May4, 2015
United States DepartmentofTransportation FederalAviationAdministration DocketManagement System 1200NewJersey Avenue, NE Washington, DC 20590
Filed in www.regulations.gov 

# AkinGump

STRAUSS HAUER & FELD LLP

GREGORY S. WALDEN +1 202.887.4213/fax: +1 202.887.4288 gswalden@akingump.com

Re: DocketFAA2015-0931; Amendmentto Petitionfor Exemption ofFirestorm Emergency Services Ltd. d/b/aFirestorm UAVunder Section 333 ofthe FAA Modernization and ReformAct, 49 U.S.C. 44701(±), and 14 C.F.R. Part 11, to operate during nighttime conditions
On behalfofFirestonn Emergency Services Ltd. d/b/a Firestorm UA V ("Firestorm"), we hereby submit this amendment to the petition for an exemption filed on April 4, see Docket FAA 2015- 0931, to allow Firestorm to operate the Spreading Wings 1000+ UAV manufactured by DJI modified by Troy Built Models called TigerStrike® TF, under nighttime conditions, to carry the patentpendingIntelligent Radio Direction Finding (iRDF) system to provide emergency services such as search and rescue, preventing runaways ofpersons with dementia, and gee-locating a firefighter in a buildingfilled with smoke, in both rural and urban environments. Please consider this document as part ofthepetition filed dated April4,2015.
In its petition, Firestorm stated that it "will limit its operations to daytime Visual Flight Rules ("VFR") plus 30minutes before sunrise and 30 minutes after sunset (dusk), with each operation endingno later than 30minutes after sunset.

...The UA V is equipped with LED lightingvisible for 3miles. Accordingly, we do notbelieve an exemption from 14C.F.R. 91.209 is necessary."
The amendment to the petition sets forth the public interest in support ofnighttime operations and the operational and equipment consideration that achieve an equivalent level of safety for such operations. 

### Operations during nighttime hours are in the public interest. As Firestorm stated in its petition, "UA V operations will substantially benefit wandering dementia patients with wrist beacons, Emergency Locatorbeacons both 406 and 121.5 used by ground teams, geolocation of the firefighters' radio in wild land fire and structure fires by using the TigerStrike® technology to geolocate them using their existing radios as a beacon. Lost hikers and skiers who are equipped with the FRS radios can also be geo-located effectively. Tagged wildlife can be located

RobertS. Strauss Building 11333 New Hampshire Avenue, N.W. 1Washington, D.C. 20036-15641202.887.4000 Ifax 202.887.4288 I akingump comFirestorm Emergency Services Ltd. Amendment to Petition for Exemption May 4, 2015 Page 2
and observed with little orno interactions/riskto the animal that is being tracked or the biologist. The critical elementis the speed to recovery that mitigates damage bothbodily and financial."
In search and rescue involving some form ofradio transmission time is of the essence. Those involved in the first responder world know that the survivalpercentage ofvictims decreases with every hourpassing. Unfortunately, most ofthese events happen in rural environments where access to the event is often blocked by terrain and man-made structures. The art ofradio direction finding ("RFI") is further complicated by reflections and man-made interference. The process is very simple: discover the most accurate angle to the source ofthe radio frequency emanations to ascertain the line ofbearing from the searchers location to the victim. The next step is to move location from the initial reading and take a second line ofbearing with enough variance from the first that it creates an accurately that they can create an intersection. Atthis intersection is the mostprobable location ofthe source ofthe signal. Further information about the use ofthis technology, which contains commercially sensitive and proprietymaterial, is beingprovided separately to the FAA. Historically most aviation rescue units will not participate in search-and-rescue radio direction finding work at night because ofthe proximity to terrain and in many cases inclement weather. However, once they know that the ground team has geo-located the signal they will come and hoist out any victims. In certain states, Civil Air Patrol (CAP) tasked by the USAF Rescue Coordination Center (AFRCC) with inland search and rescue responsibility will not fly at night, even in good weather. So this becomes an enormous safety factor for both the searchers, ground team members and pilots that are pressed into service at night to find someone in distress.
With the integration that has been fitted to the bottom ofthe UAV connected to a Panasonic 7 inch tablet, the results ofthe automatic radio direction finding are relayed to the ground station next to the UA V pilot. Ifthe beacon is a406 MHz ELT, PLB, or Epirb, it will decode the signal and display the result on the map on the ground station software. Otherbeacons like Alzheimer's bracelets, special needs bracelets, VHF UHF handheld radios or other devices that are transmitting will show up as a line of bearing from the UA V pilot's location on the map instantly. This first readingwould be available in less than five minutes from setup. Based onterrain clearance and location to problematic structures, the altitude wouldbe limited to 400 feet AGL. The Tiger strike equipped UAV would then fly right or left ofthe initial reading to establish the second line ofbearing at no greater than 3,000feet orline ofsight ofthe lights on the UAV. Due to the very narrow aperture of this antenna (2-5) degrees, the accuracy of the results would be greaterthan any other commercial equipment otherthan military. Ifno signal isFirestorm Emergency Services Ltd. Amendmentto Petitionfor Exemption May 4, 2015 Page3
determined in either scenario the speed ofdeployment by the firestorm UAV equipped with the Tiger strike technology allows sampling for the signal to occur at a much higher rate than by travelingbycaralongroads. Operations undernighttimeconditionswillmaintainan equivalentlevelof safety. Firestorm's nighttime operations will maintain an equivalent level ofsafety for the reasons sets forth in its petition (i.e., operations will be conducted under 400 ft. AGL and within the line of sight of the operator) plus the fact that the UAV will be lighted sufficiently to be seen by the operator, other aircraft operators in that same airspace, and other persons on the ground. Firestorm has added a 1.5GHz anti-GPSjamming capability to increase the margin of safety of its UAS. Sincerely,

rrayCraig, FirestormEmergencyServices Ltd.