-- 6.ocH~ELLER p GROUP 

6200 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 

• SenseFiy eBee 

• SenseFiy eBee RTK 

• SenseFiy Exom 

• Sirius 

• Tarot T-15 
U.S. Department of Transportation 

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 

Page 2 

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. 

All 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, DJIInspire 1, DJIInspire 2, DJI Spreading Wings S1000, 

DJI Spreading Wings S1000+, 3D Robotics Aero-M, 3D Robotics Solo, PrecisionHawk 

Lancaster, PrecisionHawk Lancaster MK3, SenseFly eBee, SenseFiy eBee RTK, SenseFiy 

Exam, 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 

Docket Operations 

Petition for Amendment to Exemption No. 12504 

September 4, 2015 

Page 3 

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 greater than 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. All 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 VO. 

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 revised 
U.S. Department of Transportation 

Docket Operations 

Petition for Amendment to Exemption No. 12504 

September 4, 2015 

Page 4 

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 aVO 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 which 
U.S. Department of Transportation 

Docket Operations 

Petition for Amendment to Exemption No. 12504 

September 4, 2015 

the PIC is rated on his or her pilot certificate. 

Page 5 

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. All 

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 

Docket Operations 

Petition for Amendment to Exemption No. 12504 

September 4, 2015 

Page 6 

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). All 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. All 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. All 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 of 
U.S. Department of Transportation 

Docket Operations 

Petition for Amendment to Exemption No. 12504 

September 4, 2015 

Page 7 

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. All 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; 
d ' 

U.S. Department of Transportation 

Docket Operations 

Petition for Amendment to Exemption No. 12504 

September 4, 2015 

Page 8 

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, and 91. 

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, 

I:E~:RJ;;C. 

Sean L. Suttles 

sUAS Project Manager