Intelligent Corporate Solutions, LLC

8 Redstone Ct.

Mechanicsburg, PA 17050

Phone: 717-796-5920 

E-Mail: joseph@intelligentcorporatesolutions.com

Web: www.intelligentcorporatesolutions.com

April 10, 2015

U.S. Department of Transportation

Docket Management System

1200 New Jersey Ave.,

SE Washington, DC 20590

Dear Sir or Madam:

This application is being submitted on my own behalf without legal council or consulting services. 

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the Reform Act) and 14 C.F.R. Part 11, Intelligent Corporate 

Solutions, LLC, operator of Small Unmanned Aircraft Systems (“SUASs”) equipped to conduct aerial photography and videography, hereby 

applies for an exemption from the listed Federal Aviation Regulations (“FARs”) to allow commercial operation of its SUASs, 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 333.1 

As described more fully below, the requested exemption would permit the operation of small, unmanned and relatively inexpensive SUAS 

under controlled conditions in airspace that is 1) limited 2) predetermined and 3) controlled. The proposed exemption, if granted, would allow 

Intelligent Corporate Solutions, LLC to conduct commercial operations of small unmanned aircraft systems (“UAS”) meeting or exceeding 

all of the operational and safety requirements Congress has set forth in Section 333. 

Intelligent Corporate Solutions, LLC is an image processing company that plans to exploit the capabilities of Unmanned Aerial Systems to 

offer a multitude of services, including: 

- Aerial surveying 

- Remote sensing 

- Event Photography /Videography 

- Agriculture purposes 

- Real Estate Photography 

- Aerial filmmaking and photography 

- Construction site inspections and monitoring 

- Wildlife and forestry monitoring 

- Educational and research operations 

Statutory Authority Section 333, titled “Special Rules for Certain Unmanned Aircraft Systems”, provides a mechanism for seeking 

expedited FAA authorization of safe civil UAS operations in the NAS. Section 333(a) states that the FAA “shall determine if certain 

unmanned aircraft systems may operate safely in the national airspace system before completion of the (comprehensive) plan and rulemaking 

required by section 332(b)(1) of this Act or the guidance required by section 334 of this Act.” In Section 332(b)(1), Congress made it clear that

Section 333 provides a mechanism for “expedited operation authorization” if several factors are met. Petitioner meets all requirements to 

permit FAA approval of commercial UAS operations. 

The Petitioner Requests Relief From the Following: 

Regulations from which the exemption is requested: 

14 C.F.R. Part 21 

14 C.F.R. 45.23 (b) 

14 C.F.R. 61.113(a) and (b) 

14 C.F.R. 91.7 (a) 

14 C.F.R. 91.9 (b) (2) 

14 C.F.R. 91.109 

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. 91.205 (b) 
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14 C.F.R. 91.215 

14 C.F.R. (91.401 - 91.417) 

Unmanned Aircraft System 

SUASs are oftentimes seen as superior to helicopters due to the smaller devices cheaper equipment and personnel cost, reduced noise and as 

such, a much smaller environmental impact which promotes public safety. 

We are petitioning for exemption to enable Intelligent Corporate Solutions, LLC to operate a DJI Inspire 1 equipped with three-axis gimbals 

and using High-Def. cameras. This SUAS has a built- in capability to limit the height it flies above the ground, to limit the radius of the 

distance it flies from the operator and to exclude it from Class B, C and D airspace including a no fly zone feature. The Inspire 1 also has the 

failsafe function of the Naza-M autopilot system, which means when the communication between the Main Controller and the transmitter is 

disconnected, the outputs of all command sticks from controller will go to the center position. If the GPS signal is good enough, the system 

will automatically trigger Return to Home and will land safely. 

The above specifications meet with the Model Aircraft Operating Standards as set below:

• Intelligent Corporate Solutions, LLC will only operate its SUAS in line of sight of a pilot and/or observer and will operate at sites 

that are a 'sufficient distance' from populated areas within the sterile 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." 

• When flying SUAS within 3 miles of an airport, airport operators will be notified and the operator will give the right of way to avoid 

flying in the proximity of full-scale aircraft. 

• Maximum flight time for each operational flight will be 30 minutes.

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

• The SUAS will be programmed so that it will not be operated at an altitude of no more than 400 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 SUAS Pilot, and Visual Observer.

• The SUAS operated by the petitioner weighs less than 55 pounds, including the payload (i.e. camera, lens, and gimbal).

• The SUAS will operate at speeds of no more than 50 knots, can hover, and can simultaneously move vertically and horizontally.

• Given the small size of the SUAS and the restricted sterile environment within which they will operate, our SUAS operations 

adhere to the Reform Act's safety requirements.

The UA, 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 death 

or serious bodily injury. With a small payload and maximum flight time of only 20 minutes, this 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 applicants in the past have chartered 2-seat full-sized helicopters for this 

purpose, which has proven more costly than many potential clients have been able to afford. 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. 

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. 

a. No flight will be made with a Gross weight exceeding 55 pounds; 

b. All operations must occur in FAA Class G airspace at no more than 400 ft. AGL, at an airspeed of no more than 25 knots and no 

further than 3/4 NM from the PIC; 

c. All operations must utilize a visual observer (VO). The VO and PIC must be able to communicate by voice at all times during a 

flight operation;

d. Operations will be restricted to flights over private property with the permission of the property owner; 

e. All required permits will be obtained from state and local government prior to operation;

f. Intelligent Corporate Solutions, LLC will not operate over densely populated areas; 

g. Intelligent Corporate Solutions, LLC will not be operating over any open-air assembly of people;
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h. Intelligent Corporate Solutions, LLC will not be operating over heavily trafficked roads;

i. Intelligent Corporate Solutions, LLC will not be operating within 5 NM of an airport or heliport; 

We respectfully request exemption under Section 333 to enable Intelligent Corporate Solutions, LLC to operate efficient, limited, low-risk 

commercial SAUS operations for the activities stated respecting at all times the space and privacy of citizens and property whilst keeping our 

skies safe. 

Sincerely,

Joseph Toth

Intelligent Corporate Solutions, LLC

www.intelligentcorporatesolutions.com

joseph@intelligentcorporatesolutions.com

717-796-5920
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EXEMPTION REQUESTS AND EQUIVALENT LEVEL OF SAFETY 

Intelligent Corporate Solutions, LLC requests an exemption from the following regulations as well as any additional regulations that may 

technically apply to the operation of the SUAS System: 

14 CFR Part 21, Airworthiness Certificates 

This part establishes the procedures for the issuance of an airworthiness certificate. While the FAA continues to work to develop 

airworthiness standards for Unmanned Aerial Systems, we request an experimental certificate be issued for the DJI Inspire 1 under either or 

both of the following provisions: 

21.191 Experimental certificates. Experimental certificates are issued for the following purposes: 

a. Research and development. Testing new aircraft design concepts, new aircraft equipment, new aircraft installations, new aircraft 

operating techniques, or new uses for aircraft.

b. Showing compliance with regulations. Conducting flight tests and other operations to show compliance with the airworthiness 

regulations including flights to show compliance for issuance of type and supplemental type certificates, flights to substantiate major 

design changes, and flights to show compliance with the function and reliability requirements of the regulations. Since the 

experimental certificate can be used for commercial purposes such as market surveys, sales demonstrations, and customer crew 

training, we would expect that an experimental certificate would permit our commercial purpose as well. The aircraft will not carry 

persons or property, will not carry fuel, and will only fly under strict operational requirements. Combined with the UA's lightweight, 

being constructed primarily of carbon fiber and plastic, we propose that the UA will be at least as safe, if not safer, than a 

conventionally certificated aircraft performing the same mission. If an experimental airworthiness certificate is not appropriate for 

this application, then we request an exemption of 14 CFR Part 21, Subpart H, and the requirement for an airworthiness certificate in 

general, citing the equivalent level of safety outlined in the previous paragraph. 

14 CFR 45.23 Display of marks; general and 45.29 Size of marks. These regulations provide that each aircraft must display "N" and the 

aircraft's registration number in letters at least 3 inches high. Additionally, the aircraft must display the word "EXPERIMENTAL" in letters at 

least 2 inches high near the entrance to the cabin, cockpit, or pilot station. The SUAS does not have an entrance in which the word 

"EXPERIMENTAL" can be placed, and may not have a registration number assigned to it by the FAA. We propose to achieve an equivalent 

level of safety by including the word "EXPERIMENTAL" in the placard on the top of the aircraft, as shown above, where the PIC (Pilot In 

Control), VO (Visual Observer) and others in the vicinity of the aircraft while it is preparing for launch will be able to see the designation. 

Additionally, we feel that the permanent placard discussed in the previous paragraph will provide the aircraft's registration information at the 

ground station. Finally, we will display at the ground station a high contrast flag or banner that contains the words "Unmanned Aircraft 

Ground Station" in letters 3 inches high or greater. Since the aircraft will operate within 3/4 NM of the ground station, the banner should be 

visible to anyone that observes the aircraft and chooses to investigate its point of origin. 

14 CFR 61.113 Private pilot privileges and limitations: Pilot in Command and 61.133 Commercial pilot privileges and limitations. The 

regulation provides that no person that holds a Private Pilot certificate may act as pilot in Command of an aircraft for compensation or hire. 

Subparagraph (b) allows a private pilot to act as pilot in command of an aircraft in connection with any business or employment if: (1) The 

flight is only incidental to that business or employment; and (2) The aircraft does not carry passengers or property for compensation or hire. 

Our proposed operations require that the PIC must hold at least a Recreational Pilot Certificate issued by the FAA and since the aircraft 

cannot carry passengers or property, we feel we meet the intent of 61.113 Subparagraph (b) even though the intent of this application is to 

conduct a business. 

14 CFR 91.7 Prohibits the Operation of an aircraft without an airworthiness certificate. As no such certificate will be applicable in the 

form contemplated by the FARs, this Regulation is inapplicable. 

14 CFR 91.9 Civil aircraft flight manual, marking, and placard requirements. This regulation provides that no person may operate an 

aircraft unless a current, approved flight manual is in the aircraft. We assume that the intent of this requirement is to ensure that flight manual 

information is available to the aircrew while operating the aircraft. We request an exemption to this requirement since the aircraft is not only 

too small to carry documentation, the documentation would not be available to the crew during flight operations. To obtain an equivalent 

level of safety and meet the intent of 91.9, we propose that a current, approved SUAS Flight Manual must be available to the crew at the 

ground station anytime the aircraft is in, or preparing for, flight. 

14 CFR 91.109 Flight Instruction; Simulated instrument flight and certain flight tests. The regulation states, "No person may operate a 

civil aircraft that is being used for flight instruction unless that aircraft has fully functioning dual controls." The SUAS System ground- based 

control station consists of a small hand-held radio transmitter and while it does not offer a second set of "controls", both the student and 

instructor can, and will, operate the single set of controls simultaneously. With both student and instructor having "hands-on" the controls 

during flight, we feel that this technique meets the intent 91.109 and provides an equivalent level of safety. 

91.119 Minimum safe altitudes: General. The regulation states that over sparsely populated areas the aircraft cannot be operated closer than 
5

500 feet to any person, vessel, vehicle, or structure. Since the typical mission of the SUAS would be photography or survey of persons, vessels, 

vehicles or structures it would be necessary to operate closer than 500 feet to the items listed. Operations will only be flown over property or 

persons where permission has been obtained and careful pre-flight planning has been performed. The aircraft will be operated at a low altitude 

allowing, if a power unit fails, an emergency landing without undue hazard to persons or property on the surface. Therefore we maintain that 

due to the small size of the UAS, the hazard to persons, vehicles and structures is minimal compared to manned aircraft, which should be 

considered in granting the exemption. 

CFR 91.121 Altimeter settings. The regulation requires that aircraft shall maintain cruising altitudes by reference to an altimeter setting 

available within 100 NM of the aircraft. The SUAS will always fly below 400 feet AGL and will not need to maintain cruising altitudes in 

order to prevent conflict with other aircraft. An Above Ground Level altimeter measurement above the launch and recovery point is 

transmitted via radio from the SUAS on-board computer to the display screen held by the PIC, providing a constantly updated AGL readout. 

14 CFR 91.151 Fuel requirements for flight in VFR conditions. The regulation provides that no person may begin a flight in an airplane 

under day-VFR conditions unless there is enough fuel to fly to the first point of intended landing and to fly after that for at least 30 minutes. 

We feel the intention of this paragraph is to provide an energy reserve as a safety buffer for delays to landing. The SUAV is battery operated 

and the maximum duration of flight from a single battery charge is 12 minutes with a 20% reserve. Since the aircraft will never fly more than 

3f4 NM from the point of intended landing, a full battery charge at launch will ensure that we meet the reserve energy requirement of this 

paragraph. We request an exemption to the word "fuel" and ask for an equivalent interpretation with the word "energy". 

14 CFR 91.203(a) & (b) Civil aircraft: Certifications required. The regulation provides that an airworthiness certificate, with the registration 

number assigned to the aircraft and a registration certificate must be aboard the aircraft. Additionally, subparagraph (b) provides that the 

airworthiness certificate be "displayed at the cabin or cockpit entrance so that it is legible to passengers or crew." At a maximum gross weight 

of 5.3 pounds, the SUAS is too small to carry documentation, does not have an entrance, and is not capable of carrying passengers or crew. 

To obtain an equivalent level of safety and meet the intent of 91.203, we propose that documents deemed appropriate for this aircraft by the 

FAA will be co-located with the crew at the ground control station and available for inspection upon request. In order to identify the aircraft, 

we propose that the information found on airworthiness and registration certificates be permanently affixed to the aircraft via placard 

containing the following information plus the word "EXPERIMENTAL" to satisfy the requirement of 14 CFR 45.23. 

14 CFR Subpart E (91.401- 91.417) - Maintenance, Preventive Maintenance, Alterations The regulation provides that the operator is 

primarily responsible for maintaining the aircraft in an airworthy condition, including compliance with part 39 and 43. Paragraphs 91.407 and 

91.409 require that the aircraft be "approved for return to service by a person authorized under 43.7" after maintenance and inspection. It is 

our intention that the PIC perform maintenance and inspection of the aircraft and "be authorized to approve the aircraft for return to service." 

The PIC will ensure that the aircraft is in an airworthy condition prior to every flight and in addition conduct detailed inspections after every 

two hours of flight. Maintenance performed by the PIC is limited to repairing small cracks, replacing a propeller, checking electrical 

connections and updating software and firmware for the on-board computer. All other maintenance will be performed by the manufacturer or 

their designated repair facility. The PIC will document work performed in accordance with 91.417. We feel that due to the size, construction, 

and simplicity of the aircraft, the PIC can ensure an equivalent level of safety. 

Safety and Benefits of the UAS 

Intelligent Corporate Solutions, LLC will be using the SUAS in a variety of applications that generally require expensive full-size manned 

aircraft to complete. Small, light, unmanned aerial vehicles offer 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 Intelligent Corporate Solutions, LLC 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. Intelligent Corporate Solutions, 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 SUASs which our company would use, under authorization by the US DOT-FAA, are small, lightweight devices operated within the line of sight of the Pilot-in-Command (PIC), less than 400 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 SUASs 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 of SUAs such as ours. 

For the foregoing reasons, the exemptions requested herein should be granted and Intelligent Corporate Solutions, 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 SUASs may be used for legitimate commercial activities and under reasonably safe conditions. 
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8 Redstone Ct. Mechanicsburg, PA 17050

E-Mail: joseph@intelligentcorporatesolutions.com

Web: www.intelligentcorporatesolutions.com

Phone: 717-796-5920