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

IN THE MATTER OF THE PETITION FOREXEMPTION OF: Brent K Baker

FORANEXEMPTION SEEKINGRELIEF FROM THE REQUIREMENTS OF TITLE 14 OF THE CODE OF FEDERAL REGULATIONS 14 C.F.R**~~** 61.23(a). 61.101(34) 61.113(a) & (b). 61.315 (a). 91.7(a). 91.119 (c). 91.119 (c). 91.121. 91.151(b), 91.405(a). 91.407(a)(l). 91.409(a)(l) & (a)(2). and 91.417(a) & (b). CONCERNING COMMERCIAL OPERATION OF DJI PHANTOM 3VISION+ AND DJI INSPIRE 1UNMANNED AIRCRAFT SYSTEMS PURSUANT TO SECTION 333 OF THE FAAMODERNIZATION AND REFORM ACT OF 2012

Submitted on June 2, 2015 /

Brent K Baker 4176 Maple St. Chino, CA. 91710 909-703-0225 thebrent1Sl@gmail.corn (PUBLIC LAW 112-95)

### ofContents GLOSSARY OF ABBREVIATIONS

.................................................................................................................. 2 SUMMARY

......................................................................................................................................................... 3 INTRODUCTION AND INTERESTS OF THE PETITIONER

.......................................................................... 3 BACKGROUND

.................................................................................................................................................. 3 BASIS FORPETITION

....................................................................................................................................... 3 Name And Address OfThe Petitioner

.................................................................................................................. 5 The Specific Sections Of 14 C.F.R. From WhichApplicant Seeks Exemption

.................................................... 5 The Extent OfReliefApplicant Seeks And The Reason Applicant Seeks The Relief.

......................................... 7 The Reasons Why Granting Applicant Request Would Be In The Public Interest; That Is, HowIt Would Benefit The Public As A Whole

........................................................................................................................................ 9 The Reasons Why Granting The Exemption Would NotAdversely Affect Safety, Or How The Exemption Would Provide A Level OfSafetyAt Least Equal To That ProvidedByThe Rule From WhichApplicant Seeks Exemption

.......................................................................................................................................................... 10 CONCLUSION

.................................................................................................................................................. 17



## l

### LOSSARY OF AGL AOI ATC ATO AV CFR COA FAA 

### FAR GCS GPS LOL NAS NOT AM PIC Section 333 

## so SOP UA UAS VFR VLOS VMC VTOL Above Ground Level Area ofInterest AirTraffic Control AirTraffic 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 Aim1an Pilot In Command FAAModernization and Reform Act of2012 Safety Observer Standard OperatingProcedures Umnanned Aircraft Unmanned Aircraft System Visual Flight Rules Visual Line ofSite Visual Meteorological Conditions Vertical Takeoffand Landing

### M Brent K Baker (APPlicant) seeks exemption from the reauirements of 14 C.F.R**~~** 61.23(a). 61.101(34) 61.113(a) & (b). 61.315 (a).91.7(a). 91.119 (c). 91.119 (c). 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 Svstem pursuant to Section 333 of the FAA Modernization and Refonn Act of2012 (FMRA). This exemption will permit APPlicant to operate an Unmanned Aircraft Svstem (UAS) for the commercialpuroose ofconducting aerial video and photography of to be used intelevision commercials, weather traffic and news reports, and sporting events over certain areas of the United States.



### INTRODUCTION AND ! OF THE Mvname is Brent K Baker, I am 46 years old, with an Bachelors Degree in Electronics Engineering Technology I've completed mv Flight Training and single engine land private pilot's license in 1996 followed bv mv instrument rating in 2000. I have 400+ total hours pilot in command. Also video ground school in VTAL rotating wing. I wish to provide high quality imaging for a variety ofcommercial and public uses, specifically targeting:

• Aerial Survey

• Commercial Photography

• Management ofConstruction Progress.

• Site Health and Safety Plan inspections

• Insure implementation ofEnvironmental Controls such as storm water discharge requirements and pollutionprevention mitigation

• Inspections ofConm1ercial Real Estate



### ROUND Umnanned Aircraft Systems: DJI Phantom 3Vision+, blade 350Qx3 and Blade 450X Helicopter. APPlicant seeks an exemptionto operate DJI svstemsfor compensation orhire within the NAS. The DJI Phantom 3Vision+ and DJI Inspire 1 are vertical takeoffand landing (VTAL) Unmanned Aircraft (UA) with a Ground Control Station (GCS) utilizing electronic tablet or smartphone svstems. The DJIPhantom 3Vision+ has a maximum gross weight ofapproximately 2 pounds 11 ounces, while having a length of 16 inches width of 16 inches, height of8 inches, and a maximum speed ofapproximately 29 knots. 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 ofapproximately 42 knots. The DJI Phantom 3Vision+ and DJI Inspire 1 UAs are equippedwith four main rotors; driven by Lithium Polymerbattery powered electric motors. The DJI Phantom 3Vision+ and DJI Inspire 1UAs that will be operatedbvAPPlicant will be registered in accordance with 49 U.S.C. 44103, Rezistration of Aircraft. as well as 14 C.F.R Part47,AircraftRegistration, and marked in accordance with 14 C.F.R. Part 45, Identification andRegistration Marking.



### BASIS FOR PETITION Petitioner, APPlicant, pursuant to the provisions ofthe Federal AviationRegulations 04 C.F.R.**~** 11.61) and the FAAModernization and Reform Act of2012 (FMRA). Section 333. Soecial Rulesfor Certain Unmanned AircraftSvstems, hereby petitions the Administratorto commercially operate the DJIPhantom 3Vision+, DJI Inspire 1UASs inthe National Airspace Svstem (NAS). and for an exemption from the reauirements of 14 C.F.R**~~** 61.23(a), 61.101(e4) 61.113(a) & (b), 61.315 (a), 91.7(a), 91.119 (c), 91.119 (c), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(l) & (a)(2), and 91.417(a) & (b). In consideration ofthe speed, weight, size, and limited operating area associated withthe unmanned aircraft and 

## 3its operation, Applicant operation ofDJIPhantom 3Vision+ and DJI Inspire 1UASs meets the conditions of FMRA Section 333 and therefore, will not require an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H. Accordingly, Applicant requests relieffrom Sections 91.405(at 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. APPlicant submits that the requested reliefis proper since an equivalent level ofsafetv will be ensured. Applicant will use experienced personnel ortechnicians to perform maintenance, alterations, or preventive maintenance onthe UASs using the methods, techniques, and practices prescribed inthe operating documents (i.e._ MonthlvMaintenance Log, and DJIPhantom 3Vision+ and DJI Inspire 1 InstructionManual). Furthermore, Applicant will document and maintain all maintenance records for the DJIPhantom 3Vision+ and DJIInspire 1UASs. Relieffrom certainrequirements ofSection 61.113(a) and (b)_ entitled Private vilotvrivilezes andlimitations: Pilot in command, is requested bvAPPlicant to the extent necessary to allow a Pilot in Command (PIC) holding a private Pilot orhigher level certificate, as well as an airman medical certificate, and who has demonstrated, by meeting minimum flight- hour and currencyrequirements, that the PIC is able to safelv operate the DJI Phantom 3Vision+ and DJI Inspire 1UASs in a manner consistent with this exemption, including evasive and emergency maneuvers and maintaining appropriate distances from people, vessels, vehicles and structures. Applicant seeks relieffrom Section 91.7(at entitled Civil aircraft airworthiness, because the DJI Phantom 3Vision+ and DJI Inspire 1 UASs do not require an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H. As such, APPlicant submits that he will ensure that the DJI Phantom 3Vision+ and DJI Inspire 1

UASs are in an airworthv condition, priorto everv flight, bv determining that the UASs are in compliance with the operating documents (i.e., Monthlv Maintenance Log, and DJIPhantom 3Vision+ and DJI Inspire 1 InstructionManual), and that the aircraft are in a condition for safe flight. APPlicant also seeks an exemption from the requirements ofSection 91.119 (c

### t entitledMinimum Safe Altitudes: General, as the DJIPhantom 3Vision+ and DJI Inspire 1 UAs operate at low altitudes of400 feet or less. Applicant also seeks an exemption from the requirements ofSection 91.121, entitledAltimeter Settinzs, as the DJIPhantom 3Vision+ and DJI Inspire 1 UAs will not have a typical barometric altimeter onboard. However, altitude information ofthe DJI Phantom 3Vision+ and DJI Inspire 1UAs will be provided to the PIC via Global Positioning Svstem (GPS) equipment and radio communications telemetry data link, which downlinks from the UAto the GCS for active monitoring ofthe flight path. This altitude infonnation, combined withAPPlicant's operation ofthe DJIPhantom 3Vision+ and DJI Inspire 1UASs within visual line ofsight, at or below 500 feet AGL, will ensure a level ofsafety equivalentto Section 91.121. Additionally, Applicant seeks an exemption from the requirements ofSection 91.151(b), entitled Fuel reauirementsforflizht in VFR conditions. APPlicant submits that safetv will notbe affected bv operation ofthe DJIPhantom 3Vision+ and DJI Inspire 1 UAs during davlight hours in visual meteorological conditions (VMC) under visual flight rules (VFR)_ with enoughbattery powerto flv 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, Applicantprovides the following information in support ofits petition for exemption:



## 4

### me And 

### Of Petitioner. The name and address ofthe Petitioner and point ofcontact is: Brent K Baker Applicant 4176 Maple St Chino, CA. 91710 The brent182@gmail.com



### The Specific C.F.R. From Which Applicant ption. Annlicant Seeks Exemntion From The Requirements OfSection 61.23(a). Medical certificates: Requirement and duration. (a) Operations requiring a medical certificate. Except as provided inparagraphs (b) and (c) ofthis section. Annlicant Seeks Exemption From The Requirements OfSection 61.101(e4)Recreational pilot privileges and limitations. (e) Except as provided in paragraphs (d) and (i) ofthis section, a recreational pilot may not act as pilot in command ofan aircraft- (iv) With retractable landing gear; Applicant Seeks Exemption From The Requirements OfSection 61.113(a) And (b). Section 61.113. entitled Private pilot privileges and limitations: Pilot in command, subsections (a) and (b) prescribethe following, inrelevant part: (a) No person who holds a private oilot certificate mav act as a pilot in command (PIC) ofan aircraft that is carrving passengers orproperty 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 carry passengers orproperty for compensation or hire. Applicant Seeks Exemption From The Requirements OfSection 315 (a). 61.315 What are the privileges and limits ofmy sport pilot certificate? (a) Ifyou hold a sport pilot certificate you may act as pilot in command ofa light-sport aircraft, except as specified in paragraph (c) ofthis section. Applicant Seeks Exemption From The Requirements OfSection 91.7(a). Section 91.7, entitled Civil aircraft airworthiness, subsection (a), states the following: (a) No person may operate a civil aircraft unless it is in an airworthy condition. Applicant Seeks Exemption From The Requirements OfSection 91.119 (c). Except when necessary for takeoffor landing, no person may operate an aircraft below the following altitudes: Applicant Seeks Exemption From The Requirements OfSection 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, byreference to an altimeter that is set, when operating--



## 5(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) Inthe case ofan aircraft not equipped with a radio, the elevation ofthe departure airport or an appropriate altimeter setting available before departure. Applicant Seeks Exemption From The Requirements OfSection 91.151(b). Section 91.151, entitled Fuel requirements for flight in VFR conditions, subsection (b), states the following: (b) No verson mav bezin aflizht in a rotorcraft under VFR conditions unless (considerinz windandforecast weather conditions) there is enouzhfuel toflv to the firstpointof intended landing and, assumingnormal cruising speed, tofly after that for at least 20 minutes. Applicant Seeks Exemption From The Requirement OfSection 91.405(a). Section 91.405, entitled Maintenance required, subsection (a), states the following: Each owner or operator of an aircraft- (a) Shall have that aircraft inspected as prescribed in subpart E ofthis part and shall between required inspections, except as provided in paragraph (c) ofthis section, have discrepancies repaired as prescribed in part 4 3 ofthis chapter[.] Applicant Seeks Exemption From The Requirements OfSection 91.407(a)(1) Section 91.407. entitled Overation after maintenance,preventive maintenance, rebuilding, or alteration,subsection (a)(1), states the following: (a) No person may operate any aircraft that has undergone maintenance, preventive maintenance, rebuilding, or alteration unless-- (1) It has been approved for returnto service by a person authorized under§ 43.7 ofthis chapter[.] Applicant Seeks Exemption From The Requirements OfSections 91.409(a)(1) And 91.409(a)(2). Section 91.409, entitledInspections, subsection (a), states the following: (a) Except as provided in paragraph (c) ofthis section, no person may operate an aircraft unless, within the preceding 12 calendar months, ithas had-- (1) An annual inspection in accordance with part 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 with part 21 ofthis chapter. Applicant Seeks Exemption From The Requirements OfSections 91.417(a) And 91.417(b). Section 91.417, entitledMaintenance records, subsections (a) and (b), state the following: (a) Except for work perfonned in accordance with<$<$ 91.411 and 91.413, each registered owner or operator shall keep the following records for the periods specified in paragraph (b) 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 include-- (i) 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 oftheperson approving the aircraft for return to service. (2) Records containingthe following information: (i) The total time in service ofthe airframe, each engine, each propeller, and each rotor. (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 

## 6specifiedtime basis. (iv) The current inspection status ofthe aircraft including the time since the last inspection required by the inspectionprogram under which the aircraft and its appliances are maintained. (v) The current status ofapplicable airworthiness directives (AD) and safetv directives including. for each, the method ofcompliance. the AD or safetvdirective 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 prescribedbv**~** 43.9(d) ofthis chapter for each major alterationto the airframe and currently installed engines, rotors, propellers, and appliances. (b) The owner oroperator shall retain the following records for the periods prescribed: (1) The records specified inparagraph (a)(1) ofthis section shall be retained until the work is repeated or superseded by other work or for 1 year after the work is performed. (2) The records specified inparagraph (a)(2) ofthis section shall be retained and transferred withthe 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.

Extent Rei Applicant Seeks And The ica Extent OfReliefApplicant Seeks And The Reason Applicant Seeks ReliefFrom Section 61.23(a). Medical certificates: Requirement and duration. (a) Operations requiring a medical certificate. Except as provided inparagraphs (b) and (c) ofthis section. The PIC will not be operating a aircraft which is capable of carryingpassengers or the pilot. Extent OfReliefApplicant Seeks And The Reason Applicant Seeks ReliefFrom Section 61.101(e4). 61.101 Recreational Pilot privileges and limitations. (e) Except as provided in paragraphs (d) and (i) ofthis section. a recreational pilot mav not act as pilot in command ofan aircraft-(iv) With retractable landing gear; as the DJI Inspire 1has retractable landing gear which is integral to the operation ofthe camera. The landing gear lifts to allow 360 degree rotation ofthe camera without interference bvthe landing gear. This operation is ultimately safer than rotating the entire DJIInspire 1 do the simplification ofthe rotation process. Extent OfReliefApplicant Seeks And The Reason Applicant Seeks ReliefFrom Section 61.113(a) And (b). Relieffrom Section 61.113(a) and (b) entitled

### Private vilotvrivilezes and limitations: Pilot in command. is requested to the extent necessarv to allow a PIC holding a orivate Pilot orhigher level certificate. as well as a current and valid airman medical certificate. and who has met certain flight-hour and currency requirements, to conduct the proposed UAS flight operations for compensation orhire. This reliefis 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 ofan aircraft in connection with anv business or emplovment if: (1) The flight is onlv incidental to that business or employment; and (2) The aircraft does not can-y passengers or property for compensation orhire. As set forth more fullv below. Applicant submits that an equivalent level ofsafetv will be maintained because

no PIC will be allowed to operate the DJI Phantom 3Vision+ UAS or DJI Inspire 1UAS unless that PIC has met certain flight-hour and currency requirements. demonstrating that the PIC is able to safelv operate either the DJIPhantom 3Vision+ orDJI Inspire 1 UAS in a manner consistent withthe operations specifications as described in this exemption. including evasive and emergency maneuvers, as well as maintaining appropriate distances from people, vessels, vehicles and structures. Further. APPlicant submits that all flights ofthe DJI Phantom 3Vision+ and DJI Inspire 1 UASs. conducted by the PIC pursuantto the grant ofthis Petition: (1) will be incidental to Applicant's business; and (2) will not carry passengers orproperty for compensation orhire. Extent OfReliefApplicant Seeks And The Reason Applicant Seeks ReliefFrom Section 91.7(a). Relieffrom Section 91.7(a) entitled 

### Civil aircraftairworthiness. is requested tothe extent required to allow Applicant to determine that the DJI Phantom 3Vision+ and DJI Inspire 1 UASs are in airworthy conditionprior to every flight by ensuring that the UAS is in compliance with the operating documents (i.e., the ApplicantAerial Operations Manual, Monthly Maintenance Log, and DJIPhantom 3Vision+ and DJI Inspire 1 Instruction Manual). Aoolicant seeks the requested reliefbecause the DJI Phantom 3Vision+ and DJI Insoire 1 UASs do not require an airworthiness certificate in accordance with 14 C.F.R. Part 21. Subpart H. Therefore. AoPlicant will ensure thatthe DJIPhantom 3Vision+ and DJI Inspire 1 UASs are in airworthy conditionbasedupon its compliance with the ooeratimz documents (i.e

.. Monthly Maintenance Log, and DJIPhantom 3Vision+ and DJI Inspire 1 InstructionManual) priorto every flight and further, determine that the aircraft are in condition for safe flight,

as stated in the conditions and limitations below. 

### Extent OfReliefApplicant Seeks And The Reason Applicant Seeks ReliefFrom Section 91.119 (c). Relieffrom Section 91.119 (c). entitled Minimum Safe Altitudes: General, as the DJI Phantom 3Vision+ and DJIInspire 1UAs operate at low altitudes of400 feet or less. 

### Extent OfReliefApplicant Seeks And The Reason ApplicantSeeks ReliefFrom Section 91.121. Relieffrom Section 91.121. entitled Altimeter settings. maybe required to allow flight operations ofthe DJI Phantom 3Vision+ and DJI Inspire 1UASs. whichutilize a barometric pressure sensor. GPS equioment and a radio communications telemetry data linkto downlink altitude information from the UAto the PIC at the ground control station (GCS). Since the FAArequires that any altitude information concerningUAS operations be reported to airtraffic control (ATC) in feet above ground level (AGL). Aoolicant seeks the requested relief because the DJI Phantom 3Vision+ and DJI Inspire 1 UA's altimeter may be set on the ground to zero feet AGL, rather thanthe local barometric pressure orfield altitude, before each flight. Consideringthe limited altitude ofthe orooosed ooerations. relieffrom 14 CFR 91.121 is sought to the extent necessarv to comply with the applicable conditions and limitations stated below. As more fully set forth herein, an equivalent level ofsafety will be maintained since the DJIPhantom 3Vision+ and DJI Inspire 1UAs are eouipoed with a barometric pressure sensor and GPS equipment. which automatically ensures that a ground level pressure setting will be established priorto each flight, and provides the PIC with altitude information of the UA onthe heads-up display ofthe GCS. 

### Extent OfReliefApplicant Seeks And The Reason Applicant 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 batterv oowered DJIPhantom 3Vision+ and DJI Insoire 1 UAs during davlight 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. assuming normal cruising speed. to fly after that for at least 4.5 minutes.Aoolicant seeks the requested reliefbecause without an exemotion from Section 91.151(b), the flight time duration ofthe batterv powered DJIPhantom 3Vision+ and DJI Insoire 1 UAs will severely constrain the practicality ofany aerial video or still photo flight operations that Applicant proposes to conduct pursuantto this Petition. Sirnificantlv. as set forth below. the technical specifications ofthe DJIPhantom 3Vision+ and DJI Insoire 1 UASs. the DJIPhantom 3Vision+ and DJI Inspire 1 operating documents. and Applicant's oroposed ooerating limitations. ensure that Applicant will safely operate the battervpowered DJI Phantom 3Vision+ and DJI Insoire 1 UAs during davlight hours in visual meteorological conditions (VMCt under visual flight rules (VFR), with enoughbatterv power 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. 

### Extent OfReliefAoolicant Seeks And The Reason Aoolicant Seeks ReliefFrom Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & 

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

### (b). Since Sections 91.405(at 91.407(a)(l). 91.409(a)(l) & (a)(2). and 91.417(a) & (b) onlv aoolvto aircraft with an airworthiness certificate. Aoolicant requests relieffrom these Sections because the DJIPhantom 3Vision+ and DJI Inspire 1UASs do not require airworthiness certificates. As set forth more fully below. the DJIPhantom 3Vision+ and DJI Insoire 1 UASs meet the conditions ofFMRA Section 333 for ooeration without an airworthiness certificate. Accordinglv. AoPlicant will use trained technicians to perform maintenance. alterations. orpreventive maintenance onthe UASs using the methods. techniques. and practices prescribed in theUAS operating documents (i.e

.. the APPlicant Aerial Ooerations ManuaL Monthly Maintenance Log, and DJI Phantom 3Vision+ and DJI Inspire 1 InstructionManual). Furthermore. Applicant will document and maintain all maintenance records for the DJIPhantom 3Vision+ and DJI Inspire 1UASs.



## 8

### Reasons Why Granting ld In Public I That Is, How It Would blic A Whole. Grantingthe oresent Petition will further the public interest bv allowing APPlicantto safelv. efficientlv. and economicallyperform aerial video and photography ofconstruction sites, real estate, and landscape over certain

areas ofthe United States. Additionallv. use ofthe DJIPhantom 3Vision+ and DJI Inspire 1UASs will decrease congestion ofthe NAS. reduce pollution. andprovide significantbenefits to the economv. Notablv. the benefits ofAPPlicant's proposed operation ofthe DJIPhantom 3Vision+ and DJI Inspire 1UASs will be realized without implicating any pnvacy 1ssues. 

### The Public Will Benefit From Decreased Congestion OfTheNAS. The DJIPhantom 3Vision+ and DJI Inspire 1 UAs are battervpowered and serve as a safe. efficient and economical alternative to the manned aircraft traditionally utilized to obtain aerial imagerv. Bvreducing the amount ofmanned aircraft needed to perform aerial acquisitions, an exemption allowing the use ofa DJI Phantom 3Vision+ or DJI Inspire 1UAS would reduce the amount ofmanned aircraft in the NAS, reduce noise and air pollution, as well as increase the safety oflife andproperty inthe air and onthe ground. Furthermore, bvreducing the number ofmanned aircraft operating inthe NAS. congestion around airports caused bv arriving and departing aircraft will be reduced. The DJI Phantom 3Vision+ and DJI Inspire 1 UAs do not require an aimort to takeoffor land. Likewise, a reduction ofmanned aircraft conducting aerial video and photography missions would result in fewer aircraft that must be handled by air traffic control during the ground, takeoff, departure, arrival, and landingphases offlight operations. 

### ThePublicWill Benefit FromThe Safety And Efficiency OfThe DJI Phantom 3Vision+ and DJI Inspire 1 UASs. Conducting aerial acquisitions with the DJI Phantom 3Vision+ and DJI Inspire 1UASs. instead ofmanned aircraft. will greatlv benefit the public bv drastically reducing the levels ofair and noise pollution generated during traditional aerial video and still photography flight operations. Bvusingbattervpower and electric motors. the DJI Phantom 3Vision+ and DJI Inspire 1 UASs produce no airpollution. and is the most viable environmentally conscious alternative to the cabin class, sixcvlinder internal combustion engine aircraft that are tvoicallv utilized for aerial video and photography, while burning aporoximatelv 20-30 gallons per hour of leaded aviation fuel. The DJIPhantom 3Vision+ and DJI Inspire 1UAs. while reducing the carbon footorint of aerial acquisitions, also eliminates noise pollution, as the UAs are propelled bybatterypowered electric motors, rather than an internal combustion engine. Bvusing the DJIPhantom 3Vision+ and DJI Inspire 1 UASs to perform aerial acquisitions, the substantial risk to life and property inthe air and onthe ground, which is usuallv associated with traditional manned aircraft flight operations. will be substantially reduced or completely eliminated. Aside from the lack of**fli~ht** crew members located onboardthe aircraft. the DJIPhantom 3Vision+ and DJI Inspire 1 UAs (weighing approximately 2 pounds 11 ounces and 6 pounds 7.5 ounces respectivelv. at their maximum gross weights with lengths of 16 inches and 17.3 inches respectively, widths of 16 inches and 17.7 inches respectively, and with no fuel on board). has less physical potential for collateral damage to life and property on the ground, and in the air, compared to the manned aircraft that tvoicallv 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). 

### Performin!! Aerial Video and Photography Operations With TheDJI Phantom 3Vision+ and DJI Inspire 1 UASs Will Benefit TheEconomy. In addition to being safe and efficient the DJI Phantom 3Vision+ and DJI Inspire 1 UASs are also an economical alternative to using manned aircraft to conduct similar aerial operations. As such. operation ofthe DJI Phantom 3Vision+ and DJI Inspire 1 UASs will allowUnited States based companies. like APPlicant to remain competitive and contribute to growth ofthe U.S. economv. Specifically, with the rising cost ofaviation fuel andthe Environmental Protection Agencv ("EPA") regulatorv 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 batterv powered DJI Phantom 3Vision+ and DJI Inspire 1UASs is one suchtechnology that not onlv allows companies greater operational flexibility comparedto manned aircraft, but provides such flexibility without the high operational cost ofa traditional manned aircraft. Bvoperatingthe DJIPhantom 3Vision+ and DJI Inspire 1UASs. companies such as APPlicant can remain competitive andprofitable, and therefore, provide greaterjob stability to employees and contractors, which will 

## 9ultimately contribute to growth ofthe U.S. economv. Improved financial performance ofU.S. companies, throu!ili commercial use ofthe DJI Phantom 3Vision+ and DJI Inspire 1UASs, 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 inthe United States and abroad. 

### There Are No Privacy Issues. Similarto the manned aerial acquisition flight operations that have been conducted for decades, Applicant's proposed operation ofthe DJI Phantom 3Vision+ and DJI Insoire 1 UASs will not imolicate anv orivacv issues. Specifically, the DJI Phantom 3Vision+ and DJI Inspire 1 UASs will be ooerated onlv in compliance with operating documents (i.e., the Applicant Aerial Operations Manual. Monthly Maintenance Log, andDJI Phantom 3Vision+ and DJI Inspire 1 Instruction Manual) whichreauires orooertv 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.



### The Why Granting Exemption Would Not Adversely Safety, The ption Would Provide A Level Of At That Provided By Which nt ption. Reasons Whv The DJI Phantom 3Vision+ and DJI Insuire 1 UAs MeetThe Conditions OfThe FAA Modernization and Reform Act of2012 (FMRA) Section 333. In consideration ofthe size, weight soeed, and limited ooerating area associated with the unmanned aircraft and its operation. APolicant's operation ofthe DJI Phantom 3Vision+ and DJI Inspire 1 UASs meet the conditions ofFMRA Section 333, and will not require an airworthiness certificate in accordance with 14 C.P.R. Part 21, Subpart H. Section 333 Provides authoritv for a UAS to overate without airworthiness certification and sets forth 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. Specifically, FMRA Section 333 states the following, inpart: (a) In General.--Notwithstandinzanv other reauirement of this subtitle. andnot later than 180 davs after the date of enactment of thisAct. the Secretarv ofTransvortation shall determine if certain unmannedaircraft svstems mav overate safelv in the nationalairsvace svstem before comvletion of the vlan andrulemaking requiredby section 332 of thisActor the guidance required bysection 334 of thisAct. (b)Assessment ofUnmannedAircraftSvstems.--In makingthe determination undersubsection (a), the Secretmy shalldetermine, ata minimum-- (]) which tvves of unmannedaircraftsvstems. if anv. as a result of their size. weizht. sveed. overational cavabilitv. vroximitv to airvorts andvovulatedareas. andoveration within visual line of sizhtdo not create a hazardto users of the national airspace system or thepublic orpose a threat to national security; and (2) whether a certificate of waiver. certificate of authorization. orairworthiness certification under section 44704 of title 49. UnitedStates Code, is required for the operation of unmannedaircraft systems identified underparagraph (1). (c) Reauirementsfor Safe Overation.--Ifthe Secretarv determines under this section that certain unmanned aircraftsvstems mav overate safelv in the national airsvace svstem. the Secretary shall establish requirements for the safe operation of such aircraft systems in the national airspace system. In seeking this exemption. Aoolicant submits that the DJIPhantom 3Vision+ and DJI Inspire 1 UASs can operate safelv in the NAS pursuant to FMRA Section 333. as demonstrated bv: (a) the characteristics ofthe DJI Phantom 3Vision+ and DJI Inspire 1UASs; (b) the pilot certificationrequirement; and (c) the specific operating limitations.



### a. The Suecifications OfThe DJI Phantom 3Vision+ and DJI Inspire 1 UASs Demonstrate Its Safe Characteristics. The DJI Phantom 3Vision+ and DJI Inspire 1 UASs do not create a hazard to users oftheNAS orthe public, or otherwise pose a threat to national security considering its size, weight, speed, and operational capability. 

### i. Technical Specifications OfThe DJI Phantom 3Vision+ and DJI Inspire 1 UASs. The technical specifications ofthe DJI Phantom 3Vision+ and DJI Inspire 1UASs are set forth bythe 

## 10DJIPhantom 3Vision+ and DJI Inspire 1 Specifications and Data Sheet, attachedhereto as Exhibit A and B. ii. 

### TheDJI Phantom 3Vision+ and DJI Insoire 1 UASs Autonomous Fli!!ht And Navigation Modes Enable The UASs To Remain WithinA Defined Operational Area. The DJIPhantom 3Vision+ and DJI Inspire 1UASs may be operated inbothmanual and fully autonomous flight modes. A complete description ofthe flight and navigational modes ofthe DJI Phantom 3Vision+ and DJI Inspire 1UASs is provided at pages 25-35 ofthe DJIPhantom 3Vision+ andpages 12-16 and 45-50 ofthe DJI Inspire 1User Manuals, attached hereto as Exhibit C and D. iii. 

### The DJI Phantom 3Vision+ and DJI Insoire 1 UASs AreDesi!!ned ForAutomatic Return To Home Point OrHover In The Event OfLoss OfThe ControlLink OrNavigation. When the Control Link is lost the DJI Phantom 3Vision+ and DJI Inspire 1UAs will remain stationary, in flight for 3 seconds ormore. If. after 3 seconds. the DJIPhantom 3Vision+ and DJI Inspire 1 UAs do not reacauire control link data from the GCS. the UAs will assume thatthe Control Link is lost and the UAs will return to the home position (i.e., failsafe mode) via GPS, and will descend to the takeoff position and shutdown. A complete description ofthe Failsafe Functions ofthe DJIPhantom 3Vision+ UAS are set forth at pages 27 through 29 and for the DJIInspire 1 at pages 13 through 15 ofthe DJI Phantom 3Vision+ and DJI Inspire 1UserManuals, attached hereto as Exhibit C and D. 

### iv. The DJI Phantom 3Vision+ and DJI Inspire 1 GCS And Its Operation. A complete description ofthe operation and specifications ofthe DJIPhantom 3Vision+ and DJI InsPire 1 GCS and flight control software is provided at pages 32 through 43 ofthe DJIPhantom 3Vision+ UserManual and pages 40 through 47 ofthe DJI Inspire 1 UserManual. DJI Phantom 3Vision+ and DJI Inspire 1 User Manuals are attached hereto as Exhibits C and D. 

### b. Fli!!ht Ooerations OIDJI Phantom 3Vision+ and DJI Insoire 1UASs Are Limited To The Line OfSight OfA Certificated Pilotin CommandWith A Safety Observer. APPlicant will only utilize certificated Pilots who possess a current and valid airman medical certificate to act as a pilot in command (PIC) ofthe DJIPhantom 3Vision+ and DJI Inspire 1 UASs. Additionally, a safety observer will assist all pilots during flight time.



### c. Fli!!hts OIDJI Phantom 3Vision+ and DJI Inspire 1UASs Will Be Conducted Pursuant To Specific Operating Limitations. In seeking this exemption. APPlicant proposes to commercially operate DJI Phantom 3Vision+ and DJI Inspire 1 UASs for the special purpose ofconducting aerial video and photography over certain areas ofUnited States, pursuantto the following specific operating limitations: 1. Operations authorized bythis grant ofexemption will be limitedto the following aircraft described inthe operating documents. rotorcraft UASs weighing less than 55 pounds maximum gross weight: DJIPhantom 3Vision+ and DJI Inspire 1 Unmanned Aircraft Systems. Proposed operations ofany other aircraft will require a newpetition or a petition to amend this grant. 2. UAS operations underthis exemption will be limited to conducting operations for the purpose of aerial video andphotography. 3. The UAs may notbe flown at anindicated airspeed exceeding 20 knots. 4. The UA must be operated at an altitude ofno more than 500 feet above ground level 

### (AGU. as indicated bythe procedures specified inthe operating documents unless a special request is made and approved byATC. All altitudes reported to ATC mustbe in feet AGL. 5. The UAs must be operated within visual line ofsight (VLOS) ofthe PIC at all times. This reauires the PIC to be able to use human vision unaided by any device otherthan corrective lenses, as specified on the PIC's FAA-issued airman medical certificate. 6. The use offirst person view (FPV) bythe PIC or safety observer (SO) is not permitted. 7. All operations must utilize a safetv observer (SO). The SO maybe used to satisfv the VLOS reauirement as long as the PIC always maintains VLOS capabilitv. The SO and PIC must be able to communicate verbally at all times. Electronic messaging or texting is not permitted during flight operations. The PIC must be designated before the flight and cannot transfer his or her designation for 

## 1the duration ofthe flight. The PIC must ensure that the SO canperform the functions prescribed in the operating documents. 8. The SO must notoerform anv other duties bevond assisting the PIC with seeing and avoiding other airtraffic and other ground based obstacles/obstructions and is not permittedto operate the camera or other instruments. 9. The ooerating documents and the grant ofexemotion must be accessible during UAS ooerations and made available to the Administrator uoon request. Ifa discreoancv exists between the conditions and limitations contained inthe grant ofexemotion and the orocedures outlined in the ooerating documents, the conditions and limitations contained inthe grant ofexemotion take orecedence and must be followed. Otherwise. the ooerator must follow the orocedures as outlined in its ooerating documents. The ooerator mavuodate or revise its ooerating documents. It is the ooerator's resoonsibilitvto track such revisions and oresent uodated and revised documents to the Administratoruoon request. The ooerator must also oresent uodated and revised documents ifit oetitions for extension or amendment to the grant ofexemotion. Ifthe ooerator determines that anv uodate or revision would affect the basis

uoon whichthe FAA granted the exemotion. thenthe ooerator must oetition for amendment to its grant ofexemotion. The FAA'sUAS Integration Office (AFS-80) may be contacted ifquestions arise regarding updates orrevisions to the operating documents. 10. Priorto each flight the PIC must insoect the UAS to ensure that it is ina condition for safe flight. If the insoection reveals a conditionthat affects the safe ooeration ofthe UAS. the aircraft is orohibited from ooeratinguntil the necessarv maintenancehas been oerformed and the UAS is found to be in a condition for safe flight. The Ground Control Station must be included inthe oreflight inspection. All maintenance and alterations must be properly documented in the aircraft records. 11. Anv UAS thathas undergone maintenance or alterations that affect the UAS ooeration or flight characteristics. e.g. reolacement ofa flight critical comoonent must undergo a functional test flight. The PIC who conducts the functional test flight must make an entry inthe aircraft records. 12. The ore-flight insoection must account for all ootential discreoancies. e.g. inooerable components, items, or equipment, not already covered in the relevant sections ofthe operating documents. 13. The ooerator must follow the UAS manufacturer's aircraft/component, maintenance, overhaul, replacement, inspection, and life limitrequirements. 14. The ooerator must carrv out its maintenance. insoections. and record keeoing requirements, in accordance with the ooerating documents. Maintenance. insoection. alterations. and status of reolacement/overhaul comoonent oarts must be noted inthe aircraft records. including total time in service. descriotion ofwork accomplished, and the signature ofthe authorizedpersonreturning the UAS to service. 15. EachUASs operated under this exemption must comply with all manufacturer Safety Bulletins. 16. The authorized oersonmust make an entrv inthe aircraft record ofthe corrective action taken against discrepancies discovered between inspections. 17. The PIC must possess at least a private pilot certificate and at least a current third- class medical certificate. 18. The ooerator mav not oermit anv PIC to overate unless the PIC meets the ooerator's qualification criteria and demonstrates the abilitv to safelv overate the UAS in a manner consistent withhowthe UAS will be ooerated under the exemotion. including evasive and emergency maneuvers and maintaining aoorooriate distances from oersons. vessels. vehicles and structures. PIC qualification flight hours must be logged in a manner consistent with 14 C.F.R.**~** 61.51(b). Flights for the oumoses oftraining the ooerator's PICs are oermitted under the terms ofthe exemotion. However. training ooerations mav onlvbe conducted during dedicated training sessions. During training. oroficiency, and exoerience-building flights. all oersons not essential for flight ooerations are considered nonoarticioants. and the PIC must overate the UA with appropriate distance from nonparticipants in accordance with 14 C.F.R. § 91.119. 19. UAS ooerations mav not be conducted during night as defined in 14**C.P.R.~** 1.1. All ooerations mustbe conducted under visual meteorological conditions (VMC). Ifflight at night is required. a soecial request will be made at the FAA office closest to proposed area ofoperations. Flights under special visual flight rules (SVFR) are not authorized. 

## 1220. The UA mav not operate within 5 nautical miles ofan airport reference point as denoted on a current FAA-Published aeronautical chart unless a letter ofagreement with that airport's management is obtained. and the operation is conducted in accordance with a NOT AM as required bvthe operator's CO A. The letter ofagreement with the airport management mustbe made available to the Administratorupon request. 21. The UA mav not be operated less than 500 feet below or less than 2,000 feet horizontally from a cloud or when visibility is less than 3 statute miles from the PIC. 22. Ifthe UA loses communications or loses its GPS signal. it must return to a pre- determined location within the planned operating area and land or be recovered in accordance withthe operating documents. 23. The PIC must abortthe 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 enough powerto flv at normal cruising speed to the intended landingpoint and land the UA with 25% batterypowerremaining. 25. The operator must obtain an Air Traffic Organization (ATO) issued Certificate ofWaiver or Authorization (COA) priorto conducting anv operations under the grant ofexemption. This COAwill also require the operatorto request a Notice to Airman (NOT AM) not more than 72 hours in advance, but not less than48 hours priorto the operation. All operations shall be conducted in accordance with airspace requirements inthe ATO issued COA including class ofairspace, altitude level and potential transponder requirements. 26. All aircraft operated in accordance with the exemptionmustbe identified bv serial number. registered in accordance with 14 C.F.R. part 47. and have identification (N- Number) markings in accordance with 14 C.F.R. part 45, Subpart C. Markings must be as large as practicable. 27. Before conducting operations. the radio frequencv 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 must be available to the PIC at the Ground Control Station ofthe UAS anv time the UAS is operating. These documents mustbe made available to the Administrator or any law enforcement official uponrequest. 29. The UA must remain clear and yieldthe right ofway to all manned aviation operations and activities at all times. 30. The UAS maynot be operated by the PIC from any moving device or vehicle. 31. Flight operations mustbe conducted at least 500 feet from all nonparticipating persons (persons other than the PIC, SO, operator trainees or essentialpersons), vessels, vehicles, and structures unless:

a. Barriers or structures are mesentthat sufficientlvprotect nonparticipating persons from the UA and/or debris in the event ofan accident. The operatormust ensure that nonparticipatingpersons remain under suchprotection. Ifa situation arises where nonparticipating persons leave suchprotection 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 ofsuch vessels. vehicles or structures has granted permission and the PIC has made a safetv assessment ofthe risk ofoperating closerto those objects and determined that it does notpresent an undue hazard, and;

c. Operations nearerto the PIC. SO. operatortrainees or essential persons do notpresent an undue hazard to those persons per § 91.119(a). 32. All operations shall be conducted over private or controlled-access propertv 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. Anv incident accident or flight operationthattransgresses the lateral orvertical boundaries ofthe operational area as definedbvthe applicable COAmust be reported to the FAA's UAS Integration Office (AFS-80) within 24 hours. Accidents mustbe reported to the National Transportation Safety Board (NTSB) per instructions contained onthe NTSB Web site: vV\Vw.ntsb.gov. Reasons Why An Exemption From The Requirements OfSection 61.113(a) And (b) Would Not AdverselyAffect Safety. APPlicant submits that the equivalent level ofsafetv establishedbv Section 61.113(a) and (b) will be maintained because no PIC will be allowed to operate the DJIPhantom 3Vision+ and DJI Inspire 1 UASs unless that PIC has demonstrated. bvmeeting minimum flight-hour and currencvrequirements. that the PIC is able to safelv operate the DJIPhantom 3Vision+ orDJI Inspire 1UAS in a manner consistent with the exemption. including evasive and emergencymaneuvers and maintaining appropriate distances from people, vessels, vehicles and structures. Considering Applicant's proposed area ofoperations. and the operating limitations set forth-above: the parallel nature ofprivatepilot aeronautical knowledge requirements to those ofcommercial pilot requirements (See ExemPtion No. 11062): and the airmanshiP skills necessarv to safelv operate the DJI Phantom 3Vision+ orDJI Inspire 1UAS. APPlicant submits that the additional manned airmanshiP experience ofa commerciallv certificated pilot would not correlate to the airmanship skills necessary for Applicant's specific proposed flight operations. The FAAhas oreviouslv granted relieffrom Section 61.113(a) and (b) specific to UAS. in circumstances similar, in all material respects. to those presented herein (e.g. Exemption Nos. 11062. 11063. 11064. 11065. 11066, 11067,11080,11109,11110,11112,11136,11138,11150,11153,11156,11158,11159,11160, 11161). Applicant will not allow any PIC to operate the DJIPhantom 3Vision+ orDJI Inspire 1UAS unless that PIC has demonstrated. bv meeting minimum flight-hour requirements orthe DJI Phantom 3Vision+ or DJI Inspire 1 UAS training and currencvrequirements. that the PIC is able to safelv operate the DJIPhantom 3Vision+ or DJI Inspire 1UAS in a manner consistent with this exemption. including evasive and emergency maneuvers and maintaining appropriate distances from people, vessels, vehicles and structures. Specificallv. the PIC must have accumulated and logged. in a manner consistent with 14 C.P.R. Q61.51(b), 25 hours oftotaltime 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 under the exemption). In addition to the hour requirements, the PIC must accomplish 3 takeoffs and landings inthe preceding 90 days (for currency purposes). As in ExemptionNos. 11062. 11138. and 11153. prior documented flight experience that was obtained in compliance with applicable regulations will ensure an equivalent level ofsafetv during Applicant's proposed operations. The Administratorhas 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 FAA required that priorto conducting operations for the purpose ofmotion picture filming (or similar operations). the PIC must have accumulated and logged. in a manner consistent with 14 CPR 61.51(b). 25 hours oftotaltime as a UAS rotorcraft Pilot including at least 10 hours logged as a UAS pilot with a multi-rotor UAS. Prior to operations under Exemption No. 11062. the PIC must also have accumulated and logged a minimum of5 hours as a UAS pilot operating the same make and model ofUAS to be used for operations underthe exemption. For clarification. the FAA considers these minimumhour requirements to be inclusive rather than additive: i.e. 5 hours make and model time mav be included in the 10 hours ofmulti-rotor time and the 10 hours mav be included inthe total25 hours ofUAS rotorcraft time. In addition to the hour requirements. the PIC must accomplish 3 takeoffs and landings inthe preceding 90 days (forcurrencv purposes). The FAA finds that at a minimum. the flight-hour requirements in ExemptionNo. 11062 are appropriate to practice and build proficiency inthe skills necessarv to safely conductthe petitioner's proposed operations. The FAA also finds that prior documented flight experience that was obtained in compliance with aPPlicable regulations would satisfvthis requirement. Training. proficiency, and experiencebuilding flights can also be conducted under the grant ofexemption to accomplish the required flight time. Duringtraining. proficiencv. and experience-building flights the PIC is required to operate the UA with appropriate distances in accordance with 14 C.F.R 91.119. Exemption No. 11138 at page 15. Accordingly. Applicant will ensure safe operations by not allowing any PIC to operate the DJI Phantom 3Vision+ or DJI Inspire 1UAS unless that PIC has demonstrated. bymeeting minimum flight-hour and currencvrequirements. that the PIC is able to safelv operate the DJIPhantom 3Vision+ or DJI Inspire 1 UAS in a manner consistent withthe exemption. including evasive and emergency maneuvers and maintaining appropriate distances from people, vessels, vehicles and structures. Reasons Why An Exemption From The Requirements OfSection 91.7(a) Would Not Adversely Mfect Safety.



## 4The equivalent level ofsafetv established by Section 91.7(a) will be maintained because priorto every flight APPlicant will ensure that the DJI Phantom 3Vision+ or DJI Inspire 1 UAS is in an airworthy conditionbased uponthe UAS's compliance with its operating documents and as stated inthe conditions and limitations herein. AdditionallY. the FAAhas previously granted relieffrom Section 91.7(a) specific 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). Reasons Whv An Exemotion From The Requirements OfSection 91.119 (c) and91.121 Would Not Adversely Affect Safety. The equivalent level ofsafety establishedby Sections 91.119 (c) and 91.121 will be maintainedbecause the altitude information ofthe DJIPhantom 3Vision+ and DJI Inspire 1 UAs will be orovided 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 withApplicant's operation ofthe DJIPhantom 3Vision+ and DJI Inspire 1 UAs within visual line ofsight at or below 500 feet AGL. will ensure a level ofsafety equivalentto 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 establishedby the UASs at ground level. The FAA has oreviously granted relieffrom Section 91.121 specific to UAS. in circumstances similar. in all material respects. to those presentedherein (e.g. Exemption Nos. 11062. 11063. 11064. 11065. 11066, 11067, 11080,11109,11112,11136,11138,11150,11153,11156,11157,11158,11159,11160, 11161). Reasons Why An Exemption From The Requirements OfSection 91.151(b) Would Not Adversely Mfect Safety. A !rrant ofthis exemption would ensure an equivalent level ofsafety establishedby 14 C.F.R. Section 91.151(b) as a result of(1) the technical specifications ofthe DJI Phantom 3Vision+ and DJI Inspire 1UASs: (2) the limitations on the proposed flight operations: and (3) the location ofthe proposed flight operations. Accordingly, APPlicant will ensure that it will safely operate the battervpowered DJI Phantom 3Vision+ and DJIInsPire 1 UAs during daylight hours in VFR conditions. with enough batterv powerto 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 in Exemption No. 11109. the technical specifications ofthe DJIPhantom 3Vision+ and DJI Inspire 1 UASs: the limitations onthe proposed flight operations: and the location ofthe oroposed operations. will ensure an equivalent level ofsafetv established by 14 C.F.R. Section 91.151(b). Furthermore. safetv will be ensured as the DJI Phantom 3Vision+ and DJI Inspire 1UASs orovide audible and visual warnings to the PIC atthe GCS when the UAs experiences lowbattervvoltage. the first warning occuning at approximately 33% remaining batterv power. and again at approximately 10% remaining batterv power. At the critically lowbattery level, the DJIPhantom Vision+ and DJI Inspire 1 UASs will descend and land automatically. SignificantlY. orevious exemptions granted by the FAA concerning Section 91.151 establish that safetv 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 thanthe minimums prescribed in Section 91.151, including Exemption Nos. 2689. 5745. and 10650. Moreover. the FAA has previously granted relieffrom Section 91.151 specific to UAS. in circumstances similar. in all material respects. to those presented herein (e.g. Exemption Nos. 881 L 10808, 10673, 11042, 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 11136, 11138, 11150, 11153, 11156, 11157, 11158, 11159, 11160, 11161). Reasons Whv An Exemotion From The Reouirements OfSections 91.405(a), 91.407(a)(l), 91.409(a)(l) & (a)(2), And 91.417(a) & (b) Would Not Adversely Affect Safety. In seeking this exemption. Applicant submits that the equivalent level ofsafety withregard to the regulatorv maintenance and alteration requirements established by Sections 91.405(a), 91.407(a)(1). 91.409(a)(1) & (a)(2), and 91.417(a) & (b) will be met because APPlicant will use trained technicians to perform maintenance. alterations. or oreventive maintenance onthe UASs using the methods, techniques. and practices orescribed in the operating documents (i.e., the Applicant Aerial Operations ManuaL MonthlyMaintenance Log, and DJI Phantom 3Vision+ and DJI Inspire 1 Instruction Manual). Furthermore. Applicant will document and maintain all maintenance records for the DJIPhantom 3Vision+ and DJI Inspire 1 UASs. Since the DJIPhantom 3Vision+ and DJIInspire 1UASs will be inspected as prescribed bythe operating documents, Applicant will maintainthe equivalent level ofsafety established by Sections 91.405(a), 

## 1591.409(a)(l). and 91.409(a)(2). A copy ofthe DJIPhantom 3Vision+ and DJI Inspire 1UserManuals are attachedhereto as Exhibit C and D: a copy ofthe DJI Phantom 3Vision+ and DJI Inspire 1UAS Maintenance LOG is attached hereto as Exhibit E. Likewise. the exemption sought will not adversely affect safety because Applicant will use trained technicians to perform maintenance. alterations orpreventive maintenance on the UAS using the methods, techniques, and practices prescribed bythe operating documents. Furthern1ore. the exemotion sought would maintain an eauivalent level ofsafety establishedbv Sections 91.407, 91.417(a) and 91.417(b). because all maintenance ofthe DJIPhantom 3Vision+ and DJI Inspire 1 UASs will be performed bvtrained technicians. Maintenance will be documented and maintained utilizing the monthly maintenance log. SignificantlY. previous exemptions granted bvthe FAA concerning Sections 91.405(a). 91.407(a)(1). 91.409(a)(l) & (a)(2). and 91.417(a) & (b) establishthat safety is not adversely affected when the technical characteristics and operating limitations ofthe UAS are considered. In consideration ofApplicant's proposed operating limitations. the operating documents. and the technical asoects ofthe DJIPhantom 3Vision+ and DJI Insoire 1UASs. Aoolicant submits that safetv will not be adversely affected bv granting exemotion 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 FAAhas previously granted reliefspecific to UAS in circumstances similar. in all material respects. to those presented herein (e.g. Exemotion Nos. 11062. 11063. 11064. 11065. 11066.11067,11080,11109,11110,11112,11136,11138,11150,11153,11156,11157,11158,11159,11160, 11161). The FAA May Prescribe Any Other Conditions For Safe Operation. In accordance with Section 333 ofthe FAAModernization and Reform Act of2012 (FMRA) and 14 C.P.R. & 21.16 entitled Soecial Conditions. Aoolicant reauests that the FAA orescribe special conditions for the intended operation ofthe DJIPhantom 3Vision+ and DJI Inspire 1UASs. which contain such safety standards that the Administrator finds necessary to establish a level ofsafetv eauivalent to that establishedbv 14 C.P.R. Part 21. Suboart H. and 14 C.F.R && 61.113(a) & (b). 91.7 (a). 91.12L 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 limited puroose ofconducting aerial video and photography over certain areas ofthe United States for compensation or hire. FMRA Section 333 sets forth the reauirements 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 in the NAS. Likewise. the Administrator mav orescribe soecial conditions oursuant to 14 C.P.R. &21.16. for operation ofthe DJIPhantom 3Vision+ and DJI Insoire 1UASs. 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 adeauate or aoorooriate safetv standards for an aircraft. aircraft engine. or oropeller because ofa novel or unusual design feature ofthe aircraft. aircraft engine or propeller. he prescribes special conditions and amendments thereto for the product. The soecial conditions are issued in accordance with Part 11 ofthis chaoter 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 3 3 3 and 14 C.F.R. 

### &21.16. the FAA mav orescribe special conditions for the Aoolicant intended operation ofthe DJIPhantom 3Vision+ and DJI Insoire 1 UASs. which contain such safety standards that the Administrator finds necessary to establish a level ofsafetv equivalent to that established bv 14 C.P.R. Part 2L 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).

• A Summarv That Can Be Published In The Federal Register, stating: The Rules From Which Applicant Seeks Exemption: Armlicantseeks exemvtionfrom the reauirements of 14 C.F.R Sections 61.113(a)&(b), 91. 7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and91.417(a) & (b). A BriefDescription OfThe Nature OfThe Exemption Applicant Seeks: 

## 16This exemvtion will vermitAvvlicantto commerciallv overate an UnmannedAircraftSvstem (UAS)for the purpose of conductingaerialvideo and photography over certain areas of the UnitedStates.

• Any Additional Information, Views, OrArguments Available To Support Applicant'sRequest. This Petition is made pursuant to the FAAModernization and Reform Act of2012 (FMRA) Section 333. which directs the Secretarv ofTransportation to determine ifcertainUAS mav ooerate safely inthe NAS. As such, Applicant's request for exemptionmaybe granted pursuant to the authority of FMRA Section 333 and 14 C.F.R. Part 11, as set forth above. FMRA Section 333 sets forth the requirements for considering whether a UAS will create a hazard to users of theNAS or the oublic. or otherwise oose a threat to national security; and further, provides the authority for such UAS to operate without airworthiness certification. As discussed in detail above. Aoolicant will operate the DJI Phantom 3Vision+ and DJI Insoire 1 UASs safelv inthe NAS, without creating a hazard to users ofthe NAS, or the public, or otherwise pose a threatto national security.

As set forth herein. Aoolicant seeks an exemotion oursuantto 14 C.F.R.**~** 11.61 and Section 333 ofthe FAA Modernization and Reform Act of2012 (FMRA). which will oermit safe operation ofthe DJI Phantom 3Vision+ and DJIInsoire 1 UASs commercially, without an airworthiness certificate, for the limited ouroose of conducting aerial video and ohotograohv over certain areas ofthe United States. Bv granting this Petition. the FAA Administrator will be fulfilling the Comrressional mandate ofthe FAA Modernization and Reform Act of 2012. while also advancing the interests ofthe public. bv allowing Aoolicant to safelv. efficiently, and economically operate the DJIPhantom 3Vision+ andDJI Inspire 1UASs commercially withinthe NAS. WHEREFORE. in accordance with the Federal AviationRegulations and the FAA Modernization and Reform Act of2012. Section 333. Aoolicant resoectfullv reauests that the Administrator grant this Petition for an exemption from the requirements of 14 C.F.R Sections 61.113(a) & (b). 91.7(a). 91.12L 91.151(b). 91.405(a). 91.407(a)(l). 91.409(a)(l) & (a)(2). and 91.417(a) & (b). and oermitthe Aoolicant to operate the DJIPhantom 3Vision+ and DJI Insoire 1 UASs commercially for the purpose ofconducting aerial video andphotography

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Brent K Baker 4176 Maple St. Chino, CA. 91710 thebrent182((7)gmail.com 909-703-0225



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