[Type text]

U.S. Department of Transportation, Docket Operations West Building Ground Floor, Room w12

- 140 1200 New Jersey Avenue, SE., Washington, DC 20590 Scott Rokeby President Daedalus Imaging, LLC 1324 North Willow Avenue Broken Arrow, OK 74012 918

- 346

- 0832 DaedalusImage@gmail.com

Re: Exemption Request under Section 333 of the FAA Reform Act and Part 11 of the Federal Aviation Regulations

Dear Sir or Madam:

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the “Reform Act”) and 14 C.F.R. Part 11, Daedalus Imaging, LLC seeks an exemption from Federal Aviation Regulations (“FARs”) detailed below for the following described Unmanned Aeri al System calle d in this application the Daedalus Imaging Unmanned Aerial System (DI UAS) , whi ch includes an
Unmanned Aircraft (UA) and ground station

- based equipment and crew:

THE UNMANNED AIRCRAFT (UA):

 A light weight, battery operated, 4 motor rotorcraf t commonly known as a "quadcopter" that takes off and lands vertically, built on a frame manufactured by Tarot

, Ironman650 model, modified by the applicant to carry the following equipment in flight;

 An on

- board flight computer with GPS navigation and loc ation 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 deliv ers flight data from the on

- board flight computer to the on

- board radio transmitter including altitude AGL, horizontal and vertical speed, compass direction of flight and direction back to its launch site;

 A 600mW, 5.8GHz on

- board radio transmitter that t ransmits live video from the on

board camera plus all the flight data from the telemetry system described above;

THE GROUND STATION

- BASED PART OF THE SYSTEM:

 A Pilot In Command (PIC)/Operator in operational control of the flight operation from beginning to end, who controls the UA while the aircraft is in flight;[Type text]

 A 100mW, 2.4GHz radio transmitter/controller operated by the PIC /Operator to control the UA while in flight;

 A radio receiver to receive live video and telemetry data from the onboard camera and
fl ight computer and displays this information on a screen for PIC /Operator reference (NOT to be used for First

- Person

- View flying);

 A co mputer running Mission Planner software to log telemetry data.

The requested exemption would support an application for a commercial Certificate of Authorization to use the above UAV system for aerial video and photogr aphy primarily of real property and infrastructures.

The UA , powered by batteries is smaller, lighter and more maneuverable than larger aircraft powered by internal combustion engi nes. It operates at much lower altitudes and with no persons onboard, eliminating the risk to life onboard and greatly reducing the overall likelihood of death or bodily injury. This result s in dramatic increases in safety compared to methods of
obtainin g the same photographs and video from a similarly capable camera system carried aloft by a traditional rotorcraft required to be crewed by at least a pilot and camera operator.

The small payload and short flight times, often less than 30 minutes means little to no risk of national security.

Aerial photography is often the preferred means by which buyers and sellers of real property can most fully evaluate the merits of a transaction and so has value to both buyers and sellers. This is traditionally acc omplished by hiring a two

- seater helicopter which is both cost prohibitive and a nuisance to surrounding properties and their owners/inhabitants. The benefits of reduced cost, improved presentation value and less obtrusive means of production ensure a hig her value and greater benefit to our customers.

Further, infrastructure inspections often require the same helicopter and crew as real estate transactions, but with the requirement the flights are made much closer to the infrastructure being inspected . This creates an even greater risk to the lives of the crew and increases the risk

to people and property on the ground. The DI UAS decreases these risks dramatically by
removin g the crew from the air and using a significantly lighter a ircraft.

Additionally, Daedalus Imaging would request we be allowed to lend our technology and expertise to benefit local first responders who may find our system beneficial . These may include fire fighters, local p olice and sheriff departments, forestry service, et al., while remaining under the restriction s and limitations cited in this exemption request.[Type text]

The DI UAS will be operated with the following restrictions:

a) No flight will be made with a UA having a gross we ight greater than 55 pounds; b) All operations must b e conducted at an altitude no greater than 400 feet AGL, at an airspeed not to exceed 25 knots, and no further than 3/4 of a mile from the

PIC /Operator ; c) All flights over privately owned land must have the p ermission of the property owners over which the intended flight path is to be executed; d) All PICs /Operators used by Daedalus Imaging wi ll have accumulated and logged in accordance with FAR Part 61.51 (b) , a minimum of 100 flight cycles and 25 hours of total
time as PIC /Operator of UAS and at least 10 hours of PIC time logged in a rotorcraft UA of similar type; e) All required permits will be obtained from state and local agencies prior to operation; f) The UA will not be operated at air shows; g) The UA will not be operated directly over open

- air assemblies of people; h) The UA will not be operated over heavily trafficked roads; i) The UA will not be operated within Class A airspace, and any flights occurring within Classes B, C, D, or E airspace require prior contact and coordination with Air Traffic
Control (ATC). Operations in Class G airspace further than three miles from the nearest controlled airport will not require notifying ATC ; j) Operations are restricted to day time only and conditions equivalent to VFR; k) In cases where a visual observer (VO) is used, such as heavily forested properties, the
PIC /Operator will brief the VO on the intended operation and risks prior to to the first flight at each new location, or new intended operation at the same location; l) The PIC /Ope rator will brief the property owners of the intended flight operation and any risks involved; m) No flight may be made without a Pre

- Flight Check performed by the PIC /Operator from a checklist to ascertain the UA is in safe flying condition. (See Addendum A)

The PIC /Operator will meet the requirements outlined in FAA Policy N 8900.227 Section 16 personnel qualifications. Additionally the PIC /Operator will perform maintenance on the UAS and record all maintenance activities in their pilot log book.

We submi t that the combination of the UA's light weight, flight performance and ability, fully qualified flight crew, and strict adherence to the restrictions and limitations created by the guidance found in 8900.227, and under all restrictions listed in ( a) thru ( m) above , the FAA can have full confidence that Daedalus Imaging operations will be conducted with an equivalent or greater level of safety than manned aircraft performing the same missions.[Type text]

The regulations from which the exemption is requested are listed below, each with an associated Addendum page where on which may be found equivalent or greater level s of safety.

- 14 CFR 21

- 14 CFR 91.203

- 14 CFR 45.23

- 14 CFR 45.29

- 14 CFR 91.9

- 14 CFR 61.113

- 14 CFR 61.133

- 14 CFR 91.109

- 14 CFR 91.119

- 14 CFR 91 .121

- 14 CFR 91.151

- 14 CFR Subpart E 91.401 thru 91.417 FAA Policy 8900.227, 16 (c)(4) and (e)(1) Addendum Page 1 Addendum Page 2 Addendum Page 2 Addendum Page 2 Addendum Page 3 Addendum Page 3 Addendum Page 3 Addendum Page 4 Addendum Page 4 Addendum Page 4 Addendum Page 4 Addendum Page 5 Addendum Page 5

Contact information of the applicant: Daedalus Imaging LLC Scott Rokeby

- President
Ph. 918

- 346

- 0832 Email: srokeby@gmail.com

We understand that this initial contact may be followed by a request from the FAA to modify or alter any part or segment of the exemption request and look forward to working with the FAA to meet or exceed an equivalent level of safety.

Best Regards,

Scott Rokeby, President Daedalus Imaging LLC
Private Pilot Certificate No. 27933241 

## Addendum

Exemption Request and Equivalent Level of Safety

Daedalus Imaging, LLC, requests an exemption from the following regulations as well as any additional regulations that may technically apply to the operation of the DI UAS:



### 14 CFR Part 21, Subpart H: Airworthiness Certificates This part establishes the procedures for the issuance of an airworthiness certificate. While the FAA continues to work to develop airworthiness standards for Unmanned Aerial Systems, we request an experimental certificate be issued for the DI UAS System u nder either or both of the following provisions: 21.191 Experimental certificates. Experimental certificates are issued for the following purposes: (a) Research and Development. Testing new aircraft design concepts, new aircraft equipment,
new aircraft i nstallations, new aircraft operating techniques, or new uses for aircraft. (b) Showing compliance with regulations. Conducting flight tests and other operations to show compliance with the airworthiness regulations including flights to show compliance for issuance of type and supplemental type certificates, flights to substantiate major design changes, and flights to show compliance with the function and reliability requirements of the regulations.

Since the experimental certificate can be used for comme rcial purposes such as market surveys, sales demonstrations, and customer crew training, we would expect that an experimental certificate would permit our commercial purpose as well.

The aircraft will not carry persons or property, will not carry fuel, a nd will only fly under strict operational requirements. Combined with the UA’s light weight, being constructed primarily of carbon fiber and plastic, we propose that the UA will be at least as safe, if not safer, than a conventionally certificated aircraft performing the same mission.

If an experimental airworthiness certificate is not appropriate for this application, then we request an exemption of 14 CFR Part 21, Subpart H, and the requirement for an airworthiness certificate in general, citing the equ ivalent level of safety outlined in the previous paragraph.2



### 14 CFR 90.203(a) and (b) Civil aircraft: Certifications required The regulation provides that an airworthiness certificate, with the registration number assigned to the aircraft and a registrati on certificate must be aboard the aircraft. Additionally, subparagraph (b) provides that the airworthiness certificate be "displayed at the cabin or cockpit entrance so that it is legible to passengers or crew."

At a maximum gross weight of 5.3 pounds, t he UA is too small to carry documentation, does not have an entrance, and is not capable of carrying passengers or crew. To obtain an equivalent level of safety and meet the intent of 91.203, we propose that documents deemed appropriate for this aircraft b y the FAA will be co

- located with the crew at the ground control station and available for inspection upon request. In order to identify the aircraft, we propose
that the equivalent and appropriate information found on airworthiness and registration
certif icates be permanently affixed to the aircraft via placard containing the following information plus the word “EXPERIMENTAL” to satisfy the requirement of 14 CFR 45.23, which follows immediately after the proposed placard description below:

EXPERIMENTAL As sembled by: Daedalus Imaging, LLC 1324 N Willow Ave Broken Arrow, OK 74012 Unmanned Aerial System No. 001 If found please contact: (918) 346

- 0832



### 14 CFR 45.23 Display of marks; general and 45.29 Size of marks

These regulations provide that each aircraft must display "N" and the aircraft's registration number in letters at least 3 inches high. Additionally, the aircraft must display the word "EXPERIMENTAL" in letters at least 2 inches high near the entrance to the cabin, cockpit, or pilot station. The UA does not have an entrance in which the word "EXPERIMENTAL" can be placed, and may not have a registration number assigned to it by the FAA.

We propose to achieve an equivalent level of safety by including the word "EXPERIMENTAL" in the placard on the top of the aircraft, as shown above, where the PIC /Operator and others in the vicinity of the aircraft while it is preparing for launch will be able to see the designation. Additionally, we feel that the permanent placard discussed in the previous paragraph will provide the aircraft's registration information at th e ground station. Finally, we will display at the ground station a high contrast flag or banner that contains the words "Unmanned Aircraft Ground Station" in letters 3 inches high or greater. Since the aircraft will operate within 3/4 NM3

of the ground stat ion, the banner should be visible to anyone that observes the aircraft and chooses to investigate its point of origin.



### 14 CFR 91.9 Civil aircraft flight manual, marking, and placard requirements This regulation provides that no person may operate an aircr aft unless a current, approved flight manual is in the aircraft. We assume that the intent of this 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 obtain an equivalent level of safety and meet the intent of 91.9, we propose that a current, accepted UA F light Manual (Appendix A) must be available to the crew at the ground station anytime the aircraft is in, or preparing for, flight.



### 14 CFR 61.113 Private pilot privileges and limitations: Pilot in Command and 61.133 Commercial pilot privileges and limitat ions 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 aircraft does not carry passengers or property for compensation or hire.

Our proposed operations require that the PIC /Operator must either

1. Hold a pr ivate pilot c ertificate issued by the FAA, and have logged 25 hours of flight experience in this type of UA, or

2. Meet the requirements of 8900.227 para 16(c)(2)(c) "Operations without a pilot certificate" in which the PIC is required to complete "FAA priva te pilot ground instruction" and pass "the FAA Private Pilot written examination." Since there are currently no means available for the pilot of a UAS to gain the experience in an equivalent category and class in order to apply for a commercial pilot's lic ense, we propose to generate an equivalent level of safety by requiring our pilots to complete, at a minimum, FAA private p ilot ground instruc tion and pass the FAA private p ilot written examination in addition to completing the private pilot requirements. Since the aircraft cannot carry passengers or property, we feel we meet the intent of 61.113 Subparagraph (b) even though the intent of this application is to conduct a business.4



### 14 CFR 91.109 Flight instruction; Simulated instrument flight and certain f light

tests 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."

Part of the DI UAS ground

- based control station consists of a small hand

- he ld radio tr ansmitter and in the form of a "buddy box" input jack located on the rear of the controller in which a
second hand

- held radio transmitter can be connected for use by the student while overriding control remains with the primary radio held by the instructor. With both student and instructor having "hands

- on" the controls during flight, we feel that this technique meets the intent 91.109 and provides an equivalent level of safety.



### 14 CFR 91.119 Minimum safe altitudes: General The regulation state s 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 of 400 feet AGL, we cannot comply with this requirement.

In order to provid e an equivalent level of safety, when fly ing over private property
, the permission of the owner /s of the property shall be obtained . The aircraft will not be operated over congested areas or over any open air assembly of persons. The property owner /s will be
briefed on the planned route of flight and the associated risks to persons and property on the ground. The aircraft will be operated at a low altitude allowing, if a power unit fails, an emergency landing without undue hazard to persons or prope rty on the surface. Therefore we maintain that due to the small size of the UA, the hazard to persons, vehicles and structures is minimal compared to manned aircraft, which should be considered in granting the exemption.



### 14 CFR 91.121 Altimeter settings

T he regulation requires that aircraft shall maintain cruising altitudes by reference to an altimeter setting available within 100 NM of the aircraft.

The UA will always fly below 400 feet AGL and will not need to maintain cruising altitudes in order to pr event conflict with other aircraft. An Above Ground Level altimeter measurement above the takeoff point is transmitted via radio from the UA on

- board computer to the display screen held by the PIC /Operator , providing a constantly updated AGL readout.



### 14 C FR 91.151 Fuel requirements for flight in VFR conditions The regulation provides that no person may begin a flight in an airplane under day

- VFR5

conditions unless there is enough fuel to fly to the first point of intended landing and to fly after
that for a t least 30 minutes.

We feel the intention of this paragraph is to provide an energy reserve as a safety buffer for delays to landing. The UA is battery operated and the maximum duration of flight from a single battery charge is 40 minutes with a 20% reserve. Since the aircraft will never fly more than 3/4 NM from the point of intended landing, a full battery charge at launch will ensure that we meet the reserve energy requirement of this paragraph. We request an exemption to the wo rd "fuel" and ask for an equivalent interpretation with the word "energy".



### 14 CFR Subpart E (91.401 thru 91.417) Maintenance, Preventative Maintenance,
Alterations The regulation provides that the operator is primarily responsible for maintaining the airc raft 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.
It is our intention t hat the PIC /Operator perform minor maintenance and inspection of the
aircraft and "be authorized to approve the aircraft for return to service." As provided in the Pre

Flight Checklist in Appendix A, the PIC /Operator will ensure that the aircraft is in an airworthy condition prior to every flight and in addition conduct deta iled inspections after every five hours of flight. Maintenance performed by the PIC /Operator is limited to repairing small cracks, replacing a propeller, checking electrical connections and updating software and firmware for
the on

- board computer. As this UAS was fully constructed from readily available parts by the President of Daedalus Imaging, any repairs beyond the scope allowed by the PIC/Operator will be performed by the President o f DI LLC. This may include such items as replacing motors, recalibrating the onboard flight computer, replacement of faulty electronic speed controllers (ESCs) , or replacement of various antenna and transmitters. In every case maintenance performed will be document ed in accordance with 91.417. We feel that due to the size, construction, and sim plicity of the aircraft, the this will ensure an equivalent level of safety.



### 8900.227 Paragraph 16(c)(4) PIC Medical

This policy provides that the PIC must have a valid FAA second

- class medical certificate issued under part 67 in order to perform as a pilot or observer.

The UA maximum gross weight is 5.3 pounds, it is constructed of carbon fiber and plastic and the PIC /Oper ator is not on board. The PIC/Operator is required to be in VLOS. Given the unlikely event th at the PIC /Operator becomes medically incapacitated while the aircraft is in flight, the UA will return autonomously to the site of launching and land without crew intervention. Theref ore, requiring the PIC /Operator to meet the same medical requirements as a commercial6

pilot carrying passengers in a large aircraft is an unnecessary burden.

We propose that the minimum m e dical requirements for the PIC/ Operator be vis ion corrected
to 20/20 and a valid, state issued driver's license. The 20/20 vision requirement will ensure that the PIC/Operator can see and avoid air traffic; a light sport pilot with a drivers license is medically qualified to operate a much larger vehi cle.



### APPENDIX A

- FLIGHT MANUAL

FLIGHT RESTRICTIONS a) No flight will be made with a UA Gross weight exceeding 55 pounds; b) All operations not performed in conjunction with local ATC must occur in FAA Class G airspace at no more than 400' AGL , at an airspeed of no greater than 25 knots and no further than 3/4 mile from the PIC /Operator ; c) Flights done in air space Classes B, C, D, and E require prior coordination with local ATC. d) No flights are permitted in Class A airspace. e) No flight will be made over people tha t are not directly involved in the operation of the DI UAS; f) The PIC /Operator must have accumulated and logged, in a manner consistent with 14 CFR § 61.51 (b), a minimum of 100 flight cycles and 25 hours of total time as a UA rotorcraft pilot and at least t en hours logged as a UA pilot with a similar UA type; g) All required permits will be obtained from state and local government prior to operation; h) The DI UAS will not be operated over densely populated areas; i) The DI UAS will not be operated at air shows; j) The DI UAS will not be operated over any open

- air assembly of people; k) The DI UAS will not be operated over heavily trafficked roads; l) The DI UAS will not be operated within 3 NM of an airport or heliport without first notifying ATC of the intended operation ; m) Operations will be restricted to day time only and weather conditions equivalent to VFR; n) The PIC /Operator will brief the property owner /s about the operation and risk before the first flight at each new location; 

### o) No flight may be made without a successful Pre

- Flight Inspection by the PIC /Operator before each operation to ascertain that the UA is in a condition safe for flight. 

### p) All flights will be made with Failsafe mode enabled.7



### PRE

- FLIGHT CHECKLIST

1. Use voltmeter to determine that UA battery is fully charged in order to prevent unexpected premature descent; 

### 2. Check all wiring connections are tight; 

### 3. Check all propellers are undamaged and no cracks exist in any structural members of the UA; 

### 4. Turn on radi o controller, check for adequate voltage, set it to connect to the UA, move all control switches to forward or down position and throttle control stick full back position; 

### 5. Connect UA main battery, check for radio contact with UA’s radio receiver; 

### 6. Verify s olid blue LED on flight computer to indicate GPS and compass lock ; 

### 7. Turn on transmitter, gimbal and camera.



### TO REGAIN CONTROL AFTER LOST RADIO CONTACT

1. Mode

- POS HOLD 2. Throttle

- 50% 3. Move toward aircraft until radio contact regained
4. Verify positive contr ol by looking for appropriate UA responses to PIC/Operator inputs
5. Mode

- Stabilize.

If radio contact is not reestablished, the UA will automatically climb to 50 ft above its last established AGL altiude before returning to its initial takeoff point and descending for landing.8 

## Controller function and Flight Controls

3 position
mode switch Camera pitch
control

4

- way stick.

Move forward, move backward, move left, move right. 4

- way stick. Throttle up,
throttle down, yaw left, yaw right Note: Switches and control features left unmarked have no function in the current configuration and do not impact flight.

Power ON,
OFF9101112 

## Electronic Speed Controller Operations13



## Specifications Propellars (4) 15 inch x 5.5 inch pitch Electronic Speed Controllers (4) HK Blue Series 30 amp
Motors (4) 480 rpm/volt Frame diagonal 650mm Frame Height 290mm Battery (1) or (2) 4S LiPo 6000mah