1st Landing LLC Ph: 631-750-9238 Email: nick@accsystemsinc.com

29 November 2015

U.S. Department of Transportation 

Docket Management System 

1200 New Jersey Ave., SE 

Washington, DC 20590 

Re: Exemption Request Under Section 333 of the FAA Reform Act and Part 11 of the Federal Aviation Regulations 

Dear Sir or Madam: 

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the “Reform Act”) and 14 CFR Part 

11, 1st Landing, LLC (“1st Landing”), seeks an exemption from Federal Aviation Regulations (“FARs”) detailed 

below for multiple models of rotary small unmanned aerial systems (sUAS). 

The sUAS will be equipped to conduct aerial data collection for hire using remote sensing and measuring by 

instruments recorded aboard and transmitted to the ground. None of the data collection instrumentation interferes 

with the safe operations as they conform to published weight and balance restrictions, do not alter the command and 

control of the vehicles and do not require any adjustment to safety features during lost link operations. The 

commercial activities meet the needs of wide array of customers who do not have comparable alternatives and this 

requested exemption would support an application for a commercial Certificate of Authorization to use the system 

to support the following commercial operations, each of which serve the public good:

 imagery (photography, video, infrared, etc.)

 electronic measurement (precision surveying, RF analysis, etc.)

 chemical measurement (particulate measurement, etc.)

 other gathering of data by other instruments placed and to be placed aboard the sUASs

 aerial photography and video for the motion picture, television and commercial video industry

 search and rescue services for hire

 accident and disaster insurance compensation evaluation

 construction, transportation, communication, distribution, utility and risk management services

 other services as requested for by customers' for their needs

The sUAS in question are similar or identical to those granted exemptions in prior requests and the aviation 

experience of the applicant and the type of commercial operations requested for consideration closely match the 

criteria of numerous operators granted exemptions. The operations by 1st Landing would be subject to the same 

conditions and limitations.

1. 3DRobotics DIY Quad

a. Optional Equipment: 

i. Ublox M8N GPS

b. Previous Exemption Granted

i. Exemption No. 12283 // Orlando Production, Inc.

2. 3DRobotics DIY Quad

a. Optional Equipment: 

i. Ublox M8N GPS

ii. 3DR Extended Legs Kit
1st Landing LLC Ph: 631-750-9238 Email: nick@accsystemsinc.com

iii. Tarot T-2D Gimbal

iv. Logitech USB Webcam

v. Raspberry Pi Computer

b. Previous Exemption Granted

i. Exemption No. 12283 // Orlando Production, Inc.

3. 3DRobotics X8+

a. Optional Equipment:

i. Tarot T-2D Gimbal

ii. Logitech USB Webcam

iii. Raspberry Pi Computer

b. Previous Exemption Granted

i. Exemption No. 13506 // Top Flight Digital Media LLC

4. Aerosky C17

a. Optional Equipment:

i. Tarot T-2D Gimbal

ii. 3DR GPS

iii. Logitech USB Webcam

iv. Raspberry Pi Computer

b. Previous Exemption Request

i. Docket ID: FAA-2015-4374 // David A. Kello

 

Unless otherwise specified in this grant of exemption, the UAS, the UAS PIC, and the UAS operations will comply 

with all applicable parts of 14 CFR including, but not limited to, parts 45, 47, 61, and 91. These operations will also 

be subject to strict operating requirements defined in the aircraft user manuals.

The PIC and VO will meet the requirements outlined in FAA Policy N 8900.227 Section 16 Personnel 

Qualifications. Additionally, the PIC and VO will perform maintenance on the system and will complete a course of 

maintenance instruction as part of their initial training. 

We submit that the combination of the aircraft's light weight, historically demonstrated flight performance, fully 

qualified flight crew and strict operation under the guidelines established in 8900.227, the FAA can have 

confidence that the operation will have an equivalent or greater level of safety of manned aircraft performing the 

same mission. 

In regards to privacy concerns, all flights will occur over private or controlled access property with the property

owner’s prior consent and knowledge. Inspection will be in areas where the owners will have consented to the 

inspections or otherwise have agreed to allow the UAS and the operator to be in the area where inspection will take 

place.

The regulations from which the exemption is requested are as follows: 14 CFR 61.113(a) and (b), 91.7(a), 

91.119(c), 91.121; 91.151(a)(1), 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 1st Landing to operate sUAS for the purpose of aerial data collection. This exemption is subject 

to the conditions and limitations listed below.

1. Operations authorized by this grant of exemption are limited to the type aircraft detailed above. 

Proposed operations of additional aircraft will require a new petition or a petition to amend this grant.

2. The UA may not be flown at an indicated airspeed exceeding 70 knots.

3. The UA must be operated at an altitude of no more than 400 feet above ground level (AGL), as 

indicated by the procedures specified in the operating documents. All altitudes reported to ATC must be 

in feet AGL.
1st Landing LLC Ph: 631-750-9238 Email: nick@accsystemsinc.com

4. The UA 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.

5. All operations must utilize a visual observer (VO). 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. 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 functions 

prescribed in the operating documents.

6. The operating documents and this grant of exemption must 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 the operating documents, the conditions and limitations herein 

take precedence and must be followed. Otherwise, the operator must follow the procedures as outlined in 

its operating documents. The operator may update or revise its operating documents. It is the operator’s 

responsibility to track such revisions and present updated and revised documents to the Administrator 

upon request. The operator must also present updated and revised documents if it petitions for extension 

or amendment to this grant of exemption. If the operator determines that any update or revision would 

affect the basis upon which the FAA granted this exemption, then the operator must petition for

amendment to its grant of exemption. The FAA’s UAS Integration Office (AFS-80) may be contacted if 

questions arise regarding updates or revisions to the operating documents.

7. Prior to each flight the PIC must 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 is 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 must be included in the preflight inspection. All maintenance 

and alterations must be properly documented in the aircraft records.

8. Any UAS maintenance or alterations that affect the UAS operation or flight characteristics, e.g. 

replacement of a flight critical component, must undergo a functional test flight. The PIC who conducts 

the functional test flight must make an entry in the aircraft records.

9. The pre-flight inspection section in the operating documents must account for all discrepancies, i.e. 

inoperable components, items, or equipment, not already covered in the relevant sections of the operating 

documents.

10. The operator must follow the UAS aircraft/component, maintenance, overhaul, replacement, 

inspection, and life limit requirements.

11. The operator must carry out its maintenance, inspections, and record keeping requirements, in 

accordance with the operating documents. Maintenance, inspection, and alterations must be noted in the 

aircraft records, including total flight hours, description of work accomplished, and the signature of the 

PIC returning the UAS to service.

12. Each UAS operated under this exemption must comply with all manufacturer System and Safety 

Bulletins.

13. The PIC must make an entry in the aircraft record of the corrective action taken against discrepancies 

discovered between inspections.

14. The Pilot in Command (PIC) must possess at least a private pilot certificate and at least a current thirdclass medical certificate. The PIC must 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.

15. The operator may not permit any PIC to operate unless that PIC has demonstrated through the 

operator’s training that the PIC is able to safely operate the UAS in a manner consistent with how the 

UAS will be operated under this exemption, including evasive and emergency maneuvers and maintaining 
1st Landing LLC Ph: 631-750-9238 Email: nick@accsystemsinc.com

appropriate distances from persons, vessels, vehicles and structures. A record of training must be 

documented and made available upon request by the Administrator. Flights for the purposes of training 

the operator’s PICs and VOs (training, proficiency, and experience-building), are permitted under the

terms of this exemption. However, said training operations may only be conducted during dedicated 

training sessions.

16. UAS operations may not be conducted during night, as defined in 14 CFR 1.1. All operations must be 

conducted under visual meteorological conditions (VMC). Flights under special visual flight rules (SVFR) 

are not authorized.

17. All operations shall be conducted in Class G airspace.

18. The UA may not operate within the required distances from airport reference points as denoted on a 

current FAA-published aeronautical chart without express permission from the FAA.

19. The UA may 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.

20. If the UA loses communications or loses its GPS signal, it must return to a predetermined location 

within the planned operating area and land or be recovered in accordance with the operating documents. 

21. The PIC must abort the flight in the event of unpredicted obstacles or emergencies in accordance with 

the operating documents.

22. The PIC is prohibited from beginning a flight unless (considering wind and forecast weather 

conditions) there is enough power to fly at normal cruising speed to the intended landing point and land 

the UA with reserve battery power remaining.

23. The operator must obtain an Air Traffic Organization (ATO) issued Certificate of Waiver or 

Authorization (COA) prior to conducting any operations under this grant of exemption. This COA will 

also require the operator to request a Notice to Airman (NOTAM) not more than 72 hours in advance, but 

not less than 48 hours prior to the operation.

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

in accordance with 14 CFR part 47, and have identification (NNumber) markings in accordance with 14 

CFR part 45, Subpart C. Markings must be as large as practicable.

25. Before conducting operations, the radio frequency spectrum used for operation and control of the UA 

must comply with the Federal Communications Commission (FCC) or other appropriate government 

oversight agency requirements.

26. The documents required under 14 CFR 91.9 and 91.203 must 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.

27. The UA must remain clear and yield the right of way to all other manned aviation operations and 

activities at all times.

28. The UAS may not be operated by the PIC from any moving device or vehicle.

29. The UA may not be operated over congested or densely populated areas.

30. Flight operations must be conducted at least 500 feet from all nonparticipating persons, vessels, 

vehicles, and structures unless:

a. Barriers or structures are present that sufficiently protect nonparticipating persons from the UA 

and/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
1st Landing LLC Ph: 631-750-9238 Email: nick@accsystemsinc.com

within 500 feet of the UA, flight operations must cease immediately and/or; 

b. the aircraft is operated near vessels, vehicles or structures where the land owner/controller has 

granted permission 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, and

c. operations nearer to the PIC, VO, operator trainees or essential persons do not present an undue 

hazard to those persons per § 91.119(a).

31. All operations shall be conducted over private or controlled-access property with permission from the 

land owner/controller or authorized representative. Permission from land owner/controller or authorized 

representative will be obtained for each flight to be conducted.

32. Any incident, accident, or 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's UAS Integration Office 

(AFS-80) within 24 hours. Accidents must be reported to the National Transportation Safety Board 

(NTSB) per instructions contained on the NTSB Web site: www.ntsb.gov.

We are prepared to modify or amend any part of this request to satisfy the need for an equivalent level of safety. 

We look forward to working with your office. Please contact us at any time if you require additional information or 

clarification. 

The name and contact information of the applicant are: 

1st Landing LLC 

Attn: Nicholas Addonisio

125 Wilbur Place

Suite 200

Bohemia, NY 11716

Ph: 631-750-9238

Email: nick@accsystemsinc.com

 Sincerely, 

 //signed//

 Nicholas Addonisio

 Managing Partner

Appendices: 

A. Exemption Request and Equivalent Level of Safety 

B. Maintenance Procedures 

C. Training Program 

D. Aviation Experience

E. Aircraft Manuals
1st Landing LLC Ph: 631-750-9238 Email: nick@accsystemsinc.com

APPENDIX A

EXEMPTION REQUESTS AND EQUIVALENT LEVEL OF SAFETY

1st Landing LLC requests an exemption from the following regulations as well as any additional regulations that 

may technically apply to the operation of rotary sUAS: 

14 CFR 61.113 Private pilot privileges and limitations: Pilot in Command and 61.133 Commercial pilot 

privileges and limitations. 

The regulation provides that no person that holds a private pilot certificate may act as pilot in command of an 

aircraft for compensation or hire. Subparagraph (b) allows a private pilot to act as pilot in command of an aircraft 

in connection with any business or employment if: (1) The flight is only incidental to that business or employment; 

and (2) The aircraft does not carry passengers or property for compensation or hire. 

Since there are currently no means available for the pilot of a UAS to gain the experience in an equivalent category 

and class in order to apply for a commercial pilot's license, we propose to generate an equivalent level of safety by 

requiring our pilots to hold a private 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 91.119 Minimum safe altitudes: General. 

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

any person, vessel, vehicle, or structure. Since the aircraft will be operating at a maximum of 400 feet AGL, we 

cannot comply with this requirement. 

To provide an equivalent level of safety we will only fly over private property with the permission of the land 

owner. The land owner will be briefed of the expected route of flight and the associated risks to persons and 

property on the ground. We maintain that due to the small size of the aircraft, the hazard to persons, vessels, 

vehicles, and structures is not comparable to manned aircraft and should be considered in granting the exemption. 

(See appendix C section 6.4.1 Consideration about risks related to ground impacts) 

The aircraft will not be operated over congested areas nor over any open air assembly of persons. The aircraft will 

be operated at an altitude allowing, if a power unit fails, an emergency landing without undue hazard to persons or 

property on the surface. 

14 CFR 91.121 Altimeter settings. 

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

within 100 nautical miles of the aircraft. The aircraft will fly below 400 feet AGL and will not need to maintain 

hemispherical cruising altitudes in order to de-conflict with other aircraft. As such, an appropriate altimeter 

measurement presented to the pilot should be Above Ground Level and should be based on the barometric pressure 

at the point of launch. To provide an equivalent level of safety, the UAS's AGL altimeter will be set to zero on the 

ground prior to every flight. Since the aircraft will fly no more than 50 minutes, even rapid changes in barometric 

pressure will have limited effect on the safety of the flight. 

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 a reserve of energy as a safety buffer for go-arounds and other delays to 

landing. 

The aircraft are battery operated and the maximum duration of flight from a single battery charge is less than 30 

minutes. 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. 
1st Landing LLC Ph: 631-750-9238 Email: nick@accsystemsinc.com

The PIC will not initiate flight unless there is enough power to fly to the first point of intended landing and, 

assuming normal cruising speed, land the UA with sufficient battery power remaining.

14 CFR Subpart E (91.401 - 91.417) - Maintenance, Preventive Maintenance, and 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." 

As provided in the attached Maintenance Procedures (Appendix D) and User’s Manual (Appendix E), the PIC will 

ensure that the aircraft is in an airworthy condition prior to flight and conduct detailed inspections after every 10 

hours. 

Maintenance performed by the PIC is limited to repairing small cracks, replacing a propeller, and updating software 

and firmware. All other maintenance will be performed by the manufacturer. 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. 
1st Landing LLC Ph: 631-750-9238 Email: nick@accsystemsinc.com

APPENDIX B

MAINTENANCE PROCEDURES

Aircraft Maintenance

Pre-flight maintenance inspections of the sUAS are detailed in 3D Robotics and Aerosky Manuals. 1st 

Landing’s chief pilot has implemented a policy of requiring reference to inspection checklists prior to each 

flight. The procedures include a visual inspection as well as a series of automated status checks performed by 

the sUAS’s internal firmware as well as the operator’s flight control software.

Prior to each flight the PIC must 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 is 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 must be included in the preflight inspection. All maintenance and alterations must be 

properly documented in the aircraft records. 

Post-flight maintenance inspections include a visual inspection as well as a comparison of flight data tracked 

onboard the UAS with the data tracked on the Ground Control Station to verify the integrity of the telemetry 

data relayed to the operator in flight.

Internal safety requirements also contain inspection and maintenance actions that are to be performed in 

between flights. These procedures effectively evaluate the airframe, motor, servos and sensors. The PIC will

make an entry in the aircraft record of the corrective action taken against discrepancies discovered between 

inspections. 

Any UAS maintenance or alterations that affect the UAS operation or flight characteristics, e.g. replacement of 

a flight critical component, must undergo a functional test flight. The PIC who conducts the functional test 

flight must make an entry in the aircraft records. 

Each UAS operated under this exemption will comply with all manufacturer System and Safety Bulletins. 

1st Landing will carry out its maintenance, inspections, and record keeping requirements, in accordance with 

the operating documents. Maintenance, inspection, and alterations will be noted in the aircraft records, 

including total flight hours, total flight hours of critical aircraft components such as batteries and propellers,

description of work accomplished, and the signature of the PIC returning the UAS to service. The aircraft 

records will be kept with the UAS and up to date data will be tracked and electronically maintained by 1st 

Landing.

Software Maintenance

Occasionally, the UAS manufacturer may release software upgrades to provide additional features to or to 

address potential issues. The Ground Control Software checks for new versions during start-up and will display 

a message with update instructions if a new version is available. Every updated version of the Ground Control 

Station software is packaged with an accompanying firmware revision which must be installed on the drone 

before it can be used. Any potentially mismatched software between the Ground Control Station and the 

firmware on the sUAS is identified by the Ground Control Station’s software and must be remedied before the 

aircraft can be advanced into a ready for flight condition.
1st Landing LLC Ph: 631-750-9238 Email: nick@accsystemsinc.com

APPENDIX C

TRAINING PROGRAM

1st Landing’s training program capitalizes on experience gained from civilian as well as multiple US Air Force 

flight training programs. If and when 1st Landing adds additional UAS pilots to its operation, the chief pilot 

will ensure that qualified pilots complete a comprehensive flight training program. This flight training will 

include academic study, simulated flight and supervised training flights. 1st Landing personnel have 

completed this training program and will adopt and augment it to train any and all of its future additional 

pilots. 

1st Landing will not permit any PIC to operate the UAS unless that PIC has demonstrated through our training 

program that the PIC is able to safely operate the UAS in a manner consistent with how the UAS will be 

operated under this exemption, including evasive and emergency maneuvers and maintaining appropriate 

distances from persons, vessels, vehicles and structures. In accordance with our training plan, all PICs will 

pass a written test of standard operating procedures as well as emergency actions, perform a simulated flight, 

and fly with a 1st Landing evaluator pilot until endorsed for PIC duties. 

Any 1st Landing, manufacturer, or FAA issued safety bulletins will be maintained in a Flight Crew 

Information File and signed off by the PIC prior to their next flight. If changes to operating procedures are 

mandated, the new procedures will be fully instructed to all pilots and observers and simulated flights will be 

performed to verify that the procedures are understood. 

Pilots wishing to advance to the ranks of instructor pilots will undergo additional training. Instructor 

candidates will demonstrate their suitability for the increased level of responsibility through written 

examination testing their knowledge and verbal evaluation of their teaching ability. They will first be 

supervised while instructing until endorsed by an evaluator pilot to assume full instructor pilot duties.

Evaluator pilots will be hand-picked from the ranks of instructor pilots and will be endorsed for evaluator 

duties by 1st Landing’s chief pilot. Evaluator pilots can perform spot checks to ensure that flight operations 

are conducted according to standards, and they can prescribe additional training for individual pilots or issue 

Flight Crew Information File bulletins to address the entire crew force.

Training records will be tracked and maintained electronically by 1st Landing and will be furnished for 

evaluation if requested. 
1st Landing LLC Ph: 631-750-9238 Email: nick@accsystemsinc.com

APPENDIX D

AVIATION EXPERIENCE

After training in a civilian flight training program for his private pilot’s license, 1st Landing’s founding 

member and Chief Pilot (Nicholas Addonisio) has gained extensive experience during his 13 years as a private

pilot and maintained a flawless flight safety record. His qualifications include:

 Rating – Airplane Single Engine Land, Private Pilot, Certificate # 3058362

 Training – Mid Island Air Service (midislandair.com) at both Brookhaven Calabro Airport (Class G 

Airport) & Long Island McArthur Airport (Class C Airport)

 Total hours (Airplane Single Engine Land) – 192.5

o Approximately 30.0 Hours of Instrument IFR Training

o 1.0 Hours – Robinson R-22 Helicopter

o 1.0 Hours – Glider

The Chief Pilot also has extensive experience operating remotely piloted aircraft as flying these vehicles has 

been a long-standing hobby of his prior to seeking a commercial exemption.
1st Landing LLC Ph: 631-750-9238 Email: nick@accsystemsinc.com

APPENDIX E

AIRCRAFT MANUALS

{User Manual begins on next page starting with the title page}