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 Transportation 

Docket Operations 

1200 New Jersey Ave.SE 

West Building Ground Floor Room W12-140 

Washington DC 20590 

Re: Exemption Request Pursuant To Section 333 of the FAA Reform Act of 2012 

Dear Sir or Madam: 

I am writing pursuant 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 

Defense Systems LLC, owner and operator of a small UAS, and FAA Private Pilot (license 

#3776396) be exempted from the Federal Aviation Regulations (FAR's) listed below. 

The exemption is needed in order to operate a small lightweight unmanned aircraft system 

(UAS) commercially in airspace regulated by the Federal Aviation Administration (FAA). These 

operations will be conducted within and under the conditions outlined herein or as may be 

established by the FAA as required by Section 333.§11.81. 

First Defense Systems LLC's commercial use of the UAS will be restricted to crisis response 
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 powered 

electric 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 airspace 

system 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 permits 

exemption 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 such 

certificate 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 sight 

operations provide separation from other aircraft, obstructions, and terrain, providing 

an equivalent level of safety. 
14 C.F.R. 45.23; Marking of the Aircraft 

Applicable Codes of Federal Regulation require aircraft 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 because 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 prescribed 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 accordance to FAA regulations 

and manufacturers specifications. An equivalent level of safety will be provided by preflight 
In Summary, First Defense Systems LLC seeks an exception from the following Regulations: 

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. 91.109; 14 C.F.R. 

91.119; 14 C.F.R. 91.121; 14 C.F.R. 91.151 (a); 14 C.F.R. 91.203 (a) and (b); 14 

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) 

Summary 

In Summary First Defense Systems LLC requested exemption would authorize the use of DJI 

Phantom 3 and DJI Inspire 1 in commercial operations of aerial videography and photography, 

crisis 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 DJIInspire 1 UAs, will be operat ed under controlled 

conditions at an altitude of no greater than three hundred (400) feet AGL in airspace that is 

limited in scope and will have automated control features. First Defense Systems UAs will also 

be operated by an individual who has a current and valid third class medical and current and 

valid private pilots license. First Defense Systems UAs will be used in lieu of comparatively 

hazardous operations now conducted with fixed wing and rotary conventional aircraft which 

should reassure the FAA that these operations will achieve at least an equivalent level or 

greater level of safety. Further providing a beneficial and currently unavailable service to 

government organizations and the general public that will serve the public interest. It is 

possible to operate UAS's so as not to pose a threat to national security or the public if done so 

safely and responsibly. 

Respectfully