ANDREW TRONE

D.B.A TRONES DRONES

118 VIRGINIA LANE

RUSHVILLE, IL 62681

309.333.7875

TRONESDRONES@GMAIL.COM

Dear Sir or Madam,

 Andrew Trone d.b.a Trones Drones is petitioning the Federal Aviation Administration (FAA) for 

an exemption to Section 333 of the FAA Modernization and Reform Act of 2012 (FMRA) and 14 

CFR part 11. The exemption would allow commercial operation of the DJI Phantom 2 vision plus 

v3.0 unmanned aircraft systems (UAS) for the purpose of aerial videography and photography for 

constructions sites, agriculture inspections, real estate agents, insurance claims due to natural 

disasters, and landscape photography and videography.

 Trones Drones agrees to operate within the boundaries set forth by this exemption. Trones Drones 

would provide a professional service in the aerial photography and videography field. Trones Drones 

will provide a low cost business alternative to its customers to be more efficient and a safer alternative 

to using a manned aircraft. Please Allow Trones Drones to offer UAS operations to its local market to 

promote the safe, efficient and responsible use of UAS.

 

The Aircraft, specifications, and levels of safety and maintenance.

Trones Drones will operate the DJI Phantom 2 Vision Plus and will provide a professional and safe 

manner of collecting photos and videos.

1. The safe operation of the UAS will be the first priority before, during and after every

operation.

2. The Phantom 2 has numerous safety features such as Failsafe mode, automatic landing 

should signal between PIC and UAS be interrupted, GPS based altitude and distance locks, 

Flight Limits function and low battery warnings at 20% that automatically returns to home.

3. Operations utilizing the Phantom 2 will provide a benefit to the general public and serve the 

public interest by providing the service of aerial photographic images and video to numerous 

businesses and individuals for considerably less than the previously only available option of 

utilizing manned aircraft at an equivalent level of safety

4. The device utilizes GPS to establish its home points for takeoff and return to home when 

battery levels reach 20%. 

5. The device, equipped with a failsafe should something go wrong, will go to its designated 

home point set before each flight. 

6. The weight of the DJI Phantom is under 3 pounds and is powered by a 5200mah battery which 

is used to power the 4 electric motors. The batteries enable a flight time of 20 to 28 minutes. 
7. All UAS operations will be conducted at Visual Line Of Sight (VLOS) at no more than 400 

feet AGL.

8. No UAS operations will be conducted within 5 NM of an airport.

9. No UAS operations shall occur over densely populated areas, large assemblies of people, 

stadiums, government buildings, power lines, or major roads.

10. All nonparticipating persons shall be a minimum of 500 feet from the UAS.

11. If a nonparticipating person comes within 500 feet of the UAS, flight operations will cease 

immediately.

12. All UAS operations shall take place during daylight hours under conditions

equivalent to Visual Flight Rules (VFR) with the UAS no more than 3/4 NM from the

PIC.

13. The UAS will yield to all manned aircraft at all times.

14. A pre-flight inspection by the PIC will be performed prior to each flight to assure that

the UAS is safe for flight. A post-flight inspection will also be performed as an added

level of safety. An aircraft check will also occur after every two hours of flight.

15. At no time shall the UAS be operated with missing or manufacturer unapproved parts,

or in any condition that could pose a hazard to any other aircraft or structure or person on the 

ground.

16. The DJI Phantom 2 Vision plus has a weight of less than 3 pounds, a length of 16 inches and a

width of 16 inches, height of 8 inches, and has a max speed of 15m/s mph.

Regulations from which the exemption is requested: 

14 CFR Part 21 

14 C.F.R. § 45.23(b) 

14 CFR § 61.3 

14 C.F.R. § 91.7 (a) 

14 CFR § 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 CFR § 91.151 (a) 

14 CFR § 91.203 (a) & (b) 

14 CFR § 91.205(b) 

14 CFR § 91.215 

14 CFR § 91.405 (a) 

14 CFR § 407 (a) (1) 

14 CFR § 409 (a) (2) 

14 CFR § 417 (a) & (b)
Flight Profiles

Trones Drones flight profile varies per customer, and not every flight path will be the same. 

Each client will have a specific need for the services Trones Drones provides. And with such 

a wide range of options for the customer, a needs assessment will be provided to assure 

customer satisfaction. Often times I will provide services for social networking to promote the 

importance of the use of drones and the benefits they provide. The use of the DJI Phantom 2

Vision Plus will provide a benefit to the general public and serve the public interest by

providing the service of aerial photographic images and video to numerous businesses and 

individuals for considerably less than the previously only available option of utilizing manned 

aircraft at an equivalent level of safety.

Conclusion

 Trones Drones is requesting an exemption for the purpose of providing aerial photography, 

videography, mapping, crop management, insurance claims, and real estate photography. This

exemption would allow Trones Drones to provide the aerial footage necessary for the 

community to get a better perspective of ways to improve crop performance, the housing 

market, a quicker turn around after a natural disaster, as well as that person who wants to get 

an aerial photograph of their property. With the market in high demand for individuals in need 

of this service, Trones Drones will provide this service with safety and quality in mind. With 

over 7 years of previous radio controlled vehicles, both gas and electric, I fell I am qualified to 

provide this service. 
Appendix 

Section Subject Justification 

14 CFR § 45.23(b) Requirement to display 

registration number on vehicle 

Insufficient space on vehicle 

14 CFR Part 21 Aircraft certification 

requirements and procedures 

Designed for manned aircraft; 

not suitable for off-the-shelf 

UAS 

14 CFR § 61.3 Requirement for pilot 

certificate 

Part 61 requirements designed 

for manned aircraft, not UAS; 

petition describes training for 

UAS operator 

14 CFR § 91.7 (a) Airworthiness requirement Designed for manned aircraft; 

not suitable for off-the-shelf 

UAS 

14 CFR § 91.9 (b) (2) Requirement for manual to be 

available in the cockpit 

No one aboard to read manual 

14 CFR § 91.103(b) Requirement for crew 

members to be onboard 

Unmanned vehicle 

14 CFR § 91.109 Requirement for dual controls 

during flight instruction 

No one aboard to operate 

controls 

14 CFR § 91.119 Minimum altitudes for safe 

flight 

Safety requires operation 

below these altitudes 

14 CFR § 91.121 Altimeter settings No one aboard to read 

altimeter 

14 CFR § 91.151(a) Fuel requirements Vehicle does not use fuel 

14 CFR § 91.203 (a) & (b) Requirement for registration 

and airworthiness certificates 

to be onboard 

No one aboard to read 

certificates 

14 CFR § 91.205(b) Cockpit instruments No one aboard to read