Drone Integration Services, Inc. 

Andres L. Justicia Doll 

Founder/President 

216 Chesterfield Court 

UnitB 

Schaumburg, IL 

60193 

Dear Sir or Madam: 

Let this letter and enclosed documentation serve as a respectful and formal request from me, 

Andres L. Justicia Doll, founder and president of Drone Integration Services, Inc., to be allowed 

to operate drones, commercially, for compensation or hire. 

The enclosed documentation has been formatted following "Petition for Exemption 14CFR 

11.81 ", as found in the FAA's website, www.faa.gov. I am confident you will find all the 

information in order. 

I can be reached for questions or conversation about the matter hereby enclosed via e-mail at 

justiciadoll75@gmail.com, or via phone at (787)-374-3741. 

Drone Integration Services, Inc. 

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) 

6) PUBLIC BENEFIT 

7) PUBLISHABLE INFORMATION 

8) ADDITIONAL INFORMATION 

9) PRNILAGES OUTSIDE THE UNITES STATES 

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b) Andres L. Justicia Doll: I've been a certified pilot, in good standing with the FAA, 

since October 16th, 2007. I received my instrument rating on April12 2011. 

Pursuant to complying with Section 333 and the FAA's Modernization Act of 

2012, I feel I comply with what I believe to be the pivotal requirement for 

commercial operation of a drone for compensation or hire, which is having a 

pilot's certificate and being in good standing with the FAA. 

Furthermore, I have been actively involved since age twelve (12) in the radio 

controlled airplane hobby. I have continuously maintained membership through 

the Academy of Model Aeronautics (AMA), the governing body as it refers to the 

aero modeling hobby, and am currently in good standing. 

2) INTRODUCTION 

Drone Integration Services, Inc. is Schaumburg Illinois based company which aims to 

capitalize on the commercial use of drones, for compensation or hire, while serving several 

market verticals and/or industries in a variety of specialized functions, within the continental 

United States (including Alaska), Puerto Rico, United States Virgin Islands and Hawaii. 

(Privileges outside of the continental Unites States and its territories will be addressed in the 

"Privileges outside the United States" section) 

The ve1ticals and industries that we hope to impact with our services include, but are not limited 

to: 

• Agriculture 

• Transp01tation 

• Infrastructure 

• Engineering 

• Architecture 

• Manufacturing 

• Health care 

• Legal 

• Non-for-profit 

• Higher Education 

• K-12 

• Telecommunications 

• State and Local Governments 

• Commercial, General 

• Commercial, Industrial 

• Marketing and Adve1tising 

• Real Estate 

• Energy 

• Oil & Gas 

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 p

y 

• topography studies 

• geo mapping 

• surveying 

• strategic farming studies 

• livestock monitoring 

• logistics 

• crowd control 

• missing person search 

• rapid response 

• structure inspections 

• surveillance 

• flight instruction/training 

• flare stack inspections 

3) BASIS FOR PETITION 

Drone Integration Services, Inc., pursuant to comply and abide with and by the provisions 

put forward by the FAA Modernization Act of2012 and Section 333, hereby respectfully request 

that petmission be granted, in a manner which aligns with the interest of the FAA and that of 

Drone Integration Services, Inc. in conducting commercial operations safely, to operate drones, 

commercially, for compensation or hire. 

Drone Integration Services, Inc.'s fleet of drones comprises of the following: 

DJI Phantom 2 

DJI Phantom 1 

DJI Inspire 

Free Fly Systems Alta 

Trimble UX-5 

These are commercially available drone units which operate well within the limitations for 

weight, speed, altitude and operational capabilities set fmth by the FAA. In addition, all of these 

commercially available drones have been listed in other several petitions for exemption as being 

pa11 of a drone fleet. Further technical infmmation will be furnished upon request. 

4) EXEMPTIONS SEEKED 

Following suite whereas other section 333 applicants have put forward this section for 

"exemptions seeked" and have successfully navigated the application process to operate their 

drones, for compensation or hire, Drone Integration Services, Inc. hereby respectfully request 

exemption from the following Federal Aviation Regulations patts/sections/sub-sections: 

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14 CFR 91.121 Altimeter settings 

14CFR 91.151 Fuel requirements for flight in VFR conditions 

14 CFR 91.203 Civil aircraft: cetiifications required 

14 CFR 91.405 Maintenance required (a)(b) 

14 CFR 91.407 Operation after maintenance, preventive maintenance, rebuilding or alteration 

14 CFR 91.409 Inspections 

14 CFR 91.41 7 Maintenance records 

5) EXTENT OF RELIEF 

Pursuant to complying with the petition format and infmmation required, as set forward 

by the "Petition for Exemption 14CFR 11.81 ", as found in the FAA's website, www.faa.gov, let 

the following section "Extent of Relief' serve as fmiher detail and more granular explanation for 

request of exemption, as listed above. 

• 14 CFR 21 subpati H Airworthiness certificates: 

Based on the size, weight, operation, safety measures, conditions and limitations 

set fmih, and the pivotal fact that my drones are commercially available and, therefore, 

places the need to abide by any requirement and/or regulation that the Administrator 

deems necessary, on the manufacturer, (including, if found necessary, an airwmihiness 

certificate), exemption should be granted to Drone Integration Services, Inc, for the 

reason that we are, merely, a user. 

As an alternative, Drone Integration Services, Inc. will set a 

maintenance/inspection schedule and a maintenance log book will be kept for each drone 

in operation as to track infmmation that will include, but will not be limited to: date of 

inspection/repair, name of person who perfmmed repair, what part or appliance (if any) 

was replaced, general items or actions performed during inspection/repair, PIC who 

performed operation flight check (if applicable), return to service on date. This is an 

effmi to maintain the fleet in the utmost ainvorthiness condition. 

• 14 CFR45.23 Display ofmarks, general: 

In the drone units commercially available today there is no entrance to a cockpit, 

cabin or pilot station, therefore, the traditional placement of flight placards is not 

possible. Fmihetmore, a standardized marking system for "drones" and uav's has not yet 

been set fmih. 

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• 14 CFR 61.113 Private pilot privileges and limitations: pilot in command: 

By viliue of this regulation, which prohibits a private pilot from flying, persons or 

cargo, for compensation or hire, exemption is necessary since the FAA has deemed the 

aeronautical knowledge possessed by a private pilot as acceptable for acting as PIC of a 

drone, flying commercially, for compensation or hire. 

In addition, in the future, Drone Integration Services, Inc. will hire pilots as pati 

of their expansion plans. A private, sport or recreational pilot would meet the FAA's 

requii·ement for commercial operations (as far as having the pilot in command be a 

cetiificate holder in good standing with the FAA) and, as such, would respectfully 

request exemption in this area. 

• 14 CFR 91.9 Civil aircraft flight manual, markings and placard requii·ements: 

Markings and placards were previously addressed in 14 CFR 45.23. 

As an altemative, the flight manual, while not practical to be carried on board the 

flying drone, should be kept accessible to the pilot, at all times, at the ground station. 

Drone Integration Services, Inc. has made this pati of the operating procedures. 

• 14 CFR 91.109 Flight instmction: simulated instmment flight and cetiain flight tests: 

By virtue that a drone is, by nature, unmanned, therefore, does not have a 

cabin/cockpit/flight station, instmction cannot be conducted by use of a "dual control" 

system. 

As an altemative, Drone Integration Services, Inc. will establish a pilot training 

program, very much like the cunent teaching method for radio controlled model 

airplanes. This method consists of a pilot in command and a student. Previous to the first 

flight, the appropriate "ground" time has been spent talking about aircraft systems, 

control systems, basics of flight and how the actual teaching will take place. 

While in the air, there is constant verbal communication between the student and 

instmctor and, in the event that the student requires help, the instmctor "takes over" the 

control unit. 

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As an alternat

v

, 

p

g

procedures, the necessary measures will be taken as to provide for public safety by 

setting a "perimeter" which allows for the safe takeoff, flight operations, and landing of 

the drone while avoiding close contact with the public (people not inherent to the flight 

mission), structures, property, etc .. 

• 14 CFR 91.121 Altimeter settings: 

While the drone is not equipped with an on board pressure sensitive altimeter, the 

global positioning system aided guidance system (which does have altitude telemetry) in 

combination with the organic nature of drone flights (low level, line of sight, one pilot in 

command and one visual observer), builds a level of safety as it relates to obstacle 

avoidance, controlled flight and general safety. 

• 14CFR 91.151 Fuel requirements for flight in VFR conditions: 

This regulation addressed the traditional, av/jet/diesel/mogas fuel dependent, 

flying craft. Exemption is requested for this part since drones, as commercially available 

today, do not rely on fuel as listed before but on electricity provided by a rechargeable 

battery, for flight. 

As an alternative, Drone Integration Services, Inc. will enforce the following as 

part of its flight procedures: the pilot in command shall have the ability to initiate the 

flight, conduct the flight and land while having at least 20% of battery life remaining. 

Example: 

- Battery life, per flight, under normal circumstances: 3 0 minutes flight time 

- 20% equates to 6 minutes 

- Pilot in command can fly up to 24 minutes 

• 14 CFR 91.203 Civil aircraft: ce1iifications required: 

While it is not practical to have any appropriate documentation aboard the drone, 

while in flight or on the ground (for lack of storage space onboard), Drone Integration 

Services, Inc. suggests that, as a viable alternative, to have all the appropriate 

documentation stored, available and ready to be reviewed, at all times, at the ground 

station. 

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Exemption is seeked from these regulations since they only petiain to crafts that 

have airw01ihiness certificates. As such, the drone, providing it complies with all the 

limitations put forth by the Administrator, shall not be ruled under these. 

As an alternative, Drone Integration Services, Inc. will conduct maintenance and 

repairs as prescribed by the manufacturers' operating handbook. Furthermore, flight, as 

well as maintenance, logs will be kept for each unit in use. (See 14 CFR 21) 

6) PUBLIC BENEFIT 

The advent of drones and the gesture from the FAA in allowing certificate holders to be 

able to conduct commercial operations and applications, could not have come at a better time. 

The public, as well as businesses, are constantly looking to minimize their footprint and, at the 

same time, controlling costs while improving safety. Drones in commercial applications achieve 

this is several levels: 

• Decreased congestion of the National Airspace System 

• Zero emissions 

• Decreased noise pollution 

• Limiting human exposure to inherently dangerous operations like inspections, mining 

studies, surveying, etc. 

• Decrease cost of doing business (ex: a drone taking aerial pictures versus a helicopter 

taking pictures) 

• No privacy issues (flights conducted over private or controlled propetiies, where 

permission has been previously received) 

• Employment generation 

7) PUBLISHABLE INFORMATION 

The entire content of this document is publishable. 

8) ADDITIONAL INFORMATION 

Drone Integration Services, Inc. will potentially become one of the pioneering companies 

in the United States for commercial applications of drones. As such, we are committed to setting 

f01ih a positive example as it relates to operational excellence, corporate integrity and having 

safety as our true n01ih. Therefore, we hereby set forward our unconditional commitment to 

following and abiding the rules set forth by the FAA. Fmihetmore, our internal processes will 

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will embrace those that po

y

1) Every unit on our fleet will abide with the limitations set forward by the FAA as it relates 

to weight, speed, altitudes, operational capabilities, etc .. 

2) Day time operations only 

3) Line of sight flight 

4) Minimum flight crew will consist of Pilot in Command (PIC) and Visual Observer (VO) 

5) Pre-mission briefmg mandatory 

6) Checklists abided by for pre-flight and post-flight 

7) Comply with "minimum fuel" (20% battery life) requirement 

8) Petmission (from owner or agent) will be received verbally and noted in written fmm 

before flight over prope1iy is commenced 

9) If flight mission requires Drone Integration Services, Inc. to operate with 5 NM of the 

center of a runway complex of an airpmi, we will advise, with no less than 72 hours, the 

Administrator ofthe activity. A detailed briefing ofthe operation will be furnished. 

On the day of the flight, the PIC will issue, by way of hand held radio, repmiing calls to 

the controlling tower or CT AF which will include all the pertinent data as it relates to the 

drone's altitude, location, proximity to the airport and intentions. 

1 0) Drones will yield and give right of way and remain clear at all times 

10) PRIVILAGES OUTSIDE THE UNITED STATES 

The opportunity may arise where a domestic customer/prospect may want Drone 

Integration Services, Inc. to conduct operations outside of the continental United States and/or its 

tenitories. If this was the case, Drone Integration Services, Inc. would, as pati of travel abroad, 

take with us our safety procedures, any required hardware, software and anything else deemed 

necessary. 

Drone Integration Services, Inc. will proactively look into what considerations should be 

observed when travelling to other countries (ex: acceptance of drones in the country, permits, 

safety requirements {which exceed the ones established}). Potentially contacting the United 

States Embassy at that country for futiher information gathering. In addition, find local rules for 

operating drones in general. 

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