IN THE MATTER OF THE PETITION FOR EXEMPTION OF:

Z-DRONES, LLC.

FOR AN EXEMPTION SEEKING RELIEF FROM THE REQUIREMENTS OF TITLE 12 OF 

THE CODE OF FEDERAL REGULATIONS

SECTIONS:

CONCERNING COMMERCIAL OPERATION OF THE:

DJI INSPIRE 1

DJI S1000

PURSUANT TO SECTION 333 OF

THE FAA MODERNIZATION AND REFORM ACT OF 2012 (PUBLIC LAW 112-95)

Z-DRONES,	LLC.

JEFFREY	ZITA

PO	BOX	2636

DOUGLAS, MI 49406

Tel:	(630)-707-4598
BACKGROUND INFORMATION 

Z-DRONES, LLC. is in the business of consultation and pilot contracting, unmanned aircraft 

operations. 

Z-DRONES seeks an exemption to operate several sUAS, listed below, for compensation or hire 

within the National Airspace System (“NAS”). The proposed aircraft all include vertical takeoff 

and landing (VTOL) Unmanned Aircraft (UA) and transportable Ground Control Stations 

(GCS). Regulatory exemptions laid out in this petition would allow Z-DRONES to provide aerial 

photography and cinematography services, utilizing UA, for private and commercial interests in 

the United States. 

AIRCRAFT MODELS INCLUDED IN THIS PETITION 

1. DJI Inspire 1 

2. DJI S1000

REGULATORY BASIS FOR PETITION 

Pursuant to the provisions of the Federal Aviation Regulations (14 C.F.R. § 11.61) and the FAA 

Modernization and Reform Act of 2012, Section 333, Special Rules for Certain Unmanned 

Aircraft Systems, Z-DRONES hereby petitions the Administrator to operate sUAS in the NAS, 

and for an exemption from the requirements of 14 C.F.R §§ 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). 

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

unmanned aircraft and its operation, Z-DRONES’s operation of the listed UAS meets the 

conditions of Section 333 and therefore, will not require an airworthiness certificate in 

accordance with 14 C.F.R. Part 21, Subpart H. 

Accordingly, Z-DRONES 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. 

Z-DRONES submits that the requested relief is proper since an equivalent level of safety will be 

ensured. Z-DRONES will perform maintenance, alterations, or preventive maintenance on the 

UAS as prescribed by the manufacturers’ maintenance documentation where applicable, or by 

returning the aircraft to its manufacturer when operator maintenance is not recommended. 

Furthermore, Z-DRONES will document and maintain all maintenance records for the aircraft 

used in the requested operations.

Z-DRONES seeks relief from Section 91.7(a), entitled Civil aircraft airworthiness, because the 

selected sUAS do not require an airworthiness certificate in accordance with 14 C.F.R. Part 21, 

Subpart H. As such, Z-DRONES submits that it will ensure that the unmanned aircraft are in an 

airworthy condition prior to every flight, by determining that the UAS are in compliance with the 
applicable UAS Operator and Maintenance Manuals, and that the UA are in condition for safe 

flight. 

Z-DRONES also seeks an exemption from the requirements of Section 91.121, entitled Altimeter 

Settings, as the proposed UAS are equipped with a barometer and Global Positioning System 

(GPS) equipment, which ensures that a ground level pressure setting will be established prior to

each flight. The UA barometer and GPS equipment ensure safety by providing the PIC with 

adequate information concerning altitude of the UA, above ground level (AGL), as shown on the 

heads-up display of the GCS. 

Additionally, Z-DRONES seeks an exemption from the requirements of Section 91.151(b), Fuel 

requirements for flight in VFR conditions. Z-DRONES submits that safety will not be affected 

because flights will be terminated at or before battery levels which are recommended by the 

OEM for safe operation. 

In accordance with 14 C.F.R. § 11.81, Z-DRONES provides the following information in support 

of its petition for exemption: 

A. The Specific Sections of 14 C.F.R. From Which Z-DRONES Seeks Exemption.

1. Z-DRONES 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. 

2. Z-DRONES Seeks Exemption From The Requirements Of Section 91.121. 

Section 91.121, entitled Altimeter settings, subsection (a), states the following, in relevant 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; 

3. Z-DRONES Seeks Exemption from The Requirements of Section 91.151(b). 
Section 91.151, entitled Fuel requirements for flight in VFR conditions, subsection (b), states the 

following: 

(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. 

4. Z-DRONES 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[.] 

5. Z-DRONES Seeks Exemption From The Requirements Of Section 91.407(a)(1). 

Section 91.407, entitled Operation after maintenance, preventive maintenance, rebuilding, 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[.] 

6. Z-DRONES 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. 

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7. Z-DRONES Seeks Exemption From The Requirements Of Sections 91.417(a) And 

91.417(b). 
Section 91.417, entitled Maintenance records, 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 

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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. 

B. The Extent Of Relief Z-DRONES Seeks And The Reason Z-DRONES Seeks The Relief. 

1. Extent of Relief Z-DRONES Seeks And The Reason Z-DRONES Seeks Relief From 

Section 91.7(a). 

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

required to allow Z-DRONES to determine that the operations UAS is in an airworthy condition 

prior to every flight by ensuring that the UAS is in compliance with the applicable operations 

and maintenance manuals, and that the UA is in condition for safe flight. Copies of the Inspire 1 

and S1000 operator’s manuals are attached as exhibits A and B.

Z-DRONES seeks the requested relief because the proposed sUAS do not require an 

airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H. Therefore, ZDRONES will ensure that the sUAS is in an airworthy condition based upon its compliance with 

the operating documents prior to every flight, and as stated in the conditions and limitations 

below. 

2. Extent of Relief Z-DRONES Seeks And The Reason Z-DRONES Seeks Relief From 

Section 91.121. 

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

operations of the proposed UAS, which utilize barometer and GPS equipment, to ensure that a 

ground level pressure setting will be established prior to each flight, and in order to report 

altitude to the PIC. Z-DRONES seeks the requested relief because the proposed UAS do not 

utilize a typical barometric altimeter that may be set as contemplated by Section 91.121. As more 

fully set forth below, an equivalent level of safety will be maintained since the sUAS are 

equipped with a barometer and GPS equipment, which will ensure that a ground level pressure 

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

the UA, above ground level (AGL), on the heads-up display of the ground control station (GCS). 

3. Extent Of Relief Z-DRONES Seeks And The Reason Z-DRONES Seeks Relief From 

Section 91.151(b). 

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

requested to the extent required to allow flights of the battery powered UA, during daylight hours 

in visual meteorological conditions under visual flight rules (VFR), to continue for a total 

duration not greater than that recommended by the manufacturer for safe operation. Z-DRONES
seeks the requested relief, because without an exemption from Section 91.151(b), the flight time 

duration of the battery powered UA will severely constrain the practicality of any aerial 

photography operations which Z-DRONES proposes to conduct pursuant to this Petition. 

4. Extent Of Relief Z-DRONES Seeks And The Reason Z-DRONES 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, Z-DRONES requests relief from these Sections because 

the UAS do not require an airworthiness certificate. As set forth more fully below, the selected 

UAS meet the conditions of Section 333 of the FMRA for operation without an airworthiness 

certificate. Accordingly, Z-DRONES will perform maintenance, alterations, or preventive 

maintenance on the UAS as prescribed by the manufacturers’ maintenance documentation where 

applicable, or by returning the aircraft to its manufacturer when operator maintenance is not 

recommended. 

C. Reasons Why Granting Z-DRONES’s Request Would Be In The Public Interest; That 

Is, How It Would Benefit The Public As A Whole. 

Granting the present Petition will further the public interest by allowing Z-DRONES to safely, 

efficiently, and economically perform commercial aerial photography and cinematography. 

Additionally, our services will aid in increasing safety and proper operating procedures for these 

aircraft both in commercial and private markets to reduce risk and potential accidents. Notably, 

the benefits of Z-DRONES’s proposed operations of the listed UAS will be realized without 

implicating any privacy issues. 

1. The Public Will Benefit From The Aerial Photography And Cinematography. 

Z-DRONES’s photography and cinematography program will provide safe, efficient, and 

economical imaging to the public. The exemption process under FMRA section 333 allows the 

FAA to hand pick the safest operators to spearhead the UAS service market in the United States, 

which increases the safety for the public as a whole. This petition and its supporting documents 

prove Z-DRONES to be exactly the type of operator the FAA should wish to proliferate based on 

its dual mandate to increase safety and economic prosperity. Z-DRONES has empirically proven 

itself to be safer than many other UAS operators, and UAS in general pose a much smaller risk 

to the public than manned, combustion engine aircraft generally used for aerial photography. To 

utilize an analogy from microeconomics, granting this petition will increase the supply of safe, 

lawful aerial photography operators in the United States, which will drive down the demand for 

and use of less safe manned aircraft operators or illegal UAS operators. 

Aerial imaging which uses UA is inherently cheaper than operations which rely on manned 

aircraft, meaning that Z-DRONES will be able to provide the same services to the general public 

at a tremendous discount. This will create an economic benefit for the public, in addition to the 

safety benefit. 
Finally, the exemptions granted by this petition would allow Z-DRONES to operate as an aid to 

law enforcement agencies, search and rescue operations, and accident investigation efforts. ZDRONES will provide timely strategic and investigative information to these operations, which 

could help save lives and reduce property losses. Granting the specified exemptions will provide 

not only safety and economic benefit to the public, but also an increased effectiveness of preexisting public services. 

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

The DJI Inspire 1 and S1000 serve as a safe, efficient, and economical alternative to the manned 

aircraft traditionally utilized in many commercial industries. By reducing the amount of manned 

aircraft needed, an exemption allowing the use of these aircraft 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. These aircraft do not 

require an airport to takeoff or land. Likewise, a reduction of manned aircraft conducting 

commercial operations 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. 

3. The Public Will Benefit From The Safety And Efficiency Of These Aircraft. 

Conducting commercial operations with the DJI Inspire 1 and S1000, instead of manned aircraft, 

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

generated during traditional commercial aviation operations. All models use only battery power 

and electric motors. These aircraft produce no air pollution, and are the most viable 

environmentally conscious alternative to cabin class, internal combustion aircraft that are 

typically utilized in commercial operations. SUAS also reduce noise pollution, as the electric 

motors produce far less noise. 

By using these aircraft to perform commercial aerial operations, 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 or completely eliminated. Aside from the lack of 

flight crew members located onboard the aircraft, these aircraft all weigh less than 55 pounds at 

their maximum gross weight, and therefore have less physical potential for collateral damage to 

life and property on the ground, and in the air, compared to typical manned aircraft. 

4. There Are No Privacy Issues. 

Similar to manned commercial operations that have been conducted for decades, Z-DRONES’s 

proposed operations will not implicate any privacy issues. Specifically, these aircraft will be 

operated only in rural areas and in accordance with all Federal Aviation Regulations, including 

the minimum altitude requirements of 14 C.F.R. 91.119. Most significantly, these aircraft will 

not be operated closer than 500 feet to any person, vessel, vehicle, or structure, which is not 

directly involved in the operations. Privacy and safety of any persons in the vicinity of operations 
are of great importance to Z-DRONES and Z-DRONES will comply with all local, state and 

federal laws applicable to the safety and privacy of people in the vicinity of sUAS 

operations. Unless required to safely return the aircraft in an emergency situation, aircraft visual 

sensors will not focus on anything but Z-DRONES’s assets, and if any images or video of non-ZDRONES assets is accidentally captured, the data will be immediately erased from the UAS 

camera, sensors, ground stations etc. at the local landing site. 

D. 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 Z-DRONES Seeks Exemption. 

1. Reasons Why The DJI Inspire 1, DJI S1000 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 their operation, Z-DRONES’s operations of the DJI Inspire 1 and DJI 

S1000 UAS meet the conditions of FMRA Section 333, and will not require an airworthiness 

certificate in accordance with 14 C.F.R. 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, Z-DRONES submits that the included UAS can operate safely in the 

NAS pursuant to FMRA Section 333, as demonstrated by: (a) the characteristics of these UAS; 

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

Copies of the Inspire 1 and S1000’s operator’s manuals are attached as exhibits A and B. The 

2. Reasons Why An Exemption From The Requirements Of Section 91.7(a) Would Not 

Adversely Affect Safety. 

The level of safety established by Section 91.7(a) will be maintained because prior to every 

flight, Z-DRONES will ensure that the UAS is in an airworthy condition and safe for flight 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). 

3. 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 UAS 

is equipped with a digitally encoded barometric altimeter and GPS triangulation equipment, with 

a zero altitude initiation point being established prior to each flight. As such, the PIC on the UAS 

is provided the altitude of the UA above ground level (AGL) via a heads-up display of the 

ground control station (GCS). 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). 

4. Reasons Why An Exemption From The Requirements Of Section 91.151(b) Would Not 

Adversely Affect Safety. 

A grant of this exemption would ensure the equivalent level of safety established by 14 C.F.R. 

Section 91.151(b) because the operator will always have detailed information on the charge and 

state of the battery, and preset battery failsafe’s will prevent any loss of flight control due to 

power loss. Furthermore, previous exemptions granted by the FAA concerning Section 91.151(b) 

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

limitations of a UAS are considered. 

The ground control station (GCS) provides a battery indicator on the heads-up display, which 

indicates the UA’s current remaining battery power measured in volts, and thus provides the PIC 

with constant awareness of the real-time battery voltage during a flight. 
Specific details on battery failsafes can be found in the Inspire 1 and S1000 operator’s manuals, 

which are attached as exhibits A and B. 

Likewise, as set forth above, Z-DRONES has proposed specific operating limitations in this 

Petition that will maintain the equivalent level of safety established by Section 91.151(b), 

including the following: (1) the UA will only be operated during daylight hours (i.e. between the 

end of morning civil twilight and the beginning of evening civil twilight, as published in the 

American Air Almanac, converted to local time); (2) The UA will only be operated pursuant to 

visual flight rules (VFR) in visual meteorological conditions (VMC); and (3) the duration of each 

flight shall not exceed the maximum time or battery charge level recommended by the 

manufacturer for safe operations. 

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). 

5. 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, Z-DRONES submits that an 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 Z-DRONES and 

the manufacturers of each aircraft, will use trained technicians to perform maintenance, 

alterations, or preventive maintenance on the unmanned aircraft system using the methods, 

techniques, and practices prescribed in the manufacturer’s maintenance manual. Furthermore, ZDRONES will document and maintain all maintenance records for each of the individual aircraft. 

Since each UAS will be inspected as prescribed by the manufacturer’s maintenance manual, ZDRONES will maintain the equivalent level of safety established by Sections 91.405(a), 

91.409(a)(1), and 91.409(a)(2). The Aircraft Maintenance Manuals set forth Scheduled 

Maintenance Inspection Procedures for each system and component. Inspection intervals for the 

aircraft include preflight and postflight inspections, as well as scheduled inspections every 25 

hours, 50 hours, 75 hours, and 100 hours of operation. 

Likewise, the exemption sought will not adversely affect safety because Z-DRONES will 

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

techniques, and practices prescribed by the manufacturer’s maintenance manuals for each 

respective aircraft. 

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 aircraft will be
performed by manufacturer approved technicians, who will document and maintain maintenance 

records for the UAS. A Maintenance Action Form must be completed and saved in the 

maintenance logs for all maintenance that is performed on the UAS. The procedures for 

maintaining the maintenance logs for the UAS are fully set forth in the Z-DRONES Operations 

Manual, Exhibit Q. Details on the Kittyhawk.io logging program can be found in the Kittyhawk 

Sell Sheet, attached as Exhibit C. 

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

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

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

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). 

6. 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 C.F.R. § 21.16 entitled Special Conditions, Z-DRONES requests that the FAA prescribe 

special conditions for the intended operation of each UAS, which contain such safety standards 

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

by 14 C.F.R. Part 21, Subpart H, and 14 C.F.R §§ 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 UA for the limited purpose of conducting aerial photography over rural 

areas of the United States. 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 C.F.R. § 21.16, for 

operation of each UAS, since the airworthiness regulations of 14 C.F.R. 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 C.F.R. § 21.16. 

Therefore, in accordance with FMRA Section 333 and 14 C.F.R. § 21.16, the FAA may 

prescribe special conditions for Z-DRONES’s intended operation of the DJI Inspire 1 and S1000, 
which contain such safety standards that the Administrator finds necessary to establish a level of 

safety equivalent to that established by 14 C.F.R. Part 21, Subpart H, and 14 C.F.R Sections 

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). 

F. A Summary That Can Be Published In The Federal Register, Stating: 

The Rules From Which Z-DRONES Seeks Exemption: 

Z-DRONES, LLC. seeks exemption from the requirements of 14 C.F.R. Sections), 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). 

A Brief Description Of The Nature Of The Exemption Z-DRONES Seeks: 

This exemption will permit Z-DRONES, LLC. to commercially operate Unmanned Aircraft 

Systems for the purpose of conducting aerial photography and cinematography over certain 

rural areas of the United States. 

G. Any Additional Information, Views, Or Arguments Available To Support Z-DRONES’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, Z-DRONES’s request for exemption may be granted 

pursuant to the authority of FMRA Section 333 and 14 C.F.R. 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, Z-DRONES will operate the specified UAS safely in the NAS 

without creating a hazard to users of the NAS, or the public, or otherwise pose a threat to 

national security. 

CONCLUSION 

As set forth herein, Z-DRONES seeks an exemption pursuant to 14 C.F.R. § 11.61 and Section 

333 of the FAA Modernization and Reform Act of 2012 (FMRA), which will permit safe 

operation of the DJI Inspire 1, 3DR Solo, and SteadiDrone Mavrik UAS commercially, without 

an airworthiness certificate, for the limited purpose of conducting aerial photography and 

cinematography within the stated operational guidelines. By granting this Petition, the FAA 

Administrator will be fulfilling the Congressional mandate of the FAA Modernization and 

Reform Act of 2012, while also advancing the interests of the public, by allowing Z-DRONES to 

safely, efficiently, and economically operate these UAS commercially within the NAS. 

WHEREFORE, in accordance with the Federal Aviation Regulations and the FAA 

Modernization and Reform Act of 2012, Section 333, Z-DRONES respectfully requests that the 
Administrator grant this Petition for an exemption from the requirements of 14 C.F.R Sections 

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), 

and permit Z-DRONES to operate the specified UAS for the purpose of conducting aerial 

photography and cinematography over rural areas of the United States.