Page | 1 December 17, 2015

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

Re: Petition of Dragonfly Guys for Exemption from Certain Federal Aviation Regulations to Operate Unmanned Aircraft Systems Pursuant to Section 333 of the FAA Modernization and Reform Act

Dear Sir or Madam:

Pursuant to Section333 of the FAA Modernization a nd Reform Act ("FMRA") and 14
C.F.R. part 11, Dragonfly Guys (Dragonfly) hereby petitions the Federal Aviation Administration
("FAA") for exemption from 14 C.F.R. §§ 61.23(a) and (c), 61.101(e)(4) and (5), 61.113(a),
61.315(a), 91.7(a), 91.15l(a)(l), 9 1.119(c), 91.12 1, 91.405(a), 91.407(a)(l), 91.409(a)(l) and
(2), and 91.417(a) and (b), and any other rules the FAA deems necessary, to enable Dragonfly to
operate unmanned aircraft systems ("UAS") for aerial data collection and services . Specifically, Dr agonfly
seeks to operate UAS for aerial photography, facilities inspection, and production assistance using

the DJI Phantom 3 Professional UAS.

I. PROPOSED OPERATIONS AND PUBLIC INTEREST BENEFITS
Dragonfly , an employee

- owned company, is a startup partnership with two principals.
Dragonfly will provide aerial photography services , both photo and video for clients requiring real estate
sales documentation, insurance inspections, news gathering and code enforcement inspections.
UAS can provide a safe and co st

- effective way to achieve these objective s . Grant of this petition
will enable Dragonfly to better serve its customers in its operating area.Page | 2

Permitting Dragonfly to use UAS will result in : Dragonfly's operations will carry minimal risk. Using UAS for aerial photography, visual facility inspection will both eliminate the dangers associated with conducting these activities manually from the ground or in manned aircraft and enable Drago nfly to efficiently and quickly provide needed services. Dragonfly is committed to the safe operation as specified by current FAA regulations, the UAS manufacturer, and
UAS industry recommendations.

Th i s commitment ensure s that Dragonfly will operate safely in the na tional airspace, mi t igate the risks of harming other aircraft or people or prope r ty on the ground, and present no threat to national security.

II. THE UAS
Dragonfly requests an exemption to operate the DJI Phantom 3 Professional which is well below 55

po unds including payload. Through the Section 333 exemption process, the FAA has authorized use of all UAS for which e xemption is requested

.
III. APPLICANT INFORMATION
The name and contact information of the applicant is:

James R. Adair , Partner Dragonfly G uys 509 Bryan St. Weatherford, Texas 76086 (817946

- 4818 radair1914@yahoo.com

IV. REGULATIONS FROM WHICH EXEMPTION IS REQUESTED
14 C.F.R. §§ 61.23(a) and (c);
14 C.F.R. §§ 61.101(e)(4) and (5);
14 C.F.R. § 61.113(a);
14 C.F.R. § 61.315(a);
14 C.F.R. § 91.7(a);
14 C.F.R. § 91.119(c);
14 C.F.R. § 91.121;Page | 3 14 C.F.R. § 91.151(a)(l);

14 C.F.R. § 91.405(a);
14 C.F.R. § 91.407(a)(1);
14 C.F.R. §§ 91.409(a)(l) and (2);
14 C.F.R. §§ 91.417(a) and (b).

V. OPERATING PARAMETERS
Dragonfly will ad here to the following operating parameters when operating a UAS pursuant
to a grant of the requested exemption:
1. Operations will be conducted using the DJI Phantom 3 Professional

. 2. The UAS will not be operated at a speed exceeding 87 knots (1 00 miles per hour), at an altitude greater than 400 feet above ground level, or, when visibility is less than 3 statute miles, less than 500 feet below or 2,000 feet horizontally from cloud s . All operations will be conducted during the day under visual flight conditions.
3. All operations will be conducted in accordance with a Ce r tificate of Waiver or Authorization ("COA'').
4. All operations will use a pilot

- in

- command ("PIC") and a visual observer ("VO"), and the UAS will remain within the visual line of s ight of the PIC or the VO at all times. The PIC will maintain VLOS capability and the ability to communicate verbally with the VO during the duration of the flight.
5. The PIC will hold an airline transp ort , commercial, private, recreational, or sport pil ot certificate, as well as an FAA ai r man medical certificate or a valid U.S. driver's license. The PIC will meet the flight review requirements specified in 14 C.F.R. § 61.56 in an aircraft in which the PIC is rated on his or her pilot certificate.

6. Dra gonfly will ensure prior to operation that the PIC has demonstrated the ability to safely operate the UAS in a m ann er consistent with how the UAS will be operated under this exemption, including evasive and emergency maneuvers and maintaining appropriate d istances from persons, vessels, vehicles and st ru ctures. PIC qualification flight hours and currency will be logged in a m ann er consistent with 14 C.F.R. § 61.51(b).
7. Dragonfly's operating documents will be accessible during UAS operations and made avai lable to the Administrator upon request.Page | 4

8. Prior to each flight, the PIC will conduct a pre

- flight inspection and determine the UAS is in a condition for safe flight. If the inspection reveals a condition that affects the safe operation of the UAS, the U AS will not be operated until the necessary maintenance has been performed and the UAS is found to be in a condition for safe flight.

9. If the UAS has undergone maintenance or alterations that affect the UAS operation or flight characteristics, e.g., rep lacement of a flight critical component, it will undergo a functional test flight prior to conducting fu r ther operations under this exemption.
10. Dragonfly will follow the UAS manufacturer's maintenance, overhaul, replacement, inspection, and life limit requirements, as well as safety bulletins, for the aircraft and aircraft components.

11. The PIC will ab or t the fl ight in the event of unpredicted obstacles or emergencies, and will yield to all manned aviation activities.
12. Dragonfly will register and mark its UAS in accordance with 14 C.P.R. parts 47 and 45.

VI. THE FAA'S AUTHORITY TO GRANT THIS PETITION
The FAA has authority to grant the exemption requested herein under the FMRA and the Federal Aviation Act. Section 333 of the FMRA deals specifical ly with integrating UAS into the national airspace, and directs the Secretary of Transportation to determine which UAS, "as a result of their size, weight, speed, operational capability, proximity to airports and populated areas, and operation within visua l line of sight do not create a hazard to users of the national airspace system or the public or pose a t hreat to national security." Section 333 further directs the Secretary to "establish requirements for the safe operation of such aircraft systems in th e national airspace system. " The Federal Aviation Act authorizes the Administrator of the FAA to grant exemptions from regulations prescribed under certain provisions of the Act where such exempti ons are in the public interest. Pa r t 11 of the Federal Avia tion Regulations governs the FAA's exemption process and requirements. The FAA has granted more than 2,600 exemptions to date pursuant to its Section 333 and exemption authority, enabling commercial UAS operations in a wide variety of industries.

VII. SUM MARY TO BE PUBLISHED IN THE FEDERAL REGISTER
Should the FAA determine that publication in the Federal Register is required, Dragonfly offers the following summ ar y pursuant to sec tion 11.81 of the FAA's rules:
Petitioner: Dragonfly GuysPage | 5

Sections of 14 C. F R. Affected: 14 C.F.R. §§ 61.23(a) and (c); 14 C.F.R. §§ 61.101(e)(4) and (5); 14 C.F.R. § 61.113(a); 14 C.F.R. § 61.315(a); 14 C.F.R. § 91.7(a); 14 C.F.R. § 91.119(c); 14 C.F.R. § 91.121; 14 C.F.R. § 91.15l(a)(l); 14 C.F.R. § 91.405(a); 14 C.F.R. § 91.407 (a)(l); 14 C.F.R. §§ 91.409(a)(1) and (2); 14 C.F.R. §§ 91.417(a) and (b).
Description of Relief Sought : Petitioner seeks relief from the requirements of 14 C.F.R. §§ 61.23(a) and (c); 14 C.F.R. §§ 61.101(e)(4) and (5); 14 C.F.R. § 61.113(a); 14 C.F.R. § 61.315(a); 14 C.F.R. § 91.7(a); 14C.F.R. § 91.119(c); 14 C.F.R. § 91.121; 14 C.F.R. § 91.151(a)(l); 14 C.F.R. § 91.405(a); 14 C.F.R. § 91.407(a)(1); 14 C.F.R. §§ 91.409(a)(l) and (2); 14 C.F.R. §§ 91.417(a) and (b) to operate unmanned aerial systems for ph otography, aerial inspections, and commercial production.

VIII. CONCLUSION
As demonstrated above, the UAS operations Dragonfly has proposed in this petition for
exemption will garner significant public benefits by the creation of economic activity, while presenting minimal safety risks.
Dragonfly's petition satisfies the criteria of Section 333 of the FMRA and respectfully requests that the FAA grant this petition to enhance Dragonfly's ability to provide beneficial services to business and the public

.

Sincerely,

James R. Adair
Dragonfly Guys