The Rome Drone

Owner: Braden Keith

147 Selman Rd NW

Rome, GA 30165

Re: Exemption Request Pursuant to Section 333 of the FAA Reform Act and Part 11 of the Federal Aviation Regulations from: 14 CFR 21 subpart H; 

14 CFR 45.23(b); 14 CFR 61.113(a) and (b); 14 CFR 91.7(a); 14 CFR 91.9(b)(2); 14 CFR 91.103; 14 CFR 91.109; 14 CFR 91.119(c); 14 CFR 91.121; 

14 CFR 91.151(a); 14 CFR 91.203(a) and (b); 14 CFR 91.405(a); 14 CFR 91.407(a)(1) 14 CFR 91.409(a)(1) and (2); 14 CFR 91.417(a) and (b)

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, The Rome Drone

(Braden Keith), Owner of an Unmanned Aircraft System (UAS), Hereby applies for an exemption from the listed Federal Aviation Regulations (FARs) to 

allow The Rome Drone to legally operate its DJI Phantom 3 UAS, 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.

The proposed exemption would allow The Rome Drone to operate a small UAS under controlled conditions in FAA regulated airspace that is 1) limited 

2) predetermined 3) controlled, for purposes of unmanned aerial photography and videography for real estate as well as small business promotional 

media. If the exemption is granted, The Rome Drone will conduct commercial UAS flights following all conditions set forth by the FAA Section 333 with 

emphasis on safety and operational requirements. 

Proposed Operations of The Rome Drone UAS 

● Aerial Video and Photography for Real Estate and business promotion purposes.

Upshot products will follow all FAA UAS Safety Operating Guidelines including but not limited to the following.

● The UAS will operate no more than 200 feet above ground level and within a radius of 1000 feet of Pilot in Command (PIC) and will not 

exceed 35mph.

● Operations will only occur during daytime conditions abiding by Visual Flight Rules (VFR) within Visual line of sight (VLOS) of the UAS 

pilots at all times.

● Obtain permission from the owner or representative of the owner to conduct operations

● If operations occur within 500 feet of any vessel, vehicle, or structure, a safety assessment will be conducted.

● Flight times will be limited to 10-15 minutes per flight. Allowing 25% of total battery battery to be used to safely land the UAS. This exceeds 

the manufacturer's recommended minimum battery level parameters for “return to home” function.

● DJI Phantom 3 utilizes Global Positioning System (GPS), which will automatically land (return to home) the UAS in any cases where 

Communication between PIC and craft is lost or the battery levels reach a critical level.

● DJI Phantom 3 also has “return to home” button on controller.

● Contact Airports if operations are within a 5 mile radius. Advise Airports of all pertinent information including but not limited to: time of flight, 

flight duration, elevation of flight.

● Only operate UAS in safe weather conditions. Unsafe conditions include, but are not limited to high wind, poor visibility, low clouds or any 

conditions that may cause the pilot to lose VLOS or control of the UAS.

This will be achieved by:

● Obtaining and reviewing weather reports prior to flight

● Procedures for a mid-flight abort in cases where weather or other factors cause conditions to become unsafe or dangerous. 

● Only operate in controlled environment
● Will have procedures in place to identify and avoid any hazardous areas such as power lines, street lights, trees, airports, densely 

populated areas (yellow areas on VFR charts)

● Will have procedures in place to abort flights that have safety breaches or dangerous issues.

● Will always operate UAS with 2 people, with a designated “visual observer (VO)” who will also keep constant Visual Contact with UAS 

along with PIC.

● Will have policies that will clear the operational flight area of any non-essential personnel.

● We will conduct extensive preflight inspections on the UAS, utilizing procedures that will check integrity of all operational parts including but 

not limited to: propellers, aircraft antenna, aircraft LED lights, remote buttons, control sticks, signal strength between craft and remote, signal strength 

of GPS, battery strength. 

● We will follow guidelines of 14 CFR 61.51(b) along with our own safety operation procedures.

● The PIC will have a minimum of 6 hours logged operating the craft before commercial use, along with over 10 hours operating UAS 

quadcopters in various conditions and environments. 

● The PIC holds a valid PPL, ASL, VFR Cert 3672766

● With emphasis on safety, we will have training procedures that include emergency landing, evasive maneuvers and other possible 

dangerous scenarios such as yielding the right away to any airplane or helicopter that comes within 5 miles of the operating UAS.

The Rome Drone requests exemptions from the specific regulations outlined below and any additional regulations that may technically apply to the 

operation of the UAS for purposes of acquiring photos and videos which will promote local economic growth through employment and tax base.

14 C.F.R. Part 21, Subpart H: Airworthiness Certificates 14 C.F.R. 91.203 (a) ( 1) Subpart H, entitled Airworthiness Certificates, establishes the 

procedural requirements for the issuance of airworthiness certificates as required by FAR 91.203 (a) (1 ). 

Given the size and limited operating area associated UAS, an exemption from Part 21 Subpart H meets the requirements of an equivalent level of 

safety under Part 11 and 333 of the Reform Act. Federal Aviation Act (49 U.S.C.4470 1 (f)) and 333 of the Reform Act both authorize the FAA to 

exempt aircraft from the requirement for an airworthiness certificate, upon consideration of the size, weight, speed, operational capability, and proximity 

to airports and populated areas of the particular UAS. 

In all cases, an analysis of these criteria demonstrates that the UAS operated without an airworthiness certificate, in the restricted environment and 

under the conditions proposed will be at least as safe, or safer, than a conventional aircraft (fixed wing or rotorcraft) operating with an airworthiness 

certificate without the restrictions and conditions of proposed UAS operations.

The UAS to be operated by The Rome Drone is less than 55lbs. Fully loaded, carries neither pilot, nor passengers, carries no explosive or flammable 

materials including combustible fuels, and operates exclusively within a secured area. Unlike other civil aircraft, operations under this exemption will be 

controlled and monitored by both the pilot (PIC) and “visual observer(VO)” as a secondary monitor for safety issues, and a technician, which assists in 

matters related to maintaining the UAS and also monitors for safety concerns. These enhancements to current safety practices and regulations, which 

already apply to civil aircraft, provide a greater degree of safety to the public and property owners than conventional aircraft operations conducted with 

airworthiness certificates issued under 14 C.F.R. Part 21, Subpart H. 

Lastly, application of these same criteria demonstrates that there is no intrinsic credible threat to national security posed by the UAS, due to its size, 

speed of operation, location of operation, lack of explosive materials or flammable liquid fuels, and inability to carry a substantial external load. 

14 CFR 45.23(b) Display of marks; general and 45.29 Size of marks

These regulations provide that each aircraft must display "N" and the aircraft's registration number in letters at least 3 inches high. Additionally, the 

aircraft must display the word "EXPERIMENTAL" in letters at least 2 inches high near the entrance to the cabin, cockpit, or pilot station. The UAS does 

not have an entrance in which the word "EXPERIMENTAL" can be placed. We propose an equivalent level of safety by including the word 

"EXPERIMENTAL" on the top and bottom of the aircraft, where the PIC (Pilot In Control), VO (Visual Observer) and others in the vicinity of the aircraft 

while it is preparing for launch will be able to see the designation. We will display at the ground station a high contrast flag or banner that contains the 
words "Unmanned Aircraft Ground Station" in letters 4 inches high or greater. The banner will be visible to anyone that observes the aircraft and 

chooses to investigate its point of origin.

14 CFR 91.7(a) Civil Aircraft Worthiness

The Rome Drone request an exemption from 91.7(a) which prohibits the operation of an aircraft without an airworthiness certificate, since there is 

currently no certificate applicable to our operation, this regulation is inapplicable. 

14 CFR 91.9 Civil aircraft flight manual, marking, and placard requirements.

The Rome Drone request an exemption from 91.9(b)(2) which requires an aircraft flight manual in the aircraft, however since there are no pilots or 

passengers on board the aircraft and given its size, this regulation is inapplicable. We believe an equivalent level of safety will be achieved by 

maintaining a safety/flight manual with the UAS ground station. 

14 CFR 91.119 Minimum safe altitudes

The Rome Drone requests an exemption from the minimum safe altitude requirements of 14 CFR 91.119. Section 91.119 prescribes the minimum safe 

altitudes under which aircraft may not operate, including 500 feet above the surface and away from any person, vessel, vehicle, or structure in noncongested areas. See 14 CFR 91.119(c). Section 91.119(d)(1) allows for a hazard to persons helicopter complies with any routes or altitudes 

specifically prescribed for helicopters

14 CFR 91.121 Maintain cruising altitude or flight level by reference to an altimeter

The Rome Drone requests an exemption from 14 CFR 91.121, which requires a person operating an aircraft to maintain cruising altitude or flight level 

by reference to an altimeter that is set to the elevation of the departure airport or barometric pressure. An exemption is required because the UAS does 

not have a barometric altimeter, but the Phantom 3 software has a GPS altitude meter display. PIC will use display to constantly monitor altitude during 

the flight.

14 CFR 91.151(a) 

The Rome Drone requests an exemption from 14 CFR 91.151(a) fuel requirements for flight in VFR conditions. Section 91.151 states: (a) No person

may begin a flight in an airplane under VFR conditions unless (considering wind and forecast weather conditions) there is enough fuel to fly to the first 

point of intended landing and, assuming normal cruising speed (1) During the day, to fly after that for at least 30 minutes or (2) At night, to fly after that 

for at least 45 minutes. The battery powering the Phantom 3 UAS provides approximately 25 minutes of powered flight. An exemption from the 30 

minute reserve requirement in 14 CFR 91.151 is therefore required. 

Equal levels of safety can be achieved by limiting flight times to approximately 15-20 minutes or until 25% of battery life remains, whichever comes 

first. This is more than enough battery power to achieve a safe landing.

14 CFR 91.405(a); 91.407(a)(1); 91.409(a)(2); 91.417(a)&(b) Maintenance and inspection standards in reference to 14 C.F.R. Part 43.

The Rome Drone requests exemptions from these regulations because Part 43 and these sections apply only to aircraft with an airworthiness 

certificate, which the UAS will not have. 

The Rome Drone will achieve an equivalent level of safety because maintenance and inspections will be performed in accordance with the DJI 

Phantom 3 Aircraft Operations Manual.

The operator will ensure that the UAS is in working order prior to initiating flight, perform all required maintenance, and keep a comprehensive log of 

any maintenance performed on UAS.

The UAS small size, carrying capacity, and the fact that flight operations will only take place in controlled areas for limited periods of time, create less 

risk than the same factors associated with conventional fixed-wing aircraft and rotorcraft performing the same operation.

14 CFR 91.103 PIC to become familiar with specific information before each flight
The Rome Drone requests an exemption from 91.103, which requires a PIC to become familiar with specific information before each flight, including 

information contained in the FAA approved Flight Manual on board the aircraft. As an FAA approved flight manual will not be provided for the UAS, an 

exemption will be needed. 

The equivalent Level of Safety will be achieved by following the DJI manufactures aircraft manual with comprehensive preflight checklist. Other 

comprehensive preflight information gathering and interpreting will be done by the PIC utilizing weather reports, web based mapping(google earth) 

battery requirements, determining safe takeoff and landing areas. All pertinent information will be gathered and interpreted by PIC before any flights. 

14 CFR 91.109 Flight Instruction

The Rome Drone requests an exemption from the 14 CFR 91.109(a) which provides that person may operate a civil aircraft (except a manned free 

balloon) that is being used for flight instruction unless that aircraft has fully UAS and remotely piloted aircraft, by their design do not have fully 

functional dual controls. The control box communicates with the UAS through radio communications.

Equal levels of safety will be achieved based on the size and speed of UAS an equal level of safe training can be achieved without the “dual controls”

because the UAS is unmanned and all essential personnel will be a safe distance away in the event of difficulties during the flight.

14 CFR 61.113(a) Private Pilot Privileges and Limitations: Pilot in Command

The Rome Drone requests an exemption from the private pilot privileges and limitations of 61.113 (a) & (b): Private 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. The UAS aircraft 

cannot carry passengers or property, therefore an exemption is needed. 

Public Interest

The current Aerial Photography and Videography uses either fixed wing aircraft or helicopters which have expensive operating costs, the use of large 

heavy aircrafts, and manned flight operation introduces certain elements of risk for the public and pilot safety. Along with the additional risk associated 

with manned flight, the cost to small business owners is often expensive. By granting The Rome Drone an exemption, we will be able to provide 

photography and videography at a lower cost. This will stimulate local commerce by giving the small business owner access to high quality promotional 

media, while also minimizing safety risks by utilizing a small unmanned UAS.

UAS Overview The Rome Drone will operate the DJI Phantom 3 Standard

● Dimensions

○ Size-40.36cm x 40.36cm x 19.05 x or 16inch x 16inch x 7.5inch

○ Weight- 1216g total or 2.16lbs total

● Speed

○ Under still air maximum speed is no more than 16m/s or 35mph with a cruising speed of 11m/s or 25mph

● Motors

○ 4 motors total

○ Motor model DJI 3510

● Power

○ 4480mAh LiPo 4s Lithium Polymer Battery

● Propellers

○ Model DJI 1345

● Remote Controller
○ DJI issued C3 remoter controller

○ Operating frequency- 5.725-5.825GHz

○ Live Video frequency- 2.4GHz ISM (max range- 1.2 miles)

● Operation Parameters 

○ The Rome Drone will operate the UAS with visual line of sight within a closed off pre-determined area; With authorization of the 

the property owner or representative.

DJI Phantom 3 GENERAL FEATURES

● Ready to fly

● Precision flight and stable hovering

● GPS/GLONASS positioning and auto return home

● FAA no-fly zones locked out via DJI installed software

● Onscreen real-time flight parameters

○ High Definition 4k camera

○ 3 Axis camera stabilization

○ Adobe lens profile support

○ Album synchronization

○ DJI VISION APP-System requirement of Mobile Device: iOS version 6.0 or above/ Android system version 4.0 or above

● CAMERA

○ Operating Environment Temperature- 0 degrees C to 40 degrees C

○ FOV- 94 degrees/85degrees

○ Sensor Size- 1/ 2.3”

○ Max Resolution-4096x2162p @24/25 fps

● TRANSMITTER

○ Communication Distance (open area) – CE: 2000m; FCC: 2000m

○ Transmitter Power- CE: 16dBm; FCC: 20dBm

○ Operating Frequency- 2.400 GHz- 2.483 GHz

○ Receiver Sensitivity (1%PER) :-101dBm +/- 2dBm

○ Battery- 4480mAh LiPo 4s

○ Working Voltage- 1.2A @ 7.4V

Conclusion

The approval of this application presents no national security issues. Due to the small size of the unmanned UAS and the controlled environment, all 

proposed operations will meet or exceed the Reform Act’s safety requirements. Regarding the level of safety surrounding proposed operations and the 

public/economic benefit, the grant of the requested exemption is in the public interest for the following reasons: reduction in environmental impacts, 

including but not limited to reduced emissions and noise. For this reason, The Rome Drone requests that the FAA grant the requested exemption with 

minimum delay. 

Manuals and Specifications:

- DJI Phantom 3 Standard User Manual

- https://dl.djicdn.com/downloads/phantom_3_standard/en/Phantom_3_Standard_User_Manual__V1.4.pdf
I would like to thank you for your consideration in granting the exemptions mentioned in this document. If additional information is required or if you 

have any questions please contact Braden Keith, 980.202.2119 owner of The Rome Drone

Thank you,

Braden Keith

The Rome Drone

bradenkeith@gmail.com