Drone	Assist,	Inc. 333	Exemption	Request

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December 10, 2015

To Whom It May Concern: 

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (Reform Act) and 

14 C.F.R. Part 11, Drone Assist, Inc., hereby applies for an exemption from the Federal Aviation 

Regulations (FARs) identified below, to operate small unmanned aerial vehicles (i.e., small 

unmanned aircraft systems or UAS) for aerial data collection, aerial photography and 

cinematography. Drone Assist, Inc. respectfully submits that this Petition for Exemption 

qualifies for approval, as the Federal Aviation Administration (FAA) has previously issued 

grants of exemption in circumstances similar in all material respects to those presented herein. 

In addition to this Petition for Exemption, Drone Assist, Inc. also submits a confidential Motion 

Picture and Television Operations Manual (MPTOM).

Respectfully,

//signed//

William Douglas Harwell IV, President/Chief Pilot

Drone Assist, Inc.

11989 Music Street

Gulfport, MS 39503

228 265-0174
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The specific applicable regulations from which relief is required (CFRs):

Drone Assist, Inc. is requesting relief from Federal Aviation Regulations:

Exemption from of Title 14, Code of Federal Regulations (14 CFR):

Part 21

Part 45

61.56(a)

61.57

61.101(e)(1)(ii)(iv), (2), (4), (5), and (7)

61.113(a) and (b)

61.315(a)

91.9 (b)(1) and (2)

91.103(b)

91.105 (a)(2), (b)(1) and (2)

91.107

91.109 (b)(1) and (2), (c)(1), (2) and (3)(i)(ii)

91.119

91.121

91.144

91.151

91.203

91.205

91.313(e)(1) and (3)

91.403(b)

91.405(a) and (b)

91.407(a)(1)

91.409(a)(1) and (2)

91.417(a) and (b)

Part 21: Request relief from this rule.

Part 45: Request relief from this rule as the UAS is too small to accommodate the size of 

markings dictated in §45.29. Drone Assist, Inc. will place markings on the aircraft in a 

location that allows for the most visibility.

61.56(a)...Request flight review minimum flight time be reduced from 1 hour to 1 UAS flight, 

during which the PIC will demonstrate competence while operating the UAS. 

Subpart A—General

§61.56 Flight review.

(a) Except as provided in paragraphs (b) and (f) of this section, a flight review consists of a minimum of 1 

hour of flight training and 1 hour of ground training. 

61.57...Request 3 takeoffs and3 landings while operating the UAS in the preceding 90 days 

meet the intent of this rule. 

§61.57 Recent flight experience: Pilot in command.

(a) General experience. (1) Except as provided in paragraph (e) of this section, no person may act as a 

pilot in command of an aircraft carrying passengers or of an aircraft certificated for more than one pilot 

flight crewmember unless that person has made at least three takeoffs and three landings within the 

preceding 90 days, and—

 (i) The person acted as the sole manipulator of the flight controls; and 
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 (ii) The required takeoffs and landings were performed in an aircraft of the same category, class, and 

type (if a type rating is required), and, if the aircraft to be flown is an airplane with a tailwheel, the 

takeoffs and landings must have been made to a full stop in an airplane with a tailwheel. 

 (2) For the purpose of meeting the requirements of paragraph (a)(1) of this section, a person may act 

as a pilot in command of an aircraft under day VFR or day IFR, provided no persons or property are 

carried on board the aircraft, other than those necessary for the conduct of the flight. 

 (3) The takeoffs and landings required by paragraph (a)(1) of this section may be accomplished in a 

flight simulator or flight training device that is—

 (i) Approved by the Administrator for landings; and 

 (ii) Used in accordance with an approved course conducted by a training center certificated under 

part 142 of this chapter. 

61.101(e)(1)(ii)(iv), (2), (4), (5), and (7)...The UAS is a multiengine aircraft with retractable 

landing gear being used for compensation or hire in the furtherance of a business with 

possible operations in Class B, C and D airspace; request a waiver to allow recreational pilots 

to act as PIC of the UAS.

Subpart D—Recreational Pilots

§61.101 Recreational pilot privileges and limitations.

(e) Except as provided in paragraphs (d) and (i) of this section, a recreational pilot may not act as pilot in 

command of an aircraft—

 (1) That is certificated—

 (ii) With more than one powerplant;

 (iv) With retractable landing gear

 (2) That is classified as a multiengine airplane, powered-lift, glider, airship, balloon, powered 

parachute, or weight-shift-control aircraft;

 (4) For compensation or hire; 

 (5) In furtherance of a business; 

 (7) In Class A, B, C, and D airspace, at an airport located in Class B, C, or D airspace, or to, from, 

through, or at an airport having an operational control tower;

61.113(a) and (b)...Request permission to allow a Private Pilot be PIC of the UAS for 

compensation or hire.

Subpart E—Private Pilots

§61.113 Private pilot privileges and limitations: Pilot in command.

(a) Except as provided in paragraphs (b) through (h) of this section, no person who holds a private pilot 

certificate may act as pilot in command of an aircraft that is carrying passengers or property for 

compensation or hire; nor may that person, for compensation or hire, act as pilot in command of an 

aircraft. 

(b) A private pilot may, for compensation or hire, act as pilot in command of an aircraft in connection 

with any business or employment if: 

 (1) The flight is only incidental to that business or employment; and 

 (2) The aircraft does not carry passengers or property for compensation or hire.
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61.315(a)... Request permission to allow a Sport Pilot to act as PIC of the UAS for 

compensation or hire and for the purposes of a demonstration flight of the UAS to a 

prospective buyer.

Subpart J—Sport Pilots

§61.315 What are the privileges and limits of my sport pilot certificate?

(a) If you hold a sport pilot certificate you may act as pilot in command of a light-sport aircraft, except as 

specified in paragraph (c) of this section

(c) You may not act as pilot in command of a light-sport aircraft:

 (2) For compensation or hire.

 (3) In furtherance of a business.

 (9) To demonstrate the aircraft in flight to a prospective buyer if you are an aircraft salesperson

14 CFR: 91.9 (b)(1) and (2)...The UAS does not have the ability to carry manuals or 

registration onboard. Request exemption from carrying these documents onboard; they will 

readily available to the UAS pilot during operations and made available to the administrator 

when requested. 

Subpart A—General

§91.9 Civil aircraft flight manual, marking, and placard requirements

(b) No person may operate a U.S.-registered civil aircraft—

 (1) For which an Airplane or Rotorcraft Flight Manual is required by §21.5 of this chapter unless there is 

available in the aircraft a current, approved Airplane or Rotorcraft Flight Manual or the manual provided 

for in §121.141(b); and 

 (2) For which an Airplane or Rotorcraft Flight Manual is not required by §21.5 of this chapter, unless 

there is available in the aircraft a current approved Airplane or Rotorcraft Flight Manual, approved 

manual material, markings, and placards, or any combination thereof.

91.103(b)...Request exemption from this rule as the UAS does not have manufacturers 

performance information in relation to takeoff and landing information. 

§91.103 Preflight action.

(b) For any flight, runway lengths at airports of intended use, and the following takeoff and landing 

distance information: 

 (1) For civil aircraft for which an approved Airplane or Rotorcraft Flight Manual containing takeoff and 

landing distance data is required, the takeoff and landing distance data contained therein; and

 (2) For civil aircraft other than those specified in paragraph (b)(1) of this section, other reliable 

information appropriate to the aircraft, relating to aircraft performance under expected values of 

airport elevation and runway slope, aircraft gross weight, and wind and temperature. 

91.105 (a)(2), (b)(1) and (2)...The unmanned aircraft lacks onboard crew members and 

therefore does not have seat belts. Requesting exemption from this rule for registered UASs. 

Subpart B—Flight Rules

§91.105 Flight crewmembers at stations.

(a) During takeoff and landing, and while en route, each required flight crewmember shall—

 (2) Keep the safety belt fastened while at the crewmember station. 

(b) Each required flight crewmember of a U.S.-registered civil aircraft shall, during takeoff and landing, 

keep his or her shoulder harness fastened while at his or her assigned duty station. This paragraph does 

not apply if—

 (1) The seat at the crewmember's station is not equipped with a shoulder harness; or 
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 (2) The crewmember would be unable to perform required duties with the shoulder harness fastened. 

91.107... The unmanned aircraft lacks occupants and therefore does not have seat belts. 

Drone Assist, Inc. is requesting exemption from this rule in order to legally operate the U.S. 

registered UAS.

§91.107 Use of safety belts, shoulder harnesses, and child restraint systems.

(a) Unless otherwise authorized by the Administrator—

 (1) No pilot may take off a U.S.-registered civil aircraft (except a free balloon that incorporates a basket 

or gondola, or an airship type certificated before November 2, 1987) unless the pilot in command of that 

aircraft ensures that each person on board is briefed on how to fasten and unfasten that person's safety 

belt and, if installed, shoulder harness. 

 (2) No pilot may cause to be moved on the surface, take off, or land a U.S.-registered civil aircraft 

(except a free balloon that incorporates a basket or gondola, or an airship type certificated before 

November 2, 1987) unless the pilot in command of that aircraft ensures that each person on board has 

been notified to fasten his or her safety belt and, if installed, his or her shoulder harness.

91.109 (b)(1) and (2), (c)(1), (2) and (3)(i)(ii)...The UAS does not have dual yokes nor does it 

have rudder pedals thereby requiring exemption from this rule for the purposes of flight 

instruction. It may or may not be operated with dual controllers with “trainer” mode during 

instruction. If the flight instructor does not have a “buddy box,” which connects two 

transmitters for “trainer” mode, he/she will remain next to the student controlling the UAS 

ready to take over control when needed.

§91.109 Flight instruction; Simulated instrument flight and certain flight tests.

(b) An airplane equipped with a single, functioning throwover control wheel that controls the elevator 

and ailerons, in place of fixed, dual controls may be used for flight instruction to conduct a flight review 

required by §61.56 of this chapter, or to obtain recent flight experience or an instrument proficiency 

check required by §61.57 when—

 (1) The airplane is equipped with operable rudder pedals at both pilot stations;

 (2) The pilot manipulating the controls is qualified to serve and serves as pilot in command during the 

entire flight

 (3) Except in the case of lighter-than-air aircraft, that aircraft is equipped with fully functioning dual 

controls. However, simulated instrument flight may be conducted in a single-engine airplane, equipped 

with a single, functioning, throwover control wheel, in place of fixed, dual controls of the elevator and 

ailerons, when—

 (i) The safety pilot has determined that the flight can be conducted safely; and 

 (ii) The person manipulating the controls has at least a private pilot certificate with appropriate 

category and class ratings.

91.119...Current UAS rules preclude the ability to comply with 500 feet above the surface.

Request relief to the extent necessary to operate in accordance with sUAS rules and Drone 

Assist, Inc.’s Motion Picture and Television Operations Manual (MPTOM).

§91.119 Minimum safe altitudes: General.

Except when necessary for takeoff or landing, no person may operate an aircraft below the following 

altitudes: 

(a) Anywhere. An altitude allowing, if a power unit fails, an emergency landing without undue hazard to 

persons or property on the surface. 
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(b) Over congested areas. Over any congested area of a city, town, or settlement, or over any open air 

assembly of persons, an altitude of 1,000 feet above the highest obstacle within a horizontal radius of 

2,000 feet of the aircraft. 

(c) Over other than congested areas. An altitude of 500 feet above the surface, except over open water 

or sparsely populated areas. In those cases, the aircraft may not be operated closer than 500 feet to any 

person, vessel, vehicle, or structure. 

(d) Helicopters, powered parachutes, and weight-shift-control aircraft. If the operation is conducted 

without hazard to persons or property on the surface—

 (1) A helicopter may be operated at less than the minimums prescribed in paragraph (b) or (c) of this 

section, provided each person operating the helicopter complies with any routes or altitudes specifically 

prescribed for helicopters by the FAA; and

 (2) A powered parachute or weight-shift-control aircraft may be operated at less than the minimums 

prescribed in paragraph (c) of this section.

91.121...The sUAS does not have an adjustable altimeter; rather it uses the GPS altitude

calculation function. Before taking off the PIC will either reset the GPS altitude to 0’ AGL if 

able or note the GPS altitude and subtract it from the airborne GPS altitude to determine 

height AGL. Therefore, Drone Assist, Inc. requests exemption from this rule. 

§91.121 Altimeter settings.

(a) Each person operating an aircraft shall maintain the cruising altitude or flight level of that aircraft, as 

the case may be, by reference to an altimeter that is set, when operating—

 (1) Below 18,000 feet MSL, to—

 (i) The current reported altimeter setting of a station along the route and within 100 nautical miles of 

the aircraft; 

 (ii) If there is no station within the area prescribed in paragraph (a)(1)(i) of this section, the current 

reported altimeter setting of an appropriate available station; or 

 (iii) In the case of an aircraft not equipped with a radio, the elevation of the departure airport or an 

appropriate altimeter setting available before departure; or 

 (2) At or above 18,000 feet MSL, to 29.92ʺ Hg. 

(b) The lowest usable flight level is determined by the atmospheric pressure in the area of operation as 

shown in the following table:

Current altimeter setting Lowest usable flight level 

29.92 (or higher) 180 

29.91 through 29.42 185 

29.41 through 28.92 190 

28.91 through 28.42 195 

28.41 through 27.92 200 

27.91 through 27.42 205 

27.41 through 26.92 210

(c) To convert minimum altitude prescribed under §§91.119 and 91.177 to the minimum flight level, the 

pilot shall take the flight level equivalent of the minimum altitude in feet and add the appropriate 

number of feet specified below, according to the current reported altimeter setting:
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Current altimeter setting Adjustment factor 

29.92 (or higher) None 

29.91 through 29.42 500 

29.41 through 28.92 1,000 

28.91 through 28.42 1,500 

28.41 through 27.92 2,000 

27.91 through 27.42 2,500 

27.41 through 26.92 3,000

91.144...Since the UAS is operated in accordance with the sUAS rules and does not solely rely 

on a barometric altimeter to determine altitude, Drone Assist, Inc. requests exemption from 

this rule.

§91.144 Temporary restriction on flight operations during abnormally high barometric 

pressure conditions.

(a) Special flight restrictions. When any information indicates that barometric pressure on the route of 

flight currently exceeds or will exceed 31 inches of mercury, no person may operate an aircraft or 

initiate a flight contrary to the requirements established by the Administrator and published in a Notice 

to Airmen issued under this section.

(b) Waivers. The Administrator is authorized to waive any restriction issued under paragraph (a) of this 

section to permit emergency supply, transport, or medical services to be delivered to isolated 

communities, where the operation can be conducted with an acceptable level of safety.

91.151...The UAS is electric with a total flight time of 20-30 minutes. The minimum battery 

voltage established by the battery manufacturer should be used to determine minimum “fuel” 

requirements, however if a minimum voltage is not established then Drone Assist, Inc. will use 

25% voltage remaining to establish minimum fuel for the LiPo battery.

§91.151 Fuel requirements for flight in VFR conditions.

(a) No person may begin 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 of intended 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. 

(b) No person may begin a flight in a rotorcraft under VFR conditions unless (considering wind and 

forecast weather conditions) there is enough fuel to fly to the first point of intended landing and, 

assuming normal cruising speed, to fly after that for at least 20 minutes. 
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91.203...Request exemption from this rule as pertinent documents cannot be carried onboard 

the UAS. Drone Assist, Inc. will have the documents available to the UAS pilot as part of the 

UAS equipment and readily accessible to the pilot during operations. 

Subpart C—Equipment, Instrument, and Certificate Requirements

§91.203 Civil aircraft: Certifications required.

(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. Each U.S. airworthiness certificate used to 

comply with this subparagraph (except a special flight permit, a copy of the applicable operations 

specifications issued under §21.197(c) of this chapter, appropriate sections of the air carrier manual 

required by parts 121 and 135 of this chapter containing that portion of the operations specifications 

issued under §21.197(c), or an authorization under §91.611) must have on it the registration number 

assigned to the aircraft under part 47 of this chapter. However, the airworthiness certificate need not 

have on it an assigned special identification number before 10 days after that number is first affixed to 

the aircraft. A revised airworthiness certificate having on it an assigned special identification number, 

that has been affixed to an aircraft, may only be obtained upon application to an FAA Flight Standards 

district office. 

 (2) An effective U.S. registration certificate issued to its owner or, for operation within the United 

States, the second copy of the Aircraft registration Application as provided for in §47.31(c), or a 

registration certification issued under the laws of a foreign country.

(b) No person may operate a civil aircraft unless the airworthiness certificate required by paragraph (a) 

of this section or a special flight authorization issued under §91.715 is displayed at the cabin or cockpit 

entrance so that it is legible to passengers or crew. 

(c) No person may operate an aircraft with a fuel tank installed within the passenger compartment or a 

baggage compartment unless the installation was accomplished pursuant to part 43 of this chapter, and 

a copy of FAA Form 337 authorizing that installation is on board the aircraft. 

(d) No person may operate a civil airplane (domestic or foreign) into or out of an airport in the United 

States unless it complies with the fuel venting and exhaust emissions requirements of part 34 of this 

chapter.

91.205...Request exemption from this rule. The UAS lacks most of the required instruments 

necessary to be considered airworthy.

§91.205 Powered civil aircraft with standard category U.S. airworthiness certificates: 

Instrument and equipment requirements.

(a) General. Except as provided in paragraphs (c)(3) and (e) of this section, no person may operate a 

powered civil aircraft with a standard category U.S. airworthiness certificate in any operation described 

in paragraphs (b) through (f) of this section unless that aircraft contains the instruments and equipment 

specified in those paragraphs (or FAA-approved equivalents) for that type of operation, and those 

instruments and items of equipment are in operable condition. 

(b) Visual-flight rules (day). For VFR flight during the day, the following instruments and equipment are 

required: 

 (1) Airspeed indicator. 

 (2) Altimeter. 

 (3) Magnetic direction indicator. 

 (4) Tachometer for each engine. 

 (5) Oil pressure gauge for each engine using pressure system. 

 (6) Temperature gauge for each liquid-cooled engine. 
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 (7) Oil temperature gauge for each air-cooled engine. 

 (8) Manifold pressure gauge for each altitude engine. 

 (9) Fuel gauge indicating the quantity of fuel in each tank. 

 (10) Landing gear position indicator, if the aircraft has a retractable landing gear. 

 (11) For small civil airplanes certificated after March 11, 1996, in accordance with part 23 of this 

chapter, an approved aviation red or aviation white anticollision light system. In the event of failure of 

any light of the anticollision light system, operation of the aircraft may continue to a location where 

repairs or replacement can be made.

 (12) If the aircraft is operated for hire over water and beyond power-off gliding distance from shore, 

approved flotation gear readily available to each occupant and, unless the aircraft is operating under 

part 121 of this subchapter, at least one pyrotechnic signaling device. As used in this section, “shore” 

means that area of the land adjacent to the water which is above the high water mark and excludes land 

areas which are intermittently under water. 

 (13) An approved safety belt with an approved metal-to-metal latching device for each occupant 2 

years of age or older.

 (14) For small civil airplanes manufactured after July 18, 1978, an approved shoulder harness for each 

front seat. The shoulder harness must be designed to protect the occupant from serious head injury 

when the occupant experiences the ultimate inertia forces specified in §23.561(b)(2) of this chapter. 

Each shoulder harness installed at a flight crewmember station must permit the crewmember, when 

seated and with the safety belt and shoulder harness fastened, to perform all functions necessary for 

flight operations. For purposes of this paragraph—

 (i) The date of manufacture of an airplane is the date the inspection acceptance records reflect that 

the airplane is complete and meets the FAA-approved type design data; and 

 (ii) A front seat is a seat located at a flight crewmember station or any seat located alongside such a 

seat. 

 (15) An emergency locator transmitter, if required by §91.207. 

 (16) For normal, utility, and acrobatic category airplanes with a seating configuration, excluding pilot 

seats, of 9 or less, manufactured after December 12, 1986, a shoulder harness for—

 (i) Each front seat that meets the requirements of §23.785 (g) and (h) of this chapter in effect on 

December 12, 1985; 

 (ii) Each additional seat that meets the requirements of §23.785(g) of this chapter in effect on 

December 12, 1985. 

 (17) For rotorcraft manufactured after September 16, 1992, a shoulder harness for each seat that 

meets the requirements of §27.2 or §29.2 of this chapter in effect on September 16, 1991.

91.313(e)(1) and (3)...Request permission to operate in accordance with the sUAS rules, 

Motion Picture and Television Operation Manual and as necessary to accomplish the mission 

in a safe manner. 

Subpart D—Special Flight Operations

§91.313 Restricted category civil aircraft: Operating limitations.

(e) Except when operating in accordance with the terms and conditions of a certificate of waiver or 

special operating limitations issued by the Administrator, no person may operate a restricted category 

civil aircraft within the United States—

 (1) Over a densely populated area; 

 (3) Near a busy airport where passenger transport operations are conducted
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91.403(b)...Request permission to perform maintenance, preventive maintenance or 

alterations as needed to properly configure the aircraft to perform the mission as long as it 

remains within manufacturer’s performance limitations and does not adversely affect the safe 

flight characteristics and performance.

Subpart E—Maintenance, Preventive Maintenance, and Alterations

§91.403 General.

(b) No person may perform maintenance, preventive maintenance, or alterations on an aircraft other 

than as prescribed in this subpart and other applicable regulations, including part 43 of this chapter.

91.405(a) and (b)...Request a deviation from this rule that allows pre and post flight 

inspections to meet the intent of the required inspections, and gives the PIC or appointed 

Drone Assist, Inc. personnel the ability to determine if/when the UAS has been approved for 

return to service. 

§91.405 Maintenance required.

Each owner or operator of an aircraft—

(a) Shall have that aircraft inspected as prescribed in subpart E of this part and shall between required 

inspections, except as provided in paragraph (c) of this section, have discrepancies repaired as 

prescribed in part 43 of this chapter

(b) Shall ensure that maintenance personnel make appropriate entries in the aircraft maintenance 

records indicating the aircraft has been approved for return to service;

91.407(a)(1)...Request a deviation from this rule to allow the PIC be the authorized person to 

determine the aircraft is airworthy after maintenance, preventive maintenance, rebuilding or 

alteration work is conducted.

§91.407 Operation after maintenance, preventive maintenance, rebuilding, or alteration.

(a) No person may operate any aircraft that has undergone maintenance, preventive maintenance, 

rebuilding, or alteration unless—

 (1) It has been approved for return to service by a person authorized under §43.7 of this chapter

91.409(a)(1) and (2)...Request a deviation that allows a thorough pre and post flight 

inspections meet the intent in lieu of the required inspections. If a discrepancy is found then 

the PIC will be required to “down” the aircraft until all discrepancies have been corrected and 

a functional test flight has been completed with the PIC returning the UAS to service.

§91.409 Inspections.

(a) Except as provided in paragraph (c) of this section, no person may operate an aircraft unless, within 

the preceding 12 calendar months, it has had—

 (1) An annual inspection in accordance with part 43 of this chapter and has been approved for return 

to service by a person authorized by §43.7 of this chapter; or 

 (2) An inspection for the issuance of an airworthiness certificate in accordance with part 21 of this 

chapter.
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91.417(a) and (b)...Request a deviation in order to create a maintenance record program 

suitable for unmanned aircraft. The 100 hour and annual inspections will most likely be 

superseded by the UAS manufacturer’s recommendations. 

§91.417 Maintenance records.

(a) Except for work performed in accordance with §§91.411 and 91.413, each registered owner or 

operator shall keep the following records for the periods specified in paragraph (b) of this section: 

 (1) Records of the maintenance, preventive maintenance, and alteration and records of the 100-hour, 

annual, progressive, and other required or approved inspections, as appropriate, for each aircraft 

(including the airframe) and each engine, propeller, rotor, and appliance of an aircraft. The records must 

include—

 (i) A description (or reference to data acceptable to the Administrator) of the work performed; and 

 (ii) The date of completion of the work performed; and 

 (iii) The signature, and certificate number of the person approving the aircraft for return to service. 

 (2) Records containing the following information: 

 (i) The total time in service of the airframe, each engine, each propeller, and each rotor. 

 (ii) The current status of life-limited parts of each airframe, engine, propeller, rotor, and appliance. 

 (iii) The time since last overhaul of all items installed on the aircraft which are required to be 

overhauled on a specified time basis. 

 (iv) The current inspection status of the aircraft, including the time since the last inspection required 

by the inspection program under which the aircraft and its appliances are maintained. 

 (v) The current status of applicable airworthiness directives (AD) and safety directives including, for 

each, the method of compliance, the AD or safety directive number and revision date. If the AD or safety 

directive involves recurring action, the time and date when the next action is required.

 (vi) Copies of the forms prescribed by §43.9(d) of this chapter for each major alteration to the 

airframe and currently installed engines, rotors, propellers, and appliances.

(b) The owner or operator shall retain the following records for the periods prescribed: 

 (1) The records specified in paragraph (a)(1) of this section shall be retained until the work is repeated 

or superseded by other work or for 1 year after the work is performed. 

 (2) The records specified in paragraph (a)(2) of this section shall be retained and transferred with the 

aircraft at the time the aircraft is sold. 

 (3) A list of defects furnished to a registered owner or operator under §43.11 of this chapter shall be 

retained until the defects are repaired and the aircraft is approved for return to service. 

How the operator will maintain an equivalent level of safety or no adverse impact to safety:

 Drone Assist, Inc. is petitioning to operate a DJI Spreading Wings S1000+, eight engine, 

electric unmanned aircraft with a maximum aircraft weight of 24.25lbs. The aircraft is 41 inches 

in diameter and operates on the 2.4GHz frequency. The aircraft is equipped with an autopilot, 

specifically designed and programmed to maintain the aircraft’s stability during motor failure,

allowing the pilot to recover the aircraft back to the intended landing point and terminate the 

mission without loss of directional control. The autopilot also has lost link programmable 

command that will guide it back to a pre-established location for landing should it lose link with 

the 2.4GHz controller. During a loss of GPS signal the pilot has the option to select “attitude 

mode” on the controller which then allows the pilot to operate the aircraft in the same manner as 

a radio controlled aircraft. 

 The UAS is configured with a 5.8GHz high definition video downlink that will transmit video 

to the ground station where both the pilot and camera operator will have “first pilot view.” The 
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downlink will also transmit telemetry information from the UAS such as power voltage, flight 

velocity, height, distance from the home point, horizontal attitude and GPS satellite status, etc.

Additionally, the onboard instrumentation can record the flight telemetry, record the input and 

output information of every channel, GPS signal, power voltage, home distance and height, etc.,

which are all pertinent information needed to investigate the cause of a crash should an aircraft 

mishap occur.

 Drone Assist, Inc.’s President and Chief Pilot is an Air Force aviator with a combined 22 

years of civilian and military aviation experience. He also has over 24 years’ experience flying 

radio controlled airplanes. FAA airman certificates held are: Airline Transport Pilot (ATP)

airplane multi-engine land, Commercial Privileges airplane single-engine land, expired Certified 

Flight Instructor (CFI) airplane single and multi-engine and instrument airplane and Ground 

Instructor Instrument. Training and qualifications include Chief of Safety, Flight Safety Officer, 

Aircraft Mishap Investigator’s Course, Risk Management, Flight Safety’s Crew Resource 

Management Course and oversight of special use airspace for air to air and air to ground training. 

Additionally, he is an experienced FAR Part 141 Flight and Ground Instructor in association 

with Delta State University’s Bachelors of Commercial Aviation program. 

 Drone Assist, Inc.’s Pilot in Command (PIC) will ensure all operations are in accordance with 

FAR 91, the attached Motion Picture and Television Operations Manual (MPTOM) and the rules 

and exemptions set forth by the FAA’s sUAS rulemaking. Additionally, the PIC will conduct 

mission planning before each flight to determine potential hazards, safe takeoff and landing 

locations including emergency landing areas, areas where nonparticipants might encroach on the 

operation and ensuring necessary public notifications are announced in a timely manner. 

The following outlines the FAA’s guidelines to operate a sUAS for commercial operations and 

as such will be followed by all Drone Assist, Inc.’s employees when operating a UAS:

 Not operated at a speed exceeding 87 knots (100 miles per hour) 

 Operated at an altitude of no more than 400 feet above ground level (AGL). 

 Operated within visual line of sight (VLOS) of the PIC at all times

 This exemption and all documents needed to operate the UAS and conduct its operations 

must be accessible during UAS operations and made available to the Administrator upon 

request

 Any UAS that has undergone maintenance or alterations that affect the UAS operation or 

flight characteristics will undergo a functional test flight

 The operator is responsible for maintaining and inspecting the UAS to ensure that it is in 

a condition for safe operation
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 Drone Assist, Inc. will follow the UAS manufacturer’s maintenance, overhaul, 

replacement, inspection, and life limit requirements for the aircraft and aircraft 

components and comply with all manufacturer safety bulletins

 The PIC will hold either an airline transport, commercial, private, recreational, or sport 

pilot certificate. The PIC must also hold a current FAA airman medical certificate or a 

valid U.S. driver’s license 

 No PIC may operate the UAS, other than for training unless the PIC demonstrates the 

ability to safely operate the UAS in a manner consistent with how the UAS will be 

operated 

 UAS operations will be day time visual meteorological conditions (VMC)

 The UA will not operate within 5 nautical miles (NM) from an airport having an 

operational control tower; or 3 NM from an airport with a published instrument flight 

procedure, but not an operational tower; or 2 NM from an airport without a published 

instrument flight procedure or an operational tower; or 2 NM from a heliport with a 

published instrument flight procedure of an airport reference point (ARP) as denoted in 

the current FAA Airport/Facility Directory (AFD) or for airports not denoted with an 

ARP, the center of the airport symbol as denoted on the current FAA-published 

aeronautical chart, unless a letter of agreement with that airport’s management is 

obtained or otherwise permitted by a COA issued to the exemption holder. The letter of 

agreement with the airport management must be made available to the Administrator or 

any law enforcement official upon request. 

 The PIC must abort the flight in the event of unpredicted obstacles or emergencies

 The UAS must remain clear and give way to all manned aviation operations and activities 

at all times

 All Flight operations must be conducted at least 500 feet from all nonparticipating 

persons, vessels, vehicles, and structures unless: a. Barriers or structures are present that 

sufficiently protect nonparticipating persons from the UA and/or debris in the event of an 

accident. The operator must ensure that nonparticipating persons remain under such 

protection. If a situation arises where nonparticipating persons leave such protection and 

are within 500 feet of the UA, flight operations must cease immediately in a manner 

ensuring the safety of nonparticipating persons; and b. The owner/controller of any 

vessels, vehicles or structures has granted permission for operating closer to those objects 

and the PIC has made a safety assessment of the risk of operating closer to those objects 

and determined that it does not present an undue hazard. 

 The PIC, VO, operator trainees or essential persons are not considered nonparticipating 

persons under this exemption. Drone Assist, Inc.’s MPTOM Appendix 3 contains a 

document to notify personnel on and around a motion picture or television set that a UAS 
Drone	Assist,	Inc. 333	Exemption	Request

14

will be used. Additionally, the MPTOM Appendix 5 outlines a sample checklist to be 

used in planning and briefing before the UAS begins an operation. 

 All operations shall be conducted over private or controlled-access property with 

permission from the property owner/controller or authorized representative. Permission 

from property owner/controller or authorized representative will be obtained for each 

flight to be conducted. Drone Assist, Inc.’s MPTOM Appendix 4 contains a document to 

obtain necessary permissions from property owner/controller and/or governmental 

agencies. 

 

 Any incident, accident, or flight operation that transgresses the lateral or vertical 

boundaries of the operational area as defined by the applicable COA must be reported to 

the FAA's UAS Integration Office (AFS−80) within 24 hours. Accidents must be 

reported to the National Transportation Safety Board (NTSB) per instructions contained 

on the NTSB Web site: www.ntsb.gov. 

 Finally, all unmanned aircraft operations will be conducted within the limitations set forth by

the aircraft and aircraft components’ manufacturer and if no limitation is established by the

manufacture, Drone Assist, Inc. will establish limits. Drone Assist, Inc. believes that the LiPo 

battery used to power the UAS is a safety concern and therefore will charge, discharge and use 

the battery according to manufacturer’s specifications and will immediately cease using and will 

fully discharge to 0 volts and discard any battery that shows signs or symptoms of damaged cells 

such as battery swelling or cell imbalance that cannot be corrected via a balancing charger. 

Additionally, the LiPo batteries will be charged, discharged and stored in LiPo specific safety

bags that are designed to contain a battery fire.

How granting the exemption would be in the public’s interest:

 Granting Drone Assist, Inc.’s exemption furthers the spirit of the Congressional mandate by

allowing a small business whose owner has years of professional aviation experience to 

contribute to the safe integration of unmanned technology into industries that are constantly

seeking ways to leverage technology to improve safe working conditions, increase profitability, 

reduce expenses and increasing returns for both shareholders and stakeholders by reducing their 

overall environmental impact. Furthermore, we seek to safely further the use of unmanned 

aircraft as a replacement and/or substitution for the current hazardous means of aerial 

photography/cinematography and aerial data collection. Additionally, we believe unmanned 

technology will provide an overall benefit to the United States as well as the world economies as 

small unmanned aircraft businesses safely integrate into industries that normally did not use 

and/or could not afford to use aviation assets as part of their processes. 

• UAS provide safer work conditions for company employees because the employees will 

not have to go into a dangerous environment

• A UAS is safer than a helicopter or small plane because it is lighter and less 

combustible

• A UAS is more environmentally friendly than a helicopter or small plane because it 

reduces noise and air pollution
Drone	Assist,	Inc. 333	Exemption	Request

15

• UAS use contributes to reduced airport congestion by reducing the commercial use of 

small planes and helicopters

• There is less risk to life and property on the ground

• UAS use is more economical for companies and contributes to the U.S. economy by

allowing them to stay competitive

The proposed operations:

 Drone Assist, Inc. is an aerial data collection and storage company created to provide the 

customer with detailed aerial data used to make intelligent operational and fiduciary decisions. 

We will focus on capturing videos and/or photos of real estate, aerial surveying, utility

infrastructure and power generation systems, above and below ground pipeline inspection, 

communication towers, precision agriculture, wildlife and forestry monitoring, construction site

surveys and monitoring, archaeology and geology exploration, and motion picture and television 

production and training to individuals belonging to both private and public organizations to

increase awareness and improve safety for current and future UAS operations. Additionally, 

Drone Assist, Inc seeks to offer its UAS for use in conjunction with state and federal agencies for 

aerial video and pictures assisting with search and rescue and state and federal emergency

management operations. Lastly, we seek the ability to operate in all 50 states and its territories 

and possessions. 

The make and model of the aircraft for proposed operations (aircraft manuals are not 

necessary):

 Drone Assist, Inc currently owns and seeks to operate the DJI Spreading Wings S1000+ for 

commercial purposes. Aircraft and component manuals available upon request.

FEDERAL REGISTER SUMMARY 

The following summary is provided pursuant to 14 C.F.R. Part 11: 

Drone Assist, Inc. seeks an exemption from the following rules in Title 14 of the Code of Federal 

Regulations: Part 21; Part 45; 61.56(a); 61.57; 61.101(e)(1)(ii)(iv), (2), (4), (5), and (7); 

61.113(a) and (b); 61.315(a); 91.9 (b)(1) and (2); 91.103(b); 91.105 (a)(2), (b)(1) and (2); 

91.107; 91.109 (b)(1) and (2), (c)(1), (2) and (3)(i)(ii); 91.119; 91.121; 91.144; 91.151; 91.203; 

91.205; 91.313(e)(1) and (3); 91.403(b); 91.405(a) and (b); 91.407(a)(1); 91.409(a)(1) and (2); 

91.417(a) and (b). The exemption will enhance safety by reducing risk to the general public and 

property owners from the substantial hazards associated with using conventional fixed-wing 

aircraft or, rotorcraft for aerial data collection and aerial photography and cinematography.