U.S. Department of Transportation

Docket Management System 1200 New Jersey Avenue, SE Washington, D.C. 20590

Aerial Media Productions Anthony McCurdy and Matt Arch 75 Holly Glen Lane Cape May Court House NJ 08210

BASIS FOR PETITION

Petitioner, Aerial Media Productions (hereinafter “Aerial Media”) , 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 Syst ems, hereby petitions the Administrator to commercially operate the DJI Inspire 1 and DJI Phantom 3 , in the National Airspace System (NAS), and for an exe mption from the requirements of :

14 C.F.R §§ 61.113(a) & (b) 14 CFR 45.23(b) 91.7(a), 91.109,

91.119
, 91.121,

91.151
, 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91 .417(a) & (b)

Name and Address of t he Petitioner : The name and address of the Petitioner and Point of Contact is:

AERIAL MEDIA PRODUCTIONS

ATTN: ANTHONY McCURDY

75 HOLLY GLEN LANE

CAPE MAY COURT HOUSE NJ 08210

CELL: 609

- 332

- 1423 EMAIL: sales@aerialmedianj .comPREFACE:

The Federal Aviation Act expressly grants the FAA the authority to issue exemptions. This statutory authority by its terms includes exempting civil aircraft,
as the t erm is defined under §40101 of the Act, that includes UAS, from the requirement that all civil aircraft must have a current airworthiness certificate.

The Administrator may grant an exemption from a requirement of a regulation prescribed under subsection (a) or (b) of this section or any sections 44702

- 44716 of this title if the Administrator finds the exemption in the public interest. 49 U.S.C. §44701(f) See also 49 USC §44711(a); 49 USC §44704; 14 CFR §91.203 (a) (1).

Aerial Media proposes to use two UAS: one (1) DJI INSPIRE 1 and one (1) DJI

PHANTOM 3 for the following purposes:

 Aerial photography and/or videography for public and/or private use including real estate, architecture, land surveying, engineering and other related professional activities

.

 Aerial photography , videography and/or providing live video feed for public and/or private use including television, public events, videography and news gathering.

 Aerial inspection/photography of residential/commercial structures under
contract with the owners or local government authority.

 Aerial video/photography or providing live video feed (so as long as all other parameters are met contained herein) to assist with search and rescue operations in cases of an emergency or natural disaster only when
th e local authorities or government has requested it by contract or
donation.

 The ability to offer training to persons individually or belonging to both private and/or public organizations that have interests in the use and application of a UAS for the purpo se of the safe operation of a UAS to enhance the safety of the National Airspace System (NAS) as well as for the protection of the persons and property.

Both UAS are quadcopters with four rotors and four motors and are only capable
of vertical take

- off an d landing. These UAS weigh less than 55 pounds including payload. The Inspire 1 can reach a maximum air speed of 49 mph (22meters/second) in non

- GPS mode with perfect flight conditions. The Phantom 3

can reach a maximum airspeed of 36 mph (16 meters/sec ond) in non

- GPS mode with similarly perfect flight conditions. NOTE: Aerial Media does not fly either

UAS in non

- GPS mode or anywhere near top speed. Both can hover and move simultaneously in both the vertical and horizontal plane. Both are also equipp ed
with GPS and auto

- return function to the predetermined safe landing area as well as allowing reading of magnetic interference that can cause loss of GPS signal.

Aerial Media w ill operate both UAS only in visual line of sight and in such a

manner as to ensure the UAS will “not create a hazard to users of the national airspace system or the public.” (Reform Act Section 333 (b)).

This exemption application is expressly submitted to fulfill Congress’ goal in passing Section 333(a) through (c) of the Reform Act. This law directs the Secretary of Transportation to consider whether certain unmanned aircraft systems may operate safely in the national airspace system (NAS) before completion of the rule making required under Section 333 of the Reform Act. In making this determination, the Secretary is required to determine which types of

UAS do not create a hazard to users of the NAS or the public or pose a threat to national security in light of the following:

• The UAS’s size, weight, speed and operational capability; • Operation of the UAS in close proximity to airports and populated areas;
and • Operation of the UAS within visual line of sight of the operator.

Reform Act § 333 (a). Secretary determines that such vehicles “may operate safely in the national airspace system, the Secretary shall establish requirements for the safe operation of such aircraft in the national airspace system.” Id. §333(c).

The Federal Aviation Act expressly grants the FAA the authority to issue exemptions. This statutory authority by its terms includes exempting civil aircraft, as the term is defined under §40101 of the Act, that includes UAS, from the requirement that all civil aircraft must have a current airworthiness certificate.

The Administrator may grant an exemption from a requirement of a regulation prescribed under subsection (a) or (b) of this section or any sections 44702

-44716 of this title if the Administrator finds the exemption in the public interest.

49 U.S.C. §44701(f) See also 49 USC §4 4711(a); 49 USC §44704; 14 CFR §91.203 (a) (1).

RELIEF OVERVIEW : Given the small size of the UAS involved and the restricted sterile environment within which they will operate, the applicant falls squarely within that zone of safety (an equivalent level o f safety) in which Congress envisioned that the FAA must, by exemption, allow commercial operations of UASs to commence immediately. Also due to the size of the UAS and the restricted areas in which the relevant UAS will operate, approval of the applicatio n presents no national security issue.

Given the clear direction in Section 333 of the Reform Act, the authority contained in the Federal Aviation Act, as amended; the strong equivalent level of safety surrounding the proposed operations, and the signific ant public benefit, including enhanced safety, reduction in environmental impacts, including reduced emissions associated with allowing UAS for aerial inspections, surve ying and photography and vide ography, the grant of the requested exemptions is in the

p ublic interest. Accordingly, the applicant respectfully requests that the FAA grant the requested exemption without delay.

AIRCRAFT AND EQUIVALENT LEVEL OF SAFETY : Aerial Media proposes that the exemption requested herein apply to civil aircraft
that have the characteristics and that operate with the limitations listed herein. These limitations provide for at least an equivalent or even higher level of safety to operations under the current regulatory structure because the proposed operations represent a s afety enhancement to the already safe aerial inspections,

surve ying and photography and vide ography operations conducted with
conventional aircraft.

These limitations and conditions to which Aerial Media agrees to be bound when conducting commercial opera tions under an FAA issued exemption include:

1. Both UAS will weigh less than 55 lbs. 2. Flights will be operated within visual line of sight of a pilot and/or observer. 3. Maximum total flight time for ea ch operational flight will be 20 minutes or less.Flights will be terminated at 25% battery power reserve s hould that occur prior to

the 20 minute limit. 4. Flights will be operated at an altitu de of no more than 400 feet AGL. 5. Minimum crew for each operation will consist of the UAS Pilot and the Visual

O bserver.

6 . The UAS will only operate within a confined sterile closed

- set area with a set safety perimeter, the boundaries of which will be determined by the UAS PIC
based on the site

- specific activities and speed of the UAS required for the operation, and coordinated with the jurisdictional FAA FSDO and local government officials as applicable.

7

. Visual Observer and PIC will at all times be able t o communicate by voice and/or 2

- way hands

- free radio or wireless communication system

. 8 . Written and/or or al permission from the relevant property holders will be
obtained.

9 . If applicable, all required permissions and permits will be obtained from territorial, state, county or city jurisdictions, including local law enforcements, fire, or other appropriate g overnmental agencies.

10 . If the UAS loses communications or loses its GPS signal, the UAS will have the capability to return to a pre

- determined safe location and land safely.

11 . The UAS will have the capability to abort flight in case of unpredicted
obs tacles or emergencies.

14 C.F.R. Part 21, Subpart H: Airworthiness Certificates 14 C.F.R. §91.203 (a) (1) Subpart H, entitled Airworthiness Certificates, establishes the procedural requirements for the issuance of airworthiness certificates as required by FAR §91.203 (a) (1). Given the size and limited operating area associated with the aircraft to be utilized by the Applicant, an exemption from Part 21 Subpart H meets the requirements of an equivalent level of safety under Part 11 and Section
333 of the R eform Act. The Federal Aviation Act (49 U.S.C.§44701 (f)) and Section 333 of the Reform Act both authorize the FAA to exempt aircraft from the requirement for an airworthiness certificate, upon consideration of the size, weight, speed, operational capabili ty, and proximity to airports and populated areas of the particular UAS. In all cases, an analysis of these criteria demonstrates that the UAS operated without an airworthiness certificate, in the restricted environment and under the conditions proposed wi ll be at least as safe, or safer, than a conventional aircraft (fixed wing or rotorcraft) operating with an airworthiness certificate without the restrictions and conditions proposed. Inconsideration of the speed, weight, size, and limited operating area assoc iated

with the UAS and its operation, Aerial Media’s operation of the DJI Inspire 1 and
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, Subpar t H.

Accordingly, Aerial Media 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
certifi cate. Aeri al Media submits that the requested relief is proper since an equivalent level of safety will be ensured. Aerial Media will use experienced personnel or technicians as needed to perform maintenance, alterations, or

pr eventive maintenance on the UAS using t he methods, techniques, and practices prescribed in the operating documents (i.e., Monthly Maintenance Log, and DJI Inspire 1 and DJI Phantom 3 Instruction Manual s ). Furthermore, Aerial Media will
document and maintain all maintenance records for the DJI I nspire 1 and DJI
Phantom 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 Aerial Media to the extent necessary to allow a Pilot in Command (PIC) to m eet or exceed the described requirements of operations set by manufacturer, and who has demonstrated, that the PIC is able to safely operate the DJI Inspire 1 and DJI
Phantom 3 UAS in a manner consistent with this exemption, including evasive and emergency maneuvers and maintaining appropriate distances from people, vessels, vehicles and structures.

Aerial Media seeks relief from Section 91.7(a), entitled Civil aircraft airwor thiness, because the DJI Inspire 1 and DJI Phantom 3 UAS do not require an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H. As such, Aerial Media
submits that t he PIC will ensure that the DJI Inspire 1 and/or DJI Phantom 3 UAS is in an airworthy condition, prior to every flight, by determining that the UAS are in compliance with the operating documents (i.e., Monthly Maintenance Log, and DJI Inspire 1 and DJI Phantom 3 Instruction Manual s ), and that the aircraft are in a
condition for safe flight.Aerial Media also seeks an exemption from the requi rements of Section 91.109,

titled Flight Instruction. This regulation provides that "No person may operate a civil aircraft that is being used for flight instruction unless that aircraf t has fully functioning dual controls." The controls for a UAS do not currently have a set of fully functioning dual controls. If a UAS pilot is being trained, the pilot performing the training would be directly supervising and could take over the controls from the pilot in training if the need arose. This would be similar to the technique of a
"throw

- over type" control wheel in some fixed wing aircraft. This technique
meets the intent 91 .109 and provides an equivalent level of safety. In addition,
any tr aining would be performed in a des ignated RC aircraft flying area or similar area with no spectators or other people in the area and following all safety guidelines to ensure the safety of the pilot, observer and trainee(s).

In addition, Aerial Media requ ests an exemption from the re quirements of Section 91.119, titled Minimum safe altitudes. This regulation provides that over sparsely populated areas the aircraft cannot be operated closer than 500 feet to any person, vessel, vehicle, or structure. Since the proposed uses would include flights involving photography , videography or survey of persons, vessels, vehicles or

structures

, it would be necessary to operate closer than 500 feet to the items listed. Operations will only be flown over property or pers ons where permission has been obtained, and careful pre

- planning has been performed including taking weather conditions and wind speeds into account, identifying potential obstacles or threats and aggressive use of the visual safety observer to maintain sa fe distances and flight paths . Further, UAS aircraft operate at a very slow airspeed, and a low mass, and do not need as much space to operate safely, as outlined in

91.119. Aerial Media asserts that the slower speed, smaller mass and careful pre

planning would provide an equivalent level of safety. Furthermore, Aerial Media can place warning signs, barriers and/or structures to sufficiently protect nonparticipating person from the UA S or debris in the event of an accident.

Aerial Media also seeks an exemp tion from the re quirements of Section 91.121, titled Altimeter Settings, as the DJI Inspire 1 and DJI Phantom 3 will not have a typical barometric altimeter onboard. However, altitude information of the DJI Inspire 1 and DJI Phantom 3 will be provided to t he PIC via Global Positioning System (GPS) equipment and radio communications telemetry data link, which
downlinks from the UA S to the GCS for active monitoring of the flight path. This altitude information, combined with Aerial Media’s operation of the DJ I Inspire 1or DJI Phantom 3 UAS within visual line of sight, at or below 4 00 feet AGL, will

ensure a level of safety equivalent to Section 91.121.

Additionally, Aerial Media seeks an exemption from the requirements of Section

91.151 , entitled Fuel requirements for flight in VFR conditions. This regulation provides that no person may begin a flight in an airplane under day

- VFR conditions unless there is enough fuel to fly to the first point of intended landing and to fly after t hat fo r at least 30 minutes, th e intention of this paragraph being to provide a reasonable reserve of energy to plan for a safe landing should there
be a delay in landing. Given the close proximity to the ground station, the ability
for the UAS to land in a very small space and the built in energy level monitoring
of the UAS there is a resulting equivalent level of safety if the flight is planned to
be completed with 20% battery energy remaining. Aerial Media request s an exemption to the word "fuel" and ask for a n equivalent interpretation with the word "energy".

REASONS FOR RELIEF FROM THE LISTED SECTIONS ABOVE:

1. Section 61.113(a) & b). Relief from Section 61.113(a) and (b) entitled Private pilot privileges and limitations: Pilot in command, is requested to the extent necessary to allow a PIC meet all requirements as described in the DJI Inspire 1 owner’s manual to conduct the proposed UAS flight opera tions for compensation or hire. This relief is requested since the limitations set forth in Section 61.113(a) and (b) state that a private pilot may, for compensation or hire, act as PIC of an aircraft in connection with any business or employment if: (1) The flight is only incidental to that
b usiness or employment; and (2) t he aircraft does not carry passengers or property for compensation or hire.

As set forth more fully below, Aerial Media submits that an equivalent level of safety will be maintained because no PIC will be allowed to operate the DJI Inspire

1 or DJI Phant om 3 UAS unless that PIC has demonstrated that the PIC is able to safely operate either the DJI Inspire 1 or DJI Phantom 3 UAS in a manner consistent with the operations specifications as described in this exemption, including evasive and emergency maneuve rs, as well as maintaining appropriate distances from people, vessels, vehicles and structures.Further more , Aerial Media submits that all flights of the DJI Inspire 1 or DJI

Phantom 3 UAS, conducted by the PIC pursuant to the grant of this Petition: (1)
will be incidental to Aerial Media’s business; and (2) will not carry passengers or
property for compensation or hire.

2. 91.7(a). Relief from Section 91.7(a) entitled Civil aircraft airworthiness, is requested to the extent required to allow Aerial Medi a to determine that the DJI Inspire 1 and 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 Monthly Maintenance Log, and DJI Inspire 1 and DJI Phantom 3 Inst ruction Manual s ).

Aerial Media seeks the requested relief because the DJI Inspire 1 and DJI Phantom
3 UAS do not require an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H. Therefore, Aerial Media will ensure that the DJI Inspir e 1 and DJI
Phantom 3 UAS are in airworthy condition based upon its compliance with the operating documents (i.e., the Monthly Maintenance Log, and DJI Inspire 1 and
DJI Phantom 3 Instruction Manual s ) prior to every flight, and further, determine
that the UAS are in condition for safe flight, as stated in the conditions and
limitations below.

3. 91.121. Relief from Section 91.121, entitled Altimeter settings, may be required to allow flight operations of the DJI Inspire 1 and DJI Phantom 3 UAS, which utilize a barometric pressure sensor, GPS equipment, and a radio communications telemetry data link to downlink altitude information from the UA to the PIC at the ground control station (GCS). Since the FAA requires that any altitude informatio n concerning UAS operations be reported to air traffic control (ATC) in feet above ground level (AGL), Aerial Media seeks the requested relief because the DJI Inspire 1 and 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 operations, relief from 14 CFR 91.121 is sought to the extent necessary to comply with the applicable conditions
and limitations stated below. As more fully set forth herein, an equivalent level of safety will be maintained since the DJI Inspire 1 and DJI Phantom 3 UA S are equipped with a barometric pressure sensor and GPS equipment, whichautomatically ensures that a ground level pressure setting will be established

prior to each flight, and provides the PIC with altitude information of the UA S on the heads

- up display of the GCS.

4. 91.151(b). Relief from Section 91.151(b) entitled Fuel requirements for flight in VFR

c onditions, is requested to the extent required to allow flights of the battery powered DJI Inspire 1 and DJI Phantom 3 UA S during daylight hours in visual meteorological conditions (VMC), under visual flight rules ( VFR), for flights planned to be completed with 20% battery energy remaining. Aerial Media seeks the requested relief because without an exemption from Section 91.151(b), the flight time duration of the battery powered DJI Inspire 1 and DJI Phantom 3 UA S will severely constrain the practicality of any aerial video or still photo flight operations that Aerial Media proposes to conduct pursuant to this Petition. Significantly, as set forth below, the technical specifications of the DJI Inspire 1
and DJI Phantom 3 UAS, the DJI Inspire 1 and DJI Phant om 3 operating documents, and Aerial Media’s proposed operating limitation s, ensure that Aerial
Media will safely operate the battery powered DJI Inspire 1 and DJI Phantom 3

UA S during daylight hours in visual meteorological conditions (VMC), under visual flight rules (VFR), with flights planned to be completed with 20% battery energy remaining.

14 CFR 45.23(b) Marking of the Aircraft; Applicable codes of Federal Regulation requ ire aircraft to be marked according to certain specifications. Aerial Media UAS are, by definition, unmanned. They therefore do not have a cabin, cockpit or pilot station on which to mark certain words or phrases. Further, two inch lettering is difficult t o place on such small
aircraft. The FAA has previously issued exempti ons to this regulation through Exemption s No 10167 and 10700

.

5. 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), And 91.417(a) & (b). Since Sections 91.405(a), 91.407(a)(1), 91.409(a)( 1) & (a)(2), and 91.417(a) & (b) only apply to aircraft with an airworthiness certificate, Aerial Media requests relief from these Sections because the DJI Inspire 1 and DJI Phantom 3 UAS do not require airworthiness certificates. As set forth more fully b elow, the DJI Inspire 1
and DJI Phantom 3 UAS meet the conditions of FMRA Section 333 for operationwithout an airworthiness certificate. Accordingly Aerial Media will use trained

technicians to perform maintenance, alterations, or pr eventive maintenance o n the UAS using the methods, techniques, and practices prescribed in the UAS operating documents (i.e., the Monthly Maintenance Log, and DJI Inspire 1 and
DJI Phantom 3 Instruction Manual s ). Furthermore, Aerial Media will document
and maintain all maintena nce records for the DJI Inspire 1 and DJI Phantom 3

UAS.

PUBLIC BENEFIT TO GRANTING RELIEF UNDER PETITION: Granting the present Petition will further the public interest by allowing Aerial
Media to safely, efficiently, and economically perform aerial photography, videography , surveys and inspections of real estate, construction sites, undeveloped natural areas, and other locations where such work is appropri ate and necessary, in support of other businesses attempts to develop and grow their opportuniti es for commerce . This exemption application is expressly submitted to fulfill Congress’ goal in passing Section 333(a) through (c) of the Reform Act. This law directs the Secretary of Transportation to consider whether certain unmanned aircraft systems may operate safely in the national airspace system (NAS) before completion of the rule making required under Section 332 of the Reform Act. In making this determination, the Secretary is required to determine which types of UAS do not create a hazard to users of the NAS or the public or pose a threat to national security in light of the following: • The UAS’s size, weight, speed and operational capability; • Operation of the UAS in close proximity to airports and populated areas;
and • Operation of the UAS wit hin visual line of sight of the operator.
Reform Act
§ 333 (a). Lastly, if the Secretary determines that such vehicles “may operate safely in the national airspace system, the Secretary shall establish requirements for the safe operation of such aircraft in the national airspace system.” Id. §333(c).

Given the small size of the UAS involved and th e nature of their intended use, the applicant falls squarely within that zone of safety (an equivalent level of safety) in which Congress envisioned that the FAA must, by exemption, allow commercial operations of UASs to commence immediately. Also due to the size of the UAS
and the ir intended use, approval of the application presents no national securityissue. Given the clear direction in Section 333 of the Refor m Act, the authority

contained in the Federal Aviation Act, as amended; the strong equivalent level of safety surrounding the proposed operations, and the significant public benefit, including enhanced safety, reduction in environmental impacts, including reduced emissions associated with allowing UASs for aerial photography and videography

, the grant of the requested exemptions is in the public interest.

Accordingly, the applicant respectfully requests that the FAA grant the requested exemption without d elay.

REASONS FOR PUBLIC BENEFIT: 1. The Public Will Benefit From Decreased Congestion Of The NAS. The DJI Insp ire 1 and DJI Phantom 3 UA S 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 perform such aerial photography and videography , an exemption allowing the use of a DJI Inspire 1 and 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.

Furthermore, by reducing the number of manned aircraft operating in the NAS, congestion around airports caused by arriving and departing aircraft will be reduced. The DJI Inspire 1 and DJI Phantom 3 UA S do not require an airport to
takeoff or land. Likewise, a reduction of manned aircraft conducting aerial video and photography missions would result in fewer aircra ft that must be handled by air traffic control during the ground, takeoff, departure, arrival, and landing phases of flight operations.

2. The Public Will Benefit From The Safety And Efficiency Of The DJI Inspire 1 and
DJI Phantom 3 UAS. Conducting aeria l photography and videography with the DJI Inspire 1 and DJI
Phantom 3 UAS, instead of manned aircraft, will greatly benefit the public by drastically reducing the levels of air and noise pollution generated during

tra ditional aerial photography and videog raphy flight operations. By using battery power and electric motors, the DJI Inspire 1 and DJI Phantom 3 UAS produce no air pollution, and are the most viable environmentally conscious alternative to the cabin class, six cylinder internal combustion engine aircraft that are typicallyutilized for aerial video and photography, while burning approximately 20

- 30

gallons per hour of leaded aviation fuel. The DJI Inspire 1 and DJI Phantom 3 U AS

, while reducing the carbon footprint of aerial photography and videography, also
eliminate noise pollution, as the UAS are propelled by battery powered electric motors, rather than an internal combustion engine

.

By using the DJI Inspire 1 and DJI Phantom 3 UA S to perform aerial photography and videography , the substantial risk to life and property in the air and on the ground usually associated with traditional manned air craft flight operations will
be substan tially reduced or completely eliminated. Aside from the lack of flight
crew members located on

- board the aircraft, the DJI Inspire 1 and DJI Phantom 3

UA S (weighing respectively about 6.5 pounds and 2.8 pounds with diagonal lengths of about 23 inches and c arrying no fuel or other combustibles 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 p ounds with a wingspan of approximately 42 feet, a length of 34 feet, and a fuel capacity of 180 gallons).

3. Performing Aerial Photography , Videography , Surveys

, Inspections, and Other Operations With The DJI Inspire 1 and DJI Phantom 3 UAS Will Benefit The Economy. In addition to being safe and efficient, the DJI Inspire 1 and DJI Phantom 3 UAS are also an economical alternative to using manned aircraft to conduct similar aerial operations. As such, operation of the DJI Inspire 1 and DJI Phantom 3 UAS

w ill allow U.S.

- based companies, like Aerial Media, to remain competitive and contribute to growth of the U.S. economy. Specifically, with the rising cost of aviation fuel and the Environmental Protection Agency (“EPA”) regulatory actions phasing out leaded aviation fuels, U.S. owned and operated companies must adopt new and alternative technology in order to remain competitive. Operating the battery powered DJI Inspire 1 and DJI Phantom 3 UAS is one such technology that not only allows companies greater ope rational flexibility compared to manned aircraft, but provides such flexibility without the high operational cost of a traditional manned aircraft. By operating the DJI Inspire 1 and DJI Phantom 3 UAS, companies such as Aerial Media 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 Inspire 1 andDJI Phantom 3 UAS, provides a stable workforce that increases consumer

spending; improves local, state, and federal tax revenues; and allows companies to invest in research and development in order to remain competitive both in the
United States and abroad.

4. There Are No Privacy Issues. Similar to the manned aerial acquisition flight operations that have been conducted for decades, Aerial Media’s proposed operation of the DJI Inspire 1 and
DJI Phantom 3 UAS will not implicate any privacy issues. Specifica lly, the DJI Inspire 1 and DJI Phantom 3 UAS will be operated only in compliance with operating documents (i.e., the Aerial Media Standard Operating Procedures, the Monthly Maintenance Log, and DJI Inspire 1 and DJI Phantom 3 Instruction
Manual s) which require 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.F.R. § 91.119.

REASONS WHY GRANTING THE EXEMPTION WOULD NOT ADV ERSELY EFFECT

SAFETY: Reasons Why The DJI Inspire 1 and DJI Phantom 3 UA S 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 u nmanned aircraft and its operation, Aerial Media operation of the DJI Inspire 1 and DJI Phantom 3 UAS meet the conditions of FMRA Section 333, and will not require an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H. In seeking thi s exemption, Aerial Media submits that the DJI Inspire 1
and DJI Phantom 3 UAS can operate safely in the NAS pursuant to FMRA Sect ion 333, as demonstrated by the characteristics of the DJI Inspire 1 and DJI Phantom 3 UAS. Both UAS are designed to hover and /or return to a safe home point in the
event of loss of the control link with the GCS.

During all flights of either the DJI Inspire 1 or DJI Phantom 3 UAS, the PIC will be assisted by a visual safety observer to maintain safe visual line of sight tracking and control of the UAS. All flights will be conducted solely for the purpose of performing aerial photography, videography, surveys and inspections, not to carry passengers or cargo for hire.Due to the design of the DJI Inspire 1 and DJI Phantom 3 UAS, neither UAS is able

to exceed the maximum allowed airspeed under prior FAA exemptions. T he UA may not be flown at an indicated airspeed exceeding 45 knots. Neither UAS reaches the 55 pound threshold since both weigh under 10 pounds including battery and camera payload. The maximum operating altitude is set at 400 feet in the navigation software for both UAS and the software provides both a visual and audio warning regarding the approaching maximum altitude.

PERSONAL STATEMENTS AND BACKGROUND: Anthony McCurdy and Matt Arch are partners in Superhero Media LLC, a New Jersey veteran

- owned limited liability company operating as Aerial Media Productions. Both partners are public school teachers pursuing a drea m of establishing a seasonal business combining their interests, experience and talent in photography, videography and RC aircraft. Located in the southern tip of New Jersey, Aerial Media operates mostly in rural and suburban areas and occasionally (if they are lucky) by the beach.

As a company, Aer ial Media has both UAS insurance through Costello Aviation Insurance and commercial liability through Farmers Insurance. M att Arch has more recent experience with RC aircraft and is an excellent pilot while Anthony McCurdy typically acts as visual safety observer, though Anthony is training to be the main pilot on the Phantom 3. Matt Arch has over 200 hours of flight time recreationally on both the DJI Phantom and Inspire 1 craft and Anthony McCurdy
has over 50 hours on the DJI Phantom series. While both hold driver’s licenses, and Anthony McCurdy has driven everything from a Suzuki 450E to an M113 APC,

n either partner is a licensed pilot nor are either interested in actually flying a small aircraft, but they are investigating obtaining ground training an d simulator training to expand on their experience and capabilities as UAS pilots and are willing to take additional coursework and pay licensure fees to be able to operate their UAS commercially

. The main focus for both pilots is safety during flight

ope rations, both for themselves and others as well as their equipment and others’ property. From a practical perspective, neither partner wants to endanger the almost $6,000 they have invested in their UAS, cameras and gear. Both are very
familiar with the DJI Operator Manuals for both the DJI Inspire 1 and the DJI Phantom 3 and work hard to stay on top of developments in the industry as well as how UAS are being used in the community.They have already met with local police and municipal code inspectors regarding

how UAS could be valuable in promoting public safety and ensuring compliance with local conservation and land use ordinances. In addition, they have inspired some of their middle school students to purchase their own small UAS to fly as hobbyist s and even to express an interest in engineering and technological development as a potential career. Obtaining this exemption will be a major step forward in making this dream a reality.

Respectfully submitted,

Anthony McCurdy
Aerial Media Productions