SHERIFF 

WALLY OLSON 

P. 0 . BOX 279 

DALE COUNTY · OZARK, ALABAMA 36361 

October 4, 2015 

U.S. Department of Transportation 

Docket Operations, M-30 

1200 New Jersey Avenue, SE 

Room W12-140, West Building Ground Floor 

Washington, DC 20590-0001 

TELEPHONES: 334-774-2335 

Fax: 334-774-2909 

E-mail: wolson @dalecountysheriff.com 

Re: Petition of Dale County Sheriff's Office for an Exemption Pursuant to Section 333 of 

the FAA Modernization and Reform Act of 2012 to operate an Unmanned Aircraft 

System 

Dear Sir or Madam: 

Pursuant to Section 333 of the FAA Modernization and Reform Act of2012 (the Reform Act) 

and 14 C.F .R. Part 11, Dale County Sheriffs Office hereby applies for an exemption from the 

Federal Aviation Regulations identified below to allow for the commercial operation of the 

INDAGO Vertical Take-off and Landing (VTOL) System which is manufactured by Lockheed 

Martin. 

I. REGULATIONS FOR WHICH EXEMPTION IS REQUESTED 

Dale County Sheriffs Office requests exemption from the following regulations: 

• 14 C.F.R Part 21, Subpart H; 

• 14 C.F.R Part 27; 

• 14 C.F.R § 45.23(b); 

• 14 C.F.R. § 45.27(a); 

• 14 C.F.R § 61.113; 

• 14 C.F.R § 91.7(a); 

• 14 C.F.R § 91.9(b)(2); 

• 14 C.F.R § 91.9(c); 

• 14 C.F.R § 91.103; 

• 14 C.F.R § 91.109(a); 

• 14 C.F.R § 91.119; 

• 14 C.F.R § 91.121; 

• 14 C.F.R § 91.151(a) & (b) 

• 14 C.F.R § 91.203 (a) & (b); 

• 14 C.F.R § 91.405(a); 

• 14 C.F.R § 91.407(a)(l); 

• 14 C.F.R § 91.409(a)(2); 

• 14 C.F.R § 91.417 (a) & (b) . 
II. STATUTORY AUTHORITY FOR REQUESTED EXEMPTIONS 

This petition for exemption is submitted in accordance with Section 333 of the Reform Act. 

Congress has directed the FAA "to safely accelerate the integration of civil unmanned aircraft 

systems into the national airspace system." Pursuant to Section 333 ofthe Reform Act, the FAA 

Administrator is to permit operation of an unmanned aircraft system where it does not create a 

hazard to users of the national airspace system (NAS) or the public or pose a threat to national 

security based on the following considerations: 

• The size, weight, speed and operational capability; 

• Operation in proximity to airports and populated areas; and 

• Operation within visual line of sight of the operator. 

Furthermore, the Federal Aviation Act grants the FAA Administrator general authority to grant 

exemptions from the agency's safety regulations and minimum standards when the 

Administrator decides a requested exemption is in the public interest. See 49 U.S.C. §§ 

1 06(f), 44701-44716, et seq. A party requesting an exemption must explain the reasons why the 

exemption: (1) would benefit the public as a whole, and (2) would not adversely affect safety or 

how it would provide a level of safety at least equal to the existing rules. 14 C.F .R. § 11.81. 

III. DESCRIPTION OF DALE COUNTY SHERIFF'S OFFICE AND ITS 

SERVICES 

Dale County Sheriff's Office is a located in rural area of Southeast Alabama. Dale County is 

approximately 561.15 square miles. Our agency operations consist of enforcement of all public 

laws, protection of the county's court system, drug enforcement, search and rescue etc. We 

operate our own law enforcement aviation unit which consists of three helicopters and one 

airplane. Our missions cover a wide range of operations from surveillance, search and rescue, 

firefighting, swat, and patrol. Our aviation unit also supports a program called Project Lifesaver 

which is a system that consists of a small transmitter that is worn by persons that have cognitive 

disorders such as Autism, Down syndrome, and Alzheimer's. 

Primary uses of the UAS will be Project Lifesaver search and rescue operation conducted by the 

Dale County Sheriff's Office. Other applications in the future will be tactical operations with 

SWAT such as hostage barricaded subject with weapons etc. 

The contact information for the petitioner, Dale County Sheriff's Office, is as follows: 

Tim McDonald 

Dale County Sheriff's Office 

Chief Deputy 

113 West Reynolds St. 

P.O. Box 279 

Ozark, AL 36360 

tmcdonald@daleso.com 

www.daleso.com 

www.projectlifesaver.org 

334-774-2335 or 334-379-9717 
IV. DESCRIPTION OF PROPOSED OPERATIONS 

Dale County Sheriffs Office is requesting exemptions from applicable Federal Aviation 

Regulations (FARs) pursuant to Section 333 ofthe Reform Act to perform aerial videography 

and photography for search and rescue operations. Additionally Dale County Sheriffs Office 

will train other public safety agencies that will in tum operate under public use rules. 

A. The Aircraft 

Dale County Sheriffs Office will operate INDAGO manufactured by Lockheed Martin. The 

INDAGO 's autopilot has a high degree of pre-programmed control and various built-in 

technical capabilities that strictly limit the potential for operation outside of the operating 

conditions set forth in the exemption application. Hands-on experience with the INDAGO are a 

far more effective guarantee of flight safety than a commercial pilot certificate would be, until 

the FAA UAS Pilot Certificate requirements catch up to the SUAS technology. 

The INDAGO's autopilot has an all-digital software platform with advanced features previously 

restricted to full size unmanned aircraft. Automated features and advanced fly-safe controls 

enable safe, reliable operation, as well as advanced networking capabilities and system 

extensibility. 

• The system will be flown in manual mode at all times. 

• Flight time and battery minutes are displayed at all times. The system will return home 

and land automatically if user-configurable limits are reached 

• Flight safety is a priority, no matter the operating environment or project. SUAS offer 

superior safety over manned aircraft by removing the need for people to be onboard in 

potentially dangerous situations. With multiple built-in safety features, SUAS platforms 

are comparable to manned operations with respect to safety 

• The INDAGO automatically detects potential issues- with configurable automated 

response behavior such as a return-home and automatic-landing routines 

• The INDAGO self-calibrates all of its sensors and performs required failsafe pre-flight 

tests prior to takeoff to check for errors 

• The INDAGO has the ability to automatically return to base in a loss of link situation so 

the aircraft can't fly horizontally or vertically beyond the pre-planned flight area 

• The INDAGO has battery minutes and flight time displayed at all times. The system will 

return home and land automatically ifuser-configurable limits are reached 

• The INDAGO auto-detects a loss of GPS, warns the pilot and initiates a landing based on 

user specified timelines 

--• Low battery on the INDAGG triggers a return to base for. landing-and-battery replacemen 

• If the INDAGO detects a loss-of-link with the Ground Control Station the vehicle will 

return to base and perform an automatic landing at the takeoff point or other user defined 

return home point 

Considering the programmability and safety features of this UAV, it serves as the best option to 

protect the Public and NAS for the purposes of this petition. 
Dale County Sheriffs Office is using a UA V that has the capability for taking off and landing at 

a single point, identical to a· helicopter. There are no runways, aided take off apparatuses, nor 

routes that need to be flown to areas being aerial video recorded or photographed. Allowing a 

reduced and more confined area of flight. 

The motors, rotors, propellers, body/frame, landing pads, etc. for the UAV utilized in this 

petition are not complicated. Engineering and design allows layman maintenance. Pre-flight 

inspections for cracks, damage or other physical conditions that could hamper safe flight will be 

conducted prior to any and all missions. Post flight inspections will also be conducted in order to 

aid in identifying flight conditions that may cause stress to propellers, landing gear, etc. 

Thorough inspection of the UAV shall be conducted and flight response tested should a hard 

landing or crash occur insuring that the U A V can operate in a safe manner before conducting any 

further missions. 

Like the Astraeus Petition Petitioner Dale County Sheriffs Office requests waiver or exemption 

for markings due to the small size of the fuselage for the INDAGO. 

Petitioner Dale County Sheriffs Office requests modification, waiver or exemption and 

clarification (within reason) concerning section 91.119 prohibition of flight in congested areas. 

Petitioner Dale County Sheriffs Office requests waiver for this condition to allow reasonable 

and responsible videography in congested areas of subdivisions and neighborhoods. 

In compliance with Section 90.151 (a) the INDAGO is a battery operated UA V IUAS with 

battery level monitoring capability. Fully charged battery flight time is rated at 50 minutes 

respectively, with videos/photos taking much less time to record. Operator or PIC is warned 

when battery level is low. 

Petitioner Dale County Sheriffs Office requests waiver/exemption from Section 91.203 (a) since 

the INDAGO is a commercial and military grade UA V IUAS that should not require an 

airworthiness certificate. Posting of special flight authorization would not be possible since the 

INDAGO has no cabin and are not large enough to carry a certificate. However, a special flight 

authorization can be maintained by the operator to make available upon request. 

B. Dale County Sheriff's Office Proposed Operations Demonstrate an Equivalent Level 

of Safety 

1. General Description of Proposed Flight Operations 

Dale County Sheriffs Office proposes to operate within the limitations and performance 

specifications listed in the user manuals which are summarized below. These limitations provide 

for at least an equivalent, or higher, level of safety for operations under the current regulatory 

structure because the proposed operations represent a safety enhancement to the protocols. 

The proposed operations do not create any hazard to users of the national airspace system or pose 

a threat to national security. The aircraft is a battery operated quadcopter with a maximum flight 

time of 50 minutes. The vehicle weighs approximately 5 pounds. The vehicle will be operated 

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between 2 and 35 miles per hour, and it will operate at or below 200 feet AGL unless a separate 

COA is submitted. 

Manned aircraft are at risk of fuel spillage and fire in the event of an incident or accident. The 

INDAGO carries no fuel, and therefore the risk of fire following an incident or accident due to 

fuel spillage is eliminated. Compared to manned aircraft, the unmanned aircraft being operated 

by the petitioner reduces the risk to participating persons in close proximity to the aircraft due to 

the limited size, weight, operating conditions, and design safety features of INDAGO. 

The FAA has determined that the risk of not having an electronic means to monitor and 

communicate with other aircraft, such as transponders or sense and avoid technology, is 

mitigated by placing limits on altitude, requiring stand-off distance from clouds, permitting 

daytime operations only, requiring that the aircraft be operated within visual line of sight, and 

requiring INDAGO yield right of way to all other manned operations. Additionally, the operator 

will request a NOT AM prior to operations to alert other users of the NAS. See Exemption No. 

11062, Docket No. FAA 2014-0352, at p. 13. 

The petitioner's aircraft has the capability to operate safely after experiencing certain in- flight 

failures. The aircraft is also able to respond to a lost-link event with a precoordinated, predictable, automated flight maneuver. 

2. Reasons why the exemption would not adversely affect safety or how the 

exemption would provide a level of safety at least equal to the existing rule. 

Given the small size involved, the restricted environment within which they will operate, the 

procedures listed below, and pilot certification requirements, Dale County Sheriffs Office 

proposed operations using the INDAGO would "not create a hazard to users of the national 

airspace system or the public or pose a threat to national security." Reform Act Section 333(b) 

(1). 

1. The aircraft will be identified by serial number, registered with the FAA, and 

have identification (N-Number) markings as large as practicable. 

2. Flights will be operated within visual line of sight of the pilot in command (PIC). 

3. Prior to each flight, a zero altitude initiation point will be established and 

confirmed for accuracy by PIC. 

4. Maximum flight time for each operational flight will be approximately 50 

minutes. 

5. The aircraft will be safely landed with no less than the greater of (a) 20% battery 

life remaining or (b) three minutes of flight time remaining. 

6. The aircraft will be operated during daylight and in VFR conditions. 

7. Flights will be operated at a lateral distance of at least 50 feet from any persons or 

property not associated with the operation who have not given prior permission. 

8. Flights will be limited to a groundspeed of 5-35 mph. 

9. Minimum crew for each flight will consist of a PIC and an Observer. 

10. The PIC will possess at least a private pilot certificate and a valid state driver's 

license. 
11. Have completed and received certification in an INDAGO training program. 

12. Have completed 10 hours (or 20 flights) of training on the SUAS and/or simulator 

before commencing commercial operations. 

13. Prior to the flight, a Mission Plan will be created setting forth the limitations for 

the flight as well as contact information for the PIC. 

14. The flight operations will yield the right of way to other manned aircraft 

operations. 

15. All persons who are not involved with flight operations will be required to stay 50 

feet from the edge of the flight operation perimeter. 

16. Dale County Sheriffs Office will provide NOT AM details to the FAA 24 hours 

prior to each flight. 

17. All required permissions and permits will be obtained from territory, state, county 

or city jurisdictions prior to flight. 

18. Prior to commencing operations, Dale County Sheriffs Office will obtain a 

Certificate of Waiver or Authorization (COA) from the FAA if flying above 200 

feet AGL. 

19. If the aircraft loses communications, it will have the capability to return to a predetermined location within the operational area and land. 

20. If the aircraft loses its GPS signal it will have the capability ofbeing flown 

manually to a predetermined location within the operational area and land. 

21. The flight will be aborted in case ofunpredicted obstacles or emergencies. 

22. Each flight will be recorded in an Operations Log Book. 

24. Maintenance on the aircraft will be recorded in a Maintenance Log Book. 

V. SPECIFIC FAR EXEMPTIONS REQUESTED 

Dale County Sheriffs Office seeks an exemption from several interrelated provisions of 14 

C.F .R. Parts 21, 45, 61, and 91 for purposes of conducting the requested operations using the 

INDAGO. Listed below are (1) the specific FAR sections for which exemption is sought, and (2) 

the operating procedures and safeguards that Dale County Sheriffs Office has established which 

will ensure a level of safety better than or equal to the rules from which exemption is 

sought. See 14 C.P.R. § 11.81 (e). 

A. 14 C.F.R. Part 21, Subpart H- Airworthiness Certificates and 14 C.F.R. 

§ 91.203(a)(1) 

The FAA has stated that no exemption is needed from this section if a finding is made under the 

Reform Act that the UAS selected provides an equivalent level of safety when compared to 

aircraft normally used for the same application. These criteria are met, and therefore no 

exemption is needed. See Grant of Exemption to Astraeus Aerial, Docket No. FAA 2014-

0352 at 13-14,22. If, however, the FAA determines that there are some characteristics ofthe 

INDAGO that fail to meet the requirements of the Reform Act, an exemption is requested. 

Equivalent Level of Safety: The INDAGO is safe when taking into account its size, weight, 

speed, and operational capability. The INDAGO weighs approximately 5 pounds will be flown at 

speeds of 5-35 miles per hour, and in visual line of sight ofthe operator. The INDAGO does not 

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carry pilots, passengers, explosive materials, or flammable liquid fuels. The INDAGO will be 

operated within the parameters of the User Manuals. 

Dale County Sheriffs Office will also provide the FAA with advance notice of all operations via 

a NOT AM and coordination with the local Flight Standards District Office (FSDO). The 

proposed operations will be at least as safe as, or safer than, conventional rotorcraft operating 

with an airworthiness certificate without the restrictions and conditions proposed here. 

B. 14 C.F.R. Part 27 Airworthiness Standards: Normal Category Rotorcraft 

14 C.F.R. Part 27 sets forth the procedural requirements for airworthiness certification of normal 

category rotorcraft. To the extent the INDAGO would otherwise require certification under Part 

27, Dale County Sheriffs Office seeks an exemption from Part 27's airworthiness standards for 

the same reasons identified in the request for exemption from 14 C.F .R. Part 21, Subpart H. 

C. 14 C.F.R. §§ 45.23(b), 45.27(a) and 91.9(c): Aircraft Marking and 

Identification Requirements 

14 C.F.R. §45.23(b), Markings of the Aircraft states: 

When marks include only the Roman capital letter "N" and the registration number is displayed 

on limited, restricted or light-sport category aircraft or experimental or provisionally certificated 

aircraft, the operator must also display on that aircraft near each entrance to the cabin, cockpit, or 

pilot station, in letters not less than 2 inches nor more than 6 inches high, the words "limited," 

"restricted," "light-sport, "experimental," or "provisional," as applicable. 

14 C.F.R. § 45.27(a) states: 

Rotorcraft. Each operator of a rotorcraft must display on that rotorcraft horizontally on both 

surfaces of the cabin, fuselage, boom, or tail the marks required by§ 45.23. 

14 C.F.R. § 91.9(c) states: 

No person may operate a U.S.-registered civil aircraft unless that aircraft is identified in 

accordance with part 45 of this chapter. 

In a previous Grant of Exemption, the FAA determined that exemption from these requirements 

was warranted provided that the aircraft "have identification (N-Number) markings in 

accordance with 14 CFR part 45, Subpart C if the markings are "as large as 

practicable." See Exemption No. 11062, Docket No. FAA 2014-0352, at p. 14. 

Equivalent Level of Safety: Dale County Sheriffs Office will mark all INDAGOs with their NNumber in a prominent spot on the fuselage with markings that are as large as practicable. 

D. 14 C.F.R. § 61.113: Private Pilot Privileges and Limitations 
Dale County Sheriffs Office seeks exemption from 14 CPR§ 61.113, which restricts private 

pilots from flying aircraft for compensation or hire and would also require a second class 

medical certificate. The purpose of Part 61 is to ensure that the skill and competency of any PIC 

matches the airspace in which the PIC will be operating, as well as requiring certifications if the 

pilot is carrying passengers or cargo for hire. 

While the INDAGO will be operated as part of a commercial operation, they carry neither 

passengers nor cargo. In the Grant of Exemption in FAA Docket No. FAA-2014-0352, the FAA 

determined that the unique characteristics ofUAS operation outside of controlled airspace did 

not warrant the additional cost and restrictions attendant with requiring the PIC to have a 

commercial pilot certificate and a class II medical certificate. The FAA has also determined that 

the required knowledge for a commercial pilot covers the same fundamental principles as a 

private pilot. 

The PIC will possess at least a private pilot certificate, a third class medical certificate, and will 

have completed a Basic Operator Course for the INDAGO. 

The FAA stated in its grant of an exception to Astraeus Aerial the "the FAA considers the 

overriding safety factor for the limited operations proposed by the petitioner to be the airmanship 

skills acquired through UAS-specific flight cycles, flight time, and specific make and model 

experience, culminating in verification through testing." See Exemption No. 11062, Docket No. 

FAA 2014-0352, at p. 18. The proposed operations can achieve an equivalent level of safety by 

requiring the knowledge and experience in INDAGO operations described above. 

The restrictions Dale County Sheriffs Office has placed on its INDAGO operations meet or 

exceed the restrictions similarly imposed on Astraeus Aerial in FAA Docket No. F AA-2014-

0352. Dale County Sheriffs Office will operate in restricted areas (the sites) away from persons 

and property not involved in the operation. The aircraft will be flown based on VLOS at or 

below 400 feet AGL, so as to accommodate flight operations on specified sites. A NOT AM will 

be issued at least 24 hours before the flight is to occur, and the flight will be coordinated with the 

applicable FSDO. 

E. 14 C.F.R. § 91.7(a): Civil Aircraft Ainvorthiness 

Dale County Sheriffs Office seeks an exemption from 14 C.P.R. § 91.7(a), which requires that a 

civil aircraft be in airworthy condition to be operated. The FAA has stated that no exemption is 

required to the extent that the requirements of Part 21 are waived or found inapplicable. 

Accordingly, Dale County Sheriffs Office requests that the requirements for Section 91.7 be 

treated in accordance with FAR Part 21 Subpart H. See Grant of Exemption No. 11062, p. 19. 

F. 14 C.F.R. § 91.9(b)(2): Civil Aircraft Flight Manual in the Aircraft; 

14 C.F.R. §§ 91.203(a) and (b): Carrying Civil Aircraft Certification and 

Registration 

Pursuant to 14 C.P.R. § 91.9(b)(2): 
(b)No person may operate a U.S.-registered civil aircraft-

(2)For which an Airplane or Rotorcraft Flight Manual is required by§ 21.5 of this 

chapter, unless there is available in the aircraft a current approved Airplane or 

Rotorcraft Flight Manual, approved manual material, markings, and placards, or 

any combination thereof. 

Pursuant to 14 C.F.R. § 91.203(a) and (b): 

(a)Except as provided in§ 91.715, no person may operate a civil aircraft unless it has 

within it the following: 

(1 )An appropriate and current airworthiness certificate. 

(b )No person may operate a civil aircraft unless the airworthiness certificate required by 

paragraph (a) of this section or a special flight authorization issued under§ 91.715 is 

displayed at the cabin or cockpit entrance so that it is legible to passengers or crew. 

Dale County Sheriffs Office does not request an exemption from this section but instead notifies 

the FAA that, in accordance with FAA Office of Chief Counsel's Opinion dated August 8, 2014, 

the U AS flight manual, registration certificate and other documentation will be kept at the 

control station with the PIC during flight. The Chief Counsel's Office has held that for all UAS 

operations, this alternate method constitutes full compliance with the regulations. See also Grant 

of Exemption No. 11062, pp. 19-20, and Grant of Exemption No. 8607. 

G. 14 C.F.R. § 91.103: Preflight Action 

Dale County Sheriffs Office seeks an exemption from 14 C.F.R. § 91.103, which requires a PIC 

to become familiar with specific information before each flight, including information contained 

in the FAA-approved Flight Manual on board the aircraft. The aircraft will not have a Flight 

Manual on board. The PIC will take all actions including reviewing weather, flight battery 

requirements, landing and takeoff distances and aircraft performance data before initiation of 

flight. Under these circumstances, the FAA has stated that no exemption is required. See Grant 

of Exemption No. 11062, p. 20. An exemption is requested to the extent that an FAAapproved Flight Manual is required. 

Equivalent Level of Safety: An equivalent level of safety will be provided by following the User 

Manuals. The PIC will take all required preflight actions - including performing all required 

checklists and reviewing weather, flight requirements, battery charge, landing and takeoff 

distance, aircraft performance data, and contingency landing areas - before initiation of flight. 

The User Manuals will be kept at the ground station; with the operator at all times. 
H. 14 C.F.R. § 91.109(a): Flight Instruction 

Dale County Sheriff's Office seeks an exemption from 14 C.P.R.§ 91.109(a), which provides 

that "[n]o 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." UASs and remotely 

piloted aircraft, by their design, do not have functional dual controls. Instead, flight control is 

accomplished through the use of the A2 Flight Control System/Ground Control Station (GCS) 

that communicates with the aircraft via radio communications. 

Equivalent Level of Safety: When flight instruction is performed, no pilots will be on the aircraft 

and the GCS will be a safe distance from the aircraft and the public, causing no safety hazard. 

Given the size and speed of INDAGO, an equivalent level of safe training can still be performed 

without dual controls because no pilot or passengers are aboard the aircraft, and all persons will 

be a safe distance away in the event that the aircraft experiences any difficulties during flight 

instruction. These flights will comply with the provisions in the User Manuals. Accordingly, 

Dale County Sheriff's Office proposed method of operation provides superior levels of safety. 

I. 14 C.F.R. § 91.119(c): Minimum Safe Altitudes in Uncongested Areas 

Dale County Sheriff's Office requests an exemption from the minimum safe altitude 

requirements of 14 C.F .R. § 91.119( c). Section 91.119( c) prescribes that an aircraft may not be 

operated closer than 500 feet to any person, vessel, vehicle, or structure. The FAA has already 

determined that relief from Section 91.119( c) is warranted for UAS operations in uncongested 

areas with similar flight restrictions as those imposed by Dale County Sheriff's Office. See Grant 

ofExemption No. 11062, p. 20-21. 

Equivalent Level of Safety: Compared to flight operations with rotorcraft weighing far more 

than the maximum weights proposed herein, and given the lack of flammable fuel, any risk 

associated with these operations is far less than those that presently exist with conventional 

aircraft. An equivalent level of safety will be achieved given the size, weight, and speed of the 

INDAGO, as well as the locations where it is operated. In order to avoid any risk to aircraft, 

flight operations will be restricted to 400 feet AGL or below. The INDAGO will be operated at 

sites, away from persons or structures not involved in the operation. All persons who are not 

involved with Dale County Sheriff's Office operations will be required to be at least 50 feet from 

the flight operation perimeter. 

J. 14 C.F.R. § 91.121: Altimeter Settings 

This petition seeks an exemption from 14 C.F .R. § 91.121, which requires a person operating an 

aircraft to maintain cruising altitude or flight level by reference to an altimeter that is set to the 

elevation of the departure airport. The INDAGO uses both barometric pressure sensors and GPS 

to determine altitude but do not have the ability to set in a current altimeter setting. An 

exemption is required to the extent that the INDAGO does not have a barometric altimeter 

setting. The altitude of the aircraft is monitored by the PIC on the ground control station and by 

the visual observer. 
Equivalent Level of Safety: The FAA has stated that an equivalent level of safety can be 

achieved if the aircraft will be operated at or below 400 feet AGL and within visual line-of-sight 

in addition to GPS based altitude information relayed in real time to the operator. See Grant of 

Exemption No. 11062, p. 20-21. As the attached User Manuals indicate, the INDAGO will be 

operated at or below 400 feet AGL and comply with the limitations in the Grant of Exemption 

No. 11062. 

K. 14 C.F.R. § 91.151(a): Fuel Requirements for Flight in VFR Conditions 

Dale County Sheriffs Office requests an exemption from 14 C.F.R. § 91.151(a)'s fuel 

requirements for flight in VFR conditions. Section 91.151 states: 

(a) No person may begin a flight in an airplane under VFR conditions unless 

(considering wind and forecast weather conditions) there is enough fuel to fly to the 

first point of intended landing and, assuming normal cruising speed -

(1) During the day, to fly after that for at least 30 minutes; or 

(2) At night, to fly after that for at least 45 minutes. 

Here, the technological limitations on INDAGO battery power means that no meaningful flight 

operations can be conducted while still maintaining a 30 minute reserve. The aircraft is battery 

powered with a maximum flight time of between 50 minutes. Dale County Sheriffs Office 

proposes that the maximum flight time for each operational flight will be 50 minutes. The 

aircraft will be safely landed with no less than the greater of(a) 20% battery life remaining or (b) 

three minutes of flight time remaining. 

Equivalent Level of Safety: The FAA has stated that an equivalent level of safety is provided if 

the UAS flight is conducted under daytime VFR flight conditions using VLOS, and terminated 

with at least 25% reserve battery power still available. See Grant of Exemption No. 11062, p. 21-

22. The User Manuals providing an equivalent level of safety by safely landing with no less than 

the greater of (a) 20% battery life remaining or (b) three minutes of flight time remaining and 

otherwise complying with the flight restrictions above. 

L. 14 C.F.R. §§ 91.405(a), 91.407(a)(l), 91.409(a)(2); 91.417(a) and 

(b): Maintenance Inspections 

Dale County Sheriffs Office seeks an exemption from the maintenance inspection requirements 

contained in 14 C.F.R. § 91.405(a), 91.407(a)(l), 91.409(a)(2); 91.417(a) and 

(b). These regulations specify maintenance and inspection standards in reference to 14 C.F.R. 

Part 43. See, e.g., 14 C.F.R. § 91.405(a) (stating that each owner or operator of an aircraft 

"[ s ]hall have the aircraft inspected as prescribed in subpart E of this part and shall between 

required inspections ... have discrepancies repaired as prescribed in part 43 of this chapter"). An 

exemption from these regulations is needed because Part 43 and these sections only apply to 

aircraft with an airworthiness certificate, which the INDAGO will not have. 
Equivalent Level of Safety: An equivalent level of safety will be achieved because maintenance 

and inspections will be performed in accordance with the Manuals. This includes maintenance, 

overhaul, replacement, and inspection requirements for the aircraft and procedures to document 

and maintain maintenance records for the aircraft. This also includes preflight inspection 

procedures. See Exemption No. 11062, Docket No. FAA 2014- 0352, at p. 14-15. 

As provided in the Manuals, flights will not be conducted unless a flight operations checklist is 

performed that includes all of the aircraft's components. The Manuals also set requirements for 

maintenance log books and record keeping as well as routine and post-flight maintenance. The 

Manuals set requirements for both annual maintenance and preventative maintenance. 

VI. PUBLIC INTEREST 

Granting Dale County Sheriffs Office petition for exemption furthers the public interest. 

National policy set by Congress favors early integration ofUAS into the NAS in controlled, safe 

working environments as proposed in this petition. By granting this petition, the FAA will fulfill 

Congress's intent of allowing UAS to operate safely in the NAS before completion of the 

rulemaking required under Section 333 of the Reform Act. 

Dale County Sheriffs Office will operate in a manner that will ensure the public's safety and 

will set the example for others to emulate. It is well established that UAS provide an additional 

tool for the public benefit, adding a greater degree of flexibility, which supplements the current 

capabilities offered by manned aircraft. 

VII. PRIVACY 

All flights will be conducted in accordance with any federal, state or local laws regarding 

privacy. All flights will occur over private or controlled access property with the property 

owner's prior consent and knowledge. Images or video taken of individuals will have consented 

to being filmed or otherwise they will be made anonymous. 

VIII. NATIONAL SECURITY 

Given the small size ofthe UAS involved and the restricted environment within which they will 

operate, our petition presents no national security issue. Furthermore, the security screening 

conducted by the Transportation Security Administration of certificated airmen satisfies the 

statutory requirement of Section 333 for operations to not pose a threat to national St:l:urity. 

IX. SUMMARY FOR FEDERAL REGISTER 

Pursuant to 14 C.F.R. Part 11, the following summary is provided for publication in the Federal 

Register, should it be determined that publication is needed: 

Dale County Sheriffs Office seeks an exemption from the following rules in order to provide 

aerial imaging, photography, videography and cinematography: 14 C.F.R Part 21, Subpart H; 14 

C.F.R Part 27; 14 C.F.R § 45.23(b); 14 C.F.R. § 45.27(a); 14 C.F.R § 61.113; 14 C.F.R § 
91.7(a); 14 C.F.R § 91.9(b)(2); 14 C.F.R § 91.9(c); 14 C.F.R § 91.103; 14 C.F.R § 91.109(a); 14 

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

C.F.R § 91.405(a); 14 C.F.R § 91.407(a)(l); 14 C.F.R § 91.409(a)(2); 14 C.F.R § 91.417 (a) & 

(b). 

Operation of the INDAGO may substantially reduce the risk to life and property by performing 

missions that are currently being performed by manned aircraft that are considered dangerous 

such as transmission tower inspections, firefighting or operating in extreme terrain or weather 

conditions. The INDAGO provides an efficient and quickly deployable solution to provide 

Emergency Responders with increased situational awareness and minimizes risk to the 

emergency response personnel and the public at large. 

The exemption will enhance safety by reducing risk to the operator, the general public and 

property owners from the hazards associated with operating UAS through deliberate planning, 

risk mitigation, and flight operations. 

X. CONCLUSION 

Satisfaction of the criteria provided in Section 333 of the Reform Act- size, weight, speed, 

operating capabilities, proximity to airports and populated areas, operation within visual line of 

sight, and national security considerations - provides more than adequate justification for the 

grant of the requested exemptions to permit Dale County Sheriffs Office to operate the 

INDAGO. 

Granting the requested exemption will benefit the public interest as a whole in many ways, 

including (1) significantly improving safety and reducing risk by alleviating human exposure to 

danger; (2) improving the quality of services Dale County Sheriffs Office can provide to its 

citizen's; and (3) decreasing the risks of unmanned aircraft interfering with manned aircraft. 

Respectfully submitted, 

By: /s/ Tim McDonald 

Chief Deputy 

Dale County Sheriffs Office