FROM:

Mara Virabov Coastal Luxury Films 30101 Town Center Drive Suite #206 Laguna Niguel, CA 92677 Tel: 310-995-2475 Email: CoastalLuxuryFilms@gmail.com

TO:

DOCKET OPERATIONS ROOM W12-140 OF THE WEST BUILDING GROUND FLOOR 1200 NEW JERSEY AVENUE, SE. WASHINGTON, DC, 20590
Regulatory Docket No. _______________

PETITION FOR EXEMPTION OF: Coastal Luxury Films FOR AN EXEMPTION SEEKING RELIEF FROM THE REQUIREMENTS OF TITLE 14 OF THE CODE OF FEDERAL REGULATIONS PART 21, SUBPART H AND SECTIONS §§ 61.113(a) & (b), 91.109, 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), AND 91.417(a) & (b) CONCERNING COMMERCIAL OPERATION OF DJI PHANTOM 2 VISION + AND DJI PHANTOM 3 PROFESSIONAL UNMANNED AIRCRAFT SYSTEMS

PURSUANT TO SECTION 333 OF THE FAA MODERNIZATION AND REFORM ACT OF 2012 (PUBLIC LAW 112-95)

Submitted on April 23, 2015

Coastal Luxury Films Petition for Exemption Section 333 FAA 1TABLE OF CONTENTS

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 COASTAL LUXURY FILMS

SEEKS EXEMPTION.................................................................................................................8

THE EXTENT OF RELIEF COASTAL LUXURY FILMS SEEKS AND THE

REASON COASTAL LUXURY FILMS SEEKS THE RELIEF...........................................11
THE REASONS WHY GRANTING COASTAL LUXURY FILMS’ REQUEST

WOULD BE IN THE PUBLIC INTEREST ..........................................................................15

THE REASONS WHY GRANTING THE EXEMPTION WOULD NOT

ADVERSELY AFFECT SAFETY.............................................................................................19

SUMMARY THAT CAN BE PUBLISHED IN THE FEDERAL REGISTER.........................33
ANY ADDITIONAL INFORMATION, VIEWS, OR ARGUMENTS

CONCLUSION.........................................................................................................................33

Coastal Luxury Films Petition for Exemption Section 333 FAA 2GLOSSARY 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 Landing

Coastal Luxury Films Petition for Exemption Section 333 FAA 3SUMMARY Coastal Luxury Films (Mara Virabov) seeks exemption from the requirements of 14 C.F.R §§ 61.113(a) & (b), 91.109, 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a) (2), and 91.417(a) & (b), to operate an Unmanned Aircraft System pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (FMRA). This exemption will permit Coastal Luxury FIlms to operate an Unmanned Aircraft System (UAS) for the commercial purpose of conducting aerial video and photography of Real Estate Properties (for homeowners, realtors, home builders, home contractors and / or home inspectors for real estate marketing and inspection of home exteriors) as well as filming of special events, film sets, scripted and unscripted television sets and landscape over certain areas of the United States.

INTRODUCTION AND INTERESTS OF THE PETITIONER

Coastal Luxury Films is a production company based in California specializing in real estate videography, photography, music video production, special event production with plans to extend into film and television production. The principals of Coastal Luxury Films (parent company CBH Pictures LLC) have been in the video and entertainment production business for over ten years; have produced over 300 music videos and commercials, several reality television shows, award shows, concerts and special events. Coastal Luxury Films’ objective is to conduct aerial photography and videography in order to provide high quality digital imaging and video content to its clients, in particular to homeowners, real estate agents, realtors, home builders, home contractors, and/or home inspectors for real estate marketing and inspections of home exteriors utilizing DJI S Phantom 2 Vision + and/or DJI Phantom 3 UAS. More specifically, Coastal Luxury Films aerial video and photography operations will serve in the following areas:

• Aerial photography of houses / residential and commercial buildings

• Aerial videography of houses / residential and commercial buildings

• Aerial event photography • Aerial event filming • Aerial Film & Television production • Aerial location scouting and safety inspection

• Increase public knowledge of UAS and promote safe UAS operations.

Coastal Luxury Films Petition for Exemption Section 333 FAA 4The proposed aerial filming will be conducted over private property with controlled access in the NAS and with the knowledge and permit of the private property’s owner.

Unmanned Aircraft Systems: DJI Phantom 2 Vision+, Phantom 3 Professional UAS

Coastal Luxury Films seeks an exemption to operate DJI systems DRONES for compensation or hire within the NAS. The DJI Phantom 2 Vision+, Phantom 3 Professional are vertical takeoff and landing (VTOL) Unmanned Aircrafts (UAS) with a Ground Control Station (GCS) utilizing electronic tablet or smart phone systems. The DJI Phantom 2 Vision+, Phantom 3 Professional have a maximum gross weight of approximately 2 pounds 11 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 DJI Phantom 2 Vision+, Phantom 3 Professional UAS are equipped with four main rotors; driven by Lithium Polymer battery powered electric motors.

The DJI Phantom 2 Vision+, Phantom 3 Professional UAS that will be operated by Coastal Luxury Films (trained professional), will be registered in accordance with 49 U.S.C. 44103, Registration of Aircraft, as well as 14 C.F.R Part 47, Aircraft Registration, and marked in accordance with 14 C.F.R. Part 45, Identification and Registration Marking.

BASIS FOR PETITION

Petitioner, Coastal Luxury Films, 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 Phantom 2 Vision+, Phantom 3 UAS in the National Airspace System (NAS), and for an exemption from the requirements of 14 C.F.R §§ 61.113(a) & (b), 91.109, 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b).

In consideration of the speed, weight, size, and limited operating area associated

Coastal Luxury Films Petition for Exemption Section 333 FAA 5with the unmanned aircraft and its operation, Coastal Luxury Films operation of DJI Phantom 2 Vision+, Phantom 3 Professional UAS 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, Coastal Luxury Films 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 with an airworthiness certificate. Coastal Luxury Films submits that the requested relief is proper since an equivalent level of safety will be ensured. Coastal Luxury Films 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 Phantom 2 Vision+, Phantom 3 Professional Instruction Manual). Furthermore, Coastal Luxury Films will document and maintain all maintenance records for the DJI Phantom 2 Vision+ and Phantom 3 Professional UAS.

Relief from certain requirements of Section 61.113(a) and (b), entitled Private pilot privileges and limitations : Pilot In Command, is requested by Coastal Luxury Films to the extent necessary to allow a Pilot in Command (PIC) holding a Supplemental Pilot Certificate, and who has demonstrated, by meeting minimum flight- hour and currency requirements, that the PIC is able to safely operate the DJI Phantom 2 Vision+, Phantom 3 Professional UAS in a manner consistent with this exemption, including evasive and emergency maneuvers and maintaining appropriate distances from people, vessels, vehicles and structures.

Coastal Luxury Films seeks relief from Section 91.7(a), entitled Civil aircraft airworthiness , because the DJI Phantom 2 Vision+, Phantom 3 Professional UAS do not require an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H. As such, Coastal Luxury Films submits that it will ensure that the DJI Phantom 2 Vision+, Phantom 3 Professional UAS are in an airworthy condition, prior to every flight, by determining that the UASs are in compliance with the operating documents (i.e., Monthly Maintenance Log, and DJI Phantom 2 Vision+, Phantom 3 Professional Instruction Manual), and that the aircraft are in a condition for safe flight. Coastal Luxury Films also seeks an exemption from the requirements of Section

Coastal Luxury Films Petition for Exemption Section 333 FAA 691.121, entitled Altimeter Settings , as the DJI Phantom 2 Vision+, Phantom 3 Professional UAS will not have a typical barometric altimeter onboard. However, altitude information of the DJI Phantom 2Vision+, DJI Phantom 3 Professional 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 the flight path. This altitude information, combined with Coastal Luxury Films’ operation of the DJI Phantom 2 Vision+, Phantom 3 Professional UAS within visual line of sight, at or below 200 feet AGL, will ensure a level of safety equivalent to Section 91.121.

Additionally, Coastal Luxury Films seeks an exemption from the requirements of Section 91.151(b), entitled Fuel requirements for flight in VFR conditions. Coastal Luxury Films submits that safety will not be affected by operation of the DJI Phantom 2 Vision+, Phantom 3 Professional UA during daylight hours in visual meteorological conditions (VMC) under visual flight rules (VFR), with enough battery power to fly for a total duration of approximately 13.5 minutes to the first point of intended landing and, assuming normal cruising speed, to fly after that for at least 4.5 minutes.

In accordance with 14 C.F.R. § 11.81, Coastal Luxury Films 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: Mara Virabov Coastal Luxury Films (parent company CBH Pictures LLC) 30101 Town Center Drive Suite 206 Laguna Niguel, CA 92677 Tel: 310-995-2485 Email: coastalluxuryfilms@gmail.com

Coastal Luxury Films Petition for Exemption Section 333 FAA 7B. The Specific Sections Of 14 C.F.R. From Which Coastal Luxury Films Seeks Exemption. 1. Coastal Luxury Films Seeks Exemption From The Requirements Of Section 61.113(a) And (b). Section 61.113, entitled Private pilot privileges and limitations: Pilot in command, subsections (a) and (b) prescribe the following, in relevant part: (a) No person who holds a private pilot certificate may act as a pilot in command (PIC) of an aircraft that is carrying passengers or property for compensation or hire; nor may that person, for compensation or hire, act as PIC of an aircraft. (b) A private pilot 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. 2. Coastal Luxury Films 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.

3. Coastal Luxury Films Seeks Exemption From The Requirements Of Section 91.121. Section 91.121, entitled Altimeter settings, subsection (a), states the following, in part: (a) Each person operating an aircraft shall maintain the cruising altitude or flight level of that aircraft, as the case may be, by reference to an altimeter that is set, when operating-- (1) Below 18,000 feet MSL, to-- (i) The current reported altimeter setting of a station along the route and within 100 nautical miles of the aircraft; (ii) If there is no station within the area prescribed in paragraph (a)(1)(i) of this section, the current reported altimeter setting of an appropriate available station; or (iii) In the case of an aircraft not equipped with a radio, the elevation of the departure airport or an appropriate altimeter setting available before departure.

Coastal Luxury Films Petition for Exemption Section 333 FAA 84. Coastal Luxury Films Seeks Exemption From The Requirements Of Section 91.151(b). Section 91.151, entitled Fuel requirements for flight in VFR conditions, subsection (b), states the following: (b) No person may begin a flight in a rotorcraft under VFR conditions unless (considering wind and forecast weather conditions) there is enough fuel to fly to the first point of intended landing and, assuming normal cruising speed, to fly after that for at least 20 minutes.

5. Coastal Luxury Films Seeks Exemption From The Requirement Of Section 91.405(a). Section 91.405, entitled Maintenance required, subsection (a), states the following: Each owner or operator of an aircraft— (a) Shall have that aircraft inspected as prescribed in subpart E of this part and shall between required inspections, except as provided in paragraph (c) of this section, have discrepancies repaired as prescribed in part 43 of this chapter[.]

6. Coastal Luxury Films 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[.]

7. Coastal Luxury Films Seeks Exemption From The Requirements Of Sections 91.409(a)(1) And 91.409(a)(2). Section 91.409, entitled Inspections, subsection (a), states the following: (a) Except as provided in paragraph (c) of this section, no person 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

Coastal Luxury Films Petition for Exemption Section 333 FAA 9been approved for return to service by a person authorized by § 43.7 of this chapter; or (2) An inspection for the issuance of an airworthiness certificate in accordance with part 21 of this chapter.

8. Coastal Luxury Films 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. (iii) The time since last overhaul of all items installed on the aircraft which are required to be overhauled on a specified time basis. (iv) The current inspection status of the aircraft, including the time since the last inspection required by the inspection program under which the

Coastal Luxury Films Petition for Exemption Section 333 FAA 10aircraft 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 service.

C. The Extent Of Relief Coastal Luxury Films Seeks And The Reason Coastal Luxury Films Seeks The Relief. 1. Extent Of Relief Coastal Luxury Films Seeks And The Reason Coastal Luxury Films Seeks Relief From Section 61.113(a) And (b). Relief from Section 61.113(a) and (b) entitled Private pilot privileges and limitations: Pilot in command, is requested to the extent necessary to allow a PIC holding a Supplemental Pilot Certifiacte, 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 61.113(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

Coastal Luxury Films Petition for Exemption Section 333 FAA 11incidental 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, Coastal Luxury Films submits that an equivalent level of safety will be maintained because no PIC will be allowed to operate the DJI Phantom 2 Vision+, Phantom 3 Professional 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 Phantom 2 Vision+, Phantom 3 Professional 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, Coastal Luxury Films submits that all flights of the DJI Phantom 2 Vision+, Phantom 3 Professional UAS, conducted by the PIC pursuant to the grant of this Petition: (1) will be incidental to Coastal Luxury Films business; and (2) will not carry passengers or property for compensation or hire.

Coastal Luxury Films believes that though UAS are not traditional aircrafts, a PIC operating the UA must have knowledge of Airman rules, basic Airspace and comply with all the rules proposed by the FAA. However, considering the fact that a UA is almost like a toy, weighing less than a skinny person, the PIC may be except from obtaining a Private Pilot Certificate, a Sports Certificate, a Recreational Certificate considering these certificates require flight hours of several thousand tons weighing aircrafts. The operation of UAS by Coastal Luxury Films is strictly for entertainment / informational purposes, thus the operators of the UAS have a career and / or freelance employment as a Camera Operator and Cinematographer and will be not be entertaining a career as a pilot. Lastly, Coastal Luxury Films PICs will operate the UAS no higher than 200 feet, consequently causing no danger do any other aircraft in the NAS. However, Coastal Luxury Films Proposes PIC Certification as a Supplemental pilot and a minimum requirement of successfully completed private pilot ground school. Additionally, supplemental pilots without a current FAA private pilot

Coastal Luxury Films Petition for Exemption Section 333 FAA 12certificate must have successfully passed the private pilot, commercial pilot, or airline transport pilot knowledge test within the past 24 calendar months.

2. Extent Of Relief Coastal Luxury Films Seeks And The Reason Coastal Luxury Films Seeks Relief From Section 91.7(a). Relief from Section 91.7(a) entitled Civil aircraft airworthiness, is requested to the extent required to allow Coastal Luxury Films to determine that the DJI Phantom 2 Vision+, Phantom 3 UAS are in airworthy condition prior to every flight by ensuring that the UAS is in compliance with the operating documents (i.e., the Coastal Luxury Films Aerial Operations Manual, Monthly Maintenance Log, and DJI Phantom 2 Vision+, Phantom 3 Professional Instruction Manual). Coastal Luxury Films seeks the requested relief because the DJI Phantom 2 Vision+ UAS do not require an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H. Therefore, Coastal Luxury Films will ensure that the DJI Phantom 2 Vision+ UAS are in airworthy condition based upon its compliance with the operating documents (i.e., Monthly Maintenance Log, and DJI Phantom 2 Vision+, Phantom 3 Professional Instruction 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 Coastal Luxury Films Seeks And The Reason Coastal Luxury Films Seeks Relief From Section 91.121. Relief from Section 91.121, entitled Altimeter settings, may be required to allow flight operations of the DJI Phantom 2 Vision+, Phantom 3 Professional UAS, which utilize a barometric pressure sensor, GPS equipment, and a radio communications telemetry data link to downlink altitude information from the UA to the PIC at the ground control station (GCS). Since the FAA requires that any altitude information concerning UAS operations be reported to air traffic control (ATC) in feet above ground level (AGL), Coastal Luxury Films seeks the requested relief because the DJI Phantom 2 Vision+ UA’s altimeter may be set on the ground to zero feet AGL, rather than the local barometric pressure or field

Coastal Luxury Films Petition for Exemption Section 333 FAA 13altitude, 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 Phantom 2 Vision+, Phantom 3 Professional 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 provides the PIC with altitude information of the UA on the heads-up display of the GCS.

4. Extent Of Relief Coastal Luxury Films Seeks And The Reason Coastal Luxury Films Seeks Relief From Section 91.151(b). Relief from Section 91.151(b) entitled Fuel requirements for flight in VFR conditions, is requested to the extent required to allow flights of the battery powered DJI Phantom 2 Vision+, Phantom 3 Professional UAS during daylight hours in visual meteorological conditions (VMC), under visual flight rules (VFR), for a total duration of 13.5 minutes to the first point of intended landing and, assuming normal cruising speed, to fly after that for at least 4.5 minutes. Coastal Luxury Films seeks the requested relief because without an exemption from Section 91.151(b), the flight time duration of the battery powered DJI Phantom 2 Vision+, Phantom 3 UA will severely constrain the practicality of any aerial video or still photo flight operations that Coastal Luxury Films proposes to conduct pursuant to this Petition. Significantly, as set forth below, the technical specifications of the DJI Phantom 2 Vision+ UAS, the DJI Phantom 2 Vision+, Phantom 3 Professional operating documents, and Coastal Luxury Films proposed operating limitations, ensure that Coastal Luxury Films will safely operate the battery powered DJI Phantom 2 Vision+, Phantom 3 Professional 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.

Coastal Luxury Films Petition for Exemption Section 333 FAA 14! ! 5. Extent Of Relief Coastal Luxury Films Seeks And The Reason Coastal Luxury Films Seeks Relief From Section 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), And 91.417(a) & (b). Since Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b) only apply to aircraft with an airworthiness certificate, Coastal Luxury Films requests relief from these Sections because the DJI Phantom 2 Vision +, Phantom 3 Professional UAS do not require airworthiness certificates. As set forth more fully below, the DJI Phantom 2 Vision+, Phantom 3 Professional UAS meet the conditions of FMRA Section 333 for operation without an airworthiness certificate. Accordingly, Coastal Luxury Films will use trained technicians to perform maintenance, alterations, or preventive maintenance on the UAS using the methods, techniques, and practices prescribed in the UAS operating documents (i.e., the Coastal Luxury Films Aerial Operations Manual, Monthly Maintenance Log, and DJI Phantom 2 Vision+, Phantom 3 Professional Instruction Manual). Furthermore, Coastal Luxury Films will document and maintain all maintenance records for the DJI Phantom 2 Vision+, Phantom 3
UAS.

D. The Reasons Why Granting Coastal Luxury Films 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 Coastal Luxury Films to safely, efficiently, and economically perform aerial video and photography of real estate, special events, film sets, and landscape over certain areas of the United
States. Additionally, use of the DJI Phantom 2 Vision+, Phantom 3 Professional UAS will decrease congestion of the NAS, reduce pollution, and provide significant benefits to the economy. Notably, the benefits of Coastal Luxury Films’ proposed operation of the DJI Phantom 2 Vision, Phantom 3+ UAS will be realized without implicating any privacy issues. 1. The Public Will Benefit From Decreased Congestion Of The NAS.

Coastal Luxury Films Petition for Exemption Section 333 FAA 15The DJI Phantom 2 Vision+, Phantom 3 Professional UA 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 Phantom 2 Vision+, Phantom 3 UAS would reduce the amount of manned aircraft in the NAS, reduce noise and air pollution, as well as increase the safety of life and property in the air and on the ground. Furthermore, by reducing the number of manned aircraft operating in the NAS, congestion around airports caused by arriving and departing aircraft will be reduced. The DJI Phantom 2 Vision+, Phantom 3 Professional UA 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 Phantom 2 Vision+, Phantom 3 UAS. Conducting aerial acquisitions with the DJI Phantom 2 Vision+, Phantom 3 Professional 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 power and electric motors, the DJI Phantom 2 Vision+, Phantom 3 Professional UAS produce no air pollution, and is the most viable environmentally conscious alternative to the cabin class, six cylinder internal combustion engine aircraft that are typically utilized for aerial video and photography, while burning approximately 20-30 gallons per hour of leaded aviation fuel. The DJI Phantom 2 Vision+, Phantom 3 Professional UA, while reducing the carbon footprint of aerial acquisitions, also eliminates noise pollution, as the UAS are propelled by battery powered electric motors, rather than an internal combustion engine. By using the DJI Phantom 2 Vision+, Phantom 3 Professional UAS to perform aerial acquisitions, the substantial risk to life and property in the air and

Coastal Luxury Films Petition for Exemption Section 333 FAA 16on 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, the DJI Phantom 2 Vision+, Phantom 3 UAS (weighing approximately 2 pounds 11 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 respectively, 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 Phantom 2 Vision+, Phantom 3 UAS Will Benefit The Economy. In addition to being safe and efficient, the DJI Phantom 2 Vision+, Phantom 3 Professional is also an economical alternative to using manned aircraft to conduct similar aerial operations. As such, operation of the DJI Phantom 2 Vision+, Phantom 3 Professional UAS will allow United States based companies, like Coastal Luxury Films, 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 battery powered DJI Phantom 2 Vision+, Phantom 3 Professional UAS is one such technology that not only allows companies greater operational flexibility compared to manned aircraft, but provides such flexibility without the high operational cost of a traditional manned aircraft. By operating the DJI Phantom 2 Vision+, Phantom 3 Professional UAS, companies such as Coastal Luxury Films, 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

Coastal Luxury Films Petition for Exemption Section 333 FAA 17performance of U.S. companies, through commercial use of the DJI Phantom 2 Vision +, Phantom 3 Professional UAS, provides a stable workforce that increases consumer spending; improves local, state, and federal tax revenues; and allows companies to invest in research and development in order to remain competitive both in the United States and abroad.

4. There Are No Privacy Issues. Similar to the manned aerial acquisition flight operations that have been conducted for decades, Coastal Luxury Films proposed operation of the DJI Phantom 2 Vision+, Phantom 3 UAS will not implicate any privacy issues. Specifically, the DJI Phantom 2 Vision+, Phantom 3 Professional UAS will be operated only in compliance with operating documents (i.e., the Coastal Luxury Films Aerial Operations Manual, Monthly Maintenance Log, and DJI Phantom 2 Vision+, Phantom 3 Professional Instruction Manual) which requires property owner involvement as well as local law enforcement notification, and in accordance with the Federal Aviation Regulations, including the minimum altitude requirements of 14 C.F.R. § 91.119.

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

1. Reasons Why The DJI Phantom 2 Vision+, Phantom 3 Professional UAS 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, Coastal Luxury Films operation of the DJI Phantom 2 Vision+, Phantom 3 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 a hazard to users of the NAS or the public, or otherwise pose a threat to national security.

Coastal Luxury Films Petition for Exemption Section 333 FAA 18Specifically, 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 rule-making 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) Requirements for Safe Operation.--If the Secretary determines under this section that certain unmanned aircraft systems may operate safely in the national airspace system, the Secretary shall establish requirements for the safe operation of such aircraft systems in the national airspace system. In seeking this exemption, Coastal Luxury Films submits that the DJI Phantom 2 Vision+ UAS can operate safely in the NAS pursuant to FMRA Section 333, as demonstrated by: (a) the characteristics of the DJI Phantom 2 Vision+, Phantom 3 Professional UAS; (b) the pilot certification requirement; and (c) the specific operating limitations.

a. The Specifications Of The DJI Phantom 2 Vision+, Phantom 3 Professional UAS Demonstrate Its Safe Characteristics.

Coastal Luxury Films Petition for Exemption Section 333 FAA 19The DJI Phantom 2 Vision+, Phantom 3 Professional UAS does not create a hazard to users of the NAS or the public, or otherwise pose a threat to national security considering its size, weight, speed, and operational capability.

i. Technical Specifications Of The DJI Phantom 2 Vision+, Phantom 3 Professional UAS. The technical specifications of the DJI Phantom 2 Vision+, Phantom 3 Professional UAS is set forth by the DJI Phantom 2 Vision+, Phantom 3 Professional Specifications and Data Sheet, attached hereto as Exhibit A.

ii. The DJI Phantom 2 Vision+, Phantom 3 Professional UAS Autonomous Flight And Navigation Modes Enable The UAS To Remain Within A Defined Operational Area. The DJI Phantom 2 Vision+, Phantom 3 Professional UAS may be operated in both manual and fully autonomous flight modes. A complete description of the flight and navigational modes of the DJI Phantom 2 Vision+, Phantom 3 UAS is provided at pages 25-35 of the DJI Phantom 2 Vision+, User Manual, attached hereto as Exhibit B & D (Phantom 3 User Manual will be available after May 15, 2015; however, is very similar to DJI Phantom 2 Vision+ User Manual).

iii. The DJI Phantom 2 Vision+, Phantom 3 Professional 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 Phantom 2 Vision+ UA will remains stationary, in flight, for 3 seconds or more. If, after 3 seconds, the DJI Phantom 2 Vision+, Phantom 3 Professional UA does not reacquire control link data from the GCS, the UA will assume that the Control Link is lost and the UA will return to the home position (i.e., failsafe mode) via GPS, and will descend to the takeoff position and shutdown. A complete description of the Failsafe Functions of the DJI Phantom 2 Vision+, Phantom 3 UAS are set forth at

Coastal Luxury Films Petition for Exemption Section 333 FAA 20pages 27 through 29 of the DJI Phantom 2 Vision+, (Phantom 3) Professional User Manual, attached hereto as B & D.

iv. The DJI Phantom 2 Vision+, Phantom 3 Professional GCS And Its Operation. A complete description of the operation and specifications of the DJI Phantom 2 Vision+, Phantom 3 GCS and flight control software is provided at pages 32 through 43 of the DJI Phantom 2 Vision+, (Phantom 3) Professional User Manual. DJI Phantom 2 Vision+ User Manual is attached hereto as Exhibit B & D.

b. Flight Operations Of DJI Phantom 2 Vision+, Phantom 3 Professional UAS Are Limited To The Line Of Sight Of A Certificated Pilot in Command With A Safety Observer. Coastal Luxury Films 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 Phantom 2 Vision, Phantom 3 + UAS. Additionally, a safety observer will assist all pilots during flight time.

c. Flights Of DJI Phantom 2 Vision+, Phantom 3 Professional UAS Will Be Conducted Pursuant To Specific Operating Limitations. In seeking this exemption, proposes to commercially operate DJI Phantom 2 Vision+ UAS for the special purpose of conducting aerial video and photography 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: DJI Phantom 2 Vision+, Phantom 3 Professional Unmanned Aircraft System. Proposed operations of any other aircraft will require a new petition or a petition to amend this grant.

Coastal Luxury Films Petition for Exemption Section 333 FAA 212. UAS operations under this exemption will be limited to conducting operations for the purpose of aerial video and photography for homeowners, Realtors, home builders, contractors, home inspectors for use in real estate marketing and real estate inspections. Additionally, aerial video and photography may be conducted on occasional basis for film and television sets, special events and landscape photography as deemed
necessary.

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

4. The UAS must be operated at an altitude of no more than 200 (500 per the User Manual) feet above ground level (AGL), as indicated by the procedures specified in the operating documents unless a special request is made and approved by 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 her designation for the duration of the flight. The PIC must ensure that the SO can perform the functions prescribed in the operating documents.

Coastal Luxury Films Petition for Exemption Section 333 FAA 228. 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 conditions and limitations contained in the grant of exemption and the procedures outlined in the operating documents, the conditions and limitations contained in the grant of exemption take precedence and must be followed. Otherwise, the operator must follow the procedures as outlined in its operating documents. The operator may update or revise its operating documents. It is the operator’s responsibility to track such revisions and present updated and revised documents to the Administrator upon request. The operator must also present updated and revised documents if it petitions for extension or amendment to the grant of exemption. If the operator determines that any update or revision would affect the basis upon which the FAA granted the exemption, then the operator must petition for amendment to its grant 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 ensure that it is in a condition for safe flight. If the inspection reveals a condition that affects the safe operation of the UAS, the aircraft is prohibited from operating until the necessary 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 properly documented in the aircraft records.

11. Any UAS that has undergone maintenance or alterations that affect the UAS operation or flight characteristics, e.g. replacement of a flight critical component, must undergo a functional test flight. The PIC who conducts the

Coastal Luxury Films Petition for Exemption Section 333 FAA 23functional test flight must make an entry in the aircraft records.

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

13. The operator must follow the UAS 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 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, description of work accomplished, and the signature of the authorized person returning the UAS to service.

15. Each UAS operated under this exemption must comply with all manufacturer Safety Bulletins.

16. The authorized person must make an entry in the aircraft record of the corrective action taken against discrepancies discovered between inspections.

17. The PIC must possess at least a Suplemental Pilot certificate and at least a current third- class medical certificate. Supplemental pilots must have, at a minimum, successfully completed private pilot ground school. Additionally, supplemental pilots without a current FAA private pilot certificate must have successfully passed the private pilot, commercial pilot, or airline transport pilot knowledge test within the past 24 calendar months.

18. The operator may not permit any PIC to operate unless the PIC meets the operator’s qualification criteria and demonstrates the ability to safely operate

Coastal Luxury Films Petition for Exemption Section 333 FAA 24the 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 the operator’s PICs are permitted under the terms of the exemption. However, training operations may only be conducted during dedicated training sessions. During training, proficiency, and experience-building flights, all persons not essential for flight operations are considered nonparticipants, and the PIC must operate the UA with appropriate distance from nonparticipants in accordance with 14 C.F.R. § 91.119.

19. UAS operations may not be conducted during night, as defined in 14 C.F.R. § 1.1. All operations must be conducted under visual meteorological 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 cloud or when visibility is less than 3 statute miles from the
PIC.

22. If the UA loses communications or loses its GPS signal, it must return to a predetermined location within the planned operating area and land or be recovered

Coastal Luxury Films Petition for Exemption Section 333 FAA 25in accordance with the operating 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) there is enough power to fly at normal cruising speed to the intended landing point and land the UA with 25% battery power remaining.

25. The operator must obtain an Air Traffic Organization (ATO) issued Certificate of Waiver 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 (NOTAM) not more than 72 hours in advance, but not less than 48 hours prior to the operation. All operations shall be conducted in accordance with airspace requirements 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 accordance with 14 C.F.R. part 47, and have identification (N- Number) markings in accordance with 14 C.F.R. part 45, Subpart C. Markings must be as large as practicable.

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

28. The documents required fewer than 14 C.F.R. 91.9 and 91.203 must be available to the PIC at the Ground Control Station of the UAS any time the UAS is operating. These documents must be made available to the Administrator or any law enforcement official upon request.

Coastal Luxury Films Petition for Exemption Section 333 FAA 2629. The UAS must remain clear and yield the right of way to all manned aviation operations and activities at all times.

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

31. Flight operations must be conducted at least 500 feet from all nonparticipating persons (persons other than the PIC, SO, operator trainees or essential persons), vessels, vehicles, and structures unless: a. Barriers or structures are present that sufficiently protect nonparticipating persons from the UA and/or debris in the event of an accident. The operator must ensure that nonparticipating persons remain under such protection. If a 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 per § 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 reported to the National Transportation Safety Board (NTSB) per instructions contained on the NTSB Web site: www.ntsb.gov

.

Coastal Luxury Films Petition for Exemption Section 333 FAA 272. Reasons Why An Exemption From The Requirements Of Section 61.113(a) And (b) Would Not Adversely Affect Safety.

Coastal Luxury Films 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 operate the DJI Phantom 2 Vision+, Phantom 3 Professional UAS unless that PIC has demonstrated, by meeting minimum flighthour and currency requirements, that the PIC is able to safely operate the DJI Phantom 2 Vision +, Phantom 3 Professional UAS in a manner consistent with the exemption, including evasive and emergency maneuvers and maintaining appropriate distances from people, vessels, vehicles and structures. Considering Coastal Luxury Films proposed area of operations, and the operating limitations set forth-above; the parallel nature of private pilot aeronautical knowledge requirements to those of commercial pilot requirements (See Exemption No. 11062); and the airmanship skills necessary to safely operate the DJI Phantom 2 Vision+, Phantom 3 Professional UAS, Coastal Luxury Films submits that the additional manned airmanship experience of a commercially certificated pilot would not correlate to the airmanship skills necessary for Coastal Luxury Films specific proposed flight operations. The FAA has previously granted relief from Section 61.113(a) and (b) specific to UAS, in circumstances similar, in all material respects, to those presented herein (e.g. Exemption Nos. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 11112, 11136, 11138, 11150, 11153, 11156, 11158, 11159, 11160, 11161).

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, Coastal Luxury Films will ensure that the DJI Phantom 2 Vision+ UAS is in an airworthy condition based upon the UAS’s compliance with its operating documents and as stated in the conditions and limitations herein. Additionally, the FAA has previously granted relief from Section 91.7(a) specific to UAS, in circumstances similar, in all material respects, to those presented herein (e.g.

Coastal Luxury Films Petition for Exemption Section 333 FAA 28Exemption Nos. 11062, 11063, 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 level of safety established by Section 91.121 will be maintained because the altitude information of the DJI Phantom 2, Vision, Phantom 3 + UA will be provided to the PIC via GPS equipment and a radio communications telemetry data link, which downlinks from the UA to the GCS for active monitoring of the flight path and altitude. This altitude information, combined with Coastal Luxury Films’ operation of the DJI Phantom 2 Vision+, Phantom 3 UAS within visual line of sight, at or below 500 feet AGL, will ensure a level of safety equivalent to Section 91.121. The altitude information will be generated by GPS equipment installed onboard the aircraft. Prior to each flight, a zero altitude initiation point is automatically established by the UASs at ground level. The FAA has previously granted relief from Section 91.121 specific to UAS, in circumstances similar, in all material respects, to those presented herein (e.g. Exemption Nos. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11112, 11136, 11138, 11150, 11153, 11156, 11157, 11158, 11159, 11160, 11161).
5. Reasons Why An Exemption From The Requirements 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 Phantom 2 Vision+, Phantom 3 UAS; (2) the limitations on the proposed flight operations; and (3) the location of the proposed flight operations. Accordingly, Coastal Luxury Films will ensure that it will safely operate the battery powered DJI Phantom 2 Vision+, Phantom 3 Professional 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 that for at least 4.5 minutes. Here, as in Exemption No. 11109, the technical specifications of the DJI Phantom 2

Coastal Luxury Films Petition for Exemption Section 333 FAA 29Vision+, Phantom 3 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 Phantom 2 Vision+, Phantom 3 Professional 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 33% remaining battery power, and again at approximately 10% remaining battery power. At the critically low battery level, the DJI Phantom Vision+, Phantom 3 UAS will descend and land automatically. Significantly, previous exemptions granted by the FAA concerning Section 91.151 establish that safety is not adversely affected when the technical characteristics and operating limitations of the UAS are considered. Relief has been granted for manned aircraft to operate at less than the minimums prescribed in Section 91.151, including Exemption Nos. 2689, 5745, and 10650. 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.

In seeking this exemption, Coastal Luxury Films 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 Coastal Luxury FIlms will use trained technicians to perform maintenance, alterations, or preventive maintenance on the UAS using the methods, techniques, and practices prescribed in the operating documents (i.e., the Coastal Luxury Films Aerial Operations Manual, Monthly Maintenance Log, and DJI Phantom 2 Vision+, Phantom 3 Professional Instruction Manual). Furthermore, Coastal Luxury Films will document and maintain all maintenance records for the DJI Phantom 2 Vision+, Phantom 3 Professional UAS. Since the DJI Phantom 2 Vision+, Phantom 3 Professional UAS will be inspected as prescribed by the operating documents, Coastal Luxury Films will maintain the equivalent level of safety

Coastal Luxury Films Petition for Exemption Section 333 FAA 30established by Sections 91.405(a), 91.409(a)(1), and 91.409(a)(2). A copy of the DJI Phantom 2 Vision+ User Manual is attached hereto as Exhibit B & D; a copy of the DJI Phantom 2 Vision+, Phantom 3 UAS Maintenance LOG is attached hereto as Exhibit C. Likewise, the exemption sought will not adversely affect safety because Coastal Luxury Films 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 safety established by Sections 91.407, 91.417(a) and 91.417(b), because all maintenance of the DJI Phantom 2 Vision+, Phantom 3 Professional UAS will be performed by trained technicians. Maintenance will be documented and maintained utilizing the monthly maintenance log. Significantly, previous exemptions granted by the FAA concerning Sections 91.405(a), 91.407(a)(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 Coastal Luxury Films proposed operating limitations, the operating documents, and the technical aspects of the DJI Phantom 2 Vision +, Phantom 3 Professional UAS, Coastal Luxury Films 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 specific to UAS in circumstances similar, in all material respects, to those presented herein (e.g. Exemption Nos. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 11112, 11136, 11138, 11150, 11153, 11156, 11157, 11158, 11159, 11160, 11161).

7. The FAA May Prescribe Any Other Conditions For Safe Operation. In accordance with Section 333 of the FAA Modernization and Reform Act of 2012 (FMRA) and 14 C.F.R. § 21.16 entitled Special Conditions, Coastal Luxury Films requests that the FAA prescribe special conditions for the intended operation of the DJI Phantom 2 Vision+, Phantom 3 UAS, which contain such safety standards that the Administrator finds necessary to establish a level of safety equivalent to that established by 14 C.F.R. Part 21, Subpart H, and 14 C.F.R §§ 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). Such special conditions will permit safe

Coastal Luxury Films Petition for Exemption Section 333 FAA 31operation 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 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 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 14 C.F.R. § 21.16, for operation of the DJI Phantom 2 Vision+, Phantom 3 Professional 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 special conditions for Coastal Luxury Films’ intended operation of the DJI Phantom 2 Vision+, Phantom 3 UAS, which contain such safety standards that the Administrator finds necessary to establish a level of safety equivalent to that established by 14 C.F.R. Part 21, Subpart H, and 14 C.F.R Sections 61.113(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 Coastal Luxury Films Seeks Exemption: Coastal Luxury Films seeks exemption from the requirements of 14 C.F.R Sections 61.113(a)&(b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b).

Coastal Luxury Films Petition for Exemption Section 333 FAA 32A Brief Description Of The Nature Of The Exemption Coastal Luxury FIlms Seeks: This exemption will permit Coastal Luxury Films 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 Information, Views, Or Arguments Available To Support Coastal Luxury Films 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 operate safely in the NAS. As such, Coastal Luxury Films 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, Coastal Luxury Films will operate the DJI Phantom 2 Vision +, Phantom 3 Professional UAS safely in the NAS, without creating a hazard to users of the NAS, or the public, or otherwise pose a threat to national security.

CONCLUSION

As set forth herein, Coastal Luxury Films 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 Phantom 2 Vision+, Phantom 3 Professional UAS commercially, without an airworthiness certificate, for the limited purpose of conducting aerial video and photography over certain areas of the United States. By granting this Petition, the 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 Coastal Luxury Films to safely, efficiently, and economically operate the DJI Phantom 2, Phantom 3 Vision+ UAS commercially within the NAS.

WHEREFORE, in accordance with the Federal Aviation Regulations and the FAA

Coastal Luxury Films Petition for Exemption Section 333 FAA 33Modernization and Reform Act of 2012, Section 333, Coastal Luxury Films respectfully requests that the Administrator grant this Petition for an exemption from the requirements of 14 C.F.R Sections 61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b), and permit Coastal Luxury Films to operate the DJI Phantom 2 Vision +, Phantom 3 Professional UAS commercially for the purpose of conducting aerial video and photography of Real Estate Properties (for homeowners, realtors, home builders, home contractors and / or home inspectors for real estate marketing and inspection of home exteriors) as well as filming of special events, film sets, scripted and unscripted television sets and landscape over certain areas of the United States.

Dated: April 23, 2015 Respectfully submitted by, Mara Virabov

_________________________ Mara Virabov Coastal Luxury Films

(CBH Pictures LLC) 30101 Town Center Drive Suite #206 Laguna Niguel, CA 92677 Tel: 310-995-2475 Email: CoastalLuxuryFilms@gmail.com

Coastal Luxury Films Petition for Exemption Section 333 FAA 34Appendixes: A – DJI Phantom 2 Vision+ Specifications Data Sheet B – DJI Phantom 2 Vision+ Manufacturer’s User Manual C – DJI Phantom 3 Professional Specifications Data Sheet D – DJI Phantom 3 Manufacturer’s User Manual E – Monthly Maintenance Log

APPENDIX – A

DJI PHANTOM 2 VISION+ TECHNICAL SPECIFICATIONS
Coastal Luxury Films only utilizes safe and reliable UASs. DJI is an industry leader in small UAS production. DJI UASs are loaded with ground breaking software enabling the user to 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, DJI software provides real-time altitude and location information to the PIC via the linked monitor (smart phone/tablet devices)

1.1 DJI Phantom 2 Vision+

1.1.1 Aircraft 1.1.1.1 Supported Battery – DJI 5200mAH LiPo Battery 1.1.1.2 Weight (Battery & Propellers Included) – 2lbs 11.810oz (1242g) 1.1.1.3 Hover Accuracy (Ready to Fly) – Vertical: .8m; Horizontal: 2.5m 1.1.1.4 Max Yaw Angular Velocity - 200 0 /s 1.1.1.5 Max Tilt Angel - 35 0 1.1.1.6 Max Ascent Speed – 6m/s 1.1.1.7 Max Descent Speed – 2m/s 1.1.1.8 Max Flight Speed – 15m/s (NOT RECOMMENDED)

1.1.2 Gimbal 1.1.2.1 Working Current – Static: 750mA; Dynamic: 900mA 1.1.2.2 Control Accuracy - ±0.03 0 1.1.2.3 Controllable Range – Pitch: -90 0 - 0 0 1.1.2.4 Maximum Angular Speed – Pitch: 90 0 /s

1.1.3 Camera 1.1.3.1 Operating Temperature Range - 32 0 F - 104 0 F (0 0 C - 40 0 C) 1.1.3.2 Sensor Size – 1/2.3” 1.1.3.3 Effective Pixels – 14M

Coastal Luxury Films Petition for Exemption Section 333 FAA 351.1.3.4 Resolution – 4384x3288 4.1.3.5 HD Video Recording – 1080p30 & 720p 4.1.3.6 Recording Field of View - 110 0 /85 0 1.1.4 Transmitter 1.1.4.1 Operating Frequency – 5.728GHz – 5.85GHz 1.1.4.2 Communication Distance (unobstructed) – FCC Compliance: 800m 1.1.4.3 Receiver Sensitivity (1%PER) - -93dBm 1.1.4.4 Transmitter Power – FCC Compliance: 100mW
1.1.4.5 Working Voltage – 120mA@3.7V
1.1.5 Range Extender 1.1.5.1 Operating Frequency – 2412-2462MHz 1.1.5.2 Communication Distance (unobstructed) – 500-700m 1.1.5.3 Transmitter Power – 20dBm 1.1.5.4 Power Consumption – 2W

Coastal Luxury Films Petition for Exemption Section 333 FAA 36APPENDIX – B DJI Phantom 2 Vision+ Manufacturer’s User Manual

(uploaded in a separate attachment, a 72-page document)

Coastal Luxury Films Petition for Exemption Section 333 FAA 37APPENDIX – C

DJI PHANTOM 3 TECHNICAL SPECIFICATIONS

AIRCRAFT


### Weight (Including Battery And Propellers) 1280 g
Diagonal Size (Including Propellers) 590 mm
Max Ascent Speed 5 m/s
Max Descent Speed 3 m/s
Hover Accuracy

• Vertical: +/- 10cm

• Horizontal: +/- 1m

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

Max Altitude Above Sea Level 6000 m
Operating Temperature 0°C to 40°C
Gps Mode GPS/GLONASS

GIMBAL


### Controllable Range Pitch -90° to +30°

Stabilization 3-axis (pitch, roll, yaw)

Coastal Luxury Films Petition for Exemption Section 333 FAA 38REMOTE CONTROLLER


### Operating Frequency **2.400 GHz-2.483 GHz**

**Max Distance 2000m (outdoors and unobstructed)** 
**Video Output Port USB** 
**Operating Temperature 0°C- 40°C** 
**Battery 6000 mAh LiPo 2S** 

**Mobile Device Holder For tablet or phone** 
**Receiver Sensitivity (1%Per) -101 dBm ±2 dBm** 
**Transmitter Power (Eirp)**

• FCC: 20 dBm

• CE: 16 dBm

**Working Voltage 1.2 A @7.4 V** 

BATTERY CHARGER


### Voltage **17.4 V**

**Rated Power Phantom 3 Professional 100 W** 

Coastal Luxury Films Petition for Exemption Section 333 FAA 39INTELLIGENT FLIGHT BATTERY


### Capacity 4480 mAh
**Voltage 15.2 V** 
**Battery Type LiPo 4S** 
**Energy 68 Wh** 
**Net Weight 365 g** 
**Max Flight Time Approximately 23 minutes** 
**Operating Temperature -10°C to 40°C** 
**Max Charging Power 100 W** 

Coastal Luxury Films Petition for Exemption Section 333 FAA 40APPENDIX – D DJI Phantom 3 Professional Manufacturer’s User Manual

(DJI Phantom 3 Professional Manual will be available after May 15, 2015. Coastal Luxury Films ordered DJI Phantom 3 Professional UA and will expect shipping after May 15, 2015 along with

the User Manual. The User Manual of DJI Phantom 3 Professional is very similar to the User Manual of DJI Phantom 2 Vision +, with several minor changes, in particular of the quality of the camera attached to the device. For more information please refer to attachment (Appendix - B) which provides the complete manual of DJI Phantom 2 Vision + UA.)

Coastal Luxury Films Petition for Exemption Section 333 FAA 41APPENDIX – E

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:

Mara Virabov Coastal Luxury Films (CBH Pictures LLC) 30101 Town Center Drive Suite #206 Laguna Niguel, CA 92677 Tel: 310-995-2475 Email: CoastalLuxuryFilms@gmail.com

Coastal Luxury Films Petition for Exemption Section 333 FAA 42