August 7, 2015

U.S. Department of Transportation Docket Management System 1200 New

Jersey Ave., SE Washington, DC 20590

Laurent Fady 965 Kemp Rd Petoskey, MI 49770
Dear Madam or Sir, ADERYS Northern Michigan Aerial Survey Systems is seeking exem ption s under Section 333 from FAR title 14, parts 21, 36, 61 and 91. Aderys has been created to offer aerial imagery to be used for real estate agents, land surveyors, precis ion farmers, law enforcement, search and rescue agencies, construction and industrial compani es and any individual or entity requiring detailed aerial image s . The sensors are carried by a DJI S1000 UAV, and will provide photographic , videograph ic , multispectral and thermal documentati on. I will be the pilot in command and currently hold a US private and commercial pilot certificate , single engine land, IFR rated ( number 2463550 ), a glider pilot license issued in France (VV0205009590), an Ultralight pilot license issued in France (0205 004994) and a private pilot license issued in France (TT0203001593) and have a total flight time of over 4 00 hours ; I also hold a valid driver’s license issued in Michigan. I seek exemption f

r o m the following 14CFR rules under Section 333 to be able to o perate UAVs without undue burden and to offer valuable services to the Northern Michigan communities: 14CFR §21, 14CFR §91.7 (a) and 14CFR §91.203 relative to airworthiness of UAV: the FAA, in its “Notice of Proposed Rulemaking” (NPRM) relative to the operation of small unmanned aerial vehicles, does not impose an airworthiness certificate. The UAV operated by ADERYS will be inspected prior to each flight according to the procedures suggested by the manufacturer, following a pre

- flight i nspection checklist. 14CFR §36 relative to noise testing and certification as this UAV generates less noise than a car. 14CFR §61.23 (2) and (3) which states that “ a person: 2) Must hold at least a second class medical certificate when exercising: (i) S econd

- in

- command privileges of an airline transport pilot certificate in part 121 of this chapter (other than operations specified in paragraph (a)(1)(ii) of this section); or (ii) Privileges of a commercial pilot certificate; or (3) Must hold at least a third

- class medical certificate

— (i) When exercising the privileges of a private pilot certificate ” Since the FAA does not require a medical certificate in its NPRM relative to the operation of small unmanned aerial vehicles, this rule should not apply to the PIC of a DJI S1000 UAV.1 4CFR §91.9: a UAV cannot comply with aircraft	flight	manual,	marking,	and	placard	requirements	due	to	its

size .	However,	a	user	manual	will	always	be	available	befor e,	during	and	after	each	flight,	and	the	UAV’s	serial number can	be	placated	on	its	frame. 14CFR §91.109 (a): “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.” A UAV does not have dual flight co ntrols. 14CFR §91.119 (b) and (c) which states that: “E xcept when necessary for takeoff or landing, no person may operate an aircraft below the following altitudes: (b) Over congested areas. Over any congested area of a city, tow n, or settlement, or over any open air assembly of persons, an altitude of 1,000 feet above the highest obstacle within a horizontal radius of 2,000 feet of the aircraft. (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.” A UAV , being limited to a ceiling of 500 f t AGL , cannot be in compliance with this rule. 14CFR §91.121 relative to altimeter settings; this UAV does not operate with an altimeter but uses GPS altitude information. This will be set to zero before each flight. 14CFR §91.151 relative to fuel requir em ents during VFR flights which requires “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; or (2) At night, to fly after that for at least 45 minut es.” The maximum flight time of our UAV is no longer than 20 minutes on a fully charged battery. 14CFR §91.405, §91.407, §91.409, §91.417 relative to maintenance and inspection, which have to be performed by authorized personnel and logged into the mainte nance logbook kept in the airplane. There are no manufacturer recommended maintenance schedule s other than preflight inspections and no certified mechanic for this type of aircraft. An exemption from these rules w ould not jeopardize public safety as it is my intention to follow strict procedures prior, during and after each flight to insure safe operation.
 Preflight inspection
 Consent of flight from client/landowner
 Visual Line of Sight flight rule maintained
 DJI S1000 w eighs less than 55 lbs and has a maximum airspeed we ll below 100m ph
 DJI S1000 does not carry flammable fuel
 Minimum flight VFR requirements observed
 Post flight inspection
ADERYS proposes to fly a DJI S1000 octocopter with the purpose of high definition aerial imagery and to offer its services to the Northe rn Michigan communities. The on

- board sensors can be used fo r photography and videography, building and structure inspection, photogrammetry and mapping, assistance in search and rescue operations, and for forestry a nd crop management. This will apply to industries such as real

- estate agents, building insulation inspections , land surveyors , construction, government agencies , emergency response teams, agriculture and land management. Before each flight, an agreement will be signed to obtain authorization to fly over private/public property. A thorough pre

- flight inspection will be performed, including and not limited to checking motors and propellers, center of gravity, all parts secured, communication with ground station confirmed, ATC authorization received if within class C or D , communication established and monitored f or E airspace, take

- off area cleared, and w eather forecast checked. No flights will be conducted in class B airspa ce. Compass will be calibrated, and GPS communi cation confirmed with a minimum of 6 satellites.Flights will be conducted during daylight, within visual line of sight range, in VFR weather conditions, no higher

than 500 FT AGL, clear of clouds and with a 3 mile visibility. The m aximum operating airspeed will be kept below 30 mph. Crowded areas will be avoided. In busy airspace, communication will be maintained with local ATC and traffic, and right o f way yielded to other aircraft

. A trained spotter will be used in case there are obstructions betw een the PIC and the intended flight path. The S1000 is equipped with a failsafe feature which automatically brings it back to its ground station in case of communication failure with the PIC or low battery level

. Fl ights will be terminate d when battery level reaches 30%. The landing area will be cleared of obstacle s and people. Alternate landing zone s will have been identified in case of em ergency landing. The UAV will be inspected for any damage, loose or missing p art s . If an ATC authorization was received, ATC will be contacted to declare end of flight.
Here are the specifications of a DJI S1000 per the manufacturer’s website:

**Fram e**  Diagonal Wheelbase: 1045mm

Fram e Arm

Length: 386mm Fram e Arm Weight (Including Motor, ESC, Propeller ): 325g Center Frame Diameter: 337mm Center Frame Weight (with Landing Gear Mounting Base, Servos): 1520g Landing Gear Size: 460mm (Length)×511mm(Width)×305mm(Height)

**Motor** Stator Size: 41×14mm

KV: 400rpm

/V Max Pow er: 500W Weight (with Cooling Fan): 158g

**ESC** Working Current: 40A

Working Voltage: 6S LiPo Signal Frequency: 30Hz ~ 450 Hz Drive PWM Frequency: 8 KHz Weight (with Radiators): 35g

**Flight Param eters**  Takeoff Weight: 6.0Kg ~ 11.0Kg

Total Weight: 4.4Kg Pow er Battery: LiPo (6S, 10000mAh~20000mAh , 15C ( Min)) Max Pow er Consumption: 4000W Hover Pow er Consumption: 1500W (@9.5Kg Takeoff Weight) Hover Time: 15min (@15000mAh & 9.5Kg Takeoff Weight) Working Environment Temperature:

- 10 °C ~ +40 °C

As demonstrated above, an exem ption under Section 333 would not jeopardize public safety and would enhance Northern Michigan communities with never before offered aerial service s .
Respectfully submitted,

Laurent Fady Northern Michigan Aerial Survey Systems