Matthew Sloane

Atlanta Drone Consultants, LLC

120 N. Candler St.

Decatur, GA 30030

(404) 723-5621

Info@AtlantaDroneConsultants.com

January 22, 2016

U.S. Department of Transportation

Docket Management System

1200 New Jersey Avenue SE

Washington, DC 20590

RE: Amendments 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 Law 112-95 to petitioner Atlanta Drone Consultants, LLC (“ADC”) permitting operation 

by ADC of a DJI Inspire 1 small unmanned aerial system (“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 exemption, 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. The terms ADC’s previous petition and the Grant of Exemption, as 

amended, are incorporated herein by 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 previously permitted by the Grant of Exemption, as amended.1 The FAA has 

previously granted 333 exemptions 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 currently 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 currently 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 proposed 

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 18

 

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 (photography, 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 22 pounds. This lighter 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 200 feet in length, 

the tether prevents the proposed aircraft from being operated outside the Visual Line of Sight 

(“VLOS”) of the Pilot in Command (“PIC”) 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 easily ascertain current aircraft altitude in the unlikely event the proposed aircraft’s 

altimeter fails to function properly. The tether also provides command and control signals 

between the ground station and the proposed aircraft thus eliminating the risk of lost 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 without physical 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 supply 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 will be flown at all times under 300 feet AGL 

as measured by the UAS’ on-board GPS system, will be kept within 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, always using Visual Flight Rules (“VFR”) and within VLOS, and never using 

first person view by the PIC. The PIC will be able to use human vision unaided by any device 

other than corrective lenses as specified by a current state-issued driver’s license. The PIC 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 PIC will have over 400 hours of 

logged flight experience in the same UAS type or model, including 10 take offs and landings 

within the prior 30 days. The PIC will conduct a full and complete inspection of aircraft prior to 

the 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 mile 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 reasons, 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 a 
Request Amendments to Grant of Exemption No. 12299

Atlanta Drone Consultants, LLC

January 22, 2016

3

hazard to the national airspace system or the public. ADC further believes that approval of this 

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 as 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