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 454588475 Woodgrove Court eric@gointellidrone.com Centerville, Ohio 45458 (937) 416

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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 D escription

................................ ................................ ................................ . 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 D escription

................................ ................................ ................................ . 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)

................................ ................................ ................................ ........ 108475 Woodgrove Court eric@gointellidrone.com Centerville, Ohio 45458 (937) 416

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2 | P a g e 1. Exemption Description

................................ ................................ ............................... 10

2. E xtent 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

................................ ................................ ................................ ............................. 128475 Woodgrove Court eric@gointellidrone.com Centerville, Ohio 45458 (937) 416

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## I. PETITIONER’S INFORMATION

Name: IntelliDrone, LLC

Contact: Eric Tindall
Address: 8475 Woodgrove Court

Centerville, OH 45458 Telephone: (937) 416

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Email: eric@gointellidrone.com



## II. REQUESTED EXEMPTION S

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



## A. § 45.23(b)

1. EXEMPTION DESCRIPTIO N (b) When marks include only the Roman capital letter “N” and the registration number is displayed o n 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

c ategory 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 airworthines s 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 SAFET Y 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. Ex cept as provided in paragraphs (b) and (c) of this section, a person

— (1) Must hold a first

- class medical certificate:8475 Woodgrove Court eric@gointellidrone.com Centerville, Ohio 45458 (937) 416

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4 | P a g e (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 o f 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 e xercising 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 exercisin g 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 fo r 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 cer tif icate or U.S. driver's license. (1) A person must hold and possess either a medical cert ificate 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 wi th 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 pilo t 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 licen se and any judicial or administrative order applying to the operation of a motor vehicle;8475 Woodgrove Court eric@gointellidrone.com Centerville, Ohio 45458 (937) 416

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5 | P a g e (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
h as 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 w ithdrawn; 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 physi cal and valid driver’s license meet the safety requirements of this section.



### 3. EQUIVALENCE OF SAFET Y 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 Phant om 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 prese nted herein (e.g. Exemption Nos. 11410, 11553, 11257, 11213, 11437, 11150A).



## C. § 61.56

1. EXEMPTION DESCRIPTIO N (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 gr ound 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 hou r of flight training required in paragraph (a) of this section.8475 Woodgrove Court eric@gointellidrone.com Centerville, Ohio 45458 (937) 416

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6 | P a g e (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 m onth 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 instru ctor 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 specifi ed 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 n eed 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 a ccomplished 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.8475 Woodgrove Court eric@gointellidrone.com Centerville, Ohio 45458 (937) 416

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### 3. EQUIVALENCE OF SAFET Y 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 p ilot in command
of an aircraft.



### 2. EXTENT OF RELIEF AND REASONING

IntelliDrone requests an exemption from 14 CFR § 61.113, limiting private pilots to non

commercial operations. However, the UAS will not carry pilots, passengers, or any living thing
and be res tricted 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 SAFE TY 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 oper ator 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 p aragraph (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 flight hour and currency requirements, to conduct the proposed UAS flight operations for compensation or hi re.



### 3. EQUIVALENCE OF SAFET Y

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 flight hour and currency requirements, demonst rating that the PIC is able to safely operate either the DJI8475 Woodgrove Court eric@gointellidrone.com Centerville, Ohio 45458 (937) 416

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8 | P a g e 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 dist ances 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 cl oser 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 di stance can be maintained.



### 3. EQUIVALENCE OF SAFET Y 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 fr om 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 a vailable station;

or8475 Woodgrove Court eric@gointellidrone.com Centerville, Ohio 45458 (937) 416

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9 | P a g e (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 de parture. An exemption is required because the UAS is not equipped with a user

- configurable barometric
altimeter.8475 Woodgrove Court eric@gointellidrone.com Centerville, Ohio 45458 (937) 416

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### 3. EQUIVALENCE OF SAFET Y Complying with the pre

- flight procedures in the Phantom 3 User Manual and verifying the GPS altitude before each flight w ill 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 ope rations 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 pe rson 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 cr uising 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 SAFET Y

Plannin g 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 tr ansit 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 DESCRIPTION S

91.405
Each ow ner or operator of an aircraft

— (a) Shall have that aircraft inspected as prescribed in subpart E of this part and sha ll 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

maintenanc e, rebuilding, or alteration unless

—8475 Woodgrove Court eric@gointellidrone.com Centerville, Ohio 45458 (937) 416

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11 | P a g e (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 airworthi ness 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, prope ller, 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 certifi cate 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 pa rts 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, incl uding 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 to8475 Woodgrove Court eric@gointellidrone.com Centerville, Ohio 45458 (937) 416

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12 | P a g e maintenance of aircraft holding an airworthiness certificate, which the Phantom 3 does not have. Therefore an exemption is required.



### 3. EQUIVALENCE OF SAFET Y 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 a nd 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 aer ial 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 smal l 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 othe rs using the National Airspace.