Greenville Drone, LLC, Simpsonville, SC - Section 333 Exemption Petition

May 18, 2015

U. S. Department of Transportation Docket Management System

1200 New Jersey Ave, SE Washington, DC 20590 

Re: Exemption Request Section 333 of the FAA Reform Act of the Federal 

Aviation Regulations from 14 C.F.R. 45.23(b); 14 C.F.R. Part 21; 14 C.F.R. 

61.113(a)&(b); 91.7(a); 91.9(b) (2); 91.103(b); 91.109; 119.121; 91.151(a); 

91.203(a)&(b); 91.405(a); 91.407(a) (1); 91.409(a) (2); 91.417(a)&(b) 

Dear Sir or Madam:

I Chad Cody, Owner and operator of Greenville Drone, LLC, am writing pursuant 

to the FAA Modernization and Reform Act of 2012 and the procedures contained 

within 14 C.F.R. 11, to request that Greenville Drone, LLC, owner and operator of 

small unmanned aircraft, be exempted from the

Federal Aviation Regulations (“FARs”) listed below so that Greenville Drone, may

operate small ultra light weight unmanned aircraft system (“UAS”) commercially 

in airspace regulated by the Federal Aviation Administration (“FAA”).

The requested exemption would permit the operation of small, unmanned and 

UAV’s under controlled conditions in airspace that is 1) limited 2) predetermined 

3) Controlled as to access.

As described herein, Greenville Drone, LLC has over 30 + years of experience 

with flying, building and safely operating recreational RC airplanes and 

helicopters. Greenville Drone LLC, has studied, built and repaired small and 

large commercial UAV’s over the past 17 months. I have a high level of 

knowledge and respect for industry along with safety. My sole UAV is the DJI 

Inspire 1. My choice for this UAV is the advanced safety systems that the DJI 

Inspire offers and with the exclusive set up with the combined flight systems, 

Flight Data Log systems and camera system, which allows safe, use for aerial 

videography/cinematography. This will enhance academic community awareness 

for those individuals and companies unfamiliar with the geographical layout of the 

Upstate South Carolina area, and augment real estate listing videos; following 

exemption and approval by the FAA. Thereby enhancing their academic research 

experience for the Upstate South Carolina area. 
Having flown small RC airplanes and helicopters for over ten (30) years without 

incident. Committed to safety with each flight. Greenville Drone, LLC, exemption 

request would permit operation of ultra lightweight, unmanned (piloted by remote 

control) and comparatively inexpensive UAS(s) in tightly controlled and limited 

airspace. Predetermined in areas away from general public, airports, heliports 

and vehicular traffic for community videos, and within property boundaries for 

individual homeowner real estate listing videos/photos. Currently, unmonitored 

amateur hobbyists with no safety plan or controls in place to prevent catastrophe 

legally operate similar lightweight, remote controlled UAS’s. 

I have developed my own personal operating procedures that I believe far 

exceeds the standards in place at this time. My objective is to prevent public 

hazards and well as manned aircraft / catastrophe.

This will act to further provide safe protocols exclusive to lightweight UAS's 

specific to real estate video and photography usage as Greenville Drone, LLC, 

record flight data and other information gained through permitted flight operations 

to share with the FAA through any required FAA reports to assist with future 

protocol and safety regulation. 

The name and address of the applicant is:

Greenville Drone, LLC

Attn: Chad T Cody

Email ccody@greenvilledrone.com

2 Dapple Grey Ct

Simpsonville, SC 29680

864-616-0316

Regulations from which the exemption is requested:

14 C.F.R. Part 21

14 C.F.R. 45.23 (b)

14 CFR 61.113(a); 

14 C.F.R. 91.7 (a)

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

14 C.F.R. 91.103

14 C.F.R. 91.109

14 C.F.R. 91.119

14 C.F.R. 91.121

14 C.F.R. 91.151 (a)

14 C.F.R. 91.203 (a) & (b)

14 C.F.R. 91.405 (a)
14 C.F.R. 407 (a) (1)

14 C.F.R. 409 (a) (2)

14 C.F.R. 417 (a) & (b)

This exemption application is expressly submitted to fulfill Congress' goal in 

passing

Section 333(a) through (c) of the Reform Act. This law directs the Secretary of 

Transportation to consider whether certain unmanned aircraft systems may 

operate safely in the national airspace system (NAS) before completion of the 

rulemaking required under Section 332 of the Reform Act. In making this 

determination, the Secretary is required to determine which types of UAV do not 

create a hazard to users of the NAS or the public or pose a threat to national 

security in light of the following:

• The UAV size, weight, speed, and operational capability;

• Operation of the UAV in close proximity to airports and populated areas; and

• Operation of the UAV within visual line of sight of the operator

Reform Act§ 333(a). Lastly, 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." Applicant interprets this provision to place the duty on the Administrator 

to not only process applications for exemptions under section 333, but for the 

Administrator to craft conditions for the safe operation of the UAS, if it should be 

determined that the conditions set forth herein do not fulfill the statutory 

requirements for approval. The Federal Aviation Act expressly grants the FAA 

the authority to issue exemptions. This statutory authority by its terms includes 

exempting civil aircraft, as the term is defined under §401 01 of the Act that

includes UAV, from the requirement that all civil aircraft must have a current 

airworthiness certificate.

The Administrator may grant an exemption from a requirement of a regulation 

prescribed under subsection (a) or (b) of this section or any sections 44702-

44716 of this title if the

Administrator finds the exemption in the public interest. 49 U.S.C. §44701(f) See 

also 49 USC §44711(a); 49 USC §44704; 14 CFR §91.203(a) (1).

Greenville Drone’s UAV’s consist of manufacturer built 4 engine multirotor craft, 

weighing 55 or fewer lbs. including payload. They operate, under normal 

conditions, at a speed of no more than 50 knots and have the capability to hover, 

and move in the vertical and horizontal plane simultaneously. They will operate 

only in line of sight and will operate only within a small controlled area described 
in the Confidential Operations Procedures, attached as Exhibit A (hereinafter 

"Procedures") Such operations will insure that the UAV will "not create a hazard 

to users of the national airspace system or the public.''

Applicant submits this Procedure as a Confidential and Proprietary document 

under 14

CFR 11 .35 (b) as the entire Procedures contains proprietary information that the 

applicant has not and will not share with others. The Procedures contains 

operating conditions and procedures that are not available to the public and are 

protected from release under the Freedom of Information Act 5 USC 552 et.seq.

Given the small size of the UAV’s involved and the restricted controlled 

environment within which they will operate, the applicant falls squarely within that 

zone of safety (an equivalent level of safety) in which Congress envisioned that 

the FAA must, by exemption, allow commercial operations of UAV’s to 

commence immediately. Also due to the size of the UAV’s and the controlled 

areas in which the relevant UAV’s will operate, approval of the application 

presents no national security issue. Given the following, the grant of the 

requested exemptions is clearly in the public interest:

• Clear direction in Section 333 of the Reform Act, the authority contained in the 

Federal Aviation Act, as amended

• The level of safety surrounding the proposed operations that implement the use 

of HD and thermal imagining, and the significant public benefit

• Innovative reductions in physical dangers of personnel climbing towers (e.g., 

thermal imaging of active wasp/hornet nests, electrical “hot spots”...) and/or the 

use of high-rise heavy equipment thus reduced emissions associated with 

allowing UAV’s operations.

Accordingly, the applicant respectfully requests that the FAA grant the requested 

exemption without delay. 

AIRCRAFT AND EQUIVALENT LEVEL OF SAFETY

The applicant proposes that the exemption requested herein apply to civil aircraft 

that have the characteristics and that operate with the limitations listed herein. 

These limitations provide for an exceptional level of safety to operations. These 

limitations and conditions to which Greenville Drone agrees to be bound when 

conducting commercial operations under an FAA issued exemption include:

DJI Inspire 1 unmanned aircraft is designed to hover in place via GPS and 

operate in less than a 13 knot (15 mph) wind. 

For safety, stability and fear of financial loss, I will not fly in winds exceeding

13 knot (15 mph). 
Built in safety systems include a GPS mode that allows my UAS to hover in place 

when radio controls are released. 

With three programmable flights modes to choose from, I utilize the Safe Mode

for aerial videography/photography. This is the safest, most reliable and stable 

mode to prevent accident and hazard. 

When pilot communication is lost UAS is designed to slowly descend to point of 

take off. 

No UAS operations near airports, Hospitals nor Police heliports, and do not 

operate near areas where general public is within fifty to one hundred (50-100) 

yards depending on location, conditions and weather. 

I am constantly on alert for any manned aircraft (Police/Medical helicopters, etc.) 

and prepared to land/abort immediately to the nearest and safest ground point 

should a manned aircraft approach my location or If I suspect manned aircraft 

may approach near my location. 

My UAS is capable of vertical and horizontal operations, and is flown only within 

my line of sight of my location, as the remote control pilot. 

Utilizing battery power rather than combustible fuels, flights generally last 

between ten (10) to fifteen (15) minutes, with an altitude under three hundred 

(300) feet 

 DJI Inspire UAS weighs less than 7 pounds complete with gimbal and high 

resolution camera system including battery system;

 I only operate my UAS below 350 feet (well within the 400 foot permissible 

ceiling set by the FAA Modernization and Reform Act of 2012); 

 My UAS only operates for 10-15 minutes per flight;

 I land my UAS prior to manufacturer recommended minimum level of 

battery power;

 I pilot my UAS through remote control only by line of sight, and with 

ground control spotter if and when needed for additional safety;

 My UAS has GPS a flight safety feature whereby it hovers and then slowly 

lands
if communication with the remote control pilot is lost;

 I actively analyze flight data and other sources of information to constantly 

update and enhance safety protocols;

 I only operate in reasonably safe environment that are strictly controlled, 

are away from power lines, elevated lights, airports and actively populated 

areas;

 I conduct extensive pre-flight inspections and protocol, during which safety 

carries primary importance;

 I always obtain all necessary permissions prior to operation; and,

I have procedures in place to abort flights in the event of safety breaches 

or potential danger. 

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 UAV. In all cases, an analysis of these criteria demonstrates that the 

UAV 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 UAV’s to be operated hereunder is less than 55 lbs. fully loaded, carries 

neither a pilot nor passenger, carries no explosive materials or flammable liquid 

fuels, and operates exclusively within a controlled area as set out in the 

Procedures. Unlike other civil aircraft, operations under this exemption will be 

tightly controlled and monitored by the operator, pursuant to the Procedures 

requirements. Lastly, application of these same criteria demonstrates that there 

is no credible threat to national security posed by the UAV, 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. §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 and the requirements contained in the Procedures 

for maintenance and use of safety checklists 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 UAV, 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 operator flying the UAV will have immediate 

access to it. The

FAA has issued the following exemptions to this regulation: Exemption Nos. 

8607, 8737, 8738, 9299, 9299A, 9565, 95658, 10167, 10167A, 10602, 32827, 

and 10700.

14 C.F.R. § 91.103: Preflight action
This regulation requires each operator 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. An equivalent level of 

safety will be provided as set forth in

Procedures. The operator will take all actions including 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. 

UAV’s 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. See Exemption 

Nos.5778K & 9862A. 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 UAV that is a helicopter and the exemption requests 

authority to operate at altitudes up to 400 AGL, an exemption may be needed to 

allow such operations.

As set forth herein, except for the limited conditions stated in the Procedures, the 

UAV will never operate at higher than 400 AGL.

The equivalent level of safety will be achieved given the size, weight, and speed 

of the UAV as well as the location where it is operated. In addition, the lowaltitude operations of the UAV will ensure separation between these small-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 UAV 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 Procedures and Safety Check list, 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."

In ideal conditions the battery powering the UAV provides approximately 40 

minutes of powered flight. To meet the 30-minute reserve requirement in 14 CFR 

§91 .151, UAV flights would be limited to approximately 10 minutes in length. 

Given the limitations on the UAV's proposed flight area and the location of its 

proposed operations within a predetermined area, a longer time frame for flight in 

daylight or night VFR conditions is reasonable.

Applicant believes that an exemption from 14 CFR §91 .151 (a) falls within the 

scope of prior exemptions. See Exemption 10673 (allowing Lockheed Martin 

Corporation to operate without compliance with FAR 91.151 (a)). Operating the 

small UAS, in a tightly controlled area, 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 UAV 

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 15 minutes or 15% of battery power whichever happens first. This 

restriction would be more than adequate to return the UAV to its planned landing 

zone from anywhere in its limited operating area.

Similar exemptions have been granted to other operations, including Exemptions 

2689F, 5745, 10673, and 10808.

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 UAV fully loaded weighs no more than 55 lbs and is operated without an on 

board pilot. As such, there is no ability or place to carry certification and 

registration documents or to display them on the UAV.

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

ground control point where the operator flying the UAV will have immediate 

access to them, to the extent they are applicable to the UAV. The FAA has 

issued numerous exemptions to this regulation. A representative sample of other 

exceptions includes Exemption Nos. 9565, 9665, 9789, 9789A, 9797, 9797A, 

9816A, and 10700.

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. The operator will 

accomplish maintenance pursuant to the flight manual and operating handbook 

as referenced in the Procedures. An equivalent level of safety will be achieved 

because these small UAV’s are very limited in size and will carry a small payload 

and operate only in controlled areas for limited periods of time. If mechanical 

issues arise the UAV can land immediately and will be operating from no higher 

than 400 feet AGL. As provided in the Procedures, the operator will ensure that 

the UAV 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.

Pursuant to 14 C.F.R. Part 11, the following summary is provided for publication 

in the

Federal Register, should it be determined that publication is needed:

Applicant seeks an exemption from the following rules:
14 C.F.R. §21, subpart H; 14 C.F.R 45.23(b); 14 C.F.R. §§ 61.113(a) & (b); 

91.7(a); 91.9(b) (2); 91.103(b); 91.109; 91.119; 91.121; 91.151(a); 91.203(a) and 

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

to operate commercially a small unmanned vehicle (551bs or less) for the 

purpose of inspection, monitoring, mapping and photographing attached 

equipment and engineering studies involving communication tower operations.

Approval of exemptions allowing commercial operations of UAV’s will create a 

level of safety by reducing risk. For example: Conventional tower structure 

inspections and associated tasks involve extreme risks to personnel physically 

climbing such structures and/or utilizing high rise equipment both of which create 

numerous and extreme risk to such personnel. In contrast, a UAV weighing fewer

than 55 lbs. and powered by batteries eliminates virtually all of that risk. The UAV 

will carry no passengers or crew and, therefore, will not expose personnel to any 

of the risks described above.

The operation of small UAV’s, weighing less than 55 lbs., conducted in the strict 

conditions outlined above, will provide a level of safety supporting the grant of the 

exemptions requested herein, including exempting the applicant from the 

requirements of Part 21 and allowing commercial operations. These lightweight 

aircraft operate at slow speeds, close to the ground, and in a controlled 

environment.

All flights will occur over private or controlled access property with the property 

owner's prior consent and knowledge. 

The granting of this exemption request will provide innovative safety operations. 

Satisfaction of the criteria provided in Section 333 of the Reform Act of 2012--

size, weight, speed, operating capabilities, proximity to airports 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 applicant's UAV in and pursuant to the 

Procedures appended hereto.

Respectfully,

Greenville Drone, LLC

2 Dapple Gray Ct

Simpsonville, SC 29680