## May 19, 2015 First Defense Systems LLC 1109 Pleasant Valley Rd West Bend WI. 53095 262-844-3818 billmikkelson@yahoo.com United States Department of TransportationDocket Operations 1200 New Jersey Ave.SE West Building Ground Floor Room W12-140 Washington DC 20590 Re: Exemption Request Pursuant To Sec t ion 333 of the FAA Reform Act of 2012 Dear Sir or Madam:

I am writing pur s uant to the FAA Modernization and Reform Act of2012 (the "Reform Act " )and the procedures contained in 14 C.F

. R

. 11, to request William M Mikkelson DBA First Defen se System s LLC, owner and operator of a small UAS

, and FAA Private Pilot (license#3776396) be e x empted from the Federal Aviation Regulations (FAR 's ) listed below.
Th e exemption is needed in order to operate a small lightweight unmanned aircraft s ystem(UAS) commercially in airspace regulated by the F e deral Aviation Administration (FAA). These operations will be conducted within and under the conditions outlined her e in or as may b e established by the FAA as required by Section 333.§11.81. First Defense Systems LLC ' s commercial use of th e UAS will be re s tricted to c r i sis respo n se sup p ort, includ ing sea r c h a n d r esc u e, damage assessme nt

, in s u ra n ce cl a ims assess m e nt

,accide

n t inves ti gat i o n s and e n ha n cing disaste r s it e si tu ational awareness for f i rst res p onders

, in add i t i on t h e UAS wi ll also be util i zed for reside n t i a l a n d co m mercia l aer i al pho t ography

.

## DJI Phantom 3 

# & Inspire 1 

# First Defense Systems LLC seeks an exemption to operate a DJI Phantom 3 and DJI Inspire 1 UAS, for compensation or hire in the previously described manners. The DJI Phantom 3 and Inspire 1 is comprised of a quad rotor unmanned aircraft and a handheld ground control station. The Phantom 3 and Inspire 1 have a maximum gross weight of approximately 1280g,diameter (rotor span) 23.75 inches, width of 12.5 inches, and height of 8.1 inches. The Phantom

3 and inspire 1 are equipped with four rotors driven by four lithium polymer battery poweredelectric motors. The above UA's operate, under normal conditions at a ground speed of no more than thirty (30) knots and have the capability to hover, and move in the vertical and horizontal plane simultaneously. The above UAs will operate only in line of sight. Such operations will insure that the UA will"not create a hazard to users of the national airspacesystem or the public. EXEMPTION REQUESTS AND EQUIVALENT LEVEL OF SAFETY 14 C.F.R. 21, Subpart H :Airworthiness Certificates 

# Sets forth requirements for procurement of necessary airworthiness certificates. The size, weight, and enclosed operations area of the proposed lightweight UAS's permitsexemption from Part 21 because the UAS meets and exceeds an equivalent level of safety pursuant to Section 333 of the Reform Act. 14 C.F.R. 91.7(a) 

# Prohibits the operation of an aircraft without an airworthiness certificate. As no suchcertificate will be applicable in the form contemplated by the FAR's, this regulation is inapplicable. 14 C.F.R. 91

. 9(b) (2) 

# Requires an aircraft flight manual in the aircraft. As there are no on board pilots or passengers, and given the size of the UAS's, this Regulation is inapplicable. The FAA has previously issued exemptions to this regulation in Exemption Nos. 8607, 8737

,8738,9299,

9299A, 9565,95658, 10167, 10167A, 10602, 10700 and 32827. 14 C.F.R

. 91.121 

# Regarding altimeter settings is inapplicable insofar as the UAS ' s applied for all use electronic global positioning systems with a barometric sensor. Also, line of sightoperations provide separation from other aircraft, obstructions, and terrain, providing

an equivalent level of safety. 14 C

. F.R. 91.203 (a) and (b) 

# Provides for the carrying of civil aircraft certifications and registrations. These are inapplicable for the same reasons described above. The equivalent level of safety will
be achieved by maintaining any such required certifications and registration s by the operator.14 C.F.R. 45.23; Marking of the Aircraft Applicable Codes of Federal Regulation require a i rcraft to be marked according to certain specifications. UAS's are by definition unmanned and have no cockpit or cabin on which to fix letters or numbers. Also

, the aircraft is smaller than the minimum required size of the letters and numbers stipulated

. The FAA has previously issued exemptions to this regulation through Exemptions Nos. 8738

, 10167, 10167 A and 10700. 14 C.F.R. 61.113; Private Pilot Privileges and Limitations: PIC Pursuant to 14 C.F

. R. 61

. 113 (a) and (b)

, private pilots are limited to non-commercial operations . I, William Mikkelson

, can achieve an equivalent level of safety as achieved by current Regulations becaus e my UAS does not carry any pilots or passengers. The risks of operating my UAS are far less than the risk levels in the commercial activities outlined in C.F.R. 61 et seq

. , thus allowing me to operate my UAS only in a way that meets and exceeds current safety levels in relation to 14 C.F.R. 61.113 (a) and (b).
14 C.F.R. 91.119; Minimum Safe Altitudes Prescribes safe altitudes for the operation of civi l aircraft. My UAS will never be operated above 400 AGL. It will also be operated away from public and traffic

, providing a level of safety below the standard of 400 AGL, equivalent to or below current minimum safe altitudes

. Given the size, weight, maneuverability and speed of my UAS, an equivalent or higher level of safety will be achieved . 14 C.F.R. 91.405 (a); 407 (a) (1); 409 (a) (2); 417 (a) and (b); Maintenance Inspections Requires, amongst other things, that aircraft owners and operators to "have [the] aircraft inspected as p r escribed in subpart E ofthis 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

.... "These regulations apply only to an aircraft with an airworthiness certificate. They will not

, therefore, apply to my UAS. However

, as a safety precaution I will inspect my UAS before and after every flight

. 14 CFR 91.103 As FAA approved flight manuals are not available for the aircraft an exemption will be needed. Normal procedures including but not limited to; reviewing weather, flight battery requirement, landing and takeoff distances, and flight characteristics will be in a c cordance to FAA regulations and manufacturers specifications. An equivalent level of safety will be provided by preflight protocol to properly match the machine. 14 CFR 91.109 UAS and remotely piloted aircraft do not have fully functional dual controls. Flight control is achieved through the use of a control box that communicates with the aircraft via radio communications. The equivalent level of safety provided because neither a pilot nor passenger will be carried in the aircraft, and by the speed and size of the aircraft.In Summary

, First Defense Sy s tems LLC s eeks an exception from the following Regulati o ns :
14 C.F.R

. 21

, subpart H ; 14 C.F

. R. 45

. 23 (b) ; 14 C.F

. R

. 61.113 (a) and (b); 14 C.F.R

. 91.7

(a) ; 14 C.F

. R. 91.9 (b) (2) ; 14 C.F

. R

. 91.103 (b) ; 14 C.F

. R

. 91. 1 09 ; 14 C.F

. R

. 91.

1 19 ; 14 C.F

. R

. 91.121 ; 14 C.F

. R

. 91.151 (a ); 14 C.F.R. 91.203 ( a ) and (b) ; 1 4 C.F.R. 91.405 (a); 14 C.F

. R

. 91.407 (a) (1); 14 C.F

. R

. 91.409 (a) ( 2); ( 2) ; 14 C.F.R

. 91.417 (a) (b); and 14 C.F

. R

. 91.45 (a) 

### Summ a ry In Summa r y First Defense Systems LLC requested exemption would authorize the u s e of DJI Phantom 3 and DJI Inspir e 1 in commercial operations of aerial videography and photography

,

c

risis response support

, including search and rescue, damage assessment, insurance claims assessment, accident investigations and enhancing disaster site situational awareness for first responders. The DJI Phantom 3 and DJIIn s pire 1 UAs, will be opera t ed under c ontrolled cond i tions at an a l titude of no greater than three hundred (400) fe et AGL i n ai r spa ce th a t i s limited in s cope and will have automated control features

. First Def e n s e Systems UAs w i ll also

be operated by an individual who has a curr e nt and valid thi r d cla ss medical and current and valid private pilots license

. First Defense Systems UAs will be us ed in lieu of comparatively haza r dou s operations n ow conducted with fi x ed wing and rotary co n ventional aircra ft which

s h ould r eassure the FAA tha t these operatio ns will achiev e at lea st an e qu i valent l ev el or greater level of safety. Further providing a beneficial and currently u navailable serv i ce to government organizations and the general public that will serve the pub l ic interest

. I t i s pos s ible to operate UAS' s so as not to pose a threat to national s e c urity or the public if done so

sa f ely and re s ponsibly

. Respect f ully 

# ~i~L~owner Fir s t Defens e systems LLC 1109 Pleasant Valley Rd We s t Bend WI. 53095 262-844 - 3818