OUTLAW ENGINEERING, INC PO BOX 1800 ROOSEVELT; UT 84066 (435)232-4321 

September 1, 2015 

U.S. Department ofTransportation 

Docket Operations 

West Building Ground Floor, Room W12-140 

1200 New Jersey Ave., SE 

Washington, DC 20590 

OUTLAW 

ENGINEERING INC. 

RE: Exemption Request Under Section 333 of the FAA Act and Part 11 of the Federal Aviation 

Regulation 

To whom it may concern, 

Pursuant to Section 333 of the FAA Modernization and Reform Act of2012 (the "Reform Act") and 14 

C.F.R. Part 11, Outlaw Engineering, Inc. (OEI), an operator ofthe DJI Phantom 3 Professional 

Unmanned Aircraft Systems (UAS), seeks an exemption from the Federal Aviation Regulation (FARs) 

while still maintaining an equivalent level of safety. 

The following exemptions are listed below: 

14 C.F.R. 21 Subpart H AIRWORTHINESS CERTIFICATIONS 

In consideration of the speed, weight, size and limited operating area associated with the unmanned 

aircraft and its operation. OEI's operation of the Phantom 3 meets the conditions ofFMRA Section 333 

and therefore will not require an airworthiness certificate in accordance with 14 C.F.R. Part 21 Subpart 

H. 

14 C.F.R. 45.23 DISPLAY OF MARKS; GENERAL 

There is no entrance to the cabin, cockpit, or pilot station on which to display. 

14 C.F.R. 45.29 SIZE OF MARKS 

There is no cabin, cockpit or pilot station on which to display. 

14 C.F.R. 61.1-61.429 '') 

Pilot certification. OEI respectfully requestsAhat the FAA grant exemptions from regulations that 

address general flight rules, pilot certificate requirements, manuals, maintenance and equipment 

mandates. OEI believes these requirements are unnecessary to the issue of pilot controlled drone flight. 

Additionally, current FAA proposals have omitted this as a future requirement for small UA V's. 
14 C.F.R. 61.113(a)(b) PRIVATE PRIVILEGES AND LIMITATIONS: PILOT IN COMMAND 

Pilot certification requirements can be achieved by requiring pilots to complete a UAS flight training 

course. The UAS to be operated hereunder weighs less than 55 lbs. fully loaded, carries neither a pilot 

nor passenger, carries no explosive materials or flammable liquid fuels, and operates exclusively within 

a secured area. 

14 C.F.R 67 MEDICAL STANDARDS AND CERTIFICATION 

A third class medical certificate is no longer required. Now, a Section 333 operator only needs a valid 

driver's license to satisfy the medical requirement. 

14 C.F.R. 91.7(b) CIVIL AIRCRAFT AIRWORTHINESS 

This regulation requires that no person may operate a civil aircraft unless it is in airworthy condition. 

Should the exemption be granted allowing commercial operation without an airworthiness certificate, no 

standard will exist for airworthiness. OEI will insure compliance with the Phantom 3 Operating Manual 

prior to each flight. 

14 C.F.R. 91.9(b)(2) & 91.203(a)(b) CIVIL AIRCRAFT FLIGHT MANUAL, MARKING, AND PLACARD 

REQUIREMENTS/CIVIL AIRCRAFT: CERTIFICATIONS REQUIRED 

The flight manual and applicable certification and registration documents will be provided by storing at 

the ground control point where the UAS pilot will have immediate access to them. 

14 C.F.R. 91-103 PREFLIGHT ACTIONS 

Our operations manual already includes preflight procedures directly pertaining to our UAS which 

includes equipment checklist as well as preplanning details regarding weather conditions, review of any 

possible flight path of general aviation, our mission flight path and weather conditions amongst other 

parameters required to complete the mission. 

14 C.F.R. 91.109(a) FLIGHT INSTRUCTION; SIMULATED INSTRUMENT FLIGHT AND CERTAIN 

FLIGHT TESTS 

The UAS, by design, do not have fully functional dual controls, and are controlled instead through the 

use of a control box that uses radio communications for aircraft control. The UAS is unmanned, can be 

controlled remotely, and relatively small, and operate at slower speeds than the aircraft envisioned by 

the regulation. 

14 C.F.R. 91.119 MINIMUM SAFE ALTITUDES; GENERAL 

The Phantom 3 will only fly over property with the permission of the landowner(s) or public agencies. 

The PIC will define before every flight a working area radius and a flight area ceiling, preventing the 

Phantom 3 to go beyond the flight area. Due to the small size of the Phantom 3 and the material with 

which it is built, the hazard to persons, vessels, vehicles and structures is not comparable to manned 

aircraft. 

14 C.F.R. 91.121 ALTIMETER SETTINGS 

The UAS has GPS altitude read-outs instead of barometric altimeters. The read-out will be verified by 

the operator prior to flight by comparing it to the launch site altitude in accordance with the Manual and 

Safety checklist. 
14 C.F.R. 91.151(a) FUEL REQUIREMENTS FOR FLIGHT IN VFR CONDITIONS 

This would be inapplicable because the U AS is battery powered and has limited minutes of powered 

flight. 

14 C.F.R. Subpart E (91.401 - 91.417) MAINTENANCE, PREVENTIVE MAINTENANCE AND 

ALTERATIONS 

Maintenance requirements only apply to aircraft with an airworthiness certificate and are therefore 

inapplicable to its UAS operations. In place of these requirements, the PIC will perform maintenance by 

following procedures outlined in the manual. 

The requested exemptions would authorize commercial operations using the DJI Phantom 3 Professional 

for various site inspections, surveys, planning, As-built construction, site monitoring and other similar 

projects for clients in the oilfield and natural gas industries, telecommunications, mining, agriculture, 

private landowners as well as the public sector. The civil engineering industry routinely utilizes workers 

on the ground to monitor, take photos, and conduct surveys of project sites. These operations will be 

subject to strict operating requirements defined in the Phantom 3 Operating Handbook and Pilot 

Operating Handbook and conditions defined by the Safety Code of the Academy of Model Aeronautics. 

The DJI Phantom 3 will be operated by an individual (Pilot in Command (PIC)) and is able to safely 

operate in a manner consistent with this exemption, including evasive and emergency maneuvers and 

maintaining appropriate distances from people, vessels, vehicles, and structures. The PIC does possess 

significant experience with and has demonstrated the appropriate skillset needed for flying UAS. The 

PIC has flown numerous practice flights in remote areas as a hobbyist simulating flights for future 

commercial use to gain familiarization with the characteristics of the UAS performance. With this 

experience, the PIC has fulfilled the following requirements: 

• Has successfully passed a manufacturer's training program for the Phantom 3. 

• Uses methods, techniques, and practices prescribed in the operating documents. 

• Has flown many hours as a hobbyist pilot. 

• Has a valid Driver's License. 

BACKGROUND OF THE APPLICANT 

OEI is comprised oflicensed professional engineers, surveyors, survey crew chiefs, GIS mappers and 

qualified draftsman trained in working in the civil engineering, surveying, mapping, and environmental 

fields. Outlaw Engineering, Inc. (OEI) is an engineering company in both the Civil and Structural 

engineering field that requires access through inefficient, tedious and dangerous methods. OEI is a 

Utah corporation formed to provide engineering, surveying and drafting to the civil engineering, 

environmental, cultural and construction fields. OEI will specialize in providing extremely high quality 

data for difficult and inaccessible sites using small Unmanned Aircraft Systems (UAS or drone, 55lbs or 

less). 

OEI has 9 years of combined employee experience in professional services practiced within those 

markets. This experience creates an understanding of the economic and safety challenges experienced 

in these markets, as well as the concerns and conditions brought forth by the Federal Aviation 

Administration who regulates the National Airspace in which we propose to utilize UAS to gather data 
with significant cost savings, and more importantly, vastly increased safety for our employees, as well as 

our clients' employees. 

The basis of any design and/or analysis within our fields of service begins, and ultimately depends upon 

timely, current, and accurate baseline data. The collection of that data often includes remote and 

inaccessible sites, resulting in significant safety concerns for both the employees collecting the field 

data, and any persons implementing the resultant design and/or improvements. OEI's UAS flights will 

be flown to achieve an aerial view, video recording, signal analysis, laser measurement and 

concentration measurements. Data captured from the flights will provide valuable data to assist in 

engineering proposals, design and necessary actions. 

CHARACTERISTICS OF THE AIRCRAFT 

The DJI Phantom 3 Professional is a small (590 mm diagonal size including propellers) and ultra-light 

(weight of 1280 g including battery and propellers) platform made of composite materials. Each of the 

four legs contains a high-powered antenna, all constantly broadcasting the live video feed and receiving 

control commands from any direction. The specifications for the Phantom 3 are as follows: 

Remote control: Max.Transmission Distance 1.2 miles (outdoors and unobstructed) 

Flight time: Approximately 23 minutes 

Flight Altitude: 6000 m 

Battery: PH3-4480 mAh-15.2 V 

Motors: 4 Brushless 

Aerodynamic self-tightening propellers 

Max Ascent Speed: 5 m/s 

Max Descent Speed: 3 m/s 

Max Speed: 16 m/s (ATTI mode, no wind) 

GPS Mode: GPS/GLONASS 

Controllable Range: Pitch- 90 degree to 30 degree 

Stabilization: 3-axis (pitch, roll, yaw) 

SAFETY FEATURES 

The UAS missions will be planned and executed with the highest level of safety in mind. The primary 

objective is to safely collect data within a relatively small flight window and return to the landing zone. 

• GPS controlled positioning allows the UAS to "know" it's location, attitude and altitude. 

• RTH (return to home) when triggered, will bring the Phantom 3 back and land it autonomously 

in the event the PIC (pilot in charge) is unable to do so. 

• FAILSAFE Intelligent Flight Battery. If the battery is running low, or if the Phantom 3 loses the 

connection with your remote controller for any reason, the aircraft will automatically return to 

the takeoff point and land safely. 

• AUTOMATIC FLIGHT LOGS are generated and in the event something was to happen, the 

information could be reviewed and steps could be taken to avoid mishaps in the future. 
APPLICATIONS 

The aircraft will be utilized for gathering survey, environmental and engineering data for civil and 

structural engineering services. These areas are typically rural and will not include congested areas. 

The collected data will be used for creating highly accurate orthomosaic maps, 3-D models, digital 

surface models and GPS points. 

The data obtained through the use of the Phantom 3 will enable OEI to better comply with laws and 

regulations by conducting aerial acquisitions for project sites in an efficient and safe manner. Use ofthe 

UAS is a low cost solution with low-environmental impact that protects surveyors and engineering 

personnel from the often hazardous conditions present at civil engineering project sites, while 

optimizing the quality and effectiveness of the data collected. 

The name and contact information of the applicant: 

Outlaw Engineering, Inc. 

Attn: Randy L. Preston, II 

PO Box 1800 

Roosevelt, UT 84066 

Phone:435-232-4321 

Email: randy@outlaw-engineering.com 

Attn: McCoy Anderson, PIC 

PO Box 1800 

Roosevelt, UT 84066 

Phone:435-823-4320 

Email: mccoy@outlaw-engineering.com 

CONCLUSION 

Safety being the main factor for allowing a visual view of the work site while keeping the employee a 

safe distance away. The ability ofUAS to remotely gather data in a safe manner cannot be completed as 

safely or timely with any other current technology. OEI's Pilot in Command (PIC) will be responsible 

for all safety procedures and protocols while on the ground. The Visual Observer (VO) will assist the 

PIC in maintaining safety procedures throughout the course of a project. 

Safety procedures to be utilized in the field include the following: 

• A full diagnostic check of the aircraft by the PIC and VO using a pre-flight checklist will be 

performed on the ground prior to commencement of each project; 

• Operations to be conducted over private or public controlled-access property where approved; 

• Permission from the land owner/authority required before commencing any flight; 

• Operations over congested areas shall be avoided; 

• Operations will not interfere with manned aircraft operations, will yield the right of way to 

manned aircraft, and operators must See & A void other aircraft and obstacles at all times; 
A ' < \. 

• Operations limited to Visual Flight Rules Meteorological Conditions (VMC) and daylight hours; 

• Aircraft operations will remain within Visual Line of Sight (VLOS) and will be visually 

monitored at all times; 

• Flight ceiling pre-programed at 400 feet; 

• All operations conducted within 5 miles from an airport shall only be initiated after verbal 

coordination with the airport authority, or air traffic control when a control tower is present at the 

airport; 

• Post-flight inspection of the aircraft will be performed by the PIC and VO utilizing a post-flight 

checklist; 

In addition, permitting use of the Phantom 3 UAS will achieve various economic and environmental 

benefits, as well as significant efficiencies, associated with cost, labor and safety. 

Please do not hesitate to contact me via email at randy@outlaw-engineering.com if you have any 

questions or concerns. 

Respectfully Submitted,