September 17,2015
Attn: U.S. DepartmentofTransportationDocket Operations WestBuilding GroundFloor, Roomw12-140 1200NewJersey Ave, SE Washington, DC 20590

RE: REVEL FILM INC. REQUEST AN EXEMPTION FROM THE REQUIREMENTS OF TITLE 14 OF THE CODE OF FEDERAL REGULATIONS SECTIONS 61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(l), 91.409(a)(l) & (a)(2), AND 91.417(a) & (b) CONCERNING COMMERCIAL OPERATION OF DJI Phantom 3 UNMANNED AIRCRAFT SYSTEMS PURSUANT TO SECTION 333 OF THEFAAMODERNIZATION AND REFORM ACT OF 2012 (PUBLIC LAW 112-95)

BrianBrennan Founder/Owner Revel film Inc. 54 Lolly Lane CentereachNY 11720 631-513-3292 Brian@revelfilm.com

1

### TABLE OF CONTENTS Page GLOSSARY OF ABBREVIATIONS

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

SUMMARY

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

INTRODUCTION AND INTERESTS OF PETITIONER.

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

BACKGROUND

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

BASIS FORPETITION

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

NAMEAND ADDRESS OF PETITIONER

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

THE SPECIFIC SECTIONS OF 14 C.F.R. FROM WHICHREVEL FILMINC. SEEKS EXEMPTION

............................................................................................................7 THEEXTENT OF RELIEF REVEL FILM INC. SEEKS AND THE REASON REVEL FILM INC SEEKS THE RELIEF

..............................................................10 THE REASONS WHY GRANTING REVEL FILMINC.'S REQUEST WOULD BEIN THE PUBLIC INTEREST

............................................................................................12 THE REASONS WHY GRANTING THE EXEMPTIONTO REVEL FILMINC. WOULD NOTADVERSELYAFFECT SAFETY.

.............................................................14 SUMMARYTHAT CANBEPUBLISHED IN THEFEDERALREGISTER

...................25 ANYADDITIONAL INFORMATION, VIEWS, ORARGUMENTS AVAILABLETO SUPPORTREVEL FILMINC.'S REQUEST

..................................................25 CONCLUSION

.....................................................................................................................25 APPENDICES

......................................................................................... 26

2AGL AOI ATC ATO AV CFR COA FAA FAR GCS GPS LOL NAS NOT AM PIC Section 333 

## so SOP UA UAS VFR VLOS VMC VTOL GLOSSARY OF ABBREVIATIONS Above GroundLevel Area ofInterest Air Traffic Control Air Traffic Organization Aerial Vehicle Code ofFederal Regulations Certificate ofAuthorization Federal AviationAdministration Federal AviationRegulation Ground Control Station Global Positioning System Loss ofLink National Airspace System Noticeto Airman PilotInCommand FAAModernization andReform Act of2012 (FMRA) Safety Observer Standard Operating Procedures UnmannedAircraft UnmannedAircraft System Visual FlightRules Visual Line ofSite Visual Meteorological Conditions Vertical Takeoffand Landing

3SUMMARY REVEL FILM INC. seeks exemption from the requirements of 14 C.F.R §§ 61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(l) & (a)(2), and 91.417(a) & (b), to operate an Unmanned Aircraft System (DJI Phantom 3) pursuant to Section 333 ofthe FAA Modernization and Reform Act of 2012 (FMRA). This exemption will permit REVEL FILM INC. to operate an Unmanned Aircraft System (UAS) for the commercial purpose ofconducting aerial video and photography ofweddings, residential and commercial real estate, construction sites, civil landscapes and events over certain areas ofthe United States. INTRODUCTION AND INTERESTS OFTHEPETITIONER REVEL FILM INC. has for the past two years provided their clients with expertise and knowledge in video and multimedia marketing, advertising, public relations and training using advanced technologies and solutions. REVEL FILM INC. has worked on hundreds of productions over the past 2 years in all types oflocations with a perfect client and employee safety record. We recently have introduced our clients withthe option ofaerial videography and photography for their productions. The objective REVEL FILM INC. and our Unmanned Aircraft System (DJI Phantom 3) aerial operations is to provide a more affordable, high-quality production system for a variety of governmental, commercial, public, and residential uses, specifically targeting

• Special eventcoverage • Real-estate marketing
• Construction sites before and after
• Appraisals
• Economic development
• Civic landmarks
My staffhas safely flown small RC electric quadcopters recreationally for approximately 2years without incident. BACKGROUND UnmannedAircraft Systems: DJI Phantom 3, UAS REVEL FILM INC. seeks an exemption to operate DJI Phantom 3 system for compensation or hire within the U.S. The DJI Phantom 3 is vertical takeoff and landing (VTOL) Unmanned Aircraft (UA) with a Ground Control Station (GCS) utilizing electronic tablet or smart phone systems. The DJI Phantom 3 has a maximum gross weight ofapproximately 2.8 lb. while having a diagonal dimension of 23.2", a maximum speed of approximately 16.4'fps and a maximum flying height of400'. The DJI Phantom 3 is equipped with four main rotors; driven by Lithium Polymerbattery poweredelectric motors. The DJI Phantom 3that will be operated by REVEL FILM INC. will be registered in accordance with 49 U.S.C. 44103, Registration ofAircraft, as well as 14 C.F.R Part 47, Aircraft

4Registration, and marked in accordance with 14 C.P.R. Part 45, Identification andRegistration Marking.

BASIS FORPETITION Petitioner, REVEL FILM INC., pursuant to the provisions ofthe Federal Aviation Regulations (14 C.P.R.§ 11.61) and the FAA Modernization and Reform Act of2012 (FMRA), Section 333, Special Rulesfor Certain Unmanned Aircraft Systems, hereby petitions the Administrator to commercially operate the DJI Phantom 3, UAS in the National Airspace System (NAS), and for
an exemption from the requirements of 14 C.F.R §§ 61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(l), 91.409(a)(l) & (a)(2), and 91.417(a) & (b). In consideration of the speed, weight, size, and limited operating area associated with the unmanned aircraft and its operation, REVEL FILM INC. operationofDJIPhantom 3UAS meets the conditions ofFMRA Section 333 and therefore, will not require an airworthiness certificate in accordance with 14 C.F.R. Part 21, SubpartH. Accordingly, REVEL FILM INC. requests relief from Sections 91.405(a), 91.407(a)(l), 91.409(a)(l) & (a)(2), and 91.417(a) & (b), as these sections set forth requirements for maintenance that only apply to aircraftwith an airworthiness certificate. REVEL FILM INC. submits thatthe requested reliefis proper since an equivalent level ofsafety will be ensured. REVEL FILM INC. will use experienced personnel or technicians to perform maintenance, alterations, or preventive maintenance on the UAS using the methods, techniques, and practices prescribed in the operating documents (i.e., Monthly Maintenance Log, and DJI Phantom 3 Instruction Manual). Furthermore, REVEL FILM INC. will document and maintain all maintenance records for the DJI Phantom 3UAS. Relieffrom certain requirements of Section 61.113(a) and (b), entitled Privatepilotprivileges and limitations: Pilot in command, is requested by REVEL FILM INC. to the extent necessary to allow a Pilot in Command (PIC) holding a private pilot or higher level certificate, as well as an airman medical certificate, and who has demonstrated, by meeting minimum flight- hour and currency requirements, that the PIC is able to safely operate the DJI Phantom UAS in a manner consistent with this exemption, including evasive and emergency maneuvers and maintaining appropriate distances from people, vessels, vehicles and structures. REVEL FILM INC. seeks relief from Section 91.7(a), entitled Civil aircraft airworthiness, because the DJI Phantom 3 UAS do not require an airworthiness certificate in accordance with 14 C.P.R. Part21, SubpartH. As such, REVEL FILMINC. submitsthatthey will ensurethatthe DJI Phantom 3 UAS is in an airworthy condition, prior to every flight, by determining that the UAS are in compliance with the operating documents (i.e., Monthly Maintenance Log, and DJI Phantom 3 InstructionManual), andthatthe aircraft are ina conditionfor safe flight. REVEL FILM INC. also seeks an exemption from the requirements ofSection 91.121, entitled Altimeter Settings, as the DJI Phantom 3 UAS will not have a typical barometric altimeter

5onboard. However, altitude information ofthe DJI Phantom 3 UAS will be provided to the PIC via Global Positioning System (GPS) equipment and radio communications telemetry data link, which downlinks from the UA to the GCS for active monitoring ofthe flight path. This altitude information, combined with REVEL FILM INC.'s operation ofthe DJI Phantom 3 UAS within visual line ofsight, at or below400 feet AGL, will ensure a level ofsafety equivalent to Section 91.121. Additionally, REVEL FILM INC. seeks an exemption from the requirements of Section 91.151(b), entitled Fuel requirementsforflight in VFR conditions. REVEL FILM INC. submits that safety will not be affected by operation ofthe DJI Phantom 3 UAS during daylight hours in visual meteorological conditions (VMC) under visual flight rules (VFR), with enough battery power to fly for a total duration ofapproximately 23 minutes. Battery power indicators are also able to show exactly how much battery power is left, as well as how much time is needed to return safely backto point oftake off. In accordance with 14 C.F.R. § 11.81, REVEL FILM INC. provides the following information in support ofits petition for exemption:

A. Name And Address OfThe Petitioner. The name and address ofthe Petitioner andpointofcontactis: BrianBrennan Founder/Owner Revel film Inc. 54 Lolly Lane CentereachNY 11720 631-513-3292 Brian@revelfilm.com

B. The Specific Sections Of14 C.F.R. From Which REVEL FILM INC. Seeks Exemption.

61. REVEL FILM INC. Seeks ExemptionFrom The Requirements OfSection 61.113(a) And (b). Section 61.113, entitled Private pilot privileges and limitations: Pilot in command, subsections (a) and (b) prescribethe following, inrelevantpart: (a) No person who holds a private pilot certificate may act as a pilot in command (PIC) ofan aircraft that is carrying passengers or property for compensation or hire;
normay thatperson, for compensationorhire, act as PIC ofan aircraft. (b) A private pilot may, for compensation or hire, act as PIC of an aircraft in connectionwith any business oremploymentif- (1) The flight is only incidentaltothatbusiness oremployment; and (2) The aircraft does notcarry passengers orproperty for compensationorhire. 2.REVEL FILMINC. Seeks ExemptionFrom The Requirements OfSection91.7(a). Section 91.7, entitled Civilaircraftairworthiness, subsection (a), statesthe following: (a) Nopersonmay operate a civil aircraftunless it is in anairworthy condition. 3. REVEL FILM INC. Seeks ExemptionFrom The Requirements OfSection91.121. Section 91.121, entitledAltimeter settings, subsection (a), statesthe following, inpart: (a) Eachpersonoperating an aircraft shall maintain the cruising altitude orflight level ofthat 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 1 00 nautical miles ofthe aircraft; (ii) Ifthere is no station within the area prescribed in paragraph (a)(l)(i) of this section, the current reported altimeter setting ofan appropriate available station; or

(iii) In the case ofan aircraft not equipped with a radio, the elevation ofthe departure airport or an appropriate altimeter setting available before departure.

4.REVEL FILMINC. Seeks ExemptionFrom The Requirements OfSection91.15l(b). Section91.151, entitledFuel requirementsforflight in VFR conditions, subsection (b), states the following:

7(b) No person may begin aflight in a rotorcraft under VFR conditions unless (considering windand forecast weather conditions) there is enoughfuel tofly to the firstpoint of intended landing and, assuming normal cruising speed, tofly after that for at least20 minutes. 5.REVEL FILM INC. Seeks ExemptionFrom The Requirement OfSection91.405(a). Section 91.405, entitledMaintenance required, subsection (a), states the following: Each
owneroroperator ofanaircraft- (a) Shall have that aircraft inspected as prescribed in subpart E ofthis part and shall between required inspections, except as provided in paragraph (c) of this section, have discrepancies repaired as prescribed inpart4 3 ofthis chapter[.] 6.REVEL FILM INC. Seeks ExemptionFrom The Requirements OfSection 91.407(a)(l) Section 91.407, entitled Operation after maintenance, preventive maintenance, rebuilding, oralteration, subsection (a)(1), statesthe following: (a) No person may operate any aircraft that has undergone maintenance, preventive maintenance, rebuilding, or alterationunless-- (1) Ithas been approved for returnto service by a person authorized under§ 43.7 ofthis chapter[.] 7. REVEL FILM INC. Seeks Exemption From The Requirements OfSections 91.409(a)(l) And 91.409(a)(2). Section 91.409, entitledInspections, subsection (a), states the following: (a) Except as provided in paragraph (c) ofthis section, no person may operate an aircraftunless, withinthe preceding 12 calendarmonths, ithashad-- (1) An annual inspection in accordance with part 43 ofthis chapter and has been approved for returnto service by apersonauthorizedby§ 43.7 ofthis chapter; or (2) An inspection for the issuance of an airworthiness certificate in accordance withpart21 ofthis chapter.

8. REVEL FILM INC. Seeks Exemption From The Requirements Of Sections 91.417(a) And91.417(b). Section 91.417, entitled Maintenance records, subsections (a) and (b), state the following: (a) Except for work performed in accordance with §§ 91.411 and 91.413, each registered owner oroperator shall keep the following records for the periods specified inparagraph (b) ofthis section:

8(1) Records of the maintenance, preventive maintenance, and alteration and records of the 100-hour, annual, progressive, and other required or approved inspections, as appropriate, for each aircraft (including the airframe) and each engine, propeller, rotor, and appliance ofan aircraft. The records mustinclude-- (i) A description (or reference to data acceptable to the Administrator) ofthe workperformed; and (ii) The date ofcompletionofthe workperformed; and (iii) The signature, and certificate number ofthe person approving the aircraft for returnto service. (2) Records containingthe following information: (i) The total time in service ofthe airframe, each engine, each propeller, and eachrotor.

(ii) The current status oflife-limited parts ofeach airframe, engine, propeller, rotor, and appliance.

(iii) The time since last overhaul ofall items installed on the aircraft which
are required to be overhauled ona specifiedtime basis. (iv) The current inspection status ofthe aircraft, including the time since the last inspection required by the inspection program under which the aircraft and its appliances are maintained. (v) The current status ofapplicable 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 whenthe next actionisrequired.

(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 retain the following records for the periods prescribed: (1) The records specified inparagraph (a)(1) ofthis section shall be retained until the work is repeated or superseded by other work or for 1 year after the work is performed. (2) The records specified in paragraph (a)(2) ofthis section shall be retained and transferred withthe aircraft atthe timethe aircraftis sold.

9(3) A list ofdefects furnished to a registered owner or operator under§ 43.11 of this chapter shall be retained until the defects are repaired and the aircraft is approvedfor returnto service.

C. The Extent OfReliefREVEL FILM INC. Seeks And The Reason REVEL FILM INC. SeeksTheRelief. 1.Extent OfReliefREVEL FILM INC. Seeks And The Reason REVEL FILM INC. Seeks ReliefFromSection61.113(a) And (b). Relief from Section 61.113(a) and (b) entitled Privatepilotprivileges and limitations: Pilot in command, is requested to the extent necessary to allow a PIC holding a private pilot or higher level certificate, as well as a current and valid airman medical certificate, and who has met certain flight-hour and currency requirements, to conductthe proposedUAS flight operations for compensationorhire. This relief is requested since the limitations set forth in Section 61.113(a) and (b) state that a private pilot may, for compensation or hire, act as PIC of an aircraft in connection with any business or employment if: (1) The flight is only incidental to that business or employment; and (2) The aircraft does notcarry passengers orproperty for compensationorhire. As set forth more fully below, REVEL FILMINC. submits that anequivalent level ofsafety will be maintained because no PIC will be allowed to operate the DJI Phantom 3 UAS unless that PIC has met certain flight-hour and currency requirements, demonstrating thatthe PIC is able to safely operate either the DJI Phantom 3 UAS in a manner consistent with the operations specifications as described in this exemption, including evasive and emergency maneuvers, as well as maintaining appropriate distances from people, vessels, vehicles and structures. Further, REVEL FILM INC. submits that all flights ofthe DJI Phantom 3 UAS, conducted by the PIC pursuant to the grant ofthis Petition: (1) will be incidental to REVEL FILM INC.'s business; and (2) will not carry passengers orproperty for compensationorhire.

2.Extent OfReliefREVEL FILM INC. Seeks And The Reason REVEL FILM INC. Seeks ReliefFromSection91.7(a). Relief from Section 91.7(a) entitled Civil aircraft airworthiness, is requested to the extent requiredto allow REVEL FILMINC. to determine thatthe DJI Phantom 3 UAS are in airworthy condition prior to every flight by ensuring that the UAS is in compliance with the operating documents (i.e., REVEL FILM INC. Aerial Operations Manual, Monthly Maintenance Log, and DJI Phantom 3 InstructionManual). REVEL FILMINC. seeks the requested reliefbecause the DJI Phantom 3 UAS do notrequire an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H. Therefore, REVEL FILM INC. will ensure that the DJI Phantom 3 UAS are in airworthy condition based upon its

10

### compliance with the operating documents (i.e., Monthly Maintenance Log, and Dll Phantom 3) prior to every flight, and further, determine that the aircraft are in condition for safe flight, as stated inthe conditions and limitationsbelow.

3.Extent OfReliefREVEL FILM INC. Seeks AndThe Reason REVEL FILM INC. Seeks ReliefFromSection91.121. Relief from Section 91.121, entitled Altimeter settings, may be required to allow flight operations of the DJI Phantom 3 UAS, which utilize a barometric pressure sensor, GPS equipment, and a radio communications telemetry data link to downlink altitude information from the UA to the PIC at the ground control station (GCS). Since the FAA requires that any altitude information concerning UAS operations be reported to air traffic control (ATC) in feet above ground level (AGL), REVEL FILM INC. seeks the requested relief because the DJI Phantom 3 UA's altimeter may be set on the ground to zero feet AGL, rather than the local barometricpressure orfield altitude, before eachflight. Considering the limited altitude ofthe proposed operations, relieffrom 14 CFR 91.121 is sought to the extentnecessary to comply withthe applicable conditions and limitations stated below. As more fully set forth herein, an equivalent level of safety will be maintained since the Dll Phantom 3 UAS are equipped with a barometric pressure sensor and GPS equipment, which automatically ensures that a ground level pressure setting will be established prior to each flight, and providesthe PIC with altitude information ofthe UA onthe heads-up display ofthe GCS.

4. Extent OfReliefREVEL FILM INC. Seeks AndThe Reason REVEL FILM INC. Seeks ReliefFromSection91.15l(b). Relief from Section 91.151(b) entitled Fuel requirements for flight in VFR conditions, is requested to the extent required to allow flights ofthe battery powered Dn Phantom 3 UAS during daylight hours in visual meteorological conditions (VMC), under visual flight rules (VFR), for a total duration of23 minutes. REVEL FILM INC. seeks the requested reliefbecause without an exemption from Section 91.151(b), the flight time duration ofthe battery powered DJI Phantom 3 UAS will severely constrain the practicality of any aerial video or still photo flight operationsthatREVEL FILM INC. proposes to conductpursuantto this Petition. Significantly, as set forth below, the technical specifications ofthe DJI Phantom 3 UAS, the Dn Phantom 3 operating documents, and REVEL FILM INC.'s proposed operating limitations, ensure that REVEL FILM INC. will safely operate the battery powered DJI Phantom 3 UAS during daylight hours in visual meteorological conditions (VMC), under visual flight rules (VFR), with enoughbatterypowerto fly for atotal duration of23 minutes.

5. Extent OfReliefREVEL FILM INC. Seeks AndThe Reason REVEL FILM INC. Seeks ReliefFromSections91.405(a),91.407(a)(l),91.409(a)(l) & 

### (a)(2),And91.417(a) & 

### (b).

11Since Sections 91.405(a), 91.407(a)(l), 91.409(a)(l) & (a)(2), and 91.417(a) & (b) only apply to aircraft with an airworthiness certificate, REVEL FILM INC. requests relieffrom these Sections becausethe DJI Phantom 3UAS do notrequire airworthiness certificates. As set forth more fully below, the DJI Phantom 3 UAS meetthe conditions ofFMRA Section 333 for operationwithout
an airworthiness certificate. Accordingly, REVEL FILM INC. will use trained technicians to perform maintenance, alterations, or preventive maintenance on the UAS using the methods, techniques, and practices prescribed in the UAS operating documents (i.e., REVEL FILM INC. Aerial Operations Manual, Monthly Maintenance Log, and DJI Phantom 3 Instruction Manual). Furthermore, REVEL FILM INC. will document and maintain all maintenance records for the DJI Phantom 3UAS.

D. The Reasons Why Granting REVEL FILM INC. Request Would Be In The Public Interest; That

### Is,How ItWould Benefit The Public As A Whole. Granting the present Petition will further the public interest by allowing REVEL FILM INC. to safely, efficiently, and economically perform aerial video and photography ofconstruction sites, real estate, events and civic landscape overcertain areas ofthe United States. Additionally, use of the DJI Phantom 3 UAS will decrease congestion of the NAS, reduce pollution, and provide significant benefits to the economy. Notably, the benefits of REVEL FILMINC.'sproposed operation ofthe DJI Phantom 3UAS will be realized without implicating



### . 

## . any pnvacy Issues.

1. The Public Will BenefitFrom Decreased Congestion OfThe NAS. The DJI Phantom 3 UAS are battery powered and serve as a safe, efficient, and economical alternative to the manned aircraft traditionally utilized to obtain aerial imagery. By reducing the amount ofmanned aircraft needed to perform aerial acquisitions, an exemption allowing the use ofa DJI Phantom 3 UAS would reduce the amount ofmanned aircraft in the NAS, reduce noise and airpollution, as well as increase the safety oflife andproperty inthe air and onthe 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 3 UAS do not require an airport to takeoff or land. Likewise, a reduction of manned aircraft conducting aerial video and photography missions would result in fewer aircraft that must be handledby airtraffic control during the ground, takeoff, departure, arrival, and landing phases of flight operations.

2. The Public Will BenefitFrom The Safety AndEfficiency OfThe DJI Phantom 3 UAS.

12Conducting aerial acquisitions with the DJI Phantom 3 UAS, instead ofmanned aircraft, will greatly benefit the public by drastically reducing the levels ofair and noise pollution generated during traditional aerial video and still photography flight operations. By using battery power and electric motors, the DJI Phantom 3 UAS produce no air pollution, and is the most viable environmentally conscious alternative to the cabin class, six cylinder internal combustion engine aircraft that are typically utilized for aerial video and photography, while burning approximately 20-30 gallons per hour of leaded aviation fuel. The DJI Phantom 3 UAS, while reducing the carbon footprint ofaerial acquisitions, also eliminates noise pollution, as the UAS are propelled by batterypowered electric motors, ratherthan an internal combustionengine. By using the DJI Phantom 3 UAS to perform aerial acquisitions, the substantial risk to life and property inthe air and onthe ground, which is usually associated withtraditional manned aircraft flight operations, will be substantially reduced or completely eliminated. Aside from the lack of flight crew members located onboard the aircraft, the DJI Phantom 3 UAS (weighing approximately 2.8 pounds at their maximum gross weight with diagonal dimension of 23.2 inches, and with no fuel on board), has less physical potential for collateral damage to life and property on the ground, and in the air, compared to the manned aircraft that typically conduct similar operations (weighing approximately 6,000 pounds with a wingspan ofapproximately 42 feet, alength of34 feet, and a fuel capacity of 180 gallons). 3. PerformingAerialVideo andPhotography OperationsWithTheDJIPhantom3 UAS Will BenefitTheEconomy. In addition to being safe and efficient, the DJI Phantom 3 UAS are also an economical alternative to using manned aircraft to conduct similar aerial operations. As such, operation of the DJI Phantom 3 UAS will allow United States based companies, like REVEL FILM INC., to remain competitive and contribute to growth ofthe U.S. economy. Specifically, with the rising cost of aviation fuel and the Environmental Protection Agency ("EPA") regulatory actions phasing out leaded aviation fuels, U.S. owned and operated companies must adopt new and alternative technology in order to remain competitive. Operating the battery powered DJI Phantom 3 UAS is one such technology that not only allows companies greater operational flexibility compared to manned aircraft, but provides such flexibility without the high operational costofatraditional manned aircraft. By operating the DJI Phantom 3 UAS, companies such as REVEL FILM INC., can remain competitive and profitable, and therefore, provide greater job stability to employees and contractors, which will ultimately contribute to growth ofthe U.S. economy. Improved financial performance ofU.S. companies, through commercial use ofthe DJI Phantom 3 UAS, provides a stable workforce that increases consumer spending; improves local, state, and federal tax revenues; and allows companies to invest in research and development in order to remain competitive bothinthe United States and abroad.

4.ThereAreNo PrivacyIssues.

13Similar to the manned aerial acquisition flight operations that have been conducted for decades, REVEL FILM INC.'s proposed operation ofthe DJI Phantom 3 UAS will not implicate any privacy issues. Specifically, the DJI Phantom 3 UAS will be operated only in compliance with operating documents (i.e., REVEL FILM INC. Aerial Operations Manual, Monthly Maintenance Log, and DJI Phantom 3 InstructionManual) whichrequires property owner involvement as well
as local law enforcement notification, and in accordance with the Federal Aviation Regulations, includingthe minimum altitude requirements of 14 C.F.R. § 91.119. 

### E. The Reasons Why Granting The Exemption Would Not Adversely Affect Safety, Or How The Exemption Would Provide A Level OfSafety At Least Equal To That Provided By TheRule FromWhich REVEL FILMINC.Seeks Exemption. 1. 

### Reasons Why The DJI Phantom 3 UAS Meet The Conditions Of The FAA Modernization andReformActof2012 (FMRA) Section333. In consideration of the size, weight, speed, and limited operating area associated with the unmanned aircraft and its operation, REVEL FILM INC.'s operation ofthe DJI Phantom 3 UAS meet the conditions ofFMRA Section 333, and will not require an airworthiness certificate in accordance with 14 C.F.R. Part 21, SubpartH. Section 333 provides authority for a UAS to operate without airworthiness certification and sets forth requirements for considering whether a UAS will create a hazardto users ofthe NAS orthe public, or otherwise pose a threatto national security. Specifically, FMRA Section 333 states the following, inpart: (a) In General.--Notwithstanding any other requirement ofthis subtitle, and not later than 180 days after the date ofenactment ofthis Act, the Secretary ofTransportation shall determine 

### if certain unmanned aircraft systems may operate safely in the national airspace system before completion ofthe plan and rulemaking required by section 332 of thisActorthe guidance requiredby section334 of thisAct. (b) Assessment ofUnmanned Aircraft Systems.--In making the determination under subsection (a), the Secretary shalldetermine, ata minimum-- (1) which types ofunmannedaircraft systems, 

### if any, as a result oftheir size, weight, speed, operational capability, proximity to airports and populated areas, andoperation within visual line of sightdo notcreate a hazardto users ofthe national airspace system or the public or pose a threat to national security; and (2) whether a certificate of waiver, certificate of authorization, or airworthiness certification under section 44704 oftitle 49, United States Code, is requiredfor the operation ofunmanned aircraft systems identified underparagraph (1). (c) Requirementsfor Safe Operation.--Ifthe Secretary determines under this section that certain unmanned aircraft systems may operate safely in the national airspace

14system, the Secretary shall establish requirements for the safe operation ofsuch aircraftsystems in the nationalairspace system. In seeking this exemption, REVEL FILMINC. submits thatthe DJI Phantom 3 UAS can operate safely inthe NAS pursuant to FMRA Section 333, as demonstrated by: (a) the characteristics of the DJI Phantom 3 UAS; (b) the pilot certification requirement; and (c) the specific operating limitations.



### a.TheSpecifications OfTheDJIPhantom 3 UAS DemonstrateItsSafe Characteristics. The DJI Phantom 3 UAS does not create a hazardto users ofthe NAS orthe public, orotherwise pose a threatto national security considering its size, weight, speed, and operational capability. 

### i. TechnicalSpecifications OfTheDJIPhantom 3 UAS. The technical specifications ofthe DJI Phantom 3 UAS are set forth by the DJI Phantom 3 User Manual, attachedhereto as AppendixA. 

### ii.TheDJIPhantom3 UAS GlobalPositioningModes EnableTheUAS To Remain WithinADefinedOperationalArea. The DJI Phantom 3 UAS may be operated inbothmanual and global positioning flight modes. A complete description ofthe flight andnavigational modes ofthe DJI Phantom 3 UAS is provided atpages 11 ofthe DJI Phantom 3 UserManual attachedhereto as AppendixA. 

### iii.TheDJIPhantom 3 UAS Are DesignedForAutomatic ReturnToHome Point OrHoverInTheEventOfLoss OfThe ControlLinkOrNavigation. When the Control Link is lost, the DJI Phantom 3 UAS will remain stationary, in flight, for 3 seconds ormore. If, after 3 seconds, the DJI Phantom 3 UAS does notreacquire control link data from the GCS, the UAS will assume thatthe Control Link is lost andthe will returnto the home position (i.e., failsafe mode) via GPS, and will descendto the takeoffpositionand shutdown. A complete description ofthe Failsafe Functions ofthe DJI Phantom 3 UAS are set forth at pages 12 through 14 ofthe DJI Phantom 3 UserManual, attachedhereto as AppendixA. 

### iv. TheDJIPhantom3 GCS AndIts Operation. A complete description ofthe operation and specifications ofthe DJI Phantom 3 GCS and flight control software is provided at pages 23 through 29 ofthe DJI Phantom 3 User Manual. DJI Phantom 3 UserManual is attachedhereto as AppendixA. 

### b.FlightOperationsOfDJIPhantom 3 UAS Is LimitedToTheLine OfSightOfA CertificatedPilotin CommandWithA Safety Observer. REVEL FILM INC. video production staffwill be the only persons to act as a pilot in command (PIC) ofthe DJI Phantom 3 UAS. Additionally, a safety observer will assist him at all times during flight time.

15c.Flights OfDJI Phantom 3 UAS Will Be ConductedPursuantToSpecific Operating Limitations. In seeking this exemption, REVEL FILM INC. proposesto commercially operate DJI Phantom 3 UAS for the special purpose ofconducting aerial video and photography overcertain areas of United States, pursuantto the following specific operating limitations. 1. Operations authorized by this grant ofexemption will be limited to the following aircraft described in the operating documents, rotorcraft UAS weighing less than 55 pounds maximum gross weight: DJI Phantom 3 Unmanned Aircraft Systems. Proposed operations ofany other aircraft will require a new petition or a petition to amend this grant.

2. UAS operations under this exemption will be limited to conducting operations for the purpose ofaerial video andphotography. 3. The UAS may notbe flown at an indicated airspeed exceeding 20 knots. 4. The UA mustbe operated at an altitude ofno more than400 feet above ground level (AGL), as indicated by the procedures specified in the operating documents unless a special request is made and approved by ATC. All altitudes reported to ATC must be in feet AGL. 5. The UAS must be operated within visual line of sight (VLOS) ofthe PIC at all times. This requires the PIC to be able to use human vision unaided by any device other than corrective lenses, as specified on the PIC's FAA-issued airman medical certificate. 6. The use of first person view (FPV) by the PIC or 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 VLOS capability. 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 duration ofthe flight. The PIC must ensure that the SO can perform the functions prescribed in the operating documents. 8. The SO must not perform any other duties beyond assisting the PIC with seeing and avoiding other air traffic and other ground based obstacles/obstructions and is not permittedto operate the cameraorother 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

16exemption and the procedures outlined in the operating documents, the conditions and limitations contained in the grant ofexemption take precedence and must be followed. Otherwise, the operator must follow the procedures as outlined in its operating documents. The operator may update or revise its operating documents. It is the operator's responsibility to track such revisions and present updated and revised documents to the Administrator upon request. The operator must also present updated and revised documents if it petitions for extension or amendment to the grant of exemption. If the operator determines that any update or revision would affect the basis upon which the FAA granted the exemption, then the operator must petition for amendment to its grant ofexemption. The FAA's UAS Integration Office (AFS-80) may be contacted if questions arise regarding updates or revisions to the operating documents.

10. Priorto each flight the PIC must inspectthe UAS to ensure that it is in a condition for safe flight. Ifthe inspection reveals a condition that affects the safe operation of the UAS, the aircraft is prohibited from operating until the necessary maintenance has been performed and the UAS is found to be in a condition for safe flight. The Ground Control Station must be included in the preflight inspection. All maintenance and alterations mustbe properly documented in the aircraftrecords.

11. Any UAS that has undergone maintenance or alterations that affect the UAS operation or flight characteristics, e.g. replacement of a flight critical component, must undergo a functional test flight. The PIC who conducts the functional test flight mustmake an entry in the aircraftrecords. 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 ofthe operating documents. 13. The operator must follow the UAS manufacturer's aircraft/component, maintenance, overhaul, replacement, inspection, and life limitrequirements. 14. The operator must carry out its maintenance, inspections, and record keeping requirements, in accordance with the operating documents. Maintenance, inspection, alterations, and status ofreplacement/overhaul component parts must be noted in the aircraft records, including total time in service, description of work accomplished, and the signature ofthe authorizedpersonreturning the UAS to service. 15. Each UAS operated under this exemption must comply with all manufacturer Safety Bulletins. 16. The authorized person must make an entry in the aircraft record ofthe corrective action taken against discrepancies discoveredbetweeninspections. 17. The PIC mustpossess at least a private pilot certificate and at least a currentthirdclass medical certificate.

1718. The operator may not permit any PIC to operate unless the PIC meets the operator's qualification criteria and demonstrates the ability to safely operate the UAS in a manner consistentwithhowthe UAS will be operatedunder the exemption, including evasive and emergency maneuvers and maintaining appropriate distances from persons, vessels, vehicles and structures. PIC qualification flight hours must be logged in a manner consistent with 14 C.F.R. § 61.51(b). Flights for the purposes of training the operator's PICs are permitted under the terms of the exemption. However, training operations may only be conducted during dedicated training sessions. During training, proficiency, and experience-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.P.R.§ 91.119. 19. UAS operationsmay notbe conducted during night, as defined in 14 C.P.R. § 1.1. All operations must be conducted under visual meteorological conditions (VMC). If flight at night is required, a special request will be made at the FAA office closest to proposed area ofoperations. Flights under special visual flight rules (SVFR) are not authorized. 20. The UA may not operate within 5 nautical miles ofan airport reference point as denoted on a current FAA-published aeronautical chart unless a letter ofagreement with that airport's management is obtained, and the operation is conducted in accordance with a NOTAM as required by the operator's COA. The letter of agreement withthe airport management must be made available to the Administrator uponrequest. 21. The UA may not be operated less than 500 feet below or less than 2,000 feet horizontally from a cloud orwhen visibility is less than 3 statutemiles from the PIC. 22. Ifthe UA loses communications or loses its GPS signal, it must return to a predetermined location within the planned operating area and land or be recovered in accordance withthe operating documents. 23. The PIC must abortthe flight inthe eventofunpredictedobstacles or emergencies in accordance withthe 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 landingpointand landthe UA with25% batterypowerremaining. 25. The operator must obtain an Air Traffic Organization (ATO) issued Certificate of Waiver orAuthorization (COA) priorto conducting any operations under the grant of exemption. This COA will also require the operator to request a Notice to Airman (NOTAM) not more than 72 hours in advance, but not less than 48 hours prior to the operation. All operations shall be conducted in accordance with airspace requirements

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### in the ATO issued COA including class of airspace, altitude level and potential transponderrequirements. 26. All aircraft operated in accordance withthe exemptionmustbe identifiedby serial number, registered in accordance with 14 C.F.R. part 47, and have identification (N

### Number) markings in accordance with 14 C.F.R. part 45, Subpart C. Markings must be as large as practicable. 27. Before conducting operations, the radio frequency spectrum used for operation and control ofthe UA must comply with the Federal Communications Commission (FCC) orother 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 ofthe UAS any time the UAS is operating. These documents must be made available to the Administrator or any law enforcementofficial uponrequest. 29. The UA must remain clear and yield the right of way to all manned aviation operations and activities at all times. 30. The UAS may notbe operatedby the PIC from any moving device or vehicle. 31. Flight operations must be conducted at least 500 feet from all nonparticipating persons (persons other than the PIC, SO, operator trainees or essential persons), vessels, vehicles, and structures unless:

a. Barriers or structures are present that sufficiently protect nonparticipating persons from the UA and/or debris in the event ofan accident. The operator must ensure that nonparticipating persons remain under such protection. If a situation arises where nonparticipating persons leave such protection and are within 500 feet ofthe UA, flight operations must cease immediately and/or; b. The aircraft is operated near vessels, vehicles or structures where the owner/controller ofsuch vessels, vehicles or structures has granted permission and the PIC has made a safety assessment ofthe risk of operating closer to those objects and determined thatit does notpresent an undue hazard, and;

c. Operations nearer to the PIC, SO, operator trainees or essential persons do notpresent an undue hazardto those personsper§ 91.119(a). 32. All operations shall be conducted over private or controlled-access property with permission from the land owner/controller or authorized representative. Permission from land owner/controller or authorized representative will be obtained for each flight to be conducted. 33. Any incident, accident, or flight operation that transgresses the lateral or vertical boundaries ofthe operational area as defined by the applicable COA must be reported to the FAA's UAS Integration Office (AFS-80) within 24 hours. Accidents must be

19reported to the National Transportation Safety Board (NTSB) per instructions contained on the NTSB Web site: www.ntsb.gov.

2. Reasons Why An Exemption From The Requirements Of Section 61.113(a) And (b) Would Not Adversely Affect Safety. REVEL FILM INC. submits that the equivalent level ofsafety established by Section 61.113(a) and (b) will be maintained because no PIC will be allowed to operate the DJI Phantom 3 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 3 UAS in a manner consistent with the exemption, including evasive and emergency maneuvers and maintaining appropriate distances from people, vessels, vehicles and structures. Considering REVEL FILM INC.'s proposed area ofoperations, and the operating limitations set forth-above; the parallel nature ofprivate pilot aeronautical knowledge requirements to those of commercial pilot requirements (See Exemption No. 11062); and the airmanship skills necessary to safely operate the DJI Phantom 3 UAS, REVEL FILM INC. submits that the additional manned airmanship experience of a commercially certificated pilot would not correlate to the airmanship skills necessary for REVEL FILM INC.'s specific proposed flight operations. The FAA has previously granted relief from Section 61.113(a) and (b) specific to UAS, in circumstances similar, in all material respects, to those presented herein (e.g. Exemption Nos. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 11112, 11136, 11138, 11150, 11153, 11156, 11158, 11159, 11160, 11161). The REVEL FILM INC. will not allow any PIC to operate the DJI Phantom 3 UAS unless that PIC has demonstrated, by meeting minimum flight-hour requirements orthe DJI Phantom 3UAS training and currency requirements, that the PIC is able to safely operate the DJI Phantom 3UAS in a manner consistent with this exemption, including evasive and emergency maneuvers and maintaining appropriate distances from people, vessels, vehicles and structures. Specifically, the PIC musthave accumulated and logged, in a manner consistentwith 14 C.F.R. § 61.51(b), 25 hours oftotal time as a UAS rotorcraft pilot (with a minimum of5 hours ofthose hours as a UAS pilot operating the same make and model ofUASto be used for operations under the exemption). In addition to the hour requirements, the PIC must accomplish 3 takeoffs and landings inthe preceding 90 days (for currency purposes). As in Exemption Nos. 11062, 11138, and 11153, prior documented flight experience that was obtained in compliance with applicable regulations will ensure an equivalent level of safety during REVEL FILM INC.'s proposed operations. The Administrator has held that prior documented flight experience that was obtained in compliance with applicable regulations would ensure safe operations, stating as follows: In Exemption No. 11062, the FAA required that prior to conducting operations for the purpose ofmotionpicture filming (or similar operations), the PIC must have accumulated

20and logged, in a manner consistent with 14 CFR 61.51(b), 25 hours oftotal time as a UAS rotorcraft pilot including at least 10 hours logged as a UAS pilot with a multi-rotor UAS. Prior to operations under Exemption No. 11062, the PIC must also have accumulated and logged a minimum of5 hours as a UAS pilot operating the same make and model ofUAS to be used for operations under the exemption. For clarification, the FAA considersthese minimumhourrequirements to be inclusive rather than additive; i.e. 5hours make and model time may be included inthe 10 hours ofmulti-rotortime and the 10 hours may be included in the total25 hours ofUAS rotorcraft time. In addition to the hour requirements, the PIC must accomplish 3 takeoffs and landings in the preceding 90 days (for currency purposes). The FAA finds that at a minimum, the flight-hour requirements inExemptionNo. 11062 are appropriate to practice andbuildproficiency in the skills necessary to safely conduct the petitioner's proposed operations. The FAA also finds that prior documented flight experience that was obtained in compliance with applicable regulations would satisfy this requirement. Training, proficiency, and experience-building flights can also be conducted under the grant of exemption to accomplishthe required flighttime. During training, proficiency, and experience-building flights the PIC is required to operate the UA with appropriate distances in accordance with 14 C.F.R91.119.

ExemptionNo. 11138 atpage 15. Accordingly, REVEL FILM INC. will ensure safe operations by not allowing any PIC to operate the DJI Phantom 3 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 3UAS in a manner consistent with the exemption, including evasive and emergency maneuvers and maintaining appropriate distances from people, vessels, vehicles and structures.



### 3. Reasons Why An Exemption From The Requirements Of Section 91.7(a) Would Not AdverselyAffect Safety. The equivalent level ofsafety established by Section 91.7(a) will be maintained because prior to every flight, REVEL FILM INC. will ensure that the DJI Phantom 3 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. Additionally, the FAA has previously granted relief from Section 91.7(a) specific to UAS, in circumstances similar, in all material respects, to those presented herein (e.g. Exemption Nos. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 11112, 11136, 11138, 11150, 11153, 11156, 11157, 11158, 11159, 11160, 11161).

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### 4. Reasons Why An Exemption From The Requirements Of Section 91.121 Would Not Adversely Affect Safety. The equivalent level of safety established by Section 91.121 will be maintained because the altitude information ofthe DJI Phantom 3 UAS 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 ofthe flight path and altitude. This altitude information, combined with The REVEL FILM INC.'s operation ofthe DJI Phantom 3 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 information will be generated by GPS equipment installed onboard the aircraft. Prior to each flight, a zero altitude initiationpointis automatically established by the UAS at ground level. The FAA has previously granted relieffrom Section 91.121 specific to UAS, in circumstances similar, in all material respects, to those presented herein (e.g. Exemption Nos. 11062, 11063, 11064,11065,11066,11067,11080,11109,11112,11136,11138,11150,11153,11156,11157, 11158,11159,11160, 11161).



### 5. Reasons Why An Exemption From The Requirements OfSection 91.151(b) Would Not Adversely Affect Safety. A grant ofthis 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 specifications ofthe DJI Phantom 3 UAS; (2) the limitations on the proposed flight operations; and (3) the location of the proposed flight operations. Accordingly, The REVEL FILM INC. will ensure that it will safely operate the battery powered DJI Phantom 3 UAS during daylight hours in VFR conditions, with enough battery powerto fly for a total duration of23 minutes. Here, as in Exemption No. 11109, the technical specifications ofthe DJI Phantom 3 UAS; the limitations on the proposed flight operations; and the location ofthe proposed operations, will
ensure an equivalent level of safety established by 14 C.F.R. Section 91.151(b). Furthermore, safety will be ensured as the DJI Phantom 3 UAS provide audible andvisual warnings to the PIC at the GCS when the UAS experiences low battery voltage, the first warning occurring at approximately 33% remaining battery power, and again at approximately 10% remaining battery power. At the critically low battery level, the DJI Phantom 3 UAS will descend and land automatically. Significantly, previous exemptions granted by the FAA concerning Section 91.151 establish that safety is not adversely affected whenthe technical characteristics and operating limitations ofthe UAS are considered. Relief has been granted for manned aircraft to operate at less than the minimums prescribed in Section 91.151, including Exemption Nos. 2689, 5745, and 10650. Moreover, the FAA has previously granted relief from Section 91.151 specific to UAS, in circumstances similar, in all material respects, to those presented herein (e.g. Exemption Nos. 8811, 10808, 10673, 11042, 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 11136,11138,11150,11153,11156,11157,11158,11159,11160, 11161).

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### 6. Reasons Why An Exemption From The Requirements Of Sections 91.405(a), 91.407(a)(l), 91.409(a)(l) & 

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

### (b) Would Not Adversely Affect Safety. In seeking this exemption, REVEL FILM INC. submits that the equivalent level ofsafety with regard to the regulatory maintenance and alteration requirements established by Sections 91.405(a), 91.407(a)(l), 91.409(a)(l) & (a)(2), and 91.417(a) & (b) will be met because The REVEL FILM INC. 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. REVEL FILM INC. Aerial Operations Manual, Monthly Maintenance Log, and DJI Phantom 3 Instruction Manual). Furthermore, REVEL FILM INC. will document and maintain all maintenance records for the DJI Phantom 3UAS. Since the DJI Phantom 3 UAS will be inspected as prescribed by the operating documents, REVEL FILM INC. will maintain the equivalent level of safety established by Sections 91.405(a), 91.409(a)(l), and 91.409(a)(2). A copy of the DJI Phantom 3 User Manuals are attached hereto as Appendix A and B; a copy ofthe DJI Phantom 3 UAS Maintenance LOG is attachedhereto as Appendix C. Likewise, the exemption sought will not adversely affect safety because REVEL FILM INC. will
use trained technicians to perform maintenance, alterations or preventive maintenance on the UAS using the methods, techniques, andpractices prescribedby the operating documents. Furthermore, the exemption sought would maintain an equivalent level ofsafety established by Sections 91.407, 91.417(a) and 91.417(b), because all maintenance ofthe DJI Phantom 3 UAS will be performed by trained technicians. Maintenance will be documented and maintained utilizing the monthly maintenance log. Significantly, previous exemptions granted by the FAA concerning Sections 91.405(a), 91.407(a)(l), 91.409(a)(l) & (a)(2), and 91.417(a) & (b) establish that safety is not adversely affected whenthe technical characteristics and operating limitations ofthe UAS are considered. In consideration of The REVEL FILM INC.'s proposed operating limitations, the operating documents, and the technical aspects ofthe DJI Phantom 3 UAS, REVEL FILM INC. submits that safety will not be adversely affected by granting exemption from 14 C.F.R. Sections 91.405(a), 91.407(a)(l) and (a)(2), 91.409(a)(2), and 91.417(a) and (b). The FAA has previously granted relief specific to UAS in circumstances similar, in all material respects, to those presented herein (e.g. Exemption Nos. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 11112, 11136, 11138, 11150, 11153, 11156, 11157, 11158, 11159, 11160, 11161). 

### 7. The FAA May Prescribe Any Other Conditions For Safe Operation. In accordance with Section 333 ofthe FAA Modernization and Reform Act of2012 (FMRA) and 14 C.F.R. § 21.16 entitled Special Conditions, REVEL FILM INC. requests that the FAA

23prescribe special conditions for the intended operation ofthe DJI Phantom 3UAS, which contain such safety standards that the Administrator finds necessary to establish a level of safety equivalent to that established by 14 C.F.R. Part 21, Subpart H, and 14 C.F.R §§ 61.113(a) & (b), 91.7 (a), 91.121, 91.151(b), 91.405(a), 91.407(a)(l), 91.409(a)(l) & (a)(2), and 91.417(a) & (b). Such special conditions will permit safe operation of the UAS for the limited purpose of conducting aerial video and photography over certain areas of the United States for compensation or hire. FMRA Section 333 sets forth the requirements for considering whether a UAS will create a hazard to users ofthe NAS orthe public, orotherwisepose athreat to national security; and further, provides the authority for such UAS to operate without airworthiness certification in accordance with any requirements that must be established for the safe operation ofthe UAS inthe NAS. Likewise, the Administrator may prescribe special conditions pursuant to 14 C.F.R. § 21.16, for operation of the DJI Phantom 3 UAS, since the airworthiness regulations of 14 C.F.R. Part 21 do not contain adequate or appropriate safety standards, due to the novel or unusual design features of the aircraft. Section 21.16, entitled Special Conditions, states the following: If the FAA finds that the airworthiness regulations of this subchapter do not contain adequate or appropriate safety standards for an aircraft, aircraft engine, or propeller because ofa novel or unusual design feature ofthe aircraft, aircraft engine or propeller, he prescribes special conditions and amendments thereto for the product. The special conditions are issued in accordance with Part 11 ofthis chapter and contain such safety standards for the aircraft, aircraft engine or propeller as the FAA finds necessary to establish a level ofsafety equivalentto that established inthe regulations. See 14 C.F.R. §21.16. Therefore, in accordance with FMRA Section 333 and 14 C.F.R. § 21.16, the FAA may prescribe special conditions for Leading Edge's intended operation ofthe DJI Phantom 3 UAS, which contain such safety standards thatthe 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 61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(l), 91.409(a)(1) & (a)(2), and 91.417(a) & (b).

• A Summary That Can Be Published In The Federal Register, stating: The RulesFromWhichREVELFILMINC.SeeksExemption:

REVEL FILM INC. seeks exemption from the requirements of 14 C.FR Sections 61.113(a)&(b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(l), 91.409(a)(l) & (a)(2), and91.417(a) & (b). A BriefDescriptionOfTheNatureOfTheExemptionREVELFILMINC. Seeks:



### 24This exemption willpermit REVEL FILM INC. to commercially operate an Unmanned Aircraft System (UAS)for thepurpose ofconducting aerial video andphotography over certainareas of the United States.

• Any Additional Information,Views, OrArguments Available To SupportREVEL FILMINC.'sRequest.

This Petitionis made pursuantto the FAAModernization and Reform Act of2012 (FMRA) Section 333, which directs the Secretary ofTransportation to determine ifcertain UAS may operate safely in the NAS. As such, REVEL FILM INC.'s request for exemption may be grantedpursuanttothe authority ofFMRA Section 333 and 14 C.F.R. Part 11, as setforth above. FMRA Section 333 sets forth the requirements for considering whether a UAS will create a hazard to users ofthe NAS or the public, or otherwise pose a threat to national security; and further, providesthe authority for such UAS to operate without airworthiness certification. As discussed in detail above, REVEL FILM INC. will operate the DJI Phantom 3 UAS safely in the NAS, without creating a hazard to users ofthe NAS, orthe public, or otherwise pose a threat to national security. CONCLUSION As set forth herein, REVEL FILM INC. seeks an exemption pursuant to 14 C.F.R. 

### § 11.61 and Section 333 ofthe FAA Modernization and Reform Act of2012 (FMRA), whichwill permit safe operation ofthe DJI Phantom 3 UAS commercially, without an airworthiness certificate, for the limited purpose of conducting aerial video and photography over certain areas ofthe United States. By granting this Petition, the FAA Administrator will be fulfilling the Congressional mandate ofthe FAA Modernization and Reform Act of2012, while also advancing the interests ofthe public, by allowing REVEL FILM INC. to safely, efficiently, and economically operate the DJI Phantom 3UAS commercially withinthe NAS. WHEREFORE, in accordance with the Federal Aviation Regulations and the FAA Modernization and Reform Act of2012, Section 333, REVEL FILM INC. respectfully requests that the Administrator grant this Petition for an exemption from the requirements of 14 C.F.R Sections 61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(l), 91.409(a)(l) & (a)(2), and 91.417(a) & (b), and permit Leading Edge to operate the DJI Phantom 3 UAS commercially for the purpose ofconducting aerial video and photography over certain areas of the United States. Dated: June 10, 2015 Respectfully submitted,

25BrianBrennan Founder/Owner Revel film Inc. 54 Lolly Lane Centereach NY 11720 631-513-3292 Brian@revelfilm.com

Appendices:

A- Linkto DJI Phantom3 Manual: Click onlinkbelow http:lj_do**\\'Il_lQ~d.**d ji: mnovations.cqiTII**~_Qwnloads_Lph<llltg_m_]/**enLPhantgm

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## ust;r_Manual v1.2 en.pdf

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