2001 Airway Ave.

Fort Collins, Colorado 80524

larry.hansen@paravion.com

970-484-6804

October 26, 2015

U.S. Department of Transportation

Docket Management System

1200 New Jersey Ave., SE

Washington, DC 20590

Reference: Exemption request under the provisions of Section 333 of the FAA Reform Act and 

Part 11 of the Federal Aviation Regulations.

Dear Madam or Sir:

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 and 14 CFR Part 11, 

I N. Larry Hansen, President of Century Helicopters Inc. seek an exemption from Federal 

Aviation Regulations listed herein for the operation of DJI Phantom and Inspire Series and 

Parrot Bebop series UASs. Due to manufacturers continuing model number changing, it is in 

the best interest of the FAA and our company to apply for this exemption by referring to a 

“series” rather than a specific model number. This reduces the necessity to continually reapply 

for an exemption due to a simple model change of the UAS although we are aware of the 

necessity to register with the FAA each UAS prior to commercial operations. Currently the DJI 

Phantom is at model 3 and the DJI Inspire is at model 1. The Parrot is presently the model 

name Bebop. Please refer to the attached specifications.

This request for exemption is in support of an application for a Commercial Certificate of 

Authorization to use the above listed UASs in various operations within the US to include aerial 

photography, aerial survey, patrolling and aerial inspection, search and rescue, forest and 

wildlife management, agriculture monitoring, livestock management, mapping, and real estate 

video imaging. An approval of this exemption by the FAA will provide a reduction in 

environmental and public impact through the use of small UAS equipment in place of large 

rotorcraft and airplanes commonly used to accomplish the same tasks. As a result, the 

reduction in the impact of these activities is in the best interest of the public.

Each of the DJI and Parrot UAS weigh far less than the maximum 55 pounds allowed by current 

regulation. Also, the maximum speed capability is less than 35 miles per hour. The DJI and 

Parrot series UASs are very small, popular quadcopters equipped with high resolution video 
imagery systems, making them the ideal airborne platform for many projects requiring detailed

viewing of objects and terrain without inducing undo harm to persons or property on the ground. 

Unlike conventional manned aircraft, their noise footprint is almost undetectable when flown at 

reasonable altitudes and distances from sensitive areas.

Century Helicopters, Inc. requests to be exempt from the following Title 14 CFR Regulations

due to the lack of applicability to small UASs and their operations. Each regulation has 

previously, many times over, been approved as exempt for Small UAS operations (supporting 

data) and therefore further deliberation is kept to a minimum.

 

14 CFR 21(h)

14 CFR 45.23

14 CFR 61.113

14 CFR 91.9(b)(2)

14 CFR 91.119(c)

14 CFR 91.121

14 CFR 91.151(a)

14 CFR 91.203(a) and (b)

14 CFR 91.405(a)

14 CFR 91.407(a)(1)

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

14 CFR 91.417(a) and (b)

14 CFR 21 Subpart H—Airworthiness Certificates

Due to the size and nature of these UASs, we feel the necessity to pursue a Type Certificate is 

beyond the scope of this regulation.

45.23 Display of marks; general

Due to the small size of these UASs, it may not be possible to maintain the 2” minimum height 

for required markings. Therefore, the markings shall be as large as space allows.

61.113 Private pilot privileges and limitations: Pilot in command

Due to the UASs being unable to carry persons or property, the pilots need not be commercially 

rated to conduct our planned operations. 

91.9 Civil aircraft flight manual, marking, and placard requirements

Due to the size and limited payload capability, it would be impractical to transport a POH or 

other documentation on board the UAS. Therefore, these items shall be maintained at the base 

station.

91.119 Minimum safe altitudes: General

Since UAS operations are limited to a maximum of 400 feet AGL, the intent of this regulation 

does not apply.

91.121 Altimeter settings

These UAS’s are not equipped with a barometric altimeter. The altitude is reported through the 

means of GPS or other electronic devices located on the UAS. There are no means to adjust or 

calibrate these devices.
91.151 Fuel requirements for flight in VFR conditions

These UASs do not require fuel as they operate on battery power. They only have an 

endurance of 15 to 25 minutes. Each is equipped with a battery level indication and a low 

battery warning system visible by the pilot on the base station display. Due to the limited 

endurance of these craft, this regulation in not applicable.

91.203 Civil aircraft: Certifications required

Due to the size and nature of these UASs, we feel the necessity to pursue a Type Certificate is 

beyond the scope of this regulation. A registration certificate shall be maintained at the base 

station.

91.405 Maintenance required - thru 91.417 Maintenance records

Due to the small size and nature of the UAS, the scope of these regulations is far broader than 

necessary to operate these craft in a safe manner. The UASs shall be maintained in 

accordance with each manufacturer’s recommendations. All maintenance activities shall be 

recorded and the record shall be kept at the base station.

All commercial operations will be conducted under day VFR conditions in accordance with 

current FAA regulations by a US FAA licensed pilot with the necessary training to safely

accomplish the assigned task. A commercially rated pilot is not required as no persons or 

property are being transported. Preparation for each flight will include a preflight inspection of 

the UAS as recommended by the UAS manufacturer and a review of the current status of the 

weather and airspace in which the UAS is to be operated. An APP such as ForeFlight or other 

similar product will be installed on each viewing device used to operate the UAS. This APP will 

provide information on airspace restrictions such as airspace class, TFRs, airports, congested 

airspace, and restricted airspace. It will also provide current and forecasted weather and other 

essential information necessary to conduct a safe flight.

Each UAS to be covered under this exemption is equipped with several safety devices to help 

prevent uncontrolled flight that may create an unsafe situation. Such items are low battery 

warning systems, return to home capability, auto takeoff and landing capability, and restrictive 

altitude and location systems all of which provide a degree of safety unmatched by current 

manned aircraft.

Best Regards,

N. Larry Hansen

President

Century Helicopters, Inc.
DJI Phantom 3
DJI Inspire 1
Parrot Bebop