FROM:	

Tim Dennesen

24 Marion Ave

Beverly, MA 01915

978-473-1771

tim@timdennesen.com

TO:	Federal	Aviation	Administration	US	Department	of	Transportation	Docket	Management	System	1200	New	Jersey	

Ave.	S.E	Washington,	DC	.	20590	

October 14,	2015	

Re:	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)	

Dear	Sir	or	Madam:	

Pursuant	to	Section	333	of	the	FAA	Modernization	and	Reform	Act	of	2012	(the	“Reform	Act”)	and	14	CFR	Part	11,	

Tim	Dennesen,	operator	of	an	Unmanned	Aircraft	System	(UAS),	hereby	applies	for	an	exemption	from	the	listed	

Federal	Aviation	Regulations	(“FARs”)	to	allow	commercial	operation	of	its	UAS,	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.	

Commercial	operation	of	an	UAS,	as	described	herein,	which	are	equipped	with	camera(s)	and	sensors,	would	operate	

in	the	following	manner:	

• Aerial	photography	and/or	video	for	public	and/or	private	use	including	real	estate,	architecture,	and	

other	related	professional	activities.	

• Aerial	video	and/or	photography	for	public	and/or	private	use	including	television,	public	events,	

cinematography	and	news	gathering.	

• The	ability	to	offer	training	to	persons	individually	or	belonging	to	both	private	and/or	public	

organizations	that	have	interests	in	the	use	and	application	of	a	UAS	for	the	purpose	of	the	safe	operation	

of	a	UAS	to	enhance	the	safety	of	the	National	Airspace	System	(NAS)	as	well	as	for	the	protection	of	the	

persons	and	property.	

As	described	fully	below,	the	requested	exemption	would	permit	the	operation	of	a	UAS	under	controlled	conditions	

in	the	NAS	that	would	be	a)	limited	b)	controlled	c)	predetermined	and	d)	will	provide	safety	enhancements	to	the	

already	safe	operations	in	the	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.”	

The	name	and	address	of	the	applicant	is:	

Tim	Dennesen Email:	tim@timdennesen.com Address:	24	Marion	Ave.	Beverly,	MA	01915

Regulations	from	which	the	exemption	is	requested:	

14	CFR	Part	21	subpart	H	14	CFR	45.23	(b)	14	CFR	61.113	(a)	&	(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)	&	(b)	14	CFR	91.405	(a)	14	CFR	91.407	(a)	(1)	14	CFR	91.409	(a)	(2)	14	CFR	91.417	

(a)	&	(b)	
Tim	Dennesen,	will	operate	the	DJI	Phantom	3	Professional,	with	a	total	weight	of	1280g	or	2lbs	13	oz.	The	

dimensions	are	40.36cm x	40.36cm	x	19.05cm	or	16inch	x	16inch	x	7.5inch.	Under	still	air	the	maximum	speed	is	no	

more	than	16m/s	or	35mph	with	a	cruising	speed	of	11m/s	or	25mph.	The	DJI	Phantom	3	Professional	has	four	

motors,	Motor	Model	DJI	3510,	powered	by	a	4480mAh	4s	LiPo	Lithium	Polymer	battery.	There	are	four	propellers,	

Propeller	Model	DJI	1345,	in	use.	The	DJI	Phantom	3	Professional	will	be	controlled	with	the	C3	remote	controller	

with	an	operating	frequency	of	2.400GHz	– 2.483GHz.	The	live	video	feed	will	have	an	operating	frequency	of	2.4GHz	

ISM	with	maximum	range	of	1.2	miles.	The	applicant	will	operate	the	UAS	in	line	of	sight	within	a	closed	off	and	

predetermined	area	owned	and/operated	by	the	property	representative.	

DJI Phantom 3 Professional GENERAL FEATURES 

• Ready	to	fly	

• 3-axis	camera	stabilization	

• Precision	flight	and	stable	hovering	

• GPS/GLONASS	positioning	&	auto	return	home	

• Onscreen	real-time	flight	parameters	

• High	Definition	4k	Camera	

• Camera	tilt	control	

•Film	straight	down	

• Supports	Adobe	DNG	RAW	

• Adobe	lens	profile	support	

• Camera	parameter	settings	

• Album	synchronization	

• FAA	no-fly	zones	locked	out	via	installed	software	TRANSMITTER 

• Operating	Frequency:2.400	GHz	– 2.483	GHz	

• Communication	Distance(open	area):	CE:	2000m;	FCC:	2000m	

• Receiver	Sensitivity(1%PER):-101dBm	+/- 2dBm	

• Transmitter	Power:	CE:	16dBm;	FCC:	20dBm	

• Working	Voltage:	1.2A	@	7.4V	

• Battery:	6000	mAh	LiPo	2s	CAMERA 

• HD	Recording:	4k	p	24/25fps	/	720p	60fps	DJI VISION APP 

• System	Requirement	of	Mobile	Device:	iOS	version	6.0	or	above/	Android	system	version	4.0	or	above	

• Mobile	Device	Support:	Recommended:	iPhone4s,	iPhone5,	iPhone5s,	iPod	Touch4,	iPod	Touch5;	
• Operating	Environment	Temperature: 0°C-40°C 

• Max	Resolution:	4096	x	2162p	@	24/25fps	

• FOV:	94°/	85°	

• Sensor	size:	1/2.3"	

Given	the	small	size	of	the	UAS	and	the	controlled	environment	provided	the	proposed	operations	will	adhere	to	the	

Reform	Act’s	safety	requirements.	The	approval	of	this	application	presents	no	national	security	issues.	Regarding	the	

level	of	safety	surrounding	the	proposed	operations	and	the	public	benefit,	reduction	in	environmental	impacts,	

including	but	not	limited	to	reduced	emissions	and	noise,	the	grant	of	the	requested	exemption	is	in	the	public	

interest.	Accordingly	the	applicant	requests	that	the	FAA	grant	the	requested	exemption	with	minimum	delay.	

AIRCRAFT AND EQUIVALENT LEVEL OF SAFETY 

The	operation	limitations	proposed	for	an	equivalent	or	higher	level	of	safety	because	operations	will	further	enhance	

the	safety	of	the	persons	and/or	property	using	conventional	aircraft.	

These	limitations	and	conditions	to	which	the	applicant	agrees	to	adhere	to	when	conducting	commercial	operations	

under	the	FAA	issued	exemption	as	set	forth	in	the	Flight	Operations	Manual	(FOM)	include:	

• The	UAS	will	weigh	less	than	55	lbs.	(DJI Phantom 3 Professional weighs 1280G or 2lbs 13oz) 

• The	UAS	will	have	a	maximum	operating	speed	of	no	more	than	35mph.	

• Flights	will	be	operated	within	line	of	sight	of	the	Pilot	in	Command	(PIC)	and/or	Visual	Observer	(VO).	

• Maximum	flight	time	for	each	operational	flight	will	be	20	minutes.	Flights	will	be	terminated	at	25%	

battery	power	reserve	or	20	minutes	of	flight	time	whichever	occurs	first.	

• Flights	will	be	operated	at	an	altitude	of	no more	than	400	feet	Above	Ground	Level	(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,	the	Visual	Observer	(VO)	and	may	include	

but	not	limited	to	a	Camera	Operator.	

• The	UAS	pilot	will	be	a	designated	Pilot	in	Command	(PIC)	and	will	take	and	pass	all	necessary	

certifications	currently	being	approved	by	the	FAA	administration	for	commercial	use.	

• A	briefing	will	be	performed	regarding	the	planned	UAS	operations	prior	to	each	day’s	flight	consisting	of	

all	the	days’	production	activities.	

• All	flights	will	occur	under	Visual	Flight	Rules	Meteorological	Conditions	(VMC)	only.	

• The	flights	will	occur	no	closer	than	a	5	mile	radius	of	the	geographic	center/Airport	Reference	Point	(ARP)	

of	a	tower	controlled	or	uncontrolled	airport.	The	DJI	Phantom	3	Professional	has	built	in	software	for	all	

FAA	regulated	‘No	Fly	Zones’	and	was	uploaded	by	DJI	(February	2015)	for	all	DJI	drones	to	download	and	

prevent	any	possible	flights	occurring	within	no-fly	zones.	DJI	Phantom	3	Professional	has	installed	software	

(code)	that	denies	flights	within	the	FAA	no-fly	zones.	

• If	operations	will	be	within	a	5	mile	radius	of	the	geographic	center/Airport	Reference	Point	(ARP)	of	a	

tower	controlled	or	uncontrolled	airport	the	respective	airports	will	be	contacted	advising	them	of the	

estimated	flight	time,	flight	duration,	elevation	of	flight	and	other	pertinent	information.	
• The	operator	will	file	FAA	Form	7711-1,	or	its	equivalent,	as	modified	in	light	of	the	requested	exemption,	

with	the	appropriate	local	Flight	Standards	District	Office	(FSDO)	no	more	than	72	hours	but	no	less	than	48	

hours	from	planned	operation.	

• The	operator	will	obtain	verbal/written	consent	of	all	persons	involved	with	the	planned	operation	and	

ensure	that	only	consenting	persons	will	be	allowed	within	100	feet	of	the	flight	operation,	and	the	radius	

may	be	reduced	to	30	feet	based	upon	an	equivalent	level	of	safety	determination,	as	required	under	the	

FOM.	With	the	advanced	permission	of	the	FSDO,	operations	at	closer	range	may	be	approved.	

• The	PIC	and	VO	will	have	been	trained	in	operation	of	UAS	and	receive	up-to-date	information	for	the	

particular	UAS	to	be	operated.	

• The	PIC	and	VO	will	be	able	to	communicate	by	voice,	radio,	and/or	text	at	all	times.	

• Written	and/or	verbal	permission	and	permits	will	be	obtained	from	territorial,	state,	county	or	

city	jurisdictions,	including	law	enforcement,	fire	or	other	appropriate	governmental	agencies.	

• If	the	UAS	loses	communications	with	the	remote	controller	or	loses	GPS	signal,	the	UAS	will	have	the	

capability	to	return	to	a	pre-determined	location	within	a	designated	location	and	land	autonomously.	

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

emergencies.	14 C.F.R. Part 21, Subpart H: Airworthiness Certificates 14 C.F.R. §91.203 (a) (1) Subpart	H,	

entitled	Airworthiness	Certificates,	establishes	the	procedural	requirements	for	the	issuance	of	

airworthiness	certificates	as	required	by	FAR	§91.203	(a)	(1).	Given	the	size	and	limited	operating	area	

associated	with	the	aircraft	to	be	utilized	by	the	Applicant,	an	exemption	from	Part	21	Subpart	H	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	

aircraft	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	UAS.	In	all	cases,	an	

analysis	of	these	criteria	demonstrates	that	the	UAS	operated	without	an	airworthiness	certificate,	in	the	

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.	The	UAS	to	be	operated	hereunder	is	less	than	55	lbs.	(3	lbs.)	fully	

loaded,	carries	neither	a	pilot	nor	passenger,	carries	no	explosive	materials	or	flammable	liquid	fuels,	and	

operates	exclusively	within	a	secured	and	designated	area.	Unlike	other	civil aircraft,	operations	under	this	

exemption	will	be	tightly	controlled	and	monitored	by	both	the	operator	and	under	the	requirements	and	in	

compliance	with	local	public	safety	requirements.	The	FAA	will	have	advance	notice	of	all	operations.	These	

safety	enhancements	provide	a	greater	degree	of	safety	to	the	public	and	property	owners	than	

conventional	operations	conducted	with	airworthiness	certificates	issued	under	14	C.F.R.	Part	21,	Subpart	

H.	Lastly,	application	of	these	same	criteria	demonstrates	that	there	is	no	credible	threat	to	national	

security	posed	by	the	UAS,	due	to	its	size,	speed	of	operation,	location	of	operation,	lack	of	explosive	

materials	or	flammable	liquid	fuels,	and	inability	to	carry	a	substantial	external	load.	

14 C.F.R. § 45.23 (b). Marking of the Aircraft 

The	regulation	requires:	When	marks	include	only	the	Roman	capital	letter	"N"	and	the	registration	number	is	

displayed	on	limited,	restricted	or	light-sport	category	aircraft	or	experimental	or	provisionally	certificated	aircraft,	

the	operator	must	also	display	on	that	aircraft	near	each	entrance	to	the	cabin,	cockpit,	or	pilot	station,	in	letters	not	

less	than	2	inches	nor	more	than	6	inches	high,	the	words	"limited,"	"restricted,"	"light-sport,"	"experimental,"	or	

"provisional," as	applicable.	

Even	though	the	UAS	will	have	no	airworthiness	certificate,	an	exemption	will	be	needed	as	the	UAS	will	have	no	

entrance	to	the	cabin,	cockpit	or	pilot	station	on	which	the	word	“Experimental”	can	be	placed.	

Given	the	size	of	the	UAS,	two-inch	lettering	will	be	impossible.	The	word	“Experimental”	will	be	placed	on	the	

fuselage	in	compliance	with	§45.29	(f).	
The	equivalent	level	of	safety	will	be	provided	by	having	the	UAS	marked	on	its	fuselage	as	required	by	§45.29	(f)	

where	the	pilot,	observer	and	others	working	with	the	UAS	will	see	the	identification	of	the	UAS	as	“Experimental.”	

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

Pursuant	to	14	CFR	61.113	(a)	&	(b),	no	person	who	holds	a	private	pilot	certificate	may	act	as	a	pilot	in	command	of	

an	aircraft	that	is	carrying	passengers	or	property	for	compensation	or	hire.	An	equivalent	level	of	safety	can	be	

achieved	by	current	Regulations	because	the	applicant’s	UAS	do	not	carry	any	pilots	or	passengers	nor	property.	The	

risks	attendant	to	the	operation	of	UAS	is	far	less	than	the	risk	levels	inherent	in	the	commercial	activities	outlined	in	

14	CFR	61.	The	operation	and	limitations	set	forth	in	the	FOM	will	equate	to	the	safe	operation	of	the	UAS.	

14 C.F.R. §91.7(a): Civil Aircraft Airworthiness. 

The	regulation	requires	that	no	person	may	operate	a	civil	aircraft	unless	it	is	in	airworthy	condition.	As	there	will	be	

no	airworthiness	certificate	issued	for	the	aircraft,	should	this	exemption	be granted,	no	FAA	regulatory	standard	will	

exist	for	determining	airworthiness.	

Given	the	size	of	the	aircraft	for	maintenance	and	use	of	safety	check	lists	prior	to	each	flight	an	equivalent	level	of	

safety	will	be	provided.	

14 C.F.R. § 91.9 (b) (2): Civil Aircraft Flight Manual in the Aircraft. 

Section	91.9	(b)	(2)	provides:	No	person	may	operate	a	U.S.-registered	civil	aircraft	...	(2)	For	which	an	Airplane	or	

Rotorcraft	Flight	Manual	is	not	required	by	§21.5	of	this	chapter,	unless	there	is	available	in	the	aircraft	a	current	

approved	airplane	or	Rotorcraft	Flight	Manual,	approved	manual	material,	markings,	and	placards,	or	any	

combination	thereof.	The	UAS,	given	its	size	and	configuration	has	no	ability	or	place	to	carry	such	a	flight	manual	on	

the	aircraft,	not	only	because	there	is	no	pilot	on	board,	but	because	there	is	no	room	or	capacity	to	carry	such	an	

item	on	the	aircraft.	The	equivalent	level	of	safety	will	be	maintained	by	keeping	the	flight	manual	at	the	ground	

control	point	where	the	pilot	flying	the	UAS	will	have	immediate	access	to	it.	

14 C.F.R. § 91.103: Preflight Action. 

This	regulation	requires	each	pilot	in	command	to	take	certain	actions	before	flight	to	insure	the	safety	of	flight.	As	

FAA	approved	rotorcraft	flight	manuals	will	not be	provided	for	the	aircraft	an	exemption	will	be	needed.	The	PIC	will	

take	all	actions	as	stated	in	the	manufacturer	FOM	in	the	pre-flight	inspection	section,	including	but	not	limited	to	

reviewing	weather,	flight	battery	requirements,	landing	and	takeoff	distances	and	aircraft	performance	data	before	

initiation	of	flight.	

14 C.F.R. §91.109: Flight Instruction. 

Section	91.103	provides	that	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.	UAS	and	remotely	piloted	aircraft,	by	their	

design	do	not	have	fully	functional	dual	controls.	Flight	control	is	accomplished	through	the	use	of	a	control	box	that	

communicates	with	the	aircraft	via	radio	communications.	The	FAA	has	approved	exemptions	for	flight	training	

without	fully	functional	dual	controls	for	a	number	of	aircraft	and	for	flight	instruction	in	experimental	aircraft.	The	

equivalent	level	of	safety	provided	by	the	fact	that	neither	a	pilot	nor	passengers	will	be	carried	in	the	aircraft	and	by	

the	size	and	speed	of	the	aircraft.	

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

Section	91.119	establishes	safe	altitudes	for	operation	of	civil	aircraft.	Section	91.119	(d)	allows	helicopters	to be	

operated	at	less	than	the	minimums	prescribed,	provided	the	person	operating	the	helicopter	complies	with	any	

route	or	altitudes	prescribed	for	helicopters	by	the	FAA.	As	this	exemption	is	for	a	UAS	that	is	a	helicopter	and	the	

exemption	requests	authority	to	operate	at	altitudes	up	to	400	AGL,	or	not	more	than	200	above	an	elevated	

platform	from	which	filming	is	planned,	an	exemption	may	be	needed	to	allow	such	operations.	As set	forth	herein,	

the	UAS	will	never	operate	at	higher	than	400	AGL	with	the	exception	that	in	circumstances	where	the	UAS	is	used	to	

survey	or	photograph	a	structure	whose	height	exceeds	400	feet	AGL,	the	UAS	will	not	be	operated	more	than	200	

feet	above the	highest	point	on	the	structure.	It	will	however	be	operated	in	a	restricted	area	with	security	perimeter,	
where	buildings	and	people	will	not	be	exposed	to	operations	without	their	pre-obtained	consent.	

The	equivalent	level	of	safety	will	be	achieved given	the	size,	weight,	speed	of	the	UAS	as	well	as	the	location	where	it	

is	operated.	No	flight	will	be	taken	without	the	permission	of	the	property	owner	or	local	officials.	Because	of	the	

advance	notice	to	the	property	owner	and	participants	in	the	filming	activity,	all	affected	individuals	will	be	aware	of	

the	planned	flight	operations.	Compared	to	flight	operations	with	aircraft	or	rotorcraft	weighting	far	more	than	the	

maximum	55lbs.	proposed	herein	and	the	lack	of	flammable	fuel,	any	risk	associated with	these	operations	is	far	less	

than	those	presently	presented	with	conventional	aircraft	operating	at	or	below	500	AGL.	In	addition,	the	low-altitude	

operations	of	the	UAS	will	ensure	separation	between	these	UAS	operations	and	the	operations	of	conventional	

aircraft	that	must	comply	with	Section	91.119.	

14 C.F.R. §91.121 Altimeter Settings. 

This	regulation	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	the	UAS	may	not	have	a	barometric	altimeter,	but	instead	a	GPS	altitude	read	out,	an	exemption	may	be	needed.	

An	equivalent	level	of	safety	will	be	achieved	by	the	operator, pursuant	to	the	safety	check	list	and	live	flight	data	

monitoring,	confirming	the	altitude	of	the	launch	site	shown	on	the	GPS	altitude	indicator	before	flight.	

14 C.F.R. § 91.151(a): Fuel Requirements for Flight in VFR Conditions 

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;	or	(2)	At	night,	to	fly	

after	that	for	at	least	45	minutes.”	

The	battery	powering	the	UAS	provides	approximately	25	minutes	of	powered	flight.	To	meet	the	30	minute	reserve	

requirement	in	14	CFR	§91.151,	UAS	flights	would	be	limited	to	approximately	10	minutes	in	length.	Given	the	

limitations	on	the	UAS’s	proposed	flight	area	and	the	location	of	its	proposed	operations	within	a	predetermined	

area,	a	longer	time	frame	for	flight	in	daylight	or	twilight	VFR	conditions	is	reasonable.	

Applicant	believes	that	an	exemption	from	14	CFR	§91.151(a)	falls	within	the	scope	of	prior	exemptions.	Operating	

the	UAS,	in	a	tightly	controlled	area	where	only	people	and	property	owners	or	official	representatives	who	have	

signed	waivers	will	be	allowed,	with	less	than	30	minutes	of	reserve	fuel,	does	not	engender	the	type	of	risks	that	

Section	91.151(a)	was	intended	to	alleviate	given	the	size	and	speed	of	the	small	UAS.	Additionally,	limiting	UAS	

flights	to	10	minutes	would	greatly	reduce	the	utility	for	which	the	exemption	will	be	granted.	Applicant	believes	that	

an	equivalent	level	of	safety	can	be	achieved	by	limiting	flights	to	20	minutes	or	25%	of	battery	power— whichever	

happens	first.	This	restriction	would	be	more	than	adequate	to	return	the	UAS	to	its	planned	landing	zone	from	

anywhere	in	its	limited	operating	area.	

14 C.F.R. §91.203 (a) and (b): Carrying Civil Aircraft Certification and Registration 

The	regulation	provides	in	pertinent	part: (a)	Except	as	provided	in	§	91.715,	no	person	may	operate	a	civil	aircraft	

unless	it	has	within	it	the	following:	(1)	An	appropriate	and	current	airworthiness	certificate.	.	.	.	(b)	No	person	may	

operate	a	civil	aircraft	unless	the	airworthiness	certificate	required	by	paragraph	(a)	of	this	section	or	a	special	flight	

authorization	issued	under	§91.715	is	displayed	at	the	cabin	or	cockpit	entrance	so	that	it	is	legible	to	passengers	or	

crew.	

The	UAS	fully	loaded	weighs	no	more	than	55	lbs.	and	is	operated without	an	onboard	pilot.	As	such,	there	is	no	

ability	or	place	to	carry	certification	and	registration	documents	or	to	display	them	on	the	UAS.	

An	equivalent	level	of	safety	will	be	achieved	by	keeping	these	documents	at	the	ground	control	point	where	the	pilot	

flying	the	UAS	will	have	immediate	access	to	them;	to	the	extent	they	are	applicable	to	the	UAS.	

14 C.F.R. §91.405 (a); 407 (a) (1); 409 (a) (2); 417(a) & (b): 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	section	and	Part	43	apply	only	to	aircraft	with	an	airworthiness	certificate,	these	sections	will	not	

apply	to	the	applicant.	Maintenance	will	be	accomplished	by	the	operator	pursuant	to	the	flight	manual	and	

operating	handbook.	An	equivalent	level	of	safety	will	be	achieved	because	the	UAS	is	very	limited	in	size	and	will	

carry	a	small	payload	and	operate	only	in	restricted	areas	for	a	limited	period	of	time.	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	initiating	flight,	perform	required	maintenance,	and	keep	a	log	of	any	maintenance	

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

aircraft	in	an	airworthy	condition	to	provide	the	equivalent	level	of	safety.	

An	equivalent	level	of	safety	will	be	achieved	because	maintenance	and	inspections	will	be	performed	in	accordance	

with	the	UAS	Manufacturer's	User	Manual.	As	provided	in	the	FOM,	the	operator	will	ensure	that	the	UAS	is	in	

working	order	prior	to	initiating	flight	and	perform	required	maintenance	needed.	

Additional Information

The	applicant,	Tim	Dennesen,	is	owner	of	Tim	Dennesen	LLC,	a	Boston	based	video	production	company,	and	has	an	

in-depth	understanding	of	the	capabilities	and	safety	concerns	involved	in	using	this	technology	as	an	asset	to	the	

community.	Satisfaction	of	criteria	provided	in	Section	333	of	the	Reform	Act	of	2012	provide	more	than	adequate	

justification	for	the	grant	of	the	requested	exemptions	allowing	the	commercial	operation	of	the	applicant’s	UAS.	

Sincerely,

Tim	Dennesen