January 20, 2016

U.S. Department of Transportation

Docket Operations

West Building Ground Floor, Rm W12-140 1200 New Jersey Avenue, SE

Washington, DC 20590

REQUEST FOR SUMMARY GRANT OF EXEMPTION

Dear Sir or Madam,

I am applying for a Summary Grant of Exemption under Section 333 of the FAA Reform 

Act and Part 11 of the Federal Aviation Regulations from 14 CFR Part 21, Subpart H; 

14 CFR 45.23 (b); 14 CFR 61.101 (a)(2), (e)(1)(ii),(iv), (e)(2) - (8), (e)(12), (e)(14), (g); 

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 91.111; 14 CFR 91.119; 14 CFR 91.121; 14 CFR 91.151; 14 CFR 

91.203 (a), (b); 14 CFR 91.209; 14 CFR 91.405 (a), (b); 14 CFR 91.407 (a)(1); 14 CFR 

91.409 (a)(1)-(2); and 14 CFR 91.417 (a), (b); to allow commercial operation of Small 

Unmanned Aircraft Systems ("sUAS ") for aerial data collection. If this exemption 

request is granted, I plan to use the Yuneec Q500 Typhoon for aerial data collection 

including, but not limited to, remote sensing and measuring by instrument(s) aboard the 

sUAS to include imagery (photography, video, infrared, etc.), electronic measurement 

(precision surveying, RF analysis, etc.), and chemical measurement (particulate 

measurement, etc.). More specific mission and proposed operational use with Previous 

Grants of Exemption listed below.

APPLICANT:

Perry Gilland

152 Reid St., Roopville, Ga 30170

Ph: 770-842-6648

Email: perrygilland@gmail.com

UAS CERTIFICATE NUMBER: FA3WR9NXFM

YUNEEC Q500 “TYPHOON”

The UAS for the proposed use in the exemption is the YUNEEC Q500 “TYPHOON”

which has been a part of multiple previous Grants of Exemption including: 13120, 

12890, 13500, 12933, 13727. The link to the manufacturer’s owners/operators manual 

including specs, maintenance, proper operation and recommended safety procedures is 

included for reference. 

https://www.yuneec.com/download/manuals/Typhoon%20Q500%204k-

%20User%20Manual%20V12302015.pdf
FLIGHT TIME: Up to 25 Minutes

DIMENSIONS: 8.27 in (210mm) x 16.54 in (420mm)

DIAGONAL MOTOR TO MOTOR DISTANCE: 20 in (510mm)

PROPELLER/MAIN ROTOR DIAMETER: 13.0 in (330mm)

WEIGHT WITHOUT BATTERY AND PAYLOAD: 40.0 oz (1130g)

MAXIMUM TAKEOFF WEIGHT WITH CGO3: 60.0 oz (1700g)

BATTERY: 5400mAh 3S 11.1V LiPo 

CHARGER: 3S 11.1V LiPo DC Balancing Smart Charger with AC Adapter

TRANSMITTER: 10-channel 2.4GHz with 5.8GHz video downlink

MAXIMUM FLYING ALTITUDE: Default 400 Feet Above Ground Level 

MAXIMUM ROTATION RATE: 65°/s 

MAXIMUM ROLL ANGLE: 35° 

RADIO CONTROL FREQUENCY BAND: 2.4GHz

MAXIMUM CLIMB RATE: 2m/s

MAXIMUM DESCENT RATE: 3m/s

THE COMMERCIAL (MISSION/OPERATION) USE

FAA Previously Approved Exemption Numbers

The FAA has previously issued grants of exemption for aerial data collection in 

circumstances similar in all material respects to those I am petitioning for. In Grants of 

Exemption Nos. 11062 to Astraeus Aerial (see Docket No. FAA−2014−0352), 11109 to 

Clayco, Inc. (see Docket No. FAA−2014−0507), 11112 to VDOS Global, LLC (see 

Docket No. FAA−2014−0382), 11213 to Aeryon Labs, Inc. (see Docket No. 

FAA−2014−0642), and 12645 to Allied Drones (see Docket No. FAA-2014-0804). The 

FAA also has previous Grants of Exemption for the following forms of data collection 

which I am petitioning for:

1. Bridge Inspections: 11603, 11564, 11422, 11171

2. Flare stack inspection: 11251, 11581, 11241, 11156

3. Utility-power generation system inspections and patrolling: 11581, 11512, 11238, 

11467

4. Aerial inspection, photography and videography of residential and commercial real 

estate, weddings and wedding receptions: 11784, 11786, 11787, 11789

5. Aerial inspection, photography and videography of utility infrastructure including but 

not limited to electrical power lines, wind turbines and cell towers: 11787, 11512, 11581, 

11238

6. Pipeline inspection and patrolling: 11467, 11422, 11554, 11561, 11564

7. Filmmaking, cinematography, and videography: 11581, 11251, 11256, 11659

8. Precision agriculture with on board sensors: 11759, 11222, 11673, 11769

9. Wildlife and forestry monitoring and mosquito and insect control: 11684, 11648, 

11790, 11551

10. Aerial surveying: 11593, 11600, 11567, 11581

11. Construction site inspection and monitoring: 11591, 11508, 11535, 11469

12. Public entity support operations: 11471, 11426, 11412, 11389
13. Aerial imaging for safety, monitoring and comparing work efforts and completion 

percentages, and security of controlled environment of various sites: 11649, 11524, 

11522, 11481

14. Aerial video and live video feed to assist with search and rescue operations under 

the authority and support of local authority: 11327, 11282, 11558, 11842

15. Aerial video and photography for public and private use including television, public 

events, and cinematography live feed and live newsgathering: 11408, 11406, 11787, 

11760

16. Training to persons individually or belonging to both private and public organizations 

to increase awareness and improve safety for current and future UAS operations within 

the NAS: 11789, 11663, 11668

17. Special Events (including High Schools, Colleges, Professional Sports, open air and 

fairs): 11787, 11792, 11777, 11757

18. Research: 11424, 11389, 11370, 11368

19. Risk Management and Assessment: 11293, 11494, 11481, 11293

20. Disaster and Catastrophe events: 11309, 11487, 11370, 11327 11683

AIRCRAFT AND EQUIVALENT LEVEL OF SAFETY 

The applicant proposes that the exemption requested herein apply to civil aircraft that 

have the characteristics of sUAS and that operate with the limitations listed herein. 

These limitations provide for at least an equivalent or higher level of safety to operations 

under the current regulatory structure as the proposed operations represent a safety 

enhancement to the already safe aerial commercial photography and survey operations 

conducted with conventional aircraft. 

The Unmanned Aircraft (“UA”) planned to be operated is a rotorcraft, weighing 55 or 

fewer pounds including payload. It would operate at a speed of no more than 87 knots. 

Operations will be performed by a qualified PIC, as outlined below, to insure that the UA 

will “not create a hazard to users of the national airspace system or the public.” The UA 

will also carry no passengers or crew. Given the small size of the UA involved, and the 

pre-planned environment within which it will operate, the applicant believes that these 

operations fall squarely within that zone of safety (an equivalent level of safety) in which 

Congress envisioned that the FAA must, by exemption, allow commercial operations of 

UASs to commence immediately. Also, the operation of the sUAS will have no credible 

threat to national security. The operation of the UA by knowledgeable professionals with 

experience in the NAS will serve to enhance safety, add to the public benefit and reduce 

environmental impacts related to current methods of aerial photography and survey.

PUBLIC INTEREST

This exemption application will also 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 sUAS to operate 

with significant safety precautions in low risk environments.
The use of sUASs on or within a site or facility can significantly reduce the risk to 

workers of falls while inspecting, surveying, or monitoring site progress, facilities, or 

structures. UASs can inspect, photograph, and collect data on hard to get to areas that 

otherwise would require worker inspection or are inaccessible. Falls are the leading 

source of workplace fatality and injury on sites and reducing falls through sUAS use for 

site imaging could save workers lives.

Additionally, sUASs could replace the use of helicopters and small aircraft to monitor 

sites. The UA I propose to fly in this application is under 55 pounds, and carries no 

combustible material on board, as opposed to the much larger conventionally powered 

small aircraft. Shifting to a sUAS from helicopters or other aircraft presents a marked 

safety increase for workers and the public. The UA does not carry a crew or passengers 

that a conventional small aircraft does. The UAS, when compared to the operation of 

other small aircraft that are many hundreds of times heavier, carry highly flammable 

fuels and highly hazardous liquids, is a much safer choice due to the possible 

catastrophic results of an accident. 

Lastly, sUASs reduce the environmental impact by dramatically decreasing the energy 

used for aerial imaging and data collection over a site, facility, or structure. The 

proposed sUAS uses rechargeable lithium ion batteries, as opposed to fossil fuels 

burned in operation of other small aircraft which has a detrimental effect on the 

environment. The petitioner feels that the UAS operation enabled by this exemption is in 

the public’s interest. 

SAFETY FACTORS AND OPERATIONS PROPOSED

1. Prior to a sUAS flight, an area of operation will be established. This area of 

operation will include a defined lateral and vertical area, where the sUAS will 

operate. Safety procedures will be established for persons, property and 

applicable airspace within the area of operation.

2. Flights will be operated under visibility and cloud clearance requirements 

equivalent to Visual Flight Rules (VFR). 

3. Flight planning will include flight completion with at least 20% battery power 

remaining as measured by the sUAS or appropriate timing. 

4. The sUAS aircraft used will utilize GPS navigation, failsafe, return-to-home (RTH) 

and/or flight abort safety features.

5. All required permissions and permits will be obtained from appropriate state, 

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

appropriate governmental agencies.

6. Prior to each flight, the PIC will inspect the sUAS to ensure it is in a condition for 

safe flight. If the inspection reveals a condition that affects the safe operation of 

the sUAS, the sUAS will not be operated until the necessary maintenance has 

been performed and the sUAS is found to be in a condition for safe flight.

7. The Ground Control Station will be included in the preflight inspection. All 

maintenance and alterations will be properly documented in the aircraft records.

8. Any sUAS that has undergone maintenance or alterations that affect the sUAS 

operation or flight characteristics, e.g. replacement of a flight critical component, 
will undergo a functional test flight. The operator who conducts the functional test 

flight will make an entry in the aircraft records.

9. The operator will follow the sUAS manufacturer’s aircraft/component, 

maintenance, overhaul, replacement, inspection, and life limit requirements.

10.The sUAS operated under this exemption will comply with all manufacturer 

Safety Bulletins.

11.Operation near airports will be conducted according to the "blanket" COA unless 

another COA is obtained.

a. 5 nautical miles (NM) from an airport having an operational control tower; 

or

b. 3 NM from an airport with a published instrument flight procedure, but not 

an operational tower; or

c. 2 NM from an airport without a published instrument flight procedure or an 

operational tower; or

d. 2 NM from a heliport with a published instrument flight procedure 12. 

Maximum speed 50 knots.

12.The UAS will weigh less than 55 lbs. including payload. 

13.The UAS will operate under normal conditions at a speed of no more than 87 

knots. In no case will the UA be operated at airspeeds greater than the maximum 

UAS operating airspeed recommended by the aircraft manufacturer.

14.The sUAS will operate only in the PIC’s visual line of sight (VLOS) at all times.

15.The UAS will be operated at an altitude of no more than 400 feet above ground 

level (AGL).

Such operations will insure that the sUASs 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 listed in my application, the sUAS 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 sUASs to commence immediately. Also 

due to the small size of the UASs and the low altitudes and restricted areas in which my 

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, I respectfully 

request that the FAA grant the Summary Grant of Exemption, as the exemption would 

not set a precedent, and any delay in acting on this petition would be detrimental to the 

petitioner.

Exemptions Requested

The Operator generally requests exemption from the following regulations for the 

purpose of conducting commercial UAS operations within controlled airspace. 14 CFR 

Part 21, Subpart H; 14 CFR 45.23 (b); 14 CFR 61.101 (a)(2), (e)(1)(ii),(iv), (e)(2) - (8), 

(e)(12), (e)(14), (g); 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 91.111; 14 CFR 91.119; 14 CFR 91.121; 14 CFR 
91.151; 14 CFR 91.203 (a), (b); 14 CFR 91.209; 14 CFR 91.405 (a), (b); 14 CFR 91.407 

(a)(1); 14 CFR 91.409 (a)(1)-(2); and 14 CFR 91.417 (a), (b).

The Operator specifically requests relief from the following regulations and in such 

capacity as depicted below:

14 CFR part 21 Subpart H - Certification procedures for products and parts, 

Subpart H— Airworthiness Certificates.

In accordance with the statutory criteria provided in Section 333 of Public Law 112−95 

in reference to 49 U.S.C. 44704, and in consideration of the size, weight, speed, and 

limited operating area associated with the UAS and its operation, the Operator requests 

exemption from 14 CFR part 21, Certification procedures for products and parts, 

Subpart H—Airworthiness Certificates, and any associated noise certification and 

testing requirements of part 36. 14 CFR Part 21 Subpart H meets the requirements of 

an equivalent level of safety under Part 11 and Section 333 of the FMRA. The Federal 

Aviation Act (49 U.S.C.§ 44701(f)) and Section 333 of the FMRA 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 particular UAS. In all cases, an analysis of these criteria 

demonstrates that the UAS operated without an airworthiness certificate, in the 

restricted environment and under the conditions proposed will be at least as safe, or 

safer, than a conventional aircraft operating with an airworthiness certificate without the 

restrictions and conditions proposed.

14 CFR 45.23 (b) – Display of marks; General.

This regulation requires that aircraft display proper registration markings as required by 

aviation authority. 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. The Operator’s UAS has no entrance to 

the cabin, cockpit, or pilot station on which the markings can be placed, two inch 

lettering would not be possible. Operator to mark the UAS with UAS Certificate Number

registration markings as large as practical to be displayed on the top of the UA.

14 CFR 61.101 (a)(2), (e)(1)(ii),(iv), (e)(2) - (8), (e)(12), (e)(14), (g) - Recreational pilot 

privileges and limitations.

The Operator specifically request exemption from the aforementioned regulations of 14 

CFR

61.101. This regulation prohibits recreational pilots from performing duties as a pilot for 

compensation or hire or aircraft with more than one power plant, retractable landing 

gear, carrying persons or property, in furtherance of a business or within class A, B, C 

or D airspace. The Operator proposes to utilize a pilot in command (PIC) with a 

minimum of a sport pilot certificate. The proposed operations can achieve an equivalent 

level of safety of current operations by requiring the PIC operating the UAS to have a 

minimum of a sport pilot’s certificate rather than a commercial pilot’s certificate to 

operate the UAS proposed to be utilized in this operation. Flights which are proposed to 

be conducted by the Operator within controlled airspace will be conducted only having 

received prior approval from the local FSDO and/or the local airspace controlling 
agency, (ATC) in which operations are proposed to be conducted and if applicable the 

appropriate airport manager or owner. The Operator will also publish NOTAM advisories

a minimum of 24 hours prior to conducting operations within controlled airspace or as 

requested by FSDO. All PIC shall meet the requirements of 14 CFR 61.97 prior to 

conducting operations for the Operator as PIC.

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

This regulation prohibits a person which holds a private pilot certificate from operating 

any aircraft as pilot in command (PIC) for compensation or for hire. This regulation also 

prohibits a private pilot from conducting operations which involves carriage of persons 

or property for hire. The UAS platform is not capable of carrying a pilot or persons 

onboard the aircraft. The proposed operations can achieve an equivalent level of safety 

of current operations by requiring the PIC operating the UAS to have a minimum of a 

sport pilot’s certificate rather than a commercial pilot’s certificate to operate this UAS. 

Operator specifically requests exemption from this regulation so that the Operator may 

conduct operations using UAS for hire and in the carriage of property or equipment.

14 C.F.R. 91.7 (a), (b): Civil aircraft airworthiness

This regulation requires that no person may operate a civil aircraft unless it is in 

airworthy condition. As the UAS has no airworthiness certificate issued for the aircraft, 

should this exemption be granted, no FAA regulatory standard will exist for determining 

airworthiness. An equivalent level of safety will be provided by the small size of the UAV 

and the requirements contained in the manufacturer instructions for maintenance and 

use of safety check lists prior to each flight. The Operator will ensure that the UAS is in 

an airworthy condition prior to each flight based on compliance with the specifications in 

the manufacturer instructions.

14 CFR 91.9 (b) (2) - Civil aircraft flight manual, marking, and placard 

requirements.

This regulation requires that an aircraft flight manual be carried upon the aircraft while in 

flight. With the operational limitations of the UAS and the unmanned nature of its 

operation, it is not practical to carry a flight manual onboard the aircraft while it is in 

operation. The Operator shall familiarize him/herself with the operational manual of the 

UAS prior to performing operations as the PIC. Additionally, the PIC shall have access 

to the manufacturer’s operational manual (OM) while operating the UAS. The UAS 

operated by the Operator will be identified by serial number, registered in accordance 

with 14 CFR part 47, and have identification markings in accordance with 14 CFR part 

45, Subpart C. Markings will be as large as practicable.

14 CFR 91.103 - Preflight action.

The Operator only seeks to obtain exclusion from this regulation as to an FAA approved 

operational or flight manual for the UAS. UAS equipment is not approved as an airframe 

under 14 CFR Parts 23 or 25 certification and as such no FAA approved flight 

operations manual is published. The Operator will utilize the UAS manufacturer 

operators’ manuals (OM), policies and procedures developed by the manufacturer for 

operation of the UAS. Additionally, the Operator will conduct preflight activity to include 

but not necessarily limited to determine among other items, current and forecast 

weather conditions, wind, temperature, performance calculations for take-off and 

landing, runway distances, power source requirements, facilities at intended airports 

and/or areas of operation.
14 C.F.R. 91.109: Flight instruction.

This regulation provides 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. By their design, UAS and remotely piloted aircraft do not have 

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

electronic control that communicates with the aircraft via radio telemetry 

communications. The FAA has approved exemptions for flight training without fully 

functional dual controls for a number of aircraft and for flight instruction in experimental 

aircraft. See Exemption Nos. 5778K and 9862A. The equivalent level of safety provided 

by the fact that neither a pilot nor passengers will be carried in the aircraft and by the 

size and speed of the aircraft. As such, the Operator requests relief from this regulation 

as described in this request for exemption and IAW its proposed order of operations.

14 CFR 91.111 - Operating near other aircraft.

Operator specifically requests exemption from this regulation so that the Operator may 

conduct controlled formation flight operations with multiple UAS and or manned aircraft. 

From time to time the Operator may utilize more than one UAS or manned aircraft 

designated as a chase or visual observer aircraft in effort to conduct its operations. The 

Operator will only conduct such operations within controlled airspace after having 

received written approval from the local FSDO, local controlling airspace agency in 

which operations are proposed to be conducted and if applicable the appropriate airport 

manager or owner. The Operator will also publish NOTAM advisories a minimum of 24 

hours prior to conducting operations within controlled airspace or as requested by 

FSDO.

14 C.F.R. 91.119: Minimum safe altitudes.

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

allows helicopters to be operated at less than the minimums prescribed, provided the 

person operating the helicopter complies with any route or altitudes prescribed for 

helicopters by the FAA. As this exemption is for UAS that are similar to helicopters, and 

the exemption requests authority to operate at altitudes up to and including 400 AGL, an 

exemption may be needed to allow such operations. The UAS platform will not be 

operated higher than 400 AGL without prior written authorization on a case-by-case 

basis from the local FSDO or ATC airspace controlling agency responsible for the 

airspace in which operations are proposed to be conducted. Additionally, the Operator 

will also publish NOTAM advisories a minimum of 24 hours prior to conducting 

operations within controlled airspace or as requested by FSDO. An equivalent level of 

safety will be achieved given the size, weight, speed of the UAS platform as well as the 

locations where they are operated. The low-altitude operations of the UAS platform will 

ensure separation between the UAS operations and the operations of conventional 

manned aircraft that must comply with Section 91.119.

14 C.F.R. 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 UAS platform may not 

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

required. An equivalent level of safety will be achieved by the operator, pursuant to the 

SOP and manufacturer instructions, the PIC shall confirm the altitude of the launch site 
shown on the GPS altitude indicator before flight with topographical maps, sectional 

charting or published airport elevation designations.

14 C.F.R. 91.151: Fuel Requirements for Flight in VFR Conditions.

This regulation prohibits an individual from beginning “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.” Given the limitations on the proposed operations areas, a 

longer time frame for VFR conditions is reasonable. Applicant 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 14 C.F.R. 91.151 (a)). Operating the 

UAS platform in controlled operations does not engender the type of risks that Section 

91.151(a) was intended to alleviate given the size and speed of the UAS platform. The 

UAS platform does not utilize fuel either liquid or solid format. Similar exemptions have 

been granted to other operations, including Exemptions 2689F, 5745, 10673, and 

10808. The Operator proposes to terminate flight operations when indication form the 

UAS controller is received showing 20% battery life is remaining.

14 C.F.R. 91.203 (a) and (b): Carrying Civil Aircraft Certification and Registration.

The FAA has previously determined that no airworthiness certification is necessary for 

UAS platforms. See, e.g., Exemption No. 11110. The Operator therefore believes that 

no exemption is necessary from 91.203. However, to the extent that the FAA finds that 

section 91.203 is applicable to the Operator’s operations, the Operator requests an 

exemption therefrom. The regulation provides in pertinent part: (a) except as provided in 

14 CFR 91.715, no person may operate a civil aircraft unless it has within it the 

following: (1) 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 14 CFR 91.715 is displayed at 

the cabin or cockpit entrance so that it is legible to passengers or crew.

The UAS platform weighs no more than 55 pounds fully loaded, and are operated 

without an onboard pilot. As such, there is no ability or place to carry certification and 

registration documents or to display them on the UAS. An equivalent level of safety will 

be achieved by keeping these documents at the ground control point where the 

Operator will have immediate access to them, to the extent they are applicable to the 

UAS. The FAA has issued numerous exemptions to this regulation. A representative 

sample of other exceptions includes Exemption Nos. 9565, 9665, 9789, 9789A, 9797, 

9797A, 9816A, and 10700. Based on the limited size, weight, operating conditions, 

design safety features, and the imposed conditions and limitations, Operator has 

determined that its operations would not adversely affect safety compared to similar 

operations conducted with aircraft that have been issued an airworthiness certificate 

under 14 CFR part 21, Subpart H. Therefore, as the FAA found for similar exemptions 

(See Exemption 11110), the Operator believes that the requested relief from 14 CFR 

Part 21, and 14 CFR 91.203 (a), (b) and any associated noise certification and testing 

requirements of part 36, should be granted.

14 CFR 91.209 Aircraft lights.
This regulation states that no person may, during the period from sunset to sunrise 

operate an aircraft unless it has lighted position lights. Additionally, no person may 

operate an aircraft that is equipped with an anti-collision light system, unless it has 

lighted anti-collision lights. However, the anti-collision lights need not be operated when 

the pilot-in-command determines that, because of operating conditions, it would be in 

the interest of safety to turn the lights off. The Operator specifically requests exemption 

from this regulation on a case-by-case basis, as approved by the local FSDO, in order 

to perform covert investigations in concert with a licensed private investigation agency a 

United States law enforcement agency and/or as directed by United States 

governmental directive. The Operator will not conduct operations without prior written 

consent from the local FSDO or ATC airspace controlling agency responsible for the 

airspace in which operations are proposed to be conducted. Additionally, the Operator 

will also publish NOTAM advisories a minimum of 24 hours prior to conducting 

operations within controlled airspace or as requested by FSDO. An equivalent level of 

safety will be achieved given the size, weight, speed of the UAS platform as well as the 

locations where they are operated. The low-altitude operations of the UAS platform will 

ensure separation between the UAS operations and the operations of conventional 

manned aircraft that must comply with Section 91.119 and 14 CFR 91.209.

14 C.F.R. 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 section and Part 43 apply only to aircraft 

with an airworthiness certificate, these sections will not apply to the Operator. 

Maintenance will be accomplished by the Operator pursuant to the manufacturer 

instructions. An equivalent level of safety will be achieved because the UAS are limited 

in size, carry a small payload, and will operate only in defined operations areas for 

limited periods of time. If mechanical issues arise the UAS platform can land 

immediately and will be operating from no greater than 400 feet AGL. As provided in the 

manufacturer instructions, the Operator will ensure that the UAS is in working order 

prior to initiating flight, perform required maintenance, and will keep a log of any 

maintenance performed. Moreover, the Operator 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.

SUMMARY OF PETITION

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

Act) and 14 C.F.R. Part 11, I plan on using the afore mentioned sUASs for capturing 

data. I hereby respectfully request an exemption from the listed Federal Aviation 

Regulations (“FARs”) to allow commercial operation of the sUASs for aerial imaging for 

data capture, so long as such operations are conducted within and under the conditions 

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

Approval of this exemption would thereby enhance safety and fulfill the Secretary of 

Transportation’s (the FAA Administrator’s) responsibilities to “...establish requirements 
for the safe operation of such aircraft systems in the national airspace system.” Section 

333(c) of the Reform Act.

Sincerely,

Perry Gilland