Pennsylvania  Ohio  West Virginia  Texas  Massachusetts www.dawood .cc 2020 Good Hope Rd. Enola PA 17025
August 6, 2015
U.S Department of Transportation, Docket Operations West Building Ground Floor, Room w12-140 1200 New Jersey Avenue, SE., Washington, DC 20590

Re: Request for Exemption for FAA Modernization and Reform Act of 2 012, Public Law, 112-95 FEB 14, 2012, Section 333.

Dear Sir or Madam,

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the “Reform Act”) and 14 C.F.R. Part 11, Dawood Engineering, Inc., (Dawood) seeks an exemption from the Federal Aviation Regulations (“FARs”) listed below:

 14 C.F.R. Part 21 Subpart H

 14 C.F.R. 45.23(b)

 14 C.F.R 45.29

 14 C.F.R. 61.113 (a) & (b)

 14 C.F.R. 91.7(a)

 14 C.F.R. 91.9(b)

 14 C.F.R. 91.109(a)

 14 C.F.R. 91.119

 14 C.F.R. 91.121

 14 C.F.R. 91.151(a)

 14 C.F.R. 91.203(a)(1)

 14 CFR Subpart E (91.401 - 91.417)

The requested exemption would authorize commercial operations u sing approved UAS’s for mapping and survey applications. These operations will be subje ct to strict operating requirements and conditions defined by the Safety Code of the A cademy of Model Aeronautics, in order to ensure at least an equivalent level of safety to cu rrently authorized operations using
manned aircrafts.Request for Exemption for FAA Modernization and Reform Act of 2 012, Public Law, 112-95 FEB 14, 2012, Section 333 for Dawood Enginee ring, Inc. Page 2
Dawood is a consulting engineering firm with a significant surv ey & mapping division. We conduct surveying and mapping on civil design projects for comm ercial and industrial developers and for municipal and governmental entities includin g departments of transportation. The proposed aerial filming will be conducted over private and public project sites with the knowledge and permit of the property’s owner(s).



### Unmanned Aircraft Systems:

Dawood seeks an exemption to operate DJI systems Phantom 3 Prof essional for compensation
or hire within the NAS. The DJI Phantom 3 Professional is a ver tical takeoff and landing (VTOL) Unmanned Aircrafts (UAS) with a Ground Control Station (GCS) ut ilizing electronic tablet or smart phone systems. The DJI Phantom 3 Professional have a maxi mum gross weight of approximately 2 pounds 11 ounces, while having a length of 16 i nches width of 16 inches, height of 8 inches, and a maximum s peed of approximately 29 kno ts. The DJI Phantom 3 Professional UAS is equipped with four main rotors; driven by L ithium Polymer battery powered electric motors. (See section entitled “Intended Equipment for Exemption” on page 9 for additional specifications)

The DJI Phantom 3 Professional UAS that will be operated by a t rained Dawood professional, will be registered in accordance with 49 U.S.C. 4 4103, Registration of Aircraft, as well as 14 C.F.R Part 47, Aircraft Registration, a nd marked in accordance with 14 C.F.R. Part 45, Identification and Registration Marking.



### 1

. CHARACTERISTICS OF THE AIRCRAFT

The UAS is a small (37.8 inches wingspan) and ultra-light (maxi mum take-off weight of 2 pounds 11 ounces) platform made of flexible foam that performs precision aerial mapping missions thanks to the on-board GPS and the related flight mana gement software (eMotion) that allows the operator to plan safely and efficiently a mission in 3D, and then monitor it in real-time. Thanks to the embedded camera, protected by a foam envelope, th e UAS takes a collection of high-definition still images that are used later to generate ma ps and contour lines of the surveyed area.Request for Exemption for FAA Modernization and Reform Act of 2 012, Public Law, 112-95 FEB 14, 2012, Section 333 for Dawood Enginee ring, Inc. Page 3



### 2. APPLICATIONS

Surveying and mapping for:

• Federal, State, and Local Infrastructure projects

• Pipelines

• Landfills

• Mining

• Utilities

• Construction Sites



### 3. APPLICABLE LEGAL STAN DARD UNDER SECTION 333

A

. Operating requirements

Grant of the exemption to Dawood will be subject to the followi ng operating conditions:

• Operations to be conducted over private, controlled-access, or public property where approved;

• Permission from the land owner/authority required before comme ncing any flight;

• Operations over congested areas shall be avoided;

• Operations must not interfere with manned aircraft operations, must yield the right of way to manned aircraft, and operators must See & Avoid other ai rcraft and obstacles
at all times

• Operations limited to Visual Flight Rules Meteorological Condi tions (VMC) and daylight hours

• Aircraft operations must remain within Visual Line of Sight (V LOS) and will be visually monitored at all times;

• VLOS guaranteed with a GPS geo-fence around operator of 0.5 mi les

• Flight ceiling pre-programed at 400 feet;

• All operations conducted within 5 miles from an airport shall only be initiated after verbal coordination with the airport authority, or air traffic control when a control tower is present at the airport;

• All operations shall comply with required permissions and perm its established by territorial, state, county or city jurisdictions; including loc al law enforcement, fire, or other appropriate governmental agencies.Request for Exemption for FAA Modernization and Reform Act of 2 012, Public Law, 112-95 FEB 14, 2012, Section 333 for Dawood Enginee ring, Inc. Page 4

B. The Specific Sections of 14 C.F.R. From Which Dawood Seeks Exemption.
Dawood requests an exemption from the following regulations as well as any additional regulations that may technically apply to the operation UAS’s:

14 C.F.R. Part 21, Subpart H: Airworthiness Certificates 14 CFR § 91.203(a)(1)
Section 91.203(a)(1) requires all civil aircraft to have a cert ificate of airworthiness. Part 21, Subpart H, entitled Airworthiness Certificates, establishes the procedural requirements for the issuance of airworthiness certificates as required by FAR § 91. 203(a)(1). Given the size of the UAS’s used, it’s very light weight and the limited operating ar ea associated with its utilization, it is unnecessary to go through the certificate of airworthiness proc ess under Part 21 Subpart H to achieve or exceed current safety levels.

Such an exemption meets the r equirements of an equivalent level of safety under Part 11 and
Section 333 of the Reform Act. The Federal Aviation Act and Sec tion 333 of the Reform Act both authorize the FAA to exempt aircraft from the requirement for a n airworthiness certificate, upon consideration of the size, weight, speed, operational capabilit y, and proximity to airports and populated areas of the UAS involved. In this case, an analysis of these different criteria demonstrates that the UAS operated without an airworthiness cer tificate, under the conditions proposed in that exemption, will be at least as safe, or safer, than a conventional aircraft with an
airworthiness certificate.

Operations under this exemption will be tightly controlled and monitored by the operator through the constant communication link between the UAS and the ground station. Moreover, a geo-fence and a flight ceiling will be defined by the operator before eac h flight to make sure the UAS will not go beyond the defined flight envelop.

14 C.F.R. § 45.23 & 14 C.F.R. § 45.29: Display of marks; size o f marks



### .

These regulations provide that each aircraft must display "N" a nd the aircraft's registration number in letters at least 3 inches high. Additionally, the aircraft m ust display the word "EXPERIMENTAL" in letters at least 2 inches high near the entrance to the cabi n, cockpit, or pilot station. Given the size of the UAS’s, this requirement may be impossible to match.Request for Exemption for FAA Modernization and Reform Act of 2 012, Public Law, 112-95 FEB 14, 2012, Section 333 for Dawood Enginee ring, Inc. Page 5

The equivalent level of safety w ill be achieved by having the o perator display at the ground station a high contrast flag or banner that contains the words "Unmanne d Aircraft System Ground Station" in letters 3 inches high or greater. Since the aircraft will op erate within 1/2 Nautical Miles of the ground station, the banner should be visible to anyone that observes the aircra ft and chooses to investigate its point of origin.

14 C.F.R. § 61.113 (a) & (b): Private pilot privileges and limitations: Pilot in command
This regulation limits private pilots to non-commercial operati ons. Because the UAS will not carry a pilot or passengers, the proposed operations can achieve the equivalent level of safety of current operations by requiring the pilot operating the aircraf t to have completed a UAS flight training course of 10 hours before flying a UAS. Unlike a conve ntional aircraft that carries the pilot and passengers, the UAS will be remotely controlled with no liv ing thing or cargo on board. The area of operation will be controlled and restricted, and all fl ights will be planned and coordinated in advance. The risks associated with the operation of the UAS are so diminished from the level of risk associated with commercial operations contemplated by P art 61 when drafted, that allowing operations of the UAS as requested with a pilot who has met the minimum requirements of this document exceeds the present level of safety achieved by 14 C.F .R. §61.113 (a) & (b).

14 C.F.R. 91.7 (a): Civil aircraft airworthiness
This regulation requires that no person may operate a civil air craft unless it is in airworthy
condition. As there will be no airworthiness certificate issued for the aircraft, should this exemption be granted, no FAA regulatory standard will exist for determini ng airworthiness. Given the size of the aircraft and the requirem ents contained in th e DJI Manual f or maintenance and use of safety checklists prior to each flight, as set forth in this document, an equivalent level of safety will be provided.

14 C.F.R. § 91.9(b): Civil aircraft flight manual, marking, and placard requirements.
This regulation provides that no person may operate an aircraft unless a current, approved flight
manual is in the aircraft. We assume that the intent of this re quirement is to ensure that flight manual information is available to the aircrew while operating the aircraft. We request an exemption to this requirement since the aircraft is not only to o small to carry documentation, theRequest for Exemption for FAA Modernization and Reform Act of 2 012, Public Law, 112-95 FEB 14, 2012, Section 333 for Dawood Enginee ring, Inc. Page 6
documentation would not be available to the crew. The equivalen t level of safety will be achieved by keeping a hard copy of the flight manual in the UAS transpor tation box.

14 C.F.R. § 91.109(a): Flight instruction; Simulated instrument flight and certain flight tests.
This regulation provides that "No person may operate a civil ai rcraft that is being used for flight instruction unless that aircraft has fully functioning dual con trols." Flight instruction will be accomplished through an elaborated training program, using firs t the simulation mode of the flight management software. The equivalent level of safety during the training will be achieved by the manufacturer providing the training.

14 CFR § 91.119: Minimum Safe Altitudes
The regulation provides that over sparsely populated areas the aircraft cannot be operated closer than 500 feet to any person, vessel, vehicle, or structure. Sin ce the aircraft will be operating at a maximum of 400 feet AGL, the UAS cannot comply with this requir ement. The equivalent level of safety will be achieved because the UAS will only fly over property with the permission of the landowner. The operator will define befor e every flight a working area radius and a flight area ceiling, preventing the UAS to go beyond the flight area.

The landowner and the persons who may be on the ground in the f light area will be briefed of the expected route of flight and the associated risks to persons an d property on the ground. Due to the small size of the UAS, the hazard to persons, vessels, vehi cles, and structures is not comparable to manned aircraft and should be considered in grant ing the exemption. Moreover, the aircraft will not be operated over congested areas nor over any open-air assembly of persons. The aircraft will be operated at an altitude allowing, if a pow er unit fails, an emergency landing without undue hazard to persons or property on the surface.

14 CFR 91.121 – Altimeter settings
This section requires that each person operating an aircraft sh all maintain the cruising altitude or flight level of that aircraft, as the case may be, by reference to an altimeter that is set, when operating below 18,000 feet MSL to:

 The current reported altimeter setting of a station along the route and within 100 nauticalRequest for Exemption for FAA Modernization and Reform Act of 2 012, Public Law, 112-95 FEB 14, 2012, Section 333 for Dawood Enginee ring, Inc. Page 7
miles of the aircraft;

 If there is no station within the area prescribed in paragraph (a)(1)(i) of this section, the current reported altimeter setting of an appropriate available station;

 In the case of an aircraft not equipped with a radio, the elev ation of the departure airport or an appropriate altimeter setting available before departure.

To provide an equivalent level of s afety, the UAS autopilot cal culates the reference altitude (ground level) with the on-board GPS during the pre-flight test s. The GPS and barometer data are merged with respect to their respective precisions. The GPS provides reliable information to correct potential barometric bias, while rapid variations in al titude are detected through the
barometer. Hence, barometric bias induced by environmental factors is reje cted.

14 C.F.R. § 91.151(a): Fuel Requirements for Flight in VFR Cond itions
The regulation provides that no person may begin a flight in an airplane under day-VFR conditions unless there is enough fuel to fly to the first point of intend ed landing and to fly after that for at
least 30 minutes.

Dawood believes that an equivalent level of safety is already a chieved with the specific procedure preventing the UAS to accept a take-off order if the battery le vel is below a given value.

14 CFR Subpart E (91.401 - 91.417) - Maintenance, Preventive Ma intenance, and Alterations
The regulation provides that the operator is primarily responsi ble for maintaining the aircraft in an airworthy condition, including compliance with Parts 39 and 43. Paragraphs 91.407 and 91.409 require that the aircraft be "approved for return to service by a person authorized under 43.7" after maintenance and inspection. Section 91.409(a)(2) requires an an nual inspection for the issuance of an airworthiness certificate. Section 91.417(a) requires the owner or operator to keep records showing certain maintenance work that has been accomplished by certificated mechanics, under Part 43, or licensed pilots and records of approval of the airc raft for return to service.

Dawood proposes that the maintenance of the UAS will be accompl ished by the owner/operator according to the maintenance manual. Moreover, the operator is the person most familiar withRequest for Exemption for FAA Modernization and Reform Act of 2 012, Public Law, 112-95 FEB 14, 2012, Section 333 for Dawood Enginee ring, Inc. Page 8

the aircraft and is best suited to maintain the aircraft in an airworthy condition and to ensure an equivalent level of safety. Finally, before every flight, the U AS will run automatically a sequence of pre-flight tests to make sure that every sensor and every cr itical part is running properly. If a problem is detected, the UAS will not be able operated.

Benefits to the Public as a Whole
It is our belief that UAS’s will provide additional and improve d access to high quality aerial mapping, reducing environmental pollution from larger aircraft, and produce training and development opportunities for survey professionals resulting in additional jobs.

In Summary (For the Federal Register):
Dawood is seeking exemption from Section 333 of the FAA Moderni zation and Reform Act of 2012 (the “Reform Act”) and 14 C.F.R. Part 11 in order to provi de unmanned Aerial Surveying and Mapping. Similar exemptions have been granted to companies within our industry because of the potential benefits to the public, improved safety, and l ower impact to property owners.

Respectfully Submitted,

Vincent J. Paparella, PLS Vice President Dawood Engineering, Inc. 2020 Good Hope Rd. Enola, PA 17025 717-732-8576 vpaparella@dawood.ccRequest for Exemption for FAA Modernization and Reform Act of 2 012, Public Law, 112-95 FEB 14, 2012, Section 333 for Dawood Enginee ring, Inc. Page 9

Intended Equipment for Exemption

Aircraft: DJI Phantom 3 Professional Operating Frequency/Sensitivity : 2.400- 2.483 GHz/Radio Sensitivity: -101 dBm Manufactures Website : http://www.dji.com/

Aircraft Performance

Maximum Altitude: 19,685 ft. (6000 m) Operational Range: 6,560 ft. (2,000 m) Hover Accuracy: (Ready to Fly) Vertical: 0.1m; Horizontal: 1.5m Precision Flight and Stable Hovering Flight Time: 23 Minutes Battery Life (quad copter): 23 Minutes Weight (Battery & Propellers included): 1280 g Max Ascent Speed: 5m/s Max Descent Speed: 3m/s Max Flight Speed: 16m/s (Not Recommended) Operating Temperature: -10°C - 40°C Self-Tightening Propellers For in-depth info see http://www.dji.com/product/phantom-3/specRequest for Exemption for FAA Modernization and Reform Act of 2 012, Public Law, 112-95 FEB 14, 2012, Section 333 for Dawood Enginee ring, Inc. Page 10

Maintenance

To ensure safe operational control a maintenance schedule will be followed, a personal tailored maintenance manual has been created, and quality replacement pa rt will be used.
Inspection : Before and after every flight, the quadcopter's operational c ondition will be inspected for damage and deterior ation, paying attention to the props for damage, cracks or ware and the UASs fuselage for damage. If damage, cracks or unu sual ware is detected the flight will be suspended until proper repairs have been made.

There is no intention in modifying aircraft beyond factory spec ifications. The UAS will be in compliance with the FAA airworthiness regulations.



### Safety Concerns
Prop guards: Prop guards will always be in use during commercial flights.
Hazards Spotter : To ensure safety, either the listing agent, seller, contracto r, owner or another party, will be on site to review and observe hazards before and during the flight.
Population of Intended Areas : To ensure safety, all non-essential personnel will be removed from the area. There will be no flight over heavily populated a reas like stadiums, schools, malls, casinos, and the like during operating hours.
Airports: According FAA rules and to ensure pilot(s) safety, there will n o flight in or around airports unless explicit permission is granted according to cur rent FAA regulations.

Weather: To ensure safety of spotter, agents, property owners, pet and w ildlife flights will be conducted in optimal weather conditions. Flights will not be co nducted in winds above 20 mph.

Return-to-Home Feature: In the event the DJI Phantom 3 Professional v2 H3-3D loses sign al or runs critically low on battery the UAS has a GPS controlled ret urn to home feature. The "home" is set upon flight startup.

 Auto Return-to-Home & Landing

 See Pre-Flight Checklist Exhibit A
Flying in Confined Areas: There is a high probability of flying in confined spaces, aroun d residential properties. Pilot and spotter will be in constant c ommunication by two way radio, or cell phone, or other approved FAA communications device when ge ographically separated during flight to ensure awareness of obstacles, hazards and UAS locati on.

Line of Site: The UAS will always be within the line of site of the pilot and spotter. If the UAS cannot be seen the return home failsafe will be used to regain visual control.
Height : Fights will not exceed 400 ft AGL above subject properties at any time.Request for Exemption for FAA Modernization and Reform Act of 2 012, Public Law, 112-95 FEB 14, 2012, Section 333 for Dawood Enginee ring, Inc. Page 11

Potential Hazards
The following are potential hazards that may, or may not be, pr esent during flight operations. The Pilot and Spotter will be aware of:

 Other UASs

 Houses, Commercial Buildings, Shops, and Out Buildings

 Power Lines, Low Voltage Lines, High Voltage Lines, Cable

 Lines

 Trees, Shrubs, and Hedges

 Automobiles and RVs

 Wildlife, both Land and Air

 Rivers, Lakes, Ponds, Sounds, Straits, and Other Bodies of Wat er

 Unaccounted for People

 Unaccounted for Pets

 Conditions as set forth in the DJI Manual 

### Operational Conditions
To capture high resolution images and video operational conditi ons will be closely monitored because showcasing a property in the best light is and image qu ality is the utmost client priority.
Day Time

 Sunny Weather is Highly Preferred

 Little to No Cloud Cover

 Zero to Low Wind Speeds

 High Visibility Conditions

*No night-time operations are permitted. 

### Pre-Flight Checklist
Prior to every flight, the pilot will go through a pre-flight c hecklist. The checklist will then be filed with every property's file in the event of an audit.
Preflight Checklist: SEE Exhibit A


### Active Flight Operations
Exercise continuous control of UAS, monitor potential hazards, be aware of changing environments that may present hazards. UAS will always be in vi ew of Pilot and spotter. There will be a strict flight ceiling of 400 ft AGL. All flight will be done in accordance with current FAA rules and the conditions set forth in this document.Request for Exemption for FAA Modernization and Reform Act of 2 012, Public Law, 112-95 FEB 14, 2012, Section 333 for Dawood Enginee ring, Inc. Page 12



### Exhibit A
Pre-Flight Checklist
Flight Operation Location: ________________________

Pilot:_________________________

Date:_________________________

 Conduct Walk Around of Flight Area  Identify Potential Hazards with Spotter  Locate Safe Launch & Landing Area  Set Spotter (Spotter May Change Location due to Filming Angle) Secure all Pets  Request on Non-Essential Perso nnel to Remain Behind Pilot  Unpack All Equipment from Transportation Case  Inspect UAS for damage, ware and proper flight setup according to the DJI manual. If no damage or unusual ware is detected proceed to the next step. If damage is detected the flight will be aborted until proper repairs are completed.  If the UAS is deemed flight worthy - Power Up Remote  Power Up GoPro  Initiate Video Recording  Power Up DJI Phantom 3 Professional  Launch DJI Phantom 3 Professional  Conduct Flight Operations  Land DJI Phantom 3 Professional in Designated Landing Area  Power Down DJI Phantom 3 Professional  Turn Off Video Recording  Power Down GoPro  Power Down Remote  Inspect UAS for damage and ware  Put All Equipment Back into Transportation Case



### Pilot Signature______

_____________________________________