July 11, 2015

U. S. Department of Transportation

Docket Management System

1200 New Jersey Ave.,

SE Washington, DC 20590

RE: Petition of DET LLC for Exemption Pursuant to Section 333 of the FAA Reform Act

Petitioner’s Name and Address:

DET LLC

Owner: Jonathan M DeSisto

146 Elm St

Quincy MA 02169

617­784­6490

dolotransport@gmail.com

To whom it may concern:

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the Reform Act)

and 14 C.F.R. Part 11, DET LLC, operator of Small Unmanned Aircraft Systems

(“sUAVs”) equipped to conduct aerial photography, videography, and inspections of industrial

sites, hereby applies for an exemption from the listed Federal Aviation Regulations (“FARs”) to

allow commercial operation of its sUAVs. All operations will be conducted within and under the

conditions outlined herein or as may be established by the FAA as required by Section 333.1

As described below, the requested exemption would permit the operation of small,

unmanned sUAV under controlled conditions in airspace that is 1) limited 2) predetermined and

3) controlled. The proposed exemption, if granted, would allow DET LLC to conduct commercial

operations of sUAVs meeting or exceeding all of the operational and safety requirements

Congress has set forth in Section 333. DET LLC is a video photography and industrial

inspection company owned and operated by Jonathan M DeSisto. DET LLC is located in

Quincy Massachusetts just south of Boston.
Jonathan M DeSisto has over 23 years in Remote Controlled (“RC”) aircraft experience in both

fixed wing and rotary aircraft. This experience includes development, building, testing and flying

a variety of RC aircraft. In addition to that Jonathan M DeSisto has over 200 hours of fixed wing

flight time and has held a commercial pilot certificate, single engine land rating, with instrument

rating since May of 1997. Jonathan M DeSisto also holds a current class II FAA medical

certificate.

DET LLC plans to use the capabilities of sUAVs to offer a multitude of services,

including:

­ Event Photography/Videography

­ Real Estate Photography and presentation

­ Aerial filmmaking and photography

­ Construction site inspections and monitoring

­ Industrial site inspections and monitoring

Statutory Authority Section 333, titled “Special Rules for Certain Unmanned Aircraft Systems”,

provides a mechanism for seeking expedited FAA authorization of safe civil Unmanned Aircraft

Systems (UAS) operations in the National Airspace System (“NAS”). Section 333(a) states that

the FAA “shall determine if certain unmanned aircraft systems may operate safely in the

national airspace system before completion of the (comprehensive) plan and rulemaking

required by section 332(b)(1) of this Act or the guidance required by section 334 of this Act.” In

Section 332(b)(1), Congress made it clear that Section 333 provides a mechanism for

“expedited operation authorization” if several factors are met. Petitioner meets all requirements

to permit

FAA approval of commercial UAV operations

The name and address of the applicant are:

Name: DET LLC

Owner: Jonathan M. DeSisto

Address: 146 Elm St.

Quincy MA 02169

Phone: 617­784­6490

Email: dolotransport@gmail.com

DET LLC is requesting exemption from the following regulations:

14 C.F.R. Part 21

14 C.F.R. 45.23 (b)

14 C.F.R. 61.113(a) and (b)

14 C.F.R. 91.7 (a)
14 C.F.R. 91.9 (b)(2)

14 C.F.R. 91.109

14 C.F.R. 91.119

14 C.F.R. 91.121Page 3

14 C.F.R. 91.151(a)

14 C.F.R. 91.203 (a) & (b)

14 C.F.R. 91.205 (b)

14 C.F.R. 91.215

14 C.F.R. (91.401 ­ 91.417)

sUAVs are superior to other flight platforms for photography and inspections due to low cost of

equipment and personnel to operate equipment. In addition to cost savings there is little to no

impact on the environment due to Lipo Poly battery propulsion systems. Battery power offers

little to no noise disturbance to the public or gas/Co2 emissions. DET LLC requests a grant of

exemption without delay.

Petitioner is requesting an exemption to enable DET LLC to operate a DJI Inspire 1

sUAV that is upgraded to latest version firmware, equipped with a 3 axis Zenmuse camera

gimbal, which uses a High­Def video camera that can capture up to 4K (4096x2160p) video and

12M pixel photos. DJI is the leader in multicopter technology with integrated software to control

safety parameters of every flight. This sUAV has a built­in capability to limit 1) the height it flies

above the ground and 2) the radius of the distance it flies from the operator. The DJI Inspire 1 is

equipped with a failsafe “home” function of the autopilot system. In the event communication is

lost between the main remote controller and the sUAV, the system will automatically trigger a

return home sequence and land automatically. The DJI pilot application is the only flight

monitoring system in the industry that integrates navigation, system monitoring and camera

control on a single screen. It incorporates both visual and audio alarms for battery life that can

be customized for each flight, to ensure maximum safety. The DJI Inspire 1 platform also offers

real time monitoring of GPS satellites, remote control connection quality, video downlink, engine

performance, altitude, and flight telemetry.

Please refer to Attachments 1­5, the DJI Inspire 1 Instruction Manual, for the performance

limitations and flight operations. Aircraft weight is 2935 grams or 6.47 pounds with battery,

which is the total gross weight. A pre­flight inspection will be performed by the PIC in

accordance with the factory instruction manual, as well as redundant checks to include the

Internal Measurement Unit (IMU) to make sure that the compass, gyro and acceleration values

are within specs, positive GPS locks are secure, battery health in each individual LiPo cells are

balanced, and radio signals are locked in. The sUAV will be maintained in accordance with the

manufacturer’s instruction manual and only manufacturer's authorized replacement parts will be

used.
FCC Information

The DJI Inspire 1 transmitter used for controlling the sUAV complies with part 15 of the FCC

rules. Operation is subject to the following two conditions: (1) This device may not cause

harmful interference, and (2) this device must accept any interference received, including

interference that may cause undesired operation.

The DJI Inspire1 radio transmitter used for controlling the sUAV is wireless technology which

has been tested and found to be compliant with the applicable regulations governing a radio

transmitter in the 2.400GHz to 2.4835GHz frequency range.

Antenna Separation Distance:

When operating the DJI Inspire 1 transmitter, the PIC will maintain a separation distance of at

least 5 cm between his body (excluding fingers, hands, wrists, ankles and feet) and the antenna

to meet RF exposure safety requirements as determined by FCC regulations.

Pilot in Command and Observer Qualifications and Duties:

The PIC will maintain at least a Private Pilot Certificate and a current State issued drivers

license, plus at least 2 hours flying time and 3 takeoffs and landings within 30 days in the type

of sUAV utilized in operations.

The PIC will have at least 200 hours total time single engine land aircraft. The PIC will have at

least 75 hours flying Radio Controlled Model Aircraft, of which, 50 hours will be flying the DJI

Inspire 1 sUAV.

The PIC is responsible for the safe and efficient operation of the aircraft. Specific duties include

all preflight preparation and inspection, in flight operation, post flight requirements, and all

procedures including but not limited to:

Safe in flight operations

Risk evaluation

Current weather conditions for safe flight

The Observer must have the visual acuity to observe the sUAV and be able to communicate

clearly with the PIC.

The Observer’s duties:

Warning the PIC of any impending obstacles in the flight path of the sUAV.

Warning the PIC of any deviations in the planned flight path of the sUAV.

Warning the PIC should any unauthorized personnel appear in the area of the planned
flight.

The Observer will have the authority to order the PIC to terminate the flight should he feel the

flight cannot be conducted safely.

General Operating Standards

DET LLC will only operate its sUAV in line of sight of a pilot and/or observer and

will operate at sites. Operations will insure that the sUAV will "not create a hazard to users of

the national airspace system or the public."

Before operation of a sUAV within 5NM of an airport with a control tower, the control

tower will be called to gain permission to operate the sUAV. The PIC will give the position,

altitude and the times the sUAV will be operated. The sUAV will not be operated at an

altitude of over 400 feet AGL.

Before operation of a sUAV within 5NM of a non­tower controlled, airport operators

will be notified. PIC will give the right of way to avoid flying in the proximity of all

aircraft. At no time will the sUAV be operated within the final approach course and

the takeoff course of any runway. The sUAV will not be operated at an altitude of over

400 feet AGL.

Maximum flight time for each operational flight will be 18 minutes. Flights will be terminated at

30% battery power reserve should that occur prior to the 18 minute limit.

Minimum crew for each operation will consist of the sUAV Pilot, and Visual Observer.

The sUAV operated by the petitioner weighs less than 55 pounds, including the payload

(i.e. camera, lens, and gimbals).

The sUAV will operate at speeds of no more than 25 knots, can hover, and can

simultaneously move vertically and horizontally.

The small size of the sUAV and the restricted environment within which they

will operate, adhere to the Reform Act's safety requirements. The sUAV, powered by batteries,

is smaller, lighter and more maneuverable than larger aircraft running on combustible fuel. The

sUAV operates at lower altitudes reducing risk to altitude workers, enhance safety, and diminish

the likelihood of death or serious bodily injury.

Low level photos and video from several angles are far more effective than ground

based imagery for displaying the characteristics of large, complex properties. The benefits of

reduced cost and improved quality of presentation from the sUAV over manned aircraft will be

valuable to and benefit many buyers and sellers of real property, local city officials, and
industrial operations. Additionally, we request that we be allowed to use our system to benefit

first responders including firefighters, police, sheriff, etc., all while

remaining subject to all limitations cited below:

1. No flight will be made with a Gross weight exceeding 55 pounds;

2. 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 1000ft. from the PIC

3. All operations must utilize a visual observer (VO). The VO and PIC must be able to

communicate by voice at all times during a flight operation;

4. All required permits will be obtained from state and local government prior to operation;

5. DET LLC will not be operating at night.

EXEMPTION REQUESTS:

DET LLC requests an exemption from the following regulations:

14 CFR Part 21, Airworthiness Certificates

This part 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 DJI Inspire1 under either or both of the

following provisions:

21.191 Experimental certificates

Experimental certificates are issued for the following

purposes:

1. Research and development. Testing new aircraft design concepts, new aircraft equipment,

new aircraft installations, new aircraft operating techniques, or new uses for aircraft.

2. 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 purposes 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 sUAV's light weight, being constructed primarily of

carbon fiber and plastic, we propose that the sUAV will be at least as safe, if not safer, than a

conventionally certificated aircraft performing the same mission.
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 letters at least 2 inches high near the entrance to the cabin, cockpit, or

pilot station. The sUAV 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.

14 CFR 61.113 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 property for compensation or hire. Our proposed operations require that the PIC

must hold at least a Private Pilot Certificate with a Class III Medical issued by the FAA and 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 conduct a business.

14 CFR 91.7 Prohibits the Operation of an 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 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

sUAV Flight Manual must be available to the crew at the ground station anytime the aircraft is

in, or preparing for, flight, and ready for presentation for any governing official upon request.

14 CFR 91.109 Flight Instruction; Simulated instrument flight and certain flight tests

The regulation states that "No person may operate a civil aircraft that is being used for flight

instruction unless that aircraft has fully functioning dual controls. Although the DJI Inspire 1 is

capable of dual/linked controls, DET LLC will be operating with a single remote controller.
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 typical

mission of the sUAV would be photography or survey of persons, vessels, vehicles or structures

it would be necessary to operate closer than 500 feet to the items listed. Operations will only

be flown over property or persons where permission has been obtained and careful pre­planned

flight path has been performed. 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 UAS, the hazard to persons,

vehicles and structures is minimal compared to manned aircraft, which should be considered in

granting the exemption.

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 sUAV 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 sUAV flight monitoring software to the display screen held by the PIC,

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 airplane under day­VFR

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 sUAV is battery operated and the maximum

duration of flight from a single battery charge is 18 minutes with a 20% reserve. A full battery

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 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

cockpit entrance so that it is legible to passengers or crew." At a maximum gross weight of 6.47

pounds, the sUAV is too small to carry documentation, does not have an entrance, and is not

capable of carrying passengers or crew. To obtain an equivalent level of safety and meet the

intent of 91.203, we propose that documents deemed appropriate for this aircraft by the FAA

will be with the crew at the ground control station and available for inspection upon request. In
order to identify the 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.

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 aircraft be "approved for return to service by a person authorized under

43.7" after maintenance and inspection. It is our intention that the PIC perform maintenance

and inspection of the aircraft and "be authorized to approve the aircraft for return to service."

The PIC 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 PIC is limited to repairing small cracks, replacing a propeller, checking electrical

connections and updating software and firmware for the on­board computer. The PIC

will document work performed in accordance with 91.417. We feel that due to the size,

construction, and simplicity of the aircraft, the PIC can ensure an equivalent level of safety.

Safety and Benefits of the sUAV.

Conclusion

DET LLC will be using the sUAV in a variety of applications that generally require

expensive full­size manned aircraft to complete. Small, light, unmanned aerial vehicles offer

more efficient and safer benefits over the use of full­sized manned aircraft for aerial

photography, film and still photography, industrial inspection. This would greatly supply safer,

faster, and more efficient information to our local officials and Industrial facilities managers to

make efficient decisions and planning.

DET LLC is committed to promoting the UAS research efforts of policymakers by sharing data

from its commercial UAS operations and serving as a resource for future UAS research

operations. Thus, the FAA has good cause to grant this Petition.

As pointed out in this application, the DJI Inspire1 which our company would use, under

authorization by the US DOT­FAA, is a small, light­weight device operated within the line of

sight of the Pilot­in­Command (PIC), less than 400 feet above the ground and outside 5 miles

from any airport, heliport, seaplane base, spaceport, or other location with aviation activities,

unless the air traffic control authorities (ATC) have been notified and have authorized each

flight within a radius of this distance.

Attachments:
DJI Inspire 1 Quick Start Guide

DJI Inspire 1 User Manual

DJI Inspire 1 Safety Guide

DJI Inspire 1 Intelligent Flight Battery

DJI Inspire 1 Maintenance Manual