April 6, 2015 United States DepartmentofTransportation FederalAviationAdministration Docket Management System 1200 NewJerseyAvenue, NE Washington, DC 20590 Filed inwww.regulations.gov 

# Akin Gum

STRAUSS HAUER & FELD LLP

GREGORY S. WALDEN +1 202.887.4213/fax: +1 202.887.4288 gswalden@akingump.com

Re: Petitionfor Exemption ofFirestorm Emergency Services Ltd. d/b/a Firestorm UAV under Section 333 ofthe FAAModernization and ReformAct, 49 U.S.C. 44701(f), and 14 C.P.R. Part 11 OnbehalfofFirestorm Emergency Services Ltd. d/b/a Firestorm UAV ("Firestorm"), we hereby seek an exemption from certain Federal Aviation Regulations enumerated below, as authorized by Section 333 ofthe FAAModernization and Reform Act ("Section 333"), Subsection44701(f) ofthe Federal Aviation Act, and pursuant to the procedures set forth in Part 11 of the Federal Aviation Regulations, to allow Firestorm to operate the Spreading Wings 1000+ UAV manufactured by DJI modified by Troy Built Models called TigerStrike® TF to carry the patent pending Intelligent Radio Direction Finding (iRDF) system to provide emergency services such as search and rescue, preventing runaways of persons with dementia, and geo-locating a firefighter in abuildingfilled with smoke, in bothrural and urban environments.
Because the relief requested herein is in all material respects similar to the relief requested in previously granted exemptions, and because Firestorm agrees.to abide by and comply with the terms and conditions in those exemptions, Firestorm respectfully requests summary processing ofthis petition. Firestorm is the only antenna/software receiver manufacturer of the patent pending highly compact intelligent radio frequency direction finding set of capabilities which are in further enhanced when utilized with the capability of the UAV. The TigerStrike® technology uses proprietary multilevel functionality that accommodates both geolocation from a GPS-equipped transmitter to a radio transmission source of any kind from 100 MHz to 2 GHz, for rapid detection and geolocation ofpeople and property by way ofbeacons and radio frequency energy with a very high accuracy. The unparalleled accuracy when networked with other TigerStrike® devices provides an immediate solution in geo-locatingthe target.

Robert 8. Strauss Building 11333 New Hampshire Avenue, N.W. 1 Washington, D.C. 20036-15641 202.887.4000 Ifax 202.887.4288 Iak1ngump comFirestorm Emergency Services Ltd. Petition for Exemption April 6, 2015 Page 2 TigerStrike® is a quantum leap in the evolution of locator technology. It comprises an interchangeable antenna system coupled with an artificial intelligence-based digital signal processingreceiver that is capable ofcommunicating to a compact Windows-based computer to provide near-instant targeting and location data on an easy-to-use mapping screen. Designed and manufactured by experienced search and rescue professionals, it is the first life-saving technology that is equally effective at locating crashed airplanes, lost hikers or skiers equipped withELTbeacons on 121.5 MHz or406 MHz, lostAlzheimer'spatientswithbeaconbracelets in the 216 MHz range, trapped firefighters using their own radios as beacons in either the VHF or UHFrange, and ahost ofotherlocatorfunctions.
Due to its unparalleled accuracy, TigerStrike® saves lives by dramatically increasing the speed to recovery ofthose lost or in distress while making the searchers and their results visible in real time to their leaders via the networked command module. Its hand-held phased array antenna system is coupled with hand-held computers, software applications and topographical mapping solutions which can be mobile mounted, airborne, or in fixed locations, all with the same advanced system components and robust command software capabilities. Firestorm currently provides these products in the hand-held ground based platform to selective government agencies and search and rescue organizations. TigerStrike®, has successfully been tested by the Department of Defense, Department of Homeland Security, National Air Search and Rescue, NASA, US Customs and Border Protection, police departments, fire departments, Alzheimer locators, wildlife experts, and others. The US Army Special Forces Command assessed the TigerStrike® at Camp Roberts and described it as "amazing." The DOD Rapid Reaction Technology Office conducted an extensive test ofTigerStrike® in the Yuma Proving Ground in Arizona, and produced a 75-page report in May 2012 which concluded that the technology had "merit" and recommended further assessment for mission task capabilities. In DOD terminology, systems identified as having merit are considered technologies that provide operationally relevant military solutions. As an example of its potential, the Army currently deploys Wolfhound which costs $135,000, weighs 38lbs, and uses inferiortechnology, while the TigerStrike® military version is faster and more accurate, costs only $52,000, and weighs only 5.6lbs. By integrating this sensor technology with a micro UA V, Firestorm has effectively created the opportunity for small to intermediate organizations to have similar capability as a multimillion dollarmanned aircraft. Firestorm has initially chosen the DJI 1000+ UAV, which it has successfully integrated with its technology. The many safety benefits ofthis UAV make it easy to fly and less stressful on theFirestormEmergency Services Ltd. Petitionfor Exemption April 6, 2015 Page 3 operator. Because Firestorm's sensor package weighs less than the traditional gimbal and camera, flight characteristics are improved. When available, Firestorm will add a parachute option to the DJI 1000+for an additional margin ofsafety.
For training purposes, the DJI Inspire 1 UAS will be used to familiarize new pilots after they have completed a commercial UAV training course. Pilots holding commercial pilot certificates withthe class III medical certificationwill also receive this familiarization training

.. The Firestorm crewis based onthe type ofmission. The crewfor a simple cameramissionwould be a Pilot and Observer. For an intermediate mission using the TigerStrike technology, the crew would consistofaPilot, an Observer, and a Sensor Operator. For amissionwhere there maybe a congregation ofpersons in the location ofthe operation, a Pilot, Observer, Sensor Operator and Mission Safety/Agency Liaison Officer would be employed. Secure communication would be maintained by the use of a professional intercom system that would allow two of the four participants to talk via Link to Motorola VHF/UHF handheld to the host agency. This would provide a sterile operating environment for the crew. For emergency purposes an Iridium SATPHONEwithbe preprogrammedwith the local FAAFSDO and any adjacent airporttower. Where possible in all missions, an operating base that includes a safety orange 10 x 10 EZ up tent will host the equipment and an apron for landing and takeoffofthe UAV. This area will be boundedby cautiontape thatwill secure the operatingarea from potential onlookers. 

### The name ofthe applicant is Firestorm Emergency Services Ltd d/b/a Firestorm UAV. The primary Firestorm contact is Mr. Murray Craig, 1700 Seventh Avenue, Suite 2100, Seattle, Washington 98101. Telephone is 360-920-8715. His email is murray.craig@fsems.com and Firestorm'sweb address is www.fsems.com. 

### Exemptionsrequested
14 C.F.R. Part21 (airworthiness certification) 14 C.F.R. Part27 (normal category rotorcraft) 14 C.F.R. 61.113 (a) and (b) (pilot certificationand qualification) 14 C.F.R. 91.7(a) (airworthiness) 14 C.F.R. 91.119(b) and (c) (minimum safe altitudes) 14 C.F.R. 91.151(a) and (b) (fuel requirements in VFR conditions) 14 C.F.R. 91.405 (a) and (b) (maintenance) 14 C.F.R. 91.407(a)(1) (approval for return to service) 14 C.F.R. 91.409(a) (annual and airworthiness certificationinspection)FirestormEmergency Services Ltd. Petitionfor Exemption April 6, 2015 Page 4
14 C.F.R. 91.417(a) and (b) (maintenancerecords)


### Safety equivalenceor noadverse effecton safety UnmannedAerialVehicleand System The FAAis well familiar with the DJI 1000+, as ithas granted several exemptions under section 333 for operators proposing 

### to use this unmanned aircraft. See Exemption No. 11156 (Total Safety U.S., Inc.); Exemption No. 11158 (Team 5, LLC); Exemption No. 11159 (Shotover Camera Systems L.P.); Exemption No. 11160 (Helinet Aviation Services, LLC; and Exemption No. 11184 (Low Country RC, Corporation). The DJI S1000+ has a number of technological capabilities to demonstrate its airworthiness. In the event ofa loss ofGPS signal, the UAV will not lock in its position and automatically go to ATTI mode and remain stable. Should there be a loss ofpower, the pilot has control ofthe UA V to perform auto rotation capability and land the aircraft. Ifthe UA V encounters an unexpected obstacle, the pilot will either divert the flight or maintain the UA V in a safe hoverposition away from the obstacle. Given its small size, operational capabilities, and restricted area in which the UAV will operate, an exemption from Part 21, Subpart H, Airworthiness Certificates, and 14 C.F.R. 91.7(a), is warranted, as Firestorm's UAV satisfies the equivalent level ofsafety as compared with manned aircraft and meets the criteria in section 333. Operating the UA V without an airworthiness certificate under the conditions proposed will be safer than operating a manned helicopter operatingwith an airworthiness certificate and not subjectto suchconditions. The UAV with payload is less than 6 pounds; it carries no explosive materials or flammable liquid fuels, and operate exclusively overprivate property, with no passengers or crew on board. As the FAAhas found ingrantingan exemptionto Clayco, ExemptionNo. 11109, atpage 10: The limited weight significantly reduces the potential for harm to participating and nonparticipatingindividuals orproperty in the event ofan incident or accident. The risk to an onboardpilot and crew during an incident or accident is eliminated with the use ofa UAfor the aerial filming operations. For the reasons outlined above, Firestorm also seeks an exemption from the certification requirements for normal categoryrotorcraft inPart 27.Firestorm Emergency Services Ltd. Petitionfor Exemption April 6, 2015 Page 5
In support of Firestorm's request for an exemption from 14 C.P.R. 91.405(a), 91.407(a)(1), 91.409(a)(1) and (2), and 91.417(a) and (b), Firestorm will adhere to the following inspection and maintenance program: Firestorm will inspect the UA V before and after each operation, as well as perform daily, weekly, monthly, and annual inspections, as setforth in its Pilot Operating Handbook (provided to the FAA separately from this document). Before each flight, the pilot in command will inspect the UAV to ensure it is in a safe condition for flight. The preflight inspection will account for any discrepancy, such as an inoperable component, item, or equipment. Firestorm will not initiate a flight ifthe inspection reveals a condition that adversely affects the safety ofoperations, and will not operate that UAV until it is found to be in a safe condition. Any UAV that has undergone maintenance or an alteration that affects the UAV's operation orflight characteristicswill undergo afunctional flight testbefore return to service. Firestorm will follow the manufacturer's UAV requirements relating to components, maintenance, overhaul, replacement, inspection and life limits. Firestorm will record all maintenance, alterations, and the functional flight test in the UA V logbook, including total flight hours, description ofwork accomplished, and the signature ofthe UAV technician who returned the UAV to service. These records with be used to establish similar criteria as aircraft best practices, like MeanTime BetweenFailures, Total Time Since New, Time Between Inspections , Time Since Inspection, Time Since Overhaul and others through tracking, hours, landings, cycles and dates on each ratable, and consumable part on the UAV as part ofaproposed industry wide programwith DJI. Firestorm's UAV is equipped with an altimeter that provides the pilot with a constant digital display of altitude. Moreover, the UAV will be operated within the visual line of sight of the pilot in command and observer and below 400 feet, above vacant property. Accordingly, Firestorm does notbelieve an exemptionfrom 14 C.P.R. 91.121 is required.
In supportofFirestorm'srequest for an exemptionfrom fuel requirements in 14 C.P.R. 91.151(a) and (b), Firestorm notes that its UAV is battery-powered and is operated for brief periods of time, within the battery capacity ofthe UAV. 

### UAVand 

### UAS Operator Qualifications and Training
In support ofFirestorm's request for an exemption from the pilot certification and qualifications requirements in 14 C.P.R. 61.113(a) and (a), Firestorm asserts that an equivalent level ofsafety is achieved by the UAV-specific experience of its Pilots. Each Firestorm pilot will receive a commercial UAS training course and then receive flight trainingusingthe DJI Inspire 1UAS, or will hold acommercialpilot certificatewith the class III medical certification.FirestormEmergency Services Ltd. Petitionfor Exemption April 6, 2015 Page 6
The FAA has exemption authority under section 44701(t) to exempt UAV operators from the particularrequirements ofParts 61 and 67

- such as the requirement to conduct flight training on board an aircraft

- and develop airman certification requirements specifically designed for small UAVoperations. Applyingmanned aircraftpilotcertificationrequirements to small UAVs is not necessary as amatter ofsafety, and does notmake sense as amatter ofpublicpolicy. Firestorm believes that FAA's determination in the Astraeus Aerial and other exemptions that a commercial pilot certificate is not required for the operators of UAVs for closed set filming applies equally to the nature ofits UAV operations: [T]he experience obtained beyond a private pilot certificate in pursuit of a commercial pilot certificate in manned flight does not necessarily aid a pilot in the operational environment proposed by the petitioner; the FAA considers the overriding safety factor for the limited operations proposed by the petitioner to be the airmanship skills acquired through VAS-specific flight cycles, flight time, and specific make and model experience, culminatinginverificationthrough testing. Firestormbelieves this reasoning supports aUAV/UAS-focused training and experience regimen that should obviate not only a commercial pilot certificate but also a private pilot certificate because any training will be focused on the particular skills of operating the particular small UAV and the particularnature ofUAS operations. Firestorm notes that the FAA has proposed in its recent SUAS Notice ofProposed Rulemaking that a small UAS pilot would be required to successfully complete an aeronautical knowledge test and receive an unmanned aircraft operatorpermit with small UAS rating, but would not be required to obtain a commercial orprivate pilot certificate. Also, medical certification would be obviated by apilot's self-certification before flight that the pilot is physically and mentally fit to operate the UAS. Accordingly, the FAA should grant appropriateexemptionreliefto permitFirestorm to use pilots who have successfully completed commercial UAS training and have also gained flying experience usingthe DJIInspire 1UAV. 

### UAVand UAS OperatingParameters Firestorm will operate its UA V in full compliance with any local permit or safety ordinance, in accordance with its Handbook. All flights will be conducted within the visual line ofsight ofthe pilot in command, in a tightly circumscribed area ofa single parcel ofproperty, with the consentFirestormEmergency Services Ltd. Petitionfor Exemption April 6, 2015 Page 7
ofthe property owner and/or developer. Although the UAV may be operated in a metropolitan area, it will be flown below400 feet AGL, Firestorm will notify the appropriate Flight Standards District Office "("FSDO") and Air Traffic Control for any operation within five miles of an airport. Firestorm conducts a briefing before each day's operations, which all personnel participating in the operations must attend. Firestorm will obtain written consent of any person who will be participating in the operations or otherwise be on the property over which the UAV will be flown. Firestorm will provide notice to personsresiding orworkingin any adjacentbuildings or structures. Firestorm will limit its operations to daytime Visual Flight Rules ("VFR") plus 30 minutes before sunrise and 30 minutes after sunset (dusk), with each operation ending no later than 30 minutes after sunset. The UAV is equipped with LED lightingvisible for 3 miles. Accordingly, we do notbelieve an exemptionfrom 14 C.P.R. 91.209 is necessary. Firestorm seeks an exemption from the requirement in 14 C.P.R. 91.119, subsection (b), that an aircraft must remain at least 1,000 feet above any congested area or open air assembly of persons, and subsection (c), that an aircraft must remain at least 500 feet above any person or structure in an area other than populated orcongested, and not closerthan 500 feet to any person, vehicle, or structure. These requirements were adopted with fixed-wing, manned aircraft operations in mind. While Firestorm may operate its UAVin ametropolitan area, the operations will not be operated over a congested area or open air assembly ofpersons. Combined with the technological capabilities ofthe UAV and that the UAVwill be operated within the visual line of sight of the pilot and an observer, Firestorm submits that its operational limitations provide an equivalentlevel ofsafety to thatprovided in section 91.119. Public interest Firestorm's UAV operations will substantially benefit wandering dementia patients with wrist beacons, Emergency Locator beacons both 406 and 121.5 used by ground teams, geolocation of the firefighters' radio in wild land fire and structure fires by using the TigerStrike® technology to geolocate them using their existing radios as a beacon. Lost hikers and skiers who are equipped with the FRS radios can also be geo-located effectively.Tagged wildlife canbe located and observed with little orno interactions/riskto the animal that is being tracked orthe biologist. The critical elementis the speed to recoverythat mitigates damage bothbodily and financial.FirestormEmergency Services Ltd. Petition for Exemption April 6, 2015 Page 8
The inspection of structures like bridges and railway lines can be increasingly important in the future as well. Operating UAVs under the limitations proposed by Firestorm will avoid any risk of harm to pilots as well as persons and people on the ground that would be present during the operation of manned helicopters. Finally, UAV operations will also require a much smaller energy footprint thanwithmanned helicopters. Operations limitedto the UnitedStates Firestorm does not intend to operate its UA V outside ofthe United States. Summary forFederalRegister Firestorm submits the following summary to be included inthe Federal Register, should the FAA determine thatpublicationofa summaryis required. Firestorm seeks an exemptionto operate the DJI 1000+withTigerStrike® technology to perform commercial and emergency services.
Because grantingthispetitionwould not set aprecedent, and indeed would be consistentwith the terms and conditions ofprevious exemptions, Firestormrespectfully requests the FAAdispense withFederal Registerpublicationand publiccomment. Sincerely,

Craig, FirestormEmergency Services Ltd. Proprietary Documentsprovided to FAAseparately
Pilot OperatingHandbookfor DJI SlOOO (Troy Built) DJI SpreadingWings SlOOO UserManual Vl.lO A2Flight Control User Manual