# 2015

Stidham Reconstruction & Investigation , LLC PO B ox 632 5961 Hwy 80 Wooton, KY 41776 (606) 279
- 6043



# EXEMPTION **REQUEST UN**  **DER SECTION**  **333 OF**  **THE FAA**  **REFORM AC** **T AND**  **PART 11**  **OF THE FEDERAL AVIATION**  **REGULATIONS**

August 7, 2015**EXEMPTION REQUEST UNDER SECTION 333 OF THE FAA REFORM**

**ACT AND PART 11 OF THE FEDERAL AVIATION REGULATIONS** 

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Page 1 August 7, 2015 U.S. Department of Transportation Federal Aviation Administration Docket Management System 1200 New Jersey Ave., SE Washington, DC 20590 **Regulatory Docket No. :**  **Date Submitted**  **: August 7, 2015**  Dear Sir or Madam : Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the “Reform Act”) and 14 C.F.R. Part 11, Stidham Reconstruction & Investigation LLC (SRI) , seeks an exemption from the Federal Aviation Regulations listed below:

 14 C.F.R. 21, subpart H  14 C.F.R. 61.3  14 C.F.R. 61.113(a)&(b)  14 C.F.R. 61.133(a)  14 C.F.R. 91.9(b)(2)  14 C.F.R. 91.103(b)  14 C.F.R. 91.105  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(a) & (b)  14 C.F.R. 91.319(a)(1)  14 CFR 91, Subpart E (91.405, 91.407, 91.409, 91.417) The requested exemption would authorize SRI to conduct commercial operations using the DJI Phantom f or aerial data collection in support of forensic mapping and reconstruction of crime scenes and traffic collisions . These applications would utilize digital photography and imaging to measure areas through photogrammetric software processes
. In order to ensure at least an equivalent level of safety to currently authorized operations using manned aircraft the Phantom unmanned aircraft system (UAS) owned by SRI will be operated only by individuals who hold at least an FAA issued private, recreational, or sport pilot certificate and who have successfully logged two hours of in

- air flight time with the DJI Phantom in a controlled setting.**EXEMPTION REQUEST UNDER SECTION 333 OF THE FAA REFORM**

**ACT AND PART 11 OF THE FEDERAL AVIATION REGULATIONS** 

## 201 **5**

Page 2 The characteristics of the UAS, detailed UAS operator requirements, and UAS operating parameters given below will ensure that all SRI UAS operations are carried out with an equivalent or higher level of safety than currently authorized manned aircraft operations. The details below regarding SRI’s intended UAS applications provide clear evidence that approval of this exemption is in the public interest. 

### CHARACTERISTICS OF THE UAS **:** The Phantom has a diagonal motor

- to
- motor distance of approximately 14 inches. The Phantom is approximately 23 inches across, measured diagonally and including the propellers and propeller guards
. The Phantom is constructed primarily of frangible materials (plastic) and weigh less than 3 pounds. The Phantom is powered by a 2200 mAh LiPo battery giving it approximately 10 minutes of flight time
. The maximum flight speed of the Phantom is 23 miles per hour and the maximum ascent/descent rate is 14 miles per hour. The Phantom communicates with the controlling receiver on a frequency of 2.4 GHz ISM on 7 channels. The maximum communicating distance for the Phantom is listed as 1000 meters. The Phantom operates using an on - board GPS receiver and flight controller for automatic attitude adjustment and flight stabilization. The Phantom also utilizes a GPS “home” location to automatically return to safely when communication is lost with the receiver. The Phantom operated by SRI for commercial use will be registered in accordance with 14 C.F.R Part 47, and will be marked in accordance with 14 C.F.R. Part 4 5, Subpart C, in a size as large as practical for the size of the UA. The Phantom operated by SRI will be maintained in accordance with the manufacture’s maintenance, overhaul, replacement, inspection, and life limit requirements for the aircraft and aircraft components and all pertinent instructions in the user manuals. Repairs, component changes, and software/firmware updates will be recorded in the UAS’s maintenance log. Maintenance log entries will include the date, UAS ID number, registration number, current UAS flight time, a description of work performed, and the name of the individual who completed the work . Any UAS that has undergone maintenance or alterations that affect the UAS operation or flight characteristics, e.g. replacement of a flight critical component, must undergo a functional test flight, prior to use in any commercial operations. The functional test flight must be conducted in such a manner so as to not pose an undue hazard to persons and property. The pilot in command (PIC) who conducts the functional test flight must make an entry in the aircraft records. A pre

- flight inspection of the UAS will be completed by the PIC prior to each flight operation as specified in the DJI Phantom Owner’s Manual. If the inspection reveals a condition that affects the safe operation of the UAS, the aircraft is prohibited from operating until the necessary maintenance has been performed and the UAS is found to be in a condition for safe flight. All SRI UAS will comply with all applicable manufacturer safety bulletins. The safety and reliability of the DJI Phantom that numerous FAA exemptions have previously been approved for their use in commercial operations.**EXEMPTION REQUEST UNDER SECTION 333 OF THE FAA REFORM**

**ACT AND PART 11 OF THE FEDERAL AVIATION REGULATIONS** 

## 201 **5**

Page 3 

### UAS OPERATING PARAMETERS **:** In order to provide for a level of safety at least equivalent to operations conducted using manned aircraft, all SRI commercial UAS operations will be conducted in accordance with the following specific operating limitations:

 The UA may not be operated at a speed exceeding 20 knots ( 23 miles per hour). In no case will the UA be operated at airspeeds greater than the maximum UA operating airspeed recommended by the aircraft manufacturer.  All operations shall be conducted in accordance with an Air Traffic Organization (ATO)

- issued COA.  All UA operations will occur at or below 400 feet above ground level (AGL)
.  No UA will be operated within 3 nautical miles of an airport reference point (ARP) as denoted in the current FAA Airport/Facility Directory (AFD) or for airports not denoted with an ARP, the center of the airport symbol as denoted on the current FAA published aeronautical chart, unless a letter of agreement with that airport’s management is obtained or otherwise permitted by a COA issued to SRI . The letter of agreement with the airport management must be made available to the Administrator or any law enforcement official upon request.  No UA will be operated within class B, C, D or E airspace unless a letter of agreement from the controlling Air Traffic Control (ATC) office is obtained or the flight is otherwise permitted by a COA issued to SRI . The letter of agreement from ATC must be made available to the Administrator or any law enforcement official upon request.  The UA must be operated within visual line of sight (VLOS) of the PIC at all times. This requires the PIC to be able to use human vision unaided by any device other than corrective lenses, as specified on the PIC’s FAA

- issued airman medical certificate or U.S. driver’s license.  All operating documents and a grant of exemption must be accessible during UAS operations and made available to the Administrator upon request. If a discrepancy exists between the conditions and limitations in the grant of exemption and the procedures outlined in the operating documents, the conditions and limitations in the grant of exemption take precedence and must be followed. Otherwise, the PIC must follow the procedures as outlined in the operating documents.  UAS operations may not be conducted during night, as defined in 14 CFR § 1.1. All operations must be conducted under visual meteorological conditions (VMC). Flights under special visual flight rules (SVFR) are not authorized.  The UA may not be operated less than 500 feet below or less than 2,000 feet horizontally from a cloud or when visibility is less than 3 statute miles from the PIC.  Prior to each flight the PIC must inspect the UAS to ensure that it is in a condition for safe flight. If the inspection reveals a condition that affects the safe operation of the UAS, the aircraft is prohibited from operating until the necessary maintenance has been performed and the UAS is found to be in a condition for safe flight. All maintenance and alterations must be properly documented in the aircraft records.**EXEMPTION REQUEST UNDER SECTION 333 OF THE FAA REFORM**

**ACT AND PART 11 OF THE FEDERAL AVIATION REGULATIONS** 

## 201 **5**

Page 4  Any UAS that has undergone maintenance or alterations that affect the UAS operation or flight characteristics, e.g. replacement of a flight critical component, must undergo a functional test flight. The PIC who conducts the functional test flight must make an entry in the aircraft records.  If the UAS loses communications or loses its GPS signal, the UA must return to a predetermined location.  The PIC must abort the flight in the event of unpredicted obstacles or emergencies.  The PIC is prohibited from beginning a flight unless the UA’s battery level is at 75% or higher. The PIC must begin returning the UA to the designated landing area when the battery level drops below 25%.  Documents used by the operator to ensure the safe operation and flight of the UAS and any documents required under 14 CFR §§ 91.9 and 91.203 must be available to the PIC at the Ground Control Station of the UAS any time the aircraft is operating. These documents must be made available to the Administrator or any law enforcement official upon request.  The UA must remain clear and give way to all manned aviation operations and activities at all times.  The UA may not be operated below 150 feet AGL in the vicinity of any roadway while vehicular traffic is present.  The UAS may not be operated by the PIC from any moving device or vehicle.  UA will not be operated directly over nonparticipating persons unless barriers or structures are present that sufficiently protect nonparticipating persons from the UA and/or debris in the event of an accident. UA will not be operated over any open

- air ass embly of people.  Any incident, accident, or flight operation that transgresses the lateral or vertical boundaries of the operational area as defined by the applicable COA will be reported to the FAA's UAS Integration Office (AFS

- 80) within 24 hours. Accidents will be reported to the National Transportation Safety Board (NTSB) per instructions contained on the NTSB Web site: www.ntsb.gov
. 

### APPLICATIONS AND PUBLIC INTEREST **:** The requested exemption would allow SRI to operate the DJI Phantom for the purposes of forensic mapping and reconstruction of crime scenes and traffic collisions . These operations are completed on residential, commercial and public properties including streets, roads, and highways. Use of UAS for these applications will offer significant advantages related to safety, time, and cost as well as overall improvement of quality and accuracy
. SRI currently provides forensic mapping services in support of civil and criminal litigation . Our crime scene forensic models often demonstrate that certain events either could or could not have occurred as described by witnesses or affiants in the criminal court. This is clearly in the public interest in order to ensure justice is carried out according to sci entifically sound evidence and methods. Furthermore, our traffic collision models often identify safety hazards that currently exist under various simulated conditions and recommend corrective modifications. This also is clearly in the public interest to improve the safety of motorists across the state of Kentucky.**EXEMPTION REQUEST UNDER SECTION 333 OF THE FAA REFORM**

**ACT AND PART 11 OF THE FEDERAL AVIATION REGULATIONS** 

## 201 **5**

Page 5 Currently these operations are conducted using traditional survey techniques utilizing a Nikon Nivo 3.M total station and a topographic pole prism targets in order to map areas required to build 3D models. These methods require survey technicians to operate close to moving traffic, often where vehicular accidents have occurred previously due to unsafe road conditions. The ability for SRI to utilize a UAS in order to map crime scenes and traff ic collision scenes greatly improves the safety for technicians by removing personnel and equipment from potential harm caused by unsafe or inattentive drivers. Use of manned aircraft is typically not feasible and therefore valuable information remains beyond the reach of the technician . In almost all cases, use of a UA is quicker and easier than any other alternative and often yields better information. Due to their small size and the fact they carry no fuel the DJI Phantom pose s a very low risk of damage to persons, structures , or vehicles on the ground. Because these UA are electric powered, they create no harmful emissions and make very little noise. 

### SUMMARY THAT CAN BE PUBLISHED IN THE FEDERAL REGISTER **:** SRI requests the grant of an exemption to the following specific sections of the Title 14 Code of federal Regulations which would allow it to operate micro UAS for commercial use: 14 CFR 21, subpart H, 14 C.F.R Sections 61.3, 61.113(a)&(b), 61.133(a), 91.9 (b)(2), 91.103(b), 91.105 , 91.109(a), 91.119, 91.121, 91.151(a), 91.203(a) &(b), 91.319(a)(1), 91.405, 91.407, 91.409, 91.417 

### CONCLUSIONS **:** SRI respectfully requests that the FAA grant the exemption sought in this request. SRI believes that considering the small size and weight of the UAS, along with the UAS PIC training and certification requirements stipulated above and the strict operating guidelines proposed herein, it is clearly demonstrated that the UAS will be operated s afely in the national air space (NAS) with an equivalent or greater level of safety compared to manned aircraft. We are prepared to modify or amend any part of this request as deemed necessary by the FAA to satisfy the need for an equivalent level of saf ety. Please contact us at any time if you require additional information or clarification. Sincerely,
Jeremy Woods
Phone: (606) 279
- 6043 ◦ Fax: (606) 279
- 6042 ◦ Address: P.O. Box 632 Wooton, KY 41776

Email: jeremywoods@stidhamreconstruction.com