UNITED STATES OF AMERICA DEPARTMENT OF TRANSPORTATION FEDERAL AVIATION ADMINISTRATION WASHINGTON, DC

Regulatory Docket No. _______________

IN THE MATTER OF THE PETITION FOR EXEMPTION OF: THE GOODWYN GROUP , LLC FOR AN EXEMPTION SEEKING RELIEF FROM THE REQUIREMENTS OF TITLE 14 OF THE CODE OF FEDERAL REGULATIONS SECTIONS 45.27 (a), 61.113(a) & (b), 91.7(a), 91.105, 91.119 (c), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), AND 91.417(a) & (b) C ONCERNING COMMERCIAL OPERATION OF DJI PHANTOM SERIES , DJI INSPIRE , DJI S

800 , DJI S

- 900 and DJI S

- 1000 UNMANNED AIRCRAFT SYSTEMS PURSUANT TO SECTION 333 OF THE FAA MODERNIZATION AND REFORM ACT OF 2012 (PUBLIC LAW 112

- 95)
Re: Request for Exemption under Section 333 of the FAA Modernization and Reform Act and Part 11 of the Federal Aviation Regulations from 14 C.F.R. 45.27 (a), 61.113(a) & (b), 91.7(a), 91.105, 91.119 (c), 91.121, 91.151(b), 91.405(a), 91.407(a )(1), 91.409(a )(1) & (a)(2), and 91.417(a) & (b).

Submitted on May 22 , 2015

Rich ard W. Goodwyn 42762 Hollowind Ct. Broadlands, VA 20148 Tel: ( 703 ) 606

- 39782 TABLE OF CONTENTS
Page

GLOSSARY OF ABBREVIATIONS...................................................................................3

SUMMARY...................................................................................................................... .....4

INTRODUCTI ON AND INTERESTS OF PETITIONER....................................................4

BACKGROUND...................................................................................................................

. 5

BASIS FOR PETITION......................

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

NAME AND ADDRESS OF PETITIONER............................................................. 8

THE SPECIFIC SECTIONS OF 14 C.F.R. FROM WHICH THE GOODWYN GROUP, LLC SEEKS EXEMPTION.................................................................

...... 9

THE EXTENT OF RELIEF GOODWYN GROUP, LLC SEEKS AND THE REASON GOODWYN GROUP, LLC SEEKS THE RELIEF......................... ...14

THE REASONS WHY GRANTING GOODWYN GROUP, LLC ’S REQUEST WOULD BE IN THE PUBLIC INTEREST .........................................................1 9

THE REASONS WHY GRANTING THE EXEMPTION WOULD NOT ADVERSELY AFFECT SAFETY.......................................................................... 2 3

SUMMA RY THAT CAN BE PUBLISHED IN THE FEDERAL REGISTER......3 9
ANY ADDITIONAL INFORMATION, VIEWS, OR ARGUMENTS AVAILABLE TO SUPPORT GOODWYN GROUP, LLC’S REQUEST.........

... 39

CONCLUSION...................................................................................................................

. 40 Rich Goodwyn 5/29/2015 6:51 AM Deleted: 8

Rich Goodwyn 5/29/2015 6:52 AM

Deleted: 23 GLOSSARY OF ABBREVIATIONS

AGL Above Ground Level
AOI Area of Interest
ATC Air Traffic Control
ATO Air Traffic O rganization
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 o f 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
SUAS Small Unmanned Aircraft System
UA Unmanned Aircraft
UAS Unmanned Aircraft System
VFR Visual Flight Rules
VLOS Visual Line of Site
VMC Visual Meteorological Conditions
VO Visual Observer
VTOL Vertical Takeoff and Landing4 SUMMARY
The Goodwyn Group, LLC seeks exemption from the requirements of 14 C.F.R §§
45.27 (a), 61.113(a) & (b), 91.7(a), 91.105, 91.119 (c), 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 Unmanned Aircraft
Systems pursuant to Section 333 of the FAA Modernization and Reform Act of 2012
(FMRA). This exemption will permit The Goodwyn Group, LLC to operate Unmanned
Aircraft System s (UAS) for the commercial purpose of conducting aerial data collection of

construction sit es, real estate, and landscape over certain areas of the United States , and

la unch from a moving vessel such as a boat for the commercial purpose of aerial data

collection of motor vessels and sailing vessels over open waters.

INTRODUCTION AND INTERESTS O F THE PETITIONER
The Goodwyn Group, LLC (dba Orion Aerial Solutions) is a Service Disabled
Veteran Owned Small Business and is operated by Richard Goodwyn. Mr. Goodwyn is a
retired Naval Aviator and FAA licensed commercial pilot with single/ multiengine land and
instrument ratings. He also holds a First Class Medical Certificate. He has been piloting

for 35 yea r with over 3500 flight hours and has been active in model radio controlled
aviation for 10 years with a focus on aerial data collecti on

. Mr. Goodwyn is also an active
member of the Academy of Model Aeronautics (AMA) and the Director of Veteran
Outreach for the DC Area Drone Users Group (DCDUG).
The objective of The Goodwyn Group, LLC’s aerial data collection operation s is to
provide high quality imaging for a variety of comme rcial, public, and residential uses,
specifically targeting:

• I nspections of P ublic and P rivate S tructures5 • Aerial Acquisition (Mapping)

• Real Estate, Construction Sites, Vineyards

• Motor and Sailing Vessels on Open Waters

• Film and Cinematography Work

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

BACKGROUND Unmanned Aircraft Systems: DJI Phantom Series , DJI Inspire , DJI S800 , DJI S900 and
DJI S1000 UASs The Goodwyn Group, LLC seeks an exemption to operate DJI systems for compensation or hire within the NAS. The DJI Phantom Series , DJI Inspire, DJI S800 , DJI
S900 and DJI S1000 are vertical takeoff and landing (VTOL) Unmanned Aircraft (UA) with a Ground Control Station (GCS) utilizing electronic table t or smart phone sy stems. The DJI Phantom Series has 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 Inspire 1 has a maximum gross weight of 6 pounds 7.5 ounces, a length of 17.3 inches, width of 17.7 inches, height of 11.8 inches, and a maximum speed of approximately 42 knots. The DJI Phantom Series and DJI Inspire UAs are equipped with four main rotors; driven by Li thium Polymer battery powered electric motors.
The DJI S8 00 is a radio controlled electric powered (battery) carb on fiber hexacopter measuring 19.685 inches high by 39.37 inches wid e . It weighs 11 pounds empty and 15.4 pounds with the camera and battery. The aircraft carries a Sony Nex 7 camera or similar device, stabilized by a three axis gimbal. The sUAS will operate at speeds no greater than 30 knots. The DJI S900 is a professional grade, 6

- blade airframe weighing l ess than 1 8 lb at take off. It has an estimated 18

- minute flight time @1 5 000mAh and 1 5 lb take off weight

. It has a diagonal wheelbase of appx 3 feet

. The aircraft carries a Sony Nex 7 camera or similar device, stabilized by a three axis gimbal. The sUAS will operate at speeds no greater than 40 knots. It is controlled via remote control operating on a digital 2.4ghz Rich Goodwyn 5/29/2015 6:29 AM Deleted: 1 Rich Goodwyn 5/29/2015 6:29 AM Deleted: 15oz Rich Goodwyn 5/29/2015 6:35 AM Deleted: 5 Rich Goodwyn 5/29/2015 6:36 AM Deleted: 1 Rich Goodwyn 5/29/2015 6:36 AM Deleted: 15oz6 signal. Because this is a digital signal, and not analog, interference from other 2.4ghz signals would not pose a safety risk or loss of aircraft control.
The DJI S1000 is a multi

- rotor octocopter. This UAS has been engineered and is considered a professional class UAS. It has a maximum take off weight of 25 lbs and a max speed of 45 knots. It is controlled via remote control operating on a digital 2.4ghz signal. Because this is a digital signal, and not analog, interference from other 2.4ghz signals would not pose a safety risk or loss of aircraft control.
The DJI Phantom Series , DJI Inspire, DJI S800 , DJI S900 and DJI S1000 UA S s that will be operated by The Goodwyn Group, 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, The Goodwyn Group, 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 Phantom Series , DJI Inspire 1 , DJI S800 , DJI S900 and DJI S1000 UASs in the National Airspace System (NAS), and for an exemption from the requirements of 14 C.F.R §§ 45.27 (a), 61.113(a) & (b), 91.7(a), 91.105, 91.119 (c), 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, The Goodwyn Group, LLC’s operation of
DJI Phantom Series , DJI Inspire, DJI S800 , DJI S900 and DJI S1000 UASs meets the conditions of FMRA Section 333 and therefore, will not require an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H. Accordingly, The Goodwyn Group, 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 with an airworthiness certificate. The Goodwyn Group, LLC submits that the requested r elief is proper since an equivalent level of safety will be ensured. The Goodwyn Group, LLC will use experienced Rich Goodwyn 5/29/2015 6:41 AM Deleted:7 personnel or technicians to perform maintenance, alterations, or preventive maintenance on the UASs using the methods, techniques, and practice s prescribed in the operating documents (i.e., DJI Phantom Series , DJI Inspire, DJI S800 , DJI S900 and DJI S1000
Instruction Manual s ). Furthermore, The Goodwyn Group, LLC will document and
maintain all maintenance records for the DJI Phantom Series , DJI In spire, DJI S800 , DJI
S900 and DJI S1000 UASs. Relief from certain requirements of Section 61.113(a) and (b), entitled Private pilot privileges and limitations: Pilot in command , is requested by The Goodwyn Group, LLC to the extent necessary to allow a Pilot in Command (PIC) holding a sport pilot, recreation pilot, private pilot or higher level certificate, as well as an airman medical certificate or valid driver’s license , and who has demonstrated, by meeting minimum f light

- hour and currency requirements, that the PIC is able to safely operate the DJI Phantom Series , DJI Inspire, DJI S800 , DJI S900 and DJI S1000 UASs in a manner consistent with this exemption, including evasive and emergency maneuvers and maintaining a ppropriate distances from people, vessels, vehicles and structures unless prior coordination and authorization has been given by the FAA

. The Goodwyn Group, LLC seeks relief from Section 91.7(a), entitled Civil aircraft
airworthiness , because the DJI Phan tom Series , DJI Inspire, DJI S800 , DJI S900 and DJI
S1000 UASs do not require an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H. As such, The Goodwyn Group, LLC submits that he will ensure that the
DJI Phantom Series , DJI Inspire , DJI S800 , DJI S900 and DJI S1000 UASs 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 Series , DJI Inspire, DJI S800 , DJI S900 and DJI S1000 Instruction Manual s ), and that the aircraft are in a condition for safe flight. The Goodwyn Group, LLC also seeks an exemption from the requirements of
Section 91 .121, entitled Altimeter Settings , as the DJI Phantom Series , DJI Inspire, DJI
S800 , DJI S900 and DJI S1000 UAs will not have a typical barometric altimeter onboard. However, altitude information of the DJI Phantom Series , DJI Inspire, DJI S800 , DJI S900
and DJI S1000 UAs will be provided to the PIC via Global Positioning System (GPS) equipment and radio communications telemetry data link, which downlinks from the UA to8 the GCS for active monitoring of the flight path. This altitude information, combined with The Goodwyn Group, LLC’s operation of the DJI Phantom Series , DJI Inspire, DJI S800 , DJI S900 and DJI S1000 UASs within visual line of sight, at or below 500 feet AGL, will ensure a level of safety equivalent to Section 91.121. Additionally, The Goodwyn Group, LLC seeks an exemption from the requirements of Sectio n 91.151(b), entitled Fuel requirements for flight in VFR conditions

. The Goodwyn Group, LLC submits that safety will not be affected by operation of the DJI
Phantom Series , DJI Inspire, DJI S800 , DJI S900 and DJI S1000 UA S s during daylight
hours in visual meteorological conditions (VMC) under visual fli ght rules (VFR) as t he PIC is prohibited from beginning a flight unless (considering wind and forecast weather conditions) there is enough available power for the UA to conduct the intended operation
and to operate after that for at least 5 minutes or with the reserve power recommended by the manufacturer if greater. In addition to the above request, The Goodwyn Group, LLC requests consideration for operations from a watercraft on the water. Under “Summary o f Major Provisions of Proposed Part 107 Operation Limitations, “No operations from a moving vehicle or aircraft, except from a watercraft on the water” is being proposed and already has an established safety case. The Goodwyn Group, LLC would like to condu ct operations in such a manner as is consistent with the proposed rule. The Goodwyn Group, LLC will ensure safety measures are in place, to include communication with the operator of the vessel and the crew, and training on visual cues such as relative mot ion

. In accordance with 14 C.F.R. § 11.81, The Goodwyn Group, LLC 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:
Rich ard W. Goodwyn 42762 Hollowind Ct. Broadlands, VA 20148 Tel: ( 703) 606

- 3978 Email: rwgoodwyn@gmail.com9 B. The Spec ific Sections Of 14 C.F.R. From Which The Goodwyn Group, LLC Seeks Exemption.

1. The Goodwyn Group, LLC Seeks Exemption From The Requirements Of
Section 45.27 (a).

Section 45.27 (a), entitled Location of marks; non fixed

- wing aircraft, subsection (a) prescribe the following with respect to lettering :

(a) Rotorcraft. Each operator of a rotorcraft must display on that rotorcraft horizontally on both surfaces of the cabin, fuselage, boom, or tail the marks required by Section 45.23.

2

. The Goodwyn Group, LLC 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 pr operty 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 on ly incidental to that business or employment; and (2) The aircraft does not carry passengers or property for compensation or hire.

3

. The Goodwyn Group, LLC Exemption From The Requirements Of Section 91.7(a).10 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.
4

. The Goodwyn Group, LLC Exemption From The Re quirements Of Section
91.105. Section 91.105, entitled Flight crewmember at station, states the following: (a) During takeoff and landing, and while en route, each required flight
crewmember shall

- (1) Be at the crewmember station unless the absence is necessary to perform duties in connection with the operation of the aircr aft or in connection with physiological needs; and (2) Keep the safety belt fastened while at the crewmember station. (b) Each required flight crewmember of a U.S.

– registered civil aircraft shall, during takeoff and landing, keep his or her shoulder harness
fast ened while at his or her assigned duty station. This paragraph does not apply if

– (1) The seat at the crewmember’s station is not equipped with a shoulder harness; or, (2) The crewmember would be unable to perform required duties with
the shoulder harness fastened.
5

. The Goodwyn Group, LLC Exemption From Th e Requirements Of Section 91.110(c)

. Section 91.11 9 (c), entitled Minimum safe a ltitudes, subsection (c), states the following: (c) Over other than congested areas, a n altitude of 500 feet above the surface, except over open water or sparsely populated areas. In those cases, the aircraft may not be operated closer than 500 to any person, vessel, vehicle or

structure.
6

. The Goodwyn Group, LLC Exemption From The Requirements Of Section
91.121.11 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 depart ure.

7

. The Goodwyn Group, 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 available power for the UA to conduct the intended operation and to operate after that for at least 5 minutes or with the reserve power recommended by the manufacturer if greater.12 8

. The Goodwyn Group, LLC 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[.]

9

. The Goodwyn Group, 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[.]

10

. The Goodwyn Group, 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 section, no person may operate
an aircraft u nless, 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 of this chapter.13 11

. The Goodwyn Group, 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 s 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, roto r, 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 n umber 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.14 (iv) The cur rent inspection status of the aircraft, including the time since

the last inspection required by the inspection program under which the aircraft and its appliances are maintained.

(v) The current status of applicable airworthiness directives (AD) and
safe ty 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 prescri bed 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 speci fied 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 wi th 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 The Goodwyn Group, LLC Seeks And The Reason The Goodwyn Group, LLC Seeks The Relief.

1. Extent Of Relief The Goodwyn Group, LLC Seeks And The Reason The Goodwyn Group, LLC Seeks Relief From Section 45.27 (a).15 Relief from Section 45.27 (a) entitled Location of marks; non fixed

- wing aircraft , is requested to the extent necessary to allow The Goodwyn Group, LLC the ability to mark the aircraft with lettering as large as practicable (14 C.F.R. Section 45. 29(f)) on its largest
available surface so as to permit such marking to be displayed to pilot, crew, and others both when the aircraft are on the ground, and airborne. The airframes utilized by the petitioner are of insufficient size to accommodate such markings as prescribed, thus marking the airframes would not be possible.

2 . Extent Of Relief The Goodwyn Group, LLC Seeks And The Reason The Goodwyn Group, LLC 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 sport pilot, recreation pilot, private pilot or higher level certificate, as well as a current and
valid airman medical certificate or driver’s license , and who has met certain flight

- hour and currency requirements, to conduct the proposed UAS flight operations for compensation or hire. Furthermore, The Goodwyn Group, LLC requests that certificate holders of a higher degree are authorized to enact the privileges of the lesser ce rtificate, ie a commercial pilot license holder can utilize the sport pilot privileges of their license so long as their have a valid U.S. d river’s license and meet the requirements of the sport pilot
license. 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 airc raft does not carry passengers or property for compensation or hire. As set forth more fully below, The Goodwyn Group, LLC submits that an equivalent level of safety will be maintained because no PIC will be allowed to operate the
DJI Phantom Series , DJI Inspire 1, DJI S800 , DJI S900 and/or DJI S1000 UAS unless that
PIC has met certain training, flight

- hour and currency requirements, demonstrating that the PIC is able to safely operate ei ther the DJI Phantom Series , DJI Inspire 1 , DJI S800 , DJI
S900 and/or DJ I S1000 UAS in a manner consistent with the operations specifications as16 described in this exemption, including evasive and emergency maneuvers, as well as maintaining appropriate distances from people, vessels, vehicles and structures. Further, The Goodwyn Group, LLC submits that all flights of the DJI Phantom
Series , DJI Inspire, DJI S800 , DJI S900 and DJI S1000 UAS, conducted by the PIC pursuant to the grant of this Petition: (1) will be incidental to The Goodwyn Group, LLC’s business; and (2) will not carry passengers or property for compensation or hire.

3 . Extent Of Relief The Goodwyn Group, LLC Seeks And The Reason The Goodwyn Group, LLC 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 The Goodwyn Group, LLC to determine that the DJI Phantom
Series , DJI Inspire, DJI S800 , DJI S900 and DJI S1000 UASs are in airworthy condition prior to every flight by ensuring that the UAS is in compliance wi th the operating
documents

. (i.e., DJI Phantom Series , DJI Inspire, DJI S800 , DJI S900 and DJI S1000 Instruction Manual). The Goodwyn Group, LLC seeks the requested relief because the DJI Phantom
Series , DJI Inspire, DJI S800 , DJI S900 and DJI S1000 UASs do not require an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H. Therefore, The Goodwyn Group, LLC will ensure that the DJI Phantom Series , DJI Inspire, DJI S800 , DJI
S900 and DJI S1000 UASs are in airworthy condition base d upon its compliance with the operating documents (i.e ., Monthly Maintenance Log, and DJI Phantom Series , DJI Inspire, DJI S800 , DJI S900 and DJI S1000 Instruction Manual) prior to every flight, and further, determine that the aircraft are in condition fo r safe flight, as stated in the
conditions and limitations below.

4 . Extent Of Relief The Goodwyn Group, LLC Seeks And The Reason The Goodwyn Group, LLC Seeks Relief From Section 91.105

.

Relief from Section 91.105, entitled Flight crewmembers at stations , requires pilot and crew to be at their duty stations and harnessed during flight. Petitioner seeks exemption from the Section 91.105 because the airframes utilized by the petitioner are , by17 definition , unmanned aircraft, having neither pilot nor crew so as to be stationed or harnessed as required by regulations. An equivalent level of safety can be provided instead by using an unmanned aircraft controlled by a PIC who at all times is located at, and controls the airframes from visual line of sight at all times.

5 . Extent Of Relief The Goodwyn Group, LLC Seeks And The Reason The Goodwyn Group, LLC Seeks Relief From Section 91.119(c)

.

Relief from Section 91. 119(c), entitled Minimum safe altitudes , establishes safe altitudes for operation of civil aircraft over other than congested areas. Petitioner seeks exemption from subsection 91.119(c) because, pursuant to this Petition, the sUAS will at time be operated at or below 400 feet AGL. An equivalent or even higher level of safety can be provided inst ead by, as provided herein, operating so as to de

- conflict with manned vehicles operating above 500 feet AGL, within VLOS of the PIC with the assistance of a VO so as to ensure the safety
of and de

- confliction with any persons or property in the air and on the ground, including participating and non

- participating personnel, 100 feet and 500 feet, respectively, away from who the UA would generally be restricted. Further, the sUAS flight operations will be monitored at all times by both the PIC and VO and wil l be in compliance with public safety requirements, so as to prevent access to the restricted areas of operation. The FAA has set precedence by previously granted exemptions in circumstances similar in all material respects, to those presented herein.

6

. Extent Of Relief The Goodwyn Group, LLC Seeks And The Reason The Goodwyn Group, LLC 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 Series , DJI Inspire, DJI S800 , DJI S900 and DJI
S1000 UASs, 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). Sin ce the FAA requires that any altitude18 information concerning UAS operations be reported to air traffic control (ATC) in feet above ground level (AGL), The Goodwyn Group, LLC seeks the requested relief because
the DJI Phantom Series , DJI Inspire, DJI S800 , DJI S900 and DJI S1000 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 sou ght 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 Series , DJI Inspire, DJI S800 , DJI S900 and DJI
S1000 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 displa y of
the GCS.

7 . Extent Of Relief The Goodwyn Group, LLC Seeks And The Reason The Goodwyn Group, LLC 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 Series , DJI Inspire, DJI S800 , DJI S900 and DJI S1000 UAs during daylight hours in visual meteorological conditions (VMC), under visual flight rules (VFR), n o
person m ay begin a flight in a rotorcraft under VFR conditions unless (considering wind and forecast weather conditions) there is enough available power for the UA to conduct the intended operation and to operate after that for at least 5 minutes or with the reserve power recommended by the manufacturer if greater

. The Goodwyn Group, LLC seeks the requested relief because without an exemption from Section 91.151(b), the flight time duration of the battery powered DJI Phantom Series , DJI Inspire, DJI S800 , DJI S900 and
DJI S1000 UAs will severely constrain the practicality of any aerial video or still photo flight operations that The Goodwyn Group, LLC proposes to conduct pursuant to this
Petition.19 Significantly, as set forth below, the technical specifications of the DJI Phantom
Series , DJI Inspire, DJI S800 , DJI S900 and DJI S1000 UASs, the DJI Phantom Series , DJI Inspire, DJI S800 , DJI S900 and DJI S1000 operating documents, and The Goodwyn Group, LLC’s proposed operating limitations, ensure that The Goodwyn Group, LLC will safely operate the battery powered DJI Phantom Series , DJI Inspire, DJI S800 , DJI S900
and DJI S1000 UAs during daylight hours in visual meteorological conditions (VMC), under visual flight rules (VFR). No person may begin a flight in a rotorcraft under VFR
conditions unless (considering wind and forecast weather conditions) there is enough available power for the UA to conduct the intended operation and to operate after that for at least 5 minutes or with the reserve power recommended by the manufacturer if greater.

8 . Extent Of Relief The Goodwyn Group, LLC Seeks And The Reason The Goodwyn Group, 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), and 91.417(a) & (b) only apply to aircraft with an airworthiness certificate, The Goodwyn Group, LLC requests relief from these Sections because the DJI Phantom Series , DJI Inspire, DJI S800 , D JI
S900 and DJI S1000 UASs do not require airworthiness certificates. As set forth more fully below, the DJI Phantom Series , DJI Inspire, DJI S800 , DJI S900 and DJI S1000 UASs meet the conditions of FMRA Section 333 for operation without an airworthiness

c ertificate. Accordingly, The Goodwyn Group, LLC will perform maintenance, alterations, or preventive maintenance on the UASs using the methods, techniques, and practices prescribed in the UAS operating documents (i.e., DJI Phantom Series , DJI Inspire, DJI
S800 , DJI S900 and DJI S1000 Instruction Manual). Furthermore, The Goodwyn Group,
LLC will document and maintain all maintenance records for the DJI Phantom Series , DJI Inspire, DJI S800 , DJI S900 and DJI S1000 UASs.

D. The Reasons Why Granting The Goodwyn Group, LL C’s Request Would Be In The Public Interest; That Is, How It Would Benefit The Public As A Whole.20 Granting the present Petition will further the public interest by allowing The Goodwyn Group, LLC to safely, efficiently, and economically provide high quality imaging for a variety of commercial, public, and residential uses, specifically targeting inspections of public and private structures, aerial acquisition (mapping), real estate, construction sites, vineyards, motor and sailing vessels on open waters and to increase public knowledge of UAS and promote safe UAS operations. Additionally, use of the DJI Phantom Series , DJI Inspire, DJI S800 , DJI S900 and
DJI S1000 UASs will decrease congestion of the NAS, reduce pollution , and provide significant benefits to the economy. Notably, the benefits of The Goodwyn Group, LLC’s proposed operation of the DJI Phantom Series , DJI Inspire, DJI S800 , DJI S900 and DJI
S1000 UASs will be realized without implicating any privacy issues.

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

The DJI Phantom Series , DJI Inspire, DJI S800 , DJI S900 and DJI S1000 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 data collection , an exemption all owing the use of t he DJI
Phantom Series , DJI Inspire, DJI S800 , DJI S900 and DJI S1000 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,

conge stion around airports caused by arriving and departing aircraft will be reduced. The
DJI Phantom Series , DJI Inspire, DJI S800 , DJI S900 and DJI S1000 UAs do not require an airport to takeoff or land. Likewise, a reduction of manned aircraft conducting aer ial 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 Efficienc y Of The Phantom
DJI Series , DJI Inspire, DJI S800 , DJI S900 and DJI S1000 UASs.21 Conducting aerial data collection with the DJI Phantom Series , DJI Inspire, DJI
S800 , DJI S900 and DJI S1000 UASs, 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, t he DJI Phantom Series , DJI Inspire, DJI S800 , DJI S900 and DJI S1000 UASs 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 utilize d for aerial video and photography, while burning approximately 20

- 30 gallons per hour of leaded aviation fuel. The DJI Phantom Series , DJI Inspire, DJI S800 , DJI S900 and DJI S1000 UA Ss , while reducing the carbon footprint of aerial data
collections , 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 Series , DJI Inspire, DJI S800 , DJI S900 and DJI S1000 UASs to perform aerial data collection , 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 completely eliminated. Aside from the lack of flight crew members located onboard the aircraft, the DJI Phantom Series , DJI Inspire, DJI
S800 , DJI S900 and DJI S1000 UA S s have 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 s imilar 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 Series , DJI Inspire, DJI S800 , DJI S900 and DJI S1000 UASs Will Benefit The Economy.

In addition to being safe and effi cient, DJI Phantom Series , DJI Inspire, DJI S800 , DJI S900 and DJI S1000 UASs are also an economical alternative to using manned aircraft
to conduct similar ae rial operations. As such, operation of the DJI Phantom Series , DJI Inspire, DJI S800 , DJI S900 and DJI S1000 UASs will allow United States based22 companies, like The Goodwyn Group, LLC , to remain competitive and contribute to growth of the U.S. economy. Spe cifically, 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 competitiv e. Operating the battery powered DJI Phantom Series , DJI Inspire, DJI S800 , DJI S900 and DJI S1000 UASs is one such technology that not only allows companies greater operational flexibility compared to manned aircraft, but provides such flexibility without the high operational cost of a traditional manned aircraft. By operating the DJI Phantom Series , DJI Inspire, DJI S800 , DJI S900 and DJI
S1000 UASs, companies such as The Goodwyn Group, LLC , can remain competitive and profitable, and therefore, provide greater job stability to employees and contractors, which will ultimately contribute to growth of th e U.S. economy. Improved financial performance of U.S. companies, through commercial use of the DJI Phantom Series , DJI Inspire, DJI
S800 , DJI S900 and DJI S1000 UASs, provides a stable workforce that increases consumer spending; improves local, state, and federal tax revenues; and allows companies to invest in research and development in order to remain competitive both in the United States and
abroad.

4. There Are No Privacy Issues.

Similar to the manned aerial data collection flight operations that have been conducted for decades, The Goodwyn Group, LLC’s proposed operation of the DJI Phantom Series , DJI Inspire, DJI S800 , DJI S900 and DJI S1000 UASs will not implicate any privacy issues. Specifically, the DJI Phantom Series , DJI Inspire, DJI S800 , DJI S900 and DJI
S1000 UASs will be operated only in compliance with operating documents (i.e., DJI
Phantom Series , DJI Inspire, DJI S800 , DJI S900 and DJI S1000 Instruction Manual)
which requires property owner involvement as well as local law enforcement notification, NOTAMs and cooperati o n with local FSDOs, and in accordance with the Federal Aviation Regulations, including the minimum altitude requirements of 14 C.F.R. § 91.119.23 E. The Reasons Why Granting The Exemption Would N ot Adversely Affect Safety, Or How The Exemption Would Provide A Level Of Safety At Least Equal To That Provided By The Rule From Which The Goodwyn Group, LLC Seeks Exemption.

1. Reasons Why The DJI Phantom Series , DJI Inspire, DJI S800 , DJI S900
and DJI S1000 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, The Goodwyn Group, LLC’s operation of the
DJI Phantom Series , DJI Inspire, DJI S800 , DJI S900 and DJI S1000 UASs meet the conditions of FMRA Section 333, and will not require an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H. Section 333 provides authority for a UAS to operate without 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. Speci fically, 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 certa in 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 Syste ms.

-- 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 populate d 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; and24 (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 Sa fe 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 natio nal airspace system.

In seeking this exemption, The Goodwyn Group, LLC submits that the DJI
Phantom Series , DJI Inspire, DJI S800 , DJI S900 and DJI S1000 UASs can operate safely in the NAS pursuant to FMRA Section 333, as demonstrated by: (a) the charact eristics of
the DJI Phantom Series , DJI Inspire, DJI S800 , DJI S900 and DJI S1000 UASs; (b) the pilot certification requirement; and (c) the specific operating limitations.

a. The Specifications Of The DJI Phantom Series , DJI Inspire, DJI S800 , DJI S900 and DJI S1000 UASs Demonstrate Its Safe Characteristics.

The DJI Phantom Series , DJI Inspire, DJI S800 , DJI S900 and DJI S1000 UASs do not create a hazard to users of the NAS or the public, or otherwise pose a threat to national security considering its s ize, weight, speed, and operational capability.

i. Technical Specifications Of The DJI Phantom Series , DJI Inspire,
and DJI S1000 UASs.

The technical specifications of the DJI Phantom Series , DJI Inspire, DJI S800 , DJI
S900 and DJI S1000 UASs are set forth by the DJI Phantom Series , DJI Inspire, DJI S800 , DJI S900 and DJI S1000 Specifications and Data Sheet s , included as supplementary
documents to this Petition

.25 ii. The DJI Phantom Series , DJI Inspire, DJI S800 , DJI S900 and DJI
S1000 UASs Autonomous Flight And Navigation Modes Enable The UASs To Remain Within A Defined Operational Area.

The DJI Phantom Series , DJI Inspire, DJI S800 , DJI S900 and DJI S1000 UASs may be operated in both manual and fully autonomous flight modes. A comple te description of the flight and navigational modes of the DJI Phantom Series , DJI Inspire,
DJI S800 , DJI S900 and DJI S1000 UASs are included in the manufacturer’s operator’s
manual

.

iii. The DJI Phantom Series , DJI Inspire, DJI S800 , DJI S900 and DJI
S1000 UASs 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 Series , DJI Inspire, DJI S800 , DJI
S900 and DJI S1000 UAs will remain stationary, i n flight, for 3 seconds or more. If, after 3 seconds, the DJI Phantom Series , DJI Inspire, DJI S800 , DJI S900 and DJI S1000 UA S s do not reacquire control link data from the GCS, the UAs will assume that the Control
Link is lost and the UAs will return to t he 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 these platforms is included in the manufacturer’s operator’s manual

iv. The DJI Phantom Series , DJI Inspire, DJI S800 , DJI S900 and DJI
S1000 GCS And Its Operation.

A complete description of the operation and specifications of the DJI Phantom
Series , DJI Inspire, DJI S800 , DJI S900 and DJI S1000 GCS and flight control software is
included in the manufacturer’s operator’s manual

.26 b. Flight Operations Of DJI Phantom Series , DJI Inspire, DJI S800 , DJI
S900 and DJI S1000 UASs Are Limited To The Line Of Sight Of A Certificated Pilot in Command With A Safety Observer.

The Goodwyn Group, LLC will onl y utilize certificated pilots who possess a
current and valid airman medical certificate or driver’s license to act as a pilot in command (PIC) of the DJI Phantom Series , DJI Inspire, DJI S800 , DJI S900 and DJI S1000 UASs. Additionally, a safety observer will assist all pilots during flight time.

c. Flights Of DJI Phantom Series , DJI Inspire, DJI S800 , DJI S900 and DJI
S1000 UASs Will Be Conducted Pursuant To Specific Operating
Limitations.

In seeking this exemption, The Goodwyn Group, LLC proposes to commercially operate DJI Phantom Series , DJI Inspire, DJI S800 , DJI S900 and DJI S1000 UASs 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 are limited to the DJI Phantom Series , DJI Inspire, DJI S800 , DJI S900 and DJI S1000 Unmanned Aircraft Systems when weighing less than 55 pounds including payload. Proposed operations of any other aircraft will require a new petition or a petition to amend this exemption.

2. Operations for the purpose of closed

- set motion picture and television filming are permitted

.

3. The UA may not be operated at a speed exceeding 87 knots (100 miles per hour). The exemption holder may use either groundspeed or calibrated airspeed to determine compliance with the 87 knot speed restriction. In no case will the UA be operated at airspeeds greater than the maximum UA operating airspeed recommended by the
aircraft manufacturer.27 4. The UA must be operated at an altitude of no more than 400 feet above ground level (AGL). Altitude must be reported in feet AGL.

5. The UA 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 or
U.S. driver’s license.

6. All operations must utilize a visual observer (VO). The UA must be operated within the visual line of sight (VLOS) of the PIC and VO at all times. The VO may be used to satisfy the VLOS requirement as long as the PIC always maintains VLOS capability.
The VO 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 en sure that the VO can perform the duties required of the
VO.

7. This exemption and all documents needed to operate the UAS and conduct its operations in accordance with the conditions and limitations stated in this grant of exemption, are hereinafter refer red to as the operating documents. The operating documents must be accessible during UAS operations and made available to the Administrator upon request. If a discrepancy exists between the conditions and limitations in this exemption and the procedures ou tlined in the operating documents, the conditions and limitations herein 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 docume nts. It is the operator’s responsibility to track such revisions and present updated and revised documents to the Administrator or any law enforcement official upon request. The operator must also present updated and revised documents if it petitions for e xtension or amendment to this grant of exemption. If the operator determines that any update or revision would affect the basis upon which the FAA granted this exemption, then28 the operator must petition for an 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.

8. Any UAS that has undergone maintenance or alterations that affect the UAS operation or flight characteristics, e.g., replace ment of a flight critical component, must undergo a functional test flight prior to conducting further operations under this exemption. Functional test flights may only be conducted by a PIC with a VO and must remain at
least 500 feet from other people. The functional test flight must be conducted in such a manner so as to not pose an undue hazard to persons and property.

9. The operator is responsible for maintaining and inspecting the UAS to ensure that it is
in a condition for safe operation.

10. Prior to each flight, the PIC must conduct a pre

- flight inspection and determine the UAS is in a condition for safe flight. The pre

- flight inspection must account for all potential discrepancies, e.g., inoperable compo nents, items, or equipment. 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 fl ight.

11. The operator must follow the UAS manufacturer’s maintenance, overhaul, replacement, inspection, and life limit requirements for the aircraft and aircraft components.

12. Each UAS operated under this exemption must comply with all manufacturer

s afety bulletins.

13. Under this grant of exemption, a PIC must hold either an airline transport, commercial, private, recreational, or sport pilot certificate. The PIC must also hold a
current FAA airman medical certificate or a valid U.S. driver’s licens e issued by a29 state, the District of Columbia, Puerto Rico, a territory, a possession, or the Federal
Government.

14. The operator may not permit any PIC to operate unless the PIC demonstrates the ability to safely operate the UAS in a manner consistent with how the UAS will be operated under this exemption, including evasive and emergency maneuvers and maintaining appropriate distances from persons, vessels, vehicles and structures not participating in the operation . PIC qualification flight hours and currency must be logged
in a manner consistent with 14 CFR § 61.51(b). Flights for the purposes of training the operator’s PICs and VOs (training, proficiency, and experience

- building) and determining the PIC’s ability to safely operate the UAS in a manner consistent with how the UAS will be operated under this exemption are permitted under the terms of this 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 CFR § 91.119.

15. UAS operations may not be conducted during nig ht, as defined in 14 CFR § 1.1. All operations must be conducted under visual meteorological conditions (VMC). Flights under special visual flight rules (SVFR) are not authorized.

16. The UA may not operate within 5 nautical miles of an airport reference point (ARP) as denoted in the current FAA Airport/Facility Directory (AFD) or for airports not denoted with an ARP, the center of the airport symbol as denoted on the current
FAA

- published aeronautical chart, unless a letter of agreement with that airport’ s management is obtained or otherwise permitted by a COA issued to the exemption holder. The letter of agreement with the airport management must be made available to the Administrator or any law enforcement official upon request.

17. The UA may not be op erated 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.30 18. If the UAS loses communications or loses its GPS signal, the UA must return to a

pre
- determined location wi thin the private or controlled

- access property.

19. The PIC must abort the flight in the event of unpredicted obstacles or emergencies.

20. The PIC is prohibited from beginning a flight unless (considering wind and forecast weather conditions) there is e nough available power for the UA to conduct the intended operation and to operate after that for at least 5 minutes or with the reserve power recommended by the manufacturer if greater.

21. Air Traffic Organization (ATO) Certificate of Waiver or Authorization (COA). All operations shall be conducted in accordance with an ATO

- issued COA. The exemption holder may apply for a new or amended COA if it intends to conduct operations that cannot be conducted under the terms of the attached COA.

22. All aircraft operated in accordance with this exemption must be identified by serial number, registered in accordance with 14 CFR part 47, and have identification (N

− Number) markings in accordance with 14 CFR part 45, Subpart C. Markings must be as large as pr acticable.

23. Documents used by the operator to ensure the safe operation and flight of the UAS and any documents required under 14 CFR §§ 91.9 and 91.203 must be available to the PIC at the Ground Control Station of the UAS any time the aircraft is oper ating. These documents must be made available to the Administrator or any law enforcement official upon request.

24. The UA must remain clear and give way to all manned aviation operations and
activities at all times.

25. The UAS may not be operated by t he PIC fr om any moving device or vehicle without31 prior FAA coordination.

26. All f light operations must be conducted at least 500 feet from all nonparticipating 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 in a manner ensuring the safety of nonparticipating persons; and

b. The owner/controller of any vessels, vehicles or structures has granted permission for operating closer to those objects 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.

The PIC, VO, operator trainees or essential persons are not considered

n on
- participating persons under this exemption.

27. All operations shall be conducted over private or controlled

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

28. Any incident, accident, or flight operation that transgresses the lateral or vertical boundaries of the operational area as defined by the applicabl e 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

.32 29. The operator must have a motion picture and television operations manual (MPTOM) as documented in this grant of exemption.

30. At least 3 days before aerial filming, the operator of the UAS affected by this exemption must submit a written Plan of Activities to the local Flight Standards District Office (FSDO) with jurisdiction over the area of proposed filming. The 3

- day notification may be waived with the concurrence of the FSDO. The plan of activities
must include a t least the following:

a. Dates and times for all flights; b. Name and phone number of the operator for the UAS aerial filming conducted under this grant of exemption; c. Name and phone number of the person responsible for the on

- scene operation of
the UA S; d. Make, model, and serial or N

− Number of UAS to be used; e. Name and certificate number of UAS PICs involved in the aerial filming; f. A statement that the operator has obtained permission from property owners
and/or local officials to conduct the film ing production event; the list of those who gave permission must be made available to the inspector upon request; g. Signature of exemption holder or representative; and h. A description of the flight activity, including maps or diagrams of any area, city, town, county, and/or state over which filming will be conducted and the altitudes essential to accomplish the operation.

31. Flight operations may be conducted closer than 500 feet from participating persons consenting to be involved and necessary for th e filming production, as specified in the exemption holder’s MPTOM.

2. Reasons Why An Exemption From The Requirements Of Section 61.113(a) And (b) Would Not Adversely Affect Safety.33 The Goodwyn Group, 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 operate
the DJI Phantom Series , DJI Inspire, DJI S800 , DJI S900 and DJI S1000 UASs unless that PIC has demonstrated, b y meeting minimum flight

- hour and currency requirements, that the PIC is able to safely operate the DJI Phantom Series , DJI Inspire, DJI S800 , DJI S900
and DJI S1000 UAS s in a manner consistent with the exemption, including evasive and

emergency maneuvers and maintaining appropriate distances from people, vessels,
vehicles and structures. Considering The Goodwyn Group, LLC’s proposed area of operations, and the operating limitations set forth

- above; the parallel nature of private pilot aeronautical
knowled ge requirements to those of commercial pilot requirements ( See Exemption No. 11062); and the airmanship skills necessary to safely operate the DJI Phantom Series , DJI Inspire, DJI S800 , DJI S900 and DJI S1000 UAS, The Goodwyn Group, LLC submits that the additional manned airmanship experience of a commercially certificated pilot would not correlate to the airmanship skills necessary for The Goodwyn Group, LLC ’s specific proposed flight operations. The FAA has previously granted relief f rom Section 61.113(a) and (b) specific to UAS, in circumstances similar, in all material respects, to those presented herein (e.g. Exemption Nos. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 11112, 11136, 11138, 11150, 11153, 11156, 11158 , 11159, 11160, 11161). The Goodwyn Group, LLC will not allow any PIC to operate the DJI Phantom
Series , DJI Inspire, DJI S800 , DJI S900 and DJI S1000 UAS unless that PIC has demonstrated, by meeting minimum flight

- hour requirements or the DJI Phantom Ser ies , DJI Inspire, DJI S800 , DJI S900 and DJI S1000 UAS training and currency requirements, that the PIC is able to safely operate the DJI Phantom Series , DJI Inspire, DJI S800 , DJI
S900 and DJI S1000 UAS in a manner consistent with this exemption, includin g evasive and emergency maneuvers and maintaining appropriate distances from people, vessels,
vehicles and structures. Specifically, the PIC must have accumulated and logged, in a manner consistent with 14 C.F.R. § 61.51(b), 25 hours of total time as a UA S rotorcraft pilot (with a minimum of 5 hours of those hours as a UAS pilot operating the same make and model of34 UAS to be used for operations under the exemption). In addition to the hour requirements, the PIC must accomplish 3 takeoffs and landings in th e preceding 90 days (for currency purposes). As in Exemption Nos. 11062, 11138, and 11153, prior documented flight experience that was obtained in compliance with applicable regulations will ensure an equivalent level of safety during The Goodwyn Group, L LC ’s proposed operations. The Administrator has held that prior documented flight experience that was obtained in compliance with applicable regulations would ensure safe operations, stating as follows:

In Exemption No. 11062, the FAA required that prior to conducting operations for the purpose 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 time as a UAS rotorcraft pilot including at least 10 hours logged as a UAS pilot with a multi

- rotor UAS. Prior to operations under Exemption No. 11062, the PIC must also have accumulated and logged a minimum of 5 hours as a UAS pilot operating the same make and model of UAS to be used for operations under the

exe mption. 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 o f 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 flight

- hour requirements in Exemption No. 11062 are appropri ate 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 experience

- building flights the PIC is required to operate the UA with appropriate
distances in accordance with 14 C.F.R 91.119.35 Accordingly, The Goodwyn Group, LLC will ensure safe operations by not allowing any PIC to operate the DJI Phantom Series , DJI Inspire, DJI S800 , DJI S900 and
DJI S1000 UAS s unless that PIC has demonstrated, by meeting minimum flight

- hour and currency requirements, that the PIC is able to safely operate the DJI Phantom Series , DJI Inspire, DJI S800 , DJI S900 and DJI S1000 UAS in a manner consistent with the exemption, includi ng 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 safe ty established by Section 91.7(a) will be maintained because prior to every flight, The Goodwyn Group, LLC will ensure that the DJI Phantom
Series , DJI Inspire, DJI S800 , DJI S900 and DJI S1000 UAS is in an airworthy condition based upon the UAS’s complian ce with its operating documents and as stated in the
conditions and limitations herein. Additionally, the FAA has previously granted relief from Section 91.7(a) specific to UAS, in circumstances similar, in all material respects, to those presented herein (e.g. Exemption Nos. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 1111 2, 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 mainta ined
because the altitude information of the DJI Phantom Series , DJI Inspire, DJI S800 , DJI
S900 and DJI S1000 UA S s 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 act ive monitoring of the flight path and altitude. This altitude information, combined with The Goodwyn Group, LLC ’s operation of the DJI Phantom Series , DJI Inspire, DJI S800 , DJI
S900 and DJI S1000 UA S s 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 be36 generated by GPS equipment installed onboard the aircraft. Prior to each flight, a zero altitude initiation point is automatically established by the UASs at grou nd 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, 1 1138, 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 Series , DJI Inspire, DJI S800 , DJI S900 and DJI S1000 UASs; (2) the limitations on the proposed flight operations; and (3) the location of the proposed flight operations. Accordingly, The Goodwyn Group, LLC will ensure that it will safely operate the battery powered DJI Phantom Series , DJI Inspire, DJI S800 , DJI S900 and DJI S1000 UA S s during daylight hours in VFR conditions, n o person may begin a flight in a rotorcraft under
VFR conditions unless (considering wind and forecast weather conditions) there is enough available power for the UA to conduct the inten ded operation and to operate after that for at least 5 minutes or with the reserve power recommended by the manufacturer if greater

. Here, as in Exemption No. 11109, the technical specifications of the DJI Phantom
Series , DJI Inspire, DJI S800 , DJI S900 a nd DJI S1000 UASs; 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 Series , DJI Inspire, DJI S800 , DJI S900 and DJI S1000 UASs 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 approx imately 10% remaining battery power. At the critically low battery level, the DJI Phantom Series , DJI Inspire, DJI S800 , DJI S900 and
DJI S1000 UASs will descend and land automatically.37 Significantly, previous exemptions granted by the FAA concerning Sect ion 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, 11 042, 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 9 1.417(a) & (b) Would Not Adversely Affect Safety.

In seeking this exemption, The Goodwyn Group, LLC submits that the equivalent level of safety with regard to the regulatory maintenance and alteration requirements established by Sections 91.405(a), 91.40 7(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b)
will be met because The Goodwyn Group, LLC will 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
Series , DJI Inspire, DJI S800 , DJI S900 and DJI S1000 Instruction Manual s ). Furthermore, The Goodwyn Group, LLC will document and maintain all maintenance records for the
DJI Phantom Series , DJI Inspire, DJI S800 , DJI S900 and DJI S1000 UASs.
Since the DJI Phantom Series , DJI Inspire, DJI S800 , DJI S900 and DJI S1000 UASs will be inspected as prescribed by the operating documents, The Goodwyn Group,
LLC will maintain the equivalent level of safety established by Sections 91.405(a), 91.409(a)(1), and 91.409(a)(2). 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 Series , DJI Inspire, DJI S800 , DJI S900 and DJI S1000 UASs will be38 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), 91.4 07(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 The Goodwyn Group, LLC ’s proposed operating li mitations, the operating documents, and the technical aspects of the DJI Phantom Series , DJI Inspire,
DJI S800 , DJI S900 and DJI S1000 UASs, The Goodwyn Group, LLC submits that safety will not be adversely affected by granting exemption from 14 C.F.R. Sect ions 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, 1106 5, 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 , The Goodwyn Group, LLC requests that the FAA prescribe special conditions for the intended operation of the DJI
Phantom Series , DJI Inspire, DJI S800 , DJI S900 and DJI S1000 UASs, 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 operation of the UAs for the limited purpose of conducting aerial data collection over certain areas of the United States for compensation or hire. FMRA Section 33 3 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 operate39 without airworthiness certifica tion 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 Series , DJI Inspir e, DJI S800 , DJI S900 and DJI
S1000 UASs, since the airworthiness regulations of 14 C.F.R. Part 21 do not contain adequate or appropriate safety standards, due to the novel or unusual design features of the aircraft. Section 21.16, entitled Special Conditi ons , states the following: If the FAA finds that the airworthiness regulations of this subchapter do not contain adequate or appropriate safety standards for an aircraft, aircraft engine, or propeller because of a novel or unusual design feature of the ai rcraft, aircraft engine or propeller, he prescribes special conditions and 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. Therefore, in accordance with FMRA Section 333 and 14 C.F.R. § 21.16, the FAA may prescribe special conditions for The Goodwyn Group, LLC’s intended operation of
the DJI Phantom Series , DJI Inspire, DJI S800 , DJI S900 and DJI S1000 UASs, 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. P art 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 The Goodwyn Group, LLC Seeks Exemption:

The Goodwyn Group, LLC seeks exemption from the requirements of 14 C.F.R
Sections 45.27(a), 61.113(a)&(b), 91.7(a), 91.105, 91.119(c), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b).40 A Brief Description Of The Nature Of The Exemption The Goodwyn Group,
LLC Seeks:

This exemption will permit The Goodwyn Group, LLC to commercially operate an Unmanned Aircraft System (UAS) for the purpose of conducting aerial data
collection over certain areas of the United States.

G. Any Additional Information, Views, Or Arguments Available To Support The Goodwyn Group, LL C’s Request.

This Petition is made pursuant to the FAA Modernization and Reform Act of 2012 (FMRA) Section 333, which d irects the Secretary of Transportation to determine if certain UAS may operate safely in the NAS. As such, The Goodwyn Group, LLC ’s 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 airwo rthiness
certification. As discussed in detail above, The Goodwyn Group, LLC will operate the DJI
Phantom Series , DJI Inspire, DJI S800 , DJI S900 and DJI S1000 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, The Goodwyn Group, 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 Phantom Series , DJI Inspire, DJI
S800 , DJI S900 and DJI S1000 UASs commercially, without a n airworthiness certificate, for the limited purpose of conducting aerial data collection over certain areas of the United41 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 The Goodwyn Group, LLC to safely,
efficient ly, and economically operate the DJI Phantom Series , DJI Inspire, DJI S800 , DJI
S900 and DJI S1000 UASs commercially within the NAS.
WHEREFORE , in accordance with the Federal Aviation Regulations and the FAA Modernization and Reform Act of 2012, Section 3 33, The Goodwyn Group, LLC respectfully requests that the Administrator grant this Petition for an exemption from the requirements of 14 C.F.R Sections 45.27 (a), 61.113(a) & (b), 91.7(a), 91.105, 91.119 (c), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.40 9(a)(1 ) & (a)(2), AND 91.417(a) & (b), and permit The Goodwyn Group, LLC to operate the DJI Phantom Series , DJI Inspire, DJI
S800 , DJI S900 and DJI S1000 UASs commercially for the purpose of conducting aerial video and photography over certain areas of the United States.

Date d: May 2 9 , 2015

Respectfully submitted,
The Goodwyn Group, LLC

_________________________ Rich ard W. Goodwyn 42762 Hollowind Ct. Broadlands, VA 20148 Tel: (703) 606

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