EAGLEYE DRONE LLC, 

2828 Cochran Street, Suite 506, Simi Valley, CA 93065, Phone (805) 404-5558, email: info@eagleyedrone.com

August 7, 2015

U.S. Department of Transportation

Docket Operations

West Building Ground Floor

Room W12-140

1200 New Jersey Avenue, SE.,

Washington, DC 20590-0001

RE: Exemption Request Section 333 of the FAA Reform Act of2012 and Part 11 of the Federal

Aviation Regulations

Dear Sir or Madam;

In accordance with the Public Guidance for Petitions for Exemption filed under Section 333,

Eagleye Drone LLC requests exemption from the Federal Aviation Regulations to allow for 

commercial UAS operations of a DJI Phantom 2 Vision+, DJI Phantom 3 Professional, DJI Inspire 

1, 3DRobotics IrisM-Pro and X8-M for the purpose of aerial photography, tower inspection, real 

estate marketing, surveying, agricultural mapping and other flight operations that could be performed 

safely and more cost effectively than a traditional manned aircraft.

One element of the exemption application involves evidence of the airworthiness of the sUAS.

Eagleye Drone LLC believes that the sUAS owned and planned to be operated by Eagleye Drone 

LLC have been shown to be airworthy and compliant with a significant level of safety. The many 

previous 333 Grants of Exemptions by the FAA further highlight that operations of the sUAS 

will not adversely affect safety when compared to similar operations conducted by aircraft that 

have been issued an airworthiness certificate under 14 C.F.R. Part 21, Subpart H. (e.g. FAA 

Exemption Nos. 11357 for the airworthiness of Phantom 2 Vision+, 11325 for the airworthiness 

of DJI Phantom2 Vision+ and Inspire 1, 11204 for the airworthiness of 3DRobotics Iris+ and 

Inspire 1, and 11433 for 3DRobotics X8+).

To enhance safety, it is also important to note that the sUAS are equipped with automated 

features which enhance safe takeoff, flight, and landing in many conditions, further details of 

which are provided in the applicable DJI’s and 3DRobotics’ User Manuals.

To maintain airworthiness, Eagleye Drone LLC will follow the inspection and maintenance 

programs designed specifically for the sUAS by their manufacturers, DJI and 3DRobotics. Those 

programs are enhanced by an inflight monitoring system for the sUAS that monitor current 

position, wind speed and direction, battery charge, flight time, and altitude, including both above 

the takeoff location and above sea level. If onboard sensors detect a critical situation at any time 

(low battery, close proximity to the ground, weak data link signal, etc.) the sUAS will 

automatically initiate a preprogrammed safety procedure. In the event of any malfunction, the 

sUAS will undergo all maintenance required by the manufacturer and undergo flight testing 

before recommencing commercial operations.

Applicant:

Eagleye Drone LLC
Ruben Nalbandian (President)

2828 Cochran St., Suite 506

Simi Valley, CA 93065

Email: ruben@eagleyedrone.com

Phone: (805) 404-5558

Mobile: (818) 930-1354

Attachments:

Please note since the files sizes are larger than the expected size limitation the URL addresses of 

the attachments are provided instead:

1. DJI Phantom 3 Professional User Manual

http://download.dji-innovations.com/downloads/phantom_3/en/Phantom_3_Professional_User_Manual_v1.0_en.pdf

2. DJI Inspire1 User Manual 

http://download.dji-innovations.com/downloads/inspire_1/en/Inspire_1_User_Manual_v1.4_en.pdf

3. DJI Phantom Pilot Training Guide

http://download.dji-innovations.com/downloads/phantom-2-vision/en/Phantom_2_Vision_Pilot_Training_Guide_en.pdf

4. 3DRobotics IrisM-Pro User Manual 

http://3drobotics.com/wp-content/uploads/2015/04/DCT0085-IRISMProOperationManualvC.pdf

5. 3DRobotics X8-M User 

http://3drobotics.com/wp-content/uploads/2014/10/X8M-Operation-Manual-v1.pdf

Regulations from which the exemption is requested:

14 CFR 21, Subpart H

14 CFR 45.23 (b)

14 CFR 61.113 (a) & (b) & 14 CFR 61.133 (a)

14 CFR 91.7 (a)

14 CFR 91.9 (b)(2)

14 CFR 91.103 (b)(2)

14 CFR 91.109

14 CFR 91.119 (c)

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)(l)

14 CFR 91.409 (a)(l) & (a)(2)

14 CFR 91.417 (a) & (b)

14 CFR 21, Subpart H- In consideration of the size, weight, speed, and limited operating area 

associated with this UAS and its operation, Eagleye Drone LLC requests relief from 14 CFR part 21,

Subpart H, and any associated noise certification and testing requirements of part 36. The UAS will 

not carry a pilot, passenger, explosive materials or flammable liquids.

14 CFR 45.23 (b)- 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 word

"Experimental" can be placed. Given the size of the UAS, two-inch lettering will be impossible. The 

word "Experimental" will be placed on the fuselage in compliance with §45.29 (f). 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 as

"Experimental."
14 CFR 61.113 (a) & (b) & 14 CFR 61.133 (a)- Since the UAS will not carry a pilot or passengers

Eagleye Drone LLC requests a relief from these regulations. Any pilot in command (PIC) operating

the UAS will have at least completed a minimum of 30 hours UAS training certificate program. A 

visual observer or (VO) will be utilized and required to communicate verbally at all times. The UAS 

will be limited to operations within visual distance of both the PIC and VO. All UAS operations will 

take place in a controlled area. The risks associated with the use of a UAS are far less than similar 

commercial aircraft operations.

14 CFR 91.7 (a) Since the UAS will not carry a pilot or passengers there will be no airworthiness 

certificate issued for the aircraft, should this exemption be granted, no FAA regulatory standard 

exists for determining airworthiness. Given the size of the aircraft, maintenance, and use of safety 

checklist prior to each flight, an equivalent level of safety will be provided. All flights will be in 

accordance with the safety and maintenance recommendations found in the DJI Phantom and 

3DRobotics attachments.

14 CFR 91.9 (b)(2)- Given the size and configuration, the UAS has no ability to carry a flight 

manual on the aircraft. There is no room, capacity, or pilot on board to adequately carry a flight 

manual. An equivalent level of safety will be maintained by keeping the flight manual at the ground 

station where the UAS pilot will have immediate access to it.

14 CFR 91.103 (b)(2) -As no FAA approved flight manuals will be provided for the aircraft an 

exemption is needed. Alternate procedures including but not limited to reviewing weather conditions, 

checking flight battery requirements, checking takeoff and landing distances along with those found 

in the attached Training Manuals will be implemented. These actions will provide an equivalent or 

higher level of safety.

14 CFR 91.109- UAS and remotely piloted aircraft do not have fully functional dual controls. Flight 

control is achieved through the use of a control box that communicates with the aircraft via radio 

communications. An equivalent level of safety will be achieved using the real time ground station 

data and given the UAS will carry neither a pilot nor passengers.

14 CFR 91.119 (c)- The UAS will never be operated at an altitude higher than 400 feet AGL. The

UAS will operate in safe areas away from public and traffic and only with permission of the property

and structure owners. The UAS will also be restricted by the flight controller to a maximum vertical 

height of 400 feet AGL, and 1500 feet horizontal. Given the size, weight, maneuverability and speed 

of the UAS, an equivalent or higher level of safety will be achieved.

14 CFR 91.121- As the UAS may not have a barometric altimeter, but instead a GPS barometric 

sensor for altitude information an exemption may be required. An equivalent level of safety will be 

achieved using a ground station which links to a telemetry data link. This will provide the pilot with 

live flight data monitoring, confirming the altitude of the launch site shown on the GPS altitude 

indicator prior to flight.

14 CFR 91.151 (a)- The UAS has a limited range and will be limited to operations in a controlled 

environment. The battery power the UAS provides approximately 15 to 20 minutes of flight time. 

The UAS is unable to meet the 30 minute reserve requirement and therefore requires an exemption. 
An equivalent level of safety will be achieved by monitoring the battery through the ground station 

and landing with a minimum of 30 percent battery power remaining.

14 CFR 91.203 (a) & (b)- Given the size and configuration, the UAS has no ability to carry a flight

manual on the aircraft. There is no room, capacity, or pilot on board to adequately carry a flight

manual. An equivalent level of safety will be maintained by keeping the flight manual at the ground

station where the UAS pilot will have immediate access to it.

Given the following sections only apply to aircraft with an airworthiness certificate; these sections do

not apply to this applicant. As a safety precaution, the operator will perform preflight inspections and

ensure UAS is in working condition before initiating each flight:

14 CFR 91.405 (a)

14 CFR 91.407 (a)(1)

14 CFR 91.409 (a)(l) & (a)(2)

14 CFR 91.417 (a) & (b) Equivalent Level of Safety

In addition to the safety standards mentioned above the UAS will adhere to the following additional

guidelines:

1. The UAS will not be operated within 5 miles of an airport.

2. Flights will not exceed the an airspeed of 36 mph (31.3 knots)

3. Flights will be operated at or below an altitude never exceeding 400 feet AGL. Normal operations 

will be conducted at 200 feet AGL.

4. The PIC and VO will communicate verbally at all times.

5. UAS operations will not be conducted during night.

6. All operations will be conducted under visual meteorological conditions.

7. The UAS will land with a minimum 30 percent battery reserve remaining.

8. The UAS will only be piloted within visual line of sight.

9. The UAS will utilize an internal flight safety feature that will return to a preprogrammed position 

and land if communication with the remote control is lost.

10. Preflight inspections and protocol will be followed prior to all operations.

11. The UAS will abort flight in the event of unpredictable obstacles or emergencies.

Public Interest

Eagleye Drone LLC seeks an exemption to be able to provide the following services to the public and 

private clients: 

 Construction site observation and monitoring. 

 Aerial surveying and photogrammetry. 

 Photography and videography. 

 Inspection of structures.

 Precision agriculture

The requested exemptions would permit Eagleye Drone LLC to operate small, unmanned UASs 

under conditions that are limited, controlled, economical and would provide safety enhancements 

over conventional aircraft. 
Approval of this exemption would thereby enhance safety to the public and fulfill the FAA’s 

responsibilities to establish requirements for the safe operation of such aircraft systems in the 

national airspace system. We believe the use of a UAS in lieu of a manned aircraft would enhance 

safety and reduce the environmental impact compared to similar operations conducted with a manned 

aircraft carrying a crew and flammable fuel.

The photographs and video collected will provide valuable information to professionals and 

engineers to enhance their decision making process. The use of a UAS in the real estate industry 

provides both the buyer and seller with a higher level of marketing and service. The UAS is able to 

provide a high resolution view which encompasses the entire field in a single photo or short video 

clip. When compared to similar operations using manned aircraft, utilizing a UAS poses much less of 

a safety concern for the general public with less fuel, time, noise and other resources.

Businesses may benefit through data and image acquisition for real estate, construction, precision 

agriculture, surveying and other applications of UAS technology.

Privacy

All flights will occur over private or controlled areas with the owner's consent. 

Sincerely,

Ruben Nalbandian

President