1924 Barnwell Street
· Columbia, SC
· 29201 

## cds corporation

803

- 779

- 9237 “IT is our Passion.” Page 1 of 5 April 14 , 2015

CDS Corporation Kenny McLean
1924 Barnwell St reet Columbia, SC 29201 ( 803 ) 779

- 9237
Email: Kenny@CDSCorp.com

U.S. Department of Transportation

, Docket Management System West Building Ground Floor, Room W12

- 140 1200 New Jersey Ave., SE Washington, DC 20590

RE: Exemption Request Section 333 of the FAA Reform Act of 2012

Attachments: 1) DJI Phantom 2 Vision User Man ual

2 ) DJI Inspire 1 User Manual 3) Pulse Aero Vapor 55 Brochure

References: 1) FAA Exemption No. 11405, Regulatory Docket No. FAA

- 2015

- 0118 in the matter

of Bryan Cherry

2 ) FAA Exemption No. 11138, Regulatory Docket No. FAA

- 2014

- 0481 in the matter
of th e petition of DOUGLAS TRUDEAU

3 ) FAA Exemption No. 1 1136, Regulatory Docket No. FAA

- 2014

- 0508 in the matter of the petition of ADVANCED AVIATION SOLUTIONS LLC

4 ) FAA Exemption No. 11080 Regulatory Docket No. FAA

- 2014

- 0355 in the matter of the peti tion of FLYING CAM INC

Dear Sir or Madam,

In accordance with the FAA’s Guidelines for Submitting a Petition for Exemption under section 333 of the FAA Modernization and Reform Act of 2012 , I

, Kenny McLean

, petitioner, request exemption from the follo wing sections of Title 14, Code of Federal Regulations §§

61.113(a); 61.113(b); 91.119(c); 91.121; 91.151(a); 91.405(a); 91.407(a)(1); 91.409(a)(1); 91.409(a)(2); 91.417(a) & (b);

In order to operate small unmanned aircraft systems (UAS) commercially in airspace regulated by the Federal Aviation Administration (FAA) for the purposes of aerial photography, cinematography, photogrammetry , mapping, crop surveying, inspecti ons and other fl ight operations that could be performed safely and more cost effectively with the use of small UAS at low altitude within the U.S. national airspace system as compared to a manned aircraft. Operations will be performed only at the request of and with the a uthorization and permission of clients or their authorized agents in1924 Barnwell Street
· Columbia, SC
· 29201 

## cds corporation

803

- 779

- 9237 “IT is our Passion.” Page 2 of 5 order to facilitate commerce and raise awareness of the beneficial uses of small unmanned air systems. So long as such operations are conducted within and under the conditions outlined he rein or as may be established by the FAA as required by Section 333. The conditions identified and proposed by the petitioner are drawn from references 1 3.

The FARs

The petitioner seeks exemption from the above mentioned FARs for the following reasons;

6 1.113(a) & (b); The petitioner requests relief in order to facilitate the utilization of pilots, who hold a PRIVATE PILOT (or greater) certificate. Any pilots operating under this exemption would be required to comply with any conditions as set forth and in a similar fashion to the previously granted exemptions.

91.119(c) As discussed in Exemption 11138 (DOUGLAS TRUDEAU), operations conducted closer than 500 feet to the ground may require that the UA be operated closer than 500 feet to essential persons, or objects that would not be possible without additional relief. The petitioner requests modification, waiver or exemption and clarification concerning the terms “congested areas” and “densely populated”. The petitioner requests waiver for this condition t o allow reasonable and responsible operations in areas of subdivisions and neighborhoods if required.

91.121 As discussed in Exemption 11138 (DOUGLAS TRUDEAU) is inapplicable since the UAS
does not have an altimeter and instead utilizes electronic GPS wit h a barometric sensor for altitude
information.

91.151(a) As discussed in Exemption 11136 (ADVANCED AVIATION SOLUTIONS LLC) prior relief has been granted for manned aircraft to operate at less than the prescribed minimums, including Exemption Nos. 2689, 5 745, and 10650. In addition, similar UAS specific relief has been granted in Exemption Nos. 8811, 10808, and 10673 for daytime, VFR conditions. The UAS provides battery power remaining as a percent age to the PIC. Information provided in the operating doc uments discusses procedures regarding remaining battery power management. Those documents contain a condition in which the PIC will initiate a landing procedure when battery remaining reaches a specified remaining level. Given the limitations on proposed operations and the location of those proposed operations, t he FAA found that a reduced minimum power reserve for flight in daytime
VFR conditions was reasonable.

91.405(a); 91.407(a)(1); 91.409 (a)(1) & (2); 91.417(a) & (b ) As discussed in Exem ption 11138 (DOUGLAS TRUDEAU), t he petitioner proposes to inspect and ensure that the UAS is in a condition for safe flight in accordance with the operating documents. The FAA found that adherence to the petitioner’s operating docume nts and the conditions and limitations specified, describing the requirements for maintenance, inspection, and recordkeeping, were sufficient to ensure that safety would not be adversely affected.

The UAS Systems

The DJI Phantom 2 V ision is a highly succes sful consumer grade small quadrotor in the quadcopter configuration with an advertised weight of less than 4 2 Ounces (12 00 g) designed primarily to carry aloft a high definition camera. It has an advertised maximum speed of less than1924 Barnwell Street
· Columbia, SC
· 29201 

## cds corporation

803

- 779

- 9237 “IT is our Passion.” Page 3 of 5 30 knots (15m/s) and a maximum climb rate of less than 1200 fpm (6 m/s). It is powered by four electric motors with a distance between motors of less than 14 inches (350mm) It utilizes an internal inertial measuring unit (IMU) with integrated barometric sensor augmented with glo bal positioning system (GPS) to maintain its geospatial orientation and position. It is controlled primarily through an FCC certified radio control (RC) unit. Real time video and telemetry information is transmitted back to a ground control station allowin g the operator and/or PIC to monitor battery level, GPS signal strength, altitude (AGL), distance from PIC, camera imagery, and control camera angle. It has failsafe modes of operation for either loss of RC or GPS signal. Altitude can be limited by the onb oard flight controller and maximum altitude can be preprogrammed by the PIC. Battery life limits flight times to approximately 25 minutes. The onboard flight controller will warn the pilot via telemetry and external lighting cues before reaching a low batt ery state. An automatic termination of flight and landing will be initiated when the battery reaches a predetermined low state. It is anticipated that flights will usually last less than 20 minutes. More
information is available in attachment 1 or http://www.dji.com/product/phantom

- 2

- vision/spec

.
The DJI Inspire 1 is a high end consumer grade small rotorcraft in the quadrotor configuration with an advertised weight of less than 103 Oun ces ( 2935 g) designed primarily to carry aloft a high definition camera. It has an advertised maximum speed of less than 40 knots ( 22 m/s) and a maximum climb rate of less than 1000 fpm ( 5 m/s). It is powered by four electric
motors with a distance between m o tors o f less than 18 inches (450 mm) It utilizes an internal inertial measuring unit (IMU) with integrated barometric sensor augmented with global positioning system (GPS) to maintain its geospatial orientation and position. It is controlled primarily thro ugh an FCC certified radio control (RC) unit. Real time video and telemetry information is transmitted back to a ground control station allowing the operator and/or PIC to monitor battery level, GPS signal strength, altitude (AGL), distance from PIC, and c amera imagery. It has failsafe modes of operation for either loss of RC or GPS signal. Altitude can be limited by the onboard flight controller and maximum altitude can be preprogrammed by the PIC. Battery life limits flight times to approximately 20 minu tes. The onboard flight controller will warn the pilot via telemetry and external lighting cues before reaching a low battery state. An automatic termination of flight and landing will be initiated when the battery reaches a predetermined low state. It is anticipated that flights will usually last less than 15 minutes. More information is available in attachment 2 or http://www.dji.com/product/inspire

- 1/spec

.
The Pulse Aero Vapor 55 is a battery powered, high end professional grade small rotorcraft
in the single rotor configuration with a maximum takeoff weight of less than 55 lbs and operational weight of 30 lbs ( 16k g) . The Vapor 55 is configured primarily to carry aloft various payload s including a high definition camera and LiDaR eqipment . It has an advertised cruise speed of 22 knots ( 12 m/s) with a maximum vertical speed of 394 fpm (2m/s)

. It is powered by electric motor with a two stage transmission and Lithium Polymer battery. It utilizes an multi axis internal inertial measuring unit (IMU) augmented wit h GPS/GLONASS to maintain precision geospatial orientation and position. It is controlled primarily through an FCC certified radio control (RC) unit. Real time telemetry information is transmitted back to a ground control station (GCS) allowing the operator and/or PIC to monitor battery level, GPS signal strength, alt itude (AGL), distance from PIC . It has failsafe modes of operation for either loss of RC or GPS signal. The Vapor 55 h as a n autorotate1924 Barnwell Street
· Columbia, SC
· 29201 

## cds corporation

803

- 779

- 9237 “IT is our Passion.” Page 4 of 5 feature that can engage in the event of a loss of motor drive that will allow for a controlled
descent. Battery life limits flight times to approximately 60 minutes. The onboard flight controller will warn the pilot via telemetry before reaching a low battery state. It is anticipated that flights will usually last less than 4 0 minutes. More information is available in attachment 3 or http://pulseaero.com/products/vapor

- helicopter

- uas.php

. Risk mitigation

The petitioner has reviewed FAA exemptions reference’s 1 3 Conditions and Limitations section and believes that the procedures specified therein are reasonable and will be utilized in order to manage and mitigate risk and ensure public safety. A preflight checklist will be utilized to ensure that the UA airworthiness will be verified before launch. Airworthiness will be maintained by performance of routine inspections before each flight, maintaining flight and maintenance logs. The petitioner request that in a manner similar to reference 4 , he be allowed to operate within 5 miles of an airpo rt provided that;

“ The UA may not operate in Class B, C, or D airspace without written approval from the FAA. The UA may not operate within 5 nautical miles of the geographic center of a nontowered airport as denoted on a current FAA published aeronautic al chart unless a letter of agreement with that airport’s management is obtained, and the operation is conducted in accordance with a NOTAM as required by the operator’s
COA. The letter of agreement with the airport management must be made available
to the Administrator upon request .”

Operations within 5 miles of an airport are not anticipated to be routine but the petitioner is requesting a mechanism to facilitate such activities without requesting a new and separate exemption(s) should the need arise. Op erations within class B airspace are not requested due to the lack of mode C transponder.

Public interest

Use of the UAS in lieu of a manned aircraft would enhance safety and reduce the environmental impact as compared to similar operations conducted with manned aircraft of greater proportions, carrying a crew and flammable fuel. Additionally, use of the UAS i n order to facilitate commerce could lead to economic growth. Operations for this petition will enable service for property owners or their designees seeking an enhanced perspective for characteristics, amenities, and benefits of their desired photographic subjects that cannot be displayed through ground level videography/photography. Aerial photography is a valuable marketing tool that can lead to increased commerce and enhance personal photography. Crop surveying applications could
lead to decreased use o f pesticides and fertilizer and conservation of water as well as increased crop yields and decreased costs. Aerial surveying and inspections can increase work site efficiency, improve volumetric estimations and reduce risks. The petitioner will provide cli ents with photographic data for these purposes on a ‘for hire’ basis acting as an independent contractor. A visual observer will be utilized. Liability insurance will be maintained. Flight data including UA S flight time , incident, accident, and details co ncerning any deviations from normal operations will be1924 Barnwell Street
· Columbia, SC
· 29201 

## cds corporation

803

- 779

- 9237 “IT is our Passion.” Page 5 of 5 available to FAA for use in collecting data regarding the use of UAS as part of this application. This data may be submitted to FAA if requested.

Conclusion

The petitioner is requesting this exemption for the purposes of aerial photography, cinematography, photogrammetry , mapping, crop surveying, inspecti ons and other flight operations . The petitioner's business model is based on the idea of offering information processing
and management solutions whic h are enhanced by utilization of UAV systems

. The petitioner’s market research shows pent up demand for these services currently exists in the mining, stockpile management, right

- of

- way management, agriculture and new markets that are emerg ing

. The prima ry purpose of seeking this exemption is to expand the business capability to offer the above services while remaining in compliance. The petitioner has over 50 hours of experience in the UA V
models listed herein, over 30 years experience in general and hol ds a Private Pilot airman
certificate.

Respectfully submitted,

Kenny McLean CDS Corporation

803

- 779

- 9237