Reid	Plumbo July 31st,	2015

Director	of	Product Management

Sentera, LLC

6636	Cedar	Ave	South

Minneapolis,	MN	55423

U.S.	Department	of	Transportation	

Docket	Management	System	

1200	New	Jersey	Ave.,	SE	

Washington,	DC	20590	

Dear	Sir	or	Madam:	

Attached,	please	find	Sentera, LLC’s request	for	an	exemption	from	certain	stated	Federal	

Aviation	Regulations	to	allow	commercial	operation	of	its	small	unmanned	aircraft	systems	

(hereafter	referred	to	as	“SUAS”	or	“Drone”)	for	the	purposes	of	aerial	photography,	

cinematography,	videography,	mapping,	crop	surveying,	aerial	inspections,	data	collection,	

security	monitoring,	public	safety,	first	responder	and	emergency	response	support and	

other	flight	operations,	so	long	as	such	operations	are	conducted	within	and	under	the	

conditions	outlined	herein	or	as	may	be	established	by	the	FAA	as	required	by	Section	333

of	the	FAA	Modernization	and	Reform	Act	of	2012.

Please	be	advised	that	the	FAA	has	previously	issued	grants	of	exemption	in	circumstances	

similar	in	all	material	aspects	to	those	requested	in	this	petition,	notably in	Exemption	Nos.	

11487 to	HAZON	Solutions, 11552	to	Sinclair	Community	College,	and	11110	to	Trimble	

Navigation	Ltd.	for	fixed	wing	SUAS	similar	to	the	fixed	wing	SUAS	proposed	herein, in	

Exemption	No.	11446	to	Trumbull	Unmanned	LLC	which	includes	the	specific	VTOL	SUAS	

proposed	herein,	Exemption	No.	11925	to	James	Michael	Hourihan	for	VTOL	SUAS-based	

emergency	response	support	operations. Therefore,	Sentera,	LLC	respectfully	requests	this	

exemption	be	considered	under	the	“summary	grant”	process.

As	detailed	in	this	document,	a	granted	exemption	would	permit	the commercial operation	

of	SUAS	under	controlled	conditions in	airspace	that	is	limited and	controlled	via	

subsequent	COA	applications.	Predominantly,	Sentera,	LLC	seeks	to	operate	under	the	

“Blanket	200ft	COA”	guidance	that	was	issued	by	the	FAA	in	March	2015	and	respectfully	

requests	the	“Blanket 200ft COA”	be	granted	in	concert	with	these	exemptions.

The	requested	exemptions	and	proposed limitations	provide	for	at	least	an	equivalent	or	

higher	level	of	safety	to	operations	under	the	current	regulatory	structure,	specifically	

safety	enhancements	to	personnel	climbing	vertical	infrastructure	and create	a	low-risk	

alternative	to	certain manned	aviation	operations.

As	outlined	in	this	request	for	exemption,	the	SUAS	Sentera, LLC proposes	to	use	are:

Sentera	Phoenix	

Lockheed	Martin	Procerus	Technologies (LMPT) Indago
2

If	I	can	provide	any	additional	information	in	support	of	your	review	of	this	petition,	please	

do	not	hesitate	to	call	me	at	952-242-9241 or	send	an	email	to	reid.plumbo@sentera.com.

Sincerely,

/s/

Reid	Plumbo

Director	of	Program	Management

Sentera,	LLC
3

Section	1:	Introduction	&	Interest	of	Sentera,	LLC

Sentera,	LLC	is	a	developer	of	precision	sensing	solutions	for	the	industrial,	commercial,	

agricultural	and	first	responder	markets. The	staff	and	leadership	at	Sentera,	LLC	offer	over	

100	years	of	experience	in	the	SUAS	industry	and	have	flown	several-thousand	flight	hours	

on	various	UAS	systems.	This	team	has	deep	experience	in	SUAS	airspace	integration,	

airworthiness	and	flight	operations,	including	the	successful	award	of	an	SUAS	

airworthiness	certificate	issued	by	the	British	Military.	Sentera,	LLC	also	has	on	staff	a	

professional airman	holding	CFI,	CFII	and	MEI	certificates	with	nearly	3,000hrs	of	flight	

experience,	including	over	900	hours	of	multi-engine	flight	instruction.	Sentera,	LLC’s	has

the	background	and	team	to	safely	integrate	within	the	NAS	and	provide	low-risk,	costeffective	airborne	data	and	photography	to	its	customers.

Sentera,	LLC	proposes	to	commercially	operate	its	Sentera	Phoenix	and	Lockheed	Martin	

Procerus	Technologies	(LMPT) Indago SUAS	platforms	for	the	purposes	of	aerial	

inspections,	crop	and	agricultural	surveys,	aerial	photography,	videography,	data	collection,	

security	monitoring,	public	safety,	first	responder	and	emergency	response	support and	

other	flight	operations	conforming	to	the proposed limitations	and	restrictions.	Sentera,	

LLC	holds	that	commercially	operating	an	SUAS	within	the	NAS	under	these same	

limitations	and	restrictions	will	not	pose	a	hazard	to	manned	aircraft,	and	that	operation	of	

its	SUAS	is	in	the	public	best	interest	by	providing	an	inexpensive,	low-risk	alternative	to	

manned	survey	operations.

Section	2:	Regarding	the	Unmanned	Aircraft	System

The	FAA’s	public	guidance	on	filing	an	exemption	under	Section	333	is	reprinted	below.	

This	section	intends	to	fulfill	each	requirement	of	this	guidance.

1.	Petitioners	should	describe	how	the	proposed	UAS	operation	will	be	safely	conducted	to	

minimize	risk	to	the	NAS	or	to	persons	and	property	on	the	ground.	Specifically,	petitioners	

should	describe	the	design	and	operational	characteristics	for	the	type(s)	of	UAS	they	intend	to	

operate,	e.g.	aircraft	performance	and	performance	limitations,	operating	procedures,	and	

aircraft	loading	information	in	as	much	detail	as	possible.	This	could	be	provided	in	the	

petition	or	in	an	Aircraft	Flight	Manual	or	similar	document.

NOTE:	The	FAA	will	consider	all	information	and	data	submitted	by	the	petitioner	that	

describes	the	UAS	developmental	and	operational	history.	This	could	include	statistical	data	or	

other	documentation	for	the	specific	design	and	performance	characteristics	of	the	UAS,	

including	the	operational	history	and	operational	failure	modes,	obtained	through	previous	

Research	&	Development	(R&D)	and/or	flight	test	activities,	e.g.	operations	conducted under	a	

COA,	with	a	civil	airworthiness	certificate,	or	under	other	authorized	operating	conditions.

2.	Petitioners	should	describe	any	procedures	they	would	implement,	such	as	pre-flight	

inspections,	maintenance,	and	repair,	to	ensure	that	the	UAS	is	in a	condition	for	safe	flight.	

This	could	be	provided	in	the	petition,	an	Aircraft	Flight	Manual,	a	Maintenance	and	

Inspection	Manual,	or	similar	document.

NOTE:	The	Aircraft	Flight	Manual	and	Maintenance	and	Inspection	Manual	may

be separate	documents	or	combined	in	a	single	document.

3.	The	petitioner	should	describe	the	Radio	Frequency	(RF)	spectrum	used	for	control	of	the	

UAS	and	associated	equipment	that	is	part	of	the	UAS	(i.e.,	sensors,	cameras,	etc.),	and	whether	
4

it	complies	with	Federal	Communications	Commission	(FCC)	or	other	appropriate	government	

oversight	agency	requirements.

NOTE:	Petitioners	should	be	able	to	provide	the	FCC	approval	letter	or	show	compliance	with	

FCC	requirements	upon	request.

Sentera,	LLC	intends	to commercially	operate	SUAS	weighing	less	than	10lbs,	during	

daylight	hours,	within	visual	line	of	sight	of	the	PIC,	at	altitudes	less	than	400ft	AGL and	at	

speeds	less	than	52mph (depending	on	system,	see	Section	2.1	below).	As	described	later,	

Sentera	PICs	shall	be	fully	qualified	airmen,	holding	at	least	a	sport	pilot	certificate	and	

associated	medical	clearance. The	proposed	SUAS	are	equipped	with	GPS-enabled	

autopilots,	capable	of	safe,	steady	autonomous	flight	and	guided	by	the	PIC.	The	proposed	

SUAS	are	commercially	available,	“off	the	shelf”	products	that	have	accumulated	

innumerable	flight	hours	and	they	have	proven	themselves	low-risk,	safe	aircraft.	Given	the	

small	size	and	weight,	low	altitudes,	slow	speeds,	a	qualified	PIC,	a	GPS-equipped	autopilot,	

data-link	and	countless	flight	hours,	Sentera,	LLC	holds	that	commercially	operating	these	

SUAS	under	the	limitations	and	restrictions	set	forth	is	a	safe	alternative	to	the	current	

regulatory	structure	and	minimizes risk	to	the	NAS	or	to	persons	and	property	on	the	

ground.

2.1	Proposed	SUAS

Sentera,	LLC	intends	to	operate	the	Sentera	Phoenix	family	of	SUAS	along	with	the	

Lockheed	Martin	Procerus	Technologies	(LMPT)	Indago	family	of	SUAS.		Both	of	

these	types	of	systems	have	been	proven	to	be	reliable	and	effective	SUAS	with	the	

ability	to	carry	payloads such	as	cameras,	sensors	and	other	equipment	necessary	to	

complete	Sentera’s aerial	photography,	cinematography,	videography,	mapping,

crop	surveying, inspection	security	monitoring,	public	safety,	first responder	and	

emergency	response	support tasks.	 Each	SUAS	is	described	below.

Sentera	Phoenix

The	Sentera	Phoenix	system	is	comprised	of	a	fixed	wing,	hand-launched,	

propeller	driven	unmanned	aircraft	and	a	laptop	or	tablet	based	ground	

control,	responsible	for	both	vehicle	operation	and	camera	functions,	along	

with	a	communications	data-link	providing	bi-directional	communications	

between	the	air	vehicle	and	the	ground	control	station.		The	Phoenix	SUAS	

has	the	ability	to	conduct	hand-launched	takeoffs, precision	landings	in	

varied	terrain	and	execute	standard	horizontal	flight	maneuvers.		The	

maximum	gross	weight	of	the	Phoenix	is	3.5	lb	(1588g),	and	it	measures	8in	

(203mm)	tall,	22-26in	(559-660mm)	long	(depending	on	the	model)	and	has	

either	a	38in	(965mm)	or	48in	(1219mm)	wingspan	(again,	depending	on	

the	model).		Its	standard	cruise	speed	is	29-35 mph (25-30	ktas,	13-15m/s),	

maximum	horizontal	speed	is	52	mph (45	ktas,	23	m/s) and	maximum	

ascent	and	descent	speeds are 800	ft/min	(4.1m/s)	is	400	ft/min	(2.0m/s)

respectively.		The	Phoenix is	powered	with	a	Lithium	Ion	battery	and	flies	

for	approximately	60	minutes.	Detailed	specifications	are	available	in	the	

Sentera	Phoenix	UAS	Pilot	Operational	Handbook	attached	as	Appendix	1.		

The	Sentera	Phoenix	system	has	been	proven	to	be	a	reliable	and	effective	

system	for	operations	such	as	those	proposed	herein	and	has	previously	

been	approved	for	similar	uses	by	FAA.		The	Sentera	Phoenix	is	an	evolution	

of	the	Vireo	UAS,	originally	produced	by	UTC	Aerospace	Systems	by	the	team	

that	now	forms	the	core	engineering	team	of	Sentera.		The	Sentera	Phoenix’s		
5

immediate	predecessor,	the	Vireo	is	currently	operating	in	numerous	FAAapproved	Public	COAs	as	identified	below:	

• 2013-ESA-46	COA	Hyde		(Proponent:	NC	State	University)

• 2013-ESA-65	COA	Butner	(Proponent:	NC	State	University)

• 2013-ESA-69	COA	Caratoke	(Proponent:	NC	State	University)

• 2014-ESA-93	COA	Vernon	James	(Proponent:	NC	State	University)

• 2014-ESA-114	COA	Lake	Wheeler	(Proponent:	NC	State	University)

• 2015-CSA-24-COA	Springfield	Airpark (Proponent:	Sinclair	Community	

College)

• 2013-CSA-56	Wilmington	Airpark	(Proponent:	Sinclair	Community	

College)

Lockheed	Martin	Procerus	Technologies	(LMPT)	Indago

The	Indago	system	is	comprised	of	a	four-rotor	Vertical	Takeoff	and	Landing	

(VTOL)	unmanned	aircraft	and	ground	control	station	– either	a	handheld	

controller	or	a	laptop/tablet	based	control	station	– which	is	responsible	for	

both	vehicle	operation	and	camera	functions,	along	with	a	communications	

data-link	providing	bi-directional	communications	between	the	air	vehicle	

and	the	ground	control	station.			The	Indago	SUAS	has	the	ability	to	conduct	

vertical	takeoffs	and	landings,	hover	and	execute	standard	horizontal	flight	

maneuvers.		The	maximum	gross	weight	of	the	Indago is	4.85	lb	(2200g),	

and	it	measures	32	x	32	x	9 in	(813 x	813 x	229mm).	The	Indago’s	maximum	

horizontal speed	is	30mph	(13.4 m/s),	maximum	ascent	speed	is	800	ft/min	

(4.1 m/s),	and	maximum	descent	speed	is	400	ft/min	(2.0 m/s).		The	Indago

is	powered	by	a	Lithium	Ion	battery and	flies	for	approximately	45 minutes.	

More	detailed	specifications	are	available	in the	Indago	User	Guide	attached	

as	Appendix 3.

The	Indago	system	has	been	proven	to	be	a	reliable	and	effective	system	for	

operations	such	as	those	proposed	herein	and	has	previously	been	approved	

for	similar	uses	by	FAA	in	the	form	of	numerous	Section	333	Exemptions,	

such	as	those	outlined	on	page	1	of	the	cover	letter	above.

2.2	 Maintenance &	Inspection

Sentera,	LLC	shall	follow	the	manufacturer’s	maintenance,	overhaul,	

inspection	and	record-keeping guidelines	as	specified	in	the	relevant	

manufacturer	user	manuals,	attached	as	Appendices	1	and	3. Sentera,	LLC	

will	conduct	inspections	and	maintenance,	which	shall	be	noted	in	the	

aircraft’s	logbook	including	total	flight	hours	and	the	nature	of	maintenance	

performed. Comprehensive	maintenance	will	be	performed	in	conformance	

with	the	manufacturer’s	guidelines.

In	advance	of	every	flight	operation,	the	Pilot	In	Command	(PIC)	will	

thoroughly	inspect	the	SUAS	to	ensure	it	is	safe	to	fly	as	described	in	the	

relevant	manufacturer	user	manuals	and	checklists,	attached	as	Appendices

2 (Sentera	Phoenix)	and 4 (LMPT	Indago).	Furthermore,	the	PIC	will	conduct	

a	pre-flight	checklist	as	described	in	the	Operations	Manual.	With	both	

inspections	completed	and	passed,	the	SUAS	shall	be	deemed	safe	to	fly.
6

All	SUAS	proposed	under	this	request	for	exemption	will	be	in	compliance	

with	all	manufacturer	maintenance,	system	and	safety	bulletins.

2.3 Radio	Communications

All	radio	systems	used	in	the	proposed SUAS	comply	with	FCC	regulations	

and	have	earned	FCC	approval.	Sentera,	LLC	shall	operate	the	SUAS	in	

compliance	with	those	approvals.	Certificates	of	compliance	may	be	found	in	

Operations	manuals	in	Appendices	1	and	3.

Section	3:	Regarding	the	Unmanned	Aircraft	PIC

The	FAA’s	public	guidance	on	filing	an	exemption	under	Section	333	is	reprinted	below.	

This	section	intends	to	fulfill	each	requirement	of	this	guidance.

Regarding	the	Unmanned	Aircraft	PIC

4.	Petitioners	should	describe	the	qualifications	required of	any	PIC(s)	who	will	be	directly	

responsible	for	the	operation	of	the	UAS,	including	information	such	as:	the	level	of	airman	

certificate	held;	any	applicable	training	related	to	the	operation;	and	any	minimum	hours	of	

flight	experience	required	by	the	PIC(s),	both	total	flight	time	and	the	time	with	the	particular	

UAS.	If	the	operation	would	use	visual	observers,	petitioners	should	describe	their	roles	and	

qualifications.

5.	Petitioners	should	describe	the	medical	standards	and	certification	of	the	PIC(s)	directly	

responsible	for	the	operation	of	the	UAS.

Sentera,	LLC	PICs shall	possess	a	current	airline	transport,	commercial,	private,	recreational	

or	sport	pilot	certificate.	The	PIC	shall	also	hold	a	current	FAA	airman	medical	certificate	or	

a	valid	U.S.	Driver’s	License.	The	PIC	shall also	meet	the	flight	review	requirements	specified	

in 14	CFR	§	61.56	in	an	aircraft	in	which	the	PIC	is	rated	on	his	or	her	pilot	certificate.

Prior	to	commercial	operations,	Sentera,	LLC	PICs	shall	have	accumulated	and logged	a	

minimum	of	25	hours	total	time	as	an	SUAS	pilot.	Flights	for	the	purposes	of	training	

Sentera,	LLC’s	PICs	and	VOs	(training,	proficiency,	and	experience-building)	and	

determining	the	PIC’s	ability	to	safely	operate	the	UAS	in	a	manner	consistent	with	how	the	

UAS	will	be	operated	under	this	exemption, are	requested	under	the	terms	of	this	

exemption.	Training	operations	shall	only	be	conducted	during	dedicated	training	sessions.	

During	training,	proficiency,	and	experience-building	flights,	all	persons	not	essential	for	

flight	operations	shall	be	considered	nonparticipants,	and	the	PIC	shall	operate	the	UA	with	

appropriate	distance	from	nonparticipants	in	accordance	with	14	CFR	§	91.119.

Section	4:	Regarding	the	Operation	of	the	Unmanned	Aircraft

The FAA’s	public	guidance	on	filing	an	exemption	under	Section	333	is	reprinted	below,	

along	with	Sentera,	LLC’s	proposal.	This	section	intends	to	fulfill	each	requirement	of	this	

guidance.

Regarding	the	Operation	of	the	Unmanned	Aircraft

6. Petitioners	should	fully	describe	their	intended	UAS	operation(s).	Petitioners	should	

describe	how	the	proposed	operation(s)	would	not	adversely	affect	safety,	or	how	they	

would	provide	a	level	of	safety	at	least	equivalent	to	that	provided	by	the	rule	from	

which	exemption	is	sought.	Petitioners	should	address	any	plans	to	implement	clearly	
7

defined	operational	borders	and	procedures	to	ensure	public	safety,	which	includes	

persons	and	property	both	in	the	air	and	on	the	ground.	This	can	be	described	in	the	

petition,	in	an	Operations	Manual,	or	similar	document.		NOTE:	The	FAA	will	closely	

examine	the	proposed	operation(s)	with	respect	to	safety	of	flight,	NAS	safety	

considerations,	and	the	safety	of	the	non-participating	persons	and	property	during	

the	operational	period	and	within	the	operational	area.		

7. Petitioners	should	specify	the	proposed	maximum	operating	speed	and	altitude,	and	

describe	minimum	flight	visibility	and	distance	from	clouds	for	their	intended	

operation(s).	Petitioners	should	describe	potential	hazards	and	safety	mitigations	

associated	with	these	proposed	conditions.	These	issues	can	be	addressed	in	the	

petition,	an	Operations	Manual,	or	similar	document.		

The	SUAS	will	be	operated	during	daylight hours,	in	compliance	with	visual	flight	rules,	and	

flown	within	direct	visual	line	of	sight	of	the	PIC	at	all	times and	never	over	congested	or	

densely	populated	areas	unless	specifically	authorized	by	the	Air	Traffic	Organizationissued	COA.	The	PIC	shall	use	human	vision	unaided	by	any	device	other	than	corrective	

lenses,	as	specified	on	the	PIC’s	FAA-issued	airman	medical	certificate	or	U.S.	driver’s	

license.

The	SUAS	shall	be	operated	at	an	altitude	of	no	more	than	400ft	AGL,	unless	specifically	

authorized	and	operating	under	the	terms	of	the	COA,	at	speeds	less	than	23m/s	(52mph).	

The	SUAS	will	not	be	operated	less	than	500ft	below	or	less	than	2000ft	horizontally	from	a	

cloud,	or	when	visibility	is	less	than	3	statute	miles.

Prior	to	beginning	a	flight,	the	PIC	shall	clearly	establish	the	limits	in	latitude,	longitude	and	

altitude	AGL	to	ensure	compliance	with	the	COA	under	which	the	SUAS	is	flown	and	

establish	the	“sterile	area”	for	operations.	If	at	any	time,	this	area	is	breached	by	

unpredicted	obstacles	(manned	aircraft	or	otherwise),	the	PIC	shall	abort	the	flight.	Manned	

aircraft	shall	have	right	of	way	at	all	times.

In	case	of	a	reduced	or	diminished	control link,	the	SUAS	will	automatically	return	to	a	

predetermined	point	within	the	private	or	controlled-access	property.

The	PIC	shall	not	begin	a	flight	unless	there	is	sufficient	available	power	for	the	SUAS	to	

complete	the	intended	mission	and	to	operate	for	at	least	five	minutes	after	that.

By	operating	within	the	limitations	and	guidelines	set	forth	herein,	Sentera,	LLC	shall	

provide	an	equivalent	level	of	safety	to	operations	under	the	existing	regulatory	structure.

8. Petitioners	should	describe	the	characteristics	of	the	area	of	intended	operation(s)	and	

the	associated	potential	hazards,	in	accordance	with	the	statutory	mandate	under	

Section	333		regarding	proximity	to	populated	areas.	These	issues	can	be	addressed	in	

the	petition,	an	Operations	Manual,	or	similar	document.	

9. Petitioners	should	describe	if	they	intend	to	operate	in	the	proximity	of	any	airports,	in	

accordance	with	the	statutory	mandate	under	Section	333	regarding	proximity	to	

airports.		

All	flight	operations	will	be	conducted	at	least	500ft	from	all	nonparticipating	persons,	

vessels,	vehicles	and	structures	on	private	or	controlled	access	property	with	permission	

from	the	property	owner/controller	or	authorized	representative.	In	some	cases	due	to	

mission	requirements,	the	SUAS	will	be	operated	closer	than	500ft	to	commercial	and	

industrial	infrastructure	and	facilities.	In	these	instances,	Sentera,	LLC	shall	have	the	
8

authorization	of	the	property	owner/controller	or	from	an	authorized	representative,	and	

the	PIC	shall	have	conducted	a	safety	assessment	and	determined	that	it	does	not	present	an	

undue	hazard.	Permission	from	the	property	owner/controller	or	authorized	

representative	will	be	obtained	for	each	flight	to	be	conducted.	

In	accordance	with	the	“Blanket	200ft	COA”	guidance	that was	issued	by	the	FAA	in	March	

2015,	flight	operations	will	not	take	place	within

• 5	nm from	an	airport	having	an	operational	control	tower;	or

• 3	nm from	an	airport	with	a	published	instrument	flight	procedure,	but	not	an	

operational	tower;	or

• 2	nm from	an airport	without	a	published	instrument	flight	procedure	or	an	

operational	tower;	or

• 2 nm from	a	heliport	with	a	published	instrument	flight	procedure

unless	a	letter	of	agreement	with	that	airport’s	management	is	obtained and/or	otherwise	

permitted	by	an	Air	Traffic	Organization-issued	COA.

Foreseen	hazards	include encroachment	of	manned	aviation	operations	and	nonparticipants	on	the	ground.	Both	of	these	hazards	are	mitigated	by	choice	of	location	(noncongested	areas) and	strict	limits	on	range	(visual	line	of	sight)	and	altitude	established	

herein. Operation	under	these	limits	effectively	mitigates	these	risks.

10. The	UAS	must	be	operated	within	visual	line-of-sight	(VLOS),	in	accordance	with	the	

	statutory	mandate	under	Section	333(b)(1).	Petitioners	should	describe	how	they	

intend	to		comply	with	his	mandate.		

11. Petitioners	should	describe	any	procedures	they	would	implement	for	conducting	a	

preflight	safety	risk	assessment	to	determine	that	the	UAS	is	in	a	condition	for	safe	

flight	(14	CFR	§	91.7(b))	and	that	the	planned	operation	can	be	completed	safely.	

These	procedures	can	be	addressed	in	the	petition,	an	Aircraft	Flight	Manual,	

Operations	Manual,	or	similar	document.		

As	described	above,	The	SUAS	will	be	operated during	daylight hours,	in	compliance	with	

visual	flight	rules,	and	flown	within	direct	visual	line	of	sight	of	the	PIC	at	all	times.	The	PIC	

shall	use	human	vision	unaided	by	any	device	other	than	corrective	lenses,	as	specified	on	

the	PIC’s	FAA-issued	airman	medical	certificate	or	U.S.	driver’s	license.

In	advance	of	every	flight	operation,	the	Pilot	In	Command	(PIC)	will	thoroughly	inspect	the	

SUAS	to	ensure	it	is	safe	to	fly	as	described	in	Appendices 1-4.	Furthermore,	the	PIC	will	

conduct	a	pre-flight	checklist	as	described	in	Appendix	2 (Sentera	Phoenix) and	4 (LMPT	

Indago),	and	ensure	the	planned	operation	can	be	completed	safely	with	sufficient	battery

reserves (including	wind	and	terrain	limitations). With	both	inspections	completed	and	

passed,	the	SUAS	shall	be	deemed	safe	to	fly.

12. If	petitioners	intend	to	conduct	operations	which	have	existing	requirements	to	notify	

Flight	Standards	District	Offices	(FSDOs)	prior	to	operations	– such	as	motion	picture	

and	television	filming,	or	pipeline	and	powerline	patrol	– petitioners	should	describe	

their	intended	coordination	in	this	regard	for	their	proposed	operation(s).		

Sentera,	LLC’s	aerial	infrastructure	inspections,	cinematography/videography,	agricultural	

operations,	security	monitoring,	public	safety,	first	responder	and	emergency	response	

support	operations do	not	require	notification	to	FSDOs.
9

13. The	FAA	intends	to	require	entities	who obtain	an	exemption	under	this	process	to	also	

obtain	a	Certificate	of	Waiver	or	Authorization	(COA)	from	the	FAA	Air	Traffic	

Organization	prior	to	conducting	operation(s)	in	the	NAS.	The	COA	application	is	

available	here.

As	stated	previously,	Sentera,	LLC	shall	obtain	an	Air	Traffic	Organization-issued	COA	prior	

to	conducting	any	operations	under	this	requested	grant	of	exemption.	Sentera,	LLC	seeks	

primarily	to	operate	under	the	“Blanket	200ft	COA”	guidance	offered	by	the	FAA	in	March,	

2015	and	respectfully	requests	that	COA	be	issued	concurrently	with	these	exemptions.	For	

operations	not	conforming	to	the	“Blanket	200ft	COA”	guidance,	Sentera,	LLC	will	seek	

separate	and	additional	COAs	to	operate	its	SUAS.

Section	5:	Requested	Exemptions

14	C.F.R	Part Summary	of	Regulation Proposed	Action

21,	Subpart	H Airworthiness	

Certification

In	consideration	of	the	size,	weight,	

speed,	and	limited	operating	area	

associated	with	the	aircraft	and	its	

operation,	the	FAA has	previously	held	

that	this	aircraft	meets	the	conditions	of	

Section	333,	therefore, requested	relief	

from	14	CFR	part	21,	and	any	associated	

noise	certification	and	testing	

requirements	of	part	36,	is	not	

necessary.

45.23(b) Display	of	Marks Sentera,	LLC SUAS	shall	be	identified	by	

serial	number	and	N-number,	in	

markings	as	large	as	practical	given	the	

small	size	of	the	aircraft.	However,	the	2	

inch	minimum	set	forth	in	this	rule	is	

impractical,	therefore	relief	is	requested.

61.23(a)

61.101(e)(4&5)

61 113(a)	&	(b)

61.133(b)

61.315(a)

Certification:	Pilots,	Light	

Instructors	and	Ground	

Instructors

In	previous	petitions	for	exemption,	the	

FAA	has	held	that a	PIC	of	an	SUAS

holding	at	least	a	Sport	Pilot	certificate

and	a	U.S.	Driver’s	License,	or	greater	

medical	certification, would	not	

adversely	affect	safe	operations	within	

the	NAS or	present	a	hazard	to	people	or	

structures	on	the	ground.	Relief,	subject	

to	the	limitations	provided	in	this	

document,	is	requested.

91.7(a) Civil	Aircraft	

Airworthiness

PICs	operating	on	behalf	of	Sentera,	LLC	

shall	perform	preflight	inspections	and	

ensure	airworthiness	prior	to	flight	as	

described	in	this	document,	manuals

and	appropriate	appendices.	Relief	from	

this	requirement	is	not	necessary.

91.9(b)(2)	&	(c) Civil	aircraft	flight	

manual,	marking,	and	

placard	requirements

Sentera,	LLC	shall	provide	a	current	

SUAS	Flight	Manual,	and	operational	

instruction	material	at	the	location	of	

the	PIC	and/or	Ground	Station. The	FAA	

has	previously	determined	that,	given	
10

this,	relief	from	this	requirement	is	not

necessary.

91.103 Preflight	Action Sentera,	LLC	will	perform.	Relief	is	not	

necessary.

91.105 Flight	Crewmembers	at	

Stations

No	human	will	be	aboard	the	SUAS	

operated	by	Sentera,	LLC,	however,	the	

FAA	has	held	in	previous	petitions	that	

relief	is	not	necessary.

91.109(a) Flight	Instruction Sentera,	LLC	will	conduct	flight	training	

in	accordance	with	the	guidance	and	

limitations	offered	in	this	document,	as	

well	as	the	Operations	&	Flight	Manuals	

attached	as	appendices	to	this	

document.	The	FAA	has	held	in	previous	

petitions	that	relief	is	not	necessary.

91.119 Minimum	Safe	Altitudes Request	relief	within	limitations	and	

restrictions	proposed	herein,	specifically	

in	Section	4.

91.121 Altimeter	Settings Each	of	the	SUAS	Sentera,	LLC	proposes	

to	operate	measure	altitude	with	both	

barometric	pressure	sensors	and	GPS.	

Prior	to	each	flight,	the	barometric	

altimeter	will	be	set	to	0ft	AGL	instead	of	

the	setting	of	the	nearest	reporting	

station.	Sentera,	LLC	holds	that	by	

counting	altitude	in	AGL,	zeroed	at	the	

point	of	departure,	will	ensure	

conformance	to	the	COA	restrictions	

under	which	the	SUAS	is	operating.	

Given	the	low	operating	altitudes	of	

system	and	operating	within	the	

proposed	restrictions,	relief	is

requested.

91.151 Fuel	Requirements	in	VFR	

Conditions

As	described	in	this	document,	the	SUAS	

Sentera,	LLC	proposes	to	operate	have	

total	endurance	of	between	45 and	60

minutes.	Sentera,	LLC	will	ensure	

missions	are	conducted	with	sufficient	

reserve	to	operate	for	at	least	five	

minutes	after	the	intended	mission	is	

complete.	The	short	flight	time	makes	

the	reserves	specified	in	91.151	

impractical	and	therefore	relief	is	

requested.

91.203 Certifications	Required Sentera,	LLC	will	place	these	documents	

at the	location	of	the	ground	station	

and/or	with	the	PIC.	The	FAA	has	

previously	held	that	this	is	sufficient	to	

provide	an	equivalent	level	of	safety,	and	

therefore,	relief	is	requested.

91.405 Maintenance	Required Relief	is	requested	within	the	limitations	
11

and	conditions	set	forth	in	Section	2.2	of	

this	document.

91.407 Operation	After	

Maintenance

Relief	is	requested	within	the	limitations	

and	conditions	set	forth	in	Section	2.2	of	

this	document.

91.409 Inspections Relief	is	requested	within	the	limitations	

and	conditions	set	forth	in	Section	2.2	of	

this	document.

91.417 Maintenance	Records Relief	is	requested	within	the	limitations	

and	conditions	set	forth	in	Section	2.2	of	

this	document.

Section	6:	Public	Interest & Equivalent	Level	of	Safety

Though	this	is	addressed	in	pieces	of	this	petition,	a	more	complete	answer	is	provided	in	

this	section.

Sentera,	LLC	proposes	certain	14	CFR	exemptions	to	allow	commercial	operation	of	its	

small	unmanned	aircraft	systems	for	the	purposes	of	aerial	photography,	cinematography,	

videography,	mapping,	crop	surveying,	inspections,	data	collection,	security	monitoring,	

public	safety,	first	responder	and	emergency	response	support and	other	flight	operations,	

so	long	as	such	operations	are	conducted	within	and	under	the	conditions	outlined	herein.	

Traditional	agricultural	operations	such	as	crop	inspections	and	data	collections	under	the	

current	regulatory	structure	include	the	use	of	manned	aircraft,	which	are	expensive,	

inefficient	and	cannot	be	safely	operated	in	close	proximity	to	the	ground.	By	using	Drones	

to	complete	these	missions	the	public	interest	is	served	by	increasing	safety	to	pilots,	

passengers	and	non-participants	on	the	ground.	

Traditional	industrial	infrastructure	inspection	operations	under	the	current	regulatory	

structure	are	often	performed	1)	from	the	ground,	where	high	detail	is	impossible	2)	by	a	

climber	at	great	risk	to	his	or	her	personal	safety,	or	3)	by	a	manned	aircraft	where	flying	

close	to	elevated	infrastructure	is	extremely	dangerous,	and	not	permitted	by	14	CFR	

91.119.

Traditional	public	safety,	security	(such	as	facility	perimeter	monitoring),	first	responder,	

natural	resource	management	and	emergency	response/emergency	management	flight	

operations	under	the	current	regulatory	structure	include	the	use	of	manned	aircraft,	which	

are	expensive,	inefficient	and	can	pose	significant	risks	to	the	aircrew,	property	and	

structures	and	persons	on	the	ground	when	being	operated	in	close	proximity	to the	

ground.	By	using	Drones	to	complete	these	missions	the	public	interest	is	served	by	

increasing	safety	to	pilots,	passengers	and	non-participants	on	the	ground	while	increasing	

availability	and	responsiveness	due	to	the	lower	cost	of	equipment	and	operations.		

Grant	of	exemption,	with	the	conditions	and	limitations	set	forth	herein, to	Sentera,	LLC	will	

provide	for	at	least	an	equivalent	or	better	level	of	safety,	reduce	risk	to	life	and	property,	

thereby	serving	the	public	interest.
12

Section	7:	Summary	of	Exemption	Request	for	the	Federal	Register

In	accordance	with	14	CFR	11.81	and	Section	333	of	the	FAA	Modernization	and	Reform	Act	

of	2012,	P.L.	112-95,	Sentera,	LLC	seeks	exemption	from	the	requirements	of	14	C.F.R	

§§Part	21,	Subpart	H,	45.23(b),	61.23(a),	61.101(e)(4&5),	61	113(a)	&	(b),	61.133(b),	

61.315(a),	91.7(a),	91.9(b)(2)	&	(c	),	91.103,	91.105,	91.109(a),	91.119,	91.121,	91.151,	

91.203,	91.405,	91.407,	91.409 and	91.417 to	operate	small	unmanned	vehicles	weighing	

55lbs	or	less	for	commercial	purposes.

Approval	of	these	exemptions	will	allow	Sentera,	LLC	to	conduct	safe,	commercial	operation	

of	small	unmanned	aircraft	for	the	purposes	of	aerial	photography,	cinematography,	

videography,	mapping,	crop	surveying,	inspections,	data	collection,	security	monitoring,	

public	safety,	first	responder	and	emergency	response	support and	other	flight	operations.	

Section	8:	Compliance	with	14	CFR	11.81

14	CFR	11.81a	– Published	on	Cover	Page.

14	CFR	11.81b	– Please	see	Section	5.

14	CFR	11.81c	– Please	see	Sections	2,	3,	4	and	5.

14	CFR	11.81d	– Please	see	Section	6.

14	CFR	11.81e	– Please	see	Section	6.

14	CFR	11.81f – Please	see	Section	7.

14	CFR	11.81g	– Please	see	Appendices	1-4.

14	CFR	11.81h	– Not	applicable.

Appendix	1:	Sentera	Phoenix	UAS	Pilot	Operational	Handbook

Appendix	2:	Sentera	Phoenix	A1,	Phoenix	M1,	Vireo	Pre-flight	Checklist

Appendix	3:	Lockheed	Martin	Procerus	Technologies	Indago	User	Guide	v1.1

Lockheed	Martin	considers	these	documents	to	be	proprietary	information	and	prefers	to	

keep	this	confidential.	To	make	it	available	for	review,	it	has	been	sent	to	

333exemptions@faa.gov with	the	comment tracking	number	included	in	the	email.	Please	

contact	reid.plumbo@sentera.com with	questions	or	concerns.

Appendix	4:	Lockheed	Martin	Procerus	Technologies	Indago	Flight	Checklist

Lockheed	Martin	considers	these	documents	to	be	proprietary	information	and	prefers	to	

keep	this	confidential.	To	make	it	available	for	review,	it	has	been	sent	to	

333exemptions@faa.gov with	the	comment	tracking	number. Please	contact	

reid.plumbo@sentera.com with	questions	or	concerns.