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; 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)

Dear	Sir	or	Madam:	

The	sUAS	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	Drohne	Air, hereby	applies	for	an	exemption	from	the	Federal	

Aviation	Regulations	(FARs)	listed herein.

The	requested	exemption	would	permit	and	allow	commercial	operation	of	the	

(DJI	Inspire	1) sUAS for	flight	operations; so	long	as	all flight	operations	are	

conducted	within, and	under	the	conditions	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.	
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Background	of	Applicant:	

Retired	US	Army,	Founder	of	Drohne	Air,	John	M.	Brantley	is	an expert within	the	

UAS	industry.	John	has	been	flying	Unmanned	Aerial	Systems since	1999	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	200	sorties	of	logged	flight	time in	a	combat zone.	John

has	coordinated	UAS	airspace	(AGL to FL	170) with	the	Untied	States	Air	Force	

along	with	other	Agencies.	He	developed	the	Standard	Operating	Procedure	for	

conducting	counter	mortar	search	and attack	operations using	FalconView	

Mapping	System. He	is	skilled	in	flying	multiple	Unmanned	Aerial	Systems to	

include	the	(RQ-7)	Shadow	200,	and	the	(RQ-5)	Hunter, Unmanned	Aerial	System.	

John has	also	accumulated	3298	hours of	Instructor time.	Instructing	US	Army,	

UAS	new	recruit	students, 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.	With	his	vast	knowledge	of	FAA	safety regulations he	has	acquired	

throughout his	UAS	career,	John looks	forward	in	being	a	leader	in	the	civil	

application	of	small	Unmanned	Aerial	Systems,	and	providing	safe	flight	for	those	

who	seek	sUAS	services.		

sUAS	Service	to	be	Provided:				

Drohne	Air,	is	a full	service	sUAS	video, cinematography, and photography

company	using	DJI	Inspire	1	flight	technology,	which	will provide	sUAS	service to	

clients	in	the	following	related	Industry:

• Motion	Picture	/	Television	

• Video /	Photography

• Inspection	/	Monitoring	

• Precision	Agriculture	

• Mapping	/	Surveying	

The	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	systems	in	the	national	

airspace	system.” Under	Section	333, of	the	FAA	Modernization, and	Reform	Act	

of	2012	(FMRA)	and	14	C.F.R	Part	11.
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Drohne	Air	understands:	Failure	to	comply	with	the	conditions	and	limitations	of	

exemption	herein,	are	grounds	for	immediate	suspension	or	rescission	of	Drohne	

Air’s	exemption.	

The	name	and	address	of	the	applicant:	

Name:	John	M.	Brantley																																																																																															

d/b/a	Drohne	Air																																																																																																												

Phone:	512-900-0912																																																																																																					

Email:	johnbrantleyUAV@yahoo.com 																																																																	

Address:	150	Klattenhoff	Lane	#5204																																																																							

Hutto,	TX	78634

Regulations	from	which	the	exemption	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	Aerial	Systems	and Safety:

The	Unmanned	Aerial	System	to	be	used	is	the	(DJI	Inspire	1)	weighing	less than	

55lbs including	payload	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	operated 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	Unmanned	Aerial	System (DJI	Inspire	1) will occur	over	
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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	

have	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	as	excellent	way to	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.	

The	level	of	safety	of	the	DJI	Inspire	1	only	benefits	the	public	with	a	large	

decrease	in	environmental	impact,	including	but	not	limited	to	a	large decreased	

emissions	and	noise,	and	redundancy	is	built	into the	sUAS	software.	The	grant	of	

the	requested	exemption	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	Aerial	Systems:

The permissions,	limitations	and	conditions	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)	weighs less	than	55	lbs., to	include	payload.

• Flights	will	be	operated	within	(line	of	sight)	of	Pilot	in	Command	and	Visual	

Observer	at	all	times	during	flights.

• Maximum	flight	time	for	each	flight	will	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	platform	from	

which	filming	is	planned.

• If	the	sUAS	loses	communications,	the	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.	
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• The	Pilot	in	Command	will hold	a	current	(Third	Class	Medical	Certificate) or	

higher; 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	each	landing.	

• The	operator	will	file	FAA	Form	7711-1,	or	its	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,	

• The	radius	may	be	reduced	to	30	feet	based	upon	an	equivalent	level	of	

safety,	required	under	the	FOM.	Also,	a closer	range	can	be	approved but	

must	be	done	in	advance,	and	with	the	permission	of	the	FSDO.	

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

sUAS, FAA	flight	regulations and	will	stay	current	of future	upgrades	to	sUAS	

flight	systems and	file	proper	exemptions	as	needed.	

• The	Pilot	in	Command	and	Visual	Observer	will	at	all	times	be	able	to	

communicate	by	voice,	radio, headsets or	while	not	in	flight text	message.	

• All	permission	and	permits	will	be	obtained	from	1)	State,	2)	County	3)	City	

jurisdictions,	including	Law	Enforcement,	Fire,	EMS	or	other	appropriate	

governmental	agencies.	

• The	 sUAS	has	 the	 capability	 to	abort	flights in	 case	 of	emergencies, the	DJI	

Inspire	is	designed	to	(return	home)	to	a	per-determined	coordinate,	and	land	

autonomously.

DJI	Inspire	Unmanned	Aerial	System:
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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"	
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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	

Systems.	

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.	

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.	The	FAA	will	have	advance	notice	of	all	

operations.	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.	
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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	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.	

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.	
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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	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	

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	
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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	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,	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	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	
U.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	proposed	

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	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	
U.S.	Department	of	Transportation	

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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	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.	

In	Summary	

Our	proposal	for exemption criteria	has	been	met satisfactory	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	the	requested	exemptions	for	

commercial	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																																																																																

512-900-0912																																																																							

johnbrantleyUAV@yahoo.com																																																																																				

1500	Klattenhoff	Lane	#5204																																																																																						

Hutto	Texas	78634