1 901Drones, LLC

2809 Kirby Pkwy

Bldg 116. #161

Memphis TN 38119
Brandon@901Drones.com

August 7, 2015

Dept. of Transportation, Docket Operations
West Building Ground Floor, Room w12-140
1200 New Jersey Avenue, SE.,
Washington, DC 20590

VIA FEDERAL DOCUMENT MANAGEMENT SYSTEM

Exemption Request under Section 333 of the FAA Reform Act and P art 11 of the

Federal Aviation Regulations – Amended August 7, 2015

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, 901Drones LLC (901Drones), a Te nnessee based Limited Liability
Company operating small Unmanned Aircraft Systems (sUAS) equipp ed to conduct
aerial photography and survey for various industries, hereby se eks an exemption from

Federal Aviation Regulations (FARs) detailed below to allow operation of our sUA S
commercially in airspace regulated by the Federal Aviation Admi nistration (FAA) so long as
such operations are conducted with and under the conditions out lined herein or as may be
established by the FAA as required by Section 333. The requeste d exemption is similar to
previous FAA issued grants of exemption including but not limit ed to Exemption Nos. 11062,

11109, 11112, 11213 and 11295.

The requested exemption would allow 901Drones to pursue commerc ial business by being
permitted to provide services to consumers, companies, local la w enforcement and first
responders as well as government agencies interested in trainin g, research, and aerial data
capture using sUAS in the following areas:

- Agricultural Surveying and Application
- Aerial Photography and Videography for real estate, insurance , construction, mining and
utilities companies
- Disaster relief and emergency management efforts

- Product and Service Demonstrations
- Operator Training
- Research and Development2 The petitioner request relief from the following regulations:

14 CFR §§ 61.23(a) and (c), 61.101(e)(4) and (5), 61.113(a), 61 .315(a), 91.7(a), 91.109, 91.119(c), 91.121, 91.151(a)(1), 91.215, 91.405(a), 91.407(a)(1 ), 91.409(a)(1) and (2), and 91.417(a) and (b), to the extent necessary to allow 901Drones t o operate a UAS to perform research, training and aerial data collection.

Petitioner’s sUAS platforms

We are petitioning for exemption to enable 901Drones to operate a series of widely operated and well established sUAS platforms manufactured by DJI that have b een previously approved by exemption. These include:

DJI Phantom 2 - Exemption 11398 DJI Phantom 2 Vision - Exemption 11310 DJI Phantom 2 Vision + - Exemption 11398 DJI Phantom 3 - Exemption 12342 DJI Inspire 1 - Exemption 12331 DJI S1000 - Exemption 11416

These sUAS all weigh less than 55 lbs, have a built-in capabili ty to limit the height flown above the ground, to limit the radius of the distance it flies from the o perator and to exclude it from Class B, C and D airspace including a no fly zone feature. Each system a lso has the failsafe function of the autopilot system, which means when the communication between th e Main Controller and the transmitter is lost, the system will automatically trigger Retu rn to Home and will land safely.

This submission does not include the Operating Manuals for each model requested above, as they have been reviewed by the Administrator in granting previo us exemptions. Copies of all Operating Manuals for the individual models listed can be submi tted on request.

General Operating Standards

The 901Drones sUAS will be operated in the field with both a PI C (Pilot in Command) and a VO (Visual Observer) in accordance with FAA Policy and with the fo llowing Restrictions:

a) No flight will be made with a UAS Gross weight exceeding 55 pounds, including payload;
b) All operations must occur in FAA Class G airspace at no more than 400 ft AGL, at

an airspeed of no more than 87 knots (100 miles per hour) and be o perated within
the visual line of sight (VLOS) of the PIC at all times;
c) All operations must utilize a visual observer (VO). The VO a nd PIC must be

able to communicate by voice at all times during a flight operation;
d) Operations will be restricted to flights over private proper ty with the permission of

the property owner(s);3 e) The PIC will hold either airline transport, commercial, priv ate, recreational, or sport pilot

certificate. The PIC will also hold a current FAA Airman medica l certificate or a valid
U.S. driver’s license issued by a state, the District of Columb ia, Puerto Rico, a territory,
a possession, or the Federal government. The PIC will also mee t the flight review
requirements specified in 14 CFR § 61.56 in an aircraft in whic h the PIC is rated on his
or her pilot certificate.
f) All required permits will be obtained from state and local g overnment prior to operation;
g) The 901Drone sUAS will not be operated over densely populate d locations;
h) The 901Drone sUAS will not be operated at air shows;
i) The 901Drone sUAS will not be operated over any open-air ass embly of people;
j) The 901Drone sUAS will not be operated over heavily traffick ed roads;
k) The 901Drone sUAS will not be operated within 5 NM of an air port or heliport;
l) Operations will be restricted to day only and weather co nditions equivalent to VFR;
m) The PIC will brief the VO and property owner about the opera tion and risk before the

first flight at each new location;
n) No flight may be made without a Preflight Inspection by the PIC before each operation

to ascertain that the sUAS is in a condition safe for flight (see Appendix A).

We submit that the combination of the sUAV's light weight, flig ht performance and ability, fully qualified flight crew and under all of the Restrictions (a) through (n) listed above, the

FAA can have full confidence that the operation will have an equivalent or greater level of safety than manned aircraft performing the same mission.

All sUAS operated in accordance with this exemption will be ide ntified by serial number, registered in accordance with 14 CFR part 47, and have identifi cation (N−Number) markings in accordance with 14 CFR part 45, Subpart C. Markings will be as large as practicable.

Exemption Requests and Equivalent Level of Safety

901Drones requests an exemption from the following regulations as well as any additional regulations that may technically apply to the operation of the sUAV System:

14 CFR 61.23 Medical Certificates

The regulation provides that a person requires a first or secon d class medical to act as Pilot in Command of an aircraft for compensation or hire. Our proposed o perations require that the PIC

must hold a current FAA airman medical certificate or a valid U .S. driver’s license issued by a state, the District of Colombia, Puerto Rico, a territory, a po ssession, or the Federal government. Since the aircraft cannot carry passengers or prope rty, we feel we meet the intent of 61.23 even though the intent of this application is to condu ct a business.

14 CFR 61.101, 14 CFR 61.113, and 14 CFR 61.315 Pilot privilege s and Limitations

The regulation provides that no person that holds a Recreationa l Pilot, Sport Pilot, or Private Pilot certificate may act as Pilot in Command of an aircraft fo r compensation or hire. Our proposed operations require that the PIC must hold at least air line transport, commercial, private, recreational, or sport pilot certificate. Since the ai rcraft 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 91.7 Civil Aircraft Airworthiness

This Section 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 CFR 91.109 Flight Instruction; Simulated instrument flight a nd certain flight tests

The regulation states that "No person may operate a civil aircr aft that is being used for flight Instruction unless that aircraft has fully functioning dual con trols." Training will be conducted by 901Drones PIC instructors. We have the ability to provide dual controls utilizing two transmitters

with a wireless and or wired link between the transmitters. One transmitter is designated the master transmitter and the other transmitter is designated as a slave. The 901Drones PIC instructor, utilizing the master transmitter, will be at all ti mes be able assume control of the

sUAS.

14 CFR 91.119 Minimum safe altitudes: General

The regulation states that over sparsely populated areas the ai rcraft cannot be operated closer than 500 feet to any person, vessel, vehicle, or structure. Sin ce the typical mission of the sUAS would be photography or survey of p ersons, vessels, vehicles or structures it would be necessary to operate closer than 500 feet to the items listed. Operations will only be flown over property where permission has been obtained and careful pre-pla nning has been performed. The sUAS will be operated at a low altitude allowing, if a powe r unit fails, an emergency landing without undue hazard to persons or property on the surface. The refore we maintain that due to the small size of the UAS, 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

The regulation requires that aircraft shall maintain cruising a ltitudes by reference to an altimeter setting available within 100 NM of the aircraft. The sUAS will always fly below 400 feet AGL and will not need to maintain cruising altitudes in order to preven t conflict with other aircraft. An

Above Ground Level altimeter meas urement above the takeoff poin t is transmitted via radio from the sUAS on-board computer to the display screen held by t he PIC, providing a constantly updated AGL readout.

14 CFR 91.151 Fuel requirements for flight in VFR conditions

The regulation provides that no person may begin a flight in an airplane under day-VFR conditions unless there is enough fuel to fly to the first poin t of intended landing and to fly after that for at least 30 minutes. We feel the intention of this par agraph is to provide an energy reserve as a safety buffer for delays to landing. The sUAS are battery operated and the maximum duration of flight from a single battery charge is 12-4 5 (depending on which sUAS) minutes with a 20% reserve. Since the aircraft will never fly m ore than 1/2 NM from the point of intended landing, a full battery charge at launch will ensure t hat we meet the reserve energy requirement of this paragraph. We request an exemption to the w ord "fuel" and ask for an equivalent interpretation with the word "energy". We also reque st exemption from the 30 min reserve and ask that our reserve will be to fly the mission to the point of intended landing and have at least a 20% battery reserve after that.5 14 C.F.R. 91.215 ATC transponder and altitude reporting equipme nt and use:

This regulation states all aircraft operating within 30 nautica l miles of class A, B and C airspace must be equipped with automatic pressure altitude reporting equ ipment having a Mode C capability that automatically replies to Mode C interrogations. Due to the small size and lifting capabilities of our sUAS we cannot carry a traditional transpon der. All of our operations will be under 250’ if we are operating within the 30mi reach of a mode C vail.

14 CFR Subpart E (91.401- 91.417) - Maintenance, Preventive Mai ntenance, Alterations

The regulation provides that the operator is primarily responsi ble for maintaining the aircraft in an airworthy condition, including compliance with part 39 and 4 3. Paragraphs 91.407 and 91.409 require that the aircraft be "approved for return to ser vice by a person authorized under 43.7" after maintenance and inspection. It is our intention tha t the 901Drones PIC perform maintenance and inspection of the aircraft and "be authorized t o approve the aircraft for return

to service."

The PIC will ensure that the sUAS is in an airworthy condition prior to every flight and in addition, conduct detailed inspections after every two hours of flight. Maintenance performed by the PIC is limited to repairing small cracks, replacing a prope ller, checking electrical connections and updating software and firmware for the on-board computer. All other maintenance will be performed by the manufacturer or their desi gnated repair facility. The PIC will document work performed in accordance with 91.417. We feel that due to the size, construction, and simplicity of the aircraft, the PIC can ensur e an equivalent level of safety.

How this request is to the betterment of our community

Our UAS are powered by batteries, smaller, lighter and more man euverable than larger aircraft running on combustible fuel, it operates at lower altitudes wit h no people on board and will thereby reduce current risk levels associated with traditional aircraft, enhance safety and diminish the likelihood of death or serious bodily injury. Also with a small payload and typical flight time of only 20 minutes, there is little or no risk to n ational security.

Low level photos and video are far more effective than ground o r high altitude manned aircraft imagery for displaying detailed characteristics of ground based objects. The applicant in the past has chartered full-sized helicopters for this purpose, whi ch has proven more costly than many potential clients have been able to afford. The benefits o f reduced cost and improved quality of presentation from the UAS will be incredibly valuabl e to future clients.

Additionally, we will make our sUAS available to first responde rs in our community who might require assistance, including fire fighters, police, sheriff, e t al., while remaining subject to all limitations cited in this application.6 The name and contact information of the petitioner are:

901Drones, LLC

Attn: Brandon Turk

Phone: 901.236.2932

Email: Brandon@901Drones.com

We are prepared to modify or amend any part of this request to satisfy the need for an
equivalent level of safety. Please contact us at any time if yo u require additional information

or clarification. We look forward to working with your office.

Sincerely,

Brandon Turk, Owner

901Drones, LLC