August 25, 2015

U.S. Department ofTransportation Docket Management System 1200 New Jersey Ave, SE Washington, DC 20590 RE: Exemption Request Section 333 ofthe FAA Reform Act of2012 Attachments:
 Inspire 1 User Manual
 Inspire 1 Quick Start Guide
 Inspire 1 Maintenance Manual These attachments are too large to submit via the submission portal. They are available for download at this website

- http://www.dji.com/product/inspire

-1/download

Dear Sir or Madam, Pursuant to Section 333 ofthe FAA Modernization and Reform act of2012 and 14 C.F.R. Part 11, Sunflower Unmanned Solutions LLC, referred to hereafter as the petitioner, hereby requests exemption from the following sections ofTitle 14, Code ofFederal Regulations

14 C.F.R. 61.113(a)&(b); 14 C.F.R. 91.7(a); 14 C.F.R. 91.119(c); 14 C.F.R. 91.121; 14 C.F.R. 91.151(a)(1); 14 C.F.R. 91.405(a); 14 C.F.R. 91.407(a) (1); 14 C.F.R. 91.409(a) (2); 14 C.F.R. 91.417(a)&(b). In order to provide commercial services by use ofunmanned aircraft systems (UAS) at the highest level ofsafety

. Commercial services to be provided through the use ofa small unmanned aircraft would be:



### • Aerial photography

/ videography



### • Agriculture



### • Mapping



### • Inspections



### • Real Estate



### • Wildlife and forestry monitoring



### • News gathering



### • Emergency response assistance

### • Research and training



### • Other flight operations The petitioner's goal with this exemption is to gain legal access to the National Airspace System while also maintaining the highest level ofsafety for these services. **The UAS**  This exemption would allow the petitioner to operate one DJI Inspire 1. This aircraft is a four motor, quad copter configuration that weighs roughly 3 kilograms (2,935 grams), which falls into the category ofsmall UAS, and measures 17.3x11.8x17.7 inches. Maximum speed is 22 m/s, or 42.8 knots, while the maximum ascent speed is 5 m/s and the descent speed reaches 4 m/s. Ground to air communication is accomplished through a 2.4 GHz frequency from a master transmitter that is in compliance with FCC regulations. The DJI Inspire 1 utilizes a brand new flight controller built specially for the aircraft. This flight controller allows the aircraft to record its "home point", or location at takeoff, which insures a failsafe in the event ofan unscheduled in

-flight emergency- i.e. lost transmitter signal

- that would enable the aircraft to automatically return to its home point and land. This intelligent flight controller is also capable ofhaving flight limits and flight restriction areas. These restrictions prevent the aircraft from flying past a predetermined altitude and distance from the operator, as well as preventing any flights from occurring in "no

-fly zones", which are areas ofhigh air traffic or national security

. **Risk Management**  The petitioner is trained with the right tools to mitigate risk and operate in a safe manner while ensuring public safety

. The pilot in command (PIC) holds a current private pilot license with instrument rating along with a current second class medical certificate and has a high level ofknowledge ofthe National Airspace System (NAS)

. This operator is also highly educated in unmanned aircraft systems as he is enrolled in one ofthe top UAS programs in the country
. The PIC also has over 30 (32) hours ofpilot in command time ofmultirotor platforms, including 8 hours in the DJI Inspire 1 aircraft

. Pre

-flight, in

-flight, and post
-flight checklists will be utilized in each mission, as well as safety briefings for crew members before each flight. A risk assessment matrix will be completed before each flight as well to ensure that not only is the aircraft in a condition safe for flight, but that factors such as weather and crewmembers are assessed before flight as well. A visual observer (VO) will be used during all flight operations, and will remain within unaided audio range ofthe PIC. All flight times will be logged along with the aircraft's flight characteristics, and any changes to flight critical components will be noted and reported to the FAA. All manufacturer recommended maintenance checks will performed and logged in order to ensure the proper steps are being taken to maintain the aircraft in a condition that is safe for flight. All flight operations would also be subject to the following guidelines:
 Flight times would be limited to 30 minutes, or 25% ofremaining capacity ofbattery, whichever comes first
 Minimum crew for operations would consist ofone PIC and one VO
 Operations will not exceed 400 feet above ground level (AGL)
 Operations will be conducted during daylight hours only
 Aircraft will remain within visual line ofsight ofthe PIC and VO at all times Flights will not occur when weather minimums are not met (500 feet below or 2,000 feet

horizontally from a cloud and at least 3 statute miles ofvisibility from the operator)
 Operations will not occur within 5nm ofany airport unless a letter ofagreement with that airport's management is obtained and the appropriate communication is made with said persons prior to the flight
 All documents mentioned in this exemption request, also referred to as the operating documents, will be made available along with the grant ofexemption to the Administrator and any law enforcement personnel upon request **Operation s**  **of the**  **Unmanned Aircraft**  Before operating on and over private property, the petitioner will obtain landowner's permission. All operations will be conducted at least 500 feet from non-participating people to ensure the public's safety is not compromised. In the event that the 500 foot radius is injeopardy from non-participating persons, vessels, vehicles and structures, the PIC will immediately cease flight operations in order to preserve the safety ofsaid subjects. The operator's high knowledge ofthe surrounding NAS will aid in maintaining a high level ofsafety when communicating with local air traffic controllers before flights. In regards to the area ofoperations, two exemptions have been granted to organizations operating in similar environments, referring to exemption number 11741 (Witt Tech LLC) and exemption number 11172 (Blue

-Chip UAS). These organizations have safely and successfully been integrated into the NAS and have operated in similar environments, as well as a similar geographical area (in regards to the local environment) to that the petitioner is requesting. The petitioner also finds many similarities with other exemptions that have been granted, in particular exemption number 11881 (Empire Unmanned LLC), which operates the same aircraft as the petitioner and is involved in the same, ifnot very similar, flight operations as the petitioner is petitioning to conduct. The petitioner finds that because ofthe similarities in all facets ofits own exemption and those mentioned as being granted above, it is feasible to grant Sunflower Unmanned Solutions LLC its request for exemption. **Public Interest**  As a relatively new industry, UAS is still in its beginning stages ofeconomic growth. As a small, local business, Sunflower Unmanned Solutions LLC would be able to create new possibilities within the area for this industry

. Not only would this exemption permit the petitioner to boost the local economy, it would also allow the petitioner to effectively promote the safe use ofunmanned aircraft systems to its clients and, as a result, the community as a whole. The strict operating procedures that would be upheld by the petitioner would result in operations being performed at an equivalent level ofsafety as manned aircraft operate. All services being conducted would allow a less expensive operation while still maintaining the FAA's safety standards for manned aviation.

## Exem**ption Requests**  **and Equivalent**  **Level of** **Safety**

**14 C.F.R.**  **§ 61.113**  **Private pilot**  **privileges and**  **limitations: Pilot**  **in command.**  The regulation provides that no person that holds a private pilot certificate may act as pilot in command ofan aircraft for compensation or hire. Subparagraph (b) allows a private pilot to act as pilot in command ofan aircraft in connection with any business or employ ment if: (1) The flight is only incidental to that business or employment; and (2) The aircraft does not carry passengers or property for compensation or hire. **Equivalent Level**  **of Safety**  Currently, there are no applicable areas identified for aircraft in either the private or commercial sector and therefore an exemption is required to conduct commercial operations. As flight operations will be conducted in a contained environment, these strict guidelines will achieve an equivalent level ofsafety for each individual flight when compared to commercial flights identified in Part 61 when originally developed.

**14 C.F.R.**  **§ 91.7(a):**  **Civil Aircraft**  **Airworthiness** Petitioner seeks an exemption from 14 C.F.R. § 91.7(a), which requires that a civil aircraft be in airworthy condition to be operated. Inasmuch there will be no airworthiness certificate issued for the aircraft, should this exemption be granted, no FAA regulatory standard will exist for determining airworthiness. **Equivalent Level**  **of Safety**  Given the size ofthe DJI Inspire 1 and the preflight procedures, including all logbooks, preflight checklists, and maintenance checks, an equivalent level ofsafety will be provided to ensure the aircraft is in an airworthy condition for flight operations.

**14 C.F.R.**  **§ 91.119(c):**  **Minimum Safe**  **Altitudes** Petitioner requests an exemption from the minimum safe altitude requirements of 14 C.F.R. § 91.119(c) which states that aircraft may not operate closer than 500 feet above the surface and away from anyperson, vessel, vehicle, or structure in non-congested areas. To provide the intended operations, the aircraft is operated below 400 feet AGL. **Equivalent Level**  **of Safety**  Compared to flight operations with manned aircraft that far outweigh the Inspire 1, and given the lack offlammable fuel, any risk associated with these operations is far less than those that presently exist with conventional aircraft. An equivalent level ofsafety will be achieved given the size, weight, and speed ofthe UAS, as well as the location where it is operated. As set forth in the operations section ofthis exemption, the UAS will be operated away from densely populated areas and at least 5nm away from airports (unless a letter ofagreement from the airport’s management is obtained), where buildings and people will not be at risk ofany incident or accident

. Because ofthe advance notice to the property owners and participants, all affected individuals will be aware ofthe planned flight operations.**14 C.F.R.**  **§ 91.121:**  **Altimeter Settings** 

This petition seeks an exemption from 14 C.F.R. § 91.121, which requires a person operating an aircraft to maintain cruising altitude or flight level by reference to an altimeter that is set to the elevation ofthe departure airport or barometric pressure. An exemption is required because the UAS does not have a barometric altimeter, but rather a GPS altitude indicator. **Equivalent Level**  **of Safety**  An equivalent level ofsafety will be achieved by the operator confirming the altitude of the launch site before flight as shown on the GPS altitude indicator

. The PIC will also use the GPS altitude indicator to continuously monitor the aircraft's height, ensuring operation at safe altitudes. **14 C.F.R.**  **§ 91.151(a)(1):**  **Fuel Requirements**  **for Flight**  **in VFR**  **Conditions** Petitioner requests an exemption from 14 C.F.R. § 91.151(a)(1)'s fuel requirements for flight in VFR conditions during the day

. Section 91.151(a)(1) states: (a) No person may begin 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 cruising speed

– (1) During the day, to fly after that for at least 30 minutes; The batterypowering the Inspire 1 provides approximately 22 minutes offlight. To meet the 30 minutes reserve requirement in 14 C.F.R. § 91.151, flights could not be conducted. Given the limitations on the aircraft's proposed flight area and the location ofits proposed operations within a predetermined area, a safety margin based on a reserve amount ofbattery life is needed. **Equivalent Level**  **of Safety**  An equivalent level ofsafety will be achieved as flight operations will be limited to visual line of sight, requiring the operations to be conducted on site thus limiting any transit time ofthe aircraft. All flights will be terminated with no less than 25% reserve battery power still available as stated in the Risk Management section ofthis request
. This restriction would be more than adequate to return the aircraft safely to the ground and its planned landing zone from anywhere in its limited operating area even in the event ofan unexpected occurrence. Operation ofthe aircraft with less than 30 minutes ofreserve fuel does not include the ty pe ofrisks that Section 91.151(a)(1) was intended to alleviate given the size and speed ofthe petitioner's UAS, and the proximity ofthe flight operation to the landing zone.**14 C.F.R.**  **§ 91.405(a),**  **91.407(a)(1), 91.409(a)(2);**  **91.417(a) and**  **(b): Maintenance**  **Inspections** Petitioner also seeks an exemption from requirements contained in 14 C.F.R. § 91.405(a), 91.407(a)(1), 91.409(a)(2); 91.417(a) and (b). These regulations specify maintenance and inspection standards in reference to 14 C.F.R. Part 43. See, e.g., 14 C.F.R. § 91.405(a) (stating that each owner or operator ofan aircraft "[s]hall have the aircraft inspected as prescribed in subpart E ofthis part and shall between required inspections ...have discrepancies repaired as prescribed in part 43 ofthis chapter"). An exemption to these regulations is needed because Part 43 and these sections only apply to aircraft with an airworthiness certificate, which the aircraft will not have. **Equivalent Level**  **of Safety**  An equivalent level ofsafety will be achieved because the operator will ensure that the aircraft is in working order prior to initiating flight by following the appropriate checklists and logs as discussed in the Risk Management section ofthis request. The operator is the person most familiar with the particular aircraft and best suited to maintain the aircraft in an airworthy condition. **Concluding Statement**  Sunflower Unmanned Solutions LLC seeks an exemption from the aforementioned FARs in order to conduct safe, legal, and efficient commercial operations using one DJI Inspire 1. The petitioner finds that its operating procedures are ofat least an equivalent level of documented safety as all exemptions granted before the date ofsubmission. Given the Inspire 1's size, weight, speed, flight capabilities, operation within visual line ofsight, lack ofproximity to airports and populated areas, and national security, all criteria as set forth in Section 333 ofthe Reform Act have been satisfied. It is under these circumstances that the petitioner finds adequate justification for its request for exemption to be granted, and thus respectfully submits this letter for approval.

Best Regards,

Spencer Schrader Sunflower Unmanned Solution, LLC SunflowerUnmannedSolutions@gmail.com 785

-577

-3417 800 South Santa Fe, Salina, KS 67401