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U.S. Department of Transportation 

Docket Management System 

1200 New Jersey Avenue, S.E. West Building Ground Floor, Room W12-140 

Washington, DC 20590 

RE: Docket ID: 

Petition for Modification of current FAA Exemption No. 16513, Docket No. FAA-2015-

7472 under Section 333 of the FAA Modernization and Reform Act and Part 11.81 of the 

Federal Aviation Regulations (Tracking ID Number: _____)

17 August 2016

Petitioner: 

Drone Co-Habitation Services (DCS)

2110 Raven Tower Court #301,

Herndon, VA 20170

Tel: 571-216-3245

E-Mail: me98@yahoo.com

Attachments (Confidential):

1. DCS UAV Operator Safety Guidelines

2. DCS Sample Monthly Maintenance Log

3. Example of DCS-NASA sUAS Hazard Analysis

4. uAvionix ping2020 Wireless Certification

5. uAvionix Quickstart Guide

6. uAvionix ping2020 Data Sheet

7. uAvionix ping2020 Integration Guide

Dear U.S. Department of Transportation, 

On behalf of Drone Co-Habitation Services, LLC (hereinafter called DCS), company which I 

own and am President for, I contact you.

DCS seeks Amendment/Modification to our current FAA Commercial Usage sUAS 

Section-333 Exemption related to 14 CFR 91.215 to allow uAvionix ping2020 Universal 

Access Transceiver-UAT (ADS-B). The uAvionix ping2020 UAT was designed to and behaves 

per RTCA DO-144A.

On 22 April 2016, FAA Granted DCS a Section-333 Exemption (No. 16513), based upon our 

Petition of 8Oct2015 (Docket No. FAA-2015-7472). Some of the FAA Conditions of our 

Exemption included (examples; NOTAL): It granted us Exemption to use any aircraft identified 

on the List of Approved Unmanned Aerial Systems (UAS) under Section-333 at regulatory 

docket FAA-2007-3330...when weighing less than 55-pounds including payload, in nationwide 

COA. In that Exemption, FAA stated requirements for PIC Certification, and Qualifications. It 
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restricted our UA operations to at-or-below 400-Feet AGL, and at speed not exceeding 87-knots 

(100-miles per hour).

We do NOT desire to reduce or delete any of our currently FAA-approved Section-333 

Exemptions with regard to our Scope of Activities described in that previous Petition. However, 

we do seek Amendment to our Exemption to allow expansion of our Section-333 Exemption to 

include installation, integration, and usage of uAvionix ping2020 Universal Access TransceiversUAT (ADS-B) across our entire fleet of small UAS (sUAS) aircraft.

INTRODUCTION AND INTERESTS OF THE PETITIONER

Drone Co-Habitation Services (DCS) is a sister organization of Aviation Management Inc., LLC 

(AMI). Both companies are Delaware-incorporated, Veteran-Owned Small Businesses (VOSB). 

Both are government registered in SAM.gov. DCS and AMI are owned and led by Michael 

Erickson, who is a retired, FAA-certified, Marine Corps Air Traffic Control-ATC Chief that held 

FAA-certified ATC Ratings in Control Tower, GCA, and Radar Approach Control (RAPCON) 

at military and dual Civil/Military Facilities in CONUS/OCONUS for over nineteen years. Mr. 

Erickson graduated from not only the Navy ATC School and ATC Facility Management 
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Courses, he also graduated from USAF and Army Aviation Command & Staff Courses. Mr. 

Erickson holds a Bachelor’s Degree in Aviation Management from SIU. All senior managers of 

DCS and AMI are retired or former ATC Controllers or Aviator Pilots.

Mr. Erickson and AMI have conducted FAA-based NextGeneration CNS/ATM Master Planning 

studies in most Asian countries, and supported Aviation Master Planning technology seminars 

sponsored by USTDA and Japan’s equivalent JICA/JBIC. These aviation-related Master Plan 

Studies and Implementation Planning consultations have been performed in Philippines; 

Indonesia; Malaysia; Vietnam; Cambodia; Lao; Nepal; China; Mongolia and others. 

Additionally, AMI has captured aviation-related US Defense Contracts at Military bases such as 

USAF-Laughlin, TX; USAF-Sheppard, TX; USAF-McGuire, NJ; USAF-Charleston, SC; USAFDyess, CA; USAF-Hurlburt, FL; USAF-Yokota, Japan; etc. These involved projects related to 

such things as ATC Equipage; Passenger Terminal Design & Fabrication; Airfield Lighting & 

Navigational Aids; etc.

For the past 13-years, AMI and Mr. Erickson have provided their clients (which include private 

sector businesses and non-profits, along with local state and federal agencies) with expertise and 

knowledge in ATC procedures, Airspace Reorganization; Flight Procedures to include Standard 

Instrument Departures/Arrivals; Performance Based Navigation-PBN; business development, 

and other aviation related technical training using advanced technologies and solutions. AMI has 

worked on dozens of aviation projects over the past 13-years, in all types of locations, with a 

perfect client and employee safety record. Mr. Erickson was formerly the Secretariat of Airline 

Electronic Engineering Committee (AEEC), when working at ARINC on FAA-approved 

Standards & Characteristics development for aircraft cockpit avionics. Further, he supported 

FAA for the Controller-Pilot Data Link Communications (CPDLC) Build-1/1A rollout 

nationwide, and supplied FAA with Ground-Air and Ground-Ground CPDLC End Systems and 

ATN Routers. Thus, AMI and Mr. Erickson...and through him....DCS are clearly experts in all 

matters of FAA Airport and ATC Procedures.

In 2015, Mr. Erickson created Drone Co-Habitation Services, LLC (DCS, for short) to focus our 

ATC expertise on providing aviation and ATC consulting support to the Unmanned Aerial 

Vehicle (UAV) industry, to facilitate safe integration of UAVs into the FAA-controlled National 

Airspace System (NAS). Although DCS is newly-formed, because of the close synergy between 

the Management & Practices of DCS with that of AMI company, and the decade-long historical 

business success of AMI, it is important to demonstrate that DCS will be operated the same way 

that AMI has been operated...in safe and professional manner. DCS, supported by AMI, 

currently has several Proposals under consideration by NASA-Ames for the FAA-sponsored 

UAV Traffic Management (UTM) Program.

The objective of DCS (supported by AMI) activities in the UAV-sector is to leverage our 

decades of direct ATC experience towards facilitating safe and methodical encroachment of 

UAVs into the communities that can benefit from such proliferation. We aspire to facilitate and 

guide private industry and Government in their UAV procedures development, Research & 

Development (R&D) of UAV technologies and platforms, and provide consulting support in 

their UAV deployments. We are currently in the process of creating multi-stakeholder (Public & 

Private) UAV Centers of Excellence (COE) to accomplish this UAV consulting support.
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DCS seeks to promote and expand knowledge for the science and art of UAVs. Our Operators, 

staff, and students of our consulting will use our Exemption and Certificates of Waiver or 

Authorization (COAs) to create new UAV systems, developing flight operations, and 

standardizing procedures that will move UAS activity into human daily life. Application of UAS 

will span an expansive range of purposes, including agriculture, traffic monitoring, 

environmental monitoring, search/rescue operations, customs payload scanning, immigration 

enforcement, pipeline/power lines monitoring, firefighting service, sport casting, cellular 

networking, meteorological services/research, fisheries monitoring, law enforcement, and 

entertainment. Eventually, when allowed by FAA, we aspire to deploy Commercial UAVDrones in performance of Logistics and Parcel Delivery Services.

Details of our Section-333 Exemption Modification Request

The uAvionix ping2020 UAT system (which we Petition for usage) retains the hardware in 

basically same box (minus final stage High Gain Amplifier), software, firmware, & hardware 

(DO-178B / DO-254) of other Certified (TSO’d) UAT product lines, but at a reduced (detuned) 

transmit power setting and significant size and weight savings. It exhibits the same waveform 

characteristics as the TSO’d versions of UATs being sold around USA.

(Please see attached Wireless Testing Report)...The EUT model listed were tested utilizing the following 

documents and found to be in compliance with the required criteria.

Professional Testing (EMI), Inc., (PTI): Testing Processes:

EUT User Control Requirement

Power is removed at the aircraft operator’s position by the user either removing power from the

EUT itself or from the vehicle power plug at the end of the power cable. This satisfies control

requirements of FCC 87.143.

EUT Operation

The EUT was exercised in a manner consistent with normal operations. To insure accurate

measurement, the EUT was placed into higher than normal duty cycle modes or even briefly in

continuous transmit mode. Continuous 100% duty cycle transmit was limited to only a few

seconds as the transmitter would otherwise overheat.
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Modifications to EUT

Transmitter output matching network components were adjusted to better suppress harmonic

spurious emissions. The top plastic cover was coated with a conductive paint to reduce radiated

spurious emissions.

Test Site

Radiated measurements were made at the PTI semi-anechoic facility designated Site 45 (FCC

459644, IC 3036B-1) in Austin, Texas. The site is registered with the FCC under Section 2.948

and Industry Canada per RS-GEN, and is subsequently confirmed by laboratory accreditation

(NVLAP). The test site is located at 11400 Burnet Road, Austin, Texas 78758, while the main

office is located at 1601 North A.W. Grimes Boulevard, Suite B, Round Rock, Texas, 78665.

Professional Testing (EMI), Inc., (PTI) follows the guidelines of National Institute of 

Standards and Technology (NIST) for all uncertainty calculations, estimates, and expressions 

thereof for electromagnetic compatibility testing.

Applicable Documents:
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Any antenna certified to TSO-C66, TSO-C74, TSO-C112 with a peak gain of 4 dBi or less, an 

omni-directional radiation pattern, and a VSWR of 1.8 or less at 978MHz is approved for use 

with this device and will ensure conformance to all applicable standards for RF emissions.

Modifications and use outside of intended scope

This device has been design and tested to conform to all applicable standards in the original form 

and when configured with the components shipped with the device. It’s not permissible to 

modify the device, use the device for any use outside of the intended scope, or use the device

with any antenna other than the one shipped with the device.

Important Pilot Advisory Note Regarding Safety of Radio Frequency Energy

Safe use of this device requires care as to the placement of the antenna. Place the antenna at least 

4cm away from any part of your body or that of other cabin occupants. To stop all RF emissions, 

remove power from the equipment. Only handle the antenna when power is disconnected.
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Advise personnel to avoid contact with the antenna while power is applied to the equipment. 

Retain these instructions with your maintenance logs/files and for future reference.

FCC RF Radiation Exposure Statement

This equipment complies with FCC RF radiation exposure limits (Table 1 of 47Pt1 (i) 1.1310) 

set forth for a Public/Uncontrolled environment.

Our Concept of Usage:

 UAV GPS

 factory installed inside the top of the DJI P3P

 number of satellites and signal quality shown on iOS apps

 used to display UAV position on iOS apps for use by GCSO and PIC

 UAT GPS

 ping Nav mounted on “tail” to avoid interference with UAV

 supplies position to ping2020 UAT, which transmits to ADS-B receiver for 

position reporting to NASA-UTM

ADS-B:

 Primary:

• uAvionix Universal Access Transceiver-UAT operating as a 

Receiver...or...Freeflight Systems UAT module operating as Receiver

• Connected to and powered from PC via USB micro-A cable and maintenance 

dongle

 

 Backup

• uAvionics UAT (ADS-B) Receiver pingUSB

• Connected and powered from PC vis USAB cable

• Maintained via serial terminal application (TeraTerm) command line interface

Example of Integration Aboard DJI Phantom sUAS:

https://developer.dji.com/onboard-sdk/documentation/sensor-integrationguides/ping/README.html
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The uAvionix ping2020 UAT equipment is fully compatible with the Harris ADS-B Ground 

Stations. For example, we have separate UAT receivers to connect directly to the Drone CoHabitation Sevices UTM Client application allowing the parsing the traffic data independently of 

the Harris ADS-B system during our NASA-UTM Trials.

This Petition for Amendment/Modification contains competition-sensitive business plans as 

to operations, techniques for mitigating safety, and planned sUAS equipment; therefore, we 

ask FAA not to publish it for public viewing or dissemination.

DCS seeks to leverage our current Section-333 Exemption Grant to promote and expand 

knowledge for the science and art of UAVs. Our Operators, staff, and students of our consulting 

will use our Exemption and Certificates of Waiver or Authorization (COAs) to create new UAV 

systems, developing flight operations, and standardizing procedures that will move UAV activity 

into human daily life. Our planned application of UAVs will also span an expansive range of 

purposes, including closed-set photography & movie-making, fixed/permanent building and 

structure inspections, agriculture, traffic monitoring, environmental monitoring, search/rescue 

operations, customs payload scanning, immigration enforcement, pipeline/power lines 

monitoring, firefighting service, sport casting, cellular networking, meteorological 

services/research, fisheries monitoring, law enforcement, and entertainment.

On 22 April 2016, FAA Granted DCS a Section-333 Exemption (No. 16513), based upon our 

Petition of 8Oct2015 (Docket No. FAA-2015-7472). Some of the FAA Conditions of our 

Exemption included (examples; NOTAL): It granted us Exemption to use any aircraft identified 

on the List of Approved Unmanned Aerial Systems (UAS) under Section-333 at regulatory 

docket FAA-2007-3330...when weighing less than 55-pounds including payload, in nationwide 

COA. In that Exemption, FAA stated requirements for PIC Certification, and Qualifications. It 

restricted our UA operations to at-or-below 400-Feet AGL, and at speed not exceeding 87-knots 

(100-miles per hour).

We do NOT desire to reduce or delete any of our currently FAA-approved Section-333 

Exemptions with regard to our Scope of Activities described in that previous Petition.

However, we do seek Amendment to our Exemption to allow expansion of our Section-333 

Exemption to include deployment of this uAvionix ping2020 UAT across all sUAS Platforms 

and missions that will benefit from such ADS-B capability towards Air Traffic Control-ATC 

Facilities to enhance Air Traffic Management-ATM.

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the Reform Act) 

Drone Co-Habitation Services (DCS) seeks exemption from Federal Aviation Administration 

(FAA) for part 21, and §§ 91.113, 91.119(c), 91.151, 91.203(a)(1), 91.209, 91.405(a) and (b), 

91.407(a)(1), 91.409(a)(1) and (2), and 91.417(a) of Title 14 Code of Federal Regulations (14 

CFR). The exemption would allow the petitioner to operate the uAvioix ping2020 UAT

equipment installed and operated aboard any unmanned aircraft system (UAS), or other suitablycomparable and safety-equipped Drones from the FAA Approved List of Drones. The missions 
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that may use this UAT Transceiver may include Parcel Delivery, Building Inspections, Research 

& Development (R&D), Platform and System Testing & Trials, generating Community 

Economic Benefit, conducting aerial video and photography of surface mining sites, construction 

sites, residential and commercial real estate, civil landscapes and events, closed-set Movie and 

Picture Filming & Cinematography, etc. areas of the United States. It would also facilitate our 

pursuit of FAA Approval to conduct Logistics & Parcel Delivery by sUAS Platforms.

Specifically, it would grant Exemption from 14 CFR 91.215(a), specifically with regard to 

the TSO for a transponder. 

91.215 ATC transponder and altitude reporting equipment and use. 

(a) All airspace: U.S.-registered civil aircraft. For operations not conducted under part 121 

or 135 of this chapter, ATC transponder equipment installed must meet the performance 

and environmental requirements of any class of TSO-C74b (Mode A) or any class of TSOC74c (Mode A with altitude reporting capability) as appropriate, or the appropriate class of 

TSO-C112 (Mode S). 

(b) All airspace. Unless otherwise authorized or directed by ATC, no person may operate an 

aircraft in the airspace described in paragraphs (b)(1) through (b)(5) of this section, unless that 

aircraft is equipped with an operable coded radar beacon transponder having either Mode 3/A 

4096 code capability, replying to Mode 3/A interrogations with the code specified by ATC, or a 

Mode S capability, replying to Mode 3/A interrogations with the code specified by ATC and 

intermode and Mode S interrogations in accordance with the applicable provisions specified in 

TSO C-112, and that aircraft is equipped with automatic pressure altitude reporting equipment 

having a Mode C capability that automatically replies to Mode C interrogations by transmitting 

pressure altitude information in 100-foot increments. This requirement applies—

(1) All aircraft. In Class A, Class B, and Class C airspace areas; 

(2) All aircraft. In all airspace within 30 nautical miles of an airport listed in appendix D, 

section 1 of this part from the surface upward to 10,000 feet MSL; 

(3) Notwithstanding paragraph (b)(2) of this section, any aircraft which was not 

originally certificated with an engine-driven electrical system or which has not subsequently 

been certified with such a system installed, balloon or glider may conduct operations in the 

airspace within 30 nautical miles of an airport listed in appendix D, section 1 of this part 

provided such operations are conducted—

(i) Outside any Class A, Class B, or Class C airspace area; and 

(ii) Below the altitude of the ceiling of a Class B or Class C airspace area 

designated for an airport or 10,000 feet MSL, whichever is lower; and 

(4) All aircraft in all airspace above the ceiling and within the lateral boundaries of a 

Class B or Class C airspace area designated for an airport upward to 10,000 feet MSL; and 

(5) All aircraft except any aircraft which was not originally certificated with an enginedriven electrical system or which has not subsequently been certified with such a system 

installed, balloon, or glider—

(i) In all airspace of the 48 contiguous states and the District of Columbia at and 

above 10,000 feet MSL, excluding the airspace at and below 2,500 feet above the 

surface; and 
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(ii) In the airspace from the surface to 10,000 feet MSL within a 10-nautical-mile 

radius of any airport listed in appendix D, section 2 of this part, excluding the airspace 

below 1,200 feet outside of the lateral boundaries of the surface area of the airspace 

designated for that airport. 

(c) Transponder-on operation. While in the airspace as specified in paragraph (b) of this section 

or in all controlled airspace, each person operating an aircraft equipped with an operable ATC 

transponder maintained in accordance with §91.413 of this part shall operate the transponder, 

including Mode C equipment if installed, and shall reply on the appropriate code or as assigned 

by ATC.

We request Exemption during the period of our COA Approval (and extensions of time therein) 

because (Specifications noted herein):

1. The evidence indicates that the uAvionix ping2020 UAT has internal WAAS/GPS 

Sensors.

2. Provides ADS-B IN / OUT.

3. Is TSO Rule Compliant: The UAT provides a complete ADS-B system via an internal 

GPS and baro-altimeter, allowing the UAS to fully integrate into the National Airspace System. 

The receive functionality of the FCU allows the UAS to take full advantage of ADS-B In 

benefits, including local traffic and weather data. The compact Radar Altimeter, is a light weight, 

low-power radar altimeter tailored for UAS applications.

4. Meets FAA Design Assurances

* DO-178B Level C (Software)

* DO-254 Level C (Hardware)

5. The DO-282b MOPS defines Class A0 which supports a minimum transmit power at 

the antenna of 7 watts. The UAT is MOPS compliant.

6. The UAT passed all box and platform level testing using the Ramp Test Set. The 

AERamp Test Set was within its calibration window for all tests. 

7. The UAT has been used for several years; been integrated, tested, and passed the 

NASA-UTM Airworthiness & Flight Safety Review Board (AFSRB) Review, and is currently 

undergoing similar AFSRB Review for UTM Build-2 Trials in October 2016 by numerous 

Testing Teams. In such configuration, NASA is able to interrogate and receive Digital Data from 

the sUAS Drones, and transmit them effectively to the ATC Facilities associated with each of 

these UTM Trials to receive Air Traffic Control Services.

8. All usage to date in those environments indicates that the UAT behaves as expected 

per DO-Certification processes.

9. uAvionix and independent testing laboratories (as noted above), and that of our Drone 

Co-Habitation Services operational testing, has shown that the FAA Air Traffic Control services 

will be able to receive the correct ATC data.

10. Although a transponder is not required in most commercial sUAS airspaces that we 

will operate in, a transponder will enhance the safety of the proposed operation by providing

additional “visibility” of our UAV-Drones not only to ATC Facilities, but also to other aircraft in 

the proposed flight region. 

11. Drone Co-Habitation Services will utilize the UAT Transceivers under very close 

scrutiny and within our highly-detailed Aviation Safety Management System (SMS) processes.
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The reasons why granting your request would be in the public interest; that is, how it 

would benefit the public as a whole:

An additional “layer” of safety offered by use of the UAT Transceivers would contribute to a 

safer flight environment. Where local air traffic control possesses radar coverage, our UAVDrones will display on that radar; the aircraft will provide a distinct target for ATC. Plus, we will 

provide direct Controller-Pilot Communications (albeit in most cases, via Digital Datalink) with 

local ATC. Thus, our pilots, upon direction by ATC, can alter our flight pathway as needed to 

avoid other aircraft traffic. 

For properly equipped aircraft, the Drone Co-Habitation Services sUAS aircraft with our 

Transceiver will show on their displays, providing additional situational awareness for those 

aircraft.

Similar to FAA previously-approved Exemption for Boeing/Insitue to integrate and deploy an 

experimental, non-TSO Certified transponder manufactured by SageTech...our DCS company 

desires to use our uAvionix ping2020 UAT Transceivers.

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 seek the exemption:

Since the evidence indicates that the uAvionix ping2020 UAT Transceiver behaves per the 

performance expectations cited in DO-Certifications, there is no adverse impact to safety. 

Indeed, adding the transponder should produce added safety benefit to all aviation participants in 

the identified locality of our Flight Operations.

We propose to conduct these UAT & Transponder operations with our already-established 

Operations Manual (OM), that may be modified to comply with FAA Exemption, and which 

contains (at least) these items:

a. Operator name, address, and telephone number.

b. Distribution and Revision. Procedures for revising and distributing the operations 

manual to ensure that it is kept current. Revisions must comply with the applicable conditions 

and limitations in this exemption.

c. Persons Authorized. Specify criteria for designating individuals as directly 

participating in the safe operation of the UAS. The operations manual must include procedures to 

ensure that all operations are conducted at distances from persons in accordance with the 

conditions and limitations of the exemption.

d. Plan of Activities. The operations manual must include procedures for the submission 

of a written plan of activities.

e. Permission to Operate. The operations manual shall specify requirements and 

procedures that the operator will use to obtain permission to operate over property or near 

vessels, vehicles, and structures in accordance with this exemption.

f. Security. The manual must specify the method of security that will be used to ensure 

the safety of nonparticipating persons. This should also include procedures that will be used to 
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stop activities when unauthorized persons, vehicles, or aircraft enter the operations area, or for 

any other reason, in the interest of safety.

g. Briefing of persons directly participating in the intended operation. Procedures must be 

included to brief personnel and participating persons on the risks involved, emergency 

procedures, and safeguards to be followed during the operation.

h. Personnel directly participating in the safe operation of the UAS Minimum 

Requirements. In accordance with this exemption, the operator must specify the minimum 

requirements for all light personnel in the operating manual. The PIC at a minimum will be 

required to meet the certification standards specified in this exemption. 

i. Communications. The operations manual must contain procedures to provide 

communications capability with participants during the operation. The operator can use oral, 

visual, or radio communications as along as the participants are apprised of the current status of 

the operation. 

j. Accident Notification. The operations manual must contain procedures for notification 

and reporting of accidents in accordance with this exemption. 

We will notify the FAA Flight Standards District Office (FSDO) at least 24-72 hours prior to our 

conduct of these nighttime operations (depending upon ATC Facility requirements in the area of 

flight operations). We will submit a Plan of Activities that includes at least the following: 

a. Dates and times for all flights. For seasonal or long-term operations, this can include 

the beginning and end dates of the timeframe, the approximate frequency (e.g. daily, every 

weekend, etc.), and what times of the day operations will occur. A new plan of activities must be 

submitted prior to each season or period of operations. 

b. Name and phone number of the on-site person responsible for the operation. 

c. Make, model, and serial or N-Number of each UAS to be used. 

d. Name and certificate number of each UAS PIC involved in the operations. 

e. A statement that the operator has obtained permission from property owners. Upon 

request, the operator will make available a list of those who gave permission. 

f. Signature of exemption holder or representative stating the plan is accurate. 

g. A description of the flight activity, including maps or diagrams of the area over which 

operations will be conducted and the altitudes essential to accomplish the operation. 

Regarding, 14 CFR part 21, Certification procedures for products and parts. In accordance with 

the statutory criteria provided in Section 333 of PL 112-95 in reference to 49 USC 44704, and in 

consideration of the size, weight, speed, and limited operating area associated with the aircraft 

and their operation, the Secretary of Transportation has already determined that these aircraft 

meet the conditions of Section 333 and that an airworthiness certificate is not required. 

Therefore, the FAA has previously found that the requested relief from 14 CFR part 21 and any 

associated noise certification and testing requirements of part 36 is not necessary.

We request relief from 14 CFR §91.113 Right-of-way rules: Except water operations since there 

will be no pilot in the UA to “see and avoid” other aircraft. Section 91.113(b) requires a pilot to 

maintain vigilance “so as to see and avoid other aircraft.” That section requires an aircraft pilot 

to have the perspective of being inside the aircraft, something that is not possible for the operator 

of a small UAS at this time. See 80 Fed. Reg. 9544, 9549 (Feb. 23, 2015) (Proposed Rule: 

Operation and Certification of Small [UAS]).
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The FAA has previously Granted Exemption to Boeing/Insitu company for exactly this same 

type of Exemption request, with the Boeing/Insitu deployment of a non-TSO Certified 

Transponder.

We propose to conduct our operations with suitably-equipped sUAS from the FAA’s Approved 

List (e.g. DJI Phantom-3/4 Pro).

DCS request relief from the following sections 14 CFR §§ 91.405(a) Maintenance required, 

91.407(a)(1) Operation after maintenance, preventive maintenance, rebuilding, or alteration, 

91.409(a)(2) Inspections, and 91.417(a) and (b) Maintenance records. The FAA has already 

determined that relief from § 91.409(a)(1) may be necessary, because it is an alternate inspection 

requirement of 91.409(a)(2). Prior UAS specific relief has been granted in Grant of Exemption 

No. 13465A, Kansas State University. Therefore, we ask FAA to find that for our Petition, 

exemption from 14 CFR §§ 91.405(a), 91.407(a)(1), 91.409(a)(1) and (2), and 91.417(a) and (b) 

is warranted subject to any appropriate conditions and limitations FAA feels necessary.

We feel that the below-described Petition with our proposed operations satisfy the seven factors 

in section 333 and include several additional mitigating factors to ensure the safety and security 

In addition, in light of the FAA’s recent sUAS Notice of Proposed Rulemaking 

(“NPRM”)(15Feb2015), DCS believes that the operating conditions set forth in our original 

Exemption Request, as well as this Request for Modification, constitute “reasonable mitigation” 

for Transponder-based operations that would ensure that DCS maintains an equivalent level of 

safety and requests that the FAA consider such mitigation to grant DCS’ Exemption Request and 

permit DCS’ flights. The information below is intended to amend and supplement DCS’

Exemption request.

Please see attached below, our Hazard Safety Analysis Summary that is being reviewed by 

NASA-UTM Airworthiness & Flight Safety Review Board (AFSRB):
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It is not currently possible to install UAT Transceivers on all FAA-Approved sUAS (because 

many sUAS Drones cannot hold the extra weight). However, if FAA will Grant DCS Exemption 

to fly more/wider-selection of sUAS with these uAvionix ping2020 UAT Transceivers, then we 

will commit to testing UATs on more types of sUAS Platforms.
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 As noted above, and in our original Section-333 Exemption, our Operations Manual will 

include at least these items:

 Contact information

 Distribution and revision information

 Persons authorized

 Plan of activities

 Permission to operate

 Security methodology

 Briefing instructions

 Flight personnel minimum requirements

 Communications information

 Accident notification plan

Allowing DCS to conduct real-world UAV Operations and Testing using these UAT 

Transceivers can be important first steps towards safe introduction of UAV operations into the 

Air Traffic Management (ATM) activities of the National Airspace System (NAS) that is desired 

by FAA and NASA-ATM Program Office. Further, it can be important first steps toward 

realizing the consumer benefits of using UAS for private-sector economic growth. These DCS

proposed UAV activities will take place amid conditions that would be impossible to create at 

any pre-approved COA or Test Site.

To ensure utmost safety, DCS will limit the likelihood of hazard (as noted above) to the general 

public on the ground and in the air by adhering to its UAV Operations Manual(s); and complying 

with all conditions and limitations contained in a Grant of the relief sought, and all instructions 

from the FAA and the official(s)-in-charge of or having authority over a particular area and 

airspace.

There Are No Privacy Issues.

Similar to the manned aerial acquisition flight operations that have been conducted with various 

types of Transponders for decades, DCS’ proposed operation of the UAVs will not implicate any 

privacy issues. Specifically, our UAVs will be operated only in compliance with operating 

documents (i.e., Aerial Operations Manual, Monthly Maintenance Log, and Instruction Manuals) 

which requires property owner involvement as well as local law enforcement notification, and in 

accordance with the Federal Aviation Regulations, including the minimum altitude requirements 

of 14 C.F.R. § 91.119.

A summary that can be published in the Federal Register, stating: 

(1) The rule from which you seek the exemption; and Drone Co-Habitation Services requests an 

exemption to 14 CFR 91.215(a) for a transponder authorization.

(2) A brief description of the nature of the exemption you seek; 

Drone Co-Habitation Services, LLC seeks to use uAvionix ping2020 Universal Access 

Transceivers-UATs; evidence indicates that the equipment behaves per the performance 

expectations cited in RTCA DO-Certification documents. Allowing our small UAV-Drone 
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aircraft to use the uAvionix ping2020 UAT equipment will increase the operational safety of the 

proposed flight operations.

Respectfully,

Michael J. Erickson

President, Drone Co-Habitation Services (DCS)

President, Aviation Management Inc., LLC (AMI)