January 19, 2016 U.S. Dept. ofTransportation, Docket Operations West Building Ground Floor, Room w12-140 1200 NewJersey Avenue, SE., Washington, DC 20590 Submitted Electronically via the Federal Docket Management System (FDMS) Re: Exemption Request under Section 333 ofthe FAA Reform Act and Part 11 ofthe Federal Aviation Regulations Dear Sir or Madam On behalfofSacramento Municipal Utility District (SMUDL and Pursuant to Section 333 ofthe FAA Modernization and Reform Act of2012 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 ofthe 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 offand 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 ofstructures 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.

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### THE GROUND STATION PART OF THE SYSTEM:
• A Pilot in Command {PIC) in operational control of a mission from beginning to end, and who cont rols the UAS while in the air. • A 2.4GHz radio transmitter/controller operated bythe 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 oftheir initial training. I submit that the combination ofthe UAS light weight, flight performance and ability, fully qualified flight crew and strict operation under the guidelines established in 8900.227, and under all ofthe Restrictions listed above, the FAA can have full confidence that the operation will have an equivalent or greater level ofsafety 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 ofYolo and Placer counties.

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### 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 fl ight 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 ofexemption 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 ofexemption would be in the public interest (See above). 

### THE REGULATIONS FROM WHICH THE EXEMPTIONS ARE BEING REQUESTED Beside each regulation number is the page ofthe attached Addendum upon which each may be found together with a proposed eq uivalent level ofsafety for each regulation:

- 14CFR Part 21 Subpart H Addendum Page 1

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

- 14CFR 45.23 (b) Addendum Page 1

- 14CFR 91.7 (a) Addendum Page 2

- 14CFR 91.9 Addendum Page 2

- 14CFR 61.113, 61.133 Addendum Page 2

- 14 CFR 91.109, 91.119, 91.121 Addendum Page 3

- 14CFR 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

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### 4I am prepared to modify or amend any part ofthis request to satisfy the need fo r an equ ivalent level of safety. Please contact me at any time if you require additional information or clarification. I am the primary point ofcontact for this request and look forward to working with youroffice. Sincerely,



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# v · /·**~ae l**  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 ofSafety Append ix A- F light Operations/Procedures Appendix B-User's Manuals

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