Drones Unlimited, LLC CEO - Bryan Gonzalez & Raymond Anthony 139 Brooks st se Fort Walton Beach, Florida 34479 Ph:352 - 361 - 1932 & 352 -816 - 5196 (September, 18, 2015) U.S. Dept. of Transportation Docket Operations West Building Ground Floor, Room w1 2 - 140 1200 New Jersey Avenue, 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 Modernizati on and Reform Act of2012 (the Reform Act) and 14 C.F.R. Part 11 Drones Unlimited, LLC seeks an exemption from Federal Avi ation Regulations { FARs ) detailed below for th e following described Unmanned Aircraft System s .

THE UNMANNED AIRCRAFT SYSTEM (UAS) DETAILS: 1) One manufacturer is DJI. It is model : Inspire1 (6.57 lb gross weight fully eq uipped). B attery only operated 4 m otor craft in the form of a quad copter that takes off and lands vertically. It carries the following equipment in flight; An on - board flight computer with GPS navigation and location ability that receives signals for flight co ntrols from a ground - based tran smitter/controller.

 An on - board camera capable of capturing images in the form of full color, high definition still photos and videos.Drones Unlimited, LLC CEO - Bryan Gonzalez & Raymond Anthony 139 Brooks st se Fort Walton Beach, Florida 34479 Ph:352 - 361 - 1932 & 352 -816 - 5196

 It is equipped to send flight data from the on - board flight computer to the on - board radio transmitter.

 The DJI Inspire1 has the return to home feature. If signal beco mes lost, it is programmed t o come back to the launch site . 2) Our second UAS is a Tarot model TL4X001. (9.4 lb gross weight fully equipped) The flight controller onboard is a DJI Naza v2. Battery only operated 4 motor craft in the form of a quadcopter that t akes off and lands vertically. It carries the following equipment in flight; • An on - board flight computer with GPS navigation and location ability that receives signals for flight controls from a ground - based transmitter/controller.

 Return to home feature via DJI Naza V2 flight controller. 3) Our 3 rd UAS is a DJI S1000. (18 lb gross weight fully equipped) Battery only operated 8 motor craft in the form of an octocopter that takes off and lands vertically. It carries the following equipment in flight; • An on - board flight computer with GPS navigation and location ability that receives signals for flight controls from a ground - based transmitter/controller

 An on - board camera capable of capturing images in the form of full color, high definition still photos and videos.

 An additional thermal camera onboard

 It is equipped to send flight data from the on - board flight computer to the on - board radio transmitter.

 The DJI S1000 has the return to home feature. If signal becomes lost, it is programmed to come back to th e launch site.Drones Unlimited, LLC CEO - Bryan Gonzalez & Raymond Anthony 139 Brooks st se Fort Walton Beach, Florida 34479 Ph:352 - 361 - 1932 & 352 -816 - 5196 The Unmanned Aircraft System will be operated in the field with a PIC in accordance w ith FAA Policy N 8900.227 Secti on 14 "Operational Requiremen ts for UAS".

Drones Unlimited, LLC respectfully requests the grant of exemption allowing to operate lightweig ht, remote controlled UAS's lawfully and safely.

Drones Unlimited also respectfully requests Exemption Request Section 333 from (but not limited to) the Specific Sections of Title 14 of the Code of Federal Regulations and part ll of the Federal Aviation. Regulations listed below. 14 C.F.R.45.23(b); 14 CFR Part 21; 14 CFR 61.113 (a) & (b); 91.7 (a); 91.9 (b) (2); 91.103(b); 91.109; 91.119; 91.121~ 91.151(a); 91.203(a) & (b); 91.405 (a); 91.407(a) (1); 91.409 (a) (2); 91.417 (a) & (b)

**The extent of relief Drones Unlimited**  **seeks and the reason why:** Drones Unlimited is seeki ng relief from any applicable FARs operating to prevent Drones Unlimited from conducting low level aerial serv ices including but not limited to real estate, special events and utility inspections. The weight of the UAS meets the definition of ''small unmanned ai rcraft" found in section 331 of The Reform Act. Drones Unlimited seeks to operate legally as a professio nal drone service company. One of our goals is to create jobs for certified pilots to inspect power lines starting in the Panhandle of Florida. Drones Unlimited uses UAS’s that is considerably less than 55 pounds fully loaded . The UAS will be used at speed s under 30mph becau se of the nature of the business.Drones Unlimited, LLC CEO - Bryan Gonzalez & Raymond Anthony 139 Brooks st se Fort Walton Beach, Florida 34479 Ph:352 - 361 - 1932 & 352 -816 - 5196 The UAS will be in accordance with fl ying well below 400ft. The UAS’ s we use only operate on battery power . There are no combustible fuels used in the UAS that Drones Unlimited uses . The maximum flight t ime for our particular UAS is 18 minutes battery life. It will fly no more than 15 minutes maximum at one time at one location. The amount of time the UAS will be in the air, under 400ft, is very minimal. A Safety system in place for Drones Unlimited UAS i ncludes a GPS mode that allows the UAS to hover in place if communication is lo st. Further, the GPS onboard all ows the UAS to return back to its launched position if the battery life of the UAS is low. T HE GROUND STATION PART OF THE SYSTEM:

 A Pilot in Com mand (PIC) in operational control of a flight operation from beginning to end and who controls the UAS while in the air. Additionally, the line of site of the UAS will not leave the sight of the PIC. A visual observer will also be present during every figh t.

 A radio transmitter/controller operated by the PIC to control the UAS while in flight

 A radio receiver receiving live video and flight data from the on - board. Camera and computer. It projects it all in. one screen to the Pilot in Command.

The UAS’s, weighing considerably less than 55 lbs full y loaded, is powered by batteries and operates with no people on board which lowers the likelihood of death or serious bodily injury. With a small payload consisting of harmless electronics such as a camera and GPS, the UASs only purpose is to be used as a tool professionally to fill the needs of customers and lowering costs to utility inspections.Drones Unlimited, LLC CEO - Bryan Gonzalez & Raymond Anthony 139 Brooks st se Fort Walton Beach, Florida 34479 Ph:352 - 361 - 1932 & 352 -816 - 5196 Low level aerial photos and video from several angles are far more effective than ground based photos. Low level aeri al video and pictures show the layout of properties with the advantage of seeing more in one photo or short video. Current applicants have chartered helicopters and small planes for this purpose. As an ex Aviation Logistics Specialist in the U.S. Navy (Bryan) , the cost of fuel, time, and emissions of such aircraft (helicopters and planes) is not efficient enough for most customers to afford. The benefits of reduced cost and improved efficiency of the UAS allows future customers to afford this service with a faster turnaround time a t a lesser cost. Additionally, we respectfully request that Drones Unlimited be allowed to use the UAS’s to benefi t possible first responders in our area for actions that could benefit the public. Such as, forest fires and/or se arch and rescue. The areas where Drones Unlimited conducts aerial photography is predetermined which allows for a controlled environment to operate safely. With allowing Drones Unlimited to conduct business with a light weight UAS, it could very well help the economy and benefit people in first response situations. Further, Drones Unlimited UAS’s is considerably lighter than the alternative which is a helicopter or small plane. The likeli hood of injury or even death with such a small unmanned aircraft, compared to an aircraft flown by a person loaded with combustible fuel, is considerably low.Drones Unlimited, LLC CEO - Bryan Gonzalez & Raymond Anthony 139 Brooks st se Fort Walton Beach, Florida 34479 Ph:352 - 361 - 1932 & 352 -816 - 5196

**SUMMARY:** Drones Unlimited is more than willing to follow the safety guidelines of the FAA Pol icy N 8900.227 Section 14 "Op erational Requirements for UAS with the appropriate exemptions for flying a small UAS. (a) No flight will be made with a UA Gross weight exceeding 55 pounds (b) All operations must occur in FAA Class G airspace at no more than 400 ft. AGL, at an airspeed of no m ore than 25 knots and no further than 3/4 NM from the Pilot In Charge (c) Operations will be restricted to flights over private property with the permission of the property owner (d) All required permits will be obtained from state and local government prior to operation (e) The UAS will not be operate d over densely populated areas (f) The UAS will not b e operated at air shows (g) The UAS will not be operated over any open - air assembl y of peop le ( h) The UAS will n ot be op erated over heav ily trafficked roads (i) The U AS will not be operated within 5 NM of an airport or heliport (j) Operations will be restricted to daytime only and weather equivalent to VFR.Drones Unlimited, LLC CEO - Bryan Gonzalez & Raymond Anthony 139 Brooks st se Fort Walton Beach, Florida 34479 Ph:352 - 361 - 1932 & 352 -816 - 5196 (k) The PIC will brief the property owner about the operation and risk before the first flight at each location. (l) No flight may be made without a Pre - Flight Inspection by the PIC before each operation to ascertain that the UAS is in a condition safe for flight (see Appendix A).

Our operations above, [(A) through (L)], are the bare minimum safety requirements Drones Unlimited follow. Drones Unlimited is also more than willing to follow any additional safety requirements if not listed above.

As stated by President Barak Obama in his recent memorandum for the heads of executive departments and agencies concerning UAS's, published on February 15 , 2015 . "As compared to manned aircraft, UAS may provide lower- cost operation and augment existing capabilities while reducing risks to human life. Estimates suggest the positi ve economic impact to U.S. industry of the integration of UAS into the NAS could be substantial and likely will grow for the foreseeable future". Drones Unlimited believes flying its UAS’s as a business within the safety parameters of the FAA, can help the economy by creating jobs starting in the North West Florida region.Drones Unlimited, LLC CEO - Bryan Gonzalez & Raymond Anthony 139 Brooks st se Fort Walton Beach, Florida 34479 Ph:352 - 361 - 1932 & 352 -816 - 5196 **The name and contact information of the applicant s**  **are:** Drones Unlimited, LLC Attn; Bryan Gonzalez- CEO, Raymond Anthony- CEO Phone: 352 - 361 - 1932, 352 -816 - 5196 Email: Bryan@dronesunltd.com or ranthony7474@hotmail.com I, Bryan Gonzalez, has served 4 years in the Navy from 2009 - 2013 with experience as an aviation logistics specialist. Luxury Aerial Shots, LLC is a business I own with the section 333 exemption #11513. I already have an approval but my goal is to have one made for Drones Unlimited, LLC and close Luxury Aerial Shots, LLC. We have over 200 hours each of sma ll UAS flight time and we are very familiar with the section 3 33 rules and COA. It’s a matter of possibly having our current section 333 (#11513) transferred into Drones Unlimited, LLC. Drones Unlimited, LLC respectfully requests that the FAA grant its exemption request without delay. Thank you for your time! Respectfully, Bryan Gonzalez, CEO - Drones Unlimited, LLC 9/18/2015

_____________________________ & Raymond Anthony, CEO - Drones Unlimited, LLC 9/18/2015

______________________________Drones Unlimited, LLC CEO - Bryan Gonzalez & Raymond Anthony 139 Brooks st se Fort Walton Beach, Florida 34479 Ph:352 - 361 - 1932 & 352 -816 - 5196