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### 1. C H E L L IE



## IRO U 5200 Vogel Road, Evansville, Indiana 47715 • 812.479.6200

September 4, 2015
U.S. Department of Transportation Docket Operations West Building Ground Floor, Room W12-140 1200 New Jersey Ave., SE Washington, DC 20590
Electronically Submitted via www.regulations.gov

Re: Docket No. FAA-2015-1828, Petition for Amendment to Exemption No. 12504, Lochmueller Group, Inc.

Dear Sir or Madam:
Lochmueller Group, Inc. hereby requests an amendment to FAA Exemption No. 12504, Docket No. FAA-2015-1828 to allow for the use of the following sUAS (small unmanned aircraft systems) in addition to the DJI Phantom 2 Vision + sUAS, for which the original FAA exemption was granted, for the purpose of aerial data collection:

• DJI Phantom 3 • DJI Inspire 1 • DJI Inspire 2 • DJI Spreading Wings S1000 • DJI Spreading Wings S1000+ • 3D Robotics Aero-M • 3D Robotics Solo • PrecisionHawk Lancaster • PrecisionHawk Lancaster MK3 • SenseFly eBee • SenseFly eBee RTK • SenseFly Exom • Sirius • Tarot T-15U.S. Department of Transportation Page 2

Docket Operations Petition for Amendment to Exemption No. 12504 September 4, 2015

• Tarot T15 C/F Folding Octocopter • Tarot T18 UAV • Trimble UX5 • Trimble UX5 hp
The sUAS originally authorized in FAA Exemption FAA-2015-1828, The DJI Phantom 2 Vision +, is comparable in size, weight (under 55 pounds), speed, (less than 87 knots), type and operating capabilities to the requested additional sUAS's listed above.
The Applicant name and address is:
Lochmueller Group Inc. Attn: Sean L. Suttles sUAS Project Manager 6200 Vogel Road Evansville, Indiana 47715 Phone: (812)-479-6200 Fax: (812) 479-6262 Email: ssuttles@lochgroup.com
This amendment petition is, in most regards, similar to granted exemption No. 12646 (FAA Exemption No. FAA-2015-1602) in terms of requested sUAS platform types.
AII operations of the requested additional sUAS platforms will be in full compliance with the terms of Lochmueller Group, Inc.'s current FAA Exemption No. 12504 and Lochmueller Group, Inc. hereby requests to operate the requested amendment sUAS's while adhering to the conditions and limitations listed below:

1. Operations authorized by this amendment to the Exemption are limited to the DJI Phantom 2 Vision +, DJI Phantom 3, DJI Inspire 1, DJI Inspire 2, DJI Spreading Wings S1000, DJI Spreading Wings S1000+, 3D Robotics Aero-M, 3D Robotics Solo, PrecisionHawk Lancaster, PrecisionHawk Lancaster MK3, SenseFly eBee, SenseFly eBee RTK, SenseFly Exom, Sirius, Tarot T-15, Tarot T15 C/F Folding Octocopter, Tarot T18 UAV, Trimble UX5 and Trimble UX5 hp when weighing less than 55 pounds including payload. Proposed operations of any other aircraft will require a new petition or a petition to amend this exemption.U.S. Department of Transportation Page 3

Docket Operations Petition for Amendment to Exemption 

### No. 12504 September 

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2. Operations for the purpose of closed-set motion picture and television filming are not permitted.

3. The UA may not be operated at a speed exceeding 87 knots (100 miles per hour). The exemption holder may use either groundspeed or calibrated airspeed to determine compliance with the 87 knot speed restriction. In no case will the UA be operated at airspeeds greaterthan the maximum UA operating airspeed recommended by the aircraft manufacturer.

4. The UA must be operated at an altitude of no more than 400 feet above ground level (AGL). Altitude must be reported in feet AGL.

5. 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 human vision unaided by any device other than corrective lenses, as specified on the PIC's FAA-issued airman medical certificate or U.S. driver's license.

6. AII operations must utilize a visual observer (VO). The UA must be operated within the visual line of sight 

### (VLOS) of the PIC and VO at all times. The VO may be used to satisfy the 

### VLOS requirement as long as the PIC always maintains 

### VLOS capability. The VO and PIC must be able to communicate verbally at all times; electronic messaging or texting is not permitted during flight operations. 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 perform the duties required of the V0.

7. This exemption and all documents needed to operate the UAS and conduct its operations in accordance with the conditions and limitations stated in this grant of exemption, are hereinafter referred to as the operating documents. The operating documents must be accessible during UAS operations 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 revisedU.S. Department of Transportation Page 4

Docket Operations Petition for Amendment to Exemption No. 12504 September 4, 2015

documents to the Administrator or any law enforcement official upon request. The operator must also present updated and revised documents if it petitions for extension 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 an 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.

8. Any UAS that has undergone 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 prior to conducting further operations under this exemption. Functional test flights may only be conducted by a PIC with a VO and must remain at least 500 feet from other people. The functional test flight must be conducted in such a manner so as to not pose an undue hazard to persons and property.

9. The operator is responsible for maintaining and inspecting the UAS to ensure that it is in a condition for safe operation.

10. Prior to each flight, the PIC must conduct a pre-flight inspection and determine the UAS is in a condition for safe flight. The pre-flight inspection must account for all potential discrepancies, e.g., inoperable components, items, or equipment. 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.

11. The operator must follow the UAS manufacturer's maintenance, overhaul, replacement, inspection, and life limit requirements for the aircraft and aircraft components.

12. Each UAS operated under this exemption must comply with all manufacturer safety bulletins.

13. Under this grant of exemption, a PIC must hold either an airline transport, commercial, private, recreational, or sport pilot certificate. The PIC must also hold a current FAA airman medical certificate or a valid U.S. driver's license issued by a state, the District of Columbia, Puerto Rico, a territory, a possession, or the Federal government. The PIC must also meet the flight review requirements specified in 14 CFR § 61.56 in an aircraft in whichU.S. Department of Transportation Page 5

Docket Operations Petition for Amendment to Exemption No. 12504 September 4, 2015

the PIC is rated on his or her pilot certificate.

14. The operator may not permit any PIC to operate unless the PIC demonstrates the ability 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 maintaining appropriate distances from persons, vessels, vehicles and structures. PIC qualification flight hours and currency must be logged in a manner consistent with 14 CFR § 61.51(b). Flights for the purposes of training the operator's PICs and VOs (training, proficiency, and experience-building) and determining the PIC's ability to safely operate the UAS in a manner consistent with how the UAS will be operated under this exemption are permitted under the terms of this exemption. However, training operations may only be conducted during dedicated training sessions. During training, proficiency, and experience-building flights, all persons not essential for flight operations are considered nonparticipants, and the PIC must operate the UA with appropriate distance from nonparticipants in accordance with 14 CFR § 91.119.

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

16. The UA may not operate within 5 nautical miles of an airport reference point (ARP) as denoted in the current FAA Airport/Facility Directory (AFD) or for airports not denoted with an ARP, the center of the airport symbol as denoted on the current FAA-published aeronautical chart, unless a letter of agreement with that airport's management is obtained or otherwise permitted by a COA issued to the exemption holder. The letter of agreement with the airport management must be made available to the Administrator or any law enforcement official upon request.

17. 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.

18. If the UAS loses communications or loses its GPS signal, the UA must return to a predetermined location within the private or controlled-access property.

19. The PIC must abort the flight in the event of unpredicted obstacles or emergencies.U.S. Department of Transportation Page 6

Docket Operations Petition for Amendment to Exemption No. 12504 September 4, 2015

20. The PIC is prohibited from beginning a flight unless (considering wind and forecast weather conditions) there is enough available power for the UA to conduct the intended operation and to operate after that for at least five minutes or with the reserve power recommended by the manufacturer if greater.

21. Air Traffic Organization (ATO) Certificate of Waiver or Authorization (COA). AII operations shall be conducted in accordance with an ATO-issued COA. The exemption holder may apply for a new or amended COA if it intends to conduct operations that cannot be conducted under the terms of the attached COA.

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

23. Documents used by the operator to ensure the safe operation and flight of the UAS and any 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 available to the Administrator or any law enforcement official upon request.

24. The UA must remain clear and give way to all manned aviation operations and activities at all times.

25. The UAS may not be operated by the PIC from any moving device or vehicle.

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

a. Barriers or structures are present 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 are within 500 feet of the UA, flight operations must cease immediately in a manner ensuring the safety of nonparticipating persons; and b. The owner/controller of any vessels, vehicles or structures has granted permission for operating closer to those objects and the PIC has made a safety assessment ofU.S. Department of Transportation Page 7

Docket Operations Petition for Amendment to Exemption No. 12504 September 4, 2015

the risk of operating closer to those objects and determined that it does not present an undue hazard.
The PIC, VO, operator trainees or essential persons are not considered nonparticipating persons under this exemption.

27. AII operations shall be conducted over private or controlled-access property with permission from the property owner/controller or authorized representative. Permission from property owner/controller or authorized representative will be obtained for each flight to be conducted.

28. 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

. If this exemption permits operations for the purpose of closed-set motion picture and television filming and production, the following additional conditions and limitations apply.

29. The operator must have a motion picture and television operations manual (MPTOM) as documented in this grant of exemption.

30. At least 3 days before aerial filming, the operator of the UAS affected by this exemption must submit a written Plan of Activities to the local Flight Standards District Office (FSDO) with jurisdiction over the area of proposed filming. The 3-day notification may be waived with the concurrence of the FSDO. The plan of activities must include at least the following:
a. Dates and times for all flights; b. Name and phone number of the operator for the UAS aerial filming conducted under this grant of exemption;
C. Name and phone number of the person responsible for the on-scene operation of the UAS; d. Make, model, and serial or N—Number of UAS to be used;

e. Name and certificate number of UAS PICs involved in the aerial filming;U.S. Department of Transportation Page 8

Docket Operations Petition for Amendment to Exemption No. 12504 September 4, 2015

f. A statement that the operator has obtained permission from property owners and/or local officials to conduct the filming production event; the list of those who gave permission must be made available to the inspector upon request; g. Signature of exemption holder or representative; and h. A description of the flight activity, including maps or diagrams of any area, city, town, county, and/or state over which filming will be conducted and the altitudes essential to accomplish the operation.

31. Flight operations may be conducted closer than 500 feet from participating persons consenting to be involved and necessary for the filming production, as specified in the exemption holder's MPTOM
Unless otherwise specified in this grant of exemption, the UAS, the UAS PIC, and the UAS operations must comply with all applicable parts of 14 CFR including, but not limited to, parts 45, 47,61,and91.
Based on the foregoing, the Petitioner hereby requests that the FAA grant this amendment petition and provide such further relief as deemed appropriate for the operations proposed.
Since the requested amendment to Lochmueller Group, Inc.'s exemption would not set any precedent or raise any novel issues, and because the Petitioner seeks to begin these operations without delay and because the addition of these sUAS's to our fleet would not materially affect our current granted exemption No.12504 in any way, Lochmueller Group, Inc. respectfully requests the FAA to determine that good cause exists to dispense with publication of the summary of this petition in the Federal Register and grant the requested amendment expeditiously by summary means.
Please feel free to contact me if you have any questions concerning this request for an amendment to the exemption.
Sincerely, 

### LOCHMUELLER GROUP, INC.

Sean L. Suttles sUAS Project Manager