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Ready to Drone, LLC’s Petition for Exemption for the 

Event 38 E384 Unmanned Aerial System

FAA Rules Docket:

Submitted on 27July2015

Brenden Duffy

Ready to Drone, LLC

117 Rutland Ave

Rockville Centre, NY 11570

Phone: 646-456-0644

Email: brenden.duffy@readytodrone.com
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Table of Contents

1. CHARACTERISTICS OF THE AIRCRAFT......................................................5

2. APPLICATIONS.........................................................................................6

3. APPLICABLE LEGAL STANDARD UNDER SECTION 333.................................6

4. CONCLUSION............................................................................................9

Appendix

A. Event 38 Operating and Maintenance Manuals

B. Standard Practice for Unmanned Aircraft System (UAS) Visual Range Flight

 Operations - F2500 − 07

C. Standard Practice for Maintenance and Continued Airworthiness of Small

 Unmanned Aircraft Systems (sUAS) - F2909 − 14

D. Ready to Drone Training Course Outline
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July 9, 2015

U.S. Department of Transportation

Docket Management System

1200 New Jersey Ave., SE

Washington, DC 20590

Re: Request for Summary Grant of Exemption Under Section 333 of the FAA Reform Act and

Part 11 of the Federal Aviation Regulations

Dear Madam/Sir,

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

Act) and 14 C.F.R. Part 11, Ready to Drone LLC, developer and operator of Small Unmanned 

Aircraft Systems (“sUASs”) equipped to conduct aerial photogrammetry for the purpose of

geospatially accurate 3 dimensional reconstructions, hereby applies for an exemption from the 

listed Federal Aviation Regulations (“FARs”) to allow commercial operation of its sUASs, so 

long as such operations are conducted within and under the conditions outlined herein or as may 

be established by the FAA as required by Section 333.1 

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

small, unmanned and relatively inexpensive sUAS under controlled conditions in airspace that is 

1) limited 2) predetermined 3) controlled as to access and 4) would provide safety enhancements 

to the already safe operations in the Oil and Gas industry presently using conventional aircraft. 

Approval of this exemption would thereby 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: 

Ready To Drone, LLC

Attn: Brenden Duffy

Ph: (646) 456-0644

Email: brenden.duffy@readytodrone.com

Address: 17 Rutland Ave

Rockville Centre, NY 11570

Regulations from which the exemption is requested: 

14 CFR Part 21 

14 C.F.R. 45.23(b) 

14 CFR 61.113(a) & (b) 

14 C.F.R. 91.7 (a) 

14 CFR 91.9 (b) (2) 

14 C.F.R. 91.103 

14 C.F.R. 91.109 
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14 C.F. R. 91.119 

14 C.F.R. 91.121 

14 CFR 91.151 (a) 

14 CFR 91.203 (a) & (b) 

14 CFR 91.405 (a) 

14 CFR 407 (a) (1) 

14 CFR 409 (a) (2) 

14 CFR 417 (a) & (b) 

This exemption application is expressly submitted to fulfill Congress’ goal in passing 

Section 333(a) through (c) of the Reform Act. This law directs the Secretary of Transportation to 

consider whether certain unmanned aircraft systems may operate safely in the national airspace 

system (NAS) before completion of the rulemaking required under Section 332 of the Reform 

Act. In making this determination, the Secretary is required to determine which types of UASs do 

not create a hazard to users of the NAS or the public or pose a threat to national security in light 

of the following: 

• The UAS’s size, weight, speed, and operational capability; 

• Operation of the UAS in close proximity to airports and populated areas; and 

• Operation of the UAS within visual line of sight of the operator. 

Reform Act § 333 (a). Lastly, if the Secretary determines that such vehicles “may operate safely 

in the national airspace system, the Secretary shall establish requirements for the safe operation of 

such aircraft in the national airspace system.” Id. §333(c) (emphasis added)2. 

The Federal Aviation Act expressly grants the FAA the authority to issue exemptions. 

This statutory authority by its terms includes exempting civil aircraft, as the term is defined under 

§40101 of the Act, which includes sUASs, from the requirement that all civil aircraft must have a 

current airworthiness certificate. 

The requested exemption would authorize commercial operations using the Event 38

E384 for mapping and survey applications. These operations will be subject to strict operating 

requirements defined in the E384 user manual in order to ensure at least an equivalent level of 

safety to currently authorized operations using manned aircrafts.

The E384 will be operated by an individual who fulfill the following requirements:

 Has successfully passed a manufacturer’s training program for the E384; as well as pass 

flight requirements put forth by Ready to Drone.

 Has at a minimum, a Ground School Certification and a third/first class medical 

certificate.
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1. CHARACTERISTICS OF THE AIRCRAFT

The E384 is a small (37.8 inches wingspan) and ultra-light (maximum take-off weight of 

6.8 lbs, platform made of molded foam that performs pre-programmed precision aerial mapping 

missions thanks to the on-board GPS and the related flight management software (Ardupilot) that 

allows the operator to plan safely and efficiently a mission in 3D, and then monitor it in real-time.

Thanks to the embedded camera, the E384 takes a collection of high-definition still images/videos

that are used later to generate maps and contour lines of the surveyed area. The four main 

characteristics of the E384 are:

a. Very light weight

The E384 is so light that the operator can launch it by hand and let it land on almost any surface 

without requiring a parachute or landing net (belly land). Its low impact energy (38 J in case of a 

controlled emergency landing) also significantly reduces the risk of hazardous situations. Finally, 

the wings of the E384 are detachable and made of flexible foam with no sharp or hard edges and 

almost no internal strengthening structure.

b. Electric-powered

The E384 is electric powered. One brushless engine technology makes it silent and reliable. The 

propeller is attached with a lock tight nut to the base of the motor and is made of plastic so that it 

can easily break away in case of contact with any object.

c. Semi-automatic flight

The artificial intelligence incorporated within the Pixhawk autopilot system continuously 

analyzes data from the Inertial Measurement Unit (IMU) and from the onboard GPS and takes 

care of all the aspects of the flight under the supervision of the operator.
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d. Option for Manual control

Additionally, the E384 provides an override capability that allows the operator to take manual 

actions during the flight (Go to Home, Go Land, Hold and Resume the mission) and also suspend 

automated operations and take manual control of the aircraft should it become necessary to 

respond to emergency circumstances, thanks to the remote controller provided with the system.

2. APPLICATIONS

Ready To Drone LLC intends to use the E384 to conduct imaging flights for the purpose 

of precision mapping of public utilities, infrastructure, wild fire monitoring and

emergency public response. The aircraft will be used over controlled access property and 

only be used to image property for which we have been contracted by the landowner to do so. 

Images will be used to increase mining production, identify environmental land issues and allow 

for land use planning.

3. APPLICABLE LEGAL STANDARD UNDER SECTION 333

1. Operations authorized by this grant of exemption are limited to the following aircraft described 

in the operating documents which is a fixed-wing aircraft weighing approximately 6.8 pounds: 

E384. Proposed operations of any other aircraft will require a new petition or a petition to amend 

this grant.

2. The UAS may not be flown at an indicated airspeed exceeding 40 knots.

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

(AGL), as indicated by the procedures specified in the operating documents. All altitudes

reported to ATC must be in feet AGL.

4. The UAS 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.

5. All operations must utilize a visual observer (VO). 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. The PIC must be designated before the, 

the PIC must ensure that the VO can perform the functions prescribed in the operating 

documents. Ready to Drone intends to adopt ASTM F2500-07 Standard Practice for Unmanned 

Aircraft System (UAS) Visual Range Flight Operations (Attached as Appendix B) and ASTM 

F2909- 14 Standard Practice for Maintenance and Continued Airworthiness of small Unmanned 

Aircraft Systems (Attached as Appendix C)

6. The operating documents and this grant of exemption must be maintained 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 upon request. The operator must also present 

updated and revised documents if it petitions for extension or amendment to this grant of 
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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 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.

7. Prior to each flight the PIC will inspect the UAS to ensure it is in a condition for safe flight. 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 and proper documentation in the maintenance handbook 

is complete. The Ground Control Station must be included in the preflight inspection. 

8. Any UAS 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. The PIC who 

conducts the functional test flight must make an entry in the aircraft records.

9. The pre-flight inspection section in the operating documents must account for all discrepancies, 

i.e. inoperable components, items, or equipment, not already covered in the relevant sections of 

the operating documents.

10. The operator must follow the UAS aircraft/component, maintenance, overhaul, replacement, 

inspection, and life limit requirements.

11. The operator must carry out its maintenance, inspections, and record keeping requirements, in 

accordance with the operating documents. Maintenance, inspection, and alterations must be noted 

in the aircraft records, including total flight hours, description of work accomplished, and the 

signature of the PIC returning the UAS to service.

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

Safety Bulletins.

13. The PIC must make an entry in the aircraft record of the corrective action taken against 

discrepancies discovered between inspections.

14. A record of training must be documented and made available upon request by the 

Administrator. Flights for the purposes of training the operator’s PICs and VOs (training, 

proficiency, and experience-building), are permitted under the terms of this exemption. However, 

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

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). 

16. The UAS may not operate within 5 nautical miles of the airport reference point as denoted on 

a current FAA-published aeronautical chart.

17. The UAS 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, it must return to a pre-determined 

location within the planned operating area and land or be recovered in accordance with the 

operating documents.
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20. The PIC must abort the flight in the event of unpredicted obstacles or emergencies in 

accordance with the operating documents.

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

conditions) there is enough power to fly at normal cruising speed to the intended landing point 

and land the UAS with 30% battery power remaining.

23. The operator must obtain an Air Traffic Organization (ATO) issued Certificate of Waiver or 

Authorization (COA) prior to conducting any operations under this grant of exemption. This 

COA will also require the operator to request a Notice to Airman (NOTAM) not more than 72 

hours in advance, but not less than 48 hours prior to the operation.

24. Before conducting operations, the radio frequency spectrum used for operation and control of 

the UAS must comply with the Federal Communications Commission (FCC) or other appropriate 

government oversight agency requirements.

25. The 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.

26. The UAS must remain clear and yield the right of way to all other manned aviation operations 

and activities at all times.

29. The UAS may not be operated over congested or densely populated areas.

30. 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 

UAS 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

UAS, flight operations must cease immediately and/or;

b. The aircraft is operated near vessels, vehicles or structures where the land owner/controller has 

granted permission 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, and

c. Operations nearer to the PIC, VO, operator trainees or essential persons do not present an 

undue hazard to those persons per § 91.119(a).

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

from the land owner/controller or authorized representative. Permission from land 

owner/controller or authorized representative will be obtained for each flight to be conducted.

32. 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 reported to the National

Transportation Safety Board (NTSB) per instructions contained on the NTSB Web site: 

www.ntsb.gov. Unless otherwise specified in this grant of exemption, the UAS, the UAS PIC, 
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and the UAS operations must comply with all applicable parts of 14 CFR including, but not 

limited to, parts 45, 47, 61, and 91.

c. Operator Requirements

The Pilot-In-Command of the E384 will hold, at a minimum, a ground school Certificate and a 

third class medical certificate.

4. CONCLUSION

Ready to Drone LLC has a great deal of experience in UAS implementation, deployment, 

training and operations. The members that comprise the leadership team have over 15 years of 

collective sUAS operating experience worldwide. In 2015 alone, Ready to Drone has worked 

with many academic, non-governmental institutions, government agencies and private entities

around the world including but not limited to Princeton University, Rutgers University, 

Pennsylvania State University, CUNY Graduate Center, Brooklyn College, University of Prince 

Edward Island, University of Hawaii, Jane Goodall Institute, Conservation International, Canada 

Parks Enforcement, and Parks Canada. 

This request is designed to follow up on previous efforts by the Federal Aviation Administration 

to determine equivalent levels of safety for UAS operations. By requesting a summary grant of 

exemption we hope to achieve expedited approval for UAS operations to the public’s benefit.

Kind regards,

Brenden Duffy

CEO

Ready to Drone
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ANNEX A: EXEMPTION REQUEST AND EQUIVALENT LEVEL OF SAFETY

SHOWINGS UNDER APPLICABLE RULES SUBJECT TO EXEMPTION

Ready to Drone requests an exemption from the following regulations as well as any additional 

regulations that may technically apply to the operation of the E384 fixed-winged UAV:

14 CFR 61.133: Commercial pilot privileges and limitations. 

The regulation provides that no person that holds a private pilot certificate may act as 

pilot in command of an aircraft for compensation or hire. Subparagraph (b) allows a private pilot 

to act as pilot in command of an aircraft in connection with any business or employment if: (1) 

The flight is only incidental to that business or employment; and (2) The aircraft does not carry 

passengers or property for compensation or hire. To obtain a commercial pilot certificate a 

candidate must demonstrate a level of aeronautical knowledge and aircraft handling beyond what 

is required to operate a UAS. Our proposed operations would require that a Pilot-In-Command 

have the aeronautical knowledge and aircraft handling skills currently required to obtain a private 

pilot certificate. Given the lack of passengers or cargo on board the UAS, controlled access 

operations area we operate in and the simplicity of the UAS we believe that an equivalent level of 

safety can be achieved by requiring the pilot in command hold, at a minimum, a ground school 

certificate and a third/first class medical certificate.

14 CFR 91.7(a): Civil aircraft airworthiness

This regulation requires that no person may operate a civil aircraft unless it is in 

airworthy condition. Should the exemption be granted allowing commercial operation of the 

E384 UAV without an airworthiness certificate, no standard will exist for airworthiness of the 

E384. An equivalent level of safety will be achieved by insuring compliance with the E384

manuals prior to each flight.

14 CFR 91.119: Minimum Safe Altitudes

The regulation provides that over sparsely populated areas the aircraft cannot be operated 

closer than 500 feet to any person, vessel, vehicle, or structure. Since the aircraft will be operating 

at a maximum of 400 feet AGL, the E384 cannot comply with this requirement. The equivalent 

level of safety will be achieved because the E384 will only fly over private property with the 

permission of the landowner. The operator will define before every flight a working area radius 

and a flight area ceiling, preventing the E384 to go beyond the flight area. The landowner and the 

persons who may be on the ground in the flight area will be briefed of the expected route of flight 

and the associated risks to persons and property on the ground. Due to the small size of the E384

and the material with which the E384 is built of, the hazard to persons, vessels, vehicles, and 

structures is not comparable by far to manned aircraft and should be considered in granting the 

exemption. Moreover, the aircraft will not be operated over congested areas nor over any open-air 

assembly of persons. The aircraft will be operated at an altitude allowing, if a power unit fails, an

emergency landing without undue hazard to persons or property on the surface.

14 CFR 91.151(a): Fuel Requirements for Flight in VFR Conditions

The regulation provides that no person may begin a flight in an airplane under day-VFR 

conditions unless there is enough fuel to fly to the first point of intended landing and to fly after

that for at least 30 minutes. Given the area of operation for the E384, Ready to Drone believes 
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that an equivalent level of safety is already achieved with the specific procedure preventing the 

E384 to accept a takeoff order if the battery level is below a given value. Moreover, Event 38 has 

integrated “low” and “critical” battery level warnings and implemented a “return to Home” (and 

“Go Land”) actions in these situations to the ground station preventing any hazards of the craft to 

continue to fly. 

14 CFR Subpart E (91.401 - 91.417) - Maintenance, Preventive Maintenance, and

Alterations

The regulation provides that the operator is primarily responsible for maintaining the 

aircraft in an airworthy condition, including compliance with Parts 39 and 43. Paragraphs 91.407 

and 91.409 require that the aircraft be "approved for return to service by a person authorized 

under 43.7" after maintenance and inspection. Section 91.409(a)(2) requires an annual inspection 

for the issuance of an airworthiness certificate. Section 91.417(a) requires the owner or operator 

to keep records showing certain maintenance work that has been accomplished by certificated 

mechanics, under Part 43, or licensed pilots and records of approval of the aircraft for return to 

service. Ready to Drone proposes that the maintenance of the E384 will be accomplished by the

owner/operator according to the maintenance manual, provided by Event 38. An equivalent level 

of safety will be achieved because the E384 is small in size, it is not a complex mechanical 

device, it will carry no external payload, and it will operate only in restricted predetermined areas. 

Moreover, the operator is the person most familiar with the aircraft and is best suited to maintain 

the aircraft in an airworthy condition and to ensure an equivalent level of safety. Finally, before 

every flight, the E384 runs automatically a sequence of pre-flight tests to make sure that every 

sensor and every critical part is running properly. If a problem is detected, the E384 will not be 

able to be switched-on and a message error is displayed on the main screen of the flight 

management software. The operator can then refer to the maintenance manual to troubleshoot this 

issue. Several parts of the E384 are easily interchangeable (propellers, Legs antenna), which 

allows the operator to make sure the landing gear and propulsion system are always airworthy

when a mission is initiated.