May 20,2015 

Elite Unmanned Aerial Systems, LLC 

101 Lightwater Court 

Aberdeen, NC 28315 

785-979-8560 

ELITEUAS@GMAIL. COM 

U.S. Department of Transportation 

Docket Management System 

1200 New Jersey Ave., SE 

Washington, DC 20590 

Submission of Request for Authorization to Conduct Unmanned Aircraft 

Systems Operations Allowed by Section 333 of the FAA Modernization and 

Reform Act of 2012 Through the Exemption Process Identified Under 14 C.F.R. 

Section 11.81 

FAA Regulatory Docket 

NAME AND ADDRESS OF PETITIONER 

Elite Unmanned Aerial Systems, LLC 

Attn: John P. Cross 

101 Lightwater Ct. 

Aberdeen, NC 28315 

785-979-8560 

ELITEUAS@GMAIL. COM 
Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012, 

Pub. L. No. 112-95 (2012), 126 Stat. 11 ("Section 333") and the Federal Aviation 

Administration's ("FAA") general exemption authority under 49 U.S.C. § 44701 (f), 

Elite UAS, LLC ("Petitioner or Operator") hereby petitions for exemptions from 14 C.F.R. 

Part 21, 14 C.F.R. §§ 61.113(a) and (b), 61 .133(a), 91 .7(a), 91.9(b)(2), 91.103(b)(1), 

91.119(c), 91 .121, 91 .151, 91.203(a) and (b), 91.405(a), 91.409(a)(1) 91.409(a)(2). 

I. Petition Summary 

If granted, this exemption would allow Elite UAS, LLC to conduct commercial unmanned 

aerial systems (UAS) operations for the agriculture, oil and gas, aerial 

photography/videography, aerial imaging and wildlife preservation industries, within the 

United States National Airspace System (NAS); within Class G and occasionally E 

airspace. The mitigating factors listed below provide the framework for Elite UAS to 

operate the DJIInspire 1 in a manner equal to the safety standards set forth by the FAA 

for civilian manned aircraft: 

• Reliability of UAS 

• Return to designated point in the event of a lost control link 

• Return to designated point automatically with a low battery that is 

dynamically updated depending how far away the UAS is from the 

designated point 

• Low weight 

• Slow speed 

• No passengers to be carried 

• Experienced and FAA certified pilots 

• Stringent maintenance program 

• UAS knowledge and skills test administered by an FAA approved 

instructor 

II. Exemptions Requested 

The operator is requesting relief from the following FAA regulations: 

• FAR part 21 (Certification procedures) 

• FAR 61 .113 (a) and (b) (Private pilot privileges and limitations) 

• FAR 61 .133(a) (Commercial pilot privileges and limitations) 

• FAR 91.7(a) (Civil aircraft airworthiness) 

• FAR 91 .9(b)(2) (Civil aircraft flight manual, markings, placards 

requirement) 

• FAR 91 .103(b)(1) (Preflight action) 

• FAR 91 .119(c) (Minimum safe altitudes) 
• FAR 91.121 (Altimeter settings) 

• FAR 91 .151 (Fuel requirements) 

• FAR 91.203(a) and (b) (Civil aircraft certifications required) 

• FAR 91.405(a) (Maintenance Required) 

• FAR 91.409(a)(1) and (a)(2) (Inspections) 

Ill. Operational Procedures to Satisfy Section 333 

1 Unmanned Aircraft System 

1.1 Elite UAS seeks exemption to operate the DJIInspire 1. This UAS is 

the most recent model OJI offers and was a highly improved from 

the previous highly popular and reliable OJI Phantom series. The 

DJI Inspire 1 is a 6.471b multi-rotor (4 rotors) UAS with 

approximately 18 minutes of endurance. The Inspire 1 's purpose is 

to carry a small camera as its payload. The Inspire 1 has the ability 

to be controlled by a single crewmember acting as pilot in command 

by wireless remote control on a 2.4GHz band having a transmitting 

distance of 2km (1.08nm). 

1.2 The Inspire 1 is equipped with lost link protection (referred to as 

"Return To Home" (RTH) in the Inspire 1 User Manual), allowing the 

UAS to automatically climb vertically to a safe altitude to clear 

obstacles; then proceed to a pre-designated point to automatically 

land. At any time the UAS and the controller reestablish link, the PIC 

can cancel the RTH and resume control of the UAS. In the event of 

lost GPS signal, control to the Inspire UAS is not lost. All operations 

will be conducted under Visual Line of Sight (VLOS) ensuring the 

PIC can control the aircraft back to a safe location to land. 

1.3 Because the Inspire 1 UAS does not have the endurance to meet 

the requirements of FAR 91.155(b), the operator is requesting 

exception from this regulation and substituted with the following 

standard: All flights will be terminated at a maximum of a 25-minute 

flight or when the battery level reaches 25% (whichever occurs first). 

1.4 The operator will register the UAS lAW FAR part 47. The operator's 

UAS will have identification makings in accordance with FAR 45(c). 

The Inspire 1 UAS is too small to practically display registration 

markings lAW FAR 45.29(a) though (e). The registration marks will 

be affixed as large as practical lAW FAR 45.29(f). 

1.5 The operator is requesting relief from FAR 91.121 because the 

Inspire UAS is not equipped with a standard adjustable barometric 

altimeter system. The Inspire 1 UAS collects altitude information for 
two sources: GPS and barometric aiding. Upon powering one the 

Inspire 1, the system will reset the altitude readout on the controller 

base station to 0 feet above ground level (AGL). The PIC then will 

reference the digitally displayed altitude in AGL for the duration of 

the flight. 

1.6 Because of the small size, low weight, slow speed, and limited 

operating area of the Inspire 1 UAS, the operator is requesting relief 

from CFR part 21 (h) (airwortl:liness certificates). The operator has 

determined that it can operate the Inspire 1 UAS to an equivalent 

level of safety set forth under part 21 of the CFRs and meets the 

requirements set forth in the 333 exemption. 

1.7 Prior to flight operations the Inspire 1 UAS will be determined to be 

in an airworthy condition lAW the pre-flight checklist outlined in 

appendix A Inspire 1 User Manual V1 .0 page 49. The operator is 

requesting exemption from required inspections of FAR 91.409(a) 

(1) and (2) and will adopt the manufactures recommended 

inspections program as outlined in the following paragraph. Because 

the FAA has not established an inspection standard for UAS as 

have been established for manned aircraft under FAR 43.13 

appendix D, the operator is requesting an exemption from the 

maintenance scope and detail of FAR 43.13 appendix D and 

replaced with the manufactures recommended maintenance 

program: The operator will inspect and maintain the Inspire 1 UAS 

lAW DJIInspire 1 Maintenance Manual (See appendix B Inspire 1 

Maintenance Manual). The operator will follow the manufactures 

recommended inspection interval to preform comprehensive 

maintenance of the Inspire 1 every 50 flight hours or 200 flights, 

whichever comes first as outlined in the Inspire 1 Maintenance 

Manual. 

1.8 The operator will adopt maintenance record requirements set forth 

under FAR 91.417. 

1.9 The DJIInspire UAS operates on the 2.4GHz frequency band for 

both UAS control as well as video downlink. Both the Inspire 1 UAS 

as well and the UAS remote controller comply with part 15 of the 

FCC rules (see page appendix A, page 62 of the OJ I Inspire user 

manual). The Inspire 1 is equipped with a vision positioning system 

along with a sonar system in order to be able to fly inside a building 

and still remain stable. The Inspire 1 's primary payload is a small X3 

model FC350 camera mounted with a Zenmuse X3 gimbal. 

1.10 Refer to appendix A Inspire 1 User Manual V1.0 for more detail on 

the Inspire 1 UAS. 
2. Unmanned Aircraft Pilots in Charge (PIC) 

2.1 PIC's will at a minimum, meet the following requirements prior to 

conducting commercial flights; 

• Hold a FAA Private Pilot License 

• Hold a FAA third class medical or higher 

• Meets the flight review requirements of FAR 61.56 in 

manned aircraft 

• Meets the recent flight experience for PIC of FAR 61.57 

(UAS takeoff/landings) 

• Has accrued 25 hours total time operating the OJI Inspire 1 

• Pass a knowledge and skill test with an 80% or better 

administered by an FAA certified instructor 

2.2 The PIC will designate a Visual Observer (VO) prior to any flight to 

be conducted. Any VO to be used by the PIC must be designated by 

PIC and be present in all mandatory meetings and pre-flight 

rehearsals. Further, the VO shall be familiar with UAS operations to 

the extent their designated role as VO requires. The VO will be 

required to communicate with the PIC verbally at all times. 

2.3 It will be the PIGs responsibility to review weather conditions, flight 

battery requirements, and UAS performance limitations prior to 

conducting the flight. 

2.4 PIC's and VO's will attend pre and post flight mission briefs which 

will consist of weather information, flight information to include 

operational area and mission objectives, hazard mitigation actions 

and most importantly emergency and abort procedures; also 

included will be any NOTAMs or improvements to standard 

operating procedures through further refinements in operations. 

2.5 PIC's and VO's will sign applicable documentation verifying their 

attendance to mandatory briefs as well as produce daily pre and 

post flight inspections and flight logs. 

3. UAS Operating Procedures 

3.1 All UAS flight operations will be conducted during daylight hours. 

3.2 All UAS operations will be conducted in VFR conditions. 
3.3 No UAS operation will be conducted with less cloud clearance or 

visibly then is allowed by FAR 91.155. 

3.4 No UAS flight operations will be conducted beyond the visual sight 

both the PIC and the VO. 

3.5 No UAS flight operation will be conducted above a vertical height of 

400ft AGL. 

3.6 NO UAS flight operations will be conducted within highly populated 

areas. 

3.7 The PIC will not fly the UAS at speeds to exceed 50KTS ground 

speed. 

3.8 The PIC will insure that no person, other than those trained are within 

500ft of horizontal distance from the UAS during flight operations or 

while the rotors are turning. 

3.9 The PIC will insure that the UAS in flight comes no closer than 250ft 

of vehicles or structures, with the exception of those that are a under 

direct observation as a result of pre-negotiated services performed by 

Elite UAS. 

3.10 Prior to any UAS flight operation the PIC will consult current FAA 

aeronautical sectional charts and airport facility directory to insure 

that no flight operation will come within 5NM of an airport with a 

control tower,3NM of an airport not having an operational control 

tower but having a published instrument approach procedure, 2NM of 

an airport not having an operational control tower or instrument 

approach procedure, or 2NM of a heliport having an instrument 

approach procedure without having an appropriate authorization from 

the A TC controlling facility and airport manager. 

3.11 PIC will remain clear and yield right of way to all manned aircraft 

operations of all category and classes. 

3.12 The PIC prior to conducting UAS flight operations will review current 

aeronautical charts, TFRs, and NOTAMS to insure that no flight 

operations will be conducted within an active restricted area, 

prohibited area, warning area, or TFR. 

3.13 Prior to UAS operations for the motion picture or television industry, 

the operator will comply with regulations set forth in FAA order 

8900.1, Volume 3, chapter 8, section 1 (Certificate of Waiver for 

Motion Picture and Television Filming). 
3.14 Operator will obtain an Air Traffic Organization (ATO) certificate of 

waiver or authorization (COA) prior to conduction UAS operations. 

3.15 Operator, as required by the COA, will request a NOT AM be filed for 

the UAS operation at least 48 hours in advance, but not more than 72 

hours in advance. 

IV. Conclusion 

We feel confident that with the above provided information the FAA will find Elite UAS 

qualified for the exemptions allowed under section 333 of the FAA Modernization and 

Reform Act of 2012. We would be happy to answer any questions regarding this 

exemption request if needed. 

~ :p:c;oss 

President and CEO 

Elite UAS