Panther City Drones LLC

2318 5 5th Ave,

Fort Worth, TX, 76110

October 15, 2015

U.S. Department of Transportation 

Docket Operations 

1200 New Jersey Ave, SE 

Washington DC, 20590 

RE: Exemption Request Panther City Drones LLC. Under Section 333 of the 

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

To Whom It May Concern, 

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 and 14 C.F.R. Part 

11, Panther City Drones LLC. requests exemptions from several provisions of the Federal Aviation 

Regulations (“FARs”), specifically portions of 14 C.F.R. Parts 47, 61, and 91 to allow, among other things, 

commercial operations of a Tarot T-18 (“T-18”) in areas of the United States, by a Pilot in Command 

(“PIC”) holding a FAA issued Airman Certificate. Panther City Drones submits this application for 

approval of commercial operations for the T-18 as the relief requested in this document has been 

granted to others. Exemption 11409 and others, as set forth in this document, authorize the 

commercial operation of small UASs on terms and conditions that Panther City Drones accepts. 

The UAS

Panther City Drones proposes to use the T-18, a lightweight, battery-powered, ground-launched, 

small Unmanned Aerial System (“UAS”) in an Octocopter configuration that, depending on its payload, is 

capable of transmitting live airborne video images and location information to a Ground Control Station 

(“GCS”). The UAS will use 8 electric motors powered by Lithium Polymer Batteries The UAS is 

controlled by a Spektrum DX8 transmitter that uses select frequencies between 2.4 GHz to 2.4835 GHz. 

The Spektrum DX8 complies with Part 15 of the FCC rules and does not cause harmful interference. 

Furthermore, the controller will accept any interference received (see attached manual for the 

Spektrum DX8 radio system). The T-18 is designed for vertical take-off and landing (“VTOL”) with a 

maximum weight of 35 pounds, and a span of 1250mm from motor center to motor center. It has a 

flight endurance of around 20 minutes with a cruise speed of 35 knots in forward flight and typically 

operates at an altitude of less than 400 feet AGL. 

Panther City Drones proposes to fly the T-18, for the intended purpose of aerial surveying, 

agriculture, inspecting, aerial photography and video in controlled environments. Panther City Drones 

commitment to safety, combined with the controlled environments in which the T-18 will operate in 

make it clear that this Unmanned Aircraft (“UA”) can operate safely in the National Airspace System 

(“NAS”). 
The T-18 capabilities combined with our airman’s experience, make it ideally suited to conduct 

commercial operations in carefully controlled environments in both controlled (Class B, C, D, and E 

surface areas) and uncontrolled (Class G) airspace. T-18 operations will be conducted within Visual Line 

of Sight (“VLOS”) and typically conducted within 1500 feet of the Pilot in Command (“PIC”), therefore 

enhancing safety procedures. 

Acknowledging the FAA’s mission to provide the safest and most efficient airspace system in the 

world, commercial operations of the T-18 will comply with applicable FAR provisions as well as T-18 

operations manual in regards to operations and recommended maintenance procedures. Panther City 

Drones will only fly in airspace as allowed under the exemption granted to it and will coordinate with 

the FAA as necessary to ensure safe operations. 

As a result of the T-18 size, weight, maximum speed, and operational capability, the conditions 

in which it will operate near airports and populated areas; its operation within VLOS of the PIC; its 

operation within controlled boundaries; and its operation using a visual observer to provide conflict 

resolution from other air traffic, the T-18 does not create a hazard to other users of the NAS or the 

public. Therefore, the FAA should grant Panther City Drones the requested exemptions. Alternatively, if 

the FAA finds that modification of Panther City Drones 's application is required for safe operation of the 

UAS in the NAS, Panther City Drones requests that the FAA describe the required modifications and 

process Panther City Drones application as if the modifications were already made.

Panther City Drones recognizes that the FAA has granted exemption with similar circumstances 

as noted in FAA Exemption Nos. 11109, 11111, 11114, 11409 and others.

This exemption request encompasses the following regulations with discussion for each 

described herein: 14 C.F.R. Part 2114 C.F.R. 61.113(a) and (b), 14 C.F.R. 61.133(a), 14 C.F.R. 91.7 (a), 14 

C.F.R. 91.121, 14 C.F.R. 91.151 (b), 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)(2), and14 C.F.R. 91.417(a) & (b).

The name and address of the applicant are: 

PANTHER CITY DRONES, LLC.

2318 5th Ave, 

Fort Worth, TX 76110

Email: Steven.Frederickson@hotmail.com

Section 333's Mandate and the Federal Aviation Act 

Grant of this exemption application for use of the T-18 in aerial surveillance pursuant to the 

exemption requested herein will advance the Congressional mandate in Section 333 of the FAA Reform 

Act to accelerate the introduction of UASs into the NAS. Section 333 directs the Secretary of 

Transportation to consider whether certain UASs may operate safely in the NAS before completion of 

the rulemaking required under Section 333 of the FAA Reform Act. To make that determination, the 
Secretary must evaluate which types of UASs do not create a hazard to users of the NAS or the public or 

pose a threat to national security in light of several criteria: 

• The UAS's size, weight, speed, and operational capability; 

• Operation of the UAS in close proximity to airports and populated areas; and 

• Operation of the UAS within visual line of sight of the operator. 

FAA Reform Act § 333(b)(1). Once the Secretary determines that such vehicles "may operate 

safely in the national airspace system, the Secretary shall establish requirements for the safe operation 

of such aircraft in the national airspace system." 

The Federal Aviation Act expressly grants the FAA the authority to issue exemptions. 49 U.S.C. 

44701(f). This statutory authority, by its terms, includes exempting civil aircraft, as the term is defined 

under 40101 of the Act, from the requirements that all civil aircraft must have a current airworthiness 

certificate, 49 U.S.C. 44711(a), and those used in commercial service must be piloted by commercial 

pilots. 14 C.F.R. 61.113(a) and (b), 61.133. 

The grant of the requested exemption is in the public interest based on (i) the clear direction in 

Section 333 of the FAA Reform Act; (ii) additional authority in the Federal Aviation Act, as amended; (iii) 

the strong equivalent level of safety surrounding the proposed operations; and (iv) the significant public 

benefit, including enhanced safety and cost savings associated with utilizing UASs for aerial surveying, 

photography, inspection and research. Accordingly, Panther City Drones respectfully requests that the 

FAA grant the requested exemption without delay. 

Airworthiness 

Considering the controlled conditions in which the T-18 will operate, the precision involved in 

the manufacturing of the UAS, and recent advances in the technology involved in the control of UASs, 

the T-18 can be safely operated in the NAS without the issuance of a Standard Airworthiness Certificate. 

Due to the size and weight of the T-18, as well as its inability to carry passengers or cargo for 

compensation or hire, Panther City Drones proposes that an equivalent level of safety can be achieved. 

General Operating Standards

Panther City Drones proposes that the grant of the exemption be subject to the following 

conditions, which are based upon operating conditions set forth for operation of UASs by public entities 

pursuant to Certificates of Waiver or Authorization, and with additional restrictions: 

• All operations will occur within controlled areas. 

• Operations will be conducted over private or controlled-access property to limit the number of 

persons being placed at risk not associated with the operations. 

• Permission from land owner/controller required before commencing any flight. 

• Operations will occur during Visual Meteorological Conditions (“VMC”). 

• Aircraft will remain within Visual Line of Sight (“VLOS”). 
• Height Above Ground Level (“AGL”) altitude to be restricted to 400 feet. 

• Launch and recovery areas will be cordoned off to limit access only to personnel associated with 

the flight operation. 

• A Visual Observer (“VO”) will be utilized to maintain overall operation situational awareness, 

maintain VLOS and scan for intruder traffic.

• All operations conducted in vicinity of an airport will be in compliance with any ATC-COA issued 

by the controlling ATC facility or by prior arrangement with the airport manager if no ATC facility is 

present at the airport. . 

• Flight operations will be conducted at least 500 feet from all nonparticipating persons (persons 

other than the PIC or VO), vessels, vehicles, and structures unless: 

a. Barriers or structures are present that sufficiently protect nonparticipating persons from debris 

in the event of an accident. The operator will 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 UA, flight operations must cease immediately and/or; 

b. the aircraft is operated near vessels, vehicles or structures where the land owner/controller has 

granted permission and the PIC has made a safety assessment of the risk of operating closer to those 

objects and; 

c. Operations near the PIC or VO will not present an undue hazard to the PIC or VO, per 91.119(a). 

Proposed Operating Parameters 

Panther City Drones proposes to conduct all flights within VLOS of a pilot and observer and all 

flights will be limited to a maximum altitude of 400 feet AGL. To further enhance safety and a controlled 

environment, Panther City Drones only will allow authorized personnel in the operational area. On the 

ground, the launch site will be restricted from the public, and there will be a designated person to 

intercept anyone not authorized. This procedure not only protects non-authorized individuals, it also 

minimizes distractions for the flight crew. 

Pilot in Command

Panther City Drones will utilize pilots holding a current FAA issued airman certificate and 

medical, unless otherwise required by the FAA. Since the T-18 is very stable and light weight aircraft it 

can be easily controlled by any person with proper training. The automatic flight control system 

(“AFCS”) on the T-18 is highly integrated allowing for very precise positioning of the UAV by comparing 

current GPS coordinates and trends with preprogramed parameters. If the need arises due to 

unforeseen circumstances to take control of the UAV, the PIC can manually override the autopilot and 

safely control the UAV and its payload. The requirement to hold an FAA issued Airman Certificate will 

enhance the safety of the operation by allowing the T-18 to operate safely within the complexities of the 

NAS. 
Specific Regulatory Exemption Requests

14 C.F.R Part 21, Airworthiness Certificates.

Part 21 establishes the procedures for the issuance of airworthiness certificates. Due to 

continuing work by the FAA to develop airworthiness standards for UAS, and considering the size, 

weight, speed and limited operations area associated with the T-18; Panther City Drones requests 

exemption of this Part under the conditions of Sections 333.

14 C.F.R. 61.113(a) and (b), 61.133(a) - Private Pilot Privileges and Limitations: Pilot in Command.

61.113 subsections (a) and (b) prohibit private pilots from operating aircraft in commercial 

operations, and Section 61.133(a) requires an individual operating an aircraft for compensation or hire 

to hold a commercial pilot certificate. The FAA has the statutory authority to waive the pilot 

requirements for commercial operations. 49 U.S.C. 44701(f). Basis for exemption is as follows: Panther

City Drones requests an exemption from 14 C.F.R. 61.113(a) and (b) and 14 C.F.R. 61.133(a) so that the 

T-18 may be operated by individuals who hold a private pilot certificate

Based upon the design features of the T-18, its autopilot system, and safety factors, the FAA 

should permit operation of UASs by operators with a private pilot certificate when the conditions 

described above have been satisfied. The above-described conditions are in line with those set forth in 

Volume 16, Chapter 4, Section 1 of FAA Order 8900.1. Panther City Drones proposes to conduct 

operations in accordance with these restrictions. Given these conditions and restrictions, an equivalent 

level of safety will be provided by allowing operation of the T-18 with a private pilot certificate. The risks 

associated with the operation of the T-18 (given its size, speed, operational capabilities, and lack of 

combustible fuel) are much less than the level of risk associated with manned operations, both private 

and commercial, as contemplated by Part 61 and Part 91, that allowing operations of the Max 8-UAV, as 

set forth above, meets or exceeds the present level of safety provided under 14 C.F.R. 61.113(a) & (b) 

and 61.133(a). 

14 C.F.R. 91.7 (a) Civil Aircraft Airworthiness 

91.7 (a) requires that no person may operate a civil aircraft unless it is in airworthy condition. 

Should the exemption be granted allowing commercial operation of the T-18 without an airworthiness 

certificate, no standard will exist for airworthiness of the T-18. Given the size of the aircraft, the speed it 

will operate at, the procedures for operating and maintaining the aircraft as set forth in the manuals, an 

equivalent level of safety will be achieved. 

14 C.F.R. 91.121: Altimeter Settings 

91.121 requires that 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.” 

Since the UAV may not have a barometric altimeter, but instead use GPS triangulation to maintain 

altitude control, an exemption may be needed. An equivalent level of safety will be achieved by the 
operator as the UAS uses height AGL from its departure point, cross-referenced with height above mean 

sea level (“MSL”) of the launch point to determine altitude.

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

91.151(b) prohibits an individual from beginning "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.” 

The T-18 batteries provide up to20 minutes of powered flight. Without an exemption from 14 

C.F.R. 91.151 (b), the T-18 flights would be extremely limited in length. Given the nature of T-18 

controlled operations, a limitation on flight time would severely comprise its intended mission. 

Panther City Drones believes that an exemption from 14 C.F.R. 91.151(b) is safe and consistent 

with the scope of previous exemptions. Operating the T-18 without 20 minutes of reserves does not 

entail the type of risks that Section 91.151(b) was meant to prevent. The fact that the T-18 carries 

neither pilot or passenger also enhances its safety. Given its size, weight and construction material, the 

risks are less than envisioned by the current regulation.

Similar exemptions have been granted to others, including Exemptions 11062, 11067, 11080, 11409, 

and 11430.

14 C.F.R. 91.203 (a) and (b): Civil Aircraft: Certifications Required

91.203 (a) and (b) require that an airworthiness certificate, with the registration number 

assigned to the aircraft and a registration certificate must be displayed in the aircraft. Due to the size of 

the T-18, as well as the inability to carry passengers or crew, Panther City Drones request that this 

requirement be waived. To request an equivalent level of safety, Panther City Drones proposes that the 

documents deemed appropriate by the FAA for this aircraft be kept by the Crew at the ground control 

station for review if requested by the Administrator. 

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

91.405(a) requires that an aircraft operator or owner "(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." 

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 that an 

owner or operator 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.

Maintenance of the T-18 will be accomplished by the PIC/operator pursuant to the manuals 

provided by the Manufacturer. An equivalent level of safety will be achieved because the T-18 is small in 

size and will only operate in predetermined restricted areas. The T-18 PIC/operator will ensure that it is 

in working order prior to initiating flight, perform required maintenance, and keep a log of any 

maintenance that is performed. Furthermore, 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. Maintenance is very easy as the operator can simply swap out consumable parts and is 

competent in these procedures. A licensed airplane and power mechanic is not necessary. 

Public Interest

The use of the UAS in lieu of a manned aircraft would enhance safety and reduce the 

environmental impact as compared to the use of a manned aircraft carrying a crew and flammable fuel. 

Additionally the use of the UAS to facilitate commerce would lead to economic growth. Operations for 

this petition will enable service for property owners or their designees seeking an enhance perspective 

that cannot be achieved through normal ground based photography. Using the UAS for aerial 

photography provides a valuable marketing tool to real estate agents and other interested parties. By 

allowing the use of the UAS for aerial surveying, construction companies can greatly reduce the cost 

associated with a project, as well as enhance the safety of their workers by reducing the risk associated 

with a typical construction site. Also, the use of the UAS for agricultural surveying allows for a more 

efficient use of water and pesticides leading to a reduced environmental impact of these practices.

Panther City Drones will operate as an independent contractor to the general public, providing 

these services in a cost effective way that has traditionally not been available to them.

Conclusion

By granting the requested exemption, the FAA will allow Panther City Drones to benefit the 

public interest by promoting advancement and development of the technology available to the general 

public. The associated cost savings, combined with the technological advances associated with the 

emerging market of UAS, will directly benefit the public. Furthermore, by granting the Section 333 

exemption, the FAA will be fulfilling its Congressional mandate of the FAA Modernization and Reform 

Act of 2012 by advancing the interest of the public. Therefore, Panther City Drones respectfully 

requests that the FAA grant the exemption without undue delay.

Sincerely, 

Steven Frederickson