Pristine	Line	Productions

Mohammad	Tomaleh

9250	Beloit	Ave	Unit	305

Bridgeview,	Il	60455

Tel:	708	513	0350 Email:	mtomaleh.film@gmail.com

RE,	requested	information	about	Exemption	333	Request	 Docket	No.	FAA-2015-

2989

Dear	Sir	or	Madam:

The	specific	section	or	sections	of	14	CFR	from	which	we	seek	an	exemption;

Petition	for	Exemption	under	Sec	333

The	extent	of	relief	we	seek	and	the	reason	we	seek	the	relief:	

Sec	333	prohibits	the	use	of	a	UAS	for	commercial	purposes	on	private	property.	we	

do	wedding	videography	and	photography	for	real	estate	agents	and	insurance	

agents	and	private	individuals.	I	am	simply	petitioning	for	an	exemption	to	provide	

a	commercial	service	to	private	land	owners	and	companies	who	wish	to	obtain	and	

capture	Aerial	photos	and	videos	of	said	property	for	purposes	including	real	estate	

listings,	insurance	property	claims,	and	for	use	as	a	marketing	tool	for	businesses.	I	

would	like	to	be	able	to	accept	payment	for	these	services	therefore	making	this	a	

commercial	use	of	a	UAS.

How	your	request	would	benefit	the	public	as	a	whole:

My	request	benefits	the	public	as	a	whole	by	providing	an	opportunity	for	small	
business	

owners,	real	estate	agents,	and	others	who	wish	to	document	their	land	or	property	

to	take	

advantage	of	the	technology	that	now	exists	in	the	form	of	UASs	and	allows	them	to	

do	so	

using	an	experienced	RC	Pilot	in	Command	that	understands	how	to	safely	operate	

such	technology.	

Reasons	why	the	exemption	would	not	adversely	affect	safety,	or	how	the	

exemption	would	provide	a	level	of	safety	at	least	equal	to	the	existing	rule:

Being	informed	and	aware	of	the	FAA	rules	regarding	UAS	flights,	safety	and	privacy	

issues	I	can	and	will	operate	with	an	understanding	of	the	importance	of	different	

uses	and	safety	concerns	regarding	FAA	regulated	airspace,	I	would	be	a	good	

candidate	for	exemption	of	Sec	333	while	not	putting	Air	Safety	in	any	accelerated	

risk.

Any	additional	information,	views,	or	arguments	available	to	support	your	

request;	

I	am	fully	aware	of	the	pre	flight	safety	checks	and	procedures	implicated	in	the	

operation	

manual	for	the	DJI Phantom	3	Advanced and	intend	to	implement	pre	flight	safety	

checks	and	utilize	the	safety	technology	provided	with	this	unit.	I	intend	to	only	fly	

in	non	populated,	residential	or	rural	areas	and	stay	clear	of	all	utility	lines	etc.	I	

intend	to	be	fully	aware	of	my	surroundings	at	all	times	and	to	only	fly	the	
unmanned	aircraft	within	a	visual	line	of	sight	and	only	in	Visual	Flight	Conditions.

Pursuant	to	Section	333	of	the	FAA	Modernization	and	14	CFR	Part	11,	Mohammad				

Tomaleh,	operator	of	an	Unmanned

Aircraft	System	(UAS),	hereby	applies	for	an	exemption	from	the	listed	Federal	

Aviation	Regulations	(“FARs”)	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.

Commercial	operation	of	an	UAS,	as	described	herein,	which	are	equipped	with	

camera(s)	and	sensors,	would	operate	in	the	 following	manner:

• 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	or	donation.

• 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	of	the	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.

As	described	fully	below,	the	requested	exemption	would	permit	the	operation	of	a	

UAS	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	(the	FAA	

Administrator’s)	responsibilities	to	“....establish	requirements	for	the	safe	operation

of	such	aircraft	systems	in	the	national airspace	system.”

The	name	and	address	of	the	applicant	is:

Pristine	Line	Production

Attn: Mohammad	Tomaleh/Owner

Email: mtomaleh.film@gmail.com

Address: 9250	Beloit	Ave	Unit	305,	Bridgeview,	IL	60455

Regulations	from	which	the	exemption	is	requested:
14	CFR	Part	21	subpart	H

14	CFR	45.23	(b)

14	CFR	61.113	(a)	&	(b)

14	CFR	91.7	(a)

14	CFR	91.9	(b)	(2)

14	CFR	91.103

14	CFR	91.109

14	CFR	91.119	(c)

14	CFR	91.121

14	CFR	91.151	(a)

14	CFR	91.203	(a)	&	(b)

14	CFR	91.405	(a)

14	CFR	91.407	(a)	(1)

14	CFR	91.409	(a)	(2)

14	CFR	91.417	(a)	&	(b)

Pristine	Line,	will	operate	the	DJI	Phantom	3	Advanced,	with	a	total	weight	of	1280g	

or	2lbs	13	oz.	The	dimensions	are

40.36cm	x	40.36cm	x	19.05cm	or	16inch	x	16inch	x	7.5inch.

Under	still	air	the	maximum	speed	is	no	more	than	16m/s	or	35mph	with	a	cruising	

speed	of	11m/s	or	25mph.	

The	DJI	Phantom	3	Advanced	has	the	ability	to	hover	and	move	along	a	vertical	and	
horizontal	plane	simultaneously.

The	DJI	Phantom	3	Advanced	has	four	motors,	Motor	Model	DJI	W322,	powered	by	a	

4480mAh	4s	LiPo	Lithium	Polymer	

battery. There	are	four	propellers,	Propeller	Model	DJI	1345,	in use. The	DJI	

Phantom	3	Advanced	will	be	controlled	with	the

C3	remote	controller	with	an	operating	frequency	of	2.400GHz	– 2.483GHz. The	

live	video	feed	will	have	an	operating

frequency	of	2.4GHz	ISM	with	maximum	range	of	1.2	miles. The	applicant	will	

operate	the	UAS	in	line	of	sight	within	a	closed

off	and	predetermined	area	owned	and/operated	by	the	property	representative.

DJI	Phantom	3	Advanced	general	features:

• Ready	to	fly	

• 3-axis	camera	stabilization	

• Precision	flight	and	stable	hovering	

• GPS/GLONASS	positioning	&	auto	return	home	

• Onscreen	real-time	flight	parameters	

• High	Definition	2k	Camera.

• Camera	tilt	control	

• Film	straight	down	

• Supports	Adobe	DNG	RAW	

• Adobe	lens	profile	support	

• Camera	parameter	settings	

• Album	synchronization	
• FAA	no-fly	zones	locked	out	via	installed	software	transmitter.

• Operating	Frequency:2.400	GHz	– 2.483	GHz	

• Communication	Distance(open	area):	CE:	2000m;	FCC:	2000m	

• Receiver	Sensitivity(1%PER):-101dBm	+/- 2dBm

• Transmitter	Power:	CE:	16dBm;	FCC:	20dBm

• Working	Voltage:	1.2A	@	7.4V	

• Battery:	6000	mAh	LiPo	2s

• Operating	Environment	Temperature: 0°C-40°C

• FOV:	94°/	85°	

• Sensor	size:	1/2.3"	

• HD	Recording:	2k	p	24/25fps	/	720p	60fps	

DJI	VISION	APP:

• System	Requirement	of	Mobile	Device:	iOS	version	6.0	or	above/	Android	

											system	version	4.0	or	above	

• Mobile	Device	Support:	Recommended:	iPhone4s,	iPhone5,	iPhone5s,	iPod

								Touch4,	iPod	Touch5;	

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	applicant	requests

that	the	FAA	grant	the	requested	exemption	with	minimum	delay.

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	the	persons	and/or	property	using	conventional	aircraft.

These	limitations	and	conditions	to	which	the	applicant	agrees	to	adhere	to	when	

conducting	commercial	operations	under	the

FAA	issued	exemption	as	set	forth	in	the	Flight	Operations	Manual	(FOM)	include:	•

The	UAS	will	weigh	less	than	55	lbs.	

(DJI	Phantom	3	Advanced	weighs	1280G	or	2lbs	13oz)	• The	UAS	will	have	a	

maximum	operating	speed	of	no	more	than	35mph.

• Flights	will	be	operated	within	line	of	sight	of	the	Pilot	in	Command	(PIC)	

									and/or	Visual	Observer	(VO).

• Maximum	flight	time	for	each	operational	flight	will	be	20	minutes. Flights	will	

									be	terminated	at	25%	battery	power	reserve	or	20	minutes	of	flight	time	

									whichever	occurs	first.

• Flights	will	be	operated	at	an	altitude	of	no	more	than	400	feet	Above	Ground	

										Level	(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,	the	Visual			

											Observer	(VO)	and	may	include	but	not		limited	to	a	Camera	Operator.

• The	UAS	pilot	will	be	a	designated	Pilot	in	Command	(PIC)	and	will	take	and	

										pass	all	necessary	certifications currently	being	approved	by	the	FAA	

										administration	for	commercial	use.

• A	briefing	will	be	performed	regarding	the	planned	UAS	operations	prior	to

									each	day’s	flight	consisting	of	all	the	days’	production	activities.

• All	flights	will	occur	under	Visual	Flight	Rules	Meteorological	Conditions	(VMC)	

								only.

• The	flights	will	occur	no	closer	than	a	5	mile	radius	of	the	geographic	

									center/Airport	Reference	Point	(ARP)	of	a	tower	ontrolled	or	uncontrolled

									airport.

The	DJI	Phantom	3	Advanced	has	built	in	software	for	all	FAA	regulated	‘No	Fly	

Zones’	and	was	uploaded	by	DJI	(February

2015)	for	all	DJI	drones	to	download	and	prevent	any	possible	flights	occurring	

within	no-fly	zones. DJI	Phantom	3	

Advanced	has	installed	software	(code)	that	denies	flights	within	the	FAA	no-fly	

zones.

• If	operations	will	be	within	a	5	mile	radius	of	the	geographic	center/Airport	

Reference	Point	(ARP)	of	a	tower controlled	or	uncontrolled	airport	the	respective	

airports	will	be	contacted	advising	them	of	the	estimated	flight	time,	flight	duration,

elevation	of	flight	and	other	pertinent	information.

• The	operator	will	file	FAA	Form	7711-1,	or	its	equivalent,	as	modified	in	light	
										of	the	requested	exemption,	with	the	appropriate	local	Flight	Standards	

										District	Office	(FSDO)	no	more	than	72	hours	but	no	less	than	48	hours	from	

planned	operation.

• The	operator	will	obtain	verbal/written	consent	of	all	persons	involved	with	

								the	planned	operation	and	ensure	that	only	consenting	persons	will	be	allowed	

									within	100	feet	of	the	flight	operation,	and	the	radius	may	be	reduced	to	30

feet	based	upon	an	equivalent	level	of	safety	determination,	as	required	under	

									the	FOM. With	the	advanced		permission	of	the FSDO,	operations	at	closer

									range	may	be	approved.

• The	PIC	and	VO	will	have	been	trained	in	operation	of	UAS	and	receive	up-to-

										date	information	for	the	particular	UAS	to	be	operated.

• The	PIC	and	VO	will	be	able	to	communicate	by	voice,	radio,	and/or	text	at	all	

											times.

• Written	and/or	verbal	permission	and	permits	will	be	obtained	from	

										territorial,	state,	county	or	city	jurisdictions,	including	law	enforcement,	fire	or	

											other	appropriate	governmental	agencies.

• If	the	UAS	loses	communications	with	the	remote	controller	or	loses	GPS	

										signal,	the	UAS	will	have	the	capability	to return	to	a	pre-determined	location	

									within	a	designated	location	and	land	autonomously.

• The	UAS	will	have	the	capability	to	abort	a	flight	in	case	of	unpredicted

									obstacles,	weather,	or	emergencies.

14	C.F.R.	Part	21,	Subpart	H:	Airworthiness	Certificates	14	C.F.R.	§91.203	(a)	(1)

Subpart	H,	entitled Airworthiness	Certificates,	establishes	the	procedural	
requirements	for	the	issuance	of	airworthiness	

certificates	as	required	by	FAR	§91.203	(a)	(1).	Given	the	size	and	limited	operating	

area	associated	with	the	aircraft	to	be	

utilized	by	the	Applicant,	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	of	the	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.	(3	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.	The	FAA	will	

have	advance	notice	of	all	operations.

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,	lack	of	explosive	materials	or	flammable	liquid	

fuels,	and	inability	to	carry	a	substantial	

external	load.	

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

The	regulation	requires:	

When	marks	include	only	the	Roman	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	will	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	C.F.R.	§	61.113	(a)	and	(b):	Private	Pilot	Privileges	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. An	

equivalent	level	of	safety	can	be	achieved	by

current	Regulations	because	the	applicant’s	UAS	do	not	carry	any	pilots	or	

passengers	nor	property. The	risks	attendant	to

the	operation	of	UAS	is	far	less	than	the	risk	levels	inherent	in	the	commercial	

activities	outlined	in	14	CFR	61.

The	operation	and	limitations	set	forth	in	the	FOM	will	equate	to	the	safe	operation	

of	the	UAS.
14	C.F.R.	§91.7(a):	Civil	Aircraft	Airworthiness.

The	regulation requires	that	no	person	may	operate	a	civil	aircraft	unless	it	is	in	

airworthy	condition.	As	there	will	be	no	

airworthiness	certificate	issued	for	the	aircraft,	should	this	exemption	be	granted,	

no	FAA	regulatory	standard	will	exist	for	

determining	airworthiness.	

Given	the	size	of	the	aircraft	for	maintenance	and	use	of	safety	check	lists	prior	to	

each	flight	an	equivalent	level	of	safety	will	

be	provided.	

14	C.F.R.	§	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	flight	manual	at	the	ground	control	point	where	the	pilot	

flying	the	UAS	will	have	immediate	access	to	it.	

14	C.F.R.	§	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	manufacturer	FOM	in	the	pre-flight	inspection	section,	including	but	

not	limited	to	reviewing	weather,	flight	

battery	requirements,	landing	and	takeoff	distances	and	aircraft	performance	data

before	initiation	of	flight.	

14	C.F.R.	§91.109:	Flight	Instruction.	

Section	91.103	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.	UAS	and	remotely

piloted	aircraft,	by	their	design	do	not	have

fully	functional	dual	controls.	Flight	control	is	accomplished	through	the	use	of	a

control	box	that	communicates	with	the	

aircraft	via	radio	communications.	The	FAA	has	approved	exemptions	for	flight

training	without	fully	functional	dual	controls	for

a	number	of	aircraft	and	for	flight	instruction	in	experimental	aircraft. The	

equivalent	level	of	safety	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.	

14	C.F.R.	§91.119:	Minimum	Safe	Altitudes.	

Section	91.119	establishes	safe	altitudes	for	operation	of	civil	aircraft.	Section	
91.119	(d)	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	a

helicopter	and	the	exemption requests	

authority	to	operate	at	altitudes	up	to	400	AGL,	or	not	more	than	200	above	an	

elevated	platform	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	400	AGL	with	the	exception	that	in	circumstances	where	the	UAS	is	used	

to	survey	or	photograph	a	structure

whose	height	exceeds	400	feet	AGL,	the	UAS	will	not	be	operated	more	than	200	

feet	above	the	highest	point	on	the	

structure.	It	will	however	be	operated	in	a	restricted	area	with	security	perimeter,	

where	buildings	and	people	will	not	be

exposed	to	operations	without	their	pre-obtained	consent.	

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	

operations.	Compared	to	flight	operations	with	aircraft	or	rotorcraft	weighting	far	
more	than	the	maximum	55lbs.	proposed	

herein	and	the	lack	of	flammable	fuel,	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.	

14	C.F.R.	§91.121	Altimeter	Settings.	

This	regulation	requires	each	person	operating	an	aircraft	to	maintain	cruising	

altitude	by	reference	to	an	altimeter	that	is	set

“...to	the	elevation	of	the	departure	airport	or	an	appropriate	altimeter	setting	

available	before	departure.”	As	the	UAS	may	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.	

14	C.F.R.	§	91.151(a):	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	25	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	20	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	C.F.R.	§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.	

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.	

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

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,	except	as	provided	in	

paragraph	(c)	of	this	section,	have	

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

in	compliance	with	Part	43.	

Given	that	these	section	and	Part	43	apply	only	to	aircraft	with	an	airworthiness

certificate,	these	sections	will	not	apply	to	the

applicant.	Maintenance	will	be	accomplished	by	the	operator	pursuant	to	the	flight	

manual	and	operating	handbook.	An	

equivalent	level	of	safety	will	be	achieved	because	the	UAS	is	very	limited	in	size	and	

will	carry	a	small payload	and	operate

only	in	restricted	areas	for	a	limited	period	of	time.	If	mechanical	issues	arise	the

UAS	can	land	immediately	and	will	be	

operating	from	no	higher	than	400	feet	AGL.	The	operator	will	ensure	that	the	UAS

is	in	working	order	prior	to	initiating	flight,

perform	required	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.	

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

will	be	performed	in	accordance	with	the

UAS	Manufacturer's	User	Manual. As	provided	in	the	FOM,	the	operator	will	ensure

that	the	UAS is	in	working	order	prior	to	initiating	flight	and	perform	required	

maintenance	needed.

Sincerely,

Mohammad	Tomaleh
“Safety	Always	our	concern”