December 19, 2015
Department ofTransportation Docket Management System 1200 NewJersey Ave., SE Washington, DC 20590

DronePilotSafety Thomas Calloway Freeman 747 South Eighth Street Mebane, NC 27302 (919) 619-6828 mailto:tc@dronepilotsafety.com
Re: Exemption Request Section 333 ofthe FAA Reform Act of2012

To whom it may concern,
Pursuant to Section 333 ofthe FAA Modernization and Reform Act of2012, Thomas C Freeman doing business as DronePilotSafety, an operatorofsmall Unmanned Aircraft Systems (sUAS), respectfully request an exemption from the Federal Aviation Regulations ("FARs") detailed belowforthe following described small Unmanned Aircraft Systems, which include an Unmanned Aircraft (UA) and ground station-based equipment and crew. DJI Phantom 3 The Phantom is a quadcopterfor aerial photography and filmmaking. It includes a high-quality camera, custom-built remote controller, and Intelligent Flight Battery, and is compatible with DJI GO app for model devices, which will stream live HD video overWiFi as you fly. Critical flight data is collected, computed and communicated tothe entire aircraft in real time. Description of Proposed Operations The requested exemption would permitcommercial operations of DronePilotSafety, the abilityto perform precision aerial inspections orsurveys that consist ofstill photographs orvideo taken by an onboard camera. Operations and applications we seek forthese sUAS and associated data processing functions include aerial photography, mapping, structural inspections, pipelines and otheroil and gas related inspections, real estate marketing, surveys and otherflight operations that could be performed safely and more cost effectivelywith the use ofsUAS at lowaltitude within the U.S. national airspace system as compared to a manned aircraft. The sUAS will be forthe used in support ofour demonstration, sales and training mission of DronePilotSafety. Use ofsUAS forthese operations reduces the need to operate conventional aircraft orother equipment forthe same purpose and providesvery high quality imagery at afraction ofthe cost ofthe same operations using conventional means. Likewise, inspections ofstructures can be safely performed without endangeringthe inspectoror inhibiting local industrial or public operations with ladders, lifts orother equipment.These savings result in enhanced efficiency and productivity forthe affected activities, as well as environmental benefits and potential savings in both cost and hazards to the public.


### 1The proposed sUAS operations will be limited to daytime Visual Flight Rule ("VFR") conditions, within visual line-of-sight ("VLOS") ofthe operator, in Class Gairspace, and will occur at least 5 miles awayfrom an airport, unless prior contact to AirTraffic Control orthe airport manager has been made. In addition to the fail safe systems programmed in each UAS, DronePilotSafety incorporates redundant safeguards to assure thatthe aircraft does nottravel outside the controlled area of UAS operations, including GPS "geefencing" technologies.
Name and address ofthe petitioner is: DronePilotSafety Attn: Thomas Calloway Freeman 747 South Eighth Street Mebane, NC 27302 Regulations from which exemption is requested:
14 C.F.R. Part 21 Subpart H- Airworthiness Certificates 14C.F.R. 45.23- Display ofmarks; general 14C.F.R. 61.113 (a) 

### & (b)- Private pilot privileges and limitations: Pilot in command 14C.F.R. 91.7 (a)- Civil Aircraft Airworthiness 14CFR § 91.9(b)(2): Civil Aircraft Flight Manual in the Aircraft 14C.F.R. 91.9 (c)- Marking ofAircraft 14 C.F.R. 91.103- Preflight Actions 14 C.F.R. 91.109- Flight instruction 14 C.F.R. 91.119- Minimum safe altitudes: General 14 C.F.R. 91.121- Altimeter settings 14C.F.R. 91.151- Fuel requirements forflights in Visual Flight Rules (VFR) conditions 14C.F.R. 91.203 (a)(l)- Civil aircraft: certification required 14 C.F.R. 91.405- Maintenance required 14 C.F.R. 91.407- Operation after maintenance, preventative maintenance, rebuilding, and alteration 14 C.F.R. 91.409 -Inspections 14 C.F.R. 91.417- Maintenance records 1. DronePilotSafetyseeks exemptionfrom the requirements of 14CFR Part 21, Subpart H: Airworthiness Certificates and 14CFR 

### § 91.203(a) (1)
Section 91.203(a) (1) requires all civil aircraft to have a certificate ofairworthiness. Part 21, Subpart H, entitled Airworthiness Certificates, establishes the procedural requirements forthe issuance of airworthiness certificates as required by FAR§ 91.203(a)(1). Given the size ofthe aircraft (typically less than 10 lbs., and always less than 55 lbs.) and the limited operating area associated with its utilization, it is unnecessary to go through the certificate ofairworthiness process under Part 21 Subpart Hto achieve orexceed current safety levels.
Such an exemption meetsthe requirements ofan equivalent level ofsafety under Part 11 and Section 333 ofthe Reform Act. The Federal Aviation Act and Section 333 ofthe**Re~orm** Act both authorize the FAA to exempt aircraft from the requirementfor an airworthiness certificate, upon consideration ofthe size, weight, speed, operational capability, and proximityto airports and populated areas ofthe UAS involved.

### 2

### In this case, an analysis ofthese criteria demonstratesthatthe sUAS operated without an airworthiness certificate, underthe conditions proposed herein, will be at least as safe, orsafer, than a conventional aircraft (fixed wing or rotorcraft) with an airworthiness certificate. The sUAS weighs less than 55 lbs. fully loaded. Itwill not carry a pilot or passenger, will notcarry flammable fuel, and will operate exclusively within an area pre-disclosed and in compliance with conditions set forth herein. Operations underthis exemption will be tightlycontrolled and monitored by both the operator, and by local public safety requirements. The FAA will have advance notice ofall operationsthrough the filing of NOTAMs. Receipt of the prior permission ofthe land owner, the size ofthe aircraft, the lack offlammable fuel, and the fact thatthe aircraft is carried to the location and notflown there all establish the equivalent level ofsafety. The sUAS provides at least an equivalent, and most likely exceeds, level ofsafetyto that ofsuch operations being conducted with conventional aircraftthatwould be substantially larger and would be carrying passengers, cargo, and flammable fuel. 

### 2. DronePilotSafety seeks exemption from the requirements of 14CFR § 

### 45.23 & 

### 91.9(c): Marking ofthe Aircraft Regulation 45.23 provides: (a) Each operator ofan aircraft must display on that aircraft, marks consisting ofthe Roman capital letter "N" (denoting United States registration) followed by the registration numberofthe aircraft. Each suffix letter used in the marks displayed must also be a Roman capital letter. (b) When marks include onlythe Roman capital letter "N" and the registration number is displayed on limited, restricted or light-sport category aircraft orexperimental or provisionally certificated aircraft, the operator must also display on that aircraft near each entrance tothe cabin, cockpit, or pilot station, in letters not less than 2 inches nor more than 6 inches high, the words "limited," "restricted," "light- sport," "experimental," or "provisional," as applicable. Regulation 91.9(c) provides: No person mayoperate a U.S.-registered civil aircraft unless that aircraft is identified in accordance with part 45 ofthis chapter.
The sUAS has no entrance to the cabin, cockpit, or pilot station on which the markings can be placed. Given the size ofthe sUAS, two-inch lettering will be impossible. Official marking systems for sUAS have notyet been established for operations inside the NAS. DronePilotSafety is prepared to markthe sUAS with the name ofthe organization and location ororigin and fulfill any other request by the FAA to this topic in accordance to§ 45.29(f) where the pilot, observer, and others workingwith the sUAS will see the identification ofthe sUAS.
The FAA has issued the following exemptionstothis regulation; see 

### Exemption Nos. 8738, 10167, 10167A, 10700, 11256, and11251.
3. DronePilotSafety seeks exemption from the requirements of 14 CFR § 

### 61.113(a) & 

### (b); Private Pilot Privileges and Limitations;
This regulation restricts private pilot certificate holders from flying aircraft for compensation or hire, and would also require a second class medical certificate.The purpose of Part 61 is to ensure thatthe skill and competency ofany PIC matchesthe airspace in which the PIC will be operating, as well as requiring certifications ifthe private pilot is carrying passengers or cargo for hire. In this case, while the sUAS will be operated as part ofa commercial operation, it carries neither passengers norcargo. In the Grant of 

### 3Exemption to Astraeus Aerial, the FAA determined that the unique characteristics ofsUAS operation outside ofcontrolled airspace did notwarrant the additional cost and restrictions with requiring the PIC to have a Commercial Pilot Certificate and Class II Medical Certificate. The fulfillment ofthe additional requirements for a private pilotto become qualified as a commercial pilotwould not lead to any additional safety benefitswhen sUAS operations are involved.
The equivalent level ofsafety is the restrictions DronePilotSafety has placed on its sUAS operations. DronePilotSafetywill operate on private property away from persons and property not involved in the operation. DronePilotSafety will also obtain an ATO issued COA priorto conducting any operations under this Grant of Exemption unless the operation can be captured within the confines ofthe "blanket" 200- foot COA. In addition to these flight restrictions, DronePilotSafetywill further ensure safe operation by requiring that any PIC be thoroughlyversed notonly in airspace and communication issues pertainingto all aircraft operators but also in the unique aspects ofsUAS flight. Our PICs will have experience not only in general sUAS operations, but have logged flighttime in the specific make and model used forthe operations before they are permitted to participate in commercial flights on behalfof DronePilotSafety. DronePilotSafety pilots are competent and proficient in the UAS they are operating. DronePilotSafety training and qualification requirements are consistent with those contained in prior FAA Section 333 Grants of Exemption, and will provide a higher level ofcompetency and proficiency for its pilots and will ensure at least an equivalent level ofsafety. DronePilotSafety sUAS pilots will be trained and supervised by the founderThomas Calloway Freeman, FAA certificated Certified Flight Instructor (CFI), Airline Transport Pilot (ATP), orqualified certificated Sport Pilot or higher rated pilot



### 4. DronePilotSafetyseeks exemption from the requirements of 14CFR 

### § 91.7(a): 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 ofsUAS without an airworthiness certificate, no standard will exist for airworthiness ofthe sUAS. Given the size ofthe sUAS and the previous COAs issued for similar sUAS, an equivalent level ofsafety will be achieved by ensuring compliance with the given sUAS manuals and use ofsafety checklists priorto each flight.


### 5. DronePilotSafetyseeks exemptionfromthe requirements of 14CFR 

### § 91.9(b)(2): Civil Aircraft Flight Manual in theAircraft.
The regulation provides: No person mayoperate a U.S.-registered civil aircraft

... (2) For which an Airplane or Rotorcraft Flight Manual is not required by §21.5 ofthis chapter, unless there is available in the aircraft a current approved airplane or Rotorcraft Flight Manual, approved manual material, markings, and placards, orany combination thereof.
Given the size ofsUAS, they have no abilityor place to carry such aflight manual on the aircraft, not only because there is no pilot on board, but because there is no room or capacity to carry such an item on the aircraft. The equivalent level ofsafety will be achieved by keeping the flight manual atthe ground control point where the PIC flying the sUAS will have immediate access to it.The FAA has issued to othersthe following 

### 4exemptions to this regulation: Exemption Nos. 8607, 8737, 8738, 9299, 9299A, 9565, 95658, 10167, 10167A, 10602, 32827, 10700, 11251, and 11256.
6. DronePilotSafetyseeks exemptionfrom the requirements of 14CFR 

### § 91.103: Preflight action
This regulation requires each PIC to take certain actions before flightto insure the safety offlight. As FAA approved rotorcraftflight manuals will not be provided forthe aircraft an exemption will be needed. Following a comprehensive preflight checklist will provide an equivalent level ofsafety. The PIC will take all actions including reviewing weather, flight battery requirements, landing and takeoffdistances and aircraft performance data before initiation offlight.

7. DronePilotSafetyseeks exemptionfrom the requirements of 14CFR § 91.109: Flight Instruction Section 91.109(a), which provides in pertinent partthat "[n]o person may operate a civil aircraft (except a manned free balloon) that is being used forflight instruction unless that aircraft has fully functioning dual controls." sUAS and remotely piloted aircraft, by theirdesign, do not have functional dual controls. Instead, flight control is accomplished through the use ofa device that communicates with the aircraftvia radio communications. Accordingly, an exemption will be required forthe flight instruction requirements of 14C.F.R. 

### § 91.109(a).
Given the size and speed ofthe sUAS that DronePilotSafety intendsto use, an equivalent level ofsafe training can still be performed without dual controls because no pilot or passengers are aboard the sUAS, and all persons will be a safe distance away in the eventthatthe UAS experiences any difficulties during flight instruction.The FAA has approved exemptions forflight training without fullyfunctional dual controls for a number ofaircraft and forflight instruction in experimental aircraft. See Exemption Nos. 5778K

### & 9862A.

8. DronePilotSafetyseeks exemptionfromthe requirements of 14CFR § 91.119: Minimum Safe Altitudes
Section 91.119 establishes safe altitudesfor operation ofcivil aircraft. Specifically, 91.119(c) limits aircraft flying overareas otherthan congested areas to an altitude of500 feet above the surface, except over open water orsparsely populated areas. In those cases, the aircraft may not be operated closer than 500 feetto any person, vessel, vehicle, or structure.
Because aerial survey, mapping and inspection work must be accomplished at relatively low altitudes and at altitudes less than 500 feetAGL, an exemption from Section 91.119(c) is needed.
The equivalent level ofsafetywill be achieved given the size, weight, speed, and material with which sUAS are built. Also, no flight will be taken withoutthe permission ofthe landowner orthose who control the land. Because ofthe advance notice to the landowner, all affected individuals will be aware ofthe flights. Compared to aerial survey operations conducted with aircraft or rotorcraft weighing far morethan 55 lbs. and carrying flammable fuel, any risk associated with these operations will be far less than those currently allowed with conventional aircraft operating at or below 500 feetAGL. Indeed, the low-altitude operations ofthe sUAS will maintain separation between these sUAS operations and the operations of conventional aircraftthat must complywith Section 91.119.


### 5

### 9. DronePilotSafetyseeks exemptionfrom the requirements of 14CFR § 

### 91.121: AltimeterSettings
Section 91.121 requires a person operating an aircraftto maintain cruising altitude orflight level by reference to an altimeterthat is set to the elevation ofthe departure airport or barometric pressure. Some sUAS have a barometric pressure sensor, while others only use GPS for elevation oraltitude. When a barometric pressure sensor is on the sUAS, it is typically "zeroed" atthe pointoftake-off; this is right nextto the PIC and not at a departure airport. The altitude reading will be relative tothat point (on the ground) and nota known elevation.
The equivalent level ofsafety will be achieved by the PIC confirming the elevation or altitude ofthe launch site. The altitude ofthe sUAS will also be displayed via telemetryon the Ground Station and will be constantly monitored by the PIC during the entire flight operation.

10. DronePilotSafetyseeks exemptionfrom the requirements of 14CFR § 

### 91.151(a): Fuel Requirements for Flight in VFR Conditions
This regulation prohibits an individual from beginning "a flight in an airplane underVFR conditions unless (considering wind and forecast weather conditions) there is enough fuel to flytothe first point of intended landing and, assuming normal cruising speed- (1) During the day, to fly afterthatfor at least 30 minutes; or (2) At night, to fly afterthatfor at least 45 minutes."
The different sUAS batteries provide avariety of powered flight times. An exemption from §14 CFR 91.151 is therefore required.
The applicant believes that an exemption from 14 CFR § 91.151(a) is safe and within the scope ofa prior exemption. See Exemption 10673 

### (allowing Lockheed Martin Corporation to operate without compliance with 91.151(a)). Operatingthe sUAS, without 30 minutes of reserve fuel does not promptthetype of risks that Section 91.151(a) was meantto prevent given the size and speed at which the sUAS operates. The fact that it carries no pilot, passenger, orcargo also enhances its safety. In the unlikely eventthatthe battery on the sUAS should run out, itwould simply land. Given its weight and construction material, the risks are less than contemplated by the current regulation.
The applicant believes that an equivalent level ofsafety can be achieved by maintaining 20% of reserve battery, which would be more than adequate to return the sUAS to its planned landing zone from anywhere in its operating area.
The FAA has granted similar exemptionsto others, including Exemptions 2689F, 5745, 10673, 10808, and 11251.


### 11. DronePilotSafetyseeks exemptionfrom the requirements of 14CFR § 

### 91.203 (a) 

### & (b): Carrying Civil AircraftCertification and Registration
This regulation provides as follows:

... no person may operate a civil aircraft unless it has

... an appropriate and current airworthiness certificate. No person may operate acivil aircraft unlessthe airworthiness certificate required by paragraph {a) of 

### 6this section or aspecial flight authorization issued under §91.715 is displayed at the cabin or cockpit entrance so that it is legible to passengers orcrew.
The sUAS fully loaded typically weighs less than 10 lbs., and always less than SSibs. As such, there is no ability or place to carry certification and registration documents orto displaythem on the sUAS. In addition, there is no pilot on board the aircraft.
An equivalent level ofsafety will be achieved by keeping these documents atthe ground control point where the PIC flying the sUAS will have immediate access to them. The FAA has issued numerous exemptions to this regulation. A representative sample ofother exceptions includes Exemption Nos. 9565, 9665, 9789, 9789A, 9797, 9797A, 9816A, 10700, 11251, and 11256. 12. DronePilotSafety seeks exemption from the requirements of 14CFR § 91.405(a); 407(a)(1); 409(a)(1) and (2); 417(a) and (b): Maintenance Inspections
Section 91.405{a) requiresthat an aircraftoperatororowner "shall have that aircraft inspected as prescribed in subpart Eofthis part and shall between required inspections, except as provided in paragraph (c) ofthis section, have discrepancies repaired as prescribed in part43 ofthis chapter

..." Section 91.407 similarly makes reference to requirements in Part 43; Section 91.409(a)(2) requires an annual inspection forthe issuance ofan airworthiness certificate. Section 91.417(a) requires the owner or operatorto keep records showing certain maintenance workthat has been accomplished by certificated mechanics, under Part 43, or licensed pilots and records ofapproval ofthe aircraft for return to service.
The sUAS are nearly maintenance free, they perform automatic pre-flight checks and the failure ofany check will preventtake-off. Checks which cannot be done by the system will be performed by a qualified person priorto each flight and at predefined intervals as part ofa maintenance schedule. Pre-flight checklist includes: Visual inspection ofthe airframe Visual inspections of rotor integrity Check charge ofall batteries (aerial vehicle, command station, radio repeater station)
An equivalent level ofsafety will be achieved because the sUAS is small in size, will carry no external payload, will operate only in restricted predetermined areas and is nota complex mechanical devise. The operatorofthe sUAS will ensure that it is in working order priorto initiatingflight, perform required maintenance, and keep a log ofany maintenance that is performed. Moreover, the operator is the person mostfamiliar with the aircraft and is best suited to maintain the aircraft in an airworthy condition and to ensure an equivalent level ofsafety.
If mechanical issues arise, the sUAS can land immediately due to the pre-determined area ofoperation. Moreover, the sUAS's small size, carrying capacity, and the fact thatflight operations will onlytake place in restricted areas for limited periods oftime, create' less risk than the same factors associated with conventional fixed-wing aircraft and rotorcraft performing the same operation.

Public Interest Approval ofthisexemption for commercial operationswill enhance safety by reducing risk. Use ofthe 

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sUAS in lieu ofa manned aircraft would enhance safety and reduce the environmental impact as compared to similar operations conducted with manned aircraft thatweigh in excess of

### 6,000 lbs., carrying a crew and flammable fuel. Such aircraft must fly to and from the project location. In contrast, a sUAS weighing less than 10 lbs. and powered by batteries, eliminatesvirtually all ofthat risk given the reduced mass and lack ofcombustible fuel carried on board. The sUAS is carried to the target area and notflown. The sUAS will carry no passengers orcrew and, therefore, will not expose them to the risks associated with manned aircraftflights.
In regards to performing inspections ofvarious structures, and natural gas pipelines the sUAS will minimize the risk to persons attemptingto climb these structures and photograph problem areas. Itwill provide away for companies to have their engineers review photographs and provide additional safetyto the general public in regard to structure failure or natural gas pipelines having structural issues. Many of the natural gas pipelinestravel in areas that are hard to reach by vehicle orfoot and ifan area is suspected of having problems the sUAS will allowfor an easier and safer assessment. The sales and training mission ofthe organization will allowthe industryto demonstrate, sale and train future sUAS pilots. 

### Conclusion DronePilotSafety respectfully requests that the FAA grantthe requested exemption and are prepared to modify or amend any part ofthis request to satisfythe need for an equivalent level ofsafety. We look forward to working withyour office. Ifadditional information or clarification is needed, please feel free to contact us.


### DronePilotSafety Thomas Calloway Freeman 747 South Eighth Street Mebane, NC 27302 (919) 619-6828 mailto:tc@dronepilotsafety.com


### Appendices: DJI Phantom 3- Specifications Data Sheet and User Manual link 

### APPENDIX A DJI PHANTOM 3 TECHNICAL SPECIFICATIONS
1.1 DJI Phantom 3
1.1.1 Aircraft 1.1.1.1 Supported Battery- DJI 5200mAH liPo Battery 1.1.1.2 Weight (Battery 

### & Propellers Included)- 21bs 11.810oz (1242g) 1.1.1.3 HoverAccuracy (Ready to Fly)- Vertical: .8m; Horizontal: 2.5m 1.1.1.4 MaxYaw AngularVelocity- 2000/s 1.1.1.5 MaxTilt Angel
- 350 1.1.1.6 MaxAscent Speed- 6m/s 1.1.1.7 Max Descent Speed- 2m/s 1.1.1.8 Max Flight Speed -15m/s (NOT RECOMMENDED) 

### 81.1.2 Gimbal 1.1.2.1 Working Current- Static: 750mA; Dynamic: 900mA 1.1.2.2 Control Accuracy- ±0.030 1.1.2.3 Controllable Range- Pitch: -900- 00 1.1.2.4 MaximumAngular Speed- Pitch: 900/s 1.1.3 Camera 1.1.3.1 OperatingTemperature Range- 320F- 1040F (OOC- 400C) 1.1.3.2 Sensor Size -1/2.3" 1.1.3.3 Effective Pixels -14M 1.1.3.4 Resolution- 4384x3288 4.1.3.5 HD Video Recording- 1080p30 

### & 720p 1.1.4Transmitter 1.1.4.1 Operating Frequency- 5.728GHz- 5.85GHz 1.1.4.2 Communication Distance (unobstructed)- FCC Compliance: BOOm 1.1.4.3 Receiver Sensitivity (1%PER)
- -93dBm 1.1.4.4Transmitter Power- FCC Compliance: lOOmW 1.1.4.5 WorkingVoltage- 120mA@3.7V 1.1.5 Range Extender 1.1.5.1 Operating Frequency- 2412-2462MHz 1.1.5.2 Communication Distance (unobstructed)- 500-700m 1.1.5.3 Transmitter Power- 20dBm 1.1.5.4 Power Consumption- 2W



### DJI Phantom 3- User Manual Link http://www.dji.com/product/phantom-3/download

Application CommentTracking Number: 1jz-8mw6-7syj

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