Drone Control Systems, LLC 

1964 North Red Rock Road

P.O. Box 252

Dragoon, Arizona 85609

Phone: 520-686-4303

Fax: 520-329-6258

July 28, 2015

U.S. Dept. of Transportation, Docket Operations 

West Building Ground Floor, Room w12-140 

1200 New Jersey Avenue, SE.,

Washington, DC 20590

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, Drone Control Systems, LLC seeks an exemption from Federal Aviation 

Regulations (“FARs”) detailed below for the following described Unmanned Aerial System 

described in this document, which includes an Unmanned Aircraft and ground station-based 

equipment and crew:

THE UNMANNED AIRCRAFT:

 A lightweight (6.5 lbs gross weight with all on-board equipment), battery operated 4-

motor rotorcraft in the form of a quad-copter that takes off and lands vertically, and is

manufactured by DJI, Inspire 1, Model T600. The Unmanned Aircraft is not modified 

from the original delivered form.

 An on-board flight computer with GPS navigation and location ability that receives 

signals for flight controls from a ground-based transmitter/and dual controller system;

 An on-board camera capable of capturing imagery in the form of full color, high 

definition still photos and video;

 An on-board telemetry system that delivers flight data from the on-board flight computer 

to the on-board radio transmitter including altitude AGL, horizontal and vertical speed, 

compass direction of flight and direction back to its launch site;

 On-board radio transmitter that transmits live video from the on-board camera plus all the 

flight data from the telemetry system described above;

THE GROUND STATION-BASED PART OF THE SYSTEM: 

 An Unmanned Aircraft Pilot in operational control of a flight operation from beginning to 

end and who controls the Unmanned Aircraft while in flight;

 A Visual Observer whom is constant contact and Pilot and provides visual support of all 

flight operations;

 A Camera Operator whom is responsible for all camera and gimbal control during flight 

operations.
 A radio transmitter/controller operated by the Pilot to control the Unmanned Aircraft 

while in flight; The controller operates on frequencies between 5.725 GHz – 5.824 GHz 

and 2.400 GHz – 2.483 GHz.

 A radio receiver receiving live video and flight data from the on-board camera and 

computer projects it all together onto a screen for the Pilot to view during flight; 

 A Visual Observer is a person who provides a second pair of eyes to visually track the 

Unmanned Aircraft while in flight.

 A Camera Operator is a person who uses the second slave controller to control camera 

operation to allow Pilot and Visual Observer to focus on Unmanned Aircraft operation.

The requested exemption would support an application for a commercial Certificate of 

Authorization to use the above described Unmanned Aircraft System to support aerial 

photography and video capture services in support of real-estate agency websites and real-estate 

agent/client use, agricultural livestock containment and crop health inspections.

Low level photos and video from several angles are far more effective for real-estate 

advertisement than ground-based imagery for displaying the characteristics of large, complex 

properties listed by agents and agencies for sale. The benefits of reduced cost and improved 

quality of presentation from the Unmanned Aircraft provide a valuable benefit to agencies, 

agents, buyers and sellers of real-estate property.

The use of aerial photography and high definition video capture to provide large agricultural 

operations an overview of their crops and livestock containment area aids the rancher or farmer in 

quickly assessing the overall health of their crops as well as providing quick identification of 

fencing and containment structures that require repair. Ground based inspections is time 

consuming and does not present an overall view of the area.

The Unmanned Aircraft System will be operated in the field with both a Pilot, Visual Observer, 

and dedicated Camera Operator in accordance with FAA Policy N 8900.227 Section 14 

"Operational Requirements for UAS" and with the following Restrictions:

a) No flight will be made with an Unmanned Aircraft’s Gross weight exceeding 25 pounds;

b) All operations must occur in FAA Class G airspace at no more than 400 ft. AGL, at an 

airspeed of no more than 25 knots and no further than 3⁄4 NM from the Pilot;

c) All operations must utilize a Visual Observer, and dedicated Camera Operator. The 

Visual Observer and Pilot must be able to communicate by voice at all times during a 

flight operation;

d) Operations will be restricted to flights over private property with the permission of the 

property owner;

e) The Pilot must have accumulated and logged, in a manner consistent with 14 CFR § 

61.51 (b), a minimum of 100 flight cycles and 25 hours of total time as a Unmanned 

Aircraft quad copter pilot;

f) All required permits will be obtained from state and local government prior to operation;

g) The Unmanned Aircraft System will not be operated over densely populated areas;

h) The Unmanned Aircraft System will not be operated at air shows;

i) The Unmanned Aircraft System will not be operated over heavily trafficked roads;

j) The Unmanned Aircraft System System will not be operated within 5 NM of an airport or 

heliport;

k) Operations will be restricted to day only and weather conditions equivalent to Visual 

Flight Rules;
l) The Pilot will brief the Visual Observer and Property Owner about the operation and risk 

before the first flight at each new location;

m) No flight may be made without a Pre-Flight Inspection by the Pilot before each operation 

to ascertain that the Unmanned Aircraft is in a condition safe for flight (see Appendix A);

The Pilot, Visual Observer, and Camera Operator will meet the requirements outlined in FAA 

Policy N 8900.227 Section 16 personnel Qualifications. Additionally, the Pilot and Visual 

Observer will perform all required maintenance on the system in accordance with the 

manufacturer’s recommendations. Repairs to the Unmanned Aircraft will be performed only by 

authorized dealers of the Unmanned Aircraft.

We submit that the combination of the Unmanned Aircraft’s light weight, flight performance and 

ability, fully qualified flight crew and strict operation under the guidelines established in 

8900.227, and under all of the Restrictions (a) through (m) listed above, the FAA can have full 

confidence that the operation will have an equivalent or greater level of safety than manned 

aircraft performing the same mission. 

The name and contact information of the applicant is:

Drone Control Systems, LLC

Attn: James D. Lawrence

Phone: 520-686-4303 

Fax: 520-329-6258

Email: james.d.lawrence@red-nranch.com

The regulations from which the exemption is requested are listed below together with our 

proposed equivalent level of safety for each regulation:

 14 CFR Part 21

 14 CFR 91.203

 14 CFR 45.23, 45.29

 14 CFR 91.9

 14 CFR 61.113, 61.133

 14 CFR 91.109, 91.119, 91.121

 14 CFR 91.151

 14 CFR Subpart E (91.401 - 91.417)

 FAA Policy 8900.227 Paragraph 16(c)(4) and Paragraph 16(e)(1)

We are prepared to modify or amend any part of this request to satisfy the need for an equivalent 

level of safety. Please contact us at any time if you require additional information or clarification.

We look forward to working with your office.
ADDENDUM

EXEMPTION REQUESTS AND EQUIVALENT LEVEL OF SAFETY

Drone Control Systems LLC, requests an exemption from the following regulations as well as 

any additional regulations that may technically apply to the operation of the Unmanned Aircraft

System:

14 CFR Part 21, Subpart H: Airworthiness Certificates

This part establishes the procedures for the issuance of an airworthiness certificate. While the 

FAA continues to work to develop airworthiness standards for Unmanned Aerial Systems, we 

request an experimental certificate be issued for the Unmanned Aircraft System under either or 

both of the following provisions:

21.191 Experimental certificates.

Experimental certificates are issued for the following purposes:

(a) Research and development. Testing new aircraft design concepts, new aircraft equipment, 

new aircraft installations, new aircraft operating techniques, or new uses for aircraft.

(b) Showing compliance with regulations.

Conducting flight tests and other operations to show compliance with the airworthiness 

regulations including flights to show compliance for issuance of type and supplemental type 

certificates, flights to substantiate major design changes, and flights to show compliance with the 

function and reliability requirements of the regulations.

Since the experimental certificate can be used for commercial purposes such as market surveys, 

sales demonstrations, and customer crew training, we would expect that an experimental 

certificate would permit our commercial purpose as well.

The aircraft will not carry persons or property, will not carry fuel, and will only fly under strict 

operational requirements. Combined with the Unmanned Aircrafts’ light weight, being 

constructed primarily of carbon fiber and plastic, we propose that the Unmanned Aircraft will be 

at least as safe, if not safer, than a conventionally certificated aircraft performing the same 

mission.

If an experimental airworthiness certificate is not appropriate for this application, then we request 

an exemption of 14 CFR Part 21, Subpart H, and the requirement for an airworthiness certificate 

in general, citing the equivalent level of safety outlined in the previous paragraph.

14 CFR 91.203(a) & (b) Civil aircraft: Certifications required.

The regulation provides that an airworthiness certificate, with the registration number assigned to 

the aircraft and a registration certificate must be aboard the aircraft. Additionally, subparagraph 

(b) provides that the airworthiness certificate be "displayed at the cabin or cockpit entrance so 

that it is legible to passengers or crew."

At a maximum gross weight of 6.5 pounds, the Unmanned Aircraft is too small to carry 

documentation, does not have an entrance, and is not capable of carrying passengers or crew. To 

obtain an equivalent level of safety and meet the intent of 91.203, we propose that documents 

deemed appropriate for this aircraft by the FAA will be co-located with the crew at the ground 

control station and available for inspection upon request. In order to identify the aircraft, we 

propose that the information found on airworthiness and registration certificates be permanently 

affixed to the aircraft via placard containing the following information plus the word 

“EXPERIMENTAL” to satisfy the requirement of 14 CFR 45.23, which follows immediately 

after the proposed placard description below:
EXPERIMENTAL

Drone Control Systems, LLC

1964 North Red Rock Road

Dragoon, AZ 85609

Model: T600, Serial Number: W13DCD25030957

If found please contact: (520) 686-4303

14 CFR 45.23 Display of marks; general and 45.29 Size of marks.

These regulations provide that each aircraft must display "N" and the aircraft's registration

number in letters at least 3 inches high. Additionally, the aircraft must display the word

"EXPERIMENTAL" in letters at least 2 inches high near the entrance to the cabin, cockpit, or

pilot station. The Unmanned Aircraft does not have an entrance in which the word 

"EXPERIMENTAL" can be placed, and may not have a registration number assigned to it by the 

FAA.

We propose to achieve an equivalent level of safety by including the word "EXPERIMENTAL"

in the placard on the top of the aircraft, as shown above, where the Pilot, Visual Observer, 

Camera Operator and others in the vicinity of the aircraft while it is preparing for launch will be 

able to see the designation. Additionally, we feel that the permanent placard discussed in the 

previous paragraph will provide the aircraft's registration information at the ground station. 

14 CFR 91.9 Civil aircraft flight manual, marking, and placard requirements.

This regulation provides that no person may operate an aircraft unless a current, approved flight

manual is in the aircraft. We assume that the intent of this requirement is to ensure that flight

manual information is available to the aircrew while operating the aircraft. We request an

exemption to this requirement since the aircraft is not only too small to carry documentation; the

documentation would not be available to the crew during flight operations.

To obtain an equivalent level of safety and meet the intent of 91.9, we propose that a current,

approved Unmanned Aircraft Flight Manual (Appendix A) must be available to the crew at the 

ground station anytime the aircraft is in, or preparing for, flight.

14 CFR 61.113 Private pilot privileges and limitations: Pilot in Command and 61.133

Commercial pilot privileges and limitations.

The regulation provides that no person that holds a private pilot certificate may act as pilot in

command of an aircraft for compensation or hire. Subparagraph (b) allows a private pilot to 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.

Our proposed operations require that the Pilot must:

1) Have logged a minimum of 25 hours of flight experience in this type of Unmanned 

Aircraft or

2) Meet the requirements of 8900.227 para 16(c)(2)(c) "Operations without a pilot 

certificate" in which the Pilot is required to complete "FAA private pilot ground 

instruction" and pass "the FAA Private Pilot written examination." Since the aircraft 

cannot carry passengers or property, we feel we meet the intent of 61.113 Subparagraph 

(b) even though the intent of this application is to conduct a business.

14 CFR 91.109 Flight Instruction; Simulated instrument flight and certain flight tests
The regulation states that "No person may operate a civil aircraft that is being used for flight 

instruction unless that aircraft has fully functioning dual controls." The Unmanned Aircraft

System ground-based control station consists of a small hand-held radio transmitter and a second 

set of hand-held radio transmitter controls that serve as a slave control system and back-up 

control system for the Unmanned Vehicle. The Inspire 1 Unmanned Aircraft is the only DJI 

developed drone that provides this capability. Having this dual control capability for both student 

and instructor we feel meets the intent 91.109 and provides an equivalent level of safety.

14 CFR 91.119 Minimum safe altitudes: General.

The regulation states that over sparsely populated areas the aircraft cannot be operated closer than 

500 feet to any person, vessel, vehicle, or structure. Since the aircraft will be operating at a 

maximum of 400 feet AGL, we cannot comply with this requirement.

In order to provide an equivalent level of safety we will only fly over private property with the 

permission of the owner of the property flown over. The aircraft will not be operated over 

congested areas. The property owner will be briefed on the expected route of flight and the 

associated risks to persons and property on the ground. The aircraft will be operated at a low 

altitude allowing, if a power unit fails, an emergency landing without undue hazard to persons or 

property on the surface. Therefore we maintain that due to the small size of the Unmanned 

Aircraft, the hazard to persons, vehicles and structures is minimal compared to manned aircraft, 

which should be considered in granting the exemption.

14 CFR 91.121 Altimeter settings.

The regulation requires that aircraft shall maintain cruising altitudes by reference to an altimeter 

setting available within 100 NM of the aircraft.

The Unmanned Aircraft will always fly below 400 feet AGL and will not need to maintain 

cruising altitudes in order to prevent conflict with other aircraft. An Above Ground Level 

altimeter measurement above the takeoff point is transmitted via radio from the Unmanned 

Aircraft’s on-board computer to the display screen held by the Pilot, providing a constantly 

updated AGL readout.

14 CFR 91.151 Fuel requirements for flight in VFR conditions.

The regulation provides that no person may begin a flight in an airplane under day-VFR

conditions unless there is enough fuel to fly to the first point of intended landing and to fly after

that for at least 30 minutes.

We feel the intention of this paragraph is to provide an energy reserve as a safety buffer for

delays to landing. The Unmanned Aircraft is battery operated and the maximum duration of flight 

from a single battery charge is 14.5 minutes with a 20% reserve. Since the aircraft will never fly 

more than 3⁄4 NM from the point of intended landing, a full battery charge at launch will ensure 

that we meet the reserve energy requirement of this paragraph. We request an exemption to the 

word "fuel" and ask for an equivalent interpretation with the word "energy".

14 CFR Subpart E (91.401 - 91.417) - Maintenance, Preventive Maintenance, Alterations.

The regulation provides that the operator is primarily responsible for maintaining the aircraft in

an airworthy condition, including compliance with part 39 and 43. Paragraphs 91.407 and

91.409 require that the aircraft be "approved for return to service by a person authorized under

43.7" after maintenance and inspection.

It is our intention that the Pilot perform maintenance and inspection of the aircraft and "be

authorized to approve the aircraft for return to service." As provided in the Pre-Flight Checklist
in Appendix A, the Pilot will ensure that the aircraft is in an airworthy condition prior to every

flight and in addition conduct detailed inspections after every two hours of flight. Maintenance

performed by the Pilot is limited to repairing small cracks, replacing a propeller, checking

electrical connections and updating software and firmware for the on-board computer. All other

maintenance will be performed by the manufacturer or their designated repair facility. The Pilot 

will document work performed in accordance with 91.417.

We feel that due to the size, construction, and simplicity of the aircraft, the Pilot can ensure an 

equivalent level of safety.

8900.227 Paragraph 16(c) (4) PIC Medical. And Paragraph 16(e) (1) Observer Medical.

This policy provides that both the Pilot and Visual Observer must have a valid FAA second-class 

medical certificate issued under part 67 in order to perform as a pilot or observer.

The Unmanned Aircraft’s maximum gross weight is 6.5 pounds, it is constructed of carbon fiber 

and plastic and the Pilot is not on board. Both the Pilot and the Visual Observer are required to 

be in VLOS. Given the unlikely event that both the Pilot and Visual become medically 

incapacitated while the aircraft is in flight, the Unmanned Aircraft will return autonomously to 

the site of launching and land without crew intervention as the DJI Inspire 1 drone is equipped 

with a return to home GPS homing feature should the communications with the drone become 

interrupted or lost.

Therefore, requiring the Pilot and Visual Observer to meet the same medical requirements as 

commercial pilot carrying passengers in a large aircraft is an unnecessary burden.

We propose that the minimum medical requirements for the Pilot and Visual Observer be vision 

corrected to 20/20 and a valid, state issued driver's license. The 20/20 vision requirement will 

ensure that the Pilot and Visual Observer can see and avoid air traffic; a licensed driver is 

medically qualified to operate a much larger vehicle.
APPENDIX A

FLIGHT OPERATIONS MANUAL

a) No flight will be made with an Unmanned Aircraft’s Gross weight exceeding 25 pounds;

b) All operations must occur in FAA Class G airspace at no more than 400 ft. AGL, at an 

airspeed of no more than 25 knots and no further than 3⁄4 NM from the Pilot;

c) All operations must utilize a Visual Observer, and dedicated Camera Operator. The 

Visual Observer and Pilot must be able to communicate by voice at all times during a 

flight operation;

d) Operations will be restricted to flights over private property with the permission of the 

property owner;

e) The Pilot must have accumulated and logged, in a manner consistent with 14 CFR § 

61.51 (b), a minimum of 100 flight cycles and 25 hours of total time as a Unmanned 

Aircraft quad copter pilot;

f) All required permits will be obtained from state and local government prior to operation;

g) The Unmanned Aircraft System will not be operated over densely populated areas;

h) The Unmanned Aircraft System will not be operated at air shows;

i) The Unmanned Aircraft System will not be operated over heavily trafficked roads;

j) The Unmanned Aircraft System will not be operated within 5 NM of an airport or 

heliport;

k) Operations will be restricted to day only and weather conditions equivalent to Visual 

Flight Rules;

l) The Pilot will brief the Visual Observer and Property Owner about the operation and risk 

before the first flight at each new location;

m) No flight may be made without a Pre-Flight Inspection by the Pilot before each operation 

to ascertain that the Unmanned Aircraft is in a condition safe for flight (see Appendix A);

PRE-FLIGHT CHECKLIST

1) Use DJI Pilot Mobile Application to verify Unmanned Aircraft battery is fully charged in 

order to prevent unexpected premature descent;

2) Check all wiring connections are tight; 

3) Check all propellers are undamaged and no cracks exist in any structural members of the 

Unmanned Aircraft; 

4) Turn on radio controller, check for adequate voltage, set it to connect to the Unmanned 

Aircraft, move all control switches to forward or down position;

5) Turn on secondary controller, check for adequate voltage, set it to connect as the slave to 

the Unmanned Aircraft, move all control switches to forward or down position to verify 

gimbal functionality and slave functionality is correct.

6) At a location different from previous flight, re-set GPS and compass to current location;

7) Turn on transmitter, gimbal and camera.

TO REGAIN CONTROL AFTER LOST RADIO CONTACT

1) Prior to initiating flight establish home point by setting home point through DJI Pilot 

Mobile Application.

2) DJI Inspire 1 drone is equipped with return to home capability upon loss of radio contact.