James C. Watson -Carolina Drone Works, LLC 17111 Claret Ct. Cornelius, NC 28031 704.621.5734 Docket Operations, M-30 U.S. Department ofTransportation Room W12-140, West Building Ground Floor 1200 NewJersey Avenue, SE. Washington, DC 20590-0001 Re: Exemption Request under Section 333 ofthe FAA Reform Act and Part 11 ofthe Federal Aviation Regulations Dear Sir or Madam, Pursuant to Section 333 ofthe FAA Modernization and Reform Act of2012 (the "Reform Act") and 14 C.F.R. Part 11, I, James C. Watson, organizer ofCarolina Drone Works, LLC, seek an exemption from Federal Aviation Regulations to allow commercial operations of UAS's for the purpose ofconducting aerial photography, video, and survey forvarious industries in the Carolinas. 

### Unmanned Aircraft Systems 

### 1. The requested exemption would support an application for a commercial Certificate of Authorization to use the following described UAS, as long as operations are conducted within and under the conditions outlined or as may be established bythe FAA as required by Section 333. like the FAA, it is the Operator's mission to provide the safest and most efficient means of Civil Commercial implementation intothe National Airspace System. Furthermore, the Operator is comprised of members with a FAA Commercial Pilot Certificate or higher adding an additional layer ofsafety for operations as well as the necessary high-level of understanding and respect of the NAS and FARs.

• DJI Phantom 3 Professional- Reference Phantom 3 Professional User Manual version 1.2 •The Phantom 3 Professional is a quadcopter UAS capable ofcapturing 4K video and transmitting an HD video signal to a ground station. The built-in camera has an integrated gimbal to maximize stability and weight efficiency while minimizing space. When no GPS signal is available, Vision Positioning technology provides hovering precision. 2. Reference Phantom 3 Professional User Manual (EN) v1.2 [FCC Compliance- Appendix Pg. 62] 

### Unmanned Aircraft PIC 3. Operator proposes to operate its UASs with a pilot holding, at a minimum, a private pilot certificate.• The UAS PIC will be trained in advance forthe safe operation ofthe UAS to be operated. This will include operation ofthe UAS both in normal and emergency procedures, and will include familiarization with the user manual published by the UAS manufacturer. Training will also include types ofmaneuvers to be performed and the safe operation in relation to persons, property and applicable airspace. •The PIC must have accumulated a minimum of 100flight cycles and 25 hours oftotal time as a UAS pilot and at least 10 hours logged as a UAS's pilotwith a similar UAS type.

• All operations must utilize Visual Observers (VOs). VOs who are not pilots will attend ground training to understand the roles ofan observer, communication procedures, and propervisual scan techniques, operations at non-towered airports, and appropriate sections ofthe Aeronautical Information Manual. 4. The PIC must possess at least athird-class airman medical certificate for all of petitioner'sflight operations. Operation ofthe Unmanned Aircraft Systems 5. Operator proposes Civil Commercial operation ofan UAS to operate in the following manner:

• Aerial photography and/orvideo for public and/or private use including real estate, architecture, land surveying, engineering and other related professional activities.

• Aerial video and/or photography for public and/or private use at public events.

• Aerial inspection/photography ofresidential/commercial structures undercontract with the owners or local government authority.

• Aerial inspection/photography ofresidential/commercial utility infrastructure including but not limitedto electrical power lines, and cell towers.

• Aerial video/photography or providing live video feed (so as long as all other parameters are met contained herein) to assist with search and rescue operations in cases ofan emergency or natural disaster onlywhen the local authorities orgovernment has requested it by contract or donation.

• The abilityto offertraining to persons individually or belonging to both private and/or public organizationsthat have interests in the use and application ofa UAS forthe purpose ofthe safe operation ofa UAS to enhance the safety ofthe National Airspace System as well as forthe protection ofthe persons and property. •Foradditional operatoradherence: Reference- Phantom 3 Safety Guidelines and Disclaimer. 6. The UAS may not be flown at an indicated airspeed exceeding 29 knots. The UAS must be operated atan altitude ofno morethan 400feet AGL. The UA may not be operated less than500 feet below or less than 2,000 feet horizontallyfrom a cloud orwhen visibility is less than 3 statute miles from the PIC. UAS operations may not be conducted during night, as defined in 14 CFR § 1.1.

• All operations must be conducted undervisual meteorological conditions (VMC). Flights under special visual flight rules (SVFR) are not authorized. • A briefing will be performed regarding the planned UAS operations priorto each day's flight consisting ofall the days' production activities.

• Flights will be terminated at 20% battery power. 7. As described fully above, the requested exemption would permit the operation ofan UAS under controlled conditions in the NAS thatwould be a) limited b) controlled c) predetermined and d) will provide safety enhancements to the already safe operations in the industry presently using conventional aircraft. Approval ofthis exemption would thereby enhance safety and fulfill the Secretary ofTransportation's (the FAA Administrator's) responsibilities to "

....establish requirements forthe safe operation ofsuch aircraft systems in the national airspace system." Given the small size ofthe UAS and the controlled environment provided, the proposed operations will adhere to the Reform Act's safety requirements. The approval ofthis application presents 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. 8. The UAS may not operate within 5 nautical miles ofan airport reference point as denoted on a current FAA-published aeronautical chart unless a letterofagreement with the airport's management is obtained, and the operation is conducted in accordance with a Notice to Airmen (NOTAM), as required by the operator's COA. 9. The UAS must be operated within the visual line ofsight (VLOS) ofthe PIC and VO at all times. The VO may be used to satisfy the VLOS requirement as long as the PIC always maintains VLOS capability. The VO and PIC must be able to communicate verbally at all times. Electronic messaging ortexting is not permitted during flight operations.

10. Reference- Phantom 3 Safety Guidelines and Disclaimer

11. Operator's Point ofContact Charlotte FSDO 3800 Arco Corporate Drive Suite 233 Charlotte, NC 28273 12. Operatorwill obtain required COAs once exemption is granted. Exemption Requests and Equivalent Level ofSafety14CFR Part 21, Subpart H: Airworthiness Certificates 14CFR 

### § 91.203 (a) (1) Based on the limited size, weight, operating conditions, design safety features, and the imposed conditions and limitations, the operator has demonstrated that its operations would notadversely affect safety compared to similar operations conducted with aircraftthat have been issued an airworthiness certificate under 14CFR part 21, Subpart H. Therefore, as the FAA found for Astraeus Aerial, Exemption 11062, the requested relieffrom 14 CFR Part 21, and any associated noise certification and testing requirements of part 36, is not necessary. 14CFR 

### § 45.23 (b)- Display of marks Since Operator's UAS has no entrance to the cabin, cockpit, or pilot station on which the markings can be placed, two inch letteringwill be impossible. Official marking systems for small UAS have notyet been established foroperations inside the NAS. The operator is prepared to markthe UAS with the name ofthe organization and location ororigin and fulfill any other request by the FAA tothistopic in accordance with 45.29 

### (f) where the pilot, observer, and othersworkingwith the sUAS will see the identification ofthe sUAS. The FAA has issued the following exemptions to this regulation, see Exemption Nos. 8738, 10167, 10167A and 10700. 14CFR 

### § 61.113 (a) 

### &(b) - Private pilot privileges and limitations This regulation provides: (a) This regulation providesthat no person that holds a private pilot certificate may act as pilot in command ofan aircraftforcompensation or hire. (b) This allows a private pilotto act as pilot in command ofan aircraft in connection with any business or employment if: (1} The flight is only incidental to that business oremployment; and (2} The aircraft does notcarry passengers or propertyforcompensation or hire. All the requirements ofa private pilotcertificate will prepare the UAS operatorforthe environmentthat theywill be operating in. *Please reference Grant of Exemption No. 11062 to Astraeus Aerial (Astraeus), the FAA determined that a PIC with a private pilot certificate operating a UAS would notadversely affect operations in the NAS or present a hazard to persons or property on the ground. 14CFR 

### § 91.7 (a) 

### & (b) - Civil aircraft airworthiness This regulation provides: (a) No person may operate a civil aircraft unless it is in an airworthy condition. (b) The pilot in command ofa civil aircraft is responsible for determiningwhetherthat aircraft is in condition forsafe flight. The pilot in command shall discontinue the flightwhen unairworthy mechanical, electrical, orstructural conditions occur. While the operator's UAS will not require an airworthiness certificate, operator is required to ensure that its aircraft is in an airworthy condition- based on compliance with the operating documents priorto everyflight. As previously determined with Astraeus Aerial, Exemption 11062, relevant materials may be kept in a location accessible to the PIC in compliance with the regulations. 14CFR 

### § 91.9 (b) (2) -CivilAircraft Flight Manual, marking, and placard requirements 14CFR 

### § 91.203 (a) 

### & (b) -Civil aircraft: Certifications required As previously determined with Astraeus Aerial, Exemption 11062, relieffrom these sections are not necessary. Relevant materials may be kept in a location accessible to the PIC in compliance with the regulations. 14CFR 

### § 91.109 - Flight instruction: Simulated instrumentflightand certainflighttests This regulation provides that "No person may operate a civil aircraftthat is being used forflight instruction unless that aircraft has fullyfunctioning dual controls." The controls for a UAS do not currently have a set offullyfunctioning dual controls. Ifa UAS's pilot is being trained, the pilot performingthe training would be directlysupervising and could take overthe controls from the pilot in training ifthe need arose. This would be similartothe technique ofa "throwovertype" control wheel in some fixed wing aircraft. We feel thatthistechnique meetsthe intent 91 .109 and provides an equivalent level ofsafety. 14CFR 

### § 91.119 - Minimum safe altitudes This regulation providesthat oversparsely populated areas the aircraft cannot be operated closerthan 500feetto any person, vessel, vehicle, orstructure. Since thetypical mission ofthis UAS would be photography orsurvey of persons, vessels, vehicles or structures itwould be necessary to operate closer than 500 feettothe items listed. Operationswill only be flown over propertyor persons where permission has been obtained, and careful pre-planning has been performed. Further, UAS aircraft operate atavery slow airspeed, and a low mass, and do not need as much space to operate safely, as outlined in 91.119. We believe the slower speed, smaller mass and careful pre-planningwould provide an equivalent level ofsafety. Furthermore,the operator can place barriers and/orstructuresto sufficiently protect nonparticipating person from the UA ordebris inthe eventofan accident. 14CFR 

### § 91.121 -Altimetersettings This regulation providesthat aircraft shall maintain cruising altitudes by reference to an altimeter setting available within 100 nautical miles ofthe aircraft. The UAS will normally be flying close tothe ground, and in line ofsight ofthe PIC oran observer. This line ofsight operation will provide separation from otheraircraft, obstructions and terrain providing an equivalent level ofsafety. Additionally, the altitude information generated byonboard GPS equipment installed on the aircraftwill aid in estimatingthe altitude. 14CFR 

### § 91.151 - Fuel requirementsforflight inVFR conditionsThis regulation provides that no person may begin aflight in an airplane under day VFR conditions unless there is enough fuel to fly to the first point ofintended landing and tofly afterthatfor at least 

### 30 minutes. We feel the intention ofthis paragraph itto provide a reasonable reserve ofenergy to plan for a safe landing should there be a delay in landing. Given the close proximityto the ground station, the abilityfor the UAS to land in a very small space and the built in energy level monitoring ofthe UAS there is a resulting equivalent level ofsafety ifthe flight is planned to be completed with 

### 20% battery energy remaining. We request an exemption to the word "fuel" and ask for an equivalent interpretation with the word "energy". 

### 14CFR § 

### 91.205 (b)- Powered civil aircraftwith standard category U.S. airworthiness certificates: Instrument and equipment requirements Since the operator's UAS does not have a standard category U.S. airworthiness certificate, relieffrom 

### 14 CFR 

### § 

### 91.205 is not necessary. 

### 14CFR 

### § 

### 91.215- ATC transponder and altitude reporting equipment and use Section 

### 91.215 (b) (3) includes provision for aircraft not originally certificated with an engine-driven electrical system orwhich has not subsequently been certified with such a system installed. For UAS not equipped with atransponder, sub-paragraph (d) (3) authorizes requests for ATC authorized deviations made to the ATC facility havingjurisdiction overthe concerned airspace within the time periods specified. For operation ofan aircraftthat is not equipped with atransponder, the request must be made at least one hour beforethe proposed operation. 

### 14CFR § 

### 91.401-91.417- Maintenance, preventive maintenance, and alterations This regulation provides that the operator is primarily responsible for maintainingthe aircraft in an airworthy condition, including compliance with part 39 and 43. The operator believes that adherence to their documents containing preflight and post flight checks for the UAS is sufficient to ensure that safety is not adversely affected. Respectfully,

James C. Watson -Owner, Carolina Drone Works, LLC Phone: 

### 704.621.5734 info@carolinadroneworks.com