US Department ofTransportationExemptionRequestPursuantto Section 333 ofthe FAA Reform Act and Part 11 oftheFederal Aviation September 11, 2015 Craig Dimmitt 25614 Ave 220 Lindsay, CA 93247 U.S. Department ofTransportation DocketManagement System 1200 NewJersey Ave., SE Washington DC 20590 Re: ExemptionRequestPursuantto Section 333 ofthe FAA Reform Act and Part 11 ofthe Federal AviationRegulations from: 14 CFR 21 subpart H; 14 CFR 45.23(b); 14 CFR 61.113(a) and (b); 14 CFR 91.7(a); 14 CFR 91.9(b)(2); 14 CFR 91.103; 14 CFR 91.109; 14 CFR 91.119(c); 14 CFR 91.121; 14 CFR 91.151(a); 14 CFR 91.203 (a) and (b); 14 CFR 91.405 (a); 14 CFR 91.407 (a) (1) 14 CFR 91.409 (a)(1) and (2); 14 CFR91.417(a) and (b) Dear Sir or Madam: Pursuantto Section 333 oftheFAAModernization and Reform Act of2012 (the ' 6 Refomt Act") and 14 CFR Part 11, Craig Dimmitt, operator of Unmanned Aircraft Systems (UAS), hereby applies for an exemption from the listed Federal Aviation Regulations ("FARs") to allow commercial operation of designated UAS, provided such·operations.**:are~** conducted-within·

## ·and under. the· 'conditions- outlined herein 

## or as may be establishedbytheFAAastequiredbySection3g3.**~~**..**,.,.,,~,r** 

### ..**::!::x~.:,** • '·': '' ··· • Thankyou in advance for your consideration.

• T •**~** ·,**~ ~-**  • ·., Commercial operation ofa UAS, as described herein,·whichwill be equipped withcainera(s)and

### ior·sensors, w'ould provide professional services in the following areas: 1. Aerial photography and/or video for public and/or private use including real estate, architecture, land surveying, engineering and otherrelatedprofessional activities. 2. Aerial video and/or photography for public and/or private use including television, public events, newsgathering, and atthe request 

### Ipermission oflocal authorities, accident and crime scene investigation. 3. Aerial inspection/photography of residential/commercial structures under contract with the owners or local government authority. 4. Aerial inspection/photography of residential/commercial utility infrastructure including but not limited to electrical power lines, wind turbines and cell towers. 5. Aerial video/photography or providing live video feed to assist with search and rescue opcra:tiorts 

### iti cases·of

# an emergency ornatural disaster onlywhenthe local authorities or governmenthas requested itby contractor donation.

As described fully below, the requested exemption wouldpermitthe operation ofdesignated UAS as set forth in this document under controlled conditions in the NAS that would be a)Limited, b)controlled; c).predetermined, and d)



### .....

### ·

..

### · ·,, '.) .'.·.·.· i ;

.;safe. Approval ofthis exemption would increase public awareness ofUAS operations and enhance safety to aid in fulfilling the Secretary ofTransportation's (the FAA Administrator's)responsibilities to "

....establishrequirements for the safe operation ofsuch aircraft systems inthe national airspace system." The name and address ofthe applicant is: Craig Dimmitt Address: 25614 Ave 220, Lindsay, CA 93247 Ph: 559-359-8331 Email: cdquad15@gmail.com Regulations from whichthe exemption is requested: 14 CFRPart21 subpartH 14 CFR45.23 (b) 14 CFR 61.113 (a) & (b) 14 CFR91.7 (a) 14 CFR91.9 (b) (2) 14 CFR91.103 14 CFR91.109 14 CFR91.119 (c) 14 CFR91.121 14 CFR91.151 (a) 14 CFR91.203 (a) & (b) 14 CFR91.405 (a) 14 CFR91.407 (a) (1) 14 CFR91.409 (a) (2) 14 CFR91.417 (a) & (b) Craig Dimmittwill operate the following model UAS: 

### 3D Robotics Iris+, specifications shown here: 

### PRODUCT SPECIFICATIONS 

## • 3DRIris+ o 

### FlightTime o 

### Up to 22 

### Minutes o 

### Height o 210mm (8.25 in) o 

### Width WithoutRotorBlades o 413mm (16.25 in) o 

### Diagonal LengthWithoutRotorBlades o 491mm (19.35 in) o 

### PropellerDiameter o 241mm (9.5 in) o 

### WeightWithoutBatteryandPayload o 962g 

### (34.0 oz)



### o Battery o 5100mAh 3S ll.lV

### LiPo (included) o Charger o 3S ll.lV

### LiPo DC Balancing SmartChargerwith AC Adapter 

### 2o Transmitter o 8channel 2.4GHz o 

### 3 FlightModes o Standard,Loiter, & Return to Launch o MaximumFlyingHeight o Default400 FeetAbove Ground Level o TakeoffWeightWithBattery and MaxPayload o 1600g (56.4 oz) o Radio ControlFrequencyBand o 2.4GHz 

## Camera I 

## Gimbal System o Camera o GoPro Hero 4 o Video Resolution o FULL HD lOSOp Adjustable

60, 50 or48 FPS o Photo Resolution o 12 Megapixels o WorkingTemperature o 0°C to 50°C o Storage (memory) o microSD Class 10**~** 4 to 64GB o Height o ll5mm (4.5 in) o Weight o 283g (10.0 oz) o Depth o 135mm (1.4 in) o Width o 74mm (2.9 in)

Given the small size ofthe UAS in scope and the controlled environment provided, the proposed operations will adhere tothe,Reform Act's safetyrequirements. The approval ofthis applicationpresents no national security issues. Regarding the level ofsafety surrounding the proposed operations and the public benefit, reduction in environmental impacts, including but not limited to reduced emissions and noise, the grant ofthe requested exemption is in the public interest. Accordingly, the applicant graciously requests thatthe FAAgrantthe requested exemption. AIRCRAFTAND EQUIVALENTLEVEL OF SAFETY The operation limitations proposed for an equivalent or higher level of safety because operations will further enhance the safety ofthe persons and/or property using conventional aircraft. These limitations and conditions to which the applicant agrees to adhere to when conducting commercial operations under the FAA issued exemption as setforth inthe Flight OperationsManual (FOM) include: 1. The UAS will weigh significantly less than 55 lbs. Itweighs less than4 pounds withbattery and camera. 2. The UAS will have a maximum operating speed ofno more than25 mph.



### 33. Flights will be operatedwithin line ofsight ofthe Pilot in Command (PIC) and/or Visual Observer (VO). 4. Maximum flight time for each operational flight will be depending on the UAS model in operation, but will not exceed 15 minutes. Flights will be terminated at 25% battery power reserve or 15 minutes offlight time whichever occurs first. 5. Flights will be operated at an altitude ofno more than 400 feet Above GroundLevel (AGL). 6. Minimum crew for each operationwill consist ofthe UAS Pilot and at least one Visual Observer (VO). 7. The UAS pilotwill be a designated Pilot in Command (PIC). The PIC will have logged a minimum of20 hours on the designated UAS. The PIC, CraigDimmitt, holds a Commercial Pilot's License, No. 1957612. 8. A safetybriefingwill be performedpriorto each flight consisting ofthe production activities. 9. All flight activities will be logged. 10. All flights will occurunder Visual FlightRules Meteorological Conditions (VMC) only. 11. The flights will occur in Class G airspace no closer than a Smile radius of the geographic center/ Airport Reference Point (ARP) ofa towercontrolled oruncontrolled airport. 12. The operator will obtain verbal/written consent ofall persons involved with the planned operation and ensure that only consenting persons will be allowed within 100 feet ofthe flight operation. The radius may be reduced to 30 feet based upon an equivalent level ofsafety determination, as required by the U.S. Department ofTransportation under the FOM. With the advancedpermission ofthe FSDO, operations at closerrange maybe approved. 13. The PIC and VO will have been trained in operation ofUAS and receive up to date information for the particular UAS to be operated. 14. The PIC and VO will be able to communicate by voice and/orradio at all times. 15. Written and/or verbal permission and permits will be obtained from territorial, state, county or cityjurisdictions, including law enforcement, fire or other appropriate governmental agencies as appropriate to flight operations. 16. If the UAS loses communications with the remote controller or loses GPS signal, the UAS will have the capabilityto return to apredetermined location within a designated location and land autonomously. 17. The UAS will have the capabiiityto abort a flight in case ofemergencies with an automated "Returnto

## Launch,_ function. 18. The UAS will have the capabilityto abort a flight in case ofunpredicted obstacles, weather, or emergencies such as low battery.

14 C.F.R. Part 21, SubpartH: Airworthiness Certificates 14 C.F.R. §91.203 (a) (1) SubpartH, entitledAirworthiness Certificates, establishes the procedural requirements for the issuance ofairworthiness certificates as required by FAR §91.203 (a) (1). Given the size and limited operating area associated with the aircraft to be utilized bythe Applicant, an exemption from Part 21 Subpart H meets the requirements of an equivalent level of safety under Part 11 and Section 333 ofthe Reform Act. The Federal Aviation Act (49 U.S.C.§44701 (f)) and Section 333 ofthe Reform Act both authorize the FAA to exempt aircraft from the requirement for an airworthiness certificate, upon consideration ofthe size, weight, speed, operational capability, and proximity to airports and populated areas ofthe particular 

### 4UAS. In all cases, an analysis of these criteria demonstrates that the UAS operated without an airworthiness certificate in the restricted environment and under the conditions proposed will be at least as safe, or safer, than a conventional aircraft (fixed wing orrotorcraft) operatingwith an airworthiness certificate withoutthe restrictions and conditions proposed. The UAS to be operated hereunder is less than 55 lbs. fully loaded, carries neither a pilot nor passenger, carries no explosive materials or flammable liquid fuels, and operates exclusively within a secured and designated area. Unlike other civil aircraft, operations under this exemption will be tightly controlled and monitored by both the operator and under the requirements and in compliance with local public safety requirements. These safety enhancements provide a greater degree of safety to the public and property owners than conventional operations conducted with airworthiness certificates issued under 14 C.F.R. Part 21, Subpart H. Lastly, application ofthese same criteria demonstrates that there is no credible threat to national security posed by the UAS, due to its size, speed ofoperation, location ofoperation, lack ofexplosive materials or flammable liquid fuels, and inabilityto carry a substantial external load. 14 C.F.R. §45.23 (b).Marking oftheAircraft: The regulation requires: 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 orprovisionally certificated aircraft, the operator must also display on that aircraft near each entrance to the cabin, cockpit, orpilot station, in letters notless than 2inche's nor mOte than 6 inches high, the words "limited," "restricted," "light sport", "experimental," or "provisional," as applicable. 14 C.F.R. §45.23 (b). Marking ofthe Aircraft: The regulation requires: 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 orprovisionally 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. Even though the UAS will have no airworthiness certificate, an exemption may be needed as the UAS will have no entrance to the cabin, cockpit or pilot station on which the word "Experimental" can be placed. Given the size ofthe UAS, two inch lettering will be impossible. The word "Experimental" will be placed on the fuselage in compliance with §45.29 (f). US Department ofTransportation February 20, 2015 The equivalent level ofsafety will be provided by having the UAS marked on its fuselage as required by §45.29 (f) where the pilot, observer and others working with the UAS will see the identification ofthe UAS as "Experimental." 14 C.F.R. § 61.113 (a) and (b): Private Pilot Privileges and Limitations: Pilot in Command. Pursuant to 14 CFR 61.113 (a) & (b), no person who holds a private pilot certificate may act as a pilot in command ofan aircraft that is carrying passengers or property for compensation or hire. The proposed UAS operations may achieve an equivalent level ofsafety as achieved by current Regulations because the applicant's UAS do not carry any pilots or passengers or property. The risks attendant to the operation ofUAS is far less than the risk levels inherent in the commercial activities outlined in 14 CFR 61. The PIC ofthe UAS will be, or be under the direct supervision of, a FAA Certificated Private Pilot with current Third Class orhigher medical certificate. It is believed thatthe operation and limitations set forth in the FOM will equate to the safe operation ofthe UAS. 14 C.F.R. §91.7(a): Civil Aircraft Airworthiness. The regulation requires that no person may operate a civil aircraft unless it is in airworthy condition. As there will be no airworthiness certificate issued for the aircraft, should this exemption be granted, no FAA regulatory standard will exist for determining airworthiness. Given the size ofthe aircraft for maintenance and use of safety checklists prior to each flight, an equivalent level of safety will be provided. 14 C.F.R. § 91.9 (b) (2): Civil Aircraft Flight Manual in the Aircraft. Section 91.9 (b) (2) provides: No person may operate a U.S. registered civil aircraft

... (2) For which an Airplane or Rotorcraft Flight Manual is not required by §21.5 ofthis chapter, unless there is available in the aircraft a current app::.-oved airplane orRotorcraft Flight Manual, approved manual material, markings, and placards, or any combination thereof. The UAS, given its size and 

### 5configuration has no ability or place to carry such a flight manual on the aircraft, not only because there is no pilot on board, but because there is no room or capacity to carry such an item on the aircraft. The equivalent level of safety will be maintained by keeping the flight manual at the ground control point where the pilot flying the UAS will have immediate access to it. 14 C.F.R. § 91.103: Preflight Action. This regulation requires each pilot in command to take certain actions before flight to insure the safety offlight. As FAA approvedrotorcraftflight manuals will notbe provided forthe aircraft an exemption will be needed. The PIC will take all actions as stated in the FOM in Section 4 underNormal Procedures includingbutnot limited toreviewingweather, flight batteryrequirements, landing andtakeoffdistances and aircraft performance databefore initiation offlight 14 C.P.R. §91.109: Flight Instruction. Section 91.103 provides that 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. UAS and remotely piloted aircraft, by their design do not have fully functional dual controls. Flight control is accomplished through the use ofa control box that communicates with the aircraft via radio communications. The FAA has approved exemptions for flight training without fully functional dual controls for a number ofaircraft and for flight instruction in experimental aircraft. The equivalent level ofsafety isprovidedbythe fact thatneither apilot norpassengers will be carried inthe aircraft andbythe size and speed ofthe airctaft. ---·-**·--~··-------** 14 C.P.R. §91.119: Minimum Safe Altitudes. Section 91.119 establishes safe altitudes for operation ofcivil aircraft. Section 91.119 (d) allows helicopters to be operated at less than the minimums prescribed, provided the person operating the helicopter complies with any route or altitudes prescribed for helicopters by the FAA. As this exemption is for a UAS that is a helicopter and the exemption requests authority to operate at altitudes up to 400 AGL, ornot more than 200 above an elevated platform from which filming is planned, an exemptionmay be needed to allow such operations. As setforth herein, the UAS will never operate at higherthan 400 AGL with the exception that in circumstances where the UAS is used to survey or photograph a structure whose height exceeds 400 feet AGL, the UAS will not be operated more than 200 feet above the highest point on the structure. It will however be operated in a restricted area with security perimeter, where buildings and people will not be exposed to operations withouttheirpre-obtained consent. The equivalent level ofsafety will be achieved given the size, weight, and speed ofthe UAS as well as the location where itis operated. No flight willbe taken withoutthepermission oftheproperty owner or local officials. Because ofthe advance notice to the property owner andparticipants in the filming activity, all affected individuals will be aware ofthe planned flight operations. Compared to flight operations with aircraft or rotorcraft weighting far more than the maximum 55lbs. proposed herein and the lack offlammable fuel, any risk associated with these operations is far less than those presently presented with conventional aircraft operating at or below 500 AGL. In addition, the low altitude operations ofthe UAS will ensure separation between these UAS operations and the operations ofconventional aircraftthatmustcomplywith Section 91.119. 14 C.F.R. §91.121 Altimeter Settings. This regulation requires each person operating an aircraft to maintain cruising altitude by reference to an altimeter that is set"

...to the elevation ofthe depatture airport or an appropriate altimeter setting available before departure." As the UAS maynothave a barometric altimeter, butinstead a GPS altitude read out, an U.S. exemption maybe needed. An equivalent level ofsafety will be achieved by the operator, pursuantto the safety check list and live flight data monitoring, confirming the altitude of the launch site shown on the GPS altitude indicatorbefore flight. 14 C.P.R. § 91.151(a): Fuel Requirements for Flight in VFR Conditions Section 91.151 (a) prohibits an individual from beginning "a flight in an airplane under VFR conditions unless (considering wind and forecast weather conditions) there is enough fuel to fly to the first point ofintended landing, and, assuming normal cruising speed

- (1) During the day, to fly after that for at least 30 minutes; or (2) At night, to fly after that for at least 45 minutes." The applicant believes that an exemption from 14 CFR §91.151(a) falls within the scope of prior exemptions. Operating the UAS in a tightly controlled area where only people and property owners or official representatives who have signed waivers will be allowed does notengenderthe type ofrisks that Section 91.151(a) was intended to alleviate given the size and speed ofthe small UAS. The applicant believes that an equivalent level ofsafety can be 

### 6achieved by limiting flights to 16 minutes or 25% ofbattery power - whichever happens first. This restriction is more than adequate to return the UAS to its planned landing zone from anywhere in its limited operating area. 14 C.F.R. §91.203 (a) and (b): Carrying Civil Aircraft Certification and Registration The regulation provides in pertinent part: (a) Except as provided in § 91.715, no person may operate a civil aircraft unless it has within it the following: (1) An appropriate and current airworthiness certificate

.... (b) No person may operate a civil aircraft unless the airworthiness certificate required by paragraph (a) ofthis section or a special flight authorization issued under §91.715 is displayed atthe cabin or cockpit entrance so that it is legible to passengers orcrew. The UAS fully loaded weighs well under the proposed 55lb limit and is operated without an onboard pilot. As such, there is no ability orplace to carry certification and registration documents orto display them on the UAS. An equivalent level ofsafety will be achieved by keeping these documents at the ground control point where the pilot flying the UAS will have immediate access to them, to the extentthey are applicableto the UAS. 14 C.F.R. §91.405 (a); 407 (a) (1); 409 (a) (2); 417(a) & (b): Maintenance Inspections. These regulations require that an aircraft operator or owner "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 inpart43 ofthis chapter

...,"and others shall inspect ormaintainthe aircraft in compliance with Part43. Given that these sections and Part 43 apply only to aircraft with an**airworthiness~certificate;""'lhese** sectionsw1H not applyto the applicant. Maintenance will be accomplished bythe operatorpursuantto the flight manual and operating handbook. An equivalent level ofsafety will be achieved because the UAS is very limited in size and will carry a small payload and operate only in restricted areas for a limited period oftime. Ifmechanical issues arise the UAS can land immediately and will be operating from no higher than 400 feet AGL. The operator will ensure that the UAS is in working orderpriorto initiating flight, perform required maintenance, and keep a log ofany maintenance performed. Moreover, the operator is the person most familiar with the aircraft and best suited to maintain the aircraft in an airworthy condition to provide the equivalent level of safety. An equivalent level of safety will be achieved because maintenance and inspections will be performed in accordance with the UAS Manufacturer's User Manual. As provided in the FOM, the operator will ensure that the UAS is in working orderprior to initiating flight andperform required maintenance needed. Additional Information. The applicant, Craig Dimmitt, believes this exemption request and associated safety considerations adequately satisfy criteria provided in Section 333 ofthe Reform Act of2012, providing sufficientjustification for the granting ofcommercial operations ofthe applicant's UAS. The applicant, Craig Dimmitt, requests yourrespective approval ofthis Section 333 exemptionpetition.

Thankyou for your interest and attention in this matter. Please notify Craig Dimmitt ofyourdecision.

Sincerely,

Craig Dimmitt 25614 Ave 220 Lindsay, CA 93247 cdquad15@gmail.com 7