ynomic Ae:orospoce:o Te:ochnoloqil?s DynAeroTech Section 333 Exemption Request 9275 N. Union Blvd, Suite 140-206, Colorado Springs CO 80920 (719) 596-9777 http: //www.dynaerotech.com 1

24August 2015 United States Department ofTransportation Docket Management System 1200 New Jersey Avenue SE Washington, DC 20590 Filed atwww.regulations.gov SUBJECT: Petition for exemption under Section 333 ofthe FAA Reform Act and Part 11 ofthe Federal Aviation Regulations to allow use of small unmanned aerial systems by employees of Dynamic Aerospace Technologies for commercial use. Dear Sir or Madam: Pursuant to Section 333 ofthe FAA Modernization and Reform Act of2012 (FMRA) and 14 C.F.R. Part 11, Dynamic Aerospace Technologies, LLC. (DynAeroTech), respectfully requests exemptions from several provisions ofthe Federal Aviation Regulations (FAR), specifically portions ofTitle 14ofthe Code of Federal Regulations (CFR) Parts 45,61, and 91 to allow commercial operations of itsfleet of small Unmanned Aircraft Systems (sUAS) inthe Continental United States (CONUS) bytrained DynAeroTech employees for safe aerial photogrammetry, imaging, surveying, mapping, monitoring and inspection, tracking, education, and search and rescue applications, so long as such operations are conducted within and under the conditions outlined herein oras may be established bythe FAA as required by Section 333. This request stems from astrong safety culture and conservative risk-based approach towards sUAS operations derived from extensive experience with military and commercial aviation. The grant of an exemption is consistent with the intent ofthe Congress, as shown in Section 333 ofthe FAA Modernization and Reform Act of2012 (Section 333) that safe systems be permitted into the National Airspace System (NAS) prior to the issuance offinal regulations governing general use ofthese systems. 

# )fo;bU
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- Gustavo A. Hernandez President/CEO Dynamic Aerospace Technologies, LLC.DynAeroTech Section 333 Exemption Request 9275 N. Union Blvd

, Suite 140-206

, Colorado Springs CO 80920 (719) 596-9777 http://www.dvnaerotechcom 2 l.,jndmic AE?rOSpdCE? TE?chnoloqiE?s



### Abbreviations AGL ATC CFR COA CONUS DynAeroTech FAA FAR GCS GPS NAS PIC PO Section 333 sUAS UA UAS VO VLOS Above Ground Level

Air Traffic Control Code of Federal Regulations Certificate ofWaiver orAuthorization Continental United States Dynamic Aerospace Technologies, LLC. Federal Aviation Administration Federal Aviation Regulations Ground Control Station Global Positioning System National Airspace System Pilot in Command Payload Operator FAA Modernization and Reform Act of 2012, Section 333 small Unmanned Aircraft System Unmanned Aircraft Unmanned Aircraft System Visual Observer Visual Line of Sight 

### Background Information Dynamic Aerospace Technologies, LLC. is a new modern company designed and structured to capitalize on today's industrial technological innovations by bringing next generation applications, tools, services and efficiencies to a broad base of customers ranging from defense, aerospace, local, state, federal and commercial. By leveraging a blend of seasoned industry experts with youthful innovation, we plan to provide customers superior, cost effective, low risk and high performing solutions
. Our team is postured to provide professional, engineering, scientific, technical, advisory and assistance, management, geographical surveying, environmental, telecommunication and information technology services and solutions that fully employ today's new technologies, cloud capabilities, distributed communications, collaborative platforms and social media. We are building afoundation for customer service success that isset for many decades to come. DynAeroTech is largely comprised of prior US military personnel with decades of experience with military and civil flight including piloting, flight testing, and extensive knowledge and respect for the FARs that govern and certify manned aircraft. Oneynclmic AE"fOSPclCE" TE"chnoloqiE"S DynAeroTech Section 333 Exemption Request 9275 N
. Union Blvd, Suite 140-206, Colorado Springs CO 80920 (719) 596

-9777 http://www.dynaerotech

.com 3

important segment of DynAeroTech's growing business issUAS operations. The requested exemption would authorize commercial operations by Dynamic Aerospace Technologies using its sUAS fleet for aerial photogrammetry, imaging, surveying, mapping, monitoring and inspection, tracking, education, and search and rescue applications.


### 14CFR 

## §11.81 (a) -Contact Information Gustavo A
. Hernandez Dynamic Aerospace Technologies, LLC

. 9275 N
. Union Blvd, Suite 140-206 Colorado Springs CO 80920 Phone: (719) 596-9777 Email: ghernandez@dynaerotech

.com Website: http://www

.dynaerotech
.com


### 14CFR 

## §11
.81 (b) -Specific Sections of the Title 14Code of Federal Regulations from which Dynamic Aerospace Technologies requests exemption Title 14ofthe Code of Federal Regulations (14 CFR) governs the manner inwhich all aircraft and pilots operate within the National Airspace System (NAS). Due tothe nature oftheir systems and operation, small Unmanned Aircraft Systems (sUAS) are unable to comply with certain sections of 14CFR as the regulations were written prior to the consideration of small UAS operating within the NAS. DynAeroTech is requesting an exemption from certain parts of 14 CFR cited below in addition to such further exemptions and relief as the FAA may determine is necessary to permit the operations described herein:



### • 14CFR Part 

### 21, Subpart H -Airworthiness Certificates


### • 14CFR 

### §45.23 (b) - Requirement to display registration number on vehicle


### • 14CFR 

### §61.101 (e)(4)and 

### (5)

- Recreational pilot privileges and limitations


### • 14CFR 

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


### • 14CFR 

### §61.315 (a) - Privileges and limits of asport pilot certificate


### • 14CFR 

### 91.7 (a) - Civil aircraft airworthiness


### • 14CFR 

### §91.9 (b) 

### (2)

-Civil aircraft flight manual, marking, and placard requirements


### • 14CFR 

### §91.103 (b) - Preflight Action


### • 14CFR 

### §91.109

- Requirement for dual controls during flight instructionl,Indmic AE?rOSpdCE? TE?chnoloqiE?s DynAeroTech Section 333 Exemption Request 9275 N
. Union Blvd, Suite 140-206 , Colorado Springs CO 80920 (719) 596-9777 http://www.dvnaerotech.com 4

• 14 CFR 91.119 - Minimum safe altitudes
• 14 CFR 91.121 -Altimetersetlings
• 14 CFR 91.151 (a) - Fuel requirements forflight inVFR conditions
• 14 CFR 

### §91.203 (a) 

### & (b) - Requirement for registration and airworthiness certificates to be onboard
• 14 CFR 

### §91.205 (b) - Cockpit instruments
• 14 CFR 

### §91.405 (a) - Maintenance required
• 14 CFR 

### §91.407 (a)(1) - Operation after maintenance, preventive maintenance, rebuilding, oralteration
• 14 CFR 

### §91.409 (a)(1) and (a)(2) - Inspections
• 14 CFR 

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



### 14CFR 

## §11.81 (c) -The extent of the relief Dynamic Aerospace Technologies seeks and reasons for relief Introduction Dynamic Aerospace Technologies, LLC. (DynAeroTech) will operate as safely as possible, taking every precaution to minimize riskto the National Airspace System (NAS) orto persons and property on the ground. DynAeroTech is largely comprised of prior US military personnel with decades of experience with military and civil flight, including flight test, and extensive knowledge and respect for the FARs that govern and certify manned aircraft. DynAeroTech's proposed exemptions will not adversely affect safety to persons or property due to the company's following the strict guidance set forth by its procedures and the operators' years of experience. By allowing DynAeroTech to operate commercially, the company's pilots will be able to gain valuable real world experience that is unatlainable from any other means and customers will benefit from reduced cost and increased efficiency and safety. This experience will allow DynAeroTech to implement existing techniques and protocols aswell as develop new ones. DynAeroTech isworking diligently to create its sUAS Flight Operations Manual that, among other things, defines the following:

• Safety management system
• Pilot in Command (PIC) qualifications, duties, evaluation, and currency requirements
• Visual Observer (VO) qualifications, duties, evaluation, and currency requirements
• Payload Operator (PO) qualifications, duties, evaluation, and currency requirements
• Pre-flight and post-flight requirements and reviews
• Crew resource management standardsync3mic Al?rOSpc3CI? Tl?chnologil?s DynAeroTech Section 333 Exemption Request 9275 N. Union Blvd, Suite 140-206, Colorado Springs CO 80920 (719) 596-9777 http://www.dynaerotech.com 5

Dynamic Aerospace Technologies will comply with all current and future Federal Aviation Regulations (FARs) and upon approval ofthis petition for exemption, DynAeroTech's sUAS Flight Operations Manual will be completed and used forflight operations. The manual will be a living document and will be periodically updated with changes in FARs, sUAS characteristics, and improved safety practices. DynAeroTech asserts it issignificantly safer to operate a battery powered, lightweight, sUAS piloted by FAA licensed pilots than manned alternatives, the latter ofwhich are not even affordable or practical for several ofthe missions DynAeroTech will pursue. Most importantly, the potential loss of life is greatly reduced due to the slow speed, combined light weight ofvehicle and payload, and low operating altitudes, aswell as flying in airspace segregated from airports and dense populations. DynAeroTech's sUAS are battery powered and carry nofuel orflammable liquids, thus greatly reducing the potential forfire orexplosions. Further, the small size and extreme maneuverability of our sUAS allows our PIC to avoid hazards. Given their small size and weight, they pose far less of an environmental and noise impact than conventional manned aircraft and helicopter systems available today. Finally, implementation ofautonomous flight safety software allows for safe recovery ofthe vehicle inthe unlikely event of a loss of the command and control link. The requested exemption would authorize commercial operations by Dynamic Aerospace Technologies using its sUAS fleet comprised ofthe OGIPhantom 3, OGI Inspire 1, OJI Spreading Wings S900, 3D Robotics Solo, 30R Aero M, PrecisionHawk Lancaster, Parrot senseFly eXom, and senseFly e8ee Ag/RTK for aerial photogrammetry, imaging, surveying, mapping, monitoring and inspection, tracking, education, and search and rescue applications, and the UOI U818A and Cheerson CX10sUAS for educational applications.
14 CFR Part

### 21 Subpart H-Airworthiness Certificates This regulation isdesigned for larger, manned aircraft and is not suitable for off-theshelf sUAS. FAR section: 14 CFR Part 21 Subpart H, entitled Airworthiness Certificates, establishes the procedural requirements forthe issuance ofairworthiness certificates as required by FAR §91.203 (a) (1). Given the size and limited operating area associated with the sUAS aircraft to be utilized bythe DynAeroTech, an exemption from Part 21 Subpart H meets the requirements of an equivalent level of safety under Part 11 and Section 333 ofthe Reform Act, upon consideration ofthe size, weight, speed, maneuverability, and proximity to airports and populated areas ofthe particular UAS. Our small unmanned aircraft will be operated at low speed in a controlled environment, farfrom airports and densely populated areas, and carry neither humans nor explosive materials orflammable liquid fuels. Further, application ofthese same criteria demonstrates that there is no credible threat to national security posed bytherreerntc AE"rOSpdCE" TE"chnologiE"s DynAeroTech Section 333 Exemption Request 9275 N
. Union Blvd

, Suite 140-

206 , Colorado Springs CO 80920 (719) 596-9777 http: //www.dynaerotech.com 6

sUAS, due to its size, speed ofoperation, location of operation, lack of explosive materials orflammable liquid fuels. Finally, the FAA has previously approved numerous exemptions to this regulation for sUAS. OynAeroTech Fleet sUAS Characteristics Dynamic Aerospace Technologies has initially partially acquired and will operate an sUAS fleet comprised ofthe OJIPhantom 3, OJllnspire 1, OJI Spreading Wings S900, 3D Robotics Solo, 30R Aero M, PrecisionHawk Lancaster, Parrot senseFlyeXom and senseFlyeBee Ag/RTK for commercial operations and the UOI U818A and Cheerson CX-10 sUAS for educational applications. The OJIPhantom 

### 3isan electrically powered rotary wing sUAS with agross weight, excluding payload, of2.92 Ib (1.28 kg). Ithas a maximum flight time of about 23 minutes and a maximum speed of 35.8 mph (57

.6 km/h). The vehicle has adiagonal size of about 23 inches (59 cm), including propellers. The flight vehicle is powered by a 4480 mAh lithium-ion polymer LiPo 4S battery and operates at 15.2V; the controller is powered bya 6000 mAh rechargeable lithium-ion polymer LiPo 2S battery and operates at 7.4 V. The OJllnspire 1 is an electrically powered rotary wing sUAS with agross lift-off weight, including payload, of 6
.5 Ib(2.935 kg). The vehicle measures approximately 17.3 x 17.7 x 11.8 inches (44 x45 x30 ern), has a maximum flight time of about 18 minutes, a maximum speed of about 49 mph (22 m/s), and aceiling of 14.8 kft (4500 m). The flight vehicle is powered by aTB47 Intelligent Battery, a lithium-ion polymer at4500 mAh, and operates at22.2 V; the controller is powered by a rechargeable lithium-ion battery at 6000 mAh, 7.2 V The OJI Spreading Wings S900 is an electrically powered, rotary wing sUAS with a gross lift-off weight ofabout 10.4to 18.1 Ib (4.7 to 8.2 kg), depending upon payload weight, and adiagonal wheelbase of about 2.9 ft (0.90 m). The flight vehicle is powered bya6S 1~000mAh battery, providing a hover time ofabout 8 minutes with a 6.8 kg payload. 3D Robotics Solo is an electrically powered rotary wing sUAS with agross lift-off weight, including payload, of 3.9 Ib (1.8 kg). It has a maximum flight time ofabout 20 minutes, a maximum speed of 55 mph (89 km/h), and a maximum range of 0
.5 miles (0.8 km). The 3D Robotics Solo uses a 3DR secure WiFi network communication link operating at a frequency of 2.4 GHz. The vehicle isapproximately 10 inches (25 cm) tall and has a diameter of 18 inches (46 ern) motor-to-motor. The flight vehicle is powered by a lithium-ion polymer flight battery at 5200 mAh, 14.8 Vdc; the controller is powered by a rechargeable lithium-ion battery at 2600 mAh, 7.2 V.l
.Jndmic AE"rOSpdCE" TE"chnoloqiE"s DynAeroTech Section 333 Exemption Request 9275 N
. Union Blvd

, Suite 140-206

, Colorado Springs CO 80920 (719) 596-9777 http: //www

.dynaerotech.com 7

The 

### 30RAero M is an electrically powered, fixed wing, pusher propeller, sUAS with a gross lift-off weight ofabout 6.8 to 7.9 Ib(3.1 to 3.6 kg), depending upon payload weight. The vehicle has awingspan of 74 in (188 ern), atotal length of 51 in (129 cm) length, and a maximum flight time of about 40 minutes. The UA is powered bya4S 6000 mAh 35C lithium polymer battery
. PrecisionHawk Lancaster isan electrically powered, fixed wing sUAS with agross lift-off weight of about 5.3 to 7.3 Ib(2.4 to 3.3 kg), depending upon payload weight. The Parrot senseFly eXom is an electrically powered rotary wing sUAS with a gross liftoffweight, including payload, of 3.7 Ib (1.7 kg), including battery, payload, and shrouding. It has a maximum flight time of about 22 minutes, a maximum air speed in automatic flight mode of 18 mph (29.0 km/h) and in manual flight mode of27 mph (43.4 km/h), and a maximum range of 1.2 miles (2 km). The senseFly eXom uses shrouding around itsfour propellers for enhanced operational safety and has navigational lights as well as anti-collision strobe lights. The vehicle measures approximately 22 x32 x7 inches (56 x80 x 17 cm) and is powered by athree cell lithium-ion polymer flight battery at 8500 mAh
. The senseFly eBee Ag/RTK is an electrically powered, pusher propeller, fixed wing sUAS with a gross lift-off weight, including payload, of about 1.6 Ib (0.71 kg). It is constructed of EPP foam, carbon structure and composite parts and has awing span of 38 inches (96 cm) and a maximum flight time of about 45 minutes. The UA is powered bya lithium-ion polymer flight battery at2150 mAh, 11.1 Vand has a nominal cruise speed of25-56 mph (11-25 rn/s). The Cheerson CX-10 Mini quadcopter isavery small, inexpensive (afew inches in diameter), electrically powered, rotary wing, entry level drone weighing just afew ounces with a maximum flight time ofjust afew minutes. The UOI U818A issimilar to the Cheerson, and is powered by a 500mAh battery, providing aflight time of6to 9 minutes. Both vehicles are very short range micro UAs; the UDI, for example, can only be operated from adistance of upto 30 meters away. DynAeroTech plans to employ these two micro sUAS only for educational applications and notfor certification or qualification purposes. Airworthiness Assessment ofthe OynAeroTech Fleet Dynamic Aerospace Technologies notes that both the DJI Phantom 3 sUAS and the 3D Robotics Solo sUAS, including the aircraft, the flight software, and the controllers, are mature and established systems. Indeed, these companies and products are among the leaders ofthe industry. The airworthiness ofthe both the DJI Phantom 3sUAS and the 3D Robotics Solo sUAS have been demonstrated extensively prior, and a large number of exemptions have already been granted bythe FAA for either these specific sUAS or forvery similar models (e.g.11433 and 11419 for 3D Robotics, and 11434, 12051, andrresrruc; AE?fO:'PdCE? TE?chnoloqiE?:' DynAeroTech Section 333 Exemption Request 9275 N
. Union Blvd

, Suite 140-206, Colorado Springs CO 80920 (719)596-9777 http: //www.dynaerotech.com 8

12047 for OJI Phantom). The Parrot senseFly eXam has even more sophisticated flight software, including: automated system checks; automated take-off 

### & landing; real-time flight status; main camera, navigation, and thermal camera video feed integration, fully automatic flight; and black-box recording of all flight and mission parameters, which should make iteven safer than the other sUAS in OynAeroTech's fleet. The airworthiness of several senseFly sUAS models have also been demonstrated extensively prior and a large number of exemptions have already been granted bythe FAA for similar models (e.g.11339 and 12040), and the Parrot senseFly eXom received an exemption just lastweek (11373A). The PrecisionHawk Lancaster and the OJI Spreading Wings S900 have also received FAA exemptions (11345 and 11289A, respectively)

. 14 CFR 

### §45.23 (b) -Requirement to display registration number on vehicle This regulation isdesigned for larger, manned aircraft and is not suitable for off-theshelf sUAS. There is insufficient area on small unmanned aircraft to use the specified two-inch lettering. OynAeroTech will mark every sUAS with the largest possible identification lettering, within reason. The FAA has previously approved numerous exemptions to this regulation for sUAS.
The following three FAR Sections are addressed collectively: 14 CFR 

### §61.101 

### (e)(4) and 

### (5)

- Recreational pilotprivileges and limitations 14 CFR 

### §61.113 (a) & (b) -Private pilotprivileges and limitations: Pilot in command 14 CFR 

### §61.315 (a) -Privileges and limits of a sportpilot certificate Sections 

### 14 CFR 61.101 (e)(4) and

### (5),61.113 (a) & (b), and 61.315(a) limit recreational, private, and sport pilots, respectively, to non-commercial operations. Because the sUAS will not carry a pilot or passengers, the proposed commercial operations of sUAS by OynAeroTech can achieve the equivalent level ofsafety of operations under current regulations. All operations will utilize avisual observer (Va). The va may be used to satisfy the VLOS requirement as long asthe PIC always maintains VLOS capability. The va and PIC will communicate verbally at all times. It isthe responsibility ofthe PICto be aware ofthe va's visual limitations and limit operations ofthe sUAS to distances within the visual capabilities of both the PIC and VO. The va will not be operating the aircraft. Many planned operations, especially the more complex ones, will utilize a payload operator (PO). Forthese operations the POwill operate the payloads to enhanceynomic A(?rospoc(? T(?chnologi(?S DynAeroTech Section 333 Exemption Request 9275 N. Union Blvd

, Suite 140-206

, Colorado Springs CO 80920 (719) 596-9777 http: //www

.dynaerotech.com 9

mission effectiveness and increase safety, the latter by providing more focus on piloting and reducing the workload on the PIC. The POwill not be operating the aircraft. Unlike a conventional aircraft that carries the pilot and passengers, the UAS is remotely controlled with no living thing orcargo on board. The area ofoperation iscontrolled and restricted, and allflights are planned and coordinated in advance. The risks associated with the operation ofthe UAS are so diminished from the level of risk associated with commercial operations contemplated by Part 61 when drafted, that allowing operations ofthe sUAS as requested above with a PIC and aVO exceeds the present level ofsafety achieved by 

### 14 CFR 61.101 (e)(4) and 

### (5),61.113 (a) & (b), and 61.315(a). Finally, the FAA has previously approved numerous exemptions to these regulations for sUAS.
14 CFR 

### §91.7 (a) - Civilaircraft airworthiness This regulation isdesigned for larger, manned aircraft and is not suitable for off-theshelf sUAS. DynAeroTech will inspect sUAS and use safety checklists prior to each flight to ensure airworthiness and provide an equivalent level of safety
. The FAA has previously approved numerous exemptions to this regulation forthe specific models of sUAS Dynamic Aerospace Technologies will fly
. 14 CFR 

### §91.9 (b) 

### (2)

- Civilaircraft flight manual, marking, andplacard requirements This regulation isdesigned for larger, manned aircraft and is not suitable for off-theshelf sUAS. There will be neither anyone aboard to read the manual nor room or capacity to carry such an item on the UA. The equivalent level ofsafety will be achieved by DynAeroTech by keeping the sUAS Flight Operations Manual atthe ground control point where the pilot in command (PIC) flying the sUAS will have immediate access to it. The requested relief ofthis FAR Section may not be necessary due to the FAA Memorandum, "Interpretation regarding whether certain required documents may be kept at an unmanned aircraft's control station," dated August 8,2014
. In addition, the FAA has issued numerous exemptions tothis regulation for small unmanned aircraft.
14 CFR 

### §91.103(b) -Preflight actionyndmic AElfOSPdCEl TElchnoloqiElS DynAeroTech Section 333 Exemption Request 9275 N. Union Blvd

, Suite 140-206

, Colorado Springs CO 80920 (719) 596-9777 http://www

.dynaerotech
.com 10

This regulation isdesigned for manned aircraft and is not suitable for off-the-shelf sUAS. The DynAeroTech sUAS PIC will provide an equivalent level of safety bytaking a number of preflight actions, including checking forweather conditions, checking flight battery requirements, checking wind, temperature, and other weather conditions, checking flight altitudes above ground level (AGL), and all other actions inthe Preflight Checklist. The FAA has previously approved numerous exemptions to this regulation for sUAS.
14 CFR

### §91.109 -Requirement fordual controls during flight instruction This regulation isdesigned for manned aircraft and is not suitable for off-the-shelf sUAS. Since there is no one aboard to operate dual controls, this requirement is not appropriate for asmall UA
. Bydesign, small unmanned aircraft do not have fully functional dual controls and are instead controlled via use ofa control box bythe pilot that communicates with the aircraft via radio communications
. The equivalent level of safety is provided bythe fact that the aircraft is unmanned, the ability to control the UAS via radio signals from the controller, and bythe size, lightweight, and slow speed ofthe aircraft, aswell asthe small payload, low altitude flight, and short flight duration. The FAA has previously approved numerous exemptions for small unmanned aircraft without dual controls
. 14 CFR 

### §91.119 - Minimum safe altitudes sUAS safety requires operation below these altitudes. DynAeroTech will operate its entire sUAS fleet from 0to 400 feet AGL. The equivalent level of safety is provided by the fact that the aircraft are unmanned, the ability to control the UAS via radio signals from the controller, and bythe size, light weight, and slow speed ofthe aircraft, aswell asthe small payload, low altitude flight, and short flight duration. The FAA has previously approved numerous exemptions for small unmanned aircraft for 14 CFR 

### §91
.119.
14 CFR

### §91.121 -Altimeter settings This regulation isdesigned for manned aircraft and is not suitable for off-the-shelf sUAS. Since no one isaboard to read an altimeter, this requirement is not appropriate for a UA. Small unmanned aircraft typically use GPS to determine operating altitude instead of a barometric pressure altimeter. The sUAS will automatically provide

. onboard GPS altitude information to the pilot via a radio communications telemetry datayndmic Ae>rOSpdCe> Te>chnoloqie>s DynAeroTech Section 333 Exemption Request 9275 N
. Union Blvd

, Suite 140-206

, Colorado Springs CO 80920 (719)596-9777 http: //www

.dynaerotech.com 11

linkfor active monitoring ofthe flight information. The equivalent level ofsafety will be achieved by OynAeroTech byconfirming the altitude ofthe launch site shown on the GPS altitude indicator before flight. The FAA has previously approved numerous exemptions tothis regulation for small unmanned aircraft.
14 CFR 

### §91.151 (a) -Fuel requirements forflight in VFR conditions This regulation isdesigned for large aircraft and is not suitable for off-the-shelf sUAS. Vehicle does not use fuel. Current technology small unmanned aircraft employ a battery that provide short flight times that make 14CFR 

### §91
.151 (a) specified reserve flight time requirements impossible or unreasonable. An equivalent level of safety can be achieved by limiting flights to employ battery reserve to ensure that the sUAS lands atthe ground station with at least 20% of battery power. The small unmanned aircraft systems employed by OynAeroTech have onboard power management systems that continuously monitor flight time and amount of battery power remaining and they transmit this information tothe pilot in real-time. In addition the sUAS systems provide an automatic command to cause the small unmanned aircraft to return tothe launch point when critical minimum voltage is reached as prescribed bythe pilot. The FAA has previously approved numerous exemptions to this regulation for small unmanned aircraft.
14 CFR 

### §91.203 (a) & (b) -Requirement forregistration and airworthiness certificates tobe onboard This regulation isdesigned for manned aircraft and is not suitable for off-the-shelf sUAS. Since neither anyone is aboard to read the certificates norvolume exists to carry such an item on the aircraft, this requirement is not appropriate for a UA. The equivalent level ofsafety will be achieved by OynAeroTech by keeping these documents atthe ground flight control point where the pilot flying the small unmanned aircraft will have immediate access to them, to the extent they are applicable to the sUAS. The FAA has previously approved numerous exemptions for sUAS for 14 CFR 

### §91.203 (a) & (b). The requested relief ofthis FAR Section may not be necessary due tothe FAA Memorandum, "Interpretation regarding whether certain required documents may be kept at an unmanned aircraft's control station," dated August 8,2014.
14CFR 

### §91.205 (b) - Cockpit instruments

## -----------------------------------------------------------------------------------
ljndmic Ae:orOSpdCe:o Te:ochnoloqie:os DynAeroTech Section 333 Exemption Request 9275 N
. Union Blvd

, Suite 140-

206 , Colorado Springs CO 80920 (719)596-9777 http.1lwww.dvnaerotech.com 12

This regulation isdesigned for manned aircraft and is not suitable for off-the-shelf sUAS

. Since no one isaboard to read cockpit instruments, this requirement is not appropriate for a UA. The FAA has previously approved numerous exemptions to this regulation for sUAS.
The following four FAR Sections are addressed collectively: 14 CFR 

### §91.405 (a) - Maintenance required 14 CFR 

### §91.407 (a)(1) - Operation aftermaintenance, preventive maintenance, rebuilding, 

### oralteration 14 CFR 

### §91.409 (a)(1) & (a)(2) -Inspections 14 CFR 

### §91.417 (a) & (b) -Maintenance records These regulations require maintenance, inspections, and documentation thereof. Since these regulations are only applicable to aircraft with an airworthiness certificate, they are hence not applicable to asUAS

. The equivalent level of safety will be achieved by OynAeroTech due tothe size, light weight, and slow speed ofthe aircraft, aswell as the small payload, low altitude flight, and short flight duration, and the OynAeroTech requirement that the PICwill ensure the UAS is in good working condition prior toflight, perform required maintenance, and keep a log of any maintenance performed. The PIC will follow the operations and maintenance procedures outlined in OynAeroTech's sUAS Flight Operation Manual at all times. Prior to each flight the PIC will inspect the sUAS to ensure it is in acondition for safe flight as outlined in OynAeroTech's sUAS Flight Operation Manual. Ifthe inspection reveals a condition that affects the safe operation of the UAS, the aircraft is prohibited from operating until the necessary maintenance has been performed and the UAS isfound to be in a condition for safe flight and tested via a functional test flight. Any UAthat has undergone maintenance oralterations that affect the sUAS operation orflight characteristics will undergo afunctional test flight in accordance with OynAeroTech's sUAS Flight Operation Manual prior to conducting further operations. OynAeroTech will follow the UAS manufacturer's maintenance, overhaul, replacement, inspection, safety bulletins, and life limit requirements for the aircraft and aircraft components. Finally, since the sUAS will operate at altitudes less than 400 ftAGL, the sUAS can be landed very quickly if mechanical issues arise. The FAA has previously approved numerous exemptions for sUAS for 14 CFR 

### §91.407 (a)(1), 14 CFR 

### §91.409 (a)(1) & (a)(2), and 14 CFR 

### §91.417 (a) & (b)

.

-- -- - - ------.--------------------------------------------------------------nomic AE?rospoCE? TE?chnoloqiE?s DynAeroTech Section 333 Exemption Request 9275 N. Union Blvd, Suite 140-206, Colorado Springs CO 80920 (719) 596-9777 http.Jlwww
.dynaerotech.com 13



### 14 CFR § 11.81 (d) -The reasons why granting your request would be inthe public interest; that is, how itwould benefit the public as a whole Granting the exemption would further public interest by allowing DynAeroTech to safely, efficiently, and economically perform sUAS commercial operations ofvalue to the public. An overarching goal isto safely integrate sUAS into aerial photogrammetry, imaging, surveying, mapping, monitoring and inspection, tracking, education, and search and rescue applications that are either currently not provided or currently provided atfar higher costs and risk. With astrong safety and risk culture and decades of military aviation experience, our team will ensure safe sUAS integration and operation into the NAS and provide valuable services tothe public.



### 14 CFR 

## § 11.81 (e) -The reasons why granting the exemption would not adversely affect safety, or howthe exemption would provide a level ofsafety at least equal tothat provided bythe rule from which you seek the exemption DynAeroTech proposes that the exemption requested herein apply to sUAS that have the characteristics and that operate with the limitations listed herein. These limitations provide for at least an equivalent oreven higher level of safety to operations with manned aircraft under the current regulatory structure. OynAeroTech's Flight Rules The following describe the flight rules DynAeroTech will use when conducting its sUAS operations under an FAA issued exemption: 1. The maximum take-off weight ofthe UA (unmanned aircraft), including payload, will be less than 55 pounds. 2. The UAwill not be operated at airspeeds greater than the maximum UA operating speed recommended bythe aircraft manufacturer, and will not be flown with an indicated air speed exceeding 100 mph (87 knots). 3. Flights will be operated at or below an altitude never exceeding 400 feet AGL. 4. The UAwill be operated within visual line of sight (VLOS) ofthe PIC at all times. The PIC will only use human vision unaided by any device other than corrective· yndmic Al?rOSpdCI? Tl?chnologil?s DynAeroTech Section 333 Exemption Request 9275 N
. Union Blvd

, Suite 140-206

, Colorado Springs CO 80920 (719) 596-9777 http://www.dvnaerotech.com 14

lenses, as specified on the PIC's FAA-issued airman medical certificate or U.S. driver's license
. 5. All operations will utilize avisual observer ryO). The UAwill be operated within VLOS ofthe PIC and VO at all times. The VO may be used to satisfy the VLOS requirement as long asthe PIC always maintains VLOS capability. The VO and PIC will have the ability for constant verbal communication at all times; electronic messaging ortexting will not be permitted during flight operations. 6. Many planned operations, especially the more complex ones, will utilize a payload operator (PO)

. Forthese operations the POwill enhance mission effectiveness and increase safety, the latter by providing more focus on piloting and reducing the workload on the PIC

. The POwill not operate the aircraft. 7. The PIC will be designated before the flight and cannot transfer his or her designation for the duration ofthe flight. The PICwill ensure that the VO can perform the duties required ofthe VO. 8. The PIC will follow the operations and maintenance procedures outlined in DynAeroTech's sUAS Flight Operation Manual at all times. Prior to each flight the PIC will inspect the sUAS to ensure it is in a condition for safe flight as outlined in DynAeroTech's sUAS Flight Operation Manual. Ifthe inspection reveals a condition that affects the safe operation ofthe UAS, the aircraft is prohibited from operating until the necessary maintenance has been performed and the UAS isfound to be in a condition for safe flight and tested via a functional test flight, as required 9. Any UAthat has undergone maintenance oralterations that affect the sUAS operation orflight characteristics will undergo afunctional test flight in accordance with DynAeroTech's sUAS Flight Operation Manual prior to conducting further operations. Functional test flights will only be conducted by a PIC with aVO and the UAwill remain at least 500 feet from other people. The functional test flight must be conducted in such a manner so asto not pose an undue hazard to persons and property. 10. DynAeroTech will follow the UAS manufacturer's maintenance, overhaul, replacement, inspection, safety bulletins, and life limit requirements forthe aircraft and aircraft components
. 11. The PIC will hold either an airline transport, commercial, private, recreational, or sport pilot certificate. The PIC must also hold a current FAA airman medical certificate or avalid U.S. driver's license issued by astate, the District ofLJndmic Al?fOSPdCI? Tl?chnoloqil?s DynAeroTech Section 333 Exemption Request 9275 N. Union Blvd

, Suite 140-206, Colorado Springs CO 80920 (719)596-9777 http: //www.dynaerotech.com 15

Columbia, Puerto Rico, aterritory, a possession, orthe Federal government. The PIC must also meet the flight review requirements specified in 14 CFR 

### § 61.56 in an aircraft inwhich the PIC is rated on his or her pilot certificate. 12. DynAeroTech will not permit any PIC to operate unless that PIC has demonstrated through DynAeroTech's training and currency requirements that the PIC is able to safely operate the sUAS in a manner consistent with howthe sUAS will be operated as outlined inthe DynAeroTech sUAS Flight Operation Manual, including evasive and emergency maneuvers and maintaining appropriate distances from people, vessels, vehicles and, structures, and other objects. 13. PIC qualification flight hours and currency must be logged in a manner consistent with 14 CFR 

### §61.51 (b). Flights forthe purposes oftraining the operator's PICs and VOs (training, proficiency, and experience-building) and determining the PIC's ability to safely operate the sUAS in a manner consistent with how the sUAS will be operated under this exemption are permitted under the terms ofthis exemption. However, training operations may only be conducted during dedicated training sessions. During training, proficiency, and experience-building flights, all persons not essential forflight operations are considered nonparticipants, and the PIC must operate the UAwith appropriate distance from nonparticipants in accordance with 14 CFR 

### §91.119. 14. DynAeroTech will conduct extensive briefings prior toflight, emphasizing safety, crew duties, weather, and mission requirements. Post flight briefings will also be conducted to assess mission performance and safety. DynAeroTech actively analyzes electronic flight data and other sources of information to constantly update and enhance safety protocols
. 15
. As asafety margin, DynAeroTech will land each UAwith at least five minutes of battery power remaining orwith the reserve battery power recommended bythe manufacturer, whichever is greater. 16. DynAeroTech will only operate in secured areas that are strictly controlled, are away from congested ordensely populated areas, and are at least 5 nautical miles from airports. Security will be established forthe operations area at a minimum as part ofthe pre-flight inspections. Each person within the operations area will be briefed about the sUAS flight and give consent to be inthe operations area. 17. Inthe extremely rare event an operation needs to be conducted closer to an airport (e.g. search and rescue, disaster orwild fire monitoring, and/or mapping),j . 

## .... 'lJndmic Ae>rO:.pdCe> Te>chnoloqie>:
. DynAeroTech Section 333 Exemption Request 9275 N. Union Blvd, Suite 140-206, Colorado Springs CO 80920 (719) 596-9777 http: //www.dynaerotech.com 16

DynAeroTech will inform the airport operator and airport traffic control tower of the contemplated operation and will comply with any and all directions issued by airtraffic control and/or airport management atthat airport and obtain a letter of agreement with that airport's management unless otherwise permitted by a COA issued tothe exemption. The letter of agreement with the airport management shall be made available tothe Administrator or any law enforcement official upon request. DynAeroTech will diligently ensure its sUAS missions work closely and collaboratively and do not interfere with manned aircraft and higher priority UA missions such as reconnaissance orfirefighting aircraft flights, aswell as emergency ground personnel such as police, forest service, firemen, and others. Forsuch missions DynAeroTech will preferably employ the Parrot senseFly eXom which has shrouding around itsfour propellers for enhanced operational safety and navigational lights and anti-collision strobe lights, or another sUAS with similar features
. 18. The UA may not be operated less than 500 feet below or less than 2,000 feet horizontally from a cloud orwhen visibility is less than 3statute miles from the PIC. 19. Ifthe UAS loses communications orthe battery power reaches reserve levels, the UAwill automatically return to a pre-determined location and land or be recovered in accordance with DynAeroTech's sUAS Flight Operation Manual
. 20. The PIC will abort the flight inthe event of unpredicted obstacles, other flight vehicles, oremergencies in accordance with DynAeroTech's sUAS Flight Operation Manual. 21. The PIC is prohibited from beginning a UAS flight unless (considering wind and forecast weather conditions and assuming normal cruising speed) there is enough power tofly tothe first point of intended landing prior to utilizing battery reserve power. 22. The operator will obtain an Air Traffic Organization (ATO) issued Certificate of Waiver orAuthorization (COA) prior to conducting any operations
. This COA will also require the operator to request a Notice to Airman (NOTAM) not more than 72 hours in advance, but not less than 48 hours prior tothe operation. 23. All UA operated by DynAeroTech will be identified by serial number. Except for the hand-held micro UA, we intend to acquire and provide identification (N - Number) markings for the fleet that will be as large as practicable
.ljndmic Aerospdce Technologies DynAeroTech Section 333 Exemption Request 9275 N
. Union Blvd, Suite 140-206 , Colorado Springs CO 80920 (719) 596-9777 http://www.dynaerotech.com 17

24. The documents required to ensure safe operation and flight and any documents required under 14 CFR 91.9 and 91.203 will be available tothe PIC atthe Ground Control Station ofthe sUAS any time the aircraft isoperating. These documents will be made available tothe Administrator orany law enforcement official upon request. 25. The UAwill remain clear and yield the right ofway to all manned aviation operations and activities at all times. 26. The UAwill not be operated bythe PICfrom any moving device orvehicle. 27. All flight operations must be conducted at least 500 feet from all nonparticipating persons, vessels, vehicles, and structures unless: a. Barriers orstructures are present that sufficiently protect nonparticipating persons from the UA and/or debris inthe event of an accident. The operator must ensure that nonparticipating persons remain under such protection. Ifasituation arises where nonparticipating persons leave such protection and are within 500 feet ofthe UA, flight operations must cease immediately in a manner ensuring the safety of nonparticipating persons; and b. The owner/controller of any vessels, vehicles or structures has granted permission for operating closer to those objects and the PIC has made a safety assessment ofthe risk of operating closer to those objects and determined that itdoes not present an undue hazard. 

### 2B. All operations shall be conducted over private orcontrolled-access property with permission from the land owner/controller orauthorized representative. Permission from the land owner/controller or authorized representative will be obtained prior to the beginning of every flight. 29. Any incident, accident, orflight operation that transgresses the lateral orvertical boundaries ofthe operational area as defined bythe applicable COA will be reported to the FAA's UAS Integration Office (AFS-BO)within 24 hours
. Accidents will be reported tothe National Transportation Safety Board (NTSB) per instructions contained on the NTSB Web site: www.ntsb
.gov.

### ------~----~--------------------------------

.•... ljndmic AerOE:.pdCe TechnologiE?E:
. DynAeroTech Section 333 Exemption Request 9275 N_Union Blvd, Suite 140-206, Colorado Springs CO 80920 (719) 596-9777 http: //www_dynaerotechcom 18



### 14CFR 

## §11.81 (f) -Summary the FAA can publish in the Federal Register: - 1. Petitioner: Dynamic Aerospace Technologies, LLC. 2. The rule from which you seek the exemption: 14 CFR Part 21, Subpart H -Airworthiness Certificates 14 CFR 

### §45.23 (b) - Requirement to display registration number on vehicle 14 CFR 

### §61.101 (e)(4) and (5) - Recreational pilot privileges and limitations 14 CFR 61.113 (a) and (b) - Private pilot privileges and limitations: Pilot in command 14 CFR 

### §61.315 (a) - Privileges and limits of asport pilot certificate 14 CFR 91.7 (a) - Civil aircraft airworthiness 14 CFR 

### §91.9 (b) (2) - Civil aircraft flight manual, marking, and placard requirements 14 CFR§ 91.103 (b) - Preflight Action 14 CFR 

### §91.109 - Requirement for dual controls during flight instruction 14 CFR 91.119 - Minimum safe altitudes 14 CFR 91.121 -Altimeter settings 14 CFR 91.151 (a) - Fuel requirements forflight inVFR conditions 14 CFR 

### §91.203 (a) 

### & (b) - Requirement for registration and airworthiness certificates to be onboard 14 CFR 

### §91.205 (b) - Cockpit instruments 14 CFR 

### §91.405 (a) - Maintenance required 14 CFR 

### §91.407 (a)(1) - Operation after maintenance, preventive maintenance, rebuilding, or alteration 14 CFR 

### §91
.409 (a)(1) and (a)(2) - Inspections 14 CFR 

### §91.417 (a) and (b) - Maintenance records 3. A brief description of the nature of the exemption you seek: DynAeroTech seeks relief from the applicable parts of 14 CFR 45, 61, and 91 as requested herein to allow DynAeroTech to safely and efficiently conduct commercial sUAS flight operations in CONUS. 

### Summary Pursuant to Section 333 ofthe FAA Modernization and Reform Act of 2012 (FMRA) and

- 14 C.F.R. Part 11, Dynamic Aerospace Technologies, LLC. (DynAeroTech), respectfully

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.~jIlii-t'LJndmiC AE?fOSPdC(? T(?chnoloQi(?S DynAeroTech Section 333 Exemption Request 9275 N. Union Blvd

, Suite 140-206, Colorado Spnnqs CO 80920 (719) 596-9777 http: //www.dynaerotech.com 19

requests exemptions from several provisions ofthe Federal Aviation Regulations (FAR), specifically portions ofTitle 14ofthe Code of Federal Regulations (CFR) Parts 45,61, and 91 to allow commercial operations of itsfleet of small Unmanned Aircraft Systems (sUAS) inthe Continental United States (CONUS) bytrained DynAeroTech employees for safe aerial photogrammetry, imaging, surveying, mapping, monitoring and inspection, tracking, education, and search and rescue applications, so long as such operations are conducted within and under the conditions outlined herein oras may be established bythe FAA as required by Section 333. This request stems from astrong safety culture and conservative risk-based approach towards sUAS operations derived from extensive experience with military and commercial aviation. The grant ofan exemption is consistent with the intent ofthe Congress, as shown in Section 333 ofthe FAA Modernization and Reform Act of2012 (Section 333) that safe systems be permitted into the National Airspace System (NAS) prior to the issuance offinal regulations governing general use ofthese systems. Ifthe FAA believes additional exemptions beyond those requested inthis petition are required for DynAeroTech to conduct sUAS operations described here, we respectfully request an exemption from any such regulatory provisions as deemed necessary. For any questions orconcerns, please contact me directly atthe phone number or email address provided. ,. 

# 1fj;16~-

<s=: .,f~

,Gustavo A. Hernandez President/CEO Dynamic Aerospace Technologies, LLC

.