U. S. Department of Transportation Docket Management System 1200 New Jersey Ave., SE 

Washington DC 20590

14 December 2015

Revised 

Re: Exemption Request Pursuant to Section 333 of the FAA Reform Act and Part 11 of the 

Federal Aviation Regulations from: 14 CFR 61.113(a) and (b); 91.103; 91.119(c); 91.121; 

91.151(a); 91.405(a); 91.407(a)(1); 91.409 (a)(1) and (2); 91.417(a) and (b). 

To whom it may concern: This is a revision of original submitted July 14, 2015 (1jz-8jz7-

o1t5) to remove closed-set filming.

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

and 14 C.F.R. Part 11, Drone Loan, LLC, an operator of Small Unmanned Aircraft Systems and 

Aerial and Photography Vehicles (“UAS/APVs”) for aerial image acquisition including but not 

limited to, the following industries: real estate, short range inspection, mapping & survey, 

agriculture, search and rescue, hereby applies for an exemption from the Federal Aviation 

Regulations (“FARs”) to allow commercial operation of its UAS/APV. 

Drone Loan, LLC's requested exemption would permit the operation of UAS/APV under 

controlled and secure conditions that is: (i) limited, (ii) predetermined, (iii) subject to controlled 

access, and (iv) provide greater safety in connection with aircraft operations. As established by

the exemptions already granted by the FAA, approval of Drone Loan, LLC’s exemption would 

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. 

The name and address of the petitioner is: 

William Edward Ray- Owner/Manager/Pilot 

24 year Military Veteran 

Company Name: Drone Loan, LLC 

Address: 7791 Three Canyons Rd, Hereford AZ 85615 

Phone: 520 559 3293 Email: droneloan@hotmail.com 

Proposed Aircraft: Yuneec Q500+; 3DR Solo 

See Enclosed UAS/APV Owner’s Manual 

Regulations from which the exemption is requested: 

14 CFR 61.113(a) and (b) 

14 C.F.R. 91.103

14 C.F. R. 91.119 

14 C.F.R. 91.121 

14 CFR 91.151(a) 

14 CFR 91.405(a) 
14 CFR 407(a) (1) 

14 CFR 409(a) (2) 

14 CFR 417(a) and (b) 

UAS/APVs operated by Drone Loan, LLC weigh less than 55 pounds, including the payload (i.e. 

camera, lens, and gimbal). They operate at speeds of no more than 50 knots, can hover, and can 

simultaneously move vertically and horizontally. Drone Loan, LLC will only operates its 

UAS/APVs in line of sight and will operate only within the secure area described in the FOPM. 

Such operations will insure that the UAS/APV will “not create a hazard to users of the national 

airspace system or the public. “Given the small size of Drone Loan, LLC's UAS/APVs and the 

restricted secure environment within which they will operate, Drone Loan, LLC's UAS/APV 

operations adhere to the Reform Act’s safety requirements. Additionally, due to the size of the 

UAS/APVs, permission from relevant property owners or other applicable parties, and the 

limited areas in which they will operate, approval of this application presents no national security

issues. Based on the substantial level of safety surrounding the proposed operations, and the 

significant public benefit (enhanced safety), reduction in environmental impacts (reduced 

emissions and noise), the grant of the requested exemption is in the public interest. Accordingly, 

Drone Loan, LLC respectfully requests that the FAA grant the requested exemption. Aircraft and 

Equivalent Level of Safety 

The operating limitations proposed by Drone Loan, LLC provide for at least an equivalent or 

higher level of safety because operations further enhance safety of aerial image collection using 

conventional aircraft. 

The limitations and conditions include: 

• The UAS/APVs will weigh less than 55 pounds. 

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

• Maximum flight time for each operational flight will be no more than 30 minutes. Flights will 

be terminated at no less than 25% battery power reserve should that occur prior to the 30 minute 

limit. 

• Flights will be operated at an altitude below 400 feet AGL, and not more than 200 feet above 

an elevated platform from which filming is planned. 

• Minimum crew for each operation will consist of the UAS/APV Pilot, the Visual Observer

• A UAS/APV pilot will be an FAA licensed airman with at least a sport pilot’s certificate, and 

third class medical or valid US or Canadian driver’s license. 

• A UAS/APV pilot will be Pilot in Command (PIC). 

• The UAS/APV will only operate within a confined secure area as defined in the FOPM. A 

briefing will be conducted for planned UAS/APV operations prior to each day’s flight. All 

personnel performing duties within the boundaries of the safety perimeter are required to attend. 
• The operator will obtain consent of all persons involved in the filming and ensure that only 

consenting persons will be allowed within 500 feet of the flight operation. 

• The Pilot and observer must be trained in UAS/APV operations and have received current 

information on the particular UAS/APV to be operated as required by the FOPM. 

• The Observer and pilot will be able to communicate by voice and/or text at all times. 

• Written and/or oral permission from the relevant property holders will be obtained prior to 

flight operations. 

• All appropriate permissions and permits will be obtained from territorial, state, county, or city 

jurisdictions, including local law enforcement, fire, or other appropriate governmental agencies. 

If the UAS/APV loses communications or loses its GPS signal, the UAS/APV will have the 

capability to “return to home” (original point of origin) within the secure perimeter and land. 

• The UAS/APV will have the capability to abort a flight in case of unpredicted obstacles or 

emergencies. 

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

Sections 61.113 (a) and (b) limit private pilots to non-commercial operations. Because the 

UAS/APV 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 a UAS/APV. Unlike a 

conventional manned aircraft, a UAS/APV is remotely controlled by a ground-based operator. 

The operational area is controlled and restricted, and all flights are planned and coordinated in 

advance. The level of safety exceeds that provided by a single individual holding a commercial 

pilot’s certificate operating a conventional aircraft. The risks associated with the use of a 

UAS/APV are so diminished from the level of risk associated with commercial operations 

contemplated by Part 61 allowing UAS/APV use by a sport pilot as the PIC exceeds the present 

level of safety sought by 14 C.F.R. §61.113 (a) and (b). 

14 C.F.R. § 91.103: Preflight Action 

Section 91.103 requires each pilot to preflight an aircraft before flight to insure the safety of 

flight. As FAA approved rotorcraft flight manuals will not be used, an exemption is requested. 

However, an equivalent level of safety will be provided. The PIC will take all actions, including 

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

performance data before commencement of flight. 

14 C.F.R. §91.119(c): Minimum Safe Altitudes 

Section 91.119 establishes safe altitudes for operation of civil aircraft. 

Section 91.119 provides, in pertinent part, that: “except when necessary for takeoff or landing, 

no person may operate an aircraft below the following altitudes: 
(c) Over other than congested areas. An altitude of 500 feet above the surface, except over open 

water or sparsely populated areas. In those cases, the aircraft may not be operated closer than 500 

feet to any person, vessel, vehicle, or structure.” 

Because Drone Loan, LLC requests authority to operate at altitudes no higher than 400 AGL, 

and not more than 200 above an elevated platform from which filming is planned, an exemption 

is needed to allow such operations. Except for the limited conditions stated in the FOPM, the 

UAS/APV will never operate higher than 400 AGL. It will, however, be operated in a restricted 

area within a 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, and speed of the 

UAS/APV as well as the location where it is operated. No flight will be taken without the 

permission of property owners or local officials. 

Because of the advance notice to the property owners and participants in the filming activity, all 

affected individuals will be informed of the planned flight operations. Compared to flight 

operations for manned aircraft and the lack of flammable fuel, any risk associated with the 

proposed UAS/APV operations is far less than conventional aircraft operating at or below 500 

AGL. In addition, the low-altitude operations of the UAS/APV will ensure separation between a 

UAS/APV and conventional aircraft. 

14 C.F.R. §91.121: Altimeter Settings 

Section 91.121 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 a UAS/APV may not have a barometric 

altimeter, but instead a GPS altitude data, an exemption is needed. An equivalent level of safety 

will be achieved by the operator, pursuant to the FOPM and Safety Check list, 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 . . . .” 

The typical battery powering the Drone Loan, LLC UAS/APVs provides less than 30 minutes of 

powered flight. To meet the 30-minute reserve requirement in 14 CFR §91.151, UAS/APV flight 

would not be possible. Given the limitations on the UAS/APV’s proposed light area and its 

proposed operations within a predetermined location, a longer time frame for flight in daylight 

VFR conditions is reasonable. Furthermore, operating the UAS/APVs in a tightly controlled area 

where only people, property owners, or official representatives who have signed waivers will be 

allowed, less than 30 minutes of reserve fuel does not engender the type of risk that §91.151(a) 

was intended to address. 
Drone Loan, LLC believes that safety can be achieved by limiting flights to 30 minutes or 25% 

of battery power, whichever occurs first. This restriction would be more than adequate to return 

the UAS/APV to its pre-determined landing zone from anywhere in its limited operating area. 

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 sections and Part 43 apply only to aircraft with an airworthiness certificate, these sections 

will not apply to Drone Loan, LLC operations. Maintenance will be accomplished by the 

operator. An equivalent level of safety will be achieved because the UAS/APVs are limited in 

size, will carry a small payload and operate only in restricted areas for limited periods of time. If 

mechanical issues arise, the UAS/APV can land immediately and will be operating from no 

higher than 400 feet AGL. As provided in the FOPM, the operator will ensure that the UAS/APV 

is in working order prior to flight, perform any required maintenance, and keep a log of any 

maintenance performed. Moreover, the operator is the person most familiar with the UAS/APV 

and best suited to maintain it in an airworthy condition. 

Summary for Publication 

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: 

Drone Loan, LLC seeks an exemption from the following rules: 14 C.F.R. §§ 61.113(a) and (b); 

91.103; 91.119(c); 91.121; 91.151(a); 91.405(a); 91.407(a)(1); 91.409(a)(2); and 91.417(a) and 

(b) to operate commercially a small unmanned vehicle (55 pounds or less) in commercial image 

acquisition operations. As established by the UAS/APV exemptions already granted by the FAA, 

allowing commercial operations of UAS/APVs in agriculture, real estate, inspection, S & R, and 

film industries will enhance safety by reducing risk. Conventional survey, agricultural, mapping, 

inspection, and film operations, using turbine aircraft, operate at low altitudes and present the 

risks associated with aircraft that weigh around 4,000 pounds, and which carry large amounts of 

Jet A fuel. Such aircraft must also fly to and from the target location. In contrast, a UAS/APV 

weighing fewer than 55 pounds and powered by batteries eliminates virtually all of that risk 

given the small size and lack of combustible fuel. The UAS/APV is carried, and not flown, to 

target site. In this regard, the UAS/APV carries no passengers or crew and, therefore, will not 

expose them to the risks associated with manned flights. The operation of UAS/APVs conducted 

in the strict conditions outlined in the FOPM will provide an equivalent level of safety 

supporting the grant of the exemption requested herein. The UAS/APVs operate at slow speeds, 

close to the ground, and in a secure environment. As a result, they are far safer than conventional 

operations conducted with turbine helicopters flying near the ground and people. 

Privacy 
All flights will occur over private or controlled access areas with the property owner’s prior 

consent and knowledge. Recognizable images will only be recorded of people who have given 

their consent or otherwise have agreed to be in the area where active image acquisition will take 

place. Satisfaction of the criteria provided in Section 333 of the Reform Act of 2012 (size, 

weight, speed, operating capabilities, proximity to airports and populated areas and operation 

within visual line of sight and national security) provide more than adequate justification to grant 

Drone Loan, LLC’s requested exemption, allowing for Drone Loan, LLC's UAS/APV 

commercial operations for the listed industries pursuant to the included FOPM. 

If you have any questions or need any additional information, please contact the undersigned by 

phone at 520 559 3292 or via email at droneloan@hotmail.com 

Very Respectfully 

William Edward Ray