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UNITED STATES OF AMERICA DEPARTMENT OF TRANSPORTATION FEDERAL AVIATION ADMINISTRATION WASHINGTON, DC Regulatory Docket No. _______________

**IN THE MATTER OF THE PETITION FOR EXEMPTION OF: EDWA RD STANZA**  **FOR A N**  **EXEMPTION SEEKING RELIEF FROM THE REQUIREMENTS OF TI**  **TLE 14 OF THE CODE OF FEDERA L REGULATIONS SECTIONS 61.113(a) &**  **(b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), AND 91.417(a) & (b) CONCERNING COMMERCIAL OPERATI**  **ON OF DJI Phantom 3, DJI Inspire 1 UNMA**  **NNED AIRCRA FT** **SYSTEMS PURSUANT TO SECTION 333 OF THE FAA MODERNIZATION AND REFORM ACT OF 2012**  **(PUBLIC LA**

**W 112**

**- 95)** 

Subm itted on Septem ber 11 , 2015 Edward Stanza 1 954 Argyle Ave. #D Los Angeles, CA 90068 409

- 599

- 9 846**2 |**  Page

**TABLE OF CONTENTS** Page GLOSSARY OF ABBREVIATIONS........................................................................................3 SUMMARY....................................................................................................... .......................4 INTRODUCTION AND INTERESTS OF PETITIONER..........................................................4 BACKGROUND................................................................................................................... ...4 BASIS FOR PETITION........................................................................................................... 5 NAME AND ADDRESS OF PETITIONER..............................................................................6 THE SPECIFIC SECTIONS OF 14 C.F.R. FROM W HICH EDWA RD STANZA SEEKS EXEMPTION............................................................................................ ...............................6 THE EXTENT OF RELIEF EDWA RD STANZA AND THE REASON EDWARD STANZA SEEKS THE RELIEF.....................................................................................

........................ 9 THE REASONS WH Y GRANTING EDWA RD STANZA REQUEST WOULD BE IN THE PUBLIC INTEREST .......................................... ..........................................................11 THE REASONS WH Y GRANTING THE EXEMPTION W OULD NOT ADVERSELY AFFECT SAFETY................................................................................................................ .13 SUMM ARY THAT CAN BE PUBLISHED IN THE FEDERAL REGISTER............................23 ANY ADDITIONAL INFORMATION, VIEW S, OR ARGUMENTS AVAILABLE TO SUPPORT EDWA RD STANZA’S REQUEST.......................................

...... ..............24 CONCLUSION............................................... .......................................................................24 APPENDICES....................................................................................................25**3 |**  Page

**GLOSSA RY OF ABBREVIATIONS**  AGL Above Ground Level AOI Area of Interest ATC Air Traffic Control ATO Air Traffic Organization AV Aerial Vehicle CFR Code of Federal Regulations COA Certificate of Authorization FAA Federal Aviation Adm inistration FAR Federal Aviation Regulation GCS Ground Control Station GPS Global Positioning System LOL Loss of Link NAS National Airspace Sys tem NOTAM Notice to Airman PIC Pilot In Comm and Section 333 FAA Modernization and Reform Act of 2012 (FMRA) Section 333 SO Safety Observer SOP Standard Operating Procedures UA Unm anned Aircraft UAS Unm anned Aircraft System VFR Visual Flight Rules VLOS Visual Line of Site VMC Visual Meteorological Conditions VTOL Vertical Takeoff and Landing**4 |**  Page

**SUMMARY** Edward Stanza seeks exem ption from the requirem ents of 14 C.F.R §§ 61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409( a)(1) & (a)(2), and 91.417(a) & (b), to operate an Unm anned Aircraft System pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (FMRA). This exem ption will perm it **EDWARD STANZA**  to operate an Unm anned Aircraft System (UAS) for the com mercial purpose of conducting aerial video and photography of construction sites, real estate, Special Events and landscape over certain areas of the United States. **INTRODUCTION AND INTERESTS OF THE PETITIONER** Edward Stanza provides clients w ith experti se in advanced photography and videography technologies to increase productivity and effectiveness. He has over 4 years recreational/hobby experience in rem ote controlled vehicles. Additionally, he currently has 41 hours flight in Airplane Single Engine Land; The objective of Edward Stanza’s aerial video and photography operations is to provide high quality im aging for a variety of commercial, public, and residential uses, specifically targeting: R e a l e s t a t e a n d p r i va t e p ro p e rty a e r i a l p h o to g ra p h y Aerial event photography S e a rc h a n d R e s c u e Ae r i a l i m a g e s u s e d fo r i n s p e ct i o n s of p u b l i c a n d p r i va t e s t r u ct u re s , a n d I n c re a s e p u b l i c k n o w l e d g e of U AS a n d p ro m o t e s a fe U A S o p e ra t i o n s

.

**BACKGROUND** Unm anned Aircraft System s: DJI Phantom 3, DJI Inspire 1 Edward Stanza seeks an exem ption to operate DJI system s for compensation or hire within the NAS. D J I M o d e l s : DJI Phantom 3, and Inspire 1 are lightweight (under 55 lbs) , battery operated Multi

- Rotor VTOL aircraft A n o n

- board flight compute r w ith GPS navigation and location ability that receives signals for flight controls from a ground

- based transm itter/controller A n o n

- board cam era attached to the UA via three axis gim bal, capable of capturing full color, high definition imagery A n o n

- board telem etry system that delivers flight data from the on

- board flight com puter to the on

- board radio transm itter including altitude AGL, horizontal and vertical speed,

com pass direction of flight and direction back to its launch site

The DJI UAS th at w ill be operated by Edward Stanza 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 m arked in accordance with 14 C.F.R. Part 45, Identification and Registration Marki ng

.**5 |**  Page

**BA SIS FOR PETITION**  Petitioner, Edward Stanza, pursuant to the provisions of the Federal Aviation Regulations (14 C.F.R. § 11.61) and the FAA Modernization and Reform Act of 2012 (FMRA), Section 333, Special Rules for Certain Unmanned Aircraft Syste ms , hereby petitions the Adm inistrator to commerc ially operate the DJI Phantom 3, DJI Inspire 1 UAS in the National Airspace System (NAS), and for an exem ption from the requirem ents of 14 C.F.R §§ 61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91 .407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b). In consideration of the speed, weight, size, and lim ited operating area associated with the unm anned aircraft and its operation, Edward Stanza’s operation of DJI Phantom 3, DJI Inspire 1 UAS m eets t he conditions of FMRA Section 333 and therefore, w ill not require an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H. Accordingly, Edward Stanza requests relief from Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 9 1.417(a) & (b), as these sections set forth requirem ents for maintenance that only apply to aircraft w ith an airworthiness certificate. Edward Stanza subm its that the requested relief is proper since an equivalent level of safety w ill be ensured. Edward Stanza will use experienced personnel or technicians to perform maintenance, alterations, or preventive maintenance on the UASs using the methods, techniques, and practices prescribed in the operating documents (i.e., Monthly Maintenance Log, and DJI Phan tom 3, DJI Inspire 1 Instruction Manual). Furtherm ore Edward Stanza will docum ent and m aintain all maintenance records for the DJI Phantom 3, DJI Inspire 1 UAS. Edward Stanza seeks relief from Section 91.7(a), entitled Civil aircraft airworthiness

, becaus e the DJI Phantom 3, DJI Inspire 1 UAS does not require an airworthiness certificate in accordance w ith 14 C.F.R. Part 21, Subpart H. As such, Edward Stanza subm its that he w ill ensure that the DJI Phantom 3, DJI Inspire 1 UAS is in an airworthy condition , prior to every flight, by determ ining that the UAS is in com pliance with the operating docum ents (i.e., Monthly Maintenance Log, and DJI Phantom 3, DJI Inspire 1 Instruction Manual), and that the aircraft is in a condition for safe flight. Edward Stanza also seeks an exem ption from the requirem ents of Section 91.121, entitled Altimeter Settings , as the DJI Phantom 3, DJI Inspire 1 UA w ill not have a typical barom etric altim eter onboard. However, altitude inform ation of the DJI Phantom 3, DJI Inspire 1 UAS w ill be provided to the PIC via Global Positioning System (GPS) equipm ent and radio communications telem etry data link, which downlinks from the UA to the GCS for**6 |**  Page

active m onitoring of the flight path. This altitude inform ation, com bined with Edward Stanza ’s operation of the DJI Phantom 3, DJI Inspire 1 UAS w ithin visual line of sight, at or below 400 feet AGL, will ensure a level of safety equivalent to Section 91.121. Additionally, Edward Stanza seeks an exem ption from the requirem ents of Section 91.151(b), entitled Fuel requirements for flight in VFR conditions

. **EDWARD STANZA** subm its that safety w ill not be affected by operation of the DJI Phantom 3, DJI Inspire 1 UA during daylight hours in visual m eteorological conditions (VMC) under visual flig ht rules (VFR), w ith enough battery power to fly for a total duration of approximately 13.5 m inutes to the first point of intended landing and, assum ing norm al cruising speed, to fly after that for at least 4.5 m inutes. In accordance with 14 C.F.R. § 11.8 1, **EDWARD STANZA** provides the following inform ation in support of its petition for exem ption: **A. Name A nd A** **ddress Of The Petitioner.** The nam e and address of the Petitioner and point of contact is: EDWA RD STANZA 1954 ARGYLE AVE. #D LOS ANGELES, CA 90068 Tel: ( 409) 599

- 9846 Em ail: edwardstanza @yahoo.com **B. The Specific Sections Of 14 C.F.R. From Which Edward Stanza**  **Seeks Exemption. 1. Edward Stanza**  **Seeks Exemption From The Requirements Of Section 61.113(a) A nd**  **(b).** Section 61.113, entitled Private pilot privileges and lim itations: Pilot in command

, subsections (a) and (b) prescribe the following, in relevant part: (a) No person who holds a private pilot certificate m ay act as a pilot in command (PIC) of an aircraf t that is carrying passengers or property for com pensation or hire; nor m ay that person, for compensation or hire, act as PIC of an aircraft. (b) A private pilot m ay, for com pensation or hire, act as PIC of an aircraft in connection with any business or em ploym ent if

— (1) The flight is only incidental to that business or em ploym ent; and (2) The aircraft does not carry passengers or property for com pensation or hire. **2. Edward Stanza Seeks Exemption From The Requirements Of Section 91.7(a).**  Section 91. 7, entitled Civil aircraft airworthiness , subsection (a), states the following: (a) No person m ay operate a civil aircraft unless it is in an airworthy condition.**7 |**  Page

**3. EDWARD STANZA Seeks Exemption From The Requirements Of Section 91.121.**  Section 91.121 , entitled Altim eter settings, subsection (a), states the following, in part: (a) Each person operating an aircraft shall m aintain the cruising altitude or flight level of that aircraft, as the case may be, by reference to an altim eter that is set, when operating (1) Below

18,000 feet MSL, to

-- (i) The current reported altim eter setting of a station along the route and w ithin 100 nautical miles of the aircraft; (ii) If there i s no station within the area prescribed in paragraph (a)(1)(i) of this section, the current reported altim eter setting of an appropriate available station; or (iii) In the case of an aircraft not equipped with a radio, the elevation of the departure airp ort or an appropriate altim eter setting available before departure. **4. EDWARD STANZA**  **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 followi ng: (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. EDWARD STANZA**  **Seeks Exemption From The Requirement Of Section 91.405(a).** Section 91.405, entitled Maintenance required, subsection (a), states the follow ing: Each owner or operator of an aircraft

— (a) Shall have that aircra ft inspected as prescribed in subpart E of this part and shall between required inspections, except as provided in paragraph (c) of this section, have discrepancies repaired as prescribed in part 43 of this chapter[.] **6. EDWARD STANZA**  **Seeks Exemption From The Requirements Of Section**  **91.407(a)(1)** Section 91.407, entitled Operation after maintenance, preventive maintenance, rebuilding, or alteration , subsection (a)(1), states the following: (a) No person m ay operate any aircraft that has undergone m ainten ance, preventive maintenance, rebuilding, or alteration unless

--**8 |**  Page

(1) It has been approved for return to service by a person authorized under § 43.7 of this chapter [.] **7. EDWARD STANZA**  **Seeks Exemption From The Requirements Of Sections 91.409(a)(1) And 91.409(a)(2).**  Section 91.409, entitled Inspections , subsection (a), states the following: (a) Except as provided in paragraph (c) of this section, no person m ay operate an aircraft unless, w ithin the preceding 12 calendar m onths, it has had

– (1) An annual inspection in accordance with part 43 of this chapter and has been approved for return to service by a person authorized by § 43.7 of this chapter; or (2) An inspection for the issuance of an airworthiness certificate in accordance with part 21 of this chapter. **8. EDWARD STANZA**  **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 follow ing: (a) Except for work perform ed in accordance with §§ 91.411 and 91.413, each registered owner or operator shall keep the following records for the periods specified in paragraph (b) of this section: (1) Records of the m aintenance , preventive m aintenance, and alteration and records of the 100

- hour, annual, progressive, and other required or approved inspections, as appropriate, for each aircraft (including the airfram e) and each engine, propeller, rotor, and appliance of an aircraf

t. The records must include

— (i) A description (or reference to data acceptable to the Adm inistrator) of the work perform ed; and (ii) The date of com pletion of the work perform ed; and (iii) The signature, and certificate num ber of the person approving t he aircraft for return to service. (2) Records containing the following inform ation: (i) The total time in service of the airfram e, each engine, each propeller, and each rotor (ii) The current status of life

- lim ited parts of each airframe, engine, prope ller, rotor, and appliance.**9 |**  Page

(iii) The tim e since last overhaul of all items installed on the aircraft w hich are required to be overhauled on a specified tim e basis. (iv) The current inspection status of the aircraft, including the tim e since the last inspection required by the inspection program under which the aircraft and its appliances are m aintained. (v) The current status of applicable airworthiness directives (AD) and safety directives including, for each, the m ethod of compliance, the AD or safety directive num ber 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 ow ner or operator shall retain the following records for the periods prescribed: (1) The records specified in paragraph (a)(1) of this section shall be retained until the work is repeated or superseded by other work or for 1 year after the work is perform ed. (2) The records specified in paragraph (a)(2) of this section shall be retained and transferred with the aircraft at the tim e the aircraft is sold. (3) A list of defects furnished to a registered owner or operator under § 43.11 of this chapter shall be retained until the defects are repaired and the aircraft is approved for return to service. **C. The Extent Of Relief EDWARD STANZA**  **Seeks And The Reason**  **EDWA RD STANZA**  **Seeks The Relief. 1. Extent Of Relief**  **EDW ARD STANZA**  **Seeks A nd The Reason**  **EDWA RD STANZA**  **Seeks Relief From Section 61.113(a) A nd (b).**  Relief from Section 61.113(a) and (b) entitled Private pilot privileges and limitations: Pilot i n 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 airm an medical certificate, and who has m et certain flight

- hour and currency requirements, to conduct the pro posed UAS flight operations for compensation or hire. This relief is requested since the lim itations 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 busines s or em ploym ent if: (1) The flight is only incidental to that business or em ploym ent; and (2) The aircraft does not carry passengers or property for

com pensation or hire. As set forth more fully below, EDWA RD STANZA subm its that an equivalent level of**10 |**  Page

safety w ill be m aintained because no PIC w ill be allowed to operate the DJI Phantom 3, DJI Inspire 1 UAS unless that PIC has met certain flight

- hour and currency requirem ents, dem onstrating that the PIC is able to safely operate the DJI Phantom 3, DJI Ins pire 1 UAS in a m anner consistent with the operations specifications as described in this exem ption, including evasive and emergency m aneuvers, as well as m aintaining appropriate distances fro m people, vessels, vehicles and structures. Further, **EDWA RD STA**  **NZA** subm its that all flights of the DJI Phantom 3, DJI Inspire 1 UAS, conducted by the PIC pursuant to the grant of this Petition: (1) w ill be incidental to **EDWA RD STANZA**  business; and (2) will not carry passengers or property for

com pensation or hire. **2. Extent Of Relief EDW** **ARD STANZA Seeks A**  **nd The Reason EDWA**  **RD STANZA 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 **EDWARD STANZA** to determ ine that the DJI Phantom 3, DJI Inspire 1 UAS is in airworthy condition prior to every flight by ensuring that the UAS is in com pliance with the operating documents (i.e., Monthly Maintenance Log, and DJI Phantom 3, DJI Inspire 1 Instruction Manua l). **EDWA RD STANZA**  seeks the requested relief because the DJI Phantom 3, DJI Inspire 1 UAS does not require an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H. Therefore, **EDW ARD STANZA**  will ensure that the DJI Phantom 3, DJI Inspi re 1 UAS is in airworthy condition based upon its compliance with the operating docum ents (i.e., Monthly Maintenance Log, and DJI Phantom 3, DJI Inspire 1 UAS Instruction Manual) prior to every flight, and further, determ ine that the aircraft is in conditi on for safe flight, as stated in the conditions and limitations below

. **3. Extent Of Relief EDW** **ARD STANZA Seeks A**  **nd The Reason EDWA**  **RD STANZA Seeks Relief From Section 91.121.**  Relief from Section 91.121, entitled Altim eter settings, may be required to allo w flight operations of the DJI Phantom 3, DJI Inspire 1 UAS, w hich utilize a barom etric pressure sensor, GPS equipm ent, and a radio comm unications telem etry data link to dow nlink altitude inform ation from the UA to the PIC at the ground control station (G CS). Since the FAA requires that any altitude inform ation concerning UAS operations be reported to air traffic control (ATC) in feet above ground level (AGL), **EDW ARD STANZA**  seeks the requested relief because the DJI Phantom 3, DJI Inspire 1 UA altim eter m a y be set on the ground to zero feet AGL, rather than the local barom etric pressure or field altitude, before each flight. Considering the lim ited altitude of the proposed operations, relief from 14 CFR 91.121 is sought to the extent necessary to com ply w ith the applicable conditions and lim itations stated below. As m ore fully set forth herein, an equivalent level of safety will be m aintained since the DJI Phantom 3, DJI Inspire 1 UA is equipped with a barom etric pressure sensor and GPS equipm ent, which au tom atically ensures that a ground level pressure setting will be established prior to each flight, and provides the PIC with altitude inform ation of the UA on the heads

- up display of the GCS.**11 |**  Page

**4. Extent Of Relief EDW** **ARD STANZA Seeks A**  **nd The Reason EDWA**  **R D STANZA**  **Seeks Relief From Section 91.151(b).** Relief from Section 91.151(b) entitled Fuel requirem ents for flight in VFR conditions, is requested to the extent required to allow flights of the battery powered DJI Phantom 3, DJI Inspire 1 UA during daylig ht hours in visual m eteorological conditions (VMC), under visual flight rules (VFR), for a total duration of 13.5 m inutes to the first point of intended landing and, assum ing norm al cruising speed, to fly after that for at least 4.5 minutes. **EDWA RD**  **STANZA** seeks the requested relief because without an exem ption from Section 91.151(b), the flight tim e duration of the battery powered DJI Phantom 3, DJI Inspire 1 UA w ill severely constrain the practicality of any aerial video or still photo flight operations th at **EDWA RD**  **STANZA** proposes to conduct pursuant to this Petition. Significantly, as set forth below, the technical specifications of the DJI Phantom 3, DJI Inspire 1 UAS, the DJI Phantom 3, DJI Inspire 1 operating docum ents, and **EDWA RD**  **STANZA ’S**  proposed operating lim itations, ensure that **EDWARD STANZA** will safely operate the battery powered DJI Phantom 3, DJI Inspire 1 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 13.5 minutes to the first point of intended landing and, assum ing

norm al cruising speed, to fly after that for at least 4.5 minutes. **5. Extent Of Relief EDW** **ARD STANZA Seeks A**  **nd The Reason EDWA**  **RD STANZA Seeks Relief From Secti**  **ons 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, **EDWA RD STANZA**  requests relief fro m thes e Sections because the DJI Phantom 3, DJI Inspire 1 UAS does not require airworthiness certificates. As set forth m ore fully below, the DJI Phantom 3, DJI Inspire 1 UAS m eets the conditions of FMRA Section 333 for operation without an airworthiness certifi cate. Accordingly, **EDWA RD STANZA**  will use trained technicians to perform maintenance, alterations, or preventive m aintenance on the UASs using the m ethods, techniques, and practices prescribed in the UAS operating docum ents (i.e., Monthly Maintenance Log, and DJI Phantom 3, DJI Inspire 1). Furtherm ore, **EDW ARD STANZA**  will docum ent and maintain all m aintenance records for the DJI Phantom 3, DJI Inspire 1 UAS. **D. The Reasons Why**

**Granting EDWA**  **RD STANZA ’s Request Would Be In The Public**  **Interest; That Is, How I t Would Benefit The Public As A**  **Whole.** Granting the present Petition will further the public interest by allowing **EDWA RD STANZA**  to safely, efficiently, and econom ically perform aerial video and photography of construction sites, real estate, Special Events and landscape over certain areas of the United States. Additionally, use of the DJI Phantom 3, DJI Inspire 1 UAS will decrease congestion of the NAS, reduce pollution, and provide significant benefits to the econom y. Notably, the benefits of **EDW ARD STA**  **NZA ’S**  proposed operation of the DJI Phantom 3, DJI Inspire 1 UAS w ill be realized without im plicating any privacy issues.**12 |**  Page

**1. The Public Will Benefit From Decreased Congestion Of The NA S.**  The DJI Phantom 3, DJI Inspire 1 UA is battery powered and serves as a safe, efficient, and econom ical alternative to the m anned aircraft traditionally utilized to obtain aerial im agery. By reducing the am ount of manned aircraft needed to perform aerial a cquisitions,

an exem ption allowing the use of a DJI Phantom 3, DJI Inspire 1 UAS would reduce the

am ount 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. Furt herm ore, by reducing the num ber of manned aircraft operating in the NAS, congestion around airports caused by arriving and departing aircraft w ill be reduced. The DJI Phantom 3, DJI Inspire 1 UA does not require an airport to takeoff or land. Likewise, a reduction of ma nned aircraft conducting aerial video and photography m issions would result in fewer aircraft that must be handled by air traffic control during the ground, takeoff, departure, arrival, and landing phases of flight operations. **2. The Publi c Will Benefit From The Safety**  **And Efficiency**

**Of T he DJI Phantom 3, DJI**  **Inspire 1 UA S.**  Conducting aerial acquisitions with the DJI Phantom 3, DJI Inspire 1 UAS, instead of manned aircraft, will greatly benefit the public by drastically reducing the level s 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 3, DJI Inspire 1 UAS produces no air pollution, and is the m ost viable environm enta lly conscious alternative to the cabin class, six cylinder internal com bustion engine aircraft that are typically utilized for aerial video and photography, while burning approxim ately 20

- 30 gallons per hour of leaded aviation fuel. The DJI Phantom 3, DJI Inspire 1 UA, w hile reducing the carbon footprint of aerial acquisitions, also elim inates noise pollution, as the UAs are propelled by battery powered electric m otors, rather than an internal com bustion engine. By using the DJI Phantom 3, DJI Inspire 1 UAS to perform aerial acquisitions, the substantial risk to life and property in the air and on the ground, which is usually associated with traditional access methods, w ill be substantially reduced or com pletely elim inated. Aside from the lack of flight c rew me mbers located onboard the aircraft, the DJI Phantom 3, DJI Inspire 1 UA (under 3lbs, and 6.5lb. gross weight respectively) and w ith no fuel on board), has less physical potential for collateral dam age to life and property on the ground, and in the ai r, com pared to the manned aircraft that typically conduct similar operations (weighing approxim ately 6,000 pounds with a wingspan of approxim ately 42 feet, a length of 34 feet, and a fuel capacity of 180 gallons). **3. Performing A erial Video and Photograph**  **y Operations With The DJI Phantom 3, DJI Inspire 1 UA** **S Will Benefit The Economy**

**.** In addition to being safe and efficient, the DJI Phantom 3, DJI Inspire 1 UAS is also an

econom ical alternative to using m anned aircraft to conduct sim ilar aerial operations . As such, operation of the DJI Phantom 3, DJI Inspire 1 UAS w ill allow United States based

com panies, like **EDWARD STANZA ’S**  , to rem ain com petitive and contribute to growth of the U.S. econom y. Specifically, with the rising cost of aviation fuel and the Environm ental Protection Agency (“EPA”) regulatory actions phasing out leaded aviation fuels, U.S. owned**13 |**  Page

and operated com pan ies m ust adopt new and alternative technology in order to rem ain

com petitive. Operating the battery powered DJI Phantom 3, DJI Inspire 1 UASs is one such technology that not only allows com panies greater operational flexibility com pared to manned aircraft, but provides such flexibility without the high operational cost of a traditional manned aircraft. By operating the DJI Phantom 3, DJI Inspire 1 UAS, com panies such as **EDWA RD**  **STANZA**’s, can rem ain com petitive and profitable, and therefore, provide greater job stability to em ployees and contractors, w hich will ultim ately contribute to growth of the U.S.

econom y. Improved financial perform ance of U.S. com panies, through commercial use of the DJI Phantom 3, DJI Inspire 1 UAS, provides a stable workforce that increases consum er spending; im proves local, state, and federal tax revenues; and allows com panies to invest in research and development in order to remain com petitive both in the United States and abroad. **4. There Are No Privacy Issues.** Sim ilar to the manned aerial acquisition flight operations that have been conducted for decades, **EDWARD STANZA**’s proposed operation of the DJI Phantom 3, DJI Inspire 1 UAS w ill not im plicate any privacy issues. Specifically, the DJI Phantom 3, DJI Inspire 1 UAS w ill be operated only in com pliance with operating docum ents (i.e., Monthly Maintenance Log, and DJI Phantom 3, DJI Inspire 1) which requires property owner involvem ent as well as local law enforcem ent notification, and in accordance with the Federal Aviation Regu lations, including the m inimum altitude requirem ents of 14 C.F.R. § 91.119. **E. The Reasons Why**

**Granting The Exemption Would Not A dversely**  **A ffect Safety**  **, Or How The Exemption Would Provide A**  **Level Of Safety**

**A t Least Equal To That**  **Provided By**

**T he Rule From**  **Which EDWA**  **RD STANZA Seeks Exemption.**  **1. Reasons Why**

**T he DJI Phantom 3, DJI Inspire 1 UA**  **M eets The Conditions Of**  **The FAA Modernization and Reform A ct of 2012 (FMRA) Section 333.**  In consideration of the size, weight, speed, and lim ited operating area ass ociated with the unm anned aircraft and its operation, **EDWARD STANZA ’S**  operation of the DJI Phantom 3, DJI Inspire 1 UAS m eets the conditions of FMRA Section 333, and will not require an airworthiness certificate in accordance w ith 14 C.F.R. Part 21, Subpart H. Section 333 provides authority for a UAS to operate without airworthiness certification and sets forth requirem ents for considering whether a UAS w ill create a hazard to users of the NAS or the public, or otherwise pose a threat to national security. Specifically, FMRA Section 333 states the following, in part: (a) In General.

-- Notwithstanding any other requirement of this subtitle, and not later than 180 days after the date of enactment of this Act, the Secretary of Transportation shall determine if certain unmanned aircraft systems may operate safely in the natio nal airspace system before completion of the plan and rulemaking required by section 332 of this Act or the guidance required by section 334 of this Act.**14 |**  Page

(b) Assessment of Unmanned Aircraft Systems.

-- In making the determination under subsection (a), the Secretary shall determine, at a minimum

-- (1) which types of unmanned aircraft systems, if any, as a result of their size, weight, speed, operational capability, proximity to airports and populated areas, and operation within visual line of sight do not create a hazard to users of the national airspace system or the public or pose a threat to national security; and (2) whether a certificate of waiver, certificate of authorization, or airworthiness certification under section 44704 of title 49, United States Code, is required for the operation of unmanned aircraft systems identified under paragraph (1). (c) Requirements for Safe Operation.

-- If the Secretary determines under this section that certain unmanned aircraft systems may operate safely in the nat ional airspace system, the Secretary shall establish requirements for the safe operation of such aircraft systems in the national airspace system. In seeking this exem ption, **EDWA RD STANZA**  subm its that the DJI Phantom 3, DJI Inspire 1 UAS can operate safel y in the NAS pursuant to FMRA Section 333, as dem onstrated by: (a) the characteristics of the DJI Phantom 3, DJI Inspire 1 UAS; (b) the pilot certification requirem ent; and (c) the specific operating lim itations. **a. The Specifications Of The DJI Phantom 3, DJI Inspire 1 UA S Demonstrate Its**  **Safe Characteristics.** The DJI Phantom 3, DJI Inspire 1 UAS does not create a hazard to users of the NAS or the public, or otherwise pose a threat to national security consider ing its size, weight, speed, and operational capability. **i. Technical Specifications Of The DJI Phantom 3, DJI Inspire 1 UAS.** The technical specification of the DJI Phantom 3, DJI Inspire 1 UAS is set forth by the DJI Phantom 3, DJI Inspire 1 Specificati ons and Data Sheet, attached hereto as Exhibit A and B. **ii. The DJI Phantom 3, DJI Inspire 1 UA S A**  **utonomous Flight A nd Navigation Modes**  **Enable The UA Ss T**  **o Remain Within A Defined Operational Area.**  The DJI Phantom 3, DJI Inspire 1 UAS m ay be operated in b oth m anual and fully autonom ous flight modes. A complete description of the flight and navigational m odes of the DJI Phantom 3, DJI Inspire 1 UAS is provided in the DJI Phantom 3, DJI Inspire 1 User Manual, attached hereto as Exhibit C and D. **iii. The DJ I Phantom 3, DJI Inspire 1 UA** **S is Designed For A utomatic Return**  **To Home Point Or Hover In The Event Of Loss Of The Control Link Or Navigation. 15**  **|** Page

Wh en the Control Link is lost, the DJI Phantom 3, DJI Inspire 1 UA w ill rem ain stationary, in flight, for 3 se conds or more. If, after 3 seconds, the DJI Phantom 3, DJI Inspire 1 UA does not reacquire control link data from the GCS, the UAs w ill assum e that the Control Link is lost and the UAs w ill return to the hom e position (i.e., failsafe mode) via GPS, and wil l descend to the takeoff position and shutdown. A com plete description of the Failsafe Functions of the DJI Phantom 3, DJI Inspire 1 UAS are set forth in the DJI Phantom 3, DJI Inspire 1 User Manual, attached hereto as Exhibit C and D. **iv. The DJI Phantom 3, DJI Inspire 1 GCS A nd Its Operation.**  A com plete description of the operation and specifications of the DJI Phantom 3, DJI Inspire 1 GCS and flight control software is provided in the User Manual. DJI Phantom 3, DJI Inspire 1 User Ma nual is attached hereto as Exhibits C and D. **b. Flight Operations Of DJI Phantom 3, DJI Inspire 1 UA S is Limited To The Line Of**  **Sight Of A**

**Pilot in Command With A Safety Observer.**  **EDWA RD STANZA**  will only utilize pilots who possess a current and valid m e dical certificate to act as a pilot in command (PIC) of the DJI Phantom 3, DJI Inspire 1 UAS. Additionally, a safety observer will assist all pilots during flight tim e. **c. Flights Of DJI Phantom 3, DJI Inspire 1 UAS Will Be Conducted Pursuant To Specifi**  **c Operating Limitations.** In seeking this exem ption, **EDWA RD STANZA**  proposes to commercially operate DJI Phantom 3, DJI Inspire 1 UAS for the special purpose of conducting aerial video and photography over certain areas of United States, pursuant to the fol lowing specific operating lim itations: 1. Operations authorized by this grant of exem ption will be lim ited to the following aircraft described in the operating docum ents, rotorcraft UASs weighing less than 55 pounds maxim um gross weight: DJI Phantom 3, DJI Inspire 1 Unm anned Aircraft Systems. Proposed operations of any other aircraft w ill require a new petition or a petition to am end this grant. 2. UAS operations under this exem ption will be lim ited to conducting operations for the purpose of aerial vi deo and photography. 3. The UAs may not be flown at an indicated airspeed exceeding 20 knots. 4. The UA must be operated at an altitude of no m ore than 400 feet above ground level (AGL), as indicated by the procedures specified in the operating documents unless a special request is m ade and approved by ATC. All altitudes reported to ATC must be in feet AGL. 5. The UA must be operated within visual line of sight (VLOS) of the PIC at all tim es. This requires the PIC to be able to use hum an vision unaided by any device other than corrective**16 |**  Page

lenses. 6. The use of first person view (FPV) by the PIC or safety observer (SO) is not perm itted. 7. All operations m ust utilize a safety observer (SO). The SO m ay be used to satisfy the VLOS requirem ent as long a s the PIC always maintains VLOS capability. The SO and PIC must be able to communicate verbally at all times. Electronic m essaging or texting is not perm itted during flight operations. The PIC m ust be designated before the flight and cannot transfer his or her designation for the duration of the flight. The PIC must ensure that the SO can perform the functions prescribed in the operating docum ents. 8. The SO m ust 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 perm itted to operate the cam era or other instrum ents. 9. The operating documents and the grant of exem ption m ust be accessible during UAS operations and m ade available to the Ad mi nistrator upon request. If a discrepancy exists between the conditions and lim itations contained in the grant of exem ption and the procedures outlined in the operating docum ents, the conditions and limitations contained in the grant of exem ption take precedence and must be followed. Otherwise, the operator must follow

the procedures as outlined in its operating docum ents. The operator m ay update or revise its operating docum ents. It is the operator’s responsibility to track such revisions and present u pdated and revised docum ents to the Adm inistrator upon request. The operator m ust also present updated and revised docum ents if it petitions for extension

or am endm ent to the grant of exem ption. If the operator determ ines that any update or revision would affect the basis upon which the FAA granted the exem ption, then the operator m ust petition for am endm ent to its grant of exem ption. The FAA’s UAS Integration Office (AFS

- 80) may be contacted if questions arise regarding updates or revisions to the operatin g docum ents. 10. Prior to each flight the PIC m ust inspect the UAS to ensure that it is in a condition for safe flight. If the inspection reveals a condition that affects the safe operation of the UAS, the aircraft is prohibited from operating until the necessary m aintenance has been perform ed and the UAS is found to be in a condition for safe flight. The Ground Control Station m ust be included in the preflight inspection. All m aintenance and alterations m ust be properly docum ented in the aircraft records

. 11. Any UAS that has undergone m aintenance or alterations that affect the UAS operation or flight characteristics, e.g. replacem ent of a flight critical com ponent, must undergo a functional test flight. The PIC w ho conducts the functional test flight m ust make an entry in the aircraft records. 12. The pre

-flight inspection m ust account for all potential discrepancies, e.g. inoperable

com ponents, items, or equipm ent, not already covered in the relevant sections of the operating docum ents. 13. The op erator m ust follow the UAS m anufacturer’s aircraft/component, maintenance, overhaul, replacem ent, inspection, and life lim it requirem ents. 14. The operator m ust carry out its m aintenance, inspections, and record keeping**17 |**  Page

requirem ents, in accordance wit h the operating docum ents. Maintenance, inspection, alterations, and status of replacem ent/overhaul com ponent parts m ust be noted in the aircraft records, including total tim e in service, description of work accomplished, and the signature of the authoriz ed person returning the UAS to service. 15. Each UAS operated under this exem ption must com ply w ith all m anufacturer Safety Bulletins. 16. The authorized person m ust m ake an entry in the aircraft record of the corrective action taken against discrepanc ies discovered between inspections. 17. The PIC must possess at least a current medical certificate. 18. The operator m ay not perm it any PIC to operate unless the PIC meets the operator’s qualification criteria and dem onstrates the ability to safely operate the UAS in a m anner consistent with how the UAS w ill be operated under the exem ption, including evasive and

em ergency m aneuvers and m aintaining appropriate distances from persons, vess els, vehicles and structures. PIC qualification flight hours m ust be logged in a m anner consistent with 14 C.F.R. § 61.51(b). Flights for the purposes of training the operator’s PICs are perm itted under the terms of the exem ption. However, training operati ons m ay 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 m ust operate the UA with appropriate di stance from nonparticipants in accordance with 14 C.F.R. § 91.119. 19. UAS operations m ay not be conducted during night, as defined in 14 C.F.R. § 1.1. All operations m ust be conducted under visual m eteorological conditions (VMC). If flight at night is required, a special request w ill be m ade at the FAA office closest to proposed area of operations. Flights under special visual flight rules (SVFR) are not authorized. 20. The UA m ay not operate within 5 nautical miles of an airport reference point as de noted on a current FAA

- published aeronautical chart unless a letter of agreement w ith that airport’s m anagem ent is obtained, and the operation is conducted in accordance with a NOTAM as required by the operator’s COA. The letter of agreem ent with the airp ort managem ent must be made available to the Adm inistrator upon request. 21. The UA m ay not be operated less than 500 feet below or less than 2,000 feet horizontally from a cloud or w hen visibility is less than 3 statute miles from the PIC. 22. If the UA loses communications or loses its GPS signal, it must return to a predeterm ined location within the planned operating area and land or be recovered in accordance with the operating docum ents. 23. The PIC must abort the flight in the event of unpredicted obstacles or em ergencies in accordance with the operating docum ents. 24. The PIC is prohibited from beginning a flight unless (considering wind and forecast**18 |**  Page

weather conditions) there is enough power to fly at norm al cruising speed to the intended landi ng point and land the UA with 25% battery power rem aining. 25. The operator m ust obtain an Air Traffic Organization (ATO) issued Certificate of W aiver or Authorization (COA) prior to conducting any operations under the grant of exem ption. 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 requirem ents in the ATO issued COA includ ing class of airspace, altitude level and potential transponder requirem ents. 26. All aircraft operated in accordance with the exem ption m ust be identified by serial

num ber, registered in accordance with 14 C.F.R. part 47, and have identification (NNum be r) markings in accordance w ith 14 C.F.R. part 45, Subpart C. Markings must be as large as practicable. 27. Before conducting operations, the radio frequency spectrum used for operation and control of the UA m ust com ply with the Federal Communications Commission (FCC) or other appropriate governm ent oversight agency requirem ents. 28. The docum ents required fewer than 14 C.F.R. 91.9 and 91.203 m ust be available to the PIC at the Ground Cont rol Station of the UAS any tim e the UAS is operating. These docum ents m ust be made available to the Adm inistrator or any law enforcem ent official upon request. 29. The UA m ust remain clear and yield the right of way to all m anned aviation operations and activities at all tim es. 30. The UAS may not be operated by the PIC from any m oving 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 ess ential persons), vessels, vehicles, and structures unless: a. Barriers or structures are present that sufficiently protect nonparticipating persons fro m the UA and/or debris in the event of an accident. The operator m ust ensure that nonparticipating persons rem ain under such protection. If a situation arises where nonparticipating persons leave such protection and are within 500 feet of the UA, flight operations m ust cease immediately and/or; b. The aircraft is operated near vessels, vehicles or structures w here the owner/controller of such vessels, vehicles or structures has granted permission and the PIC has m ade a safety assessm ent of the risk of operating closer to those objects and determ ined that it does not present an undue hazard, and; c. Op erations nearer to the PIC, SO, operator trainees or essential persons do not present an undue hazard to those persons per § 91.119(a). 32. All operations shall be conducted over private or controlled

- access property with**19 |**  Page

perm ission from the land owne r/controller or authorized representative. Perm ission 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 boun daries of the operational area as defined by the applicable COA must be reported to the FAA's UAS Integration Office (AFS

- 80) w ithin 24 hours. Accidents must be reported to the National Transportation Safety Board (NTSB) per instructions contained on the N TSB We b site: www .ntsb.gov. **2. Reasons Why**

**A n Exemption From The Requirements Of Section 61.113(a)**  **And (b) Would Not A dversely**  **A ffect Safety.**  **EDWA RD STANZA**  subm its that the equivalent level of safety established by Section 61.113(a) and (b) will be m aintained because no PIC w ill be allowed to operate the DJI Phantom 3, DJI Inspire 1 UAS unless that PIC has dem onstrated, by meeting m inimum flight

- hour and currency requirem ents, that the PIC is able to safely operate the DJI P hantom 3, DJI Inspire 1 UAS in a m anner consistent w ith the exem ption, including evasive and em ergency m aneuvers and m aintaining appropriate distances from people, vessels, vehicles and structures. **EDWA RD STANZA** **’S** specific proposed flight operations. The FAA has previously granted relief from Section 61.113(a) and (b) specific to UAS, in circum stances sim ilar, in all m aterial respects, to those presented herein (e.g. Exem ption Nos. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 11112, 1 1136, 11138, 11150, 11153, 11156, 11158, 11159, 11160, 11161). **EDWA RD STANZA**  will not allow any PIC to operate the DJI Phantom 3, DJI Inspire 1 UAS unless that PIC has demonstrated, by m eeting m inimum flight

- hour requirem ents or the DJI Phantom 3, DJI Ins pire 1 UAS training and currency requirem ents, that the PIC is able to safely operate the DJI Phantom 3, DJI Inspire 1 UAS in a m anner consistent w ith this

exem ption, including evasive and em ergency maneuvers and m aintaining appropriate distances from peop le, vessels, vehicles and structures. Specifically, the PIC m ust have accum ulated and logged, in a m anner consistent with 14 C.F.R. § 61.51(b), 25 hours of total tim e as a UAS rotorcraft pilot (with a m inim um of 5 hours of those hours as a UAS pilot ope rating the sam e make and m odel of UAS to be used for operations under the exem ption). In addition to the hour requirem ents, the PIC m ust

accom plish 3 takeoffs and landings in the preceding 90 days (for currency purposes). As in Exem ption Nos. 11062, 111 38, and 11153, prior docum ented flight experience**20 |**  Page

that was obtained in compliance with applicable regulations will ensure an equivalent level of safety during **EDWARD STANZA ’S**  proposed operations. The Adm inistrator has held that prior docum ented flight experience that was obtained in com pliance w ith applicable regulations would ensure safe operations, stating as follows: In Exem ption No. 11062, the FAA required that prior to co nducting operations for the purpose of m otion picture filming (or sim ilar operations), the PIC must have

accum ulated and logged, in a m anner consistent w ith 14 CFR 61.51(b), 25 hours of total tim e as a UAS rotorcraft pilot including at least 10 hours lo gged as a UAS pilot with a m ulti

- rotor UAS. Prior to operations under Exem ption No. 11062, the PIC m ust also have accum ulated and logged a minim um of 5 hours as a UAS pilot operating the sam e make and m odel of UAS to be used for operations under the

ex em ption. For clarification, the FAA considers these m inim um hour requirem ents to be inclusive rather than additive; i.e. 5 hours m ake and m odel tim e may be included in the 10 hours of multi

- rotor tim e and the 10 hours m ay be included in the total 25 hou rs of UAS rotorcraft tim e. In addition to the hour requirem ents, the PIC m ust

accom plish 3 takeoffs and landings in the preceding 90 days (for currency purposes). The FAA finds that at a minimum, the flight

- hour requirem ents in Exem ption No. 11062 are app ropriate to practice and build proficiency in the skills necessary to safely conduct the petitioner’s proposed operations. The FAA also finds that prior docum ented flight experience that was obtained in com pliance with applicable regulations would satisfy this requirem ent. Training, proficiency, and experience building flights can also be conducted under the grant of exemption to accom plish the required flight time. During training, proficiency, and experience

- building flights the PIC is required to operate the UA with appropriate distances in accordance with 14 C.F.R 91.119. Exem ption No. 11138 at page 15. Accordingly, **EDWARD STANZA** will ensure safe operations by not allowing any PIC to operate the DJI Phantom 3, DJI Inspire 1 UAS unless that PIC has dem onstrated, by meeting m inimum flight

- hour and currency requirem ents, that the PIC is able to safely operate the DJI Phantom 3, DJI Inspire 1 UAS in a m anner consistent with the exem ptio n, including evasive and emergency m aneuvers and m aintaining appropriate distances from people, vessels, vehicles and structures. **3. Reasons Why**

**A n Exemption From The Requirements Of Section 91.7(a)**  **Would Not A dv** **ersely A** **ffect Safety**

**.** The equivalent leve l of safety established by Section 91.7(a) will be maintained because prior to every flight, **EDWA RD STANZA**  will ensure that the DJI Phantom 3, DJI Inspire 1 UAS is in an airworthy condition based upon the UAS’s com pliance with its operating docum ents and as stated in the conditions and lim itations herein. Additionally, the FAA has previously granted relief from Section 91.7(a) specific to UAS, in circum stances sim ilar, in all m aterial respects, to those presented herein (e.g. Exem ption Nos. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 11112, 11136, 11138, 11150, 11153, 11156, 11157, 11158, 11159, 11160, 11161).**21 |**  Page

**4. Reasons Why**

**A n Exemption From The Requirements Of Section 91.121**  **Would Not A dv** **ersely A** **ffect Safety**

**.** The equivalent level of safety established by Section 91.121 will be maintained because the altitude inform ation of the DJI Phantom 3, DJI Inspire 1 UA w ill be provided to the PIC via GPS equipment and a radio communications telem etry data link, which downlinks from the UA to the GCS for active m onitoring of the flight path and altitude. This altitude inform ation, combined w ith **EDWARD STANZA ’S**  operation of the DJI Phantom 3, DJI Inspire 1 UA w ithin visual line of sight, at or below 400 feet AGL, w ill ensure a level of safety equivalent to Section 91.121. The altitude inform ation w ill be generated by GPS equipm ent installed onboard the aircraft. Prior to each flight, a zero altitude initiation point is autom atically established by the UASs at ground level. The FAA has previous ly granted relief from Section 91.121 specific to UAS, in circum stances similar, in all m aterial respects, to those presented herein (e.g. Exem ption Nos. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11112, 11136, 11138, 11150, 11153, 11156, 111 57, 11158, 11159, 11160, 11161). **5. Reasons Why**

**A n Exemption From The Requirements Of Section 91.151(b)**  **Would Not A dv** **ersely A** **ffect Safety**

**.** A grant of this exem ption would ensure an equivalent level of safety established by 14 C.F.R. Section 91.151(b) a s a result of (1) the technical specifications of the DJI Phantom 3, DJI Inspire 1 UAS; (2) the lim itations on the proposed flight operations; and (3) the location of the proposed flight operations. Accordingly, **EDWARD STANZA** will ensure that it will safel y operate the battery powered DJI Phantom 3, DJI Inspire 1 UA during daylight hours in VFR conditions, w ith enough battery power to fly for a total duration of 13.5 minutes to the first point of intended landing and, assum ing norm al cruising speed, to fly after that for at least 4.5 m inutes. Here, as in Exem ption No. 11109, the technical specifications of the DJI Phantom 3, DJI Inspire 1 UAS; the lim itations on the proposed flight operations; and the location of the proposed operations, will ensure an equ ivalent level of safety established by 14 C.F.R. Section 91.151(b). Furtherm ore, safety w ill be ensured as the DJI Phantom 3, DJI Inspire 1 UAS provide audible and visual warnings to the PIC at the GCS w hen the UAs experiences low battery voltage, the first warning occurring at approxim ately 33% remaining battery power, and again at approxim ately 10% rem aining battery power. At the critically low battery level, the DJI Phantom 3, DJI Inspire 1 UAS UAS w ill descend and land autom atically. Significantly, previous exem ptions granted by the FAA concerning Section 91.151 establish that safety is not adversely affected when the technical characteristics and operating lim itations of the UAS are considered. Relief has been granted for m anned aircraft to operate a t less than the m inimums prescribed in Section 91.151, including Exem ption Nos. 2689, 5745, and 10650. Moreover, the FAA has previously granted relief fro m Section 91.151 specific to UAS, in circumstances sim ilar, in all material respects, to those present ed herein (e.g. Exem ption Nos. 8811, 10808, 10673, 11042, 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 11136, 11138, 11150, 11153, 11156, 11157, 11158, 11159, 11160, 11161).**22 |**  Page

**6. Reasons Why**

**A n Exemption From The Requirements Of Sections**  **91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), And 91.417(a) & (b) Would Not A** **dversely**

**A ffect Safety** 

**.** In seeking this exem ption, **EDWA RD STANZA**  subm its that the equivalent level of safety w ith regard to the regulatory m aintenance and alteration requirements established by Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b) w ill be m et because **EDWARD STANZA** will use trained technicians to perform maintenance

, alterations, or preventive m aintenance on the UAS using the m ethods, techniques, and practices prescribed in the operating docum ents (i.e., Monthly Maintenance Log, and DJI Phantom 3, DJI Inspire 1 Instruction Manual). Furtherm ore, **EDWA RD STANZA**  will doc um ent and maintain all m aintenance records for the DJI Phantom 3, DJI Inspire 1 UAS. Since the DJI Phantom 3, DJI Inspire 1 UAS w ill be inspected as prescribed by the operating docum ents, **EDW ARD STANZA**  will maintain the equivalent level of safety establ ished by Sections 91.405(a), 91.409(a)(1), and 91.409(a)(2). A copy of the DJI Phantom 3, DJI Inspire 1 User Manual is attached hereto as Exhibit B; a copy of the DJI Phantom 3, DJI Inspire 1 UAS Maintenance LOG is attached hereto as Exhibit C. Likewise, the exem ption sought will not adversely affect safety because **EDWA RD STANZA**  will use trained technicians to perform m aintenance, alterations or preventive maintenance on the UAS using the m ethods, techniques, and practices prescribed by the operating doc um ents. Furtherm ore, the exemption sought would m aintain an equivalent level of safety established by Sections 91.407, 91.417(a) and 91.417(b), because all maintenance of the DJI Phantom 3, DJI Inspire 1 UAS will be perform ed by trained technicians. Main tenance will be docum ented and m aintained utilizing the m onthly m aintenance log. Significantly, previous exem ptions granted by the FAA concerning Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b) establish that safety is not ad versely affected when the technical characteristics and operating lim itations of the UAS are considered. In consideration of **EDW ARD STANZA’**  s proposed operating lim itations, the operating docum ents, and the technical aspects of the DJI Phantom 3, DJI Insp ire 1 UAS, **EDWA RD**  **STANZA** submits that safety w ill not be adversely affected by granting exem ption from 14 C.F.R. Sections 91.405(a), 91.407(a)(1) and (a)(2), 91.409(a)(2), and 91.417(a) and (b). The FAA has previously granted relief specific to UAS in circum stances sim ilar, in all material respects, to those presented herein (e.g. Exem ption Nos. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 11112, 11136, 11138, 11150, 11153, 11156, 11157, 11158, 11159, 11160, 11161). **7. The FAA**

**M ay**  **Prescribe A ny** 

**Other Conditions F or Safe Operation.**  In accordance with Section 333 of the FAA Modernization and Reform Act of 2012 (FMRA) and 14 C.F.R. § 21.16 entitled Special Conditions, **EDWA RD STANZA**  requests that the FAA prescribe special conditions for the intended operation of the DJI Phantom 3, DJI Inspire 1 UAS, w hich contain such safety standards that the Adm inistrator finds**23 |**  Page

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), 91.12 1, 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 perm it safe operation of the UAs for the lim ited purpose of conducting aerial video and photography over certain areas of the United States for com pensation or hire. FMRA Section 333 sets forth the requirem ents for considering whether a UAS w ill create a hazard to users of the NAS or the public, or otherwise pose a threat to national security; and further, provides the authority for such UAS to op erate without airworthiness certification in accordance with any requirem ents that must be established for the safe operation of the UAS in the NAS. Likewise, the Adm inistrator m ay prescribe special conditions pursuant to 14 C.F.R. § 21.16, for operation of the DJI Phantom 3, DJI Inspire 1 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 Conditi ons, states the following: If the FAA finds that the airworthiness regulations of this subchapter do not contain adequate or appropriate safety standards for an aircraft, aircraft engine, or propeller because of a novel or unusual design feature of the ai rcraft, aircraft engine or propeller, he prescribes special conditions and am endm ents thereto for the product. The special conditions are issued in accordance with Part 11 of this chapter and contain such safety standards for the aircraft, aircraft engine or propeller as the FAA finds necessary to establish a level of safety equivalent to that established in the regulations. See 14 C.F.R. § 21.16. Therefore, in accordance w ith FMRA Section 333 and 14 C.F.R. § 21.16, the FAA may prescribe special conditions for Edward Stanza’s intended operation of the DJI Phantom 3, DJI Inspire 1 UAS, which contain such safety standards that the Adm inistrator 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)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b). **F. A Summary That Can Be Published In The Federal Register, stating: The Rules**  **From Which E**  **DWA RD STANZA**  **Seeks Exemption: EDWA**  **RD STANZA** seeks exemption from the requirements of 14 C.F.R Sections 61.113(a)&(b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b). **A Brief Description Of The Nature Of The Exemption**  **EDWA RD STANZA**  **Seeks:** This exemption will permit **EDWA RD STANZA**  to commercially operate an Unmanned Aircraft System (UAS) for the purpose of conducting aerial video and photography over certain areas of the United States.**24 |**  Page

**G. A ny**  **A dditional I**  **nformation, Views, Or Arguments Available To Support EDWA**  **RD STANZA** **’S Request.**  This Petition is m ade pursuant to the FAA Modernization and Reform Act of 2012 (FMRA) Section 333, which directs the Secretary of Transportation to determ ine if certain UAS m ay operate safely in the NAS. As such, **EDWA RD STANZA** **’S** request for exem ption m ay be granted pursuant to the authority of FMRA Section 333 and 14 C.F.R. Part 11, as set forth above. FMRA Section 333 sets forth the requirem ents for considering whether a UAS w i ll create a hazard to users of the NAS or the public, or otherw ise pose a threat to national security; and further, provides the authority for such UAS to operate without airworthiness certification. As discussed in detail above, **EDWA RD STANZA**  will operate the DJI Phantom 3, DJI Inspire 1 UAS safely in the NAS, w ithout creating a hazard to users of the NAS, or the public, or otherwise pose a threat to national security. **CONCLUSION** As set forth herein, **EDWA RD STANZA**  seeks an exem ption pursuant to 14 C.F.R. § 11.61 and Section 333 of the FAA Modernization and Reform Act of 2012 (FMRA), which will perm it safe operation of the DJI Phantom 3, DJI Inspire 1 UAS commercially, without an airworthiness certificate, for the lim ited purpose of conducti ng aerial video and photography over certain areas of the United States. By granting this Petition, the FAA Adm inistrator w ill be fulfilling the Congressional m andate of the FAA Modernization and Reform Act of 2012, while also advancing the interests of the public, by allowing **EDWA RD STANZA**  to safely, efficiently, and econom ically operate the DJI Phantom 3, DJI Inspire 1 UAS commercially within the NAS. **WHEREFORE** , in accordance with the Federal Aviation Regulations and the FAA Modernization and Reform Act of 2012, Section 333, **EDWA RD STANZA**  respectfully requests that the Adm inistrator grant this Petition for an exem ption from the requirem ents of 14 C.F.R Sections 61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2 ), and 91.417(a) & (b), and perm it **EDWA RD STANZA**  to operate the DJI Phantom 3, DJI Inspire 1 UAS commercially for the purpose of conducting aerial video and photography over certain areas of the United States. Dated: September 11 , 2015 Respectfully subm itted, **EDWA RD STANZA** 

_________________________ Edward Stanza 1954 Argyle Ave. #D Los Angeles, CA 90068

Tel: (409) 599

- 9846 edwardstanza@yahoo.com**25 |**  Page

Appendices: A

– DJI Phantom 3 Specifications Data Sheet B

– DJI Inspire 1 Specifications Data Sheet C

– DJI Phantom 3 Manufacturer’s User Manual D

– DJI Inspire 1 Manufacturer’s User Manual E

– Monthly Maintenance Log **APPENDIX**

**– A**  **DJI Phantom 3 TECHNICA L SPECIFICATIONS**  **EDWA RD STANZA**  only utilizes safe and reliable UASs. DJI is an industry leader in sm all UAS production. DJI UASs are loaded with ground breaking software enabling the user to set param eters w hich will not allow flight into controlled airspace. Parameters can also be set to lim it flight to no higher than a predeterm ined and set altitud e as well as lim it flight to a predeterm ined and set distance. In addition, DJI software provides real

- tim e altitude and location inform ation to the PIC via the linked monitor (sm art phone/tablet devices) Aircraft We ight (including battery and propelle rs) 1280 g Diagonal size (including propellers) 590 mm Max Ascent Speed 5 m/s Max Descent Speed 3 m/s Hover Accuracy Vertical: +/

- 0.1 m (w hen Vision Positioning is active) or +/

- 0.5 m Horizontal: +/

- 1.5 m Max Speed 16 m/s (ATTI mode, no wind) Max Altitude Above Sea Level 6000 m Operating Tem perature 0°C to 40°C GPS Mode GPS/GLONASS Cam era Sensor Sony EXMOR 1/2.3” Effective pixels: 12.4 M (total pixels: 12.76 M) Lens FOV 94° 20 mm (35 mm form at equivalent) f/2.8, focus at ∞ ISO Range 100

- 3 200 (video) 100

- 1600 (photo) Shutter Speed 8s

- 1/8000s Im age Max Size 4000 x 3000 Still Photography Modes •Single Shot •Burst Shooting: 3/5/7 shots •Auto Exposure Bracketing (AEB): 3/5 •Bracketed Fram es at 0.7EV Bias**26 |**  Page

•Tim e

- lapse Video Recording Modes Phantom 3 Professional •UHD: 4096x2160p 24/25, 3840x2160p 24/25/30 •FHD: 1920x1080p 24/25/30/48/50/60 •HD: 1280x720p 24/25/30/48/50/60 Phantom 3 Advanced •FHD: 1920x1080p 24/25/30/48/50/60 •HD: 1280x720p 24/25/30/48/50/60 Supported SD Card Ty pes Micro SD Max capacity: 64 GB. Class 10 or UHS

- 1 rating required Max Bitrate of Video Storage Phantom 3 Professional 60 Mbps Phantom 3 Advanced 40 Mbps Supported File Form ats •FAT32/exFAT •Photo: JPEG, DNG •Video: MP4, MOV (MPEG

- 4 AVC/H.264) Operating Tem perature 0°C to 40°C Gim bal Controllable Range Pitch

- 90° to +30° Stabilization 3

- axis (pitch, roll, yaw) Vision Positioning Max Velocity Less than 8 m/s (w hen 2 m above ground) Altitude Range 30 cm

- 300 cm Operating Range 30 cm

- 300 cm Operating Environm ent Surface w ith clear pattern and adequate lighting (Lux > 15) Rem ote Controller Operating Frequency 2.400 GHz

- 2.483 GHz Max Distance 2000m (outdoors and unobstructed) Video Output Port USB Operating Tem perature 0°C

- 40°C Battery 6000 m Ah LiPo 2S Mobile Device Holder For tablet or phone Receiver Sensitivity (1%PER)

- 101 dBm ±2 dBm Transm itter Power (EIRP) •FCC: 20 dBm**27 |**  Page

•CE: 16 dBm Wo rking Voltage 1.2 A @7.4 V Battery Charger Voltage 17.4 V Rated Power Phantom 3 Professional •100 W Phantom 3 Advanced •57 W Intelligent Flight Battery Capacity 4480 m Ah Voltage 15.2 V Battery Type LiPo 4S Energy 68 W h Net W eight 365 g Max Flight Tim e Approxim ately 23 m inutes Operating Tem perature

- 10°C to 40°C M ax Charging Power 100 W App / Live View Mobile App DJI Pilot EIRP 100mW Live View W orking Frequency 2.4GHz ISM Live View Quality 720P @ 30fps (depending on conditions and m obile device) Latency 220m s (depending on conditions and mobile device) Requi red Operating System s •iOS 8.0 or later •Android 4.1.2 or later Recomm ended Devices •iOS: iPhone 5s, iPhone 6, iPhone 6 Plus, iPad Air, iPad Air W i

- Fi + Cellular, iPad m ini 2, iPad m ini 2 W i

- Fi + Cellular, iPad Air 2, iPad Air 2 W i

- Fi + Cellular, iPad m ini 3, and iPad mini 3 W i

- Fi + Cellular. This app is optim ized for iPhone 5s, iPhone 6, and iPhone 6 Plus •Android: Sam sung S5, Note 3, Sony Xperia Z3, Google Nexus 7 II, Google Nexus 9, Mi 3, Nubia Z7 m ini **APPENDIX**

**– B**  **DJI Inspire 1 TECHNICAL SPECIFICATIONS EDWA**  **RD STANZA** only utilizes safe and reliable UASs. DJI is an industry leader in sm all UAS production. DJI UASs are loaded with ground breaking software enabling the user to set param eters w hich will not allow flight into controlled airspace. Parameters can also be set to lim it flight to no higher than a predeterm ined and set altitu de as well as lim it flight to a predeterm ined and set distance. In addition, DJI software provides real

- tim e altitude and location inform ation to the PIC via the linked monitor (sm art phone/tablet devices)**28 |**  Page

Aircraft Model T600 We ight (Battery Included ) 2935 g Hovering Accuracy (GPS m ode) Vertical: 0.5 m Horizontal: 2.5 m Max Angular Velocity Pitch: 300°/s Yaw: 150°/s Max Tilt Angle 35° Max Ascent Speed 5 m/s Max Descent Speed 4 m/s Max Speed 22 m/s (ATTI mode, no wind) Max Flight Altitude 4500 m Max W ind Speed Resistance 10 m/s Max Flight Tim e Approxim ately 18 m inutes Motor Model DJI 3510 Propeller Model DJI 1345 Indoor Hovering Enabled by default Operating Tem perature Range

- 10° to 40° C Diagonal Distance 559 to 581 mm Dim ensions 438x451x301 mm Gim bal Model ZENMUSE X3 Output Power (with camera) Static: 9 W In Motion: 11 W Operating Current Station: 750 m A Motion: 900 m A Angular Vibration Range ±0.03° Mounting Detachable Controllable Range Pitch:

- 90° to +30° Pa n: ±320° Mechanical Range Pitch:

- 125° to +45° Pan: ±330° Max Controllable Speed Pitch: 120°/s Pan: 180°/s Cam era Nam e X3 Model FC350 Total Pixels 12.76M Effective Pixels 12.4M Im age Max Size 4000x3000 ISO Range 100

- 3200 (video) 100

- 1600 (photo ) Electronic Shutter Speed 8s

- 1/8000s**29 |**  Page

FOV (Field of View ) 94° CMOS Sony EXMOR 1/2.3” Lens 20mm (35mm format equivalent)f/2.8 focus at ∞ 9 Elem ents in 9 groups Anti

- distortion Still Photography Modes Single shoot Burst shooting: 3/5/7 frames Auto Exposure Bracketing (AEB): 3/5 bracketed fram es at 0.7EV Bias Tim e

- lapse Video Recording Modes UHD (4K): 4096x2160p24/25, 3840x2160p24/25/30 FHD: 1920x1080p24/25/30/48/50/60 HD: 1280x720p24/25/30/48/50/60 Max Bitrate of Video Storage 60 Mbps Su pported File Form ats FAT32/exFAT Photo: JPEG, DNG Video: MP4/MOV (MPEG

- 4 AVC/H.264) Supported SD Card Types Micro SD Max capacity: 64 GB. Class 10 or UHS

- 1 rating required. Operating Tem perature Range 0° to 40° C Rem ote Controller Nam e C1 Operati ng Frequency 5.725~5.825 GHz 2.400~2.483 GHz Transm itting Distance (outdoor and unobstructed) 2 km EIRP 10dBm @900m , 13dBm @5.8G, 20dBm @2.4G Video Output Port USB, m ini

- HDMI Power Supply Built

- in battery Charging DJI charger Dual User Capability Host

- and

- Slave connection Mobile Device Holder Tablet or Phone Max Mobile Device W idth 170mm Output Power 9 W Operating Tem perature Range

- 10° to 40° C Storage Tem perature Range Less than 3 m onths:

- 20° to 45° C More than 3 m onth s: 22° to 28° C Charging Tem perature Range 0

- 40° C Battery 6000 m Ah LiPo 2S Charger Model A14

- 100P1A Voltage 26.3 V Rated Power 100 W**30 |**  Page

Battery (Standard) Nam e Intelligent Flight Battery Model TB47 Capacity 4500 m Ah Voltage 22.2 V Battery Type LiPo 6S High voltage battery Energy 99.9 W h Net W eight 570 g Operating Tem perature Range

- 10° to 40° C Storage Tem perature Range Less than 3 m onths:

- 20° to 45° C More than 3 m onths: 22° C to 28° C Charging Tem perature Range 0° to 40° C Max Charging Power 180 W Battery (Optional) Nam e Intelligent Flight Battery Model TB48 Capacity 5700 m Ah Voltage 22.8 V Battery Type LiPo 6S Energy 129.96 W h Net W eight 670 g Operating Tem perature Range

- 10° to 40° C Storage Tem perature Range Less than 3 m onths:

- 20 to 45° C More than 3 m onths: 22° to 28° C Charging Tem perature Range 0° to 40° C Max Charging Power 180 W Vision Positioning Velocity Range Below 8 m/s (2 m above ground) Altitude Range 5

- 500 cm Operating Environm ent Brightly lit (lux > 15) patterned surfaces Operating Range 0

- 250 cm App / Live View Mobile App DJI Pilot EIRP 100mW Live View W orking Frequency 2.4GHz ISM Live View Quality 720P @ 30fps (depending on conditions and m obile device) L atency 220m s (depending on conditions and mobile device) Required Operating System s •iOS 8.0 or later •Android 4.1.2 or later 

### MONTH:__________YEAR:__________UAS #DATE (ISSUE DISCOVERED)DATE (ISSUE CORRECTED)ISSUE DESCRIPTION & MAINTENANCE CONDUCTEDMAIN TENANCE PERFORMED BY: (PRINT & SIGN)SOFTWAREUPUPDATESAIRFRAMEENGINESCAMERALANDING
GEARVIBRATIONDAMPENINGOTHER:UAS MONTHLY MAINTENANCE LOG**31 |**  Page

Recomm ended Devices •iOS: iPhone 5s, iPhone 6, iPhone 6 Plus, iPad Air, iPad Air W i

- Fi + Cellular, iPad m ini 2, iPad m ini 2 W i

- Fi + Cellular, iPad Air 2, iPad Air 2 W i

- Fi + Cellular, iPad m ini 3, and iPad mini 3 W i

- Fi + Cellular. This app is optim ized for iPhone 5s, iPhone 6, and iPhone 6 Plus •Android: Sam sung S5, Note 3, Sony Xperia Z3, Google Nexus 7 II, Google Nexus 9, Mi 3, Nubia Z7 m ini **APPENDIX**

**– C**  http://www.dji.com/product/phantom

- 3/dow nload **APPENDIX**

**– D**  http://www.dji.com/product/inspire

- 1/download **APPENDIX**

**– E**