Sept 6, 2015

U.S. Department of Transportation 

Docket Management System

1200 New Jersey Ave., SE 

Washington, DC 20590

Re: Petition of Drop My Drone LLC, for an 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 ("Reform Act") and 

14 C.F.R. Part 11, Drop My Drone LLC (DMD) hereby applies for an exemption from the Federal 

Aviation Regulations ("FARs") identified below to allow commercial operation ofsmall unmanned aerial 

vehicles (i.e., "small unmanned aircraft" or "UAS”) for providing aerial photography and videography 

for the real estate industry as well as property mapping, inspections and 3D compositing.

This petition for exemption addresses pertinent FAA FAR’s and CFR’s as well as, but not 

limited to, these accompanying DMD’s documents.

1. Flight Operations Manual and;

2. Operations Manuals

(collectively referred to as Operations Manuals")

3. User Guide and;

4. User Manual

(collectively referred to as "Manufacturer's Manual").1

DMD submits these as well as other DMD supporting materials asconfidential documents 

pursuant to 14 C.F.R. § 11.35 (b), as the materials contain confidential commercial and/or proprietary 

information that the DMD has not and will not share with others. Additionally, these documents contain 

operating conditions and procedures that are not generally available to the public and are protected from 

release under the Freedom of Information Act, 5 U.S.C. §552 etseq.

1The term"Manufacturer's Manual" also includes all relevant manufacturer publications, including, but 

not limited to: operations and flight manuals, user guides, component maintenance manuals, pilot 

training manuals, service information letters and, safety/service bulletins).
U.S. Department of Transportation 

Sept 6, 2015

Page 2

This Petition is organized as follows:

I. Petitioner

II. Description of Proposed Operations

A. Real Estate Aerial Photography. Videography and Inspection Service

III. Relevant Statutory Authority

IV. DMD Proposed RE-UAS Operations Meet the Requirements of Section 333 ofthe 

Reform Act

A. Approval is Warranted Based on the RE-UAS's Size, Weight, Speed, and Operational 

Capability

B. Approval is Warranted Based on the Operational Restrictions Set Forth in theOperations 

Manuals

V. Regulations From Which Exemption is Requested

A. 14 C.F.R. Part 21, Subpart H – Airworthiness Certificates and 14 C.F.R. § 

91.203(a)(1) B. 14 C.F.R. Part 27 Airworthiness Standards: Normal CategoryRotorcraft

C.14 C.F.R. §§ 91.9(c), 45.23(b) and 45.27(a): Aircraft Marking and Identification 

Requirements D. 14 C.F.R. § 91.405(a), 91.407(a)(1), 91.409(a)(1) and (2); 91.417(a) and (b): 

Maintenance Inspections

E. 14 C.F.R. Part 61, 14 C.F.R. § 61.3, 14 C.F.R. § 61.113: Private Pilot Privileges andLimitations

F. 14 C.F.R. § 91.7(a): Civil Aircraft Airworthiness

G. 14 C.F.R. § 91.9(b)(2): Civil Aircraft Flight Manual in the Aircraft and 14 C.F.R. § 91.203(a) 

and (b): Carrying Civil Aircraft Certification and Registration

H. 14 C.F.R. § 91.103: Preflight Action

I. 14 C.F.R. § 91.109(a): Flight Instruction

J. 14 C.F.R. § 91.119(c): Minimum Safe Altitudes

K. 14 C.F.R. § 91.121: Altimeter Settings

L. 14 C.F.R. § 91.151(a): Fuel Requirements for Flight in VFR Conditions

VI. Drug and Alcohol Program

VII. Public Interest

VIII. Privacy

IX. Federal Register Summary

X. Conclusion
U.S. Department of Transportation 

Sept 6, 2015

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I. DESCRIPTION OF PETITIONER

Drop my Drone LLC will be a service based business that delivers high quality, real footage and videos 

to its clients. The client base will include commercial and residential real estate agents who are looking 

to showcase and sell high end real estate. Additional clients will include the boating and yachting

community and any business or individual that would like high quality video for their property or 

inspection of that property. 

Currently Drop my drone is operated solely by the owner, Valter Golfieri. There are no immediate 

plans to hire additional employees. Upon approval, Mr. Golfieri will begin advertising and marketing 

this business through his website, social media, existing relationships with real estate agents and boat 

owners and networking in his local community of Marina del Rey, Ca.

Real Estate DMD is based in Marina Del Rey, CA, working in photography and videography services. 

The Company specializes in, and will continue to focus on, the videography of property and real estate for 

sales purposes as well as property mapping, inspections, and 3D compositing. The company also shoots

travel videos. The Company’s Principal has been building and flying sUAV Quadcopters as a hobby for 

more than four years without incident, spending thousands of hours flying as well as eight years of video 

production experience. The Company also employs two partners, one of whom serves as primary camera 

operator and director of photography. The work generated provides a major source of all of ourincome.

The contact information for Petitioner is asfollows: 

Valter Golfieri

Drop My Drone LLC 

13816 Bora Bora Way #126

Marina del Rey, CA 90292 

Phone: 310-995-8610

Email: valter.golfieri@hotmail.com

II. DESCRIPTION OF PROPOSEDOPERATION

DMD seeks an exemption pursuant to Section 333 of the Reform Act to operate the DJI Phantom 2, S800 

Evo, S1000 also known as, (RE-UASs) for the proposed operations discussed below. RE-UAS 

operations will occur under tightly controlled conditions on private property where DMD has received 

permission to operate from the landowner, controller or authorized representatives. The proposed REUAS operations will be conducted in accordance with the conditions and limitations of this Petition for 

Exemption and DMD’s Operations Manuals. As detailed in DMD’s Operations Manuals, RE-UAS 

operations will be limited to daytime VFR conditions, within visual line-of-sight ("VLOS") of the 

operator, in uncontrolled airspace, and will occur at least 5 nmaway from an airport. Moreover, DMD’s 

Operations Manuals incorporate redundant safeguards to assure that the aircraft does not travel outside 

the controlled area of RE-UAS operations, including GPS"geo- fencing" technologies.
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Sept 6, 2015

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A. Real Estate Aerial Photography. Videography and Inspection Service

DMD seeks to use RE-UASs for the purpose of conducting aerial photography, videography 

and inspection services for the real estate industry. Company has tailored its operations to meet the 

requirements established by the FAA in prior grantsof exemptions authorizing the commercial use 

of UAS in general photography and videography and the same for the production of video in the real 

estate industry including:

 Team 5, LLC (Exemption No. 11158)

 Alan D. Purwin (Exemption No. 11161)

 Helinet Aviation Services, LLC (Exemption No. 11160)

 Picture Factory, Inc. (Exemption No. 11178)

 Dronair Solutions (Exemption No. 11671)

UAS real estate photography and videography operations will be conducted on private property in 

a controlled area, away from spectators and persons not involved in the video production. UASvideo 

photography will be conducted during daylight hours, VFR conditions, at altitudes below 400' AGL. As 

set forth below, Company’s operations provide a superior level of safety and quality compared to 

performing the same filming work using conventional fixed-wing aircraft or helicopters.

Traditional methods of real estate video production and inspection of structures, expose 

videographer-inspectors to higher risks of serious injuries, or death. Videographer-inspectors need to 

climb roof tops or otherwise perform elevated work, which exposes them to the risk of dangerous falls, 

electrocution or other work related extremes. In addition, depending on the nature of the video needed 

and inspection, proximity to equipment, and other mechanical hazards associated with industrial sites 

and construction facilities often involves a risk of exposure to hazardous. The use of RE-UASs 

mitigates these hazards and is ultimately a much safer method of performing these and most other 

types of inspections.

RE-UAS real estate video production and inspection of structures is much safer than traditional 

manned aircraft performing the same function. Conventional operations using rotorcraft andfixed-wing 

aircraft in low level operations present very high risks with vehicles weighing thousands of pounds, 

carrying passengers and large amounts of fuel. It is important to note that the use of small RE-UAS in 

this area will not only be safer and more cost effective, but the quality of collected data and information 

is far superior.

RE-UAS real estate video production and inspection of structures is more reliable, and allows for 

the collection, dissemination, and storage of visual content and other sensory data with greater precision 

and duration. RE-UASs are also capable of accessing finish and structural quality through the use of 

video and inspecting areas that would otherwise be inaccessible to humans and would be impossible to 

be completed with conventional aircraft or other inspection methods.
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Sept 6, 2015

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III. RELEVANT STATUTORY AUTHORITY

This Petition for Exemption is submitted pursuant to Section 333(a) through (c) of the FAA

Modernization and Reform Act of 2012 ("Reform Act"). Congress has directed the FAA "to safely 

accelerate the integration of civil unmanned aircraft systems into the national airspace system." 

Pursuant to Section 333 of the Reform Act, the FAA Administrator is to permit unmanned aircraft 

systems to operate in the National Air Space ("NAS") where it is safe to do so based on the following 

considerations:

● The UAS's size, weight, speed and operational capability;

● Operation of the UAS in close proximity to airports and populated areas; and

● Operation of the UAS within the visual line of sight of the operator.

Additionally, the FAA Administrator has general authority to grant exemptions from the agency's 

safety regulations and minimum standards when the Administrator decides a requested exemption isin 

the public interest. See 49 U.S.C. § 106(f) (defining the authority of the Administrator); 49 U.S.C. § 

44701(f) (permitting exemptions from §§ 44701(a), (b) and §§ 44702 – 44716, et seq.). A party 

requesting an exemption must explain the reasons why the exemption: (1) would benefit the public as a 

whole, and (2) would not adversely affect safety (or how it would provide a level of safety at least 

equal to the existing rules). See 14 C.F.R. § 11.81 (petitions for exemption).

IV. REAL ESTATE SHOWCASES’ PROPOSED RE-UAS OPERATIONS MEET THE 

REQUIREMENTS OF SECTION 333 OF THE REFORMACT

The small RE-UAS operations proposed by DMD in this Petition for Exemption qualify for 

expedited approval pursuant to Section 333 of the Reform Act as each of the statutory criteria and 

relevant factors are satisfied.

A. Approval is Warranted Based on the RE-UAS's Size, Weight, Speed, andOperational 

Capability

A Grant of Exemption is appropriate for operations conducted using the RE-UASs due to itssize 

weight, speed, and operational capability.
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 The RE-UASs have been approved for use in prior Section 333 Grants of Exemption from the FAA.2

 The RE-UASs weigh less than 55 pounds, including payload.

 The RE-UASs will not be flown at a ground speed in excess of 50 knots.

 Altitude information will be generated by equipment onboard the UA as specified using GPS 

triangulation, digitally encoded barometric altimeter, radio altimeter, or any combinationthereof. 

This information will be transmitted to the pilot via telemetric data feed.

 The RE-UASs will have system redundancies and independent functionality to ensure the overall 

safety and predictability of the system. If connection to the remote control or ground controlstation 

is lost, failsafe systems will permit the RE-UAS to return to a predetermined location and safely 

land without injury or damage.

 The radio frequencies used for operations and control of the RE-UAS comply with the 

Federal Communications Commission ("FCC") and other appropriate government 

oversight agency requirements. The operating frequency for RE-UASs are 2.4 GHz.

If the same operations were conducted using a helicopter, the aircraft's take-off weight would likelyexceed 

6,000 pounds carrying a pilot, camera operator and VO-visual observer- navigator. The difference in 

weight between RE-UASs and a helicopter significantly reduces the potential harm to the participating and 

non- participating individuals or property in the event of an accident or incident. In addition, the risk tothe 

onboard pilot and camera operator is eliminated.

2See e.g., Grant of Exemption to Shotover Camera Systems L.P. (Exemption No. 11159); Grant of 

Exemption to VDOS Global, LLC (Exemption No. 11112); Grant of Exemption to Low Country RC, Corp. 

(Exemption No. 11184); Grant of Exemption to Alan Purwin (Exemption No. 11161); Grant of Exemption 

to Helinet Aviation Services (Exemption No. 11160); Grant of Exemption to Total

Safety U.S., Inc. (Exemption No. 11156).
U.S. Department of Transportation 

Sept 6, 2015

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B. Approval is Warranted Based on the Operational Restrictions Set Forth inDMD’s 

Operations Manuals

DMD’s Operations Manuals and the Manufacturer's Manual for the selected RE-UASs will contain 

all the procedures and limitations necessary to safely and successfully perform theoperations specified in 

this Petition for Exemption. To assist the FAA in making a safety assessment ofDMD’s proposed 

operations, below is a summary of operational limitations and conditions that DMD will adhere to, and 

which will ensure an equivalent or higher level of safety to operations conducted under current regulatory

guidelines:

1. The RE-UAS weighs less than 55 pounds, fully loaded.

2. 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 operation.

3. All RE-UASs operated under the Grant of Exemption will be identified by serial number, 

registered in accordance with 14 CFR part 47, and have identification (N-Number) markingsin 

accordance with

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

4. Minimum crew for each flight operation will consist of a pilot, who will be Pilot- inCommand 

("PIC") of the RE-UAS, and one or more Visual Observers ("Observer") as necessary to safely 

conduct the mission.

5. PICs shall possess at least a Private Pilot's Certificate and current Class III Medical Certificate. 

The PIC will also meet the flight review requirements specified in 14 C.F.R 61.56 in an aircraft in 

which the PIC is rated on his or her pilot certificate.

6. The UA shall be operated within VLOS of the PIC and Observer at all times. The PIC must use 

human vision unaided by any device other than corrective lenses, as specified on the PIC's FAAissued medical certificate.

7. The PIC and Observer designated for any operation will be able to communicate verbally at all 

times.

8. Electronic messaging or texting will not be permitted during flight operations.

9. The additional requirements identified in the Grant of Exemption shall be added to the DMD’s 

Operations Manuals.
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Sept 6, 2015

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The Operations Manuals will be maintained and made available to the Administrator upon request. If 

a discrepancy exists between the conditions and limitations in the Grant of Exemption and DMD’s 

Operations Manuals, the conditions and limitations in the Grant of Exemption shall take precedence 

and must be followed. Otherwise, DMD shall follow the procedures outlined in their Operations

Manuals.

10. DMD may update or revise its Operations Manuals. Revisions will be tracked and a revised copy 

of the Manual will be provided to the Administrator upon request. DMD will also present an updated

and revised Operations Manuals if it petitions for extension or amendment to its Grant of Exemption. If 

an update or revision would affect the basis upon which the FAA grants the exemption, DMD will 

seek an amendment to its Grant of Exemption. DMD will contact the FAA’sRE- UAS Integration

Office (AFS-80) if questions arise regarding updates or revisions to the operating documents.

11. DMD’s Operations Manuals and its Grant of Exemption will be available to the PIC at the 

ground control station anytime the RE-UAS is operating.

12. The PIC is prohibited from beginning a RE-UAS flight unless (considering wind and forecast 

weather conditions) there is enough power to fly to the first intended point of landing, and assuming 

normal cruising speed, to fly after that for at least 10 minutes.

13. Maximum total flight time for each operational flight using the RE-UAS will be limited to 40 

minutes or the amount of time the RE-UAS can be flown and still maintain a reserve battery power of 

no less than 25%, whichever occurs first.

14. Flights will be operated at an altitude of no more than 400 feet AGL and will never enter 

navigable controlled airspace without prior written authorization and approval from the FAA. In the 

event the structure being inspected exceeds 400 feet AGL, the RE-UAS will not be operated more 

than 100 feet above the highest point on the structure, and no more than 50 feet horizontally from the 

structure.

15. Flight operations must be conducted at least 500 feet from all nonparticipating persons. (persons 

other than the PIC, VO, operator trainees or essential personnel), vessels, vehicles, and structures 

unless:

a) Barriers or structures are present that sufficiently protect nonparticipating persons fromthe 

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 within 500 feet of the UA, flight operations must cease 

immediately and/or;
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Sept 6, 2015

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b) The aircraft is operated near vessels, vehicles or structures where the owner/controller ofsuch 

vessels, vehicles or structures 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).

16. 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 three statute miles from the PIC.

17. The UA may not operate within 5 nm of an airport reference point as denoted on a current 

FAA-published aeronautical chart unless a letter of agreement with that airport’s management is 

obtained, and the operation is conducted in accordance with a NOTAM as required by the 

DMDCOA. The letter of agreement with the airport management will be made available to the 

Administrator upon request.

18. Prior to each flight the PIC shall inspect the RE-UAS to confirm that it is in a condition safe 

for flight. The pre-flight inspection will account for all discrepancies, e.g. inoperable components, 

items, or equipment, not already covered in the relevant sections of the operating documents. The 

PIC shall not operate the RE-UAS if the inspection reveals a condition that affects the safe 

operation of the RE-UAS until the necessary maintenance has been performed and the RE-UAS is 

found to be in a condition for safe flight. The ground control station shall be included in the 

preflight inspection. All maintenance and alternations must be properly documented in the RE-UAS

records as required by DMD’s Operations Manuals.

19. DMD will carry out its maintenance, inspections, and record keeping requirementsin 

accordance with the Operations Manuals. Maintenance, inspection, and alterations will be notedin 

the RE-UAS records, including total time in service, description of work accomplished, and the 

signature of the authorized person returning the RE-UAS to service.

20. Any RE-UAS that has undergone maintenance or alterations that affect the RE-UAS

operation or flight characteristics (e.g., replacement of a flight critical component) must undergo a 

functional test flight in accordance with DMD’s Operations Manuals. The PIC whoconducts the

functional test flight must make an entry in the RE-UAS aircraft records of the flight. The 

requirements and procedures for a functional test flight and RE-UAS record entry shall be 

included in the DMD’s Operations Manuals.
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Sept 6, 2015

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21. The RE-UAS will be operated and maintained according to the Manufacturer's Manuals and 

any required manufacturer Safety/Service Bulletins.

22. Prior to the operation, a Mission Packet will be created in accordance with the requirements 

on DMD’s Operations Manuals.

23. DMD will obtain an Air Traffic Organization ("ATO") issued Certificate of Waiver or 

Authorization, otherwise known as a COA, prior to conducting any operations under this Grant of 

Exemption. A NOTAM will be issued as required by the COA. All operations will be conducted in 

accordance with airspace requirements in the ATO issued COA including class of airspace, altitude 

level and potential transponder requirements.

24. All required permissions and permits will be obtained from territorial, state, county or city 

jurisdictions, including local law enforcement, fire or other appropriate governmental agencies.

25. If the RE-UAS loses communication with the pilot, it will have the capability to return toa 

pre- determined location within the operational area and land safely.

26. Contingency plans will be in place to safely terminate flight if there is a loss of 

communication between the PIC and the Observer.

27. The RE-UAS will have the capability to safely abort flight in the case of unpredicted 

obstacles or emergencies.

28. PICs and Observers will have at least a current Class III Medical Certificate.

29. Prior to conducting operations for filming, the PIC will have accumulated and logged, in a 

manner consistent with 14 CFR § 61.51(b), a minimum of 200 flight cycles and 25 hours totaltime 

as a RE-UAS rotorcraft pilot and at least 10 hours logged as a RE-UAS pilot with a similarREUAS type.

30. Prior to conducting operations for filming, the PIC will have accumulated and logged, in a 

manner consistent with 14 CFR § 61.51(b), a minimum of 54 CFR §61.51(b), a minimum of 10 

logged hours as RE-UAS pilot operating the make and model of RE-UAS to be utilized for 

operations under the exemption and thirty take-offs and thirty landing in the preceding 90 days.
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31. Operations shall occur during daytime VFR Meteorological Conditions; flights under 

Special Visual Flight Rules ("SVFR") shall not be conducted.

32. The UA shall remain clear and yield the right of way to all other manned operations and 

activities at all times (including, but not limited to, ultralight vehicles, parachute activities, 

parasailing activities, hang gliders, etc.).

33. RE-UAS Operations under Instrument Flight Rules, at night, or beyond VLOS are prohibited.

34. The RE-UASs will not be operated from an elevated platform or moving device / vehicle.

35. Before conducting operations, the radio frequency spectrum used for operation and control 

of the UA will comply with the Federal Communications Commission (FCC) or other appropriate 

government oversight agency requirements.

V. REGULATIONS FROM WHICH EXEMPTION ISREQUESTED

The Federal Aviation Act expressly grants the FAA the authority to issue exemptions. This 

statutory authority, by its terms, includes exempting civil aircraft, as the term is defined under § 40101 of 

the Act, including RE-UASs, from its safety regulations and minimum standards when theAdministrator 

decides a requested exemption is in the public interest.3

DMD seeks an exemption from several interrelated provisions of Title 14 of the Code of Federal 

Regulations ("14 C.F.R") Parts 21, 45, 61 and 91 for purposes of conducting the requested operations using 

a RE-UAS. Listed below are: (1) the specific sections of 14 C.F.R for which exemption is sought, and (2) 

the operating procedures and safeguards that Petitioner has established which will ensure a level of safety 

better than or equal to the rules from which exemption issought.4

3

49 U.S.C. § 44701(f) (authorizing the grant of exemptions from requirements of regulations prescribed 

pursuant to Sections 44701(a) and (b) and Sections 44702 - 44716).

4

14 C.F.R § 11.81(e), which requires a petition for exemption to include:

The reasons why granting the exemption would not adversely affect safety, or how the exemption would 

provide a level of safety at that provided by the rule from which you seek exemption.
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UNMANNED AIRCRAFT SYSTEM

A. 14 C.F.R. Part 21, Subpart H – Airworthiness Certificates and 14 C.F.R. § 91.203(a)(1)

The FAA has stated that no exemption is needed from this section if a finding is made underthe 

Reform Act that the RE-UAS selected provides an equivalent level of safety when compared to aircraft 

normally used for the same application. These criteria are met, and therefore no exemption is needed.5If,

however, the FAA determines that there are some characteristics of the chosen RE-UAS that fail tomeet 

the requirements of the Reform Act, an exemption is requested.

Equivalent Level of Safety

DMD’s use of the RE-UAS is safe when taking into account their size, weight, speed, and 

operational capability. As set forth in the description of proposed operations in Section IV (A), theREUAS weighs less than 55 pounds, including payload and will not be flown at a ground speed in excess of 

50 knots. RE-UAS is also equipped with safety features that will allow Petitioner to operate theRE-UAS

safely after experience certain in-flight contingencies or failures.67

5

See Grant of Exemption No. 11062 to Astraeus Aerial (FAA-2014-0352 at pgs. 13-14, 22).

6

See e.g., Grant of Exemption No. 11184 to Low Country RC, Corp. (FAA-2014-0803 at pg. 3):

"The RE-UAS have the capability to operate safely after experiencing certain in-flight contingencies or 

failures and uses an auto-pilot system to maintain RE-UAS stability and control. The RE-UAS is also able 

to respond to a loss of global positioning system (GPS) or a lost-link event with a pre-coordinated, 

predictable, automated flight maneuver, and manual flight control functionality as a backup. These safety 

features provide an equivalent level of safety compared to a manned aircraft performing a similar 

operation."

7 See e.g., Grant of Exemption No. 11184 to VDOS Global, LLC. (FAA-2014-0382 at pgs. 4-5):

The RE-UAS’s can be operated entirely by a touch-screen, map-based interface. This means the operator 

only needs to command the system where to go, and the system does all the flying for the operator. The 

RE-UAS can be operated in both semi and fully autonomous flight modes, with the operator simply 

clicking on a map to create a pre-planned flight path for a flight. In addition, the operator can create no fly 

zones or maximum flight ranges and altitudes so the system cannot

enter areas

{footnote continued}
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Additionally, the RE-UASs carry neither pilots nor passengers, carry no explosive materials or 

flammable liquid fuels, and operate exclusively within the parameters stated in DMD’s Operations

Manuals.

Operations conducted under this exemption will be closely controlled and monitored by the 

operator and will be conducted in compliance with local public safety requirements, to provide security 

for the area of operation. DMD will also provide the FAA with advance notice of all operations via 

NOTAMs as required by the applicable COA. In all cases, operation of the RE-UAS under the 

proposed conditions will be at least as safe as, or safer than, conventional rotorcraft operating withan 

airworthiness certificate.

Lastly, the RE-UASs do not need a means to communicate with other aircraft or ATC, because 

those capabilities will be possessed by the PIC and Observer, who are not onboard the RE-UAS.8In

addition, no sense-and-avoid technology is necessary for the RE-UASs because they will be operated at 

all times in VFR conditions and within VLOS of the PIC and Operator.9

B. 14 C.F.R. Part 27 Airworthiness Standards: Normal Category Rotorcraft

Title 14 C.F.R. Part 27 sets forth the procedural requirements for airworthiness certification of 

normal category rotorcraft. To the extent that Company's small UASs would otherwise require 

certification under Part 27, Petitioner seeks an exemption from Part 27's

{continued from previous page}

deemed unsafe or unnecessary to fly over. The petitioner states further that the RE-UAS has built-in

intelligent fault handling which allowsthe Phantom II and S1000+ to detect a system fault while in the air 

and automatically fly back to its takeoff location and land. Faults that can be detected include: loss of 

communication; exceeding pre-set wind thresholds; and low batterylevels.

All flight operations are global positioning system (GPS) controlled, making the system easy to navigate.

At any point if the operator is not explicitly commanding the system to move, the system automatically

holds its GPS position. The flight control system employs not only GPS positioning but a variety of 

sensors including sonar, barometric pressure, temperature, wind speed and others to ensure stability so long

as wind thresholds are not exceeded. Also a flight termination link – to prevent a 'fly away' or other 

potentially dangerous situation – is available to the operator.

8 See Grant of Exemption No. 11062 to Astraeus Aerial (FAA-2014-0352 at pg. 13). 

9

Id.
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Sept 6, 2015

Page 14

C. 14 C.F.R. §§ 91.9(c), 45.23(b) and 45.27(a): Aircraft Marking and Identification 

Requirements

DMD seeks an exemption from the aircraft marking and identification requirements contained in14 

C.F.R. §§ 91.9(c), 45.23(b) and 45.27(a).

● 14 C.F.R. § 91.9(c), Civil Aircraft Flight Manual, Marking and Placard requirements, provides 

that:

No person may operate a U.S.-registered civil aircraft unless that aircraft is identifiedin 

accordance with Part 45 of this chapter.

● 14 C.F.R. § 45.23(b), Markings of the Aircraft, states:

When marks include only the Roman capital letter "N" and the registration number is displayed on 

limited, restricted or light-sport category aircraft or experimental or provisionally certificated 

aircraft, the operator must also display on that aircraft near each entrance to the cabin, cockpit, 

or pilot station, in letters not less than two inches nor more than six inches high, the words 

"limited," "restricted," "light-sport, "Experimental," or "provisional," as applicable.

● 14 C.F.R. § 45.27(a), Rotorcraft, states:

Each operator of a rotorcraft must display on that rotorcraft horizontally on both surfaces of the 

cabin, fuselage, boom, or tail the marks required by § 45.23.

In a previous Grant of Exemption, the FAA determined that exemption from these requirements 

was warranted provided that the aircraft "have identification (N-Number) markings in accordance 

with 14 C.F.R Part 45, Subpart C if the markings are as large as practicable."10

Equivalent Level of Safety

All UA flown by DMD will bear N-number markings that are as large as practicable in 

accordance with 14 C.F.R. Part 45, Subpart C.11

________________________________________

10FAA Docket No. FAA-2014-0352.

11See, e.g., FAA Docket No. FAA-2014-0352, at 14.
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D. 14 C.F.R. § 91.405(a), 91.407(a)(1), 91.409(a)(1) and (2); 91.417(a) and (b): Maintenance

Inspections

DMD seeks an exemption from the maintenance inspection requirements contained in 14 

C.F.R. § 91.405(a), 91.407(a)(1), 91.409(a)(2); 91.417(a) and (b). These regulationsspecify

maintenance and inspection standards in reference to 14 C.F.R. Part 43. See, e.g., 14 C.F.R. § 91.405(a) 

(stating that each owner or operator of an aircraft "shall have the aircraft inspected as prescribed insubpart 

E of this part and shall between required inspections ...have discrepancies repaired as prescribed in part43 

of this chapter"). An exemption from these regulations is needed because Part 43 and these sectionsonly 

apply to aircraft with an airworthiness certificate, which the RE-UAS to be operated under this grant of 

exemption will not have.

Equivalent Level of Safety

An equivalent level of safety will be achieved because maintenance and inspections will be 

performed in accordance with the Manufacturer's Manual and any required manufacturer Safety orService 

Bulletins. Further, as required by DMD’s Operations Manuals, the PIC will conduct a pre-flight inspection 

of the RE-UAS and all associated equipment to account for all discrepancies and/orinoperable 

components. Maintenance will be performed and verified to address any conditions potentially affecting 

safe operation of the RE-UAS and no flights will occur unless, and until, all flight critical components of 

the RE-UAS have been found to be airworthy and in a condition safe for operation. A functional testflight 

will be conducted following the replacement of any flight-critical components. As required by DMD’s 

Operations Manuals, the PIC who conducts the functional test flight will make an entry in theRE-UAS

aircraft records of the flight.

DMD’s Operations Manual also includes requirements to follow the manufacturer’sRE-UAS

aircraft/component, maintenance, overhaul, replacement, inspection, and life limit requirements for the 

following applicable components: powertrain system (powerplant), propellers, avionics and control 

surfaces (including ailerons/elevons), structures & airframe, camera system, electrical systems(including 

batteries), ground control station, hazard accessories, and spare parts. Further, DMD’s Operations 

Manuals also includes procedures to document and maintain a record of the RE-UAS maintenance, 

preventative maintenance, alterations, and status of replacement /overhaul component parts, and the total 

time in service of the RE-UASs used under this Grant of Exemption. As a whole, the maintenance and 

inspection procedures required in DMD’s Operations Manuals ensure that an equivalent or higher level of 

safety will be achieved.
U.S. Department of Transportation 

Sept 6, 2015

Page 16

PILOT-IN-COMMAND OF THEUAS

E. 14 C.F.R. § 61.113: Private Pilot Privileges and Limitations

DMD seeks exemption from 14 CFR § 61.113, which restricts private pilot certificate holders from

flying aircraft for compensation or hire, and would also require a second class medical certificate. Thepurpose

of Part 61 is to ensure that the skill and competency of any PIC matches the airspace in which the PIC will be

operating, as well as requiring certifications if the private pilot is carrying passengers or cargo for hire.In this

case, while the RE-UASs will be operated as part of a commercial operation, it carries neitherpassengers nor

cargo.

In the Grant of Exemption to Astraeus Aerial.12, the FAA determined that the unique characteristics 

of RE-UAS operation outside of controlled airspace did not warrant the addition cost and restrictions 

attendant with requiring a the PIC to have a Commercial Pilot Certificate and Class II MedicalCertificate. 

The fulfillment of the additional requirements for a private pilot to become qualified as a commercial pilot 

would not lead to any additional safety benefits when RE-UAS operations are involved.

Equivalent Level of Safety

The DMD restrictions have placed on its RE-UAS operations meet or exceed the restrictions 

similarly imposed on Astraeus Aerial. DMD will operate on private property away from persons and 

property not involved in the operation. DMD will also obtain an ATO issued COA prior to conducting any 

operations under this Grant of Exemption. All operations will be conducted in accordance with airspace 

requirements in the ATO issued COA including class of airspace, altitude level and potential transponder 

requirements. A NOTAM will also be issued as required by the applicableCOA.

In addition to these flight restrictions, DMD will further ensure safe operation by requiring that any 

PIC be thoroughly versed not only in airspace and communication issues pertaining to all aircraft operators 

but also in the unique aspects of RE-UAS flight. As set forth in the Operations Manuals, pilots will have 

experience not only in RE-UAS operations generally but have logged flight time in the specific make and 

model used for the operations before they are permitted to participate in commercial flights on behalf of 

DMD. The pilot qualification, training, and currency requirements in the OperationsManuals ensure that 

DMD pilots are competent and proficient in the RE-UAS they are operating. DMD’s training and 

qualification requirements are consistent with those contained in prior FAA Section 333 Grants of 

Exemption, and will provide a higher level of competency and proficiency for its pilots and will ensure at 

least an equivalent level ofsafety.

12Exemption No. 11062 (FAA Docket No. FAA-2014-0352).
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Sept 6, 2015

Page 17

OPERATING PARAMETERS OF THERE-UAS

F. 14 C.F.R. § 91.7(a): Civil Aircraft Airworthiness

Although there will be no airworthiness certificate issued for the RE-UASs, DMD seeks an 

exemption from 14 C.F.R. § 91.7(a), which requires that a civil aircraft be in airworthy condition to be 

operated. The FAA has stated that no exemption is required for 14 C.F.R. § 91.7(a) to the extent that the 

requirements of Part 21 are waived or found inapplicable.13 Accordingly, Petitioner requests that the 

requirements for § 91.7(a) be treated in accordance with Section V (A),supra.

G. 14 C.F.R. § 91.9(b)(2): Civil Aircraft Flight Manual in the Aircraft and 14

C.F.R. 03(a) and (b): Carrying Civil Aircraft Certification and Registration

Title 14 C.F.R. § 91.9(b)(2) and § 91.203(a) and (b) require the operator to carry airworthiness 

documents and other aircraft manuals onboard the aircraft. Pursuant to 14 C.F.R. § 91.9(b)(2):

...

(2) For which an Airplane or Rotorcraft Flight Manual is required by § 21.5 of this chapter, unless 

there is available in the aircraft a current approved Airplane or Rotorcraft Flight Manual, approved manual 

material, markings, and placards, or any combination thereof.

Pursuant to 14 C.F.R. § 91.203(a) and (b):

(a) Except as provided in § 91.715, no person may operate a civil aircraft unless it has within it the 

following:

(1) An appropriate and current airworthiness certificate...

(b) No person may operate a civil aircraft unless the airworthiness certificate required by 

paragraph (a) of this section or a special flight authorization issued under § 91.715 is displayed at the cabin 

or cockpit entrance so that it is legible to passengers or crew.

13See id. at 13-14, 22
U.S. Department of Transportation 

Sept 6, 2015

Page 18

Given the small size and configuration of the RE-UASs, it would be impossible to keep 

airworthiness documents and other aircraft manuals on board the RE-UAS because there is simply no room

and the RE-UAS has no cabin or cockpit.

Equivalent Level of Safety

In an FAA Office of Chief Counsel's Opinion dated August 8, 2014, and prepared by Dean E. 

Griffith, Attorney, AGC-220, it was acknowledged that the intent of 14 C.F.R. 91.9(b) and 91.203(a) and

(b) is met if the pilot of the unmanned aircraft has access to the RE-UAS flight manual,registration 

certificate, and other required documents from the ground control station from which he or she is operating 

the aircraft.14 As this FAA Office of Chief Counsel Opinion clarifies, the intent of the rule is to ensure the 

pilot has access to these key documents during flight. Therefore, an equivalent level of safety will be 

achieved by ensuring that the pilot has access to the documents at the ground control station from which he 

or she is piloting the RE-UAS.

H. 14 C.F.R. § 91.103: Preflight Action

DMD seeks an exemption from 14 C.F.R. § 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. While the PIC will be familiar with all information necessary to safely 

conduct the flight, an exemption is requested to the extent that an FAA-approved Flight Manual isrequired.

Equivalent Level of Safety

An equivalent level of safety will be provided by following the DMD’s Operations Manuals and 

the Manufacturer's Manual. The PIC will perform a series of checklists designed to identify any defects or 

inoperable components in accordance with the DMD’s Operations Manuals, including checklists covering 

Pre-Flight, Launch, Landing, and Post-Flight procedures. The PIC will also be required to review weather, 

flight requirements, battery charge, landing and takeoff distance, UA performancedata, and contingency 

landing areas—before initiation of flight. DMD’s Operations Manuals and the Manufacturer's Manual will 

be kept at the ground control station and will be accessible to the PIC at all times while operating the REUAS.

I. 14 C.F.R. § 91.109(a): Flight Instruction

14 Memorandum from Mark Bury, FAA Assistant Chief Counsel for International Law, Legislation and 

Regulation, to John Duncan, FAA Flight Standards Service (Aug. 8, 2014); see also Docket No. FAA2014-0352 at 16-18.
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Sept 6, 2015

Page 19

DMD seeks an exemption from 14 C.F.R. § 91.109(a), which provides in pertinent part that "[n]o 

person may operate a civil aircraft (except a manned free balloon) that is being used forflight instruction 

unless that aircraft has fully functioning dual controls." RE-UASs and remotely piloted aircraft, by their 

design, do not have functional dual controls. Instead, flight control is accomplished through the use of a 

device that communicates with the aircraft via radio communications. Accordingly, an exemptionwill be 

required for the flight instruction requirements of 14 C.F.R. § 91.109(a).

Equivalent Level of Safety

Given the size and speed of the RE-UASs that DMD intends to use, an equivalent level of safe 

training can still be performed without dual controls because no pilot or passengers are aboard the REUAS, and as required by the DMD’s Operations Manuals, all persons will be a safe distance awayin the 

event that the RE-UAS experiences any difficulties during flight instruction. Moreover, as required by the 

DMD’s Operations Manuals, all flight training will be conducted in controlled and sterile environment. As 

a whole, the safety procedures provided for in DMD’s Operations Manuals ensure that the proposed REUAS operations provide an equivalent or higher level of safety than that providedby the flight instruction

regulations.

J. 14 C.F.R. § 91.119(c): Minimum Safe Altitudes

DMD requests an exemption from the minimum safe altitude requirements of 14 C.F.R. § 

91.119(c).15 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 C.F.R. § 91.119(c). Section 91.119(d) allows for a helicopter to operate at less 

than those minimum altitudes when it can be operated "without hazard to persons or property on the 

surface," provided that "each person operating the helicopter complies with any routes or altitudes 

specifically prescribed for helicopters by the FAA."

An exemption is required because the proposed RE-UAS operations will normally need to occur 

below 400 feet AGL. In circumstances where the RE-UAS is used to inspect a structure whoseheight 

exceeds 400 feet AGL, the RE-UAS will not be operated more than 100 feet above the highest point onthe 

structure, and within 50 feet horizontally of the structure. Additionally, due the nature of the proposed 

operations, the Pilot and/or Observers(s) may need to be less than 500 feet away from the RE-UAS.

15Relief from § 91.119(a) will not be necessary because Petitioner will be able to perform an emergency 

landing without undue hazard to persons or property on the ground in the event of a failure. Petitioner's 

proposed RE-UAS operations will not occur over congested areas, and therefore an exemption from § 

91.119(b) will not be necessary. See e.g., Grant of Exemption No. 11157 to Slug wear, Inc., dba Like on a 

tree Aerial (FAA-2014-0534 at 15).
U.S. Department of Transportation 

Sept 6, 2015

Page 20

Equivalent Level of Safety

Compared to flight operations with rotorcraft weighing far more than the maximumweights 

proposed herein, and given the lack of flammable fuel with the RE-UASs, any risk associatedwith 

these operations is far less than those that presently exist with conventional aircraft. An equivalent 

level of safety will be achieved given the size, weight, and speed of the RE-UASs, as well the 

controlled location where the operations will occur. In order to avoid any risk to manned aircraft, 

flight operations will be restricted to 400 feet AGL or below, or when inspecting a structure whose 

height exceeds 400 feet AGL, within 100 feet above the highest point on that structure and 50 feet 

horizontally of the structure.

As set forth in the Operations Manuals, the RE-UASs will be operated in a restricted area, and all 

flights will be operated at a lateral distance of at least 500 feet from any nonparticipating persons,unless 

that person is in a position where he or she is shielded from the RE-UAS and any possible debrisresulting 

from RE-UAS failure. As required by the Operations Manuals, flights will be terminated if a 

nonparticipating person within 500 feet of the RE-UAS leaves a shielded position. Further, RE-UAS

operations will occur at least 500 feet away from vehicles or structures unless the propertyowner

/controller has granted permission and the PIC has made a safety assessment of the risk of operating

closer to those objects and, operations near the PIC or Observer will not present an undue hazard per § 

91.119(a). Adherence to these restrictions in DMD’s Operations Manuals will ensure operations can be 

conducted without compromising safety.16

K. 14 C.F.R. § 91.121: Altimeter Settings

DMD seeks an exemption from 14 C.F.R. § 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 ofthe 

departure airport or barometric pressure An exemption is required to the extent that the RE-UASs donot 

have a barometric altimeter, but rather a GPS altitude read out.

16See e.g., Grant of Exemption No. 11138 to Douglas Trudeau (FAA-2014-0481 at 19):

"If barriers or structures are present that can sufficiently protect nonparticipating persons from the UA or 

debris in the event of an accident, then the UA may operate closer than 500 feet to persons afforded such 

protection. The operator must also ensure that nonparticipating persons remain under such protection. If a 

situation arises where nonparticipating persons leave such protection and are within 500 feet of the UA, 

flight operations must cease immediately. When considering how to immediately cease operations, the 

primary concern is the safety of those nonparticipating persons. In addition, the FAA finds that operations 

may be conducted closer than 500 feet to vessels, vehicles and structures when the owner/controller of any 

such vessels, vehicles orstructures grants permission forthe operation and the PIC makes a safety 

assessment of the risk of operating closer to those objects and determines that it does not present an undue 

hazard.
U.S. Department of Transportation 

Sept 6, 2015

Page 21

The FAA has stated that an equivalent level of safety to the requirements of 14 C.F.R. § 91.121 

can be achieved in circumstances where: (1) the RE-UASs will be operated below 400 feet AGL or

below17, (2) within VLOS, (3) where GPS based altitude information is relayed in real time to theoperator

at a ground-based on-screen display and, (4) where prior to each flight, a zero altitude initiation pointis 

established for the PIC to confirm accuracy of the onboard GPS.18

The RE-UASs that DMD intends to use for the proposed operations will meet all these operational 

characteristics. Moreover, as required by DMD’s Operations Manuals, the PIC will be required to 

calibrate the aircraft's GPS compass prior to each flight operation. Like prior FAA Section 333 Grants of 

Exemption, the RE-UASs DMD to use, and the safety mitigation procedures contained in the Operations 

Manuals, both ensure that an equivalent level of safety will be achieved, and a Grant of Exemption to the 

requirements of § 191.121 is therefore appropriate.

L. 14 C.F.R. § 91.151(a): Fuel Requirements for Flight in VFR Conditions

DMD requests an exemption from 14 C.F.R. § 91.151(a)'s 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.

Here, the technological limitations on RE-UAS battery power means that no meaningfulflight 

operations can be conducted while still maintaining a 30-minute battery reserve. An exemption fromthe 

fuel requirements of 14 C.F.R. § 91.151(a) is therefore required.

17 If the height of the structure being inspected exceeds 400 feet AGL, the RE-UAS will not be operated 

more than 100 feet above the highest point on the structure.

18 See Grant of Exemption No. 11062 to Astraeus Aerial (FAA-2014-0352 at 21).
U.S. Department of Transportation 

Sept 6, 2015

Page 22

Equivalent Level of Safety

In the Grant of Exemption to VDOS (Exemption No. 11112), the FAA determined that an 

equivalent level of safety to the fuel requirements for flight in VFR conditions could be achieved by 

prohibiting the PIC from beginning a RE-UAS flight unless (considering wind and forecast weather 

conditions) there was enough power to fly to the first intended point of landing and, assuming normal 

cruising speed, to fly after that for at least 10 minutes. In reaching this conclusion, the FAA considered that 

the RE-UAS batteries for the RE-UAS provided provide approximately 20 minutes of powered flight (with 

payload) and provided battery level and battery time remaining in minutes and seconds to the PIC.19 The 

FAA also considered the fact that the RE-UAS operating manual states: “start every flight with a fully 

charged battery in the aerial vehicle”, and that in the event that the RE-UAS should run low on power, the 

PIC will be alerted and can land the RE-UAS as soon as possible. Like the VDOS Grant of Exemption, 

DMD’s use of the RE-UAS, combined with the requirements of Petitioner's Operations Manuals, ensure 

that an equivalent level of safety can be achieved.

Similarly, in the Grant of Exemption to Alan Purwin (Exemption No. 11161), the FAA determined 

that an equivalent level of safety to the fuel requirements for flight in VFR conditions could be achieved by 

prohibiting the PIC from beginning a flight with the RE-UAS unless (considering wind and forecast 

weather conditions), there was enough power to fly at normal cruising speed to the intended landing point 

and land the UA with 25% battery power remaining. DMD will adhere to this limitation for RE-UAS

flights.

The RE-UAS includes a low battery warning system and the amount of battery reserve power 

remaining is transmitted to the PIC via telemetric data feed, which downlinks from the RE-UAS to a 

ground-based-on-screen display.20 As required by DMD’s Operations Manuals, the PIC will promptly fly 

the RE-UAS back to the home launch location or pre-determined abort location where the RE-UAS may 

safely land, while still maintaining a minimum of 25% reserve battery power. DMD submitsthat the 

procedures requiring flights to be safely terminated once the batteries fall below 25% capacity, combined 

with the requirement that flights only be conducted within a secure, isolated area, using a RE- UAS 

weighting less than 55 pounds, and within VLOS of the PIC and Observer(s), ensure that the proposed 

operation will provide an equivalent or higher level of safety to that provided by the regulations from 

which exemption is sought.

19Grant of Exemption No. 11112 to VDOS Global, LLC (FAA-2014-0382 at 10).

20The RE-UAS ground control station displays, the RE-UASs position, navigation route, tail number, 

altitude, heading, north seeking arrow, range to targets, calculated target position, date/time, and sensor 

heading and orientation relative to the RE-UAS.
U.S. Department of Transportation 

Sept 6, 2015

Page 23

VI. DRUG AND ALCOHOL PROGRAM

DMD will have policies in place to ensure that no person may participate in RE-UAS flight 

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

VII. PUBLIC INTEREST

The public interest will be served by granting DMD’s Petition for Exemption. Congress has 

established a national policy that favors early integration of RE-UAS into the NAS in controlled,safe 

working environments such as those proposed in this Petition. Granting this Petition for Exemption helps 

fulfill Congress' goal in passing Section 333(a) through (c) of the Reform Act—the FAA Administrator's 

assessment of whether certain RE-UAS may operate safely in the NAS before completion of the statutorily 

required rulemaking.

The proposed RE-UAS operations in this Petition for Exemption significantly improve safety and 

reduce risk harm or serious injury to inspecting engineers. Traditional methods of real estate video 

production and inspection of structures, expose videographer-inspectors to higher risks of serious injuries, 

or death. Videographer-inspectors need to climb roof tops or otherwise perform elevated work, which 

exposes them to the risk of dangerous falls, electrocution or other work related extremes. In addition, 

depending on the nature of the video needed and inspection, proximity to equipment, and other mechanical 

hazards associated with industrial sites and construction facilities often involves a risk of exposure to 

hazardous. The use of RE-UASs mitigates these hazards and is ultimately a much safer method of 

performing these and most other types of inspections.

The use of small RE-UASs also enhances safety and reduces risk because, unlike manned aircraft 

weighing thousands of pounds, carrying crew in addition to flammable fuel, the RE-UASs carry no 

passengers or crew. Further, in the unlikely event of an accident, DMD small battery powered RE- UASs 

presents significantly less danger to persons on the ground when compared to operations by conventional 

manned aircraft.21 As Petitioner's RE-UASs are battery powered, the public will also benefit from a 

reduction in harmful emissions associated with conventional aircraft performing in the same functions 

proposed herein. Lastly, as recognized by the FAA in prior Section 333 Grants of Exemption to 

filmmakers, RE-UASs provide an additional tool for the aerial filming industry, adding a greater degree of 

flexibility, which supplements the current capabilities offered by manned aircraft.22

21See Grant of Exemption No. 11158 to Team 5, LLC (FAA-2014-0783 at 12): Manned helicopters 

conducting aerial filming can weigh 6,000 pounds or more and are operated by an onboard pilot, in addition 

to other onboard crewmembers, as necessary. The petitioner’s UAs will weigh less than 55 pounds with no 

onboard pilot or crew. The pilot and crew will be remotely located from the aircraft. The limited weight 

significantly reduces the potential for harm to participating and nonparticipating individuals or property in 

the event of an incident or accident. The risk to an onboard pilot and crew during an incident or accident is 

eliminated with the use of a UA for the aerial filming operation."
U.S. Department of Transportation 

Sept 6, 2015

Page 24

RE-UASs provide an additional tool for the aerial filming industry, adding a greater degree of flexibility, 

which supplements the current capabilities offered by manned aircraft.22

VIII. PRIVACY

All DMD’s RE-UAS operations will be conducted in accordance with applicable federal, state, or 

local laws regarding privacy. 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.

IX. FEDERAL REGISTER SUMMARY

Pursuant to 14 C.F.R. 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 in Title 14 of the Code of Federal 

Regulations:

Part 21, Subpart H; Part 27; 45.23(b); 45.27(a); 61.113; 91.7(a); 91.9(b)(2); 91.9(c); 91.103; 91.109(a);

91.119(c); 91.121; 91.151(a); 91.203 (a) & (b); 91.405(a); 91.407(a)(1); 91.409(a)(1) & (2); 91.417 (a)

& (b).

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

from the substantial hazards associated with performing equivalent real estate aerial photography and 

inspection with conventional fixed-wing aircraft, rotorcraft, or other methods.

X. CONCLUSION

DMD’s Petition for Exemption satisfies the criteria articulated in Section 333 of the Reform Act of 

2012 including weight, speed, operating capabilities, proximity to airports and populated areas, operation 

within VLOS and national security. The proposed RE-UAS operations will benefit the public as a whole by

improving safety and reducing risk by alleviating human exposure to danger. In consideration of the 

foregoing, this Petition for Exemption provides the FAA with more than adequate justification for granting 

the requested exemptions allowing DMD use small RE-UASs for providing aerial photography and 

videography for the real estate industry, as well as property mapping, inspections, and 3D compositing.

22 See e.g., Grant of Exemption No. 11178 to Picture Factory, Inc. (FAA-2014-0794 at 18).
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Sept 6, 2015

Page 25

(The following attached items contain and commercial information exempt from disclosure underthe 

Freedom of Information Act, 5 U.S.C. § 522 et seq., and should be held in a separate file pursuant to 14 

C.F.R. § 11.35(b).

Attachments:

1. General Operations Manual

2. PIC Operating Manual

3. DMD Protocols

4. Location Protocols

5. Flight Communications Protocols

6. Departing Location Protocols

7. Transmitter Protocols

8. Preflight Checklist

9. Post Flight Checklist

10. Equipment Checklist

11. UAS Manufacturer’s Manuals

a. User Manuals

b. Maintenance Manuals