Drone Solutions , LLC Attn: James D. Morgan 1750 Highway 70 East Lenoir City, TN 37772

August 18 , 2015

U.S. Department of Transportation Docket Management System 1200 New Jersey Ave., SE Washington DC 20590

Re: Exemption Request Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 from 14 CFR 61.113(a) and (b); 14 CFR 91.7(a); 14 CFR 91.9(b)(2); 14 CFR 91.103; 14 CFR 91.109; 14 CFR 91.119(c); 14 CFR 91.121; 14 CFR 91.151(a); 14 CFR 91.405 ( a); 14 CFR 91.407 (a) (1) ; 14 CFR 91.409 (a)(1) ; and (2); 14 CFR 91.417(a) and (b)

Dear Sir or Madam:

Pursuant to Section 333 of the FAA Moder nization and Reform Act of 2012 (Reform Act)
, Drone Solutions, LLC (Applicant) hereby applies for an exemption from the above

- listed Federal Aviation Regulations (FARs ) to allow commercial operation of its small unmanned aircraft systems ( UAS s) as more fully described herein, 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. This re quest for exemption is similar to many previously submitted requests that have received exemption.

The name and address of the A pplicant is:

Drone Solutions, LLC Attn: James D. Morgan 1750 Highway 70 East Lenoir City, TN 37772 Ph one : 865.323. 6466

Proposed c ommercial uses by Drone Solutions, LLC of a UAS equipped with a camera and /or sensors would include aerial photography, video and data collection for the following purposes :

1. Real estate marketing and inspection
, environmental monitoring and investigations, agricultural support, and other related professional activities.

2. P ublic events, private events (e.g. reunions
, weddings, etc.) , tourism promotion, and news gathering.3. Assistance with search and rescue operations in cases of an emergency or natural disaster or when otherwise approved by local authorities, government or other agency in charge

.

4. Inspection and marketing of private facilities ( e.g. golf courses
, resorts, corporate facilities,
etc .)

Drone Solutions, LLC will operate a variety of UASs, including :

 DJI Phantom 2 Vision +
,

 DJI Phantom 3,

 DJI Inspire 1, and

 DJI Spreading Wings models

.

Each of these UAS are readily

- available UAS available to the general public. Each UAS will be powered using lithium polymer batteries and controlled with a remote transmitter operating on 2.4 GHz band. Applicant will operate the UAS in line of sight within a predetermined area



### . Additional specification s for the DJI Phantom 2 Vision + are conta ined in the User Manual (Appendix A).

James D. Morgan , owner of Drone Solutions, LLC, is an experienced UAS operator and a member of the Academy of Model Aeronautics

. Drone Solutions, LLC intends to conduct aerial photography, video and data collection as described above. Mr. Morgan is a Professional Geologist with over 25 years conducting environmental consulting and wat er

- resources investigations and is aware of the benefits and safety precautions associated with using UAS for the safe and efficient accomplishment of environmental monitoring and investigations . Mr. Morgan is a Private Pilot (Certificate #3728638 ) with a current Third Class Medical Certificate and is knowledgeable about national airspace and other relevant issues

. The requested exemption would permit the operation of a UAS in the national airspace under conditions that will be limited and that will provide safety enhancements to the already safe operations in the industry presently using conventional aircraft. Approval of this exemption would thereby enhance safety and fulfill the Secretary of Transportation’s (the FAA Administra tor’s) responsibiliti es to establish requirements for the safe operation of such aircraft systems i n the national airspace system.

The specific section or sections of 14 CFR from which Drone Solutions, LLC seeks an exemption.

14 CFR 61 .113 (a) & (b) 14 CFR 91 .7 (a) 14 CFR 91 .9 (b) (2) 14 CFR 91 .103 14 CFR 91.109 14 CFR 91.119 (c) 14 CFR 91.121 14 CFR 91. 151 (a) 14 CFR 91. 405 (a) 14 CFR 91. 407 (a) (1)14 CFR 91.409 (a) (2) 14 CFR 91.417 (a) & (b)

An exemption from 14 CFR 21 is not necessary, based on the size, weight, speed, and limited operating area associated with the UASs and operatio n s described in this exemption request.

Given the small size of the UAS and the controlled environment in which the UAS will operate, the proposed operations will adhere to the Reform Act’s safety requirements. The approval of this application presents no national security issues. Regarding the level of safety surrounding the proposed operations and the pub lic benefit, reduction in environmental impacts, including but not limited to reduced emissions and noise, the grant of the requested exemption is in the public interest. Accordingly
, Applicant requests that the FAA grant the request ed exemption with minim um delay.

The extent of relief that Drone Solutions, LLC seeks and the reason that we seek the relief.

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

Pursuant to 14 CFR 61.113 (a) & (b), no person who holds a private (versus commercial) pilot certificate may act as a pilot in command of an aircraft that is carrying passengers or property for compensation or hire.

Drone Solutions, LLC will achieve an equivalent level of safety compar ed with current Regulations because our UAS s do not carry any pilots or passengers nor property. The risks associated with the operation of UAS are far less than the risk levels inherent in the commercial activities outlined in 14 CFR 61.

14 C.F.R. §91.7(a): Civil Aircraft Airworthiness

.
The regulation requires that no person may operate a civil aircraft unless it is in airworthy condition.

As there will be no airworthiness certificate issued for the aircraft no FAA regulatory standard will exist f or determining airworthiness. An equivalent level of safety will be provided by conducting maintenance and inspections in accordance with the manufacturer’s user m anuals and checklists

.

14 C.F.R. § 91.9 (b) (2): Civil Aircraft Flight Manual , Markings and Placard Requirements

.
Section 91.9 (b) (2) provides: No person may operate a U.S.

- registered civil aircraft ... (2) For which an Airplane or Rotorcraft Flight Manual is not required by §21.5 of this chapter, unless there is available in the aircraft a curr ent approved airplane or Rotorcraft Flight Manual, approved manual material, markings, and placards, or any combination thereof.

The UASs proposed for use herein have n o ability or place to carry a flight manual on the aircraft due to their small size and configuration. In addition, any flight manual that might be carried onboard a UAS would not be available for use by the UAS operator located on the ground. The equivalent level of safety will be maintained by keeping the flight manual at the ground contr ol point where the pilot flying the UAS will have immediate access to it.14 C.F.R. § 91.103: Preflight Action

.
This regulation requires each pilot in command to take certain actions before flight to insure the safety of flight.

As FAA approved rotorcraft flight manuals will not be provided for the aircraft an exemption will be needed. In order to provide an appropriate and equivalent level of safety the UAS operator will take all actions contained in the user m anuals and pre

- flight checklists including
, b ut not limited to
, reviewing the physical setting where the UAS will be utilized, weather conditions , flight battery requirements, UAS settings for safety features such as Return to Home (RTH), and aircraft performance data before initiation of flight.



### 14 C.F.R. §91.109: Flight Instruction



### .

Section 91.109 provides , in part, that no person may operate a civil aircraft (except a manned free balloon) that is being used for flight instruction unless that aircraft has fully functioning dual controls.

UAS flight control is accomplished with a control box
, operated by a pilot on the ground, which communicates with the aircraft via radio communications. UAS by their design do not have fully functional dual controls. The FAA has approved exemptions for fli ght training without fully functional dual controls for a number of aircraft and for flight instruction in experimental aircraft. The equivalent level of safety will be provided due to the fact that neither a pilot nor passengers will be carried in the air craft and by the size and speed of the aircraft.



### 14 C.F.R. §91.119: Minimum Safe Altitudes



### .

Section 91.119 prescribes safe altitudes for the operation of civil aircraft. It allows helicopters to be operated at lower altitudes in certain conditions, provided the person operating the helicopter complies with any route or altitudes prescribed for helicopters by the FAA.

As this exemption is for a UAS that is a helicopter and the exemption requests authority to oper ate between land surface and altitudes up to 400 feet AGL , an exemption may be needed to allow such operations. As set forth herein, the UAS will never operate at higher than 400 AGL

.
The equivalent level of safety will be achieved given the size, weight, speed of the UAS as well as the locati on where it is operated. No flight will be taken without the permission of the property owner or local officials. Compared to flight operations with aircraft or rotorcraft weighting far more than the maximum 55lbs. proposed herein and the lack of flammable fuel, any risk associated with these operations is far less than those presently presented with conventional aircraft operating at or below 500 AGL. In addition, the low

- altitude operations of the UAS will ensure separation between these UAS operations an d the operations of conventional aircraft that must comply with Section 91.119.

### 14 C.F.R. §91.121 Altimeter Settings.

14 CFR 91.121 requires each person operating an aircraft to maintain cruis ing altitude by reference to

an altimeter , and further describes various options for obtaining an appropriate altimeter setting (such as a setting from a station along the route of flight and within 100 nautical miles, a setting from the departure airport, or another appropriate station)

.
As the UAS may not ha ve a barometric altimeter , but instead an altitude determined by GPS , an exemption may be needed. An equivalent level of safety will be achieved by confirming that the GPS altitude reading for the ground station is 0 f ee t AGL prior to flight, monitoring in

- flight altitude information, and utilizing the programing capabilities to produce visual and audible alerts associated with a maximum permitted altitude

.

14 C.F.R. § 91.151(a): Fuel Requirements for Flight in VFR Conditions

Section 91.151 (a) prohibits an individual from beginning “a flight in an airplane under VFR conditions unless (considering wind and forecast weather conditions) there is enough fuel to fly to the first point of intended landing, and, assuming normal cruis ing speed

– (1) During the day, to fly after that for at least 30 minutes; or (2) At night, to fly after that for at least 45 minutes.”

Relief from 14 CFR 91.151 is needed because without a n exemption the flight time duration of the battery

- powered DJI wou ld be severely constrained and it would be impractical to use the UAS for the purposes proposed herein. To achieve safe flight and maintain a safe reserve of battery power, UAS flights would be conducted with enough available power for the UAS 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. This restriction would be more than adequate to return the UAS to its planned landing zone from anywhere in its limited operating area.

14 C.F.R. §91.405 (a); 91. 407 (a) (1); 91. 409 (a) (2); 91. 417(a) & (b): Maintenance Inspections.

These regulations require , among other requirements, that an aircraft operator or owner “shall have that aircraft inspected as prescribed in subpart E of this part and shall between required inspections, except as provided in paragraph (c) of this section, have discrepancies repaired as prescribed in part 43 of this chapter...,” and others shall inspect or maintain the aircraft in compliance with Part 43.

These regulations apply only to aircraft with an airworthiness certificate and will not apply to A pplicant. An equivalent level of safety will be achieved because the UAS m aintenance will be accomplished by the operator pursuant to the manufacturer’s u ser m anual and the operator will ensure that the UAS is in working or der prior to initiating flight and perform required maintenance

.Reasons why the exemption will not adversely affect safety, or how the exemption would provide a level of safety at least equal to the existing rule.

The exemption proposed herein for Drone Solutions, LLC will not adversely affect safety. The following proposed opera ting limitations a nd conditions will provide for safe UAS flight.

 Flights will be operated within line of sight of the Pilot in Command (PIC) and/or Visual Observer (VO). The PIC and VO will be able to communicate verbally at all times.

 The UAS will weigh less than 55 lbs.

 The UAS will have a maximum operating speed of no more than 50mph.

 If the UAS loses communications with the remote controller or loses GPS signal, the UAS will have the capability to return to a pre

- determined location within a designated location
and lan d autonomously. Manufacturer’s p rocedures for the return

- to

- home (RTH) feature,
such as those described in the User Manual for the DJI Phantom 2 Vison + (Appendix A)
will be followed.

 Manufacturer’s procedures for pre

- flight inspections and flight operations such as those
contained in the User Manual f or the DJI Phantom 2 Vision + (Appendix A) will be
followed

. In addition a proprietary checklist (Appendix B) will be followed , and the
checklist will be modified and expanded as more flights are take n in order to continually improve flight safety and efficiency.

 The PIC will not begin a flight unless there is en ough available power for the UAS to conduct the intended operation and to operate after that for at least five minutes or with the

reserve po wer recommended by the manufacturer
, if greater.

 Flights will be operated at an altitude of no more than 40 0 feet above ground l evel (AGL).

 The PIC will hold either a sport, recreational, private or commercial pilot’s l icense along
with a Third Class or higher medical c ertificate

.

 The flights will occur no closer than a 5 mile radius of the geographic center/Airport Reference Point (ARP) of a tower controlled or uncontrolled airport.

 If operations w ill be within a 5 mile radius of the geographic center/ ARP of a tower controlled or uncontrolled airport the respective airports will be contacted advising them of the estimated flight time, flight duration, elevation of flight and other pertinent information.

 The UAS will have the capability to abort a flight in case of unpredicted obstacles, weather, or emergencies.How the request of Drone Solutions, LLC would benefit the public as a whole.

Granting this exemption will further the public interest by allowing Drone Solutions, LLC to safely

e fficiently, and economically take pictures/video and collect data tha t will benefit a variety of users. Use of the proposed small UAS, rather than full

- scale manned aircraft will decrease traffic congestion in the national airspace, reduce noise and air p ollution, decrease risks to life and property, and provide significant benefits to the economy.

Aerial imagery and data collection have traditionally been conducted by manned aircraft. Th e use of small UAS to condu ct some portion of similar services woul d reduce the amount of manned aircraft in the NAS

. C ongestion around airports would be reduced due to a reduction in the number of departures and arrivals of manned aircraft. Small UAS do not require an airport to take off and land . Additionally,

a reduction in manned aircraft flights would result in fewer aircraft that must be handled by air traffic control staff.

By using battery power and electric motors, the proposed UASs will produce no air pollution. UAS are an environmentally conscious altern ative to manned aircraft that burn several gallons of fuel per hour. The UAS produces much less noise than manned aircraft powered by an internal combustion engine.

By using a UAS to conduct the activities proposed herein, r isk to life and property in the air and on the ground will be reduced, as compared to similar operations conducted with manned aircraft. Because of the small size and low weight of the DJI UASs as compared to maned aircraft, there is less potential for physical damage to life and propert y on the ground and in the air

. The UAS carry no pilot, no passengers, and no fuel, which reduces the potential for accident

- related damage to life and property as compared to a full

- scale manned aircraft.

Granting this exemption would provide economic be nefits. The expense of conducting many of UAS activities may be cost prohibitive for many consumers if conducted using manned aircraft . By comparison, the act ivities could be conducted more efficiently and economically using UAS and as a result many more companies and individuals would be able to obtain the proposed services
, stim ulating the economy as a result. Photographs and video produced from the UAS activities will be used as affordable marketing and promotional tools for the consumers of the UAS pr oducts.

Conclusion

As set forth herein, Drone Solutions, LLC seeks an exemption pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 from 14 CFR 61.113(a) and (b); 14 CFR 91.7(a); 14 CFR 91.9(b)(2); 14 CFR 91.103; 14 CFR 91.109; 14 CFR 91.119(c); 14 CFR 91.121; 14 CFR 91.151(a); 14 CFR 91.405 (a); 14 CFR 91.407 (a) (1); 14 CFR 91.409 (a)(1); and (2); 14 CFR 91.417(a) and (b) . This exemption will allow Drone Solutions, LLC to conducted limited data collection activities using UASs includ ing the DJI Phantom 2 Vision +
, DJI Phantom 3, DJI Inspire 1, and DJI Spreading Wings models

. Exemptions for similar purposes and these same UAS s have previously been granted by the FAA.

James D. Morgan, owner of Drone Solutions, LLC, is an experienced UAS operator and a member of the Academy of Model Aeronautics. Mr. Morgan is a Professional Geologist with over 25 years conducting environmental consulting and water

- resources investigations and is aware of the benefits and safety precautions associated with using UAS for the safe and efficient accomplishment of environmental monitoring and investigations. Mr. Morgan is a Private Pilot (Certificate #3728638) witha current Third Class Medical Certificate and is knowledgeable about aviation regulations, n ational airspace and other relevant issues.

Drone Solutions, LLC respectfully requests that the FAA Administrator grant this exemption.

Sincerely,

James D. Morgan Drone Solutions , LLC

Appendices

Appendix A : User Manual, DJI Phantom 2 Vision + Appendix B: Drone Solutions, LLC Flight Checklist (proprietary)