< 

.. 

UAS Exemption for DroneBuzzings LLC 

AUGUST 21, 2015 

US Department of Transportation 

Docket Management System 

1200 New Jersey Ave., SE 3 

Washington DC 20590 

The name, address and contact information of the Petitioner is: 

Drone Buzzings LLC 

Chris Pierson, Pres. 

3 0 Pierson Ln 

Bernville, P A 19506 

CELL PHONE: 610.207.5924 

Business Phone: 484.999.0986 

Email; DroneBuzzings@gmail.com (1st) 

CPierson@DroneBuzzings.com 

To whom it may concern: 

Re: Exemption Request Pursuant to Public Law 112-95, Section 333 of the FAA Reform Act 

and Part 11 of the Code of Federal Regulations from: 

Regulations from which the exemotion is requested: 

14 CFR Part 21 subpart H 

14 CFR 47.3(b)(2) 

14 CFR 47.31(c) 

14 CFR 91 .9(b)(2) 

14CFR 91.7 (a) 

14 CFR 103 

14 CFR 91.109(a) 

14 CFR 91.131(b)(1) 

14 CFR 91.131(d)(1)&(2) 

14 ~FR 91. 145 (b) 

14 CFR 91.151 (a) 

14 CFR 91.203(a &b)(2) 

14 CFR 45.23 

14 CFR 61.113 (a & b) 

14 CFR 61.133 

14 C.F.R. 91.403(b & c) 

14 CFR 91.405 

14 CFR 91.407 

14 CFR 91.409 

14 CFR 91.417 

14 CFR 91.119(d)(1) 

14 CFR 91.121 

l[Page 
• Note: 14 CFR Part 61 in its current form applies to manned aircraft. 14 CFR 61.3 refers 

specifically to flight crew members who is defined in Part 1.1 as a pilot, flight engineer, or flight 

navigator assigned to duty "in an aircraft" duringflight time; therefore no exemptions from 

Part 61.3 is being sought for as it is not applicable at the time of this exemption request. 

Pursuant to Section 333 of the FAA Modernization and Reform Act of2012 (the "Reform Act") 

and 14 CFR Part 11, Drone Buzzings LLC, operator of a small Unmanned Aircraft System 

(UAS ), hereby applies for an exemption from the listed Federal Aviation Regulations ("F ARs") 

to allow commercial operation of its UAS, so long as such operations are conducted within and 

under the conditions outlined herein or as may be established by the FAA as required by 

Section 333. 

The exemption would permit Drone Buzzings LLC , to operate a small Unmanned Aircraft 

System (UAS) for the commercial purposes stated in Docket No.: FAA-2015-0150; Notice No. 

15-01, including aerial video and photography over certain areas of the United States. Briefly 

described: 

•!• The ability to offer training to persons individually or belonging to both private and/or 

public organizations that have interests in the use and application of a UAS for the 

purpose ofthe safe operation of a UAS to enhance the safety of the National Airspace 

System (NAS) as well as for the protection of the persons and property. 

•!• Aerial photography and/or video for public and/or private use including real estate, 

architecture, land surveying, engineering and other related professional activities. 

•!• Aerial video and/or photography for public and/or private use including television, public 

events, cinematography and news gathering. 

•!• Aerial inspection/photography of residential/commercial structures under contract with 

the owners or local government authority. 

•!• Aerial inspection/photography of residential/commercial utility infrastructure including 

but not limited to electrical power lines, wind turbines and cell towers. 

•!• Aerial video photography or providing live video feed to assist with search and rescue 

operations in cases of an emergency or natural disaster only when the local authorities or 

government has requested it by contract and/or donation. 

21Page 
· As described fully hereafter, the requested exemption would permit the operation of a UAS by 

Drone Buzzings LLC under controlled conditions in the NAS that would be a) limited b) 

controlled c) predetermined and d) will provide safety enhancements to the already safe 

operations in the industry presently using conventional aircraft. Approval of this exemption 

would thereby enhance safety and fulfill the Secretary of Transportation's and the FAA 

Administrator's responsibilities to " .... establish requirements for the safe operation of such 

aircraft systems in the national airspace system. 

Description and specifications of UAS to be used by the Petitioner 

DJI Phantom 3 Professional 

Type: Quad Rotor Copter 

Weight: (including battery and propellers) 2.8 pounds 

Diagonal size: (including propellers) 23.3 inches 

Max Speed: 35.8 mph (no wind) 

GPS Mode: GPS/GLONASS 

Aircraft means of propulsion: Electric via Lithium Polymer Batteries 

Battery Capacity: 4480 mAh 

Remote Control Operating Frequency: 2.400GHz- 2.483GHz. 

Live Feed Frequency: 5.728GHz- 5.850GHz. 

Max Flight Time: Approximately 23 minutes 

Special Features: Return to Home (RTH) mode if battery life gets to low point 

DJI INSPIRE 1 T600 

Type: Quad Rotor Copter 

Weight: (including battery and propellers) 2935 grams (6.47 lbs) 

Dimensions: 438mm x 451mm x 301mm or 17.24in x 17.75in x 11.85in. 

Max Speed: 22.2nlsec = 49mph (no wind) 

GPS Mode: GPS/GLONASS 

Aircraft means of propulsion: Electric via Lithium Polymer High Voltage Batteries 

Battery Capacity: 4500 mAh and -+ 5700 mAh 

Remote Control Operating Frequency: 2.400GHz - 2.483GHz. 

Live Feed Frequency: 5.728GHz- 5.850GHz. 

Max Flight Time: Approximately 18 minutes 

Special Features: Return to Home (RTH) mode if battery life gets to low point 

DJI SlOOO Professional Spreading Wings 

Type: Octo- Rotor copter 

Weight: (including battery and propellers) 4.4 Kg 

Diagonal size: (including propellers) 1045 mm 

Max Speed: not made for high speed 

GPS Mode: GPS/GLONASS 

Aircraft means of propulsion: Electric via Lithium Polymer Batteries 

Battery Capacity: 1 OOOmAh-2000 mAh 

Remote Control Operating Frequency: 2.400GHz - 2.483GHz. 

Live Feed Frequency: 5.728GHz- 5.850GHz. 

Max Flight Time: Approximately 15 minutes 

31Paoe :::;:. 
· General Operatin2 Standards 

The Petitioner, Drone Buzzings LLC , will operate the UAS in line of sight within a 

predetermined area owned ami! operated by the property representative. Given the small size of 

the UAS and the controlled environment provided, the proposed operations will adhere to the 

Reform Act's safety requirements. The approval of this application presents no national security 

issues. Regarding the level of safety surrounding the proposed operations and the public 

benefit, reduction in environmental impacts, including but not limited to reduced emissions and 

noise, the grant of the requested exemption is in the public interest. Accordingly the Petitioner 

requests that the FAA grant the requested exemption with minimum delay. 

Drone Buzzings LLC will only operate its UAS in line of sight of a pilot and/or observer and 

will operate at sites that are a 'sufficient distance' from populated areas. Such operations will 

insure that the UAS will "not create a hazard to users of the national airspace system or the 

public." 

Before an operation of a UAS within 5NM of an airport with a control tower, the control tower 

will be called to gain permission to operate the UAS. The PIC will give the position, altitude 

and the times the UAS will be operated. The UAS will not be operated at an altitude of over 500 

feet AGL. Weather minimums will be 3 miles visibility and a 1000 foot ceiling. 

Before an operation of a UAS within 5NM of a non-tower controlled, airport operators will be 

notified and the PIC will give the right of way to avoid flying in the proximity of full-scale 

aircraft. At no time will the UAS be operated within the final approach course and the takeoff 

course of any runway. 

- Maximum flight time for each operational flight will be 15 minutes. 

- Flights will be terminated at 25% battery power reserve should that occur prior to the 15 

minute limit. 

- The UAS will be programmed so that it will not be operated at an altitude of no more 

than 500 feet AGL and not more than 200 feet above an elevated platform from which 

filming is planned. 

- Minimum crew for each operation will consist of the UAS Pilot, and Visual Observer. 

- The UAS operated by the petitioner weighs less than 55 pounds, including the payload 

(i.e. camera, lens, and gimbals). 

- The UAS will operate at speeds of no more than 25 knots, can hover, and can 

simultaneously move vertically and horizontally. 

- Given the small size of the UAS and the restricted sterile environment within which they 

will operate, our UAS operations adhere to the Reform Act's safety requirements. 

The UAS, powered by batteries, is smaller, lighter and more maneuverable than larger aircraft 

running on combustible fuel, it operates at lower altitudes with no people on board and will 

thereby reduce current risk levels and thereby enhance safety and diminish the likelihood of 

41Page 
. 

· death or serious bodily injury. With a small payload and maximum flight time of only 15 

minutes, this is offers little or no risk to national security. 

Low level oblique photos and video from several angles are far more effective than ground 

based imagery for displaying the characteristics of large, complex properties with several 

buildings and large trees. 

The benefits of reduced cost and improved quality of presentation from the UA will be valuable 

to and benefit many buyers and sellers of real property. Chartering full-sized helicopters for this 

purpose, have proven more costly than many potential clients are able to afford. 

Additionally, we request that we be allowed to use our system to benefit first responders nearby 

who might require assistance, including fire fighters, the police, the sheriff, et al., while 

remaining subject to all limitations cited in this application as we do so. 

Pilot in Command and Observer Qualifications and Duties 

In addition to these flight restrictions, Drone Buzzings LLC will further ensure safe operation 

by requiring that any PIC be thoroughly versed not only in airspace and communication issues 

pertaining to all aircraft operators but also in the unique aspects ofUAS flight. As set forth in 

the Operations Manual, Pilots will have experience not only in UAS operations generally but 

have logged flight time in the specific make and model used for the operations before they are 

permitted to participate in commercial flights on behalf of Drone Buzzings LLC . Petitioner 

believes that this system will provide a higher level of competency and proficiency for its pilots. 

Pilot In Command Duties are: 

The PIC is responsible for the safe and efficient operation of the aircraft. Specific duties include 

all preflight preparation, in flight operation, post flight requirements, all procedures including 

but not limited to: 

• Safe in-Bight operations 

• Risk Mitigation to Persons and Property 

• Airfield Suitability 

The Visual Observers Duties are: 

• The Observer must have the visual acuity to observe the UAS and be able to 

communicate clearly with the PIC. 

• Warning the PIC of any impending obstacles in the flight path of the UAS. 

5\Page 
• Warning the PIC of any deviations in the planned flight path of the UAS. 

• Warning the PIC should any unauthorized personnel appear in the area of the planned 

flight. 

• The Observer will have the authority to order the PIC to terminate the flight should he 

feel the flight cannot be conducted safely. 

AIRCRAFT AND EQUIVALENT LEVEL OF SAFETY 

The operation limitations proposed for an equivalent or higher level of safety because 

operations will further enhance the safety of persons, property and also manned aircraft in the 

NAS. These limitations and conditions to which the Petitioner, hereafter referred to as the 

operator, agrees to adhere to when conducting commercial operations under the FAA issued 

exemption limitations, and as set forth in the Flight Operations Manual (FOM) include: 

1. The small UAS, as specifically designated and described in this petition, will weigh less than 

55 lbs including payload. 

2. The UA will be operated within visual line of sight (VLOS) at all times by the operator or 

visual observers. (VOs). 

3. The UA will remain close enough to the operator so that human vision unaided by any 

device other than corrective lenses will be used. 

4. The UA will not be operated over persons not directly involved in the operation unless those 

persons remain under a covered structure. 

5. The UA will only be operated during sunlight (official sunrise to sunset in operation area) 

unless specific authorization from the FAA is granted prior to operations. 

6. The operator may use VOs for certain operations and will ensure each VO is trained on 

procedures listed in the operators FOM. 

7. The UA will not be operated at a speed exceeding 87 knots (100 miles per hour) using 

ground speed or calibrated airspeed to determine compliance with the 87 knot speed 

restriction. In no case will the UA be operated at airspeeds greater than the maximum UA 

operating airspeed recommended by the aircraft manufacturer. 

8. The UA will be operated at an altitude of no more than 500 feet above ground level (AGL). 

Altitude will be measured in feet AGL. If an object to be inspected, such as an antenna, 

exceeds 500 feet AGL, the operator will limit the flight to within 200 feet higher than the 

structure being photographed. The operator will notify the FAA and local authorities of the 

proposed plan to include date, time, location and height of the object to be inspected prior to 

operations. The UA will be flown in a safe manner in close proximity to the object as to not 

61Page 
interfere with traffic in the NAS. 

9. The UA will not be operated unless visibility is greater than day requirements listed in 14 

CFR 91.15 5 for the Class of airspace at the operator's ground station, on location. 

10. The UA will not be 9perated in Class A airspace (18,000 feet and above). 

11. The operator will receive ATC permission prior to operations in Class B, C, D and E 

airspace. 

12. The operator will ensure that any VOs, if used, will only monitor one UA at any given time. 

13. The operator will not allow operations from a moving vehicle or aircraft, except for 

watercraft on the water. 

14. The operator will not conduct any careless or reckless operations. A flight will be 

terminated immediately as possible if the safety of the operation cannot be maintained. 

15. Prior to each flight, the operator will conduct a pre-flight inspection and determine that the 

UAS is in a condition for safe flight. The pre-flight inspection must account for all potential 

discrepancies, e.g. inoperable components, items, or equipment. If the inspection reveals a 

condition that affects the safe operation of the UAS, the aircraft is prohibited from operating 

until the necessary maintenance has been performed, logged and the UAS is found to be in a 

condition for safe flight. 

16. The operator will not operate any UA if a physical or mental condition would prevent the 

safe operation of that aircraft. 

17.When using aVO or VOs, the operator and VO must be able to communicate at all times. 

Radio communications or communication assisting devices may be used. Electronic 

messaging or texting will not be permitted during flight operations. Daisy-chaining ofVOs 

for the purpose of expanding the operations area will not be permitted. 

18. The operator will be responsible to see and avoid all other users of the NAS in which the 

UAS is operating. 

19. The holder of this exemption will be responsible to ensure its aircraft are properly registered 

in accordance with 14 CFR Part 47, and have identification (N-Number) markings in 

accordance with 14 CFR Part 45 Subpart C. Markings must be large as practicable. 

20.The UAS operator will be designated before the flight and cannot transfer his or her 

designation for the duration of the flight unless a medical duress or unforeseen emergency is 

preventing safe operation of the UAS. In which case the VO, who has been deemed qualified 

and trained in the operation of the UAS, will operate the controls to land the UA in a 

predetermined "emergency plan" set forth by the operator who was granted this exemption. 

The holder of this exemption must ensure that VOs, if used, can perform the duties required 

of aVO. 

21.Documents for UAS operations and maintenance will be made available to the FAA upon 

request. If a discrepancy exists between the conditions and limitations in this exemption and 

the procedures outlined in the FOM, the conditions and limitations herein take precedence 

and must be followed. Otherwise, the operator must follow the procedures as outlined in the 

FOM. The operator may update or revise its operating documents. It is the operator's 

responsibility to track such revisions and present revised documents to the FAA or any law 

enforcement official upon request. If the operator determines that any update or revision 

71Page 
would affect the basis upon which the FAA granted an exemption, then the operator must 

petition for an amendment to its grant of exemption. The FAA's UAS Integration Office 

(AFS-80) may be contacted if questions arise regarding updates or revisions to the operating 

documents. 

22. Any UAS that has undergone maintenance or alterations that affect UAS operations or flight 

characteristics, e.g. replacement of a flight critical component, must undergo an operational 

check flight prior to conducting further operations under this exemption. Operational check 

flights may only be conducted by a qualified operator familiar with the specific UAS being 

checked and must remain 500 feet from any persons unless they remain under a covered 

structure. (NPRM wording) The operational check flight must be conducted in such a 

manner so as to not pose an undue hazard to persons and property. 

23.The operator is responsible for maintaining and inspecting the UAS to ensure that it is in a 

condition for safe operation. 

24. The operator must follow the UAS manufacturer's maintenance; overhaul, replacement, 

inspection, and life limit requirements for the aircraft and aircraft components. 

25.The holder of this exemption will follow manufacturers safety bulletins for each UAS 

operated under this exemption. 

26. The holder of this exemption will ensure that each operator is 17 years or older, a US citizen 

and has a state issued driver's license. 

27. The holder of this exemption will require that its operators demonstrate the ability to safely 

operate the UAS in a manner consistent with how the UAS will be operated in this petition, 

including evasive and emergency maneuvers and maintaining appropriate distances from 

persons, vessels, vehicles and structures. Qualification flight hours and currency may be 

logged in a manner consistent with 14 CFR 61.51 (b). Flights for the purposes of training the 

operator's and VOs (training, proficiency, and experience building) and determining the 

ability to safely operate the UAS in a manner consistent with how the UAS will be operated, 

will be permitted. However, training operations may only be conducted during dedicated 

training sessions. During training, proficiency, and experience-building flights will be 

conducted 500 feet from any persons that are not intended to be part of such training 

operations unless those persons remain under a covered structure. 

28. The operator will use UAS that have safety features allowing it to return to a preset location 

if it loses communications with its ground station. The operator will set this pre-determined 

location within the private or controlled access property as to minimize any possible contact 

with objects. 

8JPage 
29. The operator is prohibited from beginning a flight (considering wind and forecast weather 

conditions) unless there is enough available power for the UA to conduct the intended 

operation and to operate after that with at least 25% energy reserves or with the reserve 

power recommended by the manufacturer, whichever is greater. The operator will perform 

training tests, in a designated training area as prescribed herein, to assess the true energy 

characteristics of the specific UAS battery system to determine the power. Said energy tests 

will deem the "safety" operating procedure for actual emergencies and useful flight time. 

30.The exemption holder will ensure that operators and VOs have a copy of this exemption, the 

FOM and applicable aircraft registrations located at the ground station during operations. 

These documents will be made available to the Administrator or any law enforcement 

official upon request. 

31.All operations shall be conducted over private or controlled access property with permission 

from the property owner/controller or authorized representative. 

32. The exemption holder will be responsible to report to the FAA any small UAS operation that 

results in: (1) any injury to a person; or (2) damage to property other than the small 

unmanned aircraft. The report would have to be made within 10 days of the operation that 

resulted in injury or damage to property. Accidents will be reported to the National 

Transportation Safety Board (NTSB) per instructions contained on the NTSB Web site: 

www.ntsb.gov. Current NTSB accident reporting is required when ... 

1) Any person suffers death or serious injury. 

2) Any UAS with max gross takeoff weight exceeding 300 pounds sustains substantial 

damage. 

Operations for closed-set motion picture and television filming and production include the 

following limitations: 

33.The operator must have a motion picture and television operations manual (MPTOM) in 

his/her possession. 

34.At least 3 days before aerial filming, the operator of the UAS must submit a written Plan of 

Activities to the local Flight Standards District Office (FSDO) with jurisdiction over the area 

of proposed filming. The 3-day notification may be waived with the concurrence of the 

FSDO. The plan of activities must include at least the following: 

a.Dates and times for all flights; 

b. Name and phone number of the operator for the UAS aerial filming; 

c. Name and phone number of the person responsible for the on-scene operation of 

the UAS 

d. Make, model, and serial or N-Number ofUAS to be used; 

e. A statement that the operator has obtained permission from property owners and/or 

local officials to conduct the filming production event; 

91Paoe b 
f. A list of those who gave permission, must be made available to the inspector upon 

request; 

g. Signature of operator or representative; 

h. 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 altitudes 

essential to accomplish the operation. 

3 5. Flight operations may be conducted over/near participating persons consenting to be 

involved and necessary for the filming production, as specified in the operator's MPTOM. 

Regulations from which the exemption is requested: 

14 CFR Part 21, Subpart Hand 14 CFR §91.203(a)(l)&(b): Airworthiness Certificates 

Subpart H, entitled Airworthiness Certificates, establishes the procedural requirements for the 

issuance of airworthiness certificates as required by 14 CFR 91 .203 (a)( 1 ). Given the size and 

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

from Part 21 Subpart H meets the requirements of an equivalent level of safety under Part 11 

and Section 333 of the Reform Act. The Federal Aviation Act (49 U.S.C.§44701 (f)) and 

Section 333 ofthe "A Reform Act both authorize the FAA to exempt aircraft from the 

requirement for an airworthiness certificate, upon consideration of the size, weight, speed, 

operational capability, and proximity to airports and populated areas of the particular UAS. in 

all cases, an analysis of these criteria demonstrates that the UAS operated without an 

airworthiness certificate, in the restricted environment and under the conditions proposed will 

be at least as safe, or safer, than a conventional aircraft (fixed wing or rotorcraft) operating with 

an airworthiness certificate without the restrictions and conditions proposed. 

The UAS to be operated hereunder is less than 55 lbs. fully loaded, carries neither a pilot nor 

passenger, carries no explosive materials or flammable liquid fuels, and operates exclusively 

within a secured and designated area. Unlike other civil aircraft, operations under this 

exemption will be tightly controlled and monitored by both the operator and under the 

requirements and in compliance with local public safety requirements. These safety 

enhancements provide a greater degree of safety to the public and property owners than 

conventional operations conducted with airworthiness certificates issued under 14 C.F .R. Part 

21, Subpart H. Lastly, application of these same criteria demonstrates that there is no credible 

threat to national security posed by the UAS, due to its size, speed of operation, location of 

operation, nearly silent operation, lack of explosive materials or flammable liquid fuels, and 

inability to carry a substantial external load. 

14 CFR 47.3(b)(2) and 14 CFR 47.31(c) and 14 CFR 91.203(a)(2): Registration required 

This regulation states in part: No person may operate an aircraft that is eligible for registration 

under 49 U.S.C. 44101- 44104 unless the aircraft is carrying aboard the temporary authorization 

required by §47.31(c). Part 91 .203(a)(2) reads similar. The Petitioner will be operating small 

10 I Page 
· UAS. Placing registration paperwork inside the UA will be impractical. An equivalent level of 

safety can be achieved by the Petitioner ensuring that all temporary or permanent registration 

paperwork for the UAS being operated is located on site at the ground station as stated in item 

#30 in this document. 

14 CFR 91 .9(b)(2): Civil Aircraft Flight Manual in 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 current approved airplane or Rotorcraft Flight Manual, 

approved manual material, markings, and placards, or any combination thereof. The UAS, given 

its size and configuration has no ability 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 UAS 

flight manual at the ground station where the UAS operator will have immediate access to it. 

14 CFR 91.109(a): Flight Instruction 

Section 91.109(a) provides 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. The Petitionerwill be operating small UAS that it do not have fully functional dual 

controls. Flight control is accomplished through the use of a control box transmitter that 

communicates with the aircraft via radio communications. The equivalent level of safety is 

provided by the fact that neither a pilot nor passengers will be carried in the aircraft and by the 

size and speed of the aircraft. Flight instruction is accomplished by handing the transmitter 

between the instructor and trainee or by the use of a buddy box system instruction will also be 

accomplished in accordance with item #27 in this document. 

14 CFR 91.119(d)(l): Minimum Safe Altitudes 

Section 91.119 establishes safe altitudes for operation of civil aircraft. Section 91 .119( d)(l) 

allows helicopters to be operated at less than the minimums prescribed, provided the person 

operating the helicopter complies with any route or altitudes prescribed for helicopters by the 

FAA. As this exemption is for a UAS that is similar to a helicopter and the exemption requests 

authority to operate at altitudes up to 500 AGL, or not more than 200 above a structure from 

which filming is planned, an exemption may be needed to allow such operations. As set forth 

herein, the UAS will never operate at higher than 500 AGL with the exception that in 

circumstances where the UAS is used to survey or photograph a structure whose height exceeds 

500 feet AGL, the UAS will not be operated more than 200 feet above the highest point on the 

structure in accordance with procedures outlined in item #8 of this document. 

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 officials. Because of the advance notice to the property owner and 

participants in the filming activity, all affected individuals will be aware of the planned flight 

lliPage 
· operations. Compared to flight operations with aircraft or rotorcraft weighting far more than the 

maximum 55lbs. proposed herein and the lack of flammable fuel, noise and any risk associated 

with these operations is far less than those presently presented with conventional aircraft 

operating at or below 500 AGL. In addition, the low-altitude operations of the UAS will ensure 

separation between these UAS operations and the operations of conventional aircraft that must; 

comply with Section 91 .119. The procedures outlined in this document prohibit flight over 

persons not involved in operations unless they remain under a covered structure. 

14 CFR 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 small UAS does not have a barometric 

altimeter, but instead a GPS altitude read out, an exemption may be needed. An equivalent level 

of safety will be achieved by the operator, pursuant to the safety check list and live flight data 

monitoring, confirming the altitude of the launch site shown on the GPS altitude indicator 

before flight. Flights will be conducted 500 feet above that read out or within 200 feet above the 

highest point of the structure being filmed as outlined in item #8 of this document 

14 CFR 45.23: Marking of the Aircraft 

The regulation requires: 

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. 

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 UAS, two inch lettering will be impossible. 

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

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

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

identification of the UAS as "Experimental 

14 CFR 91.103: Preflight Action. 

This regulation requires each pilot in command to take certain actions before flight to insure the 

safety of flight. As FAA approved rotorcraft flight manuals will not be provided for the aircraft 

an exemption will be needed. The PIC will take all actions as stated in the FOM in Section 4 

under Normal Procedures including but not limited to reviewing weather, flight battery 

requirements, landing and takeoff distances and aircraft performance data before initiation of 

flight. Before the aircraft takes flight, a home GPS location will be set for any reason the aircraft 

becomes disoriented in flight, and return safely to home. 

121 Page 
· 14 CFR 91.145: Management of aircraft operations in the vicinity of aerial 

demonstrations and managing events states: 

of this section, the FAA considers the following factors: 

( 1) Area where the event will be held. 

(2) Effect flight restrictions will have on known aircraft operations. 

(3) Any existing ATC airspace traffic management restrictions. 

( 4) Estimated duration of the event. 

( 5) Degree of public interest. 

( 6) Number of spectators. 

(7) Provisions for spectator safety. 

(8) Number and types of participating aircraft. 

(9) Use of mixed high and low performance aircraft. 

(10) Impact on non-participating aircraft. 

( 11) Weather minimums. 

(12) Emergency procedures that will be in effect. 

Note: If Drone Buzzings LLC intends to use a UAS to cover sporting events from outside the 

activity, coordination will be completed by contacting the FSDO prior to the event to ascertain 

the presence of any other unmanned activities. Flight activity will be conducted based on safety 

and with particular attention to the avoidance of overflight of large concentrations of people. 

However, specific relief from this regulation is still necessary to ensure compliance with F ARs. 

14 CFR 61.113 (a) and (b): Private Pilot Privileges and Limitations and 61.133 

Commercial pilot privile&es and limitations. 

Pilot in Command. 

Pursuant to 14 CFR 61.113 (a) & (b), no person who holds a private pilot certificate may act as 

a pilot in command of an aircraft that is carrying passengers or property for compensation or 

hire. Drone Buzzings LLC may achieve an equivalent level of safety as achieved by current 

Regulations because the applicant's UAS do not carry any pilots or passengers nor property. 

The risks inherent to the operation ofUAS is far less than the risk levels inherent in the 

commercial activities outlined in 14 CFR 61. 

Drone Buzzings LLC seeks exemption from 14 CFR § 61.113, which restricts private pilot 

certificate holders from flying aircraft for compensation or hire, and would also require a second 

class medical certificate. The purpose of Part 61 is to ensure that the skill and competency of 

any PIC matches the airspace in which the PIC will be operating, as well as requiring 

certifications if the private pilot is carrying passengers or cargo for hire. In this case, while the 

UASs will be operated as part of a commercial operation, it carries neither passengers nor 

cargo. In the Grant ofExemption in FAA Docket No. FAA-2014-03 52, the FAA determined 

that the unique characteristics of UAS operation outside of controlled airspace did not warrant 

the additional cost and restrictions encumbent with requiring the PIC to have a commercial pilot 

certificate and/or class II medical certificate. 

131Page 
· The restrictions Drone Buzzings LLC has placed on its UAS flight operations manual is to 

meet or exceed the restrictions similarly imposed on Astraeus Aerial in FAA Docket No. FAA20 14-0352. Drone Buzzings LLC will operate away from persons and property not involved 

in the operation, and flights will be conducted using VLOS at 500' AGL or below. A NOT AM 

will be issued between 48 and 72 hours before the flight is to occur, and the flight will be 

coordinated with the applicable FSDO. 

14 CFR 91.131 (b)(l): Pilot requirements for Class B airspace 

This regulation states that no person may operate a civil aircraft within a Class B airspace 

unless that person is a private pilot, recreational pilot, sport pilot or is a student pilot that meets 

requirements of §61.94 or §61.95 of this chapter. An exemption from this regulation may be 

required. An equivalent level of safety will be achieved by operating the small UAS at altitudes 

listed in the limitation section of this document. The UA will not be landing or departing from 

airports in Class B airspace nor flying through Class B airspace. The UAS will be flown in a 

controlled environment within VLOS. The UAS operator will require ATC permission prior to 

conducting operations and will give right of way to any manned aircraft. 

14 CFR 91 .131(d)(l) and (2): Equipment reguirements for Class B airspace 

The regulation states that no person may operate an aircraft in Class B airspace unless it is 

equipped with a transponder and after January 1, 2020 an ADS-Bout system. An exemption 

may be required. Due to the size, weight and payload capacity of the small UAS, installing 

these systems is not practical. An equivalent level of safety will be achieved by operating the 

small UAS at altitudes listed in the limitations section of this document. The UAS will not be 

landing or departing from airports in Class B airspace nor flying through Class B airspace. The 

UAS will be flown in a controlled environment within VLOS. The UAS operator will require 

ATC permission prior to conducting operations and will give right of way to any manned 

aircraft. 

Note: If Drone Buzzings LLC is conducting an exposition or contracted for filming purposes 

at an airport that would require landing or departing in Class B airspace. Drone Buzzings LLC 

will seek and acquire the proper permits thru the FAA, local authorities, and any other 

necessary agency. A detailed proposed plan would include date, time, location and purpose of 

needed area to complete the planned operations. The UA will be flown in a safe manner as to 

not interfere with traffic in the NAS. 

14 CFR 91.403 (b) and (c); 91.405; 91.407; 91.409; 91.417: 

Maintenance and Inspections. 

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, have discrepancies 

repaired as prescribed in part 43 of this chapter ... ," and others shall inspect or maintain the 

aircraft in accordance with Part 43. 

Part 43 only applies to aircraft with a US airworthiness certificate or foreign registered aircraft 

operating in common carriage under provisions of Part 121 or 135. These sections will not 

apply to the Petitioner who will be operating a small UAS. An equivalent level of safety will be 

141 Page 
· achieved as the UAS will be maintained in accordance with the UAS manufacturer's 

instructions and limitations listed in the operator's FOM. The small UAS will carry a small 

payload and operate in a controlled area for a limited period of time. If mechanical issues arise 

the UAS can land immediately and will be operating from no higher than 500 feet AGL, 

without prior FAA authorization. The operator will ensure that the UAS is in working order 

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

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

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

safety. 

14 CFR 91.151: Fuel Requirements for Flight in VFR Conditions 

Section 91.151 (a) prohibits an individual from beginning "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; or (2) At night, to fly after that for at least 45 minutes." 

The battery powering the UAS provides approximately 30 minutes of powered flight. To meet 

the 30 minute reserve requirement in 14 CFR §91.151, UAS flights would be limited to 

approximately 10 minutes in length. Given the limitations on the UAS's proposed flight area 

and the location of its proposed operations within a predetermined area, a longer time frame for 

flight in daylight or twilight VFR conditions is reasonable. 

Applicant believes that an exemption from 14 CFR §91.151(a) falls within the scope of prior 

exemptions. Operating the UAS, in a tightly controlled area where only people and property 

owners or official representatives who have signed waivers will be allowed, with less than 30 

minutes of reserve fuel, does not engender the type of risks that Section 91 .151( a) was intended 

to alleviate given the size and speed of the small UAS. Additionally, limiting UAS flights to 10 

minutes would greatly reduce the utility for which the exemption will be granted. 

Applicant believes that an equivalent level of safety can be achieved by limiting flights to 30 

minutes or 25% of battery power whichever happens first. This restriction would be more than 

adequate to return the UAS to its planned landing zone from anywhere in its limited operating 

area. 

14 CFR 91.203 (a) and (b): Carrying Civil Aircraft Certification 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: 

(1) An appropriate and current airworthiness certificate .... 

(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. 

151Page 
· The UAS fully loaded weighs no more than 55 lbs. and is operated without an onboard pilot. As 

such, there is no ability or place to carry certification and registration documents or to display 

them on the UAS. 

An equivalent level of safety will be achieved by keeping these documents at the ground control 

point where the pilot flying the UAS will have immediate access to them, to the extent they are 

applicable to the UAS. 

Again, if pilot forgets documents, all documents can be achieved via the DJI Pilot App. 

14 CFR 91.403(b) and (c); 91.405; 91.407; 91.409; 91.417: Maintenance and Inspections. 

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, have discrepancies 

repaired as prescribed in part 43 of this chapter ... ," and others shall inspect or maintain the 

aircraft in accordance with Part 43. 

Part 43 only applies to aircraft with a US airworthiness certificate or foreign registered aircraft 

operating in common carriage under provisions of Part 121 or 135. These sections will not 

apply to the Petitioner who will be operating a small UAS. An equivalent level of safety will be 

achieved as the UAS will be maintained in accordance with the UAS manufacturer's 

instructions and limitations listed in the operator's FOM. The small UAS will carry a small 

payload and operate in a controlled area for a limited period of time. If mechanical issues arise 

the UAS can land immediately and will be operating from no higher than 500 feet AGL, 

without prior FAA authorization. The operator will ensure that the UAS is in working order 

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

maintenance performed. Moreover, the operator is the person most familiarwith the aircraft and 

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

safety. 

161Page 
'" 

., .. Safety and Benefits of the UAS 

Drone Buzzings LLC will be using the UAS in a variety of applications that generally require 

expensive full-size manned aircraft to complete. Small, light, unmanned aerial vehicles offer a 

myriad benefits over the use of full-sized manned aircraft for electric power line inspection, 

oil/gas pipeline inspection, advanced agriculture, film and still photography, just to name a few. 

Replacing significantly larger manned aircraft carrying crew and flammable fuel with small 

UAS carrying no passengers or crew creates a much greater margin of safety for the pilots and 

crew. By granting Drone Buzzings LLC 's requested exemptions, the FAA will help drive 

development of safe and successful commercial UAS operations and will advance the public 

knowledge base for such operations. Drone Buzzings LLC is committed to promoting the 

UAS research efforts of policymakers including the FAA, NASA, DOD and DARPA by 

sharing data from its commercial UAS operations and serving as a resource for future UAS 

research operations. Thus, the FAA has good cause to grant this Petition. 

Conclusion 

As pointed out in this application, all the SUAs which Drone Buzzings LLC use, under 

authorization by the US DOT-FAA, are small, light-weight devices operated within the line of 

sight of the Pilot-in-Command (PIC), less than 500 feet above the ground and outside 5 miles 

from any airport, heliport, seaplane base, Spaceport, or other location with aviation activities, 

unless the air traffic control authorities (ATC) have been notified and have authorized each 

flight within a radius of this distance. 

All our SUAs have proven capability for controlled flight. They are devices offered for general 

sale on the market around the world and have often been used as Model Aircraft in the USA. 

We are certain that the studies conducted until now by the FAA, about Section 332, Public Law 

112-95,2014, have already provided you with the assurances on the airworthiness ofSUAs 

such as ours. 

For the foregoing reasons, the exemptions requested herein should be granted and Drone 

Buzzings LLC should be permitted to conduct small UAS operations in accordance with its 

manuals and all other operating parameters deemed necessary and appropriate by the FAA. The 

submission of this application and its contents is the best demonstration that indeed it is 

possible to pursue the authorization process so that some SUAs may be used for legitimate 

commercial activities and under reasonably safe conditions. 

171Page 
.. 

Additional Information 

The Petitioner, Christopher Pierson, president of Drone Buzzings LLC, currently holds 

certification by the state of Pennsylvania for inspection of Amusements and Amusement rides, 

and therefore is quite knowledgeable about Saftey, Risk Assessment, and 

Protection to property and human lives from defective or dysfunctional equipment. His 

expertise of safety in the amusement industry would be helpful and translate into teaching 

others about UAS safety and operations to generations to come. 

He has had a long term love for RC devices since he was a young boy and therefore possess RC 

skills such as model building, repairing, maintaining and flying experience. He also holds a 

Bachelor of Recreation Management degree from Brigham Young University in Provo UT and 

is currently the General Manager of a 10 acre multi-attraction Entertainment facility in 

Leesport, P A. 

Satisfaction of criteria provided in Section 333 of the Reform Act of2012 provide more than 

adequate justification for the grant of the requested exemptions allowing the commercial 

operation of the Petitioner's UAS. 

Respectfully submitted, 

Christopher Pierson, President 

Drone Buzzings LLC 

DroneBuzzin s.com 

181Page