1 of 16

Flight Dynamics LLC

Larry Whitlow

2904 Columbine Cir

Valparaiso, IN 46383

773-359-3861

larrywhitlowaviation@gmail.com

Date: October 19, 2015

U. S. Department of Transportation

Docket Management System

1200 New Jersey Ave.,

SE Washington, DC 20590

RE: Petition of Flight Dynamics LLC, for Exemption Pursuant to Section 333 of the FAA

Reform Act

Attn: 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, Flight Dynamics LLC, operator of Small Unmanned Aircraft

Systems (sUAS) equipped to conduct aerial photography and videography, and infrared

imaging hereby applies for an exemption from the listed Federal Aviation Regulations

(FAR) to allow commercial operation of its sUAS, so long as such operations are

conducted within and under the conditions outlined herein or as may be established by

the FAA as required by Section 333.1

As described more fully below, the requested exemption would permit the operation of

small, unmanned and relatively inexpensive sUAS under controlled conditions in

airspace that is 1) limited 2) predetermined and 3) controlled. The proposed exemption,

if granted, would allow Flight Dynamics LLC, to conduct commercial operations of small

unmanned aircraft systems (sUAS) meeting or exceeding all of the operational and

safety requirements Congress has set forth in Section 333. Page 2
2 of 16

Flight Dynamics LLC, is a media/technology company created, owned and run by Larry

Whitlow. Mr. Whitlow has a current Private Pilot Certificate with Single Engine Land and

Multi Engine Land Ratings, and a current Class III Medical. He has constructed and

obtained certification for his Amateur Built-Experimental Aircraft. Mr. Whitlow has been

active in Radio Controlled Aircraft for over 25 years with experience in fixed wing and

rotary wing aircraft. Flight Dynamics LLC, plans to exploit the capabilities of small

Unmanned Aerial Systems (sUAS) to offer a multitude of services, including:

- Aerial surveying

- Event Photography/Videography

- Aerial Filmmaking and Photography

- Agriculture purposes

- Real Estate Photography

- Construction site inspections and monitoring

- Pipeline Inspection

- Fixed Equipment Inspection

- Aerial Promotion

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

Systems”, provides a mechanism for seeking expedited FAA authorization of safe civil

UAS operations in the 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 rule making 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 UAS operations.

The Petitioner Requests Relief From the following regulations from which the exemption

is requested:

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)
3 of 16

sUAS Operational Benefits

Small Unmanned Aircraft Systems are oftentimes seen as superior to helicopters and

fixed wing aircraft due to the smaller devices, lower cost equipment and personnel,

reduced noise and as such, a much smaller environmental impact which promotes

public safety.

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

ground based imagery for displaying the characteristics of large, complex properties

with several buildings and large trees. The applicants in the past have chartered 2 -6

seat, Piston and Turbine, full-sized helicopters and various size fixed wing single and

multi-engine aircraft for this purpose, which has proven more costly than many potential

clients have been able to afford. The benefits of reduced cost and improved quality of

presentation from the sUAS will be valuable to and benefit many commercial concerns.
4 of 16

sUAS Systems

We are petitioning for exemption to enable Flight Dynamics LLC, to operate the

following sUAS systems:

- Blade Series Multi-rotor sUAS equipped with a camera gimbal and using a HighDefinition camera. This sUAS has a built-in capability to limit the height it flies above

the ground, to limit the radius of the distance it flies from the operator. The Blade also

has the failsafe function of the autopilot system If the Command Link between the

Blade Main Controller and the ground transmitter is interrupted, the outputs of all

command controller will go to the center position. Using the onboard GPS, the system

will automatically trigger Return to Home and will land safely. The sUAS provides in

flight telemetry to the PIC for situational awareness of the sUAS Airspeed, Altitude,

Heading, GPS Altitude, Barometric Altitude, Battery Status, and Autopilot status.

- Blade Series Multi-rotor sUAS Gross weight will not exceed 2.25 lb. sUAS

airspeed / groundspeed will not exceed 20 knots. We plan on using this sUAS in

“dense areas” that we have placed controlled and limited access to by nonparticipating persons for the purposes of;

- Aerial surveying

- Event Photography/Videography

- Aerial Filmmaking and Photography

- Agriculture purposes

- Real Estate Photography

- Construction site inspections and monitoring

- Pipeline Inspection

- Fixed Equipment Inspection

- Building inspection

- Aerial Promotion

- DJI Phantom Series Multi-Rotor sUAS, equipped with a camera gimbal and using a

High-Definition or Infrared Camera. This sUAS with its accompanying ground station,

has a built-in capability to limit the height it flies above the ground, to limit the radius

of the distance it flies from the operator. The Phantom Series also has the failsafe

function of the autopilot system. In the event that the Command Link between the

airborne autopilot system and the ground transmitter is interrupted, all sUAS rates are

nulled and the sUAS is brought to a hover at its current position. If the command link

is not restored in 10 seconds, the system will automatically trigger Return to Launch

Site abort (RTLS) using the on-board GPS and will execute the auto land sequence

safely. The sUAS provides in flight telemetry to the PIC for situational awareness of

the sUAS Airspeed, GPS Altitude, Barometric Altitude, Heading, Attitude, Battery

Status, and Autopilot status.
5 of 16

- DJI Phantom Series Multi-Rotor sUAS Gross weight will not exceed 3.2 lb..

sUAS airspeed / groundspeed will not exceed 20 knots. We plan on using this

sUAS in “dense areas” that we have placed controlled and limited access to by

non-participating persons for the purposes of:

- Aerial surveying

- Event Photography/Videography

- Aerial Filmmaking and Photography

- Agriculture purposes

- Real Estate Photography

- Construction site inspections and monitoring

- Pipeline Inspection

- Fixed Equipment Inspection

- Building inspection

- Aerial Promotion

- DJI Inspire Series Multi-Rotor sUAS, equipped with a camera gimbal and using a

High-Definition or Infrared Camera. This sUAS with its accompanying ground station,

has a built-in capability to limit the height it flies above the ground, to limit the radius

of the distance it flies from the operator. The DJI Inspire Series also has the failsafe

function of the autopilot system. In the event that the Command Link between the

airborne autopilot system and the ground transmitter is interrupted, all sUAS rates are

nulled and the sUAS is brought to a hover at its current position. If the command link

is not restored in 10 seconds, the system will automatically trigger Return to Launch

Site abort (RTLS) using the on-board GPS and will execute the auto land sequence

safely. The sUAS provides in flight telemetry to the PIC for situational awareness of

the sUAS Airspeed, GPS Altitude, Barometric Altitude, Heading, Attitude, Battery

Status, and Autopilot status.

- DJI Inspire Series Multi-Rotor sUAS Gross weight will not exceed 7.2 lb. sUAS

airspeed / groundspeed will not exceed 20 knots. We plan on using this sUAS in

“dense areas” that we have placed controlled and limited access to by nonparticipating persons for the purposes of:

- Aerial surveying

- Event Photography/Videography

- Aerial Filmmaking and Photography

- Agriculture purposes

- Real Estate Photography

- Construction site inspections and monitoring

- Pipeline Inspection

- Fixed Equipment Inspection

- Building inspection

- Aerial Promotion
6 of 16

- DJI Spreading Wings Series Multi-Rotor sUAS, equipped with a camera gimbal and

using a High-Definition or Infrared Camera. This sUAS with its accompanying ground

station has a built-in capability to limit the height it flies above the ground, to limit the

radius of the distance it flies from the operator. The DJI Spreading Wings Series also

has the failsafe function of the autopilot system. In the event that the Command Link

between the airborne autopilot system and the ground transmitter is interrupted, all

sUAS rates are nulled and the sUAS is brought to a hover at its current position. If the

command link is not restored in 10 seconds, the system will automatically trigger

Return to Launch Site abort (RTLS) using the on-board GPS and will execute the auto

land sequence safely. The sUAS provides in flight telemetry to the PIC for situational

awareness of the sUAS Airspeed, GPS Altitude, Barometric Altitude, Heading,

Attitude, Battery Status, and Autopilot status.

- DJI Spreading Wings Series sUAS Gross weight will not exceed 25 lb. sUAS

airspeed / groundspeed will not exceed 20 knots. We plan on using this sUAS in

“non-dense areas” that we have placed controlled and limited access to by nonparticipating persons for the purposes of:

- Aerial surveying

- Event Photography/Videography

- Aerial Filmmaking and Photography

- Agriculture purposes

- Real Estate Photography

- Construction site inspections and monitoring

- Pipeline Inspection

- Fixed Equipment Inspection

- Building inspection

- Aerial Promotion

Inspections and Maintenance

A daily sUAS inspection will be performed by the PIC before commencement of daily

flight operations. A Pre-flight inspection will be performed by the PIC of each sUAS,

after every battery change, prior to each launch, in accordance with the factory

instruction manual and Flight Dynamics LLC operational procedures.

The sUAS will be maintained in accordance with the manufacturers instruction manual.

Flight Dynamics LLC, will develop an inspection and maintenance logging system for

each sUAS system
7 of 16

Flight Crew

Pilot in Command (PIC) and Observer (VO) Qualifications

The PIC will maintain at least a United States issued Private Pilot Certificate and a

current Class III medical certificate, plus at least 2 hours flying time and 3 takeoffs and

landings within 30 days with the type of sUAS utilized in operations. The PIC will have at

least 100 hours total time as PIC of any type of manned aircraft, any and at least 30

hours flying Radio Controlled Model Aircraft of which will be 10 hours flying sUAS.

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

communicate clearly with the PIC.

Training will be conducted on private property used with permission of the property

owner. Flight Dynamics LLC has the ability to provide "dual controls" utilizing two

transmitters with a wired or wireless link between the transmitters. One transmitter is

designated the master transmitter and the other transmitter is designated as a slave.

The PIC instructor, utilizing the master transmitter, will be at all times be able assume

control of the sUAS.

Pilot in Command Duties

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

include all preflight preparation, in flight operation, post flight requirements, all

procedures including but not limited to:

- Safety in flight operations

- Risk Mitigation to Persons and property

- Operating Area Suitability

- sUAS Inspection and maintenance

Observer Duties

The Observer is responsible for maintaining visual contact with the sUAS and the flight

operations area during sUAS operations. The Observer will have the authority to order

the PIC to terminate the flight should he feel the flight cannot be conducted safely.

Observer responsibilities include but are not limited to;

- Warning the PIC of any impending obstacles in the flight path of the sUAS.

- Warning the PIC of any other aircraft approaching the flight operations area.

- Warning the PIC of any deviations in the planned flight path of the sUAS.

- Warning the PIC of any unauthorized personnel appearing in the area of the planned

flight.
8 of 16

General Operating Standards

Flight Dynamics LLC, will only operate its sUAS in the line of sight of a pilot and/or

observer. Such operations will insure that the sUAS will "not create a hazard to users of

the National Airspace System (NAS) or the public.” Flight Dynamics LLC will not operate

any sUAS in Class A or B airspace, Prohibited Airspace, Active Restricted Areas, or

Active Military Operations Areas (MOA), as depicted on the current sectional chart for

the area of proposed sUAS operations. Operations in Class C, D, E and G airspace

subject to the procedures below:

- Before operation of a sUAS within Class C or D airspace (generally 5NM of an

airport with an operating control tower)

- All operations will be DAY VFR only

- Prior to the days of planned operation, the ATC facility responsible for the

airspace will be called to gain clearance to operate the sUAS within Class C or D

airspace. If the flight is planned to operate higher than the structures, or trees or

other ground cover in the area surrounding the planned operations, a Notice To

Airmen (NOTAM) will be filed listing the area, times, and altitudes of the planned

operation.

- On the day of the planned operation, the ATC facility responsible for the airspace

will be notified the planned sUAS operations are ready to occur. This notification

may be done by telephone, or by two-way radio on the ATC facility frequency.

The PIC will give the position, altitude and the times the sUAS will be operated.

- The sUAS will not be operated at an altitude of over 400 feet AGL or as a speed

greater than 20 knots. Weather minimums will be 1 miles visibility and clear of

clouds, equivalent to Special VFR (SVFR) operations.

- Before an operation of a sUAS within Class E airspace and / or 5 NM of a nontower controlled,

- The ATC facility for the airspace and / or airport operators will be notified prior to

the planned operation. If the flight is planned to operate higher than the structures,

or trees in the area surrounding the planned operations, a Notice To Airmen

(NOTAM) will be filed listing the area, times, and altitudes of the planned operation.

- The PIC of the sUAS will give the right of way to avoid flying in the proximity of

manned aircraft.

- At no time will the sUAS be operated on a 3 NM extended centerline of any runway

of an airport depicted on the current sectional chart for the area of proposed

operations.

- The sUAS will not be operated at an altitude of over 400 feet AGL or at a speed

greater than 20 knots. Weather minimums will be 1 miles visibility and clear of

clouds, equivalent to Special VFR (SVFR) operations.
9 of 16

- Maximum planned flight time for each operational flight will be 30 minutes.

- Flights will be terminated at 25% battery power reserve should that occur prior to the

30 minute limit.

- The sUAS will be programmed so that it will not be operated at an altitude of no more

than 400 feet AGL, or not more than 200 feet above an elevated structure or platform

from which filming is planned.

- Minimum crew for each operation will consist of the sUAS Pilot (PIC), and Visual

Observer (VO). An Imaging Systems Operator (ISO) may be a required crew member

depending on sUAS payload and Flight Dynamics LLC operational manual

requirements

- The sUAS operated by the petitioner for dense areas weigh less than 8 pounds,

including the payload (i.e. camera, lens, and gimbals).

- The sUAS operated by the petitioner for non-dense areas weigh less than 25 pounds,

including the payload (i.e. camera, lens, and gimbals).

- The sUAS will operate at speeds of no more than 20 knots, can hover, and can

simultaneously move vertically and horizontally.

- Each area of proposed operation will be secured from entry by non-participating

persons by erecting temporary barricades and / or signage warning of the flight

operations. Adequate personnel will be available to insure non-participating persons

do not attempt to enter the open space of the operating area.

- Given the small size of the sUAS and the restricted environment within which they will

operate, our sUAS operations adhere to the Reform Act's safety requirements.

National Airspace System and National Security

The sUAS, powered by batteries, is smaller, lighter and more maneuverable than larger

aircraft running on combustible fuel, it operates at lower altitudes with no people on

board and will thereby reduce current risk levels and thereby enhance safety and

diminish the likelihood of death or serious bodily injury. With a low Maximum Gross

Take Off Weight (MGTOW), small payload and maximum flight time of less than 30

minutes, these operations offer little or no risk to national security. In addition, by

requiring the PIC to have a current United States issued Private Pilot Certificate, the

concerns of the Dept. of Homeland Security for operations in the National Airspace

System (NAS) should be mitigated.
10 of 16

FCC Information

The transmitter (s) used for controlling the sUAS comply with part 15 of the FCC rules.

Operation is subject to the following two conditions:

1. This device may not cause harmful interference

2. This device must accept any interference received, including interference that may

cause undesired operation.

The radio transmitters used for the Command Link in each sUAS system, are 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. Future transmitter systems operating in other frequency ranges will be compliant

with applicable regulations

Antenna Separation Distance

When operating the 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.

Law Enforcement and Public Safety Operations

Additionally, we request that we be allowed to use our sUAS to benefit Law

Enforcement, Public Safety Officials and First Responders nearby who might require

assistance, including fire fighters, the police, the sheriff, et al., while remaining subject to

all limitations cited in this application as we do so.

A. No flight will be made with a Gross weight exceeding 25 pounds;

B. All operations must occur at an airspeed of no more than 20 knots and no further

than 3/4 NM from the PIC;

C. 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;

D. Operations will be restricted to flights over private property with the permission of the

property owner, or public property after obtaining proper permission or permit from

the government with jurisdiction over the proposed flight area.

E. A sterile area will be created to insure no non-participating persons are in the

operations area.

F. All required permits will be obtained from state and local government prior to

operation;

G. Flight Dynamics LLC, will not operate the sUAS over any open-air assembly of

people;

H. Flight Dynamics LLC, will not operate the sUAS at night.
11 of 16

EXEMPTION REQUESTS AND EQUIVALENT LEVEL OF SAFETY

Flight Dynamics LLC, requests an exemption from the following regulations as well as

any additional regulations that may technically apply to the operation of the sUAS

System:

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 exemption of 14 CFR Part 21, Subpart H,

and the requirement for an airworthiness certificate in general, citing the FAA analysis in

the exemption granted in FAA Regulatory Docket No. FAA-2014-0481 (Trudeau Grant of

Exemption No. 11138)

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. We feel that the permanent placard

will provide the aircraft's registration information at the ground station. We will display at

the ground station a high contrast flag, banner, or signage that contains the words

"Unmanned Aircraft Ground Station" in letters 3 inches high or greater. Since the sUAS

will operate within 3/4 NM of the ground station, the banner should be visible to anyone

that observes the aircraft and chooses to investigate its point of origin. Since the sUAS

will not be certified under Part 21, relief from 45.23 and 45.29 may not be needed citing

the FAA analysis in the exemption granted in FAA Regulatory Docket No. FAA-2014-0481

(Trudeau Grant of Exemption No. 11138)

14 CFR 61.113 A and B 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. The FAA has previously

found that for sUAS systems this is acceptable for both regulatory and security

compliance citing FAA analysis in the exemption granted in FAA Regulatory Docket No.

FAA-2014-0352 (Astraeus Aerial Grant of Exemption 11062)
12 of 16

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. We intend to insure airworthiness by compliance with the

manufacturers flight and maintenance manuals, The FAA has previously found that for

sUAS systems this is acceptable, citing FAA analysis in the exemption granted in FAA

Regulatory Docket No. FAA–2014–0507 (Clayco Inc. Grant of Exemption 11109)

14 CFR 91.9 (b)(2) Civil aircraft flight manual, marking, and placard requirements.

14 CFR 91.203 (a) and (b) Civil Aircraft: Certifications Required

This regulation provides that no person may operate an aircraft unless a current,

approved flight manual is in the aircraft. 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, manufacturers or Flight Dynamics LLC, approved sUAS Flight

Manual must be available to the crew at the ground station anytime the aircraft is in, or

preparing for, flight. Relief from 91.9 and 91.203 may not be needed citing the FAA

analysis in the exemption granted in FAA Regulatory Docket No. FAA–2014–0507 (Clayco

Inc. Grant of Exemption 11109)

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

tests

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

instruction unless that aircraft has fully functioning dual controls." Training will be

conducted on private property with the owner’s permission. Flight Dynamics LLC has

the ability to provide "dual controls" utilizing two transmitters with a wired or wireless link

between the transmitters. One transmitter is designated the master transmitter and the

other transmitter is designated as a slave. The PIC instructor, utilizing the master

transmitter, will be at all times be able assume control of the sUAS. Relief from 91.109

may not be needed citing the FAA analysis in the exemption granted in FAA Regulatory

Docket No. FAA-2014-0481 (Trudeau Grant of Exemption No. 11138)
13 of 16

91.119 (b) Operation over Congested Areas 91.119 (c) Minimum safe altitudes:

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 sUAS 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 pre-planned 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 (less the 8 lb. and restricted to 20 knots) the sUAS we intend to be used

in dense areas, the hazard to persons, vehicles and structures is minimal compared to

manned aircraft or larger sUAS, 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 sUAS 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 sUAS on-board computer to the display screen

held by the PIC, providing a constantly updated AGL readout. The FAA has previously

found that for sUAS systems this is acceptable citing FAA analysis in the exemption

granted in FAA Regulatory Docket No. FAA-2014-0352 (Astraeus Aerial Grant of

Exemption 11062

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 DAY-VFR

Conditions unless there is enough fuel to fly to the first point of intended landing and to

fly after that for at least 30 minutes. The intention of this paragraph is to provide an

energy reserve as a safety buffer for delays to landing. Our sUAS are battery operated

and the maximum duration of flight from a single battery charge is up to 45 minutes,

depending on the sUAS in use. Since the aircraft will never fly more than 3/4 NM from

the point of intended landing, a full battery charge at launch will ensure that we meet the

reserve energy requirement of this paragraph. Operationally, via software setting in the

sUAS we will terminate the planned flight at 25% Battery State of Charge (SOC) and

land with at least 20% SOC. The FAA has previously found that for sUAS systems this

is acceptable, citing FAA analysis in the exemption granted in FAA Regulatory Docket No.

FAA-2014-0481 (Trudeau Grant of Exemption No. 11138)
14 of 16

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 less than 25 pounds, our sUAS are 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. The FAA

has previously found that for sUAS systems this is acceptable, citing FAA analysis in

the exemption granted in FAA Regulatory Docket No. FAA-2014-0481 (Trudeau Grant of

Exemption No. 11138)

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 Field

Replaceable Units, repairing small cracks, replacing a propeller, checking electrical

connections and updating software and firmware for the on-board computer. All other

maintenance will be performed by our maintenance technicians at our repair and

maintenance facility, or by a factory authorized service center, in accordance with the

manufacturers maintenance manual and documentation. The PIC will document work

performed in accordance with 91.417. Our maintenance technicians will document any

work performed at our repair and maintenance facility in accordance with 91.417. We

feel that due to the size, construction, and simplicity of the aircraft, these procedures

can ensure an equivalent level of safety. The FAA has previously found that for sUAS

systems this is acceptable, citing FAA analysis in the exemption granted in FAA

Regulatory Docket No. FAA–2014–0507 (Clayco Inc. Grant of Exemption 11109)
15 of 16

Safety and Benefits of the UAS

Flight Dynamics LLC, will be using our sUAS in a variety of applications that generally

require expensive full-size manned aircraft to complete. Small, light, unmanned aerial

vehicles offer myriad benefits over the use of full-sized manned aircraft for electric

power line inspection, oil/gas pipeline inspection, advanced agriculture, film and still

photography, just to name a few. Replacing significantly larger manned aircraft carrying

crew and flammable fuel with small UAS carrying no passengers or crew creates a

much greater margin of safety for the pilots and crew.

By granting Flight Dynamics LLC‘s requested exemptions, the FAA will help drive

development of safe and successful commercial UAS operations and will advance the

public knowledge base for such operations. Flight Dynamics LLC, is committed to

promoting the UAS research efforts of policymakers including the FAA, NASA, DOD and

DARPA 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.
16 of 16

Conclusion

As pointed out in this application, all the sUAS which our company would use, under

authorization by the US DOT-FAA, are small, light-weight devices operated within the

line of sight of the Pilot-in-Command (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

about each flight within a radius of this distance.

All our SUAs have proven capability for controlled flight. They are devices offered for

general sale on the market around the world and have often been used as Model

Aircraft in the USA. We are certain that the studies conducted until now by the FAA,

about Section 332, Public Law 112-95, 2014, have already provided you with the

assurances on the airworthiness of SUAs such as ours.

For the foregoing reasons, the exemptions requested herein should be granted and

Flight Dynamics LLC should be permitted to conduct commercial small UAS operations

in accordance with its manuals and all other operating parameters deemed necessary

and appropriate by the FAA. The submission of this application and its contents is the

best demonstration that indeed it is possible to pursue the authorization process so that

some SUAs may be used for legitimate commercial activities and under reasonably safe

conditions.

Signed

Larry Whitlow

Flight Dynamics LLC