November 20 , 2015

U.S. Department of Tr ansportation, Docket Operations
West Buil ding Ground Floor, Room w12

- 140 1200 New Jersey Avenue, SE Washington, DC 20590

VIA FED ERAL DOCUMENT MANAGEMENT SYSTEM

RE: Exemption Request under Section 333 of the FAA Reform Act and Part 11 of t he Federal Aviation Regulations

Dear Sir or Madam:

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2 012 (the “Reform Act”) and 14

CF R Part 11, Drone Graphics, Inc., ( a Florida corporation dba DR1Graphics) seeks an exemption from Federal Aviation Regulations (“FARs”) detailed below for the following described small Unmanned Aerial System (called in this application the “ DR1G System ” ) , which includes a small Unmanned Aircraft (UA)
and a Ground S tation (GS), consisting of ground

- based equipment and crew.

DESCRIPTION OF THE UNMANNED AIRCRAFT (UA):

A lightweight (3.2 pound gross weight with all on

- board equipment), lithium polymer battery operated

4

- motor rotorcraft in the form of a quadcopter that takes off and lands vertically, manufactured by DJI Innovations, Inc. , Model Phantom 3 Professional , that includes the following equipment in flight:

1. An on

- board flight c omputer with GPS navigation and location ability that receives signals for flight controls from a ground

- based transmitter/controller;

2. An on

- board camera capable of capturing imagery in the form of full color, high definition still photos and video;

3. An on

- board telemetry system that delivers flight data from the on

- board flight computer to the

on

- board radio transmitter including altitude AGL, horizontal and vertical speed, compass direction of flight and direction back to its launch site;4. A 2.4GHz on

- board radio transmitter that transmits live video from the on

- board camera plus all

the flight data from the telemetry system described above;

DESCRIPTION OF THE GROU N D STATION (GS) :

The Ground S tation consists of the following personnel and equipment element s:

1. A Pilot in Command (PIC) in operational control of a flight operation from beginning to end and
who controls the UA while it is in the air;

2. A 2.4GHz radio transmitter/controller operated by the PIC to control the UA while it is in flight;

3. A radio recei ver receiving live video and flight data from the on

- board camera and computer projects it all together onto a smartphone or tablet screen for the PIC to view during flight;

4. A Visual Observer (VO)

, a person who provides a second pair of eyes to visually tr ack the UA
while it is in flig ht.

The requested exemption would support an application for a commercial Certificate of Authorization to
use the above described DR1G System to support aerial data collection

, including aerial photography
and video for commercial purposes ( primarily of real estate property, boats and marine property

, and special event s such as weddings, reunions, corporate events or functions

, and other privately organized gatherings of people for similar purposes. Other uses may in clude aerial surveys of property for evidence of insurability or for damage claims, support of search and rescue or tactical operations at the direction of contracted local, county, and state law enforcement agencies, and security surveys for public or pri vate entities )

.

SERVICE OF THE PUBLIC INTEREST

T he UA, powered by lithium polymer battery , is smaller, lighter and more maneuverable than larger

aircr aft running on combustible fuel. I t operates at lower altitudes with no people on board and will thereby reduce current risk levels and thus enhance safety and diminish the likelihood of death or serious bodily injury as compared to a full sized, manned aircraft . With a small payload , limi ted speed, limited climb and descent rates, and a maximum flight t ime of 23 minutes, the UA offers little o r no risk to national security.

Low

- altitude perspective photos and video from several angles

– especially low angles

– are far more
effective than ground

- based imagery for displaying (as an example) the characteristics of large, complex properties , which may have several buildings, large trees , and unique design or location features best
visible from low altitude

. The alternative could be to charter a full

- sized helic opter for this purpose,
which i s significantly more costly than many potential clients are able to afford. The benefits of reduced
cost and improved quality of low

- altitude, low angle perspectives in the data captured from the UA will be valuable to and benefit many buyers and sellers of rea l property and marine property.

In the case of some sporting or special events, the UA may operate i n remote or extreme locations where ground

- based video recording could potential ly put the camera crew in harm’s way. The UA is a safer way to capture these sporting or special events.

Additionally, we request that we be allowed to use our system to benefit first responders nearby who might require assistance in a variety of public s afety applications , including local (municipal) firefighters and police, county public safety agents and sheriffs, and state agents

. These applications could include,but are not limited to: Search and Rescue, Tactical Surveillance, Crime Scene or Fire Sce ne Management,

Evidence Collection, Training Enhancement, Water Management, Wildlife, Fish and Game Management, and the like. All of these operations, when conducted within the limitations cited in this application, serve the public interest in tangible wa ys.

STATEMENT OF COMPLIANCE WITH RULES AND REGULATIONS

The DR1G System will be operated in the field with both a PIC and a VO in accordance with FA A Notice N

8900.227 , Paragraph 14 “ O perational Requirements for UAS” and w ith the following R estrictions:

a) No flight will be made with a UA Gr oss weight exceeding 55 pounds; b) All operations will occur in FAA Class G airspace at no more than 400 f ee t AGL, at an airspeed of
no more than 50 knots and no fu rther than .75 NM from the PIC; c) All operations will utilize a visual observer (VO). The VO and PIC will be able to communicate by
voice at all t imes during a flight operation; d) Operations will be restricted to flights over property with the pe rmission of the property owner; e) The PIC will have accumulated and logged, in a manner consistent with 14 CFR § 61.51 (b), a minimum of 100 flight cycles and 25 hours of total time as a UA rotorcraft pilot and at least ten hours logged as a U A pilot with a similar UA type; f) All required permits will b e obtained from state and local government prior to operation; g) The DR1G System will not be operate d over densely populated areas; h) The DR1G System wil l not be operated at air shows; i) The DR1G System will not be operated directly over a ny open

- air assembly of people; j) The DR1G System will not be operated over heavily trafficked road way s; k) The DR1G System will not be operated within 5 NM of an airport or heliport; l) Operations will be restricted to day time only and weathe r conditions equivalent to VFR; m) The PIC will brief the VO and other parties with interest in the flight about the operation and risk
before the fir st flight at each new location; n) No flight shall be made without a Pre

- Flight Inspection by the PIC before each operation to
ascertain that th e UA is in a condition safe for flight (see Appendix A).

The PIC and VO will meet the requirements outlined in FAA Notice N 8900.227 Section 16 “P ersonnel Qualifications. ” Additionally, the PIC and VO will perform maintenance on the DR1G S ystem and will

c omplete a course of maintenance instruction as part of their init ial training.

We submit that the combination of the UA’ s light weight, flight performance and ability, fully qualified flight crew and strict operation under the guidelines established in FA A Notice N 8900.227, and under all of the Restrictions (a) through (n) listed above, the FAA can have full confidence that the operation will have an equivalent or greater level of safety than manned aircra ft performing the same mission.

The name and cont act in formation of the applicant are:

Drone Graphics, Inc., dba DR1Graphics
Attention: W. David Robshaw , President
Address: 1832 NW 48 Terrace, Coconut Creek, FL, 33063 Phone: (954) 914

- 5028
Email: David@DR1Graphics.comThe regulations from which an exemption is requested are listed below. Beside each regulation number

is the page of the attached Addendum upon which each may be found together with our proposed equivalent level of safety for each regulation:

- 14 CFR Part 21........................................

... ... ... ... ... ... ... ... ... ... ... ... ... ... ... ... ... .. ...... ............ . ... . ...... ...Addendum Page 1

- 14 CFR 91. 203................

......... ... ... ... ... ... ... ... ... ... ... ... ... ... ... ... ... ... ... ............ . ......................... .. .......Addendum Page 1

- 14 CFR 45.23 and 45.29.........

............................... ... ... ... ... ... ... ... ... ... ... ... ... ... ... ... ... . ... . ...... . ....... .. Addendum Page 2

- 14 CFR 91 .9.........................................

...... ... ... ... ... ... ... ... ... ... ... ... ... ... ... ... ... ... ... ..................... .. ......Addendum Page 2

- 14 CFR 61.113 and 61.133............

.. ... ... ... ... ... ... ... ... ... ... ... ... ... ... ... ... ... ................... ... . ...... . ........ ..Addendu m Page 3

- 14 CFR 91.109...........................

.......................... .. ... . ... ... ... ... ... ... ... ... ... ... ... ... ... ... ... ... ... ... . ...........Addendum Page 3

- 14 CFR 91.119

.......................... ..... . ............... ... ... ... ... ... ... ... ... ... ... ... ... ... ... ... ... ... . ..........................Addendum Page 3

- 14 CFR 91. 121..........................

..... . ......... .................. ... ... ... ... ... ... ... ... ... ... ... ... ... ... ... ... ... . ..............Addendum Page 4

- 14 CFR 91. 151......................................

............... ... ... ... ... ... ... ... ... ... ... ... ... ... ... ... ... ... . ... . ... . ............ Addendum Page 4

- 14 CFR Subpart E (91. 401

- 91.417) ............

............... ... ... ... ... ... ... ... ... ... ... ... ... ... ... ... . ... . ............Addendum Page 4

- FAA Notice N 8900.227 Para 16(c)(4) and Para 16(e)(1)

... ... ... ... ... ... ... ... ... ... ... ... .. ...... . . ......... Addendum Pag e 4

We are prepared to modify or amend any part of this request to satisfy the need for an e quivalent level of safety. Please contact us at any time if you require additional information or clarification. We look
forwa rd to working with your office.

Sinc erely,

W. David Robshaw , President Drone Graphics, Inc.

Addendum containing Exemption Requests and Equivalent Level of Safety Appendix A

– DR1G System Flight ManualADDENDUM

............................................. .................. ... ... ... ... ... ... ... ... ... ... ... ... ... ... ... ... ... ... .. .........................PAGE 1

STATEMENT S OF EXEMPTION REQUESTS AND PROVISION OF EQUIVALENT LE VEL OF SAFETY

Drone Graphics, Inc. ( dba DR1Graphics ) requests an exemption from the following regulations as well as any additional regulations that may technically apply to the operation of the DR1G System:

14 CFR Part 21, Subpar t H: Airworthiness Certificates This part est ablishes the procedures for the issuance o f an airworthiness certificate.

While the FAA continues to work to develop airworthiness standards for Unmanned Aerial Systems, we request an experimental certificate be issued for the DR1G System under either or bo th of the following provisions:

21 .191 Experimental certificates. Experimental certificates are iss ued for the following purposes: (a) Research and development. Testing new aircraft design concepts, new aircraft equipment, new aircraft installations, ne w aircraft operating techni ques, or new uses for aircraft. (b) Showing compliance with regulations. Conducting flight tests and other operations to show compliance with the airworthiness regulations including flights to show compliance for issuance of type and supplemental type certificates, flights to substantiate major design changes, and flights to show compliance with the function and reliability r equirements of the regulations.

Since the experimental certificate can be used for commercial purposes suc h as market surveys, sales demonstrations, and customer crew training, we would expect that an experimental certificate would permit our commercial purpose as well.

The aircraft will not carry persons or property, will not carry fuel, and will only fly un der strict operational requirements. Combined with the UA’s light weight, being constructed primarily of high impact lightweight plastic, we propose that the UA will be at least as safe, if not safer, than a conventionally certificated aircraft perf orming the same mission.

If an experimental airworthiness certificate is not appropriate for this application, then we request an exemption of 14 CFR Part 21, Subpart H, and the requirement for an airworthiness certificate in general, citing the equivalent level of safety outl ined in the previous paragraph.

14 CFR 91.203(a) & (b) Civil air craft: Certifications required. The regulation provides that an airworthiness certificate, with the registration number assigned to the aircraft and a registration certificate must be aboard the aircraft. Additionally, subparagraph (b) provides that th e airworthiness certificate be “ displayed at the cabin or cockpit entrance so that it is legible to passengers or crew.”

At a maximum gross weight of 3.2 pounds (with camera payload) , the UA is too small to carry the required documentation, does not have an entrance, and is not capable of carrying passengers or crew. To obtain an equivalent level of safety and meet the intent of 91.203, we propose that documents deemed appropriate for this aircraft by the FAA will be co

- located with the cre w at the ground control

station and availab le for inspection upon request.ADDENDUM

............................................. .................................... ... ... ... ... ... ... ... ... ... ... ... ... ... ... ... ... ... ... .. .......PAGE 2

In order to identify the aircraft, we propose that the information found on airworthiness and registration certificates be permanently affixed to the aircraft via placard containing the following information plus the word “EXPERIMENTAL” to satisfy the requirement of 14 CFR 45.23, which follows immediately after the proposed pla card descriptio n below:

EXPERIMENTAL
Manufacture r: DJI Innovations, Inc. 14th Floor, West Wing, Skyworth Semiconductor Design Building, No.18 Gaoxin South 4th Ave, Nanshan District, Shenzhen, China, 518057
If found please contact: (954) 914

- 5028

14 CFR 45.23 Display of marks, g eneral and 45.29 Size of marks. These regulations provide that each aircraft must displ ay “N” and the aircraft’ s registrat ion number in
letters at least three inches high. Additionally, the aircraft must display the word “EXPERIMEN TAL” in
letters at least two inches high near the entrance to the ca bin, cockpit, or pilot station.

The UA does not have an entrance in which the word “EXPERIMENTAL” can be placed, and may not have a registration nu mber assigned to it by the FAA. We propo se to achieve an equivalent level o f safety by including the word “EXPERIMENTAL” in a placard on the top of the aircraft, where the PIC, VO and others in the vicinity of the aircraft while it is preparing for launch will be able to see the designation.
Add itionally, we feel that the permanent placard discussed in the previous paragraph will provide the
aircraft’ s registration information at the ground station. Finally, we will display at the ground station a high contrast flag or banner that contains the wo rds “ Unmanned Aircra ft Ground Station” in letters
three inches high or greater. Since the aircraft will oper ate within .75 NM of the ground station, the banner should be visible to anyone that observes the aircraft and chooses to i nvestigate its point of

o rigin.

14 CFR 91.9 Civil aircraft flight manual, mar king, and placard requirements. This regulation provides that no person may operate an aircraft unless a current, approved fl ight manual
is in the aircraft.

We assume that the intent of this requirement is to ensure that flight manual information is available to the aircrew while operating the aircraft. We request an exemption to this requirement since the aircraft is not only too small to carry documentation , the documentation would not be available to the crew during flight operations.

To obtain an equivalent level of safety and meet the intent of 91.9, we propose that a current, approved UA Flight Manual ( See Appendix A , DR1G System Flight Manual ) must be available to the crew at the ground station anytime the aircraft i s in, or preparing for, flight.ADDENDUM

............................................. ........................ ... ... ... ... ... ... ... ... ... ... ... ... ... ... ... ... ... ... .. ...................PAGE 3

14 CFR 61.113 Private pilot privileges and limitations: Pilot in Command

, and 61.133 Commercial pi lot privileges and limitations. The regulation provides tha t no person that holds a private pilot certificate may act as pilot in command of an aircraft for compensation or hire. Subparagraph (b) allows a private pilot to act as pilot in command of an aircraft in connection with any business or employment if: (1) The flight is only incidental to that business or employment; and (2) The aircraft does not carry passengers or pro perty for compensation or hire.

Our proposed operations r equire that the PIC must either:

1. Hold a Private Pilot Certificate issued by the FAA, and have logged 25 hours of flight ex perience in this type of UA, or

2. Meet the requirements of 8900.227 para 16(c)(2)(c) "Operations without a pilot certificate" in
which t he PIC is required to complete “ FAA p rivate p ilot ground instruction” and pass “ the FAA
Private Pilot written examination. ”

Since there are currently no means available for the pilot of a UAS to gain the experience in an equivalent category and class in order to apply for a commercial pilot’ s license, we propose to generate an equivalent level of safety by requiring our pilots to complete, at a minimum, FAA private pilot ground

instruc tion and pass the FAA Private Pilot written examination or to hold a valid private pilot certificate

. Since t he aircraft cannot carry passengers or property, we feel we meet the intent of 61.113 Subparagraph (b) even though the intent of this applic ation is to conduct a business.

14 CFR 91.109 Flight Instruction; Simulated instrument flight and certain flight te sts The regulation states that "No person may operate a civil aircraft that is being used for flight instruction
unless that aircraft has fu lly functioning dual controls."

The DR1G System ground

- based control station consists of a small hand

- held radio transmitter and smartphone or tablet and while it does not offer a second set of “ controls ,” both the student and instructor can, and will, operate the single set of controls simultan eously. With both s tudent and instructor having “ hands

- on ” the controls during flight, we feel that this technique meets the intent of 91.109 and provides an equivalent level of safety.

14 CFR 91.119 M inimum safe altitudes: General. The regulation states that over sparsely populated areas the aircraft cannot be operated closer than 500 feet to any person, vessel, vehicle, or structure. Since the aircraft will be operating at a maximum of 400 feet AGL, we canno t comply with this requirement.

In order to pr ovide an equivalent level of safety we will only fly over private ly owned property with pre

flight consent obtained from the property owner. The aircraft will not be operated over congested areas or over any open air assembly of persons. The property owner will be briefed on the expected route of flight and the associated risks to persons and property on the ground. The aircraft will be operated at a low altitude allowing, in the event of a power unit failure, an emergency landing without undue hazard
to pe rsons or prop erty on the surface. W e maintain that due to the small size and weight of the UA, the hazard to persons, vehicles and structures is minimal compared to manned aircraft, which should be
consid ered in granting the exemption.ADDENDUM

............................................. ........................... ... ... ... ... ... ... ... ... ... ... ... ... ... ... ... ... ... ... .. ................PAGE 4

14 CFR 91.121 Altim eter set tings. The regulation requires that aircraft shall maintain cruising altitudes by reference to an altimeter setting
available within 100 NM of the aircraft.

The UA will always fly below 400 feet AGL and will not need to maintain cruising altitudes in order to prevent conflict with other aircraft. An Above Ground Level altimeter measurement above the takeoff point is transmitted via radio from the UA on

- board computer to the display screen observed by the PIC, providing a constantly updated altitude AGL readout.

14 CFR 91.151 Fuel requirements for flight in VFR conditions. The regulation provides that no person may begin a flight in an airplane under day

- VFR conditions unless there is enough fuel to fly to the first point of intended landing and to fly after that for at least 30

minutes.

We feel the intention of this paragraph is to provide an energy reserve as a safety buffer for delays to landing. The UA is battery operated and the maximum duration of flight from a single battery charge is
18 minutes with a 20% reserve. Since the airc raft will never fly more than .75 NM from the point of intended landing, a full battery charge at launch will ensure that we meet the reserve energy requirement of this pa ragraph. We request an exemption to the word "fuel" and ask for an equivalent interpr etation with the word "energy"

14 CFR Subpart E (91.401

- 91.417)

- Maintenance, Prev entive Maintenance, Alterations The regulation provides that the operator is primarily responsible for maintaining the aircraft in an airworthy condition, including compliance with part 39 and 43. Paragraphs 91.407 and 91.40 9 require
that the aircraft be “ approved for return to service by a person authorized under 43.7” af ter
maint enance and inspection.

It is our intention that the PIC perform maintenance and inspection of the aircraft and “ be authorized to approve the a ircraft for return to service.” As provided in the Pre

- Flight Checklist in Appendix A, the PIC
will ensure that t he aircraft is in an airworthy condition prior to every flight and in addition conduct detailed inspections after every two hours of flight. Maintenance performed by the PIC is limited to repairing small cracks, replacing a propeller, checking electrical connections and updating software and
firmware for the on

- board computer. All other maintenance will be performed by the manufacturer or their designated repair facility. The PIC will document work performed in accordance with 91.417. We
feel that due to t he size, construction, and simplicity of the aircraft, the PIC can ensure an equivalent level of safety.

8900.227 Para 16(c)(4) PIC Medical, and Para 16(e)(1) Observer Medical.

This policy provides that both the PIC and VO must have a valid FAA second

- cl ass me dical certificate
issued under P art 67 in order to perform as a pilot or observer.

The UA maximum gross weight is 3.2 pounds, it is constructed of high impact plastic and the PIC is not on board. Both the PIC and the VO are required to be in VLOS. G iven the unlikely event that both the PIC and VO become medically incapacitated while the aircraft is in flight, the UA will return autonomously to the site of launching and land without crew intervention.Therefore, requiring the PIC and VO to meet the s ame medical requirements as a commercial pilot

carrying passengers in a large air craft is an unnecessary burden.

We propose that the minimum medical requirements for the PIC and VO be vision corrected to 20/20 and a valid, state issued driver's license. T he 20/20 vision requirement will ensure that the PIC and VO can see and avoid air traffic; a licensed driver is medically qualified to operate a much larger vehicle.APPENDIX A

– DR1G SYSTEM FLIGHT MANUAL

FLIGHT RESTRICTIONS a) No flight will be made wit h a UA Gr oss weight exceeding 55 pounds; b) All operations must occur in FAA Class G airspace at no more than 400’ AGL, at an airspeed of no
more than 5 0 knots and no further than .75 NM from the PIC; c) All operations must utilize a visual observer (VO). The VO and PIC must be able to communicate verbally at all t imes during a flight operation; d) Operations will be restricted to flights over property with the permission of the property owner; e) The PIC must have accumulated and logged, in a manner consi stent with 14 CFR 61.51 (b), a minimum of 100 flight cycles and 25 hours of total time as a UA rotorcraft pilot and at least ten hours logged as a

U A pilot with a similar UA type; f) All required permits will be obtained from state and local government pri or to operation; g) The DR1G System will not be operate d over densely populated areas; h) The DR1G System wil l not be operated at air shows; i) The DR1G System will not be operated over any open

- air assembly of people; j) The DR1G System will not be operated over heavily traveled road way s; k) The DR1G System will not be operated within 5 NM of an airport or heliport; l) Operations will be restricted to day time only and weather conditions equivalent to VFR; m) The PIC will brief the VO and property owner about the operation and risk before the fir st flight at each new location; n) No flight may be made without a successful Pre

- Flight Inspection by the PIC before each operation to
ascertain that the UA is in a condition safe for fligh t.

PREFLIGHT CHECKLIST
1. Remote controller battery

, UA battery, and mobile display device battery are fully charged. 2. Propellers ar e mounted correctly and firmly.

3. Micro

- SD card has been inserted in on

- board camera, if necessary. 4. Camera g imbal fun ction s as normal.

5. UA m otors can start and function as normal.

6. Wireless connection between DJI Pilot “ app ” and the UA is established. 7. If operating outdoors, the UA’s internal compass is calibrated , consistent with manufacturer’s

instructions.

8. If operating outdoors, t he UA has established a strong GPS/GLONASS system “lock.”

9.

TO REGAIN CONTROL AFTER LOST RADIO CONTACT If radio contact is lost and not restored within 3 seconds, an automatic Return to Home feature is activated and will bring the UA back to the launch site and the PIC.