UNITED STATES OF AMERICA DEPARTMENT OF TRANSPORTATION FEDERAL AVIATION ADMINISTRATION

WASHINGTON, DC

Regulatory Docket No.

**IN THE MATTER OF THE PETITION FOR EXEMPTION OF: Air** 

**- Reelz LLC**  **FOR AN EXEMPTION SEEKING RELIEF FROM THE REQUIREMENTS OF**

**TITLE 14 OF THE CODE OF FEDERAL REGULATIONS SECTIONS 61.101(e)(4) & (5), 61.113(a) & (b), 61.23(a), 61.315(a), 91.7(a),**  **91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), AND 91.41 7(a) &**  **(b) CONCERNING COMMERCIAL OPERATION OF DJI INSPIRE 1**

**UNMANNED AIRCRAFT SYSTEMS PURSUANT TO SECTION 333 OF**  **THE FAA MODERNIZATION AND REFORM ACT OF 2012**

**(PUBLIC LAW 112**

**- 95)** 

Submitted on June 23 rd , 2015

Christopher Earle

- Handley Air

- Reelz LLC 22 Country Club Drive Apt 29 Manchester, NH 03102 Tel: (978) 347

- 5964 Email: info@air

- reelz.com2 **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...................................................................... ...7

THE SPECIFIC SECTIONS OF 14 C.F.R. FROM WHICH AIR

- REELZ LLC SEEKS EXEMPTION ...........................................

............................................................................. 8

THE EXTENT OF RELIEF AIR

- REELZ LLC SEEKS AND THE REASON AIR

- REELZ LLC SEEKS THE RELIEF.......................................................................... 11

THE REASONS WHY GRANTING AIR

- REELZ LLC’S REQUEST WOULD BE IN THE PUBLIC INTEREST ..

......................................................................... 15

THE REASONS WHY GRANTING THE EXEMPTION WOULD NOT ADVERSELY AFFECT SAFETY .....

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

SUMMARY THAT CAN BE PUBLISHE D IN THE FEDERAL REGISTER. ............ 34

ADDITIONAL INFORMATION, VIEWS, OR ARGUMENTS AVAILABLE TO SUPPORT AIR

- REELZ LLC’S REQUEST...............................

................................... .... 34

CONCLUSION

.................................................................................................... ............... 35

APPENDICES........................................................................................373

**GLOSSARY 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 Administration
FAR Federal Aviation Regulation
GCS Ground Control Station
GPS Global Positioning System
LOL Loss of Link
NAS National Airspace System
NOTAM Notice to Airman
PIC Pilot In Command
Section 333 FAA Modernization and Reform Act of 2012 (FMRA) Section 333
SO Safety Observer
SOP Standard Operating Procedures
UA Unmanned Aircraft
UAS Unmanned Aircraft System
VFR Visual Flight Rules
VLOS Visual Line of Site
VMC Visual Meteorological Conditions
VTOL Vertical Takeoff and Landing4 **SUMMARY**
Christopher Earle

- Handley seeks exemption from the requirements of 14 C.F.R §§

61.101(e)(4) and (5), 61.315(a), 61.23(a), 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
System pursuant to Section 333 of the FAA Modernization and Reform Act of 2012

(FMRA). This exemption will permit Air

- Reelz LLC to operate an Unmanned Aircraft
Syste m (UAS) for the commercial purpose of conducting aerial video and photography of
areas including but not limited to: construction sites, building inspections, agricultural
lands, wineries, outdoor recreational facilities, real estate, special events, busin esses and
landscapes within the United States.

**INTRODUCTION AND INTERESTS OF THE PETITIONER**

Air

- Reelz LLC will provide its clients with the highest quality digital content for
use in their commercial, personal, and non

- profit multimedia projects. Air

- R eelz LLC will
bring together years of professional marketing expertise, award

- winning production talent

and state

- of

- the

- art technology to make studio quality productions within reach for
organizations of any size. Air

- Reelz LLC will also leverage years of professional civil
engineering experience to become a leading provider of geomapping and image analysis
services to the civil engineering and environmental monitoring industries. Air

- Reelz LLC
has over 2 years recreational/hobby experience in all aspects of aerial video and
photography. The objective of Air

- Reelz LLC aerial video and photography operations is
to provide high quality imaging for a variety of commercial, public, and residential uses,
specifically targeting:

• Aerial event filming and photography

• Promotional videos for businesses, non

- profits & government entities

• Agricultural surveys and environmental monitoring

• Civil engineering inspection and documentation5 **BACKGROUND**

**Unmanned Aircraft Systems: DJI Inspi re 1 UAS** 

Air

- Reelz LLC seeks an exemption to operate DJI systems for compensation or
hire within the NAS. The DJI Inspire 1 (Inspire 1) is a vertical takeoff and landing
(VTOL) Unmanned Aircraft (UA) with a Ground Control Station (GCS) utilizing
electronic tablet or smart phone systems. The Inspire 1 is an electric powered rotary wing
UAS that is capable of transmitting live airborne video images and location information t o
a Ground Control Station (GCS). The Inspire stores the photographs and data on board
and makes them available for download after completion of the flight. The Inspire is 22 in
x 22 in x 8 in and weighs 6.4 pounds, well under the 55 lbs mandated in the FM RA. The
Inspire can conduct hovering flight and has a maximum cruising speed of 42 knots. It is
battery powered, has a flight endurance of 22 minutes and can operate in temperatures
ranging from 0° to 40° C. The Inspire’s omni

- directional antenna has a ran ge of 2.1 km
and operates in the 2.420

– 2.483 GHz frequency range.

The Inspire 1 that will be operated by Air

- Reelz LLC will be registered in

accordance with 49 U.S.C. 44103, Registration of Aircraft , as well as 14

C.F.R Part 47, Aircraft Registration
, and marked in accordance with 14 C.F.R. Part 45,

Identification and Registration Marking

.

**BASIS FOR PETITION**

Petitioner, Air

- Reelz LLC, 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 Systems , hereby
petitions the Administrator to commercially operate the DJI Inspire 1 in the National6

Airspace System (NAS), and for an exemption from the requirements of 14 C.F.R §§ 61.101(e)(4) and (5), 61.315(a), 61.23(a), 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, Air

- Reelz’s operation of the DJI Inspire 1
UAS meets the conditions of FMRA Section 333 and therefore, will not require an

airworthiness certificate in accor dance with 14 C.F.R. Part 21, Subpart H.
Accordingly, Air

- Reelz LLC requests relief from Sections 91.405(a),

91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b), as these sections set forth
requirements for maintenance that only apply to aircraft wit h an airworthiness certificate.

Air

- Reelz LLC submits that the requested relief is proper since an equivalent level
of safety will be ensured. Air

- Reelz LLC 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 Inspire 1 Instruction Manual). Furthermore, Air

- Reelz LLC will
document and maintain all maintenance records for the DJI Inspire 1 UAS.

Relief from certain requirements of Section 61.101(e)(4) and (5) entitled
Recreational pilot privileges and limitations: Pilot in command , and from Section

61.315(a) entitled What are the privileges and limits of my sport pilot certificate , and from

Section 6 1.23(a) entitled Medical certificates: Requirements and duration , is requested by

Air

- Reelz LLC to the extent necessary to allow a Pilot in Command (PIC) holding a sport
pilot or higher level certificate, as well as a valid driver’s license, and who has

de monstrated, by meeting minimum flight

- hour and currency requirements, that the7

PIC is able to safely operate the DJI 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.

Air

- Reelz LLC seeks relief from Section 91.7(a), entitled Civil aircraft

airworthiness , because the DJI Inspire 1 UAS d oes not require an airworthiness certificate
in accordance with 14 C.F.R. Part 21, Subpa rt H. As such, Air

- Reelz LLC submits that it
will ensure that the DJI Inspire 1 UAS is in an airworthy condition, prior to every flight, b y
determining that the UASs is in compliance with the operating documents (i.e., Monthly
Maintenance Log, and DJI Insp ire 1 Instruction Manual), and that the aircraft are in a
condition for safe flight.

Air

- Reelz LLC also seeks an exemption from the requirements of Section 91.121,

entitled Altimeter Settings , as the DJI Inspire 1 UA will not have a typical barometric

alt imeter onboard. However, altitude information of the DJI Inspire 1 UA will be provided
to the PIC via Global Positioning System (GPS) equipment and radio communications
telemetry data link, which downlinks from the UA to the GCS for active monitoring of th e
flight path. This altitude information, combined with Air

- Reelz LLC’s operation of the DJI
Inspire 1 UAS within visual line of sight, at or below 4 00 feet AGL, will ensure a level of
safety equivalent to Section 91.121.

Additionally, Air

- Reelz LLC seeks an exemption from the requirements of Section

91.151(b), entitled Fuel requirements for flight in VFR conditions . Air

- Reelz LLC submits
that safety will not be affected by operation of the DJI Inspire 1 UA during daylight hours
in visual meteorological co nditions (VMC) under visual flight rules (VFR), with enough
battery power to fly for a total duration of approximately 13.5 minutes to the first point of8

intended landing and, assuming normal cruising speed, to fly after that for at least 4.5

minutes.

In accordance with 14 C.F.R. § 11.81, Air

- Reelz provides the following
information in support of its petition for exemption:

**A. Name And Address Of The Petitioner.** 

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

Christopher Earle

- Handley Air

- Reelz LLC 22 Country Club Drive Apt 29 Manchester, NH 03102 Tel: (978) 347

- 5964 Email: info@air

- reelz.com

**B. The Specific Sections Of 14 C.F.R. From Which Air** 

**- Reelz LLC Seeks**  **Exemption.**

**1. Air** 

**- Reelz LLC Seeks**  **Exemption From The Requirements Of Section 61.101(e)(4) and (5).** 

Section 61.101, entitled Recreational pilot privileges and limitations: Pilot in

command , subsection (e)(4) and (5) prescribe the following, in relevant part:

(e) Except as provided in p aragraphs (d) and (i) of this section, a recreational pilot may not act as pilot in command of an aircraft

--
(4) For compensation or hire;

(5) In furtherance of a business;

**2. Air** 

**- Reelz LLC Seeks Exemption From The Requirements Of Section**  **61.23(a).**9 Section 61.23(a), entitled Operations requiring a medical certificate: Requirements

and duration , subsection (a) prescribe the following, in relevant part:

(f) Except as provided in paragraphs (d) and (i) of this section, a recreational pilot may not act as pilot in command of an aircraft

--

**3. Air** 

**- Reelz LLC Seeks Exemption From The Requirements Of Section**  **61.315(a).**

Section 61.315(a), entitled What are the privileges and limits of my sport pilot

certificate , subsection (a) prescribe the following, in relevant part:

(c) You may not act as pilot in command of a light

- sport aircraft:

(2) For compensation or hire.

(3) In furtherance of a business.

--

**4. Air** 

**- Reelz LLC 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 may operate a civil aircraft unless it is in an airworthy condition.

**5. Air** 

**- Reelz LLC**  **Seeks Exemption From The Requirements O**  **f Section 91.121.** 

Section 91.121, entitled Altimeter settings, subsection (a), states the following, in

part:

(a) Each person operating an aircraft shall maintain the cruising altitude or flight level of that aircraft, as the case may be, by reference to an altimeter that is set, when operating

--
(1) Below 18,000 feet MSL, to

--10 (i) The current reported altimeter set ting of a station along the route and within 100 nautical miles of the aircraft;

(ii) If there is no station within the area prescribed in paragraph (a)(1)(i) of this section, the current reported altimeter setting of an appropriate available station; or

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

**6. Air** 

**- Reelz LLC**  **Seeks Exemption From The Requirements Of Section**  **91.151(b).**

Section 91.151, entitled Fuel requirements for flight in VFR conditions , subsection
(b), states the following:

(b) No person may begin a flight in a rotorcraft under VFR conditions unless (considering wind and forecast weather conditions) there is enough fuel to fly to the first point of intended landing and, assuming normal cruising speed, to fly after that for at least 20 minutes.

**7. Air** 

**- Reelz LLC**  **Seeks Exemption From The Requirement Of Section**  **91.405(a).**

Section 91.405, entitled Maintenance requir ed , subsection (a), states the following:
Each owner or operator of an aircraft

— (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, ha ve discrepancies repaired as prescribed in part 43 of this chapter[.]

**8. Air** 

**- Reelz LLC**  **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 may operate any aircraft that has undergone maintenance, preventive maintenance, rebuilding, or alteration unless

--
(1) It has been approved for return to service by a person authorized under § 43.7 of this chapter[.]11

**9. Air** 

**- Reelz LLC 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 s ection, no person may operate an aircraft unless, within the preceding 12 calendar months, 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 o f this chapter.

**10. Air** 

**- Reelz LLC**  **Seeks Exemption From The Requirements Of Sections**  **91.417(a) and 91.417(b).**

Section 91.417, entitled Maintenance records , subsections (a) and (b), state the
following:

(a) Except for work performed in accordance with §§ 91.411 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 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

--
(i) A description (or reference to data acceptable to the Administrator) of the work performed; and

(ii) The date of completion of the work performed; and

(iii) The signature, and certificate number of the person approving the aircraft for return to service. (2) Records containing the following information:

(i) The total time in service of the airframe, each engine, each propeller, and each rotor.

(ii) The current status of life

- limited parts of each airframe, engine, propeller, rotor, and appliance.12 (iii) The time since last overhaul of all items installed on the aircraft which are required to be overhauled on a specified time basis.

(iv) The current inspection status of the aircraft, including the time since the last inspection required by the inspection program unde r which the aircraft and its appliances are maintained.

(v) The current status of applicable airworthiness directives (AD) and safety directives including, for each, the method of compliance, the AD or safety directive number and revision date. If the AD or safety directive involves recurring action, the time and date when the next action is required.

(vi) Copies of the forms prescribed by § 43.9(d) of this chapter for each major alteration to the airframe and currently installed engines, rotors, propellers, and appliances.

(b) The owner or operator shall 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 performed.

(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.

(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 serv ice.

**C. The Extent Of Relief Air** 

**- Reelz LLC Seeks And The Reason Air** 

**- Reelz LLC**  **Seeks The Relief.**

**1. Extent Of Relief Air** 

**- Reelz LLC Seeks And The Reason Air** 

**- Reelz LLC**  **Seeks Relief From Section 61.113(a) and (b).**  Relief from Section 61.113(a) and (b) ent itled Private pilot privileges and

limitations: Pilot in command , is requested to the extent necessary to allow a PIC holding a
private pilot or higher level certificate, as well as a current and valid airman medical13

certificate, and who has met certain fl ight

- 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 61.113(a) and (b)
state that a private pilot may, for compensation or hire, act as PIC of an aircraft in
connection with any business or employment if: (1) The flight is only incidental to that
business or employment; and (2) The aircraft does not carry passengers or property for
compensation or hire.

As set forth more fully below, Air

- Reelz LLC submits that an equivalent level of
safety will be maintained because no PIC will be allowed to operate the DJI Inspire
1 UAS UA unless that PIC has met certain flight

- hour and currency requirements,
demonstrating that the PIC is able to safely operate either the DJI Inspire 1 UAS in a
manner consistent with the operations specifications as describ ed in this exemption,
including evasive and emergency maneuvers, as well as maintaining appropriate distances
from people, vessels, vehicles and structures.

Further, Air

- Reelz LLC submits that all flights of the DJI Inspire 1 UAS, conducted
by the PIC pur suant to the grant of this Petition: (1) will be incidental to Air

- Reelz LLC
business; and (2) will not carry passengers or property for compensation or hire.

**2. Extent Of Relief Air** 

**- Reelz LLC Seeks And The Reason Air** 

**- Reelz LLC**  **Seeks Relief From Section 61.2 3(a).** 

Relief from Section 61.23(a), entitled Operations requiring a medical certificate:
Requirements and duration, is requested to the extent required to necessary to allow a PIC
holding a sport pilot certificate or higher level certificate, as well as a current and valid
driver’s license, to conduct the proposed UAS flight operations for compensation or hire.

This relief is requested since the limitations set forth in Section 61.23(a) otherwise
require the PIC of any flight for compensation or hire to hold a comprehensive FAA issued14

medical certificate. In Exemption No. 11213 to Aeryon Labs, Inc., the FAA “finds that,
because of the risk mitigations established in the conditions and limitations of this
exemption, a person that holds a U.S. issued drive r’s license who is operating a UAS will
not adversely affect safety. The FAA is granting relief from § 61.23(a) to allow any pilot
that holds one of the pilot’s certificates discussed above to operate a UAS under this
exemption with a U.S. issued driver’s license, in lieu of an FAA

- issued medical certificate.
The FAA is also granting relief from § 61.23(c) to allow sport pilot certificate holders to
operate aircraft other than LSA with a U.S. issued driver’s license under this exemption.”

**3. Extent Of Reli**  **ef Air**

**- Reelz LLC Seeks And The Reason Air** 

**- Reelz LLC**  **Seeks Relief From Section 61.315(a).** Relief from Section 61.315(a) entitled What are the privileges and limits of my
sport pilot certificate , is requested to the extent necessary to allow a PIC holding a sport
pilot or higher level certificate to conduct the proposed UAS flight operations for
compensation or hire.

This relief is requested since the limitations set forth in Section 61.315(a) r estrict a
sport pilot from acting as the PIC of any flight for compensation or hire, or for the
furtherance of any business.

In Exemption No. 11213 to Aeryon Labs, Inc., the FAA re

- assessed the level of
pilot certificate that would be appropriate for th e petitioner’s operations. In evaluating this
petition, similar to the evaluation of the private and commercial pilot certificates in
Exemption No. 11062, the agency compared the aeronautical knowledge requirements of
the recreational and sport pilot certi ficates to those of the private pilot certificate. They
found that the aeronautical knowledge requirements that would be applicable to a UAS
operation for a recreational pilot and sport pilot certificate are substantially similar as those
for a private pil ot certificate.15 Additionally, similar to the private and commercial pilot certificates, holders of
recreational and sport pilot certificates are subject to security screening by the Department
of Homeland Security (DHS).

Therefore, because they must de monstrate aeronautical knowledge relevant to UAS
operations and are subject to DHS screening, factors that were considered by the FAA in
allowing private pilot operations under previous exemptions, the FAA now determines that
holders of recreational and sp ort pilot certificates may serve as the PIC for UAS
operations.

**4. Extent Of Relief Air** 

**- Reelz LLC Seeks And The Air** 

**- Reelz LLC Seeks Relief**  **From Section 91.7(a).** Relief from Section 91.7(a) entitled Civil aircraft airworthiness , is requested to the

extent re quired to allow Air

- Reelz LLC to determine that the DJI Inspire 1 UAS are in
airworthy condition prior to every flight by ensuring that the UAS is in compliance with
the operating documents (i.e., the DJI Inspire 1 Maintenance Manual, Monthly

Maintenance L og, and DJI Inspire 1 Instruction Manual).

Air

- Reelz LLC seeks the requested relief because the DJI Inspire 1 UAS do not
require an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H.

Therefore, Air

- Reelz LLC will ensure that the DJ I Inspire 1 UAS are in airworthy
condition based upon its compliance with the operating documents (i.e., Monthly
Maintenance Log, and DJI Inspire 1 Instruction Manual) prior to every flight, and further,

determine that the aircraft are in condition for saf e flight, as stated in the conditions and

limitations below.

**5. Extent Of Relief Air** 

**- Reelz LLC Seeks And The Reason Air** 

**- Reelz LLC**  **Seeks Relief From Section 91.121.**

Relief from Section 91.121, entitled Altimeter settings, may be required to allow
flight op erations of the DJI Inspire 1 UAS, which utilize a barometric pressure sensor, GPS16

equipment, and a radio communications telemetry data link to downlink altitude
information from the UA to the PIC at the ground control station (GCS). Since the FAA
requires that any altitude information concerning UAS operations be reported to air traffic
control (ATC) in feet above ground level (AGL), Air

- Reelz LLC seeks the requested relief
because the DJI Inspire 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 flight.

Considering the limited altitude of the proposed operations, relief from 14 CFR

91.121 is sought to the extent necessary to comply with the applicable conditions and
limitations stated below. As more fully set forth herein, an equivalent level of safety will
be maintained since the DJI Inspire 1 UAs are equipped with a barometric pres sure sensor
and GPS equipment, which automatically ensures that a ground level pressure setting will
be established prior to each flight, and provides the PIC with altitude information of the

UA on the heads

- up display of the GCS.

**6. Extent Of Relief Air** 

**- Ree**  **lz LLC Seeks And The Air**

**- Reelz LLC Relief From**  **Section 91.151(b).**

Relief from Section 91.151(b) entitled Fuel requirements for flight in VFR
conditions, is requested to the extent required to allow flights of the battery powered DJI
Inspire 1 UAs during daylight hours in visual meteorological conditions (VMC), under

visu al flight rules (VFR), for a total duration of 13.5 minutes to the first point of intended
landing and, assuming normal cruising speed, to fly after that for at least 4.5 minutes.

Air

- Reelz LLC seeks the requested relief because without an exemption from Section
91.151(b), the flight time duration of the battery powered DJI Inspire 1 UA will severely
constrain the practicality of any aerial video or still photo flight operations that Air

- Reelz
proposes to conduct pursuant to this Petition.17 Significantly, as set forth below, the technical specifications of the DJI Inspire 1
UAS, the DJI Inspire 1 operating documents, and Air

- Reelz LLC’s proposed operating

limitations, ensure that Air

- Reelz LLC will safely operate the battery powered DJI Inspire
1 UAs 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, assuming normal cruising speed, to fly after that for

at least 4.5 minutes.

**7. Extent Of Relief Air** 

**- Reelz LLC Seeks And The Reason Air** 

**- Reelz LLC**  **Seeks Relief From 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), a nd 91.417(a) & (b)
only apply to aircraft with an airworthiness certificate, Air

- Reelz LLC requests relief from
these Sections because the DJI Inspire 1 UAS does not require airworthiness certificates.
As set forth more fully below, the DJI Inspire 1 UAS m eets the conditions of
FMRA Section 333 for operation without an airworthiness certificate. Accordingly, Air

Reelz LLC will use trained technicians to perform maintenance, alterations, or preventive
maintenance on the UASs using the methods, techniques, a nd practices prescribed in the
UAS operating documents (i.e., the DJI Inspire 1 Maintenance Manual, Monthly
Maintenance Log, and DJI Inspire 1 Instruction Manual). Furthermore, Air

- Reelz will
document and maintain all maintenance records for the DJI Inspir e 1 UAS.

**D. The Reasons Why Granting Air** 

**- Reelz LLC Request Would Be In The Public**  **Interest; That Is, How It Would Benefit The Public As A Whole.**

Granting the present Petition will further the public interest by allowing Air

- Reelz
LLC to safely, efficiently, and economically conduct aerial video and photography of
construction sites, building inspections, agricultural lands, wineries, outdoor recrea tional
facilities, real estate, special events, and landscapes over certain areas of the United States.18 Additionally, use of the DJI Inspire 1 UAS will decrease congestion of the NAS,
reduce pollution, and provide significant benefits to the economy. Nota bly, the benefits of

Air

- Reelz LLC’s proposed operation of the DJI Inspire 1 UAS will be realized without
implicating any privacy issues.

**1. The Public Will Benefit From Decreased Congestion Of The NAS.** 

The DJI Inspire 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 DJI Inspire 1 UAS w ould reduce the amount of manned
aircraft in the NAS, reduce noise and air pollution, as well as increase the safety of life and
property in the air and on the ground.

Furthermore, by reducing the number of manned aircraft operating in the NAS,
congestion around airports caused by arriving and departing aircraft will be reduced. The
DJI Inspire 1 UAS do not require an airport to takeoff or land. Likewise, a reduction of
manned aircraft conducting aerial video and photography missions would result in fewer
aircraft that must be handled by air traffic control during the ground, takeoff, departure,
arrival, and landing phases of flight operations.

**2. The Public Will Benefit From The Safety And Efficiency Of The DJI**  **Inspire 1 UAS.**

Conducting aerial acquisition s with the DJI Inspire 1 UAS, instead of manned
aircraft, will greatly benefit the public by drastically reducing the levels of air and noise
pollution generated during traditional aerial video and still photography flight operations.
By using battery powe r and electric motors, the DJI Inspire 1 UAS produce no air
pollution, and is the most viable environmentally conscious alternative to the cabin class,
six cylinder internal combustion engine aircraft that are typically utilized for aerial video19

and photog raphy, while burning approximately 20

- 30 gallons per hour of leaded aviation
fuel. The DJI Inspire 1 UAS, while reducing the carbon footprint of aerial acquisitions,
also eliminates noise pollution, as the UASs are propelled by battery powered electric

mot ors, rather than an internal combustion engine.

By using the 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 manned aircraft flight operations, will be substantially reduced or complet ely
eliminated. Aside from the lack of flight crew members located onboard the aircraft, the
DJI Inspire 1 UAS (weighing approximately 6.5 pounds maximum gross weights with a
length of 17.3 inches, width of 17.7 inches, and with no fuel on board), has less physical
potential for collateral damage to life and property on the ground, and in the air, compared
to the manned aircraft that typically conduct similar operations (weighing approximately
6,000 pounds with a wingspan of approximately 42 feet, a length of 34 feet, and a fuel
capacity of 180 gallons).

**3. Performing Aerial Video and Photography Operations With The DJI**  **Inspire 1 UAS Will Benefit The Economy.**

In addition to being safe and efficient, the DJI Inspire 1 is also an economical

alternative to us ing manned aircraft to conduct similar aerial operations. As such, operation
of the DJI Inspire 1 UAS will allow United States based companies, like Air

- Reelz 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
(“EPA”) regulatory actions phasing out leaded aviation fuels, U.S. owned and operated
companies must adopt new and alternative technology in order to remain competitive.
Operating the bat tery powered DJI Inspire 1 UAS is one such technology that not only20

allows companies greater operational flexibility compared to manned aircraft, but provides
such flexibility without the high operational cost of a traditional manned aircraft.

By operatin g the DJI Inspire 1 UAS, companies such as Air

- Reelz LLC, can remain
competitive and profitable, and therefore, provide greater job stability to employees and
contractors, which will ultimately contribute to growth of the U.S. economy. Improved
financial p erformance of U.S. companies, through commercial use of the DJI Inspire 1
UAS, provides a stable workforce that increases consumer spending; improves local, state,
and federal tax revenues; and allows companies to invest in research and development in

orde r to remain competitive both in the United States and abroad.

**4. There Are No Privacy Issues.** 

Similar to the manned aerial acquisition flight operations that have been conducted for

decades, Air

- Reelz LLC proposed operation of the DJI Inspire 1 UAS will n ot implicate
any privacy issues. Specifically, the DJI Inspire 1 UAS will be operated only in
compliance with the conditions set forth in any exemption granted under this petition.

**E. The Reasons Why Granting The Exemption Would Not Adversely Affect Safety,**  **Or How The Exemption Would Provide A Level Of Safety At Least Equal To That Provided By The Rule From Which Air** 

**- Reelz LLC Seeks Exemption.** 

**1. Reasons Why The DJI Inspire 1 UA Meet The Conditions Of The FAA**  **Modernization and Reform Act of 2012 (FMRA) Section 333.**  In consideration of the size, weight, speed, and limited operating area associated
with the unmanned aircraft and its operation, Air

- Reelz LLC operation of the DJI Inspire 1
UAS meet the conditions of FMRA Section 333, and will not require an airworthiness
certificate in accordance with 14 C.F.R. Part 21, Subpart H.
Section 333 provides authority for a UAS to operate without airworthiness
certification and sets forth requirements for considering whether a UAS will create a21

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 national 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.

(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) Requirement s for Safe Operation.

-- If the Secretary determines under this section that certain unmanned aircraft systems may operate safely in the national airspace system, the Secretary shall establish requirements for the safe operation of such aircraft systems in t he national airspace system.

In seeking this exemption, Air

- Reelz LLC submits that the DJI Inspire 1 UAS can
operate safely in the NAS pursuant to FMRA Section 333, as demonstrated by: (a) the
characteristics of the DJI Inspire 1 UAS; (b) the pilot cert ification requirement; and (c) the
specific operating limitations.

**a. The Specifications Of The DJI Inspire 1 UAS Demonstrate Its Safe**  **Characteristics.**

The 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 considering its size, weight, speed, and
operational capability.22 **i. Technical Specifications Of The DJI Inspire 1 UAS.** 

The technical specifications of the DJI Inspire 1 UAS is set forth by the DJI Inspire
1 Specifications and Data Sheet, attached hereto as Exhibit A.

**ii. The DJI Inspire 1 UAS Autonomous Flight And Navigation Modes**  **Enable The UAS To Remain Within A Defined Ope rational Area.** 

The DJI Inspire 1 UAS may be operated in both manual and fully autonomous
flight modes. A complete description of the flight and navigational modes of the DJI
Inspire 1 UAS is provided in the DJI Inspire 1 User Manual, attached hereto as Exhibit B.

**iii. The DJI Inspire 1 UAS Are Designed For Automatic Return To**  **Home Point Or Hover In The Event Of Loss Of The Control Link Or Navigation.** 

When the Control Link is lost, the DJI Inspire 1 UA will remain stationary, in
flight, for 3 seconds or mo re. If, after 3 seconds, the DJI Inspire 1 UA does not reacquire

control link data from the GCS, the UA will assume that the Control Link is lost and the
UA will return to the home position (i.e., failsafe mode) via GPS, and will descend to the
takeoff pos ition and shutdown.

A complete description of the Failsafe Functions of the DJI Inspire 1 UAS are set
forth in the DJI Inspire 1 User Manual, attached hereto as B.

**iv. The DJI Inspire 1 GCS And Its Operation.** 

A complete description of the operation and specifications of the DJI Inspire 1 GCS
and flight control software is provided in the DJI Inspire 1 User Manual. DJI Inspire 1

User Manual is attached hereto as Exhibit B.

**b. Flight Operations Of DJI Inspire 1 UAS**  **Are Limited To The Line Of Sight Of A Certificated Pilot in Command With A Safety Observer.** 23 Air

- Reelz LLC will only utilize certificated pilots who possess a current and valid
airman medical certificate to act as a pilot in command (PIC) of the DJI Inspire 1 UAS.
Additionally, a safety observer will assist all pilots during flight time.

**c. Flights**  **Of DJI Inspire 1 UAS Will Be Conducted Pursuant To Specific Operating Limitations.** 

In seeking this exemption, proposes to commercially operate DJI Inspire 1 UAS for
the special purpose of conducting aerial video and photography over certain areas of

Uni ted 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 gro ss weight: DJI Inspire 1 Unmanned Aircraft System. 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 exceeding 20 knots.

4. The UA must be operated at an altitude of no more than 500 feet above ground level (AGL), as indicated by the procedures specified in the operating do cuments unless a special request is made and approved by ATC. All altitudes reported to ATC must be in feet AGL.

5. The UAs must be operated within visual line of sight (VLOS) of the PIC at all times. This requires the PIC to be able to use human vision unaided by any device other than corrective lenses, as specified on the PIC’s FAA

- issued airman medical certificate.

6. The use of first person view (FPV) by the PIC or safety observer (SO) is not permitted.

7. All operations must utilize a safety observer (SO). The SO may be used to satisfy the VLOS requirement as long as the PIC always maintains VLOS capability. The SO and PIC must be able to communicate verbally at all times. Electronic messaging or texting is not permitted during flight operations. The PIC must be designated before the flight and cannot transfer his or her24 designation for the duration of the flight. Th e PIC must ensure that the SO can perform the functions prescribed in the operating documents.

8. The SO must not perform any other duties beyond assisting the PIC with seeing and avoiding other air traffic and other ground based obstacles/obstructions and is not permitted to operate the camera or other instruments.

9. The operating documents and the grant of exemption must be accessible during UAS operations and made available to the Administrator upon request. If a discrepancy exists between the condition s and limitations contained in the grant of exemption and the procedures outlined in the operating documents, the conditions and limitations contained in the grant of exemption take precedence and must be followed. Otherwise, the operator must follow the p rocedures 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 operat or must also present updated and revised documents if it petitions for extension or amendment to the grant of exemption. If the operator determines that any update or revision would affect the basis upon which the FAA granted the exemption, then the operat or must petition for amendment to its grant of exemption. The FAA’s UAS Integration Office (AFS

- 80) may be contacted if questions arise regarding updates or revisions to the operating documents.

10. Prior to each flight the PIC must inspect the UAS to ensur e 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 maintenance has been performed and the UAS is found to be in a

con dition for safe flight. The Ground Control Station must be included in the preflight inspection. All maintenance and alterations must be properly documented in the aircraft records.

11. Any UAS that has undergone maintenance or alterations that affect the U AS operation or flight characteristics, e.g. replacement of a flight critical component, must undergo a functional test flight. The PIC who conducts the functional test flight must make an entry in the aircraft records.

12. The pre

- flight inspection must ac count for all potential discrepancies, e.g. inoperable components, items, or equipment, not already covered in the relevant sections of the operating documents.

13. The operator must follow the UAS manufacturer’s aircraft/component, maintenance, overhaul, replacement, inspection, and life limit requirements.

14. The operator must carry out its maintenance, inspections, and record keeping requirements, in accordance wit h the operating documents. Maintenance, inspection, alterations, and status of replacement/overhaul component parts must25 be noted in the aircraft records, including total time in service, description of work accomplished, and the signature of the authorize d 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 entry in the aircraft record of the corrective action taken against discrepancies di scovered between inspections.

17. The PIC 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 PIC meets the operator’s qualification criteria and demonstrates the ability to safely 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 struct ures. PIC qualification flight hours must be logged in a manner consistent with 14 C.F.R. § 61.51(b). Flights for the purposes of training the operator’s PICs are permitted under the terms of the exemption. However, training operations may only be conducte d during dedicated training sessions. During training, proficiency, and experience

- building flights, all persons not essential for flight operations are considered nonparticipants, and the PIC must operate the UA with appropriate distance from nonparticipa nts in accordance with 14 C.F.R. § 91.119.

19. UAS operations may not be conducted during night, as defined in 14 C.F.R. § 19.1. All operations must be conducted under visual meteorological conditions (VMC). If flight at night is required, a special request will be made at the FAA office closest to proposed area of operations. Flights under special visual flight rules (SVFR) are not authorized.

20. The UA may not operate within 5 nautical miles of an airport reference point as denoted on a current FAA

- published aeronautical chart unless a letter of agreement with that airport’s management is obtained, and the operation is conducted in accordance with a NOTAM as required by the operator’s COA. The letter of agreement 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 clo ud or when visibility is less than 3 statute miles from the PIC.26

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 opera ting documents.

23. The PIC must abort the flight in the event of unpredicted obstacles or emergencies in accordance with the operating documents.

24. The PIC is prohibited from beginning a flight unless (considering wind and forecast weather conditions) the re is enough power to fly at normal cruising speed to the intended landing point and land the UA with 25% battery power remaining.

25. The operator must obtain an Air Traffic Organization (ATO) issued Certificate of Waiver or Authorization (COA) prior to co nducting any operations under the grant of exemption. This COA will also require the operator to request a Notice to Airman (NOTAM) not more than 72 hours in advance, but not less than 48 hours prior to the operation. All operations shall be conducted in a ccordance with airspace requirements in the ATO issued COA including class of airspace, altitude level and potential transponder requirements.

26. All aircraft operated in accordance with the exemption must be identified by serial number, registered in acco rdance with 14 C.F.R. part 47, and have identification (N

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

27. Before conducting operations, the radio frequency spectrum used for operation and cont rol of the UA must comply with the Federal Communications Commission (FCC) or other appropriate government oversight agency requirements.

28. The documents required fewer than 14 C.F.R. 91.9 and 91.203 must be available to the PIC at the Ground Control Stat ion of the UAS any time the UAS is operating. These documents must be made available to the Administrator or any law enforcement official upon request. 29. The UA must remain clear and yield the right of way to all manned aviation operations and activities at all times.

30. The UAS may not be operated by the PIC from any moving device or vehicle.

31. Flight operations must be conducted at least 500 feet from all nonparticipating persons (persons other than the PIC, SO, operator trainees or essential persons), vessels, vehicles, and structures unless:

a. Barriers or structures are present that sufficien tly protect nonparticipating persons from the UA and/or debris in the event of an accident. The27 operator must ensure that nonparticipating persons remain under such protection. If a situation arises where nonparticipating persons leave such protection and are within 500 feet 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 PIC has made a safety assessment of the risk of operating closer to those objects and determined that it does not present an undue hazard, and;

c. Operations nearer to the PIC, SO, operator trainees or essential persons do not present an undue hazard to those persons p er § 91.119(a).

32. All operations shall be conducted over private or controlled

- access property with permission from the land owner/controller or authorized representative. Permission from land owner/controller or authorized representative will be obtained for each flight to be conducted.

33. Any incident, accident, or flight operation that transgresses the lateral or vertical boundaries of the operational area as defined by the applicable COA must be reported to the FAA's UAS Integration Office (AFS

- 80) within 24 hours. Accidents must be repor ted to the National Transportation Safety Board (NTSB) per instructions contained on the NTSB Web site: www.ntsb.gov

.

**2. Reasons Why An**  **Exemption From The Requirements Of Section 61.113(a) And (b) Would Not Adversely Affect Safety.** 

Air

- Reelz LLC submits that the equivalent level of safety established by
Section 61.113(a) and (b) will be maintained because no PIC will be allowed to oper ate the
DJI Inspire 1 UAS unless that PIC has demonstrated, by meeting minimum flight

- hour and
currency requirements, that the PIC is able to safely operate the DJI Inspire 1 UAS in a
manner consistent with the exemption, including evasive and emergency ma neuvers and
maintaining appropriate distances from people, vessels, vehicles and structures.

Considering Air

- Reelz LLC proposed area of operations, and the operating

limitations set forth

- above; the parallel nature of sport pilot aeronautical knowledge

re quirements to those of commercial pilot requirements ( See Exemption No.28

11062); and the airmanship skills necessary to safely operate the DJI Inspire 1 UAS, Air

Reelz LLC submits that the additional manned airmanship experience of a commercially

certifica ted pilot would not correlate to the airmanship skills necessary for Air

- Reelz LLC
specific proposed flight operations.

The FAA has previously granted relief from Section 61.113(a) and (b) specific to
UAS, in circumstances similar, in all material respect s, to those presented herein (e.g.

Exemption Nos. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 11112,

11136, 11138, 11150, 11153, 11156, 11158, 11159, 11160, 11161).

Air

- Reelz LLC will not allow any PIC to operate the DJI Inspire 1 UAS unless that
PIC has demonstrated, by meeting minimum flight

- hour requirements or the DJI Inspire 1
UAS training and currency requirements, that the PIC is able to safely operate the DJI
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 co nsistent
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 addition to the hour requirements,
the PIC must accomplish 3 takeoffs and landings in the preceding 90 days (for currency
purposes).
As in Exemption Nos. 11062, 11138, and 11153, prior documented flight experience that was obtained in compliance with applicable regulations w ill ensure an
equivalent level of safety during Air

- Reelz LLC 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 follo ws:29 In Exemption No. 11062, the FAA required that prior to conducting operations for the purpose of motion picture filming (or similar operations), the PIC must have accumulated and logged, in a manner consistent with 14 CFR 61.51(b), 25 hours of total ti me as a UAS rotorcraft pilot including at least 10 hours logged as a UAS pilot with a multi

- rotor UAS. Prior to operations under Exemption No. 11062, the PIC must also have accumulated and logged a minimum 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 FAA 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. In addition to the hour requirements, the PIC must accomplish 3 takeoffs and landings in the preceding 90 days (for currency purposes). The FAA finds that at a minimum, the fl ight

- hour requirements in Exemption No. 11062 are appropriate to practice and build proficiency in the skills necessary to safely conduct the petitioner’s proposed operations. The FAA also finds that prior documented flight experience that was obtained in compliance with applicable regulations would satisfy this requirement. Training, proficiency, and experience

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

- building flights the PIC is required to operate the UA with appropriate distances in accordance with 14 C.F.R 91.119.

Exemption No. 11138 at page 15.

Accordingly, Air

- Reelz will ensure safe operations by not allowing any PIC to
operate the DJI Inspire 1 UAS unless that PIC has demonstrated, by meeting minimum
flight

- hour and currency requirements, that the PIC is able to safely operate the DJI Inspire
1 UAS in a manner consistent with the exemption, including evasive and emergency

maneuvers and maintaining appropriate distances from people, vessels, vehicles and

structures.

**3. Reasons Why An Exemption From The Requirements Of Section 91.7(a)**  **Would Not Adversely Affect Safety.**

The equivalent level of safety established by Section 91.7(a) will be maintained because prior to every flight, Air

- Reelz LLC will ensure that the DJI Inspire 1 UAS is in
an airworthy condition based upon the UAS’s compliance with its operating documents

and as stated in the conditions and limitations herein.30 Additionally, the FAA has previously granted relief from Section 91.7(a) specific to
UAS, in circumstances similar, in all material respects, to those presented herein (e.g.
Exemption Nos. 11062, 110 63, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 11112,

11136, 11138, 11150, 11153, 11156, 11157, 11158, 11159, 11160, 11161).

**4. Reasons Why An Exemption From The Requirements Of Section 91.121**  **Would Not Adversely Affect Safety.**

The equivalent lev el of safety established by Section 91.121 will be maintained
because the altitude information of the DJI Inspire 1 UAS will be provided to the PIC via
GPS equipment and a radio communications telemetry data link, which downlinks from

the UAS to the GCS fo r active monitoring of the flight path and altitude. This altitude

information, combined with Air

- Reelz LLC’s operation of the DJI Inspire 1 UAS within
visual line of sight, at or below 500 feet AGL, will ensure a level of safety equivalent to

Section 91.1 21. The altitude information will be generated by GPS equipment installed
onboard the aircraft. Prior to each flight, a zero altitude initiation point is automatically
established by the UASs at ground level.

The FAA has previously granted relief from Sec tion 91.121 specific to UAS, in
circumstances similar, in all material respects, to those presented herein (e.g. Exemption

Nos. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11112, 11136, 11138,

11150, 11153, 11156, 11157, 11158, 11159, 11160, 11161).

**5. Reasons Why An Exemption From The Requirements Of Section 91.151(b)**  **Would Not Adversely Affect Safety.**

A grant of this exemption would ensure an equivalent level of safety established by 14 C.F.R. Section 91.151(b) as a result of (1) the technical specifications of the DJI Inspire
1 UAs; (2) the limitations on the proposed flight operations; and (3) the location of the
proposed flight operations. Accordingly, Air

- Reelz will ensure that it wi ll safely operate31

the battery powered DJI Inspire 1 UA during daylight hours in VFR conditions, with
enough battery power to fly for a total duration of 13.5 minutes to the first point of
intended landing and, assuming normal cruising speed, to fly after t hat for at least 4.5

minutes.

Here, as in Exemption No. 11109, the technical specifications of the DJI Inspire 1
UAS; the limitations on the proposed flight operations; and the location of the proposed
operations, will ensure an equivalent level of safety established by 14 C.F.R. Section
91.151(b). Furthermore, safety will be ensured as the DJI Inspire 1 UAS provide audible
and visual warnings to the PIC at the GCS when the UAs experiences low battery voltage,
the first warning occurring at approximately 3 3% remaining battery power, and again at
approximately 10% remaining battery power. At the critically low battery level, the DJI
Inspire 1 UAS will descend and land automatically.

Significantly, previous exemptions granted by the FAA concerning Section 91 .151
establish that safety is not adversely affected when the technical characteristics and
operating limitations of the UAS are considered. Relief has been granted for manned
aircraft to operate at less than the minimums prescribed in Section 91.151, incl uding

Exemption Nos. 2689, 5745, and 10650. Moreover, the FAA has previously granted relief
from Section 91.151 specific to UAS, in circumstances similar, in all material respects, to
those presented herein (e.g. Exemption Nos. 8811, 10808, 10673, 11042, 11062, 11063,

11064, 11065, 11066, 11067, 11080, 11109, 11110, 11136, 11138, 11150, 11153, 11156,

11157, 11158, 11159, 11160, 11161).

**6. Reasons Why An 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 Adversely Affect Safety.**32 In seeking this exemption, Air

- Reelz LLC submits that the equivalent level of
safety with regard to the regulatory maintenance and alteration requirements established by

Sections 91.405(a), 91.407(a)(1) , 91.409(a)(1) & (a)(2), and 91.417(a) & (b) will be met

because Air

- Reelz LLC will use trained technicians to perform maintenance, alterations, or
preventive maintenance on the UAS using the methods, techniques, and practices
prescribed in the operating d ocuments (i.e., the DJI Inspire 1

Maintenance Manual, Monthly Maintenance Log, and DJI Inspire 1 Instruction Manual).

Furthermore, Air

- Reelz LLC will document and maintain all maintenance records for the
DJI Inspire 1 UAS.

Since the DJI Inspire 1 UAS wil l be inspected as prescribed by the operating

documents, Air

- Reelz LLC will maintain the equivalent level of safety established by
Sections 91.405(a), 91.409(a)(1), and 91.409(a)(2). A copy of the DJI
Inspire 1 User Manuals are attached hereto as Exhibit B; a copy of the DJI Inspire 1
Maintenance Manual is attached hereto as Exhibit C; a copy of the DJI Inspire 1 UAS

Maintenance LOG is attached hereto as Exhibit D.

Likewise, the exemption sought will not adversely affect safety because Air

- Reelz

LLC will use trained technicians to perform maintenance, alterations or preventive
maintenance on the UAS using the methods, techniques, and practices prescribed by the
operating documents.
Furthermore, the exemption sought would maintain an equivalent level of sa fety
established by Sections 91.407, 91.417(a) and 91.417(b), because all maintenance of the
DJI Inspire 1 UAS will be performed by trained technicians. Maintenance will be
documented and maintained utilizing the monthly maintenance log.33 Significantly, pr evious exemptions 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 adversely affected when the technical characteristics and operating limitations of

the UAS are considered.

In consideration of Air

- Reelz LLC proposed operating limitations, the operating
documents, and the technical aspec ts of the DJI Inspire 1 UAS, Air

- Reelz LLC submits
that safety will not be adversely affected by granting exemption from

14 C.F.R. Sections 91.405(a), 91.407(a)(1) and (a)(2), 91.409(a)(2), and 91.417(a) and (b).
The FAA has previously granted relief spec ific to UAS in circumstances similar, in all
material respects, to those presented herein (e.g. Exemption Nos. 11062, 11063, 11064,

11065, 11066, 11067, 11080, 11109, 11110, 11112, 11136, 11138, 11150,

11153, 11156, 11157, 11158, 11159, 11160, 11161).

**7. The FAA May Prescribe Any Other Conditions For Safe Operation.** 

In accordance with Section 333 of the FAA Modernization and Reform Act of
2012 (FMRA) and 14 C.F.R. § 21.16 entitled Special Conditions, Air

- Reelz LLC requests
that the FAA prescribe spe cial conditions for the intended operation of the DJI Inspire 1
UAS, which contain such safety standards that the Administrator finds necessary to
establish a level of safety equivalent to that established by 14 C.F.R. Part 21, Subpart H,

and 14 C.F.R §§ 6 1.113(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). Such special conditions will permit safe
operation of the UAs for the limited purpose of conducting aerial video and photography

over certain areas of the United States for compensation or hire. FMRA Section 333 sets

forth the requirements for considering whether a UAS will create a hazard to users of the34

NAS or the public, or otherwise pose a threat to national security; and further, provides the
authority for such UAS to operate without airworthiness certification in accordance with
any requirements that must be established for the safe operation of the UAS in the NAS.

Likewise, the Administrator may prescribe special conditions pursuant to 1 4 C.F.R.

§ 21.16, for operation of the 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 Conditions, states
the following:

If the FAA finds that the airworthiness regulations of this subchapter do not contain adequate or appropriate safety standards for an aircraft, aircraft engine, or propeller because of a novel or unusual design feature of the aircraft, aircraft engine or propeller, he prescribes special conditions and amendments thereto for the product. The special conditions are issued in accordance with Part 11 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 with FMRA Section 333 and 14 C.F.R. § 21.16, the FAA
may prescribe specia l conditions for Leading Edge’s intended operation of the DJI Inspire
1 UAS, which contain such safety standards that the Administrator finds necessary to
establish a level of safety equivalent to that established by 14 C.F.R. Part 21,

Subpart H, and 14 C .F.R Sections 61.113(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 Air**

**- Reelz LLC Seeks Exemption:** 

A ir

- Reelz LLC seeks exemption from the requirements of 14 C.F.R Sections 61.101(e)(4) and (5), 61.315(a), 61.23(a), 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 Air** 

**- Reelz LLC Seeks:** 35 This exemption will permit Air

- Reelz LLC to commercially operate an Unmanned Aircraft System (UAS) for the purpose of conducting aerial video and photography over certain areas of the United States.

**G. Any Additional Info**  **rmation, Views, Or Arguments Available To Support Air**

  ** Reelz LLC Request.**

This Petition is made pursuant to the FAA Modernization and Reform Act of 2012
(FMRA) Section 333, which directs the Secretary of Transportation to determine if certain
UAS may op erate safely in the NAS. As such, Air

- Reelz LLC request for exemption may
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 requirements for considering whether a UAS will
create a hazard to users of the NAS or the public, or otherwise pose a threat to national
security; and further, provides the authority for such UAS to operate without airworthiness

certification.

As discussed in detail above, Air

- Reelz LLC will operate the DJI Inspire 1 UASs
safely in the NAS, without creating a hazard to users of the NAS, or the public, or
otherwise pose a threat to national security.

**CONCLUSION**

As set forth herein, Air

- Reel z LLC seeks an exemption pursuant to 14 C.F.R § 11.61

and Section 333 of the FAA Modernization and Reform Act of 2012 (FMRA), which will
permit safe operation of the DJI Inspire 1 UAS commercially, without an airworthiness
certificate, for the limited purp ose of conducting aerial video and photography over certain
areas of the United States. By granting this Petition, the FAA

Administrator will be fulfilling the Congressional mandate of the FAA Modernization and
Reform Act of 2012, while also advancing the interests of the public, by allowing Air

-36

Reelz LLC to safely, efficiently, and economically operate the 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, Air

- Reelz LLC respectfully
requests that the Administrator grant this Petition for an exemption from the requirements

of 14 C.F.R Sections 61.101(e)(4) and (5), 61.315(a), 61.23(a), 91.7(a), 91.121, 91.151(b),

91.405(a), 91.407(a)(1) , 91.409(a)(1) & (a)(2), and 91.417(a) & (b), and permit Air

- Reelz
LLC to operate the DJI Inspire 1 UAS commercially for the purpose of conducting aerial
video and photography over areas of the United States.

Dated: June 23rd , 2015

Respectfully submitted
, Christopher Earle

- Handley

Christopher Earle

- Handley Air

- Reelz LLC 22 Country Club Drive Apt 29 Manchester, NH 03102 Tel: (978) 347

- 5964 Email: info@air

- reelz.com

Exhibits :

A

– DJI Inspire 1 Specifications Data Sheet B

– DJI Inspi

re 1 Manufacturer’s User Manual C

– DJI Inspire 1 Maintenance Manual D

– Monthly Maintenance Log37 EXHIBIT

– A

DJI Inspire 1 Specifications Data Sheet38

Aircraft **Model**

T600 **Weight (Battery Included)** 2935 g **Hovering Accuracy (GPS Mode)**  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 Wind Speed Resistance**  10 m/s **Max Flight Time** Approximately 18 minutes **Motor Model** DJI 3510 **Propeller Model** DJI 1345 **Indoor Hovering** Enabled by default **Operating Temperature Range**

- 10° to 40° C **Diagonal Distance** 559 to 581 mm **Dimensions** 438x451x301 mm39

Gimbal **Model**

ZENMUSE X3 **Output Power (With Camera)** Static: 9 W In Motion: 11 W **Operating Current** Station: 750 mA Motion: 900 mA **Angular Vibration Range** ±0.03° **Mounting** Detachable **Controllable Range** Pitch:

- 90° to +30° Pan: ±320° **Mechanical Range** Pitch:

- 125° to +45° Pan: ±330° **Max Controllable Speed** Pitch: 120°/s Pan: 180°/s40

Camera **Name**

X3 **Model** FC350 **Total Pixels** 12.76M **Effective Pixels** 12.4M **Image Max Size** 4000x3000 **ISO Range** 100

- 3200 (video) 100

- 1600 (photo) **Electronic Shutter Speed**  8s

- 1/8000s **FOV (Field Of View)** 94° **CMOS** Sony EXMOR 1/2.3” **Lens** 20mm (35mm format equivalent)f/2.8 focus at ∞ 9 Elements in 9 groups Anti

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

- 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 Bitrat e Of Video Storage**  60 Mbps **Supported File Formats** 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 Temperature Range** 0° to 40° C41

Remote

Controller **Name**

C1 **Operating Frequency** 922.7~927.7 MHz (Japan Only) 5.725~5.825 GHz 2.400~2.483 GHz **Transmitting Distance (Outdoor And Unobstructed)** 2 km **EIRP** 10dBm@900m, 13dBm@5.8G, 20dBm@2.4G **Video Output Port** USB, mini

- 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 Width** 170mm **Output Power** 9 W **Operating Temperature Range**

- 10° to 40° C **Storage Temperature Range** Less than 3 months:

- 20° to 45° C More than 3 months: 22° to 28° C **Charging Temperature Range** 0

- 40° C **Battery** 6000 mAh LiPo 2S

Charger **Model**

A14

- 100P1A **Voltage** 26.3 V **Rated Power**  100 W42

Battery
(Standard) **Name**

Intelligent Flight Battery **Model** TB47 **Capacity** 4500 mAh **Voltage** 22.2 V **Battery Type** LiPo 6S High voltage battery **Energy** 99.9 Wh **Net Weight** 570 g **Operating Temperature Range**

- 10° to 40° C **Storage Temperature Range** Less than 3 months:

- 20° to 45° C More than 3 months: 22° C to 28° C **Charging Temperature 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 Environment** Brightly lit (lux > 15) patterned surfaces **Operating Range** 0

- 250 cm43 EXHIBIT

– B DJI Inspire 1 Manufacturer’s User Manual

http://download.dji

innovations.com/downloads/inspire_1/en/Inspire_1_User_Manual_v1.2_en.pdf44 Exhibit

– C DJI Inspire 1 Maintenance Manual

http://download.dji

innovations.com/downloads/inspire_1/en/Inspire_1_Maintenance_ManualV1.0_en.pdf45 EXHIBIT

– D

Monthly Maintenance Log EXHIBIT

– D
**MONTHLY MAINTENANCE LOG**

month: year:

**UAS #:** Date Issue Discovered Date Issue

Addressed Issue Description & Maintenance Conducted Maintenance Performed By: Print & Sign

Software Updates

Airframe

Engines

Propellers

Camera Gimbal

Landing Gear

Vibration Dampening

Other:46 Christopher Earle

- Handley Air

- Reelz LLC 22 Country Club Drive Apt 29 Manchester, NH 03102 Tel: (978) 347

- 596 Email: info@air

- reelz.com