### Drone Control Systems , LLC

1964 North Red Rock Road

P.O. Box 252 Dragoon, Arizona 85609

Phone: 520

- 686

- 4303

Fax: 520

- 329

- 6258



### July 28, 2015

U.S. Dept. of Transportation, Docket Operations West Building Ground Floor, Room w12

- 140 1200 New Jersey Avenue, SE., Washington, DC 20590

Re: Exemption Request under Section 333 of the FAA Reform Act and Part 11 of the Federal Aviation Regulations

Dear Sir or Madam:

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the “Reform Act”)
and 14 C.F.R. Part 11, Drone Control Systems, LLC seeks an exemption from Federal Aviation Regulations (“FARs”) detailed below for the following described Unmanned Aerial System
described in this document, which includes an Unmanned Aircraft and ground st ation

- based
equipment and crew:

THE UNMANNED AIRCRAFT:

 A lightweight (6.5 lbs gross weight with all on

- board equipment), battery operated 4

- motor rotorcraft in the form of a quad

- copter that takes off and lands vertically, and is manufactured by DJI, Insp ire 1, Model T600 . T he Unmanned A ircraft is not modified from the original delivered form.

 An on

- board flight computer with GPS navigation and location ability that receives signals for flight controls from a ground

- based transmitter/ and dual controller s ystem ;

 An on

- board camera capable of capturing imagery in the form of full color, high

def inition still photos and video;

 An on

- board telemetry system that delivers flight data from the on

- board flight computer

to the on

- board radio transmitter including altitude AGL, horizontal and vertical speed, compass direction of flight and dir ection back to its launch site;

 O n

- board radio transmitter that transmits live video from the on

- board camera plus all the flight data from the te lemetry system described above ;

THE GROUND STATION

- BASED PART OF THE SYSTEM:

 An Unmanned Aircraft Pilot in operational control of a flight operation from beginning to end and who controls the Unmanned Aircraft while in flight;

 A Visual Observer whom is constant contact and Pilot and provides visual support of all flight operations;

 A Camera Operator whom is responsible for all camera and gimbal control during flight operations. A radio transmitter/controller operated by the Pilot to control the Unmanned Aircraft

while in flight; The controller operates on frequencies between 5.725 GHz

– 5.824 GHz

and 2.400 GHz

– 2.483 GHz.

 A radio receiver receiving live video and flight data from the on

- board camera and computer projects it all together onto a screen for the Pilot to view during flig ht;

 A Visual Observer is a person who provides a second pair of eyes to visually track the Unmanned Aircraft while in flight.

 A Camera Operator is a person who uses the second slave controller to control camera operation to allow Pilot and Visual Observer to focus on Unmanned Aircraft operation.

The requested exemption would support an application for a commercial Certificate of

A uthorization to use the above described Unmanned Aircraft System to support aerial pho tography and video capture services in support of real

- estate agency websites and real

- estate agent/client use , agricultural livestock containment and crop health inspections.

Low level photos and video from several angles are far more effective for real

- estate
advertisemen t than ground

- based imagery for displaying the characteristics of large, complex properties listed by agents and agencies for sale

. The benefits of reduced cost and improved quality of presentation from the Unmanned Aircraft provide a valuable benefit to agencies,

agents, buyers and sellers of real

- estate property.

The use of aerial photography and high definition video capture to provide large agricultural operations an overview of their crops and livestock containment area aids the rancher or farmer in quickly assessing the overall health of their crops as well as providing quick identification of fencing and containment structures that require repair. Ground based inspections is time consuming and does not present an overall view of the area.

The Unma nned Aircraft System will be operated in the field with both a Pilot, Visual Observer, and dedicated Camera Operator in accordance with FAA Policy N 8900.227 Section 14 "Operational Requirements for UAS" and with the following Restrictions:

a) No flight will be made with a n Unmanned Aircraft’s Gr oss weight exceeding 25 pounds;
b) All operations must occur in FAA Class G airspace at no more than 400 ft. AGL, at an airspeed of no more than 2 5 knots and no further than 3⁄4 NM from the Pilot;
c) All operations must utilize a Visual Observer, and dedicated Camera Operator. The Visual Observer and Pilot must be able to communicate by voice at all times during a flight operation;
d) Operations will be restricted to flights over private property with the permission of the

p roperty owner; e) The Pilot must have accumulated and logged, in a manner consistent with 14 CFR § 61.51 (b), a minimum of 100 flight cycles and 25 hours of total time as a Unmanned

Aircraft quad copter pilot;
f) All required permits will be obtained from state and local government prior to operation;
g) The Unmanned Aircraft System will not be operated over densely populated areas;
h) The Unmanned Aircraft System will not be operated at air shows;
i) The Unmanned Aircraft System will not be operated over heavily traffick ed roads;
j) The Unmanned Aircraft System System will not be operated within 5 NM of an airport or heliport;
k) Operations will be restricted to day only and weather conditions equivalent to Visual Flight Rules ;l) The Pilot will brief the Visual Observer and Prope rty O wner about the operation and risk

before the first flight at each new location;
m) No flight may be made without a Pre

- Flight Inspection by the Pilot before each operation

to ascertain that the Unmanned Aircraft is in a condition sa fe for flight (see App endix A);

The Pilot, Visual Observer, and Camera Operator will meet the requirements outlined in FAA Policy N 8900.227 Section 16 personnel Qualifications. Additionally, the Pilot and Visual Observer will perform all required maintenance on the system in accordance with the manufacturer’s recommendations. Repairs to the Unmanned Aircraft will be performed only by

authorized dealers of the Unmanned Aircraft.

We submit that the combination of the Unmanned Aircraft’s light weight, flight performance and

abi lity, fully qualified flight crew and strict operation under the guidelines established in 8900.227, and under all of the Restrictions (a) through (m) listed above, the FAA can have full confidence that the operation will have an equivalent or greater leve l of safety than manned aircraft performing the same mission.

The name and contact information of the applicant is :

Drone Control Systems , LLC

Attn: James D. Lawrence

Phone: 520

- 686

- 4303

Fax: 

### 520

- 329

- 6258

Email: james.d.lawrence@red

- nranch.com

The regulations from which the exemption is requested are listed below together with our proposed equivalent level of safety for each regulation:

 14 CFR Part 21

 14 CFR 9 1.203

 14 CFR 45.23, 45.29

 14 CFR 91.9

 14 CFR 61.113, 61.133

 14 CFR 91.109, 91.119, 91.121

 14 CFR 91.151

 14 CFR Subpart E (91.401

- 91.417)

 FAA Policy 8900.227 Paragraph 16(c)(4) and Paragraph 16(e)(1)

We are prepared to modify or amend any part of this re quest to satisfy the need for an equivalent level of safety. Please contact us at any time if you require additional information or clarification.

We look forward to working with your office.ADDENDUM EXEMPTION REQUESTS AND EQUIVALENT LEVEL OF SAFETY

Drone Control Systems LLC , requests an exemption from the following regulations as well as any additional regulations that may technically apply to the operation of the Unmanned Aircraft System:

14 CFR Part 21, Subpart H: Airworthiness Certificates This p art establishes the procedures for the issuance of an airworthiness certificate. While the FAA continues to work to develop airworthiness standards for Unmanned Aerial Systems, we request an experimental certificate be issued for the Unmanned Aircraft Syst em under either or

bo th of the following provisions: 21.191 Experimental certificates. Experimental certificates 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 including 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 reliability requirements of the regulations.

Since the experimental certificate can be used for commercial purposes such as market surveys, sales demonstrations, and customer crew training, we would expect that an experimental certificate would permit our commercial purpose as well

.

The aircraft will not carry persons or property, will not carry fuel, and will only fly under strict operational requirements. Combined with the Unmanned Aircrafts’ light weight, being constructed primarily of carbon fiber and plastic, we propose that t he Unmanned Aircraft will be at least as safe, if not safer, than a conventionally certificated aircraft performing the same

mission.

If an experimental airworthiness certificate is not appropriate for this application, then we request an exemption of 14 CFR Part 21, Subpart H, and the requirement for an airworthiness certificate in general, citing the equivalent level of safety outl ined in the previous paragraph.

14 CFR 91.203(a) & (b) Civil aircraft: Certifications required. The regulation provides that an airworthiness certificate, with the registration number assigned to the aircraft and a registration certificate must be aboard the aircraft. Additionally, subparagraph (b) provides that the airworthiness certificate be "displayed at the cabin or cockpi t entrance so that it is legible to passengers or crew."

At a maximum gross weight of 6.5 pounds, the Unmanned Aircraft is too small to carry documentation, does not have an entrance, and is not capable of carrying passengers or crew. To obtain an equiva lent level of safety and meet the intent of 91.203, we propose that documents deemed appropriate for this aircraft by the FAA will be co

- located with the crew at the ground control station and available for inspection upon request. In order to identify th e aircraft, we propose that the information found on airworthiness and 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 , which follows immediately after the proposed placard description below:EXPERIMENTAL Drone Control Systems , LLC

1964 North Red Rock Road Dragoon, A Z 85609

Model: T600 , Serial Number: W13DCD25030957

If found please contact: ( 520 ) 686

- 4303

14 CFR 45.23 Display of marks; general and 45.29 Size of marks. These regulations provide that each aircraft must display "N" and the aircraft's registration number in letters at least 3 inches high. Additionally, the aircraft must display the word

"EXPERIMENTAL" in le tters at least 2 inches high near the entrance to the cabin, cockpit, or pilot station. The Unmanned Aircraft does not have an entrance in which the word

"EXPERIMENTAL" can be placed, and may not have a registration number assigned 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 Pilot

, Visual Observer, Camera Operator and others in the vicinity of the aircraft while it is prepar ing for launch will be able to see the designation. Additionally, we feel that the permanent placard discussed in the previous paragraph will provide the aircraft's registration information at the ground station.

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 the intent of this requirement is to ensure that flight

manual information is available to the aircrew 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 crew during flight operations.

To obtain an equivalent level of safety and meet the intent of 91.9, we propose that a current, approved Unmanned Aircraft Flight Manual (Appendix A) must be available to the crew at the ground station anytime the aircraft is in, or preparing for, flight.

14 CFR 61.1 13 Private pilot privileges and limitations: 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. Subparagraph (b) allows a private pilot to act as pilot in command of an aircraft in connection with any business or employment if: 1) The flight is only incidental to that business or employment; and 2) The aircraft does not carry passengers or propert y for compensation or hire.

Our proposed operations require that the Pilot must: 1) H ave logged a minimum of 25 hours of flight experience in this type of Unmanned

Aircraft or 2) M eet the requirements of 8900.227 para 16(c)(2)(c) "Operations without a pilot

cer tificate" in which the Pilot is required to complete "FAA private pilot ground instruction" and pass "the FAA Private Pilot written examination." Since the aircraft cannot carry passengers or property, we feel we meet the intent of 61.113 Subparagraph (b) even though the intent of this application is to con duct a business.

14 CFR 91.109 Flight Instruction; Simulated instrument flight and certain flight testsThe regulation states that "No person may operate a civil aircraft that is being used for flight

i nstruction unless that aircraft has fully functioning dual controls." The Unmanned Aircraft System ground

- based control station consists of a small hand

- held radio transmitter and a second

set of hand

- held radio transmitter controls that serve as a slave control system and back

- up control system for the Unmanned Vehicle. The Inspire 1 Unmanned Aircraft is the only DJI developed drone that provides this capability

. H aving this dual control capability for both student

and instructor we feel meets the inten t 91.109 and provides an equivalent level of sa fety.

14 CFR 91.119 Minimum safe altitudes: General. The regulation states that over sparsely populated areas the aircraft cannot be operated closer than 500 feet to any person, vessel, vehicle, or structure. Since the aircraft will be operating at a maximum of 400 feet AGL, we canno t comply with this requirement.

In order to provide an equivalent level of safety we will only fly over private property with the permission of the owner of the property flown ove r. The aircraft will not b e operated over congested areas. The property owner will be briefed on the expected route of flight and the associated risks to persons and property on the ground. The aircraft will be 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 small size of the Unmanned

Aircraft , the hazard to persons, vehicles and structures is minimal compared to manned airc raft,

which should be consid ered in granting the exemption.

14 CFR 91.121 Altimeter settings. The regulation requires that aircraft shall maintain cruising altitudes by reference to an altimeter setting available within 100 NM of the aircraft.

The Unmanned Aircraft will always fly below 400 feet AGL and will not need to maintain cruising altitudes in order to prevent conflict with other aircraft. An Above Ground Level altimeter measurement above the takeoff point is transmitted via radio from the U nmanned

Aircraft’s on

- board computer to the display screen held by the Pilot , providing a constantly updated AGL readout.

14 CFR 91.151 Fuel requirements for flight in VFR conditions. The regulation provides that no person may begin a flight in an airplan e under day

- VFR conditions unless there is enough fuel to fly to the 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. The Unmanned Aircraft is battery operated and the maximum duration of flight from a single battery charge is 14.5 minutes with a 20% reserve. Since the aircraft will never fly

more than 3⁄4 NM from the point of intended landing, a full ba ttery charge at launch will ensure

that we meet the reserve 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 Subpart E (91.401

- 91.417)

- Maintenance , Preventive Maintenance, Alterations

. The regulation provides that the operator is primarily responsible for maintaining the aircraft in an airworthy condition, including compliance with part 39 and 43. Paragraphs 91.407 and 91.409 require that the aircra ft be "approved for return to service by a person authorized under 43.7" after maintenance and inspection.

It is our intention that the Pilot perform maintenance and inspection of the aircraft and "be authorized to approve the aircraft for return to servi ce." As provided in the Pre

- Flight Checklistin Appendix A, the Pilot will ensure that the aircraft is in an airworthy condition prior to every

flight and in addition conduct detailed inspections after every two hours of flight. Maintenance performed by the Pilot is limited to repairing small cracks, replacing a propeller, checking electrical connections and updating software and firmware for the on

- board computer. All other maintenance will be performed by the manufacturer or their designated repair fac ility. The Pilot will document work performed in accordance with 91.417.

We feel that due to the size, construction, and simplicity of the aircraft, the Pilot can ensure an equivalent level of safety.

8900.227 Paragraph 16(c ) ( 4) PIC Medical. And Paragraph 16(e ) ( 1) Observer Medical. This policy provides that both the Pilot and Visual Observer must have a valid FAA second

- class

medical certificate issued under part 67 in order to perform as a pilot or observer.

The Unmanned Aircraft’s maximum gro ss weight is 6.5 pounds, it is constructed of carbon fiber and plastic and the Pilot is not on board. Both the Pilot and the Visual Observer are required to

be in VLOS. Given the unlikely event that both the Pilot and Visual become medically incapacitate d while the aircraft is in flight, the Unmanned Aircraft will return autonomously to the site of launching and land without crew intervention as the DJI Inspire 1 drone is equipped with a return to home GPS homing feature should the communications with the drone become interrupted or lost.

Therefore, requiring the Pilot and Visual Observer to meet the same medical requirements as commercial pilot carrying passengers in a large aircraft is an unnecessary burden.

We propose that the minimum medical requirements for the Pilot and Visual Observer be vision

corrected to 20/20 and a valid, state issued driver's license. The 20/20 vision requirement will

ensure that the Pilot and Visual Observer can see and avoid air t raffic; a licensed driver is medically qualified to operate a much larger vehicle.APPENDIX A

FLIGHT OPERATIONS MANUAL
a) No flight will be made with a n Unmanned Aircraft’s Gr oss weight exceeding 25 pounds;
b) All operations must occur in FAA Class G airspace at no more than 400 ft. AGL, at an airspeed of no more than 25 knots and no further than 3⁄4 NM from the Pilot;
c) All operations must utilize a Visual Observer, and dedicated Camera Operator. The

Visual Observ er and Pilot must be able to communicate by voice at all times during a flight operation;
d) Operations will be restricted to flights over private property with the permission of the

property owner; e) The Pilot must have accumulated and logged, in a manner cons istent with 14 CFR § 61.51 (b), a minimum of 100 flight cycles and 25 hours of total time as a Unmanned

Aircraft quad copter pilot;
f) All required permits will be obtained from state and local government prior to operation;
g) The Unmanned Aircraft System will not be operated over densely populated areas;
h) The Unmanned Aircraft System will not be operated at air shows;
i) The Unmanned Aircraft System will not be operated over heavily trafficked roads;
j) The Unmanned Aircraft System will not be operated within 5 NM of an airport or heliport;
k) Operations will be restricted to day only and weather conditions equivalent to Visual Flight Rules;
l) The Pilot will brief the Visual Observer and Property Owner about the operation and risk before the first flight at each new locatio n; m) No flight may be made without a Pre

- Flight Inspection by the Pilot before each operation to ascertain that the Unmanned Aircraft is in a condition safe for flight (see Appendix A);

PRE

- FLIGHT CHECKLIST
1) Use DJI Pilot Mobile Application to verify Unmanned Aircraft battery is fully charged in order to prevent unexpected premature descent; 2) Check all wiring connections are tight; 3) Check all propellers are undamaged and no cracks exist in any structural members of the Unmanned Aircraft; 4) Turn on radio controller, check for adequate voltage, set it to connect to the Unmanned Aircraft, move all control switches to forward or down position;
5) Turn on secondary controller, check for adequate voltage, set it to connect as the slave to the Unmanned Aircraft, move all control switches to forward or down position to verify gimbal functionality and slave functionality is correct.
6) At a location different from previous flight, re

- set GPS and compass to current location;
7) Turn on transmitter, gimbal and camera.

TO R EGAIN CONTROL AFTER LOST RADIO CONTACT 1) Prior to initiating flight establish home point by setting home point through DJI Pilot Mobile Application. 2) DJI Inspire 1 drone is equipped with return to home capability upon loss of radio contact

.