Dronisphere LLC 

6 Charter Ridge Drive 

Sandy Hook, CT 06482 

Ph. 561-529-6223

Kurt Thompson C.O.O. Rotorwave@gmail.com

 

U.S. Department of Transportation 

Docket Management System 

1200 New Jersey Ave. SE 

Washington, DC 20590 

Re: Exemption Request Section 333 of the FAA Reform Act. 

Dear Sir or Madam: 

Pursuant of Section 333 of the FAA Modernization and Reform Act of 2012 (the “Reform Act”) and 14 

CFR part 11, Dronisphere LLC, operator of an Unmanned Aircraft System (UAS), herby applies for an 

exemption from the listed Federal Aviation Regulations to allow commercial operation of its UAS, 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. 

Commercial operation of an UAS, as described herein, which are equipped with camera(s) and 

sensors, would operate in the following manner: 

• Aerial photography and/or video for public and/or private use including real estate, 

architecture, land surveying, engineering, and other professional activities. 

• Aerial video and/or photography for public and/or private use including television, public 

events, cinematography, and news gathering. 

• Aerial inspection/photography or providing live feed to assist with search and rescue 

operations in case of an emergency or natural disaster only when local authorities has 

requested it. 

The requested exemptions would permit the operation of a UAS under controlled conditions in the 

national airspace system that would be limited, controlled, predetermined, and will provide safety 

enhancements to operation. Approval of this exemption will thereby enhance safety and fulfill the 

Secretary of Transportations (the FAA Administrators) responsibilities to “... establish requirements 

for the safe operation of such aircraft systems in the national airspace system” Section 333(c) of the 

Reform Act. 

Regulations from which the exemption is requested: 

14 CFR Part 21 Subpart H 

14 CFR Part 45.23(b) 

14 CFR Part 61.113(a) & (b) 
14 CFR Part 91.7(a) 

14 CFR Part 91.9(b) (2) 

14 CFR Part 91.103 

14 CFR Part 91.109 

14 CFR Part 91.119(c) 

14 CFR Part 91.121 

14 CFR Part 91.151(a) 

14 CFR Part 91.203(a) & (b) 

14 CFR Part 91.405(a) 

14 CFR Part 91.407(a) (1) 

14 CFR Part 91.409(a) (2) 

14 CFR Part 91.417(a) & (b) 

FAA Policy 8900.277 Paragraph 16 (cXa) and Paragraph 16 (eX1) 

Dronisphere, LLC will operate the DJI Inspire 1, Model T600, with a total weight of 2935g or 6.47lbs. 

The dimensions are 438mm x 451mm x 301mm or 17.24in x 71.75in x 11.85in. Under still air the 

maximum speed is no more than 22m/s or 49mph with a cruising speed of 11m/s or 25mph. The DJI 

Inspire 1 has the ability to hover and move along a vertical and horizontal plane simultaneously. 

The DJI Inspire 1 has 4 motors, Motor Model DJI 3510, powered by a 6-cell 4500mAh or 5700mAh 

Lithium Polymer battery. There are four propellers, Propeller Model DJI 1345, in use. The DJI Inspire 

1 will be controlled with one C1 remote controller with an operating frequency of 2.400GHz2.483GHz. The live video feed will have an operating frequency of 5.728GHZ-5.850GHz. The 

applicant will operate the UAS in line of sight within a predetermined area owned and/or operated 

by the property representative. 

AIRCRAFT AND EQUIVALENT LEVEL OF SAFETY 

The operation limitations propose for an equivalent or higher level of safety because operations will 

further enhance the safety of the person and/or property using conventional aircraft. 

These limitations and conditions to which the applicant agrees to adhere to when conducting 

commercial operations under the FAA issued exemptions as set forth in the Flight Operations 

Manual (FOM) include: 

• The UAS weight is less than 55lbs. 

• The UAS will have a maximum operating speed of no more than 50mph. 

• Flights will be operated within line of sight of the UAS pilot and/or visual observer (VO). 

• Maximum flight time for each operational flight will be 25 minutes. Flights will be 

terminated at 25% battery reserve or 25 minutes of flight time, whichever comes first. 

• Flights will be operated at an altitude of no more than 400 feet Above Ground Level (AGL). 

• A preflight meeting will be held regarding the planned UAS operations prior to each flight. 

For each commercial operation a minimum crew will consist of the UAS Pilot (PIC), Visual 
Observer (VO) and may include a Camera Operator. All members present will sign a 

document verifying attendance of pre and post operation meeting. 

• All flights will occur under Visual Flight Rules Meteorological Conditions (VMC) only. 

• The flights will not occur any closer than a 5 mile radius of the geographic center/Airport 

Reference Point (ARP) of a tower controlled or uncontrolled airport. 

• If operations will be within 5 mile radius of geographic center/ Airport Reference Point 

(ARP) of a tower controlled or uncontrolled airport, the airfield operator and airfield traffic 

control tower (when applicable) will be contacted no later than 24 hours prior to flight 

operations, advising them of the estimated flight time, flight duration, elevation of flight 

and other relevant information. 

• All required permissions and permits will be obtained from appropriate state, county, or city 

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

agencies no later than 24 hours prior to operations. 

• Written and/or electronic permission from the relevant property owners will be obtained 

prior to operations. Consenting persons will be allowed within 100 feet of the flight 

operation, and may be reduced to a radius of 30 feet based upon equivalent level of safety 

determination, as required under the FOM. 

• The UAS pilot will be trained in advance for the safe operation of the UAS to be operated. 

This will include operation of the UAS both in normal and emergency modes of operation 

and will include familiarization with the operation manual published by the UAS 

manufacturer. Training will also include types of maneuvers to be performed and the safe 

operation in relation to persons, property, and applicable airspace. 

• The UAS Pilot and VO will be able to communicate by voice or radio at all times. 

• If the UAS loses GPS signal or communication with the remote controller, the UAS has the 

capability to return to a predetermined location autonomously. 

• The UAS has the capability to abort a flight in case of emergencies. 

14 CFR Part 21, Subpart H: Airworthiness Certificates 14 CFR Part 91.203(a) (1) 

Subpart H, entitled Airworthiness Certificates, establishes the procedural requirements for 

the issuance of airworthiness certificates as required by 14 CFR Part 91.203(a) (1). Given the 

size and limited operating area associated with the UAS to be utilized by Dronisphere, LLC, 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 UAS to be operated has a total weight of 6.47lbs fully loaded and does not carry a pilot 

or passengers. The UAS does not carry explosive materials or flammable liquid fuels and is 

powered exclusively by a 4500mAh or 5700mAh Lithium Polymer battery. Under this 

exemption, appropriate governmental and local public safety agencies will have 24 hours 

advanced notice of all operations and will be tightly monitored thereby providing a greater 

degree of safety to the public. Under the conditions proposed, the UAS will be safer than a 

conventional aircraft operating with an airworthiness certificate without the restrictions and 

conditions proposed. Also, the UAS demonstrates no credible threat to national security due 
to its size, operating speed, flight restrictions, lack of exploding materials, lack of flammable 

liquids and inability to carry a substantial external load. 

14 CFR Part 45.23(b) 

The regulation requires: When marks include only the roman capital letter “N” and the 

registration number is displayed on limited, restricted or light-sport category aircraft or 

experimental or provisional certificate aircraft, the operator must also display on the aircraft 

near each entrance of the cabin, cockpit, or pilot station, in letters not less than 2 inches nor 

more than 6 inches in height the words “limited”, ”restricted”, ”light-sport”, ”experimental” 

or “provisional” as applicable. 

Even though the UAS will have no airworthiness certificate, an exemption may be needed as 

the UAS will have no entrance to the cabin, cockpit or pilot station on which the word 

“Experimental” can be placed. Given the size of the UAS, two inch lettering will be 

impossible. The word “experimental” will be placed on the fuselage in compliance with Part 

45.29(f). 

The equivalent level of safety will be provided by having the UAS marked on its fuselage as 

required by Part 45.29(f) where the pilot, observer and others working with the UAS will see 

the identification of the UAS as “experimental”. 

14 CFR Part 61.113(a) (b): Private and Commercial Pilot Privilege and Limitations 

Currently, there are no applicable areas identified for UAS in either the private or 

commercial sector, therefore an exemption is required to conduct commercial operations. 

Under Part 61.113(a) (b) private pilots are limited to non-commercial operations; however 

an equivalent level of safety can be achieved by current regulations because the DJI Inspire 

1 UAS does not carry any pilot or passengers. Furthermore, although a pilot license is 

helpful, it will not ensure remote control piloting skills. The risks of operating a UAS are far 

less than the risk inherent in the commercial activities outlined in 14 CFR Part 61, thus an 

exemption is requested from Part 61.113 Private Pilot Privileges and Limitations. 

In regards to the UAS operational training, the applicant has flown numerous practice flights 

as a hobbyist under different temperatures and climate conditions. The applicant has also 

gain significant experience with the UAS’ performance under various emergency landing 

situations. Presently the applicant is familiarizing himself with the Pilot’s Handbook of 

Aeronautical Knowledge, FAA-H-8083-25A-Single PDF and is eager to participate in any 

future UAS airman certification courses that may be offered. 

The applicant sets forth a request for a 120 day temporary airman certificate in accordance 

with Part 63.13 to allow time to obtain a private pilot certificate or to allow the FAA time to 

establish minimum UAS airman certification status. 

14 CFR Part 91.7(a): Civil Aircraft Airworthiness 

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, through maintenance and use of safety check 

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

14 CFR Part 91.103: Preflight Action 

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

ensure the safety of the flight. As FAA approved rotorcraft flight manuals will not be 

provided for the aircraft, an exemption will be needed. The operating pilot will take all 

actions as stated in the FOM in Section 4 under Normal procedures including but not limited 

to reviewing the weather, flight battery requirements, landing and takeoff distances, and 

aircraft performance data before initiation of flight. 

14 CFR Part 91.109: Flight Instruction 

This regulation provides that no person may operate a civil aircraft (except a manned free 

balloon) that is being used for flight instruction unless the aircraft has fully functioning dual 

controls. UAS and remotely controlled 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 FAA has approved 

exemptions for flight training without fully functional dual controls for a number of aircrafts 

and for flight instruction in experimental aircraft. The equivalent level of safety will be 

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

the size and speed of the aircraft. 

14 CFR Part 91.119(c) Minimum Safe Altitudes 

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

allows helicopters to be operated at less 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 helicopter and the exemption request authority to 

operate at altitudes up to 400 feet AGL or not more than 200 feet above an elevated 

platform from which filming is planned, an exemption may be needed to allow such 

operations. As set forth herein, the UAS will never operate higher than 400 feet AGL with 

the exception that in circumstances where the UAS is used to survey or photograph a 

structure whose height exceeds 400 feet AGL, the UAS will not be operated more than 200 

feet above the highest point on the structure. It will however, be operated in a restricted 

area with a secured perimeter, where buildings and people will not be exposed to 

operations without their pre-obtained consent. 

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

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

property owner or local officials. Because of the advance notice to the property owner and 

participants in the filming/photography activity, all affected individuals will be aware of 

planned flight operations. Compared to flight operations with aircraft or rotorcraft 

weighting far more than the maximum 55lbs. proposed herein and the lack of flammable 

fuel, any risk associated with these operations is far less than those presently presented 
with conventional aircraft operating at or below 500 feet AGL. In addition, the low-altitude 

operations of the UAS will ensure separation between these UAS operations and the 

operations of a conventional aircraft that must comply with Section 91.119. 

14 CFR Part 91.121 Altimeter Settings: 

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

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

altimeter setting available before departure.” As the 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 and confirming the altitude of the launch site shown on the GPS 

altitude indicator before flight. 

14 CFR Part 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.” The battery power of the UAS provides approximately 25 minutes of powered 

flight. To meet the 30 minutes reserve requirement, UAS flights would be limited to 

approximately 10 minutes in length. Given the limitations of the UAS’ 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 than an exemption from 14 CFR 91.151(a) falls within the scope of prior 

exemptions. Operating the 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 types of risks that section 91.151(a) was 

intended to alleviate, given the size and speed of a small UAS. Additionally, limiting UAS 

flights to 10 minutes would greatly reduce the utility for which the exemption will be 

granted. Applicant believes than an equivalent level of safety can be achieved by limiting 

flight to 30 minutes or 25% battery power, whichever comes first. This restriction would be 

more than adequate to return the UAS to its landing zone from anywhere in its limited 

operating area. 

14 CFR Part 91.203(a) (b): Carrying Civil Aircraft Certification and Registration. 

The regulation provides in part: 

(a)Except as provided in Section 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 Section 91.715, 

is displayed at the cabin or cockpit entrance so that it is legible to passengers and crew. 
The UAS fully loaded weights no more than 55lbs and it is operated without an onboard 

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

documents or to display them on the UAS. 

An equivalent level of safety will be achieved by keeping the documents at the ground 

control point where the ground crew will have immediate access to them, to the extent 

they are applicable to the UAS. 

14 CFR Part 91.405(a); 407(a) (1); 409(a) (2); 417(a) & (b): Maintenance Inspections 

These regulations require than an aircraft operator or owner “shall have the 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 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 part43 apply only to aircraft with an airworthiness certificate, 

these sections will not apply to the applicant. Maintenance will be accomplished be 

accomplished by the operator pursuant to the flight manual and operating handbook. An 

equivalent level of safety will be achieved because the UAS is very limited in size and will 

carry a small payload and operate only in restricted areas for a limited period of time. If 

mechanical issues arise, the UAS can land immediately and will be operating from no higher 

than 400 feet AGL. 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 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 UAS manufacturer’s user manual. The operator will 

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

maintenance as needed. 

8900.227 Paragraph 16(cXa): PIC Medical and Paragraph 16(eX1) Observer Medical 

These regulations require that both the PIC and the VO have a valid FAA second-class 

medical certificate issued under part67 in order to perform as a PIC or VO. requiring the 

crew to meet the same medical requirements as a commercial pilot carrying passengers in a 

large aircraft is an unnecessary burden. Given that the risk of both the PIC and VO 

becoming incapacitated at the same time and suddenly is very low, the applicant proposes 

that the minimum medical requirements be vision corrected to 20/20 and a valid state 

issued driver’s license. An equivalent level of safety will be achieved because the UAS 

operates at low altitude and can brought in for landing in a very short period of time if 

incapacitation was suspected. Furthermore, DJI Inspire 1 is equipped with an automatic 

return home feature that would provide a final level of safety. 
My self and the Dronisphere team would like to thank you for your time and consideration 

of this application. We look forward to future collaboration with the FAA in the 

development of UAV regulations and the benefits that these platforms will provide in the 

future.

V/r

Kurt Thompson

Chief Operating Officer

Dronisphere LLC

(561) 529-6223