### 1415	Marietta	Road

Lancaster,	Ohio		43130 Phone:	740.407.4542 E
-mail:	clandis2015@outlook.com October	22nd

### ,	2015 **U.S.	Department	of	Transportation** Docket	Management	System 1200	New	JerseyAve.,	SE Washington,	DC,	20590 **RE: Exemption**  **Request Under**  **Section 333**  **of the**  **FAA Modernization**  **and Reform**  **Act	of 2012	and	14	C.F.R.	Part	11**  Dear	Madam,	Sir, Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 and 14 C.F.R. Part 11, Aero Drone Design & Logistics seeks an exemption from the Federal Aviation Regulations	detailed	below	for	the	DJI	Inspire	1	UAS.	The	UAS	has	a	maximum	gross	takeoff weight of 1.30 kilograms. The proposed UAS is multi
-rotor aircraft utilizing lithium polymer batteriestoo power four (4) electric motors, each motor driving one propeller, all of which provide propulsion. This UAS is a commercial platforms manufactured by DJI Inovations; an aero drone manufacturing company with a proven track record and has been widely accepted by a large number of commercial drone operators under numerous FAA	Certificates	of	Autorization	(COA). The	requested	exemption	will	enable	Aero	Drone	Design	&	Logistics	to	conduct	commercial operations involving aerial data collection using a small unmanned aircraft system. The system indicated above will be used to conduct data acquisition for agricultural applications, aerial inspections, aerial mapping, aerial surveying, R&D for further drone development, R&D to further enhance safety and operational procedures, and future product and service demonstrations. Aero Drone Design and Logistics will operate in accordance with FAA N 8900.227 and utilize both a pilot in command (PIC) and a ground
based	visual	observer (VO).	Aero	Drone	Design	&	Logistics will	also	utilize	emergency,	lost link, and lost communication procedures that are available upon request. All flights under these	exemptions	will	be	conducted	with	the	following	restrictions: 1. All UAS flight operations will be conducted in Class G airspace at altitudes less than 400’	AGL.

### 2. All UAS	flight	operations	will	be	conducted over	private	property,	and onlywiththe

permission	of	thepropertyowner. 3. No	flight	operationswill	be conductedover	populated	areas. 4. No flight operations will be conducted within 5 NM of public civilian or military airports. 5. All flight operations will be conducted during daylight hours and in visual meteorologicalconditions (VMC)
. 6. The PIC will ensure at all times the UAS being operated remain within visual line of sight	of	the PIC	or	the	VO	and	will	remain	within	1⁄2	nautical	mile	of	the	PIC. 7. A	NOTAM	will	be	issued	prior	toany	flight	operation
. 8. No flight operations will be conducted utilizing a UAS with a maximum gross take
off	weight	(GTOW)	of	more	than 55	lbs. 9. No flight operations will be conducted utilizing a UAS unless the aircraft displays a proper U.S.	registration	number
. 10.All PICs andVOs	will	possess certifications	requiredunder	N	8900.227
. 11. No operator or observer will engage in, nor may an operator or observer permit, any activity during a critical phase of flight which could distract any operator or observer from the performance of his/her duties or interfere in any way with the proper	conduct	of	his/her	duties. 12. The PIC will conduct a pre-flight inspection prior to each flight in order to ensure the UAS intended for current operations and the UAS associated systems are in a conditionwhich	will	permitsafe	operation. 13. During all flight operations, the PIC and VO will maintain two-way communications. ifunable to maintain two-way communications, or ifany condition occurs that may otherwise cause the flight operation to be unsafe, the operator will immediately conclude	theflightoperation. 14. The aircraft intended for use (see paragraph one) will have the capability to automatically return to a specific location ifthe communications link is lost at any time	during	flight	operations. 15. 

### All	flight	operations	will	be	conducted	below	70mph	as	derived	UASs	onboard	GPS.

### The regulations from which the exemption is requested are as follows (the Appendix

contains	detailsofAero	Drone	Design	&	Logistics operations	related	to	showing	an	equivalent level	of	safety	for	these	exemptregulations). 14	C.F.R.	Part	21,	Subpart	H 14	C.F.R.	§91.203(a)	and	(b) 14	C.F.R.	§45.23(b) 14	C.F.R.	§61.23(a) 14	C.F.R.	§61.113(a)	and	(b) 14 C.F.R.	§61.133(a) 14	C.F.R.	§91.7(a) 14	C.F.R.	§91.9 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.	Subpart	E	(§91.401
- §91.417) UAS	Overview Aero Drone Design & Logistics is submitting this request for the DJI Inspire 1 multi
-rotor platform
. These commercially available systems from DJI have demonstrated reliability, as well as popularity among hobbyists and professionals. Aero Drone Design & Logistics has expertise and knowledge in the operation of this system. Aero Drone Design & Logistics will adhere to training and operational procedures that follow the guidelines presented in N	8900.227	and	the	guidelines	and	safety	recommendations	as	published	by	DJI. Aero Drone Design & Logistics intends on utilizing the DJI Inspire 1 UAS to pursue further commercial applications. The DJI Inspire 1 UAS is a multi
-rotor aircraft which utilizes electric propulsion supplied by lithium polymer batteries
. Figure 1 below contains an image ofthe DJI Inspire 1 UAS. Experts proposesthatthe small size andweight ofthe UAS included in	this request	for	exemption,	flown	under	the	guidelines	ofN 8900.227,	will	have an	equivalent	level	of	safety	to	manned	aircraft	performing	similar	missions.

Figure 1

### Aircraft	Dimensions	Weight (**DJI	INSPIRE	1**)

Dimensions: 17”	x	18”	x	12” Weight: 6.5	Lbs.
The	name	and	contact	information	of	the	applicant	are:

Aero	Drone	Design	&	Logistics,	LLC Attn:	Christopher	A.	Landis Phone:	740.407.4542 E
-mail:clandis2015@outlook.com
**Aero Drone**  **Design &**  **Logistics requests**  **exemp tion**  **under Section**  **333 for**  **the purpose**  **of providing**  **safe ,**  **commercial UAS**  **flight operations**  **for the**  **activities stated.**  **By approving**  **these exemptions**  **the FAA**  **will create**  **benefit s**  **to the**  **areas mentioned**  **that are,**  **ultimately ,**  **in the**  **public interest.**  **Please contact**  **us if** **you require**  **additional information	or	clarifi** **cation.** Sincerely,

Christopher	A.	Landis President Aero	Drone	Design	&	Logistics,	LLC

### A**PPENDIX**

**Specific Exemption Requests and Equivalent Level of Safety Show** **ings 14 C.F.R. Part 21, Subpart H: A** **irw orthiness Certificates**  **14 C.F.R. §91.203(a) and (b)**  **- Civil aircraft: Certifications required.**  Section 91.203 requires all civil aircraft to have a certificate ofairworthiness. Part 21, Subpart H, entitled Airworthiness Certificates, establishes the procedural requirements for the issuance of airworthiness certificates as required by FAR §91.203(a). Aero Drone Design & Logistics requests an exemption from these rules and will utilize an internal airworthiness process based on the following DJI manuals:  Inspire 1 User Manual  Inspire 1 Safety Guidelines  Inspire 1 Intelligent Flight Batter Safety Guidelines  1345s Quick

-Release Propeller for the Inspire 1  Inspire 1 Maintenance Manual Such an exemption meets the requirements of an equivalent level of safety under Part 11 and Section 333 of the Reform Act. The Federal Aviation Act and Section 333 of the Reform Act both authorize the FAA to exempt aircraft from the requirement for an airworthiness certificate, upon consideration of the size, weight, speed, operational capability, and proximity to airports and populated areas of the UAS involved. **14 C.F.R. §45.23(b) -**  **Display of marks; general.** These regulations provide that each aircraft must display "N" and the aircraft’s registration number in letters at least 3 inches high. Additionally, the aircraft must display the word "EXPERIMENTAL" in letters at least 2 inches high near the entrance to the cabin, cockpit, orpilot station. Given the size of the UAS (fuselage length of 17”’), this requirement is impossible to match. The equivalent level of safety will be achieved by having the registered N
-number in 1 inch lettering on the side of the fuselage. **14 C.F.R. §61.23(a) -**  **Me dical certificates: Requirement and duration.**  Regulations provide that a person must hold at least a second class medical certificate when exercising:

 Second
-in
-command privileges of an airline transport pilot certificate in part 121 of this chapter (otherthan operations specified in paragraph (a)(1)(ii) of this section); or

 Privileges of a commercialpilot certificate Given the size of the UAS in this petition and the limited flight area and the safety features integrated in the autopilot

, Aero Drone Design & Logistics believes that an equivalent level of safety can be maintained if the operator has a valid driver’ s license. **14 C.F.R. §61.113(a) and (b), §61.133 -**  **Private Pilot Privileges and Limitations: Pilot in Command;**  **Commercial Pilot Privileges and Limitations** Subsections (a) and (b) of §61.113 prohibit private pilots from operating aircraft in commercial operations, and §61.133(a) requires an individual operating an aircraft for compensation or hire to hold a commercial pilot certificate. Aero Drone Design & Logistics requests an exemption from 14 C.F.R. §61.113(a) and (b) and 14 C.F.R. §61.133(a) so that UAS specified in this exemption may be operated by individuals who have a private pilot certificate. Based upon the design features ofthe UAS, its autopilot system, and safety factors, theFAA should permit operation of the UAS by operators with a private pilot certificate when the conditions

described above have been satisfied. The above
-described conditions are in
-line with those set forth i n Volume 16, Chapter 4, Section 1 of FAA Order 8900.1. Aero Drone Design & Logistics proposes to conduct operations in accordance with these restrictions. Given these conditions and restrictions, an equivalent level of safety to manned flight operations will be maintained by drone operators who possess a private pilot certificate. The risks associated with the operation ofthe DJI Inspire1 multi
-rotor aircraft (considering the size, speed, operational capabilities, and lack of combustible fuel) are considerably less than the level of risk associated with manned fixed wing and rotorcraft operations, both private and commercial, as contemplated by Part 61. T herefore, permitting operation of DJI Inspire 1 UAS, as set forth above, meets or exceeds the present level of safety provided under 14 C.F.R. §61.113(a) and (b) and §61.133(a). **14 C.F.R. §91.7(a)**  **- Civil aircraft flight manual, marking, and placard requirements**  This regulation requires that no person may operate a civil aircraft unless it is in airworthy condition. Aero Drone Design & Logistics requests that an exemption be grantedpermitting commercial operation without an airworthiness certificate. Given the size of the aircraft, self
-certification utilizing the following DJI manuals will provide an equivalent level of safety:  Inspire 1 User Manual  Inspire 1 Safety Guidelines  Inspire 1 Intelligent Flight Batter Safety Guidelines  1345s Quick

-Release Propeller for the Inspire 1  Inspire 1 Maintenance Manual **14 C.F.R. §91.9(b) -**  **Civil aircraft flight manual, marking, and placard requirements.** This regulation provides that no person may operate an aircraft unless a current, approved flight manual is located in the aircraft. Aero Drone Design & Logistics assumes that the intent ofthis requirement is to ensure that aircraft safety of flight an operational information located in the flight manual is available to the aircrew while operating the aircraft. Aero Drone Design & Logistics requests an exemption to this requirement since the aircraft is unmanned of a size in which placing aircraft manuals on board the UAS during flight is not practical, and documented operating and safety offlight information would not be available to the crew. The equivalent level ofsafety will be achieved by keeping a hard copy ofthe following DJI manuals with the PIC on the ground during flight operations:  Inspire 1 User Manual  Inspire 1 Safety Guidelines  Inspire 1 Intelligent Flight Batter Safety Guidelines  1345s Quick

-Release Propeller for the Inspire 1  Inspire 1 Maintenance Manual **14 C.F.R. §91.109(a) -**  **Flight instruction; Simulated instrument flight and certain flight tests**  Sections 91.109(a) provides that no person may operate a civil aircraft that is being used for flight instruction unless that aircraft has fully functioning dual controls. The UAS indicated in this exemption are remotely piloted aircraft, and, by design, not equipped with fully functional dual controls. Flight control is accomplished through the use of a control box that communicates with the aircraft via radio communications. Utilizing a pilot skilled in remote controlpiloting will provide an equivalent level of safety. **14 C.F.R. §91.119 -**  **Minimum safe altitudes: General.** The regulation provides that over sparsely populated areas the aircraft cannot be operated closer than 500feet to any person, vessel, vehicle, or structure. Since the UAS indicated in this exemption will be

operating at a maximum of 400 feet AGL, the requirement s of this regulation cannot be adhered to

. In order to provide an equivalent level of safety Aero Dr one Design & Logistics will only fly over private property with the permission of the land owner. The land owner will be briefed on the intended route of flight and the associated risks to persons and property on the ground. Aero Drone Design & Logistics maintains that

, due to the small size ofthe DJI Inspire 1 UAS, the hazar d to persons and property is not comparable to manned aircraft , and should be considered in granting the exemption. Furthermore, Aero Drone Design & Logistics will not operate over congested areas, nor over any open air assembly of persons. **14 C.F.R. §91.121 -**  **Altimeter settings.** The regulation states that aircraft shall maintain cruising altitudes by reference to an altimeter setting available within 100 nautical miles of the aircraft. The UAS will fly below 400 feet AGL and will not need to maintain hemispherical cruising altitudes in order to maintain required altitude separation with other aircraft. In order to maintain an equivalent level of safety, the DJI Inspire 1 autopilot calculates the reference altitude (

the UAS altitude while positioned on the ground ) and compares that altitude with the altitude determined by the on-board GPS during the pre-flight tests. The GPS and barometer data are then used to calculate the altitude in
-flight. **14 C.F.R. §91.151(a) -**  **Fuel requirements for flight in VFR conditions.** The regulation states that no person may begin a flight in an airplane under day
-VFR conditions unless there is enough fuel to fly to the first point ofintended l anding and to fly after that for at least 30 minutes. T he DJI Inspire 1 UAS utilizes a lithium polymer battery to provide power to the propulsion system. Therefore, since the UAS does not carry fuel on board, the requirements in this regulation are not applicable

. An equivalent level ofsafety is achieved through a low batterypower warning. The PIC has the ability to select the percentage of battery power remaining in which this warning is displayed. The DJI Inspire 1 UAS are designed to automatical ly return to base and land safely when the battery power becomes low, but before the battery power becomes low enough to become a safety of flight issue. **14 C.F.R. Subpart E (§91.401 -**  **§91.417) -**  **Ma intenance, Preventive Maintenance, and A** **lterations** The regulation provides that the operator is primarily responsible for maintaining the aircraft in an airworthy condition, including compliance with part 39 and 43. Paragraphs 91.407 and 91.409 require that the aircraft be "approved for return to service by a person authorized under 43.7" after maintenance and inspection due to the small size and simplicity of the DJI Inspire 1, it is the intent of Aero Drone Design & Logistics to authorize the PIC to perform maintenance and inspection of the aircraft and appr ove the aircraft for return to service. The PIC will ensure that the aircraft is in an airworthy condition prior to flight and conduct detailed inspections after every 10 flight hours. Additionally, checklists will be utilized with all of the necessary pre-flight procedures prior to every flight operation. The PIC will document workperformed in accordance with 91.417. Due to the small size, construction, and simplicity of the aircraft, Aero Drone Design & Logistics believes the PIC is able to ensure an equivalent level of safety.