January 4, 2016
U.S. Department ofTransportation Docket Management System 1200NewJersey Avenue, SE Washington, DC 20590
Re: F3EA Exemption Request to Operate an Unmanned Aircraft System Pursuant to Section 333 ofthe FAA Modernization and Reform Act of2012 and Part 11 ofthe Federal Aviation Regulations from 14 C.F.R. To whom it may concern, Pursuantto Section 333 ofthe FAA Modernization and Reform Act of2012 and 14 C.F.R. Part 11, F3EA hereby applies for an exemption from the Federal Aviation Regulations (FARs) identified belowto allow for the commercial operation ofsmall Unmanned Aircraft Systems (sUAS) for aerial data collection. The data will be used in support ofproviding a high-quality videography system to commercial and governmental organizations. F3EA will provide these services for military training, marketing, structural inspection, economic development, survey, and agriculture. F3EA employs current and former US Army Aviators and has developed a sUAS flight standardization program modeled after US Army aviation standardizationprograms. The name and address ofthe applicant: F3EA, Inc. Attn: Bryan C. Madden, Phone 208-890-2937 Email: bmadden@F3EA.com Address: 10 Turnbull Lane, Savannah, GA, 31410 The specific section or sections thatF3EA, LLC seeks an exemption from: • 14 CFR § § 61.23 (a) and (c) • 61.101 (e)(4) and (5) • 61.113 (a) • 61.315 (a) • 91.7 (a) • 91.119 (c) • 91.121 • 91.151 (a)(1) • 91.405 (a) • 91.407 (a)(l) • 91.409 (a)(l) and (2)• 91.417 (a) and (b) Information Regarding the UAS F3EA Inc. operates a DJI Phantom 3 andthe DJI Inspire 111 Pro. F3EA Inc. adheres to the Inspire 1User Manual, Inspire 1 Maintenance Manual, Inspire 1 Safety Guidelines, and Intelligent Flight Battery Safety Guidelines. The current version ofthe Inspire 1 documents are available onthe DJI website at http://www.dji.com/product/inspire1/download. F3EA Inc. adheres to the DJIPhantom 3 User Manual, Phantom 3 Maintenance Manual, and Phantom 3 Safety Guidelines. The current version ofthe Phantom 3 documents are available onthe DJI website at http://www.dji.com/product/phantom-3-pro/info#downloads. These operating documents are accessible during UAS operations and F3EA verifies document currencypriorto operation. F3EAprocedures for preflight, inspections, maintenance, andrepair come directly from the DJI operating documents. The DJI Phantom 3 has the following flight and safety features: • Phantom 3 is a UAS Quadcoptermade by DJIthat has a fixed gimbal and camera attached to the bottom. Phantom 3 has a maximum weight of2.82lbs. (1280 grams), and a maximumrange of2000m. • Phantom 3 has built intelemetry to allowthe operatorto see all onboard information relating to the safety offlight including butnot limitedto battery percentage remaining, overall health ofthe operating system, built-in GPS for position hold and automatic return-to-home, and multiple fail-safes for maximum safety. • The onboard camera allows the operatorto record HighDefinitionvideo, as well as take camera stills. The video is transmitted real-time to the control and operator allowing the operatorto see images to all sides ofthe UAS utilizing an Apple iPad Air. • DJI Phantom 3 is limited to a maximum assentrate of5 m/s and has a maximum decent rate of3 m/s. It also has a limitation ofmaximum speed of 16 m/s. • The Inspire 1 will be operatedwith a 4480maH lithiumpolymerbattery allowing for flight times not to exceed 23 minutes. The DJI Inspire 1has the following flight and safety features: • Inspire 1 is a UAS Quadcoptermade byDJI that has a fixed gimbal and camera attached to the bottom. Inspire 1has a maximum weight of6.47lb. (2965 grams), and a maximumrange of2000m. • Inspire 1 has built intelemetry to allowthe operatorto see all onboard informationrelating to the safety offlight including but not limitedto battery percentage remaining, overall health ofthe operating system, built-in GPS for positionhold and automatic return-to-home, and multiple fail-safes for maximum safety. • The onboard camera allows the operatorto record High Definitionvideo, as well as take camera stills. The video is transmittedreal-time to the control and operator allowing the operatorto see images to all sides ofthe UAS utilizing an Apple iPad Air.• DJI Inspire 1 is limitedto a maximum assentrate of5 m/s and has a maximum decent rate of4 m/s. Italso has a limitation ofmaximum speed of22 m/s or 49 mph. • The Inspire 1 will be operatedwith a 5700maH lithium polymerbattery allowing for flight times notto exceed 22 minutes. 

### Information Regarding the UAS PIC F3EA's UAS PICs hold an airline transport, commercial, private, recreational, or sport pilot certificate. The PIC will meetthe flight reviewrequirements specified in 14 CFR § 61.56 in an aircraft in whichthe PIC is rated onhis or herpilot certificate. F3EA will not permit any PIC to operate unless the PIC demonstrates the ability to safely operate the UAS. PIC qualification flight hours and currency will be logged in a manner consistent with 14 CFR § 61.51(b). F3EAwill utilize a visual observer (VO) and will operate the UAS within visual line of sight (VLOS) ofthe PIC and VO at all times. The PIC and VO willmaintainthe ability to communicate at all times, excludingthe use ofelectronic messaging ortexting. 

### Information Regarding the Operation ofthe UAS F3EA's UAS operations will be conducted in Class G airspace at altitudes of400 feet and below, notto exceed 87 knots. F3EA will use geo-fencing as the means to control the area ofoperations, a PIC invisual line ofsight ofthe UAS, and a visual observer within constant visual line ofsight ofthe UAS. The specific area ofoperations for each flight will be limited to the property boundaries ofthe property being filmed and a safety survey is conducted bythe PIC and VOprior to all flight operations. Whenthe property boundary is in close proximityto outside structures orpersonnel, a no-fly area is establishedthrough geo-fencing and flight operations will notbe conducted any closer than 500 feet unless permissionhas been granted bythe non-participating owner or controller. Inthe event ofa loss ofcommunication withthe UAS, the UAreturns to a pre-determined location withinthe private or controlled-access property. F3EAUAS operations always remain clear and give way to manned aviation operations at all times. The DJI Inspire operates on 5.725-5.825 GHz and 2.400-2.483 GHz and complies with the Federal Communications Commission. F3EA will provide commercial sUAS services to support commercial and real estate photography and videography. This provides a significantreduction in cost and improvement in safety to the public. In addition, F3EA will provide structural inspection services that reduces fall risk to personnel. Finally, F3EA will provide ISR support for military and law enforcementtraining with the sUAS. This will enhance the training and readiness ofthosepersonnel. 

### Extent ofReliefandEquivalent Level ofSafety forExemptions Requested 14 CFR § § 61.23 (a) 

### and (c) F3EA, Inc. seeks exemption from this regulation that outlines the medical certificate requirements and duration, including the operations that require a medical certificate (a) and operations requiring either a medical certificate or U.S. driver's license (b).• Extent ofRelief: F3EA seeks the ability for the sUAS PIC to hold a current FAA airmen medical certificate or a valid U.S. driver's license issuedby a state, the District ofColumbia, Puerto Rico, a territory, a possession, orthe Federal Government. • Equivalent Level ofSafety: The equivalent level ofsafety is met inthe extent of reliefrequested. The PIC will have a current FAA airman medical certificate or a valid U.S. driver's license. 

### § 61.101 (e)(4) and (5) F3EA, Inc. seeks exemption from the regulation thatprohibits a recreational pilot from acting a pilot in command ofan aircraft used for compensation orhire, or in furtherance ofa business. • Extent ofRelief: F3EA seeks the ability for employees qualified as recreational pilots to operate the UAS for compensation. • EquivalentLevel ofSafety: The UAS PIC will hold an airline transport, commercial, private, recreational, or sportpilot certificate. The PIC will meet the flight reviewrequirements specified in 14 CFR § 61.56 in an aircraft in whichthe PIC is rated onhis orherpilot certificate. F3EA will notpermit any PIC to operate unless the PIC demonstrates the ability to safely operate the UAS. PIC qualification flight hours and currency will be logged in a manner consistent with 14 CFR § 61.51(b). Duringtraining, proficiency, and experience-building flights, all persons not essential for flight operations will be no closerthan 500 feet from flight operations. 

### § 61.113 (a) F3EA, Inc. seeks exemption from the regulation thatprohibits a privatepilot to act a pilot in command for compensation orhire. • Extent ofRelief: F3EA seeks the ability for employees qualified as private pilots to operate the UAS for compensation. • Equivalent Level ofSafety: The UAS PIC will hold an airline transport, commercial, private, recreational, or sportpilot certificate. The PIC will meetthe flight reviewrequirements specified in 14 CFR 

### § 61.56 in an aircraft in which the PIC is rated onhis orherpilot certificate. F3EA will notpermit any PIC to operate unless the PIC demonstrates the ability to safely operate the UAS. PIC qualification flight hours and currency will be logged in a manner consistent with 14 CFR § 61.51(b). During training, proficiency, and experience-building flights, all persons not essential for flight operations will be no closerthan 500 feet from flight operations. 

### § 61.315 (a) F3EA, Inc. seeks exemptionfrom the regulation that prohibits a sportpilot from acting as pilot in command ofan aircraft used for compensation orhire. • Extent ofRelief: F3EA seeks the ability for employees qualified as sportpilots to operate the UAS for compensation. • Equivalent Level ofSafety: The UAS PIC will hold an airline transport, commercial, private, recreational, or sportpilot certificate. The PIC will meet theflight reviewrequirements specified in 14 CFR 

### § 61.56 in an aircraft in whichthe PIC is rated onhis or herpilot certificate. F3EA will notpermit any PIC to operate unless the PIC demonstrates the ability to safely operate the UAS. PIC qualification flight hours and currency will be logged in a manner consistent with 14 CFR § 61.51(b). During training, proficiency, and experience-building flights, all persons not essential for flight operations will be no closer than 500 feet from flight operations. 

### § 91.7 (a) F3EA, Inc. seeks exemption from the regulation that restricts operation ofcivil aircraft unless it is an airworthy condition. • Extent ofRelief: F3EA seeks relieffrom obtaining an airworthiness certification for the UAS. • Equivalent Level ofSafety: F3EA will be responsible for maintaining and inspecting the UAS to ensure that it is in a conditionfor safe operation. Prior to each flight, the PIC will conduct a pre-flight inspection and determine ifthe UAS is in a condition for safe flight. F3EA will follow the UAS manufacturer's maintenance, overhaul, replacement, inspection, and life limit requirements for the aircraft and aircraft components. F3EA will comply with all manufacturer safety bulletins. F3EA will conduct a functional test flight after any maintenance or alterations to the UAS that affect the operation or flight characteristics. The functional test flight will be conducted by the PIC and VO, will remain at least 500 feet from otherpeople, and will be conducted in such a manner so as to not pose an undue hazard to persons and property. 

### § 91.119 (c) F3EA, Inc. seeks exemption from the regulation that requires operation over other than congested areas, except for takeoffand landing, to an altitude no lower that 500 feet above the surface and no closer than 500 feet to any person, vessel, vehicle, or structure. • Extent ofRelief: F3EA requests to operate at an altitude ofno more than 400 feet above ground level (reported in feet AGL). • Equivalent Level ofSafety: F3EA will utilize a visual observer (VO) and will operate within visual line ofsight (VLOS) ofthe PIC and VO at all times. The PIC and VO will maintain the ability to communicate at all times, excluding the use ofelectronic messaging ortexting. The UAS will onlybe operate during Day VMC conditions (no SVFR). F3EAwill not operate the UAS unless a minimum cloud clearance of500' below or 2,000' horizontally and 3 statute miles visibility canbe maintained from the PIC. F3EA will not operate within 5 nautical miles of an airport reference point denoted inthe current FAA Airport/Facility Directory. The flight will be aborted inthe event ofunpredicted obstacles or emergencies. 

### § 91.121 F3EA, Inc. seeks exemption from the regulation that requires the use ofan altimeter to maintain a cruising altitude orflight level. • Extent ofRelief: The F3EArequests full relieffrom the use ofan altimeter and associated altitude requirements.• Equivalent Level ofSafety: F3EA flight operations will be conducted at an altitude ofno more than 400 feet above ground level (reported in feet AGL) utilizing the onboard GPS altitude reading. F3EA will utilize a visual observer (VO) and will operate within visual line ofsight (VLOS) ofthe PIC and VO at all times. The PIC and VO will maintain the ability to communicate at all times, excluding the use ofelectronic messaging ortexting. The UAS will only be operate during Day VMC conditions (no SVFR). F3EAwill not operate the UAS unless a minimum cloud clearance of500' below or 2,000' horizontally and 3 statute miles visibility can be maintained from the PIC. The flight will be aborted inthe event ofunpredicted obstacles or emergencies. F3EAwill not operate the UAS within 5 nautical miles ofan airport unless permitted by a COA. 

### § 91.151 (a)(1) F3EA, Inc. seeks exemption from the regulationthatrequires a 30 minute fuel reserve beyondthe intended point oflanding for day VFR operations. • Extent ofRelief: F3EA seeks full relieffromthe 30 minute fuel reserve requirement. • Equivalent Level ofSafety: The F3EA PIC will not conduct the flight unless there is enoughpower available for the UAS to conduct the intended operation and to operate after that for at least five minutes or withthe reserve power recommendedbythe manufacturer. 

### § 91.405 (a) F3EA, Inc. seeks exemptionfrom the regulation that requires prescribed inspections andrepairs lAWpart 43 ofChapter I. • Extent ofRelief: F3EA seeks full relieffrom the inspection and repair requirements. • Equivalent Level ofSafety: F3EA will be responsible for maintaining and inspecting the UAS to ensure that it is in a condition for safe operation. Prior to each flight, the PIC will conduct a pre-flight inspection and determine ifthe UAS is in a condition for safe flight. F3EA will follow the UAS manufacturer's maintenance, overhaul, replacement, inspection, and life limit requirements for the aircraft and aircraft components. F3EA will comply with all manufacturer safety bulletins. F3EA will conduct a functional test flight after any maintenance or alterations to the UAS that affect the operation or flight characteristics. The functional test flight will be conductedbythe PIC and VO, will remain at least 500 feet from otherpeople, and will be conducted in such a manner so as to not pose anundue hazard to persons andproperty. 

### § 91.407 (a)(1) F3EA, Inc. seeks exemption from the regulation that restricts operation ofthe aircraft after maintenance, preventative maintenance, rebuilding, or alteration unless it has been approved for returnto service by a person authorized under chapter I of§43.7. • Extent ofRelief: F3EA seeks full relieffrom obtaining approval from an authorized person under chapter I of§43.7 to approve the UAS for return to flight.• Equivalent Level ofSafety: F3EA will be responsible for maintaining and inspecting the UAS to ensure that it is in a condition for safe operation. Priorto each flight, the PIC will conduct a pre-flight inspection and determine ifthe UAS is in a condition for safe flight. F3EA will follow the UAS manufacturer's maintenance, overhaul, replacement, inspection, and life limit requirements for the aircraft and aircraft components. F3EA will comply with all manufacturer safety bulletins. F3EA will conduct a functional test flight after any maintenance or alterations to the UAS that affect the operation orflight characteristics. The functional test flight will be conducted by the PIC and VO, will remain at least 500 feet from otherpeople, and will be conducted in such a manner so as to not pose an undue hazardto persons and property. 

### § 91.409 (a)(l) and (2) F3EA, Inc. seeks exemption from the regulation thatrequires an annual inspection and an issuance ofairworthiness certificate to operate an aircraft. • Extent ofRelief: F3EA seeks full relieffromthe annual inspection and airworthiness certificate requirements. • Equivalent Level ofSafety: F3EA will beresponsible for maintaining and inspecting the UAS to ensure that it is in a conditionfor safe operation. Priorto each flight, the PIC will conduct a pre-flightinspection and determine ifthe UAS is in a conditionfor safe flight. F3EAwill follow the UAS manufacturer's maintenance, overhaul, replacement, inspection, and life limitrequirements for the aircraft and aircraft components. F3EA will comply with all manufacturer safety bulletins. F3EA will conduct a functional test flight after any maintenance or alterations to the UAS that affect the operationor flight characteristics. The functional test flight will be conducted bythe PIC and VO, will remain at least 500 feet from otherpeople, and will be conducted in such a manner so as to not pose an undue hazardto persons and property. Benefit to the Public as a Whole F3EA's use ofa UAS to obtain aerial imagery is a safe alternative to larger manned aircraft, which can cause great damage and loss oflife inthe event ofan accident. F3EA utilizes a UAS that does notuse flammable fuel. In addition, the use ofaerial imageryto advertise commercial and residential property promotes economic growth inthe community by enhancing a marketer's ability in providing a unique perspectiveto potential buyers. Finally, F3EA is a company that is operating a UAS for commercial purposes legally inthe national airspace system. The PICs for F3EA are military trained rotary wing aviators, , who have a perfecttrack record ofaviation operations and strictly adhere to safetyprotocols inthe National Airspace System. · Summary for publication in the Federal Register "F3EA, Inc seeks an exemption from the following rules for the commercial operation of a small unmanned aerial system: 14 CFR § § 61.23 (a) and (c), 61.101 (e)(4) and (5), 61.113 (a), 61.315 (a), 91.7 (a), 91.119 (c), 91.121,91.151 (a)(1), 91.405 (a), 91.407 (a)(l), 91.409 (a)(1) and (2), 91.417 (a) and (b). Exemption from these regulations would allow F3EA, Inc to operate small unmanned aerial vehicles (55 pound or less) in areaswith limited and controlled access for the purpose ofproviding high-resolution aeria l imagery."

Please contact BryanMadden at 208-890-2937 orbmadden@F3EA.com with any questions orrequests for additional information. Thank you for the consideration ofour exemption to safely and legally operate ourUAS. Respectfully,



# ;,:-~ Tim Pearson President/CEO F3EA, Inc.