LanierFord.Com

1

October 23, 2015

U.S. Department of Transportation, Docket Operations

West Building Ground Floor, Room W 12-140

1200 New Jersey Ave., SE

Washington, DC 20590

Re: Exemption Request Pursuant to Section 333 of the FAA Modernization and Reform 

Act of 2012 and Part 11 of the Federal Aviation Regulations from 14 C.F.R. Part 21, Subpart H, 

14 C.F.R. Part 27, and 14 C.F.R. §§ 45.23(b), 45.27(a), 61.101(e)(4), 61.113, 61.133(a), 61.23(a) 

and (c); 61.315(a), 91.9(c), 91.119, 91.121, 91.151(a) & (b), 91.405(a), 91.407(a)(1), 

91.409(a)(2), and 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 C.F.R. Part 11, Signalink, Inc. (“Signalink”) hereby applies for an exemption from the 

Federal Aviation Regulations identified below to allow for the commercial operation of the DJI 

Spreading Wings S-900 (“Spreading Wings”) unmanned aircraft systems for aerial data 

collection. 

Signalink requests that the FAA review this petition pursuant to its “summary grant” process as 

the FAA has already granted exemptions similar in all material respects to this petition. See FAA 

Grant of Exception Nos. 11062, 11109, 11112, and 11213. The reasons stated by the FAA in 

granting the exemptions listed above also apply to this petition, and the grant of this petition are 

in the public interest. 

I. REGULATIONS FOR WHICH EXEMPTION IS REQUESTED 

Signalink requests exemption from the following regulations: 

· 14 C.F.R Part 21, Subpart H; 

· 14 C.F.R Part 27; 

· 14 C.F.R § 45.23(b); 

Jonathan F. Mayhall

Attorney at Law

Facsimile: (256) 533-9322

jfm@lanierford.com
2

· 14 C.F.R. § 45.27(a);

· 14 C.F.R § 61.101(e)(4);

· 14 C.F.R § 61.113;

· 14 C.F.R § 61.133(a);

· 14 C.F.R § 61.23(a) and (c);

· 14 C.F.R § 61.315(a); 

· 14 C.F.R § 91.9(c); 

· 14 C.F.R § 91.119; 

· 14 C.F.R § 91.121; 

· 14 C.F.R § 91.151(a) & (b) 

· 14 C.F.R § 91.405(a); 

· 14 C.F.R § 91.407(a)(l); 

· 14 C.F.R § 91.409(a)(2); 

· 14 C.F.R § 91.417 (a) & (b).

This petition incorporates the material contained in the User Manuals for the Spreading Wings

S900

II. STATUTORY AUTHORITY FOR REQUESTED EXEMPTIONS 

This petition for exemption is submitted in accordance with Section 333 of the Reform Act. 

Congress has directed the FAA “to safely accelerate the integration of civil unmanned aircraft 

systems into the national airspace system.” Pursuant to Section 333 of the Reform Act, the FAA 

Administrator is to permit operation of an unmanned aircraft system (“UAS”) where it does not 

create a hazard to users of the national airspace system (“NAS”) or the public or pose a threat to 

national security based on the following considerations: 

· The size, weight, speed and operational capability; 

· Operation in proximity to airports and populated areas; and 

· Operation within visual line of sight of the operator. Furthermore, the Federal Aviation 

Act grants the FAA Administrator general authority to grant exemptions from the 

agency’s safety regulations and minimum standards when the Administrator decides a 
3

requested exemption is in the public interest. See 49 U.S.C. §§ 106(f), 44701-44716, et 

seq. A party requesting an exemption must explain the reasons why the exemption: (1) 

would benefit the public as a whole, and (2) would not adversely affect safety or how it 

would provide a level of safety at least equal to the existing rules. 14 C.F.R. § 11.81. 

III. DESCRIPTION OF SIGNALINK AND ITS SERVICES 

Signalink provides aerial data capture and imaging services for a wide variety of industries 

including infrastructure, real estate, wild life, energy, agriculture, engineering and insurance. 

Signalink is headquartered in Madison, Al.

Signalink, Inc.

1286 Slaughter Rd

Madison, Al 35758

IV. DESCRIPTION OF PROPOSED OPERATIONS 

Signalink is requesting exemptions from applicable Federal Aviation Regulations (FARs) 

pursuant to Section 333 of the Reform Act to perform aerial data capture and imaging services 

for a variety of industries including infrastructure, real estate, wild life, energy, agriculture,

engineering and insurance. 

Helicopter or fixed wing aircraft typically performs this type of aerial imagery and data

collection. Use of a UAS will reduce safety risks due to the fact it does not carry flammable fuel 

or a pilot, and UAS operations can be performed at significant savings. The UAS will also allow 

for better imagery than can be produced by using a helicopter or fixed wing aircraft. 

A. Aircraft to be Operated 1. DJI Spreading Wings S-900 

Signalink will use the Spreading Wings S-900 as the main aircraft to provide its services. The 

FAA has already approved the Spreading Wings for commercial use in FAA Exemption No. 

11521 (FAA Docket No. FAA-2014-0947). The Spreading Wings is shown in Figure 1 below. 
4

Figure 1– DJI Spreading Wings S-900

The Spreading Wings is more fully described in the Spreading Wings User Manual. 

B. Signalink’s Proposed Operations Demonstrate an Equivalent Level of Safety 

1. General Description of Proposed Flight Operations 

Signalink proposes to operate within the limitations and performance specifications listed in this 

application and in the manual. These limitations provide for at least an equivalent, or higher, 

level of safety for operations under the current regulatory structure because the proposed 

operations are safer than conventional operations using helicopters or fixed wing aircraft, which 

carry an operator and flammable fuel. The proposed flight operations are similar in all material 

respects to operations already approved by the FAA and are therefore subject to the FAA’s 

“summary grant” process. 

The proposed operations do not create any hazard to users of the national airspace system or pose 

a threat to national security. The aircraft are battery operated with a maximum flight time of less 

than 20 minutes. The vehicles weigh less than 55 pounds. The vehicles will be operated at or 

below 400 feet AGL within the visual line of sight of the pilot in command. Signalink’s 

operations will be over private or controlled access property with the permission of the 

owner/controller or authorized agent. 

Manned aircraft are at risk of fuel spillage and fire in the event of an incident or accident. The 

proposed UAS carry no fuel, and therefore the risk of fire following an incident or accident due 

to fuel spillage is eliminated. Compared to manned aircraft, the UAS being operated by the 

petitioner reduces the risk to participating persons in close proximity to the aircraft due to the 

limited size, weight, operating conditions, and design safety features. 

The petitioner’s aircraft have the capability to operate safely after experiencing certain in- flight 
5

failures, as specified in the manual. The aircraft are also able to respond to a lost-link event with 

a pre-coordinated and automated flight maneuver. 

2. Specific Limitations on Proposed Flight Operations 

Given the small size involved, the restricted environment within which they will operate, the 

procedures listed below, and pilot certification requirements, Signalink’s proposed operations 

would “not create a hazard to users of the national airspace system or the public or pose a threat 

to national security.” Reform Act Section 333(b)(1). 

1. The aircraft weigh less than 55 pounds. 

2. Each aircraft will be identified by serial number, registered with the FAA, and have 

identification (N-Number) markings as large as practical. 

3. Flights will be operated within visual line of sight of the pilot in command (PIC). 

4. Prior to each flight, a zero altitude initiation point will be established and confirmed for 

accuracy by PIC. 

5. The PIC will ensure that before each flight, there is enough available power for the UAS 

to conduct the intended operation with a reserve power of 25%, or greater if

recommended by the manufacturer. 

6. The aircraft will be operated during daylight and in VFR conditions. 

7. Flights will not exceed 400 feet AGL. 

8. Flights will be operated at a lateral distance of at least 500 feet from any persons or 

property not associated with the operation who have not given prior permission. 

9. Flights will be limited to a groundspeed of 100 mph. 

10. Minimum crew for each flight will consist of a PIC and an Observer. 

11. The PIC will hold either an airline transport, commercial, private, recreational, or sport 

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

valid U.S. driver’s license issued by a state or the Federal Government. The PIC will 

also meet the flight review requirements specified in 14 CFR § 61.56. 

12. Prior to the flight, a Mission Plan will be created setting forth the limitations for the flight 

as well as contact information for the PIC. 

13. The flight operations will yield the right of way to other manned aircraft operations. 
6

14. All persons who are not involved with Signalink‘s operations will be required to be at 

least 500 feet from flight operations. 

15. The aircraft will only operate over private or controlled access property with the 

permission of the owner/controller or authorized representative. 

16. The UAS will not operate within 5 nautical miles of an airport unless a letter of 

agreement is obtained. 

17. All required permissions and permits will be obtained from territory, state, county or city 

jurisdictions prior to flight. 

18. For any operations not allowed under the Blanket Certificate of Waiver or Authorization 

(COA) issued on March 23, 2015,, Signalink will obtain a COA from the FAA prior to 

commencing operations. 

19. If the aircraft loses communications, it will have the capability to return to a predetermined location within the operational area and land. 

20. If the aircraft loses its GPS signal it will have the capability of being flown manually to a 

predetermined location within the operational area and land. 

21. The flight will be aborted in case of unpredicted obstacles or emergencies. 

22. All flights performed will have data logs containing relevant flight information.

23. UAS operations will be conducted within the parameters of the Manuals. 

V. SPECIFIC FAR EXEMPTIONS REQUESTED 

Signalink seeks an exemption from several interrelated provisions of 14 C.F.R. Parts 21, 45, 61, 

and 91 for purposes of conducting the requested operations. Listed below are (1) the specific 

FAR sections for which exemption is sought, and (2) the operating procedures and safeguards 

that Signalink has established which will ensure a level of safety better than or equal to the rules 

from which exemption is sought. See 14 C.F.R. § 11.81 (e). 

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

The FAA has stated that no exemption is needed from this section if a finding is made under the 

Reform Act that the UAS selected provides an equivalent level of safety when compared to 

aircraft normally used for the same application. These criteria are met with this petition, and 

therefore no exemption is needed. See Grant of Exemption No. 11062, Docket No. FAA 2014-

0352 at 13-14, 22. If, however, the FAA determines that there are some characteristics of the 

UAS that fail to meet the requirements of the Reform Act, an exemption is requested. 
7

Equivalent Level of Safety: The UASs are safe when taking into account their size, weight, 

speed, and operational capability. They weigh less than 55 pounds and will be flown at speeds 

less than 100 miles per hour, and in visual line of sight of the operator. The UASs do not carry 

pilots, passengers, explosive materials, or flammable liquid fuels. The UASs will be operated 

within the parameters of their respective Manuals. 

The proposed operations will be at least as safe as, or safer than, conventional rotorcraft or fixed 

wing aircraft operating with an airworthiness certificate without the restrictions and conditions 

proposed here. 

B. 14 C.F.R. Part 27 Airworthiness Standards: Normal Category Rotorcraft 

14 C.F.R. Part 27 sets forth the procedural requirements for airworthiness certification of normal 

category rotorcraft. To the extent the UAS would otherwise require certification under Part 27, 

Signalink seeks an exemption from Part 27’s airworthiness standards for the same reasons 

identified in the request for exemption from 14 C.F.R. Part 21, Subpart H. 

C. 14 C.F.R. §§ 45.23(b), 45.27(a) and 91.9(c): Aircraft Marking and Identification 

Requirements 

14 C.F.R. §45.23(b), Markings of the Aircraft states: 

When marks include only the Roman capital letter “N” and the registration number is displayed 

on limited, restricted or light-sport category aircraft or experimental or provisionally certificated 

aircraft, the operator must also display on that aircraft near each entrance to the cabin, cockpit, or 

pilot station, in letters not less than 2 inches nor more than 6 inches high, the words “limited,” 

“restricted,” “light-sport, “experimental,” or “provisional,” as applicable. 

14 C.F.R. § 45.27(a) states: 

Rotorcraft. Each operator of a rotorcraft must display on that rotorcraft horizontally on both 

surfaces of the cabin, fuselage, boom, or tail the marks required by § 45.23. 

14 C.F.R. § 91.9(c) states: 

No person may operate a U.S.-registered civil aircraft unless that aircraft is identified in 

accordance with part 45 of this chapter. 

In a previous Grant of Exemption, the FAA determined that exemption from these requirements 

was warranted provided that the aircraft “have identification (N-Number) markings in 

accordance with 14 CFR part 45, Subpart C if the markings are “as large as practicable.” See 

Exemption No. 11062, Docket No. FAA 2014-0352, at p. 14. 

Equivalent Level of Safety: Signalink will mark all UASs with their N-Number in a prominent 

spot on the fuselage with markings that are as large as practicable. 

D. 14 C.F.R. § 61.23(a) and (c), 61.101(e)(4), 61.113(a), 61.133(a), 61.315(a): Pilot Privileges 
8

and Limitations

Signalink seeks exemption from the above regulations to the extent that they require the PIC of 

an UAS to have a commercial pilot’s license with a current medical certificate. Section 61.23(a) 

sets out the operations requiring a medical certificate and the level of certificate required. 

Sections 61.113(a) and (b) limit private pilots to non-commercial operations. Likewise, Sections 

61.315(a) and 61.101(a) limit light-sport and recreational pilots, respectively, to non-commercial 

operations. Section 61.133(a) requires an individual with a commercial pilot’s license to be pilot 

in command of an aircraft for compensation or hire. The purpose of Part 61 is to ensure that the 

skill and competency of any PIC matches the airspace in which the PIC will be operating, as well 

as requiring certifications if the pilot is carrying passengers or cargo for hire

While the UAS will be operated as part of a commercial operation, they carry neither passengers 

nor cargo. The FAA has granted exemptions allowing operations by people who hold an airline 

transport, commercial, private, recreational, or sport pilot certificate with a current FAA airman 

medical certificate or a valid U.S. driver’s license issued by a state or the Federal Government. 

The PIC must also meet the flight review requirements specified in 14 CFR § 61.56. See FAA 

Exemption No. 11374. 

Signalink will ensure the PIC will meet the requirements listed in the above paragraph. Signalink

will also ensure the PIC will have completed the manufacturers’ training guidelines outlined in 

the Manuals. 

The FAA stated in its grant of an exception to Astraeus Aerial the “the FAA considers the 

overriding safety factor for the limited operations proposed by the petitioner to be the airmanship 

skills acquired through UAS-specific flight cycles, flight time, and specific make and model 

experience, culminating in verification through testing.” See Exemption No. 11062, Docket No. 

FAA 2014-0352, at p. 18. The proposed operations can achieve an equivalent level of safety by 

requiring the knowledge and experience in the UAS operations described above. 

The restrictions Signalink has placed on its UAS operations meet or exceed the restrictions 

similarly imposed on Astraeus Aerial in FAA Docket No. FAA-2014-0352 and those listed in the 

FAA’s “summary grant” process.

E. 14 C.F.R. § 91.119(c): Minimum Safe Altitudes in Uncongested Areas 

Signalink requests an exemption from the minimum safe altitude requirements of 14 C.F.R. § 

91.119(c). Section 91.119(c) prescribes that an aircraft may not be operated closer than 500 feet 

to any person, vessel, vehicle, or structure. The Manuals provide for Signalink operations at least 

500 feet from persons and structures not involved in the operations. The FAA has already 

determined that relief from Section 91.119(c) is warranted for UAS operations in uncongested 

areas with similar flight restrictions as those imposed by Signalink. See Grant of Exemption No. 

11062, p. 20-21. 

Equivalent Level of Safety: Compared to flight operations with rotorcraft or fixed wing aircraft 

weighing far more than the maximum weights proposed herein, and given the lack of flammable 
9

fuel, any risk associated with these operations is far less than those that presently exist with 

conventional aircraft. An equivalent level of safety will be achieved given the size, weight, and 

speed of the UAS, as well as the locations where it is operated . In order to avoid any risk to 

aircraft, flight operations will be restricted to 400 feet AGL or below. Other aircraft are already 

prohibited from operating closer than 500 from structures where Signalink proses to operate. 

This is airspace where other aircraft do not normally operate. As set forth in the Manuals and 

herein, the UAS will be operated in the remote sites, away from persons or structures not 

involved in the operation. All persons who are not involved with Signalink’s operations will be 

required to be at least 500 feet from flight operations. This will pose no risk to the public because 

other aircraft are not operating in these areas. 

F. 14 C.F.R. § 91.121: Altimeter Settings 

This petition seeks an exemption from 14 C.F.R. § 91.121, which requires a person operating an 

aircraft to maintain cruising altitude or flight level by reference to an altimeter that is set to the 

elevation of the departure airport. The UASs proposed here use both barometric pressure sensors 

and GPS to determine altitude but do not have the ability to set in a current altimeter setting. An 

exemption is required to the extent that the UAS does not have a barometric altimeter setting. 

The altitude of the UAS is monitored by the PIC on the ground control station and by the visual 

observer. 

Equivalent Level of Safety: The FAA has stated that an equivalent level of safety can be 

achieved if the aircraft will be operated at or below 400 feet AGL and within visual line-of- sight 

in addition to GPS based altitude information relayed in real time to the operator. See Grant of 

Exemption No. 11062, p. 20-21. As the attached Manuals indicate, the UAS will be operated at 

or below 400 feet AGL and otherwise comply with the limitations in the Grant of Exemption No. 

11062. 

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

Signalink requests an exemption from 14 C.F.R. § 91.151(a)’s fuel requirements for flight in 

VFR conditions. Section 91.151 states: 

(a) No person may begin a flight in an airplane under VFR conditions unless (considering wind 

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

and, assuming normal cruising speed -

. (1) During the day, to fly after that for at least 30 minutes; or 

. (2) At night, to fly after that for at least 45 minutes. 

Here, the technological limitations on the UAS battery power means that no meaningful flight 

operations can be conducted while maintaining a 30 minute reserve. The aircraft are battery 

powered with a maximum flight time of less than 25 minutes. The PIC will ensure that before 

each flight, there is enough available power for the UAS to conduct the intended operation and to 

operate after that for at least five minutes or with the reserve power recommended by the 

manufacturer if greater. 
10

Equivalent Level of Safety: The FAA has stated that an equivalent level of safety is provided if 

the UAS flight is conducted under daytime VFR flight conditions using VLOS, and terminated 

with at least 25% reserve battery power still available. See Grant of Exemption No. 11062, p. 21-

22. The FAA’s “summary grant” process provides that the PIC is prohibited from beginning a 

flight unless there is enough available power to conduct the intended operation and to operate 

after that for at least five minutes or with the reserve power recommended by the manufacturer if 

greater. See FAA Exemption No. 11374 (FAA Docket No. 2015-0091 at p. 5). The limitations 

here provide that the PIC will ensure that before each flight, there is enough available power for 

the UAS to conduct the intended operation and to operate after that for at least five minutes or 

with the reserve power recommended by the manufacturer if greater. 

H. 14 C.F.R. §§ 91.405(a), 91.407(a)(l), 91.409(a)(2); 91.417(a) and (b): Maintenance 

Inspections 

Signalink seeks an exemption from the maintenance inspection requirements contained in 14 

C.F.R. § 91.405(a), 91.407(a)(l), 91.409(a)(2); 91.417(a) and (b). These regulations specify 

maintenance and inspection standards in reference to 14 C.F.R. Part 43. See, e.g., 14 C.F.R. § 

91.405(a) (stating that each owner or operator of an aircraft “[s]hall have the aircraft inspected as 

prescribed in subpart E of this part and shall between required inspections ... have discrepancies 

repaired as prescribed in part 43 of this chapter”). An exemption from these regulations is needed 

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

the UAS proposed here will not have. 

Equivalent Level of Safety: An equivalent level of safety will be achieved because maintenance 

and inspections will be performed in accordance with the Manuals. This includes maintenance, 

overhaul, replacement, and preflight inspection requirements.

See Exemption No. 11062 (FAA Docket No. 2014-0352, at p. 14-15) and Exemption No. 11374 

(FAA Docket No. 2015-0091, at p. 4). 

Signalink will follow the UAS manufacturer’s maintenance requirements. Flights will not be 

conducted unless a flight operations checklist is performed that includes all of the aircraft’s 

components. 

VI. PUBLIC INTEREST 

Granting Signalink’s petition for exemption furthers the public interest. National policy set by 

Congress favors early integration of UAS into the NAS in controlled, safe working environments 

such as proposed in this petition. By granting this petition, the FAA will fulfill Congress’s intent 

of allowing UAS to operate safely in the NAS before completion of the rulemaking required 

under Section 332 of the Reform Act. 

Moreover, use of UAS will promote the efficient use of resources. The use of the UAS propped 

here will also decrease safety-related incidents involving traditional aircraft. The public has an 

interest in promoting science and technology education and in reducing the hazards and 

emissions associated with alternate use of helicopters and small airplanes to conduct similar 
11

operations. 

VII. PRIVACY 

All flights will occur over private or controlled access property with the owner’s consent. All 

flights will be conducted in accordance with any federal, state or local laws regarding privacy. 

IX. ATTACHMENTS 

Attachment 1: 

Spreading Wings S-900 User Manual 

If you have any questions or require any additional information, please do not hesitate to contact 

the undersigned attorneys for Signalink.

X. CONCLUSION 

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

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

sight, and national security considerations - provides more than adequate justification for the 

grant of the requested exemptions to permit Signalink to operate the UASs proposed here. 

Furthermore, this petition warrants review by the FAA under the “summary grant” process for 

immediate approval. 

XI. SUMMARY FOR FEDERAL REGISTER

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012, Signalink, Inc. 

requests exemption from the following Federal Aviation Regulations that are found under Title 

14 of the Code of Federal Regulations: Part 21, Subpart H, Part 27, and Sections 45.23(b), 

45.27(a), 61.101(e)(4), 61.113, 61.133(a), 61.23(a) and (c); 61.315(a), 91.9(c), 91.119, 91.121, 

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

Sincerely, 

Jonathan Mayhall

Counsel for Signalink, Inc.

Enclosures
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
29
30
31
32
33
34
35
36
37
38
39
40
41
42
43
44
45
46
47
48