic Shutter Speed

8s

- 1/8000s FOV (Field Of View)
94°
CMOS Sony EXMOR 1/2.3”
Lens 20mm (35mm format equivalent)f/2.8 focus at ∞ 9 Elements in 9 groups
Anti

- distortion Still Photography Modes Single shoot Burst shooting : 3/5/7 frames Auto Exposure Bracketing (AEB): 3/5 bracketed frames at
0.7EV Bias
Time

- lapse Video Recording Modes UHD (4K): 4096x2160p24/25, 3840x2160p24/25/30 FHD: 1920x1080p24/25/30/48/50/60 HD: 1280x720p24/25/30/48/50/60 Max Bitrate Of Video Stora ge 60 Mbps Supported File Formats FAT32/exFAT Photo: JPEG, DNG Video: MP4/MOV (MPEG

- 4 AVC/H.264) Supported SD Card Types Micro SD Max capacity: 64 GB. Class 10 or UHS

- 1 rating required. Operating Temperature Range 0° to 40° C

Remote Controller Name
C1 Operating Frequency 922.7~927.7 MHz (Japan Only) 5.725~5.825 GHz
2.400~2.483 GHz Transmitting Distance (Outdoor And Unobstructed) 2 km
EIRP 10dBm@900m, 13dBm@5.8G, 20dBm@2.4G Video Output Port USB,
mini

- HDMI Power Supply Built

- in batteryCharging DJI charger Dual User Capability
Host

- and

- Slave connection Mobile Device Holder Tablet or Phone Max Mobile Device Width
170mm Output Power
9 W Operating Temperature Range

- 10° to 40° C Storage Temperature Range
Less than 3 months:

- 20° to 45° C More than 3 months: 22° to 28° C Charging Temperature Range
0

- 40° C Battery 6000 mAh LiPo 2S

Charger Model
A14

- 100P1A Voltage
26.3 V Rated Power
100 W

Battery (Standard) Name Intelligent Flight Battery Model
TB47 Capacity 4500 mAh Voltage
22.2 V Battery Type LiPo 6S High voltage battery Energy 99.9 Wh Net Weight 570 g Operating Temperature Range

- 10° to 40° C Storage Temperature Range Less than 3 months:

- 20° to 45° C More than 3 months: 22° C to 28° C Charging Temperature Range 0° to 40° C Max Charging Power
180 WVision Positioning Velocity Range Below 8 m/s (2 m above ground) Altitude Range
5

- 500 cm Operating Environment Brightly lit (lux > 15) patterned surfaces Operating Range 0

- 250 cm

Phantom 2 specifications:

Aircraft Weight (Battery & Propellers Included) 1000g Hover Accuracy (Ready To Fly) Vertical: 0.8m; Horizontal: 2.5m Max Yaw Angular Velocity 200°/s Max Tilt Angle 35° Max Ascent / Descent Speed Ascent: 6m/s; Descent: 2m/s Max Flight Speed 15m/s Diagonal Length 350mm Flight Time 25 mins Take

- Off Weight ≤1300g Operating Temperature

- 10°C ~ 50°C Supported Battery: DJI Smart Battery Type: 3S LiPo Capacity: 5200mAh, 11.1V Charging Environment Range: 0 °C to
40 °C Discharging Environment Range:

- 20 °C to 50 °C 2.4GHz Remote Control Operating Freq uency:2.4GHz ISM Communication Distance (Open Area) 1000m Receiver Sensitivity (1%PER)

- 97dBm Working Current/Voltage 120 mA@3.7V Built

- In LiPo Battery Working Current/Capacity 3.7V, 2000mAh

Exhibits: A

– DJI Inspire 1 and Phantom 2 Specifications Data She et B.1

– DJI Inspire 1 Manufacturer’s User Manual B.2

– DJI Phantom 2 Manufacturer’s User Manual C

– DJI Inspire 1 Maintenance Manual D

– Monthly Maintenance Log

EXHIBIT

– B.1

DJI Inspire 1 Manufacturer’s User Manual

Exhibits: A

– DJI Inspire 1 and Phan tom 2 Specifications Data Sheet B.1

– DJI Inspire 1 Manufacturer’s User Manual B.2

– DJI Phantom 2 Manufacturer’s User Manual C

– DJI Inspire 1 Maintenance Manual D

– Monthly Maintenance Log

Exhibit

– C

DJI Inspire 1 Maintenance Manual

Exhibits: A

– DJI Inspire 1 and Phantom 2 Specifications Data Sheet B.1

– DJI Inspire 1 Manufacturer’s User Manual B.2

– DJI Phantom 2 Manufacturer’s User Manual C

– DJI Inspire 1 Maintenance Manual D

– Monthly Maintenance Log

# EXHIBIT

– D

Monthly Maintenance Log

Month ___________

Year _____________

UAS # Issue Discovered Date Repaired Description & Maint Performed By Software Update Airframe Engines Propellers Camera Gimble Landing Gear Other

Jeffrey Brock
206 Oconee Dr Cohutta, Ga 30710
706

- 264

- 1568 jeff@webmizer.com