26 September 2015

Re: Exemption Request Section 333 of the FAA Reform Act and Part 11 of the Federal

Aviation Regulations from 14 C.F.R. 45.23(b);14 CFR Part 21;14 CFR 61.315 (a) (b) &

(c); 91.7 (a);91.9 (b) (2);91.103(b); 91.109;91.119; 91.121; 91.151(a);91.203(a) &

(b);91.405 (a); 91.407(a) (1); 91.409 (a) (2);91.417 (a) & (b).

U.S. Department of Transportation

Docket Management System

1200 New Jersey Ave., SE

Washington, DC 20590

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, Silver Octopus LLC., operator of Small

Unmanned Aircraft Systems (“sUASs”) equipped to offer on-demand commercial UAS

operations for a host of industries and applications. These include:

• Private and commercial marine vessel videography, photography, inspection and

 patrolling

• Aerial	photography,	videography,	and	surveying;

• Closed-set	filming	and	aerial	photography;

• Surveying,	monitoring,	inspections,	videography,	photography	and	filmmaking;

• Aerial	imaging	for	safety,	monitoring,	inspecting	and/or	recording	of	secured	and

					controlled	environment	construction	sites,	proposed	development	sites,

					inspections	of	property,	and	photography	for	realty	advertisements;

• Precision	photogrammetry	and	crop	scouting;

• Search	and	rescue	and	disaster	operations;

• Educational	research,	technical	demonstrations	and	training;

• Precision	agriculture,	market	research,	surveying,	mapping	and	inspection;	and

• Oil	and	gas	pipeline	inspections,	solar	installation	inspections,	power	line/cable

				inspections,	cooling	tower	inspections,	forestry,	critical	infrastructure	inspections,

				wind	turbine	inspections,	and	radiation	measurement	and	monitoring

Silver Octopus LLC. is a servicing company providing service to the private and 

commercial marine industry as well as real estate development. Silver Octopus LLC. 

President Llyn Buckwalter is a private pilot and USCG Master Mariner with experience 

in private and commercial marine operations, energy sector, safety training and 

operations, and IT. Silver Octopus LLC. would like to use sUAS’s to provide expanded 

services to its existing customers as well as develop new service applications within the 

FAA guidelines.

Silver Octopus LLC hereby applies for an exemption from the listed Federal Aviation 

Regulations (“FARs”) to allow commercial operation of its sUASs, so long as such 

operations are conducted within and under the conditions outlined herein or as may be 

established by the FAA as required by Section 333.
As described more fully below, the requested exemption would permit the operation of

small, unmanned and relatively inexpensive sUAS under controlled conditions in

airspace that is 1) limited 2) predetermined 3) controlled as to access and 4) would

provide safety enhancements to the already safe operations using conventional aircraft.

Approval of this exemption would thereby enhance safety and fulfill the Secretary of

Transportation’s (the FAA Administrator’s) responsibilities to “...establish requirements

for the safe operation of such aircraft systems in the national airspace system.” Section

333(c) of the Reform Act.

Silver Octopus LLC. seeks an exemption to commercially operate the DJI Phantom 3, 

DJI Phantom 2, DJI Inspire1, 3D Robotics X8, 3D Robotics Iris, 3D Robotics Solo. 

Specifications of the aircraft are attached as an Appendix A.

Contact Info

Silver Octopus LLC

622 West Ilex DR

Lake Park FL 33403

llynbuckwalter@yahoo.com

954-612-2866

Relevant Statutory Authority:

This petition for exemption is submitted to fulfill Congress' goal in passing Section 

333(a) through (c) of the Reform Act. Congress has directed the FAA "to safely 

accelerate the integration of civil unmanned aircraft systems into the national airspace 

system." Pursuant to Section 333 of the Reform Act, the FAA Administrator is to 

consider whether certain unmanned aircraft systems may operate safely in the National 

Airspace ("NAS") before completion of the formal UAS rulemaking, based on the 

following considerations:

• The UAS's size, weight, speed, and operational capability;

• Operation of the UAS in close proximity to airports and populated areas; and

• Operation of the UAS within the visual line of sight of the operator.

If the Secretary determines that such vehicles "may operate safely in the National 

Airspace System, the Secretary shall establish requirements for the safe operation of such 

aircraft in the National Airspace System".

Additionally, the FAA Administrator has general authority to grant exemptions from its 

safety regulations and minimum standards, and has done so on numerous occasions, 

when the Administrator decides a requested exemption is in the public interest. A party 

requesting an exemption must explain the reasons why the exemption: (1) would benefit 

the public as a whole, and (2) would not adversely affect safety (or how it would provide 

a level of safety at least equal to the existing rules).

The Federal Aviation Act expressly grants the FAA the authority to issue exemptions. 

This statutory authority, by its terms, includes exempting civil aircraft, as the term is 

defined under 40101 of the Act, from the requirement that all civil aircraft must have a 

current airworthiness certificate and those regulations requiring commercial pilots to 

operate aircraft in commercial service:

The Administrator may grant an exemption from a requirement of a
regulation prescribed under subsection (a) or (b) of this section or

any of sections.

Qualifications for Approval Under Section 333 of the Reform Act

The proposed operations in this petition for exemption qualify for expedited approval 

under Section 333 of the Reform Act. Each of the statutory criteria and other relevant 

factors are satisfied. The proposed operations would permit Silver Octopus LLC. the use 

of small UAS under controlled conditions in airspace that is: (1) predetermined; (2) 

controlled as to access; and that (3) provides an increased level of safety beyond that 

existing when fixed or rotor wing aircraft are used to accomplish the same purpose.

Silver Octopus LLC. uses sUASs that are multirotor, weighing less than 55 pounds 

including payload. They operate, under normal conditions, at speeds not to exceed 87

mph and have the capability to fly, hover, and move in the vertical and horizontal plane. 

Silver Octopus LLC. sUASs will operate in visual line of sight (VLOS), during daylight 

hours, and will only operate within a sterile area. Silver Octopus LLC. will operate at or 

below 400 feet AGL and will file a NOTAM for each flight operated in controlled 

airspace. All required permissions and permits would be obtained from territorial, state, 

county or city jurisdictions, including local law enforcement, fire, or other appropriate 

governmental agencies prior to operating a sUAS.

Given the small size of the sUAS’s involved and the restricted sterile environment within 

which they will operate, Silver Octopus LLC. exemption falls within the zone of safety 

and demonstrates an equivalent level of safety, in which Congress desired the FAA to 

permit commercial UAS operations by exemption pending completion of formal 

rulemaking. Also, due to the size of the sUAS’s and the confined area in which the 

sUAS’s will operate, approval of the application presents no hazard in the NAS.

Considering the clear direction in Section 333 of the Reform Act, the authority contained 

in the Federal Aviation Act, as amended, the equivalent level of safety surrounding the 

proposed operations, and the significant public benefit, the grant of the requested 

exemptions is also in the public interest.

Operations

The applicant 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 even higher level of safety to operations

under the current regulatory structure because the proposed operations represent a

safety enhancement to the already safe operations conducted with conventional aircraft.

These limitations and conditions to which Silver Octopus LLC. agrees to be bound when 

conducting commercial operations under an FAA issued exemption include:

1. The sUAS will weigh less than 55 lbs.

2. Flights will be operated within line of sight (VLOS) of a pic and/or observer.

3. Maximum total flight time for each operational flight will be 30 minutes. Flights will 

be terminated at 25% battery power reserve should that occur prior to the 30 minute 

limit.

4. Flights will be operated at an altitude of no more than 400 feet AGL or, not more than

 200 feet above an elevated platform from which filming is planned.
5. Minimum crew for each operation will consist of the sUAS Pilot, the Visual Observer,

and/or the Camera Operator.

6. sUAS pilot will be an FAA licensed airman with at least a sport pilot’s certificate and

hold a class 3 medical certificate or a valid driver’s license.

7. sUAS Pilot will be Pilot in Command (PIC). If a pilot certificate holder other than the

sUAS Pilot, who possess the necessary PIC qualifications, is also present (i.e. the 

Visual Observer), that person can also be designated as the PIC.

8. The sUAS will only operate within a confined “Sterile Area” of the flight operations 

area.

9. 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

within the boundaries of the safety perimeter be present for this briefing.

10. The operator will obtain the consent of all persons involved and ensure that only

consenting persons will be allowed within 100 feet of the flight operation, and this 

radius may be reduced to 30 feet based upon an equivalent level of safety 

determination. With the advanced permission of the relevant FSDO, operations at 

closer range can be approved.

11. Pilot and observer will have been trained in operation of sUAS generally and received

up-to-date information on the particular sUAS to be operated.

12. Observer and pilot will at all times are able to communicate by voice or text.

13. Written and/or oral permission from the relevant property holders will be obtained.

14. All required permissions and permits will be obtained from territorial, state, county or

city jurisdictions, including local law enforcement, fire, or other appropriate 

governmental agencies.

15. If the sUAS loses radio communications, the sUAS will have the capability to return

to a pre-determined location within the Security Perimeter and land.

16. The sUAS will have the capability to abort a flight in case of unpredicted obstacles or

emergencies.

17. The sUAS may not operate within 5 nautical miles 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.

18. The UA may not be operated less than 500 feet below or less than 2,000 feet

horizontally from a cloud or when visibility is less than 3 statute miles from the

PIC.
The Extent of FAR Relief requested and the equivalent safety.

14 CFR Part 21, Subpart H – Airworthiness Certificates

14 CFR 61.315 (a) (b) &(c); Private Pilot Privileges for commercial operations: Pilot in 

Charge

14 CFR 91.7 (a) – Airworthiness required for operation

14 CFR 91.9 (b) (2) Civil Aircraft flight manual in aircraft

14 CFR 91.103(b) – Preflight Action

14 CFR 91.109 – Flight instruction

14 CFR 91.119 (c), Minimum safe altitudes

14 CFR 91.121 – Altimeter settings

14 CFR 91.151(a) (1) - Fuel requirements for flights in VFR

14 CFR 91.203(a) &(b) – Carrying Civil aircraft certification and registration

14 CFR 91.405 (a) Maintenance required

14 CFR 91.407(a) (1) Operations after maintenance

14 CFR 91.409 (a) (1) (2) - Inspections

14 CFR 91.417 (a) & (b) - Maintenance records

14 CFR Part 21, Subpart H – Airworthiness Certificates

Subpart H, entitled Airworthiness Certificates, establishes the procedural requirements

for the issuance of airworthiness certificates as required by FAR §91.203 (a) (1). Given

the size and limited operating area associated with the aircraft to be utilized by the

Applicant, an exemption from Part 21 Subpart H meets the requirements of an equivalent

level of safety under Part 11 and Section 333 of the Reform Act. 

The Federal Aviation Act (49 U.S.C.§44701 (f)) and Section 333 of the Reform Act both 

authorize the FAA to exempt aircraft from the requirement for an airworthiness 

certificate, upon consideration of the size, weight, speed, operational capability, and 

proximity to airports and populated areas of the particular small UAS. In all cases, an 

analysis of these criteria demonstrates that the small UAS operated without an 

airworthiness certificate, in the restricted environment and under the conditions proposed 

will be at least as safe, or safer, than a conventional aircraft (fixed wing or rotorcraft) 

operating with an airworthiness certificate without the restrictions and conditions 

proposed.

The FAA has issued the following exemptions to this regulation: Exemption Nos. 8607,

8737, 8738, 10167A, 10602,

14 CFR 61.315 (a) (b) &(c); Private Pilot Privileges for commercial operations: Pilot 

in Charge

Relief from Section 61.113(a) and (b) entitled Private pilot privileges and

limitations: Pilot in command, is requested to the extent necessary to allow a PIC holding 

a private pilot or higher level certificate, as well as a current and valid airman medical

certificate, and who has met certain flight-hour and currency requirements, to conduct the

proposed UAS flight operations for compensation or hire.

This relief is requested since the limitations set forth in Section 61.113(a) and (b)

state that 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.

Silver Octopus LLC. will have a PIC’s with at least the minimum of sport pilot and third 

class airmen medical certificate. The owner of the company holds a private pilot.

The FAA has issued the following exemptions to this regulation: Exemption Nos. 8607,

8737, 8738, 10167A, 10602,

14 CFR 91.7 (a) – Airworthiness required for operation

The regulation requires that no person may operate a civil aircraft unless it is in airworthy

condition. 

As there will be no airworthiness certificate issued for the aircraft, should this

exemption be granted, no FAA regulatory standard will exist for determining

airworthiness. Given the size of the aircraft for maintenance and use of safety checklists

prior to each flight an equivalent level of safety will be provided. 

14 CFR 91.9 (b) (2) Civil Aircraft flight manual in aircraft

No person may operate a U.S.-registered civil aircraft ...

(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.

The sUAS, given its size and configuration has no ability or place to carry such a

flight manual on the aircraft, not only because there is no pilot on board, but because

there is no room or capacity to carry such an item on the aircraft.

The equivalent level of safety will be maintained by keeping the flight manual at the

ground control point where the pilot flying the sUAS will have immediate access to it.

The FAA has issued the following exemptions to this regulation: Exemption Nos. 8607,

8737, 8738, 10167A, 10602,

14 CFR 91.103(b) – Preflight Action

This regulation requires each pilot in command to take certain actions before flight to

insure the safety of flight. 

As FAA approved rotorcraft flight manuals will not be provided for the aircraft an 

exemption will be needed. The PIC will take all actions including reviewing weather, 

flight battery requirements, landing and takeoff distances and aircraft performance data 

before initiation of flight.

14 CFR 91.109 – Flight instruction

Section 91.103 provides that no person may operate a civil aircraft (except a manned

free balloon) that is being used for flight instruction unless that aircraft has fully

functioning dual controls. 

sUASs and remotely piloted aircraft, by their design do not have fully functional dual 

controls. Flight control is accomplished through the use of a control box that
communicates with the aircraft via radio communications. The equivalent level of safety 

provided by the fact that neither a pilot nor passengers will be carried in the aircraft and 

by the size and speed of the aircraft. The FAA has approved exemptions for flight 

training without fully functional dual controls for a number of aircraft and for flight 

instruction in experimental aircraft. See Exemption Nos.5778K & 9862A

14 CFR 91.119 (c), Minimum safe altitudes

Section 91.121, entitled Altimeter settings, subsection (a), states the following, in

part: (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.

Silver Octopus LLC. requests authority to operate at altitudes only up to 400 AGL over 

uncongested areas. The UA will operate in a limited area within pre-defined boundaries 

with the consent of the landowner/controller and require that all non-essential persons 

remain clear of the flight area during operations. The PIC will make a safety assessment 

of the risk of operating the UA and ensure no undue hazard is present for persons or 

property. Considering the size, weight, and speed of the UA, these protections will ensure 

the equivalent level of safety of minimum safe altitudes. Compared to flight operations 

for manned aircraft and the lack of flammable fuel, any risk associated with the proposed 

UA operations is far less than conventional aircraft operating at or below 500 AGL. In 

addition, the low altitude operations of the UA will ensure separation with conventional 

aircraft.

14 CFR 91.121 – Altimeter settings

This regulation requires each person operating an aircraft to maintain cruising altitude by

reference to an altimeter that is set “...to the elevation of the departure airport or an

appropriate altimeter setting available before departure.” 

As the small UAS may not have a barometric altimeter, but instead a GPS altitude read 

out, an exemption may be needed. An equivalent level of safety will be achieved by the 

operator, pursuant to the safety check list and live flight data monitoring, confirming the 

altitude of the launch site shown on the GPS altitude indicator before flight.

14 CFR 91.151(a) (1) - Fuel requirements for flights in VFR

Section 91.151 (a) prohibits an individual from beginning “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.” 
The battery powering the small UAS provides approximately 30 minutes of powered 

flight. To meet the 30 minute reserve requirement in 14 CFR §91.151, small UAS flights 

would be limited to approximately 0-10 minutes in length due to only having 30-40 min. 

approximately of battery. Given the limitations on the small UAS’s proposed flight area 

and the location of its proposed operations within a predetermined area, a longer time 

frame for flight in daylight or twilight VFR conditions is reasonable. Applicant believes 

that an exemption from 14 CFR §91.151(a) falls within the scope of prior exemptions. 

Operating the small UAS, in a tightly controlled area where only people and property 

owners or official representatives who have signed waivers will be allowed, with less 

than 30 minutes of reserve fuel, does not engender the type of risks that Section 91.151(a) 

was intended to alleviate given the size and speed of the small sUAS. Sliver Octopus 

LLC. believes that an equivalent level of safety can be achieved by limiting flights to 30 

minutes or 25% of battery power whichever happens first. This restriction would be more 

than adequate to return the sUAS to its planned landing zone from anywhere in its limited 

operating area.

Similar exemptions have been granted to other operations, including Exemptions 2689F,

5745, 10673, and 10808.

14 CFR 91.203(a) &(b) – Carrying Civil aircraft certification and registration

The regulation provides in pertinent part:

(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. . . .

(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.

The UAS fully loaded weighs no more than 55 lbs and is operated without an onboard

pilot. As such, there is no ability or place to carry certification and registration documents

or to display them on the sUAS. An equivalent level of safety will be achieved by 

keeping these documents at the ground control point where the pilot flying the sUAS will 

have immediate access to them, to the extent they are applicable to the sUAS. The FAA 

has issued numerous exemptions to this regulation. A representative sample of other 

exceptions includes Exemption Nos. 9565, 9665, 9789, 9789A, 9797, 9797A, 9816A, and 

10700.

14 CFR 91.405 (a) 91.407(a) (1) 91.409 (a) (1) (2) 91.417 (a) & (b) - Maintenance 

These regulations require that an aircraft operator or owner “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...,” and others shall inspect or maintain the aircraft in

compliance with Part 43. 

Given that these section and Part 43 apply only to aircraft with an airworthiness 

certificate, these sections will not apply to the applicant. Maintenance will be 

accomplished by the operator pursuant to the flight manual and operating handbook. 
An equivalent level of safety will be achieved because these small UASs are

very limited in size and will carry a small payload and operate only in restricted areas for

limited periods of time. If mechanical issues arise the small UAS can land immediately

and will be operating from no higher than 400 feet AGL. The operator will ensure that

the small UAS is in working order prior to initiating flight, perform required

maintenance, and keep a log of any maintenance performed. Moreover, the operator is the

person most familiar with the aircraft and best suited to maintain the aircraft in an

airworthy condition to provide the equivalent level of safety.

An equivalent level of safety will be achieved because maintenance and inspections will

be performed in accordance with the small UAS Manufacturer's Manual, as referenced in

the Aircraft Operations Manual (AOM). As provided in the FOM, the operator will

ensure that the small UAS is in working order prior to initiating flight and perform

required maintenance needed. (Appendix B contains Maintenance Logs example)

Privacy

All flights will occur over private or controlled access property with the property owner’s

prior consent and knowledge. Filming will be of people who have also consented to

being filmed or otherwise have agreed to be in the area where filming will take place.

The grant of this exemption request will provide improved safety in both day and night

operations. 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 UAS.

The public will benefit from the approval as a whole.

The use of small light weight sUAS’s to conduct inspections and videography is in the 

publics interest. sUAS can eliminate the need for a person to go into a hazardous 

environment for routine inspection or trouble shooting. A sUAS will also cut the 

environmental impact due to its low energy consumption compared to traditional aircraft. 

The noise pollution from a battery operated sUAS is a small fraction of traditional 

aircraft. Traditional rotary aircraft, carrying liquid fuel, conducting video, photography 

and inspections under 400ft AGL posses a much higher potential of hazard to persons and 

property than a battery powered sUAS under 55lbs. Emergency operations and disaster 

response sUAS can minimized the hazards to responders by giving detailed views and 

information without sending persons into a dangerous area. Silver Octopus LLC. also 

believes that the development of new economic avenues of use for the sUAS is important 

to the US economy as whole. Granting the exemptions would allow Silver Octopus LLC. 

to operate with the legal regulation provided by the FAA and ensuring that sUAS 

operations are done in the safest manner possible.

In accordance with 14 C.F.R. Part 11, the following summary is provided for 

publication in the Federal Register, should it be determined that publication is 

needed:

Applicant seeks an exemption from the following rules:

14 C.F.R. §21, subpart H; 14 C.F.R. 61.315( a) (b) & (c);91.7 (a);
91.9 (b) (2); 91.103(b); 91.109; 91.119 (c); 91.121; 91.151(a) (1); 91.203(a) & (b); 

91.405 (a); 91.407 (a) (1); 91.409 (a) (1); 91.409 (a) (2) and 91.417 (a) & (b) to operate

commercially a small unmanned vehicle (55lbs or less). Approval of exemptions 

allowing commercial operations of sUASs, will enhance safety by reducing risk. 

Conventional operations, using jet or piston power aircraft, operate at extremely low 

altitudes just feet from the subjects being filmed and in extreme proximity to people and 

structures and present the risks associated with vehicles that weigh in the neighborhood 

of 4,000lbs, carrying large amounts of jet A or other fuel. Such aircraft must fly to and 

from the operational location. In contrast, a sUAS weighing fewer than 55 lbs. and 

powered by batteries eliminates virtually all of that risk given the reduced mass and lack 

of combustible fuel carried on board. The sUAS is carried to the operation site and not 

flown. The sUAS will carry no passengers or crew and, therefore, will not expose them to 

the risks associated with manned aircraft flights. The operation of small UASs, weighting

less than 55 lbs., conducted in the strict conditions outlined above, will provide an

equivalent level of safety supporting the grant of the exemptions requested herein, 

including exempting the applicant from the requirements of Part 21 and allowing 

commercial operations. These lightweight aircraft operate at slow speeds, close to the 

ground, and in a sterile environment and, as a result, are far safer than conventional 

operations conducted.

Conclusion.

Silver Octopus LLC. is seeking an exemption in order to utilize sUAS’s in the 

performance of aerial photography, videography survey and inspection. Industries 

serviced are both private and commercial in, and not limited to, real estate, marine, 

construction, agriculture, and energy. Silver Octopus LLC has asked for a broad scope to 

continue developing new ways to employ sUAS’s within the structure permitted via the 

FAA. Our market shows a large demand for business capable of providing legal services 

to real estate, construction and surveying. Even more demand is found in offering ne 

innovative ways to employ the technology to other industries. Silver Octopus LLC. has 

refrained from engaging in commercial use with sUAS. Granting the exemption would 

allow Silver Octopus LLC. to legally service it’s customers and help develop new sUAS 

uses with the highest standards and in full compliance with FAA regulations.

Thank you for you consideration.

Llyn Buckwalter.

Managing Member

Silver Octopus LLC.

622 West Ilex DR. 

Lake Park FL 33403
Apendix A

sUAS DJI Phantom 3 DJI Phantom 2 DJI Inspire 1 3d Robotics X8 3d Robotics Iris 3d Robotics Solo

Size 18”x13”x8” 16”x16”x8” 17 1/4”x17 3/4”x12” 13.7”x20.1”x11.8” 26.7x55.5x13.3mm 10”x18”x18”

Total Weight 1280g 1242g 2935g 3500g 1282g 1500

Max Ascent Speed 5 m/s 6 m/s 5 m/s 5 m/s not avial. not avial.

Max Descent 

Speed

3 m/s 2 m/s 4 m/s 4 m/s not avial. not avial.

Max Flight Speed 16 m/s 15 m/s 22 m/s 30m/s 22m/s 22m/s

Controller 

Frequency

(Main Controller)

2.4GHz-2.483GHz 5.728GHz-5.85GHz 5.728GHz-5.85GHz;

2.4GHz-2.483GHz

915MHz or 433MHz 2.4GHz 2.4GHz

Controller Range 2000m 800m 2000m 1000m 1000m 800m

Links to User 

Manuals

http://download.djiinnovations.com/

downloads/

phantom_3/en/

Phantom_3_Profess

ional_User_Manual_

v1.4_en_0915.pdf

http://download.djiinnovations.com/

downloads/

phantom_2_vision_p

lus/en/

Phantom_2_Vision_

Plus_User_Manual_

v1.8_en.pdf

http://download.djiinnovations.com/

downloads/

inspire_1/en/

Inspire_1_User_Ma

nual_v1.4_en.pdf

http://

3drobotics.com/wpcontent/uploads/

2015/04/X8-

Operation-ManualvC.pdf

http://

3drobotics.com/wpcontent/uploads/

2015/02/IRIS-PlusOperation-ManualvH-web.pdf

http://

3drobotics.com/kb/

solo-user-manual/

Previous 

Exemption 

Numbers

12814, 12806, 

12821

12205,12807, 

12786, 12796

12814, 12804, 

12807,12786

12842 11490, 12833, 

12842

12826, 12804
Appendix B

MONTHLY MAINTENANCE LOG

UAS #: ___________________ Date Issue 

Discoverd

Date Issue 

Addressed Issue Description & Maintenance Conducted

Maintenace Preformed 

by:

Print & Sign 

Software Updates

Airframe

Engines

Propellers

Camera Gimbal

Landing Gear

Vibration Dampening

Other