7/27/2015

U. S. Department ofTransportation Docket Management System 1200 NewJerseyAve., SE Washington, DC 20590 Re: Exemption Request Section 333 ofthe FAA Reform Act Dear Sir or Madam:
Pursuant to Section 333 ofthe FAA Modernization and Reform Act of2012 (theReform Act) and 14 C.F.R. Part 11, PEACHTREE DRONES, LLC, a small business focused on UAS applications utilizing developing software, inspection, assessments and consulting services, PEACHTREE DRONES, LLC hereby applies for an exemption from the listed Federal Aviation Regulations (“FARs”) to allow commercial operation of its Small Unmanned Aircraft Systems (“sUAS”) PEACHTREE DRONES, LLC UAS Platforms DJI Series, Phantom II+, Phantom 3, and Inspire 1. PEACHTREE DRONES, LLC will provide on-demand commercial UAS operations for public and private sectors clients including the following applications below:

• Aerial Videography& Photography/Mapping/Assessment

• Agriculture Survey and Assessments
• Real Estate Videography& Photography/Mapping/Assessment
• Oil Spill Response & Planning Mapping/ Inspection/Assessments
• Offshore Platform Inspection/Assessments
• Pipeline Mapping/ Inspection/Assessments
• Refinery Mapping/ Inspection/Assessments
• SPCC Spill Prevention Control and Countermeasures Mapping/ Inspection/Assessments
• Damage Assessment
• Public Safety Mapping/ Inspection/Assessments/Search and Rescue
• Wind Farm Inspections So long as such operations are conducted within and under the conditions outlined herein or as may be established bythe FAA as required by Section 333. As detailed in this document, the requested exemption would permitthe operation ofsUAS under controlled conditions in airspace that is 1) limited 2) predetermined 3) controlled as to access and 4) would provide safety enhancements to the already best practices safety protocols followed by PEACHTREE DRONES, LLC. Approval of this exemption would thereby enhance safety and fulfill the Secretary ofTransportation’s (the FAA Administrator’s) responsibilities to “...establish requirements forthe safe operation ofsuch aircraft systems in the national airspace system.” Section 333(c) ofthe Reform Act.

PEACHTREE DRONES, LLC FAA333Submittal 1 | P a g e**The name**  **and address**  **of the**  **applicant is:** 

**PEACHTREE DRONES, LLC**  4821 Edinburgh Drive Smyrna, GA 30082 Phone+1

-404

-368

-7511 Jason A Fritz, President/COO Email: Peachtree Drones@gmail.com **Regulations from**  **which the**  **exemption is**  **requested:**
**14 C.F.R.**  **Part 21**  **14 C.F.R.**  **45.23(b) 14**  **C.F.R. 61.113**  **(a) &**  **(b) 14**  **C.F.R. 91.7**  **(a) 14**  **C.F.R. 91.9**  **(b) (2)**  **14 C.F.R.**  **91.103 14** **C.F.R. 91.109**  **14 C.F.R.**  **91.119 14** **C.F.R. 91.121**  **14 C.F.R.**  **91.203 (a)**  **& (b)**  **14 C.F.R.**  **91.405 (a)**  **14 C.F.R.**  **407 (a)**  **(1) 14**  **C.F.R. 409**  **(a) (2)**  **14 C.F.R.**  **417 (a)**  **& (b)** 

**I. STATUTORY** **AUTHORITY FOR**  **EXEMPTIONS** The Federal Aviation Act expressly grants the FAA authorityto issue exemptions. This statutory authority includes exempting civil aircraft, as the term is defined under §40101 ofthe Act, including sUASs, from the requirementthat all civil aircraft must have a current airworthiness certificate. The Administrator may grant an exemption from a requirement ofa regulation prescribed under subsection (a) or (b) ofthis section or any sections 44702

-44716 ofthis title ifthe Administrator finds the exemption in the public interest. 49 U.S.C. §44701(f) See also 49 USC §44711(a); 49 USC §44704; 14 CFR §91.203(a) (1). Section 333(b) ofthe Reform Act assists the Secretary in determining whether sUAS may operate in the National Airspace System (NAS) without creating a hazard to the user, the public, or a threat to national security. In makingthis determination, the Secretary must consider:

• The sUAS’s size, weight, speed, and operational capability;

• Whetherthe sUAS operates within the visual line ofsight ofthe operator

• Whetherthe sUAS operates outside of highly populated areas and away from close proximityto airports
PEACHTREE DRONES, LLC FAA333Submittal 2 | P a g eReform Act §333(a). Ifthe Secretary determinesthat a sUAS “may operate safely in the national airspace

system, the Secretary shall establish requirements forthe safe operation ofsuch aircraft in the national airspace system.” Id. §333(c). PEACHTREE DRONES, LLC sUAS are multirotorvehicles, weighing 10 orfewer lbs. including payload. They operate under normal conditions at a speed of no more than 30 knots and have the capabilityto hover, and move in the vertical and horizontal plane simultaneously. The sUAS will operate only in the Pilot’s visual line of sight at all times and will operate only within the sterile area described in Mission PlanningWorksheet, attached as Exhibit One& Four(hereinafter MissionPlanningWorksheet) Such operations will insure that the sUAS will “not create a hazard to users ofthe national airspace system orthe public.” Reform Act Section 333 (b). Given the small size ofthe sUAS involved and the restricted and sterile environment within which they will operate, our application falls squarely within the zone ofsafety (an equivalent level ofsafety) in which Congress envisioned thatthe FAA must, by exemption, allow commercial operations ofsUASto commence immediately. Also due to the small size of the sUAS and the low altitudes and restricted areas in which the sUASwill operate, approval ofthe application presents no national security issue. Given the clear direction in Section 333 ofthe Reform Act, the authority contained in the Federal Aviation Act, as amended; the strong equivalent level ofsafety surroundingthe proposed operations, and the significant public benefit, including enhanced safety, the grant ofthe requested exemptions is in the public interest. Accordingly, PEACHTREE DRONES, LLC respectfully requests that the FAAgrant the requested exemption without delay.

**II. PUBLIC**  **INTEREST**

This exemption application is expressly submitted to fulfill Congress’ goal in passing Section 333(a)through (c) of the Reform Act. This law directs the Secretary ofTransportation to considerwhether certain unmanned aircraft systems may operate safely in the NAS before completion ofthe rulemaking required under Section 332 ofthe Reform Act. By granting an exemption the FAAwill fulfill Congress’s intent ofallowing UAS to operate with significant safety precautions in low risk environments. The use ofsUAS on a Public and Private applications can significantly reduce the risk while inspecting, surveying, or monitoring missions. sUAS can inspect, photograph, and collect data on hard to getto areas that otherwise would require worker inspection. Additionally, sUAS could replace the use of helicopters and small aircraft to monitor sites. The sUAS we propose tofly in this application are underfive pounds, and carry no combustible material on board, as opposed to the much larger conventionally powered small aircraft. Shifting to sUAS from helicopters presents a marked safety increase for ourworkers andthe public. Lastly, sUAS reduce the environmental impact by dramatically decreasingthe energy used for aerial imaging and data collection over a construction site. Our sUAS use rechargeable lithium ion batteries, as opposed to fossil fuels burned in operation of small aircraftthat are many hundreds oftimes heavier. PEACHTREE DRONES, LLC FAA333Submittal 3 | P a g e**III. EQUIVALENT**  **LEVEL OF**  **SAFETY**

PEACHTREE DRONES, LLC proposes thatthe exemption requested herein applyto sUAS that have the characteristics and that operate with the limitations listed herein. These limitations provide for at least an equivalent or even higher level ofsafetyto operations underthe current regulatory structure because the proposed operations represent a safety enhancement to the already safe protocols followed on construction sites and imaging and surveying operations conducted with helicopters and other conventional aircraft.
PEACHTREE DRONES, LLC will be bound by the following limitations when conducting its sUAS operations under an FAA issued exemption:
1. The sUAS will be less than 10 pounds. 2. Mission Planning to be conducted priorto each Mission Tasking See Exhibit One & Four 3. Flights will be operated withinvisual line ofsight ofa pilot with a VO Visual Observer as required. 4. Maximum total flighttime for each operational flight will be 20 minutes. The UAS calculates battery reserve in real time, and will return to its ground station with at least 20% battery power reserve should that occur priorto the 15 minute limit. 5. Flights being operated never exceeding400 feet AGL. 6. Crewfor each operation will consist ofthe sUAS Pilot and VO who will keep the sUAS within his visual line ofsight at all times 7. The sUAS Pilot will be minimum holder of Private Pilot Certificate with a Class 3 Medical or Issued State Driver License. 8. The sUAS will only operate within a planned flight profile, unless conditions warrant a different path due to changing conditions and environment. 9. All flights will be conducted within set guidelines ofweather constraints. 10. All flightwill be conducted 5NM outside of designed FAA Airport in AFD. 11. A briefing will be conducted in regard to the planned sUAS operations priorto each day’s production activities. It will be mandatorythat all personnel who will be performing duties within the boundaries ofthe safety perimeter be present forthis briefing. 12. All flights will have prior consent from property owner or designee. 13. Pilots will have been trained in operation of UASs generally and received up-to
-date information on the particular UAS. 14. All required permissions and permits will be obtained from territorial, state, county or city jurisdictions, including local law enforcement, fire, or other appropriate governmental agencies. 15. Ifthe sUAS loses communications or loses its GPS signal, it will have capability to enter “loiter mode” and hover, reestablish satellite connection, and return to a pre- determined location within the Security Perimeterand land.
**IV. DESCRIPTION**  **OF SPECIFIC**  **REGULATIONS 14**  **CFR 61.113**  **(a) &**  **(b): Private**  **pilot privileges**  **and limitations:**  **Pilot in**  **command** Sections 61.113 (a) & (b) limit private pilots to non
-commercial operations. Because the sUASwill not carry a pilot or passengers, the proposed operations can achieve the equivalent level ofsafety ofcurrent operations by requiringthe Pilot operating the aircraft to have completed a sUAS a minimum of 100 Cycles of Landing and Takeoffwith min of50 Flight Hours in Type ofcraft. Unlike a conventional aircraft that carries the pilot and
PEACHTREE DRONES, LLC FAA333Submittal 4 | P a g epassengers, the sUAS is remotely controlled with no living thing or cargo on board. DJI UAS Platforms are also

operated by an autopilot, which greatly reduces the danger of human error. The area ofoperation is controlled and restricted, and all flights are planned and coordinated in advance asset forth in Mission Plan Worksheet. The sUASto be operated hereunder is less than 10 lbs. fully loaded, carries neither a pilot nor passenger, carries no explosive materials orflammable liquid fuels, and operates exclusively within a secured area as set out in the Manual. Like other civil aircraft, operations underthis exemption will be tightly controlled and monitored by the operator, pursuantto the Manual’s requirements, and underthe requirements and in compliance with local public safety requirements, to provide security forthe area ofoperation as is currently done on active construction sites. The FAAwill have advance notice ofall operations. The risks associated with the operation ofthe sUAS are therefore diminished from the level of risk associated with commercial operations contemplated by Part 61 when drafted, and allowing operations ofthe sUAS as requested with a Pilot who has met the minimum requirements stated in the Manual achieves the level ofsafety contemplated by 14 C.F.R. §61.113 (a) & (b).

**14 C.F.R.**  **91.103: Preflight** **Action** This regulation requires each pilot in command take certain actions before flight to ensure the safety offlight. An exemption is needed from this requirement asthe Pilot will take separate preflight actions, including checkingforweather conditions, checkingflight battery requirements, checkingtakeoffand landing distances, and all other actions in the Preflight Checklist in the Manual. These actions will provide an equivalent level of Safety. See Exhibit One and Four.

**14 C.F.**  **R. 91.119:**  **Minimum Safe** **Altitudes** Section 91.119 establishes safe altitudes for operation ofcivil aircraft. Section 91.119 (d) allows helicopters to be operated at less than the minimums prescribed, provided the person operating the helicopter complies with any route or altitudes prescribed for helicopters bythe FAA. This exemption is for a multirotor craftthat flies similarlyto a helicopter, with vertical takeoffand vertical landing, which will typically operate at altitudes of200 AGL, so an exemption may be needed to allow such operations. The sUAS will never operate at altitude higher than 400 AGL and will be mission flight profile, where buildings and people will not be exposed to operations withouttheir pre-obtained consent. The equivalent level ofsafety will be achieved given the size, weight, speed ofthe sUAS as well as the location where it is operated. No flight will be taken without the permission ofthe property owner or local officials. Because ofthe advance notice to the property owner and any onsite personnel asoutlined in the Manual, all affected individuals will beaware ofthe planned flight operations. Unlike flight operations with aircraft or rotorcraft weighingfar more than the maximum 10 lbs. proposed herein, our sUAS will not carry flammable fuel. In addition, the low

-altitude operations ofthe sUAS will ensure separation between sUAS operations and the operations ofconventional aircraft that must complywith Section 91.119.

PEACHTREE DRONES, LLC FAA333Submittal 5 | P a g e**14 C.F.R.**  **91.121: Altimeter** **Settings**

This regulation requires each person operating an aircraft to maintain cruising altitude by reference to an altimeterthat is set “...to the elevation ofthe departure airport or an appropriate altimeter setting available before departure.” Asthe sUAS may not have a barometric altimeter, but instead a GPS altitude read out, an exemption may be needed. An equivalent level ofsafety will be achieved bythe operator, pursuant to the Manual and Safety Check list, confirmingthe altitude ofthe launch site shown on the GPS altitude indicator before flight.
**14 CFR** **91.151 (a):**  **Fuel requirements**  **for flight**  **in VFR** **conditions** Section 91.151 (a) outlines fuel requirements for beginning a flight in VFR conditions. Our sUAS is limited to operations in sterile and controlled environments as outlined in the Manual, and has a limited range and flight time which require an exemption from 14 CFR 91.151(a). The battery poweringthe sUAS provides approximately 20 minutes of powered flight. To meet the 30 minute reserve requirement in 14 CFR §91.151, sUAS flightswould be limited to approximately 10 minutes in length. Given the limitations on the sUAS’s proposed flight area and the location of its proposed operations within a predetermined area, a longer time frame for flight in daylight or night VFR conditions is reasonable. PEACHTREE DRONES, LLC believes that anexemption from 14 CFR §91.151(a) falls within the scope of prior exemptions. See Exemption 10673 (allowing Lockheed Martin Corporation to operate without compliance with FAR 91.151 (a)). Operatingthe small sUAS, in a tightly controlled area where only people and property owners or official representatives who have signed waivers will be allowed, with less than 30 minutes of reserve fuel, does not engenderthe type of risksthat Section 91.151(a) was intended to alleviate given the size and speed of the small UAS. Additionally, limiting sUAS flights to 10 minutes would greatly reduce the utility forwhich the exemption will be granted.
An equivalent level ofsafety can be achieved by limiting flights to 30 minutes, or enough battery reserve to ensure that the sUAS lands at the ground station with at least 20% of battery power (as determined by the onboard monitoring system and the Pilot), whichever happens first. This restriction would be more than adequate to return the sUAS to its planned landing zone from anywhere in its limited operating area. Similar exemptions have been granted to other operations, including Exemptions 2689F, 5745, 10673, and 10808. **14 CFR**  **91.405 (a);**  **407 (a)(1);**  **409 (a)(2);**  **417 (a)**  **& (b):**  **Maintenance inspections**  These regulations require that an aircraft operator or owner “shall have that aircraft inspected as prescribed in subpart E ofthis part and shall between required inspections, except as provided in paragraph (c) ofthis section, have discrepancies repaired as prescribed in part 43 ofthis chapter...,” and others shall inspect or maintain the aircraft in compliance with Part 43. Given that these sections and Part 43 apply only to aircraft with an airworthiness certificate, these sections will not applyto PEACHTREE DRONES, LLC. Maintenance will be accomplished by the operator pursuant to the flight manual and operating handbook as referenced Exhibit Two. An equivalent level ofsafety will be achieved because these small sUAS are very limited in size and will carry a small payload and operate only in restricted areas for limited periods oftime. If mechanical issues arise the sUAS can land immediately and will be operating from no higher PEACHTREE DRONES, LLC FAA333Submittal 6 | P a g ethan 400 feet AGL. As provided in the Manual and Checklist, the Pilot will ensure that the sUAS is in working

order priorto initiating flight, perform required maintenance, and keep a log ofany maintenance performed. Moreover, the Pilot is the person most familiar with the aircraft and best suited to maintain the aircraft in an airworthy condition to provide the equivalent level ofsafety.
Pursuant to 14 C.F.R. Part 11, the following summary is provided for publication inthe Federal Register, should it be determined that publication is needed: Applicant seeks an exemption from the following rules: 14 C.F.R. §21, subpart H; 14 C.F.R 45.23(b);14 C.F.R. §§ 61.113( a) & (b);91.7 (a); 91.9 (b) (2);91.103(b);91.109; 91.119; 91.121; 91.151(a);91.203(a) and (b); 91.405 (a); 91.407 (a) (1); 91.409 (a) (2); 91.409 (a) (2) and 91.417 (a) & (b) to operate commercially a small unmanned vehicle (55lbs or less) in construction operations. Approval ofexemptions allowing commercial operations ofsUAS in the public/private sector enhances safety while reducing risk. Manned aircraft monitoring and surveying creates a greater risk because the craft are much larger, have combustible fuel, and carry an onboard human pilot. In contrast, a sUAS weighing fewer than 10 lbs. and powered by batteries eliminates virtually all ofthat risk given the reduced mass and lack ofcombustible fuel carried on board. The sUAS will carry no passengers or crew and, therefore, will not expose them to the risks associated with manned aircraft flights. The operation ofsmall sUAS, weighing less than 10 lbs., conducted in the strict conditions outlined above, will provide an equivalent level ofsafety supporting the grant ofthe exemptions requested herein, including exemptingthe applicant from the requirements of Part 21 and allowing commercial operations. These lightweight aircraft operate at slow speeds, close to the ground, and in a sterile environment and, as a result, are far saferthan conventional operations conducted with turbine helicopters operating in close proximity to the ground and people. **Privacy** All flights will occur over private or controlled access property with the property owner’s prior consent and knowledge. Images taken will be of individuals who have also consented to being filmed or otherwise have agreed to be in the area where aerial photography willtake place. Satisfaction ofthe criteria provided in Section 333 ofthe Reform Act of 2012

--size, weight, speed, operating capabilities, proximity to airports and populated areas and operation within visual line ofsight and national security
– provide more than adequate justification forthe grant ofthe requested exemptions allowing commercial operation ofapplicant’s sUAS in public/private sector as defined above Sincerely,

Jason A. Fritz President/COO Commercial Pilot with Multiengine Rating FAA Certificate #2725331

PEACHTREE DRONES, LLC FAA333Submittal 7 | P a g eAttachments

Note: Due to file size limitation on Regulations.gov hyperlinks have been provided below Exhibit One

-Mission Planning Worksheet ExhibitTwo
– Maintenance Worksheet ExhibitThree

– UAS Flight Log Exhibit Four
– Pre Mission Planning DJI Phantom Vision 2+V3 Spec Phantom 2 Vision+ PilotTraining Guide v1.1 Phantom 2Vision+ Quick Start Guide Phantom 2Vision + User Manual v1.8 DJI Phantom 3 Specs DJI Inspire 1 Spec DJI Inspire 1 Maintenance Manual V1.0 DJI Inspire 1 Quick Start Guide DJI Inspire 1 Safety Guidelines DJI Inspire 1 User Manual

PEACHTREE DRONES, LLC FAA333Submittal 8 | P a g e

### PEACHTREE DRONES, LLC Mission Checklist

Customer Name Customer Email Customer Phone Number Flight Location Address Flight Plan Lat/Long Boundaries NearestAirport **Mission Planning**  **Yes No**  **NA Comments**  Review Proposed Flight Area ReviewAirspace Constraints Review ifflight path is within 5NM ofAirport Designated underAFD Review ifflight path is on or inside Instrument Approach Path Review Sunrise SunsetTimes for designated flight area Review NOTAMS Review Possible Obstructions Review UAVforecast.com Seven Day Forecast ReviewTerminal Area Forecast to Nearest Location Review KP Index Forecast Assignment ofdesignated(VO) Visual Observer Review Proposed Flight Plan Review Flight Limitations Review of Flight Maintenance Logs **Preflight** Verification ofAll Firmware is update and testflown. Review Current Flight Plan ReviewCurrent Notams ReviewObstructions Review Current WX Nearest Station Does Wind Exceed 20kts If Exceeds No Flight Does Ceiling Exceed 500' above flight plan height If Exceeds no Flight Does Visibility Exceed 3NM Flight will be at least 500' from nonparticipating person vessels vehicles and structures UAS Preflight Inspection Check UAS for visual signs of damage, if damage do not fly Ensure propellers are tightlyfastened and not damaged Check propellers are in correct positions on motors Ensure that motors spinn freel and are not damaged Flight Controller Battery Exceed 90% Charge Flight Controller Range Extender Exceed 90% UAS System Battery Exceed 90% Flight Vision System Battery exceeds 90% Preflight Calibrations of Flight Controller Insert Battery into UAS Turn on Controller/Range Extender ConnectVision Device to UAS Wifi Establish Go Home Location Verify Min of Eight Satellites are seen by UAS **Flight** Announce Voice Clear Prop Start Engines of UAS Validate UAS Startup Increase Throttle to lift off Increase Powerto apx 6'' Hover and establish X,Y,Z Movement in Controls Proceed Preplanned Flight Flight Plan Execution Monitor Flight Telemetry Return Flightto designated landing location Stop Engines **Post Flight**  **Inspection** Inspect UAS for any abnormalities Downlink Data Remove Battery Turn off Flight Controller/Range Extender**PEACHTREE DRONES, LL** **C Maintenance** **CheckList**

CustomerName Customer Location Mission Flight # Date/Time Checked **Airframe** Checkthat all the screws on the frame, gimbal and motor mounts are still securelyfastened. Checkthat all theABS parts are still intact and do not show signs ofwear orfatigue, particularlythe inner mounts Checkthe carbon plates and tubes forwear and damagethat would reducethe structural integrity oftheframe. **Motors** Checkthat the prop holder is still secure fastened to the motor with all three screws and thatthe nut and tread that secures the prop is still in good condition. Checkthat the motor is still securelyfastened tothe motor mount with all 4 screws. Checkthat the motor runs smooth when turned by hand and thatthere is not any play in the bearings. Checkthat the motors are free ofdust and any otherforeign particles. Checkthat the motorwindings do not show any damage or bubbling/melting. Also checkthat the motorwires are not damaged. Checkthat the motorwindings do not show any damage or bubbling/melting. Also checkthat the motorwires are not damaged. **Electronics** Checkthat the batteryconnector is in good condition and that the soldering is still secure. Also make sure the wires are not damaged. Checkthatthe wires between the ESC and the motors are not damaged. Checkthat all the different electronic modules are still securelyfastened. Checkthe ESC, Gimbal Control Board, Receiver, Flight Controller, GPS/Compass, etc. Checkthat all thevarious plugs that connect all the electronics are still securely plugged in. Checkthat all the electronics are free ofdust or dirt. Checksensor readingsfor abnormalities. (Check in Mission Planner, Compass reading, GPS, attitude, etc. See **Radio** Checkthat the control gimbals are freefrom dust and other particles. Checkthat the battery is still in good condition. Perform a radio range check. (See radio manual for details) **Lipo Batteries**  Checkthat the battery is not punctured or does not have any other physical damage. The battery should also not be swollen at all. Checkthat all the cells ofthe battery are balanced. (Within 0.1V ofeach other) Checkthat the batteryconnector is in good condition and that the soldering is still secure. Also make sure the wires are not damaged.

Signature 1

Signature 2UASType DJI Phantom 3

UAS Serial # 03Z0121865 Flight # Mission # Locations Date Time Pilot Observer Max Alt Max Distance Max Speed DistanceTraveled Flight Duration Maintenance RequiredPEACHTREE DRONES, LLC Pre

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