U.S. Department of Transportation, Docket Operations 

West Building Ground Floor, Room W12-140 

1200 New Jersey Avenue, SE., Washington, DC 20590 

Exemption Request Pursuant to Section 333 of the FAA Reform Act of 2012 

To Whom It May Concern: 

We are writing pursuant to the FAA Modernization and Reform Act of 2012 and the 

procedures contained in 14 C.F.R. ESRUAS is a proponent ofthe recently released docket no.: 

F AA-20 15-0 150; Notice No. 15-01 and will abide by and assist in the development of all 

proposed rules but seeks relief from 14 C.F.R. until further protocols, standards and tests are 

established. ESRUAS, LLC is dedicated to the development of unmanned aircraft, specifically 

multi-rotor aircraft (aerial vehicles with a minimum of four ((4)) counter-rotating propellers) 

which are inherently stable with the ability to hover in place, and safety/flight procedures. M. 

Duncan Criscoe, of Crooked Pines Farm, LLC, CEO seeks relief from specific procedures 

contained in 14 C.F.R. 

Crooked Pines Farm, LLC has received requests of high definition aerial photography 

from numerous entities, that pertain, but are not limited to; Real Estate, Wildlife Conservation, 

and closed-set filming. M. Duncan Criscoe, owner and operator of small unmanned multirotor aircraft, seeks relief, sothe he may operate his smalVlightweight unmanned aircraft 

systems commercially in airspace close to airspace regulated by the FAA as required by 

Section 333. 

Crooked Pines Farm, LLC's exemption request would permit its operation of small, 

lightweight, unmanned (remotely controlled within line of sight) multi-rotor aerial systems in 

tightly controlled and limited airspace. Predetermined, specifically marked areas of operation, 

private property locations that correspond or surpass current safety protocols will allow Crooked 

Pines Farm, LLC to operate within current safety parameters and to aid in the development of 

new protocols being implemented. As identified, amateurs with no flight experience, safety plan 

or controls in place to prevent catastrophe legally operate similar lightweight, remote controlled 

multi-rotors. Crooked Pines Farm, LLC is developing plans to monitor, evaluate and implement 

all of its UAS's safely. 

The plans include but are not limited to: pre-flight visual inspection, pre-flight 

mechanical inspection, in-flight mechanical test, maintaining a visual of the aircraft and a flight 

log. 

0 Pre-flight visual inspection includes examination of; propellers, motors, 

electrical components and parts of the frame for chips, cracks, burns or 

any other damage. 

0 Pre-flight mechanical inspection is powering on the aircraft, transmitter(s) 

and receiver(s)- checking video feed and throttling up from 3rd person 

point-of-view without takeoff to ensure function of drive components 

(propellers, motors and speed controllers). 
0 In-flight mechanical test is done from 3rd person point-of-view (pilot 

watches the aircraft) at lo'Y altitude (eye level)- the pilot puts maximum 

input of pitch, roll, yaw and throttle sharply into transmitter to ensure all 

axis of aircraft are fully capable. 

0 Maintain visual of aircraft through 3rd person (pilot watches aircraft) 

operation or by using a spotter during 151 person (pilot sees point-of-view 

of aircraft) operation. 

D A flight log documents the pilot in control, spotter, weather, area of 

operation and purpose of flight. 

To date, Crooked Pines Farm, LLC has rejected all offers to work with interested 

parties on locations within the United States, to ensure it is in compliance with any applicable 

F ARs. It, like other applicants, has done so despite Judge Patrick G. Geraghty's decision in 

the Raphael Pirker matter and his reasoning that no F ARs prohibits the use of small, 

unmanned multi-rotor aircraft or lightweight UASs like those flown by other peer companies. 

Granting Crooked Pines Farm, LLC's request unites with the Secretary of Transportation's 

responsibilities to not only integrate UASs into the national airspace system, but to" ... establish 

requirements for the safe operation of such aircraft systems [UASs] in the national airspace 

system" under Section 333(c) of the Reform Act. Further, Crooked Pines Farm, LLC will conduct 

its operations in compliance with the protocols described herein or as otherwise established by the 

FAA. 

Granting Crooked Pines Farm, LLC exemption would benefit the public in that 

Congress has already pronounced that it is in the public's interest to integrate commercially 

flown UASs into the national airspace system, hence the passing of the Reform Act. Crooked 

Pines Farm, LLC will conduct research into safe UAS operations for every flight of its UASs. 

Flight data, visual inspections, recorded observations and flight analyses will be compiled to 

further enhance current safety protocols. 

Allowing Crooked Pines Farm, LLC to log more flight time directly relates to its research and its 

ability to further enhance current safety measures. The public has critical interest in reducing the 

danger and emission associated with current aerial cinematic capture methods, namely, full size 

helicopters. 

Crooked Pines Farm, LLC respectfully requests the grant of an exemption allowing it 

to operate small, lightweight, remote controlled multi-rotor UASs in Class G airspace. 

The specific sections ofTitle 14 ofthe Code ofFederal Regulations, ESRUAS requests 

exemption from: 

14CFR21; 14C.F.R.45.23(b); 14CFR61.113 (a)&(b); 14C.F.R. 9l,etseq.; 14CFR407 

(a)(l); 14 CFR 409 (a)(2); and, 14 CFR 417 (a) & (b). 

Exemption Request Section 333 ofthe FAA Reform Act and Part 11 ofthe Federal Aviation 

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

(2);91.103(b); 91.119; 91.121 ; 91.203(a) & (b); 91.405 (a); 91.407(a) (1); 91.409 (a) (2); 91.417 

(a) & (b). 
The Extent of Crooked Pines Farm, LLC Seeks and the Reason It 

Seeks Such Relief: 

Crooked Pines Farm, LLC submits this application in accordance with the Reform Act, 112 P.L. 

95 §§ 331-334, seeking relief from any currently applicable F ARs operating to prevent ESRUAS 

contemplated commercial photography, research and other flight operations within the national 

airspace system. The Reform Act in Section 332 provides for such integration of civil unmanned 

aircraft systems into our national airspace system as it is in the public's interest to do so. Crooked 

Pines Farm, LLC's lightweight UASs meet the definition of "small unmanned aircraft" as 

defined in Section 331 and therefore the integration of Crooked Pines Farm, LLC's lightweight 

UASs are expressly contemplated by the Reform Act. Crooked Pines Farm, LLC would like to 

operate its lightweight UASs prior to the time period by which the Reform Act requires the FAA 

to promulgate rules governing such craft. 

The Reform Act guides the Secretary in determining the types ofUASs that may operate 

safely in our national airspace system. Considerations include: 

The weight, size, speed and overall capabilities of the UAS; Whether the UAS will be 

operated near airports or populated areas; and, Whether the UAS will be operated by line of 

sight 

112 P.L. 95 § 333 (a). Each ofthese items militates in favor of an exemption for ESRUAS. 

Crooked Pines Farm, LLC UASs utilizes four counter-rotating propellers for precise 

control and stability. They each weigh less than 25 pounds, including photography or other 

equipment. Each of Crooked Pines Farm, LLC small unmanned aircraft are designed to primarily 

hover in place and operate at less than a 40 knot maximum speed. They are capable of vertical 

and horizontal operations but operate only within the line of sight of the remote control pilot. In 

addition to the remote control pilot, Crooked Pines Farm, LLC uses a spotter and a technician, 

such that, at minimum, two Crooked Pines Farm, LLC personnel govern the safe flight of an 

Crooked Pines Farm, LLC aircraft at all times. 

Utilizing battery power and not combustible fuels, flights generally last between two and 

twenty minutes. Crooked Pines Farm, LLC does not operate its UASs with less than twenty five 

percent battery capacity. Safety systems in place include a GPS mode that allows Crooked Pines 

Farm, LLC UASs to hover in place if communication with the radio control pilot is lost and then 

slowly descend the aircraft until landing. Further, Crooked Pines Farm, LLC aircraft are 

programmed to slowly descend when twenty five percent battery capacity has been reached. 

Crooked Pines Farm, LLC does not operate its UASs near airports and generally does 

not operate them near populated areas. Crooked Pines Farm, LLC only operates its UASs in 

predetermined areas and only in compliance with FAA regulations. 

Crooked Pines Farm, LLC operation of its fleet of small, unmanned aircraft will not 

"create a hazard to users ofthe national airspace system or the public." 112 P.L. 95 § 333 (b). 

Given the small size and weight of Crooked Pines Farm, LLC UASs, combined with their 

superior maneuverability and operation in well-controlled areas, Crooked Pines Farm, LLC's 

aircraft lay within Congress's contemplated safety zone when it promulgated the Reform Act 

and the corresponding directive to integrate UASs into the ational airspace system. Crooked 

Pines Farm, LLC aircraft do not pose any threat to the general public or national security. 
The FAA has the authority to issue the exemption to ESRUAS pursuant to the Federal Aviation 

Act, 85 P.L. 726 (1958), as amended (the "Act"). 

Commercial and Public Benefits 

Granting Crooked Pines Farm, LLC exemption request furthers the public interest. 

First, Congress has already pronounced that it is in the public's interest to integrate 

commercially flown UASs into the national airspace system, hence the passing of the Reform 

Act. Second, Crooked Pines Farm, LLC conducts research into safe UAS operations every 

time it flies one of its UASs. Flight data, visual inspections, recorded observations and flight 

analyses are compiled to further enhance current safety protocols. Allowing Crooked Pines 

Farm, LLC to log more flight time directly relates to its research and its ability to further 

enhance current safety measures. Third, the public has an interest in reducing the danger and 

emission associated with current aerial cinematic capture methods, namely, full size 

helicopters. Crooked Pines Farm, LLC's UASs are battery powered and create no emissions. If 

an Crooked Pines Farm, LLLC UAS crashes there is no fuel to ignite and explode. The impact 

of Crooked Pines Farm, LLC's lightweight UASs is far less than a full size helicopter, despite 

the statistically noteworthy safety record of full size helicopters used in aerial picture capture. 

The public's interest is furthered by minimizing ecological and crash impacts by permitting 

aerial photography capture through Crooked Pines Farm, LLC's lightweight UASs. 

Progression of the arts and sciences has been fundamental to our society since its 

inclusion in the United States Constitution. Indeed, Congress mandated the integration ofUASs 

into our national airspace system, in part, to achieve progression in this noteworthy, and 

inevitable, field. Permitting Crooked Pines Farm, LLC to immediately fly within the United 

States furthers these objectives. Whether it is the combination of scientific discoveries applicable 

to societal advancement (including those drawing upon architecture, physics, engineering and 

cultural inclusiveness) to advancements in publicly usable technologies or advancements in 

equipment available to law enforcement personnel/first responders that does not cost millions of 

dollars, granting Crooked Pines Farm, LLC exemption request substantially furthers the public's 

interest in ways known and currently unknown. 

Reasons Why Crooked Pines Farm, LLC Exemption Will Not Adversely Affect Safety Or How 

The Exemption Will Provide a Level of Safety At Least Equal To Existing Rule: 

Crooked Pines Farm, LLC's exemption will not adversely affect safety. Quite the 

contrary, for the reasons stated, supra, permitting ESRUAS to log more flight time in FAA 

airspace will allow Crooked Pines Farm, LLC to innovate and implement new and as of yet 

undiscovered safety protocols. In addition, Crooked Pines Farm, LLC submits the following 

representations of its flight standards: 

• Crooked Pines Farm, LLC UASs weigh less than 25 pounds complete with small, 

high-definition cameras like the GoPro or Canon T3i; 

• Crooked Pines Farm, LLC only operates its UASs 

below 400 feet; 

• Crooked Pines Farm, LLC UASs only operate for 2-25 

minutes per flight; 
• Crooked Pines Farm, LLC lands its UASs before they reach 25% 

battery power; 

• Crooked Pines Farm, LLC remote control pilots operate Crooked Pines 

Farm, LLC UASs by line of sight; 

• Crooked Pines Farm, LLC remote control pilots have video backup and nearest 

airfield(s) contact information should they somehow lose sight of the UAS; 

• Crooked Pines Farm, LLC staffs each flight with a remote control pilot, technician 

and spotter with communication systems enabling real time communication between 

them; 

• Crooked Pines Farm, LLC UASs have GPS flight modes whereby they hover and 

then slowly land if communication with the remote control pilot is lost or battery power 

is below 25%; 

• Crooked Pines Farm, LLC actively analyses electronic flight data and other sources 

of information to constantly update and enhance safety protocols; 

• Crooked Pines Farm, LLC only operates in secured areas that are controlled, are away 

from airports and highly populated areas; 

• Crooked Pines Farm, LLC only operates during 

daylight hours; 

• Crooked Pines Farm, LLC conducts extensive pre-flight checks, boundaries and 

awareness prior to flight, during which safety carries primary importance; 

• Crooked Pines Farm, LLC always obtains all necessary permissions prior to 

operation; and, Crooked Pines Farm, LLC has procedures in place to abort flights in the 

event of safety breaches or potential danger. 

Crooked Pines Farm, LLC provides a level of safety at least equal to existing rules, and 

in nearly every instance, greater than existing rules. It is important to note that absent 

the integration of commercial UASs into our national airspace system, helicopters are 

the primary means of aerial photography. While the safety record of such helicopters is 

great, it is far safer to operate a battery powered lightweight UAS. First, the potential 

loss of life is diminished because UASs carry no people on board and Crooked Pines 

Farm, LLC only operates them in specific areas away from mass populations. Second, 

there is no fuel on board a UAS and thus the potential for fire or explosions is greatly 

diminished. Third, the small size and extreme maneuverability of Crooked Pines Farm, 

LLC UASs allow remote control pilots to avoid hazards. Also, Crooked Pines Farm, 

LLC UASs noise emissions, compared to today's helicopters, are drastically lower. 

Lastly, given their small size and weight, even when close enough to capture images, 

Crooked Pines Farm, LLC UASs need not be so close to the objects they are focused 

on. Accordingly, Crooked Pines Farm, LLC UASs will operate at and above current 

safety levels. 

Summary The FAA May Publish in the Federal Register 

Part 21 prescribes the procedural requirements for issuing and changing design approvals, 

productions approvals, airworthiness certificates, and airworthiness approvals. 
14 C.F.R. 21, Subpart H, entitled Airworthiness Certificates, sets forth requirements for 

procurement of necessary airworthiness certificates in relation to FAR § 91.203(2)(b, c, & d) & 

91.317(£)(2), (g), (j)(1 & 2). The size, weight, speeds, flight maneuvers and controlled 

operational area of Crooked Pines Farm, LLC UASs permits exemption from Part 21 because 

Crooked Pines Farm, LLC's UASs meet an equivalent level of safety pursuant to Section 333 of 

the Reform Act. The FAA is authorized to exempt aircraft from the airworthiness certificate 

requirement under both the Act (49 U.S.C. § 44701 (f)) and Section 333 of the Reform Act. Both 

pieces of legislation permit the FAA to exempt UASs from the airworthiness certificate 

requirement in consideration of the weight, size, speed, maneuverability and proximity to areas 

such as airports and dense populations. Crooked Pines Farm, LLC multi-rotor UASs do not carry 

passengers nor crewmembers, therefor, are not designed with a cabin or a cockpit. Furthermore, 

Crooked Pines Farm, LLC UASs will not be operating in or out of airports and in view of the 

fact that Crooked Pines Farm, LLC multi-rotor UASs are electrically powered by small lithiumpolymer (LiPo) batteries and emit no known emissions -- fuel regulations for aircraft do not 

apply. Therefore Crooked Pines Farm, LLC's UASs meet or exceed each of these elements and 

elements proposed in Docket No.: FAA-2015-0150; Notice No. 15-01. Part 107. 14 C.F.R. 91.7 

(a) prohibits the operation of an aircraft without an airworthiness certificate. No such certificate 

will be applicable in the form contemplated by the F ARs. With proposed Docket No.: FAA20 15-0 150; Notice No. 15-1 as no such certificate will be applicable, this Regulation is 

inapplicable. 

14 C.F.R. § 91.9 (b) (2) requires an aircraft flight manual in the aircraft. As there are no pilots or 

passengers, and given the size of the UASs, this Regulation is inapplicable. An equivalent level of 

safety will be achieved by maintaining a manual at ESRUAS's flight operations center. The FAA 

has previously issued exemptions to this regulation in Exemption Nos. 8607, 8737, 8738, 9299, 

9299A, 9565, 9565B, 10167, 10167A, 10602, 10700 and 32827. 

14 C.F.R. § 91.121 regarding altimeter settings is inapplicable insofar as Crooked Pines Farm, 

LLC UASs utilize electronic global positioning systems and internal gyroscopes and altimeters to 

provide spatial coordination. 

14 C.F.R. § 91.203 (a) and (b) provides for the carrying of civil aircraft certifications and 

registrations. They are inapplicable for the same reasons described above - with recently 

proposed Docket No.; F AA-20 15-0 150; Notice No. 15-1. The equivalent level of safety will be 

achieved by maintaining such quality assurance and registrations reports at the Crooked Pines 

Farm, LLC flight operations center. 

14 C.F.R. § 45.23: Marking ofThe Aircraft. 

Applicable Codes of Federal Regulation require aircraft to be marked according to certain 

specifications. Crooked Pines Farm, LLC UASs are unmanned-- they, therefore, do not have a 

cabin, cockpit or pilot station on which to mark certain words or phrases. Further, two-inch 

lettering is difficult to place on such a small aircraft. Regardless, Crooked Pines Farm, LLC will 

mark its UASs in the largest possible lettering by placing identification marks on its frame as 

required by 14 C.F.R. § 45.29 (f) so that the pilot, technician, spotter and others working with the 

UA V will be identifiable and will see the markings. The FAA has previously issued exemptions 

to this regulation through Exemptions Nos. 8738, 10167, 10167A and 10700. 
14 C.F.R. § 61.113: Private Pilot Privileges and Limitations: PIC. 

Pursuant to 14 C.F.R. §§ 61.113 (a) & (b), private pilots are limited to non-commercial 

operations. Crooked Pines Farm, LLC can achieve an equivalent or superior level of safety as 

achieved by current Regulations because Crooked Pines Farm, LLC UASs do not carry any pilots 

or passengers- the operators will maintain visual line of site ofUA and given the size, weight, 

speed, maneuverability and operating parameters of Crooked Pines Farm, LLC UAS's risk to 

people and property is reduced. Further, while helpful, a pilot license will not ensure remote 

control piloting skills, though Crooked Pines Farm, LLC pilot vetting and training programs will. 

Further, private pilot licensees require 60-70 hours of flight time - with hundreds of hours of 

computer simulation and remote control aircraft [50+ hours of multi-rotor UAS] experience the 

person in control of the UA will operate Crooked Pines Farm, LLC UASs with the same or more 

skill. Further, the risks attendant to the operation of Crooked Pines Farm, LLF UASs is far less 

than the risk levels inherent in the commercial activities outlined in 14 C.F.R. § 61 , et seq -

Crooked Pines Farm, LLC maintains visual ofUA via a spotter, altitude ofUA will never 

exceed 400ft AGL. Thus, allowing Crooked Pines Farm, LLC to operate its multi-rotor UASs 

with it's current experience and standards meets the minimum safety requirements of 14 

C.F.R. §61.113 (a) & (b). 

14 C.F.R. 91.119: Minimum Safe Altitudes. 

14 C.F.R. § 91 .119 prescribes safe altitudes for the operation of civil aircraft. It allows 

helicopters to be operated at lower altitudes in certain conditions. As proposed in Docket No.: 

FAA-2015-0150; Notice No. 15-01, Crooked Pines Farm, LLC UASs never operates at an 

altitude greater than 400 AGL. Crooked Pines Farm, LLF will, however, operate its UASs at a 

much lower altitude than proposed in Docket No.: FAA-2015-0150; Notice No. 15-01, a level 

of safety exceeding those in relation to minimum safe altitudes. Given the size, weight, 

maneuverability and speed of Crooked Pines Farm, LLC UASs, an equivalent level of safety 

will be achieved. 

14 C.F.R. 91.405 (a); 407 (a) (1); 409 (a) (2); 417(a) & (b): Maintenance Inspections. 

The above-cited Regulations require, amongst other things, aircraft owners and operators 

to "have [the] 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." These Regulations only apply to aircraft with an 

airworthiness certificate. They will not, therefore, apply to Crooked Pines Farm, LLC 

should its requested exemption be granted. Crooked Pines Farm, LLC conducts an 

extensive maintenance program that involves regular software updates and constant 

mechanical inspection for assessment of any damaged hardware. Therefore, an equivalent 

or greater level of safety will be achieved. Crooked Pines Farm, LLC has researched its 

designs. 

Summary 
Crooked Pines Fann, LLF seeks an exemption from the following Regulations: 14 C.F.R. 21 , 

subpart H; 14 C.F.R.45.23(b); 14 C.F.R. §§ 61.113 (a) & (b); 14 C.F.R. § 91.7 (a) & (b); 14 C.F.R. § 

91.9 (b)(2); 14 C.F.R. § 91.119; 14 C.F.R. § 91.121; 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); and, 14 C.F.R. §§ 91.417 (a) & (b) 

to commercially operate small lightweight unmanned aerial vehicles in aerial photography and 

research operations, to conduct its own fieldwork and to assist in the development of platforms for 

photographers, first responders, law enforcement, and search & rescue. 

Granting Crooked Pines Fann, LLC's request for exemption will enhance safety protocols thereby 

reducing risk of incident. Aerial photography relies primarily on the use of larger aircraft, housing a 

crew and running on combustible fuel. Crooked Pines Fann, LLC aircraft do not house a crew of 

pilots nor do they contain combustible fuel --they are smaller, lighter and more maneuverable than 

conventional aircraft. Additionally, Crooked Pines Farm, LLC aircraft operate at lower altitudes and 

will not interfere with conventional aircraft. Crooked Pines Farm, LLC has been analyzing flight 

data, flight film and other information to compile above-standard safety protocols and the 

implementation oftlight operations that exceeds current procedures of safe flight 

There are no people on board Crooked Pines Fann, LLC aircraft therefore the likelihood of death or 

serious bodily injury is significantly limited. Crooked Pines Fann, LLC will ensure positive growth 

of it's safety and flight protocols with multi-rotors Crooked Pines Fann, LLC operation of its UASs, 

weighting less than 25 pounds and traveling at speeds lower than 40 knots in exclusive areas will 

provide at least an equivalent level of safety as that achieved under current F ARs. 

With current knowledge and experience and until operator certifications become clearer 

Crooked Pines Farm, LLC respectfully requests that the FAA grant its exemption request without 

delay. The FAA has the authority to issue the exemption sought by Crooked Pines Farm, LLC 

pursuant to the Federal Aviation Act, 85 P.L. 726 (1958), as amended (the "Act"). 

Respectfully, 

41/.~L M D..n:al CrisxE, CEO 

Crt:x)q:d Pres Fam, LLC 

3551-tarro¥ Rd. 

E.ct:rtl1, GA. 31024