Feel Good Now, LLC 1

Feel Good Now, LLC.

Joshua D. Guiles

877 Bridle Court

Carmel, IN 46032

231.670.0267

joshua@feelgoodnow.today

September 10, 2015

U.S. Department of Transportation

Docket Operations

1200 New Jersey Ave., SE

Washington, DC 20590

Re: Submission of Request for Determination under Section 333 of the FAA Modernization

and Reform Act and Exemptions under 14 C.F.R. Section 11.81

Dear Sir or Madam:

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (“FMRA”), I, Mr.

Joshua D. Guiles hereby request a determination by the Secretary of Transportation

authorizing conduct of commercial operations of its UAS for the purposes of photography,

videography, inspection of infrastructure, precision agriculture, and scientific &

environmental research. Pending a grant of exemption, I will be launching my company,

which will provide a broad spectrum of safe and efficient aerial solutions. I will be using

UAS manufactured by DJI Innovations. Operations will be conducted within and under the

safeguards outlined herein and as may be established by the FAA under FMRA Section

333(c).

I also petition for exemptions as necessary to effect the determination requested pursuant

to FMRA Section 333. The attached documentation includes detailed exemption requests

that demonstrate how these exemptions are in the best public interest and will maintain at

least an equal level of safety to existing regulations. Authorizing me to conduct commercial

UAS operations would enhance community education and awareness of UAS. Further,

operation of these UAS in these commercial operations are less disruptive, safer, and more

cost effective than manned aviation equivalents due to the low altitude environment, size,

speed and inherent risk of traditional commercial helicopter operations. These commercial

operations often occur in the unsafe areas of the height-velocity diagram requiring special

precision and skill. I will conduct the commercial UAS operations in a manner that will

meet, and in many cases exceed, the current level of safety of commercial helicopter

operations. I will deploy UAS that are under 25 lbs, have a low noise signature, and carry no

volatile fuel, which will limit collateral damage in the event of catastrophic failure. The low

expense of operation compared to cost prohibitive manned aviation alternatives allow a

greater economic benefit to businesses. For these reasons, granting an exemption under

FMRA Section 333(c) is in the public interest. UAS technology used for these commercial

purposes benefit the public interest in the following ways:
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• Reduces the collateral damage risks to life and property associated with low

altitude helicopter operations in undesirable portions of the height-velocity

envelope.

• Increased public awareness regarding safe and responsible utilization of UAS.

• Increased economic wellbeing to local businesses via cost reductions.

• Enabling aerial business solutions to be available to a larger market.

• Enhanced agriculture practices resulting in reduced environmental

contamination from pesticide/fertilizer runoff and increased crop yields.

• More efficient and frequent inspection of infrastructure due to reduced cost.

• Additionally, I commit to hiring appropriately qualified pilots and observers

from the local community whenever possible in future expansions. I

appreciate your careful consideration in granting this exemption.
Feel Good Now, LLC 3

Table of Contents

I. Regulations – Exemptions Requested

II. Commercial Operation/Operator

III.Unmanned Aircraft System (UAS)

IV. UAS Pilot-in-Command (PIC)

V. Public Interest

VI. Summary

VII. Appendix A – Inspire 1 Operating

Documents

VIII. Appendix B – S1000 Operating

Documents

IX. Appendix C – Phantom operating Documents
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I. Regulations – Exemptions requested

Pursuant to 14 C.F.R. § 11.81(e), Feel Good Now, LLC. seeks exemption from the below

mentioned regulations and provide reason as to why the exemption should be approved

based on the level of safety at least equal to that of which the rules require.

14 C.F.R. Part 21 Subpart H – Airworthiness Certificates

Establishes: The procedural requirements for the issuance of airworthiness certificates as

required by 14 C.F.R. § 91.203(a)(1). Given the small size of the UAS and the safeguards

that will be taken as outlined below, an exemption from Part 21 Subpart H meets the

requirements of an equivalent level of safety under Part 11 and Section 333 of the FMRA

with consideration “of the size, weight, speed, operational capability, and proximity to

airports and populated areas of the particular UAS.”

14 C.F.R. § 45.23(b) – Aircraft Marking and Identification Requirements

When marks include only the Roman capital letter "N" and the registration number is

displayed on limited, restricted or light-sport category aircraft or experimental or

provisionally certificated aircraft, the operator must also display on that aircraft near each

entrance to the cabin, cockpit, or pilot station, in letters not less than 2 inches nor more

than 6 inches high, the words "limited," "restricted," "light-sport, "experimental," or

"provisional," as applicable. Our UAS will ensure compliance with § 45.29(f) to meet the

intent of the regulation by displaying the registration number in the largest practicable

lettering.

14 C.F.R. 61.113 (a)(b) and 61.133(a)(1)(ii) – Private and Commercial Pilot Privilege

and Limitations

14 C.F.R. § 61.113: (a) Except as provided in paragraphs (b) through (g) of this section, no

person who holds a private pilot certificate may act as pilot in command of an aircraft that

is carrying passengers or property for compensation or hire; nor may that person, for

compensation or hire, act as pilot in command of an aircraft. (b) A private pilot may, for

compensation or hire, act as pilot in command of an aircraft in connection with any

business or employment

14 C.F.R. § 61.133: (a) Privileges – (1) General. A person who holds a commercial pilot

certificate may act as pilot in command of an aircraft – (ii) For compensation or hire,

provided the person is qualified in accordance with this part and with the applicable parts

of this chapter that apply to the operation. Currently, there are no applicable areas

identified for UAS in either the private or the commercial sector and therefore an

exemption is required to conduct commercial operations. As flight operations will be

conducted with an abundance of caution following the procedure outline below, our

operations will achieve an equivalent level of safety for each individual flight especially

when compared to commercial flights identified in Part 61 when originally developed. Our
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operation will be conducted with pilots who hold, at a minimum, a private certificate of any

category or class and a 3 rd class medical.

14 C.F.R. 91.7(a) – Civil Aircraft Airworthiness

No person may operate a civil aircraft unless it is in an airworthy condition. Currently there

is no airworthiness certificate for UAS. Daily pre and post flight inspections will be

accomplished in accordance with manufactures maintenance manual(s) and guidance.

During flight, the PIC will adhere to § 91.7(b) and abort air operations immediately upon

identification of an in-flight emergency or other unsafe condition. By complying with

procedures outlined by the manufacturer, an equivalent level of safety will be achieved.

14 C.F.R. 91.9(b) civil aircraft flight manual, marking, and placard requirements

(b)(2) prohibits operation of U.S.-registered civil aircraft unless there is available in the

aircraft a current approved Airplane or Rotorcraft Flight Manual, approved manual

material, markings, and placards, or any combination thereof. By keeping all operating

documents, manuals, authorizations and exemptions in a binder co-located with the GCS,

we can meet the intent of the regulations and therefore achieve an equivalent level of

safety.

14 C.F.R. 91.109(a) – Flight Instruction

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. The majority of

sUAS by design are developed with single operational control through the use of predetermined GPS enabled waypoints programmed before or during flight in addition to the

use of a single hand held transmitter or control station controlled by the PIC. The design

does not allow for dual controls during flight training and therefore the exemption is

requested to train operators, build experience, and maintain proficiency. An equal level of

safety will be achieved by conducting all training in a controlled environment. Training

sessions will be accomplished separately from flights conducted for compensation or hire.

14 C.F.R. 91.119 (c) – Minimum Safe Altitudes

Except when necessary for takeoff or landing, no person may operate an aircraft below the

following altitudes: (a) Over any congested area of a city, town, or settlement, or over any

open air assembly of persons, an altitude of 1,000 feet above the highest obstacle within a

horizontal radius of 2,000 feet of the aircraft. (b) Over other than congested areas. An

altitude of 500 feet above the surface, except over open water or sparsely populated areas.

In those cases, the aircraft may not be operated closer than 500 feet to any person, vessel,

vehicle, or structure. (c) Helicopters, powered parachutes, and weight-shift-control aircraft.

If the operation is conducted without hazard to persons or property on the surface—(1) A

helicopter may be operated at less than the minimums prescribed in paragraph (a) or (b) of

this section, provided each person operating the helicopter complies with any routes or

altitudes specifically prescribed for helicopters by the FAA. Commercial UAS operations

will be conducted at or below 400 ft. AGL. Given the size, weight and lack of fuel; combined

with operation limitations listed below, the operation will be conducted with a greater

level of safety than exists with current manned aviation operations.
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14 C.F.R. 91.121 – Altimeter Settings

Each person operating an aircraft shall maintain the cruising altitude or flight level of that

aircraft, as the case may be, by reference to an altimeter that is set, when operating. UAS

are equipped with Global Positioning System (GPS), which provide altitude and geolocation data to the operator without utilizing an altimeter. Due to this fact, an exemption is

required. GPS are precise within a few feet and combined with fail-safes and a visual

observer the operation will meet an equivalent level of safety.

14 C.F.R. 91.151(a) – Fuel Requirements for Flight in VFR Conditions

No person may begin a flight in an airplane under VFR conditions unless (considering wind

and forecast weather conditions) there is enough fuel 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 30 minutes; This regulation is written based on the capabilities of a traditional

aircraft, which have flight times of several hours or greater; therefore, with the majority of

sUAS which have flight times of only an hour or less, this regulation would effectively deny

the ability of the air vehicle to operate. The DJI UAS display a visual Warning and in case of

the DJI Inspire 1, emit an audible low battery alert at 30% at which time the UAS will

automatically engage the landing sequence. Based upon that safeguard and the small

operational area in VLOS, the operation can meet an equivalent level of safety.

14 C.F.R. 91.405(a), 91.407(a)(1), 91.409(a)(2) and 91.417(a) & (b) – Maintenance

Inspections

91.405(a) States: Each owner or operator of an aircraft—(a) Shall have that 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

prescribed in part 43 of this chapter

91.407(a)(1) States: (a) No person may operate any aircraft that has undergone

maintenance, preventive maintenance, rebuilding, or alteration unless—(1) It has been

approved for return to service by a person authorized under § 43.7 of this chapter.

91.409(a)(2) States: (a) Except as provided in paragraph (c) of this section, no person

may operate an aircraft unless, within the preceding 12 calendar months, it has had—(2)

An inspection for the issuance of an airworthiness certificate in accordance with part 21 of

this chapter. No inspection performed under paragraph (b) of this section may be

substituted for any inspection required by this paragraph unless it is performed by a

person authorized to perform annual inspections and is entered as an ‘‘annual’’ inspection

in the required maintenance records.

91.417(a) & (b) States: (a) Except for work performed in accordance with §§91.411 and

91.413, each registered owner or operator shall keep the following records for the periods

specified in paragraph (b) of this section: (paragraphs 1 (i– iii), 2 (i – vi)); (b) The owner or

operator shall retain the following records for the periods prescribed: (paragraphs 1 – 3)

Because DJI UAS at present do not have airworthiness certificates, these regulations do not
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apply and therefore an exemption is required. Pre/Post flight inspections and maintenance

will be conducted in accordance with the manufacturer’s guidance as stated in the

operations manual. In addition, to meet the intent of these regulations, I will maintain daily

logs of pre and post flight inspections. If maintenance is required, a dedicated test flight will

be conducted to ensure safety before resuming commercial operations. All inspection,

maintenance and alterations will be documented and maintained in a record. These actions

will meet the intent of the regulations from which exemption is being requested and lead to

an equivalent level of safety.

II. Commercial Operator/Operation

Initially, One of our pilots holding at least a private pilots license will be the operator of the

exempted UAS, with subsequent hiring of employees to follow. Co-founder and myself are

very educated in UAS subject matter and believe our knowledge is what is needed to

operate successfully and efficiently. I request that my future employees be exempt from§

61.113 (a) and (b) allowing operations of my UAS for compensation or hire, possessing

only a private pilot certificate and 3rd class medical. A private pilot certificate will

demonstrate a safe and equivalent level of aeronautical safety, judgment, security and

responsibility to operate my UAS. I am knowledgeable in human factors awareness; crew

resource management; and risk management. I will apply those principles to my operation.

For each flight, my employees or I:

 Will contact the controlling air traffic organization to issue a NOTAM.

 Will obtain a preflight briefing from a pilot briefer, DUATS, or similar means.

 Will conduct a comprehensive worksite inspection and analysis, identifying limits

of customer property or authorized access areas.

 Will conduct preflight planning in accordance with Section 91.103 Preflight Action.

 Will operate in those areas only with the consent of the landowner or designated

representative.

 Will identify potential obstructions or other hazards to safe operation.

 Will clear the area of personnel or bystanders that are non-essential to the

operation, maintaining at a minimum, 500 feet away from non-participating

persons.

 Will conduct a preflight safety briefing to Visual Observer (VO) and participating

persons.

 Will at all times yield to manned air traffic.

 Will operate within VLOS of both PIC and VO during daylight hours only.

 Will maintain voice communications with VO and participating persons.

 Will operate under Class D visual flight rules, defined as 500 feet below and 2000

feet horizontal from clouds with a minimum of 3 statute miles of visibility.

 Will not exceed an altitude 400 feet AGL as determined by the installed GPS.

 Will keep operating documents, manuals, authorizations and exemptions in a

binder collocated with the GCS.

 Will immediately terminate flight, in the safest manner possible, when safety to

persons or property become compromised.
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• Will terminate flight, in the safest manner possible, when unable to comply with

these limitations or any other limitations granted as part of this exemption. In

order to remain at an altitude at or below 400 feet AGL, relief is needed from

Section 91.119 (c) and (d). By following these operating standards, the

commercial operation will meet an equivalent level of safety to the regulation in

which relief is sought.

III. Unmanned Aircraft System

I seek an exemption to operate the DJI line of UAS. The Inspire 1 and Phantom are the

primary aircraft in our operation for which we seek exemption. We will also be utilizing the

S1000 for larger scale projections. The DJI UAS utilize a common autopilot system and

common ground control station software (GCS). The UAS will be flown via a combination of

RC control, Tablet GCS, or PC-based GCS. The Inspire 1, Phantom, and S1000 are GPS

equipped, multirotor helicopters. The Inspire 1 and Phantom are a quad-type aircraft

utilizing four rotors. The S1000 is an Octo-type utilizing eight rotors. The UAS are powered

by lithium-polymer batteries. The UAS will carry the proprietary camera from DJI, a GoPro

hero 4, or a Canon Mark III camera. The Inspire 1, Phantom, and S1000 UAS have the

capability to land at its current location with a dedicated switch. The UAS also has several

fail-safes for loss of RC signal, loss of GPS, and low battery as outlined in the respective

Operation Manuals. The UAS display a visual low battery alert at 25% at which time the

UAS will automatically engage the landing sequence. Based upon that safeguard, I request

exemption from Section 91.151(b) Fuel requirements for flight in VFR conditions. The UAS

also has a height restriction function, which will be programmed for a maximum altitude of

400 feet. Given the aircraft will be operated within VLOS with the aid of a VO, I believe the

operation can be conducted with an equivalent amount of safety and therefore request

exemption from Section 91.121. Given the size, weight, speed, and controlled operating

area associated with the UAS to be utilized, an exemption from 14 CFR part 21, Subpart H

(Airworthiness Certificates) and §91.203 (a) and (b) is requested. I seek exemption from §

45.23 Marking of the aircraft. The UA will display the registration number in the largest

practicable lettering. We wish to be exempt from § 91.405(a), 91.407(a)(1), 91.409(a)(2)

and 91.417(a) and b). Maintenance inspections will be conducted according to operations

manual and prudent judgment as previously outlined to determine the integrity and safety

of the UAS and associated equipment. Further, I require relief from 91.7(a), which prohibits

the operation of an aircraft without an airworthiness certificate and 91.9(b) (2) requiring

an approved flight manual in the aircraft. The UAS will not be operating with an

airworthiness certificate therefore, this would be inappropriate. The UAS are too small to

carry the operating documents so an equivalent amount of safety can be achieved through

keeping the operating documents and manuals at the GCS.

IV. UAS Pilot in Command (PIC)

Under § 61.113 (a) and (b) private pilots are limited to non-commercial operations,

however I can ensure my operation will achieve an equivalent level of safety as current

regulation because my UAS do not carry any pilots or passengers. A commercial pilot
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certificate will not ensure RC piloting ability, as the psychomotor skills are different. The

inherent risks of operating a UAS are far less than in the commercial activities outlined in

14 CFR part 61, et seq., thus I request an exemption from § 61.113 Private Pilot Privileges

and Limitations: Pilot in command. All UAS PICs will have logged, in accordance with 61.51

(b), appropriate training on the UA consisting of 25 hours as UAS rotorcraft, 10 hours

multirotor UAS or 25 hours as UAS airplane, 10 hours single-engine as appropriate. PICs

will maintain recent flight experience on the UAS. Training and experience flights will be

conducted separate from commercial operations.

PIC Training will consist of:

 Pre-flight Tasks

Full site inspection

Assembly and inspection of UAS

Set-up and configuration of RC radio and GCS

System checks

 Mission Tasks

Establish flight plan

Takeoff and landing

Manual flight modes

Autonomous flight modes

Emergency Procedures

 Post-flight Tasks

Inspection

Shutdown

Disassembly

 Other Tasks

Regulations

Operating limitations

Flight planning

V. Public Interest

Given the above stated evidence, procedures, and precautions; I feel that operating my UAS

commercially for the purposes of photography, videography, inspection of infrastructure,

precision agriculture, and scientific & environmental research will ultimately be in the

public interest. These operations, when executed with prudence, will exceed the current

level of safety as the regulations from which I seek exemption. My operation will allow

greater access to commercial aerial services that were not previously economically feasible

for many firms. This will provide a much needed economic uplift to the community and

hence the public. My operation will be conducted with less risk of collateral damage to

persons and property while limiting disruptive noise pollution associated with low altitude

aviation operations. A major factor to consider regarding the public interest is the current

state of UAS operations in the US. As a manned aviator, the need to integrate UAS into the
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national airspace system in a safe, deliberate manner is always at the forefront of my mind.

As the technology becomes more readily available, the challenges will intensify. By

allowing commercial operations, it will enable communities to become educated in the

proper use of this technology. As an educator, I am already working to foster positive

awareness and safe, responsible utilization of UAS technology. Granting my exemption will

result in a direct extension of these efforts, which is in the public interest.

VI. Summary

Pursuant to Section 333 of PL 112-95 commonly known as the “FAA Modernization and

Reform Act of 2012”, Joshua D. Guiles, hereby applies for authorization to conduct

commercial unmanned aerial systems (UAS) operations for the purposes of		photography,

videography, inspection of infrastructure, precision agriculture, and scientific &

environmental research.

Rules in which I seek exemption:

 14 C.F.R. Part 21 Subpart H

 14 C.F.R. § 45.23(b)

 14 C.F.R. § 61.113 and 61.133(a)(1)(ii)

 14 C.F.R. § 91.7(a)

 14 C.F.R. 91.9(b)

 14 C.F.R. § 91.103

 14 C.F.R. § 91.109(a)

 14 C.F.R. § 91.119

 14 C.F.R. § 91.121

 14 C.F.R. § 91.151(a)

 14 C.F.R. § 91.405(a)

 14 C.F.R. § 91.407(a)(1)

 14 C.F.R. § 91.409(a)(2)

 14 C.F.R. § 91.417(a) & (b)

Throughout this exemption request, I have shown how my expertise and knowledge with

UAS technology will ensure the public’s best interest is at hand and how my operation will

aid in safely integrating civil UAS into the national airspace system.
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VII. Unmanned Aircraft Vehicle: Inspire 1 UAV

Feel Good Now, LLC. seeks an exemption to operate its existing Inspire 1, UAV, for

compensation or hire within the national airspace system (“NAS”).

The Inspire 1 UAV is comprised of a VTOL unmanned aircraft and a transportable ground

station. The Inspire 1 UAV has a maximum gross weight of approximately six and one half (6.5)

pounds and the following technical and operational specifications:

Weight (Battery Included) 2935 g

Hovering Accuracy (GPS mode) Vertical: 0.5 m

Horizontal: 2.5 m

Max Angular Velocity Pitch: 300°/s

Yaw: 150°/s

Max Tilt Angle 35°

Max Ascent Speed 5 m/s

Max Descent Speed 4 m/s

Max Speed 22 m/s (ATTI mode, no wind) 4500 m

Max Flight Altitude 4500m

Max Wind Speed Resistance 10 m/s

Max Flight Time Approximately 18 minutes

Motor Model DJI 3510

Figure 1. DJI Inspire 1 UAV
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Propeller Model DJI 1345

Indoor Hovering Enabled by Default

Operating Temperature Range -10° to 40° C

Diagonal Distance 559 to 581 mm

Dimensions 438 x 451 x 301 mm
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VIII. Unmanned Aircraft Vehicle: S1000 UAV

Feel Good Now, LLC. seeks an exemption to operate its existing S1000, UAV, for compensation

or hire within the national airspace system (“NAS”).

The S1000 UAV is comprised of a VTOL unmanned aircraft and a transportable ground station.

The S1000 UAV has a maximum gross weight of approximately nine and one half (9.5) pounds

and the following technical and operational specifications:

Diagonal Wheelbase: 1045mm

Frame Arm Length: 386mm

Frame Arm Weight: 325g (Including Motor, ESC, Propeller)

Center Frame Diameter: 337.5mm

Center Frame Weight: 1330g (with Landing Gear Mounting Base, Servos)

Landing Gear Size: 460mm (Length) ×511mm (Width) ×305mm (Height),

(Top width: 155 mm)

Motor: Stator Size: 41×14mm

KV: 400rpm/V

Max Power: 500W

Weight: 158g (with Cooling Fan)

Working Current: 40A

Working Voltage: 6S LiPo

Signal Frequency: 30Hz ~ 450Hz

Figure 2. DJI S1000 UAV
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Drive PWM Frequency: 8KHz

Weight: 35g (with Radiators)

Foldable Propeller: (1552/1552R)

Propeller Size: 15×5.2inch

Weight: 13g

Takeoff Weight: 6.0Kg – 11.0Kg

Total Weight: 4.2Kg

Power Battery: Lipo (6S 10,000mAh – 20000mAh 15C(Min))

Max Power Consumption: 4000W

Hover Power Consumption: 1500W (@9.5Kg Takeoff Weight)

Hover Time: 15min (@15000mAh & 9.5Kg Takeoff Weight)

Working Environment Temperature: -10 °C ~ +40 °C

For A2 flight controller:

Basic: Roll 120%, Pitch 120%, Yaw 120%

Attitude: Roll 170%, Pitch 170%, Vertical 120%

For WooKong-M flight controller:

Basic: Roll 180%, Pitch 180%, Yaw 120%

Attitude: Roll 180%, Pitch 180%, Vertical 120%
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VIV. Unmanned Aircraft Vehicle: Phantom 1 UAV

Feel Good Now, LLC. seeks an exemption to operate its existing Phantom 1, UAV, for

compensation or hire within the national airspace system (“NAS”).

The Phantom 1 UAV is comprised of a VTOL unmanned aircraft and a transportable ground

station.

Operating Temperature -10°C ~ 50°C

Power Consumption 3.12W

Take-Off Weight <1200g

Hovering Accuracy (GPS Mode) Vertical: .8m

Horizontal: 2.5m

Max Yaw Angular Velocity 200°/s

Max Tilt Angle 45°

Max Ascent / Decent Speed 6m/s

Max Flight Velocity 10m/s

Diagonal Distance 350mm

Figure 3. DJI Phantom 1 UAV