August 6, 2015 

Craig Levine 

478 Trabert Avenue 

Atlanta, GA 30309 

Craig@GeorgiaDroneServices.com

Website: GeorgiaDroneServices.com 

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 61.113(a) and (b) 

14 CFR 91.7(a) 

14 CFR 91.9(b)(2) 

14 CFR 91.103 

14 CFR 91.109 

14 CFR 91.119(c) 

14 CFR 91.121 

14 CFR 91.151(a) 

14 CFR 91.203 (a) and (b) 

14 CFR 91.405 (a) 

14 CFR 91.407 (a) (1) 

14 CFR 91.409 (a)(1) and (2) 

14 CFR 91.417(a) and (b) 

Uses for UAS

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the “Reform Act”) and 14 

CFR Part 11, Craig Levine, operator of Georgia Drone Services, LLC, 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 Section 333. 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. 

Types of UAS to be used

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.” 

I plan to operate a UAS, the DJI PHANTOM 2 Vision Plus which is comprised of an unmanned aircraft (UA 

or Phantom 2 Vison Plus) and a transportable ground station. The Phantom 2 Vision Plus is referred to as 

a quad-copter with a maximum gross weight of about 3 pounds. It is equipped with four rotors that are 

driven by electric motors powered by batteries. The UA has a maximum airspeed of 16 m/s. 

I also plan to operate a UAS, the DJI PHANTOM 3 Professional which is comprised of an unmanned 

aircraft (UA or Phantom 3) and a transportable ground station. The Phantom 3 is referred to as a quadcopter with a maximum gross weight of about 3 pounds. It is equipped with four rotors that are driven 

by electric motors powered by batteries. The UA has a maximum airspeed of 16 m/s. 

Additionally, I plan to operate a UAS, the DJI Inspire 1 which is comprised of an unmanned aircraft (UA 

or Inspire 1) and a transportable ground station. The Inspire 1 is referred to as a quad-copter with a

maximum gross weight of about 6.5 pounds. It is equipped with four rotors that are driven by electric 

motors powered by batteries. The UA has a maximum airspeed of 22 m/s. 

Limitations and Conditions 

Also, given the small size of the UAS’s involved and the restricted controlled environment within which 

they will operate, the applicant fits within that zone of safety (an equivalent level of safety) in which 

Congress envisioned that the FAA must, by exemption, allow commercial operations of UASs to 

commence immediately. Also due to the size of the UASs and the controlled areas in which the relevant 

UASs will operate, approval of the application presents no national security issue. Given the following, 

the grant of the requested exemptions is clearly in the public interest: Craig Levine proposes that the 

exemption requested herein apply to civil aircraft that have the characteristics and that operate with the 

limitations listed herein. These limitations provide for an exceptional level of safety to operations. These 

limitations and conditions to which Craig Levine agrees to be bound when conducting commercial 

operations under an FAA issued exemption including:
1. The UAS will weigh less than 55 lbs. 

2. Flights will be operated within line of sight of operator. 

3. Maximum total flight time for each operational flight will be 30 minutes. 

4. Flights will be terminated at 15% battery power reserve. 

4. Flights will be operated at an altitude of no more than 400 feet AGL 

5. UAS operator will be trained and certified in the proper safety and operations of the UAS. 

6. The UAS will only operate within a controlled area as defined in the Procedures. 

7. The operator will post advisor notice around the controlled area. 

8. The operator will have been trained in operation of UAS generally and received up-to-date 

information on the particular UAS to be operated as required. 

9. If the UAS loses communications or loses its GPS signal, the UAS will have capability to return to a predetermined location within the Security Perimeter and land. 

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

The Reasons Why Granting Georgia Drone Services, LLC Request Would Be In The Public Interest; 

That Is, How It Would Benefit The Public As A Whole. Granting the present Petition will further the 

public interest by allowing Georgia Drone Services, LLC to safely, efficiently, and economically perform 

aerial video and photography of construction sites, real estate, events and civic landscape over certain 

areas of the United States. Additionally, use of the DJI UAS will decrease congestion of the NAS, reduce 

pollution, and provide significant benefits to the economy. Notably, the benefits of Georgia Drone 

Services’ proposed operation of the DJI UAS will be realized without implicating any privacy issues. 

1. The Public Will Benefit From Decreased Congestion Of The NAS. 

The DJI UAS are battery powered and serve as a safe, efficient, and economical alternative to the 

manned aircraft traditionally utilized to obtain aerial imagery. By reducing the amount of manned 

aircraft needed to perform aerial acquisitions, an exemption allowing the use of a DJI UAS would reduce 

the amount of manned aircraft in the NAS, reduce noise and air pollution, as well as increase the safety 

of life and property in the air and on the ground. Furthermore, by reducing the number of manned 

aircraft operating in the NAS, congestion around airports caused by arriving and departing aircraft will 

be reduced. The DJI UAS do not require an airport to takeoff or land. Likewise, a reduction of manned 

aircraft conducting aerial video and photography missions would result in fewer aircraft that must be 

handled by air traffic control during the ground, takeoff, departure, arrival, and landing phases of flight 

operations. 
2. The Public Will Benefit From The Safety And Efficiency Of The DJI UAS. 

Conducting aerial acquisitions with the DJI UAS, instead of manned aircraft, will greatly benefit the 

public by drastically reducing the levels of air and noise pollution generated during traditional aerial 

video and still photography flight operations. By using battery power and electric motors, the DJI UAS

produce no air pollution, and is the most viable environmentally conscious alternative to the cabin class, 

six cylinder internal combustion engine aircraft that are typically utilized for aerial video and 

photography, while burning approximately 20-30 gallons per hour of leaded aviation fuel. The DJI UAS, 

while reducing the carbon footprint of aerial acquisitions, also eliminates noise pollution, as the UAS are 

propelled by battery powered electric motors, rather than an internal combustion engine. By using the 

DJI UAS to perform aerial acquisitions, the substantial risk to life and property in the air and on the 

ground, which is usually associated with traditional manned aircraft flight operations, will be 

substantially reduced or completely eliminated. Aside from the lack of flight crew members located 

onboard the aircraft, the DJI UAS has less physical potential for collateral damage to life and property on 

the ground, and in the air, compared to the manned aircraft that typically conduct similar operations 

(weighing approximately 6,000 pounds with a wingspan of approximately 42 feet, a length of 34 feet, 

and a fuel capacity of 180 gallons). 

3. Performing Aerial Video and Photography Operations With The DJI UAS Will Benefit The Economy. 

In addition to being safe and efficient, the DJI UAS are also an economical alternative to using manned 

aircraft to conduct similar aerial operations. As such, operation of the DJI UAS will allow United States 

based companies, like Georgia Drone Services, LLC, to remain competitive and contribute to growth of 

the U.S. economy. Specifically, with the rising cost of aviation fuel and the Environmental Protection

Agency (“EPA”) regulatory actions phasing out leaded aviation fuels, U.S. owned and operated 

companies must adopt new and alternative technology in order to remain competitive. Operating the 

battery powered DJI UAS is one such technology that not only allows companies greater operational 

flexibility compared to manned aircraft, but provides such flexibility without the high operational cost of 

a traditional manned aircraft. By operating the DJI UAS, companies such as Georgia Drone Services, LLC, 

can remain competitive and profitable, and therefore, provide greater job stability to employees and 

contractors, which will ultimately contribute to growth of the U.S. economy. Improved financial 

performance of U.S. companies, through commercial use of the DJI UAS, provides a stable workforce 

that increases consumer spending; improves local, state, and federal tax revenues; and allows 

companies to invest in research and development in order to remain competitive both in the United 

States and abroad. 

4. There Are No Privacy Issues. 

Similar to the manned aerial acquisition flight operations that have been conducted for decades, 

Georgia Drone Services’ proposed operation of the DJI UAS will not implicate any privacy issues. 

Specifically, the DJI UAS will be operated only in compliance with property owner involvement as well as 

local law enforcement notification, as necessary, and in accordance with the Federal Aviation 

Regulations, including the minimum altitude requirements of 14 C.F.R. § 91.119. 
Accordingly, the applicant respectfully requests that the FAA grant the requested exemption and are 

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

safety. We look forward to working with your office. Please contact us at any time if additional 

information or clarifications are needed. 

Sincerely, 

Craig Levine 

Craig Levine 

Georgia Drone Services, LLC