April 6, 2015 

United States Department of Transportation 

Federal Aviation Administration 

Docket Management System 

1200 New Jersey Avenue, NE 

Washington, DC 20590 

Filed in www.regulations.gov 

Akin Gum 

STRAUSS HAUER & FELD LLP 

GREGORY S. WALDEN 

+1 202.887.4213/fax: +1 202.887.4288 

gswalden@akingump.com 

Re: Petition for Exemption of Firestorm Emergency Services Ltd. d/b/a Firestorm UA V 

under Section 333 of the FAA Modernization and Reform Act, 49 U.S.C. 44701(f), and 

14 C.P.R. Part 11 

On behalf of Firestorm Emergency Services Ltd. d/b/a Firestorm UA V ("Firestorm"), we hereby 

seek an exemption from certain Federal Aviation Regulations enumerated below, as authorized 

by Section 333 of the FAA Modernization and Reform Act ("Section 333"), Subsection 44701(f) 

of the 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 a building filled with smoke, in both rural 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 

of this 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 UA V. 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 of people and property by way of beacons and radio frequency energy 

with a very high accuracy. The unparalleled accuracy when networked with other TigerStrike® 

devices provides an immediate solution in geo-locating the target. 

Robert 8. Strauss Building 11333 New Hampshire Avenue, N.W. 1 Washington, D.C. 20036-15641 202.887.4000 I fax 202.887.4288 I ak1ngump com 
Firestorm 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 

processing receiver that is capable of communicating 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 

with ELT beacons on 121.5 MHz or 406 MHz, lost Alzheimer's patients with beacon bracelets in 

the 216 MHz range, trapped firefighters using their own radios as beacons in either the VHF or 

UHF range, and a host of other locator functions. 

Due to its unparalleled accuracy, TigerStrike® saves lives by dramatically increasing the speed 

to recovery of those 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 of TigerStrike® 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 inferior technology, 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 

dollar manned aircraft. 

Firestorm has initially chosen the DJI 1000+ UAV, which it has successfully integrated with its 

technology. The many safety benefits of this UAV make it easy to fly and less stressful on the 
Firestorm Emergency Services Ltd. Petition for 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 of safety. 

For training purposes, the DJI Inspire 1 UAS will be used to familiarize new pilots after they 

have completed a commercial UA V training course. Pilots holding commercial pilot certificates 

with the class III medical certification will also receive this familiarization training .. 

The Firestorm crew is based on the type of mission. The crew for a simple camera mission would 

be a Pilot and Observer. For an intermediate mission using the TigerStrike technology, the crew 

would consist of a Pilot, an Observer, and a Sensor Operator. For a mission where there may be a 

congregation of persons in the location of the 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 

SATPHONE with be preprogrammed with the local FAA FSDO and any adjacent airport tower. 

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 takeoff of the UAV. This area will be 

bounded by caution tape that will secure the operating area from potential onlookers. 

The name of the 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's web address is www.fsems.com. 

Exemptions requested 

14 C.F.R. Part 21 (airworthiness certification) 

14 C.F.R. Part 27 (normal category rotorcraft) 

14 C.F.R. 61.113 (a) and (b) (pilot certification and 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 certification inspection) 
Firestorm Emergency Services Ltd. Petition for Exemption 

April 6, 2015 

Page 4 

14 C.F.R. 91.417(a) and (b) (maintenance records) 

Safety equivalence or no adverse effect on safety 

Unmanned Aerial Vehicle and System 

The FAA is well familiar with the DJI 1000+, as it has 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 of a loss of GPS signal, the UA V will 

not lock in its position and automatically go to ATTI mode and remain stable. Should there be a 

loss of power, the pilot has control of the UA V to perform auto rotation capability and land the 

aircraft. If the UA V encounters an unexpected obstacle, the pilot will either divert the flight or 

maintain the UA V in a safe hover position away from the obstacle. 

Given its small size, operational capabilities, and restricted area in which the UA V 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 of safety 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 

operating with an airworthiness certificate and not subject to such conditions. 

The UA V with payload is less than 6 pounds; it carries no explosive materials or flammable 

liquid fuels, and operate exclusively over private property, with no passengers or crew on board. 

As the FAA has found in granting an exemption to Clayco, Exemption No. 11109, at page 10: 

The limited weight significantly reduces the potential for harm to participating and 

nonparticipating individuals or property in the event of an incident or accident. The risk 

to an onboard pilot and crew during an incident or accident is eliminated with the use of a 

UA for the aerial filming operations. 

For the reasons outlined above, Firestorm also seeks an exemption from the certification 

requirements for normal category rotorcraft in Part 27. 
Firestorm Emergency Services Ltd. Petition for 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 set forth in its Pilot Operating 

Handbook (provided to the FAA separately from this document). Before each flight, the pilot in 

command will inspect the UA V 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 if the inspection reveals a condition that adversely 

affects the safety of operations, and will not operate that UA V 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 or flight characteristics will undergo a functional flight test before return to service. 

Firestorm will follow the manufacturer's UA V 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 of work accomplished, and the signature of the UA V technician who returned 

the UAV to service. These records with be used to establish similar criteria as aircraft best 

practices, like Mean Time Between Failures, 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 UA V as part of a proposed industry wide 

program with DJI. 

Firestorm's UAV is equipped with an altimeter that provides the pilot with a constant digital 

display of altitude. Moreover, the UA V 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 not believe an exemption from 14 C.P.R. 91.121 is required. 

In support of Firestorm's request for an exemption from 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 of the UAV. 

UA V and UAS Operator Qualifications and Training 

In support of Firestorm'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 of safety 

is achieved by the UA V -specific experience of its Pilots. Each Firestorm pilot will receive a 

commercial UAS training course and then receive flight training using the DJI Inspire 1 UAS, or 

will hold a commercial pilot certificate with the class III medical certification. 
Firestorm Emergency Services Ltd. Petition for Exemption 

April 6, 2015 

Page 6 

The FAA has exemption authority under section 44701(t) to exempt UAV operators from the 

particular requirements of Parts 61 and 67 - such as the requirement to conduct flight training on 

board an aircraft - and develop airman certification requirements specifically designed for small 

UAV operations. Applying manned aircraft pilot certification requirements to small UAVs is not 

necessary as a matter of safety, and does not make sense as a matter of public policy. 

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 of its 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, 

culminating in verification through testing. 

Firestorm believes this reasoning supports a UAV/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 

UA V and the particular nature of UAS operations. 

Firestorm notes that the FAA has proposed in its recent SUAS Notice of Proposed Rulemaking 

that a small UAS pilot would be required to successfully complete an aeronautical knowledge 

test and receive an unmanned aircraft operator permit with small UAS rating, but would not be 

required to obtain a commercial or private pilot certificate. Also, medical certification would be 

obviated by a pilot's self-certification before flight that the pilot is physically and mentally fit to 

operate the UAS. 

Accordingly, the FAA should grant appropriate exemption relief to permit Firestorm to use pilots 

who have successfully completed commercial UAS training and have also gained flying 

experience using the DJI Inspire 1 UAV. 

UA V and UAS Operating Parameters 

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 of sight of the 

pilot in command, in a tightly circumscribed area of a single parcel of property, with the consent 
Firestorm Emergency Services Ltd. Petition for Exemption 

April 6, 2015 

Page 7 

of the property owner and/or developer. Although the UA V may be operated in a metropolitan 

area, it will be flown below 400 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 UA V will be 

flown. Firestorm will provide notice to persons residing or working in any adjacent buildings 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 lighting visible for 3 miles. Accordingly, 

we do not believe an exemption from 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 or congested, and not closer than 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 UA V in a metropolitan area, the operations 

will not be operated over a congested area or open air assembly of persons. Combined with the 

technological capabilities of the UA V and that the UA V will be operated within the visual line of 

sight of the pilot and an observer, Firestorm submits that its operational limitations provide an 

equivalent level of safety to that provided 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 can be located 

and observed with little or no interactions/risk to the animal that is being tracked or the biologist. 

The critical element is the speed to recovery that mitigates damage both bodily and financial. 
Firestorm Emergency 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 

than with manned helicopters. 

Operations limited to the United States 

Firestorm does not intend to operate its UA V outside of the United States. 

Summary for Federal Register 

Firestorm submits the following summary to be included in the Federal Register, should the FAA 

determine that publication of a summary is required. 

Firestorm seeks an exemption to operate the DJI 1000+ with TigerStrike® technology to 

perform commercial and emergency services. 

Because granting this petition would not set a precedent, and indeed would be consistent with the 

terms and conditions of previous exemptions, Firestorm respectfully requests the FAA dispense 

with Federal Register publication and public comment. 

Sincerely, 

Craig, Firestorm Emergency Services Ltd. 

Proprietary Documents provided to FAA separately 

Pilot Operating Handbook for DJI SlOOO (Troy Built) 

DJI Spreading Wings SlOOO User Manual Vl.lO 

A2 Flight Control User Manual