Page 1 of 10 12/10 /15

Deborah Winkelman : CEO Thomas Christopher Coyle: President

ArcticZoneDrone LLC

Physical Address 8749 Cormorant Way

Wasilla AK 99823

Mailing Address:

P.O. Box 879016

Wasilla AK 99687

Cell: 907

- 317

- 6432 (Deb)

Cell: 907

- 250

- 2565 (Chris)

Office: 907

- 373

- 9219

Email: Akdebwinkelman@gmail.com Akchriscoyle@gmail.com

U.S. Department of Transportation Docket Management System 1200 New Jersey Ave., SE W ashington,

DC 2059

RE: Exemption Request Section 333 of the FAA Reform Act of 2012

Attachments: 1) Phantom 3 Pro Technical Data 2) Phantom Inspire 1 Technical Data 3) DJI S afety Tips for Flying in Cold Weather

References: 1) Exemption No. 11409 Regulatory Docket No. FAA

- 2015

- 0187 in the matter of the petition of WADE BELL. 2) SkyLynx, LLC petition for exemption letter. 3) Steel City NDT LLC, BlackHawk Aerial Systems p etition for exemption letter.Page 2 of 10 Dear Sir or M adam,

In accordance with the FAA's Guidelines for Submitting a Petition for Exemption under section 333 of the

FAA Moderni zation and Reform Act of 2012, we Deborah Winkelman and Thomas C Coyle , owners of ArcticZoneDrone LLC, referred to hereafter as the p etitioner s , request exemption from the following sections of Title 14, Code of Federal Regulations §§

14 CFR 21 subpart H; 14 CFR 45.23(b); 14 CFR 61.113(a); 14 CFR 61.113(b); 14 CFR 91.7(a); 14 CFR 91.9(b) (2); 14 CFR 91.103; 14 CFR 91.109; 14 CFR 91.119 (c); 14 CFR 91.121; 14 CFR 91.151(a); 14 CFR 91.203(a); 14 CFR 91.203(b); 14 CFR 91.405(a); 14 CFR 91.407(a) (1); 14 CFR 91.409(a) (2); 14 CFR 91.409(a)(2); 14 CFR 91.417(a); 14 CFR 91.417(b);

In order to operate small Unmanned Aircraft Systems (UAS) commercially in airspace regulated by the Federal Aviation Administration (FAA) for the purposes of aerial photography, cinematography, video photo graphy, mapping, crop surveying, inspection and other flight operations that could be performed safely

and mo re cost effectively with the use of small U AS at low altitude within the United States national airspace system as compared to a manned aircraft. Operations will be performed only at the request of and

with the commerce and raise awareness of the beneficial uses of small unmanned air systems. So long as such operations are conducted within and under the conditions outlined herein or as may be established by

t he FAA as required by Section 33 3. The conditions identified and proposed by the petitioner s are drawn

from Attachments 1

- 3

.

The Federal Aviation Regulations (FARs)

14 CFR Part 21 subpart H 14 CFR
45.23 (b) 14 CFR 61.113 (a) & (b) 14
CFR 91.7 (a) 14 CFR 91.9 (b) (2) 14

CFR 91.103 14 CFR 91.109 14 CFR
91.119 (c) 14 CFR 91.121 14 CFR
91.151 (a) 14 CFR 91.203 (a) & (b) 14
CFR 91.405 (a) 14 CFR 91.407 (a) (1)
14 CFR 91.409 (a) (1) 14 CFR 91.409
(a) (2) 14 CFR 91.417 (a) & (b)

The petitioner seeks exemp tion from the above mentioned F ARs for the following reasons;

14 CFR Part 21, Subpart H: Airwort hiness Certificates 14 CFR §91.203(a) (1) Subpart H , entitled Airworthiness Certificates, establishes the procedural requirements for the issuance of airworthiness certificates as required by FAR §91.203 (a) (1) . Given the size and limited operating area a ssociated with the aircraft to be utilized by the Applicant, an exemption from Part 21 Subpart H meets the requirements of an equivalent level of safety under Part 11 and Section 333 of the Reform Act.Page 3 of 10 The Federal Aviation Act (49 U.S.C.§44701 (f)) and Section 333 of the Reform Act both authorize the FAA to exempt aircraft from the requirement for an airworthiness certificate, upon consideration of the size, weight, speed, operational capability, and proximity to airports and populated areas of the parti cular UAS. In all cases, an analysis of these criteria demonstrates that the UAS operated without an airworthiness certificate, in the restricted environment and under the conditions proposed will be at least as safe, or safer,

than a conventional aircraft (fixed wing or rotorcraft) operating with an airworthiness certificate without the restrictions and conditions proposed.

The UAS to be operated hereunder is less than 55 lbs. fully loaded, carries neither a pilot nor passenger, carries no explosive materials or flammable liquid fuels, and operates exclusively within a secured and designated area. Unlike other civil aircraft, operations under this exemption will be tightly controlled and monitored by both the operator and under the requirements and in compliance with local public safety requirements. The FAA will have advance notice of all operations. These safety enhancements provide a greater degree of safety to the public and property owners than conventional operations conducted with airworthiness certificates issued under 14 C.F .R. Part 21, Subpart H. Lastly, application

of these same criteria demonstrates that there is n o credible threat to national security posed by the UAS, due to its size, speed of operation, location of operation, lack of explosive materials or flammable liquid fuels, and inability to carry a substantial external load.

14 CFR §45.23(b): Marking of th e Aircraft : When marks include only the Roman capital letter "N" and the registration number is displayed on limited, restricted or light

- sport category aircraft or experimental or provisionally certificated aircraft, the operator must also display on that aircraft near each entrance to the cabin, cockpit, or pilot station, in letters not less than 2 inches nor more than 6 inches high, the words "limited," "restricted," "light

- sport, "experimental," or "provisional," as applicable. Even though the UAS will have no airworthiness certificate, an exemption may be needed as the U AS will have no entrance to the cabin, cockpit or pilot station on which the word "Experimental" can be placed.

Given the size of the UAS, two

- inch lettering will be impossible. The wor d "Experimental" will be placed on the fuselage in compliance with §45.29 (f).

The equivalent level of safety will be provided by having the UAS marked on its fuselage as required by §45.29 (f) where the pilot, observer and others working with the UAS wi ll

see the identification of the UAS as "Experimental."

14 CFR §61.113(a) and (b): Private Pilot Privileges and Limitations

- Pilot in Command The petitioner s requests relief in order to facilitate the utilization of pilots, who hold a Private Pilot (or greater) certificate. Any pilots operating under this exemption would be required to comply with any conditions as set forth and in a similar fashion to the previously granted exemptions.

14 CFR §91.7(a): Civil Aircraft Airworthiness No person may operate a civil aircraft unless it is in airworthy condition. As there will be no airworthiness certificate issued for the aircraft, should this exemption be granted, no FAA regulatory standard will exist for determining airworthiness. Given the size of the aircraft for maintenance and use of safety check lists prior to each flight an equivalent level of safety will be provided.Page 4 of 10 14 CFR §91.9(b) (2): Civil Aircraft Flight Manual in the Aircraft Section §91.9 (b) (2) provides: No person may operate a U.S.

- registered civil aircraft (2) For which an Airplane or Rotorcraft Flight Manual is not required by §21.5 of this chapter, unless there is available in the aircraft a current approved airplane or Rotorcraft Flight Manu al, approved manual material, markings, and placards, or any combination thereof. The UAS, given its size and configuration has no ability or place to carry such a flight manual on the aircraft, not only because there is no pilot on board, but because ther e is no room or capacity to carry such an item on the aircraft. The equivalent level of safety will be maintained by keeping the flight manual at the ground control point where the pilot flying the UAS will have immediate access to it.

14 CFR §91.103: Pr eflight Action This regulation requires each pilot in command to take certain actions before flight to insure the safety of flight. As FAA approved rotorcraft flight manuals will not be provided for the aircraft an exemption will be

needed. The PIC will t ake all actions as stated in the FOM in Section 4 under Normal Procedures including but not limited to reviewing weather, flight battery requirements, landing and takeoff distances and aircraft performance data before initiation off light.

14 CFR §91.109: Flight Instruction Section §91.103 provides that no person may operate a civil aircraft (except a manned free balloon) that is being used for flight instruction unless that aircraft has fully functioning dual controls. UAS and remotely piloted aircraft, b y their design do not have fully functional dual controls. Flight control is accomplished through the use of a control box that communicates with the aircraft via radio communications. The FAA has approved exemptions for flight training without fully

funct ional dual controls for a number of aircraft and for flight instruction in experimental aircraft. The equivalent level of safety provided by the fact that neither a pilot nor passengers will be carried in the aircraft and by the size and speed of the aircr aft.

14 CFR §91.119(c): Minimum Safe Altitudes

As discussed in Exemption 11138 (DOUGLAS TRUDEAU), operations conducted closer than 500 feet to the ground may require that the UAS be operated closer than 500 feet to essential persons, or objects that woul d not be possible without additional relief. The petitioner’s requests modification, waiver or exemption and clarification concerning the terms "congested areas" and "densely populated". The petitioner s request a
waiver for this condition to allow reasonab le and responsible operations in areas of subdivisions and neighborhoods if required.

14 CFR §91.121: Altimeter Settings

As discussed in Exemption 11138 (DOUGLAS TRUDEAU) is inapplicable since the UAS does not

have an altimeter and instead utilizes elect ronic GPS with a barometric sensor for altitude information.

14 CFR §91.151(a): Fuel Requirements for Flight in VFR Conditions

As discussed in Exemption 11136 (ADVANCED AVIATION SOLUTIONS LLC) prior relief has been granted for manned aircraft to operate at less than the prescribed minimums, including Exemption Nos. 2689, 5745, and 10650. In addition, similar UAS

- specific relief has been granted within Exemption Nos. 8811, 10808, and 10673 for da ytime, VFR conditions. The UAS provides battery power remaining in percent to the PIC. The UAS batteries provide approximately an average of 25 minutes of powered flight. Information provided in the Operating documents discusses procedures regarding

remain ing battery power management. Those documents contain a condition in which the PIC will initiate a landing procedure when battery remaining reaches a specified level. Given the limitations on proposed operations and the location of those proposed operation s, The FAA found that a reducedPage 5 of 10 minimum power reserve for flight in daytime VFR conditions was reasonable.

14 C FR § 9l.203 ( a) and (b): Carrying Civil Aircraft Certification and Registration

Th e reg u lat ion provides in pertinent part: (a) Except as provi ded in §91.715, no person may operate a civil aircraft unless it has within it the following:
(1) An appropriate and current airworthiness certificate (b) No person may operate a civil aircraft unless the airworthiness certificate required by paragraph ( a) of

this section or a special flight authorization issued under §91.715 is displayed at the cabin or cockpit entrance so that it is legible to passengers or crew. The UAS fully loaded weighs no more than 55 lbs. and is operated without an onboard pilot. As such, there is no ability or place to carry certification and registrat ion documents or to display them on the UAS. An equivalent level of safety will be achieved by keeping these documents at the ground control point where the pilot flying the UAS will have immediate access to them; to the extent they are applicable to the U AS.

91.405(a); 91.407(a) (1); 91.409 (a ) ( 1) & (2); 91.417(a) & (b): Maintenance Inspections as discussed in Exemption 11138 (DOUGLAS TRUDEAU), the petitioner s proposes to inspect and ensure that the UAS is in a condition for safe flight in accordance with the operating documents. The FAA found that adherence to the petitioner's operating documents and the conditions and limitations specified, describing the

req uirements for maintenance, inspection, and recordkeeping, were sufficient to ensure that safety would not be adversely affected.Page 6 of 10 THE S UAS(s)

DJI Phantom 3 Pro

– Serial # P76DCI06011238

The DJI Phantom 3 is a new highly successful consumer grade small rotorcraft in the quad copter configuration with an advertised weight of 45 Ounces (1280g) designed primarily to carry aloft a high

definition camera. It has an advertised maximum speed of 3 1 knots (16 rn/s) and a maximum climb rate of 984 feet per minute (5 m/s). The DJI Phantom 3 is powered by four electric motors with a distance between

motors of 23.22 inches (590 mm). The DJI Phantom 3 utilizes and internal inertial measuring unit (IMU)

w ith integrated barometric sensor augmented with global positioning system (GPS) to maintain its geospatial orientation and position. It is controlled primarily through an FCC certified radio control (RC) unit. Real time video and telemetry information is t ransmitted back to a ground control station allowing the operator and/or PIC to monitor battery level, GPS signal strength, altitude (AGL), distance from PIC, camera imagery, and control camera angle. It has failsafe modes of operation for either loss of R C or GPS signal. Altitude can be limited by the onboard flight controller and maximum altitude can be preprogrammed by the PIC. Battery life limits flight times to approximately 23 minutes. The onboard flight controller will warn the pilot via telemetry an d external lighting cues before reaching a low battery state. An automatic termination of flight and landing will be initiated when the battery reaches a predetermined low

state. It is anticipated that flights will usually last less than I 0 minutes. More information is available in

Attachment 1 or http : / / www

. dji

. com/product/phantom

- 3 / spec

.

DJI Inspire 1

- Serial #W13DCB04020105 The DJI Inspire 1 is DJI's newest and most advanced consumer grade small rotorcraft in the quad copter configuration with an advertised weight of less than 103.5 Ounces (2935g) designed primarily to carry aloft a high definition camera. It has an advertised maximum speed of less than 42.8 knots (22 rn/s) and a

maximum climb rate of less than 990 feet per m inute (5 rn/s). The DJI Inspire I is powered by four electric

motors with a distance between motors of22 to 22

. 87 inches (559 to 58Imm)

. The DJI Inspire I utilizes an internal inertial measuring unit (IMU) with integrated barometric sensor augmented with g lobal positioning system (GPS) to maintain its geospatial orientation and position. It is controlled primarily through an FCC certified radio control (RC) unit. Real time video and telemetry information is transmitted back to a ground

control station allow ing the operator and/or PIC to monitor battery level, GPS signal strength, altitude (AGL), distance from PIC, camera imagery, and control camera angle. It has failsafe modes of operation for either loss of RC or GPS signal. Altitude can be limited by the o nboard flight controller and maximum altitude can be preprogrammed by the PIC. Battery life limits flight times to approximately I8 minutes. The onboard flight controller will warn the pilot via telemetry and external lighting cues before reaching a low

ba ttery state. An automatic termination of flight and landing will be initiated when the battery reaches a predetermined low state. It is anticipated that flights will usually last less than 1 0 minutes. More information

is available in Attachment 2 or http : / / www

. d j i.com/product/inspire

- 1 / specPage 7 of 10 RISK MITIGATION & SAFETY

The petitioner s have reviewed FAA exemption reference's 1

- 3 Conditions and Limitations section and the procedures set forth will be utilized in order to manage and mitigate risk and ensure public safety. A preflight checklist will be developed and implemented to ensure that the UA airworthiness will be verified and documented before flight. Airworthiness will be maintained by performance of routine inspections before each flight, maintaining flight and maintenance logs to record time on failure

- prone components. In addition a full safety program will be implemented and followed to ensure that further safety precautions are followed during operational flights. Full maintenance procedures (SOPs) as well as maintenance frequencies shall be developed and documented to reduce and/or eliminate failures.

The petitioner’s requests that in a manner si milar to reference 3, that the petitioner s be allowed to operate

within 5 miles of an airport provided that;

"The UA may not operate in Class B, C, or D airspace without written approval from the FAA

. The UA may not operate within 5 nautical miles of the geographic center of a non

- towered airport as

denoted on a current FAA

- published aeronautical chart unless a letter of agreement with that airport's management is obtained, and the operation is conducted in accordance with a NOTAM as required by the opera tor's COA. The letter of agreement with the airport management must be made available to the Administrator upon request."

Operations within 5 miles of an airport are not anticipated to be routine but the petitioner s are requesting

a mechanism to facilitat e such activities without requesting a new and separate exemption(s) should the need arise. Operations within class B airspace are not requested due to the lack of mode C transponder.

PUBLIC INTEREST

Use of specified UAS(s) in lieu of a manned aircraft w ould enhance safety and reduce the environmental impact as compared to similar operations conducted with manned aircraft of greater proportions, carrying a crew and flammable fuel. Additionally, use of specified UAS(s) in order to facilitate commerce could lead to economic growth. Operations for this petition will enable service for property owners or their designees seeking an enhanced perspective for characteristics, amenities, and benefits of their desired photographic subjects that cannot be displayed t hrough ground level video and photo graphy . Aerial photography is a valuable marketing tool that can lead to increased commerce and enhance personal photography. Crop surveying applications could lead to decreased use of pesticides and fertilizer and conser vation of water as well as increased crop yields and decreased costs. Aerial surveying and inspections can increase work site efficiency, improve volumetric estimations and reduce risks. The petitioner s will provide clients with photographic data for these purposes on a 'for hire' basis acting as an independent contractor. A visual observer will be utilized. Liability insurance will be obtained commensurate with the granting of this request for exemption. Flight data including UA flight time, control unit o peration time, incident, accident, and details concerning any deviations from normal operations will be available to FAA for use in collect ing data regarding the use of U AS ’s as part of this application. This data may be submitted to FAA via traditional

me ans, e.g. COA Monthly Reports or other means as required.Page 8 of 10 The petitioners will utilize all recommended safety guidelines from the manufactures of the SUAS’s such as the following (attachment 3):

DJI Safety Tips for Flying in Cold Weather (DJI News 12

- 11

- 15)

Flying DJI aircraft in winter can be fun, but bear in mind that as the temperature drops, so does the battery’s performance. It has come to DJI’s attention that several of our users have experienced issues when flying in

cold weather. These issues include sudden drops in battery voltage, motor output overload and, in some cases, even crashing the aircraft. In response, we urge users to read the following tips to ensure flight safety when flying in cold weather.

The Intelligent Flight Ba ttery contains a Li

- Po battery cell. The performance of the Li

- Po battery cell is subject to ambient temperature so that the battery drains significantly faster at cold temperatures (15°C). When the Intelligent Flight Battery is placed in cold environments , the chemical reactions within the battery cell are subdued, leading to increased resistance and eventually a significant drop in battery voltage. The drop in battery voltage (below 3V per cell) contribute to two major risks. Firstly, the propulsion syste m on the aircraft can suffer from lack of thrust due to the low voltage. Secondly, the battery will automatically

shut off because the over

- discharge protection will have taken effect. This is a known limitation to all Li

- Po batteries and many mobile devic es that use Li

- Po batteries also have the same issue. Note that you might not be able to use your mobile device at cold temperatures for the same reason.

Aircraft such as the Inspire 1 and Inspire 1 Pro require more power to sustain flight and carry out ma neuvers such as climbing at high speeds. At high altitudes where air pressure is low, the motors on the aircraft will rotate faster in order to produce enough lift. Consequently, even more power output is required and the battery voltage will be more likel y to drop to an extremely low level, triggering over

- discharge protection. Therefore, we strongly recommend that users charge the battery to 100% in order to prevent over

- discharge protection from triggering.

Follow the tips bellow when you are flying the aircraft:

1.Fully charge the battery before each flight.

2.Allow the battery to warm up to 25°C or more. It is recommended to use the Battery Heater to warm up the battery.

3.Hover the aircraft for about a minute to allow the battery to warm upPage 9 of 10 CONCLUSION

The petitioner s are requesting this exemption for the purposes of "aerial photography, cinematography,

video photo graphy , mapping, crop surveying, inspections and other flight operations". The reason for such a general and broad based request i s that the petitioner s wish to utilize a business strategy of horizontal integration and maximize economies of scope in order to capitalize on opportunities as they may arise in the future without the long turnaround time associated with additional exempti ons. The petitioner's

business model is based on the idea of offering ad hoc small UAS services to individuals or companies who wish to employ these services as a safe, effective, and legal option to enhance their business or hobby. The petitioner's own market research shows pent up demand for these services current ly exists in the real estate market and other markets are just beginning to emerge. Although video photo graphy and photography are included in the request, the primary objective will be aerial survey of farm crops for precision agriculture. The petitioner s ha ve identified universities and other agencies that could benefit from the operation requested in this application.

Internet research shows that many are currently operating similar UAS in exactly this fashion without, it is assumed, FAA authorization. The petitioner s have refrained from engaging in commercial use of the UAS. The primary purpose of seeking this exemption is to obtain the capability to offer those services while remaining in compliance.

Respectfully Submitted

Deborah Winkelman

Thom as Christopher CoylePage 10 of 10