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 61.113(a) and (b); 91.103; 91.119(c); 

91.121; 91.151(a); 91.405(a); 91.407(a)(1); 91.409 (a)(1) and (2); 91.417(a) and (b).

To whom it may concern:

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

Act”) and 14 C.F.R. Part 11, Drone Loan, LLC, an operator of Small Unmanned Aircraft 

Systems and Aerial and Photography Vehicles (“UAS/APVs”) for aerial image 

acquisition including but not limited to, the following industries: motion pictures and 

television, real estate, short range inspection, mapping & survey, agriculture, search 

and rescue, hereby applies for an exemption from the Federal Aviation Regulations 

(“FARs”) to allow commercial operation of its UAS/APV.

Drone Loan, LLC's requested exemption would permit the operation of UAS/APV under 

controlled and secure conditions that is: (i) limited, (ii) predetermined, (iii) subject to 

controlled access, and (iv) provide greater safety in connection with aircraft operations. 

As established by the exemptions already granted by the FAA, approval of Drone Loan, 

LLC's exemption would 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.” Section 333(c) of the Reform act.

The name and address of the petitioner is:

William Edward Ray- Owner/Manager/Pilot

24 year Military Veteran

Company Name: Drone Loan, LLC

Address: 7791 Three Canyons Rd, Hereford AZ 85615

Phone: 520 559 3293

Email: droneloan@hotmail.com

Proposed Aircraft: Yuneec Q500+; 3DR Solo

See Enclosed UAS/APV Owners Manual
Regulations from which the exemption is requested:

14 CFR 61.113(a) and (b)

14 C.F.R. 91.103

14 C.F. R. 91.119

14 C.F.R. 91.121

14 CFR 91.151(a)

14 CFR 91.405(a)

14 CFR 407(a) (1)

14 CFR 409(a) (2)

14 CFR 417(a) and (b)

UAS/APVs operated by Drone Loan, LLC weigh less than 55 pounds, including the 

payload (i.e. camera, lens, and gimbal). They operate at speeds of no more than 50 

knots, can hover, and can simultaneously move vertically and horizontally. Drone Loan, 

LLC will only operates its UAS/APVs in line of sight and will operate only within the 

secure area described in the FOPM. Such operations will insure that the UAS/APV will 

“not create a hazard to users of the national airspace system or the public.”Given the 

small size of Drone Loan, LLC's UAS/APVs and the restricted secure environment 

within which they will operate, Drone Loan, LLC's UAS/APV operations adhere to the 

Reform Act’s safety requirements. Additionally, due to the size of the UAS/APVs, 

permission from relevant property owners or other applicable parties, and the limited 

areas in which they will operate, approval of this application presents no national 

security issues. Based on the substantial level of safety surrounding the proposed 

operations, and the significant public benefit (enhanced safety), reduction in 

environmental impacts (reduced emissions and noise), the grant of the requested 

exemption is in the public interest. Accordingly, Drone Loan, LLC respectfully requests 

that the FAA grant the requested exemption. Aircraft and Equivalent Level Of Safety

The operating limitations proposed by Drone Loan, LLC provide for at least an 

equivalent or higher level of safety because operations further enhance safety of aerial 

image collection using conventional aircraft.

The limitations and conditions include:

• The UAS/APVs will weigh less than 55 pounds.

• Flights will be operated within line of sight of a pilot and/or observer. 

• Maximum flight time for each operational flight will be no more than 30 minutes. Flights 

will be terminated at no less than 25% battery power reserve should that occur prior to 

the 30 minute limit. 

• Flights will be operated at an altitude below 400 feet 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 UAS/APV Pilot, the Visual 

Observer

• A UAS/APV pilot will be an FAA licensed airman with at least a sport pilot’s certificate,

and third class medical or valid US or Canadian driver’s license. 

• A UAS/APV pilot will be Pilot in Command (PIC).
• The UAS/APV will only operate within a confined secure area as defined in the FOPM. 

A briefing will be conducted for planned UAS/APV operations prior to each day’s flight. 

All personnel performing duties within the boundaries of the safety perimeter are 

required to attend. 

• The operator will obtain consent of all persons involved in the filming and ensure that 

only consenting persons will be allowed within 500 feet of the flight operation.

• The Pilot and observer must be trained in UAS/APV operations and have received 

current information on the particular UAS/APV to be operated as required by the FOPM. 

• The Observer and pilot will be able to communicate by voice and/or text at all times. 

• Written and/or oral permission from the relevant property holders will be obtained prior 

to flight operations. 

• All appropriate permissions and permits will be obtained from territorial, state, county, 

or city jurisdictions, including local law enforcement, fire, or other appropriate 

governmental agencies. 

• If the UAS/APV loses communications or loses its GPS signal, the UAS/APV will have 

the capability to “return to home” (original point of origin) within the secure perimeter 

and land. 

• The UAS/APV will have the capability to abort a flight in case of unpredicted obstacles 

or emergencies.

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

Command 

Sections 61.113 (a) and (b) limit private pilots to non-commercial operations. Because 

the UAS/APV will not carry a pilot or passengers, the proposed operations can achieve 

the equivalent level of safety of current operations by requiring the PIC operating the 

aircraft to have a private pilot’s license rather than a commercial pilot’s license to 

operate a UAS/APV. Unlike a conventional manned aircraft, a UAS/APV is remotely 

controlled by a ground-based operator. The operational area is controlled and restricted, 

and all flights are planned and coordinated in advance. The level of safety exceeds that 

provided by a single individual holding a commercial pilot’s certificate operating a 

conventional aircraft. The risks associated with the use of a UAS/APV are so diminished 

from the level of risk associated with commercial operations contemplated by Part 61 

allowing UAS/APV use by a sport pilot as the PIC exceeds the present level of safety 

sought by 14 C.F.R. §61.113 (a) and (b). 

14 C.F.R. § 91.103: Preflight Action 

Section 91.103 requires each pilot to preflight an aircraft before flight to insure the 

safety of flight. As FAA approved rotorcraft flight manuals will not be used, an 

exemption is requested. However, an equivalent level of safety will be provided. The 

PIC will take all actions, including reviewing weather, flight battery requirements, landing

and takeoff distances, and aircraft performance data before commencement of flight.
14 C.F.R. §91.119(c): Minimum Safe Altitudes

Section 91.119 establishes safe altitudes for operation of civil aircraft. 

Section 91.119 provides, in pertinent part, that: “except when necessary for takeoff or 

landing, no person may operate an aircraft below the following altitudes: 

(c) Over other than congested areas. An altitude of 500 feet above the surface, except 

over open water or sparsely populated areas. In those cases, the aircraft may not be 

operated closer than 500 feet to any person, vessel, vehicle, or structure.”

Because Drone Loan, LLC requests authority to operate at altitudes no higher than 400 

AGL, and not more than 200 above an elevated platform from which filming is planned, 

an exemption is needed to allow such operations. Except for the limited conditions 

stated in the FOPM, the UAS/APV will never operate higher than 400 AGL. It will, 

however, be operated in a restricted area within a 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, and speed of the 

UAS/APV as well as the location where it is operated. No flight will be taken without the 

permission of property owners or local officials. 

Because of the advance notice to the property owners and participants in the filming 

activity, all affected individuals will be informed of the planned flight operations. 

Compared to flight operations for manned aircraft and the lack of flammable fuel, any 

risk associated with the proposed UAS/APV operations is far less than conventional 

aircraft operating at or below 500 AGL. In addition, the low-altitude operations of the 

UAS/APV will ensure separation between a UAS/APV and conventional aircraft.

14 C.F.R. §91.121: Altimeter Settings

Section 91.121 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 a UAS/APV may not have a 

barometric altimeter, but instead a GPS altitude data, an exemption is needed. An 

equivalent level of safety will be achieved by the operator, pursuant to the FOPM 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 . . . .”

The typical battery powering the Drone Loan, LLC UAS/APVs provides less than 30 

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

§91.151, UAS/APV flight would not be possible. Given the limitations on the UAS/APV’s 

proposed light area and its proposed operations within a predetermined location, a 

longer time frame for flight in daylight VFR conditions is reasonable. Furthermore, 

operating the UAS/APVs in a tightly controlled area where only people, property 

owners, or official representatives who have signed waivers will be allowed, less than 

30 minutes of reserve fuel does not engender the type of risk that §91.151(a) was 

intended to address.

Drone Loan, LLC believes that safety can be achieved by limiting flights to 30 minutes 

or 25% of battery power, whichever occurs first. This restriction would be more than 

adequate to return the UAS/APV to its pre-determined landing zone from anywhere in 

its limited operating area.

!

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 sections and Part 43 apply only to aircraft 

with an airworthiness certificate, these sections will not apply to Drone Loan, LLC 

operations. Maintenance will be accomplished by the operator. An equivalent level of 

safety will be achieved because the UAS/APVs are limited in size, will carry a small 

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

issues arise, the UAS/APV can land immediately and will be operating from no higher 

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

UAS/APV is in working order prior to flight, perform any required maintenance, and 

keep a log of any maintenance performed. Moreover, the operator is the person most 

familiar with the UAS/APV and best suited to maintain it in an airworthy condition.

Summary for Publication

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:

Drone Loan, LLC seeks an exemption from the following rules:

14 C.F.R. §§ 61.113(a) and (b); 91.103; 91.119(c); 91.121; 91.151(a); 

91.405(a); 91.407(a)(1); 91.409(a)(2); and 91.417(a) and (b) to operate commercially a 

small unmanned vehicle (55 pounds or less) in commercial image acquisition 

operations. As established by the UAS/APV exemptions already granted by the FAA, 
allowing commercial operations of UAS/APVs in agriculture, real estate, inspection, S & 

R, and film industries will enhance safety by reducing risk. Conventional survey, 

agricultural, mapping, inspection, and film operations, using turbine aircraft, operate at 

low altitudes and present the risks associated with aircraft that weigh around 4,000 

pounds, and which carry large amounts of Jet A fuel. Such aircraft must also fly to and 

from the target location. In contrast, a UAS/APV weighing fewer than 55 pounds and 

powered by batteries eliminates virtually all of that risk given the small size and lack of 

combustible fuel. The UAS/APV is carried, and not flown, to target site. In this regard, 

the UAS/APV carries no passengers or crew and, therefore, will not expose them to the 

risks associated with manned flights. The operation of UAS/APVs conducted in the strict 

conditions outlined in the FOPM will provide an equivalent level of safety supporting the 

grant of the exemption requested herein. The UAS/APVs operate at slow speeds, close 

to the ground, and in a secure environment. As a result, they are far safer than 

conventional operations conducted with turbine helicopters flying near the ground and 

people.

Privacy

All flights will occur over private or controlled access areas with the property owner’s 

prior consent and knowledge. Recognizable images will only be recorded of people who 

have given their consent or otherwise have agreed to be in the area where active image 

acquisition will take place. 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 to grant Drone Loan, LLC’s requested exemption, 

allowing for Drone Loan, LLC's UAS/APV commercial operations for the listed industries 

pursuant to the included FOPM.

If you have any questions or need any additional information, please contact the 

undersigned by phone at 520 559 3292 or via email at droneloan@hotmail.com

Very Respectfully

William Edward Ray