Petition for exemption section 333

Telesens, LLC

900 North Stuart Street Apt 804 Arlington VA 22203. Phone: 301-219-0661

Email: ankur@umiacs.umd.edu

Re: Exemption Request Section 333 of the FAA Reform Act and Part 11 of the Federal Aviation 

Regulations from Title 14, Code of Federal Regulations 14 C.F.R. Part 21; 14 C.F.R. 45.23 (b); 14 C.F.R. 

61.113(a) and (b) ; 14 C.F.R. 91.7; 14 C.F.R. 91.9; 14 C.F.R. 91.119 (c); 14 C.F.R. 91.121; 14 C.F.R. 

91.151(a); 14 C.F.R. 91.405 (a); 91.407 (a) (1); 91.409 (a) (1) & (2); 91.417(a) & (b)

PETITION FOR EXEMPTION

Dear Sir or Madam:

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

C.F.R. Part 11, Telesens, LLC, operator of Small Unmanned Aircraft Systems (“sUASs”) (referred to as the 

“Petitioner” or “Applicant”) hereby applies for an exemption from the listed Federal Aviation 

Regulations (“FARs”) to allow commercial operation of its sUASs, 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 333.1 

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

controlled conditions in airspace that is 1) limited 2) predetermined and 3) controlled. The proposed 

exemption, if granted, would allow Telesens, LLC to conduct commercial operations of sUASs meeting or 

exceeding all of the operational and safety requirements that Congress has set forth in Section 333. 

Page 2. Telesens LLC asks that if any part of this request is deemed not in compliance, that part be 

removed and process the remainder of this request as applicable.

Table of Contents

1. Introduction to Telesens, LLC

2. Operations of Interest

3. Regulations from which Exemption is Requested

4. Aircraft Types

5. UAS Information

6. Operation and Safety Standards

7. Public Interest

8. Exemption Request Details

9. Request for waiver for publication and comment procedures

10. Federal Register Summary

Telesens,	LLC

Address: 900 North Stuart Street, Apt 804 Arlington, VA 22203. EIN: 47-4983461
Telesens, LLC is a technology company owned and run by Ankur Ankur. Mr. Ankur holds a Masters in 

Electrical Engineering from the University of Maryland and a M.B.A from Georgetown University. Mr. 

Ankur is intimately familiar with the details of flight control and command and control systems used in 

UAS and has given numerous talks about building and safely operating UAS in the greater Washington, 

DC area. A link to Mr. Ankur’s recent talk about operating the Iris+ quadcopter from 3D Robotics is as 

follows:

http://www.meetup.com/DC-Area-Drone-User-Group/events/224717878/

Mr. Ankur has extensive experience operating sUAS manufactured by 3D Robotics and DJI and has flown

numerous flights in both manual and autonomous mode without incident and always respecting 

applicable FAA regulations.

Operations	of	Interest

Telesens, LLC plans to exploit the capabilities of UASs to offer a multitude of services, including:

- Aerial Surveying and 3D mapping

- Event Photography/Videography

- Crop Inspections

- Real Estate Photography

- Construction site Inspections and Surveys

- Research and Development and

- Education

Regulations	from	which	Exemption	is	Requested

Statutory Authority Section 333, titled “Special Rules for Certain Unmanned Aircraft Systems”, provides 

a mechanism for seeking expedited FAA authorization of safe civil UAS operations in the NAS. Section 

333(a) states that the FAA “shall determine if certain unmanned aircraft systems may operate safely in 

the national airspace system before completion of the (comprehensive) plan and rulemaking required 

by section 332(b)(1) of this Act or the guidance required by section 334 of this Act.” In Section 332(b)(1), 

Congress made it clear that Section 333 provides a mechanism for “expedited operation authorization” 

if several factors are met. Petitioner meets all requirements to permit FAA approval of commercial UAS 

operations.

The petitioner requests relief from the following regulations:

14 C.F.R. Part 21 

14 C.F.R. 45.23 (b) 

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

14 C.F.R. 91.7

14 C.F.R. 91.9

14 C.F.R. 91.119 (c)

14 C.F.R. 91.121

14 C.F.R. 91.151(a) 

14 C.F.R. 91.405 (a); 91.407 (a) (1); 91.409 (a) (1) & (2); 91.417(a) & (b)
Aircraft	Types

Exemption is requested for the following aircrafts:

DJI Phantom 3

DJI Inspire 1

3DR Iris+

3DR Solo

UAS	Information

Salient Features of these aircrafts are presented in the table below:

DJI Phantom 3 

(Pro)

DJI Inspire 1 3DR Iris+ 3DR Solo

Weight 1280 g 2945g 1282g 1800 g

Max Payload

Max Speed 16 m/s 22 m/s 20 m/s 24 m/s

Max Climb 

Rate

5 m/s 5 m/s 5 m/s 10 m/s 

(stabilize 

mode)

GPS Failsafe? Yes Yes Yes Yes

GeoFence 

(max altitude, 

radius from 

home)? 

Yes Yes Yes Yes

Battery Life 

(with Payload)

~20 min ~15 min ~20 min ~20 min

User	Manuals:

Phantom 3:

http://download.djiinnovations.com/downloads/phantom_3/en/Phantom_3_Professional_User_Manual_v1.4_en.pdf

Inspire 1:

http://download.dji-innovations.com/downloads/inspire_1/en/Inspire_1_User_Manual_v1.4_en.pdf

3DR Iris+

http://3drobotics.com/wp-content/uploads/2015/02/IRIS-Plus-Operation-Manual-vH-web.pdf

3DR Solo

http://3drobotics.com/wp-content/uploads/2015/08/v5_08_21_15.pdf
All UASs referred to in this petition feature an integrated microprocessor and IMU sensors running 

heavily tested flight control systems that continuously maintain aircraft stability and geospatial position 

and orientation. The sensors include gyroscopes, accelerometers, GPS unit, barometers and compass. 

The DJI Phantom 3 and Inspire 1 also feature integrated optical flow sensor enabling the UAS to hover 

by observing patterns on the ground. The flight control boards contain multiple sensor units to provide 

redundancy. The UASs are primarily controlled by FCC certified radio control (RC) unit. Real time video 

and telemetry information is transmitted back to the ground control station allowing the PIC to monitor 

battery level, GPS signal strength, altitude, distance from PIC, camera imagery and camera angle. 

Risk	Mitigation

The petitioner's small UAS has failsafe modes of operation for either loss of radio control, GPS signal, or 

low battery level. Altitude can be limited by the onboard flight controller and maximum altitude can be 

programmed by the PIC. Battery life limits flight times to approximately 25 minutes. The onboard flight 

controller will warn the pilot via telemetry and external lighting cues before reaching a low battery 

state. An automatic termination of flight and landing will be initiated when the battery reaches a 

predetermined state. It is anticipated that flights will usually last less than 10 minutes. More information 

is available on:

Pages 12-14 of the attached Phantom 3 Professional User Manual version 1.4

Page 13-16 of the attached Inspire 1 User Manual version 1.4

Page 7 of the attached Iris+ User Manual

Section 6.2 of the attached Solo User Manual

Operation	and	Safety Standards

 The sUASs will weigh less than 10 pounds 

 Flights will be operated within line of sight of a pilot and/or observer. 

 Maximum flight time for each operational flight will be no more than 20 minutes

 Prior to each flight, the pilot shall conduct pre-flight checks including but not limited to: ensuring 

the battery for the UAS and the remote control is fully charged, there is no visible damage to the 

airframe and propellers that might impede safe flight or alter expected flight characteristic, a 

sufficiently strong GPS lock is available, all sensors on board required for a safe flight such as 

accelerometers, gyroscopes, barometer, compass/magnetometer are properly calibrated. The 

pilot will also ensure that the “home position” (point of origination) is set properly and the 

vehicle is able to safely return to home in case a return to home is triggered. 

 Flights will be terminated at no less than 30% battery power reserve should that occur prior to 

the 20 minute limit. 

 Flights will be operated at an altitude below 300 feet AGL, and not more than 150 feet above an 

elevated platform from which filming is planned. 

 Minimum crew for each operation will consist of the sUAS Pilot and the Visual Observer. 
 A sUAS pilot will be Pilot in Command (PIC)

 A briefing will be conducted for planned sUAS operations prior to each day’s flight. All 

personnel performing duties within the boundaries of the safety perimeter are required to 

attend. 

 The operator will obtain consent of all persons involved in the filming and ensure that only 

consenting persons will be allowed within 500 feet of the flight operation. 

 The Pilot and observer must be trained in sUAS operations and have received current 

information on the particular sUAS to be operated 

 The Observer and pilot will be able to communicate at all times

 Written and/or oral permission from the relevant property holders will be obtained prior to 

flight operations. 

 If the sUAS loses communications or loses its GPS signal, the sUAS will have the capability to 

return to the point of launch using the RTL safety future of the flight controller 

 Detailed logs contain position and altitude information and IMU measurements will be 

maintained by the UAS operator.

Public	interest	

Use of the sUAS in lieu of a manned aircraft would enhance safety and reduce the environmental impact 

as compared to similar operations conducted with manned aircraft of greater proportions, carrying a 

crew and flammable fuel. Additionally, use of the sUAS in order to facilitate commerce could lead to 

economic growth. Operations for this petition will enable service for property owners or their designees 

seeking an enhanced perspective for characteristics, amenities, and benefits of their desired 

photographic subjects that cannot be displayed through ground level videography/photography. Aerial 

photography is a valuable marketing tool that can lead to increased commerce and enhance personal 

photography. Crop surveying applications could lead to decreased use of pesticides and fertilizer and 

conservation of water as well as increased crop yields and decreased costs. Aerial surveying and 

inspections can increase work site efficiency, improve volumetric estimations and reduce risks. Liability 

insurance will be obtained commensurate with the granting of this request for exemption. Detailed logs 

contain position and altitude information and IMU measurements will be maintained by the UAS 

operator and provided to relevant government agencies upon request.

Exemption	Request	Details

14 CFR Part 21, Airworthiness Certificates 

This part establishes the procedures for the issuance of an airworthiness certificate. While the FAA 

continues to work to develop airworthiness standards for Unmanned Aerial Systems, we request an 

experimental certificate be issued for the sUASs considered herein under either or both of the following 

provisions: 

21.191 Experimental certificates. Experimental certificates are issued for the following purposes: 
(a) Research and development. Testing new aircraft design concepts, new aircraft equipment, new 

aircraft installations, new aircraft operating techniques, or new uses for aircraft. 

(b) Showing compliance with regulations. Conducting flight tests and other operations to show 

compliance with the airworthiness regulations including flights to show compliance for issuance of type 

and supplemental type certificates, flights to substantiate major design changes, and flights to show 

compliance with the function and reliability requirements of the regulations. 

Since the experimental certificate can be used for commercial purposes such as market surveys, sales 

demonstrations, and customer crew training, we would expect that an experimental certificate would 

permit our commercial purpose as well. The aircraft will not carry persons or property, will not carry 

fuel, and will only fly under strict operational requirements. Combined with the UAS's light weight, being 

constructed primarily of carbon fiber and plastic, we propose that the UAS will be at least as safe, if not 

safer, than a conventionally certificated aircraft performing the same mission. If an experimental 

airworthiness certificate is not appropriate for this application, then we request an exemption of 14 CFR 

Part 21, Subpart H, and the requirement for airworthiness certificate in general, citing the equivalent 

level of safety outlined in the previous paragraph. 

Please note that Exemption # 11224 granted to NextEra Energy, Inc. determined that the DJI Phantom 2 

Vision +, DJI Inspire, and DJI S900 were previously determined in other exemptions to not be required to 

have an airworthiness certificate based upon the authority of Section 333 of the FAA Modernization and 

Reform Act of 2012. Other exemptions have also determined that the Phantom 2 platform does not 

need an airworthiness certificate. See Exemption # 11220 for Aerial Production Services, Inc. The 

Phantom 3 platform is similar to the Phantom 2 and should not need an airworthiness certificate. We 

argue that the 3DR Iris+ and Solo have also been extensively flight tested and used safely by hundreds of 

thousands fliers and should be suitable exempted from airworthiness certificate. 

14 CFR 45.23 Display of marks

These regulations provide that each aircraft must display "N" and the aircraft's registration number in 

letters at least 3 inches high. Additionally, the aircraft must display the word "EXPERIMENTAL" in letters 

at least 2 inches high near the entrance to the cabin, cockpit, or pilot station. The sUAV does not have 

an entrance in which the word "EXPERIMENTAL" can be placed, and may not have a registration number 

assigned to it by the FAA. We propose to achieve an equivalent level of safety by including the word 

"EXPERIMENTAL" in a placard on the top of the aircraft, where the PIC (Pilot In Control), VO (Visual 

Observer) and others in the vicinity of the aircraft while it is preparing for launch will be able to see the 

designation. 

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

Pilot in Command Sections 61.113 (a) and (b) limit private pilots to non-commercial operations. Because 

the sUAS will not carry a pilot or passengers, the proposed operations can achieve the equivalent level 

of safety of current operations by requiring the PIC operating the aircraft to have a private pilot’s license 

rather than a commercial pilot’s license to operate a sUAS. Unlike a conventional manned aircraft, a 
sUAS is remotely controlled by a ground-based operator. The operational area is controlled and 

restricted, and all flights are planned and coordinated in advance. The level of safety exceeds that 

provided by a single individual holding a commercial pilot’s certificate operating a conventional aircraft. 

The risks associated with the use of a sUAS are so diminished from the level of risk associated with 

commercial operations contemplated by Part 61 allowing sUAS use by a sport pilot as the PIC exceeds 

the present level of safety sought by 14 C.F.R. §61.113 (a) and (b). 

14 CFR 91.7: Prohibits the Operation of an aircraft without an airworthiness certificate

As no such certificate will be applicable in the form contemplated by the FARs, this Regulation is 

inapplicable.

14 CFR 91.9: Civil aircraft flight manual, marking, and placard requirements

This regulation provides that no person may operate an aircraft unless a current, approved flight manual 

is in the aircraft. We assume that the intent of this requirement is to ensure that flight manual 

information is available to the aircrew while operating the aircraft. We request an exemption to this 

requirement since the aircraft is not only too small to carry documentation, the documentation would 

not be available to the crew during flight operations. To obtain an equivalent level of safety and meet 

the intent of 91.9, we propose that a current, approved sUAS Flight Manual must be available to the 

crew at the ground station anytime the aircraft is in, or preparing for, flight.

14 C.F.R. 91.119(c): Minimum Safe Altitudes 

Section 91.119 establishes safe altitudes for operation of civil aircraft. Section 91.119 provides, in 

pertinent part, that: “except when necessary for takeoff or landing, no person may operate an aircraft 

below the following altitudes: ..... (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.” Telesens, LLC requests 

authority to operate at altitudes no higher than 300 AGL, and not more than 150 above an elevated 

platform from which filming is planned, an exemption is needed to allow such operations. The sUASs will 

be operated in a restricted area within a 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, and speed of the sUAS as well as the location where it is operated. No 

flight will be taken without the permission of property owners or local officials. Because of the advance 

notice to the property owners and participants involved in the sUAS operation, all affected individuals 

will be informed of the planned flight operations. Compared to flight operations for conventional 

aircraft, any risk associated with the proposed sUAS operations is far less than conventional aircraft 

operating at or below 500 AGL. In addition, the low-altitude operations and light weight of the sUASs

will ensure separation between the sUAS and conventional aircraft. 

14 C.F.R. §91.121: Altimeter Settings
Section 91.121 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 a sUAS may not have a barometric altimeter, but instead a GPS altitude 

data, an exemption is needed. An equivalent level of safety will be achieved by the operator, pursuant 

to the operating manuals

14 C.F.R. §91.151(a): Fuel Requirements for Flight in VFR (Visual Flight Rules) 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 . . . .” The typical battery powering the sUASs provides less than 20 minutes of powered 

flight. To meet the 30-minute reserve requirement in 14 CFR §91.151, sUAS flight would not be possible. 

Given the limitations on the sUASs proposed flight area and its proposed operations within a 

predetermined location, a shorter time frame for flight in daylight VFR conditions is reasonable. 

Furthermore, operating the sUASs in a tightly controlled area where only people, property owners, or 

official representatives who have signed waivers will be allowed, less than 30 minutes of reserve fuel 

does not engender the type of risk that §91.151(a) was intended to address. Petitioner believes that 

safety can be achieved by limiting flights to 15 minutes or 30% of battery power, whichever occurs first. 

This restriction would be more than adequate to return the sUAS to the point of launch from anywhere 

in its limited operating area.

Information provided in the operating documents discusses procedures regarding remaining battery 

power management. Those documents contain a condition in which the PIC will initiate a landing 

procedure when battery remaining reaches a specified level. Beyond that, the petitioner's small UAS 

initiates a "Go Home" (to the flight's origination point) when battery level drops to the "Low Battery" 

level. Telesens will ensure that aircraft remains within reach of the origination point in case a “Go 

Home” needs to be initiated. 

Similar UAS-specific relief has been granted in Exemption Nos. 8811, 1 0808, and 10673 for daytime, VFR 

conditions.

14 C.F.R. §91.405 (a); 91.407 (a) (1); 91.409 (a) (1) & (2); 91.417(a) & (b): Maintenance Inspections and 

Records:

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 sections and 

Part 43 apply only to aircraft with an airworthiness certificate, these sections will not apply Telesens’s 

operations. An equivalent level of safety will be achieved because these small UAS’s are very limited in 

size and will carry a small payload and operate only in restricted areas for limited periods of time. The 

operator will also maintain logs of each flight undertaken by the UASs. These logs will contain detailed 

telemetry data about aircraft altitude and position, IMU measurements, RC inputs, flight controller 
output and other information necessary to fully reconstruct the flight path and characteristics should it 

become necessary. The operator will provide these logs to the FAA, NTSB or any other interested 

government agency if requested to do so. 
REQUEST	FOR	WAIVER	FOR	PUBLICATION	AND	COMMENT	PROCEDURES

TELESENS, LLC REQUESTS THAT THE PUBLICATION AND COMMENT PROCEDURES BE WAIVED IN 

ACCORDANCE WITH 14 C.F.R. § 11.87. 

§ 11.87 Are there circumstances in which FAA may decide not to publish a summary of my petition for 

exemption? 

The FAA may not publish a summary of your petition for exemption and request comments if you 

present or we find good cause why we should not delay action on your petition. The factors we consider 

in deciding not to request comment include: 

(a) Whether granting your petition would set a precedent. 

(b) Whether the relief requested is identical to exemptions granted previously 

(c) Whether our delaying action on your petition would affect you adversely 

(d) Whether you filed your petition in a timely manner

Corresponding to the above sub-sections, Telesens, LLC has good cause to request the FAA to waive the 

comment period and not delay action on the petition because: 

(a) Telesens, LLC would not set any precedent. Telesens, LLC agrees to the same limitations as many 

similar exemptions already granted, for example, Exemption # 11284. Furthermore, all of the aircraft 

requested in this application have already been evaluated under previous petitions and are deemed to 

have the equivalent level of safety if operated under the restrictions hereto already agreed upon. 

(c) Delaying the granting of this petition would adversely affect the public, the FAA, and Telesens, LLC. 

The public, as well as the FAA, would be better served by the FAA quickly granting this petition and 

thereby freeing up limited FAA resources and allowing FAA inspectors to dedicate their time and 

attention to much higher priorities. Moreover, Telesens, LLC is adversely affected by the below listed 

regulations.

(d) The petition has been filed in a timely manner. 
FEDERAL	REGISTER	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. Applicant seeks an exemption from the following 

rules: 14 C.F.R. Part 21, 14 C.F.R. 45.23 (b), 14 C.F.R. 61.113(a) and (b), 14 C.F.R. 91.7, 14 C.F.R. 91.9,

14 C.F.R. 91.119 (c), C.F.R. 91.121, 14 C.F.R. 91.151(a), 14 C.F.R. 91.405 (a); 91.407 (a) (1); 91.409 (a) (1) 

& (2); 91.417(a) & (b) to operate commercially a small unmanned vehicle (55 lbs. or less) for Aerial 

Surveying, Event Photography/Videography, Crop Inspections, Real Estate Photography, Construction 

site Inspections and Surveys, Education and Research and Development. This exemption will allow 

commercial operations of UA’s which will enhance safety by reducing risk. The alternative to using a UA 

is to use a jet or piston power aircraft carrying large amounts of jet or other fuel. Not only is the 

operation dangerous at the location, the aircraft must fly to the location and back to the home airport. 

Our UA will weigh less than 55 lbs. and powered by batteries which eliminates most of the risk because 

no highly flammable fuel will be involved. The UA will carry no passengers or crew; thus, eliminating 

most of the risk to the pilot and personnel. The operations of the UA listed under the restrictions 

proposed herein will provide an equivalent level of safety as the Federal Aviation Regulations.

If I can be of any assistance to further expedite this petition, please do not hesitate to contact me at 

(301)219-0661 or at my email ankur@umiacs.umd.com. 

Sincerely yours,

Ankur Ankur

Telesens, LLC

900 North Stuart Street Apt 804, Arlington VA 22203