1st Landing LLC Ph: 631

- 750

- 9238 Email: nick@accsystemsinc.com 29 November 2015

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 2 012 (the “Reform Act”) and 14 CFR Part 11, 1st Landing, LLC (“1st Landing ”), s eeks an exemption from Federal Aviation Regulations (“FARs”) detailed

below for multiple models of rotary small unmanned aerial systems (sUAS).

The sUAS will be equipped to conduct aerial data collection for hire using remote sensing and measuring by

in struments recorded aboard and transmitted to the ground . None of the data collection instrumentation interferes with the safe operations as they conform to published weight and balance restrictions, do not alter the command and

control of the vehicles and do not require any adjustment to safety features during lost link operations. The commercial activities meet the needs of wide array of customers who do not have comparable alternatives and this requested exemption would support an application for a commer cial Certificate of Authorization to use the system to support the following commercial operations, each of which serve the public good:

 imagery (phot ography, video, infrared, etc.)

 electronic measurement (precisio n surveying, RF analysis, etc.)

 chemical measurement (particulate me asurement, etc.)

 other gathering of data by other instruments placed an d to be placed aboard the sUASs

 aerial photography and video for the motion picture, television and commercial video industry

 sear ch and rescue services for hire

 accident and disaster in surance compensation evaluation

 construction, transportation, communication, distribution, utility and risk management services

 other services as requested fo r by customers' for their needs

The sUAS in question are similar or identical to those granted exemptions in prior requests and t h e aviat ion experience of the applicant and the type of commercial operations requested for consideration closely match the criteria of numerous operators granted exemptions. The operations by 1 s t Landing would be subject to the same

conditions and limitations.

1. 3DRobotics DIY Quad

a. Optional Equipment:

i. Ublox M8N GPS

b. Previous Exemption Granted

i. Exemption No. 12283 // Orlando Production, Inc

.

2. 3DRobotics DIY Quad

a. Optional Equipment:

i. Ublox M8N GPS

ii. 3DR Extended Legs Kit1st Landing LLC Ph: 631

- 750

- 9238 Email: nick@accsystemsinc.com iii. Tarot T

- 2D Gimbal
iv. Logitech USB Webcam

v. Raspberry Pi Computer

b. Previous Exemption Granted

i. Exemption No. 12283 // Orlando Production, Inc

.

3. 3DRobotics X8+

a. Optional Equipment:

i. Tarot T

- 2D Gimbal

ii. Logitech USB Webcam

iii. Raspberry Pi Computer

b. Previous Exemption Granted

i. Exemption No. 13506 // Top Flight Digital Media LLC

4. Aerosky C17

a. Optional Equipment:

i. Tarot T

- 2D Gimbal

ii. 3DR GPS

iii. Logitech USB Webcam

iv. Raspberry Pi Computer

b. Previous Exemption Request

i. Docket ID: FAA

- 2015

- 4374 // David A. Kello

Unless otherwise specified in this grant of exemption, th e UAS, the UAS PIC, and the UAS operations will comply with all applicable parts of 14 CFR including, but not limited to, parts 45, 47, 61, and 91. These operations will also be subject to strict operating requirements d efined in the aircraft user manual s

.

The PIC and VO will meet the requirements outlined in FAA Policy N 8900.227 Section 16 Personnel Qualifications. Additionally, the PIC and VO will perform maintenance on the system and will co mplete a course of maintenance instruction as part of their initial training.

We submit that the combination of the aircraft's light weight, historically demonstrated flight performance, fully qualified flight crew and strict operation under the guidel ines established in 8900.227, the FAA can have confidence that the operation will have an equivalent or greater level of safety of manned air c raft performing the

same mission.

In regards to privacy concerns, a ll flights will occur over private or control led access property with the property owner’s prior consent and knowledge. Inspection will be in areas where the owners will have consented to the inspections or otherwise have agreed to allow the UAS and the operator to be in the area where inspection wil l take place.

The regulations from which the exemption is requested are as follows: 14 CFR 61.113(a) and (b), 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 1 st Landing to operate s UAS for the purpose of aerial data collection . This exempti on is subject

to the conditions and limitations listed below.

1. Operations authorized by this grant of exemption are limited to the type aircraft detailed above. Proposed operations of additional aircraft will require a new petition or a petition to amend this grant.

2. The UA may not be flown at an indicate d airspeed exceeding 70 knots.

3. The UA must be operated at an altitude of no more t han 400 feet above ground level ( AGL), as indicated by the procedures specified in the operating documents. All altitudes reported to ATC must be

in feet AGL.1st Landing LLC Ph: 631

- 750

- 9238 Email: nick@accsystemsinc.com

4. 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 hum an vision unaided by any device other than corrective le nses, as specified on the

PIC’s FAA

- issued airman medical certificate.

5. All operations must utilize a visual observer (VO). The VO may be used to satisfy the VLOS requirement as long as the PIC alwa ys maintains VLOS capability. The VO and PIC must be able to communicate verbally at all times. 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 perf orm the functions prescribed in the operating documents.

6. The operating documents and this grant of exemption must be maintained and made available to the Administrator upon request. If 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 procedures 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 upon request. The operator must also present updated and revised documents if it petitions for ex tension or amendment to this grant of exemption. If the operator determines that any update or revision would

affect the basis upon which the FAA granted this exemption, then the operator must petition for 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.

7. Prior to each flight the PIC must 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 is 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 must be included in the preflight inspection. All maintenance

and alterations must be properly documented in the aircraft records.

8. Any UAS 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. The PIC who conducts the functional test flight must make an entry in the aircraft records.

9. The pre

- flight inspection section in the operating documents must account for all discrepancies, i.e. inoperable components, i tems, or equipment, not already covered in the relevant sections of the operating

documents.

10. The operator must follow the UAS aircraft/component, maintenance, overhaul, replacement, inspection, and life limit requirements.

11. The operator must carry o ut its maintenance, inspections, and record keeping requirements, in accordance with the operating documents. Maintenance, inspection, and alterations must be noted in the aircraft records, including total flight hours, description of work accomplished, an d the signature of the PIC returning the UAS to service.

12. Each UAS operated under this exemption must comply with all manufacturer System and Safety

Bulletins.

13. The PIC must make an entry in the aircraft record of the corrective action taken against discrepancies discovered between inspections.

14. The Pilot in Command (PIC) must possess at least a private pilot certificate and at least a current third

class medical certificate. The PIC must also meet the flight review requirements specified in 14 CFR

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

15. The operator may not permit any PIC to operate unless that PIC has demonstrated through the operator’s training that the PIC is able to safely operate the UAS in a manner consistent with how the UAS will be operated under this exemption, including evasive and emergency maneuvers and maintaining1st Landing LLC Ph: 631

- 750

- 9238 Email: nick@accsystemsinc.com

appropriate distances from persons, vessels, vehicles and structures. A record of training must be

documented and made available up on request by the Administrator. Flights for the purposes of training the operator’s PICs and VOs (training, proficiency, and experience

- building), are permitted under the terms of this exemption. However, said training operations may only be conducted dur ing dedicated training sessions.

16. UAS operations may not be conducted during night, as defined in 14 CFR 1.1. All operations must be conducted under visual meteorological conditions (VMC). Flights under special visual flight rules (SVFR)

are not authori zed.

17. All operations shall be conducted in Class G airspace.

18. The UA may not operate within the required distances from airport reference point s as denoted on a current FAA

- published aeronautical chart without express permission from the FAA

.

19. 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 less than 3 statute miles from the PIC.

20. If the UA loses communications or loses its GPS signal, it must return to a predetermined l ocation within the planned operating area and land or be recovered in accordance with the operating documents.

21. The PIC must abort the flight in the event of unpredicted obstacles or emergencies in accordance with the operating documents.

22. The PIC is prohibited from beginning a flight unless (considering wind and forecast weather conditions) there is enough power to fly at normal cruising speed to the intended landing point and land

the UA with reserve battery power remaining.

23. The operator must obtain an Air Traffic Organization (ATO) issued Certificate of Waiver or Authorization (COA) prior to conducting any operations under this grant of exemption. This COA will also require the operator to request a Notice to Airman (NOTAM) not more than 72 ho urs in advance, but not less than 48 hours prior to the operation.

24. All aircraft operated in accordance with this exemption must be identified by serial number, registered in accordance with 14 CFR part 47, and have identification (NNumber) markings in accordance with 14 CFR part 45, Subpart C. Markings must be as large as practicable.

25. Before conducting operations, the radio frequency spectrum used for operation and control of the UA must comply with the Federal Communications Commission (FCC) or oth er appropriate government oversight agency requirements.

26. The documents required under 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 availabl e to the Administrator or any law enforcement official upon request.

27. The UA must remain clear and yield the right of way to all other manned aviation operations and

activities at all times.

28. The UAS may not be operated by the PIC from any moving dev ice or vehicle.

29. The UA may not be operated over congested or densely populated areas.

30. Flight operations must be conducted at least 500 feet from all nonparticipating persons, vessels, vehicles, and structures unless:

a. Barriers or structures are p resent 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 such protection. If a situation arises where nonparticipating persons leave such protection and are1st Landing LLC Ph: 631

- 750

- 9238 Email: nick@accsystemsinc.com

within 500 feet of the UA, flight operations must cease immediately and/or;

b. the aircraft is operated near vessels, vehicles or s tructures where the land owner/controller has granted permission 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, and

c. operations nearer to the PIC, VO, operator trainees or essential persons do not present an undue hazard to those persons per § 91.1 19(a).

31. All operations shall be conducted over private or controlled

- access property with permission from the land owner/controller or authorized representative. Permission from land owner/controller or authorized representative will be obtained for eac h flight to be conducted.

32. Any incident, accident, or flight operation that transgresses the lateral or vertical boundaries of the operational area as defined 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.

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 information or

clarification.

The name and contact information of the applicant are:

1st Landing LLC

Attn: Nicholas Addonisio

125 Wilbur Place

Suite 200 Bohemia, NY 11716

Ph: 631

- 750

- 9238

Email: nick@accsystemsinc.com

Sincerely,

//signed//

Nicholas Addonisio Managing Partner

Appendices: A. Exemption Request and Equivalent Level of Safety

B . Maintenance Procedures

C . Training Program

D . Aviation Experience

E. Aircraft Manual s1st Landing LLC Ph: 631

- 750

- 9238 Email: nick@accsystemsinc.com APPENDIX A

EXEMPTION REQUESTS AND EQUIVALENT LEVEL OF SAFETY

1st Landing LLC requests an exemption from the following regulations as well as any additional regulations that may technical ly apply to the operation of rotary sUAS :

14 CFR 61.113 Private pil ot privileges and limitations: Pilot in Command and 61.133 Commercial pilot privileges and limitations.

The regulation provides that no person that holds a private pilot certificate may act as pilot in command of an aircraft for compensation or hire. Subparagraph (b) allows a private pilot to act as pilot in command of an aircraft in connection with any bus iness or employment if: (1) The flight is only incidental to that business or employment; and (2) The aircraft does not carry passengers or property for compensation or hire.

Since there are currently no means available for the pilot of a UAS to gain the experience in an equivalent category and class in order to apply for a commercial pilot's license, we propose to generate an equivalent level of safety by requiring our pilots to hold a private pilot certificate . Since the aircraft cannot carry passengers or property, we feel we meet the intent of 61.113 Subparagraph (b) even though the intent of this application is to conduct a business.

14 CFR 91.119 Minimum safe altitudes: General.

The regulation provides that over sparsely populated areas the aircraf t cannot be operated closer than 500 feet to any person, vessel, vehicle, or structure. Since the aircraft will be operating at a maximum of 400 feet AGL, we cannot comply with this requirement.

To provide an equivalent level of safety we will only fly over private property with the permission of the land owner. The land owner will be briefed of the expected route of flight and the associated risks to persons and property on the ground. We maintain that due to the small size of the aircraft , the hazard to persons, vessels, vehicles, and structures is not comparable to manned aircraft and should be considered in granting the exemption. ( See appendix C section 6.4.1 Consideration about risks related to ground impacts)

The aircraft will not be operated ov er congested areas nor over any open air assembly of persons. The aircraft will be operated at an altitude allowing, if a power unit fails, an emergency landing without undue hazard to persons or property on the surface.

14 CFR 91.121 Altimeter settings.

The regulation provides that aircraft shall maintain cruising altitudes by reference to an altimeter setting available within 100 nautical miles of the aircraft. The aircraft will fly below 400 feet AGL and will not need to maintain hemispherical cruising altitudes in order to de

- conflict with other aircraft. As such, an appropriate altimeter measurement presented to the pilot should be Above Ground Level and should be based on the barometric pressure at the point of lau nch. To provide an equivalent level of safety, the UAS's AGL altimeter will be set to zero on the ground prior to every flight. Since the aircraft will fly no more than 50 minutes, even rapid changes in baromet ric pressure will have limited e ffect on the safety of the flight.

14 CFR 91.151 Fuel requirements for flight in VFR conditions.

The regulation provides that no person may begin a flight in an airplane under day

- VFR conditions unless there is enough fuel to fly to the first point of intended lan ding and to fly after that for at least 30 minutes. We feel the intention of this paragraph is to provide a reserve of energy as a safety buffer for go

- arounds and other delays to landing.

The aircraft are battery operated and the maximum duration of fligh t from a single battery charge is less than 3 0 minutes. Since the aircraft will never fly more than 1/2 nm from the point of intended landing, a full battery charge at launch will ensure that we meet the reserve energy requirement of this paragraph.1st Landing LLC Ph: 631

- 750

- 9238 Email: nick@accsystemsinc.com The PIC will not initiate flight unless there is enough power to fly to the first point of intended landing and, assuming normal cruising speed, land the UA with sufficient battery power remaining.

14 CFR Subpart E (91.401

- 91.417)

- Maintenance, Preventive Maintenance, and Alterations

The regulation provides that the operator is primarily responsible for maintaining the aircraft in an airworthy condition, including compliance with part 39 and 43. Paragraphs 91.407 and 91.409 require that the aircraft be "approved for retur n to service by a person authorized under 43.7" after maintenance and inspection. It is our intention that the PIC perform maintenance and inspection of the aircraft and "be authorized to approve the aircraft

for return to service."

As provided in the at tached Maintenance Procedures (A ppendix D) and User’s Manual (Appendix E) , the PIC will ensure that the aircraft is in an airworthy condition prior to flight and conduct detailed inspections after every 10

hours.

Maintenance performed by the PIC is li mited to repairing small cracks, replacing a propeller, and updating software and firmware. All other maintenance will be performed by the manufacturer. The PIC will document work performed in accordance with 91.417. We feel that due to the size, constr uction, and simplicity of the aircraft, the PIC can ensure an equivalent level of safety.1st Landing LLC Ph: 631

- 750

- 9238 Email: nick@accsystemsinc.com APPENDIX B



### MAINTENANCE PROCEDURES

Aircraft Maintenance

Pre

- flight maintenance inspections of the s UAS are detailed in 3D Robotics and Aerosky Manual s . 1st

L anding’s chief pilot has implemented a policy of requiring reference to inspection checklists prior to each flight. The procedures include a visual inspection as well as a series of automated status checks performed by

the s UAS’s internal firmware as well as the operator’s flight control software.

Prior to each flight the PIC must 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 is 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 must be included in the preflight inspection. All maintenance and alterations mus t be properly documented in the aircraft records.

Post

- flight maintenance inspections include a visual inspection as well as a comparison of flight data tracked

onboard the UAS with the data tracked on the Ground Control Station to verify the integrity of the telemetry data relayed to the operator in flight.

Internal safety requirements also contain inspection and maintenance actions that are to be performed in between flights. These procedures effectively evaluate the airframe, motor, servos and senso rs. The PIC will make an entry in the aircraft record of the corrective action taken against discrepancies discovered between inspections.

Any UAS 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. The PIC who conducts the functional test flight must make an entry in the aircraft records.

Each UAS op erated under this exemption will comply with all manufacturer System and Safety Bulle tins.

1st Landing will carry out its maintenance, inspections, and record keeping requirements, in accordance with the operating documents. Maintenance, inspection, and alterations will be noted in the aircraft records, including total flight hours, tot al flight hours of critical aircraft components such as batteries and propellers

, description of work accomplished, and the signature of the PIC returning the UAS to service. The aircraft records will be kept with the UAS and up to date data will be tracke d and electronically maintained by 1st Landing

.

Software Maintenance

Occasionally, the UAS manufacturer may release software upgrades to provide additional features to or to
address potential issu es. The Ground Control Software check s for new versions during start

- up and will display a message with update instructions if a new version is available. Every updated version of the Ground Control Station software is packaged with an accompanying firmware revision which must be installed on the drone before it can be used. Any potentially mis matched software between the Ground Control Station and the

firmware on the s UAS is identified by the Ground Control Station’s software and must be remedied before the

aircraft can be advance d into a re ady for flight condition.1st Landing LLC Ph: 631

- 750

- 9238 Email: nick@accsystemsinc.com 

### APPENDIX C

TRAINING PROGRAM

1st Landing’s training program capitalizes on experience gained from civilian as well as multiple US Air Force flight training programs. If and when 1st Landing adds additional UAS pilots to its operation

, the chief pilot will ensure that qualified pilots complete a compreh ensive flight training program

. This flight training will

include academic study, simulated flight and supe rvised training flights. 1st Landing personnel have completed this t raining program and will adopt and augment it to train any and all of its future additional pilots.

1st Landing will not permit any PIC to operate the UAS unless that PIC has demonstrated through our training program that the PIC is able to safely opera te the UAS in a manner consistent with how the UAS will be operated under this exemption, including evasive and emergency maneuvers and maintaining appropriate distances from persons, vessels, vehicles and structures. In accordance with our training plan, a ll PICs will pass a written test of standard operating procedures as well as emergency actions, perform a simulated flight, and fly with a 1st Landing evaluator pilot until endorsed for PIC duties.

Any 1st Landing , manufacturer, or FAA issued safety b ulletins will be maintained in a Flight Crew Information File and signed off by the PIC prior to their next flight. If changes to operating procedures are mandated, the new procedures will be fully instructed to all pilots and observers and simulated flig hts will be performed to verify that the procedures are understood.

Pilots wishing to advance to the ranks of instructor pilots will undergo additional training. Instructor candidates will demonstrate their suitability for the increased level of responsibility through written examination testing their knowledge and verbal evaluation of their teaching ability. They will first be supervised while instructing until endorsed by an evaluator pilot to assume full instructor pilot duties.

Evaluator pilots will be hand

- picked from the ranks of instructor pilots and wil l be endorsed for evaluator duties by 1st Landing’s chief pilot. Evaluator pilots can perform spot checks to ensure that flight operations are conducted according to standards, and they can prescribe additional training for individual pilots or issue Flig ht Crew Information File bulletins to address the entire crew force.

Training records will be tracked and maintained electronically by 1st Landing and will be furnished for evaluation if requested.1st Landing LLC Ph: 631

- 750

- 9238 Email: nick@accsystemsinc.com 

### APPENDIX D

AVIATION EXPERIENCE

After training in a civilian flight training program for his private pilot’s license, 1st Landing ’ s founding

member and Chief P ilot ( Nicholas Addonisio ) has gained extensive experience during his 13 years as a private pilot a nd maintained a flawless flight safety record

. His qualifications include :

 Rating

– Airplane Single Engine Land, Private Pilot, Certificate # 3058362

 Training

– Mid Island Air Service (midislandair.com) at both Brookhaven Calabro Airport (Class G Airport) & Long Island McArthur Airport (Class C Airport)

 T otal hours (Airplane Single Engine Land)

– 192.5

o Approx imately 30.0 Hours of Instrument IFR Training

o 1.0 Hours

– Robinson R

- 22 Helicopter

o 1.0 Hours

– Glider

The Chief Pilot also has extensive experience operating remotely piloted aircraft as flying these vehicles has been a long

- standing hobby of his prior to seeking a commercial exemption

.1st Landing LLC Ph: 631

- 750

- 9238 Email: nick@accsystemsinc.com 

### APPENDIX E

AIRCRAFT MANUAL S

{ User Manual b egins on next page starting with the title page}