August 7, 2015

U.S. Department of Transportation 

Docket Management System 

1200 New Jersey Ave., SE 

Washington, DC 20590

Laurent Fady

965 Kemp Rd

Petoskey, MI 49770

Dear Madam or Sir,

ADERYS Northern Michigan Aerial Survey Systems is seeking exemptions under Section 333 from FAR title 14, 

parts 21, 36, 61 and 91.

Aderys has been created to offer aerial imagery to be used for real estate agents, land surveyors, precision farmers, 

law enforcement, search and rescue agencies, construction and industrial companies and any individual or entity 

requiring detailed aerial images. The sensors are carried by a DJI S1000 UAV, and will provide photographic, 

videographic, multispectral and thermal documentation.

I will be the pilot in command and currently hold a US private and commercial pilot certificate, single engine land, 

IFR rated (number 2463550), a glider pilot license issued in France (VV0205009590), an Ultralight pilot license 

issued in France (0205004994) and a private pilot license issued in France (TT0203001593) and have a total flight 

time of over 400 hours; I also hold a valid driver’s license issued in Michigan.

I seek exemption from the following 14CFR rules under Section 333 to be able to operate UAVs without undue 

burden and to offer valuable services to the Northern Michigan communities:

14CFR §21, 14CFR §91.7 (a) and 14CFR §91.203 relative to airworthiness of UAV: the FAA, in its “Notice of 

Proposed Rulemaking” (NPRM) relative to the operation of small unmanned aerial vehicles, does not impose an 

airworthiness certificate. The UAV operated by ADERYS will be inspected prior to each flight according to the 

procedures suggested by the manufacturer, following a pre-flight inspection checklist.

14CFR §36 relative to noise testing and certification as this UAV generates less noise than a car.

14CFR §61.23 (2) and (3) which states that “a person: 

2) Must hold at least a second class medical certificate when exercising:

(i) Second-in-command privileges of an airline transport pilot certificate in part 121 of this chapter (other than 

operations specified in paragraph (a)(1)(ii) of this section); or

(ii) Privileges of a commercial pilot certificate; or

(3) Must hold at least a third-class medical certificate—

(i) When exercising the privileges of a private pilot certificate” 

Since the FAA does not require a medical certificate in its NPRM relative to the operation of small unmanned aerial 

vehicles, this rule should not apply to the PIC of a DJI S1000 UAV.
14CFR §91.9: a UAV cannot comply with aircraft	flight	manual,	marking,	and	placard	requirements	due	to	its	

size.	However,	a	user	manual	will	always	be	available	before,	during	and	after	each	flight,	and	the	UAV’s	serial	

number	can	be	placated	on	its	frame.

14CFR §91.109 (a): “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.” A UAV does not have dual flight controls.

14CFR §91.119 (b) and (c) which states that: 

“Except when necessary for takeoff or landing, no person may operate an aircraft below the following altitudes: 

(b) Over congested areas. Over any congested area of a city, town, or settlement, or over any open air assembly of 

persons, an altitude of 1,000 feet above the highest obstacle within a horizontal radius of 2,000 feet of the aircraft. 

(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.” 

A UAV, being limited to a ceiling of 500 ft AGL, cannot be in compliance with this rule.

14CFR §91.121 relative to altimeter settings; this UAV does not operate with an altimeter but uses GPS altitude 

information. This will be set to zero before each flight.

14CFR §91.151 relative to fuel requirements during VFR flights which requires “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; or 

(2) At night, to fly after that for at least 45 minutes.”

The maximum flight time of our UAV is no longer than 20 minutes on a fully charged battery.

14CFR §91.405, §91.407, §91.409, §91.417 relative to maintenance and inspection, which have to be performed by 

authorized personnel and logged into the maintenance logbook kept in the airplane. There are no manufacturer 

recommended maintenance schedules other than preflight inspections and no certified mechanic for this type of

aircraft.

An exemption from these rules would not jeopardize public safety as it is my intention to follow strict procedures 

prior, during and after each flight to insure safe operation.

 Preflight inspection

 Consent of flight from client/landowner

 Visual Line of Sight flight rule maintained

 DJI S1000 weighs less than 55 lbs and has a maximum airspeed well below 100mph

 DJI S1000 does not carry flammable fuel

 Minimum flight VFR requirements observed

 Post flight inspection

ADERYS proposes to fly a DJI S1000 octocopter with the purpose of high definition aerial imagery and to offer its 

services to the Northern Michigan communities. The on-board sensors can be used for photography and 

videography, building and structure inspection, photogrammetry and mapping, assistance in search and rescue 

operations, and for forestry and crop management. This will apply to industries such as real-estate agents, building 

insulation inspections, land surveyors, construction, government agencies, emergency response teams, agriculture 

and land management.

Before each flight, an agreement will be signed to obtain authorization to fly over private/public property. 

A thorough pre-flight inspection will be performed, including and not limited to checking motors and propellers, 

center of gravity, all parts secured, communication with ground station confirmed, ATC authorization received if 

within class C or D, communication established and monitored for E airspace, take-off area cleared, and weather 

forecast checked. No flights will be conducted in class B airspace. Compass will be calibrated, and GPS 

communication confirmed with a minimum of 6 satellites.
Flights will be conducted during daylight, within visual line of sight range, in VFR weather conditions, no higher 

than 500 FT AGL, clear of clouds and with a 3 mile visibility. The maximum operating airspeed will be kept below

30 mph. Crowded areas will be avoided. In busy airspace, communication will be maintained with local ATC and 

traffic, and right of way yielded to other aircraft. A trained spotter will be used in case there are obstructions 

between the PIC and the intended flight path. The S1000 is equipped with a failsafe feature which automatically 

brings it back to its ground station in case of communication failure with the PIC or low battery level. Flights will be 

terminated when battery level reaches 30%.

The landing area will be cleared of obstacles and people. Alternate landing zones will have been identified in case of 

emergency landing. The UAV will be inspected for any damage, loose or missing parts. If an ATC authorization was 

received, ATC will be contacted to declare end of flight.

Here are the specifications of a DJI S1000 per the manufacturer’s website:

Frame

Diagonal Wheelbase: 1045mm

Frame Arm Length: 386mm

Frame Arm Weight 

(Including Motor, ESC, Propeller ): 325g

Center Frame Diameter: 337mm

Center Frame Weight (with Landing Gear Mounting Base, Servos): 1520g

Landing Gear Size: 460mm (Length)×511mm(Width)×305mm(Height)

Motor

Stator Size: 41×14mm

KV: 400rpm/V

Max Power: 500W

Weight (with Cooling Fan): 158g

ESC

Working Current: 40A

Working Voltage: 6S LiPo

Signal Frequency: 30Hz ~ 450 Hz

Drive PWM Frequency: 8 KHz

Weight (with Radiators): 35g

Flight Parameters

Takeoff Weight: 6.0Kg ~ 11.0Kg

Total Weight: 4.4Kg

Power Battery: LiPo (6S, 10000mAh~20000mAh, 15C (Min))

Max Power Consumption: 4000W

Hover Power Consumption: 1500W (@9.5Kg Takeoff Weight)

Hover Time: 15min (@15000mAh & 9.5Kg Takeoff Weight)

Working Environment Temperature: -10 °C ~ +40 °C

As demonstrated above, an exemption under Section 333 would not jeopardize public safety and would enhance 

Northern Michigan communities with never before offered aerial services.

Respectfully submitted,

Laurent Fady

Northern Michigan Aerial Survey Systems