April 8, 2015

Exemption No. 11303 Regulatory Docket No. FAA

− 20 14

− 1019

Mr. Martin Lovelady

TradeCraft

, LLC

7090 Pale Down Place SE
Owens Cross Roads, AL 35763

Dear Mr. Lovelady :

This letter is to inform you that we have granted your request for exemption. It transmits our
decision, explains its basis, and gives you the conditions and limitations of the exemption, including the date it ends.

The Basis for Our Decision

By letter dated December 6, 2014 , you petitioned the Federal Aviation Administration (FAA)

on behalf of TradeCraft

, LLC ( hereinafter petitioner or operator ) for an exemption

. The exemption would all ow the petitioner to operate an unmanned ai rcraft system (UAS) to

conduct agriculture, a erial surveying, and imagery operations

.

See Appendix A for the petition submitted to the FAA des cribing the proposed operations and

the regulations that the petitioner seeks an exemption

.

The FAA has determined that good cause exists for not publishing a summary of the petition in the Federal Register because the requested exemption would not set a precedent, and any delay in acting on this petition would be detrimental to the petitioner

.

Airworthiness Certification

The UAS proposed by the petitioner is a DJI Inspire 1

.2

The petitioner requested relief from 14 CFR part 21, C ertification procedures for products and parts, Subpart H

— Airworthiness Certificates . In accordance with the statutory criteria provided in Section 333 of P ublic Law 112

− 95 in reference to 49 U

. S

. C

. § 44704, and in consideration of the size, weight, speed, and limited operating area associated with the

aircraft and its operation, the Secretary of Transportation has determined that this aircraft meets the conditions of Section 333. Therefore, the FAA finds that the requested relief from

14 CFR part 21, and a ny associated noise certification and testing requirements of part 36, is

not necessary.

The Basis for Our Decision

You have requested to use a UAS for aerial data collection . The FAA has issued grants of exemption in circumstances similar in all materia l respects to those presented in your petition. In Grants of Exemption No s

. 11062 to Astraeus Aerial ( see Docket No. FAA−2014−0352), 11109 to Clayco, Inc. ( see Docket No. FAA

− 2014

− 0507), 11112 to VDOS Global, LLC ( see Docket No. FAA−2014−0382), and 11213 to Aeryon Lab s , Inc. ( see Docket No. FAA−2014−0642), the FAA found that the enhanced safety achieved using an unmanned aircraft (UA) with the specifications described by the petitioner and carrying no passengers or
crew, rather than a manned aircraft of s ignificantly greater proportions, carrying crew in addition to flammable fuel, gives the FAA good cause to find that the UAS operation enabled by this exemption is in the public interest.

Having reviewed your reasons for requesting an exemption, I find that

—

• They are similar in all material respects to relief previously requested in Grant of Exemption Nos. 11062, 11109, 11112, and 11213 ;

• The reasons stated by the FAA for granting Exemption Nos. 11062, 11109, 11112, and

11213 also apply to the situation you present; and

• A grant of exemption is in the public interest.

Our Decision

In consideration of the foregoing, I find that a grant of exemption is in the public interest.
Therefore, pursuant to the authority contained in 49 U.S.C. 106(f), 40113, and 44701, delegated to me by the Administrator, TradeCraft

, LLC is granted an exemption from 14 CFR §§ 61.23(a) and ( c ), 61.101(e)(4 ) and (5), 61.113(a), 61.315(a) , 91.7(a), 91.119(c), 91.121, 91.151(a)(1), 91.405(a), 91.407(a)(1), 91.409(a)(1) and (2), and 91.417(a) and (b), to the extent necessary to allow the petitioner to operate a UAS to perform aerial data collection

. This exemption is subject to the conditions and limitations listed below.

Conditions and Limitations

In this grant of exemption, Trade Craft

, LLC is hereafter referred to as the operator.3

Failure to comply with any of the conditions and limitations of this grant of exemption will be grounds for the immediate suspension or rescission of this exemption.

1. Operations authorized by this grant of exemption are limited to the DJI Inspire 1 when weighing less than 55 pounds including payload. Proposed operations of any other aircraft will require a new petition or a petition to amend this exemption

.

2. Operations for the purpose of closed

- set motion picture and television filming are

not permitted.

3. The UA may not be operated at a speed exceeding 87 knots (100 miles per hour). The exemption holder may use either groundspeed or calibrated airspeed to determine

com pliance with the 87 knot speed restriction. In no case will the UA be operated at airspeeds greater than the maximum UA operating airspeed recommended by the

aircraft manufacturer.

4. The UA must be operated at an altitude of no more than 400 feet above gro und level (AGL). Altitude must be reported in feet AGL.

5. The UA must be operated within visual line of sight (VLOS) of the PIC at all times. This requires the PIC to be able to use human vision unaided by any device other than corrective lenses, as specifi ed on the PIC’s FAA

- issued airman medical certificate or

U.S. driver’s license.

6. All operations must utilize a visual observer (VO). The UA must be operated within the visual line of sight (VLOS) of the PIC and VO at all times. The VO may be used

to satisfy the VLOS requirement as long as the PIC always maintains VLOS capability. The VO and PIC must be able to communicate verbally at all times ;

e lectronic messaging or texting is not permitted during flight operations. The PIC must be designated before the flight and cannot transfer his or her designation for the duration of the flight. The PIC must ensure that the VO can perform the duties required of the VO.

7. This exemption and all documents needed to operate the UAS and conduct its operations in acc ordance with the conditions and limitations stated in this grant of exemption, are hereinafter referred to as the operating documents. The operating

documents must be accessible during UAS operations and made available to the Administrator upon request. I f a discrepancy exists between the conditions and limitations in this exemption and the procedures outlined in the operating documents, the conditions and limitations herein take precedence and must be followed. Otherwise, the operator must follow the pro cedures as outlined in its operating documents. The operator may update or revise its operating documents. It is the operator’s responsibility to track such revisions and present updated and revised documents to the Administrator or any law enforcement o fficial upon request. The4

operator must also present updated and revised documents if it petitions for extension or amendment to this grant of exemption. If the operator determines that any update or revision would affect the basis upon which the FAA gran ted this exemption, then the operator must petition for an amendment to its grant of exemption. The FAA’s UAS Integration Office (AFS

- 80) may be contacted if questions arise regarding updates or revisions to the operating documents.

8. Any UAS that has unde rgone maintenance or alterations that affect the UAS operation or flight characteristics, e.g. replacement of a flight critical component, must undergo a functional test flight prior to conducting further operations under this exemption.

Functional test f lights may only be conducted by a PIC with a VO and must remain at least 500 feet from other people. The functional test flight must be conducted in such a manner so as to not pose an undue hazard to persons and property.

9. The operator is responsible for maintaining and inspecting the UAS to ensure that it is in a condition for safe operation.

10. Prior to each flight, the PIC must conduct a pre

- flight inspection and determine the UAS is in a condition for safe flight. The pre

- flight inspection must account for all potential discrepancies, e.g. inoperable components, items, or equipment. If the inspection reveals a condition that affects the safe operation of the UAS, the aircraft is prohibited from operating until the necessary maintenance has been performed and the UAS is found to be in a condition for safe flight.

11. The operator must follow the UAS manufacturer’s maintenance, overhaul, replacement, inspection, and life limit requirements for the aircraft and aircraft

components.

12. Each UAS operated under this exemption must comply with all manufacturer safety

bulletins.

13. Under this grant of exemption, a PIC must hold either an airline transport, commercial, private, recreational, or sport pilot certificate. The PIC must also hold a

current FAA airman medical certificate or a valid U.S. driver’s license issued by a
state, the District of Col u mbia, Puerto Rico, a territory, a possession, or the Federal government. The PIC must also meet the flight revi ew requirements specified in

14 CFR § 61.56 in an aircraft in which the PIC is rated on his or her pilot certificate.

14. The operator may not permit any PIC to operate unless the PIC demonstrates the ability to safely operate the UAS in a manner consistent with how the UAS will be operated under this exemption, incl uding evasive and emergency maneuvers and maintaining appropriate distances from persons, vessels, vehicles and structures. PIC qualification flight hours and currency must be logged in a manner consistent with

14 CFR § 61.51(b). Flights for the purposes of training the operator’s PICs and VOs5

(training, proficiency, and experience

- building) and determining the PIC’s ability to safely operate the UAS in a manner consistent with how the UAS will be operated under this exemption are permitted under the term s of this exemption. However, training operations may only be conducted during dedicated training sessions. During training, proficiency, and experience

- building flights, all persons not essential for flight operations are considered nonparticipants, and the PIC must operate the UA with appropriate distance from nonparticipants in accordance with 14 CFR § 91.119.

15. UAS operations may not be conducted during night, as defined in 14 CFR § 1.1. All operations must be conducted under visual meteorological cond itions (VMC). Flights under special visual flight rules (SVFR) are not authorized.

16. The UA may not operate within 5 nautical miles of an airport reference point (ARP) as denoted in the current FAA Airport/Facility Directory (AFD) or for airports not

denote d with an ARP, the center of the airport symbol as denoted on the current FAA

published aeronautical chart, unless a letter of agreement with that airport’s management is obtained or otherwise permitted by a COA issued to the exemption

holder. The letter o f agreement with the airport management must be made available to the Administrator or any law enforcement official upon request.

17. The UA may not be operated less than 500 feet below or less than 2,000 feet horizontally from a cloud or when visibility is l ess than 3 statute miles from the PIC.

18. If the UAS loses communications or loses its GPS signal, the UA must return to a pre

determined location within the private or controlled

- access property.

19. The PIC must abort the flight in the event of unpredicted ob stacles or emergencies.

20. The PIC is prohibited from beginning a flight unless (considering wind and forecast weather conditions) there is enough available power for the UA to conduct the intended operation and to operate after that for at least five minutes or with the reserve power recommended by the manufacturer if greater.

21. Air Traffic Organization (ATO) Certificate of Waiver or Authorization (COA). All operations shall be conducted in accordance with an ATO

- issued COA. The exemption holder may a pply for a new or amended COA if it intends to conduct operations that cannot be conducted under the terms of the attached COA

.

22. All aircraft operated in accordance with this exemption must be identified by serial number, registered in accordance with 14 C FR part 47, and have identification (N

Number) markings in accordance with 14 CFR part 45, Subpart C. Markings must be as large as practicable.6

23. Documents used by the operator to ensure the safe operation and flight of the UAS and any documents required un der 14 CFR §§ 91.9 and 91.203 must be available to the PIC at the Ground 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.

24. The UA must r emain clear and give way to all manned aviation operations and

activities at all times.

25. The UAS may not be operated by the PIC from any moving device or vehicle.

26. All Flight operations must be conducted at least 500 feet from all nonparticipating

person s, vessels, vehicles, and structures unless:

a. Barriers or structures are present that sufficiently protect nonparticipating persons from the UA and/or debris in the event of an accident. The operator must ensure that nonparticipating persons remain under su ch protection. If a situation arises where nonparticipating persons leave such protection and are within 500 feet of the UA, flight operations must cease immediately in a manner ensuring the safety of nonparticipating persons ; and

b. The owner/controller of a ny vessels, vehicles or structures has granted permission for operating closer to those objects and the PIC has made a safety assessment of the risk of operating closer to those objects and determined that it does not present an undue hazard.

The PIC, VO, operator trainees or essential persons are not considered nonparticipating persons under this exemption.

27. All operations shall be conducted over private or controlled

- access property with permission from the property owner/controller or authorized represe ntative. Permission from property owner/controller or authorized representative will be obtained for each flight to be conducted.

28. Any incident, accident, or flight operation that transgresses the lateral or vertical boundaries of the operational area as d efined by the applicable COA must be reported to the FAA's UAS Integration Office (AFS

- 80) within 24 hours. Accidents must be reported to the National Transportation Safety Board (NTSB) per instructions

contained on the NTSB Web site: www.ntsb.gov

.

If this exemption permits operations for the purpose of closed

- set motion picture and television filming and production, the following additional conditions and limitations apply.

29. The operator must have a motion picture and t elevision operations manual (MPTOM) as documented in this grant of exemption.7

30. At least 3 days before aerial filming, the operator of the UAS affected by this exemption must submit a written Plan of Activities to the local Flight Standards

District Office (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 op erator for the UAS aerial filming 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 PICs involved in the aerial filming;

f. A statement that the operator has obtained permission from property owners and/or local officials to conduct the filming production event; the list of those who gave permission must be made available to the inspector upon r equest;

g. Signature of exemption holder or representative; and

h. A description of the flight activity, including maps or diagrams of any area, city, town, county, and/or state over which filming will be conducted and the altitudes essential to accomplish the o peration.

31. Flight operations may be conducted closer than 500 feet from participating persons consenting to be involved and necessary for the filming production, as specified in the exemption holder’s MPTOM.

Unless otherwise specified in this grant of exemption, the UAS, the UAS PIC, and the UAS operations must comply with all applicable parts of 14 CFR including, but not limited to, parts 45, 47, 61, and 91.

This exemption terminates on April 30, 2017 , unless sooner superseded or rescinded.

Sincerely,

/s/ John Barbagallo Acting Deputy Director, Flight Standards Servicewww.tradecraftuas.com 6 December 2014

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 Modernization and Reform

Act of 2012 and 14 C.F.R. Part 11

Dear Sir or Madam:

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (FMRA) and 14 C.F.R. Part 11, TradeCraft LLC requests exemptions from several provisions of the Federal Aviation Regulations (FAR), specifically portions of 14 C.F.R Parts 45, 61, and 91 to allow among other things, commercial operations of its DJI Inspire 1 small

Unmanned Aircraft S ystem (sUAS) in the Continental United States (CONUS) by

individuals who have FAA Commercial Rotorcraft I nstrument certificates a nd have completed TradeCra ft’s training program for commercial operation of sUAS.

The Inspire i s an electric powered rotary wing sUAS that is capable of transmitting live airborne video images and location information to a Ground Control Station (GCS). T he Inspire stores the photo graphs and data on board and makes them available for download after completion of the flight. The Inspire is 22 in x 22 in x 8 in and weighs

6.4 pounds, well under the 55 lbs mandated in the FMRA

. The Inspire can conduct hovering flight and has a maximu m cruising speed of 42 knots

. It is battery powered, has a flight endurance of 22 minutes and can operate in t emperatures ranging from 0°

to 40° C

. The Inspire ’s omni

- directional ante nna has a range of 2.1 km and operates in

the 2.420

– 2.483 GHz frequen cy range.

DJI is a leader in the sUAS rotorcraft market. There are thousands of DJI products being used in the recreational and hobby industry. T he Inspire can operate safely in the National Airspace System (NAS), without posing a threat to national secu rity, by operating in accordance with the requirements discussed herein. Additionally, TradeCraft will utilize commercial rated pilots with extensive sUAS experience that will

set them apart from most 333 applicants.

The Inspire ’s capabilities, along wit h TradeCraft personnel’s prior experience conducting s UAS training, maintenance, and operations within the Department of

Defense make it ideally suited to conduct commercial operations such as agriculture,Page 2

www.tradecraftuas.com aerial surveying, and aerial photography within Vi sual Line of Sight (VLOS). Use of the Inspire reduces the need to operate manned aircraft, decreasing the risk to the pilot

, crew, and those on the ground as the Inspire is carried to the area of operations and not

flown there.

As a result of the Inspire ’s size, weight, maximum speed, operational capability, and safety record the Inspire does not create a hazard to users of the NAS or the public. Neither does it pose a threat to national security. The petitioner states that, given the

clear direction in Section 333, the strong equivalent level of safety surrounding the proposed operations, and the significant public benefit, including enhanced safety, reduction in environmental impacts, including reduced emissions associated with allowing UAS. Therefore , the FAA should grant TradeCraft the requested exemptions. Alternatively, if the FAA finds that modification of TradeCraft application is required for safe operation of the Inspire in the NAS, TradeCraft requests that the FAA delineate the required modif ications and either process TradeCraft application as if the modifications were already made or allow TradeCraft to amend its application to incorporate the FAA’s findings.

The name and email address of the applicant are:

TradeCraft LLC

email: tradecraftuas@gmail.comPage 3

www.tradecraftuas.com Regulations from which the exemption is requested:

14 C.F.R Part 21 14 C.F.R. 45.23 (b ) 14 C.F.R. 91.7 (a) 14 C.F.R. 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 C.F.R. 91.151 (a) 14 C.F.R. 91.203 (a) & (b) 14 C.F.R. 91.405 (a) 14 C.F.R. 407 (a) (1) 14 C.F.R. 409 (a) (2) 14 C.F.R. 417 (a) & (b)

This e xemption application is expressly submitted to fulfill Congress goal in passing Section 333 (a) through (c) of the Reform Act. This law directs the Secretary of Transportation to consider whether certain unmanned aircraft systems may operate safely in the NAS before completion of the rulem aking required under section 332 of the Reform Act. In making this determination, the Secretary is required to determine which types of UAS do not create a hazard to users of the NAS or the public or pose a threat

to nat ional security in light of the following:

• The UAS size, weight, speed, and operational capability;

• Operation 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 determines that such vehicles “may operate in the national airspace system, the Secretary shall establish requirements for the safe operation of such aircraft in the national airspace system.” Id. §333(c) (emphasis adde d) 1

The FRMA 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 Ac t that includes sUAS, from the requirement that all civil aircr aft must

have a current airworthiness certificate.

The Administrator may grant an exemption from a requirement of a regulation prescribed under subsection (a) or (b) of this section or any sections 44702

- 44716 of

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

1 Applicant interprets this provision to place the duty on the Administrator to not only process applications for exemptions under section 333, but for the Administrator to craft conditions for the operation of the UAS, if it should be determined that the conditions set fourth herein do not fulfill the statutory requirements for approval.Page 4

www.tradecraftuas.com TradeCraft LLC sUAS are rotorcraft, weighing 55 lbs. or less, including payload. They operate under normal conditions at a spee d of no more than 50 knots and have the capability to hover and, move in the vertical and horizontal plane simultaneously. They will operate within line o f sight and will only operate under strict risk mitigation guidelines as outlined in the TradeCraft L LC Commercial sUAS Flight Oper ations Procedures (hereinafter “the Manual”) 2 . Such operations will insure that the sUAS will “not create a hazard to users of the national airspace system or the public” 3

Given the small size of the sUAS involved and the re stricted environment within which they will operate, the applicant falls squarely within the zone of safety (an equivalent level of safety) in which Congress envisioned that the FAA must, by exemption, allow commercial operations of UAS to commence immedia tely. Also, due to the size of the UAS and the areas in which the relevant sUAS will operate, approval of the application presents no national security issue. Given the clear direction in Section 333 of the Reform Act, the authority contained in the Fede ral Aviation Act as amended; the strong equivalent level of safety surrounding the proposed operations, and the significant public benefit, including enhanced safety, reduction in environmental impacts, including reduced emissions associated with allowing s UAS for commercial operations, the grant requested exemptions is in the public interest. Accordingly, the applicant respectfully requests that FAA grant the requested exemption without delay.

Airworthiness

The Inspire is safe and fit for operation in t he NAS under the conditions listed herein. In support of this application, TradeCraft LLC provide s the following documents, the Inspire Flight and Maintenance Manual and the TradeCraft LLC Commercial sUAS Flight Operations P rocedure s

.

2 Applicant provides this manual as a Confidential document under 14 C.F.R. 11.35 (b) as the entire

man ual contains proprietary information that the applicant has not and will not share with others. The manual contains operating conditions and procedures that are not available to the public and are protected from release under the Freedom of Information Ac t 5 USC 552 et.seq.

3 Reform Act Section 333 (b)Page 5

www.tradecraftuas.com Mandato ry Operating Conditions

TradeCraft LLC proposes that the grant of the exemption be subject to the following mandatory conditions which are based upon operating conditions set forth for operation

of s UAS for commercial use pursuant to Certificates of Waive r or Authorization, with

additional restrictions.

• Class III Flight Physical

• Air craft will not exceed 42 knots

• Aircraft to remain wit hin Visual Line of Sight (VLOS)

• Operations to occur during daylight hours

• Above Ground Level (AGL) altitu de to be restrict ed to 400 feet

• Pilot in Command wi ll file a NOTAM for each flight

Pilot Qualifications

Tradecraft proposes the following sUAS pilots:

Pilot in Command Qualifications Hours

Pilot 1

FAA Certificate: 3233322 FAA Commercial Instrument Rotary

W ing Army sUAS master trainer graduate Manned : 2683

Unmanned: 123 203 fixed wing launch/recovery 112 rotary wing launch/ recovery

Pilot 2

FAA Certificate: 3116078 FAA Commercial Instrument Rotary Wing Manned: 363

Aircraft Information and Emergency Procedures

T he Inspire is an inherently stable, lig htweight aircraft that weighs 6.4 lbs

. M oreover, although the aircraft can be configured to give the pilot full control of the aircraft and payload during flight, the Inspire has an advanced autopilot that flies the aircraft, managing altitude and flight path within the intended flight envelope at all times when the that flight mode is engaged. The autopilot limits maneuvering to simple airspeed, altitude, and turn rate changes. These limits are hard coded into the autopilot and define the aircraft’s normal flight operating envelope. The autopilot manages, pitch, roll, yaw and collective throttle to maintain target airspeed, target turn rate, and target altitude. All flight modes utilize GPS and in the event of uni ntended input the aircraft can be put into an operator controlled flight mode that allows for the aircraft to come to an immediate hover. Turn rates and airspeeds are limited by the autopilot and do not allow commands that are outside of the normal operat ing envelope.

Equally significant, the Inspire is comprised of composite materials, has energy absorbing landing gear that reduce damage in the event of a hard landing and is

com posed of carbon fiber and plastic components.Page 6

www.tradecraftuas.com The DJI inspire has additional safety features to facilitate safe integration into the NAS. The Inspire GCS software incorporates “Flight Restriction” areas around all B, C, and D airports. These flight restriction areas have different levels of notification, from warnings

on the Gro und Control Station, to altitude restrictions and finally not allowing the start of

the motors.

Another feature that is pilot defined, allows for altitude and distance limits to be set on the GCS. TradeCraft believes this is a key safety attribute that will allow seamless integration into the NAS and compliance with all FAA regulations.

The Inspire has three failsafe emergency procedures:

Loss of Communication: In the event the communication link with the operators ground control station is lost, the Inspire enters return to home mode after three seconds of

transmission loss. The aircraft climbs to a Pilot defined altitude based on obstacle height. It then returns to the home waypoint

, hovers for 15 seconds while trying to

establish connection. T h e aircraft conducts a controlled landing then shuts off the

motors if connection is not reestablished

.

Low Battery: The low battery e mergency procedure is triggered when the DJI smart battery is depleted to a point that may affect the safe return of th e aircraft; the P ilot in

Command will Land as Soon as Possible. The thresholds for these warnings are automatically determined based on the current aircraft altitude and its distance from the Home point.

Loss of GPS: A loss of GPS while in guidance mode will cause the aircraft to hover using the onboard altimeter

. This will allow the Pilot in Command to land the aircraft as soon as possible

. Additionally, the aircraft utilizes an “optical flow” sensor that uses ultrasonic and image data to help the airc raft identify its position. This allows for the

aircraft to hover when GPS is lost.Page 7

www.tradecraftuas.com Specific Exemption Requests and Equivalent Level of Safety Showings

14 C.F.R. § 45.23(b)

– Display of marks; general

The regulation requires:

When marks in clude 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 entra nce 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 c ertificate, an exemption may be needed as the UAS will have no entrance to the cabin, cockpit or pilot station on which the word “Restricted” can be place d as required by this provision. Two

- inch lettering also is not possible given the overall size of th e Inspire

. TradeCraft LLC , therefore, requests an exemption to display, with one

- inch lettering the word “Restricted” on the fuselage in compliance with §45.299(f).

The equivalent level of safety will be achieved by having the Inspire marked with one
inc h lettering on its fuselage because the pilot, observer, and others working with the
sUAS will have the identification of the aircraft as “Restricted”. The FAA has issued similar exemptions to this regulation, including to Pioneer Hi

- Bred International, I nc., Exemption No. 10810; Raytheon Missile Systems/Advanced Programs, Exemption Nos. 10167 and 8738; and Trimble Navigation Limited, Exemptions No. 10700 and
11042.

14 C.F.R. § 91.7 (a) and (b): Civil aircraft airworthiness

Sections 91.7 (a) and (b) pro hibit operation of a civil aircraft unless it is in airworthy
condition. TradeCraft LLC requests an exemption from this regulation because the Inspire would not operate with an airworthiness certificate under the proposal set forth in this filing. Given the size of the aircraft and requirements contained in the Manual for maintenance and use of safety check lists prior to each flight, as set f orth in in the operators manual, an equivalent level of safety will be provided.

14 C.F.R. § 91.109(a): Flight In struction

Section 91.109 (a) 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.

The Inspire is a remotely piloted aircraf t, and, by design, it does 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. Completing instruction through the TradeCraft t raining progr am will ensure an equivalent level of safety.

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 and 9862A.Page 8

www.tradecraftuas.com 14 C.F.R § 91.119 Minimum Safe Altitudes

Section 91.119 establishes safe altitudes for operation of civil aircraft. Specifically, Section 91.119 (c) limits aircraft flying over areas other than congested areas to an altitude of 500 feet above the surface, except over open water or sparsely populated areas. In those cases, the aircraft may not be operated closer than 500 feet to any person vessel, vehicle, or structure.

As set forth herein, the Inspire will never oper ate at higher than 400 feet AGL

. Beca use agriculture, ae rial survey work, and aerial imagery must be accomplished at relatively low altitudes, i.e. less than 500 feet AGL, an exemption from Section 91.119(c) is needed.

The equivalent level of safety will be achieved given the size, weight sp eed, and
material with which the Inspire is built. Also, no flight will be taken without the permission of the land owner or the party controlling the land. With advance notice to the landowner, all affected individuals will be aware of agriculture, surv ey, and aerial imagery . Compared to similar operations conducted with conventional aircraft or rotorcraft, which weigh thousand s of pounds and carry flammable fuel, any risk associated with these operations will be far less than those currently allowed wi th such conventional aircraft operating at or below 500 feet AGL.

14 C.F.R. § 91.151 (b): Fuel Requirements for Flight in VFR Conditions

Section 91.151 (b) prohibits an individual from beginning “a flight in a rotorcraft under VFR conditions unless (co nsidering wind and forecast weather conditions) there is enough fuel to fly to the first point of intended landing and, assuming normal cruising speed, to fly after that for at least 20 minutes.

The Inspire ’s battery provides 22 minutes of powered flight. Without an exemption from 14 C.F.R. §91.151, the Inspire ’s f li ghts would only be allowed to fly for 2 minutes

. Given the limitations on its proposed operations and the location of those proposed operations, a lesser reserve for flight in VFR conditions is reasonable.

TradeCraft LLC believes that an exemption from 14 C.F.R. § 91.151 (a) is safe and consistent with the scope of a prior exemption. See Exemption 10673 (allowing Lockheed Martin Corporation to operate without compliance with 91.151 (a)). Op erating the Inspire s UAS without 20 minutes of reserve fuel does not engender the type of risks that Section 91.151 (a) was meant to prevent. Given its weight and construction material, the risks are less the n contemplated by the current regulation.

Trad eCraft LLC believes that an equivalent level of safety c an be achieved by maintaining 3 minutes of reserve fuel, which, allowing 19 minutes of flight time, would be more than adequate to return the UAS to its planned landing zone from anywhere
in its visua l line of s ite operating area.

Similar exemptions have been granted to others, including Exemptions 2689F, 5745, 10673, and 10808.Page 9

www.tradecraftuas.com 14 C.F.R § 91.405 (a); 91.407 (a) (1); 91.409 (a) (2); 91.417 (a): Maintenance inspections

Section 91.405 (a) requires that an aircraft operator or owner “[s]hall have that aircraft inspect as prescribed in subpart E of this part and shall between required inspections, excepts as provided in paragraph (c) of this section, have discrepancies repaired as prescribed in part 43 of this chapter.” Section 91.407 similarly makes reference to requirements in Part 43; Section 91.409 (a) (2) requires an annual inspection for issuance of an air worthiness certificate. Section 91.417 (a) requires that an owner or operator keep records sh owing certain maintenance work that has been accomplished by certificated mechanics, under Part 43, or licensed pilots and records of approval of
the aircraft for return to service.

Maintenance of the Inspire 1 will be accomplished by TradeCraft LLC pilot s pursuant to the manuals provided by DJI . An equivalent level of safety will be achieved
because the Inspire is small in size, will operate only in predetermined areas, and is

not a complex mechanical device. With the combined use of the DJI Inspire 1

op erat or’s and maintenance manual and TradeCraft LLC Commercial sUAS Flight Operations Procedures, the Pilot in Command of the Inspire will ensure that it is in
safe working order prior to initiating flight, TradeCraft LLC pilots will perform required
mainte nance, and keep a log of any maintenance that is performed. Moreover, the Pilot in Command, prior to all flight s will ensure the air craft is safe for flight

, which will provide an equivalent level of safety.Page 10

www.tradecraftuas.com Federal Register Summary

Pursu ant to 14 C.F.R. § 11.81(f), the following summary is provided for publication in the Federal Register, should the FAA determine that publication is needed:

Docket No.: No. FAA

- 2014

- Petitioner: TradeCraft LLC

Section of 14 CFR: 14 C.F.R. § 45.23(b), 14 C .F.R. § 61.113(a) and (b), 14 C.F.R. § 61.133(a), 14 C.F.R. § 91.7(a) and (b), 14 C.F.R. § 91.109(a), 14 C.F.R. § 91.119, 14 C.F.R. § 91.151(a), 14 C.F.R. § 91.405(a), 14 C.F.R.§ 91.407(a)(1), 14 C.F.R. § 91.409(a)(2), 14 C.F.R. § 91.417(a).

Description o f Relief Sought: TradeCraft LLC is seeking an exemption to conduct commercial agriculture, aerial survey, and imagery operatio ns using a small Unmanned A ircraft S ystem (55lbs or less) in areas of the
continental United States.

Based upon the foregoing, Tr adeCraft LLC requests that the FAA grant it the necessary exemptions under Section 333 of the FAA Reform ACT and 49 U.S.C. §44701(f) of the Federal Aviation Act as requested herein to allow commercial operations of the Inspire

within the continental United States and its territories.

Sincerely,

TradeCraft LLC