### E agle Digital Imaging, Inc

April 30 , 2015

U.S. Department of Transportation Docket Management System 1200 New Jersey Avenue SE Washington , D. C . 20590

Re: Exemption Request Section 333 of the FAA Reform Act and Part 11 of the Federal Aviation Reg ulations from 14 CFR § 91.7(a), 91.119(c), 91.121, 91.151(a)(1), 91.405(a), 91.407(a)(1), 91.409(a)(1) and (2), and 91.417(a) and (b) to the extent necessary to allow Eagle Digital Imaging, Inc to operate a UAS for the purpose of performing aerial data

col lection.



### Dear Sir or Madam:

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (Reform Act) and 14 CFR Part 11, Eagle Digital Imaging, Inc (EDI) hereby applies for an exemption from the listed Federal Aviation Regulations (FARs) to allow commercial operation of its Unmanned A ircraft Systems (UASs), 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. Introduction

EDI is a remot e sensing and analysis company that has safely operated manned aircraft profitably for over a decade providing a broad range of aerial data collection services.

EDI offers high quality imagery acquisition and analysis services to customers in the forestry

, precision agriculture, natural resource and mining industries. EDI is staffed by commercially rated pilots

, professional engineers and scientists and has an unblemished record operating manned aircraft used in airborne data acquisition. EDI is submitti ng this petition for exemption in order to improve safety in certain of its acquisition

environments and add to the public welfare by adding on

- demand commercial operations using UASs to its existing and future suite of business services . These services i nclude:

 Stockpile volume measurements

 Power line tower and insulator inspections

 Agricultural crop scouting and precision agriculture

 Forest stand based management

As described more fully below, the requested exemption would permit the operation of

smal l, unmanned UAS under controlled conditions in airspace that is 1) limited 2) predetermined 3) controlled as to access and 4) would provide safety enhancements to the already safe operations EDI conducts using conventional aircraft.

### Approval of this exemp tion 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.” Section 333(c) of the R eform Act.”

The name and address of the petitioner is:

Eagle Digital Imaging, Inc

Attn: David J. Shear, President

435 NW 5 th 

### Street, Suite B Corvallis Oregon 97330

Ph: 541 754 9310

d avid.shear@eagleimaging.net

The specific regulations from which the exemption is being requested are :

14 CFR § 91.7(a) 14 CFR § 91.119(c) 14 CFR § 91.121

1 4 CFR § 91.151(a) (1) 14 CFR § 91.405(a) 14 CFR § 91.407(a) (1) 14 CFR § 91.409(a) (1) and (2) 14 CFR § 91.417(a) and (b)



### 2. Aircraft and Equivalent Level of Safety

The petitioner proposes that the exemption submitted apply to civil aircraft that have the characteristics and that operate within the conditions and limitations listed below

. These limitations provide for at least an equivalent or higher level of safety in operations under

the current rules. Furthermore, these limitations are similar in all material respects to relief requested by other petitioners’ previously granted exempti ons and EDI accepts and agrees to abide by those limitations.

EDI plans to use the DJI

- S900 Hexacopter, ( Futaba 14SG )

, a small, light weight roto

copter UAS platform for use in aerial data collection

. The aircraft is controlled remotely, weighs approxi mately 20lbs (maximum w/ payload) and has the ability to hover and move vertically and horizontally. The conditions and limitations to which EDI will operate the UAS when conducting commercial operations under an FAA exemption are identical to previously g ranted exemptions’ limitations and include:

1. Operations authorized by this grant of exemption are limited to the following aircraft described in the operating documents which is a DJI

- S900 Hexacopter weighing less than 55pounds, including any payload . Proposed operations of any other aircraft will require a new

petition or a petition to amend this exemption.

2. Operations for the purpose of closed

- set motion picture and television filming are not permitted.

3. The UA may not be operated at a speed exceeding 87 knots (100 miles per hour). The exemption holder may use either groundspeed or calibrated airspeed to determine compliance with the 87 knot speed restriction. In no case will the UA be operated at airspeeds greater than the maximum UA operati ng airspeed recommended by the aircraft manufacturer.

4. The UA must be operated at an altitude of no more than 400 feet above ground level (AGL). Altitude must be reported in feet AGL.

5. The UA must be operated within visual line of sight (VLOS) of t he PIC at all times. This requires the PIC to be able to use human vision unaided by any device other than corrective lenses, as specified on the PIC’s FAA

- issued airman medical certificate or U.S. driver’s

license.

6. All operations must utilize a visua l observer (VO). The UA must be operated within the visual line of sight (VLOS) of the PIC and VO at all times. The VO may be used to satisfy the VLOS requirement as long as the PIC always maintains VLOS capability. The VO and

PIC must be able to communica te verbally at all times; electronic messaging or texting is not permitted during flight operations. The PIC must be designated before the flight and cannot transfer his or her designation for the duration of the flight. The PIC must ensure that the VO

can perform the duties required of the VO.

7. This exemption and all documents needed to operate the UAS and conduct its operations in accordance with the conditions and limitations stated in this grant of exemption, are hereinafter referred to as the opera ting documents. The operating documents must be accessible during UAS operations and made available to the Administrator upon request. If a discrepancy exists between the conditions and limitations in this exemption and the procedures outlined in the opera ting documents, the conditions and limitations herein take precedence and must be followed. Otherwise, the operator must follow the procedures as outlined in its operating documents. The operator may update or revise its operating documents. It is the oper ator’s responsibility to track such revisions and present updated and revised documents to the Administrator or any law enforcement official upon request. The operator must also present updated and revised documents if it petitions for extension

or amendm ent to this grant of exemption. If the operator determines that any update or revision would affect the basis upon which the FAA granted this exemption, then the operator must petition for an amendment to its grant of exemption. The FAA’s UAS Integration O ffice (AFS

- 80) may be contacted if questions arise regarding updates or revisions to the operating documents.

8. Any UAS that has undergone maintenance or alterations that affect the UAS operation or flight characteristics, e.g. replacement of a flight c ritical component, must undergo a functional test flight prior to conducting further operations under this exemption. Functional test flights may only be conducted by a PIC with a VO and must remain at least 500 feetfrom other people. The functional test flight must be conducted in such a manner so as to not

pose an undue hazard to persons and property.

9. The operator is responsible for maintaining and inspecting the UAS to ensure that it is in a condition for safe operation.

10. Prior to each flight, the PIC must conduct a pre

- flight inspection and determine the UAS is in a condition for safe flight. The pre

- flight inspection must account for all potential discrepancies, e.g. inoperable components, items, or equipment. If the inspection reveals a

cond ition that affects the safe operation of the UAS, the aircraft is prohibited from operating until the necessary maintenance has been performed and the UAS is found to be in a condition for safe flight.

11. The operator must follow the UAS manufacturer’s maintenance, overhaul, replacement, inspection, and life limit requirements for the aircraft and aircraft components.

12. Each UAS operated under this exemption must comply with all manufacturer safety

bulletins.

13. Under this grant of exemption, a PI C must hold either an airline transport, commercial, private, recreational, or sport pilot certificate. The PIC must also hold a current FAA airman medical certificate or a valid U.S. driver’s license issued by a state, the District of Columbia,

Puerto Ric o, a territory, a possession, or the Federal government. The PIC must also meet the flight review requirements specified in 14 CFR § 61.56 in an aircraft in which the PIC is rated on his or her pilot certificate.



### 14. The operator may not permit any PIC t o operate unless the PIC demonstrates the ability to safely operate the UAS in a manner consistent with how the UAS will be operated under this exemption, including evasive and emergency maneuvers and maintaining appropriate distances from persons, vessels , vehicles and structures. PIC qualification flight hours and currency must be logged in a manner consistent with 14 CFR § 61.51(b). Flights for the purposes of training the operator’s PICs and VOs (training, proficiency, and experience

- building) and deter mining the PIC’s ability to safely operate the UAS in a manner consistent with how the UAS will be operated under this exemption are permitted under the terms of this exemption. However, training operations may only be conducted during dedicated training s essions. During training, proficiency, and experience

- building flights, all persons not essential for flight operations are considered nonparticipants, and the PIC must operate the UA with appropriate distance from nonparticipants in accordance with 14 CFR § 91.119.

15. UAS operations may not be conducted during night, as defined in 14 CFR § 1.1. All operations must be conducted under visual meteorological conditions (VMC). Flights under special visual flight rules (SVFR) are not authorized.

16. The UA may 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

aer onautical chart, unless a letter of agreement with that airport’s management is obtained orotherwise permitted by a COA issued to the exemption holder. The letter of agreement with

the airport management must be made available to the Administrator or any law enforcement official upon request.

17. The UA may 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.

18. If the UAS loses communications or loses its GPS signal, the UA must return to a pre

determined location within the private or controlled

- access property.

19. The PIC must abort the flight in the event of unpredicted obstacles or emergencies.

20. The PIC is prohibited from beginning 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.

21. Air Traffic Organization (ATO) Certificate of Waiver or Authorization (COA). All operations shall be conducted in accordance with an ATO

- issued COA. The exemption holder may apply for a new or amended COA if it intends to conduct operations that can not
be conducted under the terms of the attached COA.

22. All aircraft operated in accordance with this exemption must be identified by serial number, registered in accordance with 14 CFR part 47, and have identification (N

- Number) markings in accordance with 14 CFR part 45, Subpart C. Markings must be as large as 

### practicable.

23. 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 must be available to the

PIC at th e Ground Control Station of the UAS any time the aircraft is operating. These documents must be made available to the Administrator or any law enforcement official

upon request.

24. The UA must remain clear and give way to all manned aviation operations and

activities at all times

.

25. The UAS may not be operated by the PIC from any moving device or vehicle.

26. All Flight operations must be conducted at least 500 feet from all nonparticipating persons, vessels, vehicles, and structures unless:

a. B arriers or structures are present that sufficiently protect nonparticipating persons from the UA and/or debris in the event of an accident. The operator must ensure that nonparticipating persons remain under such protection. If a situation arises where

non participating persons leave such protection and are within 500 feet of the UA, flight operations must cease immediately in a manner ensuring the safety of nonparticipating persons’ andb. The owner/controller of any vessels, vehicles or structures has gr anted permission for operating closer to those objects and the PIC has made a safety assessment of the risk of operating closer to those objects and determined that it does not present an

undue hazard.

The PIC, VO, operator trainees or essential persons are not considered nonparticipating persons under this exemption.

27. All operations shall be conducted over private or controlled

- access property with permission from the property owner/controller or authorized representative. Permission from

property o wner/controller or authorized representative will be obtained for each flight to be

conducted.

28. Any incident, accident, or flight operation that transgresses the lateral or vertical boundaries of the operational area as defined by the applicable COA m ust be reported to the FAA's UAS Integration Office (AFS

- 80) within 24 hours. Accidents must be reported to the National Transportation Safety Board (NTSB) per instructions contained on the NTSB Web site: www.ntsb.gov.

If this exemption permits operation s for the purpose of closed

- set motion picture and television filming and production, the following additional conditions and limitations apply.

29. The operator must have a motion picture and television operations manual (MPTOM) as documented in this gr ant of exemption.

30. At least 3 days before aerial filming, the operator of the UAS affected by this exemption must submit a written Plan of Activities to the local Flight Standards District Office (FSDO) with jurisdiction over the area of proposed film ing. The 3

- day notification may be waived with the concurrence of the FSDO. The plan of activities must include at least the following:

a. Dates and times for all flights;

b. Name and phone number of the operator for the UAS aerial filming conducted

un der 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 filming production event; the list of those who gave permission must be made available to the inspector upon request;

g. Signature of e xemption holder or representative; andh. 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.

31. F light operations may be conducted closer than 500 feet from participating persons consenting to be involved and necessary for the filming production, as specified in the exemption holder’s MPTOM. Unless otherwise specified in this grant of exemption, the UAS, the UAS PIC, and the UAS operations must comply with all applicable parts of 14 CFR including, but not limited to, parts 45, 47, 61, and 91.



### 3. Regulations from Which Exemption is Requested

EDI respectfully requests exemption f rom the following FARs as listed in the table

below :

FAR S ection Subject Justification
14 CFR § 91.7(a) Airworthiness
requirements Prior to each flight the PIC will conduct a pre

- flight inspection

and determine the UAS is in a condition for safe flight. 14 CFR § 91. 119( c) Minimum altitudes for safe flight People will not be allowed over, under or within 500 feet laterally of the UAS in flight.. 14 CFR § 91.121 Altimeter settings An onboard sensor s and software resolve agl altitudes sufficiently to insure safe flight.

14 CFR § 91.151(a)(1) On board fuel requirements Battery voltage is displayed on the PIC’s controller during flight. Procedures to land

before battery minimums are reached will be in place. 14 CFR § 91.405 (a) Aircraft Inspection
requirements EDI will document all inspection and maintenance

activities and maintain those

records for FAA review as

necessary. 14 CFR § 91.407(a) (1) Inspection approval
requirements Procedures for the PIC to test and approve return to service will be in place. 14 CFR § 91.409 (a) (1) & (2) Airworthiness inspection The PIC will accept responsibility for airworthiness inspections. 14 CFR § 91.417 (a) & (b) Maintenance records
requirements EDI will maintain UAS

maintenance records and

maintain those record s for FAA review as necessary.

### 4. Privacy

All UAS operations will be only be conducted on and above private property with controlled access and only with permission of the property owner.

5. Request

EDI respectfully requests that the FAA grant an exemption for the FARs listed in the table above. EDI has been conducting safe aerial data collection operations using manned aircraft since 2005 and will operate with equal diligence and attention to safety under the limitations set forth by the FAA for its UAS operations. EDI is not currently using UASs and seeks these exemptions to be allowed to operate UASs legally in the pursuit of expand ing business opportunities and in order to remain competitive as these new technologies evolve.

6. Exemption o ut side the United States

Eagle Digital Imaging Inc is not requesting permission to exercise th e privileges of this exemption outside the United States.

7

. Summary for Publication in the Federal Register

The following summary is provided to the FAA fo r pu blication in the Federal Register:

Eagle Digital Imaging Inc is petitioning the FAA for exemption from the following

rules : 14 CFR § 91.7(a), 91.119(c), 91.121, 91.151(a)(1), 91.405(a), 91.407(a)(1), 91.409(a)(1) and (2), and 91.417(a) and (b) 

### to operat e a UAS for use in aerial data collection including stockpile volume measurements, power line tower and insulator inspections, agricultural crop scouting and precision agriculture and forest stand based management . These and other applications will be con ducted under the

conditions and limitations established by the FAA as per the granted exemption.

8 . Exhibits

The DJI S900 User Manual “Spreading Wings S900 User Manual , V12 ” can be found at the following link:

http://www.dji.com/product/spreading

- wings

- s900/spec