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 ofTransportation Docket Operations 1200 NewJerseyAve., SE Washington, DC 20590 Re: Submission ofRequest for Determination under Section 333 ofthe FAA Modernization and Reform Act and Exemptions under 14 C.F.R. Section 11.81 Dear Sir or Madam: Pursuantto Section 333 ofthe FAA Modernization and Reform Act of2012 (“FMRA”), I, Mr. Joshua D. Guiles hereby request a determination by the Secretary ofTransportation authorizing conduct ofcommercial operations ofits UAS for the purposes ofphotography, videography, inspection ofinfrastructure, precision agriculture, and scientific & environmental research. Pending a grant ofexemption, I will be launching my company, which will provide a broad spectrum ofsafe 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 necessaryto effectthe 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 ofsafetyto existing regulations. Authorizing me to conduct commercial UAS operations would enhance community education and awareness ofUAS. Further, operation ofthese 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 oftraditional commercial helicopter operations. These commercial operations often occur in the unsafe areas ofthe height
-velocity diagram requiring special precision and skill. I will conductthe commercial UAS operations in a manner thatwill meet, and in many cases exceed, the current level ofsafety ofcommercial 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 ofcatastrophic failure. The low expense ofoperation compared to cost prohibitive manned aviation alternatives allow a greater economic benefitto businesses. For these reasons, granting an exemption under FMRA Section 333(c) is in the public interest. UAS technology used for these commercial purposes benefitthe public interest in the following ways:Feel Good Now, LLC 2 • Reduces the collateral damage risks to life and property associated with low altitude helicopter operations in undesirable portions ofthe height
-velocity envelope.
• Increased public awareness regarding safe and responsible utilization ofUAS.
• 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 runoffand increased crop yields.
• More efficient and frequent inspection ofinfrastructure due to reduced cost.
• Additionally, I committo hiring appropriately qualified pilots and observers from the local communitywhenever 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. AppendixA

– Inspire 1 Operating Documents VIII. Appendix B

– S1000 Operating Documents IX. Appendix C

– Phantom operating DocumentsFeel Good Now, LLC 4

**I. Regulations**  **– Exemptions**  **requested** Pursuantto 14 C.F.R. § 11.81(e), Feel Good Now, LLC. seeks exemption from the below mentioned regulations and provide reason as to whythe exemption should be approved based on the level ofsafety at least equal to that ofwhich the rules require. **14 C.F.R.**  **Part 21**  **Subpart H**  **– Airworthiness**  **Certificates Establishes:**  The procedural requirements for the issuance ofairworthiness certificates as required by 14 C.F.R. § 91.203(a)(1). Given the small size ofthe UAS and the safeguards thatwill be taken as outlined below, an exemption from Part 21 Subpart H meets the requirements ofan equivalent level ofsafety under Part 11 and Section 333 ofthe FMRA with consideration “ofthe size, weight, speed, operational capability, and proximityto airports and populated areas ofthe 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 meetthe intent ofthe 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 Limitation** **s 14**  **C.F.R. §**  **61.113:** (a) Except as provided in paragraphs (b) through (g) ofthis section, no person who holds a private pilot certificate may act as pilot in command ofan aircraftthat is carrying passengers or property for compensation or hire; nor may that person, for compensation or hire, act as pilot in command ofan aircraft. (b) A private pilot may, for compensation or hire, act as pilot in command ofan 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 ofan aircraft

– (ii) For compensation or hire, provided the person is qualified in accordance with this part and with the applicable parts ofthis 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 ofcaution following the procedure outline below, our operations will achieve an equivalent level ofsafety for each individual flight especially when compared to commercial flights identified in Part 61 when originally developed. OurFeel Good Now, LLC 5

operation will be conducted with pilots who hold, at a minimum, a private certificate ofany category or class and a 3 rdclass 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. Currentlythere 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 ofan in
-flight emergency or other unsafe condition. By complying with procedures outlined by the manufacturer, an equivalent level ofsafety will be achieved. **14 C.F.R.**  **91.9(b) civil**  **aircraft flight**  **manual, marki** **ng, and**  **placard requirements**  (b)(2) prohibits operation ofU.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 meetthe intent ofthe regulations and therefore achieve an equivalent level of safety. **14 C.F.R.**  **91.109(a) –**  **Flight Instruct** **ion** 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 ofpredetermined GPS enabled waypoints programmed before or during flight in addition to the use ofa single hand held transmitter or control station controlled by the PIC. The design does not allow for dual controls during flighttraining and therefore the exemption is requested to train operators, build experience, and maintain proficiency. An equal level of safetywill 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**  Exceptwhen necessary for takeoffor landing, no person may operate an aircraft below the following altitudes: (a) Over any congested area ofa city, town, or settlement, or over any open air assembly ofpersons, an altitude of 1,000 feet above the highest obstacle within a horizontal radius of2,000 feet ofthe aircraft. (b) Over other than congested areas. An altitude of500 feet above the surface, except over open water or sparsely populated areas. In those cases, the aircraft may not be operated closer than 500 feetto any person, vessel, vehicle, or structure. (c) Helicopters, powered parachutes, and weight
-shift
-control aircraft. Ifthe 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 offuel; combined with operation limitations listed below, the operation will be conducted with a greater level ofsafetythan exists with current manned aviation operations.Feel Good Now, LLC 6

**14 C.F.R.**  **91.121 –**  **Altimeter Settings**  Each person operating an aircraft shall maintain the cruising altitude or flight level ofthat 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 ofsafety. **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 forecastweather conditions) there is enough fuel to flyto the first point ofintended 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 ofa traditional aircraft, which have flighttimes ofseveral hours or greater; therefore, with the majority of sUAS which have flight times ofonly an hour or less, this regulation would effectively deny the ability ofthe 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% atwhich 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 ofsafety. **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 ofan aircraft

—(a) Shall have that aircraft inspected as prescribed in subpart E ofthis part and shall between required inspections, except as provided in paragraph (c) ofthis section, have discrepancies repaired as prescribed in part 43 ofthis chapter **91.407(a)(1) States** : (a) No person may operate any aircraftthat 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 ofthis chapter. **91.409(a)(2) States:**  (a) Except as provided in paragraph (c) ofthis section, no person may operate an aircraft unless, within the preceding 12 calendar months, it has had

—(2) An inspection for the issuance ofan airworthiness certificate in accordance with part 21 of this chapter. No inspection performed under paragraph (b) ofthis 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) ofthis 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 notFeel Good Now, LLC 7

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 meetthe intent ofthese regulations, I will maintain daily logs ofpre and post flight inspections. Ifmaintenance is required, a dedicated test flightwill 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 meetthe intent ofthe regulations from which exemption is being requested and lead to an equivalent level ofsafety. **II. Commercial**  **Operator/Operation** Initially, One ofour pilots holding at least a private pilots license will be the operator ofthe exempted UAS, with subsequent hiring ofemployees to follow. Co
-founder and myselfare very educated in UAS subject matter and believe our knowledge is what is needed to operate successfully and efficiently. I requestthat my future employees be exempt from§ 61.113 (a) and (b) allowing operations ofmy UAS for compensation or hire, possessing only a private pilot certificate and 3rdclass medical. A private pilot certificate will demonstrate a safe and equivalent level ofaeronautical safety, judgment, security and responsibilityto 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 ofcustomer property or authorized access areas. Will conduct preflight planning in accordance with Section 91.103 PreflightAction. Will operate in those areas onlywith the consent ofthe landowner or designated representative. Will identify potential obstructions or other hazards to safe operation. Will clear the area ofpersonnel 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 ofboth 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 ofvisibility. Will not exceed an altitude 400 feetAGL as determined by the installed GPS. Will keep operating documents, manuals, authorizations and exemptions in a binder collocated with the GCS. Will immediatelyterminate flight, in the safest manner possible, when safetyto persons or property become compromised.Feel Good Now, LLC 8

• Will terminate flight, in the safest manner possible, when unable to complywith these limitations or any other limitations granted as part ofthis exemption. In order to remain at an altitude at or below 400 feetAGL, reliefis needed from Section 91.119 (c) and (d). By following these operating standards, the commercial operation will meet an equivalent level ofsafetyto the regulation in which reliefis sought. **III. Unmanned**  **Aircraft System**  I seek an exemption to operate the DJI line ofUAS. 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 carrythe 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 ofRC signal, loss ofGPS, and low battery as outlined in the respective Operation Manuals. The UAS display a visual low battery alert at 25% atwhich 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 aircraftwill be operated within VLOS with the aid ofa VO, I believe the operation can be conducted with an equivalent amount ofsafety 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 ofthe 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 inspectionswill be conducted according to operations manual and prudentjudgment as previously outlined to determine the integrity and safety ofthe UAS and associated equipment. Further, I require relieffrom 91.7(a), which prohibits the operation ofan aircraftwithout 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 carrythe operating documents so an equivalent amount ofsafety 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 ofsafety as current regulation because my UAS do not carry any pilots or passengers. A commercial pilotFeel Good Now, LLC 9

certificate will not ensure RC piloting ability, as the psychomotor skills are different. The inherent risks ofoperating 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 PilotPrivileges andLimitations: Pilotin command. All UAS PICs will have logged, in accordance with 61.51 (b), appropriate training on the UA consisting of25 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 ofUAS Set
-up and configuration ofRC radio and GCS System checks Mission Tasks Establish flight plan Takeoffand 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 ofphotography, videography, inspection ofinfrastructure, precision agriculture, and scientific & environmental research will ultimately be in the public interest. These operations, when executed with prudence, will exceed the current level ofsafety as the regulations from which I seek exemption. My operation will allow greater access to commercial aerial services thatwere 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 ofcollateral damage to persons and propertywhile limiting disruptive noise pollution associated with low altitude aviation operations. A major factor to consider regarding the public interest is the current state ofUAS operations in the US. As a manned aviator, the need to integrate UAS into theFeel Good Now, LLC 10

national airspace system in a safe, deliberate manner is always at the forefront ofmy mind. As the technology becomes more readily available, the challenges will intensify. By allowing commercial operations, itwill enable communities to become educated in the proper use ofthis technology. As an educator, I am alreadyworking to foster positive awareness and safe, responsible utilization ofUAS technology. Granting my exemption will result in a direct extension ofthese efforts, which is in the public interest. **VI. Summary**  Pursuantto Section 333 ofPL 112
-95 commonly known as the “FAA Modernization and Reform Act of2012”, Joshua D. Guiles, hereby applies for authorization to conduct commercial unmanned aerial systems (UAS) operations for the purposes of photography, videography, inspection ofinfrastructure, 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) Throughoutthis exemption request, I have shown how my expertise and knowledge with UAS technologywill ensure the public’s best interest is at hand and how my operation will aid in saf ely integrating civil UAS into the national airspace system.Feel Good Now, LLC 11 **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 ofa VTOL unmanned aircraft and a transportable ground station. The Inspire 1 UAV has a maximum gross weight ofapproximately 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** Feel Good Now, LLC 12

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 mmFeel Good Now, LLC 13 **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 ofa VTOL unmanned aircraft and a transportable ground station. The S1000 UAV has a maximum gross weight ofapproximately 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**Feel Good Now, LLC 14

Drive PWM Frequency: 8KHz Weight: 35g (with Radiators) Foldable Propeller: (1552/1552R) Propeller Size: 15×5.2inch Weight: 13g TakeoffWeight: 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 TakeoffWeight) Hover Time: 15min (@15000mAh & 9.5Kg TakeoffWeight) 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%Feel Good Now, LLC 15 **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 ofa VTOL unmanned aircraft and a transportable ground station.

Operating Temperature
-10°C ~ 50°C Power Consumption 3.12W Take

-OffWeight <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**