Mesa County Sheriff’s Office Sheriff Matt Lewis

Grand Junction, Colorado http://sheriff.mesacounty.us/ http://www.MCSONews.com

www.mesauas.com 

Federal Aviation Administration 

800 Independent Ave. SW 

Washington D.C 20591 

Ref: Petition for an amendment to grant of exemption # 11281 paragraph 13. 

- FAA Docket No. FAA-2014-0963 

To Whom It May Concern, 

My name is Ben Miller and I’m the Unmanned Aircraft Program Director for the 

Mesa County Sheriff’s Office (MCSO) in Grand Junction Colorado. 

I’m submitting this letter in collaboration with Draganfly Innovations to request an 

amendment to their 333 exemption (#11281) allowing myself to operate, off duty, 

under their 333 exemption for commercial purposes as an employee of Draganfly 

Innovations without holding a pilots certificate from the FAA. 

I have received permission and support from Mesa County Sheriff Matt Lewis, 

according to MCSO internal policy on secondary employment. Reference attached 

letter. 

Background: 

I began the UAS program at the MCSO in 2008 and we received the first jurisdiction 

wide CoA for the use of sUAS by law enforcement in the United States. Since that 

time our program has received 13 separate CoA. We fly both a quad rotor sUAS as 

well as a fixed wing sUAS. Our program has flown operationally now for 5 years and 

has 85 operational missions to date, not including training flights. I’ve flown 27 of 

those missions ranging from search and rescue flights, armed suspect apprehension, 

and crime scene reconstruction among others. 

Over the years the MCSO, under my direction, has created one of the premier UAS 

teams in public safety, as well as a robust UAS training course that developes safe 

and highly effective UAS operators. 

In our program, operators are selected through a rigorous selection process 

including work performance evaluation, board interview and table top exercise 

testing. After selection, team members are then required to take our 40 hour basic 
- 2 - 

UAS course and successfully pass a written and practical test. Operators are then 

required 6 hrs of UAS training per month during their tenure. This training does not 

only include flight time, but tactics and aviation situational awareness. 

I have personally logged more than 100 hours of ground training as both a student 

and instructor. I am also our programs lead instructor. 

Having filled the role of lead operator in the early days of our program I have 

completed 98 total UAS flight hours. Considering our first UAS, the Draganflyer X6 

had an average flight time of just 12 minutes, this equates to numerous launch and 

recovery evolutions. 

Of my total flight time, 65 hours have been on Draganflyer platforms. 

The Draganflyer X4-ES, our primary mission platform, has an average flight duration 

of 20 minutes. That equates to an average of 195 launch and recovery. 

Furthermore, I have successfully completed Draganfly Innovations Flight Instructor 

training course and have 12 hours of flight training in a Cessna 172 while flying 

under the instruction of a CFII. 

Amendment Request: 

I believe there is substantial merit to allow an amendment to exemption 11281 

paragraph 13. Whereby the FAA will allow myself, Benjamin Joseph Miller, to 

operate all UAS identified in exemption 11281 having completed all mandatory 

flight training required by the MCSO, numerous operational missions in command, 

12 hours of single engine, manned aircraft, flight training, attainment of Flight 

instructor certification by Draganfly Innovations and holding a driver’s license in 

the state of Colorado. 

My UAS operations experience during my tenure with the Mesa County Sheriff’s 

Office Unmanned Aircraft program creates an equivalent level of knowledge and 

safety that will allow me to operate UAS safely under exemption 11281. 

Your interest in providing public service employees increased opportunities for 

professional development is appreciated. 

Respectfully, 

Ben Miller 

UAS program Director