Date: November 5th, 2015

Christopher Wiegand

Noble Lure, LLC

6815 Pemberton Drive

Dallas, TX 75230

214-695-3337

chris@noblelure.com

U.S. Department of Transportation, Docket Operations 

West Building Ground Floor, Room W12-140

1200 New Jersey Avenue, SE

Washington, DC 20590

Re: Exemption Request of NOBLE LURE, LLC. under Section 333 of the FAA Reform Act.

To Whom it May Concern:

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

Act") and 14 C.F.R. Part 11, Noble Lure, LLC hereby applies for an exemption from the Federal 

Aviation Regulations identified below to allow commercial operation of small unmanned aerial 

vehicles (i.e., "small unmanned aircraft" or "UAS") for the purpose of conducting: (1) controlled 

flights for closed-set filming for the motion picture, television, and internet production, and; (2) 

controlled flights for the Real Estate industry, and; (3) controlled flights for aerial data collection, 

and; (4) search and rescue operations, and (5) agriculture, wildlife industries and inspections.

Noble Lure LLC requests exemption from:

14 CFR 45.23(b); 14 CFR Part 21; 14 CFR 61.23(a) and (c), 61.101(e)(4) and (5), 61.113(a) & 

(b), 61.315(a); 91.7(a); 91.9(b)(2); 91.103(b); 91.109: 91.119; 91.121; 91.151(a)(b); 91.203(a) & 

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

Requests for exemption are similar to previously granted exemptions: Exemption Numbers: 

11062, 11109, 11112, 12886 and 11213.

UAS TYPE:

Noble Lure, LLC will be using the DJI Inspire 1 and DJI Phantom 2 with 3D gimbal and GoPro. 

Detailed specs are available and these two UAS’s are already approved by the FAA and meet 

all safety requirements. 

THE REASON I SEEK RELIEF:

Noble Lure, LLC seeks relief because we can operate a UAS with more control and public 

safety mindedness than alternative methods such as Airplanes, Helicopters and Hot Air 

Balloons. 
COA:

This is from the FAA website, which I want to make sure to get my COA when/if my 333 

Exemption is granted. “Under the new policy, the FAA will grant a Certificate of Waiver or 

Authorization (COA) for flights at or below 200 feet to any UAS operator with a Section 

333 exemption for aircraft that weigh less than 55 pounds, operate during daytime Visual 

Flight Rules (VFR) conditions, operate within visual line of sight (VLOS) of the pilots, and 

stay certain distances away from airports or heliports” 

PUBLIC GOOD:

I believe granting exemption would be in the public interest due to the zero carbon footprint left 

by the UAS compared to the alternatives such as small aircraft which impacts the environment 

due to its emissions and its fuel consumption. Our UAS’s are all battery powered and create 

zero emissions. An additional benefit to the public good is that gas, fuel or flammable liquids 

would NOT be flying overhead. In the unlikely event of a crash, there would be no fuel to ignite 

and explode. Also, the National Airspace System, which is already crowded, would benefit by 

allowing a small, professionally controlled UAS fly over a specific area, relieving the air traffic in 

the sky. I have law enforcement relationships and I will be available for search and rescue 

operations as well as offering services to other safety officials as needed. 

SAFETY: 

Granting the exemptions will NOT adversely affect safety and the exemption will provide a level 

of safety equal to the UAS rules, conditions and limitations currently in place. 

Noble Lure, LLC will perform a pre-flight check at every takeoff and will ground our flights if 

there is any safety risk. Perform regular maintenance and repairs and always will make sure the 

UAS is in condition for a safe flight. We will stay 5 miles away from any Airport and obey all 

rules regarding populated areas. We will say under 400 feet, and under the recommended 

speed of 87 knots (100 miles per hour) and utilize every safety feature such as GPS technology 

which supports auto land to a predetermined point or to the take off location due to an 

unforeseen loss of signal or communication. We will only fly the UAS in visual line of sight. UAS 

will not create a hazard to the NAS or the public or pose a threat to national security. We will 

follow every recommendation for a safe flight from the manufacturer. We will have a copy of the 

UAS flight manual, registration info and other required documents from the ground station from 

where the pilot will be operating the aircraft. The UAS is within the 55 lbs weight restriction. 

Noble Lure, LLC lands its UAS when battery levels reach 30% capacity. The DJI website puts it 

this way, “When in flight, your remaining battery power is shown live, letting you know how long 

you can continue to fly. Advanced algorithms calculate the distance of your aircraft and 

estimated time to return home, letting you know when it’s time to fly back.” Also, mapping 

software built into the device makes for a safer flying environment as the operator has full 

access to the location and coordinates of the UAS at all times. 

AIRCRAFT PERFORMANCE:

DJI makes some of the best UAS on the market and uses the latest technology to make flights 

safer buy implementing safety features. The GPS features cause the UAS to remain at a 

stationary point if no actions are made on the controller which gives time to safely adjust if there 

were a moment where operator needed to pause briefly. As DJI website puts it, “This technology 

allows the Inspire to hold its position, stop when the controls are released, and respond to your 
commands even when GPS is unavailable.” Another feature as stated from the DJI website, 

“Every part, every component of the Inspire 1 was engineered to be durable and lightweight. 

The body’s aerodynamic design cuts through the sky and further enhances your control over the 

aircraft. This ensures long flight times and a long operational life.” Other features include, Autotakeoff and landing, flight telemetry, dynamic home point and live map and radar. From the DJI 

website, “When GPS is available, the Home Point (the location you are standing) automatically 

refreshes, so your Inspire 1 always knows where you are even if you move around. When you 

tell it to come back, or in case of an emergency, it knows exactly where to go and land safely.”

OPPERATIONAL HISTORY:

Noble Lure, LLC has hundreds of hours flying UAS. Noble Lure, LLC is fully trained in the use of 

the UAS. We have lots of experience using the UAS safely in controlled settings making motion 

picture films and videos for non-profits and footage used to augment real estate videos. 

CONCLUSION: 

Noble Lure, LLC’s Petition for Exemption fulfills the criteria in Section 333 of the Reform Act of 

2012 including speed, weight, operations, airport distance and population areas, operation 

within visual line of sight and national security threats. Operating the UAS will benefit the public 

as a whole by improving safety and reducing risk by limiting human exposure to danger. Please 

consider granting the requested exemptions allowing Noble Lure, LLC to use small UASs.

Thank you for your consideration of our requested exemptions. 

Respectfully submitted,

Christopher Wiegand

CEO

Noble Lure LLC

For more information needed to grant Noble Lure LLC the requested exemptions please contact 

us at chris@noblelure.com or 214-695-3337