THE ULYSSES GROUP, LLC 

87B S, Market St.

Charleston, SC 29401

Phone: 843-437-1144

alewis@theulyssesgroup.com

November 23, 2015

To: US Department of Transportation From: Andrew Lewis, President

Docket Management System The Ulysses Group, LLC

1200 New Jersey Ave, SE 87B S Market St.

Washington, DC 20590 Charleston, SC 29401

(Submitted electronically to the Federal 

Docket Management System-FDMS)

Re: Request for Exemption under Section 333 of the FAA Reform Act

Summary of Exemption Request

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012, and the Federal 

Aviation Administration’s general exemption authority under Title 49, United States Code, 

Section 44701(f), The Ulysses Group, LLC (Ulysses) hereby petitions for exemptions from the 

following Federal Aviation Regulations specified in Title 14 Code of Federal Regulations:

14 CFR Part 21, Subpart H

14 CFR 45.23(b)

14 CFR 61.113(a)(b) 

14 CFR 61.133(a) 

14 CFR 91.7(a) 

14 CFR 91.9(b)(2) 

14 CFR 91.109(a) 

14 CFR 91.119(c) 

14 CFR 91.121 

14 CFR 91.151(a)(1) 

14 CFR 91.203(a)(b) 

14 CFR 91.319(a)(1) 

14 CFR 91.405(a) 

14 CFR 91.407(a)(1) 

14 CFR 91.409(a)(1)(2) 

14 CFR 91.417(a)(b)

These proposed exemptions, if granted, will allow Ulysses to operate their 3DR Iris+ (3DR)

Unmanned Aircraft System (UAS) and may benefit the following commercial applications: 

Disaster Response, including Emergency Search & Rescue 

Critical Infrastructure Monitoring, including Spectral & Thermal Analysis 
THE ULYSSES GROUP, LLC 

87B S, Market St.

Charleston, SC 29401

Phone: 843-437-1144

alewis@theulyssesgroup.com

Security Awareness 

Agriculture, Oil, Gas, and Mineral Survey/Scan 

3-Dimensional Terrain and Structural Modeling

UAS Operations Research & Development 

The 3DR UAS uses interchangeable onboard sensors to capture high definition imagery and 

video that may be translated into three-dimensional models of a surveyed area. Ulysses’ use of 

the UAS will grant landowners, corporations, emergency response teams, and others a greater 

awareness, heightened security, and increased level of safety during operations, as well as 

remove the need for conventional aircraft and the associated risk involved with manned flight. 

This results in an immediate environmental benefit, as well as enhanced efficiency and safety for 

any activity conducted.

Operation under the anticipated exemption will be subject to strict conditions and requirements, 

ensuring, at a minimum, an equivalent level of safety to currently authorized operating standards 

and procedures per FAA Regulations. Additionally, we are prepared to revise operational 

procedures and limitations in accordance with FAA guidance.

Supplemental Information: 

The following information is to be submitted separately to assist the FAA in making an effective 

evaluation: 

3DR Iris + Operation Manual 

3DR Iris+ Flight Checklist

Background of Applicant

The Ulysses Group, LLC, headquartered in Charleston, SC, is conducting contracted services for 

the Department of Defense with a particular emphasis in aviation operations and geospatial 

mapping. Currently, the company offers services specific to aviation operations and has a wealth 

of knowledge in aviation operations and unmanned flight operations. 

At this time, the Ulysses Group employs multiple pilots who possess a combined total of 

approximately 6,884 hours manned flight hours, 390 UAS combat flight hours, 50 Medium

Altitude Long-Endurance (MALE) UAS simulator flight hours, and 1850 USAF Aircrew flight 

hours. Certifications among employees include a senior military rotary-wing/fixed-wing pilot 

with CPL and IR, two CFIs, one PPL with IR, and one additional PPL. These pilots are very 

passionate and knowledgeable regarding flight safety, air traffic operations, and unmanned 

aviation. In addition to the extensive flight experience, Ulysses Group pilots possess formal 

educations which include bachelor’s degrees in Aeronautics, Air Traffic Management,
THE ULYSSES GROUP, LLC 

87B S, Market St.

Charleston, SC 29401

Phone: 843-437-1144

alewis@theulyssesgroup.com

Aeronautical Science, and Unmanned Aircraft System Science from Embry-Riddle Aeronautical 

University. 

The Ulysses Group is eager to commence flight operations in the unmanned sector and intendeds 

to proceed with the same discipline and commitment to flight safety as our pilots have 

demonstrated in their previous manned, unmanned, and combat operational experiences. We 

look forward to working with the FAA and we are confident in our ability to safely and 

effectively integrate with and contribute to this exciting and emerging aviation community.

Aircraft Overview

The Aircraft: 3DRIris+ 

UAS Design: 

The Iris+ UAS is built from a variety of durable, lightweight and modular components that aid in 

its capability to be on mission in a variety of conditions. The modular construction allows for 

easy exchange of structural, propulsion or sensor components in the field. 

As defined by 3DR Aircraft Performance/Specifications: 

• Aircraft Composition: polymers/plastic 

• Flight Controls: 

Primary: GPS Guided Autopilot (Ground Control Station) 

Backup: Standard Flight Controls (RC Transmitter) 

• Power Supply: Electric Motor /5100 Mah battery pack 

• Speed: 35kts

• Empty Weight: 1282g/2.83lbs 

• Max Payload: 400g/.81bs 

• Launch (Take Off): GPS assisted or manually 

• Recovery (Landing): GPS assisted or manually

Training

Ulysses requires every Operator to be fully qualified on its 3DR Iris+ UAS appropriately as 

determined by the chief pilot for the operation. Trainees are given insturction in general skills 

such as: maintaining altitude, maintaining visual line of sight, general navigation principles, 

obstacle avoidance, air traffic de-confliction, and emergency procedures. Qualification as an 

Operator for the 3DR Iris+ UAS requires that the trainee show proficient levels of all 

aforementioned skill areas, with special emphasis on emergency procedures and UAS flight 
THE ULYSSES GROUP, LLC 

87B S, Market St.

Charleston, SC 29401

Phone: 843-437-1144

alewis@theulyssesgroup.com

logic. Operators will meet applicable flight review requirements in an aircraft in which s/he is 

rated through flights and instruction as required.

Ulysses requires every person who will be acting as a Visual Observer to be a rated pilot 

proficient in airspace knowledge, emergency procedures, aeronautical chart interpretation and 

airspace safety, ground operations, and radio communications. Two-way radio communication 

will be established between the UAS operator and visual observer(s) during flight operations. 

Operations

Ulysses intends to operate the 3DR UAS in accordance with the following restrictions:

1. The	UAS	will	weigh	less	than	55	lbs.	

2. Flights	will	be	operated	within	visual	line	of	sight	of	the	Operator and/or	Visual	

Observer.	

3. Flights	will	be	operated	at	an	altitude	of	no	more	than	400ft	AGL.	

4. Flight	operations	will	take	place during	daylight	hours	under	VFR	or	Marginal	VFR	

conditions.	

5. Minimum	crew	for	each operation	will	consist	of	the	UAS	Operator	and	the	Visual	

Observer.	The	Operator	and	Visual	Observer	will	be	able	to	communicate	by	voice	at	

all	times.

6. The	UAS	Operator will	be	an	FAA	licensed	airman	with	an	FAA	medical	certificate	or	

a	valid	U.S.	driver’s	license.	

7. The	PIC	may	train	other	pilots	in	the	use	of	the	UAS.

8. The UAS	will	operate	within	an	area	that	has	been	determined	to	be	safe	and	at	least	

200ft	away	all	persons	who	are	unaware	of	the	operation.	The	operator	will	obtain	

written	and/or	verbal	consent	of	all	persons	involved	or	in	the	area	of	the	operation.

9. Written	and/or	verbal	permission	from	the	relevant	property	holders	will	be	

obtained when	conducting	flights	over	private	property.	

10. The	UAS	will	operate	at	least	100ft	away	from	buildings	in	urbanized	areas	with	the	

exception	of	buildings	which	may	be	the	subject	of	the	operation.

11. A	briefing	will	be	conducted	in	regard	to	the	planned	UAS	operation prior	to	each	

flight.	It	will	be	mandatory	that	all	personnel	who	will	be	performing	duties	within	

the	operational	area be	present	for	this	briefing	

12. The	Operator and	Visual	Observer	will	be	trained	in	the	operation	of	UAS	and	

receive	up-to-date	information	on	3DR	UAS.	

13. All	required	permissions	and	permits	will	be	obtained	from	territorial,	state,	county	

or	city	jurisdictions,	including	local	law	enforcement,	fire,	or	other	appropriate	

governmental	agencies.	

14. If	the	UAS	loses	communications	or	loses	its	GPS	signal,	the	UAS	will	have	capability	

to	return	to	a	pre-determined	location	and	land.	
THE ULYSSES GROUP, LLC 

87B S, Market St.

Charleston, SC 29401

Phone: 843-437-1144

alewis@theulyssesgroup.com

15. The	UAS	will	have	the	capability	to	abort	a	flight	in	case	of	unpredicted	obstacles	or	

emergencies.

Authority for Petition

Section 333, titled “Special Rules for Certain Unmanned Aircraft Systems,” provides a method 

for seeking expedited FAA authorization of safe, civil UAS operation in the National Airspace 

System (“NAS”). Section 333(a) states that 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.” 

Section 333(b) outlines any factors the Secretary of Transportation must consider in order to 

determine whether commercial UAS operation should be approved. These factors include at 

minimum “[the UAS’s] 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 [...]” 

Section 333(c) states that should the Secretary determine a certain UAS may operate safely in the 

NAS, “the Secretary shall establish requirements for safe operation of such aircraft systems in 

the National Airspace System.” Section 44701(f) of Title 49, United States Code, states that 

“The [FAA] Administrator may grant an exemption from a requirement of a regulation 

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

if the Administrator finds the exemption is in public interest.”

Explanations

14 CFR Part 21, Subpart H; Section 91.203(a)(1): Procedural requirements for issuing and 

changing design approvals, production approvals, airworthiness certificates, and airworthiness 

approvals.

Section 91.203(a)(1) requires all civil aircraft to have a certificate of airworthiness. Part 21, 

Subpart H, entitled Airworthiness Certificates, establishes the procedural requirements for the 

issuance of airworthiness certificates as required by FAR § 91.203(a)(1). Given the size and 

weight of the 3DR aircraft and the limited operating area associated with its utilization, it is 

unnecessary to go through the certificate of airworthiness process under Part 21 Subpart H to 

achieve or exceed current safety levels. Such an exemption meets the requirements of an 

equivalent level of safety under Part 11 and Section 333 of the Reform Act. 
THE ULYSSES GROUP, LLC 

87B S, Market St.

Charleston, SC 29401

Phone: 843-437-1144

alewis@theulyssesgroup.com

The Federal Aviation Act and Section 333 of the Reform Act both authorize the FAA to exempt 

aircraft from the requirement for an airworthiness certificate, upon consideration of the size, 

weight, speed, operational capability, and proximity to airports and populated areas of the UAS 

involved. An analysis of these criteria demonstrates that the 3DR Iris+, operated without an 

airworthiness certificate and acting under the conditions proposed herein, will be at a minimum 

as safe, if not safer, than a conventional aircraft (fixed wing or rotorcraft) that contains an

airworthiness certificate. The 3DR Iris+ weighs no more than 3.7 lbs fully configured. The 3DR 

Iris+ will not carry a pilot or passenger, it will not carry flammable fuel, and it will operate 

exclusively within an area pre-disclosed and in compliance with the conditions set forth herein. 

Operations under this exemption will be monitored and tightly controlled by both the operator, 

pursuant to the conditions set forth above, and by local public safety requirements. 

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

aircraft and its operation, Ulysses believes exemption from 14 CFR Part 21 should be granted.

14 CFR 45.23(b): Aircraft marking and identification requirements.

Since the 3DR UAS will not be certificated under 14 CFR 21.191, a grant of exemption for 14 

CFR 45.23(b) is not necessary, as the FAA has commented in the grant for exemption for 

Astraeus Aerial.

Ulysses will identify the UAS by serial number and will display any required markings in 

accordance to this exemption as large as practicable in order to meet an equivalent level of safety 

as intended by 14 CFR 45.23(a).

14 CFR 61.113(a) and (b); 61.133(a): Private pilot privileges and limitations; Pilot in Command; 

Commercial Pilot Privileges and Limitations.

Ulysses will require that all UAS operators be FAA certificated airmen and possess an FAA 

medical certificate or a valid U.S. driver’s license. UAS operators will complete the training 

requirements as described herein and will maintain all applicable flight review and currency 

requirements for their pilot qualifications.

For these reasons, Ulysses believes exemption from 14 CFR 61.113(a) and (b); 61.133(a) should 

be granted. 

14 CFR 91.7(a): Civil aircraft airworthiness 
THE ULYSSES GROUP, LLC 

87B S, Market St.

Charleston, SC 29401

Phone: 843-437-1144

alewis@theulyssesgroup.com

Under this regulation, a civil aircraft may only be operated if it is in airworthy condition. As 

there is no published standard for validating the airworthiness condition of the 3DR Iris+ UAS,

Ulysses will achieve an equivalent level of safety by ensuring compliance with all maintenance 

and inspection manuals as well as conducting a pre-flight check of the aircraft and its 

components in accordance with the procedures outlined in the manufacturer’s operation manual.

For these reasons, Ulysses believes exemption from 14 CFR 91.7(a) should be granted.

14 CFR 91.9(b)(2): Civil aircraft flight manual in the aircraft 

This regulation requires that any person to operate a U.S.-registered civil aircraft “[...] (2) For 

which an Airplane or Rotorcraft Flight Manual is not required by §21.5 of this chapter, unless 

there is available in the aircraft a current approved airplane or Rotorcraft Flight Manual, 

approved manual material, markings, and placards, or any combination thereof.” 

Given the small size of the 3DR Iris+ and the fact that the Operator will be located on the 

ground, the UAS has no ability or need to carry such a flight manual on the aircraft. However, an

equivalent level of safety will be achieved by keeping the operation manual and flight checklist

at the ground control point where the Operator and anyone involved in the operation will have 

immediate access to the documentation.

Ulysses believes exemption from 14 CFR 91.9(b)(2) should be granted, as an equivalent level of 

marking and documentation will be achieved.

14 CFR 91.109(a) & 91.319(a)(1): Flight Instruction 

These regulations provide that no person may operate a civil aircraft (except a manned free 

balloon) that is being used for flight instruction unless that aircraft has fully functioning dual 

controls. In operational configuration, the 3DR Iris+ is a remotely piloted aircraft and does not 

have fully functional dual controls. Flight control is accomplished through the use of a 

transmitter or ground control station that communicates with the aircraft via line-of-sight radio 

communications. The flight plan is preprogrammed into the autopilot before or during flight and 

the UAS may also receive manual pilot input control functions to alter the pre-programmed 

flight. Instruction will be accomplished as outlined herein; therefore, an equivalent level of 

safety will be assured.

For these reasons, Ulysses believes exemption from 14 CFR 91.109(a) & 91.319(a)(1) should be 

granted. 
THE ULYSSES GROUP, LLC 

87B S, Market St.

Charleston, SC 29401

Phone: 843-437-1144

alewis@theulyssesgroup.com

14 CFR 91.119(c): Minimum safe altitudes 

Section 91.119 establishes safe altitudes for operation of civil aircraft. Specifically, 91.119(c) 

limits aircraft flying over areas other than congested areas to an altitude of 500 feet above the 

surface, except over open water or sparsely populated areas. In those cases, the aircraft may not 

be operated closer than 500 feet to any person, vehicle, vessel, or structure. 

Ulysses will conduct all UAS operations below 400ft AGL and will	operate	within	an	area	that	

has	been	determined	to	be	safe	and	at	least	200ft	away	from	all	persons	who	are	unaware	

of	the	operation.	The	UAS	will	operate	at	least	100ft	away	from	buildings	in	urbanized	

areas	with	the	exception	of	buildings	which	may	be	the	subject	of	the	operation.	In	

addition,	any	objects	or	hazards	will	be	identified	and	mediated	prior	to	the	flight.	The	

small	size	and	weight	of	the	aircraft,	the	lack	of	flammable	fuel	on	board,	and	continuous	

communication	between	the	Operator	and	Visual	Observer	further	reduce	any	potential	

risk	associated	with	UAS	operations.	

For these reasons, Ulysses believes exemption from 14 CFR 91.119(c) should be granted 

because an equivalent level of safety will be achieved.

14 CFR 91.121: Altimeter settings 

Section 91.121 requires aircraft operators to maintain cruising altitude or flight level by reference 

to an altimeter. The 3DR UAS utilizes a Global Positioning System and altitude will be 

determined using this type of equipment.

Ulysses believes exemption from 14 CFR 91.121 should be granted as an equivalent level of 

safety will be achieved using this type of equipment. 

14 CFR 91.151(a)(1): Fuel requirements for flight in VFR conditions 

The 3DR UAS is battery powered and flight duration will be planned based on battery capacity, 

which is approximately 15-25 minutes. Flight control software will automatically return the 

aircraft to the launch point and land once the battery reaches 25%.

Because the 3DR UAS is battery powered and comes programmed with this safety feature,

Ulysses believes exemption from 14 CFR 91.151(a)(1) should be granted.

14 CFR 91.203 (a) & (b): Carrying Civil Aircraft Certification and Registration 
THE ULYSSES GROUP, LLC 

87B S, Market St.

Charleston, SC 29401

Phone: 843-437-1144

alewis@theulyssesgroup.com

This regulation provides as follows: (a) [...] no person may operate a civil aircraft unless it has 

[...] an appropriate and current airworthiness certificate. (b) No person may operate a civil 

aircraft unless the airworthiness certificate required by paragraph (a) of this section or a special 

flight authorization issued under §91.715 is displayed at the cabin or cockpit entrance so that it is 

legible to passengers or crew. 

When fully configured for flight operations, the 3DR Iris+ weighs no more than 3.7 lbs. Due to 

its light weight, there is no ability or place to carry certification and registration documents or to 

display them on the UAS. In addition, there is no pilot on board the aircraft. An equivalent level 

of safety will be achieved by keeping aircraft specific documents at the ground control point 

where the pilot flying the UAS will have immediate access to them. The FAA has issued 

numerous exemptions to this regulation.

Ulysses believes exemption from 14 CFR 91.203 (a) & (b) should be granted, as the regulation is 

not applicable to its 3DR UAS.

14 CFR 91.405(a), 91.407(a)(1), 91.409(a)(1), 91.409(a)(2), 91.417(a)(b): Maintenance 

Requirements 

Section 91.405(a) requires 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 

[...]” Section 91.407 similarly makes reference to requirements in Part 43; Section 91.409(a)(2) 

requires an annual inspection for the issuance of an air worthiness certificate. Section 91.417(a) 

requires the owner or operator to keep records showing certain maintenance work that has been 

accomplished by certificated mechanics, under Part 43, or licensed pilots and records of approval 

of the aircraft for return to service. 

Ulysses will conduct pre- and post-flight inspections, as well as regularly scheduled inspections, 

of the aircraft and its components. Ulysses will maintain inspection and maintenance logs in 

order to comply with the intent of these regulations. Unscheduled maintenance will be 

accomplished as required and will be documented appropriately in the maintenance logs. A test 

flight in a controlled area will be conducted after any maintenance or alterations to the UAS have 

taken place and prior to any other flight operations.

Due to the relative simplicity, ease of maintenance, and low risk associated with the 3DR UAS, 

Ulysses believes exemptions from these regulations should be granted.
THE ULYSSES GROUP, LLC 

87B S, Market St.

Charleston, SC 29401

Phone: 843-437-1144

alewis@theulyssesgroup.com

Summary

The 3DR Iris + UAS will capture aerial data including: high definition and/or multispectral 

imagery and video that may be translated into three-dimensional models of a surveyed area, 

electronic measurement with precision surveying, or any other gathering of data by instruments 

aboard the UAS. Ulysses believes this approval from the FAA will enhance the efficiency of all 

activities conducted and will provide multiple economic, environmental, and safety benefits

regarding these operations and alternative methods of data collection, and is therefore beneficial 

to the public’s interest. 

V/R,

Andrew Lewis, President

The Ulysses Group, LLC

87B S Market St.

Charleston, SC 29401