John	M.	Brantley d/b/a	Drohne	Air
150	Klattenhoff	Lane	#5204
Hutto

, Texas	78634

June	27, 2015

United	States Department	of	Transportation Docket	Management	System 1200	New	Jersey	Ave.,	SE West	Building	Ground	Floor	W12

- 140 Washington	DC	20590

RE:	Exemption	Request	Section	333	of	the	FAA	Reform	Act	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; 1 4	CFR	91.119(c) ; 14	CFR 91.121; 14	CFR 91.151(a); 14	CFR 91.203	(a)	and	(b); 14	CFR	91.405	(a); 14	C FR	91.407 (a)	(1); 14 CFR	91.409	(a)(1)	and	(2); 14	CFR	91.417(a)	and	(b)

Dear	Sir	or	Madam:

The s UAS	proposed	by	the	petitioner	is	a	DJI	Inspire	1

Pursuant	to	Section	333	of	the	FAA	Modernization	and	Reform	Act	of	2012 (FMRA)	and	14	C.F.R.	Part	11, Owner ,	operator	of	sUAS, John	M.	Brantley
hereinafter d/b/a	Dr ohne	Air

, hereby	applies	for	an exemption	from	the	Federal
Aviation Regulations	(FARs)	liste d herein

.
The	requested	exemption	would	permit and	allow	commercial operation	of the ( D JI	Inspire	1) s UAS for f light	operations ; s o	long	as	all flight operations	are conducted	within

, and	under	the	co nditions	outlined	by	the	FAA	regulations
established under Section	333 of	the	FAA	Modernization	and	Reform	Act	of	2012 (FMRA)	and	14	C.F.R	Part	11

.
Drohne	Air	understands,	and	adheres	to	the additional regulations for Motion Picture	and	Television	closed

- set production

, found in	the	Motion	Picture	and
Television Operations	Manual	(MPTOM),	which	list	additional conditions	and
limitations that	must	be	met	for	flight	operations.U.S.	Department	of	Transportation

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Background	of	Applicant:

Retired	US	Army, Founder	of Drohne	Air, Jo hn	M.	Brantley	is	an expert within	the UAS	industry.	John	has	been	f lying	Unmanned	Aerial	Systems since	1 999	for	the United	States	Army, has	taken	the	PAR	Exam	with	a	score	95% and	by granting exemption	the	FAA	will	be	incorporating	an	Iraq	War	Veteran	with	over	800 (PIC)
combat hours	and	over	20 0	sorties	of	logg ed	flight	time in	a	combat zone.	John
has	coordinated UAS airspace ( AGL to FL	170 ) with the Untied	States	Air	Force along	with	other	A gencies.	He developed	the	Standard	Operating	Procedure for conducting	counter	mortar sea rch	an d attack	operations using	FalconView Mapping	System

. He	is	skilled	in	flying	multiple	Unmanned	Aerial	System s to include	the (RQ

- 7)	Shadow	200

, and the	(RQ

- 5)	Hunter

, Unmanned	Aerial System

. John has	also	accu mulated	3298	hour s of	Instructor time.	Instructing US	Army,
U AS	new	recruit	student s , on	the	RQ

- 7	Shadow	200

. John	holds	a	Bachelor Degree	in	Film	and	Motion	Picture,	from	one	of	the	top	Film	Universities	in	the country.	W ith	his	vast	knowledge	of	FAA	safety regulations he has	acquire d
th roughout his	UAS	career, John looks	forward	in	being	a	leader	in	the	civil application	of small Unmanned	Aerial	System s,	and	providing	safe	flight	for	those
who	seek s UAS	services.

sUAS Service to be Provided:

Drohne	Air,	is	a full	service	sUA S video, cinematography

, and photography

company using	DJI	Inspire	1	flight tech nology, which will provide sUAS service t o

c lients	in	the	foll owing related	Industry:

• Motion	Picture	/	Television

• V ideo /	Photogr aphy

• Inspection	/	Monitoring • Precision	Agriculture

• Mapping	/	Surveying

T he	requested	exemption	for	Drohne	Air would	permit	the	operation	of	DJI Inspire	1

, and would	mandate controlled safe conditions in	airspace	that	are:

1) Limited ; 2) Predetermined; 3) Controlled	as	to	access; Approval	of	this exemption	would	thereby	enhance	safety	and	fulfill	the	Secretary	of Transportation	(the	FAA	Administrator’s)	responsibilities	to,	“Establish requirements	for	the	safe	operation	of	such	sUAS	system s	in	the	national airspace	system. ” U nder	Section	333

, of	the	FAA	Modernization

, and	Reform	Act of	2012	(FMRA)	and	14	C.F.R	Part	11

.U.S.	Department	of	Transportation

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Drohne	Air understands :	Failure	to	comply	with the	conditions	a nd	limitations	of exemption herein, are	grounds	for immediate	s uspension	or	rescission	of Drohne
Air’s exemption.

The	name	and	addre ss	of	the	applicant :

Name:	John	M.	Brantley d/b/a	Drohne	Air
Phone:	512

- 900

- 0912
Email: johnbrantleyUAV@yahoo.com
Addre ss:	150	Klattenhoff	Lane	#5204 Hutto,	TX	78634

Reg ulations	from	which	the	exem ption	is	requested :

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	CFR	91.405	(a); 14	CFR	91.407	(a)	(1); 14	CFR	91.409	(a)(1)	and	(2); 14	CFR	91.417(a)	and	(b);

Unmanned A erial	Systems	and Safety :

T he Unmanned	Aerial	System	to	be	used is	the (DJI	Inspire	1) weighing less than
55lbs including	payloa d	and	will	at	all	times	operate	at	speeds less	than 50kts

. The	DJI	Inspire	1	has the	ability	hover

, and	move	along	a	vertical	and horizontal
axis simultaneously.	The	sUAS will	only be operate d by	a	certified Pilot	in
Command ; always	within	line	of line	of	sight

, and	always operate	within	a	closed off	predetermined	area.

Contracted	flights	of	the	Unmann ed	Aerial	System (DJI	Inspire	1) will occur	overU.S.	Department	of	Transportation

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private	or	controlled	access	property	and	will do	so	with	the	property	owner (s) or property representative(s)	verbal	and	written consent;	Only	persons evolved who
h ave given	their consent verbally	and	in	writing	will be	in	the predetermined area where video/ cinematography / photography will	take	place.

Unmanned	Aerial	Systems	often	times	are	seen	a s excellent	way t o	collect	digital imagery for	aerial video/ cinematography / photography

, due	to smaller	flight signature and	mobility,	as	well	as	being much	more	cost	effective	for individual persons	(or) corporations.

T he	level	of	safety of	the	DJI	Inspire	1	only	benefits	the	public	with a large decrease	in	environmental	impact,	including	b ut	not	limited to a	large decreased emissions	and	noise,	and	redundancy is built	into the	sUAS software. The	grant	of the	requested	exemp tion	is	in	the	public	interest and	promotes	public	safety

. Given	the	small	size	of	the	sUAS	(DJI	Inspire	1)	and	it’s	controlled	environment would	adhere	to	the	Reform	Act’s	safety	requirements,	and by the	approval	of this	application	presents	no	national	security	issues.

Unmanned A erial	Systems :

The permissions, limitations	and	con ditions	to	which	the	applicant	Drohne	Air agrees	to,	adheres	to

, without	deviation

, are under	the	FAA	issued	exemption	as set	forth	in	the	Flight Operations	Manual	(FOM).

The	DJI	Inspire	1, meets	all	specifications	for	small	Unmanned	Aerial	Systems
sUAS for	commercial use:

• The	sUAS (DJI	Inspire	1) weigh s less	than	55	lbs.

, to	include	payload.

• Flights	will	be	operated	within ( line	of	sight )	of Pilot	in	Command	and Visual
Observer at	all	tim es	during	flight s

.

• Maximum	f light	time	for	each flight	w ill	always	be	less	than 30	minutes.

• All	Flights	will	be	terminated	at	25%	battery power,	which	allows	for	sufficient

reserve battery	power	for	safe	landing	of	the	DJI	Inspire	1.

• 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	platfor m	from which	filming	is	planned.

• If	the	sUAS	loses communications ,	t he	DJI	Inspire	1	has	the capability	to ( return home) to	a	per

- determined	coordinate,	and	land	autonomously.

• Minimum	crew	for	each	flight	will	consist	of	the:	Pilot	in	Command, Visual Observer,	and may	(or)	may	not	include	a Camera	Operator.U.S.	Department	of	Transportation

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• The	Pilot	in	Command	will hold	a	current ( Third Class	Medical	Certificate ) or h igher ; along	with	a	valid ( State	Driver’s	License )	and	must	have at	least	20 hours	of	logged flight	time	on	the sUAS	system.

• A	mission briefing	will	be	performed	regarding	the	planned	sUAS flight operation	prior	to	each	takeoff

, and	a	debrief	after	ea ch	landing

.

• The	operator	will	file	FAA	Form	7711

- 1,	or	i ts	equivalent, with	the	appropriate local	Flight	Standards	District	Office	(FSDO)	no	more	than	72	hours	but	no	less than	48	hours	from	planned	operation.

• The PIC operator or company	representative(s ) will	obtain	verbal and	written consent	of	all	persons	involved	with	the	planned flight operation

.

• The PIC operator or company	representative(s)	will	ensure that	only written consenting persons	will	be	allowed	within	100	feet	of	the	flight	operation,

• T he	radius	may	be	reduced	to	30	feet	based	upon	an	equivalent	level	of safety

, required	under	the	FOM. Also,	a closer	range	c an	be	approved but must	be	done	in	advance,	and	with	the perm ission	of	the	FSDO.

• The	Pilot	in	Command	and	Visual Observer	will	stay current in all updated
sUAS

, FAA	flight	regulation s and	will	stay	current	of future	upgrades	to	sUAS flight	system s and	file	proper	exemptions	as	needed.

• The	Pilot	in	Command	an d	Visual	Observer	will	at	all	times	be able	to communicate	by	vo ice,	radio, headsets or while not	in	flight text	message

.

• All permission	and	permits	w ill	be	obtained	from	1)	State,	2)	County	3)	City jurisdictions,	including	Law	Enforcement,	F ire,	EMS	or	other	appropriate governmental	agencies.

• The	 sUAS has	 the	 capability	 to	abort flight s i n case	 of emergencies

, the	DJI Inspire	is	designed	to	( return	home )	to	a	per

- determined	coordinate, and	land autonomously.

DJI	Inspire	Unmanned A erial	System:U.S.	Department	of	Transportation

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Model T600

Weight	(Battery Included) 6.47lbs.

Hovering	Accuracy:

Vertical 1.6	feet

Horizontal 8.2	feet

Max	Angular Velocity 150°/s

Max	Tilt	Angle 35°

Max	Ascent	Speed 16.4	ft/s

Max	Decent	Speed 13.1	ft/s

Max	Speed 42	kts

Max	Flight	Time 18	minutes

Operating Temperature	Range 14°	F

- 104°

Dimension 18"x18"x12"U.S.	Department	of	Transportation

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Exemption	Requests	and	Equivalent	Level	of	Safety

Drohne	Air requests	an	exemption	from	the	following	regulations	as	well	as	any additional	regulations	that	may	technically apply	to	the	operation	of	the	sUAV Sys tems.

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	certi ficates	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	an d 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	th e	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.

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	tight ly	controlled	and monitored	by	both	the	operator	and	under	the	requirements	and	in	compliance with	local	public	safety	requirements.	The	FAA	will	have	advance	notice	of	all operations.	These	safety	enhancements	provide	a	greater	degree	of	safety	to	the pub lic	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.U.S.	Department	of	Transportation

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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	ne ar	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	a irworthiness	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	“Exper imental”	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	aircr aft	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	pi loting	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	sUA S.

14	C.F.R.	§91.7(a):	Civil	Aircraft	Airworthiness.

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.U.S.	Department	of	Transportation

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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	air craft,	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	f lying	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	func tional	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	airc raft.

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 prescribed,	provided	the	person	operating	the	helic opter	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	platfo rm	from	whichU.S.	Department	of	Transportation

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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	structu re	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	operati ons	without	their	pre

- obtained	consent.

The	equivalent	level	of	safety	will	be	achieved	given	the	size,	weight, and	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	loc al	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	mor e	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	operation s	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	f light.

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	a pproximately	30	minutes	of	powered flight.	To	meet	the 30

- minute reserve	requirement	in	14	CFR	§91.151,	sUASU.S.	Department	of	Transportation

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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	pr oposed operations	within	a	predetermined	area,	a	longer	time	frame	for	flight	in	daylight or	twilight	VFR	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	li miting 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	certifica te 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	operate d	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	ow ner	“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,	haveU.S.	Department	of	Transportation

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discrepancies	repaired	as	prescribed	in	part	43	of	this	chapter...,”	and	other s	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	ope rator	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	mainte nance	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	main tenance	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	fligh t	and	perform	required	maintenance	needed.

In	Summary

Our	proposal	for exemption criteria	has	been	met s atisfactory under: Section	333 of	the	FAA	Modernization	and	Reform	Act	of	2012	(FMRA)	and	14	C.F.R.	Part	11

, And the	Motion	Picture	and	Television Operations	Manual	(MPTOM)

, and	has
shown adequate validation for	the allowance of	th e	requested	exemptions	for

comme rcial	application.	John	M.	Brantley	d/b/a	Drohne	Air	is	excited to	join this new	frontier	as	the	FAA	moves	forward	in	the	quest	of	sUAS	unmanned	aircraft
into national	airspace.

Thank	You	for	your	time

Sincerely,

John	M.	Brantley	d/b/a	Drohne	Air

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- 0912 johnbrantleyUAV@yahoo.com
1500	Klattenhoff	Lan e	#5204
Hutto	Texas	78634