UNITED STATES OF AMERICA DEPARTMENT OF TRANSPORTATION FEDERAL AVIATION ADMINISTRATION

WASHINGTON, DC

Regulatory Docket No. _______________

IN THE MATTER OF THE PETITION FOR EXEMPTION OF: NATHAN EDMONDS dba PRECISION AERIAL IMAGERY FOR AN EXEMPTION SE EKING RELIEF FROM THE REQUIREMENTS OF

TITLE 14 OF THE CODE OF FEDERAL REGULATIONS SECTIONS 61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), AND 91.417(a) & (b) CONCERNING COMMERCIAL OPERATION OF DJI PHANTOM 3 UNM ANNED AIRCRAFT SYSTEMS

PURSUANT TO SECTION 333 OF THE FAA MODERNIZATION AND REFORM ACT OF 2012

(PUBLIC LAW 112

- 95)

Submitted on September 29 , 2015 Nathan Edmonds dba Precision Aerial imagery 12017 Lavenia Ln Louisville, KY 40272 Tel: (502) 396

- 1950

TABLE OF CONTENTS Page GLOSSARY OF ABBREVIATIONS...................................................................................3
SUMMARY................................................................................................................. ..........4
INTRODUCTION AND INTERESTS OF PETITIONER...................................................4
BACKGROUND................................................................................................................... 52

BASIS FOR PETITION... .....................................................................................................5
NAME AND ADDRESS OF PETITIONER............................................................8 THE SPECIFIC SECTIONS OF 14 C.F.R. FROM WHICH PRECISION AERI AL IMAGERY SEEKS EXEMPTION.......................................................................8 THE EXTENT OF RELIEF PRECISION AERIAL IMAGERY SEEKSAND THE REASON PRECISION AERIAL IMAGERY SEEKSTHE RELIEF.............................12 THE REASONS WHY GRA NTING PRECISION AERIAL IMAGERY REQUEST WOULD BE IN THE PUBLIC INTEREST ............................................... .........15 THE REASONS WHY GRANTING THE EXEMPTION WOULD NOT ADVERSELY AFFECT SAFETY........................................................ ..................18 SUMMARY THAT CAN BE PUBLISHED IN THE FEDERAL REGISTER......32 ANY ADDITIONAL INFORMATION, VIEWS, OR ARGUMENTS AVAILABLE TO SUPPORT PRECISION AERIAL IMAGERY REQUEST ...............33 CONCLUSION........................................... .........................................................................33 APPENDICES................................................................................................................... ..35

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 Link3

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 Obser ver SOP Standard Operating Procedures UA Unmanned Aircraft UAS Unmanned Aircraft System VFR Visual Flight Rules VLOS Visual Line of Site VMC Visual Meteorological Conditions VTOL Vertical Takeoff and Landing

SUMMARY Nathan Edmond s dba Precision Aerial imagery, 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 Sectio n 333 of the FAA Modernization and Reform Act of 2012 (FMRA). This exemption will permit Nathan Edmonds to operate an Unmanned Aircraft System (UAS) for the commercial purpose of conducting aerial video and photography of construction sites, real estate, s pecial events, film sets, and landscape over certain areas of
the United States.4 INTRODUCTION AND INTERESTS OF THE PETITIONER
Precision Aerial Imagery provides its clients with expertise and knowledge in advanced technologies and solutions to increase efficiency, productivity and effectiveness.
Precision Aerial Imagery also provides its clients with the highest quality digital content for use in their commercial, personal, and non

- profit multimedia projects. Precision Aerial Imagery has over 13 years of professional experience in photography and videotaping. I have provided services to CNW Productions of models, Photography of action sports, commercial and residential photography and videography. I have over 3 years recreational/hobby experience in all aspects of aerial video and photography. The objective
of Precision Aerial Imagery aerial video and photography operations is to provide high quality imaging for a variety of commercial, public, and residential uses, targeting: Aerial inspections of publ ic and private structures. Search and Rescue operations Aerial photography/videography of houses / residential and commercial buildings Aerial event photography/videography Aerial event filming Aerial Appraisals Real Estate Marketing Insurance Inspections of Home and Property Commercial Advertising Video and Photography Real Estate Photography and Videography FREE services offered to our community, firefighter and state officials Nature Monitoring

BACKGROUND

Unmanned Aircraft Systems: DJI Phantom 3 UAS Precision Aerial Imagery Seeks an exemption to operate DJI systems for compensation or hire within the NAS. The DJI Phantom 3 is a vertical takeoff and landing (VTOL) Unmanned Aircraft (UA) with a Ground Control Station (GCS) utilizing electronic tablet5

or smart phone systems. The DJI Phantom 3 has a maximum gross weight of 2 pounds 13.1 ounces, a length of 16.2 inches, width of 16.6 inches, height of 10.5 inches, and a maximum speed of approximately 31.1 knots. The DJI Phantom 3 UA is equipped with four mai n rotors; Driven by Lithium Polymer battery powered electric motors. The DJI Phantom 3 UA that will be operated by Precision Aerial Imagery and will be registered in accordance with 49 U.S.C. 44103, Registration of Aircraft , as well as 14 C.F.R Part 47, A ircraft Registration , and marked in accordance with 14 C.F.R. Part 45, Identification and Registration Marking

. BASIS FOR PETITION Petitioner, Precision Aerial Imagery , 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 commercially operate the DJI Phantom 3 UAS in the National Airspace System (NAS), and for an exemp tion 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, Precision Aerial Imagery operation of DJI

Phantom 3 UAS meets the conditions of FMRA Section 333 and therefore, will not require an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H. Accordingly, Preci sion Aerial Imagery requests relief from Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b), as these sections set forth requirements for maintenance that only apply to aircraft with an airworthiness certificate.
Precision Aerial Imagery submits that the requested relief is proper since an equivalent level of safety will be ensured. Precision Aerial Imagery will use experienced personnel or technicians to perform maintenance, alterations, or preventive maintenance on
the UAS usi ng the methods, techniques, and practices prescribed in the operating6

documents (i.e., Monthly Maintenance Log, and DJI Phantom 3 Instruction Manual) ). Furthermore, Precision Aerial Imagery will document and maintain all maintenance
records for the DJI Ph antom 3 UAS

. Relief from certain requirements of Section 61.113(a) and (b), entitled Private pilot privileges and limitations: Pilot in command , is requested by Precision Aerial Imagery to the extent necessary to allow a Pilot in Command (PIC) holding a p rivate pilot or higher level certificate, as well as an airman medical certificate, and who has demonstrated, by meeting minimum flight

- hour and currency requirements, that the PIC is able to safely operate the DJI Phantom 3 UAS in a manner consistent wit h this exemption, including evasive and emergency maneuvers and maintaining appropriate distances from people, vessels, vehicles and structures. Precision Aerial Imagery Seeks relief from Section 91.7(a), entitled Civil aircraft
airworthiness , because the D JI Phantom 3 UAS do not require an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H. As such, Precision Aerial Imagery submits
that he will ensure that the DJI Phantom 3 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 3 Instruction Manual), and that the aircraft are in a condition for safe flight.
Precision Aerial Imagery also seeks an exemption fro m the requirements of Section 91.121, entitled Altimeter Settings , as the DJI Phantom 3 UAS will not have a typical barometric altimeter onboard. However, altitude information of the DJI Phantom 3 UAS will be provided to the PIC via Global Positioning Syst em (GPS) equipment and radio communications telemetry data link, which downlinks from the UA to the GCS for active monitoring of the flight path. This altitude information, combined with Precision Aerial7

Image ry operation of DJI Phantom 3 UAS within visua l line of sight, at or below 400 feet AGL, will ensure a level of safety equivalent to Section 91.121. Additionally, Precision Aerial Imagery Seeksan exemption from the requirements of Section 91.151(b), entitled Fuel requirements for flight in VFR conditi ons . Precision
Aerial Imagery submits that safety will not be affected by operation of the DJI Phantom 3 UAS during daylight hours in visual meteorological conditions (VMC) under visual flight rules (VFR), with enough battery power to fly for a total dura tion of approximately 13.5 minutes to the first point of intended landing and, assuming normal cruising speed, to fly
after that for at least 4.5 minutes. In accordance with 14 C.F.R. § 11.81, Precision Aerial Imagery 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:
Nathan Joel Edmonds Precision Aerial Imagery 12017 Lavenia Ln Louisville, Kky 40272 Tel: (502) 396

- 1950 Emai l: ejoedmonds1@gmail.com B. The Specific Sections Of 14 C.F.R. From Which Precision Aerial Imagery Seeks Exemption. 1. Precision Aerial Imagery Seeks Exemption From The Requirements Of Section 61.113(a) And (b). Section 61.113, entitled Private pilot privi leges and limitations: Pilot in command , subsections (a) and (b) prescribe the following, in relevant part:8 (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 c ompensation 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 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.
2. Precision Aerial Imagery 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.
3. Precision Aerial Imagery Seeks Exemption From The Requirements Of Section 91.121. Section 91.121, entitled Altimeter settings , subs ection (a), states the following, in
part: (a) Each person operating an aircraft shall maintain the cruising altitude or flight level of that aircraft, as the case may be, by reference to an altimeter that is set, when operating

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

-- (i) The current reported altimeter setting of a station along the route and within 100 nautical miles of the aircraft; (ii) If there is no station within the area prescribed in paragraph (a) (1) (i) of this section, the current reported altimeter se tting of an appropriate available station; or (iii) In the case of an aircraft not equipped with a radio, the elevation of the departure airport or an appropriate altimeter setting available before departure. 4. Precision Aerial Imagery Seeks Exemption Fro m 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 fo recast weather conditions) there is enough fuel to fly to9 the first point of intended landing and, assuming normal cruising speed, to fly after that for at least 20 minutes. 5. Precision Aerial Imagery Seeks Exemption From The Requirement Of Section 91.405 (a). Section 91.405, entitled Maintenance required , subsection (a), states the following: Each owner or operator of an aircraft

— (a) Shall have that aircraft inspected as prescribed in subpart E of this part and shall between required inspections, except a s provided in paragraph (c) of this section, have discrepancies repaired as prescribed in part 43 of this chapter[.] 6. Precision Aerial Imagery Seeks Exemption From The Requirements Of Section 91.407(a) (1) Section 91.407, entitled Operation after mainten ance, preventive maintenance, rebuilding, or alteration , subsection (a) (1), states the following: (a) No person may operate any aircraft that has undergone maintenance, preventive maintenance, rebuilding, or alteration unless

-- (1) It has been approved fo r return to service by a person authorized under § 43.7 of this chapter [.] 7. Precision Aerial Imagery 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 foll owing: (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. Precision Aerial Imagery Seeks Exemption From The Requirements Of Secti ons 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 recor ds 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 approved10 inspections, as appropriate, for each air craft (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 th e work performed; and (iii) The signature, and certificate number of the person approving the aircraft for return to service. (2) Records containing the following information: (i) The total time in service of the airframe, each engine, each propeller, and each rotor. (ii) The current status of life

- limited parts of each airframe, engine, propeller, rotor, and appliance. (iii) The time since last overhaul of all items installed on the aircraft which are required to be overhauled on a specified time basis. (i v) The current inspection status of the aircraft, including the time since the last inspection required by the inspection program under which the aircraft and its appliances are maintained. (v) The current status of applicable airworthiness directives (AD) and 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 shall be retained and transfer red with the aircraft at the time the aircraft is sold. (3) A list of defects furnished to a registered owner or operator under § 43.11 of this chapter shall be retained until the defects are repaired and the aircraft is approved for return to service. C. The Extent Of Relief Precision Aerial Imagery Seeks And The Reason Precision Aerial Imagery Seeks The Relief. 1. Extent Of Relief Precision Aerial Imagery Seeks And The Reason Precision Aerial Imagery Seeks Relief From Section 61.113(a) And (b).11 Relief from Se ction 61.113(a) and (b) entitled Private pilot privileges and

limitations: Pilot in command , is requested to the extent necessary to allow a PIC holding a private pilot or higher level certificate, as well as a current and valid airman medical certificate, and who has met certain flight

- hour and currency requirements, to conduct the proposed UAS 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, fo r 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 se t forth more fully below, Precision Aerial Imagery submits that an equivalent level of safety will be maintained because no PIC will be allowed to operate the DJI

Phantom 3 UAS unless that PIC has met certain flight

- hour and currency requirements,
demons trating that the PIC is able to safely operate either the DJI Phantom 3 UAS in a manner consistent with the operations specifications as described in this exemption, including evasive and emergency maneuvers, as well as maintaining appropriate distances

fr om people, vessels, vehicles and structures.

Fur ther, Precision Aerial Imagery submits that all flights of the DJI Phantom 3 UAS, conducted by the PIC pursuant to the grant of this Petition: (1) will be incident al to Precision Aerial Imagery business; an d (2) will not carry passengers or property for compensation or hire. 2. Extent Of Relief Precision Aerial Imagery Seeks And The Reason Precision Aerial Imagery Seeks Relief From Section 91.7(a).12 Relief from Section 91.7(a) entitled Civil aircraft airworthi ness , is requested to the

extent required to allow Precision Aerial Imagery to determine that the DJI Phantom 3 UAS are in airworthy condition prior to every flight by ensuring that the UAS is in compliance with the operating documents (i.e., the Precisio n Aerial Ima gery Aerial Operations Manual, Monthly Maintenance Log, and DJI Phantom 3 Instruction Manual). Precision Aerial Imagery seeks the requested relief because the DJI Phantom 3 UAS do not require an airworthiness certificate in accordance with 14 C .F.R. Part 21, Subpart H. Therefore, Precision Aerial Imagery will ensure that the DJI Phantom 3 UAS are in airworthy condition based upon its compliance with the operating documents (i.e., Monthly Maintenance Log, and DJI Phantom 3 Instruction Manual) pr ior 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 Precision Aerial Imagery Seeks And The Reason Precision Aerial Imagery Seeks Relief From Se ction 91.121. Relief from Section 91.121, entitled Altimeter settings , may be required to allow flight operations of the DJI Phantom 3 UAS, which utilize a barometric pressure sensor, GPS equipment, and a radio communications telemetry data link to downli nk 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), Precision Aerial I magery s eeks the requested relief because the DJI Phantom 3 UA’s altimeter may be set on the ground to zero feet AGL, rather than the local barometric pressure or field altitude, before each flight. Considering the limited altitude of the proposed operation s, 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 be13

maintained since the DJI Phantom 3 UA are equipped w ith 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. E xtent Of Relief Precision Aerial Imagery Seeks And The Reason Precision Aerial Imagery Seeks Relief From Section 91.151(b). Relief from Section 91.151(b) entitled Fuel requirements for flight in VFR
conditions , is requested to the extent required to allow f lights of the battery powered DJI
Phantom 3 UA during daylight hours in visual meteorological conditions (VMC), under visual flight rules (VFR), for a total duration of 13.5 minutes to the first point of intended landing and, assuming normal cruising speed , to fly after that for at least 4.5 minutes. Precision Aerial Imagery s eeks the requested relief because without an exemption from Section 91.151(b), the flight time duration of the battery powered DJI Phantom 3 UAs will severely constrain the practicality of any aerial video or still photo flight operations that Precision Aerial Imagery proposes to conduct pursuant to this Petition. Significantly, as set forth below, the technical specifications of the DJI Phantom 3 UAS, the DJI Phantom 3 operating docume nts, and Precision Aerial Imagery proposed operating limitations, ensure that Precision Aerial Imagery will safely operate the battery powered DJI Phantom 3 UA during daylight hours in visual meteorological conditions (VMC), under visual flight rules (VF R), with enough battery power to fly for a total duration of 13.5 minutes to the first point of intended landing and, assuming normal cruising speed, to fly after that for at least 4.5 minutes. 5. Extent Of Relief Precision Aerial Imagery Seeks And The Reas on Precision Aerial Imagery Seeks Relief From Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), And 91.417(a) & (b).14 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 cert ificate, Precision Aerial Imagery requests relief from these Sections because the DJI Phantom 3 UAS do not require airworthiness certificates. As set forth more fully below, the DJI Phantom 3 UAS meet the conditions of FMRA Section 333 for operation witho ut an airworthiness certificate. Accordingly,
Precision Aerial Imagery will use trained technicians to perform maintenance, alterations, or preventive maintenance on the UAS using the methods, techniques, and practices prescribed in the UAS operating docu ments (i.e., the Precision Aerial Imagery Aerial Operations Manual, Monthly Maintenance Log, and DJI Phantom 3 Instruction Manual). Furthermore, Sky Vision, LLC will document and maintain all maintenance records for the
DJI Phantom 3 UAS.

D. The Reasons W hy Granting Precision Aerial Imagery 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 Precision
Aerial Imagery to safely, efficiently , and economically perform aerial video and photography of construction sites, real estate, special events, film sets, and landscape over
certain areas of the United States. Additionally, use of the DJI Phantom 3 UAS will decrease congestion of the NAS,

re duce pollution, and provide significant benefits to the economy. Notably, the benefits of
Precision Aerial Imagery proposed operation of the DJI Phantom 3 UAS will be realized without implicating any privacy issues.
1. The Public Will Benefit From Decreas ed Congestion Of The NAS.
The DJI Phantom 3 UAs are battery powered and serve as a safe, efficient, and economical alternative to the manned aircraft traditionally utilized to obtain aerial imagery. By reducing the amount of manned aircraft needed to perfo rm aerial acquisitions, an15

exemption allowing the use of a DJI Phantom 3 UAS would reduce the amount of manned aircraft in the NAS, reduce noise and air pollution, as well as increase the safety of life and property in the air and on the ground.
Furthermor e, 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 3 UA do not require an airport to takeoff or land. Likewise, a reduction of
manned airc raft 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 Sa fety And Efficiency Of The DJI Phantom 3 UAS. Conducting aerial acquisitions with the DJI Phantom 3 UASs, instead of manned aircraft, will greatly benefit the public by drastically reducing the levels of air and noise pollution generated during traditiona l aerial video and still photography flight operations. By using battery power and electric motors, the DJI Phantom 3 UAS produce no air pollution, and is the most viable environmentally conscious alternative to the cabin class, six cylinder internal combu stion 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 3 UA, while reducing the carbon footprint of aerial acquisitions,
also eliminate s noise pollution, as the UA are propelled by battery powered electric motors, rather than an internal combustion engine. By using the DJI Phantom 3 UAS to perform aerial acquisitions, the substantial risk to life and property in the air and on the ground, which is usually associated with traditional manned aircraft flight operations, will be substantially reduced or completely16

eliminated. Aside from the lack of flight crew members located onboard the aircraft, the
DJI Phantom 3 UA (weighing approximately 2 pounds 13.1 ounces respectively, at its maximum gross weight with a length of 16.2 inches and width of 16.6 inches, 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 DJI Phantom 3 UAS Will Benefit The Economy. In addition to being safe and efficient, the DJI Phantom 3 UAS are also an economical alternative to using manned aircraft to conduct similar aerial operations. As such, operation of the DJI Phantom 3 UAS w ill allow United States based companies, like
Precision Aerial Imagery, 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 acti ons 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 3 UAS is one such technology that not only allows companies greater operational flexibility compared to manned aircraft, but provides such flexibility without the high operational cost of a
traditional manned aircraft. By operating the DJI Phantom 3 UAS, companies such as Precision Aerial Imagery, 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 3 UAS, pr ovides a stable workforce that increases consumer spending;17

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 Pri vacy Issues. Similar to the manned aerial acquisition flight operations that have been conducted for decades, Precision Aerial Imagery proposed operation of the DJI Phantom 3 UAS will not implicate any privacy issues. Specifically, the DJI Phantom 3 UAS w ill be operated only in compliance with operating documents (i.e., the Precision Aerial Imagery Aerial Operations Manual, Monthly Maintenance Log, and DJI Phantom 3 Instruction Manual) which requires property owner involvement as well as local law enforce ment notification, and in accordance with the Federal Aviation Regulations, including the minimum altitude requirements of 14 C.F.R. § 91.119. E. The Reasons Why Granting The Exemption Would Not Adversely Affect Safety, Or How The Exemption Would Provide A Level Of Safety At Least Equal To That Provided By The Rule From Which Precision Aerial Imagery Seeks Exemption
. 1. Reasons Why The DJI Phantom 3 UA Meet The Conditions Of The FAA Modernization and Reform Act of 2012 (FMRA) Section 333.
In consideration of the size, weight, speed, and limited operating area associated with the unmanned aircraft and its operation, Precision Aerial Imagery operation of the
DJI Phantom 3 UAS meet the conditions of FMRA Section 333, and will not require an
airworthiness cer tificate 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 publ ic, 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 of18 Transportation shall determine if certain unmanned aircraft systems may operate safely in the national airspace system before completion of the plan and rulemaking required by section 332 of this Act or the guidance required by section 33 4 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, ope rational capability, proximity to airports and populated areas, and operation within visual line of sight do not create a hazard to users of the national airspace system or the public or pose a threat to national security; and (2) whether a certificate o f waiver, certificate of authorization, 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 syst em. In seeking this exemption, Precision Aerial Imagery submits that the DJI Phantom
3 UAS can operate safely in the NAS pursuant to FMRA Section 333, as demonstrated by: (a) the characteristics of the DJI Phantom 3 UAS; (b) the pilot certification requi rement; and (c) the specific operating limitations.

a. The Specifications Of The DJI Phantom 3 UAS Demonstrate Its Safe Characteristics. The DJI Phantom 3 UAS do not create a hazard to users of the NAS or the public, or otherwise pose a threat to national security considering its size, weight, speed, and operational capability.

i. Technical Specifications Of The DJI Phantom 3 UAS. The technical specifications of the DJI Phantom 3 UAS are set forth by the DJI Phantom 3 Specifications and Data Sheet, attach ed hereto as Exhibit A.

ii. The DJI Phantom 3 UAS Autonomous Flight And Navigation Modes Enable The UAS To Remain Within A Defined Operational Area.19

The DJI Phantom 3 UAS may be operated in both manual and fully autonomous flight modes. A complete descrip tion of the flight and navigational modes of the DJI Phantom 3 UAS is provided in the Manufacturer’s User Manual *See attached PDF File
iii. The DJI Phantom 3 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 3 UA will remain stationary, in flight, for 3 seconds or more. If, after 3 seconds, the DJI Phantom 3 UA do not reacquire control link data from the GCS, the UAs will assume that the Cont rol Link is lost and the UAs will return to the home position (i.e., failsafe mode) via GPS, and will descend to the takeoff position and shutdown. A complete description of the Failsafe Functions of the DJI Phantom 3 UAS is provided in the Manufacturer’s User Manual *See attached PDF

iv. The DJI Phantom 3 GCS And Its Operation. A complete description of the operation and specifications of the DJI Phantom 3 GCS and flight control software is provided in the Manufacturer’s User Manual *See

attached PDF

b. Flight Operations Of DJI Phantom 3 UAS Are Limited To The Line Of Sight Of A Certificated Pilot in Command With A Safety Observer.
Precision Aerial Imagery will only utilize certificated pilots who possess a current
and valid airman medical certificate t o act as a pilot in command (PIC) of the DJI Phantom 3 UAS. Additionally, a safety observer will assist all pilots during flight time.

c. Flights Of DJI Phantom 3 UAS Will Be Conducted Pursuant To Specific Operating Limitations. In seeking this exemption, Precision Aerial Imagery proposes to commercially operate DJI Phantom 3 UAS for the special purpose of conducting aerial video and photography over certain areas of United States, pursuant to the following specific operating limitations:20 1. Operations au thorized 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 3 Unmanned Aircraft Systems. Proposed operations of any other aircraft will require a new petition or a petition to amend this grant. 2. UAS operations under this exemption will be limited to conducting operations for the purpose of aerial video and photography. 3. The UAs may not be flown at an indicated airspeed exceeding 20 knots. 4. The UA must be operated at an altitude of no more than 500 feet above ground level (AGL), as indicated by the procedures specified in the operating documents unless a special request is made and approved by ATC. All altitudes repo rted 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 requirement as long as the PIC al ways 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 transfer his or her designa tion 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 Administrator 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 precedence and must be followed. Otherwise, the operator must follow the procedures as outlined in its operating documents. The operator may update or revise its operating documents. It is the operator’s responsibility to track such revisions and present updated and revised documents to t he Administrator upon request. The operator must also present updated and revised documents if it petitions for extension or amendment to the grant of exemption. If the operator determines that any update or revision would affect the basis upon which the F AA granted the exemption, then the operator must petition for amendment to its grant of21 exemption. The FAA’s UAS Integration Office (AFS

- 80) may be contacted if questions arise regarding updates or revisions to the operating documents.
10. Prior to each f

light 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 necessary maintenance has been per formed and the UAS is found to be in a condition for safe flight. The Ground Control Station must be included in the preflight inspection. All maintenance and alterations must be properly documented in the aircraft records. 11. Any UAS that has undergone maintenance or alterations that affect the UAS 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 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 manufactur er’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 documents. Maintenance, i nspection, 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.
1 5. Each UASs operated under this exemption must comply with all manufacturer Safety Bulletins. 16. The authorized person must make an entry in the aircraft record of the corrective action taken against discrepancies discovered between inspections.
17. Th e 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 demonstrates the ability to safely operate the UAS in a manner consistent with how the UAS will be operated under the exemption, including evasive and emergency maneuvers and maintaining appropriate distances from persons, vessels, vehicles and structures. PIC qualification flight ho urs must be logged in a manner consistent with 14 C.F.R. § 61.51(b). Flights for the purposes of training the operator’s PICs are permitted under the terms of the exemption. However, training operations may only be conducted during dedicated training sessi ons. During training, proficiency, and experience

- building flights, all persons not essential for flight operations are22 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. § 1.1. All operations must be conducted under visual meteorological conditions (VMC). If flight at night is required, a special request will be made at the FAA office closest to proposed area of operations. Flights under special visual flight rules (SVFR) are not authorized. 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 up on 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 emergencies in accordance with the operating d ocuments. 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 the UA with 25% battery power remaining.
25 . The operator must obtain an Air Traffic Organization (ATO) issued Certificate of Waiver or Authorization (COA) prior to conducting any operations under the grant of exemption. This COA will also require the operator to request a Notice to Airman (NOTAM) not more than 72 hours in advance, but not less than 48 hours prior to the operation. All operations shall be conducted in accordance with airspace requirements in the ATO issued COA including class of airspace, altitude level and potential transponder req uirements. 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. Marki ngs 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 requ irements.23 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 enforceme nt 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 nonparticipat ing 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 th e UA, flight operations must cease immediately and/or; b. The aircraft is operated near vessels, vehicles or structures where the owner/controller of such vessels, vehicles or structures has granted permission and the PIC has made a safety assessment of t he 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 undue hazard to those persons per § 91.119(a).
32. Al l 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 b e 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 UAS Integration Office (AFS

- 80) within 24 hours. Acci dents 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) Wo uld Not Adversely Affect Safety. Precision Aerial Imagery 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 3 UAS unless that PIC has demonst rated, by meeting minimum flight

- hour24

and currency requirements, that the PIC is able to safely operate the DJI Phantom 3 UAS in a manner consistent with the exemption, including evasive and emergency maneuvers and maintaining appropriate distances from pe ople, vessels, vehicles and structures. Considering Precision Aerial Imagery proposed area of operations, and the operating limitations set forth

- above; the parallel nature of private pilot aeronautical knowledge requirements to those of commercial pilot requirements ( See Exemption No. 11062); and the airmanship skills necessary to safely operate the DJI Phantom 3 UAS, Precision Aerial Imagery submits that the additional manned airmanship experience of a commercially certificated pilot would not correlate to the airmanship skills necessary for Precision Aerial Imagery specific proposed flight operations. The FAA has previously granted relief from Section 61.113(a) and (b) specific to UAS, in circumstances similar, in all material respects, to those presen ted herein (e.g. Exemption Nos. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 11112, 11136, 11138, 11150, 11153, 11156, 11158, 11159, 11160, 11161).
Precision Aerial Imagery will not allow any PIC to operate the DJI Phantom 3 UAS
unless t hat PIC has demonstrated, by meeting minimum flight

- hour requirements or the
DJI Phantom 3 UAS training and currency requirements, that the PIC is able to safely operate the DJI Phantom 3 UAS in a manner consistent with this exemption, including
evasive an d emergency maneuvers and maintaining appropriate distances from people, vessels, vehicles and structures. Specifically, the PIC must have accumulated and logged, in a manner consistent with 14 C.F.R. § 61.51(b), 25 hours of total time as a UAS rotorcraft pilot (with a minimum of 5 hours of those hours as a UAS pilot operating the same make and model of UAS to be used for operations under the exemption). In addition to the hour requirements,25

the PIC must accomplish 3 takeoffs and landings in the preceding 9 0 days (for currency purposes). As in Exemption Nos. 11062, 11138, and 11153, prior documented flight experience that was obtained in compliance with applicable regulations will ensure an equivalent level of safety during Precision Aerial Imagery 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 UA S pilot with a multi

- rotor UAS. Prior to operations under Exemption No. 11062, the PIC must also have accumulated and logged a minimum of 5 hours as a UAS pilot operating the same make and model of UAS to be used for operations under the exemption. For cla rification, 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 rotorcraf t 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 compliance with applicable regulations would satisfy this requirement. Tr aining, 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 appropr iate distances in accordance with 14 C.F.R 91.119. Exemption No. 11138 at page 15. Accordingly, Precision Aerial Imagery will ensure safe operations by not allowing any PIC to operate the DJI Phantom 3 UAS unless that PIC has demonstrated, by meeting

min imum flight

- hour and currency requirements, that the PIC is able to safely operate the DJI Phantom 3 UAS in a manner consistent with the exemption, including evasive and26

emergency maneuvers and maintaining appropriate distances from people, vessels,
vehicl es 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, Precision Aerial Imagery will ensure that the DJI Phantom 3 UAS is in an airworthy condition based upon the UAS’s compliance with its operating

documents and as stated in the conditions and limitations herein. Additionally, the FAA has previously granted relief from Section 91.7(a) specific to UAS, in circumstances similar, in all material respects, to those presented herein (e.g. Exemption Nos. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 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 91.121 will be maintained
because the altitude information of the DJI Phantom 3 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 path and altitude. This altitude information, combined with Precision Aerial Imagery operation of the DJI Phantom 3 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 information will be generated by GPS equipment installed onboard the aircraft. Prior to each flight, a zero altitude initiation point is automatically established by the UASs at ground level. The FAA has previously granted relief from Section 91.121 specific to UAS, in circumstances similar, in all material respects, to those presented herein (e.g. Exemp tion27

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 gr ant 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 3 UAS; (2) the limitations on the proposed flight operations; and (3) the locatio n of the proposed flight operations. Accordingly, Precision Aerial Imagery will ensure that it will safely operate the battery powered DJI Phantom 3 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 3 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). Furthermore, safety will be ensured as the DJI Phantom 3 UAS provide audible and visual warnings to the PIC at th e GCS when the UAs experiences low battery voltage, the first warning occurring at approximately 33% remaining battery power, and again at approximately 10% remaining battery power. At the critically low battery level, the DJI
Phantom 3 UAS will descend an d 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 gr anted for manned aircraft to operate at less than the minimums prescribed in Section 91.151, including28

Exemption Nos. 2689, 5745, and 10650. Moreover, the FAA has previously granted relief from Section 91.151 specific to UAS, in circumstances similar, in a ll 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 Exemptio n 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, Precision Aerial Imagery submits that the equivalent level of safety with regard to t he 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 Precision Aerial Imagery will use trained technicians to perform maintenance, alterations , or preventive maintenance on the UAS using the methods, techniques, and practices prescribed in the operating documents (i.e., the Drone Sky Vision LLC, Aerial Operations Manual, Monthly Maintenance Log, and DJI Phantom 3 Instruction Manual). Furthermore , Precision Aerial Imagery will document and maintain
all maintenance records for the DJI Phantom 3 UAS. Since the DJI Phantom 3 UAS will be inspected as prescribed by the operating documents, Precision Aerial Imagery will maintain the equivalent level o f safety established by Sections 91.405(a), 91.409(a)(1), and 91.409(a)(2). A copy of the DJI Phantom 3 User Manuals are attached hereto as Exhibit B; a copy of the DJI Phantom 3
UAS Maintenance LOG is attached hereto as Exhibit C. Likewise, the exemption sought will not adversely affect safety because Precision
Aerial Imagery will use trained technicians to perform maintenance, alterations or29

preventive maintenance on the UAS using the methods, techniques, and practices prescribed by the operating documen ts. 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 3 UAS will be performed by trained technicians. Maintenance will be
docum ented and maintained utilizing the monthly maintenance log. Significantly, previous exemptions granted by the FAA concerning Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b) establish that safety is not adversely affected when t he technical characteristics and operating limitations of the
UAS are considered. In consideration of Precision Aerial Imagery proposed operating limitations, the operating documents, and the technical aspects of the DJI Phantom 3 UAS, Precision
Aerial Im agery 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, 11080, 11109, 11110, 11112, 11136, 11138, 11150, 11153, 11156, 11157, 11158, 11159, 11160, 11161). 7. The FAA May Prescribe Any Other Condit ions For Safe Operation.
In accordance with Section 333 of the FAA Modernization and Reform Act of 2012 (FMRA) and 14 C.F.R. § 21.16 entitled Special Conditions , Precision Aerial Imagery requests that the FAA prescribe special conditions for the intended operation of the DJI Phantom 3 UASs, which contain such safety standards that the Administrator finds necessary to establish a level of safety equivalent to that established by 14 C.F.R. Part 21,30

Subpart H, and 14 C.F.R §§ 61.113(a) & (b), 91.7 (a), 91.121 , 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b). Such special conditions will permit safe operation of the UA for the limited purpose of conducting aerial video and photography over certain areas of the United States for co mpensation or hire. FMRA Section 333 sets forth the requirements for considering whether a UAS will create a hazard to users of the NAS or the public, or otherwise pose a threat to national security; and further, provides the authority for such UAS to oper ate 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 3 UAS, since the airworthiness regulations of 14 C.F.R. Part 21 do not contain adequate or appropriate safety standards, due to the novel or unusual design features of the aircraft. Section 21.16, entitled Special Conditions , states
the fol lowing: If the FAA finds that the airworthiness regulations of this subchapter do not contain adequate or appropriate safety standards for an aircraft, aircraft engine, or propeller because of a novel or unusual design feature of the aircraft, aircraft eng ine or propeller, he prescribes special conditions and amendments thereto for the product. The special conditions are issued in accordance with Part 11 of this chapter and contain such safety standards for the aircraft, aircraft engine or propeller as the FAA finds necessary to establish a level of safety equivalent to that established in the regulations.
See 14 C.F.R. § 21.16. Therefore, in accordance with FMRA Section 333 and 14 C.F.R. § 21.16, the FAA may prescribe special conditions for Precision Aeria l Imagery intended operation of the DJI Phantom 3 UAS, which contain such safety standards that the Administrator finds necessary to establish a level of safety equivalent to that established by 14 C.F.R. Part 21,31

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 Precision Aerial Imagery Seeks Exemption:
Precision Aerial Im agery 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 Precision Aerial Imagery Seeks : This exemption will permit Precision Aerial Imagery 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, O r Arguments Available To Support Precision Aerial Imagery 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 sa fely in the NAS. As such, Precision Aerial Imagery 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 wil l create a hazard to users of the NAS or the public, or otherwise pose a threat to national security; and further, provides the authority for such UAS to operate without airworthiness
certification. As discussed in detail above, Precision Aerial Imagery will operate the DJI Phantom 3 UAS safely in the NAS, without creating a hazard to users of the NAS, or the public, or otherwise pose a threat to national security.
CONCLUSION32 As set forth herein, Precision Aerial Imagery Seeks an exemption pursuant to 14

C. F.R. § 11.61 and Section 333 of the FAA Modernization and Reform Act of 2012 (FMRA), which will permit safe operation of the DJI Phantom 3 UAS commercially, without an airworthiness certificate, for the limited purpose of conducting aerial video and photog raphy over certain areas of the United States. By granting this Petition, the FAA Administrator will be fulfilling the Congressional mandate of the FAA Modernization and Reform Act of 2012, while also advancing the interests of the public, by allowing Prec ision
Aerial Imagery to safely, efficiently, and economically operate the DJI Phantom 3 UAS commercially within the NAS.
WHEREFORE , in accordance with the Federal Aviation Regulations and the FAA Modernization and Reform Act of 2012, Section 333, Precisio n Aerial Imagery 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 Precision Aerial Imagery to operate the DJI Phantom 3 UAS commercially for the purpose of conducting aerial video and photography over certain areas of the United States.33

Dated: September 29 , 2015

Respectfully submitted,
Preci sion Aerial Imagery

/s/ Nathan Joel Edmonds

_________________________ Nathan Joel Edmonds 12017 Lavenia Ln Louisville, KY 40272 Tel: (502 ) 396

- 1950

Appendices :
A

– DJI Phantom 3 Technic al Specifications B

– DJI Phantom 3 Monthly Maintenance Log

APPENDIX

– A
DJI PHANTOM 3 TECHNICAL SPECIFICATIONS Precision Aerial Imagery only utilizes safe and reliable UASs. DJI is an industry leader in small UAS production. DJI UASs are loaded w ith ground breaking software enabling the user to set parameters which will not allow flight into controlled airspace. Parameters can also be34

set to limit flight to no higher than a predetermined and set altitude as well as limit flight to a predetermined and set distance. In addition, DJI software provides real

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

### Aircraft

WEIGHT (INCLUDING BA TTERY AND PROPELLERS )

1280 g DIAGONAL SIZE (INCLU DING PROPELLERS )

590 mm MAX ASCENT SPEED

5 m/s MAX DESCENT SPEED

3 m/s HOVER ACCURACY

 Vertical: +/

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

- 0.5 m

 Horizontal: +/

- 1.5 m MAX SPEED
16 m/s (ATTI mode, no wind) MAX ALTITUDE ABOVE S EA LEVEL

6000 m OPERATING TEMPERATUR E

0°C to 40°C GPS MODE

GPS/GLONASS



### Camera SENSOR

Sony EXMOR 1/2.3” Effective pixels: 12.4 M (total pixels: 12.76 M) LENS
FOV 94° 20 mm (35 mm format equivalent) f/2.8, focus at ∞ ISO RANGE

100

- 3200 (video) 100

- 1600 (photo) SHUTTER SPEED

8s

- 1/8000s IMAGE MAX SIZE35 4000 x 3000 STILL PHOTOGRAPHY MO DES

 Single Shot

 Burst Shooting: 3/5/7 shots

 Auto Exposure Bracketing (AEB): 3/5

 Bracketed Frames at 0.7EV Bias

 Time

- laps e VIDEO RECORDING MODE S 

### Phantom 3 Professional

 UHD: 4096x2160p 24/25, 3840x2160p 24/25/30

 FHD: 1920x1080p 24/25/30/48/50/60

 HD: 1280x720p 24/25/30/48/50/60 

### Phantom 3 Advanced

 FHD: 1920x1080p 24/25/30/48/50/60

 HD: 1280x720p 24/25/30/48/50/60 SUPPORTED SD CA RD TYPES

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

- 1 rating required MAX BITRATE OF VIDEO STORAGE 

### Phantom 3 Professional

60 Mbps 

### Phantom 3 Advanced

40 Mbps SUPPORTED FILE FORMA TS

 FAT32/exFAT

 Photo: JPEG, DNG

 Video: MP4, MOV (MPEG

- 4 AVC/H.264) OPERATING TEMPERATURE36 0°C to 40°C



### Gimbal CONTROLLABLE RANGE

Pitch

- 90° to +30° STABILIZATION

3

- axis (pitch, roll, yaw)



### Vision Positioning MAX VELOCITY

Less than 8 m/s (when 2 m above ground) ALTITUDE RANGE

30 cm

- 300 cm OPERATING RANGE

30 cm

- 300 cm OPERATING ENVIR ONMENT
Surface with clear pattern and adequate lighting (Lux > 15)



### Remote Controller OPERATING FREQUENCY

2.400 GHz

- 2.483 GHz MAX DISTANCE
2000m (outdoors and unobstructed) VIDEO OUTPUT PORT

USB OPERATING TEMPERATUR E

0°C

- 40°C BATTERY

6000 mAh LiPo 2S MOBI LE DEVICE HOLDER
For tablet or phone RECEIVER SENSITIVITY (1%PER)

- 101 dBm ±2 dBm TRANSMITTER POWER (E IRP)

 FCC: 20 dBm

 CE: 16 dBm WORKING VOLTAGE

1.2 A @7.4 V37



### Battery Charger VOLTAGE

17.4 V RATED POWER 

### Phantom 3 Professional

 100 W 

### Phantom 3 Advanced

 57 W



### Intelligent Flight Battery CAPACITY

4480 mAh VOLTAGE

15.2 V BATTERY TYPE

LiPo 4S ENERGY

68 Wh NET WEIGHT
365 g MAX FLIGHT TIME
Approximately 23 minutes OPERATING TEMPERATUR E

- 10°C to 40°C MAX CHARGING POWER

100 W



### App / Live View MOBILE APP

DJI Pilot EIRP

100mW LIVE VIEW WORKING FR EQUENCY

2.4GHz ISM LIVE VIEW QUALITY38 720P @ 30fps (depending on conditions and mobile device) LATENCY
220ms (depending on conditions and mobile device) REQUIRED OPERATING S YSTEMS

 iOS 8.0 or later

 Android 4.1.2 or later RECOMMENDE D DEVICES

 iOS: iPhone 5s, iPhone 6, iPhone 6 Plus, iPad Air, iPad Air Wi

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

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

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

- Fi + Cellular. This app is optimized for iPhone 5s, iPhone 6, and iPhone 6 Plus

 Android: Samsung S5, Note 3, Sony Xperia Z3, Google Nexus 7 II, Google Nexus 9, Mi 3, Nubia Z7 mini

 *Support for additional Android devices available as testing and development continues

APPENDIX

– B

Monthly Maintenance Log39 UAS #_____ Date Issue Maintenance Initials Performed Firmware Check Frame Engines Propellers Camera Gimbal Landing Gear Vibration Other: