Westside Drones

Lestley Pierce

13635 Vose St.

Van Nuys CA, 91405

Tele: (818)781-0877

May 15, 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; 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,

We, Westside Drones, are writing pursuant to the FAA 

Modernization and Reform Act of

2012 and the procedures contained within 14 C.F.R. 11, to 

request that Westside Drones, an owner and operator of small 

unmanned aircraft, be exempted from the

Federal Aviation Regulations (“FARs”) listed below so that We, 

Westside Drones, may operate our small ultra light weight 

unmanned aircraft system (“UAS”) commercially in airspace 

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

As described herein Westside Drones Members, are Certified 

Private Pilots in the United States; experienced in flying hobby 

Quad Copters for recreational purposes. Our Inventory includes a 

Two DJI Phantom 3 with 4k cameras and a 3DR Solo Smart 

Drone equipped with a GoPro Hero 4 with the intent for aerial 

videography/cinematography to enhance academic community 
awareness for those individuals and companies unfamiliar with 

the geographical layout of the Southern California area, and 

augment real estate listing videos; following exemption and 

approval by the FAA. Thereby enhancing their academic research 

experience for the Southern California area. UAS Specs Below:

Phantom 3 AircraftWeight (Including Battery And Propellers)

1280 g

Diagonal Size (Including Propellers)

590 mm

Max Ascent Speed

5 m/s

Max Descent Speed

3 m/s

Hover Accuracy

• Vertical: +/- 10cm

• Horizontal: +/- 1m

Max Speed

16 m/s (ATTI mode, no wind)

Max Altitude Above Sea Level

6000 m

Operating Temperature

0°C to 40°C

Gps Mode

GPS/GLONASS

3DR Solo Smart Drone AircraftCameras: Compatible with GoPro® HERO3, 3+ and 4; 

optimized for HERO3+ and 4
Streaming video quality: 720p

Flight time: 25 minutes; 20 minutes with payload*

Range: .5 miles** (.8 km)

Max speed: 55 mph (89 km/h)

Max ascent speed: 10 m/s in stabilize mode; “fly” mode spec 

forthcoming

Max descent speed: ditto

Max payload: 420 g

Max altitude: 400 ft per FAA regulation, user adjustable (122 m)

Motors: 880 kV

Propellers: 10ʺ diameter 4.5ʺ pitch self-tightening (24 cm 

diameter 144 cm pitch)

Autopilot: Pixhawk 2

Software: APM:Copter

Communication: 3DR Link secure WiFi network

Frequency: 2.4 GHz

Weight: 3.3 lbs. (1.5 kg) / 3.9 lbs. (1.8 kg) with GoPro® and 

Solo Gimbal

Dimensions: 10 in. tall (25 cm), 18 in. (46 cm) motor-to-motor

Flight battery: Lithium polymer 5200 mAh 14.8 Vdc
Battery charge time: ~1.5 hours

Controller battery: 2600 mAh 7.2 Vdc rechargeable lithium ion

Westside Drones is Committed to safety with each flight. 

Westside Drones exemption request would permit operation of 

ultra light weight, 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.

Granting our, Westside Drones, request comports with the 

Secretary of Transportation’s (FAA Administrator’s) responsibilities 

and authority to not only integrate UAS's into the national 

airspace system, but to “...establish requirements for the safe 

operation of such aircraft systems [UAS's] in the national airspace 

system” under Section 333(c) of the Reform Act specific to the 

use of UAS's for real estate/Realtor purposes. Further We, 

Westside Drones, will conduct our operations in compliance with 

the protocols described herein or as otherwise established by the 

FAA.

For the reasons stated below, We, Westside Drones, respectfully 

request the grant of an exemption allowing us to operate ultra 

light weight, remote controlled UAS’s for academic community 

awareness to benefit/stimulate attraction to the Los Angeles area 

and to enhance real estate listing videos for homeowners who 

cannot afford expensive manned aircraft for the same purpose. 

Both of which will promote local economic growth through 

increased employment and increased tax base. Both with public 

safety in mind by keeping heavier manned aircraft containing 

combustible fuel that poses potential public hazard.
I. Contact Information:

Westside Drones, Lestley Pierce

13635 Vose St. Van Nuys CA, 91405 Tele:(818) 781-0877

Email: SonnySly@gmail.com

II. The Specific Sections of Title 14 of the Code of Federal 

Regulations from which Westside Drones, Requests 

Exemption are:

14 CFR 21;

14 C.F.R. 45.23(b);

14 C.F.R. 91, et seq.;

14 CFR 407 (a) (1);

14 CFR 409 (a) (2); and, 14 CFR 417 (a) & (b).

III. The Extent of relief Westside Drones seeks and the 

Reason We Seek Such Relief:

We, Westside Drones, submit this application in accordance with 

the Reform Act, 112 P.L. 95 §§ 331-334, seeking relief from any 

currently applicable FARs operating to prevent we, Westside 

Drones, contemplated commercial cinematic, academic and other 

flight operations within the national airspace system. The Reform 

Act in Section 332 provides for such integration of civil unmanned 

aircraft systems into our national airspace system as it is in the 

public’s interest to do so. Our, Westside Drones, ultra light weight 

UAS meets the definition of “small unmanned aircraft” as defined 

in Section 331 and therefore the integration of our ultra light 

weight UAS is expressly contemplated by the Reform Act. We 

would like to operate our light weight UAS prior to the time period 

by which the Reform Act requires the FAA to promulgate rules 

governing such craft. Thereby, providing direct experience and 

valuable information for formal regulation that can be 

administered uniformly to all real estate related UAS aerial video 
and photography. The Reform Act guides the Secretary in 

determining the types of UAS's that may operate safely in our 

national airspace system. Considerations include: The weight, 

size, speed and overall capabilities of the UAS's; Whether the 

UAS will be operated near airports or heavily populated areas; 

and, Whether the UAS will be operated by line of sight. 112 P.L. 

95 § 333 (a). Each of these items reflect in favor of an exemption 

for us, Westside Drones. Our UAS utilizes eight (4) counterrotating propellers for balance, control and stability. Our UAS is 

equipped with GPS and auto return safety technology. Weighing 

less than fifteen (20) pounds (far below the max. 55 pound limit); 

including camera with gimbal.

Westside Drones, considers safety as foremost with each flight. 

Our small 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 we will not fly in winds exceeding

13 knot (15 mph). Built in safety systems include a GPS mode 

that allows our UAS to hover in place when radio controls are 

released. 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. We are 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 our location or we suspect 

manned aircraft may approach near our location. Our UAS is 

capable of vertical and horizontal operations, and are flown only 

within our line of sight of us, 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. We, Westside Drones, utilize a fresh 

fully charged battery with each flight as a safety precaution; full 

flight time limit for each battery is ten (10) to fifteen (15) minutes 

as tested. We do not operate our UAS at or below manufacture 

recommend minimum charge levels for operation; preferring to 
remain well within a safe operating range to insure adequate 

communication between radio control and UAS to eliminate 

potential for crash, loss of control or hazard. Reserve batteries 

are at hand with each exercise to insure replacement for sufficient 

safe level of operation. We do not believe in taking risk that may 

cause a crash, that could create hazard to the public/property/

manned aircraft, and have no desire to lose an investment. We 

have clocked numerous practice flights in remote areas as a 

hobbyist simulating flights for future commercial use to gain 

familiarization with the characteristics of this specific UAS's 

performance under different temperature and weather conditions.

We, Westside Drones, are extremely cautious when operating our 

UAS/ultra light weight unmanned aircraft and will not “create a 

hazard to users of the national airspace system or the public.” 112 

P.L. 95 § 333 (b). Given the small size and weight of our UAS it 

falls well within Congress’s contemplated safety zone when it 

promulgated the Reform Act and the corresponding directive to 

integrate UAS's into the national airspace system. Westside 

Drones UAS, used in hobby flight, has a demonstrable safety 

record and does not pose any threat to the general public or 

national security.

IV. How Westside Drones Request Will Benefit the Public As 

A Whole:

Aerial videography for geographical awareness and for real estate 

marketing has been around for a long time through manned fixed 

wing aircraft and helicopters. For small budget real estate 

companies and average homeowners the expense of such aerial 

videography is cost prohibitive. Only large companies and high 

end Realtors or luxury homeowners can afford to absorb such 

expense. Depriving non-luxury homeowners and lower budget 

Realtors from a valuable marketing tool. Manned aircraft pose a 

threat to the public through potential catastrophic crash that the 

Los Angeles community has experienced in the past with military 

aircraft and medical helicopter crashes within the SoCal area. 
Each resulting in loss of life. Each with combustible fuel that 

exploded and burned on impact. Police helicopters have made 

emergency hard landings within city limits. Our, Westside Drones, 

UAS pose no such threat since size and lack of combustible fuel 

alleviates any potential threat to the public.

Congress has already proclaimed that it is in the public’s interest 

to integrate commercially flown UAS's into the national airspace 

system, hence the passing of the Reform Act. Granting Our, 

Westside Drones, exemption request furthers the public interest 

through academic/visual awareness of the geographical benefits 

in and around the Los Angeles area. Our ultra light weight UAS is 

battery powered and creates no emissions that can harm the 

environment. The consequence of my ultra light weight UAS 

crashing is far less than a full size helicopter or fixed wing aircraft; 

which are heavy, contain combustible fuel and can cause 

catastrophic devastation to the public.The public’s interest is 

furthered by minimizing ecological and crash threat by permitting 

aerial video/photo capture through our battery operated ultra light 

weight UAS's. Permitting us, Westside Drones, to immediately fly 

within national air space furthers economic growth. Granting our 

exemption request substantially furthers the economic impact for 

the Los Angeles community for companies looking to relocate or 

build in the SoCal area as well as individuals looking to relocate 

for career advancement through academic and geographical 

awareness. Both of which serve as a stimulus to the community.

V. Reasons Why Westside Drones Exemption Will Not 

Adversely Affect Safety Or How The Exemption Will 

Provide a Level of Safety At Least Equal To Existing Rule:

Our, Westside Drones, exemption will not adversely affect safety. 

Quite the contrary, for the reasons stated permitting us, Westside 

Drones, to log more flight time in FAA controlled airspace, with 

communication with the FAA, will allow us to contribute to the 

innovation and implementation of new and novel, as of yet 
undiscovered safety protocols for Realtors that can be embraced 

by the National Association of Realtors and California Association 

of Realtors, for development in cooperation with the FAA. In 

addition We, Westside Drones, submit the following 

representations of enhancements to current aerial videography 

and photography for real estate:

Our UAS weighs less than 20 pounds complete with gimbal and 

high resolution Cameras;

We only operate our UAS below 300 feet (well within the 400 foot 

permissible ceiling set by the FAA Modernization and Reform Act 

of 2012);

Our UAS only operate for 10-15 minutes per flight;

We land our UAS prior to manufacturer recommended minimum 

level of battery power;

We pilot our UAS through remote control only by line of sight;

Our UAS has GPS a flight safety feature whereby it hovers and 

then slowly lands

if communication with the remote control pilot is lost;

We actively analyze flight data and other sources of information to 

constantly update and enhance safety protocols;

We only operate in reasonably safe environment that are strictly 

controlled, are away from power lines, elevated lights, airports 

and actively populated areas;

We conduct extensive pre-flight inspections and protocol, during 

which safety carries primary importance; and

We always obtain all necessary permissions prior to operation.

Our, Westside Drone, safety protocols provide a level of safety 

equal to or exceeding existing rules. It is important to note that 

absent the integration of commercial UAS into our national 

airspace system, helicopters are the primary means of aerial 

video and photography for community awareness and real estate. 

While the safety record of such helicopters is remarkably 

astounding, there has been local incident involving loss of life as 

well as extensive property damage; it is far safer to operate a 
battery powered ultra light weight UAS.

First, the potential loss of life is diminished because UAS's carry 

no people on board and we only operate our UAS in specific 

areas away from mass populations. 

Second, there is no fuel on board a UAS and thus the potential for 

fire or explosions is greatly diminished.

Third, the small size and extreme maneuverability of our UAS 

allows us to remotely pilot away from and avoid hazards quickly 

and safely.

Lastly, given its small size and weight, even when close enough 

to capture amazing images, our UAS need not be so close to the 

objects they are focused on through the technology and use of 

post editing software allowing pan and zoom.

Accordingly, our UAS has been experimentally operated for 

familiarization/competency and will continue to operate at and 

above current safety levels.

VI. A Summary The FAA May Publish in the Federal 

Register:

A. 14 C.F.R. 21 and 14 C.F.R. 91: Airworthiness Certificates, 

Manuals and The Like.

14 C.F.R. 21, Subpart H, entitled Airworthiness Certificates, sets 

forth requirements for procurement of necessary airworthiness 

certificates in relation to FAR § 91.203(a)(1). The size, weight and 

enclosed operational area of our, Westside Drones, UAS permits 

exemption from Part 21 because our UAS meets (and exceeds) 

an equivalent level of safety pursuant to Section 333 of the 

Reform Act. The FAA is authorized to exempt aircraft from the 

airworthiness certificate requirement under both the Act (49 

U.S.C. § 44701 (f)) and Section 333 of the Reform Act. Both 
pieces of legislation permit the FAA to exempt UAS's from the 

airworthiness certificate requirement in consideration of the 

weight, size, speed, maneuverability and proximity to areas such 

as airports and dense populations. Our, Westside Drones, current 

and projected UAS's meet or exceed each of the elements.

14 C.F.R. 91.7(a) prohibits the operation of an aircraft without an 

airworthiness certificate. As no such certificate will be applicable 

in the form contemplated by the FARs, this Regulation is 

inapplicable.

14 C.F.R. § 91.9 (b) (2) requires an aircraft flight manual in the 

aircraft. As there are no on board pilots or passengers, and given 

the size of the UAS's, this Regulation is inapplicable. An 

equivalent level of safety will be achieved by maintaining our, 

Westside Drones, safety protocols. The FAA has previously 

issued exemptions to this regulation in Exemption Nos. 8607, 

8737, 8738, 9299, 9299A, 9565, 9565B, 10167, 10167A, 10602, 

10700 and 32827.

14 C.F.R. § 91.121 regarding altimeter settings is inapplicable insofar 

as our UAS utilizes electronic global positioning systems with a 

barometric sensor.

14 C.F.R. § 91.203 (a) and (b) provides for the carrying of civil aircraft 

certifications and registrations. They are inapplicable for the same 

reasons described above. The equivalent level of safety will be 

achieved by maintaining any such required certifications and 

registrations by us, Westside Drones.

14 C.F.R. § 45.23: Marking of The Aircraft.

Applicable Codes of Federal Regulation require aircraft to be marked 

according to certain specifications. Our UAS are, by definition, 

unmanned. They therefore do not have a cabin, cockpit or pilot station 

on which to mark certain words or phrases. Further, two-inch lettering 

is difficult to place on such small aircraft with dimensions smaller that 

minimal lettering requirement. Regardless, We will mark our UAS in 

the largest possible lettering by placing the word “EXPERIMENTAL” 
on its fuselage as required by 14 C.F.R. §45.29 (f) so that we the pilot, 

or anyone assisting me as a spotter with the UAV will see the 

markings. The FAA has previously issued exemptions to this 

regulation through Exemptions Nos. 8738, 10167, 10167A and 10700.

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

14 C.F.R. § 91.119 prescribes safe altitudes for the operation of civil 

aircraft. It allows helicopters to be operated at lower altitudes in certain 

conditions. Our UAS will never operate at an altitude greater than 300 

AGL; safely below the standard of 400 AGL. We, Westside Drones, 

will however operate our UAS in safe areas away from public and 

traffic, providing a level of safety at least equivalent to or below those 

in relation to minimum safe altitudes. Given the size, weight, 

maneuverability and speed of our UAS, an equivalent or higher level 

of safety will be achieved.

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

Maintenance Inspections.

The above-cited Regulations require, amongst other things, aircraft 

owners and operators to “have [the] 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. . . .”

These Regulations only apply to aircraft with an airworthiness 

certificate. They will not, therefore, apply to our, Westside 

Drones,UAS. However, as a safety precaution we inspect our UAS 

before and after each flight as well as maintaining a maintenance log.

A Summary The FAA May Publish in the Federal Register:

A. 14 C.F.R. 21 and 14 C.F.R. 91: Airworthiness Certificates, 

Manuals and The Like. 14 C.F.R. 21, Subpart H, entitled 

Airworthiness Certificates, sets forth requirements for 

procurement of necessary airworthiness certificates in relation to 

FAR § 91.203(a)(1). The size, weight and enclosed operational 

area of our UAS permits exemption from Part 21 because our, 

Westside Drones, UAS meets an equivalent level of safety 
pursuant to Section 333 of the Reform Act. The FAA is authorized 

to exempt aircraft from the airworthiness certificate requirement 

under both the Act (49 U.S.C. § 44701 (f)) and Section 333 of the 

Reform Act. Both pieces of legislation permit the FAA to exempt 

UAS's from the airworthiness certificate requirement in 

consideration of the weight, size, speed, maneuverability and 

proximity to areas such as airports and dense populations. Our 

UAS meets or exceeds each of the elements. 14 C.F.R. 91.7(a) 

prohibits the operation of an aircraft without an airworthiness 

certificate. As no such certificate will be applicable in the form 

contemplated by the FARs, this Regulation is inapplicable. 14 

C.F.R. § 91.9 (b) (2) requires an aircraft flight manual in the 

aircraft. As there are no pilots or passengers, and given the size 

of the UAS's, this Regulation is inapplicable. An equivalent level 

of safety will be achieved by maintaining a manual. The FAA has 

previously issued exemptions to this regulation in Exemption Nos. 

8607, 8737, 8738, 9299, 9299A, 9565, 9565B, 10167, 

maintenance program that involves regular software updates and 

curative measures for any damaged hardware. Therefore, an 

equivalent level of safety will be achieved.

In summary, Westside Drones seeks an exemption from the 

following Regulations:

14 C.F.R. 21, subpart H; 14 C.F.R. 45.23(b); 14 C.F.R. § 91.7 (a); 

14 C.F.R. § 91.9 (b)(2); 14 C.F.R. § 91.103(b); 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) and (b); 14 C.F.R. § 91.405 (a); 14 C.F.R. § 

91.407 (a)(1); 14 C.F.R. § 91.409 (a)(2); 14 C.F.R. § 91.409 (a ) 

(2); and, 14 C.F.R. §§ 91.417 (a) & (b) to commercially operate 

our, Westside Drones, small unmanned vehicle/lightweight 

unmanned aircraft vehicle in community awareness and real 

estate operations, and to develop economic platforms for real 

estate to enhance the experience of those seeking to relocate to 

the Los Angeles area. Currently, area awareness and real estate 

aerial videography/photography relies primarily on the use of 
larger aircraft running on combustible fuel. Posing potential risk to 

the public. Granting our, Westside Drones, request for exemption 

will reduce current risk levels and thereby enhance safety. Our 

UAS craft do not contain potentially explosive fuel, is smaller, 

lighter and more maneuverable than conventional real estate 

video and photographic aircraft with less flight time. Further, We 

operate at lower altitudes and in controlled airspace eliminating 

potential public risk flying to and from established air fields. We, 

Westside Drones have been informally analyzing flight information 

and will compile safety protocols and the implementation of a 

flight operations manual for real estate usage that exceeds 

currently accepted means and methods for safe flight. Formal 

collection of information shared with the FAA will enhance the 

FAA's internal efforts to establish protocols for complying with the 

FAA Modernization and Reform Act of 2012. There are no 

personnel on board our, Westside Drones, UAS and therefore the 

likelihood of death or serious bodily injury is significantly 

diminished. our, Westside Drones, operation of our UAS, 

weighing less than 20 pounds and traveling at lower speeds 

within limited areas will provide an equivalent level of safety as 

that achieved under current FARs. Accordingly We, Westside 

Drones, respectfully request that the FAA grant our exemption 

request and are willing

to cooperate in sharing information to benefit the FAA, safety of 

manned aircraft, and the general public at large.

Respectfully submitted,

Westside Drones, Lestley Pierce

13635 Vose St. Van Nuys CA, 91405