July 20, 2015 U. S. Department of Transportation Docket Management System 1200 New Jersey Ave., SE Washington, DC 20590

RE: Petition of Drone 1 Applied Drone Systems, LLC for Exemption Pursuant to Section 333 of the FAA Reform Act

Petitioner’s Name and Address:

Applied Drone Systems, LLC Owner: Quentin Wheeler 1845 Curraghmore Road Clemmons, NC 27012 619-227-5655 quentin @appdronesystems.com

To whom it may concern:

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the Reform Act) and 14 C.F.R. Part 11, Applied Drone Systems, LLC, operator of Small Unmanned Aircraft Systems(“sUASs”) equipped to conduct aerial photography, videography,and data collection hereby applies for an exemption from the listed Federal Aviation Regulations (“FARs”) to allow commercial operation of its sUASs, so long as such operations are conducted within and under the conditions outlined herein or as may be established by the FAA as required by Section 333.

As described more fully below, the requested exemption would permit the operation of small, unmanned and relatively inexpensive sUAS under controlled conditions in airspace that is 1) limited 2) predetermined and 3) controlled. The proposed exemption, if granted, would allow Applied Drone Systems, LLC to conduct commercial operations of sUASs meeting or exceeding all of the operational and safety requirements Congress has set forth in Section 333.

Applied Drone Systems, LLC is an aviation technology company owned and operated by Quentin Wheeler. The purpose of Applied Drone Systems, LLC is to provide sUAS imagery to customers and to develop new and innovative sUAS flight applications using the drone’s cameras and sensors to provide time or cost savings for business, non-profit organizations and people in the United States and its territories. Mr. Wheeler has 30 years of aviation experience experience in both fixed wing and helicopters. As a military aviator, he was involved with Predator and Global Hawk integration into the airspace above Iraq and Afghanistan. He was a squadron maintenance functional check-flight pilot, maintenance officer, and officer in charge of forward deployed detachments. He brings a professional approach to aviation operations, maintenance and airspace integration to his company operations.Applied Drone Systems, LLC plans to use the capabilities of sUASs to offer numerous services all based on aerial photography and videography flight profiles. Applied Drone Systems will then process the aerial data collected and transform it to the client’s requirement. These requirements include:



### - Aerial Photography/Videography



### - Real Estate Photography/Videography - Event Photography/Videography



### - Construction Site Inspections and Progress Monitoring



### - Environmental Monitoring



### - Terrain Mapping



### - Research Operations Carrying Environmental Data Collection Payloads

Statutory Authority Section 333, titled “Special Rules for Certain Unmanned Aircraft Systems”, provides a mechanism for seeking expedited FAA authorization of safe civil Unmanned Aircraft Systems (UAS) operations in the National Airspace System (“NAS”). Section 333 states that the FAA “shall determine if certain unmanned aircraft systems may operate safely in the national airspace system before completion of the (comprehensive) plan and rule making required by section 332(b)(1) of this Act or the guidance required by section 334 of this Act.” In section 332(b)(1), Congress made it clear that Section 333 provides a mechanism for “expedited operation authorization” if several factors are met. Petitioner meets all requirements to permit FAA approval of commercial UAS operations.

The name and address of the applicant are:

Name: Applied Drone Systems, LLC Owner: Quentin Wheeler Address: 1845 Curraghmore Road Clemmons, NC 27012 Phone: 619-227-5655 Email: QUENTIN@APPDRONESYSTEMS.COM

Exemptions are being requested from the following regulations:

14 C.F.R. Part 21, 14 C.F.R. 61.113 (a), 14 C.F.R. 61.3, 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)(1) and (2), 14 C.F.R. 91.417(a) and (b).

## AIRCRAFT

Applied Drone Systems, LLC will operate the 3D Robotics Solo sUAS. Aircraft weight is 3.3 pounds with battery and has a payload capacity of 1.1 pounds (500g). Solo is a commercially available, off-the-shelf sUAS. The sUAS will weigh no more than 4.4 pounds and will operate no faster than 55 knots groundspeed. This is an agile, professionally engineered aircraft having the ability to hover, and move about its three axes simultaneously. Because of the sUAS’s specifications and flight characteristics, it poses no threat to national security. Compared to fixed wing and helicopters, Solo provides reduced personnel to operate and maintain, reduced noise levels, zero emissions i nto the environment, and enhanced safety protocols engineered into the aircraft system.
Petitioner is requesting an exemption to enable Applied Drone Systems, LLC to operate a 3D Robotics Solo sUAS that is upgraded to latest version software on the sUAS, controller, and tablet that runs the Solo App. Solo’s onboard computers control navigation, attitude, and data communications in flight while sending real-timetelemetry and video output. Control inputs are received over the 3DR Link secure WiFi network. Solo is optimized for capturing aerial video using the Go Pro Hero camera. The gimbal and frame allow for different cameras to be utilized with the airframe. the UAS will not be operated outside parameters set forth in the manufacturer’s handbook.

This sUAS has a built-in capability to set a maximum Above Ground Level (AGL) altitude for the flight. The aircraft’s Wi-Fi controller has a 1/2 mile line of sight maximum distance. If communication between the sUAS and the controller is lost (lost link), the sUAS will fly back towards to takeoff point until it reacquires the signal.

These factors are beneficial for, and in the best i nterest of, the public. Accordingly, the applicant respectfully requests that the FAA grant the requested exemption without delay

.

## OPERATIONS

Maximum Airspeed and Altitude

The drone may not be operating at airspeeds greater than the maximum airspeeds recommended by the manufacturer (55 knots) and may not exceed 400 feet AGL.

Airport Restrictions

Flight operation may not be within 5 nautical miles of an airport reference point (ARP) as denoted in the current FAA Airport/Facility Directory (AFD) or for airports notlisted in the ARP, the center of the airport symbol as denoted on the current FAApublished aeronautical chart, unless a letter of agreement with that airports management is obtained or otherwise permitted by a COA issued to the exemption holder. This letter of agreement with the airport management must be available to the Administrator or any law enforcement official upon request.

Visibility and Clouds

The aircraft may not be operated less than 500 feet below or 2000 feet horizontally from a cloud or when visibility is less than 3 statue mile from the PIC.

Reserve Flight Time

The pilot in command should not begin a flight unless (considering wind and forecast weather conditions) there is enough available battery power (or additional batteries) for the aircraft to conduct the intended operation. All Applied Drone Systems pilots/ operators will terminate flights when remaining battery power level reaches 20%, or 20 minutes flight time is reached, whichever comes first after takeoff.

Visual Line of Sight

The aircraft 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 specified on the PIC’s FAA issued airman medical certificate or U.S. driver’s license.

Visual Observer

All operations must utilize a visual observer (VO). The aircraft must be operated within the 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; electronic 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 required duties of the VO.Obstruction Clearances

All flight operations must be conducted at least 500 feet from all nonparticipating persons, vessels, vehicles, and structures unless:

• Barriers or structures are present that sufficiently protect nonparticipating persons

from the aircraft an/or debris in the event of an accident. The operator must ensure that nonparticipating persons remain under such protection. If a situation arises where nonparticipating persons leave such protection and are within 500 feet of the aircraft, flight operations must cease immediately in a manner ensuring the safety of nonparticipating persons: and

• The owner/controller of any 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.

Additional Operational Clarifications
Aircraft may not operate over any persons not directly involved in the operation. Daylight-only operations (official sunrise to official sunset, local time). Must yield right-of-way to other aircraft, manned or unmanned. Must use visual observer (VO) on all commercial operations. First-person view camera not authorized for pilot use on commercial operations. Clients may view first person while pilot flys normally. No operations are allowed in Class A (18,000 feet & above) airspace. Operations in Class B, C, D and E airspace are allowed with the required ATC permission. Operations in Class G airspace are allowed without ATC permission No person may act as an operator or VO for more than one unmanned aircraft operation at one time.
No careless or reckless operations. Operational preflight inspection required. The aircraft may not be operated by the PIC from any moving device or vehicle.

## EXEMPTIONS

Applied Drone System LLC requests exemptions from the following regulations as well as any additional regulations that may technically apply to the operation of the sUAV System: 14 C.F.R. Part 21, 14 C.F.R. 61.113 (a), 14 C.F.R. 61.3, 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)(1) and (2), 14 C.F.R. 91.417(a) and (b).



### AIRWORTHINESS CERTIFICATION (14 CFR Part 21)

To ensure airworthiness, the Pilot in Command will perform a thorough preflight prior to any flight operation. The preflight inspection will be performed in accordance with the 3D Robotics Solo User Manual to ensure the aircraft is safe for flight and has the necessary battery power to accomplish the assigned flight. Any damage or malfunction that poses a hazard to flight will be documented and corrected prior to operation. The UAS carries neither a pilot nor passenger, carries no explosive materials or flammable liquid fuels, and operates exclusively within visual line of site of the operator. Operations under this exemption will be tightly controlled and monitored by the operator.

The sUAS will be maintained in accordance with the manufacturer’s maintenance instructions. sUAS maintenance records will be kept on all life-limited parts of each airframe, engine, rotors, controllers, and other appliances. Only manufacturer's authorized replacement parts will be used.

By nature of these conditions, this UAS provides a greater degree of safety to the public and property owners than conventional operations conducted with airworthiness certificates issued under 14CFR Part 21.



### FLIGHT CREW TRAINING AND CERTIFICATIONS (14 CFR 61.3, 14 CFR 61.113)

The aircraft does not carry passengers for compensation or hire. Copies of the pilot’s FAA certificates and training records will be kept on file at Applied Drone Systems. Pilots/Operators will be required to successfully pass the online Applied Drone Systems Ground School test before flying a commercial operation. All pilot and operators must hold at least a FAA sport pilot license with commercial pilot being desirable. Also, pilots/operators will hold a valid driver's license or at least a third class medical certificate. Any research operation that is carrying a sensor, must have a commercial pilot as the pilot in command. The Applied Drone Systems pilot/ operator is in charge and controls the entire flight and will not transfer responsibilityfor operational control of the sUAS aircraft to any other person (unless the flight is specifically for training purposes and not for hire).

Prior to operations for hire, the PIC must have accumulated and logged a minimum of 10 hours of Solo sUAS time and have at least 50 hours total flight time. Designation as an Applied Drone Systems, LLC pilot/operator will remain on file. The PIC is responsible for the safe and efficient operation of the aircraft. Specific duties include all preflight preparation and inspection, in flight operation, post flight requirements, and all procedures including but not limited to:

• Impact of Weather Conditions

• Risk Management

• Operational Flight Safety

• Post Flight Data/Imagery Transfers

For Visual Observers, completion of the online exam is required before field operations. The curriculum serves as an information baseline to ensure visual observers are familiar with potential Applied Drone Systems operations and can be effective in field flight operations. The Visual Observer will possess a current valid driver’s license issued in the United States

.


### FUEL REQUIREMENTS (14 CFR 91.151)

The sUAS is powered by a battery, which provides up to 25 minutes of powered flight. Because of the absence of flammable operating fluids, the sUAS does not pose the same level of risk as a conventional aircraft. All Applied Drone Systems pilots/ operators will terminate flights when remaining battery power level reaches 20%, or 2 0 minutes flight time is reached, whichever comes first after takeoff.
Since no flights conducted by Applied Drone Systems will require traditional petroleum based fuel, and those flights will be for less than 25 minutes, Applied Drone Systems, LLC requests relief from 14CFR 91.151.



### MAINTENANCE (91.405(a), 91.407(a)(1), 91.409(a)(1) and (2), and 91.417(a) and (b) )

Applied Drone Systems will keep maintenance records on all airframes that the company owns. Aircraft maintenance records must include the current status of the life-limited parts of each airframe, engine, rotors, and appliances.Each aircraft operated under this exemption must comply with all manufacturer safety bulletins.

Applied Drone Systems will track all life limited components mentioned above. When engines, rotors, controllers, or other drone equipment is replaced, maintenance records must accurately reflect the changes and track individual and total times.

Any aircraft that has undergone maintenance or alterations that affect the aircraft 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 flights 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 person and property.

All maintenance will be done is accordance with 3D Robotics guidelines. Applied Drone Systems must follow the 3D Robotics maintenance, overhaul, replacement, inspection , and life limit requirements for the aircraft and aircraft components.



### CONCLUSION

Applied Drone Systems, LLC plans to use the capabilities of sUASs to offer numerous services all based on standard aerial photography and videography flight profiles. Applied Drone Systems will then process the aerial data collected and transform it to the client’s requirement.

With operation being directed by a retired military pilot and FAA licensed commercial pilot, Applied Drones systems understands and intends to comply with every applicable regulation to the operation of sUAS. Each exemption for which we seek relief, will allow for safe and efficient commercial operations that are far superior to those conducted by manned aircraft.
Applied Drone Systems proposed exemptions and operational limitations are very closely aligned with other exemptions already granted. Applied Drone Systems LLC should be permitted to conduct small UAS operations in accordance with its manuals and all other operating parameters deemed necessary and appropriate by the FAA.

Please contact me at your convenience with any questions regarding this request.
Thank You,
Quentin Wheeler, Founder and Director of Operations, Applied Drone Systems, LLC