Name and Address of Petitioner:

Mr. Carl Young

Premier Drone Solutions, LLC

2205 Tuscany Drive

Corinth, TX 76210

Docket # FAA-2015-6060

RE: Request for additional information, letter dated February 23, 2016

Request for Exemption, Section 333 of the FAA Reform Act pertaining to Federal Aviation

Regulations 14 CFR §§ 61.23(a) and (c), 61.101(e)(4) and (5), 61.113(a), 61.315(a), Part 21, 

91.7(a), 91.119(c), 91.121, 91.151(a)(1), 91.405(a), 91.407(a)(l) & (a)(2), 91.409(a)(l) and (2), 

91.417(a) and (b)

Premier Drone Solutions, LLC, the petitioner, requests exemptions in order to legally operate an 

Unmanned Aircraft System (UAS), as defined under Section 333 Subtitle B (6), and specifically 

the DJI Phantom 3 and/or DJI Inspire 1, as well as other similar FAA approved, and registered 

small UAS in the National Airspace System. 

All flights of the UAS will be flown, in line of sight during daylight hours, at less than 175' above 

ground level (AGL) and well clear of the flight path of any manned aircraft. The UAS also uses a 

smartphone or similar device to enhance controls by showing current AGL and visual location of 

the UAS to the subject and its surroundings. The petitioner wishes to be granted the exemption 

for use of the UAS for commercial data collection including, but not limited to, videography and 

photography of:

1. Residential and Commercial Real Estate for marketing or analysis

2. Construction (Residential and Commercial), providing a visual review of the construction 

process to be used for marketing or analysis

3. Property Survey, providing a visual review of the property for marketing or analysis.

4. Property Inspection, providing a visual review of existing conditions for marketing or analysis.

5. Landscaping, providing visual documentation of ‘before and after’ improvement for marketing 

or analysis.

Using a small UAS substantially reduces the risk to public safety in comparison to a manned 

fixed wing aircraft or rotorcraft. Weighing less than 10 pounds, the UASs deployed by Premier 

Drone Solutions are incapable of causing the level of damage or injury that could potentially be 

caused by a full-size, manned aircraft. In addition, the ecologic and noise impact is negligible as 

compared to a traditional manned aircraft. Furthermore, this valuable service is substantially 

more cost-effective than using fixed wing aircraft or rotorcraft, thus providing a means for small 

businesses to capture previously cost-prohibitive, but all too important, data.

Request for Exemption, Section 333 of the FAA Reform Act pertaining to Federal Aviation

Regulations:

14 CFR Part 21

Certification Procedures For Products and Parts

 REASON FOR EXEMPTION

It has been determined that similar UAS’s do not require an airworthiness certificate 

as granted in Exemption No. 11623, 11650, 11664, and 11734.
14 CFR 61.23

Medical Certificate Requirement

 REASON FOR EXEMPTION

It has been determined that this requirement is not applicable for these stated 

purposes, and exemptions have been granted at least twice in exemption #'s 14977 

and 14970. 

14 CFR 61.101(e)4

Recreational Pilots may not act as pilot in command of an aircraft for compensation or hire.

 REASON FOR EXEMPTION

It has been determined a recreational license may be used for compensation or hire 

under these circumstances. See Exemption No.s 14977 and 14970.

14 CFR 61.113(a) and (b)

Private pilot privileges and limitations: (a) No person who holds a private pilot certificate may 

act as a pilot in command (PIC) of an aircraft that is carrying passengers or property for 

compensation or hire; nor may that person, for compensation or hire, act as PIC of an aircraft.

(b) A private pilot may, for compensation or hire, act as PIC 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.

 REASON FOR EXEMPTION 

All flights of the UAS, conducted by the PIC pursuant to the grant of this Petition: (1) 

will be incidental to Premier Drone Solutions’s business; and (2) will not carry 

passengers or property for compensation or hire.

14 CFR 61.315(a)

Sport pilots may not act as pilot in command of an aircraft for compensation or hire.

 REASON FOR EXEMPTION

It has been determined a sport pilot certificate may be used for compensation or hire 

under these circumstances. See Exemption No.s 14977 and 14970.

14 CFR 91.7(a)

Civil Aircraft Airworthiness: (a) No person may operate a civil aircraft unless it is in an airworthy

condition.

 REASON FOR EXEMPTION

It has been determined that similar UAS’s do not require an airworthiness certificate, 

however the petitioner will ensure airworthiness through the combined use of the 

manufacturer's operations manual and preflight checks.
14 CFR 91.119(c)

Minimum Safe Altitudes:(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.

 REASON FOR EXEMPTION

The UAS will be flown no higher than 200’ AGL in line of sight over developed and

developing residential areas that may be considered congested areas. That will not 

always be the case when providing a ‘Property Survey’ flight because they could be 

conducted over empty lots or acreages with no structures. This will minimize the 

amount of bystanders present or in the surrounding area. In the case of flying over or 

near existing private property while providing photography for ‘Residential and 

Commercial Marketing’, ‘Construction Process’, ‘Property Inspection’, and ‘Property 

Landscaping’ landowners will be notified in person by the petitioner, or by a card left 

behind by the petitioner, of an occurring UAS flight. The petitioner also proposes to 

display a caution sign on site while a UAS flight is ongoing. The petitioner will review 

with the landowners the associated risks to people and property. Due to the small 

size of the UAS the associated risk to persons, vessels, vehicles, and structures is 

not comparable to manned aircraft.

14 CFR 91.121

Altimeter Settings.

 REASON FOR EXEMPTION

The UAS does not have a barometric altimeter. It does have a GPS that will calculate

altitude. The petitioner will limit flights to a maximum altitude of 175 feet AGL as 

granted in Exemption No. 11623, 11650, 11664, and 11734.

14 CFR 91.151

Fuel requirements for flight in VFR conditions

 REASON FOR EXEMPTION

The UAS provides low battery warnings to indicate when the Pilot in Command 

should return the UAS to the launch point. The UAS will be landed upon the 1st low 

battery alert. The petitioner will not initiate a flight unless (considering wind and 

forecast weather conditions) there is enough power to fly at normal cruising speed to 

the intended landing point. All flights will be done during the day and at an 

appropriate time as to not be a nuisance to others.

14 CFR 91.405(a)

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.

 REASON FOR EXEMPTION
The petitioner shall inspect the aircraft prior to every flight. The petitioner plans to 

follow manufacturer's recommended preflight checklist.

14 CFR 91.407(a)(1)

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

 REASON FOR EXEMPTION

The petitioner who has the responsibility for the operation and safety of the UAS will

follow the manufacturer's suggestions for maintenance and repair, including the use 

of suggested replacement parts.

14 CFR 91.409(a)(1) & (2)

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. No inspection performed under paragraph

(b) of this section may be substituted for any inspection required by this paragraph unless it is

performed by a person authorized to perform annual inspections and is entered as an "annual"

inspection in the required maintenance records.

 REASON FOR EXEMPTION

The petitioner will follow manufacturer’s suggestions to ensure that the UAS is in a

condition for safe flight.

14 CFR 91.417(a) & (b)

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 (l)(i)(ii)(iii) (2)(i)(ii)(iii)(iv)(v) 

(vi) for the periods specified in paragraph (b) of this section: (1)(2)(3)

 REASON FOR EXEMPTION

The petitioner will keep a record of all repairs and modifications. The petitioner will 

also use manufacturer approved parts for repairs and modifications.

SUMMARY

Premier Drone Solutions, LLC, the petitioner, requests for exemption Section 333 of the FAA 

Reform Act pertaining to Federal Aviation Regulations 14 CFR §§ 61.23(a) and (c), 61.101(e)(4) 

and (5), 61.113(a), 61.315(a), Part 21, 91.7(a), 91.119(c), 91.121, 91.151(a)(1), 91.405(a), 

91.407(a)(l) & (a)(2), 91.409(a)(l) and (2), 91.417(a) and (b) in order to legally operate an 

Unmanned Aircraft System in the National Airspace System in order to collect data including, 

but not limited to, aerial video and photography for real estate marketing, construction, survey, 

landscape and inspection purposes. This submission is substantially similar to granted 

exemptions 14977 and 14970.