May 22, 2015

Exemption No. 11656

Regulatory Docket No. FAA–2015–0548

Mr. Todd Thomas

Drone Pics

P.O. Box 2254

Surf City, NC 28445

Dear Mr. Thomas:

This letter is to inform you that we have granted your request for exemption. It transmits our 

decision, explains its basis, and gives you the conditions and limitations of the exemption, 

including the date it ends.

By letter dated February 13, 2015, you petitioned the Federal Aviation Administration (FAA) 

for an exemption. The exemption would allow the petitioner to operate an unmanned aircraft 

system (UAS) to conduct aerial photography, videography, and surveying.

See Appendix A for the petition submitted to the FAA describing the proposed operations and 

the regulations that the petitioner seeks an exemption.

The FAA has determined that good cause exists for not publishing a summary of the petition 

in the Federal Register because the requested exemption would not set a precedent, and any 

delay in acting on this petition would be detrimental to the petitioner.

Airworthiness Certification

The UAS proposed by the petitioner is a DJI Phantom 2 Vision+.

The petitioner requested relief from 14 CFR part 21, Certification procedures for products 

and parts, Subpart H—Airworthiness Certificates. In accordance with the statutory criteria 

provided in Section 333 of Public Law 112−95 in reference to 49 U.S.C. § 44704, and in 

consideration of the size, weight, speed, and limited operating area associated with the 

aircraft and its operation, the Secretary of Transportation has determined that this aircraft 
2

meets the conditions of Section 333. Therefore, the FAA finds that the requested relief from 

14 CFR part 21, Certification procedures for products and parts, Subpart H—Airworthiness 

Certificates, and any associated noise certification and testing requirements of part 36, is 

not necessary.

The Basis for Our Decision

You have requested to use a UAS for aerial data collection. The FAA has issued grants of 

exemption in circumstances similar in all material respects to those presented in your petition. 

In Grants of Exemption Nos. 11062 to Astraeus Aerial (see Docket No. FAA−2014−0352), 

11109 to Clayco, Inc. (see Docket No. FAA−2014−0507), 11112 to VDOS Global, LLC (see

Docket No. FAA−2014−0382), and 11213 to Aeryon Labs, Inc. (see Docket No. 

FAA−2014−0642), the FAA found that the enhanced safety achieved using an unmanned 

aircraft (UA) with the specifications described by the petitioner and carrying no passengers or 

crew, rather than a manned aircraft of significantly greater proportions, carrying crew in 

addition to flammable fuel, gives the FAA good cause to find that the UAS operation enabled 

by this exemption is in the public interest.

Having reviewed your reasons for requesting an exemption, I find that—

 They are similar in all material respects to relief previously requested in Grant of 

Exemption Nos. 11062, 11109, 11112, and 11213;

 The reasons stated by the FAA for granting Exemption Nos. 11062, 11109, 11112, and 

11213 also apply to the situation you present; and 

 A grant of exemption is in the public interest.

Our Decision

In consideration of the foregoing, I find that a grant of exemption is in the public interest. 

Therefore, pursuant to the authority contained in 49 U.S.C. 106(f), 40113, and 44701, 

delegated to me by the Administrator, Mr. Todd Thomas dba Drone Pics is granted an 

exemption from 14 CFR §§ 61.23(a) and (c), 61.101(e)(4) and (5), 61.113(a), 61.315(a), 

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

91.417(a) and (b), to the extent necessary to allow the petitioner to operate a UAS to perform 

aerial data collection. This exemption is subject to the conditions and limitations listed 

below.

Conditions and Limitations

In this grant of exemption, Mr. Todd Thomas dba Drone Pics is hereafter referred to as 

the operator.

Failure to comply with any of the conditions and limitations of this grant of exemption will be 

grounds for the immediate suspension or rescission of this exemption.
3

1. Operations authorized by this grant of exemption are limited to the DJI Phantom 2 

Vision+ when weighing less than 55 pounds including payload. Proposed operations 

of any other aircraft will require a new petition or a petition to amend this exemption.

2. Operations for the purpose of closed-set motion picture and television filming are 

not permitted. 

3. The UA may not be operated at a speed exceeding 87 knots (100 miles per hour). The 

exemption holder may use either groundspeed or calibrated airspeed to determine 

compliance with the 87 knot speed restriction. In no case will the UA be operated at 

airspeeds greater than the maximum UA operating airspeed recommended by the 

aircraft manufacturer.

4. The UA must be operated at an altitude of no more than 400 feet above ground level 

(AGL). Altitude must be reported in feet AGL.

5. The UA must be operated within visual line of sight (VLOS) of the PIC at all times. 

This requires the PIC to be able to use human vision unaided by any device other than 

corrective lenses, as specified on the PIC’s FAA-issued airman medical certificate or

U.S. driver’s license.

6. All operations must utilize a visual observer (VO). The UA must be operated within 

the visual line of sight (VLOS) of the PIC and VO at all times. The VO may be used 

to satisfy the VLOS requirement as long as the PIC always maintains VLOS 

capability. The VO and PIC must be able to communicate verbally at all times; 

electronic messaging or texting is not permitted during flight operations. The PIC 

must be designated before the flight and cannot transfer his or her designation for the 

duration of the flight. The PIC must ensure that the VO can perform the duties 

required of the VO.

7. This exemption and all documents needed to operate the UAS and conduct its 

operations in accordance with the conditions and limitations stated in this grant of 

exemption, are hereinafter referred to as the operating documents. The operating 

documents must be accessible during UAS operations and made available to the 

Administrator upon request. If a discrepancy exists between the conditions and 

limitations in this exemption and the procedures outlined in the operating documents, 

the conditions and limitations herein take precedence and must be followed. 

Otherwise, the operator must follow the procedures as outlined in its operating 

documents. The operator may update or revise its operating documents. It is the 

operator’s responsibility to track such revisions and present updated and revised 

documents to the Administrator or any law enforcement official upon request. The 

operator must also present updated and revised documents if it petitions for extension 

or amendment to this grant of exemption. If the operator determines that any update 
4

or revision would affect the basis upon which the FAA granted this exemption, then 

the operator must petition for an amendment to its grant of exemption. The FAA’s 

UAS Integration Office (AFS−80) may be contacted if questions arise regarding 

updates or revisions to the operating documents.

8. Any UAS that has undergone maintenance or alterations that affect the UAS operation 

or flight characteristics, e.g., replacement of a flight critical component, must undergo 

a functional test flight prior to conducting further operations under this exemption. 

Functional test flights may only be conducted by a PIC with a VO and must remain at 

least 500 feet from other people. The functional test flight must be conducted in such 

a manner so as to not pose an undue hazard to persons and property.

9. The operator is responsible for maintaining and inspecting the UAS to ensure that it is 

in a condition for safe operation.

10. Prior to each flight, the PIC must conduct a pre-flight inspection and determine the 

UAS is in a condition for safe flight. The pre-flight inspection must account for all 

potential discrepancies, e.g., inoperable components, items, or equipment. If the 

inspection reveals a condition that affects the safe operation of the UAS, the aircraft is 

prohibited from operating until the necessary maintenance has been performed and the 

UAS is found to be in a condition for safe flight.

11. The operator must follow the UAS manufacturer’s maintenance, overhaul, 

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

aircraft components.

12. Each UAS operated under this exemption must comply with all manufacturer 

safety bulletins.

13. Under this grant of exemption, a PIC must hold either an airline transport, 

commercial, private, recreational, or sport pilot certificate. The PIC must also hold a 

current FAA airman medical certificate or a valid U.S. driver’s license issued by a 

state, the District of Columbia, Puerto Rico, a territory, a possession, or the Federal 

Government. The PIC must also meet the flight review requirements specified in 

14 CFR § 61.56 in an aircraft in which the PIC is rated on his or her pilot certificate.

14. The operator may not permit any PIC to operate unless the PIC demonstrates the 

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

operated under this exemption, including evasive and emergency maneuvers and 

maintaining appropriate distances from persons, vessels, vehicles and structures. PIC 

qualification flight hours and currency must be logged in a manner consistent with 

14 CFR § 61.51(b). Flights for the purposes of training the operator’s PICs and VOs 

(training, proficiency, and experience-building) and determining the PIC’s ability to 

safely operate the UAS in a manner consistent with how the UAS will be operated 
5

under this exemption are permitted under the terms of this exemption. However, 

training operations may only be conducted during dedicated training sessions. During 

training, proficiency, and experience-building flights, all persons not essential for 

flight operations are considered nonparticipants, and the PIC must operate the UA 

with appropriate distance from nonparticipants in accordance with 14 CFR § 91.119.

15. UAS operations may not be conducted during night, as defined in 14 CFR § 1.1. All 

operations must be conducted under visual meteorological conditions (VMC). Flights 

under special visual flight rules (SVFR) are not authorized.

16. The UA 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.

17. 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.

18. If the UAS loses communications or loses its GPS signal, the UA must return to a 

pre-determined location within the private or controlled-access property.

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

20. The PIC is prohibited from beginning a flight unless (considering wind and forecast 

weather conditions) there is enough available power for the UA to conduct the 

intended operation and to operate after that for at least 5 minutes or with the reserve 

power recommended by the manufacturer if greater.

21. Air Traffic Organization (ATO) Certificate of Waiver or Authorization (COA). All 

operations shall be conducted in accordance with an ATO-issued COA. The 

exemption holder may apply for a new or amended COA if it intends to conduct 

operations that cannot be conducted under the terms of the attached COA.

22. All aircraft operated in accordance with this exemption must be identified by serial 

number, registered in accordance with 14 CFR part 47, and have identification 

(N−Number) markings in accordance with 14 CFR part 45, Subpart C. Markings must 

be as large as practicable.

23. Documents used by the operator to ensure the safe operation and flight of the UAS and 

any documents required under 14 CFR §§ 91.9 and 91.203 must be available to the 

PIC at the Ground Control Station of the UAS any time the aircraft is operating. 
6

These documents must be made available to the Administrator or any law enforcement 

official upon request.

24. The UA must remain clear and give way to all manned aviation operations and 

activities at all times. 

25. The UAS may not be operated by the PIC from any moving device or vehicle. 

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

persons, vessels, vehicles, and structures unless:

a. Barriers or structures are present that sufficiently protect nonparticipating persons 

from the UA and/or debris in the event of an accident. The operator must ensure 

that nonparticipating persons remain under such protection. If a situation arises 

where nonparticipating persons leave such protection and are within 500 feet of 

the UA, flight operations must cease immediately in a manner ensuring the safety 

of nonparticipating persons; and

b. The owner/controller of any vessels, vehicles or structures has granted permission 

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

the risk of operating closer to those objects and determined that it does not 

present an undue hazard.

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

nonparticipating persons under this exemption.

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

permission from the property owner/controller or authorized representative. 

Permission from property owner/controller or authorized representative will be 

obtained for each flight to be conducted.

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

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

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

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

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

If this exemption permits operations for the purpose of closed-set motion picture and 

television filming and production, the following additional conditions and limitations apply.

29. The operator must have a motion picture and television operations manual (MPTOM) 

as documented in this grant of exemption.

30. At least 3 days before aerial filming, the operator of the UAS affected by this 

exemption must submit a written Plan of Activities to the local Flight Standards 

District Office (FSDO) with jurisdiction over the area of proposed filming. The 3-day 
7

notification may be waived with the concurrence of the FSDO. The plan of activities 

must include at least the following:

a. Dates and times for all flights;

b. Name and phone number of the operator for the UAS aerial filming conducted 

under this grant of exemption;

c. Name and phone number of the person responsible for the on-scene operation of 

the UAS;

d. Make, model, and serial or N−Number of UAS to be used;

e. Name and certificate number of UAS PICs involved in the aerial filming;

f. A statement that the operator has obtained permission from property owners 

and/or local officials to conduct the filming production event; the list of those 

who gave permission must be made available to the inspector upon request;

g. Signature of exemption holder or representative; and

h. A description of the flight activity, including maps or diagrams of any area, city, 

town, county, and/or state over which filming will be conducted and the altitudes 

essential to accomplish the operation.

31. Flight operations may be conducted closer than 500 feet from participating persons 

consenting to be involved and necessary for the filming production, as specified in the 

exemption holder’s MPTOM.

Unless otherwise specified in this grant of exemption, the UAS, the UAS PIC, and the UAS 

operations must comply with all applicable parts of 14 CFR including, but not limited to, 

parts 45, 47, 61, and 91.

This exemption terminates on May 31, 2017, unless sooner superseded or rescinded.

Sincerely,

/s/

John S. Duncan

Director, Flight Standards Service

Enclosures
February 13, 2015 

U.S. Department of Transportation 

Docket Management System 

1200 New Jersey Ave., SE 

Washington, DC 20590 

Re: Exemption Request under Section 333 of the FAA Reform Act and 

Part 11 of the Federa I 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, Todd Thomas dba Drone Pies, the operator of small Unmanned Aircraft 

Systems ("sUAS"), seeks an exemption from the Federal Aviation Regulations ("FARs") listed 

below and discussed in Appendix A. Attached as Appendix B is a summary of this request. 

The requested exemption would permit commercia l operation of Todd Thomas dba Drone Pies 

sUAS's, which weigh approximately Sibs. and performs aerial surveys and videography that 

consists of still photographs and videography taken by on board cameras. The sUAS's takes a 

series of high quality, still digital images and video that are used to promote real estate sales 

and survey in North Carolina. Additional aerial inspections/survey applications may include 

construction jobsite monitoring, pipeline inspection and precision topological surveys. Use of 

the sUAS for aerial inspections and surveys reduce the need to utilize conventional manned 

aircraft, manned lifting devices or manned climbing for the same purpose and provides very 

high quality imagery at a fraction of the cost. These savings result in enhanced safety, 

efficiency and productivity for the affected activities, as well as environmental benefits. 

Operations under the exemption will be subject to strict operating requirements and conditions 

to ensure at least an equivalent level of safety to currently authorized operations using manned 

aircraft and under conditions as may be modified by the FAA as requ ired by Section 333. 

As described more fully below, the requested exemption would authorize commercial 

operations of aerial photos and inspections or surveys using the sUAS's, which weigh less than 5 

lbs. and are small in size. (See attached O&M manuals for the DJI Phantom 2 Vision+). The 

sUAS's will be ope rated under controlled condit ions at low altit ude in airspace that is limited in 

scope, as described more fully herein; it will have automated control features as described 

below and in the O&M manuals. The sUAS also will be operated by an individual who has FAA 

Rotorcraft Private Pilot License and has a current medical certification. Finally, t he airspace in 

which the sUAS will operate will be Class G airspace or airspace approved by the FAA in 

advance. 

1 
Todd Thomas dba Drone Pies respectfully submits that because these small, unmanned aerial 

vehicles will be used in lieu of comparatively hazardous operations now conducted with fixed 

wing and rotary conventional aircraft or other manned means of inspections, the FAA can have 

confidence that the operations will achieve at least the equivalent level or greater level of 

safety. Approval of the exemptions would thereby enhance safety and fulfill the Secretary of 

Transportation's (the FAA Administrator's) responsibilities under Section 333(c) of the Reform 

Act to "establish requirements for the safe operation of such aircraft systems in the national 

airspace system." 

The name and address of the applicant are: 

Todd Thomas dba Drone Pies 

Att: Todd Thomas 

Ph: 910-262-1135 

Email: thotrash@yahoo.com 

Address: P.O. Box 2254 

Surf City, NC 28445 

The regulations from which the exemption is requested are as follows: 

14 C.F.R. Part 21; 

14 C.F.R. 45.23(b); 

14 C.F.R. 61.113(a) & (b); 

14 C.F.R. 61.133 (a); 

14 C.F.R. 91.7(b); 

14 C.F.R. 91.9(b)(2); 

14C.F.R. 91.109(a); 

14 C.F.R. 91.119; 

14 C.F.R. 91.121; 

14 C.F.R. 91.151(a); 

14 C.F.R. 91.203(a) & (b); 

14 C.F.R. 91.405(a); 

14 C.F.R. 91.407(a)(1); 

14 C.F.R. 91.409(a)(2}; 

14 C.F.R. 91.417(a) & (b). 

2 
Appendix A discusses each rule listed above and explains why exemptions pursuant to the 

proposal set forth in this letter are appropriate, provide an equivalent level of safety, and are in 

the public interest. 

The Applicable Legal Standard under Section 333 

Todd Thomas dba Drone Pies submits that grant of this exemption application for use of the 

proposed UAS's in precision aerial inspections will advance the Congressional mandate in 

Section 333 of the Reform Act to accelerate the introduction of UASs into the national airspace 

system ("NAS") if it can be accomplished safely. This law directs the Secretary of 

Transportation to consider whether certain UASs may operate safely in the NAS before 

completion of the rulemaking required under the Section 332 of the Reform Act. In making this 

determination, the Secretary is required to determine which types of UASs do not create a 

hazard to users of the NAS or the public or pose a threat to national security in the light of the 

following: 

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

• Operation of the sUAS in closed proximity to airports and populated areas; and 

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

Reform Act §333{a)(1). If the Secretary determines that such vehicles "may operate safely in 

the national airspace system, the Secretary shall establish requirement for the safe operation of 

such aircraft in the national airspace system." ld. §333(c) (emphasis added). 1 

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 the sections 44702-44716 

of this title if the Administrator finds the exemption is in the public interest. 

1Applicant submits that this provision places a duty on the Administrator to not only process 

applications for exemptions under Section 333, but for the Administrator, if he deems the 

conditions proposed herein require modification in order to allow approval, to supply 

conditions for the safe operation of UAS. Todd Thomas dba Drone Pies welcomes the 

opportunity to consult with FAA staff in order to address any issues or concerns that this 

proposal may raise that they believe may require modification. 

49 U.S.C. §44701(f). See also 49 U.S.C. §44711 (a); 49 U.S.C. §44704; 14 C.F.R. §91.203(a)(1). 

3 
The grant of the requested exemption is in the public interest based on the clear direction in 

Section 333 of the Reform Act; the additional authority in the Federal Aviation Act, as 

amended; the strong equivalent level of safety surrounding the proposed operations; and the 

significant public benefit, including enhanced safety and cost savings associated with 

transitioning to UASs for aerial inspections and survey photography and real estate 

photography. Accordingly, the applicant respectfully requests that the FAA grant the requested 

exemption without delay. 

Airworthiness of the sUAS 

A critical element of the exemption application involves evidence of the airworthiness oft he 

sUAS. 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 sUAS. Our small UAS's will operate at low speed in a 

controlled environment, at least five miles from an airport or densely populated area. An 

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

certificate, in the restricted environment and under the conditions proposed will be a least as 

safe, or safer, than a conventional aircraft (fixed wing or helicopter) operating with an 

airworthiness certificate without the restrictions and conditions proposed. 

Mandatory Operating Conditions (see O&M and Safety lists) 

Grant of the exemption to Todd Thomas dba Drone Pies will be subject to the following 

mandatory conditions, which are based upon operating conditions set forth for operation of 

sUAS by public entities pursuant to Certificates of Authorization, with additional restrictions: 

4 

• All operations to occur in Class G airspace. 

• Operations to avoid congested or populated areas, which are depicted in yellow on VFR 

charts. 

• Operations to be conducted over private or controlled-access property. 

• Permission from land owner/controller required before commencing flight. 

• Operations to occur during Visual Flight Rules Meteorological Conditions (VMC). 

• Aircraft to remain within Visual Line of Sight (VLOS). 

o VLOS guaranteed with a cylinder of operation around operator of Yi nautical miles 

(NM). 

o Cylinder walls may be expanded by observer with ability to control aircraft. 

• Operations to occur during daylight hours. 

• Above Ground Level (AGL) altitude to be restricted to 400 feet. 

• All operations conducted in vicinity of airport to remain more than 2.5 NM from 

centerline azimuth of runway centerline measured from runway thresholds 
• All required permissions and permits will be obtained from territorial, stat e, county or 

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

governmental agencies. 

Operator Requirements 

Todd Thomas dba Drone Pies respectfully purposes that operator requirements should take into 

account the characteristics of the particular UAS. Certain UASs, such as the DJI Phantom 2 

Vision+, are characterized by a high degree of control and various built-in technical capabilities 

that limit the potential for operation outside of the operating conditions set forth above. 

Please see details in the attached O&M manuals. 

Additional automated safety functions and safety enhancing features of the sUAS's include the 

following: 

• Auto-pilot detection of lost GPS or of insufficient satellites initiates an immediate return 

to aircraft take-off location ("home"). 

• Low power on the aircraft triggers escalating alarms at GCS. 

• If the auto-pilot detects a lost-link to the GCS, landing procedure begins. 

Given these safety features, Todd Thomas dba Drone Pies proposes that operators of the sUAS 

shou71d not be required to hold a commercial pilot certification. Instead, operators should be 

required to: 

• Hold a private pilot license and have a current medical certification. 

• Have completed the manufacturer's training or a minimum of 10 hours training program 

for operation of the sUAS's. 

Todd Thomas dba Drone Pies notes that the FAA has found that safety factors permitted 

operation of sUASs by operators with these qualifications in the case of operations pursuant to 

public COAs when the mandatory operating conditions specified above were present. See 

Federal Aviation Administration, Notice N-8900.227, Unmanned Aircraft Systems (UAS) 

Operational Approval, at 20-21 (July 30, 2013). The FAA has the statutory authority to grant 

exemptions to the requirements for and privileges associated with the grant of airmen's 

certificates. 49 USC §44701 (f). 

* * * 

In summary, applicant seeks an exemption from the FARs set forth above in Appendix A to 

allow commercial operations of a sUAS's conducting precision aerial inspections or surveys and 

real estate photos. 

5 
Approval of the exemption allowing commercial operations of the sUAS for precision 

inspection, survfy work, and real estate photos will enhance safety by reducing risk. 

Conventional aerial inspection, survey operations, and real estate photos, using jet or pistonpowered aircraft present risks associated with vehicles that weigh in the neighborhood of 5,000 

to 7,000 lbs., or more, carry large quantities of fuel, passengers, and, in some cases, cargo. 

Such aircraft must fly to and from the survey location. Other conventional manned climbing or 

manned lifts risk safety hazards associated with falls, electrical hazards, fuel related hazards, 

and inhalation associated with the structures being inspected. In contrast, a sUAS weighing less 

than 15 lbs. and powered by batteries eliminates a portion of that risk given the reduced mass 

and lack of combustible fuel carried on board a manned aircraft and the lack of risks associated 

with manned lifts or manned climbing apparatus. The sUAS will carry no passengers or crew 

and, therefore; will not expose any individuals to the risks associated with manned aircraft 

flights, manned lifts or climbing hazards. 

Additionally, no national security issue is raised by the grant of the requested exemptions. 

Given the size, load carrying capacity, speed at which it operates, and the fact that it carries no 

explosives or other dangerous materials, the sUAS poses no threat to national security. 

The operation of the sUAS, weighing less than 15 lbs., for inspections, surveys, and real estate 

photos in accordance with the strict conditions outlined above, will provide an equivalent level 

of safety supporting the grant of the exemptions requested herein, including exempting Todd 

Thomas dba Drone Pies from the requirements of Part 21. 

The sUAS's satisfaction of the criteria set forth in Section 333 ofthe Reform Act-size, weight, 

speed, operating capabilities, lack of proximity to airports and populated areas, operation 

within visual line of sight, and national security-and its showing of an equivalent level of safety 

as it may relate to the requirement for FAA training, provide more than adequate justification 

for the grant of the requested exemptions allowing commercial operation of the sUAS in the 

commercial aerial inspection, survey, and real estate photo business. 

Enclosures: 

6 

~;;:l?J;~ Todd N. Thomas 

Owner 

Drone Pies 

Appendix A: Exemption Request and Equivalent Level of Safety Showings under 

Applicable Rules Subject to Exemption 

Appendix B: Operation and Maintenance Manuals: 

DJI Phantom 2 Vision+ O&M Manual 

Appendix C: Safety Checklists