Conestoga-Rovers & Associates 

° d 3075 Brecicinridge Blvd, Suite 470 

Dulutli, Georgia 30096 

Plioiie: 678-232-1933 

E-mail: bleroy@CRAworld.com 

UR.L: http://www.CR.Aworld.coin 

May 29, 2015 

U.S. Department of Ti•a.nsportation 

Docicet Management System 

1200 New Jersey Ave., SE 

Washington, DC, 20590 

RE: Exemption Request Under Section 333 of the FAA Modernizatiorn and Reform Act of 

2012 and 14 C.F.R. Part 11 

Dear Madaan, Sir, 

Pursuant to Section 333 of the FAA Modernization a.nd Reform Act of 2012 and 14 C.F.R. Part 11, 

Conestoga Rovers & Associates ("CRA") seeks an exemption from the Federal Aviation Regulations detailed 

below foL the DJI Phantom 2, Phantom 3, Inspire, S900, and S1000 UAS. The largest of these five systems, 

the S 1000 UAS has a maximtim gross talceoff weight of 24.3 lbs. All of the proposed UAS are mttlti-i otor 

aircra.ft with electric propulsion. These UAS are all commercial platforins fiom DJI with a proven tracls 

recoz•d and have been approved for flights in the National Airspace under several difFerent FAA Certificates 

of Autliorization (COA) . 

The requested exemption would allow CRA to pursue commercial interests in aerial data collection 

using small unmanned a.ircraft systeins. The systems nroposed will be used to conduct data gathering for 

agricultura.l applications, aerial irispections, mapping, surveying, R&D search and rescue, and product 

demonstrations. The team at CRA will operate in accordaaice with FAA N 8900.227 a.nd utilize both a 

Pilot in Comma.nd a.nd . a ground-based visual observer. CRA will also utilize einergency, lost link, and lost 

commtinication procedures previously approved for FAA COA's for the DJ1 Phantom 2 UAS. These are 

available upon request. All flights under these exemptions will be conducted with the following restiictions: 

1. Flights will be in Class G airspace at no more tha.n 400' AGL. 

2. The UAS will be operated over private property only witli the permission of the owner. 

3. The UAS will not be operated over populated areas. 

4. The UAS will not be operated within 5 NM of an airport. 

5. Operations will be limited to daytime operations under visual meteorologica.l conditions. 

G. The aircra.ft will rema.inwithin visual line of sight of the observer at no more than 1/2 NM ra.nge. 

7. A NOTAM will be issued prior to fligllt opera.tions. 

8. The UAS will liave a maximum GTOW of less tha.n 55 lbs. 

9. The aircraft will be U.S. registered a•nd display the N-number. 

10. The PIC and Observer will possess the certifications required tuider N 8900.227. 

11. No operator or observer will engage in, nor may an operator or observer permit, any activity during a 
criticad phase of flight which could distract any operator or observer from the perfortnance of his/her 

duties or interfere in any way with the proper condttct of his/lter duties. 

12. The PIC will conduct a pre-fliglit inspection prior to each fligltt so as to ensure that the UAS and 

associated systems ase in a conclition for sa.fe operation. 

13. The PIC and observers will maintain two-way communications with each other during all operations; 

if tmable to tnaintaitn two-way commtmications, or if any condition occurs that may otherwise cattse 

the operation to be ttnsafe,the operator willimmediately conclude the operation. 

14. The a.ircraft will automatically return to a specific location if tlte commiunications link is lost. 

15. All flights will be conducted below 70mph. 

The regulations from which the exemption is reqttested are as follows. The Appenclix contains details 

of the CRA operations related to slrowing an equivalent level of safety for these exempt regulations. 

• 14 C.F.R. Part 21, Snbpart H 

• 14 C.F.R. §91.203(a) and (b) 

• 14 C.F.R. §45.23(b) 

• 14 C.F.R. §61.23(a) 

• 14 C.F.R. §61.113(a) a.nd (b) 

• 14 C.F.R.§61.133(a) 

• 14 C.F.R..§91.7(a) 

• 14 C.F.R. §91.9 

• 14 C.F.R. §91.109(a) 

• 14 C.F.R. §91.119 

• 14 C.F.R. §91.121 

• 14 C.F.R. §91.151(a) 

• 14 C.F.R. Subpa.rt E (§91.401 - §91.417) 

UAS Overview 

CRA is submitting this reqttest for exemption for five different multi-rotor platforms from DJI; the Phatttotn 

2, Phantotn 3, Inspire, S900, and S1000. CRA has experience witlt the platfornts and has worke<t with local 

Sheriff departments to secure FAA COA's for the DJI Pltantom 2. CRA training and operational procedures 

follow the gttictelines presented in N 8900.227. 

CRA is planning on ttsing the proposed five UAS to purstte ftutlter cotntnercial applications. The five 

UAS are mttlti-rotor aircraft with electric propttlsion. Figttre 1 below contains an image of the five UAS and 

Table 1 contains more detailed information on these systems. CRA proposes that the small size and weight 

of the UAS included in this request for exemption, flown under the guidelines of N 8900.227, will have an 

equivalent level of safety to manned aircraft performing sirttilar missions. 

2 
u. 

T •1~ .1. - .-. 

{:~~ • 

t1) 

AIR 

r,•J -~ ,~., r 

~ 

(2) 

--•sw _~ '1 "` ~ .,.r.~- 

~ 

(4) (5) 

Figure 1: The UAS: (1) The DJI Phantom 2, (2) the DJI Phantom 3, (3) the DJI Inspire, 

(4) the DJI S900, and (5) the DJI S1000 

Aircraft Dimensions Weight 

DJI Phauitom 2 14"x14"x7" 2.6 lbs 

DJI Pha.ntom 3 14 1 'x14"x7" 2.8 lbs 

DJIlnspire 17"x18"x12" 6.51bs 

DJI S900 35 "x35"x14" 18.1 lbs 

DJI S1000 41 "x41 "x14" 24.3 lbs 

Table 1: Name, size, and weight of the aircraft. 

The name and contact inforina.tion of the applica.nt are: 

Conestoga-Rovers & Associates 

Attn: Briau (Bo) LeRoy 

Phone: 678-232-1933 

E-ma.il: bleroy@CRAworld.com 

CRA redttests exemption under Section 333 to enable safe commercia.l UAS operations for the activities 

stated. By approving these exemptions the FAA will create benefits to the a.reas mentioned that is ultimately 

in the public interest. Plea.se contact us if you rectttire additional inforination or clarifica;tion. 

Sincer 

~z 

Brian (Bo) L - oy 

Director of Flight Uperations 

3 
APPENDIX 

Specific Exemption Requests and Equivalent Level of Safety Showings 

14 C.F.R. Part 21, Subpart H: Airworthiness Certificates 

14 C.F.R. §91.203(a) and (b) - Civil aircraft: Certifications required. 

Section 91.203 requires all civil aircraft to have a certificate of airworthiness. Part 21, Subpa.rt H, entitled 

Airworthiness Certificates, establishes the procedural requirements for the issuance of airworthiness certificates 

as required by FAR §91.203(a). CRA requests an exemption frotn these rules and will utilize an internal 

airworthiness process based on MIL-HDBK 516B for an equivalent level of sa£ety. 

Sttch an exemption nteets the requirements of an equivalent level of safety under Pa.rt 11 and Section 

333 of tlte Reform Act. The Federal Aviation Act aatd Section 333 of the Reform Act both autltorize the 

FAA to exempt aireraft fronr the requirement for an airworthiness certificate, upon consideration of the size, 

weight, speed, operational capability, and proximity to airports and popttlated areas of the UAS involvecl. 

14 C.F.R. §45.23(b) - Display of marks; general. 

These regulations provide that each a.ircraft tnust display "N" and the aireraft's registration number in 

letters at least 3 inches high. Additionally, the aircraf't mttst display the word "EXPERIMENTAL" in 

letters at least 2 inches high near the entraarce to the cabin, cockpit, or pilot station. Given the size of the 

UAS (faselage length of G'), this reqttirement is impossible to niatclt. The eqttivalent level of safety will be 

acliieved by having the registered N-number in I incli lettering ozn the side of the fuselage. 

14 C.F.R. §61.23(a) - Medical certificates: Requirement and duration. 

Regulations provide that a persotn must ltold at least a second class medical certifrcate when exercising: 

• Sewond-in-conrmand privileges of an airline transport pilot certificate in part 121 of this chapter (other 

tltan operations specified in paragra.ph (a)(1)(ii) of this section); or 

• Privileges of a commercial pilot certificate 

Given the size of the UAS in this petition and the limited flight asea aud the safety featttres integrated in 

the atitopilot CRA believes that an Equivalent Levei of Safety can be reached if the operator has a valid 

drivers license. 

14 C.F.R. §61.113(a) and (b), §61.133 - Private Pilot Privileges and Limitations: Pilot in 

Command; Cotnmercial Pilot Privileges and Limitations 

Sttbsections (a) and (b) of §61.113 prohibit private pilots from operating aireraft in commercial operations, 

and §61.133(a) requires an individual operating an aircraft for compensation or hire to hold a commercial 

pilot certificate. 

CRA requests an exemption from 14 C.F.R. §61.113(a) and (b) and 14 C.F.R. §61.133(a) so that 

above mentioned UAS may be operated by individuals who ltave a private pilot certificate. 

Based upon the design features of the UAS, its autopilot system, and safety factors, the FAA should 

permit operation of UAS by operators with a private pilot certificate when the conditions clescribed above 

have been satisfied. The above-described conditions are in-line witlt those set forth in Volutne 16, Chapter 4, 

Section 1 of FAA Order 8900.1. 

CRA proposes to condttet operations in accawrdance with these restrietions. Given these conditions 

and restrictions, an equivalent level of safety to manned operations will be achieved through operation witli 

a private pilot certificate. The risks associated with the operation of the DJI tnttlti-rotor aircraft (given the 

size, speed, operational capabilities, and lack of combustible fiiel) are so tnuch less than the level of rislc 

associated with fixed wing and rotorcraft operations, both private aaxl cominercial, as contenrplated by Part 

61, that allowing operations of these UAS, as set forth above, meets or exceeds the present level of sa.fety 

4 
provided under 14 C.F.R. §61.113(a) and (b) and §61.133(a) 

14 C.F.R. §91.7(a) - Civil aircraft flight manual, marking, and placard requirements 

This regttlation reqttires that no person may operate a civil aircraft ttnless it is in airworthy condition. CRA 

requests that an exemption be granted adlowing commercial operation witltout aat airworthiness certificate. 

Given the size of the aircraft self certification ntilizing nQIL-HDBK 516B will provide aat equivalent level of 

safety. 

14 C.F.R. §91.9(b)- Civil aircraft flight manual, tnarking, and placard requirements. 

This regulation provides that no person may operate an aircraft ttnless a catrrent, approved fligltt maantal is 

in the aircraft. CRA assumes that the intent of this requirement is to ensure that flight manual information 

is available to the aircrew while operating the aircraft. CRA requests an exemption to this requirement since 

the aircraft is not only too stnall to carry documentation, bttt the documentation wottld not be available to 

the crew. The eqttivalent level of sa£ety will be achieved by keeping a hard copy of the DJI ttser manua.l 

with the grouncl crew. 

14 C.F.R. §91.109(a) - Flight instruction; Simulated instrutnent flight and certain flight tests 

Sections 91.109(a) provides that no person may operate a civil aircraft that is being used for flight instruction 

nnless that aircraft lras fnlly fiutctioning dual controls. The UAS in this exemption are remotely piloted 

aircraft, and, by clesign, not equippecl witlt fttlly fttnctiona.l clttal controls. Flight control is accontplishect 

througlt the use of a coutrol box that cotnmunicates with the aircraft via radio communications. Utilizing a 

pilot skilled in remote piloting will provide aar equivaient level of safety. 

14 C.F.R. §91.119 - Minimum safe altitudes: General. 

The regulation provides tha.t over sparsely populated a.reas the aircra.ft casutot be operated closer thaar 500 

feet to any person, vessel, vehicle, or structure. Since the UAS in this exemption will be operating at a 

ma.xinnun of 400 feet AGL, this requirement cannot be followed. To provide an equivalent level of safety 

CR.A will only fly over private propety with the permission of the la.nd owner. The land owner will be 

briefed of the expected route of flight and the associated risks to persons and property on the ground. We 

maintain that due to the small size of tlre UAS, the hazard to persons, vessels, vehicles, and structmes is 

not comparable to manned a.ircraft and sltottld be considered in granting the exemptiott. Fmthermore, CRA 

will not operate over congested areas nor over any open air assembly of persons. 

14 C.F.R. §91.121 - Altimeter settings. 

The regulation states that aircraft shall maintain cruising altitudes by reference to a.n altimeter setting 

available witltin 100 nautical miles of the aircraft. The UAS will fly below 400 feet ACL and will not need to 

maintain liemispherical cruising altitudes in order to de-conflict with other aircraft. To provide an equivalent 

level of'safety, the atitopilot calcttlates the reference altitttde (ground level) with the on-boa.rcl GPS dttring 

the pre-flight tests. The GPS and barometer data are then used to calculate the altitude in-flight. 

14 C.F.R. §91.151(a) - Fuel requiretnents for flight in VFR conditions. 

The regulation states that no person may begin a flight in an airplane under day-VFR conditions unless 

there is enottgh fuel to fly to the first point of intended landing and to fly after that for at least 30 mintttes. 

As the aircraft in this request are electric-powered, this reqttirernent is inapplicable. An equiva.lent level of 

safety is achieved through a low battery power warning. The DJI UAS are designed to automatically return 

to base and land safely when the power is too low. 

14 C.F.R. Subpart E(§91.401 -§91.417) - Maintenance, Preventive Maintenance, and Alterations 

The regulation provides that the operator is primarily responsible for maintaining the aircraft in an airworthy 

condition, including compliance with part 39 attd 43. Paragraphs 91.407 and 91.409 require that the aircraft 

be "approved f'or return to service by a person atttltorized ttnder 43.7" after tnaintenaxtce aud inspection. 

CRA plans to have the PIC perfortn maintenance aud inspection of the aircraft and "be attthorized to 

5 
approve the aircraft for return to service." The PIC wili ensure that the aircraft is in an aiiworthy condition 

prior to flight and conduct detailed inspections after every 10 flight hours. Additionally, checldists will be 

utilized witth all of the necessary pre-flight procedures prior to every flight operation. The PIC will document 

work performed in accordance with 91.417. We feel that due to the size, constraction, and simplicity of the 

aircraft, the PIC ca.n ensure an equivalent level of safety.