UAV Aerial Video for Exemption Page 1

FROM:

Chris McClintock

UAV Aerial Video

10716 County Road 1114

Princeton

, TX 75407

T el: 214

- 697

- 7279

Email: info@uavaerialvideo.com

T O:

DOCKET OPER A

TIONS

ROOM W12

- 140 OF THE WEST BUILDING

GROUND FLOOR

1200 NEW JERSEY A

VENUE, SE.

W ASHING T ON, DC, 20590

Regulat ory D ocket No.

PETITION FOR EXEMPTION OF :

UAV Aerial Video

FOR AN EXEMPTION SEEKING RELIEF FROM THE REQUIREMENTS OF

TITLE 14 OF THE CODE OF FEDERAL RE GU L A T IONS

P A R T 21, SUB P

A R T H AND S ECTIONS §§ 61. 1 13(a) & (b), 91.109, 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 COMM E RCIA L

OPER A TION OF DJI PHANTOM 2 VISION+ AND DJI PHAN T OM 3 PROF E SSIONA L

UNMANNED AIRCRAFT SYS TE MS

PURSUANT T O SECTION 333 OF

THE F AA MODERNIZ A

TION AND REFORM ACT OF 2012

(PUBLIC L A

W 1 12

- 95)

Submitted on May 20 , 2015UAV Aerial Video for Exemption Page 2 T ABLE OF C O N T EN TS

GLOSSA R

Y OF ABBREVI A

TIONS.........................................................................................3

SUM MA R

Y

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

INTRODUCTION AND INTERESTS OF PETITIONER.........................................................4

BACKGROUND........ .................................................................................................................4

BASIS FOR PETITION..............................................................................................................5

NAME AN D ADDRESS OF PETITIONER...............................................................................7

THE SPECIFIC SECTIONS OF 14 C. F .R. FROM WHICH UAV AERIAL VIDEO SEEKS

EXEMPTION........................................................................ ......................................................8

THE EXTENT OF RELIEF UAV AERIAL VIDEO SEEKS AND THE

REASON UAV AERIAL VIDEO SEEKS THE RELIEF................................................... 1 1

THE REASONS WHY GRANTING UAV AERIAL VIDEO REQUEST

WOULD BE I N THE PUBLIC INTEREST ...........................................................................15

THE REASONS WHY GRANTING THE EXEMPTION WOULD NOT

ADVERSE L

Y AFFECT SAFET Y

.................................................................................... .........19

SUMMA R

Y TH A T CAN BE PUBLISHED IN THE FEDERAL REGISTER.........................33

ANY ADDITIONAL INFORM A TION, VIEWS, OR ARGUMENTS

CONCLUSION..................................................................................................... ....................33UAV Aerial Video for Exemption Page 3 GLOSSA R

Y OF A BBRE VI A

T IONS

AGL Above Ground Level

AOI Area of Interest

A TC Air T ra f fic Control

A T O Air T ra f fic O r ganization

A V Aerial V ehicle

CFR Code of Federal Regulations

COA Certificate of Authorization

F AA Federal A vi ation Administration

F AR Federal A viation Regulation

GCS Ground Control Station

GPS Global Positioning System

LOL Loss of Link

NAS National Airspace System

NO T AM Notice to Airman

PIC Pilot In Command

Section 333 F AA Modernization and Reform Act of 201 2 (FMRA) Section 333

SO Safety Observer

SOP Standard Operating Procedures

UA Unmanned Aircraft

UAS Unmanned Aircraft System

VFR V isual Flight Rules

VLOS V isual Line of Site

VMC V isual Meteorological Conditions

V T OL V ertical T akeo f f and LandingUAV Aerial Video for Exemption Page 4 SUM MA R

Y

UAV Aerial Video (Chris McClintock) seeks exemption from the requirements of 14 C. F .R §§

61. 1 13(a) & (b), 91.109, 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 Syste m pursuant to Section 333 of the

F AA Modernization and Reform Act of 2012 (FMRA). This exemption will permit

UAV Aerial Video to operate an Unmanned Aircraft System (UAS) for the commercial purpose

of conducting aerial video and photography of Real Estate Properties (for homeowners, realtors,

home builders, home contractors and / or home inspectors for real estate marketing and

inspection of home exteriors) as well as filming of special events, film sets, scripted and

unscripted television sets and landscap e

, conducting power line inspection , aerial mapping,

surveying and search and rescue over certain areas of the United States.

INTRODUCTION AND INTERESTS OF THE P ETITI O NER

UAV Aerial Video is a production company based in Texas specializing in r eal estate

videograph y

, photograph y

, music video production, special event production and film and

television production. The principals of UAV Aerial Video (parent compa ny True Image

Productions LLC) have been in the video and entertainment production bus iness for over twenty

five years; have produced music videos and commercials, several reality television shows, award

shows, concerts

, special events, aerial mapping, power line inspection and search and rescue.

UAV Aerial Video’s objective is to conduct aerial photography and videography in order to

provide high quality digital imaging and video content t o its clients, in particular to homeowners,

real estate agents, realtors, home builders, home contractors, and/or home inspectors for real estate

marketi ng and inspections of home exteriors as well as filming of special events, film sets,

scripted and unscripted television sets and landscap e

, conducting power line inspection , aerial

mapping, surveying and search and rescue utilizing DJI Phantom 2 Vision + and/or DJI Phantom 3

UAS. More specificall y

, UAV Aerial Video aerial video and photography operations will serve in

the following areas:

• Aerial photography of houses / residential and commercial buildings and power lines

• Aerial videography of houses / residential and commercial buildings and power lines

• Aerial event photography

• Aerial event filming

• Aerial Film & T

elevision productionUAV Aerial Video for Exemption Page 5

• Aerial search and rescue and safety in spection s

• Increase public knowledge of UAS and promote safe UAS operations.UAV Aerial Video for Exemption Page 6

The proposed aerial filming will be conducted over private property with controlled access in the

NAS and with the knowledge and permit of the private property ’ s owne r

.

Unm anned Ai r

craft Systems: DJI Phantom 2 Vision+

, Phantom 3 P r ofessional UAS

UAV Aerial Video seeks an exemption to operate DJI systems DRONES for compensation

or hire within the NAS. The DJI Phantom 2 Vision+

, DJI Phantom 3 Professional are vertical

take o f f and landing (V T OL) Unmanned Aircrafts (UAS) with a Ground Control Station (GCS)

utilizing electronic tablet or smart phone systems. The DJI Phantom 2+ , DJI Phantom 3

Professional have a maximum gross weight of approximately 2 pounds 1 1 ounces, while ha ving a

length of 16 inches width of 16 inches, height of 8 inches, and a maximum speed of

approximately 29 knots. The DJI Phantom 2 Vision +

, DJI Phantom 3 Professional UAS are

equipped with four main rotors; driven by Lithium Polymer battery powered electr ic motors.

The DJI Phantom 2 Vision + , DJI Phantom 3 Professional UAS that will be operated by

UAV Aerial Video (trained professional), 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

Petitione r

, UAV Aerial Video

, pursuant to the provisions of the Federal A viation

Regulations (14 C. F

.R. § 1 1.61) and the F

AA Mode rnization and Reform Act of 2012

(FMRA), Section 333, Special Rules for Certain Unmanned Ai r craft Systems

, hereby

petitions the Administrator to commercially operate the DJI Phantom 2 V ision+ , DJI Phantom 3

Professional UAS

in the National Airspace System (NAS), and for an exemption from the requirements of 14 C. F .R

§§ 61. 1 13(a) & (b), 91.109, 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 operatin g area associatedUAV Aerial Video for Exemption Page 7

with the unmanned aircraft and its operation, UAV Aerial Video operation of DJI Phantom 2

V ision+ , DJI Phantom 3 Professional UAS meets the conditions of FMRA Section 333 and

therefore, will not require an airworthiness certificate in ac cordance with 14 C. F .R. Part 21,

Subpart H. Accordingl y

, UAV Aerial Video 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 aircraf t with an airworthiness certificate.

UAV Aerial Video submits that the requested relief is proper since an equivalent

level of safety will be ensured. UAV Aerial Video will use experienced personnel or

technicians to perform maintenance, alterations, or pr eventive maintenance on the UAS ’ s

using the methods, techniques, and practices prescribed in the operating documents (i.e.,

Monthly Maintenance Log, and DJI Phantom 2 V ision+ , DJI Phantom 3 Professional

Instruction Manual). Furthermore, UAV Aerial Video wi ll document and maintain all

maintenance records for the DJI Phantom 2 Vision+ and DJI Phantom 3 Professional UAS.

Relief from certain requirements of Section 61. 1 13(a) and (b), entitled Private pilot privileges

and limitations : Pilot In Command, is requ ested by UAV Aerial Video to the extent necessary

to allow a Pilot in Command (PIC) holding a Supplemental Pilot Certificate,

and who has demonstrated, by meeting minimum flight

- hour and currency requirements, that the

PIC is able to safely operate the DJ I Phantom 2 V ision+ , DJI Phantom 3 Professional UAS in a

manner consistent with this exemption, including evasive and eme r gency maneuvers and

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

UAV Aerial Video seeks relief f rom Section 91.7(a), entitled Civil ai r craft airworthiness

,

because the DJI Phantom 2 V ision+ , DJI Phantom 3 Professional UAS do not require an

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

Aerial Video submits tha t it will ensure that the Phantom 2 Vision+

, DJI Phantom 3

Professional UAS are in an airworthy condition, prior to every flight, by determining that the

UAS ’ s are in compliance with the operating documents (i.e., Monthly Maintenance Log, and

DJI Phantom 2 V

ision+ , DJI Phantom 3 Professional Instruction Manual), and that the

aircraft are in a condition for safe flight. UAV Aerial Video also seeks an exemption from

the requirements of SectionUAV Aerial Video for Exemption Page 8

91.121, entitled Altimeter Settings

, as the DJI Phantom 2 V ision+

, DJI Phantom 3 Professional

UAS will not have a typical barometric altimeter onboard. Howeve r

, altitude information of the

DJI Phantom 2 V

ision+

, DJI Phantom 3 Professional UA will be provided to the PIC via Global

Positioning System (GPS) equipment and ra dio communications telemetry data link, which

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

information, combined with UAV Aerial Video ’ s operation of the DJI Phantom 2 V ision+ , DJI

Phantom 3 Professional UAS withi n visual line of sight, at or below 200 feet AGL, will ensure a

level of safety equivalent to Section 91.121.

Additionall y

, UAV Aerial Video seeks an exemption from the requirements of

Section 91.151(b), entitled Fuel r equi r ements for flight in VFR cond itions. UAV Aerial Video

submits that safety will not be a f fected by operation of the DJI Phantom 2 V ision+

, DJI Phantom

3

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

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

In accordance with 14 C. F .R. § 1 1.81, UAV Aerial Video provides the f ollowing

information in support of its petition for exemption:

A. Name And Add r

ess Of The Petitione r

.

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

Chris McClintock

UAV Aerial Video

(parent company True Image Productions LLC)

10716 C ounty Road 1114

Princeton, TX 75407

T el: 214

- 697

- 7279

Email: info@uavaerialvideo.comUAV Aerial Video for Exemption Page 9

B. The Specific Sections Of 14 C. F .R. Fr om Which UAV Aerial Video Seeks

Exemption.

1. UAV Aerial Video Seeks Exemption From The Requirements Of Section

61. 1 13(a) And (b).

Section 61. 1 13, 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 certifica te may act as a pilot in command

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

hire; nor may that person, for compensation or hire, act as PIC of an aircraft.

(b) A private pilot ma y

, 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 aircraft does not carry passengers or property for compensation or

hire.

2. UAV Aerial Video Seeks Exemption Fro m The Requirements Of Section 91.7(a).

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

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

3. UAV Aerial Video 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 operating 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 station 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 altimete r setting available before departure.UAV Aerial Video for Exemption Page 10

4. UAV Aerial Video 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 first point of intended landing and, assuming normal cruising speed, to

fly after that for at least 20 minutes.

5. UAV Aerial Video Seeks Exemption From The Requirement Of 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 i n subpart E of this part and shall

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

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

6. UAV Aerial Video Seeks Exemption From The Requirements Of Se ction

91.407(a)(1) Section 91.407, entitled Operation after maintenance, preventive

maintenance, rebuilding, or alteration, subsection (a)(1), states the following:

(a) No person may operate any aircraft that has unde r gone maintenance, preventive

mainten ance, rebuilding, or alteration unless

--

(1) It has been approved for return to service by a person authorized under §

43.7 of this chapter[.]

7. UAV Aerial Video Seeks Exemption From The Requirements Of Sections

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

Secti on 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 ac cordance with part 43 of this chapter and hasUAV Aerial Video for Exemption Page 11 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 chapte r

.

8. UAV Aerial Video 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 §§ 91.4 1 1 and 91.413, eac h

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

specified in paragraph (b) of this section:

(1) Records of the maintenance, preventive maintenance, and alteration and

records of the 100

- hou r , annual, progressive, and other r equired or approved

inspections, as appropriate, for each aircraft (including the airframe) a nd

eac h engine, propelle r

, roto r

, and appliance of an aircraft. The 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 tim e in service of the airframe, each engine, each propelle r

, and

each roto r

.

(ii) The current status of life

- limited parts of each airframe, engine,

propelle r

, roto r

, 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 inspection required by the inspection program under which theUAV Aerial Video for Exemption Page 12 aircraft and its appliances are maintained.

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

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

safety directive number and revision date. 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 currently installed engines, rotors,

propellers, and appliances.

(b) The owner or operator shall reta in 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 repeated or superseded by other work or for 1 year after the

work is performed.

(2) The records specifi ed 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. 1 1 of

this chapter shall be retained until the defec ts are repaired and the aircraft is

approved for return to service.

C. The Extent Of Relief UAV Aerial Video Seeks And The Reason UAV Aerial Video Seeks

The Relief.

1. Extent Of Relief UAV Aerial Video Seeks And The Reason UAV Aerial

Video Seeks Relie f From Section 61. 1 13(a) And (b).

Relief from Section 61. 1 13(a) and (b) entitled Private pilot privileges and

limitations: Pilot in command, is requested to the extent necessary to allow a PIC

holding a Supplemental Pilot Certificate

, as well as a current and valid

airman medical certificate, and who has met certain flight

- hour and currency

requirements, to conduct the proposed UAS flight operations for compensation or

hire. This relief is requested since the limitations set forth in Section 61. 1 13(a)

and (b) state that a private pilot ma y

, for compensation or hire, act as PIC of an

aircraft in connection with any business or employment if: (1) The flight is onlyUAV Aerial Video for Exemption Page 13 incidental to that business or employment; and (2) The aircraft does not carry

passengers or p roperty for compensation or hire.

As set forth more fully belo w

, UAV Aerial Video submits that an equivalent level

of safety will be maintained because no PIC will be allowed to operate the DJI

Phantom 2 V

ision+, Phantom 3 Professional UA unless that P IC has met certain

flight

- hour and currency requirements, demonstrating that the PIC is able

to safely operate either the DJI Phantom 2 V ision+, Phantom 3 Professional UAS

in a manner consistent with the operations specifications as described in this

exemp tion, including evasive and eme r gency maneuvers, as well as maintaining

appropriate distances from people, vessels, vehicles and structures. Furthe r

, UAV

Aerial Video submits that all flights of the DJI Phantom 2 V ision+, Phantom 3

Professional UAS, conduc ted by the PIC pursuant to the grant of this Petition: (1)

will be incidental to UAV Aerial Video business; and (2) will not carry

passengers or property for compensation or hire.

UAV Aerial Video believes that though UAS are not traditional aircrafts, a PIC

operating the UA must have knowledge of Airman rules, basic Airspace and

comply with all the rules proposed by the F AA. Howeve r

, considering the fact

that a UA is almost like a to y

, weighing less than a skinny person, the PIC may be

e xcept from obtai ning a Private Pilot Certificate, a Sports Certificate, a

Recreational Certificate considering these certificates require flight hours of

several thousand tons weighing aircrafts. The operation of UAS by UAV Aerial

Video is strictly for entertainment / inf ormational purposes, thus the operators of

the UAS have a career and / or freelance employment as a Camera Operator and

Cinematographer and will be not be entertaining a career as a pilot. Lastl y

, UAV

Aerial Video PICs will operate the UAS no higher than 2 00 feet, consequently

causing no danger do any other aircraft in the NAS. Howeve r

, UAV Aerial

Video Proposes PIC Certification as a Supplemental

pilot and a minimum requirement of successfully completed private pilot ground

school. Additionall y

, supplem ental pilots without a current F AA private pilotUAV Aerial Video for Exemption Page 14 certificate must have successfully passed the private pilot, commercial pilot, or

airline transport pilot knowledge test within the past 24 calendar months.

2. Extent Of Relief UAV Aerial Video Seeks And The Reason UAV Aerial

Video Seeks Relief From Section 91.7(a).

Relief from Section 91.7(a) entitled Civil aircraft airworthiness, is requested to

the extent required to allow UAV Aerial Video to determine that the DJI

Phantom 2 V

ision+, Phantom 3 Professional UAS are in airworthy condition

prior to every flight by ensuring that the UAS is in compliance with the operating

documents (i.e., the UAV Aerial Video Aerial Operations Manual, Monthly

Maintenance Log, and DJI Phantom 2 V ision+, Phantom 3 Professional

Instru ction Manual). UAV Aerial Video seeks the requested relief because the

DJI Phantom 2

V ision+ , Phantom 3 Professional UAS do not require an airworthiness certificate in

accordance with 14

C. F .R. Part 21, Subpart H. Therefore, UAV Aerial Video will ensure that the

DJI Phantom 2 V

i sion+ UAS are in airworthy condition based upon its

compliance with the operating documents (i.e., Monthly Maintenance Log, and

DJI Phantom 2 V

ision+, Phantom 3 Professional Instruction Manual) prior to

every flight, and furthe r

, determine that the aircraf t are in condition for safe flight,

as stated in the conditions and limitations belo w

.

3. Extent Of Relief UAV Aerial Video Seeks And The Reason UAV Aerial

Video 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 V ision+, Phantom 3 Professional UAS,

which utilize a barometric pressure senso r

, 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 F AA requires that any

altitude information concerning UAS operations be reported to air tra f fic control

( A TC) in feet above ground level (AGL), UAV Aerial Video seeks the

requested relief because t he DJI Phantom 2 V ision+

, Phantom 3 Profess ional

U A ’ s altimeter may be set on the ground to zero feet AGL, rather than the local

barometric pressure or fieldUAV Aerial Video for Exemption Page 15

altitude, before each flight.Considering the limited altitude of the proposed operations, relief from

14 CFR 91.121 is so ught to the extent necessary to comply with the applicable conditions and

limitations stated belo w

. As more fully set

forth herein, an equivalent level of safety will be maintained since the DJI

Phantom 2 V

ision+, Phantom 3 Professional UAS are equipped w ith 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

with altitude information of the UA on the heads

- up display of the GCS.

4. Extent Of Relief UAV Aerial Video Seeks And The Reason UAV Aerial

Video 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 t he battery

powered DJI Phantom 2 V ision+, Phantom 3 Professional UAS during daylight

hours in visual meteorological conditions (VMC), under visual flight rules (VFR),

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

assuming normal cruising speed, to fly after that for at least 4.5 minutes. UA V

Aerial Video seeks the requested relief because without an exemption

from Section 91.151(b), the flight time duration of the battery powered DJI

Phantom 2 V

ision+, Phantom 3 UA will s everely constrain the practicality of any

aerial video or still photo flight operations that UAV Aerial Video proposes to

conduct pursuant to this Petition.

Significantl y

, as set forth belo w

, the technical specifications of the DJI Phantom 2

V ision+

, Phantom 3 Professional UAS operating documents, and UAV Aerial

Video proposed operating limitations, ensure that UAV Aerial Video will safely

operate the battery powered DJI Phantom 2

V ision+, Phantom 3 Professional UAS during daylig ht hours 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 least

4.5 minutes.UAV Aerial Video for Exemption Page 16

! ! 5. Extent Of Relief UAV Aerial Video Seeks And The Reason UAV Aerial

Video Seeks Relief From Section 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2),

And 91.417(a) & (b).

Since Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & ( a)(2), and 91.417(a) &

(b) only apply to aircraft with an airworthiness certificate, UAV Aerial Video

requests relief from these Sections because the DJI Phantom 2 V ision +, Phantom

3 Professional UAS do not require airworthiness certificates. As set forth more

fully belo w

, the DJI Phantom 2 V ision+, Phantom 3 Professional UAS meet the

conditions of FMRA Section 333 for operation without an airworthiness

certificate. Accordingl y

, UAV Aerial Video will use trained technicians to

perform maintenanc e, alterations, or preventive maintenance on the UAS using

the methods, techniques, and practices prescribed in the UAS operating

documents (i.e., the UAV Aerial Video Aerial Operations Manual, Monthly

Maintenance Log, and DJI Phantom 2 V ision+, Phant om 3 Professional

Instruction Manual). Furthermore, UAV Aerial Video will document and

maintain all maintenance records for the DJI Phantom 2 V ision+, Phantom 3

UAS.

D. The Reasons Why Granting UAV Aerial Video Request W ould Be In The

Public Inte r

est; That Is, How It W

ould Benefit The Public As A Whole.

Granting the present Petition will further the public interest by allowing UAV Aerial

Video to safel y

, e f

ficientl y

, and economically perform aerial video and photography

of real estate, special e vents, film sets, and landscape over certain areas of the United

States.

Additionall y

, use of the DJI Phantom 2 V ision+, Phantom 3 Professional UAS will

decrease congestion of the NAS, reduce pollution, and provide significant benefits to the

econom y

. No tabl y

, the benefits of UAV Aerial Video’s proposed operation of the DJI

Phantom 2 V

ision +

, Phantom 3 UAS will be realized without implicating any privacy

issues.

1. The Public W

ill Benefit From Decreased Congestion Of The NAS.UAV Aerial Video for Exemption Page 17 The DJI Phantom 2 V

ision+, Phantom 3 Professional UA are battery powered and

serve as a safe, e f

ficient, and economical alternative to the manned aircraft

traditionally utilized to obtain aerial imager y

. By reducing the amount of manned

aircraft needed to perform aerial acquisitions

, an exemption allowing the use of a

DJI Phantom 2 V

ision+, Phantom 3 Professional UAS would reduce the amount of

manned aircraft in the NAS, reduce noise and air pollution, as well as increase the

safety of life and property in the air and on the ground.

Furthermore, by reducing the number of manned aircraft operating in the NAS,

congestion around airports caused by arriving and departing aircraft will be

reduced. The DJI Phantom 2 V ision+, Phantom 3 Professional UA do not require

an airport to takeo f

f or land. Likewi se, a reduction of manned aircraft conducting

aerial video and photography missions would result in fewer aircraft that must be

handled by air tra f

fic control during the ground, takeo f f, departure, arrival, and

landing phases of flight operations.

2. The Public W

ill Benefit From The Safety And E f ficiency Of The DJI

Phantom 2 V

ision+, Phantom 3 UAS.

Conducting aerial acquisitions with the DJI Phantom 2 V ision+, Phantom 3

Professional UAS, instead of manned aircraft, will greatly benefit the public by

dras tically 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 V ision+, Phantom 3 Professional

UAS produce no air pollu tion, 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 photograph y

, while burning

approximately 20

- 30 gallons per hour of lead ed aviation fuel. The DJI Phantom 2

V ision+, Phantom 3 Professional UA, while reducing the carbon footprint of

aerial acquisitions, also eliminates noise pollution, as the UAS are propelled by

battery powered electric motors, rather than an internal combus tion engine. By

using the DJI Phantom 2 V ision+, Phantom 3 Professional UAS to

perform aerial acquisitions, the substantial risk to life and property in the air andUAV Aerial Video for Exemption Page 18 on the ground, which is usually associated with traditional manned aircraft flight

operati ons, will be substantially reduced or completely eliminated. Aside from the

lack of flight crew members located onboard the aircraft, the DJI Phantom 2

V ision+, Phantom 3 UAS (weighing approximately 2 pounds 1 1 ounces and 6

pounds 7.5 ounces respectivel y

, at their maximum gross weights with lengths of

16 inches and 17.3 inches respectivel y

, widths of 16 inches and 17.7 inches

respectivel y

, and with no fuel on board), has less physical potential for collateral

damage to life and property on the ground, and in the ai r

, compared to the manned

aircraft that typically conduct similar operations (weighing approximately 6,000

pounds with a wingspan of approximately 42 feet, a length of 34 feet, and a fuel

capacity of 180 gallons).

3. Performing Aerial V

ideo and Photography Operations W ith The DJI

Phantom 2 V

ision+, Phantom 3 UAS W ill Benefit The Econom y

.

In addition to being safe and e f ficient, the DJI Phantom 2 V ision+, Phantom 3

Professional is also an economical alternative to using manned aircraft to conduc t

similar aerial operations. As such, operation of the DJI Phantom 2 V ision+,

Phantom 3 Professional UAS will allow United States based companies, like UAV

Aerial Video

, to remain competitive and contribute to growth of the U.S.

econom y

. Specificall y

, with the rising cost of aviation fuel and the Environmental

Protection Agency (“E P

A”) regulatory actions phasing out leaded aviation fuels,

U.S. owned and operated companies must adopt new and alternative technology

in order to remain competitive. Operating th e battery powered DJI Phantom 2

V ision+, Phantom 3 Professional UAS is one such technology that not only allows

companies greater operational flexibility compared to manned aircraft, but provide s

such flexibility without the high operational cost of a tra ditional manned aircraft.

By operating the DJI Phantom 2 V ision+, Phantom 3 Professional UAS,

companies such as UAV Aerial Video

, can remain competitive and profitable,

and therefore, provide greater job stability to employees and contractors, which

will u ltimately contribute to growth of the U.S. econom y

. Improved financialUAV Aerial Video for Exemption Page 19 performance of U.S. companies, through commercial use of the DJI Phantom 2

V ision +, Phantom 3 Professional UAS, provides a stable workforce that increases

consumer spending; improves local, state, and federal tax revenues; and allows

companies to invest in research and development in order to remain competitive

both in the United States and abroad.

4. There Are No Privacy Issues.

Similar to the manned aerial acquisition flight oper ations that have been

conducted for decades, UAV Aerial Video proposed operation of the DJI

Phantom 2 V

ision+, Phantom 3 UAS will not implicate any privacy issues.

Specificall y

, the DJI Phantom 2 V ision+, Phantom 3 Professional UAS will be

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

Video Aerial Operations Manual, Monthly Maintenance Log, and DJI Phantom 2

V ision+, Phantom 3 Professional Instruction Manual) which requires property

owner involvement as well as local law enforc ement notification, and in

accordance with the Federal A viation Regulations, including the minimum

altitude requirements of 14 C. F .R. § 91. 1 19.

E. The Reasons Why Granting The Exemption W ould Not Adversely Affect Safet y

,

Or How The Exemption W ould P r ovid e A Level Of Safety At Least Equal T o That

P r ovided By The Rule F

r om Which UAV Aerial Video Seeks Exemption.

1. Reasons Why The DJI Phantom 2 V ision+, Phantom 3 Professional UAS Meet The Conditions

Of The F AA 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, UAV Aerial Video operation of the DJI

Phantom 2 V

ision+, Phantom 3 Professional UAS meet the conditions of FMRA Section 333,

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

H.

Section 333 provides authority for a UAS to operate without airworthiness

certification and sets forth requirements for considering whether a UAS will creat e a

hazard to users of the NAS or the public, or otherwise pose a threat to national securit y

.UAV Aerial Video for Exemption Page 20

Specificall y

, FMRA Section 333 states the following, in part:

(a) In General.

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

later than 180 d ays after the date of enactment of this Act, the Secretary of

T ransportation shall determine if certain unmanned aircraft systems ma y operate

safely in the national airspace system before completion of the plan

and rule

- making required by section 332 of th is Act or the guidance required by

section 334 of 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 an y

, as a result of their

size, weight, speed, operational capabilit y

, 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 natio nal security; and

(2) whether a certificate of waive r

, 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 Safe 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 a ircraft systems in the national airspace system.

In seeking this exemption, UAV Aerial Video submits that the DJI Phantom 2

V ision+ , Phantom 3 Professional UAS can operate safely in the NAS pursuant to

FMRA Section 333, as demonstrated by: (a) the characteristics of the DJI

Phan tom 2 V

ision+, Phantom 3 Professional UAS;

(b) the pilot certification requirement; and (c) the specific operating limitations.

a. The Specifications Of The DJI Phantom 2 V ision+, Phantom 3 P r

ofessional

UAS Demonstrate Its Safe Characteristics.UAV Aerial Video for Exemption Page 21 The D JI Phantom 2 V

ision+, Phantom 3 Professional UAS does 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 capabilit y

.

i. T echnical Specifications Of T he DJI Phantom 2 V ision+, Phantom 3

Professional UAS.

The technical specifications of the DJI Phantom 2 V ision+, Phantom 3

Professional UAS is set forth by the DJI Phantom 2 V ision+, Phantom 3

Professional Specifications and Data Sheet, attached hereto as Exhibit A.

ii. The DJI Phantom 2 V

ision+, Phantom 3 Professional UAS Autonomous

Flight And Navigation Modes Enable The UAS T o Remain W

ithin A

Defined Operational Area. The DJI Phantom 2 V ision+, Phantom 3

Professional UAS may be operated in both man ual and fully autonomous

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

of the DJI Phantom 2 V

ision+, Phantom 3 UAS is provided at pages 25

- 35

of the DJI Phantom 2 V

ision+, User Manual, attached hereto as

Exhibit B & D (Phantom 3 User Manual will be available after May 15,

2015; howeve r

, is very similar to DJI Phantom 2 V ision+ User Manual).

iii. The DJI Phantom 2 V

ision+, Phantom 3 Professional UAS A re

D e s igne d For Automatic Return T o Home Point Or Hover In The Event Of

Loss Of The Control Link Or Navigation. When the Control Link is lost,

the DJI Phantom 2 V

ision+ UA will remains stationar y

, in flight, for 3

seconds or more. If, after 3 seconds, the DJI Phantom 2 V ision+, Phantom

3 Professional UA does 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

takeo f f position and shutdown. A complete description of the Failsafe

Functions of the DJI Phantom 2 V ision+, Phantom 3 Professional UAS

are set forth atUAV Aerial Video for Exemption Page 22 pages 27 through 29 of the DJI Phantom 2 V ision+, (Phantom

3) Professional User Manual, attached hereto as B & D.

i v

. The DJI Phantom 2 V

ision+, Phantom 3 Professional GCS And Its

Operation.

A complete description of the operation and specifications of the DJI

Phantom 2 V

ision+, Phantom 3 GCS and flight control software is

provided at pages 32 through 43 of the DJI Phantom 2 V ision+, (Phantom

3) Professional User Manual. DJI Phantom 2 V ision+ User Manual is

attached hereto as Exhibit B & D.

b. Flight Operations Of DJI Phantom 2 V ision+, Phantom 3 P r

ofessional

UAS A r e Limited T

o The Line Of Sight Of A Certificated Pilot in Command

W ith A Safety Observe r

.

UAV Aerial Video will only utilize ce rtificated pilots who possess a current and

valid airman medical certificate to act as a pilot in command (PIC) of the DJI

Phantom 2 V

ision +

, Phantom 3 Professional UAS. Additionall y

, a safety observer

will a ss i s t all pilots during flight time.

c. Flights Of DJI Pha ntom 2 V ision+, Phantom 3 P r

ofessional UAS W ill Be

Conducted Pursuant T

o Specific Operating Limitations.

In seeking this exemption, proposes to commercially operate DJI Phantom 2

V ision + , Phantom 3 Professional UAS for the special purpose of conducting

aerial video and photogr aphy 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 described in the operating documents, rotorcraft UASs weighi ng less

than 55 pounds maximum gross weight: DJI Phantom 2 V ision+, Phantom 3 Professional

Unmanned Aircraft System. Proposed operations of any other aircraft will require a new

petition or a petition to amend this grant.UAV Aerial Video for Exemption Page 23

2. UAS operations under this e xemption will be limited to conducting operations for the

purpose of aerial video and photography for homeowners, Realtors, home builders,

contractors, home inspectors for use in real estate marketing and real estate inspections.

Additionall y

, aerial video and photography may be conducted on occasional basis for

film and television sets, special events and landscape photography , conducting power

line inspection, aerial mapping, surveying as deemed necessar y

.

3. The UAS may not be flown at an indicated airspeed exceeding 29 knots (15 m/s).

4. The UAS must be oper ated at an altitude of no more than 200 (500 per the User

Manual) feet above ground level (AGL), as indicated by the procedures specified in the

operating documents unless a special request is made and approved by A TC. All altitudes

reported to A

TC must be in feet AGL.

5. The UAS must be operated within visual line of sight (VLOS) 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 F AA

- issued airman

med ical certificate.

6. The use of first person view (FPV) by the PIC or safety 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 V LOS capabilit y

.

The SO and PIC must be able to communicate verbally at all times. Electronic

messaging or texting is not permitted during flight operations. The PIC must be

designated before the flight and cannot transfer his or her designation for the

du ration of the flight. The PIC must ensure that the SO can perform the

functions prescribed in the operating documents.UAV Aerial Video for Exemption Page 24

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

and avoiding other air tra f fic and other ground based o bstacles/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, th e operator must follow the procedures as

outlined in its operating documents. The operator may update or revise its

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

and present updated and revised documents to the Administra tor upon request.

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

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

that any update or revision would a f fect the basis upon which the F AA granted

th e exemption, then the operator must petition for amendment to its grant of

exemption. The F

A A ’ s UAS Integration O f

fice (AFS

- 80) may be contacted if

questions arise regarding updates or revisions to the operating documents.

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

condition for safe flight. If the inspection reveals a condition that a f fects the

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

necessary maintenance has been performed and t he 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.

1 1. Any UAS that has unde r gone maintenance or alterations that a f fect the UAS

operation or flight characteristics, e.g. replacement of a flight critical

component , must unde r go a functional test flight. The PIC who conducts theUAV Aerial Video for Exemption Page 25

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

12. The pre

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

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

relevant sections of the operating documents.

13. The operator must follow the UAS manufacture r ’ s air craft/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,

inspecti on, alterations, and status of replacement/overhaul component 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. Eac h UAS 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 P IC must possess at least a Suplemental Pilot certificate and at least a current

third

- class medical certificate. Supplemental pilots must have, at a minimum,

successfully completed private pilot ground school. Additionall y

, supplemental pilots

without a c urrent F

AA private pilot certificate must have successfully passed the private

pilot, commercial pilot, or airline transport pilot knowledge test within the past 24

calendar months.

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

operato r ’ s qualification criteria and demonstrates the ability to safely operateUAV Aerial Video for Exemption Page 26

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

exemption, including evasive and eme r gency 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 operato r ’ s PICs are

permitted under the terms of the exemption. Howeve r

, tr aining operations may

only be conducted during dedicated training sessions. During training,

proficienc y

, and experience

- building 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. 1 19.

19. UAS operations may not be conducted during night, as defined in 14 C. F .R. §

1.1. All operations must be conducted under visual meteorological conditi ons (VMC).

If flig ht at night is required, a special request will be made at the F AA o f fice closest

to proposed area of operations. Flights under special visual flight

rules (SVFR) are not authorized.

20. The UA may not operate within 5 nautical miles of an airport refer ence point as

denoted on a current F

AA

- published aeronautical chart unless a letter of

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

conducted in accordance with a NO T AM as required by the operato r ’ s COA.

The letter of agreeme nt 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

PI C.

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

predetermined location within the planned operating area and land or be recoveredUAV Aerial Video for Exemption Page 27

in accordance with the operating documents.

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

eme r gencies in accordance with the operating documents.

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

forecast weather conditions) there is enough 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 T ra f fic O r ganization ( A

T O) issued Certificate

of W aiver or Authorization (COA) prior to conducting any operations under the

grant of exempti on. This COA will also require the operator to request a Notice

to Airman (NO T

AM) 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 A T O i ssued 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 numbe r

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

identi fication (N

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

Subpart C. Markings must be as la r ge 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 fewer 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 opera ting. These

documents must be made available to the Administrator or any law enforcement o f ficial

upon request.UAV Aerial Video for Exemption Page 28

29. The UAS 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 struc tures unless:

a. Barriers or structures are present that su f ficiently 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 situatio n

arises where nonparticipating persons leave such protection and are within 500

feet of the UA, flight operations must cease immediately and/or;

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

owner/controller of such vessels, v ehicles 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 e ssential persons

do not present an undue hazard to those persons per § 91. 1 19(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 appl icable COA must be

reported to the F

AA's UAS Integration O f fice (AFS

- 80) within 24 hours. Accidents must

be reported to the National T ransportation Safety Board (NTSB) per instructions

contained on the NTSB W eb site: ww w .ntsb.go v

.UAV Aerial Video for Exemption Page 29

2. Reasons Why An Exemption F r om The Requi r ements Of Section 61. 1 13(a)

And (b) W

ould Not Adversely Affect Safet y

.

UAV Aerial Video submits that the equivalent level of safety established by Section 61. 1 13(a)

and (b) will be maintained because no PIC will be allowed to operate the DJI Phantom 2 V ision

+, Phantom 3 Professional 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 V ision

+

, Phantom 3 Professional UAS in a manner consistent with the exemption, including evasive

and eme r gency maneuvers and maintaining appropriate distances from people, vessels, vehicles

and structures.

Considering UAV Aerial Video proposed area of operations

, and the operating limitations set

forth

- above; the parallel nature of private pilot aeronautical knowledge requirements to those of

commercial pilot requirements (See Exemption No. 1 1062); and the airmanship skills necessary

to safely operate the DJI Pha ntom 2 V ision+, Phantom 3 Professional UAS, UAV Aerial Video

submits that the additional manned airmanship experience of a commercially certificated pilot

would not correlate to the airmanship skills necessary for UAV Aerial Video specific proposed

flight operations.

The F AA has previously granted relief from Section 61. 1 13(a) and (b) specific to

UAS, in circumstances simila r

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

Exemption Nos. 1 1062, 1 1063, 1 1064, 1 1065, 1 1066, 1 1067, 1 1080, 11 109, 11 1 10, 111 12,

11 136, 11 138, 11 150, 11 153, 11 156, 11 158, 11 159, 11 160, 11 161).

3. Reasons Why An Exemption F r om The Requi r ements Of Section 91.7(a)

W ould Not Adversely Affect Safet y

.

The equivalent level of safety established by Section 91.7(a) will be mai ntained

because prior to every flight, UAV Aerial Video will ensure that the DJI Phantom 2

V ision+ , Phantom 3 Professional UAS is in an airworthy condition based upon the

UAS ’ s compliance with its operating documents and as stated in the conditions and

limitations herein. Additio nall y

, the F AA has previously granted relief from Section

91.7(a) specific

to UAS, in circumstances simila r

, in all material respects, to those presented herein (e.g.UAV Aerial Video for Exemption Page 30

Exemption Nos. 1 1062, 1 1063, 1 1064, 1 1065, 1 1066, 1 1067, 1 1080, 11 109, 111 10, 111 12,

11 136, 11 138, 11 150, 11 153, 11 156, 11 157, 11 158, 11 159, 11 160, 11 161).

4. Reasons Why An Exemption F r om The Requi r ements Of Section 91.121

W ould Not Adversely Affect Safet y

.

The equivalent level of safety established by Section 91.121 will be maintained

because the altitude information of the DJI Phantom 2 V ision +

, Phantom 3 Professional 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 an d altitude.

This altitude information, combined with UAV Aerial Video’s operation of the DJI Phantom 2

V ision+, Phantom 3 Professional UAS within visual line of sight, at or below 500 feet AGL,

will ensure a level of safety equivalent to Section 91.121. The altitude i nformation 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 F AA has previously granted relief from Section 91.121 specif ic to UAS, in

circumstances simila r

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

1 1062, 1 1063, 1 1064, 1 1065, 1 1066, 1 1067, 1 1080, 11 109, 111 12, 11 136, 11 138,

11 150, 11 153, 11 156, 11 157, 11 158, 11 159, 11 160, 11 161).

5. Reas ons Why An Exemption F r om The Requi r ements Of Section 91.151(b)

W ould Not Adversely Affect Safet y

.

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

14 C. F .R. Section 91.151(b) as a result of (1) the technical specifica tions of the DJI

Phantom 2 V

ision+, Phantom 3 Professional UAS; (2) the limitations on the proposed flight

operations; and (3) the location of the proposed flight operations. Accordingl y

, UAV Aerial

Video will ensure that it will safely operate the battery powered DJI Phantom 2 V ision+,

Phantom 3 Professional UA during daylight hours in VFR conditions, with enough battery power

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

normal cruising speed, to fly after that for a t least 4.5 minutes.

Here, as in Exemption No. 11 109, the technical specifications of the DJI Phantom 2UAV Aerial Video for Exemption Page 31

V ision+, Phantom 3 Professional UAS; the limitations on the proposed flight operations; and the

location of the proposed operations, will ensure an equivalent leve l of safety established by 14

C. F .R. Section 91.151(b). Furthermore, safety will be ensured as the DJI Phantom 2 V ision+,

Phantom 3 Professional UAS provide audible and visual warnings to the PIC at the GCS when

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

remaining battery powe r

, and again at approximately 10% remaining battery powe r

. At the

critically low battery level, the DJI Phantom V ision+, Phantom 3 UAS will descend and land

automaticall y

. Significantl y

, previous exemptions granted by the F AA concerning Section

91.151

establish that safety is not adversely a f fected 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. Moreove r

, the F AA has previously granted relief

from Section 91.151 specific to UAS, in circumstances simila r

, in all material respects, to

those prese nted herein (e.g. Exemption Nos. 88 1 1, 10808, 10673, 1 1042, 1 1062, 1 1063,

1 1064, 1 1065, 1 1066, 1 1067, 1 1080, 11 109, 111 10, 11 136, 11 138, 11 150, 11 153, 11 156,

11 157, 11 158, 11 159, 11 160, 11 161).

6. Reasons Why An Exemption F r om The Requi r ements Of Secti ons

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

Not Adversely Affect Safet y

.

In seeking this exemption, UAV Aerial Video 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 UAV Aerial Video will use trained technicians to perform maintenance,

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

practices prescribed in the operating documents (i.e., the UAV Aerial Video Aerial Operations

Manual, Monthly Maintenance Log, and DJI Phantom 2 V ision+, Phantom 3 Professional

Instruction Manual). Furthermore, UAV Aerial Video wi ll document and maintain all

maintenance records for the DJI Phantom 2 V ision+, Phantom 3 Professional UAS.

Since the DJI Phantom 2 V ision+, Phantom 3 Professional UAS will be inspected as prescribedUAV Aerial Video for Exemption Page 32

by the operating documents, UAV Aerial Video will mainta in the equivalent level of safetyUAV Aerial Video for Exemption Page 33

established by Sections 91.405(a), 91.409(a)(1), and 91.409(a)(2). A copy of the DJI

Phantom 2 V

ision+ User Manual is attached hereto as Exhibit B & D; a copy of the DJI Phantom

2 V ision+, Phantom 3 UAS Maintenance LOG is attached hereto as Exhibit C.

Likewise, the exemption sought will not adversely a f fect safety because UAV Aerial Video w ill

use trained technicians to perform maintenance, alterations or preventive maintenance on the UAS

using the methods, techniques, and practices prescribed by the operating documents. Furthermore,

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 V

ision+, Phantom 3 Pr ofessional UAS will be performed by trained technicians.

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

Significantl y

, previous exemptions granted by the F AA 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 a f

fected when the technical characteristics and operating limitations of the

UAS are considered.

In consideration of UAV Aerial Video proposed operating limitations, the

operating document s, and the technical aspects of the DJI Phantom 2 V ision +, Phantom 3

Professional UAS, UAV Aerial Video submits that safety will not be adversely a f fected 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 F AA has previously granted relief specific to UAS in circumstances

simila r

, in all material respects, to those presented herein (e.g. Exemption Nos. 1 1062,

1 1063, 1 1064, 1 1065, 1 1066, 1 1067, 1 1080, 11 109, 111 10, 111 12, 11 136, 11 138, 11 150,

11 153, 11 156, 11 157, 11 158, 11 159, 11 160, 11 161).

7. The F AA May P r

escribe Any Other Conditions For Safe Operation.

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

(FMRA) and 14 C. F

.R. § 21.16 entitled Special Co nditions, UAV Aerial Video requests

that the F AA prescribe special conditions for the intended operation of the DJI Phantom 2

V ision+, Phantom 3 Professional 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. 1 13(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 safeUAV Aerial Video for Exemption Page 34

operation of the U AS for the limited purpose of conducting aerial video and photography

over certain areas of the United States 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 t he public, or otherwise pose a threat to national security; and furthe r

, 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 th e NAS.

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

§ 21.16, for operation of the DJI Phantom 2 V ision+, Phantom 3 Professional UAS, since the

airworthiness regulations of 14 C. F .R. Part 21 do not contain adequate or a ppropriate safety

standards, due to the novel or unusual design features of the aircraft. Section 21.16, entitled

Special Conditions, states the following:

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

adequate or ap propriate safety standards for an aircraft, aircraft engine, or propeller

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

propelle r

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

The special condi tions are issued in accordance with Part 1 1 of this chapter and

contain such safety standards for the aircraft, aircraft engine or propeller as the

F AA 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 F

AA

may prescribe special conditions for UAV Aerial Video’s intended operation of the DJI Phantom

2 V ision+, Phantom 3 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 Sections 61. 1 13(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).

F

. A Summary That Can Be Published In The Federal Registe r , stating: The Rules

F r om Which UAV Aerial Video Seeks Exemption:

UAV Aerial Video seeks exemption from the requirements of 14 C. F .R Sections

61. 1 13(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).UAV Aerial Video for Exemption Page 35

A Brief Description Of The Nature Of The Exemption UAV Aerial Video Seeks:

This exemption will permit UAV Aerial Video to commercially operate an

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

photography over certain areas of the United States.

G. Any Additional Information, V iews, Or Arguments A

vailable T

o Support UAV Aerial

Video Request.

This Petition is made pursuant to the F AA Modernization and R eform Act of 2012 (FMRA)

Section 333, which directs the Secretary of T ransportation to determine if certain UAS may

operate safely in the NAS. As such, UAV Aerial Video request for exemption may be

granted pursuant to the authority of FMRA Section 333 and 14 C. F .R. Part 1 1, 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 furthe r

, provides the authority f or such UAS to operate without airworthiness

certification. As discussed in detail above, UAV Aerial Video will operate the DJI Phantom 2

V ision +, Phantom 3 Professional UAS safely in the NAS, without creating a hazard to users of

the NAS, or the public, or otherwise pose a threat to national securit y

.

C O NCLUSI O N

As set forth herein, UAV Aerial Video seeks an exemption pursuant to 14 C. F .R.

§ 1 1.61 and Section 333 of the F AA Modernization and Reform Act of 2012 (FMRA),

which will permit safe opera tion of the DJI Phantom 2 V ision+, Phantom 3 Professional UAS

commerciall y

, 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 F AA

Administrator will be fulfilling the Congressional mandate of the F AA Modernization and

Reform Act of 2012, while also advancing the interests of the public, by allowing UAV

Aerial Video to safel y

, e f ficientl y

, and economically operate the DJI Phantom 2 Vision+

, Phantom

3 Professional UAS commercially within the NAS.

WHEREFORE, in accordance with the Federal A viation Regulations and the F AAUAV Aerial Video for Exemption Page 36

Modernization and Reform Act of 2012, Section 333, UAV Aerial Video respectfully

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

of 14 C. F .R Sections 61. 1 13(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 UAV Aerial Video to operate the DJI

Phantom 2 V

ision +, Phant om 3 Professional UAS commercially for the purpose of conducting

aerial video and photography of Real Estate Properties (for homeowners, realtors, home

builders, home contractors and / or home inspectors for real estate marketing and inspection of

home ex teriors) as well as filming of special events, film sets, scripted and unscripted television

sets and landscape as well as conducting power line inspection, aerial mapping, surveying and search

and rescue over certain areas of the United States.

Date d: May 20 , 2015

Respectfully submitted b y

, Chris McClintock

Chris

McClintock

UAV Aerial

Video (True Image

Productions LL C)

10716 County Road 1114

Princeton, TX 75407

T el: 214

- 697

- 7279

Email: info@uavaer ialvideo.comUAV Aerial Video for Exemption Page 37

Appendixes:

A

– DJI Phantom 2 V ision+ Specifications Data Sheet

B

– DJI Phantom 2 V ision+ Manufacture r ’ s User Manual

C

– DJI Phantom 3 Professional Specifications Data Sheet

D

– DJI Phantom 3 Manufacture r ’ s User Manual

E

– Monthly Maint enance Log

APPENDIX

– A

DJI PHAN T OM 2 VISION+ TECHNICAL SP E CIFIC A T IONS

UAV Aerial Video only utilizes safe and reliable UASs. DJI is an industry leader in small

UAS production. DJI UASs are loaded with ground breaking software enabling the user to se t

parameters which will not allow flight into controlled airspace. Parameters can also be set to

limit flight to no higher than a predetermined and set altitude as well as limit flight to a

predetermined and set distance. In addition, DJI software provides real

- time altitude and location

information to the PIC via the linked monitor (smart phone/tablet devices)

1.1 DJI Phantom 2 V

ision+

1.1.1 A ircraft

1.1.1.1 Supported Battery

– DJI 5200mAH LiPo Battery

1.1.1.2 W eight (Battery & Propellers Included)

– 2 lbs 1 1.810oz (1242g)

1.1.1.3 Hover Accuracy (Ready to Fly)

– V ertical: .8m; Horizontal: 2.5m

1.1.1.4 Max Y

aw Angular V

elocity

- 200 0 /s

1.1.1.5 Max T ilt Angel

- 35 0

1.1.1.6 Max Ascent Speed

– 6m/s

1.1.1.7 Max Descent Speed

– 2m/s

1.1.1.8 Max Flight Speed

– 15m/s (NOT RECOMMENDED)

1.1.2 Gimbal

1.1.2.1 W

orking Current

– Static: 750mA; Dynamic: 900mA

1.1.2.2 Control Accuracy

- ±0.03 0

1.1.2.3 Controllable Range

– Pitch:

- 90 0

- 0 0

1.1.2.4 Maximum Angular Speed

– Pitch: 90 0 /s

1.1.3 Camera

1.1.3.1 Operating T

emperature Range

- 32 0 F

- 104 0 F (0 0 C

- 40 0 C)

1.1.3.2 Sensor Size

– 1/2.3”

1.1.3.3 E f fective Pixels

– 14MUAV Aerial Video for Exemption Page 38 1.1.3.4 Resolution

– 4384x3288

4.1.3.5 HD V

ideo Recording

– 1080p30 & 720p

4.1.3.6 Recording Field of V iew

- 1 10 0 /85 0

1.1.4 T ransmitter

1.1.4.1 Opera ting Frequency

– 5.728GHz

– 5.85GHz

1.1.4.2 Communication Distance (unobstructed)

– FCC Compliance: 800m

1.1.4.3 Receiver Sensitivity (1%PER)

- - 93dBm

1.1.4.4 T ransmitter Power

– FCC Compliance: 100mW

1.1.4.5 W orking V oltage

– 120mA@3.7V

1.1.5 Range Extender

1.1.5.1 Operating Frequency

– 2412

- 2462MHz

1.1.5.2 Communication Distance (unobstructed)

– 500

- 700m

1.1.5.3 T ransmitter Power

– 20dBm

1.1.5.4 Power Consumption

– 2WCoastal Luxury Films Petition for Exemption Section 333 FAA APPENDIX

- B

DJI Phantom 2 Vision+ Manufacturer' s User Manual

(uploaded in a separate attachment, a 72

- page document )Coastal Luxury Films Petition for Exemption Section 333 F AA ! 38 APPENDIX

– C

DJI PHAN T OM 3 TECHNICAL SP E CIFIC A T IONS

AIRCRAFT



### W eight (Including Battery And P r opellers) 1280 g

Diagonal Size (Including P r opellers) 590 mm

Max Ascent Speed 5 m/s

Max Descent Speed 3 m/s

Hover Accuracy

• V ertical: +/

- 10cm

• Horizontal: +/

- 1m

Max Speed 16 m/s ( A TTI mode, no wind)

Max Altitude Above Sea Level 6000 m

Operating T

emperatu r e 0°C to 40°C

Gps Mode GPS/GLONASS

GIMBAL



### Cont r ollable Range Pitch

- 90° to +30°

Stabilization 3

- axis (pitch, r oll, yaw)Coastal Luxury Films Petition for Exemption Section 333 F AA ! 39 REMOTE CONTROLLER



### Operating F r equency 2.400 GHz

- 2.483 GHz

Max Distance 2000m (outdoors and unobstructed)

V ideo Output Port USB

Operating T

emperatu r e 0°C

- 40°C

Battery 6000 mAh LiPo 2S

Mobile Device Holder For tablet or phone

Receiver Sensitivity (1%Per)

- 101 dBm ±2 dBm

T ransmitter Power (Eirp)

• FCC: 20 dBm

• CE: 16 dBm

W orking V oltage 1.2 A @7.4 V

B A TTE R Y CHARGER



### V oltage 17.4 V

Rated Power Phantom 3 P r ofessional 100 WCoastal Luxury Films Petition for Exemption Section 333 F AA ! 40 INT ELLIGENT FLIGHT B A TTE R Y



### Capacity 4480 mAh

V oltage 15.2 V

Battery T

ype LiPo 4S

Energy 68 Wh

Net W eight 365 g

Max Flight T ime App r oximately 23 minutes

Operating T

emperatu r e

- 10°C to 40°C

Max Charging Power 100 WCoastal Luxury Films Petition for Exemption Section 333 F AA ! 41 APPENDIX

– D

DJI Phantom 3 Professio nal Manufacture r ’ s User M anual

(uploaded in a separate attachment, a 58

- page document )Coastal Luxury Films Petition for Exemption Section 333 F AA ! 42 APPENDIX

– E

MONTH L

Y MAINTENANCE LOG

mon t h : yea r:

UAS

# Date Issue

Discovered Date Issue

Addressed Issue Description &

Maintenance Conducted Maintenance

Performed By:

Print & Sign

Software Updates

Airframe

Engines

Propellers

Camera Gimbal

Landing Gear

V ibration

Dampening

Other:

Chris

McClintock

UAV Aerial

Video

(True Image

Productions LL C)

10716 County Road 1114

Prin ceton, TX 75407

T el: 214

- 697

- 7279

Email: info@uavaerialvideo.com