Commercial Drone Services LLC

Jonathan J Pascua

222 Raccoon Run RD 

Coventry, RI 02816 CommercialDroneServicesLLC@gmail.com 

January 19, 2016 

U. S. Department of Transportation Docket Management System

1200 New Jersey Ave., SE Washington, DC 20590 

Re: Exemption Request Section 333 of the FAA Reform Act and Part 

11 of the Federal Aviation Regulations from 14 C.F.R. 45.23(b);14 

CFR Part 21;14 CFR 61.113 (a) & (b); 91.7 (a);91.9 (b) (2);91.103(b); 

91.109;91.119; 91.121; 91.151(a);91.203(a) & (b);91.405 (a); 

91.407(a) (1); 91.409 (a) (2);91.417 (a) & (b). 

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, Commercial Drone 

Services LLC, developer and operator of Small Unmanned Aircraft 

Systems (“sUASs”) equipped to conduct aerial electronic data 

collection c and aerial photography, videography for the use of real 

estate marketing, infrastructure inspection, news gathering, 

cinematography, advertising, agricultural inspection, landmark 

photography, environmental photography and inspection, search and 

rescue, fire and rescue operations and training hereby applies for an 

exemption from the listed Federal Aviation Regulations (“FARs”) to 

allow commercial operation of its sUASs, so long as such operations 

are conducted within and under the conditions outlined herein or as 

may be established by the FAA as required by Section 333. 

As described more fully below, the requested exemption would permit 

the operation of small, unmanned and relatively inexpensive sUAS 

under controlled conditions in airspace that is 1) limited 2) 

predetermined 3) controlled as to access and 4) would provide safety 

enhancements to the already safe operations in the aerial filming and 

monitoring 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.” Section 333(c) of the 

Reform Act. 

(

c Aerial Data Collection” which includes any remote sensing and measuring by an instrument(s) aboard the UA. Examples include 

imagery (photography, video, infrared, etc.), electronic measurement (precision surveying, RF analysis, etc.), chemical 

measurement (particulate measurement, etc.), or any other gathering of data by instruments aboard the UA )

The name and address of the applicant is:

Commercial Drone Services LLC

Jonathan J Pascua

Ph: 401-598-7562

Email: CommercialDroneServicesLLC@gmail.com

Address: 222 Raccoon Run Rd Coventry, RI 02816 

Regulations from which the exemption is requested: 

14 CFR Part 21

14 C.F.R. 45.23(b)

14 CFR 61.113 (a) & (b) 14 C.F.R. 91.7 (a)

14 CFR 91.9 (b) (2)

14 C.F.R. 91.103

14 C.F.R. 91.109

14 C.F. R. 91.119

14 C.F.R. 91.121

14 CFR 91.151 (a)

14 CFR 91.203 (a) & (b) 14 CFR 91.405 (a)

14 CFR 407 (a) (1)

14 CFR 409 (a) (2)

14 CFR 417 (a) & (b) 
This exemption application is expressly submitted to fulfill Congress’ 

goal in passing Section 333(a) through (c) of the Reform Act. This law 

directs the Secretary of Transportation to consider whether certain 

unmanned aircraft systems may operate safely in the national 

airspace system (NAS) before completion of the rulemaking required 

under Section 332 of the Reform Act. In making this determination, the 

Secretary is required to determine which types of sUASs do not create 

a hazard to users of the NAS or the public or pose a threat to national 

security in light of the following: 

• The sUAS’s size, weight, speed, and operational capability;

• Operation of the sUAS in close proximity to airports and populated 

areas • Operation of the sUAS within visual line of sight of the 

operator. 

A Applicant interprets this provision to place the duty on the Administrator to not only 

process applications for exemptions under section 333, but for the Administrator to craft 

conditions for the safe operation of the sUAS, if it should be determined that the 

conditions set forth herein do not fulfill the statutory requirements for approval. 

The Federal Aviation Act expressly grants the FAA the authority to 

issue exemptions. This statutory authority by its terms includes 

exempting civil aircraft, as the term is defined under §40101 of the Act, 

that includes sUASs, from the requirement that all civil aircraft must 

have a current airworthiness certificate. 

The Administrator may grant an exemption from a requirement of a 

regulation prescribed under subsection (a) or (b) of this section or any 

sections 44702-44716 of this title if the Administrator finds the 

exemption in the public interest. 49 U.S.C. §44701(f) See also 49 USC 

§44711(a); 49 USC §44704; 14 CFR §91.203 (a) (1). 

Commercial Drone Services sUASs are rotorcraft, weighting 55 or 

fewer lbs. including payload. They operate, under normal conditions at 

a speed of no more than 50 knots and have the capability to hover, 
and move in the vertical and horizontal plane simultaneously. They will 

operate only in line of sight and will operate only within the sterile area 

described in the Flight Safety Manual, attached as Exhibit B 

(hereinafter “the Manual”). Such operations will insure that the sUAS 

will “not create a hazard to users of the national airspace system or 

the public.” B 

Given the small size of the sUASs involved and the restricted sterile 

environment within which they will operate, the applicant falls squarely 

within that zone of safety (an equivalent level of safety) in which 

Congress envisioned that the FAA must, by exemption, allow 

commercial operations of UASs to commence immediately. Also due 

to the size of the sUASs and the restricted areas in which the relevant 

sUASs will operate, approval of the application presents no national 

security issue. Given the clear direction in Section 333 of the Reform 

Act, the authority contained in the Federal Aviation Act, as amended; 

the strong equivalent level of safety surrounding the proposed 

operations, and the significant public benefit, including enhanced 

safety, reduction in environmental impacts, including reduced 

emissions associated with allowing sUASs for commercial video 

operations, the grant of the requested exemptions is in the public 

interest. Accordingly, the applicant respectfully requests that the FAA 

grant the requested exemption without delay. 

AIRCRAFT AND EQUIVALENT LEVEL OF SAFETY 

The applicant proposes that the exemption requested herein apply to 

civil aircraft that have the characteristics and that operate with the 

limitations listed herein. These limitations provide for at least an 

equivalent or even higher level of safety to operations under the 

current regulatory structure because the proposed operations 

represent a safety enhancement to the already safe commercial video 

filming operations conducted with conventional aircraft. 
These limitations and conditions to which Commercial Drone Services 

LLC agrees to be bound when conducting commercial operations 

under an FAA issued exemption include: 

1. The sUAS will weigh less than 55 lbs.

2. Flights will be operated within line of sight of a pilot and/or observer.

3. Maximum total flight time for each operational flight will be 20 

minutes. Flights will be terminated at 25% battery power reserve 

should that occur prior to the 20 minute limit.

4. Flights will be operated at an altitude of no more than 400 feet AGL 

or, not more than 200 feet above an elevated platform from which 

filming is planned.

5. Minimum crew for each operation will consist of the sUAS Pilot and 

the Visual Observer.

6. sUAS pilot will be an FAA licensed airman with at least a 3rd class 

medical certificate and a valid driver’s license. The observer will also 

hold a valid driver’s license.

7. sUAS Pilot will be Pilot in Command (PIC). If a pilot certificate 

holder other than the sUAS Pilot, who possess the necessary PIC 

qualifications, is also present, that person can also be designated as 

PIC. 

8. Pilot and observer will have been trained in operation of sUAS 

generally and received up- to-date information on the particular sUAS 

to be operated as required. 

9. Observer and pilot will at all times be able to communicate by voice.

10. Written and/or oral permission from the relevant property holders 

will be obtained.

11. All required permissions and permits will be obtained from 

territorial, state, county or city jurisdictions, including local law 

enforcement, fire, or other appropriate governmental agencies. 

12. If the sUAS loses communications or loses its GPS signal, the 

sUAS will have capability to return to a pre-determined location within 

the Security Perimeter and land.

13. The sUAS will have the capability to abort a flight in case of 

unpredicted obstacles or emergencies. 
14. The sUAS will not be flown when there are other known aircraft in 

the vicinity (ie new helicopter or medical helicopter)

14 C.F.R. Part 21, Subpart H: Airworthiness Certificates 14 C.F.R. 

§91.203 (a) (1) 

Subpart H, entitled Airworthiness Certificates, establishes the 

procedural requirements for the issuance of airworthiness certificates 

as required by FAR §91.203 (a) (1). Given the size and limited 

operating area associated with the aircraft to be utilized by the 

Applicant, 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 sUAS. In all cases, an analysis of these criteria 

demonstrates that the sUAS 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 

(fixed wing or rotorcraft) operating with an airworthiness certificate 

without the restrictions and conditions proposed. 

The sUAS to be operated hereunder is less than 55 lbs. fully loaded, 

carries neither a pilot nor passenger, carries no explosive materials or 

flammable liquid fuels, and operates exclusively within a secured area 

as set out in the Manual. Unlike other civil aircraft, operations under 

this exemption will be tightly controlled and monitored by both the 

operator, pursuant to the Manual’s requirements, and under the 

requirements and in compliance with local public safety requirements, 

to provide security for the area of operation as is now done with 

conventional filming. The FAA will have advance notice of all 

operations. These safety enhancements, which already apply to civil 

aircraft operated in connection with motion picture and television 

production, provide a greater degree of safety to the public and 

property owners than conventional operations conducted with 

airworthiness certificates issued under 14 C.F.R. Part 21, Subpart H. 
Lastly, application of these same criteria demonstrates that there is no 

credible threat to national security posed by the sUAS, due to its size, 

speed of operation, location of operation, lack of explosive materials 

or flammable liquid fuels, and inability to carry a substantial external 

load. 

14 C.F.R. § 45.23 (b). Marking of the Aircraft 

The regulation requires: 

When marks include only the Roman capital letter "N" and the 

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

category aircraft or experimental or 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 words "limited," "restricted," "light-sport," 

"experimental," or "provisional," as applicable. 

Even though the sUAS will have no airworthiness certificate, an 

exemption may be needed as the sUAS will have no entrance to the 

cabin, cockpit or pilot station on which the word “Experimental” can be 

placed. Given the size of the sUAV, two-inch lettering will be 

impossible. The word “Experimental” will be placed on the fuselage in 

compliance with §45.29 (f). 

The equivalent level of safety will be provided by having the sUAV 

marked on its fuselage as required by §45.29 (f) where the pilot, 

observer and others working with the sUAV will see the identification 

of the sUAS as “Experimental.” The FAA has issued the following 

exemptions to this regulation to Exemptions Nos. 10700, 8738, 10167 

and 10167A. 

14 C.F.R. § 61.113 (a) & (b): Private Pilot Privileges and Limitations: 

Pilot in Command. 

Sections 61.113 (a) & (b) limit private pilots to non-commercial 

operations. Because the sUAS will not carry a pilot or passengers, the 

proposed operations can achieve the equivalent level of safety of 

current operations by requiring the PIC operating the aircraft to have a 
private pilot’s license rather than a commercial pilot’s license to 

operate this small sUAS. Unlike a conventional aircraft that carries the 

pilot and passengers, the sUAS is remotely controlled with no living 

thing on board. The area of operation is controlled and restricted, and 

all flights are planned and coordinated in advance as set forth in the 

Manual. The level of safety provided by the requirements included in 

the Manual exceeds that provided by a single individual holding a 

commercial pilot’s certificate operating a conventional aircraft. The 

risks associated with the operation of the sUAS are so diminished 

from the level of risk associated with commercial operations 

contemplated by Part 61 when drafted, that allowing operations of the 

sUAS as requested with a private pilot as the PIC exceeds the present 

level of safety achieved by 14 C.F.R. §61.113 (a) & (b). 

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

The regulation requires that no person may operate a civil aircraft 

unless it is in airworthy condition. As there will be no airworthiness 

certificate issued for the aircraft, should this exemption be granted, no 

FAA regulatory standard will exist for determining airworthiness. Given 

the size of the aircraft and the requirements contained in the Manual 

for maintenance and use of safety check lists prior to each flight, as 

set forth in Sections C & D, an equivalent level of safety will be 

provided. 

14 C.F.R. § 91.9 (b) (2): Civil Aircraft Flight Manual in the Aircraft. 

Section 91.9 (b) (2) provides:

No person may operate a U.S.-registered civil aircraft ... 

(2) For which an Airplane or Rotorcraft Flight Manual is not required by 

§21.5 of this chapter, unless there is available in the aircraft a current 

approved airplane or Rotorcraft Flight Manual, approved manual 

material, markings, and placards, or any combination thereof. 

The sUAS, given its size and configuration has no ability or place to 

carry such a flight manual on the aircraft, not only because there is no 

pilot on board, but because there is no room or capacity to carry such 

an item on the aircraft. 
The equivalent level of safety will be maintained by keeping the flight 

manual at the ground control point where the pilot flying the sUAS will 

have immediate access to it. The FAA has issued the following 

exemptions to this regulation: Exemption Nos. 8607, 8737, 8738, 

9299, 9299A, 9565, 9565B, 10167, 10167A, 10602, 32827, and 

10700. 

14 C.F.R. § 91.103: Preflight action 

This regulation requires each pilot in command to take certain actions 

before flight to insure 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. 

sUASs 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. 

Safe simulation and practice flight will be carried out in controlled 

environments. All simulations will be carried out on a computer using 

the drone controls. Any practice flying will take place in a safe 

environment, with no risk to human life below. 

14 C.F.R. §91.119: Minimum safe altitudes 
Section 91.119 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 a sUAS that is a helicopter and the 

exemption requests authority to operate at altitudes up to 400 AGL, or 

not more than 200 above an elevated platform from which filming is 

planned, an exemption may be needed to allow such operations. As 

set forth herein the sUAS will never operate at higher than 400 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 sUAS as well as the location where it is 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 55lbs. proposed herein and the lack of 

flammable fuel, any risk associated with these operations is far less 

than those presently presented with conventional aircraft operating at 

or below 500 AGL in the movie industry. In addition, the low- altitude 

operations of the sUAS will ensure separation between these smallUAS operations and the operations of conventional 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 sUAS may not have a barometric 

altimeter, but instead a GPS altitude read out, an exemption may be 

needed. An equivalent level of safety will be achieved by the operator, 

pursuant to the Manual and Safety Checklist, confirming the altitude of 

the launch site shown on the GPS altitude indicator before flight. 
14 C.F.R. § 91.151(a): Fuel Requirements for Flight in VFR Conditions 

Section 91.151 (a) prohibits an individual from beginning “a flight in an 

airplane under VFR conditions unless (considering wind and forecast 

weather conditions) there is enough fuel to fly to the first point of 

intended landing, and, assuming normal cruising speed – (1) During 

the day, to fly after that for at least 30 minutes; or (2) At night, to fly 

after that for at least 45 minutes.” 

The battery powering the sUAS provides approximately 25 minutes of 

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

§91.151, sUAS flights would be limited to approximately 20 minutes in 

length. Given the limitations on the sUAS’s proposed flight area and 

the location of its proposed operations within a predetermined area, a 

longer time frame for flight in daylight or night 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 FAR 

91.151 (a)). Operating the small sUAS, in a tightly controlled area 

where only people and property owners or official representatives who 

have signed waivers will be allowed, with less than 30 minutes of 

reserve fuel, does not engender the type of risks that Section 

91.151(a) was intended to alleviate given the size and speed of the 

small sUAS. Additionally, limiting sUAS flights to 20 minutes would 

greatly reduce the utility for which the exemption will be granted. 

Applicant believes that an equivalent level of safety can be achieved 

by limiting flights to 20 minutes or 25% of battery power whichever 

happens first. This restriction would be more than adequate to return 

the sUAS to its planned landing zone from anywhere in its limited 

operating area. 

Similar exemptions have been granted to other operations, including 

Exemptions 2689F, 5745, 10673, and 10808. 

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

Registration 
The regulation provides in pertinent part:

(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. 

The sUAS fully loaded weighs no more than 55 lbs and is 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 

sUAS. 

An equivalent level of safety will be achieved by keeping these 

documents at the ground control point where the pilot flying the sUAS 

will have immediate access to them, to the extent they are applicable 

to the sUAS. 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. 

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 applicant. 

Maintenance will be accomplished by the operator pursuant to the 

flight manual and operating handbook as referenced in the Manual.
(See Sections B, D and G) An equivalent level of safety will be 

achieved because these small sUASs are very limited in size and will 

carry a small payload and operate only in restricted areas for limited 

periods of time. If mechanical issues arise the sUAS can land 

Pursuant to 14 C.F.R. Part 11, the following summary is provided 

for publication in the Federal Register, should it be determined 

that publication is needed: 

Applicant seeks an exemption from the following rules:

14 C.F.R. §21, subpart H; 14 C.F.R 45.23(b);14 C.F.R. §§ 61.113( a) & 

(b);91.7 (a); 91.9 (b) (2);91.103(b);91.109; 91.119; 91.121; 91.151(a);

91.203(a) and (b); 91.405 (a); 91.407 (a) (1); 91.409 (a) (2); 91.409 (a) 

(2) and 91.417 (a) & (b) to operate commercially a small unmanned 

vehicle (55lbs or less) DJI Phantom 3 Advanced Drone. 

In summary, approving these exemptions and allowing Commercial Drone Services LLC to 

operate a small unmanned electric quad rotor drone will enhance safety, promote the local 

economy and even save lives. The Commercial Drone Services LLC is Owned by Jonathan 

J Pascua, a Licensed FAA Private Pilot with extensive Drone experience and a Career 

Firefighter/EMT. Commercial Drone Services LLC will be operating in many ways 

including but not limited too Public safety in conjunction with Fire/Rescue Departments in 

various ways like Search and Rescue, Infrastructure inspection, Fire Scene safety 

monitoring, Fire load inspection and other various uses in Hazmat situations and water 

rescue to name a few. These incidents would normally require putting Humans in harms 

way to get this information however, that would no longer be needed with the use of a 

drone from Commercial Drone Services LLC. Commercial Drone Services LLC will 

provide fire ground support and training in the use and operation of Drones at all types of 

Fire/Rescue operations. Commercial Drone Services LLC will also be taking still pictures 

and video of Real Estate for various commercial reasons. Prior to this helicopters or other 

low flying aircraft were used to do this and they were carrying humans and explosive fuel, 

creating more or a risk then a sUAS from Commercial Drone Services LLC. Commercial 

Drone Services LLC will also take aerial photography and video for local news stations in 

for use in local media when all safety guidelines have been met that are listed in this 

proposal. Other uses for Commercial Drone Services LLC include advertising, agricultural 

inspection, landmark photography and environmental photography. Commercial Drone 

Services LLC has multiple business points and is not “Primary” in one particular area 
listed. I respectfully ask the FAA to review the Documents attached and ask for any 

clarifying information on anything needed. All of these uses that Commercial Drone 

Services LLC will be using the drone for will ensure the public will benefit due to being in a 

safer environment due to the fact you will not need larger, heavier Aircraft, carrying 

humans and flammable fuel on board, rather you will have a licensed medically current 

pilot remotely flying a small under 55lbs quad rotor A/C with several fail safes that are 

listed in this document. 

Commercial Drone Services LLC

222 Raccoon Run Rd 

Coventry, RI 

401-598-7562

Jonathan Pascua

sUASs Details: See Appendix C 

Safety Features:

● Emergency “Return-To-Home” 

○ At the beginning of each flight a home point is set. This home point 

is set in accordance with the manual to allow for a safe take- off and 

return. Should the pilot’s control lose signal with the sUAS or manually 

request a return, the sUAS will return to the starting point. 

Appendix A: No-Fly Zones 

Commercial Drone Services LLC’s Pilots will not be operating within 5 

nautical miles of any airport. 

As a safety precaution, Commercial Drone Services LLC’s pilots will 

not be operating within 5 nautical miles of any airport similar to the 

permission granted in Exemption No. 11153 - Regulatory Docket No. 

FAA20140519, page 25, "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 airports management 

is obtained, and the operation is conducted in accordance with a NOTAM as 

required by the operators COA. The letter of agreement with the airport 

management must be made available to the Administrator upon request." 

As well as in Exemption No. 11195 - Regulatory Docket No. 

FAA20140884, page 12, "19. 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 airports management is obtained, and the operation is conducted 

in accordance with a Notice to Airmen (NOTAM), as required by the 

operators Certificate of Waiver or Authorization (COA). The letter of 

agreement with the airport management must be made available to 

the Administrator upon request." 

Commercial Drone Services LLC requests the same flexibility as 

exemptions 11153 and 11195 for acquiring agreement with the 

airports' management should operations fall within 5 nautical miles of 

an airport. 

A. Maintenance 

Appendix B: Safety Manual 

 a. The sUAS must be inspected by a factory trained technician at 

intervals required by the manufacturer. All maintenance records 

will be maintained for inspection as set forth in Section B. 

 b. If any maintenance is undergone, the sUAS must pass a flight 

test with Licensed FAA Pilot. 

B. Record Keeping 

a. A digital record will be kept for all flights, flight times, and 

maintenance records. 
b . Identify potential obstacles

i. Before each flight, an inventory will be taken for all potential 

obstacles 

that must be avoided while in flight. Including: 

 1. Powerlines 

 2. Cell Phone Towers 

 3. Trees 

 4. Flocks of birds that may take flight 

 5. Heavily traveled roadways 

 6. Utility wires 

 7. Elevated structures 

 8. At least 5 nautical miles from the nearest airport or helipad. 

D. Pre-FlightChecklist 

a. Take Off Location/ “Home” 

i. The sUAS will mark its take off location as a safe area to return to 

should the sUAS lose signal with the control or if the pilot signals the 

craft to return to its “home” location. 
 1. Take off location will be in an area with a 20ft radius with no 

obstructions, maintaining said radius vertically 200ft. 

 2. The sUAS will take off and land in the same location. 

 3. GPS Altimeter will be marked as 0’ elevation 

b. Flight Canceling Events 

i. All flights will be cancelled for a minimum of 2 hours if any of the 

below occur: 

 1. Low flying aircraft in the area 

 2. Medical/News Helicopters active in the area 

 3. Wind exceeding 10 mph 

 4. PIC is unable to complete flight without losing visual of the sUAS 

 5. Any precipitation 

 6. Heavy bird presence in the area that could cause a mid-air 

collision. 

 7. Any defects or damage found during preflight exam 

c. Physical Inspection 
i. Before flight. 1. 2. 

3. 4. 5. 

d. Post Flight Inspections/Checklist

i. After each flight, the the sUAS will be thoroughly inspected for any 

damage that occurred in flight. 

 1. Body inspected for any damage 

 2. Blades visually checked for any damage at all 

 3. Battery checked for damage 

E. Mid-AirSafetyProtocol a. Max Speed 

 i. Accent

1. 10m/s 

 ii. Decent

1. 4m/s 

 iii. Flight Speed 

1. The sUAS is never to exceed 10m/s 

b. Altitude 

i. The sUAS is never to exceed 400ft 

c. Emergency 

i. If it appears that the sUAS, any property or humans are at risk, the 

sUAS will be grounded immediately to a safe location. 
d. Sight 

i. The pilot must keep the sUAS within eyesight at all times unassisted 

by any technology. 

F. Participation by non-pilot staff 

a. All staff involved in the production or filming using the sUAS will 

consent to maintain a safe distance of at least 30 ft during the filming. 

G. Pilot/Spotter Training 

a. Before flying, both the Pilot and spotter will receive updated 

information on the sUAS and its firmware. 

i. The controller allows for a simulator training, both the pilot and 

spotter are allowed to run through the simulator training