1 Atif R. Aleemi DBA Dulles One Consultants, LLC 44329 Lord Fairfax Place Ashburn, VA 20147 Phone: 703-798-7918 Email: Atif.Aleemi@yahoo.com

May 8, 2015

U.S. Department of Transportation Docket Management System 1200 New Jersey Ave., SE Washington DC 20590

Re: Atif R. Aleemi DBA Dulles One Consultants, LLC Exemption Petition Pursuant to Section 333 of the FAA Reform Act

Dear Sir or Madam:

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the “Reform Act”) and 14 CFR Part 11, Atif R. Aleemi DBA Dulles One Consultants, LLC (DON) , hereafter referred to as the “petitioner”, operator of Small Unmanned aircraft Systems (“sUAS”), hereby applies for an exemption from the listed Federal Aviation Regulations (“FARs”) to allow commercial operation of sUAS, 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.

The proposed exemption, if granted, would allow the petitioner to conduct commercial operations of sUAS meeting or exceeding operational and safety requirements Congress has set forth in Section 333. 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 National Airspac e System (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 and 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 met. 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. 91.7 (a) 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) & (b) 14 C.F.R. 91.215 14 C.F.R. 91.405 14 C.F.R. 91.407 14 C.F.R. 91.4092 14 C.F.R. 91.417 14 C.F.R. 91.109

This petition for exemption would allow DON to operate sUAS to conduct aerial photography and/or video, inspections, training, and closed-set filming. We intend to operate the DJI Phantom 3 and 3D Robotics SOLO to perform these activities. We are proposing two sUAS, with similar form and characteristics, to avoid burdening the FAA for a separate exemption or amendment at a later time. This will also provide our proposed commercial operations with flexibility and enhance safety as we can match the sUAS to the specific task.

Both sUAS are commercially produced by their respective companies, with long history of actively supporting their machines as well as extensive commitment to safe operations. The proposed sUAS have built in safety features utilizing GPS and failsafe functions. Our sUAS are multi-rotor craft weighing no more than 55lbs. including payload. Under normal conditions they operate at speeds of no more than 50kts and have the ability to hover and move along a vertical and horizontal plane simultaneously. They will operate in line of sight and will operate within a closed off and predetermined area owned and/operated by the property representative.

As described fully below, the requested exemption would permit the operation of sUAS that are a) limited, b) controlled, c) predetermined, and d) will provide safety enhancements to the already safe operations in the industry presently using conventional aircraft. Approval of this exemption would thereby enhance safety and fulfill the Secretary of Transportation’s (the FAA Administrator’s) responsibilities to “....establish requirements for the safe operation of such aircraft systems in the national airspace system.”

The pilot in command (PIC), Atif R. Aleemi DBA Dulles One Consultants, LLC (DON), holds a Private Pilot Certificate originally issued 11/24/1987 (reissued on 4/4/2015 to replace social security number as the certificate number) with a third-class medical certificate recently issued on 4/4/2015. With a high commitment to safety and compliance, the PIC has recently completed several courses via the FAA Safety Team Aviation Learning Center including covering rotary aircrafts. Also the PIC has been engaged with the Radio Control (RC) hobby since 1980, with significant experience in operating fixed wing and rotary RC crafts.

Specifically, our commercial activities would include:

1. Aerial photography and/or video for public and/or private use including real estate, architecture, land surveying, engineering and other related professional activities.

2. Aerial video and/or photography for public and/or private use including television, public events, cinematography and news gathering.

3. Aerial video and/or photography for closed-set filming.

4. Aerial inspection/photography of residential/commercial structures under contract with the owners or local government authority.3 5. Aerial video/photography or providing live video feed to assist with search and rescue operations in cases of an emergency or natural disaster only when the local authorities or government has requested it by contract or donation.

6. The ability to offer training to persons individually or belonging to both private and/or public organizations that have interests in the use and application of sUAS for the purpose of the safe operation of sUAS to enhance the safety of the NAS as well as for the protection of the persons and property.

The remainder of this petition follows the FAA’s Public Guidance for Petitions for Exemption Filed under Section 333, Rev. 9/25/2014 :

1. Information Regarding the Unmanned Aircraft System – Page 3 2. Information Regarding the Unmanned Aircraft PIC – Page 11 3. Information Regarding the Operation of the Unmanned Aircraft – Page 12 4. Discussion of Requested Regulation Exemptions – Page 15



### 1. Information Regarding the Unmanned Aircraft System

The sUAS subject of this petition are: (1) Phantom 3 manufactured and supported by DJI. (2) SOLO manufactured and supported by 3D Robotics. We are proposing two sUAS, with similar form and characteristics, to avoid burdening the FAA for a separate exemption or amendment at a later time. This will also provide our proposed commercial operations with flexibility and enhance safety as we can match the sUAS to the specific task.

Both crafts include safety features and their respective companies are committed safety. DJI enforces no-fly zones in compliance with guidance from the FAA. For example, Phantom 3 does not operate within 5 miles of large airports. It also enforces altitude limits of 400 feet, as does the SOLO. Both UASs provide automated features enhance safety such as auto-takeoff, auto-return to home, and failsafe. The description of these features for Phantom 3 includes:

Auto-Takeoff: With one tap in the DJI Pilot app, Phantom 3 will turn on its motors and rise to a pre-set height. It will then hover perfectly in place until you direct it where to go.

Auto-Return Home: When GPS is available, Phantom 3 remembers the exact spot that it took off from. Wherever your aircraft is flying, tap a button to have it return right back home.

Failsafe: If the Intelligent Flight Battery is running low, or if your Phantom 3 loses the connection with your remote controller for any reason, the aircraft will automatically return to the takeoff point and land safely.

The description of the safety features for 3D Robotics SOLO includes:

One-Button Flying: Take off, land, and return home automatically.

Pause: If release controls for a moment or wish to capture a static shot, simply press the "Pause" button for the Solo to hold in a fixed hover. When ready, just press "Pause" again to resume flying.4 Safety Net: This flying mode limits the range and altitude the Solo can fly. Typically, the maximum flight ceiling is restricted to less than 400 feet and the aircraft is limited to flying within a user-specified radius

The PIC will employ all safety features, while being fully in command of the sUAS. The PIC and VO will be an integral team and employ this checklist to ensure safety of operations:

Flight-Planning 1. Survey the area subject to sUAS operation

2. Review any potential hazards and plan mitigations with Visual Observer (VO)

3. Seek any necessary authorizations from property owners

4. Review compliance with Grant of Exemption, Conditions and Limitations

5. Conduct a briefing regarding the planned UAS operations

Pre-Flight 6. Inspect the sUAS for any lose parts or wires

7. Remote controller charged fully (confirm level on remote)

8. Aircraft battery charged fully (confirm level on remote)

9. Mobile device charged fully (confirm level on device)

10. Propellers are mounted correctly and firmly

11. Micro-SD card has been inserted if necessary

12. Gimbal is functioning as normal

13. Announce “clear” before starting the motors

14. Motors can start and are functioning as normal

15. Pilot app connected to the aircraft

During-Flight 16. PIC to follow the light plan

17. VO to review monitor flight and environment

Post-Flight 18. Turn-off and disconnect all power

19. Remove propellers5 20. Log sUAS operations

21. Communicate completion of operations as necessary

22. Remove equipment from field

As both the Phantom 3 and SOLO are produced for the U.S. consumer market, these devices comply with FCC rules and regulations. Specific frequency and features information is included in the manufacturer’s tables provided in this section, while other detailed product information is provided as separate documents. 

# DJI Phantom 3 Specifications

Aircraft WEIGHT (INCLUDING BATTERY AND PROPELLERS)

1280 g DIAGONAL SIZE (INCLUDING PROPELLERS)

590 mm MAX ASCENT SPEED

5 m/s MAX DESCENT SPEED

3 m/s HOVER ACCURACY

 Vertical: +/- 10cm

 Horizontal: +/- 1m

MAX SPEED

16 m/s (ATTI mode, no wind) MAX ALTITUDE ABOVE SEA LEVEL

6000 m OPERATING TEMPERATURE

0°C to 40°C GPS MODE

GPS/GLONASS 

### Camera SENSOR

Sony EXMOR 1/2.3” Effective pixels: 12.4 M (total pixels: 12.76 M)6 LENS

FOV 94° 20 mm (35 mm format equivalent) f/2.8, focus at ∞ ISO RANGE

100-3200 (video) 100-1600 (photo) SHUTTER SPEED

8s -1/8000s IMAGE MAX SIZE

4000 x 3000 STILL PHOTOGRAPHY MODES

 Single Shot

 Burst Shooting: 3/5/7 shots

 Auto Exposure Bracketing (AEB): 3/5

 Bracketed Frames at 0.7EV Bias

 Time-lapse

VIDEO RECORDING MODES

Phantom 3 Professional

 UHD: 4096x2160p 24/25, 3840x2160p 24/25/30

 FHD: 1920x1080p 24/25/30/48/50/60

 HD: 1280x720p 24/25/30/48/50/60

Phantom 3 Advanced

 FHD: 1920x1080p 24/25/30/48/50/60

 HD: 1280x720p 24/25/30/48/50/60

SUPPORTED SD CARD TYPES

Micro SD Max capacity: 64 GB. Class 10 or UHS-1 rating required MAX BITRATE OF VIDEO STORAGE

60 Mbps SUPPORTED FILE FORMATS

 FAT32/exFAT7  Photo: JPEG, DNG

 Video: MP4, MOV (MPEG-4 AVC/H.264)

OPERATING TEMPERATURE

0°C to 40°C 

### Gimbal CONTROLLABLE RANGE

Pitch -90° to +30° STABILIZATION

3-axis (pitch, roll, yaw) 

### Vision Positioning MAX VELOCITY

Less than 8 m/s (when 2 m above ground) ALTITUDE RANGE

30 cm-300 cm OPERATING RANGE

30 cm-300 cm OPERATING ENVIRONMENT

Surface with clear pattern and adequate lighting (Lux > 15) 

### Remote Controller OPERATING FREQUENCY

2.400 GHz-2.483 GHz MAX DISTANCE

2000m (outdoors and unobstructed) VIDEO OUTPUT PORT

USB OPERATING TEMPERATURE

0°C- 40°C BATTERY

6000 mAh LiPo 2S MOBILE DEVICE HOLDER

For tablet or phone RECEIVER SENSITIVITY (1%PER)

-101 dBm ±2 dBm TRANSMITTER POWER (EIRP)8  FCC: 20 dBm

 CE: 16 dBm

WORKING VOLTAGE

1.2 A @7.4 V 

### Battery Charger VOLTAGE

17.4 V RATED POWER

Phantom 3 Professional

 100 W

Phantom 3 Advanced

 57 W



### Intelligent Flight Battery CAPACITY

4480 mAh VOLTAGE

15.2 V BATTERY TYPE

LiPo 4S ENERGY

68 Wh NET WEIGHT

365 g MAX FLIGHT TIME

Approximately 23 minutes OPERATING TEMPERATURE

-10°C to 40°C MAX CHARGING POWER

100 W 

### App / Live View MOBILE APP9 DJI Pilot EIRP

100mW LIVE VIEW WORKING FREQUENCY

2.4GHz ISM LIVE VIEW QUALITY

720P @ 30fps (depending on conditions and mobile device) LATENCY

220ms (depending on conditions and mobile device) REQUIRED OPERATING SYSTEMS

 iOS 8.0 or later

 Android 4.1.2 or later

RECOMMENDED DEVICES

 iOS: iPhone 5s, iPhone 6, iPhone 6 Plus, iPad Air, iPad Air Wi-Fi +
Cellular, iPad mini 2, iPad mini 2 Wi-Fi + Cellular, iPad Air 2, iPad Air 2 Wi-Fi + Cellular, iPad mini 3, and iPad mini 3 Wi-Fi + Cellular. This app is optimized for iPhone 5s, iPhone 6, and iPhone 6 Plus

 Android: Samsung S5, Note 3, Sony Xperia Z3, Google Nexus 7 II, Google Nexus 9, Mi 3, Nubia Z7 mini

 *Support for additional Android devices available as testing and development continues



# 3D Robotics SOLO Specifications

Performance

Maximum Speed 55 mph / 88.5 km/h

Maximum Altitude 400' / 121.9 m AGL

Flight Time Up to 25 minutes (20 with camera and Solo Gimbal)



### Flight Control System10 Model Pixhawk 2

Software APM flight control software

GPS Yes



### Handheld Transmitter

Frequency Remote 2.400 GHz-2.483 GHz MAX DISTANCE

Display Color Screen for menu and live flight telemetry

Battery Chemistry: Lithium-polymer Capacity: 5200 mAh Voltage: 14.8 VDC Life: Up to 4 hours



### Mobile App

System Requirements Wi-Fi enabled iOS or Android mobile device

Wi-Fi Range Up to 2640' / 805 m (depending on environment)



### FPV and Monitoring

Video Downlink Latency: 180 ms

Connectivity 1 x HDMI output on Transmitter



### Components

Rotors 4 x 10 x 4.5" / 25.4 x 11.4 cm self-tightening props

Motors Velocity Constant: 880 kV

Gimbal Compatibility Solo Gimbal for HERO3+ and HERO4 (gimbal and camera available separately)



### Flight Battery

Model Solo Battery11 Chemistry Lithium-polymer

Capacity 5200 mAh

Voltage 14.8 VDC



### General

Running Lights Customizable color LEDs to assist orientation

Dimensions Not specified by manufacturer

Weight Unladen: 3.3 lb / 1.5 kg With Solo Gimbal and GoPro: 4 lb / 1.8 kg


### Shipping Info

Shipping Weight 8.4 lb

Box Dimensions (WxHxD) 0.0 x 0.0 x 0.0



### 2. Information Regarding the Unmanned Aircraft PIC

The pilot in command (PIC), Mr. Atif R. Aleemi DBA Dulles One Consultants LLC, holds a Private Pilot Certificate (No. 3799100) issued 11/24/1987 (reissued on 4/4/2015 to replace social security number as the certificate numbe r). As required, PIC has a third-class medical certificate recently issued on 4/4/2015 by Avia tion Medical Examiner (AME) James Koch, MD.

With a high commitment to safety and compliance, the PIC has recently completed several courses via the FAA Safety Team Aviation Learning Center including covering rotary aircrafts. Also the PIC has been engaged with the Radio Control (RC) hobby since 1980, with over 200 hours experience in operating fixed wing and rotary RC crafts.

We will utilize a visual observer (VO) in all operations covered by this requested exemption. The VO will be trained for the following responsibilities:

• Before each operations, check to ensure compliance with all “conditions and limitations” as provided in the Grant of Exemption letter. • After PIC establishes the area of operations, validate and identify any additional potential hazards that must be mitigated. • Review compliance with the pre-flight checklist, while the PIC performs the pre-flight check12 • While PIC is operating the sUAS, VO will deal with any distractions such as onlookers or curious bystanders • sUAS operations will only commence when both the PIC and VO agree to proceed



### 3. Information Regarding the Oper ation of the Unmanned Aircraft

The UAS operations covered by this petition include the following:

1. Aerial photography and/or video for public and/or private use including real estate, architecture, land surveying, engineering and other related professional activities.

2. Aerial video and/or photography for public and/or private use including television, public events, cinematography and news gathering.

3. Aerial video and/or photography for closed-set filming.

4. Aerial inspection/photography of residential/commercial structures under contract with the owners or local government authority.

5. Aerial video/photography or providing live video feed to assist with search and rescue operations in cases of an emergency or natural disaster only when the local authorities or government has requested it by contract or donation.

6. The ability to offer training to persons individually or belonging to both private and/or public organizations that have interests in the use and application of sUAS for the purpose of the safe operation of sUAS to enhance the safety of the NAS as well as for the protection of the persons and property.

The operation limitations proposed by the petitioner as set forth in the Flight Operations Manual (FOM) include:

1. UASs will weigh less than 55 pounds including payload. 2. UASs will operate under the maximum airspeed recommended by the manufacturer, and in will not exceeding 87 knots (100 miles per hour). 3. Maximum flight time for each operational flight will be 30 minutes. Flights will be terminated at 25% battery power reserve or 30 minutes of flight time whichever occurs first. 4. The UA will be operated at an altitude of no more than 400 feet above ground level (AGL). 5. The UA will operate within visual line of sight (VLOS) of the PIC at all times. 6. All operations will utilize a visual observer (VO). The UA will operate within the visual line of sight (VLOS) of the PIC and VO at all times. 7. The VO and PIC will be able to communicate verbally at all times; electronic messaging or texting is not permitted during flight operations. 8. The PIC will be designated before the flight and cannot transfer his or her designation for the duration of the flight. 9. The PIC will ensure that the VO can perform the duties required of the VO.13 10. Operating documents including Grant of Exemption will be accessible during UAS operations and made available to the authorities upon request. 11. The operator will maintain documents and track changes as necessary, and present to authorities for inspections as required. 12. Any UAS that has undergone maintenance or alterations that affect the UAS operation or flight characteristics, e.g. replacement of a flight critical component, will undergo a functional test flight prior to conducting further operations under this exemption. 13. Functional test flights will be conducted by a PIC with a VO and must remain at least 500 feet from other people, and pose no undue hazard to persons and property. 14. The operator will maintain and inspect the UAS to ensure that it is in a condition for safe operation. 15. Prior to each flight, the PIC will conduct a pre-flight inspection and determine the UAS is in a condition for safe flight. The pre-flight inspection will account for all potential discrepancies, e.g. inoperable components, items, or equipment. 16. If the inspection reveals a condition that affects the safe operation of the UAS, the aircraft will not be operated until the necessary maintenance has been performed and the UAS is found to be in a condition for safe flight. 17. The operator will follow the UAS manufacturer’s maintenance, overhaul, replacement, inspection, and life limit requirements for the aircraft and aircraft components. 18. The UAS receiving Grant of Exemption will comp ly with all manufacturer safety bulletins. 19. The designated PIC will hold either an airline transport, commercial, private, recreational, or sport pilot certificate. The PIC will hold a current FAA airman medical certificate or a valid U.S. driver’s license. 20. The operator wil not permit any PIC to operate unless the PIC demonstrates the ability to safely operate the UAS in a manner consistent with how the UAS will be operated under the granted exemption, including evasiv e and emergency maneuvers and maintaining appropriate distances from persons, vessels, vehicles and structures. 21. PIC qualification flight hours and currency will be logged in a manner consistent with 14 CFR § 61.51(b). 22. During training, proficiency, and experience-building flights, all persons not essential for flight operations are considered nonparticipants, and the PIC will operate the UA with appropriate distance from nonparticipants in accordance with 14 CFR § 91.119. 23. UAS operations may not be conducted during night, as defined in 14 CFR § 1.1. All operations will be conducted under visual meteorological conditions (VMC). 24. The UA wil not operate within 5 nautical miles of an airport reference point (ARP) as denoted in the current FAA Airport/Facility Directory (AFD) or for airports not denoted with an ARP, the center of the airport symbol as denoted on the current FAA-published aeronautical chart, unless a letter of agreem ent with that airport’s management is obtained or otherwise permitted by a COA issued to the exemption holder. The letter of agreement with the airport management will be made available to the Administrator or any law enforcement official upon request. 25. The UA will not be operated less than 500 feet below or less than 2,000 feet horizontally from a cloud or when visibility is less than 3 statute miles from the PIC.1426. If the UAS loses communications or loses its GPS signal, the UA will return to a predetermined location within the private or controlled-access property. 27. The PIC will abort the flight in the event of unpredicted obstacles or emergencies. 28. The PIC will not begin a flight unless (considering wind and forecast weather conditions) there is enough available power for the UA to conduct the intended operation and to operate after that for at least five minutes or with the reserve power recommended by the manufacturer if greater. 29. Documents used by the operator to ensure the safe operation and flight of the UAS and any documents required under 14 CFR §§ 91.9 and 91.203 will be available to the PIC at the Ground Control Station of the UAS any time the aircraft is operating. 30. The UA will remain clear and give way to all manned aviation operations and activities at all times. 31. The UAS will not be operated by the PIC from any moving device or vehicle. 32. All Flight operations will be conducted at least 500 feet from all nonparticipating persons, vessels, vehicles, and structures unless. 33. All operations will be conducted over private or controlled-access property with permission from the property owner/controller or authorized representative. Permission from property owner/controller or authorized representative will be obtained for each flight to be conducted. 34. For the purpose of closed-set motion picture and television filming and production, the operator will implement a motion picture and television operations manual (MPTOM) 35. At least 3 days before aerial filming, will submit a written Plan of Activities to the local Flight Standards District Office (FSDO) with jurisdiction over the area of proposed filming, including the following:

a. Dates and times for all flights; b. Name and phone number of the operator for the UAS aerial filming conducted under this grant of exemption; c. Name and phone number of the person responsible for the on-scene operation of the UAS; d. Make, model, and serial or N-Number of UAS to be used; e. Name and certificate number of UAS PICs involved in the aerial filming; f. A statement that the operator has obtained permission from property owners and/or local officials to conduct the film ing production event; the list of those who gave permission must be made available to the inspector upon request; g. Signature of exemption holder or representative; and h. A description of the flight activity, including maps or diagrams of any area, city, town, county, and/or state over which filming will be conducted and the altitudes essential to accomplish the operation.

36. Flight operations will be conducted closer than 500 feet from participating persons only if they consent to be involved and necessary for the filming production as specified in the MPTOM.

BETTERMENT OF OUR COMMUNITY: Our UAS are powered by batteries, smaller, lighter and more maneuverable than larger aircraft running on combustible fuel, it operates at lower15 altitudes with no people on board and will thereby reduce current risk levels associated with traditional aircraft, enhance safety and diminish the likelihood of death or serious bodily injury. Also with a small payload and typical flight time of only 20 minutes, there is little or no risk to national security. Low level photos and video are far more effective than ground or high altitude manned aircraft imagery for displaying detailed characteristics of ground based objects. The applicant in the past has chartered full-sized helicopters for this purpose, which has proven more costly than many potential clients have been able to afford. The benefits of reduced cost and improved quality of presentation from the UAS will be incredibly valuable to future clients. Aerial sightseeing will be conducted safely over coastal Massachusetts water ways and underpopulated areas. This new form of tourism will allow all individuals including children, elderly and disabled to enjoy the feeling of flig ht and see the area from above without the noise, danger and cost associated with traditional helicopters. Additionally, we will make our sUAS available to first responders in our community who might require assistance, including fire fighters, police, sheriff, et al., while remaining subject to all limitations cited in this application.



### 4. Discussion of Requested Regulation Exemptions

The petitioner requests an exemption from the following regulations as well as any additional regulations that may technically apply to the operation of the sUAS System.

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 experimental certificate be issued for our UAS’s under either or both 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, new 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 type 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 such as market surveys, sales demonstrations, and cust omer crew training, we would expect that an experimental certificate would permit our commerc ial purpose as well. The aircraft will not carry persons or property, will not carry fuel, and will only fly under strict operational requirements. Combined with the UAS lightweight, being constructed primarily of carbon fiber and plastic in conjunction with the ability to utilize emergency parachute systems. We propose that the UAS will be at least as safe, if not safer, than a conventionally certificated aircraft performing the same 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 an airworthiness certificate in general, citing the equiva lent level of safety outlined in the previous paragraph.

14 CFR 45.23 Display of marks; general and 45.29 Size of marks: These 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 the cabin, cockpit, or pilot station. The sUAS does not have an entrance in which the word "EXPERIMENTAL" can16 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 incl uding the word "EXPERIMENTAL" in the placard on the top of the aircraft, as shown above, 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. Additionally, we feel that the permanent placard discussed in the previous paragraph will provide the aircraft's registration information at the ground station. Finally, we will display at the ground station a high contrast flag or banner that contains the words "Unmanned Aircraft Ground Station" in letters 3 inches high or greater. Since the aircraft will operate within 3/4 NM of the ground station, the banner should be visible to anyone that observes the aircraft and chooses to investigate its point of origin.

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.

91.119 Minimum safe altitudes : The regulation states that over sparsely populated areas the aircraft cannot be operated closer than 500 feet to any person, vessel, vehicle, or structure. Since the typical mission of the sUAS would be photography or survey of persons, vessels, vehicles or structures it would be necessary to operate closer than 500 feet to the items listed. Operations will only be flown over property or persons where careful pre-planned flight path has been performed. In the event of a system malfunction or emergency landing with or without a deployed parachute. The hazard to persons or property on the surface will be very limited. Therefore we maintain that due to the small size of the UAS, the hazard to persons, v ehicles and structures is minimal compared to manned aircraft, which should be considered in granting the exemption.

CFR 91.121 Altimeter settings : The regulation requires that aircraft shall maintain cruising altitudes by reference to an altimeter setting available within 100 NM of the aircraft. The sUAS will always fly below 400 feet AGL and will not need to maintain cruising altitudes in order to prevent conflict with other aircraft. An Above Ground Level altimeter measurement above the takeoff point is transmitted via radio from the sUAS on-board computer to the display screen held by the PIC, providing a constantly updated AGL readout. The flight controller can be configured to geo-fence the UAS under the 400 feet maximum altitude.

14 CFR 91.151 Fuel requirements for flight in VFR conditions : The regulation provides that no person may begin a flight in an airplane under day-VFR conditions unless there is enough fuel to fly to the first point of intended landing and to fly after that for at least 30 minutes. The purpose of this is to provide an energy reserve as a safety buffer for delays to landing. Since the aircraft will never fly more than 3/4 NM from the point of intended landing, a full battery charge at launch will ensure that we meet the reserve energy requirement of this paragraph.

14 CFR 91.203(a) & (b) Civil aircraft: Certifications required : The regulation provides that an airworthiness certificate, with the registration number assigned to the aircraft and a registration certificate must be aboard the aircraft. Additionally, subparagraph (b) provides that the airworthiness ce rtificate be "displayed at the cabin or cockpit entrance so that it is legible to passengers or crew." At a maximum gross weight of 55 pounds, the sUAS is too small to carry documentation, does not have an entrance, and is not capable of carrying passengers or crew. To obtain an equivalent level of safety and meet the intent of17 91.203, we propose that documents deemed appropriate for this aircraft by the FAA will be with the crew at the ground control station and available for inspection upon request. In order to identify the aircraft, we propose that the information found on airworthiness and registration certificates be permanently affixed to the aircraft via placard containing the following information plus the word "EXPERIMENTAL" to satisfy the requirement of 14 CFR 45.23.

14 CFR Subpart E (91.401- 91.417) -Maintenance, Preventive Maintenance, Alterations: The regulation provides that the operator is primarily responsible for maintaining the aircraft in an airworthy condition, including compliance with part 39 and 43. Paragraphs 91.407 and 91.409 require that the aircraft be "approved for return to service by a person authorized under 43.7" after maintenance and inspection. It is our intention that the PIC perform maintenance and inspection of the aircraft and "be authorized to approve the aircraft for return to service." The PIC will ensure that the aircraft is in an airworthy condition prior to every flight and in addition conduct detailed inspections after every five hours of flight. All maintenance will be performed by the PIC in accordance with the manufactures manual. If required maintenance is beyond the ability of the PIC the maintenance will be performed by the manufacturer or their designated repair facility. The PIC will document work performed in accordance with 91.417. We feel that due to the size, construction, and simplicity of the aircraft, the PIC can ensure an equivalent level of safety.

14 CFR 91.109 Flight Instruction; Simulated instrument flight and certain flight tests: Section 91.103 provides that 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. sUAS and remotely piloted aircraft, by their design do not have fully functional dual controls. Flight control is accomplished through the use of a control box that communicates with the aircraft via radio communications. The FAA has approved exemptions for flight training without fully functional dual controls for a number of aircraft and for flight instruction in experimental aircraft. The equivalent level of safety provided by the fact that neither a pilot nor passengers will be carried in the aircraft and by the size and speed of the aircraft.

14 C.F.R. 91.215 ATC transponder and altitude reporting equipment and use: This regulation states all aircraft operating within 30 nautical miles of class A, B and C airspace must be equipped with automatic pressure altitude reporting equipment having a Mode C capability that automatically replies to Mode C interrogations. Due to the small size and lifting capabilities of our UASs we cannot carry a traditional transponder. All of our operations will under 250 feet if we are operating within the 30mi reach of a mode c vail.

In conclusion, by granting the requested exempt ions, the FAA will help drive development of safe and successful commercial UAS operations and will advance the public knowledge base for such operations of UAS. We are committed to promoting the UAS research efforts of policymakers by sharing data from its commercial UAS operations and serving as a resource for future UAS research operations.

As described above, all the sUASs which our co mpany would use, under authorization by theUS DOT-FAA, are small, light-weight devices operated within the line of sight of the Pilot-inCommand (PIC), less than 400 feet above the ground and outside 5 miles from any airport or18 location with aviation activities, unless the air tr affic control authorities (ATC) have been notified and have authorized each flight within a radius of this distance.

We are seeking an exemption pursuant to 14 C.F.R. and Section 333 of the FAA Modernization and Reform Act of 2012 (FMRA), which will permit safe operation of our UAS commercially, without an airworthiness Certificate. By granting this Petition, the FAA Administrator will be fulfilling the Congressional mandate of the FAA Modernization and Reform Act of 2012, while also advancing the interests of the public, by allowing DON to safely, efficiently, and economically operate sUASs commercially within the NAS. Wherefore, in accordance with the Federal Aviation Regulations and the FAA Modernization and Reform Act of 2012, Section 333, we respectfully requests that the Administrator grant this Petition for an exemption from the requirements of 14 C.F.R Sections.

Sincerely,

/s/ Atif R. Aleemi General Partner Dulles One Consultants, LLC Phone: 703-798-7918 Email: Atif.Aleemi@yahoo.com