UASolutions Group, Inc.

2518 Auburn Drive, Cocoa FL 32926

Tel: (321) 261-2547

kellyneubecker@uasolutionsgroup.com

September 9, 2015

U.S. Department of Transportation, Docket Operations

West Building Ground Floor, Room W12-140

1200 New Jersey Avenue, SE

Washington, DC 20590 

Re: Summary Grant Petition for an Exemption to Conduct Small Unmanned Aircraft 

Systems (sUAS) Operations Allowed by Section 333 of the Federal Aviation Administration 

Modernization and Reform Act of 2012, 49 U.S.C. § 44701(f), and 14 C.F.R. Part 11

A. Summary

On behalf of our client, Green Drone Inspections, LLC (Green Drone Inspections) and 

pursuant to Section 333 of the Federal Aviation Administration (FAA) Modernization and 

Reform Act of 2012 (“FMRA”), Subsection (f) of 49 U.S.C. § 44701, and 14 C.F.R. Part 11, 

Green Drone Inspections, (hereafter known as the “Petitioner”), seeks exemption from the

following listed Code of Federal Regulations (“CFR”) to allow commercial operation of the 

previously approved DJI Phantom Series, Leptron RDASS, Yuneec Q500, and the Sensefly eBee 

within the National Airspace System (NAS) for controlled, low-risk, aerial photography and 

survey, data collection for industrial inspections including pipe line, power lines, wind turbines, 

solar farms, flare stack, and offshore platforms, and first responder/emergency management 

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

as required by Section 333 requirements. 

As described more fully below, the requested exemption would permit the operation of 

the DJI Phantom Series, Leptron RDASS, Yuneec Q500, and the Sensefly eBee sUAS by

Petitioner under controlled conditions in predetermined airspace that is 1) Limited in scope 2) 
2

Controlled as to access by mission essential personnel only. 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” as stated within Section 333(c) of the FMRA. In making this 

determination, the Secretary is required to determine which types of sUAS do not create a hazard 

to users of the NAS or the public or pose a threat to national security in light of the aircraft’s 

size, weight, speed and operational capability; Operation of the sUAS in close proximity to 

airports and population centers; Operation of a sUAS within visual line of sight of the operator.

Grant of the requested exemption is in the public interest based upon the concise 

direction expressed within section 333 of the reform act; the added authority granted by the Act, 

as amended; an equivalent level of safety regarding flight operations as expressed herein, and 

significant cost savings achieved by transitioning from traditional manned aerial resources to 

sUAS. The petitioner respectfully requests that the FAA grant the requested exemption without 

delay. Petitioner will operate the DJI Phantom Series, Leptron RDASS, Yuneec Q500, and the 

Sensefly eBee sUASs while keeping the documents required by the regulations at the ground 

control station and immediately accessible to the Pilot in Command (PIC) and by modification of 

the required markings (registration number) of the sUAS to be displayed on the fuselage of the 

unmanned aircraft.

The name and address of the Petitioner is:

Green Drone Inspections, LLC 

The primary contact for this petition, with a copy to me at the address above is:

Kevin A. Coward

Green Drone Inspections, LLC

220 Ravenglass Way

Colorado Springs, CO 80906

B. Regulations – Exemptions Requested

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

b. 14 C.F.R. 61.23, 

c. 14 C.F.R. 61.101 (e)(4) &(5)

d. 14 C.F.R. 61.113(a) and (b), 

e. 14 C.F.R. 61.315(a),

f. 14 C.F.R. 91.7(a), 

g. 14 C.F.R. 91.105, 
3

h. 14 C.F.R. 91.119(c)

i. 14 C.F.R. 91.121, 

j. 14 C.F.R. 91.151(a) (b), 

k. 14 C.F.R. 91.405(a), 

l. 14 C.F.R. 91.407(a)(1), 

m. 14 C.F.R. 91.409(a)(1) and (2), and 

n. 14 C.F.R. 91.417(a) and (b). 

C. Background

Green Drone Inspections is a Colorado based company providing a complete line of 

sUAS and unmanned solutions with the operational infrastructure to provide low-risk, aerial 

photography and survey, data collection for industrial inspections including pipe line, power 

lines, wind turbines, solar farms, flare stack, and offshore platforms, and first 

responder/emergency management in different geographical locations throughout the United 

States in a safe, convenient, and legal manner. 

The sUASs for the purposes of this petition is the DJI Phantom Series, Leptron RDASS, 

Yuneec Q500, and the Sensefly eBee. Each of these aircraft meet the requirements for 

determination of Summary Grant for exemption as each platform has been previously approved 

by the FAA in numerous other Petitions. All pertinent operational and maintenance manuals 

have been previously submitted, reviewed, and approved by the FAA for each of the requested

platforms.

Petitioner will operate only within visual line of sight (VLOS) and during daylight hours 

in Visual Flight Rules (VFR) conditions. Additionally, Petitioner will operate only within the 

parameters defined in the blanket Certificate of Authorization (COA) issued by the FAA under 

the new interim policy. In the event any Green Drone Inspections operation exceeds the 200

foot limitation imposed by the policy, a separate COA specific to the airspace required for that 

operation will be obtained prior to flight operations. Such requirements will insure that the 

sUAS will “not create a hazard to users of the national airspace system or the “public” as stated 

in Section 333 of the FMRA. 

D. Airworthiness 

A critical element of consideration for grant of the petition is evidence of an equivalent 

level of safety for airworthiness of the sUAS. The FAA has been authorized to exempt aircraft 

from the requirement for an actual airworthiness certificate in accordance with the statutory 

criteria provided in Section 333 of PL 112-95 in reference to 49 USC 44704, in consideration of 
4

the size, weight, speed, and limited operating area associated with the aircraft and its operation. , 

Also, in accordance with FAA N 8900.291, Petitioner has an established inspection and 

maintenance program for the continued airworthiness of the aircraft in accordance with the 

manufacture’s maintenance, overhaul, replacement, inspection, and life limit requirements for 

the aircraft and aircraft components.

Green Drone Inspection’s standard operating procedures are detailed within the Flight 

Operation Limitations and Safety section on page 7. 

E. Operational Capabilities

Petitioner seeks an exemption to operate the DJI Phantom Series, Leptron RDASS, 

Yuneec Q500, and the Sensefly eBee for limited approved commercial purposes within the

NAS1. These aircraft are all comprised of the UA and a transportable GCS. They do not 

carry any flammable propellant or fuel. The sUASs also have integrated GPS systems that 

calculates the sUAS's position and height and relays that information via a secure connection to 

the operator. Additionally, the DJI Phantom Series, Leptron RDASS, Yuneec Q500, and the 

Sensefly eBee, have the capability to operate safely after experiencing certain in-flight 

contingencies or failures and uses an auto-pilot system to maintain stability and control. They

are also able to respond to a loss of GPS or a lost- link event with pre-coordinated automated 

flight maneuvers. 

`F. Regulatory Basis for Petition

Petitioner, pursuant to 14 C.F.R. §§ 11.61(b), 11.81, 2and the FAA Modernization and

Reform Act of 2012 (“FMRA”), Section 333, Special Rules for Certain Unmanned Aircraft

Systems (“Section 333”), hereby respectfully petitions the Administrator for an exemption from

the requirements of 14 C.F.R. 45.23 (b),14 C.F.R. 61.23, 14 C.F.R. 61.101 (e)(4) &(5),14 

C.F.R. 61.113(a) and (b), 14 C.F.R. 61.315(a), 14 C.F.R. 91.7(a), 14 C.F.R. 91.105, 14 C.F.R. 

91.119(c), 14 C.F.R. 91.121, 14 C.F.R. 91.151(a) (b), 14 C.F.R. 91.405(a), 14 C.F.R. 

91.407(a)(1), 14 C.F.R. 91.409(a)(1) and (2), and 14 C.F.R. 91.417(a) and (b). 

 

1 Green Drone Inspections will submit Aircraft Registration Applications as required, upon the 

grant of the exemptions sought by this petition.

2

14 C.F.R. § 11.61(b) (“Using a petition for exemption, you may ask FAA to grant you relief from 

current regulations in 14 C.F.R.”), 14 C.F.R. § 11.81 (“What information must I include in my 

petition for an exemption”)?
5

1. Section 333 

Congress identifies Section 333 of the FMRA, as a pathway for “expedited operational 

authorization” of certain sUAS in the NAS. Section 333 (b)(1) (“expedited operational 

authorization.”).

3

 Under Section 333 Congress mandates that the FAA “shall determine if certain 

unmanned aircraft systems may operate safely in the national airspace system before completion 

of the plan and rulemaking required by Section 332 of this Act or the guidance required by 

section 334 of this Act” (Section 333(a)) upon consideration of its “size, weight, speed, operational 

capability, proximity to airports and populated areas, and operation within visual line of sight.” 

Section 333(b)(1). If the FAA makes such a determination, the FAA “shall [also] establish 

requirements for the safe operation.” Section 333(c). The FAA further may find that the sUAS does 

not require “airworthiness certification under section 44704 of title 49, United States Code.” Section 

333(b)(2).

2. 49 U.S.C. § 44701

The FAA is further authorized to grant exemptions from its safety regulations and 

minimum standards under 49 U.S.C. § 44701 (“Section 44701”) “if the Administrator finds 

the exemption is in the public interest.” Section 44701(f)4(authorizing the grant of 

exemptions from safety regulations and minimum standards under Section 44701(a) and (b) and 

Sections 44702-44716).5

For the reasons addressed herein, this Petition qualifies for expedited approval of 

Petitioner’s request for exemption under both Section 333 of the FMRA and 49 U.S.C § 44701.

G. Statutory Criteria for Exemption under Section 333

Given their small size, light weight, slow speed, limited load capacity, superior 

operational capabilities, and that the operations will be conducted only during the day, under 

visual meteorological conditions (“VMC”), within VLOS of the PIC, with the assistance of a 

 

3 See also www.faa.gov/sUAS/legislative_programs/section_333/ (noting that Section 333 grants 

the FAA “the statutory flexibility to expedite requirements for the safe operation of certain aircraft 

systems in the NAS.”).

4 Under 49 U.S.C. § 44701(f), the “Administrator may grant an exemption from a requirement

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

44716 of [Title 49] if the Administrator finds the exemption is in the public interest.”

5 See e.g. 49 USC §44711(a)(1) prohibiting operations without airworthiness certificate; (2) 

prohibiting serving as airman without airman’s certificate; (5) prohibiting commercial operations in 

violation of regulations); 49 USC §44704 (issuance of airworthiness certificate); 14 C.F.R. §91.203

(a)(1) (carry airworthiness certificate)).
6

visual safety observer (“VO”), and confined within the boundaries of a consenting landowner’s 

property and not in the proximity of populated areas, the DJI Phantom Series, Leptron RDASS, 

Yuneec Q500, and the Sensefly eBee are the very category of sUAS that qualifies for expedited 

approval under Section 333.

1. Proximity to Airports/Population Centers or Areas

Flight operations pursuant to this Petition will be tightly controlled and restricted to

low risk areas and in accordance with the blanket 200-foot COA requirements at an altitude of no 

more than 200 feet above ground level (AGL). In the event a Green Drone Inspections operation 

is required to exceed the 200-foot limitation imposed by the policy, a separate COA specific to the 

airspace required for that operation will be obtained prior to operations at an altitude of no more 

than 400 feet AGL. All altitudes reported to ATC will be in AGL when required and any 

operations conducted within 5 nautical miles (NM) of the geographic center of a non-towered 

airport will obtain a Letter of Agreement with the appropriate airport management and made 

available to FAA upon request. In addition, access to any property will be limited to persons 

associated with and necessary to flight operations.

2. Visual Line-of-Sight

The minimum crew for each operation will consist of a PIC and VO. The VO will be 

used as an additional mitigation to satisfy the VLOS requirement, but the PIC will always 

maintain VLOS with the sUAS. The aircraft will at all times be flown by Petitioner only in the 

daytime (not at night) under VMC, within VLOS of the PIC, with the further assistance of the 

VO with whom the PIC will have the ability for direct and continuous two-way verbal 

communications

6

so as to ensure that the flight operations remain within the PIC’s VLOS and 

prescribed flight boundaries and de-conflict with objects in the air and on the ground. Thus, 

pursuant to the FAA Order 8900.1 Volume 16, Chapter 1, Section 3, the proposed operations 

will provide an approved method of control and collision avoidance to satisfy the “see and 

avoid” requirement of 14 C.F.R. § 91.113:

Only qualified and current PIC’s and VOs will be used.

3. Other Factors

 

6 PIC and VO are within speaking distance and all communications between PIC and VO will be 

without communications equipment
7

a. Petitioner proposes that requirements should take into account the 

characteristics of these particular sUASs. The DJI Phantom Series, Leptron RDASS, Yuneec 

Q500, and the Sensefly eBee are all characterized by a high degree of pre-programmed control, 

various built-in technical capabilities that limit the potential for operation outside of the 

operating conditions as set forth below, and many built-in functional, safety and redundancy 

features to ensure a safe and reliable operation. At a minimum: geo-fencing at a maximum 

ceiling of 200’or 400' AGL, flight programming capabilities, a flight termination link available to 

the operator to prevent a "fly away," and safe abort procedures. If the DJI Phantom Series, 

Leptron RDASS, Yuneec Q500, and the Sensefly eBee loses communications or their GPS 

signal, they will return to a pre-determined location and land or be recovered in accordance with 

the User’s Manual. The airframes will have markings identifying the serial number and 

identification (N-number) markings as large as practicable. Further, Green Drone Inspections

operations will comply with all manufacturer Safety Bulletins. 

b. Safety Management System

A Safety Management System (SMS) approach will regulate Petitioner’s operation of 

the sUASs and will significantly contribute to maintaining the level of safety contemplated by 

the airworthiness certificate requirements from which Petitioner now seeks relief.

Pursuant to the SMS and 14 C.F.R. § 43.13, entitled Performance Rules (general), each 

person performing maintenance, alteration, or preventive maintenance on the DJI Phantom 

Series, Leptron RDASS, Yuneec Q500, and the Sensefly eBee, motor, propeller, or appliance

shall use the methods, techniques, and practices prescribed in the current manufacturer's User’s 

Manual or Instructions for Continued Airworthiness prepared by its manufacturer, or other

methods, techniques, and practices acceptable to the Administrator. Each person shall use the

tools and equipment necessary to assure completion of the work in accordance with accepted

industry practices.

c. Flight Operation Limitations and Safety

In seeking this exemption, Petitioner proposes to operate all sUAS pursuant to the

following specific operating limitations: 

1. The DJI Phantom Series, Leptron RDASS, Yuneec Q500, and the Sensefly 

eBee all weigh less than 55 pounds, fully loaded.

2. The aircraft shall only be operated at or below 200 ft. AGL, unless a separate 

COA specific to the airspace required for that operation is obtained prior to 
8

operations at an altitude of no more than 400 feet AGL.

3. All aircraft will be operated within VLOS of the PIC and safety VO.

4. The radio frequencies used for operations and control of the UAS (2.4GHz) will 

comply with the Federal Communications Commission ("FCC") or other 

appropriate government oversight agency requirements.

5. Operations shall be conducted pursuant to Day Visual Flight Rules (VFR) in visual

meteorological conditions (VMC) and only during daylight hours (i.e. between the

end of morning civil twilight and the beginning of evening civil twilight, as

published in the American Air Almanac, converted to local time).

6. The DJI Phantom Series, Leptron RDASS, Yuneec Q500, and the Sensefly eBee

shall operate from on-site takeoff/landing locations directly next to the PIC and colocated VO. The PIC and the VO shall be able to verbally communicate during all 

operations. 

7. Operations shall be conducted by certificated airmen who possess either a 

commercial, private, recreational, or sport pilot certificate.

8. The PIC will be a FAA licensed airman and will hold a current airman medical 

certificate or valid U.S. driver’s license issued by a state, the District of Colombia, 

Puerto Rico, a territory, a possession, or the Federal government. The PIC will also 

meet the flight review requirements specified in 14 CFR § 61.56 in an aircraft in which 

the PIC is rated on his or her pilot certificate. 

9. The PIC shall have successfully completed the training and qualification processin 

accordance with DJI Phantom Series, Leptron RDASS, Yuneec Q500, and the Sensefly 

eBee Pilot Training Guides. PIC qualification flight hours and currency will be logged 

in a manner consistent with 14 CFR § 61.51(b). Training operations will only be 

conducted during dedicated training sessions. 

10. A minimum of three take-offs and three landings in the preceding 90 days will 

be required by the PIC to maintain currency, such log of which shall be made 

available to the Administrator upon request.

11. All operations will utilize a VO. The UA will be operated within the VLOS of the

PIC and VO at all times. The VO may be used to satisfy the VLOS requirement as 

long as the PIC always maintains VLOS capability. The VO and PIC will be able

to communicate verbally at all times; electronic messaging or texting is not 
9

permitted during flight operations. The PIC will be designated before the flight and 

cannot transfer his or her designation for the duration of the flight. The PIC will 

ensure that the VO can perform the duties required of the VO.

12. The sUASs will be operated within visual line of sight (VLOS) of the PIC at all 

times. This requires the PIC to be able to use human vision unaided by any 

device other than corrective lenses, as specified on the PIC’s FAA-issued airman 

medical certificate or U.S. driver’s license.

13. If a pilot certificate holder other than the PIC, who possesses the necessary PIC 

qualifications, is also present during flight operations, that person can also be 

designated as PIC and will follow the necessary procedures to assume control.

14. A briefing will be conducted in regard to the planned operations prior to each 

flight. It will be mandatory that all personnel who are performing duties within 

the boundaries of the flight operations safety perimeter be present for the 

briefing.

15. Petitioner will obtain an Air Traffic Organization (ATO) issued COA prior to 

conducting any actual flight operations. Green Drone Inspections will only 

operate within the guidelines of the blanket 200-foot COA under the FAA’s 

interim policy. For flights above 200 feet AGL, Green Drone Inspections will 

operate in a confined geographic area as defined by a separate approved ATO 

issued COA.

16. Petitioner will file a NOTAM for each flight at least 24 hours in advance of each 

flight with the appropriate FSDO.

17. Any operations that will be conducted within 5 nautical miles (NM) of the 

geographic center of a non-towered airport will obtain a Letter of Agreement 

with the appropriate airport management and made available to FAA upon 

request.

18. Prior to flight operations, Petitioner shall coordinate 1 hour ahead of the proposed 

flight a communication with the nearest local Air Traffic Control facility 

indicating location, altitude and duration of the proposed flight.

19. Any required permissions and permits will be obtained from territorial, state, 

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

appropriate governmental agencies at least 12 hours in advance of any flight 
10

operation.

20. The DJI Phantom Series, Leptron RDASS, Yuneec Q500, and the Sensefly eBee

shall be marked with an identification (N-Number) in accordance with 14 C.F.R. § 

45.23, such markings to be as large as practicable pursuant to 14 C.F.R. § 45.29(f), 

and identified by a serial number registered in accordance with 14 C.F.R. Part 47.

21. All flights will remain clear and yield the right of way to all other manned 

operations and activities at all times, including, but not limited to: ultralight 

vehicles, parachute activities, parasailing activities, hang gliders, etc.

22. Flights will not be operated less than 500 feet below or less than 2,000 feet 

horizontally from a cloud or when visibility is less than 3 statute miles from the 

PIC.

23. The DJI Phantom Series, Leptron RDASS, Yuneec Q500, and the Sensefly eBee

shall be operated at an airspeed not to exceed 87 knots.

24. Any time the DJI Phantom Series, Leptron RDASS, Yuneec Q500, and the 

Sensefly eBee is operating, all documents required under 14 C.F.R. § 91.9 and § 

91.203 shall be available to the PIC at the GCS. Such documents shall be made 

available to the Administrator or any law enforcement official upon request. 

25. Operations shall not occur directly over any person, except authorized and 

consenting personnel required for flight/imaging operations, 

26. The radio frequency spectrum used for operation and control of the DJI Phantom 

Series, Leptron RDASS, Yuneec Q500, and the Sensefly eBee shall comply with 

the requirements of users manuals. The aircraft shall at all times be operated to 

ensure a safe distance away from all participating and non-participating personnel, 

at least 500 feet away from persons not involved in the flight operations (nonparticipating persons) unless: 

 Barriers or structures are present that sufficiently protect nonparticipating 

persons from the UA and/or debris in the event of an accident. The operator 

must ensure that nonparticipating persons remain under such protection. If a 

situation arises where nonparticipating persons leave such protection and are 

within 500 feet of the UA, flight operations must cease immediately in a 

manner ensuring the safety of nonparticipating persons.

 The owner/controller of any vessels, vehicles or structures has granted 
11

permission for operating closer to those objects and the PIC has made a 

safety assessment of the risk of operating closer to those objects and 

determined that it does not present an undue hazard.

27. The flight will be terminated at 20% battery power reserve. 

28. Prior to each flight, the PIC shall inspect the aircraft, including any inoperable 

components, items or equipment, to ensure it is in an airworthy condition for 

safe flight. If the inspection reveals a condition that affects flight readiness or

safe operations, the DJI Phantom Series, Leptron RDASS, Yuneec Q500, and 

the Sensefly eBee shall not be operated until the necessary maintenance has 

been performed and it is found to be in a condition for safe flight. Any 

discrepancies and all maintenance or alterations shall be documented in the 

aircraft records, such records to be made available to the Administrator upon 

request.

29. Except as may be designated otherwise for Fail-Safe operations, the aircraft shall

take off and land at a location within the boundaries of the subject property next to

the PIC.

30. Upon loss of communication or GPS signal, all sUAS shall return to a 

predetermined location within the boundaries of the landowner’s property and 

land or be recovered in accordance with the User’s Manual. 

31. In the event of an emergency or unanticipated obstacle to planned operations, 

the operation shall be aborted and the sUAS if airborne, shall return to a 

predetermined location.

32. The DJI Phantom Series, Leptron RDASS, Yuneec Q500, and the Sensefly eBee

shall be maintained in accordance with the manufacturer’s maintenance, 

overhaul, replacement, inspection, and life limit requirements for the aircraft and 

aircraft components and in accordance with FAA N 8900.291. 

33. All operations shall be conducted over private or controlled-access property with 

permission from the property owner/controller or authorized representative. 

Permission from property owner/controller or authorized representative will be 

obtained for each flight to be conducted.

34. Any incident, accident or flight operation that transgresses the lateral or vertical 

boundaries of the operational area as defined by the applicable COA shall be 
12

reported to the FAA’s UAS Integration Office within 24 hours. Accidents shall 

also be reported to the National Transportation Safety Board (NTSB). Further 

flight operations shall not be conducted until the incident, accident or 

transgression is reviewed by the UAS Integration Office and authorization to 

resume operations is provided.

d. Privacy 

All Green Drone Inspections sUAS operations will be conducted in accordance with 

applicable Federal, State, and local laws regarding privacy. All operations shall be conducted 

over private or controlled-access property with permission from the land/building 

owner/controller or authorized representative. Permission from land owner/controller or 

authorized representative will be obtained for each flight to be conducted. 

e. Physical Security

In order to ensure its safe and proper use, Petitioner will be the operator of the DJI 

Phantom Series, Leptron RDASS, Yuneec Q500, and the Sensefly eBee and the aircraft will 

remain in Petitioner’s custody during operations.

4. .Lack of Threat to the NAS, Public, or National Security 

For the reasons previously addressed, including meeting Section 333(b)(1) criteria, 

Petitioner’s record of safety and the small size of the sUAS involved and the controlled sterile 

area within which they will operate, Petitioner 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 sUASs to commence immediately. Petitioner will operate the 

DJI Phantom Series, Leptron RDASS, Yuneec Q500, and the Sensefly eBee in accordance with 

the aforementioned flight limitations without creating a hazard to other aircraft or persons or 

property on the ground. The fact that each PIC will be required to be screened by the Department of 

Homeland Security, approval of the petition presents no threat to national security. Further, given their 

small size and limit load capacity, the aircraft are incapable of carrying any substantial external 

load, including explosive materials or flammable liquids. 

For all of these reasons, Petitioner’s proposed operations using the DJI Phantom Series, 

Leptron RDASS, Yuneec Q500, and the Sensefly eBee qualify for expedited approval of the sought

exemption pursuant to Section 333 for the specified uses and under the proposed operating 

requirements and restrictions.
13

H. Public Interest Benefits 

Granting Petitioner’s request for exemption would benefit the public and have no 

adverse effect on safety for the following reasons. 

1. Public Interest Generally

The grant of the requested exemption is in the public interest based on the clear direction 

in Section 333 and 49 U.S.C. § 44701(f), the equivalent and enhanced level of safety of the

proposed operations, the significant public benefit, and cost savings to be realized as a result of 

the use of sUAS for product demonstration and training services. Moreover, the FAA has 

previously granted identical exemptions for sUAS.

7 The DJI Phantom Series, Leptron RDASS, 

Yuneec Q500, and the Sensefly eBee are battery powered sUASs that serves as a safer, more 

efficient, and economical alternative to larger and heavier manned aircraft carrying flammable 

liquid fuels, traditionally use for aerial photography or aerial surveying. This will provide for an 

added superior level of safety to persons and property in the air and on the ground than that 

provided by manned aircraft performing the same operations. No pilot or crew need be airborne

and granting the exemption would also decrease the number of manned aircraft in the NAS and, 

as a result, reduce congestion as well as the environmental impact of such operations. Using 

these aircraft also provides the benefit of greater operational flexibility and reduced cost when 

compared to manned aircraft.

a. Increased Aircrew Safety and Reduced Risk to Persons/Property on Ground

Because the platforms are unmanned, the proposed operations eliminate the risk to pilot and 

crew associated with flying such aerial-surveying missions in confined airspace at low altitude. 

Further, given its small size and weight and low airspeed, using these platforms also reduces the risk 

of damage or injury to persons or property on the ground, and in the air, were there to be an 

unforeseen mishap. 

b. Reduced Environmental Impact

Using sUAS instead of manned aircraft also benefits the public by eliminating or greatly 

reducing air and noise pollution associated with traditional aerial imaging operations. Because 

they are battery powered and uses electric motors, the DJI Phantom Series, Leptron RDASS, 

 

7 Green DroneInspections requests that the FAA not solicit public comment on its petition because

it would not set any new precedent and because the relief requested is identical to exemptions

granted previously. 14 C.F.R. § 11.87.
14

Yuneec Q500, and the Sensefly eBee sUAS consumes no fuel, generates no air pollution, and 

creates very little noise. As a result, the public is benefited as a result of reduced environmental 

impact, reduced operator and other human exposure, and greater fuel conservation, which

serves additionally to support our Government’s specific efforts to reduce the U.S.’s carbon 

footprint.8

c. Fewer Manned Aircraft in the NAS and Reduced Need for ATC Handling

The DJI Phantom Series, Leptron RDASS, Yuneec Q500, and the Sensefly eBee also

does not require a runway or helipad to takeoff or land and will not be operated within the close 

proximity of any airports without prior FAA approval. As such, fewer aircraft will need to be

handled by air traffic control during ground, takeoff, departure, arrival, and landing phases. 

Operations pursuant to this Petition will further reduce the number of manned aircraft flying or 

transiting at or above 500’ AGL to and from the areas of imaging operations as well as

congestion around airports due to aircraft arrival and departure.

d. Superior Aerial Imagery and Increased Benefit to U.S. Economy

Better aerial footage can also be obtained using these small and nimble platforms than can be 

obtained using manned aircraft or other ground-based methods. Due to its small size and superior 

flight performance characteristics, the DJI Phantom Series, Leptron RDASS, Yuneec Q500, and the 

Sensefly eBee allows for images to be taken from certain locations and angles and with better 

precision than using manned aircraft. As a result, less time is needed in the air to obtain the desired 

footage, which in addition to providing the benefit of fewer aircraft in the NAS and associated 

reduced risk to objects and persons and property in the air and on the ground, reduced noise, etc., 

allows for the production of surveys, which benefits consumers. This additionally ensures that

organizations such as Green Drone Inspections and its customers remain competitive and

profitable, thereby providing their employees greater job stability, which ultimately contributes

further to the U.S. economy through increased consumer spending. 

e. Increased Operational Flexibility and Reduced Cost

Using sUAS also provides the benefit of greater operational flexibility and reduced cost 

when compared to manned aircraft. Instead of each time having to hire a manned aircraft at 

thousands of dollars/hour, subject to the pilot’s schedule and availability, Petitioner can operate 

the DJI Phantom Series, Leptron RDASS, Yuneec Q500, and the Sensefly eBee, at lower combined 

 

8 Reducing the U.S.’s carbon footprint is a high priority and consistent with the U.S. Environmental

Protection Agency’s regulatory efforts to phase out the use of fossil fuels. 
15

cost, innumerable times and at the convenience of Petitioner’s and its customer’s schedules.

2. No Adverse Safety Effects

Granting this Petition will also not adversely affect aviation safety or pose any undue 

risks to the public. The operations pursuant to this Petition will be in accordance with approved 

processes and checklists and in compliance with all applicable FAA safety policies and 

guidance. Accordingly, and as detailed herein, granting the requested exemption would not 

adversely affect safety. Indeed, as detailed below, operations pursuant to the limitations and 

guidelines addressed herein and the safety procedures, Petitioner will provide an equivalent 

level of safety to those regulations from which Petitioner seeks exemption. The FAA has also 

recently set precedence by granting exemptions with similar purposes in all material respects,

to those presented herein. For these reasons, Petitioner’s operations pursuant to this Petition also 

qualify for an exemption. 

I. Exemptions Sought By Petitioner and Reasons for the Requested Relief

Pursuant to Section 333, Petitioner seeks an exemption from the requirements of 14 

C.F.R. 45.23 (b),14 C.F.R. 61.23, 14 C.F.R. 61.101 (e)(4) &(5),14 C.F.R. 61.113(a) and (b), 14 

C.F.R. 61.315(a), 14 C.F.R. 91.7(a), 14 C.F.R. 91.105, 14 C.F.R. 91.119(c), 14 C.F.R. 91.121, 14 

C.F.R. 91.151(a) (b), 14 C.F.R. 91.405(a), 14 C.F.R. 91.407(a)(1), 14 C.F.R. 91.409(a)(1) and 

(2), and 14 C.F.R. 91.417(a) and (b). 

1. 14 C.F.R 45.23(b)

 Applicable codes of Federal Regulation require aircraft to be marked according to 

certain specifications. UASs 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. Regardless, Green Drone

Inspections will mark its UAS in the largest possible lettering by placing the "N" number 

on its fuselage as required by 14 CFR 45.29 (f) so that the pilot, technician, spotter and 

others working with the UAV will see the markings.

2. 14 C.F.R. 61.23(a) &(c)

Relief from the requirements of Section 61.23(a) and (c) is requested by 

Petitioner who is seeking the approval to use a valid state issued driver’s license in lieu of 

FAA issued Medical Certificate. The FAA has previously routinely approved the use of a 

valid state driver’s license as part of the “summary grant” exemptions.
16

3. 14 C.F.R. 61.101 (e)(4) &(5)

Petitioner requests from this Section to enable the PIC to perform duties utilizing 

a recreational pilot’s license. The FAA has routinely approved the use of a recreational 

pilot license as part of the “summary grant” exemptions.

4. 14 C.F.R.61.113(a) and (b). 

Petitioner seeks an exemption from 14 C.F.R. 61.113(a) and (b). Section 61.113, 

entitled Private pilot privileges and limitations: Pilot in command, subsections (a) and (b) 

state (emphasis added):

(a) Except as provided in paragraphs (b) through (h) of this section, no person who 

holds a private pilot certificate may act as pilot in command of an aircraft that is 

carrying passengers or property for compensation or hire; nor may that person, 

for compensation or hire, act as pilot in command of an aircraft.

(b) A private pilot may, for compensation or hire, act as pilot in command of an 

aircraft in connection with any business or employment if:

(1) The flight is only incidental to that business or employment; and

(2) The aircraft does not carry passengers or property for compensation or 

hire.

In general, subsections 61.113 (a) and (b) prohibit a private pilot from conducting 

commercial operations. Petitioner seeks exemption from the subsections because the DJI 

Phantom Series, Leptron RDASS, Yuneec Q500, and the Sensefly eBee will not carry a pilot, 

passengers or property (other than a camera). As addressed, the platforms are very light, 

remotely controlled sUASs with no persons or property on board. Each flight is planned and

fully coordinated in advance in accordance with those procedures provided in the SOP. Thus 

the risk associated with the proposed operations is so diminished from that associated with

commercial operations contemplated by Part 61, that allowing a PI C having a private pilot 

certificate, rather than a commercial certificate, met the minimum flight hour and qualification 

criteria, and operating according to the limitations and guidelines provided herein, provides a 

level of safety that exceeds that provided by a pilot having a commercial certificate operating a 

conventional aircraft as required under the regulations.

The FAA has already set precedence by previously granted exemptions in circumstances

similar, in all material respects, to those presented herein. 
17

5. 14 C.F.R. 61.315(a)

Petitioner requests exemptions from this Section to enable the PIC to perform duties 

utilizing a recreational or sport pilot’s license. The FAA has routinely approved the use of a 

recreational or sport pilot license as part of the “summary grant” exemptions.

6. 14 C.F.R. 91.7(a)

Either finding that Petitioner meets the Section 333 criteria or exemption from the 

airworthiness certification requirement under 14 C.F.R. Part 21 renders subsection 91.7(a) 

inapplicable. 

Section 91.7, entitled Civil aircraft airworthiness, subsection (a) states (emphasis added):

“No person may operate a civil aircraft unless it is in an airworthy condition.” There is no FAA 

standard by which such a determination of airworthiness can be made. Nonetheless, given the

limitations and procedures, as contained herein, the Safety Procedures contained within the 

SOP, and the Maintenance Manual, for maintaining the aircraft and checking it before each 

flight to ensure that it is in peak operational condition, an equivalent level of safety will be

provided.

7. 14 C.F.R 91.105

Petitioner seeks an exemption from 14 C.F.R. 91.105. Section 91.105, entitled Flight 

crewmembers at stations, states (emphasis added):

(a) During takeoff and landing, and while en route, each required flight 

crewmember shall—

(1) Be at the crewmember station unless the absence is necessary to 

perform duties in connection with the operation of the aircraft or in 

connection with physiological needs; and

(2) Keep the safety belt fastened while at the crewmember station.

(b) Each required flight crewmember of a U.S.-registered civil aircraft shall, 

during takeoff and landing, keep his or her shoulder harness fastened while at his 

or her assigned duty station. This paragraph does not apply if—

(1) The seat at the crewmember's station is not equipped with a shoulder 

harness; or,

(2) The crewmember would be unable to perform required duties with the 

shoulder harness fastened.
18

In general, Section 91.105 requires pilot and crew to be at their duty stations and 

harnessed during flight. Petitioner seeks exemption from the Section 91.105 because the DJI 

Phantom Series, Leptron RDASS, Yuneec Q500, and the Sensefly eBee sUAS are by their 

definition unmanned aircraft, having neither pilot nor crew so as to be stationed or harnessed as 

required by the regulation. An equivalent or even higher level of safety can be provided instead 

by using an unmanned aircraft controlled by a PIC who at all times is located at and controls the 

sUAS from the GCS. 

8. 14 C.F.R. 91.119(c)

Petitioner seeks an exemption from 14 C.F.R. 91.119(c). Section 91.119, entitled Minimum 

safe altitudes: General, subsection (d) states (emphasis added):

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.

Section 91.119(c) establishes safe altitudes for operation of civil aircraft over other than 

congested areas. Petitioner seeks exemption from subsection 91.119(c) because, pursuant to this 

Petition, the sUAS will at times be operated either at or below 200 or 400 feet AGL.

An equivalent or even higher level of safety can be provided instead by, as provided

herein, operating so as to de-conflict with manned vehicles operating above 500 feet AGL, within

the VLOS of the PIC with the assistance of a VO so as to ensure the safety of and de-confliction 

with any persons or property in the air and on the ground, including participating and nonparticipating personnel, 100 feet and 500 feet, respectively, away from who the UA would 

generally be restricted. Further, flight operations will be monitored at all times by both the

PIC and VO and will be in compliance with local public safety requirements, so as to prevent

access to the restricted areas of operation. 

The FAA has set precedence by previously granted exemptions in circumstances similar,

in all material respects, to those presented herein.

9. 14 C.F.R. 91.121

Petitioner seeks an exemption from 14 C.F.R. 91.121. Section 91.121, entitled Altimeter 
19

settings, 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.” Petitioner seeks exemption from Section 91.121 because the 

DJI Phantom Series, Leptron RDASS, Yuneec Q500, and the Sensefly eBee sUAS do not use or 

have on board a typical barometric altimeter as contemplated by the regulation. 

Note: An equivalent level of safety will be provided instead, by operating the sUAS at 

or below 400 feet AGL, within the VLOS of the PIC (with the assistance of a VO), with altitude 

information downlinked from the sUAS to the PIC to maintain altitude and ensure safety. Prior 

to each flight, a zero altitude/AGL will be established at the launch site, as confirmed for 

accuracy by the PIC. 

10. 14 C.F.R. 91.151(b)

Petitioner seeks an exemption from 14 C.F.R. 91.151(b). Section 91.151(b), entitled Fuel 

requirements for flight in VFR conditions, states (emphasis added):

(b) No person may begin a flight in a rotorcraft 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, to fly 

after that for at least 20 minutes.

The DJI Phantom Series, Leptron RDASS, Yuneec Q500, and the Sensefly eBee are 

unmanned aircraft, and thus would not begin a flight with a person in it as the regulation 

contemplates. To the extent the regulation applies to some of the rotorcraft contemplated by 

Green Drone Inspections, the maximum flight duration is 18 minutes, depending upon 

atmospheric conditions and type of camera or sensor. 

An equivalent level of safety can be achieved by terminating the flight at 20% battery 

power reserve. Given that the sUAS will be operated within the VLOS of the PIC, within the 

confines of the particular landowner’s property with prior written consent of the landowner and 

participating and non-participating personnel, this restriction would provide more than enough 

battery reserve to accommodate a safe return to the landing zone from anywhere in the 

operating area with no adverse effect on the safety of persons and property in the air or on the 

ground. 

The FAA has set precedence by previously granted exemptions in circumstances similar,

in all material respects, to those presented herein. 
20

11. 14 C.F.R. 91.405(a), 91.407(a)(1), 91.409(a)(2), 91.417(a) and (b) 

Section 91.405(a), entitled Maintenance required, states:

Each owner or operator of an aircraft—

(a) 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;

Section 91.407(a)(1), entitled Operation after maintenance, preventive maintenance, rebuilding, 

or alteration, states:

(a) No person may operate any aircraft that has undergone maintenance, 

preventive maintenance, rebuilding, or alteration unless—

(1) It has been approved for return to service by a person authorized under 

§ 43.7 of this chapter;

Section 91.409 (a)(2), entitled Inspections, states:

(a) Except as provided in paragraph (c) of this section, no person may operate an 

aircraft unless, within the preceding 12 calendar months, it has had—

(1) An annual inspection in accordance with part 43 of this chapter and 

has been approved for return to service by a person authorized by § 43.7

of this chapter; or

(2) An inspection for the issuance of an airworthiness certificate in 

accordance with part 21 of this chapter.

No inspection performed under paragraph (b) of this section may be substituted 

for any inspection required by this paragraph unless it is performed by a person 

authorized to perform annual inspections and is entered as an “annual” inspection 

in the required maintenance records.

Section 91.417(a) and (b), entitled Maintenance records, state:

(a) Except for work performed in accordance with §§ 91.411 and 91.413, each 

registered owner or operator shall keep the following records for the periods 

specified in paragraph (b) of this section:

(1) Records of the maintenance, preventive maintenance, and alteration and 

records of the 100-hour, annual, progressive, and other required or approved 
21

inspections, as appropriate, for each aircraft (including the airframe) and each 

engine, propeller, rotor, and appliance of an aircraft. The records must include—

(i) A description (or reference to data acceptable to the Administrator) of 

the work performed; and

(ii) The date of completion of the work performed; and

(iii) The signature, and certificate number of the person approving the 

aircraft for return to service.

(2) Records containing the following information:

(i) The total time in service of the airframe, each engine, each propeller, 

and each rotor.

(ii) The current status of life-limited parts of each airframe, engine, 

propeller, rotor, and appliance.

(iii) The time since last overhaul of all items installed on the aircraft which 

are required to be overhauled on a specified time basis.

(iv) The current inspection status of the aircraft, including the time since 

the last inspection required by the inspection program under which the 

aircraft and its appliances are maintained.

(v) The current status of applicable airworthiness directives (AD) and 

safety directives including, for each, the method of compliance, the AD or 

safety directive number and revision date. If the AD or safety directive 

involves recurring action, the time and date when the next action is 

required.

(vi) Copies of the forms prescribed by § 43.9(d) of this chapter for each 

major alteration to the airframe and currently installed engines, rotors, 

propellers, and appliances.

(b) The owner or operator shall retain the following records for the periods 

prescribed:

(1) The records specified in paragraph (a)(1) of this section shall be retained until 

the work is repeated or superseded by other work or for 1 year after the work is 

performed.
22

(2) The records specified in paragraph (a)(2) of this section shall be retained and 

transferred with the aircraft at the time the aircraft is sold.

(3) A list of defects furnished to a registered owner or operator under § 43.11 of 

this chapter shall be retained until the defects are repaired and the aircraft is 

approved for return to service.

In general, these regulations require that an airworthy certificated aircraft be inspected as

prescribed in 14 C.F.R. Part 91, Subpart E (Maintenance, Preventive Maintenance, and 

Alterations), any discrepancies be repaired and the aircraft be approved for return to service as

prescribed in Part 43 (Maintenance, Preventive Maintenance, Rebuilding, and Alterations) and 

that any work on the aircraft be recorded and such records maintained. 

Petitioner seeks an exemption because, as addressed, the DJI Phantom Series, Leptron 

RDASS, Yuneec Q500, and the Sensefly eBee sUASs will operate pursuant to this Petition 

without airworthiness certification. An equivalent level of safety can be provided instead by 

requiring, as provided herein, that inspections and maintenance be accomplished according to 

the inspection, maintenance, and preflight sections IAW the manufacturer’s guidance in the 

associated User’s Manual. Among other things, the aircraft will be inspected prior to each flight 

to confirm that it is in good working order. Any maintenance or repairs will be perform and 

logged, and, upon any work being performed, the aircraft will be checked and approved for 

flight by personnel before being returned to service. 

The FAA has already set precedence by previously granted exemptions in circumstances 

similar, in all material respects, including airframe types, to those presented herein. 

J. Conclusion

As set forth in the document above, the following summary is provided for publication 

in the Federal Register. Petitioner seeks an exemption pursuant to Section 333 of the FAA 

Modernization and Reform Act of 2012, 49 U.S.C. § 44701(f), and 14 C.F.R. Part 11 to permit 

safe operation of the DJI Phantom Series, Leptron RDASS, Yuneec Q500, and the Sensefly 

eBee sUAS commercially, for the purposes of low-risk, aerial photography and survey, data 

collection for industrial inspections including pipe line, power lines, wind turbines, solar farms, 

flare stack, and offshore platforms, and first responder/emergency management. By granting 

this Petition, the FAA Administrator will be fulfilling the Congressional mandate of Section 333 

of the FAA Modernization and Reform Act of 2012 to expedite approval of operations of certain 

sUAS in the NAS, while also advancing the interests of the public.
23

WHEREFORE, in accordance with the Title 49 of the United States Code, the Code of 

Federal Regulations, and the FAA Modernization and Reform Act of 2012, Section 333, 

Petitioner respectfully requests that the Administrator grant this Petition for an exemption from 

the requirements of 14 C.F.R. 45.23 (b),14 C.F.R. 61.23, 14 C.F.R. 61.101 (e)(4) &(5),14 

C.F.R. 61.113(a) and (b), 14 C.F.R. 61.315(a), 14 C.F.R. 91.7(a), 14 C.F.R. 91.105, 14 C.F.R. 

91.119(c), 14 C.F.R. 91.121, 14 C.F.R. 91.151(a) (b), 14 C.F.R. 91.405(a), 14 C.F.R. 

91.407(a)(1), 14 C.F.R. 91.409(a)(1) and (2), and 14 C.F.R. 91.417(a) and (b). 

Respectfully Submitted, 

Kelly Neubecker

Kelly J. Neubecker

CEO

UASolutions Group, Inc.

cc: Kevin A. Coward