www.tradecraftuas.com 6 December 2014

U.S. Department of Transportation
Docket Management System
1200 New Jersey Ave., SE
Washington, DC 20590

RE: Exemption request under Section 333 of the FAA Modernization and Reform

Act of 2012 and 14 C.F.R. Part 11

Dear Sir or Madam:

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (FMRA) and

14 C.F.R. Part 11, TradeCraft LLC requests exemptions from several provisions of the
Federal Aviation Regulations (FAR), specifically portions of 14 C.F.R Parts 45, 61, and
91 to allow among other things, commercial operations of its DJI Inspire 1 small

Unmanned Aircraft S ystem (sUAS) in the Continental United States (CONUS) by

individuals who have FAA Commercial Rotorcraft I nstrument certificates a nd have
completed TradeCra ft’s training program for commercial operation of sUAS.

The Inspire i s an electric powered rotary wing sUAS that is capable of transmitting live
airborne video images and location information to a Ground Control Station (GCS). T he
Inspire stores the photo graphs and data on board and makes them available for
download after completion of the flight. The Inspire is 22 in x 22 in x 8 in and weighs

6.4 pounds, well under the 55 lbs mandated in the FMRA

. The Inspire can conduct
hovering flight and has a maximu m cruising speed of 42 knots

. It is battery powered, has a flight endurance of 22 minutes and can operate in t emperatures ranging from 0°

to 40° C

. The Inspire ’s omni

- directional ante nna has a range of 2.1 km and operates in

the 2.420

– 2.483 GHz frequen cy range.

DJI is a leader in the sUAS rotorcraft market. There are thousands of DJI products
being used in the recreational and hobby industry. T he Inspire can operate safely in the
National Airspace System (NAS), without posing a threat to national secu rity, by
operating in accordance with the requirements discussed herein. Additionally,
TradeCraft will utilize commercial rated pilots with extensive sUAS experience that will

set them apart from most 333 applicants.

The Inspire ’s capabilities, along wit h TradeCraft personnel’s prior experience
conducting s UAS training, maintenance, and operations within the Department of

Defense make it ideally suited to conduct commercial operations such as agriculture,Page 2

www.tradecraftuas.com aerial surveying, and aerial photography within Vi sual Line of Sight (VLOS). Use of the

Inspire reduces the need to operate manned aircraft, decreasing the risk to the pilot

, crew, and those on the ground as the Inspire is carried to the area of operations and not

flown there.

As a result of the Inspire ’s size, weight, maximum speed, operational capability, and safety record the Inspire does not create a hazard to users of the NAS or the public.
Neither does it pose a threat to national security. The petitioner states that, given the

clear direction in Section 333, the strong equivalent level of safety surrounding the
proposed operations, and the significant public benefit, including enhanced safety,
reduction in environmental impacts, including reduced emissions associated with
allowing UAS. Therefore , the FAA should grant TradeCraft the requested exemptions. Alternatively, if the FAA finds that modification of TradeCraft application is required for
safe operation of the Inspire in the NAS, TradeCraft requests that the FAA delineate the
required modif ications and either process TradeCraft application as if the modifications
were already made or allow TradeCraft to amend its application to incorporate the FAA’s findings.

The name and email address of the applicant are:

TradeCraft LLC

email: tradecraftuas@gmail.comPage 3

www.tradecraftuas.com Regulations from which the exemption is requested:

14 C.F.R Part 21
14 C.F.R. 45.23 (b )
14 C.F.R. 91.7 (a)
14 C.F.R. 91.9 (b) (2)

14 C.F.R. 91.103

14 C.F.R. 91.109

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) & (b)
14 C.F.R. 91.405 (a)
14 C.F.R. 407 (a) (1)
14 C.F.R. 409 (a) (2)
14 C.F.R. 417 (a) & (b)

This e xemption application is expressly submitted to fulfill Congress goal in passing
Section 333 (a) through (c) of the Reform Act. This law directs the Secretary of
Transportation to consider whether certain unmanned aircraft systems may operate
safely in the NAS before completion of the rulem aking required under section 332 of the
Reform Act. In making this determination, the Secretary is required to determine which
types of UAS do not create a hazard to users of the NAS or the public or pose a threat

to nat ional security in light of the following:

• The UAS size, weight, speed, and operational capability;

• Operation of the UAS in close proximity to airports and populated areas; and

• Operation of the UAS within visual line of sight of the operator.

Reform Act § 333 (a). Lastly, if the Secretary determines that such vehicles “may
operate in the national airspace system, the Secretary shall establish requirements for
the safe operation of such aircraft in the national airspace system.” Id. §333(c)
(emphasis adde d) 1

The FRMA expressly grants the FAA the authority to issue exemptions. This statutory
authority by its terms includes exempting civil aircraft, as the term is defined under
§40101 of the Ac t that includes sUAS, from the requirement that all civil aircr aft must

have a current airworthiness certificate.

The Administrator may grant an exemption from a requirement of a regulation
prescribed under subsection (a) or (b) of this section or any sections 44702

- 44716 of

this title if the Administrator finds the exemption in the public interest. 49 U.S.C.
§44701(f) See also 49U.S.C. §44711(a); 49 U.S.C. 44704; 14 C.F.R. §91.203 (a) (1).

1 Applicant interprets this provision to place the duty on the Administrator to not only process applications
for exemptions under section 333, but for the Administrator to craft conditions for the operation of the
UAS, if it should be determined that the conditions set fourth herein do not fulfill the statutory
requirements for approval.Page 4

www.tradecraftuas.com TradeCraft LLC sUAS are rotorcraft, weighing 55 lbs. or less, including payload. They
operate under normal conditions at a spee d of no more than 50 knots and have the
capability to hover and, move in the vertical and horizontal plane simultaneously. They
will operate within line o f sight and will only operate under strict risk mitigation
guidelines as outlined in the TradeCraft L LC Commercial sUAS Flight Oper ations Procedures (hereinafter “the Manual”) 2 . Such operations will insure that the sUAS will
“not create a hazard to users of the national airspace system or the public” 3

Given the small size of the sUAS involved and the re stricted environment within which they will operate, the applicant falls squarely within the zone of safety (an equivalent
level of safety) in which Congress envisioned that the FAA must, by exemption, allow
commercial operations of UAS to commence immedia tely. Also, due to the size of the
UAS and the areas in which the relevant sUAS will operate, approval of the application
presents no national security issue. Given the clear direction in Section 333 of the
Reform Act, the authority contained in the Fede ral Aviation Act as amended; the strong equivalent level of safety surrounding the proposed operations, and the significant
public benefit, including enhanced safety, reduction in environmental impacts, including
reduced emissions associated with allowing s UAS for commercial operations, the grant
requested exemptions is in the public interest. Accordingly, the applicant respectfully
requests that FAA grant the requested exemption without delay.

Airworthiness

The Inspire is safe and fit for operation in t he NAS under the conditions listed herein. In
support of this application, TradeCraft LLC provide s the following documents, the
Inspire Flight and Maintenance Manual and the TradeCraft LLC Commercial sUAS
Flight Operations P rocedure s

.

2 Applicant provides this manual as a Confidential document under 14 C.F.R. 11.35 (b) as the entire

man ual contains proprietary information that the applicant has not and will not share with others. The

manual contains operating conditions and procedures that are not available to the public and are
protected from release under the Freedom of Information Ac t 5 USC 552 et.seq.

3 Reform Act Section 333 (b)Page 5

www.tradecraftuas.com Mandato ry Operating Conditions

TradeCraft LLC proposes that the grant of the exemption be subject to the following
mandatory conditions which are based upon operating conditions set forth for operation

of s UAS for commercial use pursuant to Certificates of Waive r or Authorization, with

additional restrictions.

• Class III Flight Physical

• Air craft will not exceed 42 knots

• Aircraft to remain wit hin Visual Line of Sight (VLOS)

• Operations to occur during daylight hours

• Above Ground Level (AGL) altitu de to be restrict ed to 400 feet

• Pilot in Command wi ll file a NOTAM for each flight

Pilot Qualifications

Tradecraft proposes the following sUAS pilots:

Pilot in Command Qualifications Hours

Pilot 1

FAA Certificate: 3233322 FAA Commercial
Instrument Rotary

W ing Army sUAS master
trainer graduate Manned : 2683

Unmanned: 123
203 fixed wing launch/recovery
112 rotary wing launch/ recovery

Pilot 2

FAA Certificate: 3116078 FAA Commercial
Instrument Rotary
Wing Manned: 363

Aircraft Information and Emergency Procedures

T he Inspire is an inherently stable, lig htweight aircraft that weighs 6.4 lbs

. M oreover, although the aircraft can be configured to give the pilot full control of the aircraft and
payload during flight, the Inspire has an advanced autopilot that flies the aircraft,
managing altitude and flight path within the intended flight envelope at all times when
the that flight mode is engaged. The autopilot limits maneuvering to simple airspeed,
altitude, and turn rate changes. These limits are hard coded into the autopilot and define the aircraft’s normal flight operating envelope. The autopilot manages, pitch, roll,
yaw and collective throttle to maintain target airspeed, target turn rate, and target altitude. All flight modes utilize GPS and in the event of uni ntended input the aircraft
can be put into an operator controlled flight mode that allows for the aircraft to come to
an immediate hover. Turn rates and airspeeds are limited by the autopilot and do not
allow commands that are outside of the normal operat ing envelope.

Equally significant, the Inspire is comprised of composite materials, has energy
absorbing landing gear that reduce damage in the event of a hard landing and is

com posed of carbon fiber and plastic components.Page 6

www.tradecraftuas.com The DJI inspire has additional safety features to facilitate safe integration into the NAS.
The Inspire GCS software incorporates “Flight Restriction” areas around all B, C, and D
airports. These flight restriction areas have different levels of notification, from warnings

on the Gro und Control Station, to altitude restrictions and finally not allowing the start of

the motors.

Another feature that is pilot defined, allows for altitude and distance limits to be set on
the GCS. TradeCraft believes this is a key safety attribute that will allow seamless
integration into the NAS and compliance with all FAA regulations.

The Inspire has three failsafe emergency procedures:

Loss of Communication: In the event the communication link with the operators ground

control station is lost, the Inspire enters return to home mode after three seconds of

transmission loss. The aircraft climbs to a Pilot defined altitude based on obstacle
height. It then returns to the home waypoint

, hovers for 15 seconds while trying to

establish connection. T h e aircraft conducts a controlled landing then shuts off the

motors if connection is not reestablished

.

Low Battery: The low battery e mergency procedure is triggered when the DJI smart
battery is depleted to a point that may affect the safe return of th e aircraft; the P ilot in

Command will Land as Soon as Possible. The thresholds for these warnings are
automatically determined based on the current aircraft altitude and its distance from the
Home point.

Loss of GPS: A loss of GPS while in guidance mode will cause the aircraft to hover
using the onboard altimeter

. This will allow the Pilot in Command to land the aircraft as
soon as possible

. Additionally, the aircraft utilizes an “optical flow” sensor that uses
ultrasonic and image data to help the airc raft identify its position. This allows for the

aircraft to hover when GPS is lost.Page 7

www.tradecraftuas.com Specific Exemption Requests and Equivalent Level of Safety Showings

14 C.F.R. § 45.23(b)

– Display of marks; general

The regulation requires:

When marks in clude only the Roman capital letter "N" and the registration
number is displayed on limited, restricted or light

- sport category aircraft or
experimental or provisionally certificated aircraft, the operator must also display

on that aircraft near each entra nce to the cabin, cockpit, or pilot station, in letters
not less than 2 inches nor more than 6 inches high, the words "limited,"
"restricted," "light

- sport," "experimental," or "provisional," as applicable.

Even though the UAS will have no airworthiness c ertificate, an exemption may be needed as the UAS will have no entrance to the cabin, cockpit or pilot station on which the word “Restricted” can be place d as required by this provision. Two

- inch lettering also is not possible given the overall size of th e Inspire

. TradeCraft LLC , therefore, requests an exemption to display, with one

- inch lettering the word “Restricted” on the fuselage in compliance with §45.299(f).

The equivalent level of safety will be achieved by having the Inspire marked with one

inc h lettering on its fuselage because the pilot, observer, and others working with the

sUAS will have the identification of the aircraft as “Restricted”. The FAA has issued similar exemptions to this regulation, including to Pioneer Hi

- Bred International, I nc., Exemption No. 10810; Raytheon Missile Systems/Advanced Programs, Exemption Nos. 10167 and 8738; and Trimble Navigation Limited, Exemptions No. 10700 and

11042.

14 C.F.R. § 91.7 (a) and (b): Civil aircraft airworthiness

Sections 91.7 (a) and (b) pro hibit operation of a civil aircraft unless it is in airworthy

condition. TradeCraft LLC requests an exemption from this regulation because the Inspire would not operate with an airworthiness certificate under the proposal set forth in this filing. Given the size of the aircraft and requirements contained in the Manual for maintenance and use of safety check lists prior to each flight, as set f orth in in the operators manual, an equivalent level of safety will be provided.

14 C.F.R. § 91.109(a): Flight In struction

Section 91.109 (a) provides that no person may operate a civil aircraft (except a manned free balloon) that is being used for flight instruction unless that aircraft has fully functioning dual controls.

The Inspire is a remotely piloted aircraf t, and, by design, it does not have fully functional dual controls. Flight control is accomplished through the use of a control box that communicates with the aircraft via radio communications. Completing instruction through the TradeCraft t raining progr am will ensure an equivalent level of safety.

The FAA has approved exemptions for flight training without fully functional dual controls for a number of aircraft and for flight instruction in experimental aircraft. See Exemption Nos. 5778K and 9862A.Page 8

www.tradecraftuas.com 14 C.F.R § 91.119 Minimum Safe Altitudes

Section 91.119 establishes safe altitudes for operation of civil aircraft. Specifically, Section 91.119 (c) limits aircraft flying over areas other than congested areas to an
altitude of 500 feet above the surface, except over open water or sparsely populated areas. In those cases, the aircraft may not be operated closer than 500 feet to any person vessel, vehicle, or structure.

As set forth herein, the Inspire will never oper ate at higher than 400 feet AGL

. Beca use agriculture, ae rial survey work, and aerial imagery must be accomplished at relatively low altitudes, i.e. less than 500 feet AGL, an exemption from Section 91.119(c) is needed.

The equivalent level of safety will be achieved given the size, weight sp eed, and

material with which the Inspire is built. Also, no flight will be taken without the permission of the land owner or the party controlling the land. With advance notice to the landowner, all affected individuals will be aware of agriculture, surv ey, and aerial imagery . Compared to similar operations conducted with conventional aircraft or rotorcraft, which weigh thousand s of pounds and carry flammable fuel, any risk associated with these operations will be far less than those currently allowed wi th such conventional aircraft operating at or below 500 feet AGL.

14 C.F.R. § 91.151 (b): Fuel Requirements for Flight in VFR Conditions

Section 91.151 (b) prohibits an individual from beginning “a flight in a rotorcraft under VFR conditions unless (co nsidering wind and forecast weather conditions) there is enough fuel to fly to the first point of intended landing and, assuming normal cruising speed, to fly after that for at least 20 minutes.

The Inspire ’s battery provides 22 minutes of powered flight. Without an exemption from 14 C.F.R. §91.151, the Inspire ’s f li ghts would only be allowed to fly for 2 minutes

. Given the limitations on its proposed operations and the location of those proposed operations, a lesser reserve for flight in VFR conditions is reasonable.

TradeCraft LLC believes that an exemption from 14 C.F.R. § 91.151 (a) is safe and consistent with the scope of a prior exemption. See Exemption 10673 (allowing Lockheed Martin Corporation to operate without compliance with 91.151 (a)). Op erating the Inspire s UAS without 20 minutes of reserve fuel does not engender the type of risks that Section 91.151 (a) was meant to prevent. Given its weight and
construction material, the risks are less the n contemplated by the current regulation.

Trad eCraft LLC believes that an equivalent level of safety c an be achieved by maintaining 3 minutes of reserve fuel, which, allowing 19 minutes of flight time, would be more than adequate to return the UAS to its planned landing zone from anywhere

in its visua l line of s ite operating area.

Similar exemptions have been granted to others, including Exemptions 2689F, 5745,
10673, and 10808.Page 9

www.tradecraftuas.com 14 C.F.R § 91.405 (a); 91.407 (a) (1); 91.409 (a) (2); 91.417 (a): Maintenance inspections

Section 91.405 (a) requires that an aircraft operator or owner “[s]hall have that aircraft inspect as prescribed in subpart E of this part and shall between required inspections, excepts as provided in paragraph (c) of this section, have discrepancies repaired as prescribed in part 43 of this chapter.” Section 91.407 similarly makes reference to requirements in Part 43; Section 91.409 (a) (2) requires an annual inspection for issuance of an air worthiness certificate. Section 91.417 (a) requires that an owner or operator keep records sh owing certain maintenance work that has been accomplished by certificated mechanics, under Part 43, or licensed pilots and records of approval of

the aircraft for return to service.

Maintenance of the Inspire 1 will be accomplished by TradeCraft LLC pilot s pursuant to the manuals provided by DJI . An equivalent level of safety will be achieved

because the Inspire is small in size, will operate only in predetermined areas, and is

not a complex mechanical device. With the combined use of the DJI Inspire 1

op erat or’s and maintenance manual and TradeCraft LLC Commercial sUAS Flight Operations Procedures, the Pilot in Command of the Inspire will ensure that it is in

safe working order prior to initiating flight, TradeCraft LLC pilots will perform required

mainte nance, and keep a log of any maintenance that is performed. Moreover, the Pilot in Command, prior to all flight s will ensure the air craft is safe for flight

, which will provide an equivalent level of safety.Page 10

www.tradecraftuas.com Federal Register Summary

Pursu ant to 14 C.F.R. § 11.81(f), the following summary is provided for publication in the Federal Register, should the FAA determine that publication is needed:

Docket No.: No. FAA

- 2014

- Petitioner: TradeCraft LLC

Section of 14 CFR: 14 C.F.R. § 45.23(b), 14 C .F.R. § 61.113(a) and (b), 14 C.F.R. § 61.133(a), 14 C.F.R. § 91.7(a) and (b), 14 C.F.R. § 91.109(a), 14 C.F.R. § 91.119, 14 C.F.R. § 91.151(a), 14 C.F.R. § 91.405(a), 14 C.F.R.§ 91.407(a)(1), 14 C.F.R. § 91.409(a)(2), 14 C.F.R. § 91.417(a).

Description o f Relief Sought: TradeCraft LLC is seeking an exemption to conduct commercial agriculture, aerial survey, and imagery operatio ns using a small Unmanned A ircraft S ystem (55lbs or less) in areas of the

continental United States.

Based upon the foregoing, Tr adeCraft LLC requests that the FAA grant it the necessary
exemptions under Section 333 of the FAA Reform ACT and 49 U.S.C. §44701(f) of the
Federal Aviation Act as requested herein to allow commercial operations of the Inspire

within the continental United States and its territories.

Sincerely,

TradeCraft LLC