RoadRunner Drone Service, LLC

Cordell Walker

3080 North State Route 89 Lot 32

Prescott, AZ 86301

US Department of Transportation Exemption Request Pursuant to Section 333 of the FAA

Reform Act and Part 11 of the Federal Aviation

Re: Exemption Request Pursuant to Section 333 of the FAA Reform Act and Part 11 of the

Federal Aviation Regulations from:

14 CFR 21 subpart H; 14 CFR 45.23(b); 14 CFR 61.113(a) and (b); 14 CFR 91.7(a); 14 CFR

91.9(b)(2); 14 CFR 91.103; 14 CFR 91.109; 14 CFR 91.119(c); 14 CFR 91.121; 14 CFR

91.151(a); 14 CFR 91.203 (a) and (b); 14 CFR 91.405 (a); 14 CFR 91.407 (a) (1) 14 CFR

91.409 (a)(1) and (2); 14 CFR 91.417(a) and (b)

Dear Sir or Madam:

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the “Reform Act”)

and 14 CFR Part 11, RoadRunner Drone Service LLC operator of Unmanned Aircraft Systems

(UAS), hereby applies for an exemption from the listed Federal Aviation Regulations (“FARs”) to

allow commercial operation of designated UAS, provided such operations are conducted within

and under the conditions outlined herein or as may be established by the FAA as required by

Section 333.

Thank you in advance for your consideration.

Commercial operation of an UAS, as described herein, which are equipped with camera(s) and

sensors, would provide professional services in the following areas:

1. Aerial photography and/or video for public and/or private use including real estate,

architecture, land surveying, engineering and other related professional activities.

2. Aerial video and/or photography for public and/or private use including television, public
events, cinematography and news gathering.

3. Aerial inspection/photography of residential/commercial structures under contract with the

owners or local government authority.

4. Aerial inspection/photography of residential/commercial utility infrastructure including but not

limited to electrical power lines, wind turbines and cell towers.

5. Aerial video/photography or providing live video feed to assist with observation/search and rescue

operations in cases of an emergency or natural disaster only when the local authorities or

government has requested it by contract or donation.

6. Training to persons individually or belonging to both private and/or public organizations to

increase awareness and improve safety for current and future UAS operations within the NAS.

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As described fully below, the requested exemption would permit the operation of designated

UAS as set forth in this document under controlled conditions in the NAS that would be a)

limited b) controlled c) predetermined and d) safe. Approval of this exemption would increase

public awareness of UAS operations and enhance safety to aid in fulfilling the Secretary of

Transportation’s (the FAA Administrator’s) responsibilities to “....establish requirements

for the safe operation of such aircraft systems in the national airspace system.”

The name and address of the applicant is:

RoadRunner Drone Service LLC

Cordell Walker

3080 North State Route 89 Lot 32

Prescott, AZ 86301

Email: cwalker614@gmail.com

Phone: 928-910-5646

Regulations from which the exemption is requested: 14 CFR Part 21 subpart H
14 CFR 45.23 (b)

14 CFR 61.113 (a) & (b)

14 CFR 91.7 (a)

14 CFR 91.9 (b) (2)

14 CFR 91.103

14 CFR 91.109

14 CFR 91.119 (c)

14 CFR 91.121

14 CFR 91.151 (a)

14 CFR 91.203 (a) & (b)

14 CFR 91.405 (a)

14 CFR 91.407 (a) (1)

14 CFR 91.409 (a) (2)

14 CFR 91.417 (a) & (b)

RoadRunner Drone Service LLC will operate one or more of the following models:

DJI Phantom 3 Professional

DJI Inspire 1

These aircraft have fail safe features to include geo fencing and lost link return home capability.

DJI is the manufacturer of multi-rotor sUAS aircraft weighing less than 25lbs and has developed

technology that will enhance safe sUAS operations within the NAS.

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Phantom 3 Professional Specifications:

Aircraft:

Weight (Including Battery And Propellers) - 1280 g

Diagonal Size (Including Propellers) -590 mm
Max Ascent Speed -- 5 m/s

Max Descent Speed -- 3 m/s

Hover Accuracy Vertical: -- +/- 0.1 m (when Vision Positioning is active) 

or +/- 0.5 m

Horizontal: +/- 1.5 m

Max Speed -- 16 m/s (ATTI mode, no wind)

Max Altitude Above Sea Level -- 6000 m

Operating Temperature -- 0°C to 40°C

GPS Mode -- GPS/GLONASS

Battery:

Capacity --- 4480 mAh

Voltage --- 15.2 V

Battery Type --- LiPo 4S

Energy --- 68 Wh

Net Weight --- 365 g

Max Flight Time --- Approximately 23 minutes

Operating Temperature --- -10°C to 40°C

Max Charging Power --- 100 W

Camera:

Sensor --- Sony EXMOR 1/2.3” Effective pixels: 12.4 M (total pixels: 12.76 M)

Lens --- FOV 94° 20 mm (35 mm format equivalent) f/2.8, focus at ∞!

ISO Range --- 100-3200 (video) 100-1600 (photo)

Shutter Speed --- 8s -1/8000s

Image Max Size --- 4000 x 3000

Operating Temperature --- 0°C to 40°C
Gimble:

Controllable Range --- Pitch -90° to +30°

Stabilization --- 3-axis (pitch, roll, yaw)

Remote:

Operating Frequency --- 2.400 GHz-2.483 GHz

Max Distance --- 2000m (outdoors and unobstructed)

Video Output Port - USB

Operating Temperature --- 0°C- 40°C

Battery --- 6000 mAh LiPo 2S

Mobile Device Holder for tablet or phone

Receiver Sensitivity (1%PER) -101 dBm ±2 dBm

Working Voltage --- 1.2 A @7.4 V

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DJI Inspire 1 Specifications:

Aircraft:

Weight (Battery Included)- 2935 g

Hovering Accuracy (GPS Mode) -Vertical: 0.5 m Horizontal: 2.5 m

Max Angular Velocity Pitch: 300°/s Yaw: 150°/s

Max Tilt Angle 35°

Max Ascent Speed 5 m/s

Max Descent Speed 4 m/s

Max Speed 22 m/s (ATTI mode, no wind)

Max Flight Altitude 4500 m

Max Wind Speed Resistance 10 m/s

Max Flight Time Approximately 18 minutes
Indoor Hovering Enabled by default

Operating Temperature Range -10° to 40° C

Dimensions - 438x451x301 mm

Battery:

Capacity 4500 mAh

Voltage 22.2 V

Battery Type LiPo 6S High voltage battery

Energy 99.9 Wh

Net Weight 570 g

Operating Temperature Range -10° to 40° C

Max Charging Power 180 W

Camera:

Name X3

Model FC350

Total Pixels 12.76M

FOV (Field Of View) 94°

Gimble:

Mounting Detachable

Operating Current Station: 750 mA

Motion: 900 mA

Controllable Range Pitch: -90° to +30° Pan: ±320°

Given the small size of the UAS in scope and the controlled environment provided, the proposed 

operations will adhere to the Reform Act’s safety requirements. The approval of this application 

presents no national security issues. Regarding the level of safety surrounding the proposed operations 

and the public benefit, reduction in environmental impacts, including but not limited to reduced 

emissions and noise, the grant of the requested exemption is in the public interest. Accordingly, the 

applicant graciously requests that the FAA grant the requested exemption.
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AIRCRAFT AND EQUIVALENT LEVEL OF SAFETY

The operation limitations proposed for an equivalent or higher level of safety because

operations will further enhance the safety of the persons and/or property using conventional

aircraft. These limitations and conditions to which the applicant agrees to adhere to when

conducting commercial operations under the FAA issued exemption as set forth in the Flight

Operations Manual (FOM) include:

1. The UAS will weigh significantly less than 55 lbs.

2. The UAS, depending on the model in operation, will have a maximum operating speed of no

more than 50mph.

3. Flights will be operated within line of sight of the Pilot in Command (PIC) and/or Visual

Observer (VO).

4. Maximum flight time for each operational flight will be depending on the UAS model in

operation, but will not exceed 30 minutes. Flights will be terminated at 25% battery power

reserve.

5. Flights will be operated at an altitude of no more than 400 feet Above Ground Level (AGL)

and not more than 200 feet above an elevated platform from which filming is planned.

6. Minimum crew for each operation will consist of the UAS Pilot and at least one Visual

Observer (VO), and may include a third, but separate, Camera Operator (CO).

7. The UAS pilot will be the designated Pilot in Command (PIC) . The PIC must log a minimum

of 20 hours on the designated UAS. The PIC will be required to hold a commercial pilot certificate in

fixed wing or rotorcraft. The PIC will hold and maintain a minimum of a Class 2 FAA Medical.

8. A safety briefing will be performed prior to each day’s flights consisting of all the days’

production activities.

9. All flight activities will be logged.
10. All flights will occur under Visual Flight Rules Meteorological Conditions (VMC) only.

11. The flights will occur in Class G airspace no closer than a 5 mile radius of the geographic

center/Airport Reference Point (ARP) of a tower controlled or uncontrolled airport.

12. Flights will not be closer than a 5 mile radius of the geographic center/Airport.

13. The operator will file FAA Form 77111, or its equivalent, as modified in light of the requested

exemption, with the appropriate local Flight Standards District Office (FSDO) no more than 72

hours but no less than 48 hours from planned operation.

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14. The operator will obtain verbal/written consent of all persons involved with the planned

operation and ensure that only consenting persons will be allowed within 100 feet of the flight

operation, and the radius may be reduced to 30 feet based upon an equivalent level of safety

determination, as U.S. Department of Transportation required under the FOM. With the

advanced permission of the FSDO, operations at closer range may be approved.

15. The PIC and VO will have been trained in operation of UAS and receive uptodate

information for the particular UAS to be operated.

16. The PIC and VO will be able to communicate by voice and/or radio at all times.

17. Written and/or verbal permission and permits will be obtained from territorial, state, county

or city jurisdictions, including law enforcement, fire or other appropriate governmental agencies

as appropriate to flight operations.

18. If the UAS loses communications with the remote controller or loses GPS signal, the UAS

will have the capability to return to a predetermined location within a designated location and

land autonomously.

19. The UAS will have the capability to abort a flight in case of emergencies with an automated

“Return Home and Land” function.

20. The UAS will have the capability to abort a flight in case of unpredicted obstacles, weather,
or emergencies such as low battery.

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14 C.F.R. Part 21, Subpart H: Airworthiness Certificates 14 C.F.R. §91.203 (a) (1) Subpart H,

entitled Airworthiness Certificates, establishes the procedural requirements for the issuance of

airworthiness certificates as required by FAR §91.203 (a) (1). Given the size and limited

operating area associated with the aircraft to be utilized by the Applicant, an exemption from

Part 21 Subpart H meets the requirements of an equivalent level of safety under Part 11 and

Section 333 of the Reform Act. The Federal Aviation Act (49 U.S.C.§44701 (f)) and Section 333

of the Reform Act both authorize the FAA to exempt aircraft from the requirement for an

airworthiness certificate, upon consideration of the size, weight, speed, operational capability,

and proximity to airports and populated areas of the particular UAS. In all cases, an analysis of

these criteria demonstrates that the UAS operated without an airworthiness certificate in the

restricted environment and under the conditions proposed will be at least as safe, or safer, than

a conventional aircraft (fixed wing or rotorcraft) operating with an airworthiness certificate

without the restrictions and conditions proposed. The UAS to be operated hereunder is less

than 55 lbs. fully loaded, carries neither a pilot nor passenger, carries no explosive materials or

flammable liquid fuels, and operates exclusively within a secured and designated area. Unlike

other civil aircraft, operations under this exemption will be tightly controlled and monitored by

both the operator and under the requirements and in compliance with local public safety

requirements. These safety enhancements provide a greater degree of safety to the public and

property owners than conventional operations conducted with airworthiness certificates issued

under 14 C.F.R. Part 21, Subpart H. Lastly, application of these same criteria demonstrates that

there is no credible threat to national security posed by the UAS, due to its size, speed of

operation, location of operation, lack of explosive materials or flammable liquid fuels, and

inability to carry a substantial external load.
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14 C.F.R. § 45.23 (b). Marking of the Aircraft The regulation requires: When marks include only

the Roman capital letter "N" and the registration number is displayed on limited, restricted or

lightsport category aircraft or experimental or provisionally certificated aircraft, the operator must

also display on that aircraft near each entrance to the cabin, cockpit, or pilot station, in letters

not less than 2 inches nor more than 6 inches high, the words "limited," "restricted," "lightsport,"

"experimental," or "provisional," as applicable. Even though the UAS will have no airworthiness

certificate, an exemption may be needed as the UAS will have no entrance to the cabin, cockpit

or pilot station on which the word “Experimental” can be placed. Given the size of the UAS, twoinch

lettering will be impossible. The word “Experimental” will be placed on the fuselage in

compliance with §45.29 (f). US Department of Transportation February 20, 2015 The equivalent

level of safety will be provided by having the UAS marked on its fuselage as required by §45.29

(f) where the pilot, observer and others working with the UAS will see the identification of the

UAS as “Experimental.” 14 C.F.R. § 61.113 (a) and (b): Private Pilot Privileges and Limitations:

Pilot in Command. Pursuant to 14 CFR 61.113 (a) & (b), no person who holds a private pilot

certificate may act as a pilot in command of an aircraft that is carrying passengers or property

for compensation or hire. The proposed UAS operations may achieve an equivalent level of

safety as achieved by current Regulations because the applicant’s UAS do not carry any pilots

or passengers nor property. The risks attendant to the operation of UAS is far less than the risk

levels inherent in the commercial activities outlined in 14 CFR 61. The PIC of the UAS will be, or

be under the direct supervision of, a FAA Certificated Private Pilot with current Third Class or

higher medical certificate. It is believed that the operation and limitations set forth in the FOM

will equate to the safe operation of the UAS.

14 C.F.R. §91.7(a): Civil Aircraft Airworthiness. The regulation requires that no person may

operate a civil aircraft unless it is in airworthy condition. As there will be no airworthiness
certificate issued for the aircraft, should this exemption be granted, no FAA regulatory standard

will exist for determining airworthiness. Given the size of the aircraft for maintenance and use of

safety checklists prior to each flight, an equivalent level of safety will be provided.

14 C.F.R. § 91.9 (b) (2): Civil Aircraft Flight Manual in the Aircraft. Section 91.9 (b) (2) provides:

No person may operate a U.S.registered civil aircraft ... (2) For which an Airplane or Rotorcraft

Flight Manual is not required by §21.5 of this chapter, unless there is available in the aircraft a

current approved airplane or Rotorcraft Flight Manual, approved manual material, markings, and

placards, or any combination thereof. The UAS, given its size and configuration has no ability or

place to carry such a flight manual on the aircraft, not only because there is no pilot on board,

but because there is no room or capacity to carry such an item on the aircraft. The equivalent

level of safety will be maintained by keeping the flight manual at the ground control point where

the pilot flying the UAS will have immediate access to it.

14 C.F.R. § 91.103: Preflight Action. This regulation requires each pilot in command to take

certain actions before flight to insure the safety of flight. As FAA approved rotorcraft flight

manuals will not be provided for the aircraft an exemption will be needed. The PIC will take all

actions as stated in the FOM in Section 4 under Normal Procedures including but not limited to

reviewing weather, flight battery requirements, landing and takeoff distances and aircraft

performance data before initiation of flight.

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14 C.F.R. §91.109: Flight Instruction. Section 91.103 provides that no person may operate a civil

aircraft (except a manned free balloon) that is being used for flight instruction unless that aircraft

has fully functioning dual controls. UAS and remotely piloted aircraft, by their design do not have

fully functional dual controls. Flight control is accomplished through the use of a control box that

communicates with the aircraft via radio communications. The FAA has approved exemptions

for flight training without fully functional dual controls for a number of aircraft and for flight
instruction in experimental aircraft. The equivalent level of safety is provided by the fact that

neither a pilot nor passengers will be carried in the aircraft and by the size and speed of the

aircraft.

14 C.F.R. §91.119: Minimum Safe Altitudes. Section 91.119 establishes safe altitudes for

operation of civil aircraft. Section 91.119 (d) allows helicopters to be operated at less than the

minimums prescribed, provided the person operating the helicopter complies with any route or

altitudes prescribed for helicopters by the FAA. As this exemption is for a UAS that is a

helicopter and the exemption requests authority to operate at altitudes up to 400 AGL, or not

more than 200 above an elevated platform from which filming is planned, an exemption may be

needed to allow such operations. As set forth herein, the UAS will never operate at higher than

400 AGL with the exception that in circumstances where the UAS is used to survey or

photograph a structure whose height exceeds 400 feet AGL, the UAS will not be operated more

than 200 feet above the highest point on the structure. It will however be operated in a restricted

area with security perimeter, where buildings and people will not be exposed to operations

without their preobtained consent. The equivalent level of safety will be achieved given the size,

weight, and speed of the UAS as well as the location where it is operated. No flight will be taken

without the permission of the property owner or local officials. Because of the advance notice to

the property owner and participants in the filming activity, all affected individuals will be aware of

the planned flight operations. Compared to flight operations with aircraft or rotorcraft weighting

far more than the maximum 55lbs. proposed herein and the lack of flammable fuel, any risk

associated with these operations is far less than those presently presented with conventional

aircraft operating at or below 500 AGL. In addition, the low altitude operations of the UAS will

ensure separation between these UAS operations and the operations of conventional aircraft

that must comply with Section 91.119. 14 C.F.R. §91.121 Altimeter Settings. This regulation

requires each person operating an aircraft to maintain cruising altitude by reference to an
altimeter that is set “...to the elevation of the departure airport or an appropriate altimeter setting

available before departure.” As the UAS may not have a barometric altimeter, but instead a GPS

altitude read out, an U.S. exemption may be needed. An equivalent level of safety will be

achieved by the operator, pursuant to the safety check list and live flight data monitoring,

confirming the altitude of the launch site shown on the GPS altitude indicator before flight.

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

prohibits an individual from beginning “a flight in an airplane 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 – (1) During the day, to fly after that for

at least 30 minutes; or (2) At night, to fly after that for at least 45 minutes.” The applicant

believes that an exemption from 14 CFR §91.151(a) falls within the scope of prior exemptions.

Operating the UAS in a tightly controlled area where only people and property owners or official

representatives who have signed waivers will be allowed does not endanger the type of risks

that Section 91.151(a) was intended to alleviate given the size and speed of the small UAS. The

applicant believes that an equivalent level of safety can be achieved by limiting flights to 30

minutes or 25% of battery power — whichever happens first. This restriction would be more

than adequate to return the UAS to its planned landing zone from anywhere in its limited

operating area.

14 C.F.R. §91.203 (a) and (b): Carrying Civil Aircraft Certification and Registration The

regulation provides in pertinent part: (a) Except as provided in § 91.715, no person may operate

a civil aircraft unless it has within it the following: (1) An appropriate and current airworthiness

certificate. . . . (b) No person may operate a civil aircraft unless the airworthiness certificate

required by paragraph (a) of this section or a special flight authorization issued under §91.715 is

displayed at the cabin or cockpit entrance so that it is legible to passengers or crew. The UAS
fully loaded weighs well under the proposed 55lb limit and is operated without an onboard pilot.

As such, there is no ability or place to carry certification and registration documents or to display

them on the UAS. An equivalent level of safety will be achieved by keeping these documents at

the ground control point where the pilot flying the UAS will have immediate access to them, to

the extent they are applicable to the UAS.

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

regulations require that an aircraft operator or owner “shall have that aircraft inspected as

prescribed in subpart E of this part and shall between required inspections, except as provided

in paragraph (c) of this section, have discrepancies repaired as prescribed in part 43 of this

chapter...,” and others shall inspect or maintain the aircraft in compliance with Part 43. Given

that these sections and Part 43 apply only to aircraft with an airworthiness certificate, these

sections will not apply to the applicant. Maintenance will be accomplished by the operator

pursuant to the flight manual and operating handbook. An equivalent level of safety will be

achieved because the UAS is very limited in size and will carry a small payload and operate

only in restricted areas for a limited period of time. If mechanical issues arise the UAS can land

immediately and will be operating from no higher than 400 feet AGL. The operator will ensure

that the UAS is in working order prior to initiating flight, perform required maintenance, and keep

a log of any maintenance performed. Moreover, the operator is the person most familiar with the

aircraft and best suited to maintain the aircraft in an airworthy condition to provide the equivalent

level of safety. An equivalent level of safety will be achieved because maintenance and

inspections will be performed in accordance with the UAS Manufacturer's User Manual. As

provided in the FOM, the operator will ensure that the UAS is in working order prior to initiating

flight and perform required maintenance needed.

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Additional Information.

The applicant, Cordell Walker, believes this exemption request and associated safety

considerations adequately satisfy criteria provided in Section 333 of the Reform Act of 2012,

providing sufficient justification for the granting of commercial operations of the applicant’s UAS.

The applicant, Cordell Walker, requests your respective approval of this Section 333 exemption

petition request.

Thank you for your interest and attention in this matter. Please notify Cordell Walker of your

actions, and or approvals. Thank You for your interest in this request.

Sincerely,

Cordell Walker

RoadRunner Drone Serivce LLC

3080 North State Route 89 Lot 32

Prescott, AZ 86301

Email: cwalker614@gmail.com

Phone: 928-910-5646