July 22, 2015 U.S. Dept. ofTransportation, Docket Operations West Building Ground Floor, Room w12-140 1200 NewJersey Avenue, SE., Washington, DC 20590 Submitted Electronically via the Federal Docket Management System (FDMS) Re: Exemption Request under Section 333 ofthe FAA Reform Act and Part 11 ofthe Federal Aviation Regulations Dear Sir or Madam: On Behalf of Diversified Design & Drafting Services, Inc., and Pursuant to Section 333 ofthe FAA Modernization and Reform Act of2012 and 14 C.F.R. Part 11, I Pam Nobles, President am seeking an exemption from Part 21 Subpart H; and Sections 91.203 (a) (1), 45.23 (b), 91.7 (a), 91.9, 61.113, 61.133, 91.109, 91.119, 91.121, 91.151, and (91.401- 91.417) Subpart E , ofTitle 14, Code of Federal Regulations (14 CFR). This proposed exemption would allow forthe operation ofour unmanned aircraft (UA) the DJI Phantom 2 Vision, DJI Spreading Wings SlOOO+, and the Allied Drones EF44 Atlas. THE UNMANNED AIRCRAFT (UA}: • The UA's are lightweight (under 551b. gross weight), battery operated multi Rotor copters that take offand land vertically and have the abil ity to hover in one location during flight. THE UA INCLUDES:
• 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 photos 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 direction offlight and direction back to its launch site • 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 GROUND STATION PART OF THE SYSTEM: • A Pilot in Command (PIC) In operational control of a mission from beginning to end, and who controls the UA while in the air • A radio transmitter/controller operated by the PIC to control the UA while in flight • Ground Station (computer, tablet for smart phone based app) which receives and displays video and system telemetry real time from the UA • A Visual Observer (VO), a person who provides a second pair of eyes to visually track the UA while in flight
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### PILOT IN COMMAND (PIC) AND VISUAL OBSERVER: The PIC and VO will meet the requirements outlined in FAA Policy N 8900.227 Section 16 personnel Qualifications. Additionally, the PIC and VO will perform maintenance on the system and will complete a course of maintenance instruction as part oftheir initial training. I submit thatthe combination ofthe UA's light weight, flight performance and ability, fully qualified flight crew and strict operation under the guidelines established in 8900.227, and under all ofthe Restrictions listed above, the FAA can have full confidence that the operation will have an equivalent or greater level ofsafety than manned aircraft performing the same mission. 

### INTENDED USE: The requested exemption would allow us to use the UA for aerial image acquisition to support various mapping and surveying applications as well as video documentation for the public good
. Typical applications would include, but are not limited to:
• Inspection Services • Aerial Photography • Aerial Mapping • Volumetric Surveys • Transportation Mapping Survey • Corridor Mapping Surveys The inherent ability of the UA is to capture imagery from a low altitude including oblique photos and video from several angles is far more effective than ground- based imagery for displaying the characteristics of buildings, sites and properties or areas where consistent monitoring is needed. The applicant in the past has chartered fixed wing aircraft and/or helicopters for this purpose, which have proven more costly than many potential clients have been able to afford, resulting loss ofopportunities. The reduced cost and higher quality data from the UA will be beneficial to the public in applications such as preservation of historic buildings or archeological sites where access is limited due to the sensitive nature of the site. In addition we intend to offer inspection services on sites that would include microwave or radio towers where conditions are unsafe for human participation. 

### PUBLIC SAFETY: UA's, are powered by batteries, they are smaller, lighter and more maneuverable than larger aircraft running on combustible fuel; they operate at lower altitudes (under 400') with no people on board thereby reducing current risk levels and enhancing public safety
. With a small payload and maximum flight time of approximately 22 to 60 minutes, UA's offer little or no risk to national security. In addition the Our OJI model UA's have their own built in flight restrictions in special areas such as airports, which limit flight in these areas. More information can be found in the UA's User Manual or on DJI's website at https:/ /www.dji.com/fly-safe. The Allied Drones EF-44 has a similar systems.



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### of 3SUMMARYGRANT REQUEST: This request follows many others using sim ilar sys tems and process that have been granted pre viously. I am requesting the FAA issue a summary grant ofexemption, as this request would not set a precedent.
• The reasons stated by the FAA for granting Exemption Nos. 11062, 11109, 11112, and 11213 also apply to this request • A grant ofexemption would be in the public interest. THE REGULATIONS FROM WHICH THE EXEMPTIONS ARE BEING REQUESTED Beside each regulation number is the page ofthe attached Addendum upon which each may be found together with a proposed equivalent level ofsafety for each regulation:

- 14CFR Part 21 Subpart H Addendum Page 1

- 14 CFR 91.203 (a) (1) Addendum Page 1

- 14 CFR 45.23 (b) Addendum Page 1

- 14 CFR 91.7 (a) Addendum Page 2 -14 CFR 91.9 Addendum Page 2

- 14 CFR 61.113, 61.133 Addendum Page 2

- 14CFR 91.109, 91.119, 91.121 Addendum Page 3

- 14CFR 91.151 Addendum Page 3

- 14CFR Subpart E(91.401 - 91.417) Addendum Page 4

- FAA Policy 8900.227 Paragraph 16(c)(4) and Paragraph 16(e)(1) Addendum Page 4
I am prepared to modifyor amend any part ofthis request to satisfy the need for an equivalent level of safety. Please contact us at any time if you require additional information or clarification. I am the primary point ofcontact forthis request and lookforward to working with your office.



# ~ Pam Nobles, President Diversified Design 

### & Drafting Services, Inc. 2374 Capital Circle NE Tallahassee, FL 32308 Phone : 850-519-1364 Email : pam@dddsinc.com Addendum Containing Exemption Requests and Equivalent Level of Saf ety Appendix A- Flight Operations/Procedures Appendix B - User's Manuals

Diversified Design 

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## 3AQQENDUM EXEMPTION REQUESTS AND EQUIVALENT LEVEL OF SAFETY 

### I, Pam Nobles, President of Diversified Design 

### & Drafting Services, Inc. , request an exemption from the following regulations as well as any additional regulations that may technically apply to the operations of the D JI Phantom 2 Vision, DJI Spreading Wings 51000+, and the Allied Drones EF44 Atlas: 

### 14 C.F.R. Part 21, Subpart H: Airworthiness Certificates 14C.F.R. 91.203 (a) (1) Subpart H, entitled Airworth iness Certificates, establishes the procedural requirements for the issuance ofairworthiness certificates as required by FAR 91.203( a) (1). 

### Given the size and limited operating area associated with the UA to be utilized by the Petitioner, an exemptionfrom Part 21 Subpart Hmeets the requirements ofan equivalent level ofsafety under Part 11 and Section 333 ofthe FMRA. The FederalAviation Act {49 U.S.C.44701 (f)) 

### and Section 333 ofthe FMRA both authorize the FAA to exempt aircraftfrom the requirement for an airworthiness certificate, upon consideration of the size, weight, speed, operational capability, and proximity to airports and populatedareas of theparticular UA. In all cases, an analysis ofthese criteria demonstrates thatthe UA operated without an airworthiness certificate, in the restricted environment and under the conditions proposed will be at least as safe, or safer, than a conventional aircraft (fixed wing or rotorcraft) operating with an airworthiness certificate without the restrictions and cond itionsproposed. The UA to be operated hereunder is less than 55 lbs
.fully loaded, is bydefinition unmanned and carries neither a pilot norpassenger, carries no explosive materials or flammable liquidfuels, and operates exclusively within a limitedflight area. Unlike other civil aircraft , operations under this exemption will be tightly controlled and monitored by the Operator and will also remain within the requirements of, and in compliance with, local public safety requirements. These safety enhancements, which already apply to civil aircraft provide a greater degree ofsafety to the public andproperty owners than conventional operations conducted with airworthiness certificates issued under 14 C.F.R. Part 21, Subpart H. Last ly, application ofthese same criteria demonstrates that there is no credible threat to national security posed by the UA due to itssize, speed ofoperation, location ofoperation, lack of explosive materials or flammable liquid fuels , and inability to carry a substantialexternalload.


### 14 C.F.R. 45.23 (b). Marking ofthe Aircraft The regulation requires; When marks include only the Roman capital letter "N" and the registration number is displayed on limited, restricted or light-sport category aircraft or experimental or provisionally certificated aircraft, the operator must also display on that aircraft near each entrance to the cabin, cockpit, or pilot station, in letters not less than 2 inches nor more than 6 inches high, the words " limited," "restricted," "light-sport," "experimental," or "provisional," as applicable. 

### Even though the UA will have no airworthiness certificate, an exemption maybe neededas the UA will have no entrance to the cabin, cockpit orpilotstation on which the word "Experimental" can be placed. Given the size ofthe UA, two-inch lettering will be impossible. The word "Experimental" will beplaced on thefuselage in compliance with 45.29 (f). The equivalent level ofsafety will be provided by having Diversified Design 

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### the UA marked on itsfuselage as required by 45.29 (f) where the pilot , observer and others working with the UA will see the identification ofthe UA as "Experimental." The FAA has issued the following exemptions to this regulation to Exemptions Nos. 10700, 8738, 10167 and 10167 A. 14C.F.R. 91 .7(a) : Civil aircraft airworthiness. The regulation requires that no person may operate a civil aircraft unless it is in airworthy condition. 

### As there will be no airworthi ness certificate issued for the aircraft, should this exemption be granted, no FAA regulatory standard will existfor determining airworthiness. Given the size ofthe aircraft and the requirements containedhereinfor the use of safetycheck lists prior to eachflight , an equivalent level of safety will beprovided. 14 CFR 91 .9 Civil aircraftflight 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 ofthis requirement is to ensure that flight manual information is available to the 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 obtai n an equivalent level ofsafety and meet the intent of91.9, we propose that a current approved UA Flight Operations/Procedur es (Appendix A) must be available to the crew at the ground station anytime the aircraft is in, orpreparingfor ,flight. The F AA has issued the following exemptions to this regulation: Exemption Nos. 8607, 8737, 8738, 9299, 9299A,9565, 95658,10167,10167A, 10602,32827, and 10700
. 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 ai rcraft does not carry passengers or property for compensation or hire
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### Ourproposed operations require that the PICmusteither

1. Hold a Private orSport Pilot Certificate issued by the FAA and have logged 10 hours of flight experience in this type ofUA, or 2
. Meet the requirements of8900.227para 16(c)(2)(c) "Operations without apilot 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 availablefor the pilot of a UA to gain the experience in an equivalent categoryandclass in order to apply for a private pilot's license, wepropose to generate an equivalent level ofsafety by requiring our Diversified Design 

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### pilots to complete, at a minimum, FAA private pilot ground instruction and pass the FAA Private Pilot written examination in addition to completing the private pilot requirements. Since the aircraft cannot carry passengers orproperty, wefeel that we meet the intent of 61.113 Subparagraph (b) even though the intent of this application is toconducta business. 14CFR 91.109 Flight Instruction; Simulated instrumentflight and certain flighttests 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 UA's ground-basedcontrol station consists of a small hand-held radio transmitter and while itdoes notoffera secondsetof"controls", both the studentand instructorcan, and will, operate thesingle set ofcontrols simultaneously
. With both student and instructor having "hands

-on" the controls during flight, wefeel thatthis technique meets the intent91.109 andprovides an equivalent level of safety. 14CFR 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, vessel, vehicle, or structure. Since the aircraft will be operating at a maximum of400 feet AGL, we cannot comply with this requirement. 

### In order toprovide an equivalent level of safety The UA's will not be operated over congested areas or over any open air assembly of persons withprior approval. Anyproperty owner affectedwill be briefed on the expected route of flight and the associated risks to persons andproperty on the ground. The aircraft will be operatedat a low altitude allowing, 

## ifapowerunit fails, an emergencylanding without undue hazard topersons orproperty on the surface. Therefore we maintain that due to the small size ofthe UA, the hazard to persons, vehicles and structures is minimal compared to manned aircraft , which shouldbeconsideredin granting theexemption. 14CFR 91.121 Altimeter Settings. The regulation requires that aircraft shall maintain cruising altitudes by reference to an altimeter setting available within 100 NM ofthe aircraft. 

### The UA will alwaysfly below400feet 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 radiofrom the VA'S on-board computer to the display screen held by the PIC, providing a constantly updatedAGL readout. 14CFR 91.151 Fuel requirements forflight in VFR conditions. The regulation provides that no person may begin 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. 

### The intention ofthis paragraph is toprovide an energy reserve as a safety buffer for delays to landing. Each UA is battery operated and the maximum duration of flightfrom a single battery charge is 18 minutes with a 20% reserve. Since the aircraft will neverfly more than 3/4NMfrom the point of 

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### intended landing, a full battery charge at launch will ensure that we meet the reserve energy requirement ofthis paragraph. We request an exemption to the word ''fuel" and askfor an equivalent interpretation with the word "energy". 14 CFR Subpart E (91.401- 91.417)- 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
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### It is ourintention thatthe PICperform maintenance and inspection ofthe aircraft and "be authorized to approve the aircraft for return toservice. " Asprovided in the Pre-Flight Checklist in AppendixA, the PIC will ensure that the aircraft is in an airworthy condition prior to everyflight and in addition conduct detailed inspections after every two hours of flight. Maintenance performed by the PIC is limited to repairing small cracks, replacing a propeller, checking electrical connections andupdating software and firmwarefor the on-board computer. All other maintenance will beperformed by the manufacturer or their designated repairfacility. The PIC will document workperformed in accordance with 91.417. We feel that due to the size, construction, and simplicity ofthe aircraft, the PIC can ensure an equivalent level of safety. 8900.227 Paragraph 16(c)(4) PIC Medical. And Paragraph 16(e)(l) Observer Medical. This policy provides that both the PIC and VO must have a valid FAA second-class med ical certificate issued under part 67 in order to perform as a pilot or observer. 

### The UA's maximum gross weight are each less than Bibs., are constructed primarily of, plastic and carbonfiber. The PIC is not on board. Both the PIC and the VO are required to be in VLOS. Given the unlikely event that both the PIC and VO become medically incapacitated while the aircraft is inflight, the UA will return autonomously to the site of launching and land withoutcrew intervention. Therefore , requiring the PIC and VO to meet the same medical requirements as commercial pilot carrying passengers in a large aircraft is an unnecessaryburden. Wepropose that the minimum medical requirementsfor 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 n see and avoid air traffic; a licensed driver is medically qualified to operate a much larger vehicle.

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### 4 of4APPENDIX A- FLIGHT OPERATIONS/PROCEDURES The UA's will be operated underthe following flight restrictions.

OPERATIONAL FLIGHT RESTRICTIONS The UA will be operated in the field with both a PIC and aVO in accordance with and with the following Restrictions: • All operations must occur in FAA Class G airspace at no more than 400ft AGL, at an airspeed of no more than 25 knots and no further than 3/4 NM from the PIC; • All operations must utilize a visual observer (VO). The VO and PIC must be able to communicate by voice at all timesduring a flight operation; • The PIC must have accumulated and logged, in a manner consistent with 14 CFR § • 61.51 (b), 10 hours oftotal time as a UA rotorcraft pilot and at least 5 hours logged as a UA pilot with a similar UA type; • The UA will not be operated over densely populated areas; without prior approval. • The UA will not be operated over any open-air assembly of people; without priorapproval. • The UA will not be operated within 5 NM ofan airport or heliport; without prior approval. • Operations will be restricted to day only and weather conditions equivalent toVFR; • The PIC will briefthe VO and property owner about the operation and risk before operation • No flight will 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
PRE-FLIGHT CHECKLIST Prior to operation preflight checklists provided by the manufacturer ofthe UA's will be followed. Below is such an example. 1. Remote Controller, smart battery, Range Extender and smartphone are fully charged. 2. Propellers are mounted correctly. 3. Damping absorbers are in good condition, not broken or worn. 4. Camera lens cap has been removed. 5. Micro-SO card has been inserted ifnecessary. 6. Gimbal is functioning as normal. 7. Motors can start and are functioning as normal. 8. Sensor connection is established.



### Diversified Design & 

### Drafting Services, Inc.- APPENDIX A- FLIGHT OPERATIONS AND PROCEDURESTAKE OFF/LANDING PROCEDURES Manufacturer recommended Takeoffand landing procedures will be followed. Place the UA on ground with the battery level indicatorfacing you. 1. Power on the remote controller. 2. Power on the range extender. 3. Power on or connect sensor. 4. Power on the aircraft by turning on the battery 5. Connect the mobile device (Ground Station) to the UA. 6. Wait until the LED flight indicator lights indicate good GPS connectivity and Ready to Fly. 7. Push the throttle stick up slowlyto lift the aircraft offthe ground. 8. When landing, hovering over a level surface, pull down on the throttle stick gently to descend and land. 9. After landing the aircraft on the ground, keep the throttle stick down while the motors come to a complete stop. FAILSAFE FUNCTION The UA will enter Failsafe mode when the connection from the remote controller is lost. The flight control system will automatically control the aircraft to return to home and land to reduce injuries or damage. The following situations would make the aircraft fail to receive a signal from the remote controller and enter Failsafe mode: 

### 1. The remote controller is powered off. 2. The aircraft has flown out ofthe effective communication range ofthe remote controller. 3. There is an obstacle obstructing the signal between the remote controller and the aircraft, essentially reducing the distance the signal can travel. 4. There is interference causing a signal problem with the remote controller
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Diversified Design 

### & Drafting Services, Inc.- APPENDIX A- FLIGHT OPERATIONS AND PROCEDURESAPPENDIX 8- USER'S MANUALS OJI Phantom 2 Vision. OJI Soreading Wings S1000+. Allied Drones EF44 Atlas

Users Manuals foreach ofthese systems can be downloaded here. Diversified Design 

### & Drafting Services, Inc., keeps a copy with each UA. http://www
.d ji
.com/product/phantom-2-vision-pius/ download http:ljwww.dji.com/product/spreading-wings-s1000/download http://allieddrones.com/wp-content/uploads/2015/02/ADEF44SpecSheet
.pdf Upon request these will be provided



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