Technology integration systems, LLC

2751 FL­121

Morriston, FL 32668

U.S. Department of Transportation

Docket Management System

1200 New Jersey Ave., SE

Washington, DC 20590

RE: Exemption Request Section 333 of the FAA Reform Act of 2012

References:

1) FAA Exemption No. 11138, Regulatory Docket No. FAA20140481in the matter of the petition of DOUGLAS TRUDEAU

2) FAA Exemption No. 11136, Regulatory Docket No. FAA–2014–0508 in the matter of the petition of ADVANCED

AVIATION SOLUTIONS LLC

3) FAA Exemption No. 11080 Regulatory Docket No. FAA20140355 in the matter of the petition of FLYING CAM INC

4) Inspire 1 User Manuals ­ http://www.dji.com/product/inspire­1/download

5) DJI Matrice 1 User manual ­ https://developer.dji.com/matrice­100/downloads/

6) DJI Phantom 3 Professional manuals ­ http://www.dji.com/product/phantom­3/download

7) Zagi 60 manual ­ http://www.zagi.com/pdf/Zagi­60w.pdf

8) 3D Robotics Pixhawk manual ­ https://3drobotics.com/kb/pixhawk/

Dear Sir or Madam,

In accordance with the FAA’s Guidelines for Submitting a Petition for Exemption

under section 333 of the FAA Modernization and Reform Act of 2012 ,Technology integration systems, LLC, referred

to hereafter as the petitioner, request exemption from the following sections of Title 14, Code of Federal Regulations

§§ 61.113(a); 61.113(b); 91.119(c); 91.121; 91.151(a); 91.405(a); 91.407(a)(1); 91.409(a)(1); 91.409(a)(2); 91.417(a)&(b);

In order to operate small unmanned aircraft systems (UAS) commercially in airspace regulated by the Federal

Aviation Administration (FAA) for the purposes of aerial data collection and other flight operations that could be

performed safely and more cost effectively with the use of small UAS at low altitude within the U.S. national airspace

system as compared to a manned aircraft. Operations will be performed only at the request of and with the

authorization and permission of clients or their authorized agents in order to facilitate commerce and raise awareness

of the beneficial uses of small unmanned air systems. So long as such operations are conducted within and

under the conditions outlined herein or as may be established by the FAA as required by Section 333. The conditions

identified and proposed by the petitioner are drawn from references 1­3.
The FARs

The petitioner seeks exemption from the above mentioned FARs for the following reasons;

61.113(a) & (b); The petitioner requests relief in order to facilitate the utilization of pilots, who hold a SPORT

PILOT (or greater) certificate. Any pilots operating under this exemption would be required to comply with any

conditions as set forth and in a similar fashion to the previously granted exemptions.

91.119(c) As discussed in Exemption 11138 (DOUGLAS TRUDEAU), operations conducted closer than 500

feet to the ground may require that the UA be operated closer than 500 feet to essential persons, or objects that

would not be possible without additional relief. The petitioner requests modification, waiver or exemption and

clarification concerning the terms “congested areas” and “densely populated”. The petitioner requests waiver for this

condition to allow reasonable and responsible operations in areas of subdivisions and neighborhoods if required.

91.121 As discussed in Exemption 11138 (DOUGLAS TRUDEAU) is inapplicable since the UAS does not

have an altimeter and instead utilizes electronic GPS with a barometric sensor for altitude information.

91.151(a) As discussed in Exemption 11136 (ADVANCED AVIATION SOLUTIONS LLC) prior relief has

been granted for manned aircraft to operate at less than the prescribed minimums, including Exemption Nos. 2689,

5745, and 10650. In addition, similar UAS specific relief has been granted in Exemption Nos. 8811, 10808,

and 10673 for daytime, VFR conditions. The UAS provides battery power remaining in percent to the PIC. The UA

batteries provide approximately 25 minutes of powered flight. Information provided in the operating documents

discusses procedures regarding remaining battery power management. Those documents contain a condition in

which the PIC will initiate a landing procedure when battery remaining reaches a specified level. Given the limitations

on proposed operations and the location of those proposed operations, The FAA found that a reduced minimum

power reserve for flight in daytime VFR conditions was reasonable.

91.405(a); 91.407(a)(1); 91.409 (a)(1) & (2); 91.417(a) & (b) As discussed in Exemption 11138 (DOUGLAS

TRUDEAU), The petitioner proposes to inspect and ensure that the UAS is in a condition for safe flight in accordance

with the operating documents. The FAA found that adherence to the petitioner’s operating documents and the

conditions and limitations specified, describing the requirements for maintenance,inspection, and recordkeeping,

were sufficient to ensure that safety would not be adversely affected.

The UAS

The DJI Inspire 1, DJI Marice 1, DJI Phantom 3 professional are highly successful consumer grade small

rotorcraft in the quadcopter configuration. All are designed primarily to carry aloft a high definition digital camera. All

utilize an internal inertial measurement (IMU) with integrated barometric sensor and augmented with global

positioning system (GPS) to maintain geospatial orientation and position. They are controlled primarily through an

FCC certified radio control (RC) unit. Real time video and telemetry information is transmitted back to a ground

control station allowing the operator and/or PIC to monitor battery level, GPS signal strength, altitude (GPS and

BARO), distance from PIC, camera imagery, and control camera angle. All have failsafe modes of operation for either

loss of RC or GPS signal. Altitude can be limited by the onboard flight controller and maximum altitude can be

preprogrammed by the PIC. Battery life limits flight times (See below for aircraft specifics). The onboard flight

controller will warn the pilot via telemetry and external lighting cues before reaching a low battery state. An automatic

termination of flight and landing will be initiated when the battery reaches a predetermined low state.. More

information is available in the attachments below.
The Zagi 60 is a highly successful hobby grade fixed wing model aircraft, in the flying wing configuration,

with a tail mounted pusher type motor. It is constructed of EPP foam, wood and mylar. It will utilize the 3D robotics

inc. Pixhawk flight controller and be controlled primarily through an FCC certified radio control (RC) unit to carry aloft

a high definition digital camera. It has the capability to transmit real time telemetry data back to a ground control

station, including position, speed, power management data,battery level, GPS signal strength, altitude (GPS and

Baro), distance from PIC. It has failsafe modes of operation for either loss of RC or GPS signal. Maximum altitude

and geofencing options can be preprogrammed by the Operator/PIC. Battery life limits flight times to approximately

20 minutes. The onboard flight controller will warn the pilot via telemetry before reaching a low battery state. An

automatic termination of flight and landing will be initiated when the battery reaches a predetermined low state with

no input from the PIC.

Risk mitigation

The petitioner has reviewed FAA exemptions reference’s 13 Conditions and Limitations section and believes that the

procedures specified therein are reasonable and will be utilized in order to manage and mitigate risk and ensure

public safety. A preflight checklist will be developed and employed to ensure that the UA airworthiness will be verified

before launch. Airworthiness will be maintained by performance of routine inspections before each flight, maintaining

flight and maintenance logs to record time on failure prone components. The petitioner request that in a manner

similar to reference 3, he be allowed to operate within 5 miles of an airport provided that;

“ The UA may not operate in Class B, C, or D airspace without written approval from the FAA. The UA may

not operate within 5 nautical miles of the geographic center of a non towered airport as denoted on a current FAA

published aeronautical chart unless​a letter of agreement with that airport’s management is obtained, and the

operation is conducted in accordance with a NOTAM as required by the operator’s COA. The letter of agreement with

the airport management must be made available to the Administrator upon request .”

Operations within 5 miles of an airport are not anticipated to be routine but the petitioner is requesting a mechanism

to facilitate such activities without requesting a new and separate exemption(s) should the need arise. Operations

within class B airspace are not requested due to the lack of mode C transponder.

Public interest

Use of the UAS in lieu of a manned aircraft would enhance safety and reduce the environmental impact as

compared to similar operations conducted with manned aircraft of greater proportions, carrying a crew and flammable

fuel. Additionally, use of the UAS in order to facilitate commerce could lead to economic growth. Operations for this

petition will enable service for property owners or their designees seeking an enhanced perspective for

characteristics, amenities, crop health and benefits of their desired photographic subjects that cannot be displayed

through ground level videography/photography. Aerial photography is a valuable tool that can lead to increased

commerce and enhance productivity. The petitioner will provide clients with photographic data for these purposes on

a ‘for hire’ basis. A visual observer will be utilized. Liability insurance will be obtained commensurate with the granting

of this request for exemption. Flight data including UA flight time, Control Unit operation time, incident, accident, and

details concerning any deviations from normal operations will be available to FAA for use in collecting data regarding

the use of UAS as part of this application. This data may be submitted to FAA via traditional means, e.g. COA

Monthly Reports, or other means as required.
Conclusion

The petitioner is requesting this exemption for the purposes of “aerial data collection”. The reason for such a

general and broad based request is that the petitioner wishes to utilize a business strategy of horizontal integration

and maximize economies of scope in order to capitalize on opportunities as they may arise in the future without

the long turnaround time associated with additional exemptions. The petitioner's business model is based on the idea

of offering ad hoc small UAS services to individuals or companies who wish to employ these services as a safe,

effective, and legal option to enhance their business or hobby. The petitioner’s own market research

shows pent up demand for these services currently exists. The primary purpose of seeking this exemption is to obtain

the capability to offer those services while remaining in compliance. The petitioner is an LLC that is owned by an

individual with numerous years of experience in general and commercial aviation and holds an airman certificate,

COMMERCIAL PILOT, as well as current FAA medical certificate.

Respectfully submitted,

Dennis Stiles,

Owner

Technology integration

systems, LLC
DJI Matrice 100

https://developer.dji.com/matrice­100/specs/

Structure

Diagonal Wheelbase 650 mm

Weight (with TB47D battery) 2355 g

Weight (with TB48D battery) 2431 g

Max. Takeoff Weight 3400 g

Expansion Bay Weight 45 g

Battery Compartment Weight 160 g

Zenmuse X3 Gimbal with Camera

Weight

247 g
Performance

Hovering Accuracy (P­Mode With GPS) Vertical: 0.5 m, Horizontal: 2.5

m

Max. Angular Velocity Pitch: 300°/s, Yaw: 150°/s

Max. Tilt Angle 35°

Max. Speed of Ascent 5 m/s

Max. Speed of Descent 4 m/s

Max. Wind Resistance 10 m/s

Max. Speed 22 m/s (ATTI mode, no

payload, no wind)

17 m/s (GPS mode, no

payload, no wind)

Hovering Time (with TB47D battery) No payload: 22 min; 500g

payload: 17 min;1kg payload:

13 min

Hovering Time (with TB48D battery) No payload: 28 min; 500g

payload: 20 min;

1kg payload: 16 min

Hovering Time (with two TB47D batteries) No payload: 33 min

Hovering Time (with two TB48D battery) No payload: 40 min

Hovering Time (with TB47D battery and Zenmuse X3) No payload: 19 min

Hovering Time (with TB48D battery and Zenmuse X3) No payload: 23 min

Propulsion System

Motor Model DJI 3510

Propeller Model DJI 1345s

ESC Model DJI E SERIES 620D

Flight Control System Model N1
Other Operating Temperature ­10°C to 40°C

Remote Controller

Name C1

Operating Frequency 5.725~5.825 GHz

922.7MHz~927.7 MHz (Japan)

2.400~2.483 GHz (Lightbridge)

Transmission Distance CE: 3.5 km

FCC: 5 km (unobstructed and no

interference)

EIRP 10dBm@900M

13dBm@5.8G

20dBm@2.4G

Video Output USB、Mini­HDMI

Power Supply Built­in battery

Charger DJI approved charger

Dual Users Capability Master­and­Slave control

Mobile Device Holder Supports smartphones and

Battery (Standard/Optional)

Name Intelligent Flight Battery

Model TB47D/TB48D

Capacity 4500/5700 mAh mAh

Voltage 22.2 V

Type LiPo 6S

Energy 99.9/129.96 Wh

Net Weight 600/670 g
DJI Inspire 1
Aircraft

Weight (Battery Included)

2935 g

Hovering Accuracy (GPS Mode)

Vertical: 0.5 m

Horizontal: 2.5 m

Max Angular Velocity

Pitch: 300°/s

Yaw: 150°/s

Max Tilt Angle

35°

Max Ascent Speed

5 m/s

Max Descent Speed

4 m/s

Max Speed

22 m/s (ATTI mode, no wind)

Max Service Ceiling Above Sea Level

4500 m (Software altitude limit: 120 m above takeoff point)

Max Wind Speed Resistance
10 m/s

Max Flight Time

Approximately 18 minutes

Motor Model

DJI 3510H

Propeller Model

DJI 1345T

Indoor Hovering

Enabled by default

Operating Temperature Range

­10° to 40° C

Diagonal Distance

559 to 581 mm

Dimensions

438x451x301 mm

Power Spectral Density

9.06mW/MHz

Gimbal Model

ZENMUSE X3
Operating Current

Station: 750 mA

Motion: 900 mA

Angular Vibration Range

±0.03°

Mounting

Detachable

Controllable Range

Pitch: ­90° to +30°

Pan: ±320°

Mechanical Range

Pitch: ­125° to +45°

Pan: ±330°

Max Controllable Speed

Pitch: 120°/s

Pan: 180°/s

Camera Name

X3

Model

FC350
Total Pixels

12.76M

Effective Pixels

12.4M

Image Max Size

4000x3000

ISO Range

100­3200 (video)

100­1600 (photo)

Electronic Shutter Speed

8s - 1/8000s

FOV (Field Of View)

94°

CMOS

Sony EXMOR 1/2.3”

Lens

20mm (35mm format equivalent)f/2.8 focus at ∞

9 Elements in 9 groups

Anti­distortion

Still Photography Modes
Single shoot

Burst shooting: 3/5/7 frames

Auto Exposure Bracketing (AEB): 3/5 bracketed frames at 0.7EV Bias

Time­lapse

Video Recording Modes

UHD (4K): 4096x2160p24/25, 3840x2160p24/25/30

FHD: 1920x1080p24/25/30/48/50/60

HD: 1280x720p24/25/30/48/50/60

Max Bitrate Of Video Storage

60 Mbps

Supported File Formats

FAT32/exFAT

Photo: JPEG, DNG

Video: MP4/MOV (MPEG­4 AVC/H.264)

Supported SD Card Types

Micro SD

Max capacity: 64 GB. Class 10 or UHS­1 rating required.

Operating Temperature Range

0° to 40° C
Remote

Controller

Name

C1

Operating Frequency

922.7~927.7 MHz (Japan Only)

5.725~5.825 GHz

2.400~2.483 GHz

Maximum Transmitting Distance

Up to 5 km or 3.1 miles (unobstructed, free of interference) when FCC compliant

EIRP

10dBm@900m, 13dBm@5.8G, 20dBm@2.4G

Video Output Port

USB, mini­HDMI

Power Supply

Built­in battery

Charging

DJI charger

Dual User Capability

Host­and­Slave connection

170mm

Output Power
9 W

Operating Temperature Range

­10° to 40° C

Battery

6000 mAh LiPo 2S
Battery

(Standard)

Name

Intelligent Flight Battery

Model

TB47

Capacity

4500 mAh

Voltage

22.2 V

Battery Type

LiPo 6S High voltage battery

Energy

99.9 Wh

Net Weight

570 g

Max Charging Power

180 W
Battery

(Optional)

Name

Intelligent Flight Battery

Model

TB48

Capacity

5700 mAh

Voltage

22.8 V

Battery Type

LiPo 6S

Energy

129.96 Wh

Net Weight

670 g
DJI Phantom 3 professional

F
Aircraft Weight (Including Battery And Propellers)

1280 g

Diagonal Size (Including Propellers)

590 mm

Max Ascent Speed

5 m/s

Max Descent Speed

3 m/s

Hover Accuracy

● Vertical: +/­ 0.1 m (when Vision Positioning is active) or +/­ 0.5 m

● Horizontal: +/­ 1.5 m

Max Speed

16 m/s (ATTI mode, no wind)

Max Service Ceiling Above Sea Level

6000 m (Software altitude limit: 120 m above takeoff point)

Operating Temperature

0°C to 40°C

GPS Mode

GPS/GLONASS
Vision Positioning Max Velocity

Less than 8 m/s (when 2 m above ground)

Altitude Range

50 cm­300 cm

Operating Range

50 cm­300 cm

Operating Environment

Surface with clear pattern and adequate lighting (Lux > 15)

Remote Controller Operating Frequency

2.400 GHz­2.483 GHz

Max Distance

Up to 5 km or 3.1 miles (unobstructed, free of interference) when FCC compliant

Up to 3.5 km or 2.1 miles (unobstructed, free of interference) when CE compliant

Battery

6000 mAh LiPo 2S
Receiver Sensitivity (1%PER)

­101 dBm ±2 dBm

Transmitter Power (EIRP)

FCC: 20 dBm

Working Voltage

1.2 A @7.4 V

Battery Charger Voltage

17.4 V

Rated Power

100 W

Intelligent Flight Battery Capacity

4480 mAh

Voltage

15.2 V

Battery Type

LiPo 4S

Energy

68 Wh
Net Weight

365 g

Max Flight Time

Approximately 23 minutes

Operating Temperature

­10°C to 40°C

Max Charging Power

100 W
Zagi 60

All EPP Foam

Precision CNC cut

Light plywood brace

5 carbon spar matrix

1800 mAh NiMh battery

Transverse battery position

Carbon prop w/machined hub

Die cut servo and battery bays

Zagi­20 electronic speed control

Zagi reverse rotation pusher motor

Airfoil shaped, constant cord elevons

Airfoil Zagi 101.5

Flying Weight 31.5 oz

Wing span 60"

Wing area 4.5 sq ft

Wing loading 8.7oz sq ft

Servos Micro
Pixhawk is an advanced autopilot system designed by the PX4 open­hardware project and

manufactured by 3D Robotics. It features advanced processor and sensor technology from

ST Microelectronics® and a NuttX real­time operating system, delivering incredible

performance, flexibility, and reliability for controlling any autonomous vehicle.