**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).
T o 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 Sy stems and Aerial and Photograph y 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, hereb y applies for an exemption from the Federal Aviation Regulations (“FARs”) to allow commercial operation of i ts 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 alread y granted b y 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 requirem ents for the safe operation of such aircraft s ys tems in the national airspace s ys tem.” Section 333(c) of the Reform act. The name and address of the petitioner is: William Edward Ray

- Owner/Manager/Pilot 24 y ear Military

Veteran Company Name: Drone L oan, LLC Address: 7791 Three Cany ons 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 b y 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 onl y 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 sy stem 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 safet y requirements. Additionally , due to the size of the UAS/APVs, permission from re levant propert y 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

s ignificant public benefit (enhanced safet y), 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 request ed exemption. Aircraft and Equivalent Level of Safety The operating limitations proposed b y Drone Loan, LLC provide for at least an equivalent or higher level of safet y because operations further enhance safet y of aerial image collection using convention al 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 f ilming 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 pe rforming duties within the boundaries of the safet y perimeter are required to attend.• The operator will obtain consent of all persons involved in the filming and ensure that onl y

consenting persons will be allowed within 500 feet of the flight operatio n. • 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 b y the FOPM. • The Observer and pilot will be able to communicate b y voice and/or text at all ti mes. • Written and/or oral permission from the relevant propert y 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.
• Th e 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 safet y of current operations by requiring the PI C 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 b y a ground

- based operator. The operational area is controlled and restricted, and all flights are planned and coordinated in advanc e. 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 commerci al operations contemplated b y 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 a n aircraft before flight to insure the safet y of flight. As FAA approved rotorcraft flight manuals will not be used, an exemption is requested. However, an equivalent level of safet y will be provided. The PI C 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.
Se ction 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 o pen

water or sparsel y populated areas. In those cases, the aircraft may not be operated closer than 500 feet to an y 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 operate d in a restricted area within a securit y perimeter, where buildings and people will not be exposed to operations without their pre

- obtained consent. The equivalent level of safet y 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 propert y owners or local officials. Because of the advance notice to the propert y owners and participants in the filming activity, all affected individuals will be i nformed of the planned flight operations. Compared to flight operations for manned aircraft and the lack of flammable fuel, an y risk associated with the proposed UAS/APV operations is far less than conventional aircraft operating at or below 500 AGL. In ad dition, 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 b y 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 b y the operator, pursuant to the FOPM and Safet y Check list, confirming the altitude of the launch site shown on the G PS 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 weath er conditions) there is enough fuel to fly to the first point of intended landing, and, assuming normal cruising speed

– (1) During the day , to fl y after that for at least 30 minutes . . . .” The ty pical battery

powering the Drone Loan, LLC UAS/APVs provi des 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 loc ation, a longer time frame for flight in daylight VFR conditions is reasonable. Furthermore, operating the UAS/APVs in a tightl y controlled area where onl y people, property owners, or official representatives who have signed waivers will be allowed, less than 30 minutes of reserve fuel does not engender the t yp e of risk that §91.151(a) was intended to address.Drone Loan, LLC believes that safet y can be achieved b y 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 an ywhere i n 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 onl y to aircraft with an airworthiness certificate, these sections will not apply

to Drone Loan, LL C operations. Mai ntenance will be accomplished by the operator. An equivalent level of safet y will be achieved because the UAS/APVs are limited in size, will carry

a small payload and operate onl y 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 an y required maintenance, and keep a log of an y mainte nance performed. Moreover, the operator is the person most familiar with the UAS/APV and best suited to maintain it in an airworth y 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, rea l estate, inspection, S & R, and film industries will enhance safet y b y reducing risk. Conventional survey, agricultural, mapping, inspection, and film operations, using turbine aircraft, operate at low altitudes and present the risks associated with aircr aft 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 b y batteries eliminates virtually all of that ris k 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 oper ation of UAS/APVs conducted in the strict conditions outlined in the FOPM will provide an equivalent level of safet y supporting the grant of the exemption requested herein. The UAS/APVs operate at slow speeds, close to the ground, and in a secure environme nt. As a result, they are far safer than conventional operations conducted with turbine helicopters fl yi ng near the ground and people. **Privacy**All flights will occur over private or controlled access areas with the property owner’s prior consent and kn owledge. 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 2 012 (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 f or Drone Loan, LLC's UAS/APV commercial operations for the listed industries pursuant to the included FOPM.
If you have an y questions or need an y additional information, please contact the undersigned b y phone at 520 559 3292 or via email at droneloan@ho tmail.com Very Respectfully William Edward Ray