Justin Leach

Eagle Eye Dynamics LLC 364 Hampton Park
Westerville, OH 43081
(614)315

- 2182 Justin@eagleeyedynamics.com

July 19, 2015

U.S Department of Transportation
Docket Management System

1200 New Jersey Ave., SE Washington, DC 20590

To whom it may Concern,

Re: Exemption Request per PL 112

- 95 under Section 333 and 14CFR 21 part H, 14CFR 61.3, 14CFR 61.113, 14CFR 91.119, 14CFR 91.121, 14CFR 91.151, 14CFR 91.405, 14CFR 91.407, 14CFR 91.409,

14CFR 91.417.

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 and 14 CFR 11, Eagle Eye Dynamics LLC, seeks exemption from Federal Aviation Regulations (FAR ’ s) detailed in the following paragraphs for the DJI inspire 1 and Sky Hero Little Spyder . The requested exemption would allow Eagle Eye Dynamics LLC DJI Inspire 1 and Sky Hero Little Spyder to conduct commercial and public service operations in the following sectors: aerial photography and videography, agriculture

surveys, con s tructio n surveys, real estate, insurance damage assessment, accident/incident documentation

and unmanned aircraft education and training. The employment of these unmanned platforms for these flights should provide the FAA with good cause to find that these opera tions enhance safety by eliminating the use of conventional aircraft that could pose a safety concern for the crew and those on the ground in different environments.

Eagle Eye Dynamics LLC wa s launched in 2015 as a small veteran owned business . Eagle Ey e Dynamics LLC has experience in civil and military aviation operations, security, intelligence and 10+

year ’ s operations with RC aircraft to include airplanes, helicopters and quad copters.

DJI Inspire 1 Sky Hero Little SpyderThe Aircraft

Eagle Eye Dynamics LLC will employ the use of unmanned “ quad

- copter s ” manufactured by DJI and Sky Hero . The unmann ed aircraft are electrically powered camera platform s using a combined GPS and Optical sensor system providing accurate and quick satellite /g round reference acquisition to ensure flight accuracy. Both aircraft have a failsafe system in which an autopilot system returns the aircraft to where it was launched from if a transmitter signal is lost or the battery voltage is to low; which enhances

th e overall safety and reliability of the aircraft. Both the GPS and failsafe capabilities aid in removing the human error aspect for unmanned aerial flight. The maintenance of the Inspire 1 and Sky Hero Little Spyder in regards to the inspections and maintenance are not as complicated to a manned aircraft . Eagle Eye Dynamics LLC will follow the recommended maintenance procedures and practices prescribed by

the manufacturer ’ s user manual to keep the unmanned aircraft airworthy

The Operator ’ s

The chief pilot and primary PIC has over 2500 hours total time in various rotary and fixed wing aircraft and is incident, accident and violation free. The primary PIC also holds a FAA commercial rotary wing with instrument privi leges, certified flight instructor and certified flight instructor

– instrument rotary wing; as well as an airplane single engine land private pilot license.

Eagle Eye Dynamics LLC will use remote camera operator (CO) personnel when /if necessary. The CO will adhere to PIC instructions in flight and will be trained in preflight, system assembly and disassembly

, aircraft fail safe practices, safe aerial operations and camera operations.

Operation of the unmanned aircraft

- Operations will be limited to 400 feet Above Ground Level (AGL) altitude

- The aircraft will weigh less than 55 pounds

- The aircraft will be restricted to 40 knots

- Operations will follow 14 CFR Part 91.155 weather minimums

- Operations will occur in Class G and E airspace on occasion

- Operation s will be conducted in Visual Flight Rules (VFR) only

- Operations will be conducted with in line of sight of the PIC and unmanned aircraft

- Operations will not occur closer than 1 statute mile to any operational airport.

- Proper preflight will be conducted by the PIC in accordance with the manufacturers user manual

- Verify all batteries are fully charged

- Verify all aircraft fail safes are functioning properly prior to flight

- PIC will ensure they are familiar with all information regarding to flight by checking weather, NOTAMS, obstructions in the flight area

- The UAS will never fly over a person and will remain 100 feet away from all persons

- When necessary, at least 72 hours prior to flight, the operator will file form 7711

- 1, or its equivalent to the appropriat e FISDO.

- When necessary, appropriate permission will be obtained from property owners.

- PIC will abort the flight if any unpredicted emergencies arise.

- All accidents and incidents will be reported in the aircraft log and reported in accordance the FAA

directives.Eagle Eye Dynamics LLC request exemption p ursuant to the Administrator ’ s authority to

grant exemptions contained in 49 USC 106(f), 40113, and 44701.

- 14CFR 21 part H

- 14CFR 61.3

- 14CFR 61.113

- 14CFR 91.119

- 14CFR 91.121

- 14CFR 91.151

- 14CFR 91.405

- 1 4CFR 91.407

- 14CFR 91.409

- 14CFR 91.417

14 CFR Part 21 subpart H

– Airworthiness Certificates

The unmanned aircraft operated by Eagle Eye Dynamics LLC will undergo a preflight inspection before every flight to ensure air worthiness. Anything that poses a hazard to flight or malfunction will be corrected prior to flight. The Inspire 1 and Sky Hero Little Spyder does not carry a pilot or passenger, carries no explosive materials or flammable liquid fuels and will operate within visual range line of sight of the operator

. All aspects of the Operations will be closely monitored by the PIC. Because of these

condit io ns unmanned aircraft operations provide a greater degree of safety to the public and property

owners then manned aircraft operating under airworthiness certificates under 14CFR part 21.

14 CFR 91.151 Fuel Requirements

The Inspire 1 and Sky Hero Little Spyder are powered by a battery which provides up to 20 minutes of safe flight time. The lack of flammable liquids provides a safe alternative to conventional aircraft and lower the overall risk. All Eagle Eye Dynamics LLC will discontinue flights when b attery levels reach 15% or 18 minutes of flight. Due to the fact that no petroleum fuels will be used and the flights will be less than 20 minutes, Eagle Eye Dynamics LLC requests an exemption from 14CFR

91.151.

14 CFR 91.405, 14CFR 91.407, 14CFR 91.409, 14CFR 91.417 Maintenance

Eagle Eye Dynamics LLC requests exemption from the above “ Maintenance ” CFR ’ s. Eagle Eye Dynamics LLC will perform all maintenance functions per the manufacturer specifications and the

owner ’ s manual. Eagle Eye Dynamics LLC will abide by all notices from the manufacturer regarding maintenance practices to include preventative ma intenance and alterations of the aircraft.

All Maintenance inspections will be conducted by Eagle Eye Dynamics LLC in accordance with the manufactures guidelines since there is no certified FAA inspection process. The Maintenance will be

conducted and documented prior to every flight to include a functional test flight after maintenance was performed.

14 CFR 21 part H, 14CFR 61.3, 14CFR 61.113 Flight Crew

All PIC ’ s will have to successfully complete a training program through Eagle Eye Dynamics

LLC. PIC ’ s will hold either a valid driver ’ s license or hold a FAA third class medical certificate. ThePIC is the sole person in charge of the aircraft from preflight to landing. The PIC will not transfer

operational control of the aircraft to any other pers on unless the flight is for training and not for hire. The Camera Operator will be required to have a valid driver ’ s license and also successfully complete Eagle Eye Dynamics LLC training program.

14 CFR 61.3 and 14 CFR 61.113 Training and Certification

Eagle Eye Dynamics LLC PIC ’ s will successfully complete the training program and operators

will hold a valid driver ’ s license or third class medical certificate. Eagle Eye Dynamics LLC training program was designed referencing the US Department of Interio r for training UAV pilots. This current curriculum is accepted by the FAA as valid training for initial UAS operators as a replacement for a pilot ’ s license. Eagle Eye Dynamics LLC training program is available upon request. PIC ’ s will have

accumulated and logged 5 hours of total time as a UAS pilot and demonstrated profi ciency in all modes of flight.

Summary

Eagle Eye Dynamics LLC intends to fully comply with every acceptable regulation to the operation of the Inspire 1 and the Sky Hero Little Spyder . Each of Eagle Eye Dynamics LLC ’ s request

are done so understanding that operations are able to be conducted at least as safe or safer than those commercial operations currently conducted by manned aerial operations.

Eagle Eye Dynamics LLC ’ s proposed ex emption and operational limitations are very closely aligned with other exemptions already granted and also with proposed FAR 91.107, which is specific to

micro unmanned aircraft.

I appreciate your assistance with helping me and Eagle Eye Dynamics LLC i n this process.

Please don ’ t hesitate to contact me via email at Justin@eagleeyedynamics.com if you have any questions.

Regards,

Justin Leach President and Chief Operator
Eagle Eye Dynamics LLC