UNITED STATES OF AMERICA DEPARTMENT OF TRANSPORTATION FEDERAL 

AVIATION ADMINISTRATION WASHINGTON, DC 

IN THE MA TIER OF THE PETITION FOR EXEMPTION OF: US DRONE GROUP, LLC, 

WILLIAM W. WILLIAMS, MANGING MEMBER, FOR AN EXEMPTION SEEKING 

RELIEF FROM THE REQUIREMENTS OF TITLE 14 OF THE CODE OF FEDERAL 

REGULATIONS SECTIONS: 

14 CPR Part 21 Subpart H 

14 C.P.R. 45.23(b) 

14 CPR 61.113 (a) & (b) 

14 C.P.R. 91.7 (a) 

14 CPR 91.9 (b) (2) 

14 C.P.R. 91.103 

14 C.P.R. 91.109 

14 C.F. R. 91.119 

14 C.P.R. 91.121 

14 CPR 91.151 (a) 

14 CPR 91.203 (a) & (b) 

14 CPR 91.405 (a) 

14 CPR 407 (a) (1) 

14 CPR 409 (a) (2) 

14 CPR 417 (a) & (b) 

14 CPR 61.3 (a) 

14 CPR 61.23 (a) 

CONCERNING COMMERCIAL OPERATION OF 2 DJI PHANTOM 3 PROFESSIONAL 

SMALL AIRCRAFT SYSTEMS (sUAS) PURSUANT TO SECTION 333 OF THE FAA 

MODERNIZATION AND REFORM ACT OF 2012 (PUBLIC LAW 112-95) and 14 C.P.R. Part 

11.81 

Submitted On September 12,2015, US Drone Group, LLC, William W Williams, 1 Hall Manor, 

Alpharetta, GA 30022. 404-433-1509 

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EXEMPfiON REQUEST 

US Drone Group, LLC a Georgia corporation seeks exemption from the requirements of the 

following sections of Title 14 Code of Federal Regulations, Aeronautics and Space in order to 

operate small Unmanned Aircraft Systems (sUAS) pursuant to Section 333 of the FAA 

Modernization and Reform Act of2012 (FMRA). 

14 CFR Part 21 Subpart H 

14 C.P.R. 45.23(b) 

14 CFR 61.113 (a) & (b) 

14 C.P.R. 91.7 (a) 

14 CFR 91.9 (b) (2) 

14 C.P.R. 91.103 

14 C.P.R. 91.109 

14 C.F. R. 91.119 

14 C.P.R. 91.121 

14 CFR 91.151 (a) 

14 CPR 91.203 (a) & (b) 

14 CFR 91.405 (a) 

14 CFR 407 (a) (1) 

14 CFR 409 (a) (2) 

14 CFR 417 (a) & (b) 

14 CFR 61.3 (a) 

14 CFR 61.23 (a) 

This exemption will permit US Drone Group, LLC to operate Unmanned Aircraft Systems 

(UAS) for the commercial purposes of conducting aerial video and photography of construction 

sites, cell towers, real estate, search and rescue operations and agriculture inspection over certain 

areas of the United States. 

INTRODUCTION OF THE PETITIONER 

William W. Williams has been an air transport pilot (ATP) for over twenty-five years and is 

currently employed full time by a major airline. He has over 13,000 hours of flight time and 

possesses the following ratings and certifications: 

Airline Transport Pilot 

Airplane Multiengine Land 

Type Ratings: B-727, B-757, B-767, B-747-400, L-382 

Commercial Privileges 

Airplane Single Engine Land 

Radiotelephone Operator Permit: Restricted 

Medical Certificate: FAA Class I 

Mr. Williams successfully completed International Air Transport Association (IA TA) 

Operational Safety Auditor and Lead Auditor Training with ARGUS/PROS 

The objective of US Drone Group, LLC is to provide high quality imaging and aerial data 

collection for a variety of commercial, public, and residential uses, specifically targeting: 

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• Construction site progress inspections 

• Cell tower and crane inspections 

• Agriculture monitoring and air sampling 

• Real-estate marketing 

• Search & Rescue Operations 

BASIS FOR PETITION 

Petitioner, US Drone Group, LLC, pursuant to the provisions of the Federal Aviation 

Regulations (14 C.F.R. § 11.61) and the FAA Modernization and Reform Act of2012(FMRA), 

Section 333, Special Rules for Certain Unmanned Aircraft Systems, hereby petitions the 

Administrator to commercially operate two DJI Phantom 3 Professional UASs in the National 

Airspace System (NAS), and for an exemption from the following: 

14 CFR Part 21 Subpart H 

14 C.P.R. 45.23(b) 

14 CFR 61.113 (a) & (b) 

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 91.405 (a) 

14 CFR 407 (a) (1) 

14 CFR 409 (a) (2) 

14 CFR 417 (a) & (b) 

14 CFR 61.3 (a) 

14 CFR 61.23 (a) 

DESCRIPTION OF RELIEF SOUGIIT FOR SPECIFIC REGULATIONS 

14 C.F.R. Part 21, Subpart H: Airworthiness Certificates 14 C.F.R. §91.203 (a) (1) 

Subpart H, entitled Airworthiness Certificates, establishes the procedural requirements for the 

issuance of airworthiness certificates as required by FAR §91.203 (a) (1). Given the size and 

limited operating area associated with the aircraft to be utilized by the Applicant, US Drone 

Group, LLC, an exemption from Part 21 Subpart H 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 aircraft 

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 

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UAS. In all cases, an analysis of these criteria demonstrates that the UAS operated without an 

airworthiness certificate, in the 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. 

The sUAS to be operated hereunder meets the definition of Section 333 (6) being less than the 55 

lbs. fully loaded, carries neither a pilot nor passenger, carries no explosive materials or 

flammable liquid fuels, and operates within an area with written or verbal approval. The sUAS 

will not achieve a speed exceeding 87 knots (100 miles per hour). The maximum speed for the 

DJI Phantom 3 is 16 meters per second or 35.791 miles per hour. 

Unlike other civil aircraft, operations under this exemption will be tightly controlled and 

monitored by the operator, and in compliance with both Federal and local public safety 

requirements. The FAA will have advance notice of all operations with the required filing of a 

Certificate of Waiver. These safety enhancements, which are already greater than currently 

required by hobbyist, provide a greater degree of safety to the public and property owners than 

conventional operations conducted with airworthiness certificates issued under 14 C.P.R. Part 

21, Subpart H. 

Lastly, application of these same criteria demonstrates that there is no credible threat to national 

security posed by the UAS, due to its size, speed of operation, location of operation, lack of 

explosive materials or flammable liquid fuels, and inability to carry a substantial external load. 

14 C.F.R. § 45.23 (b). Marking of the Aircraft 

The regulation requires: 

When marks include only the Roman capital letter "N" and the registration number is displayed 

on limited, restricted or light-sport category aircraft or experimental or provisionally certificated 

aircraft, the operator must also display on that aircraft near each entrance to the cabin, cockpit, or 

pilot station, in letters not less than 2 inches nor more than 6 inches high, the words "limited," 

"restricted," "light-sport," "experimental," or "provisional," as applicable. Even though the UAS 

will have no airworthiness certificate, an exemption may be needed as the UAS will have no 

entrance to the cabin, cockpit or pilot station on which the word "Experimental" can be placed. 

Given the size of the sUA V, two-inch lettering will be impossible. The word "Experimental" will 

be placed on the fuselage in compliance with §45.29 (f). The equivalent level of safety will be 

provided by having the sUAV marked on its fuselage as required by §45.29 (f) where the pilot, 

observer and others working with the sUA V will see the identification of the UAS as 

"Experimental." Additionally, "If Found Return To" instructions will be affixed to the UAS. 

The FAA has issued the following exemptions to this regulation to Exemptions Nos. 10700, 

8738, 10167 and 10167A. 

14 C.F.R. § 61.113 (a) & (b): Private Pilot Privileges and Limitations: Pilot in Command. 

Sections 61.113 (a) & (b) limit private pilots to non-commercial operations. Because the UAS 

will not carry a pilot or passengers, the proposed operations can achieve the equivalent level of 

safety of current operations by requiring the PIC operating the aircraft to have specific training to 

the sSUA along with in house training to current FAA regulations regarding our NAS and civic 

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

remotely controlled with no living thing on board. The area of operation is controlled and 

restricted, and all flights are planned and coordinated in advance. These types of sSUAs are 

currently being flown by hobbyist without any certifications. The level of safety provided by the 

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requirements included in the US Drone Group, LLC Manual will exceed that provided by a 

single individual currently operating one of these sSUAs as a hobbyist. The risks associated with 

the operation of the sUAS are significantly diminished from the level of risk associated with 

conventional manned operations contemplated by Part 61 when drafted, that allowing operations 

of the sUAS as requested with specific training as the operator exceeds the present level of safety 

achieved by 14 C.P.R. §61.113 (a) & (b) or what is allowed currently by hobbyist. 

14 C.F.R. §91.7(a): Civil aircraft airworthiness. The regulation requires that no person may 

operate a civil aircraft unless it is in airworthy condition. As there will be no airworthiness 

certificate issued for the aircraft, should this exemption be granted, no FAA regulatory standard 

will exist for determining airworthiness. Given the size, speed and flight restrictions placed on 

the UAS along with the preflight and maintenance required, an airworthiness certificate is not 

needed. The DJI Phantom 3will be in an airworthy condition, prior to every flight, by ensuring 

that the sUAS is in compliance with the operating documents (i.e., Monthly Maintenance Log, 

DJI Training Manual and 

DJI Instruction Manual), and that the aircraft is in a condition safe for flight. 

14 C.F.R. § 91.9 (b) (2): Civil Aircraft Flight Manual in the Aircraft. Section 91.9 (b) (2) 

provides: No person may operate a U.S .-registered civil aircraft ... (2) For which an Airplane or 

Rotorcraft Flight Manual is not required by §21.5 of this chapter, unless there is available in the 

aircraft a current approved airplane or Rotorcraft Flight Manual, approved manual material, 

markings, and placards, or any combination thereof. The sUAS, given its size and configuration 

has no ability or place to carry such a flight manual on the aircraft, not only because there is no 

pilot on board, but because there is no room or capacity to carry such an item on the aircraft. The 

equivalent level of safety will be maintained by keeping the flight manual at the ground control 

point where the pilot flying the sUAS will have immediate access to it. The FAA has issued the 

following exemptions to this regulation: Exemption Nos. 8607,8737, 8738,9299, 9299A, 9565, 

9565B, 10167, 10167A, 10602,32827, and 10700. 

14 C.F.R. § 91.103: Preflight action This regulation requires each pilot in command to take 

certain actions before flight to insure the safety of flight. As FAA approved rotorcraft flight 

manuals will not be provided for the aircraft an exemption will be needed. An equivalent level of 

safety will be provided as set forth in the following Operator Preflight checklist. The Operator 

will take all actions including reviewing weather, flight battery requirements, landing and takeoff 

distances and aircraft performance data before initiation of flight. 

Preflight Procedures 

• Ensure remote controller, Intelligent Flight Battery and mobile device(s) are fully 

charged. 

• Propellers are mounted correctly and firmly 

• Micro SD card inserted, if required 

• Gimbal is functioning normally 

• Motors can start and are functioning normally 

• The DJI SO app is successfully connected to the aircraft and successfully checked. 

• Ensure compass calibration is completed. 

5 
Right Test 

• After enduring that all ground systems are functioning normally, initiate flight test. 

• In a secure area free from people, equipment, and structures perform a low altitude (less 

than lOft) take off, hover and land flight test. 

• Verify accuracy of altitude readout 

• Ensure emergency Return to Home (RTH) function is programmed and armed. 

• After successful flight test commence operational flight. 

14 C.F.R. §91.109: Flight instruction: Section 91.103 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. sUASs and remotely piloted aircraft, by their design 

do not have fully functional dual controls. Right 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. See Exemption Nos.5778K & 9862A. 

The equivalent level of safety provided by the fact that neither a pilot nor passengers will be 

carried in the aircraft and by the size and speed of the aircraft. The safety of those on the ground 

is protected by the fact that each structure that is the subject of the documented flight will have 

verbal or written authorization and will be conducted in a defined area where we can limit nonparticipating individuals. 

14 C.F.R. §91.119: Minimum Safe Altitudes (MSA): 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. As this exemption is for a sUAS that is a 

helicopter and the exemption requests authority to operate at altitudes up to 400 AGL. The UAS 

will never operate at higher than 400 AGL. It will, however, be operated in a restricted area with 

security perimeter, where buildings and people will not be exposed to operations without their 

pre-obtained consent. The equivalent level of safety will be achieved given the size, weight, 

speed of the UAS 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 participants in the air data collection and filming activity, all affected individuals will 

be aware of the planned flight operations. Compared to flight operations with aircraft or 

rotorcraft weighting far more than the maximum 55lbs. proposed herein and the lack of 

flammable fuel, any risk associated with these operations is far less than those presently 

presented with conventional aircraft operating at or below 400 AGL in other fixed wing and 

rotorcraft operations. In addition, the low altitude operations of the sUAS will ensure separation 

between these small-UAS 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 Operating 

6 
Manual and Safety Check list, confirming the altitude of the launch site shown on the GPS 

altitude indicator before flight. 

14 C.F.R. § 91.151(a): Fuel Requirements for Flight in VFR Conditions 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; or Section 91.151(b) that prohibits a from beginning "a flight in a rotorcraft 

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, to fly after 

that for at least 20 minutes." The battery powering the sUAS provides approximately 23 minutes 

of powered flight. The battery life on the DJI Phantom 3 will not accommodate the flight time 

required to meet this fuel requirement. Given the strict limitations on the UAS's proposed flight 

area and the location of its proposed operations within a predetermined area, the requirements of 

Section 91.151 (a) and (b) are not necessary to achieve a safe flight profile. Applicant believes 

that an exemption from 14 CFR §91.151(a) falls within the scope of prior exemptions. Applicant 

believes that an equivalent level of safety can be achieved by limiting flights to 20 minutes or 

25% of battery power whichever happens first. This restriction would be more than adequate to 

return the sUAS to 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 C.F.R. §91.203 (a) and (b): Carrying Civil Aircraft Certification and Registration The 

regulation provides in part: (a) Except as provided in§ 91.715, no person may operate a civil 

aircraft unless it has within it the following: (1) An appropriate and current airworthiness 

certificate .... (b) No person may operate a civil aircraft unless the airworthiness certificate 

required by paragraph (a) of this section or a special flight authorization issued under §91.715 is 

displayed at the cabin or cockpit entrance so that it is legible to passengers or crew. The UAS 

fully loaded weighs no more than 55 lbs. and is operated without an onboard pilot. As such, there 

is no ability or place to carry certification and registration documents or to display them on the 

sUAS. An equivalent level of safety will be achieved by keeping these documents at the ground 

control point where the pilot flying the sUAS will have immediate access to them, to the extent 

they are applicable to the sUAS. The FAA has issued numerous exemptions to this regulation. A 

representative sample of other exceptions includes Exemption Nos. 9565,9665,9789, 9789A, 

9797, 9797A, 9816A, and 10700. 

14 C.F.R. §91.405 (a); 407 (a) (1); 409 (a) (2); 417(a) & (b): 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 the applicant. Maintenance will be accomplished by the operator 

pursuant to the flight manual and operating handbook provided by DJI and further developed by 

Atlanta Unmanned Aircraft Systems (See Maintenance Required Petition for Relief Section 14 

CFR 91.405 (a)). An equivalent level of safety will be achieved because these small UASs are 

7 
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 UAS can land immediately and will be operating 

from no higher than 400 feet AGL. As provided in the Manual, the operator will ensure that the 

VAS is in working order prior to initiating flight, perform required maintenance, and keep a log 

of any maintenance performed. Moreover, the operator 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. 

14 C.F.R. §61.3 Requirement for certificates, ratings, and authorizations. These regulations 

require that no person may serve as a required pilot of a civil aircraft unless that person holds a 

current pilot certificate in accordance §61.19; §61.77; §61.17; or §61.29(e). Under this grant of 

exemption, a PIC must hold either an airline transport, commercial, private, recreational, or sport 

pilot certificate. 

§61.23 Medical certificates: Requirement and duration. This regulation requires medical 

certificates for all pilots operating in the NAS. Applicant is seeking relief to the extant that all 

PICs will hold a current FAA airman medical certificate or a valid U.S. driver's license issued by 

a state, the District of Columbia, Puerto Rico, a territory, a possession, or the Federal 

government. 

PUBLIC INTEREST 

The integration of sUAS in the National Airspace System (NAS) and the proliferation of its 

commercial application is based on its inherent safety, multi-faceted applications and 

significantly reduced cost compared to larger fixed wing and rotor aircraft . Historically, 

rotorcraft and fixed wing aircraft have been able to accommodate some of the aerial data 

collection methodologies required by various industries. They are, however, very expensive and 

cannot accommodate all the aerial data collection requirements. Proximity to the subject is 

crucial for viable data collection, particularly with respect to safety inspections. the following 

applications would benefit significantly from UAS based aerial applications. 

• 

• 

i 

• 

• 

Construction site progress inspections 

Cell tower and crane inspections 

Agriculture monitoring and air sampling 

Real-estate marketing 

Search & Rescue Operations 

Construction sites and cell tower/crane assembly and inspection. These industrial disciplines 

and applications are inherently dangerous. In order to ensure the highest degree of safety 

possible the assembly and construction of these devices requires meticulous attention to detail. 

A significant contribution to safety would be provided by conducting close proximity inspections 

of the assembly, construction, and wear and tear of this equipment. 

Agriculture presents its own set of criteria for relevant aerial data collection. Maintaining the 

health and safety of agriculturally based food supplies requires monitoring crops for both ground 

and airborne insect infestation. The low altitude collection of air samples contributes 

significantly to relevant data collection in order to better address these challenges. 

8 
Real Estate marketing has successfully used airborne photography to provide a much more 

complete assessment of property. Due to the cost of using larger fixed wing and rotor craft it has 

been cost prohibitive for use on smaller properties. UAS video applications would expand the 

marketing options for property owners and stimulate real estate sales across a wider spectrum of 

properties. 

Search and rescue has historically utilized airborne surveillance to expeditiously locate victims, 

provide damage assessment, provide direction to first responders, assess efficacy of remediation 

efforts and increase overall situational awareness. The safe, cost effective and rapid deployment 

of sUAS would provide a level of data collection not before possible and enhance the 

effectiveness of the rescue efforts. 

The use of conventional rotorcraft and fixed wing aircraft in these disciplines would be 

extremely dangerous. Using manned aircraft at extremely low altitudes poses a threat to the 

public through potential catastrophic loss or crash of such a large aircraft loaded with explosive 

hydrocarbon based fuel. The sUAV is a much safer, more economical and viable tool to address 

the data collection requirements of these disciplines. 

The benefit of granting theses exemption falls within the intended relief of Section 333(c) of the 

FAA Modernization and Reform Act of 2012 to safely integrate sUA V onto the National 

Airspace System while promoting appropriate safe commercial operations. 

SAFETY 

This exemption request for use of sUAS is subject to Extensive Operational and Safety 

Measures. Limitations and conditions to which US Drone Group, LLC. agrees to be bound when 

conducting commercial operations under a FAA issued exemption include at a minimum: 

Safety Requirements 

1. The sUAS Pilot in Command (PIC) shall possess either an airline transport, commercial, 

private, recreational, or sport pilot certificate. 

2. The PIC will hold a current FAA airman medical certificate or a valid U.S. driver's 

license issued by a state, the District of Columbia, Puerto Rico, a territory, a possession, 

or the Federal government. 

3. The PIC shall be trained in the operation of the specific make and model of the sUAS 

being piloted and successfully completed all training required. The PIC shall have 

accumulated and logged, in a manner consistent with 14 CPR 61.51 (b), a minimum of 

five hours as sUAS pilot operating the make and model of sUAS to be utilized for 

operations under the exemption. Three take-offs and three landings in the preceding 90 

days must be accomplished to maintain currency. The PIC shall have accumulated and 

logged, in a manner consistent with 14 CFR 61.51 (b), a minimum of 200 flight cycles 

and 25 hours of total time as a sUAS rotorcraft pilot and at least five hours logged as a 

sUAS pilot with a similar sUAS (multi rotor or helicopter). Prior documented flight 

experience that was obtained in compliance with applicable regulations may satisfy this 

requirement. Training, proficiency, and experience-building flights can also be conducted 

9 
under this grant of exemption to accomplish the required flight cycles and flight time. 

During training, proficiency and experience-building flights, all persons not essential for 

flight operations are considered non-participants, and the PIC must operate the sUAS 

with appropriate distance from non-participants in accordance with 14 CFR 91.119. 

4. The sUAS Safety Observer (SO) shall meet all training requirements and be responsible 

for all of his/her duties as set forth by the US Drone Group, LLC sUAS Operating 

Manual. The PIC and SO will be designated before each flight. 

5. The minimum crew for each flight operation will consist of the sUAS PIC and SO. The 

PIC and the SO shall always be within visual line of sight (VLOS) of each other and in 

direct verbal communications at all times. 

6. Safety Briefings shall be conducted before each day's activities to include, but not limited 

to the designated roles of the PIC and SO. 

7. All sUAS flown under this exemption shall be less than 55 pounds including aircraft and 

payload. This exemption requests permission only with respect to the specific use of the 

DJI Phantom 3 Professional sUAS which weigh less than 3 pounds including payload. 

8. The radio frequency spectrum used for operation and control of the sUAS shall comply 

with the Federal Communications Commission (FCC) or other appropriate government 

oversight agency requirements. 

9. Maximum speed shall be less than 50 knots. 

10. The sUAS shall be designed, should it lose communications or lose its GPS signal, to 

return to a pre-determined location (Return To Home, RTH feature) within the 

Operations Area and land or be recovered in accordance with the US Drone Group, LLC 

sUAS Operating Manual. 

11. All sUAS shall be maintained in accordance with the manufacturer's recommendations 

and the US Drone Group, LLC. sUAS Operating Manual and Inspection Program. 

12. US Drone Group, LLC. will document and maintain a record of the sUAS maintenance, 

preventative maintenance, alterations, and status of replacement, overhaul component 

parts, and the total time in service of the sUAS. These records will be maintained at the 

principle base of operations for the life of the aircraft or as required by Federal Aviation 

Regulations. 

13. US Drone Group, LLC. shall comply with all manufacturer Safety/Service Bulletins or 

equivalent pertaining to the sUAS aircraft. The PIC shall perform a preflight inspection 

of the s UAS, controller and ground station prior to each flight to ensure it is operational 

with no discrepancies. If the preflight inspection reveals discrepancies, repairs or 

maintenance shaH be performed prior to flight. The sUAS will only be operated if all 

systems are operating per manufacture's specifications and in a discrepancies free 

condition. 

14. Maintenance or repairs that may affect the sUAS operation or flight characteristics shall 

undergo a functional test flight when required in accordance with manufacture's 

recommendations and the US Drone Group, LLC. sUAS Operating Manual. This 

functional test flight shall be recorded in the sUAS's records. If the functional test flight 

is completed successfully, the sUAS can return to service by the PIC. 

15. US Drone Group, LLC. shall follow the manufacturer's sUAS maintenance, overhaul, 

replacement, inspection, and life limit requirements. When not provided by the 

manufacturer, aircraft maintenance, component, overhaul, replacement, and inspection 

10 
maintenance requirements shall be established and included in the US Drone Group, 

LLC. Operating Manual and Inspection Program. 

16. All sUAS shall be identified by serial number, registered in accordance with 14 CFR Part 

47, and have identification (N-Number) markings in accordance with 14 CFR Part 45, 

Subpart C, except with respect to the size of the markings. Markings shall be as large as 

practical. Additionally, there will be the name address and telephone number of US 

Drone Group, LLC. and "If Found Return To" instructions affixed to the sUAV. 

17. All required permissions and permits shall be obtained from territorial, state, county or 

city jurisdictions, including local law enforcement or other appropriate governmental 

agencies. At least three days before a scheduled operational flight, US Drone Group, 

LLC. shall submit a written plan of activities to the local Flight Standards District Office 

(FSDO) with jurisdiction over the area of the proposed flight. The 3 day notification may 

be waived with the concurrence of the FSDO. The plan of activities shall include at least 

the following: 

• Dates and times for all requested flights. 

• Name and phone number of US Drone Group, LLC. sUAS Flight Operations 

representative. 

• Name, certificate and phone number of PIC responsible. 

• Make, model and N-Number of sUAS to be used. 

• Statement from US Drone Group, LLC. that it will be operating on approved 

privately owned and operated property; the list of those who gave permission shall be 

made available to the inspector upon request. 

• Description of flight activity, including maps or diagrams of any area over which 

flights will be conducted, the relationship of that area to any nearby city, town, etc., 

and the altitudes essential to accomplish the operation. 

• Signature of the exemption-holder or representative 

18. Documents required under 14 CFR 91.9 and 91.203 shall be readily available to the PIC 

anytime the aircraft is in operation. These documents shall be made available to the 

Administrator or any law enforcement official upon request. US Drone Group, LLC shall 

obtain an Air Traffic Organization (ATO) issued Certificate of Waiver or Authorization 

(COA) prior to conducting any operations under this grant of exemption. US Drone 

Group, LLC shall also request a Notice to Airman (NOT AM) not more than 72 hours in 

advance, but not less than 48 hours prior to the operation. US Drone Group, LLC shall 

obtain the consent of all persons involved in the operation and ensure that only 

consenting persons be allowed within 500 feet of the Operations Area. 

19. The sUAS shall not operate within 5 nautical miles of the geographic center of any 

airport as denoted on the current FAA published aeronautical chart unless a letter of 

agreement with that airport's management is obtained, and the operation is conducted in 

accordance with a NOT AM as required by the operator's COA. This letter of agreement 

with the airport management shall be made available to the Administrator upon request. 

20. The sUAS will only operate within the lateral boundaries of approved privately owned 

and operated property. An Operations Area within those boundaries will be established 

for each flight. These areas will be free of unnecessary hazards or risks and 

nonparticipating personnel. The sUAS shall only operate within a pre-defined Operations 

Area that shall be thoroughly inspected by the PIC for buildings, overhangs, obstacles, 

11 
wires, poles, people, vehicles, sun angle, shadows, glare, reflective surfaces, clouds, 

smoke, and terrain among other potential hazards. 

21. Flights shall be conducted during day visual meteorological conditions (VMC) only. In 

addition, the sUAS shall not be operated less than 500 feet below or less than 2,000 feet 

horizontally from a cloud or when the visibility is less 3 statute miles from the PIC. 

sUAS operations shall not be conducted during night, as defined in 14 CFR 1.1. iii) 

Flights shall not be conducted under special visual flight rules (SVFR). 

22. Flights shall be operated at an altitude at or below 400 feet AGL, as indicated by the 

procedures specified in the US Drone Group, LLC. Operating Manual. 

23. The PIC shall be prohibited from operating the sUAS from any moving device or vehicle. 

24. The sUAS shall be operated within VLOS of the PIC. 

25. The PIC shall maintain VLOS without the aid of telescopes, cameras or other devices. 

The PIC shall maintain VLOS with their own vision, which includes the use of 

eyeglasses or corrective lenses as specified on the PIC's medical certificate. 

26. The sUAS shall remain clear and yield the right of way to manned operations and 

activities at all times including, but not limited to, ultralight vehicles, parachute activities, 

parasailing activities, hang gliders, etc. 

27. US Drone Group, LLC. will require the PIC and the SO to have successfully completed a 

qualifications process which will include ground and flight training, as outlined in the US 

Drone Group, LLC. Operating Manual. I. The PIC's primary responsibility while in flight 

is the safe operation of the sUAS . J. The PIC and the SO may not switch roles during the 

flight. 

28. DJI Phantom 3 Professional operations shall be completed within 20 minutes of flight 

time or with 25% power remaining whichever occurs first. If the flight time exceeds 25% 

of battery life an aural warning shall sound signifying that the aircraft must be landed 

immediately. 

MAINTENANCE 

14 CPR 91.405 (a) - Maintenance Required. Each owner or operator of an aircraft- (a) 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. 

This section and Part 43 apply only to aircraft with an airworthiness certificate, therefore these 

sections will not apply. 

In the absence of regulatory provisions dealing with sUAS operation for maintenance required, 

US Drone Group, LLC will establish the sUAS Operating Manual, Inspection Program and 

Manufacturers Maintenance Recommendations for maintenance required. 

1. Maintenance will be accomplished by US Drone Group, LLC. in accordance with 

manufacturer's recommendations and the US Drone Group, LLC. Operating Manual and 

Inspection Program. 

2. Maintenance, preventive maintenance, rebuilding and alteration will be successfully 

accomplished by trained personnel or factory authorized maintenance facilities. 

3. Functional test flights will be performed by the PIC when required. The sUAS shall only 

be returned to service when this functional test flight is successfully completed. An 

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appropriate log entry shall be made in the sUAS's Aircraft Flight Log that the aircraft has 

successfully completed a functional test flight and is authorized for return to service. 

4. The US Drone Group, LLC Operating Manual details how to enter in the maintenance 

log scheduled and unscheduled maintenance or functional test flights that are performed. 

5. US Drone Group, LLC shall only operate its sUAS with all systems functioning per 

manufactures specification in a discrepancy free condition. 

6. These records will be maintained at the principle base for operation for the life of the 

aircraft or as required by Federal Aviation Regulations. 

7. US Drone Group, LLC and the Aircraft Manufacturer (DJI) are the most familiar with the 

aircraft and best suited to maintain the aircraft in an airworthy condition. These 

maintenance procedures allow for an equivalent level of safety to be achieved due to the 

limited size of the aircraft, the scope and area of operations. 

FEDERAL REGISTER 

A summary for the Federal Register is provided in the section "Description of Relief Sought for 

Specific Regulations" starting on pages 3-6 copied here for continuity. 

14 CFR Part 21 Subpart H 

14 C.F.R. 45.23(b) 

14 CFR 61.113 (a) & (b) 

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 91.405 (a) 

14 CFR 407 (a) (1) 

14 CFR 409 (a) (2) 

14 CFR 417 (a) & (b) 

14 CFR 61.3 (a) 

14 CFR 61.23 (a) 

UNMANNED AIRCRAFT SYSTEMS TECHNICAL INFORMATION 

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• 

US Drone Group, LLC seeks an exemption to operate two DJI Phantom 3 Professional sUAS for 

compensation or hire within the National Airspace System (NAS). 

The DJI Phantom 3 Professional is a vertical takeoff and landing (VTOL) Unmanned Aircraft 

(UA) with a Ground Control Station (GCS) utilizing electronic tablet or smart phone systems. 

The DJI Phantom 3 Professional has the following specifications: 

Aircraft 

Weight (Battery, Camera & Propellers Included) 

Max. Ascent Speed 

Max. Descent Speed 

Max. Speed 

Max. Flight Altitude 

Max. Flight Time 

Operating Temperature 

GPS Mode 

Gimbal 

Controllable Range 

Vision Positioning 

Velocity Range 

Altitude Range 

Operating Range 

Operating Environment 

Camera 

Sensor 

M (total pixels: 12.76 M) 

Lens 

f/2.8 

ISO Range 

Electronic Shutter Speed 

Image Max. Size 

1280 g (a maximum gross weight of 

approximately 3 pounds 11 ounces, diameter 

of 16 inches) 

5 m/s 

3 m/s 

16 m/s (ATTI mode, no wind) 

6000m 

Approximately 23 minutes 

ooc to 40°C 

GPS/GLONASS 

Pitch: - 90° to + 30° 

< 8 m/s (2 m above ground) 

30 cm-300 em 

30 cm-300 em 

Brightly lit (lux> 15) patterned surfaces 

Sony EXMOR 112.3" Effective pixels:12.4 

FOV 94° 20mm(35mm format equivalent ) 

100-3200(video) 100-1600(photo) 

8s -1/8000s 

4000 X 3000 

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Still Photography Modes 

Auto Exposure Bracketing (AEB): 

lapse 

Supported SD Card Types 

Video Recording Modes 

Max. Bitrate Of Video Storage 

Supported File Formats 

MP4/MOV (MPEG-4 A VC/H.264) 

Operating Temperature Range 

Remote Controller 

Operating Frequency 

Transmitting Distance 

Video Output Port USB 

Operating Temperature Range 

Battery 

Mobile Device Holder 

Transmitter Power(EIRP) 

Working Voltage 

Charger 

Voltage 

Rated Power 

Battery 

Intelligent Hight Battery 

Capacity 

Voltage 

Battery Type 

Energy 

Net Weight 

Operating Temperature 

Max. Charging Power 

Single shoot Burst shooting: 3/517 frames 

3/5 bracketed frames at 0.7EV Bias TimeMicro SD Max. capacity: 64GB. Class 10 

or UHS-1 Rating required 

UHD: 4096x2160p 24/25, 

3840x2160p24/25/30 PHD: 1920x1080p 

24/25/30/48/50/60 HD: 1280x720p 

24/25/30/48/50/60 

60Mbps 

FAT32/exFAT Photo: JPEG, DNG Video: 

ooc to 40°C 54© 2015 DJI. 

2.400 GHz-2.483 GHz 

2000 m (Outdoor And Unobstructed) 

0°C-40°C 

6000 mAh LiPo 2S 

Tablets and smartphones 

FCC: 20 dbm; CE: 16 dbm 

1.2A @7.4 V 

17.4V 

lOOW 

( PH3-4480 mAh-15.2 V) 

4480mAh 

15.2V 

LiPo4S 

68Wh 

365 g 

-lO"C- 40"C 

100W 

The Phantom 3 Professional is equipped with four main rotors; driven by Lithium Polymer 

battery powered electric motors. The DJI Phantom 3 Professional UAS that will be operated by 

US Drone Group, LLC will be registered in accordance with 14 C.F.R Part 47.33 Aircraft 

Registration, and marked in accordance with the petitioned exemption for 14 C.P.R. 45.23(b), 

Identification and Registration Marking. 

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CONCLUSION 

US Drone Group, LLC believes that the criteria provided in Section 333 of the FMRA regarding 

size, weight, speed, operating capabilities, proximity to airports and populated areas, operation 

within visual line of sight, and national security have been satisfied. US Drone Group, LLC is 

committed to follow these criteria in a safe and professional manner. I respectfully request the 

granting of this exemption request. Please contact William W. Williams, US Drone Group, LLC 

with any questions or for more information. 

Respectfully, 

William W Williams 

Managing Member 

US Drone Group, LLC 

404.433.1509 

2 .bill. williams@ gmail.com 

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