July 17, 2015 Triangle AirShots, LLC 2917 Woodslope Dr. Raleigh, NC 27610

U.S. Dept. of Transportation, Docket Operations West Building Ground Floor, Room w12

- 140 1200 New Jersey Avenue, SE., Washington, DC 20590

VIA FEDERAL DOCUMENT MANAGEMENT SYSTEM

Re: Exemption Request under Section 333 of the FAA Reform Act and Part 11 of the Federal Aviation Regulations

Dear Sir or Madam:

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the “Reform Act”) and 14 C.F.R. Part 11, Triangl e AirShots, LLC, seeks an exemption from Federal Aviation Regulations (“FARs”) detailed below for the following described Unmanned Aerial System

called in this application the ME System, which includes an Unmanned Aircraft (UA) and ground station based equ ipment and crew:

THE UNMANNED AIRCRAFT (UA):

 A lightweight (20 lb. gross weight with all on

- board equipment), manufactured by DJI,

T

- 600 Inspire 1, Phantom 2 and Phantom 3 that includes the following equipment in flight;

 An on

- board flight computer with GPS navigation and location ability that receives signals for flight controls from a ground

- based transmitter/controller;

 An on

- board camera capable of capturing imagery in the form of full color, high definition still pho tos and video;

 An on

- board telemetry system that delivers flight data from the on

- board flight computer

to the on

- board radio transmitter including altitude AGL, horizontal and vertical speed, compass of flight and direction back to its launch site;

 A 2. 4GHz on

- board radio transmitter that transmits live video from the on

- board camera plus all the flight data from the telemetry system described above;

THE GROUD STATION BASED PART OF THE SYSTEM:

 A Pilot in Command (PIC) in operational control of a fli ght operation from beginning to

end and who controls the UA while in the air;

 A 2.4GHz radio transmitter/controller operated by the PIC to control the UA while in flight;

 A radio receiver receiving live video and flight data from the on

- board camera and
computer projects it all together onto a screen for the PIC to view during flight;

 A second person called a Visual Observer (VO ) a person who visually track s the UA while in flight.

The requested exemption would support an application for a commercial Certificate of

A uthorization to use the above described ME System to support commercial videography and photography

, structure inspections

, marketing imagery , and private event imagery, land surveying and topographic survey

, never operating over persons no t directly involved with the ME system.The UA, powered by batteries, is smaller, lighter and more maneuverable than larger aircraft

running on combustible fuel, and it operates at lower altitudes with no people on board and will thereby reduce current r isk levels and thus enhance safety and diminish the likelihood of death or serious bodily injury. With a small payload and maximum flight time of less than 1⁄2 an hour

, this offers little or no risk to national security.

Low level oblique photos and video from several angles are far more effective than ground

based imagery for displaying the characteristics of large, complex properties with several buildings and large trees. The alternative would be to charter a full

- sized helicopter or airplane for this pu rpose, which has proven more costly than many potential clients are able to afford. The benefits of reduced cost and improved quality of presentation of the UA imagery will be valuable to and benefit many businesses, organizations, and individuals who have commercial and personal interest in legal uses for such imagery

.

Additionally, we reques t that we be allowed to use the ME System to benefit first responders nearby who might require assistance, including fire fighters, the police, the sheriff, et al., while remaining subject to all limitations cited in this application as we do so.

The ME System will be operated in the field with both a PIC and a VO in accordance with FAA Policy N 8900.227 Section 14 "Operational Requirements for UAS" and with the fol lowing

Restrictions:

a) No flight will be made with a UA Gross weight exceeding 55 pounds; b) All operations must occur in FAA Class G airspace at no more than 400 ft. AGL, at an airspeed of no more than 50 knots and no further than 3/4 NM from the PIC; c) All operations must utilize a visual observer (VO). The VO and PIC must be able to communicate by voice at all times during a flight operation; d) Operations will be restricted to flights over property with the permission of the property

owner; e) The PIC must hav e accumulated and logged, in a manner consistent with 14 CFR § 61.51 (b), a minimum of 100 flight cycles and 25 hours of total time as a UA rotorcraft pilot and at least ten hours logged as a UA pilot with a similar UA type; f) All required permits will be o btained from state and local government prior to operation; g) The ME System will not be operated over densely populated areas; h) The ME System will not be operated at air shows; i) The ME System will not be operated over any open

- air assembly of people; j) The M E System will not be operated over heavily trafficked roads; k) The ME System will not be operated within 5 NM of an airport or heliport; l) Operations will be restricted to day only and weather conditions equivalent to Visual Flight Rules ( VFR ) ; m) The PIC will brief the VO and property owner about the operation and risk before the

first flight at each new location; n) No flight may be made without a Pre

- Flight Inspection by the PIC before each operation

to ascertain that the UA is in a condition safe for flight ( see Appendix A).

The PIC and VO will meet the requirements outlined in FAA Policy N 8900.227 Section 16

P ersonnel Qualifications (8900.227) . Additionally, the PIC and VO will perform maintenance on the system and will review and be familiar with manufacturer suggested UA maintenance as part of their initial training.Attachment Page 1 of 4

ATTACHMENT: EXEMPTION REQUESTS AND EQUIVALENT LEVEL OF SAFETY

Triangle AirShots, LLC requests an exemption from the following regulations as well as any additional regulations that may technically apply to the operation of the ME System:

14 CFR Part 21, Subpart H: Airworthiness Certificates This part establishes the procedures for the issuance of an airworthiness certificate. While the

FAA continues to work to develop airworthiness standards for Unmanned Aerial Systems, we request an experimental certificate be issued for the ME System under either or both of the following provisions:

1. 21.191 Experimental c ertificates.

Experimental certificates are issued for the following purposes:

a) Research and development. Testing new aircraft design concepts, new aircraft equipment, new aircraft instal lations, new aircraft operating techniques, or new uses for

aircraft.

b) Showing compliance with regulations. Conducting flight tests and other operations to

show c ompliance with the airworthiness regulations including flights to show compliance for issuanc e of type and supplemental type certificates, flights to substantiate major design changes, and flights to show compliance with the function and reliability requirements of the regulations. Since the experimental certificate can be used for commercial pur poses such as market surveys, sales demonstrations, and customer crew training, we would expect that an experimental certificate would permit our commercial purpose as well.

2. If an experimental airworthiness certificate as described above is not appropria te for this application, then we request an exemption of 14 CFR Part 21, Subpart H , and the requirement for an airworthiness certificate in general, citing the equivalent level of safety

outlined below:

The aircraft will not carry persons or property, will not carry fuel, and will only fly under strict operational requirements. Combined with the UA’s light weight, being constructed primarily of carbon fiber and plastic, we propose that the UA will be at l east as safe, if not safer, than a conventionally certificated aircraft performing the same mission.

14 CFR 91.203(a) & (b) Civil aircraft: Certifications required. The regulation provides that an airworthiness certificate, with the registration number assigned to the aircraft and a registration certificate must be aboard the aircraft. Additionally, subparagraph (b) provides that the airworthiness certificate be "displayed at the cabin or cockpit entrance so that it is legible to passengers or crew." Wit h such a limited gross weight

as outlined herein , the UA is too small to carry documentation, does not have an entrance, and is not capable of carrying passengers or crew. To obtain an equivalent level of safety and meet the intent of 91.203, we propose th at documents deemed appropriate for this aircraft by the

FAA will be co

- located with the crew at the ground control station and available for inspection upon request. In order to identify the aircraft, we propose that the information found on

airworthiness and registration certificates be permanently affixed to the aircraft via placard containing the following information plus the word “EXPERIMENTAL” to satisfy theAttachment Page 2 of 4

requirement of 14 CFR 45.23 (see below) , which follows immediately after the proposed placard description below:

EXPERIMENTAL Manufacturer: DJI Innovations, Inc. 950 E Baseline Ave. Ste. 210 Apache Junction AZ 85119

Models: T

- 600 Inspire 1, Phantom 3 and Phantom 2

14 CFR 45.23 Display of marks; general and 45.29 Size of marks. These regulati ons provide that each aircraft must display "N" and the aircraft's registration number in letters at least 3 inches high. Additionally, the aircraft must display the word "EXPERIMENTAL" in letters at least 2 inches high near the entrance to the cabin, cock pit, or pilot station. The UA does not have an entrance in which the word "EXPERIMENTAL" can be placed, and may not have a registration number assigned to it by the FAA.

We propose to achieve an equivalent level of safety by including the word "EXPERIMEN TAL" in the placard on the top of the aircraft, as shown above, where the PIC, VO and others in the vicinity of the aircraft while it is preparing for launch will be able to see the designation. Additionally, we feel that the permanent placard discussed in the previous paragraph will provide the aircraft's registration information at the ground station. Finally, we will display at the ground station a high contrast flag or banner that contains the words "Unmanned Aircraft

Ground Station" in letters 3 inches high or greater. Since the aircraft will operate within 3/4 NM of the ground station, the banner will be visible to anyone that observes the aircraft and chooses to investigate its point of origin.

14 CFR 91.9 Civil aircraft flight manual, marking, and placard requirements. This regulation provides that no person may operate an aircraft unless a current, approved flight manual is in the aircraft. We assume that the intent of this requirement is to ensure that flight manual information is available to th e aircrew while operating the aircraft. We request an exemption to this requirement since the aircraft is not only too small to carry documentation, the documentation would not be available to the crew during flight operations.

To obtain an equivalent le vel of safety and meet the intent of 91.9, we propose that a current, approved UA Flight Manual (Appendix A) must be available to the crew at the ground station anytime the aircraft is in, or preparing for, flight.

14 CFR 61.113 Private pilot privileges and limitations: Pilot in Command and 61.133 Commercial pilot privileges and limitations. The regulation provides that no person that holds a private pilot certificate may act as pilot in

command of an aircraft for compensation or hire. Subparagraph (b) allows a private pilot to act as pilot in command 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.

Our proposed operations require that the PIC must either

1. Hold a Sport Pilot Certificate issued by the FAA, and have logged 25 hours of flight experience in this type of UA, or

2. Meet the requirements of 8 900.227 para graph 16(c)(2)(c) "Operations without a pilot certificate" in which the PIC is required to complete "FAA private pilot ground instruction" and pass "the FAA Private Pilot written examination." Since there are currently no means available for th e pilot of a UAS to gain the experience in anAttachment Page 3 of 4 equivalent category and class in order to apply for a commercial pilot's license, we propose to generate an equivalent level of safety by requiring our pilots to complete, at a minimum, FAA commercial pilot gro und instruction and pass the FAA Commercial Pilot written examination in addition to completing the private pilot requirements. Since the aircraft cannot carry passengers or property, we feel we meet the intent of 61.113 Subparagraph (b) even though the i ntent of this application is to conduct a business.

14 CFR 91.109 Flight Instruction; Simulated instrument flight and certain flight tests The regulation states that "No person may operate a civil aircraft that is being used for flight instruction unless that aircraft has fully functioning dual controls.” The ME System ground

based control station consists of a small hand

- held radio transmitt er and while it does not offer a second set of "controls", both the student and instructor can, and will, operate the single set of controls simultaneously. With both student and instructor having "hands

- on" the controls during flight, we feel that this te chnique meets the intent 91.109 and provides an equivalent level of safety.

14 CFR 91.119 Minimum safe altitudes: General. The regulation states that over sparsely populated areas the aircraft cannot be operated closer than 500 feet to any person, vesse l, vehicle, or structure. Since the aircraft will be operating at a maximum of 400 feet AGL, we cannot comply with this requirement.

In order to provide an equivalent level of safety, we will only fly over private property with sufficient space to allow for safe maneuvering of the ME System while not endangering people, vessels, vehicles, or structures. We will only fly over property with the permission of the subject property's owner or the owner's representative. The aircraft will not be operated

over congested areas or over any open air assembly of persons. The property owner or owner's representative will be briefed on the expected route of flight and the associated risks to persons and property on the ground. The aircraft will be operated at a low a ltitude allowing, if a power unit fails, an emergency landing without undue hazard to persons or property on the

surface.

14 CFR 91.121 Altimeter settings. The regulation requires that aircraft shall maintain cruising altitudes by reference to an

altimet er setting available within 100 NM of the aircraft.

The UA will always fly below 400 feet AGL and will not need to maintain cruising altitudes in order to prevent conflict with other aircraft. An Above Ground Level altimeter measurement

above the takeoff point is transmitted via radio from the UA on

- board computer to the display screen held by the PIC, providing a constantly updated AGL readout.

14 CFR 91.151 Fuel requirements for flight in VFR conditions. The regulation provides that no person may beg in a flight in an airplane under day

- VFR conditions unless there is enough fuel to fly to the first point of intended landing and to fly after that for at least 30 minutes. We feel the intention of this paragraph is to provide an energy reserve as a safety buffer for delays to landing. The UA is battery operated and the maximum duration of flight from a single battery charge is less than 1⁄2 an hour , including a 20% reserve.

Since the aircr aft will never fly more than 3/ 4 NM from the point of intended landing at a max
AGL of 400 , a full battery charge at launch will ensure that we meet the reserve energy requirement of this paragraph and can make a safe landing upon activation of reserve batteryAttachment Page 4 of 4

power . We request an exemption from the word "fuel" and ask for a n equivalent interpretation with the word "energy" . We further request that the method described in this paragraph be substituted for the requirement to be able to fly for 30 minutes beyond the point of intended landing

.

14 CFR Subpart E (91.401

- 91.41 7)

- Maintenance, Preventive Maintenance, Alterations The regulation provides that the operator is primarily responsible for maintaining the aircraft in an airworthy condition, including compliance with part 39 and 43. Paragraphs 91.407 and 91.409 require that the aircraft be "approved for return to service by a person authorized under 43.7" after maintenance and inspection.

It is our intention that the PIC perform maintenance and inspection of the aircraft and "be authorized to approve the aircraft for return to service." As provided in the Pre

- Flight Checklist in Appendix A, the PIC will ensure that the aircraft is in an airworthy condition prior to every flight and in addition conduct detailed inspections after every two hours of flight. Maintenance

pe rformed by the PIC is limited to repairing small cracks, tightening or replacing a propeller, checking electrical connections and updating software and firmware for the on

- board computer. All other maintenance will be performed by the manufacturer or their designated repair facility. The PIC will document work performed in accordance with 91.417. We feel that due to the size, construction, and simplicity of the aircraft, the PIC can ensure an equivalent level of safety.

8900.227 Paragraph 16(c)(4) PIC Med ical and Paragraph 16(e)(1) Observer Medical. This policy provides that both the PIC and VO must have a valid FAA second

- class medical certificate issued under part 67 in order to perform as a pilot or observer. The UA has a small maximum gross weight (as specified herein) , it is constructed of carbon fiber and plastic and the PIC is not on board. Both the PIC and the VO are required to be in visual line of sight ( VLOS ) . Given the unlikely event that both the PIC and VO become medically incapacitated

while the aircraft is in flight, the UA will return autonomously to the site of launching and land without crew intervention. Therefore, requiring the PIC and VO to meet the same medical requirements as a commercial pilot carrying passengers in a large aircraft is an unnecessary

burden.

We propose that the minimum medical requirements for the PIC and VO be vision corrected to 20/20 and a valid, state issued driver's license. The 20/20 vision requirement will ensure that

the PIC and VO can see the UA ; a state i ssued driver’s license serves as verification that the

PIC and VO are medically qualified to operate a much larger vehicle.APPENDIX A

– FLIGHT MANUAL

FLIGHT RESTRICTIONS a) No flight will be made with a UA Gross weight exceeding 55 pounds; b) All operations must occur in FAA Class G airspace at no more than 400' AGL, at an airspeed of no more than 50 knots and no further than 3/4 NM from the PIC; c) All operations must utilize a visual observer (VO). The VO and PIC must be able to communicate verbally at all times during a flight operation; d) Operations will be restricted to flights over property with the permission of the property

owner; e) The PIC must have accumulated and logged, in a manner consistent with 14 CFR § 61.51 f) (b), a minimum of 100 flight cycles and 25 hours of total time as a UA rotorcraft pilot and at least ten hours logged as a UA pilot with a similar UA type; g) All required permits will be obtained from state and lo cal government prior to operation; h) The ME System will not be operated over densely populated areas; i) The ME System will not be operated at air shows; j) The ME System will not be operated over any open

- air assembly of people; k) The ME System will not be oper ated over heavily trafficked roads; l) The ME System will not be operated within 5 NM of an airport or heliport; m) Operations will be restricted to day only and weather conditions equivalent to Visual Flight Rules ( VFR ) ; n) The PIC will brief the VO and property owner about the operation and risk before the first flight at each new location; o) No flight may be made without a successful Pre

- Flight Inspection by the PIC before each operation to ascertain that the UA is in a cond ition safe for flight.

PREFLIGHT CHECKLIST

 Remote controller, aircraft battery, and mobile device are fully charged.

 Propellers are mounted correctly and firmly.

 Micro

- SD card has been inserted if necessary.

 Gimbal is functioning as normal.

 Motors can start and are functioning as normal.

 DJI Pilot app connected to the aircraft.

TO REGAIN CONTROL AFTER LOST RADIO CONTACT
If radio contact is lost and not restored within 3 seconds, an automatic Return to Home feature

is ac tivated and will bring the UAV back to the PIC.APPENDIX B

– OWNER’S MANUAL FOR UA(s)

1. http://download.dji

- innovations.com/downloads/inspire_1/fr/Inspire_1_Quick_Start_Guide_fr.pdf

2. http://download.dji

innovations.com/downloads/phantom_2_vision_plus/en/Phantom_2_Vision_Plus_User_Manual _v1.8_en.pdf

3. http://download.dji

innovations.com/downloads/phantom_3/en/Phantom_3_Professional_User_Manual_v1.2_en.pd

f