North Georgia Drones, LLC

1760 Loblolly Lane
Cumming, GA 30041

770

- 330

- 7382 stan.jessen@outlook.com

May 1 , 2015

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

Re: Request for Exemption under Section 333 of the FAA Reform Act of 2012

Dear Sir or Madam:



### 1 Summary for the Federal Register

North Georgia Drones, LLC (NGD) is requesting exemptions under Section 333 of the FAA

Reform Act of 2012. NGD pl ans to do c ommercial a erial survey and photography operations

. Applications include, but are not limited to, a griculture , real estate, special events, mapping,
construction site monitoring and inspections. This will be done using DJI Phantom 2 Vision Plu s (2.8 pounds GW) and DJI Inspire 1 (6.5 pounds GW ) camera equipped quadcopters. Both
qualify as small U nmanned A ircraft S ystems (sU A S) and are under the 55 pound limit proposed
by Section 331 of the FAA Reform Act of 2012.

The following abbreviations ar e used in this document,

CO Camera Operator

NAS National Air Space

NGD North Georgia Drones, LLC

PIC Pilot in Command

RTH Return to Home

sUAS small Unmanned Aircraft System

UAS Unmanned Aircraft System

VO Visual Observer

### 2 Exemptions Requested

We have studied the current FAA grants of Exemption and conclude that our request is similar
in all material respects to the following:

Exemption No. Petitioner DocketNo

. 11240 Aerius Flight, LLC FAA

- 2014

- 0894

11062 Astraeus Aerial FAA

- 2014

- 0352

111 09 Clayco, Inc. FAA

- 2014

- 0507

11213 Aeryon Lab, Inc FAA

- 2014

- 0642

11217 Monterey Drone FAA

- 2014

- 0919

We analyzed the exemptions requested by these and other petitioners and noted that the FAA
determined many of exemptions to be “Relief not necess ary“, “Relief not granted” or “Relief
not warranted”. We have limited our request only to exemptions where relief was granted or
granted with conditions and limitations. We accept the “Conditions and Limitations” the FAA
assigned to the above petitioner s.

Therefore, we request exemption from the following sections of Title 14 CFR:

61.23(a) and (c)
61.101(e)(4) and (5)
61.113(a) and (b)
61.315(a)
91.7(a)
91.119(c)

91.121 91.151(a)(1)
91.405(a)
91.407(a)(1)
91.409(a)(1) and (2)
91.417(a) and (b)



### 3 About N orth Georgia Drones

The founder of NGD, Stan Jessen, has extensive aviation experience:

• BS in Aeronautical Engineering from Cal Poly in San Obispo, CA

• Flight test Operations Engineer at Boeing, Seattle (worked on 737 and 747 flight test
programs)• 9 years as a Navy Pilot flying TA4 and A7 aircraft carrier based aircraft

• Several hundred hours f lying light civilian aircraft (C150, C172, C182,...)

• Commercial/ Instrument rated pilot

• Over 2600 h ou r s of fligh t

- time

• Member: AMA (Academy of Model Aeronautics)

• Memb er: GMA (Georgia Model Aviators)

• Member: AUVSI (Association for Unmanned Vehicle Systems International)

• Member: EAA (Experimental Aircraft Association)

• Member: FlySafe

Mr. Jessen attended FlySafe UAS training class es in March 2015

, and passed both the academic
and flight test. FlySafe is a workshop t h at immerses UAV pilots and camera operators into
standardized training and education for low

- range unmanned aerial photography and UAS
operations.

Mr. Jessen’s above experiences make him uniquely qualifi ed to operate, manage and
implement the necessary programs for safe sUAS operations.



### 4 Benefits to the Public

NGD will employ electric powered sUAS (small Unmanned Aerial Systems) from DJI , a leader in
the sUAS space. The following quadcopters will be emp loyed

,

 Phantom 2 Vision Plus maximum gross weight of 2.8 lbs

 Phantom 3 maximum gross weight of 2.8 lbs

 Inspire 1 maximum gross weight of 6.5 lbs

The benefits of these sUAS compared to manned aircraft are compelling,

 Light weight means considerably l ess danger and damage to people and structures on
the ground in the event of an accident

 E lectric sUAS use considerably less energy

. T here is no fuel to ignite if there is an
accident and no noxious gases exhausted

. They are environmentally “green” vehicl es.

 sUAS can be launched on

- site, eliminating transit times to and from the operating area.
The result is shorter flight times and no exposure to people and things outside operating

area.

 Electric sUAS are very quiet compared to manned aircraft.

 sUAS can operate in smaller space and lower to the ground than manned aircraft. This

opens al l kinds of new applications

. The lower acquisition and operating cost of sUAS will make aerial photography

affordable to organization s that have a need but could not justi fy the high cost of
manned aircraft. It will also open the door to new applications.

There is currently the wide spread use of sUAS by operators for commercial purpose. Some may

be operating safely, but many have no aviation experience

, bought a drone an d taught
themselves to fly it. Both these groups are in violation of FAA rules and regulations. Granting

FAA petition s to qualified organizations is the best way to stop this. Once potential customer s
understand t he risk and realize that there are compa nies who the FAA has granted the right to
engage in commerce with sUAS , these illegal operations will be unable to get business. This is
clearly in the public interest.



### 5 Aircraft

NGD plans to use the following multi

- rotor aircr aft,

DJI

Phantom 2 Vision + DJI

P hantom 3 Professional DJI
Inspire 1

Type Aircraft Quadcopter (4 motors) Quadcopter (4 motors) Quadcopter (4 motors)

Battery 5200mAH LiPo 5200mAH LiPo 5700mAh LiPo

Max Flight Time ~20 minutes ~20 minutes ~18 minutes
Diagonal Mo tor Distance 350 mm 350 mm 581 mm Height 191 mm 191 mm 301 mm
Maximum Weight 1242g (2.74 lbs) 1242g (2.74 lbs) 2935g (6.47 lbs)

Maximum Flight Speed 15 m/s (34 mph) 15 m/s (34 mph) 22 m/s (50 mph)

Remote Control Freq 5.728

- 5.85 GHz 5.728

- 5.85 GHz 5.728

- 5.85 GHz

GPS Positioning Yes Yes Yes

Vision Positioning No No Yes

Gimbals DJI Remote pitch control DJI Remote pitch control Zenmuse X3

Pitch and Pan control

Camera DJI 14 Megapixels DJI 14 Megapixels X3 12.4 Megapixels
Remote Control Freq 5.8 GHz ban d, spread

spectrum 5.8 GHz band, spread

spectrum 5.8 GHz band, spread

spectrum

Live Video Feed Range Extender (low res)
2.4 GHz band, spread

spectrum Range Extender (low res)
2.4 GHz band, spread

spectrum Lightbridge (HD)
2.4 GHz band, spread

spectrum

GPS enabled Yes Yes Yes

### 6 Flight Safety

The following sections describe our approach to flight safety. The key aspects of our flight safety

program are: aircraft failsafe modes, crew qualifications and training; flight planning; and the use of

checklist.



### 6.1 Aircraft Failsafe Modes

The following Failsafe features applies to both sUAS

 A utomatic “Return to Home” (RTH) when communications is lost or initiated by the PIC.
When RTH is initiated, the sUAS climbs to a preset altitude, travels to the GPS location at

take

- off, descends, lands and shuts down the motors. If GPS is not working

, the sUAS
hovers in place and descends to the ground.

 Automatic “Return to Home” is also triggered if the PIC ignores low battery warning lights
and messages. If the sUAS determi nes that there is insufficient power to RTH, the sUAS
hovers in place and descends to the ground.

 The sUAS can be programmed before flight to stay within a defined di stance from the
RTH point. T he aircraft software will not allow the aircraft to go pass t his zone, even i f
directed by PIC.



### 6.2 Crew Qualifications and Testing

A crew of t hree people are required for NGD flight operations: Pilot

- in

- Command (PIC), Camera
Operator (CO) and Visual Observer (VO). Since crew members are not always co

- located, Wa lkie

- talkies

are used to ensure communication.



### 6.2.1 Pilot in Command (PIC)

Private Pilot license (minimum)

Pass written test on:
FAA requirements AMA safety rules

Multi

- Rotor systems
Experience

20 hrs of multi

- rotor experience 5 hours of experie nce on the NGD aircraft to be flown
Pass flight test

### 6.2.2 Camera Operator (CO)

Pass written test on:
FAA requirements AMA safety rules

Multi

- Rotor systems Demonstrate familiarity with photography
Camera setting Framing shots
Demonstrate familiarity with gimba led cameras and aerial photography

Practice with PIC



## 6.2.3 Visual Observer (VO)

Pass written test on:
FAA requirements AMA safety rules
Communications procedures
Proper visual scan



## 6.3 Mission Planning

Mission planning begins with prospective client and ends with a mission Flight Plan. The details
of mission planning are proprietary, but involve 4 phases.

Phase 1

– Qualification

W hat does the cu stomer want ?

C an we do it safely ?

Phase 2

- On Site Evaluation

L ook for hazards and discuss the video and photographic requirements

Phase 3

– Sign ed c ontract and deposit

Phase 4

– Flight Plan

Using the photographic requirements, plan the ideal flight path, crew role s, RTH failsafe
point and safety issues

.

## 6.4 Checklist

The following checklists are for the Phantom 2 Vision Plus

.

Arrival Checklist

1 Meet with Client representation and review 

2 Mission objective 

3 Mission plan 

4 Safety issues 

5 Pass out Walkie

- talkie to PIC, CO, VO and client 

6 Perform a communication test 

7 Check weather conditions 

8 Wind speed and direction 

9 Temperat ure (cold reduces battery output) 

10 Visibility and lighting 

11 Safety concerns 

12 Notify tower if within 5 miles 

13 Ground Station display (if not performed previously) 

14 Connect to Web via Wi

- Fi 

15 Load with local area maps 

16 Disable all non sUAS Wi

- Fi’s 

17 Calibrate compass 

18 Quickly flip S1 switch from Up/Dn about 5 times (solid Yellow) 

19 Level flight attitude

- Rotate aircraft clockwise 360 o (solid Green) 

20 Nose

- down attitud e

– Rotate aircraft clockwise 360 o 

21 Calibration failure if Red

- Yellow, Red

- Yellow, Red

- Yellow ...) 

22 Walk through mission with crew (take

- off, flight plan, landing) 

23 Perform a communications check if positions are changed during flight 

Pre

- Flight Checklist

1 Inspect aircraft for damage
Cracks in high stress areas

Loose screws and fasteners
Loose or damaged wiring and tie wraps 

2 Install Props

Check for tightness

Check for nicks 

3 Check that motors spin with little resistance 

4 Install battery

– check for full change 

5 Camera

Micro

- card installed

Damping absorbers in good condition

Anti

- drop mounted correctly
Lens cap removed Gimbal clamp removed
Fill in clapper board data

6 Remote Controller

S2 and S1 Switches UP
Controls move freely and center when released
Power up (check for green light)
Range Extender

– Power up (check for green light) 

7 Power Up Aircraft 

8 Ground Station display (these steps executed by Camera Operator)

Power up and connect to aircraft W i

- Fi access point
Launch Vision app
Check for aircraft data (altitude and battery % level)

Check camera tilt

Check Ground Station for camera video
Clapper board

– take 1 photograph and 5 sec of video 







Aircraft

– Power up and Take

- Off

1 Rem ote Control switches S1 and S2 in up positions 

2 Quadcopter on level ground, facing into wind, battery facing pilot 

3 Wait until Rear Flight LEDs blink Gre en (GPS w/6 satellite s ) signals GPS working 

4 Check that camera operator is a Go for hover 

5 Check that observer is a Go for hover 

6 Check that area is clear 

7 Use CSC to start motors 

8 Use CSC to stop motors (to confirm it works) 

9 Start motors and bring throttle to full back position
(motor should stop in 10 sec ) 

10 Start mot ors and while at idle apply a little pitch, roll and yaw.
Listen for changes in motor speed to confirm inputs were received 

11 Advance Power and hover at about 8 ft for 1 minute

Check for blinking Green GPS rear lights

Watch for drift 

12 Check that a ircraft responds to pitch, roll and yaw 

13 Check that camera operator is a Go for mission

Double check that CO has video and control of camera 

1 4 Check that observer is a Go for mission

Double check that operating area is clear and safe 

1 5 Start Mission 

Landing Checklist

1 Check that LZ area is clear 

2 Check the observer is Go for landing 

3 Hover about 8 ft about the LZ 

4 Orient aircraft into the wind and the rear facing the PIC 

5 Land the aircraft Post Landing Checklist

1 Check that landing area is clear 

2 Land a ircraft (hand

- and if windy/gusty ) 

3 Shut down motors 

4 Post Flight Checklist 

5 Turn off aircraft 

6 Turn off range extender 

7 Turn off RC 

8 Remove battery 

9 Remove camera memory card 

10 Copy files to laptop 

11 View video/photographs 

12 Mission Debrief 

13 What went wrong 

14 What went right 

15 Deviations from Flight Plan 



### 7 sUAS Maintenance

Other than a pre

- flight check list, t here is currently no recommended maintenance for the sUAS

NGD will be using . Should the manufacturer (DJI) introduce any maintenance

recommendations we will make it part of our processes . The modern multi

- rotor device is
mechanically very simple and electronically very complex . It is a 100% fly

- by

- wi re device that
cannot be controlled without a computer

. No flight control cables or surfaces. The only moving
parts are the electric motors and they are extremely reliable. It is difficult to see how
preventive maintenance can be applied to electronic d evices. Structurally, experience shows

sUAS to be pretty tough as they seem to surviv e some pretty nasty human cause d crashes

. Based on the above discussion and a lack of guidance from the sUAS manufacturer, we have

created our own maintenance program to ensure airworthiness of our sUAS.



### 7.1 Maintenance Log

An electronic log is maintained for each aircraft owned by the NGD. All flights

- time s , inspections and maintenance events are recorded in the log.



### 7.2 Periodic Inspection

Periodic inspections are performed,

 Qu arterly or every 20 flight hours

– whichever comes first

 If the aircraft was exposed to water

 After any report of unusual unexplained behavior of the aircraftThe inspection consist of the following,

 Removal of top cover

 Look for foreign debris inside copt er

 Check that connectors are secure

 Check solder joints

 Look for frayed wires

 Look for crimped wires

 Look for signs of burning

 Check tightness of all internal screws

 Check motors for: clip on bottom end spins easily and quietly

 Reinstall motor screws

 Reins tall top cover

 Inspect the structure for cracks, bent or damaged parts

 Check props for dings and chips

 Check prop hubs for small cracks where blades blend with the hub



### 7.3 Battery Management

A n electronic log is used to record battery usage. This is necessary to comply with the DJI
Manuals to fully discharge batteries after around 20 charges. The specific battery used also
recorded in the maintenance log. Batteries are store d with a 50% charge if they are not being
used for an upcoming flight.



### 7.4 Functional Tes t Flight (FTF)

An FTF is flown by the most experienced pilot of the type of aircraft being tested. The testing
must take place in a clear area, so as not to be a hazard to persons or property. The PIC must
be accompanied by a VO.

An FTF is flown in the f ollowing circumstances,

 Replacement of flight critical components ( i.e. motors, any electronic box)

 Any change that impacts weight and balance ( i.e. new camera)

 After a periodic inspection

 After any report of unusual behavior of the aircraft for which no p roblem is found



### 8 Summary

NGD feels it has made a compelling case for the exemptions requested. Our Chief pilot has over 2600 military and civilian flight hours plus other aviation experience. As a Navy carrier pilot he is very familiar with the importanc e of maintenance, procedures, checklist s, weather

and knowled ge of rules and regulations as keys to safe flight operations. We have created detailed processes that include considerable up front work that takes place before starting ajob. We have develop ed maintenance procedures that we believe is the best possible for sUAS

type aircraft. We have defined training requirements and are in the process of creating a syllabus and written test for each area. We are close to completing an Operations Manual tha t will encapsulate these things and be the key document for our operations

.

Sincerely,

Stan Jessen