October 21, 2014 

United States Department of Transportation 

Docket Operations 

1200 New Jersey Ave.SE 

West Building Ground Floor Room W12-140 

Washington DC 20590 

Re: Exemption Request Pursuant To Section 3 3 3 of the FAA Reform Act of 2012 

Dear Sir or Madam: 

I am writing pursuant to the FAA Modernization and Reform Act of2012 (the "Reform Act") 

and the procedures contained in 14 C.F .R. 11, to request that Drone Zone LLC, an owner and operator 

of small unmanned aircraft, be exempted from the Federal Aviation Regulations (FAR's) listed below 

so that Drone Zone, may operate its small unmanned aircraft/lightweight unmanned aircraft systems 

(UAS) commercially in airspace regulated by the Federal Aviation Administration (FAA); as 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. 

As identified and described herein, Scott Zimmerman, and his company Drone Zone LLC, is an 

experienced, licensed, and insured RIC model pilot (25yrs) and comes from a family of pilots. His 

Father, a pilot with the Minnesota DOT, and Uncle a retired commercial pilot with United Airlines. 

With this background, Scott Zimmerman has a full and unique understanding of the safety precautions, 

and laws that must be observed and adhered to. 

Drone Zone LLC has been actively involved in the technical development ofUASIUAV 

service applications to provide high definition film quality by aerial cinematography with small, 

unmanned aircraft and lightweight UASs.lt is currently one of the very few companies that is 

developing advanced technical applications and abilities for future commercial service applications. 

Drone Zone LLC has fully equipped each of its small unmanned aircraft for aerial photography and 

cinematography. Through given their stability and maneuverability, they may be used for other 

cinematography, by law enforcement personnel, search and rescue and by other first responders. 

To Date, Drone Zone LLC has rejected all offers to work with film, television, commercial 

television production companies and directors on locations within the United States to ensure it is in 

compliance with any applicable FARs. It, like other applicants, has done so despite Judge Patrick G. 

1 
October 21, 2014 

Geraghty's decision in the Rapheal Pirker matter and his reasoning that no FARs prohibits the use of 

small unmanned aircraft or lightweight UASs like those flown by other peer companies. 

Drone Zone LLC exemption request would permit its operation of lightweight, unmanned 

(remotely controlled in line of sight) UASs in tightly controlled and limited airspace. Predetermined, 

specifically marked areas of operation cordoned off locations and corresponding enhancements to 

current safety controls will allow Drone Zone LLC to operate within current safety parameters and new 

ones being implemented. As identified, similar lightweight, remote controlled UASs are legally 

operated by amateurs with no flight experience, safety plan or controls in place to prevent catastrophe. 

Drone Zone LLC is developing a state-of-the art client website application to monitor, evaluate and 

implement all aerial cinematography activities with a pre-flight safety and flight plan system. 

Granting Drone Zone LLC request comports with the Secretary of Transportation's (FAA 

Administrator's) responsibilities to not only integrate UASs into the national airspace system, but to 

" ... establish requirements for the safe operation of such aircraft systems (UASs) in the national 

airspace system" under Section 333© of the Reform Act. Further, Drone Zone LLC will conduct its 

operations in compliance with the protocols described herein or as otherwise established by the FAA. 

Drone Zone LLC respectfully requests the grant of an exemption allowing it to operate 

lightweight, remote controlled UAS's. 

The Specific Sections of Title 14 of Federal Regulations, Drone Zone LLC requests exemption are: 

14 CFR 21; 14 C.F.R. 45.23(b); 14 CFR 61.113(a) & (b); 14 C.F.R. 91, et seq; 14 CFR 407 (a) (I); 14 

CFR 409 (a) (2); and, 14 CFR 417 (a) & (b). 

Exemption Request Section 333 ofthe FAA Reform Act and Part 11 ofthe Federal Aviation 

Regulations from 14 C.F.R. 45.23(b); 14 CFR Part 21;14 CFR 61.113 (a) & (b); 91.7 (a); 91.9 (b) (2); 

91.103 (b); 91.109;91.119; 91.121;91.151(a);91.203(a) & (b);91.405 (a); 91.407(a) (1); 91.409 (a) 

(2);91.417 (a) & (b). 

The Extent of Relief Drone Zone Services Seeks and the Reason it seeks Such Relief: 

Drone Zone LLC submits this application in accordance with the Reform Act, 112 P.L. 95 ss 

331-334, seeking relieffrom any currently applicable FARs operating to prevent Drone Zone LLC 

contemplated commercial cinematic, research and other flight operations within the national airspace 

system. There Reform Act in Section 332 provides for such integration of civil unmanned aircraft 

systems into our national airspace systems into our national airspace system as it is in the public's 

interest to do so. Drone Zone LLC lightweight UASs meet the defmition of "small unmanned aircraft: 

as defmed in Section 331 and therefore the integration ofNetwork Media Services lightweight UASs 

are expressly contemplated by the Reform Act, Network Media Services would like to operate its 

lightweight UASs prior to the time period by which the Reform Act requires the FAA to promulgate 

rules governing such craft. 

2 
October 21, 2014 

The Reform Act guides the Secretary in determining the types ofUASs that may operate safely in our 

national airspace system. Considerations include: 

The weight, size, speed and overall capabilities of the UAS; Whether the UAS will be operated 

near airports or populated areas; and, Whether the UAS will be operated by line of sight. 

112 P.L. 95 s 333 (a). Each of these items militates in favor or an exemption for Network Media 

Services. 

Drone Zone LLC UASs utilizes three to four counter-rotating propellers for extreme balance, 

control and stability. They each weigh less than 55 pounds, including cinematic or other equipmen. 

Each of Drone Zone LLC small unmanned aircraft are designed to primarily hover in place and operate 

at less than a 50 knot maximum speed. They are capable of vertical and horizontal operations but 

operate only wihin the line of sight of the remote control pilot. In addition to the remote control pilot, 

Drone Zone LLC uses a spotter and a technician, such that, at minimum, three Drone Zone LLCs 

personnel govern the safe flight of an Drone Zone LLC aircraft at all times. 

Utilizing battery power and not combustible fuels, flights generally last between five and 

twenty minutes. Drone Zone LLC des not operate its UASs with less than twenty five percent battery 

capacity. Safety systems in place include a GPS mode that allows Drone Zone LLC UASs to hover in 

place if communication with the radio control pilot is lost and then slowly descend the UAS at twenty 

five percent battery capacity. Further, Drone Zone LLC fleet is programmed, in some instances, to 

slowly follow a predetermined set ofwaypoints to return to a safety point if communications are lost. 

Drone Zone LLC does not operate its UASs near airports and generally does not operate them 

near populated areas. The UAS operating software and GPS navigation systems do not allow any of the 

Drone Zone LLC UAS vehicles to operate near airports or restricted fly zones. The failsafe software 

will disable the UAS vehicles from taking off and also limit the fly zones. The failsafe software will 

disable the UAS vehicles from taking off and also limit the UAS systems from operating within 

specific GPS present no-fly zones. To date, Drone Zone LLC has only operated its fleet on private 

property cordoned off areas under the control of Drone Zone LLC clients. Drone Zone LLC only 

operates its UASs in predetermined areas and only in compliance with well-regarded safety protocols. 

Drone Zone LLC operation of its fleet of small unmanned aircraft will not "create a hazard to 

users of the national airspace system or the public." 112 P.L. 95 s 333 (b). Given the small size and 

weight of Drone Zone LLC UASs, combined with their operation in cordoned off and well-controlled 

areas, Drone Zone LLC fleet falls within Congress;;s contemplated safety zone when it promulgated 

the Reform Act and the corresponding directive to integrate UASs into the national airspace system. 

Indeed, Drone Zone LLC UASs have a demonstrable safety record and do not pose any threat to the 

general public or national security. 

The FAA has the authority to issue the exemption to Drone Zone LLC pursuant to the Federal 

Aviation Ace, 85 P. L. 726 (1958), as amended (the "Act"). Commercial and Public Benefits. 

3 
October 21, 2014 

Granting Drone Zone LLC exemption request furthers the public interest. First, Congress has 

already pronounced that it is in the public's interest to integrate commercially flown UASs into the 

national airspace system, hence the passing of the Reform Act. Second, Drone Zone LLC conducts 

research into safe UAS operations every time it flies one of its UASs. Flight data, visual inspections, 

recorded observations and flight analyses are compiled to further enhance current safety protocols. 

Allowing Drone Zone LLC to log more flight time directly relates to its research and its ability to 

further enhance current safety measures. Third, the public has an interest in reducing the danger and 

emission associated with current aerial capture methods, namely, full size helicopters. Drone Zone 

LLC UASs are battery powered and create no emissions. If a Drone Zone LLC lightweight UASs is far 

less than a full size helicopter, notwithstanding the statistically noteworthy safety record of full size 

helicopters. Drone Zone LLC UASs are battery powered and create no emissions. If a Drone Zone LLC 

crashes there is no fuel to ignite and explode. The impact of Drone Zone LLC lightweight UASs is far 

less than a full size helicopter, notwithstanding the statistically noteworthy safety record of full size 

helicopters used in aerial photography. The public's interest is furthered by minimizing ecological and 

crash impacts by permitting aerial photography through Drone Zone LLC lightweight UASs. 

Progression of the arts and sciences has been fundamental to our society since its inclusion in 

the United States Constitution. Indeed, Congress mandates the integration ofUASs into our national 

airspace system, in part, to achieve progression in the noteworthy, and inevitable, field. Permitting 

Drone Zone LLC to immediately fly within the United States furthers these goals. Whether it is the 

amalgam of scientific discoveries applicable to feature film making (including those drawing upon 

architecture, physics, engineering and cultural inclusiveness) to advancements in publicly usable 

technologies or advancements in equipment available to law enforcement personnel/first responders 

that does not cost millions of dollars, granting Drone Zone LLC exemption request substantially 

furthers the public's interest in ways known and currently unknown. 

4 
October 21, 2014 

Reasons Why Drone Zone LLC Exemption Will Not Adversely Affect Safety or How the Exemption 

Will Provide a Level of Safety at Least Equal to Existing Rule: 

Drone Zone LLC exemption will not adversely affect safety. Quite the contrary, for the reasons 

stated, supra, permitting Drone Zone LLC to log more flight time in FAA controlled airspace will allow 

Drone Zone LLC to innovate and implement new and as of yet undiscovered safety protocols. In 

addition, Drone Zone LLC submits the following representations of enhancements to current aerial 

picture capture techniques: 

• Drone Zone LLC UASs weigh less than 55 pounds complete with digital cameras 

• Drone Zone LLC only operates its UASs below 400 feet; 

• Drone Zone LLC UASs only operate for 5-25 minutes per flight; 

• Drone Zone LLC lands its UASs when they reach 25% battery power; 

• Drone Zone LLC remote control pilots operate Drone Zone LLC UASs by line of sight; 

• Drone Zone LLC remote control pilots have video backup should they somehow lose 

sight of the UAS; 

• Drone Zone LLC staffs each flight with a remote control pilot technician and spotter 

with communication systems enabling real time communication between them; 

• Drone Zone LLC UASs have GPS flight modes whereby they hover and then slowly 

land if communication with the remote control pilot is lost or battery power is below 

25% 

• Drone Zone LLC actively analyses electronic flight data and other sources of 

information to constantly update and enhance safety protocols; 

• Drone Zone LLC only operates in secured areas that are strictly controlled, are away 

from airports and populated areas; 

• Drone Zone LLC conducts extensive briefmgs prior to flight, during which safety 

carries primary importance; 

• Drone Zone LLC always obtains all necessary permission and permits prior to 

operation; and, Drone Zone has procedures in place to abort flights in the event of 

safety breaches or potential danger. 

5 
October 21, 2014 

Drone Zone LLC provides a level of safety at least equal to existing rules, and in nearly every 

instance, greater than existing rules. It is important to note that absent the integration of commercial 

UASs into our national airspace system, helicopters are the primary means of aerial photography. 

While the safety record of such helicopters is remarkably astounding, it is far safer to operate a battery 

powered lightweight USAS. First, the potential loss of life is diminished because UASs carry no people 

of board and Drone Zone LLs only operates them in specific areas away from mass populations. 

Second, there is no fuel on board a UAS and thus the potential for fire explosions is greatly diminished. 

Third, the small size and extreme maneuverability of Drone Zone LLs UASs allow our remote control 

pilots to avoid hazards. Lastly, given their small size and weight, even when close enough to capture 

amazing images, Drone Zone LLC UASs need not be so close to the objects they are focused on. 

Accordingly, Drone Zone LLC UASs have operated and will continue to operate at an above current 

safety levels. 

A summary The FAA May Publish in the Federal Register: 

A. 14 C.F.R. 21 and 14 C.F.R. 91; Airworthiness Certificates, Manuals and The like. 

14 C.F.R. 21, Subpart H, entitled Airworthiness Certificates, sets forth requirements for 

procurement of necessary airworthiness certificates in relation to FAR s 91.203(a){l). The size, 

weight and enclosed operational area of Drone Zone LLC UASs permits exemption from Part 

21 because Drone Zone LLC UASs meet an equivalent level of safety pursuant to Section 333 

of the Reform Act. The FAA is authorized to exempt aircraft from the airworthiness certificate 

requirement under both the Act (49 U.S.C. s 44701 (f)) and Section 333 of the Reform Act. 

Both pieces oflegislation permit the FAA to exempt UASs from the airworthiness certificate 

requirement in consideration of the right, size, speed, maneuverability and proximity to areas 

such as airports and dense populations. Drone Zone LLC UASs meet to exceed each of the 

elements. 

6 
October 21, 2014 

14 C.F.R. 91.7(a) 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 C.F.R. s 91.9(b )(2) requires an aircraft flight manual in the aircraft. As there are no pilots or 

passengers, and given the size of the UASs this Regulation is inapplicable, An equivalent level 

of safety will be achieved by maintaining a manual at the flight operations center. The FAA has 

previously issues exemptions to the regulation in Exemption Nos. 8607, 8737, 8738, 9299, 

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

B. 14 C.F.R. s 45.23: Marking of The Aircraft 

Applicable codes of Federal Regulation require aircraft to be marked according to certain 

specifications. Drone Zone LLC UASs are, by defmition, unmanned. They therefore do not have a 

cabin, cockpit or pilot station on which to mark certain words or phrases. Further, two-inch lettering is 

difficult to place on such small aircraft. Regardless, Drone Zone LLC will mark its UASs in the largest 

possible lettering by placing the work "EXPERIMENTAL" on its fuselage as required by 14 C.F.R. s 

45.29(t) so that the pilot, technician, spotter and others working with the UAV will see the markings. 

The FAA has previously issues exemptions to this regulation through Exemptions Nos. 8738, 10167, 

10167A and 10700. 

C. 14 C.F.R s 61.113: Private Pilot Privileges and Limitations: PIC 

Pursuant to 14 C.F .R. ss 61.113 (a) & (b), private pilots are limited to non-commercial operations. 

Drone Zone LLC can achieve an equivalent level of safety as achieved by current Regulations 

because Drone Zone LLC UASs do not carry any pilots or passengers. Further, while helpful, a 

pilot license will not ensure remote control piloting skills, though Drone Zone LLC pilot vetting 

and training programs will. Further, private pilot licensees will operate Drone Zone LLC UASs 

with the same skill. Further, the risks attendant to the operation of Drone Zone LLC UASs is far 

less than the risk levels inherent in the commercial activities outlines in 14 C.F.R. s 61, et seq. 

Thus, allowing Drone Zone LLC to operate its UASs with a private pilot as the pilot in control will 

exceed current safety levels in relation to 14 C.F.R. s 61.113(a) & (b). 

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

7 
October 21, 2014 

14 C.F.R. 91.119 prescribes safe altitudes for the operation of civil aircraft. It allows helicopters to 

be operated at lower altitudes in certain conditions. Drone Zone LLC UASs will never operate at an 

altitude greater than 400 AGL. Drone Zone LLC will, however, operate its UASs in cordoned off areas 

with security providing a level of safety at least equivalent to those in relation to minimum safe 

altitudes. Given the size, weight, maneuverability and speed of Drone Zone LLC UASs, an equivalent 

level of safety will be achieved. 

E. 14 C.F.R 91.405 (a); 407 (a) (1);409 (a) (2);417 (a)&9b): Maintenance Inspections. 

The above-cited regulations require, amongst other things, aircraft owner and operators to have [the] 

aircraft inspected as prescribed in subpart E of this part and shall betwen required inspections, except as 

provided in paragraph ( c) of this section, have discrepancies repaired as prescribed in par t43 of this 

chapter. 

These regulations only apply to aircraft with an airworthiness certificate. They will not, therefore, apply 

to Drone Zone llc should its requested exemption be granted. Drone Zone conduct an extensive 

maintenance program that involves regular software updates and constant inspection for assessment of 

any damaged hardware. Therefore, an equivalent level of safety will be achieved. Drone Zone has 

researched and developed it's own designs. 

F. Summary 

Drone Zone llc. seeks an exemption from the following regulations: 14 C.F.R. 21, subpart H; 14 

C.F.R45.23(b); 14 C.F.R. §§ 61.113 (a) & (b); 14 C.F.R. § 91.7 (a); 14 C.F.R. § 91.9 (b)(2); 14 C.F.R. 

§ 91.103(b); 14 C.F.R. § 91.109; 14 C.F.R. § 91.119; 14 C.F.R. § 91.121; 14 C.F.R. § 91.151(a) 14 

C.F.R §§ .91.203 (a) & (b); 14 C.F.R. § 91.405 (a); 14 C.F.R. § 91.407(a)(1); 14 C.F.R. §91.409(a)(2); 

14 C.F.R. § and, 14 C.F.R. §§ 91.4179(a) & (b) to commercially operate its fleet of small, light, 

unmanned aircraft for the purposes of aerial photography/video, and to conduct its own research, and 

develop platforms for first responders,search and rescue. 

Granting Drone Zone llc. request for exemption will reduce current risk levels and thereby enhance 

public safety. Currently the aerial photography industry relies primarily on the use on full scale, large 

aircraft running on combustible fuel. Drone Zone llc. craft do not contain potentially explosive fuel, 

are smaller, lighter, and more maneuverable than conventional aerial camera platforms. Further, Drone 

Zone llc. operated at lower altitudes and in controlled airspace. Drone Zone llc. has been analyzing 

8 
October 21, 2014 

flight data and other information in compiling novel saftey protocols and the implementation of a flight 

operations manual that exceeds currently accepted means and methods of safe flight. 

There are no people on board Drone Zone llc. UA V's and therefore the likelihood of death or serious 

bodily injury is significantly limited. Drone Zone llc. UA V's weigh less than 55 lbs. and travel at 

speeds less than 50 knots in cordoned off areas will provide at least an equivalent level of safety as that 

achieved under current F ARs. 

Drone Zone llc. Respectfully requests that the FAA grant its exemption request without delay. The 

FAA has the authority to issue the exemption sought by Drone Zone llc pursuant to the Federal 

Aviation Act, 85 P.L. 726 (1958), as amended (the "act") 

Sincerly, 

z~~ Scott Zimmerman 

Drone Zone llc. 

1980 Hoyt Ave. E. 

St. Paul, MN. 55119 

9