U.S. Dept. of Transportation, Docket Operations

We st Building Ground Floor, Room w12
- 140 1200 New Jersey Avenue Wa shington, DC 20590 Re: Exemption Request under Section 333 of the FAA Reform Act and Part 11 of the Federal Aviation Regulations. Document ID:
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, The Miami
- Dade Police Department seeks an exemption from Federal Aviation Regulations (“FARs”) detailed below for the following described Unmanned Aerial System called in this application DJI Inspire 1, Phantom 2, and Phantom 3 , wh ich includes an Unmanned Ariel System (UA S ) and ground station
- based equipment and
crew:
THE UNMANNED SYSTEM (UA S ): DJI Inspire 1 , Phantom 2, and Phantom 3 : See enclosed Manual s . The inherent safety features, sophistication, programmability, GPS navigation, return home capability, airport vicinity no
- fly feature and restricted altitude feature, as well as differentiating radio frequency (rf) for aircraft controller/receiver and for the camera make this a much safer UA S fo r the purposes of this petition. This is a radio controlled UA S that has the capacity for software upgrades. It is light, less than 7 pounds including battery and camera. Incorporated into the programming of th es e DJI UAS ’ s is an automatic return home feature that automatically directs the craft back to point of take off should communication with the transmitter be lost. The Inspire1 has a maximum speed of 4 9 miles/hour. Maximum flight time is 18 minutes. Gross weight is 6.5 pounds. The Phantom 2 has a maximum speed of 15 miles/hour. Maximum flight time of 25 minutes. Gross weight is 2.2 Pounds. The Phantom 3 has a maximum speed of 16miles/hour. Maxim um flight time of 30 minutes. Gross weight is 2.8 Pounds.

The DJI UAV’s have an additional communication link between the camera and craft on a different remote frequency fo r a smart phone connection. Allowing the operator or Pilot In Command (PIC) to monitor battery level, altitude (AGL), distance from PIC, camera imagery, and control camera angle. The software for the DJI UAS ’s allows the operator or PIC to set maximum altitude AGL for each flight, allowing customization of flights to no higher tha n 150 feet can be programmed into the UA S 's software pre
-flight to insure compliance with FAA standards. Adding to the safety capabilities of this UA S . This UA S is programmed to remain in position when controls are released. Maintaining altitude and GPS location. All three DJI UAS ’s has an altitude and radar monitoring function that allows the operator more precise determination of height, direction of flight and distance from the operator ( PIC ) . The operator or PIC can monitor GPS lock status while U AS is in flight, with the ability to anticipate loss of GPS locking so the operator or PIC can land the UAV as a precaution. The DJI UAS ’s are also equipped with a new safe dynamic return to home function and automatic safe landing and taking off modes. The intelligent battery also calculates how much power is needed to safely return home. The requested exemption would support an application for a commercial Certificate of Authorization to use the above described CAV System to support aerial photography and videography. The UAS , powered by batteries, is smaller, lighter and more maneuverable than larger aircraft running on combustible fuel, it operates at lower altitudes with no people on bo ard and will thereby reduce current risk levels and thereby enhance safety and diminish the likelihood of death or serious bodily injury. Wi th a small payload and maximum flight time of only 30 minutes, this is offers little or no risk to national security.Low level oblique photos and video from several angles are far more effective than

ground
- based imagery for displaying the characterist ics of large, structures and properties. Additionally, we request that we be allowed to use our system to benefit municipal Law enforcement Departments who might require assistance, including fire fighters , and other Federal Agencies. The three DJI UAS ’s will be operated in the field with bo th a PIC and a Visual Observer in accordance with FAA Policy N 8900.227 Section 14 "Operational Requirements for UA S " and with the following Restrictions: (a ) All operations must be within the restrict ions of The Florida State Statutes governing UAS Operations; ( b ) No flight will be made with a UA S Gross weight exceeding 55 pounds; ( c ) All operations must occur in FAA Class G airspace at no more than 400 ft AGL, at an airspeed of no more than 25 knots and no further than 3/4 NM from the PIC; ( d ) (All operations must utilize a visual observer (VO). The VO and PIC must be able to communicate by voice at all times during a flight operation; (e) The PIC must have accumulated and logged, in a manner consistent with 14 CFR § 61.51 (b), a minimum of 100 flight cycles and 25 hours of total time as a UA rotorcraft pilot and at least ten hours logged as a UA pilot with a similar UA type; (f ) The DJI UAS ’s will not be operated within 5 NM of an airport or heliport; (m) Operations will be conducted dur ing VFR conditions with at least Class E weather minimums; (n) The PIC will brief the VO and command staff about the operation and risk before the first flight at each new location;(o) No flight may be made without a Pre
- Flight Inspection by the PIC before each

operation to ascertain that the UA S is in a condition safe for flight. T he PIC and VO will perform maintenance on the system and will complete a course of maintenance instruction as part of their initial training. Wesubmit that the combination of the UA's light weight, flight performance and ability, fully qualified flight crew and strict operation under the guidelines established in 8900.227, and under all of the Restrictions (a) through (o) listed above, the FAA can have full co nf idence that the operation will have an equivalent or greater level of safety than manned aircraft performing the same mission. The name and contact information of the applicant are: Miami
- Dade Police Department Sergeant Jose Gonzalez 1563 N W 79 Avenue Miami, Fl 33018 Tel: 786 390
- 2730 Email: J.Gonzalez@MDPD.com I am prepared to modify or amend any part of this request to satisfy the need for an equivalent level of safety. Please contact us at any time if you require additional information or clarif ication. Many thanks for your time. Sincerely, Jose Gonzalez