March 3, 2016

ODN, Inc.: Gregory Heifner

Exemption request to section 333 of the FAA Reform Act of 2012

Dear Sir or Madam:
In regards to section 333 of the FAA Reform Act o f 2012 and C.F.R Part 11. My registered business ODN, Inc, I am the owner and op erator. ODN, Inc. would like to move into the Small Unmanned Aircraft Vehicals (UAV s), requests to be exempted from the Federal Aviation Regulations (FARs) listed belo w so that ODN, Inc. may operate UASs commercially in airspace regulated by Federal Aviation Administration; as long as such operations are conducted under the conditions of the FAA that are required by section 333. ODN, Inc. works exclusively with publi c safety in the USA and Canada.

ODN, Inc.is owned by Gregory Heifner, and is the leading supplier of satellite communications for agencies across the US and Canad a. ODN, Inc. has been moving into aerial photography and the aerial inspection m arkets (tower and bridge inspections). I, Gregory Heifner, have over 1000 ho urs of flight time with the DJI Inspire series UAVs, as well as others and all of the work that I have done to date has been for personal enjoyment and education of how to properly and safely fly a drone as well as demoing their capability to law enforcement and fir e. All of my flights will adhere to the FAA’s Flight Photography Standard Operating Procedu res (SOPs).

My contact info: Gregory F. Heifner ODN, Inc. Address: 4451 I-70 Drive NW, Columbia, MO, 65202 Phone: 573-445-8101 Email: greg.heifner@orbitaldata.net Drone registration number: 

### FA37RPMRAFGregory F. Heifner holds a private pilot license with multi-engine instrument ratings

and Glider and Tow endorsements. He has approximate ly 6000 hours as PIC.

The exemption that I am asking for would permit the operation of any of the DJI UAVs, under controlled conditions for commercial us e by Gregory Heifner. ODN, Inc. requests with respect to the FAA to grant an exempt ion to the following specific sections of the Title 14 Code of federal Regulations allowin g it to operate the DJI Inspire series drones which are light weight UAV’s for commercial use.

14 CFR 21, subpart H, 14 CFR 45.23(b), 14 CFR 91.7(a), 14 CFR 91.9(b)(2), 14 CFR 91.103(b), 14 CFR 91.109, 14 CFR 91.119(c), 14 CFR 91.121, 14 CRF 91.151(a), 14 CFR 91.203(a)&(b), 14 CFR 91.405(a), 14 CFR 91.407(a)(1), 14 CFR 91.409(a)(2), 14 CFR 91.417(a)&(b), 14 CFR 61.113(a)&(b), 61.23(a) and (c), 61.101(e)(4) and (5), 61.113(a), 61.315(a), ODN, Inc. submits this application in accordance wi th the Reform Act, 112 P.L. 95 331334, seeking relief from any currently applicabl e FARs operating to prevent commercial cinematic, tower and bridge inspection, training and other flight operations within the national airspace system. The Reform Act in Section 332 provides for suchintegration of civil unmanned aircraft systems into our national airspace system as it is

in the public’s interest to do so. All public safet y flight operations will be done with full permission and oversight from the agencies responsi ble for those public assets. Any airspace within 5 miles of an airport or heliport w ill be contacted for permission to operate before any flight commences.
ODN, Inc., uses the DJI series UAVs that meet the d efinition of “small unmanned aircraft” as defined in Section 331 and therefore t he integration of the ultra-light weight UAV is expressly contemplated by the Reform Act. Th e Reform Act guides the Secretary in determining the types of UAV's that ma y operate safely in our national airspace system. Considerations include: The weight , size, speed and overall capabilities of the UAV's; whether the UAV will be operated near airports or heavily populated areas; and, Whether the UAV will be opera ted by line of sight. 112 P.L. 95 333 (a). Each of these items are in favor of an exe mption for ODN, Inc.. ODN, Inc. UAVs utilizes four (4) counter-rotating propellers for balance, control and stability. Their UAV is equipped with GPS and auto return safety tec hnology. Weighing less than ten (10) pounds (far below the maximum 55 pound limit); including camera. Attached is link to DJI Inspire Pro specs and fligh t manuals; http://www.dji.com/product/inspire-1-pro-and-raw/in fo#specs http://dl.djicdn.com/downloads/inspire_1_pro/en/Ins pire_1_Pro_User_Manual_en_v1.0_ 1201.pdf Considerations when Operating
Starting the spring of 2016 ODN, Inc. would be taki ng aerial photography / video of • Bridge inspection for Departments of Transportati on • Deactivated towers inspection for Highway Patrols and other emergency agencies • Search and Rescue • Natural disaster scene evaluation • Training in operation of UAV’s • Aerial mapping• FLIR operations near fires in support and coopera tion with the authority on the

scene • Aerial photography and video streaming

Consideration of Risk Management • All flights are operated with in line of sight • Flights will take place during the daytime • Flights will terminated once the battery reaches 20% • Full site surveys will be conducted prior to the flight • If the UAV loses sight or GPS signal is lost, it will automatically return to the
home location and land • If the UAV Battery reaches 20% it will automatica lly return to the home location
and land • UAVs are equipped with ‘First-Person-View’ (FPV) • Fights will be canceled due to high winds, rain, and snow • UAV’s will have a pre-flight check on all parts, as well as the most recent
firmware loaded The DJI Inspire is equipped with sensors for indoor flight for safety and control. Any indoor flights will have written permission as well as no people are to be in the indoor area where the flight is taking place, except for t he pilot and camera operator.
All flights will be accomplished with a PIC within view of the UAV, as well as a safety observer/camera operator (VO).
The Coalition commented that a visual observer (VO) should not be required for all small UAV operations. The Coalition further asserte d that the presence of one or more VOs may allow the UAV to be operated beyond visual line of sight (VLOS) of the pilot in command (PIC) and that the petitioner’s proposal to operate the unmanned aircraft (UA) within VLOS of the PIC and/or VO should be permitte d. The FAA notes that one of the determinations for operations under section 333 is operation within visual line of sight. The PIC must maintain VLOS while operating the UA. The FAA may find that a VO complements the PIC’s capability to see and avoid o ther aircraft, including when thePIC may be momentarily attending to other flying ta sks. The VO provides an additional

level of operational safety. About Gregory Heifner
Mr. Heifner is a well acknowledged pioneer in satel lite communications. After the 9/11 attacks, he dedicated his life to the use of commun ication satellites in public safety communication networks. Currently his system protec ts millions of people throughout the nation, allowing 911 calls to be answered even in sever circumstances where a natural disaster has rendered all other channels of communication as worthless. The addition of UAV’s is an offshoot of 50 years in RC aircraft, 45 years as a multi-engine, instrument rated, private pilot and my desire to us e UAV’s to save lives. See: www,orbitaldata.net

Benefits for the community • ODN, Inc. will provide for safer tower inspection s where no life is put at risk. • ODN, Inc. will provide for safer bridge inspectio ns where no life is put at risk. • ODN, Inc. will provide quality flight training to public safety personnel. • ODN, Inc. will safely bring the use of UAV’s to p ublic safety to save lives and property. • ODN, Inc. will make small UAV’s available to sear ch and rescue operations.

Query ODN, Inc. with the guidance of the FAA, would like recommendations on the use of UAV’s at night with FLIR cameras attached for fire fighters. This technology can sense roofs that are about to burn thru, one of the leadi ng causes of death to fire fighters.

Sincerely Gregory Heifner 4451 I-70 Drive NW Columbia, MO 65202