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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 Reform 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 C.F.R. Part 11, Advance Aviation Solutions LLC, seeks an exemption from Federal Aviation Regulations (“FARs”) detailed below for the DJI Phantom 2 Vision+, DJ I Phantom 2, DJI Inspire 1, DJI S1000+, and DJI S900

.

The requested exemption would support an application for a commercial Certificate of

Authorization (COA) to use th e system to support ; crewmember training, aerial surveying, aerial photography, agri culture, wildlife and forestry monitoring, wild land firefighting support, patrolling, aerial inspection, real estate surveying, and mapping operations. By approving these exemptions, the FAA will create benefits to industries benefiting from applications of using

multi

- rotor UA Systems and the environment which are ultimately in the public interest. 1

Each DJI UAS weighs less than 55 lbs. fully loaded, will be operated at a speed no more than 87 knots, carry neither a pilot nor passenger, carry no explo sive materials or flammable liquids, and operate exclusively within an approved COA airspace. All DJI UA Systems use a radio frequency spectrum for operation and control that complies with Federal Communications Commission (“FCC”) requirements and has int egrated safety features as described within user manuals for each DJI UAS. The UAS are equipped with redundant safety mechanisms allowing them to operate safely after experiencing certain

- flight failures. If a lost

- link event occurs, including the loss o f ground communications and/or the loss of a GPS signal, the UAS have the ability to perform a pre

- coordinated, predictable, automated flight maneuver and return to a predetermined location within a designated security parameter for landing. The UAS furth er have the ability to abort a flight in the event of unpredicted obstacles or emergencies. The aircraft will be operated in the field with both a Pilot in Command (PIC) and a ground

- based Visual Observer (VO) in accordance with FAA Order 8900.1, vol. 16 " Unmanned Aircraft Systems" with the following additional restrictions:

- All operations will be conducted IAW the Air Traffic Organization (ATO) Certificate of Waiver or Authorization (COA).

- All UAS operations will remain clear of manned aviation operat ions and activities at all times.

- All operations will occur at altitudes no more than 400' AGL

- Operations will be operated over private property with the permission of the land owner

- The UAS will not be operated by a PIC from any moving device.

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- The aircraft will not be operated within 5 NM of an airport or heliport unless prior coordination with ATC or airport management is made.

- Operations will be limited to day, visual meteorological conditions

- Aircraft will remain within Visual Line of Sight of the PIC and VO at all times.

- While the aircraft is airborne, the VO will be positioned within voice distance to the PIC

The PIC and VO will meet the requirements outlined in FAA Order 8900.1, volume 16, chapter 4

. The PIC will hold at least a recreational or sport pilot certificate. Additionally, the PIC will perform maintenance on the system and will complete a course of maintenance instruction as part of their initial training. Due to the simplicity of the system, we do not anticipate the n eed for a supplemental pilot.

We submit that the combination of the aircraft's light weight, historically demonstrated flight performance, fully qualified flight crew and strict operation under the guidelines established in 8900.1, the FAA can have confid ence that the operation will have an equivalent or greater level of safety of manned aircraft performing the same mission.

The name and contact information of the applicant is :

Advanced Aviation Solutions

Attn: Stephen C. Edgar

Ph: 208

- 412

- 9651

Email: Steve @adavso.com

The regulations from which the exemption is requested are as follows:

- 14 CFR Part 21

- 14 CFR 91.203

- 14 CFR 45.23, 45.29

- 14 CFR 91.9

- 14 CFR 61.113, 61.133

- 14 CFR 91.109, 91.119

- 14 CFR 91.121, 91.151

- 14 CFR Subpart E (91.40 1

- 91.417)

- 14 CFR 91.103(b)

We 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 you require additional inform ation or clarification.

Sincerely,

Ronald E. Looney

Chief Pilot

Advanced Aviation Solutions3 of 6

Appendices: A. Exemption Request and Equivalent Level of Safety

B. Privacy Issues C. Safety Assessment

D. Maintenance Procedures

E. User Manuals F. Training Program G. Aviation ExperiencePROPRIETARY INFORMAT ION

- NOT FOR PUBLIC RELEA SE

Date: 20150 516 Revision: 1.0 Revision:1. 0
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PROPRIETARY INFORMATION

- NOT FOR PUBLIC RELEASE