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LAW OFFICES OF WAYNE A. JOHNSON

WAYNE A. JOHNSON, ATTORNEY

2901 W. PARKER ROAD #864434 

PLANO, TEXAS 75086

214.454.3292

October 2, 2015

U. S. Department of Transportation 

Federal Aviation Administration

Attention: Brenda Robeson, Program Analyst

Submission via docket at www.regulations.gov

Re: previously filed Drone Pilot, LLC exemption request under Section 333 of the FAA Reform Act 

and Part 11 of the Federal Aviation Regulations

Docket No. FAA-2015-2553

FAA letter of September 21, 2015 requesting further information 

Dear Sir or Madam:

Drone Pilot, LLC has previously filed its above-referenced application for exemption pursuant to Section 333 of 

the FAA Modernization and Reform Act of 2012 and 14 CFR Part 11. In response to the FAA letter of 

September 21, 2015 requesting further information, Drone Pilot submits the following information:

The Unmanned Aircraft Systems. Drone Pilot proposes to use sUAS that are rotorcraft and one fixed wing 

aircraft, which crafts have a maximum takeoff weight of less than 55 pounds (including payload), will be 

operated at a speed of no more than 50 knots, and which crafts contain built-in safety features. Proposed 

operations will be conducted under controlled conditions in airspace that is (1) limited, (2) predetermined, and 

(3) access controlled. Operations under the exemption will be subject to strict operating parameters to ensure at 

least an equivalent level of safety to currently authorized operations using manned aircraft.

Drone Pilot will conduct operations with lightweight rotorcrafts produced by industry leaders DJI, 3D Robotics 

and Yuneec Electric Aviation, along with one small 3D Robotics fixed wing (Aero). These aircraft are 

identified below.

DJI aircraft

 Phantom 2 

 Phantom 2 Vision + 

 Phantom 3 Standard

 Phantom 3 Professional

 Phantom 3 Advanced 

 Inspire 1

 S 800 EVO
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 S 900 

 S 1000 

 S 1000+ 

3D Robotics aircraft 

 X8+ 

 3DR Aero fixed wing 

 Solo 

Yuneec Electric Aviation aircraft

 Typhoon Q500 

 Typhoon Q500 + 

 Typhoon Q500 4K 

_______________________________________________________________________

These sUAS have common characteristics. Each can be operated by toggle or entirely by a touch-screen, mapbased interface. This means the operator only needs to command the system where to go, and the system does 

all the flying for the operator. They can be operated in both semi and fully autonomous flight modes, with the 

operator simply clicking on a map to create a pre-planned flight path for a flight. In addition, the operator can 

create no fly zones or maximum flight ranges and altitudes so the system cannot enter areas deemed unsafe or 

unnecessary to fly over. 

In addition, the sUAS have built-in intelligent fault handling capabilities which allow them to detect a system 

fault while in the air and automatically fly back to its take-off location and land. Faults that can be detected 

include: loss of communication; exceeding pre-set wind thresholds; and low battery levels. 

All flight operations are global positioning system (GPS) controlled, making the systems easy to navigate. At 

any point if the operator is not explicitly commanding the rotorcraft system to move, the system automatically

holds its GPS position. The flight control system employs not only GPS positioning but a variety of sensors 

including sonar, barometric pressure, temperature, wind speed and others to ensure stability so long as wind 

thresholds are not exceeded. 

DJI, 3DR and Yuneec all maintain online product information portals with comprehensive downloadable 

operating and maintenance manuals, user guides, flight checklists, safety information and mission planning 

instructions. Available also are instructional product and training videos along with robust online blogs and 

product forums. 

Operating Documents. The web addresses for the comprehensive operation manuals/user guides for each 

aircraft are listed on Appendix “A”. They are available openly on the internet at the manufacturers’ website. 

Standard Operating Procedures, Pre-flight checklist and Post-flight checklist were filed as confidential 

documents with the above-referenced application for exemption.

Sincerely,

/s/

Wayne A. Johnson
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Appendix “A”

Operating Documents 

DJI aircraft

 Phantom 2 www.dji.com/product/phantom-2/download

 Phantom 2 Vision + www.dji.com/product/phantom-2-vision-plus/download

 Phantom 3 Standard www.dji.com/product/phantom-3-standard/download

 Phantom 3 Professional www.dji.com/product/phantom-3/download

 Phantom 3 Advanced www.dji.com/product/phantom-3/download

 Inspire 1 www.dji.com/product/inspire-1/download

 S 800 EVO www.dji.com/product/spreading-wings-S800-evo/download

 S 900 www.dji.com/product/spreading-wings-S900/download

 S 1000 www.dji.com/product/spreading-wings-S1000/download

 S 1000+ www.dji.com/product/spreading-wings-1000+/download

3D Robotics aircraft 

 X8+ www.3drobotics.com/kb/X8+/

 3DR Aero fixed wing www.3drobotics.com/kb/aero/

 Solo www.3drobotics.com/kb/solo/

Yuneec Electric Aviation

 Typhoon Q500 www.yuneec.com/support/

 Typhoon Q500 + www.yuneec.com/support/

 Typhoon Q500 4K www.yuneec.com/support/