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UNITED STATES OF AMERICA 

DEPARTMENT OF TRANSPORTATION 

FEDERAL AVIATION ADMINISTRATION 

DOCKET MANAGEMENT SYSTEM 

1200 NEW JERSEY AVE., SE 

WASHINGTON, DC 20590

IN THE MATTER OF THE PETITION FOR EXEMPTION OF:

Drone Business Systems, LLC

FOR AN EXEMPTION SEEKING RELIEF FROM 

THE REQUIREMENTS OF THE FAA REFORM ACT AND 

PART 11 OF THE FEDERAL AVIATION REGULATIONS FROM 

TITLE 14 OF THE CODE OF FEDERAL REGULATIONS

SECTIONS C.F.R. §§ 61.113 (a) & (b); 91.7(a); 91.119 (c); 91.121; 91.151(a);

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

CONCERNING COMMERCIAL OPERATION OF UNMANNED AIRCRAFT SYSTEMS 

PURSUANT TO SECTION 333 OF THE FAA MODERNIZATION AND 

REFORM ACT OF 2012 (PUBLIC LAW 112-95)

Submitted on September 15, 2015

Drone Business Systems, LLC

222 Hickman Drive Ste. 101

Sanford, FL 32771

407-732-2488

www.DroneBusinessSystems.com

info@DroneBusinessSystems.com
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Table of Contents

GLOSSARY OF ABBREVIATIONS.........................................................................3

INTRODUCTION & INTERESTS OF THE PETITIONER.......................................4

Executive Summary.................................................................................................4

Expeditious Summary Grant Approval Request..................................................4

Description of Type, Make and Models of sUAV/UAS Requested .........................5

Commercial (Mission, Operation) Purpose .............................................................6

Regulations from which Specific Relief is requested: .........................................6

The name and address of the Petitioner .............................................................6

Background ..........................................................................................................7

Commitment to Safety .........................................................................................7

Expertise & Experience........................................................................................7

The Exemption Request..........................................................................................8

Operator Requirements ...........................................................................................9

Aircraft and Equivalent Level of Safety .................................................................11

Specific Uses Public Benefits ................................................................................11

Equivalent Level of Safety .................................................................................12

14 C.F.R. § 91.7(a): Civil aircraft airworthiness.................................................13

14 C.F.R. §91.119: Minimum safe altitudes ......................................................13

14 C.F.R. §91.121 Altimeter Settings ................................................................14

14 C.F.R. § 91.151(a): Fuel Requirements for Flight in VFR Conditions .........14

14 C.F.R. §91.405 (a); 91.407 (a) (1); 91.409(a) (2); 91.417(a) & (b): 

Maintenance Inspections ...................................................................................14

Federal Register Publication..............................................................................15

Petitioner seeks an exemption from the following rules ....................................15

Privacy and National Security............................................................................16

Summary ............................................................................................................16

APPENDIX A – FLIGHT OPERATIONS MANUAL...............................................18

APPENDIX B - TECHNICAL MANUALS AND SPECIFICATIONS ......................19

APPENDIX C - MAINTENANCE AND REPAIR LOG...........................................20

APPENDIX D – MOTION PICTURE AND TELEVISION FLIGHT OPERATIONS 

MANUAL ................................................................................................................21
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GLOSSARY OF ABBREVIATIONS

AGL Above Ground Level

AOI Area of Interest

ATC Air Traffic Control

ATO Air Traffic Organization

AV Aerial Vehicle

CFR Code of Federal Regulations

COA Certificate of Authorization

FAA Federal Aviation Administration

FAR Federal Aviation Regulation

GCS Ground Control Station

GPS Global Positioning System

LOL Loss of Link

NAS National Airspace System

NOTAM Notice to Airman

PIC Pilot in Command

Section 333 FAA Modernization and Reform Act of 2012 (FMRA) Sec 333

SO Safety Observer

SOP Standard Operating Procedures

sUAS Small Unmanned Aircraft System

sUAV Small Unmanned Aircraft Vehicle

UA Unmanned Aircraft

UAS Unmanned Aircraft System

UAV Unmanned Aircraft Vehicle

VFR Visual Flight Rules

VLOS Visual Line of Site

VMC Visual Meteorological Conditions

VTOL Vertical Take-Off and Landing
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INTRODUCTION & INTERESTS OF THE PETITIONER

Gentlemen:

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

“Reform Act”) and 14 C.F.R. Part 11, Drone Business Systems, LLC, (“DBS”) an 

Operator of Small Unmanned Aircraft Systems (“sUASs”) that is equipped to offer ondemand commercial UAS operations for a multitude of businesses and industries. DBS

desires to perform flights for the purposes listed below, and hereby applies for an 

exemption from specific Federal Aviation Regulations (“FARs”) to allow commercial 

operation of its sUAV’s/UAS, within and under the conditions stated herein or as may 

be established by the FAA in an exemption granted under either Section 333 of

Section 49 U.S.C. §44701(f)

Our requested exemption would permit the operation of a UAS under controlled 

conditions in NAS that is 1) limited; 2) predetermined; and 3) would heighten safety in

fields operations, which presently relies upon conventional aircraft or humans climbing 

on dangerous structures, traversing treacherous terrain, and working on hazardous

infrastructures. Approving this exemption would enhance public safety and help fulfill 

the Secretary of Transportation’s and the FAA’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.1

Executive Summary

Expeditious Summary Grant Approval Request

The petitioner requests the agency issue a summary grant process for this application. 

Petitioner has provided specific exemption numbers whereby the FAA has already 

granted a previous exemption similar or identical to each of our requests.

The petitioner requests to operate an unmanned aircraft system (UAS) for aerial data 

collection2to conduct aerial inspection, photography, filmmaking, cinematography, 

videography, precision agriculture, wildlife and forestry monitoring and mosquito and 

 

1

DBS relies upon the following exemptions where specific reference to an exemption is not provided: 

Exemptions 11062 thru 11067, 11080, and 11109 through 11112, 11114, 11213, 11062, 11857 and 12496.

2

Examples include imagery (photography, video, infrared, etc.), electronic measurement (precision surveying, 

RF analysis, etc.), chemical measurement (particulate measurement, etc.), or any other gathering of data by 

instruments aboard the UAS.
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insect control, aerial surveying, public entity support operations, training, special events, 

motion picture production, surface mining, and closed set filming.

We believe that 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), in these cases 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.

In addition the FAA has issued exemptions to other petitioners requesting exemptions for 

reasons similar to our request. Specifically:

 relief previously requested in Grant of Exemption Nos. 11062, 11109, 11112, 

and 11213 are similar in all material respects to our request;

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

and 11213 also apply to our situation; and

 A grant of exemption is in the public interest.

Description of Type, Make and Models of sUAV/UAS Requested:

The petitioner is seeking an exemption to commercially operate sUAV’s makes and 

models as follows:

DJI - Phantom 2; DJI - Phantom 3; DJI - Inspire 1; DJI – Spreading Wings S800; DJI –

Spreading Wings S900; DJI – Spreading Wings S1000; DJI – Matrix 100; Cinestar 8 

Octo; Altavian Nova F6500; Blade 350 QX3; 3DRobotics X8; 3DRobotics Iris; SenseFly 

eBee; and the Yuneec Q500 Typhon.

Each of these sUAV’s weighs 55 lbs. or less, with imaging payload and equipment.

Equipment operation manuals for each sUAV listed above are available through the 

manufacture and have been previously approved by the FAA for other petitioners that 

have been issued exemptions3.

 

3

Exemption number 12496 included all of the sUAV’s listed by this parishioner.
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Commercial (Mission, Operation) Purpose:

This exemption request would allow the petitioner to operate a small unmanned aerial 

vehicle (sUAV), unmanned aircraft system (UAS) to conduct bridge Inspections, flare 

stack inspection, utility-power generation system inspections and patrolling, aerial 

inspection, photography and videography of residential and commercial real estate, 

weddings, aerial inspection, photography and videography of utility infrastructure 

including but not limited to electrical power lines, wind turbines and cell towers, pipeline 

inspection and patrolling, filmmaking, cinematography, and videography, precision 

agriculture with on board sensors, wildlife and forestry monitoring and mosquito and 

insect control, aerial surveying, construction site inspection and monitoring, public entity 

support operations, Aerial imaging for safety, monitoring and comparing work efforts and 

completion percentages, and security of controlled environment of various sites, aerial 

video and live video feed to assist with search and rescue operations under the authority 

and support of local authority officials, aerial video and photography for public and 

private use including television, public events, and cinematography live feed and live 

newsgathering, training to persons individually or belonging to both private and public 

organizations to increase awareness and improve safety for current and future UAS 

operations within the NAS, special events: including high schools, colleges, professional 

sports, open air events and fairs, research, risk management and assessment, motion 

picture production, surface mining, closed set filming, and disaster or catastrophe events 

such as hurricanes, tornados, tsunamis, and aerial data collection activities.

Regulations from which Specific Relief is requested:

14 C.F.R. § 61.113 (a) & (b)

14 C.F.R. § 61.133(a)

14 C.F.R. § 91.7(a)

14 C.F. R.§ 91.119

14 C.F.R. § 91.121

14 C.F.R. § 91.151 (a)

14 C.F.R. § 91.405 (a)

14 C.F.R. § 407 (a) (1)

14 C.F.R. § 409 (a) (2)

14 C.F.R. § 417 (a) & (b)

The name and address of the Petitioner:

Drone Business Systems, LLC

Attn: Richard H. Simonton, Sr.

222 Hickman Dr. Ste. 101

Sanford, FL 32771

RichSimonton@DroneBusinessSystems.com
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Background

The Petitioner is under Bruce Rhea and Richard Simonton’s direction. Bruce Rhea is a 

highly accomplished, capable and experienced licensed pilot, cell tower owner, 

entrepreneur and sales professional with many years of experience in radio, cellphones, 

and electronics. Richard Simonton is license pilot and an experienced financial 

institution executive, compliance officer, and federal examiner.

Drone Business Systems, LLC is a local Sanford, Florida small business seeking relief 

to conduct aerial inspection, photography, filmmaking, cinematography, videography, 

precision agriculture, wildlife and forestry monitoring and mosquito and insect control, 

aerial surveying, public entity support operations, training4, special events, motion picture 

production, surface mining, closed set filming, and data collection using sUAS.

Commitment to Safety

As part of its commitment to safety and innovation, we are asking for this exemption in 

part, to reduce the risk of injury to its employees and contractors who participate in the 

proposed activities the petitioner requests, including but not limited to damage to 

agriculture, natural habitat, buildings and other structures within the United States.

Expertise & Experience

Drone Business Systems, LLC owners are experienced pilots and entrepreneurs and

qualified to perform the sUAV activities requested. They are fast becoming subject 

matter experts in the Sanford area for UAS of all types, models and make to help 

businesses choose the best UAS for their specific application and budget.

 

4 We recognize that the FAA is unable to authorize UAS operations for training until such time as the FAA

completes its assessment. However, the petitioner will train its own pilot in commands and visual observers 

in accordance with 14 CFR § 61.51, § 91.119 and the other conditions and limitations that the FAA sets forth

in the exemption once issued.
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The Exemption Request

Drone Business Systems (DBS) proposes the use of the sUAV’s will be for capture of 

high resolution imagery and video of residential or commercial applications and 

purposes to a level of quality that allows the Petitioner to use the imagery to identify, 

record, memorialize events and objects according to the purposes noted.

The imagery and video will be used to identify the condition of landscapes, agriculture, 

events, disasters and infrastructure to conduct bridge inspections, flare stack inspection, 

utility-power generation system inspections and patrolling, aerial inspection, photography 

and videography of residential and commercial real estate, weddings, aerial inspection, 

photography and videography of utility infrastructure including but not limited to electrical 

power lines, wind turbines and cell towers, pipeline inspection and patrolling, filmmaking, 

cinematography, and videography, precision agriculture with on board sensors, wildlife 

and forestry monitoring and mosquito and insect control, aerial surveying, construction 

site inspection and monitoring, public entity support operations, aerial imaging for safety, 

monitoring and comparing work efforts and completion percentages, and security of 

controlled environment of various sites, aerial video and live video feed to assist with 

search and rescue operations under the authority and support of local authority officials, 

aerial video and photography for public and private use including television, public 

events, and cinematography live feed and live newsgathering, training to persons 

individually or belonging to both private and public organizations to increase awareness 

and improve safety for current and future UAS operations within the NAS, special 

events: including high schools, colleges, professional sports, open air events and fairs 

research, risk management and assessment, motion picture production, surface mining, 

closed set filming, disaster and catastrophe events.

The UAS will be operated by DBS and or contracting operators on occasion to capture 

high-resolution imagery/video of large structures (wide and tall) such as warehouses, 

high rise buildings, bridges, and construction sites, as well as sky views of fire and 

explosion sites. Given the small size of the sUAV’s involved, no more than 55 lbs., the 

usually velocity of operation is between 5-15 mph and is restricted by the environment 

within which they operate. The Petitioner believes that it falls within the parameters of an 

equivalent level of safety in which Congress envisioned commercial operations of UASs 

as permitted by the FAA.

This exemption application is submitted to fulfill Congress’ express goal in passing 

Sections 333(a) through (c) of the Reform Act. This law directs the Secretary of 

Transportation to consider whether certain unmanned aircraft systems may operate 

safely in the national airspace system (NAS) before completion of the rulemaking 

required under 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 light of the following:
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 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 visual line of sight of the Operator.

The Reform Act § 333 (a). Lastly, 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.” Id. 

§333(c).

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: 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 44702-44716 of this title if the Administrator finds the exemption is in the 

public interest. 49 U.S.C. §44701(f). See also 49 USC §44711(a); 49 USC §44704; 14 

CFR §91.203(a)(1) This authority to grant exemptions reaches such issues as 

authorization of commercial operation of aircraft without an FAA issued pilot’s license.

DBS in filing this application is requesting that the FAA combine the grant of the Section 

333 exemption with a standard Certificate of Operation (COA) that will allow commercial 

operations of its DBS’ sUAV without the necessity of filing for a COA for each flight, 

unless such flight is to be conducted in an area not approved in the exemption. 

Compliance with the conditions agreed to herein and that may be imposed by the FAA, 

as set forth in prior Section 333 exemptions, provide the separation needed from other 

aircraft.

In addition, given that all operations will be conducted below 400 AGL feet and no closer 

than 5 nautical miles of the geographic center of an airport as denoted on a current FAA 

published aeronautical chart, unless a letter of agreement with that airport’s 

management is obtained, DBS requests that operations over congested or densely 

populated areas be allowed. The DJI Phantom 3, and other sUAV’s, do have GPS geofencing, it will operate at a very low altitude, within confined areas, at low speed and 

weighs no more than 55 lbs.. Such operations will only be under-taken with the approval 

of the land or homeowner(s) and will comply with the distance limitation requirements in 

effect at the time unless approval has been provided by the adjacent land owner(s).

Operator Requirements

Given the sUAV proposed by DBS, some flight operations should not require the PIC to 

hold a private pilot license. DBS believes that at a minimum 1) the operator, should have 

knowledge and experience that enables the safe operation of a small, remotely piloted 

sUAV, should understand airspace restrictions, aircraft separation requirements from 

other aircraft and from non-participants and property; 2) the sUAV has built-in technical 

capabilities that limit the potential for unsafe operation and 3) there are security 
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screening mechanisms that DBS will utilize to ensure that the operators are acting 

consistently with national security interests and safely within NAS.

Advanced sUAV’s have navigation and control systems including auto-pilot that allows it 

to execute very accurate pre-programed flights. Flights are pre-programmed with GPS 

waypoint to establish perimeters beyond which the aircraft will not operate. Flights 

under auto-pilot are not directed by positive manual input, but through preprogrammed 

flight parameters that are executed by the auto-pilot. In the case of unplanned events, 

the Operator inputs preprogrammed evasive maneuvers from the control unit, and the 

autopilot executes those maneuvers. Pre-programmed Operator interventions include: 

initiation of holding at present position; suspension of mission; fly back to launch point; 

abort mission and land immediately; and emergency power cut off and land (flight 

termination system). Additional automated safety functions and safety enhancing 

features of the Advanced sUAV’s may include the following:

1) Auto-pilot detection of lost GPS or of insufficient satellites initiates an immediate 

landing,

2) Low power on the aircraft triggers escalating alarms at GCS at 35% and 10% 

levels. Low power below 10% triggers an immediate landing,

3) If the auto-pilot detects a lost-link to the ground controller, the UAS will hold 

position at its current location for 5 seconds and if the signal is not restored, 

execute a return to home and land,

4) Redundant “kill switches” that enable completely shutting the aircraft down in 

flight in the event of a loss of control or un-commanded deviation from the flight 

path,

5) The aircraft, weighs less than 55 lbs., fully loaded,

6) The motors are driven by pulse width modulated signals, not analog signals,

7) The aircraft will operate for the Purposes at no more than 30 mph (while imaging) 

nor above 200 feet above the structure (imaging altitude) or a maximum of 400 

feet AGL.

See Federal Aviation Administration, Notice N-8900.227, Unmanned Aircraft Systems 

(UAS) Operational Approval, at 20-21 (July 30, 2013); As the FAA has determined in 

Exemptions 11062 thru 11067,11080 and 11110 (the “Exemptions”), in comparing the 

requirements for private pilot knowledge and the knowledge required for a commercial 

pilot, that knowledge associated with a private pilot license, and therefore private pilot 

ground school, was sufficient to allow private pilots to operate sUAV’s under those 

exemptions.

Based upon that analysis, DBS believes successful completion of FAA private pilot 

ground school is a suitable predicate to operating the sUAV under this exemption. DBS

proposes that the Operator accumulate required sUAV flight training hours through the 

operation of sUAV’s rather than flight hours in conventional aircraft. 
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Additionally, DBS asks that our exemption be issued without the requirement for a visual 

observer for all flights. This request is based on the fact that an equivalent level of safety 

is provided by the size, speed and control capabilities of the sUAV, in addition to the 

operational procedures that are applicable to all our flights. These factors limit the safety 

benefit that a visual observer may provide during many fight operations. Many times 

flight operations take place in areas where the risk to people and property is limited, 

thereby, mitigating the benefit or need for a visual observer to be present. 

Also, the NPRM does not require the use of a visual observer. Given the clear direction 

in Section 333 of the Reform Act; the authority contained 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, reduction in environmental 

impacts, including reduced emissions associated with allowing battery powered sUAV’s 

for these functions instead of turbine or gas power aircraft/rotorcraft and operations with 

pilots having at least a private pilot license, the grant of the requested exemptions is in 

the public interest.

Aircraft and Equivalent Level of Safety

The Petitioner suggests that the exemption requested apply to civil aircraft that have the 

characteristics and that operate with the limitations listed within or petition. 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 operations conducted with conventional aircraft or with 

humans climbing up and around structures. Such conditions as those found in previously 

issued Exemptions 11136, 11138, 11172, 11174 and 11177, 11062, 11109, 11112, 

11213 and 11857.

Specific Uses Public Benefits

Drone Business Systems, LLC proposes use of its sUAV provided equivalent or 

augmented levels of safety for each of the uses proposed herein:

The present systems of photography and videography and mapping of inspecting the 

roofs, agriculture land, buildings and large structures site surveys, wild life monitoring,

mosquito and insect control are now conducted by either humans wading through 

swamps, climbing on the roofs and structures that are steep, tall, slippery, weakened or 

otherwise hazardous or by the use of conventional aircraft.

The current procedures can result in significant injuries to the people who must climb on 

the roofs or require the use of aircraft that are orders of magnitude greater in size than 
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the sUAV. Either method, manual inspection or large conventional aircraft, results in 

increased risk of injury due to personnel falling off roofs or ladders, carrying heavy 

ladders and dealing with confined and dangerous spaces, or increased risk from low 

altitude flyovers with helicopters or fixed wing aircraft inspecting buildings after damage 

from storms or other disasters, such as earthquakes or fires. Such flights are, of course, 

significantly more expensive than those undertaken with a sUAV.

The present system exposes those not only in the immediate area of inspection, but 

those who are along the path of flight associated with the arrival and departure of the 

conventional aircraft at the inspection site because the aircraft must be flown to and from 

the site. By contrast, the sUAV is carried to the site and transits no other property. 

Conventional aircraft carry flammable fuels that are not carried by the UAS and emit 

pollutants associated with internal combustion engines. The sUAV’s proposed herein are 

battery powered and have no emissions.

Equivalent Level of Safety

14 C.F.R. § 61.113(a) & (b);: Private Pilot Privileges and Limitations; Pilot in 

Command;

Section 61.113(a) & (b) limit private pilots to non-commercial operations. Unlike a 

conventional aircraft that carries a pilot, passengers, and cargo, the DBS sUAV is 

remotely controlled with no passengers or property of others on board. Section 61.133(a) 

requires an individual with a commercial pilot’s license to be pilot in command of an 

aircraft for compensation or hire.

Instead, it would seem more appropriate for sSUV Operators to have successfully 

completed the FAA private pilot ground instruction and passed the FAA Private Pilot 

written examination or FAA-recognized equivalents.

DBS notes that the FAA has found that safety factors permitted operation of UASs by 

Operators with these qualifications in the case of operations pursuant to public COAs 

where the mandatory operating conditions specified above were present. See, Federal 

Aviation Administration, Notice N8900.227, Unmanned Aircraft Systems (UAS) 

Operational Approval, at 20-21 (July 30, 2013). Likewise, DBS notes that the NPRM 

does not require that the Operator hold a private pilot license issued by the FAA.

Given these conditions and restrictions, an equivalent level of safety will be provided by 

allowing operation of the DBS’ sUAV without a private pilot’s certificate or a commercial 

pilot’s certificate, but having passed the FAA Private Pilot written examination.

The level of risk associated with the operation of the DBS’ sUAV (given its size, speed, 

operational capabilities, and lack of flammable fuel) are low compared to the level of risk 
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associated with private pilot operations or commercial operations contemplated by Part 

61 with conventional aircraft. Because of this, operations of UAS by operators not 

holding private of commercial pilots licenses should provide a level of safety required

under 14 C.F.R. § 61.113(a) & (b) and does not rise to the level of skill requiring of a 

commercial pilot to operate a sUAV aircraft under § 61.133(a).

14 C.F.R. § 91.7(a): Civil aircraft airworthiness.

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

airworthy condition. Should the exemption be granted allowing commercial operation of 

the UAS without an airworthiness certificate, no standard will exist for airworthiness of 

the UA. Given the size of the aircraft and the requirements that the Operator has agreed 

to as it relates to airworthiness, as contained in the manual, an equivalent level of safety 

will be achieved by insuring compliance with the manuals prior to each flight. The FAA 

has granted exemptions to conduct similar operations in Exemptions 11062 through 

11067, 11080 and 11110.

14 C.F.R. §91.119: Minimum safe altitudes

Section 91.119 establishes safe altitudes for operation of civil aircraft. Section 91.119 (d) 

allows helicopters to be operated at less than the minimums prescribed, provided the 

person operating the helicopter complies with any route or altitudes prescribed for 

helicopters by the FAA. As this exemption is for a sUAS that is a helicopter and the

exemption requests authority to operate at altitudes up to 400 AGL, an exemption may 

be needed to allow such operations.

The equivalent level of safety will be achieved given the size, weight, and speed of the 

UAS as well as the location where it is operated. No flight will be taken without the 

permission of the property owner, facility owner, and/or local officials. Because of the 

advance notice to the property owner and participants, all affected individuals will be 

aware of the planned flight operations as set forth in the Manuals. Compared to flight 

operations with aircraft or rotorcraft weighing far more than the maximum 55 lbs. and the 

lack of flammable fuel, any risk associated with these operations is far less than those 

presently presented by conventional aircraft operating at or below 500 AGL in the aerial 

photography industry. In addition, the low-altitude operations of the sUAS will ensure 

separation between these small-UAS operations and the operations of conventional 

aircraft that must comply with Section 91.119. The FAA has granted exemptions to 

conduct similar operations in Exemptions 11062 through 11067, 11080, 11110 and

12496
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14 C.F.R. §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 DBS’ sUAV, in manual 

or emergency mode, will not have a barometric altimeter display, but instead a GPS 

altitude display, an exemption will be needed. The Operator, pursuant to the procedures 

set forth in the Manuals as indicated before flight, will achieve an equivalent level of 

safety. The FAA has granted exemptions to conduct similar operations in Exemptions 

11062 through 11067, 11080, 11110, 12496

14 C.F.R. § 91.151(a): Fuel Requirements for Flight in VFR Conditions

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.”

Petitioner believes that an exemption from 14 CFR §91.151(a) falls within the scope of 

prior exemptions. See Exemption 10673 (allowing Lockheed Martin Corporation to 

operate without compliance with FAR 91.151 (a)). 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 UAS.

Petitioner believes that an equivalent level of safety can be achieved by limiting flights to 

30 minutes or 20-25% of remaining 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, 10808 and Exemptions 

11062, through11067, 11080 and 11110.

14 C.F.R. §91.405 (a); 91.407 (a) (1); 91.409(a) (2); 91.417(a) & (b): 

Maintenance Inspections

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

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

accomplished by the Operator or manufacturer pursuant to the flight manual and 

operating handbook as referenced in the Manuals attached as confidential Exhibits 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 defined areas for limited periods 

of time. If mechanical issues arise, the UAS can land immediately and will be operating 

from no higher than 400 feet AGL. As provided in the Aircraft Flight Operations Manual 

the Operator will ensure that the UAS is in working order prior to initiating flight, perform 

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

Operator and manufacturer are most familiar with the aircraft and best suited to maintain 

the aircraft in an airworthy condition to provide the equivalent level of safety. The FAA 

has granted exemptions for similar operations in Exemptions 11062 through 11067, 

11080 and 11110.

Federal Register Publication

Pursuant to 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:

Petitioner seeks an exemption from the following rules:

14 C.F.R. §§ 61.113(a) & (b); 91.7(a); 91.119; 91.121; 91.151(a); 91.405(a);

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

unmanned vehicle (55 lbs. or less) for the following purposes: to conduct bridge 

inspections, flare stack inspection, utility-power generation system inspections and 

patrolling, aerial inspection and photography of residential and commercial utility 

infrastructure including but not limited to electrical power lines, wind turbines and cell 

towers, pipeline inspection and patrolling, filmmaking, cinematography, and videography, 

precision agriculture with on board sensors, wildlife and forestry monitoring and 

mosquito and insect control, aerial surveying, construction site inspection and 

monitoring, public entity support operations, aerial video and live video feed to assist 

with search and rescue operations under the authority and support of local authority 

officials, aerial video and photography for public and private use including television, 

public events, and cinematography live feed and live newsgathering, training to persons 

individually or belonging to both private and public organizations to increase awareness 

and improve safety for current and future UAS operations within the NAS, special 

events: including high schools. Colleges, professional sports, open air events and fairs, 

research, risk management and assessment, motion picture production, surface mining, 

closed set filming, disaster and catastrophe events.
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Privacy and National Security

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

prior consent and knowledge. Inspection will be of inanimate objects in areas where the 

owners will have consented to the inspections or otherwise have agreed to allow the UAS 

and the Operator to be in the area where operations will take place.The size of the UAS, 

its speed and restricted area of operation do not raise national security issues.

Summary

Approval of exemptions allowing commercial operations of sUAV’s for petitioner to 

operate an unmanned aircraft system (UAS) to conduct bridge Inspections, flare stack 

inspection, utility-power generation system inspections and patrolling, aerial inspection 

and photography of residential and commercial utility infrastructure including but not 

limited to electrical power lines, wind turbines and cell towers, pipeline inspection and 

patrolling, filmmaking, cinematography, and videography, precision agriculture with on 

board sensors, wildlife and forestry monitoring and mosquito and insect control, aerial 

surveying, construction site inspection and monitoring, public entity support operations, 

aerial video and live video feed to assist with search and rescue operations under the 

authority and support of local authority officials, aerial video and photography for public 

and private use including television, public events, and cinematography live feed and live 

newsgathering, training to persons individually or belonging to both private and public 

organizations to increase awareness and improve safety for current and future UAS 

operations within the NAS, special events: including high schools. colleges, professional 

sports, open air events and fairs, research, risk management and assessment, motion 

picture production, surface mining, closed set filming, disaster and catastrophe events, 

will enhance safety by reducing risk.

Conventional operations, using jet or piston powered aircraft, ladders or placing people 

in swamps, on roofs or tall, hazardous or weakened structures, exposes them to higher 

risks than those created by use of a sUAV’s. The sUAV is carried to the target area and 

not flown. The sUAV 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, weighing less than 55 lbs., conducted under the strict 

conditions outlined above, will provide an equivalent level of safety supporting the grant of 

the exemptions requested herein. These lightweight aircraft operate at slow speeds, close 

to the ground, and in areas that are under the control of the customer for the operations 

and, as a result, are far safer than conventional operations conducted with turbine 

helicopters operating in close proximity to the ground and people or the use of individuals 

to climb the structures to conduct the 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 
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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 

Petitioner’s UAS for the Purposes outlined herein and are consistent with exemptions 

already granted, including Exemptions number 11171 through 11174, 11176, 11177, 

11062, 11109, 11112, 11213, 11857 and 12496.

Sincerely,

Richard H. Simonton, Sr. President

Drone Business Systems, LLC

222 Hickman Dr. Suite 101

Sanford, FL 32771
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APPENDIX A – FLIGHT OPERATIONS MANUAL

Petitioner submits the Appendix A Flight Operations Manuals marked 

“CONFIDENTIAL,” as they contain proprietary confidential business information 

that is not released to the public and is protected under the Freedom of Information 

Act 5 USC §552 et. seq. 5 Reform Act Section 333 (b).

Flight Operations Manual submitted as a separate document.
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APPENDIX B - TECHNICAL MANUALS AND SPECIFICATIONS

Petitioner submits the Appendix B Technical Manuals & Specifications marked 

“CONFIDENTIAL,” as they contain proprietary confidential business information that is not 

released to the public and is protected under the Freedom of Information Act 5 USC §552 

et. seq. 5 Reform Act Section 333 (b).

Manuals and Specifications submitted as a separate document.
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APPENDIX C - MAINTENANCE AND REPAIR LOG

Petitioner submits this Appendix C Maintenance and Repair Log marked “CONFIDENTIAL,” 

as they contain proprietary confidential business information that is not released to the 

public and is protected under the Freedom of Information Act 5 USC §552 et. seq. 5 Reform 

Act Section 333 (b).

Logs submitted as a separate document.
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APPENDIX D – MOTION PICTURE AND TELEVISION FLIGHT OPERATIONS 

MANUAL

Petitioner submits the Appendix D Motion Picture and Television Flight Operations Manual

marked “CONFIDENTIAL,” as they contain proprietary confidential business information

that is not released to the public and is protected under the Freedom of Information Act 5 

USC §552 et. seq. 5 Reform Act Section 333 (b).

Logs submitted as a separate document.