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U. S. DEPARTMENT OF TRANSPORTATION

FEDERAL AVIATION ADMINISTRATION

DOCKET MANAGEMENT SYSTEM

West Building Ground Floor, Room w 12140

1200 New Jersey Ave., SE

Washington, DC 20590

In the matter of Petition for exception of:

AERO DRONE RESOURCES LLC. 

concerning commercial operations of unmanned 

aircraft systems
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Table of Contents

SUMMARY FOR SEEKING EXEMPTION ................................................................................ 3

COMPANY BACKGROUND................................................................................................... 4

UNMANNED AIRCRAFT SYSTEM SPECIFICATIONS............................................................... 5

GROUND CONTROL STATION.............................................................................................. 6

BASIS FOR PETITION FOR EXEMPTION ................................................................................ 7

NAME AND ADDRESS OF PETITIONER ................................................................................ 7

SPECIFIC SECTIONS OF 14 C.F.R. FROM WHICH AERO DRONE RESOURCES LLC, SEEKS 

EXEMPTIONS AND THE EXTENT OF RELIEF ......................................................................... 7

REASONS WHY THE EXEMPTION WOULD NOT ADVERSELY AFFECT PUBLIC SAFETY AND 

HOW THE EXEMPTION WOULD PROVIDE A LEVEL OF SAFETY AT LEAST EQUAL TO THE 

EXISTING RULE .................................................................................................................. 18

THE EXEMPTION IS IN THE PUBLIC INTEREST ................................................................... 20

A SUMMARY TO BE PUBLISHED IN THE FEDERAL REGISTRAR.......................................... 21

SUPPORT FOR THE REQUEST FOR AN EXEMPTION ...............ERROR! BOOKMARK NOT DEFINED.

NO PRIVACY ISSUES ARISE AT THE GRANT OF THE EXEMPTION........................................ 21

CONCLUSION..................................................................................................................... 22

GLOSSARY /ABBREVIATIONS............................................................................................. 22
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SUMMARY FOR SEEKING EXEMPTION 

AERO DRONE RESOURCES LLC, seeks an exemption pursuant to Section 333 of the 

Reform Act, to use a number of different UAS platforms for training and aerial data 

collection from the requirements of Title 14 of the Code of Federal Regulations in 

particular an exemption from the following sections: 

Part 21 

14 C.F.R. §45.23(b) 

14 C.F.R. §45.27(a) 

14 C.F.R. §61.113 (a) and (b) 

14 C.F.R. §91.7(a) 

14 C.F.R. §91.9(b) (2) 

14 C.F.R. §91.103 

14 C.F.R. §91.105

14 C.F.R. §91.109(a) 

14 C.F.R. §91.119(b) 

14 C.F.R. §91.121 

14 C.F.R. §91.151(a) (1) 

14 C.F.R. §91.203(a) and (b) 

14 C.F.R. §91.405(a) 

14 C.F.R. §91.407(a) (1) 

14 C.F.R. §91.409(a) (2)

14 C.F.R. §91.417(a) and (b) 

AERO DRONE RESOURCES LLC., seeks to commercially fly an Unmanned Aircraft System 

(UAS) within the United States. The proposed UAS are less than 55 lbs. max gross and

will be flown below 400 feet above ground level (“AGL”) outside the 5 miles radius of an 

FAA airport unless a letter of agreement with that airport’s management is obtained 

and NOTAM filed. The exemption will have a positive impact on the public interest by 

providing services that are not available to the general public but are in high in demand 

in both private and municipal sectors. The exemption in particular will allow AERO 

DRONE RESOURCES LLC, to offer wide spectrum of services using the UAS including and 
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not limited to community training workshops on the proper use and operation of UASs 

to:

1. Ensure safe operation by hobbyists and commercial users 

2. Provide economically beneficial options for building/site inspections. 

3. Provide first responders an alternative by using the UAS to investigate danger 

situations which otherwise would risk human lives and/or property.

4. Land survey and data gathering for agricultural planning and Forest Inventory.

The Petitioner is dedicated to following the conditions and limitations as imposed by the 

FAA regarding the flight of the UAS and including but not limited to avoiding and 

yielding right-of-way to all manned operations, file necessary notices and flight plans as 

well as adhering to city and state imposed regulations to ensure the utmost safety for 

the general public and the operators. 

COMPANY BACKGROUND 

AERO DRONE RESOURCES LLC, is an Oregon Corporation with a primary place of 

Business in Albany OR. 

It is founded by two entrepreneurs with aviation background and a strong interest and 

desire to bring innovative services and safety to the public using the UAS vehicle as a 

more practical, economical and useful alternative.

Both founders have a strong background in aviation. One is Private Pilot, Aircraft owner 

and FBO owner and the other is an ATP/CFI/Gold Seal flight instructor with over two 

thousand hours of instruction given in a Tittle14 CFR part141 environment and over 

twenty years of RC unmanned aircraft building and flying.

The company will be engaged in performing Research, Development, Data gathering and 

Training for a unique platform of services to be utilized commercially by a variety of 

professionals.

AERO DRONE RESOURCES LLC., is dedicated to offering innovative and customized 

services to consumers using the UAS to better serve the community and the public 

interest by providing a safer alternative to current practices of building inspection and 

other aviation services as well as by providing training workshops for other UAS 

operators and commercial entities to ensure safer operations in the National Airspace 

System (“NAS”). 
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UNMANNED AIRCRAFT SYSTEM SPECIFICATIONS 

AERO DRONE RESOURCES LLC intends to use the following vehicles that meet the 

requirements of Section 333 of the Reform Act due to their weight, speed and 

operational capabilities:

 SenseFly EBee 

 DJI Inspire 1 

 DJI Phantom 3

 3DR Solo

 Draganflyer X4-ES 

 Latitude HQ-40A 

 Mikrokopter Rotorcraft 

 Delta Drone Delta Y

 MicroDrone md4-200

The FAA is familiar with and has already determined that the commercial off-the-shelf 

vehicles selected meet the requirements of Section 333 of the Reform Act due to their 

weight, speed and operational capabilities: 

 SenseFly eBee: Exemption No. 11673 to Aerial Scout Ag Ops Support, LLC; 

Exemption No. 11646 to BioSensing Systems, LLC; Exemption No. 11263 to 

SenseFly LTD. 

 DJI Inspire 1: Exemption No. 11254 to Upward Aerial; Exemption No. 11659 to 

Fovea Aero Systems; Exemption No. 11668 to Sky-Forge Robotics LLC. 

 DJI Phantom 3: Exemption No. 12734: Docket FAA-2015-1964

 Draganflyer X4-ES: Exemption No. 11557 to HAZON Solutions LLC; Exemption 

No. 11424 to AgScan, Inc.; Exemption No. 11281 to Draganfly Innovations, Inc. 

 3DR Solo: Exemption No.11935: Docket FAA-2015-1356

 Draganflyer X4-ES : Exemption No. 12040: Docket FAA-2015-1248

 Latitude HQ-40A: Exemption No. 12205A: Docket FAA-2015-1873

 Mikrokopter Rotorcraft: Exemption No. 11891: Docket FAA-2015-0778
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 Delta Drone Delta Y MicroDrone md4-200: Exemption No. 12791: Docket FAA2015-2070

 Trimble UX5 and Trimble UX5hp: Exemption No. 14445 Docket FAA-2015-5189

GROUND CONTROL STATION 

The ground control (“GCS”) station is the primary takeoff and landing point of the UAS 

and includes a setup, consisting of people and equipment, to promote the utmost safety 

for all persons involved in the operation including the operators, general public, and any 

objects or persons that may come into contact with the zone of operation (“Zone”).

Specifically the ground station includes: 

a. Pilot in Command: A designated pilot with a minimum of a sport pilot’s license

ground training or equivalent and current FAA airman medical certificate or a 

valid U.S. driver’s license and a deep knowledge with thorough understanding of 

the UAS and its operational capabilities as well as numerous hours of experience 

in operating the aircraft. PIC will operate the UAS within visual line of sight 

(VLOS) at all times using human vision unaided by any device other than 

corrective lenses.

b. Flight Coordinator / Visual Observer (FC or VO): A second person, other than the 

PIC, within visual range of the UAS at all times with the ability and 

knowledgeable to assist the PIC as needed including verbal as well as physical 

command of the controls will be required when operating within 5 miles of the 

center of the Albany Airport. The FC will have access to a VHF 2 way radio and 

will monitor the Unicom frequency for airport traffic. The UAS will always be 

within the VLOS of the FC. The PIC and the FC will have the ability to 

communicate verbally at all times.

c. Equipment: 

a. A 100mW, 2.4GHz radio transmitter/controller operated by the PIC. 

b. A portable receiver receiving transmitted live video and flight data from 

the UAS onboard camera and computer. This data is projected onto the 

controller used by the PIC to assist during flight. 

c. A functional handheld 2 Way VHF radio only when operating with 5 miles 

of the center of the Albany Airport.

d. Fire Extinguisher 

d. Zone: a designated area cordoned off by orange colored cones and/or ribbons to 

put the surrounding public on notice of the operation. One sandwich board with 
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the name of the company, contact information, and description of the operation 

in order to alert the general public of the event taking place and allowing anyone 

interested to contact AERO DRONE RESOURCES LLC ,

e. Paperwork: The ground station will also include a designated area for the 

Operator’s Manual (Appendix A) as amended with conditions or limitations 

scripted by the FAA, copy of the granted exemption, pursuant to the grant of this 

exemption by the FAA, copy of the insurance certificate, business cards and any 

other relevant paper work for the specific event. (Copy of Plan of Activities and 

COA) Mission Checklist (Appendix B)

f. Other: Anything else that is required in order to be in full compliance with the 

regulations of the City and State where the event is taking place. 

BASIS FOR PETITION FOR EXEMPTION 

Pursuant to the authority granted to the FAA under Federal Aviation Regulations, 14 

C.F.R. § 11.61(b) and the FAA Modernization and Reform Act of 2012, Section 333, 

Special Rules for Certain Unmanned Aircraft Systems, XKYVIEW Inc. respectfully requests 

to grant its petition for an exemption from the requirements of 14 C.F.R Part 21; 14 

C.F.R. §61.113 (a) and (b); 14 C.F.R. §91.7(a); 14 C.F.R. §91.9(b)(2); 14 C.F.R. §91.103; 14 

C.F.R. §91.109; 14 C.F.R. §91.119; 14 C.F.R. §91.121; 14 C.F.R. §91.151(a); 14 C.F.R. 

§91.203(a) and (b); 14 C.F.R. §91.405(a); 14 C.F.R. §91.407(a)(1); 14 C.F.R. §91.409(a)(2); 

and 14 C.F.R. §91.417(a) and (b). 

NAME AND ADDRESS OF PETITIONER

AERO DRONE RESOURCES LLC.

Attn: Jose Gutierrez/Tony Hann

525 Aviation Way

Albany, OR. 97322

SPECIFIC SECTIONS OF 14 C.F.R. FROM WHICH AERO 

DRONE RESOURCES LLC, SEEKS EXEMPTIONS AND THE 

EXTENT OF RELIEF

1. AERO DRONE RESOURCES LLC seeks an exemption from 14. C.F.R. Part 21 

14 C.F.R. Part 21- Airworthiness Certificate 
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14 C.F.R. Part 21 along with 14 C.F.R. §91.203(a) (1) establishes the necessary 

procedures in order to obtain an airworthiness certificate for a manned aircraft. The 

general purpose of an airworthiness certificate for an aircraft is to ensure the 

aircraft’s safe functionality, good working order and to ensure the safety of those 

onboard as well as anyone in proximity to the aircraft at any time. The Federal 

Aviation Act, 49 U.S.C. §44701(f) and Section 333 of the Reform Act statutorily 

authorize the FAA to issue an exemption from the airworthiness requirements upon 

consideration of the aircraft’s size, weight, speed and operational capability. Such 

considerations should be applied to Petitioner’s UAS in determining that AERO 

DRONE RESOURCES LLC., should be exempt from the airworthiness requirement for 

its UAS. 

The UAS to be operated by AERO DRONE RESOURCES LLC are less than 55 lbs. max 

gross (inclusive of additional equipment such as GPS tracker, camera, etc.) and does 

not carry a pilot or passengers. Furthermore, the UAS does not contain explosives, 

fuel or any other flammable materials. The operation of the UAS will be strictly 

confined to a designated area and under full control of the PIC and FC. 

Safety Standard: The UASs are equipped with several safety features, which will 

further serve as a reason to exempt it from an airworthiness certificate. The UAS is 

equipped with a “Fail-Safe Feature which allows it to self-correct a failure that is 

beyond control of the PIC. Once a “Failure” is detected the UAS’s automatic safety 

feature is triggered which prompts it to return to its GPS point of origin. 

AERO DRONE RESOURCES LLC. would like to refer to Exemptions No.11062 and

11067 in which the FAA previously determined that based on the [Petitioner’s] UAS 

“limited size, weight, operating conditions, design safety features and the imposed 

conditions and limitations the [Petitioner] has demonstrated that the operations 

would not adversely affect safety compared to similar operations conducted with 

aircraft that have been issued an airworthiness certificate under 14 C.F.R. Part 21, 

Subpart H”. 

In the alternative Petitioner respectfully requests that the Administrator finds that 

the exemption from 14 C.F.R. Part 21 is not necessary because the regulation is not 

applicable to the UAS to be used by the Petitioner.

2. AERO DRONE RESOURCES LLC seeks an exemption from 14 C.F.R. §45. 23(b) 

14 C. F. R. §45.23(b) - Display of Marks; General 

(b) 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 
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letters not less than 2 inches nor more than 6 inches high, the words “limited,” 

“restricted,” “light-sport,” “experimental,” or “provisional,” as applicable. 

Provided that the exemption from Part 21 is granted and the UAS will not need an 

airworthiness certificate, Petitioner seeks an exemption from the requirement that 

the word “limited,” “restricted,” “light-sport,” “experimental,” or “provisional,” as 

be displayed on the UAV near each entrance to the cabin, cockpit or pilot station 

since UAVs do not have a cabin, cockpit, pilot station or any other type of entrance. 

Also, except in some fixed wing UAVs, the size does not permit any markings to be 

above one inch (1”) in height and be longer than eight inches (8”). 

Safety Standard: In order to achieve an equivalent level of safety and to most 

closely comply with the FAA regulations, AERO DRONE RESOURCES LLC proposes to 

display a Registration Number on top of the UAS with the dimensions of the signage 

in compliance with 14 F.C.R. §45.29 (f)). This type of signage will allow the PIC, FC 

and others in close proximity to see the designation of the UAS and will comply with 

the new registration requirements.

AERO DRONE RESOURCES LLC will display markings as large as practicable on the top 

of the UAS in the interest of safety and compliance. See also Exemptions Nos. 10700, 

8738, 10167, and 10167A. 

3. AERO DRONE RESOURCES LLC, seeks an exemption from 14 C.F.R. §61.113(a) and 

(b) 

14 C.F.R. §61.113- Private pilot privileges and limitations: Pilot in command

(a) Except as provided in paragraphs (b) through (h) of this section, no person 

who holds a private pilot certificate may act as pilot in command of an 

aircraft that is carrying passengers or property for compensation or hire; nor 

may that person, for compensation or hire, act as pilot in command of an 

aircraft. 

(b) A private pilot may, for compensation or hire, act as pilot in command of an 

aircraft in connection with any business or employment if: 

1. The flight is only incidental to that business or employment; and 

2. The aircraft does not carry passengers or property for compensation 

or hire. 

AERO DRONE RESOURCES LLC., seeks an exemption from the restriction outlined in 

parts (a) and (b) of the regulation prohibiting a holder of a private pilot’s certificate 

to act as a pilot for an aircraft carrying property for compensation or hire. The UAS 

to be used by , will be used for commercial operation for compensation or for hire, 

however, will not be carrying any passengers or cargo allowing AERO DRONE 
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RESOURCES LLC, to achieve the same level of safety of current operations by 

requiring the PIC to obtain a private pilot’s license instead of a commercial pilot 

license. 

Safety Standard: Pursuant to obtaining a grant of the exemption to operate the UAS 

for compensation, AERO DRONE RESOURCES LLC, will ensure that the PIC has a 

significant number of flying hours and follows the instructions as set forth in the 

Manual for the UAS. Since there are no persons on board and the UAS will be 

operated within the safety procedures outlined by the FAA regulations, the 

operation of the UAS by remote control by the PIC will exceed the present level of 

safety meant to be achieved by the requirements of 14 C.F.R. §61.113 (a) and (b). 

As the FAA Administrator previously outlined in Exemption Nos. 11062 and 11067 

“[a]another consideration supporting the certificate requirement is that pilots 

holding a private pilot certificate are subject to security screening by the 

Department of Homeland Security” and this type of screening should overrule 

“security concerns over the UAS operations” that would be granted under this 

exemption. Granting the exemption based on the safety outlines and requirements 

outlined by the FAA and the experience and expertise of the PIC, would not 

adversely affect the safety of the NAS. 

4. AERO DRONE RESOURCES LLC, seeks an exemption from 14 C.F.R. §91.7(a) 

14 C.F.R. §91.7(a)-Civil aircraft airworthiness 

(a) No person may operate a civil aircraft unless it is in an airworthy condition.

AERO DRONE RESOURCES LLC, requests an exemption from the regulation, pursuant 

to petitioner obtaining of an exemption to 14 C.F.R. Part 21, there will be no 

airworthiness certificate issued for the UAS and consequently a standard for 

airworthiness is not applicable. 

Safety Standard: AERO DRONE RESOURCES LLC, compliance with an established preflight safety checklist, standard of operation as described in the Manual and outlined 

in the maintenance requirements prior to each flight ensures that an equivalent 

level of safety will be provided during all times of operation. The PIC will be in 

compliance with the requirements of 14 C.F.R. §91.7(b) when determining whether 

the aircraft is in a condition for safe flight. 

As the FAA determined in Exemption Nos. 11062 and 11067 that a requirement of 

airworthiness does not need to be met if a certificate of airworthiness is not 

required, the FAA should determine similarly in favor of AERO DRONE RESOURCES 

LLC, that if they are granted the exemption from a certificate of airworthiness, the 

provision of 14 C.F.R. §91.7(a) and (b) is not necessary. 
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5. AERO DRONE RESOURCES LLC, seeks an exemption from 14 C.F.R. §91.9(b) (2) 

14 C.F.R. §91.9(b) (2) - Civil Aircraft Manual Requirements 

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.

AERO DRONE RESOURCES LLC. seeks an exemption from maintaining a flight manual 

aboard the UAS. 

Safety Standard: Given the size and design of the UAS it is not possible to carry the 

manual onboard during operation. To ensure full compliance with safety 

requirements the Aircraft operation manual will be available at the ground station 

and immediately accessible by the PIC and FC at all times during operation. 

Petitioner would like to refer to Exemption Nos. 8607, 8737, 8738, 9299, 9299A, 

9565, 9565B, 10167, 10167A, 10602, 32827, 10700 and 11067 where the 

Administrator issued a similar exemption as requested here. In the alternative,

Petitioner requests that the Administrator finds that the exemption is not necessary 

based on the FAA Memorandum subject “Interpretation regarding whether certain 

required documents may be kept at an unmanned aircraft’s control station” dated 

August 8, 2014. 

6. AERO DRONE RESOURCES LLC, seeks an exemption from 14 C.F.R. §91.103 

14 .F.R. §91.103- Preflight Action 

Each pilot in command shall, before beginning a flight, become familiar with all 

available information concerning that flight. This information must include—

(a) For a flight under IFR or a flight not in the vicinity of an airport, weather 

reports and forecasts, fuel requirements, alternatives available if the planned 

flight cannot be completed, and any known traffic delays of which the pilot in 

command has been advised by ATC;

(b) For any flight, runway lengths at airports of intended use, and the following 

takeoff and landing distance information: 

(1) For civil aircraft for which an approved Airplane or Rotorcraft Flight Manual 

containing takeoff and landing distance data is required, the takeoff and landing 

distance data contained therein; and 
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(2) For civil aircraft other than those specified in paragraph (b)(1) of this section, 

other reliable information appropriate to the aircraft, relating to aircraft 

performance under expected values of airport elevation and runway slope, 

aircraft gross weight, and wind and temperature. 

AERO DRONE RESOURCES LLC, seeks an exemption from the Preflight Action 

requirements as prescribed in 14 C.F.R. §91.103 which requires the PIC to take 

certain actions before flights to ensure safety. 

AERO DRONE RESOURCES LLC, Safety Standards: The PIC will be familiar with all of 

the manual requirements and recommendations as well as perform an “Ops 

Checklist“ (Appendix B) a customized pre-flight check list of actions to be performed 

prior to operation of the UAS. Combined, the PIC will take actions such as inspection 

of the UAS, the weather elements, and physical inspection of the area of operation 

and aircraft performance data prior to the initiation of every single flight. A copy of 

the Operator’s Manual and Operational limitations (Appendix A) will be kept at the 

ground station within reach of the PIC at all times. The pre-flight procedures will 

allow an equivalent if not higher level of safety to be reached. The PIC will also take 

into account visibility and distance from clouds interpolating ASOS/ATIS from the 

nearest airports, local observations to estimate the ability to see other traffic when 

conducting the pre-flight inspections. 

In the alternative Petitioner requests the Administrator to find that the exemption is 

not necessary, as the FAA administrator found in Exemption Nos. 11062 and 11067, 

that with conditions and limitations the exemption is not necessary.

7. AERO DRONE RESOURCES LLC, seeks an exemption from 14 C.F.R. §91.105

14 C.F.R. §91.105 Flight crewmembers at stations.

(a) During takeoff and landing, and while en route, each required flight crewmember 

shall—

(1) Be at the crewmember station unless the absence is necessary to perform duties 

in connection with the operation of the aircraft or in connection with physiological 

needs; and...

Petitioner requests an exemption from the regulation because the UAS and other 

remotely piloted aircraft, by design, do not have “stations” with shoulder harness. 

Flight control of the UAS is accomplished by the PIC at the GCS (Ground Control 

Station) using a control box which communicates with the aircraft via radio signal 

communication.

Safety Standard: AERO DRONE RESOURCES LLC, will achieve the level of safety this rule 

intends to accomplish by having a PIC and VO at the present at control station whenever an 

operation is in progress. The mission checklist addresses this point in Appendix B 
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8. AERO DRONE RESOURCES LLC, seeks an exemption from 14 C.F.R. §91.109(a) 

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

(a) No person may operate a civil aircraft (except a manned free balloon) that is 

being used for flight instruction unless that aircraft has fully functional dual 

controls... 

Petitioner requests an exemption from the regulation because the UAS and other 

remotely piloted aircraft, by design, do not have functional dual controls. Flight 

control of the UAS is accomplished by the PIC’s use of a control box which 

communicates with the aircraft via radio signal communication.

Safety Standard: Since the UAS is not carrying a pilot or passengers the equivalent 

level of safety will be achieved with the remote control of the UAS and without dual 

controls. The PIC is in full control of the UAS at all times. Because the flight will be 

performed in a cordoned off area, any trouble that the UAS might experience will be 

rectified in a safe manner by the PIC and the FC without any interference or danger 

to the public. 

Petitioner would like to refer Exemption Nos. 11062 and 11067 where the 

Administrator found that UAS may be operated without dual controls. See also 

5778K and 9862A. 

In the alternative the Petitioner would like to request the Administrator to 

determine that the 14 C.F.R. §91.109(a) regulation is not applicable to XKYVIEW Inc, 

since AERO DRONE RESOURCES LLC, does not plan to use the UAS in an environment 

where dual controls are necessary such as instrument flight instruction and the PIC 

will be the only controller in operation of the UAS at all times.

9. AERO DRONE RESOURCES LLC, seeks an exemption from 14 C.F.R. §91.119(b) 

14 C.F.R. §91.119(b) - Minimum Safe Altitudes: General 

Except when necessary for takeoff or landing, no person may operate an aircraft 

below the following altitudes: 

(b) Over congested areas. Over any congested area of a city, town, or 

settlement, or over any open air assembly of persons, an altitude of 1,000 

feet above the highest obstacle within a horizontal radius of 2,000 feet of the 

aircraft. 

AERO DRONE RESOURCES LLC seeks an exemption from the requirement of a 

subsection (b) and relies on subsection (d) for an exemption. Subsection (d) permits 

the operation of a helicopter at less than the prescribed minimums, given that the 
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operator is in compliance with any route or altitudes prescribed for helicopters by 

the FAA. 

AERO DRONE RESOURCES LLC, requests an exemption to operate the UAS at below 

400 feet AGL. Except for the limited conditions stated in the Manual (Appendix A)

the UAS will not operate above 400 feet AGL. The equivalent level of safety will be 

achieved provided the size, weight and speed of the UAS.

Safety Standard: AERO DRONE RESOURCES LLC. operation will provide at least an 

equivalent or better level of safety at or below 400 feet AGL to those in relation to 

the minimum safe altitudes as outlined in regulation 91.119. Most civil airplanes 

operate at 500 feet AGL or above therefore the operation of the UAS by petitioner 

will not be in direct interference with manned aircraft in the NAS.

 The ground control station area of operation of the UAS will be in a cordoned 

off area with security perimeters set up by the PIC.

 All property owners and abutters who may be affected will receive advanced 

notice of the operation and the proposed flight operations as set forth in the

Manual.

 AERO DRONE RESOURCES LLC will ensure a “safe cone zone” around the area 

of PIC operation as large as is allowable in an urban setting.

 At all times anyone interested in the operation criteria of the UAS can 

contact Petitioner to obtain the necessary information. 

The UAS is equipped with an automatic system that detects “trouble” such as low 

battery or connection loss and automatically triggers the UAS to land safely back at 

its point of lift off based on the GPS coordinates of the take off. 

Compared to flight operations with aircraft or rotorcraft weighing far more than the 

UAS proposed to be used by AERO DRONE RESOURCES LLC, and lack of flammable 

fuel and a pilot or passengers on board any risk associated with these operations is 

far less as compared manned aircraft operated in accord with the minimum altitude 

requirements as outline in the regulation.

10. AERO DRONE RESOURCES LLC, seeks an exemption from 14 C.F.R. §91.121(a)

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

(a) Each person operating an aircraft shall maintain the cruising altitude or flight 

level of that aircraft, as the case may be, by reference to an altimeter that is 

set, when operating—... 
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AERO DRONE RESOURCES LLC, requests an exemption from the Altimeter Settings 

requirement because the UAS does not have a barometric altimeter, but is instead 

equipped with a GPS altitude reading device. 

Safety Standard: With an exemption from the regulation, an equivalent level of 

safety will be achieved by the operator, pursuant to the Manual and pre-flight check 

lists and by confirming the altitude of the launch site as shown on the GPS altitude 

indicator before flight. To ensure that the exemption from the regulation does not 

adversely affect safety the petitioner proposes to operate the UAS at or below 400 

feet AGL, provide altitude information to the PIC via a digitally encoded telemetric 

data feed, which downlinks from the ground-base on-screen display. Prior to each 

flight, a zero altitude initiation point will be established and confirmed for accuracy 

by the UAS PIC and the altitude information will be generated by equipment 

installed onboard the aircraft, as specified using GPS triangulation. 

Petitioner would like to refer to Exemption Nos. 11062 and 11067 where the 

Administrator found that UAS is permitted to be operated with a digitally encoded 

telemetric data feed instead of an onboard barometric altimeter. See also 

Exemption Nos. 5778K and 9862A. 

11. AERO DRONE RESOURCES LLC, seeks an exemption from 14 C.F.R. §91.151(a) (1) 

14 C.F.R. §91.151 (a) -Fuel requirements for flight in VFR conditions 

(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—

AERO DRONE RESOURCES LLC, seeks an exemption from the fuel requirement.

Petitioner believes that an equivalent level of safety can be achieved by limiting

flights to 30 minutes or 25% of battery power whichever happens first. 

This restriction would be more than adequate to return the UAV to its planned landing

zone from anywhere in its limited operating area. Similar exemptions have been

granted to other operations, including Exemptions 2689F, 5745, 10673, 10808 and

Exemptions 11062, through11067, 11080 and 11110.

11. AERO DRONE RESOURCES LLC, seeks an exemption from 14 C.F.R. §91.203(a) and 

(b) 

14 C.F.R. §91.203(a) and (b)-Civil Aircraft: Certifications Required 

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

has within it the following: 
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(1) An appropriate and current airworthiness certificate. Each U.S. 

airworthiness certificate used to comply with this subparagraph (except a 

special flight permit, a copy of the applicable operations specifications 

issued under §21.197(c) of this chapter, appropriate sections of the air 

carrier manual required by parts 121 and 135 of this chapter containing 

that portion of the operations specifications issued under §21.197(c), or 

an authorization under §91.611) must have on it the 15 registration 

number assigned to the aircraft under part 47 of this chapter. However, 

the airworthiness certificate need not have on it an assigned special 

identification number before 10 days after that number is first affixed to 

the aircraft. A revised airworthiness certificate having on it an assigned 

special identification number that has been affixed to an aircraft may 

only be obtained upon application to an FAA Flight Standards district 

office. 

(2) An effective U.S. registration certificate issued to its owner or, for 

operation within the United States, the second copy of the Aircraft 

registration Application as provided for in §47.31(c), or a registration 

certification issued under the laws of a foreign country. 

(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. 

AERO DRONE RESOURCES LLC, requests an exemption from sections (a) and (b) of 

the regulation because the Administrator grants the earlier requested exemption 

from Chapter 14 Part 21 the UAS will not be required to obtain an airworthiness 

certificate. Additionally the UAS is less than 55 lbs. when max gross and does not 

contain an onboard pilot therefore there is no ability or place to carry the 

certification and registration documents as prescribed.

Safety Standard: AERO DRONE RESOURCES LLC, proposes to achieve the equivalent 

level of safety that is premised by the regulation by keeping the necessary and 

required documents at the ground control station within immediate reach by the PIC 

at all times and will be made available to the Administrator and law enforcement 

immediately upon request. 

For similar exemptions to this regulation granted by the FAA see Exemption Nos. 

9565, 9665, 9789, 9789A, 9797, 9797A, 9816A, 10700, 11062 and 11067.

In the alternative, Petitioner requests that the Administrator finds that the 

exemption is not necessary based on the FAA Memorandum subject “Interpretation 
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regarding whether certain required documents may be kept at an unmanned 

aircraft’s control station” dated August 8, 2014.

12. AERO DRONE RESOURCES LLC, seeks an exemption from 14 C.F.R. §91.405(a), 

91.407(a) (1), 91.409(a) (2) and 91.417(a) and (b) 

14 C.F.R. §91.405(a), 91.407(a) (1), 91.409(a) (2) and 91.417(a) and (b) -

Maintenance Exceptions 

AERO DRONE RESOURCES LLC, seeks an exemption from the above outlined 

regulations governing the maintenance requirements, because these section along 

with Part 43 apply only to aircraft with an airworthiness certificate, which if the 

petition is granted by the Administrator, will not apply to the Petitioner 

Safety Standard: With the grant of the exemption, an equivalent or higher level of 

safety will be achieved during the operation of the UAS. The Petitioner will inspect 

the UAS regularly and address all mechanical issues immediately. The PIC will 

ensure that the UAS is in proper working order prior to every flight, perform 

required maintenance and keep a record log of any maintenance issues and their 

respective resolutions. In the instance that the UAS is dormant for a prolonged 

period of time, the operator will inspect the UAS bi-weekly to ensure its working 

order. All maintenance and inspections will be performed in accordance with the 

Aircraft Operator’s Manual and flights will not be conducted until the Mission 

Checklist (Appendix B) list is performed prior to each flight.
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REASONS WHY THE EXEMPTION WOULD NOT ADVERSELY 

AFFECT PUBLIC SAFETY AND HOW THE EXEMPTION 

WOULD PROVIDE A LEVEL OF SAFETY AT LEAST EQUAL TO 

THE EXISTING RULE 

Taking into consideration the safety standards outlined above granting AERO DRONE 

RESOURCES LLC, an exemption to permit commercial operation of the UAS will not 

adversely affect public safety and would provide a level of safety at least equal to the 

existing rule and in several cases provide a higher level of safety. The UAS is a battery 

operated unmanned aircraft with no flammable fuel, pilot or passengers on board and 

operated by an operator with at least a private pilot’s license. The UAS will in several 

instances replace a manned aircraft hired to perform the same task or serve as an 

alternative to using persons climbing to high elevations and eliminating the risk of 

incident of injury or fall. 

The UAS will be operated by an experienced PIC who will be in full control of the UAS at 

all times with a FC who will provide another visual and keep the UAS in a VLOS at all 

times. . PIC will have access to all necessary up to date equipment, machinery and 

mechanicals necessary for the proper and airworthy operation of the UAS. 

Furthermore, AERO DRONE RESOURCES LLC will carry liability insurance for the 

operation of the UAS in excess of $1 Million and provide the insurance certificates upon 

request. AERO DRONE RESOURCES LLC proposes to operate the UAS with the utmost 

diligence, care and responsibility as outlined in the exemptions, regulations and 

additional restrictions and guidelines as proposed by the FAA. 

With following the safety provisions as outlined in the Manual and being in strict 

compliance with FAA regulations, restrictions and conditions the operation of the UAS 

will not adversely affect public safety and the exemption will provide a level of safety at 

a level greater than the existing rule by providing alternative ways to inspect areas of 

high elevation instead of using physical man power to do so, thus preventing injuries 

and other hazards.
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OPERATIONS AT ALBANY AIRPORT

AERO DRONE RESOURCES LLC main place of business is located at the Albany Airport in 

Oregon. During training operations conducted under the supervision of an FAA certified 

Instructor (CFI) AERO DRONE RESOURCES LLC proposes to operate the UA under the 

following conditions; 

1. With a letter of agreement with that airport’s management

2. In conjunction with a NOTAM and 

3. With a Visual traffic spotter with a two way radio tuned to the airport Unicom 

frequency.

The letter of agreement with the airport management must be made available to the 

Administrator upon request.
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THE EXEMPTION IS IN THE PUBLIC INTEREST

Granting AERO DRONE RESOURCES LLC, request for a petition for the exemption from 

the regulations outlined above will further the public interest by allowing AERO DRONE 

RESOURCES LLC, to provide commercial services and thus expanding the stream of 

commerce. 

Providing such services to the public holds many benefits because these options are 

much more economical, safer than current available options, and create safe options for 

first responders to use in emergency situations. 

AERO DRONE RESOURCES LLC, proposes to use the UAS system to perform citywide, 

mandatory building and structure inspections providing a more economical and safe 

alternative than the current inspection method in place. These inspections are 

applicable to buildings as well as all apartment building parts. Currently the inspections 

are performed by a visual evaluation through a telescope on the ground or a physical 

escalation of the building itself. AERO DRONE RESOURCES LLC, will provide a service to 

inspect the buildings using the UAS operated by a licensed PIC adhering to all applicable 

FAA regulations as outlined by the Administrator as well as the recommendations set 

forth in the Manual. Use of the UAS will ensure a higher level of safety for the public 

and provide more accurate reporting including areas of the building such as overhangs 

and awnings which are not easily accessible. AERO DRONE RESOURCES LLC, will also 

provide services to Insurance Companies needing surveys.

These exemptions will also further the public interest by providing the option of having 

access to aerial photography and video in disasters areas at first responder’s request. 

The use of the UAS will provide government and private reporting agencies, real estate

and development firms as well as architects the option to use a UAS to obtain aerial 

views, replacing the use of the more costly manned aircraft. Use of the UAS is both 

more economical and safer and decreases congestion of the NAS. The use of the UAS 

versus a manned aircraft will also create a reduction in noise and air pollution, an 

increase in safety and a better economic alternative for the public. 

Finally, the public will benefit from the use of the UAS by AERO DRONE RESOURCES LLC,

because AERO DRONE RESOURCES LLC with thousands of hours of manned aviation 

experience will advocate safety throughout the community.

The enhanced safety achieved by using a UAS with a trained PIC and the added safety 

gear to be used strictly in compliance with the uses outlined above while carrying no 

passengers or crew is in the public interest to replace the use of a manned aircraft of 
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significantly greater proportions , carrying crew and flammable fuel. This use provides 

an alternative use with more accuracy and a higher level of safety

A SUMMARY TO BE PUBLISHED IN THE FEDERAL

REGISTRAR 

Applicant, AERO DRONE RESOURCES LLC seeks an exemption from the following 

regulations Part 21; 14 C.F.R. §45.23(b); 14 C.F.R. §61.113 (a) and (b); 14 C.F.R. §91.7(a); 

14 C.F.R. §91.9(b)(2);14 C.F.R. §91.103; 14 C.F.R. §91.105, 14 C.F.R. §91.109(a); 14 C.F.R. 

§91.119(b);14 C.F.R. §91.121; 14 C.F.R. §91.151(a)(1); 14 C.F.R. §91.203(a) and (b); 14 

C.F.R. §91.405(a); 14 C.F.R. §91.407(a)(1); 14 C.F.R. §91.409(a)(2); 14 C.F.R. §91.417(a) 

and (b), as established by the FAA, in order to commercially operate an unmanned aerial 

system weighing less than 55 lbs. and operating at a maximum altitude of 400 feet AGL 

for aerial imagery, research and development, training and other commercial uses 

including but not limited to building inspections. The grant of the exemption allowing 

for commercial operation will maintain an equivalent if not higher level of safety than 

the one proposed by the FAA regulations, benefit the public interest and create a 

positive impact on the stream of commerce. 

The operation of the UAS conducted with strict accord of the FAA regulations and within 

the conditions outlined above will provide an equivalent if not higher level of safety 

supporting the grant of the exemption request by AERO DRONE RESOURCES LLC, 

including the exemption from the requirements of Part 21 and allowing commercial 

operations.

NO PRIVACY ISSUES ARISE AT THE GRANT OF THE 

EXEMPTION 

If AERO DRONE RESOURCES LLC, is granted an exemption there are no privacy issues 

with regard to the operation of the UAS. Any privacy concerns, which might arise, can 

be alleviated by providing advanced notice to the possible affected persons. 

The UAS will be operated at the request of a client. At the inception of the agreement

AERO DRONE RESOURCES LLC, will provide the client a “Notice of UAS operation” at

least 3 days in advance outlining the operation which the client will need to distribute to 

foreseeable persons that might be affected. This advanced notice will permit the client 

to field any concerns that might arise ahead of time and if necessary allow possible 

affected persons to vacate the area for the time of the flight operation. 
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This type of action is no different than if a building inspection is done manually by an 

“inspector” positioning themselves on the fire escape with the same access to the 

window of a person’s apartment. 

Once the UAS is ready for takeoff, the ground station will be clearly marked with orange 

cones and a good sized sign noting the exact procedure in place and creating a chance 

for people to avoid the area if they do not wish to be caught on the film. This type of 

procedure can be equated with a movie production in a public area where people are 

notified in the same manner in order to have the option to avoid the area altogether. 

When the UAS is rising up into its flight the main focus of the camera is the building 

itself, if there are faces of persons who did not provide consent to be filmed which are 

caught in the frame, following proper protocol AERO DRONE RESOURCES LLC, will use 

specifically designated software to blur out the faces before turning the finished product 

over to the client whether it is an architect who will further use the video to generate an 

analysis report or submit it over to their respective client.

CONCLUSION 

For the reasons outlined above and with authority granted to the FAA by 14 C.F.R. 

§11.61 and Section 333 of the FAA Modernization and Reform Act of 2012, AERO DRONE 

RESOURCES LLC, requests and Exemption to commercially operate the UAS, without an 

airworthiness certificate for experimental uses. The low-risk UAS operations proposed 

by this Petitioner for Exemption fall squarely within the category of aerial data collection 

that has been subject to previous approval.

The grant of this exemption will advance the public interest, promote safety practices to 

the public and allow AERO DRONE RESOURCES LLC, to develop new and innovative uses 

for UASs in a safe and compliant manner.

GLOSSARY /ABBREVIATIONS 

UAS- Unmanned Aerial System 

UAV Unmanned Aerial Vehicle

PIC- Pilot in Command 

FC-Flight Coordinator 

VO- Visual Observer

COA- Certificate of Waiver or Authorization

FBO Fixed Based Operator
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CFI Certified Flight Instructor

GCS Ground Control Station

GPS- Global Positioning System 

VLOS- Visual Line of Sight