3208 E. Colonial DR. STE 108

Orlando, FL 32803

June 4, 2015

US Department of Transportation 

Docket Management System 

1200 New Jersey Ave., SE 

Washington DC 20590 

Exemption Request Pursuant to Section 333 of the FAA Reform Act and 

Part 11 of the Federal Aviation Regulations from: 14 CFR Part 21 Subpart H,

14 CFR 61.113(a) and (b), 14 CFR 91.103, 14 CFR 91.109, 14 CFR 91.119, 14 CFR 91.121,

14 CFR 91.151, 14 CFR 91.405, 14 CFR 407, 14 CFR 409, 14 CFR 417

To Whom It May Concern: 

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

“Reform Act”) and 14 C.F.R. Part 11, Limitless Drones, LLC, an operator of 

Unmanned Aircraft Systems (“UASs”) for aerial photography and video for the real estate, 

motion picture and television industry, hereby applies for an exemption from the Federal 

Aviation Regulations (“FARs”) to allow commercial operation of its UASs. 

Limitless Drones, LLC’s requested exemption would permit the operation of small, 

unmanned UAS under 55 pounds to conduct aerial video and photography under the

Operational Control of an individual holding at least a Private Pilot certificate; under direct 

control of a Pilot in Command (PIC); within Visual Line of Sight (VLOS); while utilizing a 

second person for the purpose of a Safety Observer. As established by the exemptions 

already granted by the FAA, approval of Limitless Drones exemption would 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: 

Limitless Drones, LLC 

Attn: Justin Rivera 

PH: 407-278-9200

Email: Justin@LimitlessDrones.com

Address: 3208 E. Colonial DR STE 108 Orlando, FL. 32803

Regulations from which the exemption is requested:

14 CFR Part 21 Subpart H, 14 CFR 61.113(a) and (b),

14 CFR 91.103, 14 CFR 91.109, 14 CFR 91.119, 14 CFR 91.121,

14 CFR 91.151, 14 CFR 91.405, 14 CFR 407, 14 CFR 409, 14 CFR 417

UASs operated by Limitless Drones, LLC weigh less than 55 pounds, including 

the payload (i.e. camera, lens, and gimbal). They operate at speeds of no more 

than 50 knots, can hover, and can simultaneously move vertically and 

horizontally. Limitless Drones, LLC will only operate its UASs in line of sight 

below 400 feet AGL and will operate under the operational control of (at 

minimum) an FAA certified private pilot while maintaining a safety observer. 

Such operations will insure that the UAS will “not create a hazard to users of 

the national airspace system or the public.” 

Given the small size of Limitless Drones, LLC’s UASs and the safety 

considerations proposed in this petition, Limitless Drones, LLC’s UAS 

operations adhere to the Reform Act’s safety requirements. Additionally, due to 

the size of the UASs and the proposed use in which they will operate, approval 

of this application presents no national security issues. Based on the level of 

safety surrounding the proposed operations, and the significant public benefit:

Marketing and development of real estate, public awareness, reduction in 

environmental impacts by reduced emissions and noise, as well as an increase 

in revenue to the local economy through real estate development. The grant of 

the requested exemption is in the public interest. Accordingly, Limitless Drones, 

LLC respectfully requests that the FAA grant the requested exemption. 
Aircraft And Equivalent Level Of Safety 

The operating limitations proposed by Limitless Drones provide for at least an 

equivalent or higher level of safety because operations further enhance safety of real 

estate, movie, and television filming using conventional aircraft. 

Limitless Drones Proposed limitations and conditions include: 

• The UASs will weigh less than 55 pounds. 

• Flights will be operated within line of sight of a pilot and/or observer.

Maximum flight time for each operational flight will be 30 minutes. Flights will

be terminated at 25% battery power reserve should that occur prior to the 30 

minute limit.

• Flights will be operated at an altitude of no more than 400 feet AGL, and not

more than 200 feet above an elevated platform from which filming is planned.

• Minimum crew for each operation will consist of the UAS Pilot, and a visual 

observer.

• An FAA licensed airman with at least a private pilot’s certificate and third class 

medical will oversee all flight operations to ensure the highest degree of safety.

• All UAS Pilots will undergo in-house training before operating any UAS for 

commercial use. This will include situational awareness training, airspace

education, and proper operation of the proposed UAS. 

• The UAS will be operated within a confined area pre programmed 

into the software, avoiding inadvertent fly-away or flight beyond set parameters.

• A briefing will be conducted for planned UAS operations prior to each day’s

flight. All personnel involved in the operations are required to attend.

• The operator will obtain consent of all persons involved in the filming and

ensure that only consenting persons will be allowed within 50 feet of the

flight operation. 

• The operator will submit a written Plan of Activities to the FSDO three days

• 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.

• If the UAS loses communications or loses its GPS signal, the UAS will have

the capability to return to a pre-determined location and land. The location will be 

clear of all persons or property during the duration of the flight.

• The UAS will have the capability to abort a flight in case of unpredicted obstacles or
emergencies.

• The UASs will operate on the following frequencies, which are all FCC compliant

and do not require specific licenses when transmit power is limited to 1 watt:

902 to 928 MHz, 2.400 to 2.4835 GHz, and 5.725 to 5.875 GHz.

• The UASs will not operate in the proximity of airports.

14 C.F.R. Part 21, Subpart H: Airworthiness Certificates

Given the size and limited operating area associated with the UASs to be utilized 

by Limitless Drones, this 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 the UASs 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 UASs. In all cases, an analysis of 

these criteria demonstrates that a UAS operated without an airworthiness 

certificate, in a 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.

14 C.F.R. § 61.113(a) and (b): Private Pilot Privileges and Limitation: 

Pilot in Command Sections 61.113 (a) and (b) limit private pilots to noncommercial operations. Because the UAS will not carry a pilot or passengers, the 

proposed operations can achieve an equivalent level of safety of current operations

by requiring all operations to be supervised by (at minimum) an individual holding 

private pilot’s license rather than requiring that individual to hold a commercial pilot’s 

license to operate a small UAS. Unlike conventional manned aircraft, a 

ground-based operator remotely controls a UAS. The operational area is limited, 

and all flights are planned and coordinated in advance. The level of safety exceeds 

that provided by a single individual holding a commercial pilot’s certificate operating 

a conventional aircraft. The risks associated with the use of a UAS are far lower

from those associated with commercial operations contemplated by Part 61. 

Allowing operational control of a UAS by a private pilot exceeds the present level of 

safety sought by 14 C.F.R. §61.113 (a) and (b). 

14 C.F.R. § 91.103: Preflight Action 

Section 91.103 requires each pilot to preflight an aircraft before flight to insure

the safety of flight. As FAA approved rotorcraft flight manuals will not be used, 

an exemption is requested. However, an equivalent level of safety will be provided. 

The PIC will take all actions, including reviewing weather, airspace, NOTAMS, 

TFRs flight battery requirements, landing and takeoff distances, and performance 

data before commencement of flight. Additionally all UAS will be checked for 

security of attached components prior to every flight.
14 C.F.R. § 91.109: Flight Instruction

Section 91.109 states, “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.” The proposed UASs will be operated utilizing an autopilot 

to maintain controlled flight, and all UASs are programmed to return to a level 

attitude and hover when the controls are returned to a neutral position. Because of 

these built in safety features, dual control is not necessary in order to maintain an 

equivalent level of safety proposed by section 91.109 during training. All training will 

be conducted in a controlled environment as to not cause undue harm or damage to 

persons or property. 

14 C.F.R. §91.119: Minimum Safe Altitudes 

Section 91.119 establishes safe altitudes for operation of civil aircraft. Section 

91.119 provides, in pertinent part, 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 Limitless Drones, LLC requests authority to operate at altitudes only up to 

400 AGL, and not more than 200 above an elevated platform from which filming 

is planned, an exemption is needed to allow such operations. 

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. 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 

Section 91.121 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 a UAS 

may not have a barometric altimeter, but instead reference a GPS altitude, an 

exemption is needed. The operator will achieve an equivalent level of safety,

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

flight. 

14 C.F.R. §91.151: Fuel Requirements for Flight in VFR Condition
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. . . .” The battery powering the proposed UASs provides approximately 

30 minutes of powered flight. Therefore the UAS cannot meet the 30-minute 

reserve requirement in 14 CFR §91.151. In lieu of this requirement the UAS 

flights will be terminated at approximately 25% remaining battery life or better. 

Limitless Drones, LLC believes that an equivalent level of safety can be 

achieved by limiting flights to 25% of battery power, this restriction would be

more than adequate to return the UAS to its pre-determined landing zone from

anywhere in its limited operating range. 

Limitless Drones, LLC is not seeking an exemption for night-time UAS 

operations.

14 C.F.R. §91.405: 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 sections and Part 43 apply only to aircraft with an airworthiness 

certificate, these sections will not apply to Limitless Drones operations. 

Maintenance will be accomplished by the operator in accordance with the 

manufacturers recommended procedures (attached). An equivalent level of safety 

will be achieved because the UASs are limited in size, will carry a small payload and 

operate only for limited periods of time. A preflight inspection will be performed prior 

to every flight to ensure no mechanical issues are present. 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 

flight, and perform any required maintenance. Moreover, the operator is the person 

most familiar with the UAS and best suited to maintain it in an airworthy condition

14 C.F.R. §91.407: Operation after Maintenance

Functional check flights will be conducted away from people or property after any 

maintenance has been accomplished on the UAS. The UAS may be returned to 

service once it has been determined safe for flight.

14 C.F.R. §91.409: Inspections

Due to the small size of the UASs that will be operated by Limitless Drones, LLC 

and limited components, we request that the UASs be exempt from regularly 
scheduled inspections. To meet an equivalent level of safety sought by 14CFR 

91.409, all UASs will be thoroughly inspected prior to flight. Since the UASs will 

have limited components, a thorough inspection can be accomplished before each 

flight, eliminating the need for periodic, time based, or flight-hour based inspection 

cycles.

14 C.F.R. §91.417: Maintenance Records

As previously described, the UASs proposed size and use significantly limits the 

amount of maintenance required. The UASs that will be operated by Limitless 

Drones, LLC are designed by the manufacturer for the average hobbyist to 

purchase and fly with minimal assembly, regular preventative maintenance is limited 

to security of attached components and proper storage of, and charging of batteries.

As such, Limitless Drones, LLC requests an exemption from maintaining 

maintenance records as prescribed by 14CFR 91.417. However, in order to operate 

as safely as possible, Limitless Drones, LLC will keep a running log of all 

maintenance performed on each UAS, and any anomalies noted during operation in 

order to diagnose and prevent problems with the UAS. 

Summary for Publication 

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: 

Limitless Drones, LLC seeks an exemption from the following rules: 

14 CFR Part 21 Subpart H, 14 CFR 61.113(a) and (b), 14 CFR 91.103,

14 CFR 91.109, 14 CFR 91.119, 14 CFR 91.121,14 CFR 91.151, 14 CFR 91.405,

14 CFR 407, 14 CFR 409, 14 CFR 417 to operate commercially small unmanned

vehicles (55 pounds or less) for aerial photography and video for the real estate, 

motion picture, and television industry.

As established by the UAS exemptions already granted by the FAA, allowing 

commercial operations of UASs in the real estate and film industry will enhance 

safety by reducing risk. Conventional film operations, using turbine aircraft, operate 

at low altitudes and present the risks associated with aircraft that weigh thousands of 

pounds, and carry large amounts of fuel. Such aircraft must also fly to and from the film

location. In contrast, a UAS weighing fewer than 55 pounds and powered by batteries 

virtually eliminates all of that risk given the small size and lack of combustible fuel. The 

UAS is carried, and not flown, to a film location. In this regard, the UAS carries no 

passengers or crew, therefore will not expose anyone to the risks associated with 

manned flights. The operation of UASs conducted in accordance with this request will 

provide an equivalent level of safety supporting the grant of the exemption requested 

herein. The UASs operate at slow speeds, close to the ground, and within a limited 

range. As a result, they are far safer than conventional operations conducted with 

turbine helicopters carrying fuel and flying near the ground and people. 

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 to grant Limitless Drones, LLCs requested exemption, 

allowing for Limitless Drones, LLC’s UAS commercial operations for the real estate, 

motion picture and television industry. 

Sincerely,

Justin Rivera, President/Owner 

Limitless Drones, LLC.