Alpha Taxiway Aviation

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U.S. Department of Transportation Docket Management System 1200 New Jersey Ave., SE Washington, DC 20590

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, Alpha Taxiway Aviation , seeks an exemption from Federal Aviation Regulations (“FARs”) detailed below for the DJI Phantom 2 Vision+, DJI Phanto m 2, DJI Inspire 1, DJI S1000+, DJI S900 , and DJI 550

.

The requested exemption would support an application for a commercial Certificate of

Authorization (COA) to use th e system to support ; aerial surveying, aerial photography, wildlife and forestry mo nitoring, aerial inspection, real estate surveying, and mapping operations. By approving these exemptions, the FAA will create benefits to industries benefiting from applications of using multi

- rotor UA Systems and the environment which are ultimately in the public interest. 1

Each DJI UAS weighs less than 55 lbs. fully loaded, will be operated at a speed no more than 87 knots, carry neither a pilot nor passenger, carry no explosive materials or flammable liquids, and operate exclusively within an approv ed COA airspace. All DJI UA Systems use a radio frequency spectrum for operation and control that complies with Federal Communications Commission (“FCC”) requirements and has integrated safety features as described within user

manuals for each DJI UAS. T he UAS are equipped with redundant safety mechanisms allowing them to operate safely after experiencing certain

- flight failures. If a lost

- link event occurs, including the loss of ground communications and/or the loss of a GPS signal, the UAS have the

abi lity to perform a pre

- coordinated, predictable, automated flight maneuver and return to a predetermined location within a designated security parameter for landing. The UAS further have the ability to abort a flight in the event of unpredicted obstacles o r emergencies. The aircraft will be operated in the field with both a Pilot in Command (PIC) and a ground

- based Visual Observer (VO) in accordance with FAA Order 8900.1, vol. 16 "Unmanned Aircraft Systems" with the following additional restrictions:

- All operations will be conducted IAW the Air Traffic Organization (ATO) Certificate of Waiver or Authorization (COA).

- All UAS operations will remain clear of manned aviation operations and activities at all times.

- All operations will occur at altitudes no more than 400' AGL

- Operations will be operated over private property with the permission of the land owner

- The UAS will not be operated by a PIC from any moving device.

- The aircraft will not be operated within 5 NM of an airport or heliport unless p rior coordination with ATC or airport management is made.

- Operations will be limited to day, visual meteorological conditionsAlpha Taxiway Aviation

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- Aircraft will remain within Visual Line of Sight of the PIC and VO at all times.

- While the aircraft is airborne, the VO will be positioned within voice distance to the PIC

The PIC and VO will meet the requirements outlined in FAA Order 8900.1, volume 16, chapter 4

. The PIC will hold at least a recreational or sport pilot certificate. Additionally, the PIC will perform maintenance on the system and will complete a course of maintenance instruction as part of their initial training. Due to the simplicity of the system, we do not anticipate the need for a supplemental pilot.

We submit that the combination of the aircraft 's light weight, historically demonstrated flight performance, fully qualified flight crew and strict operation under the guidelines established in 8900.1, the FAA can have confidence that the operation will have an equivalent or greater level of safety of manned aircraft performing the same mission.

The name and contact information of the applicant is :

Alpha Taxiway Aviation

Attn: Ronald E. Looney

Ph: 208

- 391

- 8448

Email: ronlooney@yahoo.com

The regulations from which the exemption is requested are as follows:

- 14 CFR Part 21

- 14 CFR 91.203

- 14 CFR 45.23, 45.29

- 14 CFR 91.9

- 14 CFR 61.113, 61.133

- 14 CFR 91.109, 91.119

- 14 CFR 91.121, 91.151

- 14 CFR Subpart E (91.401

- 91.417)

- 14 C FR 91.103(b)

We are prepared to modify or amend any part of this request to satisfy the need for an equivalent level of safety. We look forward to working with your office. Please contact us at any time if you require additional information or clarifica tion.

Sincerely,

Ronald E. Looney

President/Owner Alpha taxiway AviationAlpha Taxiway Aviation

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Appendices: A. Exemption Request and Equivalent Level of Safety

B. Privacy Issues C. Safety Assessment

D. Maintenance Procedures

E. User Manuals

F. Training Program G. Aviation ExperiencePROPRIETARY INFORMAT ION

- NOT FOR PUBLIC RELEA SE

Date: 20150 516 Revision: 1.0 Revision:1.0
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PROPRIETARY INFORMATION

- NOT FOR PUBLIC RELEASE