Petition forexemption section 333 To: U.S. Department ofTransportation Docket Operations West Building Ground Floor, Room W12-140 1200 NewJersey Avenue, SE Washington, DC 20590 From: Telesens, LLC 900 North Stuart Street Apt 804 Arlington, VA 22203. Phone: 301-219-0661 Email: ankur@umiacs.umd.edu Comment Tracking Number: 1jz-8101-73rb Date: Sep 7 2015 Re: Exemption Request Section 333 ofthe FAA Reform Act and Part 11 ofthe Federal Aviation Regulations from Title 14, Code of Federal Regulations 14 C.F.R. Part 21; 14C.F.R. 45.23 (b); 14 C.F.R. 61.113(a) and (b); 14 C.F.R. 91.7; 14 C.F.R. 91.9; 14 C.F.R. 91.119 (c); 14 C.F.R. 91.121; 14 C.F.R. 91.151(a); 14 C.F.R. 91.405 (a); 91.407 (a) (1); 91.409 (a) (1) 

### & (2); 91.417(a) 

### & (b) 

### !=IETITION FOR EXEMPTION Dear Sir or Madam: Pursuant to Section 333 ofthe FAA. Modernization and Reform Act of2012 (the Reform Act) and 14 C.F.R. Part 11, Telesens, LLC, operator ofSmall Unmanned Aircraft Systems ("sUASs") (referred to as the "Petitioner" or "Applicant") hereby applies for an exemption from the listed Federal Aviation Regulations ("FARs"} to allow commercial operation ofits sUASs, so long as such operations are conducted within and underthe conditions outlined herein oras may be established by the FAA as required by Section 333.1 As described more fully below, the requested exemption would permitthe operation ofsUAS under controlled conditions in airspace that is 1) limited 2) predetermined and 3) controlled. The proposed exemption, ifgi·anted, would allowTelesens, LLC to conduct commercial operations ofsUASs meeting or exceeding all ofthe operational and safety requirements that Congress has set forth in Section 333. Page 2. Telesens LLC asks that ifany part ofthis request is deemed not in compliance, that part be removed and process the remainder ofthis request as applicable.
Table ofContents

### 1. Introduction toTelesens, LLC 2. Operations of**lnteres~** 

### 3. Regulations from which Exemption is Requested 4. AircraftTypes 5. UAS Information 6. Operation and Safety Standards 7. Public**lnte~est** 

### 8. Exemption Request Details 9. Request forwaiverfor publication and comment procedures 10. Federal Register Summary Telesens, 

### LLC Address: 900 North Stuart Street, Apt 804 Arlington, VA 22203. EIN: 47-4983461 Telesens, LLC is atechnology company owned and run by AnkurAnkur. Mr. Ankur holds a Masters in Electrical Engineering from tile University of Maryland and a M.B.A from Georgetown University. Mr. Ankur is intimatelyfamiliarv:ith the details offlight control and command and control systems used in UAS and has given numeroustalks about building and safely operating UAS in the greaterWashington, DC area. A linkto Mr. Ankur's recent talk about operating the Iris+ quadcopterfrom 3D Robotics is as follows: http://www.meetup.com/DC-Area-Drone-User-Group/events/224717878/ Mr. Ankur has extensive experience operating sUAS manufactured by 3D Robotics and 

### OJ! and has flown numerous flights in both manual and autonomous mode without incident and always respecting applicable FAA regulations. Operations ofInterest Telesens, LLC plans to exploitthe capabilities of UASs to**~iter** 

### a multitude ofservices, including: Aerial Surveying and 3D m2pping Event Photography/Videography Crop Inspections Real Estate Photograpby Construction site ll

..:;pections and Surveys Research and Development and Education Regulations from

### which Exemption is Requested Statutory Authority Section 333, t'tled "Special Rules for**~ertain** 

### Unmanned Aircraft Systems", provides a mechanism for seeking expedited FAA**authorizc:~i'J:1** 

### ofsafe civil UAS ooerations in the NAS. Section 333(3) states thatthe FAA "shall determine ifcertain unmanned aircraft systems may operate safely in the national airspace syste11 before ':omp!etion ofthe (comprehensive) plan and rulemaking required by section 332(b)(1) ofthis Act orthe guidance required by section 334 ofthis Act." In Section 332(b)(1),

# ..

Congress made itclearthat Section 333 provides a mechanism for "expedited operation authorization" ifseveral factors are met. Petitioner meets all requirementsto permit FAA approval ofcommercial UAS operations. The petitioner requests relieffrom thefollowing regulations: 14C.F.R. Part 21 14C.F.R. 45.23 (b) 14C.F.R. 61.113(a) and (b) 14C.F.R. 91.7 14 C.F.R. 91.9 14C.F.R. 91.119 (c) 14 C.F.R. 91.121 14C.F.R. 91.151(a) 14 C.F.R. 91.405 (a); 91.407 (a) (1); 91.409 (a) (1) 

### & (2); 91.417(a) 

### & (b)



### AircraftTypes Exemption is requested forthefollowing aircrafts: DJI Phantom 3 DJI Inspire 1 3DR Iris+ 3DR Solo



### UAS Information Salient Features ofthese aircraft:s are presented in thetable below: DJI Phantom 3 DJI Inspire 1 3DR Iris+ (Pro) Weight 1280g 2945g 1282g Max Payload Max Speed 16 m/s 22 m/s 20m/s Max Climb 5m/s 5m/s 5m/s Rate
GPS Failsafe? Yes Yes Yes GeoFence Yes Yes Yes (max altitude, radius from home)? Battery Life "'20 min "'15min "'20 min (with Payload)



### UserManuals: Phantom 3: 3DRSolo 1800g
24m/s 10m/s (stabilize mode) Yes Yes

"'20 min

### • Priorto each flight, the pilot shall conduct pre-flight checks including but not limited to: ensuring the batteryfo;- the UAS and the remote control is fully charged, there is no visible damage tothe airframe and propellersthat might impede safe flight oralter expected flight characteristic, a sufficiently strong GPS lock is available, all sensors on board required for a safe flight such as accelerometers, gyroscopes, barometer, compass/magnetometer are properly calibrated. The pilotwill also**ensur~** 

### thatthe "home position" (point oforigination) is set properly and the vehicle is able to scfely return to home in case a return to home is triggered. • Flights will be terminated at no less than 

### 30% battery power reserve should that occur priorto the 

### 20 minute limit. • Flights will be operated atan altitude below 

### 300feet AGL, and not more than 

### 150feet above an elevated platform from which filming is planned. • Minimum crew for each operation will consist ofthe sUAS Pilot and the Visual Observer. • A sUAS pilotwill be**Pi~ot** 

### in Command {PIC) • A briefing will be r:onducted for planned sUAS operations priorto each day'sflight. All personnel performi;1g dutieswithin the boundaries ofthe safety perimeter are required to attend. • The operatorwill obtain consent ofall persons involved in the filming and ensure that only consenting persons will be allowed within 

### 500feet ofthe flight operation. • The Pilot and observer must be trained in sUAS operations and have received current information on the particular sUAS to be operated • The Observer and pilotwill be able to communicate atall times • Written and/ororal permission from the relevant property holders will be obtained priorto flight operc.tions. • Ifthe sUAS loses :ommunicationsor loses its GPS signal, the sUAS 

### will have the capabilityto return to the point oflaunch using the RTL safety future ofthe flight contrcller • Detailed logs co1tain position and altitude information and IMU measurements will be maintained by the UAS operator. 

### Publicinterest Use ofthe sUAS in lieu ofa manned aircraft would enhance safety and reduce the environmental impact as compared to similar operations conducted with manned aircraft ofgreater proportions, carrying a crew and flamn-;zble fuel. Additionally, use ofthe sUAS in orderto facilitate commerce could lead to economic growth. Operations for this petition will enable service for property owners ortheir designees seeking an enhanced perspective for characteristics, amenities, and benefits oftheir desired photographic subjects tha-:: cannot be displayed through ground level videography/photography. Aerial photography is avaluable marketingtool that can lead to increased commerce and enhance personal photography. Crop surveying applications could !ead to decreased use of pesticides and fertilizer and conservation ofwater as we!: as increased crop yields 2nd decreased cos·cs. Aerial surveying and inspections can increase work site efficiency, improvevolumetric estimations and reduce risks. Liability insurance will be obtained commensurate with tt:e granting ofthis request for exemption. Detailed logs contain position and altitude information and IMU measurements will be maint2ined by the UAS operator and provided to relevant governmentagencies upon request.

### http:ljdownload.djiinnovations.com/downloads/phantom 3/en/Phantom 3 Professional User Manual v1.4 en.pdf Inspire 1: http:ljdownload.dii-innovations.com/downloads/inspire 1/en/lnspire 1 User Manual v1.4 en.pdf 3DR Iris+ http:lj3drobotics.com/wp-content/uploads/2015/02/IRIS-Pius-Operation-Manual-vH-web.pdf 3DR Solo http:lj3drobotics.com/wp-content/uploads/2015/08/v5 08 21 15.pdf All UASs referred to in this j.Jetition feature an integrated microprocessor and IMU sensors running heavily tested flight control systems that continuously maintain aircraft stability and geospatial position and orier.tat!on. The**sen~ors** 

### include**g~·roscopes,** 

### accelerometers, GPS unit, barometers and compass. The DJI Phantom 3 and Inspire 1 also feature integrated optical flow sensor er.abling the UAS to hover by observing patterns on the grou;1d. The flight control boards contain multiple sensor units to provide redundancy. The UASs are primarily contrclled by FCC certified radio control (RC) unit. Real time video and telemetry information is transmitted back to the ground control station allowing the PIC to monitor battery level, GPS signal strength, altitude, distance from PIC, camera imagery and camera angle. 

### RiskMitigation The petitioner's small UAS has failsafe modes ofoperation for either loss**o·~** 

### radio control, GPS signal, or low battery level. Altitude can be limited by the onboard flight controller and maximum altitude can be programmed by the PIC. Battery !ife limitsflighttimesto approximately 25 minutes. The onboard flight controllerwill warn the jJilotvia telemetryand external lighting cues before reaching a low battery state. An automaticterminajon offlight and landingwill be initiated when the battery reaches a predetermined state. It is anticipated thatflights will usually last less than 10 minutes. More information is available on: Pages 12-14 ofthe attached Phantom 3 Professional User Manualversion 1.4 Page 13-16 ofthe attached Inspire 1 User Manualversion 1.4 Page 7 ofthe attached Iris+ User Manual Section 6.2 ofthe attachea Solo User Manual 

### OperationandSafetyStandards

• The sUASs will weigh less than lG pounds 

### • Flights will be operated within line ofsight ofa pilot and/orobserver. • Maximum flighttimeforeach operational flightwill be no more than 20 minutes

### ExemptionRequestDetails

14CFR Part 21, Airworthiness Certificates This part establishes the procedures for tt.e issuance ofan airworthiness certificate. While the FAA continuesto workto develop airworthiness standards for Unmanned Aerial Systems, we request an experimental certificate be issued for the sUASs considered herein under either or both ofthe following provisions: 21.191 Experimental certificates. Experimental certificates are issued forthe following purposes: (a) Research and development.Testing new aircraftdesign concepts, new aircraft**equipmen~,** 

### new aircraft installations, newaircraft operating techniques, or new uses for aircraft. (b) Showing compliance with regulations. Conductingflight tests and otheroperations to show compliance with the airworthiness regulations including flights to show compliance for issuance oftype and supplemental type certificates, flights to substantiate major design changes, and flights to show compliance with the function and reliability requirements ofthe 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 permitour commercial purpose as well. The aircraft will not carry persons or property, will not carry fuel, and will only fly understrict operational requirements. Combined with the UAS's lightweight, being constructed primarily ofcarbon fiber and plastic, we propose thatthe UAS will be at least as safe, if not safer, than aconventional!y certificated aircraft performing the same mission. Ifan experimental airworthiness certificate is ;1ot appropriate forthis application, then we request an exemption of 14 CFR Part 21, Subpart H, and the "equirementfor airworthiness certificate in general, citing the equivalent level ofsafety outllned in**~he** 

### previous paragraph. Please note that Exemption# 11224granted to NextEra Energy, Inc. determined thatthe DJI Phantom 2 Vision +, DJI Inspire, and DJ! S900 were previously determined in other exemptions to not be required to have an airworthir.ess certificate based upon the authority ofSection 333 ofthe FAA Modernization and Reform Act of2012. Other exemptions have also determined thatthe Phantom 2 platform does not need an airworthiness certificate. See Exemption# 11220for Aerial Production Services, Inc. The Phantom 3 piatform is simil2rtothe Phantom 2 and should not need an airwor.hiness certificate. We argue thatthe 3DR Iris+ and :>olo have also beei1 extensively flight tested and used safely by hundreds of thousands fliers and should be suitable exempted from airworthiness certificate.
14CFR 45.23 Display of marks These regulati'Jns provide that ec::ch aircraft must display "N" and the aircraft's registration number in letters at least 3 inches high. Additionaily, the aircraft must display the word "EXPERIMENTAL" in letters at least 2 inches high nearthe entrance to the cab;n, cockpit, or pilot station. The sUAV does not have an entrance in which -.:he word "EXPERIMENTAL" can be placed, and may not have a registration numberassigned to it by the FAA. We propose to achieve an equivalent level ofsafety by including the word "EXPERIMENTAL" in a placard on the top ofthe aircraft, where the PIC (Pilot In Control), YO (Visual Observer) and others in the vicinity ofthe aircraftwhile it is preparing for launch will be able to see the designation. 

### 14 C.F.R. § 

### 61.113(a) and (b): Private Pilot Privileges and Limitations
Pilot in Command Sections 

### 61.113 (a) and (b) limit private pilots tc non-commercial operations. Because the sUAS will not carry a pilot 1r passengers, the proposed operations can achieve the equivalent level ofsafety ofcurrent operatior.s by requiring the PIC operating the aircraftto have a private pilot's license ratherthan a commercial pilot's license to operate a sUAS. Unlike a conventional manned aircraft, a sUAS is remotely controlled by a ground-based operator. The operational area is controlled and restricted, and all flights are planned and coordinated in advance. The level ofsafety exceeds that provided by a single individual holding a commercial pilot's certificate operating aconventional aircraft. The risks associated with the use ofa sUAS are so diminished from the level of risk associated with commercial operations contemplated by Part 

### 61 allowing sUAS use by a sport pilot as the PIC exceeds the present level ofsafety sought by 

### 14 C.F.R. 

### §61.113 (a) and (b). 

### 14 CFR 91.7: Prohibits the Operation ofan aircraft without an airworthiness certificate
As no such certificate will be applicable in the form contemplated by the FARs, this Regulation is inapplicable. 

### 14 CFR 91.9: Civil aircraft flight manual, marking, and placard requirements
This regulation providesthat no person may operate an aircraft unless a current, approved flight manual is in the aircraft. We assume**~hat** the intent ofthis requirement is to ensure thatflight manual information is available to the aircrew while operatingthe aircraft. We reques+. an exemption to this requirement since the air.:raft is not onlytoo small to carry documentation, the documentation would not be available to the crew duringflight operations. To obtain an equivalent level ofsafety and meet the intentof

### 91.9, we propose that a current, approved sUAS Flight Manual must be available tothe crew atthe ground station anytime the aircraft is in, or preparing for, flight. 

### 14 C.F.R. 91.119(c): Minimum Safe Altitudes Section 

### 91.119 establishes safe altitudesfor operation ofcivil aircraft. Section 

### 91.119 provides, in pertinent part, that: "except when necessary fortakeoffor landing, no person may operate an aircraft belowthe following altitudes:

..... (c) Over otherthan congested areas. An altitude of

### 500feet above the surface, except over open water orsparsely populated areas. In those cases, the aircraft may not be operated closer t:1an 

### 500 feet to any person, vessel, vehicle, orstructure." Telesens, LLC requests authorityto operate at altitudes no higherthan 

### 30JAGL, and not morethan 

### 150above an elevated platform from which fiiming is planned, an exemption is needed to allow such operations. The sUASs will be operated in a restricted area within a security !Jerimeter, where buildings and people will not be exposed to operatio11s withouttheir pre-obtained consent. The equivalent level ofsafety will beachieved given the size, weight, and speed ofthe sUAS as well as the location where it is operated. No flight will be taken withoutthe permission of property owners or local officials. Because ofthe advance noticeto the property owners and participants involved in the sUAS operation, all affected individuals will be informed ofthe planned flight operations. Comparee toflight operations for conventional aircraft, any risk associated with the proposed sUAS operations is far less than conventional aircraft operating at or below 500 AGL. In addition, the low-altitude operations and light weight ofthe sUASs will ensure separation between the sUA$ c:md conventional aircraft.
14C.F.R. §91.121: Altimeter Settings Section 91.121 requires each person operating an aircraftto maintain cruising altitude by reference to an altimeterthat is set "

...to the elevation ofthe departure airport or an appropriate altimeter setting available before departure." As a sUAS may not have a barometric altimeter, but instead a GPS altitude data, an exemption is needed. An equivalent level ofsafety will be achieved by the operator, pursuant tothe operating manuals
14C.F.R. §91.151(a): Fuel Requirementsfor Flight inVFR (Visual Flight Rules) Conditions Section 91.151(a) prohibits an individual from beginning "a flight in an airplane underVFR conditions unless (considering wind and forecast weather conditions) there is enough fuel to flyto thefirst point of intended landing,**::~nd,** assuming normal cruising speed- (1) During the day, to fly afterthatforat least 30 minutes

...."The typical battery poweringthe sUASs provides less than 20 minutes of powered flight. To meetthe 30-minute reserve requirement in 14 CFR §91.151, sUAS flight would not be possible. Given the limitations on the sUASs proposed flight area and its proposed operations within a predetermined location, a shorter**t~me** frame forflight !n daylightVFR conditions is reasonable. Furthermore, operatingthe: sUASs in atightly controlled area where only people, property owners, or official representatives who have signed waivers will be allowed, less than 30 minutes of reserve fuel does not engender the type of risk that §91.151(a) was intended to address. Petitioner believes that safety can be achieved by limitingflightsto 15 minutes or 30% of battery power, whicheveroccurs first. This restriction would be more than adEquate to return the sUAS to the point of launch from anywhere in its limited operating area. Information provided 

### i11 the 0perating**d:J~uments** discusses procedures regarding remaining battery power manc:gement. Those documents contain a condition in which the PIC will initiate a landing procedure when battery remaining reaches a specified levei. Beyond that, the petitioner's small UAS initiates a "Go Home" {to the flight's origination point) when battery level dropstothe "Low Battery" level. Telesens will ensure that aircraft remains within reach ofthe origination point in case a "Go Home" needsto be initiated. Similar UAS-specific relief has been granted in Exemption Nos. 8811, 1 0808, and**~0673** for daytime, VFR conditions. 14C.F.R. §91.405 (a); 91.407 (a) (1); 91.409 (a) (1) 

### & (2); 91.417(a) 

### & (b):**Mai~tenance** Inspections and Records:

### These regulations require that an aircraft operator orownershall"have that aircraft inspected as prescribed in subpart Eofthis part and shall between required inspections, except as provided in paragraph (c) ofthis section, have discrepancies repaired as prescribed in part43 ofthis chapter

...," and others shall inspect or mainta:n the aircraft in compliance with Part 43. Given thatthese sections and Part 43 apply onlyto aircraftwith an airworthiness certificate, these sections will not applyTelesens's operations. An equivalent level ofsafetv wm be achieved because these small UAS's are very limited in size and will carry a small paybad and operate only in restricted areas for limited periods oftime.The operatorwill also maintain logs ofeach flight undertaken 

### by the UASs. These logs will contain detailed telemetry data about aircraft altitude and position, IMi.J measurements, RC inputs, flight controller output and other information necessary to fully reconstruct the flight path and characteristics should it become necessary. The operatorwill provide these logs to the FAA, NTSB orany other interested government agency if requested to do so.

### REQUEST FORWAIVER FOR PUBLICATION AND COMMENT PROCEDURES

TELESENS, LLC REQUESTS THAT THE PUBLICATION AND COMMENT PROCEDURES BE WAIVED IN ACCORDANCE WITH 14 C.F.R. 

### § 11.87. 

### § 11.87 Are there circumstances in which FAA may decide notto publish a summary of my petition for exemption? The FAA may not publish a summary ofyour petiticn 

### ·(orexemption and request comments ifyou present orwe find good cC!use why we shoJid not delay action on your petition. The factors we consider in deciding notto request comment include: (a) Whethergrantingyour petition would set a precedent. (b) Whetherthe relief requested i::- identical to exemptions granted previously (c) Whether our delaying action on your petition would affectyou adversely (d) Whetheryou filed your petition in a timely manner Corresponding tott.e above sub-sections,**Tele~ens,** LLC has good cause to request the FAA to waive the comment period and not delay action on the petition because: (a) Telesens, LLC would not set any precedtnt. Telesens, LLC agrees to the same limitations as many similar exemptions already granted, forexample, Exemption# 11284. Furthermore, all ofthe aircraft requested in this application have already been evaluated under previous petitions and are deemed to have the equivalent level ofsafety ifoperated underthe restrictions hereto already Clgreed upon. (c) Delaying the granting ofthis petition would adversely affectthe public, the FAA, and Telesens, LLC. The public, as well as the 'rAA, would be better served by the FAA quickly grantingthis petition and therebyfreeir.g up !imited FAA resour:es ar.d allowing FAA inspectors**~c** dedicate theirtime and attention to much higher priorities. Moreover, Telesens, LLC is adversely affected by the below listed regulations. (d) The petition has been filed in a timely manner.

### FEDERAL REGISTER SUMMARY Pursuantto 14C.F.R. Part 11, thefollowing summary is provided for publication in the Federal Register, should it be determined that publication is needed. Applicant seeks an exemptionfrom thefollowing rules: 14C.F.R. Part 21, 14C.F.R. 45.23 (b), 14 C.F.R. 61.113(a) and (b), 14 C.F.R. 91.7, 14C.F.R. 91.9, 14 C.F.R. 91.119 (c), C.F.R. 91.121, 14C.F.R. 91.151(a), 14C.F.R. 91.405 (a); 91.407 (a) {1); 91.409 (a) (1) 

### & (2); 91.417(a) 

### & (b) to operate c'Jmmercially a small unmanned vehicle (55 lbs. or less) forAerial Surveying, Event Photography/Videography, Crop lr.spections, Real Estate Photography, Construction site Inspections and Surveys, Education and Research and Development. This exemption will allow commercial operations ofUA's which will enhance safety by reducing risk. The alternativeto using a UA is to use ajetor piston powerah·craft carrying large amounts ofjetor otherfuel. Notonly is the operation dangerous atthe location,the aircraft mustflyto the location and back t.J the home airport. Our UA will weigh less than 55 ibs. and powered by batteries which eliminates mostofthe risk because no highlyflammable fuel will be involved. The UA will carry no passengers or crew; thus, eliminating most ofthe risk to the pilota'1d personnel. The operations ofthe UA listed underthe restrictions proposed herein will provide an equivalent level ofsafety as the Federal Aviation Regulations. If Ican be ofany assistance to further expedite this petition, please do not hesitate to contact me at (301)219-0661 orat myemail ankur@umiacs.umd.com.

Telesens, LLC 900 North StuartStreet Apt 804 Arlington VA 22203

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