UNITED STATES OF AMERICA

DEPARTMENT OF TRANSPORTATION

FEDERAL AVIATION ADMINISTRATION

WASHINGTON, DC

Regulatory Docket No. _______________

IN THE MATTER OF THE PETITION FOR EXEMPTION OF:

SAWYER INFRARED

FOR AN EXEMPTION SEEKING RELIEF FROM THE REQUIREMENTS OF

TITLE 14 OF THE CODE OF FEDERAL REGULATIONS

SECTIONS 61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), 

AND 91.417(a) & (b) CONCERNING COMMERCIAL OPERATION OF THE DJI SPREADING 

WINGS S900 UNMANNED AIRCRAFT SYSTEM

PURSUANT TO SECTION 333 OF

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

Submitted on July 13, 2015

Zachary T. Lesinski O/B/O

Sawyer Infrared

14 Newbury St, Peabody, MA 01960
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TABLE OF CONTENTS

Page

GLOSSARY OF ABBREVIATIONS................................................................................. 3

SUMMARY......................................................................................................................... 4

INTRODUCTION AND INTERESTS OF PETITIONER ................................................ 4

BACKGROUND ................................................................................................................ 4

BASIS FOR PETITION ...................................................................................................... 4

NAME AND ADDRESS OF PETITIONER...................................................................... 6

THE SPECIFIC SECTIONS OF 14 C.F.R. FROM WHICH SAWYER INFRARED

SEEKS EXEMPTION ....................................................................................................... 7

THE EXTENT OF RELIEF SAWYER INFRARED SEEKS AND THE REASON

SAWYER INFRARED SEEKS THE RELIEF................................................................... 10

THE REASONS WHY GRANTING SAWYER INFRARED'S REQUEST WOULD BE

IN THE PUBLIC INTEREST ............................................................................................ 13

THE REASONS WHY GRANTING THE EXEMPTION WOULD NOT

ADVERSELY AFFECT SAFETY..................................................................................... 15

SUMMARY THAT CAN BE PUBLISHED IN THE FEDERAL REGISTER................. 27

ANY ADDITIONAL INFORMATION, VIEWS, OR ARGUMENTS AVAILABLE

TO SUPPORT SAWYER INFRARED'S REQUEST ........................................................ 27

CONCLUSION................................................................................................................. 28
Sawyer	Infrared Page	3

GLOSSARY OF ABBREVIATIONS

AGL Above Ground Level

AOI Area of Interest

ATC Air Traffic Control

ATO Air Traffic Organization

C.F.R. Code of Federal Regulations

COA Certificate of Authorization

FAA Federal Aviation Administration

FAR Federal Aviation Regulation

FCC Federal Communications Commission

GCS Ground Control Station

GPS Global Positioning System

NAS National Airspace System

NOTAM Notice to Airmen

OEM Original Equipment Manufacturer

PIC Pilot In Command

RTH Return To Home

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

UA Unmanned Aircraft

UAS Unmanned Aircraft System

VFR Visual Flight Rules

VLOS Visual Line of Sight

VMC Visual Meteorological Conditions

VO Visual Observer

VTOL Vertical Takeoff and Landing
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SUMMARY

Sawyer Infrared seeks exemption from the requirements of 14 C.F.R §§ 61.113(a) & (b), 91.7(a), 

91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b), to operate an 

Unmanned Aircraft System pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 

(FMRA). This exemption will permit Sawyer Infrared to operate an Unmanned Aircraft System (UAS) for the 

commercial purpose of conducting infrared inspection services and optical gas imaging within the National 

Airspace System (NAS).

INTRODUCTION AND INTERESTS OF THE PETITIONER

Sawyer Infrared (hereinafter referred to as “Sawyer Infrared”) is an infrared inspection service and 

optical gas imaging consulting company, specializing in using state-of-the-art high-resolution infrared camera 

technology for various industries, including optical gas imaging, water and leak detection, critical 

infrastructure industry inspections, commercial building, and roof surveys. Sawyer Infrared is headquartered in 

Peabody, Massachusetts.

BACKGROUND

Unmanned Aircraft System: Spreading Wings S900 UAS

Sawyer Infrared seeks an exemption to operate the DJI Spreading Wings S900 UAS for compensation 

or hire within the NAS. The Spreading Wings S900 UAS is comprised of a vertical takeoff and landing 

(VTOL) Unmanned Aerial System (UAS) and a transportable Ground Control Station (GCS). The Spreading 

Wings S900 UAS has a maximum gross weight of approximately 7.3 pounds; measures approximately 18 

inches in length, 17 inches in width, and 14 inches in height; and has maximum speed of approximately 35 

miles per hour. The Spreading Wings S900 UAS is equipped with six (6) rotor wings, each being driven by a

Lithium Polymer battery-powered electric motor.

The Spreading Wings S900 UAS that will be operated by Sawyer Infrared will be registered in 

accordance with 49 U.S.C. 44103, Registration of Aircraft, as well as 14 C.F.R Part 47, Aircraft Registration, 

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

BASIS FOR PETITION

The Petitioner, Sawyer Infrared, by and through undersigned counsel, pursuant to the provisions of the 

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

Section 333, Special Rules for Certain Unmanned Aircraft Systems, hereby petitions the Administrator to 
Sawyer	Infrared Page	5

operate the Spreading Wings S900 UAS within the National Airspace System (NAS), and for an exemption 

from the requirements of 14 C.F.R §§ 61.113(a)&(b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 

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

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

aircraft and its operation, Sawyer Infrared’s operation of the Spreading Wings S900 UAS meets the conditions 

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

Part 21, Subpart H.

Accordingly, Sawyer Infrared requests relief from Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & 

(a)(2), and 91.417(a) & (b), as these sections set forth requirements for maintenance that only apply to aircraft 

with an airworthiness certificate.

Sawyer Infrared submits that the requested relief is proper since an equivalent level of safety will be 

ensured. All maintenance, alterations, or preventive maintenance of the Spreading Wings S900 UAS 

performed by Sawyer Infrared will be in accordance with the methods, techniques, and practices prescribed in 

the operating documents (i.e., the Spreading Wings S900 User Manual, the Spreading Wings S900 Release 

Notes and the A2 Flight Control System User Manual). Furthermore, only the Original Equipment 

Manufacturer (OEM) or qualified OEM maintainers will perform higher-level inspections and maintenance per 

the operating documents and OEM standards. Sawyer Infrared will document and maintain all maintenance 

records for the Spreading Wings S900 UAS.

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

limitations: Pilot in command, is requested by Sawyer Infrared to the extent necessary to allow the proposed 

UAS flight operations to be conducted by a Pilot in Command (PIC) holding a private pilot certificate, as well 

as an airman medical certificate, and who has demonstrated, by meeting minimum flight-hour and currency 

requirements, that the PIC is able to safely operate the Spreading Wings S900 UAS in a manner consistent 

with this exemption, including evasive and emergency maneuvers and maintaining appropriate distances from 

people, vessels, vehicles and structures.

Sawyer Infrared seeks relief from Section 91.7(a), entitled Civil aircraft airworthiness, because the 

Spreading Wings S900 UAS does not require an airworthiness certificate in accordance with 14 C.F.R. Part 21, 

Subpart H. As such, Sawyer Infrared submits that it will ensure that the Spreading Wings S900 UAS is in an 

airworthy condition, prior to every flight, by determining that the UAS is in compliance with the operating 

documents (i.e., the Spreading Wings S900 User Manual, the Spreading Wings S900 Release Notes and the A2 

Flight Control System User Manual), and that the aircraft is in a condition for safe flight.
Sawyer	Infrared Page	6

Sawyer Infrared also seeks an exemption from the requirements of Section 91.121, entitled Altimeter 

Settings, because the altitude reporting equipment of the Spreading Wings S900 UAS is set to zero feet above 

ground level (AGL), rather than local barometric pressure or field altitude, before each flight. The altitude 

information of the Spreading Wings S900 UAS is provided to the PIC via a barometric pressure sensor, Global 

Positioning System (GPS) equipment, and a radio communications telemetry data link, which downlinks from 

the UAS to the GCS for active monitoring of the flight path. A level of safety equivalent to Section 91.121 will 

be ensured as the altitude of the Spreading Wings S900 UAS will be reported to air traffic control (ATC) in 

feet AGL, and Sawyer Infrared will operate the Spreading Wings S900 UAS within visual line of sight, at or 

below 400 feet AGL.

Additionally, Sawyer Infrared seeks an exemption from the requirements of Section 91.151(b), 

entitled Fuel requirements for flight in VFR conditions. Sawyer Infrared submits that safety will not be 

affected by operation of the Spreading Wings S900 UAS during daylight hours in visual meteorological 

conditions (VMC) under visual flight rules (VFR). The Spreading Wings S900 contains enough battery power 

to fly for a total duration of 18 minutes, however, Sawyer Infrared will fly the UAS for no longer than 14.4 

minutes to the first point of intended landing, assuming normal cruising speed, and will reserve approximately 

3.6 minutes of flight time for safety precautions (i.e., 20 percent battery power remaining).

In accordance with 14 C.F.R. § 11.81, Sawyer Infrared provides the following information in support 

of its petition for exemption:

A. Name And Address Of The Petitioner.

The name and address of the Petitioner is:

Sawyer Infrared

14 Newbury Street

Peabody, MA 01960

The point of contact for this Petition and specific contact information is as follows:

Zachary T. Lesinski

Tel: (508) 280-4252

246 South Meadow Rd

Gate 6 Building S-2

Plymouth MA, 02644

Email: ztl@avwatch.us
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B. The Specific Sections Of 14 C.F.R. From Which Sawyer Infrared Seeks Exemption.

1. Sawyer Infrared Seeks Exemption From The Requirements Of Section 61.113(a) And (b).

Section 61.113, entitled Private pilot privileges and limitations: Pilot in command, subsections (a) and (b) 

prescribe the following, in relevant part:

(a) No person who holds a private pilot certificate may act as a pilot in command (PIC) of an aircraft that is 

carrying passengers or property for compensation or hire; nor may that person, for compensation or hire, act as 

PIC of an aircraft.

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

employment if—

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

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

2. Sawyer Infrared Seeks Exemption From The Requirements Of Section 91.7(a).

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

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

3. Sawyer Infrared Seeks Exemption From The Requirements Of Section 91.121.

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

(a) Each person operating an aircraft shall maintain the cruising altitude or flight level of that aircraft, as the 

case may be, by reference to an altimeter that is set, when operating--

(1) Below 18,000 feet MSL, to--

(i) The current reported altimeter setting of a station along the route and within 100 nautical miles of 

the aircraft;

(ii) If there is no station within the area prescribed in paragraph (a)(1)(i) of this section, the current 

reported altimeter setting of an appropriate available station; or
Sawyer	Infrared Page	8

(iii) In the case of an aircraft not equipped with a radio, the elevation of the departure airport or an 

appropriate altimeter setting available before departure;

4. Sawyer Infrared Seeks Exemption From The Requirements Of Section 91.151(b).

Section 91.151, entitled Fuel requirements for flight in VFR conditions, subsection (b), states the following:

(b) No person may begin a flight in a rotorcraft under VFR conditions unless (considering wind and forecast 

weather conditions) there is enough fuel to fly to the first point of intended landing and, assuming normal 

cruising speed, to fly after that for at least 20 minutes.

5. Sawyer Infrared Seeks Exemption From The Requirement Of Section 91.405(a).

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

Each owner or operator of an aircraft—

(a) Shall have that aircraft inspected as prescribed in subpart E of this part and shall between required 

inspections, except as provided in paragraph (c) of this section, have discrepancies repaired as prescribed in 

part 43 of this chapter [.]

6. Sawyer Infrared Seeks Exemption From The Requirements Of Section 91.407(a)(1).

Section 91.407, entitled Operation after maintenance, preventive maintenance, rebuilding, or alteration, 

subsection (a)(1), states the following:

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

alteration unless--

(1) It has been approved for return to service by a person authorized under § 43.7 of this chapter [.]

7. Sawyer Infrared Seeks Exemption From The Requirements Of Sections 91.409(a)(1) And 91.409(a)(2).

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

(a) Except as provided in paragraph (c) of this section, no person may operate an aircraft unless, within the 

preceding 12 calendar months, it has had --
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(1) An annual inspection in accordance with part 43 of this chapter and has been approved for return to 

service by a person authorized by § 43.7 of this chapter; or

(2)An inspection for the issuance of an airworthiness certificate in accordance with part 21 of this 

chapter.

8. Sawyer Infrared Seeks Exemption From The Requirements Of Sections 91.417(a) And 91.417(b).

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

(a) Except for work performed in accordance with §§ 91.411 and 91.413, each registered owner or operator 

shall keep the following records for the periods specified in paragraph (b) of this section:

(1) Records of the maintenance, preventive maintenance, and alteration and records of the 100-

hour, annual, progressive, and other required or approved inspections, as appropriate, for each aircraft 

(including the airframe) and each engine, propeller, rotor, and appliance of an aircraft. The records 

must include--

(i) A description (or reference to data acceptable to the Administrator) of the work performed; and

(ii) The date of completion of the work performed; and

(iii) The signature, and certificate number of the person approving the aircraft for return to service.

(2) Records containing the following information:

(i) The total time in service of the airframe, each engine, each propeller, and each rotor.

(ii) The current status of life-limited parts of each airframe, engine, propeller, rotor, and appliance.

(iii) The time since last overhaul of all items installed on the aircraft which are required to be 

overhauled on a specified time basis.

(iv) The current inspection status of the aircraft, including the time since the last inspection required by 

the inspection program under which the aircraft and its appliances are maintained.

(v) The current status of applicable airworthiness directives (AD) and safety directives including, for 

each, the method of compliance, the AD or safety directive number and revision date. If the AD or safety 

directive involves recurring action, the time and date when the next action is required.
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(vi) Copies of the forms prescribed by § 43.9(d) of this chapter for each major alteration to the airframe 

and currently installed engines, rotors, propellers, and appliances.

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

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

or superseded by other work or for 1 year after the work is performed.

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

aircraft at the time the aircraft is sold.

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

retained until the defects are repaired and the aircraft is approved for return to service.

C. The Extent Of Relief Sawyer Infrared Seeks And The Reason Sawyer Infrared Seeks The Relief.

1. Extent of Relief Sawyer Infrared Seeks And The Reason Sawyer Infrared Seeks Relief From Section 

61.113(a) And (b).

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

command, is requested to the extent necessary to allow a PIC holding a private pilot certificate, as well as an 

airman medical certificate, and who has met certain flight-hour and currency requirements, to conduct the 

proposed UAS flight operations for compensation or hire.

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

pilot may, for compensation or hire, act as PIC of an aircraft in connection with any business or employment 

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

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

As set forth more fully below, Sawyer Infrared submits that an equivalent level of safety will be 

maintained because no PIC will be allowed to operate the Spreading Wings S900 UAS unless that PIC has met 

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

Spreading Wings S900 UAS in a manner consistent with the operations specifications as set forth herein, 

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

vessels, vehicles and structures.
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Further, Sawyer Infrared submits that all flights of the Spreading Wings S900 UAS, conducted by the 

PIC pursuant to the grant of this Petition: (1) will be incidental to Sawyer Infrared’s business; and (2) will not 

carry passengers or property for compensation or hire.

2. Extent of Relief Sawyer Infrared Seeks And The Reason Sawyer Infrared Seeks Relief From Section 

91.7(a).

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

allow Sawyer Infrared to determine that the Spreading Wings S900 UAS is in an airworthy condition prior to 

every flight by ensuring that the UAS is in compliance with the operating documents (i.e., the Spreading 

Wings S900 User Manual, the Spreading Wings S900 Release Notes and the A2 Flight Control System User 

Manual).

Sawyer Infrared seeks the requested relief because the Spreading Wings S900 UAS does not require an 

airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H. Therefore, Sawyer Infrared will 

ensure that the Spreading Wings S900 UAS is in an airworthy condition based upon its compliance with the 

operating documents prior to every flight, and further, determine the aircraft is in a condition for safe flight, as 

stated in the conditions and limitations below.

3. Extent of Relief Sawyer Infrared Seeks And The Reason Sawyer Infrared Seeks Relief From Section 

91.121.

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

the Spreading Wings S900 UAS, because the Spreading Wings S900 UAS’s altitude reporting equipment may 

be set on the ground to zero feet AGL, rather than local barometric pressure or field altitude, before each flight. 

The Spreading Wings S900 UAS utilizes a barometric pressure sensor, GPS equipment, and a radio 

communications telemetry data link to downlink altitude information from the UAS to the PIC at the ground 

control station (GCS).

Considering the limited altitude of the proposed operations, relief from 14 C.F.R. § 91.121 is sought to 

the extent necessary to comply with the applicable conditions and limitations stated below. As more fully set 

forth herein, a level of safety equivalent to Section 91.121 will be ensured as the altitude of the Spreading 

Wings S900 UAS will be reported to air traffic control (ATC) in feet above ground level (AGL), and Sawyer 

Infrared will operate the Spreading Wings S900 UAS within visual line of sight, at or below 400 feet AGL.
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4. Extent Of Relief Sawyer Infrared Seeks And The Reason Sawyer Infrared Seeks Relief From Section 

91.151(b).

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

the extent required to allow flights of the battery powered Spreading Wings S900 UAS during daylight hours 

in visual meteorological conditions (VMC), under visual flight rules (VFR). The Spreading Wings S900 

contains enough battery power to fly for a total duration of 18 minutes, however, Sawyer Infrared will fly the 

UAS for no longer than 14.4 minutes to the first point of intended landing, assuming normal cruising speed, 

and will reserve approximately 3.6 minutes of flight time for safety precautions (i.e., 20 percent battery power 

remaining).

Sawyer Infrared seeks the requested relief because without an exemption from Section 91.151(b), the 

flight time duration of the battery powered Spreading Wings S900 UAS will severely constrain the practicality 

of any aerial acquisition and research flight operations that Sawyer Infrared proposes to conduct pursuant to 

this Petition.

Significantly, as set forth below, the technical specifications of the Spreading Wings S900 UAS, the 

Spreading Wings S900 UAS operating documents, and Sawyer Infrared’s proposed operating limitations, 

ensure that Sawyer Infrared will safely operate the battery powered Spreading Wings S900 UAS during 

daylight hours in visual meteorological conditions (VMC) under visual flight rules (VFR). The Spreading 

Wings S900 contains enough battery power to fly for a total duration of 18 minutes, however, Sawyer Infrared 

will fly the UAS for no longer than 14.4 minutes to the first point of intended landing, assuming normal 

cruising speed, and will reserve approximately 3.6 minutes of flight time for safety precautions (i.e., 20 percent 

battery power remaining).

5. Extent Of Relief Sawyer Infrared Seeks And The Reason Sawyer Infrared Seeks Relief From Sections 

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

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

aircraft with an airworthiness certificate, Sawyer Infrared requests relief from these Sections because the 

Spreading Wings S900 UAS does not require an airworthiness certificate. As set forth more fully below, the 

Spreading Wings S900 UAS meets the conditions of Section 333 of the FMRA for operation without an 

airworthiness certificate.

All maintenance, alterations, or preventive maintenance on the UAS of the Spreading Wings S900

UAS performed by Sawyer Infrared will be in accordance with the methods, techniques, and practices 

prescribed in the operating documents (i.e., the Spreading Wings S900 User Manual, the Spreading Wings 

S900 Release Notes and the A2 Flight Control System User Manual). Furthermore, only the Original 
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Equipment Manufacturer (OEM) or qualified OEM maintainers will perform higher-level inspections and 

maintenance per the operating documents and OEM standards. Sawyer Infrared will document and maintain all 

maintenance records for the Spreading Wings S900 UAS.

D. The Reasons Why Granting Sawyer Infrared’s Request Would Be In The Public Interest; That Is, 

How It Would Benefit The Public As A Whole.

Granting the present Petition will further the public interest by allowing Sawyer Infrared to safely, efficiently, 

and economically perform infrared inspection services and optical gas imaging within the NAS, commercially, 

in support of various clients including environmental firms, hotels, construction companies, critical 

infrastructure corporations including oil, gas and electricity providers, and local military bases including the 

United States Coast Guard Base in Boston, Massachusetts and the Otis Air Force Reserve Base located in 

Bourne, Massachusetts. Additionally, use of the Spreading Wings S900 UAS will decrease congestion of the 

NAS, reduce pollution, and provide significant benefits to the economy. Notably, the benefits of Sawyer 

Infrared’s proposed operation of the Spreading Wings S900 UAS will be realized without implicating any

privacy issues.

1. The Public Will Benefit From The Aerial Acquisition And Research Performed.

Sawyer Infrared submits this Petition to commercially operate the Spreading Wings S900 UAS and 

perform aerial acquisitions within the NAS, in support of environmental firms, hotels, construction companies, 

critical infrastructure corporations including oil, gas and electricity providers, and local military bases. The 

Spreading Wings S900 UAS will provide safe, efficient, and economical aerial acquisition and research 

operations to further each of these fields, all of which are critical to the well-being and safety of the general 

public.

The specific operations that Sawyer Infrared will perform with the Spreading Wings S900 UAS 

demonstrate how the requested exemption will directly benefit the above-referenced industries and the public. 

More specifically, in the oil and gas industries, the Spreading Wings S900 UAS will be used to aid in facility 

safety and compliance inspections. Inspections of facilities include roofs, solar panels, windmill blades, 

facades, bridges, liquid nitrogen gas storage tanks, electrical transmission towers, power lines and substations, 

agricultural crops, gas pipelines, and petroleum storage tanks. The Spreading Wings S900 UAS will further 

environmental management by determining threats of oil and gas pollution, as well as mapping oil and gas

spills or other types of land and water contamination.

2. The Public Will Benefit From Decreased Congestion Of The NAS.
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The Spreading Wings S900 UAS is battery powered and serves as a safe, efficient, and economical 

alternative to utilizing manned aircraft to obtain this type of aerial imagery. By reducing the amount of manned 

aircraft needed to perform aerial photography, an exemption allowing the use of a Spreading Wings S900 UAS 

would reduce the amount of manned aircraft in the NAS, reduce noise and air pollution, and increase the safety 

of life and property in the air and on the ground.

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

airports caused by arriving and departing aircraft will be reduced. The Spreading Wings S900 UAS does not 

require an airport to takeoff or land. Likewise, a reduction of manned aircraft conducting aerial survey 

missions would result in fewer aircraft that must be handled by air traffic control during the ground, takeoff, 

departure, arrival, and landing phases of flight operations.

3. The Public Will Benefit From The Safety And Efficiency Of The Spreading Wings S900 UAS.

Conducting aerial acquisitions with the Spreading Wings S900 UAS, instead of manned aircraft, will 

greatly benefit the public by drastically reducing the levels of air and noise pollution generated during 

traditional aerial imaging flights. By using battery power and electric motors, the Spreading Wings S900 UAS 

produces no air pollution, and is the most viable environmentally conscious alternative to the cabin class, six 

cylinder internal combustion twin-engine aircraft that are typically utilized for aerial imagery, and burn 

approximately 20-30 gallons per hour of leaded aviation fuel. The Spreading Wings S900 UAS, while 

reducing the carbon footprint of aerial acquisitions, also reduces noise pollution, as the UAS is propelled by 

battery powered electric motors, rather than an internal combustion engine.

By using the Spreading Wings S900 UAS to perform aerial acquisitions, the substantial risk to life 

and property in the air and on the ground, which is usually associated with traditional manned aircraft flight 

operations, will be substantially reduced or completely eliminated. Aside from the lack of flight crew members 

located onboard the aircraft, the Spreading Wings S900 UAS (weighing approximately 7.3 pounds; measuring 

approximately 18x17x14; and carrying no fuel on board), has less physical potential for collateral damage to 

life and property on the ground, and in the air, compared to the manned aircraft that typically conduct aerial 

imagery (weighing approximately 6,500 pounds with a wingspan of approximately 40 feet, a length of 34 feet, 

and a fuel capacity of 180 gallons).

4. Performing Aerial Acquisition Operations With The Spreading Wings S900 UAS Will Benefit 

The Economy.

In addition to being safe and efficient, the Spreading Wings S900 UAS is also an economical 

alternative to using manned aircraft to conduct aerial imagery. As such, operation of the Spreading Wings 

S900 UAS will allow United States-based companies, like Sawyer Infrared, to remain competitive and 
Sawyer	Infrared Page	15

contribute to growth of the United States economy. In employing infrared inspection services and optical gas 

imaging, Sawyer Infrared ensures that environmental agencies, hotels, construction companies, critical 

infrastructure corporations, military bases are able to operate effectively and safely, which ultimately prevents

death, injury, or other company liabilities which would lead to personal hardship and loss of business.

Additionally, with the rising cost of aviation fuel and the Environmental Protection Agency (“EPA”) 

regulatory actions phasing out leaded aviation fuels, United States-owned and operated companies must adopt 

new and alternative technology in order to remain competitive. Operating the battery powered Spreading 

Wings S900 UAS is one such technology that not only allows companies greater operational flexibility 

compared to manned aircraft, but provides such flexibility without the high operational cost of a traditional 

manned aircraft.

By operating the Spreading Wings S900 UAS, companies such as Sawyer Infrared can remain 

competitive and profitable, and therefore, provide greater job stability to employees and contractors, which 

will ultimately contribute to growth of the United States economy. Improved financial performance of United 

States companies, through commercial use of the Spreading Wings S900 UAS, provides a stable workforce 

that increases consumer spending; improves local, state, and federal tax revenues; and allows companies to 

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

5. There Are No Privacy Issues.

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

Infrared’s proposed operation of the Spreading Wings S900 UAS will not implicate any privacy issues. 

Specifically, the Spreading Wings S900 UAS will only be operated pursuant to the specific conditions and 

limitations set forth herein, and in accordance with the Federal Aviation Regulations, including the minimum 

altitude requirements of 14 C.F.R. § 91.119. Most significantly, the Spreading Wings S900 UAS will not be 

operated closer than 500 feet to any person, vessel, vehicle, or structure, which is not directly involved in the 

operation.

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

Exemption Would Provide A Level Of Safety At Least Equal To That Provided By The Rule From 

Which Sawyer Infrared Seeks Exemption.

1. Reasons Why The Spreading Wings S900 UAS Meets The Conditions Of The FAA Modernization and 

Reform Act of 2012 (FMRA) Section 333.

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

aircraft and its operation, Sawyer Infrared’s operation of the Spreading Wings S900 UAS meets the conditions 

of FMRA Section 333, and will not require an airworthiness certificate in accordance with 14 C.F.R. Part 21, 
Sawyer	Infrared Page	16

Subpart H. Section 333 provides authority for a UAS to operate without airworthiness certification and sets 

forth requirements for considering whether a UAS will create a hazard to users of the NAS or the public, or 

otherwise pose a threat to national security. Specifically, FMRA Section 333 states the following, in part:

(a) In General.--Notwithstanding any other requirement of this subtitle, and not later than 180 days after the 

date of enactment of this Act, the Secretary of Transportation shall determine if certain unmanned aircraft 

systems may operate safely in the national airspace system before completion of the plan and rulemaking 

required by section 332 of this Act or the guidance required by section 334 of this Act.

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

Secretary shall determine, at a minimum--

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

capability, proximity to airports and populated areas, and operation within visual line of sight do not create a 

hazard to users of the national airspace system or the public or pose a threat to national security; and

(2) whether a certificate of waiver, certificate of authorization, or airworthiness certification under section 

44704 of title 49, United States Code, is required for the operation of unmanned aircraft systems identified 

under paragraph (1).

(c) Requirements for Safe Operation.--If the Secretary determines under this section that certain unmanned 

aircraft systems may operate safely in the national airspace system, the Secretary shall establish requirements 

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

In seeking this exemption, Sawyer Infrared submits that the Spreading Wings S900 UAS can operate safely in 

the NAS pursuant to FMRA Section 333, as demonstrated by: (a) the characteristics of the Spreading Wings 

S900 UAS; (b) the pilot certification requirement; and (c) the specific operating limitations.

a. The Specifications Of The Spreading Wings S900 UAS Demonstrate Its Safe Characteristics.

The Spreading Wings S900 UAS does not create a hazard to users of the NAS or the public, or 

otherwise pose a threat to national security considering its size, weight, speed, and operational capability.

i. Technical Specifications Of The Spreading Wings S900 UAS.

The technical specifications of the Spreading Wings S900 UAS are set forth at pages 22-23 of the 

Spreading Wings S900 User Manual, attached hereto as Exhibit A. Exhibit A contains proprietary information 

and is to be held in a separate file pursuant to 14 C.F.R. § 11.35(b)1.
Sawyer	Infrared Page	17

ii. The Spreading Wings S900 UAS Is Manufactured For Safety and Reliability. 

The Spreading Wings S900 UAS is built with a strong carbon fiber frame, designed to greatly reduce 

weight while increasing stability and strength under various, tested flight and temperature conditions. It also 

contains an advanced power distribution board, which improves reliability and safety during flight. The 

Spreading Wings S900 is also manufactured with a unique screw design to secure power cords and is equipped 

with a spark-proof plug to prevent short circuits in flight. The UAS’ six motors located on each arm are 

comprised of a single-wire stator design, which improves heat dissipation for a more dependable system. Each 

arm is also designed with an 8-degree inversion and a 3-degree inclination, making the UAS more stable and 

controllable when rolling and pitching, and flexible when rotating during flight. Sawyer Infrared understands 

that the maximum flight time of 18 minutes of the Spreading Wings S900 was tested during low-wind weather 

conditions, with a payload of 14.9lbs, while hovering at a height of 6.5 feet. The safety features of the 

Spreading Wings S900 UAS are set forth in the Spreading Wings S900 User Manual, the Spreading Wings 

S900 Release Notes and the A2 Flight Control System User Manual attached hereto as Exhibit A. Exhibit A 

contains proprietary information and is to be held in a separate file pursuant to 14 C.F.R. § 11.35(b)1.

iii. The Spreading Wings S900 GCS And Its Operation.

The Spreading Wings S900 UAS is compliant with all Federal Communications Commission (FCC) 

requirements, and the radio frequency spectrum used for operation and control of the UAS is set forth at page 

31 of the Spreading Wings S900 UAS User Manual. A copy of the Spreading Wings S900 User Manual, which 

contains proprietary information, is attached hereto as Exhibit A, and is to be held in a separate file pursuant to 

14 C.F.R. § 11.35(b).

b. Flight Operations Of The Spreading Wings S900 UAS Are Limited To The Line Of Sight Of A

Certificated Pilot in Command With A Safety Observer.

Sawyer Infrared will only utilize certificated pilots who possess a current and valid FAA issued airman 

medical certificate to act as a pilot in command (PIC) of the Spreading Wings S900 UAS. Additionally, a 

safety observer will assist all pilots during flight operations.

c. Flights Of The Spreading Wings S900 UAS Will Be Conducted Pursuant To Specific Operating 

Limitations.

In seeking this exemption, Sawyer Infrared proposes to commercially operate the Spreading Wings 

S900 UAS for the special purpose of conducting infrared inspection services and optical gas imaging within 

the NAS, pursuant to the following specific operating limitations:
Sawyer	Infrared Page	18

1. Operations authorized by this grant of exemption are limited to the following aircraft described in the 

operating documents, which is a hexa-rotor aircraft weighing less than 8 pounds at maximum gross weight: 

DJI Spreading Wings S900 Unmanned Aerial System. Proposed operations of any other aircraft will require a 

new petition or a petition to amend this grant.

2. UAS operations under this exemption will be limited to conducting operations for the purpose of aerial 

acquisitions.

3. The UAS may not be flown at an indicated airspeed exceeding 30 knots.

4. The UAS must be operated at an altitude of no more than 400 feet above ground level (AGL), as indicated 

by the procedures specified in the operating documents. All altitudes reported to ATC must be in feet AGL.

5. The UAS must be operated within visual line of sight (VLOS) of the PIC at all times. This requires the PIC 

to be able to use human vision unaided by any device other than corrective lenses, as specified on the 

PIC’s FAA-issued airman medical certificate.

6. The use of first person view (FPV) by the PIC or visual observer (VO) is not permitted.

7. All operations must utilize a visual observer (VO). The VO may be used to satisfy the VLOS requirement as 

long as the PIC always maintains VLOS capability. The VO and PIC must be able to communicate verbally at 

all times. Electronic messaging or texting is not permitted during flight operations. The PIC must be 

designated before the flight and cannot transfer his or her designation for the duration of the flight. The PIC 

must ensure that the VO can perform the functions prescribed in the operating documents.

8. The VO must not perform any other duties beyond assisting the PIC with seeing and avoiding other air 

traffic and other ground based obstacles/obstructions and is not permitted to operate the camera or other 

instruments.

9. The operating documents and the grant of exemption must be accessible during UAS operations and made 

available to the Administrator upon request. If a discrepancy exists between the conditions and limitations 

contained in the grant of exemption and the procedures outlined in the operating documents, the conditions and 

limitations contained in the grant of exemption take precedence and must be followed. Otherwise, the operator 

must follow the procedures as outlined in its operating documents. The operator may update or revise its 

operating documents. It is the operator’s responsibility to track such revisions and present updated and revised 

documents to the Administrator upon request. The operator must also present updated and revised documents 

if it petitions for extension or amendment to the grant of exemption. If the operator determines that any update 

or revision would affect the basis upon which the FAA granted the exemption, then the operator must petition 
Sawyer	Infrared Page	19

for amendment to the grant of exemption. The FAA’s UAS Integration Office (AFS-80) may be contacted if 

questions arise regarding updates or revisions to the operating documents.

10. Prior to each flight the PIC must inspect the UAS to ensure it is in a condition for safe flight. If the 

inspection reveals a condition that affects the safe operation of the UAS, the aircraft is prohibited from 

operating until the necessary maintenance has been performed and the UAS is found to be in a condition for 

safe flight. The Ground Control Station must be included in the preflight inspection. All maintenance and 

alterations must be properly documented in the aircraft records.

11. Any UAS that has undergone maintenance or alterations that affect the UAS operation or flight 

characteristics, e.g. replacement of a flight critical component, must undergo a functional test flight. The PIC 

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

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

equipment, not already covered in the relevant sections of the operating documents.

13. The operator must follow the UAS manufacturer’s aircraft/component, maintenance, overhaul, 

replacement, inspection, and life limit requirements.

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

with the operating documents. Maintenance, inspection, alterations, and status of replacement/overhaul 

component parts must be noted in the aircraft records, including total time in service, description of work 

accomplished, and the signature of the authorized person returning the UAS to service.

15. Each UAS operated under this exemption must comply with all manufacturer Safety Bulletins.

16. The authorized person must make an entry in the aircraft record of the corrective action taken against 

discrepancies discovered between inspections.

17. The PIC must possess at least a private pilot certificate and at least a current third- class medical certificate. 

The PIC must also meet the flight review requirements specified in 14 C.F.R. § 61.56 in an aircraft in which 

the PIC is rated on his or her pilot certificate.

18. The operator may not permit any PIC to operate unless the PIC meets the operator’s qualification criteria 

and demonstrates the ability to safely operate the UAS in a manner consistent with how the UAS will be 

operated under the exemption, including evasive and emergency maneuvers and maintaining appropriate 

distances from persons, vessels, vehicles and structures. PIC qualification flight hours must be logged in a 

manner consistent with 14 C.F.R. § 61.51(b). The VO is also required to complete the operator’s training 

requirements. A record of training must be documented and made available upon request by the Administrator. 
Sawyer	Infrared Page	20

Flights for the purposes of training the operator’s PICs and VOs (training, proficiency, and experiencebuilding), are permitted under the terms of the exemption. However, training operations may only be 

conducted during dedicated training sessions. During training, proficiency, and experience-building flights, all 

persons not essential for flight operations are considered nonparticipants, and the PIC must operate the UAS

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

19. UAS operations may not be conducted during night, as defined in 14 C.F.R. § 1.1. All operations must be 

conducted under visual meteorological conditions (VMC). Flights under special visual flight rules (SVFR) are 

not authorized.

20. The UAS may not operate within 5 nautical miles of an airport reference point as denoted on a 

current FAA-published aeronautical chart unless a letter of agreement with that airport’s management is 

obtained, and the operation is conducted in accordance with a NOTAM as required by the operator’s COA. 

The letter of agreement with the airport management must be made available to the Administrator upon 

request.

21. The UAS may not be operated less than 500 feet below or less than 2,000 feet horizontally from a cloud or 

when visibility is less than 3 statute miles from the PIC.

22. If the UAS loses communications or loses its GPS signal, it must return to a pre- determined location 

within the planned operating area and land or be recovered in accordance with the operating documents.

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

operating documents.

24. The PIC is prohibited from beginning a flight unless (considering wind and forecast weather conditions) 

there is enough power to fly at normal cruising speed to the intended landing point and land the UAS with 20% 

battery power remaining.

25. The operator must obtain an Air Traffic Organization (ATO) issued Certificate of Waiver or Authorization 

(COA) prior to conducting any operations under the grant of exemption. This COA will also require the 

operator to request a Notice to Airmen (NOTAM) not more than 72 hours in advance, but not less than 48 

hours prior to the operation. All operations shall be conducted in accordance with airspace requirements in the 

ATO issued COA including class of airspace, altitude level and potential transponder requirements.
Sawyer	Infrared Page	21

26. All aircraft operated in accordance with the exemption must be identified by serial number, registered in 

accordance with 14 C.F.R. part 47, and have identification (N- Number) markings in accordance with 14 

C.F.R. part 45, Subpart C. Markings must be as large as practicable.

27. Before conducting operations, the radio frequency spectrum used for operation and control of the UAS

must comply with the Federal Communications Commission (FCC) or other appropriate government oversight 

agency requirements.

28. The documents required under 14 C.F.R. 91.9 and 91.203 must be available to the PIC at the Ground 

Control Station of the UAS any time the UAS is operating. These documents must be made available to the 

Administrator or any law enforcement official upon request.

29. The UAS must remain clear and yield the right of way to all manned aviation operations and activities at 

all times.

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

31. The UAS may not be operated over congested or densely populated areas.

32. Flight operations must be conducted at least 500 feet from all nonparticipating persons (persons other than 

the PIC, VO, operator trainees or essential persons), vessels, vehicles, and structures unless:

a. Barriers or structures are present that sufficiently protect nonparticipating persons from the UAS and/or 

debris in the event of an accident. The operator must ensure that nonparticipating persons remain under such 

protection. If a situation arises where nonparticipating persons leave such protection and are within 500 feet of 

the UAS, flight operations must cease immediately and/or;

b. The aircraft is operated near vessels, vehicles or structures where the owner/controller of such vessels, 

vehicles or structures has granted permission and the PIC has made a safety assessment of the risk of operating 

closer to those objects and determined that it does not present an undue hazard, and;

c. Operations nearer to the PIC, VO, operator trainees or essential persons do not present an undue hazard to 

those persons per § 91.119(a).

33. All operations shall be conducted over private or controlled-access property with permission from the land 

owner/controller or authorized representative. Permission from land owner/controller or authorized 

representative will be obtained for each flight to be conducted.
Sawyer	Infrared Page	22

34. Any incident, accident, or flight operation that transgresses the lateral or vertical boundaries of the 

operational area as defined by the applicable COA must be reported to the FAA's UAS Integration 

Office (AFS-80) within 24 hours. Accidents must be reported to the National Transportation Safety Board 

(NTSB) per instructions contained on the NTSB Web site: www.ntsb.gov.

2. Reasons Why An Exemption From The Requirements Of Section 61.113(a) And (b) Would Not 

Adversely Affect Safety.

Sawyer Infrared submits that the equivalent level of safety established by Section 61.113(a) and (b) 

will be maintained because no PIC will be allowed to operate the Spreading Wings S900 UAS unless that PIC 

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

operate the Spreading Wings S900 UAS in a manner consistent with the exemption, including evasive and 

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

Considering Sawyer Infrared’s proposed area of operations, and the operating limitations set forthabove; the parallel nature of private pilot aeronautical knowledge requirements to those of commercial pilot 

requirements (See Exemption No. 11062); and the airmanship skills necessary to safely operate the Spreading 

Wings S900 UAS, Sawyer Infrared submits that the additional manned airmanship experience of a 

commercially certificated pilot would not correlate to the airmanship skills necessary for Sawyer Infrared ’s 

specific proposed flight operations.

The Spreading Wings S900 UAS has been the subject of multiple Grants of Exemption from Section 

61.113(a) and (b) (Exemption Nos. 11153, 11157). Additionally, the FAA has previously granted relief from 

Section 61.113(a) and (b) specific to UAS, in circumstances similar, in all material respects, to those presented 

herein (e.g. Exemption Nos. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 11112, 11136, 

11138, 11150, 11153, 11156, 11158, 11159, 11160, 11161, 11170, 11171, 11172).

Sawyer Infrared will not allow any PIC to operate the Spreading Wings S900 UAS unless that PIC has 

demonstrated, by meeting minimum flight-hour requirements or the Spreading Wings S900 UAS training and 

currency requirements, that the PIC is able to safely operate the Spreading Wings S900 UAS in a manner 

consistent with this exemption, including evasive and emergency maneuvers and maintaining appropriate 

distances from people, vessels, vehicles and structures.

Specifically, the PIC must have accumulated and logged, in a manner consistent with 14 C.F.R. § 

61.51(b), 25 hours of total time as a UAS rotorcraft pilot including at least 10 hours logged as a UAS pilot 
Sawyer	Infrared Page	23

with a multi-rotor UAS (with a minimum of 5 hours of those hours as a UAS pilot operating the same make 

and model of UAS to be used for operations under the exemption). In addition to the hour requirements, the 

PIC must accomplish 3 take-offs and landings in the preceding 90 days (for currency purposes). As in 

Exemption Nos. 11062, 11138, and 11153, prior documented flight experience that was obtained in 

compliance with applicable regulations will ensure an equivalent level of safety during Sawyer Infrared’s 

proposed operations. The Administrator has held that prior documented flight experience that was obtained in 

compliance with applicable regulations would ensure safe operations, stating as follows:

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

picture filming (or similar operations), the PIC must have accumulated and logged, in a manner consistent 

with 14 CFR 61.51(b), 25 hours of total time as a UAS rotorcraft pilot including at least 10 hours logged as a 

UAS pilot with a multi-rotor UAS. Prior to operations under Exemption No. 11062, the PIC must also have 

accumulated and logged a minimum of 5 hours as a UAS pilot operating the same make and model of UAS to 

be used for operations under the exemption. For clarification, the FAA considers these minimum hour 

requirements to be inclusive rather than additive; i.e. 5 hours make and model time may be included in the 10 

hours of multi-rotor time and the 10 hours may be included in the total 25 hours of UAS rotorcraft time. In 

addition to the hour requirements, the PIC must accomplish 3 take-offs and landings in the preceding 90 days 

(for currency purposes). The FAA finds that at a minimum, the flight-hour requirements in Exemption No. 

11062 are appropriate to practice and build proficiency in the skills necessary to safely conduct the 

petitioner’s proposed operations. The FAA also finds that prior documented flight experience that was 

obtained in compliance with applicable regulations would satisfy this requirement. Training, proficiency, and 

experience-building flights can also be conducted under the grant of exemption to accomplish the required 

flight time. During training, proficiency, and experience-building flights the PIC is required to operate the 

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

Exemption No. 11138 at page 15.

Accordingly, Sawyer Infrared will ensure safe operations by not allowing any PIC to operate the 

Spreading Wings S900 UAS unless that PIC has demonstrated, by meeting minimum flight-hour and currency 

requirements, that the PIC is able to safely operate the Spreading Wings S900 UAS in a manner consistent 

with the exemption, including evasive and emergency maneuvers and maintaining appropriate distances from

people, vessels, vehicles and structures.

3. Reasons Why An Exemption From The Requirements Of Section 91.7(a) Would Not Adversely Affect 

Safety.

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

flight, Sawyer Infrared will ensure that the Spreading Wings S900 UAS is in an airworthy condition based 
Sawyer	Infrared Page	24

upon the Spreading Wings S900 UAS’ compliance with its operating documents (i.e., the Spreading Wings 

S900 User Manual, the Spreading Wings S900 Release Notes and the A2 Flight Control System User Manual), 

and as stated in the conditions and limitations herein.

The Spreading Wings S900 UAS has been the subject of multiple Grants of Exemption from Section 

91.7(a) (Exemption Nos. 11153, 11157). Additionally, the FAA has previously granted relief from Section 

91.7(a) specific to UAS, in circumstances similar, in all material respects, to those presented herein (e.g. 

Exemption Nos. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 11112, 11136, 11138, 

11150, 11153, 11156, 11157, 11158, 11159, 11160, 11161, 11166, 11167, 11170, 11171, 11172).

4. Reasons Why An Exemption From The Requirements Of Section 91.121 Would Not Adversely Affect 

Safety.

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

the Spreading Wings S900 UAS will be reported to air traffic control (ATC) in feet above ground level (AGL), 

and Sawyer Infrared will operate the Spreading Wings S900 UAS within visual line of sight, at or below 400 

feet AGL. Furthermore, the altitude information of the Spreading Wings S900 UAS will be provided to the 

PIC via a barometric pressure sensor, GPS equipment and a radio communications telemetry data link, which 

downlinks from the UAS to the GCS for active monitoring of the flight path and altitude. Prior to each flight, a 

zero altitude initiation point is automatically established by the UAS at ground level.

The Spreading Wings S900 UAS was the subject of multiple Grants of Exemption from Section 91.121 

(Exemption Nos. 11153, 1157). The FAA has previously granted relief from Section 91.121 specific to UAS, 

in circumstances similar, in all material respects, to those presented herein (e.g. Exemption Nos. 11062, 11063, 

11064, 11065, 11066, 11067, 11080, 11109, 11112, 11136, 11138, 11150, 11153, 11156, 11157, 11158, 

11159, 11160, 11161, 11166, 11167, 11170, 11171).

5. Reasons Why An Exemption From The Requirements Of Section 91.151(b) Would Not 

Adversely Affect Safety.

A grant of this exemption would ensure an equivalent level of safety established by 14 C.F.R. Section 

91.151(b) as a result of (1) the technical specifications of the Spreading Wings S900 UAS; (2) the limitations 

on the proposed flight operations; and (3) the location of the proposed flight operations. Accordingly, Sawyer 

Infrared will ensure that it will safely operate the battery powered Spreading Wings S900 UAS during daylight 

hours in visual metrological conditions (VMC) under visual flight rules (VFR). The Spreading Wings S900 

contains enough battery power to fly for a total duration of 18 minutes, however, Sawyer Infrared will fly the 

UAS for no longer than 14.4 minutes to the first point of intended landing, assuming normal cruising speed, 
Sawyer	Infrared Page	25

and will reserve approximately 3.6 minutes of flight time for safety precautions (i.e., 20 percent battery power 

remaining).

Here, as in Exemption No. 11109, the technical specifications of the Spreading Wings S900 UAS; the 

limitations on the proposed flight operations; and the location of the proposed operations, will ensure an 

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

the Spreading Wings S900 UAS provides audible and visual warnings to the PIC at the GCS when the UAS

has low battery power remaining.

Significantly, the Spreading Wings S900 UAS has been the subject of multiple Grants of Exemption 

from Section 91.151 (Exemption Nos. 11153, 11157), and other previous exemptions granted by the FAA 

concerning Section 91.151 establish that safety is not adversely affected when the technical characteristics and 

operating limitations of the UAS are considered. Relief has been granted for manned aircraft to operate at less 

than the minimums prescribed in Section 91.151, including Exemption Nos. 2689, 5745, and 10650. 

Moreover, the FAA has previously granted relief from Section 91.151 specific to UAS, in circumstances 

similar, in all material respects, to those presented herein (e.g. Exemption Nos. 8811, 10808, 10673, 11042, 

11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 11136, 11138, 11150, 11153, 11156, 

11157, 11158, 11159, 11160, 11161, 11166, 11167, 11170, 11171, 11172).

6. Reasons Why An Exemption From The Requirements Of Sections 91.405(a), 91.407(a)(1), 

91.409(a)(1) & (a)(2), And 91.417(a) & (b) Would Not Adversely Affect Safety.

In seeking this exemption, Sawyer Infrared submits that the equivalent level of safety with regard to the 

regulatory maintenance and alteration requirements established by Sections 91.405(a), 91.407(a)(1), 

91.409(a)(1) & (a)(2), and 91.417(a) & (b) will be met because all maintenance, alterations, or preventive 

maintenance of the Spreading Wings S900 UAS performed by Sawyer Infrared will be in accordance with the 

methods, techniques, and practices prescribed in the operating documents (i.e., the Spreading Wings S900 User 

Manual, the Spreading Wings S900 Release Notes and the A2 Flight System User Manual). Furthermore, only 

the Original Equipment Manufacturer (OEM) or qualified OEM maintainers will perform higher-level

inspections and maintenance per the operating documents and OEM standards. Sawyer Infrared will document 

and maintain all maintenance records for the Spreading Wings S900 UAS.

Since the Spreading Wings S900 UAS will be inspected as prescribed by the operating documents, 

Sawyer Infrared will maintain the equivalent level of safety established by Sections 91.405(a), 91.409(a)(1), 

and 91.409(a)(2). The following operating documents are attached hereto, identified as the following Exhibit: 

(A) the Spreading Wings S900 User Manual, the Spreading Wings S900 Release Notes and the A2 Flight 
Sawyer	Infrared Page	26

Control System User Manual. The foregoing exhibits contain proprietary information and are to be held in a 

separate file pursuant to 14 C.F.R. § 11.35(b).

Likewise, the exemption sought will not adversely affect safety because all maintenance, alterations, or 

preventive maintenance of the Spreading Wings S900 UAS will be performed by DJI in accordance with the 

methods, techniques, and practices prescribed in the operating documents. Only the Original Equipment 

Manufacturer (OEM) or qualified OEM maintainers will perform higher-level inspections and maintenance per 

the operating documents and OEM standards. Sawyer Infrared will document and maintain all maintenance 

records for the Spreading Wings S900 UAS.

Furthermore, an equivalent level of safety established by Sections 91.407, 91.417(a) and 91.417(b), 

because Sawyer Infrared will document and maintain all of the maintenance records for the Spreading Wings 

S900 UAS.

The Spreading Wings S900 UAS has been the subject of multiple Grants of Exemption from Sections 

91.405(a), 91.407(a)(1) and (a)(2), 91.409(a)(2), and 91.417(a) and (b) (Exemption Nos. 11153, 11157), and 

other previous exemptions granted by the FAA concerning these Sections establish that safety is not adversely 

affected when the technical characteristics and operating limitations of the UAS are considered (e.g. 

Exemption Nos. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 11112, 11136, 11138, 

11150, 11153, 11156, 11157, 11158, 11159, 11160, 11161, 11166, 11167, 11170, 11171, 11172).

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

In accordance with Section 333 of the FAA Modernization and Reform Act of 2012 (FMRA) and 14 

C.F.R. § 21.16 entitled Special Conditions, Sawyer Infrared requests that the FAA prescribe special conditions 

for the intended operation of the Spreading Wings S900 UAS, which contain such safety standards that the 

Administrator finds necessary to establish a level of safety equivalent to that established by 14 C.F.R. Part 21, 

Subpart H, and 14 C.F.R §§ 61.113(a) & (b), 91.7 (a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) 

& (a)(2), and 91.417(a) & (b). Such special conditions will permit safe operation of the UAS for the limited 

purpose of conducting aerial acquisitions within the NAS for compensation or hire. FMRA Section 333 sets 

forth the requirements for considering whether a UAS will create a hazard to users of the NAS or the public, or 

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

without airworthiness certification in accordance with any requirements that must be established for the safe 

operation of the UAS in the NAS.

Likewise, the Administrator may prescribe special conditions pursuant to 14 C.F.R.§ 21.16, for 

operation of the Spreading Wings S900 UAS, since the airworthiness regulations of 14 C.F.R. Part 21 do not 
Sawyer	Infrared Page	27

contain adequate or appropriate safety standards, due to the novel or unusual design features of the aircraft. 

Section 21.16, entitled Special Conditions, states the following:

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

safety standards for an aircraft, aircraft engine, or propeller because of a novel or unusual design feature of 

the aircraft, aircraft engine or propeller, he prescribes special conditions and amendments thereto for the 

product. The special conditions are issued in accordance with Part 11 of this chapter and contain such safety 

standards for the aircraft, aircraft engine or propeller as the FAA finds necessary to establish a level of safety 

equivalent to that established in the regulations.

See 14 C.F.R. § 21.16.

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

special conditions for Sawyer Infrared’s intended operation of the Spreading Wings S900 UAS, which contain 

such safety standards that the Administrator finds necessary to establish a level of safety equivalent to that 

established by 14 C.F.R. Part 21, Subpart H, and 14 C.F.R Section 61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 

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

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

Infrared Seeks Exemption:

Sawyer Infrared seeks exemption from the requirements of 14 C.F.R Sections 61.113(a)&(b), 91.7(a), 91.121, 

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

A Brief Description Of The Nature Of The Exemption Sawyer Infrared Seeks:

This exemption will permit Sawyer Infrared to commercially operate an Unmanned Aircraft System (UAS) for 

the purpose of conducting infrared inspection services and optical gas imaging within the National Airspace 

System (NAS).

G. Any Additional Information, Views, Or Arguments Available To Support Sawyer Infrared’s 

Request.

This Petition is made pursuant to the FAA Modernization and Reform Act of 2012 (FMRA) Section 

333, which directs the Secretary of Transportation to determine if certain UAS may operate safely in the NAS. 

As such, Sawyer Infrared’s request for exemption may be granted pursuant to the authority of FMRA Section 

333 and 14 C.F.R. Part 11, as set forth above.
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FMRA Section 333 sets forth the requirements for considering whether a UAS will create a hazard to 

users of the NAS or the public, or otherwise pose a threat to national security; and further, provides the 

authority for such UAS to operate without airworthiness certification.

As discussed in detail above, Sawyer Infrared will operate the Spreading Wings S900 UAS safely in 

the NAS, without creating a hazard to users of the NAS, or the public, or otherwise pose a threat to national 

security.

CONCLUSION

As set forth herein, Sawyer Infrared seeks an exemption pursuant to 14 C.F.R. § 11.61 and Section 333 

of the FAA Modernization and Reform Act of 2012 (FMRA), which will permit safe operation of the 

Spreading Wings S900 UAS commercially, without an airworthiness certificate, for the limited purpose of 

conducting infrared inspection services and optical gas imaging within the National Airspace System (NAS).

By granting this Petition, the FAA Administrator will be fulfilling the Congressional mandate of the 

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

Sawyer Infrared to safely, efficiently, and economically operate the Spreading Wings S900 UAS commercially 

within the NAS.

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

Reform Act of 2012, Section 333, Sawyer Infrared respectfully requests that the Administrator grant this 

Petition for an exemption from the requirements of 14 C.F.R Sections 61.113(a) & (b), 91.7(a), 91.121, 

91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b), and permit Sawyer Infrared to 

operate the Spreading Wings S900 UAS commercially for the purpose of conducting aerial acquisitions within 

the NAS.