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DroneBee, Corp. Petition for Exemption, UAS Operation

US DEPARTMENT OF TRANSPORTATION

1200 New Jersey Avenue

SE Room W-12-140

West Building Ground Floor

Washington, DC 20590-0001

William Boyd

562 Cordova Ct.

Lafayette, CO 80026

Phone: (808) 384.1670

Dear Administrator:

Enclosed please find the petition from DroneBee Corporation to the Federal Aviation 

Administration seeking an exemption from the requirements of Title 14 of the Code of Federal 

Regulations (CFR) concerning the operation of Unmanned Aircraft System (UAS) for 

commercial use and operation within the United States. 

DroneBee is a Veteran owned business in the State of Colorado with the aim of creating a 

network of highly reliable licensed pilots, operators and contributors of UAS technologies who 

will operate UAS within all published rules, laws and regulations as well as adhere to a code of 

ethics and standard operating procedures.

The proposed exemption, if granted, will permit DroneBee’s commercial use of the UAS for the 

purpose of aerial inspections and/or promotion of land, buildings, and other man-made 

infrastructure, as well as the continued research and development in leveraging UAS

technologies to advance humanitarian, social, environmental and commercial applications.

Sincerely,

William Boyd

CEO, Co-Founder

DroneBee, Corp.

10/22/2015
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DroneBee, Corp. Petition for Exemption, UAS Operation

TABLE OF CONTENTS

SUMMARY FOR SEEKING EXEMPTION 4

COMPANY BACKGROUND 4

NAME AND ADDRESS OF DRONEBEE CORP. 4

BASIS FOR PETITION FOR EXEMPTION 4

SECTIONS OF 14 CFR FROM WHICH DRONEBEE SEEKS EXEMPTION 5

HOW DRONEBEE’S REQUEST WILL BENEFIT THE PUBLIC AS A WHOLE 8

EXTENT OF RELIEF SOUGHT AND HOW SAFETY WILL BE MAINTAINED 9

CONCLUSION 14
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DroneBee, Corp. Petition for Exemption, UAS Operation

SUMMARY FOR SEEKING EXEMPTION

Company Background

DroneBee, Corporation (DroneBee) was founded by two Graduate students at the University of 

Colorado, Leeds School of Business in 2015. One founder holds a M.S. in Engineering 

Management, is a U.S. Army Veteran (honorably discharged Officer at the rank of Major, O-4) 

and has four years of Aerospace Program Management experience. The other holds a Ph.D. in 

Applied Physics with over a decade of experience as a technical contributor and program 

manager in Aerospace.

DroneBee’s aim is to source highly qualified, capable pilots (operators) and broker commercial 

agreements with industry consumers of aerial data and imagery. DroneBee will operate UAS 

consistent with all applicable published rules, laws and regulations as well as adhere to a code of 

ethics and standard operating procedures in the interest of good business and safe operations. 

DroneBee is currently ‘pre-revenue’ as it continues to perform independent market research and 

analysis pending approval of the petition for exemption herein.

Name and Address of Petitioner:

DroneBee Corporation

1949 Pearl St STE C

Boulder, CO 80302

BASIS FOR PETITION FOR EXEMPTION

Sections of Title 14 CFR from which DroneBee Seeks Exemption

DroneBee, Corp. seeks exemption to the Title 14, Aeronautics and Space, Code of Federal 

Regulations §§ 61.23(a) and (c), 61.101(e)(4) and (5), 61.113(a), 61.315(a), 91.7(a), 91.119(c), 

91.121, 91.151(a)(1), 91.405(a), 91.407(a)(1), 91.409(a)(1) and (2), and 91.417(a) and (b), to the 

extent necessary to allow DroneBee’s licensed pilots and operators to operate a small UAS

(55lbs or less) to perform aerial imagery, video and data collection. 

Extent of Relief Sought:

DroneBee believes the exemptions sought are consistent with relief previously requested in 

Grant of Exemption Nos. 11062, 11109, 11112, 11213, and 11325.

DroneBee is familiar with, has operation manuals on hand and requests exemption with respect 

to the following small UAS platforms when weighing less than 55 pounds including payload:

a. DJI Phantom 2

b. DJI Phantom 3

c. DJI Inspire

d. DJI S900

e. DJI S1000

f. 3D Robotics Solo

g. 3D RoboticsAero
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DroneBee, Corp. Petition for Exemption, UAS Operation

h. 3D Robotics Spektre Industrial

i. Aero Vironment Puma AE

j. PrecisionHawk

k. Lancaster

l. AirRobot AR180

m. AirRobot AR200

Sections of 14 CFR From Which Dronebee Seeks Exemption

The following excerpt of requested code exemptions is provided:

61.23(a) and (c)

§61.23 Medical certificates: Requirement and duration.

(a) Operations requiring a medical certificate. Except as provided in paragraphs (b) and (c) of 

this section, a person—

(1) Must hold a first-class medical certificate:

(i) When exercising the pilot-in-command privileges of an airline transport pilot certificate;

(ii) When exercising the second-in-command privileges of an airline transport pilot certificate in 

a flag or supplemental operation in part 121 of this chapter that requires three or more pilots; or

(iii) When serving as a required pilot flightcrew member in an operation conducted under part 

121 of this chapter if the pilot has reached his or her 60th birthday.

(c) Operations requiring either a medical certificate or U.S. driver's license. (1) A person must 

hold and possess either a medical certificate issued under part 67 of this chapter or a U.S. driver's 

license when—

(i) Exercising the privileges of a student pilot certificate while seeking sport pilot privileges in a 

light-sport aircraft other than a glider or balloon;

(ii) Exercising the privileges of a sport pilot certificate in a light-sport aircraft other than a glider 

or balloon;

(iii) Exercising the privileges of a flight instructor certificate with a sport pilot rating while 

acting as pilot in command or serving as a required flight crewmember of a light-sport aircraft 

other than a glider or balloon; or

(iv) Serving as an Examiner and administering a practical test for the issuance of a sport pilot 

certificate in a light-sport aircraft other than a glider or balloon.

(2) A person using a U.S. driver's license to meet the requirements of this paragraph must—
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DroneBee, Corp. Petition for Exemption, UAS Operation

(i) Comply with each restriction and limitation imposed by that person's U.S. driver's license and 

any judicial or administrative order applying to the operation of a motor vehicle;

(ii) Have been found eligible for the issuance of at least a third-class airman medical certificate at 

the time of his or her most recent application (if the person has applied for a medical certificate);

(iii) Not have had his or her most recently issued medical certificate (if the person has held a 

medical certificate) suspended or revoked or most recent Authorization for a Special Issuance of 

a Medical Certificate withdrawn; and

(iv) Not know or have reason to know of any medical condition that would make that person 

unable to operate a light-sport aircraft in a safe manner.

61.101(e)(4) and (5)

§61.101 Recreational pilot privileges and limitations.

(e) Except as provided in paragraphs (d) and (i) of this section, a recreational pilot may not act as 

pilot in command of an aircraft—

(4) For compensation or hire;

(5) In furtherance of a business;

61.113(a)

§61.113 Private pilot privileges and limitations: Pilot in command.

(a) Except as provided in paragraphs (b) through (h) of this section, no person who holds a 

private pilot certificate may act as pilot in command of an aircraft that is carrying 

passengers or property for compensation or hire; nor may that person, for compensation 

or hire, act as pilot in command of an aircraft.

61.315(a)

§61.315 What are the privileges and limits of my sport pilot certificate?

(a) If you hold a sport pilot certificate you may act as pilot in command of a light-sport aircraft, 

except as specified in paragraph (c) of this section.

91.7(a)

§91.7 Civil aircraft airworthiness.

(a) No person may operate a civil aircraft unless it is in an airworthy condition.

91.119(c)

§91.119 Minimum safe altitudes: General.

(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.

91.121

§91.121 Altimeter settings.
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DroneBee, Corp. Petition for Exemption, UAS Operation

(a) Each person operating an aircraft shall maintain the cruising altitude or flight level of that 

aircraft, as the case may be, by reference to an altimeter that is set, when operating—

(1) Below 18,000 feet MSL, to—

(i) The current reported altimeter setting of a station along the route and within 100 nautical 

miles of the aircraft; 

(ii) If there is no station within the area prescribed in paragraph (a)(1)(i) of this section, the 

current reported altimeter setting of an appropriate available station; or 

(iii) In the case of an aircraft not equipped with a radio, the elevation of the departure airport or 

an appropriate altimeter setting available before departure; or 

(2) At or above 18,000 feet MSL, to 29.92′′ Hg. 

(b) The lowest usable flight level is determined by the atmospheric pressure in the area of 

operation as shown in the following table:

(c) To convert minimum altitude prescribed under §§91.119 and 91.177 to the minimum flight 

level, the pilot shall take the flight level equivalent of the minimum altitude in feet and add the 

appropriate number of feet specified below, according to the current reported altimeter setting:

91.151(a)(1)

§91.151 Fuel requirements for flight in VFR conditions.
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DroneBee, Corp. Petition for Exemption, UAS Operation

(a) No person may begin 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.

91.405(a)

§91.405 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;

91.407(a)(1)

§91.407 Operation after maintenance, preventive maintenance, rebuilding, or alteration.

(a) No person may operate any aircraft that has undergone maintenance, preventive maintenance, 

rebuilding, or alteration unless—

(1) It has been approved for return to service by a person authorized under §43.7 of this chapter.

91.409(a)(1) and (2)

§91.409 Inspections.

(a) Except as provided in paragraph (c) of this section, no person may operate an aircraft unless, 

within the preceding 12 calendar months, it has had—

(1) An annual inspection in accordance with part 43 of this chapter and has been approved for 

return to service by a person authorized by §43.7 of this chapter; or 

(2) An inspection for the issuance of an airworthiness certificate in accordance with part 21 of 

this chapter.

91.417(a) and (b)

§91.417 Maintenance records.

(a) Except for work performed in accordance with §§91.411 and 91.413, each registered owner 

or operator shall keep the following records for the periods specified in paragraph (b) of this 

section: 

(1) Records of the maintenance, preventive maintenance, and alteration and records of the 100-

hour, annual, progressive, and other required or approved inspections, as appropriate, for each 

aircraft (including the airframe) and each engine, propeller, rotor, and appliance of an aircraft. 

The records must include—
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DroneBee, Corp. Petition for Exemption, UAS Operation

(i) A description (or reference to data acceptable to the Administrator) of the work performed; 

and 

(ii) The date of completion of the work performed; and 

(iii) The signature, and certificate number of the person approving the aircraft for return to 

service. 

(2) Records containing the following information: 

(i) The total time in service of the airframe, each engine, each propeller, and each rotor. 

(ii) The current status of life-limited parts of each airframe, engine, propeller, rotor, and 

appliance. 

(iii) The time since last overhaul of all items installed on the aircraft which are required to be 

overhauled on a specified time basis. 

(iv) The current inspection status of the aircraft, including the time since the last inspection 

required by the inspection program under which the aircraft and its appliances are maintained. 

(v) The current status of applicable airworthiness directives (AD) and safety directives including, 

for each, the method of compliance, the AD or safety directive number and revision date. If the 

AD or safety directive involves recurring action, the time and date when the next action is 

required.

(vi) Copies of the forms prescribed by §43.9(d) of this chapter for each major alteration to the 

airframe and currently installed engines, rotors, propellers, and appliances.

(b) The owner or operator shall retain the following records for the periods prescribed: 

(1) The records specified in paragraph (a)(1) of this section shall be retained until the work is 

repeated or superseded by other work or for 1 year after the work is performed. 

(2) The records specified in paragraph (a)(2) of this section shall be retained and transferred with 

the aircraft at the time the aircraft is sold. 

(3) A list of defects furnished to a registered owner or operator under §43.11 of this chapter shall 

be retained until the defects are repaired and the aircraft is approved for return to service.

How DroneBee’s Request Will Benefit the Public As a Whole

DroneBee’s request is in the public interest because DroneBee’s ultimate goal is to provide 

ethical and safe data collection services to its customers, research centers and to the public. 

DroneBee understands the rapidly evolving commercial and research application potential of 

small UAS. Emerging technologies however, create uncertainty, confusion and can lead to 
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DroneBee, Corp. Petition for Exemption, UAS Operation

mishaps in the worst case as safety standards and regulations lag behind innovation and 

technology. DroneBee will aid the public in closing this information gap in its role as an

information resource and connection hub for UAS services. DroneBee will maintain on pace 

with updating regulations and will strive to anticipate improvements to safety as it affects further 

restrictions and constraints.

As a Veteran owned company, DroneBee will seek to enable transitioning military Veterans, 

their spouses and our Nation’s treasured disabled Veterans in the vast and rapidly changing UAS 

industry. DroneBee considers this to be its most significant contribution and benefit to the 

public.

Safety and Summary of Exemption Sought

DroneBee is a safety conscious and focused organization. Our pilots will maintain standard 

operating procedures on hand in addition to all applicable flight checklists. In addition, the 

following considerations, notably published by the Administrator’s office will be strictly 

complied with:

1. DroneBee is familiar with, has operation manuals on hand and requests exemption with 

respect to the following small UAS platforms when weighing less than55 pounds 

including payload:

a. DJI Phantom 2

b. DJI Phantom 3

c. DJI Inspire

d. DJI S900

e. DJI S1000

f. 3D Robotics Solo

g. 3D RoboticsAero

h. 3D Robotics Spektre Industrial

i. Aero Vironment Puma AE

j. PrecisionHawk

k. Lancaster

l. AirRobot AR180

m. AirRobot AR200 

2. The UA may not be operated at a speed exceeding 87 knots (100 miles per hour). The 

exemption holder may use either groundspeed or calibrated airspeed to determine 

compliance with the 87 knot speed restriction. In no case will the UA be operated at 

airspeeds greater than the maximum UA operating airspeed recommended by the aircraft 

manufacturer.

3. The UA must be operated at an altitude of no more than 400 feet above ground level 

(AGL). Altitude must be reported in feet AGL.
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DroneBee, Corp. Petition for Exemption, UAS Operation

4. The UA must be operated within visual line of sight (VLOS) of the PIC at all times. This 

requires the PIC to be able to use human vision unaided by any device other than 

corrective lenses, as specified on the PIC’s FAA-issued airman medical certificate or 

U.S. driver’s license.

5. All operations must utilize a visual observer (VO). The UA must be operated within the 

visual line of sight (VLOS) of the PIC and VO at all times. The VO may be used to 

satisfy the VLOS requirement as long as the PIC always maintains VLOS capability. The 

VO and PIC must be able to communicate verbally at all times. Electronic messaging or 

texting is not permitted during flight operations. The PIC must be designated before the 

flight and cannot transfer his or her designation for the duration of the flight. The PIC 

must ensure that the VO can perform the duties required of the VO.

6. This exemption and all documents needed to operate the UAS and conduct its operations 

in accordance with the conditions and limitations stated in this grant of exemption, are 

hereinafter referred to as the operating documents. The operating documents must be 

accessible during UAS operations and made available to the Administrator upon request. 

If a discrepancy exists between the conditions and limitations in this exemption and the 

procedures outlined in the operating documents, the conditions and limitations herein 

take precedence and must be followed. Otherwise, the operator must follow the 

procedures as outlined in its operating documents. The operator may update or revise its 

operating documents. It is the operator’s responsibility to track such revisions and present 

updated and revised documents to the Administrator or any law enforcement official 

upon request. The operator must also present updated and revised documents if it 

petitions for extension or amendment to this grant of exemption. If the operator 

determines that any update or revision would affect the basis upon which the FAA 

granted this exemption, then the operator must petition for an amendment to its grant of 

exemption. The FAA’s UAS Integration Office (AFS-80) may be contacted if questions 

arise regarding updates or revisions to the operating documents.

7. Any UAS that has undergone maintenance or alterations that affect the UAS operation or 

flight characteristics, e.g. replacement of a flight critical component, must undergo a 

functional test flight prior to conducting further operations. Functional test flights may 

only be conducted by a PIC with a VO and must remain at least 500 feet from other 

people. The functional test flight must be conducted in such a manner so as to not pose an 

undue hazard to persons and property.

8. The operator is responsible for maintaining and inspecting the UAS to ensure that it is in 

a condition for safe operation.

9. Prior to each flight, the PIC must conduct a pre-flight inspection and determine the UAS 

is in a condition for safe flight. The pre-flight inspection must account for all potential 

discrepancies, e.g. inoperable components, items, or equipment. If the inspection reveals 

a condition that affects the safe operation of the UAS, the aircraft is prohibited from 

operating until the necessary maintenance has been performed and the UAS is found to 

be in a condition for safe flight.
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DroneBee, Corp. Petition for Exemption, UAS Operation

10. The operator must follow the UAS manufacturer’s maintenance, overhaul, replacement, 

inspection, and life limit requirements for the aircraft and aircraft components.

11. Each UAS operated under this exemption must comply with all manufacturer safety 

bulletins.

12. Under this grant of exemption, a PIC must hold either an airline transport, commercial, 

private, recreational, or sport pilot certificate. The PIC must also 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. The PIC 

must also meet the flight review requirements specified in 14 CFR § 61.56 in an aircraft 

in which the PIC is rated on his or her pilot certificate.

13. The operator may not permit any PIC to operate unless the PIC demonstrates the ability 

to safely operate the UAS in a manner consistent with how the UAS will be operated 

under this exemption, including evasive and emergency maneuvers and maintaining 

appropriate distances from persons, vessels, vehicles and structures. PIC qualification 

flight hours and currency must be logged in a manner consistent with 14 CFR § 61.51(b). 

Flights for the purposes of training the operator’s PICs and VOs (training, proficiency, 

and experience-building) and determining the PIC’s ability to safely operate the UAS in a 

manner consistent with how the UAS will be operated under this exemption are permitted 

under the terms of this exemption. However, training operations may only be conducted 

during dedicated training sessions. During training, proficiency, and experience-building 

flights, all persons not essential for flight operations are considered nonparticipants, and 

the PIC must operate the UA with appropriate distance from nonparticipants in 

accordance with 14 CFR § 91.119.

14. UAS operations may not be conducted during night, as defined in 14 CFR § 1.1. All 

operations must be conducted under visual meteorological conditions (VMC). Flights 

under special visual flight rules (SVFR) are not authorized.

15. The UA may not operate within 5 nautical miles of an airport reference point (ARP) as 

denoted in the current FAA Airport/Facility Directory (AFD) or for airports not denoted 

with an ARP, the center of the airport symbol as denoted on the current FAA-published 

aeronautical chart, unless a letter of agreement with that airport’s management is 

obtained or otherwise permitted by a COA issued to the exemption holder. The letter of 

agreement with the airport management must be made available to the Administrator or 

any law enforcement official upon request.

16. The UA may not be operated less than 500 feet below or less than 2,000 feet horizontally 

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

17. If the UAS loses communications or loses its GPS signal, the UA must return to a predetermined location within the private or controlled-access property.
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DroneBee, Corp. Petition for Exemption, UAS Operation

18. The PIC must abort the flight in the event of unpredicted obstacles or emergencies.

19. The PIC is prohibited from beginning a flight unless (considering wind and forecast 

weather conditions) there is enough available power for the UA to conduct the intended 

operation and to operate after that for at least five minutes or with the reserve power 

recommended by the manufacturer if greater.

20. Air Traffic Organization (ATO) Certificate of Waiver or Authorization (COA). All 

operations shall be conducted in accordance with an ATO-issued COA. The exemption 

holder may apply for a new or amended COA if it intends to conduct operations that 

cannot be conducted under the terms of the attached COA.

21. All aircraft operated in accordance with this exemption must be identified by serial 

number, registered in accordance with 14 CFR part 47, and have identification (NNumber) markings in accordance with 14 CFR part 45, Subpart C. Markings must be as 

large as practicable.

22. Documents used by the operator to ensure the safe operation and flight of the UAS and 

any documents required under 14 CFR §§ 91.9 and 91.203 must be available to the PIC at 

the Ground Control Station of the UAS any time the aircraft is operating. These 

documents must be made available to the Administrator or any law enforcement official 

upon request.

23. The UA must remain clear and give way to all manned aviation operations and activities 

at all times.

24. The UAS may not be operated by the PIC from any moving device or vehicle.

25. All Flight operations must be conducted at least 500 feet from all nonparticipating 

persons, vessels, vehicles, and structures unless:

a. Barriers or structures are present that sufficiently protect nonparticipating persons 

from the UA and/or debris in the event of an accident. The operator must ensure 

that nonparticipating persons remain under such protection. If a situation arises 

where nonparticipating persons leave such protection and are within 500 feet of 

the UA, flight operations must cease immediately in a manner ensuring the safety 

of nonparticipating persons; and,

b. The owner/controller of any vessels, vehicles or structures has granted permission 

for operating closer to those objects and the PIC has made a safety assessment of 

the risk of operating closer to those objects and determined that it does not present 

an undue hazard.

26. All operations shall be conducted over private or controlled-access property with 

permission from the property owner/controller or authorized representative. Permission 
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DroneBee, Corp. Petition for Exemption, UAS Operation

from property owner/controller or authorized representative will be obtained for each 

flight to be conducted.

27. Any incident, accident, or flight operation that transgresses the lateral or vertical 

boundaries of the operational area as defined by the applicable COA must be reported to 

the FAA's UAS Integration Office (AFS-80) within 24 hours. Accidents must be reported 

to the National Transportation Safety Board (NTSB) per instructions contained on the 

NTSB Web site: www.ntsb.gov.

For closed-set motion picture and television filming and production, the following additional 

conditions and limitations apply:

28. The operator must have a motion picture and television operations manual (MPTOM) as 

documented in this grant of exemption.

29. At least 3 days before aerial filming, the operator of the UAS affected by this exemption 

must submit a written Plan of Activities to the local Flight Standards District Office 

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

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

the following:

a. Dates and times for all flights;

b. Name and phone number of the operator for the UAS aerial filming conducted 

under this grant of exemption;

c. Name and phone number of the person responsible for the on-scene operation of 

the UAS;

d. Make, model, and serial or N-Number of UAS to be used;

e. Name and certificate number of UAS PICs involved in the aerial filming;

f. A statement that the operator has obtained permission from property owners 

and/or local officials to conduct the filming production event; the list of those 

who gave permission must be made available to the inspector upon request;

g. Signature of exemption holder or representative; and

h. A description of the flight activity, including maps or diagrams of any area, city, 

town, county, and/or state over which filming will be conducted and the altitudes 

essential to accomplish the operation.

30. Flight operations may be conducted closer than 500 feet from participating persons 

consenting to be involved and necessary for the filming production, as specified in the 

exemption holder’s MPTOM.
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DroneBee, Corp. Petition for Exemption, UAS Operation

Unless otherwise specified in this grant of exemption, the UAS, the UAS PIC, and the UAS 

operations must comply with all applicable parts of 14 CFR including, but not limited to, parts 

45, 47, 61, and 91.

CONCLUSION

Under the authority granted to the FAA by 14 CFR §11.61 and Section 333 of the FAA 

Modernization and Reform Act of 2012, DroneBee hereby requests Exemption to commercially

operate the following UAS:

a. DJI Phantom 2

b. DJI Phantom 3

c. DJI Inspire

d. DJI S900

e. DJI S1000

f. 3D Robotics Solo

g. 3D RoboticsAero

h. 3D Robotics Spektre Industrial

i. Aero Vironment Puma AE

j. PrecisionHawk

k. Lancaster

l. AirRobot AR180

m. AirRobot AR200 

If granted, DroneBee’s operations will provide a positive economic impact to the public as well 

as advance not only UAS innovation and technology but also the widespread adoption of UAS 

commercial operation standards and ethics.