December 23, 2015 U.S. DepartmentofTransportation Docket Management System 1200 New Jersey Ave., SE Washington, DC 20590 Re: Petition ofMojo Web Solutions, LLC for an Exemption Pursuant to Section 333 ofthe FAA Modernization and Reform Act of2012 Director: Flight Standards Service: Pursuantto Section 333 ofthe FAA Modernization and Reform Act of2012 ("Reform Act") and 14 C.F.R. Part 11, Mojo Web Solutions, LLC ("Mojo") hereby applies for an exemption from the Federal Aviation Regulations ("FARs") identified belowto allow commercial operation ofsmall unmanned aerial vehicles (i.e., "small unmanned aircraft" or "UAS") for the purpose of conducting aerial photography, videography, cinematography, inspection and mapping for the motionpicture, television, real estate, and web industries. This petition for exemption is made based oninformation outlined inthis Petition for Exemption, as well as the accompanying Mojo documents; 1. PIC Flight Operations Manual and; 2. Operations Manuals (Collectively 2 and 3 are referred to as Documents & Manuals") 3. User Guide and; 4. FlightManual 1 (Collectively 3 and 4 are referred to as "Manufacturer's Manuals") Mojo submits these supporting materials as confidential documents pursuantto 14 C.F.R. § 11.35(b), as the materials contain confidential commercial and/orproprietary informationthat Mojo has not and will not share with otherrequesting parties. Additionally, these documents containoperating conditions and procedures that are not generally available to the public and are protected from release underthe Freedom oflnformationAct, 5 U.S.C. § 552 et. seq. 

### NOTE: ALL ATTACHMENTS SET FORTH IN SUPPORT OF THIS LETTER OF PETITION ARE CONFIDENTIALAND SHALL NOT BE RELEASED TO THE PUBLIC WITHOUT WRITTEN AUTHORIZATION FROM THE PETITIONER.
Foryour convenience, this Petition is organized as follows:

1

. The term "Manufacturer's Manual" also includes all relevant manufacturerpublications, including, but not limited to: operations and flight manuals, user guides, componentmaintenance manuals, pilottraining manuals, service information letters and, safety/service bulletins.U.S Department ofTransportation December23 2015 Page2

### I. Description ofPetitioner II. Description ofProposed Operations A. Aerial Videography, Photography, Cinematography, Inspection and Mapping 

### III. Relevant StatutoryAuthority IV. Mojo's Proposed UAS Operations Meet the Requirements ofSection 333 ofthe Reform Act A. Approval is Warranted Based onthe UAS's Size, Weight, Speed, and Operational Capability B. Approval is Warranted Based onthe Operational Restrictions Set Forth in the Operations Manuals 

### V. Regulations FromWhich Exemption is Requested
A. 14 C.F.R. Part21, Subpart H- Airworthiness Certificates and 14 C.F.R. § 91.203(a)(1) B. 14 C.F.R. Part27 Airworthiness Standards: Normal Category Rotorcraft C. 14 C.F.R. §§ 91.9(c), 45.23(b) and 45.27(a): Aircraft Marking and Identification Requirements D. 14 C.F.R. 

### § 91.405(a), 91.407(a)(l), 91.409(a)(1) and (2); 91.417(a) and (b): Maintenance Inspections E. 14 C.F.R. Part 61, 14 C.F.R. § 61.3, 14 C.F.R. § 61.113: Private Pilot Privileges and Limitations F. 14 C.F.R. 

### § 91.7(a): Civil AircraftAirworthiness G. 14 C.F.R. § 91.9(b)(2): Civil Aircraft Flight Manual in the Aircraft and 14 C.F.R. § 91.203(a) and (b): Carrying Civil Aircraft Certification and Registration H. 14 C.F.R. § 91.103: Preflight Action 

### I. 14 C.F.R. § 91.109(a): Flight Instruction J. 14 C.F.R. § 91.119(c): Minimum Safe Altitudes 

### K. 14 C.F.R. § 91.121: Altimeter Settings 

### L. 14 C.F.R. § 91.151(a): Fuel Requirements for Flight in VFR Conditions 

### Vl. Drugand Alcohol Program VII. Public Interest VIII. Privacy IX. FederalRegister Summary X. Conclusion I. 

### DESCRIPTION OFPETITIONER Mojo, is based in Baltimore, MD and provides photography, videography, cinematography, inspection and mapping for the motionpicture, television, real estate, and web industries. The Company's Principal and ChiefPilot Alexander Fakeri has been flying UAV Quadcopters as a hobby for more than one years without incident, spending hundreds ofhours flying.U.S Department ofTransportation December 23 2015 Page3 Uponthe grant ofthe 333 Exemptionthe Company'sbusiness will specialize in photography, videography and cinematography for the film, television, real estate and web industries. Mojo's staffare well trained and experienced in providing support as visual observers ("VO") for the pilot in command ("PIC") in addition to any other needed on site assistance. All ofthe equipment owned by Mojo is ofthe highest quality gear and has been able to provide these services safely and without any claims or incident. Mojo's goal is to advise the perspective clientthat Mojo is following all the applicable state and federal rules to ensure the safety ofthe public while providing the client with a competitive and costeffective product. Mojo seeks an exemptionto allow for photography, videography, cinematography and other related mediaproducts. The contact information for Petitioner is as follows: Alexander R. Fakeri Mojo Web Solutions, LLC 8100 Ft. Smallwood Rd. Baltimore, MD 21226 Telephone: 410.439.1994 Email: alex@mojo.biz II. DESCRIPTION OF PROPOSED OPERATION Mojo seeks an exemptionpursuantto Section 333 ofthe Reform Act to operate the DJI Inspire 1 (referred to MW-UAS) (under 55lbs) for the proposed operations discussed hereinbelow. All UAS operations will occur under tightly controlled conditions onprivate property or approved location where Mojo has received verifiable permissionto operate from the landowner, controller or authorized representative. The proposed UAS operations will be conducted in accordance withthe conditions and limitations ofthis Petition for Exemption and Mojo's Operations Manuals. As detailed in Mojo's Operations Manuals, all UAS operations will be limitedto daytime VFRconditions, within visual line-of-sight ("VLOS") ofthe operator, in uncontrolled airspace, and will occur at least 5 nm away from an airportreference point. Moreover, Mojo's Operations Manuals incorporate redundant safeguards to assure the aircraft does not travel outside the controlled area ofUAS operations, including GPS "geo-fencing" technologies. A. Aerial Videography, Photography, Cinematography, Inspection and Mapping Mojo seeks to use small MW-UAS for the purpose ofconducting aerial photography, videography and cinematography, inspection and mapping for their clientbase. Mojo has purposefully tailored its operations to meetthe requirements established by the FAA inprior grants ofexemption authorizing commercial use ofUAS in the real estate industry, including:

• Astraeus Aerial (ExemptionNo. 11062) • Aerial MOB, LLC (Exemption No. 11066)U.S Department ofTransportation December 23 2015 Page4



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### • • • • • Pictorvision, Inc. (ExemptionNo. 11067) HeliVideo Productions, LLC (ExemptionNo. 11065) Snaproll Media, LLC (ExemptionNo. 11063) RC Pro Productions Consulting, LLC d/b/a Vortex Aerial (ExemptionNo. 11064) Flying-Cam, LLC (ExemptionNo. 11080) Aerocine, LLC (ExemptionNo. 11150) Team 5, LLC (Exemption No. 11158) Alan D. Purwin (ExemptionNo. 11161) HelinetAviation Services, LLC (Exemption No. 11160) Picture Factory, Inc. (ExemptionNo. 11178) All UAS photography and videography operations will occur onprivate property or approved location in a controlled area away from spectators and persons not involved in the recording process. In addition, the filming will be conducted between dawn and dusk to ensure maximum safety for the public and those involved in the manipulation and operation ofthe UAS; VFR conditions, at altitudes below400' above ground level ("AGL"). As set forth below, Mojo's operations provide an equivalent level ofsafety which is superiorto performing the same workusing conventional fixed-wing aircraft orhelicopters. Small UAS recording operations is also saferthantraditional manned aircraft performingthe same function. Videographer-inspectors also frequently need to climb rooftops, trees, ladders or otherwise perform elevated work, which exposes them to the risk ofdangerous falls, electrocution or other workrelated injuries. In addition, depending onthe nature ofthe video needed and inspection, proximity to equipment, and other mechanical hazards associated with industrial sites and construction facilities often involves a risk ofexposure to hazardous conditions. The use ofMW-UAS mitigates these hazards and is ultimately a much safer and cost efficientmethod ofperforming these and most othertypes ofrecording operations. Moreover, conventional operations using rotorcraft and fixed-wing aircraft in low level operations present risks associated with vehicles weighing tens ofthousands ofpounds (including payload) and carrying large amounts offuel which inherently presents significant fire hazards as well as exposure to other chemical contaminates. Itis important to note the use of small UAS in this area will not only be safer and more costeffective to the perspective user or purchaser ofthe service, but the quality and expanse ofacquired information will be far more robust giventhe lowcost associated with its acquisition and otherpotential consumers an inexpensive product. UAS video production is more reliable, and allows for the collection, dissemination, and storage ofvisual and other sensory data with greaterprecision and duration at a very low cost. Small UAS will also be capable ofaccessing and inspecting areas that would otherwise be inaccessible orhighly dangerous using conventional aircraft or other inspectionmethods. 

### III. RELEVANT STATUTORY AUTHORITY This Petition for Exemption is submitted pursuantto Section 333(a) through (c) ofthe FAA Modernization and Reform Act of2012 ("Reform Act"). Congress has directed the FAAU.S Department ofTransportation December 23 2015 Page 5 "to safely accelerate the integration ofcivil unmanned aircraft systems into the national airspace system." Pursuantto Section 333 ofthe Reform Act, the FAA Administrator is to permit unmanned aircraft systems to operate in the National Airspace Systems ("NAS") where it is safe to do so based onthe following considerations:

• The UAS's size, weight, speed and operational capability; • Operation ofthe UAS in close proximity to airports and populated areas; and • Operation ofthe UAS withinthe visual line ofsight ofthe operator. Additionally, the FAA Administratorhas general authority to grant exemptions from the agency's safety regulations and minimum standards whenthe Administrator decides a requested exemption is in the public interest. See 49 U.S.C. § 106(±) (defining the authority ofthe Administrator); 49 U.S.C. §44701(±) (permitting exemptions from§§ 44701(a), (b) and §§ 44702-44716, et seq.). A party requesting an exemptionmust explain the reasons why the exemption: (1) would benefit the public as a whole, and (2) would not adversely affect safety (or how it would provide a level ofsafety at least equal to the existingrules). See 14 C.F.R. § 11.81 (petitions for exemption). 

### IV. MOJO'S PROPOSED MW-UAS OPERATIONS MEETTHERE UIREMENTS OF SECTION 333 OFTHEREFORM ACT The small MW-UAS operations proposedby Mojo as noted above in this Petition for Exemption qualify for expedited approval pursuantto Section 333 ofthe Reform Act as eachofthe statutory criteria and relevant factors are satisfied. 

### A. Approval is Warranted Based on the VAS's Size, Weight, Speed, and Operational Capability
A Grant ofExemption is appropriate for operations conducted using the UASs due to their size weight, speed, and operational capability.

• The MW-UAS utilized by Mojo has been approved for use in prior Section 333 Grants ofExemption from the FAA.2

• The MW-UAS weighs less than 55 pounds, including payload

• The MW-UAS will notbe flown at a ground speed in excess of50 knots. The exemption holder may use either groundspeed orcalibrated airspeed to determine compliance with the 50 knot speed restriction

• Altitude information will be generated by equipment onboard the UAS as specified using GPS triangulation, digitally encoded barometric altimeter, radio

2 See e.g., Grant ofExemption to Shotover Camera Systems L.P. (Exemption No. 11159); Grant ofExemption to VDOS Global, LLC (Exemption No. 11112); Grant ofExemption to LowCountryRC, Corp. (Exemption No. 11184); Grant ofExemption to Alan Purwin (Exemption No. 11161); Grant ofExemption to Helinet Aviation Services (Exemption No. 11160); Grant ofExemption to Total Safety U.S., Inc. (Exemption No. 11156)

..U.S Department ofTransportation December 23 2015 Page 6 altimeter, or any combination thereof. This information will be transmitted to the pilot viatelemetric data feed.

• The MW-UAS will have system redundancies and independent functionality to ensure the overall safety and predictability ofthe system. Ifconnectionto the remote control or ground control station is lost, failsafe systems will permit the UAS to return to a predetermined location and safely land without injury or damage.

• The radio frequencies used for operations and control oftheMW-UAS comply with the Federal Communications Commission ("FCC") and other appropriate government oversight agency requirements. The operating frequency for the MWUAS is 2.4 GHz frequency bands. Ifthe same operations were conductedusing a helicopter, the aircraft's take-offweight would likely exceed 6,000 pounds depending onpayload. The difference in weightbetweenthe MWUAS and a helicopter significantly reduces the potential harm to the participating and nonparticipating individuals and/or surrounding property in the event ofan unintended accident or incident. In addition, the risk to the onboardpilot and camera operatoris eliminated. 

### B. Approval is Warranted Based on the OperationalRestrictions SetForthin Mojo's Operations Manuals Operations Manuals and the Manufacturer's Manual for the selected MW-UAS will contain all the procedures and limitations necessary to safely and successfully perform the operations specified in this Petition for Exemption. To assist the FAA inmaking a safety assessment of Mojo'sproposed operations, below is a summary ofoperational limitations and conditions that Mojo will adhere to, and which will ensure an equivalent orhigher level ofsafety to operations conductedunder current regulatory guidelines: 1. The MW-UAS weighs less than 55 pounds, withpayload. 2. All operations shall be conducted overprivate or controlled-access property with verifiable permission from the land owner/controller or authorized representative. Permission from land owner/controller or authorized representative will be obtained for each scheduled flight priorto operation. 3. All UAS operated under the Grant ofExemptionwill be identified by serial number, registered in accordance with 14 CFRpart47, andhave identification (N-Number) markings in accordance with 14 CFRpart 45, Subpart C. Markings will be as large as practicable. 4. Minimum crewfor each flight operation will consist ofa pilot, who will be Pilot-in Command ("PIC") ofthe GUN-UAS, and one or more Visual Observers ("Observer") as necessary to safely conduct the mission. 5. PICs shall possess either a private, recreational, or sportpilot certificate. The PIC must also hold a currentFAA airman medical certificate or a valid U.S. driver's license issued by a state, the District ofColumbia, Puerto Rico, a territory, aU.S Department ofTransportation December 23 2015 Page 7 possession, orthe Federal government. The PIC will also meetthe flight review requirements specified in 14 C.F.R 61.56 in an aircraft in which the PIC is rated on his orher pilot certificate. 6. The MW-UAS shall be operated within VLOS ofthe PIC and Observer at all times. The PIC must use human vision unaided by any device otherthan corrective lenses, as specified onthe PIC's FAA-issued medical certificate. 7. The PIC and Observer designated for any operation will be able to communicate verbally at all times. 8. Electronic messaging ortexting will notbe permitted during flight operations. 9. The additional requirements identified in the Grant ofExemption shall be added to the Mojo's Operations Manuals. The Operations Manuals will be maintained and made available to the Administratoruponrequest. Ifa discrepancy exists betweenthe conditions and limitations in the Grant ofExemption and Mojo's Operations Manuals, the conditions and limitations in the Grant ofExemption shall take precedence and must be followed. Otherwise, Mojo shall follow the procedures outlined in their Operations Manuals. 10. Mojo may update orrevise its Operations Manuals. Revisions will be tracked and a revised copy ofthe Manual will be providedto the Administratoruponrequest. Mojo will also present an updated and revised Operations Manuals ifit petitions for extension or amendmentto its Grant ofExemption. Ifan update orrevision would affect the basis upon which the FAA grants the exemption, Mojo will seek an amendment to its Grant ofExemption. Mojo will contactthe FAA'sUAS Integration Office (AFS-80) ifquestions arise regarding updates orrevisions to the operating documents. 11. Mojo Operations Manuals and its Grant ofExemption will be available to the PIC at the ground control station anytime the MW-UAS is operating. 12. The PIC is prohibited from beginning a MW-UAS flight unless (considering wind and forecast weather conditions) there is enoughpower to fly to the first intended point oflanding, and assuming normal cruising speed, to fly after that for at least 10 minutes. 13. Maximumtotal flight time for each operational flight using the MW-UAS will be limited to 40 minutes orthe amount oftime the UAS can be flown and still maintain a reserve battery power ofno less than 25%, whichever occurs first. 14. Flights will be operated at an altitude ofno more than 400 feet AGL and will never enternavigable controlled airspace withouttimely prior written authorization and approval from the FAA. Inthe eventthe structure being inspected exceeds 400 feet AGL, the UAS will notbe operated more than 100 feet above the highest point onthe structure, and no more than 50 feet horizontally from the structure.U.S DepartmentofTransportation December 23 2015 Page 8 15. Flight operations must be conducted at least 500 feet from all nonparticipating persons. (persons otherthan the PIC, VO, operatortrainees oressential persons), vessels, vehicles, and structures unless: a. Barriers or structures are presentthat sufficiently protect nonparticipating persons from the UA and/or debris in the event ofan accident. The operator must ensure that nonparticipating persons 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 grantedpermission andthe PIC has made a safety assessment ofthe risk ofoperating closerto those objects and determined that it does notpresent anundue hazard, and;

c. Operations nearerto the PIC, VO, operatortrainees or essential persons do not present anundue hazard to those persons per§ 91.119(a). 16. The MW-UAS may notbe operated less than 500 feet below orless than 2,000 feet horizontally from a cloud orwhen visibility is less than 3 statute miles from the PIC. 17. The MW-UAS may not operate within 5 nm ofan airport reference point as denoted on a current FAA-published aeronautical chart unless a letter ofagreement withthat airport's management is obtained, and the operation is conducted in accordance with a NOTAM as required by the Mojo COA. The letter ofagreement with the airport managementwill be made available to the Administratorupon request. 18. Priorto each flight the PIC shall inspectthe MW-UAS to confirm that it is in a condition safe for flight. The pre-flight inspection will account for all discrepancies, e.g. inoperable components, items, or equipment, not already covered in the relevant sections ofthe operating documents as well as equipmentupdates. The PIC shall not operate any MW-UAS ifthe inspectionreveals a conditionthat affects the safe operation ofthe MW-UAS until the necessary maintenance has beenperformed and the MW-UAS is found to be in a condition for safe flight. The ground control station shall be included in the preflightinspection. All maintenance and alternations mustbe properly documented inthe UAS's records as required by Mojo's Operations Manuals. 19. Mojo will timely carry outits maintenance, inspections, andrecordkeeping requirements in accordance withthe Operations Manuals. Maintenance, inspection, and alterations will be fully noted in the MW-UAS records, including total time in service, description ofwork accomplished, date completed and the signature ofthe authorized personreturning the MW-UAS to service. 20. Any MW-UAS that has undergone maintenance or alterations that affect the UAS operation or flight characteristics (e.g., replacement ofa flight critical component) must timely undergo a functional testflight in accordance with Mojo's Operations Manuals. The PIC who conducts the functional test flight must make an entry in the UAS aircraft records ofthe flight. The requirements and procedures for a functionalU.S Department ofTransportation December 23 20 15 Page 9

test flight and MW-UAS record entry shall be included in the Mojo's Operations Manuals. 21. The MW-UAS will be operated and maintained according to the Manufacturer's Manuals and any required manufacturer Safety/Service Bulletins and productupdates. 22. Prior to the operation, a Mission Packet will be created in accordance with the requirements on Mojo's Operations Manuals.
23. Mojo will obtain an Air Traffic Organization ("ATO") issued Certificate ofWaiver or Authorization, otherwise known as a COA, prior to conducting any operations under this Grant ofExemption. A NOTAM will be issued as requiredby the COA. All operations will be conducted in accordance with airspace requirements inthe ATO issued COA including class ofairspace, altitude level and potential transponder requirements. 24. All required permissions and permits will be obtained from territorial, state, county or cityjurisdictions, including local law enforcement, fire or other appropriate governmental agencies. 25. Ifthe MW-UAS loses communication with the PIC, it will have the capability to safely return to a pre-determined location within the operational area and land safely. 26. Contingency plans will be in place to safely terminate flight ifthere is a loss of communicationbetweenthe PIC and the Observer. 27. The MW-UAS will have the capability to safely abort flight in the case ofunpredicted obstacles or emergencies. 28. PICs and Observers will have at least a current Class III Medical Certificate or a valid and current state driver's license issued within the United States. 29. Prior to conducting operations for filming, the PIC will have accumulated and logged, in a manner consistentwith 14 CFR 

### § 61.51(b), a minimum of200 flight cycles and 25 hours total time as a UAS rotorcraftpilot and at least 10 hours logged as a UAS pilot with a similar MW-UAS type platform. This requirement canbe achieved by flights conducted and logged as a hobbyist. 30. Priorto conducting operations for filming, the PIC will have accumulated and logged, in a manner consistentwith 14 CFR § 61.51(b), a minimum ofhourspursuant to 54 CFR § 61.51(b) as UAS pilot operating the make and model ofMW-UAS to be utilized for operations under the exemption and three take-offs and three landing in the preceding 90 days. 31. Operations shall occur during daytime VFRMeteorological Conditions; flights under special visual flight rules ("SVFR") shall not be conducted.U.S DepartmentofTransportation December 23 2015 Page 10 32. The MW-UAS shall remain clear and yield the right ofway to all other manned operations and activities at all times (including, but not limitedto, ultralight vehicles, parachute activities, parasailing activities, hang gliders, etc.). 33. MW-UAS Operations under Instrument Flight Rules, at night, or beyond VLOS are prohibited. 34. The UAS will notbe operated from an elevated platform unless designed and engineered specifically for suchpurposes and be in compliance with the general restrictions imposedby the applicable regulations. Additionally no PIC will provide any film-flight operations while in motion from atop any elevated platform vehicle or device. 35. Before conducting operations, the radio frequency spectrumused for operation and control ofthe MW-UAS will comply withthe Federal Communications Commission (FCC) or other appropriate government oversight agency requirements. 

### V. REGULATIONS FROM WHICH EXEMPTION IS RE UESTED The Federal Aviation Act expressly grants the FAA the authority to issue exemptions. This statutory authority, by its terms, includes exempting civil aircraft, as the term is defined under§ 40101 ofthe Act, including UASs, from its safety regulations and minimum standards whenthe Administrator decides a requested exemption is in the public interest. 3 Mojo seeks an exemption from several interrelatedprovisions ofTitle 14 ofthe Code ofFederal Regulations ("14 C.F.R") Parts 21, 45,61 and 91 for purposes ofconducting the requested operations using MW-UAS platforms noted above. Listed below are: (1) the specific sections of 14 C.F.R for which exemption is sought, and (2) the operating procedures and safeguards that Petitionerhas established which will ensure a level ofsafety betterthan or equal to the rules from which exemption is sought.4 

### UNMANNEDAIRCRAFT SYSTEM A. 14 C.F.R. Part 21, Subpart H- Airworthiness Certificates and 14 C.F.R. §91.203(a)(l) The FAAhas statedthat no exemption is needed from this section ifa finding is made under the Reform Actthatthe UAS selected provides anequivalent level ofsafety when compared to aircraft normally used for the same application. These criteria are met and in point offact exceeded, andtherefore no exemption is needed. 5 If, however, the FAAdetermines that there

349 U.S.C. §44701(f) (authorizing the grant ofexemptions from requirements ofregulations prescribedpursuant to Sections 4470l(a) and (b) and Sections 44702- 44716).

4 14 C.F.R § 11.8l(e), which requires apetition for exemptionto include: The reasons why granting the exemption would not adversely affect safety, orhow the exemption would provide a level ofsafety at least equal to that provided by the rule from which you seek exemption.

5 See Grant ofExemption No. 11062 to Astraeus Aerial (FAA-2014-0352 at pgs. 13-14, 22).U.S Department ofTransportation December 23 2015 Page 11

are some characteristics ofthe chosen UAS that fail to meet the requirements ofthe Reform Act, anexemption is requested. 

### EquivalentLevelof Safety Mojo'suse ofthe MW-UAS is safe when taking into account its size, weight, speed, and operational capability. As set forth in the description ofproposed operations in SectionIV(A), the MW-UAS weighs less than 55 pounds, including payload and will not be flown at a ground speed in excess of50 knots. The MW-UAS is also equipped with safety features which will allow Petitionerto operate the MW-UAS safely after experiencing certain in-flight contingencies orfailures as noted below.6 7 Additionally, the MW-UAS carries neitherpilots norpassengers, carries no explosive materials orflammable liquid fuels, or otherelements identified by Homeland Security as being prohibitive and operate exclusively within the parameters stated in Mojo's Operations Manuals. Operations conducted under this exemptionwill be closely controlled and monitored by the PIC operator and will be conducted in compliance with local public safety requirements, to provide security for the area ofoperation. Mojo will also provide the FAA with advance notice ofall operations viaNOTAMs as required by the applicable COA. In all cases, operation ofthe MWUAS under the proposed conditions will be at least as safe as, or saferthan, conventional rotorcraft operating with an airworthiness certificate. Lastly, the MW-UAS do not need a means to communicate with other aircraft orATC, because those capabilities will be solely possessed by the PIC and Observer, who are not onboard the MW-UAS. 8 In addition, no sense-and-avoid

6 See e.g., Grant ofExemption No. 11184 to Low Country RC, Corp. (FAA-2014-0803 at pg. 3): "The [DJI S1000] has the capability to operate safely after experiencing certain in-flight contingencies or failures anduses an autopilot system to maintain UAS stability and control. The UAS is also able to respond to a loss ofglobal positioning system (GPS) or a lost-link event with a pre-coordinated, predictable, automated flight maneuver, and manual flight control functionality as a backup. These safety features provide an equivalent level ofsafety compared to a manned aircraft performing a similar operation."

7 See e.g., Grant ofExemption No. 11184 to VDOS Global, LLC. (FAA-2014-0382 at pgs. 4-5): "The MW-UAS can be operated entirely by a touch-screen, map-based interface

.This means the operator only needs to command the system where to go, and the system does all the flying for the operator. The MW-UAS can be operated in both semi and fully autonomous flight modes, with the operator simply clicking on a map to create a pre-planned flight path for a flight. In addition, the operator can create no fly zones or maximum flight ranges and altitudes so the system cannot enter areas deemed unsafe orunnecessary to fly over. The petitioner states further that the UAS has built-in intelligent fault handling which allows the MW-UAS to detect a system fault while in the air and automatically fly back to its takeofflocation and land. Faults that can be detected include: loss ofcommunication; exceeding pre-set wind thresholds; and low battery levels. All flight operations are global positioning system (GPS) controlled, makingthe system easy to navigate. At any point ifthe operator is not explicitly commanding the system to move, the system automatically holds its GPS position. The flight control system employs not only GPS positioning but a variety ofsensors including sonar, barometric pressure, temperature, wind speed and others to ensure stability so long as wind thresholds are not exceeded. Also a flight termination link- to prevent a 'fly away' orother potentially dangerous situation- is available to the operator."

8 See Grant ofExemption No. ll062 to Astraeus Aerial (FAA-2014-0352 at pg. 13).U.S DepartmentofTransportation December 23 2015 Page 12 technology is necessary for the MW-UAS because they will be operated at all times in VFR conditions and within VLOS ofthe PIC and Operator. 9


### B. 14 C.F.R. Part27 Airworthiness Standards: NormalCategory Rotorcraft
Title 14 C.F.R. Part 27 sets forth the procedural requirements for airworthiness certification of normal category rotorcraft. To the extentthat Mojo's small MW-UAS would otherwiserequire certification under Part 27, Petitioner seeks an exemption from Part 27's airworthiness standards for the same reasons identified inthe request for exemption from 14 C.F.R. R. Part 21, Subpart H, 

### supra. 

### C. 14 C.F.R. 

### §§ 91.9(c), 45.23(b) and 45.27(a): AircraftMarking and Identification Requirements Mojo seeks an exemption from the aircraft marking and identification requirements contained in 14 C.P.R.§§ 91.9(c), 45.23(b) and 45.27(a).

• 14 C.F.R. § 91.9(c), Civil Aircraft Flight Manual, Marking and Placard requirements, provides that:
Noperson may operate a U.S.-registered civil aircraftunless that aircraft is identified in accordance with Part 45 ofthis chapter.

• 14 C.F.R. § 45.23(b), Markings oftheAircraft, states: When marks include only the Romancapital letter "N" andthe registration number is displayed on limited, restricted orlight-sport category aircraft or experimental orprovisionally certificated aircraft, the operatormust also display onthat aircraft near eachentrance to the cabin, cockpit, or pilot station, in letters not less than 2 inches normore than 6 inches high, the words "limited," "restricted," "light-sport, "experimental," or "provisional," as applicable.

• 14 C.P.R. § 45.27(a), Rotorcraft, states: Each operator ofa rotorcraft mustdisplay onthat rotorcrafthorizontally onboth surfaces ofthe cabin, fuselage, boom, ortail the marks required by § 45.23.
In a previous Grant ofExemption, the FAA determinedthatexemption from these requirements was warrantedprovided thatthe aircraft "have identification (N-Number) markings in accordance with 14 C.F.R Part 45, Subpart C ifthe markings are as large as practicable." 10 

### EquivalentLevelof Safety

10

. FAA DocketNo. FAA-2014-0352.U.S Department ofTransportation December 23 2015 Page 13 All MW-UAS flown by Mojo will bear N-number markings that are as large as practicable in accordance with 14 C.F.R. Part 45, Subpart C. 11


### D. 14 C.F.R. 

### § 91.405(a), 91.407(a)(1), 91.409(a)(1) and (2); 91.417(a) and (b): Maintenance Inspections Mojo seeks an exemption from the maintenance inspectionrequirements contained in 14 C.F.R. § 91.405(a), 91.407(a) (1), 91.409(a)(2); 91.417(a) and (b). These regulations specify maintenance and inspection standards inreference to 14 C.F.R. Part43. See, e.g., 14 C.F.R. 

### § 91.405(a) (stating thateachowneror operator ofan aircraft "[s]hall have the aircraft inspected as prescribed in subpart E ofthis part and shall betweenrequired inspections

...have discrepancies repaired as prescribed in part43 ofthis chapter"). An exemption from these regulations is neededbecause Part43 andthese sections onlyapply to aircraftwith an airworthiness certificate, which the UASplatforms to be operatedunder this grant of exemption willnothave. (Emphasis added) EquivalentLevelof Safety Anequivalent level ofsafety will be achieved or exceeded because maintenance and inspections will be timely performed in accordance withthe Manufacturer's Manual and any required manufacturer Safety or Service Bulletins. Further, as required by Mojo's Operations Manuals, the PIC will conduct a pre-flight inspection ofthe MW-UAS and all associated equipmentto account for all discrepancies and/or inoperable components. Maintenance will be performed and verifiedto address any conditions potentially affecting safe operation ofthe MW-UAS and no flights will occurunless, and until, all flight critical components ofthe MW-UAS have been found to be airworthy and in a condition safe for operation. A functional test flight will be conducted following the replacement ofany flight-critical components. As required by Mojo's Operations Manuals, the PIC who conducts the functional test flight will make an entry in the MW-UAS aircraft records ofthe flight. Mojo's Operations Manual also includes requirements to follow the manufacturer's UAS aircraft/component, maintenance, overhaul, replacement, inspection, and life limit requirements for the following applicable components: powertrain system (powerplant), propellers, avionics and control surfaces (including ailerons/elevons), structures & airframe, camera system, electrical systems (including batteries), ground control station, hazard accessories, and spare parts. Further, Mojo's Operations Manuals also include proceduresto document and maintain a record ofthe MW-UAS'smaintenance, preventative maintenance, alterations, status of replacement/overhaul componentparts, andthe total time in service ofthe MW-UAS used under this Grant ofExemption. As a whole, the maintenance and inspectionprocedures required in Mojo's Operations Manuals ensure that an equivalent orhigher level ofsafety will be achieved. 

### PILOT-IN-COMMAND OFTHE UAS E. 14 C.F.R. 

### § 61.113: PrivatePilot Privileges and Limitations

11. See, e.g., FAA DocketNo. FAA-2014-0352, at 14.U.S Department ofTransportation December23 2015 Page 14 Mojo seeks exemption from 14 CFR § 61.113, which restricts private pilot certificate holders from flying aircraft for compensation orhire, and would also require a second class medical certificate. The purpose ofPart 61 is to ensure that the skill and competency ofany PIC matches the airspace inwhich the PIC will be operating, as well as requiring certifications ifthe private pilot is carrying passengers or cargo for hire. In this case, while the MW-UAS will be operated as part ofa commercial operation, they carry neither passengers nor cargo. Inthe Grant of Exemption to Astraeus Aerial, the FAA determined that the unique characteristics ofUAS operation outside ofcontrolled airspace did not warrant the additional cost and restrictions attendant withrequiring the PIC to have a Commercial Pilot Certificate and Class III Medical Certificate. 12 The fulfillment ofthe additional requirements for a private pilotto become qualified as a commercial pilotwould not lead to any additional safety benefits when UAS operations are involved. 

### EquivalentLevelof Safety The restrictions Mojo has placed on its MW-UAS operations meet or exceed the restrictions similarly imposed on Astraeus Aerial. Mojo will operate onprivate property or approved location away from persons and property not involved in the operation. Mojo will also obtain an ATO issued COAprior to conducting any operations under this Grant ofExemption. All operations will be conducted in accordance with airspace requirements in the ATO issued COA including class ofairspace, altitude level and potential transponderrequirements. A NOT AM will also be issued as required by the applicable COA.
In addition to these flight restrictions, Mojo will further ensure safe operationby requiring that any PIC be thoroughly versed not only in airspace and communication issuespertaining to all aircraft operators but also in the unique aspects ofMW-UAS flight. As set forth in the Operations Manuals, pilots will have experience not only in MW-UAS operations generally but have logged flight time in the specific make and model used for the operations before they are permitted to participate in commercial flights on behalfofMojo. The pilot qualification, training, and currency requirements in the Operations Manuals ensure that Mojo pilots are competent and proficient in the MW-UAS they are operating. Mojo'straining and qualificationrequirements are consistentwith those contained in priorFAA Section 33 3 Grants ofExemption, and will provide a higher level ofcompetency and proficiency for its pilots and will ensure at least an equivalent level ofsafety to the public. 

### OPERATING PARAMETERS OF THEUAS
F. 14 C.F.R. 

### § 91.7(a): CivilAircraftAirworthiness Inasmuch as there will be no airworthiness certificate issued for the UAS, Mojo seeks an exemption from 14 C.F.R. § 91.7(a), which requires that a civil aircraft be in airworthy condition to be operated. The FAA has stated that no exemption is required for 14 C.F.R. § 91.7(a) to the extentthat the requirements ofPart 21 are waived orfound inapplicable. 13 Accordingly, Petitionerrequests thatthe requirements for§ 91.7(a) be treated in accordance with

12 Exemption No. 11062 (FAA DocketNo. FAA-2014-0352).

13 See Id. at 13-14,22.U.S DepartmentofTransportation December 23 2015 Page 15 Section V(A), supra. G. 14 C.F.R. §91.9(b)(2): CivilAircraft Flight Manual in the Aircraft and 14 C.F.R. § 91.203(a) and (b): Carrying CivilAircraft Certification and Registration Title 14 C.P.R.§ 91.9(b) (2) and§ 91.203(a) and (b) require the operatorto carry airworthiness documents and other aircraft manuals onboardthe aircraft. Pursuantto 14 C.P.R.§ 91.9(b) (2): (b) No personmay operate a U.S.-registered civil aircraft- (2) Forwhich anAirplane orRotorcraft Flight Manual is required by§ 21.5 ofthis chapter, unless there is available in the aircraft a current approved Airplane or Rotorcraft FlightManual, approved manual material, markings, and placards, or any combination thereof. Pursuantto 14 C.P.R. § 91.203(a) and (b): (a) Except as provided in§ 91.715, no personmay operate a civil aircraft unless it has within it the following: (1) An appropriate and current airworthiness certificate

... (b) No person may operate a civil aircraft unless the airworthiness certificate required by paragraph (a) ofthis section or a special flight authorization issued under§ 91.715 is displayed at the cabin or cockpitentrance so that it is legible to passengers or crew. Giventhe small size and configuration ofthe MW-UAS, it would be impossible to keep airworthiness documents and other aircraft manuals onboardthe MW-UAS because there is simply no room and the MW-UAS has no cabin orcockpit. As a way to comply withthe code Mojo will maintainthe documents withthe PIC and make them available for inspection. EquivalentLevelof Safety
In an FAA Office ofChiefCounsel's Opinion dated August 8, 2014, andprepared by Dean E. Griffith, Attorney, AGC-220, it was acknowledgedthat the intent of 14 C.P.R. 91.9(b) and 91.203(a) and (b) is met ifthe pilot ofthe unmanned aircrafthas access to the UAS flight manual, registration certificate, and otherrequired documents from the ground control station from whichhe or she is operating the aircraft. 14 As this FAA Office ofChiefCounsel Opinion clarifies, the intent ofthe rule is to ensure the pilothas access to these key documents during flight. Therefore, an equivalent level ofsafety will be achieved by ensuring that the pilothas access to the documents at the ground control station from whichhe or she is piloting the UAS. H. 14 C.F.R. § 91.103: PreflightAction

14 Memorandum from Mark Bury, FAA Assistant ChiefCounsel for International Law, Legislation and Regulation, to John Duncan, FAA Flight Standards Service (Aug. 8, 2014); see also Docket No. FAA-2014-0352 at 16-18.U.S Department ofTransportation December 23 2015 Page 16
Mojo seeks an exemption from 14 C.F.R. § 91.103, which requires a PIC to become familiar with specific information before each flight, including informationcontained in the FAAapproved Flight Manual on board the aircraft. While the PIC will be familiar with all information necessary to safely conductthe flight, an exemption is requested to the extent that an FAAapproved Flight Manual is required. 

### EquivalentLevelof Safety
Anequivalent level ofsafety will be provided by following the Mojo's Operations Manuals and the Manufacturer's Manual. The PIC will perform a series ofchecklists designed to identify any defects or inoperable components in accordance with the Mojo's Operations Manuals, including checklists covering Pre-Flight, Launch, Landing, and Post-Flightprocedures. The PIC will also be required to review weather, flight requirements, battery charge, landing and takeoffdistance, UAperformance data, and contingency landing areas-before initiation offlight. Mojo's Operations Manuals and the Manufacturer's Manual will be kept at the ground control station and will be accessible to the PIC at all times while operating the UAS. 

### I. 14 C.F.R. 

### § 91.109(a): FlightInstruction Mojo seeks an exemption from 14 C.F.R. § 91.109(a), whichprovides in pertinent part that "[n]o personmay operate a civil aircraft (except a manned free balloon) that is being used for flight instructionunless that aircraft has fully functioning dual controls." UASs and remotely piloted aircraft, by their design, do not have functional dual controls. Instead, flight control is accomplished through the use ofa device that communicates with the aircraft viaradio communications. Accordingly, an exemption will be required for the flight instruction requirements of 14 C.F.R. 

### § 91.109(a). 

### EquivalentLevelof Safety Giventhe size and speed ofthe UASs that Mojo intends to use, an equivalent level ofsafe training can still be performedwithout dual controls because no pilot orpassengers are aboard the UAS, and as required by the Mojo's Operations Manuals, all persons will be a safe distance away in the eventthatthe UAS experiences any difficulties during flight instruction. Moreover, as required by the Mojo's Operations Manuals, all flight training will be conducted in controlled and sterile environment. As a whole, the safety procedures provided for in Mojo's Operations Manuals ensure that the proposed UAS operations provide an equivalentorhigher level ofsafety than thatprovidedby the flight instruction regulations. 

### J. 

### 14 C.F.R. 

### § 91.119(c): Minimum Safe Altitudes Mojo requests an exemption from the minimum safe altitude requirements of 14 C.F.R. 

### § 91.119(c). 15 Section 91.119 prescribes the minimum safe altitudes under which aircraft may not

15 Relieffrom§ 91.119(a) will not be necessary because Petitioner will be able to perform an emergency landing without undue hazard to persons or property on the ground in the event ofa failure. Petitioner's proposed UAS operations will not occur overcongested areas, and therefore an exemption from § 91.119(b) will not be necessary. See e.g., Grant ofExemption No. 11157 to S1ugwear, Inc., dba Like on a tree Aerial (FAA-2014-0534 at 15).U.S Department ofTransportation December 23 2015 Page 17 operate, including 500 feet above the surface and away from any person, vessel, vehicle, or structure in non-congested areas. See 14 C.F.R. § 91.119(c). Section 91.119(d) allows for a helicopterto operate at less thanthose minimum altitudes when it canbe operated "without hazard to persons orproperty onthe surface," providedthat "eachperson operating the helicopter complies with any routes or altitudes specifically prescribed for helicopters by the FAA." Anexemption is required because the proposed MW-UAS operation will normally need to occur below400 feet AGL. In circumstances where the MW-UAS is used to inspect a structure whose height exceeds 400 feet AGL, the MW-UAS will notbe operated more than 100 feet above the highestpoint onthe structure, and within 50 feet horizontally ofthe structure. Additionally, due the nature ofthe proposed operations, the Pilot and/or Observers(s) may need to be less than 500 feet away from the MW-UAS. EquivalentLevelof Safety Compared to flight operations with rotorcraft weighing far more than the maximum weights proposed herein, and given the lack offlammable fuel withthe above noted UASs, any risk associated withthese operations is far less thanthose which presently exist with conventional aircraft. An equivalent level ofsafety will be achieved given the size, weight, and speed ofthe MW-UAS, as well as the controlled location where the operations will occur. In orderto avoid any risk to manned aircraft, flight operations will be restricted to 400 feet AGL orbelow, or when inspecting a U.S. structure whose height exceeds 400 feet AGL, within 100 feet above the highest point onthat structure and 50 feet horizontally ofthe structure. As set forth in the Operations Manuals, the MW-UAS will be operated in a restricted area, and all flights will be operated at a lateral distance ofat least 500 feet from any nonparticipating persons, unless that person is in a position where he or she is shielded from the MW-UAS and any possible debris resulting from its failure. As required by the Operations Manuals, flights will be terminated ifa nonparticipating personwithin 500 feet ofthe MW-UAS leaves a shielded position. Further, its operations will occur at least 500 feet away from vehicles or structures unless the property owner/controller timely has grantedpermission and the PIC has made a safety assessment ofthe risk ofoperating closerto those objects and, operations near the PIC or Observer will not present an undue hazardper§ 91.119(a). Adherence to these restrictions in Mojo's Operations Manuals will ensure operations can be conducted without compromising public safety

.16

16See e.g., Grant ofExemption No. 11138 to Douglas Trudeau (FAA-2014-0481 at 19): "Ifbarriers or structures are present that can sufficiently protect nonparticipating persons from the UA or debris in the event ofan accident, then the UA may operate closer than 500 feet to persons afforded such protection. The operator must also ensure that nonparticipating persons remain under such protection. Ifa situation arises where nonparticipating persons leave such protection and are within 500 feet ofthe UA, flight operations must cease immediately. When considering how to immediately cease operations, the primary concern is the safety ofthose nonparticipating persons. In addition, the FAA finds that operations may be conducted closerthan 500 feet to vessels, vehicles and structures when the owner/controller ofany such vessels, vehicles or structures grants permission for the operation and the PIC makes a safety assessment ofthe risk ofoperating closer to those objects and determines that it does not present an undue hazard."U.S Department ofTransportation December 23 2015 Page 18

K. 14 C.F.R. §91.121: Altimeter Settings Mojo seeks an exemption from 14 C.F.R. § 91.121, which requires a person operating an aircraft to maintain cruising altitude or flight level by reference to an altimeter that is set to the elevation ofthe departure airport orbarometric pressure. An exemption is required to the extentthat the UASs do not have a barometric altimeter, butrather a GPS altitude read out. EquivalentLevelof Safety The FAA has stated that an equivalent level ofsafety to the requirements of 14 C.F.R. §91.121 can be achieved in circumstances where: (1) the UASs will be operated below400 feet AGL or below17

, (2) within VLOS, (3) where GPS based altitude information is relayed inreal time to the operator at a ground-based on-screen display and, (4) where priorto each flight, a zero altitude initiationpoint is established for the PIC to confirm accuracy ofthe onboard GPS. 18
The MW-UAS that Mojo intends to use for the proposed operations will meet all these operational characteristics. Moreover, as required by Mojo's Operations Manuals, the PIC will be required to calibrate the aircraft's GPS compass priorto each flight operation. Like priorFAA Section 333 Grants ofExemption, the MW-UAS Mojo intends to use, and the safety mitigation procedures contained in the Operations Manuals, both ensure that anequivalent level ofsafety or greater level will be achieved, and a Grant ofExemptionto the requirements of§ 191.121 is therefore appropriate.
L. 14 C.F.R. § 91.151(a): Fuel Requirements for Flight in VFR Conditions Mojo requests an exemption from 14 C.F.R. § 91.151(a)'s fuel requirements for flight in VFR conditions. Section 91.151 states: (a) Noperson may begin a flight in an airplane under VFRconditions unless (considering wind and forecast weather conditions) there is enough fuel to fly to the first point of intended landing and, assuming normal cruising speed

- (1) During the day, to fly after that for at least 30 minutes; or (2) Atnight, to fly after that for at least 45 minutes. Here, the technological limitations on UAS battery powermeans that no meaningful flight operations can be conducted while still maintaining a 30-minute battery reserve. An exemption from the fuel requirements of 14 C.F.R. § 91.151(a) is therefore required. Moreover, it is not Mojo's intentionto fly the MW-UAS at night. EquivalentLevelof Safety

17 Ifthe height ofthe structure being inspected exceeds 400 feet AGL, the UAS will not be operated more than 100 feet above the highestpoint on the structure.

18 See Grant ofExemption No. 11062 to Astraeus Aerial (FAA-2014-0352 at 21).U.S DepartmentofTransportation December 23 2015 Page 19

Inthe Grant ofExemptionto VDOS (ExemptionNo. 11112), the FAA determined that an equivalent level ofsafety to the fuel requirements for flight in VFRconditions couldbe achieved by prohibiting the PIC from beginning a MW-UAS flight unless (considering wind and forecast weather conditions) there was enoughpowerto fly to the first intendedpointoflanding and, assuming normal cruising speed, to fly after that for at least 1 0 minutes. In reaching this conclusion, the FAA consideredthat the UAS batteries for the MW-UAS provide approximately 50 minutes ofpowered flight (withpayload) and provided battery level and battery time remaining in minutes and seconds to the PIC. 19 The FAA also consideredthe fact the MW-UAS operating manual states: "startevery flight with a fully charged battery in the aerial vehicle", and that in the eventthat the MW-UAS should run low onpower, the PIC will be alerted and can safely land the- MW-UAS as soon as possible. Like the VDOS Grant ofExemption, Mojo's use oftheMW-UAS, combined with the requirements ofPetitioner's Operations Manuals, ensure that an equivalent level ofsafety can be achieved and in fact exceeded. Similarly, in the Grant ofExemptionto AlanPurwin (ExemptionNo. 11161), the FAA determinedthat an equivalent level ofsafety to the fuel requirements for flight in VFR conditions couldbe achieved by prohibiting the PIC from beginning a flight with the UA unless (considering wind and forecast weather conditions), there was enoughpowerto safely fly at normal cruising speedto the intended landing point and land the UA with 25% battery power remaining. Mojo will adhere to this limitation for its MW-UAS flights. The MW-UAS includes a lowbattery warning system and the amount ofbattery reserve power remaining is continuously transmitted to the PIC viatelemetric data feed, which downlinks from the MW-UAS to a ground-based-on-screen display?0 As requiredby Mojo's Operations Manuals, the PIC will promptly fly the MW-UAS backto the home launch location orpredetermined abort location where it may safely land, while still maintaining a minimum of25% reserve battery power. Mojo submits that the procedures requiring flights to be safely terminated once the batteries fall below25% capacity, combined withthe requirement that flights only be conducted within a secure, isolated area, using a UAS weighing less than 55 pounds, and within VLOS ofthe PIC and Observer(s), ensure thatthe proposed operation will provide an equivalent or higher level ofsafety to the public to thatprovidedby the regulations from which exemption is sought. 

### VI. DRUG AND ALCOHOL PROGRAM Mojo will have policies in place to ensure that no personmay participate in MW-UAS flight operations ifthey are under the influence ofalcohol or any drug.

19. Grant ofExemption No. 11112 to VDOS Global, LLC (FAA-2014-0382 at 10). 20. The MW-UAS ground control station displays, the UASs position, navigation route, tail number, altitude, heading, north seeking arrow, range to targets, calculatedtarget position, date/time, and sensor heading and orientation relative to the UAS.U.S DepartmentofTransportation December 23 2015 Page 20



### VII. PUBLIC INTEREST The public interest will be served by granting Mojo's Petition for Exemption. Congress has established a national policy that favors early integration ofUAS into the NAS in controlled, safe working environments such as those proposed in this Petition. Granting this Petition for Exemption helps fulfill Congress' goal in passing Section 333(a) through (c) ofthe Reform Act-theFAA Administrator's assessment ofwhether certain UAS may operate safely in the NAS before completion ofthe statutorily required rulemaking. The proposed MW-UAS operations in this Petition for Exemption significantly improves the safety and reduces risk ofharm, physical injury and property damage to the public at large, the property owners from whompermissionwas granted for use by Petitioner and abutting properties, staffofPetitioner, unsuspecting passersby, inspecting engineers from relevant organizations and all those who may be in the local vicinity. Traditional methods ofproviding surveillance and mapping services location personnel to climb towers, trees, venture onto precarious roofs and other dangerous scenarios, perform elevated work for which the individual is neithertrained nor equippedto perform, which exposes them to unnecessary risk ofserious physical injury from dangerous falls or otherphysical mishaps. Moreover, inspectors/surveyors are often unnecessarily exposedto hazardous conditions, unsafe environments, culturally tense situations and otherhazards associated with identifying specific locations for potential recording sitesto be used in the end product. The use ofsmall UAS can eliminate these hazards and ultimately create a much safermethod ofperforming these types ofinspections creating a safer environment for the public as well as Mojo employees. The use ofsmall UAS also enhances safety and reduces risk to the surrounding public because, unlike manned aircraft weighing thousands ofpounds, carrying crew in addition to flammable fuel, the UAS carry no passengers, crew orexplosive fuel. Furthermore, in the unlikely event of an accident, Mojo's small battery powered MW-UAS presents significantly less danger to persons onthe ground when comparedto operations by conventional manned aircraft.21 As Petitioner's MW-UAS are battery powered, the public will also benefit from a reduction in harmful petroleum based emissions associated with conventional aircraft performing in the same functions proposed herein. Air quality will naturally be improved withthe reduction offuel powered vehicles. Lastly, as recognized by the FAA inprior Section 333 Grants ofExemption to filmmakers, UAS provide an additional economic tool for the aerial filming notwithstanding the industry, adding a greater degree offlexibility, which supplements the current capabilities offered by manned aircraft.22 The quality ofthe finished product is enhanced and provides a greater finished product

21 See Grant ofExemption No. 11158 to Team 5, LLC (FAA-2014-0783 at 12): "Manned helicopters conducting aerial filming can weigh 6,000 pounds ormore and are operated by an onboardpilot, in addition to other onboard crewmembers, as necessary. Thepetitioner's UAs will weigh less than 55 pounds with no onboard pilot or crew. The pilot and crew will be remotely located from the aircraft. The limited weight significantly reduces the potential for harm to participating and nonparticipating individuals orproperty in the event ofan incident or accident. Risk to an onboard pilot and crew during an incident or accident is eliminated with the use ofa UA for the aerial filming operation."

22 See e.g., Grant ofExemption No. 11178 to Picture Factory, Inc. (FAA-2014-0794 at 18).U.S Department ofTransportation December 23 2015 Page 21 demand which will aid the currentUAS industry and provide additionaljobs as the costof providing the neededproduct is greatly reduced while reducing the difficulty with whichthe finished product is created. The demand for the current industrial product is increasing and will continue to increase giventhe enhanced flexibility ofproduction; therefore, giventhe lower cost, owner/operators and others in the relevant industry will be more inclinedto utilize the services of commercial UAS along with an appropriate licensed PIC's. 

### VIII. PRIVACY
All MW-UAS operations will be conducted in accordance with applicable federal, state, and local laws regarding privacy. All operations shall be conducted overprivate or controlled-access property withpermission from the land owner/controlleror authorized representative. Permission from land owner/controlleror authorized representative will be obtained for eachflight to be conducted. 

### IX. FEDERAL REGISTER SUMMARY
Pursuantto 14 C.F.R. Part 11, the following summary is provided for publicationinthe FEDERAL REGISTER, should it be determined that publication is needed: Petitioner seeks an exemption from the following rules inTitle 14 ofthe Code ofFederal Regulations:
Part21, Subpart H; Part 27; 45.23(b); 45.27(a); 61.113; 91.7(a); 91.9(b)(2); 91.9(c); 91.103; 91.109(a); 91.119(c); 91.121; 91.151(a); 91.203 (a) & (b); 91.405(a); 91.407(a)(l); 91.409(a)(l) & (2); 91.417 (a) & (b). The exemptionwill enhance safety by reducing risk to the aircraft crew, production crew, general public, property owners and city structures from the substantial hazards associated with performing equivalent film work and aerial video productionwith conventional fixed-wing aircraft, rotorcraft, or othermethods. 

### X. CONCLUSION Mojo'sPetition for Exemption satisfies the criteria articulated in Section 333 ofthe Reform Act of2012 which includes weight; speed; operating capabilities; proximity to airports andpopulated areas; operation withinVLOS and national security. Theproposed MW-UAS operations will benefit the public as a whole by improving safety and reducing riskby alleviating human exposure to danger while lowering the attendant related costs thereby increasing the demand for the finished product. Inconsideration ofthe foregoing, this Petition for Exemptionprovides the FAA with more than adequatejustificationfor granting the requested exemptions allowing Mojo to use small MW-UAS inthe recordedproduction ofits product.U.S Department ofTransportation December 23 2015 Page 22

We thankyoufor yourprompt consideration ofourrequested exemptions. Respectfully Submitted,

Alexander R. Fakeri Mojo Web Solutions, LLC 8100 Ft. Smallwood Rd. Baltimore, MD 21226 Telephone: 410.439.1994 Email: alex@mojo.biz (The following attached items containproprietary and commercial information exempt from disclosure under the Freedom oflnformationAct, 5 U.S.C. § 522 et seq., and should be held in a separate file pursuant to 14 C.F.R. § 11.35(b)). Attachments: 1. General Operations Manual 2. PIC Operating Manual 3. Company Protocols 4. Location Protocols 5. Flight Communications Protocols 6. Departing LocationProtocols 7. TransmitterProtocols 8. Preflight Checklist 9. PostFlight Checklist 10. Equipment Checklist 11. UAS Manufacturer'sManuals a. User Manuals b. UAS Maintenance Manuals 

### PETITIONERREQUESTS THAT GOOD CAUSE EXISTS TOEXEMPT ANY PART OF THIS PETITIONFROMBEING PUBLISHED IN THE FEDERAL REGISTERPUBLIC FORUMBECAUSE THEREQUESTED EXEMPTIONWOULD NOT SET A PRECEDENT, AND ANY DELAY IN ACTING ON THIS PETITIONWOULD BE DETRIMENTAL TOTHE PETITIONER.