Transportation Docket Management system 

1200 New Jersey Ave., SE 

Washington, DC 20590

Re: Exemption Request section 333 of the FAA Reform Act and Part 11 of the Federal 

Aviation Regulations from 14 CFR 61.113 (a) & (b); 91.103(b); 91.119; 91.121; 

91.151(a); 91.405 (a); 91.407(a)

(1); 91.409 (a) (2); 91.417 (a) &(b).

Dear Sir or Madam:

Pursuant to section 333 of the FAA Modernization and Reform Act of 2012 (the Reform 

Act) and 14 CFR Part 11, IRQ Technical Labs LLC hereby applies for an exemption 

from the listed Federal Aviation Regulations ("FARs") to allow commercial operation of 

its small unmanned Aircraft systems ("sUAS") for aerial imaging for safety

and monitoring sites, so long the conditions as required by

of secured and controlled environment construction as such operations are conducted 

within and under outlined herein or as may be established by the FAA section 333.

IRQ Technical Labs will perform many different airborne solutions such as: mapping 

data, sensing, construction, photography, real estate, agricultural, environmental, 

inspections, and FAA certifications. These techniques and procedures and often require 

our employees to be put in situations that require IRQ Technical Labs to accept risk. 

we have found that by using a small unmanned aircraft system "sUAS" with a high 

resolution camera mounted on it, often times we can accomplish the same inspection 

and alleviate the need to put our employees and public in danger.

IRQ Technical Labs shares congress's goal of getting sUAS flying commercially in the 

united states safely and soon. In the FAA Modernization and Reform Act of 2012, 

congress directed the FAA "to safely accelerate the integration of civil unmanned 

aircraft systems into the national airspace system" and, under Section 333 of that law, 

gave the FAA power to grant innovators "expedited operational authorization" to do so. 

By this

petition, IRQ Technical Labs is seeking authorization to conduct sUAS commercial 

operations.

Further, granting this request will do nothing more than allow IRQ Technical Labs to do 

what thousands of hobbyists and manufacturers of model aircraft do every day, except 

we will abide by much stronger safety measures. under supervision of a certified pilot 

we would provide a safer level of operation that is superior to current regulations. This 

invaluable experience applied to IRQ Technical Labs UAS program equates to safe 

sUAS use on our projects with no confliction with manned aircraft.
Information supporting this Petition as Specified in 14 CFR §11.81

A. Mailing address and other contact information:

IRQ Technical Labs

2618 Ritchie Marlboro Rd.

Upper Marlboro, MD 20774

GH Turner

301-257-9334

ghturner@irqlabs.com

B. The specific section or sections of 14 C.F.R from which IRQ Technical Labs

seeks exemption.

14 CFR Part 21 14 CFR 45.23(b) 14 CFR 61.113 (a) & (b)

14 CFR 91.7 (a)

14 CFR 91.9 (b) (2)

14 CFR 91.103

14 CFR 91.109

14 CFR 91.119

14 CFR 91.121

14 CFR 91.203 (a) &(b) 14 CFR 91.405

(a) 14 CFR 407 (a) (1) 14 CFR 409 (a)

(2) 14 CFR 417 (a) & (b)

I . STATUTORY AUTHORITY FOR EXEMPTIONS

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

statutory authority includes exempting civil aircraft, as the term is defined under §40101 

of the Act, including sUASs, from the requirement that all civil aircraft must have a 

current airworthiness certificate.

The Administrator may grant an exemption from a requirement of a regulation 

prescribed under subsection (a) or (b) of this section or any sections 44702-44716 of 

this title if the Administrator finds the exemption in the public interest. 49 USC. 

§44701(f) See also 49 USC §44711(a); 49 USC §44704; 14 CFR §91.203(a) (1).

Section 333(b) of the Reform Act assists the secretary in determining whether sUAS 

may operate in the National Airspace system (NAS) without creating a hazard to the 

user, the public, or a threat to national security. In making this determination, the 

Secretary must consider:

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

• whether the sUAS operates within the visual line of sight of the operator

• whether the sUAS operates outside of highly populated areas and away from close 

proximity to airports
Reform Act §333(a). If the secretary determines that a sUAS "may operate safely in the 

national airspace system, the secretary shall establish requirements for the safe 

operation of such aircraft in the national airspace system." Id. §333(c).

IRQ Technical Labs sUAS, weighing less than 55 lbs. includind payload, and will 

operate under normal conditions at a speed of no more than 50 knots. The sUAS will 

operate only in the Pilot's visual line of sight at all times and will operate only within the 

preplanned area. such operations will insure that the sUAS will ''not create a hazard to 

users of the national airspace system or the public." Reform Act section 333 (b).

Given the small size of the sUAS involved and the restricted and preplanned area within 

which they will operate, our application falls squarely within the zone of safety (an 

equivalent level of safety) in which congress envisioned that the FAA must, by 

exemption, allow commercial operations of sUAS to commence immediately. Also due 

to the small size of the sUAS and the low altitudes and restricted areas in which the 

sUAS will operate, approval of the application presents no national security issue.

Given the clear direction in section 333 of the Reform Act, the authority contained in the 

Federal Aviation Act, as amended ; the strong equivalent level of safety surrounding the 

proposed operations, and the significant public benefit, including enhanced safety, the 

grant of the requested exemptions is in the public interest . Accordingly, IRQ Technical 

Labs respectfully requests that the FAA grant the requested exemption without delay.

II. PUBLIC INTEREST

This exemption application is expressly submitted to fulfill congress' goal in passing 

section 333(a) through (c) of the Reform Act. This law directs the Secretary of 

Transportation to consider whether certain unmanned aircraft systems may operate 

safely in the NAS before completion of the rulemaking required under Section 332 of the 

Reform Act. By granting an exemption the FAA will fulfill congress's intent of allowing 

UAS to operate with significant safety precautions in low risk environments.

The use of sUAS in a wide variety of site types can significantly reduce the risk to 

workers of falls while inspecting, surveying, or monitoring work progress and site 

conditions. sUAS can inspect, photograph, and collect data on hard to get to areas that 

otherwise would require direct worker inspection. Falls are a leading source of 

workplace fatality and injury on construction sites, reducing falls and workplace slips 

and trips through sUAS use for site imaging could save workers lives.

Additionally, sUAS could replace the use of helicopters and small aircraft to perform our 

intended tasks. The sUAS we propose to fly in this application are under fifty-five 

pounds, and carry no combustible material on board, as opposed to much larger 

conventionally powered small aircraft. Shifting to sUAS from helicopters and airplanes 

presents a marked safety increase for workers and the public.
Lastly, sUAS reduce the environmental impact by dramatically decreasing the energy 

used for aerial imaging and data collection. Our sUAS use rechargeable lithium ion 

batteries, as opposed to fossil fuels burned in operation of small aircraft that are many 

hundreds of times heavier.

III. EQUIVALENT LEVEL OF SAFETY

IRQ Technical Labs sUAS operations will provide a level of safety that far exceeds the 

level of safety required by the FAA for hobbyists and manufacturers of model aircraft. 

The following operating procedures will apply during the sUAS inspection operations 

under this exemption request.

1. IRQ Technical Labs operations will be conducted:

i. Within the visual line of sight of the Pilot in command (PIC) and one or more 

visual Observers (VO).

ii. Within class G airspace

iii. At less than 300 feet AGL.

2. IRQ Technical Labs inspection operations will be conducted in a confined area over 

isolated private property located at least 4 miles away from any airport, heliport, 

seaplane base, spaceport or other location with aviation activities, and any military or 

U.S. Government installations or airfields. If we are within the 4 mile radius of any of the 

above installations IRQ Technical Labs will seek written approval from that 

installation's owner before sUAS operations take place. If said installation owner 

requires stricter guidelines for operation then IRQ Technical Labs will comply.

3. All sUAS operations will remain within the lateral and vertical boundaries of the 

operating area, taking into account all factors, including wind, gross weight and glide 

distances, that may affect the capability of the sUAS to remain within the airspace 

boundary; moreover, the ceiling height will be no more than 400 feet AGL.

4.IRQ Technical Labs sUAS inspection operations under this exemption will be 

conducted under the supervision designated PIC who ultimately has final responsibility 

for the operation in accordance with 14 CFR 91.3.

5. The PIC and vo will maintain two-way communications with each other during all 

operations; if unable to maintain two-way communications, or if any condition occurs 

that may otherwise cause the operation to be unsafe, the operator will immediately 

conclude the operation.

6. Each sUAS that IRQ Technical Labs will employ under this exemption will safely 

return automatically to a home location designated by the PIC if the communications 

link is lost.
7. The aircraft documentation required by 14 CFR §§ 91.9 and 91.203(b), as applicable, 

will be available to the PIC referred to above at any time IRQ Technical Labs sUAS are 

operating.

IRQ Technical Labs will effectively operate under our own standard operating 

procedures that will provide additional safeguards that go far beyond the level of safety 

for public model airplane fields.

IV . DESCRIPTION OF SPECIFIC REGULATIONS

14 CFR 61.113 (a) &(b): Private pilot privileges and limitations: Pilot in command

Sections 61.113 (a) &(b) limit private pilots to non-commercial operations. Because the 

sUAS will not carry a pilot or passengers, the proposed operations can achieve the 

equivalent level of safety of current operations by requiring the Pilot operating the 

aircraft to have completed a sUAS flight training course of 100 hours before flying a 

sUAS. unlike a conventional aircraft that carries the pilot and passengers, the sUAS is 

remotely controlled with no living thing or cargo on board. The sUAS are also operated 

by an autopilot, which greatly reduces the danger of human error. The area of operation 

1s controlled and restricted areas, and all flights are planned and coordinated in 

advance.

The sUAS to be operated hereunder is less than 55 lbs. fully loaded, carries neither a 

pilot nor passenger, carries no explosive materials or flammable liquid fuels, and 

operates exclusively within a secured area as set out in the operation plan. Like other 

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

the operator, and in compliance with local public safety requirements, to provide 

security for the area of operation. The FAA will have advance notice of all operations.

The risks associated with the operation of the sUAS are therefore diminished from the 

level of risk associated with commercial operations contemplated by Part 61 when 

drafted, and allowing operations of the sUAS as requested with a Pilot who has the

level of safety contemplated by 14 C.F.R . §61.113 (a) & (b). 

14 CFR 91.103: Preflight Action

This regulation requires each pilot in command take certain actions before flight to 

ensure the safety of flight. An exemption is needed from this requirement as the Pilot 

will take separate preflight actions, including checking for weather conditions, checking 

flight battery requirements, checking takeoff and landing distances, and all other actions 

in the Preflight checklist in the Manual. These actions will provide an equivalent level of 

safety.

14 CFR 91.119: Minimum safe Altitudes

Section 91.119 establishes safe altitudes for operation of civil aircraft. section 91.119 (d) 

allows sUAS to be operated at less than the minimums prescribed, provided the person 
operating complies with any route or altitudes prescribed by the FAA. The sUAS will 

never operate at altitude higher than 400 AGL and will be in a restricted area with 

security perimeter, where buildings and people will not be exposed to operations without 

their pre-obtained consent.

The equivalent level of safety will be achieved given the size, weight, speed of the 

sUAS as well as the location where it is operated. No flight will be taken without the 

permission of the property owner or local officials. Because of the advance notice to the 

property owner and any onsite personnel, all affected individuals will be aware of the 

planned flight operations. unlike flight operations with aircraft or

rotorcraft weighing far more than the maximum 55 lbs. proposed herein, our sUAS will 

not carry flammable fuel . In addition, the low-altitude operations of the sUAS will ensure 

separation between sUAS operations and the operations of conventional aircraft that 

must comply with Section 91.119.

14 CFR 91.121: Altimeter settings

This regulation requires each person operating an aircraft to maintain cruising altitude 

by reference to an altimeter that is set "...to the elevation of the departure airport or an 

appropriate altimeter setting available before departure." As the sUAS may not have a 

barometric altimeter, but instead a GPS altitude read out, an exemption may be needed. 

An equivalent level of safety will be achieved by the operator confirming the altitude of 

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

14 CFR 91.151 (a): Fuel requirements for flight in VFR conditions

Section 91.151 (a) outlines fuel requirements for beginning a flight in VFR conditions. 

our sUAS is limited to operations in sterile and controlled environments, and has a 

limited range and flight time which require an exemption from 14 CFR 91.151(a).

The battery powering the sUAS provides approximately 35 minutes of powered flight. To 

meet the 30 minute reserve requirement in 14 CFR §91.151, sUAS flights would be 

limited to approximately 5 minutes in length. Given the limitations on the sUAS's 

proposed flight area and the location of its proposed operations within a predetermined 

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

IRQ Technical Labs believes that an exemption from 14 CFR §91.151(a) falls within 

the scope of prior exemptions. See Exemption 10673 (allowing Lockheed Martin 

corporation to operate without compliance with FAR 91.151 (a)). operating the small 

sUAS, in a tightly controlled area where only people and property owners or official 

representatives who have signed waivers will be allowed, with less than 30 minutes of 

reserve fuel, does not engender the type of risks that section 91.151(a) was intended to 

alleviate given the size and speed of the small UAS. Additionally, limiting sUAS flights to 

10 minutes would greatly reduce the utility for which the exemption will be granted.
An equivalent level of safety can be achieved by limiting flights to 30 minutes, or enough 

battery reserve to ensure that the sUAS lands at the ground station with at least 20%of 

battery power (as determined by the onboard monitoring system and the Pilot), 

whichever happens first. This restriction would be more than adequate to return the 

sUAS to its planned landing zone from anywhere in its limited operating area.

Similar exemptions have been granted to other operations, including Exemptions 

2689F, 5745, 10673, and 10808.

14 CFR 91.405 (a); 407 (a)(1); 409 (a)(2); 417 (a) &(b): Maintenance inspections

These regulations require that an aircraft operator or owner "shall have that aircraft 

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

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

prescribed in part 43 of this chapter . .. ," and others shall inspect or maintain the aircraft 

in compliance with Part 43.

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

certificate, these sections will not apply to IRQ Technical Labs. Maintenance will be 

accomplished by the operator pursuant to the flight manual and operating handbook 

from the manufactural. An equivalent level of safety will be achieved because these 

small sUAS are very limited in size and will carry a small payload and operate only in 

restricted areas for limited periods of time. If mechanical issues arise the sUAS can land 

immediately and will be operating from no hi9her than 400 feet AGL. The Pilot will 

ensure that the sUAS is 1n working order prior to initiating flight, perform required 

maintenance, and keep a log of any maintenance performed. Moreover, the Pilot is the 

person most familiar with the aircraft and best suited to maintain the aircraft in an 

airworthy condition to provide the equivalent level of safety.

Pursuant to 14 CFR Part 11, the following summary is provided for publication in the 

Federal Register, should it be determined that publication is needed:

Applicant seeks an exemption from the following rules: 14 CFR §21, subpart H; 14 

C.F.R 45.23(b);14 CFR §§ 61.113( a) &

(b); 91.7

(a); 91.9 (b) (2);91.103(b);91.109; 91.119; 91.121;

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

and 91.417 (a) & (b) to operate

commercially a small unmanned vehicle (SSlbs or less).

Approval of exemptions allowing commercial operations of sUAS in the construction 

industry enhances safety while reducing risk. Manned aircraft monitoring and surveying 

creates a greater risk because the craft are much larger, have combustible fuel, and 

carry an onboard human pilot. In contrast, a sUAS weighing fewer than 55 lbs. and 

powered by batteries eliminates virtually all of that risk given the reduced mass and lack 

of combustible fuel carried on board. The sUAS will carry no passengers or crew and, 

therefore, will not expose them to the risks associated with manned aircraft flights.
The operation of small sUAS, weighing less than 55 lbs., conducted in the strict 

conditions outlined above, will provide an equivalent level of safety supporting the grant 

of the exemptions requested herein, including exempting the applicant from the 

requirements of Part 21 and allowing commercial operations. These lightweight aircraft 

operate at slow speeds, close to the ground,

and in a sterile environment and, as a result, are far safer than conventional operations 

conducted with turbine helicopters operating in close proximity to the ground and 

people.

Privacy

All flights will occur over private or controlled access property with the property owner's 

prior consent and knowledge. Images taken will be of individuals who have also 

consented to being filmed or otherwise have agreed to be in the area where aerial 

photography will take place .

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

weight, speed, operating capabilities, proximity to airports and populated areas and 

operation within visual line of sight and national security - provide more than adequate 

justification for the grant of the requested exemptions allowing commercial operation of 

applicant's sUAS.

Sincerely

IRQ Technical Labs

2618 Ritchie Marlboro Rd.

Upper Marlboro, MD 20774

GH Turner

301-257-9334

ghturner@irqlabs.com

sUAS registration FA3RX4HFL7

GH Turner

IRQ Technical Labs

www.irqlabs.com

301.613.5346 mobile

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