Sheldon S Devantier 

Designetic Designs LLC (DBA Dragonfly FX) 

4223 Canton Crest Dr. 

Katy, TX 77494 

Tel: (323) 325-2200 

Email: sd@dragonflyfx.com 

 Sheldon S Devantier 

Designetic Designs LLC (DBA Dragonfly FX) 

4223 Canton Crest Dr. 

Katy, TX 77494 

Tel: (323) 325-2200 

Email: sd@dragonflyfx.com 

 

Dear Sir or Madame, 

 

Please see the below exemption request pursuant to Section 333 of the FAA Reform Act and Part 

11 of the Federal Aviation Regulations. I have decided to reorganize my submission to better 

match the requirements of the exemption submission. Previous submission was FAA-2016-3496-

0002. 

(A)Specific Sections of 14 CFR 

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 61.101(e)(4) and (5) 

14 CFR 61.113(a) and (b) 

14 CFR 61.23(a) and (c) 

14 CFR 61.315(a) 

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) 

14 CFR 91.7(a) 

(B)Extent of Relief I Seek 

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the “Reform Act”) 

and 14 CFR Part 11, James Bender, operator of Unmanned Aircraft Systems (UAS), hereby 

applies for an exemption from the listed Federal Aviation Regulations (“FARs”) to allow 
commercial operation of designated UAS, provided such operations are conducted within and 

under the conditions outlined herein or as may be established by the FAA as required by 

Section333. 

Commercial operation of an UAS, as described herein, which are equipped with camera(s) 

and sensors, would provide professional services in the following areas: 

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 inspection/photography of residential/commercial utility infrastructure including but 

not limited to electrical power lines, wind turbines and cell towers. 

5. 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. 

6. Training to persons individually or belonging to both private and/or public organizations to 

increase awareness and improve safety for current and future UAS operations within the 

NAS. 

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

UAS as set forth in this document under controlled conditions in the NAS that would be a) 

limited b) controlled c) predetermined and d) safe. Approval of this exemption would increase 

public awareness of UAS operations and enhance safety to aid in fulfilling 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.” 

Accordingly, the applicant respectfully requests that the FAA grant the requested exemption and 

is prepared to modify or amend any part of this request to satisfy the need for an equivalent 

level of safety. I look forward to working with your office. Please contact me at any time if 

additional information or clarifications is needed. 

Sincerely, 

Sheldon S Devantier