07/ 15 / 2 015

Daedalus	Aerial	Imaging

Attn: Alan	Holland

1095	Rose	Meadow	Court

Santa	Rosa	CA		95407

707.573.1973

daedalusaerialimaging@yahoo.com

T O : F e deral A viation	Ad m inistration

US	D e part m ent	of	Tran s portation

Docket	M a nagement	Syste m

1 20 0 N ew	Jersey Ave. S.E

Was h ington,	DC	.	2059 0

R e :

Exemption	Request	Section	333	of	the	FAA	Reform	Act	Pursuant	to	section	333	of t he	FAA

Mod e rnization	and	Reform	act	of	20 1 2	(The	Refor m Act),	and	14	C.F.R.	Part	11, Daedalus	Aerial	Imaging

,

h erby see k s	and	a p plies	fo r a n exemption	to	the	Fed e ral	Aviation	Regulations	(F A Rs)	to	allow D aedalus

A erial I maging to	operate	Small	Unm a nned	Aircraft	Systems	(U A S)	commercially	in	airspace	regulated	by

the	Federal	Aviation	Administration	(FAA)	under	the	conditions	and limitations set f orth	in	thi s pe t ition.

T he	requested	ex e mption	would	permit D aedalus A erial I maging t o	operate	small,	unmanned	aircraft

system ( UAS)	for	the	purpose	of	providing	an aerial	photography	and	survey	service	to	Municip a lities,

Utilities	& P riva t e	consu m er s.	Th e areas	of	us e will	include	both	photo and	video i n	the U tilities,

Com m unications i ndustry,	real	estate	industry

, surveying	industry,	constru c tion	industry and	agricultural

industry.	The U AS will	b e operat e d	in	airspace	that	is	1)	limited	2)	predeterm ine d 3)	would	provide

added	sa f ety	enh a ncements	to	the	already	safe	oper a tions	in	the i ndustry	presently	using	conve n tional

aircraft system”

Exemption	requ e st	to	section	333	of	the	FAA	Refor m Act	Plan	11	Specific	to	UAS	operations.

14	CFR	21	subpart	H; 1 4 CFR	45.23(b); 14	CFR	61.113(a) &	(b); 1 4	CFR	9 1 .103 ; 14	CFR	91.105;	14	CFR

91. 1 09: 1 4	CFR 91.119(c);14	CFR	91.1 2 1;	14 C FR	9 1 .151(a); 1 4 CFR 9 1 .405(a);	14	CFR	91.4 0 7(a)(1);	14

CFR	91.40 1 (a)(1)	&	(2);	14	CFR	91.417(a)	7	(b).De ar	Sir	or	Madam:

Com m erci al	oper a tion	of	an	UAS,	as d e scribed	herein, which	are	equipped	with camera(s)	and	sensors,

would	operate	in	the	following	manne r :

• A e rial	photography	and/or	vide o for	public	and/or	private	use	including	real	estate,	architect u re,

land	surve y ing,	enginee r ing	and	other	relat e d	profes s ional	activiti e s.

• A e rial	inspection/photography	of	residential/commercial	structures	unde r contract with	the	owners

o r local	government	authority.

• A e rial i nspection/photography	of	residential/commercial	utility i nfrastructure	included	but	not

limited	to	ele c trical	powe r lines,	wind	turbines	a n d	cell	towers.

• A e rial	video/photogr a phy	or	providing	live vide o feed	to	assist w ith	rescue	operations in	cases	of an

em e rgency	or	natural	disaster	only	when	the	local	authorities	or	govern m ent	has	requested	it	by

contract	and/or	do n ation.

• Th e ability	to	offer	training	to	persons	or	individuals	belonging	to	b o th private	and/or	pu b lic

o r g anizations	that	have	interests	in	the	use	and	application	of UAS	for	the	purpose	of	the	safe

operation	of	a	U A S	to	enhance	the	safet y of	national	aerospace	syste m (NAS)	as	w e ll	as	for

protection	of	the	persons	and	propert y

.

As	d e scribed	fully b elow,	and	to	be	used	as FOM	(e x ibit# 1 )

, the	requested	exemptio n s would	permit

the	operation	of	a	UAS	under	controlled	conditions i n	the	NAS	that	would	be	a)	limited,	b)

controlled,	c)	predeter m ined,	and	d)	will	provide	safety	enhancements	s uch	as	limited	exposure	to

flight	crew,	climbin g crews, w eight	of	vehicles,	sp e eds	of	usage,	no n use	of	volatile	fuels,	ect.

Approval	of	this	exemption	would	ther e by	enhance	safety	and	fulfill	the	Secretary	of

Transportations	(the	FAA	administrators)	respo nsibil i ties	to	“....e s tablish	requirem e nts	for	the	safe

operation	of	such a ircraft	syste m s	in	the	national	airspace	syste m

.

AIRCRAFT A N D EQUIVALE N T LEVEL OF SAFETY

The	primary	v e hicle	to	be	used	will	be	the	DJI	Inspire1	and	or	DJI	Phantom	3.	While	vehicl es	ma y be

u pgraded	as	new	technological	and	safety	advanced	occur	the	bar	for	operation	and	safety	will	be

set	by	DJI	Inspire	1	and	any	new	vehicles	or	versions	will	exceed	the	curr e nt	safety	and	operational

standards.	No	vehicle	operated	by D aedalus A eria l I maging will	b e modif i ed	from	the	manufa c turers

design	unless	specifically	directed	by	the	sa m e	ma n ufacturer.

The	operation	limitations	proposed	for	an	equivalent	or	higher	level	of	safety	because	ope r ations

will	further	enhance	th e safety	of	the	persons and/o r property u sing	conventional	aircraft. Thes e

limitations	and	conditions	to which	the	applicant	agrees	to	adher e to	when	conducting	com m ercial

operations	under	the	FA A issued	exemption	as	set	forth	in	the	flight	operations	manual	include:

# Ex h ibit # 1

• The U AS w ill w eigh	less	than 5 5	lbs

• The	UAS w ill have	a	m a ximum	operating	spe e d	of	no	more	than	100 m p h

• Flights	will	be	operated	within	line	of	sight	of	the	pilot i n	com m and	and/or	visual	observ e r

• M aximum	flight	tim e for	each	oper a tional	flight will	be	30	minutes. Fli gh ts	will	be	terminated	at

25%	batt e ry	power	res e rve	or	30	minutes	of	flight	time	whichever	occ u rs	first

• Flights	will	be	operated	at	altitude	of	no	mo r e	than	200 f eet	above	ground	level	and	no	more

than	200	fe e t	above	an	equivalent platfor m from	which	filmin g is	planned.

• UA S will	NO T oper a te.

• 5	nautical	miles	(NM)	from	an	airport	having	an	operational	control	tower;	or

· 3	NM	from	an	airport	with	a	published	instrument	flight	procedure,	but	not	an	operational	tower;	or

· 2	NM from	an airport	withou t a	published	instrument	flight	proced u re	or	an

operational	tower;	or

· 2 NM	from	a	heliport	with	a	published	instrument	flight p rocedure

• Minimum	cr e w	for	each	operation	will	cons i st	of	the	UAS	pilot ( PIC),	the	visual	observ e r (VO ) and

may	include	but	not	l i mited	to	a	ca m era	operator

• The U AS	pilot	will	be	designated	pilot	in	command	and	h old a t	least	a Light S p o r t Pilot

C e rtificate along	with	a	Current	State	Drive r s	License. If	the P IC	feels	another	oper a tor	to	be

qualified	wit h	the	necess a ry	skills	to	be	pilot	in	com m and a nd	possesses a t	least	a 

### Light S p o r t

Pilot C e rtificate along w ith Curr e nt State	Drive r s	License

, that	person m ay	be	designated	PIC

provided	they	have	a	minimu m of	20	hours	of	flight	time	with	the	UAS.

• A	brief ing w ill	be	performed	reg a rding	the	planned	U A S	operations	prior	to	each	day’s	flight

consistin g of	all	days	pr o duction	a c tivities

• All	flights	will occur	under v isual	fl i ght	rules meteorological	conditions	(VFR	only )

.

• The	oper a tor	will obtain	verbal/w ritten	consent	of	all	persons i nvolved	with	the	planned

operations	and	ensure	only	cons en ting	persons	will be	allowed	within	100	feet	of	the	fl i ght

operation,	and	the	radius	may	b e reduced	to	30	feet	based	upon	an	eq u ivalent	level	of	safety

deter m ination, as	required	under	the	FOM. W ith	the	advance	pe r mission	of	the	FFDO,

oper a tions	at	clos e r	range	may	be	a p proved.

• Th e PIC	and VO	will have	be e n	trained	in	operation	of	UAS	and	r e ceive	up

- t o

- date i nformat i on

for	the	pa r ticular	UAS	to	b e operat e d.

• The P IC	an d VO will	be	able	to	communicate	by	voice,	radio,	and/or	text	at	a l l	times.

• W ritten	and/o r verbal	per m issio n	and	per m its	will	be	obtained	from	ter r itorial,	state,	county	or

city	jurisdictions,	including	law	enforc e ment,	fire	or	ot h er	appropriat e govern m ental	age n cies.

• If	the U AS	loses	com m unications	with	the	r e mote	c o ntroller	or	losses	GPS	si g nal, t he	UAS	w i l l

have	the	c a pability	to	return	to	a	pr e

- determined	location	within	a designated	location	and l and

autono m ously.

• The U AS	will	have	the	capability	to	abort	a	f l ight and	return	to	designated	landing	area in	case	of

unpredicted	obst a cles,	w e ather,	or	e m erge n cies.

• V O o r	P I C i nstructed	to	switch	UAS	to	automatica l ly	return	home	in	event	either	are

inca p acita t ed.https:// w ww.faa.gov/ u as/legislative_progra m s/section_333/ h ow_to_file_a

_ petition/me d ia/

section333

_ public_guid a nce.pdf

As of M arch 23, 201 5

, the FAA will autom a tically grant a "blanket" COA for flights at or below

200 feet to any U A S operator with a Sectio n 333 exemption, provi d ed the aircraft weighs less

than 55 p ounds, operati o ns are conducted d u ring daytime Visual Flight R u les (VF R ) co n diti o ns

a nd w ithin visu a l line of sight (VLO S ) of the pilots, a n d stay certai n distances a w ay from airports

or helip o rts.

In seeki n g auth o rization, p e titioners w ill

require exempti o ns from regulatio n s with

which t h ey cannot fully co m ply. The table

below provide s guida n ce regardi n g

regulati o ns from w h ich a peti t ioner ma y

require exemption. However, some

prop o sed operati o ns ma y require

exempt i on from reg u lations n ot listed

here, w h ile ot h ers ma y not re q uire

exemp t ion fro m all regula t ions liste d here

.

14 CFR PAR T

Par t 21 Airw o rthiness Certification

21, S u bp a rt H

91.10 3 (b)(2)

9 1 .1 0 5

9 1 .1 0 9

9 1 .1 1 9

9 1 .1 2 1

9 1 .1 5 1

9 1 .4 0 5

9 1 .4 0 7

9 1 .4 0 9

9 1 .4 1 7 Certification procedures for products and

parts, Airw o rthiness Certificates

Preflig h t acti o n

Flight cre w mem b e rs at sta t ions

Flig h t instr u ction

Mi n imum s a fe altitu d es

Altim e ter setting s

Fuel requireme n ts for flights in VFR

co n di t io n s

Mai n tenance required

Operatio n after maintenance

Ins p ecti o ns

Maintenance14	C.F.R.	Part 2 1,	Sub p art	H: A irwort h iness	C e rtificates 14	C.F.R.	Sec	91.203(a)(1)

The UA S will operate @ 55l b s or less (Gross), carries neither a pilot or passe n ger*, carries no explosive

materi a ls or flam m able li q uid fuel s *, and o perates i n withi n a s e cured a n d pre

- determined designate d

area, at altitudes n o t to exceed 200 feet ALT or speeds in access of 100 MP H

.

14	C.F.R.	Sec	91.105	Flight	crew	members	at	statio n

Exempti o n may be req u ired, the PIC may no t leave his station n o r shall VO leave statio n

. In event that

PIC or VO become i ncapacitated, U AS is to aut o matically return to design a ted landing area, as ou t line d

in F O M

14	C F R	Sec 9 1.10 9 Flight	Instruction	(Dual	Controls)

Requirin g that no perso n shall operate a civil aircraft for flight instruction u n less the aircraft has fully

functioni n g dual contr o ls

. UA S and Remote co n trolled aircraft by design do not have d ual controls, to

do so on a radio contr o lled aircraft would lower the ability to safely o p erate the UAS. This section

can n ot reaso n ably a pply

14	C.F.R. S ec	45.23( b ). M arkin g of	the	Aircr aft

Alth o ugh exem p tion from sai d section can n ot benefit n o r exceed current stipul a tions, ph y sical

lim i tat i on s of U A V a re reality, s uch a s cab i n s, letter size, ect. The U AV will ope r ate under my control with

regi s tration let t ering sized t o fit f use l age in c omplia n ce of said section 45.23(b) un d er conditio n s and o r

limitatio n s de e med m an d atory b y FAA. My	colleges	and	I must b e held respon s ible for com p lia n c y

, o n

behalf of Public’s safety an d shared air spac e

, as well as i ts n e e d to identify and e nforce the

acco u ntability a n d of this gro w ing industr y

.

14	C.F.R.	Sec	6 1 .113(a ) and	(b):	Pri v ate	Pilot	Privileges and	Limitations:	Pilot	in	Command

By current reg u lations bec a use the ap p licants U A S does not carry passengers, or property. The use of

UA S is fa r less dangerous ( w eight, speed, Fuel) than the inherent us a ge of commercial activities

outline d in 14 CFR.16

. The pilot in com m and sh a ll have a current Private pilots licens e as well as a

c urrent st a te drivers license wh ic h will equal if not exceed safe t y regula tions outlined in 1 4 CFR

1 6.113.(a) & (b).

14	C.F.R.	Sec.	91.10 3 : Preflight	Ac t io n :

Exemp t ion i s requested due to fact t hat FAA rotor flight manuals are not available for UAV. The PIC will

take all actions as state d in FOM, under norm a l procedures in cluded b u t not limited to revie w of

weat h er, examinati o n of batteries for flight ti m e analysis, landing a n d takeoff dista n ces as well as flight

an d aircraft performance in flig h t.14	C.F.R.	Sec	9 1 .119; M ini m um	S a fe	Altitudes

Ma n dates safe altit u de for operati o n of civil aircraft and all o w helico p ter to operates less t h en

minim u ms prescribed, provi d ing the person o p erating helicop t er complies with a n y route with a n d or

altitudes prescribed for Helicopter’s by FAA. Being that UAV is of Hel i copters standar ds and operation a

request for exempti o n to operate at a ltitude’s not to exceed 2 0 0 AGL or n o t more th a n 200 ft a b ove any

elevate d platform from w h ich take off is necessary to a chieved filming. In the eve n t of such particul a r

flight p lan, propert y owners, filmi n g crews and ot h er personnel w ould all b e briefed as to safety an d

conduct proce d ures during flight. FOB or AT C having jurisdiction i n such area woul d have notification

an d briefing as mandated.

14	C.F.R.	Sec	91.121 Altimeter	Se t ting s

The requireme n t of PIC is to use altimeter as mea n s to navigate aircraft to cruise altitu d es to and from

correspondi n g airports as predetermined in flight plan, u n less ordered otherwise. As the UAS has no

barometric altimeter, but inste a d uses GPS altitude read out, an exemptio n would need be ap p lied. Per

a pre flight c h ecklist and live flig h t data m onit o ring, the altit u de of lau n ch site will b e predetermi n ed

a n d therefore calculated int o the U AS

- GPS indicator before flight.

1 4	C.F.R.	S e c	91.151(a): F uel	Re q uireme n ts	f or	Flight	i n VFR	Co

Fuel requirements for flight. The maximu m flight time under ideal conditi o ns is 30 minutes with the

current manufacturers battery pack. The proposed rule un d er this exem p tion wo u ld require t h e U AS to

re t u r n to its p o int of launch if it s battery reac h es less than 25% p rovides a higher stan d ard of safety

whe n appli e d to U A S

.

1 4	C.F.R.	Sec	91.405(a);	407 ( a)(1);	409(a)(2);	41 7 (a)	&	(b): M aintena n ce	Inspections

Referring to main t enance, preventive m a intenance, a nd alterations to the UAS. T he operator will

provide min o r maintenance a n d inspection to the U AS

, document e d as o u tlined i n the op e ration a l

and s a fety guideline s

. Given the size and si m plicity of the U AS combined with the operati o nal and

safety gui d elines o u tlined in this petiti o n th e operat o r can maintain o r exceed the required level of

saf e t y

.

Sincerely

Alan	Holland

Daedalus	Aerial	Imaging