April 9, 2015

U. S. Department of Transportation Docket 

Management System 1200 New 

Jersey Ave. SE Washington, 

DC 20590 

Re: Exemption Request Section 333 of the FAA Reform Act and Part 11 of the Federal Aviation 

Regulations from 14 CFR 61.113 (a) & (b); 91.103(b); 91.119; 91.121; 91.151(a); 91.405 (a); 91.407(a) (1); 

91.409 (a) (2); 91.417 (a) & (b). 

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, LifeDrone, LLC, (the Company) a LifeDrone, LLC, (the Company) a startup company 

specializing in first aid training, equipment inspection and the distribution and operation of safety, 

search and rescue, first aid and heart defibulator drones, hereby submits this application for an 

exemption from the listed Federal Aviation Regulations (FARs) to allow 1) testing at the Nevada RenoStead Approved FAA Test Site of its prototype Small Unmanned Aircraft Systems (sUAS) for delivery of 

medical AED units to cardiac victims and 2) eventual testing on specifically-approved golf courses in the 

United States, 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.

There are approximately 14,564 golf courses in the United States. There are more than 7,000 lifethreatening heart attacks sustained by players on these golf courses every year. 

These golf courses are designed to reflect their natural surroundings, with narrow cart paths, flowing 

streams, small bridges, lakes, wooded glens, fenced and walled perimeters, limited vehicle access 

points, and often consist of uneven or soggy ground that prevent EMS vehicles from reaching golf course 

fairways and greens. 

In the vast majority of these cases, the emergency responders arrive more than ten minutes after the 

collapse of the victim. As a result, the survival rate for out-of-hospital cardiac arrest is only 2-3%. In the

case of golf courses, the defibulator almost always arrives too late. 

A large number of federally-sponsored medical studies have shown that the chances of survival of a 

cardiac arrest decrease by 7 – 10% for every minute that passes after the stoppage of the heart. The 

recommended best practice is to apply an AED to restart the heart and begin (or resume) heart 

compressions. In short, survival is largely determined by the time it takes for an AED unit to arrive at the 

scene. 
The AED unit instantaneously reads the patient's heartbeat and instantly determines whether the 

victim’s heart condition is appropriate for an electrical shock. In most cases, this will be a heart with no 

activity where there is no practical alternative to restart the heart. In the vast majority of cases, an 

immediate shock can result in survival and eventual hospital discharge of the patient.

The golfing public is largely a middle-aged, healthy and active group. They are devoted to a mildly 

strenuous outdoor activity on largely inaccessible courses. However, this group is at a very high risk of 

cardiac arrest. In fact, the risk of sudden cardiac arrest is the greatest danger this group faces on a golf 

course. The situation is well illustrated by a recent article by Michael DeMarco, a leading golf industry 

insurance and risk management expert: 

Sudden cardiac arrest is the number one cause of death on the golf course, according to the 

Vascular Noninvasive Screening and Diagnostic Center in London. It’s no wonder, since more 

than half of golf and country club patrons in the U.S. are over the age of 56, according to the 

McMahon Group Database, and 29 percent of members are over 66—the group most at risk for 

potential heart problems. 

In addition to the average age of club members, Dr. Edward A. Palank, a Florida cardiologist, has 

cited other reasons golfers are at high risk (in the October 1999 issue of Golf Digest): 

 • Sudden cardiac arrest is most likely to occur between 6 and 11 a.m., precisely when 

most golfers are out on the course. 

 • Golfers spend from four to six hours a day on the course, often several times a week. 

There is nothing inherently dangerous about golf, but when someone’s heart stops a quarter 

mile out on the fairway, it is very difficult to deliver emergency medical care in time to save a 

life. Because of its size, often remote location and poor accessibility, a golf course can be one of 

the worst places to be when your heart stops." 

According to the Golf Digest article cited above, "There have been a consistent and troubling 

number of cardiac-arrest victims coming from the golf course in my 21 years here" says Dr. 

Robert Tober, medical director of emergency and ambulatory services for Collier County in 

Florida. The logistics of getting to these people means that by the time they arrive at the 

hospital, there’s nothing much left to be done. 

To illustrate the magnitude of the problem, Florida EMTs report that there were four fatalities in 

one year at one multi-course golf resort alone. 
In addition to age, there are other factors listed by the AHA that can increase a person’s risk of 

sudden cardiac arrest and sudden cardiac death (SCD) that may apply to club members and 

guests, including:

 • Previous heart attack with a large area of the heart damaged (75 percent of SCD cases 

are linked to a previous heart attack)

 • Coronary artery disease (80 percent of SCD cases are linked with this disease)

 • Risk factors for coronary artery disease include smoking, family history of cardiovascular 

disease and high cholesterol

 • Prior episode of sudden cardiac arrest 

 • Family history of sudden cardiac arrest

 • Personal or family history of certain abnormal heart rhythms

In addition, nearly 5% of the nation's 400 lightening injuries each year occur on golf courses with 

immediate cardiac arrest the typical outcome of a nearby lightning strike. 

In the majority of these cases, cardiac victims can be successfully revived through layperson use of an 

Automated External Defibrillator (AED) and simple heart compressions. In such instances, the difference 

in AED arrival time determines whether they will survive to enjoy another twenty or thirty years of 

productive life or senselessly die on the course.

These AED units are extremely simple to operate and are intended for use by untrained laypersons and 

bystanders. The advanced units have a video screen and audio display that instruct a layperson to simply 

attach two plastic contacts and press the start button. The AED’s computer evaluates the cardiac rhythm 

and, if appropriate, administers a brief cardiac shock. The golf courses the Company will consider for 

implementing this system have golf carts equipped with GPS, course mapping and video instruction 

systems. These will be adapted to provide victim location and video segments that will describe AED 

delivery and use.

The cost of a golf course providing an individual AED with every cart is prohibitive. The cost of a modern 

AED is approximately $1,000 to $3,000. A typical fleet of 200 carts would result in a one-time cost of 

$200,000 to $600,000. In addition, the expenses of inspecting, charging and maintenance of such a large 

number of units could double the first year cost to over $1.2 million. Our company’s aviation solution is 

priced at approximately $10,000 per year.

The placement of a single AED at a clubhouse or with a sole ranger is quite ineffective. A typical golf 

course is 150 to 200 acres, or one third of a square mile. This generally means a distance from 

Clubhouse to most distant hole of three thousand feet. However, that route is almost never available to 

a rescue vehicle. Instead, a course employee or EMT will need to drive along 4.5 holes (an average of 

400 yards per hole) for a distance of 5,400 feet. 
In a “legal speed” cart averaging 10 mph (with minimal delays or stops), this takes at least 10 minutes to 

reach the scene. At that point, there is very little chance of a cardiac victim surviving the arrest episode. 

On the other hand, the air delivery of an AED from the clubhouse will typically save the cardiac arrest 

patient’s life. At a speed of 50 knots, any location on the golf course can be reached within 45 seconds. 

When liftoff, hover, transition and set down times are taken into account, the sUAS could deliver an AED 

in as little as one to two minutes after emergency notification. When compared with a 10 minute 

average ambulance arrival time (typically to the front door of the Club, not the location on the course), 

the survival rates for sudden cardiac arrest go from roughly 10 percent to over 80 percent, just by 

reducing the delivery time. 

As detailed in this application and the appropriate Manufacturer(s) Flight Manual, the requested 

exemption would permit the operation of an emergency sUAS in airspace that is:

1) a) an FAA-Approved Test Facility at the Reno-Stead Airport, pursuant to Stead’s approved flight 

procedures, or b) eventually a limited number of golf course test sites approved by the FAA under a 

COW; such golf courses consisting of approximately 100 to 200 acres with no public access, except the 

those individuals potentially served by this AED delivery method, 

2) along predetermined flight paths to fixed locations at the test facility or the course layout, 

3) at heights of between 100 feet and 200 feet with a maximum altitude of 400 feet above actual ground 

surface; 

4) at least five miles from any established international airport or two miles from a municipal airport ; 

5) with notification to the FAA prior to any testing activity at Stead, 

6) using a sUAS actively-controlled and monitored by qualified and trained flight personnel, and 

7) following enhanced safety procedures at Stead and each golf course test site approved by the FAA in 

a COW beyond those best practice safety protocols of the Company.

Initial Testing (Stead Airport)

The initial (Phase I) testing of sUAS and the refining of flight procedures will be conducted at the former 

Stead Air Force Base, outside of Reno, Nevada, which is one of six FAA Approved Test Sites in the United 

States. Stead was an active US Air Force Base until 1972 when it became the first BRAC military – civilian 

conversion effort in the United States.

Only after through testing of the equipment, flight procedures and safety protocols will the Company 

apply for a COW for the specific sUVA model and a specific golf course test site(s) that will be used in 

Phase II testing. Testing will only proceed after COW approval of such golf course location and local test 

site rules. 
The current Section 333 Exemption requires line of sight control of the sUAS. This is a requirement that 

will be met at the Stead facility and may also be met at a large number of existing golf courses adjacent 

to 1) elevated clubhouses or medical stations, 2) high rise hotels, 3) observation towers, or 4) other 

vistas with a clear view of the entire course, including the launch box, flight path and specified landing 

zones. 

It is expected that within 5 – 10 years, the capability of collision avoidance technology and the evolution 

of FAA regulations may permit use of semi-autonomous or autonomous drones for similar life safety 

applications. This will require proving autonomous sUAV’s pose negligible risk to flight safety and that 

they enable a lifesaving edge to a large number of cardiac victims who collapse in rural settings, such as 

golf courses, ski resorts or biking events. 

The data garnered by the Company in this initial testing of concept of delivery of life safety equipment 

will further assist in the FAA’s future rulemaking process.

The approval of this limited exemption for delivery of life safety equipment would thereby enhance 

national safety goals 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.

Applicant:

The name and address of the applicant is: LifeDrone, LLC, 1200 Fifth Street, Berkeley, CA 94. Phone (415) 

317-1708 Email: EBrown@LifeDrone.co & ebrown@constructionlawyers.com (aviation and construction 

law site).

Ernest C. Brown, Esq. PE, CEO. Mr. Brown is an aviation/construction attorney and professional civil 

engineer with thirty years of airport design, construction and operational experience. He earned 

engineering degrees from MIT (1975) and the University of California at Berkeley (MS/JD). He has been 

outside counsel for the design and construction of improvements at five major airports in the United 

States, aviation manufacturers, aircraft owners, and heliport operators. 

In 1997, his first wife, Barbara, perished of heart disease on a rural highway in California.

Request for Exemptions:

Regulations from which the exemption is requested: 14 C.F.R. Part 21 14 C.F.R. 45.23(b) 14 C.F.R. 61.113 

(a) & (b) 14 C.F.R. 91.7 (a) 14 C.F.R. 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 C.F.R. 91.151 (a) 14 C.F.R. 91.203 (a) & (b) 14 C.F.R. 91.405 (a) 14 C.F.R. 407 (a) (1) 14 

C.F.R. 409 (a) (2) 14 C.F.R. 417 (a) & (b). 
I. STATUTORY AUTHORITY FOR EXEMPTIONS 

The Federal Aviation Act expressly grants the FAA authority to issue exemptions. This statutory authority 

includes exempting civil aircraft, as the term is defined under §40101 of the Act, including sUASs, from 

the requirement that all civil aircraft must have a current airworthiness certificate. 

The Administrator may grant an exemption from a requirement of a regulation prescribed under 

subsection (a) or (b) of this section or any sections 44702-44716 of this title if the Administrator finds 

the exemption in the public interest. 49 U.S.C. §44701(f) See also 49 USC §44711(a); 49 USC §44704; 14 

CFR §91.203(a) (1). Section 333(b) of the Reform Act assists the Secretary in determining whether sUAS 

may operate in the National Airspace System (NAS) without creating a hazard to the user, the public, or 

a threat to national security. If the Secretary determines that a sUAS may operate safely in the national 

airspace system, the Secretary shall establish requirements for the safe operation of such aircraft in the 

national airspace system. Id. §333(c). 

The Company’s preferred craft are multirotor vehicles, weighing 15 or fewer lbs. including payload. They 

operate under normal conditions at a speed of no more than 50 knots and have the capability to 

vertically take off, hover, and move in the vertical and horizontal planes simultaneously. The sUAS will 

operate only in the Pilot’s visual line of sight at all times and will operate only within the sterile area of 

the golf course links described in the appropriate manufacturer’s Flight Manuals, which will vary 

depending on the actual sUAS chosen for flight testing. The preferred manufacturers of these small 

unmanned systems are SkyCatch (San Francisco) and 3D Robotics (Berkeley, CA). Our preferred Flight 

Manual is that of SkyCatch, filed under previous 333 Exemption Petitions.

Such operations will insure that the sUAS will not create a hazard to users of the national airspace 

system or the public. Reform Act Section 333 (b). Given the small size of the sUAS involved and the 

restricted and sterile environment within which they will operate, the Company’s application falls 

squarely within the zone of safety (an equivalent level of safety) in which Congress envisioned that the 

FAA must, by exemption, allow commercial operations of sUAS to commence immediately. 

Also due to the small size of the sUAS and the low altitudes and restricted areas in which the sUAS will 

operate, approval of the application presents no national security issue. Given the clear direction in 

Section 333 of the Reform Act, the authority contained in the Federal Aviation Act, as amended; the 

strong equivalent level of safety surrounding the proposed operations, and the significant public benefit, 

including enhanced safety and a radical increase in the survivorship of cardiac patients, the grant of the 

requested exemptions is in the public interest. 

There is a general consensus that lifesaving applications of sUAS technology has great application in 

search and rescue and delivery of critical medical supplies. It is believed that the FAA and the public will 

benefit from the ongoing experience of the Company as a result of its proposed test operations at the 

Stead AFB Test Facility and its eventual testing at approved golf course sites that meet the stringent 

criteria set forth in this exemption request. 
Accordingly, the Company respectfully requests that the FAA grant the requested exemption without 

delay. 

II. PUBLIC INTEREST 

This exemption application is expressly submitted to fulfill Congress’ goal in passing Section 333(a) 

through (c) of the Reform Act. This law directs the Secretary of Transportation to consider whether 

certain unmanned aircraft systems may operate safely in the NAS before completion of the rulemaking 

required under Section 332 of the Reform Act. 

By granting an exemption the FAA will fulfill Congress’s intent of allowing a highly specialized sUAS to 

operate with significant safety precautions in an extremely low risk, restricted flight environment. The 

use of sUAS to deliver an AED unit at approved golf courses will likely increase the survival rate of 

players with sudden cardiac arrest from under 10% to over 80%. This delivery technology has the 

potential to save the lives of up to 4,900 cardiac victims every year (70% increase in cardiac survival 

rates at every US golf course). 

A properly equipped sUAS can deliver the AED, a HD Camera, Audio Link and potentially cardiac drugs 

(ranging from aspirin to prescription drugs), allow bystanders to maintain contact with the 911 operator 

and medical personnel, and rapidly access areas that otherwise would be unreachable by ambulance or 

fire department vehicles. The sUAS we propose to fly in this application are under ten pounds, and carry 

no combustible material on board, as opposed to the much larger conventionally powered helicopters 

and small aircraft.

Shifting to sUAS from helicopters presents a marked safety increase for ambulance, helicopter, and 

medical personnel. 

The public is served as they are not exposed to overflight by conventional rotary winged aircraft. 

Lastly, the use of sUAS dramatically decreases the energy and materials used for training and delivery of 

AED units to acute heart patients. The intended sUAS will use rechargeable lithium ion batteries, as 

opposed to fossil fuels burned in operation of small aircraft that are many hundreds of times heavier 

and release large amounts of greenhouse gases. 

III. EQUIVALENT LEVEL OF SAFETY 

The Company proposes that the exemption requested herein apply to sUAS that have the characteristics 

and that operate with the limitations listed herein. These limitations provide for at least an equivalent or 

even higher level of safety to operations under the current regulatory structure because the proposed 

operations represent a safety enhancement to the already safe protocols followed on construction sites 

and imaging and surveying operations conducted with helicopters and other conventional aircraft. 
The Company will be bound by the following limitations when conducting its sUAS operations under an 

FAA issued exemption: 

1. The sUAS will be less than 15 pounds, operating over closed, rural terrain. 

2. Flights will be operated within visual line of sight of a trained pilot. 

3. Maximum total flight time for each operational flight will be under ten minutes. The sUAS calculates 

battery reserve in real time, and the UAS will be retrieved at the scene of the medical recovery. It will 

not be required to return to its ground station. As such, it will maintain at least 50% battery power 

reserve during the entire flight episode. 

4. Flights will normally be operated at an altitude of 100-200 feet AGL, never exceeding a maximum of 

400 feet AGL. 

5. Any flight within 5 miles of any airport will not be flown without notification and approval of the local 

FAA Flight Standards District Office (FSDO) and airport controller. 

6. There will be no operations within 5 miles of an international airport. 

7. There will be no operations within 2 miles of a municipal airport. 

8. Crew for each operation will consist of the sUAS Pilot who will keep the sUAS within his visual line of 

sight at all times and a second CPR trained individual will be dispatched with a second AED to follow the 

sUAS to the location of the cardiac patient for medical assistance and eventually the recovery of the 

sUAS and AED. It is important to train based upon this protocol, so a round trip flight back to the 

origination point is not encouraged or good practice. 

9. The sUAS Pilot will be trained in airframe mechanics and systems, flight operations, and safety 

procedures as detailed in the appropriate Flight Manual for the selected sUAV. 

10. The sUAS will only operate within a Sterile Area designated by the operators of the approved FAA 

Test Facility at Stead or as defined in the COW for the particular golf course test site, using an FAAapproved sUAS aircraft. The operations at Stead will be governed by FAA rules and the Stead facilities’ 

current local rules and regulations for experimental flight operations. A golf course-location specific 

flight manual will be prepared and submitted with each subsequent COW application. Such manuals will 

also require the establishment of a Security Perimeter for the flight operations area at Stead and at any 

approved golf course covered by a COW.

12. At the Stead test facility, a briefing will be conducted in regard to the planned sUAS operations prior 

to each day’s test activities. It will be mandatory that all personnel who will be performing duties within 

the boundaries of the safety perimeter be present for this briefing. 

13. On approval of COW’s for specific golf course test sites, the course operator will appoint three 

individuals who will be fully qualified as operators under the FAA rules and regulations that apply at that 

time. 
14. It is expected that testing and flight operations at Stead will take at least one year and will be largely 

completed when the final FAA regulations regarding operator training will be made available to the UVA 

community. 

15. All onsite personnel at Stead will consent to the UAS flyover on site by waiver, and the operator will 

obtain additional verbal or written consent of all persons who will be allowed within 100 feet of the 

flight operation. 

16. Upon the commencement of emergency response operations at specific golf courses, the players will 

be required to sign an overflight waiver and indemnity and undergo a video briefing on cardiac risk, UAS 

delivery, chest compressions, and safe AED use. 

17. At Stead, the Test Pilot will be trained in operation of the UAS and receive up-to-date information on 

the particular UAS to be operated as required by the Manufacturer(s) flight Manual. 

18. At any approved golf course with an active COW, the approved operators will have been trained in 

operation of the UAS and receive up-to-date information on the particular UAS to be operated as 

required by the Manufacturer(s) Flight Manual. 

19. Written and/or oral permission from the relevant property owners affected by overflight and will be 

obtained in advance. 

20. 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. 

21. In the rare instance that sUAS loses communications, GPS signal, or full power, it will have capability 

to slowly descend into the centerline of the course and land as it emits a loud audible tone that will 

attract the retrieval team to its location. 

IV. DESCRIPTION OF SPECIFIC REGULATIONS 14 CFR 61.113 (a) & (b): 

The Company acknowledges the applicable private pilot privileges and limitations.

The “Pilot in Command” Sections 61.113 (a) & (b) limit private pilots to non-commercial operations. 

Because the sUAS will not carry a pilot or passengers, the proposed operations can achieve the 

equivalent level of safety of current operations by requiring the Pilot operating the aircraft to have (1) 

completed a sUAS flight training course of 100 hours before flying a sUAS (Manufacturer (s) Manual for 

more details) and (2) a Sport Pilot certificate. 

The FAA has previously acknowledged in prior grants of exemption under Section 333 that a commercial 

pilot’s certificate was not necessary to operate a sUAS, but that the FAA could not waive the 

requirement for an FAA-issued pilot’s license. 
A Sport Pilot certificate addresses the FAA’s requirement that the Pilot in command have the requisite 

training and understanding of the National Airspace System, and also ensures that the Pilot is registered 

with the FAA and will not pose a risk to national security. 

The Sport Pilot certificate also does not require the Pilot to undertake the additional cost and time of 5 

additional manned solo aviation flight times that the Private Pilot’s license requires. The risk and cost of 

those hours of solo conventional flight are not expected to translate to skill or competency operating 

the sUAS. Unlike a conventional aircraft that carries the pilot and passengers, the sUAS is remotely 

controlled with no living thing on board. 

The Company’s sUAS is also operated by an autopilot, which greatly reduces the danger of human error.

The area of operation that is ultimately contemplated is controlled and restricted to the confines of an 

established, rural, heavily manicured golf course environment. All flights will be along planned, 

coordinated and preprogramed routes to reach the destination of the golf cart or cell phone that 

emitted the emergency request or a location specified by the operator on a iPad console. In all cases, 

the golf participants will have watched a training video about flight operations, the landing protocol, 

CPR and use of the AED. 

The sUAS to be operated hereunder is less than 15 lbs. fully loaded, carries neither a pilot nor passenger, 

carries no explosive materials or flammable liquid fuels, and operates exclusively within a secured area 

as set out in the Manual. Like other civil aircraft, operations under this exemption will be tightly 

controlled and monitored by the operator, pursuant to the Manual’s requirements, and under the 

requirements and in compliance with local public safety requirements, to provide security for the area 

of operation as is currently done on active construction sites. 

The FAA will have notice of the location of all emergency operations. In most cases, the flights will be 

less than one minute and under 200 feet. This is not airspace that is available to any other aircraft. Due 

to the nature of golf play, there will be no night operations.

The risks associated with the operation of the sUAS are therefore diminished from the level of risk 

associated with commercial operations contemplated by Part 61 when drafted, and allowing operations 

of the sUAS as requested with a Pilot who has met the minimum requirements stated in Section F of the 

Manual achieves the level of safety contemplated by 14 C.F.R. §61.113 (a) & (b). 14 C.F.R. 91.103: 

Preflight Action 

This regulation requires each pilot in command take certain actions before flight to ensure the safety of 

flight. An exemption is needed from this requirement as the Pilot will take separate preflight actions, 

including checking for weather conditions, checking flight battery requirements, checking takeoff and 

landing distances, and all other actions in the Preflight Checklist in the Manual. These actions will 

provide an equivalent level of safety. 
14 C.F. R. 91.119: Minimum Safe Altitudes Section 91.119 establishes safe altitudes for operation of civil 

aircraft. Section 91.119 (d) allows helicopters to be operated at less than the minimums prescribed, 

provided the person operating the helicopter complies with any route or altitudes prescribed for 

helicopters by the FAA. This exemption is for a multirotor craft that flies similarly to a helicopter, with 

vertical take off and vertical landing, which will typically operate at altitudes of 200 AGL, so an 

exemption may be needed to allow such operations. 

The sUAS will never operate at altitude higher than 400 AGL and will be in a restricted area with security 

perimeter, where buildings and people will not be exposed to operations without their pre-obtained 

consent. See Manual for detailed procedures. 6 The equivalent level of safety will be achieved given the 

size, weight, speed of the sUAS as well as the location where it is operated. No flight will be taken 

without the permission of the property owner or local officials. Because of the advance notice to the 

property owner and any onsite personnel as outlined in the Manual, all affected individuals will be 

aware of the planned flight operations. 

Unlike flight operations with aircraft or rotorcraft weighing far more than the maximum 15 lbs. 

proposed herein, our sUAS will not carry flammable fuel. In addition, the low-altitude operations of the 

sUAS will ensure separation between sUAS operations and the operations of conventional aircraft that 

must comply with Section 91.119. 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 sUAS 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 the Manual 

and Safety Check list, confirming the altitude of the launch site shown on the GPS altitude indicator 

before flight. 14 CFR 91.151 (a): Fuel requirements for flight in VFR conditions Section 91.151 (a) 

outlines fuel requirements for beginning a flight in VFR conditions. 

The sUAS will be limited to operations in sterile and controlled environments as outlined in this 

Application and the appropriate Flight Manual, and has a limited range and flight time which require an 

exemption from 14 CFR 91.151(a). 

The battery powering the sUAS provides approximately 35 minutes of powered flight. To meet the 30 

minute reserve requirement in 14 CFR §91.151, sUAS flights would be limited to approximately 5 – 10 

minutes in length. Given the limitations on the sUAS’s proposed flight area within the golf course 

environment, and the location of its proposed operations within a predetermined private or municipal 

recreation area, this may be sufficient. However, a longer time frame for flight in daylight or night VFR 

conditions in very rare situations is requested as a reasonable aspect of this exemption. 

Operating a sophisticated and specialized sUAS, in a tightly controlled area where the golf course 

owners and relevant governmental representatives have signed waivers, with less than 30 minutes of 

reserve fuel (battery power), does not remotely engender the type of risks that Section 91.151(a) was 

intended to alleviate given the tiny size, slow speeds and onboard safety systems of a small sUAS. 
So, limiting sUAS flights to just 10 minutes would reduce the utility for which the exemption will be 

granted. An equivalent level of safety can be achieved by limiting flights to 15 minutes, or enough 

battery reserve to ensure that the sUAS lands at the ground station with at least 20% of battery power 

(as determined by the onboard monitoring system and the Pilot), whichever happens first. 

This restriction would be more than adequate to allow the sUAS to safely land on the golf course 

property and its planned landing zone from anywhere in its limited operating area. Similar exemptions 

have been granted to other operations, including Exemptions 2689F, 5745, 10673, and 10808. 14 CFR 

91.405 (a); 407 (a)(1); 409 (a)(2); 417 (a) & (b).

The Company believes that an exemption from 14 CFR §91.151(a) falls within the scope of prior 

exemptions. See Exemption 10673 (allowing Lockheed Martin Corporation to operate without 

compliance with FAR 91.151 (a)). This Application is more limited in geographic and nature of the 

payload than previously granted sUVS exemptions under Section 333. 

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. 

In view of the fact that these sections and Part 43 apply only to aircraft with an airworthiness certificate, 

these sections should not apply to the Company’s operations. Maintenance will be accomplished by the 

operator pursuant to the flight manual and operating handbook as referenced in the Manufacturer’s 

Manual(s). 

In addition, the equipment will be subject to a periodic inspection by the Company, along with 

operational testing of the AED and charging systems.

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

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

issues arise the sUAS can land immediately and will be operating typically at 100 feet and no higher than 

400 feet AGL. The typical golf cart has a roof that protects the occupants from falling objects and course 

maintenance workers are required to wear OSHA approved hard hats while out of doors. 

As provided in the Manufacturer’s Manual(s), the Pilot will ensure that the sUAS is in working order 

prior to initiating flight, perform required maintenance, and keep a log of any maintenance performed. 

Moreover, the Pilot is the person most familiar with the aircraft and best suited to maintain the aircraft 

in an airworthy condition to provide the equivalent level of safety. 
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: Applicant seeks an exemption from the following 

rules: 14 C.F.R. §21, subpart H; 14 C.F.R 45.23(b);14 C.F.R. §§ 61.113( a) & (b);91.7 (a); 91.9 (b) 

(2);91.103(b);91.109; 91.119; 91.121; 91.151(a);91.203(a) and (b); 91.405 (a); 91.407 (a) (1); 91.409 (a) 

(2); 91.409 (a) (2) and 91.417 (a) & (b) to operate commercially a small unmanned vehicle (55lbs or less) 

in life saving cardiac arrest situations at US Golf Courses. 

Approval of exemptions allowing commercial operations of sUAS in the golf industry may increase the 

chances of survival from 10% to 80%. The delivery time would be one to three minutes, rather than the 

typical ambulance arrival time of ten minutes (to the address of the Clubhouse). There is a decrease 

survivorship of about 10% per minute that the AED is delayed in reaching a victim experiencing cardiac 

arrest. This will decrease the number of careflight emergencies by traditional helicopter response 

services, who are generally unable to scramble to liftoff and get to a patient any sooner than 10 

minutes. This improvement will enhance both public and flight safety while reducing risk. 

The extremely rare manned aircraft and helicopter response to cardiac emergencies creates a greater 

risk because the craft are much larger, have combustible fuel, and carry an onboard human pilot. In 

contrast, a sUAS weighing fewer than 15 lbs. and powered by batteries eliminates virtually all of that risk 

given the reduced mass and lack of combustible fuel carried on board. 

The sUAS will carry no passengers or crew and, therefore, will not expose them to the risks associated 

with manned aircraft flights. The operation of small sUAS, weighing less than 15 lbs., conducted in the 

strict conditions outlined above, will provide an equivalent level of safety supporting the grant of the 

exemptions requested herein, including exempting the applicant from the requirements of Part 21 and 

allowing commercial operations. 

These lightweight aircraft operate at slow speeds, generally 100’ to 150’ AGL, descend slowly and 

operate in a sterile environment and, as a result, are far safer than conventional operations conducted 

with turbine helicopters operating in close proximity to the ground and people. 

Privacy 

All flights will occur either a) over the Reno-Stead Test Facility during approved test hours or b) over 

land owned and controlled by the golf course owners. The flight operations will be conducted with the 

property owners, operators’ and golf player’s prior consent and knowledge. Air delivery of these AED 

devices will be limited to those individuals who have consented through their golf course admission and 

signature to use of the sUAS to bring the AED equipment. 

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

operating capabilities, controlled operating environment and operation within visual line of sight and 

national security – provide more than adequate justification for the grant of the requested exemptions 

allowing commercial operation of applicant’s testing of sUAS for use as an emergency response to 

cardiac arrest situations. 
Please feel free to email or call for further company information.

Sincerely,

LifeDrone, LLC

Ernest C. Brown, Esq. PE

Chief Executive Officer

Ph: (415) 317-1708

eMail: ebrown@lifedrone.co