May20,2015 Elite Unmanned Aerial Systems, LLC 101 Lightwater Court Aberdeen, NC 28315 785-979-8560 ELITEUAS@GMAIL.COM

U

.S. Department ofTransportation Docket Management System 1200 New JerseyAve

., SE Washington , DC 20590

Submission of RequestforAuthorization to Conduct Unmanned Aircraft Systems OperationsAllowed by Section 333 ofthe FAA Modernization and Reform Act of2012 Through the Exemption Process Identified Under 14 C.F.R. Section 11.81

FAA Regulatory Docket

NAME AND ADDRESS OF PETITIONER Elite Unmanned Aerial Systems, LLC Attn: John P

. Cross

101 Lightwater Ct. Aberdeen, NC 28315 785-979-8560 ELITEUAS@GMAIL.COMPursuantto Section 333 ofthe FAA Modernization and Reform Act of2012, Pub

. L. No. 112-95 (2012), 126 Stat. 11 ("Section 333") and the Federal Aviation Administration's ("FAA") general exemption authority under49 U.S.C. 

### § 44701 (f), Elite UAS, LLC ("Petitioner orOperator") hereby petitions for exemptions from 14 C.F.R. Part 21, 14 C

.F

.R. 

### §§ 61.113(a) and (b), 61

.133(a), 91

.7(a), 91.9(b)(2), 91.103(b)(1), 91.119(c), 91

.121, 91

.151, 91.203(a) and (b), 91.405(a), 91.409(a)(1) 91.409(a)(2). I. Petition Summary Ifgranted, this exemption would allow Elite UAS, LLC to conduct commercial unmanned aerial systems (UAS) operations forthe agriculture, oil and gas, aerial photography/videography, aerial imaging and wildlife preservation industries, within the United States National Airspace System (NAS); within Class G and occasionally E airspace. The mitigating factors listed below provide the framework for Elite UAS to operate the DJIInspire 1 in a manner equal to the safety standards setforth by the FAA for civilian manned aircraft:
• Reliability of UAS • Return to designated point in the event ofa lost control link • Return to designated point automaticallywith a low battery that is dynamically updated depending howfar awaythe UAS is from the designated point • Low weight • Slow speed • No passengers to be carried • Experienced and FAA certified pilots • Stringent maintenance program • UAS knowledge and skills test administered by an FAA approved instructor
II. Exemptions Requested The operator is requesting relieffrom the following FAA regulations:
• FAR part 21 (Certification procedures) • FAR 61

.113 (a) and (b) (Private pilot privileges and limitations) • FAR 61

.133(a) (Commercial pilot privileges and limitations) • FAR 91.7(a) (Civil aircraft airworthiness) • FAR 91

.9(b)(2) (Civil aircraftflight manual, markings, placards requirement) • FAR 91

.103(b)(1) (Preflight action) • FAR 91

.119(c) (Minimum safe altitudes)• FAR 91.121 (Altimetersettings) • FAR 91

.151 (Fuel requirements) • FAR 91.203(a) and (b) (Civil aircraft certifications required) • FAR 91.405(a) (Maintenance Required) • FAR 91.409(a)(1) and (a)(2) (Inspections)
Ill. Operational Procedures to Satisfy Section 333 1 Unmanned Aircraft System 1.1 Elite UAS seeks exemption to operate the DJIInspire 1. This UAS is the most recent model OJI offers and was a highly improved from the previous highly popular and reliable OJI Phantom series. The DJI Inspire 1 is a 6.471b multi-rotor (4 rotors) UAS with approximately 18 minutes ofendurance. The Inspire 1's purpose is to carry a small camera as its payload. The Inspire 1 has the ability to be controlled by a single crewmember acting as pilot in command by wireless remote control on a 2.4GHz band having a transmitting distance of2km (1.08nm). 1.2 The Inspire 1 is equipped with lost link protection (referred to as "Return To Home" (RTH) in the Inspire 1 User Manual), allowing the UAS to automatically climb vertically to a safe altitude to clear obstacles; then proceed to a pre-designated pointto automatically land. At anytime the UAS and the controller reestablish link, the PIC can cancel the RTH and resume control ofthe UAS. In the event of lost GPS signal, control to the Inspire UAS is not lost. All operations will be conducted underVisual Line ofSight (VLOS) ensuring the PIC can control the aircraft back to a safe location to land. 1.3 Because the Inspire 1 UAS does not have the endurance to meet the requirements of FAR 91.155(b), the operator is requesting exception from this regulation and substituted with the following standard: All flights will be terminated at a maximum ofa 25-minute flight orwhen the battery level reaches 25% (whichever occurs first). 1.4 The operatorwill registerthe UAS lAW FAR part 47. The operator's UAS will have identification makings in accordance with FAR 45(c). The Inspire 1 UAS is too small to practically display registration markings lAW FAR 45.29(a) though (e). The registration markswill be affixed as large as practical lAW FAR 45.29(f). 1.5 The operator is requesting relieffrom FAR 91.121 because the Inspire UAS is not equipped with a standard adjustable barometric altimeter system. The Inspire 1 UAS collects altitude information fortwo sources: GPS and barometric aiding. Upon powering one the Inspire 1, the system will reset the altitude readout on the controller base station to 0feet above ground level (AGL). The PIC then will reference the digitally displayed altitude in AGL forthe duration of the flight. 1.6 Because ofthe small size, lowweight, slow speed, and limited operating area ofthe Inspire 1 UAS, the operator is requesting relief from CFR part 21 (h) (airwortl:liness certificates)

.The operator has determined that it can operate the Inspire 1 UAS to an equivalent level ofsafety setforth under part 21 ofthe CFRs and meets the requirements set forth in the 333 exemption

. 1.7 Priorto flight operations the Inspire 1 UAS will be determined to be in an airworthy condition lAWthe pre-flight checklist outlined in appendixA Inspire 1 User ManualV1

.0 page 49. The operator is requesting exemption from required inspections of FAR 91.409(a) (1) and (2) and will adoptthe manufactures recommended inspections program as outlined in thefollowing paragraph. Because the FAA has not established an inspection standard for UAS as have been established for manned aircraft under FAR 43

.13 appendix D, the operator is requesting an exemption from the maintenance scope and detail of FAR 43.13 appendix D and replaced with the manufactures recommended maintenance program: The operatorwill inspect and maintain the Inspire 1 UAS lAW DJIInspire 1 Maintenance Manual (See appendix B Inspire 1 Maintenance Manual). The operatorwill follow the manufactures recommended inspection interval to preform comprehensive maintenance ofthe Inspire 1 every 50 flight hours or 200 flights, whichever comes first as outlined in the Inspire 1 Maintenance Manual. 1.8 The operatorwill adopt maintenance record requirements setforth under FAR 91.417. 1.9 The DJIInspire UAS operates on the 2.4GHz frequency band for both UAS control as well as video downlink. Both the Inspire 1 UAS as well and the UAS remote controller comply with part 15 ofthe FCC rules (see page appendixA, page 62 ofthe OJI Inspire user manual)

.The Inspire 1 is equipped with a vision positioning system along with a sonar system in orderto be able to fly inside a building and still remain stable. The Inspire 1's primary payload is a small X3 model FC350 camera mounted with a Zenmuse X3 gimbal. 1.10 Referto appendix A Inspire 1 User Manual V1.0 for more detail on the Inspire 1 UAS.2. Unmanned Aircraft Pilots in Charge (PIC) 2.1 PIC's will ata minimum, meet the following requirements priorto conducting commercial flights;
• Hold a FAA Private Pilot License • Hold a FAAthird class medical or higher • Meets the flight review requirements of FAR 61.56 in manned aircraft • Meets the recent flight experiencefor PIC of FAR 61.57 (UAS takeoff/landings) • Has accrued 25 hours total time operating the OJI Inspire 1 • Pass a knowledge and skill testwith an 80% or better administered by an FAA certified instructor 2

.2 The PIC will designate a Visual Observer (VO) priorto anyflight to be conducted. Any VO to be used bythe PIC must be designated by PIC and be present in all mandatory meetings and pre-flight rehearsals. Further, the VO shall be familiarwith UAS operations to the extenttheir designated role as VO requires. The VO will be required to communicate with the PIC verbally at all times. 2.3 Itwill be the PIGs responsibility to review weather conditions, flight battery requirements, and UAS performance limitations priorto conducting the flight. 2.4 PIC's and VO's will attend pre and postflight mission briefs which will consist ofweather information, flight information to include operational area and mission objectives, hazard mitigation actions and most importantly emergency and abort procedures; also included will be any NOTAMs or improvements to standard operating procedures through further refinements in operations. 2.5 PIC's and VO's will sign applicable documentation verifying their attendance to mandatory briefs as well as produce daily pre and postflight inspections and flight logs.
3. UAS Operating Procedures 3.1 All UAS flight operations will be conducted during daylight hours. 3.2 All UAS operations will be conducted in VFR conditions

.3

.3 No UAS operation will be conducted with less cloud clearance or visibly then is allowed by FAR 91.155. 3.4 No UAS flight operations will be conducted beyond the visual sight both the PIC and the VO. 3.5 No UASflight operation will be conducted above a vertical height of 400ftAGL. 3

.6 NO UAS flight operations will be conducted within highly populated areas. 3.7 The PIC will notfly the UAS at speeds to exceed 50KTS ground speed

. 3

.8 The PIC will insure that no person, otherthan those trained are within 500ft of horizontal distancefrom the UAS during flight operations or while the rotors are turning. 3

.9 The PIC will insure thatthe UAS in flight comes no closerthan 250ft ofvehicles or structures, with the exception ofthose that are a under direct observation as a result ofpre-negotiated services performed by Elite UAS. 3

.10 Priorto any UAS flight operation the PIC will consult current FAA aeronautical sectional charts and airportfacility directoryto insure that no flight operation will come within 5NM ofan airportwith a control tower,3NM ofan airport not having an operational control tower but having a published instrument approach procedure, 2NM of an airport not having an operational control tower or instrument approach procedure, or2NM ofa heliport having an instrument approach procedure without having an appropriate authorization from the ATC controlling facility and airport manager. 3.11 PIC will remain clear and yield right ofway to all manned aircraft operations ofall category and classes

. 3.12 The PIC priorto conducting UASflight operations will review current aeronautical charts, TFRs, and NOTAMS to insurethat no flight operations will be conducted within an active restricted area, prohibited area, warning area, orTFR. 3.13 Priorto UAS operations forthe motion picture ortelevision industry, the operatorwill comply with regulations setforth in FAA order 8900.1, Volume 3, chapter 8, section 1 (Certificate ofWaiverfor Motion Picture and Television Filming).3.14 Operatorwill obtain an AirTraffic Organization (ATO) certificate of waiver or authorization (COA) priorto conduction UAS operations. 3.15 Operator, as required by the COA, will request a NOT AM be filed for the UAS operation at least48 hours in advance, but not more than 72 hours in advance. 

### IV. Conclusion Wefeel confidentthatwith the above provided information the FAAwill find Elite UAS qualified forthe exemptions allowed under section 333 ofthe FAA Modernization and Reform Act of2012. We would be happyto answer any questions regarding this exemption request if needed.



# ~ :p:c; oss President and CEO Elite UAS