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, construction 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 operations 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 was launched in 2015 as a small veteran owned business. Eagle Eye 

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 Spyder
The Aircraft

Eagle Eye Dynamics LLC will employ the use of unmanned “quad-copters” manufactured by DJI

and Sky Hero. The unmanned aircraft are electrically powered camera platforms using a combined GPS 

and Optical sensor system providing accurate and quick satellite/ground 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 

the 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 privileges, 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

- Operations 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 appropriate 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 pursuant 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

- 14CFR 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 

conditions 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 battery 

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 maintenance 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. The 
PIC 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 person 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 Interior 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 proficiency 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 exemption 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 in 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