UNITED STATES OF AMERICA DEPARTMENT OF TRANSPORTATION FEDERAL AVIATION 

ADMINISTRATION WASHINGTON, DC

Regulatory Docket No. _______________

PETITION FOR EXEMPTION OF: 

UAV MONSTER, LLC.

SEEKING RELIEF FROM THE REQUIREMENTS OF 

TITLE 14 OF THE CODE OF FEDERAL REGULATIONS

Subchapter C section 21 subpart H, Subchapter F parts 91.103, 91.105, 91.109, 91.119,

 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), AND 91.417(a) & (b)

 CONCERNING COMMERCIAL OPERATION OF DJI PHANTOM 2, DJI PHANTOM 3, DJI 

INSPIRE 1, AND 3D ROBOTICS SOLO UNMANNED AIRCRAFT SYSTEMS PURSUANT TO

 SECTION 333 OF

THE FAA MODERNIZATION AND REFORM ACT OF 2012

(PUBLIC LAW 112-95)

Submitted on July 16, 2015

Doug Lee

Chief Pilot

UAV Monster LLC

791 Palo Verde Dr.

Sierra Vista, AZ 85635 

Tel:(520)266-1122

Email: UAVMonster@gmail.com
GLOSSARY OF ABBREVIATIONS

AGL Above Ground Level 

AOI Area of Interest

ATC Air Traffic Control

ATO Air Traffic Organization 

AV Aerial Vehicle

CFR Code of Federal Regulations 

COA Certificate of Authorization 

FAA Federal Aviation Administration 

FAR Federal Aviation Regulation 

GCS Ground Control Station

GPS Global Positioning System 

LOL Loss of Link

NAS National Airspace System 

NOTAM Notice to Airman

PIC Pilot In Command

PO Payload Operator

SECTION 33 FAA Modernization and Reform Act of 2012 (FMRA) Section 333 

SOP Standard Operating Procedures

UA Unmanned Aircraft

UAS Unmanned Aircraft System

VFR Visual Flight Rules

VLOS Visual Line of Site

VMC Visual Meteorological Conditions

VO Visual Observer
VTOL Vertical Takeoff and Landing
TABLE OF CONTENTS

Summary .............................................................................................................1

Description of Unmanned Aircraft ..............................................................................5 

Description of Ground Control Station.........................................................................7 

Flight Crew qualifications and description....................................................................8

Unmanned Aircraft System operations and limitations ...................................................9

Name and address of Petitioner ..............................................................................10

List of regulations for consideration of exemption.........................................................11

Summary for Federal Register.................................................................................14

Conclusion..........................................................................................................15
SUMMARY

Dear Sir or Madam:

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

and 14 C.F.R. Part 11, UAV Monster, LLC (Further known as UAVM) seeks exemption from 

requirements of 14 C.F.R. § 21, Subpart H; 14 C.F.R. § 43.11; 14 C.F.R. § 91.103; 14 C.F.R. § 

91.105; 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. § 91.405(a) and (d); 14 C.F.R. § 91.407(a)(1); 14 C.F.R. § 91.409(a)(2); 14 C.F.R. § 

417(a) and (b) to operate the Unmanned Aircraft Systems detailed below in support of 

commercial aerial photography and videography of events, activities, individual commercial, 

public, and residential properties and structures with owners/operators/coordinators permission 

and appropriate authorization. UAVM’s Senior Pilot is currently a US Army trained and certified 

UAS Instructor Pilot with over 2000 UAS flight hours therefore UAVM would also request to use 

this exemption to provide a venue and platform for type specific UAS flight instruction to new 

commercial and public use UAS pilot/operator applicants. Our years of experience in training 

UAS pilots and flying complex UAS systems for the military will aid in development of ground 

and flight training programs to enhance safety of new commercial UAS pilots seeking 

exemptions or certification.

The request for this exemption is in the Public Interest as there are many consumer applications 

for the services that can be provided by UAS that are currently conducted by manned aircraft. 

Using a UAS for many of these applications creates an environmentally friendly, lower cost 

solution to both the operator and consumer. These aircraft can be operated without risk of loss 

of life or limb, and without significant financial impact to the operator or any person or property 

on the ground in the event of the loss of an aircraft. Utilizing these UAS will create a safe and 

more productive work environment, reduce environmental pollution and have a positive impact 

on the local economy which is in the Public Interest. Finally the petitioner believes that granting 

this exemption would help to further the success of UAS integration into the NAS by creating an 

environment where prospective new UAS pilots could receive type specific training and 

experience to be used as these systems become more widely utilized.
THE UNMANNED AIRCRAFT (UA)

UAVM will be using 3 variants of DJI Innovations commercially available UAS systems; the 

Phantom 2, Phantom 3, and the DJI T600 Inspire; and 1 variant of 3D Robotics commercially 

available UAS system, the 3DR Solo. System specifications, flight and maintenance manuals of 

each system are available upon request.

1. Phantom 2 User manual

2. Phantom 3 User manual

3. Inspire User manual version

4. Inspire Maintenance manual

5. 3DR Solo User manual

6. Intelligent Flight Battery safety guidelines

• The Phantom variations manufactured by DJI Innovations, are lightweight 4 electric motor/

rotor, battery operated quadcopter with a 3.0lb gross weight that take off and land vertically. 

The Phantoms have a length of 16 inches, width of 16 inches, height of 8 inches, and a 

maximum speed of approximately 29 knots. Its avionics suite contains an on- board flight 

computer with GPS navigation and an Inertial Measurement Unit (IMU) based attitude 

stability system. Also included is a barometric altimeter sensor and compass unit. An onboard processor receives signals for flight and payload control from a ground-based 

transmitter/controller/ground station device. An on-board telemetry system delivers flight data 

from the flight computer to the downlink radio transmitter to provide the Pilot in Command 

(PIC) with information such as altitude AGL, horizontal and vertical speed, compass direction 

of flight, bearing and distance to the controlling station, current waypoint, battery status, 

current flight mode, GPS health status, loss of link status, and GPS position. This data is 

displayed to the PIC via the Ground Control Station (GCS) application running on one or 

more computer devices such as a smart phone, tablet or PC.

• The DJI T600 Inspire One manufactured by DJI innovations, is a lightweight 4 electric motor/

rotor, battery operated quadcopter with a 6.5lb gross weight that takes off and lands vertically. 

The Inspire one has a length of 17.3 inches, width of 17.7 inches, height of 11.8 inches, and a 

maximum speed of approximately 42 knots. Its avionics suite contains an on-board flight 

computer with GPS navigation and an Inertial Measurement Unit (IMU) based attitude 

stability system. Also included is a barometric altimeter sensor, compass unit ultrasonic 

altimeter and vision positioning camera. An on-board processor receives signals for flight and 

payload control from a ground-based transmitter/controller/ground station device. An onboard telemetry system delivers flight data from the flight computer to the downlink radio 

transmitter to provide the Pilot in Command (PIC) with information such as altitude AGL, 

horizontal and vertical speed, compass direction of flight, bearing and distance to the 

controlling station, current waypoint, battery status, current flight mode, GPS health status, 

datalink status, and GPS position. This data is displayed to the PIC via the Ground Control 

Station (GCS) application running on one or more computer devices such as a smart phone, 

tablet or PC.

• The Solo manufactured by 3D Robotics is a lightweight 4 electric motor/rotor, battery 

operated quadcopter with a 3.3lb gross weight that takes off and lands vertically. The Solo 

has a length of 18.1 inches, width of 18.1 inches, height of 10.2 inches, and a maximum 
speed of approximately 33 knots. Its avionics suite contains an on-board flight computer with 

GPS navigation and an Inertial Measurement Unit (IMU) based attitude stability system. Also 

included is a barometric altimeter sensor and compass unit. An on-board processor receives 

signals for flight and payload control from a ground-based transmitter/controller/ground 

station device. An on-board telemetry system delivers flight data from the flight computer to 

the downlink radio transmitter to provide the Pilot in Command (PIC) with information such as 

altitude AGL, horizontal and vertical speed, compass direction of flight, bearing and distance 

to the controlling station, current waypoint, battery status, current flight mode, GPS health 

status, loss of link status, and GPS position. This data is displayed to the PIC via the Ground 

Control Station (GCS) application running on one or more computer devices such as a smart 

phone, tablet or PC.

• All systems carry an on-board camera capable of capturing imagery in the form of full color, 

high definition still photos and real time video. The video stream and still pictures can be sent 

via the downlink transmitter to the Ground station for the PIC and optional Payload Operator 

(PO) to view, record, and stream.

• All UA systems described above have a GPS aided “Return Home” function in the event of a 

loss of link condition or a low battery condition. The return home function can also be 

commanded by the PIC in the event of disorientation or loss of eye contact. Prior to any flight 

operation the PIC will set the desired “Home” location and altitude the UA will fly while 

returning to the home location. The UA’s onboard autopilot system will maneuver the UA back 

to the home location and land automatically if it has been commanded or if a loss of link has 

occurred.

• All UAs that will be operated by UAVM will be registered in accordance with 49 U.S.C. 44103, 

Registration of Aircraft, as well as 14 C.F.R Part 47, Aircraft Registration, and marked in 

accordance with 14 C.F.R. Part 45, Identification and Registration Marking in a size as large 

as practical for the size of the UA.

• All UAs that will be operated by UAVM will be maintained in accordance with the 

manufactures maintenance and user manuals. Repairs, inspections (except preflight), 

component changes, and software/firmware updates will be recorded in the UAs airframe 

maintenance logbook. Logbook entries will include date, airframe serial number, registration 

number, current airframe flight time, description of work performed, part number and serial 

number of components replaced if available, signature of person performing the work.
THE GROUND CONTROL STATION/CONTROLLER:

The UAS products UAVM intends to operate under this exemption use a series of components 

to comprise the Ground Control Station (GCS). The first and primary components of the ground 

segment is a handheld pilot controller and an optional handheld payload controller. The pilot 

controller provides a user interface for flight attitude and altitude commands augmented by the 

UA’s onboard IMU and GPS aided stabilization system. The controller also has options for 

manipulating the flight mode, payload gimbal, camera functions, and landing gear if equipped. 

The Datalink segment is comprised of an uplink transmitter command/control link using a 

frequency range of 2.4GHz to 2.48GHz frequency range with a power output of approximately 

125mW. The uplink sends flight and payload commands to the UA’s autopilot which then 

processes the commands along with sensor inputs to manipulate the motor speed controllers 

and provide the desired response. The downlink transmitter on the UA operates on a 5.728GHz 

to 5.85GHz and an output power of approximately 25mW. The downlink transmitter provides live 

video from the on-board camera plus all the UA flight data described above. Downlink data and 

video is received by the pilot controller and optional payload controller which is then displayed to 

the PIC and optional PO via an application on a handheld device such as a smart phone, tablet 

or PC. The GCS application also provides a heads up display of pertinent flight data and UA 

status reports along with a moving map display. Both the uplink and downlink transmitters have 

been tested and comply with part 15 of the FCC rules for a class B digital device.
UAS FLIGHT AND SUPPORT CREW:

The Pilot in Command (PIC) is the individual responsible for and in operational control of the 

flight operation from beginning to end. The PIC performs the preflight inspection of the UA, the 

preflight risk assessment, obtains all available information pertaining to the flight and briefs the 

other crew-members. The PIC will not change once a flight has begun. During instructional 

flights the PIC will be the Instructor. The following minimum experience and currency 

requirements will be utilized.

• A UAVM UAS PIC will hold a UAS Instructor Pilot/Operator Certificate.

• A UAVM UAS PIC will hold a current class II flight physical.

• Prior to commercial operations the UAVM UAS PIC will have logged a minimum of

25 hours as PIC of a UAS.

• Prior to commercial operations the UAVM UAS PIC will have logged a minimum of 5

hours of PIC time in the make and model UAS being used.

• A UAVM UAS instructor pilot will hold a current UAS flight instructor certificate

• A UAVM UAS instructor will have logged a minimum of 200 hours of UAS instruction.

• A UAVM UAS instructor will have logged a minimum of 50 hours as PIC of a UAS. 

• A UAVM UAS instructor will have logged a minimum of 5 hours of PIC time in the

make and model of UAS being used.

• Within 90 days of a UAS commercial operations a UAVM UAS PIC will perform the

following UAS currency events.

• 3 Takeoffs and Landings

• 1 recovery from a simulated loss of link event.

• Students receiving UAS training at UAVM will be verified as U.S. citizens or approved by the 

Transportation Security Administration TSA as required by the regulations of CFR 49 subpart 

1552.

• The Visual Observer (VO) is the person or persons providing visually observation of the UA 

while in flight to alert the PIC of any risk factors inflight such as traffic, unauthorized personnel 

in the flight area, collision hazards to the UA, etc. The VO will maintain communication with 

the PIC at all times. Multiple VO’s can be used for operation but not in a “daisy chain” 

arrangement, the UA will remain in visual range of both the PIC and VO(s) at all times. The 

VO does not require a specific pilot certification or medical but will receive the following 

training prior to conduction operations as a VO.

• Overview of the UAS being used.
• Limitations of the UAS, COA, and Exemption authorization. 

• Maintaining orientation of the UA inflight.

• Proper communication to the PIC.

• Traffic and obstacle scanning.

• Conducting an IMSAFE assessment.

• The Payload Operator (PO) is an additional crew-member that can be used to perform the 

duties of operating the UA payload system while inflight. The PO will have an additional 

dedicated payload controller and display linked to the PIC flight controller. The PO controller 

will be a slave controller that can only manipulate the payload controls and not the flight 

control of the UA. During any portion of the flight if the PIC deems it necessary the PIC can 

regain payload control back to the master controller. The PO would not be considered a 

required crew-member for any flight operation. The PO would be considered support 

personnel used to relieve workload on the PIC in certain operations such as areas of 

congested obstacles. An assigned PO will not perform the duties of a VO at any time during 

the flight operation.
OPERATION OF THE UA

• The UAS’s size, weight, limited range and payload capacity, along with restricted use within a 

COA area monitored by UAVM in no way presents a national security issue. The Exemptions 

requested by UAVM provide for the equivalent, if not a higher, level of safety than the current 

similar manned airborne photo/video systems due to the dangers associated with much 

larger, heavier, and faster conventional manned aircraft.

• Using this exemption to provide type specific UAS flight training will allow UAVM to share our 

vast knowledge of unmanned operations within the national airspace to enhance safety. 

Interested students will be provided an approved venue, platform and experienced instructor 

to develop the knowledge and skills required to safely operate UA’s in the national airspace 

system.

• UAVM UAS operations will also comply with the following limitations:

(a) Operations will occur in Class G airspace at no more than 400 ft AGL or the 

maximum altitude specified in the COA limitations.

(b) Operations can be conducted within Class E and Class D airspace but only with an 

approved letter of agreement/authorization with the controlling agency/airfield manager 

and will not exceed 400 ft agl or the maximum altitude specified in the COA limitations.

(c) UAVM will not operate a UA within 5 NM of an airport or heliport unless prior 

permission has been obtained from the controlling agency/airfield manager.

(d) UAVM will not operate the UA at an airspeed greater than 42 knots.

(e) UAVM will only operate the UA in the daytime under VFR conditions.

(f) UAVM will obtain the appropriate COA for the desired flight area as required and 

remain in compliance with the COA restrictions.

(g) UAVM will file the appropriate NOTAM for the desired flight area as required.

(h) UAVM will obtain permission from the property owner, authorized agent or controlling 

agency prior to operation at that location.

(i) UAVM will ensure the operational area is posted/access controlled and the 

operational area is clear of personnel not involved in the UAS flight operation.

(j) The UAVM PIC will complete the manufactures preflight checklist as well as the 

UAVM preflight risk assessment sheet.

(k) UAVM will maintain a copy of the current user/operations manual for the UAS with 

the ground control station during operation.

(l)UAVM will ensure the UA remains clear of and yield the right of way to all manned 

aircraft operations and activities at all times.

(m) The UAS will not be operated by the PIC from any moving vehicle or device.

(n) Any incident, action, 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 Integration Office (AFS-80) within 24 hours. Accidents will be reported to the 

National Transportation Safety Board (“NTSB”). Further flight operations will not be 

conducted until the incident, accident, or transgression is reviewed by the AFS-80 and 

authorization to resume is provided.
Name and Address of the Petitioner:

The name and address of the Petitioner and point of contact is:

UAV Monster, LLC 

Attn: Doug Lee

Ph: (520) 266-1122

Email: UAVMonster@gmail.com
BASIS FOR PETITION AND LIST OF EXEMPTIONS FOR CONSIDERATION

Based on the facts and descriptions we have provided, we respectfully request that the FAA 

grant UAVM the following requested exemptions:

14 C.F.R. § 21, Subpart H; 14 C.F.R. § 43.11; 14 C.F.R. § 91.103;14 C.F.R. § 91.105; 

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. § 91.215; 14 C.F.R. § 91.405(a) and (d); 14 C.F.R. § 91.407(a)(1);

14 C.F.R. § 91.409(a)(2); 14 C.F.R. § 417(a) and (b).

14 C.F.R. 21, Subpart H: Airworthiness Certificate

UAVM requests an exemption from 14 C.F.R. 21, Subpart H. This Subpart establishes the 

procedures for the issuance of an airworthiness certificate. UAVM requests an exemption from 

Part 21, Subpart H because the UAs meets an equivalent level of safety pursuant to Section 

333 of the Reform Act due to its small size, light weight, and restricted operating environment.

14 C.F.R 43.11: Records for Inspections

UAVM requests an exemption from 14 C.F.R. 43.11. This part provides that maintenance record 

entries be maintained, that the inspector list discrepancies, and to affix placards to the aircraft. 

Due to its small size the UAS proposed for use, does not have room for placards to be placed in 

or on it and no inspections for UAS have been certified by FAA at the present time. However, as 

a condition to the grant of the exemption, UAVM will perform the inspections and time 

replaceable items recommended by the manufacturer and keep records and log books of all 

maintenance and repairs.

14 C.F.R 91.103: Preflight Action

UAVM requests an exemption from 14 C.F.R. 91.103. This regulation requires each PIC to take 

certain actions before flight to insure the safety of flight. As FAA approved flight manuals will not 

be provided for the UAS, an exemption is needed. The PIC will follow the manufactures preflight 

inspection and complete the UAVM preflight risk assessment which includes reviewing weather, 

flight battery requirements, landing and takeoff areas, loss of link plan, etc. before flight.

14 C.F.R 91.105: Flight Crew-members at Stations

UAVM requests an exemption from 14 C.F.R. 91.105. UAVM requests an exemption from 14 

C.F.R. 91.105 since this part is not applicable due to the UAS carrying no flight crew-members. 

An equivalent level of safety will be maintained by ensuring the PIC does not change inflight. In 

the case of an instructional flight the Instructor is the assigned PIC and with the aid of the 

onboard stabilization system, handover of master controller and/or use of secondary controller 

can remain in positive control of the UA flight at all times.

14 C.F.R 91.109: Flight Instruction; Simulated Instrument Flight and Certain Tests

UAVM requests an exemption from 14 C.F.R. 91.109. 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 

can be maintained with the onboard stabilization system, automatic takeoff and landing feature, 

and the automatic return home capability. In addition a second slave controller or handover of 

the master controller can ensure the PIC/Instructor remains in positive control of the UA. Also, 

increased safety is achieved because the UAS will not carry pilots or passengers, and the flight 

area will be clear of all non-flight essential personnel prior to each flight.

14 C.F.R 91.119: Minimum Safe Altitudes

UAVM requests an exemption from 14 C.F.R. 91.119. Section 91.119 establishes safe altitudes 

for operation of civil aircraft. Section 91.119(c) prevents flying an aircraft at an altitude of less 

than 500 feet or operating an aircraft closer than 500 feet to any person, vessel, vehicle, or 

structure. As this exemption requests authority to operate at altitudes up to 400 feet, an 

exemption is needed to allow such operations. As set forth herein, the UAS will never operate at 

higher than 400 feet above ground level. It will however be operated on/over private property 

with the landowner’s consent. The equivalent level of safety will be achieved given the size, 

weight, limited speed of the UAS as well as maintaining a location clear of non-essential 

personnel where it is operated. No flight will be taken without the permission of the landowner, 

authorized official, or controlling agency. Compared to flight operations with aircraft or rotorcraft 

weighing far more than the proposed UA’s weight and the lack of flammable fuel on the UAS, 

any risk associated with the UAS operations is far less than similar operations with conventional 

aircraft.

14 C.F.R 91.121: Altimeter Settings

UAVM requests an exemption from 14 C.F.R. 91.121. 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.” Although the UA does have a barometric altimeter sensor, it is not adjustable and 

relies instead on a GPS altitude and ultrasonic sensor for displaying AGL altitude to the PIC 

therefore an exemption is requested. An equivalent level of safety will be achieved by the 

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

flight as well as the operator receiving live feedback information about the UA, including the 

height of the UA, its forward velocity, and compass heading. The operator will be able to 

observe and limit the maximum height of the UA to 400’ AGL or less. Additionally, the UAS will 

be operated within the line of sight of the PIC and VO.

14 C.F.R 91.151(a): Fuel Requirements for Flight in Visual Flight Rules (“VFR”) Conditions

UAVM requests an exemption from 14 C.F.R. 91.151(a). Section 91.151(a) prohibits an 

individual from beginning “a flight in an airplane under visual flight rules 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: During the day, to fly after that for at 

least 30 minutes; or At night, to fly after that for at least 45 minutes.” The battery powering the 

UAS provides approximately 25 minutes of powered flight making it impossible to meet the 30 

minute reserve requirement in 14 C.F.R. §91.151. UAVM believes that an equivalent level of 

safety can be achieved by limiting flights to 25 minutes or 30 percent of remaining battery 

power, whichever happens first. This restriction would be more than adequate to return the UA 

to its planned landing zone from anywhere in its limited LOS operating area. In addition the UA 
reports its current battery condition and alerts the PIC when battery level is near the desired 

threshold (30%) for returning to the landing position from its current location.

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

UAVM requests an exemption from 14 C.F.R. 91.405 (a) and (d); 407 (a)(1), 409(a)(2), and 417 

(a) and (b). 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 sections and Part 43 apply only to aircraft with an airworthiness certificate, 

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

pursuant to the manufacturer’s maintenance and user manuals for the proposed UAS. An 

equivalent level of safety will be achieved because these small UAS are very limited in size and 

will carry a small camera and operate only in restricted areas for limited periods of time. If 

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

than 400 feet above ground level. The UAVM performing maintenance will hold at least a Light 

Sport Repairman’s certificate with a maintenance rating when performing required maintenance, 

and keep a log of any maintenance performed.
Summary for the Federal Register

The following summary is provided for publication in the Federal Register in accord with 14 

C.F.R. Part 11:

UAV Monster LLC requests exemptions from the following regulations:14 C.F.R. § 21, Subpart 

H; 14 C.F.R. § 43.11; 14 C.F.R. § 91.103;14 C.F.R. § 91.105;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. § 91.215; 14 C.F.R. § 91.405(a) 

and (d); 14 C.F.R. § 91.407(a)(1);14 C.F.R. § 91.409(a)(2); 14 C.F.R. §417(a) and (b) to operate 

commercially a small unmanned aircraft (10 pounds or less) in support of commercial aerial 

photography and videography of events, activities, individual commercial, public, and residential 

properties and structures with the owners/operators/coordinators permission and appropriate 

authorization. The Chief Pilot for UAVM is currently a UAS Instructor so UAVM would also 

request to use this exemption to provide a venue and platform for type specific UAS flight 

instruction to new commercial and public use UAS operator applicants. Our years of experience 

in training UAS pilots and flying complex UAS systems for the military will aid in development of 

ground and flight training programs to enhance safety of new commercial UAS operators 

seeking exemptions or certification.

Privacy

All flights will occur over private or controlled access property with the landowner’s prior consent 

and knowledge. Because overflight areas will be restricted there is little to no chance that there 

will be people who have not consented to being in close proximity with the UAS operation.
Conclusion

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

speed, operating capabilities, proximity to airports, operation within visual line of sight within a 

COA restricted area, and no impact to national security – provide more than adequate 

justification for the grant of the requested Exemptions allowing UAV Monster LLC to use the 

above described UAs for the proposed operations.

We are prepared to modify or amend any part of this request to satisfy the need for an 

equivalent level of safety. Please contact us at any time if you require additional information or 

clarification. We look forward to working with your office.

Sincerely,

Doug Lee,

Owner, UAV Monster, LLC

UAS Flight Instructor