Name and Address of Applicant:

Joshua Jennings

Co

- Founder/CEO
Professional Drone Imaging LLC.
8608 NE 116 th St. Kansas City, MO 64157

To whom it may concern,

Professional Drone Imaging LLC (PDI LLC) located at 8608 NE 116 th St. Kansas City, MO 64157

r equest s exemption under Section 333 of the FAA Modernization and Reform Act of 2012 and 14 C.F.R.

Part 11 and Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012, respectfully requests exemptions from several provisions of the Federal A viation Regulations ("FAR"), specifically
Section 333 which authorizes the FAA to determine:

1. If certain unmanned aircraft systems, if any, as a result of their size, weight, speed, operational capability, proximity to airports and populated areas, and o peration within visual line of sight do not create a hazard to users of the national airspace system or the public or pose a threat to national security; and

2. Whether a certificate of waiver, certificate of authorization, or airworthiness certification
unde r section 44704 of title 49, United States Code, is required for the operation of unmanned aircraft systems i dentified under paragraph (1).

We are writing to request that PDI LLC

, an owner and operator of small unmanned aircraft, be exempted from the Feder al Aviation Regulations ("FARs") listed below so that PDI LLC , may operate its small unmanned aircraft systems ("UAS") commercially in airspace regulated by the Federal Aviation
Administration (“FAA”); as long as such operations are conducted within and un der the conditions outlined herein or as may be established by the FAA as required by Section 333. PDI LLC has been actively involved in the technical development of UAS service applications to provide high definition aerial photography for public safety p rofessionals , real estate agents, insurance personnel and various others, with small, unmanned aircraft and lightweight UAS’s. The substance of this request is essentially the same as that granted to LowCountry RC Docket Number FAA

- 2014

- 0803 in that PDI LL C is committed in public safety, as well as, aerial photography /videography and inspection of structures. PDI LLC has fully equipped each of its small unmanned aircraft for aerial photography and video, primarily for

use in the public safety sector , real e state and land surveying.

PDI LLC exemption request would permit its operation of lightweight, unmanned (remotely controlled in line of sight) UAS's in tightly controlled and limited airspace. Predetermined, specifically marked areas of operation, sectione d off locations will allow PDI LLC to operate within current safety regulations and new ones being sought. As identified, similar lightweight, remote controlled UAS's are legally operated by amateurs with no flight experience, safety plan or controls in plac e to prevent

catastro phe. Granting PDI LLC 's request coheres with the Secretary of Transportation's (FAA Administrator's) responsibilities to not only integrate UAS's into the national airspace system, but to" ... establish requirements for the safe opera tion of such aircraft systems [UAS's] in the national airspace system" under Section 333 of the Reform Act. Further, PDI LLC will conduct its operations in compliancewith the protocols described herein or as otherwise established by the FAA. The Extent o f Relief PDI LLC

Seeks and t he Reason It Seeks Such Relief:

PDI LLC submits this application in accordance with the Reform Act, 112 P.L. 95 §§ 331

- 334, seeking relief from any currently applicable FAR's operating to prevent PDI LLC contemplated
commercial operations, research and other flight operations within the national airspace system. The Reform Act in Section 332 provides for such integration of civil unmanned aircraft systems into our national airspace system as it is in the public's interest to do s o. PDI LLC lightweight UAS's meet the
definition of "small unmanned aircraft" as defined in Section 331 and therefore the integration of PDI
LLC lightweight UAS's are expressly contemplated by the Reform Act. PDI LLC would like to operate its lightweight UAS 's prior to the time period by which the Reform Act requires the FAA to promulgate rules governing such craft. The Reform Act guides the Secretary in determining the types of UAS's that may operate safely in our national airspace system. Consid erations inc lude: The weight, size, speed and overall capabilities of the UAS; Whether the UAS will be operated near airports or populated areas; and,
Whether the UAS wil l be operated by line of sight. 112 P.L. 95 § 333 (a). Each of these items mitigates in favor of an exemption for PDI LLC

.

PDI LLC ’s aircraft uses multi counter

- rotating propellers for extreme balance, control and stability. They each weigh less than 55 pounds, including camera or other equipment. Each of PDI LLC ’s
aircraft small unmanned aircraft i s designed to primarily hover in place and operate at less than a 50 knot maximum speed. They are capable of vertical and horizontal operations but operate only within the visual line of sight pilot

- in

- command (PIC). In addition to the PIC, PDI LLC utilizes a qualified spotter, capable of fully operating the aircraft in such that, the PIC would encounter a medical emergency during operations. Utilizing battery power and not combustible fuels, flights generally last between fifteen and
twenty

- five minute s. PDI LLC will not, under any circumstance, operate the aircraft under twenty

- five percent battery level. Safety systems in place include a failsafe mode that allows PDI LLC aircraft to
return to the GPS launch coordinates if communication with the radio c ontrol is lost or battery level
becomes less than twenty five percent. PDI LLC does not operate its UAV's near airports and does not operate them near populated areas.

PDI LLC operation of its small unmanned aircraft will not "create a hazard to users of t he national airspace system or the public." 112 P.L. 95 § 3 3 3 (b). Given the small size and weight of PDI LLC aircraft, combined with their operation of well

- controlled areas, PDI LLC aircrafts fall within Congress's contemplated safety zone when it publ ished the Reform Act and the corresponding directive to integrate UAS's into the national airspace system. PDI LLC aircraft have an outstanding safety record and do not pose any threat to the general public or national security. The FAA has the authority to issue the exemption to PDI LLC pursuant to the Federal Aviation Act, 85 P.L. 726 (1958), as amended (the “Act"). Commercial and Public Benefits Granting PDI LLC exemption request furthers the public interest. First, Congress has already pronounced that it is in the public’s interest to integrate commercially flown UAS's into the national airspace system, thus the passing of the Reform Act. Second, PDI LLC conducts research into safe UAS operations every time it flies one of its UAV's. Flight data, visual i nspections, recorded observations and flight analyses are compiled to further enhance current safety protocols. Granting approval of this exemption request for PDI LLC to log more flight time will augment its ability to
further en hance current safety measure s. Granting the PDI LLC exemption request considerably furthers the public's interest in more ways than currently known. Allowing PDI LLC to fly within the United States allows for improvements in publicly usable technologies and/ or advancements in equipm ent available tolaw enforcement personnel and first responders with state of the art equipment that does not cost the

tax payers millions.

Reasons w hy PDI LLC Exemption w ill n ot a dversely a ffect s afety o r h ow t he e xemption will provide a l evel of s afety a t l east e qual t o e xisting r ule: PDI LLC exemption will not adversely affect safety. Actually, for the many reasons stated, permitting PDI LLC to gain experience and information

over time will allow PDI LLC to innovate and implement new and improved safety protocols and technologies.

1. PDI LLC aircraft weigh less than 55 pounds complete with cameras; 2. PDI LLC only operates its UAS's below 400 feet;

3. PDI LLC UAV's operate for 5

- 30 minutes per flight;

4

. PDI LLC lands its UAS's before they reach a threshold 25% battery power;

5. PDI LLC pilots operate PDI LLC aircraft by Visual Line of Sight (VSOL) at all times.

6. PDI LLC pilots have live video streamed to the ground control station should they somehow lose sight of the UAS;

7. PDI LLC staffs each flight with a pilot

- in

- command and spotter capable of operating aircraft;

8. PDI LLC aircraft have GPS flight modes whereby they return to launch if communication with the remote control is lost or battery thres hold becomes less than 25%;

9. PDI LLC actively examines electronic flight data and other sources of information to constantly update and enhance safety protocols;

10. PDI LLC only operates in secured areas that are strictly controlled, are away fro m airpor ts and heavily populated areas;

11. PDI LLC conducts extensive briefings prior to flight, during which safety carries primary importance;

12. PDI LLC always obtains all necessary permissions and permits prior to operation;

13. PDI LLC operationally administ ers a level of safety equal to and even greater than existing rules set
forth.

It is important to note that absent the integration of commercial UAS's into our national airspace system, helicopters are the primary means of aerial observation. While the saf ety record of such helicopters is incredible, it is far safer to operate a battery powered lightweight UAS. First, the potential loss of life is decreased because PDI LLC aircraft carry no people on board and PDI LLC only
operates in areas away from major populations. Second, there is no fuel on board PDI LLC aircraft and thus the potential for fire or explosions is highly decreased. Third, the small size and acute maneuverability of PDI LLC aircraft allow the pilot in command to avoid hazards. Respectfully

, PDI LLC aircraft have and will always operate at and above current safety requirements. Summary the FAA may

p ublish in the Federal Register: 14 C.F.R. 21 and 14 C.F.R. 91: Airworthiness Certificates, Manuals and the Like. 14 C.F.R. 21, Subpart H, entitle d Airworthiness Certificates, sets forth requirements for procurement of necessary airworthiness certificates in relation to FAR§ 91.203(a)(l). The size, weight and enclosed operational area of PDI LLC permits exemption from Part 21 because PDI LLC aircraft meet an equivalent level of safety pursuant to Section 3 33 of the Reform Act. The FAA is authorized to exempt aircraft from the airworthiness certificate requirement under both the Act (49 U. S.C. § 44701 (f)) and

A. Section 333 of the Reform Act. Both piec es of legislation permit the FAA to exempt UAS's from the airworthiness certificate requirement in consideration of the weight, size, speed, maneuverability and proximity to areas such as airports and dense populations.PDI LLC aircraft meet or exceed each of the elements. 14 C.F.R. 91.7 (a) prohibits the operation

of an aircraft without an airworthiness certificate. As no such certificate will be applicable in the form contemplated by the FARs, this Regulation is inapplicable. 14 C.F.R. § 91.9 (b) (2) requi res an aircraft flight manual in the aircraft. As there are no pilots or passengers, and given the size of the UAS's, this Regulation is inapplicable. An equivalent level of safety will be achieved by maintaining a manual at the flight operations center. The FAA has previously issued exemptions to this regulation in Exemption Nos. 8607, 8737, 8738, 9299, 9299A, 9565, 95658, 10167, 10167A, 10602, 10700 and 32827. 14 C.F.R. § 91.121 regarding altimeter settings is inapplicable insofar as PDI LLC UAS aircraft u tilize electronic global positioning systems and internal gyroscopes t o provide spatial coordination. 14 C.F.R. § 91.203 (a) and (b) provides for the carrying of civil aircraft certifications and registrations. They are inapplicable for the
same reasons des cribed above. The equivalent level of safety will be achieved by maintaining such certifications and registrations at the PDI LLC flight operations center. B. 14 C.F.R. § 45.23: Marking of
the Aircraft. Applicable Codes of Federal Regulation require aircraft to be marked according to certain speci fi cations. PDI LLC aircraft are, by de fi nition, unmanned. They therefore do not have a cabin, cockpit or pilot station on which to mark certain words or phrases. Further, two

- inch lettering is difficult to place on such small aircraft. The FAA has previously issued exemptions to this regulation through Exemptions

Nos. 8 738, 10167, 10167A and 10700. C. 14 C.F.R. § 61.113: Private Pilot Privileges and Limitations. PIC

Pursuant to 14 C.F.R. §§ 61.113 (a) & (b), private pilots are limited to noncommercial operations. PDI LLC can achieve an equivalent level of safety as achieved by current Regulations because PDI LLC aircraft do not carry any pilots or passengers.

Furth er, while helpful, a pilot license (we do have a commercially rated pilot on staff) will not ensure unmanned piloting skills, though PDI LLC pilot vetting and training programs (based upon completion of an FAA Approved Ground School and a self

- administered UAS flight training program and
internal procedures) will. T he risks attendant to the operation of PDI LLC aircraft is far less than the risk
levels inherent in the commercial activities outl ined in 14 C.F.R. § 61, et seq. D. 14 C.F.R. 91.119:
Minimum Safe Altitudes. 14 C.F.R. § 91.119 prescribes safe altitudes for the operation of civil aircraft. It allows Helicopters to be operated at lower altitudes in certain conditions. PDI LLC UAS aircraft will never operate at an altitude greater than 400 AGL. PDI L LC will, however, operate its UAV's in sectioned off areas with security and safety being paramount , providing a level of safety at least equivalent to those in
relation to minimum safe altitudes. G iven the size, weight, maneuverability and speed of PDI LL C aircraft, an equivalent leve l of safety will be achieved. E. 14 C.F.R. 91.405 (a); 407 (a) (1); 409 (a) (2); 417(a) & (b): Maintenance Inspections. The above

- cited Regulations require, amongst other things, aircraft owners and operators to "have [the] aircraft inspected as prescribed in subpart E of this part and shall between required inspections, except as provided in paragraph C of this section, have discrepancies repaired as prescribe d in part 43 of this chapter." These Regulations only apply to ai rcraft with an airworthiness certificate. They will not, therefore, apply to PDI LLC should its requested exemption be granted. PDI LLC conducts an extensive maintenance program that involves regular software updates and constant inspection for assessment o f any damaged hardware. Therefore, an equivalent level of safety will be achieved. PDI LLC has researched and d eveloped its own designs.

Summary PDI LLC seeks an exemption from the following Regulations: 14 C.F.R. 21, subpart H; 14 C.P.R. 45.23(b); 14 C.F.R. §§ 61.113 (a) & (b); 14 C.F.R. § 91.7 (a); 14 C.F.R. § 91.9 (b)(2); 14 C.F.R. § 91.103(b); 14 C.F.R. § 91.109; 14 C.F.R. § 91.119; 14 C.F.R. § 91.121; 14 C.F.R. § 91.151(a); 14 C.F.R. §§91.203(a) and (b); 14 C. F.R. § 91.405 (a); 14 C.F.R. § 91.407 (a)(1); 14 C.P.R.§ 91.409 (a)(2);

14 C.P.R.§ 91.409 (a)(2); and, 14 C.P.R.§§ 91.417 (a) & (b) to commercially operate its fleet of small unmanned vehicles and lightweight unmanned aircraft vehicles and to conduct its ow n research and to develop economic platforms for aerial survey, law enforcement , first responders, search and rescue and
real

- estate

. Granting the PDI LLC request for exemption will reduce current risk lev els and thereby enhance safety. Further, PDI LLC operates at lower altitudes and in controlled airspace. PDI LLC has been analyzing flight data and other information in compiling novel safety protocols and the implementation of a flight operations manual that exceeds currently accepted means and
methods of safe flight. There are no people on board PDI LLC aircraft and therefore the
likelihood of death or serious bodily injury is significantly limited. PDI LLC operation of its aircraft, weighing less than 55 pounds and traveling at speeds lower than 50 knots i n cordoned off areas will provide at least an equivalent level of safety as th at achieved under current FARs.

PDI LLC respectfully requests that the FAA grant its exemption request without delay. The FAA has the authority to issue the exemption sought by P DI LLC pursuant to the Federal Aviation Act, 85 P.L. 726 ( 1958), as amended (the "Act"). Thank you for the time and consideration of the above Exemption Request. Please contact Mr. Joshua Jennings for more information or questions that arise

.

Thank you for your time,

Joshua Jennings

Co

- Owner and CEO Professional Drone Imaging LLC “Let us improve your view”