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February 10, 2016

Good Drones LLC

202 Meserole Street, Suite 1

Brooklyn, NY 11206

(516) 263-5690 | Goodrones@gmail.com

U.S. Department of Transportation

Docket Management System

1200 New Jersey Avenue, SE

Washington, DC 20590

RE: Petition of Good Drones LLC for Exemption Pursuant to Section 333 of the 

FAA Modernization and Reform Act of 2012 and Part 11 of the Federal Aviation 

Regulations

Dear Sir or Madam:

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

and 14 CFR Part 11, Good Drones LLC hereby applies for an exemption from the Federal 

Aviation Regulations (“FARs”), identified below, to allow commercial operations of small 

unmanned aircraft systems (“UASs”). This exemption accords with protocols published by the 

Federal Aviation Administration (FAA), the enclosed UAS manufacturer’s operations and 

instructions manuals, the UAS quick start guides, and any other requirement established by the 

FAA.

As described more fully below, the requested exemption would permit commercial operation by 

Good Drones LLC (“Good Drones”) to conduct UAS education, humanitarian work, 

communication, photography, videography and film production, and geographical surveying

under controlled conditions in airspace that are (1) limited, (2) predetermined, and (3) controlled 

as to access. Moreover, Good Drones’ operation, under the exemption, will be subject to strict 

operating requirements and conditions to ensure an equivalent level of safety to currently 

authorized operation using manned aircraft and under conditions as may be modified by the FAA 

as required by Section 333. Good Drones respectfully requests that any part deemed not in 

compliance be removed and the remaining portion of this request be processed as applicable.

Additionally, the FAA issued Mehdi Salehi, CEO of Good Drones, a “sUAS Certificate of 

Registration” on December 21, 2015, certificate number FA334ML943.
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Good Drones has organized this exemption request as follows:

I. Petitioner’s Description 2

II. Relevant Statutory Authority 3

III. Qualifications for Approval Under Section 333 of the Reform Act 3

IV. Description of Proposed Operations 4

V. Regulations from Which Exemption is Requested 6

VI. Public Interest 12

VII. Federal Registry Summary 12

VIII. Conclusion 13

I. Petitioner’s Description

Good Drones LLC, headquartered in Brooklyn, New York, is a company that leverages drone 

technology to improve lives. To fulfill this mission, Good Drones provides drone education and 

develops technical solutions to humanitarian crises. For example, Good Drones is developing a 

real-time monitoring and data-sharing platform to ensure the safe arrival of refugees to the Greek 

Island of Lesbos. Further, Good Drones undertakes environmental monitoring through aerial 

photography and videography; supports research, design, and innovation; and, performs aerial 

filming for site inspections. Good Drones has also created a drone affixed with a screen for 

communication and advertisement applications.

Mehdi Salehi, Co-Founder and CEO, has been a leader in the application of drone technology to 

today’s most pressing problems as an Adjunct Professor at Parsons Design and Technology

Program at The New School in New York. He teaches masters-level classes on drone 

technology, where students conceptualize and execute socially beneficial projects with drone 

technology. This spring 2016 semester, students focus on projects related to environmental 

mapping to create 3D models, virtual reality spaces, and 3D-printed scale models. 

Good Drones’ goal is to operate in an accident-free environment by:

• Demonstrating a commitment by management and all employees to operate in a 

compliant manner;

• Identifying hazards and risks, while eliminating or controlling all these risks; and,

• Training all employees involved in flight operations to operate at the highest standard 

level.

The contact information for Petitioner follows:

Good Drones LLC

202 Meserole Street, Suite 1

Brooklyn, NY 11206

Mehdi Salehi, Co-Founder

Email: Mehdi@goodrones.com

Tel.: (516) 263-5690
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II. Relevant Statutory Authority

This petition for exemption is submitted to fulfill Congress’s goal in passing Sections 333(a)-(c) 

of the Reform Act. Congress directed the FAA “to safely accelerate the integration of civil 

unmanned aircraft systems into the national airspace system.” Reform Act § 332(a). Pursuant to 

that section, the Secretary of Transportation considers whether certain UAS may operate safely 

in the national airspace system (“NAS”), before completion of the formal UAS rulemaking under 

Section 332 of the Reform Act. The Secretary must determine which types of UASs do not 

create a hazard to NAS users or to the public or pose a threat to national security based on: (1) 

the UAS’s size, weight, speed, and operational capacity; (2) operation of the UAS in close 

proximity to airports and populated areas; and, (3) operation of he UAS within the visual line of 

sight of the operator. § 333(a), (b)(1). 

If the Secretary determines that such vehicles “may operate safely in the National Airspace 

System, the Secretary shall establish requirements for the safe operation of such aircraft in the 

National Airspace System.” § 333(c) (emphasis added).1

The Federal Aviation Act expressly grants the FAA the authority to issue exemptions. This 

statutory authority, by its terms, includes exempting civil aircraft, as defined under Section 

40101 of the Act, from the requirement that all civil aircraft have a current airworthiness 

certificate and from those regulations requiring commercial pilots to operate aircraft in 

commercial service. See 49 U.S.C. § 44701(f) (“The Administrator may grant an exemption from 

a requirement of a regulation prescribed under subsection (a) or (b) of this section or any of 

sections 44702–44716 of this title if the Administrator finds the exemption is in the public 

interest.”).

III. Qualifications for Approval

The proposed operations in this petition for exemption qualify for approval. Each of the statutory 

criteria and other relevant factors are satisfied.

The proposed operations would permit Good Drones to use its UASs under controlled conditions 

in airspace that are (1) predetermined and (2) controlled as to access as well as (3) provide an 

increased level of safety beyond that of existing fixed- or rotor-wing employed to accomplish the 

same purpose.

Good Drones’ UASs are rotorcraft, weighing 55 lbs or less, including payload. Specifically, 

Good Drones operates two commercially available models: Phantom 3 Professional, 

manufactured by DJI, and Inspire 1, also manufactured by DJI. The UASs operate, under normal 

conditions at a speed no more than 50 knots. They have the capability to hover and move in the 

vertical and horizontal planes. They will operate in line of sight, during daylight hours, and 

!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!! 1 Good Drones interprets this provision to place a duty on the Administrator to both process applications 

for exemptions as well as to craft conditions for the safe operation of the UAS. If the Administrator 

deems the conditions proposed herein require modification to permit approval for an exemption under 

Section 333, Good Drones welcomes the opportunity to consult with FAA staff to address issues or 

concerns this proposal may raise and thus may require modification.
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within an area described in the enclosed Manufacturers’ Operations Manuals (the “Manuals”), 

attached as Exhibit 1. Further, the UASs will operate at or below 400 feet above ground level,

and Good Drones will file a Notice to Airmen (NOTAM) for each flight operated in controlled 

airspace, as required. Such operations will ensure that the UASs will “not create a hazard to users 

of the national airspace system or the public.” Reform Act § 333(b).

Given the small size of UASs involved and the restricted environment within which they will 

operate, Good Drones’ flights would achieve an equivalent level of safety to that envisioned by 

Congress, whereby the FAA must, by exemption, allow commercial operations of UASs to 

commence, pending completion of formal rulemaking. Given the clear direction of Section 333 

of the Reform Act, the authority conferred under the Federal Aviation Act, the equivalent level 

of safety surrounding Good Drones’ proposed operations, and the significant public benefit, the 

grant of the requested exemption would be within the public interest. 

IV. Description of Proposed Operations

The enclosed Manuals describe, in detail, the policies and procedures for Good Drones’ 

proposed UAS operations. To assist the FAA in its safety assessment, below is a summary of 

operational limits and conditions that will ensure an equivalent or higher level of safety to 

operations conduced under current regulatory guidelines:

(1) The UAS will weigh 55 lbs or less.

(2) Flights will be operated within line of sight of the Operator.

(3) Maximum total flight time will be limited to the amount of time the UAS may be flown 

and still maintain a reserve battery power of no les than 25%.

(4) Flights will be operated at an altitude of no more than 500 feet above ground level or no 

more than 200 feet above an elevated platform from which flying is planned.

(5) Flights will be operated at a safe lateral distance from any inhabited structures, buildings, 

vehicles, vessels, or people not associated with the operation or who have not signed a 

waiver or assented to an oral waiver in advance of the operation.

(6) The UAS Pilot with Pilot in Command responsibilities for the flight will be the 

designated “Operator”). 

(7) The Operator will have been trained in the operations of the UAS generally and received 

up-to-date information on the particular UAS to be operated, as detailed in the Manuals.

(8) The UAS will operate only within a confined area described in the Manuals.

(9) A briefing will be conducted as to the planned UAS operations prior to each day’s 

activities. It will be mandatory that all personnel who will be performing duties within 

the confined area be present.

(10) All UASs will be maintained in accordance with the inspection program specified in 

Good Drones’ Manuals and in compliance with the manufacturer’s guidelines.

(11) All required permissions and permits will be obtained from territorial, state, county, or 

city jurisdictions, including local law enforcement, fire, or other appropriate 

governmental agencies.
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(12) If the UAS loses communications sight, the UAS will have the capability to return to a 

predetermined location to land.

(13) The UAS has the capability to abort a flight in case of unpredicted obstacles or 

emergencies.

Further, Good Drones will control the UASs with transmitters that comply with Part 15 of 

Federal Communication Commission rules. Good Drones’ UAS radio transmitters are compliant 

with regulations governing radio transmitters in the 2.400GHz to 2.4835GHz frequency range. 

When operating transmitters, the Operator will maintain a separation distance of at least 5 cm 

between his body and the antenna.

V. Regulations from Which Exemption is Requested

Good Drones seeks relief from the following requirements of Part 11 of the Federal Aviation 

Regulations:

14 CFR Part 21, Subpart H

14 CFR § 45.23(b)

14 CFR § 61.113 (a), (b)

14 CFR § 91.7

14 CFR § 91.205(a), (b), (c)

14 CFR §§ 91.405(a); 91.407(a)(1); 91.407(a)(2); 91.417(a), (b)

14 CFR § 91.203(a), (b)

14 CFR § 91.151(a)

14 CFR § 91.121

14 CFR § 91.119

14 CFR § 91.109

14 CFR § 91.103

14 CFR § 91.9(b)(2)
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A. 14 CFR Part 21, Subpart H: Airworthiness Certificates

Subpart H established procedural requirements for the issuance of airworthiness certificates as 

required by FAR § 91.203(a)(1). Provided the size and limited operating area associated with the 

aircraft to be used by Good Drones, an exemption from this subpart meets the requirements of an 

equivalent level of safety under Part 11of the FAR and Section 333 of the Reform Act. The latter 

along with 49 U.S.C. § 44701(f) authorize the FAA to exempt aircraft from the requirement of 

an airworthiness certificate, upon consideration of the size, weight, speed, operational capability, 

and proximity to airports and populated areas. In all cases, the UAS operated without an 

airworthiness certificate in a restricted environment and under fixed conditions proposed will be 

at least as safe, or safer, than a conventional aircraft operating with such a certification but 

without such proposed restrictions and conditions.

Equivalent Level of Safety

The UASs to be operated weigh 55 lbs or less, fully loaded, carry neither pilot nor passengers, 

carry no explosive materials or flammable liquid fuels, and operate exclusively within a 

predetermined area. Unlike other civil aircraft, operations under this exemption will be tightly 

controlled and monitored by the Operator, pursuant to the Manuals, 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 CFR Part 21, Subpart H. Lastly, application of these same criteria 

demonstrates there is no credible threat to national security posed by the UAS due to its size, 

speed of operation, location of operation, lac of explosive or flammable materials, and inability

to carry a substantial load.

B. 14 CFR § 45.23(b): Marking of the Aircraft

Under 14 CFR § 45.23(b), an aircraft must be marked as follows:

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.

Although Good Drones’ UAS will lack an airworthiness certificate, an exemption may be 

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

write. Further, given the small size of the UAS, two-inch lettering will be impossible.

Equivalent Level of Safety

To assure an equivalent level of safety, the UAS will be identified by serial number, registered in 

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

accordance with 14 CFR Part 45, Subpart C, which will be made as large as practicable. 
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C. 14 CFR § 61.113 (a), (b): Private Pilot Privileges and Limitations: Pilot in 

Command

Sections 61.113 (a) and (b) limit private pilots to non-commercial operations. 

Equivalent Level of Safety

Good Drones submits that the proposed operations can achieve the equivalent level of safety by 

requiring the Operator to have a private pilot’s license rather than a commercial pilot’s license. 

Unlike a conventional aircraft that carries a pilot, passengers, and cargo, UASs are remotely 

controlled with neither passengers nor cargo on board. The area of operation is controlled and 

restricted, and all flights are planned and coordinated in advance, as set forth in the Manuals. The 

risks associated with the operation of the UAS are diminished from the level of risk associated 

with commercial operations contemplated by Part 61. The operations of the UAS with a private 

pilot license, as requested, exceeds the present level of safety achieved by 14 CFR § 61.113 (a) 

and (b).

D. 14 CFR § 91.7: Civil Aircraft Airworthiness

Under 14 CFR § 91.7, no person may operate a civil aircraft unless it is in airworthy condition. 

To the extent that there will be no airworthiness certificate issued for UAS, should this request 

for exemption be granted, no FAA regulatory standard will exist to determine airworthiness.

Equivalent Level of Safety

Should Good Drones’ request for an exemption from an airworthiness certificate be granted, no 

FAA regulatory standard will exist to determine airworthiness. Considering the small size of the 

aircraft and requirements contained in the Manuals as to maintenance and use of pre-flight safety 

checklists, an equivalent level of safety will be provided. 

The FAA has issued exemptions to this regulation, including Exemption Nos. 9299A, 10700, and 

32827.

E. 14 CFR § 91.9(b)(2): Civil Aircraft Flight Manual in the Aircraft

Section 91.9(b)(2) of the FAR provides: 

No person may operate a U.S.-registered civil aircraft . . . [f]or 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.
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Equivalent Level of Safety

Given the size of Good Drones’ UASs, configuration, and load capacity, the UASs have no place 

to carry such a flight manual on the aircraft. Instead, an equivalent level of safety will be 

maintained by keeping the Manuals at a ground control point where the Operator will have 

immediate access. 

The FAA has issued exemptions to this regulation, including Exemption Nos. 8737, 32827, and 

111333 (“documents required under 14 CFR §§ 91.9 and 91.203 must be available to the PIC

[“Pilot in Command,” or Operator] at the Ground Control Station of the UAS any time the 

aircraft is operating.”).

F. 14 CFR § 91.103: Preflight Action

Section § 91.103 requires each Pilot in Command (“PIC”) to take certain actions before flight to 

ensure flight safety, including that the PIC must familiarize him or herself with takeoff and 

landing data in an “approved Airplane or Rotorcraft Flight Manual.” See 14 CFR § 91.103(b)(1).

Equivalent Level of Safety

Should Good Drones’ request for an exemption from storing a flight manual in the UAS be 

granted, an exemption under 14 CFR § 91.103 is necessary. An equivalent level of safety will be 

achieved by following the Manuals, and the Operator will take all required preflight actions—

including reviewing weather data, landing and takeoff distance, and aircraft performance data—

before flight. Further, the Manual will be kept at a ground control point where the Operator will 

have immediate access.

G. 14 CFR § 91.109: Flight Instruction

Section § 91.109 provides that no person may operate a civil aircraft used for flight instruction 

unless that aircraft has fully functioning dual controls.

Equivalent Level of Safety

By their design, UAS lack fully functional dual controls. Instead, flight control is accomplished 

through the use of a control box that communications with the aircraft via radio transmission. 

The equivalent level of safety may be assured since an UAS carries neither pilot nor passengers 

and in light of its size and speed. The FAA has approved exemptions for flight training without 

fully functional dual controls for aircraft and for flight instruction in experimental aircraft. See, 

e.g., Exemption Nos. 5778K, 9862A.

H. 14 CFR § 91.119: Minimum Safe Altitudes

Good Drones requests an exemption from the minimum safe altitude requirement, prescribed 

under 14 CFR § 91.119. Specifically, the provision sets out:
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Except when necessary for takeoff or landing, no person may operate an aircraft below 

the following altitudes:

(a) Anywhere. An altitude allowing, if a power unit fails, an emergency landing without 

undue hazard to persons or property on the surface.

(b) Over congested areas. Over any congested area of a city, town, or settlement, or over 

any open air assembly of persons, an altitude of 1,000 feet above the highest obstacle 

within a horizontal radius of 2,000 feet of the aircraft.

(c) Over other than congested areas. An altitude of 500 feet above the surface, except 

over open water or sparsely populated areas. In those cases, the aircraft may not be 

operated closer than 500 feet to any person, vessel, vehicle, or structure.

However, helicopters may operate at less than the minimums when it can be done “without 

hazard to persons or property on the surface,” provided that each helicopter operator complies 

with any routes or altitudes the FAA specifically prescribed. 

Equivalent Level of Safety

As this exemption requests authority to operate an UAS at altitudes up to 500 feet above ground 

level and not more than 200 feet above an elevated platform from which filming is planned, an 

exemption is necessary to allow such operations. 

Compared to flight of normal aircraft, Good Drones’ UAS weigh 55 lbs or less, and given the 

lack of flammable fuel, any risk associated with these operations is far less than those that 

presently exist with conventional aircraft. An equivalent level of safety will be achieved given 

the size, weight, and speed of the UAS, as well as the location where it is operated. As set forth 

in the Manuals, the sUAS will be operated in a predetermined area, where buildings and people 

will not be exposed to operations without their pre-obtained consent. Because of the advance 

notice to the property owners and participants, all affected individuals will be well aware of the 

planned flight operations as set forth in the Manuals. Furthermore, by operating at such lower 

altitudes, the UAS will not interfere with aircraft that are subject to the minimum safe altitude 

regulations.

I. 14 CFR § 91.121: Altimeter Settings

Good Drones seeks an exemption from 14 CFR 91.121, which requires a person operating an

aircraft to maintain cruising altitude or flight level by reference to an altimeter that is set to the 

elevation of the departure airport or barometric pressure. An exemption is required because the 

UAS does not have a barometric altimeter but a GPS altitude indicator.

Equivalent Level of Safety

An equivalent level of safety will be achieved by following the procedures set forth in the 

Manuals. Good Drones will confirm the altitude of the launch site shown on the GPS altitude 

indicator before flight. Moreover, the Operator will use the GPS altitude indicator to constantly 

monitor the UAS's altitude, thus ensuring operation at safe altitudes.
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J. 14 CFR § 91.151(a): Fuel Requirements for Flight in VFR Conditions

Good Drones requests an exemption from 14 CFR 91.151(a)’s fuel requirements for flight in 

VFR conditions. That provision states:

(a) No person may begin 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 batteries powering Good Drones’ UAS Inspire 1 provide 18 minutes of maximum of 

powered flight time and UAS Phantom 3 23 minutes maximum of powered flight. To meet the 

30-minute reserve requirement, UAS flights would be limited to approximately 10 minutes in 

length. Given the limitations on the UAS’s flight area and location of its operations within a 

predetermined area, a safety margin based on a reserve amount of battery life is needed.

Equivalent Level of Safety

An equivalent level of safety will be achieved because the operations will be conducted on-site 

without significant transit time by the UAS. All flights will be planned to terminate with no less 

than 25% reserve battery power still available. This restriction would be more than adequate to 

return the UAS safely to its planned landing zone from anywhere in its confined area of 

operation even in the event of an unexpected occurrence. Operation of the UAS with less than 30 

minutes of reserve fuel does not include the type of risks Section 91.151(a) was intended to 

alleviate, provided the size and speed of the small UAS as well as the proximity of the flight 

operation to the landing zone. Moreover, operation will be limited to controlled areas where only 

people and property owners who have signed waivers will be allowed.

K. 14 CFR § 91.203(a), (b): Carrying Aircraft Certification and Registration

Pursuant to 14 CFR § 91.203(a) and (b), for one to operate a civil aircraft, that aircraft must have 

“an appropriate airworthiness certificate . . . . displayed at the cabin or cockpit entrance so that is 

legible to passengers or crew.” The UAS, provided its weight of less than 55 lbs. and its 

operation without a pilot onboard, has no ability or place to carry certification and registration 

documents.

Equivalent Level of Safety

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

point where the Operator will have immediate access, to the extent that these documents are 

applicable to the UAS.

The FAA has issued exemptions to this regulation, including Exemption Nos. 9565, 9789, and 

10700.
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L. 14 CFR §§ 91.405(a); 91.407(a)(1); 91.407(a)(2); 91.417(a), (b): Maintenance 

Inspections

Good Drones also seeks an exemption from the maintenance inspection requirements contained

in 14 CFR §§ 91.405(a), 91.407(a)(1), 91.409(a)(2), 91.417(a) and (b), which specify 

maintenance and inspection standards with reference to 14 CFR Part 43. These sections and Part 

43 apply only to aircraft with an airworthiness certificate, and, as such, do not apply to Good 

Drones.

Equivalent Level of Safety

An equivalent level of safety will be achieved because maintenance and inspections will be 

performed pursuant to the Manuals. As detailed in the Manuals, the Operator will ensure the

UAS is in working order prior to flight, perform required maintenance, and keep a log of any 

maintenance performed. 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.

If mechanical issues arise, the UASs’ size and carrying capacity as well as the fact flight

operations will only take place in restricted areas for limited periods of time during daylight 

hours creates less risk than that associated with conventional rotorcraft performing the same 

operation.

M. 14 CFR § 91.205(a), (b), (c): Instrument and Equipment Requirements

Section 91.305 provides a minimum set of instruments and equipment required for day and night 

VFR flight for civil aircraft with an airworthiness certificate.

Equivalent Level of Safety 

Should Good Drones’ request for an exemption from an airworthiness certificate be granted, an 

exemption under 14 CFR § 91.205 is also necessary. Further, due to the small size of Good 

Drones’ UASs, it would be impossible to carry many of the instruments required under Section 

91.205(b) and (c). Nonetheless, an equivalent level of safety may be achieved by visual contact 

with the UAS and indications provided via the controller. The Manuals further delineate the 

means by which critical UAS flight information may be monitored, including GPS, battery 

reserve, and airspeed.
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VI. Public Interest

Granting Good Drones an exemption furthers the public interest. National policy set by Congress 

favors early integration of UAS into the NAS in controlled, safe working environments, such as 

those proposed in this petition. Good Drones aims to help facilitate safe integration of UAS into 

mainstream use in the following areas:

• Education

• Humanitarian Work

• Environment

• Aerial Video and Photographs

• Site-Inspections

• Real Estate

• Media and Advertising

Further, the use of UASs for aerial data collection for the aforementioned purposes, be it 

photography or videography, addresses the common public concern of safety, since the operation 

of UASs, as described herein, is controlled and pre-determined. An unforeseen UAS incident

causes less disruption than traditional aircraft.

Such use of aerial data collection with UAS, rather than manned aircraft, also mitigates noise and 

pollution public concerns. By using batter power, the UAS produces no air pollution, and UASs 

are the most environmentally conscious alternative to piston or turbine powered rotorcraft. UASs 

also eliminate noise pollution as its battery-powered motors are barely audible during takeoff 

phase, and a UAS cannot be heard when operating more than 100 feet above ground level.

Substantial risk to life and property in the air and on the ground, often associated with traditional 

manned aircraft operations, is either substantially reduced or completely eliminated through the 

use of UAS to conduct aerial data collection. The small size and weight, with the lack of onboard 

crew, creates less physical potential for collateral damage to life and property on the ground and 

in the air. The UAS contains no reactive or combustible materials, substantially diminishing the 

risk of fire or explosions.

Above all, granting this exemption will help the FAA devise future rules regarding UAS 

operations, maintenance, and crew qualification. The exemption will help advance knowledge in 

the burgeoning field of commercial UAS operations.

VII. Federal Register Summary

Pursuant to 14 CFR Part 11, the following summary is provided for publication in the Federal 

Register:

Good Drones LLC seeks an exemption from the following rules:

14 CFR Part 21, Subpart H; 14 CFR § 45.23(b); 14 CFR § 61.113 (a), (b); 14 CFR § 91.7; 14 

CFR § 91.205(a), (b), (c); 14 CFR §§ 91.405(a); 91.407(a)(1); 91.407(a)(2); 91.417(a), (b); 14 

CFR § 91.203(a), (b); 14 CFR § 91.151(a); 14 CFR § 91.121; 14 CFR § 91.119; 14 CFR § 

91.109; 14 CFR § 91.103; 14 CFR § 91.9(b)(2).
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Approval of this exemption request allows Good Drones to conduct commercial operations with 

small and lightweight unmanned aerial systems, weighing 55 lbs or less and powered by 

batteries. Good Drones leverages drone technology to find solutions to pressing social problems, 

and it will conduct UAS operations to promote education, assist in humanitarian response, 

monitor the environment, and promote communication. In general UAS operations are intended 

to be conducted away from congested areas and airports. The UASs will carry neither passengers 

nor crew and, therefore, will not expose them to the risks associated with manned aircraft flights.

The operation of small UASs, conducted in the strict conditions outline above, will provide an 

equivalent level of safety supporting the grant of the exemptions requested herein. These 

lightweight aircraft operate at slow speed, close to the ground, and in a sterile environment and, 

as a result, achieve a high level of safety.

VIII. Conclusion

For the foregoing reasons, Good Drones requests the exemptions detailed herein. Satisfaction 

provided in Section 333 of the Reform Act of 2012—size, weight, speed, operating capabilities, 

proximity to airport and populated areas and operation within visual line of sight and national 

security—provide more than adequate justification for the grant of the requested exemptions, 

allowing commercial operation of Good Drones’ UASs.

Please do not hesitate to contact, should you have any questions and concerns.

Respectfully submitted,

Mehdi Salehi 

Co-Founder

Good Drones