UNITED ST AT ES OF AMERI CA DEP AR TMENTOF TRANSPOR TA TI ON FEDERAL

A VI AT IO N ADMINISTRA TI ON WA SHI NGT ON, DC

Regulatory

Docket No. _______________

IN THE MA

TTER OF THE PETITION FOR EXEMPTI ON OF: IRONSIDES MOTION LLC

FOR AN EXEMPTION SEEKING RELIEF FROM THE REQUIREMENTS OF TITLE 14 OF THE CODE OF FEDERAL

REGULA

TI ONS SECTI ONS 61.1 13(a) & (b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), AND 91.417(a) & (b) CONCERNI NG COMMERCI AL OPERA TI ON OF DJ I PHANT OM 3 AND DJ I INSPI RE 1 UNMANNED AI RCRAFT SYSTEMS PURSUANT TO SECTION 333 OF THE F AA MODERNIZA

TI ON AND REFORM ACTOF 2012 (PUBLIC LA

W 1 12

- 95)

Submitted on July

13 , 2015

IRONSIDES MOTION LLC

www .I ronsidesMotion.com Kevin William Andrews 10657 CHERR

YBROOK CI RCLE HI GHLANDS RANCH, CO 80126 303

- 807

- 1972 kevin@denversteadicam.comTA BLE OF CONTENTS Page

GLOSSAR

Y OF ABBREVIA

TI ONS............................................................ .....................................................3

SUMMAR

Y.

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

IN TRODUCTION AND INTERESTS OF PETITIONER.................... ..................................4

BACKGROUND..................................................................................................................... 5

BASI S FOR PETITION........................................................................................................... 5

NAME AND ADDRESS OF PETITIONER................................................................6

THE SPECI FI C SECTIONS OF 14 C.F .R. FROM WHI CH IRONSIDES MOTION SEEKS EXEMPTI ON..........................................................7

THE EXTENT OF RELIEF AND THE REASON SEEKING THE RELIEF.........................9

THE REASONS WHY

GRANTING REQUEST WOUL D BE IN THE PUBLIC INTER EST.............................................................1 1

THE REASONS WHY

GRANTING THE EXEMPTI ON WOULD NOT ADVERSEL

Y A FFECTSAFETY

..............................................................................13

CONCL USION................... ....................................................................................................19GLOSSAR Y OF ABBREVIA

TI ONS

AGL Above Ground Level AOI Area of Interest AT C Air T

raf fic Control AT O Air T

raf fic Organization AV Aerial Ve hicle CFR Code of Federal Regulations COA Certificate of Authorization FA A Federal Av iation Administration FA R Federal Av iation Regulation GCS Ground Control Station GPS Global Positioning Sy stem LO L Lo ss of Link NAS National Airspace S ys tem NOT AM Notice to Airman PI C Pilot I n Command Section 333 F

AA Modernization and Reform Act of 2012 (FMRA) SO Safety

Observer SOP Standard Operating Procedures UA Unmanned Aircraft UAS Unmanned Aircraft Sy stem VFR Vi sual Flight Rules VLOS Vi sual L ine of Site VMC Vi sual Meteorological Conditions VTOL Ve rtical T akeof f and Landing DJI UA

V manufacturer ESC Electronic speed control FPV First Person V iew LI

- PO Li thium Poly mer battery RCV Radio Controlled vehicle**SUMMAR Y** 

IRONSIDES MOTION LLC seeks exemption from the requirements of 14 C.F .R §§ 61.1 13(a) & (b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b), to operate an Unmanned Aircraft Sy stem pursuant to Section 333 of the F AA Modernization and Reform Act of 2012 (FMRA). This exemption will permit IRONSIDES MOTION LLC to operate an Unmanned Aircraft Sy stem (UAS) for the commercial purpose of conducting aerial video and photograph y for Marketing, film sets, real estate photography , commercials, special events, wedding cinematograph y, and landscape over certain areas of the United States.

**INTRODUCTION AND INTERESTS OF**  **T HE PETITIONER** 

My name is Kevin William Andrews, and I am the owner of IR ONSIDES MOTION LLC. As a drone operator(pilot) w ith expertise and knowledge in all aspects of building programing and operating multiple ty

pes of UAS'S along with camera set up and operation. IRONSIDES MOTION LLC also provides clients with the highest qualit y digital content for use in their commercial, personal, and non

profit multimedia projects. Kevin Andrews has 1 5 ye ars of television experience and 20 years of radio controlled vehicle experience.

The objective of IR ONSIDES MOTION LLC’ s aerial video and photography operations is to provide high qua lity

imaging for a variet y of commercial, public, and residential uses . Kevin Andrews will also provide knowledge of UAS and promote safe UAS operations.**BACKGROUND**

Unmanned Aircraft Sy stems: DJIPhantom 3, DJ I Inspire 1 UASs IRONSIDES MOTION LLC seeks an exemption to operate DJ I systems for compensation or hire within the NAS. The DJ I Phantom 3 and DJI I nspire 1 are vertical takeof f and landing (VT OL) Unmanned Aircraft (UA) with a Ground Control Station (GCS) utilizing electro nic tablet or smart phone sy stems. The DJ I Phantom 3 has a maximum gross weight of approximately 2 pounds 14 ounces, while having a length of 16 inches width of 16 inches, height of 8 inches, and a maximum speed of approximately

29 knots. The DJ I Inspire 1 has a maximum gross weight of 6 pounds 7.5 ounces, a length of 17.3 inches, width of 17.7 inches, height of 1 1.8 inches, and a maximum speed of approximately

42 knots. The DJ I Phantom 3 and DJII nspire 1UAs are equipped with four main rotors; driven by L i thium Poly

mer battery

powered electric motors.

The DJ I Phantom 3 and DJII nspire 1 UAs that will be operated by Kevin Andrews will be registered in accordance with 49 U.S.C. 44103, Registration of Aircraft, as well as 14 C.F .R Part 47, Aircraft Registra tion, and marked in accordance with 14 C.F .R. Part 45, Identification and Registration Markings.

**BASIS FOR PETITION**

Petitioner
, Kevin William Andrews (IRONSIDES MOTI ON LL C) , pursuant to the provisions of the Federal Av iation Regulations (14 C.F .R. § 1 1.61) and the F AA Modernization and Reform Act of 2012 (FMRA), Section 333, Special Rules for Certain Unmanned Aircraft Sy stems, hereby petitions the Administrator to commercially operate the DJ I Phantom 3, DJII nspire 1 UASs in the National Airspace S ys tem (NAS), and for an exemption from the requirements of 14 C.F .R §§ 61.1 13(a) & (b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b).

In consideration of the speed, weight, size, and limited operating area associated with the unmanned aircraft and its operation of DJI Phantom 3 and DJ I Inspire 1 UASs meets the conditions of FMRA

Section 333 and therefore, will not require an airworthiness certificate in accordance with 14 C.F .R. Part 21, Subpart H.

Accordingly

, I RONSIDES MOTI ON LL C requests relief from Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b), as these sections set forth requirements for maintenance that only appl y to aircraft with an airworthiness certificate.

IRONSIDES MOTION LLC submits that the requested relief is proper since an equivalent level of safet y will be ensured. IRONSI DES MOTION LLC will use experienced personnel or technicians to perform maintenance, alterations, or preventive maintenance on the U ASs using the methods, techniques, and practices prescribed in the operating documents (i.e., Monthly Maintenance Log, and DJIPhantom 3 and DJ I Inspire 1 Instruction Manual). Furthermore, IR ONSI DES MOTION LLC will document and maintain all maintenance rec ords for the DJ I Phantom 3 and DJII nspire 1 UASs.

Relief from certain requirements of Section 61.1 13(a) and (b), entitled Private pilot privileges andlimitations: Pilot in command, is requested b y IR ONSIDES MOTION LLC to the extent necessary to

allow a Pilot in Command (PI C) 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 safel y operate the DJ I Phan tom 3 and DJII nspire 1 UASs in a manner consistent with this exemption, including evasive and emergency maneuvers and maintaining appropriate distances from people, vessels, vehicles and structures.

IRONSIDES MOTION LLC seeks relief from Section 91.7(a ), entitled Civil aircraft airworthiness, because the DJ I Phantom 3 and DJ I Inspire 1 UASs do not require an airworthiness certificate in accordance with 14 C.F .R. Part 21, Subpart H. As such, I RONSIDES MOTION LLC submits that they will ensure that the DJ I Phantom 3 and DJ I Inspire 1UASs are in an airworthy condition, prior to every flight, b y determining that the UASs are in compliance with the operating documents (i.e., Monthly Maintenance Log, and DJIPhantom 3 and DJ I Inspire 1 Instruction Manual), and that the aircraft are in a condition for safe flight.

IRONSIDES MOTION LLC also seeks an exemption from the requirements of Section 91.121, entitled Altimeter Settings, as the DJIPhantom 3 and DJ I Inspire 1 UAs will not have a t ypical barometric altim eter onboard. However, altitude information of the DJ I Phantom 3 and DJII nspire 1UAs will be provided to the PI C via Global Positioning Sy stem (GPS) equipment and radio communications telemetry data link, which downlinks from the UA to the GCS for active monitoring of the flight path. This altitude information, combined with I RONSIDES MOTION LLC’ s operation of the DJ I Phantom 3and DJ I Inspire 1 UASs within visual line of sight, at or below 500 feet AGL , will ensure a level of safet y equivalent to Section 9 1.121.

Additionally

, IRONSIDES MOTI ON LLC seeks an exemption from the requirements of Section 91.151(b), entitled Fuel requirements for flight in VFR conditions. I RONSIDES MOTION LLC submits that safety

will not be af

fected b y operation of the DJ I Phant om 3 and DJII nspire 1 UAs during day light hours in visual meteorological conditions (VMC) under visual flight rules (VFR), with enough battery

power to fly

for a total duration of approximately 15.5 minutes to the first point of intended landing and, assu ming normal cruising speed, to fl y after that for at least 4.5 minutes.

In accordance with 14 C.F .R. § 1 1.81, IRONSIDES MOTI ON LL C provides the following information in support of its petition for exemption:

**A. Name And**  **Addr ess Of**  **The Petitioner**

**.** The name and address of the Petitioner and point of contact is: Kevin William Andrews IRONSIDES MOTION LLC 10657 Cherry

brook Circle Highlands Ranch CO 80126 (303)

- 807

- 1972 Email: kevin@denversteadicam.com**B. The Specific Sections Of 14 C.F**  **.R. Fr om**  **Which** IR ONSIDES MOTION LL C **Seeks Exemption.**

1 IRONSIDES MOTION LLC **Seeks Exemption Fr om**  **T he Requir**  **ements Of Section 61.1 13(a)**  **And (b).**  2 Section 61.1 13, entitled Private pilot privileges and limitations: Pilot in c ommand, 3 4 subsections (a) and (b) prescribe the following, in relevant part: 5 (a) No person who holds a private pilot certificate may act as a pilot in command (PI C) of an aircraft that is carry ing passengers or propert y for compensation or hire; nor may that person, for compensation or hire, act as PI C of an aircraft. 6 (b) A private pilot may

, for compensation or hire, act as PIC of an aircraft in connection with any business or employ

ment if

— 7 The flight is onl y incidental to that business or employment ; and 8 (2) The aircraft does not carry passengers or property for compensation or hire. 9 10 **2.** IR ONSIDES MOTION LLC **Seeks Exemption Fr om**  **The Requir ements Of Section 91.7(a).**  11 Section 91.7, entitled Civil aircraft airworthiness, subsection (a), states the following: (a) No person may operate a civil aircraft unless it is in an airworthy condition. 12 13 **3.** IR ONSIDES MOTION LL C **Seeks Exemption Fr om**  **The Requir ements Of Section 91.121.** 

Section 91.121, entitled Altimeter settings, subsection (a), states the following, in part: (a) Each person operating an aircraft shall maintain the cruising altitude or flight level of that aircraft, as the case may be, b y reference to an altimeter that is set, when operating

-- 1 Below 18,000 feet MSL, to

-- 2 (i ) The current reported altimeter setting of a station along the route and within 100 nautical miles of the aircraft; 3 (ii) If there is no station within the area prescribed in paragraph (a)(1)(i) of this section, the current reported altimeter setting of an appropriate available station; or **4** (iii) I n the case of an aircraft not equipped with a radio, the elevation of the departure airport or an appropriate altimeter setting available before departure.

**4.** IR ONSIDES MOTION LLC **Seeks Exemption Fr om**  **The Requir ements Of Section**  **91.151(b).**

Section 91.151, entitled Fuel requirements for flight in VFR conditions, subsection (b), states the following: (b ) No person may begin a flight in a r otor craft under VFR conditions unless (considering wind and for

ecast weather conditions) ther e 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 IRONSIDES MOTION LLC **Seeks Exemptio n Fr**  **om T**  **he Requir ement Of Section 91.405(a).**  67 Section 91.405, entitled Maintenance required, subsection (a), states the following: Each owner or

operator of an aircraft

— 8 (a) Shall have that aircraft inspected as prescribed in subpart E of this part and shall between required inspections, except as provided in paragraph (c) of this section, have discrepancies repaired as prescribed in part 43 of this chapter[.] 9 **6.** IR ONSIDES MOTION LLC **Seeks Exemption Fr om**  **The Requir ements Of Section**  **91.407(a)(1** 6 Sect ion 91.407, entitled Operation after maintenance, preventive maintenance, rebuilding, or alteration, subsection (a)(1), states the following: 7 (a) No person may

operate any

aircraft that has undergone maintenance, preventive maintenance, rebuilding, or al teration unless

-- (1) Ithas been approved for return to service by a person authorized under § 43.7 of this chapter[.] 8 9 **7.** IR ONSIDES MOTION LLC **Seeks Exemption Fr om**  **The Requir ements Of Sections**  **91.409(a)(1) And 91.409(a)(2).**  10 Section 91.409, entitled Inspections, subsection (a), states the following: 11 (a) Except as provided in paragraph (c) of this section, no person may operate an aircraft unless, within the preceding 12 calendar months, it has had

-- 12 (1) An annual inspection in accordance with part 43 of this chapter and has been approved for return to service b y a person authorized by § 43.7 of this chapter; or 13 (2) An inspection for the issuance of an airworthiness certificate in accordance with part 21 of this chapter

. 14 15 **8.** IR ONSIDES MOTION LLC **Seeks Exemption Fr om**  **The Requir ements Of Sections 91.417(a)**  **And 91.417(b).** 16 Section 91.417, entitled Maintenance records, subsections (a) and (b), state the following: 17 (a) Except for work performed in accordance with §§ 91.41 1 and 9 1.413, each registered owner or operator shall keep the following records for the periods specified in paragraph (b) of this section: 18 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 of an aircraft. The records must include

-- 19 (i) A description (or reference to data acceptable to the Admini strator) of the work performed; and 20 (ii) The date of completion of the work performed; and 21 (iii) The signature, and certificate number of the person approving the aircraft for return to service. 22 Records containing the following information: 23 (i) The tot al time in service of the airframe, each engine, each propeller , and each rotor

. 24 (ii) The current status of life

- limited parts of each airframe, engine, propeller, rotor , and appliance. 25 (iii) The time since last overhaul of all items installed on the a ircraft which are required to be overhauled on a specified time basis. 26 (iv) The current inspection status of the aircraft, including the time since the last inspection required by the inspection program under which the aircraft and its appliances are mai ntained. 27 (v) The current status of applicable airworthiness directives (AD) and safety directives including, for each, the method of compliance, the AD or safety directive number and revision date. If the AD or safet y directive involves recurring action, the time and date when the next action is required. 28 (vi) Copies of the forms prescribed b y § 43.9(d) of this chapter for each major alteration to the airframe and currentl y installed engines, rotors, propellers, and appliances. 2930 (b) The owner or opera tor shall retain the following records for the periods prescribed:

31 (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 ye ar after the work is performed. 32 (2) The records specified in paragraph (a)(2) of this section shall be retained and transferred with the aircraft at the time the aircraft is sold. 33 (3) A list of defects furnished to a registered owner or operator under § 43.1 1 of this chapter shall be retained until the defects are repaired and the aircraft is approved for return to service. 34 **35 C. The Extent Of Relief**  IR ONSIDES MOTION LLC **Seeks And**  **The Reason** IR ONSIDES MOTION LLC **Seeks The Relief.**  36 **1. Extent Of Relief** IR ONSI DES MOTION LLC **Seeks And**  **The Reason** IRONSIDES MOTION LLC **Seeks Relief Fr om Section 61.1**  **13(a) And (b).**  37 Relief from Section 61.1 13(a) and (b) entitled Private pilot privileges and limitations: Pilot in command, is requested to the extent necessary to allow a PI C holding a private pil ot or higher level certificate, as well as a current and valid airman medical certificate, and who has met certain flight

- hour and currency requirements, to conduct the proposed UAS flight operations for compensation or hire. This relief is requested since the limitations set forth in Section 61.1 13(a) and (b) state that a private pilot may

, for compensation or hire, act as PIC of an aircraft in connection with any business or employ

ment if: (1) The flight is only incidental to that bu siness or employ ment; and (2) The aircraft does not carry passengers or propert y for compensation or hire. As set forth more full y below
, IR ONSIDES MOTION LLC submits that an equivalent level of safet y will be maintained because no PIC will be allowe d to operate the DJIPhantom 3 UAS or DJ I Inspire 1 UAS unless that PI C has met certain flight

- hour and currency requirements, demonstrating that the PIC is able to safel y operate either the DJ I Phantom 3 or DJ I Inspire 1 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
, IR ONSIDES MOTION LLC submits that all flights of the DJ I Phantom 3 and DJI Inspire 1 UASs, conducted by the PI C pursuant to the grant of this Petition: (1) will be incidental to IR ONSIDES MOTI ON LL C’ s business; and (2) will not carry passengers or propert y for compensation or hire.

2 **Extent Of Relief** IR ONSIDES MOTION LLC **Seeks And**  **The Reason** IR ONSIDES MOTION LLC **Seeks Relief Fr om Section 91.7(a).**  3 Relief from Section 91.7(a) entitled Civil aircraft airworthiness, is requested to the extent required to allow IRONSI DES MOT ION LLC to determine that the DJIPhantom 3 and DJI Inspire 1 UASs are in airworthy condition prior to every

flight by ensuring that the UAS is in compliance with the operating documents (i.e., IR ONSIDES MOTION LLC Aerial Operations Manual, Monthly

Main tenance Log, and DJ I Phantom 3 and DJII nspire 1 Instruction Manual). IRONSIDES MOTION LLC seeks the requested relief because the DJ I Phantom 3 and DJI Inspire 1 UASs do not require an airworthiness certificate in accordance with 14 C.F .R. Part 21, Subpart H. Therefore, IR ONSIDES MOTION LLC will ensure that the DJI Phantom 3 and DJ I Inspire 1 UASs are in airworthy condition based upon its compliance with the operating documents (i.e., Monthly Maintenance Lo g, and DJIPhantom 3 and DJ I Inspire 1 Instr uction Manual) prior to every

flight, and further , determine that the aircraft are in condition for safe flight, as stated in the conditions and limitations below

.**3. Extent Of Relief** IR ONSI DES MOTION LLC **Seeks And**  **The Reason** IRONSIDES

MOTION LLC **Seek s Relief**  **Fr om**  **Section 91.121.**

Relief from Section 91.121, entitled Altimeter settings, may be required to allow flight operations of the DJ I Phantom 3 and DJII nspire 1 UASs, which utilize a barometric pressure

sensor , GPS equipment, and a radio co mmunications telemetry data link to downlink altitude information from the UA to the PI C at the ground control station (GCS). Since the F AA requires that any altitude information concerning UAS operations be reported to air traf fic control (A

TC) in feet above ground level (AGL), IRONSIDES MOTION LLC seeks the requested relief because the DJ I Phantom 3 and DJII nspire 1 UA’s altimeter may be set on the ground to zero feet AGL, rather than the local barometric pressure or field altitude, before each flig ht.

Considering the limited altitude of the proposed operations, relief from 14 CFR 91.121 is sought to the extent necessary to compl y with the applicable conditions and limitations stated below

. As more full y set forth herein, an equivalent level of safet y will be maintained since the DJIPhantom 3 and DJ I Inspire 1 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 pro vides the PI C with altitude information of the UA on the heads

- up d isplay of the GCS. **4. Extent Of Relief** IR ONSI DES MOTION LLC **Seeks And**  **The Reason** IRONSIDES MOTION LLC **Seeks Relief Fr om**  **Section 91.151(b).**

Relief from Section 91.151(b) entitled Fu el requirements for flight in VFR conditions, is requested to the extent required to allow flights of the battery powered DJ I Phantom 3 and DJI Inspire 1 UAs during daylight hours in visual meteorological conditions (VMC), under visual flight rules (VFR ), for a total duration of 15.5 minutes to the first point of intended landing and, assuming normal cruising speed, to fl y after that for at least 4.5 minutes. IRONSI DES MOTION LLC seeks the requested relief because without an exemption from Section 91.15 1(b), the flight time duration of the battery powered DJ I Phantom 3 and DJI I nspire 1 UAs will severel y constrain the practicality of any aerial video or still photo flight operations that IRONSIDES MOTION LLC proposes to conduct pursuant to this Petiti on. Significantly

, as set forth below, the technical specifications of the DJ I Phantom 3 and DJII nspire 1 UASs, the DJIPhantom 3 and DJ I Inspire 1 operating documents, and IRONSIDES MOTION LLC proposed operating limitations, ensure that IRONSI DES MOT ION LLC will safely operate the battery powered DJ I Phantom 3 and DJII nspire 1 UAs during day light hours in visual meteorological conditions (VMC), under visual flight rules (VFR), with enough battery power to fl y for a total duration of 13.5 minutes t o the first point of intended landing and, assuming normal cruising speed, to fl y after that for at least 4.5 minutes.

5 **5.Extent Of Relief** IR ONSI DES MOTION LLC **Seeks And**  **The Reason** IRONSIDES MOTION LLC **Seeks Relief Fr om Sections 91.405(a), 91.407(a)(1),**  **91.409(a)(1) & (a)(2), And 91.417(a) &**  **(b).**

Since Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b) onl y apply to aircraft with an airworthiness certificate, IRONSIDES MOTION LLC requests relief from these Sections because the DJIPhantom 3 and DJ I In spire 1 UASs do not require airworthiness certificates. As set forth more fully below, the DJI Phantom 3 and DJ I Inspire 1 UASs meet the conditions of FMRA

Section 333 for operation without an airworthiness certificate. Accor dingl y IRONSIDES MOTI ON LL C will use trained technicians to perform maintenance, alterations, or preventive maintenance on the UASs using the methods, techniques, and practices prescribed in the UAS operating documents (i.e., IR ONSIDES MOTION LLC AerialOperations Manual, Monthly Maintenance Log, and DJIPhantom 3 and DJII nspire 1 Instruction Manual). Furthermore, IRONSIDES MOTION LLC will document and maintain all maintenance records for the DJ I Phantom 3 and DJII nspire 1 UASs.

D **The Reasons Why G**  **ranting** IR ONSIDES MOTION LL C **Request W ould Be In**  **The Public Inter**  **est; That Is, How It**  **Wo uld Benefit**  **The Public As**  **A Whole.**  DI Granting the present Petition will further the public interest b y allowing IR ONSIDES MOTION LLC to safely

, ef ficiently , and econom ically

perform aerial video and photography of construction sites, real estate, and landscape over certain areas of the United States. Additionally

, use of the DJIPhantom 3 and DJ I Inspire 1 UASs will decrease congestion of the NAS, reduce pollution , crashes and accidents caused b y pilot error and provide significant benefits to the economy . Notabl y, the benefits of IRONSIDES MOTION LLC proposed operation of the DJ I Phantom 3 and DJII nspire 1 UASs will be realized without implicating any

privac y issues. **1. The Public Will Benefit Fr om**  **Decr eased Congestion Of**  **The NAS.** The DJ I Phantom 3 and DJII nspire 1 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 of manned aircraft needed to perform aerial acquisitions, an exemption allowing the use of a DJ I Phantom 3 or DJII nspire 1 UAS would reduce the amount of manned aircraft in the NAS, reduce noise and air pollution, as well as increase the safety of life and property

in the air and on the ground. Furthermore, b y reducing the number of manned aircraft operating in the NAS, congestion around airports caused b y arriving and departing aircraft will be reduced. The DJIPhantom 3 and DJ I Inspire 1 UAs do not require an airport to takeoff or land. L ikewise, a reduction of manned aircraft conducting aerial video and photograph y missions would result in fewer aircraft that must be handled b y air traffic control durin g the ground, takeof f, departure, arrival, and landing phases of flight operations. **2. The Public Will Benefit Fr om**  **The Safety And Efficiency Of**  **The DJI Phantom 3 and DJI Inspir**  **e 1 UASs.** Conducting aerial acquisitions with the DJIPhantom 3 and DJ I Inspire 1 UASs, instead of manned aircraft, will greatl y benefit the public by drasticall y reducing the levels of air and noise pollution generated during traditional aerial video and still ph otography flight operations. By using battery

power and electric motors, the DJIPhantom 3 and DJ I Inspire 1 UASs produce no air pollution, and is the most viable environmentally conscious alternative to the cabin class, six cy linder internal combustion engine aircraft that are t ypically utilized for aerial video and photography

, while burning approximately 20

- 30 gallons per hour of leaded aviation fuel. The DJIPhantom 3 and DJ I Inspire 1 UAs, while reducing the carbon footprint of aerial acquisition s, also eliminates noise pollution, as the UAs are propelled b y battery powered electric motors, rather than an internal combustion engine. By using the DJ I Phantom 3 and DJ I Inspire 1 UASs to perform aerial acquisitions, the substantial risk to life and propert y in the air and on the ground, which is usually associated with traditional manned aircraft flight operations, will be substantially reduced or completely eliminated. Aside from the lack of flight crew members located onboard the aircraft, t he DJ I Phantom 3 and DJII nspire 1 UAs (weighing approximately 2 pounds 14 ounces and 6 pounds 7.5 ounces respectively

, at their maximum gross weights with lengths of 16 inches and 17.3 inches respectively

, widths of 16 inches and 17.7 inches respective ly , and with no fuel on board), has less ph ys ical potential for collateral damage to life and propert y on the ground, and in the air, compared to the manned aircraft that typically conduct similar operations (weighingapproximately 6,000 pounds with a wingspan of approximately 42 feet, a length of 34 feet, and a fuel capacit y of 180 gallons).

**3. Performing Aerial**  **Vi deo and Photography Operations**  **Wi th**  **The DJI Phantom 3 and DJI Inspir**  **e 1 UASs Wi**  **ll Benefit The Economy**

**.** In addition to being s afe and efficient, the DJ I Phantom 3 and DJII nspire 1 UASs are also an economical alternative to using manned aircraft to conduct similar aerial operations. As such, operation of the DJI Phantom 3 and DJ I Inspire 1 UASs will allow United States based

c ompanies, like IRONSIDES MOTION LLC , to remain competitive and contribute to growth of the U.S. economy

. Specifically

, with the rising cost of aviation fuel and the Environmental Protection Agency

(“EP A”) regulatory

actions phasing out leaded aviation fu els, U.S. owned and operated companies must adopt new and alternative technology in order to remain competitive. Operating the battery

powered DJ I Phantom 3 and DJII nspire 1 UASs is one such technology that not only

allows companies greater operational flexibility compared to manned aircraft, but provides such flexibility

without the high operational cost of a traditional manned aircraft. By operating the DJ I Phantom 3 and DJ I Inspire 1 UASs, companies such as IRONSIDES MOTION LLC , can remain comp etitive and profitable, and therefore, provide greater job stability

to employ ees and contractors, which will ultimately contribute to growth of the U.S. economy

. Improved financial performance of U.S. companies, through commercial use of the DJIPhanto m 3 and DJ I Inspire 1 UASs, provides a stable workforce that increases consumer spending; improves local, state, and federal tax revenues; and allows companies to invest in research and development in order to remain competitive both in the United States and abroad. **4 Ther**  **e Ar**  **e No Privacy Issues. 5**  Similar to the manned aerial acquisition flight operations that have been conducted for decades, IR ONSIDES MOTION LLC proposed operation of the DJ I Phantom 3 and DJ I Inspire 1 UASs will not implicate any pri vacy issues. Specifically

, the DJ I Phantom 3 and DJ I Inspire 1 UASs will be operated only in compliance with operating documents (i.e., IRONSIDES MOTION LLC Aerial Operations Manual, Monthly Maintenance Log, and DJIPhantom 3 and DJI Inspire 1 Instructio n Manual) which requires property owner involvement as well as local law enforcement notification, and in accordance with the Federal Av iation Regulations, including the minimum altitude requirements of 14 C.F .R. § 91.1 19.

**E. The Reasons**  **Why G ranting**  **The Exemption W ould Not**  **Adversely Affect Safety**  **, Or How**  **The Exemption W ould Pr**  **ovide A**  **Level Of Safety At Least Equal**  **To T**  **hat Pr ovided**  **By The Rule Fr**  **om Which**  IR ONSIDES MOTION LLC **Seeks Exemption.**

**1 Reasons Why The DJI Phantom 3 and DJI Inspir**  **e 1 UAs Meet The Conditions Of The F**  **AA Modernization and Reform**  **Act of 2012 (FMRA) Section 333. 2**  In consideration of the size, weight, speed, and limited operating area associated with the unmanned aircraft and its operation, IR ONSIDES MOTION LLC operation of the DJ IPhantom 3 and DJ I Inspire 1 UASs meet the conditions of FMRA Section 333, and will not require an airworthiness certificate in accordance with 14 C.F .R. Part 21, Subpart H. Section 333 provides authority

for a UAS to operate without airwort hiness certification and sets forth requirements for considering whether a UAS will create a hazard to users of the NAS or the public, or otherwise pose a threat to national security . Specifically

, FMRA Section 333 states the following, in part: (a) In General.

-- Notwithstanding an y other requirement of this subtitle, and not later than 180 day s after the date of enactment of this Act, the Secretary of Tr ansportation shall determine if certain unmanned aircraft sy stems may operate safely

in the nati onal airspace sy stem before completion of the plan and rulemaking required by section 332 of this Act or the guidance required b y section 334 of this Act. (b) Assessment of Unmanned Aircraft Sy stems.

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

-- (1) which t ypes of unmanned aircraft s ys tems, if any , as a result of their size, weight, speed, operational capability , proximity

to airports and populated areas, and operation within visual line of si ght do not create a hazard to users of the national airspace s ys tem or the public or pose a threat to national securit y; and whether a certificate of waiver, certificate of authorization, or airworthiness certification under section 44704 of title 49, Un ited States Code, is required for the operation of unmanned aircraft sy stems identified under paragraph (1). (c) Requirements for Safe Operation.

-- If the Secretary determines under this section that certain unmanned aircraft sy stems may operate safely

in the national airspace s ys tem, the Secretary shall establish requirements for the safe operation of such aircraft sy stems in the national airspace s ys tem. In seeking this exemption, IR ONSIDES MO TI ON LLC submits that the DJIPhantom 3 and DJII nspire 1 UASs can operate safel y in the NAS pursuant to FMRA Section 333, as demonstrated by : (a) the characteristics of the DJ I Phantom 3 and DJII nspire 1 UASs; (b) the pilot certification requirement; and (c) the specific operating limitations. **a. The Specifications Of The DJI Phantom 3 and DJI Inspir e 1 UASs Demonstrate**  **Its Safe Characteristics.** The DJ I Phantom 3 and DJII nspire 1 UASs do not create a hazard to users of the NAS or the publi c, or otherwise pose a threat to national security considering its size, weight, speed, and operational capability

. **i. Te**  **chnical Specifications Of The DJI Phantom 3 and DJI Inspir**  **e 1 UASs.** The technical specifications of the DJ I Phantom 3 and DJ I Inspire 1 UASs are set forth b y the DJIPhantom 3 and DJ I Inspire 1 Specifications and Data Sheet, attached hereto as Exhibit A and B. **ii. The DJI Phantom 3 and DJI Inspir**  **e 1 UASs Autonomous Flight**  **And Navigation Modes Enable**  **The UASs T o Remain Wit**  **hin A**  **Defined Operational Ar**  **ea.** The DJ I Phantom 3 and DJII nspire 1 UASs may be operated in both manual and fully autonomous flight modes. A complete description of the flight and navigational modes of the DJIPhantom 3 and DJ I Inspire 1 UASs is prov ided at pages 25

- 35 of the DJIPhantom 3 and pages 12

- 16 and 45

- 50 of the DJ I Inspire 1 User Manuals, attached hereto as Exhibit C and D. **iii. The DJI Phantom 3 and DJI Inspir**  **e 1 UASs Are Designed For**  **Automatic Return T**  **o Home Point Or**

**Hover In**  **Th e Event Of Loss Of**  **The Contr ol Link Or**  **Navigation.** When the Control L ink is lost, the DJIPhantom 3 and DJ I Inspire 1 UAs will remain stationary
, in flight, for 3 seconds or more. If, after 3 seconds, the DJ I Phantom 3 and DJII nspire 1 UAs do not reacquire control link data from the GCS, the UAs will assume that the Control L ink is lostand the UAs will return to the home position (i.e., failsafe mode) via GPS, and will descend to

the takeoff position and shutdown. A complete description of the Failsafe Functions of the DJ I Phantom 3 UAS are set forth at pages 27 through 29 and for the DJ I Inspire 1 at pages 13 through 15 of the DJ I Phantom 3 and DJII nspire 1 User Manuals, attached hereto as Exhibit C and D. **iv The DJI Phantom 3 and DJI Inspi**  **re 1 GCS And Its Operation.** 

A complete description of the operation and specifications of the DJ I Phantom 3 and DJII nspire 1 GCS and flight control software is provided at pages 32 through 43 of the DJ I Phantom 3 User Manual and pages 40 through 47 of the DJ I Inspire 1 User Manual. DJ I Phantom 3 and DJII nspire 1 User Manuals are attached hereto as Exhibits C and D.

**b. Flight Operations Of DJI Phantom 3 and DJI Inspir e 1 UASs**  **Ar e Limited T**  **o The Line Of Sight Of**  **A Certificated Pilot in Comma**  **nd Wi**  **th A**  **Safety Observer**

**.** IRONSIDES MOTION LLC will only utilize certificated pilots who possess a current and valid airman medical certificate to act as a pilot in command (PI C) of the DJ I Phantom 3 and DJ I Inspire 1 UASs. Additionally , a safet y ob server will assist all pilots during flight time. **c. Flights Of DJI Phantom 3 and DJI Inspir e 1 UASs Will Be Conducted Pursuant**  **To Specific Operating Limitations.**  Inseeking this exemption, IR ONSIDES MOTION LLC proposes to commerciall y operate DJ I Phantom 3 and DJII nspire 1 UASs for the special purpose of conducting aerial video and photograph y over certain areas of United States, pursuant to the following specific operating limitations: 1. Operations authorized by this grant of exemption will be limited to the following aircraft described in the operating documents, rotorcraft UASs weighing less than 55 pounds maximum gross weight: DJIPhantom 3 and DJ I Inspire 1 Unmanned Aircraft Sy stems. Proposed operations of any other aircraft will require a new petition or a petition to amend this grant. 2. UAS operations under this exemption will be limited to conducting operations for the purpose of aerial video and photography

. 3. The UAs may not be flown at an indicated airspeed exce eding 20 knots. 4. The UA

must be operated at an altitude of no more than 500 feet above ground level (AGL), as indicated b y t he procedures specified in the operating documents unless a special request is made and approved by A TC. All altitudes reporte d to AT C must be in feet AGL. 5. The UAs must be operated within visual line of sight (VLOS) of the PIC at all times. This requires the PIC to be able to use human vision unaided b y an y device other than corrective lenses, as specified on the PI C’ s FA A

- issued airman medical certificate. 6. The use of first person view (FPV) b y the PI C or safet y observer (SO) is not permitted. 7. All operations must utilize a safety observer (SO). The SO may be used to satisfy

the VLOS requirement as long as the PIC alway s maintains VLOS capability . The SO and PI C must be able to communicate verball y at all times. Electronic messaging or texting is not permitted during flight operations. The PI C must be designated before the flight and cannot transfer hi s or her designation for the duration of the flight. The PI C 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 PI C with seeing and avoiding othe r air traf

fic and other ground based obstacles/obstructions and is not permitted to operate the camera or other instruments. 9. The operating documents and the grant of exemption must be accessible during UAS operations and made available to the Adm inistrator upon request. If a discrepancy existsbetween the conditions and limitations contained in the grant of exemption and the procedures

outlined in the operating documents, the conditions and limitations contained in the grant of exemption take p recedence 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. I f the operator determines that an y update or revision would af fect the basis upon which the F AA granted the exemption, then the operator must petition for amendment to its grant of exemption. The F AA’s UAS Integration Of fice (AFS

- 80) may be contacted if questions arise regarding updates or revisions to the operating documents. 10. Prior to each flight the PI C must inspect the UAS to ensure that it is in a condition f or safe flight. If the inspection reveals a condition that af fects the safe operation of the UAS, the aircraft is prohibited from operatin g until the necessary maintenance has been performed and the UAS is found to be in a condition for safe flight. The Ground Control Station must be included in the preflight inspection. All maintenance and alterations must be properl y documented in the a ircraft records. 11

. An y 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 PI C who conducts the functional test flight must make an entry in the aircraft records. 12. The pre

- flight inspection must account for all potential discrepancies, e.g. inoperable components, items, or equipment, not alread y covered in the relevant section s of the operating documents. 13. The operator must follow the UAS manufacturer ’s aircraft/component, maintenance, overhaul, replacement, inspection, and life limit requirements. 14. The operator must carry out its maintenance, insp ections, and record keeping requirements, in accordance with the operating documents. Maintenance, inspection, alterations, and status of replacement/overhaul component parts must be noted in the aircraft records, including total time in service, descri ption of work accomplished, and the signature of the authorized person returning the UAS to service. 15. Each UASs operated under this exemption must comply with all manufacturer Safety Bulletins. 16. The authorized person must make an e ntry in the aircraft record of the corrective action taken against discrepancies discovered between inspections. 17. The PI C must possess at least a private pilot certificate and at least a current third

class medical certificate. 18. The operator may not permit any PIC to operate unless the PI C meets the operator ’s qualification criteria and demonstrates the ability to safel y operate the UAS in a manner consistent with how the UAS will be operated under the exemption, including evasive and emergency maneuvers and maintaining appropriate distances from persons, vessels, vehicles and structures. PIC qualification flight hours must be logged in a manner consistent with 14 C.F .R. § 61.51(b). Flights for the purposes of training th e operator ’s PI Cs are permitted under the terms of the exemption. However, training operations may onl y 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 PI C must operate the UA with appropriate distance from nonparticipants in accordance with 14 C.F .R. § 91.1 19. 19. UAS operations may

not be conducted during night, as defined in 14 C.F .R. § 1.1.A ll operations must be conducted under visual meteorological conditions (VMC). If flight at

night is required, a special request will be made at the F AA of fice closest to proposed area of operations. Flights under special visual flight rules (SVFR) are no t authorized. 20. The UA

may not operate within 5 nautical miles of an airport reference point as denoted on a current F

AA

- published aeronautical chart unless a letter of agreement with that airport’ s management is obtained, and the operation is con ducted in accordance with a NOT AM as required b y the operator ’s COA. The letter of agreement with the airport management must be made available to the Administrator upon request. 21. The UA

may not be operated less than 500 feet below or less than 2 ,000 feet horizontally

from a cloud or when visibility is less than 3 statute miles from the PI C. 22. If the UA

loses communications or loses its GPS signal, it must return to a pre

determined location within the planned operating area and land or be recovered in accordance with the operating documents. 23. The PI C must abort the flight in the event of unpredicted obstacles or emergencies in accordance with the operating documents. 24. The PI C is prohibited from beginning a flight unless (cons idering wind and forecast weather conditions) there is enough power to fl y at normal cruising speed to the intended landing point and land the UA with 25% battery

power remaining. 25. The operator must obtain an Air T raf fic Organization (A

TO) issued Certificate of Wa iver or Authorization (COA) prior to conducting any operations under the grant of exemption. This COA

will also require the operator to request a Notice to Airman (NOT AM) not more than 72 hours in advance, but not less than 48 hours pr ior to the operation. All operations shall be conducted in accordance with airspace requirements in the AT O issued COA including class of airspace, altitude level and potential transponder requirements. 26. All aircraft operated in accordance with th e exemption must be identified by serial number , registered in accordance with 14 C.F .R. part 47, and have identification (N

- Number) markings in accordance with 14 C.F .R. part 45, Subpart C. Markings must be as large as practicable. 27. Before cond

ucting operations, the radio frequency spectrum used for operation and control of the UA

must comply

with the Federal Communications Commission (FCC) or other appropriate government oversight agency requirements. 28. The documents required fewer than 14 C.F .R. 91.9 and 91.203 must be available to the PI C at the Ground Control Station of the UAS any time the UAS is operating. These documents must be made available to the Administrator or an y law enforcement official upon request. 29. The UA

m ust remain clear and y ield the right of way to all manned aviation operations and activities at all times. 30. The UAS may not be operated b y 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 PI C, 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

an d/or debris in the event of an accident. The operator must ensure that nonparticipating persons remain under such protection. I f a situation arises where nonparticipating persons leave such protection and are within 500 feet of the UA, flight operations must cease immediately and/or; b. The aircraft is operated near vessels, vehicles or structures where the owner/controller of such vessels, vehicles or structures has granted permission and the PI C has made a safet y assessment of the risk of operat ing closer to those objects and determined that itdoes not present an undue hazard, and; c. Operations nearer to the PI C, SO, operator trainees or essential persons do not present an undue hazard to those persons per § 91.1 19(a). 32. All opera tions 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 con ducted. 33. An y incident, accident, or flight operation that transgresses the lateral or vertical boundaries of the operational area as defined b y t he applicable COA must be reported to the FA A's UAS Integration Of fice (AFS

- 80) within 24 hours. Acci dents must be reported to the National T

ransportation Safety

Board (NTSB) per instructions contained on the NTSB We b site:

www .ntsb.gov

. **2. Reasons Why An Exemption Fr**  **om The Requir**  **ements Of Section 61.1 13(a)**  **And (b) W**  **ould Not Adversely**  **Affect Sa fety** 

**.** IR ONSIDES MOTION LLC submits that the equivalent level of safet y established by Section 61.1 13(a) and (b) will be maintained because no PIC will be allowed to operate the DJ I Phantom 3 and DJII nspire 1 UASs unless that PIC has demonstrated, by meeting minimum flight

- hour and currency

requirements, that the PIC is able to safel y operate the DJ I Phantom 3 or DJ I Inspire 1 UAS in a manner consistent with the exemption, including evasive and emergency maneuvers and maintaining appropriate distan ces from people, vessels, vehicles and structures. Considering IRONSID ES MOTI ON LLC’ s proposed area of operations, and the operating limitations set forth

- above; the parallel nature of private pilot aeronautical knowledge requirements to those of co mmercial pilot requirements (See Exemption No. 1 1062); and the airmanship skills necessary to safel y operate the DJIPhantom 3 or DJ I Inspire 1 UAS, IRONSIDES MOTION LLC submits that the additional manned airmanship experience of a commerciall y certificated pilot would not correlate to the airmanship skills necessary for IRONSI DES MOTION LLC’ s specific proposed flight operations.

The F AA has previously

granted relief from Section 61.1 13(a) and (b) specific to UAS, in circumstances similar, i n all material respects, to those presented herein (e.g. Exemption Nos. 11 062, 1 1063, 1 1064, 1 1065, 1 1066, 1 1067, 1 1080, 1 11 09, 1 111 0, 1 111 2, 1 11 36, 1 11 38, 1 11 50, 111 53, 1 11 56, 1 11 58, 1 11 59, 1 11 60, 1 11 61). BLAKE J COPPI NGER will not allow any PIC to op erate the DJ I Phantom 3 or DJ I Inspire 1 UAS unless that PI C has demonstrated, by meeting minimum flight

- hour requirements or the DJ I Phantom 3 or DJII nspire 1 UAS training and currency requirements, that the PI C is able to safely operate the DJ I Phanto m 3 or DJ I Inspire 1 UAS in a manner consistent with this exemption, including evasive and emergency maneuvers and maintaining appropriate distances from people, vessels, vehicles and structures. Specifically

, the PIC must have accumulated and logged, in a manner consistent with 14 C.F .R. § 61.51(b), 25 hours of total time as a UAS rotorcraft pilot (with a minimum of 5 hours of those hours as a UAS pilot operating the same make and model of UAS to be used for operations under the exemption). In addit ion to the hour requirements, the PI C must accomplish 3 takeof fs and landings in the preceding 90 day s (for currency purposes). As in Exemption Nos. 1 1062, 1 11 38, and 1 11 53, prior documented flight experience that was obtained in compliance with app licable regulations will ensure an equivalent level of safet y during IRONSIDES MOTION LLC’ 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. 1 1062, the F AA required that prior to conducting operations for the purpose of motion picture filming (or similar operations), the PI C must have accumulated and logged, in a mannerconsistent with 14 CFR 61.51(b), 25 hours of total time as a UAS rotorcraft pilot including at least 10

hours logged as a UAS pilot with a multi

- rotor UAS. Prior to operations under Exemption No. 1 1062, the PI C must also have accumulated and logged a minimum of 5 hours as a UAS pilot operating the same make and model of UAS to be used for operations under the exemption. For clarification, the FA A considers these minimum hour requirements to be inclusive rather than additive; i.e. 5 hours make and model time may

be included in the 10 hours of multi

- rotor time and the 10 hours may be included in the total 25 hours of UAS rotorcraft time. I n addition to the hour requirements, the PI C must accomplish 3 takeof

fs and landings in the preceding 90 day s (for currency purposes). The F

AA finds that at a minimum, the flight hour requirements in Exemption No. 1 1062 are appropriate to practice and build proficiency

in the skills necessary

to safel y conduct the petitioner ’s proposed operations. The FA A also finds that prior documented flight experience that was obtained in compliance with applicable regulations would satisfy this requirement. Tr aining, proficiency , and experience

- building flights can also be conducted under the grant of exemption to accomplish the required flight time. During training, proficiency , and experience

- building flights the PI C is required to operate the UA with appropriate distances in accordance with 14 C.F .R 91.1 19.

Exemption No. 1 11 38 at page 15. Accordingly

, IRONSIDES MOTI ON LLC will ensure safe operations by not allowing an y P IC to operate the DJ I Phantom 3 or DJ I Inspire 1 UAS unless that PI C has demonstrated, by meeting minimum flight

- hour and currency requirements, that the PI C is able to safely operate the DJ I Phantom 3 or DJII nspire 1 UAS in a manner consistent with the exemption, including evasive and emergency maneuvers and maintaining appropriate distances from people, vessels, vehicles and structures.

**CONCLUSION** IR ONSIDES MO TI ON LLC seeks an exemption pursuant to 14 C.F .R. § 1 1.61 and Section 333 of the F AA Modernization and Reform Act of 2012 (FMRA), which will permit safe operation of the DJ I Phantom 3 and DJII nspire 1 UASs commercially , without an airworthiness certif

icate, for the limited purpose of conducting aerial video and photography over certain areas of the United States. By granting this Petition, the F AA A dministrator will be fulfilling the Congressional mandate of the F AA Modernization and Reform Act of 20 12, while also advancing the interests of the public, by allowing IRONSIDES MOTION LLC to safely
, efficiently

, and economically

operate the DJ I Phantom 3 and DJII nspire 1 UASs commerciall y within the NAS. WHEREFORE, in accordance with the Federal Av ia tion Regulations and the F AAModernization and Reform Act of 2012, Section 333, IR ONSIDES MOTION LL C respectfully

requests that the Administrator grant this Petition for an exemption from the requirements of 14 C.F .R Sections 61.1 13(a) & (b), 91.7(a), 9 1.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a) (1) & (a)(2), and 91.417(a) & (b), and permit Leading Edge to operate the DJI Phantom 3 and DJII nspire 1 UASs commerciall y for the purpose of conducting aerial video and photograph y over certain areas of the United States. Dated: May 22, 2015 Submitted by

Kevin William Andrews IRONSIDES MOTION LLC

**APPENDIX**

**– A**  DJIPHANT OM 3 TECHNI CAL SPECIFICA

TI ONS

IR ONSIDES MOTION LLC onl y utilizes safe and reliable UASs. DJ I is an industry leader in small UAS production. DJ I UASs are loaded with ground breaking software enabling the user to set parameters which will not allow flight into controlled airspace. Parameters can also be set to limit flight to no higher than a predetermined and set altitude as well as limit flight to a predetermined and set distance. In addition, DJ I software provides real

- time altitude and location information to the PI C via the linked monitor (smart phone/ta blet devices)

1.1 DJIPhantom 3 1.2 1.1.1 Aircraft 1.1.1.1 Supported Battery

– DJ I 6000AH LiPo Battery

1.1.1.2 W eight (Battery

& Propellers Included)

– 2lbs 1 1.810oz (1242g) 1.1.1.3 Hover Accuracy

(Ready to Fl y)

– Ve rtical: .8m; Horizontal: 2.5m 1.1.1.4 Max Yaw Angular Ve locit y

- 200/s 1.1.1.5 Max Ti lt Angel

- 35 1.1.1.6 Max Ascent Speed

– 6m/s 1.1.1.7 Max Descent Speed

– 2m/s 1.1.1.8 Max Flight Speed

– 15m/s (NOTRECOMMENDED) 1.1.2 Gimbal 1.1.2.1 W orking Current

– Static: 750mA; Dy namic: 900mA 1.1.2.2 Control Accuracy

- ±0.03 1.1.2.3 Controllable Range

– Pitch:

- 90

- 0 1.1.2.4 Maximum Angular Speed

– Pitch: 90/s 1.1.3 Camera 1.1.3.1 Operating Temperature Range

- 32F

- 104F (0C

- 40C) 1.1.3.2 Sensor Size

– 1/2.3” 1.1.3.3 Ef fective Pixels

– 14M 1.1.3.4 Resolution

– 4384x3288 4.1.3.5 HD V

ideo Recording

– 1080p30 & 720p 4.1.3.6 Recording Field of V iew

- 11 0/85

**APPENDIX**

**– B** 

DJII NSPI RE 1 TECHNICAL SPECIFICA

TI ONS

IR ONSIDES MOTION LLC onl y utilizes safe and reliable UASs. DJ I is an industry leader in small UAS production. DJ I UASs are loaded with ground breaking software enabling the user to setparameters which will not allow flight into controlled airspace. Parameters can also be set to limit flight

to no higher than a predetermined and set altitude as well as limit flight to a predetermined and set distance. In addition, DJ I software provides real

- time altitude and location information to the PI C via the linked monitor (smart phone/tablet devices)

A ll specifications can be found in the attached user manual or at http://www .dji.com/product/inspire

- 1/spec