Lone Star Sky Solutions, LLC. Section 333 UAS Exemption Request

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March 24th, 2015

Danielle M. Rivera, CEO

Lone Star Sky Solutions, LLC

1699 Ridge Runner Ct.

Clarksville, TN 37042

danielle@lonestarskyllc.com

(931) 444-7150

U.S. Department of Transportation

Docket Management System

1200 New Jersey Ave., SE

Washington, DC 205930

Petition for Exemption Filed under Section 333 of the 2012 FAA Modernization and Reform Act

Filed via www.regulations.gov

Dear FAA UAS Exemption Review Team,

Lone Star Sky Solutions, LLC (“LSSS”) is respectfully writing to request exemptions that would 

lead to safe and legal entry into the NAS under Section 333 of the FAA Modernization and 

Reform Act of 2012. A granted exemption would allow us to obtain a COA, if required, to 

conduct commercial operations and training described in this letter. Furthermore, it would 

enhance airspace safety and efficiency in our community by offering affordable aerial imagery, 

video, and surveying to the general public that would deter and mitigate unsafe and illegal 

entrance into the NAS by untrained and unlicensed UAS users. 

Annex A outlines requested exemptions and applicable reasoning. Annex B briefly describes PIC 

training program and qualifications. Annex C outlines operations, safety considerations, and 

limitations. The remainder of this letter is outlined in accordance with (“IAW”) the Section 333 

Guidance document available at FAA’s Petitioning for Exemption under Section 333.

LSSS’ UAS Platforms

1. Operations will be conducted with 3D Robotics’ X8+ and SenseFly’s eBee UAS(s). 

Design and operational characteristics are defined within attached manuals. Recently, 

exemptions for the X8+ were granted to Build Imagery, BNSF Railway Company, and 

the eBee to Quiet Creek Corporation, amongst others, on the 11th and 12th of March. 

In addition, airworthiness of both platforms has been demonstrated in different projects 

within the United States (e.g., eBee by New Mexico State University, X8). 
Lone Star Sky Solutions, LLC. Section 333 UAS Exemption Request

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2. PIC(s) will be trained on and operate by strict conditions defined by the Safety Program 

of the Academy of Model Aeronautics, attached flight manuals, and LSSS’ training 

program. Inspections will be conducted before each flight IAW platform’s respective 

checklist and Annex C. Maintenance and repairs will be performed IAW 3DR or eBee 

user manual, at minimum, quarterly or upon failed pre- or post-flight inspections.

3. All equipment, frequencies, and payloads comply with FCC requirements and can be 

furnished upon request.

LSSS’ PIC(s)

4. LSSS has developed a PIC training program that can be furnished upon request. Refer 

to Annex B for further information. 

5. All PIC(s) will obtain and maintain First Aid and CPR certification. They will be able 

to apply basic aid in the unlikely situation that an UAS collides with personnel.

Operation of UAS

6. LSSS conducts operations to provide affordable aerial photography, video, and 

surveying to the general public. Refer to Annex C for a list of operations, safety 

considerations, and limitations.

7. The X8+ max operating speed will not exceed 15MPH and the eBee will not exceed 

35MPH. Neither platform will exceed an altitude of 400 feet above ground level. Both 

platforms will not operate at night or in weather conditions that produce precipitation, 

visibility less than three miles from the launch point, ceilings less than 1000 feet, 

sustained winds greater than 25 knots, or gust spreads greater than 10 knots. All PIC(s) 

are equipped with Kestrels to measure current site wind speed. This will prevent 

unnecessary risk to people and property.

8. Areas of intended operations are defined by property owners, responsible agents, or 

government agencies consent and boundaries obtained by government GIS sources. 

Refer to Annex C for further information.

9. PIC(s) will not conduct operations within five nautical miles of airports without 

approved consent from base operations or air traffic control authorities. PIC(s) will 

notify these agencies at least 72 hours prior if operation site is within five nautical miles 

of an airport. 

10. PIC(s) will maintain unaided VLOS with UAS. In complex duties or terrain, VO(s) will 

be used to maintain VLOS with UAS and PIC, and relay flight information.
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11. PIC(s) will verify flight limiting factors upon arrival to the operation site by using 

government sources and Kestrel for weather data, surveying and documenting site 

hazards, and conducting pre-flight inspections prior to operations.

12. PIC(s), when applicable to operations, will submit FAA Form 7711-1 or equivalent 

form with Flight Standards District Office at least 72 hours prior operations.

13. Will obtain COA, if required, from FAA Air Traffic Organization if granted exemption.

We hope that you grant us an exemption to the current regulations. We are looking forward to 

leading the way and setting a safe and efficient standard for future companies and UAS 

operators. Thank you for your consideration.

Very respectfully,

DANIELLE M. RIVERA, CEO

LONE STAR SKY SOLUTIONS, LLC
Lone Star Sky Solutions, LLC. Section 333 UAS Exemption Request

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ANNEX A: Requested Exemptions

- Part 61 Certification

o 61.113 (a, b)

 Operators should not be required to hold a commercial or private pilot 

licenses given safety features of X8+, eBee, AMA training, Lone Star Sky 

Solutions’ training program, and safety measures described in Annex C.

- Part 91 General Operating and Flight Rules

o 91.105

o 91.109

 Flight instruction will be accomplished using a thorough and safe training 

program outlined in Annex B.

o 91.119 (c)

 Cannot operate above 400 feet AGL and therefore cannot comply with this 

regulation.

o 91.121

 Onboard systems of the eBee and X8+ provide a similar level of safety by 

using GPS and other orientation sensors.

o 91.151 (a)

 X8+ and eBee do not use fuel. However, operators will prepare to land 

when battery falls below 25% and before 20% is reached. PIC(s) will 

conduct a weather brief before each flight and UAS will not be operated 

below VFR conditions.

o 91.405 (a), 91.407 (a)(1), 91.409 (a)(1, 2), 91.417 (a, b)

 All maintenance and repairs will be accomplished by utilizing 3DR

documentation or eBee user manual. An equivalent level of safety to the 

regulations will be achieved because the X8+ and eBee are not complex 

mechanical devices. Furthermore, pre- and post-flight checks will be 

conducted with each flight. If deficiencies are found, the UAS will not be 

operated until repairs are conducted. All repairs will be logged.

o 91.7 (a)

 Airworthiness of both aircraft has been demonstrated. If required, a waiver 

or certificate according to step four on the Petitioning for Exemption 

under Section 333 web page will be obtained.

o 91.203 (a, b), 91.9

 An equivalent level of safety will be ensured by requiring PIC(s) to carry 

manuals and standard operating procedure documents while operating 

UAS.

In addition, request exemption from other regulations deemed necessary by reviewer.
Lone Star Sky Solutions, LLC. Section 333 UAS Exemption Request

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ANNEX B: Pilot in Command Qualifications

Lone Star Sky Solutions’ training program is developed by our co-founder who has extensive 

knowledge in small UAS military applications and safety programs. The program is designed 

with community safety at mind using AMA guidelines. Ultimately, this program will efficiently

qualify trainees to operate and recognize the need for PIC refresher training.

The program separates operators into three tiers: Trainee, Basic Mission Qualified (“BMQ”) and 

Fully Mission Qualified (“FMQ”) PIC(s). Minimum qualifications are listed below.

1. Trainee: Can only operate UAS on training courses under supervision. Primary goal 

is to reach BMQ status by completing classroom, visual observer (“VO”), and 

operational instruction. 

a. Possess valid state issued driver’s license

b. Passes LSSS interview

c. Passes background check

2. BMQ PIC: Can operate UAS under supervision. Primary goal is to reach FMQ status 

by acquiring supervised on-the-job flight hours, passing check-ride, and becoming

First Aid and CPR certificated.

a. Completes eight hours of classroom instruction

b. Completes four hours of simulated flight training

c. Completes at least eight hours of operation instruction per platform

d. Completes at least eight hours of VO on-the-job training

3. FMQ PIC: Can operate UAS unsupervised and can recommend trainee upgrade or 

BMQ downgrade.

a. Completes at least twelve hours of supervised on-the-job flight

b. Passes written test

c. Passes UAS platform check-ride course

d. Receives Basic First Aid and CPR certification
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ANNEX C: Operations, Safety and Limitations

Lone Star Sky Solutions (“LSSS”) conducts several types of operations for two primary reasons. 

First, is to provide affordable aerial photography, video, and surveying to the general public. 

Second, is to provide free education and training to youth, high-school, and undergraduates in 

there freshman or sophomore year. By providing affordable services to the general public and 

free education, we hope to keep the community safe by deterring and mitigating untrained and 

unlicensed UAS users from entering the NAS.

1. Proposed operations are, but not inclusive to, the following:

a. Employee and youth training on LSSS’ properties or approved public locations 

with written consent of responsible government authority

b. Real-estate photography and video services for property owners, managers, or 

real-estate agents

c. Home inspections with multi-spectral cameras for owners or potential buyers.

d. Outdoor event photography or video (e.g., weddings, golf tournament, etc.) for 

the general public with consent of property owners and or responsible government 

authority

e. Agriculture monitoring, imagery, and surveying for owners, farmers, or 

agronomist with permission of property owner

f. General imagery, mapping, and surveying for property/land owners or 

governments

2. Safety is important, and the guidelines below will be followed in accordance with 

(“IAW”) FAA regulations.

a. Pre-flight:

i. PIC(s) will define operational borders using government GIS sources

ii. PIC(s) will account for all persons on property.

iii. PIC(s) will seek consent for persons within 100 feet of flight operations

iv. PIC(s) will survey and document site flight hazards

v. PIC(s) will review weather data from Kestrel and government sources

vi. PIC(s) will verify payload limits are not exceeded

vii. PIC(s) will conduct specific platform pre-flight checklist

viii. PIC(s) will document all tasks

ix. PIC(s) will conduct briefings for all PIC(s), VO(s), owners or responsible 

agent, and persons within 100 feet of operations. Brief will highlight the 

concept of operation, potential hazards, weather conditions, and 

abbreviated guidelines of the Academy of Model Aeronautics Safety Code

b. Flight Operations and Limitations:

i. PIC(s) will operate according to FAA regulations, manuals, and standard 

operating procedures

ii. PIC(s) will end operations before sunset.

iii. PIC(s) will leave operation site before evening civil twilight.
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iv. PIC(s) will not arrive to operation site before morning civil twilight.

v. PIC(s) will not start operations before sunrise.

vi. PIC(s) will not operate on any property without consent from owner or 

responsible agent

vii. PIC(s) will not fly within 5NM of airports without consent from base 

operations or air traffic control authorities

viii. PIC(s) will not fly over people

ix. PIC(s) will not fly within 100 feet of non-consenting persons

x. PIC(s) will not fly in excess of 400 feet above ground level

xi. PIC(s) will not operate UAS, to include payloads, more than 20 pounds

xii. PIC(s) will maintain VLOS and or coordination with VO(s)

xiii. PIC(s) will prepare for landing when battery level falls below 25% and 

land before level reaches 20%

c. Supervision of Operations

i. FMQ PIC(s) will ensure personnel within 100 feet of UAS operations are 

wearing protective equipment (e.g., safety vest and glasses, hard hat, etc.)

ii. FMQ PIC(s) will ensure all FAA UAS regulations and guidelines are 

maintained.

iii. FMQ PIC(s) will document violations by trainees, VO(s), or BMQ(s)

iv. FMQ PIC(s) will recommend upgrade and downgrade of trainees or

BMQ(s)

v. FMQ PIC(s) will conduct spot checks to ensure lead PIC gained proper 

consent from all authorities.