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Spectre Aerial Productions, LLC

202 Teakwood St

Lake Jackson, TX 77566

October 13, 2015

U.S. Department of Transportation

Docket Management System

1200 New Jersey Ave., SE

Washington, DC 20590

Re: Exemption Request Under Section 333 of the FAA Modernization and Reform Act of 2012 and 

Part 11 of the Federal Aviation Regulations from Certain Provisions of 14 C.F.R.

Dear Sir,

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

Spectre Aerial Productions, LLC, (Spectre) hereby seeks an exemption from 14 CFR §§ 91.7(a), 

91.119(c), 91.121, 91.151(a)(1), 91.405 (a); 407(a)(1); 409(a)(1)&(2); 417(a)&(b), to allow 

commercial operations of small unmanned aerial systems (sUAS).
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Table of Contents

I. Petitioner Contact Information 

II. Background

III. FAR Relief Requested & Extent of Relief 

IV. Granting Request in the Public Interest

V. Safety in the National Airspace System

VI. Summary for Publication

VII. Operating Description

 Crew

 Flight

 Aircraft

VIII. Appendix A - Flight Operations Manual

 Preparation for Flight

 Pre-Flight Inspection

 Flight Test

 Flight and Post Flight
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I. Petitioner Contact Information:

Herbert L Ross, Jr

Spectre Aerial Productions, LLC

202 Teakwood St

Lake Jackson, TX 77566

Email: HLRossJr@comcast.net

Phone: 979-480-7192

II. Background 

Spectre seeks exemption of specific requirements of 14 CFR. Approval of the exemption will 

allow Spectre to collect aerial data for clients in various industries such as real estate, roofing, 

construction, agriculture, surface mining, pipelines, electrical transmission systems, and other 

industries.

The safety and public benefits of using these UAs for data collection are significant. The UAs 

covered by this petition are small battery powered craft, usually weighing much less than 55 lbs.,

are restricted to less than 400 feet above ground level and have a very small chance, when 

following the FAA requirements, of interacting with manned aircraft. The small UAs are also 

capable of performing tasks, such as inspection of electrical towers and petrochemical plant 

equipment, making it safer for the scaffold builders and inspectors by eliminating the need of 

scaffolds to make inspections. By eliminating the need for scaffolds, there is a large cost savings 

for the industry.

Spectre would like to participate in the upcoming drone invasion of cost savings, risk reduction 

and future breakthrough activities that are not even known today. With this exemption, Spectre 

will be able to pursue the safe exploration of drone capabilities.

III. FAR Relief Requested & Extent of Relief and Reasons

14 C.F.R. §91.7(a): Airworthy Condition

Section 91.7(a) requires aircraft to be in airworthy condition. Relief is requested to achieve

airworthy condition by compliance with the operating procedures, checklists, and documents 

prescribed in this petition prior to every flight.

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

Section 91.119 (c) establishes minimum safe altitudes for operation of civil aircraft over 

congested and uncongested areas. Spectre requests authority to operate at altitudes up to 400 feet 

AGL to achieve data collection at better resolution than is possible at higher altitudes and to 

remain clear of manned aircraft. While the lower altitude is closer to people, the small size, low 

weight and low speed of the UA presents significantly lower hazard to the public. Non 

participating people will remain an appropriate distance from the UAV while it is in operation.
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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 an appropriate altimeter setting available before 

departure. Because the UA will be operating in reference to AGL, the reference altimeter setting 

will be the lowest ground level in the area of planned flight and will be zero AGL.

14 C.F.R. §91.151(a)(1): Fuel Requirements for Flight in VFR Conditions

Section 91.151(a)(1) requires all day VFR flights to operate with enough fuel to fly to first point 

of intended landing and then for at least an additional thirty minutes. Most of the UAs have less 

than 30 minutes of battery life and obviously can’t meet this requirement. Spectre requests 

exemption from this rule on the condition that the UAV flight is restricted to a planned area with 

a margin of safety to allow for battery depletion and safely land. Some UA’s, such as the DJI 

Inspire, have an automatic Return To Home feature that is activated on low battery.

14 C.F.R. §91.405 (a); 407(a)(1); 409(a)(1)&(2); 417(a)&(b): Maintenance Inspections

Since these sections only apply to aircraft with an airworthiness certificate, Spectre requests 

relief from these Sections because airworthiness certificates are not required of sUAS. The PIC 

will inspect and ensure the UAV is airworthy before any flight.

IV. Granting Request in the Public Interest

Public Benefits: The benefits to the public not only include safe operation in National Airspace

listed in Section V but also;

 Finding flood victims, lost children or hikers with visual and thermal imagery

 Lower risk to workers when a UA can achieve the same inspection that would require 

scaffolding, cranes and safety harnesses for buildings, radio and communication tower 

inspections and the cost would be significantly less.

 Lower cost than using manned aircraft in collecting a time lapse aerial photograph of a 

construction site.

 Enhance real estate sales with new techniques such as flyover video 

 Improve agriculture efficiency by detecting water imbalances in fields and diseases and 

stresses in the crops

 Save energy by locating heat losses in roofing with thermal imagery

 Lower costs to obtain data by UA, which is much less than by conventional manned 

aircraft 

 Better quality data since UA can obtain 10 times the resolution of conventional manned 

aircraft 

V. Safety in the National Airspace System

Safety: Provide Level of Safety Greater Than Existing Rule (Regarding Manned Aircraft)
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 Smaller target. The significantly smaller size (3 foot wingspan versus 30 foot wingspan 

of popular Light Sport Aircraft (LSA)), and 

 Lower Momentum. The lower speed (max speed is usually less than 60 mph) and the 

weight (less than 1/25 the weight of a Light Sport Aircraft) yield much smaller 

momentum if the UA were to strike an object, and

 Low exposure to manned aircraft. 

a. Smaller area of operation based on range (wifi signal less than 1 mile and VLOS)

b. Maximum ceiling of 400 feet Above Ground Level, 100 feet below manned 

aircraft, and 

c. Less time in the air. Battery life of UA is commonly less than 30 minutes. 

VI. Summary for Publication

Spectre Aerial Productions, LLC, seeks exemption of specific requirements of 14 CFR §§ 

61.23(a) and (c), 61.101(e)(4) and (5), 61.113(a), 61.315(a), 91.7(a), 91.119(c), 91.121, 

91.151(a)(1), 91.405(a), 91.407(a)(1), 91.409(a)(1) and (2), and 91.417(a) and (b). Approval of 

the exemption will allow Spectre to collect aerial data for clients in various industries such as 

real estate, roofing, construction, agriculture, surface mining, pipelines and electrical 

transmission systems, and in other industries.

VII. Operating Description

The goal of any flight is to acquire the aerial data needed by the client without adversely affecting the 

National Airspace System, public, and environment within the constraints of safe flight. The UA will be 

operated within rules established by FAA, the State of Texas, and local rules before any flight is 

considered. To accomplish this purpose Spectre will utilize the following conditions.

Crew

 Pilot In Command must have, at minimum, a sport pilot’s license and a third class medical 

certificate, or a U.S. driver’s license.

 No PIC may operate the UA unless the PIC meets Spectre’s qualification criteria and 

demonstrates the ability to safely operate the UA. Spectre’s minimum experience to fly a 

commercial mission is 20 hours flight time or 150 flight cycles on UA rotorcraft and 5 hours 

flight time and 25 flight cycles in make and model.

 Minimum flight crew is PIC and a visual observer (VO). The PIC may deem other crew essential 

to the safe operation of the UA to include camera operator, instructor, trainee, or other person 

necessary for the safe operation of the flight.

Flight

 Flight can only occur in Visual Meteorological Conditions (VMC), a 3 mile visibility, 

maintaining a distance 500 feet below clouds and 2000 feet horizontally, in daytime only, and 

yield right of way to all manned aircraft

 No flight higher than 400 feet Above Ground Level

 No flight closer than 5 miles from airport denoted on a current FA published aeronautical chart 

unless a letter of agreement with that airport’s management is obtained, and the operation is 

conducted in accordance with a NOTAM as required by the operator’s COA.
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 No flight closer than 500 feet to non-participating persons, vessels, vehicles and structures unless 

a barrier is in place and with permission of such persons.

 No flight over congested or densely populated area.

 The maximum speed is less than 50 mph, and the maximum weight is 55 pounds including 

payload.

 Flights will be operated within visual line of sight (VLOS) of the PIC and VO at all times. 

 PIC and VO will at all times be able to communicate verbally.

Aircraft

Spectre Aerial Productions, LLC, plans to use the following sUAS: 

 DJI Inspire

 DJI Phantom

 DJI Spreading Wings

 3DRobotics Solo

 3DRobotics X8

 3DRobotics Aero

 PrecisionHawk Lancaster

 Altus Delta X4 Lite

 Altus Delta X8

 Altus Delta LRX

 Yuneec Typhoon Q500

 Yuneec Tornado H920

 Talon 120 LE. 

Several of these are described below, and descriptions of others can be furnished if needed.

DJI Inspire

The DJI Inspire is a quadcopter capable of capturing 4K video and transmitting an HD video signal (up to 

2km) to multiple devices. Equipped with retractable landing gear, it can capture an unobstructed 360 

degree view from its camera. The built-in camera has an integrated gimbal to maximize stability and 

weight efficiency while minimizing space. When no GPS signal is available, Vision Positioning 

technology provides hovering precision.

 Model: T600

 Weight: 2.9 kg (6.4 lbs)

 Max climb: 5 m/s (16 fps)

 Max speed: 22 m/s (49 mph)

 Max wind speed resistance: 10 m/s (22 mph)

 Max flight time: ~18 minutes

 Operating Frequency: 5.725 - 5.825 GHz, 2.400 - 2.483 GHz

 Battery: 4500 mAh LiPo 65 high voltage battery, and 5700 mAh

 Features: Auto-Takeoff and Landing, Failsafe mode (Return To Home if remote control signal is 

lost more than 3 seconds), Low Battery Return Home mode, Dynamic Home Point mode, 

Intelligent Orientation Control, Flight Recorder.
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DJI Phantom

The DJI Phantom Pro is a quadcopter capable of capturing 4K video and transmitting real time HD video 

signal to a device. When no GPS signal is available, Vision Positioning technology provides hovering 

precision.

 Model: Phantom 3 Pro

 Weight: 1.3 kg (2.9 lbs)

 Max climb: 5 m/s (16 fps)

 Max speed: 16 m/s (35 mph)

 Max flight time: ~23 minutes

 Operating Frequency: 2.400 - 2.483 GHz

 Battery: 4480 mAh LiPo 45

 Features: Auto-Takeoff, Failsafe mode (Return To Home if remote control signal is lost more 

than 3 seconds), Low Battery Return Home mode, Flight Recorder.

DJI Spreading Wings

The DJI Spreading Wings is an octocopter with a large carrying capacity that can handle a DSLR camera. 

Retractable landing gear and low gimbal mounting enable a wide range of shooting angles and camera 

motions.

 Model: S1000+

 Weight: 4.4 kg (9.7 lbs)

 Weight with Payload: 6.2 kg - 11.0 kg (13.7 – 24 lbs)

 Max climb: 6 m/s (19 fps)

 Max speed: 16 m/s (35 mph)

 Max flight time: ~18 minutes

 Operating Frequency: 30 Hz - 450 Hz

 Battery: 10,000 – 20,000 mAh LiPo 65

3DRobotics Solo

The 3DRobotics Solo is a quadcopter that can control a GoPro camera during flight.

 Model: Solo

 Weight: 3.9 lbs with gimbal and GoPro camera

 Range: 0.5 miles

 Max Speed: 55 mph

 Max Ascent: 10 m/s (32 fps)

 Flight Time: 20 minutes with payload

 Frequency: 2.4 GHz

 Battery: 5200 mAh LiPo

3DRobotics X8

The 3DRobotics X8 is a quadcopter with camera and controller designed to create high resolution visual 

spectrum aerial maps. It offers low flying and high accuracy mapping with a fully redundant propulsion 

system for increased reliability.
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 Model: X8-M

 Weight: 3.5 kg (7.7 lbs)

 Range: 0.6 miles

 Recommended Speed: 11 mph

 Max wind speed: 25 mph

 Flight time: 14 min

 Frequency: 915 mHz or 433 mHz

 Battery: 4S 10,000 mAh 10C LiPo

 Payload capacity: 200 g (0.4 lbs)
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Appendix	A

Flight	Operations	Manual

The following steps are to be performed on every flight.

Preparation for flight

1) Ensure firmware version is up to date 

2) Ensure maintenance has been completed and aircraft is cleared to fly

3) Plan area of flight and ensure area is clear of obstacles and people

4) Obtain permission from land owner of area of flight

5) Before each flight complete a Pre-Flight Inspection

6) Set max height and radius limits on aircraft

7) Set home position at lowest ground elevation in flight area

8) Perform Flight Test

Pre-Flight Inspection (specifically DJI Inspire)

1) Remote controller, aircraft battery and mobile device are fully charged

2) Propellers are mounted correctly and firmly.

3) Micro-SD card has been inserted

4) Gimbal is functioning normally

5) Motors can start and are functioning normally

6) DJI Pilot app is connected to the aircraft

Flight Test (specifically DJI Inspire)

1) Place the aircraft on open, flat ground with battery indicators facing toward you.

2) Power on the remote controller and the mobile device, then the Intelligent Flight Battery.

3) Launch the DJI Pilot App and enter the Camera page.

4) Wait until the Aircraft Indicator blinks green. This means the Home Point is recorded and it is safe to 

fly. If it flashes yellow, it means Home Point is not recorded, and you should not take off.

5) Push the throttle up slowly or use Auto Take-off to take off.

6) Shoot photos and videos using the DJI Pilot app.

7) Land – hover over a level surface and pull down on the throttle slowly to descend.

8) After landing, execute the CSC command or hold the throttle at its lowest position for 3 seconds or 

more until the motors stop.

9) Turn off the Intelligent Flight Battery first, followed by the Remote Controller.

Flight and Post Flight

1) Perform flight following the UA’s Operation Manual

2) After landing, execute the CSC command or hold the throttle at its lowest position for 3 seconds or 

more until the motors stop.

3) Turn off the Intelligent Flight Battery first, followed by the Remote Controller.

4) Restore flight area to same condition as before the flight

5) Record flight time and maintenance needs in the UA’s logbook

6) Perform minor maintenance or send UA to manufacturer for repair