NOVEMBER	13,	2015

U.S.	Department	of	Transportation
Federal	Aviation	Administration Document	Management	System 1200	New	Jersey	Ave.,	SE Washington,	D.C.	20590

Dear Sir	or Madam

,

Pursuant to	Section	333	of	the	FAA	Modernization	and	Reform	Act	of	2012,	Pub.	L.	No.	112

- 95,	126	Stat.11	(amending 49	U.S.C.)	(Hereinafter,	the	“Reform	Act”)	and	14	C.F.R.	Part	11, DRONEPRO LLC
, hereby seeks	an	exemption	from	the
Federal	Aviation	Re gulations	listed	below,	to	allow	commercial	operation	of	its small	unmanned	aerial	vehicles	(i.e.
“small	unmanned	aircraft”	or	“ s UAS”)

DRONEPRO ,	LLC's	requested	exemption	would	permit	the operation	of	sUAS	under	controlled	and	secure	conditions that	is:	(i )	limited, (ii)	predetermined,	(iii)	subject	to	controlled	access,	and	(iv)	provide	greater safety	in	connection with	aircraft	operations.	As	established	by	the exemptions	already	granted	by	the	FAA,	approval	of DRONEPRO
, LLC's exemption	would	enhance	safe ty	and	fulfill	the	Secretary	of Transportation’s	(the	FAA	Administrator’s) responsibilities	to	“...establish requirements	for	the	safe	operation	of	such	aircraft	systems	in	the	national airspace system.”	Section	333(c)	of	the	Reform	Act.

The	name	and	addr ess	of	the	applicant	is:

DRONEPRO LLC Joey	Johnston

Phone: 832

- 492

- 7146

Email: joeypjohnston@dronepro1.com

Address: 6606	FM	1488	Suite	148

- 151	Magnolia,	TX	77354

The Applicant hereby requests	exemption from the following FARs:



### • 14 C.F.R. 21, subpart H



### • 14 C.F.R. 61.3



### • 1 4 C

. F

. R

. 6 1

. 1 13 ( a ) & ( b ) D r o n e P r o L L C
6 6 0 6 F M 1 4 8 8 S t e

. 1 4 8

- 1 5 1
M a g n o l i a , T X 7 7 3 5 4
8 3 2

- 4 9 2

- 7 1 4 6 j o e y p j o h n s t o n @ d r o n e p r o 1

. c o m

R e v i s e d d o c u m e n t f r o m t h e s u b m i t t e d f o r m d a t e d J u l y 1 5

, 2 0 1 5

.

R e v i s i o n s i n c l u d e n a m e c h a n g e f r o m N e x u s Q u a l i t y
t o D r o n e P r o L L C a n d r e v i s e d l i s t o f U A V ’ s

.Page 2 

### • 1 4 C

. F

. R

. 6 1

. 13 3 ( a)



### • 1 4 C

. F

. R

. 9 1

. 9 ( b )	( 2 )



### • 1 4 C

. F

. R

. 9 1

. 10 3 ( b)



### • 1 4 C

. F

. R

. 9 1

. 105



### • 1 4 C

. F

. R

. 9 1

. 10 9 ( a)



### • 1 4 C

. F

. R

. 9 1

. 1 19



### • 1 4 C

. F

. R

. 9 1

. 121



### • 1 4 C

. F

. R

. 9 1

. 15 1 ( a)



### • 1 4 C

. F

. R

. 9 1

. 20 3 ( a ) &	( b )



### • 1 4 C

. F

. R

. 9 1

. 31 9 ( a )	( 1 )



### • 14 CFR 91,	Subpart E (91.405,	91.407, 91.409,	91.417)

sUAS operated	by DronePro
, LLC	weigh	less	than	25 pounds, including	the	payload	(i.e.	camera,	len s,	and	gimbal).	They
operate	at speeds	of	no	more	than	50	knots,	can	hov er,	and	can	simultaneously	move vertically	and	horizontally. DronePro, LLC	will	only	operate	its sUASs	in	line	of	sight	and	will	operate	only	within	the	secure area	described in	the FOPM.	Such	operations	will	insure	t hat	the	sUAS	will	“not	create	a hazard to	users	of	the	national	airspace	system	or the	public.”

The	requested	exemption	would	authorize DronePro LLC to	conduct	comm ercial	operations	using	the Sensefly Exom
, DJI Inspire	1
, Freefly	Systems	Alta and	the	Precisionhawk	Lancaster for	mapping,	inspe ction	and	photography	of landfills,	mining	facilities,	utilities,	oil	&	gas	facilities,	agriculture,	construction	sites,	engineering	assessments,

insurance damage	assessments ,	real	estate	marketing	and	events	such	concerts,	sports,	etc. Specifications	for all	sUAS
are	attached	to	this	document.
sUAS	Operating Parameters

Grant	of	the	exemption	to DronePro will	be	subject	to	the	following	mandatory	conditions,	which	are based	upon	operating	conditions	set	forth	for	operation	of	sUAS by	public	entities	pursuant	to Certificates	of	Authorization,	with	additional	restrictions:

• All	operations	to	occur	in	Class	G	airspace.

• Operations	to	avoid	congested	or	populated	areas,	which	are	depicted	in	yellow	on	VFR	charts.

• Operations	to	be	conduc ted	over	private	or	controlled access property.

• Permission	from	land	owner/controller	required	before	commencing	any	flight.

• Operations	to	occur	during	Visual	Flight	Rules	Meteorological	Conditions	(VMC).

• Aircraft	to	remain	within	Visual	Line	of	Sight	(VLO S).

• VLOS	guaranteed	with	a	cylinder	of	operation	around	operator	of	1⁄2	nautical	miles	(NM).

• Cylinder	walls	may	be	expanded	by	observer	with	ability	to	control	aircraft.

• Operations	to	occur	during	daylight	hours.

• Above	Ground	Level	(AGL)	altitude	to	be	restr icted	to	400	feet.

• All	operations	conducted	in	vicinity	of	airport	to	remain	more	than	2.5	NM	from	centerline azimuth	of	runwayPage 3 centerline	measured	from	runway	thresholds.

• Operator	will	file	a	NOTAM	for	each	flight.

• All	required	permissions	and	permits	wil l	be	obtained	from	territorial,	state,	county	or	city jurisdictions,	including local	law	enforcement,	fire,	or	other	appropriate	governmental	agencies.

• All	operations	will	include	one	pilot	for	flight	control	and	one	observer	for	VLOS	enhancement	of surrou nding area	near	the	aircraft

Operator	Requirements :

DronePro	LLC respectfully	proposes	that	operator	requirements	should	take	into	account	the	characteristics of	the particular	sUAS.	Certain	sUASs,	such	as	the those	chosen	to	be	used	by	DronePro	LLC ,	are characterized	by	a	high degree	of	preprogrammed control	and	various	built in technical	capabilities	that	limit	the	potential	for operation outside	of	the	operating	conditions	set	forth	above.	The chosen sUAS platforms also	provides many	built in functiona l and	safety	features	to	assist	the	operator	in	safe	and	reliable	operation.

All	flight	operations	are GPS	controlled	making	the	system	easy	to	navigate,	and	the	flight	control	system	also	employs

a variety	of	sensors	including	sonar,	barometric	pressure, temperature,	wind	speed	and	others	to	ensure the	high stability	and	reliability	in	challenging	weather	conditions.	At	all	times	during	flight	operations, the	operator	can intervene	a	programmed	flight	and	take	immediate	control.

Additional	automated	safe ty	functions	and	safety	enhancing	features	of	the platforms include	the following:

• Automated	preflight system	performance	checks

• User	preflight checklist

• Automated	condition	or	fault	detection,	warnings,	and	predefined responses	to	a	number	of flight	and	s ystem conditions.

• High	winds	with	system	and	user	defined	safety	thresholds

• Low	battery	with	system	and	user	defined	safety	thresholds

• High	temperature	or	other	system	safety	thresholds

• Lost

- link communication

• Predefined responses	include	behavior	such	as attempting	to	reestablish radio communication,	return	to	home position	and	hover,	return	to	home	position	and	land,	or	land	in current	position

• In	the	case	of	lost	GPS,	a	manual	user	flight	mode	is	enabled	which	allows	the	operator	to provide	manual navigation	inputs	to	assist	in	landing	the	vehicle.

14	C.F.R.	§	61.113(a)	&	(b) ; 61.133(a):	Private	Pilot	Privileges	and	Limitations ; Pilot	in Command ; Commercial	Pilot Privileges	and	Limitations.

Section	61.113(a)	&	(b)	limit	private	pilots	to noncommercial operations.	Unlike	a	conventional	aircraft that	carries	a	pilot,	passengers,	and	cargo,	the sUAS in	this	case	is	remotely	controlled	with	no passengers	or	property of	others	on	board.	Section	61.133(a)	requires	an	individual	with	a	commercial pilot’s	license	to	be	pilot	in	command of	an	aircraft	for	compensation	or	hire. DronePro respectfully proposes	th at	operator	requirements	should take	into account	the	characteristics	of	the	particular sUAS. The	platforms	have a	high	degree	of	preprogramme d control	and various	built in technical capabilities	that	strictly	limit	the	potential	for	operation	outside	of	the	operating	conditions set	forth	in	the exemption	application.

The platforms ha ve an	all digital software	platform	with	advanced	features	pr eviously	restricted	to	full size	unmanned	aircraft.	Automated	features	and	advanced	fly safe controls	enable	safe,	reliable operation,	as	well	as	advanced	networking	capabilities	and	system	extensibility.Page 4 • Plan	your	flight	or	fly	ad

- hoc: The	system	can	auto nomously	fly	a	programmed	flight	path	or	fly in	manual	mode

• Smart	batteries	and	charger:	Flight	time	and	battery	minutes	are	displayed	at	all	times.	The system	will	return	home	and	land	automatically	if	user configurable limits	are	reached.

Flight	safety is	a	priority,	no	matter	the	operating	environment	or	project.	The platforms	offer superior	safety	over	manned	aircraft	by	removing	the	need	for	people	to	be	onboard	in	potentially dangerous	situations.

• Intelligent	fault	handling:	The	system	automatically detects	potential	issues	with configurable automated response	behavior	such	as	a	return home and land routine

• Automatic	preflight checks:	The	system	self calibrates all	of	its	sensors	and	performs self tests prior	to	takeoff	to check	for	errors

• No fly zones:	The	system	has	the	ability	to	set	up	visual	no fly zones

• Self monitoring: Monitoring	battery	levels,	inflight wind	speeds,	and	other	system	and environmental	conditions are	automatically	handled	by	the	system

• Battery	communication:	Battery	minutes and	flight	time	are	displayed	at	all	times.	The	system will	return	home and	land	automatically	if	user	configurable limits	are	reached.

The	risks	assoc iated	with	the	operation	of	these	platforms (given	its	size,	speed,	operational capabilities,	and	lack	of combustible	fuel)	are	so	diminished	from	the	level	of	risk	associated	with private	pilot	operations	or	commercial operations	contemplated	by	Part	61	with	conventional	aircraft (fixed	wing	or	rotorcraf t),	that	allowing	operations	of the	sUAS	as	set	forth	a bove	meets	or	exceeds	the present	level	of	safety	provided	under	14	C.F.R.	§ 61.113(a)	&	(b)	and does	not	rise	to	the	level	of requiring	a	commercial	pilot	to	operate	the	aircraft	under	§	61.133(a).

Pre

- Flight	action	14	C.F.R §	91.103

This	regulation	req uires	each	pilot	in	command	to	take	certain	actions	before	flight	to	insure	the	safety of	flight. The	PIC	will	take	all	actions	including	reviewing weather,	flight	battery	requirements,	landing	and	takeoff distances	and	aircraft	performance	data before	in itiation	of	flight.

Maintenance	and	Inspections	for	sUAS: 14	C.F.R.	§91.405	(a);	407	(a)	(1);	409	(a)	(2);	417(a)	&	(b): These	regulations	require	that	an	aircraft	operator	or	owner	shall	“have	that	aircraft	inspected	as	prescribed	in subpart	E	of	this	part	and	shall	between	required	inspections,	except	as	provided	in	paragraph	(c)	of	this	section,	have discrepancies	repaire d	as	prescribed	in	part	43	of	this	chapter...,”	and	others	shall	inspect	or	maintain	the	aircraft	in compliance	with	Part	43.	Given	that	these	sections	and	Part	43	apply	only	to	aircraft	with	an	airworthiness	certificate, these	sections	will	not	apply	to D ronePro LLC.	Maintenance	will	be	accomplished	by	the	operator.	An	equivalent	level of	safety	will	be	achieved	because	the	sUASs	are	limited	in	size,	will	carry	a	small	payload	and	operate	only	in restricted	areas	for	limited	periods	of	time.	If	mechanical issues	arise,	the	sUAS	can	land	immediately	and	will	be operating	from	no	higher	than	400	feet	AGL.	As	provided	in	the	FOPM,	the	operator	will	ensure	that	the	sUAS	is	in working	order	prior	to	flight,	perform	any	required	maintenance,	and	keep	a	log	of	any maintenance	performed. Moreover,	the	operator	is	the	person	most	familiar	with	the	sUAS	and	best	suited	to	maintain	it	in	an	airworthy condition. Operations	after	maintenance	will	have	the	sUAS	fly	at	an	altitude	of	no	more	than	4	feet	from	the	ground	in a	marked	off	area	to	ensure	the	maintenance	of	the	sUAS	was	done	properly	prior	to	doing	another	flight.	Maintenance records	shall	be	kept	on	file	for	at	least	5	years.Page 5 FEDERAL	REGISTER	SUMMARY

Pursuant	to	14	C.F.R.	Part	11,	the	following	summary	is provided	for	publication	in	the Federal	Register,	should	it	be determined	that	publication	is	necessary:

Nexus	Quality	LLC seeks	an	exemption	from	the	following	rules:

14	CRF	Part	21,	Subpart	H;	14	CFR	Part27;	14	CFR	45.23(b);	14	CFR	§	61.113;	14	CFR

91.7( 1);	14	CFR	91.9(b)(2);	14	CFR	91.103;	14	CFR	91.109(a);	14	CFR	91.119;	14	CFR	91.121;

14	CFR	91.151(a);	14	CFR	91.203(a)	&	(b);	14	CFR	91.405(a);	14	CFR	91.407(a)(1);	14	CFR

91.409(a)(2);	14	CFR	91.417	(a)	&	(b).

This	exemption	will	enhance	the	safety	by	r educing	risk	to	the	general	public	and property	owners	from	the	hazards associated	with	performing	the	same	work	with	conventional rotorcraft	and	aircraft.

Conclusion

In	summary, a pproval	of	the	exemption	allowing	commercial	operations	for	surveying,	mappi ng and	inspection operations	will	enhance	safety	by	reducing	risk.	Conventional	aerial	survey	and ins pection	operations	using	manned aircraft	involve	very	heavy	aerial	vehicles	carrying	significant quantities	of	combustible	fuels,	and	a	multiperson crew in piloting	and	observation	roles.	These operations	require	transit	to	and	from	the	location	of	the	activity,	and	often take	place	in	congested environments	including	proximity	to	physical	obstacles	and/or	presence	of	the	general	public. By contrast, the	Dro nePro platforms	weigh	no	more	than	25 lbs.	including	payloads	and	uses	a	battery	for	power,	is carried to/from	the	area	of	activity,	removes	the	need	for	airborne	pilots/observers,	and	poses	less	risk	to people	and infrastructure	on	the	ground.

Additionally,	no	national	security	issue	is	raised	by	the	grant	of	the	requested	exemptions.	Given	the size,	load	carrying capacity,	speed	at	which	it	operates,	and	the	fact	that	it	carries	no	explosives	or other	dangerous	materials,	the DronePro	platforms poses	no	threat	to	national	security.

DronePro	owners	have an extensive	background	in	both	safety	and	quality	with the	owners oil	and	gas	backgrounds working	for	large	corporations	such	a	ExxonMobil	and	Shell	Oil. The	same	focus	on	safety	and	quality	th at	are	used	by these	large	oil	and	gas	companies	will	be	transferred	into	DronePro’s service

. In	addition	DronePro	will	also	have	a quality	management	system	that	follows	the	requirements	of	ISO	9001	2015	to	ensure	that	quality	is	place	in	every aspect	of our	business	at	all	times.

In	closing	the	exemption	being	requested	has	previously	been	granted	to	other	companies	that	will	be	performing	the same	scope	of	work	as DronePro LLC	will	be	performing.	The	companies	that	have	been	granted	exemptions	are	as
fo llows:

• FlightWink	LLC

• Aeryon	Labs

• GSC	Surveying	Inc

• Pro	Drones	Canada

• Soar	Environmental	ConsultingPage 6 • Stark	Aerospace

• Nixon	Engineering	Solutions	LLC

• Sky	Futures	UAS

• Droneview	LLC

• Precisionhawk

Warm	regards,

Joey	Johnston

MANAGING	PARTNER

DRONEPRO LLC

Attachments:

DJI	Inspire	1	Manual

DJI	S1000	Manual

Aerialtronics	Altura	Zenith	Manual

Precisionhawk	Lancaster	Manual

DronePro LLC	Quality	Manual