Cinema & Sound Group

PO Box 6335

Fishers, IN 46038 

Web: ExplorersLikeUs.com

Kevin Williams

Senior Managing Partner 

Ph: 317.284.1423

Monday, December 07, 2015

U. S. Department of Transportation 

U.S. Department of Transportation, Docket Operations

West Building Ground Floor, Room w12-140

1200 New Jersey Avenue, SE., Washington, DC 20590

REGARDING THE MATTER OF THE PETITION FOR EXEMPTION OF: 

Explorers Like Us, LLC, herein referred to as “Explorers Like Us”

FOR AN EXEMPTION SEEKING RELIEF FROM THE REQUIREMENTS OF TITLE 14 OF THE CODE OF FEDERAL 

REGULATIONS SECTIONS: Part 21 Subpart H, 45.23 (b), 61.113(a) &(b), 91.7 (a), 91.9 (b) (2), 91.103, 91.109 (a), 

91.119 (c), 91.121, 91.151 (a), 91.405 (a), 91.407 (a)(1), 91.409(a)(1) &(a)(2), AND 91.417(a) & (b) CONCERNING 

COMMERCIAL OPERATION OF THREE (3) DJI PHANTOM 3, AND TWO (2) DJI INSPIRE UNMANNED AIRCRAFT 

SYSTEMS PURSUANT TO SECTION 333 OF THE FAA MODERNIZATION AND REFORM ACT OF 2012 (PUBLIC LAW 

11295) 

Dear Sir(s) or Madam(s): 

Explorers Like Us is petitioning the Federal Aviation Administration (FAA) for an exemption pursuant 

to Section 333 of the FAA Modernization and Reform Act of 2012 (FMRA) and 14 CFR Part 11. The 

exemption is necessary to operate a small unmanned aircraft system (sUAS) commercially in FAA 

airspace. The exemption would allow operation of three (3) DJI Phantom 3 Professional and two (2) DJI 

Inspire sUAS for the purpose of videography and photography in controlled access areas for the 

purposes of: motion picture aerial photography, film acquisition and digital image acquisition, 

commercial development, civil planning, economic development, construction planning and/or 

documentation, corporate marketing and/or promotions, government and/or civic photography, 

videography and video production. This document will outline requested relief from regulations 

pertaining to this exemption request. 
Explorers Like Us agrees to operate within the boundaries set forth by this exemption. Along with 

rules and regulations that the FAA has in place, Explorers Like Us plans to incorporate additional 

safety precautions to ensure safest possible sUAS operations. Implementation of lightweight sUAS can 

greatly improve the safety standards of or National Airspace System (NAS) while mitigating the necessity 

of flight operations that traditionally require larger manned aircraft, which carry pilots and flammable 

fuel. Explorers Like Us is requesting the ability to offer sUAS operations and to promote the safe, 

efficient, and responsible use of sUAS. 

Kindest Regards, 

Kevin Williams

Senior Managing Partner

Explorers Like Us, LLC

K.Wlliams@ExplorersLikeUs.com

317.284.1423
Table of Contents

Table of Contents..........................................................................................................................................3

Section 1: Introduction and Interest of Petitioner.......................................................................................5

Section 2: Unmanned Aircraft Systems .......................................................................................................5

General Information Pertaining to All Proposed sUAS .............................................................................5

Equipment List ..............................................................................................................................................6

Section 3: Unmanned Aircraft Pilot in Command (PIC) ...............................................................................7

Section 4: Operation of sUAS.......................................................................................................................8

Operational Limitations................................................................................................................................8

Operations ....................................................................................................................................................9

Section 5: Requested Exemptions from Regulations.................................................................................11

14 C.F.R. Part 21 Subpart H - Airworthiness Certificates........................................................................11

14 C.F.R. § 45.23 (b) - Display of marks; general. ...................................................................................11

14 C.F.R. § 61.113 (a) & (b) - Private Pilot Privileges and Limitations: Pilot in Command......................11

14 C.F.R. § 91.7 (a) - Civil aircraft airworthiness.....................................................................................12

14 C.F.R. § 91.9 (b)(2) - Civil Aircraft Flight Manual in the Aircraft.........................................................12

14 C.F.R. § 91.103- Preflight action.........................................................................................................12

14 C.F.R. § 91.109 (a) - Flight instruction................................................................................................13

14 C.F.R. § 91.119 (c) - Minimum safe altitudes: General. ....................................................................13

14 C.F.R. § 91.121 - Altimeter settings....................................................................................................13

14 C.F.R. § 91.151 (a) - Fuel requirements for flight in VFR conditions..................................................13

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

Protection of Rights and Privacy.................................................................................................................14

Public Interest.............................................................................................................................................15

Conclusion...................................................................................................................................................15
Abbreviations Used in This Document

AGL Above Ground Level

ATC Air TrafficControl

COA Certificate of Authorization

ELU Explorers Like Us 

FAA Federal AviationAdministration

FAR Federal AviationRegulation

GCS Ground Control Station

GPS Global Positioning System

LOL Loss of Link

NAS National Airspace System

NOTAMS Notices to Airmen

PIC Pilot in Command

RTH Return to Home

SOG Speed Over Ground

sUAS Small Unmanned Aircraft Systems

VFR Visual FlightRules

VMC Visual MeteorologicalConditions

VO Visual Observer

VMC Visual MeteorologicalConditions

VLOS Visual Line of Sight
Section 1: Introduction and Interest of Petitioner

Explorers Like Us is a film production company (photography, videography, audio acquisition) located 

in Fishers, Indiana. We specialize in video production and documentary imaging, but also seek to 

expand our capabilities in other areas of image acquisition and related services. Explorers Like Us utilizes 

five (5) DJI sUAS platforms for the purpose of photography and videography in controlled access and 

highly restrictive environments. Explorers Like Us is committed to offering professional, safe and 

responsible sUAS flight operations while maintaining the highest possible standards of ethics, 

performance and integrity.

Privacy is a key concern of Explorer’s Like Us operations. Explorers Like Us sUAS operators are not 

permitted to undertake any operation that would otherwise invade or encumber any person's 

reasonable expectation of privacy when operating the sUAS. Explorers Like Us’ operators will abide by all 

FAA Regulations for flight and receive proper authorization prior to flight by Explorers Like Us and/or the 

FAA when required.

Please refer to the included 2016 Explorers Like Us Flight Operations Reference for details.

Section 2: Unmanned Aircraft Systems

General Information Pertaining to All Proposed sUAS 

Explorers Like Us will operate sUAS weighing less than 55 pounds, for the purpose of conducting aerial 

videography and photography acquisition with payloads capable of supporting these operations.

Prior to each flight the PIC and VO shall inspect the sUAS to ensure its condition is safe flight. If this 

inspection reveals a condition that affects the safe operations of the sUAS, the aircraft will be prohibited 

from operating until the necessary maintenance has been performed and the sUAS is for safe flight. 

Ground Control Station will also be included in preflight inspections. Maintenance and alterations must 

be properly documented and approved. All processes, maintenance and problems found must be signed 

off by two individuals independently, with one being the PIC of the operation of the sUAS on the 

particular mission.

Any maintenance or alterations made to a sUAS must be documented in the appropriate logbook, and 

the sUAS must undergo a functional test flight prior to it being returned to service. Any repairs or 

alterations must meet the manufacturer’s guidelines, with particular attention to flight critical 

components that may not be addressed in the manufacturer’s manuals. Only authorized personnel shall 

perform such operations. All maintenance must be signed off by two individuals independently, with 

one being the PIC of the operation of the sUAS on the particular mission.

Explorers Like Us will follow all sUAS manufacturer’s maintenance, overhaul, replacement, inspection, 

and life limit requirements for the aircraft and aircraft components. All maintenance, inspections, and 

record keeping will be done in accordance with the manufacturer’s operations manual, and will be 
noted in the appropriate logbook. All processes must be signed off by two individuals independently, 

with one being the PIC of the operation of the sUAS on the particular mission.

Each sUAS operated under the proposed exemption shall comply with all manufacturer System and 

Safety Bulletins. 

Before conducting any mission or flight operation, the radio frequency spectrum used for operation 

and control of the sUAS shall comply with Federal Communications Commission (FCC) or other 

appropriate government oversight agency requirements. 

Please refer to the included 2016 Explorers Like Us Flight Operations Reference for details.

Equipment List

DJI Phantom 3 Professional (3) 

Explorers Like Us seeks an exemption to operate three (3) DJI Phantom 3 Professional sUAS for 

compensation and/or hire. The DJI Phantom 3 Professional is comprised of a quadrotor-unmanned

aircraft and a handheld ground control station. The Phantom 3 Professional has a maximum gross

weight of approximately 1280 grams and diagonal size of approximately 635mm (including propellers 

and Explorer’s Like Us mandated safety guards). The Phantom 3 Professional is equipped with four 

rotors driven by four lithium polymer battery powered electric motors. Design and operational 

characteristics are provided in the DJI Phantom 3 Professional User Manual. PIC will conduct preflight 

inspections as documented in DJI Phantom 3 Professional User Manual and any standard Explorers Like 

Us may add from time to time that exceeds such standards and practices. 

For complete information on the DJI Phantom 3 Professional, including Radio Frequency (RF) spectrum 

used for control of the sUAS, please reference the attached DJI Phantom 3 Professional User Manual. 

DJI Inspire (2)

Explorers Like Us seeks an exemption to operate up to two (2) DJI Inspire sUAS for compensation 

and/or hire. The DJI Inspire 1 is comprised of a quad-rotor unmanned aircraft and a handheld ground 

control station. A second controller may be used by an addition person to operate the camera only. The 

Inspire 1 has a maximum gross weight of approximately 2935 grams and diagonal size of approximately 

581mm. The Inspire 1 is equipped with four rotors driven by four lithium polymer battery powered

electric motors. Design and operational characteristics are provided in the DJI Inspire 1 User Manual. PIC 

will conduct preflight inspections as documented in the DJI Inspire User Manual and any standard 

Explorers Like Us may add from time to time that exceeds such standards and practices.

For complete information on the DJI Inspire, including Radio Frequency (RF) spectrum used for control of 

the sUAS, please reference the attached DJI Inspire 1 Pro User Manual.
Section 3: Unmanned Aircraft Pilot in Command (PIC) 

Explorers Like Us’ flight crew, including PIC and Visual Observer (VO), will be qualified as directed by 

Explorers Like Us. 

All flight crew members, including PIC and VO, will have an understanding of, and comply with, Title 

14 Code of Federal Regulations (CFR), and/or FAA directives and regulations, applicable to airspace 

where the sUAS will operate. Specifically all flight crew members will receive training on the rules and 

responsibilities described in 14 CFR Part 91, Sections 91.111, 91.113, and 91.115. 

All Explorers Like Us PIC must meet current FAA minimum requirements regarding regulations for 

operator status. To meet current compliance, the PIC must possess at least a current sport pilot 

certificate and valid driver’s license. The PIC for Explorers Like Us currently maintains a private pilot 

certification (rotary and single-engine fixed wing) with VFR and IFR more than 1500 hours fixed-wing and 

more than 800 hours rotary flight experience. No violations on record.

All operations utilize a VO. The VO may be used to satisfy the Visual Line of Sight (VLOS) requirement as 

long as the PIC always maintains VLOS capability. The VO and PIC must be able to communicate verbally 

at all times. This condition and limitation is consistent with all FAA approved Exemptions.

Please refer to the included 2016 Explorers Like Us Flight Operations Reference for details.
Section 4: Operation of sUAS 

Operational Limitations 

Explorers Like Us is seeking sUAS operation under the following operational limitations.

• Unmanned aircraft must weigh less than 55 lbs. (25 kg). 

• Visual line-of-sight (VLOS) only. The unmanned aircraft must remain within VLOS of the operator 

and/or visual observer. 

• At all times the sUAS must remain close enough to the operator for the operator to be capable 

of seeing the aircraft with vision unaided by any device other than corrective lenses. 

• The sUAS may not operate over any person(s) not directly involved in the operation of the sUAS. 

• All operations will be conducted in controlled or restrictive access areas. 

• All Explorers Like Us sUAS operations may be conducted only in daylight-only operations (official 

sunrise to official sunset, local time). 

• All Explorers Like Us sUAS operations must yield right-of-way to other aircraft, manned or 

unmanned. 

• All Explorers Like Us sUAS operations must use a visual observer (VO) in addition to an 

authorized PIC. 

• First-person view camera on the sUAS cannot satisfy “see-and-avoid” requirement, but can be 

used as long as requirement is satisfied in other ways. 

• All Explorers Like Us sUAS operations operate under thee a maximum airspeed of 50 mph (44 

knots).

• All Explorers Like Us sUAS operations operate under a maximum altitude of 500 feet above 

ground level (AGL). 

• All Explorers Like Us sUAS operations require a minimum weather visibility of 3 miles from 

control station. 

• The sUAS may not operate within five (5) nautical miles of an airport unless a letter of 

agreement with that airport’s management is obtained or otherwise permitted by a COA. 

• No person may act as an operator or VO for more than one unmanned aircraft operation at one 

time. 

• No careless or reckless operations of Explorers Like Us sUAS are permitted under any 

circumstances. 

• The Explorers Like Us sUAS operators are responsible for maintaining and inspecting the sUAS to 

ensure that it can operate safely in terms of maintenance, functionality and flight plan 

characteristics. 

• Each sUAS operated requires preflight inspection by the operator. 

• No person may not operate or be a VO for a sUAS operation if he or she knows or has reason to 

believe they have any physical or mental condition that would preclude the safe operation of a 

sUAS. 

• Any sUAS that has undergone maintenance or alterations that affect the sUAS operation or 

flight characteristics mush undergo a functional flight test prior to conducting further operations
and be signed off by no fewer than two (2) authorized persons consisting of an authorized PIC 

and/or VO.

• All Explorers Like Us sUAS are equipped with GPS and return to home functionality should loss 

of link occur. 

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

• The sUAS will not be operated less than 500 feet below, or less than 2000 feet horizontally from 

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

• The sUAS must be operated within all Federal, state and local laws and covenants.

• The sUAS may not be operated in such a manner as to compromise the reasonable expectations 

of an individual’s privacy.

• The Explorers Like Us sUAS may not be used for in conjunction with any investigation (private, 

civil and/or criminal) of any individual or entity.

Please refer to the included 2016 Explorers Like Us Flight Operations Reference for details.

Operations 

Explorers Like Us is a production company (photography, videography, audio acquisition) located in 

Fishers, Indiana. Explorers Like Us utilizes two (2) DJI sUAS platforms for the purpose of photography 

and videography in controlled access areas: the DJI Phantom 3 Professional and DJI Inspire. Explorers 

Like Us is committed to offering safe, responsible and ethical sUAS flight operations. 

Current and intended future applications of Explorers Like Us’ sUAS are flown in low risk, controlled 

access areas including: motion picture aerial photography, film acquisition and digital image 

acquisition, commercial development, civil planning, economic development, construction planning 

and/or documentation, corporate marketing and/or promotions, government and/or civic 

photography, videography and video production. Protocols and controls are in place to ensure safety of 

property and nonparticipating individuals. These include, but are not limited to: not operating over any 

persons not directly involved in the operation, conducting all operations in controlled or restricted 

access areas, and posting warning signs for the public at the perimeter of the controlled access area

when necessary. Protocols and controls are executed before, during, and after every flight to ensure 

safety, and are outlined by the PIC and VO and submitted to Explorers Like Us at the end of each 

acquisition. 

Explorers Like Us believes that the public can benefit greatly with the addition of sUAS photography 

and videography in the local market by providing safer photography and videography than that 

provided by traditional forms of manned aircraft. 

Current use of manned aircraft are noisy and operate with appreciably greater potential risk. Explorers 

Like Us can perform tasks at a lower risk level while at the same time not disrupting the surrounding 

community. Benefits of sUAS photography and videography include: less noise (electric motors vs gas 

powered engines), significantly reduced aircraft size and weight (sUAS are less than 55 lbs; our current 

aircraft all weigh less than 8 lbs), slower flight speeds (1 MPH to less than 50 MPH), carrying no pilots or 
crew, no gallons of flammable fuel onboard, and greater versatility to safely capture closer, lower 

altitude shots. 

Explorers Like Us’ first priority is safety. All operations performed will meet FAA safety standards, 

keeping the NAS safe and clear for manned aircraft flight.

Please refer to the included 2016 Explorers Like Us Flight Operations Reference for details.
Section 5: Requested Exemptions from Regulations 

14 C.F.R. Part 21 Subpart H - Airworthiness Certificates 

[Per RIN: 2120–AJ60; Docket No.: FAA-2015-0150; Notice No.: 15-01; NPRM 2-15-2015] 

“The FAA believes that treating small UAS as a single category without airworthiness certification would 

accommodate a large majority of small UAS businesses and other non-recreational users of UAS. The 

operational limits in this proposed rule would mitigate risk associated with small UAS operations in a 

way that would provide an equivalent level of safety to the NAS with the least amount of burden to 

business and other non-recreational users of even the smallest UAS.” -Pages 53-54 

14 C.F.R. § 45.23 (b) - Display of marks; general. 

[Per RIN: 2120–AJ60; Docket No.: FAA-2015-0150; Notice No.: 15-01; NPRM 2-15-2015] 

“The FAA acknowledges that some small unmanned aircraft may be too small to comply with the 

minimum-display-size requirements of part 45. However, as mentioned previously, part 45 already 

contains a provision, § 45.29(f), that would address this issue by allowing the too-small aircraft to simply 

display its registration number in as large a manner as practicable. Accordingly, the size of the small 

unmanned aircraft would not be a barrier to compliance with the provisions of Subpart C of part 45.” 

-Page 130 

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

[Per RIN: 2120–AJ60; Docket No.: FAA-2015-0150; Notice No.: 15-01; NPRM 2-15-2015] 

“The FAA proposes to require that applicants for an unmanned aircraft operator certificate with a small 

UAS rating pass an initial knowledge test to demonstrate that they have sufficient aeronautical 

knowledge to safely operate a small UAS. The FAA proposes a knowledge test rather than a required 

training course in order to provide applicants with flexibility as to the method that they use to acquire 

aeronautical knowledge. ” -Page 103 

Because the sUAS will not carry a pilot or passengers, the proposed operations can achieve the 

equivalent level of safety of current operations and applicable knowledge level by requiring the PIC 

operating the sUAS to have at minimum a sport pilot’s certification rather than a commercial pilot’s 

license to operate a sUAS. Unlike a conventional manned aircraft, a sUAS is remotely controlled by a 

ground-based operator. The operational area is controlled and restricted, and all flights are planned and 

coordinated in advance. The level of safety exceeds that provided by a single individual holding a 

commercial pilot’s certificate operating a conventional aircraft. The risks associated with the use of a 

sUAS are so diminished from the level of risk associated with commercial operations contemplated by 

Part 61 allowing sUAS use by a sport pilot as the PIC exceeds the present level of safety sought by 14 

C.F.R. §61.113 (a) and (b). 
14 C.F.R. § 91.7 (a) - Civil aircraft airworthiness. 

[Per RIN: 2120–AJ60; Docket No.: FAA-2015-0150; Notice No.: 15-01; NPRM 2-15-2015] 

“FAA noted that, as mentioned previously, due to their light weight, small unmanned aircraft generally 

pose a significantly lower risk to people and property on the ground than manned aircraft. This relatively 

low risk is mitigated even further by the see-and-avoid and loss-of-positive-control provisions of this 

proposed rule, which are discussed above. Accordingly, based on existing information, the FAA believes 

that requiring small UAS operators to conduct inspection and maintenance of the small UAS pursuant to 

the existing regulations of part 43, or to obtain a PTO, would not result in significant safety benefits. As a 

result, this proposed rule would not require small UAS compliance with part 43 or the application for, or 

issuance of, a PTO. 

Instead, this proposed rule would require, in § 107.21(b), that prior to each flight, the operator must 

inspect the small UAS to ensure that it is in a condition for safe operation. The operator could do this by, 

for example, performing a manufacturer-recommended preflight inspection or performing an on-theground test of the small UAS to determine whether safety-critical systems and components are working 

properly.” -Page 90 

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 and 

the requirements contained in the sUAS User and Maintenance manuals, for maintenance and use of 

safety check lists prior to each flight, as set forth in Explorers Like Us’ FOM, 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) states that no person may operate a U.S.-registered civil aircraft ...unless there is 

available in the aircraft a current approved Airplane or Rotorcraft Flight Manual. 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.

Section 91.103 requires each pilot to preflight an aircraft before flight to insure the safety of flight. As 

FAA approved flight manuals will not be used, an exemption is requested. However, an equivalent level 

of safety will be provided. The PIC will take all actions, including reviewing weather, flight battery 

requirements, landing and takeoff distances, and aircraft performance data before commencement of 

flight.
14 C.F.R. § 91.109 (a) - 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. 

14 C.F.R. § 91.119 (c) - Minimum safe altitudes: General. 

[Per RIN: 2120–AJ60; Docket No.: FAA-2015-0150; Notice No.: 15-01; NPRM 2-15-2015] 

“With regard to the vertical boundary, the FAA proposes, in § 107.51(b), to set an altitude ceiling of 

500 feet above ground level (AGL) for small UAS operations that would be subject to this proposed 

rule. The FAA chose to propose 500 feet as the vertical area-of-operation boundary because most 

manned aircraft operations take place above 500 feet. Specifically, most manned aircraft operations 

conducted over uncongested areas must be flown at an altitude above 500 feet AGL, while most 

manned aircraft operations conducted over congested areas must be flown at an even higher altitude. 

Thus, a 500-foot altitude ceiling for small UAS operations would create a buffer between a small 

unmanned aircraft and most manned aircraft flying in the NAS. Even though some manned aircraft 

operations take place at an altitude below 500 feet, there is significantly less air traffic at or below 500 

feet than there is above 500 feet altitude. As a result of this difference in air-traffic density, the FAA 

has determined that small UAS operations would not pose a significant risk to manned aircraft 

operations taking place below 500 feet altitude if proper precautions are taken by the small UAS 

operator.” - Pages 77-78 

14 C.F.R. § 91.121 - Altimeter settings. 

Section 91.121 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 a sUAS may not have a barometric altimeter, but instead GPS altitude 

data, an exemption is needed. An equivalent level of safety will be achieved by the operator confirming 

the altitude of the launch site shown on the GPS altitude indicator and logged in the flight log 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 . . . .” 
Proposed relief would be that Explorers Like Us be prohibited from beginning a flight unless 

(considering wind and forecast weather conditions) there is enough available power for the sUAS to 

conduct the intended operation and to operate after that for at least 5 minutes or with the reserve 

power recommended by the manufacturer if greater. 

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

[Per RIN: 2120–AJ60; Docket No.: FAA-2015-0150; Notice No.: 15-01; NPRM 2-15-2015] 

“FAA noted that, as mentioned previously, due to their light weight, small unmanned aircraft 

generally pose a significantly lower risk to people and property on the ground than manned aircraft. 

This relatively low risk is mitigated even further by the see-and-avoid and loss-of-positive-control 

provisions of this proposed rule, which are discussed above. Accordingly, based on existing 

information, the FAA believes that requiring small UAS operators to conduct inspection and 

maintenance of the small UAS pursuant to the existing regulations of part 43, or to obtain a PTO, would 

not result in significant safety benefits. As a result, this proposed rule would not require small UAS 

compliance with part 43 or the application for, or issuance of, a PTO. 

Instead, this proposed rule would require, in § 107.21(b), that prior to each flight, the operator must 

inspect the small UAS to ensure that it is in a condition for safe operation. The operator could do this 

by, for example, performing a manufacturer-recommended preflight inspection or performing an onthe-ground test of the small UAS to determine whether safety-critical systems and components are 

working properly.” -Page 90

Given that these sections and Part 43 apply only to aircraft with an airworthiness certificate, these 

sections will not apply. Maintenance will be accomplished by the operator. An equivalent level of safety 

will be achieved because the sUASs are limited in size, will carry a small payload and operate only in 

controlled access areas for limited periods of time. If mechanical issues arise, the sUAS can land 

immediately and will be operating from no higher than 500 feet AGL. As provided in the FOM, the 

operator will ensure that the s UAS is in working order prior to flight, perform any required 

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

most familiar with the UAS and best suited to maintain it in an airworthy condition.

Protection of Rights and Privacy 

sUAS PIC, VO, or any other person involved in flight mission are to observe privacy rights or 

expectations of the public. Any person involved in any unlawful flights that may jeopardize someone's 

privacy right or expectations will be held accountable for their actions and is ground for immediate 

termination.

Explorer’s Like Us has voluntarily adopted a stringent privacy policy that expressly prohibits any use of 

our sUAS vehicles in any manner inconsistent with the protections and respect of the reasonable 

rights of privacy of any and all individual’s incidental to the filming, photographic, research or other 
related sUAS activity. We also do not permit any Explorers Like Us sUAS to take part in any private, civil 

or Federal criminal, civil or any other investigation of any individual or entity.

Public Interest 

As established by the sUAS exemptions already granted by the FAA, allowing commercial operations 

of sUASs for aerial videography and photography will enhance safety by reducing risk. Conventional 

aerial operations, using turbine aircraft, operate at low altitudes and present the risks associated with 

aircraft that weigh around 4,000 pounds, and which carry large amounts of fuel. Such aircraft must also 

fly to and from the location. In contrast, a sUAS weighing fewer than 55 pounds and powered by 

batteries eliminates virtually all of that risk given the small size and lack of combustible fuel. The sUAS is 

carried, and not flown, to a location. In this regard, the sUAS carries no passengers or crew and, 

therefore, will not expose them to the risks associated with manned flights. 

The operation of sUASs conducted under Explorers Like Us’ strict flight conditions in addition to the 

FAA requirements and manufacturer recommendations will provide an equivalent level of safety 

supporting the grant of the exemption requested herein. The sUASs operate at slow speeds, close to 

the ground, and in a controlled access environment. As a result, they are far safer than conventional 

operations conducted with turbine helicopters flying near the ground and people. 

Conclusion

Explorers Like Us is committed to supporting and promoting the safe responsible and ethical 

implementation of sUAS into our National Airspace System (NAS). Explorers Like Us can and will perform 

safe, efficient, ethical and responsible sUAS flight operations and promote legal flight operations to 

ensure greater public safety and discouraging unlawful use, while lessening the risk to pilots, property, 

and civilians. 

Should you have any questions or requests for other information, please contact us directly. We will be 

happy to get the requested information as soon as possible.

Kevin Williams

Senior Partner, Explorers Like Us LLC

K.Williams@ExplorersLikeUs.com

317.284.1423