Matthew Sloane Atlanta Drone Consultants, LLC 332 West Benson St. Decatur, GA 30030 (404) 723

- 5621 Info@AtlantaDroneConsultants.com August 10 , 2015 U.S. Department of Transportation Docket Management Sy stem 1200 New Jersey

Avenue SE Washington, DC 20590
**RE: Am**  **endment s**  **to Grant of Exemption No. 12299**  **Atlanta Drone Consultants, LLC Regulatory Docket No. FAA** 
**- 2015** 
**- 0849**  Dear Sir or Madam, On August 4, 2015 the Federal Aviation Administration (“FAA”) granted an exemption from certain provisions of the Federal Aviation Regulations (“FAR”) pursuant to Section 333 of Public L aw 112

- 95 to petitioner Atlanta Drone Consultants, LL C (“A DC”) permitting operation by ADC of a DJ I Inspire 1 small unmanned aerial sy stem (“UAS”) for the purposes of closed

- set film and television video production. Please see Grant of Exemption No. 12299 (the “Grant of Exemption”) and ADC’s petition for exempti on, docket no. FAA

- 2015

- 0849 , the terms of both are incorporated herein by reference. ADC now submits this request to amend the Grant of Exemption as follows: a) To supplement the Grant of Exemption to permit the operation of three additional small UAS , an d b) To expand the scope of the Grant of Exemption to permit operation of covered small unmanned aerial s ys tems in the field of news gathering photography and videography , mapping an d surveying, and industrial and agricultural inspection. All of the additional unmanned aerial s ys tems covered b y this requested amendment are of the same make and general mode of operation as those covered b y the Grant of Exemption and all qualify

as small UAS weighing less than 50 pounds. The proposed addition al scope of operations will be subject to procedures and safeguards substantially identical to those applicable to the scope of operations permitted under the Grant of Exemption. Details of each requested amendment and the terms and condition s for each are are set forth in more detail below. Additional Aircraft ADC requests amendment of the Grant of Exemption to permit the operation of three additional UAS. Each proposed UAS is under 45 pounds , wi ll be flown at all times under 3 00 feet AGL as measured b y the UA S’ on

- board GPS sy stem, will be kept within line of sight of the Pilot in Command (“PI C”) , will have a separate safety Visual O bserver (“VO”) at all times in communication with and within 5 feet of the PIC, will be flown at all times at speeds of 40 miles per hour or less , will be flown at all times during daylight hours , alway s using Visual Flight Rules (“VFR”) and within visual line of sight (“VLOS”) , and never using first person view bythe PI C . The PI C will be able to use human vision unaided by an y device other than corrective lenses as specified b y a current state

- issued driver ’ s license . The PIC will provide the local Flight Standards District Office (“FSDO”) with notice of all of flight operati ons no less than 72 hours in advance of an y i ntended flight. Each PI C will have over 400 hours of logged flight experience in the same UAS ty pe or model, including 10 take offs and landings within the prior 30 day s . The PI C will conduct a f ull and comple te inspection of aircraft prior to the initial takeoff of each flight. The make, model, and type of the proposed additional UAS are as follows:
**Make Model**  **Weight (lbs.) Description**  DJI Matrice 100 (M100) 5.35 Electric Quadcopter DJI Spreading Wings S1000 9.25 Electric Octocopter DJI Phantom 3 Professional 2.82 Electric Quadcopter Operational parameters applicable to all UAS’ are set forth ADC’s petition for the Grant of Exemption

. ADC will provide operator manuals for all three proposed additional UAS together with this request for amendment.
Additional Scope of Use ADC requests amendment of the Grant of Exemption to permit use of the listed small UAS to permit their use for the purposes of news gathering photograph y and videograph y, mapping and surveying, and industrial and agricultural inspection. The public benefits of a grant of exemption for these uses are evident from the Grant of Exemption. Regular helicopters are, excep t as provided in Section 91.119, not allowed to fly less than 500 feet AGL. UAS on the other hand are best when flown between 50 and 300 feet AGL and in fact the best video quality is 50 to 100 feet. A large manned helicopter could also cause very seriou s damage to persons or property on the ground and even to pilots and passengers inside a manned helicopter. A UAS weighing in at approximately six pounds would not be nearl y as hazardous. Additionally , a regular helicopter is normally larger than a stand ard automobile whereas the UAS is significantly smaller, in this case weighing less than ten pounds . It is substantially safer for the public to have a UAS accomplish the job of aerial imaging, photography , and videography than a manned helicopter just ba sed on size alone. For the purposes of news gathering, UAS may be an exceptional tool for journalists and all manner of news gathering and reporting media, to serve the public good in enhancing accurate dissemination of newsworth y and relevant informatio n to interested citizens. When employed to conduct tower, pipeline, and industrial inspections, UAS permits workers to avoid dangerous or precarious hazards or ph ys ical positions involving high risk of injury . UAS enable safe inspection of difficult to r each or environmentally sensitive locations without the use of heav y trucks, cranes, booms or other equipment requiring greater expense or attendant undesirable environmental impact.
Proposed Operational ParametersThe PI C will follow the manufacturer’s UAS aircraft/component, maintenance, overhaul,

replacement, inspection, and life limit requirements. When unavailable, aircraft maintenance/component/overhaul, replacement, and inspection/maintenance requirements will be established and identified in the operator’s manual. At a minimum, the following w ill be included in the operator’s manual:
1. Actuators / Servos 2. Transmission (single rotor) 3. Powerplant (motors) 4. Propellers 5. Electronic speed controller 6. Batteries 7. Mechanical dy

namic components (single rotor) 8. Remote command and control 9. Ground control station (if used) 10. Any other components as determined by the operator Prior to each flight the PIC will inspect the UAS to ensure it is in a condition for safe flight. If the inspection reveals a condition that affects the safe operation of the UAS, the aircraft will be prohibited from operating until the necessary maintenance has been performed and the UAS is found to be in a condition for safe flight. The Ground Control Station, if utilized, will be included in the preflight inspection. All maintenance and alterations will be properl y documented in the aircraft records. Any UAS that has undergone maintenance or alterations that affect the UAS oper ation or flight ch aracteristics ( e.g. replacement of a flight critical component) will undergo a functional test flight in accordance with the operator’s manual. The PI C who conducts the functional test flight will make an entry

in the UAS aircraft records of the flight. Th e requirements and procedures for a functional test flight and aircraft record entry must be added to the operator’s manual. Prior to operations conducted for the purpose of motion picture filming (or similar operations), the PIC must have accumulated an d logged, in a manner consistent with 14 CFR § 61.51 (b), a minimum of five hours as a UAS pilot operating the make and model of UAS to be utilized for operations under the exemption and three take

- offs and three landings in the preceding 90 day s. Training , proficiency , experience

- building, and take

- off and landing currency flights can be conducted under this grant of exemption to accomplish the required flight time and 90 day currency . During training, proficiency , experience

- building, and take

- off and lan ding currency flights all persons not essential for flight operations are considered non

- participants, and the PI C must operate the UA with appropriate distance from non

- participants in accordance with 14 CFR § 91.119. Prior to any

flight operations authorized by this grant of exemption, the PIC and VO must have successfull y completed a qualification process, as outlined in the operator’s manual. As this is a requirement stipulated by the operator, the test must be developed and implemented by aqualifie d person designated at the sole discretion of the operator. A record of completion of this

qualification process must be documented and made available to the Administrator of the FAA (the “Administrator”) upon request. Prior to operations , a flight demo nstration, administer ed b y an operator

- approved and qualified pilot must be successfull y completed and documented. This documentation must be available for review upon request b y the Administrator. Because the knowledge and airmanship test qualifications h ave been developed b y the operator, and there are no established practical test standards that support a jurisdictional FAA FSDO evaluation and approval of company designated examiners, the petitioner will conduct these tests in accordance with the operato r’s manual. The UAS will not be operated directly over an y person, except authorized and consenting production personnel, below an altitude that is hazardous to persons or property on the surface in the event of a UAS failure or emergency

. Regarding the distance from participating persons, the operator’s manual has safety mitigations for authorized and consenting personnel. At all times, those persons must be essential to the purposes of the instant flight . Because these procedures are speci fic to participating persons, no further FSDO or Aviation Safety Inspector ( “ ASI ” ) approval is necessary for reductions to the distances specified in the petitioner’s manuals. Regarding distance from non

- participating persons, the operator will ensure th at no persons are allowed within 500 feet of the area except those consenting to be involved and necessary for purposes of the instant flight . This provision may be reduced to no less than 200 feet if it would not adversely affect safety . For example, an e quivalent level of safety may be determined b y an aviation safety inspector’s evaluation of the filming production area to note terrain features, obstructions, buildings, safety barriers, etc. Such barriers may protect non

participating persons ( e.g. obser vers, the public, news media) from debris in the event of an accident. If the UAS loses communications or loses its GPS signal, the UA S must return to a pre

determined location within the security perimeter and land or be recovered in accordance with th e operator’s manual. The proposed additional UAS’, as well as the UAS covered b y the Grant of Exemption, are designed to increase altitude 20 meters or 60 feet upon loss of signal between the ground controller held by the pilot and the aircraft itself. Upo n reaching the higher altitude (a safety feature to avoid people, trees and buildings), the UAS will return to its original take

- off point of origin and slowly land. It is critically

important for the pilot to calibrate the aircraft prior to its flight. Th e calibration procedure sets the compass and lets the aircrafts onboard computer know where it is located on E arth. The UAS also has a F ly trex black box system installed which tracks every

flight so if a loss of link to the aircraft from the controller ever occurs, then the pilot can follow and retrieve the UAS when it lands. Additional details concerning lost

- link failsafes can be found in the Operator’s Manual s
. The PI C will abort the flight in the event of unpredicted obstacles or emergencies in accordance with the operator’s manual.Each UAS operation must be completed within 30 minutes flight time or with 25%

battery power remaining, whi chever occurs first. The PI C will request a Notice to Airmen (“NOTAM”) not more than 72 and not less than 48 hours prior to the operation. The operator will develop procedures to document and maintain a record of the UAS maintenance, preventative maintenance, alterations, status of replacement/overhaul component parts, and the total time in service of the UAS. These procedures will be added to the operator’s manual. Each UAS operated under this exemption will comply with all manufacturer Safety Bulle tins. The operator must develop UAS technician qualification criteria. These criteria must be added to the operator’s manual. The preflight inspection section in the operator’s manual must be amended to include the following requirement: The preflight i nspection must account for all discrepancies, i.e. inoperable components, items, or equipment, not covered in the relevant preflight inspection sections of the operator’s manual. Before conducting operations, the radio frequency spectrum used for operati on and control of the UA S must comply with the Federal Communications Commission ( “ FCC ” ) or other appropriate government oversight agency requirements. At least three days before scheduled filming, the operator of the UAS affected by this exemption must submit a written Plan of Activities to the local FSDO with jurisdiction over the area of proposed filming. The 3

- day notification may

be waived with the concurrence of the FSDO. The plan of activities must include at least the following:

a. Dates and times for all flights b. Name and phone number of the operator for the UAS filming production conducted under this grant of exemption c. Name and phone number of the person responsible for the on

- scene operation of the UAS d. Make, model, and serial or N

- number of UAS to be used e. Name and certificate number of UAS PI Cs involved in the filming production event f. A statement that the operator has obtained permission from property owners and/or local officials to conduct the filming prod uction event; the list of those who gave permission must be made available to the inspector upon request.g. Signature of exemption

- holder or representative

The documents required under 14 CFR § 91.9 and § 91.203 will be available to the PI C at the gro und control station of the UAS any time the aircraft is operating. These documents must be made available to the Administrator or any law enforcement official upon request. The UA S will remain clear and yi eld the right of way to all other manned operatio ns and activities at all times (including, but not limited to, ultralight vehicles, parachute activities, parasailing activities, hang gliders, etc.). UAS operations will not be conducted during night, as defined in 14 CFR § 1.1. All operations will be co nducted under visual meteorological conditions ( “ VMC ” ). Flights under special visual flight rules ( “ SVFR ” ) are not authorized. The UAS will be operated by the PIC from any

moving device or vehicle. The UA will not be operated less than 500 feet below o r less than 2,000 feet horizontally from a cloud or when visibility is less than 3 statute miles from the PI C. The UA will not operate in Class B, C, or D airspace without written approval from the FAA. The UA will not operate within 5 nautical miles of the geographic center of a non

- towered airport as denoted on a current FAA

- published aeronautical 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 b y the op erator’s COA. The letter of agreement with the airport management must be made available to the Administrator upon request. Any 1) incident, 2) accident, or 3) flight operation that transgresses the lateral or vertical boundaries of the operational area as defined b y the applicable COA must be reported to the FAA UAS Integration Office (AFS

- 80) within 24 hours. Such a ccidents must be reported to the National Transportation Safety Board ( “NTSB ” ) per instructions contained on the NTSB Web site: www.ntsb.gov. Further flight operations may not be conducted until the incident, accident, or transgression is reviewed b y AFS

- 80 and auth orization to resume operations is provided. Unless otherwise specified in this grant of exemption, the UAS, PI C, and operator must comply with all applicable parts of 14 CFR including, but not limited to, parts 45, 47, 61, and 91. The Federal Aviation A dministration by and through its authorized representative is requested to approve this petition for amendment to the Grant of Exemption previously granted to ADC. Respectfully

submitted:

Matthew Sloane