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July 21, 2015 

VIA FED EX ONLY (TRACKING #8643 9813 6769} 

U.S. Department of Transportation 

Docket Management System 

1200 New Jersey Ave., SE 

Washington, DC 20590 

Re: Petition of Drone Universities, LLC for Exemption Pursuant to Section 333 of the FAA 

Modernization and Reform Act of 2012 

Dear Sir or Madam: 

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 ("FMRA") and 14 C.F.R. Part 

11, Drone Universities, LLC ("Drone U"L operator of Small Unmanned Aircraft Systems ("sUASs") 

equipped to conduct aerial videography, cinematography for pre-planned, controlled area, photographic 

and other aerial data collection services, hereby applies for an exemption from the below listed Federal 

Aviation Administration Regulations ("FARs") to allow commercial operation of its sUASs, so long as such 

operations are conducted within and under the conditions outlined herein, in accord with the enclosed 

Drone U Operations Manual ("Flight Operations Manual"), in compliance with the sUAS Operator's 

Handbook and all manufacturers' operations and/or instructions manuals ("Operator's Handbook")1

, 

and in strict compliance any and all rules, regulations, and practices as may be established by the 

Federal Aviation Administration ("FAA") for the operation of a sUAS. 

LEGAL AUTHORITY AND OVERVIEW '---------------------------- -------------~- -----·------------

1. Legal and Regulatory Framework 

The FMRA provides that "the Secretary of Transportation shall determine if certain unmanned aircraft 

systems may operate safely in the national airspace system ... " prior to final completion of the required 

Reform Act plan and the subsequent rule-making. § 333(a). 

In making this determination, the Secretary of Transportation shall determine, at a minimum1 

(1) Which types of unmanned aircraft systems, if any, as a result of their size, weight, speed, 

operational capability, proximity to airports and populated areas, and operation within 

visual line of sight do not create a hazard to users of the national airspace system or the 

public or pose a threat to national security; and 

The Flight Operations Manual and Operator's Handbook both contain confidential, trade secret and proprietary information that Drone U has 

not and will not share with others. Petitioner submits the Flight Operations Manual and Operator's Handbook and all information contained 

therein as proprietary and confidential information pursuant to 14 C.F.R. § 11.35(b). The Flight Operations Manual and Operator's Handbook 

contain operating conditions and procedures that are not available to the public and are protected from release under the Freedom of 

Information Act, 5 U.S.C. § 552 et seq. 

ALGATTORNEYS. PLLC 

(720) 5'38 4800 

(7:i'O) fh'38 11801 ALGATTORNEYS.COM 
(2) Whether a certificate of waiver, certificate of authorization, or airworthiness certification 

under section 44704 of title 49, United States Code, is required for the operation of 

unmanned aircraft systems identified under paragraph (1). 

§333(b) (1)-(2). Finally, §333 provides that "[i]f the Secretary determines under this section that certain 

unmanned aircraft systems may operate safely in the national airspace system, the Secretary shall 

establish requirements for the safe operation of such aircraft systems in the national airspace system." 

§333(c). 

The FAA has promulgated guidance for UAS users that wish to obtain a Section 333 exemption. The FAA 

has recommended that an applicant discuss the following items: 

1. The safe operation of a UAS to minimize risk to the National Airspace ("NAS"), including the 

operational characteristic for the type of UAS intended for use, operating procedures, and 

aircraft loading information; 

2. Operational procedures, including pre-flight inspections, maintenance, and repair; 

3. Radio Frequency ("RF") spectrum used for control of the UAS and associated equipment that is 

part of the UAS and whether it complies with Federal Communications Commission ("FCC") or 

other appropriate government oversight requirements; 

4. A description of the Pilot in Command ("PIC") directly responsible for the operation of the UAS, 

including the level of airman certificate held, any applicable training related to the operation, 

and any minimum hours of flight experience required by the PIC, both total flight time and the 

time with the particular UAS, as well as medical standards and certification of the PIC directly 

responsible for the operation of the UAS; 

5. The intended UAS operations, including how the operation would not adversely affect safety, or 

how they would provide a level of safety at least equivalent to that provided by the rule from 

which exemption is sought; 

6. The proposed maximum operating speed and altitude, and describe the minimum flight visibility 

and distance from clouds for their intended operations, including any potential hazards and 

safety mitigations associated with these proposed conditions; 

7. The characteristics of the area of intended operation and the associated potential hazards and 

proximity to populated areas; 

8. The proximity to airports; 

9. A description of how the application intends to operate the UAS within visual line-of-sight 

("VLOS"); 

10. Any procedures to conduct a preflight safety risk assessment to determine that the UAS is in a 

condition for safe flight and that the planned operation can be completed safely; 

11. To the extent the activity involves operations that have existing requirements, such as motion 

picture and television filming, or pipeline and power line control, how the application intends to 

comply with such regulations; and 

12. The applicant's intent to obtain a Certificate of Waiver of Authorization ("COA'') from the FAA 

Air Traffic Organization. 

Additionally, the FAA Administrator has general authority to grant exemptions from its safety 

regulations and minimum standards when the Administrator decides a requested exemption is in the 

public interest. See 49 U.S.C. § 44701(f) (permitting exemptions from §§ 44701(a), (b) and §§ 44702-

44716, et seq.). A party requesting an exemption must explain the reasons why the exemption: (1) 

would benefit the public as a whole, and (2) would not adversely affect safety (or how it would provide a 
level of safety at least equal to the existing rules}. See 14 C.F.R. § 11.81 (petitions for exemption}. 

2. Drone U Meets and Exceeds the Legal and Regulatory Requirements 

As will be shown herein, Drone U meets and exceeds the stated §333 requirements as well as the 

guidance promulgated by the FAA. The proposed operations in this petition for exemption qualify for 

expedited approval under §333 of the FMRA. Each of the statutory criteria and other relevant factors 

are satisfied. 

The proposed operations permit the use of small and relatively inexpensive UAS under controlled 

conditions in airspace that is: (1} limited; (2} predetermined; (3} controlled as to access; and that (4} 

provides an increased level of safety beyond that existing when fixed or rotor wing aircraft are used to 

accomplish the same purpose. 

Drone U's sUAS are rotorcraft, weighing 50 or fewer pounds, including payload. They operate, under 

normal conditions, at low speed and have the capability to hover and move in the vertical and horizontal 

plane. Drone U's UASs will operate in line of sight, or pursuant to the prevailing FAA regulations and 

guidance, and will only operate within those areas described in the enclosed Flight Operations Manual. 

Given the small size of the sUASs involved and the restricted environment within which they will 

operate, the comprehensive safety and operational parameters used by Drone U, and Drone U's 

commitment to compliance with the FAA's regulations now and into the future, this petition exemption 

falls within the equivalent level of safety that Congress desired the FAA to permit commercial UAS 

operations by exemption pending completion of formal rulemaking. Also, due to the size of the sUASs 

and the restricted area in which the sUASs will operate, approval of the application presents no national 

security issue. 

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

Aviation Act, as amended, the equivalent level of safety surrounding the proposed operations, and the 

significant public benefit, the grant of the requested exemptions is also in the public interest. 

Accordingly, Drone U respectfully requests the FAA grant the requested exemption without delay. 

! MEET DRONE U L__·--·--·--· -·----·- ------------------··- ---------·--·---·--------·-----·-

Drone Universities, LLC is a California limited liability company that operates Small Unmanned Aircraft 

Systems equipped to conduct aerial videography, cinematography, photography and other aerial data 

collection services. Drone U works with clients across many industries, including oil and gas companies, 

real estate, construction, and agriculture, to provide the client images, videos and data needed to 

support and grow their business. The Drone U team has extensive experience in both safely piloting 

sUASs and providing instructional training in the operations, planning, and maintenance of sUAS. 

Contact for Drone U: 

Drone Universities, LLC 

Sam Estrin 

10444 Cheviot Cut 

San Diego, CA 92126 

Sam.estrin@gmail.com 

(310} 613-0562 
PROPOSED OPERATIONS 

The enclosed Manuals describe, in detail, the policies and procedures for Drone U's proposed sUAS 

operations. To assist the FAA in its safety assessment of Drone U's proposed sUAS operations, below is a 

summary of operational limitations and conditions, which will ensure an equivalent or higher level of 

safety to operations conducted under current regulatory guidelines: 

1. The sUAS will weigh less than 50 pounds. 

2. Flights will be operated within line of sight of the Operator. 

3. Maximum total flight time for each operational flight will be limited to the amount of 

time the sUAS can be flown and still maintain a reserve battery power of no less than 

25%. 

4. Flights will be operated at an altitude of no more than 500 feet Above Ground Level 

("AGL"). 

5. Flights will be operated at a safe lateral and vertical distance from and above any 

inhabited structures, buildings, vehicles, vessels, or people not associated with the 

operation or who have not signed a waiver in advance of the operation. 

6. The sUAS Pilot with Pilot in Command responsibilities for the flight will be the 

designated Operator ("Operator"). 

7. The sUAS will operate only within a confined area as described in the Flight Operations 

Manual. 

8. A briefing will be conducted in regard to the planned sUAS operations prior to each 

day's missions. It will be mandatory that all personnel who will be performing duties 

within the boundaries ofthe safety perimeter be present for this briefing. 

9. The Operator will have been trained in operations of sUAS generally and received up-todate information on the particular sUAS to be operated as required in the Flight 

Operation Manual. 

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

11. All required permissions and permits will be obtained from territorial, state, county or 

city jurisdictions, including local law enforcement, fire or other appropriate 

governmental agencies. 

12. If the sUAS loses transmission signal, the sUAS will have the capability to return to a predetermined location and land. 

13. Contingency plans will be in place to safely terminate flight if there is a loss of 

transmitter communications or a loss of GPS signal. 

14. The sUAS will have the capability to abort a flight in case of unpredicted obstacles or 

emergencies. 

of 
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, 

including sUASs, from its safety regulations and minimum standards when the Administrator decides a 

requested exemption is in the public interest. 

Petitioner seeks an exemption from several interrelated provisions of 14 C.F.R. Parts 21, 45 and 91 for 

purposes of conducting aerial photography and videography, and other aerial data collection services. 

Listed below are (1) the specific sections of 14 C.F.R. for which exemption is sought, and (2) the 

operating procedures and safeguards that Petitioner has established which will ensure a level of safety 

better than or equal to the rules from which exemption is sought. 

A. 14 C.F.R. Part 21, Subpart H- Airworthiness Certificates and 14 C.F.R. § 91.203(a) and (b) 

Petitioner seeks an exemption from 14 C.F.R. Part 21, Subpart H, which establishes the procedural 

requirements for the issuance of airworthiness and registration certificates as required by 14 C.F.R. 

Given the size and limited operating area associated with the sUAS to be utilized by the Petitioner, an 

exemption from Part 21, Subpart H, meets the requirements of an equivalent level of safety under Part 

11 and §333 of the FMRA. 

The Federal Aviation Act and §333 of the FMRA 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 sUAS operated without airworthiness or registration certificate, 

in the restricted environment and under the conditions proposed, will be at least as safe as, or safer 

than, a conventional rotorcraft operating with an airworthiness certificate without restrictions and 

conditions of the proposed sUAS operations. 

Equivalent Level of Safety 

The sUAS to be operated hereunder, DJIInnovations Inspire 1 multi-rotor rotorcraft, weighs less than 55 

pounds with payload, carries neither a pilot nor passenger, carries no explosive materials or flammable 

liquid fuels, and operates exclusively within a secured and sterile area. Unlike other civil aircraft, the 

proposed operations will be controlled and monitored by the Operator pursuant to the Flight 

Operations Manual's requirements, as attached. 

These safety enhancements, which already apply to civil aircraft operated in connection with existing 

aerial videography operations, provide a greater degree of safety to Drone U's employees, members of 

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 sUAS, due to its size, speed of operation, 

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

B. 14 C.F.R. Part 27 Airworthiness Standards: Normal Category Rotorcraft 

14 C.F.R. Part 27 sets forth the procedural requirements for airworthiness certification of normal 

category rotorcraft. To the extent Drone U would otherwise require certification under Part 27, Drone U 

seeks an exemption from Part 27's airworthiness standards for the same reasons Identified in the 
exemption request from 14 C.F.R. Part 21, Subpart H. 

C. 14 CFR § 61.113: Private Pilot Privileges And Limitations 

Petitioner seeks an additional exemption from 14 CFR § 61.113, which restricts private pilot certificate 

holders from flying aircraft for compensation or hire, and which would also have the effect of requiring a 

second-class medical certificate. This provision limits private pilots to non-commercial operations. 

Equivalent Level of Safety 

Because the sUASs will not carry a pilot or passengers, the proposed operations can achieve the 

equivalent level of safety of current operations by requiring a ground crew member to have a private 

pilot's license rather than a commercials pilot's license to operation this sUAS. Unlike a conventional 

aircraft that carries the pilot and passengers, the sUAS is remotely controlled with no persons on board. 

The area of operation is controlled and restricted, and all flights are planned and coordinated in 

advance. The risks associated with the operation of the sUASs are so diminished from the level of risk 

associated with commercial operations contemplated by part 61 when drafted, that allowing operations 

as requested with a private pilot in the ground crew exceeds the present level of safety achieved by 14 

C.F.R. Sec. 61.113(a) and (b). 

In addition, in Grant of Exemption No. 11062 to Astraeus Aerial ("Astraeus"), the FAA determined that 

an Operator with a private pilot certificate operating the Astraeus UAS would not adversely affect 

operations in the NAS or present a hazard to persons or property on the ground. Additionally, as 

previously determined by the Secretary of Transportation, the requirement to have an airman certificate 

ameliorates security concerns over civil UAS operations conducted in accordance with §333. 

The aerial data collection conducted by Drone U will be conducted in areas where access to the public is 

limited and controlled. As such, the operations will have no substantial impact on any third persons not 

involved in the production. Drone U also has a policy to conduct its operations, when possible, during 

times when third persons not involved in the production are expected to be limited and to the extent 

possible, to provide notice to affected third persons when production and operations will occur. 

Because Drone U will operate in controlled areas and under controlled parameters, the sUAS will be 

flown based on visual line-of-sight at altitudes below 500' AGL. Accordingly, Drone U request that this 

exemption be granted. 

D. 14 C.F.R. §§ 91.9(c), 45.23(b) and 45.27(a): Aircraft Marking and Identification 

Requirements 

Petitioner seeks an exemption from the aircraft marking and identification requirements contained in 14 

C.F.R. §§ 91.9(c), 45.23(b) and 45.27(a). 14 C.F.R. § 91.9(c), Civil Aircraft Flight Manual, Marking and 

Placard requirements, provides that "[n]o person may operate a U.S.-registered civil aircraft unless that 

aircraft is identified in accordance with Part 45 of this chapter." 

Equivalent Level of Safety 

The equivalent level of safety for exemptions to the aircraft marking and identification requirements of 

§§ 91.9(c), 45.23(b) and 45.27(a) will be provided by having the sUAS marked on its fuselage as required 

by § 45.29(f). In addition, Drone U is aware of Exemption No. 11333, which required the sUAS's 

markings to be "as large as practicable." The FAA has previously issued the following related 
exemptions to the aircraft marking requirements of § 45.23(b): Exemption Nos. 10700, 10167 and 

10167A. 

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

Drone U seeks an exemption from the flight manual requirements of 14 C.F.R. § 91.9(b)(2), which states: 

(b) 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. 

Given the physical dimensions of the sUAS, configuration and load capacity, the sUASs have no ability to 

carry such a manual on the aircraft, not only because there is no pilot on board, but because there is 

simply no room or capacity to carry such an item on the aircraft. 

Equivalent Level of Safety 

The safety related purpose of this manual requirement can be equally satisfied by maintaining the sUAS 

flight manual at the ground control point where the Operator will have immediate access to it. 

Accordingly, Drone U requests an exemption from 91.9(b)(2)'s flight manual requirements, on the 

condition that the sUAS flight manual be available at the control point during each operation. 

The FAA has issued the following exemptions to this regulation: Exemption Nos. 8607, 8737, 8738, 9299, 

9299A, 9565, 9565B, 10167, 10167A, 10602, 32827, 10700, and 11333 ("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.") 

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

Drone U seeks an exemption from 14 C.F.R. § 91.7(a), which requires that a civil aircraft be in airworthy 

condition to be operated. Inasmuch there will be no airworthiness certificate issued for the sUAS, should 

this exemption be granted, no FAA regulatory standard will exist for determining airworthiness. 

Equivalent Level of Safety 

The DJI Innovations INSPIRE 1 has a stellar safety record, demonstrating that the sUAS is airworthy. 

Further, given the size of the sUAS and the requirements contained in the Flight Operation Manual for 

maintenance and pre-flight safety check lists, an equivalent level of safety will be provided. 

The FAA has issued the following exemptions to this regulation: Exemption Nos. 8607, 8737, 8738, 9299, 

9299A,9565,9565B, 10167, 10167A,10602,32827, 10700,and 11333. 

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

Drone U seeks an exemption from 14 C.F.R. § 91.103, which requires a PIC to become familiar with 

specific information before each flight, including information contained in the FAA-approved flight 

manual on board the aircraft. While the Operator will be familiar with all information necessary to safely 

conduct the flight, an exemption is requested to the extent that an FAA-approved flight manual is 
required on board the aircraft. 

Equivalent Level of Safety 

An equivalent level of safety will be provided by following the Operator's Handbook. The Operator will 

take all required preflight actions- including reviewing weather, flight battery requirements, landing and 

takeoff distance, and aircraft performance data - before initiation of flight. The Operator's Handbook 

will be kept at the ground station with the operator at all times. Further, Drone U will utilize all safety 

and manufacturer's manuals to ensure it adheres to the highest standards for safety within the industry. 

H. 14 C.F.R. § 91.109(a): Flight Instruction 

Drone U seeks an exemption from 14 C.F.R. § 91.109(a), which provides that "[n]o 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." sUASs and remotely piloted aircraft, by their design, do not have 

functional dual controls. Instead, flight control is accomplished through the use of a box that 

communicates with the aircraft via radio communications. 

Equivalent Level of Safety 

Given the size and speed of the sUAS, an equivalent level of safe training can still be performed without 

dual controls because no pilot or passengers are aboard the sUAS, and all persons will be a safe distance 

away in the event that the sUAS experiences any difficulties during flight instruction. 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. See, Exemption Nos. 

5778K & 9862A. The equivalent level of safety is 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. Enhancing this safety is the 

technology inherent in the remote controls utilizing digital communications that are paired to the sUAS, 

making it nearly impossible to unintentionally or intentionally have the control communications 

interrupted. 

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. Exemptions include: Nos. 5778K and 9862A. 

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

Petitioner requests an exemption from the minimum safe altitude requirements of 14 C.F.R. § 91.119. 

Section 91.119 prescribes the minimum safe altitudes under which aircraft may not operate, including 

500 feet above the surface and away from any person, vessel, vehicle, or structure in non-congested 

areas. See 14 C.F.R. § 91.119(c). Section 91.119(d) allows for a helicopter to operate at less than those 

minimum altitudes when it can be operated "without hazard to persons or property on the surface," 

provided that "each person operating the helicopter complies with any routes or altitudes specifically 

prescribed for helicopters by the FAA." 

To provide the intended aerial video operations, the sUAS is normally operated below 500 feet AGL. 

Additionally, due the nature of the proposed operations, the sUAS will maintain a safe lateral and 

vertical distance from inhabited structures, buildings, vehicles, and vessels, and from people not 

associated with the operation. 

U.S. 
Equivalent Level of Safety 

Compared to flight operations with rotorcraft weighing far more than the maximum 55 pounds 

proposed herein, and given the lack of flammable fuel, any risk associated with these operations is far 

less than those that presently exist with conventional aircraft. An equivalent level of safety will be 

achieved given the size, weight, and speed of the UAS, as well as the location where it is operated. As 

set forth in the Flight Operation Manual, the sUAS will be operated in a confined area, where buildings 

and people will not be exposed to operations without their pre-obtained consent. Because of the 

advance notice to the property owners and participants, all affected individuals will be well aware of the 

planned flight operations as set forth in the Flight Operation Manual. 

Furthermore, by operating at such lower altitudes, the sUAS will not interfere with other aircraft that 

are subject to the minimum safe altitude regulations. Finally, the successful safety record of the DJI 

INSPIRE 1 demonstrates that the sUAS can be safely used at these lower altitudes and closer operating 

environments. 

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

This petition seeks an exemption from 14 C.F.R. § 91.121, which requires a person operating an aircraft 

to maintain cruising altitude or flight level by reference to an altimeter that is set to the elevation of the 

departure airport or barometric pressure. An exemption is required because the sUAS does not have a 

barometric altimeter, but rather a GPS altitude read out. 

Equivalent Level of Safety 

An equivalent level of safety will be achieved by following the procedures set forth in the Flight 

Operation Manual. As prescribed in the Flight Operation Manual, the operator will confirm the altitude 

of the launch site shown on the GPS altitude indicator before flight. Moreover, the Operator will use the 

GPS altitude indicator to constantly monitor the sUAS's height, thus ensuring operation at safe altitudes. 

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

Drone U requests an exemption from 14 C.F.R. § 91.151(a}'s fuel requirements for flight in VFR 

conditions. Section 91.151 states: 

(a} No person may begin 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. 

Here, the battery powering the DJI Innovations INSPIRE 1 provides approximately 15 minutes of 

powered flight. To meet the 30 minutes reserve requirement in 14 C.F.R. § 91.151, sUAS flights could 

not be conducted. Given the limitations on the sUAS's proposed flight area and the location of its 

proposed operations within a predetermined area, a safety margin based on a reserve amount of 

battery life is needed. Petitioner will not be conducting any sUAS flights at night. 

---------~---- ----- -------------------
Equivalent Level of Safety 

An equivalent level of safety will be achieved because the operations will be conducted on-site without 

significant transit time by the sUAS. All flights will be planned to be terminated with no less than 25% 

reserve battery power still available. This restriction would be more than adequate to return the sUAS 

safely to the ground and its planned landing zone from anywhere in its limited operating area even in 

the event of an unexpected occurrence. Operation of the sUAS with less than 30 minutes of reserve fuel 

does not include the type of risks that Section 91.151(a) was intended to alleviate given the size and 

speed of the small UAS, and the proximity of the flight operation to the landing zone. 

This request for exemption falls within the scope of prior exemptions, including Exemption Nos. 10673, 

2689F, 5745, 10673, 10808 and 11333. 

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

Drone U seeks an exemption from civil aircraft certification and registration requirements of 14 C.F.R. § 

91.203(a) and (b). The regulation states 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. 

An exemption to this regulation is necessary because: (1) the sUAS's configuration, load capacity and 

size does not allow it to carry certification and registration documents; (2) the sUAS does not have a 

cabin or cockpit entrance at which documents could be displayed; and (3) there are no passengers or 

crew for whom the certificates need to be displayed. 

Equivalent Level of Safety 

To the extent these regulations are applicable to the proposed sUAS operations, an equivalent level of 

safety will be achieved by keeping these documents at the ground control point where the Operator will 

have immediate access to them. 

The FAA has issued numerous exemptions to this regulation, including: Exemption Nos. 9565, 9665, 

9789, 9789A, 9797, 9797A, 9816A, and 10700. 

M. 14 C.F.R. § 91.405(a), 91.407(a)(1), 91.409(a)(1), 91.409(a)(2); 91.417(a) and (b): 

Maintenance Inspections 

Drone U also seeks an exemption from the maintenance inspection requirements contained in 14 C.F.R. 

§ 91.405(a), 91.407(a)(1), 91.409(a)(1), 91.409(a)(2), 91.417(a) and (b). These regulations specify 

maintenance and inspection standards in reference to 14 C.F.R. Part 43. See, e.g., 14 C.F.R. § 91.405(a) 

(stating that each owner or operator of an aircraft "[s]hall have the aircraft inspected as prescribed in 

subpart E of this part and shall between required ions ... have discrepancies repaired as prescribed in 

part 43 of this chapter"). An exemption to these regulations is needed because Part 43 and these 
sections only apply to aircraft with an airworthiness certificate, which the sUAS will not have. 

Equivalent Level of Safety 

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

accordance with the Operator's Handbook as referenced in the Flight Operation Manual. As provided in 

the Flight Operation Manual, the operator will ensure that the sUAS is in working order prior to initiating 

flight, perform required maintenance, and keep a log of any maintenance performed. 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. 

If mechanical issues arise, the sUAS's size and carrying capacity, and the fact that flight operations will 

only take place in restricted areas for limited periods of time during daylight hours, creates less risk than 

that associated with conventional rotorcraft performing the same operation. 

PUBLIC INTEREST 

Granting Drone U's exemption furthers the public interest on numerous levels. National policy set by 

Congress favors early integration of UAS into the national airspace in controlled, safe working 

environments such as those propose in this petition. In addition, maintaining industrial safety has been a 

priority of state and local governments for decades. 

Drone U also believes that the use of sUASs for aerial photography and videography serves a valuable 

public interest and addresses a common public concern: safety. The use of sUAS's in a controlled and 

safe manner, as described herein. In addition, in the event of an unforeseen incident, a sUAS causes far 

less disruption than traditional aircraft. 

In addition, conducting aerial videography with the sUAS, instead of manned aircraft, meets another 

common public concern in the noise and pollution caused by traditional aircraft. The use of a sUAS 

significantly reduces the levels of air and noise pollution generated during traditional aerial video 

production flight operations. By using battery power and electric motors, the sUAS produces no air 

pollution, and is the most viable environmentally conscious alternative to piston or turbine powered 

rotorcraft. The sUAS, while reducing the carbon footprint of aerial video productions, also eliminates 

noise pollution as its battery powered electric motors are barely audible during the take-off phase, and 

cannot be heard when operating more than 100 feet above ground level. 

By using the sUAS to perform aerial videography, 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 aircrew members located 

onboard the aircraft, the minimal size and weight of a sUAS creates 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 aerial videography. Relatedly, the sUAS contains no reactive or combustible materials 

on board and thus the potential for fire or explosions is greatly diminished. 

In addition, granting the exception will help advance the knowledge base for conducting commercial 

UAS operations. This additional data will help the FAA set future rules regarding UAS flight operations, 

maintenance, and crew qualifications. The public also has an interest in reducing the hazards and 

emissions associated with alternate use of helicopters to conduct similar aerial videography operations. 

The UAS in question is very light weight and does not carry any flammable fuel, further reducing the risk 

I 1 
from any potential accident. 

PRIVACY 

All of the proposed flights and videography will be only conducted after obtaining any individual subject 

matter's permission. All flights will occur over public right-of-way or private property with the property 

owner's prior consent and knowledge. The proposed operations will not impact privacy concerns 

beyond those already implicated by manned aircraft aerial videography operations. 

FEDERAL REGISTRY SUMMARY 

Pursuant to 14 C.F.R. Part 11, the following summary is provided for publication in the Federal Register, 

should it be determined that publication is needed: 

Drone U seeks an exemption from the following rules: 

14 CFR Part 21, Subpart H; 14 CFR Part 27; 14 CFR 45.23(b); 45.27 (a); 14 C.F.R. 61.113; 14 CFR 

91.7(a); 14 CFR 91.9(b)(2); 14 CFR 91.9(c); 14 CFR 91.103; 14 CFR 91.109(a); 14 CFR 91.119; 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)(1)and (2); 14 CFR 91.417 (a) & (b). 

Approval of these exemptions allowing commercial operations of small and lightweight unmanned 

aircraft ("sUAS") to conduct aerial videography and cinematography operations will enhance safety by 

reducing risk to C5 Aerial, the general public and property owners. 

The DJI Innovations sUAS, weighing less than 55 pounds, with payload, and powered by batteries, 

eliminates virtually all of that risk given the reduced mass and lack of combustible fuel carried on board. 

The sUAS is transported to the designated survey area set up. It is not flown from an external location to 

the work-site. The sUAS will carry no passengers or crew and, therefore, will not expose them to the 

risks associated with manned aircraft flights. 

The operation of this small UAS will provide an equivalent level of safety, supporting the grant of the 

exemptions requested herein, including exempting the applicant from the requirements of Part 21 and 

allowing commercial operations. These lightweight sUASs operate at slow speeds, close to the ground, 

and in a controlled environment. As a result, they are far safer than conventional aerial photography, 

videography, and data collection operations are conducted with fixed wing aircraft or helicopters. 

CONCLUSION -------------------------

Satisfaction of the criteria provided in Section 333 of the Reform Act of 2012-size, weight, speed, 

operating capabilities, proximity to airports and populated areas and operation within visual line of sight 

and national security-provides more than adequate justification for the grant of the requested 

exemptions to permit Drone U to operate sUASs in support of its aerial photography, videography, and 

aerial data collection operations in accordance with the Flight Operation and Operator's Handbook 

appended hereto. 
Granting the requested exemption will benefit the public interest as a whole in many ways, including (1) 

significantly improving safety and reducing risk by alleviating human exposure to danger, (2) improving 

aerial videography operations and decreasing operating costs, and {3) providing an environmentally 

conscientious way of producing aerial videography and cinematography operations. 

Sincerely, 

IJ#(~~ 

LJ;i:C. Knudsen 

Encls: - Flight Operations Manual (CONFIDENTIAL- NOT FOR PUBLIC RELEASE) 

sUAS Operator's Handbook (CONFIDENTIAL- NOT FOR PUBLIC RELEASE)