Central Oregon Aerial LLC

Austin Buskohl (President) 63351 NW Britta St Bend, OR 97703

October 27, 2015

U.S. Department of Transportation Docket Management Sy stem 1200 New Jersey

Ave, SE Washington, DC 20590

RE: Amendment to Exemption No. 12137 I s sued Under Section 333 of the FAA Reform Act and Part 11, in Regulatory Docket No. FAA

- 2015

- 1625 of the Federal Aviation Regulations

Dear Sir or Madam: Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the “Reform Act” or “Secti on 333”), Subsection (f) of 49 U.S.C. § 44701, and 14 C.F.R. Part 11, Central Oregon Aerial Surveying LLC (“Central Oregon Aerial”) seeks an amendment to Exemption No. 12137 to operate two additional small Unmanned Aircraft Sy stems: the DJ I Phantom 3 Profe ssional. On July 24, 2015, the FAA issued Exemption No. 12137 to Central Oregon Aerial LLC to allow it to operate the Yuneec Ty

phoon Q500 sUAS for aerial surveying, inspection and data collection services. This requested amendment to that exemption will al low Central Oregon Aerial LLC to operate the DJ I Phantom 3 Professional for the same reasons and under the same conditions. There has been no other change in conditions and reasons relative to public interest and safet y that were the basis for granting the original exemption.

**Additional sUAS Platform**

**– DJI Phantom 3 Professional** 

Operations pursuant to the exemption will be subject to strict operating requirements and conditions to ensure at least an equivalent level of safet y to currentl y authorized operations using manned aircraft and under the same conditions as permitted by the FAA in Exemption No. 12137. The DJ I Phantom 3 Professional weighs approximately 2.83 pounds, including payload. Both models are powered electrically via small, lithium poly

mer batteries that drive electric propellers. The DJ I Phantom 3 Professional has extensive automated control features, redundant sy stems, and integrated fail

- safes, and they will be operated under controlled conditions and at low altitudes in airspace that is li mited in scope.

**Exemptions Requested**

Central Oregon Aerial LLC respectfull y requests exemptions from the following regulations previously

granted by

the FAA in Exemption No. 12137:• 14 C.F.R. Part 21

• 14 C.F.R. 45.23 • 14 C.F.R. 61.113(a) & (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. 91.203 • 14 CFR Subpart E (91.401

- 91.417)

**Airworthiness of the DJI Phantom 3 Professional**

The DJ I Phantom 3 Professional is airworthy and compliant with a significant level of safet y. In fact, the man y previous 333 Grants of Exemptions by the FAA for operations of the Phantom 3 Professional and similarly designed DJ I platforms, underscore that operations of the Phantom 3 Professional Central Oregon Aerial LLC will not adversel y affect safet y when compared to similar operations conducted b y aircraft that have been issued an airworthiness certificate under 14 C.F.R. Part 21, Subpart H. [E.g., FAA Exemption Nos. 11357 (granting exemption for the DJI Phantom 2 Vision +), 11325 (granting same for the DJ I Phantom 2)]. To be sure, the DJ I Phantom 3 Professional weighs a mere 2.83 pounds (approximately 1,280 grams) and is powered electrically

by small, lithium poly

mer batteries that drive electric propellers. It operates at a cruising speed of no more than 16 meters per second. This platform was designed with extensive automated control features, redundant systems, and integrated fail

- safes which enhance safe takeoff, flight, and landing in many conditions. Further details of these features are provided in the DJIPhantom 3 Professional operating manual.

To maintain airworthiness, Central Oregon Aerial LLC will follow the inspection and maintenance program designed spe cificall y for the Phantom 3 Professional by their manufacturer. This program is enhanced b y in

- flight monitoring sy stems for the Phantom 3 Professional that monitor current position, direction, battery charge, flight time, and altitude, including both abov e the takeoff location. If onboard sensors detect critical situation at any time (low battery , weak data link signal, etc.) the aircraft will automatically initiate a preprogrammed safet y procedure. In the event of an y malfunction, the Phantom 3 Profession al will undergo all maintenance required b y the manufacturer and undergo flight

- testing before recommencing commercial operations. Good cause exists to grant Central Oregon Aerial LLC an amendment to Exemption No. 12137. Doing so, is in the public interest based on the clear direction in Section 333, the Federal Aviation Act, the high and equivalent level of safety of the proposed operations, and in consideration of the size, weight, speed and limited operating area associated with the Phantom 3 Professiona l. Accordingl y, Central Oregon Aerial LLC respectfully requests that the FAA grant an expedited amendment to add the DJI Phantom 3 Professional to its sUAS operations.

Truly y ours, Austin Buskohl Central Oregon Aerial LLC