UNITED STATES OF AMERICA 

DEPARTMENT OF TRANSPORTATION 

FEDERAL AVIATION ADMINISTRATION 

WASHINGTON, DC

IN THE MATTER OF THE PETITION FOR EXEMPTION OF:

DELAND DRONES

FOR AN EXEMPTION SEEKING RELIEF FROM THE REQUIREMENTS OF TITLE 14 OF 

THE CODE OF FEDERAL REGULATIONS SECTIONS: 61.113(a) & (b), 91.7(a), 91.121, 91.151

(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), AND 91.417(a) & (b) CONCERNING 

COMMERCIAL OPERATION OF A TURNIGY TALON 500 QUADCOPTER AND A TARROT 

680 PRO HEXACOPTER UNMANNED AIRCRAFT SYSTEMS PURSUANT TO SECTION 333 

OF THE FAA MODERNIZATION AND REFORM ACT OF 2012 (PUBLIC LAW 112-95)

Submitted on March 29, 2015

Deland Drones

Christopher Sammons

217 E. Parkdale Ave.

Deland, Fl. 32724

321-228-7714

chris@delanddrones.com

Student Pilot/3rd class medical GX-0801175
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AGL

AOI

ATC

ATO

AV

CFR

COA

FAA

FAR

GCS

GPS

LOL

NAS

NOTAM

PIC

Section 333

SO

SOP

UA

UAS

UAV

VFR

VLOS

VMC

VTOL

GLOSSARY OF ABBREVIATIONS

Above Ground Level

Area of Interest

Air Traffic Control

Air Traffic Organization

Aerial Vehicle

Code of Federal Regulations

Certificate of Authorization

Federal Aviation Administration

Federal Aviation Regulation 

Ground Control Station 

Global Positioning System

Loss of Link 

National Airspace System

Notice to Airman

Pilot In Command

FAA Modernization and Reform Act of 2012 (FMRA) Section 333

Safety Observer

Standard Operating Procedures

Unmanned Aircraft

Unmanned Aircraft System

Unmanned Aerial Vehicle

Visual Flight Rules

Visual Line of Site

Visual Meteorological Conditions

Vertical Takeoff and Landing
3

SUMMARY

 Deland Drones seeks exemption from the requirements of 14 C.F.R §§ 61.113(a) & 

(b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 

91.417(a) & (b), to operate an Unmanned Aircraft System pursuant to Section 333 of the 

FAA Modernization and Reform Act of 2012 (FMRA). This exemption will permit 

Deland Drones to operate Unmanned Aircraft Systems, small (UASs) for the commercial 

purpose of conducting aerial video and photography of construction sites, real estate, 

events, landscape as well as perform over video certain areas of the United States. 

INTRODUCTION AND INTERESTS OF THE PETITIONER

 Deland Drones provides its clients with expertise and knowledge in advanced 

technologies and solutions to increase efficiency, productivity and effectiveness. 

Christopher Sammons, founder of Deland Drones has over has over 20 years recreational /

hobby experience in all aspects of aerial video and photography, and over 500 hours of 

flight time on various sizes Unmanned Aerial Vehicles (UAV). The objective of Deland 

Drones aerial video and photography operations is to provide high quality imaging for a 

variety of commercial, public, residential and governmental uses, specifically targeting:

• Construction sites before and after

• Events public and private

• Real-estate marketing

• Aerial acquisitions used for inspections of public and private structures.

• Search and Rescue operations

BACKGROUND

Unmanned Aircraft Systems: Turnigy Talon 500 and Tarrot 680pro UAVs

 Deland Drones seeks an exemption to operate UASs for compensation or hire 

within the NAS. The Turnigy Talon 500 quadcopter and the Tarrot 680Pro hexacopter are 

vertical takeoff and landing (VTOL) Unmanned Aerial Vehicle (UAV) with a Ground 

Control Station (GCS) utilizing electronic tablet or laptop. The Turnigy Talon 500 has a 

maximum gross weight of approximately 6 pounds, while having a length of 14 inches 

width of 14 inches, height of 5 inches, and a maximum speed of approximately 50 knots. 

The Tarrot 680Pro has a maximum gross weight of approximately 8 pounds, a length of 26 

inches, width of 26 inches, height of 11 inches, and a maximum speed of approximately 60 

knots. The Turnigy Talon 500 quadcopter UAVs is equipped with four main rotors; driven 

by a 11.1 Lithium Polymer battery powered electric motors, and the Tarrot 680Pro 

hexacopter is equipped with six main rotors; driven by a 14.8 Lithium Polymer battery 

powered electric motors.
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 The Turnigy Talon 500 quadcopter and the Tarrot 680Pro hexacopter UAVs that will be 

operated by Deland Drones will be registered in accordance with 49 U.S.C. 44103, 

Registration of Aircraft, as well as 14 C.F.R Part 47, Aircraft Registration, and marked in 

accordance with 14 C.F.R. Part 45, Identification and Registration Marking.

BASIS FOR PETITION

 Petitioner, Deland Drones, pursuant to the provisions of the Federal Aviation 

Regulations (14 C.F.R. § 11.61) and the FAA Modernization and Reform Act of 2012 

(FMRA), Section 333, Special Rules for Certain Unmanned Aircraft Systems, hereby 

petitions the Administrator to commercially operate The Turnigy Talon 500 quadcopter and 

the Tarrot 680Pro hexacopter in the National Airspace System (NAS), and for an exemption 

from the requirements of 14 C.F.R §§ 61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 91.405(a), 

91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b). 

 In consideration of the speed, weight, size, and limited operating area associated with the 

unmanned aircraft and its operation, Deland Drones operation of The Turnigy Talon 500 

quadcopter and the Tarrot 680Pro hexacopter UAVs meets the conditions of FMRA Section 

333 and therefore, will not require an airworthiness certificate in accordance with 14 C.F.R. 

Part 21, Subpart H. 

 Accordingly, Deland Drones requests relief from Sections 91.405(a), 91.407(a)(1), 

91.409(a)(1) & (a)(2), and 91.417(a) & (b), as these sections set forth requirements for 

maintenance that only apply to aircraft with an airworthiness certificate. 

 Deland Drones submits that the requested relief is proper since an equivalent level of 

safety will be ensured. Deland Drones will use experienced personnel or technicians to 

perform maintenance, alterations, or preventive maintenance on the UASs using the 

methods, techniques, and practices prescribed in the operating documents (i.e., Monthly 

Maintenance Log, and Instruction Manuals). Furthermore, Deland Drones will document and 

maintain all maintenance records for The Turnigy Talon 500 quadcopter and the Tarrot 

680Pro hexacopter UAVs. 

 Relief from certain requirements of Section 61.113(a) and (b), entitled Private pilot 

privileges and limitations: Pilot in command, is requested by Deland Drones to the 

extent necessary to allow a Pilot in Command (PIC) holding a student pilot, private pilot or 

higher level certificate, as well as an airman medical certificate, and who has demonstrated, 

by meeting minimum flight- hour and currency requirements, that the PIC is able to safely 

operate The Turnigy Talon 500 quadcopter and the Tarrot 680Pro hexacopter UAVs in a 

manner consistent with this exemption, including evasive and emergency maneuvers and 

maintaining appropriate distances from people, vessels, vehicles and structures. 

 Deland Drones seeks relief from Section 91.7(a), entitled Civil aircraft airworthiness, 

because the The Turnigy Talon 500 quadcopter and the Tarrot 680Pro hexacopter UAVs do 

not require an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H. As 

such, Deland Drones submits that he will ensure that The Turnigy Talon 500 quadcopter and 

the Tarrot 680Pro hexacopter are in an airworthy condition, prior to every flight, by 

determining hat the UAVs are in compliance with the operating documents
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(i.e., Monthly Maintenance Log, Instruction Manuals), and that the aircraft are in a 

condition for safe flight. 

 Deland Drones also seeks an exemption from the requirements of Section 91.121, 

entitled Altimeter Settings, as The Turnigy Talon 500 quadcopter and the Tarrot 680Pro 

hexacopter UAVs will not have a typical barometric altimeter onboard. However, altitude 

information of The Turnigy Talon 500 quadcopter and the Tarrot 680Pro hexacopter UAVs 

will be provided to the PIC via Global Positioning System (GPS) equipment, and radio 

communications telemetry data link, which downlinks from the UAVs to the GCS for 

active monitoring of the flight path. This altitude information, combined with Deland 

Drones’ operation of The Turnigy Talon 500 quadcopter and the Tarrot 680Pro hexacopter 

UAVs within visual line of sight, at or below 500 feet AGL, will ensure a level of safety 

equivalent to Section 91.121. 

 Additionally, Deland Drones seeks an exemption from the requirements of Section 

91.151(b), entitled Fuel requirements for flight in VFR conditions. Deland Drones submits 

that safety will not be affected by operation of The Turnigy Talon 500 quadcopter and the 

Tarrot 680Pro hexacopter UAVs during daylight hours in visual meteorological conditions 

(VMC) under visual flight rules (VFR), with enough battery power to fly for a total 

duration of approximately 25 minutes to the first point of intended landing and, assuming 

normal cruising speed, to fly after that for at least 5 minutes. 

 In accordance with 14 C.F.R. § 11.81, Deland Drones provides the following 

information in support of its petition for exemption:

A. Name And Address Of The Petitioner.

The name and address of the Petitioner and point of contact is:

Deland Drones

Christopher Sammons, owner/founder

217 E. Parkdale Ave.

Deland, Fl. 32724

321-228-7714

chris@delanddrones.com

B. The Specific Sections Of 14 C.F.R. From Which Deland Drones Seeks Exemption. 

1. Deland Drones Seeks Exemption From The Requirements Of Section 

61.113(a) And (b). 

Section 61.113, entitled Private pilot privileges and limitations: Pilot in command, 

subsections (a) and (b) prescribe the following, in relevant part: 

(a) No person who holds a private pilot certificate may act as a pilot in command 

(PIC) of an aircraft that is carrying passengers or property for compensation or 

hire; nor may that person, for compensation or hire, act as PIC of an aircraft. 
6

(b) A private pilot may, for compensation or hire, act as PIC of an aircraft in 

connection with any business or employment if—

(1) The flight is only incidental to that business or employment; and 

(2) The aircraft does not carry passengers or property for compensation or hire. 

2.Deland Drones Seeks Exemption From The Requirements Of Section 

91.7(a).

Section 91.7, entitled Civil aircraft airworthiness, subsection (a), states the 

following: 

(a) No person may operate a civil aircraft unless it is in an airworthy condition. 

3. Deland Drones Seeks Exemption From The Requirements Of Section 

91.121. 

Section 91.121, entitled Altimeter settings, subsection (a), states the following, in 

part: 

(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 

available station; or 

(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. 

4. Deland Drones Seeks Exemption From The Requirements Of Section 

91.151(b).

Section 91.151, entitled Fuel requirements for flight in VFR conditions, subsection

 (b), states the following: 

(b) No person 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.
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5.Deland Drones Seeks Exemption From The Requirement Of Section 

91.405(a).

Section 91.405, entitled Maintenance required, subsection (a), states the following: 

Each owner or operator of an aircraft—

(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[.] 

6. Deland Drones Seeks Exemption From The Requirements Of Section 

91.407(a)(1) 

Section 91.407, entitled Operation after maintenance, preventive maintenance, 

rebuilding, or alteration, subsection (a)(1), states the following: 

(a) No person may operate any aircraft that has undergone maintenance, preventive 

maintenance, rebuilding, or alteration unless--

(1) It has been approved for return to service by a person authorized under § 43.7 

of this chapter. 

7. Deland Drones Seeks Exemption From The Requirements Of Sections 

91.409(a)(1) And 91.409(a)(2). 

Section 91.409, entitled Inspections, subsection (a), states the following:

(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 airworthiness certificate in accordance 

with part 21 of this chapter. 

8. Deland Drones Seeks Exemption From The Requirements Of Sections 

91.417(a) And 91.417(b). 

Section 91.417, entitled Maintenance records, subsections (a) and (b), state the 

following: 

(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 
8

inspections, as appropriate, for each aircraft (including the airframe) and each 

engine, propeller, 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 certificate 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 parts 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, including 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. 

(b) The owner or operator shall retain the following records for the periods 

prescribed: 

(1) The records specified in paragraph (a)(1) of this section shall be retained until 

the work is repeated or superseded by other work or for 1 year after the work 

is performed. 

(2) The records specified in paragraph (a)(2) of this section shall be retained and 

transferred with the aircraft at the time the aircraft is sold. 
9

(3) A list of defects furnished to a registered owner or operator under § 43.11 of 

this chapter shall be retained until the defects are repaired and the aircraft is 

approved for return to service. 

C. The Extent Of Relief Deland Drones Seeks And The Reason Deland Drones Seeks 

The Relief. 

1. Extent Of Relief Deland Drones Seeks And The Reason Deland Drones Seeks 

Relief From Section 61.113(a) And (b). 

 Relief from Section 61.113(a) and (b) entitled Private pilot privileges and limitations: 

Pilot in command, is requested to the extent necessary to allow a PIC holding a private 

pilot or higher level certificate, as well as a current and valid airman medical certificate, 

and who has met certain flight-hour and currency requirements, to conduct the proposed 

UAVs flight operations for compensation or hire. 

 This relief is requested since the limitations set forth in Section 61.113(a) and (b) state 

that a private pilot may, for compensation or hire, act as PIC of an aircraft in connection 

with any business or employment if: (1) The flight is only incidental to that business or 

employment; and (2) The aircraft does not carry passengers or property for compensation 

or hire. 

 As set forth more fully below, Deland Drones submits that an equivalent level of 

safety will be maintained because no PIC will be allowed to operate The Turnigy Talon 500 

quadcopter nor the Tarrot 680Pro hexacopter UAVs unless that PIC has met certain 

flight-hour and currency requirements, demonstrating that the PIC is able to safely operate 

either The Turnigy Talon 500 quadcopter or the Tarrot 680Pro hexacopter UAVs in a 

manner consistent with the operations specifications as described in this exemption, 

including evasive and emergency maneuvers, as well as maintaining appropriate distances 

from people, vessels, vehicles and structures.

 Further, Deland Drones submits that all flights of The Turnigy Talon 500 quadcopter and 

the Tarrot 680Pro hexacopter UAVs, conducted by the PIC pursuant to the grant of this 

Petition: (1) will be incidental to Deland Drones business; and (2) will not carry passengers 

or property for compensation or hire. 

2. Extent Of Relief Deland Drones Seeks And The Reason Deland Drones 

Seeks Relief From Section 91.7(a). 

 Relief from Section 91.7(a) entitled Civil aircraft airworthiness, is requested to the 

extent required to allow Deland Drones to determine The Turnigy Talon 500 quadcopter and 

the Tarrot 680Pro hexacopter UAVs are in airworthy condition prior to every flight by 

ensuring that the UAVs is in compliance with the operating documents (i.e., the Deland 

Drones Aerial Operations Manual, Flight log, Monthly Maintenance Log, and Instruction 

Manuals). 

 Deland Drones seeks the requested relief because The Turnigy Talon 500 quadcopter and 

the Tarrot 680Pro hexacopter UAVs do not require an airworthiness certificate in accordance 

with 14 C.F.R. Part 21, Subpart H. Therefore, Deland Drones will ensure that The Turnigy 
10

 Talon 500 quadcopter and the Tarrot 680Pro hexacopter UAVs are in airworthy condition 

based upon its compliance with the operating documents (i.e., Monthly Maintenance Log, 

and Instruction Manuals) prior to every flight, and further, determine that the aircraft are in 

condition for safe flight, as stated in the conditions and limitations below.

3. Extent Of Relief Deland Drones Seeks And The Reason Deland Drones 

Seeks Relief From Section 91.121.

 Relief from Section 91.121, entitled Altimeter settings, may be required to allow flight 

operations of The Turnigy Talon 500 quadcopter and the Tarrot 680Pro hexacopter UAVs, 

which utilize a barometric pressure sensor, GPS equipment, and a radio communications 

telemetry datalink to downlink altitude information from the UA to the PIC at the ground 

control station (GCS). Since the FAA requires that any altitude information concerning 

UAVs operations be reported to air traffic control (ATC) in feet above ground level 

(AGL), Deland Drones seeks the requested relief because The Turnigy Talon 500 

quadcopter and the Tarrot 680Pro hexacopter UAVs altimeter may be set on the ground to 

zero feet AGL, rather than the local barometric pressure or field altitude, before each flight. 

 Considering the limited altitude of the proposed operations, relief from 14 CFR 91.121 

is sought to the extent necessary to comply with the applicable conditions and limitations 

stated below. As more fully set forth herein, an equivalent level of safety will be 

maintained since The Turnigy Talon 500 quadcopter and the Tarrot 680Pro hexacopter 

UAVs are equipped with a barometric pressure sensor and GPS equipment, which 

automatically ensures that a ground level pressure setting will be established prior to each 

flight, and provides the PIC with altitude information of the UAVs on the heads-up display 

of the GCS. 

4. Extent Of Relief Deland Drones Seeks And The Reason Deland Drones 

Seeks Relief From Section 91.151(b). 

 Relief from Section 91.151(b) entitled Fuel requirements for flight in VFR conditions, is 

requested to the extent required to allow flights of the battery powered The Turnigy Talon 

500 quadcopter and the Tarrot 680Pro hexacopter UAVs during daylight hours in visual 

meteorological conditions (VMC), under visual flight rules (VFR), for a total duration of 

25 minutes to the first point of intended landing and, assuming normal cruising speed, to 

fly after that for at least 5 minutes.Deland Drones seeks the requested relief because 

without an exemption from Section 91.151(b), the flight time duration of the battery 

powered The Turnigy Talon 500 quadcopter and the Tarrot 680Pro hexacopter UAVs will 

severely constrain the practicality of any aerial video or still photo flight operations that 

Deland Drones proposes to conduct pursuant to this Petition. 

 Significantly, as set forth below, the technical specifications of The Turnigy Talon 500 

quadcopter and the Tarrot 680Pro hexacopter UAVs The Turnigy Talon 500 quadcopter 

and the Tarrot 680Pro hexacopter UAVs operating documents, and Deland Drones' 

proposed operating limitations, ensure that Deland Drones will safely operate the battery 

powered Turnigy Talon 500 quadcopter and the Tarrot 680Pro hexacopter UAVs during 

daylight hours in visual meteorological conditions (VMC), under 
11

visual flight rules (VFR), with enough battery power to fly for a total duration of 25 

minutes to the first point of intended landing and, assuming normal cruising speed, to fly 

after that for at least 5 minutes.

5. Extent Of Relief Deland Drones Seeks And The Reason Deland Drones 

Seeks Relief From Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), And 

91.417(a) & (b). 

 Since Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b) only 

apply to aircraft with an airworthiness certificate, Deland Drones requests relief 

from these Sections because The Turnigy Talon 500 quadcopter and the Tarrot 680Pro 

hexacopter UAVs do not require airworthiness certificates. As set forth more fully below, 

The Turnigy Talon 500 quadcopter and the Tarrot 680Pro hexacopter UAVs meet the 

conditions of FMRA Section 333 for operation without an airworthiness certificate. 

Accordingly, Deland Drones will use trained technicians to perform maintenance, 

alterations, or preventive maintenance on the UASs using the methods, techniques, and 

practices prescribed in the UASs operating documents(i.e., the Deland Drones Aerial 

Operations Manual, Monthly Maintenance Log, and Instruction Manuals). Furthermore,

Deland Drones will document and maintain all maintenance records for The Turnigy Talon 

500 quadcopter and the Tarrot 680Pro hexacopter UAVs. 

D. The Reasons Why Granting Deland Drones Request Would Be In The 

Public Interest; That Is, How It Would Benefit The Public As A Whole. 

 Granting the present Petition will further the public interest by allowing Deland Drones 

to safely, efficiently, and economically perform aerial video and photography of 

construction sites, real estate, events and landscape over certain areas of the United States. 

 Additionally, use of The Turnigy Talon 500 quadcopter and the Tarrot 680Pro 

hexacopter UAVs will decrease congestion of the NAS, reduce pollution, and provide 

significant benefits to the economy. Notably, the benefits of Deland Drones' proposed 

operation of The Turnigy Talon 500 quadcopter and the Tarrot 680Pro hexacopter UAVs 

will be realized without implicating any privacy issues. 

1. The Public Will Benefit From Decreased Congestion Of The NAS. 

 The Turnigy Talon 500 quadcopter and the Tarrot 680Pro hexacopter UAVs are battery 

powered and serve as a safe, efficient, and economical alternative to the manned aircraft 

traditionally utilized to obtain aerial imagery. By reducing the amount of manned aircraft 

needed to perform aerial acquisitions, an exemption allowing the use of a The Turnigy 

Talon 500 quadcopter and the Tarrot 680Pro hexacopter UAVs would reduce the amount of 

manned aircraft in the NAS, reduce noise and air pollution, as well as increase the safety of 

life and property in the air and on the ground. 

 Furthermore, by reducing the number of manned aircraft operating in the NAS, congestion 

around airports caused by arriving and departing aircraft will be reduced. The Turnigy 

Talon 500 quadcopter and the Tarrot 680Pro hexacopter UAVs do not require an airport to 

takeoff or land. Likewise, a reduction of manned aircraft conducting aerial video and 

photography missions would result in fewer aircraft that must be handled by air traffic 
12

control during the ground, takeoff, departure, arrival, and landing phases of flight 

operations.

2. The Public Will Benefit From The Safety And Efficiency Of The Turnigy 

Talon 500 quadcopter and the Tarrot 680Pro hexacopter UAVs. 

 Conducting aerial acquisitions with The Turnigy Talon 500 quadcopter and the Tarrot 

680Pro hexacopter UAVs, instead of manned aircraft, will greatly benefit the public by 

drastically reducing the levels of air and noise pollution generated during traditional aerial 

video and still photography flight operations. By using battery power and electric motors, 

The Turnigy Talon 500 quadcopter and the Tarrot 680Pro hexacopter UAVs produce no air 

pollution, and is the most viable environmentally conscious alternative to the cabin class, 

six cylinder internal combustion engine aircraft that are typically utilized for aerial video 

and photography, while burning approximately 20-30 gallons per hour of leaded aviation 

fuel. The Turnigy Talon 500 quadcopter and the Tarrot 680Pro hexacopter UAVs, while 

reducing the carbon footprint of aerial acquisitions, also eliminates noise pollution, as the 

UAVs are propelled by battery powered electric motors, rather than an internal combustion 

engine. 

 By using The Turnigy Talon 500 quadcopter and the Tarrot 680Pro hexacopter UAVs to 

perform aerial acquisitions, the substantial risk to life and property in the air and on the 

ground, which is usually associated with traditional manned aircraft flight operations, will 

be substantially reduced or completely eliminated. Aside from the lack of flight crew 

members located onboard the aircraft, The Turnigy Talon 500 quadcopter and the Tarrot 

680Pro hexacopter UAVs (weighing approximately 6 pounds and 8 pounds respectively, at 

their maximum gross weights with lengths of 14 inches and 26 inches respectively, widths 

of 14 inches and 26 inches respectively, and with no fuel on board), has less physical 

potential for collateral damage to life and property on the ground, and in the air, compared 

to the manned aircraft that typically conduct similar operations (weighing approximately 

6,000 pounds with a wingspan of approximately 42 feet, a length of 34 feet, and a fuel 

capacity of 180 gallons). 

3. Performing Aerial Video and Photography Operations With The Turnigy 

Talon 500 quadcopter and the Tarrot 680Pro hexacopter UAVs Will Benefit 

The Economy. 

 In addition to being safe and efficient, The Turnigy Talon 500 quadcopter and the Tarrot 

680Pro hexacopter UAVs are also an economical alternative to using manned aircraft to 

conduct similar aerial operations. As such, operation of The Turnigy Talon 500 quadcopter 

and the Tarrot 680Pro hexacopter UAVs will allow United States based companies, like 

Deland Drones, to remain competitive and contribute to growth of the U.S. economy. 

Specifically, with the rising cost of aviation fuel and the Environmental Protection Agency 

(“EPA”) regulatory actions phasing out leaded aviation fuels, U.S. owned and operated 

companies must adopt new and alternative technology in order to remain competitive. 

Operating the battery powered The Turnigy Talon 500 quadcopter and the Tarrot 680Pro 

hexacopter UAVs is one such technology that not only allows companies greater 

operational flexibility compared to manned aircraft, but provides such flexibility without 

the high operational cost of a traditional manned aircraft. 
13

 By operating The Turnigy Talon 500 quadcopter and the Tarrot 680Pro hexacopter 

UAVs, companies such as Deland Drones, can remain competitive and profitable, and 

therefore, provide greater job stability to employees and contractors, which will ultimately 

contribute to growth of the U.S. economy. Improved financial performance of U.S. 

companies, through commercial use of The Turnigy Talon 500 quadcopter and the Tarrot 

680Pro hexacopter UAVs, provides a stable workforce that increases consumer spending; 

improves local, state, and federal tax revenues; and allows companies to invest in research 

and development in order to remain competitive both in the United States and abroad. 

4. There Are No Privacy Issues. 

 Similar to the manned aerial acquisition flight operations that have been conducted for 

decades, Deland Drones' proposed operation of The Turnigy Talon 500 quadcopter and the 

Tarrot 680Pro hexacopter UAVs will not implicate any privacy issues. Specifically, The 

Turnigy Talon 500 quadcopter and the Tarrot 680Pro hexacopter UAVs will be operated 

only in compliance with operating documents (i.e., the Deland Drones Aerial Operations 

Manual, Monthly Maintenance Log, and Instruction Manuals) which requires property 

owner involvement as well as local law enforcement notification, and in accordance with 

the Federal Aviation Regulations, including the minimum altitude requirements of 14 

C.F.R. § 91.119. 

E. The Reasons Why Granting The Exemption Would Not Adversely Affect Safety, 

Or How The Exemption Would Provide A Level Of Safety At Least Equal To That 

Provided By The Rule From Which Deland Drones Seeks Exemption. 

1. Reasons Why The Turnigy Talon 500 quadcopter and the Tarrot 680Pro 

hexacopter UAVs Meet The Conditions Of The FAA Modernization and 

Reform Act of 2012 (FMRA) Section 333. 

 In consideration of the size, weight, speed, and limited operating area associated with the 

unmanned aircraft and its operation, Deland Drones' operation of The Turnigy Talon 500 

quadcopter and the Tarrot 680Pro hexacopter UAVs meet the conditions of FMRA Section 

333, and will not require an airworthiness certificate in accordance with 14 C.F.R. Part 21, 

Subpart H. 

 Section 333 provides authority for a UAVs to operate without airworthiness certification 

and sets forth requirements for considering whether a UAVs will create a hazard to users of 

the NAS or the public, or otherwise pose a threat to national security. Specifically, FMRA 

Section 333 states the following, in part: 

(a) In General.--Notwithstanding any other requirement of this subtitle, and not 

later than 180 days after the date of enactment of this Act, the Secretary of 

Transportation shall determine if certain unmanned aircraft systems may 

operate safely in the national airspace system before completion of the plan 

and rulemaking required by section 332 of this Act or the guidance required by 

section 334 of this Act. 
14

(b) Assessment of Unmanned Aircraft Systems.--In making the determination under 

subsection (a), the Secretary shall determine, at a minimum--

(1) which types of unmanned aircraft systems, if any, as a result of their 

size, weight, speed, operational capability, proximity to airports and 

populated areas, and operation within visual line of sight do not create 

a hazard to users of the national airspace system or the public or pose a 

threat to national security; and

(2) whether a certificate of waiver, certificate of authorization, or 

airworthiness certification under section 44704 of title 49, United States 

Code, is required for the operation of unmanned aircraft systems 

identified under paragraph (1). 

(c) Requirements for Safe Operation.--If the Secretary determines under this 

section that certain unmanned aircraft systems may operate safely in the 

national airspace system, the Secretary shall establish requirements for the safe 

operation of such aircraft systems in the national airspace system. 

 In seeking this exemption, Deland Drones submits that The Turnigy Talon 500 

quadcopter and the Tarrot 680Pro hexacopter UAVs can operate safely in the NAS pursuant 

to FMRA Section 333, as demonstrated by: (a) the characteristics of The Turnigy Talon 500 

quadcopter and the Tarrot 680Pro hexacopter UAVs; (b) the pilot certification requirement; 

and (c) the specific operating limitations. 

a. The Specifications Of The Turnigy Talon 500 quadcopter and the Tarrot 

680Pro hexacopter UAVs Demonstrate Its Safe Characteristics.

 The Turnigy Talon 500 quadcopter and the Tarrot 680Pro hexacopter UAVs do not 

create a hazard to users of the NAS or the public, or otherwise pose a threat to national 

security considering its size, weight, speed, and operational capability. 

i. Technical Specifications Of . 

 The technical specifications of the Turnigy Talon 500 quadcopter and the Tarrot 680Pro 

hexacopter UAVs are set forth by the Specifications and Data Sheet, attached hereto as 

Exhibit A and B. 

ii. The The Turnigy Talon 500 quadcopter and the Tarrot 680Pro 

hexacopter UAVs Autonomous Flight And Navigation Modes Enable 

The UAVs To Remain Within A Defined Operational Area. 

 The Turnigy Talon 500 quadcopter and the Tarrot 680Pro hexacopter UAVs may be 

operated in both manual and fully autonomous flight modes. A complete description of the 

flight and navigational modes of the The Turnigy Talon 500 quadcopter and the Tarrot 

680Pro hexacopter UAVs is provided at pages of the 3DRobotics APM2.6 User Manual, 

attached hereto as Exhibit C.
15

iii. The Turnigy Talon 500 quadcopter and the Tarrot 680Pro 

hexacopter UAVs Are Designed For Automatic Return To Home Point 

Or Hover In The Event Of Loss Of The Control Link Or Navigation. 

 When the Control Link is lost, the Turnigy Talon 500 quadcopter and the Tarrot 680Pro 

hexacopter UAVs will remain stationary, in flight, for 3 seconds or more. If, after 3 

seconds, the Turnigy Talon 500 quadcopter and the Tarrot 680Pro hexacopter UAVs do not 

reacquire control link data from the GCS, the UAVs will assume that the Control Link is 

lost and the UAVs will return to the home position (i.e., failsafe mode) via GPS, and will 

descend to the takeoff position and shutdown. 

 A complete description of the Failsafe Functions of the Turnigy Talon 500 quadcopter 

and the Tarrot 680Pro hexacopter UAVs are set forth on pages of the 3DRobotics APM2.6 

User Manual, attached hereto as Exhibit C.

iv. TheTurnigy Talon 500 quadcopter and the Tarrot 680Pro 

hexacopter UAVs GCS And Its Operation.

 A complete description of the operation and specifications of the Turnigy Talon 500 

quadcopter and the Tarrot 680Pro hexacopter UAVs GCS and flight control software is 

provided at pages of the User Manual. User Manuals are attached hereto as Exhibits C.

b. Flight Operations Of Turnigy Talon 500 quadcopter and the Tarrot 

680Pro hexacopter UAVs1 UASs Are Limited To The Line Of Sight Of A 

Certificated Pilot in Command With A Safety Observer. 

Deland Drones will only utilize certificated pilots who possess a current and 

valid airman medical certificate to act as a pilot in command (PIC) of the Turnigy Talon 

500 quadcopter and the Tarrot 680Pro hexacopter UAVs. Additionally, a safety observer 

will assist all pilots during flight time. 

c. Flights Of Turnigy Talon 500 quadcopter and the Tarrot 680Pro 

hexacopter UAVs Will Be Conducted Pursuant To Specific Operating 

Limitations. 

 In seeking this exemption, Deland Drones proposes to commercially operate Turnigy 

Talon 500 quadcopter and the Tarrot 680Pro hexacopter UAVs for the special purpose of 

conducting aerial video and photography over certain areas of United States, pursuant to the 

following specific operating limitations:

 1. Operations authorized by this grant of exemption will be limited to the following 

aircraft described in the operating documents, rotorcraft UASs weighing less than 55 

pounds maximum gross weight: Turnigy Talon 500 quadcopter and the Tarrot 680Pro 

hexacopter UAVs Unmanned Aircraft Systems. Proposed operations of any other aircraft 

will require a new petition or a petition to amend this grant. 
16

 2. UAS operations under this exemption will be limited to conducting operations 

for the purpose of aerial video and photography. 

 3. The UAVs may not be flown at an indicated airspeed exceeding 100 knots.

 4. The UAVs must be operated at an altitude of no more than 500 feet above 

ground level (AGL), as indicated by the procedures specified in the operating 

documents unless a special request is made and approved by ATC. All altitudes 

reported to ATC must be in feet AGL. 

 5. The UAVs 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. 

 6. The use of first person view (FPV) by the PIC or safety observer (SO) is not 

permitted. 

 7. All operations must utilize a safety observer (SO). The SO may be used to 

satisfy the VLOS requirement as long as the PIC always maintains VLOS 

capability. The SO 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 SO can perform the 

functions prescribed in the operating documents. 

 8. The SO must not perform any other duties beyond assisting the PIC with 

seeing and avoiding other air traffic and other ground based obstacles/obstructions 

and is not permitted to operate the camera or other instruments. 

 9. The operating documents and the grant of exemption must be accessible 

during UAVs operations and made available to the Administrator upon request. If a 

discrepancy exists between the conditions and limitations contained in the grant of 

exemption and the procedures outlined in the operating documents, the conditions 

and limitations contained in the grant of exemption 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 upon request. The operator must also 

present updated and revised documents if it petitions for extension or amendment to 

the grant of exemption. If the operator determines that any update or revision would 

affect the basis upon which the FAA granted the exemption, then the operator must 

petition for amendment to its grant of exemption. The FAA’s UAVs Integration 

Office (AFS-80) may be contacted if questions arise regarding updates or revisions 

to the operating documents. 

 10. Prior to each flight the PIC must inspect the UAVs to ensure that it is in a 

condition for safe flight. If the inspection reveals a condition that affects the 
17

safe operation of the UAS, the aircraft is prohibited from operating until the

necessary maintenance has been performed and the UASs is found to be in a 

condition for safe flight. The Ground Control Station must be included in the 

preflight inspection. All maintenance and alterations must be 

properlydocumented in the aircraft records.

 11. Any UAVs that has undergone maintenance or alterations that affect the 

UAVs operation or flight characteristics, e.g. replacement of a flight critical 

component, must undergo a functional test flight. The PIC who conducts the 

functional test flight must make an entry in the aircraft records. 

 12. The pre-flight inspection must account for all potential discrepancies, e.g. 

inoperable components, items, or equipment, not already covered in the relevant 

sections of the operating documents. 

 13. The operator must follow the UASs manufacturer’s aircraft/component, 

maintenance, overhaul, replacement, inspection, and life limit requirements. 

 14. The operator must carry out its maintenance, inspections, and record keeping 

requirements, in accordance with the operating documents. Maintenance, 

inspection, alterations, and status of replacement/overhaul component parts must be 

noted in the aircraft records, including total time in service, description of work 

accomplished, and the signature of the authorized person returning the UAVs to 

service. 

 15. Each UAVs operated under this exemption must comply with all 

manufacturer Safety Bulletins. 

 16. The authorized person must make an entry in the aircraft record of the 

corrective action taken against discrepancies discovered between inspections. 

 17. The PIC must possess at least a student pilot, private pilot certificate, or 

greater and at least a current third class medical certificate. 

 18. The operator may not permit any PIC to operate unless the PIC meets the 

operator’s qualification criteria and demonstrates the ability to safely operate the 

UAVs in a manner consistent with how the UAVs will be operated under the 

exemption, including evasive and emergency maneuvers and maintaining 

appropriate distances from persons, vessels, vehicles and structures. PIC 

qualification flight hours must be logged in a manner consistent with 14 C.F.R. § 

61.51(b). Flights for the purposes of training the operator’s PICs are permitted 

under the terms of the 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 UAVs with appropriate 

distance from nonparticipants in accordance with 14 C.F.R. § 91.119. 
18

 19. UAVs operations may not be conducted during night, as defined in 14 C.F.R. 

§ 1.1. All operations must be conducted under visual meteorological conditions

(VMC). If flight at night is required, a special request will be made at the FAA 

office closest to proposed area of operations. Flights under special visual flight rules 

(SVFR) are not authorized. 

 20. The UAVs may not operate within 5 nautical miles of a airport reference point 

as denoted on a current FAA-published aeronautical chart unless a letter of 

agreement with that airport’s management is obtained, and the operation is conducted 

in accordance with a NOTAM as required by the operator’s COA.The letter of 

agreement with the airport management must be made available to the Administrator 

upon request. 

 21. The UAVs 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. 

 22. If the UAVs loses communications or loses its GPS signal, it must return to a 

Pre-determined location within the planned operating area and land or be recovered 

in accordance with the operating documents. 

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

emergencies in accordance with the operating documents. 

 24. The PIC is prohibited from beginning a flight unless (considering wind and 

forecast weather conditions) there is enough power to fly at normal cruising speed to 

the intended landing point and land the UAVs with 25% battery power remaining. 

 25. The operator must obtain an Air Traffic Organization (ATO) issued Certificate 

of Waiver or Authorization (COA) prior to conducting any operations under the grant 

of exemption. This COA will also require the operator to request a Notice to Airman 

(NOTAM) not more than 72 hours in advance, but not less than 48 hours prior to the 

operation. All operations shall be conducted in accordance with airspace 

requirements in the ATO issued COA including class of airspace, altitude level and 

potential transponder requirements. 

 26. All aircraft operated in accordance with the exemption must be identified by 

serial number, registered in accordance with 14 C.F.R. part 47, and have 

identification (N- Number) markings in accordance with 14 C.F.R. part 45, Subpart 

C. Markings must be as large as practicable. 

 27. Before conducting operations, the radio frequency spectrum used for operation 

and control of the UAVs must comply with the Federal Communications 

Commission (FCC) or other appropriate government oversight agency requirements. 
19

 28. The documents required fewer than 14 C.F.R. 91.9 and 91.203 must be 

available to the PIC at the Ground Control Station of the UAV any time the UAV is 

operating. These documents must be made available to the Administrator or any law 

enforcement official upon request. 

 29. The UAVs must remain clear and yield the right of way to all manned 

aviation operations and activities at all times. 

 30. The UAVs may not be operated by the PIC from any moving device or 

vehicle.

 31. Flight operations must be conducted at least 500 feet from all nonparticipating 

persons (persons other than the PIC, SO, operator trainees or essential persons), 

vessels, vehicles, and structures unless: 

a. Barriers or structures are present that sufficiently protect nonparticipating 

persons from the UA 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 UAVs, flight operations must 

cease immediately and/or; 

b. The aircraft is operated near vessels, vehicles or structures where the 

owner/controller of such vessels, vehicles or structures has granted 

permission 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, and; 

c. Operations nearer to the PIC, SO, operator trainees or essential persons 

do not present an undue hazard to those persons per § 91.119(a). 

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

with permission from the land owner/controller or authorized representative. 

Permission from land owner/controller or authorized representative will be obtained 

for each flight to be conducted.

 33. 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. 

2. Reasons Why An Exemption From The Requirements Of Section 61.113(a) 

And (b) Would Not Adversely Affect Safety.

 Deland Drones submits that the equivalent level of safety established by Section 

61.113(a) and (b) will be maintained because no PIC will be allowed to operate the Turnigy 

Talon 500 quadcopter and the Tarrot 680Pro hexacopter UAVs unless that PIC has 

demonstrated, by meeting minimum flight-hour and currency requirements, that the PIC is 

able to safely operate the Turnigy Talon 500 quadcopter and the Tarrot 680Pro hexacopter 
20

UAVs in a manner consistent with the exemption, including evasive and emergency 

maneuvers and maintaining appropriate distances from people, vessels, vehicles and 

structures. 

 Considering Deland Drones' proposed area of operations, and the operating limitations 

set forth-above; the parallel nature of private pilot aeronautical knowledge requirements to 

those of commercial pilot requirements (See Exemption No. 11062); and the airmanship 

skills necessary to safely operate the Turnigy Talon 500 quadcopter and the Tarrot 680Pro 

hexacopter UAVs, Deland Drones submits that the additional manned airmanship 

experience of a commercially certificated pilot would not correlate to the airmanship skills 

necessary for Deland Drones' specific proposed flight operations. 

 The FAA has previously granted relief from Section 61.113(a) and (b) specific to 

UAVs, in circumstances similar, in all material respects, to those presented herein (e.g. 

Exemption Nos. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 11112, 

11136, 11138, 11150, 11153, 11156, 11158, 11159, 11160, 11161). 

 Deland Drones will not allow any PIC to operate the Turnigy Talon 500 quadcopter or 

the Tarrot 680Pro hexacopter UAVs unless that PIC has demonstrated, by meeting 

minimum flight-hour requirements or the Turnigy Talon 500 quadcopter and the Tarrot 

680Pro hexacopter UAVs training and currency requirements, that the PIC is able to safely 

operate the Turnigy Talon 500 quadcopter and the Tarrot 680Pro hexacopter UAVs in a 

manner consistent with this exemption, including evasive and emergency maneuvers and 

maintaining appropriate distances from people, vessels, vehicles and structures. 

 Specifically, the PIC must have accumulated and logged, in a manner consistent with 14 

C.F.R. § 61.51(b), 25 hours of total time as a UAVs rotorcraft pilot (with a minimum of 5 

hours of those hours as a UAVs pilot operating the same make and model of UAS to be 

used for operations under the exemption). In addition to the hour requirements, the PIC 

must accomplish 3 takeoffs and landings in the preceding 90 days (for currency purposes). 

 As in Exemption Nos. 11062, 11138, and 11153, prior documented flight experience 

that was obtained in compliance with applicable regulations will ensure an equivalent level 

of safety during Deland Drones' proposed operations. The Administrator has held that 

prior documented flight experience that was obtained in compliance with applicable 

regulations would ensure safe operations, stating as follows: 

In Exemption No. 11062, the FAA required that prior to conducting operations for 

the purpose of motion picture filming (or similar operations), the PIC must have 

accumulated and logged, in a manner consistent with 14 CFR 61.51(b), 25 hours of 

total time as a UAVs rotorcraft pilot including at least 10 hours logged as a UAVs 

pilot with a multi-rotor UAVs. Prior to operations under Exemption No. 11062, the 

PIC must also have accumulated and logged a minimum of 5 hours as a UAVs pilot 

operating the same make and model of UAVs to be used for operations under the 

exemption. For clarification, the FAA considers these minimum hour requirements 

to be inclusive rather than additive; i.e. 5 hours make and model time may be 
21

included in the 10 hours of multi-rotor time and the 10 hours may be included in the 

total 25 hours of UAVs rotorcraft time. In addition to the hour requirements, the 

PIC must accomplish 3 takeoffs and landings in the preceding 90 days (for 

currency purposes). The FAA finds that at a minimum, the flight-hour requirements 

in Exemption No. 11062 are appropriate to practice and build proficiency in the 

skills necessary to safely conduct the petitioner’s proposed operations. The FAA 

also finds that prior documented flight experience that was obtained in compliance 

with applicable regulations would satisfy this requirement. Training, proficiency, 

and experience-building flights can also be conducted under the grant of exemption 

to accomplish the required flight time. During training, proficiency, and 

experience-building flights the PIC is required to operate the UAVs with 

appropriate distances in accordance with 14 C.F.R 91.119. 

 Exemption No. 11138 at page 15. 

 Accordingly, Deland Drones will ensure safe operations by not allowing any PIC to 

operate the DJI Phantom 2 Vision+ or DJI Inspire 1 UAS unless that PIC has 

demonstrated, by meeting minimum flight-hour and currency requirements, that the PIC is 

able to safely operate the DJI Phantom 2 Vision+ or DJI Inspire 1 UAS in a manner 

consistent with the exemption, including evasive and emergency maneuvers and 

maintaining appropriate distances from people, vessels, vehicles and structures. 

3. Reasons Why An Exemption From The Requirements Of Section 91.7(a) 

Would Not Adversely Affect Safety. 

 The equivalent level of safety established by Section 91.7(a) will be maintained because 

prior to every flight, Deland Drones will ensure that the Turnigy Talon 500 quadcopter and 

the Tarrot 680Pro hexacopter UAVs is in an airworthy condition based upon the UAV’s 

compliance with its operating documents and as stated in the conditions and limitations 

herein. 

 Additionally, the FAA has previously granted relief from Section 91.7(a) specific to 

UAVs, in circumstances similar, in all material respects, to those presented herein (e.g. 

Exemption Nos. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 11112, 

11136, 11138, 11150, 11153, 11156, 11157, 11158, 11159, 11160, 11161). 

4. Reasons Why An Exemption From The Requirements Of Section 91.121 

Would Not Adversely Affect Safety.

The equivalent level of safety established by Section 91.121 will be maintained because 

the altitude information of the Turnigy Talon 500 quadcopter and the Tarrot 680Pro 

hexacopter UAVs will be provided to the PIC via GPS equipment and a radio 

communications telemetry data link, which downlinks from the UAVs to the GCS for 

active monitoring of the flight path and altitude. This altitude information, combined with 

Deland Drones' operation of the Turnigy Talon 500 quadcopter and the Tarrot 680Pro 

hexacopter UAVs within visual line of sight, at or below 500 feet AGL, will ensure a level 

of safety equivalent to Section 91.121. The altitude information will be generated by GPS 

equipment installed onboard the aircraft. Prior to each flight, a zero altitude initiation point 
22

is automatically established by the UAVs at ground level. 

 The FAA has previously granted relief from Section 91.121 specific to UAV in 

circumstances similar, in all material respects, to those presented herein (e.g. Exemption 

Nos. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11112, 11136, 11138, 

11150, 11153, 11156, 11157, 11158, 11159, 11160, 11161). 

5. Reasons Why An Exemption From The Requirements Of Section 91.151(b) 

Would Not Adversely Affect Safety.

 A grant of this exemption would ensure an equivalent level of safety established by 14 

C.F.R. Section 91.151(b) as a result of (1) the technical specifications of the ach flight, a 

zero altitude initiation point is; (2) the limitations on the proposed flight operations; 

and (3) the location of the proposed flight operations. Accordingly, Deland Drones will 

ensure that it will safely operate the battery powered the during daylight hours in VFR 

conditions, with enough battery power to fly for a total duration of 25 minutes to the first 

point of intended landing and, assuming normal cruising speed, to fly after that for at least 5 

minutes. 

 Here, as in Exemption No. 11109, the technical specifications of the Purnigy Talon 500 

quadcopter and the Tarrot 680Pro hexscopter; the limitations on the proposed flight 

operations; and the location of the proposed operations, will ensure an equivalent level of 

safety established by 14 C.F.R. Section 91.151(b). Furthermore, safety will be ensured as 

the DJI Phantom 2 Vision+ and DJI Inspire 1 UASs provide audible and visual warnings to 

the PIC at the GCS when the UASs experiences low battery voltage, the first warning 

occurring at approximately 25% remaining battery power, and at approximately 10% 

remaining battery power UASs will descend and land automatically. 

Significantly, previous exemptions granted by the FAA concerning Section 91.151 

establish that safety is not adversely affected when the technical characteristics and 

operating limitations of the UAS are considered. Relief has been granted for manned 

aircraft to operate at less than the minimums prescribed in Section 91.151, including 

Exemption Nos. 2689, 5745, and 10650. Moreover, the FAA has previously granted relief 

from Section 91.151 specific to UAS, in circumstances similar, in all material respects, to 

those presented herein (e.g. Exemption Nos. 8811, 10808, 10673, 11042, 11062, 11063, 

11064, 11065, 11066, 11067, 11080, 11109, 11110, 11136, 11138, 11150, 11153, 11156, 

11157, 11158, 11159, 11160, 11161). 

6. Reasons Why An Exemption From The Requirements Of Sections

91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), And 91.417(a) & (b) Would 

Not Adversely Affect Safety. 

In seeking this exemption, Deland Drones submits that the equivalent level of safety 

with regard to the regulatory maintenance and alteration requirements established by 

Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b) will be met 
23

because Deland Drones will use trained technicians to perform maintenance, alterations, or 

preventive maintenance on the UASs using the methods, techniques, and 

practices prescribed in the operating documents (i.e., the Deland Drones Aerial Operations 

Manual, Monthly Maintenance Log, 

Inspire 1 Instruction Manual). Furthermore, Deland Drones will document and maintain all 

maintenance records for the DJI Phantom 2 Vision+ and DJI Inspire 1 UASs. 

Since the DJI Phantom 2 Vision+ and DJI Inspire 1 UASs will be inspected as prescribed 

by the operating documents, Deland Drones will maintain the equivalent level of safety 

established by Sections 91.405(a), 91.409(a)(1), and 91.409(a)(2). A copy of the DJI 

Phantom 2 Vision+ and DJI Inspire 1 User Manuals are attached hereto as Exhibit C and 

D; a copy of the DJI Phantom 2 Vision+ and DJI Inspire 1 UAS Maintenance LOG is 

attached hereto as Exhibit E. 

Likewise, the exemption sought will not adversely affect safety because Deland Drones

will use trained technicians to perform maintenance, alterations or preventive 

maintenance on the UAS using the methods, techniques, and practices prescribed by the

operating documents. 

Furthermore, the exemption sought would maintain an equivalent level of safety 

established by Sections 91.407, 91.417(a) and 91.417(b), because all maintenance of the 

DJI Phantom 2 Vision+ and DJI Inspire 1 UASs will be performed by trained technicians. 

Maintenance will be documented and maintained utilizing the monthly maintenance log. 

Significantly, previous exemptions granted by the FAA concerning Sections 91.405(a), 

91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b) establish that safety is not 

adversely affected when the technical characteristics and operating limitations of the UAS 

are considered. 

In consideration of Deland Drones' proposed operating limitations, the operating 

documents, and the technical aspects of the DJI Phantom 2 Vision+ and DJI Inspire 1 

UASs, Deland Drones submits that safety will not be adversely affected by granting 

exemption from 14 C.F.R. Sections 91.405(a), 91.407(a)(1) and (a)(2), 91.409(a)(2), and 

91.417(a) and (b). The FAA has previously granted relief 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, 11110, 11112, 11136, 11138, 11150, 

11153, 11156, 11157, 11158, 11159, 11160, 11161). 

7. The FAA May Prescribe Any Other Conditions For Safe Operation. 

In accordance with Section 333 of the FAA Modernization and Reform Act of 2012 

(FMRA) and 14 C.F.R. § 21.16 entitled Special Conditions, Deland Drones requests 

that the FAA prescribe special conditions for the intended operation of the DJI Phantom 2 

Vision+ and DJI Inspire 1 UASs, which contain such safety standards that the 

Administrator finds necessary to establish a level of safety equivalent to that established by 

14 C.F.R. Part 21, Subpart H, and 14 C.F.R §§ 61.113(a) & (b), 91.7 (a), 91.121, 
24

91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b). Such 

special conditions will permit safe operation of the UAs for the limited purpose of 

conducting aerial video and photography over certain areas of the United States for 

compensation or hire. FMRA Section 333 sets forth the requirements for considering 

whether a UAS will create a hazard to users of the NAS or the public, or otherwise pose a 

threat to national security; and further, provides the authority for such UAS to operate 

without airworthiness certification in accordance with any requirements that must be 

established for the safe operation of the UAS in the NAS. 

Likewise, the Administrator may prescribe special conditions pursuant to 14 C.F.R.

§ 21.16, for operation of the DJI Phantom 2 Vision+ and DJI Inspire 1 UASs, since the 

airworthiness regulations of 14 C.F.R. Part 21 do not contain adequate or appropriate 

safety standards, due to the novel or unusual design features of the aircraft. Section 21.16, 

entitled Special Conditions, states the following: 

If the FAA finds that the airworthiness regulations of this subchapter do not contain 

adequate or appropriate safety standards for an aircraft, aircraft engine, or propeller 

because of a novel or unusual design feature of the aircraft, aircraft engine or 

propeller, he prescribes special conditions and amendments thereto for the product. 

The special conditions are issued in accordance with Part 11 of this chapter and 

contain such safety standards for the aircraft, aircraft engine or propeller as the 

FAA finds necessary to establish a level of safety equivalent to that established in 

the regulations. 

See 14 C.F.R. § 21.16.

Therefore, in accordance with FMRA Section 333 and 14 C.F.R. § 21.16, the FAA may 

prescribe special conditions for Leading Edge’s intended operation of the DJI Phantom 2 

Vision+ and DJI Inspire 1 UASs, which contain such safety standards that the 

Administrator finds necessary to establish a level of safety equivalent to that established by 

14 C.F.R. Part 21, Subpart H, and 14 C.F.R Sections 61.113(a) & (b), 91.7(a), 91.121, 

91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b).

F. A Summary That Can Be Published In The Federal Register, stating: The Rules 

From Which Deland Drones Seeks Exemption: 

Deland Drones seeks exemption from the requirements of 14 C.F.R Sections 

61.113(a)&(b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & 

(a)(2), and 91.417(a) & (b). 

A Brief Description Of The Nature Of The Exemption Deland Drones Seeks: 

This exemption will permit Deland Drones to commercially operate an Unmanned 

Aircraft System, small (UASs) for the purpose of conducting aerial video and 

photography over certain areas of the United States.
25

G. Any Additional Information, Views, Or Arguments Available To Support Deland 

Drones' Request. 

This Petition is made pursuant to the FAA Modernization and Reform Act of 2012 

(FMRA) Section 333, which directs the Secretary of Transportation to determine if certain 

UAS may operate safely in the NAS. As such, Deland Drones' request for 

exemption may be granted pursuant to the authority of FMRA Section 333 and 14 C.F.R. 

Part 11, as set forth above. 

FMRA Section 333 sets forth the requirements for considering whether a UAS will create 

a hazard to users of the NAS or the public, or otherwise pose a threat to national security; 

and further, provides the authority for such UAS to operate without airworthiness 

certification. 

As discussed in detail above, Deland Drones will operate the DJI Phantom 2 

Vision+ and DJI Inspire 1 UASs safely in the NAS, without creating a hazard to users of 

the NAS, or the public, or otherwise pose a threat to national security. 

CONCLUSION

As set forth herein, Deland Drones seeks an exemption pursuant to 14 C.F.R. § 

11.61 and Section 333 of the FAA Modernization and Reform Act of 2012 (FMRA), 

which will permit safe operation of the DJI Phantom 2 Vision+ and DJI Inspire 1 UASs 

commercially, without an airworthiness certificate, for the limited purpose of conducting 

aerial video and photography over certain areas of the United States. By granting this 

Petition, the FAA Administrator will be fulfilling the Congressional mandate of the FAA 

Modernization and Reform Act of 2012, while also advancing the interests of the public, 

by allowing Deland Drones to safely, efficiently, and economically operate the DJI 

Phantom 2 Vision+ and DJI Inspire 1 UASs commercially within the NAS. 

WHEREFORE, in accordance with the Federal Aviation Regulations and the FAA 

Modernization and Reform Act of 2012, Section 333, Deland Drones respectfully 

requests that the Administrator grant this Petition for an exemption from the requirements 

of 14 C.F.R Sections 61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 

91.409(a)(1) & (a)(2), and 91.417(a) & (b), and permit Leading Edge to operate the DJI 

Phantom 2 Vision+ and DJI Inspire 1 UASs commercially for the purpose of conducting 

aerial video and photography over certain areas of the United States.
26

Dated: March 29, 2015

Respectfully submitted, 

Christopher Sammons, Owner Deland Drones

Deland Drones

Christopher Sammons

217 E. Parkdale Ave.

Deland, Fl. 32724

321-228-7714

chris@delanddrones.com________________________

Appendices:

A – Turnigy Talon 500 Specifications Data Sheet

B – Tarrot 680PRO Specifications Data Sheet

C – Link to 3DRobotics APM2.6 User Manual
27

APPENDIX – A

Turnigy Talon 500 TECHNICAL SPECIFICATIONS

Deland Drones only utilizes safe and reliable UASs. Turnigy is an industry leader in small 

UAS production. Our UASs are equipped with 3DR flight controllers,APM2.6, utilizing 

software enabling the user to set parameters which will not allow flight into controlled 

airspace. Parameters can also be set to limit flight to no higher than a predetermined and 

set altitude as well as limit flight to a predetermined and set distance. In addition, 3DR 

software provides real-time altitude and location information to the PIC via the linked 

monitor (laptop/tablet devices)

1.1 Turnigy Talon 500 

1.1.1 Aircraft

1.1.1.1 Supported Battery – Turnigy 5000ma/14.8vdc LiPo 4s Battery

1.1.1.2 Weight (Battery & Propellers Included) – 3lbs 10oz 

1.1.1.3 Hover Accuracy (Ready to Fly) – Vertical: .5m; Horizontal: 1.5m

1.1.1.4 Max Yaw Angular Velocity - 2000/s

1.1.1.5 Max Tilt Angel - 750

1.1.1.6 Max Ascent Speed – 10m/s

1.1.1.7 Max Descent Speed – 5m/s

1.1.1.8 Max Flight Speed – 20+m/s (NOT RECOMMENDED)

1.1.1.9 Dimensions–20.75”x20.75”x6”

1.1.2 Camera

1.1.3.1 Operating Temperature Range - 320F - 1040F (00C - 400C)

1.1.3.2 Sensor Size – 1/2.3”

1.1.3.3 Effective Pixels – 13M

1.1.3.4 Resolution – 4384x3288

4.1.3.5 HD Video Recording – 1080p & 720p

4.1.3.6 Recording Field of View - 1100/850

1.1.3 Transmitter

1.1.4.1 Operating Frequency – 2.4 GHz / 5.8 GHz

1.1.4.2 Communication Distance (unobstructed) – FCC Compliance: 1200m

1.1.4.3 Receiver Sensitivity (1%PER) - -93dBm

1.1.4.4 Transmitter Power – FCC Compliance: 100mW

1.1.4.5 Working Voltage – 120mA@3.7V
29

APPENDIX – B

TARROT 680PRO TECHNICAL SPECIFICATIONS

 Deland Drones only utilizes safe and reliable UAVs. Tarrot is an industry leader in 

small UAV'S production. Our UASs are equipped with 3DR flight controllers, APM2.6, 

utilizing software enabling the user to set parameters which will not allow flight into 

controlled airspace. Parameters can also be set to limit flight to no higher than a 

predetermined and set altitude as well as limit flight to a predetermined and set distance. 

In addition, 3DR software provides real-time altitude and location information to the 

PIC via the linked monitor (laptop/tablet devices)

2.2	TARROT 680PRO HEXACOPTER

2.2.1	Aircraft	

2.2.1.1	Model	–	TARROT 680PRO

2.2.1.2	Weight	(Battery	Included)	–	6lbs	9oz		

2.2.1.3	Hovering	Accuracy	(GPS	Mode)	–	Vertical:	0.5m;	Horizontal:	1.5m	

2.2.1.4	Max	Angular	Velocity	–	Pitch:	3000/s;	Yaw:	1500/s	

2.2.1.5	Max	Tilt	Angle	- 750	

2.2.1.6	Max	Ascent	Speed	–	10m/s	

2.2.1.7	Max	Descent	Speed	–	5m/s	

2.2.1.8	Max	Speed	–	25m/s	(	NOT	RECOMMENDED)

	2.2.1.9	Max	Flight	Altitude	–	4500m	

2.2.1.10	Max	Wind	Resistance	–	20m/s	

2.2.1.11	Max	Flight	Time	–	Approximately	30	minutes	

2.2.1.12	Motor	Model	–	GARRET 700KV (6)

2.2.1.13	Propeller	Model	–	Carbon fiber t-motor type 1437

2.2.1.14	Operating	Temperature	Range	–	140F	to	1040F	(-100C	to	400C)	

2.2.1.15	Dimensions	–	26.75”	x	26.75”	x	12”	

2.2.2	Gimbal	

2.2.2.1	Output	Power	(with	camera)	–	Static:	5W;	In	Motion:	10W	

2.2.2.2	Operating	Current	–	Static:	750mA;	In	Motion:	900mA	

2.2.2.3	Angular	Vibration	Range	-	±0.030	

2.2.2.4	Mounting	–	Detachable	

2.2.2.5	Controllable	Range	–	Pitch:	-900	to	+300;	Pan:	±3200	

2.2.2.6	Mechanical	Range	–	Pitch:	-1250	to	450;	Pan:	±3300	

2.2.2.7	Max	Controllable	Speed	–	Pitch:	1200/s;	Pan:	1800/s	
30

2.2.3	Camera	

2.2.3.1	Name	–	iLOOK	

2.2.3.2	Model	–	FC350	

2.2.3.3	Total	Pixels	–	13M	

2.2.3.4	Effective	Pixels	–	13M	

2.2.3.5	Image	Max	Size	–	4000x3000	

2.2.3.6	ISO	Range	–	100-3200	

2.2.3.7	Field	of	View	-	940	

2.2.3.8	CMOS	–	Sony	EXMOR	1/2.3”	

2.2.3.9	HD	Video	Recording	–	UHD(4K):	4096x2160p24/25,	

3840x2160p24/25/30;	FHD:	1920x1080p24/25/30/48/50/60;	HD:	

1280x720p24/25/30/48/50/60	

2.2.3.10	Operating	Temperature	Range	-	320F	-	1040F	(00C	-	400C)	

2.2.4	Transmitter	

2.2.4.1	Name	–	DEVO F12E

2.2.4.2	Operating	Frequency	–	5.728-5.850GHz;	2.400-2.483GHz	

2.2.4.3	Communicating	Distance	(unobstructed)	–	2000m	

2.2.4.4	Output	Power	–	9W	

2.2.4.5	Operating	Temperature	Range	-	140F	to	1040F	(-100C	to	400C)	

2.2.4.6	Battery	–	2000mAh	11.1vdc LiPo	3S	
31

APPENDIX – C

3DRobotics APM2.6 User Manual