UNITED STATES OF AMERICA

DEPARTMENT OF TRANSPORTATION

FEDERAL AVIATION ADMINISTRATION

WASHINGTON, DC

Regulatory Docket No. _______________

IN THE MATTER OF THE PETITION FOR EXEMPTION OF:

REDHAWK AERIAL IMAGING, INC.,

FOR AN EXEMPTION SEEKING RELIEF FROM THE REQUIREMENTS OF

TITLE 14 OF THE CODE OF FEDERAL REGULATIONS

14 C.F.R §§ 35 Part 21; and 45.23(b); 61.113(a)&(b);​91.7; 91.103(b); 91.109; 91.119;

91.121; 91.151; 91.405(a); 91.407(a)(1); 91.409(a)(1) & (a)(2); AND 91.417(a) &(b); 91.7(a)

CONCERNING COMMERCIAL OPERATION OF THE

DJI PHANTOM 2 UNMANNED AIRCRAFT SYSTEM

PURSUANT TO SECTION 333 OF

THE FAA MODERNIZATION AND REFORM ACT OF 2012 (PUBLIC LAW 112­95)

Submitted on May 19, 2015

PATRICIA J. RITHAMEL,

Redhawk Aerial Imaging, Inc.

341 Harden Street

Antioch, IL 60002

Tel: 847­847­8328

Chief Financial Officer
TABLE OF CONTENTS

Page

SUMMARY

......................................................................................................................................3

INTRODUCTION

............................................................................................................................3

BACKGROUND OF PETITIONER

................................................................................................4

PUBLIC INTEREST

........................................................................................................................4 SPECIFIC

SECTIONS OF 14 CFR WHICH REDHAWK AERIAL IMAGING SEEKS EXEMPTION

...................................................................................................................................5

REASONS REDHAWK AERIAL IMAGING EXEMPTION WILL NOT AFFECT PUBLIC

SAFETY

..........................................................................................................................................8

CONCLUSION

.............................................................................................................................10

SUPPLEMENTAL ATTACHMENTS

APPENDIX A­ REDHAWK AERIAL IMAGING FLIGHT OPERATING PROCEDURES

.....................................................................................................................................................

...11

ATTACHMENT A­ DJI PHANTOM 2 USER MANUAL

..........................................................................................................................13

ATTACHMENT B­ DJI PHANTOM 2 PRODUCT RELEASE NOTES

.....................................................................................................................................................

...13

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SUMMARY

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

and 14 C.F.R. Part 11, Redhawk Aerial Imaging, Inc., seeks an exemption from Federal

Aviation Regulations (“FARs”); C.F.R. 45.23(b); 14 C.F.R. Part 21; 14 C.F.R. 61.113(a)&(b);

91.7(a); 91.9(b) (2); 91.103(b); 91.105;(2) and (b) 91.109; 119.121; 91.151(a); 91.203(a)&(b);

91.405(a); 91.407(a) (1); 91.409(a) (2); 91.417(a)&(b). This exemption will permit Redhawk

Aerial Imaging, Inc., (hereinafter referred to as “Redhawk Aerial Imaging”) to provide

unmanned aircraft solutions with services for state, local, and commercial clients. Redhawk

Aerial Imaging is focused on providing solutions for utilizing unmanned aircraft for aerial data

acquisition, photography and videography in the areas of Construction, Agriculture,

Infrastructure, Real Estate, and other applicable areas.

INTRODUCTION

Patricia J. Rithamel, and The Company formed by her, Redhawk Aerial Imaging, Inc, (both

Patricia J. Rithamel and Redhawk Aerial Imaging, Inc., hereinafter known as Redhawk Aerial

Imaging) seeks an exemption to operate the DJI Phantom 2, for compensation or hire within

the national airspace system (NAS).

The DJI Phantom 2 unmanned aircraft system (UAS) is an advanced consumer flight platform

manufactured by DJI, a multi­rotor manufacturer established in 2006 that has a history of

producing leading edge UAS platforms and safety systems for the professional UAS operator.

The DJI Phantom 2 is comprised of a radio controlled four motor, multi­rotor UAS. The DJI

Phantom 2 has direct pilot intervention at all times. Automated systems are in place to assist

the pilot and ensure that at no time is safety compromised by a lost link situation. The DJI

Phantom 2 UAS has a maximum gross weight of approximately thirteen hundred (1300)

grams, while having a diameter of three hundred fifty (350) millimeters. The UAS is equipped

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with four propellers and four motors driven by lithium polymer batteries. Maximum speed of

approximately 33mph and a maximum rate of climb of 1181fpm. Maximum flight times of

twentyfive (25) minutes with the capability to hover, and move in the vertical and horizontal

plane simultaneously. Maximum altitude is four hundred (400) feet limited by Redhawk Aerial

Imaging, vertical line of sight (VLOS) requirements.

To maintain vertical line of sight (VLOS) requirements, the UAS is equipped with distance

limiting programs to ensure that the UAS and /or the pilot do not operate the aircraft beyond a

predetermined range.

The radio frequencies and equipment utilize the 2.4GHz spectrum. All equipment has the

appropriate FCC authorization / approval to transmit on the radio frequencies used for UAS

uplink and downlink of control, telemetry, and payload information.

BACKGROUND OF PETITIONER

I, Patricia J. Rithamel, <corporate title> of Redhawk Aerial Imaging, am writing pursuant to the

FAA Modernization and Reform Act of 2012 and the procedures contained within 14 C.F.R.

11, to request that Redhawk Aerial Imaging, an aerial data acquisition, photography and

videography business, be exempted from the Federal Aviation Regulations (FARs) listed

below so that we may operate an unmanned aircraft system (UAS) commercially in airspace

regulated by the Federal Aviation Administration (“FAA”).

I recognize the importance of safety as the first and foremost consideration in aviation. There

are many operators of small unmanned aircraft systems that are either unaware or unwilling

to adhere to the strict safety guidelines that the FAA has instituted over the years to ensure

the safety of the National Airspace System as well as persons and property on the ground.

With these issues in mind, Redhawk Aerial Imaging, Inc., seeks to offer safe and legal

unmanned aerial options for data collection, mapping and surveying, photography, and

agriculture services for state, local and commercial clients.

Redhawk Aerial Imaging is committed to safety in all of its operations, as such, Redhawk

Aerial Imaging will implement multiple safety protocols, both in its operations and its flight

platforms to ensure every level of safety and minimize the risk of damage to persons or

property on the ground or in the air (NAS) and to comply with all state, local, and FAA

regulations.

PUBLIC INTEREST

Currently, aircraft for aerial data acquisition, photography and videography and other aerial

operations, utilize manned aircraft, fixed wing or helicopters, that weigh thousands of pounds

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and can carry upwards of two hundred gallons of fuel. To perform aerial operations as

described herein, these aircraft must fly at lower altitudes, increasing the risk to those on the

ground and in the airspace, and contribute to a high level of noise pollution which can disturb

citizens or animals while performing these operations. Redhawk Aerial Imaging is concerned

with safety and the impact on the community and environment. Utilizing small unmanned

aerial systems, minimizes the impact to the environment and to the community as a whole.

Operating small electric powered UAS's, poses no risk of fuel spillage or contamination in the

event of an accident. In the unlikely event of an accident, the small size of the UAS eliminates

the risk to health and safety to onboard pilots and passengers and minimizes if not altogether

removes the hazards to persons on the ground. Sound pollution is almost nonexistent, due to

clean, quiet electric operation. Redhawk Aerial Imaging believes that responsible and safe

UAS operations must be utilized to allow for UAS operations to continue.

SPECIFIC SECTIONS OF 14 CFR WHICH REDHAWK AERIAL IMAGING SEEKS

EXEMPTION

Petitioner, Redhawk Aerial Imaging Aviation, pursuant to the provisions of the Federal

Aviation Regulations (14 C.F.R. § 11.61) and the FAA Modernization and Reform Act of 2012,

Section 333, Special Rules for Certain Unmanned Aircraft Systems, hereby petitions the

Administrator to operate the DJI Phantom 2 UAS in the national airspace system, and for an

exemption from the requirements of 14 C.F.R Part 21 subpart H, §§ 45.23(b), 61.113(a) & (b),

91.103(b) 91.119, 91.121, 91.151, 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and

91.417(a) & (b).

Redhawk Aerial Imaging requests relief from 14 C.F.R. 45.23: Display of marks; general.

Pursuant to 14 C.F.R. 45.23(b), all aircraft operators are required to mark their aircraft

according to certain specifications. Redhawk Aerial Imaging’s DJI Phantom 2 is, by definition,

unmanned and does not have a cabin, cockpit or pilot station on which to mark certain words

or phrases. Furthermore, two­inch lettering is difficult to place on small scale aircraft with

dimensions smaller than the minimal lettering requirement.

Therefore, Redhawk Aerial Imaging requests relief from 14 C.F.R. 45.23(b).

Redhawk Aerial Imaging requests relief from 14 C.F.R. 61.113: Private Pilot Privileges and

Limitations: Pilot In Command (PIC).

Pursuant to 14 C.F.R. 61.113 (a) & (b), private pilots are limited to non­commercial

operations. Redhawk Aerial Imaging can achieve an equivalent level of safety as achieved by

current Regulations. The PIC will have a Private Pilot certificate with a current Medical, and

will meet the flight review requirements specified in 14 CFR 61.56. The DJI Phantom 2 UAS

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will only be utilized for business incidental to Redhawk Aerial Imaging and is incapable of

carrying passengers.

Therefore, Redhawk Aerial Imaging requests relief from 14 C.F.R. 61.113(a) & (b).

Redhawk Aerial Imaging requests relief from 14 C.F.R. 91.7(a), Airworthiness Certificate.

In consideration of the limited size, weight, operating conditions, design safety features, and

the imposed conditions and limitations by Redhawk Aerial Imaging, with the unmanned

aircraft and its operation, Redhawk Aerial Imaging’s operation of the DJI Phantom 2 UAS

meets the conditions of Section 333 and should not require an airworthiness certificate in

accordance with 14 C.F.R. Part 21, Subpart H.

14 C.F.R. 91.7(a) prohibits the operation of an aircraft without an airworthiness certificate. As

no such certificate will be applicable in the form contemplated by the Federal Aviation

Regulations (FARs), this Regulation is inapplicable. No standard exists for airworthiness of

the DJI Phantom 2 at this time, an equivalent level of safety will be achieved by insuring

compliance with the Redhawk Aerial Imaging's Flight Operations and Procedure Manual with

Safety Checklists, and the DJI Phantom 2 User manual as well as inspection and / or

maintenance. Redhawk Aerial Imaging believes that compliance with the DJI Phantom 2 User

Manual and Redhawk Aerial Imaging's Flight Operations and Procedure Manual, including

checklists, and inspection and / or maintenance, that a very high level of safety can be

achieved in ensuring the airworthiness of Redhawk Aerial Imaging's DJI Phantom 2 UAS. The

policies and procedures in place by Redhawk Aerial Imaging and the equipment utilized on

the UAS for Risk Mitigation, provide an Acceptable Level of Safety (ALoS).

Therefore, Redhawk Aerial Imaging requests relief from 14 C.F.R. 91.7(a).

Redhawk Aerial Imaging requests relief from 91.103(b) Pre­Flight Action, specifically "For any

flight, runway lengths at airports of intended use."

Per the preflight section in Redhawk Aerial Imaging Flight Operations and Procedure Manual,

certain preflight actions by the PIC are required including, but not limited to;

● Aircraft safety and flight worthiness inspection.

● Ground station inspection.

● Site assessment and inspection.

● The PIC will take all actions including reviewing weather, including visibility and

standoff distances from clouds.

● Flight battery requirements.

Considering that operations will probably not occur at any airport, the requirement for

knowledge of runway lengths at the airport of intended use, is not appropriate in this case.

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Therefore, Redhawk Aerial Imaging requests relief from 91.103(b).

Redhawk Aerial Imaging requests relief from 91.105(2) and (b), Flight crewmembers at

stations.

The UAS operated by Redhawk Aerial Imaging has no cockpit, the requirement for seatbelts

is not applicable.

Therefore, Redhawk Aerial Imaging requests relief from 91.105(2) and (b).

Redhawk Aerial Imaging requests relief from 91.119, Minimum safe altitudes.

● Redhawk Aerial Imaging's DJI Phantom 2 UAS has multiple safety systems integrated

within the airframe to minimize the risk of damage to persons or property.

● Redhawk Aerial Imaging's DJI Phantom 2 UAS is electric and there is no risk of fuel

spillage or a fire from leaking fuel after an emergency, whereas the typical aircraft

utilized in the proposed operations of Redhawk Aerial Imaging can weigh thousands of

pounds and carry nearly 200 gallons of fuel.

● Equipped with altitude and distance limiting features that inhibit the UAS from flying

above certain altitudes or beyond specified ranges.

● In the unlikely event of a GPS and / or radio control Lost link, the UAS automatically

enters into a hover, if GPS and / or radio control link cannot be re­established, the

UAS will return back to its departure point (Fail Safe).

● Navigation lights

● Flight operations will only commence with permission of the land owner / controller

● Flight operations will only take place in VLOS.

● Flight operations will always have a Visual Observer (VO) to assist the pilot in any and

all sense and avoid concerns regarding airspace as well as any other hazards that

may exist within the flight operation envelope.

● Flight operations in Class A or B airspace will not be performed.

Therefore, Redhawk Aerial Imaging requests relief from 91.119(a), 91.119(b), 91.119(c)

91.119 (d)(1) and 91.119(d)(2).

Redhawk Aerial Imaging requests relief from 91.121, Altimeter Settings.

Redhawk Aerial Imaging’s DJI Phantom 2 UAS is equipped with barometric pressure and

GPS altimeters that provide altitude readings AGL to the UAS pilot via a digitally encoded

telemetric data feed, which downlinks from the UAS to a ground­based on­screen display.

Redhawk Aerial Imaging will only conduct flight operations within Visual Line of Sight (VLOS).

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In the Astraeus­Aerial Waiver 11062, and Snaproll Waiver 11063, the FAA determined this

method to be a sufficient method for ensuring the UAS operations do not adversely affect

safety.

Therefore, Redhawk Aerial Imaging requests relief from 91.121.

Redhawk Aerial Imaging requests relief from 91.151, Fuel Requirements in VFR Conditions.

Redhawk Aerial Imaging operates an electric powered UAS and ground station equipped with

a digitally encoded telemetric data feed that includes feedback data on remaining battery life.

Redhawk Aerial Imaging’s DJI Phantom 2 battery can provide up to twentyfive (25) minutes of

flight time. As the loads can vary, depending on net weight, so can maximum flight times.

Considering the limited flight times possible, to require a reserve of thirty minutes daytime and

forty minutes nighttime would not be possible in all situations.

The FAA recognized these limitations with small UAS's and in 2689, 5745, 10650, 8811,

10808, and 10673.

Redhawk Aerial Imaging’s DJI Phantom 2 UAS is equipped with multiple fail safe items that

minimize the risk of the UAS completely exhausting the battery supply. Should the battery

level fall below thirty (30) percent capacity, LED indicators on the UAS will produce red

blinking light. Should the capacity fall to fifteen (15) percent capacity, the DJI Phantom 2

UAS will begin to descend and land automatically. If necessary, the PIC can manually

override the automatic descent and landing to ensure a safe landing zone free of any persons

or property.

Therefore, Redhawk Aerial Imaging requests relief from 91.151.

Redhawk Aerial Imaging requests relief from 14 CFR 91.405(a), Maintenance required,

91.407(a)(1), Operation after maintenance, preventive maintenance, rebuilding, or alteration,

91.409(a)(2), Inspections, and 91.417(a) and (b), Maintenance records.

Redhawk Aerial Imaging believes that these sections only apply to aircraft with an

airworthiness certificate.

Redhawk Aerial Imaging submits that the requested relief is proper since an equivalent level

of safety will be ensured. The PIC, before each mission, will check the manufacturer’s

internet service pages, and ensure applicable software and hardware is up to date as

required, and ensure compliance with any safety bulletins posted. In addition, the Operator’s

Manual as provided by the UAS manufacturer will be revised to include specific operating

procedures and limitations to comply with the exemptions sought. The revised Operator’s

Manual will be in possession of the crew during operation of the UAS. Furthermore, Redhawk

8
Aerial Imaging will document and maintain all maintenance records for the DJI Phantom 2

UAS.

Therefore, Redhawk Aerial Imaging requests relief from 14 CFR 91.405(a), 91.407(a)(1),

91.409(a)(2), and 91.417(a) and (b).

REASONS REDHAWK AERIAL IMAGING EXEMPTION WILL NOT AFFECT PUBLIC

SAFETY

The components installed on the Redhawk Aerial Imaging DJI Phantom 2 to enhance the

safety include;

● Direct pilot intervention via remote control.

● Navigation/orientation lighting.

● GPS Based altitude and position sensors and flight stabilization system.

● Barometric pressure and GPS altimeters.

● Equipped with altitude and distance limiting features that inhibit the UAS from flying

above certain altitudes or beyond a specified range.

● Lost link integration providing for automatic return to home system ensuring that in the

unlikely event of a lost link occurrence (Fail Safe), the DJI Phantom 2 UAS will safely

return to the departure point.

● Remote instrumentation at the mobile ground station relaying data back to the pilot,

including, altitude, heading, airspeed (relative ground speed), GPS position and

battery power levels, as well as warning messages of critical onboard systems.

Redhawk Aerial Imaging will document and maintain all maintenance, overhaul and

modification records for its UAS.

Redhawk Aerial Imaging submits that the requested relief under Section 333 is proper in

consideration of the limited size, weight, operating conditions, design safety features, and the

imposed conditions and limitations by Redhawk Aerial Imaging, that an equivalent level of

safety will be ensured.

Redhawk Aerial Imaging in all flight operations will comply with airspace rules. Flight

operations will not impede, delay or divert any other aircraft as the Redhawk Aerial Imaging

flight operations will be conducted below 400 feet AGL. Any operations in airspace controlled

by a control tower, will be coordinated with the tower to ensure there are no hazards to the

NAS. A Letter of Authorization will be procured from appropriate airport managers to ensure

compliance with airspace and ATC operations. Redhawk Aerial Imaging will adhere to all

airspace rules.

Class A No Operations Allowed

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Class B No Operations Allowed

Class C per 91.130

Class D per 91.219

Class E per 91.127

Class G per 91.126

Redhawk Aerial Imaging has implemented procedures to address flight termination plans in

the unlikely event of an unrecoverable system failure. As flight operation locations will vary

considerably, Flight Termination Points (FTP's) will vary for each location (typically FTP's will

be the point of departure). Each flight operations site will be assessed for acceptable risk

FTP's (in order as follows);

● Airspace classification

● Risk to NAS operations

● Risk impedance, delay or diversion of other aircraft due to flight operations

● Risk to persons or property on the ground

● Site assessment to determine hazards that could cause an unrecoverable system

failure

Lost Link Points (LLP's) will be established at each flight operations site. The flight control

systems integrated into Redhawk Aerial Imaging’s UAS has lost link or Fail Safe procedures

that in the event of a lost link, the UAS will return to the origination point. This origination point

is the point at which the UAS departs the takeoff position and is recorded automatically as

soon as the UAS leaves the ground.

All phases of flight with the UAS are critical, as such 14 CFR 135.100 Flight crewmember

duties will be strictly enforced. The areas surrounding where the PIC and the VO are working,

including the ground station will be segregated from any non­participating individuals to

ensure that distractions are kept at a minimum during all critical phases of flight.

The DJI Phantom 2 UAS that will be operated by Redhawk Aerial Imaging will be registered in

accordance with 49 U.S.C. 44103, Registration of Aircraft, as well as 14 C.F.R Part 47,

Aircraft Registration.

CONCLUSION

As set forth herein, Redhawk Aerial Imaging seeks an exemption pursuant to 14 C.F.R. §§

11.61 and Section 333 of the FAA Modernization and Reform Act of 2012 (FMRA), which will

permit the safe operation of its DJI Phantom 2 UAS commercially, without an airworthiness

certificate, for the limited purpose of conducting aerial acquisitions over certain areas of the

United States. By granting this Petition, the FAA Administrator will be fulfilling the

Congressional mandate of the FAA Modernization and Reform Act of 2012, while also

10
advancing the interests of the public. WHEREFORE, in accordance with the Federal Aviation

Regulations and the FAA Modernization and Reform Act of 2012, Section 333, Redhawk

Aerial Imaging respectfully requests that the Administrator grant this Petition for an exemption

from the requirements of 14 C.F.R §§ 35 Part 21; and 91.7; 45.23(b), 61.113(a) & (b),

91.103(b); 91.109; 91.119; 91.121; 91.151; 91.405(a); 91.407(a)(1); 91.409(a)(1) & (a)(2);

AND 91.417(a) &(b); 91.7(a) to permit Redhawk Aerial Imaging to operate its DJI Phantom 2

UAS in the NAS for the purpose of safely, efficiently, and economically utilizing unmanned

aircraft for aerial data acquisition, photography and videography work in the areas of

Construction, Agriculture, Infrastructure, Real Estate, and other applicable areas.

Appendix A – Redhawk Aerial Imaging Flight Operating Procedures

Owner and crew must be familiar with, and follow these operating procedures:

1) Owner must:

a. Document all maintenance, alterations, and updates in the aircraft records.

b. Any maintenance or alterations that affect the UAS operation or flight

characteristics, e.g. replacement of a flight critical component, must undergo a

functional test flight in accordance with the operator’s manual. The PIC who

conducts the functional test flight must make an entry in the UAS aircraft

records of the flight.

2) Prior to each mission:

The PIC must familiarize him/herself with all possible safety aspects of the mission.

This includes but is not limited to:

a. Software versions required (manufacturers web site)

b. Weather

c. Wind (less than 12 knots)

d. NOTAMS

e. Proximity of airports or SUA

3) Prior to each flight:

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The PIC must inspect the UAS and Ground Station to ensure they are in a condition

for safe flight. If the inspection reveals a condition that affects the safe operation of the

UAS, the aircraft is prohibited from operating until the necessary maintenance has

been performed and the UAS is found to be in a condition for safe flight. This includes,

but is not limited to:

a. Batteries (full UAS battery required for each flight, check battery levels for

transmitter and range extender)

b. Inspect propellers, motors, wings and lights

c. The documents required under 14 CFR §91.9 and §91.203 must be available

to the PIC at the Ground Control Station of the UAS any time the aircraft is

operating. These documents must be made available to the Administrator or

any law enforcement official upon request.

The PIC performs a safety assessment. This includes but is not limited to:

a. If operating within 3 miles of an uncontrolled airport, check that a letter of

agreement that covers the current mission with the airport manager is available

to the PIC, and that the operation is conducted under a current NOTAM.

b. Inspect flight area for light poles, trees, utility wires, proximity to helipads,

hospitals, schools, busy roadways, gatherings of people, SUA.

c. The PIC provides a safety briefing to the spotter. An agreement is made

under which conditions the flight must be aborted.

d. Check placement of warning signs: “Caution: Small Unmanned Aircraft

Operation in Progress”

e. Identify take off and landing area.

The PIC performs pre­flight checks:

a. Check all controls neutral

b. Turn on Power at transmitter first, then on UAS, and Range Extender

c. Perform GPS alignment according to manufacturer’s operating manual

d. If alignment successful, flight can start from a safe take­off point

e. Immediately after takeoff perform the following checks:

i. Hover 5­10 feet

ii. Check data link

iii. Check video link

iv. Check altimeter

v. Check GPS

vi. Check time

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4) During each flight:

a. The UAS may not be operated by the PIC from any moving device or vehicle.

b. The UAS may not be operated at an altitude exceeding 200 feet AGL.

c. The UAS may not be operated at night or at altitudes less than 500 feet below

or less than 2,000 feet horizontally from a cloud or when visibility is less than 3

statute miles.

d. The UAS must remain clear and yield the right of way to all other manned

operations and activities at all times (including, but not limited to, ultralight

vehicles, parachute activities, parasailing activities, hang gliders, etc.).

e. Flight time is limited to maximum fifteen (25) minutes.

f. UAS must remain within line of sight and within 500 feet of PIC.

5) Emergency during flight. This could include but is not limited to:

a. Pilot distracted

b. Spotter signals abort

c. Sudden change in weather or wind

d. Manned aircraft in the vicinity

e. People getting within safety perimeter

f. Birds

Immediately:

a. Determine closest safe landing location to UAS

b. Land

6) After each flight:

a. Check and log flight time and remaining battery level.

b. Turn off power to UAS first, then turn off power to transmitter and range

extender

c. Inspect UAS for any damage

d. Remove warning signs

Attachment A ­ DJI Phantom 2 User Manual (version 1.4)

Attachment B ­ DJI Phantom 2 Product Release Notes (as of May 19, 2015)

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