U.S. Department of Transportation 

Docket Management System 

1200 New Jersey Ave., SE 

Washington, DC 20590 

July 1, 2015 

i._/;. 

. ~- . .j ' - ·, :· .· 

RE: Exemption Request Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 

Dear Sir or Madam: 

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the Reform Act) and 14 C.P.R. 

Part 11, Drone's Eye View Consulting, LLC, operator of Small Unmanned Aircraft Systems ("sUAS"), hereby 

applies for an exemption from Federal Aviation Regulations identified below, to allow commercial operations 

ofsUAS. 

The proposed operations include the following: 

• Aerial Surveying 

• Agriculture 

• Aerial Photography and Videography 

• Wildlife, Forestry and Agriculture monitoring 

• Construction site inspection and monitoring 

• Public Entity Support Operations 

• Education and Research 

As described more fully below, the requested exemption would permit the operation of sUAS under controlled 

conditions in airspace that is limited, predetermined, and controlled as to access. Approval of this exemption 

will create new benefits to the industries listed above as technical and inherently dangerous operations can be 

performed in a safer and more controlled manner by sUAS and their operators. Additionally, sUAS will 

provide economic benefit to these industries by improving efficiency and quality, and virtually eliminating 

human risk. 

The name and address of the petitioner is: 

Drone's Eye View Consulting, LLC 

Attn: Lott S Gilbert Bolden II 

209 E Monroe Ave 

Alexandria, VA 22301 

c I 703.431.9534 

e I gil@droneseyeviewconsulting.com 
Regulations from which the exemption is requested: 

14 CFR Part 21 

14 CFR Part 27 

14 C.F.R. 45.23(b) 

14 CFR 61.113 (a) & (b) 

14 C.F.R. 91.7 (a) 

14 CFR 91.9 (b)(2) 

14 C.F.R. 91.103 

14 C.F.R. 91.109 

14 C.F. R. 91.119 

14 C.F.R. 91.121 

14 CFR 91.151 (a) 

14 CFR 91.203 (a) & (b) 

14 CFR 91.405 (a) 

14 CFR 407 (a) (1) 

14 CFR 409 (a) (2) 

14 CFR 417 (a) & (b) 

The following sUAS's are submitted for exemption from the regulations above for use in safe operations listed 

above for the reasons expressed more fully below: 

DJI Phantom 2 

DJI Phantom 3 

DJI Inspire 1 

DJI S900 

DJI SIOOO 

3DR Robotic Solo 

3DRX8+ 

This exemption application is expressly submitted to fulfill Congress' goal in passing Section 333(a) through (c) 

of the Reform Act. This law directs the Secretary of Transportation to consider whether certain unmanned 

aircraft systems may operate safely in the national airspace system (NAS) before completion of the rulemaking 

required under Section 332 of the Reform Act. In making this determination, the Secretary is required to 

determine which types ofUASs do not create a hazard to users of the NAS or the public or pose a threat to 

national security in light of the following: 

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

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

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

Reform Act§ 333 (a). Lastly, if the Secretary determines that such vehicles "may operate safely in the national 

airspace system, the Secretary shall establish requirements for the safe operation of such aircraft in the national 

airspace system." Id. §333(c). 

Applicant interprets this provision to place the duty on the Administrator to not only process applications for 

exemptions under section 333, but for the Administrator to craft conditions for the safe operation of the UAS, 

if it should be determined that the conditions set forth herein do not fulfill the statutory requirements for 

approval. 

The Federal Aviation Act expressly grants the FAA the authority to issue exemptions. This statutory authority 

by its terms includes exempting civil aircraft as the term is defined under §40101 of the Act, that includes 

sUAS's, from the requirement that all civil aircraft must have a current airworthiness certificate. 
The Administrator may grant an exemption from a requirement of a regulation prescribed under subsection 

(a) or (b) of this section or any sections 44702/\44716 of this title if the Administrator finds the exemption in 

the public interest. 49 U.S.C. §44701(f) See also 49 USC §44711(a); 49 USC §44704; 14 CFR §91.203 (a) (1). 

Drone's Eye View Consulting sUASs are rotorcraft and fixed wing aircraft, weighting 55 lbs. or less including 

payload. They operate, under normal conditions at a speed of no more than 100 MPH. They will operate only 

in line of sight and will operate only within a sterile area. Such operations will insure that the sUAS will "not 

create a hazard to users of the national airspace system or the public." 

Reform Act Section 333 (b). 

Given the small size of the sUASs involved and the restricted sterile environment within which they will 

operate, the applicant falls squarely within that zone of safety (an equivalent level of safety) in which 

Congress envisioned that the FAA must, by exemption, allow commercial operations ofUASs to commence 

immediately. Also due to the size of the UASs and the restricted areas in which the relevant sUASs will 

operate, approval of the application presents no national security issue. Given the clear direction in Section 

333 of the Reform Act, the authority contained in the Federal Aviation Act, as amended; the strong equivalent 

level of safety surrounding the proposed operations, and the significant public benefit, including enhanced 

safety, reduction in environmental impacts, and reduced emissions, the grant of the requested exemptions is in 

the public interest. Accordingly, the applicant respectfully requests that the FAA grant the requested 

exemption without delay. 

AIRCRAFT AND EQUIVALENT LEVEL OF SAFETY 

The applicant proposes that the exemption requested herein apply to civil aircraft that have the characteristics 

and that operate with the limitations listed herein. These limitations provide for at least an equivalent or even 

higher level of safety to operations under the current regulatory structure because the proposed operations 

represent a safety enhancement to the already safe operations conducted with conventional aircraft. These 

limitations and conditions to which Drone's Eye View Consulting agrees to be bound when conducting 

commercial operations under an FAA issued exemption include: 

1. The sUAS will weigh less than 55 lbs. 

2. Flights will be operated within line of sight of a pilot and/ or observer. 

3. Flights will be terminated at 25% battery power to ensure the safe return of the aircraft to the launch 

point. 

4. Flights will be operated at an altitude of no more than 400 feet AGL or, not more than 200 feet above 

an elevated platform from which filming is planned, with exception of telecommunication towers or 

high power lines, when altitude shall be limited to 100 feet above said tower or line. 

5. Minimum crew for each operation will consist of the sUAS Pilot, the Visual Observer, and/ or the 

Camera Operator. 

6. The sUAS pilot will be a designated Pilot in Command (PIC) and hold a valid state driver's license. If 

the PIC feels another operator to be qualified with the necessary skills to be PIC & possess a valid 

state driver's license or higher flight certificate, that person may be designated PIC provided they have 

a minimum of 20 hours of flight time with the s U AS. 

7. A briefing will be conducted in regard to the planned sUAS operations prior to each day's activities. It 

will be mandatory that all personnel who will be performing duties within the boundaries of the safety 

perimeter be present for this briefing. 

8. The operator will obtain the consent of all persons involved and ensure that only consenting persons 

will be allowed within 100 feet of the flight operation, and this radius may be reduced to 20 feet based 

upon an equivalent level of safety determination. 

9. Pilot and observer will have been trained in operation ofUAS generally and received up to date 

information on the particular UAS to be operated. 

10. Observer and pilot will at all times be able to communicate by voice. 

11. Written and/ or oral permission from the relevant property holders will be obtained. 

12. All required permissions and permits will be obtained from territorial, state, county or city 

jurisdictions, including local law enforcement, fire, or other appropriate governmental agencies. 

13. 15. If the sUAS loses communications or loses its GPS signal, the UAS will have capability to return 

to a predetermined location within the Security Perimeter and land. 
14. 16. The sUAS will have the capability to abort a flight in case ofunpredicted obstacles or 

emergencies. 

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

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 sUAS 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 area as set 

out in the Manual. Unlike other civil aircraft, operations under this exemption will be tightly controlled and 

monitored by the operator, pursuant to the Manual's requirements, and under the requirements and in 

compliance with local and public regulation. These safety enhancements, which already apply to civil aircraft 

operated in connection with motion picture and television production, provide a greater degree of safety to the 

public and property owners than conventional operations conducted with airworthiness certificates issued 

under 14 C.P.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. 

14 C.F.R. § 45.23 (b).Marking of the Aircraft 

The regulation requires: 

When marks include only the Roman capital1etter "N" and the registration number is displayed on limited, 

restricted or light-sport 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," "light-sport," "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 sUAS, two-inch lettering will be impossible. The word "Experimental" will be placed on 

the fuselage in compliance with §45.29 (f). 

The equivalent level of safety will be provided by having the sUAS marked on its fuselage as required by 

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

UAS as "Experimental." The FAA has issued the following exemptions to this regulation in Exemptions Nos. 

10700, 8738, 10167 and 10167A. 

14 C.F.R. § 61.113 (a) & (b): Private Pilot Privileges and Limitations: Pilot in Command. 

Drone's Eye View Consulting, LLC requests that the exemption allow operation without a private pilot 

certificate. Per 49 USC § 44 711, Drone's Eye View Consulting may not serve in any capacity as an airman 

with respect to a civil aircraft in air commerce without an airman certificate authorizing the airman to serve in 

the capacity for which the certificate was issued. 

On February 15, 2015 the FAA announced new proposed rules for SUASI. In that document 

(http:/ /www.gpo.gov/fdsys/pkg/FR-2015-02-23/pdf/2015-03544.pdf), the FAA stated the following: 
"in addition to obtaining an airworthiness certificate, any person serving as an airman in the 

operation of a small UAS must obtain an airman certificate. 49 U.S.C.44711(a)(2)(A). The statute 

defines an "airman" to include an individual who is "in command, or as pilot, mechanic, or member 

of the crew, who navigates aircraft when under way." 49 U.S.C. 40102(a}(8)(A). Because the person 

operating the small UAS is in command and is a member of the crew who navigates the aircraft, that 

person is an airman and must obtain an airman certificate. 

Under current pilot certification regulations, depending on the type of operation, the operator of the 

small UAS currently must obtain either a private pilot certificate or a commercial pilot certificate. A 

private pilot certificate cannot be used to operate a small UAS for compensation or hire unless the 

flight is only incidental to the operator's business or employment. Typically, to obtain a private pilot 

certificate, the small UAS operator currently has to: {1) Receive training in specific aeronautical 

knowledge areas; (2) receive training from an authorized instructor on specific areas of aircraft 

operation; {3) obtain a minimum of 40 hours of flight experience; and (4) obtain a third class airman 

medical certificate. Conversely holding at least a commercial pilot certificate allows the small UAS to 

generally be used for compensation or hire, but is more difficult to obtain. In addition to the 

requirements necessary to obtain a private pilot certificate, applicants for a commercial pilot certificate 

currently need to also obtain 250 hours of flight time, satisfy extensive testing requirements, and 

obtain a second-class airman medical certificate. 

While these airman certification requirements are necessary for manned aircraft operations, they 

impose an unnecessary burden for many small UAS operations. This is because a person typically 

obtains a private or commercial pilot certificate by learning how to operate a manned aircraft. Much 

of that knowledge would not be applicable to small UAS operations because a small UAS is operated 

differently than a manned aircraft. In addition, the knowledge currently necessary to obtain a private 

or commercial pilot certificate would not equip the certificate holder with the tools necessary to safely 

operate a small UAS. Specifically, applicants for a private or commercial pilot certificate currently are 

not trained in how to deal with the "see-and-avoid" and loss-of-positive-control safety issues that are 

unique to small unmanned aircraft. Thus, requiring persons wishing to operate a small UAS to obtain 

a private or commercial pilot certificate imposes the cost of certification on those persons, but does 

not result in a significant safety benefit because the process of obtaining the certificate does not equip 

those persons with the tools necessary to mitigate the public risk posed by small UAS operations" 

In addition to the FAA's recent findings, Drone's Eye View Consulting believes requiring a private pilot 

certificate is not in the public interest because (1) the expenses incurred by obtaining a private pilot license and 

maintaining it will have to be passed on to Drone's Eye View Consultings' customers, (2) flying manned 

aircraft is harmful to the environment, (3) flying manned aircraft poses a higher risk to people, property, and 

other aircraft than flying UAS, and (4) since Drone's Eye View Consulting has no interest in flying manned 

aircraft, the bare minimum will be done in order to satisfy the requirement of obtaining and maintaining a 

private pilot certificate. Pilots whom are not deeply invested in flying manned aircraft pose a much greater risk 

to people, property, and other aircraft. 

Since 49 USC§ 44 711 requires an airman certificate authorizing the airman to serve in the capacity for which it 

was issued, requiring a private pilot certificate does not satisfy this statutory requirement. This is evident since 

the FAA stated that obtaining a private pilot certificate for the purpose of operating a U AS ( 1) does not result 

in a significant safety benefit, (2) does not equip those persons with the tools necessary to mitigate the public 

risk posed by small UAS operation, and (3) much of that knowledge would not be applicable to small UAS 

operations because a small UAS is operated differently than a manned aircraft. Furthermore, Drone's Eye 

View Consulting believes requiring a private pilot certificate will (1) create an unnecessary burden that is 

detrimental to Drone's Eye View Consultings' operations, (2) will not increase the level of safety, (3) will 

introduce dangerous situations that pose a much higher risk to people, property, and other aircraft, and (4) is 

not in the public interest. Furthermore, the FAA does not require a private pilot certificate for noncommercial 

operations that perform the same flights, so removing this requirement will still allow Drone's Eye View 

Consulting to operate within a level of safety that is equal to the level of safety provided by existing rules. For 

those reasons, Drone's Eye View Consulting would like this requirement to be removed from the exemption 
and for the FAA to require a certificate that allows the airman to serve in the capacity for which it was issued 

so that Drone's Eye View Consulting is able to satisfy the statutory requirement in 49 USC§ 44 711. 

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 and the requirements 

contained in the Manual for maintenance and use of safety check lists 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 sUAS, 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 sUAS will have 

immediate access to it. The FAA has issued the following exemptions to this regulation: Exemption Nos. 

8607, 8737, 8738, 9299, 9299A, 9565, 9565B, 10167, 10167A, 10602, 32827, and 10700. 

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 including reviewing weather, flight battery requirements, landing and 

takeoff distances and aircraft performance data before initiation of flight. 

14 C.F .R. §91.1 09: 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. sUASs 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. See Exemption Nos.5778K & 9862A. The equivalent level of safety will be 

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 sUAS 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. An additional 

exemption is also requested for permission to operate at 100 feet above a transmission tower, communication 

tower, or bridge for the purpose of inspection. This will allow for safe inspection of the latter without potential 

conflict with other aircraft. As set forth herein, except for the limited conditions stated previously the UAS will 

never operate at higher than 400 AGL. It will, however, be operated in a restricted area with security 

perimeter, where buildings and people will not be exposed to operations without their pre-obtained 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 required permission of the property owner or 

local officials. Because of the advance notice to the property owner and participants in the aerial 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 sUAS will ensure separation 
between these small-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 sUAS may not have a barometric altimeter, but instead a GPS altitude read out, an 

exemption may be needed. An equivalent level of safety will be achieved by the operator, pursuant to the 

Manual and Safety Check list, confirming the altitude of the launch site shown on the GPS altitude indicator 

before flight. 

14 C.F.R. § 91.151(a): Fuel Requirements tor 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." 

Depending on the sUAS, the battery provides approximately 15-60 minutes of powered flight. To meet the 30-

minute reserve requirement in 14 CFR §91.151, sUAS flights would be extremely limited. 

Given the limitations on the UAS's proposed flight area and the location of its proposed operations within a 

predetermined area, a longer time frame for flight in daylight or night VFR conditions is reasonable. 

Applicant believes that an exemption from 14 CFR §91.15l(a) falls within the scope of prior exemptions. 

See Exemption 106 7 3 (allowing Lockheed Martin Corporation to operate without compliance with FAR 

91.151 (a)). Operating the small UAS, in a tightly controlled area where only people and property owners or 

official representatives who have signed waivers will be allowed, with less than 30 minutes of reserve fuel, does 

not engender the type of risks that Section 91.15l(a) was intended to alleviate given the size and speed of the 

small UAS. Additionally, limiting sUAS flights to extremely short flights would greatly reduce the utility for 

which the exemption will be granted. 

Applicant believes that an equivalent level of safety can be achieved by limiting flights to 25% of battery 

power. This restriction would be more than adequate to return the sUAS to its planned landing zone from 

anywhere in its limited operating area. Similar exemptions have been granted to other operations, including 

Exemptions 2689F, 5745, 10673, and 10808. 

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 no more than 55 lbs 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 sUAS. An 

equivalent level of safety will be achieved by keeping these documents at the ground control point where the 

pilot flying the sUAS will have immediate access to them, to the extent they are applicable to the sUAS. The 

FAA has issued numerous exemptions to this regulation. A representative sample of other exceptions includes 

Exemption Nos. 9565, 9665, 9789, 9789A, 9797, 9797A, 9816A, and 10700. 

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 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 ... ," and others shall inspect or 

maintain the aircraft in compliance with Part 43. 
Given that these section and Part 43 apply only to aircraft with an airworthiness certificate, these sections will 

not apply to the applicant. The operator pursuant to the flight manual and operating handbook will 

accomplish maintenance. An equivalent level of safety will be achieved because these small UASs are very 

limited in size and will carry a small payload and operate only in restricted areas for limited periods of time. 

If mechanical issues arise the UAS can land immediately and will be operating from no higher than 400 feet 

AGL. As provided in the Manual, 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. 

Pursuant to 14 C.F.R. Part 11, the following summary is provided for publication in the Federal Register, 

should it be determined that publication is needed: 

Applicant seeks an exemption from the following rules: 

14 C.F.R. §21, subpart H; 14 C.F.R 45.23(b); 14 C.F.R. §§ 61.113(a) & (b); 91.7 (a); 91.9 (b) (2); 91.103(b); 

91.109; 91.119; 91.121; 91.151(a); 91.203(a) and (b); 91.405 (a); 91.407 (a) (1); 91.409 (a) (2); 91.409 (a) 

(2) and 91.417 (a) & (b) to operate commercially a small unmanned vehicle (55lbs or less). 

Approval of exemptions allowing commercial operations of sUASs, will enhance safety by reducing risk. 

Conventional aircraft operating at low altitudes near subjects being filmed and in close proximity to structures 

present major risks associated with the size of the vehicle carrying jet A or other fuels. Such aircraft must fly to 

and from the operational location. In contrast, a sUAS weighing fewer than 55 lbs. and powered by batteries 

eliminates virtually all of that risk given the reduced mass and lack of combustible fuel carried on board. The 

sUAS is carried to the operation site and not flown. The sUAS will carry no passengers or crew and, therefore, 

will not expose them to the risks associated with manned aircraft flights. 

The operation of small UASs, weighting less than 55 lbs., conducted in the strict conditions outlined above, 

will provide an equivalent level of safety supporting the grant of the exemptions requested herein, including 

exempting the applicant from the requirements of Part 21 and allowing commercial operations. 

These lightweight aircraft operate at slow speeds, close to the ground, and in a sterile environment and, as a 

result, are far safer than conventional operations conducted with turbine helicopters or fixed wing aircraft. 
Conclusion 

Satisfaction of the criteria provided in Section 333 of the Reform Act of 2012-size, weight, speed, operating 

capabilities, proximity to airports and populated areas and operation within visual line of sight and national 

security - provide more than adequate justification for the grant of the requested exemptions allowing 

commercial operation of Drone's Eye View Consulting's UAS. 

Drone's Eye View Consulting requests that the exemption allow Drone's Eye View Consulting to operate 

without a COA in Class G airspace, at 400 feet AGL or below, and at least five nautical miles from the 

geographic center of an airport unless a letter of agreement with the airport's management is obtained. The 

FAA does not require a COA for non-commercial operations in Class G airspace that perform the same 

flights, so removing this requirement will still allow Drone's Eye View Consulting to operate within a level of 

safety that is equal to the level of safety provided by existing rules. Furthermore, this requirement creates an 

unnecessary burden that is detrimental to Drone's Eye View Consulting's' operations since most operations 

will take place in Class G airspace, at 400 feet AGL or below, and at least five nautical miles from the 

geographic center of an airport. For those reason, Drone's Eye View Consulting would like the exemption to 

only require a COA when not operating in Class G airspace 

Drone's Eye View Consulting, LLC is committed to safe operation and due to the foregoing reasons should be 

permitted to conduct small UAS operations in accordance with its manuals and all other operating parameters 

deemed necessary and appropriate by the FAA. 

If you have any questions, please contact me at your earliest convenience. 

Sincerely, 

~:?:::s .. ~~'~' ........ _ 

Lott S Gilbert Bolden II 

Drone's Eye View Consulting, LLC