World	Services,	LLC

333	Excemption

1

World	Services,	LLC

World Services, LLC

6561 McKinley St

Hollywood, FL 33024

Shaun Sutton

Managing Director

Cell (954) 328 7535

Email: world1@comcast.net

U.S. Department of Transportation Docket Management System 

1200 New Jersey Ave., SE Washington, DC 20590

September 15, 2015

Dear Director:

On behalf of World Services, LLC Hereby applies for an exemption 

from the listed Federal Aviation Regulations (FARs) to allow 

commercial operation of Small Unmanned Aircraft Systems 

(sUASs) for the purposes of Arial Data collection, marine and 

industrial Photographic, visual and thermal imaging inspections, 

mapping, surveying, aerial photography, videography and other 

flight operations that could be performed safely and more cost 

effectively with the use of small UAS at low altitude within the U.S. 

national airspace system as compared to a manned aircraft or inperson visual inspections. 

In accordance with Section 333 of the FAA Modernization and 

Reform Act of 2012 and 14 C.F.R. Part 11.

World Services, LLC seeks Exemption Request per Section 333 of 

the FAA Reform Act and Part 11 of the Federal Aviation 

Regulations from:

14 C.F.R. Part 21; 

14 C.F.R. 47; 

14 C.F.R. 61.3(a); 61.23(a); 61.113(a) & (b); 

14 C.F.R. 91.7 (a); 

14 C.F.R. 91.9 (b) (2); 91.103(b); 91.109; 91.119; 91.121; 

91.151(a); 91.203(a) & (b); 91.405(a); 91.407(a) (1); 91.409(a) (2); 

91.417(a) & (b); 
The requested exemption would permit World Services, LLC to 

conduct commercial operation of small, unmanned sUAS by 

trained, certified sUAS operators.

Furthermore an exemption will allow World Services, LLC the 

opportunity to further develop NDT (non destructive testing) 

inspection programs that will be beneficial to the safety of 

inspectors our clients and the public in general and in turn raise

awareness as to the beneficial uses of small-unmanned air 

systems.

Operations will be performed only at the request of and with the 

authorization and permission of clients or their authorized agents.

Such operations will be conducted within and under the conditions 

outlined herein or as established by the FAA, as required by 

Section 333.

World Services, LLC seeks exemption; for operating the DJI 

Phantom 3 Pro, DJI Inspire 1 T600 and DJI Spreading Wings 

S1000+ 

The above referenced UAS’s manufactured by DJI are highly 

successful professional grade small rotorcraft drones each of 

which will be maintained and operated to manufactures 

specifications and at weights under 55lbs (including payload).

Controlled primarily through an FCC certified radio control (RC) 

unit. Real time video and telemetry information is transmitted back 

to a ground control station allowing the operator (PIC) to monitor 

battery level, GPS signal strength, altitude (AGL) distance from 

PIC, camera imagery, and control camera angle.

DJI utilizes internal inertial measuring unit (IMU) with integrated 

barometric sensor augmented with global positioning system 

(GPS) to maintain its geospatial orientation and position.

World Services, LLC UAS’s will be operated utilizing DJI’s failsafe 

modes of operation for either loss of RC or GPS signal.

World Services, LLC operators (PIC’s) will utilize the on-board 

flight controller that limits altitude. Maximum altitude will be preprogrammed and maintained by the PIC to 400ft AGL thus 
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maintaining a safe buffer of 100ft AGL to aircraft minimum

permitted normal operational altitude of 500ft AGL.

Battery life limits flight times to approximately 20 minutes. The onboard flight controller will warn the pilot via telemetry and external 

lighting cues before reaching a low battery state.

Visual line of sight will be maintained at all times by the “PIC”

A visual observer will be utilized.

An automatic termination of flight and landing will be initiated when 

the battery reaches a predetermined low state.

Risk mitigation 

The petitioner has reviewed FAA exemptions reference’s 13

Conditions and Limitations section and believes that the 

procedures specified therein are reasonable and will be utilized in 

order to manage and mitigate risk and ensure public safety.

14 CFR §25.23(b) Marking of the Aircraft

All aircraft operated will be identified by serial number, and 

registered in accordance with 14 CFR part 47, and have 

identification (N−Number) markings in accordance with 14 CFR 

part 45, Subpart C. 

Given the obvious limitations World Services, LLC requests 

exemption from registration and markings size limitations. Should 

they be required markings will be made as large as possible. Or as 

may be required by order of this exemption.

14 CFR §61.113(a) and (b): Private Pilot Privileges and 

Limitations: Pilot in Command

PIC will hold either an airline transport, commercial, private, 

recreational, or sport pilot certificate. Current FAA airman medical 

certificate or a valid U.S. driver’s license.

14 CFR §91.7(a): Civil Aircraft Airworthiness

Airworthiness will be maintained by performance of routine 

inspections before each flight, conducting routine maintenance per 
manufactures recommendations post flight and utilize flight and 

maintenance logs to record failure prone components.

14 CFR §91.103: Preflight Action

To ensure that the UA airworthiness be verified before launch a

pre-flight checklist as per DJI operating manuals will be employed.

14 CFR §91.109: Flight Instruction

World Services, LLC will not permit any PIC to operate unless the 

PIC has demonstrated the ability to safely operate the UAS, 

including evasive and emergency maneuvers and maintaining 

appropriate distances from persons, vessels, vehicles and 

structures. PIC qualification flight hours and currency will be 

logged in a manner consistent with14 CFR § 61.51(b). 

During training, proficiency, and experience-building flights, all 

persons not essential for flight operations are considered 

nonparticipants. The PIC in training will operate the UA with 

appropriate distance from nonparticipants the instructor will be 

considered a participant with operational control.

14 CFR §91.119: Minimum Safe Altitudes

Altitude of no more than 400 feet above ground level (AGL) will be 

maintained.

Furthermore World Services, LLC Flight operations will be 

conducted at least 500 feet from all nonparticipating persons, 

vessels, vehicles, and structures. 

The “operator” (PIC) will ensure that nonparticipating persons 

remain under protection. 

If a situation arises where nonparticipating persons enter within 

500 feet of the UA, flight operations will cease immediately.

14 CFR §91.121 Altimeter Settings

DJI systems utilizes internal inertial measuring unit (IMU) with 

integrated barometric sensor augmented with global positioning 
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system (GPS) to maintain its geospatial orientation and position. 

As part of each preflight position orientation is calibrated and set.

14 CFR §91.151(a) Fuel Requirements for Flight in VFR 

Conditions

World Services, LLC seeks exemption from minimum fuel 

requirement as required by regulation as DJI UAS’s do not carry 

fuel.

14 CFR §91.203(a) and (b): Carrying Civil Aircraft Certificates and 

Registration

Due to the UAS limits in size and construction it is impractical to 

carry any certificates and/or registration. Any documents required 

for the operation of the UAS will be held in the area of operation by 

the PIC.

14 CFR §91.405(a); 407(a)(1); 409(a)(2); 417(a) and (b): 

Maintenance Inspections

Procedures will be adhered to for pre and post flight inspections so 

as to maintain continued airworthiness. 

Airworthiness will also be maintained by the performance of 

routine inspections, as outlined in the Manufactures maintenance 

manuals. World Services, LLC will conduct routine maintenance 

per manufactures recommendations and use flight and 

maintenance log data to track and record failed components.

Public interest

Use of the UAS in lieu of a manned aircraft would enhance safety 

and reduce the environmental impact as compared to similar 

operations conducted with manned aircraft of greater proportions, 

carrying flammable fuel and a crew. 

This petition will enable World Services, LLC to offer a level of 

service to property and facility owners or their designees that 

cannot be conducted economically or safely through ground level 

or other means of areal videography and or photographic 

inspection. 
Aerial marine and industrial inspections utilizing UAS’s can 

increase work site efficiency improve safety eliminating the need 

for safety harness and scaffolding and thus reducing risks to 

inspection personnel.

Surveying applications for requested exemption will considerably 

enhances accessibility while cutting costs and greatly improving 

public safety.

Additionally, commercial use of the UAS could lead to stimulation 

of economic growth.

Conclusion

The petitioner is requesting this exemption for the purposes of 

aerial photography, cinematography, videography, mapping, 

surveying, marine and industrial inspections and other flight 

operations.

World Services, LLC requests a broad based exemption so as to 

capitalize on opportunities as they may arise without additional 

exemptions. 

Although videography and photography are included in the 

request, the primary objective will be aerial data collection in 

efforts to mitigate the need for “man-lift”, rope access, ladders or 

scaffolding.

Respectfully submitted, 

Shaun Sutton

World Services, LLC

6562 McKinley St

Hollywood FL 33024

954 328 7535

World1@comcast.net

Attachment links:

DJI Inspire: www.dji.com/product/inspire-1/download

DJI Phantom Pro: www.dji.com/product/phantom-3/download

DJI Spreading Wings S1000+: www.dji.com/product/spreadingwings-s1000-plus/download
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World	Services,	LLC