May 4, 2015 

United States Department of Transportation 

Federal Aviation Administration 

Docket Management System 

1200 New Jersey 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: Docket FAA 2015-0931; Amendment to Petition for Exemption of Firestorm 

Emergency Services Ltd. d/b/a Firestorm UAV under Section 333 of the FAA 

Modernization and Reform Act, 49 U.S.C. 44701(±), and 14 C.F.R. Part 11, to operate 

during nighttime conditions 

On behalf of Firestonn 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 

patent pending Intelligent Radio Direction Finding (iRDF) system to provide emergency services 

such as search and rescue, preventing runaways of persons with dementia, and gee-locating a 

firefighter in a building filled with smoke, in both rural and urban environments. Please consider 

this document as part of the petition filed dated April4, 2015. 

In its petition, Firestorm stated that it "will limit its operations to daytime Visual Flight Rules 

("VFR") plus 30 minutes before sunrise and 30 minutes after sunset (dusk), with each operation 

ending no later than 30 minutes after sunset. ... The UA V is equipped with LED lighting visible 

for 3 miles. Accordingly, we do not believe an exemption from 14 C.F.R. 91.209 is necessary." 

The amendment to the petition sets forth the public interest in support of nighttime 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 Locator beacons 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. 1 Washington, D.C. 20036-15641202.887.4000 I fax 202.887.4288 I akingump com 
Firestorm Emergency Services Ltd. Amendment to Petition for Exemption 

May 4, 2015 

Page 2 

and observed with little or no interactions/risk to the animal that is being tracked or the biologist. 

The critical element is the speed to recovery that mitigates damage both bodily and financial." 

In search and rescue involving some form of radio transmission time is of the essence. Those 

involved in the first responder world know that the survival percentage of victims decreases with 

every hour passing. 

Unfortunately, most of these events happen in rural environments where access to the event is 

often blocked by terrain and man-made structures. The art of radio 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 of the radio frequency emanations to ascertain the 

line of bearing from the searchers location to the victim. The next step is to move location from 

the initial reading and take a second line of bearing with enough variance from the first that it 

creates an accurately that they can create an intersection. At this intersection is the most probable 

location of the source of the signal. Further information about the use of this technology, which 

contains commercially sensitive and propriety material, is being provided separately to the FAA. 

Historically most aviation rescue units will not participate in search-and-rescue radio direction 

finding work at night because of the 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 of the UAV connected to a Panasonic 7 

inch tablet, the results of the automatic radio direction finding are relayed to the ground station 

next to the UA V pilot. If the beacon is a 406 MHz ELT, PLB, or Epirb, it will decode the signal 

and display the result on the map on the ground station software. Other beacons 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 reading would be available in less than five minutes from set up. 

Based on terrain clearance and location to problematic structures, the altitude would be limited to 

400 feet AGL. The Tiger strike equipped UAV would then fly right or left of the initial reading 

to establish the second line of bearing at no greater than 3,000 feet or line of sight of the lights on 

the UAV. Due to the very narrow aperture of this antenna (2-5) degrees, the accuracy of the 

results would be greater than any other commercial equipment other than military. If no signal is 
Firestorm Emergency Services Ltd. Amendment to Petition for Exemption 

May 4, 2015 

Page3 

determined in either scenario the speed of deployment by the firestorm UA V equipped with the 

Tiger strike technology allows sampling for the signal to occur at a much higher rate than by 

traveling by car along roads. 

Operations under nighttime conditions will maintain an equivalent level of safety. 

Firestorm's nighttime operations will maintain an equivalent level of safety 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-GPS jamming capability to increase the margin of safety of 

its UAS. 

Sincerely, 

rray Craig, Firestorm Emergency Services Ltd.