# CACI

EVER VIGILANT

August 20, 2015
U.S. Department of Transportation 1200 New Jersey Avenue, S.E. Room W 12-140 Washington, D.C. 20590
Re: CACI Reqzcest foi- Exenzptions Pcu•srrant to FMRA Section 333 aizd Pat•t 11 of the FARs to Use Small Uiznianned Ar'r•cf•aft Systems
Dear Sir or Madam: Pursuant to Section 333 of the FAA Modeinization and Reform Act of 2012 ("FMRA") 1 and 14 C.F.R. Part 11, CACI, INC.-FEDERAL ("CACI") hereby petitions for exemptions from the Federal Aviation Regulations ("FARs") listed below and any other rules necessary to allow CACI to operate small unmanned aircraft systems ("UAS") as described herein.
1. Description of Petitioner CACI is a Delaware corporation with its primary offices in Virginia that provides inforrnation solutions and services in support of national security missions and government tI•ansformation for U.S. government intelligence, defense, and civilian customers.
2. Name and Address of Petitioner• The name and address of the petitioner are: CACI, INC.-FEDERAL 1100 North Glebe Road Arlington, Virginia 22201

1FAA Modernization and Reform Act of 2012, Pub. L. No. 112-95, 126 Stat. 75-76 (codified as allote to 49 U.S.0 § 40101).

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CACI International Inc and Subsidiary Companies Worldwide Headquarters ■ 1100 North Glebe Road - Arlington, Virginia 22201 ■ (703) 841-7800 - Fax (703) 841-7882 CACl Website - www.caci.coni

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3. Purpose of UAS Operations CACI seeks this exemption to test a reprogrammable i•adio sensor that it developed to detect, track and ensure the safe and lawful use of specific commercial off-the-shelf UAS. Such testing will improve safety and security with respect to the use of UAS. Consistent with its long-standing cornmitment to safety and federal government compliance requirements, CACI will conduct all UAS operations in conforinity with strict safety guidelines, including conducting all testing only with a trained and certified pilot and fully within a controlled-access, unpopulated 130-acre private test facility located at High Horse Farm. in Hume, Virginia. Operations will occur within line of sight of the UAS operator and visual observer. CACI will at all times abide by the operating procedures and policies, pilot qualifications and training requirements contained in CACI's UAS Manual ("CACI Manual") 2 and the operating conditions and restrictions imposed by FAA in the exemption grant.
4. iJnmanned Aircraft Systems CACI proposes to conduct UAS operations using DJI Phantom 2 Vision+ and DJI Phantoln 3 aircraft (the "Aircraft"), which are quadcopter rotor aireraft. The specifications for the Aircraft are shown in the below table. DJI PHANTOM 2 VISION+ DJI PHANTOM 3 Length x Width x Height 13.8" x 13.8" x 7.5" (350rnm x 350mm x 190mrn) 23.2" x 23.2" x 8.3" (590nun x 590mtn x 210mm) Weight w/o Camera 1.9 pounds (842g) 1.9 pounds (880g) Weight with Calnera 2.7 pounds (1,242g) 2.8 pounds (1,280g) Maximum Speed 33.5 miles/houl -(15m/s) 35.8 miles/hour (16m/s) Maximum Range 1 mile 1.2 miles Maximum Flight Time 25 minutes 23 minutes

` CACI is submitting its Manual to FAA confidentially with a request for confidential treatment pursuant to 14 CFR Section 11.35(b). The CACI Manual contains confidential, proprietary and coinmercially sensitive information that has not been made available to the public and that is protected under the Freedom of Information Act, 5 U.S.C. § 552, et seq.

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As the table makes clear, both the DJI Phantom 2 Vision+ and DJI Phantom 3 are exceedingly small, lightweight aircraft with limited range and fligllt times and low operating speeds. Both kinds of Airci•aft have extensive flight programining capabilities, including preprogramming of geo-fencing (with altitude limitation) that precludes operations beyond the planned operating area. If the Aireraft lose comtnunications or GPS, they will hover in place and then slowly descend or return to a pre-determined location within the planned operating area. The Aircraft will be registered in accordance with FAA requirements and will have markings identifying serial and registratiorl numbers as large as practicable. In conducting UAS operations, CACI will comply with the Inanufacturer's manuals and safety bulletins. The User Manual for the DJI Phantom 2 Vision+ aircraft is available at: http://www.dii.colll/product/phantom-2-vision-plus/download . The User Manual for the DJI Phantom 3 is available at: http://www.dii.com/product/phantom-3-standard/download. FAA has previously approved use of DJI Phantom 2 Vision+ and DJI Phantom 3 aircraft. See, e.g., Exemption Nos. 12248 and 12229 (DJI Phantom 2 Vision+); Exemption Nos. 12141, 12005, and 11309A (DJI Phantom 2 Vision+ and DJI Phantoin 3).
5. Statutol - y Authority for Requested Exemptions Grant of this request for exeinptions will promote Congress' goal in enacting Section 333 of the FMRA. Section 333 directs the Secretary of Transportation to consider whether cei

- tain UAS may operate safely in the national airspace before completion of the rulemaking required under Section 332 of the FMRA. The Secretary is required to determine the kinds of UAS operations that do not create a hazard to users of the national airspace or the public or pose a threat to national security in light of the UAS' size, weight, speed, operational capability and areas of operation and whether the operations will occur within the visual line of sight of the operator. Section 333 reflects Congressional intent that FAA will grant exemptions to allow small UAS operations under conditions that ensure safety, like those proposed in this petition. In addition, the Federal Aviation Act expressly grants FAA the authority to issue exemptions. 3Under this authority, the Administrator may grant an exemption from a requirement of a regulation prescribed under §§ 44701(a) or (b) or in §§ 44702-44716 of the Act if the Administrator finds the exeinption in the public interest.

349 U.S.C. § 44701(f).

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6. Safetv Measures and Public Interest Benefits Approval of CACI's request to operate UAS is in the public interest. Most importantly, the testing that CACI intends to do will dramatically enhance safety alld promote security by developing a means to address growing problems relating to UAS. 4Granting this petition also advances Congress' goal of integrating civil UAS into the national airspace safely and expeditiously. Moreover, CACI's UAS operations will be conducted in accordance with strict safety procedures detailed below. Under those procedures, the LJAS will be operated by a trained, certified pilot; a visual observer will be used; the UAS will be flown only under visual meteorological conditions (VMC) during daylight hours and only within visual line of sight of the pilot and observer; and all flights will remain below 400 feet and inore than 5 nautical miles away from any airport and thus will not interfere with other users of the national airspace. The Aircraft are extremely small and lightweight, have limited speed, range and flight duration, and carry no flainlnable liquids or explosives. They have significant preprogramming capabilities, including geo-fencing that ensures that the UAS stays within the planned operating area. In the event of lost communications or GPS, the UAS will hover in place and then slowly descend or return to a pre-determined location within the planned operating area. The flights will be conducted in a tightly controlled environment, i.e., a private test facility that is a secured site with only authorized personnel permitted onsite. FAA has determined that UAS operations using the same kinds of unmanned aircl•aft that CACI proposes to use and operating under the same or similar conditions and restrictions proposed herein were in the public interest. See, e.g., Exemption Nos. 12248, 12229, 12141, 12005, and 11309A. The requested exemptions likewise are in the public interest. 7. List of Snecific FARs Fr•om Which Petitionei• Seeks Exemptions 14 C.F.R. § 61.23(a), (c) 14 C.F.R. § 61.101(e)(4), (e)(5) 14 C.F.R. § 61.113(a) 14 C.F.R. § 61.315(a) 14 C.F.R. § 91.7(a) 14 C.F.R. § 91.119(c) 14 C.F.R. § 91.121 14 C.F.R. § 91.151(a) ' S'ee, e.g., https://www.washingtonpost.com/world/national-security/how-rogue-dronesare-rapidl,y-becoming-a-national-nuisance/2015/08/10/9c05d63c-3f61-11 e5-8d45- d815146f81 fa_stol _y.html?hpid=z 1.

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14 C.F.R. § 91.405(a) 14 C.F.R. § 91.407(a)(1) 14 C.F.R. § 91.409(a)(1), (a)(2) 14 C.F.R. § 91.417(a), (b)
8. Justifications for Each Exemption Reguest For the reasons detailed below, CACI requests exemptions froin the referenced regulations to the extent necessary to enable the requested UAS operations. In Exemption Nos. 11062, 11109, 11112, 11213 and their progeny, FAA granted relief frorn these regulations, for the same or similar reasons as those discussed below.

a. 14 C.F.R. § 61.23(a) and (c),14 C.F.R. § 61.101(e)(4) and (e)(5),14 C.F.R. § 61.113(a), 14 C.F.R. § 61.315(a): Pilot pt•ivileges and limitations, meciical certificates The referenced regulations set forth cei

- tain requirements relating to pilot privileges, limitations, licenses and medical certificates. FAA has determined that for small UAS operations, an equivalent level of safety will be achieved if the pilot in coinmand holds an airlinetransport, coirunercial, private, recreational, or sport pilot certificate and either a current FAAissued airman Inedical certificate or a valid U.S. driver's license. CACI will ensure that its PICs satisfy these requirements; accordingly, FAA should grant CACI relief fiom these regulations, consistent with its current practice. b. 14 C.F.R. § 91.7(a): Civil aircl•aft airworthiness Section 91.7(a) requires that a person determine that an aircraft is in airworthy condition before flight. CACI will conduct a pre-flight inspection prior to each flight in accordance with the proposed operating restrictions and conditions, the CACI Manual and the manufacturers' User Manuals. Particularly given the characteristics of the Aircraft (including their extremely srnall size, weight and payload capacity, very low operating altitude, and exceedingly short flight time capability) and the stringent operating restrictions and conditions proposed in this petition, an equivalent level of safety will be achieved by CACI's compliance with the pre-flight inspection requirements in the proposed operating restrictions and conditions, the CACI Manual and the manufacturers' User Manuals. CACI therefore requests FAA to grant an exemption from Section 91.7(a).

C. 14 C.F.R. § 91.119(c): Minimum safe altitudes Section 91.119(c) establishes cei

- tain minimum altitudes for operation of civil aircraft. Section 91.119(c) provides, in pertinent part, that: "except when necessary for takeoff or landing,

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no person may operate an aircl•aft below the following altitudes: ... (c) Over other than congested areas. 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." CACI requests relief fi•om this section since the UAS flights will operate at altitudes no higher than 400 feet AGL. Given the small size, light weight, low speeds and limited range and duration of the UAS, and the fact that they carry no persons or explosive or flammable materials, the UAS flights inay be safely operated at rnuch lower altitudes than conventional aircraft. In addition, the operations will be conducted with the safeguards and under the operating conditions outlined herein and in the Manual. For these reasons, relief from this rule is warranted. d. 14 C.F.R. § 91.121: Altimeter settings Section 91.121 requires each person operating an aircraft to maintain cruising altitude by reference to an altimeter that is set "to the elevation of the departure airport or an appropriate altimeter setting available before departure." An exemption may be needed because the UAS do not have a baroinetric altimeter, but instead have a GPS altitude read-out. An equivalent level of safety will be achieved by the operator, pursuant to the CACI Manual, confirming the altitude of the launch site shown on the GPS altitude indicator before flight.

C. 14 C.F.R. § 91.151(a): Fuel requirements for flight in VFR conditions Section 91.151(a) prohibits an individual froin beginning "a flight in an airplane under VFR conditions unless (considering wind and forecast weather conditions) there is enough fuel to fly to the first point of intended landing, and, assuming normal cruising speed —(1) During the day, to fly after that for at least 30 minutes...." An exenlption is needed because the Aircraft have a lnaximum flight time of less than 30 minutes and thus calulot meet the 30-minute reserve requirement. It is reasonable to adopt a different fi.iel requirement for CACI's flights, which will occur in a restricted operating area during daylight hours using a small, lightweight UAS operating within visual line of sight at low altitude, with low speed, limited range, and the ability to land very quickly. Further, the UAS does not caiTy persons or any flammable or explosive materials. An equivalent level of safety can be achieved by tei

-minating flights with a minimum of 20% battery power reserve remaining, which CACI intends to do. f. 14 C.F.R. § 91.405(a): Maintenance required 14 C.F.R. § 91.407(a)(1): Operation after maintenance, preventive maintenance, rebuilding or alteration 14 C.F.R. §§ 91.409(a)(1) and (2): Inspections 14 C.F.R. §§ 91.417(a) and (b): Maintenance records

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These regulations require that an aircraft operator or owner (i) "shall have that aircraft inspected as prescribed in subpart E of this part and shall between required inspections, except as provided in paragraph (c) of this section, have discrepancies repaired as prescribed in pat

- t 43 of this chapter..." and (ii) shall inspect or maintain the aircraft in compliance with Part 43. Because these sections and Part 43 apply only to aircraft with an airworthiness certificate, these sections will not apply to the petitioner. Maintenance will be accomplished pursuant to the manufacturers' User Manuals and the CACI Manual. An equivalent level of safety will be achieved because these UAS are very small in size and weight, will carry a tiny payload and operate only in a tightly-controlled operating area at low altitude for short periods of time. If mechanical issues arise, the UAS can land immediately. As provided in the Manual, the operator will ensure that the UAS is in worldng order prior to initiating flight, perform required maintenance, and keep a log of any maintenance performed. Moreover, the operator is the person most falniliar with the aircraft and best suited to maintain the aircraft in an airworthy condition to provide an equivalent level of safety.
g. Such other relief as the FAA deems appropriate to enable the requested operations CACI also requests relief fi•om such other FARs as the FAA deems appropriate to enable the requested operations. If, during the effective dates of the exemption issued pursuant to this petition, the FAA issues interim or final rules for small UAS, CACI requests that it be relieved of the requirements of any conditions and limitations of the exemption that would not apply under such rules and that it be allowed to comply with any less burdensome regulations that may have become effective.
h. Request for expedited action CACI respectfully requests that FAA consider this petition on an expedited basis to allow CACI to begin testing as soon as possible. The tests will plainly promote the public interest by improving safety and protecting national security. Expedited action is also appropriate because the petition requests relief that FAA has already detelmined was appropriate to grant to other petitioners who proposed to operate the same kinds of UAS under the sarne or similar operating parameters.
9. Operating Conditions and Resti•ictions Flight tests will be limited to operations contained within a private, unpopulated 130-acre test facility located at the High Horse Farm in Hume, Virginia. See attached aerial photo. This facility is not located in close proxiinity to any airports and is in a rural setting. Flights will belitnited below 400 feet altitude at all tilnes and will be constrained by adjusting the softwaredefined altitude limits in the Phantom navigation software application.
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Flights are expected to last only between 10-25 Ininutes depending on the cuffent flight conditions, and will always be terminated with a minimum of 20% battery life remaining in all electrical powered components (radios and airframe). The aircraft will be within visual line of sight of the pilot and a visual observer at all times. All flights will follow strict, pre-defined flight test plans and procedures. See attached CACI Manual. The pilot will limit flights to stay within Visual Flight Rules (VFR) at all times and follow all FAA RC Aircraft regulations. Flights will only occur in daylight hours in clear weather conditions with minimal wind. Oiily flight-test related persoiulel will be in the fligllt test area during flight test events. CACI's development efforts are specifically designed to test and demonstrate safe technidues and capabilities to provide Government, law enforcement and first responders with robust abilities to identify and prevent unsafe or illegal use of UAS in the airspace. By using a secure, unpopulated private test facility, a trained pilot with an FAA-issued pilot certificate, and vetted test plans and adhering to the otller safety restrictions set foI

- th herein, CACI intends to test its reliable, low-cost UAS safety technologies with no rislc to the general public, the nation's security and the national airspace. CACI proposes the following operating parameters for its flights:
1. The operations will be conducted using DJI Phantom 2 Vision+ and DJI Phantom 3 aircraft, which are extremely small UAS weighing less than 3 pounds, with payload. 2. The UAS will not be flown at an airspeed exceeding the maximum UAS operating airspeed recommended by the aircraft manufacturer and in any will not be operated at a speed exceeding 87 knots (100 miles per hour). 3. Flights will be operated at an altitude of no more than 400 feet AGL. 4. Flights will be operated at all times within visual line of sight Of the pilot in cominand ("PIC"), unaided by any device other than corrective lenses. 5. All operations will utilize a visual observer ("VO"). All flights will be operated within visual line of sight of the VO. The VO and PIC will be able to comrnunicate verbally at all times. 6. The CACI Manual, the manufacturer's User Manual and the exelnption ("Operating Documents"), as well as any documents required under 14 CFR §§ 91.9 and 91.203, will

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be available to the pilot at the ground control station of the UAS during flight operations. CACI will follow the procedures set forth in the Operating Documents. 7. Prior to each flight, the pilot must inspect the UAS to ensure that it is in a condition for safe flight. If the inspection reveals a condition that affects the safe operation of the UAS, the aircraft is prohibited from operating until the necessary lnaintenance has been performed, and the UAS is found to be in a condition for safe flight. All rnaintenance and alterations must be properly documented in the aircraft records. 8. Any UAS that has undergone maintenance or alterations that affect the UAS operation or flight characteristics, e.g., replacement of a flight critical component, must undergo a functional test flight. The pilot who conducts the functional test flight must make an entx•y in the UAS aircraft records of the flight. 9. CACI will maintain and inspect the UAS to ensure that it is in a condition for safe operation. 10. CACI will follow the UAS manufacturer's maintenance, overhaul, replacement, inspection, and life limit requirements for the aircraft and aircraft components. 11. Each UAS operated under the exemption must comply with all inanufacturer safety bulletins. 12. UAS operations will be conducted with a PIC that holds either an airline transport, comznercial, private, recreational, or sport pilot certificate. The PIC must also hold a current FAA airman medical cel

- tificate or a valid U.S. driver's license issued by a state, the District of Columbia, Puerto Rico, a territory, a possession, or the Federal goverrunent. The PIC must also meet the flight review requirements specified in 14 CFR § 61.56 in an aircraft in which the PIC is rated on the pilot certificate. 13. Before conducting operations, a qualified UAS pilot will demonstrate and log in a lnanner consistent with 14 CFR 61.51(b) the ability to safely operate the UAS in a manner consistent with how the UAS will be operated under the exemption, including evasive and emergency maneuvers and maintaining appropriate distances from people, vessels, vehicles and structures. 14. All operations must be conducted under visual meteorological conditions and during daylight hours. 15. The UAS lnay not be operated less than 500 feet below or less than 2,000 feet horizontally from a cloud or when visibility is less than 3 statute miles froln the pilot.

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16. If the communications link or GPS signal is lost, the UAS will return to a pre-determined location within the restricted area of operations. 17. The PIC will abort the flight in the event of any unpredicted obstacles or emergencies. 18. The PIC will not begin a flight unless there is enough available power for the UAS to conduct the planned operation and operate after that for at least five minutes or with the reserve power recomrnended by the manufacturer if greater. At any rate, flights will be terminated with at least 20% reserve power remaining. 19. All aircraft operated in accordance with the exemption will be identified by serialnumber, registered in accordance with 14 CFR Part 47, and have identification (NNumber) marlcings in accordance with 14 CFR Part 45, Subpai

- t C. Markings will be made as large as practicable. 20. The UAS must remain clear and yield the right of way to all other manned operations and activities. 21. The UAS may not be operated by the PIC from any moving device or vehicle. 22. Flight operations will be conducted at least 500 feet from all nonparticipating persons, vessels, vehicles, and structures unless:

a. Barriers or structures are present that sufficiently protect nonparticipating persons froin the UAS and/or debris in the event of an accident. The operator will ensure that nonpai

- ticipating persons rernain under such protection. If a situation arises where nonparticipating persons leave such protection and are within 500 feet of the UAS, flight operations must cease immediately; and/or
b. The owner/controller of such vessels, vehicles or structures has granted permission for operating closer to those objects and the PIC has made a safety assessment of the rislc and deternlined that it does not present an undue hazard.
23. All operations will be conducted over private or controlled-access property with pertnission fi•oin the land owner/controller or authorized representative. 24. In the event a Certifcate of Authorization (COA) is required, any incident, accident, or flight operation that transgresses the boundat•ies of the operating area as defined by the applicable COA must be reported to the FAA's UAS lntegration Office witllin 24 hours. Accidents lnust be reported to the National Transportation Safety Board (NTSB) in accordance with federal regulations.

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10. Summary for Federal Register Notice CACI respectfiilly submits that good cause exists for not publishing a summaly of this request in the Federal Register and for granting the requested exemptions expeditiously. CACI's request would not set any precedent, and prompt processing of the petition would serve the public interest by allowing CACI to begin a testing program that will promote safety and national security interests. Nonetheless, CACI provides the following summary:
Petilioner: CACI, INC.-FEDERAL Affected r•egirlations: 14 C.F.R. § 61.23(a), (c); 14 C.F.R. § 61.101(e)(4), (e)(5); 14 C.F.R. § 61.113(a); 14 C.F.R. § 61.315(a); 14 C.F.R. § 91.7(a); 14 C.F.R. § 91.119(c); 14 C.F.R. § 91.121; 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)(1), (a)(2); 14 C.F.R. § 91.417(a), (b). Description: Petitioner seeks an exemption from the requirements of 14 C.F.R. § 61.23(a) and (c), 14 C.F.R. § 61.101(e)(4) and (e)(5), 14 C.F.R. § 61.113(a), 14 C.F.R. § 61.315(a), 14 C.F.R. § 91.7(a), 14 C.F.R. § 91.119(c), 14 C.F.R. § 91.121, 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)(1) and (a)(2), and 14 C.F.R. § 91.417(a) and (b) to engage in testing using small UAS. 11. Privac The petition raises no privacy issues because all flights will occur over private, controlled-access property with the property owner's prior knowledge and consent. 12. National Security The proposed UAS operations do not jeopardize national security. The UAS to be used in the test operations are exceedingly small and lightweight, operate at very low speeds, have a tiny payload capacity, carry no flainmable, explosive or otherwise dangel•ous materials and will be operated in a controlled area under strlct procedures. Accordingly, the operations pose no threat to national security. Indeed, the operations will enhance national security by enabling detection and prevention of unsafe or illegal use of UAS in the national airspace. 13. Conclusion For the reasons stated above, CACI's proposed use of UAS satisfies the criteria in FMRA Section 333 regarding size, weight, speed, operating capabilities, operating areas, operation within visual line of sight, and national security. CACI's proposed safety measures and

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operating parameters provide more than adequate justification for the grant of the requested exemptions allowing operation of UAS. CACI therefore respectfiilly requests that FAA grant the requested exemptions on an expedited basis. If anything further is needed to perfect this zequest, or if there are any questions regarding this request, please contact Ine directly. 

# i Sincerely,

illiam Koegel, Jr. Executive Vice President, General Counsel & Secretary
Attachments: Confidential treatment is requested foi the CACI Manual and supporting

materials.

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