Complete UAS, LLC 11523 Palmbrush Trail Suite 353 Lakewood Ranch, FL 34202

June 8, 2015

U.S. Department of Transportation

Docket Management System

1200 New Jersey Ave. SE 

Washington, DC 20590

Re: Exemption Request Section 333 of the FAA Reform Act

Dear Sir/Madam,

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

C.F.R. Part 11, Complete UAS, LLC (CUAS), a Florida based limited liability company operating Small 

Unmanned Aircraft System (sUAS) equipped to conduct aerial photography and survey for various 

industries, hereby applies for an exemption from the Federal Aviation Regulations (FARs) listed below to 

allow operation of our sUAS commercially in airspace regulated by the Federal Aviation Administration 

(FAA) so long as such operations are conducted with and under the conditions outlined herein or as may

be established by the FAA as required by Section 333. The requested exemption is similar to previous 

FAA issued grants of exemption including but not limited to Exemption Nos. 11062, 11109, 11112, 

11213 and 11295.

Our commercial activities would include:

The requested exemption would permit Complete UAS, LLC to pursue its commercial interests in 

providing services to consumers interested in training, research, and aerial data capture using a small 

advanced sUAS in the following areas:

 Aerial Photography and Videography for the real estate, construction, and utilities industries

 Closed-Set Motion Picture and Television filming

 Agricultural Surveying and Application

 sUAS Operator Training

 Product Demonstrations

 Research and Development

All CUAS sUAS flights that will occur over private or controlled access property will do so with the 

property owner's prior consent and knowledge. Only people who have consented or otherwise have agreed 

to be in the area where photography and videography will take place will be captured in any photos or 

videos.
Complete UAS, LLC 11523 Palmbrush Trail Suite 353 Lakewood Ranch, FL 34202

Additionally, all CUAS pilots will hold an airline transport, commercial, private, recreational, or sport 

pilot certificate and also hold a current FAA airman medical certificate or a valid U.S. driver’s license 

issued by a state, the District of Colombia, Puerto Rico, a territory, a possession, or the Federal 

government. If an observer is not a qualified pilot, they will be trained by CUAS pilots to understand the 

proper roles of an observer, communication procedures, proper visual scan techniques, operations at nontowered airports, and appropriate sections of the Aeronautical Information Manual.

The Petitioner Requests Relief From the following regulations:

Regulations from which the exemption is requested: 14 CFR §§ 61.23(a) and (c), 61.101(e)(4) and (5), 

61.113(a), 61.315(a), 91.7(a), 91.109, 91.119(c), 91.121, 91.151(a)(1), 91.215, 91.405(a), 91.407(a)(1), 

91.409(a)(1) and (2), and 91.417(a) and (b), to the extent necessary to allow CUAS to operate a UAS to 

perform training, research, and aerial data collection.

We are petitioning for exemption to enable CUAS to operate a series of UAS platforms that have been 

previously approved by exemption. Namely:

DJI Phantom 2 - Exemption 11398

DJI Phantom 2 Vision - Exemption 11310

DJI Phantom 2 Vision+ - Exemption 11398

DJI Inspire - Exemption 11398

DJI S1000 - Exemption 11416

DJI S900 - Exemption 11401

DJI S800 - Exemption 11721

Flamewheel 550 - Exemption 11397

3DRobotics IRIS+ - Exemption 11419

DJI Phantom 3 Professional - Similar to Exemption 11310

DJI Phantom 3 Advanced - Similar to Exemption 11398

Q500 Typhoon - Exemption 11703

These sUAS all weigh less than 55 lbs,, have a built- in capability to limit the height flown above the

ground, to limit the radius of the distance it flies from the operator and to exclude it from Class B, C and

D airspace including a no fly zone feature. Each system also has the failsafe function of the autopilot

system, which means when the communication between the Main Controller and the transmitter is lost,

the system will automatically trigger Return to Home and will land safely.

This submission does not include the Operating Manuals for each model requested above, as they have 

been reviewed by the Administrator in granting previous exemptions. Model specifics are listed in the 

CUAS Operating Manual which is included with this submission. Copies of all Operating Manuals for the 

individual models listed will be submitted on request. It should be noted, that while the FAA has not 

previously granted an exemption for the DJI Phantom 3 series, it is an upgraded version of the DJI 

Phantom 2 including components pioneered by DJI with the Inspire 1.
Complete UAS, LLC 11523 Palmbrush Trail Suite 353 Lakewood Ranch, FL 34202

The above specifications meet standards listed below:

• CUAS will only operate its sUAS in line of sight of a pilot and/or observer and will operate at sites 

that are a 'sufficient distance' from populated areas within the sterile area described in the operator’s

manual. Such operations will insure that the sUAS will "not create a hazard to users of the national 

airspace system or the public."

• CUAS will not operate sUAV within 5 nautical miles of an airport reference point (ARP) as denoted 

in the current FAA Airport/Facility Directory (AFD), unless a letter of agreement with that airport’s 

management is obtained or otherwise permitted by a COA issued to CUAS. 

• Maximum flight time for each operational flight will be 60 minutes.

• Flights will be terminated at 25% battery power reserve should that occur prior to the 60 minute limit.

• The sUAV will be programmed so that it will not be operated at an altitude of no more than 400 feet

AGL.

• Minimum crew for each operation will consist of the sUAS Pilot and the Visual Observer.

• The sUAS PIC's (Pilot in Command) will be an airline transport, commercial, private, recreational, or 

sport pilot certificate and also hold a current FAA airman medical certificate or a valid U.S. driver’s 

license issued by a state, the District of Colombia, Puerto Rico, a territory, a possession, or the 

Federal government.

• The sUAS operated by the petitioner weighs less than 55 pounds, including the payload (i.e. camera,

lens, and gimbal).

• The sUAS will operate at speeds of no more than 55 knots.

• Given the small size of the sUAS and the restricted sterile environment within which they will

operate, our sUAS operations adhere to the Reform Act's safety requirements.

Additionally, the fact that the CUAS pilots hold FAA Pilot certificates demonstrates that they have a high 

regard to safe operations with an understanding of FARs, pre-flight inspections, maintenance and repair,

operations within airspace, as well as being trained to high safety standards .

Under the requested exemption, CUAS will ensure that all operators have completed a small unmanned 

aircraft systems (UAS) education and training program including all applicable regulations and guidance

documents; including aeronautical background information such as charts, NOTAMS and Aircraft

Circulars; Radio Communications Procedures; Human Factors and Crew Resource Management; Basic 

Small UAS Aerodynamics; Weather factors; Airmanship and Decision-making and Safe Operating

Procedures.

We respectfully request exemption under Section 333 to enable CUAS to operate safe, low-risk 

commercial sUAV operations for the activities stated. CUAS at all times will respect the space and 

privacy of citizens and property whilst keeping our skies safe.

Exemption Requests and Equivalent Level of Safety

CUAS requests an exemption from the following regulations as well as any additional regulations that

may technically apply to the operation of the sUAV System:
Complete UAS, LLC 11523 Palmbrush Trail Suite 353 Lakewood Ranch, FL 34202

14 CFR 61.23 Medical Certificates

The regulation provides that a person requires a first or second class medical to act as pilot in Command 

of an aircraft for compensation or hire. Our proposed operations require that the PIC must hold a current 

FAA airman medical certificate or a valid U.S. driver’s license issued by a state, the District of Colombia, 

Puerto Rico, a territory, a possession, or the Federal government. Since the aircraft cannot carry

passengers or property, we feel we meet the intent of 61.23 even though the intent of this application is to 

conduct a business.

14 CFR 61.101, 14 CFR 61.113, and 14 CFR 61.315 Pilot privileges and Limitations

The regulation provides that no person that holds a Recreational Pilot, Sport Pilot, or Private Pilot

certificate may act as pilot in Command of an aircraft for compensation or hire. Our proposed operations 

require that the PIC must hold at least airline transport, commercial, private, recreational, or sport pilot 

certificate. Since the aircraft cannot carry passengers or property, we feel we meet the intent of 61.113

Subparagraph (b) even though the intent of this application is to conduct a business.

14 CFR 91.7 Civil Aircraft Airworthiness

This Section 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 91.109 Flight Instruction; Simulated instrument flight and certain flight tests

The regulation states that "No person may operate a civil aircraft that is being used for flight Instruction 

unless that aircraft has fully functioning dual controls." Training will be conducted by Aerial Optics we 

have the ability to provide dual controls utilizing two Spektrum transmitters with a wireless link between 

the transmitters. One transmitter is designated the master transmitter and the other transmitter is 

designated as a slave. The PIC instructor, utilizing the master transmitter, will be at all times be able 

assume control of the sUAS.

14 CFR 91.119 Minimum safe altitudes: General

The regulation states that over sparsely populated areas the aircraft cannot be operated closer than 500 feet

to any person, vessel, vehicle, or structure. Since the typical mission of the sUAS would be photography

or survey of persons, vessels, vehicles or structures it would be necessary to operate closer than 500 feet

to the items listed. Operations will only be flown over property or persons where permission has been 

obtained and careful pre-planned has been performed. The aircraft will be operated at a low altitude 

allowing, if a power unit fails, an emergency landing without undue hazard to persons or property on the 

surface. Therefore we maintain that due to the small size of the UAS, the hazard to persons, vehicles and 

structures is minimal compared to manned aircraft, which should be considered in granting the exemption.
Complete UAS, LLC 11523 Palmbrush Trail Suite 353 Lakewood Ranch, FL 34202

14 CFR 91.121 Altimeter settings

The regulation requires that aircraft shall maintain cruising altitudes by reference to an altimeter setting 

available within 100 NM of the aircraft. The sUAS will always fly below 400 feet AGL and will not need 

to maintain cruising altitudes in order to prevent conflict with other aircraft. An Above Ground Level 

altimeter measurement above the takeoff point is transmitted via radio from the sUAS on-board computer

to the display screen held by the PIC, providing a constantly updated AGL readout.

14 CFR 91.151 Fuel requirements for flight in VFR conditions

The regulation provides that no person may begin a flight in an airplane under day-VFR conditions unless 

there is enough fuel to fly to the first point of intended landing and to fly after that for at least 30 minutes.

We feel the intention of this paragraph is to provide an energy reserve as a safety buffer for delays to 

landing. The sUAS are battery operated and the maximum duration of flight from a single battery charge 

is 12-45 (depending on which sUAS) minutes with a 20% reserve. Since the aircraft will never fly more

than 1/2 NM from the point of intended landing, a full battery charge at launch will ensure that we meet

the reserve energy requirement of this paragraph. We request an exemption to the word "fuel" and ask for

an equivalent interpretation with the word "energy". We also request exemption from the 30 min reserve 

and ask that our reserve will be to fly the mission to the point of intended landing and have at least a 20%

battery reserve after that.

14 C.F.R. 91.215 ATC transponder and altitude reporting equipment and use:

This regulation states all aircraft operating within 30 nautical miles of class A, B and C airspace must be 

equipped with automatic pressure altitude reporting equipment having a Mode C capability that 

automatically replies to Mode C interrogations. Due to the small size and lifting capabilities of our UASs 

we cannot carry a traditional transponder. All of our operations will be under 250’ if we are operating 

within the 30mi reach of a mode c vail.

14 CFR Subpart E (91.401- 91.417) - Maintenance, Preventive Maintenance, Alterations 

The regulation provides that the operator is primarily responsible for maintaining the aircraft in an 

airworthy condition, including compliance with part 39 and 43. Paragraphs 91.407 and 91.409 require that

the aircraft be "approved for return to service by a person authorized under 43.7" after maintenance and 

inspection. It is our intention that the PIC perform maintenance and inspection of the aircraft and "be 

authorized to approve the aircraft for return to service."

The PIC will ensure that the aircraft is in an airworthy condition prior to every flight and in addition, 

conduct detailed inspections after every two hours of flight. Maintenance performed by the PIC is limited 

to repairing small cracks, replacing a propeller, checking electrical connections and updating software and 

firmware for the on-board computer. All other maintenance will be performed by the manufacturer or

their designated repair facility. The PIC will document work performed in accordance with 91.417. We

feel that due to the size, construction, and simplicity of the aircraft, the PIC can ensure an equivalent level

of safety.
Complete UAS, LLC 11523 Palmbrush Trail Suite 353 Lakewood Ranch, FL 34202

How this Request is to the Betterment of our Community

We believe that the use of UAS to perform agricultural land imaging creates a benefit to the public. The 

ability to use an onboard geo-referenced still camera to collect high-resolution data that can be used to 

increase crop production and reduce unnecessary chemical use will provide a less expensive and healthier 

food supply to the public. The unmanned aircraft does not carry any persons or flammable liquids, 

reducing public exposure in the event of an incident. Finally, the unmanned aircraft can be launched and 

recovered from the property which we have been contracted to image. The ability to avoid overflying 

private and public properties provides the public with the benefit of privacy from aircraft flying overhead.

Unmanned Aircraft Systems (sUAS) are also a feasible method to obtain information of agricultural 

cropland to determine optimum inputs that result in cost savings to farmers, yield security, and reduce 

environmental impact of excess fertilizers and chemicals in the soil.

Request for Blanket COA Approval

On March 24, 2015, the FAA announced that it has implemented a new policy of granting "blanket" 

COAs to applicants requesting exemptions from the Federal Aviation Regulations under Section 333 of 

the FAA Modernization and Reform Act of 2012.

The Applicant hereby requests that a "blanket" COA that conforms to the terms set forth in 

https://www.faa.gov/news/updates/?newsId=82245 upon approval of CUAS’ exemption request.

Sincerely

Timothy Ford

President and CEO

Complete UAS, LLC

11523 Palmbrush Trail Suite 353

Lakewood Ranch, FL 34202

(314) 397-1110