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Alexander G. Armstead

DVerse Corporation

1017 Windhook St.

Las Vegas, NV 89144

July 31, 2015

U.S. Department of Transportation

Docket Management System 1200

New Jersey Ave., SE Washington DC 20590

Exemption Request Pursuant to Section 333 of the FAA Reform Act and Part 11 

of the Federal Aviation Regulations from: 14 CFR 21 subpart H; 14 CFR 

45.23(b); 14 CFR 61.113(a); 14 CFR 91.7(a); 14 CFR 91.9(b)(2); 14 CFR 

91.103;14 CFR 91.109; 14 CFR 91.119(c); 14 CFR 91.121; 14 CFR 91.151(a); 

14 CFR 91.203 (a) and (b); 14 C

FR 91.405 (a); 14 CFR 91.407 (a) (1) 14 CFR 91.409 (a)(1) and (2); 14 CFR 

91.417(a) and (b)

To whom it may concern:

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

14 CFR Part 11, Alexander G. Armstead, operator of Small Unmanned aircraft 

Systems, hereby applies for an exemption from the listed Federal Aviation 

Regulations to allow commercial operation of an sUAS, so long as such 

operations are conducted within and under the conditions outlined herein or as 

my be established by the FAA as required by Section 333.

Commercial operation sUAS, as described herein, which are equipped with 

cameras and sensors, would operate in the following manner:

1. Aerial photography and/or video for public and/or private use including real 

estate, architecture, land surveying, engineering and other related 

professional activities. 

2. Aerial video and/or photography for public and/or private use including 

television, public events, cinematography and newsgathering. 

3. Aerial inspection/photography of residential/commercial structures under 

contract with the owners or local government authority. 

4. Aerial video/photography or providing live video feed to assist with search 

and rescue operations in cases of an emergency or natural disaster only 

when the local authorities or government has requested it by contract or 

donation. 

5. The ability to offer training to persons individually or belonging to both 

private and/or public organizations that have interests in the use and 

application of sUAS for the purpose of the safe operation of sUAS to 
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enhance the safety of the National Airspace System (NAS) as well as for 

the protection of the persons and property.

As described fully below, the requested exemption would permit the operation of 

sUAS under controlled conditions in the NAS that would be a) limited b) 

controlled c) predetermined and d) will provide safety enhancements to the 

already safe operations in the industry presently using conventional aircraft. 

Approval of this exemption would thereby enhance safety and fulfill the Secretary 

of Transportation’s (the FAA Administrator’s) responsibilities to “....establish 

requirements for the safe operation of such aircraft systems in the national 

airspace system.”

The petitioner is: Alexander G. Armstead

DVerse Corportation

1017 Windhook St.

Las Vegas, NV 89144

Phone: 702-882-4235

Email: armsteadalex@gmail.com

Petitioner is a U.S. citizen who has been a licensed Airframe and Power plant 

Mechanic for 2 years, a U.S. Air Force F-16 Fighting Falcon Crew Chief for over 

7 years, and professional UAV A&P Specialists on MQ-1C Grey Eagle (US 

Army), MQ-9 Reaper, and MQ-1B Predator (US Air Force) for over 3 years and 

actively flying sUAS’s for 1 year. Flew/driven RC Vehicles for 6 years.

Regulations from which the exemption is requested:

14 CFR Part 21 subpart H 

14 CFR 45.23 (b) 

14 CFR 61.113(a) 

14 CFR 91.7 (a) 

14 CFR 91.9 (b) (2) 

14 CFR 91.103 

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) (1) 

14 CFR 91.409 (a) (2) 

14 CFR 91.417 (a) & (b)

The sUAS’s I will be using are multi-rotor craft weighing no more than 55lbs. 

including payload. Under normal conditions they operate at speeds of no more 
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than 45 Mph or 39 Knots and have the ability hover and move along a vertical 

and horizontal plane simultaneously. They will operate in line of sight only and by 

the exempted persons employed by DVerse Corporation only obeying all other 

local and federal laws. 

Given the small size of the sUAS and the controlled environment provided the 

proposed operations will adhere to the Reform Act’s safety requirements. The 

approval of this application presents no national security issues. Regarding the 

level of safety surrounding the proposed operations and the public benefit, 

reduction in environmental impacts, including but not limited to reduced 

emissions and noise, the grant of the requested exemption is in the public 

interest. Accordingly the applicant requests that the FAA grant the requested 

exemption with minimum delay.

AIRCRAFT AND EQUIVALENT LEVEL OF SAFETY

The operation limitations proposed for an equivalent or higher level of safety 

because operations will further enhance the safety of the persons and/or property 

using conventional aircraft. These limitations and conditions to which the 

applicant agrees to adhere to when conducting commercial operations under the 

FAA issued exemption as set forth in the Flight Operations Manual (FOM) 

include:

1. The sUAS will weigh less than 55 lbs. 

2. Flights will be operated within line of sight of a pilot and/or observer. 

3. Maximum flight time for each operational flight will be 30 minutes. Flights 

will be terminated at 25% battery power reserve or 30 minutes of flight 

time whichever occurs first. 

4. Flights will be operated at an altitude of no more than 400 feet Above 

Ground Level (AGL) and not more than 200 feet above an elevated 

platform from which filming is planned. 

5. Minimum crew for each operation will consist of the sUAS Pilot, the Visual 

Observer (VO) when needed and may include but not limited to a Camera 

Operator. 

6. The sUAS pilot/pilots will be personnel hired by Dverse ONLY not allowing 

any other person to operate the sUAS in a commercial capacity. Only FAA 

approved pilots employed by my company DVerse will operate sUAS 

beside myself. 

7. A briefing will be performed regarding the planned sUAS operations prior 

to each day’s flight consisting of all the days’ production activities. 
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8. The operator will obtain verbal/written consent of all persons involved with 

the planned operation and ensure that only consenting persons will be 

allowed within 100 feet of the flight operation, and the radius may be 

reduced to 30 feet based upon an equivalent level of safety determination, 

as required under the FOM. With the advanced permission or direction of 

the FSDO, operations at closer range may be approved. 

9. The PIC and VO will have been trained in operation of sUAS and receive 

up-to-date information for the particular sUAS to be operated and will be 

able to show upon request their competent ability to operate the sUAS 

and/or Camera.

10.The PIC and VO will be able to communicate by voice, radio, and/or text 

at all times. 

11. Written and/or verbal permission and permits will be obtained from 

territorial, state, county or city jurisdictions, including law enforcement, fire 

or other appropriate governmental agencies when needed. 

12. If the sUAS loses communications or loses GPS signal, the sUAS will 

have the capability to return to a pre-determined location within a 

designated location and land autonomously. 

13. The sUAS will have the capability to abort a flight in case of unpredicted 

obstacles, weather, or emergencies.

14 C.F.R. Part 21, Subpart H: Airworthiness Certificates 14 C.F.R. §91.203 

(a) (1)

Subpart H, entitled Airworthiness Certificates, establishes the procedural 

requirements for the issuance of airworthiness certificates as required by FAR 

§91.203 (a) (1). Given the size and limited operating area associated with the 

aircraft to be utilized by the Applicant, an exemption from Part 21 Subpart H 

meets the requirements of an equivalent level of safety under Part 11 and 

Section 333 of the Reform Act. The Federal Aviation Act (49 U.S.C.§44701 (f)) 

and Section 333 of the Reform Act both authorize the FAA to exempt aircraft 

from the requirement for an airworthiness certificate, upon consideration of the 

size, weight, speed, operational capability, and proximity to airports and 

populated areas of the particular sUAS. In all cases, an analysis of these criteria 

demonstrates that the sUAS operated without an airworthiness certificate, in the 

restricted environment and under the conditions proposed will be at least as safe, 

or safer, than a conventional aircraft (fixed wing or rotorcraft) operating with an 

airworthiness certificate without the restrictions and conditions proposed. 
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The sUAS to be operated hereunder is less than 55 lbs. fully loaded, carries 

neither a pilot nor passenger, carries no explosive materials or flammable liquid 

fuels, and operates exclusively within a secured and designated area. Unlike 

other civil aircraft, operations under this exemption will be tightly controlled and 

monitored by both the operator and under the requirements and in compliance 

with local public safety requirements. These safety enhancements provide a 

greater degree of safety to the public and property owners than conventional 

operations conducted with airworthiness certificates issued under 14 C.F.R. Part 

21, Subpart H. Lastly, application of these same criteria demonstrates that there 

is no credible threat to national security posed by the sUAS, due to its size, 

speed of operation, location of operation, lack of explosive materials or 

flammable liquid fuels, and inability to carry a substantial external load. 

14 C.F.R. § 45.23 (b). Marking of the Aircraft 

The regulation requires: When marks include only the Roman capital letter "N" 

and the registration number is displayed on limited, restricted or light-sport 

category aircraft or experimental or provisionally certificated aircraft, the operator 

must also display on that aircraft near each entrance to the cabin, cockpit, or pilot 

station, in letters not less than 2 inches nor more than 6 inches high, the words 

"limited," "restricted," "light-sport," "experimental," or "provisional," as applicable. 

Even though the sUAS will have no airworthiness certificate, an exemption may 

be needed, as the sUAS will have no entrance to the cabin, cockpit or pilot 

station on which the word “Experimental” can be placed. Given the size of the 

sUAS, two-inch lettering will be impossible. The word “Experimental” will be 

placed on the fuselage in compliance with §45.29 (f). The equivalent level of 

safety will be provided by having the sUAS marked on its fuselage as required by 

§45.29 (f) where the pilot, observer and others working with the sUAS will see 

the identification of the sUAS as “Experimental.” 

14 C.F.R. § 61.113(a): Private Pilot Privileges and Limitations: Pilot in 

Command.

Pursuant to 14 CFR 61.113 (a), no person who holds a private pilot certificate 

may act as a pilot in command of an aircraft that is carrying passengers or 

property for compensation or hire. Our sUAS do not carry any pilots or 

passengers nor property therefore I am seeking an exemption to 14 CFR 

61.113(a). Although helpful, a pilot’s license will not ensure remote control 

piloting skills. The risks attendant to the operation of sUAS is far less than the 

risk levels inherent in the commercial activities outlined in 14 CFR 61. I feel the 

operation and limitations set forth in the FOM will equate to the safe operation of 

the sUAS

14 C.F.R. §91.7(a): Civil Aircraft Airworthiness
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The regulation requires that no person may operate a civil aircraft unless it is in 

airworthy condition. As there will be no airworthiness certificate issued for the 

aircraft, should this exemption be granted, no FAA regulatory standard will exist 

for determining airworthiness. Given the size of the aircraft for maintenance and 

use of safety checklists prior to each flight an equivalent level of safety will be 

provided. 

14 C.F.R. § 91.9 (b) (2): Civil Aircraft Flight Manual in the Aircraft.

Section 91.9 (b) (2) provides: No person may operate a U.S.-registered civil 

aircraft ... (2) For which an Airplane or Rotorcraft Flight Manual is not required by 

§21.5 of this chapter, unless there is available in the aircraft a current approved 

airplane or Rotorcraft Flight Manual, approved manual material, markings, and 

placards, or any combination thereof. The sUAS, given its size and configuration 

has no ability or place to carry such a flight manual on the aircraft, not only 

because there is no pilot on board, but because there is no room or capacity to 

carry such an item on the aircraft. The equivalent level of safety will be 

maintained by keeping the flight manual at the ground control point where the 

pilot flying the sUAS will have immediate access to it. 

14 C.F.R. § 91.103: Preflight Action.

This regulation requires each pilot in command to take certain actions before 

flight to insure the safety of flight. As FAA approved rotorcraft flight manuals will 

not be provided for the aircraft an exemption will be needed. The PIC will take all 

actions including reviewing weather, flight battery requirements, landing and 

takeoff distances and aircraft performance data before initiation of flight. 

14 C.F.R. §91.109: Flight Instruction.

Section 91.103 provides that no person may operate a civil aircraft (except a 

manned free balloon) that is being used for flight instruction unless that aircraft 

has fully functioning dual controls. sUAS and remotely piloted aircraft, by their 

design do not have fully functional dual controls. Flight control is accomplished 

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

communications. The FAA has approved exemptions for flight training without 

fully functional dual controls for a number of aircraft and for flight instruction in 

experimental aircraft. The equivalent level of safety provided by the fact that 

neither a pilot nor passengers will be carried in the aircraft and by the size and 

speed of the aircraft.

14 C.F.R. §91.119: Minimum Safe Altitudes.

Section 91.119 establishes safe altitudes for operation of civil aircraft. Section 

91.119 (d) allows helicopters to be operated at less than the minimums 
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prescribed, provided the person operating the helicopter complies with any route 

or altitudes prescribed for helicopters by the FAA. As this exemption is for a 

sUAS that is a helicopter and the exemption requests authority to operate at 

altitudes up to 400 AGL, or not more than 200 above an elevated platform from 

which filming is planned, an exemption may be needed to allow such operations. 

As set forth herein, the sUAS will never operate at higher than 400 AGL with the 

exception that in circumstances where the sUAS is used to survey or photograph 

a structure whose height exceeds 400 feet AGL, the sUAS will not be operated 

more than 100' above the highest point on the structure. It will however be 

operated in a restricted area with security perimeter, where buildings and people 

will not be exposed to operations without their pre-obtained consent. 

The equivalent level of safety will be achieved given the size, weight, speed of 

the sUAS as well as the location where it is operated. No flight will be taken 

without the permission of the property owner or local officials. Because of the 

advance notice to the property owner and participants in the filming activity, all 

affected individuals will be aware of the planned flight operations. Compared to 

flight operations with aircraft or rotorcraft weighting far more than the maximum 

55lbs. proposed herein and the lack of flammable fuel, any risk associated with 

these operations is far less than those presently presented with conventional 

aircraft operating at or below 500 AGL. In addition, the low-altitude operations of 

the sUAS will ensure separation between these small-UAS operations and the 

operations of conventional aircraft that must comply with Section 91.119. 

14 C.F.R. §91.121 Altimeter Settings.

This regulation requires each person operating an aircraft to maintain cruising 

altitude by reference to an altimeter that is set “...to the elevation of the departure 

airport or an appropriate altimeter setting available before departure.” As the 

sUAS may not have a barometric altimeter, but instead a GPS altitude read out, 

an exemption may be needed. An equivalent level of safety will be achieved by 

the operator, pursuant to the safety check list and live flight data monitoring, 

confirming the altitude of the launch site shown on the GPS altitude indicator 

before flight. 

14 C.F.R. § 91.151(a): Fuel Requirements for Flight in VFR Conditions 

Section 91.151 (a) prohibits an individual from beginning “a flight in an airplane 

under VFR conditions unless (considering wind and forecast weather conditions) 

there is enough fuel to fly to the first point of intended landing, and, assuming 

normal cruising speed –(1) During the day, to fly after that for at least 30 minutes; 

or (2) At night, to fly after that for at least 45 minutes.” The battery powering the 

sUAS provides approximately 30 minutes of powered flight. To meet the 30-

minute reserve requirement in 14 CFR §91.151, sUAS flights would be limited to 

approximately 10 minutes in length. Given the limitations on the sUAS’s 

proposed flight area and the location of its proposed operations within a 

predetermined area, a longer time frame for flight in daylight or twilight VFR 
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conditions is reasonable. Applicant believes that an exemption from 14 CFR 

§91.151(a) falls within the scope of prior exemptions. Operating the small UAS, 

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

representatives who have signed waivers will be allowed, with less than 30 

minutes of reserve fuel, 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. 

Additionally, limiting sUAS flights to 10 minutes would greatly reduce the utility for 

which the exemption will be granted. Applicant believes that an equivalent level 

of safety can be achieved by limiting flights to 30 minutes or 25% of battery 

power—whichever happens first. This restriction would be more than adequate to 

return the sUAS to its planned landing zone from anywhere in its limited 

operating area.

14 C.F.R. §91.203 (a) and (b): Carrying Civil Aircraft Certification and 

Registration 

The regulation provides in pertinent part: 

(a) Except as provided in § 91.715, no person may operate a civil aircraft 

unless it has within it the following: 

(1) An appropriate and current airworthiness certificate . . . . 

(b) No person may operate a civil aircraft unless the airworthiness 

certificate required by paragraph (a) of this section or a special flight 

authorization issued under §91.715 is displayed at the cabin or cockpit 

entrance so that it is legible to passengers or crew. 

The sUAS fully loaded weighs no more than 55 lbs. 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 sUAS. 

An equivalent level of safety will be achieved by keeping these documents at the 

ground control point where the pilot flying the sUAS will have immediate access 

to them, to the extent they are applicable to the sUAS. 

14 C.F.R. §91.405 (a); 407 (a) (1); 409 (a) (2); 417(a) & (b): Maintenance 

Inspections.

These regulations require that an aircraft operator or owner “shall have that 

aircraft inspected as prescribed in subpart E of this part and shall between 

required inspections, except as provided in paragraph (c) of this section, have 

discrepancies repaired as prescribed in part 43 of this chapter...,” and others 

shall inspect or maintain the aircraft in compliance with Part 43. Given that these 

section and Part 43 apply only to aircraft with an airworthiness certificate, these 

sections will not apply to the applicant. Maintenance will be accomplished by the 
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operator pursuant to the flight manual and operating handbook. An equivalent 

level of safety will be achieved because these small UASs are very limited in size 

and will carry a small payload and operate only in restricted areas for limited 

periods of time. If mechanical issues arise the sUAS can land immediately and 

will be operating from no higher than 400 feet AGL. The operator will ensure that 

the sUAS is in working order prior to initiating flight, perform required 

maintenance, and keep a log of any maintenance performed. Moreover, the 

operator is the person most familiar with the aircraft and best suited to maintain 

the aircraft in an airworthy condition to provide the equivalent level of safety. An 

equivalent level of safety will be achieved because maintenance and inspections 

will be performed in accordance with the sUAS Manufacturer's Manual, as 

referenced in the Aircraft Operations Manual (AOM). As provided in the FOM, the 

operator will ensure that the sUAS is in working order prior to initiating flight and 

perform required maintenance needed.

sUAS Information

sUAS’s to be used are as follows but not limited to providing they are within the 

scope of the exemption granted by the FAA:

DJI Phantom 3 Professional

 Supported Battery –DJI 5200mAH LiPo Battery 

 Weight (Battery & Propellers Included) –2lbs 11.810oz (1242g) 

 Hover Accuracy (Ready to Fly) –Vertical: .8m; Horizontal: 2.5m 

 Max Yaw Angular Velocity -200/s 

 Max Tilt Angel -35 

 Max Ascent Speed –6m/s 

 Max Descent Speed –2m/s

 Max Flight Speed –15m/s (NOT RECOMMENDED)

a. DJI Gimbal 

 Working Current –Static: 750mA; Dynamic: 900mA 

 Control Accuracy -±0.03 

 Controllable Range – Pitch: -90 -0 

 Maximum Angular Speed –Pitch: 90/s

b. DJI Camera 

 Operating Temperature Range -32F -104F (0C -40C) 

 Sensor Size –1/2.3” 

 Effective Pixels –14M 

 Resolution –4384x3288 

 HD Video Recording –1080p30 & 720p 

 Recording Field of View -110/85

c. DJI Transmitter 
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 Operating Frequency –5.728GHz –5.85GHz 

 Communication Distance (unobstructed) – FCC Compliance: 800m 

 Receiver Sensitivity (1%PER) -- 93dBm 

 Transmitter Power – FCC Compliance: 100mW 1.1.4.5 Working 

Voltage – 120mA@3.7V

d. DJI Range Extender 

 Frequency – 2412-2462MH

DJI Inspire

 Weight (Battery Included) 2935g

 Hovering Accuracy (GPS Mode) Vertical 0.5m, Horizontal 2.5m

 Max Angular Velocity Pitch: 300deg/s; Yaw 150deg/s

 Max Tilt Angle 30deg/s

 Max Ascent Speed 5m/s

 Max Decent Speed 4m/s

 Max Speed 22m/s

 Diagonal Distance 559mm (Landing gear lowered), 581mm (Landing 

gear raised)

a. DJI Inspire Gimbal

 Operating Current -Station: 750mA, Motion: 900mA

 Controllable Range - Pitch: -90deg to +30deg

 Max Controllable Speed – Pitch: 120deg/s, Pan: 180deg/s

b. DJI Inspire Battery

 Model (Standard) TB47

 Voltage 22.2v

 Capacity 4500mAh

 Energy 99.9Wh

 Net Weight 570g

c. DJI Inspire Remote Controller

 Frequency 

o 5.725GHz~5.850GHz (Remote Controller to Remote Controller)

o 2.400GHz~2.483GHz (Remote Controller to Aircraft)

 Battery Capacity 6000mAh

 Working Current/Voltage 

1.2A@7.4V

Conclusion,
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The use of sUAS’s provide many benefits to the general public, such as: 

Decreased air pollution due to the enormous amount of leaded fuel needed to fly 

manned aerial vehicles, decreased noise pollution when near the public, 

Decreased air traffic congestion at airports and provides a more affordable and 

reasonable alternative to current options available to the consumer. As for safety, 

Small Unmanned Aerial Systems do not carry people or property so it provides 

less of a chance of injury in the case of an accident and because of the size and 

weight of manned aircraft the ground casualties can be far less or nonexistent in 

the case of a downed sUAS vs a manned aircraft.

Thank you for the consideration of these exemptions.

Sincerely,

Alexander G. Armstead