UNITED STATES OF AMERICA

DEPARTMENT OF TRANSPORTATION

FEDERAL AVIATION ADMINISTRATION

WASHINGTON, DC

IN THE MATTER OF THE PETITION FOR EXEMPTION OF: 

INTELLIDRONE, LLC

Submitted by Eric Tindall

8475 Woodgrove Court Centerville, OH 45458
8475 Woodgrove Court eric@gointellidrone.com

Centerville, Ohio 45458 (937) 416-1478

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TABLE OF CONTENTS

I. Petitioner’s Information .......................................................................................................... 3

II. Requested Exemptions............................................................................................................ 3

A. § 45.23(b)............................................................................................................................. 3

1. Exemption Description ................................................................................................. 3

2. Extent of Relief and Reasoning..................................................................................... 3

3. Equivalence of Safety ................................................................................................... 3

B. § 61.23(a) and (c)................................................................................................................. 3

1. Exemption Description ................................................................................................. 3

2. Extent of Relief and Reasoning..................................................................................... 5

3. Equivalence of Safety ................................................................................................... 5

C. § 61.56.................................................................................................................................. 5

1. Exemption Description ................................................................................................. 5

2. Extent of Relief and Reasoning..................................................................................... 6

3. Equivalence of Safety ................................................................................................... 7

D. § 61.113(a) ....................................................................................................................... 7

1. Exemption Description ................................................................................................. 7

2. Extent of Relief and Reasoning..................................................................................... 7

3. Equivalence of Safety ................................................................................................... 7

E. § 61.315(a) & (c)(2) & (3)..................................................................................................... 7

1. Exemption Description ................................................................................................. 7

2. Extent of Relief and Reasoning..................................................................................... 7

3. Equivalence of Safety ................................................................................................... 7

F. § 91.119(c) ........................................................................................................................... 8

1. Exemption Description ................................................................................................. 8

2. Extent of Relief and Reasoning..................................................................................... 8

3. Equivalence of Safety ................................................................................................... 8

G. § 91.121............................................................................................................................ 8

1. Exemption Description ................................................................................................. 8

2. Extent of Relief and Reasoning..................................................................................... 9

3. Equivalence of Safety ................................................................................................. 10

H. § 91.151(a)(1) & (b)........................................................................................................ 10
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1. Exemption Description ............................................................................................... 10

2. Extent of Relief and Reasoning................................................................................... 10

3. Equivalence of Safety ................................................................................................. 10

I. § 91.405(a), § 91.407(a)(1), § 91.409(a), § 91.417(a) and (b) ........................................... 10

1. Exemption Descriptions.............................................................................................. 10

2. Extent of Relief and Reasoning................................................................................... 11

3. Equivalence of Safety ................................................................................................. 12

III. Public Benefits....................................................................................................................... 12

IV. Publication Summary............................................................................................................. 12

V. Conclusion ............................................................................................................................. 12
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I. PETITIONER’S INFORMATION

Name: IntelliDrone, LLC

Contact: Eric Tindall

Address: 8475 Woodgrove Court

 Centerville, OH 45458

Telephone: (937) 416-1478

Email: eric@gointellidrone.com

II. REQUESTED EXEMPTIONS

IntelliDrone, LLC seeks exemption from the 14 CFR requirements outlined in the following 

subsections.

A. § 45.23(b)

1. EXEMPTION DESCRIPTION

(b) 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.

2. EXTENT OF RELIEF AND REASONING

This regulation requires certain experimental, provisionally certificated aircraft, or light sport 

category aircraft to be marked with letters between 2 inches and 6 inches high "limited," 

“restricted," "light-sport," "experimental," or "provisional," near each entrance to a cabin, 

cockpit, or pilot station.

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 UAS, two-inch lettering will be impossible. The word 

"Experimental" will be placed on the fuselage in compliance with §45.29 (f).

3. EQUIVALENCE OF SAFETY

The equivalent level of safety will be provided by having the UAS marked on its fuselage as 

required by §45.29 (f) where the pilot, observer and others working with the UAS will see the 

identification of the UAS as "Experimental." The FAA has issued the following exemptions to this 

regulation: Exemptions Nos. 10700, 8738, 10167 and 10167A.

B. § 61.23(a) and (c)

1. EXEMPTION DESCRIPTION

(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:
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(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.

(2) Must hold at least a second class medical certificate when exercising:

(i) Second-in-command privileges of an airline transport pilot certificate in part 

121 of this chapter (other than operations specified in paragraph (a)(1)(ii) of this 

section); or

(ii) Privileges of a commercial pilot certificate; or

(3) Must hold at least a third-class medical certificate—

(i) When exercising the privileges of a private pilot certificate;

(ii) When exercising the privileges of a recreational pilot certificate;

(iii) When exercising the privileges of a student pilot certificate;

(iv) When exercising the privileges of a flight instructor certificate and acting as 

the pilot in command;

(v) When exercising the privileges of a flight instructor certificate and serving as a 

required pilot flight crewmember;

(vi) When taking a practical test in an aircraft for a recreational pilot, private pilot, 

commercial pilot, or airline transport pilot certificate, or for a flight instructor 

certificate; or

(vii) When performing the duties as an Examiner in an aircraft when administering 

a practical test or proficiency check for an airman certificate, rating, or 

authorization.

(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—

(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;
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(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.

2. EXTENT OF RELIEF AND REASONING

Relief from § 61.23(a), entitled Medical certificates: Requirement and duration, is requested to 

the extent necessary to allow a PIC, with a current physical from an approved practitioner but no 

medical certificate, to pilot the DJI Phantom 3 Professional.

The limitations of § 61.23(a) sets forth the level of medical certificate one needs in order to pilot 

an aircraft. However, because the DJI Phantom 3 Professional does not require a physical pilot 

inside the vessel and because the DJI Phantom 3 Professional can be programmed to safely 

return, within the same limitations the PIC would be required to follow, to the GCS and land in 

the event of loss of range or other emergencies a current physical will maintain a similar level of 

safety as the medical certificate would. IntelliDrone requests that a current physical and valid 

driver’s license meet the safety requirements of this section.

3. EQUIVALENCE OF SAFETY

IntelliDrone submits that the equivalent level of safety established by § 61.23(a) will be 

maintained because no PIC will be allowed to operate the DJI Phantom 3 Professional unless that 

PIC has a current physical on file with IntelliDrone and a valid Driver’s License.

The FAA has previously granted relief from § 61.23(a) & (c) specific to UAS, in circumstances 

similar, in all material respects to those presented herein (e.g. Exemption Nos. 11410, 11553, 

11257, 11213, 11437, 11150A).

C. § 61.56

1. EXEMPTION DESCRIPTION

(a) Except as provided in paragraphs (b) and (f) of this section, a flight review consists of a 

minimum of 1 hour of flight training and 1 hour of ground training. The review must include:

(1) A review of the current general operating and flight rules of part 91 of this chapter; 

and

(2) A review of those maneuvers and procedures that, at the discretion of the person 

giving the review, are necessary for the pilot to demonstrate the safe exercise of the 

privileges of the pilot certificate.

(b) Glider pilots may substitute a minimum of three instructional flights in a glider, each of which 

includes a flight to traffic pattern altitude, in lieu of the 1 hour of flight training required in 

paragraph (a) of this section.
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(c) Except as provided in paragraphs (d), (e), and (g) of this section, no person may act as pilot in 

command of an aircraft unless, since the beginning of the 24th calendar month before the month 

in which that pilot acts as pilot in command, that person has—

(1) Accomplished a flight review given in an aircraft for which that pilot is rated by an 

authorized instructor and

(2) A logbook endorsed from an authorized instructor who gave the review certifying that 

the person has satisfactorily completed the review.

(d) A person who has, within the period specified in paragraph (c) of this section, passed any of 

the following need not accomplish the flight review required by this section:

(1) A pilot proficiency check or practical test conducted by an examiner, an approved pilot 

check airman, or a U.S. Armed Force, for a pilot certificate, rating, or operating privilege.

(2) A practical test conducted by an examiner for the issuance of a flight instructor 

certificate, an additional rating on a flight instructor certificate, renewal of a flight 

instructor certificate, or reinstatement of a flight instructor certificate.

(e) A person who has, within the period specified in paragraph (c) of this section, satisfactorily 

accomplished one or more phases of an FAA-sponsored pilot proficiency award program need 

not accomplish the flight review required by this section.

(f) A person who holds a flight instructor certificate and who has, within the period specified in 

paragraph (c) of this section, satisfactorily completed a renewal of a flight instructor certificate 

under the provisions in §61.197 need not accomplish the one hour of ground training specified 

in paragraph (a) of this section.

(g) A student pilot need not accomplish the flight review required by this section provided the 

student pilot is undergoing training for a certificate and has a current solo flight endorsement as 

required under §61.87 of this part.

(h) The requirements of this section may be accomplished in combination with the requirements 

of §61.57 and other applicable recent experience requirements at the discretion of the 

authorized instructor conducting the flight review.

(i) A flight simulator or flight training device may be used to meet the flight review 

requirements of this section subject to the following conditions:

(1) The flight simulator or flight training device must be used in accordance with 

an approved course conducted by a training center certificated under part 142 of 

this chapter.

(2) Unless the flight review is undertaken in a flight simulator that is approved for 

landings, the applicant must meet the takeoff and landing requirements of 

§61.57(a) or §61.57(b) of this part.

(3) The flight simulator or flight training device used must represent an aircraft or 

set of aircraft for which the pilot is rated.

2. EXTENT OF RELIEF AND REASONING

IntelliDrone requests exemption from 14 CFR § 61.56, which subjects the pilot in command (PIC) 

to flight review requirements consisting of one (1) hour of flight time in an aircraft in which the 

PIC is rated on his or her pilot certificate and one (1) hour of ground training. The flight review 

requirements set forth in 14 CFR § 61.56 would have little relevance to the safe operation of the 

small UAS intended for use in IntelliDrone’s operations.
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3. EQUIVALENCE OF SAFETY

An equivalent level of safety will be achieved by following the training procedures in the Phantom 

3 User Manual.

D. § 61.113(a)

1. EXEMPTION DESCRIPTION

(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.

2. EXTENT OF RELIEF AND REASONING

IntelliDrone requests an exemption from 14 CFR § 61.113, limiting private pilots to noncommercial operations. However, the UAS will not carry pilots, passengers, or any living thing 

and be restricted to a flight zone that is predetermined and controlled as to access. The risks 

associated with the UAS operations are far diminished from the risks associated with commercial 

operations envisioned by 14 CFR Part 61, when drafted.

3. EQUIVALENCE OF SAFETY

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

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

restricted, and all flights are planned and coordinated in advance. The risks associated with the 

operation of the UAS are so diminished from the level of risk associated with commercial 

operations contemplated by Part 61 when drafted, that allowing operations of the UAS as 

requested with a pilot who is an experienced UAS operator exceeds the present level of safety 

achieved by 14 C.F.R. §61.113 (a) & (b).

E. § 61.315(a) & (c)(2) & (3)

1. EXEMPTION DESCRIPTION

(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.

(c) You may not act as pilot in command of a light-sport aircraft:

(2) For compensation or hire.

(3) In furtherance of a business.

2. EXTENT OF RELIEF AND REASONING

IntelliDrone requests exemption to the extent necessary to allow a PIC holding a recreational, 

private, or sport pilot certificate as well as a valid driver’s license and current physical, and who 

has met certain flighthour and currency requirements, to conduct the proposed UAS flight 

operations for compensation or hire.

3. EQUIVALENCE OF SAFETY

IntelliDrone submits that an equivalent level of safety will be maintained because no PIC will be 

allowed to operate the DJI Phantom 3 Professional UAS unless that PIC has met certain flighthour 

and currency requirements, demonstrating that the PIC is able to safely operate either the DJI 
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Phantom 3 Professional in a manner consistent with the operations specifications as described 

in this exemption, including evasive and emergency maneuvers, as well as maintaining 

appropriate distances from people, vessels, vehicles, and structures that are not part of an 

investigation.

F. § 91.119(c)

1. EXEMPTION DESCRIPTION

(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.

2. EXTENT OF RELIEF AND REASONING

IntelliDrone requests an exemption from 14 CFR § 91.119(c), which establishes minimum safe 

altitudes “over other than congested areas,” in which an aircraft below 500 feet AGL may not 

operate closer than 500 feet to any person, vessel, vehicle, or structure. In order to provide the 

intended inspection services, the UAS will be operated below 500 feet AGL and closer than 500 

feet to persons, vessels, vehicles, and structures. Considering the hovering capabilities of the DJI 

Phantom 3 Professional, which is ± 0.1 m vertically (when Vision Positioning is activated) and ± 

1.5 m horizontally, a safer than 500 feet distance can be maintained.

3. EQUIVALENCE OF SAFETY

The equivalent level of safety established by § 91.119(c) will be maintained because the DJI 

Phantom 3 Professional will not be flown closer to any Vessel, Structure, or Vehicle without prior 

authorization from the owner.

Additionally, the DJI Phantom 3 Professional has automated hover capabilities which allow the 

DJI Phantom 3 Professional to maintain position within ± 0.2m vertically and ± 1.5m horizontally.

The FAA has previously granted relief from § 91.119(c) specific to UAS, in circumstances similar, 

in all material respects, to those presented herein (e.g. Exemption Nos. 11062, 11063, 11064, 

11065, 11066, 11067, 11080, 11109, 11111, 11112, 11136, 11188, 11208, 11213, 11437, 11508, 

11671)

G. § 91.121

1. EXEMPTION DESCRIPTION

(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
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(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:

Current altimeter setting Lowest usable flight level

29.92 (or higher) 180

29.91 through 29.42 185

29.41 through 28.92 190

28.91 through 28.42 195

28.41 through 27.92 200

27.91 through 27.42 205

27.41 through 26.92 210

(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:

Current altimeter setting Adjustment factor

29.92 (or higher) None

29.91 through 29.42 500

29.41 through 28.92 1,000

28.91 through 28.42 1,500

28.41 through 27.92 2,000

27.91 through 27.42 2,500

27.41 through 26.92 3,000

2. EXTENT OF RELIEF AND REASONING

IntelliDrone requests an exemption from 14 CFR § 91.121, which states that when operating 

below 18,000 feet MSL, aircraft not equipped with a radio shall set an altimeter to the elevation 

of the departure airport or an appropriate altimeter setting available before departure. An 

exemption is required because the UAS is not equipped with a user-configurable barometric 

altimeter.
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3. EQUIVALENCE OF SAFETY

Complying with the pre-flight procedures in the Phantom 3 User Manual and verifying the GPS 

altitude before each flight will provide an equivalent level of safety. During flight, the Phantom 3 

provides an Above Ground Level (AGL) reading in relation to its takeoff location. The altitude will 

be closely monitored during flight, keeping the UAS below 400 feet AGL, ensuring operations at 

safe altitudes. Furthermore, the UAS will remain within VLOS of the PIC and VO at all times.

H. § 91.151(a)(1) & (b)

1. EXEMPTION DESCRIPTION

(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; or

(2) At night, to fly after that for at least 45 minutes.

(b) No person may begin 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.

2. EXTENT OF RELIEF AND REASONING

IntelliDrone requests an exemption from 14 CFR § 91.151(a)(1) and (b), which states than no 

person may begin a flight unless 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 30 minutes. The battery 

powering the Phantom 3 provides approximately 25 minutes of total flight time. It is therefore 

impossible for the UAS to meet the requirement of this section.

3. EQUIVALENCE OF SAFETY

Planning all flights with the intent to land after 30 minutes or at 25% battery power remaining, 

whichever comes first, will provide an equivalent level of safety. Additionally, unlike traditional 

aircraft, the UAS will always be within VLOS and no significant transit time to or from the landing 

area

I. § 91.405(a), § 91.407(a)(1), § 91.409(a), § 91.417(a) 

and (b)

1. EXEMPTION DESCRIPTIONS

91.405

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

maintenance, rebuilding, or alteration unless—
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(1) It has been approved for return to service by a person authorized under §43.7 of this 

chapter

91.409

(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) 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—

(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.

2. EXTENT OF RELIEF AND REASONING

IntelliDrone requests an exemption from the maintenance and inspections requirements of 14 

CFR § 91.405(a), 91.407(a)(1), 91.409(a), and 91.417(a) and (b). These regulations apply to 
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maintenance of aircraft holding an airworthiness certificate, which the Phantom 3 does not have. 

Therefore an exemption is required.

3. EQUIVALENCE OF SAFETY

An equivalent level of safety will be achieved by ensuring that the UAS is in working order prior 

to initiating flight. All maintenance and inspections will be performed in accordance with the 

Phantom 3 User Manual.

III. PUBLIC BENEFITS

An exemption for IntelliDrone, LLC to use UAS commercially will provide the local economy with 

a new small business for potential employment and tax revenue. Located in the Dayton, Ohio 

area, where there has been growth in the area of UAS technology, this exemption will open up 

opportunities for new college graduates and entrepreneurs to apply their skills in an evolving 

industry. By providing a diverse set of services, IntelliDrone will meet a variety of community

needs. Through the rigorous administration of safety and FAA guidelines, IntelliDrone will assist 

in establishing public trust in UAS technology, setting the stage for longer-term applications.

IV. PUBLICATION SUMMARY

The petitioner, IntelliDrone, LLC, seeks exemption from the following rules to commercially 

operate UAS in the National Airspace to provide aerial photography and videography for the 

purposes of private and public events, data collection, real estate, project planning, agriculture, 

mapping, surveying, search and rescue, and inspections:

 § 45.23(b)

 § 61.23(a) and (c)

 § 61.56

 § 61.113(a)

 § 61.315(a) & (c)(2) & (3)

 § 91.119(c)

 § 91.121

 § 91.151(a)(1) & (b)

 § 91.405(a)

 § 91.407(a)(1)

 § 91.409(a)

 § 91.417(a) and (b)

V. CONCLUSION

IntelliDrone, LLC respectfully submits this request for expedited exemption under Section 333 of 

the Reform Act. Given the small size of the UAS, the willingness of IntelliDrone to gain all 

necessary permissions, and the commencement of clear and well planned operations and 

maintenance programs, the commercial, UAS use by IntelliDrone causes no threat to the general 

public or others using the National Airspace.