Attn: To Whom It May Concern:

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

Act) and 14 C.F.R. Part 11, Palm Beach Executive Aviation, LLC, operator of Small 

Unmanned Aircraft Systems(“sUASs”) equipped to conduct aerial photography and 

videography, 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 333.1. 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 and 3) controlled. The proposed exemption, if granted, would allow Palm 

Beach Executive Aviation, LLC to conduct commercial operations of small unmanned

aircraft systems (“UAS”) meeting or exceeding all of the operational and safety

requirements Congress has set forth in Section 333, Page 2. Palm Beach Executive 

Aviation, LLC is an aviation services company owned and run by Jeffrey R. Anderson.

Mr. Anderson has an Airline Transport Certificate and is type rated in multiple transport 

aircraft. He has 22 years experience flying military airlift operations as well as Part 91 

and Part 121 large cabin operations. His total time is over 8,000 hours. Palm Beach 

Executive Aviation, LLC plans to exploit the capabilities of Unmanned Aerial Systems to 

offer a multitude of services, including:

- Aerial surveying

- Event Photography/Videography

- Golf Course Mapping

- Insurance Company Surveys

- Agriculture purposes

- Real Estate Photography/Videography

- Aerial Filmmaking and Photography

- Construction site inspections and monitoring

Statutory Authority Section 333, titled “Special Rules for Certain Unmanned Aircraft

Systems”, provides a mechanism for seeking expedited FAA authorization of safe civil 

UAS operations in the NAS. Section 333(a) states that the FAA “shall determine if 

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

before completion of the (comprehensive) plan and rulemaking required by section 

332(b)(1) of this Act or the guidance required by section 334 of this Act.” In Section 

332(b)(1), Congress made it clear that Section 333 provides a mechanism for “expedited 

operation authorization” if several factors are met. Petitioner meets all requirements to 

permit FAA approval of commercial UAS operations. The petitioner requests relief from 

the following regulations from which the exemption is requested:

14 C.F.R. Part 21

14 C.F.R. 45.23 (b)

14 C.F.R. 61.113(a) and (b)

14 C.F.R. 91.7 (a)

14 C.F.R. 91.9 (b) (2)

14 C.F.R. 91.109

14 C.F.R. 91.119
14 C.F.R. 91.121

14 C.F.R. 91.151(a)

14 C.F.R. 91.203 (a) & (b)

14 C.F.R. 91.205 (b)

14 C.F.R. 91.215

14 C.F.R. (91.401 - 91.417)

Unmanned Aircraft System (UAS) are often times seen as superior to helicopters due to 

the smaller devices, cheaper equipment and personnel cost, reduced noise and as such, a 

much smaller environmental impact which promotes public safety. We are petitioning 

for exemption to enable Palm Beach Executive Aviation, LLC to operate a DJI Inspire 1

sUAS upgraded to the Version 1.2.1.03 firmware and equipped with a two-axis camera

gimbal and using a High-Definition camera. This sUAS has a built-in capability to limit 

the height it flies above the ground and to limit the radius of the distance it flies from the

operator. The Inspire 1 also has the failsafe function of the autopilot system which means

when the communication between the Main Controller and the transmitter is 

disconnected, the outputs of all command sticks from controller will go to the center 

position. If the GPS signal is good enough, the system will automatically trigger a 

Return to Home function and will automatically land safely.

Please refer to the included DJI Inspire 1 Instruction Manual for the performance 

limitations and flight operations. Aircraft weight is 6.5 lbs with battery, 2-Axis Camera 

Gimbal, and Camera. A pre-flight inspection will be performed by the PIC in accordance 

with the factory instruction manual. An added step will be the inspection of the 

propellers. A propeller will be replaced if it has any nicks and cracks with a 

manufacturers authorized propeller. The sUAS will be maintained in accordance with the 

manufacturers instruction manual and only manufacturer's authorized replacement parts 

will be used.

FCC Information:

The Inspire 1 Remote Controllers will be used for controlling the sUAS and complies 

with part 15 of the FCC rules. Operation is subject to the following two conditions: (1) 

This device may not cause harmful interference, and (2) this device must accept any 

interference received, including interference that may cause undesired operation. The 

Inspire 1 radio transmitter used for controlling the sUAS is wireless technology which 

has been tested and found to be compliant with the applicable regulations governing a 

radio transmitter in the 2.400GHz frequency with a maximum transmission distance of 

2km.

Antenna Separation Distance:

When operating our Inspire 1 transmitter, the PIC will maintain a separation distance of 

at least 5 cm between his body (excluding fingers, hands, wrists, ankles and feet) and the

antenna to meet RF exposure safety requirements as determined by FCC regulations.

Pilot in Command and Observer Qualifications and Duties:

The PIC will maintain at least a Private Pilot Certificate and a current Class III medical

certificate, plus at least 2 hours flying time and 3 takeoffs and landings within 30 days in 

the type of UAS utilized in operations. The PIC will have at least 100 hours total time 
and at least 30 hours flying Radio Controlled Model Aircraft of which will be 10 hours 

flying sUAS's. Training will be conducted at a local Radio Control Club flying field. 

Palm Beach Executive Aviation, LLC has the ability to provide "dual controls" utilizing 

two Inspire 1 transmitters with a wireless link between the transmitters. One transmitter is 

designated the master transmitter and the other transmitter is designated as a slave. The 

PIC instructor, utilizing the master transmitter, will be at all times be able assume control 

of the sUAS. The PIC is responsible for the safe and efficient operation of the aircraft. 

Specific duties include all preflight preparation, in-flight operation, post-flight 

requirements, all procedures including but not limited to: Safe in-flight operations; Risk 

Mitigation to Persons and property; Airfield Suitability. The Observer must have the 

visual acuity to observe the sUAV and be able to communicate clearly with the PIC.

The Observers duties are:

-- warning the PIC of any impending obstacles in the flight path of the sUAS.

-- warning the PIC of any deviations in the planned flight path of the sUAS.

-- warning the PIC should any unauthorized personnel appear in the area of the planned

flight. The Observer will have the authority to order the PIC to terminate the flight 

should he feel the flight cannot be conducted safely.

General Operating Standards

• Palm Beach Executive Aviation, LLC will only operate its sUAS in line of sight of a 

pilot and/or observer and will operate at sites that are a 'sufficient distance' from 

populated areas. Such operations will insure that the sUAS will "not create a hazard to 

users of the national airspace system or the public."

• Before an operation of a sUAV within 5NM of an airport with a control tower, the 

control tower will be notified to gain permission to operate the sUAS. The PIC will give 

the position, altitude and the times the sUAV will be operated. The sUAS will not be 

operated at an altitude of over 300 feet AGL. Weather minimums will be 3 miles 

visibility and a 1000 foot ceiling. Before an operation of a sUAS within 5NM of a nontower controlled, airport operators will be notified and the PIC will give the right of way

to avoid flying in the proximity of full-scale aircraft. At no time will the sUAV be 

operated within the final approach course and the takeoff course of any runway.

• Maximum flight time for each operational flight will be 30 minutes.

• Flights will be terminated at 25% battery power reserve should that occur prior to the 30

minute limit.

• The sUAV will be programmed so that it will not be operated at an altitude of more 

than 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 sUAS Pilot, and Visual Observer.

• The sUAV operated by the petitioner weighs less than 55 pounds, including the payload

(i.e. camera, lens, and gimbals).

• The sUAV will operate at speeds of no more than 25 knots, can hover, and can

simultaneously move vertically and horizontally.

• Given the small size of the sUAV and the restricted sterile environment within which 

they will operate, our sUAV operations adhere to the Reform Act's safety requirements. 

The UAS, powered by batteries, is smaller, lighter and more maneuverable than larger
aircraft running on combustible fuel, it operates at lower altitudes with no people on 

board and will thereby reduce current risk levels and thereby enhance safety and diminish 

the likelihood of death or serious bodily injury. With a small payload and maximum 

flight time of only 20 minutes, this offers little or no risk to national security. Low level 

oblique photos and video from several angles are far more effective than ground based 

imagery for displaying the characteristics of large, complex properties with several

buildings and large trees. Compared to manned aircraft, the benefits of reduced cost and

improved quality of presentation from the UA will be valuable to and benefit many

buyers and sellers of real property. Additionally, we request that we be allowed to use our 

system to benefit first responders nearby who might require assistance, including fire 

fighters, the police, the sheriff, et al., while remaining subject to all limitations cited in 

this application as we do so. (a) No flight will be made with a Gross weight exceeding 55 

pounds;

(b) All operations must occur in FAA Class G airspace at no more than 400 ft AGL, at an

airspeed of no more than 25 knots and no further than 3/4 NM from the PIC;

(c) All operations must utilize a visual observer (VO). The VO and PIC must be able to

communicate by voice at all times during a flight operation;

(d) Operations will be restricted to flights over private property with the permission of the

property owner;

(e) All required permits will be obtained from state and local government prior to 

operation;

(f) Palm Beach Executive Aviation, LLC UAS aircraft will not be operated over densely 

populated areas;

(g) Palm Beach Executive Aviation, LLC UAS aircraft will not be operating over any

open-air assembly of people;

(h) Palm Beach Executive Aviation, LLC UAS aircraft will not be operating over heavily 

traffic roads;

(i) Palm Beach Executive Aviation, LLC UAS aircraft will not be operating at night.

EXEMPTION REQUESTS AND EQUIVALENT LEVEL OF SAFETY

Palm Beach Executive Aviation, LLC requests an exemption from the following 

regulations as well as any additional regulations that may technically apply to the 

operation of the sUAV System:

14 CFR Part 21, Airworthiness Certificates

This part establishes the procedures for the issuance of an airworthiness certificate. While

the FAA continues to work to develop airworthiness standards for Unmanned Aerial 

Systems, we request an experimental certificate be issued for the DJI Inspire 1 under 

either or both of the following provisions:

21.191 Experimental certificates. Experimental certificates are issued for the following

purposes: (a) Research and development. Testing new aircraft design concepts, new

aircraft equipment, new aircraft installations, new aircraft operating techniques, or new

uses for aircraft. (b) Showing compliance with regulations. Conducting flight tests and

other operations to show compliance with the airworthiness regulations including flights 

to show compliance for issuance of type and supplemental type certificates, flights to

substantiate major design changes, and flights to show compliance with the function and

reliability requirements of the regulations. Since the experimental certificate can be used

for commercial purposes such as market surveys, sales demonstrations, and customer 
crew training, we would expect that an experimental certificate would permit our 

commercial purpose as well. The aircraft will not carry persons or property, will not carry

fuel, and will only fly under strict operational requirements. Combined with the UA's 

light weight, being constructed primarily of carbon fiber and plastic, we propose that the 

UA will be at least as safe, if not safer, than a conventionally certificated aircraft 

performing the same mission. If an experimental airworthiness certificate is not 

appropriate for this application, then we request an exemption of 14 CFR Part 21, Subpart 

H, and the requirement for an airworthiness certificate in general, citing the equivalent 

level of safety outlined in the previous paragraph.

14 CFR 45.23 Display of marks; general and 45.29 Size of marks.

These regulations provide that each aircraft must display "N" and the aircraft's 

registration number in letters at least 3 inches high. Additionally, the aircraft must display

the word "EXPERIMENTAL" in letters at least 2 inches high near the entrance to the 

cabin, cockpit, or pilot station. The sUAV does not have an entrance in which the word 

"EXPERIMENTAL" can be placed, and may not have a registration number assigned to 

it by the FAA. We propose to achieve an equivalent level of safety by including the word 

"EXPERIMENTAL" in the placard on the top of the aircraft, as shown above, where the 

PIC (Pilot In Control), VO (Visual Observer) and others in the vicinity of the aircraft 

while it is preparing for launch will be able to see the designation. Additionally, we feel 

that the permanent placard discussed in the previous paragraph will provide the aircraft's 

registration information at the ground station. Finally, we will display at the ground 

station a high contrast flag or banner that contains the words "Unmanned Aircraft Ground 

Station" in letters 3 inches high or greater. Since the aircraft will operate within 3/4 NM 

of the ground station, the banner should be visible to anyone that observes the aircraft and 

chooses to investigate its point of origin. 14 CFR 61.113 Private pilot privileges and 

limitations: Pilot in Command and 61.133

Commercial pilot privileges and limitations.

The regulation provides that no person that holds a Private Pilot certificate may act as 

pilot in Command of an aircraft for compensation or hire. Subparagraph (b) allows a 

private pilot to act as pilot in command of an aircraft in connection with any business or 

employment if:

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

not carry passengers or property for compensation or hire. Our proposed operations 

require that the PIC must hold at least a Private Pilot Certificate with a Class III Medical 

issued by the FAA and since the aircraft cannot carry passengers or property, we feel we 

meet the intent of 61.113 Subparagraph (b) even though the intent of this application is to 

conduct a business.

14 CFR 91.7 Prohibits the Operation of an aircraft without an airworthiness certificate. 

As no such certificate will be applicable in the form contemplated by the FARs, this

Regulation is inapplicable.

14 CFR 91.9 Civil aircraft flight manual, marking, and placard requirements. This

regulation provides that no person may operate an aircraft unless a current, approved 
flight manual is in the aircraft. We assume that the intent of this requirement is to ensure 

that flight manual information is available to the aircrew while operating the aircraft. We

request an exemption to this requirement since the aircraft is not only too small to carry

documentation, the documentation would not be available to the crew during flight

operations. To obtain an equivalent level of safety and meet the intent of 91.9, we 

propose that a current, approved sUAS Flight Manual must be available to the crew at the 

ground station anytime the aircraft is in, or preparing for, flight.

14 CFR 91.109 Flight Instruction; Simulated instrument flight and certain flight tests The

regulation states that "No person may operate a civil aircraft that is being used for flight

instruction unless that aircraft has fully functioning dual controls." Training will be

conducted at a local Radio Control Club flying field. Palm Beach Executive Aviation, 

LLC has the ability to provide "dual controls" utilizing two Inspire 1 transmitters with a 

wireless link between the transmitters. One transmitter is designated the master 

transmitter and the other transmitter is designated as a slave. The PIC instructor, utilizing 

the master transmitter, will be at all times be able assume control of the sUAV.

91.119 Minimum safe altitudes:

General. The regulation states that over sparsely populated areas the aircraft cannot be

operated closer than 500 feet to any person, vessel, vehicle, or structure. Since the typical

mission of the sUAS would be photography or survey of persons, vessels, vehicles or

structures it would be necessary to operate closer than 500 feet to the items listed. 

Operations will only be flown over property or persons where permission has been 

obtained and careful pre-planned flight path has been performed. The aircraft will be 

operated at a low altitude allowing, if a power unit fails, an emergency landing without 

undue hazard to persons or property on the surface. Therefore we maintain that due to the 

small size of the UAS, the hazard to persons, vehicles and structures is minimal 

compared to manned aircraft, which should be considered in granting the exemption.

CFR 91.121 Altimeter settings.

The regulation requires that aircraft shall maintain cruising altitudes by reference to an

altimeter setting available within 100 NM of the aircraft. The sUAS will always fly 

below 400 feet AGL and will not need to maintain cruising altitudes in order to prevent 

conflict with other aircraft. An Above Ground Level altimeter measurement above the 

takeoff point is transmitted via radio from the sUAS on-board computer to the display

screen held by the PIC, providing a constantly updated AGL readout.

14 CFR 91.151 Fuel requirements for flight in VFR conditions.

The regulation provides that no person may begin a flight in an airplane under day-VFR

conditions unless there is enough fuel to fly to the first point of intended landing and to 

fly after that for at least 30 minutes. We feel the intention of this paragraph is to provide 

an energy reserve as a safety buffer for delays to landing. The sUAV is battery operated 

and the maximum duration of flight from a single battery charge is 12 minutes with a 

20% reserve. Since the aircraft will never fly more than 3/4 NM from the point of 

intended landing, a full battery charge at launch will ensure that we meet the reserve 

energy requirement of this paragraph. We request an exemption to the word "fuel" and 
ask for an equivalent interpretation with the word "energy".

14 CFR 91.203(a) & (b) Civil aircraft: Certifications required.

The regulation provides that an airworthiness certificate, with the registration number

assigned to the aircraft and a registration certificate must be aboard the aircraft. 

Additionally, subparagraph (b) provides that the airworthiness certificate be "displayed at

the cabin or cockpit entrance so that it is legible to passengers or crew." At a maximum 

gross weight of 6.5 pounds, the sUAS is too small to carry documentation, does not have 

an entrance, and is not capable of carrying passengers or crew. To obtain an equivalent 

level of safety and meet the intent of 91.203, we propose that documents deemed 

appropriate for this aircraft by the FAA will be with the crew at the ground control station 

and available for inspection upon request. In order to identify the aircraft, we propose that 

the information found on airworthiness and registration certificates be permanently

affixed to the aircraft via placard containing the following information plus the word 

"EXPERIMENTAL" to satisfy the requirement of 14 CFR 45.23.

14 CFR Subpart E (91.401- 91.417)- Maintenance, Preventive Maintenance, Alterations

The regulation provides that the operator is primarily responsible for maintaining the

aircraft in an airworthy condition, including compliance with part 39 and 43. Paragraphs

91.407 and 91.409 require that the aircraft be "approved for return to service by a person

authorized under 43.7" after maintenance and inspection. It is our intention that the PIC

perform maintenance and inspection of the aircraft and "be authorized to approve the

aircraft for return to service." The PIC will ensure that the aircraft is in an airworthy

condition prior to every flight and in addition conduct detailed inspections after every

two hours of flight. Maintenance performed by the PIC is limited to repairing small 

cracks, replacing a propeller, checking electrical connections and updating software and 

firmware for the on-board computer. All other maintenance will be performed by the 

manufacturer or their designated repair facility. The PIC will document work performed 

in accordance with 91.417. We feel that due to the size, construction, and simplicity of 

the aircraft, the PIC can ensure an equivalent level of safety.

Safety and Benefits of the UAS

Palm Beach Executive Aviation, LLC will be using the UAS in a variety of applications 

that generally require expensive full-size manned aircraft to complete. Small, light, 

unmanned aerial vehicles offer myriad benefits over the use of full-sized manned aircraft 

for electric power line inspection, oil/gas pipeline inspection, advanced agriculture, film 

and still photography, just to name a few. Replacing significantly larger manned aircraft 

carrying crew and flammable fuel with small UAS carrying no passengers or crew creates 

a much greater margin of safety for the pilots and crew. By granting Palm Beach 

Executive Aviation, LLC‘s requested exemptions, the FAA will help drive development 

of safe and successful commercial UAS operations and will advance the public 

knowledge base for such operations. Palm Beach Executive Aviation, LLC is committed 

to promoting the UAS research efforts of policymakers including the FAA, NASA, DOD, 

and DARPA by sharing data from its commercial UAS operations and serving as a 

resource for future UAS research operations. Thus, the FAA has good cause to grant this 

Petition.
As pointed out in this application, all the sUAS which our company would use, under

authorization by the US DOT-FAA, are small, light-weight devices operated within the 

line of sight (LOS) of the Pilot-in-Command (PIC), less than 400 feet above the ground 

and outside 5 miles from any airport, heliport, seaplane base, spaceport, or other location 

with aviation activities, unless the air traffic control authorities (ATC) have been notified 

and have authorized each flight within a radius of this distance.

All of our sUAS have proven capability for controlled flight. They are devices offered

for general sale on the market around the world and have often been used as Model 

Aircraft in the USA. We are certain that the studies conducted until now by the FAA, 

about Section 332, Public Law 112-95, 2014, have already provided you with the 

assurances on the airworthiness of sUAS such as ours. For the foregoing reasons, the 

exemptions requested herein should be granted and Palm Beach Executive Aviation, LLC 

should be permitted to conduct small UAS operations in accordance with its manuals and 

all other operating parameters deemed necessary and appropriate by the FAA. The 

submission of this application and its contents is the best demonstration that indeed it is

possible to pursue the authorization process so that some sUAS may be used for 

legitimate commercial activities and under reasonably safe conditions.

Signed,

Jeffrey R. Anderson

Palm Beach Executive Aviation, LLC