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Re: Exemption Request Pursuant to Section 333 of the FAA Reform Act 

and Part 11 of the Federal Aviation Regulations from: 14 CFR 21 subpart 

H; 14 CFR 61.113(a) and (b); 14 CFR 91.7(a); 14 CFR 91.103; 14 CFR 

91.109; 14 CFR 91.119 (c); 14 CFR 91.121; 14 CFR 91.151(a); 14 CFR 

91.405 (a); 14 CFR 91.407 (a) (1) 14 CFR 91.409 (a)(1) and (2); 14 

CFR 91.417(a) and (b) 

Dear Sir or Madam: 

Pursuant to Section 333 of the FAA Modernization and Reform Act of 

2012 (the “Reform Act”) and 14 CFR Part 11, AirFrame LLC, operator of 

an Unmanned Aircraft System (UAS), hereby applies for an exemption 

from the listed Federal Aviation Regulations (“FARs”) to allow commercial 

operation of its UAS, so long as such operations are conducted within and 

under the conditions outlined herein or as may be established by the FAA 

as required by Section 333. 

Commercial operation of an UAS, as described herein, which are equipped 

with camera(s) and sensors, would operate in the following manner: 

. Aerial photography and/or video for public and/or private use including 

real estate, architecture, land surveying, engineering, construction

and other related professional activities. 

. Aerial video and/or photography for public and/or private use including 

television, public events, cinematography and news gathering. 

. Aerial inspection/photography of residential/commercial structures 

under contract with the owners or local government authority. 

. Aerial inspection/photography of residential/commercial utility 

infrastructure including but not limited to bridges, electrical power 

lines, wind turbines, railways and cell towers. 

. Aerial video/photography or providing live video feed to assist with 

search and rescue operations in cases of an emergency or natural 

disaster only when the local authorities or government has 

requested it by contract or donation. 

. The ability to offer training to persons individually or belonging to both 
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private, public and/or government organizations that have interests 

in the use and application of a UAS for the purpose of the safe 

operation of a UAS to enhance the safety of the National Airspace 

System (NAS) as well as for the protection of the persons and 

property. 

As described fully below, the requested exemption would permit the 

operation of a UAS under controlled conditions in the NAS that would be, 

limited, controlled, predetermined and will provide safety enhancements 

to the already safe operations in these industries presently using 

conventional aircraft. Approval of this exemption would thereby enhance 

safety and fulfill the Secretary of Transportation’s (the FAA 

Administrator’s) responsibilities to “....establish requirements for the safe 

operation of such aircraft systems in the national airspace system.” 

Section 333 (c) of the Reform Act.

The name and address of the applicant is: 

AirFrame LLC

Attn: Nathan W. Richards, Chief Pilot

Airline Transport Pilot Certificate: 3264269

FCC Restricted Radiotelephone Operator Permit: (FRN) 0015677990

FCC Ham Amateur Radio License Call Sign: WH6EKE

Phone: (808) 597-7959

Email: nathan@airframehi.com

Address: 5776 Haleola Street, Honolulu HI 96821
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Regulations from which the exemption is requested: 

14 CFR Part 21 subpart H 

14 CFR 61.113 (a) & (b) 

14 CFR 91.7 (a) 

14 CFR 91.103

14 CFR 91.109

14 CFR 91.119 (c)

14 CFR 91.121 

14 CFR 91.151 (a)

14 CFR 91.405 (a)

14 CFR 91.407 (a) (1) 

14 CFR 91.409 (a) (1) & (2) 

14 CFR 91.417 (a) & (b) 

AirFrame LLC will operate the DJI S800 and the Tarot 680PRO, with a 

total AUW (all up weight) not to exceed 55lbs. The dimensions of the DJI 

S800 are 940mm x 940mm x 350mm or 37.6in x 37.6in x 14in. The

Tarot 680PRO is 695mm x 695mm x 300mm or 27.4in x 27.4in x 11.8in.

Under still air the maximum ground speed of either aircraft will not exceed

29 knots. The DJI S800 and Tarot 680PRO are VTOL (vertical take off 

and landing) aircraft and have the ability to hover and move along a 

vertical and horizontal plane simultaneously. The DJI S800 has six motors, 

Motor Model 4114, powered by a 6-cell 10,900 to 20,000mAh Lithium 

Polymer battery depending on mission type or payload requirements.

There are six composite propellers, Propeller Model DJI 1552, in use. The 

Tarot 680PRO also has six motors, MT3506KV650, powered by a 4-cell 
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5,200 to 10,400mAh Lithium Polymer battery. There are six plastic 

propellers on the Tarot 680PRO, model APC 12x4.7SF. Both aircraft will 

be controlled with the FrSky Taranis X9D remote controller connected to 

a Dragon Link V 2.0 UHF transmitter module with an operating frequency 

of 433Mhz. The Dragon Link V2 (DV2 – see attached manual for 

additional details and information) offers a higher level of safety by 

exceeding transition capabilities of traditional 2.4Mhz or 5.6Mhz radio 

systems by several kilometers, thus ensuring extremely low lost link 

possibility while maintaining line of site (LOS) operations. In addition to

affording superior signal at all times, DV2 also incorporates added failsafe 

capabilities and a downed craft locator beacon capabilities that are not

available from any other radio manufacturer. The live video feeds will have 

an operating frequency of 5.6Mhz and 1280Mhz, that will not exceed 1 

megawatt per FCC regulations. Telemetry data downlink will be 

transmitted in the 900Mhz band of frequency via RFD900+ Radio 

Modems. The RDF900+ offers redundant dual transmission diversity

switched antenna with a full 1 watt transmission power ensuring zero loss 

of link during LOS operations. (RF900+ - see attached manual for 

additional details). The applicant will operate the UAS in line of sight 

within a closed off and predetermined area owned and/operated by the 

property representative as stated in the FOM. 

Given the small size of the UAS and the controlled environment provided,

the proposed operations will adhere to the Reform Act’s safety 

requirements. The approval of this application presents no national 

security issues. Regarding the level of safety surrounding the proposed 

operations and the public benefit, reduction in environmental impacts, 

including but not limited to reduced emissions and noise. As the FAA 

recognized in the Douglas Trudeau, Exemption, No. 11138: “Manned 

aircraft conducting aerial filming and photography can weigh 5,000 lbs. or 

more, are operated by an onboard pilot and may carry other onboard crew 

members, as well as 100 gallons or more of fuel. The petitioner’s [sUAS] 

weighs less than 3 lbs. The pilot and crew will be remotely located from 

the aircraft. The limited weight reduces the potential for harm to persons 

or damage to property in the event of an incident or accident. The risk of 

an onboard pilot and crew during an incident or accident is eliminated with 

the use of a [sUAS] for the proposed operation.”
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AIRCRAFT AND EQUIVALENT LEVEL OF SAFETY 

The operation limitations proposed for an equivalent or higher level of 

safety because operations will further enhance the safety of the persons 

and/or property using conventional aircraft. 

These limitations and conditions to which the applicant agrees to adhere 

to when conducting commercial operations under the FAA issued 

exemption as set forth in the Flight Operations Manual (FOM) include: 

1. The UAS will weigh less than 55 lbs. 

2. The UAS will have a maximum operating speed of no more than 

15m/s or 29 knots. 

3. The UAS will be operated at an altitude of no more than 400

feet above ground level (AGL). All altitudes reported to ATC will 

be in feet AGL. 

4. The UAS will be operated within visual line of sight (VLOS) of the 

pilot in command (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. 

5. All operations will utilize a visual observer (VO). The UAS will be 

operated within the visual line of sight (VLOS) of the PIC and VO 

at all times. The VO may be used to satisfy the VLOS 

requirement as long as the PIC always maintains VLOS capability. 

The VO and PIC will be able to communicate verbally at all times. 

Electronic messaging or texting will not be permitted during 

flight operations. The PIC will be designated before the flight and 

cannot transfer his or her designation for the duration of the 

flight. The PIC will ensure that the VO can perform the functions 

prescribed in the FOM. 

6. The VO will not perform any other duties beyond assisting the 

PIC with seeing and avoiding other air traffic and other ground 

based obstacles/obstructions, and is will not be permitted to 

operate the camera or other instruments. 

7. The FOM and this grant of exemption will be accessible during 
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UAS operations and made available to the Administrator upon 

request. 

8. Prior to each flight, the PIC will inspect the UAS to ensure it is in 

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

that affects the safe operation of the UAS, the UAS will be 

prohibited from operating until the necessary maintenance has 

been performed and the UAS is found to be in a condition for 

safe flight. The Ground Control Station will be included in the 

preflight inspection. All maintenance and alterations will be 

properly documented in the aircraft records 

9. If the UAS has undergone maintenance or alterations that affect 

the UAS operation or flight characteristics (e.g. replacement of a 

flight critical component) it will undergo a functional test flight. 

The PIC who conducts the functional test flight will make an 

entry in the aircraft records.

10. The PIC will possess at least a private pilot airman certificate and 

at least a current third class medical certificate. The PIC will 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. 

11. AirFrame LLC will not permit any PIC to operate unless the PIC 

meets AirFrame LLC’s qualification criteria and 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 will be logged in a manner 

consistent with 14 CFR § 61.51(b). The PIC will ensure that the 

VO is trained appropriately in order to fulfill her or her duties. A 

record of training will be documented and made available upon 

request by the Administrator. Flights for the purposes of 

training the operator’s PICs and VOs (training, proficiency, and 

experience-building) will only be conducted during dedicated 

training sessions. During training, proficiency, and experiencebuilding flights, all persons not essential for flight operations are 

considered nonparticipants, and the PIC will operate the UA with 

appropriate distance from nonparticipants in accordance with 14 
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CFR § 91.119. 

12. UAS operations will not be conducted during night, as defined in 

14 CFR § 1.1. All operations will be conducted under visual 

meteorological conditions (VMC). 

13. The UA will not operate within 5 nautical miles of an airport 

reference point as denoted on a current FAA-published 

aeronautical chart unless a letter of agreement with that 

airport’s management is obtained, and the operation is 

conducted in accordance with a Notice to Airmen (NOTAM), as 

required by the operator’s Certificate of Waiver or Authorization 

(COA). The letter of agreement with the airport management will 

be made available to the Administrator upon request. 

14. The UA will not be operated less than 500 feet below or less 

than 2,000 feet horizontally from a cloud or when visibility is 

less than 3 statute miles from the PIC. 

15. If the UA loses communications or loses its GPS signal, it will 

return to a pre- determined location within the planned 

operating area and land or be recovered in accordance with the 

FOM. 

16. The PIC will abort the flight in the event of unpredicted 

obstacles or emergencies in accordance with FOM 

17. The PIC will be prohibited from beginning a flight unless 

(considering wind and forecast weather conditions) there is 

enough power to fly at normal cruising speed to the intended 

landing point and land the UAS with 25% battery power 

remaining. 

18. The operator will obtain an Air Traffic Organization (ATO) issued 

COA prior to conducting any operations under this grant of 

exemption. This COA will require the operator to request a 

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

48 hours prior to the operation. All operations will be conducted 

in accordance with airspace requirements in the ATO issued COA 

including class of airspace, altitude level and potential 

transponder requirements. 
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19. The UAS will be identified by serial number, registered in 

accordance with 14 CFR part 47, and have identification (NNumber) markings in accordance with 14 CFR part 45, Subpart 

C. Markings will be as large as practicable. 

20. Before conducting operations, the radio frequency spectrum 

used for operation and control of the UA will comply with the 

Federal Communications Commission (FCC) or other appropriate 

government oversight agency requirements. 

21. The operator will keep a copy of the UAS manufacturer’s 

operating/flight manual and all other operating documents in a 

location accessible to the PIC, during flight operations. These 

documents will be made available to the Administrator or any 

law enforcement official upon request. 

22. The UAS will remain clear and yield the right of way to all other 

aviation operations and activities at all times 

23. The UAS will not be operated by the PIC from any moving device 

or vehicle 

24. Flight operations will be conducted at least 500 feet from all 

nonparticipating persons, vessels, vehicles, and structures 

unless: 

a. Barriers or structures are present that sufficiently protect 

nonparticipating persons from the UA and/or debris in the 

event of an accident. The operator will ensure that 

nonparticipating persons remain under such protection. If 

a situation arises where nonparticipating persons leave 

such protection and are within 500 feet of the UA, flight 

operations will cease immediately and/or; 

b. The aircraft is operated near vessels, vehicles or 

structures where the owner/controller of such vessels, 

vehicles or structures has granted permission and the PIC 

has made a safety assessment of the risk of operating 

closer to those objects and determined that it does not 

present an undue hazard, and; 
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c. Operations nearer to the PIC, VO, operator trainees or 

essential persons do not present an undue hazard to 

those persons per § 91.119(a). 

25. All operations will be conducted over private or controlledaccess property with permission from the property 

owner/controller or authorized representative. Permission from 

property owner/controller or authorized representative will be 

obtained prior to the beginning of every flight.

26. Any incident, accident, or flight operation that transgresses the 

lateral or vertical boundaries of the operational area as defined 

by the applicable COA will be reported to the FAA's UAS 

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

reported to the National Transportation Safety Board (NTSB) per 

instructions contained on the NTSB Web site: www.ntsb.gov. 

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

that the UAS operated without an airworthiness certificate, in the 

restricted environment and under the conditions proposed will be at least 

as safe, or safer, than a conventional aircraft (fixed wing or rotorcraft) 

operating with an airworthiness certificate without the restrictions and 

conditions proposed. 

The UAS to be operated is less than 55 lbs. fully loaded, carries neither a 

pilot nor passenger, carries no explosive materials or flammable liquid 

fuels, and operates exclusively within a secured and designated area. 

Unlike other civil aircraft, operations under this exemption will be tightly 
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controlled and monitored by both the operator and under the 

requirements and in compliance with local public safety requirements. The 

FAA will have advance notice of all operations. These safety 

enhancements 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. § 61.113 (a) and (b): Private Pilot Privileges and 

Limitations: Pilot in Command 

Pursuant to 14 CFR 61.113 (a) & (b), no person who holds a private pilot 

certificate may act as a pilot in command of an aircraft that is carrying 

passengers or property for compensation or hire. AirFrame LLC may 

achieve an equivalent level of safety as achieved by current Regulations 

because the applicant’s UAS do not carry any pilots or passengers nor 

property. The risks attendant to the operation of UAS is far less than the 

risk levels inherent in the commercial activities outlined in 14 CFR 61. The 

PIC of the UAS will have a Commercial Pilot’s License along with a current 

Second Class or higher Medical exceeding the current safety levels in 

relation to 14 CFR 61.113 (a) & (b)

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 for maintenance and use of safety checklists prior to each 

flight and procedures outlined in the FOM and user’s manuals, an 

equivalent level of safety will be provided. 

 
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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. The PIC will take all actions as stated in the FOM under Normal 

Procedures including but not limited to reviewing weather, flight battery 

requirements, and aircraft performance data before initiation of flight. 

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. The equivalent level of safety is provided by the fact that neither 

a pilot nor passengers will be carried in the aircraft and by the size and 

speed of the aircraft. Details of AirFrame LLC’s required flight instruction 

are included in the FOM.

14 C.F.R. §91.119(c): Minimum Safe Altitudes 

Section 91.119 establishes safe altitudes for operation of civil aircraft 

and states that “except when necessary for takeoff or landing, no person 

may operate an aircraft below the following altitudes: ..... 

(c) Over other than congested areas. An altitude of 500 feet above the 

surface, except over open water or sparsely populated areas. In those 

cases, the aircraft may not be operated closer than 500 feet to any 

person, vessel, vehicle, or structure.” 

Because AirFrame LLC requests authority to operate at altitudes only up 

to 400 AGL, an exemption is needed to allow such operations. The UAS 

will never operate higher than 400 AGL. It will, however, be operated in a 
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restricted area within a 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, and 

speed of the UAS as well as the location where it is operated. No flight 

will be taken without the permission of property owners or local officials. 

Because of the advance notice to the property owners and participants in 

the filming activity, all affected individuals will be informed of the planned 

flight operations. Compared to flight operations for manned aircraft and 

the lack of flammable fuel, any risk associated with the proposed UAS 

operations is far less than conventional aircraft operating at or below 500 

AGL. In addition, the low-altitude operations of the UAS will ensure 

separation between a UAS and conventional aircraft. 

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

This regulation requires each person operating an aircraft to maintain 

cruising altitude by reference to an altimeter that is set “...to the 

elevation of the departure airport or an appropriate altimeter setting 

available before departure.” As the UAS may not have a barometric 

altimeter, but instead a GPS altitude read out, an exemption may be 

needed. An equivalent level of safety will be achieved by the operator, 

pursuant to FOM procedures and live flight data monitoring, confirming 

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

flight. All altitudes will be reported to ATC in feet Above Ground Level 

(AGL).

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.” 

The battery powering the UAS provides approximately 30 minutes of
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powered flight. To meet the 30 minute reserve requirement in 14 CFR 

§91.151, UAS flights would be limited to approximately 10 minutes in 

length. Given the limitations on the UAS’s proposed flight area and the 

location of its proposed operations within a predetermined area, a longer 

time frame for flight in daylight or twilight VFR conditions is reasonable. 

AirFrame LLC believes that an exemption from 14 CFR §91.151(a) falls 

within the scope of prior exemptions. Operating the UAS, in a tightly 

controlled area, with less than 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 

UAS flights to 10 minutes would greatly reduce the utility for which the 

exemption will be granted. AirFrame LLC believes that an equivalent level 

of safety can be achieved by limiting flights to 75% battery, ensuring the 

UA lands with at least 25% battery charge remaining. This restriction 

would be more than adequate to return the UAS to its planned landing 

zone from anywhere in its limited operating area. 

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 the applicant. 

Maintenance actions will be accomplished by the operator pursuant to the 

FOM and the user’s manuals. An equivalent level of safety will be achieved 

because the UAS is very limited in size and will carry a small payload and 

operate only in restricted areas for a limited period of time. If mechanical 

issues arise the UAS can land immediately and will be operating from no 

higher than 400 feet AGL. The operator will ensure that the UAS is 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 
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aircraft in an airworthy condition to provide the 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 

User Manual. As provided in the FOM and the user’s manuals, the operator 

will ensure that the UAS is in working order prior to initiating flight and 

perform required maintenance needed. 
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CONCLUSION 

Approval of exemptions allowing commercial operations of UASs will 

enhance safety by reducing risk. Conventional operations, using jet or 

piston power aircraft, operate at extremely low altitudes just feet from 

the subject being observed and in extreme proximity to people and 

structures; and present the risks associated with vehicles that weigh in 

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

fuel (140 gallons for jet helicopters). Such aircraft must fly to and from 

the inspection site. In contrast, a UAS weighing fewer than 55 lbs. and 

powered by batteries eliminates virtually all of that risk given the reduced 

mass and lack of combustible fuel carried on board. The UAS is carried to 

the operational site. The UAS will carry no passengers or crew and, 

therefore, will not expose them to the risks associated with manned 

aircraft flights. I, the Chief Pilot at AirFrame LLC, have close to 8 years 

experience flying remote controlled (RC) aircraft and over 15 years 

experience flying turbojet commercial aircraft for major commercial

carriers internationally. I fully understand the safety concerns of the 

general public and aviation industry. AirFrame LLC will adhere to all FAR’s 

and maintain an Equivalent Level Safety, or better, during all operations. 

Please find attached: Flight Operations Manual (FOM)*

Pixhawk/APM User’s Manual

Dragon Link User’s Manual

Taranis User’s Manual

RFD900 Data Sheet

S800 User’s Manual

Tarot 680 Pro Specifications

*Applicant submits this Flight Operations Maunal (FOM) as a Confidential document under 14 CFR 

11.35 (b) as the entire FOM contains proprietary information that the applicant has not and will not 

share with others. The manual contains operating conditions and procedures that are not available 

to the public and are protected from release under the Freedom of Information Act 5 USC 552 

et.seq. 

Sincerely,

Nathan W. Richards