drone-logic, LLC.

Bradley S Haubrich

48 Cypress Court

Trophy Club, Texas 76262-5571

817-567-3613 facsimile

817-791-6103 mobile

brad@drone-logic.com

U.S. Department of Transportation, Docket Operations	 	 	 July 31, 2015

West Building Ground Floor, Room w12-140

1200 New Jersey Avenue, SE., Washington, DC 20590

RE: Exemption Request under Section 333 of the Federal Aviation Administration Modernization 

and Reform Act of 2012, IAW 14 CFR 11.81

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; drone-logic, LLC (Operator) seeks an exemption from Federal Aviation 

Regulations (FARs) to allow commercial operations of their UAS (Unmanned Aerial Systems) for 

the purpose of training their and other UAS operators, data collection, conducting aerial 

photography and videography, inspections and survey for various industries.

drone-logic, LLC is a Texas based Limited Liability Company, comprised of managing members 

with Airline Transport Pilot, Certified Flight Instructor, Advanced Ground Instructor certificates. 

Members possess over 50 years of combined aviation experience to include military, civilian, 

domestic and International aviation operations under 14 CFR Parts 91, 135 and 121. 

Additionally, managing members possess experience under 14 CFR Part 142 training as TCE 

(Training Center Evaluators) SFE (Synthetic Flight Examiners) certified with the FAA, CAA, 

EASA, DCAG, JAA and other foreign aviation regulatory agencies. 

The statements within this document denoted in blue underlined bold text are drafted from 

the guidelines for submitting a petition for exemption. See http://aes.faa.gov/Petition/home.html.

* Petition for Exemption 14 CFR § 11.81

- Regarding the Operations Proposed by the Operator

1. The requested exemption would support an application for a Commercial Certificate of 

Authorization (COA) to use UAS as described below, so long as operations are 

conducted in accordance with (IAW) conditions outlined herein or as may be established 

by the FAA as required by 14 CFR Part 11 under this Section 333 exemption. 

2. The Operator’s mission is to provide UAS training to all operators; civil, public and 

private, which may utilize UAS equipment thus promoting the safe, efficient and legal 

means of operation within the National Airspace System (NAS). 

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3. The Operator’s mission is to provide commercial aerial inspection services, data 

acquisition, data collection, emergency management services, aerial surveillance and 

mapping (as authorized by directive), aerial photography and videography. 

4. The Operator owned data, information, photography or video obtained for civil, public or 

private use may include but not necessarily be limited to such industries as real-estate, 

construction, landscaping, private or country clubs, golf courses, land surveying, 

livestock surveying, ranching, farming, agriculture, insurance, petroleum, power 

production, utility, engineering and various other industries.

5. The Operator proposes to conduct aerial photography and videography for civil, public or 

private use including television, radio broadcast, public sporting events, cinematography 

and news gathering in accordance with an approved MPTOM (Motion Picture and 

Television Operations Manual).

6. Operator proposes to conduct inspection, photography and or video of residential and 

commercial structures under contract with the owners of or local governmental authority 

which may include but not necessarily limited to homes, businesses, buildings, 

structures, power and data delivery infrastructure, roads, bridges, towers, or wind 

turbines.

7. Operator proposes to provide live video feeds and/or photography to assist with SAR 

(search and rescue) operations in cases of emergency or natural disaster and/or as 

directed by law enforcement or governmental authorities.

8. Operator proposes the use of a trained VO (Visual Observer) when VLOS (Visual Line 

Of Sight) may not be maintained solely by the PIC with the UAV. The VO shall be 

trained in such operations as depicted below, See section, Regarding the Visual 

Observer (VO).

9. The exemption and all documents required for the Operator to conduct operations in 

accordance with the conditions and limitations under the exemption are hereinafter 

referred to as the operating documents. The operating documents will be accessible, by 

the Operator during UAS operations and made available to the Administrator or any Law 

Enforcement Official upon request. The Operator shall track such revisions and present 

updated and revised versions of its approved operating documents as requested by the 

Administrator.

10. The Operator shall provide copy of or surrender its operating documents as requested 

by the Administrator, any Law Enforcement Agency or any Law Enforcement Official.

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

shall be conducted in accordance with an ATO-issued COA. The Operator will apply for a 

new or amended COA if it intends to conduct operations that cannot be conducted under 

the terms of this COA.

12. The Operator proposes to conduct operations for the purpose of closed-set motion 

picture and television filming and production. The operator will have an approved motion 

picture and television operations manual (MPTOM) prior to conducting such operations.

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13. When the Operator proposes to conduct closed-set motion picture and television filming 

and production, the Operator will submit a written Plan of Action (POA) to the local Flight 

Standards District Office (FSDO) with jurisdiction over the area of proposed filming 3 

days prior to the planned event. The 3-day 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 under exemption;

C. Name and phone number of the PIC or the person responsible for the onscene operation of the UAS;

D. Make, model, and serial or N-Number of UAS to be used;

E. Name and certificate number of the PIC 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 made available to the Administrator upon request;

G. Signature of the operator 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.

14. The Operator’s official Point of Contact (POC) is as follows:

Federal Aviation Administration

North Texas FSDO

8700 Freeport Parkway, Suite 225

Irving, Texas 75063

214-277-8500

- Regarding the UAS (Unmanned Aerial Systems) and Its Operation

1. The Operator shall operate and provide instruction to operators using the following UAS 

equipment:

A. Yuneec Electric Aviation Q-500 “Typhoon” Quadcopter

B. Yuneec Electric Aviation H-920 “Tornado” Hexacopter

C. DJI S-900 Hexacopter

D. DJI “Inspire” Series Quadcopter

E. DJI “Phantom” Series Quadcopter 

F. JTT - Jiuxing Tianli Technology “T-50 & T-60” www.jttuav.com

G. Any UAS / UAV device which is approved by the Administrator through written 

correspondence on a case-by-case basis

2. The Operator will always operate the UAS within the guidance and recommendations of the 

UAS manufacturer and/or as depicted in the UAS respective Operations Manual (OM).

3. The Operator proposes the gross weight of the UAS will not to exceed 55 lbs to include the 

UAS, its cargo and/or equipment.

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4. The Operator will not operate the UAS at a speed greater than 87 KIAS (100mph) and 

never more than the Vne speed as recommended by the UAV manufacturer.

5. Generally, the Operator will not conduct operations within controlled airspace or in the 

following listed airspace without prior written approval from the local FSDO (Flight Standards 

District Office), the airspace controlling agency, airport manager or owner over which such 

operations are to be conducted:

A. Within 5 statute miles of any airport with an operating control tower.

B. Within 3 nautical miles of any airport with an approved instrument approach 

procedure IAW 14 CFR 97.

C. Within 2 nautical miles of any airport

D. Within 2 nautical miles of any heliport

E. Within any airspace depicted in a TFR (Temporary Flight Restriction) without having 

approval from the entity or agency requesting issuance of the TFR.

F. Under any operations which may be considered to be careless or reckless operation 

as described in 14 CFR 91.13

6. The Operator will not operate any UAS at an altitude greater than 400 feet AGL unless 

written correspondence approving such action is obtained from the local FSDO (Flight 

Standards District Office) having jurisdiction over the area(s) where such operation is 

prospected to occur prior to such operation. Such action will also require notification of the 

local airspace controlling agency as well as issuance of NOTAM describing the location of 

such operation and when such operation shall take place.

7. The Operator will not conduct any operation within controlled airspace without prior 

authorization from that specific airspace controlling agency. Such operation must receive 

prior written authorization from that local airspace controlling agency, airport operations 

manager or other controlling entity as may be applicable. Such operation within controlled 

airspace shall require issuance of NOTAM describing the operation, location and when such 

operation will take place. Additionally, two way radio or telephonic communication with the 

airspace controlling agency must be maintained during UAV operations.

8. While conducting operations the Operator shall follow and maintain operations IAW basic 

cloud clearances as depicted in 14 CFR 91.155.

9. The Operator will not conduct operation in less than VMC (Visual Meteorological Conditions) 

as described in 14 CFR 103.23 as conditions may exist at the location of UAS operation. 

The following shall depict the hierarchy of controlling observation:

1. As described from the air traffic controller. ( i.e. control tower, approach control facility, 

center controller, flight service station (FSS), National Weather Service (NWS) or 

National Oceanic Atmospheric Administration (NOAA), United States military aviation 

operations weather observation site. 

2. As described from the local airport Automated Weather Observation System (AWOS) or 

Automated Surface Observation System (ASOS).

3. As described from the vantage point of the PIC.

4. As described from the vantage point of the VO.

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10. The Operator will not conduct operation at night unless written correspondence of approval 

is obtained from the local FSDO allowing operations to be conducted at night. Night shall be 

defined as described IAW 14 CFR 1.1. The local FSDO may impose additional requirements 

on the Operator such as, display of navigation lights or anti-collision lights on the UAS, (as 

IAW 14 CFR 91.209). The Operator will maintain two-way radio or telephonic communication 

with the airspace controlling agency and provide NOTAM publication with information 

concerning the date, time, location and duration of such operation. If operations are 

approved at night, the Operator MUST provide written correspondence to the local FSDO, 

airspace controlling agency or airport manager having jurisdiction over the airspace where 

operations are to be conducted on a case-by-case basis. Such operations shall not be 

conducted without the expressed written consent of the local FSDO.

11. The UAS must be operated within visual line of sight (VLOS) of the PIC or VO 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 or VO’s FAA-issued airman medical certificate or 

U.S. Government issued driver’s license. (unless approved by the local FSDO on a case-bycase basis, i.e. night covert operations) VO and PIC must be able to communicate verbally 

at all times; two way radio, telephone or other verbally transmitted electronic means of 

communication is acceptable to meet this requirement. 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 and the PIC is the final authority as to the 

safe and efficient operation of the UAS.

12. The Operator shall terminate the mission when the UAS provides indication that the useful 

power supply on board the aircraft has a capacity of 20% or less. The PIC is prohibited from 

beginning a flight unless (considering wind and forecast weather conditions) there is enough 

available power for the UAS to conduct the intended operation and to operate after that for 

at least five minutes or with the reserve power recommended by the manufacturer if greater.

13. If the UAS loses communications or loses its GPS signal, the UAS must return to a predetermined location within the private or controlled-access property.

14. The PIC will abort the flight in the event of unpredicted obstacles, abnormals or 

emergencies.

15. 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.

16. The Operator is responsible for maintaining and inspecting the UAS to ensure that it is in a 

condition for safe operation.

17. Prior to each flight, the PIC or his/her designee 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 

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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.

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

inspection, and life limit requirements for the aircraft and aircraft components.

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

bulletins.

20. All UAS operated by the Operator in accordance will 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.

21. The UAS must remain clear and give way to all manned aviation operations and activities at 

all times.

22. Unless prior written consent has been obtained from the local FSDO, no Operator or UAS 

will be operated by the PIC from any moving device or vehicle.

23. 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.

24. 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.

25. The Operator of the UAS, the UAS PIC, and UAS operations must comply with all applicable 

parts of 14 CFR including, but not limited to, parts 45, 47, 61, and 91.

- Regarding the PIC(s) Pilot(s) In Command of the UAS(s)

1. The PIC must hold either a United States airline transport, commercial, private or 

recreational pilot certificate. As applicable, the PIC must also hold a current FAA airman 

medical certificate (at the level of which that certificate was issued by the Administrator) or a 

valid United States 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.

2. 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 

drone-logic, LLC
purposes of training the operator’s PICs and VOs (training, proficiency, and experiencebuilding) and determining the PIC’s ability to safely operate the UAS in a manner consistent 

with how the UAS will be operated 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 

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

3. Operator will utilize only PIC that hold a minimum of a Recreational Pilot Certificate IAW 14 

CFR 61.96 for mission related operations, excluding training of operators while under the 

instruction of a certificated flight instructor in application of a certificate and/or rating.

4. Operator will require that all PIC maintain a minimum of a current United States Government 

or Territory issued driver license or photo identification IAW 14 CFR 61.3 (2) (i) - (v) while 

conducting operations for Operator.

5. Operator will require that all PIC shall be trained in advance of any mission by conducting 

and logging flight training on areas of operation by using a UAS. This training shall be 

conducted IAW 14 CFR 61.98 (a),(b).

6. Operator will require the pilot to have a minimum of 10 flight cycles and 3 hours of logged 

flight training prior to allowing pilot to act as PIC on any mission operation. (These stated 

self-imposed requirements are subject to change based upon future regulatory 

requirements).

7. Operator will require the pilot to have acquired a minimum of 10 flight cycles and 1 hour of 

logged flight training with each UAS type and UAS manufacturer prior to conducting mission 

related operations as PIC. (These stated self-imposed requirements are subject to change 

based upon future regulatory requirements).

8. Operator will require that the pilot desiring to conduct duties as PIC shall have reviewed and 

familiarized him / herself with the manufacturer’s Operations Manual (OM) or equivalent, 

specific to the make and model of UAS that the pilot intends to operate as PIC. This 

information shall include but not necessarily be limited to normal and emergency operations, 

take-offs, landings, maneuvering around in close proximity to persons and or property which 

may be affected by such operation.

9. Operator will require that the PIC maintain currency of his/her pilot certificate and medical 

certificate (if applicable) at the level of which that certificate was issued by the Administrator; 

while exercising privileges of that certificate under operations for the Operator as PIC.

- Regarding the Visual Observer (VO)

1. A VO shall be trained and utilized by the Operator when the VLOS (Visual Line Of Sight) is 

unable to be maintained by the PIC while conducting operational missions for the Operator. 

2. The VO must be trained and utilized on the areas of operation IAW Document N8900.227 

14(a) and 16(e). 

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3. The VO must have knowledge of and be able to assist the PIC with operation of the UAS to 

maintain operation IAW 14 CFR 91.111, 91.113, 91.115 and 91.155. 

* The specific section or sections of 14 CFR from which you seek exemption;

* The extent of relief you seek and the reason you seek the relief;

AND

* Reasons why the exemption would not adversely affect safety, or how the exemption 

would provide a level of safety at least equal to the existing rule;

- Exemptions Requested

The Operator generally requests exemption from the following regulations for the purpose of 

conducting commercial UAS operations within controlled airspace. 14 CFR Part 21, Subpart H; 

14 CFR 45.23 (b); 14 CFR 61.101 (a)(2), (e)(1)(ii),(iv), (e)(2) - (8), (e)(12), (e)(14), (g); 14 CFR 

61.113 (a), (b); 14 CFR 91.7 (a); 14 CFR 91.9 (b) (2); 14 CFR 91.103; 14 CFR 91.109; 14 CFR 

91.111; 14 CFR 91.119; 14 CFR 91.121; 14 CFR 91.151; 14 CFR 91.203 (a), (b); 14 CFR 

91.209; 14 CFR 91.405 (a), (b); 14 CFR 91.407 (a)(1); 14 CFR 91.409 (a)(1)-(2); and 14 CFR 

91.417 (a), (b).

The Operator specifically requests relief from the following regulations and in such capacity as 

depicted below:

14 CFR part 21 Subpart H - 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 UAS and its operation, the Operator requests exemption 

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. 14 CFR 

Part 21 Subpart H meets the requirements of an equivalent level of safety under Part 11 and 

Section 333 of the FMRA. The Federal Aviation Act (49 U.S.C.§ 44701(f)) and Section 333 of 

the FMRA 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 UAS. In all cases, 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 at least as safe, or safer, than a 

conventional aircraft operating with an airworthiness certificate without the restrictions and 

conditions proposed.

14 CFR 45.23 (b) – Display of marks; General.

This regulation requires that aircraft display proper registration markings as required by aviation 

authority. 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 provisionally 

certificated aircraft, the operator must also display on that aircraft near each entrance to the 

cabin, cockpit, or pilot station, in letters not less than 2 inches nor more than 6 inches high, the 

drone-logic, LLC
words “limited,” “restricted,” “light-sport,” “experimental,” or “provisional,” as applicable. The 

Operator’s UAS has no entrance to the cabin, cockpit, or pilot station on which the markings can 

be placed, two inch lettering would not be possible. Official marking systems for small UAS have 

not yet been established for operations inside the NAS. Operator proposes to mark the UAS 

with registration markings as large as practical to be displayed on the UAS as directed by the 

local FSDO and/or future regulation.

14 CFR 61.101 (a)(2), (e)(1)(ii),(iv), (e)(2) - (8), (e)(12), (e)(14), (g) - Recreational pilot 

privileges and limitations.

The Operator specifically request exemption from the aforementioned regulations of 14 CFR 

61.101. This regulation prohibits recreational pilots from performing duties as a pilot for 

compensation or hire or aircraft with more than one power plant, retractable landing gear, 

carrying persons or property, in furtherance of a business or within class A,B,C or D airspace. 

The Operator proposes to utilize pilots in command (PIC’s) with a minimum of a recreational 

pilot certificate IAW 14 CFR 61 Subpart D. The proposed operations can achieve an equivalent 

level of safety of current operations by requiring the PIC operating the UAS to have a minimum 

of a recreational pilot’s certificate rather than a commercial pilot’s certificate to operate the UAS 

proposed to be utilized in this operation. Flights which are proposed to be conducted by the 

Operator within controlled airspace will be conducted only having received prior written approval 

from the local FSDO and/or the local airspace controlling agency, (ATC) in which operations are 

proposed to be conducted and if applicable the appropriate airport manager or owner. The 

Operator will maintain two-way radio or telephonic communication with the ATC agency during 

operations. The Operator will also publish NOTAM advisories a minimum of 24 hours prior to 

conducting operations within controlled airspace or as requested by FSDO. All PIC shall meet 

the requirements of 14 CFR 61.97 prior to conducting operations for the Operator as PIC.

14 CFR 61.113 (a) & (b) - Private pilot privileges and limitations: Pilot in command.

This regulation prohibits a person which holds a private pilot certificate from operating any 

aircraft as pilot in command (PIC) for compensation or for hire. This regulation also prohibits a 

private pilot from conducting operations which involves carriage of persons or property for hire. 

The UAS platform is not capable of carrying a pilot or persons onboard the aircraft. The 

proposed operations can achieve an equivalent level of safety of current operations by requiring 

the PIC operating the UAS to have a minimum of a recreational pilot’s certificate rather than a 

commercial pilot’s certificate to operate this UAS. Operator specifically requests exemption from 

this regulation so that the Operator may conduct operations using UAS for hire and in the 

carriage of property or equipment.

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

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

condition. As the UAS has no airworthiness certificate issued for the aircraft, should this 

exemption be granted, no FAA regulatory standard will exist for determining airworthiness. An 

equivalent level of safety will be provided by the small size of the UAV and the requirements 

contained in the manufacturer instructions for maintenance and use of safety check lists prior to 

each flight. The Operator will ensure that the UAS is in an airworthy condition prior to each flight 

based on compliance with the specifications in the manufacturer instructions.

14 CFR 91.9 (b) (2) - Civil aircraft flight manual, marking, and placard requirements.

This regulation requires that an aircraft flight manual be carried upon the aircraft while in flight. 

With the operational limitations of the UAS and the unmanned nature of its operation, it is not 

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practical to carry a flight manual onboard the aircraft while it is in operation. The Operator shall 

familiarize him/herself with the operational manual of the UAS prior to performing operations as 

the PIC. Additionally, the PIC shall have access to the manufacturer’s operational manual (OM) 

while operating the UAS. The UAS operated by the Operator will be identified by serial number, 

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

with 14 CFR part 45, Subpart C. Markings must be as large as practicable.

14 CFR 91.103 - Preflight action.

The Operator only seeks to obtain exclusion from this regulation as to an FAA approved 

operational or flight manual for the UAS. UAS equipment is not approved as an airframe under 

14 CFR Parts 23 or 25 certification and as such no FAA approved flight operations manual is 

published. The Operator will utilize the UAS manufacturer operators manuals (OM), policies 

and procedures developed by the manufacturer for operation of the UAS. Additionally, the 

Operator will conduct preflight activity to include but not necessarily limited to determine among 

other items, current and forecast weather conditions, wind, temperature, performance 

calculations for take-off and landing, runway distances, power source requirements, facilities at 

intended airports and/or areas of operation.

14 C.F.R. 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 that aircraft has fully functioning dual 

controls. By their design, UAS and remotely piloted aircraft do not have fully functional dual 

controls. Flight control is accomplished through the use of an electronic control that 

communicates with the aircraft via radio telemetry communications. The FAA has approved 

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

flight instruction in experimental aircraft. See Exemption Nos. 5778K and 9862A. The equivalent 

level of safety provided by the fact that neither a pilot nor passengers will be carried in the 

aircraft and by the size and speed of the aircraft. As such, the Operator requests relief from this 

regulation as described in this request for exemption and IAW its proposed order of operations.

14 CFR 91.111 - Operating near other aircraft.

Operator specifically requests exemption from this regulation so that the Operator may conduct 

controlled formation flight operations with multiple UAS and or manned aircraft. From time to 

time the Operator may utilize more than one UAS or manned aircraft designated as a chase or 

visual observer aircraft in effort to conduct its operations. The Operator will only conduct such 

operations within controlled airspace after having received written approval from the local 

FSDO, local controlling airspace agency in which operations are proposed to be conducted and 

if applicable the appropriate airport manager or owner. The Operator will also publish NOTAM 

advisories a minimum of 24 hours prior to conducting operations within controlled airspace or as 

requested by FSDO.

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

This regulation 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 UAS that are similar to helicopters, and the exemption requests authority to 

operate at altitudes up to and including 400 AGL, an exemption may be needed to allow such 

operations. The UAS platform will not be operated higher than 400 AGL without prior written 

authorization on a case-by-case basis from the local FSDO or ATC airspace controlling agency 

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responsible for the airspace in which operations are proposed to be conducted. Additionally, the 

Operator will also publish NOTAM advisories a minimum of 24 hours prior to conducting 

operations within controlled airspace or as requested by FSDO. An equivalent level of safety will 

be achieved given the size, weight, speed of the UAS platform as well as the locations where 

they are operated. The low-altitude operations of the UAS platform will ensure separation 

between the UAS operations and the operations of conventional manned aircraft that must 

comply with Section 91.119.

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 UAS platform may not have a barometric 

altimeter, but instead a GPS altitude read out, an exemption may be required. An equivalent 

level of safety will be achieved by the operator, pursuant to the SOP and manufacturer 

instructions, the PIC shall confirm the altitude of the launch site shown on the GPS altitude 

indicator before flight with topographical maps, sectional charting or published airport elevation 

designations.

14 C.F.R. 91.151: Fuel Requirements for Flight in VFR Conditions.

This regulation 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.” Given the limitations on the proposed operations areas, a longer time frame for VFR 

conditions is reasonable. Applicant 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 14 C.F.R. 91.151 (a)). Operating the UAS 

platform in controlled operations does not engender the type of risks that Section 91.151(a) was 

intended to alleviate given the size and speed of the UAS platform. The UAS platform does not 

utilize fuel either liquid or solid formatSimilar exemptions have been granted to other operations, 

including Exemptions 2689F, 5745, 10673, and 10808. The Operator proposes to terminate 

flight operations when indication form the UAS controller is received showing 20% battery life is 

remaining.

14 C.F.R. 91.203 (a) and (b): Carrying Civil Aircraft Certification and Registration.

The FAA has previously determined that no airworthiness certification is necessary for UAS 

platforms. See, e.g., Exemption No. 11110. The Operator therefore believes that no exemption 

is necessary from 91.203. However, to the extent that the FAA finds that section 91.203 is 

applicable to the Operator’s operations, the Operator requests an exemption therefrom.

The regulation provides in pertinent part:

(a) Except as provided in 14 CFR 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 14 CFR 91.715 is 

displayed at the cabin or cockpit entrance so that it is legible to passengers or crew.

The UAS platform weighs no more than 55 pounds fully loaded, and are operated without an 

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

documents or to display them on the UAS.

drone-logic, LLC
An equivalent level of safety will be achieved by keeping these documents at the ground control 

point where the pilot flying the UAS will have immediate access to them, to the extent they are 

applicable to the UAS. The FAA has issued numerous exemptions to this regulation. A 

representative sample of other exceptions includes Exemption Nos. 9565, 9665, 9789, 9789A, 

9797, 9797A, 9816A, and 10700. Based on the limited size, weight, operating conditions, design 

safety features, and the imposed conditions and limitations, Operator has determined that its 

operations would not adversely affect safety compared to similar operations conducted with 

aircraft that have been issued an airworthiness certificate under 14 CFR part 21, Subpart H. 

Therefore, as the FAA found for similar exemptions (See Exemption 11110), the Operator 

believes that the requested relief from 14 CFR Part 21, and 14 CFR 91.203 (a), (b) and any 

associated noise certification and testing requirements of part 36, should be granted.

14 CFR 91.209 Aircraft lights. 

This regulation states that no person may, during the period from sunset to sunrise operate an 

aircraft unless it has lighted position lights. Additionally, no person may operate an aircraft that 

is equipped with an anti-collision light system, unless it has lighted anti-collision lights. However, 

the anti-collision lights need not be operated when the pilot-in-command determines that, 

because of operating conditions, it would be in the interest of safety to turn the lights off. The 

Operator specifically requests exemption from this regulation on a case-by-case basis, as 

approved by the local FSDO, in order to perform covert investigations in concert with a licensed 

private investigation agency a United States law enforcement agency and/or as directed by 

United States governmental directive. The Operator will not conduct operations without prior 

written consent from the local FSDO or ATC airspace controlling agency responsible for the 

airspace in which operations are proposed to be conducted. Additionally, the Operator will also 

publish NOTAM advisories a minimum of 24 hours prior to conducting operations within 

controlled airspace or as requested by FSDO. An equivalent level of safety will be achieved 

given the size, weight, speed of the UAS platform as well as the locations where they are 

operated. The low-altitude operations of the UAS platform will ensure separation between the 

UAS operations and the operations of conventional manned aircraft that must comply with 

Section 91.119 and 14 CFR 91.209. 

14 C.F.R. 91.405 (a); 407 (a) (1); 409 (a) (2); 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.

Given that these section and Part 43 apply only to aircraft with an airworthiness certificate, 

these sections will not apply to the Operator. Maintenance will be accomplished by the Operator 

pursuant to the manufacturer instructions. An equivalent level of safety will be achieved because 

the UAS are limited in size, carry a small payload, and will operate only in defined operations 

areas for limited periods of time. If mechanical issues arise the UAS platform can land 

immediately and will be operating from no greater than 400 feet AGL. As provided in the 

manufacturer instructions, the Operator will ensure that the UAS is in working order prior to 

initiating flight, perform required maintenance, and will 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.

* If you want to exercise the privileges of your exemption outside the United States, you 

must state the reason.

drone-logic, LLC
The reason for applying for this COA is solely to conduct commercial operations. As such, our 

company requests the opportunity to expand across borders and into other countries as 

necessary in the conduct of this business and under the guidance of this approval. For example, 

in efforts to conduct business with other foreign businesses in the manufacture and distribution 

of UAS (i.e. JTT Technology company as listed above under -Regarding the UAS).

* How your request would benefit the public as a whole;

AND

* A summary we can publish in the Federal Register.

* A brief description of the exemption you seek.

* Any additional information, views, or arguments available to support your 

request

- SUMMARY

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

and 14 C.F.R. Part 11, drone-logic, LLC (Operator) seeks an exemption from Federal Aviation 

Regulations (FARs) to allow commercial operations of their UAS (Unmanned Aerial Systems) for 

the purpose of training other UAS operators, data collection, conducting aerial photography and 

videography, inspections and survey for various industries.

As described fully above, the requested exemption would permit the operation of an UAS under 

controlled conditions in the NAS that would be a) limited b) controlled c) predetermined and d) 

will provide safety enhancements to the already safe operations in the industry presently using 

conventional aircraft. Approval of this exemption would thereby enhance safety and fulfill the 

Secretary of Transportation’s (the FAA Administrator’s) responsibilities to “....establish 

requirements for the safe operation of such aircraft systems in the national airspace system.”

Given the small size of the UAS and the controlled environment provided, the proposed 

operations will adhere to the Reform Act’s safety requirements. The approval of this application 

presents no national security issues. Regarding the level of safety surrounding the proposed 

operations and the public benefit, reduction in environmental impacts, including but not limited 

to reduced emissions and noise, the grant of the requested exemption is in the best interest of 

the public.

The Operator generally requests exemption from the following regulations for the purpose of 

conducting commercial UAS operations within controlled airspace. 

14 CFR Part 21, Subpart H; 

14 CFR 45.23 (b); 

14 CFR 61.101 (a)(2), (e)(1)(ii),(iv), (e)(2) - (8), (e)(12), (e)(14), (g); 

14 CFR 61.113 (a), (b); 

14 CFR 91.7 (a); 

14 CFR 91.9 (b) (2); 

14 CFR 91.103; 

drone-logic, LLC
14 CFR 91.109; 

14 CFR 91.111; 

14 CFR 91.119; 

14 CFR 91.121; 

14 CFR 91.151; 

14 CFR 91.203 (a), (b); 

14 CFR 91.209;

14 CFR 91.405 (a), (b); 

14 CFR 91.407 (a)(1); 

14 CFR 91.409 (a)(1)-(2); 

14 CFR 91.417 (a), (b).

With Best Regards,

Brad Haubrich

Managing Member

drone-logic, LLC