Petition for exemption section 333

Telesens, LLC 900 North Stuart Street Apt 804 Arlington VA 22203 . Phone: 301

- 219

-0661 Email: ankur@umiacs.umd.edu Re: Exemption Request Section 333 of the FAA Reform Act and Part 11 of the Federal Aviation Regulations from Title 14, Code of Federal Regulations 14 C.F.R. Part 21; 14 C.F.R. 45.23 (b); 14 C.F.R. 61.113(a) and (b) ; 14 C.F.R. 91.7; 14 C.F.R. 91.9; 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); 91.407 (a) (1); 91.409 (a) (1) & (2); 91.417(a) & (b)
**PETITION FOR EXEMPTION** Dear Sir or Madam: Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the Reform Act) and 14 C.F.R. Part 11, Telesens, LLC, operator of Small Unmanned Aircraft Systems (“sUASs”) (referred to as the “P etitioner” or “Applicant” ) hereby applies for an exemption from the listed Federal Aviation Regulations (“FARs”) to allow commercial op eration of its sUASs, so long as such operations are conducted within and under the conditions outlined herein or as may be established by the FAA as required by Section 333.1 As described more fully below, the requested exemption would permit the operati on of sUAS under controlled conditions in airspace that is 1) limited 2) predetermined and 3) controlled. The proposed exemption, if granted, would allow Telesens, LLC to conduct commercial operations of sUASs meeting or exceeding all of the operational an d safety requirements that Congress has set forth in Section 333. Page 2. Telesens LLC asks that if any part of this request is deemed not in compliance, that part be removed and process the remain der of this request as applicable. **Table of Contents**
1. Introd uction to Telesens, LLC 2. Operations of Interest 3. Regulations from which Exemption is Requested 4. Aircraft Types 5. UAS Information 6. Operation and Safety Standards 7. Public Interest 8. Exemption Request Details 9. Request for waiver for publication and comment procedures 10. F ederal Register Summary **Telesens,	LLC** Address: 900 North Stuart Street, Apt 804 Arlington, VA 22203 . EIN: 47

-4983461Telesens, LLC is a technology company owned and r un by Ankur Ankur. Mr. Ankur holds a M asters in

Electrical Engineering from the University of Maryland and a M.B.A from Georgetown University. Mr. Ankur is intimately familiar with the details of flight control and command and control systems used in UAS and has given numerous talks about building and safely operating UAS in the greater Washin gton, DC area. A link to Mr. Ankur’s recent talk about operating the Iris+ quadcopter from 3D Robotics is as follows: http://www.meetup.com/DC

-Area

- Drone

- User

- Group/events/224717878/ Mr. Ankur has extensive experience operating sUAS manufactured by 3D Robotics and DJI and has flown numerous flights in both manual and autonomous mode without incident and always respecting applicable FAA regulations. **Operations	of	Interest** Telesens, LLC plans to exploit the capabilities of UASs to offer a multitude of services, including:

- Aerial Surveying and 3D mapping

- Event Photography/Videography

- Crop Inspections

- Real Estate Photography

- Construction site Inspections and Surveys

- Research and Development and

- Education **Regulations	from	which	Exemption	is	Requested** Statutory Authority Section 333, titled “Special Rules for Certain Unmanned Aircraft Systems”, provides a mechanism for seeking expedited FAA authorization of safe civil UAS operations in the NAS. Section 333(a) states that the FAA “shall determine if certain unmanned aircraft systems may operate safely in the national airspace system before completion of the (comprehensive) plan an d rulemaking required by section 332(b)(1) of this Act or the guidance required by section 334 of this Act.” In Section 332(b)(1), Congress made it clear that Section 333 provides a mechanism for “expedited operation authorization” if several factors are m et. Petitioner meets all requirements to permit FAA approval of commercial UAS operations. The petitioner requests relief from the following regulations: 14 C.F.R. Part 21 14 C.F.R. 45.23 (b) 14 C.F.R. 61.113(a) and (b) 14 C.F.R. 91.7 14 C.F.R. 91. 9 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); 91.407 (a) (1); 91.409 (a) (1) & (2); 91.417(a) & (b)**Aircraft	Types**

Exemption is requested for the following aircrafts: DJI Phantom 3 DJI Inspire 1 3DR Iris+ 3DR Solo

**UAS Information**  Salient Features of these aircrafts are present ed in the table below:

DJI Phantom 3 (Pro) DJI Inspire 1 3DR Iris+ 3DR Solo Weight 1280 g 2945g 1282g 1800 g Max Payload Max Speed 16 m/s 22 m/s 20 m/s 24 m/s Max Climb Rate 5 m/s 5 m/s 5 m/s 10 m/s (stabilize mode) GPS Failsafe? Yes Yes Yes Yes GeoFence (max altitude, radius from home)? Yes Yes Yes Yes

Battery Life (with Payload) ~20 min ~15 min ~20 min ~20 min

**User	Manuals:** Phantom 3: http://download.dji

innovations.com/downloads/phantom_3/en/Phantom_3_Professional_User_Manual_v1.4_en.pdf Inspire 1: http://download.dji

- innovations.com/downloads/inspire_1/en/Inspire_1_User_Manual_v1.4_en.pdf
3DR Iris+ http://3drobotics.com/wp

- content/uploads/2015/02/IRIS

- Plus

- Operation

- Manual

-vH

-web.pdf 3DR Solo http://3drobotics.com/wp

- content/upload s/2015/08/v5_08_21_15.pdfAll UASs referred to in this petition feature an integrated microprocessor and IMU sensors running

heavily tested flight control systems that continuously maintain aircraft stability and geospatial position and orientation. The se nsors include gyroscopes, accelerometers, GPS unit, barometers and compass. The DJI Phantom 3 and Inspire 1 also feature integrated optical flow sensor enabling the UAS to hover by observing patterns on the ground. The flight control boards contain multipl e sensor units to provide redundancy. The UASs are primarily controlled by FCC certified radio control (RC) unit. Real time video and telemetry information is transmitted back to the ground control station allowing the PIC to monitor battery level, GPS sig nal strength, altitude, distance from PIC, camera imagery and camera angle. **Risk	Mitigation** The petitioner's small UAS has failsafe modes of operation for either loss of radio control, GPS signal, or low battery level. Altitude can be limited by the onboa rd flight controller and maximum altitude can be programmed by the PIC. Battery life limits flight times to approximately 25 minutes. The onboard flight controller will warn the pilot via telemetry and external lighting cues before reaching a low battery state. An automatic termination of flight and landing will be initiated when the battery reaches a predetermined state. It is anticipated that flights will usually last less than 10 minutes. More information is available on: Pages 12

- 14 of the attached Phan tom 3 Professional User Manual version 1.4 Page 13

- 16 of the attached Inspire 1 User Manual version 1.4 Page 7 of the attached Iris+ User Manual Section 6.2 of the attached Solo User Manual **Operation	and	Safety Standards** 

 The sUASs will weigh less than 10 pounds

 Flights will be operated within line of sigh t of a pilot and/or observer.

 Maximum flight time for each operational flight w ill be no more than 20 minutes

 Prior to each flight, the pilot shall conduct pre

-flight checks including but not limited to: ensuring the battery for the UAS and the remote control is fully charged, there is no visible damage to the airframe and propellers that might impede safe flight or alter expected flight characteristic, a sufficientl y strong GPS lock is available, all sen sors on board required for a safe flight such as accelerometers, gyroscopes, barometer, compass/magnetometer are properly calibrated. The pilot will also ensure that the “home position” (point of origination) is set properly and the vehicle is able to safe ly return to home in case a return to home is triggered.

 Flights will be terminated at no less than 30% battery power reserve should that occur prior to the 20 minute limit.

 Flights will be operated at an altitude below 3 00 feet AGL, and not more than 15 0 feet above an elevated platform from which filming is planned.

 Minimum crew for each operation will consist of the sUAS P ilot and the Visual Observer. A sUAS pilot wi ll be Pilot in Command (PIC)

 A briefing will be conducted for planned sUAS operations prior to each day’s flight. All personnel performing duties within the boundaries of the safety perimeter are required to attend.

 The operator will obtain consent of all persons involved in the filming and ensure that only consenting persons w ill be allowed within 500 feet of the flight operation.

 The Pilot and observer must be trained in sUAS operations and have received current information on the particular sUAS to be operated

 The Observer and pilot will be able to communicate at all times

 Written and/or oral permission from the relevant property holders will be obtained prior to flight operations.

 If the sUAS loses communications or loses its GPS signal, the sUAS will have the capability to return to the point of launch using the RTL safety future of the flight controller

 Detailed logs contain position and altitude information and IMU measurements will be maintained by the UAS operator. **Public	interest** Use of the s UAS in lieu of a manned aircraft would enhance safety and reduce the environmental impact as compared to similar operations conducted with manned aircraft of greater proportions, carrying a crew and flammable fuel. Additionally, use of the s UAS in order to facilitate commerce could lead to economic growth. Operations for this petition will enable service for property owners or their designees seeking an enhanced perspective for characteristics, amenities, and benefits of their desired photographic subjects that cannot be displayed through ground level videography/photography. Aer ial photography is a valuable marketing tool that can lead to increased commerce and enhance personal photography. Crop surveying applications could lead to decreased use of pesticides and fertilizer and conservation of water as well as increased crop yiel ds and decreased costs. Aerial surveying and inspections can increase work site efficiency, improve volumetric estimations and reduce risks. Liability insurance will be obtained commensurate with the granting of this request for exemption. Detailed logs co ntain position and altitude information and IMU measurements will be maintained by the UAS operator and provided to relevant government agencies upon request. **Exemption	Request	Details**

**14 CFR Part 21, Airworthiness Certificates** This part establishes the procedures for the issuance of an airworthiness certificate. While the FAA continues to work to develop airworthiness standards for Unmanned Aerial Systems, we request an experimenta l certificate be issued for the sUASs considered herein under either or b oth of the following provisions: 21.191 Experimental certificates. Experimental certificates are issued for the following purposes:**(a) Research and development** . Testing new aircraft design concepts, new aircraft equipment, new

aircraft installations, ne w aircraft operating techniques, or new uses for aircraft. **(b) Showing compliance with regulations** . Conducting flight tests and other operations to show compliance with the airworthiness regulations including flights to show compliance for issuance of typ e and supplemental type certificates, flights to substantiate major design changes, and flights to show compliance with the function and reliability requirements of the regulations. Since the experimental certificate can be used for commercial purposes su ch as market surveys, sales demonstrations, and customer crew training, we would expect that an experimental certificate would permit our commercial purpose as well. The aircraft will not carry persons or property, will not carry fuel, and will only fly un der strict operational requirements. Combined with the UAS 's light weight, being constructed primarily of carbon fiber and plastic, we propose that the UAS will be at least as safe, if not safer, than a conventionally certificated aircraft performing the s ame mission. If an experimental airworthiness certificate is not appropriate for this application, then we request an exemption of 14 CFR Part 21, Subpart H, and the requirement for airworthiness certificate in general, citing the equivalent level of safety outlined in the previous paragraph. Please note that Exemption # 11224 granted to NextEra Energy, Inc. determined that the DJI Phantom 2 Vision +, DJI Inspire, and DJI S900 were previously determined in other exemptions to not be required to have an airworthiness certificate based upon the authority of Section 333 of the FAA Modernization and Reform Act of 2012. Other exemptions have also determined that the Phantom 2 platform does not need an airworthiness certificate. See Exemption # 11220 for Aerial Production Services, Inc. The Phantom 3 platform is similar to the Phantom 2 and should not n eed an airworthiness certificate. We argue that the 3DR Iris+ and Solo have also been extensively flight tested and used safely by hundreds of thousands fliers and should be suitable exempted from airw orthiness certificate. **14 CFR 45.23 Display of marks**
T hese regulations provide that each aircraft must display "N" and the aircraft's registration number in letters at least 3 inches high. Additionally, the aircraft must display the word "EXPERIMENTAL" in letters at least 2 inches high near the entrance to th e cabin, cockpit, or pilot station. The sUAV does not have an entrance in which the word "EXPERIMENTAL" can be placed, and may not have a registration number assigned to it by the FAA. We propose to achieve an equivalent level of safety by includin g the wo rd "EXPERIMENTAL" in a placard on the top of the aircraft, where the PIC (Pilot In Control), VO (Visual Observer) and others in the vicinity of the aircraft while it is preparing for launch will be able to see the designation. **14 C.F.R. § 61.113(a) and (b ): Private Pilot Privileges and Lim**  **itations** Pilot in Command Sections 61.113 (a) and (b) limit private pilots to non

- commercial operations. Because the sUAS will not carry a pilot or passengers, the proposed operations can achieve the equivalent level of safety of current operations by requiring the PIC operating the aircraft to have a private pilot’s license rather than a commercial pilot’s license to operate a sUAS. Unlike a conventional manned aircraft, asUAS is remotely controlled by a ground

- based operator. The operational area is controlled and

restricted, and all flights are planned and coordinated in advance. The level of safety exceeds that provided by a single individual holding a commercial pilot’s certificate operating a conventional aircraft. The risks associated with the use of a sUAS are so diminished from the level of risk associated with commercial operations contemplated by Part 61 allowing s UAS use by a sport pilot as the PIC exceeds the present level of safety sought by 14 C.F.R. §61.113 (a) and (b). **14 CFR 91.7: Prohibits the Operation of an aircraft without an airworthiness certificate** As no such certificate will be applicable in the form contemplated by the FARs, this Regulation is inapplicable. **14 CFR 91.9: Civil aircraft flight manual, mar king, and placard requirements**  This regulation provides that no person may operate an aircraft unless a current, approved flight manual is in the airc raft. We assume that the intent of this requirement is to ensure that flight manual information is available to the aircrew while operating the aircraft. We request an exemption to this requirement since the aircraft is not only too small to carry document ation, the documentation would not be available to the crew during flight operations. To obtain an equivalent level of safety and meet the intent of 91.9, we propose that a current, approved sUAS Flight Manual must be available to the crew at the ground st ation anytime the aircraft is in, or preparing for, flight.
**14 C.F.R. 91.119(c): Minimum Safe Altitudes**  Section 91.119 establishes safe altitudes for operation of civil aircraft. Section 91.119 provides, in pertinent part, that: “except when necessary for takeoff or landing, no person may operate an aircraft 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.” Telesens, LLC requests authority to operate at altitudes no higher than 300 AGL, and not more than 15 0 above an elevated platform from which filming is planned, an exempti on is needed to allow such operations. The sUASs will be operated in a restricted area within a security perimeter, where buildings and people will not be exposed to operations without their pre

-obtained consent. The equivalent level of safety will be achi eved given the size, weight, and speed of the sUAS as well as the location where it is operated. No flight will be taken without the permission of property owners or local officials. Because of the advance notice to the property owners and participants involved in the sUAS operation , all affected individuals will be informed of the planned flight operations. Compared to flight operations for conventional aircraft, any risk associated with the proposed sUAS operations is far less than conventional aircraft o perating at or below 500 AGL. In addition, the low

- altitude operations and light weight of the sUASs will ensure separation between the sUAS and conventional aircraft. **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.” As a sUAS may not have a barometric altimeter, but instead a GPS altitude data, an exemption is needed. An equivalent level of safety will be achieved by the operator, pursuant to the operating manuals **14 C.F.R. §91.151(a): Fuel Requirements for Flight in VFR (Visual Flight Rules)**  **Conditions** Section 91.151(a) prohibits an individual from 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 cruisi ng speed

– (1) During the day, to fly after that for at least 30 minutes . . . .” The typical battery powering the sUASs provides less than 20 minutes of powered flight. To meet the 30

- minute reserve requirement in 14 CFR §91.151, sUAS flight would not be possible. Gi ven the limitations on the sUAS s proposed flight area and its proposed operations with in a predetermined location, a shorter time frame for flight in daylight VFR conditions is reasonable. Furthermore, operating the sUASs in a tightly controlle d area where only people, property owners, or official representatives who have signed waivers will be allowed, less than 30 minutes of reserve fuel does not engender the type of risk that §91.151(a) was intended to address. Petitioner believes that safety can be achieved by limiting flights to 15 minutes or 30% of battery power, whichever occurs first. This restriction would be more than adequate to return the sUAS to the point of launch from anywhere in its limited operating area. Information provided in the operating documents discusses procedures regarding remaining battery power management. Those documents contain a condition in which the PIC will initiate a landing procedure when battery remaining reaches a specified level. Beyond that, the petitioner 's small UAS initiates a "Go Home" (to the flight's origination point) when battery level drops to the "Low Battery" level. Telesens will ensure that aircraft remains within reach of the origination point in case a “Go Home” needs to be initiated. Similar UAS

-specific relief has been granted in Exemption Nos. 8811, 1 0808, and 10673 for daytime, VFR conditions. **14 C.F.R. §91.405 (a); 91.**  **407 (a) (1); 91.**  **409 (a) (1) &**  **(2); 91.**  **417(a) & (b): Maintenance Inspections and**  **Records :**  These regulations require that an aircraft operator or owner 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 part 43 of this chapter...,” and others shall inspect or maintain the aircraft in compliance with Part 43. Given that these sections and Part 43 apply only to aircraft with an airworthiness certificate, these sections will not apply Telesens’ s operations. An equivale nt level of safety will be achieved because these small UAS’s are very limited in size and will carry a small payload and operate only in restricted areas for limited periods of time. The operator will also maintain logs of each flight undertaken by the UASs. These logs will contain detailed telemetry data about aircraft altitude and position, IMU measurements, RC inputs, flight controlleroutput and other information necessary to fully reconstruct the flight path and characteristics should it

become necess ary. The operator will provide these logs to the FAA, NTSB or any other interested government agency if requested to do so.**REQUEST	FOR	WAIVER	FOR	PUBLICATION	AND	COMMENT	PROCEDURES**

TELESENS, LLC REQUESTS THAT THE PUBLICATION AND COMMENT PROCEDURES BE WAIVED IN ACCORDANCE WITH 14 C.F.R. § 11.87. § 11.87 Are there circumstances in which FAA may decide not to publish a summary of my petition for exemption? The FAA may not publish a summary of your petition for exemption and request comments if you prese nt or we find good cause why we should not delay action on your petition. The factors we consider in deciding not to request comment include: (a) Whether granting your petition would set a precedent. (b) Whether the relief requested is identical to exemptions granted previously (c) Whether our delaying action on your petition would affect you adversely (d) Whether you filed your petition in a timely manner Corresponding to the above sub

-sections, Telesens, LLC has good cause to request the FAA to waive the comment period and not delay action on the petition because: (a) Telesens, LLC would not set any precedent. Telesens, LLC agrees to the same limitations as many similar exemptions already granted, for example, Exemption # 11284. Furthermore, all of th e aircraft requested in this application have already been evaluated under previous petitions and are deemed to have the equivalent level of safety if operated under the restrictions hereto already agreed upon. (c) Delaying the granting of this petition would adversely affect the public, the FAA, and Telesens, LLC. The public, as well as the FAA, would be better served by the FAA quickly granting this petition and thereby freeing up limited FAA resources and allo wing FAA inspectors to dedicate their time and attention to much higher priorities. Moreover, Telesen s, LLC is adversely affected by the below listed regulations. (d) The petition has been filed in a timely manner.**FEDERAL	REGISTER	SUMMARY**

Pursuant to 14 C.F.R. Part 11, the following summary is provided for publication in the Federal Register, should it be determined that publication is needed. Applicant seeks an exemption from the following rules: 14 C.F.R. Part 21, 14 C.F.R. 45.23 (b), 14 C.F.R. 61.11 3(a) and (b), 14 C.F.R. 91.7, 14 C. F.R. 91.9 , 14 C.F.R. 91.119 (c), C.F.R. 91.121, 14 C.F.R. 91.151(a), 14 C. F.R. 91.405 (a); 91.407 (a) (1); 91.409 (a) (1) & (2); 91.417(a) & (b) to operate commercially a small unmanned vehicle (55 lbs. or less) for Aeria l Surveying, Event Photography/Videography, Crop Inspections, Real Estate Photography, Construction site Inspections and Surveys, Education and Research and Development. This exemption will allow commercial operations of UA’s which will enhance safety by reducing risk. The alternative to using a UA is to use a jet or piston power aircraft carrying large amounts of jet or other fuel. Not only is the operation dangerous at the location, the aircraft must fly to the location and back to the home airport. Our U A will weigh less than 55 lbs. and powered by batteries which eliminates most of the risk because no highly flammable fuel will be involved. The UA will carry no passengers or crew; thus, eliminating most of the risk to the pilot and personnel. The operati ons of the UA listed under the restrictions proposed herein will provide an equivalent level of safety as the Federal Aviation Regulations. If I can be of any assistance to further expedite this petition, please do not hesitate to contact me at (301)219

-0661 or at my email ankur@umiacs.umd.com. Sincerely yours,

Ankur Ankur Telesens, LLC 900 North Stuart Street Apt 804, Arlington VA 22203