Northwest Drone Services 

8425 49th LP Se

Olympia, WA

December 23, 2015

U.S. Department of Transportation

Docket Management System 1200

New Jersey Ave., SE Washington DC 20590

Re: Exemption Request Pursuant to Section 333 of the FAA Reform Act and Part 11 of the Federal

Aviation

Regulations from: 14 CFR 21 subpart H; 14 CFR 45.23(b); 14 CFR 61.113(a); 14 CFR 91.7(a); 14 CFR

91.9(b)(2); 14 CFR 91.103;14 CFR 91.109; 14 CFR 91.119(c); 14 CFR 91.121; 14 CFR 91.151(a); 14

CFR 91.203 (a) and (b); 14 CFR 91.405 (a); 14 CFR 91.407 (a) (1) 14 CFR 91.409 (a)(1) and (2); 14 CFR

91.417(a) and (b)

To whom it may concern:

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 and 14 CFR Part 11,

Northwest Drone Services, operators of small Unmanned Aerial Systems (UAS), hereby applies for an

exemption from the listed Federal Aviation Regulations to allow commercial operation of a small UAS,

so long as such operations are conducted within and under the conditions outlined herein or as my be

established by the FAA as required by Section 333.

Commercial operation small UAS, as described herein, which are equipped with cameras and sensors,

would operate in the following manner:

1. Aerial photography and/or video for public and/or private use including real estate,

architecture, land surveying, engineering and other related professional activities.

2. Aerial video and/or photography for public and/or private use including television, public

events, and cinematography.

 3. Aerial inspection/photography of residential/commercial structures under contract with the 

owners or local government authority.

4. Aerial video/photography or providing live video feed to assist with search and rescue

operations in cases of an emergency or natural disaster only when the local authorities or 

government has requested it by contract or donation.

As described fully below, the requested exemption would permit the operation of small UAS under

controlled conditions in the NAS that would be a) limited b) controlled c) predetermined and d) will

provide safety enhancements to the already safe operations in the industry presently using conventional

aircraft. Approval of this exemption would thereby enhance safety and fulfill the Secretary of

Transportation’s (the FAA Administrator’s) responsibilities to “....establish requirements for the safe

operation of such aircraft systems in the national airspace system.”

The name, phone, email and address of the applicant:
Name: Northwest Drone Services

Phone: (360) 489-4720

Email: northwestdroneservices@yahoo.com 

Address: 8425 49th LP Se Olympia WA, 98513

Regulations from which the exemption is requested:

14 CFR Part 21 subpart H

14 CFR 45.23 (b)

14 CFR 61.113(a)

14 CFR 91.7 (a)

14 CFR 91.9 (b) (2)

14 CFR 91.103

14 CFR 91.109

14 CFR 91.119(c)

14 CFR 91.121

14 CFR 91.151 (a)

14 CFR 91.203 (a) & (b)

14 CFR 91.405 (a)

14 CFR 91.407 (a) (1)

14 CFR 91.409 (a) (2)

14 CFR 91.417 (a) & (b)

The small UAS’s we will be using are multi-rotor craft weighing no more than 55lbs. including

payload. Under normal conditions they operate at speeds of no more than 45 Mph or 39 Knots and 

have the ability hover and move along a vertical and horizontal plane simultaneously. They will

operate in line of sight only and by the exempted person only obeying all other local and federal laws.

Given the small size of the small UAS and the controlled environment provided the proposed

operations will adhere to the Reform Act’s safety requirements. The approval of this application

presents no national security issues. Regarding the level of safety surrounding the proposed operations

and the public benefit, reduction in environmental impacts, including but not limited to reduced

emissions and noise, the grant of the requested exemption is in the public interest. Accordingly the

applicant requests that the FAA grant the requested exemption with minimum delay.

AIRCRAFT AND EQUIVALENT LEVEL OF SAFETY

The operation limitations proposed for an equivalent or higher level of safety because operations will

further enhance the safety of the persons and/or property using conventional aircraft.

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

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

 The small UAS will weigh less than 55 lbs.

 Flights will be operated within line of sight of a pilot and the observer.

 Maximum flight time for each operational flight will be 30 minutes. Flights will be terminated at

25% battery power reserve or 20 minutes of flight time whichever occurs first.

 Flights will be operated at an altitude of no more than 400 feet Above Ground Level (AGL) and 

not more than 200 feet above an elevated platform from which filming is planned.

 Minimum crew for each operation will consist of the small UAS Pilot in Command (PIC), the

Visual Observer (VO) and maintenance crew on hand.

 6. The small UAS pilot will be Mitchel Lanyon, Brandon Renner or Raul Hilderbrandt ONLY not

allowing any other person(s) to operate the small UAS in a commercial capacity.
 7. A briefing will be performed regarding the planned small UAS operations prior to each

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

 8. The PIC will obtain verbal/written consent of all persons involved with the planned operation

and ensure that only consenting persons will be allowed within 100 feet of the flight operation, and

the radius may be reduced to 30 feet based upon an equivalent level of safety determination, as

required under the FOM. With the advanced permission or direction of the FSDO, operations at

closer range may be approved.

 9. The PIC and VO will have been trained in operation of small UAS and receive up-to-date 

information for the particular small UAS to be operated and will be able to show upon request their

competent ability to operate the small UAS and/or Camera.

 10. The PIC and VO will be able to communicate by voice at all times

 11. Written and/or verbal permission and permits will be obtained from territorial, state, county or

city jurisdictions, including law enforcement, fire or other appropriate governmental agencies

when needed.

 12. If the small UAS loses communications or loses GPS signal, the small UAS will have the

capability to return to a pre-determined location within a designated location and land

autonomously.

 13. The small UAS will have the capability to abort a flight in case of unpredicted obstacles,

weather, or emergencies.

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

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

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

area associated with the aircraft to be utilized by the Applicant, an exemption from Part 21 Subpart H

meets the requirements of an equivalent level of safety under Part 11 and Section 333 of the Reform

Act. The Federal Aviation Act (49 U.S.C.§44701 (f)) and Section 333 of the Reform Act both authorize

the FAA to exempt aircraft from the requirement for an airworthiness certificate, upon consideration of

the size, weight, speed, operational capability, and proximity to airports and populated areas of the

particular small UAS. In all cases, an analysis of these criteria demonstrates that the small UAS

operated without an airworthiness certificate, in the restricted environment and under the conditions

proposed will be at least as safe, or safer, than a conventional aircraft (fixed wing or rotorcraft)

operating with an airworthiness certificate without the restrictions and conditions proposed.

The small UAS 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

secured and designated area. Unlike other civil aircraft, operations under this exemption will be tightly

controlled and monitored by both the operator and under the requirements and in compliance with local 

public safety requirements. These safety enhancements provide a greater degree of safety to the public

and property owners than conventional operations conducted with airworthiness certificates issued under

14 C.F.R. Part 21, Subpart H. Lastly, application of these same criteria demonstrates that there is no

credible threat to national security posed by the small UAS, due to its size, speed of operation, location

of operation, lack of explosive materials or flammable liquid fuels, and inability to carry a substantial 

external load.

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

The regulation requires: When marks include only the Roman capital letter "N" and the registration

number is displayed on limited, restricted or light-sport category aircraft or experimental or
provisionally certificated aircraft, the operator must also display on that aircraft near each entrance to

the cabin, cockpit, or pilot station, in letters not less than 2 inches nor more than 6 inches high, the

words "limited," "restricted," "light-sport," "experimental," or "provisional," as applicable.

Even though the small UAS will have no airworthiness certificate, an exemption may be needed as the

small UAS will have no entrance to the cabin, cockpit or pilot station on which the word “Experimental”

can be placed. Given the size of the small UAS, two-inch lettering will be impossible. The word

“Experimental” will be placed on the fuselage in compliance with §45.29 (f). The equivalent level of

safety will be provided by having the small UAS marked on its fuselage as required by §45.29 (f) where

the pilot, observer and others working with the small UAS will see the identification of the small UAS as

“Experimental.”

14 C.F.R. § 61.113(a): Private Pilot Privileges and Limitations: Pilot in Command.

Pursuant to 14 CFR 61.113 (a), no person who holds a private pilot certificate may act as a pilot

in command of an aircraft that is carrying passengers or property for compensation or hire. Our 

small UAS does not carry any pilots or passengers nor property therefore we Northwest Drone 

Services are seeking an exemption to 14 CFR 61.113(a). Although helpful, a pilot’s license will

not ensure remote control piloting skills. All three of us, Co-Owners of Northwest Drone 

Services serve in Army Aviation with a total combined experience of 25 years. Brandon Renner 

and Raul Hilderbrandt understand Aviation, Inherent Risk, Accident Avoidance and Aerospace 

surveillance both serving (Currently) in Special Operations Aviation. Mitchel Lanyon is 

currently seeking his Privates Pilots License and holds an Airframe and Power-plant 

certification. The risks attendant to the operation of small UAS is far less than the risk levels

inherent in the commercial activities outlined in 14 CFR 61. I feel the operation and limitations 

set forth in the FOM will equate to the safe operation of the small UAS.

The safe operation and control of the UAS as described in this application does not depend on the

type of FAA license held by the PIC. That knowledge can be and is gained primarily through

practice and experience and not through flight training in fixed wing or rotor aircraft, nor is it

dependent on the acquisition of a commercial or private pilot’s certificate. Those certificates

demonstrate knowledge of the factors and skills needed for the safe operation of those types of

aircraft (fixed wing or rotorcraft). It cannot be assumed that any type of pilot, approved to operate a

helicopter or fixed wing aircraft, has the skill or ability to safely operate a small unmanned aerial

vehicle, operating at 400 AGL or lower, within strictly controlled pre-approved airspace. From a

practical standpoint, there are relatively few licensed full-scale aircraft pilots who are also qualified

to fly the type of UAS that are utilized for infrastructure image- capture operations. There are even

fewer pilots that can fly these UAS – to the point that to do both is considered rare

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

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

condition. As there will be no airworthiness certificate issued for the aircraft, should this

exemption be granted, no FAA regulatory standard will exist for determining airworthiness. Given

the size of the aircraft for maintenance and use of safety 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 small UAS,

given its size and configuration has no ability or place to carry such a flight manual on the

aircraft, not only because there is no pilot on board, but because there is no room or capacity to

carry such an item on the aircraft. The equivalent level of safety will be maintained by keeping

the flight manual at the ground control point where the pilot flying the small UAS will have 

immediate access to it.

14 C.F.R. § 91.103: Preflight Action.

This regulation requires each pilot in command to take certain actions before flight to insure the 

safety of flight. As FAA approved rotorcraft flight manuals will not be provided for the aircraft an

exemption will be needed. The 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.

Small UAS and remotely piloted aircraft, by their design do not have fully functional dual

controls. Flight control is accomplished through the use of a control box that communicates with

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

without fully functional dual controls for a number of aircraft and for flight instruction in

experimental aircraft. The equivalent level of safety provided by the fact that neither a pilot nor

passengers will be carried in the aircraft and by the size and speed of the aircraft.

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

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

helicopters to be operated at less than the minimums prescribed, provided the person operating the

helicopter complies with any route or altitudes prescribed for helicopters by the FAA. As this

exemption is for a small UAS that is a helicopter and the exemption requests authority to operate at 

altitudes up to 400 AGL, or not more than 200 above an elevated platform from which filming is

planned, an exemption may be needed to allow such operations. As set forth herein, the small UAS

will never operate at higher than 400 AGL with the exception that in circumstances where the 

small UAS is used to survey or photograph a structure whose height exceeds 400 feet AGL, the

small UAS will not be operated more than 100' above the highest point on the structure. It will

however be operated in a restricted area with security perimeter, where buildings and people will

not be exposed to operations without their pre-obtained consent. The equivalent level of safety will

be achieved given the size, weight, speed of the small UAS as well as the location where it is

operated. No flight will be taken without the permission of the property owner or local officials.

Because of the advance notice to the property owner and participants in the filming activity, all

affected individuals will be aware of the planned flight operations. Compared to flight operations

with aircraft or rotorcraft weighting far more than the maximum 55lbs. proposed herein and the 

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

presented with conventional aircraft operating at or below 500 AGL. In addition, the low-altitude

operations of the small UAS 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 small UAS may not have a barometric

altimeter, but instead a GPS altitude read out, an exemption may be needed. An equivalent level

of safety will be achieved by the operator, pursuant to the safety check list and live flight data

monitoring, confirming the altitude of the launch site shown on the GPS altitude indicator before

flight.
 

14 C.F.R. § 91.151(a): Fuel Requirements for Flight in VFR Conditions

Section 91.151 (a) prohibits an individual from beginning “a flight in an airplane under VFR

conditions unless (considering wind and forecast weather conditions) there is enough fuel to fly

to the first point of intended landing, and, assuming normal cruising speed – (1) During the day,

to fly after that for at least 30 minutes; or (2) At night, to fly after that for at least 45 minutes.”

The battery powering the small UAS provides approximately 30 minutes of powered flight. To 

meet the 30 minute reserve requirement in 14 CFR §91.151, small UAS flights would be limited

to approximately 10 minutes in length. Given the limitations on the small UAS’s proposed

flight area and the location of its proposed operations within a predetermined area, a longer time

frame for flight in daylight or twilight VFR conditions is reasonable. Applicant believes that an

exemption from 14 CFR §91.151(a) falls within the scope of prior exemptions. Operating the 

small UAS, in a tightly controlled area where only people and property owners or official 

representatives who have signed waivers will be allowed, with less than 30 minutes of reserve

fuel, does not engender the type of risks that Section 91.151(a) was intended to alleviate given

the size and speed of the small UAS. Additionally, limiting small UAS flights to 10 minutes 

would greatly reduce the utility for which the exemption will be granted. Applicant believes that

an equivalent level of safety can be achieved by limiting flights to 30 minutes or 25% of battery

power— whichever happens first. This restriction would be more than adequate to return the

small UAS to its planned landing zone from anywhere in its limited operating area.

14 C.F.R. §91.203 (a) and (b): Carrying Civil Aircraft Certification and Registration

The regulation provides in pertinent part:

(a) Except as provided in § 91.715, no person may operate a civil aircraft

unless it has within it the following:

(1) An appropriate and current airworthiness certificate. . . .

(b) No person may operate a civil aircraft unless the airworthiness certificate

required by paragraph (a) of this section or a special flight authorization issued under

§91.715 is displayed at the cabin or cockpit entrance so that it is legible to passengers or

crew.

The small UAS fully loaded weighs no more than 55 lbs. and is operated without an onboard 

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

to display them on the small UAS.

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

point where the pilot flying the small UAS will have immediate access to them; to the extent

they are applicable to the small UAS.

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

These regulations require that an aircraft operator or owner “shall have that aircraft inspected as 

prescribed in subpart E of this part and shall between required inspections, except as provided in 

paragraph (c) of this section, have discrepancies repaired as prescribed in part 43 of this
chapter...,” and others shall inspect or maintain the aircraft in compliance with Part 43. Given that

these section and Part 43 apply only to aircraft with an airworthiness certificate, these sections

will not apply to the applicant. Maintenance will be accomplished by the operator pursuant to the 

flight manual and operating handbook. An equivalent level of safety will be achieved because

these small UASs are very limited in size and will carry a small payload and operate only in

restricted areas for limited periods of time. If mechanical issues arise the small UAS can land 

immediately and will be operating from no higher than 400 feet AGL. The operator will ensure

that the small UAS is in working order prior to initiating flight, perform required maintenance,

and keep a log of any maintenance performed.

Moreover, the operator is the person most familiar with the aircraft and best suited to

maintain the aircraft in an airworthy condition to provide the equivalent level of safety.

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

performed in accordance with the small UAS Manufacturer's Manual, as referenced in the

Aircraft Operations Manual (AOM). As provided in the FOM, the operator will ensure that the

small UAS is in working order prior to initiating flight and perform required maintenance

needed.

Small UAS Information

Small UAS’s to be used are as follows but not limited to providing they are within the 

scope of the exemption granted by the FAA:

1. DJI Phantom 3 Pro (P3VP)

*See Attached User Manual for Full Specs*

2. 3DR SOLO

*See Attached User Manual for All Specs*

3. 3DR IRIS+

*See Attached User Manual for All Specs*

At Northwest Drone Services, we sincerely appreciate your consideration for this exemption.

Northwest Drone Services