CADD Connection  705 Lyon St SE  Albany, OR 97321  541-967-7954  www.cadd-connection.com

Request for Exemption for use of UAS

705 Lyon St SE

Albany, OR 97321

(541) 967-7954

July 21, 2015

US Department of Transportation Docket Operations, 

West Building Ground Floor Room W-12-140, 

1200 New Jersey Avenue, SE

Washington DC 20590

Dear Sir or Madam:

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012, and 14 CFR Part 11, CADD 

Connection, LLC petitions for an exemption from the Federal Aviation Regulations identified within to 

allow for the commercial operation of its Unmanned Aircraft System (UAS) for the purposes of aerial data 

collection including surveying, monitoring and inspection, photography,videography, so long as such 

operations are conducted within and under the conditions outlined herin or as may be established by the 

Federal Aviation Administration (FAA). 

CADD Connection, LLC provides Computer Aided Design (CAD) and Building Information Modeling (BIM) 

support services to industrial, manufacturing, educational & medical facilities throughout the State of 

Oregon. Our services assist in the renovation and maintenance of such facilities. The use of UAS to 

obtain aerial data will be integrated in design and documentation processes.

Intended UAS use:

CADD Connection, LLC requests permission to operate small unmanned lightweight aircraft system, the 

DJI Phantom 2 & DJI Inspire 1, under controlled conditions in airspace that is limited and predetermined. 

This will enable CADD Connection to safely and efficiently inspect and monitor the exterior of buildings

and facilities inclusive of equipment, structural systems, roofing systems, chimneys of customers requiring 

CADD Connection, LLC services.

Site investigation and findings specifically for building exteriors would be greatly enhanced by the use of 

UAS. It can be very expensive to safely find and document exterior construction defects on multiple story 

buildings. A UAS could inspect, find and record information that would be otherwise accessible only by

aerial inspection or by using climbing equipment such as ladders, scaffolding or rigging. Also a UAS is a

safer way to do this type of high and/or difficult access investigation. Working with current clients during 

the building modeling stage will insure complete knowledge of building conditions for remodel or 

maintenance decisions.

Table I. Summary of Use of UAS

UAS Application: Surveying, monitoring and inspection, photography,videography

Business Sector: Industrial, manufacturing, educational & medical facilities

Regional: State of Oregon
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CADD Connection  705 Lyon St SE  Albany, OR 97321  541-967-7954  www.cadd-connection.com

Request for Exemption for use of UAS

Regulations from which the exemption is requested: 14 CFR Part 21, Subpart H,14 CFR 45.23(b) , 14 

CFR 61.113 (a), 14 CFR 91.7 (a) & (b), 14 CFR 91.9 (b) (2), 14 CFR. 91.103, 14 CFR 91.109, 14 CFR 

91.119 (c),14 CFR 91.121, 14 CFR 91.151 (a), 14 CFR 91.203 (a) (1), 14 CFR 91.405 (a), 14 CFR 407 

(a) (1),14 CFR 409 (a) (1) and (2), 14 CFR 417 (a) & (b).

We seek exemptions from the aforementioned Regulations to operate our unmanned aerial system 

commercially and lawfully. By granting our request we will be able to provide a safe and economical 

approach to the visual inspection and documentation of industrial building sites, buildings, chimneys and 

stacks for remodel or maintenance needs.

We are prepared to modify or amend any part of this request to satisfy the need for an equivalent level of 

safety. Please contact us any time if you require additional information or clarification.

Respectfully,

Herb Yamamoto

Herb Yamamoto

CADD Connection, LLC
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CADD Connection  705 Lyon St SE  Albany, OR 97321  541-967-7954  www.cadd-connection.com

Request for Exemption for use of UAS

Table of Contents

1. Applicant contact information – CADD Connection, LLC........................................................4

2. Sections of 14 CFR from which CADD Connection, LLC seeks exemptions ........................5

3. The Extent of Relief and the reason CADD Connection, LLC seeks relief........................6

4. Why granting CADD Connection, LLC’s request would be in the public interest....................9

5. Why granting CADD Connection, LLC an exemption would not adversely affect safety......9

Attachment A - DJI Phantom 2 Pilot Training Guide 

Attachment B - DJI Phantom 2 User Manual v1.8

Attachment C - DJI Inspire1 User Manual v1.2

Attachment D - DJI Inspire1 Safety Guidelines

Attachment E - DJI Inspire 1 Maintenance Manual v1.0

Attachment F - License and Pilot Information for William Leemaster
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CADD Connection  705 Lyon St SE  Albany, OR 97321  541-967-7954  www.cadd-connection.com

Request for Exemption for use of UAS

1. APPLICANT INFORMATION- CADD CONNECTION, LLC

CADD Connection is a drafting and design service firm with over 25 years of service. CADD Connection 

specializes in Building Information Modeling (BIM), a series of processes aimed at increasing efficiencies 

and reducing the Total Life-Cycle cost of a building; and Facility Information Modeling (FIM), which 

includes process properties and activities documentation.

CADD Connection provides building modeling solutions to customers throughout the Northwest. 

The name and address of the applicant is:

CADD Connection, LLC

Attn: Herb Yamamoto

Chief Executive Officer

705 Lyon St SE

Albany, OR 97321

(541)967-7954

herb@cadd-connection.com

www.cadd-connection.com
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CADD Connection  705 Lyon St SE  Albany, OR 97321  541-967-7954  www.cadd-connection.com

Request for Exemption for use of UAS

2. SECTIONS PF 14 CFR FROM WHICH CADD CONNECTION, LLC 

SEEKS EXEMPTIONS:

14 CFR Part 21, Subpart H (Certification Procedures for Products & Parts - Airworthiness Certificates)

Subpart H—Airworthiness Certificates

SOURCE: Docket No. 5085, 29 FR 14569, Oct. 24, 1964, unless otherwise noted.

14 CFR 45.23(b) (Identification Registration Marking)

14 CFR 61.113(a) (Certification: Pilots, Flight Instructors, & Ground Instructors)

§61.113 Private pilot privileges and limitations: Pilot in command

14 CFR 91.7 (a) & (b) (General Operations & Flight Rules)

§91.7 Civil aircraft airworthiness.

14 CFR 91.9 (b) (2)

§91.9 Civil aircraft flight manual, marking, and placard requirements.

14 CFR. 91.103

§91.103 Preflight action.

14 CFR 91.109

§91.109 Flight instruction; Simulated instrument flight and certain flight tests.

14 CFR 91.119 (c) 

§91.119 Minimum safe altitudes: General.

14 CFR 91.121, 

§91.121 Altimeter settings

14 CFR 91.151 (a) (1), 

§91.151 Fuel requirements for flight in VFR conditions.

14 CFR 91.203 (a) (1)

§91.203 Civil aircraft: Certifications required.

14 CFR 91.405 (a)

§91.405 Maintenance required

14 CFR 407 (a) (1) 

§91.407 Operation after maintenance, preventive maintenance, rebuilding, or alteration.

14 CFR 409 (a) (1) and (2), 

§91.409 Inspections.

14 CFR 417 (a) & (b)

§91.417 Maintenance records.
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CADD Connection  705 Lyon St SE  Albany, OR 97321  541-967-7954  www.cadd-connection.com

Request for Exemption for use of UAS

3. The EXTENT OF RELIEF CADD CONNECTION, LLC SEEKS AND THE 

REASONS CADD CONNECTION, LLC SEEKS THE RELIEF

3.1) Extent of Relief CADD Connection Seeks and the Reason CADD Connection, LLC seeks relief from 

14 CFR Part 21 Subpart H

Relief from 14 CFR part 21, Certification procedures for products and parts, Subpart H, 

Airworthiness certificates is requested to the extent that would allow CADD Connection to operate 

its two UAS without an airworthiness certificate.

CADD Connection seeks relief because it meets the requirements for exemption in accordance 

with the statutory criteria provided in Section 333 of PL112-95 in reference to 49 USC 44704 

given the size, weight, speed and limited operating area, proximity to airports and populated 

areas associated with the aircraft and its operation.

3.2) Extent of Relief CADD Connection, LLC Seeks and the Reason CADD Connection, LLC Seeks Relief

from 14 CFR 45.23(b)

Relief from 14CFR 45.23(b) markings of aircraft is requested to the extent CADD Connection, 

LLC is exempt from displaying the words, “limited”, “restricted”, “light-sport”, “experimental” or 

“provisional” as applicable near the entrance.

CADD Connection, LLC seeks relief because the UAS do not have entrance to a cabin, cockpit or 

pilot station on which the word “Experimental” can be placed. In addition, CADD Connection, 

LLC UAS will not be certified under 14CFR 21.191 as it meets the requirements in Section 333 of 

PL 112-95.

3.3) Extent of Relief CADD Connection, LLC Seeks and the Reason CADD Connection, LLC Seeks relief 

from 14CFR 61.113 (a).

Relief from 14 CFR 61.113 (a) and (b), Private pilot privileges and limitations is requested to the 

extent CADD Connection is exempt from the limitation that a private pilot may not engage in 

compensation or hire operations. Under current regulations, civil operations for compensation or 

hire require a PIC holding a commercial pilot certificate per 14CFR part 61. Based on the private 

pilot limitation in accordance with pertinent parts of 14CFR § 61.113(a) and (b), a pilot holding a 

private pilot certificate cannot act as a PIC of an aircraft for compensation or hire unless the flight 

is only incidental to a business or employment

CADD Connection, LLC seeks relief because in Grant of Exemption No. 11062 to Astraeus Aerial 

the FAA determined that a PIC with a private pilot certificate operating the Astraeus UAS would 

not adversely affect operations in the NAS or present a hazard to persons or properties on the 

ground. The FAA issued grants in circumstances similar in all material respects to those 

presented in this petition.
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CADD Connection  705 Lyon St SE  Albany, OR 97321  541-967-7954  www.cadd-connection.com

Request for Exemption for use of UAS

3.4) Extent of Relief CADD Connection, LLC Seeks and the Reason CADD Connection, LLC Seeks relief 

from 14 CFR 91.7 (a) & (b) 

Relief from 14 CFR 91.7(a), Civil aircraft worthiness is requested to the extent CAD Connection, 

LLC is exempt from operating an aircraft in an airworthiness condition.

CADD Connection, LLC seeks relief based on the fact that no airworthiness certificate will be 

issued for the UAS’s and no FAA regulatory standard exists for determining airworthiness. CADD 

Connection, LLC feels compliance with its operation documents to be a sufficient means for 

determining an airworthy condition.

3.5) Extent of Relief CADD Connection, LLC Seeks and the Reason CADD Connection, LLC Seeks relief 

from 14 CFR 91.9 (b) (2)

Relief from 14CFR 91.9(b)(2), Civil Aircraft Flight Manual, is requested to the extent CADD 

Connection, LLC is exempt from having a current approved Airplane or Rotorcraft Flight Manual, 

approved manual material markings, and placards, or any combination thereof in the aircraft.

CADD Connection seeks relief due to the fact that the aircraft is too small to carry the aircraft 

flight manual documentation and the documentation would not be available to the crew.

3.6) Extent of Relief CADD Connection, LLC Seeks and the Reason CADD Connection, LLC Seeks relief 

from 14 CFR. 91.103

Relief from 14 CFR 91.103, Preflight Action, is requested to the extent CADD Connection, LLC is 

not required to become familiar with certain information, specifically, information contained in the 

FAA-Approved Flight Manual on board the aircraft. The PIC will be familiar with all information 

necessary to safely conduct the flight, just not the FAA-Approved Flight Manual because it is nonexistent.

CADD Connection, LLC seeks relief because a FAA –Approved Flight Manual does not exist. 

CADD Connection, LLC will comply with other applicable requirements of 14CFR 91.103(b)(2).

3.7) Extent of Relief CADD Connection, LLC Seeks and the Reason CADD Connection, LLC Seeks relief 

from 14 CFR 91.109

Relief from 14 CFR 91.109 is requested to the extent CADD Connection, LLC is not required to 

have fully functioning dual controls for an aircraft that is being used for flight instruction.

CADD Connection, LLC seeks relief because the UAS by design do not have functional dual 

controls. Instead flight control is accomplished through the use of remote control that 

communicates with the aircraft via radio communications.

3.8) Extent of Relief CADD Connection, LLC Seeks and the Reason CADD Connection, LLC Seeks relief 

from 14 CFR 91.119(c)

Relief from 14 CFR 91.119(c), Minimum Safe Altitude, is requested to the extent CADD 

Connection, LLC may operate below 500 feet above the surface. Section 91.119 prescribes the 

minimum safe altitude under which aircraft may not operate, including 500 feet above the surface 
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CADD Connection  705 Lyon St SE  Albany, OR 97321  541-967-7954  www.cadd-connection.com

Request for Exemption for use of UAS

and away from any persons, vessel, vehicle or structure in non-congested areas. CADD 

Connection, LLC will have a maximum operating altitude of 400 feet AGL

CADD Connection, LLC seeks relief due to the fact that the UAS will be operating at a maximum 

of 400 feet above the surface, we cannot comply with the 500 foot requirement, therefore we 

request and exemption.

3.9) Extent of Relief CADD Connection, LLC Seeks and the Reason CADD Connection, LLC Seeks relief 

from 14 CFR 91.121

Relief from 14 CFR 91.121, Altimeter Setting, is requested to the extent that CADD Connection, 

LLC is not required to have a barometric altimeter. The current regulation requires a person 

operating an aircraft to maintain cruising altitudes or flight level by reference to an altimeter that is 

set to the elevation of the departure point or barometric pressure. Accordingly, CADD 

Connection, LLC will have a GPS altitude readout instead of barometric altimeter.

CADD Connection, LLC seeks relief due to the fact that their UAS do not have a barometric 

altimeter.

3.10) Extent of Relief CADD Connection, LLC Seeks and the Reason CADD Connection, LLC Seeks 

relief from 14 CFR 91.151(a) (1)

Relief from 14 CFR 91.151(a)(1), Fuel Requirements, is requested to the extent of operation at 

less than the minimums prescribed within 14CFR 91.151(a). The current regulation provides that 

no person may begin a flight in an airplane under day VFR (visual flight rule) conditions unless 

there is enough fuel to fly to the first point of intended landing and to fly after that for 30 minutes.

CADD Connection, LLC seeks relief due to the fact that the UAS are battery operated and the 

flight time is approximately 25 minutes. We believe an equivalent level of safety can be achieved 

by limiting flight time to 20 minutes with reserve energy of 20% (5 minutes) on the battery.

3.11) Extent of Relief CADD Connection, LLC Seeks and the Reason CADD Connection, LLC Seeks 

relief from 14 CFR 91.203 (a)(1), 14 CFR 91.405 (a), 14 CFR 407 (a) (1), 14 CFR 409 (a) (1) and (2), 14 

CFR 417 (a) & (b). 

Relief from: 14 CFR 91.203 (a)(1),Airworthiness Certificate; 14 CFR 91.405 (a), Maintenance 

Requirements;14 CFR 407 (a) (1), Operation after maintenance, rebuilding or alteration;14 CFR 

409 (a) (1) and (2), Inspections;14 CFR 417 (a) & (b) Maintenance records; is requested to the 

extent that regulations listed apply to aircraft with an airworthiness certificate.

CADD Connection, LLC seeks relief due to the fact that UAS will not have airworthiness 

certificates.
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CADD Connection  705 Lyon St SE  Albany, OR 97321  541-967-7954  www.cadd-connection.com

Request for Exemption for use of UAS

4. Why granting CADD Connection, LLC’s request would be in the 

public interest

CADD Connection, LLC believes that granting the exemption request would be in the public interest and 

will benefit the public as a whole for the following reasons:

UAS operations will create benefits to both the economy and the environment which are ultimately in the 

public interest. UAS consume fewer environmental resources than manned aircraft.

The beneficial information received from UAS would allow a reduction of risk to inspection workers and 

would allow factories and plants to improve and implement cost effective visual inspection schedules to 

reduce hazards that could pose a risk to the public interest.

5. Why granting CADD Connection, LLC an exemption would not 

adversely affect safety

As detailed in this document and the attached user manuals, the exemption request is for the use of the 

UAS manufactured by DJI: the DJI Phantom 2 Vision, and the DJI Inspire 1. 

UAS operations will be conducted in daylight and under visual meterologica conditions. The UAS will not 

operate within 5 nautical miles of an airport reference point (ARP), unless a letter of agreement with that 

airport’s management is obtained or otherwise permitted by a COA issued after grant of exemption.

14 CFR 45.23(b): The UAS will be identifyable with registry marked on frame in accordance with FAA 

exemptions 

14 CFR 61.113(a): The UAS will be operated by a Pilot in Command with a private pilots license. A visual 

observer will be utilized and the UAS will be in the visual line of sight of the Pilot in command and visual 

obeserver at all times.

14 CFR 91.7 (a) & (b) ; 14 CFR 91.9(b)(2); 14CFR 91.103

These UAS weigh less than 55 pounds and would not adversely affect safety. The UAS do not carry 

flammable fuel and also have no passengers or crew which reduces safety risk.

All documentation used by the operator to ensure the safe operation and flight of the UAS will be 

available to the Pilot in Command any time the UAS is operating.

Prior to each flight the PIC will conduct a pre-flight inspection and determine the UAS is in a condition for 

safe flight. PIC will review current and forecast weather, takeoff and landing distances. 

The operatior will follow the UAS manufacturer’s maintenance, inspection and life limit requirements and 

document inspection and maintenance information. The UAS operator will comply with all manufacturere 

safety bulletins.

Therefore, safety will not be adversley affected and an equivalent level of safety will be provided by 

following the conditions and limitations set forth in the grant of exemption.