June 4th, 2015

U.S. Dept. ofTransportation, DocketOperations West Building Ground Floor, Room w12-140 1200 NewJerseyAvenue, SE., Washington, DC 20590 NetOne Inc. 12Avery Rd. Cross River, NY 10518

VIA FEDERAL DOCUMENT MANAGEMENTSYSTEM

Re: Exemption Request under Section 333 ofthe FAA Reform Act and Part 11 ofthe Federal Aviation Regulations
Dear Sir or Madam:
Pursuantto Section 333 ofthe FAA Modernization and Reform Act of 2012 (the "ReformAct") and 14 C.F.R. Part 11, NetOne Inc., seeks an exemption from Federal Aviation Regulations ("FARs") detailed belowforthe following described Unmanned Aerial System called in this application the ME System, which includes an UnmannedAircraft (UA) and ground stationbased equipment and crew:
THE UNMANNEDAIRCRAFT (UA): 

## 00 A lightweight (20 lb gross weightwith all on-board equipment), manufactured by DJI, Inspire 1- t-600 that includes the following equipment in flight; 

## 00 An on-board flight computerwith GPS navigation and location abilitythat receives signalsfor flight controls from a ground-based transmitter/controller; 

## 00 An on-board camera capable ofcapturing imagery in the form offull color, high definition still photos and video; 

## 00 An on-board telemetry system that deliversflight datafrom the on-board flight computerto the on-board radio transmitter including altitudeAGL, horizontal and vertical speed, compass direction offlight and direction backto its launch site; 

## 00 A2.4GHz on-board radio transmitterthattransmits live video from the on-board camera plus all the flight datafrom thetelemetry system described above;
THE GROUD STATION -BASED PART OFTHE SYSTEM: 

### r!] A Pilot in Command (PIC) in operational control of a flight operation from beginning to end and who controlsthe UAwhile in the air; 

## 00 A 2.4GHz radio transmitter/controller operated bythe PIC to control the UAwhile in flight; 

### fR) A radio receiver receiving live video and flight datafrom the on-board camera and computer projects it all together onto a screen for the PIC to view during flight; 

## 00 A Visual Observer (VO) is a person who provides a second pair of eyesto visuallytrackthe UAwhile in flight.The requested exemption would supportan application for a commercial Certificate of Authorization to use the above described ME System to support aerial photography and video primarily of Real Property, Demonstrationrrraining for Safe Flight; CinematicTraining; Search and Rescue Training; Low level photography and videography production; architectural Cinematography and Promo/Commercial videos neveroperating over persons notdirectly involved with the ME system.
The UA, powered by batteries, is smaller, lighter and more maneuverable than larger aircraft running on combustible fuel, it operates at lower altitudes with no people on board and will thereby reduce current risk levels and thereby enhance safety and diminish the likelihood of death or serious bodily injury. With a small payload and maximum flighttime ofonly 18 minutes, this is offers little or no risk to national security.
Low level oblique photos and video from several angles are far more effectivethan groundbased imageryfor displaying the characteristics of large, complex properties with several buildings and large trees. The alternative could be to charter a full-sized helicopterfor this purpose, which has proven more costlythan many potential clients are able to afford. The benefits of reduced cost and improved qualityof presentation from the UAwill be valuable to and benefit many buyers and sellers of real property and marine property. Additionally, we requestthatwe be allowed to use our system to benefitfirst responders nearby who might require assistance, including fire fighters, the police, the sheriff, et al., while remaining subjectto all limitations cited in this application as we do so.
The ME System will be operated in the field with both a PIC and a VO in accordance with FAA Policy N 8900.227 Section 14 "Operational Requirementsfor UAS" and with the following Restrictions: a) No flight will be made with a UA Gross weight exceeding 55 pounds; b) All operations mustoccur in FAA Class G airspace at no more than 400 ftAGL, at an airspeed of no more than 50 knots and no furtherthan 3/4 NM from the PIC; c) All operations must utilize a visual observer (VO). The VO and PIC must be able to communicate byvoice atall times during a flight operation; d) Operations will be restricted to flights over propertywith the permission ofthe property owner; e) The PIC must have accumulated and logged, in a manner consistent with 14 CFR 

### § 61.51 (b), a minimum of 100flight cycles and 25 hours oftotal time as a UA rotorcraft pilot and at leastten hours logged as a UA pilotwith a similar UAtype; f) All required permitswill be obtained from state and local government prior to operation; g) The ME System will not be operated over densely populated areas; h) The ME System will not be operated at air shows; i) The ME System will not be operated over anyopen-air assemblyof people; 

### j) The ME System will not be operated over heavilytrafficked roads; k) The ME System will not be operated within 5 NM of an airport or heliport; I) Operations will be restricted to dayonlyand weather conditions equivalentto VFR; m) The PIC will briefthe VO and property owner aboutthe operation and risk before the first flightateach new location; n) No flight may be made without a Pre-Flight Inspection bythe PIC before each operation to ascertain thatthe UA is in a condition safe forflight (seeAppendixA).

The PIC and VO will meetthe requirements outlined in FAA Policy N 8900.227 Section 16 personnel Qualifications. Additionally, the PIC and VO will perform maintenance on the system and will complete a course of maintenance instruction as part oftheir initial training.
We submitthatthe combination ofthe UA's lightweight, flight performance and ability, fully qualified flight crew and strict operation underthe guidelines established in 8900.227, and under all ofthe Restrictions (a) through (n) listed above, the FAA can have full confidence thatthe operation will have an equivalent orgreater level of safetythan manned aircraft performing the same mission.
The name and contact information ofthe applicant are:
dba NetOne Inc. : Robert Feiner Ph: 914-763-3365 Email:rob@netonevideo.com
The regulations from which the exemption is requested are listed below. Beside each regulation number is the page ofthe attachedAddendum upon which each may be found togetherwith our proposed equivalent level ofsafetyfor each regulation:

- 14 CFR Part 21 .................................Addendum Page 1

- 14 CFR 91.203.................................Addendum Page 1

- 14 CFR 45.23, 45.29
..........................Addendum Page 2

- 14 CFR 91.9....................................Addendum Page 2

- 14CFR 61.113, 61.133
.......................Addendum Page 2

- 14 CFR 91.109, 91.119, 91.121

..............Addendum Page 3

- 14 CFR 91.151 .................................Addendum Page 3

- 14 CFR Subpart E (91.401

- 91.417)

......Addendum Page 3

- FAA Policy 8900.227 Paragraph 16(c)(4) and Paragraph 16(e)(1)

...Addendum 1
We are prepared to modify oramend any part ofthis requestto satisfythe need for an equivalent level of safety. Please contact us atanytime ifyou require additional information or clarification. We lookforward to working with your office. Sincerely,



# R~~ Robert Feiner, NetOne Inc., Addendum containing Exemption Requests and Equivalent Level of SafetyAppendixA- Flight Manual's Appendix B- Owner's Manual for UAADDENDUM EXEMPTION REQUESTSAND EQUIVALENT LEVELOF SAFETY
NetOne Inc. requests an exemption from the following regulations as well as any additional regulations that maytechnically applyto the operation ofthe ME System:
14CFR Part 21, Subpart H:Airworthiness Certificates This part establishes the proceduresfor the issuance of an airworthiness certificate. While the FAA continuesto work to develop airworthiness standardsfor Unmanned Aerial Systems, we request an experimental certificate be issued for the ME System under either or both ofthe following provisions: 21.191 Experimental certificates. Experimental certificates are issued for the following purposes: (a) Research and development. Testing new aircraft design concepts, new aircraft equipment, new aircraft installations, new aircraft operating techniques, or new uses for aircraft. (b) Showing compliance with regulations. Conducting flight tests and other operationsto show compliance with the airworthiness regulations including flights to show compliance for issuance oftype and supplemental type certificates, flights to substantiate major design changes, and flights to show compliance with the function and reliability requirements ofthe regulations. Sincethe experimental certificate can be used for commercial purposes such as market surveys, sales demonstrations, and customer crew training, we would expect that an experimental certificate would permit ourcommercial purpose aswell. The aircraftwill not carry persons or property, will not carryfuel, and will onlyfly under strict operational requirements. Combined with the UA's light weight, being constructed primarily of carbon fiber and plastic, we propose thatthe UA will be at least as safe, if not safer, than a conventionally certificated aircraft performing the same mission. If an experimental airworthiness certificate is not appropriate forthis application, then we request an exemption of 14CFR Part 21, Subpart H, and the requirementfor an airworthiness certificate in general, citing the equivalent level of safety outlined in the previous paragraph.
14 CFR 91.203(a) & (b) Civil aircraft: Certifications required. The regulation providesthat an airworthiness certificate, with the registration number assigned to the aircraft and a registration certificate must be aboard the aircraft. Additionally, subparagraph (b) providesthatthe airworthiness certificate be "displayed atthe cabin orcockpit entrance so that it is legible to passengers or crew." At a maximum grossweight of 6.5 pounds, the UA istoo small to carry documentation, does not have an entrance, and is not capable of carrying passengers orcrew. To obtain an equivalent level of safety and meetthe intent of 91.203, we propose that documents deemed appropriate for this aircraft bythe FAA will be co-located with the crew atthe ground control station and available for inspection upon request. In orderto identifythe aircraft, we propose that the information found on airworthiness and registration certificates be permanently affixed to the aircraft via placard containing the following information plus the word "EXPERIMENTAL"to satisfythe requirement of 14CFR 45.23, which follows immediately afterthe proposed placard description below:AppendixA EXPERIMENTAL Manufacturer: DJI Innovations, Inc. 950 E BaselineAve. Ste. 210Apache Junction AZ 85119 Models: Inspire 1- t-600,
14CFR 45.23 Display of marks; general and 45.29 Size of marks. These regulations provide that each aircraft must display "N" and the aircraft's registration number in letters at least 3 inches high. Additionally, the aircraft mustdisplaythe word "EXPERIMENTAL" in letters at least2 inches high nearthe entranceto the cabin, cockpit, or pilot station. The UAdoes not have an entrance in which the word "EXPERIMENTAL" can be placed, and may not have a registration number assigned to it by the FAA.
We propose to achieve an equivalent level of safety by including the word "EXPERIMENTAL" in the placard on the top ofthe aircraft, as shown above, where the PIC, VO and others in the vicinity of the aircraftwhile it is preparing for launch will be able to see the designation. Additionally, we feel thatthe permanent placard discussed in the previous paragraph will provide the aircraft's registration information at the ground station. Finally, we will display atthe ground station a high contrastflag or bannerthat contains the words "UnmannedAircraft Ground Station" in letters 3 inches high or greater. Since the aircraft will operate within 3/4 NM ofthe ground station, the banner should be visible to anyone that observes the aircraft and chooses to investigate its point oforigin.
14CFR 91.9 Civil aircraftflight manual, marking, and placard requirements. This regulation providesthat no person mayoperate an aircraft unless a current, approved flight manual is in the aircraft. We assume thatthe intent ofthis requirement is to ensure thatflight manual information is available to the aircrew while operating the aircraft. We request an exemption to this requirement since the aircraft is notonlytoo small to carry documentation, the documentation would not be available to the crew during flight operations. To obtain an equivalent level of safety and meetthe intentof 91.9, we propose that a current, approved UA Flight Manual (AppendixA) must be available to the crew at the ground station anytime the aircraft is in, or preparing for, flight.
14 CFR 61.113 Private pilot privileges and limitations: Pilot in Command and 61.133 Commercial pilot privileges and limitations. The regulation providesthat no person that holds a private pilot certificate may act as pilot in command of an aircraftfor compensation or hire. Subparagraph (b) allows a private pilotto act as pilot in command ofan aircraft in connection with any business or employment if: (1) The flight is only incidental to that business or employment; and (2) The aircraft does not carry passengers or propertyfor compensation or hire. Our proposed operations require thatthe PIC must either
1. Hold a Commercial Pilot Certificate issued bythe FAA, and have logged 25 hours offlight experience in this type of UA, or 2. Meetthe requirements of 8900.227 para 16(c)(2)(c) "Operations without a pilot certificate" in which the PIC is required to complete "FAA private pilot ground instruction" and pass "the FAA Private Pilot written examination." Since there are currently no means available forthe pilot ofa UAS to gain the experience in an equivalent category and class in orderto applyfor a commercial pilot's license, we propose to generate an equivalent level of safety by requiring ourpilotsto complete, at a minimum, FAA commercial pilotground instruction and passthe FAA Commercial Pilotwritten examination in addition AppendixA to completing the private pilot requirements. Since the aircraft cannot carry passengers or property, we feel we meetthe intentof61.113 Subparagraph (b) even though the intent of this application is to conduct a business.
14CFR 91.109 Flight Instruction; Simulated instrumentflight and certain flight tests The regulation states that "No person mayoperate a civil aircraftthat is being used forflight instruction unless that aircraft hasfully functioning dual controls."
The ME System ground-based control station consists of a small hand-held radio transmitter and while it does not offer a second setof "controls", both the student and instructor can, and will, operate the single set of controls simultaneously. With both student and instructor having "hands-on" the controls during flight, we feel thatthistechnique meets the intent 91.109 and provides an equivalent level of safety.
14 CFR 91.119 Minimum safe altitudes: General. The regulation states that oversparsely populated areasthe aircraft cannot be operated closer than 500 feet to any person, vessel, vehicle, or structure. Since the aircraftwill be operating ata maximum of400 feetAGL, we cannot comply with this requirement.
In orderto provide an equivalent level of safety we will onlyfly over private property with a size ofat leasttwo acreswith the permission ofthe ownerofthe propertyflown over. The aircraftwill not be operated over congested areas orover any open air assembly of persons. The property owner will be briefed on the expected route offlight and the associated risks to persons and property on the ground. The aircraftwill be operated ata low altitude allowing, if a power unit fails, an emergency landing without undue hazard to persons or property on the surface. Therefore we maintain that due to the small size of the UA, the hazard to persons, vehicles and structures is minimal compared to manned aircraft, which should be considered in granting the exemption.
14CFR 91 .121 Altimeter settings. The regulation requires that aircraft shall maintain cruising altitudes by reference to an altimeter setting available within 100 NM ofthe aircraft.
The UAwill alwaysfly below 400 feetAGL and will not need to maintain cruising altitudes in orderto prevent conflict with other aircraft. An Above Ground Level altimeter measurement above the takeoff point is transmitted via radio from the UAon-board computerto the display screen held bythe PIC, providing a constantly updatedAGL readout.
14CFR 91.151 Fuel requirements for flight in VFR conditions. The regulation provides that no person may begin a flight in an airplane underday-VFR conditions unless there is enough fuel to fly to the first point of intended landing and to fly after thatfor at least 30 minutes. We feel the intention ofthis paragraph is to provide an energy reserve as a safety bufferfor delaysto landing. The UA is battery operated and the maximum duration offlight from a single battery charge is 18 minutes with a 20% reserve. Since the aircraftwill neverfly morethan 314 NM from the pointof intended landing, a full battery charge atlaunch will ensure that we meetthe reserve energy requirement ofthis paragraph. We request an exemption to the word "fuel" and ask for an equivalent interpretation with the word "energy".

14CFR Subpart E (91.401

- 91.417)

- Maintenance, Preventive Maintenance, Alterations The regulation provides thatthe operator is primarily responsible for maintaining the aircraft in
an airworthy condition, including compliance with part 39 and 43. Paragraphs 91.407 and 91.409 require thatthe aircraft be "approved for return to service by a person authorized under 43.7" after maintenance and inspection.
It is our intention thatthe PIC perform maintenance and inspection of the aircraft and "be authorized to approve the aircraftfor return to service."As provided in the Pre-Flight Checklist in AppendixA, the PIC will ensure thatthe aircraft is in an airworthy condition priorto everyflight and in addition conduct AppendixA detailed inspections after everytwo hours offlight. Maintenance performed by the PIC is limited to repairing small cracks, replacing a propeller, checking electrical connections and updating software and firmware for the on-board computer. All other maintenance will be performed by the manufacturerortheir designated repair facility. The PIC will documentwork performed in accordance with 91.417. We feel that dueto the size, construction, and simplicity of the aircraft, the PIC can ensure an equivalent level of safety.
8900.227 Paragraph 16(c)(4) PIC Medical. and Paragraph 16(e)(1) Observer Medical. This policy providesthat both the PIC and VO must have a valid FAA second-class medical certificate issued under part 67 in orderto perform as a pilot or observer. The UA maximum gross weight is 6.5 pounds, it is constructed of carbon fiber and plastic and the PIC is noton board. Both the PIC and the VO are required to be in VLOS. Given the unlikely eventthat both the PIC and VO become medically incapacitated while the aircraft is in flight, the UAwill return autonomouslyto the site of launching and land without crew intervention. Therefore, requiring the PIC and VO to meetthe same medical requirements as a commercial pilot carrying passengers in a large aircraft is an unnecessary burden.
We propose thatthe minimum medical requirements for the PIC and VO be vision corrected to 20/20 and a valid, state issued driver's license. The 20/20 vision requirement will ensure thatthe PIC and VO can see and avoid airtraffic; a licensed driver is medicallyqualified to operate a much largervehicle. AppendixA
APPENDIXA- FLIGHT MANUAL FLIGHT RESTRICTIONS a) No flight will be made with a UAGrossweight exceeding 55 pounds; b) All operations mustoccur in FAA Class G airspace at no more than 400'AGL, at an airspeed of no more than 50 knots and no further than 3/4 NM from the PIC; c) All operations must utilize a visual observer (VO). The VO and PIC must be able to communicate verbally at all times during aflight operation;d) Operations will be restricted to flights over property with the permission ofthe propertyowner; e) The PIC must have accumulated and logged, in a manner consistent with 14CFR 

### § 61.51 (b), a minimum of 100flight cycles and 25 hours oftotal time as a UA rotorcraft pilot and at leastten hours logged as a UA pilotwith a similar UAtype; f) All required permits will be obtained from state and local government priorto operation; g) The ME System will not be operated over densely populated areas; h) The ME System will not be operated at air shows; i) The ME System will not be operated over any open-air assembly of people; 

### j) The ME System will not be operated over heavilytrafficked roads; k) The ME System will not be operated within 5 NM ofan airportor heliport; I) Operations will be restricted to dayonly and weather conditions equivalentto VFR; m) The PIC will briefthe VO and propertyowneraboutthe operation and risk before the first flight ateach new location; n) No flight may be made without a successful Pre-Flight Inspection bythe PIC before each operation to ascertain thatthe UA is in a condition safe forflight.
PREFLIGHTCHECKLIST 1. Remote controller, aircraft battery, and mobile device are fully charged. 2. Propellers are mounted correctly and firmly. 3. Micro-SO card has been inserted if necessary. 4. Gimbal is functioning as normal. 5. Motors can start and are functioning as normal. 6. DJI Pilot app connected to the aircraft. TO REGAIN CONTROLAFTER LOST RADIO CONTACT If radio contact is lost and not restored within 3 seconds, an automatic Return to Homefeature is activated and will bring the UAV back to the PIC.