1 UNITED STATES OF AMERICA
DEPARTEMNT OF TRANSPORTATION
FEDERAL AVIATION ADMINISTRATION WASHINGTON, DC



## Original Submitted January 5 th 

## , 2016 REVISION January 16 th



## , 2016 Replaces the January 5 th 

## , 2016 Submittal

Comment Tracking Number: 1K0

- 8n7s

- hzic

Regul ator y Docket No. _____________________

IN THE MATTER OF THE PETITION FOR EXEMPTION OF:

OHIO SPECIAL RESPONSE TEAM FOR AN EXEMPTION SEEKING RELIEF FROM THE REQUIREMENTS OF
TITLE 14 OF THE CODE OF FEDERAL REGULATIONS SECTIONS 14 CFR PART 21, 45.23(b),61.113 (a)&(b), 91.7 (a), 91.9 (b)(2) 91.103, 91.109, 91.119, 91.121, 91.151 (a), 91.203 (a)&(b), 91.405 (a), 401 (a)(1), 409 (a)(2),

And 417 (a)&(b) CONCERNING COMMERCIAL OPERATION OF THE
DJI PHANTO M 2 VISION+, DJI PHANTOM 3, DJI INSPIRE 1 , AND D JI MATRICE 100
UNMANNED AIRCRAFT SYSTEM PURSUANT TO SECTION 333 OF THE FAA MODERNIZATION AND REFORM ACT OF 2012 (PUBLIC LAW 112

- 95)

Submitted on January 5 th , 2016 Revised January 16 th , 2016

Ohio Special Response Team, Inc

Elvin W. Burnell, President

597 Park Ave East

Mansfield, OH 44905

Ph: 419

- 528

- 0041 (O) / Elvin Burnell 419

- 512

- 37 09 (C)2

January 5 th , 2016 U. S. Department of Transportation Docket Management System 1200 New Jersey Ave., SE Washington, DC 20590

Re: Exemption Request Section 333 of the FAA Reform Act and Part 11 of the Federal Aviation Regulations from 14 C.F.R. 45.23(b);14 CFR P art 21;14 CFR 61.113 (a) & (b); 9 1.7 (a);91.9 (b) (2);91.103(b); 91.109;91.119; 91.121; 9 1.151(a);91.203(a) & (b);91.405 (a); 9 1.407(a) (1); 91.409 (a) (2);91.417 (a) & (b).

Dear Sir or Madam:

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the Reform Act) and 14 C.F. R. Part 11, Ohio Special Response Team (See Footnote 1) , oper ator of Small Unmanned Aircraft Systems (sUAS) equipped to offer on

- demand comme rcial UAS operations for a host of industries and applications.
These include:

• Public Safety Support Operations
• Search and Rescue

– lost or missing individuals

Ohio Special Response Team hereby applies for an exemption from the listed Federa l Aviation Regulations (“FARs”) to allow commercial operation of its sU ASs, so long as such operations are conducted within and
under the conditions outlined herein or as may be established by the FAA as requ ired by Section 333

.

As described more fully below, the requested exemptio n would permit the operation of small, unmanned and relatively inexpensive sUAS under controlled conditions in airspace that is 1) limited 2) predetermined 3) contr olled as to acces s and 4) would provide safety enhancements to the already safe operatio ns using conventional aircraft. Approval of this exemption would thereby enhance safety and fulfill the Secretary of Transportation’s (the FAA Administrator’s) responsibilit ies to “...est ablish requirements for the safe operation of such aircraft systems in the nat ional airspace system.” Section 333(c) of the Reform Act.

Footnote 1. The Ohio Special Response Team is a non

- profit organization with the dedicated mission of saving lives. The Federal Internal Revenue Employer Identification Number (EIN) 74

- 3106323. All members

are volunteers . The organization doesn’t charge for its services.

The name and address of the petitioner is: Ohio Special Response Team, Inc. Attn: Elvin W. Burnell, President
597 Park Ave. East Mansfield, OH 44905
Ph: 419

- 528

- 0041 (O) / Elvin W. Burnell 419

- 512

- 3709 (C)
Email: osrtince@yahoo.com (O) / Elvin W. Burnell e

- mail: ewburnell@embarqmail.com \ Regulations from which the exemption is requested:

14 CFR Part 21 14 C.F.R. 45.23(b) 14 CFR 61.113 (a) & (b)3

14 C.F.R. 91.7 (a) 14 CFR 91.9 (b) (2)
14 C.F.R. 91.103
14 C.F.R. 91.109
14 C.F. R. 91.119
14 C.F.R. 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)

This exemption application is expressly submitted to fu lfill Congress’ goal in passing Section 333(a) through (c) of the Reform Act. This law d irects the Secret ary of Transportat ion to consider whether certain

unmann ed aircraft systems may operate safely in the national airspace system (NAS) befo re completion of the rulemaking required under Section 332 of the Reform Act. In making this determina tion, the Secreta ry is required to determine which types of UASs do not create a hazard to users of the NAS or the public or pose a threat to national security in light of the following:

• The UAS’s size, weight, speed, and operational capability; • Opera tion of the UAS in close proximity to airports and populated areas; and • Operation of the UAS within visual line of sight of the operator.

Reform Act § 333 (a). Lastly, if the Secretary det ermines that such vehicles “may operate safely in the
national ai rspace system, the Secretary shall establish requirements for the safe operation of such aircraft in the national airspace system.” Id. §333(c) (emphasis added)

Applicant interprets this provision to place the duty o n the Administrator to not only process applications for exemptions under section 333, but for the Administrator to craft conditions for the safe operation of the UAS, if i t should be determined that the conditions set forth herein do not fulfill the statutory requirements for approval.
The Fed eral Aviation Act expressly grants the FAA the authority to issue exemptions. This statutory authority by its terms includes exempting civil aircraft, as the term is defined under §40101 of the Act that includes sUASs, from the requirement that all civil a ircraft must have a current airworthiness certificate.

The Administrator may grant an exemption from a require ment of a regulation prescribed under subsection (a) or (b) of this section or any sections 4 4702

- 44716 of this title if the Administrator finds the exemption in the public interest. 49 U.S.C. §44701(f) See also 49 USC §44711(a); 49 USC §44704; 14 CFR §91.203 (a) (1).

The Ohio Special Response Team sUASs are rotorcraft, weighting 55 or few er lbs. including payload. They
operate , under normal conditions at a speed of no more than 50 knots and have the capability to hover,
and move in the vertical and horizo ntal plane simultaneously. They will operate only in line of sight and will
operate o nly within a sterile area. Such operatio ns will insure that the sUAS will “not create a hazar d to
users of the national airspace system or the public.” Specific operational sUASs are the DJI Phantom 2 Vision+, DJI Phantom 3, and DJI Inspire 1. The DJI Phanto m 2 Vision+, DJI Phantom 3, DJI Inspir e 1 , and DJI
Matrice 100 are vertical takeoff and landing (VTOL) Unmanned Aircraft (UA) with a Ground Control Station (GCS) utilizing electronic tablet or smart phone systems

.4 * The DJI Phantom 2 Vision+ and Phantom 3 have a maximu m gross weight of approximately 2

p ounds 11 ounces, while having a length of 16 inches width of 16 inches, height of 8 inches, and maximum speed of approximately 29 knots.

* The DJI Inspire 1 has a maximum gross weight of 6 pounds 7.5 ounces, a length of 1 7.3 inches, width of 17.7 inches, height of 11.8 inches, and a maximum speed of approximately 42 knots.

* The DJI Phantom 2 Vision+, Phantom 3, and the DJI Inspire 1 UAs are equipped with four main rotors; driven by Lithiu m Polymer battery powered e lectric motors. The DJI Phantom2 Vision+, Phantom 3, DJI Inspire 1, and DJI Matrice 100 has a wheel base diagonal 650mm, gross weight 243 g, max speed 42 KTS UAs that will be operated by Ohio Special Response Team will be register ed in accordance with 49 U.S.C. 44103, Registration of Aircraft, as well as 14 C.F.R Part 47, Aircraft Registration, and marked in ac cordance with 14 C.F.R Part 45, Identification and Registration Marking.

Reform Act Section 333 (b).
Given the small size of the sUASs involved and the restri cted sterile environment within which they will operate, the applicant falls squarely within that zone of safety (an equivalent level of safety) in which Congress envisioned that the FAA must , by exe mption, allow commercial operations of UASs to co mmence immediately. Also due to the size of the UASs and the restricted areas in which t he relevant sUASs will
operate, approval of the application presents no national security issue. Given the clea r direct ion in Section 333 of the Reform Act, the authority contained in the Federal Aviation Act, as amended; the strong equivalent level of safety surroundi ng the proposed operations, and the significant public benefit, including enhanced safety, reducti on in en vironmental impacts, including reduced emissions associated with allowing UASs, the grant of the requested exemptions is in the public interest.

Accordingly, the applicant respectfully requests t hat the FAA grant the requested exemption without delay.

AI RCRAFT AND EQUIVALENT LEVEL OF SAFETY The applicant proposes that the exemption requested here in apply to civil aircraft that have the characteristics and that operate with the l imitations listed herein. These limitations provide for at least an equivalent or even highe r level of safety to operations under the current regulatory structure because the proposed operations represent a safety enhancement to the already safe operations conduc ted with
conventional aircraft. These limitations and conditions to whi ch HYSight Techn ologies agrees to be bound
when conducting commercial operations under an FAA issued exemption include:

1. The sUAS will weigh less than 55 lbs. 2. Flights will be operated within line of si ght of a pilot and/or observer. 3. Maximum total f light time for each operational flight will be 45 minutes. Flights will be terminated at 25% battery power reserve should that occur prior to the 45 minute limit. 4. Flights will be operated at an altitude of no more than 400 feet AGL or, not more th an 200 feet above an elevated platform from which filming is planned. 5. Minimum crew for each operation will consist of the s UAS Pilot, the Visual Observer, and/or the Camera Operator. 6. sUAS pilot will be an FAA licensed airman with at least a private p ilot’s certificate and 3 rd class medical
certificate. 7. sUAS Pilot will be Pilot in Command (PIC). If a pilot ce rtificate holder other than the sUAS Pilot, who possess the necessary PIC qualifications, is also present (i.e. the Visual Observer), that person can also be designated as the PIC. 8. The UAS will only operate within a confined “Sterile Area” of the flight operations area.5

9. A briefing will be conducted in regard to the planne d sUAS operations prior to each day’s activities. It will be mandatory that all personne l who will be performing duties within the boundaries of the safety perimeter be present for this briefing. 10. The operator will obtain the consent of all person s involved and ensure that only consenting persons will be allowed within 100 feet of the fl ight operation, and this radius may be reduced to 30 feet based upon an equivalent level of safety determination. 11. Pilot and observer will have been trained in operatio n of UAS generally and received up

- to

- date information on the particular UAS to be operated. 12. Observer and pilot will at all times are able to communicate by voice and/or text. 13. Written and/or oral permission from the relevant property holders will be obtained. 14. All required permissions and permits will be obtained fro m territorial, state, county or city jurisdictions, including local law enforcement, fire, or other appropriate governmental agencies. 15. If the sUAS loses communications or loses it s GPS signal, the UAS will have capability to return to a pre

determined location within the Security Perimeter and land. 16. The sUAS will have the capability to abort a flight in c ase of unpredicted obstacles or emergencies.

14 C.F.R. Part 21, Subpart H: Airworthiness Certifi cates 14 C.F.R. §91.203 (a) (1) Subpart H, entitl ed 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 th e Reform Act both authorize the FAA to exempt aircraft from the requirement for an airworthiness certificate, upon consideration of the size, weight, speed, operational capabi lity, and proximity to airports and populated areas of the particular UAS. In all cases , an analysis of
these criteria demonst rates 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 ce rtificate without the restrictions and conditions proposed.

The sUAS 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 with in a secured area as
set out in the Manual. Unlike other civil aircraft, operations under this exemption will be tightly c ontrolled and monitored by both the operator, pursuant to the Manual’s requirements, an d under the requirements
and in compliance with local public safety requirements, to p rovide security for the area of operation as is now done with conventional filming. The FAA will have advance notice of all operations. These safety enhancements, which already a pply to civil aircraft operated in conn ection with motion picture and television producti on, provide a greater degree of safety to the public and property owners than

convent ional operations conducted with airworthiness certificates issued under 14 C.F.R. Part 21, Subpart H. Lastly, applicatio n of these same criteria demonstrates that there is no credi ble 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 substa n tial external load. The FAA has issued the following exemptions to this regulations Exemptions Nos. 11251.

14 C.F.R. § 45.23 (b). Marking of the Aircraft The regulation requires: When marks include only the Roman capital letter "N" and the registration n u mber is displayed on limited, restricted or light

- sport categ ory aircraft or experimental or provisionally certificated aircraft, the operator6

must also dis play on that aircraft near each entrance to the cabin, cockpit, or pilot station, in letters not le s s 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 c ertificate, an exemption may be needed as the UAS will
have no entrance to the cabin, co ckpit or pilot station on which the word “Experimental” can be placed.
Given the size of the sUAV, two

- inch lettering will be impossible. The word “Experimental” will be place d on the fuselage in compliance with §45.29 (f).

The equivalent level of safety will be provided b y having the sUAV marked on its fuselage as required by §45.29 (f) where the pilot, obser ver and others working with the sUAV will see the identification of the UAS as “Experi mental.” The FAA has issued the fol lowing exemptions to this regulation to Exemptions, but no t limited to, Nos. 10700, 8738, 10167 and 10167A, 11256, 11251.

14 C.F.R. § 61.113 (a) & (b): Private Pilot Privi leges and Limitations: Pilot in Command. Sections 61.113 (a) & (b) limit private pil ots to non

- commercial operations

. Because the sUAS will not carry a pilot or passengers, the prop osed operations can achieve the equivalent level of safety of current operations by requiring the PIC operating the aircraft to have a private pilot’s license rather than a
commercial pilot’s license to operate this small UAS. Unlike a conventional aircraft that carries the pilot and passengers, the sUAS is remotely controlled with no living thing on board. The area of operation is
controlled and restricted, an d all flights are planned and coordinated in advance. The level of safety provided by the requirements included in the Manual ex ceeds that provided by a single individual holding a commercial pilot’s certificate operati ng a conventional aircraft. The risks associated with the operation of
the sUAS are so di minished from the level of risk associated with commercial operations contemplate d by Part 61 when drafted, that allowing operations of the sUAS as requested with a priva te pilot as the PIC
exceeds the pr esent level of safety achieved by 14 C.F.R. §61.113 (a) & (b).

14 C.F.R. §91.7(a): Civil aircraft airworthiness. The regulation requires that no person may operate a civil air craft unless it is in airworthy condition. As
there will be no airworthiness cer tificate issue d for the aircraft, should this exemption be granted, no FAA regulatory stan dard will exist for determining airworthiness. Given the size of the aircraft and th e requirements contained in the Manual for maintenance and use of safety check lis ts prior to each flight, as
set forth in Sections J, L and Q, an equivalent level of safety will be provided.

14 C.F.R. § 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 aircr aft ... (2) For which an Airplane or Rotorcraft Flight
Manual i s not 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 an y combination thereof. The sUAS, 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 i tem on the airc raft. The equivalent level of safety will be maintained by k eeping the flight manual at the ground control point where the pilot flying the sUAS wi ll have immediate access to
it. The FAA has issued the following exemptions to this regulation , but not limited to: ExemptionNos. 8607, 8737, 8738, 9299, 9299A, 9565, 9565B, 10167, 10167A, 10602, 32827, 10700, 11251, and 11256.7

14 C. F.R. § 91.103: Preflight action This regulation requires each pilot in command to take certain actions before fl ight to insure the safety of flight. As FAA approved rotorcraft flight manuals will not be provided for the aircraft an exemption will be needed. The PIC will take all actions including reviewing weather, flight battery requirements, landing and
takeoff di stances and aircraft performance data before initiation of flight.

14 C.F.R. §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 t hat aircraft has ful ly functioning dual controls UASs and remotely piloted aircraft, by their design do not have fully functional dual controls. Flight control is accomplished throug h the use of a control box that communicates with the aircraft via radio c ommunications. 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. S ee Exemption Nos.5778K & 9862A. The equivalent level of safety provided by the fact that neit her a pilot nor passengers will be carried in the aircraft and by the size and speed of the aircraft.

14 C.F.R. §91.119: Minimum safe altitudes Section 91.119 establishes safe altitudes for operation of civ il aircraft. Section 91.119 (d) allows helicopters to be operated at less than the mi nimums prescribed, provided the person operating the helicopter complies with any ro ute or altitudes prescribed for helicopters by the FAA. As this exemption is for a sU AS that is a helicopter and t he exemption requests authority to operate at altitudes up to 400 AGL, or not more than 200 above an elevated platform from which filming is planned, an exemption may be needed to allow such operations. As set forth herein, ex cept for the limited condition s stated in the Manual, the UAS will never operate at highe r than 400 AGL. It will however be operated in a restricted area with security perimeter, where buildings and people will not be exposed to operations without their pre

- obtained

c onsent. The equivalent level of safety will be achieved given the size, weight, and speed of the UAS as well
as the location where it is operated. No flight will be taken wit hout the required permission of the property
owner or local officials. Because of the advance notice to the property owner and participants in the aerial activity, all affected i ndividuals will be aware of the planned flight operations. Compared to flight operati ons with aircraft or rotorcraft weighting far more than the maximum 55lbs. proposed herein and the
lack of flamm able fuel, any risk associated with these operations is far less than those presently presented with conventional aircraft operating at or below 500 AGL oth er industries. In addition, the low

- altitude operations of the sUAS will ensure separation between t hese small

- UAS operations and the operations of
conventional aircraf t that must comply with Section 91.119.

14 C.F.R. §91.121 Altimeter Settings This regulation requires each person operating an aircraft t o maintain cru ising altitude by reference to an
altimeter that is set “...to the elevation of the departure airport or an appropriate altimeter setting available before departu re.” As the sUAS may not have a barometric altimeter, but instead a GPS altitude
read o ut, an ex emption may be needed. An equivalent level of safety will be achieved by the o perator, pursuant to the Manual and Safety Check list, confirming the altitude of the launch site shown on the GPS altitude indicator before flight.

14 C.F.R. § 91.151(a): Fuel Requirements for Flight in VFR Conditions Section 91.151 (a) prohibits an individual from beginning “a flight in an airplane under VFR conditions unless (considering wind and foreca st weather conditions) there is enough fuel to fly to the first point of
in tended landing, and, assuming normal c ruising speed

– (1) During the day, to fly after that for at least 30

m inutes; or (2) At night, to fly after that for at least 45 minutes.”8

The battery powering the sUAS provides approximately 30

- 5 0 minutes of powered flight. To meet the 30

- minute reserve requirement in 14 CFR §91.151, sUAS flights would be limited to approximately 20 minutes in length. Giv en the limitations on the UAS’s proposed flight area and the location of its proposed

op erations within a predeterm ined area, a longer time frame for flight in daylight or nigh t VFR conditions is
reasonable. Applicant believes that an exemption from 14 CFR §91.1 51(a) falls within the scope of prior exemptions. See Exemption 10673 (allowing Lockheed Martin Corporation t o operate without compliance with FAR 91.151 (a)). Operat ing the small UAS, in a tightly controlled area where only people and property

owners or official representatives who have signed waivers will be allowed, with less than 30 minutes of reserve fuel, d oes not engender the type of risks that Section 91.151(a) was inten ded to alleviate given the
size and speed of the small UAS. Additionally, limiting s UAS flights to 20 minutes would greatly reduce the utility for which the exemption will be granted.

Applicant believes that an equivalent level of safety can be achieved by limiting flights to 45 minutes or 25% of battery power whichever happens f irst. This restriction would be more than adequate to return the sUAS to its planned la nding zone from anywhe re in its limited operating area. Similar e xemptions have been granted to other operatio ns, including Exemptions 2689F, 5745, 10673, 10808, and 11251.

14 C.F.R. §91.203 (a) and (b): Carrying Civil Aircraft Certification and Registration The regulation pro vides in pertinent part: (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 airwor thiness certificate required by paragraph (a) of this section or a special flight author ization 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 onboard pilot. As such, there is no ability or place to carry certifica tion and registration documents or to display them on the sUAS.

An equivalent level of safety will be achieved by keepin g these documents at the groun d control point where the pilot flying the sUAS will have i mmediate access to them, to the extent they are applicable to the
sUAS. The FAA ha s issued numerous exemptions to this regulation. A representative sample of other

exc eptions includes Exemption Nos

. 9565, 9665, 9789, 9789A, 9797, 9797A, 9816A , 10700, 11251, and
11256. 14 C.F.R. §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 shal l between 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 insp ect or maintain the aircraf

t 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 applican t. The operator pursuant to the flight manual and operating handbook will accomplish m aintenance. An equivalent level of safety will be achieved because these small UASs ar e very limited in size and will carry a small payload and operate only in restricted areas for limited periods of time.
If mechanical issues arise the UAS can land imme diatel y and will be operating from no higher than 400 feet AGL. As provided in the Manual, th e 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. More over, the

opera tor is the person most familiar with the aircraft and best suited to maintain the aircra ft in an airworthy condition to provide the equivalent level of safety.

*********9

Pursuant to 14 C.F.R. Part 11, the following summary is provided for p ublication in the Federal Register,
should it be determi ned that publication is needed: Applicant seeks an exemption from the following rules: 14 C.F.R. §21, subpart H; 14 C.F.R 45.23(b);14 C.F.R. §§ 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) and (b); 91 .405 (a); 91.407 (a) (1); 91.409 (a) (2); 91.409 (a) (2) and 91.417 (a) & (b) to operate commercially a small unmanned vehicle (55lbs or less).

Approval of exemptions allowing commercial operation s of sUASs, will enhance safety by reducing risk. Conventional operations, using jet or pi ston power aircraft, operate at extremely low altitudes just feet from the subjects being filmed and in extreme proximity to people and structures and present the risks

a ssociated with vehicles that weigh in the neighborhood of 4,000lbs, carrying large amounts of jet A or other fuel. Such aircraft must fly to and from the operational location. In contrast , a sUAS weighing fewer
than 55 lbs. and powered by batteries eliminat es virtually all of t hat risk given the reduced mass and lack of
combustible fuel carried on board. The sUAS i s carried to the operation site and not flown. The sUAS will

carry no passengers or crew and, therefore, will not expose them to the risks associa ted with manned aircraft flights.

The operation of small UASs, weighting less than 5 5 lbs., conducted in the strict conditions outlined above, will provide an equivalent level of safety supporting the grant of the exemptions requested herein, including e x empting the applicant from the requirements of Part 21 and allowing commercial operati ons. These lightweight aircraft operate at slow speeds, close to the ground, and in a sterile environment and, as

a result, are far safer than conventional operations con ducted with turbine helicopters operating in close proxi mity to the ground and people.

Privacy All flights will occur over private or controlled access pro perty with the property owner’s prior consent and knowledge. Filming will be of pe ople who have also consented to being filmed or otherwise have agreed to
be in the area where filming will take place. The grant of this exemption request will provide improv ed safety in both day and night 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 nation al security

– provide more than adequate justification for the grant of the requested exempt ions allowing commercial operation of applicant’s UAS. It is of note that certain publi c safety operations may involve advanced monitoring technology such as Infrared Red, Ni ght Vision, etc. These specific operations will be governed pursuant to all applic able Local, St ate, and Federal laws regarding search and seizure including court approval of said operations via search warrant.

Conclusion
As set fo rth herein, Ohio Special Response Team seeks an exemption pursuant to 14 C.F.R 11.61 and
Section 333 of t he FAA Modernization and Reform Act of 2012 (FMRA), which will pe rmit safe operation of
the DJI Phanto m 2 Vision+, DJI Phantom 3, D JI Inspire 1 , and Matrice 100 UASs commercially, without an airworthiness certificate, for the limited purpose o f conducting the aforementioned on

- demand commercial sUAS operations that include:
• Public Safety Support Operations

• Search and Rescue

– lost or missing individuals

By granting this Petition, the FAA Administrator will be fulfilli ng the Congressional mandate of the FAA Modernization and Reform Act of 2012, while also advancing the interests of the public, by allowing Ohio Special Response Team to safely, effici ently, and economically operate sUASs commercially within the NAS.10

WHER EFORE, in accordance with the Federal A viation Regulations and the FAA Modernization and Reform Act of 2012, se ction 333, Ohio Special Response Team respectfully requests that the Administrator grant this Petition for an exempt ion from the requirements of 14 C.F.R Sections 45.23(b); Part 21; 61.113(a) & (b), 91.7(a); 91.9 (b); 91.103(b); 91.109; 91.119; 91.121; 91.151(a); 91.203(a); 91.405(a), 91.407(a)(1); 91.409( a)(1) & (a)(2), and 91.417(a) & (b), and permit Ohio Special Response Team to operate the DJI

P h antom 2 Vision+, DJI Phantom 3, DJI Inspire 1, and Matrice 100 com mercially in the United States. It is further noted that granting this exemption is not precedent setting and it is in the interest of the general public of the United States and public sa fety.

Respectfully Submitted, Ohio Special Response Team, Inc.
Elvin W. Burnell. President
597 Park Ave East Mansfield, OH 44905
419

- 528

- 00 41 (O) / Elvin W. Burnell 419

- 512

- 3709
E

- mail: osrtinc@yahoo.com / El vin W. Burnell ewburnell@embarqmail.com

Appendices : A

– DJI Phantom 2 Vision+/Phantom 3

– Specifications Data Sheet

B

– DJI Inspire 1 Specifications Data Sheet
C

– DJI Matrices 100

- Specifications Data Sheet

D

– Link to DJI Phantom 2 Vision+ Manufacturer’s User Manual

E

– Link to DJI Inspire 1 Manufacturer’s User Manual F _ Link to DJI Matrice 1 00 Manufacturer’s User Manual

APPENDIX

– A DJI PHANTOM 2 VISION+/PHANTOM 3 TECHNICAL SPECIFICATIONS Ohio Special Response Team utilizes safe and reliable sUASs. DJI is an industry leader in small UAS production. DJI UASs are loaded with ground breaking so ftware enabling the user to set parameters which will not allow flight into controlled airspace . Par ameters can also be set to limit flight to no higher than a predetermined and set altitude as well as limit fli ght to a predetermined and set distance. In addition, DJI software provides real

- time altitude and location information to the PIC via the linked monitor (smart phone/tablet devices) 1.1 DJI Phantom 2 Vision+/Phantom 3

. 1.1.1 Aircraft 1.1.1.1 Supported Battery

– DJI 5200mAH LiPo Battery 1.1.1.2 Weight (Battery & Propellers Include d)

– 2lbs 43 oz (1242g) 1.1.1.3 Hover Accuracy (Ready to Fly)

– Verti cal: .8m; Horizontal: 2.5m 1.1.1.4 Max Yaw Angular Velocity

- 2000/s 1.1.1.5 Max Tilt Angel

- 350 1.1.1.6 Max Ascent Speed

– 6m/s11

1.1.1.7 Max Descent Speed

– 2m/s 1.1.1.8 Max Flight Speed

– 15m/s (NOT RECOMMENDED)

1.1.2 Gimbal 1.1.2.1 Working Current

– St atic: 750mA; Dynamic: 900mA 1.1.2.2 Control Accuracy

- ±0.030 1.1.2.3 Controllable Range

– Pitch:

- 900

- 00 1.1.2.4 Maximum Angular Speed

– Pitch: 900/s

1.1.3 Camera 1.1.3.1 Operating Temperature Range

- 320F

- 1040F (00C

- 400C)
1.1.3.2 Sensor Size

– 1/2 .3”
1.1.3.3 Effective Pixels

– 14M 1.1.3.4 Resolution

– 4384x3288 4.1.3.5 HD Video Recording

– 1080p30 & 7 20p 4.1.3.6 Recording Field of
View

- 1100/850

1.1.4 Transmitter 1.1.4.1 Operating Frequency

– 5.728GHz

– 5.85GHz
1.1.4.2 Communication Distance (unobstructed)

– FCC Compliance: 800m 1.1.4.3 Receiver Sensitivity (1%PER)

- - 93dBm
1.1.4.4 Transmitter Power

– FCC Compliance: 100mW 1.1.4.5 Working Voltage

– 120mA@3.7V

1.1.5 Range Extender 1.1.5.1 Operating Frequency

– 2412

- 2462MHz
1.1.5.2 Communicatio n Distance (unobstructed)

– 500

- 700m
1.1.5.3 Transmitter Power

– 20dBm 1.1.5.4 Power Consumption

– 2W

APPENDIX

– B
DJI INSPIRE 1 TECHNICAL SPECIFICATIONS Ohio Special Response Team utilizes safe and reliable UASs. DJI is an industry leader in small UAS production. DJI UASs are loaded with ground breaking so ftware enabling the user to set parameters which will not allow flight into controlled airspace . Parameters can also be set to limit flight to no higher than a predetermined and set altitu de as wel l as limit flight to a predetermined and set distance. In addition, DJI software provides real

- time altitude and locati on information to the PI C via the linked monitor (smart phone/tablet devices)

2.2 DJI Inspire 1 2.2.1 Aircraft
2.2.1.1 Model

– T600
2.2. 1.2 Weight (Battery Included)

– 6lbs 103 oz (2935g) 2.2.1.3 Hovering Accuracy (GPS Mode)

– Vertical: 0.5m; Horizontal: 2.5m 2.2.1.4 Max Angular Velocity

– Pitch: 3000/s; Yaw: 1500/s 2.2.1.5 Max Tilt Angle

- 350 2.2.1.6 Max Ascent Speed

– 5m/s

2.2.1.7 Max De scent Speed

– 4m/s12

2.2.1.8 Max Speed

– 22m/s (ATTI mode, no wind

– NOT RECOMMENDED) 2.2.1.9 Max Flight Altitude

– 4500m
2.2.1.10 Max Wind Resistance

– 10m/s 2.2.1.11 Max Flight Time

– Approximately 20 minutes
2.2.1.12 Motor Model

– DJI 3510
2.2.1.13 Propeller Model

– DJI 1345 2.2.1.14 Operating Temperature Range

– 140F to 1040F (

- 100C to 400C) 2.2.1.15 Dimensions

– 17 1⁄4” x 17 3⁄4” x 12”

2.2.2 Gimbal
2.2.2.1 Model

– ZENMUSE X3 2.2.2.2 Output Power (with camera)

– Static: 9W; In Motion: 11W
2.2.2.3 O perating Current

– Static: 750mA; In Motion: 900mA 2.2.2.4 Angular Vibration Range

- ±0.030 2.2.2.5 Mounting

– Detachable 2.2.2.6 Controllable Range

– Pitch:

- 900 to +300; Pan: ±3200 2.2.2.7 Mechanical Range

– Pitch:

- 1250 to 450; Pan: ±3300
2.2.2.8 Max Co ntrollable Speed

– Pitch: 1200/s; Pan: 1800/s

2.2.3 Camera
2.2.3.1 Name

– X3 2.2.3.2 Model

– FC350 2.2.3.3 Total Pixels

– 12.76M 2.2.3.4 Effective Pixels

– 12.4M 2.2.3.5 Image Max Size

– 4000x3000 2.2.3.6 ISO Range

– 100

- 3200 2.2.3.7 Field of View

- 940
2 .2.3.8 CMOS

– Sony EXMOR 1/2.3”
2.2.3.9 HD Video Record ing

– UHD(4K): 4096x2160p24/25, 3840x2160p24/25/30; FHD: 1920x1080p225/ 30/48/50/60; HD: 1280x720p24/25/30/48/50/60 2.2.3.10 Operating Temperature Range

- 320F

- 1040F (00C

- 400C)

2.2.4 Transmitter
2.2.4.1 Name

– C1 2.2.4.2 Operating Frequency

– 5.728

- 5.850GHz; 2.400

- 2.483GHz 2.2.4.3 Communicating Distance (unobstructed)

– 2000m 2.2.4.4 Output Power

– 9W 2.2.4.5 Operating Temperature Range

- 140F to 1040F (

- 100C to 400C) 2.2.4.6 Battery

– 600mAh LiPo 2S

APPENDIX

– C
DJI Matrice 100 TECHNICAL SPECIFICATIONS Ohio Special Response Team utilizes safe and reliable UASs. DJI is an industry leader in small UAS production. DJI UASs are loaded with ground breaking software enabling the user to set param eters which will not allow flight into controlled airspace. Parameters can also be set to limit flight to no higher than a predetermined and set altitude as well as limit flight to a predetermined and set distance. In13

addition, DJI software provides real

- t ime altitude and location information to the PIC via the linked monitor (smart phone/tablet devices)

2.2 DJI Matrice
2.2.1 Aircraft
2.2.1.1 Model

– 100 2.2.1.2 Weight (Battery Included)

– 5 lbs/ 87 oz (2431 g) 2.2.1.3 Hovering Accuracy (GPS Mode)

– Vertica l: 0.5m; Horizontal: 2.5m 2.2.1.4 Max Angular Velocity

– Pitch: 3000/s; Yaw: 1500/s 2.2.1.5 Max Tilt Angle

- 350 2.2.1.6 Max Ascent Speed

– 5m/s 2.2.1.7 Max Descent Speed

– 4m/s 2.2.1.8 Max Speed

– 22m/s (ATTI mode, no wind

– NOT RECOMMENDED)
2.2.1.9 Max Flight Altitude

– 4500m
2.2.1.10 Max Wind Resistance

– 10m/s

2.2.1.11 Ma x Flight Time

– Approximately 45 minutes
2.2.1.12 Motor Model

– DJI 3510 2.2.1.13 Propeller Model

– DJI 1345 2.2.1.14 Operating Temperature Range

– 140F to 1040F (

- 100C to 400C) 2.2.1. 15 Dimensions

– 17 1⁄4” x
17 3⁄4” x 12”

2.2.2 Gimbal
2.2.2.1 Model

– ZENMUSE X3 2.2.2.2 Output Power (with camera)

– Static: 9W; In Motion: 11W 2.2.2.3 Operating Current

– Static: 750mA; In Motion: 900mA 2.2.2.4 Angular Vibration Range

- ±0.030
2.2.2.5 Mo unting

– Detachable 2.2.2.6 Controllable Range

– Pitch:

- 900 to +300; Pan: ±3200 2.2.2.7 Mechanical Range

– Pitch:

- 1250 to 450; Pan: ±3300 2.2.2.8 Max Controllable Speed

– Pitch: 1200/s; Pan: 1800/s

2.2.3 Camera
2.2.3.1 Name

– X3 2.2.3.2 Model

– FC350
2. 2.3.3 Total Pixels

– 12.76M 2.2.3.4 Effective Pixels

– 12.4M 2.2.3.5 Image Max Size

– 4000x3000 2.2.3.6 ISO Range

– 100

- 3200 2.2.3.7 Field of View

- 940
2.2.3.8 CMOS

– Sony EXMOR 1/2.3” 2.2.3.9 HD Video Recording

– UHD(4K): 4096x2160p24/25, 3840x2160p24/25 /30; FHD:1920x1080p225/ 30/48/50/60; HD: 1280x720p24/25/30/48/50/60 2.2.3.10 Operating Temperature Range

- 320F

- 1040F (00C

- 400C)

2.2.4 Transmitter
2.2.4.1 Name

– C1 2.2.4.2 Operating Frequency

– 5.728

- 5.850GHz; 2.400

- 2.483GHz 2.2.4.3 Communicating Distance (unobstructed)

– 2000m 2.2.4.4 Output Power

– 9W 2.2.4.5 Operating Temperature Range

- 140F to 1040F (

- 100C to 400C)14

2.2.4.6 Battery

– 600mAh LiPo 2S

APPENDIX

- D DJI Phantom 2 Vision+ Manufacturer’s User Manual http://download.djiinnovations.com/downloads/phantom_2_vision_plus/en/Phantom_2_Vision_Plus_User _Manual_v1.8_en.pdf

APPENDI X

– E DJI Inspire 1 Manufacturer’s User Manual http://download.djiinnovations.com/downloads/inspire_1/en/Inspire_1_User_Manual_v1.0_en.pdf

AOOEND IX

– F
DJI Matrice 100 Manufacture’s User Manual http://download.dji

- innovations.com/downloads/dev/Matrice/en/M100_User_Manual_v1.4__en.pdf