JINOBRONISYSTAENS 

LLC 

June 10, 2015 

U.S. Department of Transportation 

Docket Management System 

1200 New Jersey Ave., SE 

Washington, Dc 20590 

Re: Petition of AeroDrone Systems, LLC for Exemption Pursuant to Section 333 of the 

FAA Modernization and Reform Act of 2012. 

To Whom It May Concern: 

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 and 14 CFR Part 11, 

AeroDrone Systems, LLC (ADS), hereby applies for an exemption from Federal Aviation 

Regulations (FARs) identified below, to allow commercial operations of small unmanned aerial 

system (i.e., sUAS). 

This exemption is made based on information in this petition, the enclosed DJI UAS 

manufacturer's operations and/or instruction manual, DJI UAS User's manuals, DJI UAS Quick 

Start Guides, and any other requirements established by the FAA pursuant to Section 333 of the 

Reform Act. 

This exemption would permit commercial operation by ADS, which presently operates a DJI 

Phantom 3 Professional QuadCopter; however this model sUAS may not be used exclusively and 

may be upgraded as more advanced sUAS systems become available, but in all cases the sUAS 

will weigh less than the 55 pound weight limit to conduct the following operations: 

1. To offer flight training to persons individually or belonging to both private and/or public 

organizations that have an interest in the use and application of sUAS for the purpose of 

the safe operation of sUAS to enhance the safety of the National Airspace System (NAS) 

as well as for the protection of the persons and property. 

2. Aerial photography and/or video for public/private use including real estate, architecture, 

land surveying, and other related professional activities. 

3. Aerial inspection/photography of residential/commercial structures under contract with 

the owners or local government's authority and permission. 

4. Aerial video/photography/live video feed to assist with search and rescue operations in 

cases of an emergency or natural disaster only when local authorities or government has 

requested it by contract or donation. 

5. To proactively encourage sUAS capability and safety demonstrations to the general 

public and local government agencies in an effort to collectively convince these 

organizations that the operation of sUAS is safe, controlled and in the public interest. 

Page 1- ADS Exemption Request 
IINOBRONISYSTIMS 

«< 

For your convenience, ADS has organized this exemption request as follows: 

I. Petitioner's Description 

II. Regulations from which the exemption is requested (see attached appendix) 

III. Description of Proposed Operations 

W. Public Interest 

V. Federal Registry Summary 

VI. Conclusion 

VII. Attachments 

I. Petitioners Description 

Petitioner is wholly-owned by John R. Fiandola, a U.S. citizen. Mr. Fiandola is an active FAA 

Rotorcraft/Helicopter Commercial Pilot with CFI Rotorcraft/Helicopter endorsement (initial CFI 

Sept. 1997), and a current Second Class Medical. Mr. Fiandola has 26 years of aviation 

experience which was acquired as a helicopter pilot with a police department and commercial 

operators. Mr. Fiandola is currently a contract helicopter pilot to a major Northeast police 

department's Environmental Protection Uit. Mr. Fiandola has also been involved in the radio 

controlled aircraft hobby for 30 years and has extensive experience in building, maintaining and 

flying radio controlled airplanes and helicopters. This combined experience and knowledge will 

ensure "for the safe operation of such aircraft systems in the National Airspace System" Section 

333(c) of the Reform Act. 

The contact information for Petitioner is as follows: 

AeroDrone Systems, LLC 

3712 Paradiso Circle 

Kissimmee, FL 34746-1950 

Attn: John R. Fiandola 

Tel: 516-901-1631 

E-Mail: JohnF3305@aol.com 

II. Regulations from which Exemption is requested (see attached appendix) 

14 CFR Part 21 subpart H 

14 CFR 45.23 (b) 

14 CFR 61.113 

14 CFR 91.7 (a) 

14 CFR 91.9 (b) (2) 

14 CFR 91.103 

14 CFR 91.109 

Page 2- ADS Exemption Request 
JINOBBONISYSTINS 

LLC 

14 CFR 91.119 

14 CFR 91.121 

14 CFR 91.151 (a) 

14 CFR 91.203 (a) (b) 

14 CFR 91.205(b) 

14 CFR 91.215 

14 CFR 91.405 (a) 

14 CFR 91.407 (a) (1) 

14 CFR 91.409 (a) (2) 

14 CFR 91.417 (a) (b) 

III. Description of Proposed Operations 

The proposed operations in this petition for exemption qualify for expedited approval under 

Section 333 of the Reform Act. Each of the statutory criteria and other relevant factors are 

satisfied. 

The proposed operations would permit ADS the use of small sUAS under controlled conditions 

in airspace that is: (1) predetermined; (2) controlled as to access; and that (3) provides an 

increased level of safety beyond that existing when fixed or rotor wing aircraft are used to 

accomplish the same purpose. 

All sUAS operated under this exemption will have characteristics in common that warrant 

approval. All of the sUAS will be limited to a maximum speed of 55 m.p.h., vertical ascent 

speed of 15 m.p.h. and maximum weight with payload of 50 pounds. Each of the sUAS has an 

integrated GPS system to calculate its position and height and to relay that information via a 

secure connection to the sUAS operator. In addition, each sUAS contains a failsafe mode that 

will return the sUAS to its original starting point in the event that the secure connection from the 

controller to the sUAS is lost or compromised. This system permits the sUAS to return to a 

predetermined location and land in order to prevent injury to person(s) or damage to property. 

To assist the FAA in its safety assessment of Petitioner's operations, the operational limitations 

and conditions listed below will be adhered to at all times. 

l. The sUAS vehicles employed by Petitioner will weigh 50 pounds or less with payload. 

2. Flights will be limited to a maximum 55 m.p.h. speed, maximum 15 m.p.h. vertical 

ascent speed. 

3. Maximum total flight time will be limited to the flight time of the sUAS and still 

maintain a reserve battery power of no less than 20 percent. 

Page 3- ADS Exemption Request 
AFROONgNISYSTIMS 

LLC 

4. Flights will be limited to a maximum altitude of 400 feet AGL and will not be conducted 

within navigable airspace. 

5. Flights will always be within line-of-sight of the sUAS Pilot-in-Command (PIC) and 

camera/sensor operator (if camera/sensor operator is required) and will take place in day 

VFR conditions only. 

6. The PIC will have, at a minimum, a FAA private Pilot's license and current Third Class 

medical certificate, however the petitioner will be the sole operator of all sUAS at this 

time and exceeds the current proposed standard with a FAA Commercial Pilots license 

and current Second Class Medical certificate. 

7. Flights will be operated at a lateral distance of at least 100 feet from any inhabited 

structures, buildings, vehicles, vessels or person(s) not associated with the operation who 

have not given prior permission for more proximate operation. 

$. Prior to flight, the sUAS and related equipment will be pre-flight checked to determine 

that all is in working order and can accomplish the proposed flight in a safe manner. 

9. The sUAS will operate in accordance with the safety and operational requirements of 

their respective flight manuals. 

10. A mission plan will be prepared setting forth the limitations for each flight as well as 

contact information. 

11. All required permissions and permits, if necessary, will be obtained from state, county 

or city jurisdictions, including local law enforcement, fire or other appropriate 

governmental agencies; and from any commercial or private property owners/residents 

who may be impacted by any flight. 

12. If the sUAS loses secure communications from the controller, the sUAS will have the 

capability to return to a predetermined location and land in order to prevent injury to 

person(s) or damage to property. 

13. The sUAS has the capability to abort a flight in case of unpredicted obstacles, weather 

or emergencies. 

14. ADS will insure that all flights will be conducted in accordance with any federal, state 

or local laws regarding privacy. 

15. Petitioner has policies in place to ensure that no person may act as PIC, observer, or 

sensor operator if they are under the influence of any alcohol or any drug. 

IV. Public Interest 

Granting Petitioner's exemption request furthers the public interest. National policy set by 

Congress favors early integration of sUAS into the national airspace in controlled, safe working 

environments such as those proposed in this petition. In addition, the public has an interest in 

reducing the hazards and emissions associated with the use of manned helicopters to conduct 

similar operations. The sUAS proposed for this exemptions are very light, 5-7 pound gross 

weight, well under the FAA maximum of 55 pounds. They do not carry flammable fuel which 

further reduces any risk from a potential accident. 

The sUAS proposed by Petitioner can be used in all areas of real estate, including commercial, 

residential and industrial properties. The use of sUAS in place of manned helicopters, where 

Page 4- ADS Exemption Request 
JIBOBBONISYSTIMS 

LLC 

appropriate, will allow real estate professionals of all levels be able to afford to have videos, and 

photos that give a unique perspectives of properties to promote them in their best light. 

Petitioner will also be willing to coordinate with federal, state and local governments after a 

disaster and be willing to render any and all assistance that can be provided by sUAS that may 

not be possible by manned aircraft. 

Finally, Petitioner would like to donate his time to demonstrate the safety, utility and efficiency 

of sUAS to the public, FAA, any local government, law enforcement or firefighting agency, or 

school to educate them on the integration of sUAS in the National Airspace System. 

V. Federal Registry Summary 

Pursuant to 14 CFR Part 11, the following summary is provided for publication in the Federal 

Register, should it be determined that publication is needed: 

Petitioner seeks an exemption from the following rules: 

14 CFR Part 21 subpart h, 14 CFR 45.23(b), 14 CFR 61.113, 14 CFR 91.7(a), 14 CFR 91.9 

(b)(2), 14 CFR 91.103(b), 14 CFR 91.109, 14 CFR 91.119, 14 CFR 91.121, 14 CFR 91.151(a), 

14 CFR 203(a)(b), 14 CFR 91.205(b), 14 CFR 91.215, 14 CFR 91.405(a), 14 CFR 91.407(a)(1), 

14 CFR 91.409 (a)(2), 14 CFR 91.417(a)(b) 

The exemption will enhance safety by reducing risk to the general public and property owners 

from the potential hazard posed doing the same operations with conventional aircraft and 

helicopters. 

VI. Conclusion 

Satisfaction of the criteria provided in Section 333 of the Reform Act of 2012 provides more 

than adequate justification for the grant of the requested exemptions to permit Petitioner to 

operate the described sUAS in the NAS while reducing risk to the general public and property 

C~]~.+flNRI 

The operation of this sUAS will provide and equivalent level of safety, supporting the grant of 

the exemptions requested herein, including exempting the applicant from the requirements of 

several regulations and allowing commercial operations. These lightweight sUAS operate at 

slow speeds and close to ground, as a result they are far safer than conventional aerial survey and 

inspection operations conducted with fixed wing aircraft or helicopters. 

Page 5- ADS Exemption Request 
JINVORONISYSTINS 

«C 

VII. Attachments 

1. Regulations from which the exemption is requested. 

2. Phantom 3 Professional Quick Start Guide 

3. Phantom 3 Professional User Manual V1.2 

4. Phantom 3 Professional Safety Guidelines and Disclaimer 

5. Phantom 3 Professional Intelligent Flight Battery Safety Guidelines 

If any additional information is required, or if you have any questions regarding this Petition for 

Exemption, please contact the undersigned. 

Sincerely, 

John R. Fiandola, owner 

AeroDrone Systems, LLC 

Cell Phone: 516-901-1631 

Email: JohnF3305@aol.com 

Page 6- ADS Exemption Request 
JINOBBONISYSTIMS 

LLC 

CFR Section Subject Justification 

14 CFR 45.23(b) Requirement to display Insufficient space on sUAS 

registration number on 

sUAS 

14 CFR Part 21 subpart H Aircraft certification Designed for manned flight, 

requirements and procedures not suitable for off-the-shelf 

sUAS 

14 CFR 61.113 Requirement for pilot Part 61 requirements are 

certificate designed for manned aircraft; 

however petition will exceed 

current FAA pilot certification 

requirements 

14 CFR 91.7(a) Airworthiness requirement Designed for manned aircraft, 

not suitable for off-the-shelf 

sUAS 

14 CFR 91.9(b)(2) Requirement for airplane or No room on sUAS, but the 

rotorcraft flight manual to sUAS flight manual, 

be on aircraft registration certificate and any 

other required documents will 

be kept with the PIC during 

flight 

14 CFR 91.103(b) Requirement for crew sUAS is unmanned aerial 

members to be onboard vehicle incapable of holding 

during flight crew members 

14 CFR 91.109 Requirements for dual sUAS is unmanned aerial 

controls during flight vehicle, however during flight 

instruction instruction the student and 

flight instructor can share a 

common remote controller 

with no compromise in safety 

14 CFR 91.119 Minimum safe altitudes for Maximum altitude of sUAS is 

flight 400 feet, which is below the 

minimum safe altitude of 500 

feet and PIC has altitude 

information on the control unit 

Attachment 1: Regulations from Which the Exemption is Requested Page 1 
JINOBBONISYSTIMS 

LLC 

CFR Section Subject Justification 

14 CFR 91.121 Altimeter settings No barometric altimeter on 

board sUAS, however control 

unit has GPS altitude readout 

14 CFR 91.151(a) Fuel requirements Minimum fuel requirements do 

not apply to sUAS as battery 

life is below the minimum fuel 

required, however PIC sUAS 

control unit has an information 

readout that displays remaining 

battery life and the sUAS will 

land with a minimum of 20% 

battery life 

14 CFR 91.203(a)(b) Requirement for registration No room on sUAS, but the 

and airworthiness registration certificate and any 

certificates to be on board other required documents will 

be kept with the PIC during 

flight 

14 CFR 91.205(b) Cockpit instruments No one on board to read, 

however PIC has a readout on 

the control unit that gives 

airspeed, altitude, climb rate, 

heading, remaining battery life, 

GPS signal strength and other 

information to insure a safe 

flight 

14 CFR 91.215 Transponder requirement No room on the sUAS, will 

also be operated below ATC 

radar coverage 

14 CFR 91.405(a) Inspection requirements Designed for manned aircraft, 

not suitable for off-the-shelf 

sUAS however sUAS will be 

maintained as per the user 

manual, safety guidelines and 

battery safety guidelines 

Attachment 1: Regulations from Which the Exemption is Requested Page 2 
IFROBBONISYSTIMS 

LLC 

CFR Section Subject Justification 

14 CFR 91.407(a)(1) Inspection approval Designed for manned aircraft, 

requirements not suitable for off-the-shelf 

sUAS however sUAS will be 

inspected as per the user 

manual, safety guidelines and 

battery safety guidelines 

14 CFR 91.409(a)(2) Airworthiness inspection Designed for manned aircraft, 

not suitable for off-the-shelf 

sUAS however sUAS will be 

inspected as per the user 

manual, safety guidelines and 

battery safety guidelines 

14 CFR 91.417(a)(b) Maintenance records Designed for manned aircraft, 

requirements not suitable for off-the-shelf 

sUAS however maintenance 

records will be kept to show 

any repair work, required 

software/firmware upgrades, 

battery charge history as per 

the sUAS manufacturer 

Attachment 1: Regulations from Which the Exemption is Requested Page 3