Name and Address of Applicant: 

Joshua Jennings

Co-Founder/CEO

Professional Drone Imaging LLC.

8608 NE 116th St.

Kansas City, MO 64157

To whom it may concern,

Professional Drone Imaging LLC (PDI LLC) located at 8608 NE 116th St. Kansas City, MO 64157 

requests exemption under Section 333 of the FAA Modernization and Reform Act of 2012 and 14 C.F.R. 

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

requests exemptions from several provisions of the Federal Aviation Regulations ("FAR"), specifically 

Section 333 which authorizes the FAA to determine:

1. If certain unmanned aircraft systems, if any, as a result of their size, weight, speed, 

operational capability, proximity to airports and populated areas, and operation within visual line of 

sight do not create a hazard to users of the national airspace system or the public or pose a threat to 

national security; and

2. Whether a certificate of waiver, certificate of authorization, or airworthiness certification 

under section 44704 of title 49, United States Code, is required for the operation of unmanned aircraft 

systems identified under paragraph (1).

We are writing to request that PDI LLC, an owner and operator of small unmanned aircraft, be 

exempted from the Federal Aviation Regulations ("FARs") listed below so that PDI LLC, may operate its 

small unmanned aircraft systems ("UAS") commercially in airspace regulated by the Federal Aviation 

Administration (“FAA”); as 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. PDI LLC has been 

actively involved in the technical development of UAS service applications to provide high definition 

aerial photography for public safety professionals, real estate agents, insurance personnel and various 

others, with small, unmanned aircraft and lightweight UAS’s. The substance of this request is essentially 

the same as that granted to LowCountryRC Docket Number FAA-2014-0803 in that PDI LLC is committed 

in public safety, as well as, aerial photography/videography and inspection of structures. PDI LLC has 

fully equipped each of its small unmanned aircraft for aerial photography and video, primarily for 

use in the public safety sector, real estate and land surveying. 

PDI LLC exemption request would permit its operation of lightweight, unmanned (remotely 

controlled in line of sight) UAS's in tightly controlled and limited airspace. Predetermined, specifically 

marked areas of operation, sectioned off locations will allow PDI LLC to operate within current safety 

regulations and new ones being sought. As identified, similar lightweight, remote controlled UAS's are 

legally operated by amateurs with no flight experience, safety plan or controls in place to prevent 

catastrophe. Granting PDI LLC's request coheres with the Secretary of Transportation's (FAA 

Administrator's) responsibilities to not only integrate UAS's into the national airspace system, but to" ... 

establish requirements for the safe operation of such aircraft systems [UAS's] in the national airspace 

system" under Section 333 of the Reform Act. Further, PDI LLC will conduct its operations in compliance 
with the protocols described herein or as otherwise established by the FAA. The Extent of Relief PDI LLC

Seeks and the Reason It Seeks Such Relief: 

PDI LLC submits this application in accordance with the Reform Act, 112 P.L. 95 §§ 331-334, 

seeking relief from any currently applicable FAR's operating to prevent PDI LLC contemplated 

commercial operations, research and other flight operations within the national airspace system. The 

Reform Act in Section 332 provides for such integration of civil unmanned aircraft systems into our 

national airspace system as it is in the public's interest to do so. PDI LLC lightweight UAS's meet the 

definition of "small unmanned aircraft" as defined in Section 331 and therefore the integration of PDI 

LLC lightweight UAS's are expressly contemplated by the Reform Act. PDI LLC would like to operate its 

lightweight UAS's prior to the time period by which the Reform Act requires the FAA to promulgate rules 

governing such craft. The Reform Act guides the Secretary in determining the types of UAS's that may 

operate safely in our national airspace system. Considerations include: The weight, size, speed and 

overall capabilities of the UAS; Whether the UAS will be operated near airports or populated areas; and, 

Whether the UAS will be operated by line of sight. 112 P.L. 95 § 333 (a). Each of these items 

mitigates in favor of an exemption for PDI LLC.

PDI LLC’s aircraft uses multi counter-rotating propellers for extreme balance, control and 

stability. They each weigh less than 55 pounds, including camera or other equipment. Each of PDI LLC’s 

aircraft small unmanned aircraft is designed to primarily hover in place and operate at less than a 50 

knot maximum speed. They are capable of vertical and horizontal operations but operate only within 

the visual line of sight pilot-in-command (PIC). In addition to the PIC, PDI LLC utilizes a qualified spotter, 

capable of fully operating the aircraft in such that, the PIC would encounter a medical emergency during 

operations. Utilizing battery power and not combustible fuels, flights generally last between fifteen and 

twenty-five minutes. PDI LLC will not, under any circumstance, operate the aircraft under twenty-five 

percent battery level. Safety systems in place include a failsafe mode that allows PDI LLC aircraft to 

return to the GPS launch coordinates if communication with the radio control is lost or battery level 

becomes less than twenty five percent. PDI LLC does not operate its UAV's near airports and does not 

operate them near populated areas.

PDI LLC operation of its small unmanned aircraft will not "create a hazard to users of the 

national airspace system or the public." 112 P.L. 95 § 3 3 3 (b). Given the small size and weight of PDI LLC

aircraft, combined with their operation of well-controlled areas, PDI LLC aircrafts fall within Congress's 

contemplated safety zone when it published the Reform Act and the corresponding directive to 

integrate UAS's into the national airspace system. PDI LLC aircraft have an outstanding safety record 

and do not pose any threat to the general public or national security. The FAA has the authority to issue 

the exemption to PDI LLC pursuant to the Federal Aviation Act, 85 P.L. 726 (1958), as amended (the 

“Act"). Commercial and Public Benefits Granting PDI LLC exemption request furthers the public interest. 

First, Congress has already pronounced that it is in the public’s interest to integrate commercially flown 

UAS's into the national airspace system, thus the passing of the Reform Act. Second, PDI LLC conducts 

research into safe UAS operations every time it flies one of its UAV's. Flight data, visual inspections, 

recorded observations and flight analyses are compiled to further enhance current safety protocols. 

Granting approval of this exemption request for PDI LLC to log more flight time will augment its ability to 

further enhance current safety measures. Granting the PDI LLC exemption request considerably furthers 

the public's interest in more ways than currently known. Allowing PDI LLC to fly within the United States 

allows for improvements in publicly usable technologies and/or advancements in equipment available to 
law enforcement personnel and first responders with state of the art equipment that does not cost the 

tax payers millions. 

Reasons why PDI LLC Exemption will not adversely affect safety or how the exemption will 

provide a level of safety at least equal to existing rule: PDI LLC exemption will not adversely affect 

safety. Actually, for the many reasons stated, permitting PDI LLC to gain experience and information 

over time will allow PDI LLC to innovate and implement new and improved safety protocols and 

technologies. 

1. PDI LLC aircraft weigh less than 55 pounds complete with cameras;

2. PDI LLC only operates its UAS's below 400 feet; 

3. PDI LLC UAV's operate for 5-30 minutes per flight; 

4. PDI LLC lands its UAS's before they reach a threshold 25% battery power; 

5. PDI LLC pilots operate PDI LLC aircraft by Visual Line of Sight (VSOL) at all times.

6. PDI LLC pilots have live video streamed to the ground control station should they somehow lose sight 

of the UAS;

7. PDI LLC staffs each flight with a pilot-in-command and spotter capable of operating aircraft;

8. PDI LLC aircraft have GPS flight modes whereby they return to launch if communication with the 

remote control is lost or battery threshold becomes less than 25%;

9. PDI LLC actively examines electronic flight data and other sources of information to constantly update 

and enhance safety protocols;

10. PDI LLC only operates in secured areas that are strictly controlled, are away from airports and heavily 

populated areas;

11. PDI LLC conducts extensive briefings prior to flight, during which safety carries primary importance;

12. PDI LLC always obtains all necessary permissions and permits prior to operation;

13. PDI LLC operationally administers a level of safety equal to and even greater than existing rules set 

forth.

It is important to note that absent the integration of commercial UAS's into our national 

airspace system, helicopters are the primary means of aerial observation. While the safety record of 

such helicopters is incredible, it is far safer to operate a battery powered lightweight UAS. First, the 

potential loss of life is decreased because PDI LLC aircraft carry no people on board and PDI LLC only 

operates in areas away from major populations. Second, there is no fuel on board PDI LLC aircraft and 

thus the potential for fire or explosions is highly decreased. Third, the small size and acute 

maneuverability of PDI LLC aircraft allow the pilot in command to avoid hazards. Respectfully, PDI LLC

aircraft have and will always operate at and above current safety requirements. Summary the FAA may 

publish in the Federal Register: 14 C.F.R. 21 and 14 C.F.R. 91: Airworthiness Certificates, Manuals and 

the Like. 14 C.F.R. 21, Subpart H, entitled Airworthiness Certificates, sets forth requirements for 

procurement of necessary airworthiness certificates in relation to FAR§ 91.203(a)(l). The size, weight 

and enclosed operational area of PDI LLC permits exemption from Part 21 because PDI LLC aircraft meet 

an equivalent level of safety pursuant to Section 333 of the Reform Act. The FAA is authorized to exempt 

aircraft from the airworthiness certificate requirement under both the Act (49 U.S.C. § 44701 (f)) and 

A. Section 333 of the Reform Act. Both pieces of legislation permit the FAA to exempt UAS's from the 

airworthiness certificate requirement in consideration of the weight, size, speed, maneuverability and 

proximity to areas such as airports and dense populations. 
PDI LLC aircraft meet or exceed each of the elements. 14 C.F.R. 91.7 (a) prohibits the operation 

of an aircraft without an airworthiness certificate. As no such certificate will be applicable in the form 

contemplated by the FARs, this Regulation is inapplicable. 14 C.F.R. § 91.9 (b) (2) requires an aircraft 

flight manual in the aircraft. As there are no pilots or passengers, and given the size of the UAS's, this 

Regulation is inapplicable. An equivalent level of safety will be achieved by maintaining a manual at the 

flight operations center. The FAA has previously issued exemptions to this regulation in Exemption Nos. 

8607, 8737, 8738, 9299, 9299A, 9565, 95658, 10167, 10167A, 10602, 10700 and 32827. 14 C.F.R. § 

91.121 regarding altimeter settings is inapplicable insofar as PDI LLC UAS aircraft utilize electronic global 

positioning systems and internal gyroscopes to provide spatial coordination. 14 C.F.R. § 91.203 (a) and 

(b) provides for the carrying of civil aircraft certifications and registrations. They are inapplicable for the 

same reasons described above. The equivalent level of safety will be achieved by maintaining such 

certifications and registrations at the PDI LLC flight operations center. B. 14 C.F.R. § 45.23: Marking of 

the Aircraft. Applicable Codes of Federal Regulation require aircraft to be marked according to certain 

specifications. PDI LLC aircraft are, by definition, unmanned. They therefore do not have a cabin, cockpit 

or pilot station on which to mark certain words or phrases. Further, two-inch lettering is difficult to place 

on such small aircraft. The FAA has previously issued exemptions to this regulation through Exemptions 

Nos. 8738, 10167, 10167A and 10700. C. 14 C.F.R. § 61.113: Private Pilot Privileges and Limitations. PIC

Pursuant to 14 C.F.R. §§ 61.113 (a) & (b), private pilots are limited to noncommercial operations. PDI LLC

can achieve an equivalent level of safety as achieved by current Regulations because PDI LLC aircraft do 

not carry any pilots or passengers. 

Further, while helpful, a pilot license (we do have a commercially rated pilot on staff) will not 

ensure unmanned piloting skills, though PDI LLC pilot vetting and training programs (based upon 

completion of an FAA Approved Ground School and a self-administered UAS flight training program and 

internal procedures) will. The risks attendant to the operation of PDI LLC aircraft is far less than the risk 

levels inherent in the commercial activities outlined in 14 C.F.R. § 61, et seq. D. 14 C.F.R. 91.119: 

Minimum Safe Altitudes. 14 C.F.R. § 91.119 prescribes safe altitudes for the operation of civil aircraft. It 

allows Helicopters to be operated at lower altitudes in certain conditions. PDI LLC UAS aircraft will never 

operate at an altitude greater than 400 AGL. PDI LLC will, however, operate its UAV's in sectioned off 

areas with security and safety being paramount, providing a level of safety at least equivalent to those in 

relation to minimum safe altitudes. Given the size, weight, maneuverability and speed of PDI LLC

aircraft, an equivalent level of safety will be achieved. E. 14 C.F.R. 91.405 (a); 407 (a) (1); 409 (a) (2); 

417(a) & (b): Maintenance Inspections. The above-cited Regulations require, amongst other things, 

aircraft owners and operators to "have [the] 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." These Regulations only apply to aircraft 

with an airworthiness certificate. They will not, therefore, apply to PDI LLC should its requested 

exemption be granted. PDI LLC conducts an extensive maintenance program that involves regular 

software updates and constant inspection for assessment of any damaged hardware. Therefore, an 

equivalent level of safety will be achieved. PDI LLC has researched and developed its own designs. 

 Summary PDI LLC seeks an exemption from the following Regulations: 14 C.F.R. 21, subpart H; 14 

C.P.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(b); 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) and (b); 14 C.F.R. § 91.405 (a); 14 C.F.R. § 91.407 (a)(1); 14 C.P.R.§ 91.409 (a)(2); 

14 C.P.R.§ 91.409 (a)(2); and, 14 C.P.R.§§ 91.417 (a) & (b) to commercially operate its fleet of small 

unmanned vehicles and lightweight unmanned aircraft vehicles and to conduct its own research and to 

develop economic platforms for aerial survey, law enforcement , first responders, search and rescue and 

real-estate. Granting the PDI LLC request for exemption will reduce current risk levels and thereby 

enhance safety. Further, PDI LLC operates at lower altitudes and in controlled airspace. PDI LLC has 

been analyzing flight data and other information in compiling novel safety protocols and the 

implementation of a flight operations manual that exceeds currently accepted means and 

methods of safe flight. There are no people on board PDI LLC aircraft and therefore the 

likelihood of death or serious bodily injury is significantly limited. PDI LLC operation of its aircraft, 

weighing less than 55 pounds and traveling at speeds lower than 50 knots in cordoned off areas will 

provide at least an equivalent level of safety as that achieved under current FARs.

PDI LLC respectfully requests that the FAA grant its exemption request without delay. The FAA 

has the authority to issue the exemption sought by PDI LLC pursuant to the Federal Aviation Act, 85 P.L. 

726 (1958), as amended (the "Act"). Thank you for the time and consideration of the above Exemption 

Request. Please contact Mr. Joshua Jennings for more information or questions that arise.

Thank you for your time,

Joshua Jennings

Co-Owner and CEO

Professional Drone Imaging LLC

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