### North Georgia Drones, LLC

1760 Loblolly Lane
Cumming, GA 30041

770

- 330

- 7382 stan.jessen@outlook.com

August 12 , 2015

U. S. Department of Transportation Docket Management System
1200 New Jersey Ave., SW Washington, DC 20591

This letter is in response to a FAA letter dated August 3, 2015, requesting additional information that is needed to process my Section 333 request for an exemption entered into public docket (No: FAA

- 2015

- 1740).

The letter states tha t my submission does not comply with § 

### 11.81 and request the following:

 The reasons why granting the exemption would not adversely affect safety, or how the exemption would provide a level of safety at least equal to that provided by the rule from which y ou seek the exemption.

 Any additional information, views or arguments available to support your request.

This document uses the following abbreviations for brevity:

NGD North Georgia Drones

DJI Refers (only) to the three s UAS devices listed in our exemption request

DGI Phantom 2 Vision Plus

DGI Phantom 3

DGI Inspire 1

The FAA has previously granted exemptions to each Title 14 CFR mentioned in the NGD request for exemption document. Rather than putting this detail in our original document we referenced five exemptions that had been previously granted by the FAA and were similar to our request. Our assumption was that these exemptio ns set a precedent and that need for relief and safety issues had been accepted by the FAA. We felt this would simpl ify the exemption process for NGD and the FAA. Since this is not the case, t he informati on you requested follows...

### The Reasons Why Granting The Exemption Would Not Adversely Affect Safety, Or How The

Exemption Would Provide A Level Of Safety At Least Equal To That Provided By The Rule From
Which You Seeks Exemption.

1. 

### § 61.23(a) and (c) Medical certificates: Requirement and duration 

### § 61.101 (e)(4) and (5) Recreational pilot privileges and limitations 

### § 61.113 (a) and (b) Private pilot privileges and limitations: Pilot in command. 

### § 61.315 (a) What are the privileges and limits of my sport pilot certificate?

N GD request relief from the medical and pilot license requirements in these sections. We request that a sports pilot’s certificate and U.S. driver’s license be sufficient for s UAS pilots to work for compensation.

. Allowing sports pilot s to operate UAS aircraft for hir e represents less risk than a sport pilot in a manned aircraft,

 All NDG flights will be supported by an observer who is capable of operating the UAS. If the PIC releases the remote control, the s UAS used by NGD will hover in place. This provides an opport unity for someone (the observer or other) to take control.

 Worse case is that the s UAS runs low on power and lands itself.

 In the unlikely event the s UAS experiences an uncontrolled crash, the size, weight and lack of flammable fuel make if extremely unlikel y for the UAS to cause serious harm to damage.

 B ecause the s UAS takes off and lands at the operation site, there is no transit exposure to and from an airport

NGD submits that the equivalent level of safety established by these sections will be maintained because no PIC will be allowed to operate the NGD s UAS unless that PIC has demonstrated, by meeting minimum flight

- hour and currency requirements, that the PIC is able to safely operate the

s UAS in a manner consistent with the exemption , including evasive and emergency maneuvers and maintaining appropriate distances from people, vessels, vehicles and structures.

M anned pilot experience does not correlate to the airmanship skills necessary for NGD ’s specific proposed flight operations. NGD will not allow any PIC to operate a s UAS unless that PIC has demonstrated, by meeting minimum fligh t

- hour requirements of the s UAS they are operating and, training and currency requirements, that the PIC is able to safely operate it in a manner consisten t with this exemption, including evasive and emergency maneuvers and maintaining appropriate distances from people, vessels, vehicles and structures.

2. 

### § 91.7 (a)

- Civil aircraft airworthiness

No standards exist for airworthiness certificates for s UAS. The size, weight and lack of flammable fuel make it unlikely that s UAS accident would cause serious harm or damage.

The equivalent level of safety established by Section 91.7(a) will be maintained because prior to every flight, NGD will ensure that the s UAS is in an airworthy condition based upon DGI documents for the applicable s UAS.3. 

### § 91.119

- Minimum safe altitudes

This section established minimum safe altitudes for civil aircraft. Aircraft cannot fly below 500 feet

over water or sparsely populated areas. Higher minimums are specified for over populated areas.

Relief is requested is necessary since aircraft in sUAS category are required by the FAA to must remain below 500 feet. Also many sUAS operations take place in close proximity to structures (such tower/brid ge inspections).

Equivalent safety is achieved from the size, weight and speed of the UAS. Also no flight is taken without permission from the property owner. Since the PIC is on the ground and accompanied by an observer, it is easy to see people and ob jects, and avoid them.

4. 

### § 91.121

- Altimeter settings

The NGD UAS do have a barometric altimeter. However, because UAV missions are below 500 feet, the primary concern is AGL as measured from the GPS altitude at take

- off . In this low
altitude environment a higher degree of safety is provided by GPS AGL then barometric altitude.

5. 

### § 91.151(a)(1)

- Fuel requirements for flight in VFR conditions

UAV have flight endurances in the 15

- 25 range, making it impossible to meet these requirements.

However, grant of thi s exemption would ensure an equivalent level of safety established by 

### § 91.151. Because the s UAS is within line

- of

- sight, most if the time never more than a few minutes from its takeoff point. Also, the size of the s UAS allows it to land in places a manned aircraft c ould not consider. NGD requires missions to land with 20% power rema ining.

6. 

### § 91.405(a) Maintenance required 

### § 91.407(a)(1) Operation after main tenance, preventive maintenance... 

### § 91.409 (a)(1) and (2) Inspections 

### § 91.417(a) and (b) Maintenance records

The maintenance and inspections of 

### § 91 are not applicable to sUAS. FAA certified sUAS mechanics
does not exist. The modular construction of s UAS means that entire components (engine, props, flight computer...) are easily replaced, rather than doing major repairs. Also sUAS are frequently reconfigured with different sensors an d payloads that do not impact airworthiness.

To get an equivalent level of safety, NGD uses manufactures manuals and recommendations in concert with frequent inspections. In addition to pre

- flight and post

- flight inspections, our sUAS undergo a detailed i nspected every 20 flight or 4 months, whichever comes fir st. The multi

- rotor

s UAS’s are mechanically very simple devices. The only moving parts are the motor/propellers.
However, t hese devices are electronically very complex. This inspection involves removing all

covers so that all conne ctions and wires can be viewed.

All maintenance /inspections are logged. Work in critical systems must be signed off by quality. In addition, detailed inspections and any work on critical systems require a FTF (function test flight) buy a senior PIC. While not completed, NGD is developing a software application to help manage maintenance task and battery usage.

### Any Additional Information, Views, Or Arguments Available To Support Your Request.

This Petition is made pursuant to the FAA Modernization and Reform Act of 2012 (FMRA) Section 333, which directs the Secretary of Transportation to determine if certain UAS may operate safely in the NAS. It is our option that s UAS operations can be very safe. The keys to safety are qualified PICs and

maintenanc e. We are concerned about the recent bad publicity that sUAS has received. Virtually all
this is due to undisciplined use of s UAS by hobbyist . I have yet to hear of an issued with a Section 333 exempted organization. We completely agree with the need fo r UAS pilots to be familiar with the NAS

.



### Sincerely,

Stan Jessen