Date:	20150 516 Revision:	1.0 Revision:1.0 Page 1 of 3 PROPRIETARY	INFORMATION

- NOT	FOR	PUBLIC	RELEASE PROPRIETARY INFORMATION

- NOT	FOR	PUBLIC	RELEA SE U.S. Department of T ransportation Docket M anagement S ystem 1200 New J ersey Ave., SE Washington, DC 20590

Re: Exemption Request Under Section 333 of the FAA Reform Act and Part 11 of the Federal Aviation Regulations Docket No. FAA-2015-0975

Dear Sir or Madam:

Pursuant t o Section 333 of t he F AA M odernization and Reform A ct of 2012 (the “ Reform A ct”) and 14 C.F.R. Part 11, Rupestrian CyberServices, seeks a n exemption from F ederal A viation Regulations (“ FARs”) detailed below f or the DJI Phantom 2 Vision+, DJI Phantom 2, and DJI Phantom 3.

The re quested exemption woul d support a n application for a c ommercial Ce rtificate of Authorization (COA) to use t he s ystem t o support ; photography of a rchaeological f eatures, aerial photography, and mapping and surveying. By approving these e xemptions, the F AA w ill c reate benefits t o industries be nefiting from a pplications of us ing multi-rotor UA S ystems a nd the environment w hich are ul timately in the publ ic i nterest. 1

Each DJI UAS weighs l ess t han 55 lbs. fully loaded, will be ope rated at a s peed no more t ha n 87 knots, carry neither a pi lot nor passenger, carry no explosive m aterials or flammable l iquids, and operate e xclusively within an approved COA a irspace. All D JI UA S ystems us e a ra dio frequency spectrum f

or operation and control t hat c omplies w ith Federal Com munications Commission (“FCC”) requirements a nd has i ntegrated safety features a s de scribed within user manuals f or each DJI UAS. The U AS a re e quipped with redundant s afety mechanisms a llowing them t o operate s a fely after experiencing certain-flight f ailures. If a l ost-link event oc curs, including the l oss of ground communications a nd/or the l oss of a G PS s ignal, the U AS ha ve t he ability to perform a pre -coordinated, predictable, automated flight m aneuver and return to a predetermined location within a de signated security parameter for landing. The U AS f urther have t he a bility to abort a f light i n the e vent of unpre dicted obstacles or emergencies. The a ircraft w ill be ope rated in the f ield with both a P ilot i n Command (PIC) and a ground -based Visual O bserver (VO) in accordance w it h FAA O rder 8900.1, vol. 16 "Unmanned Aircraft Systems" w ith the f

ollowing additional re strictions:

- All operations will be conducted IAW the Air Traffic Organization (ATO) Certificate of Waiver or Authorization (COA).

- All UAS operations will remain clear of manned aviation operations and activities at all times.

- All operations will occur at altitudes no more than 400' AGL

1 We will provide an explanation of equivalent level of safety for each exemption request, but will point back to the benefits to the environment to justify why the requests are in the public interest.PROPRIETARY INFORMATION

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Date:	20150 516 Revision:	1.0 Revision:1.0 Page 2 of 3 PROPRIETARY	INFORMATION

- NOT	FOR	PUBLIC	RELEASE - Operations will be operated over private property or publi c lands with the permission of the land owner

- The UAS will not be operated by a PIC from any moving device.

- The aircraft will not be operated within 5 NM of an airport or heliport unless prior coordination with ATC or airport management is made.

- Oper ations will be limited to day, visual meteorological conditions

- Aircraft will remain within Visual Line of Sight of the PIC and VO at all times.

- While the aircraft is airborne, the VO will be positioned within voice distance to the PIC

The PIC and VO will meet the requirements outlined in FAA Order 8900.1, volume 16, chapter 4

. The PIC will hold at least a recreational or sport pilot certificate. Additionally, the PIC will perform maintenance on the system and will complete a course of maintenance in struction as part of their initial training. Due to the simplicity of the system, we do not anticipate the need for a supplemental pilot.

We submit that the combination of the aircraft's light weight, historically demonstrated flight performance, fully q ualified flight crew and strict operation under the guidelines established in 8900.1, the FAA can have confidence that the operation will have an equivalent or greater level of safety of manned aircraft performing the same mission.

The name and contact information of the applicant is :
Rupestrian CyberServices Attn: Robert Mark Ph: 928

- 526

- 3625 Email: rmark@infomagic.net

The regulations from which the exemption is requested are as follows:

- 14 CFR Part 21

- 14 CFR 91.203

- 14 CFR 45 .23, 45.29

- 14 CFR 91.9

- 14 CFR 61.113, 61.133

- 14 CFR 91.109, 91.119

- 14 CFR 91.121, 91.151

- 14 CFR Subpart E (91.401

- 91.417)

- 14 CFR 91.103(b)PROPRIETARY INFORMATION

- NOT	FOR	PUBLIC	RELEA SE

Date:	20150 516 Revision:	1.0 Revision:1.0 Page 3 of 3 PROPRIETARY	INFORMATION - NOT	FOR	PUBLIC	RELEASE We are prepared to modify or amend any part of this request to satisfy the need for an equivalen t level of safety. We look forward to working with your office. Please contact us at any time if you require additional information or clarification.

Sincerely,

Robert Mark Owner Rupestrian CyberServices

Appendices: A. Exemption Request and Equivalent Level of Safety B. Privacy Issues C. Safety Assessment D. Maintenance Procedures E. User Manuals F. Public Interest G. DJI Multi-rotor Training Program