UNITED STATES OF AMERICA

DEPARTMENT OF TRANSPORTATION

FEDERAL AVIATION ADMINISTRATION

WASHINGTON, DC

Regulatory Docket No. _

___________

IN THE MATTER OF THE PETITION FOR EXEMPTION OF:

WILLIAM SNEDEN

FOR AN EXEMPTION SEEKING RELIEF FROM THE REQUIREMENTS OF

TITLE 14 OF THE CODE OF FEDERAL REGULATIONS SECTIONS

61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1),

91.409(a)(1) & (a)(2), AND 91.417(a) & (b) CONCERNING COMMERCIAL

OPERATION OF DJI Phantom 2 Vision Plus UNMANNED AIRC RAFT

SYSTEMS PURSUANT TO SECTION 333 OF

THE FAA MODERNIZATION AND REFORM ACT OF 2012

(PUBLIC LAW 112

- 95)

Submitted on

WILLIAM SNEDEN

17344 14 Mile Road.

Battle Creek, Michigan 49014

269

- 967

- 4323

snedenmarc@gmail.comTABLE OF CONTENTS

Page

GLOSSARY OF ABBREVIATIONS..................................................................

... ........3

SUMMARY................................................................................................

..... ........4

INTRODUCTION AND INTERESTS OF PETITIONER.......................................

... ..........4

BACKGROUND............................................................................................

... .......4

BASIS FOR PETITION...............................................................................

. ... .. ........5

NAME AND ADDRESS OF P ETITIONER....................................................................6

THE SPECIFIC SECTIONS OF 14 C.F.R. FROM WHICH WILLIAM SNEDEN SEEKS

EXEMPTION................................................

............... ........................ .. ... ....6

THE EXTENT OF RELIEF WILLIAM SNEDEN SEEKS AND THE

REASON WILLIAM SNEDEN SEEKS THE RELIEF...

...... ....................................11

THE REASONS WHY GRANTING WILLIAM SNEDEN’S REQUEST

WOULD BE IN THE PUBLIC INTEREST ...................................................

. ......14

THE REASONS WHY GRANTING THE EXEMPTION WOULD NOT

ADVERSELY AFFECT SAFETY...............................................................

. ......16

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

. ........30

ANY ADDITIONAL INFORMATION, VIEWS, OR ARGUMENTS

AVAILABLE TO SUPPORT WILLIAM SNEDEN’S

R EQUEST......

............................................................... .............................31

CONCLUSION.....................................................................................................31

APPENDICES.....................................................................................................33GLOSSARY OF ABBREVIATIONS

AGL Above Ground Level

AOI Area of Interest

ATC Air Traffic Control

A TO Air Traffic Organization

AV Aerial Vehicle

CFR Code of Federal Regulations

COA Certificate of Authorization

FAA Federal Aviation Administration

FAR Federal Aviation Regulation

GCS Ground Control Station

GPS Global Positioning System

LOL Loss of Link

NAS National Airspace System

NOTAM Notice to Airman

PIC Pilot In Command

Section 333 FAA Modernization and Reform Act of 2012 (FMRA)

SO Safety Observer

SOP Standard Operatin g Procedures

UA Unmanned Aircraft

UAS Unmanned Aircraft System

VFR Visual Flight Rules

VLOS Visual Line of Site

VMC Visual Meteorological Conditions

VTOL Vertical Takeoff and LandingSUMMARY

WILLIAM SNEDEN seeks exemption from the requirements of 14 C.F.R §§

61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) &

(a)(2), and

, 91.417(a) & (b), to operate an Unmanned Aircraft System pursuant to Section 333 of

the FAA Moderniz ation and Reform Act of 2012 (FMRA). This exemption will permit

WILLIAM SNEDEN to operate an Unmanned Aircraft System (UAS) for the

commercial purpose of conducting aerial video and photography of real estate, golf courses and

landscape over certain areas of the United States.

INTRODUCTION AND INTERESTS OF THE PETITIONER

WILLIAM SNEDEN provides his clients with expertise and knowledge in advanced

technologies and solutions to increase efficiency, productivity and effectiveness.

WILLIAM SNEDEN has hundreds of hours flying experience. He has over 3 years

recreational/hobby experience operating Unmanned Aircraft Systems (UAS). The

objective of WILLIAM SNEDEN and his aerial operations is to provide high quality

imaging for a variety of commercial, public, and residential uses, specifically targeting but

not limited to:

• Real

- estate marketing

• Golf course marketing

BACKGROUND

Unmanned Aircraft Systems: DJI Phantom 2 Vision Plus UAS

WILLIAM SNEDEN seeks an exemption to operate DJI systems for compensation or

hire within the NAS. The DJI Phantom 2 Vision Plus is a vertical takeoff and landing

(VTOL) Unmanned Aircraft (UA) with a Ground Control Station (GCS) utilizing

electronic tablet or smart phone systems. The DJI Phantom 2 Vision Plus has a maximum gross

weight of approximately 2 pounds 13 ounces, while having a length of 16 inches width of 16

inches, height of 8 inches, and a maximum speed of approximately 31 knots. The DJI Phantom

2 Vision Plus UA is equipped with four main rotors; drive n by Lithium Polymer battery powered

electric motors. The DJI Phantom 2 Vision Plus UA that will be operated by WILLIAM

SNEDEN will be registered in accordance with 49 U.S.C. 44103, Registration of

Aircraft , as well as 14 C.F.R Part 47, Aircraft Registration , and marked in accordance with 14

C.F.R. Part 45, Identification and Registration Marking

.BASIS FOR PETITION

Petitioner, WILLIAM SNEDEN, pursuant to the provisions of the Federal

Aviation Regulations (14 C.F.R. § 11.61) and the FAA M odernization and Reform

Act of 2012 (FMRA), Section 333, Special Rules for Certain Unmanned Aircraft

Systems , hereby petitions the Administrator to commercially operate the DJI Phantom

2 Vision Plus UAS in the National Airspace System (NAS), and for an exe mption

from the requirements of 14 C.F.R §§ 61.113(a) & (b), 91.7(a), 91.121, 91.151(b),

91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b).

In consideration of the speed, weight, size, and limited operating area associated with the

unman ned aircraft and its operation, WILLIAM SNEDEN operation of DJI Phantom

2 Vision Plus UAS meets the conditions of FMRA Section 333 and therefore, will

not require an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H.

Accordingly, WI LLIAM SNEDEN requests relief from Sections 91.405(a),

91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b), as these sections set forth

requirements for maintenance that only apply to aircraft with an airworthiness certificate.

WILLIAM SNEDEN submits that the requested relief is proper since an equivalent

level of safety will be ensured. WILLIAM SNEDEN will use experienced personnel

or technicians to perform maintenance, alterations, or preventive maintenance on the

UASs using the methods, techniques, and practices prescribed in the operating

documents (i.e., Monthly Maintenance Log, and DJI Phantom 2 Vision Plus

Instruction Manual). Furthermore, WILLIAM SNEDEN will document and maintain

all maintenance records for the DJI Phantom 2 Vision Plus UAS.

Re lief from certain requirements of Section 61.113(a) and (b), entitled Private pilot

privileges and limitations: Pilot in command , is requested by WILLIAM SNEDEN to

the extent necessary to allow a Pilot in Command (PIC) holding a private pilot or higher

lev el certificate, as well as an airman medical certificate, and who has demonstrated, by

meeting minimum flight

- hour and currency requirements, that the PIC is able to safely

operate the DJI Phantom 2 Vision Plus UAS in a manner consistent with this

exempti on, including evasive and emergency maneuvers and maintaining appropriate

distances from people, vessels, vehicles and structures.

WILLIAM SNEDEN seeks relief from Section 91.7(a), entitled Civil aircraft

airworthiness , because the DJI Phantom 2 Vision Pl us UAS does not require an

airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H. As such,

WILLIAM SNEDEN submits that he will ensure that the DJI Phantom 2 Vision Plus UAS is in an

airworthy condition, prior to every flight, by determi ning that the

UAS is in compliance with the operating documents (i.e., Monthly Maintenance Log,

and DJI Phantom 2 Vision Plus Instruction Manual), and that the aircraft is in a

condition for safe flight.WILLIAM SNEDEN also seeks an exemption from the requirements of Section

91.121, entitled Altimeter Settings , as the DJI Phantom 2 Vision Plus UA will not

have a typical barometric altimeter onboard. However, altitude information of the DJI

Phantom 2 Vision Plus UA will be provided to the PIC via Global Positioning System (GPS)

equipment and radio communications telemetry data link, which downlinks

from the UA to the GCS for active monitoring of the flight path. This altitude information,

co mbined with WILLIAM SNEDEN’s operation of the DJI Phantom 2 Vision Plus UAS within

visual line of sight, at or below 500 feet AGL, will ensure a level of safety

equivalent to Section 91.121.

Additionally, WILLIAM SNEDEN seeks an exemption from the require ments of

Section 91.151(b), entitled Fuel requirements for flight in VFR conditions . WILLIAM

SNEDEN submits that safety will not be affected by operation of the DJI Phantom 2 Vision Plus

UA during daylight hours in visual meteorological conditions (VMC) un der

visual flight rules (VFR), with enough battery power to fly for a total duration of

cruising speed, to fly after that for at least 4.5 minutes.

In accordance with 14 C.F.R. § 11.81, WILLIAM SNEDEN provides the

following information in support of its pe tition for exemption:

A. Name And Address Of The Petitioner.

The name and address of the Petitioner and point of contact is:

WILLIAM SNEDEN

17344 14 Mile Road

Battle Creek, Michigan 49014

269

- 967

- 4323

snedenmarc@gmail.com

B. The Specific Sections Of 14 C.F.R. From Which WILLIAM SNEDEN Seeks

Exemption.

1. WILLIAM SNEDEN Seeks Exemption From The Requirements Of

Section 61.113(a) And (b).

Section 61.113, entitled Private pilot privileges and limitations: Pilot in command

, subsections (a) and (b) prescribe the following, in relevant part:

(a) No person who holds a private pilot certificate may act as a pilot in

command (PIC) of an aircraft that is carrying passengers or property for

compensation or hire; nor may that person, for compe nsation or hire, act as PIC

of an aircraft.

(b) A private pilot may, for compensation or hire, act as PIC of an aircraft in

connection with any business or employment if

—

(1) The flight is only incidental to that business or employment; and(2) The airc raft does not carry passengers or property for compensation or hire.

2.WILLIAM SNEDEN Seeks Exemption From The Requirements Of

Section 91.7(a).

Section 91.7, entitled Civil aircraft airworthiness , subsection (a), states the

f ollowing:

(a) No person may operate a civil aircraft unless it is in an airworthy condition.

3. WILLIAM SNEDEN Seeks Exemption From The Requirements Of

Section 91.121.

Section 91.121, entitled Altimeter settings, subsection (a), states the following, in

part:

(a) Each person oper ating an aircraft shall maintain the cruising altitude or

flight level of that aircraft, as the case may be, by reference to an altimeter that

is set, when operating

--

(1) Below 18,000 feet MSL, to

--

(i) The current reported altimeter setting of a statio n along the route and

within 100 nautical miles of the aircraft;

(ii) If there is no station within the area prescribed in paragraph (a)(1)(i)

of this section, the current reported altimeter setting of an appropriate

available station; or

(iii) In the case of an aircraft not equipped with a radio, the elevation of

the departure airport or an appropriate altimeter setting available before

departure.

4. WILLIAM SNEDEN Seeks Exemption From The Requirements Of

Section 91.151(b).

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

(b), states the following:

(b) No person may begin a flight in a rotorcraft under VFR conditions unless

(considering wind and forecast weather conditions) there is enough fuel to fly

to the firs t point of intended landing and, assuming normal cruising speed, to

fly after that for at least 20 minutes.

5. WILLIAM SNEDEN Seeks Exemption From The RequirementOf Section 91.405(a).

Section 91.405, entitled Maintenance required , subsection (a), states the following:

Each owner or operator of an aircraft

— (a) Shall have that aircraft inspected as prescribed in subpart E of this part and

shall between required inspections, except as provided in paragraph (c) of this

section, have discrepancies repa ired as prescribed in part 43 of this chapter[.]

6. WILLIAM SNEDEN Seeks Exemption From The Requirements

Of Section 91.407(a)(1)

Section 91.407, entitled Operation after maintenance, preventive maintenance,

rebuilding, or alteration , subsection (a)(1), s tates 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 return to service by a person authorized under §

43.7 of this chapter[.]

7. WILLIAM SNEDEN Seeks Exemption From The Requirements

Of Sections 91.409(a)(1) And 91.409(a)(2).

Section 91.409, entitled Inspections , subsection (a), states the following:

(a) Except as provided in paragraph (c) of this section, no person may operate

an aircraft unless, within the preceding 12 calendar months, it has had

-- (1) An annual inspection in accordance with part 43 of this chapter and has

been approved for return to service by a person authorized by § 43.7 of this

chapter; or

(2) An inspection for the issuance of an airworthiness certificate in

accordance with part 21 of this chapter.

8. WILLIAM SNEDEN Seeks Exemption From The Requirements

Of Sections 91.417(a) And 91.417(b).

Section 91.417, entitled Maintenance records , subsections (a) and (b ), state the

following:

(a) Except for work performed in accordance with §§ 91.411 and 91.413, each

registered owner or operator shall keep the following records for the periods

specified in paragraph (b) of this section:

(1) Records of the maintenance, pr eventive maintenance, and alteration and

records of the 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 of an aircraft. T he records must

include

-- (i) A description (or reference to data acceptable to the Administrator) of

the work performed; and

(ii) The date of completion of the work performed; and(iii) The signature, and certificate number of the person approving the

aircraft for return to service.

(2) Records containing the following information:

(i) The total time in service of the airframe, each engine, each propeller,

and each rotor.

(ii) The current status of life

- limited parts of each airframe, engine,

prope ller, rotor, and appliance.

(iii) The time since last overhaul of all items installed on the aircraft

which are required to be overhauled on a specified time basis.

(iv) The current inspection status of the aircraft, including the time

since the last inspe ction required by the inspection program under

which the aircraft and its appliances are maintained.

(v) The current status of applicable airworthiness directives (AD) and

safety directives including, for each, the method of compliance, the AD

or safety di rective number and revision date. If the AD or safety

directive involves recurring action, the time and date when the next

action is required.

(vi) Copies of the forms prescribed by § 43.9(d) of this chapter for each

major alteration to the airframe and cu rrently installed engines, rotors,

propellers, and appliances.

(b) The owner or operator shall retain the following records for the periods

prescribed:

(1) The records specified in paragraph (a)(1) of this section shall be retained

until the work is repeat ed or superseded by other work or for 1 year after the

work is performed.

(2) The records specified in paragraph (a)(2) of this section shall be retained

and transferred with the aircraft at the time the aircraft is sold.

(3) A list of defects furnished to a registered owner or operator under §

43.11 of this chapter shall be retained until the defects are repaired and the

aircraft is approved for return to service.

C. The Extent Of Relief WILLIAM SNEDEN Seeks And The Reason

WILLIAM SNEDEN Seeks The Relief.

1. Extent Of Relief WILLIAM SNEDEN Seeks And The Reason

WILLIAM SNEDEN Seeks Relief From Section 61.113(a) And (b).

Relief from Section 61.113(a) and (b) entitled Private pilot privileges and limitations:

Pilot in command , is requested to the extent nec essary to allow a PIC holding a private

pilot or higher level certificate, as well as a current and valid airman medical certificate,

and who has met certain flight

- hour and currency requirements, to conduct the proposed

UAS flight operations for compensat ion or hire.This relief is requested since the limitations set

forth in Section 61.113(a) and (b) state thata 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 onlyin cidental to that business or employment; and (2) The aircraft does not carry passengers or

property for compensation or hire. As set forth more fully below, WILLIAM SNEDEN submits that

an equivalent level of safety will be maintained because no PIC will be allowed to operate the

DJI Phantom 2 Vision Plus UAS unless that PIC has met certain flight

- hour and currency

requirements, demonstrating that the PIC is able to safely operate either the DJI Phantom 2

Vision Plus UAS in a manner consistent with the opera tions specifications as

described in this exemption, including evasive and emergency maneuvers, as well as

maintain WILLIAM SNEDEN submits that all flights of the DJI Phantom 2 Vision Plus UAS,

conducted by the PIC pursuant to the grant of this Petition: ( 1)

will be incidental to WILLIAM SNEDEN’s business; and (2) will not carry

passengers or property for compensation or hire.

2. Extent Of Relief WILLIAM SNEDEN Seeks Relief And The Reason

WILLIAM SNEDEN Seeks Relief From Section 91.7(a).

Relief from Sect ion 91.7(a) entitled Civil aircraft airworthiness , is requested to the extent

required to allow WILLIAM SNEDEN to determine that the DJI Phantom 2 Vision Plus UAS is in

airworthy condition prior to every flight by ensuring that the UAS is

in compliance wit h the operating documents (i.e., the WILLIAM SNEDEN Aerial

Operations Manual, Monthly Maintenance Log, and DJI Phantom 2 Vision Plus

Instruction Manual).

WILLIAM SNEDEN seeks the requested relief because the DJI Phantom 2 Vision Plus UAS

does not require an airworthiness certificate in accordance with 14 C.F.R.

Part 21, Subpart H. Therefore, WILLIAM SNEDEN will ensure that the DJI Phantom

2 Vision Plus UAS is in airworthy condition based upon its compliance with the

operating documents (i.e., Monthly Maint enance Log, and DJI Phantom 2 Vision Plus Instruction

Manual) prior to every flight, and further, determine that the aircraft is in

condition for safe flight, as stated in the conditions and limitations below.

3. Extent Of Relief WILLIAM SNEDEN Seeks And The Reason

WILLIAM SNEDEN Seeks Relief From Section 91.121.

Relief from Section 91.121, entitled Altimeter settings, may be required to allow flight

operations of the DJI Phantom 2 Vision Plus 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 information concerning UAS operations be

reported to air traffic control (ATC) in feet above ground level (AGL), WILLIAM SNEDEN seeks

the requested relief because the DJI Phantom 2 Vision Plus UA’s altimeter may be set on the

ground to zero feet AGL, rather than the local barometric pressure or field altitude, before each

fligh t. 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 Phantom 2 Vision Plus UA is equipped with a barometric

pressure sensor and GPS equipment, which automatically ensures that a ground level

pressure setting will be established prior to each flight, and provides the PIC wit h altitude

information of the UA on the heads

- up display of the GCS.4. Extent Of Relief WILLIAM SNEDEN Seeks And The Reason

WILLIAM SNEDEN Seeks Relief From Section 91.151(b).

Relief from Section 91.151(b) entitled Fuel requirements for flight in VFR conditions, is

requested to the extent required to allow flights of the battery powered DJI Phantom 2 Vision

Plus UA during daylight hours in visual meteorological conditions (VMC), under

visual flight rules (VFR), for a total duration of 13.5 minutes to t he first point of intended

landing and, assuming normal cruising speed, to fly after that for at least 4.5 minutes.

WILLIAM SNEDEN seeks the requested relief because without an exemption from

Section 91.151(b), the flight time duration of the battery power ed DJI Phantom 2 Vision Plus UA

will severely constrain the practicality of any aerial video or still photo

flight operations that WILLIAM SNEDEN proposes to conduct pursuant to this

Petition.

Significantly, as set forth below, the technical specifications of the DJI Phantom 2 Vision Plus

UAS, the DJI Phantom 2 Vision Plus operating documents, and

WILLIAM SNEDEN’s proposed operating limitations, ensure that WILLIAM SNEDEN will safely

operate the battery powered DJI Phantom 2 Vision Plus UA during daylight h ours in visual

meteorological conditions (VMC), under visual flight rules (VFR), with enough battery power to

fly for a total duration of 13.5 minutes to the first point of intended landing and, assuming normal

cruising speed, to fly after that for at leas t 4.5 minutes.

5. Extent Of Relief WILLIAM SNEDEN Seeks And The Reason

WILLIAM SNEDEN Seeks Relief From Sections 91.405(a),

91.407(a)(1), 91.409(a)(1) & (a)(2), And 91.417(a) & (b).

Since Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.41 7(a) & (b) only

apply to aircraft with an airworthiness certificate, WILLIAM SNEDEN requests

relief from these Sections because the DJI Phantom 2 Vision Plus UAS does not

require airworthiness certificates. As set forth more fully below, the DJI Phantom 2 Vision Plus

UAS meet the conditions of FMRA Section 333 for operation without an airworthiness certificate.

Accordingly, WILLIAM SNEDEN will use trained technicians to perform maintenance,

alterations, or preventive maintenance on the UAS using the methods , techniques, and

practices prescribed in the UAS operating documents (i.e., the WILLIAM SNEDEN Aerial

Operations Manual, Monthly Maintenance Log, and DJI Phantom 2 Vision Plus Instruction

Manual). Furthermore, WILLIAM SNEDEN will document and maintain all maintenance records

for the DJI Phantom 2 Vision Plus UAS.

D. The Reasons Why Granting WILLIAM SNEDEN Request Would Be In

The Public Interest; That Is, How It Would Benefit The Public As A Whole.

Granting the present Petition will further the public int erest by allowing WILLIAM SNEDEN to

safely, efficiently, and economically perform aerial video and photography of construction sites,

real estate, and landscape over certain areas of the United States.

Additionally, use of the DJI Phantom 2 Vision Plus UAS will decrease congestion

of the NAS, reduce pollution, and provide significant benefits to the economy. Notably, the

benefits of WILLIAM SNEDEN’s proposed operation of the DJI Phantom 2 Vision Plus UAS will

be realized without implicating any privacy issu es.

1. The Public Will Benefit From Decreased Congestion Of The NAS.The DJI Phantom 2 Vision Plus UA is 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 aerial

acquisitions, an exemption allowing the use of a DJI Phantom 2 Vision Plus UAS

would reduce the amount of manned aircraft in the NAS, reduce noise and air pollution, as

well as in crease 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 Phantom

2 Vision Plus UA does not require an airport to takeoff or land. Likewise, a reduction

of manned aircraft conducting aerial video and photography missions would result in fewer

aircraft that must be handled by air traffic control during the ground, takeoff, depart ure,

arrival, and landing phases of flight operations.

2. The Public Will Benefit From The Safety And Efficiency Of The DJI

Phantom 2 Vision Plus UAS.

Conducting aerial acquisitions with the DJI Phantom 2 Vision PLus UAS, instead of

manned aircraft, will greatly benefit the public by drastically reducing the levels of air and

noise pollution generated during traditional aerial video and still photography flight

operations. By using battery power and electric motors, the DJI Phantom 2 Vision Plus UAS

produce no air pollution, and is the most viable environmentally conscious alternative to the

cabin class, six cylinder internal combustion engine aircraft that are typically utilized for aerial

video and photography, while burning approximately 20

- 30 gallons per hour of leaded aviation

fuel. The DJI Phantom 2 Vision Plus UA, while reducing the carbon footprint of aerial

acquisitions, also eliminates noise pollution, as the UA is propelled by battery powered electric

motors, rather than an interna l combustion engine.

By using the DJI Phantom 2 Vision Plus UAS to perform aerial acquisitions, the

substantial risk to life and property in the air and on the ground, which is usually

associated with traditional manned aircraft flight operations, will be substantially reduced

or completely eliminated. Aside from the lack of flight crew members located onboard the

aircraft, the JI Phantom 2 Vision Plus UA (weighing approximately 2 pounds 11

ounces, at it’s maximum gross weight with a length of 16 inches, wi dth of 16 inches , and with

no fuel on board), has less physical potential for collateral damage to life and property on the

ground, and in the air, compared to the manned aircraft that typically conduct similar operations

(weighing approximately 6,000 pou nds with a wingspan of approximately 42 feet, a length of 34

feet, and a fuel capacity of 180 gallons).

3. Performing Aerial Video and Photography Operations With The DJI

Phantom 2 Vision Plus UAS Will Benefit The Economy.

In addition to being safe and efficient, the DJI Phantom 2 Vision Plus UAS is also

an economical alternative to using manned aircraft to conduct similar aerial operations. As

such, operation of the JI Phantom 2 Vision Plus UAS will allow United States

based companies, like WILLIAM SNED EN, 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 compan ies must adopt new and alternative technology in

order to remain competitive. Operating the battery powered DJI Phantom JI Phantom 2 Vision

Plus UAS is one such technology that not only allows companies greater operationalflexibility compared to manned ai rcraft, but provides such flexibility without the high

operational cost of a traditional manned aircraft.

By operating the DJI Phantom 2 Vision Plus UAS, companies such as WILLIAM SNEDEN, can

remain competitive and profitable, and therefore, provide greate r job stability to

employees and contractors, which will ultimately contribute to growth of the

U.S. economy. Improved financial performance of U.S. companies, through commercial

use of the DJI Phantom 2 Vision Plus UAS, provides a stable workforce that

i ncreases 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 ma nned aerial acquisition flight operations that have been conducted for

decades, WILLIAM SNEDEN’s proposed operation of the DJI Phantom 2 Vision Plus UAS will

not implicate any privacy issues. Specifically, the DJI Phantom 2 Vision Plus UAS will be

operated only in compliance with operating documents (i.e., the WILLIAM SNEDEN Aerial

Operations Manual, Monthly Maintenance Log, and DJI Phantom 2 Vision Plus Instruction

Manual) which requires property owner involvement as well as local law enforcement

notificat ion, and in accordance with the Federal Aviation Regulations, including the minimum

altitude requirements of 14 C.F.R. § 91.119.

E. The Reasons Why Granting The Exemption Would Not Adversely Affect Safety,

Or How The Exemption Would Provide A Level Of Safety At Least Equal To That

Provided By The Rule From Which WILLIAM SNEDEN Seeks Exemption.

1. Reasons Why The DJI Phantom 2 Vision Plus UA Meet The

Conditions Of The FAA Modernization and Reform Act of 2012 (FMRA)

Section 333.

In consideration of the size, weight, speed, and limited operating area associated with the

unmanned aircraft and its operation, WILLIAM SNEDEN’s operation of the DJI Phantom 2

Vision Plus UAS meet the conditions of FMRA Section 333, and will not require an airworthiness

certific ate in accordance with 14 C.F.R. Part 21, Subpart H.

Section 333 provides authority for a UAS to operate without airworthiness certification and sets

forth requirements for considering whether a UAS will create a hazard to users of the NAS or the

public, or otherwise pose a threat to national security. Specifically, FMRA Section 333 states the

following, in part:

(a) In General.

-- Notwithstanding any other requirement of this subtitle, and not

later than 180 days after the date of enactment of this Act, th e Secretary of

Transportation shall determine if certain unmanned aircraft systems may operate

safely in the national airspace system before completion of the plan and

rulemaking required by section 332 of this Act or the guidance required by section

334 o f this Act.

(b) Assessment of Unmanned Aircraft Systems.

-- In making the determination

under subsection (a), the Secretary shall determine, at a minimum

—(1) which types of unmanned aircraft systems, if any, as a result of their

size, weight, speed, operational capability, proximity to airports and

populated areas, and operation within visual line of sight do not create a

hazard to users of the national airspace system or the public or pose a

threat to national security; and

(2) whether a certificate of waiver, certificate of authorization, or

airworthiness certification under section 44704 of title 49, United States

Code, is required for the operation of unmanned aircraft systems identified

under paragraph (1).

(c) Requirements for Sa fe Operation.

-- If the Secretary determines under this section that

certain unmanned aircraft systems may operate safely in the national airspace system,

the Secretary shall establish requirements for the safe operation of such aircraft systems

in the natio nal airspace system.

In seeking this exemption, WILLIAM SNEDEN submits that the DJI Phantom 2 Vision Plus UAS

can operate safely in the NAS pursuant to FMRA Section 333, as demonstrated by: (a) the

characteristics of the DJI Phantom 2 Vision Plus UAS; (b ) the pilot certification requirement; and

(c) the specific operating limitations.

a. The Specifications Of The DJI Phantom 2 Vision Plus UAS

Demonstrate s Its Safe Characteristics.

The DJI Phantom 2 Vision Plus UAS do es not create a hazard to users of the NAS or

the public, or otherwise pose a threat to national security considering its size, weight,

speed, and operational capability.

i. Technical Specifications Of The DJI Phantom 2 Vision Plus UAS.

The technical specifications of the DJI Phantom 2 Vision Plus UAS are set forth by

the DJI Phantom 2 Vision Plus UAS User Manual , attached hereto as Appendix A.

ii. The DJI Phantom 2 Vision Plus UAS Autonomous Flight

And Navigation M odes Enable The UAS To Remain Within A

Defined Operational Area.

The DJI Phantom 2 Vision Plus UAS may be operated in both manual and fully

autonomous flight modes. A complete description of the flight and navigational modes of

the DJI Phantom 2 Vision Plus UAS is provided at pages 26

- 36 of the DJI Phantom 2 Vision

Plus UAS User Manual, attached hereto as Appendix A.

iii. The DJI Phantom 2 Vision Plus UAS IS Designed For

Automatic Return To Home Point Or Hover In The Event Of Loss

Of The Control Link Or Navigation.

When the C ontrol Link is lost, the DJI Phantom 2 Vision Plus UA will remainstationary, in flight, for 3 seconds or more. If, after 3 seconds, the DJI Phantom 2 Vision Plus UA

do not reacquire control link data from the GCS, the UA will assume that

the Control Link is lost and the UA will return to the home position (i.e., failsafe mode)

via GPS, and will descend to the takeoff position and shutdown.

A complete description of the Failsafe Functions of the DJI Phantom 2 Vision Plus UAS are set

forth at pages 31 throug h 34 of the DJI Phantom 2 Vision Plus User Manual, attached hereto as

Appendix A.

iv. The DJI Phantom 2 Vision Plus UAS GCS And Its Operation.

A complete description of the operation and specifications of the DJI Phantom 2 Vision Plus

UAS GCS and flight control software is provided at pages 42 through 60 of the DJI Phantom 2

Vision Plus User Manual. DJI Phantom 2 Vision Plus User Manuals are attached hereto as

Appendix A.

b. Flight Operations Of DJI Phantom 2 Vision Plus UAS Is

Limited To The Line Of Sight Of A Certificated Pilot in Command With

A Safety Observer.

WILLIAM SNEDEN will contract a licensed pilot to act as a pilot in command (PIC) of the

DJI Phantom 2 Vision Plus UAS. Additionally, WILLIAM SNEDEN will act as a safety observer to

assist t he contracted pilot during flight time.

c. Flights Of DJI Phantom 2 Vision Plus UAS Will Be Conducted

Pursuant To Specific Operating Limitations.

In	seeking	this	exemption,	WILLIAM	SNEDEN	proposes	to	commercially	operate

DJI Phantom 2 Vision Plus UAS fo r	the	special	purpose	of	conducting	aerial	video

and	photography	over	certain	areas	of	United	States,	pursuant	to	the	following	specific

operating	limitations:

1.	Operations	authorized	by	this	grant	of	exemption	will	be	limited	to	the

following	aircraft	d escribed	in	the	operating	documents,	rotorcraft	UASs

weighing	less	than	55	pounds	maximum	gross	weight:

Unmanned	Aircraft	System .	Proposed	operations	of	any	other	aircraft

will	require	a	new	petition	or	a	petition	to	amend	this	grant.

2.	UAS	operations under	this	exemption	will	be	limited	to	conducting	operations

for	the	purpose	of	aerial	video	and	photography.

3.	The	UA may	not	be	flown	at	an	indicated	airspeed	exceeding	20	knots.

4.	The	UA	must	be	operated	at	an	altitude	of	no	more	than	500	feet	abov e

ground	level	(AGL),	as	indicated	by	the	procedures	specified	in	the	operating

documents	unless	a	special	request	is	made	and	approved	by	ATC.	All	altitudes

reported	to	ATC	must	be	in	feet	AGL.5.	The	UAs	must	be	operated	within	visual	line	of	sight	(VLO S)	of	the	PIC	at	all

times.	This	requires	the	PIC	to	be	able	to	use	human	vision	unaided	by	any

device	other	than	corrective	lenses,	as	specified	on	the	PIC’s	FAA

- issued	airman

medical	certificate.

6.	The	use	of	first	person	view	(FPV)	by	the	PIC	or	safet y	observer	(SO)	is	not

permitted.

7.	All	operations	must	utilize	a	safety	observer	(SO).	The	SO	may	be	used	to

satisfy	the	VLOS	requirement	as	long	as	the	PIC	always	maintains	VLOS

capability.	The	SO	and	PIC	must	be	able	to	communicate	verbally	at	all	tim es.

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 the duration of the flight. The PIC must ensure that the SO can

perform the functions prescribed in the operating documents.

8. The SO must not perform any other duties beyond assisting the PIC with

seeing and avoiding other air traffic and other ground based

obstacles/obstructions and is not permitted to operate the camera or other

instruments.

9. The operating documents and the grant of exemption must be accessible

during UAS operations and made available to the Administrator upon request. If

a discrepancy exists between the conditions and limitations contained in the

grant of exemption and the procedures outlined in the operating documents, the

conditions and limitations contained in the grant of exemption take precedence

and must be followed. Otherwise, the operator must follow the procedures as

outlined in its operat ing documents. The operator may update or revise its

operating documents. It is the operator’s responsibility to track such revisions

and present updated and revised documents to the Administrator upon request.

The operator must also present updated and re vised documents if it petitions for

extension or amendment to the grant of exemption. If the operator determines

that any update or revision would affect the basis upon which the FAA granted

the exemption, then the operator must petition for amendment to i ts grant of

exemption. The FAA’s UAS Integration Office (AFS

- 80) may be contacted if

questions arise regarding updates or revisions to the operating documents.

10. Prior to each flight the PIC must inspect the UAS to ensure that it is in a

condition for safe flight. If the inspection reveals a condition that affects the

safe operation of the UAS, the aircraft is prohibited from operating until the

necessary maintenance has been performed and the UAS is found to be in a

condition for safe flight. The Ground Control Station must be included in the

preflight inspection. All maintenance and alterations must be properly

documented in the aircraft records.

11. Any UAS that has undergone maintenance or alterations that affect the UASoperation or flight ch aracteristics, e.g. replacement of a flight critical

component, must undergo a functional test flight. The PIC who conducts the

functional test flight must make an entry in the aircraft records.

12. The pre

- flight inspection must account for all potentia l discrepancies, e.g.

inoperable components, items, or equipment, not already covered in the

relevant sections of the operating documents.

13. The operator must follow the UAS manufacturer’s aircraft/component,

maintenance, overhaul, replacement, inspection, and life limit requirements.

14. The operator must carry out its maintenance, inspections, and record

keeping requirements, in accordance with the operating documents.

Maintenance, inspection, alterations, and status of replacement/overhaul

c omponent parts must be noted in the aircraft records, including total time in

service, description of work accomplished, and the signature of the authorized

person returning the UAS to service.

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

manufacturer Safety Bulletins.

16. The authorized person must make an entry in the aircraft record of the

corrective action taken against discrepancies discovered between inspections.

17. The PIC must possess at least a private pilot certificate a nd at least a current

third

- class medical certificate.

18. The operator may not permit any PIC to operate unless the PIC meets the

operator’s qualification criteria and demonstrates the ability to safely operate

the UAS in a manner consistent with how t he UAS will be operated under the

exemption, including evasive and emergency maneuvers and maintaining

appropriate distances from persons, vessels, vehicles and structures. PIC

qualification flight hours must be logged in a manner consistent with 14 C.F.R.

§ 61.51(b). Flights for the purposes of training the operator’s PICs are

permitted under the terms of the exemption. However, training operations may

only be conducted during dedicated training sessions. During training,

proficiency, and experience

- buildi ng flights, all persons not essential for flight

operations are considered nonparticipants, and the PIC must operate the UA

with appropriate distance from nonparticipants in accordance with 14 C.F.R. §

91.119.19. UAS operations may not be conducted duri ng night, as defined in 14 C.F.R.

§ 1.1. All operations must be conducted under visual meteorological conditions

(VMC). If flight at night is required, a special request will be made at the FAA

office closest to proposed area of operations. Flights under s pecial visual flight

rules (SVFR) are not authorized.

20. The UA may not operate within 5 nautical miles of an airport reference

point as denoted on a current FAA

- published aeronautical chart unless a letter

of agreement with that airport’s management is obtained, and the operation is

conducted in accordance with a NOTAM as required by the operator’s COA.

The letter of agreement with the airport management must be made available to

the Administrator upon request.

21. The UA may not be operated less than 500 feet below or less than 2,000

feet horizontally from a cloud or when visibility is less than 3 statute miles

from the PIC.

22. If the UA loses communications or loses its GPS signal, it must return to a

pre

- determined location within the planned operating area and land or be

recovered in accordance with the operating documents.

23. The PIC must abort the flight in the event of unpredicted obstacles or

emergencies in accordance with the operating documents.

24. The PIC is prohibited from beginn ing a flight unless (considering wind and

forecast weather conditions) there is enough power to fly at normal cruising

speed to the intended landing point and land the UA with 25% battery power

remaining.

25. The operator must obtain an Air Traffic Organ ization (ATO) issued

Certificate of Waiver or Authorization (COA) prior to conducting any

operations under the grant of exemption. This COA will also require the

operator to request a Notice to Airman (NOTAM) not more than 72 hours in

advance, but not less than 48 hours prior to the operation. All operations shall

be conducted in accordance with airspace requirements in the ATO issued COA

including class of airspace, altitude level and potential transponder

requirements.

26. All aircraft operated in accordance with the exemption must be identified by

serial number, registered in accordance with 14 C.F.R. part 47, and have

identification (N

- Number) markings in accordance with 14 C.F.R. part 45,

Subpart C. Markings must be as large as practicable.27 . Before conducting operations, the radio frequency spectrum used for

operation and control of the UA must comply with the Federal Communications

Commission (FCC) or other appropriate government oversight agency

requirements.

28. The documents required f ewer than 14 C.F.R. 91.9 and 91.203 must be

available to the PIC at the Ground Control Station of the UAS any time the

UAS is operating. These documents must be made available to the

Administrator or any law enforcement official upon request.

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

operations and activities at all times.

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

31. Flight operations must be conducted at least 500 feet from all

nonparticipating persons (persons other than the PIC, SO, operator trainees or

essential persons), vessels, vehicles, and structures unless:

a. Barriers or structures are present that sufficiently protect

nonparticipating persons from the UA and/or debris in the event of an

accident. The operator must ensure that nonparticipating persons remain

under such protection. If a situation arises where nonparticipating

persons leave such protection and are within 500 feet of the U A, flight

operations must cease immediately and/or;

b. The aircraft is operated near vessels, vehicles or structures where the

owner/controller of such vessels, vehicles or structures has granted

permission and the PIC has made a safety assessment of the risk of

operating closer to those objects and determined that it does not present

an undue hazard, and;

c. Operations nearer to the PIC, SO, operator trainees or essential persons

do not present an undue hazard to those persons per § 91.119(a).

32. All operations shall be conducted over private or controlled

- access property

with permission from the land owner/controller or authorized representative.

Permission from land owner/controller or authorized representative will be

obtained for each flight to be conducted.33. Any incident, accident, or flight operation that transgresses the lateral or

vertical boundaries of the operational area as defined by the applicable COA

must be reported to the FAA's UAS Integration Office (AFS

- 80) within 24

hours. Accidents must be reported to the National Transportation Safety Board

(NTSB) per instructions contained on the NTSB Web site: www.ntsb.gov

.

2. Reasons Why An Exemption From The Requirements Of Section

61.113(a) And (b) Would Not Adversely Affect Safety.

WILLIAM SNEDEN submits that the equivalent level of safety established by Section

61.113(a) and (b) will be maintained because no PIC will be allowed to operate the DJI Phantom

2 Vision Plus UA S unless that PIC has demonstrated, by meeting minimum flight

- hour and

currency requirements, that the PIC is able to safely operate the DJI Phantom 2 Vision Plus

UAS in a manner consistent with the exemption, including evasive and emergency maneuvers

and maintaining appropriate distances from people, vessels, vehicles and structures.

Considering WILLIAM SNEDEN ’s proposed area of operations, and the operating

limitations set forth

- above; the parallel nature of private pilot aeronautical knowledge

requireme nts to those of commercial pilot requirements (See Exemption No. 11062); and

the airmanship skills necessary to safely operate the DJI Phantom 2 Vision Plus UAS

, WILLIAM SNEDEN submits that the additional manned airmanship experience of a

commercially cert ificated pilot would not correlate to the airmanship skills necessary for

WILLIAM SNEDEN ’s specific proposed flight operations.

The FAA has previously granted relief from Section 61.113(a) and (b) specific to UAS, in

circumstances similar, in all material respects, to those 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).

WILLIAM SNEDEN will not allow any PIC to operate the DJI Phantom 2 Vision Plus UAS unless

that PIC has demonstrated, by meeting minimum flight

- hour requirements or

the DJI Phantom 2 Vision Plus UAS training and currency requirements, that the PIC

is able to safely operate the DJI Phantom 2 Vis ion Plus UAS in a manner consistent

with this exemption, including evasive and emergency maneuvers and maintaining

appropriate distances from people, vessels, vehicles and structures.

Specifically, the PIC must have accumulated and logged, in a manner con sistent with 14

C.F.R. § 61.51(b), 25 hours of total time as a UAS rotorcraft pilot (with a minimum of 5

hours of those hours as a UAS pilot operating the same make and model of UAS to be used

for operations under the exemption). In addition to the hour re quirements, the PIC must

accomplish 3 takeoffs and landings in the preceding 90 days (for currency purposes).

As in Exemption Nos. 11062, 11138, and 11153, prior documented flight experience that

was obtained in compliance with applicable regulations will ensure an equivalent level of

safety during WILLIAM SNEDEN ’s proposed operations. The Administrator hasheld that prior documented flight experience that was obtained in compliance with applicable

regulations would ensure safe operations, stating as follo ws:

In Exemption No. 11062, the FAA required that prior to conducting operations for

the purpose of motion picture filming (or similar operations), the PIC must have

accumulated and logged, in a manner consistent with 14 CFR 61.51(b), 25 hours

of total time as a UAS rotorcraft pilot including at least 10 hours logged as a UAS

pilot with a multi

- rotor UAS. Prior to operations under Exemption No. 11062, the

PIC must also have accumulated and logged a minimum of 5 hours as a UAS pilot

operating the same mak e and model of UAS to be used for operations under the

exemption. For clarification, the FAA considers these minimum hour requirements

to be inclusive rather than additive; i.e. 5 hours make and model time may be

included in the 10 hours of multi

- rotor tim e and the 10 hours may be included in

the total 25 hours of UAS rotorcraft time. In addition to the hour requirements, the

PIC must accomplish 3 takeoffs and landings in the preceding 90 days (for

currency purposes). The FAA finds that at a minimum, the fl ight

- hour requirements

in Exemption No. 11062 are appropriate to practice and build proficiency in the

skills necessary to safely conduct the petitioner’s proposed operations. The FAA

also finds that prior documented flight experience that was obtained in compliance

with applicable regulations would satisfy this requirement. Training, proficiency,

and experience

- building flights can also be conducted under the grant of

exemption to accomplish the required flight time. During training, proficiency, and

experience

- building flights the PIC is required to operate the UA with appropriate

distances in accordance with 14 C.F.R 91.119.

Exemption No. 11138 at page 15.

Accordingly, WILLIAM SNEDEN will ensure safe operations by not allowing any

PIC to operate the DJI Phantom 2 Vision Plus UAS unless that PIC has demonstrated,

by meeting minimum flight

- hour and currency requirements, that the PIC is able to safely

operate the DJI Phantom 2 Vision Plus UAS in a manner consistent with the

exemption, including evasive and emergency maneuvers and maintaining appropriate

distances from people, vessels, vehicles and structures.

3. Reasons Why An Exemption From The Requirements Of Section 91.7(a)

Would Not Adversely Affect Safety.

The equivalent level o f safety established by Section 91.7(a) will be maintained because

prior to every flight, WILLIAM SNEDEN will ensure that the DJI Phantom 2 Vision Plus UAS is in

an airworthy condition based upon the UAS’s compliance with its

operating documents and as sta ted in the conditions and limitations herein.

Additionally, the FAA has previously granted relief from Section 91.7(a) specific to UAS,

in circumstances similar, in all material respects, to those presented herein (e.g. Exemption

Nos. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 11112, 11136,

11138, 11150, 11153, 11156, 11157, 11158, 11159, 11160, 11161).

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

The equivalent level of safet y established by Section 91.121 will be maintained because

the altitude information of the DJI Phantom 2 Vision Plus UA will be provided to

the PIC via GPS equipment and a radio communications telemetry data link, which

downlinks from the UA to the GCS for active monitoring of the flight path and altitude.

This altitude information, combined with WILLIAM SNEDEN’s operation of the DJI Phantom 2

Vision Plus UA within visual line of sight, at or below 500 feet AGL,

will ensure a leve l of safety equivalent to Section 91.121. The altitude information will be

generated by GPS equipment installed onboard the aircraft. Prior to each flight, a zero

altitude initiation point is automatically established by the UASs at ground level.

The FAA has previously granted relief from Section 91.121 specific to UAS, in

circumstances similar, in all material respects, to those presented herein (e.g. Exemption

Nos. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11112, 11136, 11138,

11150, 11153, 11156, 11157, 11158, 11159, 11160, 11161).

5. Reasons Why An Exemption From The Requirements Of Section

91.151(b) Would Not Adversely Affect Safety.

A grant of this exemption would ensure an equivalent level of safety established by 14

C.F.R. Section 9 1.151(b) as a result of (1) the technical specifications of the DJI Phantom 2

Vision Plus UAS ; (2) the limitations on the proposed flight operations; and (3) the

location of the proposed flight operations. Accordingly, WILLIAM SNEDEN will

ensure that it wi ll safely operate the battery powered DJI Phantom 2 Vision Plus UA

during daylight hours in VFR conditions, with enough battery power to fly for a total

duration of 13.5 minutes to the first point of intended landing and, assuming normal cruising

speed, to fly after that for at least 4.5 minutes.

Here, as in Exemption No. 11109, the technical specifications of the DJI Phantom 2 Vision Plus

UAS ; the limitations on the proposed flight operations; and the location of

the proposed operations, will ensure an eq uivalent level of safety established by 14 C.F.R.

Section 91.151(b). Furthermore, safety will be ensured as the DJI Phantom 2 Vision Plus UAS

provide audible and visual warnings to the PIC at the GCS when the UAs

experiences low battery voltage, the first warning occurring at approximately 33%

remaining battery power, and again at approximately 10% remaining battery power. At the

critically low battery level, the DJI Phantom 2 Vision Plus UAS will descend and

land automatical ly.

Significantly, previous exemptions granted by the FAA concerning Section 91.151

establish that safety is not adversely affected when the technical characteristics and

operating limitations of the UAS are considered. Relief has been granted for manned

aircraft to operate at less than the minimums prescribed in Section 91.151, including

Exemption Nos. 2689, 5745, and 10650. Moreover, the FAA has previously granted relief

from Section 91.151 specific to UAS, in circumstances similar, in all material respe cts, to

those presented herein (e.g. Exemption Nos. 8811, 10808, 10673, 11042, 11062, 11063,

11064, 11065, 11066, 11067, 11080, 11109, 11110, 11136, 11138, 11150, 11153, 11156,11157, 11158, 11159, 11160, 11161).

6. Reasons Why An Exemption From The Requi rements Of Sections

91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), And 91.417(a) & (b) Would

Not Adversely Affect Safety.

In seeking this exemption, WILLIAM SNEDEN submits that the equivalent level of

safety with regard to the regulatory maintenance and alteration requirements established by

Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b) will be met

because WILLIAM SNEDEN will use trained technicians to perform maintenance,

alterations, or preventive maintenance on the UASs using the methods, techniques, and

practices prescribed in the operating documents (i.e., the WILLIAM SNEDEN Aerial

Operations Manual, Monthly Maintenance Log, and DJI Phantom 2 Vision Plus

Instruction Manual). Furthermore, WILLIAM SNEDEN will document an d maintain

all maintenance records for the DJI Phantom 2 Vision Plus UAS

.

Since the DJI Phantom 2 Vision Plus UAS will be inspected as prescribed by the

operating documents, WILLIAM SNEDEN will maintain the equivalent level of

safety established by Sectio ns 91.405(a), 91.409(a)(1), and 91.409(a)(2). A copy of the

DJI Phantom 2 Vision Plus UAS User Manual is attached hereto as Appendix A and B;

a copy of the DJI Phantom 2 Vision Plus UAS Maintenance LOG is attached hereto

as Appendix C.

Likewise, the exemp tion sought will not adversely affect safety because

WILLIAM SNEDEN will use trained technicians to perform maintenance,

alterations or preventive maintenance on the UAS using the methods, techniques, and practices

prescribed by the operating documents.

F urthermore, the exemption sought would maintain an equivalent level of safety

established by Sections 91.407, 91.417(a) and 91.417(b), because all maintenance of the

DJI Phantom 2 Vision Plus UAS will be performed by trained technicians.

Maintenance will be documented and maintained utilizing the monthly maintenance log.

Significantly, previous exemptions granted by the FAA concerning Sections 91.405(a),

91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b) establish that safety is not

adversely affect ed when the technical characteristics and operating limitations of the UAS

are considered.

In consideration of WILLIAM SNEDEN ’s proposed operating limitations, the

operating documents, and the technical aspects of the DJI Phantom 2 Vision Plus UAS

, WILLIAM SNEDEN submits that safety will not be adversely affected by

granting exemption from 14 C.F.R. Sections 91.405(a), 91.407(a)(1) and (a)(2),

91.409(a)(2), and

91.417(a) and (b). The FAA has previously granted relief specific to UAS in circumstances

similar, in all material respects, to those presented herein (e.g. Exemption Nos. 11062,

11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 11112, 11136, 11138, 11150,

11153, 11156, 11157, 11158, 11159, 11160, 11161).7. The FAA May Prescribe Any Oth er Conditions For Safe Operation.

In accordance with Section 333 of the FAA Modernization and Reform Act of 2012

(FMRA) and 14 C.F.R. § 21.16 entitled Special Conditions, WILLIAM SNEDEN

requests that the FAA prescribe special conditions for the intended o peration of the DJI

Phantom 2 Vision Plus UAS , which contain such safety standards that the

Administrator finds necessary to establish a level of safety equivalent to that established by

14 C.F.R. Part 21, Subpart H, and 14 C.F.R §§ 61.113(a) & (b), 91.7 ( a), 91.121,

91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b). Such

special conditions will permit safe operation of the UAs for the limited purpose of

conducting aerial video and photography over certain areas of the United St ates for

compensation or hire. FMRA Section 333 sets forth the requirements for considering

whether a UAS will create a hazard to users of the NAS or the public, or otherwise pose a

threat to national security; and further, provides the authority for such UAS to operate

without airworthiness certification in accordance with any requirements that must be

established for the safe operation of the UAS in the NAS.

Likewise, the Administrator may prescribe special conditions pursuant to 14 C.F.R.

§ 21.16, for o peration of the DJI Phantom 2 Vision Plus UAS , since the airworthiness regulations

of 14 C.F.R. Part 21 do not contain adequate or appropriate safety standards, due to the novel

or unusual design features of the aircraft. Section 21.16, entitled Special Co nditions, states the

following:

If the FAA finds that the airworthiness regulations of this subchapter do not contain

adequate or appropriate safety standards for an aircraft, aircraft engine, or propeller

because of a novel or unusual design feature of the aircraft, aircraft engine or

propeller, he prescribes special conditions and amendments thereto for the product.

The special conditions are issued in accordance with Part 11 of this chapter and

contain such safe ty standards for the aircraft, aircraft engine or propeller as the

FAA finds necessary to establish a level of safety equivalent to that established in

the regulations.

See 14 C.F.R. § 21.16.

Therefore, in accordance with FMRA Section 333 and 14 C.F.R. § 21.16, the FAA may

prescribe special conditions for Leading Edge’s intended operation of the DJI Phantom 2 Vision

Plus UAS which contain such safety standards that the Administrator finds

necessary to establish a level of safety equivalent to that establ ished by 14 C.F.R. Part 21,

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

91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b).

• A Summary That Can Be Published In The Federal Register,

stating: The Rules Fr om Which WILLIAM SNEDEN Seeks Exemption:

WILLIAM SNEDEN seeks exemption from the requirements of 14 C.F.R Sections

61.113(a)&(b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) &

(a)(2), and 91.417(a) & (b).A Brief Description Of The Nature Of The Exemption WILLIAM SNEDEN

Seeks:

This exemption will permit WILLIAM SNEDEN to commercially operate an

Unmanned Aircraft System (UAS) for the purpose of conducting aerial video and

photography over certain areas of the United States.

• Any Additional Information, Views, Or Arguments Available To

Support WILLIAM SNEDEN Request.

This Petition is made pursuant to the FAA Modernization and Reform Act of 2012

(FMRA) Section 333, which directs the Secretary of Transportation to determine if certain

UAS may operate safely in the NAS. As such, WILLIAM SNEDEN ’s request for

exemption may be granted pursuant to the authority of FMRA Section 333 and 14 C.F.R.

Part 11, as set forth above.

FMRA Section 333 sets forth the requirements for considering whether a UAS will create

a hazard to users of the NAS or the public, or otherwise pose a threat to national security;

and further, provides the authority for such UAS to operate without airworthiness

certification.

As dis cussed in detail above, WILLIAM SNEDEN will operate the DJI Phantom 2 Vision Plus

UAS safely in the NAS, without creating a hazard to users of the NAS, or the public, or otherwise

pose a threat to national security.

CONCLUSION

As set forth herein, WILLIA M SNEDEN seeks an exemption pursuant to 14 C.F.R. §

11.61 and Section 333 of the FAA Modernization and Reform Act of 2012 (FMRA),

which will permit safe operation of the DJI Phantom 2 Vision Plus UAS

commercially, without an airworthiness certificate, for the limited purpose of conducting

aerial video and photography over certain areas of the United States. By granting this

Petition, the FAA Administrator will be fulfilling the Congressional mandate of the FAA

Modernization and Reform Act of 2012, while als o advancing the interests of the public,

by allowing WILLIAM SNEDEN to safely, efficiently, and economically operate the

DJI Phantom 2 Vision Plus UAS commercially within the NAS.

WHEREFORE , in accordance with the Federal Aviation Regulations and the FAA

Modernization and Reform Act of 2012, Section 333, WILLIAM SNEDEN

respectfully requests that the Administrator grant this Petition for an exemption from the

requirements of 14 C.F.R Sections 61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 91.405(a),

91.407(a) (1),

91.409(a)(1) & (a)(2), and 91.417(a) & (b), and permit Leading Edge to operate the DJI Phantom

2 Vision Plus UAS commercially for the purpose of conducting aerial video and photographyover certain areas of the United States.

Dated:

Respectfully submitted,

WILLIAM SNEDEN

WILLIAM SNEDEN

3705 Arpent St

Saint Charles, MO 63301

917 796 2293

## Appendices:

A

– DJI Phantom 2 Vision Plus Manual (See http://www.dji.com/product/phantom

- 3/download)

E

– Monthly Maintenance Log (available upon request)