Matthew Sloane

Atlanta Drone Consultants, LLC

332 West Benson St.

Decatur, GA 30030

(404) 723-5621

Info@AtlantaDroneConsultants.com

August 10, 2015

U.S. Department of Transportation

Docket Management System

1200 New Jersey Avenue SE

Washington, DC 20590

RE: Amendments to Grant of Exemption No. 12299

Atlanta Drone Consultants, LLC

Regulatory Docket No. FAA-2015-0849

Dear Sir or Madam,

On August 4, 2015 the Federal Aviation Administration (“FAA”) granted an exemption 

from certain provisions of the Federal Aviation Regulations (“FAR”) pursuant to Section 333 of 

Public Law 112-95 to petitioner Atlanta Drone Consultants, LLC (“ADC”) permitting operation 

by ADC of a DJI Inspire 1 small unmanned aerial system (“UAS”) for the purposes of closed-set 

film and television video production. Please see Grant of Exemption No. 12299 (the “Grant of 

Exemption”) and ADC’s petition for exemption, docket no. FAA-2015-0849, the terms of both

are incorporated herein by reference. ADC now submits this request to amend the Grant of 

Exemption as follows:

a) To supplement the Grant of Exemption to permit the operation of three additional small 

UAS, and

b) To expand the scope of the Grant of Exemption to permit operation of covered small 

unmanned aerial systems in the field of news gathering photography and videography, 

mapping and surveying, and industrial and agricultural inspection.

All of the additional unmanned aerial systems covered by this requested amendment are of 

the same make and general mode of operation as those covered by the Grant of Exemption and 

all qualify as small UAS weighing less than 50 pounds. The proposed additional scope of 

operations will be subject to procedures and safeguards substantially identical to those applicable 

to the scope of operations permitted under the Grant of Exemption. Details of each requested 

amendment and the terms and conditions for each are are set forth in more detail below.

Additional Aircraft

ADC requests amendment of the Grant of Exemption to permit the operation of three 

additional UAS. Each proposed UAS is under 45 pounds, will be flown at all times under 300 

feet AGL as measured by the UAS’ on-board GPS system, will be kept within line of sight of the 

Pilot in Command (“PIC”), will have a separate safety Visual Observer (“VO”) at all times in 

communication with and within 5 feet of the PIC, will be flown at all times at speeds of 40 miles 

per hour or less, will be flown at all times during daylight hours, always using Visual Flight 

Rules (“VFR”) and within visual line of sight (“VLOS”), and never using first person view by
the PIC. The PIC will be able to use human vision unaided by any device other than corrective 

lenses as specified by a current state-issued driver’s license. The PIC will provide the local 

Flight Standards District Office (“FSDO”) with notice of all of flight operations no less than 72 

hours in advance of any intended flight. Each PIC will have over 400 hours of logged flight 

experience in the same UAS type or model, including 10 take offs and landings within the prior 

30 days. The PIC will conduct a full and complete inspection of aircraft prior to the initial 

takeoff of each flight.

The make, model, and type of the proposed additional UAS are as follows:

Make Model Weight (lbs.) Description

DJI Matrice 100 (M100) 5.35 Electric Quadcopter

DJI Spreading Wings S1000 9.25 Electric Octocopter

DJI Phantom 3 Professional 2.82 Electric Quadcopter

Operational parameters applicable to all UAS’ are set forth ADC’s petition for the Grant of 

Exemption. ADC will provide operator manuals for all three proposed additional UAS together 

with this request for amendment.

Additional Scope of Use

ADC requests amendment of the Grant of Exemption to permit use of the listed small 

UAS to permit their use for the purposes of news gathering photography and videography, 

mapping and surveying, and industrial and agricultural inspection. The public benefits of a grant 

of exemption for these uses are evident from the Grant of Exemption. Regular helicopters are, 

except as provided in Section 91.119, not allowed to fly less than 500 feet AGL. UAS on the 

other hand are best when flown between 50 and 300 feet AGL and in fact the best video quality

is 50 to 100 feet. A large manned helicopter could also cause very serious damage to persons or 

property on the ground and even to pilots and passengers inside a manned helicopter. A UAS 

weighing in at approximately six pounds would not be nearly as hazardous. Additionally, a 

regular helicopter is normally larger than a standard automobile whereas the UAS is significantly

smaller, in this case weighing less than ten pounds. It is substantially safer for the public to have 

a UAS accomplish the job of aerial imaging, photography, and videography than a manned 

helicopter just based on size alone.

For the purposes of news gathering, UAS may be an exceptional tool for journalists and 

all manner of news gathering and reporting media, to serve the public good in enhancing 

accurate dissemination of newsworthy and relevant information to interested citizens. When 

employed to conduct tower, pipeline, and industrial inspections, UAS permits workers to avoid 

dangerous or precarious hazards or physical positions involving high risk of injury. UAS enable 

safe inspection of difficult to reach or environmentally sensitive locations without the use of 

heavy trucks, cranes, booms or other equipment requiring greater expense or attendant 

undesirable environmental impact. 

Proposed Operational Parameters
The PIC will follow the manufacturer’s UAS aircraft/component, maintenance, overhaul, 

replacement, inspection, and life limit requirements. When unavailable, aircraft 

maintenance/component/overhaul, replacement, and inspection/maintenance requirements will

be established and identified in the operator’s manual. At a minimum, the following will be 

included in the operator’s manual: 

1. Actuators / Servos 

2. Transmission (single rotor) 

3. Powerplant (motors) 

4. Propellers 

5. Electronic speed controller 

6. Batteries 

7. Mechanical dynamic components (single rotor) 

8. Remote command and control 

9. Ground control station (if used) 

10. Any other components as determined by the operator 

Prior to each flight the PIC will inspect the UAS to ensure it is in a condition for safe 

flight. If the inspection reveals a condition that affects the safe operation of the UAS, the aircraft 

will be prohibited from operating until the necessary maintenance has been performed and the 

UAS is found to be in a condition for safe flight. The Ground Control Station, if utilized, will be 

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

in the aircraft records. 

Any UAS that has undergone maintenance or alterations that affect the UAS operation or 

flight characteristics (e.g. replacement of a flight critical component) will undergo a functional 

test flight in accordance with the operator’s manual. The PIC who conducts the functional test 

flight will make an entry in the UAS aircraft records of the flight. The requirements and 

procedures for a functional test flight and aircraft record entry must be added to the operator’s 

manual. 

Prior to operations conducted for the purpose of motion picture filming (or similar 

operations), the PIC must have accumulated and logged, in a manner consistent with 14 CFR § 

61.51 (b), a minimum of five hours as a UAS pilot operating the make and model of UAS to be 

utilized for operations under the exemption and three take-offs and three landings in the 

preceding 90 days. Training, proficiency, experience-building, and take-off and landing currency

flights can be conducted under this grant of exemption to accomplish the required flight time and 

90 day currency. During training, proficiency, experience-building, and take-off and landing 

currency flights all persons not essential for flight operations are considered non-participants, 

and the PIC must operate the UA with appropriate distance from non-participants in accordance 

with 14 CFR § 91.119. 

Prior to any flight operations authorized by this grant of exemption, the PIC and VO must 

have successfully completed a qualification process, as outlined in the operator’s manual. As this 

is a requirement stipulated by the operator, the test must be developed and implemented by a 
qualified person designated at the sole discretion of the operator. A record of completion of this 

qualification process must be documented and made available to the Administrator of the FAA

(the “Administrator”) upon request. 

Prior to operations, a flight demonstration, administered by an operator-approved and 

qualified pilot must be successfully completed and documented. This documentation must 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 FSDO evaluation and approval of company

designated examiners, the petitioner will conduct these tests in accordance with the operator’s 

manual. 

The UAS will not be operated directly over any person, except authorized and consenting 

production personnel, below an altitude that is hazardous to persons or property on the surface in 

the event of a UAS failure or emergency. 

Regarding the distance from participating persons, the operator’s manual has safety 

mitigations for authorized and consenting personnel. At all times, those persons must be essential 

to the purposes of the instant flight. Because these procedures are specific to participating 

persons, no further FSDO or Aviation Safety Inspector (“ASI”) approval is necessary for 

reductions to the distances specified in the petitioner’s manuals. 

Regarding distance from non-participating persons, the operator will ensure that no 

persons are allowed within 500 feet of the area except those consenting to be involved and 

necessary for purposes of the instant flight. This provision may be reduced to no less than 200 

feet if it would not adversely affect safety. For example, an equivalent level of safety may be 

determined by an aviation safety inspector’s evaluation of the filming production area to note 

terrain features, obstructions, buildings, safety barriers, etc. Such barriers may protect nonparticipating persons (e.g. observers, the public, news media) from debris in the event of an 

accident. 

If the UAS loses communications or loses its GPS signal, the UAS must return to a predetermined location within the security perimeter and land or be recovered in accordance with 

the operator’s manual. The proposed additional UAS’, as well as the UAS covered by the Grant 

of Exemption, are designed to increase altitude 20 meters or 60 feet upon loss of signal between 

the ground controller held by the pilot and the aircraft itself. Upon reaching the higher altitude (a 

safety feature to avoid people, trees and buildings), the UAS will return to its original take-off 

point of origin and slowly land. It is critically important for the pilot to calibrate the aircraft prior 

to its flight. The calibration procedure sets the compass and lets the aircrafts onboard computer 

know where it is located on Earth. The UAS also has a Flytrex black box system installed which 

tracks every flight so if a loss of link to the aircraft from the controller ever occurs, then the pilot 

can follow and retrieve the UAS when it lands. Additional details concerning lost-link failsafes 

can be found in the Operator’s Manuals.

The PIC will abort the flight in the event of unpredicted obstacles or emergencies in 

accordance with the operator’s manual. 
Each UAS operation must be completed within 30 minutes flight time or with 25% 

battery power remaining, whichever occurs first. 

The PIC will request a Notice to Airmen (“NOTAM”) not more than 72 and not less than 

48 hours prior to the operation.

The operator will develop procedures to document and maintain a record of the UAS 

maintenance, preventative maintenance, alterations, status of replacement/overhaul component 

parts, and the total time in service of the UAS. These procedures will be added to the operator’s 

manual. 

Each UAS operated under this exemption will comply with all manufacturer Safety 

Bulletins. 

The operator must develop UAS technician qualification criteria. These criteria must be 

added to the operator’s manual.

The preflight inspection section in the operator’s manual must be amended to include the 

following requirement: The preflight inspection must account for all discrepancies, i.e. 

inoperable components, items, or equipment, not covered in the relevant preflight inspection 

sections of the operator’s manual. 

Before conducting operations, the radio frequency spectrum used for operation and 

control of the UAS must comply with the Federal Communications Commission (“FCC”) or 

other appropriate government oversight agency requirements. 

At least three days before scheduled filming, the operator of the UAS affected by this 

exemption must submit a written Plan of Activities to the local FSDO with jurisdiction over the 

area of proposed filming. The 3-day notification may be waived with the concurrence of the 

FSDO. The plan of activities must include at least the following: 

a. Dates and times for all flights 

b. Name and phone number of the operator for the UAS filming production conducted under 

this grant of exemption 

c. Name and phone number of the person responsible for the on-scene operation of the UAS 

d. Make, model, and serial or N-number of UAS to be used 

e. Name and certificate number of UAS PICs involved in the filming production event 

f. A statement that the operator has obtained permission from property owners and/or local 

officials to conduct the filming production event; the list of those who gave permission must be 

made available to the inspector upon request. 
g. Signature of exemption-holder or representative 

The documents required under 14 CFR § 91.9 and § 91.203 will be available to the PIC at the 

ground control station of the UAS any time the aircraft is operating. These documents must be 

made available to the Administrator or any law enforcement official upon request. 

The UAS will remain clear and yield the right of way to all other manned operations and 

activities at all times (including, but not limited to, ultralight vehicles, parachute activities, 

parasailing activities, hang gliders, etc.).

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. 

The UAS will be operated by the PIC from any moving device or vehicle. 

The UA will not be operated less than 500 feet below or less than 2,000 feet horizontally

from a cloud or when visibility is less than 3 statute miles from the PIC. 

The UA will not operate in Class B, C, or D airspace without written approval from the 

FAA. The UA will not operate within 5 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, and the operation is conducted in accordance with a 

NOTAM as required by the operator’s COA. The letter of agreement with the airport 

management must be made available to the Administrator upon request. 

Any 1) incident, 2) accident, or 3) flight operation that transgresses the lateral or vertical 

boundaries of the operational area as defined by the applicable COA must be reported to the 

FAA UAS Integration Office (AFS-80) within 24 hours. Such accidents must be reported to the 

National Transportation Safety Board (“NTSB”) per instructions contained on the NTSB Web 

site: www.ntsb.gov. Further flight operations may not be conducted until the incident, accident, 

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

Unless otherwise specified in this grant of exemption, the UAS, PIC, and operator must 

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

The Federal Aviation Administration by and through its authorized representative is 

requested to approve this petition for amendment to the Grant of Exemption previously granted 

to ADC.

Respectfully submitted:

Matthew Sloane