U.S.	Department	of	Transportation

Docket	Operations

West	Building	Ground	Floor	Room	W12-140

1200	New	Jersey	Avenue	SE

Washington,	D.C.	20590

Re:		Exemption	petition	to	operate	various	UAS	systems	for	commercial	purposes.

Dear	Sir	or	Madam,

Pursuant	to	Section	333	of	the	FAA	Modernization	and	Reform	Act	and	14	sections	

11.61-11.103,	Control	1	Communications,	LLC	hereby	petitions	for	an	exemption	

allowing	commercial	aerial	videography	and	photography	using	small	Unmanned	

Aerial	Systems	(UAS).		Control	1	Communications	requests	exemptions	from	several

Federal Aviation	Regulations	(F.A.R.s)	as	detailed	in	Section	2	of	the	following	text.		

An	exemption	would	allow	Control	1	Communications,	LLC	to	utilize	this	new	

technology	to	further	it’s	ability	to	bring	creative	and	innovative	photographs	and	

video	to	the	public.		Specifically,	an	exemption	would	allow	Control	1	

Communications,	LLC	to	survey,	record	and	broadcast	aerial	footage	for	it’s	clients.		

Control	1	Communications,	LLC	proposes	to	utilize	2	types	of	UAS	systems	(DJI	

Inspire	1	and	DJI	Spreading	Wings	1000+)	for	aerial	video	and	photography	work	of	

real	estate	properties	around	the	suburban	Charlotte,	NC	and	surrounding	areas.				

All	proposed	operations	of	UAS	vehicles	will	be	within	both	the	manufacturer’s	

prescribed	recommendations	for	the	specific	UAS	model	and	any	additional	

restrictions	or	regulations	set	forth	by	the	FAA.			Additionally,	all	Pilot(s)	in	

Command	(PICs)	shall	hold	as	a	minimum	a	sport	pilot	class	(or	higher)	license	and	

either	a	current	third	class FAA medical	certificate	or	a	valid	US	driver’s	license (if	in	

possession	of	a	Sport	Pilot’s	License).		All	PICs	will	also	have	as	a	minimum	25	hours	

of	UAS	flight	time	and	a	minimum	of	10	hours’	flight	time	with	the	type	UAS	to	be	

used	commercially.		Additionally,	all	flights	will	be	conducted	during	daylight	times.		

The	PIC	shall	maintain	visual	line	of	sight	(LOS)	with	the	UAS	at	all	times.				The	PIC	

will	work	in	tandem	with	an	Observer	to	facilitate	safe	operation	of	the	UAS.		The	

PIC	and	Observer	will	have	voice	communication	by	way	of 2	way	hands	free radio	

link	at	all	times	the	UAS	is	in	flight.			No	flights	will	be	conducted	over	crowds	of	

people,	or	over	private	property	without	the	appropriate	permission	from	the	

properties’	owners	or	agents.		Flights	will	not	exceed	400’	altitude	AGL,	nor	50	knots

in	speed.				The	aircraft’s	battery	status	shall	be	monitored	while	in	flight	via	

telemetry	from	the	aircraft	to	the	controller	to	ensure	the	battery charge	is	adequate	

to	allow	safe	recovery	and	landing	of	the	UAS.		The	UAS	will	not	be	operated	at	less	

than	25%	battery	capacity.						 Control	1	Communications,	LLC	requests	exemptions	

for	the	following	aircraft:		DJI	Inspire	1, and	DJI	Spreading	Wings	1000+.		

Section	1:		Contact	information:
Control	1	Communications,	LLC

Attention:	Christopher	Kelley

3525	Centre	Circle

Fort	Mill,	SC	29715

chris@control1comm.com

Section	2:		Sections	from	which	exemptions	are	requested:

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).		Control	1	

Communications,	LLC	requests	an	exemption	from	this	regulation	on	the	basis	that:	

A;	the	UAS	cannot	present	a	danger	to	it’s	pilot	or	passengers	as	it	carries	no	living	

things	onboard	and	B;	the	small	mass	(under	55lbs	gross	takeoff	weight)	and	the	

fact	that	it	carries	no	flammable	fuel	renders	it	a	far	lesser	danger	to	ground	based	

personnel	or	objects	in	the	event	of	an	in-air	system	failure than	that	of	a	larger	

manned	aircraft.		Control	1	Communications	LLC	believes	this	will	give	an	

equivalent	level	of	safety	to that	of	a	larger	manned	aircraft’s	regulation	under	this	

part.	

14	C.F.R.	§	45.23 (b).	Marking	of	the	Aircraft

The	regulation	states:

(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	letters	not	less	than	2	inches	nor	

more

than	6	inches	high,	the	words	"limited,"	"restricted,"	"light-sport,"	"experimental,"	or

"provisional,"	as	applicable.”

The	UAS	in	question	have	no	cabin,	therefore	no	location	to	display	the	prescribed	

signage,	therefore	an	exemption is	requested.		The	word	“EXPERIMENTAL”	will	be	

displayed	on	the	UAS’s	fuselage	utilizing	letter	as	large	as	practicable.		This	gives	an	

equivalent	level	of	saftey	in	that	the	Pilot	and	others	working	with	the	UAS	will	

clearly	see	the	marking.			The	FAA	has	issued	the	following	exemptions	to	this	

regulation	to	Exemptions	Nos.	10700,	8738,	10167	and	10167A.
14	C.F.R.	§	45.29		(3)		Size	of	Marks

The	regulation	states:	

“Rotorcraft,	must	be	at	least	12	inches	high,	except	that	rotorcraft	displaying	before	

April	18,	1983,	marks	required	by §45.29(b)(3)	in	effect	on	April	17,	1983,	and	

rotorcraft	manufactured	on	or	after	April	18,	1983,	but	before	December	31,	1983,	

may	display	those	marks	until	the	aircraft	is	repainted	or	the	marks	are	repainted,	

restored,	or	changed.”

Due	to	the	small	size	of	the	UAS,	it	will	not	be	possible	to	mark	the	aircraft	using	

letters	of	the	size	prescribed	within	this	regulation.		Therefore	an	exemption	is	

requested.		The	equivalent	level	of	safety	will	provided	by	marking	the	UAS’s	

registration	(“N”	number)	utilizing	letting	as	large	as	practicable	for	the	UAS.		This	

will	provide	a	clear	and	immediate	method	of	identifying	the	UAS’s	registration	in	

keeping	with	the	intent	of	this	regulation.		

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

Section	61	establishes	the	certification	requirements	for	pilots.		Section	61.113	

states	“§	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.	

An	exemption	is	requested	to	allow	a	PIC	licensed	holding	a	Sport	Pilot	License	or	

higher,	along	with	the	prescribed	Medical	Certificate	appropriate	to	that	license’s	

requirement	(or	valid	U.S.	issued	Driver’s	License,	in	the	case	of	a	Sport	Pilot	

License),	to	operate	the	UAS	in	commercial	activity.		The	equivalent	level	of	safety	

will	be	provided	in	that	the	UAS	carries	no	living	thing,	property	for	hire	(transport),	

and	has	a	mass	less	than	55lbs.			In	this	the	safety	factor	is	greater	than	utilizing	a	

manned	aircraft	in	the	same	capacity.		

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

The	regulation	states:

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

As	there	is	no	certificate	of	airworthiness	issued	for	the	UAS	in	question,	an	

exemption	is	requested	from	this	regulation	insofar	as	the	regulation	requires	a	

“certificate	of	airworthiness”.		Should	this	petition	be	granted,	currently	no	

airworthiness	certification	exists	for	the	UAS	in	question,	thereby	obtaining	an	

airworthiness	certificate	is	not	currently	possible.		An	equivalent	level	of	safety	will	
be	achieved	by	compliance	with	section	91.7	(b),	preflight	checks,	and	compliance	

with	the	manufacturer’s	recommended	maintenance	practices.	

§91.9 (b)	(2) Civil	aircraft	flight	manual,	marking,	and	placard	requirements.

The	regulation	states:		

“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.”

An	exemption	is	requested	with	regard	to	this	regulation.		Due	to	the	small	size	of	

the	UAS	and	the	fact	that	it	has	no	cabin	and	carries	no	pilot	or	passenger(s),	there	is	

neither	the	carrying	capacity	nor	place	for	such	Flight	Manual.		An	equivalent	level	

of	safety	will	be	provided	by	maintaining	the	Flight	Manual	for	the	UAS	at	the	

control	location	so	that	the	PIC	has	immediate	access	to	it.	

14	C.F.R.	§	91.103		Preflight	action

The	regulation	states:

“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

(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.	“

As	FAA	approves	flight	manuals	do	not	exist	for	the	UAS	in	question,	an	exemption	is	

requested	from	section	91.103	(b)	(1).		The	equivalent	level	of	safety	shall	be	

provided	by	utilizing	the	manufacturer’s	recommendations	regarding	preflight	

checks	for	the	UAS,	as	well	as	the	regulations	set	forth	in	section	91.103	(a).		

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

Section	91.103	regulates	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.

As	the	UAS	is operated	by	a	single	remote	radio	frequency	controller,	dual	controls	

are	not available.		Thereby	an	exemption	from	this	portion	of	the	regulation	

requiring	dual	flight	controls	for	the	purpose	of	flight	instruction	is	requested.		An	

equivalent	level	of	safety	is	provided	in	that	the	UAS	carries	no	people	and	has	a	

relatively	small	mass	and	operates	at	a	low	speed	compared	to	manned	aircraft.		In	

addition	the	UAS	has	a	GPS	based	“return	to	home/	auto	land”	failsafe	system	in	the	

event	of	loss	of	the	controller’s	RF	signal.		

14	C.F.R.	§91.119		Minimum	safe	altitudes

The	regulation	states:	

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

below	the	following	altitudes:

(a)	Anywhere. An	altitude	allowing,	if	a	power	unit	fails,	an	emergency	landing	

without	undue	hazard	to	persons	or	property	on	the	surface.	

(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.	

(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;	and	

(2)	A	powered	parachute	or	weight-shift-control	aircraft	may	be	operated	at	less	

than	the	minimums	prescribed	in	paragraph	(c)	of	this	section.	

An	exemption	is	requested	from	this	regulation,	given	that	all	UAS	operations	will	

take	place	at	an	altitude	of	no	more	than	400’	above	ground	level.		The	equivalent	

level	of	safety	provided	here	lies	in	that	keeping	the	UAS	at	less	than	400’	AGL	is	

needed	for the	PIC	to	maintain	visual	line of	sight	with	the	aircraft,	and	aids	in	

keeping	the	UAS	separated	from	manned	aircraft.	

14	C.F.R.	§91.121		Altimeter	Settings

As	section	91.121	was	written	in	reference	to	an	aircraft	fitted	with	a	barometric	

altimeter,	and	given	that	the	UAS	utilizes	a GPS	based	altimeter,	an	exemption	may	

be	needed.		If	so,	the	equivalent	level	of	safety	will	be	provided	by	“zeroing”	the	

UAS’s	altimeter	to	reflect	a	zero	value	at	the	point	of	take	off.		This	will	ensure	the	

PIC	has	the	ability	to	monitor	his/her craft’s altitude in	flight and	thereby	ensure	the	

craft	is	flown	at	an	altitude	of	less	than	400’	AGL.		Furthermore,	software	within	the	

UAS’s	flight	controls may	be	enabled	to	“software limit”	the	UAS’s	operational	ceiling	

at	a	value	less	than	400’	AGL.

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

The	regulation	states:

“No	person	may	begin	a	flight	in	a	rotorcraft	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,	to	fly	after	that	

for	at	least	20	minutes.”

An	exemption	is	requested	to	accommodate	the	fact	that	the	average	flight	time	

provided	by	the	UAS’s	battery	system	is	less	than	20	minutes.		An	equivalent	level	of	

safety	will	be	provided	by	conducting	flight	operations	in	such	a	manner	as	to	

maintain	a	minimum	of	5	minutes’	flying	time	or	landing	with	no	less	than	25%	

battery	capacity	remaining,	whichever	is	greater.		Given	that	the	UAS	carries	no	

living	thing	onboard,	is	of	relatively	small	mass	compared	to	a	manned	aircraft,	and	

shall	always	remain	within	visual	sight	of	the	PIC,	this	will	provide	an	adequately	

safe	time	and	battery	capacity	to	safely	land	the	aircraft.	
14	C.F.R.	§91.203	(a)	and	(b)		Carrying	Civil	Aircraft	Certification	and	Registration

The	regulation	states:

“(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.	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	

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.

An	exemption	to	section	91.203	(a)	is	requested	due	to	the	fact	that	airworthiness	

certificates	are	not	issued	to	the	UAS	in	question.		An	equivalent	level of	safety	will	

be	provided	by	conducting	maintenance	as	per	the	manufacturer’s	

recommendations	and	schedule.		A	copy	of	these	maintenance	records	will	be	kept	

in	the	PIC’s	possession	during	flight	operations.		

An	exemption	to	91.203	(b)	is	requested	in	that there	is	no	cabin	within	the	UAS	to	

display	an	airworthiness	certificate,	nor	does	it	carry	any	pilots	or	passengers	to	

view	them.		An	equivalent	level	of	safety	will	be	provided	by	keeping	applicable	

documents	related	to	the	UAS’s	maintenance	history	in	the	possession	of	the	PIC.		

14	C.F.R.	§91	sub	part	E			Maintenance,	Preventive	Maintenance,	and	Alterations

An	exemption	is	requested	related	to	the	portions	of	section	91	sub	part	E	that	

requires	maintenance	to	be	performed	by	a	certified	mechanic	or	at	a	certified	

airframe	repair	station.		Maintenance	will	be	performed	by	the	PIC,	or	others	

familiar	and	experienced	with	the	type	UAS	to	be	maintained.			Moreover	an	

exemption	is	requested	for	portions	of	this	regulation	regarding	maintenance	that	

may	affect	the	aircraft’s	“airworthiness	certificate”.		Given	the	UAS	will	not	be	issued	
an	airworthiness	certificate,	portions	of	this	regulation	will	not	apply.		Control	1	

Communications,	LLC	will	maintain	the	UAS	in	accordance	with	the	manufacturer’s	

recommendations	and	keep	records	accordingly.		This,	and	the	fact	that	the	UAS	is	

unmanned,	lightweight,	operates	as	a	low	altitude,	and	capable	of	landing	in	a	small	

area	should	an	emergency	arise,	will	provide	an	equivalent	level	of	safety.		

Section	3:		Public	Interest	Considerations:

Control	1	Communications	believes	the	public’s	interests	will	be	served	by	granting	

our	request	in	part	by:

1) Increased	safety	to	those	in	the	vicinity	of	the	UAS’	operation when	

compared	to	manned	aircraft	videography:		Conventional	aerial	

film/videography	utilizes	manned	aircraft	weighing	thousands	of	pounds.		

Recent	advances	in	videography	equipment	now	allow similar	film	and	

videography	using	smaller	cameras	that	can	be	mounted	on	UAS.		These	

smaller	UAS	provide	a	much	safer	environment	for	not	only	the	ground	

personnel	and	property,	but	also	negates	the	possibility	of	a	pilot	or	other	

onboard	crew	member	(such	as	a	camera	operator)	being	harmed	in	an	

accident.		While	injury	or	property	damage	arising	from	a	UAS	accident	is	an	

important	consideration,	it	is	often	safer to	use	these	smaller	systems	when	

possible	rather	than	a	larger	manned	aircraft.	

2) Environmental	concerns:		When	used	in	the	place	of	manned	aircraft	to	

provide	aerial	photography/	videography,	the	UAS	provides	similar	pictures	

while	maintaining	a	much	smaller	carbon	footprint.		The	UAS	is	battery	

powered,	thereby	releasing	no	pollutants	into	the	air.		Even	the	batteries	the	

UAS	systems	utilize	are	considerably	smaller	than	batteries	found	onboard	

manned	aircraft.		In	the	event	of	a	crash,	no	petroleum	fuels	will	be	released.	

The	risk	of	a	crash-related	fire	is	greatly	reduced.			Finally,	noise	pollution	

from	a	UAS	system	in	significantly	lower	than	that	of	a	manned	helicopter.		

Section	4:		Attachments

Submitted	along	with	this	petition	are	attached	files	from	both	Control	1	

Communications,	LLC	and	the	manufacturer	detailing	safe	operation	and	

maintenance procedures for	each	of	the	UAS	types	for	which	permission	to	operate	

commercially	is	requested.		

Section	5:		Summary for	the	Federal	Register:		
Pursuant	to	Section	333	of	the	FAA	Modernization	and	Reform	Act	and	14	sections	

11.61-11.103,	Control	1	Communications,	LLC	hereby	petitions	for	an	exemption	

allowing	commercial	aerial	videography	and	photography	using	small	Unmanned	

Aerial	Systems	(UAS).		Control	1	Communications	requests	exemptions	from	several	

Federal	Aviation	Regulations	(F.A.R.s)	as	detailed	in	Section	2	of	the	following	text.		

An	exemption	would	allow	Control	1	Communications,	LLC	to	utilize	this	new	

technology	to	further	it’s	ability	to	bring	creative	and	innovative	photographs	and	

video	to	the	public.		Specifically,	an	exemption	would	allow	Control	1	

Communications,	LLC	to	survey,	record	and	broadcast	aerial	footage	for	it’s	clients.		

Control	1	Communications,	LLC	proposes	to	utilize	2	types	of	UAS	systems	(DJI	

Inspire	1	and	DJI	Spreading	Wings	1000+)	for	aerial	video	and	photography	work	of	

real	estate	properties	around	the	suburban	Charlotte,	NC	and	surrounding	areas.				

All	proposed	operations	of	UAS	vehicles	will	be	within	both	the	manufacturer’s	

prescribed	recommendations	for	the	specific	UAS	model	and	any	additional	

restrictions	or	regulations	set	forth	by	the	FAA.			Additionally,	all	Pilot(s)	in	

Command	(PICs)	shall	hold	as	a	minimum	a	sport	pilot	class	(or	higher) license	and	

either	a	current	third	class	FAA	medical	certificate	or	a	valid	US	driver’s	license (if	in	

possession	of	a	Sport	Pilot’s	License).		All	PICs	will	also	have	as	a	minimum	25	hours	

of	UAS	flight	time	and	a	minimum	of	10	hours’	flight	time	with	the	type	UAS	to	be	

used	commercially.		Additionally,	all	flights	will	be	conducted	during	daylight	times.		

The	PIC	shall	maintain	visual	line	of	sight	(LOS)	with	the	UAS	at	all	times.				The	PIC	

will	work	in	tandem	with	an	Observer	to	facilitate	safe	operation	of	the	UAS.		The	

PIC	and	Observer	will	have	voice	communication	by	way	of 2	way	hands	free radio	

link	at	all	times	the	UAS	is	in	flight.			No	flights	will	be	conducted	over	crowds	of	

people,	or	over	private	property	without	the	appropriate	permission	from	the	

properties’	owners	or	agents.		Flights	will	not	exceed	400’	altitude	AGL,	nor	50	knots	

in	speed.				The	aircraft’s	battery	status	shall	be	monitored	while	in	flight	via	

telemetry	from	the	aircraft	to	the	controller	to	ensure	the	battery charge	is	adequate	

to	allow	safe	recovery	and	landing	of	the	UAS.		The	UAS	will	not	be	operated	at	less	

than	25%	battery	capacity.							Control	1	Communications,	LLC	requests	exemptions	

for	the	following	aircraft:		DJI	Inspire	1, and	DJI	Spreading	Wings	1000+.		

Control	1	Communications,	LLC	requests	exemptions	from	the	following	

regulations:			

-14	C.F.R.	Part	21,	Subpart	H:	Airworthiness	Certificates	14	C.F.R.	§91.203	(a)	(1)

Requirement	of	airworthiness	certificate.

-14	C.F.R.	§	45.23	(b).	Marking	of	the	Aircraft

Requirement	for	aircraft’s	cabin	to	be	marked.

-14	C.F.R.	§	45.29		(3)		Size	of	Marks

UAS	too	small	to	comply	with	letter/	number	size	requirement.
-14	C.F.R.	§	61.113:	Private	Pilot	Privileges	and	Limitations:	Pilot	in	Command

Request	to	allow	non-commercial	pilot	license	holder	conduct	for-profit	UAS	

operations.

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

Request	exemption	as	no	current	airworthiness	certificates	for	UAS	exist.

- §91.9	(b)	(2) Civil	aircraft	flight	manual,	marking,	and	placard	requirements.

UAS	unable	to	carry	an	onboard	flight	manual.

-14	C.F.R.	§	91.103		Preflight	action

UAS	unable	to	carry	a	pre-flight	manual.

-14	C.F.R.	§91.109		Flight	instruction

request	exemption	from	dual-control	mandate	for	the	UAS.

-14	C.F.R.	§91.119		Minimum	safe	altitudes

Request	that	UAS	be	authorized	to	operate	under	minimum	safe	altitude	regulations.

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

UAS	use	a	GPS	altimeter	rather	than	a	barometric	altimeter.

-14	C.F.R.	§	91.151(b)		Fuel	Requirements	for	Flight	in	VFR	Conditions

Request	exemption	to	allow	UAS	to	be	operated	with	less	than	20	minutes’	fuel	reserve.

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

Request	an	exemption	due	to	the	fact	that	an	airworthiness	certificate	will	not	be	

issued	for	the	UAS,	nor	is	there	a	cabin	in	which	to	display	it.

- 14	C.F.R.	§91	sub	part	E			Maintenance,	Preventive	Maintenance,	and	Alterations

Request	an	exemption	from	requiring	a	certified	mechanic/	certified	airframe	shop	to	

perform	maintenance	in	UAS.
Sincerely,	

Christopher	Kelley- managing	member

Control	1	Communications,	LLC