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	Regulations	listed	below,	to	allow	commercial	operation	of	its small	unmanned	aerial	vehicles	(i.e.	

“small	unmanned	aircraft”	or	“sUAS”)

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	safety	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	address	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

TheApplicant hereby requests	exemption from the following FARs:

• 14 C.F.R. 21, subpart H

• 14 C.F.R. 61.3

• 14	C.F.R. 61.113(a) & (b)

DronePro LLC

6606 FM 1488 Ste. 148-151

Magnolia, TX 77354

832-492-7146

joeypjohnston@dronepro1.com

Revised document from the submitted form dated

July 15, 2015.

Revisions include name change from Nexus Quality

to DronePro LLC and revised list of UAV’s.
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• 14	C.F.R. 61.133(a)

• 14	C.F.R. 91.9(b)	(2)

• 14	C.F.R. 91.103(b)

• 14	C.F.R. 91.105

• 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. 91.203(a) &	(b)

• 14	C.F.R. 91.319(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,	lens,	and	gimbal).	They	

operate	at	speeds	of	no	more	than	50	knots,	can	hover,	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	that	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	commercial	operations	using	the	Sensefly	Exom,	

DJI	Inspire	1,	Freefly	Systems	Alta and	the	Precisionhawk	Lancaster	 for	mapping,	inspection	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	conducted	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	(VLOS).

• 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	restricted	to	400	feet.

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

• Operator	will	file	a	NOTAM	for	each	flight.

• All	required	permissions	and	permits	will	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 surrounding	

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 functional	

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	safety	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	system	

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	that	operator	requirements	should	take	into	

account	the	characteristics	of	the	particular sUAS.	The	platforms	have a	high	degree	of	preprogrammed 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 have an	all digital software	platform	with	advanced	features	previously	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.
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• Plan	your	flight	or	fly	ad-hoc: The	system	can	autonomously	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	associated	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	rotorcraft),	that	allowing	operations	of	

the	sUAS	as	set	forth	above	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	requires	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	initiation	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	repaired	as	prescribed	in	part	43	of	this	chapter...,”	and	others	shall	inspect	or	maintain	the	aircraft	in	

compliance	with	Part	43.	Given	that	these	sections	and	Part	43	apply	only	to	aircraft	with	an	airworthiness	certificate,	

these	sections	will	not	apply	to	DronePro 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.
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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	reducing	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, approval	of	the	exemption	allowing	commercial	operations	for	surveying,	mapping and	inspection	

operations	will	enhance	safety	by	reducing	risk.	Conventional	aerial	survey	and inspection	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	DronePro 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	that	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	

follows:

• FlightWink	LLC

• Aeryon	Labs

• GSC	Surveying	Inc

• Pro	Drones	Canada

• Soar	Environmental	Consulting
Page	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