CA DRONE SUPPLY SECTION 333 EXEMPTION REQUEST Page 1 of 

### 4 April 21, 2015U.S. Dept. of Transportation, Docket Operations West Building Ground Floor, Room w12-140 1200 New Jersey Avenue, SE., Washington, DC 20590

Submitted Electronically via the Federal Docket Management System (FDMS)

Re: Exemption Request under Section 333 of the FAA Reform Act and Part 11 of the Federal Aviation Regulations

Dear Sir or Madam:

On Behalf of Revolutionary Unmanned Systems LLC dba., California Drone Supply (CA Drone Supply), and Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 and 14 C.F.R. Part 11, I John Santry, Owner CA Drone Supply, request an exemption from Part 21 Subpart H; and Sections 91.203 (a) (1), 45.23 (b), 91.7 (a), 91.9, 61.113, 61.133, 91.109, 91.119, 91.121, 91.151, and (91.401 - 91.417) Subpart E, of Title 14, Code of Federal Regulations (14 CFR).

This proposed exemption would allow for the operation of our unmanned aircraft (UA) the DJI Inspire 1 and the Spreading Wings S1000 (Multi-Rotors) for the purpose of aerial image acquisition and videography.

This exemption cites similarity with relief previo usly requested in Grant of Exemption Nos. 11445, 11062, 11109, 11112, 11213, and 11138

The DJI Inspire 1 and the DJI Spreading Wings S1000 each are comprised of an Unmanned Aircraft (UA) and ground station-based equipment and crew:

THE UNMANNED AIRCRAFT (UA’s):

x DJI Inspire 1 is a lightweight (under 7lb. gross weight), battery operated 4-motor quad copter that takes off and lands vertically

x The DJI Spreading Wings S1000 is also lightweight (under 10lb. gross weight), battery operated 8-motor Octo-copter that takes off and lands vertically.

THE UA’s INCLUDES:

x An on-board flight computer with GPS navigation and location ability that receives signals for flight controls from a ground-based transmitter/controller;

x A Gimbal with a camera capable of capturing imagery in the form of full color, high definition still photos and video

x An on-board telemetry system that delivers flight data from the on-board flight computer to the on-board radio transmitter including altitude AGL, horizontal and vertical speed, compass direction of flight and direction back to its launch site

x A 5.8GHz on-board radio transmitter that transmits live video from the on-board camera plus all the flight data from the telemetry system described aboveCA DRONE SUPPLY SECTION 333 EXEMPTION REQUEST Page 2 of 

### 4 THE GROUND STATION PART OF THE SYSTEM:

x A Pilot in Command (PIC) who will be In operational control of the mission from beginning to end, and who controls the UA while in the air

x A Visual Observer (VO), a person who provides a second pair of eyes to visually track the UA while in flight.

x A 2.4GHz radio transmitter/controller oper ated by the PIC to control the UA

x A Ground Station DJI Vision App which receives and displays video and system telemetry real
time from the UA

UAS OPERATING GUIDELINES:

UA’s will be operated in the field wi th both a PIC and a VO in accordan ce with the following Restrictions:

x All operations must occur in FAA Class G airspace at no more than 400 ft AGL, at airspeed of no more than 25 knots and always within Visual Line of Sight.

x All operations must utilize a visual observer (VO) . The VO and PIC must be able to communicate by voice at all times during a flight operation

x The PIC must have accumulated and logged, in a manner consistent with 14 CFR § 61.51 (b), 10 hours of total time as a UA rotorcraft pilot and at least 5 hours logged as a UA pilot with a similar UA type

x The UA will not be operated over densely populated areas; without prior approval

x The UA will not be operated over any open-air assembly of people; without prior approval

x The UA will not be operated within 5 NM of an airport or heliport; without prior approval

x The UA will not be operated at air shows

x Operations will be restricted to day only and weather conditions equivalent to VFR

x The PIC will brief the VO and property owner about the operation and risk before operation

x No flight will be made without a Pre-Flight Inspection by the PIC before each operation to ascertain that the UA is in a condition safe for flight

PILOT IN COMMAND (PIC) AND VISUAL OBSERVER:

The PIC and VO will meet the requirements outlined in FAA Policy N 8900.227 Section 16 personnel Qualifications. Additionally, the PIC will hold at a mi nimum, a current Sport Pilot certificate. The PIC will perform maintenance on the system in accordance with manufacturer guidelines and/or instructions.

In the event the PIC cannot perfor m maintenance, the UA will be re turned to the manufacturer or a manufacturer certified technician to perform any necessary repairs

I submit that the combination of the UA’s light we ight, flight performance and ability, fully qualified flight crew and strict operation under the guidelines established in 8900.227, and under all of the Restrictions listed above, the FAA can have full confidence that the operation will have an equivalent or greater level of safety than manned ai rcraft performing the same mission.CA DRONE SUPPLY SECTION 333 EXEMPTION REQUEST Page 3 of 

### 4 INTENDED USE:

The requested exemption would allow us to use the UA for aerial image acquisition to support various mapping and surveying applications as well as video documentation for the public good. Typical applications would include, but are not limited to:

x Aerial Photography

x Aerial Surveys

x Videography for local commercial production

The inherent ability of the UA is to capture imager y from a low altitude including oblique photos and video from several angles is far more effective than ground-based imagery for displaying the characteristics of buildings, sites and properties being developed or areas where consistent monitoring is needed. The low flying capab ilities of multi rotor systems are also an excellent candidate for film/video production for local commercial advert isements. The applicant in the past has chartered made use of boom operators and/or helicopters for this purpose, which have proven more costly than many potential clients have been able to afford, resulting loss of opportunities.

PUBLIC SAFETY:

UA’s, are powered by batteries, they are smaller, lighter and more maneuverable than larger aircraft running on combustible fuel; they operate at lower altitudes (under 400’) and weigh less than 10 lbs with no people on board thereby reducing current risk levels and enhancing public safety. With a small payload and maximum flight time of 15 to 20 minutes, UA’s offer little or no risk to national security.

SUMMARY GRANT REQUEST:

This request follows many others using similar systems and process that have been granted previously. I am requesting the FAA issue a summary grant of exemption as this request would not set a precedent.

x The reasons stated by the FAA for granting Exemption Nos. 11445, 11062, 11109, 11112, and 11213 also apply to this request

x A grant of exemption would be in the public interest

x Denial of this exemption request would unfairly limit our ability to provide these services to our
clientsCA DRONE SUPPLY EXEMPTION REQUEST AND LEVEL OF SAFETY Page 1 of 

### 4 ADDENDUM

EXEMPTION REQUESTS AND EQUIVALENT LEVEL OF SAFETY

I, John Santry, Owner CA Drone Supply, request an exemption from the following regulations as well as any additional regulations that may technically apply to the operation of the our UA’s

14 C.F.R. Part 21, Subpart H: Airworthiness Certificates 14 C.F.R. 91.203 (a) (1)

Subpart H, entitled Airworthiness Certificates, establishes the procedural requirements for the issuance of airworthiness certificates as required by FAR 91.203 ( a) (1). Given the size and limited operating area
associated with the UA to be utiliz ed by the Petitioner, an exemption from Part 21 Subpart H meets the requirements of an equivalent level of safety under Part 11 and Section 333 of the FMRA. The Federal Aviation Act (49 U.S.C.44701 (f)) and Section 333 of the FMRA both authorize the FAA to exempt aircraft from the requirement for an airworthiness certificate, upon consideration of the size, weight, speed, operational capability, and proximity to airports and populated areas of the particular UA. In all cases, an analysis of these criteria demonstrates that the UA operated without an airworthiness certificate, in the restricted environment and under the conditions proposed will be at least as safe, or safer, than a conventional aircraft (fixed wing or rotorcraft) operating with an airworthiness certificate without the restrictions and conditions proposed. The UA to be operated hereunder is less than 55 lbs. fully loaded, is by definition unmanned and carries neither a pilot nor passenger, carries no explosive materials or flammable liquid fuels, and operates ex clusively within a limited flight area. Unlike other civil aircraft, operations under this exemption will be tightly controlled and monitored by the Operator and will also remain within the requirements of, and in compliance with, local public safety requirements. These safety enhancements, which already apply to civil aircraft provide a greater degree of safety to the public and property owners than conventional operations conducted with airworthiness certificates issued under 14 C.F.R. Part 21, Subpart H. Lastly, application of these same criteria demonstrates that there is no credible threat to national security posed by the UA due to its size, speed of operation, location of operation, lack of explosive materials or flammable liquid fuels, and inability to carry a substantial external load.

14 C.F.R. 45.23 (b). Marking of the Aircraft

The regulation requires; When marks include only the Roman capital letter "N" and the registration number is displayed on limited, restricted or ligh t-sport category aircraft or experimental or provisionally certificated aircraft, the operator must al so display on that aircraft near each entrance 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," "experimen tal," or "provisional," as applicable. Even though the UA will have no airworthiness certificate, an exemption may be needed as the UA will have no entrance to the cabin, cockpit or pilot station on which the word "Experimental" can be placed. Given the size of the UA, two-inch lettering will be impossi ble. The word "Experimenta l" will be placed on the fuselage in compliance with 45.29 (f). The equivalent level of safety will be provided by having the UA marked on its fuselage as required by 45.29 (f) where the pilot, observer and others working with the
UA will see the identification of the UA as "Experimental."CA DRONE SUPPLY EXEMPTION REQUEST AND LEVEL OF SAFETY Page 2 of 

### 4 The FAA has issued the following exemptions to this regulation to Exemptions Nos. 10700, 8738, 10167
and 10167 A.

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

The regulation requires that no person may operate a ci vil aircraft unless it is in airworthy condition. As
there will be no airworthiness certificate issued for the aircraft, should this exemption be granted, no FAA regulatory standard will exist for determining airw orthiness. Given the size of the aircraft and the requirements contained herein for the use of safety check lists prior to each flight, an equivalent level of safety will be provided.

14 CFR 91.9 Civil aircraft flight manual, marking, and placard requirements.

This regulation provides that no person may operate an aircraft unless a current, approved flight manual is in the aircraft. We assume that the intent of this requirement is to ensure that flight manual information is available to the aircrew while operat ing the aircraft. We request an exemption to this requirement since the aircraft is not only too small to carry documentation; the documentation would not be available to the crew during flight operations.

To obtain an equivalent level of safety and meet the intent of 91.9, we propose that a current, approved UA Flight Operations/Procedures (Appendix A) must be available to the crew at the ground station anytime the aircraft is in, or preparing for, flight.

The FAA has issued the following exemptions to th is regulation: Exemption Nos. 8607, 8737, 8738, 9299, 9299A, 9565, 95658, 10167, 10167A, 10602, 32827, and 10700.

14 CFR 61.113 Private pilot 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. Subp aragraph (b) allows a private pilot to act as pilot in command of an aircraft in connection with any business 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.
Our proposed operations require that the PIC must either

1. Hold a Private Sport Certificate issued by the FAA, and have logged 10 hours of flight experience in this type of UA, or 2. Meet the requirements of 8900.227 para 16(c)(2)(c) "Operations without a pilot certificate" in which the PIC is required to complete "FAA private pilot ground instruction" and pass "the
FAA Private Pilot written examination." Since th ere are currently no means available for the pilot of a UA to gain the experience in an equi valent category and class in order to apply for a private pilot's license, we propose to generate an equivalent level of safety by requiring our pilots to complete, at a minimum, FAA private pilot ground instruction and pass the FAA
Private Pilot written examination in addition to completing the private pilot requirements. Since the aircraft cannot carry passengers or property, we feel that we meet the int ent of 61.113 Subparagraph (b) even though the intent of this application is to conduct a business.CA DRONE SUPPLY EXEMPTION REQUEST AND LEVEL OF SAFETY Page 3 of 

### 4 14 CFR 91.109 Flight Instruction; Simulated in strument flight and certain flight tests The regulation states that "No person may operate a civil aircraft that is being used for flight instruction unless that aircraft has fully functioning dual controls."

The UA’s ground-based control station consists of a small hand-held radio transmitter and while it does not offer a second set of "controls", both the student and instructor can, and will, operate the single set of controls simultaneously. With both student and instructor having "hands-on" the controls during flight, we feel that this technique meets the intent 91.109 and provides an equivalent level of safety.

14 CFR 91.119 Minimum safe altitudes: General.

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

In order to provide an equivalent level of safety The UA’s will not be operated over congested areas or over any open air assembly of persons with prior approval. Any property owner affected will be briefed on the expected route of flight and the associated risks to persons and property on the ground. The aircraft will be operated at a low altitude allowing, if a power unit fails, an emergency landing without undue hazard to persons or property on the surface. Therefore we maintain that due to the small size of the UA, the hazard to persons, vehicles and structures is minimal compared to manned aircraft, which should be considered in granting the exemption.

14 CFR 91.121 Altimeter Settings.

The regulation requires that aircraft shall maintain cruising altitudes by reference to an altimeter setting available within 100 NM of the aircraft.

The UA will always fly below 500 feet AGL and will no t need to maintain cruising altitudes in order to prevent conflict with other aircraft. An Above Gr ound Level altimeter measurement above the takeoff point is transmitted via radio from the UA’S on-board computer to the display screen held by the PIC, providing a constantly updated AGL readout.

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 landing and to fly after that for at least
30 minutes.

The intention of this paragraph is to provide an energy reserve as a safety buffer for delays to landing. Each UA is battery operated and the maximum duration of flight from a single battery charge is 20 minutes with a 20% reserve. Since the aircraft w ill never fly more than 3/4NM from the point of intended landing, a full battery charge at launch will ensure that we meet the reserve energy requirement of this paragraph. We request an exemption to the word "fuel" and ask for an equivalent interpretation with the word "energy".CA DRONE SUPPLY EXEMPTION REQUEST AND LEVEL OF SAFETY Page 4 of 

### 4 14 CFR Subpart E (91.401 - 91.417) - Maintenance, Preventive Maintenance, Alterations

The regulation provides that the operator is primar ily 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 return 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 Pre-Flight Checklist in Appendix A, the PIC will ensure that the aircraft is in an airworthy co ndition prior to every flight and in addition conduct detailed inspections after every two hours of flight. Maintenance performed by the PIC is limited to repairing small cracks, replacing a propeller, checking electrical connections and updating software and firmware for the on-board computer. All other maintenance will be performed by the manufacturer or their designated repair facility. The PIC will document work performed in accordance with 91.417. We
feel that due to the si ze, construction, and simplicity of the aircraft, the PIC can ensure an equivalent level of safety.

8900.227 Paragraph 16(c)(4) PIC Medical. And Paragraph 16(e)(1) Observer Medical.

This policy provides that both the PIC and VO must have a valid FAA second-class medical certificate issued under part 67 in order to perform as a pilot or observer.

The UA’s maximum gross weight is less than 10 lbs., are constructed primarily of, plastic and carbon fiber. The PIC is not on board. Both the PIC and the VO are required to be in VLOS. Given the unlikely event that both the PIC and VO become medically incapacitated while the aircraft is in flight, the UA will return autonomously to the site of launchin g and land without crew intervention. Therefore, requiring the PIC and VO to meet the same medical requirements as commercial pilot carrying passengers in a large aircraft is an unnecessary burden.

We propose that the minimum medical requirements for the PIC and VO be vision corrected to 20/20 and a valid, state issued driver's license. The 20/20 vision requirement will ensure that the PIC and VO n see and avoid air traffic; a licensed driver is medically qualified to operate a much larger vehicle.CA DRONE SUPPLY – APPENDIX A – FLIGHT OPERATIONS AND PROCEDURES APPENDIX A – FLIGHT OPERATIONS/PROCEDURES

The UA will be operated under the following flight re strictions. Restrictions and procedures are the same for both DJI UA’s in this request

OPERATIONAL FLIGHT RESTRICTIONS

The UA will be operated in the field with both a PIC and a VO in accordance with and with the following
Restrictions:

x All operations must occur in FAA Class G airspace at no more than 400 ft AGL, at airspeed of no more than 25 knots and always within Visual Line of Sight.

x All operations must utilize a visual observer (VO) . The VO and PIC must be able to communicate by voice at all times during a flight operation

x The PIC must have accumulated and logged, in a manner consistent with 14 CFR § 61.51 (b), 10 hours of total time as a UA rotorcraft pilot and at least 5 hours logged as a UA pilot with a similar UA type

x The UA will not be operated over densely populated areas; without prior approval.

x The UA will not be operated over any open-air assembly of people; without prior approval

x The UA will not be operated within 5 NM of an airport or heliport; without prior approval

x The UA will not be operated at Air Shows

x Operations will be restricted to day only and weather conditions equivalent to VFR;

x The PIC will brief the VO and property owner about the operation and risk before operation

x No flight will be made without a Pre-Flight Inspection by the PIC before each operation to ascertain that the UA is in a condition safe for flight

PRE-FLIGHT CHECKLIST

Once on site the Pilot-In-Command (PIC) and a Visual Observer (VO) will:

x Assess the area for potential hazards

x Determine the take-off and landing (return to home) location

x Place signage if necessary noting survey in progress

x Brief all personnel present on th e upcoming aerial acquisition

x Instruct those not involved in the aerial acquisition on a safe viewing location

The PIC and VO will then move all equipment necessary to the launch location.

Prior to operation preflight checklists provided by the manufacturer of the UA’s will be followed. Below is such an example.

x Remote Controller, smart battery, Range Extender and smartphone are fully charged.

x Propellers are mounted correctly.

x Damping absorbers are in good condition, not broken or worn.

x Camera lens cap has been removed.CA DRONE SUPPLY – APPENDIX A – FLIGHT OPERATIONS AND PROCEDURES x Micro-SD card has been inserted if necessary.

x Gimbal is functioning as normal.

x Motors can start and are functioning as normal.

x DJI App can connect to the camera.

TAKE OFF/LANDING PROCEDURES

Manufacturer recommended Takeoff and La nding procedures will be followed.

Place the UA on ground with the battery level indicator facing you.
1. Power on the remote controller. 2. Power on the range extender. 3. Switch the camera to the “WIFI ON” position. 4. Power on the aircraft by tu rning on the intelligent battery 5. Connect the mobile device to the UA, run the DJI App to enter the camera preview page. 6. Wait until the LED flight indicator starts to slow ly blink green/yellow. This means the aircraft is initializing and entering the “Ready to Fly”/“Re ady to Fly (non-GPS).” state. Then proceed to
execute the CSC command to start motors. 7. Push the throttle stick up slowly to lift the aircraft off the ground. 8. When landing, be sure to be hovering over a level surface. Pull down on the throttle stick gently to descend and land. 9. After landing the aircraft on the ground, keep the throttle stick at its lowest position for about 3 to 5 seconds which will automatically stop the motors.

FAILSAFE FUNCTION

The UA will enter Failsafe mode when the connection from the remote controller is lost. The flight control system will automatically control the aircraft to return to home and land to reduce injuries or damage. The following situations would make the aircraft fail to receive a signal from the remote
controller and enter Failsafe mode:

1. The remote controller is powered off. 2. The aircraft has flown out of the effective communication range of the remote controller. 3. There is an obstacle obstructing the signal between the remote controller and the aircraft, essentially reducing the distance the signal can travel. 4. There is interference causing a signal problem with the remote controller.CA DRONE SUPPLY – APPENDIX B – DJI INSPIRE 1 APPENDIX B – USER’S MANUAL FOR UA (DJI Inspire 1)

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