### S a f e t y , Q u a l i t y , I n t e g r i t y & T e a m w o r k S i n c e 1 9 8 5 4 0 6 P o r t e r W a y

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January 21 , 2016

U.S. Department of Transportation Docket Management System 1200 New Jersey Ave. SE Washington, DC 20590

RE: UAS Petition for Exemption

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, operators at Cannon Companies seek an exemption from Federal Aviation Regulations detailed herein for the operation of lightweight aerial imaging equipment, also referred to throughout as Unmanned Aerial Systems (UAS), as well as their ground based operation equipment described within.

Our Aircraft:

Our operation will include a single UAS, manufacturer DJI, referred to hereinafter as the Inspire 1. (UAS manuals attached). The DJI Inspire 1 has the following flight and safety relatable
features:

 Inspire 1 is a UAS Quadcopter made by DJI that has a fixed gimbal and camera attached to the bottom. Inspire 1 has a maximum weight of 6.47 lb. (2965 grams), and a maximum range of 2000m.

 Inspire 1 has built in telemetry to allow the operator to see all onboard information relating to the safety of flight including but not limited to battery percentage remaining, overall health of the operating system, built-in GPS for position hold and automatic

return- to -home, and multiple fail-safes for maximum safety.

 The onboard camera allows the operator to record High Definition video, as well as take camera stills. The video is transmitted real-time to the control and operator allowing the operator to see images to all sides of the UAS utilizing an Apple iPhone 6 Plus.

 DJI Inspire 1 is limited to a maximum assent rate of 5 m/s and has a maximum decent rate of 4 m/s. It also has a limitation of maximum speed of 22 m/s or 49 mph.

 The Inspire 1 will be operated with a 5700maH lithium polymer battery allowing for flight times not to exceed 22 minutes.

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Our Ground Based Guidance and Control System:

 DJI Inspire 1 is controlled using a DJI transmitter, operating on a 2.4GHz frequency to a maximum range of 2km. (Specific operating range of 2.400-2.483GHz.) (See Manual Appendix page 57 for all specifications.) These specifications fall within FCC guidelines for operators. Powered by a lithium polymer battery it has a 4 hour time between charges.

 The DJI Inspire 1 transmitter has a built in GPS allowing the Inspire 1 to always know
where to return to in the event of a failure.

 The Inspire 1 transmitter will be controlled by a single operator, but will utilize a Visual Observer when necessary.

Our Operator:

 Cannon Companies will use a single operator for each flight, and when able/necessary use a Visual Observer to assist in keeping sight of the Inspire 1 at all times. At no time
will the UAS be flown outside of visual line- of -sight and visual range.

 Our Operator/Pilot has approximately 10 years of Radio Control aircraft operational experience in RC airplanes, helicopters, boats, and cars.

 The only pilot allowed to operate the UAS under this exemption will be the Owner/Operator of Cannon Companies.

Our Business Intent:

Cannon Companies will be utilizing the UAS for multiple projects for time to time ; These include:

Microwave Tower Inspections:

 Inspecting microwave towers (including cellular telephone towers) traditionally requires a human inspection. Utilizing a UAS to inspect these towers greatly improves safety and will prevent deaths of tower Inspectors. We have a significant amount of interest from companies doing business in Central and Northwest Washington to conduct such inspections.

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Bridge Inspections:

 Similar to inspecting towers with the use of UAS, the required inspections of local bridges and overpasses will see a significant amount of increased safety. We have interest from local city officials to conduct such inspections in Central and Northwest Washington.

Construction Safety Inspections & Site Survey:

 Similar to tower and bridge inspections, we plan to use the Inspire 1 to conduct inspections within and outside of construction sites. We have a large amount of interest in using our UAS to inspect and conduct jobsite safety inspections which will identify possible hazards giving General Contractor's the opportunity to eliminate future injuries and accidents that may occur.

 We intend to use the UAS to quickly survey job sites and monitor and record the progress of work, safety equipment infractions, and measure excavation depths. Utilizing a UAS to inspect projects instead of using human resources, heavy machinery and expensive surveying tools will be made more safe and less expensive wit h using our

UAS.

Insurance Inspections of Home and Property:

 Cannon Companies has a significant amount of interest from local and regional Insurance companies and adjusters to utilize the UAS to conduct inspections of property and structures. By utilizing the Inspire 1 to conduct inspections of rooftops, farm fields, and other property, the insurance company stands to save a significant amount of time inspecting such property after storms. Also, utilizing the Inspire 1 will increase safety by preventing adjusters from having to climb tall ladders and roofs to make such inspections.

Commercial Advertising Video and Photography

 Cannon Companies has a significant amount of interest in taking video and photos for advertising in our local area. Utilizing the UAS will offer a significant improvement to the agency with regards to both safety and cost. Using a 6 lb. UAS compared to a gas turbine helicopter or aircraft will offer a considerable safety margin as well as cost savings advantage.

Real Estate Photography and Videography:

 Real Estate photography will see a significant impact with our services, allowing real estate agents a much more competitive product at a much lower price. Safety will also be increased as well as productivity by utilizing our services.

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Yacht Sales Photography and Videography:

 Cannon Companies has seen a significant interest in utilizing out UAS to capture video and photos for Yacht sales near the Bay of Puget Sound. We will utilize the UAS to increase scope of sales to the yacht brokers. We can offer again a more cost competitive product and a much more safe development method over the current use of airplanes and gas/turbine helicopters.

Police/Fire/Search and Rescue:

 Cannon Companies intends to offer our services on a voluntary and pro bono basis for multiple local services including but not limited to Police services, fire fighting services, and search and rescue. These services will increase safety associated with law enforcement and search and rescue. The services will be offered free of charge to the community.

Our Safety and Operating Plan:

 Utilizing our UAS in a safe manner is of upmost importance. Safety will be the guiding principle of our operation, both with respect to the National Airspace System, as well as those on the ground. including persons and property.

 Our Safety plan will start with complying with all Federal Aviation Regulations, as well as conducting audits of safety procedures set forth within Cannon Companies to keep up to date with the safest practices.

 Our initial safety philosophy will be based on the premise of “Be Safe Before Takeoff”. We will complete preflight checklists set forth by DJI, the UAS manufacturer, as well as do thorough post-flight inspections. (see attached for the complete checklist) We will also complete post-flight checklist and debriefs to constantly monitor our procedures and identify any changes that can be made, similar to those set forth on airline flight
decks.

 Ma intenance and repair of our UAS will be conducted solely by the manufacturer, DJI, by its employees or designated technicians. With respect to safety, Cannon Companies believes the manufacturer holds higher maintenance abilities.

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Cannon Companies will comply with the following at all times when conducting commercial operations:

1. All operations will remain outside Class A,B,C,D airspace.

2. Our operating system will be programmed before all flights to avoid airports such not to accidentally fly too close to one. The onboard system will not allow the Inspire 1 to fly into such airspace. This is an automatic safety feature within the Inspire 1.

3. Operations conducted by Cannon Companies will always remain within visual line- of -sight of the

UAS. Never to excee d the limitations of our operator’s eye sight. We will limit the maximum range of the UAS to not exceed a single persons visual eye-sight range. Utilizing the software within the UAS will help to maintain this limit, not to exceed 300m. (.186 miles)

4. Our UAS will never carry an implement not approved by the manufacturer and will never exceed a weight of 55 lb. as stated within this exemption.

5. All operations conducted by Cannon Companies will be at an altitude of less than 400ft AGL, while the majority of our operations will be at an altitude less than 200ft AGL. The Inspire 1 has an automatic altitude limit built in and will be set and checked by our operator prior to every flight operation as part of the pre-flight inspection.

6. Cannon Companies will not conduct operations with a speed in excess of 27 knots. The Inspire 1 UAS has an automatic speed limiter that will be set and checked prior to every flight by the operator as part of the pre-flight inspection checklist.

7. All operations will be conducted in Day VFR conditions. Minimum flight visibility for all operation will be 5 miles. Minimum cloud ceilings will be 2000ft OVC (overcast) or BKN (broken).

8. All operations will be conducted away from densely populated areas. Cannon Companies will work with local officials to make sure any required local documents or permits are attained prior to each flight.

9. Prior to each flight our operator will conduct a safety audit of the area to be flown. An assessment will be made with regards to persons, property, and weather. This assessment will allow our operator to determine whether a safe operation and outcome will be expected.

10. Our operation will utilize a single, dual- band transceiver and will maintain a “listening watch” of airspace surrounding the operations. (example, we will monitor both local frequency 122.8 as well as maintain watch of emergency frequency 121.5.) Our operator will also make traffic advisories of our operation location and maximum altitudes prior to all flights utilizing the UAS.

11. Prior to operating under this exemption, our operator will obtain a Certificate of Waiver or Authorization (COA) from the FAA Air Traffic Organization.

12. Areas of operation are attached at the bottom of this document. Part of the addendum section.

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The current regulations that we seek exemption from are:



# A. 14 CFR Part 21 (h) Airworthiness Certification

Under this part we seek exemption to apply for and maintain airworthiness certification for our UAS. Model and serial number of our UAS will be provided within.



# B. 14 CFR Part 91 Subpart A: Airworthiness 91.7 (a) Civil Aircraft Airworthiness

Under this part, “no person may operate a civil aircraft unless it is in airworthy condition.” We seek exemption from this part, as we will keep our UAS in a safe, reliable, and airworthy condition, it may not meet all standards as set for by this part of the FAR’s. Our operator will assume all responsibility for determining that the UAS is in a condition safe for flight, as well as a condition that will not harm other people or property. This will be accomplished using specific guidelines from the manufacture, DJI, as well as following any guidance set for for routine

maintenance.



# C. 14 CFR Part 91 Subpart C: 91.203: Certifications Required

Under this part, (a) no person may operate an aircraft unless it has within it the following; An appropriate and current airworthiness certificate. This part also includes regulations regarding the use of fuel tanks, which do not apply.

We seek exemption from this part as an airworthiness certificate does not apply to our specific

UAS.



# D. 14 CFR Part 91 Subpart B; 91.119 Minimum Safe Altitude

Under this part, (a) no person may operate an aircraft below an altitude allowing, if power fails, an emergency landing without undue hazard. (c) over other than congested areas an altitude
below 500ft AGL.

We seek exemption from this part due to the nature of the operation, as well as the safety procedures set forth will have little to no risk of damaging any person or structur e.

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# E. 14 CFR Part 91 Subpart B; 91.121 (a)(1) Altimeter Setting

This section pertains to setting an altimeter setting below 18000ft to a reported altimeter reporting station setting.

We seek expedition from this part as our UAS has no way of setting an alternate altimeter setting. With a built-in barometer, the Inspire 1 uses real-time data to determine altitude each flight. Operating less than 400ft AGL, we feel our UAS will have little to no impact on other participating aircraft. Also, with flights not to exceed 16 minutes (22 minute battery, and landing at 30% battery remaining) our UAS will not need to recalibrate its altimeter while in flight.



# F. 14 CFR Part 91 Subpart B; 91.151 Fuel Required for VFR flight

This section contains requirements for fuel in VFR flight for combustion engines.

We seek exemption from this part as our UAS operates off of battery power only. We feel our operations will not compromise safety to either the operator or property as we have set forth a procedure to land our UAS when the battery level reaches 30%, or approximately 6 minutes flight time remaining. The Inspire 1 has built in battery telemetry that feeds information real time to the operator and an alarm notifies the operator of minimum battery level remaining. (See attached manual for more information)



# G. 14 CFR Part 91 Subpart E; 91.405 Maintenance Required

This section contains requirements for the operator to maintain and have inspected the aircraft in accordance with Part 43 of the CFR. Under this section it is required to keep maintenance logbooks with the aircraft. It also requires the aircraft to contain placards of the inoperative equipment.

We seek exemption from this part as our UAS will not be operating with inoperative equipment and is too small to carry logbooks. We also seek exemption due to no certified maintenance technicians will work on the UAS. Under this exemption Cannon Companies will be completing pre-flight and post-flight inspections, and any required maintenance or repairs will be completed by the manufacturer, DJI, or one of its certified technicians.

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# H. 14 CFR Part 91 Subpart E; 91.407 Operation After Maintenance

This part requires an aircraft that has undergone repair, rebuilding, alterations, or general maintenance to be approved by an authorized person required by CFR 43.9 and CFR 43.11.

We seek exemption from this part as these inspections do not pertain to our operation of the UAS. The operator will be responsible for determining the airworthiness of the UAS prior to each flight. After maintenance provided by the manufacturer, the operator will complete test flights before any operation in the vicinity of persons or property to assure all systems are functioning normally.



# I. 14 CFR Part 91 Subpart E; 91.409 Inspections This section provides details of the required inspection on an aircraft. No person will operate an aircraft unless in the preceding 12 months has had (1) an annual inspection (2) an issuance of an
airworthiness certificate.

We seek exemption from this part as the inspection and airworthiness certificate to not apply to our UAS. Our operator will be responsible for the inspection and airworthiness determination prior to each flight and will have the UAS repaired by the manufacturer or one of its certified technicians, if the UAS is found to be in a state other than intended but the manufacturer.



# J. 14 CFR Part 91 Subpart E; 91.417 Maintenance Records

This section requires the owner/operator to complete and retain a list of all records pertaining to the work preformed, the date of completion, the signature of the inspector, and all work performed on the aircraft.

We seek exemption from this part as the inspections and technician work will not apply. Our operator will be responsible for determining the airworthiness of the UAS prior to each flight and will not operate the UAS in any condition other than intended by the manufacturer. The operator will keep records of all work completed by the maintenance facility.

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# K. 14 CFR Part 91 Subpart B; 91.103 Preflight Action

This section requires each pilot prior to flight will become familiar will all available information pertaining to that flight including runway lengths, flight information, weather, etc. For any flight, runway lengths at airports of intended use, and the following takeoff and landing distance information include; all applicable information relating to aircraft performance, airport elevation, runway slope, aircraft gross weight, wind and temperature.

We seek exemption from this part as our operator, while utilizing all available information for the safe operation of the UAS, will not have the above information available for most flights. The operator will use good judgment and all resources available to ascertain the information necessary for the safe operation of the UAS. A preflight inspection will be accomplished according to the manufactures instructions prior to each flight.



# L. 14 CFR Part 91 Subpart B; 91.105 Flight Crew members Stations This section pertains to the required crew members being at their stations during all phases of flight, and requires the use of seat belts and shoulder harnesses.

We seek exemption from this section as it pertains to aircraft with flight crew member stations.
Our UAS does not have such stations.



# M. 14 CFR Part 91 Subpart B; 91.9 Placement of Manual This part states no aircraft may operate without a manual onboard the aircraft.

Our UAS is not large enough to carry such operating manual. We will however carry a current manufacturer manual in the UAS carrying case along with the operator on all flights.



# N. 14 CFR Part 45.23 Under this part, it is required that each operator must display on that aircraft marks consisting of the Roman capital N followed by the registration number of the aircraft.

Our UAS is too small to attach the “N” number. We seek exemption from this part as we will be attaching the registration or serial number as required on the UAS.

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Cannon Companies and its owners are committed to a “Safety First” atmosphere. We are committed to conducting our operation in accordance with all Federal Aviation Regulations and maintaining a safety margin of at least those regulations while striving to exceed expectations set forth by the FAA. We are confident we can approach our operations with safety while adding a significant advantage to our community both through private and civil services.

Cannon Companies is prepared to respond to any concerns and look forward to working with you on this important exemption. If you could please reference Grants of Exemption Nos. 11062 to Astraeus Aerial (see Docket No. FAA−2014−0352), 11109 to Clayco, Inc. (see Docket No. FAA−2014−0507), 11112 to VDOS Global, LLC (see Docket No. FAA−2014−0382), and 11213 to Aeryon Labs, Inc. (see Docket No. FAA−2014−064 2) as a re source of exemptions in circumstances similar in all material respects to those presented in our petition.

Please contact us with any other questions or concerns.

Sincerely yours,

Cade Cannon

General Manager Cannon Companies
Cell: 253.509.2703 Email: ccannon@cannonconstrucitoninc.com

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# ADDENDUMS

Aircraft Information:

 Make: DJI

 Model: Inspire 1

 Craft Serial #: W13DCC300330033

 UAS CERTIFICATE NUMBER#: A3XAW7FLA

Features:

 Advanced Ready- to -Fly Design

 Powerful Propulsion System

 Aerodynamic Transforming Design

 Modular, Upgradeable System

 New Camera and Gimbal System

 Live HD View

 Create Together

 Fly Indoors and Without GPS using Vision Positioning System

 Intelligent Power

 Management System

 Full -Featured App

 Dedicated Controls

 A Complete Ready- To -Fly System

Specifications:

Remote Controller

 Operating Frequency

o 922.7 ~ 927.7 MHz (Japan Only)

o 5.725 ~ 5.825 GHz

o 2.400 ~ 2.483 GHz

 Transmitting Distance (outdoor and unobstructed: 2 km)

 EIRP

o 10dBm@900M

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o 13dBm@5.8G

o 20dBm@2.4G

 Output Power:9W

 Battery: 6000 mAh LiPo 2S

 Max Mobile Device Width:170mm

Camera

 Total Pixels:12.76M

 Effective Pixels:12.4M

 ISO Range:100-3200 (video) 100-1600 (photo)

 Image Max Size:4000×3000

 Lens : 9 Elements in 9 groups , Anti-distortion
Gimbal

 Model:ZENMUSE X3

 Output Power (with camera):Static : 9 W ; In Motion : 11 W

 Angular Vibration Range:±0.03°

 Controllable Range:Pitch : -90° ~ +30° ; Pan : ±320°

 Mechanical Range:Pitch : -125° ~ +45° ; Pan : ±330°

 Max Controllable Speed : Pitch : 120°/S ; Pan: 180°/s

 Weight

o 2935g (Battery Included)

 Takeoff Weight

o 3400g

 Hovering Accuracy (GPS mode)

o Vertical : 0.5m ; Horizontal : 2.5m

 Max Angular Velocity

o Pitch : 300°/s ; Yaw : 150°/s

 Max Tilt Angle

o 35°

 Max Ascent/Descent Speed

o 5/4 m/s

 Max Speed

o 22m/s (ATTI mode, no wind )

 Max Flight Altitude

o 4500m

 Max Wind Speed Resistance

o 10m/s

 Operating Temperature Range

o -10°~40°C

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 Max Flight Time

o Approximately 18 minutes

 Indoor Hovering

o Enabled by default

Checklists:

Preflight Checklist 1. Remote controller, aircraft battery, and mobile device are fully charged. 2. Propellers are mounted correctly and firmly. 3. Micro-SD card has been inserted if necessary. 4. Gimbal is functioning as normal. 5. Motors can start and are functioning as normal. 6. DJI Pilot app connected to the aircraft.



# AREAS OF OPERATION:

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# OPERATIONS MANUAL:

(See attached Documents)