U.S. Department of Transportation 

Docket Management System 

1200 New Jersey Ave.SE 

Washington, DC 20590 

To whom it may concern: 

Everything Aviation LLC is seeking an exemption from the Federal Aviation Regulations for the DJI 

Phantom series UAS and the DJI Inspire series UAS at this time. 

The exemption is being requested to provide services for aerial surveying, videography, photography, 

inspection, agriculture, forestry services, search and rescue and other services needed by the aircraft we 

provide. 

The UAS will be operated at weight less than 55 pounds, will not exceed 87 knots, and will be flown at 

altitude 400 AGL or less. With the following additional restrictions: 

-All UAS flights will remain clear of all manned aviation operations at all times 

-Private land operations will have permission before conducting flight 

-Local authorities will be notified if operations will be near or around public events with details 

of what the flight paths will be. 

-Operations will be conducted under day visual meteorological conditions. 

-The UA will not be operated within 5 nautical miles of any airport unless prior coordination is 

made with ATC. 

-No flights will be conducted from another moving vehicle 

Each UA will be operated in line of sight of the PIC without using any visual aiding device. If the flight 

requires a visual observer, he or she can be used to satisfy the VLOS requirement providing that the VO 

is in contact with the PIC. 

Prior to each flight the PIC will conduct a preflight inspection to ensure the UA is safe for flight and 

follow directions described in the manufacturers manuals provided with each UAS. 

Any discrepancy that could cause and unsafe condition for flight should be repaired and a return to 

service flight performed before the UAS is returned to service. This also includes any scheduled 

preventative maintenance required by the manufacturer. 

PIC's will have at least Sport pilot rating or greater with current driver's license, or may be appointed by 

the chief pilot. 

The following exemptions are being requested: 

• 14 CFR Part 21 

• 14 CFR 91.203 

• 14 CFR 42.23 

• 14 CFR 61.23 

• 14 CFR 61.113, 61.133 
• 14 CFR 91.7, 91.9 

• 14 CFR 91.109 

• 14 CFR 91.119 

• 14 CFR 91.121 

• 14 CFR 91.151 

• 14 CFR Subpart E (91.401-91.4178) 

Exemptions Request and Equivalent level of Safety 

14 CFR Part 21 Subpart H: Airworthiness Certification 

Everything Aviation is requesting exemption from this requirement based the aircrafts size, weight, 

speed, and operational capability. Or confirmation that the requirements have been met provided in 

section 333 and that relief from this requirement is not necessary. 

14 CFR 91.203 (a) and (b) Civil Aircraft: Certifications required 

Based on previous research, the FAA has not issued a certification based on the criteria provided in 

section 333 and the operator will insure that all documents will be present pertaining to the UAS being 

operated at the time 

14 CFR 91.9 Civil aircraft flight manual, marking, and placard requirements 

All aircraft will be identified by serial number, registered in accordance with 14 CFR part 4 7, 

and have identification(N-Number) markings in accordance with 14 CFR part 45, Subpart C. 

Markings must be as large as practicable. 

14 CFR 61.113 Private pilot privileges and limitations: Pilot in command and 61.133 Commercial 

pilot privileges and limitations. 

Everything Aviation's chief pilot is currently an active ATP, Flight Instructor, A&P, IA. PIC's will have 

at least Sport pilot rating or greater with current driver's license. The chief pilot would like to have the 

ability to authorize a PIC if he or she demonstrates the ability to control the UAS safely and has been 

given ground instruction as well as flight instruction on the airspace systems in place. All which has been 

logged. 

14 CFR 91.109 Flight Instruction: Simulated instrument flight and certain flight tests 

The current systems do not allow for dual controls needed for 91.109. The controls are a single hand 

held radio system. Based on the experience in remote control aircraft that the chief pilot has using one 

control and both pilots having hands on can happen simultaneously. 

14 CFR 91.119 Minimum safe Altitudes 
At this time the UAS will be operated at an altitude of 400 feet or less. Since the regulations states that 

the aircraft cannot be operated closer than 500 feet, we cannot comply. PIC's must ensure that the 500 

foot requirement is maintained for all non-participating persons, vessels, vehicles, and structures unless 

prior arrangements have been made with the persons or owners. Risk Assessments should be made. 

14 CFR 91.121 Altimeter settings 

The UAS will be operating at 400 feet AGL and below and doesn't have the ability to make changes to 

barometric pressure. This is done digitally and with GPS. Before each flight the aircraft AGL altitude is set 

to zero and based on the short flight times will not be effected to produce a hazard to manned aircraft. 

14 CFR 91.151 Fuel requirements for flight in VFR conditions 

Fuel is not required for flight on the UAS. They use battery packs with approximately 30 minutes of 

flight. The PIC must ensure that the battery has enough power for the intended flight time with the 

recommendations from the manufacturer to terminate the flight when the systems warns you. Being 

that the UAS is within LOS this will be more than enough time. 

14 CFR Subpart E (91.4.1-91.417) Maintenance, Preventive Maintenance, and Alterations 

The UAS will be maintained lAW the manufactures maintenance, overhaul, replacement, inspection, and 

life limit requirements for all components. Repairs made will either be done by manufacture or per their 

instruction. logs will be kept for each UAS and maintenance documented. A functional check will be 

done and a return to service flight performed. 

14 CFR 91.103(b) Preflight Action 

Preflight and Post flight inspections will be done on each UAS by the PIC. He will also review all weather 

and surrounded areas before each flight for risk analysis. 

Matthew Hall 

Manager/Chief Pilot 

Everything Aviation 

100 Arapahoe Dr. 

lafayette, La 70503 

540-421-6076