UNITED STATES OF AMERICA

DEPARTMENT OF TRANSPORTATION

FEDERAL AVIATION ADMINISTRATION

WASHINGTON, DC

Regulatory Docket No. _______________

IN THE MATTER OF THE PETITION FOR EXEMPTION OF:

THONE DRONE LLC FOR AN EXEMPTION SEEKING RELIEF FROM THE 

REQUIREMENTS OF TITLE 14 OF THE CODE OF FEDERAL REGULATIONS

SECTIONS 45.23, 61.113(a) & (b), 91.7(a), 91.103, 91.109, 91.119, 91.121, 91.151(a), 

91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), AND 91.417(a) & (b), AS WELL AS THE 

RESTRICTED CATEGORY AIRWORTHINESS CERTIFICATION STANDARDS 

SPECIFIED IN 14 C.F.R. § 21.185 TO OPERATE COMMERCIALLY UNMANNED 

VEHICLE (55LBS OR LESS). 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 12/15/2015

Thone Drone LLC 

Terry S. Thone, President/Owner/Operator

309 E Lincoln

Luverne, MN 56156

507-449-4646

info@thonedrone.com

TABLE OF CONTENTS

NAME AND MAILING ADDRESS.......................................................................2

GLOSSARY OF ABBREVIATIONS ................................................................................2

BASIS FOR PETITION ....................................................................................................3

THE SPECIFIC SECTIONS OF 14 CFR FROM WHICH, THONE DRONE LLC

SEEKS EXEMPTION ............................................................................................5

EXTENT, REASON AND INTERESTS OF THE PETITIONER...................................8

THE REASONS WHY GRANTING THONE DRONE LLC’S REQUEST WOULD

BE IN THE PUBLIC INTEREST ...................................................................................11

THE REASONS WHY GRANTING THE EXEMPTION WOULD NOT ADVERSELY

AFFECT SAFETY...........................................................................................................17

SUMMARY.....................................................................................................................21

ADDITIONAL INFORMATION.........................................................................22

USER MANUAL LINKS..................................................................................................22

PACKING CHECKLIST, PREFLIGHT CHECKLIST, FLIGHT CARD, POSTFLIGHT 

CHECKLIST AND ACCIDENT REPORT............................................................23
Name And Address Of The Petitioner.

The name and address of the Petitioner and point of contact is:

Terry S. Thone c/o Thone Drone LLC

309 E Lincoln

Luverne, MN 56156

Tel: (507) 449-4646

Email: info@thonedrone.com

GLOSSARY OF ABBREVIATIONS

AGL Above Ground Level

AOI Area of Interest

ATC Air Traffic Control

ATO Air Traffic Organization

AV Aerial Vehicle

CASA Civil Aviation Safety Association

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)

SO Safety Observer

SOP Standard Operating Procedures

UA Unmanned Aircraft

UAS Unmanned Aircraft System

VFR Visual Flight Rules

VLOS Visual Line of Site

VMC Visual Meteorological Conditions

VTOL Vertical Takeoff and Landing

Intended Purchases

Unmanned Aircraft Systems: Presently considering the latter drones but will submit for 

amendment for future considerations.

1) DJI Inspire

2) Yuneec Tornado H920

3) DJI 1000+
Thone Drone LLC seeks an exemption to operate UAV systems for compensation or 

hire within the NAS. The fore mentioned UAV’s are vertical takeoff and landing (VTOL) 

Unmanned Aircraft (UA) with a Ground Control Station (GCS) utilizing electronic tablet,

smart phone and/or complete base stations.

All UAs that will be operated by Thone Drone LLC will be registered in accordance with 

49 U.S.C. 44103, Registration of Aircraft, as well as 14 C.F.R Part 47, Aircraft 

Registration, and marked in accordance with 14 CFR Part 45, Identification and 

Registration Marking(§ 45.23).

BASIS FOR PETITION

Petitioner, Thone Drone LLC, pursuant to the provisions of the Federal Aviation

Regulations (14 CFR § 11.61) and the FAA Modernization and Reform Act of 2012

(FMRA), Section 333, Special Rules for Certain Unmanned Aircraft Systems, 

hereby petitions the Administrator to commercially operate UASs in the National 

Airspace System (NAS), and for an exemption from the requirements of 14 C.F.R §§ 

21.185, 45.23(b), 61.113(a) & (b), 91.7(a), 91.103, 91.109, 91.119, 91.121, 91.151(a), 

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

21.185, 61.113(a) & (b), 91.7(a), 91.103, 91.109, 91.119, 91.121, 91.151(a), 91.405(a), 

91.407(a)(1), 91.409(a)(1) & (a)(2), AND 91.417(a) & (b),

14 C.F.R. § 21.185. Thone Drone seeks relief from the airworthiness certificate 

requirements of the Federal Aviation Regulations and proposes to commercially operate 

the UAVs, without an airworthiness certificate, pursuant to specific operating limitations 

and a Safety Management System (“SMS”). Thone Drone seeks relief from the 

airworthiness certificate requirements of 14 C.F.R. § 21.185 to the extent that the UAVs

have not yet been type certificated by the FAA, may be operated as if they were a 

restricted category aircraft for a single, defined, special purpose operation

14 C.F.R. § 91.103: Preflight action. This regulation requires each pilot in command to 

take certain actions before flight to ensure the safety of flight. As FAA approved 

rotorcraft flight manuals will not be provided for the aircraft an exemption will be needed. 

An equivalent level of safety will be provided as set forth in the Manual. The PIC will 

take all actions including reviewing weather, flight battery requirements, landing and 

takeoff distances and aircraft performance data before initiation of flight.

14 C.F.R. §91.109: Flight instruction: Section 91.103 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. UAVs and remotely piloted 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 aircraft and 

for flight instruction in experimental aircraft. See Exemption Nos.5778K & 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.
In consideration of the speed, weight, size, and limited operating area associated with 

the unmanned aircraft and its operation, Thone Drone LLC operation of UASs will meet 

the conditions of FMRA Section 333 and therefore, will not require an airworthiness 

certificate in accordance with 14 CFR Part 21, Subpart H.

The predefined UAS’s are remotely-piloted multirotor crafts that usually fly at a speed of 

12 mph. The petitioner states that the UAS’s carry neither a pilot nor passenger and will 

operate within visual line of sight (VLOS) of a trained pilot(PIC) and visual observer 

(spotter) only over uninhabited areas (e.g. fields, wind farms etc.) and away from 

airports (i.e. three nautical miles or more) and populated areas.

Accordingly, Thone Drone LLC requests relief from Sections 91.405(a), 91.407(a)(1), 

91.409(a)(1) & (a)(2), and 91.417(a) & (b), as these sections set forth requirements for 

maintenance that only apply to aircraft with an airworthiness certificate. Thone Drone 

LLC submits that the requested relief is proper since an equivalent level of safety will be 

ensured. The petitioner states that given the size, weight, speed, and limited operating 

area associated with the aircraft and its operation, an exemption from 14 CFR part 21, 

Subpart H (Airworthiness Certificates), subject to certain conditions and limitations, is 

warranted and meets the requirements for an equivalent level of safety under 14 CFR 

part 11 and Section 333 of P.L. 112-95 (Section 333).

Thone Drone LLC will use experienced personnel or technicians to perform 

maintenance, alterations, or preventative maintenance on the UASs using the methods, 

techniques, and practices prescribed in the operating documents (i.e., Monthly 

Maintenance Log and corresponding Instruction Manuals). 

Furthermore, Thone Drone LLC will document and comply with all maintenance records 

for all owned and operated UASs. Relief from certain requirements of Section 61.113(a) 

and (b), entitled Private pilot privileges and limitations: Pilot in command(PIC), is 

requested by Thone Drone LLC to the extent necessary to allow a Pilot in Command 

(PIC) holding a sport pilot or higher level certificate, as well as an airman medical 

certificate, and who has met the minimum flight- hour requirements, that the PIC is able 

to safely operate the UASs in a manner consistent with this exemption, including 

evasive and emergency maneuvers and maintaining appropriate distances from people, 

vessels, vehicles and structures.

Thone Drone LLC seeks relief from Section 91.7(a), entitled Civil aircraft

airworthiness, because the UASs do not require an airworthiness certificate in 

accordance with 14 CFR Part 21, Subpart H. As such, Thone Drone LLC submits that 

they will ensure that the operated UASs are in an airworthy condition, prior to every 

flight, by determining that the UASs are in compliance with the operating documents

(i.e., Monthly Maintenance Log and corresponding Instruction Manual), and that the 

aircraft are in a condition for safe flight.
The petitioner further states that UAS operated without an airworthiness certificate in 

the restricted environment and under the conditions and limitations proposed by the 

petitioner will be at least as safe, or safer, than a conventional aircraft (fixed wing or 

rotorcraft) operating with an airworthiness certificate issued under 14 CFR part 21, 

Subpart H and not subject to the proposed conditions and limitations.

Thone Drone LLC also seeks an exemption from the requirements of Section

91.121, entitled Altimeter Settings, as the UAs will not have a typical barometric 

altimeter onboard. However, altitude information of the UAs will be provided to the PIC 

via Global Positioning System (GPS) equipment and radio communications telemetry 

data link, which downlinks from the UA to the GCS for active monitoring of the flight 

path. This altitude information, combined with Thone Drone LLC’s operation of the 

Yuneec tornado h920 and DJI Inspire 1 UASs within visual line of sight, at or below 500 

feet AGL, will ensure a level of safety equivalent to Section 91.121.

Thone Drone LLC also states that the UAS have or will have a host of onboard safety 

systems, including: a self-monitor function (diagnostic before takeoff); global positioning 

system (GPS) flight control system; lost link safety controls (hover, return to home and 

land); GPS warning/indicators; speed indicators.

Additionally, Thone Drone LLC seeks an exemption from the requirements of

Section 91.151(a), entitled Fuel requirements for flight in VFR conditions. Thone Drone 

LLC submits that safety will not be affected by operation of the UAs during daylight 

hours in visual meteorological conditions (VMC) under visual flight rules (VFR), with 

enough battery power to fly for a total duration of approximately 80% of battery life to

the point of intended landing and, assuming normal cruising speed, to fly after that for 

the remaining 20% of battery life. In accordance with 14 CFR § 11.81, Thone Drone 

LLC provides the following information in support of its petition for exemption:

Regarding Marking of the Aircraft (§ 45.23)

the petitioner states that even though the UAS’s will have no airworthiness certificate, 

an exemption is warranted because it has no entrance to the cabin, cockpit, or pilot 

station on which the required marking can be displayed and the size limitations of the 

UAS’s. Given the size of the UAV, two-inch lettering will be impossible. The word 

"experimental," may be placed on one of the rotor arms of each UAV, in compliance 

with §45.29 (f). The equivalent level of safety will be provided by having the UAVs 

marked on their rotor arm as required by §45.29 (f) where the pilot, observer and others 

working with the UAV will see the identification of the UAV as "experimental,". The FAA 

has issued the following exemptions to this regulation to Exemptions Nos. 10700, 8738, 

10167 and 10167A.

The Specific Sections Of 14 CFR From Which Thone Drone LLC Seeks

Exemption.

1. Thone Drone LLC Seeks Exemption From The Requirements Of Section

Part 21, Subpart H

14 CFR Part 21, Subpart H, establishes the procedural requirements for the issuance of 

airworthiness certificates as required by 14 CFR §91.203 (a) Except as provided in § 
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 §91.715 is displayed at the cabin or cockpit 

entrance so that it is legible to passengers or crew.

2. Thone Drone LLC Seeks Exemption From The Requirements Of Section

61.113(a) And (b).

Section 61.113, entitled Private pilot privileges and limitations: Pilot in command,

Sub sections (a) and (b) prescribe the following, in relevant part:

(a) No person who holds a private pilot certificate may act as a pilot in command (PIC) 

of an aircraft that is carrying passengers or property for compensation or hire; nor may 

that person, for compensation or hire, act as PIC of an aircraft.

(b) A private pilot may, for compensation or hire, act as PIC of an aircraft in connection 

with any business or employment if—

(1) The flight is only incidental to that business or employment; and

(2) The aircraft does not carry passengers or property for compensation or hire.

3. Thone Drone LLC Seeks Exemption From The Requirements Of Section 91.7(a).

Section 91.7, entitled Civil aircraft airworthiness, subsection (a), states the following:

(a) No person may operate a civil aircraft unless it is in an airworthy condition.

4. Thone Drone LLC Seeks Exemption From The Requirements Of Section 91.121.

Section 91.121, entitled Altimeter settings, subsection (a), states the following, in part:

(a) Each person operating an aircraft shall maintain the cruising altitude or flight level of 

that aircraft, as the case may be, by reference to an altimeter that is set, when 

operating--

(1) Below 18,000 feet MSL, to--

(i) The current reported altimeter setting of a station along the route and within 100 

nautical miles of the aircraft;

(ii) If there is no station within the area prescribed in paragraph (a)(1)(i) of this section, 

the current reported altimeter setting of an appropriate available station; or

(iii) In the case of an aircraft not equipped with a radio, the elevation of the departure 

airport or an appropriate altimeter setting available before departure.

5. Thone Drone LLC Seeks Exemption From The Requirements Of Section

91.151(a).

Section 91.151, entitled Fuel requirements for flight in VFR conditions, subsection 

(a), states the following:

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 batteries powering most UAV’s commercially used provide approximately 25 to 35 

minutes of powered flight. To meet the 30 minute reserve requirement in 14 CFR 

§91.151, UAV flights would be limited to approximately five (5) minutes in length. Given 

that this limitation would prohibit the flight of the UAV’s a longer time frame for flight in 

daylight or night VFR conditions is reasonable.
6. Thone Drone LLC Seeks Exemption From The Requirement Of Section

91.405(a).

Section 91.405, entitled Maintenance required, subsection (a), states the following: 

Each owner or operator of an aircraft—

(a) 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[.]

7. Thone Drone LLC Seeks Exemption From The Requirements Of Section

91.407(a)(1)

Section 91.407, entitled Operation after maintenance, preventive maintenance,

Re-building, or alteration, subsection (a) (1), states the following:

(a) No person may operate any aircraft that has undergone maintenance, preventive 

maintenance, rebuilding, or alteration unless--

(1) It has been approved for return to service by a person authorized under §43.7 of this 

chapter [.]

8. Thone Drone LLC Seeks Exemption From The Requirements Of Sections

91.409(a) (1) And 91.409(a)(2).

Section 91.409, entitled Inspections, subsection (a), states the following:

(a) Except as provided in paragraph (c) of this section, no person may operate an 

aircraft unless, within the preceding 12 calendar months, it has had --

(1) An annual inspection in accordance with part 43 of this chapter and has been 

approved for return to service by a person authorized by § 43.7 of this chapter; or

(2) An inspection for the issuance of an airworthiness certificate in accordance with part 

21 of this chapter.

9. Thone Drone LLC Seeks Exemption From The Requirements Of Sections

91.417(a) and 91.417(b).

Section 91.417, entitled maintenance inspections, subsections (a) and (b), state the 

following:

(a) Except for work performed in accordance with §§ 91.411 and 91.413, each 

registered owner or operator shall keep the following records for the periods specified in 

paragraph (b) of this section:

(1) Records of the maintenance, preventive maintenance, and alteration and records of 

the 100-hour, annual, progressive, and other required or approved inspections, as 

appropriate, for each aircraft (including the airframe) and each engine, propeller, rotor, 

and appliance of an aircraft. The records must include--

(i) A description (or reference to data acceptable to the Administrator) of the work 

performed; and

(ii) The date of completion of the work performed; and

(iii) The signature, and certificate number of the person approving the aircraft for return 

to service.

(2) Records containing the following information:

(i) The total time in service of the airframe, each engine, each propeller, and each rotor.

(ii) The current status of life-limited parts of each airframe, engine, propeller, rotor, and 

appliance.

(iii) The time since last overhaul of all items installed on the aircraft which are required 

to be overhauled on a specified time basis.
(iv) The current inspection status of the aircraft, including the time since the last 

inspection required by the inspection program under which the aircraft and its 

appliances are maintained.

(v) The current status of applicable airworthiness directives (AD) and safety directives 

including, for each, the method of compliance, the

AD or safety directive number and revision date. If the AD or safety directive involves 

recurring action, the time and date when the next action is required.

(vi) Copies of the forms prescribed by § 43.9(d) of this chapter for each major alteration 

to the airframe and currently installed engines, rotors, propellers, and appliances.

(b) The owner or operator shall retain the following records for the periods prescribed:

(1) The records specified in paragraph (a)(1) of this section shall be retained until the 

work is repeated or superseded by other work or for 1 year after the work is performed.

(2) The records specified in paragraph (a)(2) of this section shall be retained

and transferred with the aircraft at the time the aircraft is sold.

(3) A list of defects furnished to a registered owner or operator under § 43.11 of this 

chapter shall be retained until the defects are repaired and the aircraft is approved for 

return to service.

(4) Given that these sections and Part 43 apply only to aircraft with an airworthiness 

certificate, these sections will not apply.

EXTENT, REASON AND INTERESTS OF THE PETITIONER

Petitioner: Terry S. Thone., Owner/President of Thone Drone LLC, a Federally 

recognized LLC, with a Dun & Bradstreet #. It is my mission to provide my clients with 

expertise and knowledge in all aspects of picture, video & FLIR, as well as provide them 

with advanced technologies & solutions that will increase efficiency, productivity and 

effectiveness. Thone Drone LLC will provide clients with the highest quality digital 

content for use in their commercial, personal, and emergency related projects. Thone 

Drone LLC has 20 years of professional experience in photography, computers, server, 

networking and videography and has become recognized as an experienced operator in 

these fields. Thone Drone LLC’s operator is in the process of achieving a pilot’s license. 

The objective of Thone Drone LLC’s aerial video and photography operations is to 

provide high quality imaging for a variety of commercial, public, and residential uses, 

utilizing the FAA safety standards. Following are the targeted fields:

• Real Estate Videography and Photography

• Wedding Videography and Photography

• Land survey & appraisals

• Equipment Inspections

• Roof Inspections

• Construction sites before & after

• Precision Agriculture

• Tower inspections

• Search and Rescue Operations

• Emergency operations (fire and police)

1. Thone Drone LLC seeks exemption from the requirements of section part 21,
subpart H

Given the size and limited operating area associated with the UAS to be utilized by

Thone Drone 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 Federal Aviation Act (49 U.S.C.§ 44701(f)) and Section 333 of the Reform Act 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 rotorcraft operating with an airworthiness 

certificate without the restrictions and conditions of the proposed UAS operations.

2. Extent of relief Thone Drone LLC seeks and the reason Thone Drone LLC

seeks relief from section 61.113(a) and (b).

Relief from Section 61.113(a) and (b) entitled Private pilot privileges and limitations:

Pilot in command, is requested to the extent necessary to allow a PIC holding a private

pilot or higher level certificate, as well as a current and valid airman medical certificate,

and who has met certain flight-hour and currency requirements, to conduct the 

proposed UAS flight operations for compensation or hire. This relief is requested since 

the limitations set forth in Section 61.113(a) and (b) state that a private pilot may, for 

compensation or hire, act as PIC of an aircraft in connection with any business or 

employment if: (1) The flight is only incidental to that business or employment; and (2) 

The aircraft does not carry passengers or property for compensation or hire. As set 

forth more fully below, Thone Drone LLC submits that an equivalent level of safety will 

be maintained because no PIC will be allowed to operate the UAS unless that PIC has 

met certain flight-hour and currency requirements, demonstrating that the PIC is able to 

safely operate either the UAS in a manner consistent with the operations specifications 

as described in this exemption, including evasive and emergency maneuvers, as well as 

maintaining appropriate distances from people, vessels, vehicles and structures.

Further, Thone Drone LLC submits that all flights of the proposed UASs, conducted by 

the PIC pursuant to the grant of this Petition: (1) will be incidental to Thone Drone LLC' 

business; and (2) will not carry passengers or property for compensation or hire.

3. Extent of relief Thone Drone LLC seeks and the reason Thone Drone LLC seeks 

relief from section 91.7(a). Civil aircraft airworthiness

Relief from Section 91.7(a) entitled civil aircraft airworthiness, is requested to the 

extent

required to allow Thone Drone LLC to determine that the proposed UASs are in 

airworthy condition prior to every flight by ensuring that the UAS is in compliance with 

the operating documents (i.e., Aerial Operations Manual, Monthly Maintenance Log, 

and the proposed UAV’s Manuals). Thone Drone LLC seeks the requested relief 

because the proposed UASs do not require an airworthiness certificate in accordance 

with 14 CFR Part 21, Subpart H. Therefore, Thone Drone LLC will ensure that the 

proposed UASs are in airworthy condition based upon its compliance with the operating 

documents (i.e., Monthly Maintenance Log, and instruction manuals) prior to every 
flight, and further, determine that the aircraft are in condition for safe flight, as stated in 

the conditions and limitations below. Given the size of the aircraft and the requirements 

contained in the Manual for maintenance and use of safety check lists prior to each 

flight, an equivalent level of safety will be provided.

4. Extent of relief Thone Drone LLC seeks and the reason Thone Drone LLC seeks 

relief from section 91.121.

Relief from Section 91.121, entitled Altimeter settings, may be required to allow flight

operations of the proposed UASs, which utilize a barometric pressure sensor, GPS 

equipment, and a radio communications telemetry data link to downlink altitude 

information from the UA to the PIC at the ground control station (GCS). Since the FAA 

requires that any altitude information concerning UAS operations be reported to air 

traffic control (ATC) in feet above ground level (AGL), Thone Drone LLC seeks the 

requested relief because the proposed UA’s altimeter may be set on the ground to zero 

feet AGL, rather than the local barometric pressure or field altitude, before each flight. 

Considering the limited altitude of the proposed operations, relief from 14 CFR 91.121 is 

sought to the extent necessary to comply with the applicable conditions and limitations 

stated below. As more fully set forth herein, an equivalent level of safety will be 

maintained since the proposed UAs are equipped with a barometric pressure sensor 

and GPS equipment, which automatically ensures that a ground level pressure setting 

will be established prior to each flight, and provides the PIC with altitude information of 

the UA on the heads-up display of the GCS.

5. Extent Of Relief Thone Drone LLC Seeks And The Reason Thone Drone LLC

Seeks Relief From Section 91.151(b).

Relief from Section 91.151(b) entitled Fuel requirements for flight in VFR conditions, 

(a) No person may begin 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. (b) No person may begin a flight in a rotorcraft 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, to fly after that for at 

least 20 minutes. Thone Drone LLC seeks the requested relief because without an 

exemption from Section 91.151(b), the flight time duration of the battery powered UAs 

will severely constrain the practicality of any aerial video or still photo flight operations 

that Thone Drone LLC proposes to conduct pursuant to this Petition. The proposed 

UASs and Thone Drone LLC’s proposed operating limitations, ensure that Thone Drone 

LLC, will safely operate the battery powered UAs during daylight hours in visual 

meteorological conditions (VMC), under visual flight rules (VFR).

6. Extent Of Relief Thone Drone LLC Seeks And The Reason Thone Drone LLC

Seeks Relief From Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), And

91.417(a) & (b).

Since Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b) only

apply to aircraft with an airworthiness certificate, Thone Drone LLC requests relief from

these sections because the UASs do not require airworthiness certificates. As set forth 

more fully below. The UASs meet the conditions of FMRA Section 333 for operation 

without an airworthiness certificate. Accordingly, Thone Drone LLC will use trained 
technicians to perform maintenance, alterations, or preventive maintenance on the 

UASs using the methods, techniques, and practices prescribed in the UAS operating 

documents (i.e., the Thone Drone LLC Aerial Operations Manual, Monthly Maintenance 

Log, and proposed instruction manuals). Furthermore, Thone Drone LLC , will 

document and maintain all maintenance records for the proposed UASs.

The Reasons Why Granting Thone Drone LLC Request Would Be In The Public

Interest Of The Public As A Whole.

Granting the present Petition will further the public interest by allowing Thone Drone 

LLC, to safely, efficiently, and economically perform aerial video and photography of, 

real estate, wedding films, special events, precision agriculture, land survey & appraisal,

construction sites, equipment & roof inspections and landscape over certain areas of 

the United States. Additionally, use of the proposed UASs will decrease congestion of 

the NAS, reduce pollution, and provide significant benefits to the economy. Notably, the 

benefits of Thone Drone LLC’s proposed operation of the proposed UASs will be 

realized without implicating any privacy issues.

1. The Public Will Benefit From Decreased Congestion Of The NAS.

The proposed UAs are battery powered and serve as a safe, efficient, and economical 

alternative to the manned aircraft traditionally utilized to obtain aerial imagery. By 

reducing the amount and size of manned aircraft needed to perform aerial acquisitions, 

an exemption allowing the use of a UAS would reduce the amount of manned aircraft in 

the NAS, reduce noise and air pollution, as well as increase the safety of life and

property in the air and on the ground. Furthermore, by reducing the number of manned 

aircraft operating in the NAS, congestion around airports caused by arriving and 

departing aircraft will be reduced. The proposed UAs do not require an airport to takeoff 

or land. Likewise, a reduction of manned aircraft conducting aerial video and 

photography missions would result in fewer aircraft that must be handled by air traffic 

control during the ground, takeoff, departure, arrival, and landing phases of flight 

operations.

2. The Public Will Benefit From The Safety And Efficiency Of The Yuneec tornado 

h920 and DJI Inspire 1 UASs.

Conducting aerial acquisitions with the proposed UAS’s, instead of manned aircraft, will 

greatly benefit the public by drastically reducing the levels of air and noise pollution 

generated during traditional aerial video and still photography flight operations. By using 

battery power and electric motors, the proposed UASs produce no air pollution, and is 

the most viable environmentally conscious alternative to the cabin class, internal

combustion engine aircraft that are typically utilized for aerial video and photography, 

that burn approximately 20-30 gallons per hour of leaded aviation fuel. The UAs reduce

the carbon footprint of aerial acquisitions, also significantly reduce noise pollution, as 

the UAs are propelled by battery powered electric motors, rather than an internal 

combustion engine. By using the proposed UAS’s to perform aerial acquisitions, the 

substantial risk to life and property in the air and on the ground, which is usually 

associated with traditional manned aircraft flight operations, will be substantially 

reduced. Aside from the lack of manned aircraft, the UAs have considerably less 

physical potential for collateral damage to life and property on the ground, and in the air, 

compared to the manned aircraft that typically conduct similar operations.
3. Performing Aerial Video and Photography Operations With The UASs Will 

Benefit The Economy.

In addition to being safer and efficient, the UASs are also an economical alternative to 

using manned aircraft to conduct similar aerial operations. As such, operation of the 

UASs will allow United States based companies, like Thone Drone LLC, to remain

competitive and contribute to growth of the U.S. economy. Specifically, with the 

Environmental Protection Agency (“EPA”) regulatory actions phasing out leaded 

aviation fuels, U.S. owned and operated companies must adopt new and alternative 

technology in order to remain competitive. Operating the battery powered UASs is one 

such technology that not only allows companies greater operational flexibility compared 

to manned aircraft, but provides such flexibility without the high operational cost of a 

traditional manned aircraft.

4. There Are No Privacy Issues.

Similar to the manned aerial acquisition flight operations that have been conducted for

decades, Thone Drone LLC’s proposed operation of the UASs will not infringe on any 

privacy issues. Specifically, the UASs will be operated only in compliance with operating

documents (i.e., the Thone Drone LLC Aerial Operations Manual, Monthly Maintenance

Log, and Instruction Manual) which requires property owner involvement as well as local 

law enforcement notification, and in accordance with the Federal Aviation Regulations,

including the minimum altitude requirements of 14 CFR § 91.119 which establishes safe 

altitudes for operation of civil aircraft. Section 91.119(d) allowing 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 UAV that is a multi-rotor VTOL and the exemption requests 

authority to operate at altitudes up to 400 ft. AGL, or not more than 200 ft. above an 

elevated platform from which operations are planned, an exemption may be needed to 

allow such operations. As set forth herein, except for the limited conditions stated in the 

Manual, the UAV will never operate at higher than 400 ft. AGL. It will however be 

operated in a restricted area with security 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 UAVs as well as the location 

where they will be operated. No flight will be taken without the permission of the 

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

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

planned flight operations as set forth in the Manual. Compared to flight operations with 

aircraft or rotorcraft weighting far more than the maximum 55 lbs. 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 400 ft. AGL in 

the power generation industry. In addition, the low-altitude operations of the UAVs will 

ensure separation between these small UAV operations and the operations of 

conventional aircraft that must comply with Section 91.119.

E. The Reasons Why Granting The Exemption Would Not Adversely Affect Safety,

Or How The Exemption Would Provide A Level Of Safety At Least Equal To That

Provided By The Rule From Which Thone Drone LLC Seeks Exemption.
1. Reasons Why The UAs Meet The Conditions Of The FAA Modernization and 

Reform Act of 2012 (FMRA) Section 333.

In consideration of the size, weight, speed, and limited operating area associated with 

the unmanned aircraft and its operation, Thone Drone LLC’s operation of the UAS’s 

meet the conditions of FMRA Section 333, and will not require an airworthiness 

certificate in accordance with 14 CFR Part 21, Subpart H. Section 333 provides 

authority for a UAS to operate without airworthiness certification and sets forth 

requirements for considering whether a UAS will create a hazard to users of the NAS or 

the public, or otherwise pose a threat to national security. Specifically, FMRA Section 

333 states the following, in part: (a) In General.--Notwithstanding any other requirement 

of this subtitle, and not later than 180 days after the date of enactment of this Act, the 

Secretary of Transportation shall determine if certain unmanned aircraft systems may

operate safely in the national airspace system before completion of the plan and 

rulemaking required by section 332 of this Act or the guidance required by section 334 

of this Act. (b) Assessment of Unmanned Aircraft Systems.--In making the 

determination under subsection (a), the Secretary shall determine, at a minimum--

(1) which types of unmanned aircraft systems, if any, as a result of their size, weight, 

speed, operational capability, proximity to airports and populated areas, and operation 

within visual line of sight do not create a hazard to users of the national airspace system 

or the public or pose a threat to national security; and

(2) whether a certificate of waiver, certificate of authorization, or airworthiness 

certification under section 44704 of title 49, United States Code, is required for the

operation of unmanned aircraft systems identified under paragraph (1).

(c) Requirements for Safe Operation.--If the Secretary determines under this section 

that certain unmanned aircraft systems may operate safely in the national airspace 

system, the Secretary shall establish requirements for the safe operation of such aircraft 

systems in the national airspace system. In seeking this exemption, Thone Drone LLC 

submits that the proposed UASs can operate safely in the NAS pursuant to FMRA 

Section 333, as demonstrated by: (a) the characteristics of the proposed UASs; (b) the 

pilot certification requirement; and (c) the specific operating limitations.

a. The Specifications Of The Proposed UASs Demonstrate Its Safe 

Characteristics.

The proposed UASs do not create a hazard to users of the NAS or the public, or 

otherwise pose a threat to national security considering its size, weight, speed, and 

operational capability.

i. Technical Specifications Of The Proposed UASs.

The technical specifications of the proposed UASs are set forth by the proposed 

Specifications and Data Sheet, attached hereto as Exhibit A and B.

ii. The Proposed UASs Autonomous Flight And Navigation Modes Enable The 

UASs To Remain Within A Defined Operational Area.

The proposed UASs may be operated in both manual and fully autonomous flight 

modes. A complete description of the flight and navigational modes of the proposed 

UASs are provided below via internet hyperlinks.

iii. The UASs Are Designed For Automatic Return To Home Point Or Hover In The 

Event Of Loss Of The Control Link Or Navigation.
When the Control Link is lost, the UAs will remain stationary, in flight, for 3 seconds or 

more. If, after 3 seconds, the UAs do not reacquire control link data from the GCS, the 

UAs will assume that the Control Link is lost and the UAs will return to the home 

position (i.e., failsafe mode) via GPS, and will descend to the takeoff position and 

shutdown. A complete description of the Failsafe Functions for the UAS are set forth at 

User Manual.

iv. The GCS And Its Operation.

A complete description of the operation and specifications of the GCS and flight control 

software is provided via the User Manuals and are attached.

b. Flight Operations Of The UASs Are Limited To The Line Of Sight Of A

Certificated Pilot in Command With A Safety Observer.

Thone Drone LLC will only utilize certified pilots who possess a current and valid airman 

medical certificate to act as a pilot in command (PIC) of the UASs. Additionally, a safety 

observer will assist all pilots during flight time.

c. Flights Of The UASs Will Be Conducted Pursuant To Specific Operating 

Limitations.

In seeking this exemption, Thone Drone LLC proposes to commercially operate 

UASs for the special purpose of conducting aerial video and photography over certain 

areas of United States, pursuant to the following specific operating limitations:

1. Operations authorized by this grant of exemption will be limited to the following 

aircraft described in the operating documents, rotorcraft UASs weighing less than 55

pounds maximum gross weight.

 Proposed operations of any other aircraft will require a new petition or a petition 

to amend this grant.

2. UAS operations under this exemption will be limited to conducting operations for the

purpose of aerial video and photography.

3. The UAs may not be flown at an indicated airspeed exceeding 20 knots.

4. The UA must be operated at an altitude of no more than 500 feet above ground level

(AGL), as indicated by the procedures specified in the operating documents unless a

special request is made and approved by ATC. All altitudes reported to ATC must be in

feet AGL.

5. The UAs must be operated within visual line of sight (VLOS) of the PIC 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 FAA-issued airman medical certificate.

6. The use of first person view (FPV) by the PIC or safety observer (SO) is not 

permitted.

7. All operations must utilize a safety observer (SO). The SO may be used to satisfy the

VLOS requirement as long as the PIC always maintains VLOS capability. The SO and

PIC must be able to communicate verbally at all times. 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 SO can perform the functions prescribed in the operating documents.

8. The SO must not perform any other duties beyond assisting the PIC with seeing and

avoiding other air traffic and other ground based obstacles/obstructions and is not 

permitted to operate the camera or other instruments.

9. The operating documents and the grant of exemption must be accessible during UAS
operations and made available to the Administrator upon request. If a discrepancy 

exists between the conditions and limitations contained in the grant of exemption and 

the procedures outlined in the operating documents, the conditions and limitations 

contained in the grant of exemption take precedence and must be followed. Otherwise, 

the operator must follow the procedures as outlined in its operating documents. The 

operator may update or revise its operating documents. It is the operator’s responsibility 

to track such revisions and present updated and revised documents to the Administrator 

upon request. The operator must also present updated and revised documents if it 

petitions for extension or amendment to the grant of exemption. If the operator 

determines that any update or revision would affect the basis upon which the FAA 

granted the exemption, then the operator must petition for amendment to its grant of 

exemption. The FAA’s UAS Integration Office (AFS-80) may be contacted if questions 

arise regarding updates or revisions to the operating documents.

10. Prior to each flight the PIC must inspect the UAS to ensure that it is in a condition 

for safe flight. If the 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. The Ground Control

Station must be included in the preflight inspection. The PIC will take all actions including 

reviewing weather, flight battery requirements, landing and takeoff distances and aircraft 

performance data before initiation of flight. All maintenance and alterations must be 

properly documented in the aircraft records.

11. 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. The PIC who conducts the functional test flight must 

make an entry in the aircraft records.

12. The pre-flight inspection must account for all potential discrepancies, e.g. inoperable

components, items, or equipment, not already covered in the relevant sections of the

operating documents.

13. The operator must follow the UAS manufacturer’s aircraft/component, maintenance,

overhaul, replacement, inspection, and life limit requirements.

14. The operator must carry out its maintenance, inspections, and record keeping

requirements, in accordance with the operating documents. Maintenance, inspection,

alterations, and status of replacement/overhaul component parts must be noted in the

aircraft records, including total time in service, description of work accomplished, and 

the signature of the authorized person returning the UAS to service.

15. Each UASs operated under this exemption must comply with all manufacturer 

Safety Bulletins.

16. The authorized person must make an entry in the aircraft record of the corrective

action taken against discrepancies discovered between inspections.

17. The PIC must possess at least a private pilot certificate and at least a current third

class medical certificate.

18. The operator may not permit any PIC to operate unless the PIC meets the 

operator’s qualification criteria and demonstrates the ability to safely operate the UAS in 

a manner consistent with how the UAS will be operated under the exemption, including 

evasive and emergency maneuvers and maintaining appropriate distances from 

persons, vessels, vehicles and structures. PIC qualification flight hours must be logged 
in a manner consistent with 14 CFR § 61.51(b). Flights for the purposes of training the 

operator’s PICs are permitted under the terms of the 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 UA with appropriate 

distance from nonparticipants in accordance with 14 CFR § 91.119.

19. UAS operations may not be conducted during night, as defined in 14 CFR § 1.1. All 

operations must be conducted under visual meteorological conditions (VMC). If flight at 

night is required, a special request will be made at the FAA office closest to proposed 

area of operations. Flights under special visual flight rules (SVFR) are not authorized.

20. The UA may not operate within 5 nautical miles of an airport reference point as

denoted on a current FAA-published aeronautical chart unless a letter of agreement 

with that airport’s management is obtained, and the operation is conducted in 

accordance with a NOTAM as required by the operator’s COA. The letter of agreement 

with the airport management must be made available to the Administrator upon request.

21. The UA may not be operated less than 500 feet below or less than 2,000 feet

horizontally from a cloud or when visibility is less than 3 statute miles from the PIC.

22. If the UA loses communications or loses its GPS signal, it must return to a 

predetermined location within the planned operating area and land or be recovered in

accordance with the operating documents.

23. The PIC must abort the flight in the event of unpredicted obstacles or emergencies 

in accordance with the operating documents.

24. The PIC is prohibited from beginning a flight unless (considering wind and forecast

weather conditions) there is enough power to fly at normal cruising speed to the 

intended landing point and land the UA with 25% battery power remaining.

25. The operator must obtain an Air Traffic Organization (ATO) issued Certificate of

Waiver or Authorization (COA) prior to conducting any operations under the grant of

exemption. This COA will also require the operator to request a Notice to Airman

(NOTAM) not more than 72 hours in advance, but not less than 48 hours prior to the

operation. All operations shall be conducted in accordance with airspace requirements 

in the ATO issued COA including class of airspace, altitude level and potential 

transponder requirements.

26. All aircraft operated in accordance with the exemption must be identified by serial

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

(NNumber) markings in accordance with 14 CFR part 45, Subpart C. Markings must be 

as large as practicable.

27. Before conducting operations, the radio frequency spectrum used for operation and

control of the UA must comply with the Federal Communications Commission (FCC) or

other appropriate government oversight agency requirements.

28. The documents required fewer than 14 CFR 91.9 and 91.203 must be available to

the PIC at the Ground Control Station of the UAS any time the UAS is operating. These

documents must be made available to the Administrator or any law enforcement official

upon request.

29. The UA must remain clear and yield the right of way to all manned aviation

operations and activities at all times.

30. The UAS may not be operated by the PIC from any moving device or vehicle.
31. Flight operations must be conducted at least 500 feet from all nonparticipating

persons (persons other than the PIC, SO, operator trainees or essential persons), 

vessels, vehicles, and structures unless:

a. Barriers or structures are present that sufficiently protect nonparticipating persons 

from the UA and/or debris in the event of an accident. The operator must ensure that

non-participating persons remain under such protection. If a situation arises where

non-participating persons leave such protection and are within 500 feet of the UA, flight

operations must cease immediately and/or;

b. The aircraft is operated near vessels, vehicles or structures where the 

owner/controller of such vessels, vehicles or structures has granted permission and the 

PIC has made a safety assessment of the risk of operating closer to those objects and 

determined that it does not present an undue hazard, and; c. Operations nearer to the 

PIC, SO, operator trainees or essential persons do not present an undue hazard to 

those persons per § 91.119(a).

32. All operations shall be conducted over private or controlled-access property with

permission from the land owner/controller or authorized representative. Permission from

land owner/controller or authorized representative will be obtained for each flight to be

conducted.

33. 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.

Reasons Why An Exemption From The Requirements Of Section 61.113(a) And

(b) Would Not Adversely Affect Safety.

Thone Drone LLC submits that the equivalent level of safety established by

Section 61.113(a) and (b) will be maintained because no PIC will be allowed to operate

the UASs unless that PIC has demonstrated, by meeting minimum flight-hour and 

currency requirements, that the PIC is able to safely operate the Yuneec tornado h920

or DJI Inspire 1 UAS in a manner consistent with the exemption, including evasive and 

emergency maneuvers and maintaining appropriate distances from people, vessels, 

vehicles and structures. Considering Thone Drone LLC’s proposed area of operations, 

and the operating limitations set forth-above; the parallel nature of private pilot 

aeronautical knowledge requirements to those of commercial pilot requirements (See 

Exemption No. 11062); and the airmanship skills necessary to safely operate the UAS, 

Thone Drone LLC submits that the additional manned airmanship experience of a 

commercially certificated pilot would not correlate to the airmanship skills necessary for 

Thone Drone LLC’s specific proposed flight operations. The FAA has previously granted 

relief from Section 61.113(a) and (b) specific to UAS, in circumstances similar, in all 

material respects, to those presented herein (e.g. Exemption Nos. 11062, 11063, 

11064, 11065, 11066, 11067, 11080, 11109, 11110, 11112, 11136, 11138, 11150, 

11153, 11156, 11158, 11159, 11160, 11161). Thone Drone LLC will not allow any PIC 

to operate the UAS unless that PIC has demonstrated, by meeting minimum flight-hour 

requirements or UAS training and currency requirements, that the PIC is able to safely 

operate the UAS in a manner consistent with this exemption, including evasive and 

emergency maneuvers and maintaining appropriate distances from people, vessels, 
vehicles and structures. Specifically, the PIC must have accumulated and logged, in a 

manner consistent with 14 CFR § 61.51(b), 25 hours of total time as a UAS rotorcraft 

pilot (with a minimum of 5 hours of those hours as a UAS pilot operating the same make 

and model of UAS to be used for operations under the exemption). In addition to the 

hour requirements, the PIC must accomplish 3 takeoffs and landings in the preceding 

90 days (for currency purposes). As in Exemption Nos. 11062, 11138, and 11153, prior 

documented flight experience that was obtained in compliance with applicable 

regulations will ensure an equivalent level of safety during Thone Drone LLC’ proposed 

operations. The Administrator has held that prior documented flight experience that was 

obtained in compliance with applicable regulations would ensure safe operations, 

stating as follows: In Exemption No. 11062, the FAA required that prior to conducting 

operations for the purpose of motion picture filming (or similar operations), the PIC must 

have accumulated and logged, in a manner consistent with 14 CFR 61.51(b), 25 hours 

of total time as a UAS rotorcraft pilot including at least 10 hours logged as a UAS pilot 

with a multi-rotor UAS. Prior to operations under Exemption No. 11062, the PIC must 

also have accumulated and logged a minimum of 5 hours as a UAS pilot operating the 

same make and model of UAS to be used for operations under the exemption. For 

clarification, the FAA considers these minimum hour requirements to be inclusive rather 

than additive; i.e. 5 hours make and model time may be included in the 10 hours of 

multi-rotor time and the 10 hours may be included in the total 25 hours of UAS rotorcraft 

time. In addition to the hour requirements, the PIC must accomplish 3 takeoffs and 

landings in the preceding 90 days (for currency purposes). The FAA finds that at a 

minimum, the flight-hour requirements in Exemption No. 11062 are appropriate to 

practice and build proficiency in the skills necessary to safely conduct the petitioner’s 

proposed operations. The FAA also finds that prior documented flight experience that 

was obtained in compliance with applicable regulations would satisfy this requirement. 

Training, proficiency, and experience-building flights can also be conducted under the 

grant of exemption to accomplish the required flight time. During training, proficiency, 

and experience-building flights the PIC is required to operate the UA with appropriate 

distances in accordance with 14 C.F.R 91.119. Exemption No. 11138 at page 15.

Accordingly, Thone Drone LLC will ensure safe operations by not allowing any PIC to 

operate the proposed UAS unless that PIC has demonstrated, by meeting minimum 

flight-hour and currency requirements, that the PIC is able to safely operate the 

proposed UAS in a manner consistent with the exemption, including evasive and 

emergency maneuvers and maintaining appropriate distances from people, vessels, 

vehicles and structures.

3. Reasons Why An Exemption From The Requirements Of Section 91.7(a)

Would Not Adversely Affect Safety.

The equivalent level of safety established by Section 91.7(a) will be maintained because 

prior to every flight, Thone Drone LLC will ensure that the proposed UAS is in an 

airworthy condition based upon the UAS’s compliance with its operating documents and 

as stated in the conditions and limitations herein. Additionally, the FAA has previously 

granted relief from Section 91.7(a) specific to UAS, in circumstances similar, in all 

material respects, to those presented herein (e.g. Exemption Nos. 11062, 11063, 

11064, 11065, 11066, 11067, 11080, 11109, 11110, 11112, 11136, 11138, 11150, 

11153, 11156, 11157, 11158, 11159, 11160, 11161).
4. Reasons Why An Exemption From The Requirements Of Section 91.121 Would

Not Adversely Affect Safety.

The equivalent level of safety established by Section 91.121 will be maintained

because the altitude information of the proposed UAs will be provided to the PIC via 

GPS equipment and a radio communications telemetry data link, which downlinks from 

the UA to the GCS for active monitoring of the flight path and altitude. This altitude 

information, combined with Thone Drone LLC’ operation of the UAs within visual line of 

sight, at or below 500 feet AGL, will ensure a level of safety equivalent to Section 

91.121. The altitude information will be generated by GPS equipment installed onboard 

the aircraft.

Prior to each flight, a zero altitude initiation point is automatically established by the

UASs at ground level. The FAA has previously granted relief from Section 91.121 

specific to UAS, in circumstances similar, in all material respects, to those presented 

herein (e.g. Exemption Nos. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 

11109, 11112, 11136, 11138, 11150, 11153, 11156, 11157, 11158, 11159, 11160, 

11161).

5. Reasons Why An Exemption From The Requirements Of Section 91.151(a)

Would Not Adversely Affect Safety.

A grant of this exemption would ensure an equivalent level of safety established

by 14 CFR Section 91.151(a) as a result of (1) the technical specifications of the UASs; 

(2) the limitations on the proposed flight operations; and (3) the location of the proposed 

flight operations. Accordingly, Thone Drone LLC will ensure that it will safely operate the 

battery powered UAs during daylight hours in VFR conditions, with enough battery 

power to fly for a total duration of 13.5 minutes to the first point of intended landing and, 

assuming normal cruising speed, to fly after that for at least 4.5 minutes. Here, as in 

Exemption No. 11109, the technical specifications of the DJI Yuneec h920 Tornado 

and DJI Inspire 1 UASs; the limitations on the proposed flight operations; and the 

location of the proposed operations, will ensure an equivalent level of safety established 

by 14 CFR Section 91.151(a). Furthermore, safety will be ensured as the proposed

UASs provide audible and visual warnings to the PIC at the GCS when the UAs 

experiences low battery voltage, the first warning occurring at approximately 33% 

remaining battery power, and again at approximately 10% remaining battery power. At 

the critically low battery level, the proposed UASs will descend and land automatically. 

Significantly, previous exemptions granted by the FAA concerning Section 91.151 

establish that safety is not adversely affected when the technical characteristics and 

operating limitations of the UAS are considered. Relief has been granted for manned 

aircraft to operate at less than the minimums prescribed in Section 91.151, including 

Exemption Nos. 2689, 5745, and 10650. Moreover, the FAA has previously granted 

relief from Section 91.151 specific to UAS, in circumstances similar, in all material 

respects, to those presented herein (e.g. Exemption Nos. 8811, 10808, 10673, 11042, 

11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 11136, 11138, 

11150, 11153, 11156, 11157, 11158, 11159, 11160, 11161).

6. Reasons Why An Exemption From The Requirements Of Sections 91.405(a),

91.407(a)(1), 91.409(a)(1) & (a)(2), And 91.417(a) & (b) Would Not Adversely Affect

Safety.
In seeking this exemption, Thone Drone LLC submits that the equivalent level of

safety with regard to the regulatory maintenance and alteration requirements 

established by Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & 

(b) will be met because Thone Drone LLC will use trained technicians to perform 

maintenance, alterations, or preventive maintenance on the UASs using the methods, 

techniques, and practices prescribed in the operating documents (i.e., the Thone Drone 

LLC Aerial Operations Manual, Monthly Maintenance Log, and Instruction Manuals). 

Furthermore, Thone Drone LLC will document and maintain all maintenance records for 

the proposed UASs. Since the proposed UASs will be inspected as prescribed by the 

operating documents, Thone Drone LLC will maintain the equivalent level of safety 

established by Sections 91.405(a), 91.409(a)(1), and 91.409(a)(2). A copy of the 

proposed User Manuals are attached hereto as Exhibit C and D; a copy of the UAS 

Maintenance LOG is attached hereto as Exhibit E. Likewise, the exemption sought will 

not adversely affect safety because Thone Drone LLC will use trained technicians to 

perform maintenance, alterations or preventive maintenance on the UAS using the 

methods, techniques, and practices prescribed by the operating documents. 

Furthermore, the exemption sought would maintain an equivalent level of safety 

established by Sections 91.407, 91.417(a) and 91.417(b), because all maintenance of 

the proposed UASs will be performed by trained technicians. Maintenance will be 

documented and maintained utilizing the monthly maintenance log. Significantly, 

previous exemptions granted by the FAA concerning Sections 91.405(a), 91.407(a)(1), 

91.409(a)(1) & (a)(2), and 91.417(a) & (b) establish that safety is not adversely affected 

when the technical characteristics and operating limitations of the UAS are considered.

In consideration of Thone Drone LLC’s proposed operating limitations, the operating 

documents, and the technical aspects of the Yuneec tornado h920 and DJI Inspire 1 

UAS’s, Thone Drone LLC submits that safety will not be adversely affected by granting 

exemption from 14 CFR Sections 91.405(a), 91.407(a)(1) and (a)(2), 91.409(a)(2), and 

91.417(a) and (b). The FAA has previously granted relief specific to UAS in 

circumstances similar, in all material respects, to those presented herein (e.g. 

Exemption Nos. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 

11112, 11136, 11138, 11150, 11153, 11156, 11157, 11158, 11159, 11160, 11161).

7. The FAA May Prescribe Any Other Conditions For Safe Operation.

In accordance with Section 333 of the FAA Modernization and Reform Act of

2012 (FMRA) and 14 CFR § 21.16 entitled Special Conditions, Thone Drone LLC 

requests that the FAA prescribe special conditions for the intended operation of the DJI

and DJI Inspire 1 UASs, which contain such safety standards that the Administrator 

finds necessary to establish a level of safety equivalent to that established by 14 CFR

Part 21, Subpart H, and 14 C.F.R §§ 61.113(a) & (b), 91.7 (a), 91.121, 91.151(b), 

91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b). Such special 

conditions will permit safe operation of the UAs for the limited purpose of conducting 

aerial video and photography over certain areas of the United States for compensation 

or hire. FMRA Section 333 sets forth the requirements for considering whether a UAS 

will create a hazard to users of the NAS or the public, or otherwise pose a threat to 

national security; and further, provides the authority for such UAS to operate without 

airworthiness certification in accordance with any requirements that must be established 

for the safe operation of the UAS in the NAS. Likewise, the Administrator may prescribe 
special conditions pursuant to 14 CFR § 21.16, for operation of the Yuneec tornado 

h920 and DJI Inspire 1 UASs, since the airworthiness regulations of 14 CFR Part 21 do 

not contain adequate or appropriate safety standards, due to the novel or unusual 

design features of the aircraft. Section 21.16, entitled Special Conditions, states the 

following: If the FAA finds that the airworthiness regulations of this subchapter do not 

contain adequate or appropriate safety standards for an aircraft, aircraft engine, or 

propeller because of a novel or unusual design feature of the aircraft, aircraft engine or 

propeller, he prescribes special conditions and amendments thereto for the product. 

The special conditions are issued in accordance with Part 11 of this chapter and contain 

such safety standards for the aircraft, aircraft engine or propeller as the FAA finds 

necessary to establish a level of safety equivalent to that established in the regulations. 

See 14 CFR § 21.16. Therefore, in accordance with FMRA Section 333 and 14 CFR § 

21.16, the FAA may prescribe special conditions for Leading Edge’s intended operation 

of the Yuneec tornado h920 and DJI Inspire 1 UASs, which contain such safety 

standards that the Administrator finds necessary to establish a level of safety equivalent 

to that established by 14 CFR Part 21, Subpart H, and 14 C.F.R Sections 61.113(a) & 

(b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 

91.417(a) & (b).

SUMMARY

Thone Drone LLC seeks exemption from the requirements of 14 C.F.R §§ 45.23

61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) &

(a)(2), and 91.417(a) & (b), as well as the restricted category airworthiness certification 

standards specified in 14 C.F.R. § 21.185, including the requirement to have a 

certificate of airworthiness as contemplated by 14 C.F.R. Part 21 and to operate an 

Unmanned Aircraft System pursuant to Section 333 of the FAA Modernization and 

Reform Act of 2012 (FMRA). This exemption will permit Thone Drone LLC to operate an 

Unmanned Aircraft System (UAS) for the

commercial purpose of conducting aerial video and photography for the latter:

1) real estate photography

2) wedding videography/special events

3) Tower inspection(cell, wind, water and power)

4) Civil inspection I.E. bridges etc

5) Agricultural inspection including grain elevators, land and crops

6) Construction sites including cranes

7) Ski lifts

8) Roof tops

9) Firefighting and Police reconnaissance (Rock county Fire Chief and Sheriff have 

been notified of the request for 333 exemption)

A Brief Description Of The Nature Of The Exemption Thone Drone LLC Seeks:

This exemption will permit Thone Drone LLC to commercially operate an Unmanned

Aircraft System (UAS) for the purpose of conducting aerial video and photography over

certain areas of the United States.
Any Additional Information, Views, Or Arguments Available To Support Thone 

Drone LLC’s Request.

This Petition is made pursuant to the FAA Modernization and Reform Act of 2012

(FMRA) Section 333, which directs the Secretary of Transportation to determine if 

certain UAS may operate safely in the NAS. As such, Thone Drone LLC’s request for

exemption may be granted pursuant to the authority of FMRA Section 333 and 14 CFR

Part 11, as set forth above. FMRA Section 333 sets forth the requirements for 

considering whether a UAS will create a hazard to users of the NAS or the public, or 

otherwise pose a threat to national security; and further, provides the authority for such 

UAS to operate without airworthiness certification. As discussed in detail above, Thone 

Drone LLC will operate the UASs safely in the NAS, without creating a hazard to users 

of the NAS, or the public, or otherwise pose a threat to national security. It is our 

intention to be cognizant of the FAA regulations in the controlled area we operate in and 

to be aware of visual and audio surroundings especially manned aircraft. Thone Drone 

LLC states the following conditions will be observed in support of its ability to provide at 

least an equal level of safety or no adverse safety effect to persons or property in the air 

or on the ground!

Below to manuals for the proposed UAS.

YUNEEC TORNADO H920 Manufacturer’s User Manual

User manual can be found at:

http://www.yuneec.com/download/manuals/TORNADO-H920-User-Manual-A5-(NOSONY7)-20151019.pdf

DJI Inspire 1 Manufacturer’s User Manual

User manual can be found at:

https://dl.djicdn.com/downloads/inspire_1/en/Inspire%20_1_User_Manual__V1.8.pdf

DJI S1000+ Manufacturer’s User Manual

User manual can be found at:

http://dl.djicdn.com/downloads/s1000_plus/en/S1000_Plus_User_Manual_v1.2_en.pdf
The following are the included attachments.

1-PACKING CHECKLIST................................................................................1

2-PREFLIGHT CHECKLIST ............................................................................2

3- FLIGHT CARD ..........................................................................................3

4- POSTFLIGHT CHECKLIST...........................................................................4

5- ACCIDENT REPORT...................................................................................5

Signature

Submitted on 12/15/2015

Thone Drone LLC 

Terry S. Thone, President/Owner/Operator

309 E Lincoln

Luverne, MN 56156

507-449-4646

Email: info@thonedrone.com