DroneFleet Company 

123 Swopes Valley rd 

Pine Grove PA 17963 

FAA 

Docket Management Facility 

U.S. Department of Transportation 

1200 New Jersey Avenue, SE 

West Building, Ground Floor, Room W12-140 

Washington, DC 20590 

Re: Petition of DroneFleet Exemption Request Pursuant To Section 333 of the FAA 

Reform Act of 2012 

Dear Exemption Manager, 

I. Description of Petitioner 

We are submitting our Petition for Exemption for Unmanned Aircraft Systems operations. 

DroneFleet Company, operator of Small Unmanned Aircraft Systems (sUASs) equipped to conduct 

aerial photography for the media and advertising industries for pre-planned, controlled area, 

photographic and surveying services, hereby applies for an exemption from the listed Federal 

Aviation Regulations (FARs) to allow commercial operation of its sUASs, so long as such operations 

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

Federal Aviation Administration (FAA) as required by§333. DroneFleet Company current operation 

of sUASs for commercial purposes has been halted to comply with recently enacted federal aviation 

regulations pertaining to sUASs. 

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

unmanned and relatively inexpensive multi-rotor aircraft under controlled conditions in airspace that 

is 1) contained 2) predetermined 3) has on-site safety personnel controlling access, and 4) would 

provide increased safety and enhancements to clients' business operations. 

DroneFleet has an experienced 11AS team encompassing a wide range of disciplines 

and skill sets to offer safe and effective services to its customers. 

The name and address of the applicant is: 

DroneFleet Company 

Address: 123 Swopes Valley rd Pine grove PA 17963 

Attn: Michael Zimmerman 

Ph:+1- (717)-553-9510 

Email: sales@air4marketing.com 
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June 10.2015 

Page 2 

II. Types of Operations 

A. Request to Use UASs for R&D and Training at Test Sites Owned or 

Controlled by DroneFleet 

DroneFleet seeks the following exemptions to conduct training and research and 

development at its own facilities and property. The test areas will not be open to the public and 

access will be restricted to DroneFleet employees or consultants engaged in flight tests, 

training, maintenance, or test-related work. The primary focus of DroneFleet R&D efforts 

is to evaluate how to best incorporate the UAS into Dronefleet Business procedures. 

B. Request to Use UASs for Business Marketing 

DroneFleet request for exemption focuses on its use of UAS for Marketing for conduct aerial 

photography for the media, real estate, advertising industries, and any legal purpose using UAS 

in new application in this industry. 

C. Request to Use UASs for Surveying Services 

DroneFleet also seeks exemption to perform surveying service for its commercial and residential 

property. In particular, inspections and evaluations of the roofs of large commercial 

structures, or where the roof has an especially steep pitch, provides unique challenges. 

Currently, most such roofs have to be inspected by physically sending a person onto the structure 

using ladders. These inspections are time consuming and carry a number of different risks, all of 

which can be mitigated or eliminated through the use of UAS. 

Also structures can be compromised, or access to portions of the property may be blocked due to 

flooding or debris. Sending a person in to inspect the upper portions of a damaged structure may not 

be practical or safe. These are the types of situations where UAS can provide a safe and effective 

alternative that not only permits an inspection, but can fully document the results 

III. Relevant Statutory Authority 

This Petition for Exemption is submitted pursuant to Section 333(a) through (c) of the 

FAA Modernization and Reform Act of 2012 ("Reform Act"). Congress has directed the FAA 

"to safely accelerate the integration of civil unmanned aircraft systems into the national airspace 

system." Pursuant to Section 333 of the Reform Act, the FAA Administrator is to permit 

unmanned aircraft systems to operate in the National Air Space ("NAS") where it is safe to do so 

based on the following considerations: 

• The UAS's size, weight, speed and operational capability; 

• Operation of the UAS in close proximity to airports and populated areas; and 

• Operation of the UAS within the visual line of sight of the operator.1 

Additionally, the FAA Administrator has general authority to grant exemptions from the 

agency's safety regulations and minimum standards when the Administrator decides a requested 

exemption is in the public interest. See 49 U.S.C. § 106(f) (defining the authority of the 

Administrator); 49 U.S.C. § 44701(f) (permitting exemptions from** 44701(a), (b) and§§ 44702-

44 716, et seq.). A party requesting an exemption must explain the reasons why the exemption: (1) 

would benefit the public as a whole, and (2) would not adversely affect safety (or how it would 

provide a level of safety at least equal to the existing rules). See 14 C.F.R. § 11.81 (petitions for 

exemption). 

IV. DroneFleet's Proposed UAS Operations Meet the Requirements of Section 333 of 

the Reform Act 

DroneFleet's proposed operations in this Petition for Exemption qualify for expedited 
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June 10.2015 

Page 3 

approval pursuant to Section 333 of the Reform Act as each of the statutory criteria and relevant 

factors are satisfied. 

A. Approval is Warranted Based on the UAS's Size, Weight, Speed, and 

Operational Capability 

DroneFleet will employ the Following DJI Phantom 2-3, DJI inspire.3DR Solo and SteadiDrone 

VADER quadcopter DJI S1000+ octocopter and any new airframe updates for the operations 

specified in this Petition for Exemption. This UAS has a maximum take -off weight of less than 55 

pounds. The flight speed will not exceed 55 miles per hour, and it will not be flown in controlled 

airspace or at an altitude that exceeds 400 feet AGL. All flights will be flown in such a way that 

they can be safely terminated with a reserve battery power of 25% of the battery's maximum charge. 

I Id. at 333(b)(I). 

The UAS does not carry any flammable propellant or fuel. The UAS also has 

an integrated GPS system that calculates the UAS's position and height and relays that information 

via a secure connection to the operator. Additionally, the UAS contains a failsafe mode if its 

connection to the remote control is lost, and this system permits the UAS to return to a 

predetermined location and land without injury or damage. 

B Approval is Warranted Based on the Operational Restrictions Set Forth in the 

Operations Manual 

The DroneFleet Operations Manual and the UAS maintenance and flight manuals contain 

all of the procedures and limitations necessary to successfully perform the operations specified in 

this Petition for Exemption. To assist the FAA in making a safety assessment of DroneFleet's 

operations. below is a summary of operational limitations and conditions which will ensure an 

equivalent or higher level of safety for operations conducted under current regulatory guidelines: 

1. The UAS weighs 55 pounds or less. 

2. Flights will be operated within the visual line of sight of a pilot and an observer. 

3. Maximum total flight time for each operational flight will be limited to the amount of 

time the UAS can be flown and still maintain a reserve battery power of no less than 

25%. 

4. Flights will be operated at an altitude of no more than 400 feet AGL and will not be 

conducted within navigable airspace. 

5. Flights will be operated at a lateral distance of at least 150 feet from any persons, 

inhabited structures, vehicles or vessels that are not involved in the inspection unless 

permission has been received from the persons or property owners in advance. 

6. Flights will be limited to a speed of 35 m.p.h. and vertical ascent will be limited to 15 

m.p.h. 

7. Minimum crew for each operation will consist of the UAS Pilot, one or more Visual 

Observers as necessary to safely conduct the mission, and a Sensor Operator, if the 

sensor requires human direction or control. 

8. The observer designated for any operation will be in constant voice contact with the 

pilot. 

9. The UAS will operate in accordance with the requirements of its flight and 

maintenance manuals. 

10. Prior to the operation, a Mission Plan will be created setting forth the limitations for 

the flight as well as contact and hazard information. 

11. A NOTAM will be issued not more than 72 hours in advance of flight, but not less 
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June 10,2015 

Page 4 

than 48 hours before flight. 

12. A Certificate of Authorization will be obtained prior to flight. 

13. All required permissions and permits will be obtained from territorial, state, county or 

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

governmental agencies. 

14. The operator will coordinate all flights with the appropriate Flight Standards District 

Office. 

15. If the UAS loses communication with the pilot, it will have the capability to 

return to a pre-determined location within the operational area and land. 

16. Contingency plans will be in place to safely terminate flight if there is a loss of 

communication between the pilot and the observer. 

17. The UAS will have the capability to abort flight in the case of unpredicted obstacles 

or emergencies. 

18. Both the Pilot and Observer will have a current Class III Medical Certificate or Drivers 

License 

REGULATIONS FROM WHICH EXEMPTION IS REQUESTED 

The Federal Aviation Act expressly grants the FAA the authority to issue exemptions. 

This statutory authority, by its terms, includes exempting civil aircraft, as the term is defined 

under§ 40101 of the Act, including UASs, from its safety regulations and minimum standards 

when the Administrator decides a requested exemption is in the public interest. 2 

DroneFleet seeks an exemption from several interrelated provisions of 14 C.F.R. Parts 

21, 45, 61 and 91 for purposes of conducting the requested operations using a UAS. Listed 

below are (1) the specific sections of 14 C.F.R. for which exemption is sought, and (2) the 

2 See 49 U.S.C. § 44701(f) (authorizing the grant of exemptions from requirements of regulations 

prescribed pursuant to Sections 44701(a) and (b) and Sections 44702- 44716). 

operating procedures and safeguards that Petitioner has established which will ensure a level of 

safety better than or equal to the rules from which exemption is sought.3 

A. 14 C.F.R. Part 21, Subpart H- Airworthiness Certificates and 14 C.F.R. § 

91.203(a)(1) 

The FAA has stated that no exemption is needed from this section if a finding is made 

under the Reform Act that the UAS selected provides an equivalent level of safety when 

compared to aircraft normally used for the same application. These criteria are met, and 

therefore no exemption is needed. See Grant of Exemption to Astraeus Aerial, Docket No. FAA2014-0352 at 13-14,22. If, however, the FAA determines that there are some characteristics of 

the chosen UAS that fail to meet the requirements of the Reform Act, an exemption is requested. 

Equivalent Level of Safety 

The UASs selected by DroneFleet is safe when taking into account their size, weight, speed, 

and operational capability. As set forth in Section II, Supra, the UAS weighs less than 55 pounds 

and will be flown at less than 100 miles per hour and completely outside controlled airspace. 

Additionally, the UASs carry neither pilots nor passengers, carry no explosive materials and or 

flammable liquid fuels, and operate exclusively within the parameters stated in the Operations 

Manual. Operations under this exemption will be closely controlled and monitored by the operator 

and will be conducted in compliance with local public safety requirements, to provide security 

for the area of operation. DroneFleet will also provide the FAA with advance notice of all 
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June 10,2015 

Page 5 

operations via NOTAMS and coordination with the local FSDO. In all cases, the UAS operated 

under the proposed conditions, will be at least as safe as, or safer than conventional rotorcraft 

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

UAS operations. 

The UAS does not need a means to communicate with other aircraft or A TC, because 

those capabilities will be possessed by the pilot and observer, who are not onboard. See Grant of 

Exemption, Docket FAA-2014-0352 at 13. In addition, no sense and avoid technology is 

necessary on the UAS because it will be operated at all times by visual line-of-sight. Id. 

3 See 14 C.F.R. § 11.81(e), which requires a petition for exemption to include: 

The reasons why granting the exemption would not adversely affect safety, or how the 

exemption would provide a level of safety at least equal to that provided by the rule from 

which you seek exemption. 

B. 14 C.F.R. Part 27 Airworthiness Standards: Normal Category 

Rotorcraft 

14 C.P.R. Part 27 sets forth the procedural requirements for airworthiness certification of 

normal category rotorcraft. To the extent the Petitioner's UAS would otherwise require 

certification under Part 27, Petitioner seeks an exemption from Part 27's airworthiness standards 

for the same reasons identified in the request for exemption from 14 C.F .R. Part 21, Subpart H, 

supra. 

C. 14 C.F.R. §§ 91.9(c), 45.23(b) and 45.27(a): Aircraft Marking and 

Identification Requirements 

DroneFleet seeks an exemption from the aircraft marking and identification 

requirements contained in 14 C.P.R. §§ 91.9(c), 45.23(b) and 45.27(a). 

• 14 C.P.R.§ 91.9(c), Civil Aircraft Flight Manual, Marking and Placard requirements, 

provides that: 

No person may operate a U.S.-registered civil aircraft unless that aircraft is 

identified in accordance with Part 45 of this chapter. 

• 14 C.P.R. § 45.23(b), Markings of the Aircraft, states: 

When marks include only the Roman capital letter "N" and the registration 

number is displayed on limited, restricted or light-sport category aircraft or 

experimental or provisionally certificated aircraft, the operator must also display 

on that aircraft near each entrance to the cabin, cockpit, or pilot station, in letters 

not less than 2 inches nor more than 6 inches high, the words "limited," 

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

• 14 C.P.R. § 45.27(a), Rotorcraft, states: 

Each operator of a rotorcraft must display on that rotorcraft horizontally on both 

surfaces of the cabin, fuselage. boom, or tail the marks required by § 45.23. 

In a previous Grant of Exemption, the FAA determined that exemption from these 

requirements was warranted provided that the aircraft "have identification (N-Number) markings 

in accordance with 14 C.F.R part 45, Subpart C if the markings are as large as practicable." 

FAA Docket No. FAA-2014-0352. 

Equivalent Level of Safety 

DroneFleet will mark all aircraft with their N-Number in a prominent spot on the 

fuselage with markings that are as large as practicable. 

D. 14 C.F.R. § 91.9(b)(2): Civil Aircraft Flight Manual in the Aircraft and 14 
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C.F.R. § 91.203(a) and (b): Carrying Civil Aircraft Certification and 

Registration 

Pursuant to 14 C.F.R. § 91.9(b)(2): 

(b) No person may operate a U.S.-registered civil aircraft- 

(2) For which an Airplane or Rotorcraft Flight Manual is required by 21.5 of 

this chapter, unless there is available in the aircraft a current approved Airplane or 

Rotorcraft Flight Manual, approved manual material, markings, and placards, or 

any combination thereof 

Pursuant to 14 C.F.R. § 91.203(a) and (b): 

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

has within it the following: 

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

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

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

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

passengers or crew. 

DroneFleet does not request an exemption from this section but instead notifies the 

FAA that, in accordance with FAA Office of Chief Counsel's Opinion dated August 8, 2014, the 

UAS flight manual, registration certificate and other documentation will be kept at the control 

station with the PIC during flight. The Chief Counsel's Office has held that for all UAS 

operations, this alternate method constitutes full compliance with the regulations. 

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

DroneFleet seeks an exemption from 14 C.F.R. § 91.7(a), which requires that a civil 

aircraft be in airworthy condition to be operated. The FAA has stated that no exemption is 

required to the extent that the requirements of Part 21 are waived or found inapplicable. 

Accordingly, Petitioner requests that the requirements for Section 91.7 be treated in accordance 

with Section V(A), supra. 

F. 14 C.F.R. § 91.103: Preflight Action 

DroneFleet seeks an exemption from 14 C.P.R.§ 91.103, which requires a PIC to 

become familiar with specific information before each flight, including information contained in 

the FAA-approved Flight Manual on board the aircraft. While the PIC will be familiar with all 

information necessary to safely conduct the flight, an exemption is requested to the extent that an 

FAA -approved Flight manual is required. 

Equivalent Level of Safety 

An equivalent level of safety will be provided by following the Aircraft Operations 

Manual and flight manual provided by the manufacturer. The PIC will take all required preflight 

actions- including performing all required checklists and reviewing weather, flight requirements, 

battery charge, landing and takeoff distance, aircraft performance data, and contingency landing 

areas- before initiation of flight. The Operations Manual and manufacturer's flight manual will 

be kept at the ground station with the operator at all times. 

G. 14 C.F.R. § 91.109(a): Flight Instruction 

DroneFleet seeks an exemption from 14 C.F.R. § 91.109(a), which provides that "[n]o 

person may operate a civil aircraft (except a manned free balloon) that is being used for flight 

instruction unless that aircraft has fully functioning dual controls." UASs and remotely piloted 

aircraft, by their design, do not have functional dual controls. Instead, flight control is 
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accomplished through the use of a device that communicates with the aircraft via radio 

communications. 

Equivalent Level of Safety 

Given the size and speed of the UAS employed by DroneFleet, an equivalent level of 

safe training can still be performed without dual controls because no pilot or passengers are 

aboard the UAS, and all persons will be a safe distance away in the event that the UAS 

experiences any difficulties during flight instruction. In addition, Petitioner will conduct flight 

training at its Research and Development test sites, which are located on its own property. These 

training flights will be conducted in a sterile area and will otherwise comply with the provisions 

in the Operations Manual for flights at the R&D facility. Accordingly, DroneFleet's proposed 

method of operation provides superior levels of safety. 

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

DroneFleet requests an exemption from the minimum safe altitude requirements of 14 

C.F .R. § 91.119. Section 91.119 prescribes the minimum safe altitudes under which aircraft may 

not operate, including 500 feet above the surface and away from any person, vessel, vehicle, or 

structure in non-congested areas. See 14 C.F.R. § 91.119(c). Section 91.119(d) allows for a 

helicopter to operate at less than those minimum altitudes when it can be operated "without 

hazard to persons or property on the surface," provided that "each person operating the helicopter 

complies with any routes or altitudes specifically prescribed for helicopters by the FAA." 

Equivalent Level of Safety 

Compared to flight operations with rotorcraft weighing far more than the maximum 

weights proposed herein, and given the lack of flammable fuel, any risk associated with these 

operations is far less than those that presently exist with conventional aircraft. An equivalent 

level of safety will be achieved given the size, weight. and speed of the UAS, as well as the 

location where it is operated. In order to avoid any risk to aircraft, flight operations will be 

restricted to 400' AGL or below. As set forth in the Manuals, the UASs will be operated in a 

restricted area, away from persons or structures not involved in the operation. 

I. 14 C.F.R. § 91.121: Altimeter Settings 

This petition seeks an exemption from 14 C.F .R. § 91.121, which requires a person 

operating an aircraft to maintain cruising altitude or flight level by reference to an altimeter that 

is set to the elevation of the departure airport or barometric pressure. An exemption is required 

to the extent that the UASs do not have a barometric altimeter, but rather a GPS altitude read 

out. 

Equivalent Level of Safety 

The FAA has stated that an equivalent level of safety can be achieved if the UASs will be 

operated at 400' AGL or below and within visual line-of-sight in addition to GPS based altitude 

information relayed in real time to the operator. See Grant of Exemption to Astraeus Aerial, 

Docket No. F AA-20I4-0352. As the attached Operations Manual indicates, the chosen UASs 

meets these requirements, and a zero altitude initiation point will be obtained prior to flight. 

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

Conditions 

DroneFleet requests an exemption from 14 C.F.R. § 91.151(a)'s fuel requirements for 

flight in VFR conditions. Section 91.151 states: 

(a) No person may begin a flight in an airplane under VPR conditions unless 

(considering wind and forecast weather conditions) there is enough fuel to fly to 
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the first point of intended landing and, assuming normal cruising speed - 

(1) During the day, to fly after that for at least 30 minutes; or 

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

Here, the technological limitations on UAS battery power means that no meaningful 

flight operations can be conducted while still maintaining a 30 minute reserve. DroneFleet 

proposes that all flights comply with this requirement by mandating that the aircraft be safely 

landed with no less than 25% of battery life remaining. 

Equivalent Level of Safety 

The P AA has stated that an equivalent level of safety is provided if the UAS flight is 

terminated with at least 25% reserve battery power still available. See Grant of Exemption to 

Astraeus Aerial, Docket No. PAA-2014-0352. The Operations Manual conforms to this limit, 

providing an equivalent level of safety. 

K. 14 C.F.R. § 91.405(a), 91.407(a)(1), 91.409(a)(2); 91.417(a) and (b): 

Maintenance Inspections 

DroneFleet seeks an exemption from the maintenance inspection requirements 

contained in 14 C.P.R.§ 91.405(a), 91.407(a)(1), 91.409(a)(2); 91.417(a) and (b). These 

regulations specify maintenance and inspection standards in reference to 14 C.P.R. Part 43. See, 

e.g., 14 C.P.R. § 91.405(a) (stating that each owner or operator of an aircraft "[s]hall have the 

aircraft inspected as prescribed in subpart E of this part and shall between required inspections 

... have discrepancies repaired as prescribed in part 43 of this chapter"). An exemption from 

these regulations is needed because Part 43 and these sections only apply to aircraft with an 

airworthiness certificate, which the UAS will not have. 

Equivalent Level of Safety 

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

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

Operations Manual. As provided in the Operations Manual, flights will not be conducted unless 

a flight operations checklist is performed that includes all of the aircraft's components. The 

Operations Manual also sets requirements for maintenance log books and record keeping as well 

as routine and post-flight maintenance. The Manual sets requirements for appropriate 

maintenance intervals. 

L. 14 CFR Part 61, 14 CFR 61.3, 14 CFR § 61.113: Private Pilot Privileges And 

Limitations 

Petitioner seeks exemption from 14 CFR Part 61, including 14 CFR § 61.3 to the extent 

that these regulations require a UAS operator to have a private pilot's certificate. The purpose of 

Part 61 is to ensure the skill and competency of any PIC matches the airspace in which the PIC 

will be operating. Petitioner has concerns that the training and education of persons obtaining a 

private or commercial pilots license is not an adequate match for UAS operation in low altitude 

environments, particularly given the vast differences in the control and flight profiles between 

conventional aircraft and UAS. Accordingly, Petitioner believes that a requirement for a private 

pilot's license is unnecessary. 

In addition, DroneFleet seeks exemption from 14 C.F .R § 61.113, which restricts 

private pilot certificate holders from flying aircraft for compensation or hire, and which would 

also require a second class medical certificate. The purpose of this section is to ensure the skill 

and competency of any PIC where the aircraft is carrying passengers or cargo for hire. In this 

case, while the UAS will be operated as part of a commercial operation, it carries neither 
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passengers nor cargo. In the Grant of Exemption in FAA Docket No. FAA-2014-0352, the FAA 

determined that the unique characteristics of UAS operation outside of controlled airspace did 

not warrant the additional cost and restrictions attendant with requiring a the PIC to have a 

commercial pilot certificate and class II medical certificate or Drivers License. 

Equivalent Level of Safety 

Petitioner seeks to ensure safe operation by ensuring that any PIC is thoroughly versed in 

airspace and communication issues pertaining to all aircraft operators but also in the unique 

aspects of UAS flight. Accordingly, as set forth in the Operations Manual, Erie Insurance will 

require all PIC to have completed FAA authorized ground school instruction and also to have 

250 hours of logged flight time in a UAS of the same class as will be used for Flight Operations 

(i.e. quadcopter, fixed wing, etc.). In addition, DroneFleet will require all PIC to have logged 

at least 50 hours of flight time in the specific UAS used for the Flight Operation. 

Finally, in order to meet the stated national security goal outlined by Congress in the 2012 FAA 

Reform Act. DroneFleet will require all PIC to pass a criminal background check at the time of 

hiring. 

In addition to the training and experience requirements, DroneFleet has placed 

restrictions on its Flight Operations to ensure an extra margin of safety. The UAS will operate in 

a sterile area away from persons and property not involved in the operation. It will be flown 

based on VLOS at 400' AGL or below. A NOTAM will be issued between 48 and 72 hours 

before the flight is to occur, and the flight will be coordinated with the applicable FSDO. 

In the event that the FAA determines that a waiver of 14 CFR § 61.3 is inappropriate, 

DroneFleet requests that the Exception from 14 CFR § 61.113 still be granted. The training 

and currency standards set forth by DroneFleet in the attached Operations Manual are more 

than adequate to provide the extra margin of safety to allow a private pilot to act as a pilot for 

compensation or hire 

VI. Drug and Alcohol Program 

DroneFleet has policies in place to ensure that no person may act as a PIC, observer, 

or sensor operator if they are under the influence of alcohol or any drug. 

VII. Public Interest 

The public interest will be served by granting DroneFleet Petition for Exemption. 

Congress has established a national policy that favors early integration of UAS into the NAS in 

controlled, safe working environments such as those proposed in this Petition. In addition, the 

public also has an interest in reducing the hazards associated with alternate methods of 

conducting similar inspection operations. Currently inspections are conducted using inspection 

teams physically climbing onto structures using ladders. By using a UAS, an inspector will be 

able to reduce his or her exposure to physical hazards by conducting the inspection while 

remaining safely on the ground. 

Additionally. DroneFleet client base are typically small to medium sized business' looking to 

increase their awareness of structures or landscape on their respective properties through data 

collection other Public Interest aerial video graph for geographical awareness, Business Marketing, 

and real estate marketing has been around for a long time through manned fixed wing aircraft and 

helicopters, but for small business owners, its expense has been cost-prohibitive. Granting this 

exemption to the petitioner would allow us to provide this service at a much lower cost. Further, the 

petitioner indicates his small UAS will pose no threat to the public given its small size and lack of 
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Page 10 

combustible fuel when compared to larger manned aircraft. The petitioner also states that the U.S. 

operation of his UAS will minimize ecological damage and promote economic growth by providing 

information to companies. 

by photographic, video graphic or lidar based surveying. 

These programs prevent accidents and injuries, and there 

is a strong public interest in making these programs more effective through the use ofUASs. 

VIII. Privacy 

All flights will be conducted in accordance with any federal, state or local laws regarding 

privacy. In addition, DroneFleet will adopt a series of standards to protect the privacy rights of 

persons impacted by the UAS operations. 

IX. Federal Register Summary 

Pursuant to 14 C.F.R. Part 11, the following summary is provided for publication in the 

Federal Register, should it be determined that publication is needed: 

DroneFleet seeks an exemption from the following rules: 

14 CFR Part 21, Subpart H; 14 CFR Part 27; 14 CFR 4523(b); 14 CFR Part 61, 14 CFR 

61.3, 14 CFR § 113; 14 CFR 91.7(a); 14 CFR 91.9(b)(2); 14 CFR 91.103; 14 CFR 91.109(a); 14 

CFR 91.119; 14 CFR 91.121; 14 CFR 91.151(a); 14 CFR 91.203 (a) & (b); 14 CFR 91.405(a); 

14 CFR 91.407(a)(1); 14 CFR 91.409(a)(2); 14 CFR 91.417 (a) & (b). 

The exemption will enhance safety by reducing risk to the general public and property 

owners from the substantial hazards associated with performing equivalent work with 

conventional aircraft, rotorcraft, or other methods. 

X. CONCLUSION 

DroneFleet Petition for Exemption satisfies the criteria articulated in Section 

333 of the Reform Act of2012 including weight, speed, operating capabilities, proximity to 

airports and populated areas, operation within visual line of sight and national security. 

Additionally, the Petition provides more than adequate justification for the grant of the requested 

exemptions to permit DroneFleet to operate the selected UAS for the operations specified 

herein. 

Granting the exemption will benefit the public interest as a whole in several ways, 

including (1) significantly improving safety and reducing risk by alleviating human exposure to 

danger, and (2) improving the quality of services and decreasing operating costs compared with 

normal aircraft 

Sincerely, 

M -mei Zimmerman 

DroneFleet