UNITED STATES OFAMERICA DEPARTMENT OFTRANSPORTATION FEDERAL AVIATION ADMINISTRATION WASHINGTON, DC

IN THE MA TIER OFTHEPETITION FOREXEMPTION OF: US DRONE GROUP, LLC, WILLIAM

### W. WILLIAMS,

### MANGING MEMBER, FORAN EXEMPTION SEEKING RELIEFFROMTHEREQUIREMENTS OFTITLE 14OFTHECODE OFFEDERAL REGULATIONS SECTIONS: 14 CPRPart 21 Subpart H 14 C.P.R. 45.23(b) 14CPR61.113 (a) & (b) 14 C.P.R. 91.7 (a) 14 CPR 91.9 (b) (2) 14 C.P.R. 91.103 14C.P.R. 91.109 14C.F. R. 91.119 14C.P.R. 91.121 14CPR 91.151 (a) 14 CPR91.203 (a) & (b) 14CPR91.405 (a) 14CPR407 (a) (1) 14CPR409 (a) (2) 14CPR417 (a) & (b) 14CPR 61.3 (a) 14CPR 61.23 (a)
CONCERNING COMMERCIAL OPERATION OF2 DJI PHANTOM 3 PROFESSIONAL SMALLAIRCRAFT SYSTEMS (sUAS) PURSUANT TO SECTION 333 OFTHEFAA MODERNIZATION AND REFORM ACT OF2012 (PUBLIC LAW 112-95) and 14 C.P.R. Part 11.81

Submitted On September 12,2015,US Drone Group, LLC, William W Williams, 1Hall Manor, Alpharetta, GA 30022. 404-433-1509



### 1EXEMPfiON REQUEST US Drone Group, LLC a Georgia corporation seeks exemption from the requirements ofthe following sections ofTitle 14Code ofFederal Regulations,Aeronautics and Space in orderto operate small UnmannedAircraft Systems (sUAS) pursuantto Section 333 ofthe 

### FAA Modernization and Reform Act of2012 (FMRA)

. 14 CFRPart 21 Subpart H 

### 14 C.P.R

.45.23(b) 14 CFR 61.113 (a) & (b) 14 C

.P.R. 91.7 (a) 14 CFR91.9 (b) (2) 14 C.P.R. 91.103 14C.P.R. 91.109 14C.F. R. 91.119 14 C.P.R. 91.121 14CFR 91.151 (a) 

### 14CPR 91.203 (a) 

### & (b) 14 CFR91.405 (a) 14 CFR407 (a) (1) 14 CFR409 (a) (2) 14CFR417 (a) & (b) 14CFR 61.3 (a) 14CFR 61.23 (a)

This exemption will permit US Drone Group,LLC to operate Unmanned Aircraft Systems (UAS) forthe commercial purposes ofconducting aerial video and photography ofconstruction sites, cell towers, real estate, search and rescue operations and agriculture inspection over certain
areas ofthe United States

. INTRODUCTION OFTHEPETITIONER William W. Williams has been an air transport pilot (ATP) for overtwenty

-five years and is currently employed full time by a major airline. He has over 13,000hours offlight time and possesses the following ratings and certifications: Airline Transport Pilot Airplane Multiengine Land Type Ratings: B-727, B-757,B-767, B-747-400, L-382 Commercial Privileges Airplane Single Engine Land Radiotelephone OperatorPermit: Restricted Medical Certificate: FAA Class I

Mr. Williams successfully completed International AirTransportAssociation (IATA) Operational Safety Auditor and Lead AuditorTraining with ARGUS/PROS

The objective ofUS Drone Group, LLC is to provide high quality imaging and aerial data collection for a variety ofcommercial,public, and residential uses, specifically targeting:

2• Construction site progress inspections
• Cell tower and crane inspections
• Agriculture monitoring and air sampling
• Real-estate marketing
• Search & Rescue Operations

BASIS FOR PETITION Petitioner, US Drone Group, LLC, pursuantto the provisions ofthe Federal Aviation Regulations (14 C.F.R. § 11.61) and the FAA Modernization and Reform Actof2012(FMRA), Section 333, Special Rules for Certain Unmanned Aircraft Systems, hereby petitions the Administrator to commercially operate two DJI Phantom 3 Professional UASs in the National Airspace System (NAS), and for an exemption from the following:

14CFR Part 21 Subpart H 

### 14 C.P.R. 45.23(b) 14CFR 61.113 (a) & (b) 14C.F.R. 91.7 (a) 14CFR 91.9 (b) (2) 14C.F.R. 91.103 14 C.F.R. 91.109 14 C.F.R. 91.119 14 C.F.R. 91.121 14CFR91.151 (a) 

### 14 CFR 91.203 (a) 

### & (b) 14CFR91.405 (a) 14CFR407 (a) (1) 14CFR409 (a) (2) 14CFR 417 (a) & (b) 14CFR61.3 (a) 14CFR 61.23 (a)
DESCRIPTION OFRELIEF SOUGIIT FOR SPECIFIC REGULATIONS


### 14 C.F.R.Part21, SubpartH: Airworthiness Certificates 14 C.F.R. §91.203 (a) (1) Subpart H,entitled Airworthiness 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 aircraft to be utilized by the Applicant, US Drone Group, LLC, an exemption from Part 21 Subpart H meets the requirements ofan equivalent level ofsafety under Part 11 and Section 333 ofthe Reform Act.The Federal Aviation Act ( 49 U.S.C.§44701 (f)) and Section 333 ofthe Reform Actboth authorize the FAA to exempt aircraft from the requirement for an airworthiness certificate, upon consideration ofthe size, weight, speed, operational capability, and proximity to airports and populated areas ofthe particular



### 3UAS. In all cases, an analysis ofthese criteria demonstrates thatthe UAS 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 orrotorcraft) operating with an airworthiness certificate without the restrictions and conditions proposed. The sUAS to be operated hereunder meets the definition ofSection 333 (6) being less than the 55 lbs. fully loaded,carries neither a pilot nor passenger, carries no explosive materials or flammable liquid fuels, and operates within an area with written or verbal approval. The sUAS will not achieve a speed exceeding 87 knots (100 miles perhour). The maximum speed for the DJI Phantom 3 is 16 meters per second or 35.791 miles per hour. Unlike other civil aircraft, operations under this exemption will be tightly controlled and monitored by the operator, and in compliance with both Federal and local public safety requirements. The FAA will have advance notice ofall operations with the required filing ofa Certificate ofWaiver.These safety enhancements,which are already greater than currently required by hobbyist, provide a greater degree of safety to the public and property owners than conventional operations conducted with airworthiness certificates issued under 14C.P.R. Part 21, SubpartH. Lastly, application ofthese same criteria demonstrates that there is no credible threat to national security posed by the UAS, due to its size, speed ofoperation, location ofoperation, lack of explosive materials orflammable liquid fuels, and inability to carry a substantial external load.


### 14 C.F.R. § 

### 45.23 (b).Markingofthe Aircraft The regulation requires: When marks include only the Roman capital letter "N" and the registration number is displayed
on limited, restricted orlight-sport category aircraft or experimental orprovisionally certificated aircraft, the operator must also display on that aircraft near each entrance to the cabin, cockpit, or pilot station, in letters notless than 2 inches nor more than 6 inches high, the words "limited," "restricted," "light-sport," "experimental," or "provisional," as applicable. Even though the UAS will have no airworthiness certificate, an exemption may be needed as the UAS will have no entrance to the cabin, cockpit or pilot station on which the word "Experimental" can be placed. Given the size ofthe sUAV,two-inch lettering will be impossible. The word "Experimental" will be placed on the fuselage in compliance with §45.29 (f). The equivalent level of safety will be provided by having the sUAV marked on its fuselage as required by §45.29 (f) where the pilot, observer and others working with the sUAV will see the identification ofthe UAS as "Experimental."Additionally, "IfFound Return To" instructions will be affixed to the UAS. The FAA has issued the following exemptions to this regulation to Exemptions Nos. 10700, 8738, 10167 and 10167A.


### 14 C.F.R. § 

### 61.113 (a) & (b): Private PilotPrivileges andLimitations: PilotinCommand. Sections 61.113 (a) & (b) limit private pilots to non-commercial operations. Because the UAS will not carry a pilot orpassengers, the proposed operations can achieve the equivalent level of safety ofcurrent operations by requiring the PIC operating the aircraft to have specific training to the sSUA along with in house training to current FAA regulations regarding our NAS and civic responsibility. Unlike a conventional aircraft that carries the pilot and passengers,the sUAS is remotely controlled with no living thing on board. The area ofoperation is controlled and restricted, and all flights are planned and coordinated in advance. These types ofsSUAs are currently being flown by hobbyist without any certifications. The level ofsafety provided by the



### 4requirements included in the US Drone Group, LLC Manual will exceed that provided by a single individual currently operating one ofthese sSUAs as a hobbyist. Therisks associated with the operation ofthe sUAS are significantly diminished from the level ofrisk associated with conventional manned operations contemplated by Part 61 when drafted, that allowing operations ofthe sUAS as requested with specific training as the operator exceeds the present level ofsafety achieved by 14C.P.R. §61.113 (a) & (b) orwhat is allowed currently by hobbyist.

14 C.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 airworthiness certificate issued for the aircraft, should this exemption be granted, no FAA regulatory standard will existfor determining airworthiness. Given the size, speed and flight restrictions placed on the UAS along with the preflight and maintenance required, an airworthiness certificate is not needed. The DJI Phantom 3will be in an airworthy condition, prior to every flight, by ensuring that the sUAS is in compliance with the operating documents (i.e., Monthly Maintenance Log, DJITraining Manual and DJI Instruction Manual), and that the aircraft is in a condition safe for flight.

14C.F.R. § 91.9 (b) (2): Civil AircraftFlightManual in the Aircraft.Section 91.9 (b) (2) provides: No person may operate a U.S.-registered civil aircraft

... (2) For which an Airplane or Rotorcraft Flight Manual is not required by §21.5 ofthis chapter, unless there is available in the aircraft a current approved airplane orRotorcraftFlight Manual, approved manual material, markings, and placards, or any combination thereof. The sUAS, given its size and configuration has no ability orplace to carry such a flight manual on the aircraft, not only because there is no pilot on board, but because there is no room or capacity to carry such an item on the aircraft. The equivalent level of safety will be maintained by keeping the flight manual at the ground control point where the pilotflying the sUAS will have immediate access to it.The FAA has issued the following exemptions to this regulation: Exemption Nos. 8607,8737, 8738,9299,9299A, 9565, 9565B, 10167, 10167A, 10602,32827,and 10700.

14C.F.R. § 91.103: Preflight actionThis regulation requires each pilot in command to take certain actions before flight to insure the safety offlight. As FAA approved rotorcraft flight manuals will not be provided for the aircraft an exemption will be needed. An equivalent level of safety will be provided as setforth in the following Operator Preflight checklist. The Operator will take all actions including reviewing weather,flight battery requirements, landing and takeoff distances and aircraft performance data before initiation offlight. PreflightProcedures
• Ensure remote controller, Intelligent Flight Battery and mobile device(s) are fully charged.
• Propellers are mounted correctly and firmly
• Micro SD card inserted,ifrequired

• Gimbal is functioning normally
• Motors can start and are functioning normally

• The DJI SO app is successfully connected to the aircraft and successfully checked.

• Ensure compass calibration is completed.



### 5RightTest
• After enduring that all ground systems are functioning normally, initiate flight test.
• In a secure area free from people, equipment, and structures perform a low altitude (less than lOft) take off, hover and land flight test.
• Verify accuracy ofaltitude readout
• Ensure emergency Return to Home (RTH) function is programmed and armed.
• After successful flight test commence operational flight.

14

### C.F.R. §91.109: 

### Flight instruction: Section 91.103 provides that no person may operate a civil aircraft (except a manned free balloon) that is being used for flight instruction unless that aircraft has fully functioning dual controls. sUASs and remotely piloted aircraft, by their design do nothave fully functional dual controls. Right control is accomplished through the use ofa control box that communicates with the aircraft via radio communications. The FAA has approved exemptions for flight training withoutfully functional dual controls for a number of aircraft andfor flight instruction in experimental aircraft. See Exemption Nos.5778K & 9862A. The equivalent level ofsafety provided by the fact that neither a pilot nor passengers will be carried in the aircraft and by the size and speed ofthe aircraft. The safety ofthose on the ground is protected by the fact that each structure that is the subject ofthe documented flight will have verbal or written authorization and will be conducted in a defined area where we can limit nonparticipating individuals.

14 

### C.F.R. §91.119: 

### Minimum Safe Altitudes (MSA): Section 91.119 establishes safe altitudes for operation ofcivil aircraft. Section 91.119 (d) allows helicopters to be operated at less than the minimums prescribed, provided the person operating the helicopter complies with any route or altitudes prescribed for helicopters by the FAA. As this exemption is for a sUAS that is a helicopter and the exemption requests authority to operate at altitudes up to 

### 400 AGL. The UAS will never operate at higher than 400AGL. Itwill, however, be operated in a restricted area with security perimeter, where buildings and people will not be exposed to operations without their pre-obtained consent. The equivalent level ofsafety will be achieved given the size, weight, speed ofthe UAS as well as the location where itis operated. No flight will be taken without the permission ofthe property owner orlocal officials. Because ofthe advance notice to the property
owner and participants in the air data collection and filming activity, all affected individuals will be aware ofthe planned flight operations. Compared to flight operations with aircraft or rotorcraft weighting far more than the maximum 55lbs. proposed herein and the lack of flammable fuel, any risk associated with these operations is far less than those presently presented with conventional aircraft operating at or below 400AGLin otherfixed wing and rotorcraft operations. In addition, the low altitude operations ofthe sUAS will ensure separation between these small-UAS operations and the operations ofconventional aircraft that must comply with Section 91.119.

14 

### C.F.R. §91.121 

### Altimeter Settings This regulation requires each person operating an aircraft to maintain cruising altitude by reference to an altimeterthat is set "

...to the elevation ofthe departure airport oran appropriate altimeter setting available before departure." As the sUAS may not have a barometric altimeter, but instead a GPS altitude read out, an exemption may be needed. An equivalent level ofsafety will be achieved by the operator, pursuantto the Operating



### 6Manual and Safety Check list, confirming the altitude ofthe launch site shown on the GPS altitude indicator before flight.

14 C.F.R. § 91.151(a): FuelRequirements for Flight inVFR Conditions Section 91.151 (a) prohibits an individual from beginning "aflight in an airplane under VFR conditions unless (considering wind and forecast weather conditions) there is enoughfuel to fly to the first point of intended landing, and, assuming normal cruising speed- (1) During the day,to fly after that for at least 30minutes; or Section 91.151(b) that prohibits a from beginning "aflight in a rotorcraft under VFR conditions unless (considering wind and forecast weather conditions) there is enough fuel to fly to the first point ofintended landing and, assuming normal cruising speed,to fly after that for at least 20minutes." The battery powering the sUAS provides approximately 23 minutes ofpowered flight. The battery life on the DJI Phantom 3 will not accommodate the flight time required to meetthis fuel requirement. Given the strictlimitations on the UAS's proposed flight
area and the location ofits proposed operations within a predetermined area, the requirements of Section 91.151 (a) and (b) are not necessary to achieve a safe flight profile.Applicant believes that an exemption from 14CFR §91.151(a) falls within the scope ofprior exemptions. Applicant believes that an equivalent level ofsafety can be achieved by limiting flights to 20 minutes or 25% ofbattery power whichever happens first. This restriction would be more than adequate to return the sUAS to its planned landing zone from anywhere in its limited operating area. Similar exemptions have been granted to other operations, including Exemptions 2689F, 5745, 10673, and 10808.

14C.F.R. §91.203 (a) and (b): CarryingCivilAircraft Certification andRegistrationThe regulation provides in part: (a) Except as provided in§ 91.715, no person may operate a civil aircraft unless ithas within itthe following: (1) An appropriate and current airworthiness certificate

.... (b) No person may operate a civil aircraft unless the airworthiness certificate required by paragraph (a) ofthis section or a special flight authorization issued under §91.715 is displayed at the cabin or cockpit entrance so that it is legible to passengers or crew. The UAS fully loaded weighs no more than 55 lbs. and is operated without an onboard pilot. As such, there is no ability orplace to carry certification and registration documents orto display them on the sUAS. An equivalent level ofsafety will be achieved by keeping these documents at the ground control pointwhere the pilotflying the sUAS will have immediate access to them, to the extent they are applicable to the sUAS.The FAA has issued numerous exemptions to this regulation. A representative sample ofother exceptions includes Exemption Nos. 9565,9665,9789,9789A, 9797,9797A, 9816A, and 10700.

14 C.F.R. §91.405 (a); 407 (a) (1); 409 (a) (2); 417(a) & (b): Maintenance InspectionsThese regulations require that an aircraft operator orowner "shall have that aircraft inspected as prescribed in subpart E ofthis part and shall between required inspections, except as provided in paragraph (c) ofthis section, have discrepancies repaired as prescribed in part43 ofthis chapter.

..," and others shall inspect or maintain the aircraft incompliance with Part43. Given that these sections and Part 43 apply only to aircraft with an airworthiness certificate,these sections will not apply to the applicant. Maintenance will be accomplished by the operator pursuant to the flight manual and operating handbook provided by DJI and further developed by Atlanta Unmanned Aircraft Systems (See Maintenance Required Petition for ReliefSection 14 CFR91.405 (a)). An equivalent level ofsafety will be achieved because these small UASs are



### 7very limited in size and will carry a small payload and operate only in restricted areas for limited periods oftime. Ifmechanical issues arise the UAS can land immediately and will be operating from no higher than400feet AGL. As provided in the Manual, the operator will ensure that the VAS is in working order prior to initiating flight, perform required maintenance, and keep a log ofany maintenance performed. Moreover,the operator is the person mostfamiliar with the aircraft and best suited to maintain the aircraft in an airworthy condition to provide the equivalent level ofsafety.

14 

### C.F.R. §61.3 

### Requirementfor certificates,ratings,and authorizations.These regulations require that no person may serve as a required pilot ofa civil aircraft unless that person holds a current pilot certificate in accordance §61.19; §61.77; §61.17; or §61.29(e). Under this grant of exemption, a PIC must hold either an airline transport, commercial, private, recreational, or sport pilot certificate.
§61.23 

### Medical certificates: Requirement and duration. This regulation requires medical certificates for all pilots operating in the NAS. Applicant is seeking reliefto the extantthat all PICs will hold a current FAA airman medical certificate ora valid U.S. driver's license issued by
a state, the District ofColumbia, Puerto Rico, a territory, a possession, orthe Federal government.
PUBLIC INTEREST The integration ofsUAS in the National Airspace System (NAS) and the proliferation ofits commercial application is based on its inherent safety,multi-faceted applications and significantly reduced cost compared to largerfixed wing and rotor aircraft

. Historically, rotorcraft and fixed wing aircraft have been able to accommodate some ofthe aerial data collection methodologies required by various industries. They are, however, very expensive and cannot accommodate all the aerial data collection requirements. Proximity to the subject is crucial for viable data collection, particularly with respect to safety inspections. thefollowing applications would benefit significantly from UAS based aerial applications.


# • •
i 

### • • Construction site progress inspections Cell tower and crane inspections Agriculture monitoring and air sampling Real-estate marketing Search & Rescue Operations

Construction sites and cell tower/crane assembly and inspection. These industrial disciplines and applications are inherently dangerous. In orderto ensure the highest degree ofsafety possible the assembly and construction ofthese devices requires meticulous attention to detail. A significant contribution to safety would be provided by conducting close proximity inspections ofthe assembly, construction, and wear and tear ofthis equipment. Agriculture presents its own setofcriteria for relevant aerial data collection. Maintaining the health and safety ofagriculturally based food supplies requires monitoring crops for both ground and airborne insect infestation. The low altitude collection ofair samples contributes significantly to relevant data collection in order to better address these challenges.



### 8Real Estate marketing has successfully used airborne photography to provide a much more complete assessment ofproperty. Dueto the cost ofusing largerfixed wing and rotor craftit has been cost prohibitive for use on smaller properties. UAS video applications would expand the marketing options for property owners and stimulate real estate sales across a wider spectrum of properties.
Search and rescue has historically utilized airborne surveillance to expeditiously locate victims, provide damage assessment, provide direction to first responders, assess efficacy ofremediation efforts and increase overall situational awareness. The safe, costeffective and rapid deployment ofsUAS would provide a level ofdata collection not before possible and enhance the effectiveness ofthe rescue efforts.

The use ofconventional rotorcraft and fixed wing aircraft in these disciplines would be extremely dangerous. Using manned aircraft at extremely low altitudes poses a threat to the public through potential catastrophic loss or crash of such a large aircraft loaded with explosive hydrocarbon based fuel. The sUAV is a much safer, more economical and viable tool to address the data collection requirements ofthese disciplines.

The benefit ofgranting theses exemption falls within the intended reliefofSection 333(c) ofthe FAA Modernization and Reform Act of2012 to safely integrate sUAV onto the National Airspace System while promoting appropriate safe commercial operations.

SAFETY This exemption request for use ofsUAS is subjectto Extensive Operational and Safety Measures. Limitations and conditions to which US Drone Group,LLC. agrees to be bound when conducting commercial operations under a FAA issued exemption include at a minimum: Safety Requirements 1. The sUAS Pilot in Command (PIC) shall possess either an airline transport, commercial, private, recreational, or sport pilot certificate. 2. The PIC will hold a current FAA airman medical certificate or a valid U.S. driver's license issued by a state,the District ofColumbia, Puerto Rico, a territory, a possession,
orthe Federal government. 3. The PIC shall be trained in the operation ofthe specific make and model ofthe sUAS being piloted and successfully completed all training required. The PIC shall have accumulated and logged, in a manner consistent with 14 CPR61.51 (b), a minimum of five hours as sUAS pilot operating the make and model ofsUAS to be utilized for operations under the exemption. Three take-offs and three landings in the preceding 90 days must be accomplished to maintain currency. The PIC shall have accumulated and logged, in a manner consistent with 14CFR61.51 (b), a minimum of200flight cycles and 25 hours oftotal time as a sUAS rotorcraft pilot and at leastfive hours logged as a sUAS pilot with a similar sUAS (multi rotor or helicopter). Priordocumented flight experience that was obtained in compliance with applicable regulations may satisfy this requirement. Training, proficiency, and experience-building flights can also be conducted



### 9under this grant ofexemption to accomplish the required flight cycles andflight time. During training, proficiency and experience-building flights, all persons not essential for flight operations are considered non-participants, and the PIC must operate the sUAS with appropriate distance from non-participants in accordance with 14 CFR91.119. 4. The sUAS Safety Observer (SO) shall meet all training requirements and be responsible for all ofhis/her duties as setforth by the US Drone Group,LLC sUAS Operating Manual. The PIC and SO will be designated before each flight. 5. The minimum crew for each flight operation will consist ofthe sUAS PIC and SO

. The PIC and the SO shall always be within visual line ofsight (VLOS) ofeach other and in direct verbal communications at all times. 6. Safety Briefings shall be conducted before each day's activities to include, butnotlimited to the designated roles ofthe PIC and SO. 7. All sUAS flown under this exemption shall be less than 55 pounds including aircraft and payload. This exemption requests permission only with respect to the specific use ofthe DJI Phantom 3 Professional sUAS which weigh less than 3 pounds including payload. 8. The radio frequency spectrum used for operation and control ofthe sUAS shall comply with the Federal Communications Commission (FCC) or other appropriate government oversight agency requirements. 9. Maximum speed shall be less than 50knots. 10. The sUAS shall be designed, should it lose communications orlose its GPS signal,to return to a pre-determined location (Return To Home, RTH feature) within the Operations Area and land orbe recovered in accordance with the US Drone Group,LLC sUAS Operating Manual. 11. All sUAS shall be maintained in accordance with the manufacturer's recommendations and the US Drone Group, LLC. sUAS Operating Manual and Inspection Program. 12

. US Drone Group, LLC. will document and maintain a record ofthe sUAS maintenance, preventative maintenance, alterations, and status ofreplacement, overhaul component parts, and the total time in service ofthe sUAS. These records will be maintained at the principle base ofoperations for the life ofthe aircraft or as required by Federal Aviation Regulations. 13. US Drone Group, LLC. shall comply with all manufacturer Safety/Service Bulletins or equivalent pertaining to the sUAS aircraft. The PIC shall perform a preflightinspection ofthe sUAS, controller and ground station priorto each flight to ensure itis operational with no discrepancies. Ifthe preflight inspection reveals discrepancies, repairs or maintenance shaH be performed priorto flight. The sUAS will only be operated ifall systems are operating per manufacture's specifications and in a discrepancies free condition. 14. Maintenance orrepairs that may affect the sUAS operation orflight characteristics shall undergo a functional testflight when required in accordance with manufacture's recommendations and the US Drone Group,LLC. sUAS Operating Manual. This functional testflight shall be recorded in the sUAS's records. Ifthe functional testflight is completed successfully,the sUAS can return to service by the PIC. 15. US Drone Group, LLC. shall follow the manufacturer's sUAS maintenance, overhaul, replacement, inspection, and life limit requirements. When not provided by the manufacturer, aircraft maintenance,component, overhaul, replacement, and inspection

10maintenance requirements shall be established and included in the US Drone Group, LLC. Operating Manual and Inspection Program. 16. All sUAS shall be identified by serial number,registered in accordance with 14CFRPart 47, and have identification (N-Number) markings in accordance with 14 CFRPart45, Subpart C, except with respect to the size ofthe markings. Markings shall be as large as practical. Additionally,there will be the name address and telephone number ofUS Drone Group, LLC. and "IfFound Return To" instructions affixed to the sUAV. 17

. All required permissions and permits shall be obtained from territorial, state, county or cityjurisdictions,including local law enforcement or other appropriate governmental agencies. Atleast three days before a scheduled operational flight, US Drone Group, LLC. shall submit a written plan ofactivities to the local Flight Standards District Office (FSDO) withjurisdiction over the area ofthe proposed flight. The 3 day notification may be waived with the concurrence ofthe FSDO. The plan ofactivities shall include at least the following:
• Dates and times for all requested flights.
• Name and phone number ofUS Drone Group, LLC. sUAS Flight Operations representative

. • Name, certificate and phone number ofPIC responsible.
• Make,model and N-Number ofsUAS to be used.
• Statementfrom US Drone Group,LLC. that it will be operating on approved privately owned and operated property; the list ofthose who gave permission shall be made available to the inspector upon request.
• Description offlight activity, including maps ordiagrams ofany area over which flights will be conducted,the relationship ofthat areato any nearby city,town, etc., and the altitudes essential to accomplish the operation.
• Signature ofthe exemption-holderorrepresentative 18. Documents required under 14CFR 91.9 and 91.203 shall be readily available to the PIC anytime the aircraft is in operation.These documents shall be made available to the Administrator or any law enforcement official upon request. US Drone Group, LLC shall obtain an AirTraffic Organization (ATO) issued Certificate ofWaiver orAuthorization (COA) prior to conducting any operations under this grant ofexemption. US Drone Group, LLC shall also request a Notice to Airman (NOTAM) not more than 72hours in advance, but not less than 48 hours priorto the operation. US Drone Group,LLC shall obtain the consent ofall persons involved in the operation and ensure that only consenting persons be allowed within 500feet ofthe Operations Area. 19. The sUAS shall not operate within 5 nautical miles ofthe geographic center ofany airport as denoted on the current FAA published aeronautical chart unless a letter of agreement with that airport's management is obtained, and the operation is conducted in accordance with a NOTAM as required by the operator's COA. This letter ofagreement with the airport management shall be made available to the Administrator upon request. 20. The sUAS will only operate within the lateral boundaries ofapproved privately owned and operated property. An Operations Area within those boundaries will be established for each flight. These areas will be free ofunnecessary hazards orrisks and nonparticipating personnel. The sUAS shall only operate within a pre-defined Operations Area that shall be thoroughly inspected by the PIC for buildings, overhangs, obstacles,



### 11wires, poles,people, vehicles, sun angle, shadows, glare, reflective surfaces, clouds, smoke, and terrain among other potential hazards. 21. Flights shall be conducted during day visual meteorological conditions (VMC) only. In addition, the sUAS shall not be operated less than 500feet below or less than 2,000feet horizontally from a cloud or when the visibility is less 3 statute miles from the PIC. sUAS operations shall not be conducted during night, as defined in 14 CFR 

### 1.1. iii) Flights shall not be conducted under special visual flight rules (SVFR). 22. Flights shall be operated at an altitude ator below 400feet AGL, as indicated by the procedures specified in the US Drone Group, LLC. Operating Manual. 23. The PIC shall be prohibited from operating the sUAS from any moving device or vehicle. 24. The sUAS shall be operated within VLOS ofthe PIC. 25. The PIC shall maintain VLOS without the aid oftelescopes, cameras or other devices. The PIC shall maintain VLOS with their own vision, which includes the use of eyeglasses or corrective lenses as specified on the PIC's medical certificate. 26. The sUAS shall remain clear and yield the right ofway to manned operations and activities at all times including, but not limited to, ultralight vehicles, parachute activities, parasailing activities, hang gliders, etc. 27. US Drone Group, LLC. will require the PIC and the SO to have successfully completed a qualifications process which will include ground and flight training, as outlined in the US Drone Group, LLC. Operating Manual. I.ThePIC's primary responsibility while inflight is the safe operation ofthe sUAS

.

### J. The PIC and the SO may not switch roles during the flight. 28. DJI Phantom 3 Professional operations shall be completed within 20 minutes offlight time or with 25% power remaining whichever occurs first. Ifthe flight time exceeds 25% ofbattery life an aural warning shall sound signifying that the aircraft must be landed immediately.

MAINTENANCE 14CPR91.405 (a)

- Maintenance Required. Each owner or operator ofan aircraft- (a) Shall have that aircraft inspected as prescribed in subpart E ofthis part and shall between required inspections, except as provided in paragraph (c) ofthis section, have discrepancies repaired as prescribed in part43 ofthis chapter. This section and Part43 apply only to aircraft with an airworthiness certificate,therefore these sections will not apply. In the absence ofregulatory provisions dealing with sUAS operation for maintenance required, US Drone Group, LLC will establish the sUAS Operating Manual, Inspection Program and Manufacturers Maintenance Recommendations for maintenance required.

1. Maintenance will be accomplished by US Drone Group,LLC. in accordance with manufacturer's recommendations and the US Drone Group, LLC. Operating Manual and Inspection Program. 2. Maintenance,preventive maintenance, rebuilding and alteration will be successfully accomplished by trained personnel orfactory authorized maintenance facilities. 3. Functional test flights will be performed by the PIC when required. The sUAS shall only be returned to service when this functional testflight is successfully completed. An



### 12appropriate log entry shall be made in the sUAS'sAircraft Flight Log thatthe aircrafthas successfully completed a functional testflight and is authorized for return to service. 4. The US Drone Group, LLC Operating Manual details how to enterin the maintenance log scheduled and unscheduled maintenance orfunctional testflights that are performed. 5. US Drone Group, LLC shall only operate its sUAS with all systems functioning per manufactures specification in a discrepancy free condition. 6. These records will be maintained atthe principle base for operation for the life ofthe aircraft or as required by Federal Aviation Regulations. 7. US Drone Group, LLC and the AircraftManufacturer (DJI) are the mostfamiliar with the aircraft and best suited tomaintain the aircraftin an airworthy condition.These maintenance procedures allow for an equivalent level ofsafety to be achieved due to the limited size ofthe aircraft, the scope and area ofoperations.

FEDERAL REGISTER A summary for the Federal Register is provided in the section "Description ofReliefSought for Specific Regulations" starting on pages 3-6 copied here for continuity.

14CFRPart 21 SubpartH 14C.F.R. 45.23(b) 14CFR 61.113 (a) & (b) 14C.F.R. 91.7 (a) 14CFR91.9 (b) (2) 14C.F.R. 91.103 14C.F.R. 91.109 14C.F. R. 91.119 14 C.F.R. 91.121 14CFR91.151 (a) 14CFR91.203 (a) & (b) 14CFR91.405 (a) 14CFR407 (a) (1) 14CFR409 (a) (2) 14CFR417 (a) & (b) 14CFR 61.3 (a) 14CFR 61.23 (a)

UNMANNEDAIRCRAFT SYSTEMS TECHNICAL INFORMATION



### 13•

US Drone Group, LLC seeks an exemption to operate two DJI Phantom 3 Professional sUAS for compensation orhire within the National Airspace System (NAS). The DJI Phantom 3 Professional is a vertical takeoffand landing (VTOL) Unmanned Aircraft (UA) with a Ground Control Station (GCS) utilizing electronic tablet or smartphone systems. The DJI Phantom 3 Professional has the following specifications:

Aircraft Weight (Battery, Camera & Propellers Included)

Max. Ascent Speed Max. Descent Speed Max. Speed Max. FlightAltitude Max. FlightTime Operating Temperature GPS Mode
Gimbal Controllable Range Vision Positioning Velocity Range Altitude Range Operating Range Operating Environment

Camera Sensor M (total pixels: 12.76 M) Lens f/2.8 ISO Range Electronic Shutter Speed Image Max. Size 1280 g (a maximum gross weight of approximately 3 pounds 11 ounces, diameter of 16 inches) 5 m/s 3 m/s 16 m/s (ATTI mode, no wind) 6000m Approximately 23 minutes 

## ooc to 40°C GPS/GLONASS

Pitch:

- 90° to 

### + 30°



### < 8 m/s (2 m above ground) 30cm-300 em 30cm-300 em Brightly lit (lux> 15) patterned surfaces

Sony EXMOR 112.3" Effective pixels:12.4

FOV 94° 20mm(35mm format equivalent ) 100-3200(video) 100-1600(photo) 8s -1/8000s 4000 X 3000

14Still Photography Modes Auto Exposure Bracketing (AEB): lapse Supported SD CardTypes

Video Recording Modes

Max. Bitrate OfVideo Storage Supported File Formats MP4/MOV (MPEG-4AVC/H.264) OperatingTemperature Range

Remote Controller Operating Frequency Transmitting Distance Video OutputPortUSB OperatingTemperature Range Battery Mobile Device Holder TransmitterPower(EIRP) Working Voltage Charger Voltage Rated Power
Battery Intelligent HightBattery Capacity Voltage BatteryType Energy NetWeight OperatingTemperature Max. Charging Power Single shootBurst shooting: 3/517 frames 3/5 bracketed frames at 0.7EV BiasTimeMicro SD Max. capacity: 64GB. Class 10
orUHS-1 Rating required UHD: 4096x2160p 24/25, 3840x2160p24/25/30PHD: 1920x1080p 24/25/30/48/50/60 HD: 1280x720p 24/25/30/48/50/60 60Mbps FAT32/exFAT Photo: JPEG, DNGVideo:



## ooc to 40°C 54© 2015 DJI.

2.400 GHz-2.483 GHz 2000 m (OutdoorAnd Unobstructed)

0°C-40°C 6000mAh LiPo 2S Tablets and smartphones FCC: 20 dbm; CE: 16 dbm 1.2A @7.4V

17.4V lOOW

( PH3-4480 mAh-15.2 V) 4480mAh 15.2V LiPo4S 68Wh 365 g 

### -lO"C- 40"C 100W

The Phantom 3 Professional is equipped with four main rotors; driven by LithiumPolymer battery powered electric motors. The DJI Phantom 3 Professional UAS thatwill be operated by US Drone Group, LLC will be registered in accordance with 14C.F.RPart47.33 Aircraft Registration, and marked in accordance with the petitioned exemptionfor 14C.P.R. 45.23(b), Identification and Registration Marking.



### 15CONCLUSION US Drone Group, LLC believes thatthe criteria provided in Section 333 ofthe FMRA regarding size, weight, speed, operating capabilities,proximity to airports and populated areas, operation within visual line ofsight, and national security have been satisfied. US Drone Group,LLC is committed to follow these criteria in a safe and professional manner. I respectfully request the granting ofthis exemption request. Please contact William W.Williams,US Drone Group, LLC with any questions orfor more information. Respectfully,

WilliamW Williams Managing Member US Drone Group, LLC 404.433.1509 2.bill.williams@gmail.com

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