September 2, 2015

Exemption No. 12721

Regulatory Docket No. FAA–2015–2078

Mr. Justin Rivera

Limitless Drones, LLC

3208 East Colonial Drive

Suite 108

Orlando, FL 32803

Dear Mr. Rivera:

This letter is to inform you that we have granted your request for exemption. It transmits our 

decision, explains its basis, and gives you the conditions and limitations of the exemption, 

including the date it ends.

By letter posted to the public docket on June 4, 2015, and additional information dated 

June 4, 2015, you petitioned the Federal Aviation Administration (FAA) on behalf of 

Limitless Drones, LLC (hereinafter petitioner or operator) for an exemption. The petitioner

requested to operate an unmanned aircraft system (UAS) to conduct aerial photography and 

videography for real estate, and motion picture and television production.

See Appendix A for the petition submitted to the FAA describing the proposed operations and 

the regulations that the petitioner seeks an exemption.

The FAA has determined that good cause exists for not publishing a summary of the petition 

in the Federal Register because the requested exemption would not set a precedent, and any 

delay in acting on this petition would be detrimental to the petitioner.

Airworthiness Certification

The UAS proposed by the petitioner are the DJI S1000, DJI S900, DJI Phantom 2, and DJI 

Inspire 1.
2

The petitioner requested relief from 14 CFR part 21, Certification procedures for products 

and parts, Subpart H—Airworthiness Certificates. In accordance with the statutory criteria 

provided in Section 333 of Public Law 112−95 in reference to 49 U.S.C. § 44704, and in 

consideration of the size, weight, speed, and limited operating area associated with the 

aircraft and its operation, the Secretary of Transportation has determined that this aircraft 

meets the conditions of Section 333. Therefore, the FAA finds that the requested relief from 

14 CFR part 21, Certification procedures for products and parts, Subpart H—Airworthiness 

Certificates, and any associated noise certification and testing requirements of part 36, is 

not necessary.

The Basis for Our Decision

You have requested to use a UAS for aerial data collection1and closed set motion picture and 

filming. The FAA has issued grants of exemption in circumstances similar in all material 

respects to those presented in your petition. In Grants of Exemption Nos. 11062 to Astraeus 

Aerial (see Docket No. FAA−2014−0352), 11109 to Clayco, Inc. (see Docket No. 

FAA−2014−0507), 11112 to VDOS Global, LLC (see Docket No. FAA−2014−0382), and 

11213 to Aeryon Labs, Inc. (see Docket No. FAA−2014−0642), the FAA found that the 

enhanced safety achieved using an unmanned aircraft (UA) with the specifications described 

by the petitioner and carrying no passengers or crew, rather than a manned aircraft of 

significantly greater proportions, carrying crew in addition to flammable fuel, gives the FAA 

good cause to find that the UAS operation enabled by this exemption is in the public interest.

Having reviewed your reasons for requesting an exemption, I find that—

 They are similar in all material respects to relief previously requested in Grant of 

Exemption Nos. 11062, 11109, 11112, and 11213;

 The reasons stated by the FAA for granting Exemption Nos. 11062, 11109, 11112, and 

11213 also apply to the situation you present; and 

 A grant of exemption is in the public interest.

Our Decision

In consideration of the foregoing, I find that a grant of exemption is in the public interest. 

Therefore, pursuant to the authority contained in 49 U.S.C. 106(f), 40113, and 44701, 

delegated to me by the Administrator, Limitless Drones, LLC is granted an exemption from 

14 CFR §§ 61.23(a) and (c), 61.101(e)(4) and (5), 61.113(a), 61.315(a), 91.7(a), 91.119(c), 

91.121, 91.151(a)(1), 91.405(a), 91.407(a)(1), 91.409(a)(1) and (2), and 91.417(a) and (b), to 

the extent necessary to allow the petitioner to operate a UAS to perform aerial data collection 

 

1 Aerial data collection includes any remote sensing and measuring by an instrument(s) aboard the UA. 

Examples include imagery (photography, video, infrared, etc.), electronic measurement (precision surveying, RF 

analysis, etc.), chemical measurement (particulate measurement, etc.), or any other gathering of data by 

instruments aboard the UA.
3

and closed set motion picture and filming. This exemption is subject to the conditions and 

limitations listed below.

Conditions and Limitations

In this grant of exemption, Limitless Drones, LLC is hereafter referred to as the operator.

Failure to comply with any of the conditions and limitations of this grant of exemption will be 

grounds for the immediate suspension or rescission of this exemption.

1. Operations authorized by this grant of exemption are limited to the DJI S1000, DJI 

S900, DJI Phantom 2, and DJI Inspire 1 when weighing less than 55 pounds including 

payload. Proposed operations of any other aircraft will require a new petition or a 

petition to amend this exemption.

2. Operations for the purpose of closed-set motion picture and television filming 

are permitted. 

3. The UA may not be operated at a speed exceeding 87 knots (100 miles per hour). The 

exemption holder may use either groundspeed or calibrated airspeed to determine 

compliance with the 87 knot speed restriction. In no case will the UA be operated at 

airspeeds greater than the maximum UA operating airspeed recommended by the 

aircraft manufacturer.

4. The UA must be operated at an altitude of no more than 400 feet above ground level 

(AGL). Altitude must be reported in feet AGL.

5. The UA must be operated within visual line of sight (VLOS) of the PIC at all times. 

This requires the PIC to be able to use human vision unaided by any device other than 

corrective lenses, as specified on the PIC’s FAA-issued airman medical certificate or 

U.S. driver’s license.

6. All operations must utilize a visual observer (VO). The UA must be operated within 

the visual line of sight (VLOS) of the PIC and VO at all times. The VO may be used 

to satisfy the VLOS requirement as long as the PIC always maintains VLOS 

capability. The VO and PIC must be able to communicate verbally at all times; 

electronic messaging or texting is not permitted during flight operations. The PIC 

must be designated before the flight and cannot transfer his or her designation for the 

duration of the flight. The PIC must ensure that the VO can perform the duties 

required of the VO.

7. This exemption and all documents needed to operate the UAS and conduct its 

operations in accordance with the conditions and limitations stated in this grant of 

exemption, are hereinafter referred to as the operating documents. The operating 
4

documents must be accessible during UAS operations and made available to the 

Administrator upon request. If a discrepancy exists between the conditions and 

limitations in this exemption and the procedures outlined in the operating documents, 

the conditions and limitations herein take precedence and must be followed. 

Otherwise, the operator must follow the procedures as outlined in its operating 

documents. The operator may update or revise its operating documents. It is the 

operator’s responsibility to track such revisions and present updated and revised 

documents to the Administrator or any law enforcement official upon request. The 

operator must also present updated and revised documents if it petitions for extension 

or amendment to this grant of exemption. If the operator determines that any update 

or revision would affect the basis upon which the FAA granted this exemption, then 

the operator must petition for an amendment to its grant of exemption. The FAA’s 

UAS Integration Office (AFS−80) may be contacted if questions arise regarding 

updates or revisions to the operating documents.

8. Any UAS that has undergone maintenance or alterations that affect the UAS operation 

or flight characteristics, e.g., replacement of a flight critical component, must undergo 

a functional test flight prior to conducting further operations under this exemption. 

Functional test flights may only be conducted by a PIC with a VO and must remain at 

least 500 feet from other people. The functional test flight must be conducted in such 

a manner so as to not pose an undue hazard to persons and property.

9. The operator is responsible for maintaining and inspecting the UAS to ensure that it is 

in a condition for safe operation.

10. Prior to each flight, the PIC must conduct a pre-flight inspection and determine the 

UAS is in a condition for safe flight. The pre-flight inspection must account for all 

potential discrepancies, e.g., inoperable components, items, or equipment. If the 

inspection reveals a condition that affects the safe operation of the UAS, the aircraft is 

prohibited from operating until the necessary maintenance has been performed and the 

UAS is found to be in a condition for safe flight.

11. The operator must follow the UAS manufacturer’s maintenance, overhaul, 

replacement, inspection, and life limit requirements for the aircraft and 

aircraft components.

12. Each UAS operated under this exemption must comply with all manufacturer 

safety bulletins.

13. Under this grant of exemption, a PIC must hold either an airline transport, 

commercial, private, recreational, or sport pilot certificate. The PIC must also hold a 

current FAA airman medical certificate or a valid U.S. driver’s license issued by a 

state, the District of Columbia, Puerto Rico, a territory, a possession, or the Federal 
5

government. The PIC must also meet the flight review requirements specified in 

14 CFR § 61.56 in an aircraft in which the PIC is rated on his or her pilot certificate.

14. The operator may not permit any PIC to operate unless the PIC demonstrates the 

ability to safely operate the UAS in a manner consistent with how the UAS will be 

operated under this exemption, including evasive and emergency maneuvers and 

maintaining appropriate distances from persons, vessels, vehicles and structures. PIC 

qualification flight hours and currency must be logged in a manner consistent with 

14 CFR § 61.51(b). Flights for the purposes of training the operator’s PICs and VOs 

(training, proficiency, and experience-building) and determining the PIC’s ability to 

safely operate the UAS in a manner consistent with how the UAS will be operated 

under this exemption are permitted under the terms of this exemption. However, 

training operations may only be conducted during dedicated training sessions. During 

training, proficiency, and experience-building flights, all persons not essential for 

flight operations are considered nonparticipants, and the PIC must operate the UA 

with appropriate distance from nonparticipants in accordance with 14 CFR § 91.119.

15. UAS operations may not be conducted during night, as defined in 14 CFR § 1.1. All 

operations must be conducted under visual meteorological conditions (VMC). Flights 

under special visual flight rules (SVFR) are not authorized.

16. The UA may not operate within 5 nautical miles of an airport reference point (ARP) as 

denoted in the current FAA Airport/Facility Directory (AFD) or for airports not 

denoted with an ARP, the center of the airport symbol as denoted on the current 

FAA-published aeronautical chart, unless a letter of agreement with that airport’s 

management is obtained or otherwise permitted by a COA issued to the exemption 

holder. The letter of agreement with the airport management must be made available 

to the Administrator or any law enforcement official upon request.

17. The UA may not be operated less than 500 feet below or less than 2,000 feet 

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

18. If the UAS loses communications or loses its GPS signal, the UA must return to a 

pre-determined location within the private or controlled-access property.

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

20. The PIC is prohibited from beginning a flight unless (considering wind and forecast 

weather conditions) there is enough available power for the UA to conduct the 

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

power recommended by the manufacturer if greater.

21. Air Traffic Organization (ATO) Certificate of Waiver or Authorization (COA). All 

operations shall be conducted in accordance with an ATO-issued COA. The 
6

exemption holder may apply for a new or amended COA if it intends to conduct 

operations that cannot be conducted under the terms of the attached COA.

22. All aircraft operated in accordance with this exemption must be identified by serial 

number, registered in accordance with 14 CFR part 47, and have identification 

(N−Number) markings in accordance with 14 CFR part 45, Subpart C. Markings must 

be as large as practicable.

23. Documents used by the operator to ensure the safe operation and flight of the UAS and 

any documents required under 14 CFR §§ 91.9 and 91.203 must be available to the 

PIC at the Ground Control Station of the UAS any time the aircraft is operating. 

These documents must be made available to the Administrator or any law enforcement 

official upon request.

24. The UA must remain clear and give way to all manned aviation operations and 

activities at all times. 

25. The UAS may not be operated by the PIC from any moving device or vehicle. 

26. All Flight operations must be conducted at least 500 feet from all nonparticipating 

persons, vessels, vehicles, and structures unless:

a. Barriers or structures are present that sufficiently protect nonparticipating persons 

from the UA and/or debris in the event of an accident. The operator must ensure 

that nonparticipating persons remain under such protection. If a situation arises 

where nonparticipating persons leave such protection and are within 500 feet of 

the UA, flight operations must cease immediately in a manner ensuring the safety 

of nonparticipating persons; and

b. The owner/controller of any vessels, vehicles or structures has granted permission 

for operating closer to those objects and the PIC has made a safety assessment of 

the risk of operating closer to those objects and determined that it does not 

present an undue hazard.

The PIC, VO, operator trainees or essential persons are not considered 

nonparticipating persons under this exemption.

27. All operations shall be conducted over private or controlled-access property with 

permission from the property owner/controller or authorized representative. 

Permission from property owner/controller or authorized representative will be 

obtained for each flight to be conducted.

28. Any incident, accident, or flight operation that transgresses the lateral or vertical 

boundaries of the operational area as defined by the applicable COA must be reported 

to the FAA's UAS Integration Office (AFS−80) within 24 hours. Accidents must be 
7

reported to the National Transportation Safety Board (NTSB) per instructions 

contained on the NTSB Web site: www.ntsb.gov.

If this exemption permits operations for the purpose of closed-set motion picture and 

television filming and production, the following additional conditions and limitations apply.

29. The operator must have a motion picture and television operations manual (MPTOM) 

as documented in this grant of exemption.

30. At least 3 days before aerial filming, the operator of the UAS affected by this 

exemption must submit a written Plan of Activities to the local Flight Standards 

District Office (FSDO) with jurisdiction over the area of proposed filming. The 3-day 

notification may be waived with the concurrence of the FSDO. The plan of activities 

must include at least the following:

a. Dates and times for all flights;

b. Name and phone number of the operator for the UAS aerial filming conducted 

under this grant of exemption;

c. Name and phone number of the person responsible for the on-scene operation of 

the UAS;

d. Make, model, and serial or N−Number of UAS to be used;

e. Name and certificate number of UAS PICs involved in the aerial filming;

f. A statement that the operator has obtained permission from property owners 

and/or local officials to conduct the filming production event; the list of those 

who gave permission must be made available to the inspector upon request;

g. Signature of exemption holder or representative; and

h. A description of the flight activity, including maps or diagrams of any area, city, 

town, county, and/or state over which filming will be conducted and the altitudes 

essential to accomplish the operation.

31. Flight operations may be conducted closer than 500 feet from participating persons 

consenting to be involved and necessary for the filming production, as specified in the 

exemption holder’s MPTOM.

Unless otherwise specified in this grant of exemption, the UAS, the UAS PIC, and the UAS 

operations must comply with all applicable parts of 14 CFR including, but not limited to, 

parts 45, 47, 61, and 91.
8

This exemption terminates on September 30, 2017, unless sooner superseded or rescinded.

Sincerely,

/s/

John S. Duncan

Director, Flight Standards Service

Enclosures
Limitless	Drones,	LLC

3208	E.Colonial	Drive,	Ste	108

Orlando,	FL.	32803

info@limitlessdrones.com

U.S. Department of Transportation 

Docket Management System

1200 New Jersey Ave., SE 

Washington, DC 20590 

Re:Exemption Request Pursuant To Section 333 of the FAA Reform Act of 2012 

To Whom It May Concern: 

Limitless Drones, LLC, is a Florida Limited Liability Company doing business as Limitless Drones. 

We are writing pursuant to the FAA Modernization and Reform Act of 2012 (the Reform Act) and 

the procedures contained in 14 C.F.R. 11, to request that Limitless Drones, an owner and 

operator of small unmanned aircraft, be exempted from the Federal Aviation Regulations (FARs) 

listed below so that Limitless Drones may operate its small unmanned aircraft systems (UAS) 

commercially in airspace regulated by the Federal Aviation Administration (FAA). 

Limitless Drones operates UASs under 55 pounds, all of which are manufactured by DJI a leader 

in the UAS industry. The proposed aircraft models are the S1000 with A2 flight controller, S900

with A2 flight controller, Phantom-2, and Inspire-1. All of these UASs have programmable return 

to home functions as well as programmable limitations for distance and altitude. All aircraft are 

GPS enabled with safety features such as altitude hold, return to home functions and in the case 

of the S1000 and S900, can operate with a malfunctioning motor.

Limitless Drones utilizes the DJI manufactured UASs primarily for the marketing of Real Estate, 

though they may be used for other cinematography uses such as television, water sports, 

agriculture, surveys, and by first responders. Limitless Drones only uses the most advanced

UASs available, as safety is our number one concern.

Limitless Drones operation of small UASs has in the past proven key in providing imagery and 

video to foreign developers and investors, streamlining the production of new homes and resort 

developments in the Orlando area. Our services give a broader picture to investors who cannot 

readily travel to the area in order to inspect current build projects, allowing them to make key

decisions from anywhere in the world. These operations benefit the public by bringing revenue

and jobs into the local economy without delays on the investors and builders part. Limitless 

Drones UASs are also highly cost-effective when compared to helicopter operations. We have 

also proved instrumental in the sale and marketing of such properties once construction is 

completed.

Limitless Drones, LLC is owned and operated by Justin Rivera. Justin has 10 years of military 

aviation experience, holds a current class 2 medical certificate as well as a Private Pilot 

certificate. Justin is a graduate of Embry-Riddle Aeronautical University and has worked side by 

side with tier 1 military units piloting Scan Eagle UASs overseas gaining over 1700 flight hours in 

the field. Justin has experience coordinating airspace in real time with manned aircraft in some of 

the busiest military airfields such as in Bagram Air Base Afghanistan. Justin also has experience 

as an instructor for UASs as well as a maintenance chief while supporting military operations. 

With Justin’s experience, Limitless Drones continues to have a safe and immaculate track record. 
Limitless	Drones,	LLC

3208	E.Colonial	Drive,	Ste	108

Orlando,	FL.	32803

info@limitlessdrones.com

Limitless Drones continues to look for ways to improve UAS safety through crew resource 

management training, situational awareness training, and analyzing human factors with regards 

to UAS operations.

Limitless Drones exemption request would permit its operation of lightweight, unmanned (piloted 

by remote control) and comparatively inexpensive UASs in tightly controlled and limited airspace 

under 400 feet. Predetermined, specifically marked areas of operation, cordoned off locations and 

corresponding enhancements to current safety controls will allow Limitless Drones to operate 

within current safety parameters while innovating new ones. Currently, amateurs with no flight 

experience, safety plan or controls in place to prevent catastrophe legally operate similar 

lightweight, remote controlled UASs. It is only logical to allow Limitless Drones highly experienced 

remote control pilots, technicians and safety crew to operate similar lightweight UASs. This will 

act to further safety protocols specific to lightweight UASs as Limitless Drones researches flight 

data and other information gained through permitted flight operations. 

Granting Limitless Drones request comports with the Secretary of Transportations (FAA 

Administrators) responsibilities to not only integrate UASs into the national airspace system, but 

to establish requirements for the safe operation of such aircraft systems [UASs] in the national 

airspace system under Section 333(c) of the Reform Act. Further, Limitless Drones will conduct 

its operations in compliance with the protocols described herein or as otherwise established by 

the FAA. 

For the reasons stated in our attached petition, Limitless Drones respectfully requests the grant of 

an exemption allowing it to operate lightweight, remote controlled UASs within the national 

airspace. 

The following links provide details on the specific UASs that limitless Drones plans to operate

including specs. Limitless Drones abides by all manufacturers guidelines which are also located 

at the following links:

S1000: http://www.dji.com/product/spreading-wings-s1000

S900: http://www.dji.com/product/spreading-wings-s900

Phantom 2: http://www.dji.com/product/phantom-2

Inspire-1: http://www.dji.com/product/inspire-1

If you require any additional information please do not hesitate to contact us at: 

Info@limitlessdrones.com

Respectfully,

Justin Rivera, Owner

Limitless Drones, LLC

Justin@limitlessdrones.com

(407) 278-9200
3208 E. Colonial DR. STE 108

Orlando, FL 32803

June 4, 2015

US 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 Part 21 Subpart H,

14 CFR 61.113(a) and (b), 14 CFR 91.103, 14 CFR 91.109, 14 CFR 91.119, 14 CFR 91.121,

14 CFR 91.151, 14 CFR 91.405, 14 CFR 407, 14 CFR 409, 14 CFR 417

To Whom It May Concern: 

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

“Reform Act”) and 14 C.F.R. Part 11, Limitless Drones, LLC, an operator of 

Unmanned Aircraft Systems (“UASs”) for aerial photography and video for the real estate, 

motion picture and television industry, hereby applies for an exemption from the Federal 

Aviation Regulations (“FARs”) to allow commercial operation of its UASs. 

Limitless Drones, LLC’s requested exemption would permit the operation of small, 

unmanned UAS under 55 pounds to conduct aerial video and photography under the

Operational Control of an individual holding at least a Private Pilot certificate; under direct 

control of a Pilot in Command (PIC); within Visual Line of Sight (VLOS); while utilizing a 

second person for the purpose of a Safety Observer. As established by the exemptions 

already granted by the FAA, approval of Limitless Drones exemption would 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.” Section 333(c) of the Reform Act.
The name and address of the applicant is: 

Limitless Drones, LLC 

Attn: Justin Rivera 

PH: 407-278-9200

Email: Justin@LimitlessDrones.com

Address: 3208 E. Colonial DR STE 108 Orlando, FL. 32803

Regulations from which the exemption is requested:

14 CFR Part 21 Subpart H, 14 CFR 61.113(a) and (b),

14 CFR 91.103, 14 CFR 91.109, 14 CFR 91.119, 14 CFR 91.121,

14 CFR 91.151, 14 CFR 91.405, 14 CFR 407, 14 CFR 409, 14 CFR 417

UASs operated by Limitless Drones, LLC weigh less than 55 pounds, including 

the payload (i.e. camera, lens, and gimbal). They operate at speeds of no more 

than 50 knots, can hover, and can simultaneously move vertically and 

horizontally. Limitless Drones, LLC will only operate its UASs in line of sight 

below 400 feet AGL and will operate under the operational control of (at 

minimum) an FAA certified private pilot while maintaining a safety observer. 

Such operations will insure that the UAS will “not create a hazard to users of 

the national airspace system or the public.” 

Given the small size of Limitless Drones, LLC’s UASs and the safety 

considerations proposed in this petition, Limitless Drones, LLC’s UAS 

operations adhere to the Reform Act’s safety requirements. Additionally, due to 

the size of the UASs and the proposed use in which they will operate, approval 

of this application presents no national security issues. Based on the level of 

safety surrounding the proposed operations, and the significant public benefit:

Marketing and development of real estate, public awareness, reduction in 

environmental impacts by reduced emissions and noise, as well as an increase 

in revenue to the local economy through real estate development. The grant of 

the requested exemption is in the public interest. Accordingly, Limitless Drones, 

LLC respectfully requests that the FAA grant the requested exemption. 
Aircraft And Equivalent Level Of Safety 

The operating limitations proposed by Limitless Drones provide for at least an 

equivalent or higher level of safety because operations further enhance safety of real 

estate, movie, and television filming using conventional aircraft. 

Limitless Drones Proposed limitations and conditions include: 

• The UASs will weigh less than 55 pounds. 

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

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

be terminated at 25% battery power reserve should that occur prior to the 30 

minute limit.

• Flights will be operated at an altitude of no more than 400 feet AGL, and not

more than 200 feet above an elevated platform from which filming is planned.

• Minimum crew for each operation will consist of the UAS Pilot, and a visual 

observer.

• An FAA licensed airman with at least a private pilot’s certificate and third class 

medical will oversee all flight operations to ensure the highest degree of safety.

• All UAS Pilots will undergo in-house training before operating any UAS for 

commercial use. This will include situational awareness training, airspace

education, and proper operation of the proposed UAS. 

• The UAS will be operated within a confined area pre programmed 

into the software, avoiding inadvertent fly-away or flight beyond set parameters.

• A briefing will be conducted for planned UAS operations prior to each day’s

flight. All personnel involved in the operations are required to attend.

• The operator will obtain consent of all persons involved in the filming and

ensure that only consenting persons will be allowed within 50 feet of the

flight operation. 

• The operator will submit a written Plan of Activities to the FSDO three days

• All required permissions and permits will be obtained from territorial, state, 

county, or city jurisdictions, including local law enforcement, fire, or other 

appropriate governmental agencies.

• If the UAS loses communications or loses its GPS signal, the UAS will have

the capability to return to a pre-determined location and land. The location will be 

clear of all persons or property during the duration of the flight.

• The UAS will have the capability to abort a flight in case of unpredicted obstacles or
emergencies.

• The UASs will operate on the following frequencies, which are all FCC compliant

and do not require specific licenses when transmit power is limited to 1 watt:

902 to 928 MHz, 2.400 to 2.4835 GHz, and 5.725 to 5.875 GHz.

• The UASs will not operate in the proximity of airports.

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

Given the size and limited operating area associated with the UASs to be utilized 

by Limitless Drones, this 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 the UASs 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 UASs. In all cases, an analysis of 

these criteria demonstrates that a UAS operated without an airworthiness 

certificate, in a 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.

14 C.F.R. § 61.113(a) and (b): Private Pilot Privileges and Limitation: 

Pilot in Command Sections 61.113 (a) and (b) limit private pilots to noncommercial operations. Because the UAS will not carry a pilot or passengers, the 

proposed operations can achieve an equivalent level of safety of current operations

by requiring all operations to be supervised by (at minimum) an individual holding 

private pilot’s license rather than requiring that individual to hold a commercial pilot’s 

license to operate a small UAS. Unlike conventional manned aircraft, a 

ground-based operator remotely controls a UAS. The operational area is limited, 

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 UAS are far lower

from those associated with commercial operations contemplated by Part 61. 

Allowing operational control of a UAS by a private pilot exceeds the present level of 

safety sought by 14 C.F.R. §61.113 (a) and (b). 

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 rotorcraft 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, airspace, NOTAMS, 

TFRs flight battery requirements, landing and takeoff distances, and performance 

data before commencement of flight. Additionally all UAS will be checked for 

security of attached components prior to every flight.
14 C.F.R. § 91.109: Flight Instruction

Section 91.109 states, “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.” The proposed UASs will be operated utilizing an autopilot 

to maintain controlled flight, and all UASs are programmed to return to a level 

attitude and hover when the controls are returned to a neutral position. Because of 

these built in safety features, dual control is not necessary in order to maintain an 

equivalent level of safety proposed by section 91.109 during training. All training will 

be conducted in a controlled environment as to not cause undue harm or damage to 

persons or property. 

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

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

91.119 provides, in pertinent part, that: “except when necessary for takeoff or 

landing, no person may operate an aircraft below the following altitudes... 

(c) Over other than congested areas. An altitude of 500 feet above the surface, 

except over open water or sparsely populated areas. In those cases, the aircraft 

may not be operated closer than 500 feet to any person, vessel, vehicle, or 

structure.” 

Because Limitless Drones, LLC requests authority to operate at altitudes only up to 

400 AGL, and not more than 200 above an elevated platform from which filming 

is planned, an exemption is needed to allow such operations. 

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

of the UAS as well as the location where it is operated. All affected individuals will 

be informed of the planned flight operations. Compared to flight operations for

manned aircraft and the lack of flammable fuel, any risk associated with the 

proposed UAS operations is far less than conventional aircraft operating at or below 

500 AGL. In addition, the low-altitude operations of the UAS will ensure separation 

between a UAS and conventional aircraft. 

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 UAS 

may not have a barometric altimeter, but instead reference a GPS altitude, an 

exemption is needed. The operator will achieve an equivalent level of safety,

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

flight. 

14 C.F.R. §91.151: Fuel Requirements for Flight in VFR Condition
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. . . .” The battery powering the proposed UASs provides approximately 

30 minutes of powered flight. Therefore the UAS cannot meet the 30-minute 

reserve requirement in 14 CFR §91.151. In lieu of this requirement the UAS 

flights will be terminated at approximately 25% remaining battery life or better. 

Limitless Drones, LLC believes that an equivalent level of safety can be 

achieved by limiting flights to 25% of battery power, this restriction would be

more than adequate to return the UAS to its pre-determined landing zone from

anywhere in its limited operating range. 

Limitless Drones, LLC is not seeking an exemption for night-time UAS 

operations.

14 C.F.R. §91.405: 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 sections and Part 43 apply only to aircraft with an airworthiness 

certificate, these sections will not apply to Limitless Drones operations. 

Maintenance will be accomplished by the operator in accordance with the 

manufacturers recommended procedures (attached). An equivalent level of safety 

will be achieved because the UASs are limited in size, will carry a small payload and 

operate only for limited periods of time. A preflight inspection will be performed prior 

to every flight to ensure no mechanical issues are present. If mechanical issues 

arise, the UAS can land immediately and will be operating from no higher than 

400 feet AGL. The operator will ensure that the UAS is in working order prior to 

flight, and perform any required maintenance. Moreover, the operator is the person 

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

14 C.F.R. §91.407: Operation after Maintenance

Functional check flights will be conducted away from people or property after any 

maintenance has been accomplished on the UAS. The UAS may be returned to 

service once it has been determined safe for flight.

14 C.F.R. §91.409: Inspections

Due to the small size of the UASs that will be operated by Limitless Drones, LLC 

and limited components, we request that the UASs be exempt from regularly 
scheduled inspections. To meet an equivalent level of safety sought by 14CFR 

91.409, all UASs will be thoroughly inspected prior to flight. Since the UASs will 

have limited components, a thorough inspection can be accomplished before each 

flight, eliminating the need for periodic, time based, or flight-hour based inspection 

cycles.

14 C.F.R. §91.417: Maintenance Records

As previously described, the UASs proposed size and use significantly limits the 

amount of maintenance required. The UASs that will be operated by Limitless 

Drones, LLC are designed by the manufacturer for the average hobbyist to 

purchase and fly with minimal assembly, regular preventative maintenance is limited 

to security of attached components and proper storage of, and charging of batteries.

As such, Limitless Drones, LLC requests an exemption from maintaining 

maintenance records as prescribed by 14CFR 91.417. However, in order to operate 

as safely as possible, Limitless Drones, LLC will keep a running log of all 

maintenance performed on each UAS, and any anomalies noted during operation in 

order to diagnose and prevent problems with the UAS. 

Summary for Publication 

Pursuant to 14 C.F.R. Part 11, the following summary is provided for publication

in the Federal Register, should it be determined that publication is needed: 

Limitless Drones, LLC seeks an exemption from the following rules: 

14 CFR Part 21 Subpart H, 14 CFR 61.113(a) and (b), 14 CFR 91.103,

14 CFR 91.109, 14 CFR 91.119, 14 CFR 91.121,14 CFR 91.151, 14 CFR 91.405,

14 CFR 407, 14 CFR 409, 14 CFR 417 to operate commercially small unmanned

vehicles (55 pounds or less) for aerial photography and video for the real estate, 

motion picture, and television industry.

As established by the UAS exemptions already granted by the FAA, allowing 

commercial operations of UASs in the real estate and film industry will enhance 

safety by reducing risk. Conventional film operations, using turbine aircraft, operate 

at low altitudes and present the risks associated with aircraft that weigh thousands of 

pounds, and carry large amounts of fuel. Such aircraft must also fly to and from the film

location. In contrast, a UAS weighing fewer than 55 pounds and powered by batteries 

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

UAS is carried, and not flown, to a film location. In this regard, the UAS carries no 

passengers or crew, therefore will not expose anyone to the risks associated with 

manned flights. The operation of UASs conducted in accordance with this request will 

provide an equivalent level of safety supporting the grant of the exemption requested 

herein. The UASs operate at slow speeds, close to the ground, and within a limited 

range. As a result, they are far safer than conventional operations conducted with 

turbine helicopters carrying fuel and flying near the ground and people. 

Satisfaction of the criteria provided in Section 333 of the Reform Act of 2012 

(size, weight, speed, operating capabilities, proximity to airports and populated 
areas and operation within visual line of sight and national security) provide more 

than adequate justification to grant Limitless Drones, LLCs requested exemption, 

allowing for Limitless Drones, LLC’s UAS commercial operations for the real estate, 

motion picture and television industry. 

Sincerely,

Justin Rivera, President/Owner 

Limitless Drones, LLC.