North Georgia Drones, LLC

1760 Loblolly Lane

Cumming, GA 30041

770-330-7382

stan.jessen@outlook.com

August 12, 2015

U. S. Department of Transportation

Docket Management System

1200 New Jersey Ave., SW

Washington, DC 20591

This letter is in response to a FAA letter dated August 3, 2015, requesting additional information 

that is needed to process my Section 333 request for an exemption entered into public docket 

(No: FAA-2015-1740).

The letter states that my submission does not comply with § 11.81 and request the following:

 The reasons why granting the exemption would not adversely affect safety, or how the 

exemption would provide a level of safety at least equal to that provided by the rule from 

which you seek the exemption.

 Any additional information, views or arguments available to support your request.

This document uses the following abbreviations for brevity:

NGD North Georgia Drones

DJI Refers (only) to the three sUAS devices listed in our exemption request

DGI Phantom 2 Vision Plus

DGI Phantom 3

DGI Inspire 1

The FAA has previously granted exemptions to each Title 14 CFR mentioned in the NGD request for 

exemption document. Rather than putting this detail in our original document we referenced five 

exemptions that had been previously granted by the FAA and were similar to our request. Our 

assumption was that these exemptions set a precedent and that need for relief and safety issues had 

been accepted by the FAA. We felt this would simplify the exemption process for NGD and the FAA. 

Since this is not the case, the information you requested follows...
The Reasons Why Granting The Exemption Would Not Adversely Affect Safety, Or How The 

Exemption Would Provide A Level Of Safety At Least Equal To That Provided By The Rule From 

Which You Seeks Exemption. 

1. §61.23(a) and (c) Medical certificates: Requirement and duration

§61.101(e)(4) and (5) Recreational pilot privileges and limitations

§61.113(a) and (b) Private pilot privileges and limitations: Pilot in command.

§61.315(a) What are the privileges and limits of my sport pilot certificate?

NGD request relief from the medical and pilot license requirements in these sections. We request 

that a sports pilot’s certificate and U.S. driver’s license be sufficient for sUAS pilots to work for 

compensation..

Allowing sports pilots to operate UAS aircraft for hire represents less risk than a sport pilot in a 

manned aircraft,

 All NDG flights will be supported by an observer who is capable of operating the UAS. If the PIC 

releases the remote control, the sUAS used by NGD will hover in place. This provides an 

opportunity for someone (the observer or other) to take control.

 Worse case is that the sUAS runs low on power and lands itself.

 In the unlikely event the sUAS experiences an uncontrolled crash, the size, weight and lack of 

flammable fuel make if extremely unlikely for the UAS to cause serious harm to damage.

 Because the sUAS takes off and lands at the operation site, there is no transit exposure to and 

from an airport

NGD submits that the equivalent level of safety established by these sections will be maintained 

because no PIC will be allowed to operate the NGD sUAS unless that PIC has demonstrated, by 

meeting minimum flight-hour and currency requirements, that the PIC is able to safely operate the 

sUAS in a manner consistent with the exemption, including evasive and emergency maneuvers and 

maintaining appropriate distances from people, vessels, vehicles and structures. 

Manned pilot experience does not correlate to the airmanship skills necessary for NGD ’s specific 

proposed flight operations. NGD will not allow any PIC to operate a sUAS unless that PIC has 

demonstrated, by meeting minimum flight-hour requirements of the sUAS they are operating and, 

training and currency requirements, that the PIC is able to safely operate it in a manner consistent 

with this exemption, including evasive and emergency maneuvers and maintaining appropriate 

distances from people, vessels, vehicles and structures. 

2. §91.7(a) - Civil aircraft airworthiness

No standards exist for airworthiness certificates for sUAS. The size, weight and lack of 

flammable fuel make it unlikely that sUAS accident would cause serious harm or damage.

The equivalent level of safety established by Section 91.7(a) will be maintained because prior 

to every flight, NGD will ensure that the sUAS is in an airworthy condition based upon DGI 

documents for the applicable sUAS. 
3. §91.119 - Minimum safe altitudes

This section established minimum safe altitudes for civil aircraft. Aircraft cannot fly below 500 feet 

over water or sparsely populated areas. Higher minimums are specified for over populated areas.

Relief is requested is necessary since aircraft in sUAS category are required by the FAA to must 

remain below 500 feet. Also many sUAS operations take place in close proximity to structures 

(such tower/bridge inspections). 

Equivalent safety is achieved from the size, weight and speed of the UAS. Also no flight is taken 

without permission from the property owner. Since the PIC is on the ground and accompanied by 

an observer, it is easy to see people and objects, and avoid them.

4. §91.121 - Altimeter settings

The NGD UAS do have a barometric altimeter. However, because UAV missions are below 500 

feet, the primary concern is AGL as measured from the GPS altitude at take-off. In this low 

altitude environment a higher degree of safety is provided by GPS AGL then barometric altitude.

5. §91.151(a)(1) - Fuel requirements for flight in VFR conditions

UAV have flight endurances in the 15-25 range, making it impossible to meet these requirements. 

However, grant of this exemption would ensure an equivalent level of safety established by 

§91.151. Because the sUAS is within line-of-sight, most if the time never more than a few minutes 

from its takeoff point. Also, the size of the sUAS allows it to land in places a manned aircraft could 

not consider. NGD requires missions to land with 20% power remaining.

6. §91.405(a) Maintenance required

§91.407(a)(1) Operation after maintenance, preventive maintenance...

§91.409(a)(1) and (2) Inspections

§91.417(a) and (b) Maintenance records

The maintenance and inspections of §91are not applicable to sUAS. FAA certified sUAS mechanics 

does not exist. The modular construction of sUAS means that entire components (engine, props, 

flight computer...) are easily replaced, rather than doing major repairs. Also sUAS are frequently 

reconfigured with different sensors and payloads that do not impact airworthiness.

To get an equivalent level of safety, NGD uses manufactures manuals and recommendations in 

concert with frequent inspections. In addition to pre-flight and post-flight inspections, our sUAS 

undergo a detailed inspected every 20 flight or 4 months, whichever comes first. The multi-rotor 

sUAS’s are mechanically very simple devices. The only moving parts are the motor/propellers. 

However, these devices are electronically very complex. This inspection involves removing all 

covers so that all connections and wires can be viewed.

All maintenance/inspections are logged. Work in critical systems must be signed off by quality. In 

addition, detailed inspections and any work on critical systems require a FTF (function test flight) 

buy a senior PIC. While not completed, NGD is developing a software application to help manage 

maintenance task and battery usage.
Any Additional Information, Views, Or Arguments Available To Support Your Request.

This Petition is made pursuant to the FAA Modernization and Reform Act of 2012 (FMRA) Section 333, 

which directs the Secretary of Transportation to determine if certain UAS may operate safely in the 

NAS. It is our option that sUAS operations can be very safe. The keys to safety are qualified PICs and 

maintenance. We are concerned about the recent bad publicity that sUAS has received. Virtually all 

this is due to undisciplined use of sUAS by hobbyist. I have yet to hear of an issued with a Section 333 

exempted organization. We completely agree with the need for UAS pilots to be familiar with the NAS.

Sincerely,

Stan Jessen