July 15, 2015

U. S. Department of Transportation Docket Management System 1200 New Jersey Ave., SE Washington, DC 20590

RE: Petition for Exemption Pursuant to Section 333 of the FAA Reform Act

Petitioner’s Name and Address:

Drone 6 LLC
Sean O’Gorman 1810 Wet Dusty Wren Drive Phoenix, AZ 85085 sogorman@gmail.com

To whom it may concern:
Pursuant to Section 333 of the FAA Modernization an d Reform Act of 2012 (the Reform Act) and 14 C.F.R. Part 11, Drone 6 LLC, operator of Sm all Unmanned Aircraft Systems (“sUASs”) equipped to conduct aerial photography an d videography, hereby applies for an exemption from the listed Federal Aviation Regulati ons (“FARs”) to allow commercial operation of its sUASs, so long as such operations are conduc ted within and under the conditions outlined herein or as may be established by the FAA as requi red by Section 333.1 As described more fully below, the requested exempt ion would permit the operation of small, unmanned and relatively inexpensive sUAS under cont rolled conditions in airspace that is 1) limited 2) predetermined and 3) controlled. The proposed exemption, if granted, would allow Drone 6 LLC to conduct commercial operations of sU ASs meeting or exceeding all of the operational and safety requirements Congress has se t forth in Section 333. Drone 6 LLC is a media/technology company owned an d operated by Sean O’Gorman. The purpose of Drone 6 LLC is to develop commerce in C entral and Southwest Arizona. Mr. O’Gorman has over 12 years in Remote Controlled (“R C”) aircraft experience in both fixed wing and rotary aircraft. This experience includes devel opment, building, testing and flying a variety
of RC aircraft.

Drone 6 LLC plans to use the capabilities of sUASs to offer a multitude of services, including: - Aerial surveying of local water supply to the com munity - Event Photography/Videography - Agriculture and Livestock monitoring - Real Estate Photography and presentation - Aerial filmmaking and photography - Construction site inspections and monitoringStatutory Authority Section 333, titled “Special Ru les for Certain Unmanned Aircraft Systems”,

provides a mechanism for seeking expedited FAA auth orization of safe civil Unmanned Aircraft Systems (UAS) operations in the National Airspace S ystem (“NAS”). Section 333(a) states that
the FAA “shall determine if certain unmanned aircra ft systems may operate safely in the national airspace system before completion of the ( comprehensive) plan and rulemaking required by section 332(b)(1) of this Act or the gu idance required by section 334 of this Act.” In Section 332(b)(1), Congress made it clear that Sect ion 333 provides a mechanism for “expedited operation authorization” if several factors are met . Petitioner meets all requirements to permit FAA approval of commercial UAS operations.

The name and address of the applicant are:

Name: Drone 6 LLC
Owner: Sean O’Gorman Address: 1810 West Dusty Wren Drive Phoenix, AZ 85085
Phone: 480-270-4991
Email: sogorman@gmail.com

Regulations from which the exemption is requested:

14 C.F.R. Part 21 14 C.F.R. 45.23 (b) 14 C.F.R. 61.113(a) and (b) 14 C.F.R. 91.7 (a) 14 C.F.R. 91.9 (b)(2)

14 C.F.R. 91.109

14 C.F.R. 91.119 14 C.F.R. 91.121Page 3 14 C.F.R. 91.151(a) 14 C.F.R. 91.203 (a) & (b) 14 C.F.R. 91.205 (b)

14 C.F.R. 91.215 14 C.F.R. (91.401 - 91.417)

sUASs are oftentimes seen as superior to helicopter s due to the lesser cost of equipment, the reduction of personnel needed to operate equipment, reduced noise levels and zero emissions into the environment. In addition to providing cost savings and having little to no impact on the environment, sUASs provide enhanced safety. These f actors are beneficial for, and in the best interest of, the public. Accordingly, the applicant respectfully requests that the FAA grant the requested exemption without delay. Petitioner is requesting an exemption to enable Dro ne 6 LLC to operate a DJI Inspire 1 sUAS that is upgraded to latest version firmware, e quipped with a 3 axis Zenmuse camera gimbal, which uses a High-Def video camera that can capture up to 4K (4096x2160p) video and 12M pixel photos. This sUAS has a built-in capabili ty to limit 1) the height it flies above theground and 2) the radius of the distance it flies f rom the operator. The DJI Inspire 1 also has the

failsafe function of the autopilot system, which me ans, when the communication between the
Main Controller and the transmitter is disconnected , the outputs of all command sticks from controller will go to the center position. If the G PS signal is good enough, the system will automatically trigger Return to Home and will land safely. Please refer to Attachments 1-3, the DJI Inspire 1 Instruction Manual, for the performan ce limitations and flight operations. Aircraft weight is 2935 grams or 6.47 pounds with b attery, which is the total gross weight. A pre-flight inspection will be performed by the PI C in accordance with the factory instruction manual, as well as redundant checks to include the Internal Measurement Unit (IMU) to make sure that the compass, gyro and acceleration values are within specs, positive GPS locks are secure, battery health in each individual LiPo cell s are balanced, and radio signals are locked in.
The sUAS will be maintained in accordance with the manufacturer’s instruction manual and only manufacturer's authorized replacement parts wi ll be used.

FCC Information

The DJI Inspire 1 transmitter used for controlling the sUAS complies with part 15 of the FCC rules. Operation is subject to the following two co nditions: (1) This device may not cause harmful interference, and (2) this device must acce pt any interference received, including interference that may cause undesired operation. The DJI Inspire1 radio transmitter used for control ling the sUAS is wireless technology which has been tested and found to be compliant with the applicable regulations governing a radio transmitter in the 2.400GHz to 2.4835GHz frequency range.

Antenna Separation Distance

When operating the DJI Inspire 1 transmitter, the P IC will maintain a separation distance of at least 5 cm between his body (excluding fingers, han ds, wrists, ankles and feet) and the antenna to meet RF exposure safety requirements as determin ed by FCC regulations.

Pilot in Command and Observer Qualifications and Du ties The PIC will maintain at least a Light Sport Pilot Certificate and a current State issued drivers license, plus at least 2 hours flying time and 3 ta keoffs and landings within 30 days in the type of UAS utilized in operations.
The PIC will have at least 100 hours total time and at least 30 hours flying Radio Controlled Model Aircraft, of which, 10 hours will be flying s UASs. The PIC is responsible for the safe and efficient o peration of the aircraft. Specific duties include all preflight preparation and inspection, in flight operation, post flight requirements, and all procedures including but not limited to:

• Safe in flight operations

• Risk evaluation

• Current weather conditions for safe flight The Observer must have the visual acuity to observe the sUAS and be able to communicateclearly with the PIC. The Observers duties are:

• Warning the PIC of any impending obstacles in the f light path of the sUAS.

• Warning the PIC of any deviations in the planned fl ight path of the sUAS.

• Warning the PIC should any unauthorized personnel a ppear in the area of the planned flight. The Observer will have the authority to order the P IC to terminate the flight should he feel the flight cannot be conducted safely.

General Operating Standards

• Drone 6 LLC will only operate its sUAS in line o f sight of a pilot and/or observer and will operate at sites that are a 'sufficient distan ce' from populated areas. Such operations
will insure that the sUAS will "not create a hazard to users of the national airspace system or the public." • Before an operation of a sUAS within 5NM of an ai rport with a control tower, the control tower will be called to gain permission to operate the sUAS. The PIC will give the position, altitude and the times the sUAV will be operated. T he sUAS will not be operated at an
altitude of over 200 feet AGL. Weather minimums wil l be 3 miles visibility and a 1000 foot ceiling.

• Before an operation of a sUAS within 5NM of a non-t ower controlled, airport operators will be notified and the PIC will give the right of way to avoid flying in the proximity of fullscale aircraft. At no time will the sUAS be operated with in the final approach course and the takeoff course of any runway. The sUAV will not be operated at an altitude of over
200 feet AGL. Weather minimums will be 3 miles visi bility and a 1000 foot ceiling.

5 • Maximum flight time for each operational flight w ill be 18 minutes. • Flights will be terminated at 30% battery power r eserve should that occur prior to the
18minute limit. • The sUAV will be programmed so that it will not b e operated at an altitude of no more than 200 feet AGL, and not more than 200 feet above an elevated platform from which filming is planned. • Minimum crew for each operation will consist of t he sUAS Pilot, and Visual Observer. • The sUAV operated by the petitioner weighs less t han 55 pounds, including the payload (i.e. camera, lens, and gimbals). • The sUAS will operate at speeds of no more than 2 5 knots, can hover, and can simultaneously move vertically and horizontally.
• Given the small size of the sUAV and the restrict ed sterile environment within which they will operate, our sUAV operations adhere to the Ref orm Act's safety requirements. The sUAS, powered by batteries, is smaller, lighter and more maneuverable than larger aircraft running on combustible fuel. The sUAS operates at l ower altitudes with no people on board and will thereby reduce current risk levels, enhanc e safety and diminish the likelihood of death or serious bodily injury. With a small payload and maximum flight time of only 20 minutes, this offers little or no risk to national security. Low level oblique photos and video from several ang les are far more effective than groundbased imagery for displaying the characteristics of large, complex properties with several buildings and large trees. The benefits of reduced cost and improved quality of presentation
from the sUAS over manned aircraft will be valuable to and benefit many buyers and sellers of real property, farmers and ranchers, and local cityofficials to monitor our local water supply. Additionally, we request that we be allowed to use our system to benefit first responders nearby who might require assistance, including fire fighters, police, sheriff, etc., all while remaining subject to all limitations cited below: (a) No flight will be made with a Gross weight exce eding 55 pounds; (b) All operations must occur in FAA Class G airspa ce at no more than 200 ft AGL, at an airspeed
of no more than 25 knots and no further than 1600 ft, or 0.263 NM from the PIC; (c) All operations must utilize a visual observer ( VO). The VO and PIC must be able to communicate by voice at all times during a flight o peration;

6 (d) Operations will be restricted to flights over p rivate property with the permission of the
property owner; (e) All required permits will be obtained from stat e and local government prior to operation; (f) Drone 6 LLC will not be operated over densely populated areas; (g) Drone 6 LLC will not be operating over any ope n-air assembly of people; (h) Drone 6 LLC will not be operating over heavily trafficked roads; (i) Drone 6 LLC will not be operating at night.

EXEMPTION REQUESTS AND EQUIVALENT LEVEL OF SAFETY

Drone 6 LLC requests an exemption from the followi ng regulations as well as any additional regulations that may technically apply t o the operation of the sUAV System:

14 CFR Part 21, Airworthiness Certificates This part establishes the procedures for the issuan ce of an airworthiness certificate. While the FAA continues to work to develop airworthiness stan dards for Unmanned Aerial Systems, we request an experimental certificate be issued for t he DJI Inspire1 under either or both of the following provisions: 21.191 Experimental certificates. Experimental cert ificates are issued for the following

purposes: (a) Research and development

. Testing new aircraft design concepts, new aircraft equipment, new aircraft installations, new aircraft operating techniques, or new uses for aircraft. (b) Showing compliance with regulations

. Conducting flight tests and other operations
to show compliance with the airworthiness regulations inclu ding flights to show compliance for issuance of type and supplemental type certificates, flights to substantiate major design changes, and flights to show compliance with the function and re liability requirements of the regulations. Since the experimental certificate can be used for commercial purposes such as market surveys, sales demonstrations, and customer crew training, w e would expect that an experimental certificate would permit our commercial purpose as well. The aircraft will not carry persons orproperty, will not carry fuel, and will only fly un der strict operational requirements. Combined

with the UAS's light weight, being constructed prim arily of carbon fiber and plastic, we propose that the UAS will be at least as safe, if not safer , than a conventionally certificated aircraft performing the same mission. If an experimental air worthiness certificate is not appropriate for this application, then we request an exemption of 1 4 CFR Part 21, Subpart H, and the requirement for an airworthiness certificate in gen eral, citing the equivalent level of safety outlined in the previous paragraph.

7 14 CFR 45.23 Display of marks; general and 45.29 Si ze of marks. These regulations provide that each aircraft must d isplay "N" and the aircraft's registration number in letters at least 3 inches high. Additiona lly, the aircraft must display the word "EXPERIMENTAL" in letters at least 2 inches high ne ar the entrance to the cabin, cockpit, or pilot station. The sUAS does not have an entrance i n which the word "EXPERIMENTAL" can be placed, and may not have a registration number assi gned to it by the FAA. We propose to achieve an equivalent level of safety by including the word "EXPERIMENTAL" in the placard on the top of the aircraft, as shown above, where the PIC (Pilot In Control), VO (Visual Observer) and others in the vicinity of the aircraft while it is preparing for launch will be able to see the designation. Additionally, we feel that the permane nt placard discussed in the previous paragraph will provide the aircraft's registration information at the ground station. Finally, we will display at the ground station a high contrast flag or banner that contains the words
"Unmanned Aircraft Ground Station" in letters 3 inc hes high or greater. Since the aircraft will operate within 0.263 NM of the ground station, the banner should be visible to anyone that observes the aircraft and chooses to investigate it s point of origin. 14 CFR 61.113 Private pilot privileges and limitati ons: Pilot in Command and 61.133 Commercial pilot privileges and limitations. The regulation provides that no person that holds a Private Pilot certificate may act as pilot in Command of an aircraft for compensation or hire. Su bparagraph (b) allows a private pilot to act as pilot in command of an aircraft in connection wi th any business or employment if: (1) The flight is only incidental to that business or emplo yment; and (2) The aircraft does not carry passengers or property for compensation or hire. Ou r proposed operations require that the PIC
must hold at least a Private Pilot Certificate with a Class III Medical issued by the FAA and since the aircraft cannot carry passengers or property, w e feel we meet the intent of 61.113 Subparagraph (b) even though the intent of this app lication is to conduct a business. 14 CFR 91.7 Prohibits the Operation of an aircraft without an airworthiness certificate . As no such certificate will be applicable in the form con templated by the FARs, this Regulation is inapplicable. 14 CFR 91.9 Civil aircraft flight manual, marking, and placard requirements

. This regulation provides that no person may operate an aircraft unless a current, approved flight manual is in the aircraft. We assume that th e intent of this requirement is to ensure that flight manual information is available to the aircr ew while operating the aircraft. We request an exemption to this requirement since the aircraft is not only too small to carry documentation,
the documentation would not be available to the cre w during flight operations. To obtain anequivalent level of safety and meet the intent of 9 1.9, we propose that a current, approved

sUAS Flight Manual must be available to the crew at the ground station anytime the aircraft is in, or preparing for, flight, and ready for present ation for any governing official upon request. 14 CFR 91.109 Flight Instruction; Simulated instrum ent flight and certain flight
tests The regulation states that "No person may operate a civil aircraft that is being used for flight instruction unless that aircraft has fully function ing dual controls. Although the DJI Inspire 1 is

8 capable of duel/linked controls, Drone 6 LLC will be operating with a single remote
controller. 91.119 Minimum safe altitudes : General. The regulation states that over sparsely p opulated areas the aircraft cannot be operated closer than 500 feet to any person, vessel , vehicle, or structure. Since the typical mission of the sUAS would be photography or survey of persons, vessels, vehicles or structures it would be necessary to operate closer than 500 fe et to the items listed. Operations will only be flown over property or persons where permission has been obtained and careful preplanned flight path has been performed. The aircraft will b e operated at a low altitude allowing, if a power unit fails, an emergency landing without undue hazard to persons or property on the
surface. Therefore we maintain that due to the smal l size of the UAS, the hazard to persons, vehicles and structures is minimal compared to mann ed aircraft, which should be considered in granting the exemption. CFR 91.121 Altimeter settings

. The regulation requires that aircraft shall maintai n cruising altitudes by reference to an altimeter setting available within 100 NM of the ai rcraft. The sUAS will always fly below 200 feet AGL and will not need to maintain cruising alt itudes in order to prevent conflict with other
aircraft. An Above Ground Level altimeter measureme nt above the takeoff point is transmitted via radio from the sUAS on-board computer to the di splay screen held by the PIC, providing a constantly updated AGL readout. 14 CFR 91.151 Fuel requirements for flight in VFR c onditions

. The regulation provides that no person may begin a flight in an airplane under day-VFR conditions unless there is enough fuel to fly to th e first point of intended landing and to fly after
that for at least 30 minutes. We feel the intention of this paragraph is to provide an energy reserve as a safety buffer for delays to landing. T he sUAV is battery operated and the maximum duration of flight from a single battery charge is 18 minutes with a 20% reserve. Since the aircraft will never fly more than 0.263 NM from the point of intended landing, a full battery charge at launch will ensure that we meet the reser ve energy requirement of this paragraph. We request an exemption to the word "fuel" and ask for an equivalent interpretation with the word "energy". 14 CFR 91.203(a) & (b) Civil aircraft: Certificatio ns required

. The regulation provides that an airworthiness certi ficate, with the registration number assigned to the aircraft and a registration certificate must be aboard the aircraft. Additionally, subparagraph (b) provides that the airworthiness ce rtificate be "displayed at the cabin or cockpit entrance so that it is legible to passenger s or crew." At a maximum gross weight of 6.47 pounds, the sUAS is too small to carry documentatio n, does not have an entrance, and is notcapable of carrying passengers or crew. To obtain a n equivalent level of safety and meet the

intent of 91.203, we propose that documents deemed appropriate for this aircraft by the FAA will be with the crew at the ground control station and available for inspection upon request. In order to identify the aircraft, we propose that the information found on airworthiness and

9 registration certificates be permanently affixed to the aircraft via placard containing the following information plus the word "EXPERIMENTAL" to satisfy the requirement of 14 CFR

45.23. 14 CFR Subpart E (91.401- 91.417)- Maintenance, Pre ventive Maintenance, Alterations The regulation provides that the operator is primar ily responsible for maintaining the aircraft in an airworthy condition, including compliance with p art 39 and 43. Paragraphs 91.407 and 91.409 require that the aircraft be "approved for r eturn to service by a person authorized under 43.7" after maintenance and inspection. It is our i ntention that the PIC perform maintenance and inspection of the aircraft and "be authorized t o approve the aircraft for return to service."
The PIC will ensure that the aircraft is in an airw orthy condition prior to every flight and in addition conduct detailed inspections after every t wo hours of flight. Maintenance performed by the PIC is limited to repairing small cracks, re placing a propeller, checking electrical connections and updating software and firmware for the on-board computer. All other maintenance will be performed by the manufacturer o r their designated repair facility. The PIC will document work performed in accordance with 91. 417. We feel that due to the size, construction, and simplicity of the aircraft, the P IC can ensure an equivalent level of safety. Safety and Benefits of the UAS Drone 6 LLC will be using the UAS in a variety of applications that generally require expensive full-size manned aircraft to complete. Sm all, light, unmanned aerial vehicles offer
more efficient and safer benefits over the use of f ull-sized manned aircraft for aerial photography, advanced agriculture monitoring, film and still photography, real estate marketing, (see attachment 4), and water supply mon itoring. Due to drought conditions in the area over the past few years, this would greatly su pply safer, faster, and more efficient
information to our local officials who need this in formation about the lake levels and our water supply. Replacing significantly larger manned aircraft carr ying crew and flammable fuel with small UAS carrying no passengers or crew creates a much great er margin of safety for the pilots and crew. By granting Drone 6 LLC‘s requested exemptions, th e FAA will help drive development of safe and successful commercial UAS operations and w ill advance the public knowledge base for such operations. Drone 6 LLC is committed to promo ting the UAS research efforts of policymakers including the FAA, NASA, DOD and DARPA by sharing data from its commercial UAS operations and serving as a resource for future UAS research operations. Thus, the FAA has good cause to grant this Petition. Conclusion As pointed out in this application, the DJI Inspire 1 which our company would use, under authorization by the US DOT-FAA, is a small, light- weight device operated within the line of sight of the Pilot-in-Command (PIC), less than 200 feet above the ground and outside 5 miles from any airport, heliport, seaplane base, spacepor t, or other location with aviation activities,unless the air traffic control authorities (ATC) ha ve been notified and have authorized each

flight within a radius of this distance.

10 The DJI Inspire1 has been proven capable for contro lled flight. It is a UAS offered for general
sale on the market around the world and have often been used as Model Aircraft in the USA.
We are certain that the studies conducted until now by the FAA, about Section 332, Public Law 112-95, 2014, have already provided you with the as surances on the airworthiness of sUAS such

as ours. For the foregoing reasons, the exemptions requested herein should be granted and Drone 1 Aerial LLC should be permitted to conduct small UAS operations in accordance with its manuals and all other operating parameters deemed necessaryand appropriate by the FAA. The submission of this application and its contents is the best demonstration that indeed it is possible to pursue the authorization process so tha t some SUAs may be used for legitimate commercial activities and under reasonably safe con ditions.

Signed
Sean O’Gorman

Drone 6 LLC