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January 22, 2016

Attn:

U. S. Department of Transportation Docket Operations 

West Building Ground Floor, Room w12-140

1200 New Jersey Ave, SE Washington, DC 20590

RE: PLATINUM DRONE SERVICES, LLC

REQUEST AN EXEMPTION FROM THE REQUIREMENTS OF TITLE 14 OF THE CODE 

OF FEDERAL REGULATIONS

SECTIONS 61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & 

(a)(2), AND 91.417(a) & (b) CONCERNING COMMERCIAL OPERATION OF THE DJI 

PHANTOM 2, DJI PHANTOM 3, 3DR SOLO, YUNEEC Q500+, AND THE DJI INSPIRE 1

UNMANNED AIRCRAFT SYSTEMS PURSUANT TO SECTION 333 OF

THE FAA MODERNIZATION AND REFORM ACT OF 2012 (PUBLIC LAW 112-95) 

Tyler Delino

President

Platinum Drone Services, LLC

71 Preston Drive, Gillette, NJ 07933

908-377-2649

Tyler.delino@gmail.com
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ABBREVIATIONS

AGL Above Ground Level

AOI Area of Interest

ATC Air Traffic Control

ATO Air Traffic Organization

AV Aerial Vehicle

CFR Code of Federal Regulations

COA Certificate of Authorization

FAA Federal Aviation Administration

FAR Federal Aviation Regulation

GCS Ground Control Station

GPS Global Positioning System

LOL Loss of Link

NAS National Airspace System

NOTAM Notice to Airman

PIC Pilot In Command

Section 333 FAA Modernization and Reform Act of 2012 (FMRA)

SO Safety Observer

SOP Standard Operating Procedures

UA Unmanned Aircraft

UAS Unmanned Aircraft System

VFR Visual Flight Rules

VLOS Visual Line of Site

VMC Visual Meteorological Conditions

VTOL Vertical Takeoff and Landing
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SUMMARY

Platinum Drone Services, LLC seeks exemption from the requirements of 14 C.F.R §§ 61.113(a) 

& (b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) 

& (b), to operate an Unmanned Aircraft System (THE DJI PHANTOM 2, DJI PHANTOM 3, 3DR 

SOLO, YUNEEC Q500+, AND THE DJI INSPIRE 1) pursuant to Section 333 of the FAA 

Modernization and Reform Act of 2012 (FMRA). This exemption will permit Platinum Drone 

Services, LLC to operate an Unmanned Aircraft System (UAS) for the commercial purpose of 

conducting aerial video and photography of construction sites, residential and commercial real 

estate, civil landscapes and events over certain areas of the United States. Because this petition is 

similar in all material respects to previously-granted Section 333 petitions, Platinum Drone Services, 

LLC requests expedited approval pursuant to the FAA's summary grant process.

I, Tyler Delino, owner of Platinum Drone Services, LLC have over ten years with expertise and 

knowledge in video and multimedia marketing, advertising, public relations and training using 

advanced videography. I Tyler Delino am also a USPA member (NO. 244706) and D- Licensed 

Sky Diver: D-34903 with my Coach Rating. I understand the importance of safety and flight 

patterns. I understand the importance of cloud regulations, wind strength, area objects that could 

cause potential harm and how to avoid them. I am familiar with many FAA regulations relative to 

this exemption. The objective of Platinum Drone Services, LLC and our Unmanned Aircraft 

System (THE DJI PHANTOM 2, DJI PHANTOM 3, 3DR SOLO, YUNEEC Q500+, AND THE DJI 

INSPIRE 1) and aerial operations is to provide a more affordable, high-quality production system 

for a variety of commercial, public, and residential uses, specifically targeting

 Construction sites 

 Real-estate 

 Outdoor activities

 Landscaping

 Special event coverage

 Hotels

 Golf Courses

To start it will solely be I, Tyler Delino operating the UAS which has already been registered 

with FAA. In time I will hire a small staff with highly regulated training and supervising before 

any flight under Platinum Drone Services, LLC will occur. 

BACKGROUND

Unmanned Aircraft Systems: THE DJI PHANTOM 2, DJI PHANTOM 3, 3DR SOLO, YUNEEC 

Q500+, AND THE DJI INSPIRE 1 UAS

Platinum Drone Services, LLC seeks an exemption to operate THE DJI PHANTOM 2, DJI 

PHANTOM 3, 3DR SOLO, YUNEEC Q500+, AND THE DJI INSPIRE 1 system for compensation or 

hire within the NAS. THE DJI PHANTOM 2, DJI PHANTOM 3, 3DR SOLO, YUNEEC Q500+, AND 

THE DJI INSPIRE 1 are all vertical takeoff and landing (VTOL) Unmanned Aircraft (UA) with a 

Ground Control Station (GCS) utilizing electronic tablet or smart phone systems. All of these 

UAS’s are well below the 55 pound criteria. The UAS is equipped with four main rotors; driven 

by Lithium Polymer battery powered electric motors.
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The UAS that will be operated by Platinum Drone Services, LLC will be registered in accordance 

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

and marked in accordance with 14 C.F.R. Part 45, Identification and Registration Marking.

BASIS FOR PETITION

Petitioner, Platinum Drone Services, LLC, pursuant to the provisions of the Federal Aviation 

Regulations (14 C.F.R. § 11.61) and the FAA Modernization and Reform Act of 2012 (FMRA), 

Section 333, Special Rules for Certain Unmanned Aircraft Systems, hereby petitions the 

Administrator to commercially operate the UAS in the National Airspace System (NAS), and for 

an exemption from the requirements of 14 C.F.R §§ 61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 

91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b).

In consideration of the speed, weight, size, and limited operating area associated with the 

unmanned aircraft and its operation, Platinum Drone Services, LLC meets the conditions of 

FMRA Section 333 and therefore, will not require an airworthiness certificate in accordance with 

14 C.F.R. Part 21, Subpart H.

Accordingly, Platinum Drone Services, LLC requests relief from Sections 91.405(a), 

91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b), as these sections set forth requirements 

for maintenance that only apply to aircraft with an airworthiness certificate.

Relief from certain requirements of Section 61.113(a) and (b), entitled Private pilot privileges 

and limitations: Pilot in command, is requested by Platinum Drone Services, LLC to the extent 

necessary to allow a Pilot in Command (PIC) holding a private pilot or higher level certificate, as 

well as an airman medical certificate, and who has demonstrated, by meeting minimum flighthour and currency requirements, that the PIC is able to safely operate the UAS in a manner 

consistent with this exemption, including evasive and emergency maneuvers and maintaining 

appropriate distances from people, vessels, vehicles and structures.

Platinum Drone Services, LLC seeks relief from Section 91.7(a), entitled Civil aircraft 

airworthiness, because the UAS does not require an airworthiness certificate in accordance with 

14 C.F.R. Part 21, Subpart H. As such, Platinum Drone Services, LLC submits that they will 

ensure that the UAS is in an airworthy condition, prior to every flight, by determining that the 

UAS are in compliance with the operating documents.
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Platinum Drone Services, LLC also seeks an exemption from the requirements of Section 

91.121, entitled Altimeter Settings, as the UAS will not have a typical barometric altimeter 

onboard. However, altitude information of the UAS will be provided to the PIC via Global 

Positioning System (GPS) equipment and radio communications telemetry data link, which 

downlinks from the UA to the GCS for active monitoring of the flight path. This altitude 

information, combined with Platinum Drone Services, LLC operation of the UAS within visual 

line of sight, at or below 400 feet AGL, will ensure a level of safety equivalent to Section 91.121.

Additionally, Platinum Drone Services, LLC seeks an exemption from the requirements of 

Section 91.151(b), entitled Fuel requirements for flight in VFR conditions. Platinum Drone 

Services, LLC submits that safety will not be affected by operation of the UAS during daylight 

hours in visual meteorological conditions (VMC) under visual flight rules (VFR), with enough 

battery power to fly for a total duration of approximately 20 minutes. Battery power indicators 

are also able to show exactly how much battery power is left, as well as how much time is needed 

to return safely back to point of take off.

In accordance with 14 C.F.R. § 11.81, Platinum Drone Services, LLC provides the following 

information in support of its petition for exemption:

A. Name And Address Of The Petitioner.

The name and address of the Petitioner and point of contact is:

Tyler Delino

Owner

Platinum Drone Services, LLC 

71 Preston Drive, 

Gillette, NJ 07933

908-377-2649

Tyler.delino@gmail.com
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B. The Specific Sections Of 14 C.F.R. From Which Platinum Drone Services, LLC Seeks 

Exemption.

1. Platinum Drone Services, LLC Seeks Exemption From The Requirements Of Section 

61.113(a) And (b).

Section 61.113, entitled Private pilot privileges and limitations: Pilot in command, 

subsections (a) and (b) prescribe the following, in relevant part:

(a) No person who holds a private pilot certificate may act as a pilot in command 

(PIC) of an aircraft that is carrying passengers or property for compensation or hire; 

nor may that person, for compensation or hire, act as PIC of an aircraft.

(b) A private pilot may, for compensation or hire, act as PIC 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.

2. Platinum Drone Services, LLC Seeks Exemption From The Requirements Of Section 

91.7(a).

Section 91.7, entitled Civil aircraft airworthiness, subsection (a), states the following: 

(a) No person may operate a civil aircraft unless it is in an airworthy condition.

3. Platinum Drone Services, LLC Seeks Exemption From The Requirements Of Section 

91.121.

Section 91.121, entitled Altimeter settings, subsection (a), states the following, in part:

(a) Each person operating an aircraft shall maintain the cruising altitude or flight level 

of that aircraft, as the case may be, by reference to an altimeter that is set, when 

operating--

(1) Below 18,000 feet MSL, to--

(i) The current reported altimeter setting of a station along the route and 

within 100 nautical miles of the aircraft;

(ii) If there is no station within the area prescribed in paragraph (a)(1)(i) of this 

section, the current reported altimeter setting of an appropriate available 

station; or

(iii) In the case of an aircraft not equipped with a radio, the elevation of the 

departure airport or an appropriate altimeter setting available before 

departure.
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4. Platinum Drone Services, LLC Seeks Exemption From The Requirements Of Section 

91.151(b).

Section 91.151, entitled Fuel requirements for flight in VFR conditions, subsection 

(b), states the following:

(b) No person may begin a flight in a rotorcraft 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, to fly after that 

for at least 20 minutes.

5. Platinum Drone Services, LLC Seeks Exemption From The Requirement Of Section 

91.405(a).

Section 91.405, entitled Maintenance required, subsection (a), states the following: Each 

owner or operator of an aircraft—

(a) 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[.]

6. Platinum Drone Services, LLC Seeks Exemption From The Requirements Of Section 

91.407(a)(1)

Section 91.407, entitled Operation after maintenance, preventive maintenance, 

rebuilding, or alteration, subsection (a)(1), states the following:

(a) No person may operate any aircraft that has undergone maintenance, preventive 

maintenance, rebuilding, or alteration unless--

(1) It has been approved for return to service by a person authorized under § 43.7 

of this chapter.

7. Platinum Drone Services, LLC Seeks Exemption From The Requirements Of Sections 

91.409(a)(1) And 91.409(a)(2).

Section 91.409, entitled Inspections, subsection (a), states the following:

(a) Except as provided in paragraph (c) of this section, no person may operate an 

aircraft unless, within the preceding 12 calendar months, it has had --

(1) An annual inspection in accordance with part 43 of this chapter and has been 

approved for return to service by a person authorized by § 43.7 of this chapter; or

(2) An inspection for the issuance of an airworthiness certificate in accordance 

with part 21 of this chapter.
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8. Platinum Drone Services, LLC Seeks Exemption From The Requirements Of Sections 

91.417(a) And 91.417(b).

Section 91.417, entitled Maintenance records, subsections (a) and (b), state the 

following:

(a) Except for work performed in accordance with §§ 91.411 and 91.413, each 

registered owner or operator shall keep the following records for the periods specified 

in paragraph (b) of this section:

(1) Records of the maintenance, preventive maintenance, and alteration and 

records of the 100-hour, annual, progressive, and other required or approved 

inspections, as appropriate, for each aircraft (including the airframe) and each 

engine, propeller, rotor, and appliance of an aircraft. The records must include--

(i) A description (or reference to data acceptable to the Administrator) of the 

work performed; and

(ii) The date of completion of the work performed; and

(iii) The signature, and certificate number of the person approving the aircraft 

for return to service.

(2) Records containing the following information:

(i) The total time in service of the airframe, each engine, each propeller, and 

each rotor.

(ii) The current status of life-limited parts of each airframe, engine, propeller, 

rotor, and appliance.

(iii) The time since last overhaul of all items installed on the aircraft which 

are required to be overhauled on a specified time basis.

(iv) The current inspection status of the aircraft, including the time since the 

last inspection required by the inspection program under which the aircraft 

and its appliances are maintained.

(v) The current status of applicable airworthiness directives (AD) and 

safety directives including, for each, the method of compliance, the AD or 

safety directive number and revision date. If the AD or safety directive 

involves recurring action, the time and date when the next action is required.

(vi) Copies of the forms prescribed by § 43.9(d) of this chapter for each 

major alteration to the airframe and currently installed engines, rotors, 

propellers, and appliances.
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(b) The owner or operator shall retain the following records for the periods 

prescribed:

(1) The records specified in paragraph (a)(1) of this section shall be retained until 

the work is repeated or superseded by other work or for 1 year after the work is 

performed.

(2) The records specified in paragraph (a)(2) of this section shall be retained and 

transferred with the aircraft at the time the aircraft is sold.

(3) A list of defects furnished to a registered owner or operator under § 43.11 of 

this chapter shall be retained until the defects are repaired and the aircraft is 

approved for return to service.

C. The Extent Of Relief Platinum Drone Services, LLC Seeks And The Reason Platinum 

Drone Services, LLC Seeks The Relief.

1. Extent Of Relief Platinum Drone Services, LLC Seeks And The Reason Platinum Drone 

Services, LLC Seeks Relief From Section 61.113(a) And (b).

Relief from Section 61.113(a) and (b) entitled Private pilot privileges and limitations: Pilot in 

command, is requested to the extent necessary to allow a PIC holding a private pilot or higher 

level certificate, as well as a current and valid airman medical certificate, and who has met certain 

flight-hour and currency requirements, to conduct the proposed UAS flight operations for 

compensation or hire.

This relief is requested since the limitations set forth in Section 61.113(a) and (b) state that a 

private pilot may, for compensation or hire, act as PIC 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.

As set forth more fully below, Platinum Drone Services, LLC submits that an equivalent level 

of safety will be maintained because no PIC will be allowed to operate the UAS unless that PIC 

has met certain flight-hour and currency requirements, demonstrating that the PIC is able to 

safely operate either the UAS in a manner consistent with the operations specifications as 

described in this exemption, including evasive and emergency maneuvers, as well as 

maintaining appropriate distances from people, vessels, vehicles and structures.

Further, Platinum Drone Services, LLC submits that all flights of the UAS, conducted by the PIC 

pursuant to the grant of this Petition: (1) will be incidental to Platinum Drone Services, LLC

business; and (2) will not carry passengers or property for compensation or hire.
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2. Extent Of Relief Platinum Drone Services, LLC Seeks And The Reason Platinum Drone 

Services, LLC Seeks Relief From Section 91.7(a).

Relief from Section 91.7(a) entitled Civil aircraft airworthiness, is requested to the extent 

required to allow Platinum Drone Services, LLC to determine that the UAS are in airworthy 

condition prior to every flight by ensuring that the UAS is in compliance with the operating 

documents (i.e., Platinum Drone Services, LLC Aerial Operations Manual, Monthly Maintenance 

Log, and Instruction Manual).

Platinum Drone Services, LLC seeks the requested relief because the UAS do not require an 

airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H. Therefore, Platinum 

Drone Services, LLC will ensure that the UAS are in airworthy condition based upon its 

compliance with the operating documents (i.e., Monthly Maintenance Log) prior to every flight, 

and further, determine that the aircraft are in condition for safe flight, as stated in the conditions 

and limitations below.

3. Extent Of Relief Platinum Drone Services, LLC Seeks And The Reason Platinum Drone 

Services, LLC Seeks Relief From Section 91.121.

Relief from Section 91.121, entitled Altimeter settings, may be required to allow flight operations 

of the UAS, which utilize a barometric pressure sensor, GPS equipment, and a radio 

communications telemetry data link to downlink altitude information from the UA to the PIC at 

the ground control station (GCS). Since the FAA requires that any altitude information 

concerning UAS operations be reported to air traffic control (ATC) in feet above ground level 

(AGL), Platinum Drone Services, LLC seeks the requested relief because the UA’s altimeter may 

be set on the ground to zero feet AGL, rather than the local barometric pressure or field altitude, 

before each flight.

Considering the limited altitude of the proposed operations, relief from 14 CFR 91.121 is sought 

to the extent necessary to comply with the applicable conditions and limitations stated below. As 

more fully set forth herein, an equivalent level of safety will be maintained since the UAS are 

equipped with a barometric pressure sensor and GPS equipment, which automatically ensures that 

a ground level pressure setting will be established prior to each flight, and provides the PIC with 

altitude information of the UA on the heads-up display of the GCS.

4. Extent Of Relief Platinum Drone Services, LLC Seeks And The Reason Platinum Drone 

Services, LLC Seeks Relief From Section 91.151(b).

Relief from Section 91.151(b) entitled Fuel requirements for flight in VFR conditions, is 

requested to the extent required to allow flights of the battery powered UAS during daylight 

hours in visual meteorological conditions (VMC), under visual flight rules (VFR), for a total 

duration of 20 minutes. Platinum Drone Services, LLC seeks the requested relief because without 

an exemption from Section 91.151(b), the flight time duration of the
battery powered UAS will severely constrain the practicality of any aerial video or still photo 

flight operations that Platinum Drone Services, LLC proposes to conduct pursuant to this 

Petition.

Significantly, as set forth below, the technical specifications of the UAS, operating documents, 

and Platinum Drone Services, LLC proposed operating limitations, ensure that Platinum Drone 

Services, LLC will safely operate the battery powered 3 UAS during daylight hours in visual 

meteorological conditions (VMC), under visual flight rules (VFR), with enough battery power to 

fly for a total duration of 20 minutes.

5. Extent Of Relief Platinum Drone Services, LLC Seeks And The Reason Platinum Drone 

Services, LLC Seeks Relief From Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), And 

91.417(a) & (b).

Since Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a ) & (b) only apply to 

aircraft with an airworthiness certificate, Platinum Drone Services, LLC requests relief from 

these Sections because the UAS do not require airworthiness certificates. As set forth more fully 

below, the UAS meet the conditions of FMRA Section 333 for operation without an 

airworthiness certificate. Accordingly, Platinum Drone Services, LLC will use trained technicians 

to perform maintenance, alterations, or preventive maintenance on the UAS using the methods, 

techniques, and practices prescribed in the UAS operating documents (i.e., the Platinum Drone 

Services, LLC Aerial Operations Manual, Monthly Maintenance Log, and Instruction Manual). 

Furthermore, Platinum Drone Services, LLC will document and maintain all maintenance records 

for the UAS.

D. The Reasons Why Granting Platinum Drone Services, LLC Request Would Be In The 

Public Interest; That Is, How It Would Benefit The Public As A Whole.

Granting the present Petition will further the public interest by allowing Platinum Drone Services, 

LLC to safely, efficiently, and economically perform aerial video and photography of 

construction sites, real estate, events, landscapes, golf courses, weddings, outdoor activities and 

private parties over certain areas of the United States.

Additionally, use of the UAS will decrease congestion of the NAS, reduce pollution, and provide 

significant benefits to the economy. The Public Will Benefit From Decreased Congestion Of The 

NAS. The UAS are battery powered and serve as a safe, efficient, and economical alternative to 

the manned aircraft traditionally utilized to obtain aerial imagery. This will reduce the amount of 

aircraft traffic, noise and pollution. In addition an airport is not required for takeoff and landing 

as the UAS does not require a landing strip. This will allow air traffic control to focus on other 

flight operations not conducting manned aerial imagery. Congestion in the NAS will be reduced. 

The Public Will Benefit From The Safety And Efficiency of the UAS. A typical aircraft used for 

aerial imagery burns approximately 25 gallons per hour of fuel. The UAS is much more efficient 

and will greatly benefit the public because no fuel is required as the UAS is battery powered with 

electric motors. Furthermore the UAS is much quieter eliminating noise pollution and any 

disturbance to the public cause by a loud manned aircraft flying low. There is considerable less 
risk to the public utilizing the UAS as it weighs way under 55pounds ,has no fuel for something 

to explode, compared to the manned aircraft weighing around 6,500 pounds, 42 feet wide, 35 feet 

long with typically close 185 gallons of fuel. The potential for danger with the UAS is greatly 

reduced. By using the UAS to perform aerial imagery, the risk to life and property in the air and 

on the ground, will be much less or eliminated compared the typical manned aircraft completing 

the same objective. Performing Aerial Video and Photography Operations With UAS Will 

Benefit The Economy. The UAS offer an economical alternative to using manned aircraft for 

aerial imagery. This exemption allows companies to remain competitive and offer a service for a 

much cheaper, more efficient and healthier way. It allows aerial drone companies to grow and 

positively impact our economy. 

Privacy will not be of any concern to the public as the UAS will be operated only in compliance 

with operating documents (i.e., Platinum Drone Services, LLC Aerial Operations Manual, 

Monthly Maintenance Log, and Instruction Manual) which requires property owner involvement 

as well as local law enforcement notification, and in accordance with the Federal Aviation 

Regulations, including the minimum altitude requirements of 14 C.F.R. § 91.119.

E. The Reasons Why Granting The Exemption Would Not Adversely Affect Safety, Or 

How The Exemption Would Provide A Level Of Safety At Least Equal To That Provided 

By The Rule From Which Platinum Drone Services, LLC Seeks Exemption.

1. Reasons Why The UAS Meet The Conditions Of The FAA Modernization and Reform 

Act of 2012 (FMRA) Section 333.

In consideration of the size, weight, speed, and limited operating area associated with the 

unmanned aircraft and its operation, Platinum Drone Services, LLC operation of the UAS meet 

the conditions of FMRA Section 333, and will not require an airworthiness certificate in 

accordance with 14 C.F.R. Part 21, Subpart H.

Section 333 provides authority for a UAS to operate without airworthiness certification and sets 

forth requirements for considering whether a UAS will create a hazard to users of the NAS or the 

public, or otherwise pose a threat to national security. Specifically, FMRA Section 333 states the 

following, in part:

(a) In General.--Notwithstanding any other requirement of this subtitle, and not later 

than 180 days after the date of enactment of this Act, the Secretary of Transportation 

shall determine if certain unmanned aircraft systems may operate safely in the 

national airspace system before completion of the plan and rulemaking required by 

section 332 of this Act or the guidance required by section 334 of this Act.
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(b) Assessment of Unmanned Aircraft Systems.--In making the determination under 

subsection (a), the Secretary shall determine, at a minimum--

(1)which types of unmanned aircraft systems, if any, as a result of their size, 

weight, speed, operational capability, proximity to airports and populated 

areas, and operation within visual line of sight do not create a hazard to users 

of the national airspace system or the public or pose a threat to national 

security; and

(2) whether a certificate of waiver, certificate of authorization, or 

airworthiness certification under section 44704 of title 49, United States 

Code, is required for the operation of unmanned aircraft systems identified 

under paragraph (1).

(c) Requirements for Safe Operation.--If the Secretary determines under this section 

that certain unmanned aircraft systems may operate safely in the national airspace 

system, the Secretary shall establish requirements for the safe operation of such 

aircraft systems in the national airspace system.

In seeking this exemption, Platinum Drone Services, LLC submits that the UAS can operate 

safely in the NAS pursuant to FMRA Section 333, as demonstrated by: (a) the characteristics of 

the UAS; (b) the pilot certification requirement; and (c) the specific operating limitations.

a. The Specifications of the UAS Demonstrate Its Safe Characteristics.

The UAS does not create a hazard to users of the NAS or the public, or otherwise pose a threat to 

national security considering its size, weight, speed, and operational capability.

i. Technical Specifications of the UAS.

The technical specifications of the UAS are set forth by the User Manual

The UAS Global Positioning Modes Enable The UAS To Remain Within A Defined 

Operational Area.

The UAS may be operated in both manual and global positioning flight modes. 

The UAS Are Designed For Automatic Return To Home Point Or Hover In The Event Of 

Loss Of The Control Link Or Navigation.

When the Control Link is lost, the UAS will remain stationary, in flight, for 3 seconds or more. If, 

after 3 seconds, the UAS does not reacquire control link data from the GCS, the UAS will assume 

that the Control Link is lost and the will return to the home position (i.e., failsafe mode) via GPS, 

and will descend to the takeoff position and shutdown.
Flight Operations of the UAS Is Limited To The Line Of Sight Of A Certificated Pilot in 

Command With A Safety Observer.

Platinum Drone Services, LLC video production staff will be the only persons to act as a pilot in 

command (PIC) of the UAS. Additionally, a safety observer will assist him at all times during 

flight time.

b.Flights of the UAS Will Be Conducted Pursuant To Specific Operating Limitations.

In seeking this exemption, Platinum Drone Services, LLC proposes to commercially operate the

UAS for the special purpose of conducting aerial video and photography over certain areas of 

United States, pursuant to the following specific operating limitations.

1.Operations authorized by this grant of exemption will be limited to the following 

aircraft described in the operating documents, rotorcraft UAS weighing less than 55 

pounds maximum gross weight THE DJI PHANTOM 2, DJI PHANTOM 3, 3DR 

SOLO, YUNEEC Q500+, AND THE DJI INSPIRE 1. 

2.UAS operations under this exemption will be limited to conducting operations for 

the purpose of aerial video and photography.

3.The UAS may not be flown at an indicated airspeed exceeding 20 knots.

4.The UA must be operated at an altitude of no more than 400 feet above ground level 

(AGL), as indicated by the procedures specified in the operating documents unless a 

special request is made and approved by ATC. All altitudes reported to ATC must be 

in feet AGL.

5.The UAS must be operated within visual line of sight (VLOS) of the PIC at all 

times. This requires the PIC to be able to use human vision unaided by any device 

other than corrective lenses, as specified on the PIC’s FAA-issued airman medical 

certificate.

6.The use of first person view (FPV) by the PIC or safety observer (SO) is not 

permitted.
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7. All operations must utilize a safety observer (SO). The SO may be used to satisfy 

the VLOS requirement as long as the PIC always maintains VLOS capability. The SO 

and PIC must be able to communicate verbally at all times. Electronic messaging or 

texting is not permitted during flight operations. The PIC must be designated before 

the flight and cannot transfer his or her designation for the duration of the flight. The 

PIC must ensure that the SO can perform the functions prescribed in the operating 

documents.

8. The SO must not perform any other duties beyond assisting the PIC with seeing and 

avoiding other air traffic and other ground based obstacles/obstructions and is not 

permitted to operate the camera or other instruments.

9. The operating documents and the grant of exemption must be accessible during 

UAS operations and made available to the Administrator upon request. If a 

discrepancy exists between the conditions and limitations contained in the grant of 

exemption and the procedures outlined in the operating documents, the conditions 

and limitations contained in the grant of exemption take precedence and must be 

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

operating documents. The operator may update or revise its operating documents. It 

is the operator’s responsibility to track such revisions and present updated and 

revised documents to the Administrator upon request. The operator must also present 

updated and revised documents if it petitions for extension or amendment to the grant 

of exemption. If the operator determines that any update or revision would affect the 

basis upon which the FAA granted the exemption, then the operator must petition for 

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.

10. Prior to each flight the PIC must inspect the UAS to ensure that it is in a condition 

for safe flight. 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 and the UAS is found to be in a condition for safe flight. The Ground 

Control Station must be included in the preflight inspection. All maintenance and 

alterations must be properly documented in the aircraft records.

11. Any UAS that has undergone maintenance or alterations that affect the UAS 

operation or flight characteristics, e.g. replacement of a flight critical component, 

must undergo a functional test flight. The PIC who conducts the functional test flight 

must make an entry in the aircraft records.

12. The pre-flight inspection must account for all potential discrepancies, e.g. 

inoperable components, items, or equipment, not already covered in the relevant 

sections of the operating documents.

13. The operator must follow the UAS manufacturer’s aircraft/component, 

maintenance, overhaul, replacement, inspection, and life limit requirements.
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14. The operator must carry out its maintenance, inspections, and record keeping 

requirements, in accordance with the operating documents. Maintenance, inspection, 

alterations, and status of replacement/overhaul component parts must be noted in the 

aircraft records, including total time in service, description of work accomplished, 

and the signature of the authorized person returning the UAS to service.

15. Each UAS operated under this exemption must comply with all manufacturer 

Safety Bulletins.

16. The authorized person must make an entry in the aircraft record of the corrective 

action taken against discrepancies discovered between inspections.

17. The PIC must possess at least a private pilot certificate and at least a current thirdclass medical certificate.

18. The operator may not permit any PIC to operate unless the PIC meets the 

operator’s qualification criteria and demonstrates the ability to safely operate the 

UAS in a manner consistent with how the UAS will be operated under the 

exemption, including evasive and emergency maneuvers and maintaining 

appropriate distances from persons, vessels, vehicles and structures. PIC 

qualification flight hours must be logged in a manner consistent with 14 C.F.R. § 

61.51(b). Flights for the purposes of training the operator’s PICs are permitted under 

the terms of the exemption. However, training operations may only be conducted 

during dedicated training sessions. During training, proficiency, and experiencebuilding flights, all persons not essential for flight operations are considered 

nonparticipants, and the PIC must operate the UA with appropriate distance from 

nonparticipants in accordance with 14 C.F.R. § 91.119.

19. UAS operations may not be conducted during night, as defined in 14 C.F.R. § 1.1. 

All operations must be conducted under visual meteorological conditions (VMC). If 

flight at night is required, a special request will be made at the FAA office closest to 

proposed area of operations. Flights under special visual flight rules (SVFR) are not 

authorized.

20. The UA may not operate within 5 nautical miles of an airport reference point as 

denoted on a current FAA-published aeronautical chart unless a letter of agreement 

with that airport’s management is obtained, and the operation is conducted in 

accordance with a NOTAM as required by the operator’s COA. The letter of 

agreement with the airport management must be made available to the Administrator 

upon request.

21. The UA may not be operated less than 500 feet below or less than 2,000 feet 

horizontally from a cloud or when visibility is less than 3 statute miles from the PIC.

22. If the UA loses communications or loses its GPS signal, it must return to a predetermined location within the planned operating area and land or be recovered in 

accordance with the operating documents.
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23. The PIC must abort the flight in the event of unpredicted obstacles or emergencies 

in accordance with the operating documents.

24. The PIC is prohibited from beginning a flight unless (considering wind and 

forecast weather conditions) there is enough power to fly at normal cruising speed to 

the intended landing point and land the UA with 25% battery power remaining.

25. The operator must obtain an Air Traffic Organization (ATO) issued Certificate of 

Waiver or Authorization (COA) prior to conducting any operations under the grant of 

exemption. This COA will also require the operator to request a Notice to Airman 

(NOTAM) not more than 72 hours in advance, but not less than 48 hours prior to the 

operation. All operations shall be conducted in accordance with airspace requirements 

in the ATO issued COA including class of airspace, altitude level and potential 

transponder requirements.

26. All aircraft operated in accordance with the exemption must be identified by serial 

number, registered in accordance with 14 C.F.R. part 47, and have identification (NNumber) markings in accordance with 14 C.F.R. part 45, Subpart C. Markings must 

be as large as practicable.

27. Before conducting operations, the radio frequency spectrum used for operation and 

control of the UA must comply with the Federal Communications Commission (FCC) 

or other appropriate government oversight agency requirements.

28. The documents required fewer than 14 C.F.R. 91.9 and 91.203 must be available 

to the PIC at the Ground Control Station of the UAS any time the UAS is operating. 

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

official upon request.

29. The UA must remain clear and yield the right of way to all manned aviation 

operations and activities at all times.

30. The UAS may not be operated by the PIC from any moving device or vehicle.

31. Flight operations must be conducted at least 500 feet from all nonparticipating 

persons (persons other than the PIC, SO, operator trainees or essential persons), 

vessels, vehicles, and structures unless:

a. Barriers or structures are present that sufficiently protect nonparticipating 

persons from the UA and/or debris in the event of an accident. The operator 

must ensure that nonparticipating persons remain under such protection. If a 

situation arises where nonparticipating persons leave such protection and are 

within 500 feet of the UA, flight operations must cease immediately and/or;

b. The aircraft is operated near vessels, vehicles or structures where the 

owner/controller of such vessels, vehicles or structures has granted permission 

and the PIC has made a safety assessment of the risk of operating closer to 

those objects and determined that it does not present an undue hazard, and;
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c. Operations nearer to the PIC, SO, operator trainees or essential persons do

not present an undue hazard to those persons per § 91.119(a).

32. All operations shall be conducted over private or controlled-access property with 

permission from the land owner/controller or authorized representative. Permission 

from land owner/controller or authorized representative will be obtained for each 

flight to be conducted.

33. Any incident, accident, or flight operation that transgresses the lateral or vertical 

boundaries of the operational area as defined by the applicable COA must be reported 

to the FAA's UAS Integration Office (AFS-80) within 24 hours. Accidents must be 

reported to the National Transportation Safety Board (NTSB) per instructions 

contained on the NTSB Web site: www.ntsb.gov.

2. Reasons Why An Exemption From The Requirements Of Section 61.113(a) And (b) 

Would Not Adversely Affect Safety.

Platinum Drone Services, LLC submits that the equivalent level of safety established by Section 

61.113(a) and (b) will be maintained because no PIC will be allowed to operate the UAS unless 

that PIC has demonstrated, by meeting minimum flight-hour and currency requirements, that the 

PIC is able to safely operate the UAS in a manner consistent with the exemption, including 

evasive and emergency maneuvers and maintaining appropriate distances from people, vessels, 

vehicles and structures.

Considering Platinum Drone Services, LLC proposed area of operations, and the operating 

limitations set forth-above; the parallel nature of private pilot aeronautical knowledge 

requirements to those of commercial pilot requirements (See Exemption No. 11062); and the 

airmanship skills necessary to safely operate the UAS, Platinum Drone Services, LLC submits 

that the additional manned airmanship experience of a commercially certificated pilot would not 

correlate to the airmanship skills necessary for Platinum Drone Services, LLC’s specific 

proposed flight operations.

The FAA has previously granted relief from Section 61.113(a) and (b) specific to UAS, in 

circumstances similar, in all material respects, to those presented herein (e.g. Exemption Nos. 

11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 11112, 11136, 11138, 11150, 

11153, 11156, 11158, 11159, 11160, 11161).

Platinum Drone Services, LLC will not allow any PIC to operate the UAS unless that PIC has 

demonstrated, by meeting minimum flight-hour requirements or the UAS training and currency 

requirements, that the PIC is able to safely operate the UAS in a manner consistent with this 

exemption, including evasive and emergency maneuvers and maintaining appropriate distances 

from people, vessels, vehicles and structures.

Specifically, the PIC must have accumulated and logged, in a manner consistent with 14 C.F.R. § 

61.51(b), 25 hours of total time as a UAS rotorcraft pilot (with a minimum of 5 hours of those
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hours as a UAS pilot operating the same make and model of UAS to be used for operations under 

the exemption). In addition to the hour requirements, the PIC must accomplish 3 takeoffs and 

landings in the preceding 90 days (for currency purposes).

As in Exemption Nos. 11062, 11138, and 11153, prior documented flight experience that was 

obtained in compliance with applicable regulations will ensure an equivalent level of safety 

during Platinum Drone Services, LLC proposed operations. The Administrator has held that prior 

documented flight experience that was obtained in compliance with applicable regulations would 

ensure safe operations, stating as follows:

In Exemption No. 11062, the FAA required that prior to conducting operations for the 

purpose of motion picture filming (or similar operations), the PIC must have 

accumulated and logged, in a manner consistent with 14 CFR 61.51(b), 25 hours of total 

time as a UAS rotorcraft pilot including at least 10 hours logged as a UAS pilot with a 

multi-rotor UAS. Prior to operations under Exemption No. 11062, the PIC must also 

have accumulated and logged a minimum of 5 hours as a UAS pilot operating the same 

make and model of UAS to be used for operations under the exemption. For 

clarification, the FAA considers these minimum hour requirements to be inclusive rather 

than additive; i.e. 5 hours make and model time may be included in the 10 hours of 

multi-rotor time and the 10 hours may be included in the total 25 hours of UAS 

rotorcraft time. In addition to the hour requirements, the PIC must accomplish 3 takeoffs 

and landings in the preceding 90 days (for currency purposes). The FAA finds that at a 

minimum, the flight-hour requirements in Exemption No. 11062 are appropriate to 

practice and build proficiency in the skills necessary to safely conduct the petitioner’s 

proposed operations. The FAA also finds that prior documented flight experience that 

was obtained in compliance with applicable regulations would satisfy this requirement. 

Training, proficiency, and experience-building flights can also be conducted under the 

grant of exemption to accomplish the required flight time. During training, proficiency, 

and experience-building flights the PIC is required to operate the UA with appropriate 

distances in accordance with 14 C.F.R 91.119.

Exemption No. 11138 at page 15.

Accordingly, Platinum Drone Services, LLC will ensure safe operations by not allowing any PIC 

to operate the UAS unless that PIC has demonstrated, by meeting minimum flight-hour and 

currency requirements, that the PIC is able to safely operate the UAS in a manner consistent with 

the exemption, including evasive and emergency maneuvers and maintaining appropriate 

distances from people, vessels, vehicles and structures.

3. Reasons Why An Exemption From The Requirements Of Section 91.7(a) Would Not 

Adversely Affect Safety.
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The equivalent level of safety established by Section 91.7(a) will be maintained because prior to 

every flight, Platinum Drone Services, LLC will ensure that the UAS is in an airworthy condition 

based upon the UAS’s compliance with its operating documents and as stated in the conditions 

and limitations herein.

Additionally, the FAA has previously granted relief from Section 91.7(a) specific to UAS, in 

circumstances similar, in all material respects, to those presented herein (e.g. Exemption Nos. 

11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 11112, 11136, 11138, 11150, 

11153, 11156, 11157, 11158, 11159, 11160, 11161).

4. Reasons Why An Exemption From The Requirements Of Section 91.121 Would Not 

Adversely Affect Safety.

The equivalent level of safety established by Section 91.121 will be maintained because the 

altitude information of the UAS will be provided to the PIC via GPS equipment and a radio 

communications telemetry data link, which downlinks from the UA to the GCS for active 

monitoring of the flight path and altitude. This altitude information, combined with Platinum 

Drone Services, LLC’s operation of the UAS within visual line of sight, at or below 500 feet 

AGL, will ensure a level of safety equivalent to Section 91.121. The altitude information will be 

generated by GPS equipment installed onboard the aircraft. Prior to each flight, a zero altitude 

initiation point is automatically established by the UAS at ground level.

The FAA has previously granted relief from Section 91.121 specific to UAS, in circumstances 

similar, in all material respects, to those presented herein (e.g. Exemption Nos. 11062, 11063,

11064, 11065, 11066, 11067, 11080, 11109, 11112, 11136, 11138, 11150, 11153, 11156, 11157,

11158, 11159, 11160, 11161).

5. Reasons Why An Exemption From The Requirements Of Section 91.151(b) Would Not 

Adversely Affect Safety.

A grant of this exemption would ensure an equivalent level of safety established by 14 C.F.R. 

Section 91.151(b) as a result of (1) the technical specifications of the UAS; (2) the limitations on 

the proposed flight operations; and (3) the location of the proposed flight operations. 

Accordingly, Platinum Drone Services, LLC will ensure that it will safely operate the battery 

powered UAS during daylight hours in VFR conditions, with enough battery power to fly for a 

total duration of 23 minutes.

Here, as in Exemption No. 11109, the technical specifications of the UAS; the limitations on the 

proposed flight operations; and the location of the proposed operations, will ensure an equivalent 

level of safety established by 14 C.F.R. Section 91.151(b). Furthermore, safety will be ensured as 

the UAS provide audible and visual warnings to the PIC at the GCS when the UAS experiences 

low battery voltage, the first warning occurring at approximately 33% remaining battery power, 

and again at approximately 10% remaining battery
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power. At the critically low battery level, the UAS will descend and land automatically.

Significantly, previous exemptions granted by the FAA concerning Section 91.151 establish that 

safety is not adversely affected when the technical characteristics and operating limitations of the 

UAS are considered. Relief has been granted for manned aircraft to operate at less than the 

minimums prescribed in Section 91.151, including Exemption Nos. 2689, 5745, and 10650. 

Moreover, the FAA has previously granted relief from Section 91.151 specific to UAS, in 

circumstances similar, in all material respects, to those presented herein (e.g. Exemption Nos. 

8811, 10808, 10673, 11042, 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 

11136, 11138, 11150, 11153, 11156, 11157, 11158, 11159, 11160, 11161).

6. Reasons Why An Exemption From The Requirements Of Sections 91.405(a), 

91.407(a)(1), 91.409(a)(1) & (a)(2), And 91.417(a) & (b) Would Not Adversely 

Affect Safety.

In seeking this exemption, Platinum Drone Services, LLC submits that the equivalent level of 

safety with regard to the regulatory maintenance and alteration requirements established by 

Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b) will be met 

because Platinum Drone Services, LLC will use trained technicians to perform maintenance, 

alterations, or preventive maintenance on the UAS using the methods, techniques, and practices 

prescribed in the operating documents (i.e., Platinum Drone Services, LLC Aerial Operations 

Manual, Monthly Maintenance Log, and Instruction Manual). Furthermore, Platinum Drone 

Services, LLC will document and maintain all maintenance records for the UAS.

Since the UAS will be inspected as prescribed by the operating documents, Platinum Drone 

Services, LLC will maintain the equivalent level of safety established by Sections 91.405(a), 

91.409(a)(1), and 91.409(a)(2). 

Likewise, the exemption sought will not adversely affect safety because Platinum Drone 

Services, LLC will use trained technicians to perform maintenance, alterations or preventive 

maintenance on the UAS using the methods, techniques, and practices prescribed by the 

operating documents.

Furthermore, the exemption sought would maintain an equivalent level of safety established by 

Sections 91.407, 91.417(a) and 91.417(b), because all maintenance of the UAS will be performed 

by trained technicians. Maintenance will be documented and maintained utilizing the monthly 

maintenance log.

Significantly, previous exemptions granted by the FAA concerning Sections 91.405(a), 

91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b) establish that safety is not adversely 

affected when the technical characteristics and operating limitations of the UAS are considered.
• A Summary That Can Be Published In The Federal Register, stating: The

Rules From Which Platinum Drone Services, LLC Seeks Exemption:

Platinum Drone Services, LLC seeks exemption from the requirements of 14 C.F.R 

Sections 61.113(a)&(b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) 

& (a)(2), and 91.417(a) & (b).

A Brief Description Of The Nature Of The Exemption Platinum Drone Services, 

LLC Seeks:

This exemption will permit Platinum Drone Services, LLC to commercially operate an 

Unmanned Aircraft System (UAS) for the purpose of conducting aerial video and 

photography over certain areas of the United States.

 Any Additional Information, Views, Or Arguments Available To Support 

Platinum Drone Services, LLC’s Request.

This Petition is made pursuant to the FAA Modernization and Reform Act of 2012

(FMRA) Section 333, which directs the Secretary of Transportation to determine if certain UAS 

may operate safely in the NAS. As such, Platinum Drone Services, LLC’s request for exemption 

may be granted pursuant to the authority of FMRA Section 333 and 14 C.F.R. Part 11, as set 

forth above.

FMRA Section 333 sets forth the requirements for considering whether a UAS will create a 

hazard to users of the NAS or the public, or otherwise pose a threat to national security; and 

further, provides the authority for such UAS to operate without airworthiness certification.

As discussed in detail above, Platinum Drone Services, LLC will operate the UAS safely in the 

NAS, without creating a hazard to users of the NAS, or the public, or otherwise pose a threat to 

national security.

CONCLUSION

As set forth herein, Platinum Drone Services, LLC seeks an exemption pursuant to 14 C.F.R. § 

11.61 and Section 333 of the FAA Modernization and Reform Act of 2012 (FMRA), which will 

permit safe operation of the UAS commercially, without an airworthiness certificate, for the 

limited purpose of conducting aerial video and photography over certain areas of the United 

States. By granting this Petition, the FAA Administrator will be fulfilling the Congressional 

mandate of the FAA Modernization and Reform Act of 2012, while also advancing the interests 

of the public, by allowing Platinum Drone Services, LLC to safely, efficiently, and economically 

operate THE DJI PHANTOM 2, DJI PHANTOM 3, 3DR SOLO, YUNEEC Q500+, AND THE DJI 

INSPIRE 1 commercially within the NAS.
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Because this petition is similar in material respects to previous petitions the FAA has granted, 

Platinum Drone Services, LLC requests that the FAA issue a summary grant of exemption pursuant 

to the agency's expedited summary grant process.

WHEREFORE, in accordance with the Federal Aviation Regulations and the FAA 

Modernization and Reform Act of 2012, Section 333, Platinum Drone Services, LLC respectfully 

requests that the Administrator grant this Petition for an exemption from the requirements of 14 

C.F.R Sections 61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) 

& (a)(2), and 91.417(a) & (b), and permit Leading Edge to operate the UAS commercially for the 

purpose of conducting aerial video and photography over certain areas of the United States.

Dated: 1-22-16

Respectfully submitted,

Tyler Delino

Owner

Platinum Drone Services, LLC

71 Preston Drive

Gillette, NJ, 07933

908-377-2649

tyler.delino@gmail.com
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