SECTION 333 EXEMPTION PETITION

U.S. Department of Transportation

Docket Management System

1200 New Jersey Avenue SE

Washington, DC 20590

Re: Exemption Request Section 333 of the FAA Reform act & Part 11 of the Federal 

Aviation Regulations from 14 C.F.R.45.23(b); 14 CFR Part 21; 14 CFR 61.113(a) & (b); 

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

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

To Whom It May Concern:

RE: Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the 

Reform Act) and 14 C.F.R Part 11, Sugar Rock, LLC an advertising agency and 

photography company and operator of a small (UAS) equipped for photos and videos, 

hereby applies for an exemption from the listed Federal Aviation Regulations (“FARs”) 

to allow commercial operations of its UASs, so long as such operations are conducted 

within and under the conditions outlined herein or as may be established by the FAA and 

required by Section 333.

Purpose of the proposed flight will be to provide:

 Photos and videos used to promote tourism for Municipalities, Hotels & Resorts 

and Recreational Areas

 Photos and videos of Real Estate listings offered for rental and sale

 Photos promoting land for sale

 Golf Course Photography & Course Video Tour

 Cinematography

 Crop Monitoring

 Property Surveys

 Property & Pipeline inspections

 Nature Photography & Videography.

 Photos and videos taken with UASs will be promoted on company’s websites 

(sugar-rock.com), Facebook, Instagram, Twitter & and other Social Media 

websites.
The name and address of the Applicant is:

SUGAR ROCK, LLC.

Attn: Benjamin Hassell

PH: 903-887-4561

Email: info@sugar-rock.com

Address: 

1302 S. 3rd Street, STE 102

Mabank, Texas 75147

Public Interest and National Security 

Sugar Rock, LLC intends to service the needs of aerial filming and photography for the 

purposes of advertising and marketing in a variety of industries. Traditional methods of 

aerial filming and photography are handled by full sized, fixed and rotor wing aircraft 

which are no longer competitive when compared to the low acquisition and operating 

costs of small unmanned aircraft systems. These cost savings can be directly transferred 

to the consumer to create competitiveness in the market place. Full sized aircraft have a 

greater environmental impact. They are significantly louder to operate than small, fully 

electric unmanned aircraft systems and carry a much larger carbon “footprint" adding to 

the growing concern of the emissions of greenhouse gases. Being all electric is beneficial 

in that it is significantly quieter and less likely to disrupt the peace of the surrounding 

flight operations area. Full sized aircraft carry flammable fuels and flight crew and/or 

passengers. There is a great deal of danger imposed to the flight crew and/or passengers 

and to those on the ground in the event of an emergency with regard to full size aircraft. 

This danger is considerably less in comparison with the UAS due to its small size, 

maximum forward speed and lack of flammable fuels. Because Sugar Rock, LLC will 

have a public presence for commercial UAS aerial filming and photography, we will be 

available and willing to assist in disaster relief. There is no threat to National Security 

due to the Transportation Security Administration security screening of certificated 

airmen. The PIC is U.S. Citizen with zero criminal back ground and zero FAA violations 

and is greatly concerned in ensuring the public maintains their right to privacy. We 

believe that because of advancing technologies, small unmanned aircraft systems are 

much less expensive to acquire, easier to operate, and less demanding to maintain when 

compared to full size aircraft. UAS aerial services, such as filming, surveying, inspection 

and surveillance will undoubtedly promote public interest. 

Note: Our DJI Phantom 3 Advanced is sophisticated equipment with a built in software 

that does not allow the drone to operate within 15 miles of the white house are other high 

security areas. Furthermore our DJI application also displays “no fly” zones so we can 

maintain safe distance from other aircraft.
Pilot In Command (PIC)

Name: Daniel Guiter

FAA Certificate #: 482669880

FAA Certifications/Ratings: 

 Commercial Pilot Privileges

 PIC holds over 2000 hours total time

General Operating Flight Crew Requirements 

Ø Only the PIC shall be required to maintain a valid Pilot's License (Private, 

Commercial or ATP) issued by the FAA as prescribed by 14 CFR Part 61. The 

PIC shall maintain his or her Flight Review currency requirements as per 14 CFR 

part 61.56 and 3rd, 2nd, or 1st Class Medical Certificate as prescribed by 14 CFR 

Part 67. 

Ø Prior to any UAS flight, the PIC shall be trained in all aspects of flight 

operations. Training will include, but is not limited to; Personal Computer Flight 

Simulation that is similar to the flight characteristics and control of the UAS to be 

used; actual flight training with the UAS to be used in a designated flight area.

Ø Prior to any commercial flight operations, the PIC shall have accrued at least 25 

hours of documented flight time with the UAS being operated by Sugar Rock, 

LLC. The PIC and VO shall train together during this time to practice and become 

familiar all aspects of the operations. The VO is not required to be present at all 

25 hours of flight training; however, it is the responsibility of the PIC to 

determine if the VO has a thorough understanding of how to conduct flight 

operations safely.

Ø Prior to any commercial flight operations, demonstration of complete control of 

the UAS shall be maintained. Proficiency flights shall include all normal flight 

maneuvers such as takeoff; a figure "8" coordinated turn flight pattern; and 

landings.

Ø UAS flight crewmembers are required to demonstrate the ability to speak and 

understand the English Language to the proficiency level required by ICAO 

Annex 1. This is accomplished by means of formal and informal interviewing 

during the hiring process. 

Ø Neither the PIC or VO shall participate in any flight operations, whether it be 

proficiency flights or revenue generating flights, if the blood alcohol 

concentration (BAC) level is 0.04% or higher, within 8 hours of having 

consumed any alcohol, while under the influence of alcohol, while under the 

influence of illegal, prescribed or over the counter drugs that would impair the 

ability to safely operate the UAS as prescribed in 14 CFR Part 91.17. It is the 

responsibility of the PIC and VO to police each self and each other. 
Ø The UAS flight crewmembers shall not participate in any phone calls, phone 

conversations or operation of a two-way radio during flight operations. All 

proposed flight paths and flight operations will be discussed by Sugar Rock, LLC 

and the customer prior to any flights in order to avoid unnecessary distractions. 

Only concise communications are allowed between authorized flight operations 

area personnel and the UAS flight crewmembers. Every effort shall be made to 

prevent non-essential personnel from interfering with the PIC and VO in any way 

during flight operations. 

Ø All applicable licenses, certificates, permits, authorizations, waivers, exemption 

letters, flight and maintenance logbooks, personal identifications, and this 

Operations Manuals shall be made available to any law enforcing, State or 

National Government Entity at any time.

Record keeping 

Ø Training qualifications and record keeping are maintained and tracked for the 

pilot in command and visual observer. The PIC is responsible for the management 

of all training, maintenance and flight records. Records shall include the 

following, as appropriate to the crew position; copies of certificates and ratings, 

copy of current Medical Certificate and flight training logs.

Ø Maintenance will only be conducted by an authorized DJI represented who is 

certified by DJI to maintain a DJI phantom 3. Records will include date, time, 

specific detail of work done and name and or badge number of personal who 

conducted the maintenance. Maintenance records will be kept for 5 years. 

Operational and Maintenance records may be made available for inspection by 

the Federal Aviation Administration.

The UAS & Flight

The UAS is a 3 lbs battery operated quadcopter (four motors, four blades) called the DJI 

Phantom 3 Professional, which consist of:

Ø 4k UHD video recording with fully stabilized 3-axis gimbal; Vision Positioning 

system allows stable flight.

Ø Lightbridge digital streaming allows live viewing of 720p video (full resolution 

video is simultaneously recorded on the internal microSD card).

Ø Flight battery and rechargeable remote controller. 

Ø DJI Pilot app for IOS and Android allows live viewing and complete camera 

control.

Ø The Phantom 3 Professional carries a fully stabilized 3-axis 4k UHD video 

camera for smooth, crisp videos and still photos.
Ø To allow you to see what the drone sees, DJI has engineered a new generation of 

their Lightbridge technology that allows 720p HD digital streaming of live video 

directly from the drone.

Ø Includes GPS navigation with auto takeoffs and auto landings, intelligent high 

power flight battery, a built-in safety database of no fly zones, and a powerful 

mobile app for your iOS or Android device.

Ø GPS Assisted flight- Allows quadcopter to hover when no command are being 

sent- This is a nice feature in case the PIC needs to "regroup" during flight.

Ø Non-GPS Modes- If GPS signals are lost, aircraft goes into a mode that monitors 

and hold altitude and provides control assistance to help keep aircraft stable and 

under total control of the PIC.

Ø LED Status Lights on Aircraft, along with warning system equipped on the pilot 

app which allows the PIC to always have full situation awareness on his aircraft. 

Note: DJI has locked the Phantom from being able to even start the motor if you live 

within a 15 mile radius of the White House. This encompasses not only D.C. but much of 

Prince George's County, Arlington, Fairfax, Silver Spring, Falls Church and Montgomery 

County. 

(The DJI Phantom 3 manuals will be attached to this packet)

The UAS also have two bright gold bands in front of the quadcopter, these are used for 

orientation and location of aircraft from line of site.

MAX. Ascent Speed: 5m/s

MAX. Descent Speed: 3m/s

MAX. Flight Altitude 6000m

MAX. Flight time approximately 23 minutes

GPS: GPS/GLONASS

The powerful Remote Controller allows you to pilot and maneuver the Phantom 3 

Professional at distances over 6,000 feet away, while putting selected camera controls. 

Built into the Remote control is a rechargeable LIPo battery and DJI Lightbridge, which 

when paired with a compatible mobile device gives live HD view from the Phantom 

Camera.

Operating Frequency: 2.400 GHz-2.483 GHz

Max. Transmission Distance: 2 km

Operating Temperature Range: 0c-40c

Transmit Power: FCC: 20 dbm; CE: 16 dbm

Charger: Voltage 17.4V; Rated Power 100W

The UAS will be operated by a Pilot in Command (PIC) with the following restrictions:

Ø All operations will occur in Class G airspace at no more than 400' AGL. The vast 

majority of flights will be well below this limit at an average of 200' AGL to 

accomplish the best photographs and videos. 

Ø Any required permits will be obtained from local and state government before 

flights.
Ø The Aircraft will not operate directly above human beings at any time or within 

150 feet of human beings.

Ø Maximum flight time will be 18 minutes. Battery allows 23 minutes of flight 

time. Batteries are inspected and always fully charged before use.

Ø The Aircraft will not operate within 5 miles of an airport/heliport without prior 

approval from said airport/heliport.

Ø All operations will be during the daytime and in ideal weather conditions of less 

than 15 mph winds and clear skies.

Ø Aircraft will remain in visual line of site at all times not to exceed 1/4 miles from 

PIC.

Ø Visual observer will serve as additional eyes on the aircraft and be within voice 

reach to communicate with PIC

Ø Aircraft will not fly in the area of any full scale aircraft and if a full scale aircraft 

comes into airspace during the aircraft's flight, it will be landed immediately to 

allow right of way to full scale aircraft. 

Ø At any time Aircraft is being flown, signs will be posted in least three (3) 

locations, warning of UAS operations are being conducted and to stay at 200' 

away at all times of landing and takeoff areas. 

Ø UAS will never be used as an invasion of privacy and only be used for purposes 

listed above.

Ø The UAS will never be flown near, in or over stadiums; or over large gathering of 

persons.

Ø The equipment is not inexpensive and I take general public and aviation safety 

seriously. I have developed pre-flight plans, and maintenance plan to make sure 

the aircraft is always in safe flying condition. 

REASONS FOR EXEMPTIONS

Exemption Request Section 333 of the FAA Reform Act & Part 11 of the Federal 

Aviation Regulations from:

14 C.F.R. Parts 21, 45.29, 45.23:

The aircraft has no area to display numbers or letters that are at least 2” in size. To my 

Knowledge there are are only registration systems for recreational UAS. We will place in 

the largest letters “Sugar Rock, LLC” on the top of the aircraft. 

14 C.F.R. 91.7:

To my knowledge there are no aircraft airworthiness certificates for UAS. We will before 

each flight run through the enclosed pre-flight checklist to ensure airworthiness.

14 C.F.R 91.9(b):

There is no cockpit to include said manual. Operating manual will be kept with PIC.

14 C.F.R. 91.103:

Since there will not be a FAA approved quadcopter manual to be provided we will need 

to be exempt. We will again follow our enclosed pre-flight checklist to ensure safety and 

airworthiness.

14 C.F.R. 91.109:

UAS are controlled by transmitter and do not have the capability for dual controls. It is 

our understanding there have been other aircraft approved without dual controls.

14 C.F.R. 119:
Since flights will never be above 400’ AGL and usually around 200’ AGL, we requested 

an exemption as the altitude cited in 14 CFR 91.119 would cause us to exceed said 400’ 

AGL.

14 C.F.R.91.121:

UAS does not have a traditional altimeter. The DJI Phantom 3 Professional uses 

sophisticated technology which enables precise GPS coordinates that gives real time 

positioning including altitudes and speeds all displayed on an Iphone or Ipad.

14 C.F.R. 91.51:

The UAS does not use traditional fuel but battery power. The battery provides for up to 

23 minutes of flight. Battery power levels will be monitored using an apple application 

which gives the PIC the capability to enable the return home feature telling the UAS to 

return home and land. No flight will last longer than 18 minutes as an extra safety net. 

All batteries are only used if freshly charged, all batteries are visually inspected and volt 

tested before each flight.

14 C.F.R. 91.203:

There is no cockpit to include said certificate or registration documents. Any certificates, 

exemptions or registration documents will be with the PIC on the ground level.

14 C.F.R. 91.405, 91.407, 91.409, 91.47:

As there are no airworthiness inspections available therefore we request an exemption. 

Again we will perform pre-flight checklists to ensure safety. If our pre-flight checklist 

does not pass, we will abort flight. Any items of concern will promptly be repaired using 

similar components and records will be kept through maintenance records.

We are prepared to modify or amend any part of this petition for exemption to meet or 

exceed concerns of safety; we do look forward to working with the FAA to provide a 

great service to our community and profession in a safe manner. 

Sincerely,

Benjamin Hassell

President

Sugar Rock, LLC
Pre-Flight Checklist

o Make sure you are using genuine parts and that all parts are in mint condition

o Ensure the remote controller, intelligent Flight Battery, and mobile device are fully 

charge

o Ensure that there is no foreign object stuck to the camera lens, the micro-SD card has 

been inserted into the camera, and gimbal can rotate freely before powering it on.

o Ensure the propellers are securely mounted onto the motors, and the motors can start 

and function normal.

o Make sure propellers are not chipped or damaged

o Check all electrical wiring for security

o Follow the on screen instructions to calibrate the compass

o Ensure the DJI pilot app and aircraft firmware have been upgraded to the last version

o Make sure your flight area is outside the No-Fly Zones and flight conditions are 

suitable for flying the Aircraft

o Make sure wind velocity is less than 15 MPH

o Before starting DJI Phantom make sure you are in an open area clear of trees, power 

lines or any obstacles. 

o Make sure you located at least 5 Miles from an airport unless received authorization 

from an authorized personnel. 

o Make sure any by standby personal are at least 150 feet from DJI Phantom at all times 

when in operation. 

o Set up cones notify people of DJI operations in three distinct locations
Post flight

o Turn Off UAS

o Disconnect batter from UAS

o Set Radio control transmitter power switch to off

o Perform general visual inspection of UAS

Loss of Communication

o In the event of loss of communication with the UAS utilized the return home 

feature.