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Mark Corralez

Chief Technology Officer

1008 Wade Avenue

Nashville, Tennessee 37203

T: (615) 596-4422

info@nashvilledrones.com

 June 25, 2015

U. S. Department of Transportation

Docket Management System

1200 New Jersey Ave., SE

Washington, DC 20590

Re: Exemption Request Section 333 of FAA Reform Act and Title 14, Code of Federal

Regulations (14 CFR): §§ 61.113(a) and (b); 91.119; 91.121; 91.151(a); 91.405(a);

91.407(a)(1); 91.409(a)(2); and 91.417(a) and (b)

Dear Sir or Madam:

Pursuant to 14 CFR part 11 and Section 333 of the FAA Modernization and Reform Act of 2012 (“the Reform 

Act”), Nashville Drones Aerial Asset Resources (referred to herein as “Applicant”), developer and operator of small

Unmanned Aircraft Systems (“sUASs”) equipped to conduct aerial photography/filming operations for a range of 

business including insurance, real estate, agriculture, infrastructure inspection, and motion picture and television 

production, hereby applies for an exemption from the listed Federal Aviation Regulations (“FARs”) to allow 

commercial operation of its sUAS, 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.

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, 3) controlled as to access, and 4) would provide safety 

enhancements to the already safe businesses presently using conventional aircraft. Approval of this exemption 

would thereby enhance safety and fulfill the Secretary of Transportation’s (the FAA Administrator’s) 

responsibilities to “...establish requirements for the safe operation of such aircraft systems in the national airspace 

system,” Section 333(c) of the Reform Act.

The name and address of the Applicant is:

Nashville Drones Aerial Asset Resources

1008 Wade Avenue

Nashville, Tennessee 37203

(615) 596-4422

info@nashvilledrones.com 

The Applicant requests exemption under the following Regulations:
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14 CFR §61.113(a) and (b)

14 CFR § 91.119

14 CFR § 91.121

14 CFR § 91.151(a)

14 CFR § 91.405(a)

14 CFR § 91.407(a)(1)

14 CFR § 91.409(a)(2)

14 CFR § 91.417(a) and (b)

This exemption application is expressly submitted to fulfill Congress’ goal in passing Section 333(a) through (c) of 

the Reform Act. This law directs the Secretary of Transportation to consider whether certain unmanned aircraft 

systems may operate safely in the national airspace system (NAS) before completion of the rulemaking required 

under Section 332 of the Reform Act. In making this determination, the Secretary is required to determine which 

types of unmanned aircraft system(s) (UASs) do not create a hazard to users of the NAS or the public or pose a 

threat to national security in light of: 1) the sUAS’s size, weight, speed, and operational capability; 2) operation of 

the sUAS in close proximity to airports and populated areas; and 3) operation of the sUAS within visual line of sight 

(VLOS) of the operator.

If the Secretary determines that such vehicles “may operate safely in the national airspace system, the Secretary 

shall establish requirements for the safe operation of such aircraft in the national airspace system.” Reform Act § 

333(a) and (c). 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, which 

includes sUAS, from the requirement that all civil aircraft must have a current airworthiness certificate.

The Administrator may grant an exemption from a requirement of a regulation prescribed under subsection (a) or (b) 

of this section or any sections 44702-44716 of this title if the Administrator finds the exemption in the public 

interest, 49 United States Code (U.S.C.) § 44701(f). See also 49 U.S.C. § 44711(a), 49 U.S.C. § 44704, and 14 CFR 

§ 91.203(a)(1).

Nashville Drones Aerial Asset Resources’s sUAS is a rotorcraft, weighing 55 pounds or less including payload. It 

operates at an air speed of no more than 55 knots and has the capability to hover and move in the vertical and 

horizontal planes simultaneously. It will be operated only within VLOS of the operator and will operate only within 

a secured area to ensure that the sUAS will “not create a hazard to users of the national airspace system or the 

public,” Reform Act, Section 333(b).

Given the small size of the sUAS at issue and the secured environment within which it will operate, the applicant 

falls within that zone of safety (an equivalent level of safety) in which Congress envisioned that the FAA should, by 

exemption, allow commercial operations of UASs to commence immediately. Also due to the size of the sUAS and 

the restricted areas in which it will operate, approval of the application

____________________________________________________________________________________

1 Applicant understands that if it satisfies the requirements under Section 333, then there is no need for relief under

14 CFR part 21 (airworthiness certificate), and under 14 CFR §§ 45.23(b) and 91.7(a). Applicant further understands

that operation of sUAS does not require exemptions under 14 CFR § 91.9(b)(2) (civil aircraft marking and manual

requirements) and based on the FAA memorandum “Interpretation regarding whether certain required documents

may be kept on unmanned aircraft’s control station.” If the Administrator determines that the Applicant may be

subject to those requirements, the Applicant reserves the right to supplement this request.
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presents no national security issue. Given the clear direction in Section 333 of the Reform Act, the authority 

contained in the Federal Aviation Act as amended, the equivalent level of safety surrounding the proposed aerial 

photography/filming operations, and the significant public benefit, including enhanced safety, reduction in 

environmental impacts such as reduced emissions associated with allowing UASs for operations currently performed 

by larger manned aircraft, granting of the requested exemptions is in the public interest. Accordingly, Applicant 

respectfully requests that the FAA grant the requested exemption without delay.

Specific regulations for which relief is sought by the Applicant:

14 CFR § 61.113(a) and (b) Private Pilot Privileges and Limitations: Pilot in Command (PIC)

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 this sUAS. Unlike a conventional aircraft that carries the pilot and passengers, this sUAS is remotely 

controlled with no living thing on board. The area of operation is controlled and restricted, and all flights are 

planned and coordinated in advance as set forth in the General Operations Manual (GOM). The level of safety 

provided by the requirements included in the GOM and Aircraft Flight Manual (AFM) exceeds that provided by a 

single individual holding a commercial pilot’s certificate operating a conventional aircraft. The risks associated with 

the operation of the sUAS are so diminished from the level of risk associated with commercial operations 

contemplated by part 61 when drafted, that allowing operations of the sUAS as requested with a private pilot as the 

PIC exceeds the present level of safety achieved by 14 CFR § 61.113(a) and (b).

14 CFR § 91.119 Minimum Safe Altitudes

Section 91.119 establishes safe altitudes for operation of civil aircraft. Section 91.119(d) allows helicopters to be 

operated at less than the minimums prescribed, provided the person operating the helicopter complies with any route 

or altitudes prescribed for helicopters by the FAA. As this exemption request is for a sUAS that is a helicopter and 

requests the authority to operate at altitudes up to 400 feet above ground level (AGL), or for filming operations not 

more than 200 feet above an elevated platform from which filming is planned, an exemption may be needed to allow 

such operations. As set forth herein, except for the limited conditions stated in the GOM, the sUAS will never 

operate at higher than 400 feet AGL. It will be operated in a restricted area with security perimeter, where buildings 

and people will not be exposed to operations without their 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 will be operated. No flight will be taken without the permission of the property owner or local officials. 

Because of the advance notice to the property owner and participants in the aerial photography/filming operations 

area, all affected individuals will be aware of the planned flight operations as set forth in the GOM. Compared to 

flight operations with aircraft or rotorcraft weighing far more than the maximum 55 pounds proposed herein and the 

lack of flammable fuel, any risk associated with these operations is far less than those presented with conventional 

aircraft operating at or below 400 feet AGL. In addition, the low-altitude operations of the sUAS will help ensure 

separation between these aerial photography/filming operations and the operations of conventional aircraft that must 

comply with Section 91.119.

14 CFR § 91.121 Altimeter Settings

This regulation 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 the sUAS does not have a barometric altimeter, but instead a GPS altitude readout, an exemption may be needed. 
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An equivalent level of safety will be achieved by the operator, pursuant to the GOM and AFM, confirming the

altitude of the launch site shown on the GPS altitude indicator before flight.

14 CFR § 91.151(a) Fuel Requirements for Flight in Visual Flight Rules (VFR) 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; or 2) at night, to fly 

after that for at least 45 minutes.”

The battery powering the Applicant’s sUAS provides approximately 40 minutes of powered flight. To meet the 30-

minute reserve requirement in 14 CFR § 91.151, sUAS flights would be limited to approximately 10 minutes in 

length. Given the limitations on the sUAS’s proposed flight area and the location of its proposed aerial 

photography/filming operations within a predetermined area, a longer time frame for flight in daylight or VFR 

conditions is reasonable.

Applicant believes that an exemption from 14 CFR § 91.151(a) falls within the scope of prior exemptions. See 

Exemption 10673 (allowing Lockheed Martin Corporation to operate without compliance with FAR 91.151(a)). 

Operating the sUAS in a tightly controlled area where only people and property owners or official representatives 

who have signed waivers will be allowed, with less than 30 minutes of reserve fuel, does not present the type of 

risks that Section 91.151(a) is intended to alleviate given the size and speed of the sUAS. Additionally, limiting 

sUAS flights to 10 minutes would greatly reduce the utility for the aerial photography/filming operations for which 

the exemption is sought.

Applicant submits that an equivalent level of safety can be achieved by limiting flights to 30 minutes or 25 percent 

of battery power, whichever happens first. This restriction would be adequate to return the sUAS to its planned 

landing zone from anywhere in its limited operating area. Similar exemptions have been granted to other operations, 

including Exemptions 2689F, 5745, 10673, and 10808.

14 CFR §§ 91.405(a); 91.407(a)(1); 91.409(a)(2); 91.417(a) and (b) Maintenance Inspections

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 to the Applicant. Maintenance will be accomplished by the operator pursuant to the AFM and GOM. As 

provided in the GOM, 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.

Limitations and conditions to which Nashville Drones Aerial Asset Resources agrees to be bound when conducting 

commercial sUAS operations under the requested exemption include those listed below:

AIRCRAFT

1. Operations authorized by this grant of exemption are limited to the following aircraft described in the attached 

AFM: DJI Phantom 3 - Proposed operations of any other aircraft will require a new petition or a petition to amend 

this grant.
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2. The sUAS will weigh less than 55 pounds (25 kg), including energy source(s) and equipment.

3. All aircraft operated in accordance with this exemption will be identified by serial number, registered in 

accordance with 14 CFR part 47, and have identification (N-Number) markings in accordance with 14 CFR part 45, 

subpart C. Markings will be as large as practicable.

4. The sUAS may not be flown at an airspeed exceeding 55 knots.

5. The sUAS will be programmed to return to a predetermined location within the Security Perimeter to land or be 

recovered in the event manual control is lost.

MANUALS

1. The AFM and GOM will be maintained and made available to the Administrator upon request. If a discrepancy 

exists between the conditions and limitations in this exemption and the procedures outlined in either of those 

documents, the conditions and limitations herein take precedence and must be followed. Otherwise, Nashville 

Drones Aerial Asset Resources will follow the procedures as outlined in the AFM and GOM.

2. Nashville Drones Aerial Asset Resources will track revisions to the AFM and GOM and present updated and 

revised documents to the Administrator upon request. It will also present updated and revised documents if we 

petition for extension or amendment. If it determines that any update or revision would affect the basis for which the 

FAA granted this exemption, then it will petition for amendment to the exemption. The FAA’s UAS Integration 

Office (AFS-80) will be contacted if questions arise regarding updates or revisions to the AFM and GOM.

CREW

1. Minimum crew for each operation will consist of pilot, visual observer (VO), and / or the camera operator. The 

VO may be used to satisfy the VLOS requirement as long as the PIC always maintains VLOS capability. The VO 

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

2. The PIC will possess at least a private pilot certificate and at least a current third-class medical certificate. The 

PIC will also meet the flight review requirements specified in 14 CFR § 61.56 in an aircraft in which the PIC is rated 

on his or her pilot certificate. Prior to conducting commercial aerial photography/filming operations, the PIC will 

have accumulated and logged, in a manner consistent with 14 CFR § 61.51(b), a minimum of 25 hours of total time 

as a UAS rotorcraft pilot and at least 10 hours logged as a UAS pilot with a similar UAS type.

3. Prior to conducting commercial aerial photography/filming flight operations, the PIC will be required to have 

accumulated and logged, in a manner consistent with 14 CFR § 61.51(b), a minimum of five hours as an UAS pilot 

operating the make and model of UAS to be utilized for operations under the exemption and three takeoffs and three 

landings in the preceding 90 days.

4. During training, proficiency, experience-building, and takeoff and landing currency flights, all persons not 

essential for flight operations will be considered nonparticipants, and the PIC will be required to operate the sUAS 

with appropriate distance from nonparticipants in accordance with 14 CFR § 91.119.

5. Prior to any commercial aerial photography/filming flight operations, the crew will have successfully completed 

the qualification process detailed in the GOM. As this is a requirement stipulated by Nashville Drones Aerial Asset 

Resources, the test has been developed and implemented by a qualified person designated at the sole discretion of 

Nashville Drones Aerial Asset Resources. A record of completion of this qualification process will be documented 

and made available to the Administrator upon request.
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6. Prior to commercial aerial photography/filming flight operations, a flight demonstration, administered by an 

operator-approved and qualified pilot will be successfully completed and documented. This documentation will be 

available for review upon request by the Administrator. Because the knowledge and airmanship test qualifications 

have been developed by the operator, and there are no established practical test standards that support a 

jurisdictional FAA Flight Standards District Office (FSDO) evaluation and approval of company designated 

examiners, Nashville Drones Aerial Asset Resources will conduct these tests in accordance with the GOM.

7. The documents required under 14 CFR §§ 91.9 and 91.203 will be available to the PIC any time the aircraft is 

operating. These documents will be made available to the Administrator or any law enforcement official upon 

request.

MAINTENANCE

1. If any part of the sUAS has undergone maintenance or alterations that affect operation or flight characteristics, for 

example, replacement of a flight critical component, then the entire sUAS will undergo a functional test flight in 

accordance with the GOM. The PIC who conducts the functional test flight will make an entry in the sUAS aircraft 

records of the flight, as required by the GOM.

2. The AFM will include updated current maintenance procedures, inspection requirements, and life limits for 

aircraft systems including servos, motors, propellers, electronic speed controllers, batteries, and remote control.

3. All technicians performing maintenance and inspection on the sUAS will meet technician qualification criteria 

developed by Nashville Drones Aerial Asset Resources and included in the GOM.

4. Each sUAS operated under this exemption will comply with all manufacturer safety bulletins.

5. The GOM includes procedures to document and maintain a record of the sUAS maintenance, preventative 

maintenance, alterations, status of replacement/overhaul of component parts, and the total time in service of the 

sUAS.

OPERATIONS

1. Prior to each flight, the PIC will inspect the sUAS to ensure it is in a condition for safe flight. If the inspection 

reveals a condition that affects the safe operation of the sUAS, the aircraft is prohibited from operating until the 

necessary maintenance has been performed and the sUAS is found to be in a condition for safe flight. The remote 

control will be included in the preflight inspection. All maintenance and alterations will be properly documented in 

the aircraft records.

2. Flights will be operated at an altitude of no more than 400 feet AGL, except for limited conditions outlined in the 

GOM. All altitudes reported to Air Traffic Control (ATC) will be in feet AGL.

3. The sUAS will be operated within VLOS of the PIC at all times. This requires the PIC to be able to use human 

vision unaided by any device other than corrective lenses, as specified on the PIC’s FAA-issued medical certificate.

4. Before conducting commercial aerial photography/filming flight operations, the radio-frequency spectrum used 

for operation and control of the sUAS will be checked to comply with Federal Communications Commission (FCC)

or other appropriate government-oversight agency requirements.
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5. Regarding distance from nonparticipating persons, the operator will ensure that no persons in open areas are 

allowed within 500 feet of the aircraft except those consenting to be involved and necessary for the aerial

photography/filming operations. If barriers or structures are present that can sufficiently protect nonparticipating 

persons from debris in the event of an accident then the UA may operate closer than 500 feet to persons afforded 

such protection. The operator must ensure that nonparticipating persons remain under such protection. If a situation 

arises where nonparticipating persons leave such protection and are within 500 feet of the UA, flight operations 

must cease immediately.

6. Regarding the distance from participating persons, the GOM has safety mitigations for authorized and consenting 

production personnel. At all times, those persons must be essential to the aerial photography/filming operations. 

Because these procedures are specific to participating persons, no further FSDO or aviation-safety inspector 

approval will be considered necessary for reductions to the distances specified in the GOM, consistent with the 

manned aircraft procedures described in FAA Order 8900.1, V3, C8, S1. 

7. Each sUAS operation will be completed within 30 minutes flight time or with 25% battery power remaining, 

whichever occurs first.

8. The sUAS will remain clear and yield the right of way to all other manned operations and activities at all times 

(including, but not limited to, ultra light vehicles, parachute activities, parasailing activities, hang gliders, etc.).

9. UAS operations will not be conducted during night, as defined in 14 § CFR 1.1. All operations will be conducted 

under visual meteorological conditions (VMC). Flights under special visual flight rules (SVFR) are not authorized.

10. The sUAS will not be operated from any moving device or vehicle.

11. The sUAS will not be operated fewer than 500 feet below or fewer than 2,000 feet horizontally from a cloud or 

when visibility is less than three statute miles from the PIC.

12. The sUAS will not operate in Class B, C, or D airspace without written approval from the FAA. The sUAS will 

not operate within five nautical miles of the geographic center of a non-towered airport as denoted on a current

FAA-published aeronautical chart unless a letter of agreement with that airport’s management is obtained. The letter 

of agreement with the airport management will be made available to the Administrator upon request.

13. The sUAS will only operate only within a confined “Secured Area” as defined in the GOM, which requires the 

establishment of a “Security Perimeter” for the flight operations area.

14. A briefing will be conducted in regard to the planned operation prior to each day’s flight activities. It will be 

mandatory that all personnel who will be performing duties within the boundaries of the safety perimeter be present 

for this briefing.

15. Accidents will be reported to the National Transportation Safety Board (NTSB) per instructions contained on the 

NTSB website: www.ntsb.gov. Further flight operations will not be conducted until the incident, accident, or 

transgression is reviewed by AFS-80 and authorization to resume operations is provided.

16. Unless otherwise specified in this grant of exemption, the sUAS, the sUAS PIC, and the sUAS operations will 

comply with all applicable parts of 14 CFR including, but not limited to, parts 45, 47, 61, and 91.

17. Applicant agrees that failure to comply with any of the conditions and limitations of this grant of exemption will 

be grounds for the immediate suspension or rescission of this exemption.
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*********

Pursuant to 14 CFR 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 CFR §§ 61.113(a) and (b); 91.119; 91.121; 91.151(a);

91.405(a); 91.407(a)(1); 91.409(a)(2), and 91.417(a) and (b) to operate commercially a sUAS (55 pounds or less) in 

aerial photography/filming operations.

Approval of exemptions allowing commercial operations of sUASs will enhance safety by reducing risk.

Conventional manned flight operations, using jet or piston power aircraft, sometimes operate at low in close 

proximity to people and structures; and present the risks associated with vehicles that weigh approximately 6,000 

pounds, carrying large amounts of fuel or other flammable liquid. Such aircraft must fly to and from the job

location. In contrast, a sUAS weighing less than 55 pounds 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 carried to the job location, 

not flown. 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 sUASs, weighing less than 55 pounds, conducted in accordance with the conditions outlined above, 

will provide an equivalent level of safety supporting the grant of the exemptions requested herein. These lightweight 

aircraft operate at slow speeds, close to the ground, and in a secured environment and, as a result, are safer than

conventional operations conducted with helicopters operating in close proximity to the ground and people.

Privacy

All flights will occur over private or controlled-access property with the property owner’s prior consent and 

knowledge. Photography/filming will be of people who have also consented to being photographed or otherwise 

have agreed to be in the area where the aerial photography/filming operations will take place. All operations will be 

compliant with applicable local and state laws.

The Applicant’s request satisfies the criteria set forth in Section 333 of the Reform Act. The size, weight, speed, 

operating capabilities of the sUAS, the limitations on operations proximate to airports and populated areas, and the 

operation within VLOS do not create a hazard to users of the national airspace system and do not pose any national 

security threats or concerns. The foregoing easily meets the criteria for granting the requested exemptions allowing 

commercial operations of Applicant’s sUAS pursuant to the GOM and AFM appended hereto.

Respectfully submitted,

/s/ Mark Corralez

Mark Corralez

Chief Technology Officer

Nashville Drones Aerial Asset Resources
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James F. Gafney III 

Chief Pilot, Nashville Drones

Certificate Number 3037897

Commercial Pilot, Instrument, Helicopter

PO BOX 30453

Clarksville, TN 37040

931.933.3656

james.gafney@gmail.com

US DEPARTMENT OF TRANSPORTATION 25 June 2015

Docket Management System

1200 New Jersey Ave S. E.

Washington, D. C. 20590

Re: Exemption Request Section 333 of FAA Reform Act and Title 14, Code of 

Federal Regulations (14CFR): §§ 61.113(a) and (b); 91.119; 91.121; 91.151(a); 

91.405(a); 91.407(a)(1); 91.409(a)(2); and 91.417(a) and (b)

To Whom it May Concern:

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

Drones, an operator of Small unmanned Aircraft Systems (sUAS) is equipped to film, monitor and observe 

operations in several platforms not limited to, real estate, construction, agriculture, entertainment events, 

scientific events, and safety of operations in industrial environments applies for an exemption under 

Section 333 through the FAA as long as the operations of such vehicles are operated in a safe and 

professional manner, in order to provide a commercial application of services to our future clients.

2. Approval of exemption of Nashville Drones will allow commercial operations of sUASs in rural, remote 

and populated areas, in a safe and professional environment not limited to the purposes listed in paragraph 

1 of this document.

3. The Chief Pilot is a Certified Commercial Pilot, Instrument Rated and a prior helicopter pilot, trained by 

the United States Army and has a second class medical certificate and has more than 1000 flight hours.

4. Drones operated will weigh less than 55lbs, maneuver at speeds less than 50 knots, and have the capability 

to hover in move in the vertical and horizontal plane simultaneously.

5. Drones will have an “auto return to launch point” feature when batter power is less than 25% or 

communication with the drone is lost.
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6. Operation of the sUAS will be done with the knowledge of airspace, TFRs, and FAA regulations regarding 

flight of aircraft working in a cohesive manner with local tower agencies and airfields if necessary.

7. Operation of the sUAS will NOT be operated with the intent to harm or damage personnel, property or 

equipment nor the intent to harass citizens, animals or livestock, NOR will the sUAS be operated in a 

manner to pose a threat to National Security.

8. The FAA has stated a blanket exemption for operations below 200’ AGL.

9. Nashville Drones will operate the sUASs in the following manner:

a. Flights will operate only in daytime hours unless used in an emergency situation (i.e. search and 

rescue) and only done with prior approval of the agency controlling the airspace of operation.

b. Flights will be line of sight with an operator and an observer.

c. Flights will be operated within manufactures specifications.

d. Flights will be below 200’ AGL or with approval of agency controlling the airspace of operation.

e. sUAS will be 55 lbs or less.

f. All necessary FAA clearances will be obtained and distances from airfields strictly observed.

g. Communication will be maintained via voice or two-way communications at all time during 

operations.

h. Flights will operate only in VFR conditions.

i. Pilot and crew will perform a ground walk and map check to ensure all obstacles or noted and 

avoided.

j. sUAS operation above water will ensure flotation devices are installed prior to flight.

k. Flights with pre-approval in controlled airspace will be done with a handheld radio in order to 

monitor air traffic and communicate with control tower and aviators as necessary.

10. Granting Nashville Drones the Exemption 333 will allow for the expansion of UAS systems for safe and 

professional commercial operation.

11. James F. Gafney III, Chief Pilot of Nashville Drones Aerial Asset Resources respectfully requests the FAA 

grant its exception pursuant to the Federal Aviation Act, 85 P.L 726 (1958) as amended (the ACT)
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Glossary of Acronyms

AFM: Aircraft Flight Manual, also known as a Pilot’s Information Manual; a document for a specific make and 

model laid out in the same format familiar to pilots in an FAA-approved PIH, Pilot Information Handbook. The 10 

sections are: 1) General, 2) Limitations, 3) Emergency Procedures, 4) Normal Procedures, 5) Performance, 6) 

Weight and Balance, 7) Airplane and Systems Description, 8) Handling, Servicing, and Maintenance, 9) 

Supplements, and 10) Safety and Operational Tips.

AGL: above ground level; this is one of two ways in which pilots and air traffic control refer to altitude, and it is the 

most useful way for operations close to the ground.

ATC: Air Traffic Control

CFR: Code of Federal Regulations

FARs: Federal Aviation Regulations

FSDO: Flight Standards District Office

GOM: General Operations Manual; a document that details company-wide operating procedures not specific to one 

of the aircraft that company operates. It includes details on company organization, job responsibilities, and 

procedures for training, operating, maintenance, safety, and security.

NAS: national airspace system

NTSB: National Transportation Safety Board

PIC: Pilot in Command

sUAS: small unmanned aerial system, defined as 55 pounds (24 kg) or less

SVFR: special visual flight rules

UAS: unmanned aerial system, includes the ground control equipment as well as the aircraft itself

USC: United States Code

VFR: visual flight rules

VLOS: visual line of sight

VMC: visual meteorological conditions

VO: visual observer