# JINOBRONISYSTAENS
LLC
June 10, 2015

U.S. Department of Transportation Docket Management System 1200 New Jersey Ave., SE Washington, Dc 20590

Re: Petition of AeroDrone Systems, LLC for Exemption Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012. To Whom It May Concern: Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 and 14 CFR Part 11, AeroDrone Systems, LLC (ADS), hereby applies for an exemption from Federal Aviation Regulations (FARs) identified below, to allow commercial operations of small unmanned aerial system (i.e., sUAS). This exemption is made based on information in this petition, the enclosed DJI UAS manufacturer's operations and/or instruction manual, DJI UAS User's manuals, DJI UAS Quick Start Guides, and any other requirements established by the FAA pursuant to Section 333 of the Reform Act. This exemption would permit commercial operation by ADS, which presently operates a DJI Phantom 3 Professional QuadCopter; however this model sUAS may not be used exclusively and may be upgraded as more advanced sUAS systems become available, but in all cases the sUAS will weigh less than the 55 pound weight limit to conduct the following operations: 1. To offer flight training to persons individually or belonging to both private and/or public organizations that have an interest in the use and application of sUAS for the purpose of the safe operation of sUAS to enhance the safety of the National Airspace System (NAS) as well as for the protection of the persons and property. 2. Aerial photography and/or video for public/private use including real estate, architecture, land surveying, and other related professional activities. 3. Aerial inspection/photography of residential/commercial structures under contract with the owners or local government's authority and permission. 4. Aerial video/photography/live video feed to assist with search and rescue operations in cases of an emergency or natural disaster only when local authorities or government has requested it by contract or donation. 5. To proactively encourage sUAS capability and safety demonstrations to the general public and local government agencies in an effort to collectively convince these organizations that the operation of sUAS is safe, controlled and in the public interest.

Page 1- ADS Exemption Request

# IINOBRONISYSTIMS

«< For your convenience, ADS has organized this exemption request as follows:
I. Petitioner's Description II. Regulations from which the exemption is requested (see attached appendix) III. Description of Proposed Operations W. Public Interest V. Federal Registry Summary VI. Conclusion VII. Attachments

I. Petitioners Description Petitioner is wholly-owned by John R. Fiandola, a U.S. citizen. Mr. Fiandola is an active FAA Rotorcraft/Helicopter Commercial Pilot with CFI Rotorcraft/Helicopter endorsement (initial CFI Sept. 1997), and a current Second Class Medical. Mr. Fiandola has 26 years of aviation experience which was acquired as a helicopter pilot with a police department and commercial operators. Mr. Fiandola is currently a contract helicopter pilot to a major Northeast police department's Environmental Protection Uit. Mr. Fiandola has also been involved in the radio controlled aircraft hobby for 30 years and has extensive experience in building, maintaining and flying radio controlled airplanes and helicopters. This combined experience and knowledge will ensure "for the safe operation of such aircraft systems in the National Airspace System" Section 333(c) of the Reform Act. The contact information for Petitioner is as follows: AeroDrone Systems, LLC 3712 Paradiso Circle Kissimmee, FL 34746-1950 Attn: John R. Fiandola Tel: 516-901-1631 E-Mail: JohnF3305@aol.com

II. Regulations from which Exemption is requested (see attached appendix) 14 CFR Part 21 subpart H 14 CFR 45.23 (b) 14 CFR 61.113 14 CFR 91.7 (a) 14 CFR 91.9 (b) (2) 14 CFR 91.103 14 CFR 91.109

Page 2- ADS Exemption Request

# JINOBBONISYSTINS
LLC

14 CFR 91.119 14 CFR 91.121 14 CFR 91.151 (a) 14 CFR 91.203 (a) (b) 14 CFR 91.205(b) 14 CFR 91.215 14 CFR 91.405 (a) 14 CFR 91.407 (a) (1) 14 CFR 91.409 (a) (2) 14 CFR 91.417 (a) (b)

III. Description of Proposed Operations The proposed operations in this petition for exemption qualify for expedited approval under Section 333 of the Reform Act. Each of the statutory criteria and other relevant factors are satisfied. The proposed operations would permit ADS the use of small sUAS under controlled conditions in airspace that is: (1) predetermined; (2) controlled as to access; and that (3) provides an increased level of safety beyond that existing when fixed or rotor wing aircraft are used to accomplish the same purpose. All sUAS operated under this exemption will have characteristics in common that warrant approval. All of the sUAS will be limited to a maximum speed of 55 m.p.h., vertical ascent speed of 15 m.p.h. and maximum weight with payload of 50 pounds. Each of the sUAS has an integrated GPS system to calculate its position and height and to relay that information via a secure connection to the sUAS operator. In addition, each sUAS contains a failsafe mode that will return the sUAS to its original starting point in the event that the secure connection from the controller to the sUAS is lost or compromised. This system permits the sUAS to return to a predetermined location and land in order to prevent injury to person(s) or damage to property. To assist the FAA in its safety assessment of Petitioner's operations, the operational limitations and conditions listed below will be adhered to at all times. l. The sUAS vehicles employed by Petitioner will weigh 50 pounds or less with payload. 2. Flights will be limited to a maximum 55 m.p.h. speed, maximum 15 m.p.h. vertical ascent speed. 3. Maximum total flight time will be limited to the flight time of the sUAS and still maintain a reserve battery power of no less than 20 percent.

Page 3- ADS Exemption Request

# AFROONgNISYSTIMS
LLC

4. Flights will be limited to a maximum altitude of 400 feet AGL and will not be conducted within navigable airspace. 5. Flights will always be within line-of-sight of the sUAS Pilot-in-Command (PIC) and camera/sensor operator (if camera/sensor operator is required) and will take place in day VFR conditions only. 6. The PIC will have, at a minimum, a FAA private Pilot's license and current Third Class medical certificate, however the petitioner will be the sole operator of all sUAS at this time and exceeds the current proposed standard with a FAA Commercial Pilots license and current Second Class Medical certificate. 7. Flights will be operated at a lateral distance of at least 100 feet from any inhabited structures, buildings, vehicles, vessels or person(s) not associated with the operation who have not given prior permission for more proximate operation. $. Prior to flight, the sUAS and related equipment will be pre-flight checked to determine that all is in working order and can accomplish the proposed flight in a safe manner. 9. The sUAS will operate in accordance with the safety and operational requirements of their respective flight manuals. 10. A mission plan will be prepared setting forth the limitations for each flight as well as contact information. 11.All required permissions and permits, if necessary, will be obtained from state, county or city jurisdictions, including local law enforcement, fire or other appropriate governmental agencies; and from any commercial or private property owners/residents who may be impacted by any flight. 12. If the sUAS loses secure communications from the controller, the sUAS will have the capability to return to a predetermined location and land in order to prevent injury to person(s) or damage to property. 13. The sUAS has the capability to abort a flight in case of unpredicted obstacles, weather or emergencies. 14.ADS will insure that all flights will be conducted in accordance with any federal, state or local laws regarding privacy. 15.Petitioner has policies in place to ensure that no person may act as PIC, observer, or sensor operator if they are under the influence of any alcohol or any drug.

IV. Public Interest Granting Petitioner's exemption request furthers the public interest. National policy set by Congress favors early integration of sUAS into the national airspace in controlled, safe working environments such as those proposed in this petition. In addition, the public has an interest in reducing the hazards and emissions associated with the use of manned helicopters to conduct similar operations. The sUAS proposed for this exemptions are very light, 5-7 pound gross weight, well under the FAA maximum of 55 pounds. They do not carry flammable fuel which further reduces any risk from a potential accident. The sUAS proposed by Petitioner can be used in all areas of real estate, including commercial, residential and industrial properties. The use of sUAS in place of manned helicopters, where

Page 4- ADS Exemption Request

# JIBOBBONISYSTIMS LLC appropriate, will allow real estate professionals of all levels be able to afford to have videos, and photos that give a unique perspectives of properties to promote them in their best light. Petitioner will also be willing to coordinate with federal, state and local governments after a disaster and be willing to render any and all assistance that can be provided by sUAS that may not be possible by manned aircraft. Finally, Petitioner would like to donate his time to demonstrate the safety, utility and efficiency of sUAS to the public, FAA, any local government, law enforcement or firefighting agency, or school to educate them on the integration of sUAS in the National Airspace System.
V. Federal Registry Summary Pursuant to 14 CFR Part 11, the following summary is provided for publication in the Federal Register, should it be determined that publication is needed: Petitioner seeks an exemption from the following rules: 14 CFR Part 21 subpart h, 14 CFR 45.23(b), 14 CFR 61.113, 14 CFR 91.7(a), 14 CFR 91.9 (b)(2), 14 CFR 91.103(b), 14 CFR 91.109, 14 CFR 91.119, 14 CFR 91.121, 14 CFR 91.151(a), 14 CFR 203(a)(b), 14 CFR 91.205(b), 14 CFR 91.215, 14 CFR 91.405(a), 14 CFR 91.407(a)(1), 14 CFR 91.409 (a)(2), 14 CFR 91.417(a)(b) The exemption will enhance safety by reducing risk to the general public and property owners from the potential hazard posed doing the same operations with conventional aircraft and helicopters.
VI. Conclusion Satisfaction of the criteria provided in Section 333 of the Reform Act of 2012 provides more than adequate justification for the grant of the requested exemptions to permit Petitioner to operate the described sUAS in the NAS while reducing risk to the general public and property

C~]~.+flNRI The operation of this sUAS will provide and equivalent level of safety, supporting the grant of the exemptions requested herein, including exempting the applicant from the requirements of several regulations and allowing commercial operations. These lightweight sUAS operate at slow speeds and close to ground, as a result they are far safer than conventional aerial survey and inspection operations conducted with fixed wing aircraft or helicopters.

Page 5- ADS Exemption Request

# JINVORONISYSTINS «C

VII. Attachments 1. Regulations from which the exemption is requested. 2. Phantom 3 Professional Quick Start Guide 3. Phantom 3 Professional User Manual V1.2 4. Phantom 3 Professional Safety Guidelines and Disclaimer 5. Phantom 3 Professional Intelligent Flight Battery Safety Guidelines

If any additional information is required, or if you have any questions regarding this Petition for Exemption, please contact the undersigned.

Sincerely,

John R. Fiandola, owner AeroDrone Systems, LLC Cell Phone: 516-901-1631 Email: JohnF3305@aol.com

Page 6- ADS Exemption Request

# JINOBBONISYSTIMS

LLC

CFR Section Subject Justification 14 CFR 45.23(b) Requirement to display Insufficient space on sUAS registration number on sUAS 14 CFR Part 21 subpart H Aircraft certification Designed for manned flight, requirements and procedures not suitable for off-the-shelf sUAS
14 CFR 61.113 Requirement for pilot Part 61 requirements are certificate designed for manned aircraft; however petition will exceed current FAA pilot certification requirements 14 CFR 91.7(a) Airworthiness requirement Designed for manned aircraft, not suitable for off-the-shelf sUAS 14 CFR 91.9(b)(2) Requirement for airplane or No room on sUAS, but the rotorcraft flight manual to sUAS flight manual, be on aircraft registration certificate and any other required documents will be kept with the PIC during flight 14 CFR 91.103(b) Requirement for crew sUAS is unmanned aerial members to be onboard vehicle incapable of holding during flight crew members
14 CFR 91.109 Requirements for dual sUAS is unmanned aerial controls during flight vehicle, however during flight instruction instruction the student and flight instructor can share a common remote controller with no compromise in safety
14 CFR 91.119 Minimum safe altitudes for Maximum altitude of sUAS is flight 400 feet, which is below the minimum safe altitude of 500 feet and PIC has altitude information on the control unit

Attachment 1: Regulations from Which the Exemption is Requested Page 1

# JINOBBONISYSTIMS

LLC

CFR Section Subject Justification

14 CFR 91.121 Altimeter settings No barometric altimeter on board sUAS, however control unit has GPS altitude readout 14 CFR 91.151(a) Fuel requirements Minimum fuel requirements do not apply to sUAS as battery life is below the minimum fuel required, however PIC sUAS control unit has an information readout that displays remaining battery life and the sUAS will land with a minimum of 20% battery life 14 CFR 91.203(a)(b) Requirement for registration No room on sUAS, but the and airworthiness registration certificate and any certificates to be on board other required documents will be kept with the PIC during flight 14 CFR 91.205(b) Cockpit instruments No one on board to read, however PIC has a readout on the control unit that gives airspeed, altitude, climb rate, heading, remaining battery life, GPS signal strength and other information to insure a safe flight
14 CFR 91.215 Transponder requirement No room on the sUAS, will also be operated below ATC radar coverage 14 CFR 91.405(a) Inspection requirements Designed for manned aircraft, not suitable for off-the-shelf sUAS however sUAS will be maintained as per the user manual, safety guidelines and battery safety guidelines

Attachment 1: Regulations from Which the Exemption is Requested Page 2

# IFROBBONISYSTIMS
LLC

CFR Section Subject Justification 14 CFR 91.407(a)(1) Inspection approval Designed for manned aircraft, requirements not suitable for off-the-shelf sUAS however sUAS will be inspected as per the user manual, safety guidelines and battery safety guidelines 14 CFR 91.409(a)(2) Airworthiness inspection Designed for manned aircraft, not suitable for off-the-shelf sUAS however sUAS will be inspected as per the user manual, safety guidelines and battery safety guidelines 14 CFR 91.417(a)(b) Maintenance records Designed for manned aircraft, requirements not suitable for off-the-shelf sUAS however maintenance records will be kept to show any repair work, required software/firmware upgrades, battery charge history as per the sUAS manufacturer

Attachment 1: Regulations from Which the Exemption is Requested Page 3