ADDENDUM TO 333 EXEMPTI ON FIREFLY AERIAL PHOTOGRAPY SERVI CES LLC DOCKET#: FAA
- 2015
- 5548 Dear, Michael Cameron or FAA Official, In response to the email on 1/15/2016 from Michael Cameron requesting additional information in the 333 exemption request for Firefl y Aerial Photograph y S ervices Docket No. FAA

- 2015
- 5548, IDaniel R. Otte Owner of Firefly Aerial Photography

Services LLC do submit the following addendum of Aircraft make, model and ty pe, to Petition # FAA

- 2015
- 5548: **The following Exhibits are add ed to this petition:**  **Exhibit 2**

**– Phantom 2 V2 User Manual**  **Exhibit 3**

**– Phantom 2 V2 Features**  **Exhibit 4**

**– Phantom 3 Professional specs**  **Exhibit 5**

**– E 384 Preflight procedures**  **Exhibit 6**

**– E 384 Pre Flight Checklist**  **Exhibit 7 -**  **E 384 Flight Checklist Exhibit 8** 

**– Lancaster User’s Manual**  **Exhibit 9**

**– QR X900 Quick Start Guide**  **Exhibit 10 -**  **MPTOM**

**– Firefly Aerial Photography Services ** **

****** **Exhibit 10 will be submitted confidentially to 333exemptions@FAA.gov** 
**I. Publishable Summary**  Pursuant to 14 C.F.R. § 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 C.F.R 21(h); 14 C.F.R. 43.7; 14 C.F.R. 43.11; 14 C.F.R. 45.11; 14 C.F.R. 45.27; 14 C.F.R. 45.29; 14 C.F.R. 91.7(a); 14 C.F.R. 91.9(b)(2); 14 C.F.R. 91.9(c); 14 C.F.R. 91.103(b)(2); 14 C.F.R. 91.105; 14 C.F.R. 91.109; 14 C.F.R. 91.113(b); 14 C.F.R. 91.119 (c); 14 C.F.R. 91 .121; 14 C.F.R. 91.151(a); 14 C.F.R. 91.203(a) and (b); 14 C.F.R. 215; 14 C.F.R. 91.403; 14 C.F.R. 91.405(a); 14 C.F.R. 91.407(a)(1); 14 C.F.R. 409(a)(1) and (2); and 14 C.F.R. 91.417(a) and (b) to operate commerciall y a small unmanned aircraft sy stem (UA ) (6 lbs. or less).Approval of the exemption requested b y petitioner will allow commercial operation of

**1). Phantom 2 V2 ,**  **rotorcraft 2) Phantom 3 Professional,**  **rotorcraft, 3). Event 38 E384,**  **Fixed wing 4). Precision Hawk Lancaster,**  **fixed wing and 5). Walkera QR X900**  **rotorcraft sUAS**  for real estate photograph y, remote sensing to support (i) precision farming and other agriculture applications; (ii) asset management for utilities, government agencies, and private firms; (iii) construc tion and land management; (iv) disaster response and search and rescue; as well as (v) conducting research flights to collect data and establish and refine forensic processes, procedures, and tools for investigation of accidents and crimes involving UAs,(v i) real estate photograph y; and (vii) aerial cinematography photograph y for the motion picture/television industry and sports photography

in Class G airspace or as otherwise prescribed in an ATO issued COA nationwide. The requested exemption should be granted because operation of small UAs, weighing no more than 55lbs. (24 kg.), inclusive of battery and payload, conducted in the strict conditions outlined below, will provide an equivalent level of safety, while still allowing commercial operations. The lightweight aircraft covered by the exemption are far safer than conventional operations conducted with helicopters and fixed

- wing aircraft weighing thousands of pounds and carrying highl y flammable fuel, and operating in close proximity to the ground and peo ple. The seven factors Congress directed the FAA to consider when approving Section 333 exemption petitions

- size, weight, speed, operational capability , proximity to airports, proximity to populated areas, and operation within visual line of sight

– each support the request. In particular, the aircraft are small, and will operate at slow speeds, and close to the ground in order to more safel y and efficientl y conduct operations that would otherwise involve a risk of death to the inspectors. The substantial increase of safet y and decrease of risk to human life, coupled with the low risk use of UAs to conduct these operations, weigh heavily in favor of granting the exemption. **II. Petitioner’s Contact Information** Daniel R. Otte Owner Firefl y Aerial Photography Services LLC [FFAPS] W3303 State Road 28 Sheboygan Falls, WI 53085 **III. Proposed Operations A. The UAs**  The requested exemption will permit petitioner to operate **1). Phantom 2 V2, rotorcraft**  **2) Phantom 3 Professional,**  **rotorcraft, 3). Event 38 E384,**  **Fixed wing 4). Precision Hawk**  **Lancaster, fixed wing**  **and 5). Walkera QR X900 rotorcraft**  **sUAS** and will be operated as otherwise prescribed in an Air Traffic Organization (“ATO”) issued COA and all other FAA requirements.**1. DJI Phanto**  **m 2 V2**

The requested exemption will permit petitioner to operate the Phantom 2 V 2 , with a maximum weight of approximately

2.7 lbs. (1.2 kg), inclusive of batteries and technical payload. This rotorcraft operates at a speed of no more than 43 knots and has the capability to hover and move in the vertical and horizontal planes simultaneo usly

. Please refer to Exhibits 2
- for further information about the airframe, control sy stem and transmitter. The FAA has previously reviewed these documents and approved exemptions for commercial use of the DJI Phantom 2 Vision+ in Exemption Nos. 11138 , 11189, and 11191. The UA will have the following specifications or equivalent: Airframe: DJ I Phantom 2 V2 Dimensions: diagonal motor

- motor distance 350 mm (approximately 13.78 in.) Flight Control Sy stem: DJINaza
- M V2, which includes the GPS and Compa ss and the internal measurement unit (IMU), containing a built

- in internal sensor and a barometric altimeter that measures both altitude and attitude. Transmitter (Tx): 5.728GHz

- 5.85 GHz DJIRemote Control Receiver (Rx): 5.8G receiver built in to the DJI Phantom 2 Vision+ Motor: electric DJ I 2312 CCW Data Link: 2.4 GHz USB ground modem Video L ink: 5.8 GHz OSD: DJIVision app, open on a dedicated mobile device, which allows live telemetry to be display ed to the visual observer, including the battery level and altitude Batteries: L ithium Poly mer batteries with capacity of 5200mAh Please refer to Exhibit 2
- 3 for further information about the airframe, control sy stem and transmitter. The FAA has previously reviewed these documents and approved exemptions fo r commercial use of the DJI Phantom 2.
**2 .**  **DJI Phantom 3 Professional** The requested exemption will permit petitioner to operate the Phantom 3 Professional with a maximum weight of approximately 2.7 lbs. (1.2 kg), inclusive of batteries and technical payload. This rotorcraft operates at a speed of no more than 43 knots and has the capability to hover and move in the vertical and horizontal planes simultaneously

. Please refer to Exhibit 4 for further information about the airframe, control sy stem and tr ansmitter. The FAA has previously reviewed these documents and approved exemptions for commercial use of the DJI Phantom 3 Professional.The UA will have the following specifications or equivalent:

Airframe: DJ I Phantom 3 Professional Dimensions: diagonal size (including propellers) 590 mm Weight (including battery and propellers) 1280g Flight Control Sy stem: DJINaza
- M V2, which includes the GPS and Compass and the internal measurement unit (IMU), containing a built

- in internal sensor and a barometric altimeter that measures both altitude and attitude. Operating frequency : 2,400 GHz
- 2.483 GHz GPS Mode: GPS/Glonass Transmitter Power: FCC

- 20dBm, CE

- 16 dBm Video L ink: 2
. 4 GHz OSD: DJI GO app, open on a dedicated mobile device, which allo ws live telemetry to be display ed to the visual observer, including the battery level and altitude Batteries: L ithium Poly mer batteries with capacity of 5200mAh **3 . Event38 E384**  The requested exemption will permit petitioner to operate the Event 38 E384, with a maximum weight of 5.9 lbs. (2.7 kg.), inclusive of batteries and technical payload. This f ixed wing aircraft operates at a speed of no more than 26 knots. Please refer to 5
- 7 for further information about the airframe, control sy stem and transmitter. The FAA has previousl y approved the E384 for commercial flight in Exemption No. 11166. The UA will have the following specifications or equivalent: Airframe: E384 Control Sy stem: ArduPilot Mega 2.6 autopilot, which includes the Main Control ler (MC), Internal Measurement Unit (IMU) with a built

- in internal sensor, barometric altimeter (which measures attitude and altitude), compass, GPS, and radio receiver (Rx). Tx: Spektrum DX5E Rx: AR 610 Receiver Motors: Tiger T

- Motor 3515
- 9 Data Link: 3D R 433mhz radio OSD: Mission Planner software, visible on a dedicated ground station laptop, which allows live telemetry to be displayed to the visual observer, including the battery level and altitude. Batteries: L ithium Poly

mer batteries with capacity of 5000 mAh **3. PrecisionHawk Lancaster System** The requested exemption will permit petitioner to operate the PrecisionHawk LancasterSy stem. Please refer to Exhibit 8 for information about the airframe and control sy stem,

i ncluding the UA specifications, which are proprietary business information. The FAA has previously

approved the PrecisionHawk for commercial flights in Exemption No. 11345. **4. Walkera QR X900** The requested exemption will permit petitioner to operate the Walkera QR X900 sy stem. Please refer to Exhibit 9 for information about the airframe and control s ys tems, including the UA specifications. Airframe: QR X900 Weight: 6.95 kg (Battery included) Main Controller: FCS

- RX705 Landing gear: Retractable Parachute: Yes (Dropsafe) Thank You for your time and attention towards approval of this exemption. Daniel R. Otte Owner Firefl y Aerial Photography Services LLC W3303 State Road 28 Sheboygan Falls WI 53085