Dear Sir or Madam: 

Pursuant to Section 333 ofthe FAA Modernization and Reform Act of2012 (the Reform Act) 

and 14 C.F .R. Part 11, Groveland Township, an operator of small Unmanned Aircraft Systems 

("sUAS") equipped to conduct: 

• Urban/suburban/rural post-storm (hurricane, tornado, flood, mud slide, etc) damage and 

casualty assessment; 

• Wilderness search and rescue (lost hiker, missing children, etc); 

• Real-time aerial video feed of incidents where the size ofthe incident is large (brush 

fires, commercial building fires, etc) making it difficult to monitor changes in the 

incident from one place on the ground; 

• Command and control of wide-spread incidents, such as wide area searches, making the 

deployment of limited assets (personnel, search canines) more efficient; 

• Creation of orthophotos; 

• Parcel assessment; 

• Infrastructure inspection; 

• Three-dimensional (3D) area and structural mapping; 

• Creation of digital terrain I surface models; 

• Debris volume estimation; 

• Hydrology I inundation estimation; 

hereby applies for an exemption from the listed Federal Aviation Regulations ("PARs") to allow 

commercial operation of its' sUAS, 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 3) controlled as to access and 4) would provide safety enhancements to 

the operational environment. Approval of this exemption would thereby enhance safety and 

fulfill the Secretary of Transportation's (the FAA Administrator's) responsibilities to" ... establish 

requirements for the safe operation of such aircraft systems in the national airspace system." 
Regulations from which the exemption is requested: 

14 CFR Part 21 

14 CFR 45.23(b) 

14 CFR 61.113 (a) & (b) 

14 CFR 91.7 (a) 

14 CFR 91.9 (b) (2) 

14 CFR 91.103 

14 CFR 91.109 

14 CFR 91.119 

14 CFR 91.121 

14 CFR 91.151 (a) 

14 CFR 91.203 (a) & (b) 

14 CFR 91.405 (a) 

14 CFR 407 (a) (1) 

14 CFR 409 (a) (2) 

14 CPR 417 (a) & (b) 

AUTHORITY FOR EXEMPTIONS 

This exemption 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 national airspace 

system (NAS) before completion ofthe rulemaking required under Section 332 of the Reform 

Act. In making this determination, the Secretary is required to determine which types ofUASs 

do not create a hazard to users of the NAS or the public or pose a threat to national security in 

light of the following: 

• The UAS's 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 Section 333 (a). Lastly, if the Secretary determines that such vehicles "may operate 

safely in the national airspace system, the Secretary shall establish requirements for the safe 

operation of such aircraft in the national airspace system." Id Section 333( c). 
safe operation of the sUAS, if it should be determined that the conditions set forth herein do not 

fulfill the statutory requirements for approval. 

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 

find the exemption in the public interest. 49 U.S.C. Section 44701(f) see also 49 USC Section 

4471l(a); 49 USC Section 44704; 14 CFR Section 91.203 (a) (1). 

The DJI Phantom 2 (further described below) is a multirotor aircraft weighing 5 pounds, 

including payload. It has the ability to operate under normal conditions at a speed of no more 

than 30 knots and has the capability to hover and move in the vertical and horizontal plane 

simultaneously. The sUAS will operate only in the pilot's or visual observer's visual line of sight 

at all times, and includes automatic safety features. Such operations will insure that the sUAS 

will "not create a hazard to users of the national airspace system or the public." Reform Act 

Section 333(b). 

Given the small size of the sUAS involved and restricted sterile environment within which they 

will operate, the applicant falls squarely within that zone of safety (an equivalent level of safety) 

in which Congress envisioned that the FAA must, by exemption, allow commercial operations of 

UASs to commence immediately. Also due to the size of the sUAS and the restricted 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 Federal 

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 and chemical spills, exemptions associated 

with allowing UASs for agricultural operations, the grant of the requested exemptions is in the 

public interest. Accordingly, the applicant respectfully requests that the FAA grant the requested 

exemption without delay. 

AIRCRAFT DESCRIPTION 

The sUAS that Groveland Township proposes to use is the DJI Phantom 2. The Phantom 2 is 

commonly referred to as a quadcopter (four independent motors and four rotors). The aircraft 

weighs less than three (3) pounds, including the attached camera and gimbal. The aircraft is 

powered electrically by a single 4480 mAh Intelligent Lithium Polymer (LiPo) battery. With the 

LiPo battery inserted, the aircraft weighs less than five (5) pounds in total. 
unnecessary to fly over. All flight operations of the specified aircraft are GPS controlled, 

including a Visual Positioning System (VPS) which works similarly to a radar altimeter, to 

indicate ground reference. 

The DJI Phantom 2 has two (2) primary operational safety features: 

• Auto-Return Home. When GPS is available, the aircraft remembers exactly where it took 

off from. A touch of a button, or a tap of an on-screen icon, activates this feature. 

• Failsafe. If the Intelligent LiPo battery is running low, or if the aircraft loses connection 

with the control system for any reason, the aircraft will automatically return to the take 

off point and land safely. 

Regardless of the means in which the aircraft is controlled, the aircraft will remain within the 

pilot's, or visual observer's, line of sight at all times. 

(Please see appendix A for additional pertinent aircraft information) 

DESCRIPTION OF SPECIFIC REGULATIONS 

14 CFR Part 21, Subpart H: Airworthiness certificates 

Subpart H, establishes the procedural requirements for the issuance of airworthiness certificates 

as required by FAR §91.203(a)(l). Given the size and limited operating area associated with the 

aircraft to be utilized by Groveland Township, an exemption from Part 21 Subpart H meets the 

requirements of an equivalent level of safety under Part 11 and Section 333 of the Reform Act. 

The Federal Aviation Act (49 USC §44701(f)) and Section 333 of the Reform Act 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 sUAS. In all cases, an analysis of these criteria demonstrates 

that the sUAS 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 

operating with an airworthiness certificate without the restrictions and conditions proposed. 

14 CFR 45.23(b): Marking of the aircraft 
will be impossible. Groveland Township will mark the sUAS with the organization

s na

e, 

physical address, and pertinent contact methods. 

14 CFR 61.113(a) & (b): Private pilot privileges and limitations: Pilot in command 

Sections 61.113(a) and (b) limit private pilots to non-commercial operations. Because the sUAS 

will not carry a pilot or passengers, the proposed operations can achieve the equivalent level of 

safety of current operations by requiring the pilot operating the aircraft to have completed a UAS 

flight training course of 100 hours before flying a sUAS. Unlike a conventional aircraft that 

carries the pilot and passengers, the sUAS is remotely controlled with no living thing or cargo on 

board. The area of operation is controlled and restricted, and all flights are planned and 

coordinated in advance as set forth in the User Guide. The risks associated with the operation of 

sUAS are so diminished from the level of risk associated with commercial operations 

contemplated by Part 61 when drafted, that allowing operations of the sUAS as requested 

exceeds the present level of safety achieved by 14 CFR 61.113(a) and (b). 

14 CFR 91.7(a): Civil aircraft airworthiness 

The regulation requires that no person may operate a civil 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 airworthiness. 

Given the size of the aircraft and the requirements contained in the User Guide for maintenance 

and use of safety checklists prior to each flight an equivalent level of safety will be provided. 

14 CFR 91.9(b)(2): Civil aircraft flight manual, marking and placard requirements 

The sUAS, given its size and configuration has no ability or place to carry such a flight manual 

on the aircraft, not only because there is no pilot on board, but because there is no room or 

capacity to carry such an item on the aircraft. The equivalent level of safety will be maintained 

by keeping the User Manual at the ground control point where the pilot flying the sUAS will 

have immediate access to it. 

14 CFR 91.103: Preflight action 

This regulation requires each pilot in command take certain actions before flight to ensure the 

safety of flight. An exemption is needed from this requirement as the pilot will take separate 

preflight actions, including checking for weather conditions, checking flight battery 

requirements, checking takeoff and landing distances, and all other actions in the User Guide and 

safety checklists. These actions will provide an equivalent level of safety. 
the aircraft via radio communications. The equiva

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neither a pilot nor passengers will be carried in the aircraft, the ability to control the sUAS via 

radio signals from the controller and by the size and speed of the aircraft. 

14 CFR 91.119: Minimum safe altitudes 

Section 91.119 establishes safe altitudes for operation of civil aircraft. Section 91.119( d) allows 

helicopters to be operated at less than the minimums prescribed, provided the person operating 

the helicopter complies with any route or altitudes prescribed for helicopters by the FAA. This 

exemption is for a multirotor craft that flies similarly to a helicopter, with vertical takeoff and 

vertical landing, which will typically operate at altitudes of200 feet above ground level (AGL), 

so an exemption may be needed to allow such operations. The sUAS will never operate at 

altitude higher than 400 AGL and all operations will occur during daylight hours under Visual 

Meteorological Conditions (VMC) only. 

The equivalent level of safety will be achieved given the size, weight and speed ofthe sUAS as 

well as the location where it is operated. No flight will be taken without the permission of the 

property owner or local officials. Because advance notice to the property owner and any onsite 

personnel, as well as the precautions outlined below, all affected individuals will be aware of the 

planned flight operations. 

Flight operations will be conducted at least 500 feet from all non-participating persons (persons 

other than the pilot in command (PIC) or visual observer (VO)), vessels, vehicles and structures, 

unless: 

1. Barriers or structures are present that sufficiently protect non-participating persons 

from debris in the event of an accident. The PIC will ensure that non-participating 

persons remain under such protection. If a situation arises where non-participating 

persons leave such protection and are within 500 feet of the sUAS, flight operations will 

cease immediately and/or; 

2. The aircraft is operated near vessels, vehicles or structures 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; 

3. Operations near the PIC or VO do not present an undue hazard to the PIC or VO, per 

14 CPR 91.119(a). 
proposed herein and carrying flammable fuel, any risk associated with our operations is far less 

than those presently presented with helicopters and other conventional aircraft operating at or 

below 500 feet AGL. In addition, the low-altitude operations of the sUAS will ensure separation 

between these UAS operations and the operations of conventional aircraft that must comply with 

Section 91.119. 

14 CFR 91.121: Altimeter Settings 

This regulation requires each person operating the aircraft to maintain cruising altitude by 

reference to an altimeter that is set " ... to the elevation of the departure airport or an appropriate 

altimeter setting available before departure." As the sUAS may not have a barometric altimeter, 

but instead a GPS and or VPS altitude read out, an exemption may be needed. An equivalent 

level of safety will be achieved by the PIC confirming the altitude of the launch site shown on 

the GPS altitude indicator before flight. 

14 CFR 91.151(a): Fuel requirements for flight in VFR conditions 

Section 91.151(a) outlines fuel requirements for beginning a flight in VFR conditions. Our sUAS 

is limited to operations in controlled environments and has a limited flight time which require an 

exemption from 14 CFR 91.151(a). The battery powering the sUAS provides approximately 25 

minutes of powered flight. This would render the sUAS unable to meet the 30 minute reserve 

requirement in 14 CFR 91.151. Given the limitations on the sUAS proposed flight area and the 

location of its proposed operations within a predetermined area, a longer time frame for flight in 

daylight VFR conditions is reasonable. 

An equivalent level of safety can be achieved by limiting flights to 20 minutes, or enough battery 

reserve to ensure that the sUAS lands at the ground station with at least 20% of battery power (as 

determined by the onboard monitoring system and the PIC), whichever happens first. This 

restriction would be more than adequate to return the sUAS to its planned landing zone from 

anywhere in its limited operating area. 

14 CFR 91.203(a) & (b): Carrying civil aircraft certification and registration 

The sUAS has no cabin, cockpit or pilot station and is operated without an onboard pilot. 

Therefore, there is no ability or place to carry certification and registration documents or to 

display them on the sUAS. 
prescribed in subpart E of this part and shall between required inspections, except as provided in 

paragraph (c) of this section, have discrepancies repaired as prescribed in part 43 of this 

chapter ... ," and others shall inspect or maintain the aircraft in compliance with Part 43. 

Given that these sections and Part 43 apply only to aircraft with an airworthiness certificate, 

these sections will not apply to Groveland Township. Maintenance will be accomplished by the 

operator pursuant to the User Guide. An equivalent level of safety will be achieved because these 

sUAS are very limited in size and will carry a small payload and operate only in restricted areas 

for limited periods of time. If mechanical issues arise, the sUAS can land immediately and will 

be operating from no higher than 400 feet AGL. As provided in the User Guide, the operator will 

ensure that the sUAS is in working order prior to initiating flight, perform required maintenance 

and keep a log of any maintenance performed. Moreover, the operator is the person most familiar 

with the aircraft and best suited to maintain the aircraft in an airworthy condition to provide the 

equivalent level of safety. 

PUBLIC INTEREST AND PRIVACY 

Approval of exemptions allowing commercial operations of sUASs for search and rescue 

operations, forward reconnaissance, and aerial command and control of large scale incidents 

enhances safety while reducing the risk to both the public and emergency responders. Manned 

aircraft, performing these same essential functions, creates a greater risk because the craft are 

much larger, have combustible fuel, and carry an onboard human pilot. In contrast, a sUAS 

weighing 5 pounds, powered by batteries, and utilizing flight systems such as GPS, VPS, and 

Failsafe, eliminates virtually all of that risk given the reduced mass and lack of combustible fuel 

carried on board. The sUAS will carry no passengers or crew and, therefore, will not expose 

them to the risks associated with manned aircraft flights. 

All flights will be conducted over the authorized areas of emergency operations, and with the 

express consent of the authority having jurisdiction. Images taken, still and motion, will be of the 

individuals operating within the boundaries of the incident, or the subject of the incident, and 

will not be used for any other purpose than to provide information for the incident commander, 

incident management team (IMT), or their designee(s). 
conventional aircraft. Groveland Township will be bound by the following limitations when 

conducting its sUAS operations under an FAA issued exemption: 

1. The sUAS will weigh less than 5 pounds. 

2. Be operated by an FAA certificated airman holding no less than a Private Pilot 

certificate and no less than a 3rd class medical. 

3. Flights will be operated within line of sight of a pilot and/or observer. 

4. Maximum total flight time for each operational flight will be 25 minutes. Flights will 

be terminated at 20% battery power reserve. 

5. Flights will be operated at an altitude of no more than 400 feet AGL. 

6. Flight operations will be conducted 5 miles from an airport and at least 3 miles from 

any city or densely populated area, which are depicted in yellow on VFR sectional charts. 

7. Flight operations within 5 miles of an airport require notification and approval from 

the local Flight Standards District Office and airport controller. 

8. Flight operations will occur during daylight hours and under visual meteorological 

conditions only. 

9. The FAA will have advance notice of all operations through the filing of notices to 

airmen (NOT AM). 

10. Minimum crew for each operation will consist of the sUAS pilot and visual observer. 

11. The pilot and visual observer will have been trained in the operation of the sUAS. 

12. The pilot and visual observer will at all times be able to communicate by voice and/or 

text. 

13. Written and/or oral permission from the relevant property holders will be obtained. 

14. Flight operations will be conducted at least 500 feet from all non-participating 

persons, vessels, vehicles and structures unless: a. Barriers or structures are present that 

sufficiently protect non-participating persons from debris in the event of an accident. The 
15. If the sUAS loses communication or loses its GPS signal, the sUAS will 

automatically return to a safe, pre-determined location and land. 

16. The sUAS will have the capability to abort flight in case ofunpredicted obstacles or 

emergencies. 

FEDERAL REGISTER SUMMARY 

• Groveland Township, 14645 Dixie Highway, Holly, MI 48442 for an exemption from part 

21 and§§ 45.23(b), 61.1 13(a) and (b), 91. 7(a), 91.9(b)(2), 91.103, 91.109, 91.119, 

91.121, 91.151(a), 91.203(a) and (b), 91.405(a), 407(a)(l), 409(a)(2), 417(a) and (b) of 

Title 14, Code ofthe Federal Regulations (14 CFR). The exemption would allow 

commercial operation of the DJI Phantom 2 sUAS to conduct urban/suburban/rural poststorm damage and casualty assessment; wilderness search and rescue; real-time aerial 

video feed of incidents where the size of the incident is large making it difficult to monitor 

changes in the incident from one place on the ground; command and control of widespread incidents; parcel assessment; infrastructure inspection; creation of orthophotos; 

three-dimensional (3D) area and structural mapping; creation of digital terrain I surface 

models; debris volume estimation; hydrology I inundation estimation. 

*************** 

Satisfaction of the criteria provided in Section 333 of the Reform Act of2012- size, weight, 

speed, operating capabilities, proximity to airports and populated areas and operation within 

visual line of sight and national security -provide more than adequate justification for the grant 

ofthe requested exemptions allowing commercial operation of Groveland Township's sUAS for 

the above listed purposes. 

d Township