June 29, 2015

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

Re: Exemption Request Section 333 of the FAA Reform Act

Dear Sir/Madam,

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the Reform Act), and 14 C.F.R. Part 11, Wolfe LLC, dba Drone Brothers (hereinafter Drone Brothers) seeks an exemption to operate as a planned aerial video company operating a Small Unmanned Aircraft System (sUAS) equipped to conduct aerial photography and survey for various industries, hereby applies for an exemption from the Federal Aviation Regulations (FARs) listed below to allow operation of our sUAS commercially in airspace regulated by the Federal Aviation Administration (FAA) so long as such operations are conducted with and under the conditions outlined herein or as may be established by the FAA as required by Section 333. The requested exemption would permit Drone Brothers to pursue its commercial interests in providing services to consumers interested in aerial data capture using a small advanced sUAV in the following areas:

• Construction sites before and after

• Events public and private

• Real Estate Marketing

Drone Brothers states that all sUAS flights that will occur over private or controlled access property, will be done with the property owner's prior consent and knowledge and that only people who have consented or otherwise have agreed to be in the area where filming will take place will

1be filmed . Additionally, the pilot in command (PIC) is a certified instrument-rated single engine land pilot with more than 750 hours of flight time and holds a valid U.S. driver’s license issued by the State of Michigan.

Drone Brothers respectfully submits the following petition for exemption from the listed Federal Aviation Regulations described in detail below as to allow for safe commercial operation of its sUAS. Drone Brothers plans to use the small, safe, and commonly used DJI Phantom 2 and the DJI Inspire 1 for the purpose of producing videography and photography in order to market real estate, commercial property and other scheduled functions. The lightweight aircraft covered by the exemption are far safer than conventional operations conducted by manned helicopters and fixed-wing aircraft weighing thousands of pounds, containing highly flammable fuel, and operating in close proximity to the ground and people. In the event that a grant is provided by the FAA, Drone Brothers is fully committed to abiding by the conditions and limitations expressed in recent grants made for similar requests.

Sincerely,

Andrew Wolfe 2471 Turner West Bloomfield, MI 48323

2I. Petitioner’s Contact Information :

Wolfe LLC, dba Drone Brothers Andrew Wolfe 2471 Turner West Bloomfield, MI 48323 Email: dronebros1@gmail.com

II. Petitioner seeks an exemption from the following rules:

14 CFR Part 21 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 14CFR91.119 14 CFR 91.121 14 CFR 91.151 (a) 14 CFR 91.203 (a) & (b) 14 CFR 91.405 (a) 14 CFR 407 (a) (1) 14 CFR 409 (a) (2) 14 CFR 417 (a)& (b)

III. Drone Brother’s Operations

A. The sUASs

The requested exemption will permit the operation of the DJI Phantom 2 and the DIJ Inspire 1. Both sUAS are small, unmanned multi rotor aircraft, weighing less than 10 pounds, inclusive of the batteries, the propeller guard, and technical payload. These rotocrafts can operate at a speed up to 29 knots, but Drone Brothers will limit the speed to no more than 20 knots. The FAA has previously granted exemptions allowing commercial flight of the DJI Phantom 2 (Exemption No. 11396) and DJI Inspire 1 (Exemption 11897).

3The sUASs will have the following specifications:

Airframe: DJI Phantom 2 Flight Control System: Naza – M V2, which includes the main controller (MC), internal measurement unit (IMU) with built-in internal sensor, barometric altimeter, which measures attitude and altitude, compass, GPS, and radio receiver (Rx). Transmitter (Tx): Futaba T14SG Receiver (Rx): Internal to DJI Phantom 2 Data Link: 2.4G Data Link Video Link: DJI AVL 58 Gimbal: H3-3D Zenmuse Gimbal for GoPro Hero Camera: Go Pro Hero 4 Black Batteries: 3S LiPo, 5200-mAh, 11.1V iOSD: DJI iOSD mini, which allows live telemetry to be displayed on the video monitor, including the battery level, and altitude.

Airframe: DJI Inspire 1 Flight Control System: The flight control system built into the Inspire 1 makes flying as easy and intuitive as possible. All components intelligently communicate with each other, giving you smooth, stable flight starting from the first time you takeoff. Transmitter (Tx): DJI Transmitter Receiver (Rx): Internal to DJI Inspire 1 Data Link: 2.4G Data Link Video Link: DJI AVL 58 Gimbal: ZenMuse X3 Camera: X3- FC350 Batteries: TB47, 4500-mAh, 22.2V Mobile Device System Requirments: iOS 8.0 or later , which allows live telemetry to be displayed on the video monitor, including the battery level, and altitude.

4B. Flight Conditions

The sUAS will be flown in airspace under 400 feet above ground level (“AGL”) and under controlled conditions in rural areas. The majority of flights will take place under 100 feet AGL. Drone Brothers’ operations will occur in suburban areas. Drone Brothers will avoid congested and densely populated areas. Drone Brothers will only operate its sUASs in VMC, visual meteorological conditions: no less than 500 feet below and no less than 2,000 feet horizontally from a cloud or when visibility at least 3 statute miles from the PIC. The flight crew will always make a safety assessment of the risk of every operation, and will only operate when it is determined that no undue hazards are present.

C. Flight Operations

Drone Brother ’s flight operations require that the sUAS will always be in the line of sight of both a PIC and a monitor specialist, who will also act as the visual observer (VO). Flights will be at altitudes of no more than 400 feet AGL, and at speeds less than 20 knots. Despite the 400 ft. AGL limit, most flights will take place at an altitude of no more than 100 ft. AGL.

The PIC has a private pilot single engine land license with an IFR rating, with 750 hours of flight time, and a Michigan Driver’s license. The VO has over several years of experience with RC aircraft, and has over 200 hours flying sUASs as a hobbyist. If an additional PIC is utilized by Drone Brothers, he/she will receive appropriate training and certification.

The sUASs will only fly over land which it has permission from the landowner or landowner’s agent to fly above. The flight crew will also conduct a safety briefing with the property owners.

Flights will take place on parcels of land that are at least approximately an area of half an acre to a full acre. Operations will not take place in congested or densely populated areas. The flight crew will obtain all aeronautical and weather data information.

5Prior to departing for an operation, the flight crew will briefly turn on the sUASs to ensure that everything is connected and that the sUASs are in operational condition.

Upon arrival at a location for filming or photography, the flight crew will conduct an aerial and ground preflight inspection. The flight crew will also conduct a physical inspection of the aircraft. The flight crew will then power on the sUASs and set up a iPhone or tablet connected to the sUAS. This displays the telemetry information during the flight, and be monitored by the VO. The VO will be able to see the images taken by the camera in real time.

The PIC will then conduct a pre-flight inspection.

At any time during the flight, should the aircraft lose connection with the remote control, the flight control system failsafe will be activated automatically, and the aircraft will return to the previously-set home area and land, in order to reduce injuries or damage. If any of the following situations occur, the aircraft will not receive a signal, and enter into this failsafe mode:



### • The remote control is powered off;



### • The aircraft has flown out of the effective communication range of the remote control, which is no greater than 1,000 meters (3,280 feet);



### • There is an obstacle obstructing the signal between the remote control and the aircraft, essentially reducing the distance the signal can travel; or



### • There is interference causing a signal problem with the remote control.

Both of the sUASs have “no fly zones” programmed into it, which will prevent flights in restricted zones. Although Drone Brothers will take every precaution to avoid flying in airspace other than class G airspace, the preprogrammed “no fly zones” will add an additional level of safety to operations.

Other than this automated feature, the PIC will always fly the sUAS manually. The PIC and VO have tested the sUAS in a variety of weather

6conditions, including on overcast days and in winds up to 15 knots. The PIC and VO will not fly the sUAS in heavy rainstorms, due to decreased visibility and the potential for water damage to the sUAS. The PIC and VO have also practiced emergency bailout procedures by having the sUAS return to home. In the event of an emergency, the PIC will release the joysticks. This will make the sUAS automatically hover in place and maintain its position and altitude, and the PIC and VO can determine if and when it is safe for the sUAS to return to the home location.

During flights, the PIC and the VO will be standing next to each other, in oral communication at all times at the ground station. The VO will observe the telemetry data on the iPhone or tablet and will monitor the images from the camera from the laptop. The VO will direct the PIC if he wishes to capture a different angle on the camera.

Flights will be limited to 18 minutes, which is 75% of the total battery life. Once the sUAS has landed, the PIC will conduct a post-flight checklist.

IV. Privacy

There is little concern that the proposed flights will cause invasions of privacy because all flights will occur with the property owner’s prior knowledge and consent. The only people and/or property to be filmed will have requested and hired Drone Brother’s for the express purpose of filming and photographing the people and/or property with the sUASs

. No attempt will be made to identify any individuals filmed or photographed during the flights who have not consented to be filmed or photographed, except in cases where they are trespassing upon or damaging customer property, or interfering with the applicant’s or its customers’ operations

.

7V. Aircraft and Equivalent Level of Safety

Drone Brother’s proposes that the exemption requested herein apply to civil aircraft that have the characteristics and that operate with the limitations listed herein. These limitations provide for at least an equivalent or higher level of safety to operations under the current regulatory
structure.

These limitations and conditions to which Drone Brothers agree to be bound when conducting commercial operations under an FAA issued exemption include:

1. The sUASs will weigh significantly less than fifty (50) lbs. The DJI Phantom 2 weighs 2.9 lbs., inclusive of battery and payload and the DJI Inspire 1 weighs 6.47 lbs

. 2. Flights will be operated within line of sight of a pilot and VO.

3. Maximum total flight time for each operational flight will be 75% of battery life. Flights will be terminated once the battery reaches a 25% level. This data will be available through telemetry data submitted to the transmitter and monitor.

4. The sUAS will remain clear and yield the right of way to all other manned operations and activities at all times.

5. Flights will be operated at an altitude of no more than 400 feet AGL. Despite this limitation, the majority of flights are anticipated to operate at no more than 100 feet AGL.

6. Minimum crew for each operation will consist of the sUAS PIC and VO.

7. A briefing will be conducted in regard to the planned sUAS operations prior to each day’s activities. It will be mandatory that all personnel who will be performing duties in connection with the operations be present for this briefing.

88. The PIC is a certified private pilot single engine land with 750 logged hours, and has a Michigan Driver’s license.

9. The PIC and VO have extensive practice operating the DJI Phantom 2 and the DJI Inspire 1 . Practice flights have been in a variety of weather conditions, including in winds up to 15 knots and on overcast days. Practice flights have also included using the emergency return-to- home features.

10 . The PIC and VO will at all times be able to communicate by voice and be stationed next to each other at the ground station.

11 . Written and/or oral permission from the landowner or authorized agent, of the land over which the sUAS will be flying.

12. The sUAS will have the capability to abort a flight in case of unexpected obstacles or emergencies. The PIC and VO have practiced the emergency failsafe procedures

13. If the multi-rotor and its controller disconnects during flight, the system’s failsafe protection will come to the rescue and the multi-rotor will return to home and land automatically, rather than flying off uncontrollably or landing at an unknown location.

Satisfaction of the criteria provided in Section 333 of the Reform Act of 2012--size, weight, speed, operating capabilities, proximity to airports and populated areas and operation within visual line of sight and national security – provide more than adequate justification for the grant of the requested exemptions allowing commercial operation of applicant’s sUASs pursuant to Drone Brothers’ rules of operation appended hereto.

9VI. Public Interest and Safety

Use of the sUAS will increase ground safety by eliminating the need to have a manned, aircraft take the videos or photographs. As the FAA recognized in the Douglas Trudeau, Realtor® Exemption, No. 11138:

“Manned aircraft conducting aerial filming and photography can weigh 5,000 lbs. or more, are operated by an onboard pilot and may carry other onboard crew members, as well as 100 gallons or more of fuel. The petitioner’s [sUAS] weighs less than 3 lbs. The pilot and crew will be remotely located from the aircraft. The limited weight reduces the potential for harm to persons or damage to property in the event of an incident or accident. The risk of an onboard pilot and crew during an incident or accident is eliminated with the use of a [sUAS] for the proposed operation.” Exhibit 10 at 11-12.

As in the cited exemption, Drone Brothers’ sUASs are within the recognized weight exemption. During Drone Brothers’ operations, the PIC and VO will similarly be safely on the ground, directing the sUASs at altitudes no higher than 400 feet AGL. Drone Brothers will not fly over congested or densely populated locations. The flight crew will make a safety assessment prior to each operation, and will only operate when there are no undue risks.

Manned aircraft pose a much greater threat to its occupants as well as to individuals on the ground. Additionally, a much greater space will be necessary for takeoff, landing, and operations than would be necessary for the sUASs that Drone Brothers requests an exemption to use

. VII. Regulations from Which Exemption is Requested

A. 14 C.F.R. 21(h): Airworthiness Certificates

Drone Brothers requests an exemption from 14 C.F.R. 21(h). This exemption meets the requirements for an equivalent level of safety pursuant to Section 333 based on the small size, light weight, relatively

10slow speed, and use in controlled environments on private land, as described previously in this petition. In Exemptions No. 11396 and No. 11897, the FAA stated that the Secretary of Transportation has determined that the DJI Phantom 2 and DJI Inspire 1 meet the statutory conditions of Section 333, considering the size, weight, speed, and limited operating area associated with the aircraft and its operation

. The specifications of the sUASs used by Drone Brothers are as follows:

DJI Phantom 2 :



### • has a diagonal length of 350 millimeters, 13.77 inches.



### • Light weight: 2.9 lbs.



### • Relatively slow speed: the PIC will limit the sUAS’s speed to 20 knots (23 miles per hour).



### • Operational capacity: currently, the DJI Phantom 2 can operate for 25 minutes.



### • Flights will be terminated when 25% of the battery life remains.



### • The DJI Phantom 2 can travel no more than 1,000 meters, 3280.84 feet, from the receiver.



### • Proximity to airports: Drone Brothers will only operate in Class G airspace.



### • Operation within visual line of sight: The PIC will always fly the sUAS within its line of sight.



### • Altitude: no more than 400 feet AGL, but the majority of flights are anticipated at no more than 100 feet AGL.

DJI Inspire 1:



### • has a diagonal length of 559 to 581 mm, 22 inches.



### • Light weight: 6.47 lbs.



### • Relatively slow speed: the PIC will limit the sUAS’s speed to 20 knots (23 miles per hour).



### • Operational capacity: currently, the DJI Inspire 1 can operate for 25 minutes.



### • Flights will be terminated when 25% of the battery life remains. The DJI Inspire 1 can travel no more than 2 Kilometers, 328 from the receiver.

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### • Proximity to airports: Drone Brothers will only operate in Class G airspace.



### • Operation within visual line of sight: The PIC will always fly the sUAS within its line of sight.



### • Altitude: no more than 400 feet AGL, but the majority of flights are anticipated at no more than 100 feet AGL.

B. 14 C.F.R. 43.7: Persons authorized to approve aircraft, airframes, aircraft engines, propellers, appliances, or component parts for return to service after maintenance, preventive maintenance, rebuilding, or alteration.

Drone Brothers requests an exemption from 14 C.F.R. 43.7. As described previously, Drone Brothers’ flight crew will be capable to repair and maintain the sUASs to meet an equivalent level of safety of this section. Drone Brothers will maintain and when necessary repair the sUASs. They will conduct inspections and maintenance based on maintenance guidelines provided by the manufacturer of the sUAS s.
C. 14 C.F.R. 43.11: Content, form, and disposition of records for inspections conducted under parts 91 and 125 and §§135.411(a)(1) and 135.419 of this chapter.

Drone Brothers requests an exemption from 14 C.F.R. 43.11. Drone Brothers will keep log books of all maintenance and repairs at the ground station

. D. 14 C.F.R. 45.11: Marking of products.

Drone Brothers requests an exemption from 14 C.F.R. 45.11. The PIC and VO will keep information related to the sUASs, including the user manual, at the ground control station and affix its N-Number, once obtained from the FAA Registration Office, on the “arms” of the sUASs as large as practicably possible. This exemption provides an equivalent level of safety to 14 C.F.R. 45.11 because the relevant documentation containing the serial number will be at the ground station with the PIC, where it will be useable in case of an emergency, rather than with the sUAS.

12E. 14 C.F.R. 45.27: Location of marks; nonfixed-wing aircraft

Drone Brothers requests an exemption from 14 C.F.R. 45.27. This part provides that 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 §45.23. Once Drone Brothers receives its N-Number, it will display these marks on the “arms” of the aircraft as large as practicably possible. This exemption provides an equivalent level of safety to 14 C.F.R. 45.27 because the sUAS will be registered with the FAA Aircraft Registration Branch. In the event of incident, the sUAS will be traceable to Drone Brothers.

F. 14 C.F.R. 45.29: Size of marks

Drone Brothers requests an exemption from 14 C.F.R. 45.27. Drone Brothers will affix its registration number as large as practicably possible on the “arms” of the sUASs once the N-Number is obtained. This exemption provides an equivalent level of safety to 14 C.F.R. 45.29 because the sUAS will be registered with the FAA Aircraft Registration Branch. In the event of incident, the sUAS will be traceable to Drone Brothers.

G . 14 C.F.R. 91.9(c): Civil aircraft flight manual, marking, and placard requirements

Drone Brothers requests an exemption from 14 C.F.R. 91.9(c). As stated above, Drone Brothers will place the N-number on the “arms” of the aircraft as large as practicably possible. An equivalent level of safety to 14 C.F.R. 91.9(c) is met because the sUAS will be registered with the FAA and identifiable in the event of an incident.

H . 14 C.F.R. 91.103(b)(2): Preflight action

Drone Brothers requests an exemption from 14 C.F.R. 91.103(b)(2) to the extent that is applicable. Drone Brothers’ PIC will, before beginning a flight, become familiar with all available information concerning that flight, including the aircraft performance under expected elevations, the gross weight of the aircraft, and the wind and temperature. As the flights of the

13sUASs will not be at airports the information required of Part 91.103(b)(2) does not apply.

I. 14 C.F.R. 91.105: Flight crewmembers at stations.

Drone Brothers requests an exemption from 14 C.F.R. 91.105 since this part is not applicable due to the sUASs carrying no flight crewmembers. Drone Brothers will not operate the aircrafts unless someone is at the controls at all times, and each flight will be manually flown, with the exception of the automated safety features. This will provide an equivalent level of safety to 14 C.F.R. 91.105 because the flight crew will be at their stations at all times during the flight. The stations will not be on the aircraft but on the ground.

J . 14 C.F.R. 91.113(b): Right-of-way rules: Except water operations

Drone Brothers requests an exemption from 14 C.F.R. 113(b) to the extent that it applies to overhead aircraft operating at or above 500 feet AGL as the sUASs will be operating no higher than 400 feet AGL. Should another aircraft enter the area in which Drone Brothers is operating, because the flight will be within his line of sight, the PIC will be able to give right of way to that aircraft. All flights will be in class G airspace and the majority of flights will be at no more than 100 feet AGL, which will create a very slim chance that Drone Brothers’ operations will interfere with a manned aircraft’s flight. This will provide an equivalent level of safety to 14 C.F.R. 91.113(b) because the sUASs have significantly greater mobility than a much larger, manned aircraft. As a result, the PIC will be able to react and respond much more quickly than the other pilot.

K. 14 C.F.R. 91.119(c): Minimum safe altitudes: General

Drone Brothers’ requests an exemption from 14 C.F.R. 91.119 subpart (c). Drone Brothers will not operate the sUASs any higher than 400 feet AGL and it is anticipated that the majority of operations will be no higher than 100 feet AGL. Drone Brothers will not operate in congested areas

.

L . 14 C.F.R. 91.121: Altimeter Settings

14Drone Brothers requests an exemption from 14 C.F.R. 91.121. The sUASs flight controllers will have an internal measurement unit (“IMU”). The IMU has a built-in internal sensor and a barometric altimeter that measures both attitude and altitude. Additionally, the sUASs will not be flying above 400 feet AGL in a sustained cruising flight mode such as a manned aircraft will typically fly. The PIC will at all times be controlling the maximum height of the sUAS through the telemetry features of the DJI controller. Additionally, the sUAS will be operated within the line of sight of the PIC.

M. 14 C.F.R. 91.151: Fuel requirements for flight in VFR conditions

The sUASs are powered by electricity, using lithium polymer batteries that currently have a flight limit of approximately no more than 25 minutes. Therefore, due to the limitations of the batteries, it is currently impossible to comply with Part 91.151. However, the sUASs will be operated in a manner with at least the equivalent level of safety as that of a manned aircraft complying with Part 91.151. During the entire flight, the PIC will always have a visual line of sight of the sUAS and the VO will be monitoring the battery life via the telemetry display at the ground station. The sUAS will always have enough power to land safely, given the minimum level of reserve capacity of the batteries. Drone Brothers also limits flights to 75% of battery capacity. As new batteries are obtained and put into use, Drone Brothers will continue to terminate flights after 75% of battery power has been used.

N. 14 C.F.R. 91.215: ATC Transponder and Altitude Reporting Equipment and Use

This section requires that installed Air Traffic Control (ATC) transponder equipment must meet specific performance and environmental requirements, and aircraft must be equipped with an operable coded radar beacon transponder. There are presently no known commercially available ATC transponders that meet the payload requirements of a sUAS and are available at reasonable cost. However, because the sUASs used by Drone Brothers will not be flying into or near airports, and will fly no higher than 400 feet AGL, there is very low risk of

15collision with any manned aircraft. In addition, because there will be no need to have contemporaneous communication with ATC Control, due to the short distances, short flight times, and restricted altitude the sUASs will operate within, Drone Brothers requests an exemption from this section.

O . 14 C.F.R. 91.403: General

This section requires that the owner or operator of an aircraft is primarily responsible for maintaining that aircraft in an airworthy condition. Drone Brothers will adhere to this requirement. Drone Brothers will maintain its sUASs in an airworthy condition and adhere to all manufacturer requirements for inspecting and maintaining the sUASs. Drone Brothers will keep records of maintenance to the sUASs, and these records will be available to the PIC and VO before, during, and after operations of the sUASs

. This Section also limits maintenance to that “prescribed in this subpart and other applicable regulations, including part 43 of this chapter.” Because of this limitation, and because of the exemptions under Part 43 requested above, Drone Brothers requests an exemption from this Section. This exemption meets the requirements for an equivalent level of safety pursuant to Section 333 based on the small size, light weight, relatively slow speed, and use in controlled environments on private, secured land, as described previously in this petition.

P . 14 C.F.R. 91.405 (a) and (d): Maintenance Required

This section requires that aircraft be inspected as prescribed by Section E, 14 C.F.R. §§91.401-91.421. Drone Brothers is applying for an exemption for these sections, due to the fact that its operators will inspect the sUASs prior to each flight and keep maintenance records of all parts that are replaced, in accordance with DJI’s instructions. Because the Sections referenced above are concerned with manned aircraft, and as such have inspection requirements designed for the safety of passengers, they are inapplicable to Drone Brothers

.

16Q . 14 C.F.R. 91.407: Operation after maintenance, preventive maintenance, rebuilding, or alteration

Drone Brothers respectfully requests an exemption from 91.407. The PIC, who holds a private pilot’s certificate, will conduct maintenance on the sUAS and keep logs of the battery cycle and repairs needed on the body or the propellers of the sUASs. Prior to conducting post- maintenance operations, Drone Brothers will conduct a test flight to ensure that the sUASs function properly.

R . 14 C.F.R. 91.409: Inspections

This section lays out specific requirements for inspections of aircraft. Drone Brothers respectfully requests an exemption from these requirements because they are intended to maintain the safety of manned aircraft significantly larger and capable of significantly longer flights than is sUAS. Drone Brothers ’ pre-flight and post-flight inspections meet or exceed the level of safety achieved by adherence to 14 C.F.R. 91.409.

S . 14 C.F.R. 91.417: Maintenance records

Drone Brothers respectfully requests an exemption from this Section, as it is only applicable for aircraft with an airworthiness certificate. Because Drone Brothers will not have an airworthiness certificate, this Section is inapplicable.

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