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

Regulatory DocketNo.

_____ _



### IN THE MATTER OF THE PETITIONFOREXEMPTION OF: SchulhofMarketing Group, Inc. FORAN EXEMPTION SEEKINGRELIEF FROM THE REQUIREMENTS OF TITLE 14 OF THE CODE OF FEDERAL REGULATIONS SECTIONS 21 subpartH, 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 THE DJIINSPIRE 1 UNMANNED AIRCRAFT SYSTEM PURSUANT TO SECTION 333 OF THE FAA MODERNIZATION AND REFORM ACT OF 2012 (PUBLIC LAW 112-95)

Submitted onJune 11, 2015



### Christopher Schulhof SchulhofMarketing Group, Inc. 11216 Fall CreekRd, Suite 100 Indianapolis, IN 46256 317-842-4747

1TABLE OF CONTENTS
GLOSSARY OF ABBREVIATIONS 3
SUMMARY 4
INTRODUCTIONAND INTEREST OF PETITIONERS 4
BACKGROUND 5
BASIS FORPETITION 5
NAME AND ADDRESS OF PETITIONERS 7 THE SPECIFIC SECTIONS OF 14 C.F.R. FROM WHICH SCHULHOF MARKETING GROUP, INC. SEEKS EXEMPTION 8
THE EXTENT OF RELIEF SCHULHOF MARKETING GROUP, INC. SEEKAND THE REASON SCHULHOF MARKETING GROUP, INC. SEEKS THE RELIEF 11
THE REASONS WHY GRANTING REQUEST WOULD BE IN THE PUBLIC INTEREST 14
THE REASONS WHY GRANTING THE EXEMPTION WOULD NOT ADVERSELY AFFECT SAFETY 16
A SUMMARY THAT CAN BE PUBLISHED IN THE FEDERAL REGISTER 28
CONCLUSION 

### 29
APPENDIX 30

2GLOSSARY OF ABBREVIATIONS
AGL AOI ATC ATO AV CPR COA FAA FAR GCS GPS LOL NAS NOTCAM PIC Section 333


## so SOP UA UAS VFR VLOS VMC VTOL Above Ground Level Area OfInterest Air Traffic Control Air Traffic Organization Aerial Vehicle Code ofFederal Regulations Certificate ofAuthorization Federal Aviation Administration Federal Aviation Regulation Ground Control Station Global Positioning System Loss ofLink National Airspace System Notice To Airmen Pilot In Command FAA Modernization and Reform Act of2012 (FMRA) Section 333 Safety Observer Standard Operating Procedure Unmanned Aircraft Unmanned Aircraft System Visual Flight Rules Visual Line OfSight Visual Meteorological Conditions Vertical TakeoffAnd Landing

3SUMMARY Christopher Schulhof, owner ofSchulhofMarketing Group, Inc., seeks exemption from the requirements of 14 C.F.R § § 21 subpart H, 61.113(a) & (b), 91.7(a), 91.121, 91.151 (b), 91.405(a), 91.407(a)(l), 91.409(a)(l) & (a)(2), and 91.417(a) & (b), to operate an Unmanned Aircraft Systempursuant to Section 333 ofthe FAA Modernization and Reform Act of2012 (FMRA). This exemption will permit SchulhofMarketing Group, Inc. to operate anUnmanned Aircraft System (UAS) for the commercial purpose ofconducting aerial video andphotography to beused inreal estate virtual tours, television and web based commercials, real estate promotion over certain areas ofthe United States.
INTRODUCTION AND INTEREST OF THE PETITIONER Christopher Schulhofis the owner ofSchulhofMarketing Group, Inc., located inIndianapolis, IN. Schulhof Marketing Group, Inc. was founded in 2006. Christopher Schulhofhas 3 years ofexperience with RC flight and holds a CPRCertification. SchulhofMarketing Group, Inc. predominantlymarkets residential and commercial real estate in Indiana which includes homes, commercialbuildings, land and area attractions. The objective ofSchulhofMarketing Group, Inc. is to provide high quality imaging for a variety ofcommercial andpublic uses, specifically targeting:

• Real Estate Photography • Increasing public knowledge ofUAS andpromote safe UAS operations.

4BACKGROUND Unmanned Aircraft Systems: DJI Inspire 1UAS
SchulhofMarketing Group, Inc. seeks an exemption to operate DJI systems for its own use and for compensation or hire within the NAS. The DJI Inspire 1 is a vertical takeoffand landing (VTOL) Unmanned Aircraft (UA) with a Ground Control Station (GCS) utilizing electronic tablet or smart phone systems. The DJI Inspire 1has a maximum gross weight of6 pounds 7.5 ounces, a length of 17.3 inches, width of 17.7 inches, height of 11.8 inches, and a maximum speed of approximately 42 knots. The DJI Inspire 1UA is equipped with four main rotors; drivenby Lithium Polymerbatterypowered electric motors. The DJI Inspire 1 UA that will be operated by SchulhofMarketing Group, Inc. will be registered in accordance with 49 U.S.C. 44103, Registration of Aircraft, as well as 14 C.F.R Part 47,AircraftRegistration, and marked in accordance with 14 C.P.R. Part 45, Identification andRegistrationMarking.



### BASIS FORPETITION Petitioner, Christopher SchulhofofSchulhofMarketing Group, Inc. pursuant to the provisions ofthe Federal Aviation Regulations (14 C.P.R.§ 11.61) and the FAA Modernization and Reform Act of 2012 (FMRA), Section 333, SpecialRules for Certain UnmannedAircraftSystems, herebypetition the Administrator to commercially operate the DJI Inspire 1 UAS inthe National Airspace System (NAS), and for an exemption from the requirements of 14 C.F.R §§21 subpart H, 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 ofthe speed, weight, size, and limited operating area associated withthe unmanned aircraft and its operation, SchulhofMarketing Group, Inc.'s operation ofthe DJI Inspire 1 UAS meets the conditions ofFMRA Section 333 and therefore, will not require an airworthiness certificate in accordance with 14 C.P.R. Part 21, Subpart H. Accordingly, SchulhofMarketing Group, Inc. requests relieffrom Sections 91.405(a), 91.407(a)(l), 91.409(a)(l) & (a)(2), and 91.417(a) & (b), as these sections set forth requirements for maintenance that only apply to aircraft with an airworthiness certificate.
SchulhofMarketing Group, Inc. submits that the requested reliefis proper since an equivalent level of safety will be ensured. SchulhofMarketing Group, Inc. will use experiencedpersonnel ortechnicians to perform maintenance, alterations, orpreventive maintenance onthe UAS using the methods, techniques, andpractices prescribed inthe operating documents (i.e., Monthly Maintenance Log, and DJI Inspire 1 Instruction Manual). Furthermore, SchulhofMarketing Group, Inc. will document and maintain all maintenance records for the DJI Inspire 1 UAS.
Relieffrom certainrequirements ofSection 61.113(a) and (b), entitledPrivatepilotprivileges and limitations: Pilot in command, is requested by SchulhofMarketing Group, Inc. to the extent necessary to allow a Pilot in Command (PIC) holding an airman medical certificate, and who has demonstrated, bymeeting minimum flight- hour and currencyrequirements, that the PIC is able to safely operate the DJI Inspire 1UAS in a manner consistent with this exemption, including evasive and emergency



### 5maneuvers and maintaining appropriate distances from people, vessels, vehicles and structures. SchulhofMarketing Group, Inc. seeks relieffrom Section 91.7(a), entitled Civil aircraft airworthiness, because the DJI Inspire 1UAS does not require an airworthiness certificate in accordance with 14 C.P.R. Part 21, Subpart H. As such, SchulhofMarketing Group, Inc. submits that they will ensure that the DJI Inspire 1UAS is in an airworthy condition, priorto every flight, bydetermining that the UAS are in compliance with the operating documents (i.e., MonthlyMaintenance Log, and DJI Inspire I Instruction Manual), and that the aircraft are in a condition for safe flight.
SchulhofMarketing Group, Inc. also seeks an exemption from the requirements ofSection 91.121, entitledAltimeterSettings, as the DJI Inspire 1 UA will not have a typical barometric altimeter onboard. However, altitude information ofthe DJI Inspire 1 UAwill be provided to the PIC via Global Positioning System (GPS) equipment and radio communications telemetry data link, which downlinks from the UA to the GCS for active monitoring ofthe flight path. This altitude information, combined with SchulhofMarketing Group, Inc.'s operation ofthe DJI Inspire 1 UA within visual line ofsight, at orbelow 400 feet AGL, will ensure a level ofsafety equivalent to Section 91.121. Additionally, SchulhofMarketing Group, Inc. seeks an exemption from the requirements of Section 91.151(b), entitledFuel requirements for flight in VFR conditions. Schulhof Marketing Group, Inc. submits that safety will not be affected byoperation ofthe DJI Inspire I UA during daylight hours in visual meteorological conditions (VMC) undervisual flight rules (VFR), with enoughbatterypower to fly for a total duration ofapproximately 13.5 minutes to the first point ofintended 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, SchulhofMarketing Group, Inc. provides the following information in support oftheirpetition for exemption:

6

### A. N

### arne and Address OfThe Petitioner Christopher Schulhof SchulhofMarketing Group, Inc. 11216 Fall Creek Rd, Suite 100 Indianapolis, IN 46256 chris@indyplace.com



### 7

### B. The Specific Sections Of 14 C.F.R. From Which Schulhof Marketing Group, Inc. Seeks Exemption.
1. SchulhofMarketing Group, Inc. Seeks Exemption From The Requirements Of Section Part 21, SubpartH
14 C.P.R. Part 21, Subpart H, establishes the procedural requirements for the issuance of airworthiness certificates as required by 14 C.P.R. §91.203(a)(1)
2. SchulhofMarketing Group, Inc. Seeks Exemption From The Requirements Of Section 61.113(a) and (b).
Section 61.113, entitled Private pilot privileges and limitations: Pilot in command, 

### subsections (a) and (b) prescribe the following, inrelevantpart: (a) No person who holds a private pilot certificate may act as a pilot in command (PIC) of an aircraft that is carrying passengers or property for compensation or hire; nor may that person, for compensation or hire, act as PIC ofan aircraft. (b)A private pilot may, for compensation or hire, act as PIC ofan 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 carrypassengers orproperty for compensation orhire.
3. SchulhofMarketing Group, Inc. Seeks Exemption From The Requirements Of Section 91.7(a). Section 91.7, entitled civilaircraft airworthiness, 

### subsection (a), states the following: (a) No person may operate a civil aircraft unless it is in an airworthy condition.
4. SchulhofMarketing Group, Inc. Seeks Exemption From The Requirements Of Section
91.121.
Section 91.121, entitled Altimeter settings, subsection (a), states the following, inpart: (a) 

### Eachperson operating an aircraft shall maintainthe cruising altitude or flight level ofthat aircraft, as the case maybe, by reference to an altimeterthat is set, when operating- (1) Below 18,000 feet MSL, to-- (i) The current reported altimeter setting ofa station along the route and within 100 nautical miles ofthe aircraft; (ii) 

### Ifthere is no station within the area prescribed in paragraph (a)(l)(i) ofthis section, the current reported altimeter setting ofan appropriate available station; or (iii)In 

### the case ofan aircraft not equipped with a radio, the elevation ofthe departure airport or an appropriate altimeter setting available before departure.
5. SchulhofMarketing Group, Inc. Seeks Exemption FromThe Requirements OfSection 91.151(b).
Section 91.151, entitled Fuel requirementsforflight in VFR conditions, 

### subsection (b), states the following: (b) Noperson may begin aflight in a rotorcraft under VFR conditions unless 

### 8(considering windand forecast weather conditions) there is enough fuel tofly to the first point of intended landing and, assuming normal cruisingspeed, tofly after that for at least 20 minutes.
6. SchulhofMarketing Group, Inc. Seeks Exemption From The Requirement Of Section 91.405(a).
Section 91.405, entitledMaintenance required, subsection (a), states the following: Each owner or operator ofan aircraft- (a) Shall have that aircraft inspected as prescribed in subpart E ofthis part and shall between required inspections, except as provided inparagraph (c) ofthis section, have discrepancies repaired as prescribedinpart 43 ofthis chapter[.]
7. SchulhofMarketing Group, Inc. Seeks Exemption From The Requirements Of Section 91.407(a)(l)
Section 91.407, entitled Operation after maintenance,preventive maintenance, rebuilding, or alteration, subsection (a)(l), states the following: (a) No personmay operate any aircraft that has undergone maintenance, preventive maintenance, rebuilding, or alterationunless-- (1) Ithas been approved for return to service by a person authorized under § 43.7 ofthis chapter[.]
8. SchulhofMarketing Group, Inc. Seeks Exemption From The Requirements Of Sections 91.409(a)(l) And 91.409(a)(2).
Section 91.409, entitledInspections, subsection (a), states the following: (a) Except as provided inparagraph (c)ofthis section, no personmay operate an aircraft unless, within the preceding 12 calendar months, it has had-- (1) An annual inspection in accordance withpart 43 ofthis chapter and has been approved for return to service by a person authorized by § 43.7 ofthis chapter; or (2) An inspection for the issuance ofan airworthiness certificate in accordance withpart 21 of this chapter.
9. SchulhofMarketing Group, Inc. Seeks Exemption From The Requirements Of Sections 91.417(a) And 91.417(b).
Section 91.417, entitledMaintenance records, subsections (a) and (b), state the following: (a) Except for workperformed in accordance with§§ 91.411 and 91.413, each registered owner or operator shall keep the following records for the periods specified inparagraph (b) ofthis section: (1) Records ofthe maintenance, preventive maintenance, and alteration and records ofthe 100-hour, annual, progressive, and other required or approved inspections, as appropriate, for each aircraft (including the airframe) and each engine, propeller, rotor, and appliance ofan aircraft. The records must include9(1) A description (or reference to data acceptable to the Administrator) ofthe work performed; and (ii) The date ofcompletion ofthe workperformed; and (iii)The signature, and certificate number ofthe person approving the aircraft for return to service. (2) Records containing the following information: (i) The total time in service ofthe airframe, each engine, eachpropeller, and eachrotor. (ii) The current status oflife-limitedparts ofeach airframe, engine, propeller, rotor, and appliance. (iii)The time since last overhaul ofall items installed onthe aircraft which are required to be overhauled on a specified time basis. (iv) The current inspection status ofthe aircraft, including the time since the last inspection requiredbythe inspectionprogramunder 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. Ifthe AD or safety directive involves recurring action, the time and date whenthe next action is required. (vi) Copies ofthe forms prescribedby§ 43.9(d) ofthis chapter for eachmajor 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 inparagraph (a)( I) ofthis section shall be retained until the work is repeated or supersededby otherwork or for 1 year after the work is performed. (2) The records specified inparagraph (a)(2) ofthis section shall be retained and transferred with the aircraft at the time the aircraft is sold. (3) A list ofdefects furnished to a registered owner or operator under § 43.11 ofthis chapter shall be retained until the defects are repaired and the aircraft is approved for returnto service.



### 10

### C.The Extent OfReliefSchulhofMarketing Group, Inc. Seeks And The Reason SchulhofMarketing Group, Inc. Seeks The Relief.
1. SchulhofMarketing Group, Inc. Seeks Exemption From The Requirements Of Section Part 21, Subpart H
Given the size and limited operating area associated with the UAS to be utilized by the Schulhof Marketing Group, Inc., an exemption from Part 21 Subpart H meets the requirements ofan equivalent level ofsafetyunder Part 11 and Section 333 ofthe Reform Act.
The Federal Aviation Act (49 U.S.C.§ 44701(f)) and Section 333 ofthe Reform Act both authorize the FAA to exempt aircraft from the requirement for an airworthiness certificate, upon consideration ofthe size, weight, speed, operational capability, and proximity to airports andpopulated areas ofthe particular UAS.
In all cases, an analysis ofthese criteria demonstrates that the UAS operated without an airworthiness certificate, inthe restricted environment and under the conditions proposed will be at least as safe, or safer, than a conventional rotorcraft operating with an airworthiness certificate without the restrictions and conditions ofthe proposed UAS operations.
2. Extent OfReliefSchulhofMarketing Group, Inc. Seeks And The Reason SchulhofMarketing Group, Inc. Seeks ReliefFrom Section 61.113 (a) and (b).
Relieffrom Section 61.113 (a) and (b) entitledPrivatepilotprivileges and limitations: Pilot in command, is requested to the extent necessaryto allow a PIC holding a valid airman medical certificate, and who has met certain flight-hour and currency requirements, to conduct the proposed UAS flight operations for compensation orhire.
This reliefis requested since the limitations set forth in Section 61.113(a) and (b) state that a private pilot may, for compensation orhire, act as PIC ofan 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 carrypassengers orproperty for compensation orhire.
As set forth more fully below, SchulhofMarketing Group, Inc. submits that an equivalent level ofsafetywill be maintained because no PIC will be allowed to operate the DJI Inspire 1UAS unless that PIC has met certain flight-hour and currency requirements, demonstrating that the PIC is able to safely operate the DJI Inspire I UAS in a manner consistent with the operations specifications as described inthis exemption, including evasive and emergency maneuvers, as well as maintaining appropriate distances from people, vessels, vehicles and structures. Further, SchulhofMarketing Group, Inc. submits that all flights ofthe DJI Inspire 1 UAS, conducted bythe PIC pursuant to the grant ofthis Petition: (1) will be incidental to Schulhof Marketing Group, Inc.'s business; and (2) will not carry passengers or property for compensation orhire.

11

### 3. Extent OfReliefSchulhofMarketing Group, Inc. Seeks And The Reason SchulhofMarketing Group, Inc. Seeks ReliefFrom Section 91.7(a).
Relieffrom Section 91.7(a) entitled Civil aircraft airworthiness, is requested to the extent required to allow SchulhofMarketing Group, Inc. to determine that the DJI Inspire 1 UAS are in airworthy conditionprior to every flight byensuring that the UAS is in compliance with the operating documents (i.e., the Monthly Maintenance Log, and DJI Inspire 1 Instruction Manual). SchulhofMarketing Group, Inc. seeks the requested reliefbecause the DJI Inspire 1U A does not require an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H. Therefore, SchulhofMarketing Group, Inc. will ensure that the DJI Inspire 1 UAS is in airworthy conditionbasedupon its compliance withthe operating documents (i.e., Monthly Maintenance Log, and DJI Inspire 1 Instruction Manual) prior to every flight, and further, determine that the aircraft are in condition for safe flight, as stated inthe conditions and limitations below.


### 4. Extent OfReliefSchulhofMarketing Group, Inc. Seeks And The Reason SchulhofMarketing Group, Inc. Seeks ReliefFrom Section 91.121.
Relieffrom Section 91.121, entitled Altimeter settings, maybe required to allow flight operations ofthe DJI Inspire 1UAS, whichutilize a barometric pressure sensor, GPS equipment, and a radio communications telemetry data linkto downlink altitude information from the UA to the PIC at the ground control station (GCS). Since the FAArequires that any altitude information concerning UAS operations be reported to air traffic control (ATC) in feet above ground level (AGL), SchulhofMarketing Group, Inc. seeks the requested relief because the DJI Inspire 1UA's altimetermaybe set onthe ground to zero feet AGL, rather than the local barometric pressure or field altitude, before each flight. Considering the limited altitude ofthe proposed operations, relieffrom 14 CFR 91.121 is sought to the extent necessary to complywith the applicable conditions and limitations stated below. As more fully set forth herein, an equivalent level ofsafety will be maintained since the DJI Inspire 1 UA is equipped with a barometric pressure sensor and GPS equipment, which automatically ensures that a ground level pressure setting will be establishedprior to each flight, andprovides the PIC with altitude information ofthe UA onthe heads-up display ofthe GCS.


### 5. Extent OfReliefSchulhofMarketing Group, Inc. Seeks And The Reason SchulhofMarketing Group, Inc. Seeks ReliefFrom Section 91.151(b).
Relieffrom Section 91.151(b) entitled Fuel requirements for flight in VFR conditions, is requested to the extent required to allow flights ofthe batterypowered DJI Inspire 1 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 ofintended landing and,



### 12assuming normal cruising speed, to fly after that for at least 4.5 minutes. SchulhofMarketing Group, Inc. seeks the requested reliefbecause without an exemption from Section 91.151(b), the flight time duration ofthe batterypowered DJI Inspire 1UA will severely constrain the practicality ofany aerial video or stillphoto flight operations that SchulhofMarketing Group, Inc. proposes to conduct pursuant to this Petition. Significantly, as set forth below, the technical specifications ofthe DJI Inspire 1UAS, the DJI Inspire 1 operating documents, and SchulhofMarketing Group, Inc.'sproposed operating limitations, ensure that SchulhofMarketing Group, Inc. will safely operate the batterypowered DJI Inspire 1UA during daylight hours invisual meteorological conditions (VMC), undervisual flight rules (VFR), with enough batterypower to fly for a total duration of 13.5 minutes to the first point ofintended landing and, assuming normal cruising speed, to fly after that for at least 4.5 minutes.


### 6. Extent OfReliefSchulhofMarketing Group, Inc. Seeks And TheReason SchulhofMarketing Group, Inc. Seeks ReliefFrom Sections 91.405(a), 91.407(a)(l), 91.409(a)(l) & 

### (a)(2), And 91.417(a) 

### & (b).
Since Sections 91.405(a), 91.407(a)(l), 91.409(a)(l) & (a)(2), and 91.417(a) & (b) only apply to aircraft with an airworthiness certificate, SchulhofMarketing Group, Inc. requests relieffrom these Sections because the DJI Inspire 1 UAS does not require an airworthiness certificate. As set forth more fully below, the DJI Inspire 1 UAS meets the conditions of FMRA Section 333 for operationwithout an airworthiness certificate. Accordingly, Schulhof Marketing Group, Inc. will use trained technicians to perform maintenance, alterations, or preventive maintenance onthe UAS using the methods, techniques, andpractices prescribed in the UAS operating documents (i.e., Monthly Maintenance Log, and DJI Inspire 1 Instruction Manual). Furthermore, SchulhofMarketing Group, Inc. will document and maintain all maintenance records for the DJI Inspire 1 UAS.



### 13

### D.The Reasons Why Granting SchulhofMarketing Group, Inc.'s Request Would Be In The Public Interest; or How It

### Would Benefit The Public As A Whole. Granting the presentpetition will further the public interest by allowing SchulhofMarketing Group, Inc. to safely, efficiently, and economicallyperform aerial video and photography of wilderness, real estate, and landscapes over certain areas ofthe United States. Furthermore, it will benefit the public as a whole byincreasing awareness for the wild lands, therefor increasing tourism, and stimulating the economy ofa highlytourism dependent area. Additionally, use ofthe DJI Inspire 1UAS will decrease congestion ofthe NAS, and reduce pollution. Notably, the benefits ofSchulhofMarketing Group, Inc.'sproposed operation of the DJI Inspire 1 UAS will be realized without implicating anyprivacy issues.
1. 

### The PublicWill BenefitFromDecreased Congestion OfThe NAS. The DJI Inspire 1 UAs are batterypowered and serve as a safe, efficient, and economical alternative to the manned aircraft traditionallyutilized to obtain aerial imagery. Byreducing the amount ofmanned aircraft needed to perform aerial acquisitions, an exemption allowing the use ofa DJI Inspire 1UAS would reduce the amount ofmanned aircraft inthe NAS, reduce noise and airpollution, as well as increase the safety oflife and property in the air and onthe ground. Furthermore, byreducing the number ofmanned aircraft operating inthe NAS, congestion around airports causedby arriving and departing aircraft will be reduced. The DJI Inspire 1 UAs do not require an airport to takeoffor land. Likewise, a reduction ofmanned aircraft conducting aerial video and photographymissions wouldresult in fewer aircraft that mustbe handled by air traffic control during the ground, takeoff, departure, arrival, and landing phases offlight operations.


### 2. The PublicWill Benefit From The Safety And Efficiency OfThe DJI Inspire 1 UAS. Conducting aerial acquisitions with the DJI Inspire 1 UAS, instead ofmanned aircraft, will greatlybenefit the public bydrasticallyreducing the levels ofair and noise pollution generated during traditional aerial video and still photography flight operations. Byusing batterypower and electric motors, the DJI Inspire I UAS produces no airpollution, and is the most viable environmentally conscious alternative to the cabin class, six cylinder internal combustion engine aircraft that are typically utilized for aerial video and photography, while burning approximately 20-30 gallons perhour ofleaded aviation fuel. The DJI Inspire 1 UA, while reducing the carbon footprint ofaerial acquisitions, also eliminates noise pollution, as the UAs are propelledbybatterypowered electric motors, ratherthan an internal combustion engme. Byusing the DJI Inspire 1UAS to perform aerial acquisitions, the substantial risk to life and property inthe air and onthe ground, which is usually associated with traditional manned aircraft flight operations, will be substantiallyreduced or completely eliminated.



### 14Aside from the lack offlight crew members located onboard the aircraft, the DJI Inspire 1 UA (weighing approximately 6 pounds 7.5 ounces respectively, at its maximum gross weight with a length of 17.3 inches and width of 17.7 inches, and with no fuel onboard), has less physical potential for collateral damage to life and property onthe ground, and inthe air, compared to the manned aircraft that typically conduct similar operations (weighing approximately 6,000 pounds with a wingspan ofapproximately 42 feet, a length of34 feet, and a fuel capacity of 180 gallons).


### 3. Performing Aerial Video and Photography Operations With TheDJIInspire 1 UAS Will Benefit The Economy.
In addition to being safe and efficient, the DJI Inspire 1UAS is also an economical alternative to using manned aircraft to conduct similar aerial operations. As such, operation ofthe DJI Inspire 1UAS will allow United States based companies, like SchulhofMarketing Group, Inc., to remain competitive and contribute to growth ofthe U.S. economy. Specifically, with the rising cost ofaviation fuel and the Environmental Protection Agency ("EPA") regulatory actions phasing out leaded aviation fuels, U.S. owned and operated companies must adopt new and alternative technology in order to remain competitive. Operating the batterypowered DJI Inspire 1UAS is one such technologythat not only allows companies greater operational flexibility compared to manned aircraft, butprovides such flexibility without the high operational cost ofa traditional manned aircraft. By operating the DJI Inspire 1UAS, companies such SchulhofMarketing Group, Inc., can remain competitive and profitable, and therefore, provide greaterjob stability to employees and contractors, which will ultimately contribute to growth ofthe U.S. economy. Improved financial performance ofU.S. companies, through commercial use ofthe DJI Inspire 1 UAS, provides a stable workforce that increases consumer spending; improves local, state, and federal tax revenues; and allows companies to invest inresearch and development in order to remain competitive bothinthe United States and abroad. Additionally, by allowing operation ofthe DJI Inspire 1, SchulhofMarketing Group, Inc. will be able to more easily work with local and state tourism agencies to showcase the beauty and wildness ofa very tourism based economy, therefor improving the economy of both state and local businesses.


### 4. There Are No PrivacyIssues. Similar to the manned aerial acquisition flight operations that have been conducted for decades, SchulhofMarketing Group, Inc.'s proposed operation ofthe DJI Inspire 1UAS will not implicate anyprivacy issues. Specifically, the DJI Inspire 1UAS will be operated only in compliance with operating documents (i.e., Monthly Maintenance Log, and DJI Inspire 1 Instruction Manual), whichrequires property owner involvement as well as local law enforcement notification, and in accordance with the Federal Aviation Regulations, including the minimum altitude requirements of 14 C.P.R. §91.119.



### 15

### E. The Reasons Why Granting The ExemptionWould NotAdversely Affect Safety, Or How The Exemption Would Provide A Level OfSafety AtLeastEqual To That Provided By The Rule FromWhich Schulhof Marketing Group, Inc. Seeks Exemption.
1. 

### Reasons WhyTheDJIInspire 1 UA Meets The Conditions OfThe FAA Modernization and Reform Act of2012 (FMRA) Section 333. In consideration ofthe size, weight, speed, and limited operating area associated withthe unmanned aircraft and its operation, SchulhofMarketing Group, Inc.s's operation ofthe DJI Inspire 1 UAS meets the conditions ofFMRA Section 333, and will not require an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H.
Section 333 provides authority for a UAS to operate without airworthiness certification and sets forth requirements for considering whether a UAS will create a hazard to users ofthe NAS or the public, orotherwise pose a threat to national security. Specifically, FMRA Section 333 states the following, inpart: (a) In General.--Notwithstanding any other requirement of this subtitle, andnot later than 180 days after the date of enactment of thisAct, the Secretary of Transportation shall determine 

### if certain unmannedaircraftsystems may operate safely in the national airspace system before completion of the plan and rulemaking required by section 332 of thisActor the guidance requiredby section 334 of thisAct. (b) AssessmentofUnmannedAircraftSystems.-In making the determination wider subsection (a), the Secretary shall determine, ata

**minimum~** (1) which types of unmannedaircraftsystems, 

### if any, as a result of theirsize, weight, speed, operational capability,proximity to airports and populatedareas, and operation within visual line of sightdo not create a hazard to users of the national airspace system or the public orpose a threat to nationalsecurity; and (2) whether a certificate of waiver, certificate of authorization, orairworthiness certification undersection 44704 of title 49, United States Code, is required for the operation of unmannedaircraftsystems identified underparagraph (1). (c) Requirements for Safe Operation.--If the Secretary determines under this section that certain unmannedaircraftsystems may operate safely in the nationalairspace system, the Secretary shall establish requirements for the safe operation of such aircraft systems in the national airspace system.
In seeking this exemption, SchulhofMarketing Group, Inc. submits that the DJI Inspire 1 UAS can operate safely in the NAS pursuant to FMRA Section 333, as demonstratedby: (a) the characteristics ofthe DJI Inspire 1 UAS; (b) the pilot certificationrequirement; and (c) the specific operating limitations.



### a. The Specifications OfTheDJI Inspire 1 UAS Demonstrates Its Safe Characteristics.

16The DJI Inspire 1 UAS does not create a hazard to users ofthe NAS or the public, or otherwise pose a threat to national security considering its size, weight, speed, and operational capability.


### i. Technical Specifications OfTheDJI Inspire 1 UAS. The technical specifications ofthe DJI Inspire 1 UAS are set forth by the DJI Inspire 1 Specifications and Data Sheet.


### ii. TheDJI Inspire 1 UAS Autonomous Flight And Navigation Modes Enable The UAS To RemainWithin A Defined Operational Area. The DJI Inspire 1 UAS maybe operated inbothmanual and fully autonomous flight modes. A complete description ofthe flight and navigational modes ofthe DJI Inspire 1UAS is provided at pages 12-16 and 45-50 ofthe DJI Inspire 1User Manual, attached hereto as Exhibit B.


### iii.TheDJI Inspire I UAS Is Designed ForAutomatic Return To Home Point Or Hover In The Event OfLoss OfThe Control Link Or Navigation. When the Control Link is lost, the DJI Inspire 1UA will remain stationary, inflight, for 3 seconds ormore. If, after 3 seconds, DJI Inspire 1UA do not reacquire control link data from the GCS, the UA will assume that the Control Link is lost and the UA will return to the home position (i.e., failsafe mode) via GPS, and will descend to the takeoffposition and shutdown.
A complete description ofthe Failsafe Functions ofthe DJI Inspire 1UAS are set forth at pages 13 through 15 ofthe DJI Inspire 1User Manual, attached hereto as Exhibit A.


### iv.The DJI Inspire I GCS And Its Operation. A complete description ofthe operation and specifications ofthe DJI Inspire 1 GCS and flight control software is provided at pages 40 through 47 ofthe DJI Inspire 1User Manual. DJI Inspire 1 UserManual is attached hereto as Exhibit A.


### b. Flight Operations OfDJIInspire 1 UAS is LimitedTo The Line OfSight OfA Certificated Pilotin Command With A Safety Observer.
SchulhofMarketing Group, Inc. will onlyutilize certificatedpilots to act as a pilot in command (PIC) ofthe DJI Inspire 1UAS. Additionally, a safety observer will assist all pilots during flight time.



### c. Flights OfTheDJI Inspire 1 UAS Will Be Conducted PursuantTo Specific OperatingLimitations.
In seeking this exemption, Schulhof Marketing Group, Inc. proposes to commercially operate the DJI Inspire 1 UAS for the special purpose of conducting aerial video and photographyovercertain areas ofUnited States, pursuantto the following specific operating limitations:

1. Operations authorized bythis grant ofexemption will be limited to the following



### 17aircraft described in the operating documents, rotorcraft UASs weighing less than 55 pounds maximum gross weight: DJI Inspire 1 Unmanned Aircraft Systems. Proposed operations of any other aircraft will require a new petition or a petition to amend this grant.

2. UAS operations underthis exemption will be limited to conducting operations for the purpose ofaerial video andphotography.

3. The UAs maynot be flown at an indicated airspeed exceeding 20 knots.
4. The UAmust be operated at an altitude ofno more than 400 feet above ground level (AGL), as indicatedbythe procedures specified inthe operating documents unless a special request is made and approved byATC. All altitudes reported to ATC must be in feet AGL.

5. The UAs must be operated within visual line ofsight (VLOS) ofthe PIC at all times. This requires the PIC to be able to use human visionunaided by any device other than corrective lenses, as specified onthe PIC's FAA-issued airman medical certificate.

6. The use offirst person view (FPV) bythe PIC or safety observer (SO) is notpermitted.

7. All operations must utilize a safety observer (SO). The SO maybe used to satisfy the VLOS requirement as long as the PIC always maintains VLOS capability. The SO and PIC must be able to communicate verbally at all times. Electronic messaging ortexting is not permitted during flight operations. The PIC must be designated before the flight and cannot transfer his orher designation for the duration ofthe flight. The PIC must ensure that the SO canperform 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 ofexemption must be accessible during UAS operations and made available to the Administratoruponrequest. Ifa discrepancy exists between the conditions and limitations contained inthe grant ofexemption and the procedures outlined inthe operating documents, the conditions and limitations contained in the grant ofexemption take precedence and must be followed. Otherwise, the operatormust follow the procedures as outlined in its operating documents. The operator mayupdate or revise its operating documents. Itis the operator's responsibility to track suchrevisions and present updated and revised documents to the Administratoruponrequest. The operator must also present updated and revised documents ifit petitions for extension or amendment to the grant ofexemption. Ifthe operator determines that anyupdate orrevision would affect the basis upon whichthe FAA granted the exemption, then the operator mustpetition for amendment to its grant ofexemption. The FAA's UAS Integration Office (AFS-80) maybe contacted ifquestions arise regarding updates orrevisions to the operating documents.



### 1810. Prior to each flight the PIC must inspect the UAS to ensure that it is in a condition for safe flight. Ifthe inspection reveals a condition that affects the safe operation ofthe UAS, the aircraft is prohibited from operating until the necessarymaintenance has beenperformed and the UAS is found to be in a condition for safe flight. The Ground Control Stationmust be included inthe preflight inspection. All maintenance and alterations mustbeproperly documented in the aircraft records.

11. AnyUAS that has undergone maintenance or alterations that affect the UAS operation or flight characteristics, e.g. replacement ofa flight critical component, mustundergo a functional test flight. The PIC who conducts the functional test flight must make anentry 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 ofthe operating documents.

13. The operatormust follow the UAS manufacturer's aircraft/component, maintenance, overhaul, replacement, inspection, and life limit requirements.

14. The operatormust carry out its maintenance, inspections, andrecord keeping requirements, in accordance with the operating documents. Maintenance, inspection, alterations, and status ofreplacement/overhaul componentparts must be noted inthe aircraft records, including total time in service, description ofwork accomplished, and the signature ofthe authorizedpersonreturning the UAS to service.

15. EachUAS operated underthis exemptionmust comply with all manufacturer Safety Bulletins.

16. The authorizedperson must make an entry inthe aircraft record ofthe corrective action taken against discrepancies discoveredbetween inspections.

17. The PIC must meet possess at least a current medical certificate.

18. The operatormay notpermit any PIC to operate unless the PIC meets the operator's qualification criteria and demonstrates the abilityto safely operate the UAS in a manner consistent with how the UAS will be operated under the exemption, including evasive and emergencymaneuvers and maintaining appropriate distances from persons, vessels, vehicles and structures. PIC qualification flight hours must be logged in a manner consistent with 14 C.F.R. § 61.5l(b). Flights for the purposes oftrainingthe operator's PICs are permitted under the terms ofthe exemption. However, training operations may onlybe conducted during dedicated training sessions. During training, proficiency, and experience-building flights, all persons not essential for flight operations are considered non-participants, and the PIC must operate the UA with appropriate distance from nonparticipants in accordance with 14 C.F.R. § 91.119.

19. UAS operations maynot be conducted during night, as defined in 14 C.F.R. § 1.1. All



### 19operations must be conducted under visual meteorological conditions (VMC). Ifflight 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 maynot operate within 5 nautical miles ofan airport reference point as denoted on a currentFAA-published aeronautical chart unless a letter ofagreement withthat airport's management is obtained, and the operationis conducted in accordance with a NOTAM as requiredbythe operator's COA. The letter ofagreement withthe airport management must be made available to the Administrator uponrequest.

21. The UA maynot be operated more than 400 feet above ormore than 2,000 feet horizontally from the PIC when visibility is less than 3 statute miles from the PIC.

22. Ifthe UA loses communications orloses its GPS signal, it mustreturn to a predetermined location within the planned operating area and land orbe recovered in accordance with the operating documents.

23. The PIC must abort the flight inthe event ofunpredicted 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 enoughpowerto fly at normal cruising speed to the intended landing point and land the UA with 25% batterypowerremaining.

25. The operator must obtain an AirTraffic Organization (ATO) issued Certificate ofWaiver orAuthorization (COA) prior to conducting any operations under the grant ofexemption. This COA will also require the operator to request a Notice to Airman (NOT AM) not more than 72 hours in advance, but not less than 48 hourspriorto the operation. All operations shall be conducted in accordance with airspace requirements inthe ATO issued COA including class ofairspace, altitude level andpotential transponder requirements.

26. All aircraft operated 

### in accordance with the exemption mustbe identifiedby serial number, registered in accordance with 14 C.F.R. part 47, and have identification (NNumber) markings in accordance with 14 C.F.R. part 45, Subpart C. Markings mustbe as large as practicable.

27. Before conducting operations, the radio frequency spectrum used for operation and control ofthe UA must comply with the Federal Communications Commission (FCC) or other appropriate government oversight agencyrequirements.

28. The documents required fewer than 14 C.F.R. 91.9 and 91.203 mustbe available to the PIC at the Ground Control Station ofthe UAS any time the UAS is operating. These documents mustbe made available to the Administrator or any law enforcement official uponrequest.



### 2029. 

### The UA must remain clear and yield the right ofway 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. Ifa situation arises where nonparticipating persons leave such protection and are within 500 feet ofthe 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 ofthe risk ofoperating 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. 

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

33. 

### Any incident, accident, or flight operation that transgresses the lateral or vertical boundaries ofthe operational area as defined by the applicable COA must be reported to the FAA's UAS Integration Office (AFS-80) within 24 hours. Accidents must be reported to the National Transportation Safety Board (NTSB) per instructions contained on the NTSB Web site: www.ntsb.gov.

212. Reasons WhyAn Exemption From The Requirements OfSection 21 SubpartH Would Not AdverselyAffect Safety. SchulhofMarketing Group, Inc. submits that the equivalent level ofsafety establishedby Section 61.113(a) and (b) will be maintained because The UAS to be operatedhereunder weighs less than 55 lbs. fully loaded, carries neither a pilot norpassenger, carries no explosive materials or flammable liquid fuels, and operates exclusivelywithin a secured area. Unlike other civil aircraft, the proposed operations inthis petition for exemption will be controlled and monitored bythe operator, pursuant to the Manual's requirements.
These safety enhancements, which already apply to civil aircraft operated in connection with existing inspection operations, provide a greater degree ofsafetyto the public and property owners than conventional operations conducted with airworthiness certificates issued under 14 C.F.R. Part 21, Subpart H. Lastly, application ofthese same criteria demonstrates that there is no credible threat to national securityposedbythe UAS, due to its size, speed of operation, location ofoperation, lack ofexplosive materials or flammable liquid fuels, and inability to carry a substantial external load.
3. Reasons Why An Exemption FromThe Requirements OfSection 61.113(a) And (b)Would NotAdverselyAffect Safety.
SchulhofMarketing Group, Inc. submits that the equivalent level ofsafety establishedby Section 61.113(a) and (b) will be maintained because no PIC will be allowed to operate the DJI Inspire 1 UAS unless that PIC has demonstrated, bymeeting minimum flight-hour and currencyrequirements, that the PIC is able to safely operate the DJI Inspire 1UAS in a manner consistent with the exemption, including evasive and emergencymaneuvers and maintaining appropriate distances from people, vessels, vehicles and structures. Considering SchulhofMarketing Group, Inc.'sproposed area ofoperations, and the operating limitations set forth-above; the parallel nature ofprivate pilot aeronautical knowledge requirements to those ofcommercial pilot requirements (See ExemptionNo. 11062); and the airrnanship skills necessary to safely operate the DJI Inspire 1UAS, SchulhofMarketing Group, Inc. submits that the additional manned airrnanship experience ofa commercially certificatedpilot would not correlate to the airrnanship skills necessary for SchulhofMarketing Group, Inc.'s specific proposed flight operations.
The FAA has previously granted relieffrom Section 61.113(a) and (b) specific to UAS, in circumstances similar, in all material respects, to those presentedherein (e.g. Exemption Nos. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 11112, 11136, 11138, 11150, 11153, 11156, 11158, 11159, 11160, 11161). SchulhofMarketing Group, Inc. will not allow any PIC to operate the DJI Inspire 1UAS unless that PIC has demonstrated, bymeeting minimum flight-hour requirements or the DJI Inspire 1UAS training and currency requirements, that the PIC is able to safely operate the DJI Inspire 1UAS in a manner consistent with this exemption, including evasive and

22emergencymaneuvers 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 oftotal time as a UAS rotorcraft pilot (with a minimum of5 hours ofthose hours as a UAS pilot operating the same make and model ofUAS to be used for operations underthe exemption). In addition to the hour requirements, the PIC must accomplish 3 takeoffs and landings inthe preceding 90 days (for currencypurposes).
As inExemptionNos. 11062, 11138, and 11153, prior documented flight experience that was obtained in compliance with applicable regulations will ensure an equivalent level of safety during SchulhofMarketing Group, Inc.'s 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 ExemptionNo. 11062, the FAArequired that prior to conducting operations for the purpose ofmotionpicture filming (or similar operations), the PIC must have accumulated and logged, in a manner consistent with 14 CFR 61.51(b), 25 hours oftotal time as a UAS rotorcraft pilot including at least 10 hours logged as a UAS pilot with a multi-rotorUAS. Prior to operations underExemptionNo. 11062, the PIC must also have accumulated and logged a minimum of5 hours as a UAS pilot operating the same make and model ofUAS to be used for operations under the exemption. For clarification, the FAA considers these minimum hourrequirements to be inclusive rather than additive; i.e. 5 hours make and model time maybe included inthe 10 hours ofmulti-rotortime and the 10 hours maybe included in the total25 hours ofUAS rotorcraft time. In addition to the hour requirements, the PIC must accomplish 3 takeoffs and landings inthe preceding 90 days (for currencypurposes). The FAA finds that at a minimum, the flight-hour requirements in ExemptionNo. 11062 are appropriate to practice and buildproficiency inthe skills necessary to safdyconduct the petitioner's proposed operations. The FAA also finds that prior documented flight experience that was obtained in compliance with applicable regulations would satisfythis requirement. Training, proficiency, and experience-building flights can also be conducted under the grant ofexemption 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. ExemptionNo. 11138 at page 15. Accordingly, SchulhofMarketing Group, Inc. will ensure safe operations bynot allowing any PIC to operate the DJI Inspire 1 UAS unless that PIC has demonstrated, bymeeting minimum flight-hour and currencyrequirements, that the PIC is able to safely operate the DJI Inspire 1 UAS in a manner consistent with the exemption, including evasive and emergencymaneuvers and maintaining appropriate distances from people, vessels, vehicles and structures. 4. Reasons WhyAn Exemption From The Requirements OfSection 91.7(a) Would



### 23

### Not AdverselyAffect Safety.

The equivalent level ofsafety establishedby Section 91.7(a) will bemaintainedbecause prior to everyflight, SchulhofMarketing Group, Inc. will ensure that the DJI Inspire 1 UAS is in an airworthy conditionbaseduponthe UAS's compliance with its operating documents and as stated inthe conditions and limitations herein. Additionally, the FAA has previously granted relieffrom 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).



### 5. Reasons WhyAn Exemption From The Requirements OfSection 91.121 Would Not Adversely Affect Safety.
The equivalent level ofsafety establishedby Section 91.121 will be maintainedbecause the altitude information ofthe DJI Inspire 1 U A will beprovided to the PIC via GPS equipment and a radio communications telemetry data link, which downlinks from the UAto the GCS for active monitoring ofthe flight path and altitude. This altitude information, combined with SchulhofMarketing Group, Inc.'s operation ofthe DJI Inspire 1 U A within visual line ofsight, at orbelow 400 feet AGL, will ensure a level ofsafety equivalent to Section 91.121. The altitude information will be generated by GPS equipment installed onboard the aircraft. Priorto each flight, a zero altitude initiationpoint is automatically establishedbythe UAS at ground level.
The FAA has previously granted relieffrom Section 91.121 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, 11112, 11136, 11138, 11150, 11153, 11156, 11157, 11158, 11159, 11160, 11161).


### 6. Reasons WhyAn Exemption FromThe Requirements OfSection 91.151(b) Would Not Adversely Affect Safety.
A grant ofthis exemption would ensure an equivalent level ofsafety establishedby 14 C.P.R. Section 91.151(b) as a result of(1) the technical specifications ofthe DJI Inspire 1 UAS; (2) the limitations onthe proposed flight operations; and (3) the location ofthe proposed flight operations. Accordingly, SchulhofMarketing Group, Inc. will ensure that it will safely operate the batterypowered DJI Inspire 1 U A during daylight hours in VFR conditions, with enoughbatterypowerto fly for a total duration of 13.5 minutes to the first point ofintended landing and, assuming normal cruising speed, to fly after that for at least 4.5 minutes. Here, as inExemptionNo. 11109, the technical specifications ofthe DJI Inspire 1 UAS;

24the limitations onthe proposed flight operations; and the location ofthe proposed operations, will ensure an equivalent level ofsafety established by 14 C.P.R. Section 91.151(b). Furthermore, safety will be ensured as the DJI Inspire 1UAS provides audible and visual warnings to the PIC at the GCS when the UA experiences low battery voltage, the first warning occurring at approximately 33% remaining batterypower, and again at approximately 10% remaining batterypower. At the critically low battery level, the DJI Inspire 1 UAS will descend and land automatically. Significantly, previous exemptions granted bythe FAA concerning Section 91.151 establish that safety is not adversely affected when the technical characteristics and operating limitations ofthe UAS are considered. Reliefhas been granted for manned aircraft to operate at less than the minimums prescribed in Section 91.151, including ExemptionNos. 2689, 5745, and 10650. Moreover, the FAAhas previously granted relieffrom Section 91.151 specific to UAS, in circumstances similar, in all material respects, to those presented herein (e.g. ExemptionNos. 8811, 10808, 10673, 11042, 11062,11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 11136, 11138, 11150, 11153, 11156, 11157, 11158, 11159, 11160, 11161).


### 7. Reasons WhyAn Exemption From The Requirements OfSections 91.405(a), 91.407(a)(l), 91409(a)(l) & 

### (a)(2), And 91.417(a) & 

### (b) Would Not Adversely Affect Safety.
In seeking this exemption, SchulhofMarketing Group, Inc. submits that the equivalent level ofsafety withregard to the regulatory maintenance and alteration requirements established by Sections 91.405(a), 91.407(a)(l), 91.409(a)(l) & (a)(2), and 91.417(a) & (b) will be met because SchulhofMarketing Group, Inc. will use trained technicians to perform maintenance, alterations, orpreventive maintenance on the UAS using the methods, techniques, andpractices prescribed inthe operating documents (i.e. Operations Manual, Monthly Maintenance Log, and DJI Inspire 1 Instruction Manual). Furthermore, Schulhof Marketing Group, Inc. will document and maintain all maintenance records for the DJI Inspire 1 UAS.
Since the DJI Inspire 1UAS will be inspected as prescribedbythe operating documents, SchulhofMarketing Group, Inc. will maintainthe equivalent level ofsafety established by Sections 91.405(a), 91.409(a)(1), and 91.409(a)(2). A copy ofthe DJI Inspire 1User Manual is attached hereto as Exhibit C and D; a copy ofthe DJI Inspire 1 UAS Maintenance LOG is attached hereto as Exhibit C. Likewise, the exemption sought will not adversely affect safetybecause SchulhofMarketing Group, Inc. will use trained technicians to perform maintenance, alterations orpreventive maintenance onthe UAS using the methods, techniques, and practices prescribedbythe operating documents. Furthermore, the exemption sought would maintain an equivalent level ofsafety established by Sections 91.407, 91.417(a) and 91.417(b), because all maintenance ofthe DJI Inspire 1 UAS will beperformedbytrained technicians. Maintenance will be documented and maintained utilizing the monthly maintenance log. Previous exemptions



### 25granted bythe FAA concerning Sections 91.405(a), 91.407(a)(l), 91.409(a)(l) & (a)(2), and 91.417(a) & (b) establish that safety is not adversely affected when the technical characteristics and operating limitations ofthe UAS are considered. In consideration of SchulhofMarketing Group, Inc. proposed operating limitations, the operating documents, and the technical aspects ofthe DJI Inspire 1UAS, SchulhofMarketing Group, Inc. submits that safety will not be adversely affected by granting exemption from 14 C.P.R. Sections 91.405(a), 91.407(a)(l) and (a)(2), 91.409(a)(2), and 91.417(a) and (b). The FAA has previously granted reliefspecific to UAS in circumstances similar, in all material respects, to those presented herein (e.g. ExemptionNos. 11062, 11063, 11064, 11065, 11066, 11067, 11080,11109,11110,11112,11136,11138,11150,11153,11156,11157,11158,11159, 11160,11161).


### 8. The FAA MayPrescribe Any Other Conditions For Safe Operation.
In accordance with Section 333 ofthe FAA Modernization and Reform Act of2012 (FMRA) and 14 C.P.R.§ 21.16 entitled Special Conditions, SchulhofMarketing Group, Inc. requests that the FAAprescribe special conditions for the intended operation ofthe DJI Inspire 1UAS, which contain such safety standards thatthe Administrator finds necessary to establish a level ofsafety equivalent to that established by 14 C.F.R. Part 21, Subpart H, and 14 C.F.R §§ 61.113(a) & (b), 91.7 (a), 91.121, 91.151(b), 91.405(a), 91.407(a)(l), 91.409(a)(l) & (a)(2), and 91.417(a) & (b). Such special conditions will permit safe operation ofthe UAs for the limitedpurpose ofconducting aerial video and photography over certain areas ofthe United States for compensation orhire. FMRA Section 333 sets forth the requirements for considering whether a UAS will create a hazard to users ofthe NAS or the public, or otherwise pose a threat to national security; and further, provides the authority for suchUAS to operate without airworthiness certification in accordance with any requirements that must be established for the safe operation ofthe UAS inthe NAS. Likewise, the Administrator mayprescribe special conditions pursuantto 14 C.P.R. § 21.16, for operation ofthe DJI Inspire 1UAS, since the airworthiness regulations of 14 C.P.R. Part 21 do not contain adequate or appropriate safety standards, due to the novel or unusual design features ofthe aircraft. Section 21.16, entitled Special Conditions, states the following:
Ifthe FAA finds that the airworthiness regulations ofthis subchapter do not contain adequate or appropriate safety standards for an aircraft, aircraft engine, orpropellerbecause ofa novel orunusual design feature ofthe aircraft, aircraft engine orpropeller, he prescribes special conditions and amendments thereto for the product. The special conditions are issued in accordance with Part 11 ofthis chapter and contain such safety standards for the aircraft, aircraft engine orpropeller as the FAA finds necessary to establish a level ofsafety equivalent to that established inthe regulations.
See 14 C.P.R. §21.16. Therefore, in accordance with FMRA Section 333 and 14 C.P.R.§ 21.16, the FAAmay prescribe special conditions for SchulhofMarketing Group, Inc. intended operation ofthe DJI Inspire 1

26UAS, which contain such safety standards that the Administrator finds necessaryto establish a level ofsafety 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)(l), 91.409(a)(l) & (a)(2), and 91.417(a) & (b).

27

### F. A Summary That Can Be Published In The Federal Register, stating:

The Rules From Which SchulhofMarketing Group, Inc. Seeks Exemption: Schulhof Marketing Group, Inc. seeks exemption from the requirements of 14 C.F.R Sections 21 SubpartH, 61.113(a)&(b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(l), 91.409(a)(1) & (a)(2), and91.417(a) & (b).

A Brief Description Of The Nature Of The Exemptions Schulhof Marketing Group, Inc. Seeks:
This exemption willpermitSchulhof Marketing Group, Inc. to commercially operate an UnmannedAircraftSystem (UAS)for thepurpose of conducting aerial video and photography over certain areas of the United States. AnyAdditional Information, Views, Or Arguments Available To Support Schulhof Marketing Group, Inc. Request.
This Petition is made pursuant to the FAA Modernization and Reform Act of2012 (FMRA) Section 333, which directs the Secretary ofTransportation to determine ifcertain UAS may operate safely inthe NAS. As such, SchulhofMarketing Group, Inc.'s request for exemption maybe grantedpursuant to the authority ofFMRA Section 333 and 14 C.F.R. Part 11, as set forth above. FMRA Section 333 sets forth the requirements for considering whether a UAS will create a hazard to users ofthe NAS orthe 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, SchulhofMarketing Group, Inc. will operate the DJI Inspire 1UAS safely inthe NAS, without creating a hazard to users ofthe NAS, orthe public, or otherwise pose a threat to national security.

28CONCLUSION
As set forth herein, SchulhofMarketing Group, Inc. seeks an exemptionpursuant to 14 C.F.R. § 11.61 and Section 333 ofthe FAA Modernization and Reform Act of2012 (FMRA), which will permit safe operation ofthe DJI Inspire 1 UAS commercially, without an airworthiness certificate, for the limitedpurpose ofconducting aerial video and photography over certain areas ofthe United States. By granting this Petition, the FAA Administrator will be fulfilling the Congressional mandate ofthe FAAModernization and Reform Act of2012, while also advancing the interests ofthepublic, by allowing Schulhof Marketing Group, Inc. to safely, efficiently, and economically operate the DJI Inspire 1 UASs commerciallywithin the NAS.
In accordance withthe Federal Aviation Regulations and the FAA Modernization and Reform Act of2012, Section 333, SchulhofMarketing Group, Inc. respectfully requests that the Administrator grant this Petition for an exemption from the requirements of 14 C.F.R Sections 21 Subpart H, 61.113(a) & (b), 91.7(a), 91.121,91.151 (b), 91.405(a), 91.407(a)(l), 91.409(a)(1) & (a)(2), and 91.417(a) & (b), andpermit SchulhofMarketing Group, Inc. to operate the DJI Inspire 1 UASs commercially for the purpose ofconducting aerial video and photography over certain areas ofthe United States.
Dated: June 11, 2015

SchulhofMarketing Group, Inc. 11216 Fall CreekRd, Suite 100 Indianapolis, IN 46256



### 29Appendices:
A - DJI Inspire 1 Specifications Data Sheet
APPENDIX-A
DJI INSPIRE 1 TECHNICAL SPECIFICATIONS SchulhofMarketing Group, Inc. onlyutilizes safe and reliable UASs. DJI is an industry leader in small UAS production. DJI UASs are loaded with ground breaking software enabling the user to set parameters which will not allow flight into controlled airspace. Parameters can also be set to limit flight to no higher than a predetermined and set altitude as well as limit 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)
2.2 DJI Inspire 1 2.2.1 Aircraft 2.2.1.1 Model

- T600 2.2.1.2 Weight (Battery Included)- 61bs 7.5291 oz (2935g) 2.2.1.3 Hovering Accuracy (GPS Mode)- Vertical: 0.5m; Horizontal: 2.5m 2.2.1.4 Max Angular Velocity- Pitch: 3000/s; Yaw: 1500/s 2.2.1.5 MaxTilt Angle

- 350 2.2.1.6 Max Ascent Speed- 5m/s 2.2.1.7 Max Descent Speed- 4m/s 2.2.1.8 Max Speed- 22m/s (ATTI mode, no wind- NOT RECOMMENDED) 2.2.1.9 Max Flight Altitude

- 4500m 2.2.1.10Max Wind Resistance

- 1 0 ml s 2.2.1.11 Max Flight Time

- Approximately 18 minutes 2.2.1.12MotorModel- DJI 3510 2.2.1.13Propeller Model- DJI 1345 2.2.1.140perating Temperature Range- HOF to 1040F (-lOOC to 400C) 2.2.1.15Dimensions- 17 l/4?'x 17 W' x 12" 2.2.2 Gimbal 2.2.2.1 Model

- ZENMUSE X3 2.2.22 Output Power (with camera)- Static: 9W; In Motion: 11W 2.2.2.3 Operating Current- Static: 750mA; In Motion: 900mA 2.2.2.4 Angular Vibration Range

- ±0.030 2.2.2.5 Mounting- Detachable 2.2.2.6 Controllable Range- Pitch: -900to +300; Pan: ±3200 2.2.2.7 Mechanical Range- Pitch: -1250to 450; Pan: ±3300 2.2.2.8 Max Controllable Speed

- Pitch: 1200/s; Pan: 1800/s 2.2.3 Camera 2.2.3.1 Name- X3 2.2.3.2 Model-FC350 2.2.3.3 Total Pixels- 12.76M 2.2.3.4 Effective Pixels- 12.4M 2.2.3.5 Image Max Size- 4000x3000 2.2.3.6 ISO Range- 100-3200



### 30

### 2.2.3.7 Field ofView-940 2.2.3.8 CMOS- Sony EXMOR 1/2.3" 2.2.3.9 HD Video Recording

- UHD(4K): 4096x2160p24/25, 3840x2160p24/25/30; FHD: 1920xl080p24/25/30/48/50/60; HD: 1280x720p24/25/30/48/50/60 2.2.3.100peratingTemperature Range- 320F- 1040F (OOC- 400C) 2.2.4 Transmitter 2.2.4.1 Name- Cl 2.2.4.2 Operating Frequency- 5.728-5.850GHz; 2.400-2.483GHz 2.2.4.3 Communicating Distance (unobstructed)

- 2000m 2.2.4.4 Output Power- 9W 2.2.4.5 Operating Temperature Range- 140F to 1040F (-lOOC to 400C) 2.2.4.6 Battery

- 600mAh LiPo 2S
B

- DJI Inspire 1User Manual



### 31APPENDIX-B
DJI INSPIRE 1 USERMANUAL http://download.dji-innovations.com/downloads/inspire _lien/Inspire _1_User_ Manual_ vl.2 _en.pdf

32C

- DJI Inspire 1 Maintenance Log

APPENDIX -C
DJI INSPIRE 1 Maintenance Log

Monthly Maintenance Log

Issue Description & Date Issue Date Issue Maintenance UAS# Discovered Addressed Concluded Maintenance Performed By:

Software Updates Airframe Engines Propellers Camera Gimbal Landing Gear Vibration Dampening Other:

33