The exemption granted will not adversely affect safety. In fact it will 

dramatically improve not only the safety of people, but will actually 

have a positive effect on the planet as a whole. We three are very 

green in our daily lives and are very excited about the opportunity to 

demonstrate an alternative eco friendly method of film and 

videography. We will follow these strict guidelines when operating 

our UAS:

We, will not operate the UAS above 300 feet at any time, which is 

below the purposed 400 foot limit.

Our UAS will not operate for more that 10 minutes of flying (the 

manufacture advertises 20 minuets) without landing and a mid flight 

inspection being performed. 

Our UAS will always have a pilot and spotter present at all times and 

we will require no other person (s) to come within 500 foot of pilot 

spotter or UAS.

We will operate our UAS once very specific conditions have been 

met. Those conditions include but are not limited to: 

Wind being no more than 10 miles per hour.

Absoluetly no precipitation current or at any point during the 

purposed flight of the UAS.

There are no powerlines, airports, hospitals, schools, or private 

business within the operating peramaters of the UAS.

Our UAS is equipped the latest technology and is built on an 

upgradable platform to enable the use of the latest safety updates 

possible. With that being said, our UAS not only provides us with 

flight data that we analize after each flight but video and animated 

renderings of the flight to enable better analysis.

We, Westside Drone believe that we are operating at a level of safety 

beyond what is required to do so and will continue to operate in this 

fashion. We understand that we will be examples to follow and are all 
three very active and know in our respective communities. It is of the 

upmost importance to us as we realize the totality the fact that our 

skies will be filled with drones in the near future. We support a very 

regulated future for UAS. The loss of life has been mitigated due to 

several factors:

The UAS’s small (under 10 lbs) size

The UAS contains no fuel

The UAS will avoid densely populated areas.

The manuaverability of the UAS provides safety.

The Regulations from which exemptions are sought

The FAA has been granted authority to issue exemptions by the 

Federal Aviation Act. Westside Drone seeks exemptions from the 

following provisions: C.R.F. Parts 21,27,45,61,91. We are asking for 

these exemptions to provide a service to those in need while in no 

way adversely affecting the safety of anyone. Following are specific 

sections and reasons how Westside Drone will not adversely affect 

the safety of anyone.

CRF Part 21 sub part H: Airworthiness Certificate.

Part 21 sub part H describes the way the FAA issues Airworthiness 

Exemptions and the procedures it has in place when considering 

issuing a certificate. 91.203 (A) The size and weight of our UAS will 

far exceed the safety requirments of the FAA’s reform act. The FAA 

has the ability to consider weight, speed, size, manuaverability of 

craft when issuing exemption.

CRF PART 21 sub part 27: Airwothiness standards for normal 

category Rotorcraft

We seek exemption from the above air worthiness standards based 

on size, weight, manuaverability, and operational area. As noted in 

sub part 21 the nature of the UAS is not similar in nature to a manned 

aircraft meaning items such as flight maunals be carried on board is 

not possible based on type of craft operated. 

CFR 45.23 Display of Marks; General
(a) Each operator of an aircraft must display on that 

aircraft marks consisting of the Roman capital letter 

(b) “N” (denoting United States registration) followed by 

the registration number of the aircraft. Each suffix 

letter used in the marks displayed must also be a 

Roman capital letter.

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.

We as pilots in addition to our spotter will be able to clearly

identify the markings on the UAS. The FAA has approved

numerous petetions in the past.

14 C.F.R. § 61.113: Private Pilot Privileges and 

Limitations: PIC. 

Private pilots are limited to non commercial operations

Having a commercial pilots license could be benefical but is not 

relevant to operating a UAS. All 3 pilots have over 5 years in the 

UAS/RC field as well as college level education in relevant 

application. The levels of operating a UAS are far less than on a 

typical commercial aircraft outline in 14 C.R.F. 61.113. so we would 

be able to to operate the UAS at and above the current safety levels.

§ 91.119 Minimum safe altitudes: General.

Except when necessary for takeoff or landing, no person may operate 

an aircraft below the following altitudes:
(a) Anywhere. An altitude allowing, if a power unit fails, an 

emergency landing without undue hazard to persons or property on 

the surface.

(b) Over congested areas. Over any congested area of a city, town, 

or settlement, or over any open air assembly of persons, an altitude 

of 1,000 feet above the highest obstacle within a horizontal radius of 

2,000 feet of the aircraft.

(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.

(d) Helicopters, powered parachutes, and weight-shift-control 

aircraft. If the operation is conducted without hazard to persons or 

property on the surface—

(1) A helicopter may be operated at less than the minimums 

prescribed in paragraph (b) or (c) of this section, provided each 

person operating the helicopter complies with any routes or altitudes 

specifically prescribed for helicopters by the FAA; and

(2) A powered parachute or weight-shift-control aircraft may be 

operated at less than the minimums prescribed in paragraph (c) of 

this section.

Based on the size, weight and other mitigating factors of the UAS 

being flown an Adequate level of safety will be exceed. 

We will only be operating at a mximum altitude of 300 feet far below 

the standard set by the FAA. In addition to the pre and mid flight 

inspections we will operate our UAS in the safest strictest fashion, 

away from populated areas, buildings. Given the factors listed we will 

be able to meet and exceed an adequate level of safety.

14 C.F.R. 91.405 (a); 407 (a) (1); 409 (a) (2); 417(a) & (b):

Maintenance Inspections. 

The above-cited Regulations require, amongst other things, 

aircraft owners and operators to “have [the] 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.

This is not applicable to our UAS. However before each flight and at 

the halfway point we perform inspections of our UAS. This ensures 

we are able to exceed the current safety standards.

14 C.R.F. 91.9 (b) 91.203 (a & b) Civil Aircraft flight maual in the 

aircraft

(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. 

14 C.F.R. § 91.203(a) and (b) state: 

(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. 

This is not appliciable to the UAS as there is no room for a flight 

manual, no cabin & no cockpit.

It is the opinion of the FAA as stated in previous cases that provided 

PIC has all certifications flight manuals and documentation at the 

ground control station that is acceptable to meet the current safety 

guidelines.

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

We seek exemption from this section as our UAS has no altimeter 

however contains sophisticated Global Positioning Sensors, Sonar. 
All are displayed on the pilots display and are perfectly accurate thus 

providing and exceeding a level of safety sought.

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

Conditions 

Westside Drone requests an exemption from 14 CFR § 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 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 –

i. During the day, to fly after that for at least 25 minutes; or 

ii. At night, to fly after that for at least 45 minutes. 

This again is not relevant to the operation of the UAS. Our craft has a 

4800 mAh LiPo battery and contains no fuel. Thus explosions 

or fires are not possible making it much safer than traditional 

crafts.

In summary Westside Drone seeks exemptions from Fedeal 

Regulations :

14 C.F.R. 21, subpart H; 14 C.F.R. 45.23(b); 14 C.F.R. §§ 

61.113 (a) & (b); 14 C.F.R. § 91.7 (a); 14 C.F.R. § 91.9 

(b)(2); 14 C.F.R. § 91.103(b); 14 C.F.R. § 91.109; 14 C.F.R. 

§ 91.119; 14 C.F.R. § 91.121; 14 C.F.R. § 91.151(a); 14 

C.F.R. §§ 91.203(a) and (b); 14 C.F.R. § 91.405 (a); 14 

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

§ 91.409 (a ) (2); and, 14 C.F.R. §§ 91.417 (a) & (b)