August 8, 2015 

Christopher Pendleton

Air Land Sea L.L.C. 

6770 West Via Tres Casas 

Tucson, Arizona 85743

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U.S. Department of Transportation

Docket Operations 

West Building Ground Floor 

Room WI 2-140

1200 New Jersey Avenue, SE., 

Washington, DC 20590-0001

RE: Exemption Request Section 333 of the FAA Reform Act of 2012 and Part 11 of the Federal

Aviation Regulations 

Dear Sir or Madam; 

In accordance with the Public Guidance for Petitions for Exemption filed under Section 333, Air 

Land Sea, LLC requests exemption from the Federal Aviation Regulations to allow for ·i ···

commercial UAS operations of a DJI Inspire 1, DJI Phantom 1, DJI Phantom 3 Professional, for the 

purpose of aerial photography, tower inspection, real estate marketing, surveying, agricultural mapping 

and other flight operations that could be performed safely and more cost effectively than a traditional 

manned aircraft. 

Applicant: 

Air Land Sea LLC 

Christopher Pendleton (President)

6770 West Via Tres Casas 

Tucson, AZ 85743 

 (520) 275-1663

Regulations from which the exemption is requested:

14 CFR 21, Subpart H

14 CFR 45.23 (b)

14 CFR 61.113 (a) & (b) & 14 CFR 61.133 (a)

14 CFR 91.7 (a)

14 CFR 91.9 (b)(2)

14 CFR 91.103 (b)(2)

14 CFR 91.109
14 CFR 91.119 (c)

14 CFR 91.121

14 CFR 91.151 (a)

14 CFR 91.203 (a) & (b)

14 CFR 91.405 (a)

14 CFR 91.407 (a)(l)

14 CFR 91.409 (a)(l) & (a)(2)

14 CFR 91.417 (a) & (b)

14 CFR 21, Subpart H -In consideration of the size, weight, speed, and limited operating area

associated with this UAS and its operation, Air Land Sea LLC requests relief from 14 CFR part 21,

Subpart H, and any associated noise certification and testing requirements of part 36. The UAS will

carry neither pilot, passenger, explosive materials or flammable liquids. 

14 CFR 45.23 (b) - Even though the UAS will have no airworthiness certificate, an exemption may be

needed as the UAS will have no entrance to the cabin, cockpit or pilot station on which the word

"Experimental" can be placed. Given the size of the UAS, two-inch lettering will be impossible. The 

word "Experimental" will be placed on the fuselage in compliance with §45.29 (t). The equivalent

level of safety will be provided by having the UAS marked on its fuselage as required by §45.29 (t)

where the pilot, observer and others working with the UAS will see the identification of the UAS as

"Experimental."

14 CFR 61.113 (a) & (b) & 14 CFR 61.133 (a) - Since the UAS will not carry a pilot or passengers

Air Land Sea LLC requests a relief from these regulations. Any pilot in command or (PIC) operating

the UAS will hold a Sport Pilot (or greater) certificate. A visual observer or (VO) will be utilized and 

required to communicate verbally at all times. The UAS will be limited to operations within visual

distance of both the PIC and VO. All UAS operations will take place in a controlled area. The risks 

associated with the use of a UAS are far less than similar commercial aircraft operations.

14 CFR 91.7 (a) - Since the UAS will not carry a pilot or passengers there will be no airworthiness

certificate issued for the aircraft, should this exemption be granted, no FAA regulatory standard exists 

for determining airworthiness. Given the size of the aircraft, maintenance, and use of safety checklist 

prior to each flight, an equivalent level of safety will be provided. All flights will be in accordance

with the safety and maintenance recommendations found in the DJI Operational, Safety and 

Maintenance Manuals.

14 CFR 91.9 (b)(2) - Given the size and configuration, the UAS has no ability to carry a flight manual

on the aircraft. There is no room, capacity, or pilot on board to adequately carry a flight manual. An

equivalent level of safety will be maintained by keeping the flight manual at the ground station where

the UAS pilot will have immediate access to it.

14 CFR 91.103 (b)(2) -As no FAA approved flight manuals will be provided for the aircraft an

exemption is needed. Alternate procedures including but not limited to reviewing weather conditions, 

checking flight battery requirements, checking takeoff and landing distances along with those found in

the DJI Operational, Safety and Maintenance Manuals will be implemented. These actions will 

provide an equivalent or higher level of safety.

14 CFR 91.109 - UAS and remotely piloted aircraft do not have fully functional dual controls. Flight

control is achieved through the use of a control box that communicates with the aircraft via radio

communications. An equivalent level of safety will be achieved using the real time ground station data 
and given the UAS will carry neither a pilot or passengers.

14 CFR 91.119 (c) -The UAS will never be operated at an altitude higher than 400 feet AGL. The

UAS will operate in safe areas away from public and traffic and only with permission of the property

and structure owners. The UAS will also be restricted by the flight controller to a maximum vertical

height of 400 feet AGL, and 1500 feet horizontal. Given the size, weight, maneuverability and speed

of the UAS, an equivalent or higher level of safety will be achieved. 

14 CFR 91.121 -As the UAS may not have a barometric altimeter, but instead a GPS barometric 

sensor for altitude information an exemption may be required. An equivalent level of safety will be

achieved using a ground station which links to a telemetry data link. This will provide the pilot with

live flight data monitoring, confirming the altitude of the launch site shown on the GPS altitude 

indicator prior to flight.

14 CFR 91.151 (a) - The UAS has a limited range and will be limited to operations in a controlled

environment. The battery power the UAS provides approximately 20 minutes of flight time. The UAS

is unable to meet the 30 minute reserve requirement and therefore requires an exemption. An

equivalent level of safety will be achieved by monitoring the battery through the ground station and

landing with a minimum of 30 percent battery power remaining. 

14 CFR 91.203 (a) & (b) - Given the size and configuration, the UAS has no ability to carry a flight 

manual on the aircraft. There is no room, capacity, or pilot on board to adequately carry a flight 

manual. An equivalent level of safety will be maintained by keeping the flight manual at the ground 

station where the UAS pilot will have immediate access to it.

Given the following sections only apply to aircraft with an airworthiness certificate, these sections do

not apply to this applicant. As a safety precaution, the operator will perform preflight inspections and

ensure UAS is in working condition before initiating each flight: 

14 CFR 91.405 (a)

14 CFR 91.407 (a)(l)

14 CFR 91.409 (a)(l) & (a)(2)

14 CFR 91.417 (a) & (b)

Equivalent Level of Safety

In addition to the safety standards mentioned above the UAS will adhere to the following additional 

guidelines:

1. The UAS will not be operated within 5 miles of an airport unless prior contact to Air Traffic

Control has been established.

2. Flights will not exceed the an airspeed of 100 mph (87 knots)

3. Flights will be operated at or below an altitude never exceeding 400 feet AGL.

4. The PIC and VO will communicate verbally at all times.

5. UAS operations will not be conducted during night.

6. All operations will be conducted under visual meteorological conditions.

7. The UAS will land with a minimum 30 percent battery reserve remaining.

8. The UAS will only be piloted within visual line of sight.

9. The UAS will utilize an internal flight safety feature that will return to a preprogrammed 

position and land if communication with the remote control is lost.
10. Preflight inspections and protocol will be followed prior to all operations.

11. The UAS will abort flight in the event of unpredictable obstacles or emergencies.

Public Interest

We believe the use of a UAS in lieu of a manned aircraft would enhance safety and reduce the

environmental impact compared to similar operations conducted with a manned aircraft carrying a crew

and :flammable fuel. 

The inspections of cellular communication towers or similar structures will eliminate the risks 

associated with persons attempting to climb these structures. The photographs and video collected will

provide engineers with valuable information as to the safety of these structures.

The use of a UAS in the real estate industry provides both the buyer and seller with a higher

level of marketing and service. The UAS is able to provide a view which encompasses the entire

property in a single photo or short video clip. When compared to similar operations, utilizing a UAS

poses much less of a safety concern for the general public with less fuel, time, noise and other

resources. 

Privacy

All flights will occur over private or controlled areas with the owner's consent. Capturing people in

images will rarely occur. If a person is captured in a collected image they will have consented prior to

filming or otherwise have agreed to being in the area prior to the filming taking place.

Christopher Pendleton 

President