March, 1st 2016

U. S. Department of Transportation Docket Management System

West Building Ground Floor, Room w12-140

1200 New Jersey Ave,

SE Washington, DC 20590 

Patrick J. Walsh

EnableUAV LLC

1205 Main St.

Windermere, FL 34786

716-572-9930

Re: Exemption Request Section 333 of the FAA Reform Act of the Federal Aviation Regulations 

from 14 C.F.R. 45.23(b); 14 C.F.R. Part 21; 14 C.F.R. 61.113(a)&(b); 91.7(a); 91.9(b) (2); 

91.103(b); 91.109; 119.121; 91.151(a); 91.203(a)&(b); 91.405(a); 91.407(a) (1); 91.409(a) (2); 

91.417(a)&(b)

Dear Sir or Madam, 

I, Patrick Walsh, owner, founder, and manager of EnableUAV LLC (EnableUAV), am writing 

pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (Reform Act), 

Subsection (f) of 49 U.S.C. § 44701, and 14 C.F.R. Part 11, to request an exemption from the 

Federal Aviation Regulations (FARs) listed below and discussed in Appendix A to allow 

EnableUAV, to conduct commercial operations with small Unmanned Aircraft System (sUAS) to 

provide aerial film making, photography, videography, surveying, data acquisition, site, 

structural and patrolling inspections for pipeline, energy, utility, construction, real estate, 

precision agriculture and other industries, search and rescue, remote sensing, community 

awareness, education, training, research operations and other flight operations that could be 

performed safely and more cost effectively than a traditional manned aircraft.

Performing these services with a sUAS is in the public interest for several reasons, which are 

detailed further herein and include: (1) dramatically reducing safety risks inherent in manned 

operations, both in the air and on the ground; (2) inspecting locations where humans are not 

able visit without incurring substantial risk; (3) enhancing capabilities to utilize the sUAS to 

assist first responders on safety or environmental incidents; (4) and improving access to and 

control of various sites and operations. The use of the sUAS for these services will reduce the 

need to either operate manned aircraft in a difficult environment and reduce the environmental 

impact of conventional aircraft operations or add to the safety when other non-aircraft related 

methods prove hazardous or risky. In addition, the small, lightweight, and easily controllable 

operating characteristics of the sUASs’ provide for safe operations over site locations.

Exemptions Requested:

EnableUAV requests exemptions from the following regulations:

14 C.F.R. Part 21;

14 C.F.R. 45.23(b);

14 C.F.R. 61.113(a) and (b);

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

14 C.F.R. 91.119(c);
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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.F.R. 91.409(a)(1) and (2);

14 C.F.R. 91.417(a) and (b).

Operating Conditions:

EnableUAV requests an exemption subject to the conditions listed in Appendix B, which are 

substantially similar to the operating conditions required for the FAA’s previous grants of

exemptions under Section 333. In accordance with the conditions approved in previous 

exemption grants, EnableUAV is requesting authority to operate the sUAS within visual line of 

sight and below 400 feet AGL. EnableUAV will operate during daytime Visual Flight Rules (VFR) 

conditions, operate within visual line of sight (VLOS) of the pilots, and stay the requried

distances away from airports or heliports.

Operator Requirements:

As a condition to the grant of the exemptions, EnableUAV will require that the PIC hold at least 

a sport pilot certificate and 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 will 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. EnableUAV respectfully 

submits that the operator qualifications takes into account the operating conditions and 

characteristics of the particular sUAS in use.

Public Interest:

EnableUAV respectfully submits that its use of the sUAS in lieu of manned operations, which 

are currently conducted with conventional fixed and rotary winged aircraft, offers increased 

safety benefit and will achieve an enhanced level of safety, as mandated under Section 333(c) 

of the Reform Act. Approval of this application also will benefit the public interest by allowing 

better, safer, and more cost efficient information gathering for various industries. Conventional 

aerial survey and inspection operations using manned aircraft involve very heavy aerial vehicles 

that must transit to the operational location and carry significant quantities of combustible fuels 

and a multi-person crew in piloting and observation roles. These operations become even more 

difficult if the terrain is mountainous. By contrast, the sUAS lightweight, including its payload and 

use of batteries for power, allows it to be carried to and from the area of activity, removing the 

need for airborne pilots and observers, and poses less risk to people and infrastructure on the 

ground, as well as other aircraft. Additionally, no national security issues are or will be raised by 

the grant of the requested exemptions due to the sUAS small size and extremely limited loadcarrying capacity, as well as its operational limitations and absence of flammable fuel. On the 

other hand, the sUAS is likely to enhance national security through better and more accurate 

monitoring of critical national infrastructure. The grant of the requested exemption is in the 

public interest based on the clear direction in Section 333 and 49 U.S.C. § 44701(f), the 

equivalent and enhanced level of safety of the proposed operations, the significant public 

benefit, and cost savings to be realized as a result of the use of sUAS for aerial inspection and 

survey services. Moreover, the FAA has already granted similar exemptions for sUAS used to 
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conduct high-resolution aerial imaging and surveying operations. Accordingly, the applicant 

respectfully requests that the FAA grant the requested exemption without delay.

Federal Register Summary:

Pursuant to 14 C.F.R. § 11.81(f), the following summary is provided for publication in the 

Federal Register, should the FAA determine that publication is needed: Docket No.: No. FAA2016- Petitioner: EnableUAV. Section of 14 CFR: Part 21, § 45. 23(b), § 61.113(a) and (b), § 

91.7(a), § 91.119(c), § 91.121, § 91.151(a), § 91.405(a), § 91.407(a)(1), § 91.409(a)(2), § 

91.417(a) and (b). Description of Relief Sought: EnableUAV is seeking an exemption to conduct 

commercial operations using a small-unmanned aircraft (55 pounds or less) in the national 

airspace system (NAS) of the United States. Under 49 U.S.C. § 44701(f), the “Administrator 

may grant an exemption from a requirement of a regulation prescribed under subsection (a) or 

(b) of this section or any of sections 44702-44716 of [Title 49] if the Administrator finds the 

exemption is in the public interest.” See Exemption Nos. 11109, 11110, 11136, 11166, 11167, 

11170, 11172. EnableUAV requests that the FAA not request public comment on its application 

because it would not set a precedent and because the relief requested is identical to 

exemptions granted previously. 14 C.F.R. § 11.87. 

Sincerely,

Patrick J. Walsh

Owner and Manager

EnableUAV LLC
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APPENDIX A

EXEMPTION REQUEST AND EQUIVALENT LEVEL OF SAFETY SHOWINGS UNDER 

APPLICABLE RULES SUBJECT TO EXEMPTION:

EnableUAV requests an exemption from the following regulations as well as any additional 

regulations that may technically apply to the operation of the sUAS:

14 C.F.R. Part 21, Subpart H: Airworthiness Certificates:

Part 21, Subpart H, entitled Airworthiness Certificates, establishes the procedural requirements 

for the issuance of airworthiness certificates as required by § 1.203(a)(1). Given the size and 

weight of the aircraft, the operating conditions, design safety features, and the proposed 

conditions and limitations, it is unnecessary to go through the certificate of airworthiness 

process under Part 21 Subpart H to achieve or exceed current safety levels. Such an exemption 

meets the requirements of an equivalent level of safety under Part 11 and Section 333. Section 

333 and 49 U.S.C. § 44701(f) both authorize the FAA to exempt aircraft from the requirement 

for an airworthiness certificate, upon consideration of the size, weight, speed, operational 

capability, and proximity to airports and populated areas of the sUAS involved. In this case, an 

analysis of these criteria demonstrates that the sUAS operated without an airworthiness 

certificate, under the conditions proposed herein, will be at least as safe, or safer, than a 

conventional aircraft (fixed wing or rotorcraft) with an airworthiness certificate. The sUAS weighs 

less than 10 pounds fully loaded. It will not carry a pilot, passenger or flammable fuel. The sUAS 

operates exclusively within a controlled area pre-disclosed and in compliance with conditions 

set forth herein. Unlike other civil aircraft, operations under this exemption will be tightly 

controlled and monitored by the PIC and observer(s), pursuant to the conditions set forth in 

Appendix B, the Operator’s Manual, and local public safety requirements. The FAA will have 

advance notice of all operations through the filing of NOTAMs. The lack of flammable fuel and 

the fact that the aircraft is carried to the location and not flown there all establish the equivalent 

level of safety. The sUAS provides at least an equivalent level of safety to that of such 

operations being conducted with conventional aircraft that would be orders-of-magnitude larger 

and would be carrying passengers, cargo, and flammable fuel.

14 C.F.R. § 45.23 (b). Marking of the Aircraft:

The regulation requires that 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. 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 sUAV, two-inch lettering will be impossible. 

The word “Experimental” will be placed on the fuselage in compliance with §45.29 (f). The 

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

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

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

regulation to Exemptions Nos. 10700, 8738, 10167 and 10167A.
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14 C.F.R. §§ 61.113(a) & (b): Commercial Pilot Privileges:

Sections 61.113(a) & (b) limit private pilots to non-commercial operations. Unlike a conventional 

aircraft that carries a pilot, passengers, and cargo, the sUAS is remotely controlled with no 

passengers or property of others on board. The area of operation is controlled and restricted, 

and all flights are planned and coordinated in advance as set forth in the Operator’s Manual. In 

conjunction with the required training of the PIC and observers, the level of safety provided by 

the requirements included in the Operator’s Manual exceeds that provided by a single individual 

holding a commercial pilot certificate operating a conventional aircraft. The proposed operations 

will achieve at least an equivalent level of safety.

14 C.F.R. § 91.7(a): Minimum Safe Altitudes:

Section 91.7(a) prohibits an individual from operating a civil aircraft unless it is in an airworthy 

condition. No FAA standard exists for determining an aircraft’s airworthiness when an 

airworthiness certificate is not issued. As the FAA has done with previous exemption grants, 

airworthiness will be ensured and an equivalent level of safety will be achieved by compliance 

with the operating documents prior to every flight.

14 C.F.R. § 91.119(c): Minimum Safe Altitudes:

Section 91.119 establishes safe altitudes for operation of civil aircraft. Specifically, Section 

91.119(c) limits aircraft flying over areas other than congested areas to 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. 

Because some of the aerial inspection and survey work must be accomplished at altitudes less 

than 500 feet AGL and nonparticipating employees may be working within 500 feet of the sUAS, 

an exemption from Section 91.119(c) is needed. The equivalent level of safety will be achieved 

because the sUAS, given its size, weight, speed, and materials, does not pose a serious risk. 

Also, every flight will be conducted over land controlled by EnableUAV. EnableUAV will notify 

all effected individuals of sUAS operations in advance to ensure they are aware of the planned 

flights. Compared to aerial inspection operations conducted with aircraft or rotorcraft weighing 

far more than 10 pounds and carrying flammable fuel, any risk associated with these operations 

will be far less than those currently allowed with conventional aircraft operating at or below 500 

feet AGL. Exemption Nos. 11156, 11158, 11159.

14 C.F.R. § 91.121: Altimeter Setting:

Section 91.121 requires each person operating an aircraft to maintain cruising altitude by 

reference to an altimeter that is set “to the elevation of the departure airport or an appropriate 

altimeter setting available before departure.” As the sUAS may not have a barometric altimeter, 

but instead a GPS altitude read out, an exemption is required. An equivalent level of safety will 

be achieved by the operator, pursuant to the Operator’s Manual, confirming the altitude of the 

launch site shown on the GPS altitude indicator before flight.

14 C.F.R. § 91.151(a): Fuel Requirements for Flight in VFR Conditions:

The regulation provides that no person may begin a flight in an airplane under day-VFR 

conditions unless there is enough fuel to fly to the first point of intended landing and to fly after 

that for at least 30 minutes. We feel the intention of this paragraph is to provide an energy 

reserve as a safety buffer for delays to landing. The sUAS are battery operated and the 

maximum duration of flight from a single battery charge is 12-45 (depending on which sUAS) 
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minutes with a 20% reserve. Since the aircraft will never fly more than 1/2 NM from the point of 

intended landing, a full battery charge at launch will ensure that we meet the reserve energy 

requirement of this paragraph. We request an exemption to the word "fuel" and ask for an 

equivalent interpretation with the word "energy". We also request exemption from the 30 min 

reserve and ask that our reserve will be to fly the mission to the point of intended landing and 

have at least a 20% battery reserve after that.

14 C.F.R. §§ 91.405(a), 91.407(a)(1), 91.409(a)(1) and (2), and 91.417(a) and (b): 

Maintenance Inspections:

Section 91.405(a) requires that an aircraft operator or owner “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.” Section 91.407 similarly makes reference to requirements in Part 43. Section 

91.409(a)(2) requires an annual inspection for the issuance of an airworthiness certificate. 

Section 91.417(a) requires the owner or operator to keep records showing certain maintenance 

work that has been accomplished by certificated mechanics, under Part 43, or licensed pilots 

and records of approval of the aircraft for return to service. A qualified person prior to each flight 

and at predefined intervals as part of the maintenance schedule will perform pre-flight checks.

The pre-flight checklist includes but may not be limited to:

1. Visual inspection of the airframe;

2. Visual inspections of propeller;

3. Verify GPS acquisition;

4. Plan and upload mission;

5. Video and payload check;

6. Controls check;

7. Gyro/control surfaces check;

8. Throttle check

9. Altimeter check;

10. Check sensors; and

11. Verify failsafe’s are set correctly.

An equivalent level of safety will be achieved because the sUAS will carry no external payload, 

will operate only in restricted predetermined areas, and is not a complex mechanical device. In 

addition, the operator will ensure that the sUAS is in working order prior to initiating flight, 

perform required maintenance, and keep a log of any maintenance that is performed. Moreover, 

the operator is the person most familiar with the aircraft and is best suited to maintain the 

aircraft in an airworthy condition and to ensure an equivalent level of safety. Last, the Operator’s 

Manual will have instructions to develop and document maintenance, overhaul, replacement, 

and inspection requirements in the absence of EnableUAV requirements, and procedures to 

document and maintain maintenance records for the sUAS. The sUAS maintenance guidelines 

provide an equivalent level of safety to the maintenance requirements in Part 91.
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APPENDIX B

OPERATING LIMITATIONS:

1. Operations authorized by the grant of exemption are limited to a UAS that weighs less 

than 55 lbs.

2. The UAS will not be operated at a speed exceeding 87 knots (100 miles per hour) based 

on either groundspeed or calibrated airspeed to determine compliance with the 87 knot 

speed restriction. In no case will the sUAS be operated at airspeeds greater than the 

maximums UAS operating airspeed recommended by the aircraft manufacturer.

3. The UAS will not be operated at an altitude more than 400 feet above the highest 

predominant terrain except as may be provided by FAA Air Traffic Control (ATC) via 

COA.

4. The UAS 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.

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) 

maybe 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 under this exemption. 
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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.

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 UAS 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 UAS 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 
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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. For tethered UAS operations, the tether line must have colored pennants or streamers 

attached at not more than 50 foot intervals beginning at 150 feet above the surface of 

the earth and visible from at least 1 mile. This requirement for pennants or streamers is 

not applicable when operating exclusively below the top of and within 250 feet of any 

structure, so long as the UA operation does not obscure the lighting of the structure.

18. If the UAS loses communications or loses its GPS signal, the UAS must return to a predetermined location within the private or controlled-access property.

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

20. 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 5 minutes or with the reserve power 

recommended by the manufacturer if greater.

21. 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 enclosed COA.

22. 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 

(N−Number) markings in accordance with 14 CFR part 45, Subpart C. Markings must be 

as large as practicable.

23. 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.

24. The UAS must remain clear and give way to all manned aviation operations and 

activities at all times.

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

27. The PIC, VO, operator trainees or essential persons are not considered nonparticipating 

persons under this exemption.

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

permission from the property owner/controller or authorized representative. Permission 

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

flight to be conducted.

29. 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.
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APPENDIX C

CONTACT INFROMATION, BACKGROUND, SMALL UNMANNED AERIAL SYSTEM 

DESCRIPTION:

Contact Information:

Patrick J. Walsh

EnableUAV LLC

1205 Main St, 

Windermere, FL 34786

Phone: 716-572-9930

Email: patrick@EnableUAV.com

Background:

Patrick Walsh has a background that offers benefits to the sUAS community and he wants to 

help further the progress in safely integrating sUAS into the national airspace system (NAS). 

Patrick holds a Bachelor’s and Master’s Degree in Aerospace / Mechanical Engineering, a MBA, 

and spent most of his career working at our nation’s largest defense contractor, Lockheed 

Martin. While at Lockheed, he held a DOD security clearance for almost 10 years. He has been 

safely flying UAS recreationally for over 2 years, he is a sUAS and aviation enthusiast, and he 

aspires to be a leader in the sUAS community. EnableUAV is Limited Liability Corporation, filed 

within the State Laws of Florida. Through EnableUAV, Patrick intends to help small businesses 

within his community who could not otherwise afford the services typically done with large 

manned aircraft by offering safe and affordable services with small Unmanned Aerial Systems.

sUAS Overview:

EnableUAV is submitting this request for exemption for the following professionally built sUAS 

aircraft:

1. DJI Phantom 4

2. DJI Phantom 3

3. DJI Inspire 1

4. DJI Matrice 100

5. Yuneec Q500

6. 3DR Solo

7. Aeryon Labs SkyRanger

These commercially available systems from DJI, 3DR, Aeryon Labs and Yuneec have been 

shown to be reliable and have all been approved aircraft on other current exemptions.

EnableUAV has expertise and knowledge in the operations of these systems. These sUAS all 

weigh less than 25 lbs; have a built-in capability to limit the height it flies above the ground, to 

limit the radius of the distance it flies from the operator and to exclude it from Class B, C and D 

airspace. Each system also has the failsafe function of the autopilot system, which means when 

the communication between the Main Controller and the transmitter is lost; the system will 

automatically trigger Return to Home and will land safely.

EnableUAV at all times will respect the space and privacy of citizens and property while keeping 

our skies safe. We respectfully request, without delay, an exemption under Section 333 to 

enable EnableUAV LLC to operate safe, low-risk commercial sUAV operations for the activities 

stated.