Page 1 of 21

250 International Parkway, Suite 250, Lake Mary, FL 32746 ǀ P: 407.878.1995 ǀ F: 407.264.8640 ǀ www.stileslawpa.com

February 9, 2016

U. S. Department of Transportation

Docket Management System

West Building Ground Floor – Room W12-140

1200 New Jersey Avenue SE 

Washington, DC 20590

Re: Exemption Request Section 333 of the FAA Reform Act and Part 11 of the 

Federal Aviation Regulations from 14 C.F.R. 45.23(b);14 CFR Part 21;14 

CFR 61.113 (a) & (b); 13 C.F.R. 61.133(a); 91.7 (a);91.9 (b) (2);91.103(b); 

91.109;91.119; 91.121; 91.151(a);91.203(a) & (b);91.405 (a); 91.407(a) (1); 

91.409 (a) (2);91.417 (a) & (b).

Dear Sir(s)/Madam(s):

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

Act”) and 14 C.F.R. Part 11, Greenlando Consulting, L.L.C. (“Greenlando”), seeks an exemption 

from the Federal Aviation Regulations (“FARs”) to operate Small Unmanned Aircraft System(s)

(“UA”) as outlined and discussed below.

Greenlando is committed to meticulously working through the exemption process in order 

to provide the FAA with an application which is not only thorough and comprehensive but 

demonstrates Greenlando’s professional approach to a very unique industry and Greenlando 

appreciates the opportunity to submit an exemption application for consideration. 

Greenlando’s UAs perform precision aerial surveying, inspections, videography, and 

photography in order to provide services for the following, which shall include but not be limited 

to, real estate, agriculture, mining, cellular towers, oil and gas flare stacks, power lines, 

transmission towers, bridges, dams, general infrastructure inspection, other structures, and other 

forms of aerial data and imagery collection (“purposes”). The use of Greenlando’s UAs for the 

purposes reduces the need to operate conventional aircraft typically needed to perform these types 

of operations and provides an economic benefit to the business consumer as the Greenlando UA 

provides higher quality imagery at a fraction of the cost of surveys using conventional aircraft.

These savings result in not only enhanced efficiency and productivity for the affected activities

but added environmental and safety benefits to the public at large.
Page 2 of 21

250 International Parkway, Suite 250, Lake Mary, FL 32746 ǀ P: 407.878.1995 ǀ F: 407.264.8640 ǀ www.stileslawpa.com

Greenlando’s exemption request will permit the operation of comparatively inexpensive 

UAs in a controlled and limited airspace. Greenlando has created (and attached) confidential and 

detailed safety protocols and controls (“Greenlando’s Confidential Protocols and Controls 

Exhibit”)1 to avoid and prevent public hazards as well as preventing interference with manned 

aircraft which could cause a hazard or catastrophe. This acts to enhance safety protocols unique to 

Greenlando’s lightweight UAs. Greenlando records flight information gained through permitted 

flight operations which may be shared with the FAA through any required FAA reports to assist 

with the development of future FAA protocols and safety regulations.

For the purposes outlined above, and as more fully described below, Greenlando’s 

requested exemption would authorize commercial operations, using Greenlando’s UAs, which will 

be operated under controlled conditions at an altitude of no greater than four hundred (400) feet 

above ground level (“AGL”) in airspace that is limited in scope and will have sophisticated control 

features. As outlined below, the airspace in which Greenlando’s UAs will operate within will be 

disclosed to the FAA in advance to flight operation. Finally, Greenlando’s UAs will be used in 

lieu of comparatively hazardous operations now conducted with fixed wing and rotary 

conventional aircraft which should reassure the FAA that these operations will achieve at least an 

equivalent level or greater level of safety. The types of aircraft Greenlando anticipates utilizing in 

order to provide the purposes includes: DJI Phantom 2, DJI Phantom 3 Pro, DJI S-1000+ and DJI 

Inspire 1 Pro.

In the interest of economic efficiency and public safety, Greenlando hereby respectfully 

applies for an exemption from the listed FARs to allow commercial operations of Greenlando’s 

UAs, so long as such operations are conducted within and under the conditions outlined herein or 

as may be established by the FAA. Approval of this exemption would thereby enhance safety and 

fulfill the Secretary of Transportation’s (“Administrator”) responsibilities under Section 333(c) 

of the Reform Act to “establish requirements for the safe operation of such aircraft systems in the 

national airspace system.”

As discussed above and more fully described below, the requested exemption would permit 

the operation of small, unmanned and relatively inexpensive UAs under controlled conditions in 

airspace that is limited and predetermined. Approval of this exemption would thereby enhance 

safety and fulfill the Administrator responsibilities to “...establish requirements for the safe 

operation of such aircraft systems in the national airspace system.” Please see Section 333(c) of 

the Reform Act.

 1 See Exhibit “1” - Greenlando’s Confidential Appendices.
Page 3 of 21

250 International Parkway, Suite 250, Lake Mary, FL 32746 ǀ P: 407.878.1995 ǀ F: 407.264.8640 ǀ www.stileslawpa.com

Additionally, the FAA has already granted previous exemptions which are essentially 

identical to the exemption being sought by Greenlando. 

The name and address of the applicant is: 

Greenlando Consulting, L.L.C.

Attn: Christopher D. Lee

Managing Member

2140 Nairn Drive

Winter Park, FL 32792

Phone: 407-341-0585

Email: chris@greenlandoconsulting.com

REGULATIONS FROM WHICH THE EXEMPTION IS REQUESTED

14 C.F.R. Part 21

14 C.F.R. 45.23(b)

14 C.F.R. 61.113(a) & (b)

13 C.F.R. 61.133(a)

14 C.F.R. 91.7(a)

14 C.F.R. 91.9(b)(2)

14 C.F.R. 91.103

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) & (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. 91.417(a) & (b)

This exemption application is expressly submitted to fulfill Congress’ goal in passing 

Section 333(a) through (c) of the Reform Act. This law directs the Secretary of Transportation to 

consider whether certain unmanned aircraft systems may operate safely in the national airspace 

system (NAS) before completion of the rulemaking required under Section 332 of the Reform Act. 

In making this determination, the Secretary is required to determine which types of UAs do not 
Page 4 of 21

250 International Parkway, Suite 250, Lake Mary, FL 32746 ǀ P: 407.878.1995 ǀ F: 407.264.8640 ǀ www.stileslawpa.com

create a hazard to users of the NAS or the public or pose a threat to national security in light of the 

following:

• The UA’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 visual line of sight (“VLOS”) of the operator.

Reform Act § 333 (a). 

Lastly, if the Secretary determines that such vehicles “may operate safely in the national 

airspace system, the Secretary shall establish requirements for the safe operation of such aircraft 

in the national airspace system.” Id. §333(c) (emphasis added).2

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, that includes UAs, from the requirement that all civil aircraft must have a 

current airworthiness certificate.

The Administrator may grant an exemption from a requirement of a regulation prescribed 

under subsection (a) or (b) of this section or any sections 44702-44716 of this title if the 

Administrator finds the exemption in the public interest. 49 U.S.C. §44701(f). See also 49 USC

§44711(a); 49 USC §44704; 14 CFR §91.203 (a) (1).

Greenlando’s UAs are rotorcraft weighing less than fifty-five (55) pounds (25 Kg)

including energy source(s), equipment and any payload. They operate, under normal conditions 

at a ground speed of no more than eighty-seven (87) knots (100 miles per hour) and have the 

capability to hover, and move in the vertical and horizontal plane simultaneously. They will 

operate only in line of sight and will operate as described in the Greenlando’s Flight Operations 

Procedure Manual (“FOPM”) which is included in the Exhibit “1” and is incorporated herein by 

reference. Such operations will insure that the UA will “not create a hazard to users of the national 

airspace system or the public.”3

 2 Greenlando interprets this provision to place the duty on the Administrator to not only process applications for 

exemptions under section 333, but for the Administrator to craft conditions for the safe operation of the UA, if it 

should be determined that the conditions set forth herein do not fulfill the statutory requirements for approval. 3 Reform Act Section 333 (b).
Page 5 of 21

250 International Parkway, Suite 250, Lake Mary, FL 32746 ǀ P: 407.878.1995 ǀ F: 407.264.8640 ǀ www.stileslawpa.com

Given the small size of the UAs involved, Greenlando falls squarely within that zone of 

safety (an equivalent level of safety) in which Congress envisioned that the FAA must, by 

exemption, allow commercial operations of UAs to commence immediately. Also due to the size 

of the UAs and the restricted areas in which the relevant UAs will operate, approval of the 

application presents no national security issue. Given the clear direction in Section 333 of the 

Reform Act, the authority contained in the Federal Aviation Act, as amended; the strong equivalent 

level of safety surrounding the proposed operations, and the significant public benefit, including 

enhanced safety, reduction in environmental impacts, including reduced emissions associated with 

allowing UAs for aerial photography operations, the grant of the requested exemptions is in the 

public interest. Additionally, there is economic efficiency created with the use of Greenlando’s 

UAs as the typical cost to perform aerial photography with helicopters and airplanes heavily 

multiplies the cost to business consumers and government agencies, including law enforcement, 

for the services which are to be provided by Greenlando. 

THE EXTENT AND BASIS OF THE RELIEF SOUGHT BY GREENLANDO

Greenlando submits this application in accordance with the Reform Act, 112 P.L. 95 §§ 

331-334, seeking relief from any currently applicable FARs operating that presently prevents 

Greenlando from contemplated commercial video-graphic, photographic and other flight 

operations within the national airspace system. The Reform Act in Section 332 provides for such 

integration of civil unmanned aircraft systems into our national airspace system as it is in the 

public’s interest to do so. Greenlando’s ultralight weight UAs meet the definition of “small 

unmanned aircraft” as defined in Section 331 and therefore the integration of Greenlando’s 

ultralight weight UAs is expressly contemplated by the Reform Act. Greenlando would like to 

operate its ultralight weight UAs prior to the time period by which the Reform Act requires the 

FAA to promulgate rules governing such craft. Thereby, providing direct experience and valuable 

information for formal regulation that can be administered uniformly to all related UA aerial 

videography and photography. The Reform Act guides the Administrator in determining the types 

of UAs that may operate safely in our national airspace system. These considerations include:

weight, size, speed and overall capabilities of the UAs; whether the UAs will be operated near 

airports or heavily populated areas and; whether the UAs will be operated by line of sight.4 Each 

of these items is favorable to the grant of an exemption to Greenlando. Greenlando’s UAs utilize 

four (4) counter-rotating propellers for balance, control and stability. Greenlando’s UAs are

equipped with GPS and auto return safety technology. Greenlando’s UAs weigh less than fiftyfive (55) pounds (25 Kg) including camera and gimbal assembly.

 4 112 P.L. 95 § 333 (a).
Page 6 of 21

250 International Parkway, Suite 250, Lake Mary, FL 32746 ǀ P: 407.878.1995 ǀ F: 407.264.8640 ǀ www.stileslawpa.com

Greenlando puts safety first when considering any UA flight. Greenlando’s small UAs are

designed to hover in place via GPS and operate in less than a 24 knot (27 mph) wind. In order to 

increase safety plus stability and limit harm and financial loss of property, Greenlando will not fly 

its UAs in winds exceeding 15 knots (17 mph). Greenlando’s established safety systems include a 

GPS mode that allows its UAs to hover in place when radio controls are released. Greenlando’s 

UAs utilize DJI controls which are safe, reliable and stable in order to prevent accidents and being 

a hazard to others. When pilot communication is lost, Greenlando’s UAs are designed to return 

then slowly descend to the point of takeoff. Greenlando does not operate its UAs near airports, 

hospitals, police heliports or news channel heliports. Greenlando does not operate its UAs in areas 

where general public is within fifty (50) to one hundred (100) yards depending on location, 

conditions and weather. Greenlando’s pilots and observers are constantly on alert for any manned 

aircraft and prepared to immediately abort and land the UA at the nearest and safest ground point 

in the event a manned aircraft approaches or the Greenlando pilot or observer suspects a manned 

aircraft may approach the operating area of a Greenlando UA. Greenlando’s UAs are capable of 

vertical and horizontal operations, and are flown only within my line of sight of the pilot. 

Greenlando’s UAs utilize battery power rather than combustible fuels. Greenlando does not 

operate its UAs below the manufacturer’s recommended minimum charge levels for operation 

preferring to remain well within a safe operating range to insure adequate communication between 

radio control and the UAs to eliminate potential for crashes, loss of control or hazard. Fully charged 

reserve batteries are on hand to insure replacement for a sufficiently safe level of operation. 

Greenlando operates conservatively and does believe in taking risks that may cause a crash or that 

could create hazard to the public, property and manned aircraft. Greenlando’s pilots have logged

numerous practice flights in order to simulate flights for future commercial use to gain 

familiarization with the characteristics of this specific UA’s performance under different weather 

conditions. 

Greenlando is extremely cautious when operating of its UAs and will not “create a hazard 

to users of the national airspace system or the public.”5 Given the small size and weight of 

Greenlando’s UAs, they fall well within Congress’s contemplated safety zone when it promulgated 

the Reform Act and the corresponding directive to integrate UAs into the national airspace system. 

Greenlando’s UAs, utilized in hobby flight, has a demonstrable safety record and do not pose any 

threat to the general public or national security.

 5 112 P.L. 95 § 333 (b).
Page 7 of 21

250 International Parkway, Suite 250, Lake Mary, FL 32746 ǀ P: 407.878.1995 ǀ F: 407.264.8640 ǀ www.stileslawpa.com

GREENLANDO’S REQUEST WILL BENEFIT THE PUBLIC AT LARGE

Aerial imagery, videography and photography has been around for a long time through the 

use of manned fixed wing aircraft and helicopters. The challenge for businesses and consumers is 

that the expense related to manned imagery, videography and photography is cost prohibitive. 

Typically, only large businesses and high net worth landowners are able to absorb such an 

enormous expense. This deprives non-luxury landowners and small revenue companies from 

enjoying the benefit of this valuable tool. Manned aircraft pose a clear threat to the general public 

through potential catastrophic crashes that may occur. There are many documented events where 

a manned aircraft has crashed into populated areas with the size and combustibility of these 

manned aircraft causing large property damage, human injuries and loss of life. Greenlando’s UAs 

pose no such threat since size and lack of combustible fuel alleviates any of these potential threat 

to the public.

With the passage of the Reform Act, Congress has already proclaimed that it is in the 

public’s interest to integrate commercially flown UAs into the national airspace system. The grant 

of the exemption request by Greenlando furthers the public interest by making this cost effective 

alternative available to companies and average landowners. Greenlando’s ultralight UAs are

battery powered and create no emissions that may harm the environment. In the unlikely event of 

a Greenlando UA crash, the consequence is far less than a full size manned helicopter or fixed 

wing aircraft, which are heavy and contain combustible fuel, crashing and causing catastrophic 

devastation to the public.

The public’s interest is furthered as Greenlando minimizes ecological and crash threat by 

permitting aerial imaging, videography and photography captured through Greenlando’s battery 

operated ultralight UA’s. Permitting Greenlando to immediately fly within national air space 

furthers not only public safety but economic growth. In the end, the granting of this exemption to 

Greenlando will serve as a benefit and stimulus to any community.

Accordingly, Greenlando respectfully requests that the FAA grant the requested exemption 

without delay.

AIRCRAFT AND EQUIVALENT LEVEL OF SAFETY

Greenlando proposes that the exemption requested herein apply to civil aircraft that have 

the characteristics and that operate with the limitations listed herein. These limitations provide for 

at least an equivalent or even higher level of safety to operations under the current regulatory 
Page 8 of 21

250 International Parkway, Suite 250, Lake Mary, FL 32746 ǀ P: 407.878.1995 ǀ F: 407.264.8640 ǀ www.stileslawpa.com

structure because the proposed operations represent a safety enhancement to the operations 

conducted with conventional aircraft. 

These limitations and conditions to which Greenlando agrees to be bound when conducting 

all operations under an FAA issued exemption include:

1. The UAs will weigh less than fifty-five (55) pounds (25 Kg).

2. Maximum total flight time for each operational flight will be two (2) hours. Flights 

will be terminated at twenty-five percent (25%) battery power reserve should that 

occur prior to the two (2) hour time limit.

3. Flights will be operated at an altitude of no more than four-hundred (400) feet AGL.

4. Greenlando’s UAs may not be operated at a speed exceeding eighty-seven (87) knots 

(100 miles per hour) and may use either groundspeed or calibrated airspeed to 

determine compliance with the eighty-seven (87) knot (100 miles per hour) speed 

restriction. In no case will the UA be operated at airspeeds greater than the maximum 

UA operating airspeed recommended by the aircraft manufacturer.

5. The UA Pilot will be Pilot in Command (PIC).

6. Minimum crew for each operation will consist of the PIC and a Visual Observer

(“VO”).

7. A PIC must hold either an airline transport, commercial, private, recreational, or sport 

pilot certificate. The PIC must also hold a current FAA airman medical certificate or 

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

a territory, a possession, or the Federal government. The PIC 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 pilot certificate.

8. The UAs will only operate as defined in the FOPM. 

9. A briefing will be conducted with regard to the planned UA operations prior to flight 

operations. It will be mandatory that all personnel who will be performing duties 

with regard to the flight operations be present for this briefing.
Page 9 of 21

250 International Parkway, Suite 250, Lake Mary, FL 32746 ǀ P: 407.878.1995 ǀ F: 407.264.8640 ǀ www.stileslawpa.com

10. Greenlando will obtain the consent of all participating persons involved in the 

purposes outlined above or such similar operations.

11. The PIC, VO, operator trainees or essential persons are not considered 

nonparticipating persons.

12. The PIC and VO will have been trained in operation of UAs generally and received 

up-to-date information on the particular UA to be operated and the UA will be 

operated in conformity with Greenlando’s FOPM.

13. The PIC and VO will at all times be able to communicate via voice communication.

14. Written and/or oral permission from the relevant property holder(s), or their 

authorized representative(s), will be obtained.

15. 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.

16. If the UA loses communications or loses its GPS signal, the UA will return to the 

launch site of the UA, or another more appropriate site, and land.

17. The UA will have the capability to abort a flight in case of unpredicted obstacles or 

emergencies.

14 C.F.R. PART 21, SUBPART H:

AIRWORTHINESS CERTIFICATES 14 C.F.R. §91.203 (A) (1)

Subpart H, entitled Airworthiness Certificates, establishes the procedural requirements for 

the issuance of airworthiness certificates as required by FAR §91.203 (a) (1). Given the size and 

limited operating area associated with the aircraft to be utilized by Greenlando, an exemption from 

Part 21 Subpart H 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 UA. In all cases, an analysis of these criteria 

demonstrates that the UA operated without an airworthiness certificate, in the restricted 
Page 10 of 21

250 International Parkway, Suite 250, Lake Mary, FL 32746 ǀ P: 407.878.1995 ǀ F: 407.264.8640 ǀ www.stileslawpa.com

environment and under the conditions proposed will be at least as safe, or safer, than a conventional 

fixed wing or rotorcraft aircraft operating with an airworthiness certificate without the restrictions 

and conditions proposed.

The UAs to be operated hereunder is less than fifty-five (55) pounds (25 Kg) fully loaded, 

carries neither a pilot nor passenger, carries no explosive materials or flammable liquid fuels, and 

operates exclusively as set out in the FOPM. Unlike other civil aircraft, operations under this 

exemption will be tightly controlled and monitored by the operator, pursuant to the FOPM’s 

requirements, and under the requirements and in compliance with local public safety requirements, 

to provide security for the area of operation as is now done with conventional aerial photography. 

The FAA will have advance notice of all operations. These safety enhancements, which already 

apply to civil aircraft operated in connection with motion picture and television production, 

provide a greater degree of safety to the public and property owners than conventional operations 

conducted with airworthiness certificates issued under 14 C.F.R. Part 21, Subpart H. 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 or flammable liquid fuels, and inability to carry a substantial external load.

14 C.F.R. § 45.23 (B). MARKING OF THE AIRCRAFT

The regulation requires:

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.

Even though the UAs will have no airworthiness certificate, an exemption may be needed 

as the UAs will have no entrance to the cabin, cockpit or pilot station on which the words "limited," 

"restricted," "light-sport," "experimental," or "provisional," may be placed. Given the size of the 

UAs, two-inch lettering will be impossible. Any other term as is so required by the FAA, will be 

placed on the fuselage of the UAs in compliance with §45.29 (f).
Page 11 of 21

250 International Parkway, Suite 250, Lake Mary, FL 32746 ǀ P: 407.878.1995 ǀ F: 407.264.8640 ǀ www.stileslawpa.com

The equivalent level of safety will be provided by having the UAs marked on its fuselage 

as required by §45.29 (f) where the pilot, observer and others working with the UAs will see the 

identification of the UAs. The FAA has issued the following exemptions to this regulation to 

Exemptions Nos. 10700, 8738, 10167 and 10167A.

14 C.F.R. § 61.113 (A) & (B): PRIVATE PILOT

PRIVILEGES AND LIMITATIONS: PILOT IN COMMAND

14 C.F.R. § 61.113(A) & (B); 61.133(A): PRIVATE PILOT PRIVILEGES ANDLIMITATIONS; 

PILOT IN COMMAND; COMMERCIAL PILOT PRIVILEGES AND LIMITATIONS.

Section 61.113(a) & (b) limit private pilots to non-commercial operations. Unlike a

conventional aircraft that carries a pilot, passengers, and cargo, the UA in this case is remotely

controlled with no passengers or property of others on board. Section 61.133(a) requires an

individual with a commercial pilot’s license to be pilot in command of an aircraft for 

compensation or hire. Greenlando respectfully proposes that operator requirements should take

into account the characteristics of the particular UA. 

The FAA has noted the following in the previously granted exemption number 11192:

“Regarding the petitioner’s requested relief from 14 CFR § 61.113 Private 

pilot privileges and limitations, the FAA must consider the appropriate level 

of pilot certification for the petitioner’s proposed operations. The petitioner 

states it would operate its UAS with a pilot holding a sport pilot certificate 

or a recreational pilot certificate and certified by the UA manufacturer and 

has completed the FAA private pilot’s written exam. Under current 

regulations, civil operations for compensation or hire require a PIC holding 

a commercial pilot certificate per 14 CFR part 61. As established in 14 CFR 

§ 61.113(a), with limited exception, a pilot holding a private pilot certificate 

cannot act as a PIC of an aircraft for compensation or hire. However, in 

Grant of Exemption No. 11062 to Astraeus Aerial (Astraeus), the FAA 

determined that a PIC with a private pilot certificate operating the Astraeus 

UAS would not adversely affect operations in the NAS or present a hazard 

to persons or property on the ground. Additionally, as previously 

determined by the Secretary of Transportation, the requirement to have an 

airman certificate ameliorates security concerns over civil UAS operations 

conducted in accordance with Section 333.”
Page 12 of 21

250 International Parkway, Suite 250, Lake Mary, FL 32746 ǀ P: 407.878.1995 ǀ F: 407.264.8640 ǀ www.stileslawpa.com

14 C.F.R. §91.7(A): CIVIL AIRCRAFT AIRWORTHINESS

The regulation requires that no person may operate a civil aircraft unless it is in airworthy 

condition. As there will be no airworthiness certificate issued for the aircraft, should this 

exemption be granted, no FAA regulatory standard will exist for determining airworthiness. Given 

the size of the aircraft and the requirements contained in the FOPM for maintenance and use of 

safety check lists prior to each flight.

14 C.F.R. § 91.9 (B) (2): CIVIL AIRCRAFT FLIGHT MANUAL IN THE AIRCRAFT

Section 91.9 (b) (2) provides:

No person may operate a U.S. registered civil aircraft ...

(2) For which an Airplane or Rotorcraft Flight Manual is not 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.

The UAs, given their size and configuration has no ability or place to carry such a flight 

manual on the aircraft, not only because there is no pilot on board, but because there is no room or 

capacity to carry such an item on the aircraft.

The equivalent level of safety will be maintained by keeping the FOPM at the ground 

control point where the pilot flying the UAs will have immediate access to it. The FAA has issued 

the following exemptions to this regulation: Exemption Nos. 8607, 8737, 8738, 9299, 9299A, 

9565, 9565B, 10167, 10167A, 10602, 32827, and 10700.

14 C.F.R. § 91.103: PREFLIGHT ACTION

This regulation requires each pilot in command to take certain actions before flight to 

insure the safety of flight. As FAA approved rotorcraft flight manuals will not be provided for the 

aircraft an exemption will be needed. An equivalent level of safety will be provided as set forth 

in the FOPM. The PIC will take all actions including reviewing weather, flight battery 

requirements, landing and takeoff distances and aircraft performance data before initiation of 

flight.
Page 13 of 21

250 International Parkway, Suite 250, Lake Mary, FL 32746 ǀ P: 407.878.1995 ǀ F: 407.264.8640 ǀ www.stileslawpa.com

14 C.F.R. §91.109: FLIGHT INSTRUCTION

Section 91.109 provides that no 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.

UAs and remotely piloted aircraft, 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. The FAA has approved exemptions for flight training 

without fully functional dual controls for a number of aircraft and for flight instruction in 

experimental aircraft. See Exemption Nos. 5778K and 9862A. The equivalent level of safety is 

provided as neither a pilot nor passengers will be carried in the aircraft and by the size and speed 

of the aircraft.

14 C.F.R. §91.119: MINIMUM SAFE ALTITUDES

Section 91.119 establishes safe altitudes for operation of civil aircraft. Section 91.119(d) 

allows helicopters to be operated at less than the minimums prescribed, provided the person 

operating the helicopter complies with any route or altitudes prescribed for helicopters by the FAA. 

As this exemption is for UAs that are a helicopter and the exemption requests authority to operate 

at altitudes up to four-hundred (400) feet AGL, or not more than two-hundred (200) above an 

elevated platform from which aerial photography is planned, an exemption may be needed to allow 

such operations. As set forth herein, except for the limited conditions stated in the FOPM, the 

UAS will never operate at higher than four-hundred (400) feet AGL. It will however be operated 

in a restricted area with security perimeter, where buildings and people will not be exposed to 

operations without their pre-obtained consent.

The equivalent level of safety will be achieved given the size, weight, speed of the UAs as 

well as the location where it is operated. No flight will be taken without the permission of the 

property owner or local officials. Because of the advance notice to the property owner(s), or their 

authorized representative(s), all affected individuals will be aware of the planned flight operations 

as set forth in the FOPM. Compared to flight operations with aircraft or rotorcraft weighing far in 

excess of the less then fifty-five (55) pounds (25 Kg) limit proposed herein and the lack of 

flammable fuel, any risk associated with these operations is far less than those presently presented 

with conventional aircraft operating at or below five-hundred (500) feet AGL. In addition, the 

low-altitude operations of the UAs will ensure separation between these small UAs operations and 

the operations of conventional aircraft that must comply with Section 91.119.
Page 14 of 21

250 International Parkway, Suite 250, Lake Mary, FL 32746 ǀ P: 407.878.1995 ǀ F: 407.264.8640 ǀ www.stileslawpa.com

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 UA 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 FOPM and Safety Check list, confirming the altitude 

of the launch site shown on the GPS altitude indicator before flight.

14 C.F.R. § 91.151(A): FUEL REQUIREMENTS FOR FLIGHT IN VFR CONDITIONS

Section 91.151 (a) prohibits an individual from beginning “a flight in an airplane under 

VFR conditions unless (considering wind and forecast weather conditions) there is enough fuel to 

fly to the first point of intended landing, and, assuming normal cruising speed – (1) During the 

day, to fly after that for at least 30 minutes; or (2) At night, to fly after that for at least 45 minutes.”

Greenlando believes that an exemption from 14 CFR §91.151(a) falls within the scope of 

prior exemptions. See Exemption 10673 (allowing Lockheed Martin Corporation to operate 

without compliance with FAR 91.151 (a)). Operating the small UAS, in a tightly controlled area 

where only people and property owners or official representatives who have signed waivers will 

be allowed, with less than thirty (30) minutes of reserve fuel, does not engender the type of risks 

that Section 91.151(a) was intended to alleviate given the size and speed of the small UAs. 

Additionally, limiting UA flights to ten (10) minutes would greatly reduce the utility and economic 

efficiency for which the exemption will be granted.

Greenlando believes that an equivalent level of safety can be achieved by limiting flights 

to two (2) hours or twenty-five percent (25%) of battery power whichever happens first. This 

restriction would be more than adequate to return the UAs to their planned landing zone from 

anywhere in its limited operating area.

Similar exemptions to this regulation have been granted to other operations, including 

Exemptions 2689F, 5745, 10673, and 10808.
Page 15 of 21

250 International Parkway, Suite 250, Lake Mary, FL 32746 ǀ P: 407.878.1995 ǀ F: 407.264.8640 ǀ www.stileslawpa.com

14 C.F.R. §91.203 (A) AND (B): CARRYING CIVIL

AIRCRAFT CERTIFICATION AND REGISTRATION

The regulation provides in pertinent part:

(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.

The UAs fully loaded weight is no greater than fifty-five (55) pounds (25 Kg) and is 

operated without an onboard pilot. As such, there is no ability or place to carry certification and 

registration documents or to display them on the UA.

An equivalent level of safety will be achieved by keeping these documents at the ground 

control point where the pilot flying the UA will have immediate access to them to the extent they 

are applicable to the UA. The FAA has issued numerous exemptions to this regulation. A 

representative sample of other exceptions includes Exemption Nos. 9565, 9665, 9789, 9789A, 

9797, 9797A, 9816A, and 10700.

14 C.F.R. §91.405 (A); 407 (A) (1); 409 (A) (2); 417(A) & (B):

MAINTENANCE INSPECTIONS

These regulations require that an aircraft operator or owner “shall have that aircraft 

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

provided in paragraph (c) of this section, have discrepancies repaired as prescribed in part 43 of 

this chapter...,” and others shall inspect or maintain the aircraft in compliance with Part 43.

Given that these section and Part 43 apply only to aircraft with an airworthiness certificate, 

these sections will not apply to Greenlando. Maintenance will be accomplished by the operator 

pursuant to the flight manual and operating handbook as referenced in the FOPM. An equivalent 

level of safety will be achieved because these small UAs are very limited in size and will carry a 
Page 16 of 21

250 International Parkway, Suite 250, Lake Mary, FL 32746 ǀ P: 407.878.1995 ǀ F: 407.264.8640 ǀ www.stileslawpa.com

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

arise the UAs may land immediately and will be operating from no higher than four-hundred (400)

feet AGL. As provided in the FOPM, the operator will ensure that the UAs are in working order 

prior to initiating flight, perform required maintenance, and keep a log of any maintenance 

performed. Moreover, the operator is the person most familiar with the aircraft and best suited to 

maintain the aircraft in an airworthy condition to provide the equivalent level of safety.

*********

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:

Greenlando seeks an exemption from the following rules:

14 C.F.R. §21, subpart H; 14 C.F.R 45.23(b);14 C.F.R. §§ 61.113( a) & (b);91.7 (a); 91.9 

(b) (2);91.103(b);91.109; 91.119; 91.121; 91.151(a);91.203(a) and (b); 91.405 (a); 91.407 

(a) (1); 91.409 (a) (2); 91.409 (a) (2) and 91.417 (a) & (b) to operate commercially a small 

unmanned vehicle weighing less than fifty-five (55) pounds (25 Kg) in its operations.

Approval of exemptions allowing commercial operations of UAs for the operational 

purposes outlined above, or similar operations, will enhance safety by reducing risk. Typically, 

these types of operations are performed using jet or piston power aircraft. These aircraft operate 

at extremely low altitudes just feet from the object being photographed and often in extreme

proximity to people and structures. They also present heightened risks associated with vehicles 

that weigh in the neighborhood of four thousand (4,000) pounds, carrying large amounts of jet A 

or other fuel (one hundred and forty (140) gallons for jet helicopters). Not only is there danger 

created using these types of aircraft during operations, such aircraft must fly to and from the site’s

location. In contrast, a UA weighing less than fifty-five (55) pounds (25 Kg) and powered by 

batteries eliminates virtually all of that risk given the reduced mass and lack of combustible fuel 

carried on board. The UA is carried to the site of the purposes outlined above (or similar 

operations) and not flown to the site. The UA will carry no passengers or crew and, therefore, will 

not expose them to the risks associated with manned aircraft flights.

The operation of small UAs, weighing less than fifty-five (55) pounds (25 Kg), conducted 

in the strict conditions outlined above, will provide an equivalent level of safety supporting the 

grant of the exemptions requested herein, including exempting Greenlando from the requirements 

of Part 21 and allowing commercial operations. These lightweight aircraft operate at slow speeds
Page 17 of 21

250 International Parkway, Suite 250, Lake Mary, FL 32746 ǀ P: 407.878.1995 ǀ F: 407.264.8640 ǀ www.stileslawpa.com

and close to the ground and, as a result, are far safer than conventional operations conducted with 

turbine helicopters operating in close proximity to the ground and people.

PRIVACY

All flights will occur over controlled or approved property with the property owner’s, or 

their authorized representative, prior consent and knowledge. The aerial imaging will be of 

structures and objects whose owner, or authorized representative, has consented to the aerial 

photography. The grant of this exemption request will provide improved safety in operations.

Satisfaction of the criteria provided in Section 333 of the Reform Act of 2012 -size, weight, 

speed, operating capabilities, proximity to airports and populated areas and operation within visual 

line of sight and national security – provide more than adequate justification for the granting of 

the requested exemptions allowing commercial operation of Greenlando’s UAs pursuant to the 

FOPM attached hereto.

SUMMARY OF GREENLANDO’S REQUEST FOR AN FAA EXEMPTION

1. Operations authorized by this a grant of exemption will be limited to the requested 

aircraft when weighing less than fifty-five (55) (25 Kg) pounds including payload. 

2. Operations for the purpose of closed-set motion picture and television filming are

not permitted.

3. The UA may not be operated at a speed exceeding eighty-seven (87) knots (100 

miles per hour). The exemption holder may use either groundspeed or calibrated 

airspeed to determine compliance with the eighty-seven (87) knot speed restriction. 

In no case will the UA be operated at airspeeds greater than the maximum UA 

operating airspeed recommended by the aircraft manufacturer.

4. The UA must be operated at an altitude of no more than four-hundred (400) feet 

above ground level (AGL) and the altitude must be reported in feet AGL.

5. 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 airman medical 

certificate or U.S. driver’s license.

6. All operations must utilize a visual observer (VO). The UA must be operated within

the visual line of sight (VLOS) of the PIC and VO at all times. The VO may be
Page 18 of 21

250 International Parkway, Suite 250, Lake Mary, FL 32746 ǀ P: 407.878.1995 ǀ F: 407.264.8640 ǀ www.stileslawpa.com

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;

electronic messaging or texting is not permitted during flight operations. The PIC

must be designated before the flight and cannot transfer his or her designation for

the duration of the flight. The PIC must ensure that the VO can perform the duties

required of the VO.

7. This exemption and all documents needed to operate the UAs and conduct its

operations in accordance with the conditions and limitations stated in this grant of 

exemption, are hereinafter referred to as the operating documents. The operating

documents must be accessible during UAS operations 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 operating

documents, conditions and limitations herein take precedence and must be

followed. Otherwise, the operator must follow the procedures as outlined in its

operating documents. The operator may update or revise its operating documents. 

It is the operator’s responsibility to track such revisions and present updated and

revised documents to the Administrator or any law enforcement official upon 

request. The operator must also present updated and revised documents if it 

petitions for extension or amendment to this grant of exemption. If the operator 

determines that any update or revision would affect the basis upon which the FAA 

granted this exemption, then the operator must petition for an amendment to its 

grant of exemption. The FAA’s UAS Integration Office (AFS−80) may be 

contacted if questions arise regarding updates or revisions to the operating

documents.

8. Any UA 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 prior to conducting further operations under 

this exemption. Functional test flights may only be conducted by a PIC with a VO 

and must remain at least five-hundred (500) feet from other people. The functional 

test flight must be conducted in such a manner so as to not pose an undue hazard to 

persons and property.

9. The operator is responsible for maintaining and inspecting the UA to ensure that it

is in a condition for safe operation.

10. Prior to each flight, the PIC must conduct a pre-flight inspection and determine the

UA is in a condition for safe flight. The pre-flight inspection must account for all

potential discrepancies, e.g. inoperable components, items, or equipment. If the

inspection reveals a condition that affects the safe operation of the UA, the aircraft

is prohibited from operating until the necessary maintenance has been performed 

and the UA is found to be in a condition for safe flight.
Page 19 of 21

250 International Parkway, Suite 250, Lake Mary, FL 32746 ǀ P: 407.878.1995 ǀ F: 407.264.8640 ǀ www.stileslawpa.com

11. The operator must follow the UA manufacturer’s maintenance, overhaul,

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

components.

12. Each UA operated under this exemption must comply with all manufacturer safety

bulletins.

13. Under this grant of exemption, a PIC must hold either an airline transport, 

commercial, private, recreational, or sport pilot certificate. The PIC must also hold

a current FAA airman medical certificate or a valid U.S. driver’s license issued by

a state, the District of Colombia, Puerto Rico, a territory, a possession, or the

Federal government. The PIC 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 

pilot certificate.

14. The operator may not permit any PIC to operate unless the PIC demonstrates the

ability to safely operate the UAS in a manner consistent with how the UAS will be

operated under this exemption, including evasive and emergency maneuvers and

maintaining appropriate distances from persons, vessels, vehicles and structures.

PIC qualification flight hours and currency must be logged in a manner consistent

with 14 CFR § 61.51(b). Flights for the purposes of training the operator’s PICs 

andVOs(training, proficiency, and experience-building) and determining the PIC’s 

ability to safely operate the UAS in a manner consistent with how the UAS will be

operated under this exemption are permitted under the terms of this exemption.

However, training operations may only be conducted during dedicated training 

sessions. 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.

15. UA 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.

16. The UA may not operate within five (5) nautical miles of an airport reference point 

(“ARP”) as denoted in the current FAA Airport/Facility Directory (“AFD”) or for 

airports not denoted with an ARP, the center of the airport symbol as denoted on 

the current FAA-published aeronautical chart, unless a letter of agreement with that

airport’s management is obtained or otherwise permitted by a Certificate of Waiver 

and Authorization (“COA”) issued to the exemption holder. The letter of agreement 

with the airport management must be made available to the Administrator or any 

law enforcement official upon request.
Page 20 of 21

250 International Parkway, Suite 250, Lake Mary, FL 32746 ǀ P: 407.878.1995 ǀ F: 407.264.8640 ǀ www.stileslawpa.com

17. The UA may not be operated less than five-hundred (500) feet below or less than 

two-thousand (2,000) feet horizontally from a cloud or when visibility is less than 

three (3) statute miles from the PIC.

18. If the UA loses communications or loses its GPS signal, the UA must return to a

pre-determined location within the private or controlled-access property.

19. The PIC must abort the flight in the event of unpredicted obstacles or emergencies.

20. The PIC is prohibited from beginning a flight unless (considering wind and forecast

weather conditions) there is enough available power for the UA to conduct the

intended operation and to operate after that for at least five minutes or with the

reserve power recommended by the manufacturer if greater.

21. 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.

22. Documents used by the operator to ensure the safe operation and flight of the UAS

and any 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.

23. The UA must remain clear and give way to all manned aviation operations and

activities at all times.

24. The UA may not be operated by the PIC from any moving device or vehicle.

25. All Flight operations must be conducted at least five-hundred (500) feet from all

nonparticipating persons, vessels, vehicles, and structures unless:

a. Barriers/signs will be set up to sufficiently protect nonparticipating persons 

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

ensure that nonparticipating persons remain under such protection. If a 

situation arises where nonparticipating persons leave such protection and 

are within five-hundred (500) feet of the UA, flight operations must cease 

immediately in a manner ensuring the safety of nonparticipating persons; 

and,

b. The owner/controller of any vessels, vehicles or structures has granted

permission for operating closer to those objects and the PIC has made a 
Page 21 of 21

250 International Parkway, Suite 250, Lake Mary, FL 32746 ǀ P: 407.878.1995 ǀ F: 407.264.8640 ǀ www.stileslawpa.com

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

determined that it does not present an undue hazard.

The PIC, VO, operator trainees or essential persons are not considered

nonparticipating persons under this exemption.

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

permission from the property owner/controller or authorized representative.

Permission from property owner/controller or authorized representative will be

obtained for each flight to be conducted.

27. 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 twenty-four (24)

hours. Accidents must be reported to the National Transportation Safety Board 

(“NTSB”) per instructions contained on the NTSB Web site: www.ntsb.gov.

Unless otherwise specified in a grant of exemption, the UA, the UA’s PIC, and theUA’s

operations must comply with all applicable parts of 14 CFR including, but not limited to, parts 45, 

47, 61, and 91.

Greenlando Consulting, LLC respectfully requests the FAA grant an exemption pursuant 

to this application. 

Sincerely,

Philip A. K. Stiles, Esq.

Stiles Law, P.A.

Counsel for Greenlando Consulting, LLC