US Department of Transportation 

Docket Management Systems 

West Building, Ground Floor Room W 12-140 

1200 New Jersey Ave., SE 

Washington, DC 

20590 

Drone Control Systems LLC 

James D. Lawrence 

Founder/President 

1964 North Red Rock Road 

P.O. Box 252 

Dragoon, AZ 85609 

Dear Sir or Madam: 

Let this letter and enclosed documentation serve as a respectful and formal request from me, 

James D. Lawrence, founder and president of Drone Control Systems LLC, to be allowed to 

operate drones, commercially, for compensation or hire. 

The enclosed documentation has been formatted following "Petition for Exemption 14CFR 

11.81 ", as found in the FAA's website, www.faa.gov. I am confident you will find all the 

information in order. 

I can be reached for questions or conversation about the matter hereby enclosed via e-mail at 

james.lawrence ce ,uavfms.com, or via phone at (520)-686-4303. 

Yours, 

James D. Lawrence 

Founder/President 

Drone Control Systems LLC 

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TABLE OF CONTENT 

1)GENERAL INFORMATION 

2) INTRODUCTION 

3) BASIS FOR PETITION 

4) EXEMPTIONS SOUGHT 

5)EXTENT OF RELIEF 

6) PUBLIC BENEFIT 

7) PUBLISHABLE INFORMATION 

8)ADDITIONAL INFORMATION 

9) PRIVILAGES OUTSIDE THE UNITES STATES 

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1) GENERAL INFORMATION 

(a) Drone Control Systems LLC. 

(i) Founder/President: James D. Lawrence 

(ii) Physical/Mailing address: 1964 North Red Rock Road, P.O. Box 252, 

Dragoon, Arizona 85609 

(iii)E-mail address: james.lawrence@uavfms.com 

(iv)Incorporating State: Arizona 

(b) James D. Lawrence: I've been a certified glider pilot since 12-JUN-1999 

with the FAA. I received my Private Pilot rating on June 12 1999. Pursuant to 

complying with Section 333 and the FAA's Modernization Act of 2012, I feel I 

comply with what I believe to be the pivotal requirement for commercial 

operation of a drone for compensation or hire, which is having a pilot's certificate 

and being in good standing with the FAA. 

Furthermore, I have been actively involved in the radio controlled drones as a 

hobby since 2011. I continuously strive to operate my hobbyist drones within 

visual flight rules established by the FAA and was one of the first to successfully 

register as a UAS operator on the FAA's new Drone registration database. 

My FAA issued Drone registration ID is: FA33A37PHX, which I received on 

December 21 St, 2015. 

2) INTRODUCTION 

Drone Control Systems LLC is a Dragoon Arizona based company which aims to capitalize 

on the commercial use of drones, for compensation or hire, while serving several market 

verticals and/or industries in a variety of specialized functions, within the continental United 

States (including Alaska), Puerto Rico, United States Virgin Islands and Hawaii. 

(Privileges outside of the continental Unites States and its territories will be addressed in the 

"Privileges outside the United States" section) 

The verticals and industries that we hope to impact with our services include, but are not limited 

to: 

• Agriculture 

• Transportation 

• Infrastructure 

• Engineering 

• Architecture 

• Manufacturing 

• Healthcare 

• Legal 

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• Non-for-profit 

• Higher Education 

• K-12 

• Telecommunications 

• State and Local Governments 

• Commercial General 

• Commercial, General 

• Commercial, Industrial 

• Marketing and Advertising 

• Real Estate 

• Energy 

• Oil & Gas 

• Cinematography 

• UAS Software Development 

The specialized functions we hope to perform for companies and organizations which are part of 

the verticals and industries we mentioned above include, but are not limited to: 

• Still aerial photography 

• Aerial video 

• Closed set functions 

• Cinematography 

• Photometry 

• Topography studies 

• Geomapping 

• Surveying 

• Strategic farming studies 

• Livestock monitoring 

• Logistics 

• Crowd control 

• Missing person search 

• Rapid response 

• Structure inspections 

• Surveillance 

• Flight instruction/training 

• Flare stack inspections 

• UAS tracking and monitoring software development 

3) BASIS FOR PETITION 

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Drone Control Systems LLC, pursuant to comply and abide with and by the provisions put forward 

by the FAA Modernization Act of 2012 and Section 333, hereby respectfully request that 

permission be granted, in a manner which aligns with the interest of the FAA and that of Drone 

Control Systems LLC in conducting commercial operations safely, to operate drones, 

commercially, for compensation or hire. 

Drone Control Systems LLC's fleet of drones comprises of the following: 

• DJI Inspire 1 

• DJI Inspire 1 Pro 

• DJI Phantom 3 

• DJI Phantom 2 

• DJI Phantom 1 

• Solo 3 DR 

• Yuneec Typhoon Series 

These are commercially available drone units which operate well within the limitations for 

weight, speed, altitude and operational capabilities set forth by the FAA. In addition, all of these 

commercially available drones have been listed in other several petitions for exemption as being 

part of a drone fleet. Further technical information will be furnished upon request. 

4) EXEMPTIONS SOUGHT 

Following suite whereas other section 333 applicants have put forward this section for 

"exemptions sought" and have successfully navigated the application process to operate their 

drones, for compensation or hire, Drone Control Systems LLC hereby respectfully request 

exemption from the following Federal Aviation Regulations parts/sections/sub-sections: 

• 14 CFR 21 subpart H Airworthiness certificates 

• 14 CFR 45.23 Display of marks, general 

• 14 CFR 61.113 Private pilot privileges and limitations: pilot in command 

• 14 CFR 91.9 Civil aircraft flight manual, markings and placard requirements 

• 14 CFR 91.109 Flight instruction: simulated instrument flight and certain flight tests 

• 14 CFR 91.119 Minimum safe altitudes: general 

• 14 CFR 91.121 Altimeter settings 

• 14CFR 91.151 Fuel requirements for flight in VFR conditions 

• 14 CFR 91.203 Civil aircraft: certifications required 

• 14 CFR 91.405 Maintenance required (a)(b) 

• 14 CFR 91.407 Operation after maintenance, preventive maintenance, rebuilding or 

alteration 

• 14 CFR 91.409 Inspections 

• 14 CFR 91.417 Maintenance records 

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5) EXTENT OF RELIEF 

Pursuant to complying with the petition format and infortnation required, as set forward by the 

"Petition for Exemption 14CFR 1 1.81 t", as found in the FAA's website, www.faa.gov, let the 

following section "Extent of Relief serve as further detail and more granular explanation for 

request of exemption, as listed above. 

• 14 CFR 21 subpart H Airworthiness certificates: 

Based on the size, weight, operation, safety measures, conditions and limitations set 

forth, and the pivotal fact that my drones are commercially available and, therefore, 

places the need to abide by any requirement and/or regulation that the Administrator 

deems necessary, on the manufacturer, (including, if found necessary, an airworthiness 

certificate), exemption should be granted to Drone Control Systems LLC, for the reason 

that we are, merely, a user. 

As an alternative, Drone Control Systems will set a maintenance/inspection schedule and 

a maintenance log book will be kept for each drone in operation as to track information 

that will include, but will not be limited to: date of inspection/repair, name of person who 

performed repair, what part or appliance (if any) was replaced, general items or actions 

performed during inspection/repair, PIC who performed operation flight check (if 

applicable), return to service on date. This is an effort to maintain the fleet in the utmost 

airworthiness condition. 

• 14 CFR 45.23 Display of marks, general: 

In the drone units commercially available today there is no entrance to a cockpit, cabin 

or pilot station, therefore, the traditional placement of flight placards is not possible. 

Furthermore, a standardized marking system for "drones" and uav's has not yet been set 

forth. 

As an alternative, based on James D. Lawrence's experience in the field of radio 

controlled hobbyist drone flying, and the importance of, at a very basic level, being able 

to identify a flying craft, Drone Control Systems LLC, will place the appropriate 

markings, in a manner that is convenient and does not interfere with the safe operation of 

the drone, as to reflect: drone's owner (Drone Control Systems LLC.) and contact 

information. 

• 14 CFR 61.113 Private pilot privileges and limitations: pilot in command: 

By virtue of this regulation, which prohibits a private pilot from flying, persons or cargo, 

for compensation or hire, exemption is necessary since the FAA has deemed the 

aeronautical knowledge possessed by a private pilot as acceptable for acting as PIC of a 

drone, flying commercially, for compensation or hire. 

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In addition, in the future, Drone Control Systems LLC will hire pilots as part of their 

expansion plans. A private, sport or recreational pilot would meet the FAA's requirement 

for commercial operations (as far as having the pilot in command be a certificate holder 

in good standing with the FAA) and, as such, would respectfully request exemption in 

this area. 

• 14 CFR 91.9 Civil aircraft flight manual, markings and placard requirements: 

Markings and placards were previously addressed in 14 CFR 45.23. 

As an alternative, the flight manual, while not practical to be carried on board the flying 

drone, should be kept accessible to the pilot, at all times, at the ground station. Drone 

Control Systems LLC has made this part of the operating procedures. 

• 14 CFR 91.109 Flight instruction: simulated instrument flight and certain flight tests: 

By virtue that a drone is, by nature, unmanned, therefore, does not have a 

cabin/cockpit/flight station, instruction cannot be conducted by use of a"dual control" 

system. 

As an alternative, Drone Control Systems LLC will establish a pilot training program, 

very much like the current teaching method for radio controlled model airplanes. This 

method consists of a pilot in command and a student. Previous to the first flight, the 

appropriate "ground" time has been spent talking about aircraft systems, control systems, 

basics of flight and how the actual teaching will take place. 

While in the air, there is constant verbal communication between the student and 

instructor and, in the event that the student requires help, the instructor "takes over" the 

control unit. 

• 14 CFR 91.119 Minimum safe altitudes: general: 

As set forth in the rules issued by the FAA for safe operation of a drone, whereas the 

drone should be operated no higher than 400ft AGL, exemption from 14 CFR 91.119 is 

inherently necessary to comply with the 400ft AGL rule. 

As an alternative, as part of Drone Control Systems LLC's operational procedures, the 

necessary measures will be taken as to provide for public safety by setting a"perimeter" 

which allows for the safe takeoff, flight operations, and landing of the drone while 

avoiding close contact with the public (people not inherent to the flight mission), 

structures, property, etc.. 

• 14 CFR 91.121 Altimeter settings: 

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While the drone is not equipped with an on board pressure sensitive altimeter, the global 

positioning system aided guidance system (which does have altitude telemetry) in 

combination with the organic nature of drone flights (low level, line of sight, one pilot in 

command and one visual observer), builds a level of safety as it relates to obstacle 

avoidance, controlled flight and general safety. 

• 14CFR 91.151 Fuel requirements for flight in VFR conditions: 

This regulation addressed the traditional, av/jet/diesel/mogas fuel dependent, flying craft. 

Exemption is requested for this part since drones, as commercially available today, do 

not rely on fuel as listed before but on electricity provided by a rechargeable battery, for 

flight. 

As an alternative, Drone Control Systems LLC will enforce the following as part of its 

flight procedures: the pilot in command shall have the ability to initiate the flight, 

conduct the flight and land while having at least 20% of battery life remaining. 

Example: 

• Battery life, per flight, under normal circumstances: 30 minutes of flight time - 20% 

equates to 6 minutes 

• Pilot in command can fly up to 24 minutes 

• 14 CFR 91.203 Civil aircraft: certifications required: 

While it is not practical to have any appropriate documentation aboard the drone, while 

in flight or on the ground (for lack of storage space onboard), Drone Control Systems 

LLC suggests that, as a viable alternative, to have all the appropriate documentation 

stored, available and ready to be reviewed, at all times, at the ground station. 

• 14 CFR 91.405 Maintenance required: 

See my explanation for 14 CFR 21 

~ 14 CFR 91.407 Operation after maintenance, preventive maintenance, rebuilding or 

alteration, 14 CFR 91.409 Inspections and 14 CFR 91.417 Maintenance records: 

Exemption is sought from these regulations since they only pertain to crafts that have 

airworthiness certificates. As such, the drone, providing it complies with all the 

limitations put forth by the Administrator, shall not be ruled under these. 

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As an alternative, Drone Control Systems LLC will conduct maintenance and repairs as 

prescribed by the manufacturers' operating handbook. Furthermore, flight, as well as 

maintenance, logs will be kept for each unit in use. (See 14 CFR 21) 

6) PUBLIC BENEFIT 

The advent of drones and the gesture from the FAA in allowing certificate holders to be able to 

conduct commercial operations and applications, could not have come at a better time. The public, 

as well as businesses, are constantly looking to minimize their footprint and, at the same time, 

controlling costs while improving safety. Drones in commercial applications achieve this is 

several levels: 

• Decreased congestion of the National Airspace System 

• Zero emissions 

• Decreased noise pollution 

• Limiting human exposure to inherently dangerous operations like inspections, mining 

studies, surveying, etc. 

• Decrease cost of doing business (ex: a drone taking aerial pictures versus a helicopter 

taking pictures) 

• No privacy issues (flights conducted over private or controlled properties, where 

permission has been previously received) 

• Employment generation 

7) PUBLISHABLE INFORMATION 

The entire content of this document is publishable. 

8) ADDITIONAL INFORMATION 

Drone Control Systems LLC. will potentially become one of the pioneering companies in the 

United States for commercial applications of drones. As such, we are committed to setting forth 

a positive example as it relates to operational excellence, corporate integrity and having safety 

as our true north. Therefore, we hereby set forward our unconditional commitment to following 

and abiding the rules set forth by the FAA. Furthermore, our internal processes will reflect this 

in a way that can be copied by other business in the spirit of sharing best practices and 

benchmarking. 

As it relates to enhanced safety and making safety the number one priority during pre, mission 

and post flight operations, Drone Control Systems LLC will make the following procedures 

part of their operating manual. In addition, as best practices start being shared, we will embrace 

those that pose the most benefit for enhanced safety. 

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1) Every unit on our fleet will abide with the limitations set forward by the FAA as it relates 

to weight, speed, altitudes, operational capabilities, etc.. 

2) Day time operations only 

3) Line of sight flight 

4) Minimum flight crew will consist of Pilot in Command (PIC) and Visual Observer (VO) 

5) Pre-mission briefing mandatory 

6) Checklists abided by for pre-flight and post-flight 

7) Comply with "minimum fuel" (20% battery life) requirement 

8) Permission (from owner or agent) will be received verbally and noted in written form 

before flight over property is commenced 

9) If flight mission requires Drone Control Systems LLC to operate with 5 NM of the center 

of a runway complex of an airport, we will advise, with no less than 72 hours, the 

Administrator of the activity. A detailed briefing of the operation will be furnished. On 

the day of the flight, the PIC will issue, by way of hand held radio, reporting calls to the 

controlling tower or CTAF which will include all the pertinent data as it relates to the 

drone's altitude, location, proximity to the airport and intentions. 

10)Drones will yield and give right of way and remain clear at all times 

9) PRIVILAGES OUTSIDE THE UNITED STATES 

The opportunity may arise where a domestic customer/prospect may want Drone Control 

Systems LLC to conduct operations outside of the continental United States and/or its 

territories. If this was the case, Drone Control Systems LLC would, as part of travel abroad, 

take with us our safety procedures, any required hardware, software and anything else deemed 

necessary. 

Drone Control Systems LLC will proactively look into what considerations should be observed 

when travelling to other countries (ex: acceptance of drones in the country, permits, safety 

requirements {which exceed the ones established}). Potentially contacting the United States 

Embassy at that country for further information gathering. In addition, find local rules for 

operating drones in general. 

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