FROM:

Ronnie Krupa

T. Layne Enterprises, LLC (D.B.A. 4 Forks Media Production)

3062 Hogback Hill 

PO Box 3

Mineral Springs, PA 16855

Tel: 814.577.0872

Email: Ronnie@4forksmedia.com

TO:

DOCKET OPERATIONS

ROOM W12-140 OF THE WEST BUILDING

GROUND FLOOR

1200 NEW JERSEY AVENUE, SE.

WASHINGTON, DC, 20590

Regulatory Docket No. _______________

PETITION FOR EXEMPTION OF:

T. Layne Enterprises, LLC 

FOR AN EXEMPTION SEEKING RELIEF FROM THE REQUIREMENTS OF

TITLE 14 OF THE CODE OF FEDERAL REGULATIONS

PART 21, SUBPART H AND SECTIONS §§ 61.113(a) & (b), 91.109, 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)

CONCERNING COMMERCIAL

OPERATION OF 3D Robotics IRIS+ PROFESSIONAL

UNMANNED AIRCRAFT SYSTEMS

PURSUANT TO SECTION 333 OF

THE FAA MODERNIZATION AND REFORM ACT OF 2012

(PUBLIC LAW 112-95)

Submitted April 28, 2015
T. Layne Enterprises, LLC Petition for Exemption Section 333 FAA 2

TABLE OF CONTENTS

GLOSSARYOFABBREVIATIONS...................................................................................3

SUMMARY.........................................................................................................................4

INTRODUCTION AND INTERESTS OF PETITIONER.................................................4

BACKGROUND.................................................................................................................4

BASIS FOR PETITION......................................................................................................5

NAME AND ADDRESS OF PETITIONER......................................................................6

THE SPECIFIC SECTIONS OF 14 C.F.R. FROM WHICH T. LAYNE 

ENTERPRISES, LLC SEEKS EXEMPTION....................................................................6

THE EXTENT OF RELIEF T. LAYNE ENTERPRISES, LLC FILMS SEEKS AND 

THE REASON T. LAYNE ENTERPRISES, LLC SEEKS THE RELIEF......................8

THE REASONS WHY GRANTING T. LAYNE ENTERPRISES, LLC’S REQUEST

WOULD BE IN THE PUBLIC INTEREST ..................................................................10

THE REASONS WHY GRANTING THE EXEMPTION WOULD NOT

ADVERSELY AFFECT SAFETY....................................................................................12

SUMMARY THAT CAN BE PUBLISHED IN THE FEDERAL REGISTER...............19

ANY ADDITIONAL INFORMATION, VIEWS, OR ARGUMENT .............................19

CONCLUSION......................................................................................20
T. Layne Enterprises, LLC Petition for Exemption Section 333 FAA 3

GLOSSARY OF ABBREVIATIONS

AGL Above Ground Level

ATC Air Traffic Control

ATO Air Traffic Organization

AV Aerial Vehicle

CFR Code of Federal Regulations

COA Certificate of Authorization

FAA Federal Aviation Administration

FAR Federal Aviation Regulation

GCS Ground Control Station

GPS Global Positioning System

LOL Loss of Link

NAS National Airspace System

NOTAM Notice to Airman

PIC Pilot In Command

ROI Region Of Interest

Section 333 FAA Modernization and Reform Act of 2012 (FMRA) Section 333

SO Safety Observer

SOP Standard Operating Procedures

UA Unmanned Aircraft

UAS Unmanned Aircraft System

VFR Visual Flight Rules

VLOS Visual Line of Site

VMC Visual Meteorological Conditions

VTOL Vertical Takeoff and Landing
T. Layne Enterprises, LLC Petition for Exemption Section 333 FAA 4

SUMMARY

T. Layne Enterprises, LLC (Ronnie Krupa) seeks exemption from the requirements of 14 

C.F.R §§61.113(a) & (b), 91.109, 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), to operate an Unmanned Aircraft System 

pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (FMRA). 

This exemption will permit T. Layne Enterprises, LLC to operate an Unmanned Aircraft 

System (UAS) for the commercial purpose of conducting aerial video and photography of 

Real Estate Properties (for homeowners, realtors, home builders, home contractors and / 

or home inspectors for real estate marketing and inspection of home exteriors) as well as 

filming of special events, film sets, scripted and unscripted television sets and landscape 

over certain areas of the United States.

INTRODUCTION AND INTERESTS OF THE PETITIONER

T. Layne Enterprises, LLC (D.B.A. 4 Forks Media Production) is a production company 

based in Pennsylvania specializing in real estate videography, photography, music video 

production, special event production with plans to extend into web based film production. 

The members of T. Layne Enterprises, LLC have been in the video and entertainment 

production business for one year; have produced several business promotional videos, 

event videos and real estate videos. T. Layne Enterprises, LLC’s objective is to conduct 

aerial photography and videography in order to provide high quality digital imaging and 

video content to its clients, in particular to homeowners, real estate agents, realtors, home 

builders, home contractors, and/or home inspectors for real estate marketing and 

inspections of home exteriors utilizing 3D Robotics IRIS+ UAS. More specifically, T. 

Layne Enterprises, LLC’s aerial video and photography operations will serve in the 

following areas:

• Aerial photography of houses / residential and commercial buildings

• Aerial videography of houses / residential and commercial buildings

• Aerial event photography

• Aerial event filming

• Aerial Film production

• Aerial location scouting and safety inspection

• Increase public knowledge of UAS and promote safe UAS operations.

The proposed aerial filming will be conducted over private property with controlled 

access in the NAS and with the knowledge and permit of the private property’s owner.

Unmanned Aircraft Systems: 3D Robotics IRIS+ Professional UAS

T. Layne Enterprises, LLC seeks an exemption to operate 3D Robotics IRIS+ 

Professional UAS DRONES for compensation or hire within the NAS. The 3D Robotics 

IRIS+ Professional UAS are vertical takeoff and landing (VTOL) Unmanned Aircrafts 

(UAS) with a Ground Control Station (GCS) utilizing electronic tablet or smart phone 

systems. The 3D Robotics IRIS+ Professional UAS have a maximum gross weight of 

approximately 2lbs 8oz, while having a length of 19.5 inches width of 19.5 inches, 

height of 4 inches, and a maximum speed of approximately 29 knots.

The 3D Robotics IRIS+ Professional UAS is equipped with four main rotors;

driven by Lithium Polymer battery powered electric motors. The 3D Robotics IRIS+ 
T. Layne Enterprises, LLC Petition for Exemption Section 333 FAA 5

Professional UAS that will be operated by T. Layne Enterprises, LLC will be registered 

in accordance with 49 U.S.C. 44103, Registration of Aircraft, as well as 14 C.F.R Part 

47, Aircraft Registration, and marked in accordance with 14 C.F.R. Part 45, Identification 

and Registration Marking.

BASIS FOR PETITION

Petitioner, T. Layne Enterprises, LLC, pursuant to the provisions of the Federal Aviation

Regulations (14 C.F.R. § 11.61) and the FAA Modernization and Reform Act of 2012

(FMRA), Section 333, Special Rules for Certain Unmanned Aircraft Systems, hereby

petitions the Administrator to commercially operate the 3D Robotics IRIS+ Professional 

UAS in the National Airspace System (NAS), and for an exemption from the 

requirements of 14 C.F.R§§ 61.113(a) & (b), 91.109, 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 speed, weight, size, and limited operating area associated

with the unmanned aircraft and its operation, T. Layne Enterprises, LLC’s operation of 

3D Robotics IRIS+ UAS meets the conditions of FMRA Section 333 and therefore,

will not require an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart 

H. Accordingly, T. Layne Enterprises, LLC 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.

T. Layne Enterprises, LLC submits that the requested relief is proper since an equivalent

level of safety will be ensured. T. Layne Enterprises, LLC will use experienced personnel 

or technicians to perform maintenance, alterations, or preventive maintenance on the 

UASs using the methods, techniques, and practices prescribed in the operating documents 

(i.e., Monthly Maintenance Log, and 3D Robotics IRIS+ Instruction Manual). 

Furthermore, T. Layne Enterprises, LLC will document and maintain all maintenance

records for the 3D Robotics IRIS+ Professional UAS. T. Layne Enterprises, LLC seeks 

relief from Section 91.7(a), entitled Civil aircraft airworthiness, because the 3D Robotics 

IRIS+ Professional UAS do not require an airworthiness certificate in accordance with 14 

C.F.R. Part 21, Subpart H. As such, T. Layne Enterprises, LLC submits that it will ensure 

that the 3D Robotics IRIS+ Professional UAS is in an airworthy condition, prior to every 

flight, by determining that the UASs are in compliance with the operating documents 

(i.e., Monthly Maintenance Log, and 3D Robotics Instruction Manual), and that the 

aircraft are in a condition for safe flight. T. Layne Enterprises, LLC also seeks an 

exemption from the requirements of Section 91.121, entitled Altimeter Settings, as the 

3D Robotics IRIS+ Professional UAS will not have a typical barometric altimeter 

onboard. However, altitude information of the 3D Robotics IRIS+ Professional UA will 

be provided to the PIC via Global Positioning System (GPS) equipment and radio 

communications telemetry data link, which downlinks from the UA to the GCS for active 

monitoring of the flight path. This altitude information, combined with T. Layne 

Enterprises, LLC’s operation of the 3D Robotics IRIS+ Professional UAS within visual 

line of sight, at or below 200 feet AGL, will ensure a level of safety equivalent to Section 

91.121.

Additionally, T. Layne Enterprises, LLC seeks an exemption from the requirements of

Section 91.151(b), entitled Fuel requirements for flight in VFR conditions. T. Layne 
T. Layne Enterprises, LLC Petition for Exemption Section 333 FAA 6

Enterprises, LLC submits that safety will not be affected by operation of the 3D Robotics 

IRIS+ Professional UA during daylight hours in visual meteorological conditions (VMC) 

under visual flight rules (VFR), with enough battery power to fly for a total duration of 

approximately 15 minutes to the first point of intended landing and, assuming normal 

cruising speed, to fly after that for at least 4.5 minutes. In accordance with 14 C.F.R. § 

11.81, 

T. Layne Enterprises, LLC provides the following information in support of its petition 

for exemption:

A. Name And Address Of The Petitioner.

The name and address of the Petitioner and point of contact is:

Ronnie Krupa

T. Layne Enterprises, LLC 

3062 Hogback Hill 

PO Box 3

Mineral Springs, PA 16855

Tel: 814.577.0872

Email: Ronnie@4forksmedia.com

B. The Specific Sections Of 14 C.F.R. From Which T. Layne Enterprises, LLC Seeks

Exemption.

1. T. Layne Enterprises, LLC 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. T. Layne Enterprises, LLC Seeks Exemption From The Requirements Of Section 

91.121.

Section 91.121, entitled Altimeter settings, subsection (a), states the following, in 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. T. Layne Enterprises, LLC 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:
T. Layne Enterprises, LLC Petition for Exemption Section 333 FAA 7

(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. T. Layne Enterprises, LLC 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. T. Layne Enterprises, LLC 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. T. Layne Enterprises, LLC 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.

7. T. Layne Enterprises, LLC 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
T. Layne Enterprises, LLC Petition for Exemption Section 333 FAA 8

(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 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.

C. The Extent Of Relief T. Layne Enterprises, LLC Seeks And The Reason T. Layne 

Enterprises, LLC The Relief.

2. Extent Of Relief T. Layne Enterprises, LLC Seeks And The Reason T. Layne 

Enterprises, LLC 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 T. Layne Enterprises, LLC to determine that the 3D Robotics IRIS+

UAS are in airworthy condition prior to every flight by ensuring that the UAS is in 

compliance with the operating documents (i.e., the Monthly Maintenance Log, and 3D 

Robotics IRIS+ Professional Instruction Manual).

T. Layne Enterprises, LLC seeks the requested relief because the 3D Robotics IRIS+

UAS do not require an airworthiness certificate in accordance with 14

C.F.R. Part 21, Subpart H. Therefore, T. Layne Enterprises, LLC will ensure that the

3D Robotics IRIS+ UAS is in airworthy condition based upon its compliance with the 

operating documents (i.e., Monthly Maintenance Log, and 3D Robotics IRIS+ 

Professional Instruction Manual) prior to every flight, and further, determine that the 

aircraft are in condition for safe flight, as stated in the conditions and limitations below.
T. Layne Enterprises, LLC Petition for Exemption Section 333 FAA 9

3. Extent Of Relief T. Layne Enterprises, LLC Seeks And The Reason T. Layne 

Enterprises, LLC Seeks Relief From Section 91.121.

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

operations of the 3D Robotics IRIS+ Professional UAS, which utilize a barometric 

pressure sensor, GPS equipment, and a radio communications telemetry data link to 

downlink altitude information from the UA to the PIC at the ground control station 

(GCS). Since the FAA requires that any altitude information concerning UAS operations 

be reported to air traffic control (ATC) in feet above ground level (AGL), T. Layne 

Enterprises, LLC seeks the requested relief because the 3D Robotics IRIS+ UA’s 

altimeter may be set on the ground to zero feet AGL, rather than the local barometric 

pressure or field altitude, before each flight. Considering the limited altitude of the 

proposed operations, relief from 14 CFR 91.121 is sought to the extent necessary to 

comply with the applicable conditions and limitations stated below. As more fully set

forth herein, an equivalent level of safety will be maintained since the 3D Robotics IRIS+ 

Professional UAS are equipped with a barometric pressure sensor and GPS equipment, 

which automatically ensures that a ground level pressure setting will be established prior 

to each flight, and provides the PIC with altitude information of the UA on the heads-up 

display of the GCS.

4. Extent Of Relief T. Layne Enterprises, LLC Seeks And The Reason T. Layne 

Enterprises, LLC 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 3D Robotics 

IRIS+ Professional UAS during daylight hours in visual meteorological conditions 

(VMC), under visual flight rules (VFR), for a total duration of 15 minutes to the first 

point of intended landing and, assuming normal cruising speed, to fly after that for at 

least 4.5 minutes. T. Layne Enterprises, LLC seeks the requested relief because without 

an exemption from Section 91.151(b), the flight time duration of the battery powered 3D 

Robotics IRIS+ UA will severely constrain the practicality of any

aerial video or still photo flight operations that T. Layne Enterprises, LLC proposes to

conduct pursuant to this Petition. Significantly, as set forth below, the technical 

specifications of the 3D Robotics IRIS+ Professional operating documents, and T. Layne 

Enterprises, LLC proposed operating limitations, ensure that

T. Layne Enterprises, LLC will safely operate the battery powered 3D Robotics IRIS+

Professional UAS during daylight hours in visual meteorological conditions (VMC), 

under visual flight rules (VFR), with enough battery power to fly for a total duration of 

13.5 minutes to the first point of intended landing and, assuming normal cruising speed, 

to fly after that for at least 4.5 minutes.

5. Extent Of T. Layne Enterprises, LLC Seeks And The Reason T. Layne Enterprises, 

LLC Seeks Relief From Section 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, T. Layne Enterprises, LLC 

requests relief from these Sections because the 3D Robotics IRIS+ Professional UAS do 

not require airworthiness certificates. As set forth more fully below, the 3D Robotics 
T. Layne Enterprises, LLC Petition for Exemption Section 333 FAA 10

IRIS+ Professional UAS meet the conditions of FMRA Section 333 for operation without 

an airworthiness certificate. Accordingly, T. Layne Enterprises, LLC will use trained 

technicians to perform maintenance, alterations, or preventive maintenance on the UAS 

using the methods, techniques, and practices prescribed in the UAS operating

documents (i.e., the Monthly Maintenance Log, and 3D Robotics IRIS+ Professional

Instruction Manual). Furthermore, T. Layne Enterprises, LLC will document and

maintain all maintenance records for the 3D Robotics IRIS+ UAS.

D. The Reasons Why Granting T. Layne Enterprises, LLC 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 T. Layne

Enterprises, LLC to safely, efficiently, and economically perform aerial video and 

photography of real estate, special events, film sets, and landscape over certain areas of 

the United States.

Additionally, use of the 3D Robotics IRIS+ Professional UAS will decrease congestion 

of the NAS, reduce pollution, and provide significant benefits to the economy. Notably, 

the benefits of T. Layne Enterprises, LLC ‘s proposed operation of the 3D Robotics 

IRIS+ UAS will be realized without implicating any privacy issues.

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

The 3D Robotics IRIS+ Professional UA are battery powered and serve as a safe, 

efficient, and economical alternative to the manned aircraft traditionally utilized to obtain 

aerial imagery. By reducing the amount of manned aircraft needed to perform aerial 

acquisitions, an exemption allowing the use of a 3D Robotics IRIS+ UAS 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. The 3D Robotics IRIS+

Professional UA do not require an airport to takeoff or land. Likewise, a reduction of 

manned aircraft conducting aerial video and photography missions 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.

2. The Public Will Benefit From The Safety And Efficiency Of The 3D Robotics IRIS+

UAS.

Conducting aerial acquisitions with the 3D Robotics IRIS+ Professional UAS, instead of 

manned aircraft, will greatly benefit the public by drastically reducing the levels of air 

and noise pollution generated during traditional aerial video and still photography flight 

operations. By using battery power and electric motors, the 3D Robotics IRIS+

Professional UAS produce no air pollution, and is the most viable environmentally 

conscious alternative to the cabin class, six cylinder internal combustion engine aircraft 

that are typically utilized for aerial video and photography, while burning approximately 

20-30 gallons per hour of leaded aviation fuel. The 3D Robotics IRIS+ Professional UA, 

while reducing the carbon footprint of aerial acquisitions, also eliminates noise pollution, 

as the UAS are propelled by battery powered electric motors, rather than an internal 

combustion engine. By using the 3D Robotics IRIS+ Professional UAS to perform aerial 
T. Layne Enterprises, LLC Petition for Exemption Section 333 FAA 11

acquisitions, 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, the 3D Robotics IRIS+ UAS (weighing approximately 2 pounds 8

ounces, at their maximum gross weights with lengths of 19 inches and with no fuel on 

board), has less physical potential for collateral damage to life and property on the 

ground, and in the air, compared to the manned aircraft that typically conduct similar 

operations (weighing approximately 6,000 pounds with a wingspan of approximately 42 

feet, a length of 34 feet, and a fuel capacity of 180 gallons).

3. Performing Aerial Video and Photography Operations With The 3D Robotics IRIS+

UAS Will Benefit The Economy.

In addition to being safe and efficient, the 3D Robotics IRIS+ Professional is also an 

economical alternative to using manned aircraft to conduct similar aerial operations. As 

such, operation of the 3D Robotics IRIS+ Professional UAS will allow United States 

based companies, like T. Layne Enterprises, LLC, to remain competitive and contribute 

to growth of the U.S. economy. Specifically, with the rising cost of aviation fuel and the 

Environmental Protection Agency (“EPA”) regulatory actions phasing out leaded 

aviation fuels, U.S. owned and operated companies must adopt new and alternative 

technology in order to remain competitive. Operating the battery powered 3D Robotics 

IRIS+ Professional UAS is one such technology that not only allows companies greater 

operational flexibility compared to manned aircraft, but provides such flexibility without 

the high operational cost of a traditional manned aircraft. By operating the 3D Robotics 

IRIS+ Professional UAS, companies such as T. Layne Enterprises, LLC, can remain 

competitive and profitable, and therefore, provide greater job stability to employees and 

contractors, which will ultimately contribute to growth of the U.S. economy. Improved 

financial performance of U.S. companies, through commercial use of the 3D Robotics 

IRIS+ Professional UAS, provides a stable workforce that increases consumer spending; 

improves local, state, and federal tax revenues; and allows companies to invest in 

research and development in order to remain competitive both in the United States and 

abroad.

4. There Are No Privacy Issues.

Similar to the manned aerial acquisition flight operations that have been conducted for 

decades, T. Layne Enterprises, LLC proposed operation of the 3D Robotics IRIS+ UAS 

would not implicate any privacy issues. Specifically, the 3D Robotics IRIS+ UAS will be

operated only in compliance with operating documents (i.e., the Monthly Maintenance 

Log, 3D Robotics IRIS+ Professional Instruction Manual), which requires property

owner involvement as well as local law enforcement notification, and in accordance with 

the Federal Aviation Regulations, including the minimum altitude requirements of 14 

C.F.R. § 91.119.

E. 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
T. Layne Enterprises, LLC Petition for Exemption Section 333 FAA 12

Provided By The Rule From Which T. Layne Enterprises, LLC Seeks Exemption.

1. Reasons Why The 3D Robotics IRIS+ Professional 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 its operation, T. Layne Enterprises, LLC’s operation of the 3D Robotics IRIS+ 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 rule-making 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, T. Layne Enterprises, LLC submits that the 3D Robotics 

IRIS+ UAS can operate safely in the NAS pursuant to FMRA Section 333, as

demonstrated by: (a) the characteristics of the 3D Robotics IRIS+ Professional UAS;

and (b) the specific operating limitations.

a. The Specifications Of The 3D Robotics IRIS+ Professional UAS Demonstrate Its Safe 

Characteristics.

The 3D Robotics IRIS+ Professional UAS does not create a hazard to users of the NAS 

or the public, or otherwise pose a threat to national security considering its size, weight, 

speed, and operational capability.

i. Technical Specifications Of The 3D Robotics IRIS+ Professional UAS.

The technical specifications of the 3D Robotics IRIS+
T. Layne Enterprises, LLC Petition for Exemption Section 333 FAA 13

Professional UAS is set forth by the 3D Robotics IRIS+ Professional Specifications and 

Data Sheet, attached hereto as Exhibit A.

ii. The 3D Robotics IRIS+ Professional UAS Autonomous Flight And Navigation Modes 

Enable The UAS To Remain Within A Defined Operational Area. The 3D Robotics 

IRIS+ Professional UAS may be operated in both manual and fully autonomous flight 

modes. A complete description of the flight and navigational modes of the 3D Robotics 

IRIS+ UAS is provided at pages 11-12 of the 3D Robotics IRIS+, User Manual, attached 

hereto as Exhibit B.

iii. The 3D Robotics IRIS+ Professional UAS Are Designed For Automatic Return To 

Home Point Or Hover In The Event Of Loss Of The Control Link Or Navigation. When 

the Control Link is lost, the 3D Robotics IRIS+ UA will remains stationary, in flight. If, 

the 3D Robotics IRIS+ Professional UA does not reacquire control link data from the 

GCS, the UA will assume that the Control Link is lost and the UA will return to the home

position (i.e., failsafe mode) via GPS, and will descend to the takeoff position and 

shutdown. A complete description of the Failsafe Functions of the 3D Robotics IRIS+

UAS are set forth at page 7 of the 3D Robotics IRIS+ Professional User Manual, attached 

hereto as B.

iv. The 3D Robotics IRIS+ Professional GCS And Its Operation.

A complete description of the operation and specifications of the 3D Robotics IRIS+

GCS and flight control software is provided at pages 8-20 of the 3D Robotics IRIS+ 

Professional User Manual. 3D Robotics IRIS+ User Manual is attached hereto as Exhibit 

B.

b. Flight Operations Of 3D Robotics IRIS+ Professional UAS Are Limited To The Line 

Of Sight Of A Certificated Pilot in Command With A Safety Observer.

T. Layne Enterprises, LLC will use a safety observer to assist all pilots during flight time.

c. Flights Of 3D Robotics IRIS+ Professional UAS Will Be Conducted Pursuant To 

Specific Operating Limitations. In seeking this exemption, proposes to commercially 

operate 3D Robotics IRIS+ UAS for the special purpose of conducting aerial video and 

photography over certain areas of United States, pursuant to the following specific 

operating limitations:

1. Operations authorized by this grant of exemption will be limited to the following

aircraft described in the operating documents, rotorcraft UASs weighing less

than 55 pounds maximum gross weight: 3D Robotics IRIS+ Professional Unmanned 

Aircraft System. Proposed operations of any other aircraft will require a new petition or a 

petition to amend this grant.

2. UAS operations under this exemption will be limited to conducting operations for the 

purpose of aerial video and photography for homeowners, Realtors, home builders, 

contractors, home inspectors for use in real estate marketing and real estate inspections. 

Additionally, aerial video and photography may be conducted on occasional basis for 

film and television sets, special events and landscape photography as deemed necessary.

3. The UAS may not be flown at an indicated airspeed exceeding 29 knots (15 m/s).

4. The UAS must be operated at an altitude of no more than 200 (500 per the User

Manual) feet above ground level (AGL), as indicated by the procedures specified in the

operating documents unless a special request is made and approved by ATC. All altitudes

reported to ATC must be in feet AGL.
T. Layne Enterprises, LLC Petition for Exemption Section 333 FAA 14

5. The UAS must be operated within visual line of sight (VLOS) of the PIC at all times. 

This requires the PIC to be able to use human vision unaided by any device other than 

corrective lenses, as specified on the PIC’s FAA-issued airman medical certificate.

6. The use of first person view (FPV) by the PIC or safety observer (SO) is not permitted.

7. All operations must utilize a safety observer (SO). The SO may be used to satisfy the 

VLOS requirement as long as the PIC always maintains VLOS capability. The SO and 

PIC must be able to communicate verbally at all times. Electronic messaging or texting is 

not permitted during flight operations. The PIC must be designated before the flight and 

cannot transfer his or her designation for the duration of the flight. The PIC must ensure 

that the SO can perform the functions prescribed in the operating documents.

8. The SO must not perform any other duties beyond assisting the PIC with seeing and 

avoiding other air traffic and other ground based obstacles/obstructions and is not 

permitted to operate the camera or other instruments.

9. The operating documents and the grant of exemption must be accessible during

UAS operations and made available to the Administrator upon request. If a discrepancy 

exists between the conditions and limitations contained in the grant of exemption and the 

procedures outlined in the operating documents, the conditions and limitations contained 

in the grant of exemption take precedence and must be followed. Otherwise, the operator 

must follow the procedures as outlined in its operating documents. The operator may 

update or revise its operating documents. It is the operator’s responsibility to track such 

revisions and present updated and revised documents to the Administrator upon request.

The operator must also present updated and revised documents if it petitions for

extension or amendment to the grant of exemption. If the operator determines that any 

update or revision would affect the basis upon which the FAA granted the exemption, 

then the operator must petition for amendment to its grant of exemption. The FAA’s UAS 

Integration Office (AFS-80) may be contacted if questions arise regarding updates or 

revisions to the operating documents.

10. Prior to each flight the PIC must inspect the UAS to ensure that it is in a condition for 

safe flight. If the inspection reveals a condition that affects the safe operation of the UAS, 

the aircraft is prohibited from operating until the necessary maintenance has been 

performed and the UAS is found to be in a condition for safe flight. The Ground Control 

Station must be included in the preflight inspection. All maintenance and alterations must 

be properly documented in the aircraft records.

11. Any UAS that has undergone maintenance or alterations that affect the UAS

operation or flight characteristics, e.g. replacement of a flight critical component, must 

undergo a functional test flight. The PIC who conducts the functional test flight must 

make an entry in the aircraft records.

12. The pre-flight inspection must account for all potential discrepancies, e.g. inoperable 

components, items, or equipment, not already covered in the relevant sections of the 

operating documents.

13. The operator must follow the UAS manufacturer’s aircraft/component, maintenance, 

overhaul, replacement, inspection, and life limit requirements.

14. The operator must carry out its maintenance, inspections, and record keeping

requirements, in accordance with the operating documents. Maintenance, inspection, 

alterations, and status of replacement/overhaul component parts must be noted in the 

aircraft records, including total time in service, description of work accomplished, and 
T. Layne Enterprises, LLC Petition for Exemption Section 333 FAA 15

the signature of the authorized person returning the UAS to service.

15. Each UAS operated under this exemption must comply with all manufacturers

Safety Bulletins.

16. The authorized person must make an entry in the aircraft record of the corrective 

action taken against discrepancies discovered between inspections.

17. The operator may not permit any PIC to operate unless the PIC meets the operator’s 

qualification criteria and demonstrates the ability to safely operate the UAS in a manner 

consistent with how the UAS will be operated under the exemption, including evasive 

and emergency maneuvers and maintaining appropriate distances from persons, vessels, 

vehicles and structures. 

18. UAS operations may not be conducted during night, as defined in 14 C.F.R. §

1.1. All operations must be conducted under visual meteorological conditions

(VMC). If flight at night is required, a special request will be made at the FAA office

closest to proposed area of operations. Flights under special visual flight rules (SVFR) 

are not authorized.

20. The UA may not operate within 5 nautical miles of an airport reference point as

denoted on a current FAA-published aeronautical chart unless a letter of agreement with 

that airport’s management is obtained, and the operation is conducted in accordance with 

a NOTAM as required by the operator’s COA.

The letter of agreement with the airport management must be made available to the 

Administrator upon request.

21. The UA may not be operated less than 500 feet below or less than 2,000 feet

horizontally from a cloud or when visibility is less than 3 statute miles from the

PIC.

22. If the UA loses communications or loses its GPS signal, it must return to a

predetermined location within the planned operating area and land or be recovered in 

accordance with the operating documents.

23. The PIC must abort the flight in the event of unpredicted obstacles or emergencies in 

accordance with the operating documents.

24. The PIC is prohibited from beginning a flight unless (considering wind and forecast 

weather conditions) there is enough power to fly at normal cruising speed to the intended 

landing point and land the UA with 25% battery power remaining.

25. The operator must obtain an Air Traffic Organization (ATO) issued Certificate of 

Waiver or Authorization (COA) prior to conducting any operations under the grant of 

exemption. 

26. Before conducting operations, the radio frequency spectrum used for operation and 

control of the UA must comply with the Federal Communications Commission (FCC) or 

other appropriate government oversight agency requirements.

28. The documents required fewer than 14 C.F.R. 91.9 and 91.203 must be available to

the PIC at the Ground Control Station of the UAS any time the UAS is operating. These

documents must be made available to the Administrator or any law enforcement official

upon request.

29. The UAS must remain clear and yield the right of way to all manned aviation

operations and activities at all times.

30. The UAS may not be operated by the PIC from any moving device or vehicle.

31. Flight operations must be conducted at least 500 feet from all nonparticipating
T. Layne Enterprises, LLC Petition for Exemption Section 333 FAA 16

persons (persons other than the PIC, SO, operator trainees or essential persons), vessels, 

vehicles, and structures unless:

a. Barriers or structures are present that sufficiently protect nonparticipating persons from 

the UA and/or debris in the event of an accident. The operator must ensure that 

nonparticipating persons remain under such protection. If a situation arises where 

nonparticipating persons leave such protection and are within 500 feet of the UA, flight 

operations must cease immediately and/or;

b. The aircraft is operated near vessels, vehicles or structures where the owner/controller 

of such vessels, vehicles or structures has granted permission and the PIC has made a 

safety assessment of the risk of operating closer to those objects and determined that it 

does not present an undue hazard, and;

c. Operations nearer to the PIC, SO, operator trainees or essential persons do not present 

an undue hazard to those persons per § 91.119(a).

32. All operations shall be conducted over private or controlled-access property with 

permission from the land owner/controller or authorized representative. Permission from 

land owner/controller or authorized representative will be obtained for each flight to be 

conducted.

33. Any incident, accident, or flight operation that transgresses the lateral or vertical 

boundaries of the operational area as defined by the applicable COA must be reported to 

the FAA's UAS Integration Office (AFS-80) within 24 hours. Accidents must be reported 

to the National Transportation Safety Board (NTSB) per instructions contained on the 

NTSB Web site: www.ntsb.gov.

2. Reasons Why An Exemption From The Requirements Of Section 61.113(a) And (b) 

Would Not Adversely Affect Safety.

T. Layne Enterprises, LLC submits that the equivalent level of safety established by 

Section 61.113(a) and (b) will be maintained because no PIC will be allowed to operate 

the 3D Robotics IRIS+ unless they have read and agreed to adhere to the 3D Robotics 

IRIS+ Instruction manual and have had adequate supervised flying time under the 

supervision of an experienced operator, 

The FAA has previously granted relief from Section 61.113(a) and (b) 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, 11150, 11153, 11156, 11158, 11159, 11160, 11161).

3. Reasons Why An Exemption From The Requirements Of Section 91.7(a)

Would Not Adversely Affect Safety.

The equivalent level of safety established by Section 91.7(a) will be maintained

because prior to every flight, T. Layne Enterprises, LLC will ensure that the 3D Robotics 

IRIS+ UAS is in an airworthy condition 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, 11150, 11153, 11156, 11157, 11158, 11159, 11160, 11161).

4. Reasons Why An Exemption From The Requirements Of Section 91.121 Would Not 

Adversely Affect Safety.
T. Layne Enterprises, LLC Petition for Exemption Section 333 FAA 17

The equivalent level of safety established by Section 91.121 will be maintained because 

the altitude information of the 3D Robotics IRIS+ UA will be provided to the PIC via 

GPS equipment and a radio communications telemetry data link, which downlinks from 

the UA to the GCS for active monitoring of the flight path and altitude. This altitude

information, combined with T. Layne Enterprises, LLC operation of the 3D Robotics 

IRIS+ UAS within visual line of sight, at or below 500 feet AGL, will ensure a level of 

safety equivalent to Section 91.121. The altitude information will be generated by GPS

equipment installed onboard the aircraft. Prior to each flight, a zero altitude initiation 

point is automatically established by the UASs at ground level.

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,

11150, 11153, 11156, 11157, 11158, 11159, 11160, 11161).

5. Reasons Why An Exemption From The Requirements Of Section 91.151(b)

Would Not Adversely Affect Safety.

A grant of this exemption would ensure an equivalent level of safety established by

14 C.F.R. Section 91.151(b) as a result of (1) the technical specifications of the 3D 

Robotics IRIS+ UAS; (2) the limitations on the proposed flight operations; and

(3) the location of the proposed flight operations. Accordingly, T. Layne Enterprises, 

LLC will ensure that it will safely operate the battery powered 3D Robotics IRIS+

Professional UA during daylight hours in VFR conditions, with enough battery power to 

fly for a total duration of 13.5 minutes to the first point of intended landing and, assuming 

normal cruising speed, to fly after that for at least 4.5 minutes.

Here, as in Exemption No. 11109, the technical specifications of the 3D Robotics IRIS+ 

UAS; the limitations on the proposed flight operations; and the location of the proposed 

operations, will ensure an equivalent level of safety established by 14 C.F.R. Section 

91.151(b). Furthermore, safety will be ensured as the 3D Robotics IRIS+ Professional 

UAS provide audible and visual warnings to the PIC at the GCS when the UAS

experiences low battery voltage, the first warning occurring at approximately 33% 

remaining battery power, and again at approximately 10% remaining battery power. At 

the critically low battery level, the 3D Robotics IRIS+ UAS will descend and land 

automatically.

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, 11150, 

11153, 11156, 11157, 11158, 11159, 11160, 11161).

6. 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, T. Layne Enterprises, LLC submits that the equivalent level of

safety with regard to the regulatory maintenance and alteration requirements established 
T. Layne Enterprises, LLC Petition for Exemption Section 333 FAA 18

by Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b) will be 

met because T. Layne Enterprises, LLC will use trained technicians to perform 

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

techniques, and practices prescribed in the operating documents (i.e., the Monthly 

Maintenance Log, and 3D Robotics IRIS+ Professional Instruction Manual). 

Furthermore, T. Layne Enterprises, LLC will document and maintain all maintenance 

records for the 3D Robotics IRIS+ Professional UAS. Since the 3D Robotics IRIS+ 

Professional UAS will be inspected as prescribed by the operating documents, T. Layne 

Enterprises, LLC will maintain the equivalent level of safety established by Sections 

91.405(a), 91.409(a)(1), and 91.409(a)(2). A copy of the 3D Robotics IRIS+ User 

Manual is attached hereto as Exhibit B; a copy of the 3D Robotics IRIS+UAS 

Maintenance LOG is attached hereto as Exhibit C. Likewise, the exemption sought will 

not adversely affect safety because T. Layne Enterprises, LLC will use trained 

technicians to perform maintenance, alterations or preventive maintenance on the UAS 

using the methods, techniques, and practices prescribed by the operating documents.

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

3D Robotics IRIS+ Professional UAS will be performed by trained technicians. 

Maintenance will be documented and maintained utilizing the monthly maintenance log.

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

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

adversely affected when the technical characteristics and operating limitations of the

UAS are considered. In consideration of T. Layne Enterprises, LLC proposed operating 

limitations, the operating documents, and the technical aspects of the 3D Robotics IRIS+ 

Professional UAS, T. Layne Enterprises, LLC submits that safety will not be adversely 

affected by granting exemption from 14 C.F.R. Sections 91.405(a), 91.407(a)(1) and 

(a)(2), 91.409(a)(2), and 91.417(a) and (b). 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, 11150, 11153, 11156, 11157, 11158, 11159, 11160, 

11161).

7. 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, T. Layne Enterprises, LLC

requests that the FAA prescribe special conditions for the intended operation of the 3D 

Robotics IRIS+ 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 §§ 61.113(a) & (b), 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 UAS for the limited purpose of conducting aerial video and 

photography over certain areas of the United States for compensation or hire. 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 
T. Layne Enterprises, LLC Petition for Exemption Section 333 FAA 19

conditions pursuant to 14 C.F.R. § 21.16, for operation of the 3D Robotics IRIS+ 

Professional 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 T. Layne Enterprises, LLC intended 

operation of the 3D Robotics IRIS+ 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 Sections 61.113(a) & (b), 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 T. Layne Enterprises, LLC Seeks Exemption:

T. Layne Enterprises, LLC seeks exemption from the requirements of 14 C.F.R Sections

61.113(a)&(b), 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 T. Layne Enterprises, LLC Seeks:

This exemption will permit T. Layne Enterprises, LLC to commercially operate an

Unmanned Aircraft System (UAS) for the purpose of conducting aerial video and

photography over certain areas of the United States.

G. Any Additional Information, Views, Or Arguments Available To Support T. Layne 

Enterprises, LLC 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, T. Layne Enterprises, LLC 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, T. 

Layne Enterprises, LLC will operate the 3D Robotics IRIS+ Professional 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, T. Layne Enterprises, LLC seeks an exemption pursuant to 14 C.F.R.
T. Layne Enterprises, LLC Petition for Exemption Section 333 FAA 20

§ 11.61 and Section 333 of the FAA Modernization and Reform Act of 2012 (FMRA),

which will permit safe operation of the 3D Robotics IRIS+ Professional UAS

commercially, without an airworthiness certificate, for the limited purpose of conducting 

aerial video and photography over certain areas of the United States. 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 T. Layne Enterprises, LLC to safely, efficiently, and economically operate 

the 3D Robotics IRIS+ UAS commercially within the NAS. WHEREFORE, in 

accordance with the Federal Aviation Regulations and the FAA Modernization and 

Reform Act of 2012, Section 333, T. Layne Enterprises, LLC respectfully requests that 

the Administrator grant this Petition for an exemption from the requirements of 14 C.F.R 

Sections 61.113(a) & (b), 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 T. Layne Enterprises, LLC to 

operate the 3D Robotics IRIS+ Professional UAS commercially for the purpose of 

conducting aerial video and photography of Real Estate Properties (for homeowners, 

realtors, home builders, home contractors and / or home inspectors for real estate 

marketing and inspection of home exteriors) as well as filming of special events, film 

sets, scripted and unscripted television sets and landscape over certain areas of the United 

States.

Dated: April 28, 2015

Respectfully submitted by,

Ronnie Krupa

_________________________

Ronnie Krupa

T. Layne Enterprises, LLC (D.B.A. 4 Forks Media Production)

3062 Hogback Hill 

PO Box 3

Mineral Springs, PA 16855

Tel: 814.577.0872

Email: Ronnie@4forksmedia.com

Appendixes:

A – 3D Robotics IRIS+ Specifications Data Sheet
T. Layne Enterprises, LLC Petition for Exemption Section 333 FAA 21

B – 3D Robotics IRIS+ Manufacturer’s User Manual

C – Monthly Maintenance Log

APPENDIX – A

3D Robotics IRIS+ Technical Specifications

T. Layne Enterprises, LLC only utilizes safe and reliable UASs. 3D Robotics is an 

industry leader in small UAS production. 3D Robotics IRIS+ UASs are loaded with 

ground breaking software enabling the user to set parameters which will not allow flight 

into controlled airspace. Parameters can also be set to limit flight to no higher than a 

predetermined and set altitude as well as limit flight to a predetermined and set distance. 

In addition, 3D Robotics IRIS+ software provides real-time altitude and location

information to the PIC via the linked monitor (smart phone/tablet devices)

Autopilot Hardware: Pixhawk

Firmware: APM: Copter3.1

GPS: 3DR uBlox GPS with Compass (LEA-6H module, 5 Hz update) 

Telemetry Radio: 3DR Radio Telemetry v2 (915 mHz

Battery: 3S 5.1 Ah 8C lithium polymer

Low battery voltage: 10.5 V

Maximum voltage: 12.6 V

Battery cell limit: 3S

Payload capacity: 400 g (.8 lbs)

Radio range: up to 1 km (.6 miles)

Flight time: 16-22 minutes, depending on payload

APPENDIX – B

3D Robotics IRIS+ Manufacturer’s User Manual (uploaded in a separate attachment)

APPENDIX – C

MONTHLY MAINTENANCE LOG
T. Layne Enterprises, LLC Petition for Exemption Section 333 FAA 22

Ronnie Krupa

T. Layne Enterprises, LLC (D.B.A. 4 Forks Media Production)

3062 Hogback Hill 

PO Box 3

Mineral Springs, PA 16855

Tel: 814.577.0872

Email: Ronnie@4forksmedia.com