Mr. Donald Panarisi 

South Georgia Drone Training and Services 

92 Lake Cove Approach 

Newnan GA, 30265 

December 20, 2015 

U. S. Department of Transportation Docket 

Management System 

1200 New Jersey Ave., SE 

Washington DC 20590 

' . ~ 

Re: FOR A SUMMARY GRANT EXEMPTION SEEKING RELIEF FROM THE 

REQUIREMENTS OF TITLE 14 OF THE CODE OF FEDERAL REGULATIONS PART 21, 

SUBPART HAND SECTIONS, 45.23(b), 61.23(a) and (c), 61.101(e)(4) and (5), 61.113(a), 

61.315(a), 91.7(a), 91.9(b)(2), 91.103, 91.119(c), 91.121,91.203 (a) and (b), 91.151(a)(1), 

91.405(a), 91.407(a)(1 ), 91.409(a)(1) and (a)(2) AND 91.417(a) and (b) CONCERNING 

COMMERCIAL OPERATION OF ALL DJI PHANTOM 2 AND PHANTOM 3 MODELS, DJI 

S1 000, DJI S900, AND DJI INSPIRE 1 UNMANNED AIRCRAFT SYSTEMS PURSUANT TO 

SECTION 333 OF THE FAA MODERNIZATION AND REFORM ACT OF 2012 (PUBLIC LAW 

11295) 

1. SUMMARY 

Dear Sir or Madam: 

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the "Reform Act") 

and 14 C.F.R. Part 11, South Georgia Drone Training and Services an operator of Unmanned 

Aircraft Systems ("UASs") for aerial data collection and flight training, hereby applies for an 

exemption from the Federal Aviation Regulations ("FARs") to allow commercial operation of its 

UASs. 

South Georgia Drone Training and Services request, as described in greater detail below, the 

requested exemption would permit the operation of a sUAS at or below 400 feet AGL, under 

controlled conditions in airspace that (1) is limited; (2) is predetermined; (3) is controlled as to 

access; and (4) provides safe operations. No operations will be conducted over restricted 

airspace or over congested areas. Approval of this exemption would enhance safety, promote 

industry growth and fair competition through increased affordability of aerial photography and 

videography, and would fulfill the Secretary of Transportation's responsibilities to establish 

requirements for the safe operation of such aircraft systems in the NAS pursuant to Section 333 

of FMRA. 

2. INTRODUCTION 

The name and address of the applicant is: 

South Georgia Drone Training and Services 

Mr. Donald Panarisi 

92 Lake Cove Approach 

Newnan GA, 30265 

dapanarisi@yahoo.com 
(901 )853-6566 

South Georgia Drone Training and Services objective,is to collectaeria.Ldata,and flight. 

demonstrations by conducting aerial ,photography and videograph¥ in o.r:der to provide high, 

quality digital imaging and video:content to its clients, and to, promote the safe use of s,UAS's by, 

being an educatocon the subject. More speoifically,.the purpose of this exemption wqulcl b,eto ·, 

allow South Georgia, Drone Training ,and Services to provide commercial aerial video and -- , 

photography operations in the following afeas: Aerial photographx and videographyforth~ 

advertising industry, Aerial photography and videography of re_sidential/commercial buildings for 

the real estate industry, Aerial photography and videography for industrial/construction sites, 

Aerial photography and videography for the agricultural and farming industry, and flight -.: 

demonstrations to new users. Increase public knowledge of sUAS and promote safe sUAS 

operations 

This exemption application is expressly submitted to,fulfill Congress' goal in ~assing Section 

333(a) through (c) of tiJe,Reform_Act. , . 

This law directs the Secretary of Transportation to consider whether certain unmanned ·aircraft . 

systems may operate safely in the national airspace system (NAS) before completion of the 

rulemaking required under Section 332 of the-Reform Act In making this determination; the 

Secretary is required to determine which types otUASs do: n.otcreate a hazard to users.of the . 

NAS or the public or pose a threat to national security in light of the following: 

The UAS's size, weight, speed, and operational capability; Operation of the UAS in close 

proximity to airports and populated areas; and; Operation of the .IJAS witlilin visual line· of sight of 

the operator.- The Federal Aviation Act expressly grants the FAA the authority to issue 

exemptions. This statutory authority by its terms includes exempting civil aircraft, as· the term iS: 

defined under §401 01 of the Act, that includes sUASs, from the requirement that all civil aircraft 

must have. a current airworthiness certificate, : , · e.,, 

UASs operated by South Georgia Drone Training and Services weigh less than 55 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. South Georgia 

Drone Training and Services will only operate its UASs.in .. lineofsightand will operate only.· 

within the sterile area. Such operations will insure that the UAS will "not create a hazard to 

users of the national airspace system· or the .pubHc.~· 

South Georgia Drone Training and Services seeks an exemption to operate the DJI Phantom 2, 

DJI Phantom 2 Visiont, and all Phantom3 models, The DJI S1000, S900 an!:}DJIInspire 1 .· 

model UAS for compensation or hire within the NAS. 

Each UAS operated by South Georgia Drone Training and Services will be registered in 

accordance with 49 U.S.C. 44103, Registration of Aircraft, as well as 14 C.F.R Part 47, Aircraft 

Registration, and markedjn accordance with l4·C.F.R. Part 45, Identification and Registration 

Marking. 

3. BASIS· FOR PETITION 

Given the small size of South Georgia Drone Training and Services 'UASs and the restricted 

sterile environment within which they will operate, South Georgia Drone Training and Services 

UAS operations adhere to the Reform Act's safety requirements. Additionally, due to the size of 
the UASs and the limited areas in which they will operate, approval of this application presents 

no national security issues. Each of South Georgia Drone Training and Services sUASs, 

including payload,· is fartbelow~the: 55 pound sU'AS classification ·requirement; and one is also 

below tti:e 4A pound requirementdeyeloped·by-.the proposed 14 C.F.R. Part 107 that creates 

the "mi'crotJAS'~:subclass -<Df·s:UAS. Based.nn-the sub'stantiallevel of safety surrounding the 

proposed-operations;· and <the ~ignificant public benefit (enhanced safety), reduction in 

environmenta1 impacts (reduced emissions and·'noise ), the grant of the requested exemption is 

in the public'interest . .According,ly,-South Georgia-Drone Training and Services respectfully 

requests'that the FAA grant :the re(luested::exemption without delay.· 

Aircraft and equ~ivalent tevet of safetY .. .- .. -: . ..'( ,., "" ' 

The applicant proposes that the exemption requested apply to civil aircraft that have the 

characteristics and that operate with the limitations listed. These limitations provide for at least 

an equivalent or even higher tevet of~ safety to operations under the current regulatory structure 

because the proposed operations represent a safety enhancement to the already safe aerial 

photography and aerial filming for movie and television filming operations conducted with 

conventional aircraft. ',, ,, ' · ... ' "· ' '' ' . ,, . ,,.... ',_. 

These limitati<l>ns andconditions to· which Sowth Georgia Drone· Training and Services·agrees to 

be bound when conducting commercial operations under an FAA issued exemption indude: : ~-

The sUAS will weigh less than 55 lbs. 

·" .! ~--~ .... ·t;\ ~ ·,-t, .1.-';: 

Flights will be operated within line ofsight .. of a:·pilot and/or observer. • ·:· 1 /:. . -~ :~:,r:J ~ 't. Q -~·~ ··;-~ , ·; 

Maximum total flighttirne for ea~h:operational flight will be.30'minutes:: ..... •' 

~~' ' ~ ·: ; . j ' 

Flights will be terminated at 25% battery power reserve·· should that occur prior to·the 30 minute 

limit. 

Flights will be operated at an altitude ofn6 more·than 400 feet AGL· 

Minimum crew for each operation will corisist of the sUAS Pilot, the Visual Observer. 

'·:; l'' 

sUAS pilot will be an FAA licensed airman with at·!east a private pilot's certificate and third class 

medical. 

'' '' The sUAS Pilot assume all duties and responsibilities asPilot in Command (PIC). 

A briefing will be conducted in regard to the planned sUAS operations prior to each day's 

production activities. 

It will be mandatory that all personnel who will be performing duties within the boundaries of the 

safety perimeter be present for this briefing. 

The operator will obtain the consent of all persons involved in the mission and ensure that only 

consenting persons will be allowed within 100 feet of the flight operation, and this radius may be 
reduced to 30 feet based upon an equivalent level of. safety determination. With the advanced · 

permission of-the relevant FSDO, operations at closer range can.be approved. 

The operator will submit a written Plan of Activities to the FSDO three days before the pr9posed 

shoot. ' -... 

Pilot and observer will have been trained in operatiorr of UAS. generally and received Up to date. 

information on the particular UAS to be operated. 

ALL crew members will at all times be able to communicate by ONLY voice communications as ·· 

to ensure all crew members maintain a visual contact with the UAS at ALL TIME. . · · · 

' .. 

Written and/or oral permission from the relevant property holders will be obtained. 

All required permissions and permits will be obtained from territorial, state, county or city 

jurisdictions, including local law enforcement, fire, or other appropriate governmental agenci.es. ~ 

If the sUAS loses communications or loses its GPS signal, the UAS,wilt have capability to returri 

to a predetermined location within the Security Perimeter and land. 

The sUAS will have the capability to abort a flight in case of unpredicted obstacles or 

emergencies. 

The Plan of Activities 

The Plan of Activities must include the following: 

Dates and times for all flights; · '<~.--·:'-.:' •' • : .,..· 

,:.::·· 

Name and phone number of the person responsible for the photography I filming event; ·-· .. ' i. f., 

Name and phone number of the person··responsible'for the. aircraft; 

Make, model and serial number and/or registration number of all UAS t to be used; ~ .. -. 

Name and certificate number, if applicable; .of all,crewmembers. to be utili.zed in the·event 

including copies of FAA Medical Certificates and endorsements; 

A statement that the Waiver Holder has obtained permission from property owners and/or local 

governmental officials to conduct the event; 

Signature of Waiver Holder or representative; 

A description of the flight activity including maps or diagrams of any area, city, town, county, 

and/or State over which filming will be conducted and the minimum altitudes essential to. 

accomplish the operation. 

Briefing 
South Georgia Drone Training and Services and the event representative will conduct a verbal 

and written briefing for the members involved, including emergency; if applicable, and security 

personnel. This briefing will be conducted prior to each day's UAS activities and will include the 

following.items,' -": · :. ·.·. · ... ,, .. t".:. ·_;,_ 

Authorization UAS flight operations, Plan of Activities, special provisions and any additional 

provisions issued by the,Fiighl:Standards District Office having jurisdiction over the photo I 

filming area. 

Radio communications:· 

Takeoff procedures. 

Aviation activities to be conducted during the event. 

Approach and landing: procedt:1res. 

Alternate landing zone in the event of emergency or security breach 

Recall procedures. -:; 

Emergency procedures. 

Possible risk to personnel that are involved. 

Control of n<Dnparticipatir'lg persons, 

Location of boundaries or deadlines, manmade or natural, readily visible to the participants. 

Local governmental limitations, restrictions, or any special circumstances, such as noise 

sensitive areas, time of day restrictions or changes in operating procedures. 

Security 

The exclusion from the flight operations area of unauthorized persons, vehicles or aircraft will be 

enforced by designated event personnel, private security officers or sworn law enforcement 

officers at the direction of South Georgia Drone Training and Services. 

t '' • 

·.·"':• 

South Georgia Drone Training and Services or their designated representative will halt flight 

operations in the event unauthorized·persons,' vehicles or aircraft enter the flight: operations 

area. 

A predetermined abort signal will be used to halt flight operations should a breach of perimeter 

security occur;"-or for any other reason··in the interestofsafety .. 

Alternate UAS landing sites will be made available prior to the start of the event. 

Regulations from which the exemption is requested: 

14 CFR Part 21 

14 CFR 45.23(b) 

14 CFR61.113 (a) and (b) 

14 CFR 91.7 (a) 

14 CFR 91.9 (b) (2) 

14 CFR 91.103 

14 CFR 91.109 

14 CFR 91.119 

14 CFR 91.121 

·;,,. ';:· 
14 CFR 91.151 (a) 

14 CFR 91.203 {a) and (b) 

14 CFR 91.405 (a) 

14 CFR 407 (a) (1) 

14 CFR 409 (a) (2) 

14 CFR 417 (a) and (b) 

.. , ' ·- \.~. 

.. 

3. EXTENT OF RELIEF AND REASONS SOUTH GEORGIA DRONE TRAINING and 

SERVICES SEE~~ REI.-IEF . 

) , .. 

14 C.F.R Part 21, Subpart H:· Airworthin~ss C.ertificates 14 C.F.R. §91:203 (a) (1). ·· 

.. ~ - .. ~ 

Subpart H, entitled Airworth_iness Certificates, establishes the procedural requirements for·the 

issuance of airwpr,thiness certificates 9l5 required by fA~ §91.203 (a) (1}. G_iven the size and r 

limited operating area associated with the aircraft to be utilized by the Applicant, an exemption. 

from Part 21 Su.bpart H meets the requirement~ of an equivalent level of safety underPart t1 

and Section 3~3 of the Reform Act. The Federal Avjatiqn Act (49 U.S.C.§44701 (f)) aDd Section 

333 of the Reform Aqt both al!thorize the FAA to exempt airGr:aft frornthe requirement for ~n . 

airworthineps certiticate, upcm,consideration .. ofJhe·size, weight, speed, oper.:ati.onal capability, •. 

and proximity to airports and populated areas ofthe particular UAS. ~n all cases, a(l.analysis of · 

these criteria demonstrates that the UAS operated without an airworthiness certificate, in the 

restricted environment and under the conditions proposecJwi!l be aHeast:as safe;· or safer,tban 

a conventional aircraft (fixed wing ,or rotorcraft),PP.Elf?tif:lg with an airworthiness certificat~, 

without the res~[ictions af1d conditio11s propo_s~d. TI:Je s~JAS to be pperated -hereuncter is less 

than 55 lbs. fully loaded, carries neither a piJot-no~ passenger; carries no explosive materials orr. 

flammable liquid fu~ls, anq OP;?rates exclusively within a secL~red ar;ea as $et out ·in the Manual.· 

Unlike other civiL aircraft, operations:~nder ttl.i$ exE!mption will be)ightly controlled and . 

monitored by both the operator, pur~uant to the Manuars requirements; ·and unQl3r-·the · .. 

requirements and in compliance with local_public &afe_ty r~q!Jirem~nts; to provide security for the 

area of operation as is now done with conventiona!filming.1The FAA wil.l have advance notice 

of all operations. These safety enhancements, wh.ich already apply to civil airc;;raft operated in 

connection with motion picture and television produGtion, provide a greater degree of safety to 

the public and property owners than conventional .qperc;itiom; conducted with e3irworthiness 

certificates issued under 14 C. F. R,~ Part 2 t, S.ubpart 1-L .Lastly, application of these same criteria 

demonstrates that there is no credible threat to nationalsecurity posed by the UAS, due to its 

size, speed of operation, location ofoperation,,Jaokof·explosive materials or flammable liquid. 

fuels, and inability to carry a substantial external load. 

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

The regulation requires: 

' ' 

''·· ... ,., 

When marks include only the Roman capitallett?r~'N" and the registration number is displayed· 

on limited, restricted or lightsport category <,:!jq:;mftor 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 tha.D-2 inches .oor more than 6 inches high, the words "limited," 

"restricted," "lightsport," "e,xperimental," or "provisional," as applicabl~. 

Even though the UAS will have no airworthiness certificate, an exemption may be needed as 

the UAS will have no entrance to the cabin, cockpit or pilot station on which the word 

Experimental'' can be placed. Given the size of the sUAS, two inch lettering will be impossible. · · 

The word "Experimental" will be placed on the fuselage in compliance with §45.29 (f). 
! 

I 

I 

I 

The equivalent level of safety will be provided by having the sUAS marked on its fuselage as 

required by §45.29 (f) where the pilot, observer and others working with the sUAS will see the 

identification of the UAS as "Experimental." The FAA has issued the following exemptions to this 

regulation to Exemptions Nos. 10700, 8738, 10167 and 10167A. · 

14 C.F.R. § 61._113 (a) and(b): Private_ Pilo! _Priv~leges and Limi!ations: Pilot in Com~and 

'c ·-~ ~ ' . ' ':. t •. -~ r -iv • ..\ • t ' ) .... - ' ...... 

Sections 61.113 (a) and (b) limit private pilots to noncommercial operations~ Because the UAS ,: 

will not carry a pilot or passengers, the proposed operations can achieve the equivalent level of 

safety of current operations--by requiring thl~f:PIC operat~ng the aircraft to have a private pilot's 

license rather than a commercial pilot's license to operate this small UAS. Unlike a conventional 

aircraft that carries the-pilot and passengers,·tne··sUAS is remotely 'Controlled \vith ·no living thing 

on board. The area of operation is controlled and restricted, and all' flights are planned and 

coordinated'in advance as set forth.ii"l'lhe Mc:friLiaL The level of safety'provide ·exceeds that 

provided by a single· individual holding a -corrimercia~'pHot's certificate operating a conventional 

aircraft. The risks'·a·ssocJated with' the,operation dfthe sUAS. are· so diministfed from the level of 

risk associated with ·cemmercial operations contemplated' by Part·61 when draffed, that allowing 

oper:atic;ms of the .SUAS as·-req'l&ested with a private pilot as· the PIG'exceeds the present level of 

safety achieved by:14·0.F.R. §61!11-3.(8) and(b): ··' ···· ' •1 ._ .• ~-_:,', ~:-;·r·.;_~,·r:· .... :~--~~r-t' _.·~-

14 <>F.R: §91 :?(a): Civil air:craft'air"Worthiness: ·· · 

The,,regulation·requires that-no' perscwrmay'0per-ate'a Civiraircraft unless if is 'in ainlvorthy 

condition. Asthere'will -be ·no -airWorthiness cE}rtificate' issued for the aircraft; -should· this 

exemption be grahted,;·no·FAA regul'atory·-stahda'rd win exist for determining airiNorthiness. 

Given the size;of the:aircraft and'tiierequirements·cdhtained rn the Manufacturer's Operating 

Manual formair:~tenance-and use'of'§afety:cfleck lists priortcieach night, an,equivarent level of 

safety and operating -crl!teria dan· be :f0untt· at tF-ie following links: 

Requested• exemption Aircraft Operatriig l;Jsefls Manuars http,//www.,ctjl.cbm/produd/phantom3/downt6aa~ 

http:/lw\Nw.dji.com/productlphantom27-d6Whloacf''· · ,. 

http:I/www.dji.com/procfUctlinspire1/downl0ad- r·. " .·. · , 

http://www.dji.com/productlspread'ingwinlgss900Ydbwnload 

http;//www.dji.com/product!spreadingWfngss1:oooplus/download 

14 G.F.R. § 91-.9 (b) {2)dSivH Aircraft Flight Mahliat iii the-Aircraft. 

Section 91.9 (b) (2) provides: 

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 curre'ntapprovecf airplane or Rotorcraft Fligt:lt Manual, 

approved manual material, markings, and platah:ts:, 'or an~t·combination thereof. . ~. ' . '(_' ' .. ~ ·( . ' ' 

The sUAS, given its size and configuration has n6 abi:lit'y or place' to··carry such a flight manual 

on the aircraft, not only because there'is no pilot on board, but because there is' no room or·. · 

capacity to carry such an item on the aircraft. 

The equivalent level of safety will be maintained by keeping the flight manual atthe ground 

control point where the pilot flying the sUAS will have immediate access to it. The FAA has 
issued the following exemptions to this regulation: Exemption Nos. 86Q7, 8737, 8738, 9299, 

9299A, 9565,95658,10167, 10167A, 10602,32827, and 10700. 

14 C.F.R. § 91:.,103':Preflight acUon 

' ''. ' .. ' . [ ~ .. ·~:-

·f· 

: . ~ ., i-:" <;. 

This regulation requires each pilot in comm~md to;take certain actions. before:flightto insure the 

safety of flight. As F:AA approved rotorcraft Hight m:anuals_ will not· be provided for the aircraft an 

exemption will be needed_, The PIC will take all. actions ,including reviewingweather, flight 

battery requirements, landing .. and takeoffdistances· and: aircraft performance data b~fore 

initiation of flight.,· .--:,_ .. 

14 C. F. R. §91.1 09; Flight instruction; 

Section 91.103 provides th_at-ao- persoo may operate. a civil aircraft (except a manned. free 

balloon) that is being used for flight im?truetion unless that aircraft has fully functioning dual 

oon~~- -~ 

_, ;.·•' • ,., ,., f"''·. :' . ,. - ;' • ;-

sUASs and remot~ly,~piloted ajrcraft, by their design dQ n~t have fully Junctional duaJ.controls. · 

Flight control is accomplished through the use of a control box that communicates with the 

aircraft via radio·-communications~ The FAA has approved- exemptionsJorfiight training without·· 

fully functional dual controls for a number of:aircr:aftand for flignt,instruction jr~ ex:pefJmental· 

aircraft. See Exe,m.ption Nqs5778K and 98.62A. The.eqt.!ivalent;levelof'Safety can be. achieved 

as neither a pilot nor ppssengers wi.ll be ·carried·ln the air;craft iru3ddition to,tbe small size and .. 

lowspeedoftheaircraft. ;:'<, __ .. •••. :•.c ·-·•::: ··.::-··· ,. 

14 C.F.R. §91.1 19·: Minimum safe altitudes .· : e<· ,,,,. ,i .. ·.' ·; ··· 

-,}o_.',c ·.;~ ';, ~-~~. "' < ,~,·:: ... ~-~ ', ·:~ ••' ,,0 <:' I;,: 

Section ~1.119 establishes ~afe altitudes for opera,tj~·!J ~t~ivii aircraft. Sectio~ 9,t;119 (d) allows 

helicopters to b~ operated,at less ,than the-J'ninimum:~ pxescrib~d. provided tbe·person operating 

the helicopter-complies with any. route or (llltitt~;des,Ji>resc~ib.edc:for helicopters by· the FM.As this 

exemptionis for:. a sUAS that ,is a h,elicopter and tb.e !3Xern!';!tion .req!J~~ts authority ·to, operate at · 

altitudes up to ,400 AGL, or- not m-ore than 200 apove~·at'J elevated p~atform from which filming is, 

planned, an exemption may be needed to allow s-uch· op_er:~tions. As."setforth .herein, .except foro 

the limited conditions stated in the Manual, the UAS will never operate at higher than 400 AGL. 

It will however be operated in a.restrictedsarea with~-security· perimeter,·where· build~ngs and. 

people will not qe exposed to ope(ations witho~:~t thetr pre-obtained con;;ent · 

) "• PL.':: ;:·:.. A •• I 

The equivalent level of safety will be achieved given the size,weight; speed of the UAS as well 

as the location where it is operated. No flight will be taken without the permission of the property 

owner or local·officia,ls. Because of the advance .raotice to the property owner and participants in 

the filming activity, all affected individuals will be aware of the planned flight operations. 

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

551bs. proposed herein and the lack.:qfflamm.at.l;>Je f,uel, a,ny risk associated with these operations 

is far less than those presently presented with conventional aircraft operating at or below 500 

AGL in the movie industry. In addition, the low altitude operations of the-sUAS will ensure 

separation between these small UAS operations and the operations of conventional aircraft that 

must comply with Section 91~ 1 H~·. · ·· 
14 C.F.R. §91.121 Altimeter·Settings : . . \ 

This regulation requires each person operating an aircraft to maintain cruising altitude by 

reference to an altimeter that is set" ... to the elevation of the departure airport or an-appropriate 

altimeter setting available before departure." As the sUAS may not have a barometric altimeter, 

bufinsteadi a· GPS altitUde read out, an -exemption· may be needed. An equivalent level of safety 

wiU be achieved by the operator, pursuant to the Manual and Safety Check list,. by receiving 

altitude !nfo'rmation via a digitally encoded telemethc data feed, which downlinks from tlrle 

aircraft to aground based··onscreen display,: This altitude information will'h>e generated by 

equipment installed on board the aircraft, using GPS triangulation, or digitally encoded 

barometric altimeter, or radio altimeter, or any combination thereof. Prior to each flight, a zero 

altityde initiation point will be established and confirmed for accuracy:by the pilot.' · · 

14 C.F:R. § 91:151(a): Fuel Requfrements,for.Fiight inNFRConditio"ns 

Section 91.151 ~a) prohibits:ari individual frorr.fbegirtning "a flight in an airplane U:hder 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 afterthaMor at least;30 minutes; or(2) At night, to fly after that for at least 45 minutes." •l ·:r::.· .. ' ~ -~:. •!'.~_,...;, ··,~. ~ 

The battery powering the sUAS' provides·approximately 40 minutes ofpowered flight To· meet 

the 30 mi:nuteresef'lle requirement .. in 14 CFR §91.151, sUAS flights would be limited to· 

appl'idximately 10 minutes in length. Glven ·theFifmitatioris O'n-tht.r UAS's propdsecf.flight area and 

the location' of its proposed operatlons'Withirr·a pre·determided areaFa,ionger time frame for 

flight in daylight or night VFR conditions is reasonable. · · .. · · 

South Georgia Drone Training and Services believes that ari exerrfption from 14 CFR 

§91.151 (a) falls within the scope of prior exemptions. See Exemption 10673 (allowing Lockheed 

Martin Corporation to ~Yper'afewithout cdmplia'rilce With· FAR91 t 151 (a));·Operating the small 

UAS, in a tightly: cot"ltrolled area where 'only people and' property owners or official · 

representatives· wh.o have signed waivers wm be allowed;' with ,less•than 3Q .minutes of· reserve 

fuel, aces not engender. thl3: type of:tisks t.h'at Section 91.151 (:a) wa$ :intended'to alleVIate given . 

the size ·and speed of the small UAS< Additic:ihally;·l~niiting sUAS flights to 10 minutes would 

greatly reduce the uti:lity for which the exemptioit will ·be·-granted': ' ' .. -, , ~ ., ) 

South:Georgia Drorre Training and Services 'betieves··thal an equivalent level of safety can be 

achieved by limiting flights to 30 mir:tlites or 25% ofb'Sttery power whichever happens first. This 

restriction would be more than adequate to return the sUAS to its planned landing zone from 

anYwhere in' its 'limited operating area. - . . - · " 

Similar exemptions have been granted to other operations, i'ncluding Exemptions 2689F, 57 45, 

10673, and 10808. '. · . .. · . ··r . •! 

14C.F.R. §91.203 (a) and {b): Carrying CiviiAirct~'ftlCertification and Registration 

The regulation· provides in pertinent part ,. ·, .. 

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

within it the following: 

An appropriate and current airworthiness certificate. 
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 ·§9.1>. 715 is· displayed at the cabin 

or cockpit entrance so that it-is legible to passengers.-or crew. - ;-t '·r - - , 

.; .. : ~ -:: :' ! :. :; . c:-·.: 

The UAS fully loaded weighs no more than 55 lbs: and' is operates·.without an onboafd piloL As·: 

such, there is no ability or place to carry certification and registration-doct~memts orto~display · 

them on the sUAS. __ . - ·· 

An equivalent level of safety will be achieved by keeping tbese documents- at·ti:Je ground control 

point where the pilot flying the sUASwill have-immediate access~to:them, to: the extentthey areapplicable to the sUAS. The_ FAA has issued -numerous ex(ilmptions to this regulation; A - . 

repres.entative sample of otherexceptions--includes-Exemption·Nos. 9565;,·9665, .9789, :9789A, 

9797,: 9797A, 9816A, and 10100. -~ , . (" "}._ 

14 C.F.R. §91.405 (a); 407 (a) (1); 409 (a) (2); 417(a) and (b): Maintenance Inspections 

These regulations-require-that an aircraft operator or owner "shaiL:have- that~ aircraft inspected as 

prescribed in subpart E of this. part and shall between .re.qurr:ed in_spectibns, except as. pr.ovided 

in paragraph (c) of this section, have discrepancies·repaired:astprescribed in part .43 of this 

chapter ... ," and others shall inspect or maintain the aircraft in compliance with Part 43. 

Given that these section and Part 43 apply only to aircraft with an airworthiness certificate,: _ 

these-sections will not apply to the applicant-Maintenance wiJLbe. a9complished by the operator(;, 

pursuanUo the flight manwaland)•operating handbook. As~the·manufacturer does r:mt provide 

specific maintenance instructions, maintenaAc_ewill be !~en.conditiorCfor all-aircraft and each. 

aircraft will have a maintenance log. - - ~ ,_, -::- : -- '~·· !' c. 12 :. , _ .; . r-- , -- ' ;_r·-,c~,-.: t·l ~--·· ~-~ 'r. (. ~- ~ 

An equivalent le'llel of safety will be achieved be.c.ause: thes·e smaii'UASs are very lirilited in size 

and will carry a small payload and operate only in restricted .area's for1imited periods of time. If 

mechanical issues arise the UAS can land immediately and will be operating from no higher 

than 400 feet AGL. As provided in the Manual; the. operatopnill:ensure that the UASds i.n 

working order prior to initiating flight, perform required maintenance, and keep a log of any 

maintenance performed. Moreover, the operator is the person mostfamiliar with the aircraft and 

best suited to maintain the aircraft in an airworthy condition to provide the equivalent level of 

safety. If the operator encounters a maintenance issue which cannot be addressed, the UAS will 

be returned to the manufacturer or a qualified repair facility where such repairs or maintenance 

can be performed. .. : , - :. 

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 needed: 

Applicant seeks an exemption from the following rules: 

14 C.F.R. §21, subpart H; 14 C.F.R 45.23(b); 14 C.F.R. §§ 61.113( a) and (b);91. 7 (a); 91.9 (b) 

(2);91.103(b);91.109; 91.119; 91.121; 91.151(a);91.2D3(a)and (b); 91.405 (a); 91.407 (a) {1); 

91.409 (a) {2); 91.409 (a) (2) and 91.417 (a) and (b) to operate commercially a small unmanned 

vehicle (551bs or less) in aerial photography and aerial filming operations and flight 

demonstrations for training purposes .. 

Approval of exemptions allowing commercial operations of sUASs in the aerial photo and film 

industry will enhance safety by reducing risk. Conventional film operations, using jet or piston 

power aircraft, operate at extremely low altitudes just feet from the subject being filmed and in 
extreme proximity to people and structures;' and present the risks associate·d with vehicles that 

weigh in the neighborhood of 4,'0'001bs., carrying large amounts of jet A or other fuel. Such 

aircraft must fly to and from the film location~ In contrast, a sUAS weighing fewer than 55 lbs. 

and powered by batteries eliminates virtually all of that risk given the reduced mass and lack of 

combustible fuel carried on board. The si:JAS is carried·to the film set and not flown. The sUAS 

will carry no.passenger:s.orcrew and; thereforre1·will not expose them to the-risks associated 

with manned aircraft flights. 

The operation of small UASs, weighing IE)ssthan .55.Jbs:, conducted in the strict conditions 

outlined above, will provide an equivalent level of safety supporting-the graht ofthe exemptions 

requested herein, including exempting the. applicant from the requirements of Part 21 and 

allowing commercial operations. These lightWeight akcraft bperate· at slow speeds, close to the 

ground, and in a sterile environment and, as a result, are far safer than CCDnventional ope-rations 

conducted with turbine helicopters operating in close proximity to the ground and people. . . . ... 

Privacy 

All flights will occur: over private or controlled access property with the property owner's prior 

consent.and ·knowledge. Filming will be ofpeople:who have also-consented'to being filmed or 

otherwise have agreed to be.in·the ·area where filming will take place. 

4. SUMMARY. 

Souttl:,Georgia Drone. Trair:1ing and Services· exemption\request should be granted due to the 

fact that the business will increase competi1!ion·ii:J: the marketplacr:e, ser-ve to benefit the· public 

good in a safe and not interfere with· other safe. and effective operations in the National 

Airspace. Similar exemptions have been granted and have been given .previously to· other 

operators who the same sUASs, e.g. Exemptions Nos. 11062, 11109, 11112, 11213, 11641, 

1163,9, tt240, 11654,11656, :11658, tt659;ct1660, ;11663; 11664,. 11655; 11669., 11670, 

11672, 11639, 1·1641·,.:11642,-\11644, '1t1626.:·~ (~ 

. . ;:· . • ' ' 't~ ~·· 

If yoy have any questions or need any.additional information, please'contactthe undersigned at: .! .~· .. ~. n"' .) ·, 

dapariarisi@yahoo.com {901 )853-6566 · " < • 

'', ,..,. ., '· .. ,. '.!.-\. i \ . 

Dated: 20 December 2015 

Sincerely yours, 

. (~' ,,-? . ·_. ' 

; ;!) ;:/ ~~~. {f./fo~ ,)· 

Donald .Panarisi .' P: ~- · ·. ··-~~l'\ ,. 

Owner, South Georgia Drone Training and SerV-ICes' 

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