January 19, 2016 

U.S. Dept. ofTransportation, Docket Operations 

West Building Ground Floor, Room w12-140 

1200 New Jersey Avenue, SE., 

Washington, DC 20590 

Submitted Electronically via the Federal Docket Management System (FDMS) 

Re: Exemption Request under Section 333 of the FAA Reform Act and Part 11 of the Federal 

Aviation Regulations 

Dear Sir or Madam 

On behalf of Sacramento Municipal Utility District (SMUDL and Pursuant to Section 333 of the FAA 

Modernization and Reform Act of 2012 and 14 C.F.R. Part 11, I Michael Greenhalgh, Project Manager II, 

am seeking an exemption from Part 21 Subpart H; and Sections 91.203 (a) (1), 45.23 (b), 91.7 (a), 91.9, 

61.113, 61.133, 91.109, 91.119, 91.121, 91.151, and (91.401- 91.417} Subpart E, ofTitle 14, Code of 

Federal Regulations (14 CFR). This proposed exemption would allow for the operation of the DJI 

Phantom 2 Vision and Phantom 2 Vision Plus as our Unmanned Aircraft System's (UAS) 

• DJI Phantom 2 Vision 

• DJI Phantom 2 Vision Plus 

THE UNMANNED AIRCRAFT (UAS): 

• The UAS are lightweight (under 551b. gross weight), battery operated multi-rotor copter that 

takes off and land vertically and has the ability to hover in one location during flight. 

THE UAS INCLUDES: 

• An on-board flight computer with GPS navigation and location ability that receives signals for 

flight control from a ground-based transmitter/controller. 

• An on-board camera or sensor package used to document physical and/or environmental 

conditions of structures and the natural environment. 

• An on-board telemetry system that delivers flight data from the on-board flight computer to the 

radio transmitter including altitude AGL, horizontal and vertical speed, compass direction of 

flight and direction back to its launch site. 

• A 2.4GHz on-board radio transmitter that transmits live video from the on-board camera plus all 

the flight data from the telemetry system described above. 

SMUD · SECTION 333 EXEMPTION REQUEST Page 1 of 4 
THE GROUND STATION PART OF THE SYSTEM: 

• A Pilot in Command {PIC) in operational control of a mission from beginning to end, and who 

controls the UAS while in the air. 

• A 2.4GHz radio transmitter/controller operated by the PIC to control the UAS while in flight. 

• Ground Station (computer, tablet or smart phone based app) which receives and displays video 

and system telemetry real time from the UAS. 

• A Visual Observer (VO), a person who provides a second pair of eyes to visually track the UAS 

while in flight. 

PILOT IN COMMAND (PIC) AND VISUAL OBSERVER (VO): 

The PIC and VO will meet the requirements outlined in FAA Policy N 8900.227 Section 16 Personnel 

Qualifications. Additionally, the PIC and VO will perform maintenance on the system and will complete a 

course of maintenance instruction as part of their initial training. 

I submit that the combination of the UAS light weight, flight performance and ability, fully qualified flight 

crew and strict operation under the guidelines established in 8900.227, and under all of the Restrictions 

listed above, the FAA can have full confidence that the operation will have an equivalent or greater level 

of safety than manned aircraft performing the same mission. 

INTENDED USE/ PUBLIC GOOD: 14 CFR § 11.81{d) 

The requested exemption would allow us to use the UAS for aerial image acquisition to support various 

mapping and surveying applications as well as video documentation for our customers. Typical 

applications would include, but are not limited to: 

• Aerial Photography 

• Aerial Mapping 

• Utility Inspections 

• Infrastructure Inspections 

• Wetland Monitoring 

• Volumetric Calculations 

• Emergency Response 

• Education 

The inherent ability of the UAS to capture imagery from a low altitude including oblique photos and 

video from several angles is far more effective than ground-based imagery for displaying the 

characteristics of our assets: buildings, properties, and utility corridors where consistent monitoring is 

needed to maintain our right of way. Further, UAS can access locations not accessible to conventional 

aircraft due to their own flight restrictions and/or inability to mobilize in a timely manner. The applicant 

produces maps from aerial imagery that support infrastructure assessment, utility inspections, 

development projects and construction site safety inspections. These images, maps and other products 

produced from UAS are used to ensure our infrastructure can meet and support the demands of our 

customers in the Greater Sacramento area including Sacramento County and smaller adjoining portions 

of Yolo and Placer counties. 

SMUD- SECTION 333 EXEMPTION REQUEST F-'age 2 of 4 
PUBLIC SAFETY: 

UAS are powered by batteries, they are smaller, lighter and more maneuverable than larger aircraft 

running on combustible fuel; they operate at lower altitudes {under 400') with no people on board 

thereby reducing current risk levels and enhancing public safety. Wit h a small payload and maximum 

flight time of approximately 20 minutes. UAS offer little or no risk to national security due to their size, 

payload capacity and flight duration. 

DJI models have their own built in failsafe functionality which will cause the UAS to return to its take-off 

location and land before the battery becomes empty, or the system loses communication. In addition, 

DJI uses geo fencing technology to restrict flight operations where the FAA has mandated no fly zones 

such as: Airports, National Parks, and Stadiums. 

SUMMARY GRANT REQUEST: 

This request follows many others using similar systems and process that have been granted previously. I 

am requesting the FAA issue a summary grant of exemption as this request would not set a precedent. 

• The reasons stated by the FAA for granting Exemption Nos. 13996, 13207, 13004, 12557, 12369, 

12366 and 12026 also apply to this request. 

• A grant of exemption would be in the public interest (See above). 

THE REGULATIONS FROM WHICH THE EXEMPTIONS ARE BEING REQUESTED 

Beside each regulation number is the page of the attached Addendum upon which each may be found 

together with a proposed equivalent level of safety for each regulation: 

- 14 CFR Part 21 Subpart H Addendum Page 1 

- 14 CFR 91.203 (a) (1) Addendum Page 1 

- 14 CFR 45.23 (b) Addendum Page 1 

- 14 CFR 91.7 (a) Addendum Page 2 

- 14 CFR 91.9 Addendum Page 2 

- 14 CFR 61.113, 61.133 Addendum Page 2 

- 14 CFR 91.109, 91.119, 91.121 Addendum Page 3 

- 14 CFR 91.151 Addendum Page 3 

- 14 CFR Subpart E (91.401- 91.417) Addendum Page 4 

- FAA Policy 8900.227 Paragraph 16(c)(4) and Paragraph 16(e)(1) Addendum Page 4 

SMUD- SECTION 333 EXEMPTION REQUEST Page 3 of 4 
I am prepared to modify or amend any part of this request to satisfy the need for an equivalent level of 

safety. Please contact me at any time if you require additional information or clarification. I am the 

primary point of contact for this request and look forward to working with your office. 

Sincerely, 

_/ 2;, ~ .!"': - (:;, . // V:/ ~ .. 

v ·/· ~ael Greenhalgh 

Project Manager II 

SMUD 

4401 Bradshaw Road 

Sacramento CA, 95827 

Plhone: 916-732-6768 

Email: michael.greenhalgh@smud.org 

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Addendum Containing Exemption Requests and Equivalent Level of Safety 

Appendix A- Flight Operations/Procedures 

Appendix B-User's Manuals 

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