11768 Atwood Rd, Suite 20 January 24, 2015 Auburn, CA 95603 Tel: (530) 823-6546 U.S. Department of Transportation Docket Management System 1200 New Jersey Ave, SE Washington, DC 20590
Re: Exemption Request Under Section 333 of the FAA Re form Act and Part 11 of the Federal Aviation Regulations Dear Sir or Madam : Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the Reform Act) and 14 CFR Part 11, Precision Design & Drafting, Inc. (“PDND”) a professional civil engineering firm hereby applies for an exemption from the listed Federal Aviation Regulations ("FARs") to allow commercial operation of its 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

. As described more fully below, the requested exemption would support an application for a commercial Certificate of Authorization and permit the operat ion of small, unmanned and relatively inexpensive UAS under controlled conditions in airspace including:
1. Tower structural inspections to existing tower structures – These operations would take place with express written permission from the owner of the property for the purpose of obtaining detailed structural information. These operations would be conducted in airspace previously reviewed by the FAA for the initial construction of the tower and therefore the airspace of the controlled area would create no additional hazard to the NAS. 2. Precision Photogrammetry and Mapping – These operations would take place with express written permission from the owner of the property for the purpose of obtaining detailed terrain and topographic imagery of land features. These operations would be conducted in airspace no more than 400’ AGL and the UAS will remain within Visual Line of Sight of the Pilot in Command at all times. 3. Aerial Imagery of Commercial and Residential Properties – These operations would take place with express written permission from the owner of the property for the purpose of obtaining quality aerial photos of real estate. These operations would be conducted in airspace no more than 400’ AGL and the UAS will remain within Visual Line of Sight of the Pilot in Command at all times. PDND will operate the following drones:
1. DJI Phantom Vision 2+ 2. DJI Phantom Vision 3 3. DJI Phantom Inspire 1 

# Precision Design Draftin g , Inc

. & &We can insure that the combination of the UASs lightweight, historically demonstrated flight performance, on board GPS system, fully qualified fl ight personnel, and strict operation under the guidelines established, the FAA can have confidence that PDND’s operation will have an equivalent or greater level of safety of manned aircraft performing the same missions. Also, given the small size of the UAS’s involved and the restricted controlled environment within which they will operate , the applicant fits within that zone of safety (an equivalent level of safety) in which Congress envisioned that the FAA must, by exemption , allow commercial operations of UASs to commence immediately. Also due to the size of the UASs and the controlled areas i n which the relevant UASs will operate , approval of the application presents no national security issue

. Given the following , the grant of the requested exemptions is clearly in the public interest: PDND proposes that the exemption requested herein appl y to civil aircraft that have the characteristics and that operate with the limitations listed herein

. These limitations provide for an exceptional level of safety to operations. These limitations and conditions to which PDND agrees to be bound when conducting commercial operations under an FAA issued exemption including : 1. The UAS will weigh less than 55 lbs. 2. Flights will be operated within line of sight of operator. 3. Maximum total flight time for each operational flight will be 30 minutes. 4. Flights will be terminated at 15% battery power reserve. 5

. Flights will be operated at an altitude of no more than 400 feet AGL 6

. UAS operator will be trained and certified in the proper safety and operations of the UAS. 7

. The UAS will only operate within a controlled area as defined in the Procedures

. 8. The operator will post advisor notice around the controlled area. 9. The operator will have been trained in operation of UAS generally and received up-to-date information on the particular UAS to be operated as required. 10. If the UAS loses communications or loses its GPS signal, the UAS will have capability to return to a pre-determined location within the Security Perimeter and land

. 11. The UAS will have the capability to abort a flight in case of unpredicted obstacles or emergencies. The public interest will be served by granting PDND’s petition for exemption. Granting this petition for exemption will improve safety and reduce risk by minimizing the public’s exposure to danger and emissions associated with personnel performing a similar tasks. - Tower structural inspections; conventional tower structure inspections and associated tasks involve extreme risks to personnel physically climbing such structures and/or utilizing high rise equipment both of which create numerous and extreme risk to such personnel which can be reduced utilizing a UAS performing si milar aerial data collections. - Photogrammetry and mapping; steep terrain often poses a risk to personnel which can be reduced utilizing a UAS performing similar data collections. - Aerial imagery; The UAS’s are battery powered and create no emissions. Also, any accident involved a UAS will present a significantly less danger to the pilot or other individuals on the ground than one involving a full size aircraft performing similar photos.The name and contact information of the applicant are: Precision Design & Drafting, Inc. 11768 Atwood Rd, Suite 20 Auburn, CA 95603 Bret McComb, PE 530-823-6546 bret@pdnd.com Regulations from which the exemption is requested are as follows: 14 CFR Part 21 14 CFR 45

. 23(b) 14 CFR 91

. 7(a) 14 CFR 91.9(b)(2) 14 CFR 91

. 103(b)(2) 14 CFR 91.109 14 CFR 91.119 14 CFR 91

. 121 14 CFR 91

. 151(a) 14 CFR 91

. 203(a) & (b) 14 CFR 91.405(a) 14 CFR 407(a) (1) 14 CFR 409(a) (2) 14 CFR 417(a) & (b) Accordingly, the applicant respectfully requests that the FAA grant the requested exemption and are prepared to modify or amend any part of this request to satisfy the need for an equivalent level of safety. We look forward to working with your office. Please contact us at any time if additional information or clarifications are needed

. Sincerely, Precision Design & Drafting, Inc.

Bret McComb, PE President, CEO

Appendices: A. Exemption Request and Equivalent Level of Safety B. Permission FormAppendix A EXEMPTION REQUESTS AND EQUIVALENT LEVEL OF SAFETY Precision Design & Drafting, Inc. requests an exemption from the following regulations as well as any additional regulations that may technically apply to the operation of its UAS’s. 14 CFR Part 21, Subpart H: Airworthiness Certificates Subpart H, entitled Airworthiness Certificates, establishes the procedural requirements for the issuance of airworthiness certificates as required by FAR §91

. 203(a) (1)

. Given the size and limited operating area associated with the aircraft to be utilized by the Applicant, an exemption from Part 21 Subpart H meets the requirements of an equivalent level of safety under Part 11 and Section 333 of the Reform Act. The Federal Aviation Act (49 U.S.C. §44701 ( f )) and Section 333 of the Reform Act both authorize the FAA to exempt aircraft from the requirement for an airworthiness certificate, upon consideration of the size, weight, speed, operational capability, and proximity to airports and populated areas of the particular UAS

. In all cases, an analysis of these criteria demonstrates that the UAS operated without an airworthiness certificate , in the restricted environment and under the conditions proposed will be at least as safe, or safer, than a conventional aircraft (fixed wing or rotorcraft) operating with an airworthiness certificate without the restrictions and conditions proposed. The UAS to be operated hereunder is less than 55 lbs fully loaded, carries neither a pilot nor passenger, carries no explosive materials or flammable liquid fuels, and operates exclusively within a controlled area as set out in the Procedures

. Unlike other civil aircraft, operations under this exemption will be tightly controlled and monitored by the oper ator, pursuant to the Procedures requirements

. Lastly, application of these same criteria demonstrates that there is no credible threat to national security posed by the UAS, due to its size, speed of operation, location of operation , lack of explosive materials or flammable liquid fuels, and inability to carry a substantial external load. 14 CFR § 45.23 (b). Marking of the Aircraft The regulation requires: 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

. Even though the UAS will have no airworthiness certificate, an exemption may be needed as the UAS w ill have no entrance to the cabin, cockpit or pilot station on which the word "Experimental" can be placed

. Given the size of the UAS, two-inch lettering will be impossible. The word "Experimental" will be placed on the fuselage in compliance with §45

. 29(f). The equivalent level of safety will be provided by hav ing the UAS marked on its fuselage as required by §45

. 29(f) where the operator working with the UAS will see the identification of the UAS as

" Experimental." The FAA has issued the following exem ptions to this regulation to Exemptions Nos

. 10700, 8738 , 10167 and 10167 A 14 CFR §91.7(a): Civil aircraft airworthiness. The regulation requires that no person may operate a civil aircraft unless it is in airworthy condition. As there will be no airworthiness certificate issued for the aircraft, should this exemption be granted, no FAA regulatory standard will exist for determining airworthiness. Given the size of the aircraft and the requirements contained in the Procedures for maintenance and use of safety check lists prior to each flight, an equivalent level of safety will be provided.14 CFR § 91.9(b) (2): Civil Aircraft Flight Manual in the Aircraft. Section 91

. 9(b) (2) provides : No person may operate a U.S.-registered civil aircraft ... (2) for which an Airplane or Rotorcraft Flight Manual is not required by §21.5 of this chapter , unless there is available in the aircraft a current approved airplane or Rotorcraft Flight Manual, approv ed manual material, markings, and placards, or any combination thereof. The UAS, given its size and configuration has no ability or place to carry such a flight manual on the aircraft , not only because there is no pilot on board , but because there is no room or capacity to carry such an item on the aircraft

. The equ i valent level of safety will be maintained by keeping the flight manual at the ground control point where the operator flying the UAS will have immed i ate access to it. The FAA has issued the following exemptions to this regulation : Exemption Nos

. 8607, 8737, 8738 , 9299, 9299A, 9565 , 95658, 10167 , 10167A, 10602 , 32827, and 10700

. 14 CFR § 91.103(b): Preflight action This regulation requires that e ach pilot in command shall, before beginn ing a flight, become familiar with all available information concerning that flight. This inform ation must include — (b) for any flight, runway lengths at airports of intended use, and the following ta keoff and landing distance information... As FAA approved rotorcraft flight manuals will not be provided for the aircraft and because runways are not needed for takeoff and landing operations, an exemption will be needed

. An equivalent level of safety will be provided as set forth in Procedures. The operator will take all actions including reviewing weather, flight battery requirements, landing and takeoff locations and aircraft performance data before initiation of flight. 14 CFR §91.109: Flight instruction : Section 91.103 provides that no 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 fully functional dual controls

. Flight control is accomplished through the use of a control box that communicates with the aircraft via radio communications

. The FAA has approved exemptions for flight training without fully functional dual controls for a number of aircraft and for flight instruction in experimental aircraft

. See Exemption Nos.5778K & 9862A. The equivalent level of safety provided by the fact that neither a pilot nor passengers will be carried in the aircraft and by the size and speed of the aircraft

. 14 CFR §91.119: Minimum safe altitudes Section 91.119 establishes safe altitudes for operation of civil aircraft

. Section 91.119 (d) allows helicopters to be operated at less than the minimums prescribed, provided the person operating the helicopter complies with any route or altitudes prescribed for helicopters by the FAA. As this exemption is for a UAS that is a helicopter and the exemption requests authority to operate at altitudes up to 400 AGL, an exemption may be needed to allow such operations. As set forth herein , except for the limited conditions stated in the Procedures , the UAS will never operate at higher than 400 AGL. The equivalent level of safety will be achieved given the size, we i ght, speed of the UAS as well as the location where it is operated. In addition, the low-altitude operations of the UAS will ensure separation between these small-UAS operations and the operations of conventi onal aircraft that must comply with Section 91.119

. 14 CFR §91.121: Altimeter Settings This regulation requires each person operating an aircraft to maintain cruising altitude by reference to an altimeter that is set "

. .. to the elevation of the departure airport or an appropriate altimeter setting available before departure. " As the UAS may not have a barometric altimeter, but instead a GPS altitude read out , an exemption may be needed

. An equivalent level of safety will be achieved by the operator, pursuant to the Procedures and Safety Check list, confirming the altitude of the launch site shown on the GPS altitude indicator before flight.14 CFR § 91.151(a): Fuel Requirements for Flight in VFR Conditions Section 91

. 151(a) prohibits an individual from beg i nning " a flight in an a i rplane 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

. " The battery powering the UAS provides approximately 40 minutes of powered fligh t. To meet the 30 minute reserve requirement in 14 CFR §91

. 151, UAS flights would be limited to approximately 10 minutes in length

. G i ven the limitations on the UAS's proposed flight area and the location of its proposed operations within a predetermined area, a longer time frame for flight in daylight or night VFR conditions is reasonable

. Applicant believes tha t an exemption from 1 4 CFR §91

. 151(a) falls within the scope of p r ior exemptions. See Exemption 10673 (allowing Lockheed Martin Corporation to operate without compliance with FAR 91.151(a))

. Operating the small UAS , in a tightly controlled area, with less than 30 minutes of reserve fuel, does not engender the type of risks that Section 91

. 151(a) was intended to alleviate given the size and speed of the small UAS

. Additionally , limiting UAS flights to 10 minutes would greatly reduce the utility for which the exemption will be granted

. Applicant believes t hat an equivalent level of safety can be achieved by limiting flights to 30 minutes or 15% of battery power whichever happens first. This restriction would be more than adequate to return the UAS to its planned landing zone from anywhere in its limited operating area

. Similar exemptions have been granted to other operations , including Exemptions 2689F , 5745, 10673 , and 10808. 14 CFR §91.203(a) and (b): Carrying Civil Aircraft Certification and Registration The regulation provides in pertinent part : (a) Except as provided in § 91

. 715, no pe r son 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

. The UAS fully loaded weighs no more than 55 lbs and is operated without an on board pilot. As such , there is no ability or place to carry certification and registration documents or to display them on the UAS. An equivalent level of safe ty will be achieved by keeping these documents at the ground control point where the operator flying the UAS will have immediate access to them , to the extent they are applicable to the UAS

. The FAA has issued numerous exemptions to this regulation

. A representative sample of other exceptions includes Exemption Nos. 9565, 9665, 9789 , 9789A, 9797, 9797A, 9816A , and 10700. 14 CFR §91.405(a); 407(a) (1); 409(a) (2); 417(a) & (b): Maintenance Inspections These regulations require that an aircraft operator or owner "shall have that aircraft inspected as prescribed in subpart E of this part and shall bet ween required inspections, except as provided in paragraph (c) of this section , have discrepancies repaired as prescribed in part 43 of this chapter.

. . ," and others shall inspect or maintain the aircraft in compliance with Part 43. Given that these section and Part 43 apply only to aircraft with an airworthiness certificate, these sections will not apply to the applicant. Maintenance will be accomplished by the operator pursuant to the flight manual and operating handbook as referenced in the Procedures. An equivalent level of safety will be achieved because these small UASs are very limited in si ze and will carry a small payload and operate only in controlled areas for limited periods of time. If mec hanical issues arise the UAS can land immediately and will be operating from no higher than 400 feet AGL

. As provided in the Procedures, the operator will ensure that the UAS is in working order prior to initiating flight, perform required maintenance , and keep a log of any maintenance performed

. Moreover , the operator is the person most familiar with the aircraft and best suited to maintain the aircraft in an airworthy condition to provide the equivalent level of safety

. Pursuant to 14 CFR Part 11 , the following summary is provided for publication in the Federal Register, should it be determined that publication is needed:Applicant seeks an exemption from the following rules: 14 CFR §21, subpart H ; 14 CFR 45.23(b) ; 14 CFR §§ 61

. 113(a) & (b) ; 91.7(a); 91.9(b) (2); 91.103(b); 91

. 109; 91.119; 91.121; 91

. 151(a); 91

. 203(a) & (b); 91.405(a) ; 91.407(a) (1) ; 91.409(a) (2); 91.409(a) (2) & 91.417(a) & (b) to operate commercially a small unmanned vehicle (55lbs or less) fo r the purpose of inspection, monitoring , mapping and photographing attached equipment and engineering studi es involving communication towers, wind turbine tower facilities and power transmission tower operations. Approval of exemptions allowing commercial operati ons of UASs will create a level of safety by reducing risk

. Conventional tower structure inspections an d associated tasks involve extreme risks to personnel physically climbing such structures and/or utilizing high rise equipment both of which create numerous and extreme risk to such personnel. In contrast , a UAS weighing fewer than 55 lbs and powered by batteries eliminates virtually all of t hat risk. The UAS will carry no passengers or crew and, therefore, will not expose personnel to any of the risks described above. The operation of small UASs , weighing less than 55 lbs, conducted in the strict conditions outlined above, will provide a level of safety supporting the grant of the exemptions requested herein , including exempting the applicant from the requirements of Part 21 and allowing commercial operations. These lightweight aircraft operate at slow speeds, close to the ground , and in a controlled environment. Privacy All flights will occur over private or controlled ac cess property with the property owner's prior consent and knowledge

. The granting of this exemption request w ill provide innovative safety operations. Satisfaction of the criteria provided in Section 333 of the Reform Act of 2012 - size, weight, speed, operating capabilities, proximity to airports and populated areas and operation within visual line of sight and national security - provide more than adequate justification for the grant of the requested exemptions allowing commercial operation of applicant's UAS in and pursuant to the Procedures appended hereto

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