CADD Connection  705 Lyon St SE  Albany, OR 97321  541

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- 7954  www.cadd

- connection.com Request for Exemption for us e 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 D C 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 U nmanned 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 fa cilities 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 investigatio n 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 building s. A UAS could inspect, find and record information that would be otherwise accessible only b y aerial inspection or by using cli mbing 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 r emodel or maintenance decisions.

Table I. Summary of Use of UAS

UAS Application: S urveying, monitoring and inspection, photography,videography

Business S ector: I ndustrial , manufacturing, educational & medical facilities

Regional: State of Oregon2 CADD Connection  705 Lyon St SE  Albany, OR 97321  541

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- connection.com Request for Exemption for us e 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 buil ding sites, buildings, chimneys and stacks for remodel or maintenance needs.

We are prepar ed to modify or amend any part of this request to satis f y the need for an equivalent level of safety. Please contact us any time if you require additional informatio n or clarification.

Respectfully, 

# Herb Yamamoto

Herb Yamamoto CADD Connection, LLC3 CADD Connection  705 Lyon St SE  Albany, OR 97321  541

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- connection.com Request for Exemption for us e of UAS Table of Contents

1. Appl icant contact information

– CADD Connection , L LC.....................................

.......... .... . .... 4 2. Sections of 14 CFR from which CADD Connec tion, 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 Inspire 1 User Manual v1.2

Attachment D

- DJI Inspire 1 Safety Guidelines

At tachment E

- DJI Inspire 1 Maintenance Manual v1.0

Attachment F

- License and Pilot Information for William Leemaster4 CADD Connection  705 Lyon St SE  Albany, OR 97321  541

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## 1. APPLICANT INFORMATION

- CADD C ONNECTION , 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 Tota l Life

- Cycle cost of a building; and Facility Information Modeling (FIM), which includes process properties and activities documentation.

CADD Connectio n provides building modeling solutions to customers throughout the Northwest.

The name and address of the applicant is :

CADD Connection, LLC

A ttn: Herb Yamamoto Chief Executive Officer 705 Lyon St SE Albany, OR 97321 ( 541 ) 967

- 7954 herb@cadd

- connection.com www.cadd

- connection.com5 CADD Connection  705 Lyon St SE  Albany, OR 97321  541

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## 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 S OURCE : 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 s afe 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.6 CADD Connection  705 Lyon St SE  Albany, OR 97321  541

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## 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 , Certif ication procedures for products and parts, Subpart H

, Airworthiness certificates is requested to the extent tha t would allow CADD Connection to operate its two UAS without an airworthiness certificate.

CADD Con nection seeks relief because it meets the requ irements 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 aircra ft 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 disp laying 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 “Experi mental” 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 reli ef 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.7 CADD Connection  705 Lyon St SE  Albany, OR 97321  541

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- connection.com Request for Exemption for us e 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 airc raft 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 complian ce 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 Connect ion 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 Fligh t Manua l 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 non

existent.

CADD Connection , LLC seeks relief because a FAA

– Approved Flight Manual does not exist. CADD Connection , LLC will comply with other applicable requirements of 14 CFR 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 reques ted 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. Ins tead 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)

Rel ief from 14 CFR 91.119(c), Minimum S afe 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 ab ove the surface8 CADD Connection  705 Lyon St SE  Albany, OR 97321  541

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- connection.com Request for Exemption for us e 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 referen ce 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.

3.1 0 ) 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 operatio n 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.

3.1 1 ) 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; 1 4 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.9 CADD Connection  705 Lyon St SE  Albany, OR 97321  541

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## 4. Why gr anting 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 cr eate 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 wo rkers and would allow factories and plants to improve and implement cost effective visual inspection schedules to reduce hazards that c ould 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 Pha ntom 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 poi n t (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 4 5.23(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 i n 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 limi t requirements and document inspection and maintenance information. The UAS operator will comp l y with all manufacturere safety bulletins.

Therefore, safety will not be adversley affected and an equivalent level of safety will be provided by following the condition s and limitations set forth in the grant of exemption.