November 16, 2015 U. S. Department of Transportation Docket Operations , M

-30 1200 New Jersey Ave

., SE Room W12

- 140 West Building Ground Floor Washington DC 20590

-0001 Re: Exemption Request Section 333 of the FAA Reform Act and part 11 of the Federal Aviation Regulations from 14 CFR 21; 61.113 (a) & (b); 61.133 (a); 91.7 (a); 91.9 (b); 91.109 (a); 91.119 (c); 91.121; 91.151 (a); 91.203; 91.405 (a); 91.407 (a) (1); 91.409 (a) (2); 91.417 (a) & (b). Dear Sir or Madam, Pursuant to Section 333 of the FAA Modernization and Reform Act of2012 (the Reform Act) and14 C.F.R. Part 11 , Leading Edge Drone Imagery, LLC, operator of Small Unmanned Aircraft Systems (sUAS) equipped to conduct aerial filming and photographing to include: commercial and residential real estate, infrastructure inspections , construction, architecture, environmental assessment, land surveying and mapping and other applicable applications in pre-planned and controlled areas , hereby applies for an exemption from the listed Federal Aviation Regulations (FARs) to allow commercial operation of its sUAS, so long as such operations are conducted within and under the conditions outlined herein or as may be established by the Federal Aviation Administration (FAA) as required by Section 333.

As described more fully below, the requested exemption would permit the operation of small , unmanned and multi

-rotor aircraft under controlled conditions in airspace that is 1) contained 2) predetermined 3) has on-site safety personnel controlling access , and 4) would provide increased safety and enhancements to clients' business operations

. The name and address of the applicant is: Leading Edge Drone Imagery, LLC Michael J

. Rempe 143 Draper Dr. , Statesville, NC 28625 Phone : 864

-991

-7857 Email: mike

.rempe @ outlook.com
Company Background and Planned Operations Leading Edge Drone Imager y, LLC is a North Carolina Company owned and operated by Michael J. Rempe. Mr. Rempe has been a FAA certified pilot since 1998 and has a current medical and flight review . He also has experience fl ying sUAS and is familiar with the operations and the maintenance ofthe hardware and software updates for these sy stems. The planned operations will involve collection of aerial imaging and sensor data to enable inspections and assessment ofcommercial and residential real estate, infrastructure

1inspections , construction, architecture, environmental assessment, land surveying and mapping and other applications in pre-planned and controlled areas. Public Interest The use of a UAS reduces the environmental impact by decreasing energy usage for aerial imaging data collection. The UAS use rechargeable lithium batteries and electric motors , as opposed to flammable fuel consumed by a fixed-wing aircraft or helicopter. The UAS can replace the fixed wing aircraft or helicopter in most imaging, data collection or monitoring situations. The UAS we propose to fly weigh less than 20 lbs

., carry no combustible fuel or crew members , reduces air and noise pollution and creates an increased safety factor for the public

. And lastly , there will be applications in the construction industry that will eliminate the need ofputting workers at risk of a fall. Since falls are the leading source of construction workplace fatalities , the use of a UAS for inspecting and site imaging could save workers lives. Equivalent Level of Safety Leading Edge Drone Imagery, LLC requested exemption would permit the operation of lightweight UAS (less than 55 lbs. total takeoff weight) by a FAA certified pilot under controlled conditions and would provide an equivalent or higher level of safety. The enhanced safety using a UAS in comparison to combustible fuel aircraft is self-evident and beneficial to the public's interest. All operations will be performed with the public ' s safety and right to privacy safeguarded at all times.
VAS Devices Leading Edge Drone Imagery, LLC UAS are lithium battery powered, weighing less than 55 lbs

. including payload

. The fleet includes the Yuneec Typhoon Q500 4K, DJI Phantom 3 Advanced and DJI Spreading Wings S900.

Specs OJI Phantom 3 Yuneec Typhoon OJI Spreading Advanced QS004K Wings 5900 Type 4 electric motors 4 electric motors 6 electric motors Weight 2.82 lbs 3.75 lbs 181bs Flight Speed 18 mph 

### J 15.s 35.8 mph 

### J31.1 (max) 36 MPH 

### I 31.3 knots knots knots Flight Time 23 min 25 min 18 min

All UAS in the fleet operate at speeds less than 87 knots (100 mph) and have the capability to hover and move in vertical and horizontal planes simultaneously in a precise and controlled manner. Our intent is to use the UAS at much slower speeds for imaging and data collection applications. As the industry progresses , we would like to incorporate more advanced hardware and software into our operations

. Statutory Authority for Exemptions Leading Edge Drone Imagery, LLC submits this application in accordance with the Reform Act, 112 P.L. 95 331-334, seeking relief from any currently applicable FAR ' s to prevent 2Leading Edge Drone Imagery, LLC from future commercial use of small UAS to operate in the national airspace system as described below. The Reform Act section 332 provides for such integration of civil unmanned aircraft into our national airspace as it is in the public's interest to do so . Leading Edge Drone Imagery, LLC UAS fleet will meet the definition of 'small unmanned aircraft" as defined in Section 331 and therefore the integration ofthese UAS are expressly contemplated by the Reform Act. 

### Leading Edge Drone Imagery, LLC would like to operate its lightweight UAS prior to the time period by which the Reform Act requires the FAA to promulgate rules governing such aircraft.
The Reform Act directs the Secretary ofTransportation to consider whether certain unmanned systems may operate safely in national airspace before completion ofthe rule making required under Section 332 ofthe Reform Act. In making this determination , the Secretary of Transportation is required to determine which UAS do create a hazard to users of the national airspace system or the public or pose a threat to national security in light of the following:
The UAS size , speed, weight, and operational capability Operation of the UAS in close proximity to airports and populated areas Operation of the UAS within visual line of sight ofthe Pilot in Command (PIC)
Reform Act 333(a) (1). Ifthe Secretary determines that such vehicles " may operate safely in the national airspace system, the Secretary shall establish requirements for the safe operation of such aircraft in the national airspace system. " Leading Edge Drone Imagery, LLC utilizes UAS weighing less than 55 pounds that operate at speeds less than 87 knots (100 mph) and have the capability to hover and operate in the vertical and horizontal plane simultaneously in a precisely controlled manner. The UAS will only be operated within the visual line of sight ofthe PIC within a controlled flight area of 400 ft. above ground level (AGL) or less

. Most operations are projected to be flown at heights much lower and will not present a hazard to the national airspace or the public

. The small nature ofthese UAS combined with the Operations and Risk Management in a following section will allow for the safe operation greater than that envisioned by Congress for the FAA to establish and, by exemption, allowing commercial operations ofUAS. Also , due to the size of the UAS and the controlled areas and low altitudes in which they will operate, approval of this exemption presents no national security issues and minimal safety concerns which have been mitigated by our risk management process. Given the clear direction in Section 333 ofthe Reform Act, the authority contained in the Federal Aviation Act, as amended , the strong equivalent level ofenhanced safety, reduced emissions and noise pollution, utilizing the UAS verses traditional aircraft benefits the greater public ' s interest. Leading Edge Drone Imager y, LLC request that the FAA grant the requested exemption without delay

.

3Regulations for Exemption Request Leading Edge Drone Imagery, LLC respectfully request the grant of an exemption to the fo llowing specific sections of the Title 14 code of Federal Regulations allowing it to operate lightweight UAS's for commercial use. Regulation Brief Description 14 CFR21 , subpart H Air Worthines s C ertificates 14 CFR 45

.23 (b) Identific ation and Reg istrati on Marking 14 CFR 91.7 (a) Civil Aircraft Worthine s s 14 CFR91.9 (b) (2) Civil aircraft fli ght manual , marking, and placard requirements 14 CFR 91. l 03 (b) Prefl ight action 14 CF R91.109 Flight instructi on ; S imulated instrument flight and certain fli ght tests 14 CFR 91.119 Minimum safe altitudes 1 4 C FR 91. 12 I Altimeter settings 14 CFR 91.15l (a) Fuel requirements for fl ight in VFR conditions 14 CFR 91

.203 (a) &(b) Civil Aircraft : Certifications required 14 CFR 91.405(a) Maintenance required 14 CFR 9 l.407 ( a)( I) Operati on after maintena nce , preventi ve maintenance, rebuilding , or alterati on. 14 CFR 91.409(a)&(b ) Inspections
Operations and Risk Management Conditions and Limitations The following are our proposed procedures and limitations for the flight operations of Leading Edge Drone Imagery, LLC. These proposed guidelines are open to modifications provided by the FAA in response to this request and future requirements issued by the FAA

. 1

. Flights will only occur during the daytime hours

. 2

. Flights will be operated in the visual line

-of

-sight (VLOS) of the operator (PIC) and the visual observer (VO) using human vision with no supplemental devices other than corrective lenses. 3

. Flights will be terminated at any time the weather and wind deteriorate to being "unsafe" for flight based on the manufacturer's recommendations and the PIC ' s experience

. Operations will follow the anticipated guidelines ofthis exemption (operations under visual meteorological conditions

- VMC , and standard visual flight rules

- VFR). 4. All documents , manuals , and maintenance logs associated with the UAS will be present on the site of operations. In addition, the credentials ofthe PIC (pilot

4certificate , pilot logbook with current flight review and current medical) will be available on site. 5. The UAS will be assessed for airworthiness by the PIC prior to each flight session using a checklist derived from the manufacturer ' s manual. All necessary calibrations and testing prior to the flight session will be performed

. 6. All UAS ' s in fleet will each weigh less than 55 lbs with speed capabilities well less than 87 knots. 7. Flights will be operated at 400 feet AGL or less

. 8

. Crew will be at a minimum of the operator (PIC) and a visual observer (VO)

. The PIC will be responsible for safety briefings , preflight inspections , ensuring the UAS is in condition for safe flight , fl ying the UAS and monitoring its status and flight dynamics while maintaining line of sight visualization and keeping the system operations within the specified factory limits (e

.g. flight range , battery power, etc.). The VO will be involved in monitoring the airspace for other aircraft, the ground for unintended vehicles and bystanders , and will also look for additional hazards that could compromise safe operations. 9

. Operator (PIC) and crew, including the VO will remain in voice contact during the entire flight operation 10. Prior to operations , weather forecast , weather radar, and air traffic patterns for the area will be reviewed. The proximity ofthe intended location with respect to airports and Temporary Flight Restrictions (TFR ' s) will be determined using Foreflight software on iPad or mobile devices

. If operations are anticipated within 5 nautical miles of airport reference points , the airport management or Air Traffic Control (ATC) tower will be notified prior to the operation, identif ying the location, anticipated time and intent of flight operations. A portable hand held radio will also be available to monitor local air traffic and contact local tower ifnecessary. When in the vicinity of non -towered airports , we will monitor air traffic in the area and be able to inform them of our operations as needed. 11. The UAS PIC will perform a final check ofthe flight area and make certain of the safety of all persons present and property in the controlled area prior to initiating flight operations. 12. All UAS will have the capability to return automatically to the operator in a safe manner in the event of lost communications with the remote controller or a system problem

. The auto return function will be checked and verified for proper operation on a regular basis. A starting OPS home position calibration will be performed prior to each new flight. 13. The UAS will have indicators on the control and/or displays to inform the operator ofthe UAV's distance away from the operator, its altitude and velocity, and remaining battery power. 14. Written and/or oral permission from the relevant property holders will be obtained when flights are conducted over private or controlled access property. Benefits to the public 

### as a whole Approval of these 333 exemptions in general would allow commercial operations of small UAS to provide numerous services to our clients that would benefit from aerial imaging and data collection while greatly enhancing safety by reducing the overall risk associated 5with traditional aircraft. With the use of small UAS of 55 lbs or less that are battery operated and flying below 400 feet AGL, the risk of injury ofpeople on the ground or flight crew is greatly minimized in comparison

. 

### Leading Edge Drone Imager y, LLC respectfully request the FAA grant its exemption without delay

. The FAA has the authority to issue the exemption sought by 

### Leading Edge Drone Imager y, LLC pursuant to the Federal Aviation Act, 85 P.L. 726 (1958) as amended (the ACT).
Please feel free to contact me if I can provide additional information and clatity to help expedite the process. Sincerely , 

# v;:' /f:~'?YMichael J

. Rempe Leading Edge Drone Imagery, LLC 14 3 Draper Dr. Statesville , NC 28625 Mike.rempe'a'outlook.com (M) 864

-991

-7857
Private Pilot Single Engine Land

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