November 16, 2015 

U. S. Department of Transportation 

Docket Operations, M-30 

1200 New Jersey Ave., SE 

Room W12-140 

West Building Ground Floor 

Washington DC 20590-0001 

Re: Exemption Request Section 333 of the FAA Reform Act and part 11 of the 

Federal Aviation Regulations from 14 CFR 21; 61.113 (a) & (b); 61.133 (a); 91.7 (a); 

91.9 (b); 91.109 (a); 91.119 (c); 91.121; 91.151 (a); 91.203; 91.405 (a); 91.407 (a) (1); 

91.409 (a) (2); 91.417 (a) & (b). 

Dear Sir or Madam, 

Pursuant to Section 333 of the FAA Modernization and Reform Act of2012 (the Reform 

Act) and14 C.F.R. Part 11 , Leading Edge Drone Imagery, LLC, operator of Small 

Unmanned Aircraft Systems (sUAS) equipped to conduct aerial filming and photographing 

to include: commercial and residential real estate, infrastructure inspections, construction, 

architecture, environmental assessment, land surveying and mapping and other applicable 

applications in pre-planned and controlled areas, hereby applies for an exemption from the 

listed Federal Aviation Regulations (F ARs) to allow commercial operation of its sUAS, so 

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

may be established by the Federal Aviation Administration (FAA) as required by Section 

333. 

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

small, unmanned and multi-rotor aircraft under controlled conditions in airspace that is 1) 

contained 2) predetermined 3) has on-site safety personnel controlling access, and 4) 

would provide increased safety and enhancements to clients' business operations. 

The name and address of the applicant is: 

Leading Edge Drone Imagery, LLC 

Michael J. Rempe 

143 Draper Dr., Statesville, NC 28625 

Phone: 864-991 -7857 

Email: mike.rempe@outlook.com 

Company Background and Planned Operations 

Leading Edge Drone Imagery, LLC is a North Carolina Company owned and operated by 

Michael J. Rempe. Mr. Rempe has been a FAA certified pilot since 1998 and has a current 

medical and flight review. He also has experience flying sUAS and is familiar with the 

operations and the maintenance of the hardware and software updates for these systems. 

The planned operations will involve collection of aerial imaging and sensor data to enable 

inspections and assessment of commercial and residential real estate, infrastructure 

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inspections, construction, architecture, environmental assessment, land surveying and 

mapping and other applications in pre-planned and controlled areas. 

Public Interest 

The use of a UAS reduces the environmental impact by decreasing energy usage for aerial 

imaging data collection. The UAS use rechargeable lithium batteries and electric motors, 

as opposed to flammable fuel consumed by a fixed-wing aircraft or helicopter. The UAS 

can replace the fixed wing aircraft or helicopter in most imaging, data collection or 

monitoring situations. The UAS we propose to fly weigh less than 20 lbs., carry no 

combustible fuel or crew members, reduces air and noise pollution and creates an increased 

safety factor for the public. And lastly, there will be applications in the construction 

industry that will eliminate the need of putting workers at risk of a fall. Since falls are the 

leading source of construction workplace fatalities, the use of a UAS for inspecting and site 

imaging could save workers lives. 

Equivalent Level of Safety 

Leading Edge Drone Imagery, LLC requested exemption would permit the operation of 

lightweight UAS (less than 55 lbs. total takeoff weight) by a FAA certified pilot under 

controlled conditions and would provide an equivalent or higher level of safety. The 

enhanced safety using a UAS in comparison to combustible fuel aircraft is self-evident and 

beneficial to the public's interest. All operations will be performed with the public's safety 

and right to privacy safeguarded at all times. 

VAS Devices 

Leading Edge Drone Imagery, LLC UAS are lithium battery powered, weighing less than 

55 lbs. including payload. The fleet includes the Yuneec Typhoon Q500 4K, DJI Phantom 

3 Advanced and DJI Spreading Wings S900. 

Specs 

OJI Phantom 3 Yuneec Typhoon OJI Spreading 

Advanced QS004K Wings 5900 

Type 4 electric motors 4 electric motors 6 electric motors 

Weight 2.82 lbs 3.75 lbs 181bs 

Flight Speed 18 mph J 15.s 35.8 mph J 31.1 

(max) 36 MPH I 31.3 knots knots knots 

Flight Time 23 min 25 min 18 min 

All UAS in the fleet operate at speeds less than 87 knots (100 mph) and have the capability 

to hover and move in vertical and horizontal planes simultaneously in a precise and 

controlled manner. Our intent is to use the UAS at much slower speeds for imaging and 

data collection applications. As the industry progresses, we would like to incorporate more 

advanced hardware and software into our operations. 

Statutory Authority for Exemptions 

Leading Edge Drone Imagery, LLC submits this application in accordance with the Reform 

Act, 112 P.L. 95 331-334, seeking relief from any currently applicable FAR's to prevent 

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Leading Edge Drone Imagery, LLC from future commercial use of small UAS to operate in 

the national airspace system as described below. The Reform Act section 332 provides for 

such integration of civil unmanned aircraft into our national airspace as it is in the public's 

interest to do so. Leading Edge Drone Imagery, LLC UAS fleet will meet the definition of 

'small unmanned aircraft" as defined in Section 331 and therefore the integration of these 

UAS are expressly contemplated by the Reform Act. Leading Edge Drone Imagery, LLC 

would like to operate its lightweight UAS prior to the time period by which the Reform Act 

requires the FAA to promulgate rules governing such aircraft. 

The Reform Act directs the Secretary of Transportation to consider whether certain 

unmanned systems may operate safely in national airspace before completion of the rule 

making required under Section 332 of the Reform Act. In making this determination, the 

Secretary of Transportation is required to determine which UAS do create a hazard to users 

of the national airspace system or the public or pose a threat to national security in light of 

the following: 

The UAS size, speed, weight, and operational capability 

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

Operation of the UAS within visual line of sight of the Pilot in Command (PIC) 

Reform Act 333(a) (1). 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." 

Leading Edge Drone Imagery, LLC utilizes UAS weighing less than 55 pounds that operate 

at speeds less than 87 knots (100 mph) and have the capability to hover and operate in the 

vertical and horizontal plane simultaneously in a precisely controlled manner. The UAS 

will only be operated within the visual line of sight of the PIC within a controlled flight 

area of 400 ft. above ground level (AGL) or less. Most operations are projected to be 

flown at heights much lower and will not present a hazard to the national airspace or the 

public. 

The small nature of these UAS combined with the Operations and Risk Management in a 

following section will allow for the safe operation greater than that envisioned by Congress 

for the FAA to establish and, by exemption, allowing commercial operations ofUAS. 

Also, due to the size of the UAS and the controlled areas and low altitudes in which they 

will operate, approval of this exemption presents no national security issues and minimal 

safety concerns which have been mitigated by our risk management process. Given the 

clear direction in Section 333 of the Reform Act, the authority contained in the Federal 

Aviation Act, as amended, the strong equivalent level of enhanced safety, reduced 

emissions and noise pollution, utilizing the UAS verses traditional aircraft benefits the 

greater public's interest. Leading Edge Drone Imagery, LLC request that the FAA grant 

the requested exemption without delay. 

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Regulations for Exemption Request 

Leading Edge Drone Imagery, LLC respectfully request the grant of an exemption to the 

following specific sections of the Title 14 code of Federal Regulations allowing it to 

operate lightweight UAS's for commercial use. 

Regulation Brief Description 

14 CFR21 , subpart H Air Worthiness Certificates 

14 CFR 45.23 (b) Identification and Registration 

Marking 

14 CFR 91.7 (a) Civil Aircraft Worthiness 

14 CFR91.9 (b) (2) Civil aircraft flight manual, 

marking, and placard requirements 

14 CFR 91. l 03 (b) Preflight action 

14 CFR91.109 Flight instruction; Simulated 

instrument flight and certain fli ght 

tests 

14 CFR 91.119 Minimum safe altitudes 

14 CFR 91. 12 I Altimeter settings 

14 CFR 91.15l (a) Fuel requirements for fl ight in VFR 

conditions 

14 CFR 91 .203(a) &(b) Civil Aircraft: Certifications 

required 

14 CFR 91.405(a) Maintenance required 

14 CFR 9 l.407(a)( I) Operation after maintenance, 

preventive maintenance, 

rebuilding, or alteration. 

14 CFR 91.409(a)&(b) Inspections 

Operations and Risk Management Conditions and Limitations 

The following are our proposed procedures and limitations for the flight operations of 

Leading Edge Drone Imagery, LLC. These proposed guidelines are open to modifications 

provided by the FAA in response to this request and future requirements issued by the 

FAA. 

1. Flights will only occur during the daytime hours. 

2. Flights will be operated in the visual line-of-sight (VLOS) of the operator (PIC) and 

the visual observer (VO) using human vision with no supplemental devices other 

than corrective lenses. 

3. Flights will be terminated at any time the weather and wind deteriorate to being 

"unsafe" for flight based on the manufacturer's recommendations and the PIC's 

experience. Operations will follow the anticipated guidelines of this exemption 

( operations under visual meteorological conditions - VMC, and standard visual 

flight rules - VFR). 

4. All documents, manuals, and maintenance logs associated with the UAS will be 

present on the site of operations. In addition, the credentials of the PIC (pilot 

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certificate, pilot logbook with current flight review and current medical) will be 

available on site. 

5. The UAS will be assessed for airworthiness by the PIC prior to each flight session 

using a checklist derived from the manufacturer's manual. All necessary 

calibrations and testing prior to the flight session will be performed. 

6. All UAS's in fleet will each weigh less than 55 lbs with speed capabilities well less 

than 87 knots. 

7. Flights will be operated at 400 feet AGL or less. 

8. Crew will be at a minimum of the operator (PIC) and a visual observer (VO). The 

PIC will be responsible for safety briefings, preflight inspections, ensuring the UAS 

is in condition for safe flight, flying the UAS and monitoring its status and flight 

dynamics while maintaining line of sight visualization and keeping the system 

operations within the specified factory limits (e.g. flight range, battery power, etc.). 

The VO will be involved in monitoring the airspace for other aircraft, the ground 

for unintended vehicles and bystanders, and will also look for additional hazards 

that could compromise safe operations. 

9. Operator (PIC) and crew, including the VO will remain in voice contact during the 

entire flight operation 

10. Prior to operations, weather forecast, weather radar, and air traffic patterns for the 

area will be reviewed. The proximity of the intended location with respect to 

airports and Temporary Flight Restrictions (TFR's) will be determined using 

Foreflight software on iPad or mobile devices. If operations are anticipated within 

5 nautical miles of airport reference points, the airport management or Air Traffic 

Control (A TC) tower will be notified prior to the operation, identifying the location, 

anticipated time and intent of flight operations. A portable hand held radio will also 

be available to monitor local air traffic and contact local tower if necessary. When 

in the vicinity of non-towered airports, we will monitor air traffic in the area and be 

able to inform them of our operations as needed. 

11. The UAS PIC will perform a final check of the flight area and make certain of the 

safety of all persons present and property in the controlled area prior to initiating 

flight operations. 

12. All UAS will have the capability to return automatically to the operator in a safe 

manner in the event of lost communications with the remote controller or a system 

problem. The auto return function will be checked and verified for proper operation 

on a regular basis. A starting OPS home position calibration will be performed 

prior to each new flight. 

13. The UAS will have indicators on the control and/or displays to inform the operator 

of the UAV's distance away from the operator, its altitude and velocity, and 

remaining battery power. 

14. Written and/or oral permission from the relevant property holders will be obtained 

when flights are conducted over private or controlled access property. 

Benefits to the public as a whole 

Approval of these 333 exemptions in general would allow commercial operations of small 

UAS to provide numerous services to our clients that would benefit from aerial imaging 

and data collection while greatly enhancing safety by reducing the overall risk associated 

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with traditional aircraft. With the use of small UAS of 55 lbs or less that are battery 

operated and flying below 400 feet AGL, the risk of injury of people on the ground or 

flight crew is greatly minimized in comparison. 

Leading Edge Drone Imagery, LLC respectfully request the FAA grant its exemption 

without delay. The FAA has the authority to issue the exemption sought by Leading Edge 

Drone Imagery, LLC pursuant to the Federal Aviation Act, 85 P.L. 726 (1958) as amended 

(the ACT). 

Please feel free to contact me if I can provide additional information and clatity to help 

expedite the process. 

Sincerely, 

v;:' /f:~'?YMichael J. Rempe 

Leading Edge Drone Imagery, LLC 

14 3 Draper Dr. 

Statesville, NC 28625 

Mike.rempe'a'outlook.com 

(M) 864-991 -7857 

Private Pilot Single Engine Land 

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