Request for exemption from multiple regulatory provisions to 

allow the use of small unmanned aerial systems on land 

controlled by clients of Islandtime Farms, LLC to assist in the 

safe evaluation of infrastructure and operations for our clients. 

Islandtime Farms, LLC respectfully requests an exemption from 

several provisions of Title 14 of the Code of Federal Regulations 

(C.F.R.) to permit the use of unmanned aerial systems (UAS) to 

assist in the evaluation of infrastructure and operations for our

clients. This request is motivated primarily by the desire to 

maximize safety in infrastructure and operations. While an 

exemption would not eliminate the current need for in-person 

visual inspection required by various federal regulatory 

departments, it would allow ISLANDTIME FARMS, LLC to 

broadly evaluate assets and operations with UAS, resulting in a 

safer and more efficient infrastructure network. Accordingly, 

the grant of an exemption is consistent with Congress’ intent, 

reflected in Section 333 of the FAA Modernization and Reform 

Act of 2012 (Modernization Act),1 that safe systems be 

permitted in the national airspace prior to the issuance of final 

regulations governing general use of these systems.2 A 

summary of this request suitable for publication in the Federal 

Register is provided as Appendix A. Appendix B provides the 

manufacturers information regarding the design, aircraft 

performance, and fail-safe features. We have provided 

manufacturer information related to operating limitations, 

normal and emergency procedures, and maintenance and 

inspection procedures. As we add aircraft designs, we will 
update this appendix appropriately. Appendix C provides the 

Drone Fleet & Aerospace Management Operations Manual for 

flights covered under this Exemption Request. 1 P.L. 112-95, 

126 Stat 11, February 14, 2012. 2 Section 333(b) (2) specifically 

contemplates that the FAA may issue a certificate of waiver 

upon a finding that a type of UAS, as a result of its size, weight, 

speed, operational capacity, proximity to airports and 

populated areas, and operations within visual line of sight do 

not create a hazard to users of the NAS or the public or pose a 

threat to national security. Background Information 

ISLANDTIME FARMS, LLC is in the business of video capture of 

real estate, infrastructure and industrial plants for our clients. 

ISLANDTIME FARMS, LLC is requesting FAA Exemption for UAS

operations for inspections and video capture usage. Regulatory 

Basis for Exemption Request In addition to the waiver authority 

provided in §333 of the Modernization Act, the FAA may grant 

an exemption under 49 U.S.C. §44701(f) if it has determined 

that such an exemption is in the public interest. The FAA has 

imposed a separate requirement in its procedural regulations, 

providing that the petitioner shall explain why granting the 

exemption would not adversely affect safety or how the 

exemption would provide at least an equivalent level of safety 

as compliance with the underlying regulation. In this case, 

approval of this exemption would advance the public interest 

by significantly enhancing the safety and efficiency of 

infrastructure operations and by providing the FAA with 

valuable user experience on UAS in a context with appreciable 
economic and societal benefits. As described more fully below, 

the requested exemption would permit the operation of UAS

under tightly controlled conditions, thus ensuring that 

operations will not have an adverse impact on safety. To the 

contrary, as explained below, ISLANDTIME FARMS, LLC

anticipates that use of UAS will enhance safety in infrastructure 

operations. Granting an Exemption is in the Public Interest. The 

safety and efficiency of infrastructure operations is heavily 

dependent upon constant analysis of assets, right-of-way, 

infrastructure and other assets/facilities. There are a wide 

variety of factors that can affect conditions and cause problems 

for infrastructure. Even relatively small objects or minor failures 

can lead to accidents or other incidents causing downtime of 

infrastructure. Extreme weather events can lead to flooding or 

overheating infrastructure. For example earthquakes, 

landslides, and abandoned vehicles at grade crossings can block 

infrastructure. The potential for sabotage and terrorism – or 

even just trespassing – are also among the many risks that 

modern infrastructure faces. As a result, pursuant to federal 

regulations and company policy, our client’s maintenance 

employees routinely inspect the infrastructure, such as bridges, 

tunnels, support structures, and signals. At present, this work is 

done primarily by company personnel in motor vehicles, on 

foot, in specialized equipment. This is often a labor-intensive 

and sometimes arduous job. While our clients do all they can to 

make these inspections as safe as possible, there is an

irreducible element of risk involved whenever employees are 
required to go out on structures. Employees may need to climb 

over or onto structures, which can be slippery, rough, and/or 

exposed to the elements. Some structures, such as bridges, are 

high above the ground. Equipment moving through inspection 

zones can increase risk as well, especially in high-traffic areas. 

While the use of UAS for supplemental infrastructure and 

general asset evaluation would not eliminate these risks 

entirely (as it is an additive safety measure), it would reduce 

the risks to employees by allowing for remote aerial review. 

Additionally, the sheer amount of assets and the widely 

dispersed locations – in many instances far from sizeable 

population centers – means that visual inspection in all 

instances by company personnel can be inefficient. Aerial 

analysis by traditional fixed wing aircraft is impractical because 

the required altitudes for safe flight reduce visibility below 

meaningful levels – it is simply not possible to see all asset 

anomalies from such heights. Helicopters present better 

vantage points; however manned helicopters are much more 

costly, subject to human safety and carry highly explosive jet 

fuel making them impractical for deployment. By using UAS for 

supplemental asset evaluation, ISLANDTIME FARMS, LLC will be 

able to substantially upgrade its capacity to detect and address 

issues with the right-of-way and other assets before they 

become a problem for safe operations. Thus, the use of UAS

has the potential to improve efficiency, resulting in faster and 

safer delivery of goods, energy & natural resources vital to the 

U.S. economy. Granting an Exemption will not Adversely Affect 
Safety ISLANDTIME FARMS, LLC notes that there is no 

applicable standard for an equivalency determination. Some 

have argued that the appropriate standard is that for model 

aircraft, noting that their operations, if conducted for 

recreational purposes, would fall completely within the 

allowable operations for model aircraft. We believe it is difficult 

to argue that there is sufficient correlation between model 

operations controlled by the Academy of Model Aeronautics 

and the ones contemplated by ISLANDTIME FARMS, LLC. At the 

same time, it is clear that equivalency cannot be established for 

traditional, manned civil aircraft because the design and use 

profiles between traditional aircraft and UAS are simply too 

different. As such, we believe it makes more sense to focus on 

why the contemplated operations would not adversely affect 

safety, which is all that §11.81(e) requires. Granting an 

exemption will not adversely affect safety. ISLANDTIME FARMS, 

LLC contemplates conducting UAS operations over client owned 

or controlled land, solely during daylight hours, at altitudes well 

below that which would pose a risk to other aircraft. In general, 

UAS operations are intended to be conducted in areas distant 

from both congested areas and airports. Moreover, because of 

the inherent risks presented by standard infrastructure 

operations, our clients have already taken steps to secure 

property against unauthorized public access. The nature of 

operations anticipated by ISLANDTIME FARMS, LLC requires 

that the UAS be flown at relatively low altitudes and relatively 

low speeds. ISLANDTIME FARMS, LLC expects that in most 
instances, the UAS will be flown less than 75 feet from the 

highest structure along the path of the UAS. Accordingly, the 

risk of interference with another aircraft is minimal. 

ISLANDTIME FARMS, LLC also plans to conduct UAS operations 

at least three miles from any public airports (including 

heliports)Approval of exemptions allowing commercial 

operations of UASs in the infrastructure aerial inspection 

industry will enhance safety by reducing risk. Conventional 

operations, using jet or piston power aircraft, operate at 

extremely low altitudes just feet from the subject being 

inspected and in extreme proximity to people and structures; 

and present the risks associated with vehicles that weigh in the 

neighborhood of 4,000lbs., carrying large amounts of jet A or 

other fuel (140 gallons for jet helicopters). Such aircraft must fly 

to and from the inspection site. In contrast, a UAS weighing 

fewer than 55 lbs. and powered by batteries eliminates virtually 

all of that risk given the reduced mass and lack of combustible 

fuel carried on board. The UAS is carried to the inspection site. 

The UAS will carry no passengers or crew and, therefore, will 

not expose them to the risks associated with manned aircraft 

flights. The operation of small UASs, weighing less than 55 lbs., 

conducted in the strict conditions outlined above, will provide 

an equivalent level of safety supporting the grant of the 

exemptions requested herein, including 333 Aircraft Exemption 

Status exempting the applicant from conventional aircraft 

requirements and allowing commercial operations. These 

lightweight aircraft operate at slow speeds, close to the ground, 
and in a controlled environment and, as a result, are far safer 

than conventional operations conducted with turbine 

helicopters operating in close proximity to the ground and 

people. The safety of those on the ground is protected by the 

fact that no one will be allowed into the area without the 

permission of the company. Security will be established for the 

flight area as part of the pre-flight control. Each individual 

within the secure area will be briefed prior to flight and will 

consent to being in the area. All others will be excluded from 

the area. ISLANDTIME FARMS, LLC initially intends to use a 

dedicated staff for UAS operations. All operations will be within 

visual line-of-sight (i.e., no more than approximately 0.5 miles 

from the manipulator of the controls, or pilot in command 

(PIC)). Each PIC will conduct at least three take-offs and 

landings with the UAS on which he or she is trained every 90 

days. PIC’s will establish their qualifications thru a combination 

of aeronautical knowledge, UAS airmanship skills, and 

verification through testing of flight ability before 

infrastructures operations have commenced. Depending on the 

type of operation, additional ground-based visual observers 

may be employed as well. These observers will be within 

constant visual line of sight and in constant contact with the 

PIC. The visual observers will assist the PIC in avoiding objects 

near the UAS. There are no standards for either Private or 

Commercial UAS pilot certificates. 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. Given the 
restricted and controlled airspace within which operations will 

take place, the key factors needed by the PIC are knowledge of 

the airspace within which the operation will take place and how 

that airspace fits into the National Airspace System (NAS). That 

knowledge can be and is gained primarily through ground 

school 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 a commercial 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. Besides knowledge of airspace regulations, dexterity 

in the control and operation of the UAS acquired from actual 

operation of the aircraft is the most important factor in 

establishing an equivalent level of safety. If the PIC has 

acquired the necessary knowledge of airspace requirements, 

the relevant issues are (1) where the aircraft will be flown, (2) 

the size of the aircraft relative to what is being used today to 

accomplish the same mission, and (3) what precautions will be 

taken to ensure the safety of those in the area of operation. We 

propose that the PIC has at least an FAA Private Pilots 

Certificate and a Class III medical; the aircraft be operated 

within a secure environment; and that no one be allowed to 

enter the secure environment unless they are part of the 
operation, have been fully briefed of the risks prior to 

operation of the UAS, and have consented to the risks 

associated with being in the operating area. Should there be a 

mishap, the UAS being flown pose significantly less of a threat 

than the helicopters and fixed wing aircraft now being 

employed because they are a fraction of the size, carry no 

flammable fuel, do not carry crew or passengers, and pose an 

infinitesimal risk to others. This is in stark contrast to 

conventional aircraft that are flown to the site, carry explosive 

fuel, carry passengers and crew, and operate in a much larger 

area. 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 commercial pilots that can fly 

these UAS – to the point that to do both is considered rare. 

Assuming that it is unlikely for a company to find a pilot that 

has both qualifications that company would either have to 

source a qualified UAS pilot to train and obtain a commercial 

certificate, or find a commercial certificated pilot who would be 

willing to learn to fly a UAS to the competency level required 

for professional use. ISLANDTIME FARMS, LLC intends to use 

commercially available UAS Components for UAS. These UAS

systems will be tested for quality & safety in our test facility 

before being deployed to the field. The UAS is less than 55 lbs. 

fully loaded, carries neither a pilot nor passenger, and operates 

exclusively within a secured area. We have a routine 

maintenance schedule to verify that the UAS will remain in safe 
and operational condition. Please see Appendix B, for Specific 

Types of UAS. Notes Regarding: 14 C.F.R. Part 21, Subpart H In 

accordance with the statutory criteria provided in Section 333 

of PL 112-95 in reference to 49 USC 44704, and in consideration 

of the size, weight, speed, and limited operating area 

associated with the aircraft and its operation, we request that 

this aircraft exemption meets the conditions of Section 333. 

Therefore, if granted Section 333 relief of 14 CFR part 21, and 

any associated noise certification and testing requirements of 

part 36, is not necessary. Notes Regarding: 14 C.F.R. § 45.23 (b). 

Marking of the Aircraft Given the size of the sUAV, two-inch 

lettering will be impossible. UA will be identified by serial 

number, registered in accordance with 14 CFR part 47, and 

have identification (N-Number) markings in accordance with 14 

CFR part 45, Subpart C. Markings will be as large as practicable. 

Notes Regarding: 14 CFR § 91.7(a) Civil Aircraft Airworthiness 

ISLANDTIME FARMS, LLC’s request is based on the fact that no 

airworthiness certificate will be issued for the UAS. ISLANDTIME 

FARMS, LLC’s UAS will not require an airworthiness certificate 

in accordance with 14 CFR part 21, Subpart H. Based on the fact 

that an airworthiness certificate will not be issued, exemption 

from § 91.7(a) is not necessary. Notes Regarding: 14 CFR § 

91.9(b)(2) Civil aircraft flight manual, marking & placard 

Certifications required, the original intent of these regulations 

was to display an aircraft’s airworthiness, certification, and 

registration documents so they would be easily available to 

inspectors and passengers. Based on the FAA Memorandum 
subject “Interpretation regarding whether certain required 

documents may be kept at an unmanned aircraft’s control 

station,” dated August 8, 2014, the requested relief from 14 

CFR §§ 91.9(b)(2) and 91.203(a) and (b) is not necessary. Notes 

Regarding: §91.109 Flight instruction; Simulated instrument & 

certain flight tests Small UASs, 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. Aircraft being considered for use by 

ISLANDTIME FARMS, LLC allow the UAS pilot to place the 

aircraft into ‘loiter’ mode (fixed altitude stationary hold). In the 

event of the pilot losing control, the UAS Instructor can quickly 

and via alternate equipment (equipment not in the hands of 

the student) place the aircraft into a mode that then allows the 

instructor to bring the aircraft back into control and back to the 

predetermined and/or safe landing location. ISLANDTIME 

FARMS, LLC does not describe training scenarios in which a dual 

set of controls would be utilized or required, i.e. dual flight 

instruction, provided by a flight instructor or other companydesignated individual, that would require that individual to 

have fully functioning dual controls. Rather, ISLANDTIME 

FARMS, LLC evaluates the qualification of its PICs based on their 

experience with the UAS to be operated and verifies through 

testing, in lieu of formalized training. As such, ISLANDTIME 

FARMS, LLC does not seek relief from 14 CFR § 91.109. Notes 

Regarding § 14 CFR 91.119(b) Relief from § 14 CFR 91.119(b), 

operation over congested areas, is not applicable, because the 
ISLANDTIME FARMS, LLC’s operations will only be conducted 

within the secured area described herein. ISLANDTIME FARMS, 

LLC Safety Operations & Procedures Overview: Technology 

Considerations: Best-in-class, tried and proven technologies 

that are in advanced iterations. Software from highly-reputable 

industry partners will include features - 1. Auto descent 

(landing) if communication signal were to be severed. If the 

UAS loses communications, the UAS will have capability to 

return to a pre-determined location within the Security 

Perimeter and land. 2. Auto descent (landing) if battery were to 

drop lower than nominal level. 3. Flights will be terminated at 

25% battery power reserve. 4. Live video for operator gives 

real-time positioning feedback. In other words, we can monitor 

the scene from the vehicle's perspective for collision avoidance, 

and to maintain spatial orientation. 5. The UAS will have the 

capability to abort a flight in case of unpredicted obstacles or 

emergencies. 6. On-Screen-Display (OSD) contains operating 

information to ascertain vehicle health at all times: speed, 

altitude, number of GPS satellites (when available), heading and 

voltage. 7. GPS lock supplies for return-to-home (RTH). Should 

Command and Control (C2) link failures occur (highly 

improbable), vehicle returns automatically to the point of 

launch. 8. Altitude information will be provided to the UAS pilot 

via a digitally encoded telemetric data feed, which downlinks 

from the aircraft to a ground-based on-screen display. This 

altitude information will be generated by equipment installed 

on board the aircraft, using GPS triangulation, or digitally 
encoded barometric altimeter, or radio altimeter, or any 

combination thereof. Prior to each flight, a zero altitude 

initiation point will be established and confirmed for accuracy 

by the pilot. Mechanical/Physical: 1. We will fly line-of-sight 

(LOS) only. The vehicle will always remain in direct LOS to the 

pilot, thus eliminating the concern of signal severance (flying 

behind objects/walls). 2. The UAS will weigh less than 55 lbs 

and travel at less than 50 knots. 3. Batteries should far exceed 

the capacity required for actual flight time. 4. Flights will be 

operated at an altitude of no more than 400 feet AGL. 5. 

Fireproof bags for storage and charging of high capacity Lipo 

batteries on-site. 6. UA operated under this exemption will be 

marked in accordance with 14 CFR part 45 or as otherwise 

authorized by the FAA. Personnel: 1. Spotters ensure safe 

operation and act as a redundant set of eyes for operators 

(pilot, gimbal op, director) 2. Radio spectrum analysis for 

interference on the frequencies utilized for vehicle 

control/communication. 3. A briefing will be conducted in 

regard to the planned UAS operations prior to each day’s 

activities. It will be mandatory that all personnel who will be 

performing duties within the boundaries of the safety 

perimeter be present for this briefing. 4. The operator will 

obtain the consent of all persons involved in the UAS

operations and ensure that only consenting persons will be 

allowed within 100 feet of the flight operations. 5. Observer 

and pilot will at all times be able to communicate by voice. 6. 

Written and/or oral permission from the relevant property 
holders will be obtained. 7. Pilot and observer will have been 

trained in operation of UAS generally and received up-to-date 

information on the particular UAS to be operated. Operations: 

1. The unmanned aircraft (UA) must weigh less than 55 pounds 

(25 Kg), including energy source(s) and equipment. Operations 

authorized by this petition of exemption are limited to the 

following aircraft described in Appendix B. Proposed operations 

of any other aircraft will require a new petition or a petition 

amendment to this request. 2. The UA may not be flown at a 

ground speed exceeding 50 knots. 3. Flights must be operated 

at an altitude of no more than 400 feet above ground level 

(AGL), as indicated by the procedures specified in the 

operator’s manual. All altitudes reported to ATC must be in feet 

AGL. 4. The UA must 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 medical certificate. 

5. All operations must utilize a visual observer (VO). The VO 

may be used to satisfy the VLOS requirement as long as the PIC 

always maintains VLOS capability. The VO and PIC must be able 

to communicate verbally at all times. 6. The operator’s manual 

included as Appendix C and this petition of exemption must be 

maintained and made available to the Administrator upon 

request. If a discrepancy exists between the conditions and 

limitations in this exemption and the procedures outlined in the 

operator’s manual, the conditions and limitations herein take 

precedence and must be followed. Otherwise, the operator 
must follow the procedures as outlined in its operator’s 

manual. The operator may update or revise its operator’s 

manual. It is the operator’s responsibility to track such revisions 

and present updated and revised documents to the 

Administrator upon request. The operator must also present 

updated and revised documents if it petitions for extension or 

amendment. If the operator determines that any update or 

revision would affect the basis for which the FAA grants this 

petition for exemption, then the operator must petition for 

amendment to their exemption. The FAA’s UAS Integration 

Office (AFS-80) may be contacted if questions arise regarding 

updates or revisions to the operator’s manual. 7. Prior to each 

flight the PIC must inspect the UAS to ensure it is in a condition 

for safe flight. If the inspection reveals a condition that affects 

the safe operation of the UAS, the aircraft is prohibited from 

operating until the necessary maintenance has been performed 

and the UAS is found to be in a condition for safe flight. The 

Ground Control Station, if utilized, must be included in the 

preflight inspection. All maintenance and alterations must be 

properly documented in the aircraft records. 8. Any UAS that 

has undergone maintenance or alterations that affect the UAS 

operation or flight characteristics, e.g. replacement of a flight 

critical component, must undergo a functional test flight in 

accordance with the operator’s manual. The PIC who conducts 

the functional test flight must make an entry in the UAS aircraft 

records of the flight. The requirements and procedures for a 

functional test flight and aircraft record entry must be added to 
the operator’s manual. 9. The operator must follow the 

manufacturer’s UAS aircraft/component, maintenance, 

overhaul, replacement, inspection, and life limit requirements. 

When unavailable, aircraft maintenance/component/overhaul, 

replacement, and inspection/maintenance requirements must 

be established and identified in the operator’s manual. At a 

minimum, requirements for the following must be included in 

the operator’s manual: a. Actuators / Servos; b. Transmission 

(single rotor); c. Powerplant (motors); d. Propellers; e. 

Electronic speed controller; f. Batteries; g. Mechanical dynamic 

components (single rotor); h. Remote command and control; i. 

Ground control station (if used); and j. Any other components 

as determined by the operator; 10. The Pilot In Command (PIC) 

must possess at least a private pilot certificate and at least a 

current third-class medical certificate. The PIC must 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 sport pilot license. 

11. Prior to operations conducted for the purpose of 

infrastructure inspections, the PIC must have accumulated and 

logged, in a manner consistent with 14 CFR § 61.51(b), a 

minimum of 20 flight cycles and 10 hours of total time as a UAS 

rotorcraft pilot and at least 10 hours logged as a UAS pilot with 

a similar UAS type (single blade or multirotor). Prior 

documented flight experience that was obtained in compliance 

with applicable regulations may satisfy this requirement. 

Training, proficiency, and experience-building flights can also be 

conducted under this petition of exemption to accomplish the 
required flight cycles and flight time. During training, 

proficiency, and experience-building flights, all persons not 

essential for flight operations are considered nonparticipants, 

and the PIC must operate the UA with appropriate distance 

from nonparticipants in accordance with 14 CFR § 91.119. 12. 

Prior to operations conducted for the purpose of infrastructure 

inspection, the PIC must have accumulated and logged, in a 

manner consistent with 14 CFR § 61.51(b), a minimum of five 

hours as UAS pilot operating the make and model of UAS to be 

utilized for operations under the exemption and three take-offs 

and three landings in the preceding 90 days. Training, 

proficiency, experience building, and take-off and landing 

currency flights can be conducted under this petition of 

exemption to accomplish the required flight time and 90 day 

currency. During training, proficiency, experience-building, and 

take-off and landing currency flights all persons not essential 

for flight operations are considered nonparticipants, and the 

PIC must operate the UA with appropriate distance from 

nonparticipants in accordance with 14 CFR § 91.119. 13. Prior 

to any flight operations authorized by this petition of 

exemption, the PIC and VO must have successfully completed a 

qualification process, as outlined in the operator’s manual. As 

this is a requirement stipulated by the operator, the test must 

be developed and implemented by a qualified person 

designated at the sole discretion of the operator. A record of 

completion of this qualification process must be documented 

and made available to the Administrator upon request. 14. 
Prior to operations conducted for the purpose of infrastructure 

inspection, a flight demonstration, administered by an 

operator-approved and -qualified pilot must be successfully 

completed and documented. This documentation must be 

available for review upon request by the Administrator. 

Because the knowledge and airmanship test qualifications have 

been developed by the operator, and there are no established 

practical test standards that support a jurisdictional FAA FSDO 

evaluation and approval of company designated examiners, the 

petitioner will conduct these tests in accordance with the 

operator’s manual. 15. The UA may not be operated directly 

over any person, except authorized and consenting personnel, 

below an altitude that is hazardous to persons or property on 

the surface in the event of a UAS failure or emergency. 16. 

Regarding the distance from participating persons, the 

operator’s manual has safety mitigations for authorized and 

consenting personnel. At all times, those persons must be 

essential to the operations. 17. Regarding distance from 

nonparticipating persons, the operator must ensure that no 

persons are allowed within 500 feet of the area except those 

consenting to be involved and necessary for the infrastructure 

inspection operations. This provision may be reduced to no less 

than 200 feet if it would not adversely affect safety and the 

Administrator has approved it. For example, an equivalent level 

of safety may be determined by an aviation safety inspector’s 

evaluation of the infrastructure inspection area to note terrain 

features, obstructions, buildings, safety barriers, etc. Such 
barriers may protect nonparticipating persons (observers, the 

public, news media, etc.) from debris in the event of an 

accident. 18. If the UAS loses communications or loses its GPS 

signal, the UA must return to a pre-determined location within 

the security perimeter and land or be recovered in accordance 

with the operator’s manual. 19. The UAS must abort the flight 

in the event of unpredicted obstacles or emergencies in 

accordance with the operator’s manual. 20. Each UAS operation 

must be completed with 25% battery power remaining. 21. The 

operator must obtain an Air Traffic Organization (ATO) issued 

Certificate of Waiver or Authorization (COA) prior to conducting 

any operations under this petition of exemption. This COA will 

also require the operator to request a Notice to Airman 

(NOTAM) not more than 72 hours in advance, but not less than 

48 hours prior to the operation. 22. All aircraft operated in 

accordance with this exemption must be identified by serial

number, registered in accordance with 14 CFR part 47, and 

have identification (N-Number) markings in accordance with 14 

CFR part 45, Subpart C. Markings must be as large as 

practicable. 23. The operator must develop procedures to 

document and maintain a record of the UAS maintenance, 

preventative maintenance, alterations, status of 

replacement/overhaul component parts, and the total time in 

service of the UAS. These procedures must be added to the 

operator’s manual. 24. Each UAS operated under this 

exemption must comply with all manufacturer Safety Bulletins. 

25. The operator must develop UAS technician qualification 
criteria. These criteria must be added to the operator’s manual. 

26. The preflight inspection section in the operator’s manual 

must be amended to include the following requirement: The 

preflight inspection must account for all discrepancies, i.e. 

inoperable components, items, or equipment, not covered in 

the relevant preflight inspection sections of the operator’s 

manual. 27. Before conducting operations, the radio frequency 

spectrum used for operation and control of the UA must 

comply with the Federal Communications Commission (FCC) or 

other appropriate government oversight agency requirements. 

28. At least three days before scheduled infrastructure 

inspection, the operator of the UAS affected by this exemption 

must submit a written Plan of Activities to the local FSDO with 

jurisdiction over the area of proposed infrastructure inspection. 

The 3-day notification may be waived with the concurrence of 

the FSDO. The plan of activities must include at least the 

following: a. Dates and times for all flights; b. Name and phone 

number of the operator for the UAS infrastructure inspection 

operations conducted under this petition of exemption; c. 

Name and phone number of the person responsible for the onscene operation of the UAS; d. Make, model, and serial or Nnumber of UAS to be used; e. Name and certificate number of 

UAS PICs involved in the infrastructure inspection event; f. A 

statement that the operator has obtained permission from 

property owners and/or local officials to conduct the 

infrastructure inspection event; the list of those who gave 

permission must be made available to the inspector upon 
request; g. Signature of exemption-holder or representative; 

and h. A description of the flight activity, including maps or 

diagrams of any area, city, town, county, and/or state over 

which infrastructure inspection will be conducted and the 

altitudes essential to accomplish the operation. 29. The 

documents required under 14 CFR §§ 91.9 and 91.203 must be 

available to the PIC at the Ground Control Station of the UAS 

any time the aircraft is operating. These documents must be 

made available to the Administrator or any law enforcement 

official upon request. 30. The UA must 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.). 

31. UAS operations may not be conducted during night, as 

defined in 14 CFR § 1.1. All operations must be conducted 

under visual meteorological conditions (VMC). Flights under 

special visual flight rules (SVFR) are not authorized. 32. The UAS 

may not be operated by the PIC from any moving device or 

vehicle. 33. The UA may 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. 34. The UA 

may not operate in Class B, C, or D airspace without written 

approval from the FAA. The UA may not operate within 5 

nautical miles of the geographic center of a non-towered 

airport as denoted on a current FAA-published aeronautical 

chart unless a letter of agreement with that airport’s 

management is obtained, and the operation is conducted in 
accordance with a NOTAM as required by the operator’s COA. 

The letter of agreement with the airport management must be 

made available to the Administrator upon request. 35. Any 

incident, accident, or flight operation that transgresses the 

lateral or vertical boundaries of the operational area as defined 

by the applicable COA must be reported to the FAA’s UAS 

Integration Office (AFS-80) within 24 hours. Accidents must be 

reported to the National Transportation Safety Board (NTSB) 

per instructions contained on the NTSB Web site: 

www.ntsb.gov. Further flight operations may not be conducted 

until the incident, accident, or transgression is reviewed by AFS80 and authorization to resume operations is provided. Support 

for Petition for Exemption In accordance with the procedural 

requirements of 14 C.F.R. §11.81, ISLANDTIME FARMS, LLC

provides the following information: Contact Information: Paul 

Gryce Owner Islandtime Farms, LLC. 2112 Blakemore Lane, La 

Grange, KY 40031 (502) 310-9572 Paul@islandtimefarms.com

Regulatory Provisions from which ISLANDTIME FARMS, LLC

seeks an Exemption, ISLANDTIME FARMS, LLC believes it may 

need an exemption from the following provisions to conduct 

the contemplated operations. In some instances, relief is 

needed because relief from another provision renders 

compliance with the regulation at hand infeasible. 333 Aircraft 

Exemption Status 14 C.F.R. §61.113(a) and (b) 14 C.F.R. 

§91.119(c) 14 C.F.R. §91.121 14 C.F.R. §91.151 14 C.F.R. 

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

C.F.R. §91.417(a)&(b) ISLANDTIME FARMS, LLC believes an 
exemption is only needed from the above-listed regulatory 

provisions. To the extent that the FAA believes that additional 

relief is required for ISLANDTIME FARMS, LLC to conduct the 

operations described here, we request an exemption from any 

such regulatory provisions as well.3 3 For example, 14 C.F.R. 

§91.417(a) imposes certain maintenance record keeping 

requirements “as applicable”. Since none of the underlying 

requirements (e.g., inspection intervals) can be met and will 

require an exemption, ISLANDTIME FARMS, LLC believes a 

separate exemption should not be required for §91.417(a). The 

Extent of Requested Relief and the Reasons Relief is Needed 

Section 333 Aircraft Exemption Status: Section 333 of the 

Modernization Act authorizes the FAA to exempt aircraft from 

the requirement for an airworthiness certificate based on a 

consideration of the size, weight, speed, operational capability 

of the particular UAS, as well as its proximity to airports and 

populated areas. An analysis of these criteria demonstrates 

that the UAS operated without an airworthiness certificate in 

the areas and under the conditions contemplated by 

ISLANDTIME FARMS, LLC will be at least as safe, or safer, than a 

conventional aircraft (fixed wing or rotorcraft) operating with 

an airworthiness certificate without the conditions proposed in 

this request. The UAS is less than 55 lbs. fully loaded, carries 

neither a pilot nor passenger, and operates exclusively within a 

secured area. Unlike other civil aircraft, operations under this 

exemption will be tightly controlled and monitored by the 

operator and observer. Operations will be conducted in 
compliance with the FAA and with local public safety 

requirements to provide security for the area of operation as is 

now done with conventional equipment, infrastructure, bridge 

and out building evaluation. These safety enhancements 

provide an expanded degree of safety to the inspectors over 

conventional operations. Lastly, application of these same 

criteria demonstrates that there is no credible threat to 

national security posed by the UAS, due to its size, speed of 

operation, location of operation, lack of explosive materials and 

inability to carry a substantial external load. Given the size and 

limited operating area associated with the aircraft to be utilized 

by the Applicant, this 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 

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

the 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. 14 C.F.R. 

§61.113(a) and (b) §61.113 Private pilot privileges and 

limitations: Pilot in command. (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. ***** ISLANDTIME FARMS, LLC

anticipates initially using a cadre of specially trained staff to 

conduct the UAS operations. While these individuals will not 

hold commercial pilot licenses. The UAS will not carry property 

for compensation or hire since they will be used solely to assist 

in evaluation of the infrastructure, equipment, right-of-way, 

assets, bridges, tunnels and out-buildings in furtherance of 

ISLANDTIME FARMS, LLC’s client’s primary business, the 

successful operation of a infrastructure; however, the 

employees’ operation of the UAS will not be incidental to their 

employment with ISLANDTIME FARMS, LLC, and they will be 

compensated for such work. Without an exemption, the pilot 

would be required to hold a commercial pilot certificate under 

§61.133. However, the risk associated with the contemplated 

operations is less than the risk posed by a traditional aircraft. 

The UAS will fly at altitudes well below the permissible limits 

for other civil aircraft, eliminating the risk to other aircraft, and 

within a geographical envelope under the sole control of 

ISLANDTIME FARMS, LLC clients. Accordingly, the risk would be 
limited to ISLANDTIME FARMS, LLC personnel, who will be 

appropriately outfitted in safety gear, and ISLANDTIME FARMS, 

LLC client’s property on the ground. Requiring a commercial 

pilot certificate would provide no appreciable safety benefit 

and would needlessly impose additional cost on ISLANDTIME 

FARMS, LLC. Because the contemplated operations would not 

comply with §61.113(b)(1) and none of the other exceptions to 

paragraph (a) apply, relief is needed from both paragraphs (a) 

and (b). 14 C.F.R. 91.119(c) §91.119 Minimum safe altitudes: 

General. 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. ***** ISLANDTIME FARMS, LLC submits that the only 

relief it requires from §91.119 is from the minimum altitudes 

listed in paragraph (c). Relief is required from paragraph (c) for 

fixed wing operations because asset evaluation conducted at 

500 feet or higher is insufficiently distinct to be meaningful. 

Since operations at this altitude also pose a heightened risk of 

collision with another aircraft, safety can only be assured 

through the grant of an exemption. The anticipated rotorcraft 

operations should be adequately addressed by paragraph (d) 

(1). Additionally, relief should not be needed from paragraph 

(a) because an emergency landing of the aircraft due to a 

power failure will not create an undue hazard to persons or 
property on the surface. As noted in the explanation of why an 

exemption will not adversely affect safety, ISLANDTIME FARMS, 

LLC clients has exclusive use of the land over which the UAS will 

be operated, and public access is restricted. It also has exclusive 

use of significant portions of land adjacent to the infrastructure 

and structures that will be the objects of evaluation and 

analysis. ISLANDTIME FARMS, LLC’s Clients tightly control 

access to land and have the ability to assure that no individuals 

unassociated with the planned operations are on the affected 

land. As such, the risk of injury is minimal. ISLANDTIME FARMS, 

LLC does not contemplate conducting operations over 

congested areas, so relief is not requested from paragraph (b). 

14 C.F.R. 91.121 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 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 Manual and Safety Check list, confirming the 

altitude of the launch site shown on the GPS altitude indicator 

before flight. Altitude information will be provided to the UAS

pilot via a digitally encoded telemetric data feed, which 

downlinks from the aircraft to a ground-based on-screen 

display. This altitude information will be generated by 

equipment installed on board the aircraft, using GPS 
triangulation, or digitally encoded barometric altimeter, or 

radio altimeter, or any combination thereof. Prior to each flight, 

a zero altitude initiation point will be established and confirmed 

for accuracy by the pilot. 14 C.F.R. 91.151 §91.151 Fuel 

requirements for flight in VFR conditions. (a) No person may 

begin 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. (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. ***** Operating 

the UAS in a pre-defined area with less than 30 minutes of 

reserve fuel does not raise the type of risk contemplated by 

§91.151, i.e., that an aircraft could run out of fuel in the event it 

has to be flown to an alternate airport or circle the planned 

airport in the event of unanticipated conditions. ISLANDTIME 

FARMS, LLC does not intend to use the UAS for point-to-point 

flights and will not operate the UAS beyond visual line of sight. 

Nor will the UAS require an airport in order to land. Rather, 

ISLANDTIME FARMS, LLC will operate the UAS using preplanned flight paths (taking into account weather conditions) 

designed to allow the UAS to fly to the point of intended 

landing. As such, there is no need for a timebased excess fuel 

requirement. Rather it should be sufficient to require only as 
much additional excess flight capacity as necessary to safely 

land the UAS. We believe that a 25% battery reserve is more 

than sufficient to meet this objective. 14 C.F.R. 91.405(a), 

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

91.417(a) & (b) §91.405 Maintenance required. 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; ***** §91.407 Operation after maintenance, 

preventive maintenance, rebuilding, or alteration. (a) No 

person may operate any aircraft that has undergone 

maintenance, rebuilding, or alteration unless – (1) It has been 

approved for return to service by a person authorized under 

§43.7 of this chapter; ***** §91.409 Inspections. (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. ***** §91.417 (a) & 

(b) ***** ISLANDTIME FARMS, LLC believes that an exemption 

from these three maintenance requirements is appropriate 

because the FAA has not developed maintenance standards 

that would allow an operator to meet the part 91 maintenance 

requirements. In particular, there are no individuals authorized 
by the FAA to approve a UAS for return to service under 

§91.407(a) or to conduct the initial airworthiness and annual 

return to service inspections required by §91.409(a). 

ISLANDTIME FARMS, LLC will maintain the aircraft as instructed 

in the owner’s manual and ASTM F2909, where applicable, and 

will not operate the aircraft until it has reasonably determined 

that any needed repairs have been made. However, because of 

the technical impossibility of meeting the requirements of 

§§91.405(a), 407(a), 409(a) and 417(a)&(b), we believe an 

exemption from these provisions is appropriate. Please do not

hesitate to contact me at the phone number or via the e-mail 

address provided above should you have any questions or 

concerns. Respectfully submitted, Simon Nielsen CEO, Drone 

Fleet & Aerospace Management, Inc. Appendix A Summary for 

Federal Register Publication Pursuant to 14 C.F.R. Part 11, the 

following summary is provided for publication in the Federal 

Register should the FAA determine that publication is needed. 

Petitioner: Drone Fleet & Aerospace Management, Inc. 

(ISLANDTIME FARMS, LLC) Sections of 14 C.F.R. Affected: 333 

Aircraft Exemption Status 14 C.F.R. §61.113(a) and (b) 14 C.F.R. 

§91.119(c) 14 C.F.R. §91.121 14 C.F.R. §91.151 14 C.F.R. 

§91.405(a) 14 C.F.R. §91.407(a) 14 C.F.R. §91.409(a) 14 C.F.R. 

§91.417(a)&(b) Description of Relief Sought: Petitioner seeks 

relief from the requirements of 333 Aircraft Exemption Status, 

14 C.F.R., 61.113(a)&(b)), 91.119(c), 91.121, 91.151, 91.405(a), 

91.407(a), 91.409(a), and 91.417(a)&(b) to conduct UAS

operations over ISLANDTIME FARMS, LLC Client’s owned or 
controlled land, solely during daylight hours, to assist in the 

safe evaluation and analysis of infrastructure and operations. In 

general, UAS operations are intended to be conducted in areas 

remote from both congested areas and airports. The nature of 

operations anticipated by ISLANDTIME FARMS, LLC requires 

that the UAS be flown at relatively low altitudes. ISLANDTIME 

FARMS, LLC expects that in most instances, the UAS will be 

flown less than 75 feet from the highest structure along the 

path of the UAS and in no instances will be flown higher than 

400 feet above the ground. Accordingly, the risk of interference 

with other aircraft is minimal. 

Appendix B Specific type(s), make, and model #1 –

RCT 800 Chassis

RTC APM ArduFlyer V2.5.2 Flight Controller (Not sure)

RCT CN06 Plus GPS Receiver

RCT HP4215-630KV motors x6

RCT HVSK-40A ESC x6

RCT 12x4.5 Carbon Fiber Blades x6

RCT Anti Vibration Dome Kit

RCT Beeper

RCT Power Conditioning Capacitor

RCT USB cable to Connect with "Mission Planner" software

RCT 915 MHZ Telemetry Air Module and Ground Station
RCT Battery Voltage Tester/Alarm x2

RCT Removable Battery Tray x2

RCT Carbon Fiber Landing Gear

RCT Black ASP 3 Axis Nex-GH5 Brushless Gimbal with BaseCam 

Simple BGC 32bit Brushless Gimbal Controller Alum case 

Version

RCT 5v/5a SBEC Conditioned power supply

Thunderbolt 5.8G 32CH 2000mW TS5832 Transmitter

ELGAE 32CH/5.8G Wireless Receiver

Zippy 8000mah 4s 14.8v 30c Lipo Battery x3

Walkera Devo 7 Transmitter & Devo AX701 7 Channel 

Receiver