William J. Daniel III

Lowe Engineers, LLC

990 Hammond Drive, Suite 900

Atlanta, GA 30328

U.S. Department of Transportation 

Docket Management System

1200 New Jersey Avenue SE

Washington DC 20590

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

Regulations

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the "Reform Act") and 14

C.F.R. Part 11, William J. Daniel III DBA ‘Lowe Engineers, LLC’ seeks an exemption from the Federal

Aviation Regulations ("FARs") listed below to allow commercial operation of designated UAS when 

such operations are conducted within the circumstances outlined below.

The specific sections of Title 14 of the Code of Federal Regulations from which Lowe Engineers, LLC 

requests an exemption from are 14 CFR Part 21 subpart H; 14 CFR 61.113 (a) & (b); 14 CFR 91.7 (a); 14 

CFR 91.9 (b)(2); 14 CFR 91.103; 14 CFR91.109; 14 CFR91.119 (c); 14 CFR91.121; 14 CFR 91.151 (a); 14 

CFR91.203 (a) & (b); 14 CFR 91.405 (a); 14 CFR 91.407 (a) (1); 14 CFR 91.409 (a) (2); & 14 CFR 91.417 (a) 

& (b).

The requested exemption would permit Lowe Engineers, LLC commercial operation of a light weight 

unmanned UAS, eBee RTK senseFly, a survey-grade mapping drone. It would be used for Aerial Mapping 

and Survey, which includes flying a designated project area in a series of parallel flight-paths and taking 

photographs to create geo-referenced 2D orthomosaics, 3D point clouds, triangle models and Digital 

Elevation Models.

Lowe Engineers, LLC intends to perform project analysis and commercial operations of aerial 

photography and surveying using the eBee RTK senseFly. Weighing 1.61 lbs and powered by 

rechargeable lithium-polymer battery, the UAS will be operated under controlled conditions at a low 

altitude in limited airspace. Using senseFly’s intuitive software makes it easy to plan and simulate the

mapping mission. Once you import your preferred base map and define the area you want to cover, 

eMotion software will automatically generate a full flight plan, calculating the eBee RTK’s required

altitude and displaying its projected trajectory. It has a 2.4 GHz radio link that communicates with 

eMotion flight planning software via the USB ground modem. It has a brushless electric motor which is 

low noise and low pollution. Safety features include shock absorbent foam plus low weight equating to 

low impact energy resulting in minimal hazard to people and property along with automated controls 

giving the operator full control of the situation at any given point in time.

The operation of UAS typically involves two people. The operator is responsible for flying, monitoring 

the position and flight dynamics while maintaining a visual line-of-sight (VLOS) of the UAS while keeping 

it within factory limits such as battery life and range to ensure safe operation. The observer is 
responsible for monitoring the airspace for any hazards, such as other aircraft, and instruct the operator 

before and during flight as necessary to ensure a safe distance and no conflicts. The operator will be an 

individual who has passed an FAA approved or equivalent ground training exam and training program 

for the eBee RTK senseFly as well as continually receive up-to-date training on a regular basis.

Using the UAS will benefit the public as a whole by reducing environmental impacts such as emissions 

and noise. To attain a high level of safety, Lowe Engineers, LLC agrees to observe all necessary safety 

precautions. Strict adherence to all safety operating procedures will be achieved with the use of 

checklists containing: review of hardware and software to ensure it is operating within defined 

parameters, pre-flight checklist, take-off checklist, landing checklist, emergency procedures, system

maintenance and service schedules. Maintenance and inspections will be performed in accordance with 

the UAS Manufacturers User Manual. 

Flight times will be limited to a maximum of 30 minutes and will cease upon alert to the operator at a 

determined battery voltage as well as automatically “return home” upon lost radio control or low 

battery voltage. Flights will be operated at an altitude of more than 300 feet above ground level at all 

times. A safety briefing will be performed prior to each flight. All flights will be logged. Verbal or written 

permission and permits will be obtained, when appropriate, from territorial, state, county, city 

jurisdictions, law enforcement, fire or other governmental agencies. All operations will occur in Class G 

airspace during daylight hours and will exceed a 5-mile radius of any Airport Reference Point (ARP).

Lowe Engineers, LLC will obtain a Certificate Waiver or Authorization (COA) from the FAA Air Traffic 

Organization upon approval of this petition.

14 CFR Part 21 subpart H: Airworthiness Certificates.

Because of the small area in which the UAS will be operated, speed of operation, lack of explosive or 

flammable liquids and materials, along with the petite size causing inability to carry an external load, it 

meets the safety requirements under Part 11 and Section 333 of the Reform Act.

14 CFR 61.113 (a) & (b): Private Pilot Priviledges and Limitations: Pilot in Command.

The proposed UAS does not carry pilots, passengers or property, therefore it falls well under the risk 

levels outlined in 14 CFR 61.

14 CFR 91.7 (a): Civil Aircraft Worthiness, 14 CFR 91.103: Preflight Action & 14 CFR 91.109: Flight 

Instruction.

Operators of the UAS will be required to complete an aviation fundamentals course as well as they must 

have passed the SenseFly’s training program. The operator will take actions such as reviewing weather, 

flight battery requirements, landing and take-off distances and aircraft performance before each flight.

This along with the multitude of safety features the UAS contains result in meeting the requirements 

under Part 11 and Section 333 of the Reform Act.
14 CFR 91.9 (b)(2): Civil Aircraft Flight Manual in the Aircraft.

Due to the size and configuration of the UAS, it has no ability to carry a flight manual on the aircraft.

14 CFR 91.119 (c): Minimum Safe Altitudes.

The proposed UAS will never operate at higher than 400 feet AGL and flights will take place in a 

controlled environment where buildings and people will not be exposed to operations without their 

prior consent. 

14 CFR91.121: Altimeter Settings.

The proposed UAS does not have a barometric altimeter, but instead a GPS altitude readout, therefore 

the exemption is needed.

14 CFR 91.151 (a): Fuel Requirements for Flight in VFR Conditions.

Operating the UAS in a tightly controlled area where only people and property owners or official

representatives who have signed waivers will be allowed does not engender the type of risks that

Section 91.151(a) was intended to alleviate given the size and speed of the small UAS.

14 CFR91.203 (a) & (b): Carrying Civil Aircraft Certification and Registration.

The UAS fully loaded weighs well under the proposed 55-lb limit and is operated without an onboard

pilot. As such, there is no ability or place to carry certification and registration documents or to display

them on the UAS.

14 CFR 91.405 (a); 91.407 (a) (1); 91.409 (a) (2); 91.417 (a) & (b): Maintenance Inspections

Given that these sections apply only to aircraft with an airworthiness certificate, these sections will not 

apply.

In Conclusion, this exemption request along with all associated safety considerations adequately satisfy 

criteria under Part 11 and Section 333 of the Reform Act, providing ample justification to grant

commercial operations of the proposed UAS.

Sincerely,

William J. Daniel III, PLS CP