Digital Mapping and Graphics

6346 N. Shade Tree Lane

Springfield MO 65803

 Telephone : (417) 350-4037 Email: billisenberger@yahoo.com

15 June 2015

U.S. Department of Transportation 

Docket Management System, M-30 

Room W12-140, West Building Ground Floor 

1200 New Jersey Ave., SE 

Washington, DC 20590-0001

Re: Exemption Request under Section 333 of the FAA Reform Act and Part 11 of the Federal

Aviation Regulations

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, Digital Mapping and Graphics (DMG) seeks an exemption from the

Federal Aviation Regulations (“FARs”) listed below in Table 1. 14 CFR Regulations from

which Exemption is Being Sought.

The requested exemption would authorize DMG to undertake unmanned aircraft operations

designed to gather aerial data for the purpose of developing increasingly accurate and precise

spatial images to assist in the more efficient and comprehensive management of a diverse set of

landscapes including natural areas, parks, and agricultural fields.

The point of contact for this exemption request is

Mr. William H. Isenberger, CEO

Digital Mapping and Graphics

6346 N. Shade Tree LN

Springfield MO 65803

email: billisenberger@yahoo.com

phone: (417) 350-4037 (cell)
Digital Mapping and Graphics

6346 N. Shade Tree Lane

Springfield MO 65803

 Telephone : (417) 350-4037 Email: billisenberger@yahoo.com

2

BACKGROUND

DMG is a sole proprietorship, owned, and operated by William H. Isenberger established in the

State of Missouri in 1991 to provide comprehensive and highly accurate images, maps, and

models of diverse landscapes within various Geographic Information System (GIS) environments. 

These images and models, created using an ever more sophisticated array of technological

resources, have been used by a wide variety of researchers including geologists, plant ecologist,

wildlife biologists, and archeologists as well as natural resource managers from numerous private

and public agencies.

In anticipation of the incorporation of UAS into DMG’s technological resources, Isenberger

became involved in the operation of UAS as an avocational practice in early 2013 and began the

design and development of UAS systems/crafts shortly thereafter. Since that time he has logged

several hundred avocational hours of UAS flight time over a wide variety of landscapes.

DESCRIPTION OF CRAFT

The craft to be used in DMG operations is the DMG 560, serial number DMG 2015201. It was

designed and built by its owner, William H. Isenberger, and was registered with the Federal

Aeronautics Administration (FAA) as N 541 HW on 18 March 2015. The craft’s designated

number, N 541 HW, will be displayed as prominently as possible on the DMG 560.

The DMG 560 is a quad-copter constructed with carbon fiber, aluminum, and plastic materials.

The weight of the craft is 1.3 kg and it has a height (with antenna) of 160mm. The DMG 560 has

a diameter of 560mm when using aluminum arms, 600mm when using standard length carbon

fiber arms, and 660mm when using extended carbon fiber arms.

It is powered by four (4) electric brush-less motors using 3 cell (11.1V) or 4 cell (14.8V) Lithium

Polymer (LiPo) batteries.

 

Digital images are captured from the DMG 560 by a Canon PowerShot S110 camera. The

maximum weight of the craft with camera and batteries is less than 2.5 kg. 

The DMG 560 typically operates at a speed of less than 20 mph. Individual fights seldom exceed

a total of 15 minutes.

Surface to air communication with the DMG 560 is maintained with a Spectrum DX7s 2.4GHz 7-

Channel DSMX radio transmitter and an AR8000 8-channel receiver. The flight controller is a

3D Robotics APM 2.6 with GPS and compass.
Digital Mapping and Graphics

6346 N. Shade Tree Lane

Springfield MO 65803

 Telephone : (417) 350-4037 Email: billisenberger@yahoo.com

3

The DMG 560 is equipped with fail safe devices that will either land the craft immediately or

return it to its home position in the event of either battery or radio failure. The DMG 560 also

operates within a GeoFence environment established for each mission that prohibit it from leaving

the spatial limits established for its mission.

The airworthiness of the DMG 560 is evidenced by its over 150 hours of flight time. 

APPLICATIONS

The DMG 560 will be used to capture data suitable for the construction of extremely accurate and

precise images of specific natural and agricultural landscapes as well as detailed images of

archeological properties and excavations.

AREAS OF OPERATIONS

The DMG 560 will be operated entirely over natural and agricultural landscapes populated solely

by project participants.

OPERATIONAL PROCEDURES

All DMG missions will be planned and carried out using the safety standards proposed by the

Academy of Model Aeronautics (AMA) National Model Aircraft Safety Code (1 January 2014). 

Isenberger became a member of the AMA in the late-1990s.

Mission Planning. The initial steps in DMG mission planning is the co-ordination with mission

sponsors and property owners and/or managers. Such co-ordination is designed to identify the

exact spatial aspects of the mission, collect contact information for other potentially interested

parties, and identify areas of potential operational concern. 

Once the desired spatial parameters of the mission are determined members of the mission team

will contact other potentially interested parties so that both the spatial and temporal aspects of the

mission will be satisfactorily co-ordinated to insure that the target area(s) will include only

mission personnel during the period of operation.

The agreed upon spatial components of the mission will be established using a range of

Geographic Information System (GIS) technologies and provided to interested parties for

comment and, if necessary, revised before being finalized.
Digital Mapping and Graphics

6346 N. Shade Tree Lane

Springfield MO 65803

 Telephone : (417) 350-4037 Email: billisenberger@yahoo.com

4

The spatial aspects of the mission will then be used to establish the flight plan and will be loaded

into the flight controller along with the GeoFence established for the mission and the ground

positions of all Visual Observers (VOs) will be selected. Once this is complete a check will be

done to insure that all craft and operating certificates, maintenance records, and operating manuals

are organized and prepared for transport with the DMG 560.

Pre-flight Protocols. The following protocols are mandatory for all DMG missions.

1) Mission personnel will conduct checks of the project area to determine that no unauthorized

persons are present and secure the on-ground positions for all VOs.

2) Once on-site, the operator will inspect the UAS to determined that all electrical and mechanical

connections are securely in place.

3) The operator will connect the flight controller to a computer to insure that all on-board

instrumentation is working properly.

4) The operator will visually inspect the radio transmitter to verify that all toggles, trims, levers,

and dials are in the startup positions.

5) The operator will inspect the physical condition and voltage of all batteries.

6) When the above inspections have been satisfactorily completed the UAS will be initialized and

prepared for flight. These activities will include turning on the transmitter and double checking

toggles, levers, dials, trims, and voltage and then the connection of the battery to the UAS.

7) Upon completion of Step 6 the operator will allow approximately five (5) minutes for

instruments (altimeter and GPS) to initialize. 

8) While Step 7 is in progress all mission personnel will verify that their communication devices

are functioning properly.

9) After initialization is completed the operator will Arm (enable) the flight controller for flight.

10) Once the UAS is successfully Armed the operator will slowly increase the throttle and inspect

the UAS response and motor sync. Assuming no unusual behavior of the UAS the mission will

be initiated.
Digital Mapping and Graphics

6346 N. Shade Tree Lane

Springfield MO 65803

 Telephone : (417) 350-4037 Email: billisenberger@yahoo.com

5

The DMG 560 Pilot in Command (PIC). The mission PIC will possess a commercial pilot’s

license and a driver’s license valid within the United States. In addition, the PIC will have

completed a minimum of 10 ten hours of flight instruction with the DMG 560.

In-flight Protocols. The UAS will be kept within Visual Line-of-Sight (VLOS) of the PIC

during the mission.

The PIC and VOs will be in constant and simultaneous voice contact via cell phones or hand-held

radios throughout the mission.

In the event of a radio malfunction or battery failure a fail-safe programmed into the flight

controller will be triggered and the DMG 560 will execute a Return to Launch.

The DMG 560 will be prevented from leaving the established project area by using a predefined

GeoFence programmed into the flight controller.

If the PIC sees something wrong or unusual he will immediately land the craft in the closest safe

area or execute a Return to Launch depending on the nature of the problem.

If the VO sees something wrong or unusual the VO will immediately notify the PIC who will

immediately land the craft in the closest safe area or execute a Return to Launch depending on the

nature of the problem.

BENEFIT TO PUBLIC

DMG’s use of UAS technology will greatly increase the accuracy and precision of gathering

aerial data from both agricultural and natural landscapes as well as from archeological

excavations. Because of its ease of application and low cost it will be possible to use UAS

technology to capture data across landscapes at various times during the year so that owners and

managers can track changes in such variables as vegetation and drainage within a landscape

throughout a yearly cycle or to track the nature and extent of natural catastrophes such as violent

storms or severe droughts. This will enable managers to identify areas and aspects of resource

concern as they are developing or, in the case of storm damage, immediately after they occur. 

This technology will also allow managers to assess the effects of management practices in a

timely and efficient manner. These advantages will result in the development of much more

timely and efficient management practices resulting in significant cost savings to both private

firms and public agencies.
Digital Mapping and Graphics

6346 N. Shade Tree Lane

Springfield MO 65803

 Telephone : (417) 350-4037 Email: billisenberger@yahoo.com

6

SAFETY

Because of the size of the DMG 560, the fact that it carries no personnel or cargo, and the flight

protocols described above, the employment of this UAS technology will significantly lessen the

safety concerns associated with manned aerial data acquisition.

SPECIFIC ITEMS FOR WHICH RELIEF IS REQUESTED

Table 1 is a listing of the CFR’s from which DMG is seeking an exemption in order to use UAS

as part of its technical services.

Table 1. 14 CFR Regulations from which Exemption is Being Sought

Regulation Description Comment

14 CFR 61.3 Requirement for Pilot

certificate

DMG proposed to use a PIC holding a Commercial

Pilot’s license and a valid US driver’s license

14 CFR 91.9(b) Requirement for manual to

be available in the cockpit

There is no space available for storage of such items

onboard the DMG 500 and no persons on board to

view such items.

All flight manuals, registration, and technical papers

will be on-site in the possession of the PIC.

14 CFR 91.103(b) Requirement for crew

members to be onboard

There is no space available onboard the DMG 560

for any crew member.

14 CFR 91.109 Requirement for dual

controls during flight

instruction

There is no space available onboard the DMG 560

for any crew member.

14 CFR 91.119 Minimum altitudes for safe

flight

Safety concerns mandate that the DMG be operated

at less than 500 ft.

14 CFR 91.121 Altimeter settings There is no space available onboard the DMG 560

for any crew member to read the altimeter.

14 CFR 151(a)(1) Fuel requirements The DMG 500 is entirely battery powered and will

carry no fuel on board.
Digital Mapping and Graphics

6346 N. Shade Tree Lane

Springfield MO 65803

 Telephone : (417) 350-4037 Email: billisenberger@yahoo.com

7

Table 1. 14 CFR Regulations from which Exemption is Being Sought

(continued)

Regulation Description Comment

14 CFR 91.203(a)

 & (b)

Requirement for registration and

airworthiness certificates to be

onboard

There is no space available for storage of such

items onboard the DMG 500 and no persons on

board to view such items.

All registrations, certifications, and maintenance

records will be onsite in the possession of the

PIC.

14 CFR 91.205(b) Cockpit instruments There is no space available on board the DMG

for personnel to read such instruments.

14 CFT 91.405(a) Inspection requirements As written, the inspections noted in this

regulation are not pertinent to the operation of

the DMG 560. All inspections of the DMG by

its designer and builder will be dated and noted

in the operations log for the DMG 560 and be

available onsite in the possession of the PIC.

14 CFR 91.407(a)(1) Inspection approval requirements There is no space available onboard the DMG

560 for such records. All registrations,

certifications, and flight logs will be onsite in

the possession of the PIC.

14 CFR 91.409(a)(1)

& (2)

Airworthiness inspection This regulation was designed for manned

aircraft and is not suitable for the DMG 560.

As the DMG 560 was designed and built by

Isenberger of DMG, he is the best person to

conduct all inspections of this craft and, in

addition to the routine post-flight inspection

following each mission, Isenberger will conduct

a complete and thorough inspection of the craft

after every 100 hours of service.

14 CFR 91.417 (a) &

(b)

Maintenance records requirements There is no space available onboard the DMG

560 for such records. All registrations,

certifications, and flight logs will be onsite in

the possession of the PIC.
Digital Mapping and Graphics

6346 N. Shade Tree Lane

Springfield MO 65803

 Telephone : (417) 350-4037 Email: billisenberger@yahoo.com

8

FEDERAL REGISTRY SUMMARY

Pursuant to 14 CFR 11.81, information to include for exemption, subpart F, the summary below is

provided for publication in the Federal Register:

Digital Mapping and Graphics seeks exemption from the requirements of 14 CFR Part 21 paras. 61.3,

91.9(b), 91.103(b), 91.109, 91.119, 91.121, 91.151(a)(1), 91.203 (a) & (b), 91.205 (b), 91.405 (a), 91.407

(a) (1), 91.409 (a) (1) & (2), and 91.417 (a) & (b) to operate unmanned aircraft systems pursuant to the

Federal Aviation Administration Modernization and Reform Act of 2012, Public Law 112-95 February

14, 2012, Section 333.

This exemption will allow Digital Mapping and Graphics to operate a small (less than 2.5kg) custom

designed unmanned aircraft system (UAS), the DGM 560, N 541 HW, for the purposes of aerial

photography, photogrammetry, precision agriculture, and mapping.

CLOSING

In closing, I would like to thank you for your consideration of this request. DMG has provided what we

believe to be significant contributions to the management of both public and private resources and are

confident that by the granting of this exemption you will allow us to extend and improve our services to

serve the public good without incurring any increased safety risks to either person or property.

Sincerely,

William H. Isenberger, CEO

Digital Mapping and Graphics

WHI:jb

 William H Isenberger