July 20, 2015

U. S. Department of Transportation

Docket Management System

1200 New Jersey Ave.,

SE Washington, DC 20590

RE: Petition of Drone 1 Applied Drone Systems, LLC for Exemption Pursuant to 

Section 333 of the FAA Reform Act

Petitioner’s Name and Address:

Applied Drone Systems, LLC

Owner: Quentin Wheeler

1845 Curraghmore Road

Clemmons, NC 27012

619-227-5655

quentin@appdronesystems.com

To whom it may concern:

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

Act) and 14 C.F.R. Part 11, Applied Drone Systems, LLC, operator of Small Unmanned 

Aircraft Systems(“sUASs”) equipped to conduct aerial photography, videography,and 

data collection hereby applies for an exemption from the listed Federal Aviation 

Regulations (“FARs”) to allow commercial operation of its sUASs, 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 small, unmanned and relatively inexpensive sUAS under controlled conditions in 

airspace that is 1) limited 2) predetermined and 3) controlled. The proposed 

exemption, if granted, would allow Applied Drone Systems, LLC to conduct 

commercial operations of sUASs meeting or exceeding all of the operational and 

safety requirements Congress has set forth in Section 333.

Applied Drone Systems, LLC is an aviation technology company owned and operated 

by Quentin Wheeler. The purpose of Applied Drone Systems, LLC is to provide sUAS 

imagery to customers and to develop new and innovative sUAS flight applications 

using the drone’s cameras and sensors to provide time or cost savings for business, 

non-profit organizations and people in the United States and its territories. Mr. 

Wheeler has 30 years of aviation experience experience in both fixed wing and 

helicopters. As a military aviator, he was involved with Predator and Global Hawk 

integration into the airspace above Iraq and Afghanistan. He was a squadron 

maintenance functional check-flight pilot, maintenance officer, and officer in charge 

of forward deployed detachments. He brings a professional approach to aviation 

operations, maintenance and airspace integration to his company operations.
Applied Drone Systems, LLC plans to use the capabilities of sUASs to offer numerous 

services all based on aerial photography and videography flight profiles. Applied 

Drone Systems will then process the aerial data collected and transform it to the 

client’s requirement. These requirements include: 

- Aerial Photography/Videography

- Real Estate Photography/Videography

- Event Photography/Videography

- Construction Site Inspections and Progress Monitoring

- Environmental Monitoring 

- Terrain Mapping 

- Research Operations Carrying Environmental Data Collection Payloads

Statutory Authority Section 333, titled “Special Rules for Certain Unmanned Aircraft 

Systems”, provides a mechanism for seeking expedited FAA authorization of safe civil 

Unmanned Aircraft Systems (UAS) operations in the National Airspace System (“NAS”). 

Section 333 states that the FAA “shall determine if certain unmanned aircraft systems 

may operate safely in the national airspace system before completion of the 

(comprehensive) plan and rule making required by section 332(b)(1) of this Act or the 

guidance required by section 334 of this Act.” In section 332(b)(1), Congress made it 

clear that Section 333 provides a mechanism for “expedited operation authorization” 

if several factors are met. Petitioner meets all requirements to permit FAA approval of 

commercial UAS operations.

The name and address of the applicant are:

Name: Applied Drone Systems, LLC

Owner: Quentin Wheeler

Address: 1845 Curraghmore Road

Clemmons, NC 27012

Phone: 619-227-5655

Email: QUENTIN@APPDRONESYSTEMS.COM

Exemptions are being requested from the following regulations: 

14 C.F.R. Part 21, 14 C.F.R. 61.113 (a), 14 C.F.R. 61.3, 14 C.F.R. 91.151(a), 14 C.F.R. 

91.405(a), 14 C.F.R. 91.407(a)(1), 14 C.F.R. 91.409(a)(1) and (2), 14 C.F.R. 91.417(a) 

and (b).
 

AIRCRAFT

Applied Drone Systems, LLC will operate the 3D Robotics Solo sUAS. Aircraft weight is 

3.3 pounds with battery and has a payload capacity of 1.1 pounds (500g). Solo is a 

commercially available, off-the-shelf sUAS. The sUAS will weigh no more than 4.4 

pounds and will operate no faster than 55 knots groundspeed. This is an agile, 

professionally engineered aircraft having the ability to hover, and move about its 

three axes simultaneously. Because of the sUAS’s specifications and flight 

characteristics, it poses no threat to national security. Compared to fixed wing and 

helicopters, Solo provides reduced personnel to operate and maintain, reduced noise 

levels, zero emissions into the environment, and enhanced safety protocols 

engineered into the aircraft system. 

Petitioner is requesting an exemption to enable Applied Drone Systems, LLC to 

operate a 3D Robotics Solo sUAS that is upgraded to latest version software on the 

sUAS, controller, and tablet that runs the Solo App. Solo’s onboard computers control 

navigation, attitude, and data communications in flight while sending real-time 

telemetry and video output. Control inputs are received over the 3DR Link secure WiFi network. Solo is optimized for capturing aerial video using the Go Pro Hero 

camera. The gimbal and frame allow for different cameras to be utilized with the 

airframe. the UAS will not be operated outside parameters set forth in the 

manufacturer’s handbook.

This sUAS has a built-in capability to set a maximum Above Ground Level (AGL) 

altitude for the flight. The aircraft’s Wi-Fi controller has a 1/2 mile line of sight 

maximum distance. If communication between the sUAS and the controller is lost 

(lost link), the sUAS will fly back towards to takeoff point until it reacquires the 

signal. 

These factors are beneficial for, and in the best interest of, the public. Accordingly, 

the applicant respectfully requests that the FAA grant the requested exemption 

without delay. 
OPERATIONS

Maximum Airspeed and Altitude 

The drone may not be operating at airspeeds greater than the maximum airspeeds 

recommended by the manufacturer (55 knots) and may not exceed 400 feet AGL. 

Airport Restrictions 

Flight operation may not be within 5 nautical miles of an airport reference point 

(ARP) as denoted in the current FAA Airport/Facility Directory (AFD) or for airports not 

listed in the ARP, the center of the airport symbol as denoted on the current FAApublished aeronautical chart, unless a letter of agreement with that airports 

management is obtained or otherwise permitted by a COA issued to the exemption 

holder. This letter of agreement with the airport management must be available to 

the Administrator or any law enforcement official upon request. 

Visibility and Clouds 

The aircraft may not be operated less than 500 feet below or 2000 feet horizontally 

from a cloud or when visibility is less than 3 statue mile from the PIC. 

Reserve Flight Time 

The pilot in command should not begin a flight unless (considering wind and forecast 

weather conditions) there is enough available battery power (or additional batteries) 

for the aircraft to conduct the intended operation. All Applied Drone Systems pilots/

operators will terminate flights when remaining battery power level reaches 20%, or 

20 minutes flight time is reached, whichever comes first after takeoff.

Visual Line of Sight 

The aircraft must be operated within visual line of sight (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 airman medical certificate or 

U.S. driver’s license. 

Visual Observer 

All operations must utilize a visual observer (VO). The aircraft must be operated 

within the VLOS of the PIC and VO at all times. The VO may be used to satisfy the 

VLOS requirement as long as the PIC always maintains VLOS capability. The VO and 

PIC must be able to communicate verbally at all times; electronic messaging or 

texting is not permitted during flight operations. The PIC must be designated before 

the flight and cannot transfer his or her designation for the duration of the flight. 

The PIC must ensure that the VO can perform the required duties of the VO. 
Obstruction Clearances 

All flight operations must be conducted at least 500 feet from all nonparticipating 

persons, vessels, vehicles, and structures unless: 

• Barriers or structures are present that sufficiently protect nonparticipating persons 

from the aircraft an/or debris in the event of an accident. 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 aircraft, flight operations must cease immediately in a manner ensuring the 

safety of nonparticipating persons: and 

• The owner/controller of any vessels, vehicles or structures has granted permission 

for operating closer to those objects and the PIC has made a safety assessment of 

the risk of operating closer to those objects and determined that it does not present 

an undue hazard. 

The PIC, VO, operator trainees or essential persons are not considered 

nonparticipating persons. 

Additional Operational Clarifications

Aircraft may not operate over any persons not directly

involved in the operation.

Daylight-only operations (official sunrise to official sunset, local time).

Must yield right-of-way to other aircraft, manned or unmanned.

Must use visual observer (VO) on all commercial operations.

First-person view camera not authorized for pilot use on commercial operations. Clients 

may view first person while pilot flys normally.

No operations are allowed in Class A (18,000 feet & above) airspace.

Operations in Class B, C, D and E airspace are allowed with the

required ATC permission.

Operations in Class G airspace are allowed without ATC permission

No person may act as an operator or VO for more than one unmanned

aircraft operation at one time.

No careless or reckless operations.

Operational preflight inspection required.

The aircraft may not be operated by the PIC from any moving device or vehicle.
EXEMPTIONS

Applied Drone System LLC requests exemptions from the following regulations as well 

as any additional regulations that may technically apply to the operation of the sUAV 

System: 14 C.F.R. Part 21, 14 C.F.R. 61.113 (a), 14 C.F.R. 61.3, 14 C.F.R. 91.151(a), 14 

C.F.R. 91.405(a), 14 C.F.R. 91.407(a)(1), 14 C.F.R. 91.409(a)(1) and (2), 14 C.F.R. 

91.417(a) and (b).

AIRWORTHINESS CERTIFICATION (14 CFR Part 21)

To ensure airworthiness, the Pilot in Command will perform a thorough preflight prior 

to any flight operation. The preflight inspection will be performed in accordance 

with the 3D Robotics Solo User Manual to ensure the aircraft is safe for flight and has 

the necessary battery power to accomplish the assigned flight. Any damage or 

malfunction that poses a hazard to flight will be documented and corrected prior to 

operation. The UAS carries neither a pilot nor passenger, carries no explosive 

materials or flammable liquid fuels, and operates exclusively within visual line of site 

of the operator. Operations under this exemption will be tightly controlled and 

monitored by the operator.

The sUAS will be maintained in accordance with the manufacturer’s maintenance 

instructions. sUAS maintenance records will be kept on all life-limited parts of each 

airframe, engine, rotors, controllers, and other appliances. Only manufacturer's 

authorized replacement parts will be used.

By nature of these conditions, this UAS provides a greater degree of safety to the 

public and property owners than conventional operations conducted with 

airworthiness certificates issued under 14CFR Part 21.

FLIGHT CREW TRAINING AND CERTIFICATIONS (14 CFR 61.3, 14 CFR 

61.113) 

The aircraft does not carry passengers for compensation or hire. Copies of the pilot’s 

FAA certificates and training records will be kept on file at Applied Drone Systems. 

Pilots/Operators will be required to successfully pass the online Applied Drone 

Systems Ground School test before flying a commercial operation. All pilot and 

operators must hold at least a FAA sport pilot license with commercial pilot being 

desirable. Also, pilots/operators will hold a valid driver's license or at least a third 

class medical certificate. Any research operation that is carrying a sensor, must have 

a commercial pilot as the pilot in command. The Applied Drone Systems pilot/

operator is in charge and controls the entire flight and will not transfer responsibility 
for operational control of the sUAS aircraft to any other person (unless the flight is 

specifically for training purposes and not for hire). 

Prior to operations for hire, the PIC must have accumulated and logged a minimum of 

10 hours of Solo sUAS time and have at least 50 hours total flight time. Designation as 

an Applied Drone Systems, LLC pilot/operator will remain on file. The PIC is 

responsible for the safe and efficient operation of the aircraft. Specific duties include 

all preflight preparation and inspection, in flight operation, post flight requirements, 

and all procedures including but not limited to:

• Impact of Weather Conditions

• Risk Management

• Operational Flight Safety

• Post Flight Data/Imagery Transfers 

For Visual Observers, completion of the online exam is required before field 

operations. The curriculum serves as an information baseline to ensure visual 

observers are familiar with potential Applied Drone Systems operations and can be 

effective in field flight operations. The Visual Observer will possess a current valid 

driver’s license issued in the United States. 

FUEL REQUIREMENTS (14 CFR 91.151) 

The sUAS is powered by a battery, which provides up to 25 minutes of powered flight. 

Because of the absence of flammable operating fluids, the sUAS does not pose the 

same level of risk as a conventional aircraft. All Applied Drone Systems pilots/

operators will terminate flights when remaining battery power level reaches 20%, or 

20 minutes flight time is reached, whichever comes first after takeoff. 

Since no flights conducted by Applied Drone Systems will require traditional 

petroleum based fuel, and those flights will be for less than 25 minutes, Applied 

Drone Systems, LLC requests relief from 14CFR 91.151.

MAINTENANCE (91.405(a), 91.407(a)(1), 91.409(a)(1) and (2), and 

91.417(a) and (b)) 

Applied Drone Systems will keep maintenance records on all airframes that the 

company owns. Aircraft maintenance records must include the current status of the 

life-limited parts of each airframe, engine, rotors, and appliances. 
Each aircraft operated under this exemption must comply with all manufacturer 

safety bulletins. 

Applied Drone Systems will track all life limited components mentioned above. When 

engines, rotors, controllers, or other drone equipment is replaced, maintenance 

records must accurately reflect the changes and track individual and total times. 

Any aircraft that has undergone maintenance or alterations that affect the aircraft 

operation or flight characteristics, e.g., replacement of a flight critical component, 

must undergo a functional test flight prior to conducting further operations under this 

exemption. Functional test flights may only be conducted by a PIC with a VO and 

must remain at least 500 feet from other people. The functional test flight must be 

conducted in such a manner so as to not pose an undue hazard to person and 

property. 

All maintenance will be done is accordance with 3D Robotics guidelines. Applied 

Drone Systems must follow the 3D Robotics maintenance, overhaul, replacement, 

inspection , and life limit requirements for the aircraft and aircraft components.

CONCLUSION

Applied Drone Systems, LLC plans to use the capabilities of sUASs to offer numerous 

services all based on standard aerial photography and videography flight profiles. 

Applied Drone Systems will then process the aerial data collected and transform it to 

the client’s requirement. 

With operation being directed by a retired military pilot and FAA licensed commercial 

pilot, Applied Drones systems understands and intends to comply with every 

applicable regulation to the operation of sUAS. Each exemption for which we seek 

relief, will allow for safe and efficient commercial operations that are far superior to 

those conducted by manned aircraft. 

Applied Drone Systems proposed exemptions and operational limitations are very 

closely aligned with other exemptions already granted. Applied Drone Systems LLC

should be permitted to conduct small UAS operations in accordance with its manuals 

and all other operating parameters deemed necessary and appropriate by the FAA. 

Please contact me at your convenience with any questions regarding this request. 

Thank You, 

Quentin Wheeler, Founder and Director of Operations, Applied Drone Systems, LLC