Matthew Sloane Atlanta Drone Consultants, LLC 120 N. Candler St. Decatur, GA 30030 (404) 723
- 5621 Info@AtlantaDroneConsultants.com January 2 2 , 2016 U.S. Department of Transportation Docket Management Sy stem 1200 New Jersey

Avenue SE Washington, DC 20590 **RE: Am**  **endment s**  **to Grant of Exemption No. 12299**  **Atlanta Drone Consultants, LLC Regulatory Docket No. FAA**  **- 2015**  **- 0849**  Dear Sir or Madam, On August 4, 2015 the Federal Aviation Administration (“FAA”) granted an exemption from certain provisions of the Federal Aviation Regulations (“FAR”) pursuant to Section 333 of Public L aw 112
- 95 to petitioner Atlanta Drone Consultants, LL C (“A DC”) permitting operation by ADC of a DJ I Inspire 1 small unmanned aerial sy stem (“UAS”) for the purposes of closed
- set film and television video production. Please see Grant of Exemption No. 12299 (the “Grant of Exemption”) and ADC’s petition for exempti on, docket no. FAA
- 2015
- 0849
. On September 4, 2015 the FAA granted an amendment to the Grant of Exemption permitting operation of additional aircraft. Please see the amendment to the Grant of Exemption at No. 12299A of the same docket number. T he terms ADC’s previous petition and the Grant of Exemption, as amended, are incorporated herein b y reference
. ADC now submits this request to further amend the Grant of Exemption to permit the operation of an additional small UAS , the Drone Aviation Corporation WATT
- 200 (hereafter “WATT
- 200” or “proposed aircraft”). ADC intends to utilize the proposed aircraft for the purposes previousl y permitted by the Grant of Exemption, as amended. 1 The FAA has previously

granted 333 exemption s for use of the identical make and model as the proposed aircraft for identical purposes as those requested by ADC (see e.g. Grant of Exemption No. 12174B as amended, docket no. FAA
- 2015
- 1851, operator Cable News Network, Inc.). Like the aircraft current ly covered by

the Grant of Exemption, the WATT
- 200 is a small UAS rotocopter having the ability to hover and move in a vertical and horizontal plane simultaneously
. The WATT
- 200 is a four
- arm octocopter, having two counter - rotating propellers at each of the four rotor arms. Unlike the aircraft currentl y covered by the Grant of Exemption, the WATT
- 200 is a “tethered” aircraft, such that it draws its power from equipment on the ground rather than relying upon an on
- board electric power source. Because the p roposed aircraft draws its power from a ground source the take
- off weight of the aircraft is lower than that of similarly
- sized aircraft requiring on
- board power, having an empty take
- off weight of 1 8

1 These uses consist of “aerial data collection” including any remote sensing and measuring by an instrument(s) aboard the aircraft including, but not limited to, imagery (p hotography, video, infrared, etc.), electronic measurement (precision surveying, RF analysis, etc.), chemical measurement (particulate measurement, etc.), or any other gathering of data by instruments aboard the aircraft.Request Amendments to Grant of Exemption No. 12299

Atlanta Drone Consultants, LLC January 22 , 2016

2 pounds and a maximum weight of under 2 2 pounds. This l ighter weight and the presence of a ground
- based power supply permits the aircraft to achieve greater safety for operators and individuals on the ground compared to aircraft with on
- board power supplies. In conjunction with the robust safety features of the aircraft’s operating software, the proposed aircraft poses a lower risk of power failure and a lower risk of ground impact due to its light weight and reliable power source . In addition to powering the proposed aircraft, the tether helps ensure safety of operation that exceeds that provided by manned aircraft or free
- flying UAS. Being only 2 00 feet in length, the tether prevents the proposed aircraft from being operated outside the Visual L ine of Sight (“VLOS”) of the Pilot in Command (“PI C”) or Visual Observer (“VO”) or outside the AGL altitude restrictions of the Grant of Exemption and eliminates the risk of a fly
- away incident. By measuring and monitoring the length of tether taken up by the proposed aircraft, the PIC can quickly and easil y as certain current aircraft altitude in the unlikely event the proposed aircraft’s altimeter fails to function properl y. The tether also provides command and control signals between the ground station and the proposed aircraft thus eliminating the risk of lo st link and resulting in a greater degree of control security and reliability

than that provided by

wireless ground stations. The conductive material of the tether is sheathed in a Kevlar armored structure which can withstand tension of over 600 pounds wi thout phy sical failure . Despite its high tensile strength, the tether is extremely lightweight and poses no danger to ground personnel and nonparticipants . The proposed aircraft carries a small on
- board reserve power suppl y which, in the unlikely

event the tether is severed, permits the proposed aircraft to conduct an immediate programmed auto
- landing procedure. ADC intends to operate the proposed aircraft consistent with the parameters set forth in the Grant of Exemption, as amended. The aircraft wi l l be flown at all times under 3 00 feet AGL as measured b y the UA S’ on
- board GPS sy stem, will be kept w ithin line of sight of the PIC , will have a separate safety VO at all times in communication with and within 5 feet of the PIC, will be flown at all times at speeds of 40 miles per hour or less , will be flown at all times during daylight hours , alway s using Visual Flight Rules (“VFR”) and within VLOS , and never using first person view b y the PI C . The PI C will be able to use human vision unaided by an y dev ice other than corrective lenses as specified by a current state - issued driver ’ s license . The PI C will provide the local Flight Standards District Office (“FSDO”) with notice of all of flight operations no less than 72 hours in advance of any intended flight. Each PI C will have over 400 hours of logged flight experience in the same UAS ty pe or model, including 10 take offs and landings within the prior 30 days . The PI C will conduct a f ull and complete inspection of aircraft prior to th e initial takeoff of each flight. In addition to these parameters, ADC shall attached colored pennants or streamers to the tether line at not more than 50 foot intervals beginning at 150 feet above the surface of the earth and visible from at least one mi le provided, however, that such streamers need not be attached if the proposed aircraft is operated below the top of and within 250 feet of any structure, so long as the UA operation does not obscure the lighting of the structure. For the foregoing reason s, ADC believes that the WATT
- 200 provides a higher degree of safety than even those aircraft currently covered by the Grant of Exemption so as not to create aRequest Amendments to Grant of Exemption No. 12299

Atlanta Drone Consultants, LLC January 22 , 2016

3 hazard to the national airspace s ys tem or the public. ADC further believes that approval of thi s amendment provides significant public benefit and is in the public interest. ADC shall submit the operator manual for the WATT
- 200 aircraft together with this proposed amendment under separate cover. Said manual contains proprietary and commercial information exempt from disclosure under the Freedom of Information Act 5 U.S.C. §522 et seq. and ADC requests that it be held a s a confidential document pursuant to 14 CFR 11.35(b). The FAA by

and through its authorized representative is requested to approve this petition for amendment to the Grant of Exemption previously granted to ADC. Respectfully

submitted:
Matthew Sloane