-· 

DAS 800 UNMANNED AIRCRAFT SYSTEM 

PURSUANT TO SECTION 333 OF 

THE FAA MODERNIZATION AND REFORM ACT OF 2012 (PUBLIC LAW 112-95) 

Submitted on October 9, 2015 

Michael A. Klumpp 

Nickolas C. Houghton 

Detailed Aerial Solutions, LLC 

1955 E Walton Rd. 

Shepherd, MI 48883 

Tel: (989) 312-3556 

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TABLE OF CONTENTS 

,., GLOSSARY OF ABBREVIATIONS ................................................................................. -' 

SUMMARY ......................................................................................................................... 4 

INTRODUCTION AND INTERESTS OF PETITIONER ................................................ .4 

BACKGROUND ................................................................................................................. 4 

BASIS FOR PETITION ...................................................................................................... 5 

NAME AND ADDRESS OF PETITIONER ...................................................................... 6 

THE SPECIFIC SECTIONS OF 14 C.F.R. FROM WHICH DETAILED AERIAL SOLUTIONS, 

LLC SEEKS EXEMPTION ......................................... : ...................................................... 6 

THE EXTENT OF RELIEF DETAILED AERIAL SOLUTIONS, LLC SEEKS AND THE 

REASON DAS SEEKS THE RELIEF ............................................................................... & 

THE REASONS WHY GRANTING DETAILED AERIAL SOLUTIONS, LLC REQUEST 

WOULD BE IN THE PUBLIC INTEREST ...................................................................... ! 0 

THE REASONS WHY GRANTING THE EXEMPTION WOULD NOT ADVERSELY AFFECT 

SAFETY ............................................................................................................................. !! 

SUMMARY THAT CAN BE PUBLISHED IN THE FEDERAL REGISTER .................. l2 

CONCLUSION ................................................................................................................... 24 

2 
GLOSSARY OF ABBREVIATIONS 

AGL Above Ground Level 

AOI Area of Interest 

A TC Air Traffic Control 

ATO Air Traffic Organization 

AV Aerial Vehicle 

C.F .R. Code of Federal Regulations 

COA Certificate of Authorization 

FAA Federal Aviation Administration 

FAR Federal Aviation Regulation 

GCS Ground Control Station 

GPS Global Positioning System 

LOL Loss of Link 

NAS National Airspace System 

NOT AM Notice to Airman 

PIC Pilot In Command 

Section 333 FAA Modernization and Reform Act of2012 (FMRA) Section 333 

SOP Standard Operating Procedures 

UA Unmanned Aircraft 

UAS Unmanned Aircraft System 

VFR Visual Flight Rules 

VLOS Visual Line of Site 

VMC Visual Meteorological Conditions 

YO Visual Observer 

VTOL Vertical Takeoff and Landing 4 

3 
SUMMARY 

Detailed Aerial Solutions, LLC seeks exemption from the requirements of 14 C.F.R §§ 61.113(a) & 

(b), 91.7(a), 91.121, 91.15l(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b), 

to operate an Unmanned Aircraft System pursuant to Section 333 ofthe FAA Modernization and 

Reform Act of 2012 (FMRA). This exemption will permit Detailed Aerial Solutions to operate an 

Unmanned Aircraft System (UAS) for the commercial purpose of conducting aerial acquisitions and 

research over certain rural areas of the United States. 

INTRODUCTION AND INTERESTS OF THE PETITIONER 

Detailed Aerial Solutions, LLC (hereinafter referred to as "DAS") is an unmanned aircraft solutions 

provider that integrates engineering and manufacturing with services that enable the technology for 

federal, state, local, and commercial clients. DAS is focused on providing solutions for utilizing 

unmanned aircraft to safely and efficiently collect data that is precise, accurate, and timely. 

DAS's mission is to use unmanned aircraft to simplify and increase the effectiveness of data 

collection in: Natural Resources and Conservation, Construction and Infrastructure, Precision 

Agriculture, as well as Inspection and Monitoring. 

As set forth in this Petition, DAS seeks to commercially operate its DAS 800 UAS over certain rural 

areas of the United States for the purpose of conducting aerial acquisitions and research. 

BACKGROUND 

Unmanned Aircraft System: DAS 800 

DAS seeks an exemption to operate the DAS 800 UAS for compensation or hire within the National 

Airspace System ("NAS"). The DAS UAS is comprised of a vertical takeoff and landing (VTOL) 

Unmanned Aircraft (UA) and a transportable Ground Control Station (GCS). The DAS 800 has a 

maximum gross weight of approximately 8.1 pounds, while having a rotorspan of20.1 inches, and 

maximum speed of 16 mph. The DAS 8000 is equipped with eight propellers, each being driven by a 

Lithium Polymer battery powered electric motor. 

The DAS 800 that will be operated by DAS will be registered in accordance with 49 U.S.C. 44103, 

Registration of Aircraft, as well as 14 C.F.R Part 47, Aircraft Registration, and marked in accordance 

with 14 C.F.R. Part 45, Identification and Registration Marking. 

Figure 1: The DAS 800. 

4 
BASIS FOR PETITION 

Petitioner, Detailed Aerial Solutions, LLC., by and through undersigned counsel, pursuant to the 

provisions ofthe Federal Aviation Regulations (14 C.F.R. § 11.61) and the FAA Modernization and 

Reform 6 Act of2012, Section 333, Special Rules for Certain Unmanned Aircraft Systems, hereby 

petitions the Administrator to operate the DAS UAS in the NAS, and for an exemption from the 

requirements of 14 C.F .R §§ 61.113(a) & (b), 91. 7(a), 91.121, 91.151 (b), 91.405(a), 91.407(a)( I), 

91.409(a)(l) & (a)(2), and 91.417(a) & (b). 

In consideration of the size, weight, speed, and limited operating area associated with the unmanned 

aircraft and its operation, DAS's operation ofthe DAS 800 UAS meets the conditions of Section 333 

and therefore, will not require an airworthiness certificate in accordance with 14 C.F.R. Part 21, 

Subpart H. 

Accordingly, DAS requests relief from Sections 91.405(a), 91.407(a)( 1 ), 91.409(a)( I) & (a)(2), and 

91.417(a) & (b), as these sections set forth requirements for maintenance that only apply to aircraft 

with an airworthiness certificate. 

DAS submits that the requested relief is proper since an equivalent level of safety will be ensured. 

DAS, as manufacturer of the DAS 800 UAS, will use its technicians to perform maintenance, 

alterations, or preventive maintenance on the UAS using the methods, techniques, and practices 

prescribed in the manufacturer's maintenance manual. Furthermore, DAS will document and 

maintain all maintenance records for the DAS 800 UAS. 

Relief from certain requirements of Section 61.113(a) and (b), entitled Private pilot privileges and 

limitations: Pilot in command, is requested by DAS to the extent necessary to allow a Pilot in 

Command (PIC) holding a private pilot certificate and a third-class airman medical certificate, and 

who has completed the DAS 800 training and currency requirements, to conduct the proposed UAS 

operations. DAS submits that the conditions and limitations set forth herein will ensure the safety of 

the NAS, as well as the safety of persons or property on the ground. 

DAS seeks relief from Section 91. 7(a), entitled Civil aircraft ainvorthiness, because the DAS 800 

UAS does not require an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H. 

As such, DAS submits that it will ensure that the DAS 800 UAS is in an airworthy condition, prior to 

every flight, by determining that the UAS is in compliance with the DAS 800 UAS Operator Manual, 

the DAS of Systems Operations Manual, and the DAS 800 Maintenance Manual, and that the UA is 

in condition for safe flight. 

DAS also seeks an exemption from the requirements of Section 91.121, entitled Altimeter Settings, as 

the DAS 800 is equipped with a barometer and Global Positioning System (GPS) equipment, which 

ensures that a ground level pressure setting will be established prior to each flight. DAS's barometer 

and GPS equipment ensure safety by providing the PIC with adequate information concerning 

altitude of the UAS, above ground level (AGL), as shown on the heads-up display of the GCS. 

Additionally, DAS seeks an exemption from the requirements of Section 91.151 (b), Fuel 

requirements for flight in VFR conditions. DAS submits that safety will not be affected by 

terminating flights of the battery powered DAS 800 after 15 minutes of continuous flight, which 

would allow for three minutes (i.e, 20 percent) of battery power remaining. 

5 
In accordance with 14 C.F .R. § 11.81, DAS provides the following information in support of its 

petition for exemption: 

A. Name And Address Of The Petitioner. 

The name and address of the Petitioner is: 

Detailed Aerial Solutions, LLC 

1955 E Walton Rd 

Shepherd, Ml 48883 

The point of contact for this Petition and specific contact information is as follows: 

Michael Alan Klumpp and Nickolas C. Houghton 

Detailed Aerial Solutions, LLC 

1955 E Walton Rd. 

Shepherd, Ml 48883 

Tel: (989) 312-3556) 

Email: mike@detailedaerialsolutions.com and nick@detailedaerialsolutions.com 

B. The Specific Sections Of 14 C.F.R. From Which DAS Seeks Exemption. 

1. DAS Seeks Exemption From The Requirements Of Section 61.113(a) And (b). 

Section 61.113, entitled Private pilot privileges and limitations: Pilot in command, subsections (a) 

and (b) prescribe the following, in part: 

(a) No person who holds a private pilot certificate may act as a pilot in command 

(PIC) of an aircraft that is carrying passengers or property for compensation or 

hire; nor may that person, for compensation or hire, act as PIC of an aircraft. 

(b) A private pilot may, for compensation or hire, act as PIC of an aircraft in 

connection with any business or employment 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. 

2. DAS Seeks Exemption From The Requirements Of Section 91.7(a). 

Section 91. 7, entitled Civil aircraft airworthiness, subsection (a), states the following: 

(a) No person may operate a civil aircraft unless it is in an airworthy condition. 

3. DAS Seeks Exemption From The Requirements Of Section 91.121. 

Section 91.121, entitled Altimeter settings, subsection (a), states the following, in relevant part: 

(a) Each person operating an aircraft shall maintain the cruising altitude or flight level ofthat 

aircraft, as the case may be, by reference to an altimeter that is set, when operating-- (I) 

Below 18,000 feet MSL, to-

(i) The current reported altimeter setting of a station along the route and within I 00 

nautical miles ofthe aircraft; 

(ii) lfthere is no station within the area prescribed in paragraph (a)(l)(i) ofthis 

section, the current reported altimeter setting of an appropriate available station; or 

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(iii) In the case of an aircraft not equipped with a radio, the elevation of the departure 

airport or an appropriate altimeter setting available before departure; 

4. DAS Seeks Exemption From The Requirements Of Section 91.151(b). 

Section 91.151, entitled Fuel requirements for flight in VFR conditions, subsection (b), states the 

following: 

(b) No person may begin a flight in a rotorcraft 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, to fly after that for at least 20 

minutes. 

5. DAS Seeks Exemption From The Requirement Of Section 91.405(a). 

Section 91.405, entitled Maintenance required, subsection (a), states the following: 

Each owner or operator of an aircraft-

( a) Shall have that aircraft inspected as prescribed in subpart E of this part and shall between 

required inspections, except as provided in paragraph (c) of this section, have 

discrepancies repaired as prescribed in part 43 of this chapter[.) 

6. DAS Seeks Exemption From The Requirements Of Section 91.407(a)(1). 

Section 91.407, entitled Operation after maintenance, preventive maintenance, rebuilding, or 

alteration, subsection (a)( 1 ), states the following: 

(a) No person may operate any aircraft that has undergone maintenance, preventive 

maintenance, rebuilding, or alteration unless--

(1) It has been approved for return to service by a person authorized under§ 43.7 of 

this chapter[.) 

7. DAS Seeks Exemption From The Requirements Of Sections 91.409(a)(l) And 91.409(a)(2). 

Section 91.409, entitled Inspections, subsection (a), states the following: 

(a) Except as provided in paragraph (c) of this section, no person may operate an aircraft 

unless, within the preceding 12 calendar months, it has had--

(1) An annual inspection in accordance with part 43 of this chapter and has been 

approved for return to service by a person authorized by§ 43.7 ofthis chapter; or 

(2) An inspection for the issuance of an airworthiness certificate in accordance with 

part 21 of this chapter. 

8. DAS Seeks Exemption From The Requirements Of Sections 91.417(a) And 91.417(b). 

Section 91.417, entitled Maintenance records, subsections (a) and (b), state the following: 

(a) Except for work performed in accordance with §§ 91.411 and 91.413, each registered 

owner or operator shall keep the following records for the periods specified in paragraph 

(b) ofthis section: 

(1) Records ofthe maintenance, preventive maintenance, and alteration and records 

of the 1 00-hour, annual, progressive, and other required or approved inspections, as 

appropriate, for each aircraft (including the airframe) and each engine, propeller, 

rotor, and appliance of an aircraft. The records must include--

(i) A description (or reference to data acceptable to the Administrator) of the 

work performed; and 

7 
(ii) The date of completion ofthe work performed; and 

(iii) The signature, and certificate number of the person approving the aircraft 

for return to service. 

(2) Records containing the following information: 

(i) The total time in service ofthe airframe, each engine, each propeller, and 

each rotor. 

(ii) The current status of life-limited parts of each airframe, engine, propeller, 

rotor, and appliance. 

(iii) The time since last overhaul of all items installed on the aircraft which 

are required to be overhauled on a specified time basis. 

(iv) The current inspection status of the aircraft, including the time since the 

last inspection required by the inspection program under which the aircraft 

and its appliances are maintained. 

(v) The current status of applicable airworthiness directives (AD) and safety 

directives including, for each, the method of compliance, the AD or safety 

directive number and revision date. If the AD or safety directive involves 

recurring action, the time and date when the next action is required. 

(vi) Copies of the forms prescribed by§ 43.9(d) of this chapter for each major 

alteration to the airframe and currently installed engines, rotors, propellers, 

and appliances. 

(b) The owner or operator shall retain the following records for the periods prescribed: 

(1) The records specified in paragraph (a)(l) ofthis section shall be retained until the 

work is repeated or superseded by other work or for I year after the work is 

performed. 

(2) The records specified in paragraph (a)(2) ofthis section shall be retained and 

transferred with the aircraft at the time the aircraft is sold. 

(3) A list of defects furnished to a registered owner or operator under§ 43.11 of this 

chapter shall be retained until the defects are repaired and the aircraft is approved for 

return to service. 

C. The Extent OfReliefDAS Seeks And The Reason DAS Seeks The Relief. 

1. Extent of Relief DAS Seeks And The Reason DAS Seeks Relief From Section 61.113(a) And 

(b). 

Relief from Section 61.113(a) and (b), entitled Private pilot privileges and limitations: Pilot in 

command, is requested to the extent necessary to allow a PIC holding a private pilot certificate and a 

third-class airman medical certificate, and who has completed the DAS 800 UAS training and 

currency requirements, to conduct the proposed UAS flight operations for compensation. 

This relief is requested since the limitations set forth in Section 61.113(a) and (b) state that a private 

pilot may, for compensation or hire, act as PIC of an aircraft in connection with any business or 

employment if (I) The flight is only incidental to that business or employment; and (2) The aircraft 

does not carry passengers or property for compensation or hire. 

As set forth more fully below, DAS submits that an equivalent level of safety will be maintained 

because no PIC will be allowed to operate the DAS 800 unless that PIC has demonstrated, through 

the DAS 800 UAS training and currency requirements, that the PIC is able to safely operate the DAS 

800 UAS in a manner consistent with the operations specifications as described in this exemption, 

8 
including evasive and emergency maneuvers, as well as maintaining appropriate distances from 

people, vessels, vehicles and structures. 

Further, DAS submits that all flights of the DAS 800, conducted by the PIC pursuant to the grant of 

this Petition (I) will be incidental to DAS's business; and (2) will not carry passengers or property 

for compensation or hire. 

2. Extent ofReliefDAS Seeks And The Reason DAS Seeks Relief From Section 91.7(a). 

Relief from Section 91.7(a), entitled Civil aircraft ainvorthiness, is requested to the extent required 

to allow DAS to determine that the DAS 8000 UAS is in an airworthy condition prior to every flight 

by ensuring that the UAS is in compliance with the DAS 800 UAS Operator Manual, the DAS 

Family of Systems Operations Manual, and the DAS 800 UAS Maintenance Manual, and that the UA 

is in condition for safe flight. Copies of the manuals, which contain proprietary information, are 

attached hereto as Exhibits A, B, and C, respectively, and are to be held in a separate file pursuant to 

14 C.F.R. § 11.35(b). 

DAS seeks the requested relief because the DAS 800 UAS does not require an airworthiness 

certificate in accordance with 14 C.F.R. Part 21, Subpart H. Therefore, DAS will ensure that the 

DAS 8000 UAS is in an airworthy condition based upon its compliance with the operating 

documents prior to every flight, and as stated in the conditions and limitations below. 

3. Extent ofReliefDAS Seeks And The Reason DAS Seeks Relief From Section 91.121. 

Relief from Section 91.121, entitled Altimeter settings, may be required to allow flight operations of 

the DAS 800 UAS, which utilizes a barometer and GPS equipment, to ensure that a ground level 

pressure setting will be established prior to each flight, in order to report altitude to the PIC. DAS 

seeks the requested relief because the DAS 800 UAS does not utilize a typical barometric altimeter 

onboard that may be set as contemplated by Section 91.121. As more fully set forth below, an 

equivalent level of safety will be maintained since the DAS 800 U AS is equipped with a barometer 

and GPS equipment, which will ensure that a ground level pressure setting will be established prior 

to each flight, and provides the PIC with altitude information of the UA, above ground level (AGL), 

on the heads-up display of the ground control station (GCS). 

4. Extent OfReliefDAS Seeks And The Reason DAS Seeks Relief From Section 91.151(b). 

Relief from Section 91.151 (b), entitled Fuel Requirements for flight in VFR conditions, is requested 

to the extent required to allow flights of the battery powered DAS 800 UAS, during daylight hours in 

visual meteorological conditions under visual flight rules (VFR), to continue for a total duration of 

15 minutes, which will ensure that the UA will land with three minutes (i.e., 20 percent) ofbattery 

power remaining. DAS seeks the requested relief, because without an exemption from Section 

91.151 (b), the flight time duration of the battery powered DAS 800 UAS will severely constrain the 

practicality of any aerial acquisition and research flight operations which DAS proposes to conduct 

pursuant to this Petition. 

Significantly, as set forth below, the technical specifications ofthe DAS 800 UAS, the DAS 

Operations Manual, and DAS's proposed operating limitations, ensure that DAS will safely operate 

the battery powered DAS 800 UAS during daylight hours in VFR conditions for a total flight 

duration of 15 minutes, landing with three minutes (i.e., 20 percent) ofbattery power remaining. 

5. Extent Of Relief DAS Seeks And The Reason DAS Seeks Relief From Sections 91.405(a), 

91.407(a)(l), 91.409(a)(l) & (a)(2), And 91.417(a) & (b). 

9 
Since Sections 91.405(a), 91.407(a)( I), 91.409(a)( I) & (a)(2), and 91.417(a) & (b) only apply to 

aircraft with an airworthiness certificate, DAS requests relief from these Sections because DAS 800 

UAS does not require an airworthiness certificate. As set forth more fully below, the DAS 800 UAS 

meets the conditions of Section 333 of the FMRA for operation without an airworthiness certificate. 

Accordingly, DAS, which manufactures the DAS 800 UAS, will use DAS technicians to perform 

maintenance, alterations, or preventive maintenance on the UAS using the methods, techniques, and 

practices prescribed in the manufacturer's maintenance manual. Furthermore, DAS will document 

and maintain all maintenance records for the DAS 800 UAS. 

D. The Reasons Why Granting DAS's Request Would Be In The Public Interest; That Is, How 

It Would Benefit The Public As A Whole. 

Granting the present Petition will further the public interest by allowing DAS to safely, efficiently, 

and economically perform aerial acquisitions and research over rural areas of the United States, 

commercially, in support of government entities, agriculture, scientific studies, wildlife monitoring, 

forestry operations, and the oil and gas industries. Additionally, use ofthe DAS 800 UAS will 

decrease congestion of the NAS, reduce pollution, and provide significant benefits to the economy. 

Notably, the benefits ofDAS's proposed operation ofthe DAS 800 UAS will be realized without 

implicating any privacy issues. 

1. The Public Will Benefit From The Aerial Acquisition And Research Performed. 

DAS submits this Petition to commercially operate the DAS 800 UAS and perform aerial acquisition 

and research throughout rural areas of the United States, in support of government entities, 

agriculture, scientific studies, wildlife monitoring, forestry operations, mining, and the oil and gas 

industries. The DAS 800 UAS will provide safe, efficient, and economical aerial acquisition and 

research operations to further each ofthese fields, all of which are critical to the well-being ofthe 

general public. 

The specific operations that DAS will perform with the DAS 800 UAS demonstrate how the 

requested exemption will directly benefit the above-referenced industries and the public. In 

agriculture, the aerial acquisition performed by the DAS 800 UAS will be used to predict and 

increase crop yields, as well as research for the prevention of crop disease. In the oil and gas 

industry, the DAS 800 UAS will be used to aid in facility inspections, survey and plan new 

worksites, conduct volumetric analysis, and perform right of way analysis. The DAS 800 UAS will 

also further environmental management by researching invasive species, mapping deforestation, and 

surveying point source pollution. 

2. The Public Will Benefit From Decreased Congestion Of The NAS. 

The DAS 800 UAS is battery powered and serves as a safe, efficient, and economical alternative to 

the manned aircraft traditionally utilized to obtain aerial imagery. By reducing the amount of manned 

aircraft needed to perform aerial acquisitions, an exemption allowing the use of a DAS 800 UAS 

would reduce the amount of manned aircraft in the NAS, reduce noise and air pollution, as well as 

increase the safety of life and property in the air and on the ground. 

Furthermore, by reducing the number of manned aircraft operating in the NAS, congestion around 

airports caused by arriving and departing aircraft will be reduced. The DAS 800 UAS does not 

require an airport to takeoff or land. Likewise, a reduction of manned aircraft conducting aerial 

survey missions would result in fewer aircraft that must be handled by air traffic control during the 

ground, takeoff, departure, arrival, and landing phases of flight operations. 

10 
3. The Public Will Benefit From The Safety And Efficiency Of THE DAS 800 UAS. 

Conducting aerial acquisitions with the DAS 800 UAS, instead of manned aircraft, will greatly 

benefit the public by drastically reducing the levels of air and noise pollution generated during 

traditional aerial survey flight operations. By using battery power and electric motors, the DAS 800 

UAS produces no air pollution, and is the most viable environmentally conscious alternative to the 

cabin class, six cylinder internal combustion twin engine aircraft that are typically utilized for aerial 

acquisitions, while burning approximately 20-30 gallons per hour of leaded aviation fuel. DAS 800 

UAS, while reducing the carbon footprint of aerial acquisitions, also reduces noise pollution, as the 

UA is propelled by battery powered electric motors, rather than an internal combustion engine. 

By using the DAS 800 UAS to perform aerial acquisitions, the substantial risk to life and property in 

the air and on the ground, which is usually associated with traditional manned aircraft flight 

operations, will be substantially reduced or completely eliminated. Aside from the lack of flight crew 

members located onboard the aircraft, the DAS 800 UAS (weighing approximately 8.1 pounds at its 

maximum gross weight with a rotorspan of 20.1 inches, and with no fuel on board), has less physical 

potential for collateral damage to life and property on the ground, and in the air, compared to the 

manned aircraft that typically conduct aerial acquisitions (weighing approximately 6,500 pounds 

with a wingspan of approximately 40 feet, a length of 34 feet, and a fuel capacity of 180 gallons). 

4. Performing Aerial Acquisition Operations With The DAS 800 UAS Will Benefit The 

Economy. 

In addition to being safe and efficient, the DAS 800 UAS is also an economical alternative to using 

manned aircraft to conduct aerial acquisitions. As such, operation of the DAS 800 UAS will allow 

United States based companies, like DAS, to remain competitive and contribute to growth ofthe U.S. 

economy. Specifically, with the rising cost of aviation fuel and the Environmental Protection Agency 

("EPA") regulatory actions phasing out leaded aviation fuels, U.S. owned and operated companies 

must adopt new and alternative technology in order to remain competitive. Operating the battery 

powered DAS 800 UAS is one such technology that not only allows companies greater operational 

flexibility compared to manned aircraft, but provides such flexibility without the high operational 

cost of a traditional manned aircraft. 

By operating the DAS 800 UAS companies such as DAS can remain competitive and profitable, and 

therefore, provide greater job stability to employees and contractors, which will ultimately contribute 

to growth ofthe U.S. economy. Improved financial performance of U.S. companies, through 

commercial use of the DAS 800 UAS, provides a stable workforce that increases consumer spending; 

improves local, state, and federal tax revenues; and allows companies to invest in research and 

development in order to remain competitive both in the United States and abroad. 

5. There Are No Privacy Issues. 

Similar to the manned aerial acquisition flight operations that have been conducted for decades, 

DAS's proposed operation ofthe DAS 800 UAS will not implicate any privacy issues. Specifically, 

the DAS 800 UAS will be operated only in rural areas, and in accordance with all Federal Aviation 

Regulations, including the minimum altitude requirements of 14 C.F.R. § 91.119. Most significantly, 

the DAS 8000 UAS will not be operated closer than 500 feet to any person, vessel, vehicle, or 

structure, which is not directly involved in the operation. 

E. The Reasons Why Granting The Exemption Would Not Adversely Affect Safety, Or How 

The Exemption Would Provide A Level Of Safety At Least Equal To That Provided By The 

Rule From Which DAS Seeks Exemption. 

11 
1. Reasons Why The DAS 800 UAS Meets The Conditions Of The FAA Modernization and 

Reform Act of 2012 (FMRA) Section 333. 

In consideration of the size, weight, speed, and limited operating area associated with the unmanned 

aircraft and its operation, DAS's operation of the DAS 800 UAS meets the conditions of FMRA 

Section 333, and will not require an airworthiness certificate in accordance with 14 C.F .R. Part 21, 

Subpart H. 

Section 333 provides authority for a UAS to operate without airworthiness certification and sets forth 

requirements for considering whether a UAS will create a hazard to users of the NAS or the public, 

or otherwise pose a threat to national security. Specifically, FMRA Section 333 states the following, 

in part: 

(a) In General.--Notwithstanding any other requirement of this subtitle, and not later than 

180 days after the date of enactment of this Act, the Secretary of Transportation shall 

determine if certain unmanned aircraft systems may operate safely in the national airspace 

system before completion of the plan and rulemaking required by section 332 of this Act or 

the guidance required by section 334 of this Act. 

(b) Assessment of Unmanned Aircraft Systems.--ln making the determination under 

subsection (a), the Secretary shall determine, at a minimum--

(1) which types of unmanned aircraft systems, if any, as a result of their size, weight, 

speed, operational capability, proximity to airports and populated areas, and 

operation within visual line of sight do not create a hazard to users of the national 

airspace system or the public or pose a threat to national security; and 

(2) whether a certificate of waiver, certificate of authorization, or ainvorthiness 

certification under section 44704 of title 49, United States Code, is required for the 

operation of unmanned aircraft systems identified under paragraph (1 ). 

(b) Requirements for Safe Operation.--!fthe Secretary determines under this section that 

certain unmanned aircraft systems may operate safely in the national airspace system, 

the Secretary shall establish requirements for the safe operation of such aircraft systems 

in the national airspace system. 

In seeking this exemption, DAS submits that the DAS 800 UAS can operate safely in the NAS 

pursuant to FMRA Section 333, as demonstrated by: (a) the characteristics of the DAS 800 UAS; (b) 

the pilot certification requirement; and (c) the specific operating limitations. 

a. The Specifications Of The DAS 800 UAS Demonstrate Its Safe Characteristics. 

The DAS 800 UAS does not create a hazard to users of the NAS or the public, or otherwise pose a 

threat to national security considering its size, weight, speed, and operational capability: 

i.Technical Specifications Of DAS 800 

UAS. 

Unmanned Aircraft System 

Unmanned Aircraft Dimensions 

The DAS 800 UAS is an Unmanned Aircraft 

System that is comprised of vertical takeoff 

and landing (VTOL) unmanned aircraft and a 

transportable ground control station. 

Rotorspan: 20.1 inches 

12 
Engine 

(Propulsive Unit) 

Fuel 

Engine (Propulsive Unit) Limits 

Propeller and 

Propeller Limits 

Engine (Propulsive Unit) 

(8) SunnySky V2216-12 kV II (Electric) 

fAA Engine Type Cert: None 

Propulsive Unit Type: 16.8V, 22 Amp Hour 

capacity, Lithium ion battery powered, direct 

drive electric motor 

Motor, Electric Sub-Assembly: 

Manufacturer: SunnySky 

Model: V2216-12 

Battery: 

Manufacturer: MultiStar 

Type: l(one) x Lithium Ion 

I 0 Amp hour each 

16.8V (nominal) 

Not Applicable. 

NOTE: The DAS 800 is powered by a 

Lithium Polymer rechargeable battery, DAS 

PIN 30142. 

Maximum Power Output: 1.6 HP 

Maximum RPM: 8,316 RPM 

Maximum Motor Temperature: 170 °f (77 

oq 

NOTE: The motor temperature is not 

displayed to the operator. 

Maximum motor, controller sub-assembly 

temperature: 194 Of (90 °C) 

Power On (Engine and Rotor Tach, neither 

visible to operator) 

Maximum 8316 RPM 

Minimum 3742 RPM 

(4) DAS. PIN 30490 

fAA Propeller Type Certificate: None 

Propeller Type: 2-blade, plastic, fixed pitch, 

tractor 

Propeller Sub-Assembly: 

Manufacturer: APC Propeller 

Model: CAM 16x5.5MPR 

Diameter (Nominal): 16 in. 

(4) DAS PIN 30488 

fAA Propeller Type Certificate: None 

Propeller Type: 2-blade, plastic, fixed pitch, 

tractor 

Propeller Sub-Assembly: 

Manufacturer: APC Propeller 

13 
Battery Command & Control 

Airspeed Limits 

Empty Weight C.G. Range 

Datum 

Maximum Weights 

Empty Weight 

Frequencies 

Computer Software 

Minimum Crew 

Number of Seats 

Fuel Capacity 

Oil Capacity 

Model: CAM 16x5.5MR 

Diameter (Nominal): 16 in. 

I (one) DAS Air Vehicle Batteries PIN 30142 

power the motors, and battery command and 

control. 

V ne (Never Exceed Speed) 14.5 knots (7 .5 

m/s) 

-I to 1 inches of datum 

Centroid of Vehicle 

Ramp 8.4 lbs. 

Takeoff 8.4 lbs. 

Landing 21.4 lbs. 

7.7lbs. 

NOTE: Empty Weight Excludes weight of 

batteries and payload modules. 

902-928 MHz (ISM Band) 

2.4 GHz (ISM Band) 

NOTE: FCC license is not required to utilize 

the above frequencies; uplink and downlink 

are on the 900Mhz band. If video is utilized, 

uplink, downlink, and video are all on 2.4 

Ghz. 

Avionics embedded processor, PIN 30306 

(I) The DAS 800 can be operated by a single 

operator. 

(0) Not Applicable. 

Not Applicable. 

Not Applicable. 

14 
Max. Operating Altitude 

Rotor Blade and Control Movements 

Nominal Endurance 

Ambient Outside Air 

Temperature (OAT) 

Wind Limitation 

Maintenance 

I ,200ft. AGL 

Fixed Rotor Control. Vehicle control is 

achieved through varying thrust of each motor 

individually 

25 minutes above 32 °F (0 °C) 

12 minutes below 32 °F (0 °C) 

Maximum OAT: 120 °F (49 °C) 

Minimum OAT At Altitude: -20 °F (-29 °C) 

9.7 knots 

This DAS 800 UAS must be maintained in 

accordance with the manufacturer's 

maintenance manual, or later FAA accepted 

revision. 

ii. The DAS 800 Autonomous Flight And Navigation Modes Enable The UAS To Remain 

Within A Defined Operational Area. 

A complete description ofthe autonomous modes and methods of navigation for the DAS 800 is 

provided in the DAS 800 Operator Manual. 

3. A copy of the DAS 800 Operator Manual, which contains proprietary information, is attached 

hereto as Exhibit A, and is to be held in a separate file pursuant to 14 C.F.R. § 11.35 

(b) I . I Exhibits to this Petition contain proprietary infonnarion. and in accordance "ith 14 C.F.R. § I 1.35(b), are not to be included in the Federal Docket Management System 

(FDMS). 

iii. The DAS 800 Is Designed For Complete Autonomy From Launch To Landing Even In The 

Unlikely Event Of Loss Of The Control Link Or Navigation. 

Although a degradation or loss of the control link, and/or degradation or loss of the source of 

navigation is unlikely, it is a situation that is well planned for and therefore, is a benign event. The 

DAS 800 is designed for complete autonomy from launch to landing with a line of sight operator in 

the loop monitoring the airframe. 

The DAS 800 uses a two-stage failsafe approach for all avionics failure conditions, including the 

event of a loss of communications ("Lost Link"). Upon loss of the communication signal, the DAS 

800 will attempt to reacquire the link. If after I 0 seconds the link has not been reacquired, the DAS 

800 will continue to attempt to reacquire the link while maintaining the current altitude and 

navigating to the home waypoint, which is the same as the location of the ground control station. 

Once at the home waypoint, the DAS 800 will hover while continuing its attempt to reacquire the 

link for 30 seconds (to allow for rebooting ofthe ground control station, if needed). The DAS 800 

will then continue to attempt to re-acquire the link while it navigates through the landing procedure. 

The landing procedure for Lost Link is identical to a normal landing procedure. The DAS 800 will 

enter into a hover-land procedure; descending while reducing speed until contact with the ground. 

During this decent and touchdown, the DAS 800 will remain in controlled flight. 

15 
Loss ofGPS signal will result in a two-tiered recovery approach. Upon loss of a GPS signal, the 

DAS 800 will immediately hover in an attempt to reacquire a signal. If after 15 seconds, a GPS 

signal is not reacquired, the UA will enter tier-two recovery. At any time during either tier-one or 

tier-two recovery, the operator can take over with augmented control and utilize its onboard 

magnetometer to navigate back to the home waypoint through dead-reckoning. During this failure 

mode, the observer will call out UA position and movement back to the operator. Once the UA is 

close enough to resolve orientation, or if operating with a live video payload, the operator can engage 

manual control and perform a manual landing at the pre-decided landing site. 

If a cascade of failures has occurred and Lost-Link has also occurred during tier-two recovery, the 

DAS 800 will enter into a hover-land procedure; descending while reducing speed until contacting 

the ground. Throughout this decent and touchdown, the DAS 800 will remain in controlled flight. 

The DAS 800 Operator Manual at Chapter 8 "Emergency Procedures" fully describes the features of 

the DAS 800, and sets forth the UA 's operation in the event of a power loss, loss of communications, 

loss ofGPS signal, loss of video link, or software crash. A copy ofDAS 800 Operator Manual, 

which contains proprietary information, is attached hereto as Exhibit A, and is to be held in a 

separate file pursuant to 14 C.F.R. § 11.35(b). 

iv. The DAS 800 Ground Control Station And Its Operation. 

The DAS 800 Ground Control Station is identical to the GCS utilized by the DAS UAS, which has 

been granted exemptions to operate commercially in the NAS. See Exemption Nos. IIIII and 

11114. A complete description ofthe operation and specifications ofthe ground control station 

(GCS) and flight control software for the DAS 800 is provided in the DAS 800 Operator Manual. A 

complete overview of the features and operation of the GCS software is also provided. A copy of the 

DAS 800 Operator Manual, which contains proprietary information, is attached hereto as Exhibit A, 

and is to be held in a separate file pursuant to 14 C.F.R. § 11.35(b). 

v. Safe Mobile Operation Of The DAS 800. 

The DAS 800 may be safely operated by a Pilot-in-Command (PIC) and safety observer co-located 

with a GCS on a mobile vehicle, in order to efficiently perform aerial acquisition operations of large 

areas. As set forth in the DAS Family of Systems Operations Manual, additional limitations and 

requirements apply to mobile operations of the DAS 800, including the following: 

The driver/operator of the mobile vehicle must be licensed and fully understand his/her role in the 

operation. 

The mobile vehicle must be organized and clear of any unnecessary debris prior to the operation. 

Equipment and personnel positioning within the vehicle must be predetermined and agreed upon by 

the team. Each team member must use appropriate safety restraint equipment, and such equipment 

should not interfere with safe flight. 

The PIC must have ready communication with the driver/operator of the mobile vehicle, as well as 

the safety observer. 

GCS software must be configured for constant updating ofGCS position on the map overlay, and the 

PIC must be kept aware of mobile vehicle position. The GCS must be mounted or fixed to the mobile 

vehicle to ensure that no excess movement will shift the GCS during operations. 

16 
The route of the mobile vehicle must be determined prior to operation. The PIC must ensure that no 

part of the route will obscure the safety observer's view or cause any physical obstacles or 

obstructions to any member of the flight team. 

The Area of Interest (AOI) must be large enough to warrant mobile operations, and the UA cannot be 

allowed to exit the AOI under any circumstance. The only change to the standard operating 

procedures (SOP's) with mobile operations must be an update ofthe LOL (Loss of Link) site. Mobile 

operations are only permitted if suitable LOL sites are within 500ft. of the PIC at all times. 

A copy of the DAS Family of Systems Operations Manual, which contains proprietary information, 

is attached hereto as Exhibit B, and is to be held in a separate file pursuant to 14 C.F.R. § I I .35(b). 

b. Flight Operations Of The DAS 800 Are Limited To The Line Of Sight Of A Certificated 

Pilot in Command With A Safety Observer. 

DAS will only utilize certificated pilots who possess a valid airman medical certificate to act as a 

pilot in command (PIC) of the DAS 800. Additionally, a safety observer will assist all pilots. Both 

the PIC and safety observer must complete the DAS Operators Course and meet the experience 

requirements as set forth in the DAS Family of Systems Operations Manual. A copy of the DAS 

Family of Systems Operations Manual, which contains proprietary information, is attached hereto as 

Exhibit B, and is to be held in a separate file pursuant to 14 C.F.R. § 11.35(b). 

c. Flights Of The DAS 800 Will Be Conducted Pursuant To Specific Operating Limitations. 

In seeking this exemption, DAS proposes to commercially operate the DAS 800 for the special 

purpose of conducting aerial acquisitions over rural areas of the United States, pursuant to the 

following specific operating limitations: 

I) Operations authorized by the grant of exemption will be limited to the following aircraft 

described in the operating documents, which is an eight-rotor, vertical takeoff and landing, 

unmanned aircraft weighing less than 15 pounds (maximum weight: 8.4 pounds): DAS 800. 

Proposed operations of any other aircraft will require a new petition or a petition to amend 

the grant. 

2) The DAS 800 may not be flown at an indicated airspeed exceeding 14.5 knots. 

3) The DAS 800 must be operated at an altitude of no more than 1,200 feet above ground 

level (AGL). All altitudes reported to ATC must be in feet. 

4) The DAS 800 must be operated within visual line of sight (VLOS) of the Pilot in 

Command (PIC) at all times. This requires the PlC 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. 

5) All operations must utilize a Visual Observer (YO). The YO may be used to satisfy the 

VLOS requirement, as long as the PIC always maintains VLOS capability. The YO and PIC 

must be able to communicate verbally at all times. The PIC must be designated before the 

flight and cannot transfer his or her designation for the duration of the flight. The PIC must 

ensure that the YO can perform the functions prescribed in the operating documents. 

6) The operating documents and the grant of exemption must be maintained and made 

available to the Administrator upon request. If a discrepancy exists between the conditions 

and limitations in the 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 operator must follow the procedures as outlined in its operating documents. 

The operator may update or revise its operating documents. It is the operator's responsibility 

17 
to track such revisions and present updated and revised documents to the Administrator upon 

request. The operator must also present updated and revised documents if_it petitions for 

extension or amendment to the grant of exemption. If the operator determmes that any update 

or revision would affect the basis upon which the FAA granted the exemption, then the 

operator must petition for amendment to its grant of exemption. The FAA's UAS Integration 

Office (AFS-80) may be contacted if questions arise regarding updates or revisions to the 

operating documents. 

7) Prior to each flight, the PIC must inspect the DAS 800 to ensure it is in a condition for safe 

flight. If the inspection reveals a condition that affects the safe operation of the DAS 800, the 

DAS 800 is prohibited from operating until the necessary maintenance has been performed 

and the DAS 800 is found to be in a condition for safe flight. The DAS 800 Ground Control 

Station must be included in the preflight inspection. All maintenance and alterations must be 

properly documented in the aircraft records. 

8) Any DAS 800 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 DAS 

800 aircraft record ofthe flight. 

9) In addition to the pre-flight inspection section in the operating documents, the preflight 

inspection must also account for all discrepancies, i.e. inoperable components, items, or 

equipment, not already covered in the relevant sections of the operating documents. 

I 0) The operator must follow the DAS 800 manufacturer's UAS aircraft/component, 

maintenance, overhaul, replacement, inspection, and life limit requirements. 

II) The operator must carry out its maintenance, inspections, and record keeping 

requirements, in accordance with the operating documents. Maintenance, inspection, and 

alterations must be noted in the aircraft logbook, including total flight hours, description of 

work accomplished, and the signature ofthe authorized DAS 800 maintenance personnel or 

PIC returning the DAS 800 to service. 

12) The operator's DAS 800 authorized maintenance personnel or PIC must make a record 

entry in the UAS logbook or equivalent document of the corrective action taken against 

discrepancies discovered between inspections. 

13) The operator's DAS 800 authorized maintenance personnel, PIC, and YO must receive 

and document training referenced in the operating documents. 

14) The UAS operated under the exemption must comply with all manufacturer System and 

Safety Bulletins. 

15) The PIC must possess at least a FAA-issued private pilot certificate and a valid FAAissued airman medical certificate. The PIC must also meet the flight review requirements 

specified in 14 C.F .R. 61.56 in an aircraft in which the PIC is rated on his or her pilot 

certificate. 

16) Prior to operating for hire, the PIC, and YO must have successfully completed DAS 's 

training syllabus as outlined in the operating documents. In addition, the PIC and YO must 

also have successfully completed annual (recurrent) training in accordance with the operating 

documents. A record of training must be documented and made available upon request by the 

Administrator. Training, proficiency, and experience-building flights for the purpose of 

training pilots and YOs to conduct flights authorized by the exemption are permitted under 

the terms of the exemption. 

17) If the DAS 800 loses communications or loses its GPS signal, it must return to a predetermined location within the planned operating area and land, or be recovered in 

accordance with the operating documents. 

18 
18) The PIC must abort the flight in the event of unpredicted obstacles or emergencies in 

accordance with the operating documents. 

19) The operator must obtain an Air Traffic Organization (A TO) issued Certificate of_ Waiver 

or Authorization (COA) prior to conducting any operations under the grant of exemption. 

This COA will also require the operator to request a Notice to Airman (NOT AM) not more 

than 72 hours in advance, but not less than 48 hours prior to the operation. 

20) The DAS 800 operated in accordance with the exemption must be identified by serial 

number, registered in accordance with 14 C.F.R. Part 47, and have identification (N-Number) 

markings in accordance with 14 C.F.R Part 45, Subpart C. 

21) Before conducting flight operations, the radio frequency spectrum used for operation and 

control of the DAS 800 must comply with the Federal Communications Commission (FCC) 

or other appropriate government oversight agency requirements. 

22) The documents required under 14 C.F.R §§ 91.9 and 91.203 must be available to the PIC 

at the Ground Control Station of the DAS 8000 any time the aircraft is operating. These 

documents must be made available to the Administrator, or any law enforcement official, 

upon request. 

23) The DAS 800 must remain clear and yield the right of way to all other aircraft operations 

and activities at all times. 

24) If the DAS 800 is operated from a moving device or vehicle, the operation must be in 

accordance with the operating documents. 

25) DAS 800 operations may not be conducted during night, as defined in 14 C.F .R. § 1.1. 

26) All operations must be conducted under visual meteorological conditions (VMC). The 

DAS 800 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. 

27) During operations in the National Airspace System, the UA may not operate within 5 

nautical miles of the geographic center of an airport as denoted on a current FAA-published 

aeronautical chart unless a letter of agreement with that airport's management is obtained, 

and the operation is conducted in accordance with a NOT AM as required by the operator's 

COA. The letter of agreement with the airport management must be made available to the 

Administrator upon request. 

28) The DAS 800 may not be operated over congested or densely populated areas. These 

areas include, but are not limited, to the yellow areas depicted on World Aeronautical Charts 

(WAC), Sectional Aeronautical Charts (Sectionals), or Terminal Area Charts (TAC). 

However, aeronautical charts may not reflect pertinent local information. Ultimately, it is the 

PIC's responsibility to maintain the minimum safe altitudes required by 14 C.F.R. § 91.119. 

29) Operation of the DAS 800 must be conducted at least 500 feet from all persons, vessels, 

vehicles, and structures not directly involved in the operation. 

30) Operations of the UA may be conducted at distances less than 500 feet from participating 

persons, vessels, vehicles or structures that perform an essential function in connection with 

the special purpose operations. Operations closer than 500 feet from the 30 PIC, VO, 

operator trainees and essential persons, are permitted when operationally necessary; but never 

so close as to present an undue hazard, per 14 C.F.R. § 91.119(a). 

31) Operations ofthe UA may be conducted at distances less than 500 feet from unoccupied 

vessels, vehicles or structures owned by the land owner/controller when the land 

owner/controller grants such permission and the PIC makes a safety assessment of the risk 

from operations closer to these objects. 

32) All operations shall be conducted with permission from the land owner/controller or 

authorized representative. Permission from land owner/controller or authorized representative 

will be obtained for each flight to be conducted. 

19 
33) Any incident, accident, or flight operation that transgresses the lateral or vertical 

boundaries of the operational area as defined by the applicable COA must be reported to the 

FAA's UAS Integration Office (AFS-80) within 24 hours. Accidents meeting the 

requirements of 49 C.F.R. Part 830 must be reported to the National Transportation Safety 

Board (NTSB) per instructions contained on the NTSB Web site: www.ntsb.gov. 

2. Reasons Why An Exemption From The Requirements Of Section 61.113(a) And (b) Would 

Not Adversely Affect Safety. 

DAS submits that an equivalent level of safety established by Section 61.113(a) and (b) will be 

maintained because no PIC will be allowed to operate the DAS 800 unless that PIC has 

demonstrated, through the DAS 800 training and currency requirements, that the PIC is able to safely 

operate the DAS 800 in a manner consistent with this exemption, including evasive and emergency 

maneuvers and maintaining appropriate distances from people, vessels, vehicles and structures. 

Considering DAS 's proposed area of operations and the operating limitations set forth-above; the 

parallel nature of private pilot aeronautical knowledge requirements to those of commercial pilot 

requirements (See Exemption No. II 062); and the airmanship skills necessary to safely operate the 

DAS 800, DAS submits that the additional manned airmanship experience of a commercially 

certificated pilot would not correlate to the airmanship skills necessary for DAS 's specific proposed 

flight operations. 

Additionally, the FAA has previously granted relief from Section 61.113(a) and (b) specific to UAS, 

in circumstances similar, in all material respects, to those presented herein (e.g. Exemption Nos. 

11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 11112, 11136, 11138). 

As in Exemption No. Ill 09, DAS will not allow any PIC to operate the DAS 800 unless that PIC has 

demonstrated through the DAS 800 training and currency requirements that the PIC is able to safely 

operate the DAS 800 in a manner consistent with this exemption, including evasive and emergency 

maneuvers and maintaining appropriate distances from people, vessels, vehicles and structures. 

A complete description ofthe DAS 800 Training and Qualification requirements is set forth in the 

DAS Family of Systems Operations Manual, attached hereto as Exhibit B. Exhibit B contains 

proprietary information and is to be held in a separate file pursuant to 14 C.F .R. § I 1.35(b ). 

3. Reasons Why An Exemption From The Requirements Of Section 91.7(a) Would Not 

Adversely Affect Safety. 

The level of safety established by Section 91. 7(a) will be maintained because prior to every flight, 

DAS will ensure that the DAS 800 is in an airworthy condition and safe for flight based upon the 

DAS 800's compliance with its operating documents (i.e., the DAS 800 Operator Manual, the DAS 

Family of Systems Operations Manual, and the DAS 800 Maintenance Manual) and as stated in the 

conditions and limitations herein. 

Additionally, the FAA has previously granted relieffrom Section 91.7(a), specific to UAS, in 

circumstances similar, in all material respects, to those presented herein (e.g. Exemption Nos. II 062, 

11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 11112, 11136, 11138). 

4. Reasons Why An Exemption From The Requirements Of Section 91.121 Would Not 

Adversely Affect Safety. 

20 
The equivalent level of safety established by Section 91.121 will be maintained because the DAS 800 

is equipped with a digitally encoded barometric altimeter and GPS triangulation equipment, with a 

zero altitude initiation point being established prior to each flight. As such, the PIC on the DAS 800 

is provided the altitude of the UA above ground level (AGL) via a heads-up display of the ground 

control station (GCS). Specifically, the PIC of the DAS 800 is provided three different types of 

altitude information: 

(I) Desired Altitude, indicating the commanded altitude, located at the top right corner of 

HUD as well as above the HUD; (2) Altitude Above Ground Level (AGL), indicating actual 

altitude relative to height above launch level on the ground, located in the center of the right 

side of the HUD; and (3) Climb Rate, indicating the current rate of climb, located in the 

center of the right side of the HUD. Accordingly, the PIC of the DAS 800 will be provided 

with all ofthe necessary altitude information necessary to maintain safe operation ofthe UA 

in the NAS. The FAA has previously granted relief from Section 91.121 specific to UAS, in 

circumstances similar, in all material respects, to those presented herein (e.g. Exemption Nos. 

11062, 11063, 11064, 11.065, 11066, 11067, 11080, 11109, 11112, 11136, 11138). 

5. Reasons Why An Exemption From The Requirements Of Section 91.151(b) Would Not 

Adversely Affect Safety. 

A grant ofthis exemption would ensure the equivalent level of safety established by 14 C.F.R. 

Section 91.151 (b) because the technical specifications of the DAS 800, the DAS Operations Manual, 

and DAS 's proposed operating limitations will ensure that DAS may safely operate the battery 

powered DAS 800 during daylight hours in VFR conditions for a total flight duration of 15 minutes, 

which will ensure a landing with three minutes (i.e., 20 percent) battery power remaining. 

Furthermore, previous exemptions granted by the FAA concerning Section 91.151 (b) establish that 

safety is not adversely affected when the technical characteristics and operating limitations of a UAS 

are considered. 

The DAS 800 is powered by one Lithium Ion 11 Amp hour, 16.8V batteries, and is protected by two 

low battery failsafes. The ground control station (GCS) provides a battery indicator on the heads-up 

display, which indicates the DAS 800's current remaining battery power measured in volts, and thus 

provides the PIC with constant awareness of the real-time battery voltage during a flight. 

The two low battery failsafes that protect the DAS 800 are a "Low A Y2 battery" failsafe and a 

"Critically low A V battery" failsafe. The "Low A V battery" failsafe flies the UA to the location of 

the ground control station (GCS), or identified Rally point, when the UA batteries reach a certain 

threshold of time as configured by the operator, or 16.8V. The "Critically low A V battery" failsafe 

lands the UA at its current location. This failsafe is triggered if a battery drops below the critical 

battery voltage as configured by the operator, or 14.2V. 

The DAS 800 Operator Manual defines "A V" as "Aerial Vehicle." 

Furthermore, an exemption from the requirements of Section 91.151 (b) would not adversely affect 

safety because DAS will only conduct flights during daylight hours in VMC, with the duration of 

each flight not to exceed 15 minutes, with three minutes (i.e., 20 percent) battery power remaining. 

Likewise, as set forth above, DAS has proposed specific operating limitations in this Petition that 

will maintain the equivalent level of safety established by Section 91.151 (b), including the following: 

(I) the DAS 800 will only be operated during daylight hours (i.e. between the end of morning 

civil twilight and the beginning of evening civil twilight, as published in the American Air 

21 
Almanac, converted to local time); (2) DAS 800 will only be operated pursuant to visual 

flight rules (VFR) in visual meteorological conditions (VMC); and (3) the duration of each 

flight shall not exceed 15 minutes. 

Significantly, previous exemptions granted by the FAA concerning Section 91.151 establish that 

safety is not adversely affected when the technical characteristics and operating limitations of the 

UAS are considered. Relief has been granted for manned aircraft to operate at less than the 

minimums prescribed in Section 91.151, including Exemption Nos. 2689, 5745, and I 0650. 

Moreover, the FAA has previously granted relief from Section 91.151, specific to UAS in 

circumstances similar, in all material respects, to those presented herein (e.g. Exemption Nos. 8811, 

10808, 10673, 11042, 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 11136, 

11138). 

6. Reasons Why An Exemption From The Requirements Of Sections 91.405(a), 91.407(a)(l), 

91.409(a)(l) & (a)(2), And 91.417(a) & (b) Would Not Adversely Affect Safety. 

In seeking this exemption, DAS submits that an equivalent level of safety with regard to the 

regulatory maintenance and alteration requirements established by Sections 91.405(a), 91.407(a)( I), 

91.409(a)(l) & (a)(2), and 91.417(a) & (b) will be met because DAS, the manufacturer ofthe DAS 

800, will use its trained technicians to perform maintenance, alterations, or preventive maintenance 

on the unmanned·aircraft system using the methods, techniques, and practices prescribed in the 

manufacturer's maintenance manual. Furthermore, DAS will document and maintain all maintenance 

records for the DAS 800. 

Since the DAS 800 will be inspected as prescribed by the manufacturer's maintenance manual, DAS 

will maintain the equivalent level of safety established by Sections 91.405(a), 91.409(a)( I), and 

91.409(a)(2). The DAS 800 Maintenance Manual sets forth Scheduled Maintenance Inspection 

Procedures for each system and component. Inspection intervals for the DAS 800 include preflight 

and post flight inspections, as well as scheduled inspections every 25 hours, 50 hours, 75 hours, and 

I 00 hours of operation. 

Likewise, the exemption sought will not adversely affect safety because DAS will perform 

maintenance, alterations or preventive maintenance on the UAS using the methods, techniques, and 

practices prescribed by the manufacturer's maintenance manual. The DAS 800 Maintenance Manual 

details procedures for each component of the UA, including the components of the propulsion 

system, legs/arms, avionics system, and payload system. 

A copy ofthe DAS 800 Maintenance Manual, which contains proprietary information, is attached 

hereto as Exhibit C, and is to be held in a separate file pursuant to 14 C.F .R. § 11.35(b ). 

Furthermore, the exemption sought would maintain an equivalent level of safety established by 

Sections 91.407, 91.417(a) and 91.417(b) because all maintenance ofthe DAS 800 will be performed 

by DAS trained technicians, who will document and maintain maintenance records for the DAS 800. 

DAS trained technicians are qualified to conduct any and all maintenance to ensure the safe operation 

of the DAS family of UAS, conduct all service inspections, and authorize the use of each vehicle in 

the DAS family ofUAS based upon completion of appropriate inspections. See DAS Family of 

Systems Operations Manual, Exhibit B, at page 3-4. Pursuant to the DAS Family of Systems 

Operations Manual and the DAS 800 Maintenance Manual, a Maintenance Action Form must be 

completed and saved in the maintenance logs for all maintenance that is performed on the UAS. The 

procedures for maintaining the maintenance logs for the UAS are fully set forth in the DAS Family 

of Systems Operations Manual, Exhibit B, and the DAS 800 Maintenance Manual, Exhibit C. 

22 
< 

Significantly, previous exemptions granted by the FAA concerning Sections 91.405(a), 91.407(a)( 1 ), 

91.409(a)(l) & (a)(2), 91.417(a) & (b) establish that safety is not adversely affected when the 

technical characteristics and operating limitations of a UAS are considered. The FAA has previously 

granted relief specific to UAS in circumstances similar, in all material respects, to those presented 

herein (e.g. Exemption Nos. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 

11112, 11136, 11138). 

7. The FAA May Prescribe Any Other Conditions For Safe Operation. 

In accordance with Section 333 ofthe FAA Modernization and Reform Act of2012 (FMRA) and 14 

C.F .R. § 21.16 entitled Special Conditions, DAS requests that the FAA prescribe special conditions 

for the intended operation of the DAS 800, which contain such safety standards that the 

Administrator finds necessary to establish a level of safety equivalent to that established by 14 C.F .R. 

Part 21, Subpart H, and 14 C.F .R §§ 61.113(a) & (b), 91. 7(a), 91.121, 91.151 (b), 91.405(a), 

91.407(a)( I), 91.409(a)( 1) & (a)(2), and 91.417(a) & (b). Such special conditions will permit safe 

operation of the UA for the limited purpose of conducting aerial acquisitions over certain rural areas 

of the United States. FMRA Section 333 sets forth the requirements for considering whether a UAS 

will create a hazard to users of the NAS or the public, or otherwise pose a threat to national security; 

and further, provides the authority for such UAS to operate without airworthiness certification in 

accordance with any requirements that must be established for the safe operation of the UAS in the 

NAS. 

Likewise, the Administrator may prescribe special conditions pursuant to 14 C.F.R. § 21.16, for 

operation ofthe DAS 800, since the airworthiness regulations of 14 C.F.R. Part 21 do not contain 

adequate or appropriate safety standards, due to the novel or unusual design features of the aircraft. 

Section 21.16, entitled Special Conditions, states the following: 

lfthe FAA finds that the airworthiness regulations ofthis subchapter do not contain adequate or 

appropriate safety standards for an aircraft, aircraft engine, or propeller because of a novel or unusual 

design feature of the aircraft, aircraft engine or propeller, he prescribes special conditions and 

amendments thereto for the product. The special conditions are issued in accordance with Part II of 

this chapter and contain such safety standards for the aircraft, aircraft engine or propeller as the FAA 

finds necessary to establish a level of safety equivalent to that established in the regulations. 

See 14 C.F.R. § 21.16. 

Therefore, in accordance with FMRA Section 333 and 14 C.F .R. § 21.16, the FAA may prescribe 

special conditions for DAS 's intended operation ofthe DAS 800, which contain such safety 

standards that the Administrator finds necessary to establish a level of safety equivalent to that 

established by 14 C.F.R. Part 21, Subpart H, and 14 C.F.R Sections 61.113(a) & (b), 91.7(a), 91.121, 

91.151 (b), 91.405(a), 91.407(a)( I), 91.409(a)( I) & (a)(2), and 91.417(a) & (b). 

F. A Summary That Can Be Published In The Federal Register, stating: 

The Rules From Which DAS Seeks Exemption: 

DAS, Inc. seeks exemption from the requirements of 14 C.F.R Sections 61.113(a) & (b), 

91. 7(a), 91.121, 91.151 (b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & 

(b). 

A Brief Description OfThe Nature OfThe Exemption DAS Seeks: 

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This exemption will permit DAS, Inc. to commercially operate an Unmanned Aircraft System 

(UAS) for the purpose of conducting aerial acquisitions and research over certain rural 

areas of the United States. 

G. Any Additional Information, Views, Or Arguments Available To Support DAS 's Request. 

This Petition is made pursuant to the FAA Modernization and Reform Act of20 12 (FMRA) Section 

333, which directs the Secretary of Transportation to determine if certain UAS may operate safely in 

the NAS. As such, DAS 's request for exemption may be granted pursuant to the authority of FMRA 

Section 333 and 14 C.F .R. Part II, as set forth above. 

FMRA Section 333 sets forth the requirements for considering whether a UAS will create a hazard to 

users of the NAS or the public, or otherwise pose a threat to national security; and further, provides 

the authority for such UAS to operate without airworthiness certification. 

As discussed in detail above, DAS will operate the DAS 800 safely in the NAS without creating a 

hazard to users of the NAS, or the public, or otherwise pose a threat to national security. 

CONCLUSION 

As set forth herein, DAS seeks an exemption pursuant to 14 C.F.R. § 11.61 and Section 333 of the 

FAA Modernization and Reform Act of2012 (FMRA), which will permit safe operation ofthe DAS. 

800 commercially, without an airworthiness certificate, for the limited purpose of conducting aerial 

acquisitions over certain rural areas ofthe United States. By granting this Petition, the FAA 

Administrator will be fulfilling the Congressional mandate of the FAA Modernization and Reform 

Act of2012, while also advancing the interests ofthe public, by allowing DAS to safely, efficiently, 

and economically operate the DAS 800 commercially within the NAS. 

WHEREFORE, in accordance with the Federal Aviation Regulations and the FAA Modernization 

and Reform Act of20 12, Section 333, DAS respectfully requests that the Administrator grant this 

Petition for an exemption from the requirements of 14 C.F.R Sections 61.113(a) & (b), 91.7(a), 

91.121, 91.151(b), 91.405(a), 91.407(a)(l), 91.409(a)(l) & (a)(2), and 91.417(a) & (b), and permit 

DAS to operate the DAS 800 for the purpose of conducting aerial acquisitions and research over 

certain rural areas of the United States. 

Dated: October 9, 2015 

Respectfully submitted, 

Detailed Aerial Solutions, LLC 

Is/ Nickolas C. Houghton & Michael A. Klumpp 

Michael Alan Klumpp and Nickolas C. Houghton 

Detailed Aerial Solutions, LLC 

1955 E Walton Rd. 

Shepherd, Ml 48883 

Tel: (989) 312-3556) 

Email: mike@detailedaerialsolutions.com and nick@detailedaerialsolutions.com 

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