June 29, 2015

U.S. Department of Transportation 

Docket Management System 

1200 New Jersey Ave. SE Washington, DC 20590 

Re: Exemption Request Section 333 of the FAA Reform Act

Dear Sir/Madam,

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

(the Reform Act), and 14 C.F.R. Part 11, Wolfe LLC, dba Drone Brothers 

(hereinafter Drone Brothers) seeks an exemption to operate as a planned 

aerial video company operating a Small Unmanned Aircraft System (sUAS) 

equipped to conduct aerial photography and survey for various industries, 

hereby applies for an exemption from the Federal Aviation Regulations 

(FARs) listed below to allow operation of our sUAS commercially in 

airspace regulated by the Federal Aviation Administration (FAA) so long as 

such operations are conducted with and under the conditions outlined 

herein or as may be established by the FAA as required by Section 333. The 

requested exemption would permit Drone Brothers to pursue its 

commercial interests in providing services to consumers interested in aerial 

data capture using a small advanced sUAV in the following areas:

• Construction sites before and after

• Events public and private

•Real Estate Marketing

Drone Brothers states that all sUAS flights that will occur over private or 

controlled access property, will be done with the property owner's prior 

consent and knowledge and that only people who have consented or 

otherwise have agreed to be in the area where filming will take place will 

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be filmed . Additionally, the pilot in command (PIC) is a certified 

instrument-rated single engine land pilot with more than 750 hours of 

flight time and holds a valid U.S. driver’s license issued by the State of 

Michigan. 

Drone Brothers respectfully submits the following petition for exemption 

from the listed Federal Aviation Regulations described in detail below as to 

allow for safe commercial operation of its sUAS. Drone Brothers plans to 

use the small, safe, and commonly used DJI Phantom 2 and the DJI Inspire 

1 for the purpose of producing videography and photography in order to 

market real estate, commercial property and other scheduled functions. 

The lightweight aircraft covered by the exemption are far safer than 

conventional operations conducted by manned helicopters and fixed-wing 

aircraft weighing thousands of pounds, containing highly flammable fuel, 

and operating in close proximity to the ground and people. In the event 

that a grant is provided by the FAA, Drone Brothers is fully committed to 

abiding by the conditions and limitations expressed in recent grants made 

for similar requests. 

Sincerely, 

Andrew Wolfe 

2471 Turner 

West Bloomfield, MI 48323

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I. Petitioner’s Contact Information: 

Wolfe LLC, dba Drone Brothers 

Andrew Wolfe

2471 Turner 

West Bloomfield, MI 48323

Email: dronebros1@gmail.com

II. Petitioner seeks an exemption from the following rules: 

14 CFR Part 21 

14 CFR 45.23 (b) 

14 CFR 61.113 (a) & (b) 

14 CFR 91.7 (a) 

14 CFR 91.9 (b) (2) 

14 CFR 91.103 

14 CFR 91.109 

14CFR91.119 

14 CFR 91.121 

14 CFR 91.151 (a) 

14 CFR 91.203 (a) & (b) 

14 CFR 91.405 (a) 

14 CFR 407 (a) (1) 

14 CFR 409 (a) (2) 

14 CFR 417 (a)& (b) 

III. Drone Brother’s Operations 

A. The sUASs 

 The requested exemption will permit the operation of the DJI 

Phantom 2 and the DIJ Inspire 1. Both sUAS are small, unmanned multi 

rotor aircraft, weighing less than 10 pounds, inclusive of the batteries, the 

propeller guard, and technical payload. These rotocrafts can operate at a 

speed up to 29 knots, but Drone Brothers will limit the speed to no more 

than 20 knots. The FAA has previously granted exemptions allowing 

commercial flight of the DJI Phantom 2 (Exemption No. 11396) and DJI 

Inspire 1 (Exemption 11897). 

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 The sUASs will have the following specifications: 

Airframe: DJI Phantom 2

Flight Control System: Naza – M V2, which includes the main controller 

(MC), internal measurement unit (IMU) with built-in internal sensor, 

barometric altimeter, which measures attitude and altitude, compass, GPS, 

and radio receiver (Rx). 

Transmitter (Tx): Futaba T14SG 

Receiver (Rx): Internal to DJI Phantom 2 

Data Link: 2.4G Data Link 

Video Link: DJI AVL 58 

Gimbal: H3-3D Zenmuse Gimbal for GoPro Hero 

Camera: Go Pro Hero 4 Black 

Batteries: 3S LiPo, 5200-mAh, 11.1V 

iOSD: DJI iOSD mini, which allows live telemetry to be displayed on the 

video monitor, including the battery level, and altitude. 

Airframe: DJI Inspire 1

Flight Control System: The flight control system built into the Inspire 1 makes 

flying as easy and intuitive as possible. All components intelligently 

communicate with each other, giving you smooth, stable flight starting from the 

first time you takeoff. 

Transmitter (Tx): DJI Transmitter

Receiver (Rx): Internal to DJI Inspire 1

Data Link: 2.4G Data Link 

Video Link: DJI AVL 58 

Gimbal: ZenMuse X3

Camera: X3- FC350

Batteries: TB47, 4500-mAh, 22.2V

Mobile Device System Requirments: iOS 8.0 or later, which allows live 

telemetry to be displayed on the video monitor, including the battery level, 

and altitude. 

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B. Flight Conditions

 The sUAS will be flown in airspace under 400 feet above ground level 

(“AGL”) and under controlled conditions in rural areas. The majority of 

flights will take place under 100 feet AGL. Drone Brothers’ operations will 

occur in suburban areas. Drone Brothers will avoid congested and densely 

populated areas. Drone Brothers will only operate its sUASs in VMC, 

visual meteorological conditions: no less than 500 feet below and no less 

than 2,000 feet horizontally from a cloud or when visibility at least 3 statute 

miles from the PIC. The flight crew will always make a safety assessment of 

the risk of every operation, and will only operate when it is determined 

that no undue hazards are present. 

C. Flight Operations

 Drone Brother’s flight operations require that the sUAS will always 

be in the line of sight of both a PIC and a monitor specialist, who will also 

act as the visual observer (VO). Flights will be at altitudes of no more than 

400 feet AGL, and at speeds less than 20 knots. Despite the 400 ft. AGL 

limit, most flights will take place at an altitude of no more than 100 ft. AGL. 

 The PIC has a private pilot single engine land license with an IFR 

rating, with 750 hours of flight time, and a Michigan Driver’s license. The 

VO has over several years of experience with RC aircraft, and has over 200 

hours flying sUASs as a hobbyist. If an additional PIC is utilized by Drone 

Brothers, he/she will receive appropriate training and certification.

 The sUASs will only fly over land which it has permission from the 

landowner or landowner’s agent to fly above. The flight crew will also 

conduct a safety briefing with the property owners. 

 Flights will take place on parcels of land that are at least 

approximately an area of half an acre to a full acre. Operations will not take 

place in congested or densely populated areas. The flight crew will obtain 

all aeronautical and weather data information.

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 Prior to departing for an operation, the flight crew will briefly turn on 

the sUASs to ensure that everything is connected and that the sUASs are in 

operational condition. 

 Upon arrival at a location for filming or photography, the flight crew 

will conduct an aerial and ground preflight inspection. The flight crew will 

also conduct a physical inspection of the aircraft. The flight crew will then 

power on the sUASs and set up a iPhone or tablet connected to the sUAS. 

This displays the telemetry information during the flight, and be monitored 

by the VO. The VO will be able to see the images taken by the camera in 

real time. 

The PIC will then conduct a pre-flight inspection. 

At any time during the flight, should the aircraft lose connection with 

the remote control, the flight control system failsafe will be activated 

automatically, and the aircraft will return to the previously-set home area 

and land, in order to reduce injuries or damage. If any of the following 

situations occur, the aircraft will not receive a signal, and enter into this 

failsafe mode: 

• The remote control is powered off; 

• The aircraft has flown out of the effective communication range of 

the remote control, which is no greater than 1,000 meters (3,280 feet); 

• There is an obstacle obstructing the signal between the remote 

control and the aircraft, essentially reducing the distance the signal 

can travel; or 

• There is interference causing a signal problem with the remote 

control. 

Both of the sUASs have “no fly zones” programmed into it, which will 

prevent flights in restricted zones. Although Drone Brothers will take every 

precaution to avoid flying in airspace other than class G airspace, the 

preprogrammed “no fly zones” will add an additional level of safety to 

operations. 

Other than this automated feature, the PIC will always fly the sUAS 

manually. The PIC and VO have tested the sUAS in a variety of weather 

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conditions, including on overcast days and in winds up to 15 knots. The 

PIC and VO will not fly the sUAS in heavy rainstorms, due to decreased 

visibility and the potential for water damage to the sUAS. The PIC and VO 

have also practiced emergency bailout procedures by having the sUAS 

return to home. In the event of an emergency, the PIC will release the 

joysticks. This will make the sUAS automatically hover in place and 

maintain its position and altitude, and the PIC and VO can determine if 

and when it is safe for the sUAS to return to the home location. 

 During flights, the PIC and the VO will be standing next to each 

other, in oral communication at all times at the ground station. The VO will 

observe the telemetry data on the iPhone or tablet and will monitor the 

images from the camera from the laptop. The VO will direct the PIC if he 

wishes to capture a different angle on the camera.

Flights will be limited to 18 minutes, which is 75% of the total battery 

life. Once the sUAS has landed, the PIC will conduct a post-flight checklist. 

IV. Privacy

 There is little concern that the proposed flights will cause invasions of 

privacy because all flights will occur with the property owner’s prior 

knowledge and consent. The only people and/or property to be filmed will 

have requested and hired Drone Brother’s for the express purpose of 

filming and photographing the people and/or property with the sUASs. 

No attempt will be made to identify any individuals filmed or 

photographed during the flights who have not consented to be filmed or 

photographed, except in cases where they are trespassing upon or 

damaging customer property, or interfering with the applicant’s or its 

customers’ operations. 

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V. Aircraft and Equivalent Level of Safety 

 Drone Brother’s proposes that the exemption requested herein apply 

to civil aircraft that have the characteristics and that operate with the 

limitations listed herein. These limitations provide for at least an equivalent 

or higher level of safety to operations under the current regulatory 

structure. 

 These limitations and conditions to which Drone Brothers agree to be 

bound when conducting commercial operations under an FAA issued 

exemption include: 

1. The sUASs will weigh significantly less than fifty (50) lbs. The DJI 

Phantom 2 weighs 2.9 lbs., inclusive of battery and payload and the DJI 

Inspire 1 weighs 6.47 lbs. 

2. Flights will be operated within line of sight of a pilot and VO. 

3. Maximum total flight time for each operational flight will be 75% of 

battery life. Flights will be terminated once the battery reaches a 25% level. 

This data will be available through telemetry data submitted to the 

transmitter and monitor.

4. The sUAS will remain clear and yield the right of way to all other 

manned operations and activities at all times.

5. Flights will be operated at an altitude of no more than 400 feet AGL. 

Despite this limitation, the majority of flights are anticipated to operate at 

no more than 100 feet AGL.

6. Minimum crew for each operation will consist of the sUAS PIC and VO.

7. A briefing will be conducted in regard to the planned sUAS operations 

prior to each day’s activities. It will be mandatory that all personnel who 

will be performing duties in connection with the operations be present for 

this briefing.

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8. The PIC is a certified private pilot single engine land with 750 logged 

hours, and has a Michigan Driver’s license. 

9. The PIC and VO have extensive practice operating the DJI Phantom 2 

and the DJI Inspire 1. Practice flights have been in a variety of weather 

conditions, including in winds up to 15 knots and on overcast days. 

Practice flights have also included using the emergency return-to- home 

features. 

10. The PIC and VO will at all times be able to communicate by voice and 

be stationed next to each other at the ground station. 

11. Written and/or oral permission from the landowner or authorized 

agent, of the land over which the sUAS will be flying. 

12. The sUAS will have the capability to abort a flight in case of unexpected 

obstacles or emergencies. The PIC and VO have practiced the emergency 

failsafe procedures

13. If the multi-rotor and its controller disconnects during flight, the 

system’s failsafe protection will come to the rescue and the multi-rotor will 

return to home and land automatically, rather than flying off 

uncontrollably or landing at an unknown location. 

 Satisfaction of the criteria provided in Section 333 of the Reform Act 

of 2012--size, weight, speed, operating capabilities, proximity to airports 

and populated areas and operation within visual line of sight and national 

security – provide more than adequate justification for the grant of the 

requested exemptions allowing commercial operation of applicant’s sUASs 

pursuant to Drone Brothers’ rules of operation appended hereto.

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VI. Public Interest and Safety

 Use of the sUAS will increase ground safety by eliminating the need 

to have a manned, aircraft take the videos or photographs. As the FAA 

recognized in the Douglas Trudeau, Realtor® Exemption, No. 11138:

“Manned aircraft conducting aerial filming and photography can 

weigh 5,000 lbs. or more, are operated by an onboard pilot and may 

carry other onboard crew members, as well as 100 gallons or more 

of fuel. The petitioner’s [sUAS] weighs less than 3 lbs. The pilot and 

crew will be remotely located from the aircraft. The limited weight 

reduces the potential for harm to persons or damage to property in 

the event of an incident or accident. The risk of an onboard pilot 

and crew during an incident or accident is eliminated with the use 

of a [sUAS] for the proposed operation.” Exhibit 10 at 11-12.

 As in the cited exemption, Drone Brothers’ sUASs are within the 

recognized weight exemption. During Drone Brothers’ operations, the PIC 

and VO will similarly be safely on the ground, directing the sUASs at 

altitudes no higher than 400 feet AGL. Drone Brothers will not fly over 

congested or densely populated locations. The flight crew will make a 

safety assessment prior to each operation, and will only operate when there 

are no undue risks. 

 Manned aircraft pose a much greater threat to its occupants as well as 

to individuals on the ground. Additionally, a much greater space will be 

necessary for takeoff, landing, and operations than would be necessary for 

the sUASs that Drone Brothers requests an exemption to use. 

VII. Regulations from Which Exemption is Requested 

A. 14 C.F.R. 21(h): Airworthiness Certificates

 Drone Brothers requests an exemption from 14 C.F.R. 21(h). This 

exemption meets the requirements for an equivalent level of safety 

pursuant to Section 333 based on the small size, light weight, relatively 

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slow speed, and use in controlled environments on private land, as 

described previously in this petition. In Exemptions No. 11396 and No. 

11897, the FAA stated that the Secretary of Transportation has determined 

that the DJI Phantom 2 and DJI Inspire 1 meet the statutory conditions of 

Section 333, considering the size, weight, speed, and limited operating area 

associated with the aircraft and its operation. 

 The specifications of the sUASs used by Drone Brothers are as 

follows: 

DJI Phantom 2: 

• has a diagonal length of 350 millimeters, 13.77 inches.

• Light weight: 2.9 lbs.

• Relatively slow speed: the PIC will limit the sUAS’s speed to 20 

knots (23 miles per hour).

• Operational capacity: currently, the DJI Phantom 2 can operate 

for 25 minutes.

• Flights will be terminated when 25% of the battery life remains.

• The DJI Phantom 2 can travel no more than 1,000 meters, 

3280.84 feet, from the receiver.

• Proximity to airports: Drone Brothers will only operate in Class 

G airspace.

• Operation within visual line of sight: The PIC will always fly 

the sUAS within its line of sight.

• Altitude: no more than 400 feet AGL, but the majority of flights 

are anticipated at 

 no more than 100 feet AGL.

DJI Inspire 1:

• has a diagonal length of 559 to 581 mm, 22 inches. 

• Light weight: 6.47 lbs. 

• Relatively slow speed: the PIC will limit the sUAS’s speed to 20 

knots (23 miles per hour).

• Operational capacity: currently, the DJI Inspire 1 can operate 

for 25 minutes.

• Flights will be terminated when 25% of the battery life remains. 

The DJI Inspire 1 can travel no more than 2 Kilometers, 328 

from the receiver.

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• Proximity to airports: Drone Brothers will only operate in Class 

G airspace.

• Operation within visual line of sight: The PIC will always fly 

the sUAS within its line of sight.

• Altitude: no more than 400 feet AGL, but the majority of flights 

are anticipated at 

 no more than 100 feet AGL. 

B. 14 C.F.R. 43.7: Persons authorized to approve aircraft, airframes, 

aircraft engines, propellers, appliances, or component parts for return to 

service after maintenance, preventive maintenance, rebuilding, or 

alteration.

 Drone Brothers requests an exemption from 14 C.F.R. 43.7. As 

described previously, Drone Brothers’ flight crew will be capable to repair 

and maintain the sUASs to meet an equivalent level of safety of this 

section. Drone Brothers will maintain and when necessary repair the 

sUASs. They will conduct inspections and maintenance based on 

maintenance guidelines provided by the manufacturer of the sUASs. 

C. 14 C.F.R. 43.11: Content, form, and disposition of records for 

inspections conducted under parts 91 and 125 and §§135.411(a)(1) and 

135.419 of this chapter. 

 Drone Brothers requests an exemption from 14 C.F.R. 43.11. Drone 

Brothers will keep log books of all maintenance and repairs at the ground 

station. 

D. 14 C.F.R. 45.11: Marking of products. 

 Drone Brothers requests an exemption from 14 C.F.R. 45.11. The PIC 

and VO will keep information related to the sUASs, including the user 

manual, at the ground control station and affix its N-Number, once 

obtained from the FAA Registration Office, on the “arms” of the sUASs as 

large as practicably possible. This exemption provides an equivalent level 

of safety to 14 C.F.R. 45.11 because the relevant documentation containing 

the serial number will be at the ground station with the PIC, where it will 

be useable in case of an emergency, rather than with the sUAS. 

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E. 14 C.F.R. 45.27: Location of marks; nonfixed-wing aircraft

 Drone Brothers requests an exemption from 14 C.F.R. 45.27. This part 

provides that each operator of a rotorcraft must display on that rotorcraft 

horizontally on both surfaces of the cabin, fuselage, boom, or tail the marks 

required by §45.23. Once Drone Brothers receives its N-Number, it will 

display these marks on the “arms” of the aircraft as large as practicably 

possible. This exemption provides an equivalent level of safety to 14 C.F.R. 

45.27 because the sUAS will be registered with the FAA Aircraft 

Registration Branch. In the event of incident, the sUAS will be traceable to 

Drone Brothers.

F. 14 C.F.R. 45.29: Size of marks

 Drone Brothers requests an exemption from 14 C.F.R. 45.27. Drone 

Brothers will affix its registration number as large as practicably possible 

on the “arms” of the sUASs once the N-Number is obtained. This 

exemption provides an equivalent level of safety to 14 C.F.R. 45.29 because 

the sUAS will be registered with the FAA Aircraft Registration Branch. In 

the event of incident, the sUAS will be traceable to Drone Brothers.

G. 14 C.F.R. 91.9(c): Civil aircraft flight manual, marking, and placard 

requirements 

 

 Drone Brothers requests an exemption from 14 C.F.R. 91.9(c). 

As stated above, Drone Brothers will place the N-number on the “arms” of 

the aircraft as large as practicably possible. An equivalent level of safety to 

14 C.F.R. 91.9(c) is met because the sUAS will be registered with the FAA 

and identifiable in the event of an incident. 

H. 14 C.F.R. 91.103(b)(2): Preflight action 

 Drone Brothers requests an exemption from 14 C.F.R. 91.103(b)(2) to 

the extent that is applicable. Drone Brothers’ PIC will, before beginning a 

flight, become familiar with all available information concerning that flight, 

including the aircraft performance under expected elevations, the gross 

weight of the aircraft, and the wind and temperature. As the flights of the 

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sUASs will not be at airports the information required of Part 91.103(b)(2) 

does not apply. 

I. 14 C.F.R. 91.105: Flight crewmembers at stations.

 Drone Brothers requests an exemption from 14 C.F.R. 91.105 since this 

part is not applicable due to the sUASs carrying no flight crewmembers. 

Drone Brothers will not operate the aircrafts unless someone is at the 

controls at all times, and each flight will be manually flown, with the 

exception of the automated safety features. This will provide an equivalent 

level of safety to 14 C.F.R. 91.105 because the flight crew will be at their 

stations at all times during the flight. The stations will not be on the aircraft 

but on the ground.

J. 14 C.F.R. 91.113(b): Right-of-way rules: Except water operations 

 Drone Brothers requests an exemption from 14 C.F.R. 113(b) to the 

extent that it applies to overhead aircraft operating at or above 500 feet 

AGL as the sUASs will be operating no higher than 400 feet AGL. Should 

another aircraft enter the area in which Drone Brothers is operating, 

because the flight will be within his line of sight, the PIC will be able to 

give right of way to that aircraft. All flights will be in class G airspace and 

the majority of flights will be at no more than 100 feet AGL, which will 

create a very slim chance that Drone Brothers’ operations will interfere 

with a manned aircraft’s flight. This will provide an equivalent level of 

safety to 14 C.F.R. 91.113(b) because the sUASs have significantly greater 

mobility than a much larger, manned aircraft. As a result, the PIC will be 

able to react and respond much more quickly than the other pilot.

K. 14 C.F.R. 91.119(c): Minimum safe altitudes: General

 Drone Brothers’ requests an exemption from 14 C.F.R. 91.119 subpart 

(c). Drone Brothers will not operate the sUASs any higher than 400 feet 

AGL and it is anticipated that the majority of operations will be no higher 

than 100 feet AGL. Drone Brothers will not operate in congested areas. 

L. 14 C.F.R. 91.121: Altimeter Settings 

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 Drone Brothers requests an exemption from 14 C.F.R. 91.121. The 

sUASs flight controllers will have an internal measurement unit (“IMU”). 

The IMU has a built-in internal sensor and a barometric altimeter that 

measures both attitude and altitude. Additionally, the sUASs will not be 

flying above 400 feet AGL in a sustained cruising flight mode such as a 

manned aircraft will typically fly. The PIC will at all times be controlling 

the maximum height of the sUAS through the telemetry features of the DJI 

controller. Additionally, the sUAS will be operated within the line of sight 

of the PIC.

M. 14 C.F.R. 91.151: Fuel requirements for flight in VFR conditions

 The sUASs are powered by electricity, using lithium polymer 

batteries that currently have a flight limit of approximately no more than 25 

minutes. Therefore, due to the limitations of the batteries, it is currently 

impossible to comply with Part 91.151. However, the sUASs will be 

operated in a manner with at least the equivalent level of safety as that of a 

manned aircraft complying with Part 91.151. During the entire flight, the 

PIC will always have a visual line of sight of the sUAS and the VO will be 

monitoring the battery life via the telemetry display at the ground station. 

The sUAS will always have enough power to land safely, given the 

minimum level of reserve capacity of the batteries. Drone Brothers also 

limits flights to 75% of battery capacity. As new batteries are obtained and 

put into use, Drone Brothers will continue to terminate flights after 75% of 

battery power has been used. 

N. 14 C.F.R. 91.215: ATC Transponder and Altitude Reporting 

Equipment and Use 

 This section requires that installed Air Traffic Control (ATC) 

transponder equipment must meet specific performance and 

environmental requirements, and aircraft must be equipped with an 

operable coded radar beacon transponder. There are presently no known 

commercially available ATC transponders that meet the payload 

requirements of a sUAS and are available at reasonable cost. However, 

because the sUASs used by Drone Brothers will not be flying into or near 

airports, and will fly no higher than 400 feet AGL, there is very low risk of 

15
collision with any manned aircraft. In addition, because there will be no 

need to have contemporaneous communication with ATC Control, due to 

the short distances, short flight times, and restricted altitude the sUASs will 

operate within, Drone Brothers requests an exemption from this section. 

O. 14 C.F.R. 91.403: General 

 This section requires that the owner or operator of an aircraft is 

primarily responsible for maintaining that aircraft in an airworthy 

condition. Drone Brothers will adhere to this requirement. Drone Brothers 

will maintain its sUASs in an airworthy condition and adhere to all 

manufacturer requirements for inspecting and maintaining the sUASs. 

Drone Brothers will keep records of maintenance to the sUASs, and these 

records will be available to the PIC and VO before, during, and after 

operations of the sUASs. 

 This Section also limits maintenance to that “prescribed in this 

subpart and other applicable regulations, including part 43 of this chapter.” 

Because of this limitation, and because of the exemptions under Part 43 

requested above, Drone Brothers requests an exemption from this Section. 

This exemption meets the requirements for an equivalent level of safety 

pursuant to Section 333 based on the small size, light weight, relatively 

slow speed, and use in controlled environments on private, secured land, 

as described previously in this petition. 

P. 14 C.F.R. 91.405 (a) and (d): Maintenance Required 

 This section requires that aircraft be inspected as prescribed by 

Section E, 14 C.F.R. §§91.401-91.421. Drone Brothers is applying for an 

exemption for these sections, due to the fact that its operators will inspect 

the sUASs prior to each flight and keep maintenance records of all parts 

that are replaced, in accordance with DJI’s instructions. Because the 

Sections referenced above are concerned with manned aircraft, and as such 

have inspection requirements designed for the safety of passengers, they 

are inapplicable to Drone Brothers. 

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Q. 14 C.F.R. 91.407: Operation after maintenance, preventive 

maintenance, rebuilding, or alteration 

 Drone Brothers respectfully requests an exemption from 91.407. The 

PIC, who holds a private pilot’s certificate, will conduct maintenance on 

the sUAS and keep logs of the battery cycle and repairs needed on the body 

or the propellers of the sUASs. Prior to conducting post- maintenance 

operations, Drone Brothers will conduct a test flight to ensure that the 

sUASs function properly. 

R. 14 C.F.R. 91.409: Inspections 

 This section lays out specific requirements for inspections of aircraft. 

Drone Brothers respectfully requests an exemption from these 

requirements because they are intended to maintain the safety of manned 

aircraft significantly larger and capable of significantly longer flights than 

is sUAS. Drone Brothers’ pre-flight and post-flight inspections meet or 

exceed the level of safety achieved by adherence to 14 C.F.R. 91.409. 

S. 14 C.F.R. 91.417: Maintenance records 

 Drone Brothers respectfully requests an exemption from this Section, 

as it is only applicable for aircraft with an airworthiness certificate. Because 

Drone Brothers will not have an airworthiness certificate, this Section is 

inapplicable. 

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