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(Sandhills Drone Services, LLC)

Owner/Operator: Gregory M. Cox

148 Cranes Creek Rd.

Cameron, N.C 28326

919-356-5031

sandhillsdrone@gmail.com

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 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 91.203 

(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, 

Sandhills Drone Services, LLC, operator of an Unmanned Aircraft System (UAS), hereby applies for an exemption 

from the listed Federal Aviation Regulations (“FARs”) to allow commercial operation of its 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. 

Commercial operation of an UAS, as described herein, which are equipped with camera(s) and sensors, would 

operate in the following manner: 

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

surveying, engineering and other related professional activities. 

Aerial video and/or photography for public and/or private use.

Aerial inspection/photography of residential/commercial structures under contract with the owners or 

local government authority. 

Aerial video/photography or providing live video feed to assist with search and rescue operations in cases 

of an emergency or natural disaster only when the local authorities or government has requested it.

Aerial video/photography of local government buildings for the purpose of establishing Emergency 

Evacuation Plans. Also for the purpose pre-planning Active Shooter Incidents or any other incidents that 

occur on Local(County) property.

As described fully below, the requested exemption would permit the operation of a UAS under controlled 

conditions in the NAS that would be a) limited b) controlled c) predetermined and d) will provide safety 

enhancements to the already safe operations in the industry presently using conventional aircraft. Approval of 

this exemption would thereby enhance safety and fulfill the Secretary of Transportation’s (the FAA 
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Administrator’s) responsibilities to “....establish requirements for the safe operation of such aircraft systems in the 

national airspace system.” 

The name and address of the applicant is: 

Sandhills Drone Services, LLC 

Attn: Gregory M. Cox, Owner. Operator

Phone: 919-356-5031

Email: sandhillsdrone@gmail.com

Address: 148 Cranes Creek Rd. Cameron N.C 28326

Regulations from which the exemption is requested: 

14 CFR Part 21 subpart H 

14 CFR 45.23 (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 91.203 (a) & (b) 

14 CFR 91.405 (a) 

14 CFR 91.407 (a) (1) 

14 CFR 91.409 (a) (2) 

14 CFR 91.417 (a) & (b) 

Sandhills Drone, LLC will operate the DJI Phantom 2 V2, with a total weight of 1000g or 2.20lbs. The diagonal 

dimensions including propellers are 590 mm x 590 mm. Maximum airspeed is no more than 15m/s (Not 

recommended). The DJI Phantom 2 V2 has the ability to hover and move along a vertical and horizontal plane 

simultaneously. The DJI Phantom 2 has four brushless electric motors, powered by a 5200mAh LiPo Lithium 

Polymer battery. There are four propellers, Propeller Model DJI 9450, in use. The DJI Phantom 2 will be controlled 

with the factory Phantom 2- Remote Controller with an operating frequency of 2.400GHz – 2.483GHz. The live 

video feed will have an operating frequency of 5.728GHz – 5.850GHz. The applicant will operate the UAS in line of 

sight within a predetermined area owned and or operated by the property representative. 

DJI Phantom 2 V2 Specs

Aircraft 

Weight (including battery and propellers): 1000 g
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Diagonal size (including propellers): 590 mm

Max Ascent Speed: 5 m/s, 984 fpm 

Max Descent Speed: 3 m/s, 590 fpm 

Hover Accuracy

o Vertical: +/- 0.1 m (when Vision Positioning is active) or +/- 0.5 m 

o Horizontal: +/- 1.5 m

Max Speed: 165m/s, 

Max Altitude Above Sea Level: 6000 m

Operating Temperature: 0°C to 40°C

GPS Mode: GPS/GLONASS

Camera 

GoPro 3+ Black

Weight: 2.61 oz

Camcorder Media Type: Flash Card

Optical Sensor Type: CMOS

Wireless Connection: Wireless Lan

Still Photography Modes

o Single Shot

o Burst Shooting: 3/5/7 shots

o Time-lapse

Video Recording

o Digital Video Format: H.264

Supported SD Card Types

o Micro SD Max capacity: 64 GB. Class 10 or UHS-1 rating required

Supported File Format:

o Photo: JPEG, DNG

o Video: MP4, MOV (MPEG-4 AVC/H.264)

Operating Temperature

o 0°C to 40°C

Zenmuse H3-3D Gimbal

3 Axis Gimbal

Stabilization: 3-axis (pitch, roll, yaw)

 

Remote Controller 

Operating Frequency: 2.400 GHz-2.483 GHz

Max Distance: 2000m (outdoors and unobstructed)

Video Output Port: USB

Operating Temperature: 0°C- 40°C

Battery: 6000 mAh LiPo 2S

Device Holder: For Pearl Black Receiver

o CE: 16 dBm

Working Voltage: 1.2 A @7.4 V

Battery Charger 
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Voltage: 17.4 V

Rated Power: 100 W

Intelligent Flight Battery 

Capacity: 4480 mAh

Voltage: 15.2 V

Battery Type: LiPo 4S

Energy: 68 Wh

Net Weight: 365 g

Max Flight Time: Approximately 23 minutes 

Operating Temperature: -10°C to 40°C

Max Charging Power: 100 W

Flysight Monitor 7in Black Pearl Monitor

Display Screen 7 inch

Resolution: 1020x600

Contrast: 700:1

Working Frequency: Sensitivity 

ISM 5.8GHz 

Band CH 1 CH2 CH3 CH4 CH5 CH6 CH7 

A 5865M 5845M 5825M 5805M 5785M 5765M 5745M 

B 5733M 5752M 5771M 5790M 5809M 5828M 5847M 

E 5705M 5685M 5665M 5645M 5885M 5905M 5925M 

F 5740M 5760M 5780M 5800M 5820M 5840M 5860M 

Given the small size of the UAS and the controlled environment provided the proposed operations will adhere to 

the Reform Act’s safety requirements. The approval of this application presents no national security issues. 

Regarding the level of safety surrounding the proposed operations and the public benefit, reduction in 

environmental impacts, including but not limited to reduced emissions and noise, the grant of the requested 

exemption is in the public interest. Accordingly the applicant requests that the FAA grant the requested 

exemption with minimum delay. 

AIRCRAFT AND EQUIVALENT LEVEL OF SAFETY

The operation limitations proposed for an equivalent or higher level of safety because operations will further 

enhance the safety of the persons and/or property using conventional aircraft. 

These limitations and conditions to which the applicant agrees to adhere to when conducting commercial 

operations under the FAA issued exemption as set forth in the Flight Operations Manual (FOM) include: 
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The UAS will weigh less than 55 lbs. 

The UAS will have a maximum operating airspeed of no more than 50 Kts. 

Flights will be operated within line of sight of the Pilot in Command (PIC) and Visual Observer (VO) if 

utilized. 

Maximum flight time for each operational flight will be 15 minutes. Flights will be terminated at 30% 

battery power reserve or 15 minutes of flight time whichever occurs first. 

Flights will be operated at an altitude of no more than 400 feet Above Ground Level (AGL). 

Minimum crew for each operation will consist of the UAS Pilot, and may include, depended on mission 

requirements, a Visual Observer (VO). 

The UAS pilot will be a designated Pilot in Command (PIC) and will take and pass all necessary 

certifications currently being approved by the FAA administration for commercial use. 

A briefing will be performed regarding the planned UAS operations prior to each day’s flight consisting of 

all the days’ production activities. 

All flights will occur under Visual Flight Rules Meteorological Conditions (VMC) only. 

The flights will occur no closer than a 5 mile radius of the geographic center/Airport Reference Point 

(ARP) of a tower controlled or uncontrolled airport. The DJI Phantom 2 has built in software for all FAA 

regulated ‘No Fly Zones’ and was uploaded by DJI (July 2015 Firmware) for all DJI drones to download and 

prevent any possible flights occurring within no-fly zones. DJI Phantom 2 has installed software (code) 

that denies flights within the FAA no-fly zones. 

If operations will be within a 5 mile radius of the geographic center/Airport Reference Point (ARP) of a 

tower controlled or uncontrolled airport the respective airports will be contacted advising them of the 

estimated flight time, flight duration, elevation of flight and other pertinent information. 

The PIC, and VO if utilized, will have been trained in operation of UAS and receive up-to-date information 

for the particular UAS to be operated. 

The PIC and VO, if utilized, will be able to communicate by voice, radio, and/or text at all times. 

Written and/or verbal permission and permits will be obtained from territorial, state, county or city 

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

If the UAS loses communications with the remote controller or loses GPS signal, the UAS will have the 

capability to return to a pre-determined location within a designated location and land autonomously. 

The UAS will have the capability to abort a flight in case of unpredicted obstacles, weather, or 

emergencies. 
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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 

with the aircraft to be utilized by the Applicant, an exemption from Part 21 Subpart H meets the requirements of 

an equivalent level of safety under Part 11 and Section 333 of the Reform Act. The Federal Aviation Act (49 

U.S.C.§44701 (f)) and Section 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 proposed. 

The UAS to be operated hereunder is less than 55 lbs. (3 lbs.) fully loaded, carries neither a pilot nor passenger, 

carries no explosive materials or flammable liquid fuels, and operates exclusively within a secured and designated 

area. Unlike other civil aircraft, operations under this exemption will be tightly controlled and monitored by both 

the operator and under the requirements and in compliance with local public safety requirements. The FAA will 

have advance notice of all operations. These safety enhancements provide a greater degree of safety to the public 

and property owners than conventional 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 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 C.F.R. § 45.23 (b). Marking of the Aircraft 

The regulation requires: 

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 2 

inches nor more than 6 inches high, the words "limited," "restricted," "light-sport," "experimental," or 

"provisional," as applicable. 

Even though the UAS will have no airworthiness certificate, an exemption may be needed as the UAS will have no 

entrance to the cabin, cockpit or pilot station on which the word “Experimental” can be placed. 

Given the size of the UAS, two-inch lettering will be impossible. The word “Experimental” will be placed on the 

fuselage in compliance with §45.29 (f). 

The equivalent level of safety will be provided by having the UAS marked on its fuselage as required by 

§45.29 (f) where the pilot, observer and others working with the UAS will see the identification of the UAS as 

“Experimental.” 

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

The regulation requires that no person may operate a civil aircraft unless it is in airworthy condition. As there will 

be no airworthiness certificate issued for the aircraft, should this exemption be granted, no FAA regulatory 

standard will exist for determining airworthiness. 
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Given the size of the aircraft for maintenance and use of safety check lists prior to each flight an equivalent level of 

safety will be provided. 

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

Section 91.9 (b) (2) provides: No person may operate a U.S.-registered civil aircraft ... (2) For which an Airplane or 

Rotorcraft Flight Manual is not 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. The UAS, given its size and configuration has no ability or place to carry such a flight manual 

on the aircraft, not only because there is no pilot on board, but because there is no room or capacity to carry such 

an item on the aircraft. The equivalent level of safety will be maintained by keeping the flight manual at the 

ground control point where the pilot flying the UAS will have immediate access to it. 

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

This regulation requires each pilot in command to take certain actions before flight to insure the safety of flight. As 

FAA approved rotorcraft flight manuals will not be provided for the aircraft an exemption will be needed. The PIC 

will take all actions as stated in the DJI Phantom 2 Flight Section of the User Manual including but not limited to 

reviewing weather, flight battery requirements, landing and takeoff distances and aircraft performance data 

before initiation of flight. 

14 C.F.R. §91.109: Flight Instruction. 

Section 91.103 provides that no person may operate a civil aircraft (except a manned free balloon) that is being 

used for flight instruction unless that aircraft has fully functioning dual controls. UAS and remotely piloted aircraft, 

by their design do not have fully functional dual controls. Flight control is accomplished through the use of a 

control box that communicates with the aircraft via radio communications. The FAA has approved exemptions for 

flight training without fully functional dual controls for a number of aircraft and for flight instruction in 

experimental aircraft. The equivalent level of safety provided by the fact that neither a pilot nor passengers will 

be carried in the aircraft and by the size and speed of the aircraft. 

14 C.F.R. §91.119: Minimum Safe Altitudes. 

Section 91.119 establishes safe altitudes for operation of civil aircraft. Section 91.119 (d) allows helicopters to be 

operated at less than the minimums prescribed, provided the person operating the helicopter complies with any 

route or altitudes prescribed for helicopters by the FAA. As this exemption is for a UAS that is a helicopter and the 

exemption requests authority to operate at altitudes up to 400 AGL, or not more than 200 above an elevated 

platform from which filming is planned, an exemption may be needed to allow such operations. As set forth 

herein, the UAS will never operate at higher than 400 AGL with the exception that in circumstances where the UAS 

is used to survey or photograph a structure whose height exceeds 400 feet AGL, the UAS will not be operated 

more than 200 feet above the highest point on the structure. It will however be operated in a restricted area with 

security perimeter, where buildings and people will not be exposed to operations without their pre-obtained 

consent. 

The equivalent level of safety will be achieved given the size, weight, speed of the UAS as well as the location 

where it is operated. No flight will be taken without the permission of the property owner or local officials. 

Because of the advance notice to the property owner and participants in the filming activity, all affected 

individuals will be aware of the planned flight operations. Compared to flight operations with aircraft or rotorcraft 

weighting far more than the maximum 55lbs. proposed herein and the lack of flammable fuel, any risk associated 

with these operations is far less than those presently presented with conventional aircraft operating at or below 
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500 AGL. In addition, the low-altitude operations of the UAS will ensure separation between these UAS operations 

and the operations of conventional aircraft that must comply with Section 

91.119. 

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

This regulation requires each person operating an aircraft to maintain cruising altitude by reference to an altimeter 

that is set “...to the elevation of the departure airport or an appropriate altimeter setting available before 

departure.” As the UAS may not have a barometric altimeter, but instead a GPS altitude read out, an exemption 

may be needed. An equivalent level of safety will be achieved by the operator, pursuant to the safety check list 

and live flight data monitoring, confirming the altitude of the launch site shown on the GPS altitude indicator 

before flight. 

14 C.F.R. §91.203 (a) and (b): Carrying Civil Aircraft Certification and Registration 

The regulation provides in pertinent part: 

(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. 

The UAS fully loaded weighs no more than 55 lbs. and is operated without an onboard pilot. As such, there is no 

ability or place to carry certification and registration documents or to display them on the UAS. 

An equivalent level of safety will be achieved by keeping these documents at the ground control point where the 

pilot flying the UAS will have immediate access to them; to the extent they are applicable to the UAS. 

14 C.F.R. §91.405 (a); 407 (a) (1); 409 (a) (2); 417(a) & (b): Maintenance Inspections. 

These regulations require that an aircraft operator or owner “shall have that aircraft inspected as prescribed in 

subpart E of this part and shall between required inspections, except as provided in paragraph (c) of this section, 

have discrepancies repaired as prescribed in part 43 of this chapter...,” and others shall inspect or maintain the 

aircraft in compliance with Part 43. 

Given that these section and Part 43 apply only to aircraft with an airworthiness certificate, these sections will not 

apply to the applicant. Maintenance will be accomplished by the operator pursuant to the flight manual and 

operating handbook. An equivalent level of safety will be achieved because the UAS is very limited in size and will 

carry a small payload and operate only in restricted areas for a limited period of time. If mechanical issues arise 

the UAS can land immediately and will be operating from no higher than 400 feet AGL. The operator will ensure 

that the UAS is in working order prior to initiating flight, perform required maintenance, and keep a log of any 

maintenance performed. Moreover, the operator is the person most familiar with the aircraft and best suited to 

maintain the aircraft in an airworthy condition to provide the equivalent level of safety. 
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An equivalent level of safety will be achieved because maintenance and inspections will be performed in 

accordance with the UAS Manufacturer's User Manual. As provided in the FOM, the operator will ensure that the 

UAS is in working order prior to initiating flight and perform required maintenance needed. 

Additional Information 

The applicant, Gregory M. Cox has been involved in Law Enforcement (Civilian/Military) for more than 30 Years

and has recently retired from local Law Enforcement. With the previous career, the applicant understands the 

necessity to follow rules, guidelines and laws set by the FAA. Also, the applicant understands that safety is 

paramount and is the first thought prior to operating UAS’s. The applicant has flown numerous flights as a 

hobbyist and now has request to operate commercially. For example, local law enforcement has inquired the 

applicant to take aerial photos of schools and local government buildings. The photos would be used for preplanning, Emergency Evacuation Plan, Active Shooter or any type of emergency. This type of aerial photograph 

would only be done one early morning weekends. The applicant has an understanding of the capabilities and 

safety concerns involved in using this technology as an asset to the community. Satisfaction of criteria provided in 

Section 333 of the Reform Act of 2012 provide justification for the grant of the requested exemptions allowing the 

commercial operation of the applicant’s UAS. 

Sincerely, 

Gregory, M Cox

10/28/2015