August 28, 2015 

U.S. Department of Transportation 

Docket Management System 

1200 New Jersey Ave., SE 

Washington, DC 20590 

RE: Exemption Request Pursuant to Section 333 of the FAA Modernization and 

Reform Act of 2012, 49 U.S.C. § 44701(f), and Par 11 of the Federal Aviation 

Regulations 

Dear Sir or Madam: 

We represent Zero Gravity Data, LLC and are submitting this Petition for Section 333 

Exemption on their behalf in accordance with Section 333 of the FAA Modernization and 

Reform Act of 2012 (“FMRA”). 

Applicant Information:

The name(s) of the applicant: Zero Gravity Data, LLC 

The primary contact for this application, which a copy to me at the address above, is: 

 Dennis L. Wiand 

 Zero Gravity Data, LLC 

 2209 Pine Street 

 Bloomfield Hills, MI 48301 

Zero Gravity Data, LLC is a limited liability company formed under the State laws of Michigan 

on or about August 24, 2015, and Dennis L. Wiand is the Managing Member of Zero Gravity 

Data, LLC. 

Pursuant to Section 333 of the FMRA, Zero Gravity Data, LLC hereby requests a determination 

by the Secretary of Transportation authorizing commercial operations of UAS for the purposes 

Photography, Videography and Data Collection in the NAS. Flight operations will utilize the off 

the shelf DJI Phantom 2 V2.0 and DJI Inspire 1 V 2.0 families of unmanned aircraft. Conduct of 

UA operations will be with respect to FMRA Section 333(c) and the UAS “Blanket COA”. 

Exemption is necessary to effect the determination requested pursuant to FMRA Section 333. 

The attached documentation includes detailed exemption requests that demonstrate how these 

exemptions are in the public interest and will maintain at least an equal level of safety to existing 

regulations. Authorizing Zero Gravity Data, LLC to conduct commercial UAS operations will 
August 28, 2015 

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result in less disruptive, safer, and more cost effective solutions than manned aviation 

equivalents due to the low altitude environment, given the size, speed and inherent risk of 

traditional commercial helicopter operations. These commercial operations often occur in the 

unsafe areas of the height-velocity diagram requiring special precision and skill. Zero Gravity 

Data, LLC will conduct the commercial UAS operation in a manner that will meet, and in many 

cases exceed, the current level of safety of commercial helicopter operations. UA that are under 

10 lbs., have a low noise signature, and carry no volatile fuel, will limit collateral damage in the 

event of catastrophic failure. The low expense of operation compared to cost prohibitive manned 

aviation alternatives allow a greater economic benefit to businesses. For these reasons, granting 

an exemption under FMRA Section 333(c) is in the public interest. UAS technology used for 

these commercial purposes benefit the public interest in the following ways: 

 Reduces the collateral damage risks to life and property associated with low altitude 

helicopter operations in undesirable portions of the height-velocity envelope. 

 Increased economic wellbeing to local businesses via cost reductions. 

 Enabling aerial business solutions to be available to a larger market. 
August 28, 2015 

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Table of Contents 

I. Exemptions Requested 

II. Commercial Operation/Operator 

III. Unmanned Aircraft System (UAS) 

IV. UAS Pilot-in-Command (PIC) 

V. Public Interest 

VI. Summary 

VII. List of Attachments 

I. Exemptions Requested 

Pursuant to 14 C.F.R. § 11.81(e), Zero Gravity Data, LLC requests exemption from the 

following regulations: 

 14 C.F.R. Part 21 Subpart H – Airworthiness Certificates 

o Establishes: The procedural requirements for the issuance of airworthiness 

certificates as required by 14 C.F.R. § 91.203(a)(1) 

Given the small size of the UA and the safeguards that will be taken as outline below, an 

exemption from Part 21 Subpart H meets the requirements of an equivalent level of safety 

under Part 11 and Section 333 of the FMRA with consideration “of the size, weight, 

speed, operational capability, and proximity to airports and populated areas of the 

particular UAS.” 

 14 C.F.R. § 45.23(b) – Aircraft Marking and Identification Requirements

o 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. 

Zero Gravity Data, LLC will ensure compliance with § 45.29(f) to meet the intent of the 

regulation by displaying the registration number in the largest practicable lettering. 

 14 C.F.R. 61.113 (a)(b) and 61.133(a)(1)(ii) and 61.101 – Recreational, Private and 

Commercial Pilot Privilege and Limitations

o 14 C.F.R. § 61.113: (a) Except as provided in paragraphs (b) through (g) 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 
August 28, 2015 

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o 14 C.F.R. § 61.133: (a) Privileges – (1) General. A person who holds a 

commercial pilot certificate may act as pilot in command of an aircraft – (ii) For 

compensation or hire, provided the person is qualified in accordance with this part 

and with the applicable parts of this chapter that apply to the operation. 

o 14 C.F.R. § 61.101: (a) A person who holds a recreational pilot certificate may 

not act as pilot in command of an aircraft: 

 For compensation or hire; 

 In furtherance of a business; 

UA operations will employ a PIC who holds, at a minimum, a recreational or sport pilot 

certificate of any category or class and a valid driver’s license. 

 14 C.F.R. 91.7(a) – Civil Aircraft Airworthiness

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

Daily pre and post flight inspections in accordance with manufactures maintenance 

manual(s) and guidance will be conducted. During flight, the PIC will adhere to § 91.7(b) 

and abort air operations immediately upon identification of an in-flight emergency or 

other unsafe condition. By complying with procedures outlined by the manufacturer, an 

equivalent level of safety will be achieved. 

 14 C.F.R. 91.9(b) Civil aircraft flight manual, marking, and placard requirements

o (b)(2) prohibits operation of U.S.-registered civil aircraft 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. 

By keeping all operating documents, manuals, authorizations and exemptions in a binder 

co-located with the GCS, [company name] meet the intent of the regulations and 

therefore achieve an equivalent level of safety. 

 14 C.F.R. 91.109(a) – Flight Instruction 

o 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.

The majority of sUAS by design are developed with single operational control through 

the use of pre-determined GPS enabled waypoints programmed before or during flight in 

addition to the use of a single hand held transmitter or control station controlled by the 

PIC. The design does not allow for dual controls during flight training and therefore the 

exemption is requested to train operators, build experience, and maintain proficiency. An 

equal level of safety will be achieved by conducting all training in stile environment. 

Training sessions will be accomplished separately from flights conducted for 

compensation or hire. 
August 28, 2015 

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 14 C.F.R. 91.119 (c) – Minimum Safe Altitudes 

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

below the following altitudes: (b) 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. 

(c) Over other than congested areas. An altitude of 500 feet above the surface, 

except over open water or sparsely populated areas. In those cases, the aircraft 

may not be operated closer than 500 feet to any person, vessel, vehicle, or 

structure. (d) Helicopters, powered parachutes, and weight-shift-control aircraft. If 

the operation is conducted without hazard to persons or property on the surface— 

(1) A helicopter may be operated at less than the minimums prescribed in 

paragraph (b) or (c) of this section, provided each person operating the helicopter 

complies with any routes or altitudes specifically prescribed for helicopters by the 

FAA.

Commercial UAS operations will be conducted at or below the maximum altitude 

authorized by COA. Given the size, weight and lack of fuel; combined with operation 

limitations listed below, the operation will be conducted with a greater level of safety 

than exists with current manned aviation operations. 

 14 C.F.R. 91.121 – Altimeter Settings

o 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... 

SUAS are equipped with Global Positioning System (GPS), which provide altitude and 

geo-location data to the operator without utilizing an altimeter. Due to this fact, an 

exemption is required. GPS are precise within a few feet and combined with fail-safes 

and a visual observer the operation will meet an equivalent level of safety. 

 14 C.F.R. 91.151(a) – Fuel Requirements for Flight in VFR Conditions 

o 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;

This regulation is written based on the capabilities of a traditional aircraft, which have 

flight times of several hours or greater; therefore, with the majority of sUAS which have 

flight times of only an hour or less, this regulation would effectively deny the ability of 

the air vehicle to operate. 

The PIC will achieve an equivalent level of safety by complying with all manufacturer 

guidelines and the DJI low battery failsafe system. 

 14 C.F.R. 91.405(a), 91.407(a)(1), 91.409(a)(2) and 91.417(a) & (b) – Maintenance 

Inspections 
August 28, 2015 

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o 91.405(a) States: Each owner or operator of an aircraft—(a) 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

o 91.407(a)(1) States: (a) No person may operate any aircraft that has undergone 

maintenance, preventive maintenance, rebuilding, or alteration unless—(1) It has 

been approved for return to service by a person authorized under § 43.7 of this 

chapter

o 91.409(a)(2) States: (a) Except as provided in paragraph (c) of this section, no 

person may operate an aircraft unless, within the preceding 12 calendar months, it 

has had—(2) An inspection for the issuance of an airworthiness certificate in 

accordance with part 21 of this chapter. No inspection performed under paragraph 

(b) of this section may be substituted for any inspection required by this 

paragraph unless it is performed by a person authorized to perform annual 

inspections and is entered as an ‘‘annual’’ inspection in the required maintenance 

records.

o 91.417(a) & (b) States: (a) Except for work performed in accordance with §§ 

91.411 and 91.413, each registered owner or operator shall keep the following 

records for the periods specified in paragraph (b) of this section: (paragraphs 1 (i 

– iii), 2 (i – vi)); (b) The owner or operator shall retain the following records for 

the periods prescribed: (paragraphs 1 – 3)

Pre/Post flight inspections and maintenance will be conducted in accordance with the 

manufacturer’s guidance as stated in the operations manual. If maintenance is required, a 

dedicated test flight will be conducted to ensure safety before resuming commercial 

operations. All inspection, maintenance and alterations will be documented and 

maintained in a record. These actions will meet the intent of the regulations from which 

exemption is being requested and lead to an equivalent level of safety. 

II. Commercial Operator/Operation 

Any UA flown under this exemption will be controlled by a certificated PIC. The PIC will hold, 

at a minimum, a recreational or sport pilot certificate. 

For each flight, Zero Gravity Data, LLC: 

 Will contact the controlling air traffic organization to issue a NOTAM. 

 Will conduct a comprehensive worksite inspection and analysis, identifying limits of 

customer property or authorized access areas. 

 Will conduct preflight planning in accordance with Section 91.103 Preflight Action.

 Will operate in those areas only with the consent of the landowner or designated 

representative. 

 Will identify potential obstructions or other hazards to safe operation. 

 Will clear the area of personnel or bystanders that are non-essential to the operation, 

maintaining at a minimum, 500 feet away from non-participating persons. 
August 28, 2015 

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 Will conduct a preflight safety briefing to Visual Observer (VO) and participating 

persons. 

 Will at all times yield to manned air traffic. 

 Will operate within VLOS of both PIC and VO during daylight hours only.

 Will maintain voice communications with VO and participating persons.

 Will operate under visual flight rules, in visual meteorological conditions, for the airspace 

in which the flight is conducted.

 Will not exceed the maximum altitude as defined in the COA under which flight 

authorized, as determined by the installed GPS.

 Will keep operating documents, manuals, authorizations and exemptions in a binder colocated with the GCS.

 Will immediately terminate flight, in the safest manner possible, when safety to persons 

or property become compromised. 

 Will terminate flight, in the safest manner possible, when unable to comply with these 

limitations or any other limitations granted as part of this exemption.

In order to remain at an altitude at or below the attitude prescribed by the applicable COA, relief 

is needed from Section 91.119 (c) and (d). By following these operating standards, the 

commercial operation will meet an equivalent level of safety to the regulation in which relief is 

sought. 

III. Unmanned Aircraft System 

Zero Gravity Data, LLC seeks exemption to operate DJI Phantom 2 V2.0 and DJI Inspire 1 V2.0 

UAS. Other UAS types may be requested in future amendments. The DJI Phantom 2 V2.0 and 

DJI Inspire 1 V2.0 are the primary aircraft in our operation for which we seek exemption The 

UA will be flown via a combination of RC control and tablet GCS. Both UA types are GPS 

equipped, multirotor helicopters. Quad-copter type rotorcraft utilizing four motors. Lithiumpolymer batteries power the UA. 

The UA also has several fail-safes for loss of RC signal, loss of GPS, and low battery as outlined 

in the respective Operation Manuals. The UA display visual and emit an audible low battery 

alerts at which time the UA will automatically engage the landing sequence. Based upon those 

safeguards, I request exemption from Section 91.151(b) Fuel requirements for flight in VFR 

conditions. 

Given the size, weight, speed, and controlled operating area associated with the UA to be 

utilized, an exemption from 14 CFR part 21, Subpart H (Airworthiness Certificates) and § 

91.203 (a) and (b) is requested. Exemption is sought from § 45.23 Marking of the aircraft. The 

UA will display the registration number in the largest practicable lettering. Zero Gravity Data, 

LLC seeks to be exempt from § 91.405(a), 91.407(a)(1), 91.409(a)(2) and 91.417(a) and (b) 

Maintenance inspections will be conducted according to operations manual and prudent 

judgment as previously outlined to determine the integrity and safety of the UA and associated 

equipment. Further, relief is required from 91.7(a), which prohibits the operation of an aircraft 

without an airworthiness certificate and 91.9(b) (2) requiring an approved flight manual in the 
August 28, 2015 

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aircraft. The UA will not be operating with an airworthiness certificate therefore, this would be 

inappropriate. The UAS are too small to carry the operating documents so an equivalent amount 

of safety can be achieved through keeping the operating documents and manuals at the GCS. 

IV. UAS Pilot in Command (PIC) 

Under part § 61, recreational, sport and private pilots are limited to non-commercial operations, 

however Zero Gravity Data, LLC can ensure UA operations will achieve an equivalent level of 

safety as current regulation because UA do not carry any pilots or passengers. A commercial 

pilot certificate will not ensure RC piloting ability, as the psychomotor skills are different. The 

inherent risks of operating a UAS are far less than in the commercial activities outlined in 14 

CFR part 61, et seq., thus exemption is requested from § 61.101 Recreational Pilot Privileges 

and Limitations. PICs will maintain recent flight experience on the UAS. Training and 

experience flights will be conducted separate from commercial operations. 

V. Public Interest 

Given the above stated evidence, procedures, and precautions operating UAS commercially for 

the purposes of Photography, Videography, Data Collection will ultimately be in the public 

interest. These operations, when executed with prudence, will exceed the current level of safety 

as the regulations from which exemption is sought. UA operations will allow greater access to 

commercial aerial services that were not previously economically feasible for many firms. This 

will provide a much needed economic uplift to the community and hence the public. UA 

operations are associated with less risk of collateral damage to persons and property while 

limiting disruptive noise pollution associated with low altitude aviation operations. 

VI. Summary 

Pursuant to Section 333 of PL 112-95 commonly known as the “FAA Modernization and Reform 

Act of 2012”, Zero Gravity Data, LLC, hereby applies for authorization to conduct commercial 

unmanned aerial systems (UAS) operations for the purposes of Photography, Videography, Data 

Collection Rules for which exemption is sought: 

 14 C.F.R. Part 21 Subpart H 

 14 C.F.R. § 45.23(b) 

 14 C.F.R. § 61.101, 61.113 and 61.133(a)(1)(ii) 

 14 C.F.R. § 91.7(a) 

 14 C.F.R. 91.9(b) 

 14 C.F.R. § 91.103 

 14 C.F.R. § 91.109(a) 

 14 C.F.R. § 91.119 

 14 C.F.R. § 91.121 

 14 C.F.R. § 91.151(a) 

 14 C.F.R. § 91.405(a) 
August 28, 2015 

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 14 C.F.R. § 91.407(a)(1) 

 14 C.F.R. § 91.409(a)(2) 

 14 C.F.R. § 91.417(a) & (b) 

VII. Attachments: 

1. Specific UAV manuals. 

a. DJI Inspire 1 Propeller Locks Quick Start Guide 

b. DJI Inspire 1 Quick Release Propellers Quick Start Guide 

c. DJI Inspire 1 Disclaimer and Warning 

d. DJI Inspire 1 How to Upgrade Firmware 

e. DJI Inspire 1 In the Box 

f. DJI Inspire 1 Maintenance Manual – Version 1.0 

g. DJI Inspire 1 Safety Guidelines 

h. DJI Inspire 1 Release Notes 

i. DJI Phantom 2 Vision Plus Pilot Training Guide – Version 1.1 

2. UAV user manual 

a. DJI Phantom 2 User Manual – Version 1.4 

b. DJI Inspire 1 User Manual – Version 1.4 

3. Battery Manuals 

a. DJI V1.0 Smart Flight Battery Safety Guidelines 

b. DJI Inspire 1 Intelligent Flight Battery Safety Guidelines 

4. Quick Start guides. 

a. DJI Phantom 2 Quick Start Guide 

b. DJI Inspire 1 Quick Start Guide 

5. NAZA – GPS Manuals 

a. DJI NAZA-M Quick Start Guide 

Thanks you for your prompt attention and consideration. Traverse Legal and its clients are 

committed to safe UAS operation and ambassadors. Please do not hesitate to contact me 

directly with any questions or concerns at 866-936-7447. 

 Very truly yours, 

 Traverse Legal, PLC

 

 Enrico Schaefer 

 Attorney at Law 

 www.dronelaw.pro 

 enrico@traverselegal.com 

ES/cam 

Enclosures