1

BEFORE THE 

FEDERAL AVIATION ADMINISTRATION

Juniper Unmanned, Inc., Petitioner

Docket No. FAA-2015-________

JUNIPER UNMANNED, INC.

FOR AN EXEMPTION FROM CERTAIN FEDERAL AVIATION REGULATIONS

TO PERMIT UNMANNED AIRCRAFT SYSTEMS (UAS) OPERATIONS

Jeff Cozart

3490 Parfet Street

Wheat Ridge, Colorado 80033

Phone: 303-907-6163

Jeff.cozart@juniperunmanned.com

DATE: April 30, 2015
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Contents

1. BACKGROUND INFORMATION: THE PETITIONER....................................................................................3

2. PROPOSED UAS OPERATIONS: THE EXEMPTION REQUEST ....................................................................3

3. PROPOSED CONDITIONS AND LIMITATIONS...........................................................................................3

3.1 Conditions and limitations regarding the proposed UAS Juniper Unmanned intends to operate 

the small Sirius UAS under the requested exemption............................................................................4

3.2 Conditions and limitations regarding the proposed UAS operations. .............................................4

3.3 Conditions and limitations regarding the Pilot in Command and other crewmember 

qualifications and training. ......................................................................................................................8

3.4 Conditions and limitations regarding Juniper Unmanned manuals related to UAS operations.....9

4. REQUEST FOR DETERMINATION UNDER SECTION 333 OF FMRA.........................................................10

5. INFORMATION REQUIRED BY 14 C.F.R. § 11.81 TO SUPPORT A PETITION FOR EXEMPTION..............11

5.1 Contact information:........................................................................................................................11

5.2 The specific section or sections of the FAR from which Juniper Unmanned seeks an exemption:

................................................................................................................................................................11

5.3 The extent of relief sought and the reason relief is sought:...........................................................11

5.4 Reasons why granting the request would be in the public interest:..............................................23

5.5 Reasons why granting the exemption would not adversely affect safety, or how the exemption 

would provide a level of safety at least equal to that provided by the rule from which exemption is 

sought:....................................................................................................................................................24

5.6 Summary that can be published in Federal Register, including the rule from which exemption is 

sought, a brief description of the nature of the exemption sought:....................................................25

5.7 Additional information that supports request:...............................................................................25

5.8 Request to exercise the privileges of the exemption outside the U.S.: .........................................25

5.9 Attachments:....................................................................................................................................25

6. CONCLUSION ..........................................................................................................................................26
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1. BACKGROUND INFORMATION: THE PETITIONER

Juniper Unmanned, Inc. located in Denver, Colorado, supports the aviation and remote sensing 

operations of Unmanned Aircraft operators. Juniper Unmanned develops training, standardization, and 

sustainment programs in partnership with several designers and developers of Unmanned Aircraft 

Systems, supporting their clients and customers with expertise in the safe and effective use of UAS. 

Juniper recently began supporting operators of the Sirius Basic and Sirius Pro (collectively, “Sirius UAS”) 

for mapping a wide range of sites, land surveying, and facility inspections, as well as use in mining, 

construction, and agriculture.

2. PROPOSED UAS OPERATIONS: THE EXEMPTION REQUEST

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (“FMRA”) and 14 C.F.R. 

(“FAR”) §§ 11.61(b), 11.63(a), and 11.81, Juniper Unmanned requests that the FAA grant an exemption 

from certain sections of the FAR (detailed below) so that Juniper Unmanned may commercially operate 

one or more small Sirius UAS for aerial surveying, product demonstration flights for potential customers, 

UAS product training for customers, and research and development for future product improvements 

related to these small UAS. As explained below, Juniper Unmanned’s proposed UAS operations, as 

conditioned and limited herein, will not adversely affect safety, but rather will provide an equivalent or 

greater level of safety than that provided by the current rules and large manned aircraft operations. See 

FAR § 11.81.

3. PROPOSED CONDITIONS AND LIMITATIONS

The small UAS operations proposed in this Petition will be subject to the following conditions and 

limitations. Each of these conditions and limitations is consistent with previously granted small UAS 

Section 333 exemptions and FAA guidance. See, e.g., Exemption No. 11110 (December 10, 2014; Docket 

FAA-2014-0367) (“Trimble Exemption”); Exemption No. 11062 (September 25, 2014; Docket FAA-2014-

0352) (“Astraeus Exemption”); Exemption No. 11109 (December 10, 2014; Docket FAA-2014-0507) 

(“Clayco Exemption”); Exemption No. 11136 (January 5, 2015; Docket FAA-2014-0508) (“AAS 

Exemption”). Collectively, these conditions and limitations ensure that the proposed small UAS 

operations will not adversely affect safety and will provide at least an equivalent level of safety to the 

current rules and large manned aircraft operations.
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3.1 Conditions and limitations regarding the proposed UAS Juniper Unmanned intends to operate the 

small Sirius UAS under the requested exemption.

The Sirius UAS uses a battery-powered, single electric brushless 680 W motor system and a single 

propeller. Its payload is a Panasonic GX1 camera or the FUJIFILM X-M1; its navigation system is GPS/IMU 

aided; and it has three available flight modes – automatic, autopilot-assisted, and full manual. Each 

Sirius UAS operated under the exemption will be subject to the following conditions and limitations:

3.1.1 Operations under the exemption will be limited to the Sirius UAS. The free-flying 

unmanned aircraft part of the Sirius UAS (“the UA”) will have a gross weight of not more 

than 7 pounds, including energy sources, equipment, and payload. [Trimble Exemption 

Limitation No. 1.]

3.1.2 The UA has maximum dimensions of approximately 48 inches (l) x 65 inches (w) x 12.2 

inches.

3.1.3 The UA will have a maximum ground speed of 70 knots indicated airspeed. It has a 

typical cruise speed of 35 knots indicated air speed. [Trimble Exemption Limitation No. 

2.]

3.1.4 The UA will have a maximum total flight time of 45 minutes.

3.1.5 The UA will be identified by its serial number and registered with the FAA in accordance 

with FAR Part 47. [Trimble Exemption Limitation No. 21.]

3.1.6 The UA will have identification markings in accordance with FAR Part 45, with the 

markings being as large as practicable. [Trimble Exemption Limitation No. 21.]

3.2 Conditions and limitations regarding the proposed UAS operations. 

All UAS operations under the exemption will be subject to the following conditions and limitations:

3.2.1 All UAS operations will be covered by an Air Traffic Organization (“ATO”)-issued 

Certificate of Waiver or Authorization (“COA”). This COA will require that Juniper 

Unmanned request a Notice to Airman (“NOTAM”) not more than 72 hours in advance 

of, nor less than 48 hours prior to, each UAS operation. [Trimble Exemption Limitation 

No. 20.]

3.2.2 The UA will operate only in Class G airspace. [Trimble Exemption Limitation No. 27.] It 

will not operate in Class B, C or D airspace without written approval from the FAA.

[Astraeus Exemption Limitation No. 34.]

3.2.3 The UA will not operate within 5 nautical miles of the geographic center of a nontowered airport as denoted on a current FAA-published aeronautical chart unless a 

letter agreement with the airport’s management is obtained, and the operation is 
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conducted in accordance with a NOTAM as required by Juniper Unmanned’ COA. 

Juniper Unmanned will make this letter agreement available to the FAA upon request. 

[Astraeus Exemption Limitation No. 34.]

3.2.4 Each UA will remain at least 3 nautical miles from any public towered airport to the 

extent possible.

3.2.5 Prior to each UAS operation in which the UA will operate within 3 nautical miles of a 

public towered airport, the PIC will ensure that the FAA Air Traffic Control officials with 

responsibility for that airport are notified in advance of the UAS operation; that, subject 

to the airport’s and ATC’s agreement, the PIC will maintain two-way radio 

communications with the airport’s ATC tower facility during such flight operations; and 

that the operation is conducted in accordance with a NOTAM as required by Juniper 

Unmanned’ COA.

3.2.6 Prior to UAS operations, the radio frequency spectrum used for operation and control of 

the UA (2.4 GHz) will comply with Federal Communications Commission (FCC) and other 

appropriate government oversight agency requirements. [Trimble Exemption Limitation 

No. 22.]

3.2.7 The minimum crew for each UAS operation will consist of one Pilot in Command (“PIC”) 

and one Ground Observer (“GO”). The PIC will be designated before the flight and 

cannot transfer his/her designation for the duration of the flight. The PIC must ensure 

that he maintains positive control of the Hand Control Unit (“HCU”) and can monitor the 

system reports displayed on the MAVinci Desktop as outlined by the Operator’s Manual. 

[Trimble Exemption Limitations Nos. 4 and 5.]

3.2.8 The UA will be operated within visual line of sight (“VLOS”) of the PIC at all times. The 

VLOS will be unaided, except for corrective lenses as set forth on the PIC’s FAA-issued 

airman medical certificate. The GO may be used to satisfy the VLOS requirement as long 

as the PIC always maintains VLOS capability. [Trimble Exemption Limitations Nos. 4 and 

5.]

3.2.9 During each UAS operation, the PIC and the GO must be able to communicate verbally 

with each other at all times. [Trimble Exemption Limitation No. 5.]

3.2.10 The PIC is prohibited from beginning a UAS flight unless (considering wind and forecast 

weather conditions) there is enough power to fly at normal cruising speed to the 

intended landing point and land the UA with at least 30% battery power remaining. [AAS 

Exemption Limitation No. 22.]

3.2.11 Prior to each UAS operation, each member of the crew who will be conducting the UAS 

operation will participate in a combined mission, risk assessment and safety briefing 
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about the UAS operation, as outlined in Juniper’s SOP, and the crew will complete the 

UA preflight inspection and preflight checklist per the Operator’s Manual.

3.2.12 Prior to each UAS operation, the PIC will inspect the UAS (including the Ground Control 

Station) to ensure it is in a condition for safe flight. If the inspection reveals a condition 

that affects the safe operation of the UAS, the UAS is prohibited from operating until the 

necessary maintenance has been performed and documented, and the UAS is found to 

be in a condition for safe flight. [Trimble Exemption Limitation No. 7.]

3.2.13 Prior to each UAS operation, the PIC will review the weather, the UAS battery 

requirements, the UA takeoff and landing distances, and the UAS performance, and will 

account for all relevant site-specific conditions per Juniper’s SOP.

3.2.14 All maintenance and alterations will be properly documented in the UA records. 

[Trimble Exemption Limitation No. 7.] Juniper Unmanned’ Sirius UAS maintenance 

personnel will make a record entry in the UAS Maintenance log (JU-2-M, Juniper SOP 

Appendix #) [Trimble Exemption Limitation No. 14.]

3.2.15 Prior to each UAS flight, a zero altitude initiation point will be established and confirmed 

for accuracy by the PIC. [Astraeus Exemption, at 21; AAS Exemption, at 17.]

3.2.16 During each UAS operation, the UA will remain at or below 400 feet above ground level 

(“AGL”). [Trimble Exemption Limitation No. 3.]

3.2.17 All UAS operations will be conducted over private or controlled-access property with 

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

from the land owner/controller or authorized representative will be obtained for each 

flight to be conducted. [Trimble Exemption Limitation No. 34.]

3.2.18 The UA will operate at least 500 feet from all non-participating persons, vessels, 

vehicles, and structures unless:

(a) Barriers or structures are present that sufficiently protect nonparticipating persons 

from the UA and/or debris in the event of an accident. Juniper Unmanned must ensure 

that non-participating persons remain under such protection; and if a situation arises 

where non-participating persons leave such protection and are within 500 feet of the 

UA, flight operations will cease immediately; and/or

(b) The UA is operated near vessels, vehicles or structures where the land 

owner/controller has granted permission and the PIC has made a safety assessment of 

the risk of operating closer to those objects and determined that it does not present an 

undue hazard. [AAS Exemption Limitation No. 30.]

3.2.19 Operations of the UA may be conducted at distances less than 500 feet from 

participating persons, vessels, vehicles or structures that perform an essential function 
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in connection with these special purpose operations or are otherwise necessary for such 

operations. Operations closer than 500 feet from the PIC, GO, operator trainees, 

essential persons, and potential customers are permitted when operationally necessary, 

but never so close as to present an undue hazard, per FAR.

3.2.20 All UAS operations will take place during visual meteorological conditions (VMC) only. 

[Trimble Exemption Limitation No. 28.]

3.2.21 Juniper Unmanned will not operate UAS flights under Special Visual Flight Rules (SVFR). 

[Astraeus Exemption Limitation No. 31.]

3.2.22 All UAS operations will take place during daylight hours. UAS operations will not be 

conducted during night, as defined in FAR § 1.1. [Trimble Exemption Limitation No. 26.]

3.2.23 During each UAS operation, the UA will avoid, remain clear of, and yield right-of-way to 

all manned aerial operations and activities (including, but not limited to, ultralight 

vehicle, parachute, parasailing, and hang glider activities). [Trimble Exemption 

Limitation No. 24.]

3.2.24 Each UAS operation will maintain a safe distance from any structure or facility that has a 

national security implication that is known to Juniper Unmanned and whose airspace is 

identified as Special Use Airspace on the most recent Sectional Map.

3.2.25 The UA will not be operated less than 500 feet below or less than 2,000 feet horizontally 

from a cloud, or when visibility is less than 3 statute miles from the PIC. [Trimble 

Exemption Limitation No. 28.]

3.2.26 The UAS will not be operated by the PIC from a moving device or vehicle. [Trimble 

Exemption Limitation No. 25.]

3.2.27 Any UAS that has undergone maintenance or alterations that affect the UAS operation 

or UA flight characteristics (e.g., replacement of a flight critical component) must 

undergo a functional maintenance test flight in accordance with the Operator’s Manual.

3.2.28 The PIC who conducts the functional maintenance test flight will make an entry about 

the flight in the UA records. [Trimble Exemption Limitation No. 8.]

3.2.29 For each UAS operation, the UAS will be programmed so that if the UAS loses its 

communications, the UA will return to a pre-determined location within the private or 

controlled-access property, and land or be recovered in accordance with the Operator’s 

Manual. [Trimble Exemption Limitation No. 17.] For each UAS operation, the UAS will be 

programmed so that if the UAS loses its GPS signal, the UA will circle down at its current 

location or will circle in its then-current position at its established safety altitude in 

accordance with the Operator’s Manual. These actions are part of the Sirius UAS’ Lost 

Link Procedures. Alternatively, the PIC can take over control of the UA using the RC 
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controller and execute safe landing procedures in accordance with the Operator’s 

Manual.

3.2.30 The PIC will adhere to the written emergency procedures in the Manuals and suspend 

the UAS operation and UA flight in the event of unpredicted obstacles or emergencies in 

accordance with the Operator’s Manual. [Trimble Exemption Limitation No. 18.]

3.2.31 The documents required by FAR §§ 91.9 and 91.203 (listed in Juniper’s SOP) will be 

available to the PIC at the Ground Control Station of the UAS at any time the UA is 

operating, and will be made available to the FAA or any law enforcement official upon 

request. [Trimble Exemption Limitation No. 23.]

3.2.32 The UA may not be operated over congested or densely populated areas. These areas 

include but are not limited to the yellow areas depicted on World Aeronautical Charts 

(WAC), Sectional Aeronautical Charts (Sectionals), or Terminal Area Charts (TAC). 

However, aeronautical charts may not reflect pertinent local information. It will be the 

PIC’s responsibility to maintain the minimum safe altitudes required by FAR § 91.119 

(subject to an exemption granted herein). [Trimble Exemption Limitation No. 30.] 

3.2.33 Any incident, accident or flight operation that transgresses the lateral or vertical 

boundaries of the operational area as defined by the applicable COA will be reported to 

the FAA’s UAS Integration Office (AFS-80) within 24 hours. Accidents will be reported to 

the National Transportation Safety Board (“NTSB”) per instructions contained on the

NTSB website. [Trimble Exemption Limitation No. 35.]

3.3 Conditions and limitations regarding the Pilot in Command and other crewmember qualifications 

and training. 

The PIC and other crewmembers for each UAS operation under the requested exemption will be subject 

to the following conditions and limitations:

3.3.1 The PIC will possess at least an FAA private pilot certificate and a third class airman 

medical certificate under the following conditions: The PIC also will satisfy the flight 

review requirements of FAR § 61.56 in an aircraft for which the PIC is rated on his or her 

pilot certificate. [Trimble Exemption Limitation No. 15] 8900.1 chapter 16 

3.3.2 The PIC and GO will have successfully completed the manufacturer’s authorized training 

for the Sirius UAS.

3.3.3 Each PIC will have demonstrated through the manufacturer’s authorized training 

program that he or she is able to safely operate the UAS in a manner consistent with 

how the UAS will be operated under the exemption, including evasive and emergency 

maneuvers and maintaining appropriate distances from persons, vessels, vehicles, and 

structures. Juniper Unmanned must document and make a record of such training and 
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make such documentation available upon request by the FAA. Flights for the purposes 

of training Juniper Unmanned’ PICs and GOs (training, proficiency, and experiencebuilding) are permitted under the terms of this exemption. Said training operations, 

however, may only be conducted during dedicated training sessions. [AAS Exemption 

Limitation No. 15.]

3.3.4 Juniper Unmanned will not permit any PIC to operate its Sirius UAS unless that PIC has 

demonstrated through Juniper’s training and currency requirements (as defined in 

Juniper’s SOP) that he or she is able to safely operate the UAS in accordance with 

Limitation No. 3.3.3. [Clayco Exemption Limitation No. 16.]

3.4 Conditions and limitations regarding Juniper Unmanned manuals related to UAS operations.

Juniper Unmanned has two manuals containing procedures for the UAS operations under the 

exemption: the Sirius Aerial Image UAS & MAVinci Desktop Manual Aircraft Flight Manual (“AFM”, 

Operator’s Manual) and the Juniper Unmanned Standard Operating Procedure’s (“SOP”) (collectively, 

“the Manuals”). A confidential copy of each of the Manuals will be submitted to the FAA Assistant Chief 

Counsel for International Law, Legislation, and Regulations as supporting documentation for this 

Petition. The Manuals contain information that is highly proprietary to Juniper Unmanned and/or 

MAVinci, and Juniper Unmanned requests that the FAA treat the Manuals as confidential and not 

disclose them to the public. The Manuals will be subject to the following limitations and conditions:

3.4.1 The Manuals and the exemption must be maintained and made available to the FAA 

upon request. If a discrepancy exists between the conditions and limitations in the 

exemption and the procedures outlined in the Manuals, the conditions and limitations 

in the exemption take precedence and must be followed. Otherwise, Juniper Unmanned

must follow the procedures as outlined in the Manuals. [Trimble Exemption Limitation 

No. 6.]

3.4.2 Juniper Unmanned may update or revise its Manuals, and it is Juniper Unmanned’ 

responsibility to track such revisions and present updated and revised documents to the 

FAA upon request. Juniper Unmanned must also present updated and revised 

documents if it petitions for an extension or amendment of the exemption. If Juniper 

Unmanned determines that any update or revision would affect the basis upon which 

the FAA granted the requested exemption, then Juniper Unmanned must petition for an 

amendment to the exemption. Juniper Unmanned will contact the FAA’s UAS 

Integration Office (AFS-80) if questions arise regarding updates or revisions to the 

Manuals. [Trimble Exemption Limitation No. 6.]

3.4.3 The Manuals contain information about the Sirius UAS’ performance and limitations.
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3.4.4 The Manuals contain the procedures for UAS operations, including preflight inspections, 

which will account for all discrepancies, i.e., inoperable components, items or 

equipment. [Trimble Exemption Limitation No. 9.]

3.4.5 The Manuals contain the requirements and procedures for a functional maintenance 

test flight of the UAS and aircraft record entry. [Trimble Exemption Limitation No. 8.]

3.4.6 Juniper Unmanned must carry out its maintenance, inspections, and record keeping 

requirements in accordance with the Manuals. Maintenance, inspection, and alterations 

must be noted in the aircraft logbook, including total flight hours, description of work 

accomplished, and the signature of the authorized Sirius UAS maintenance personnel

returning the Sirius UAS to service. [Trimble Exemption Limitation No. 11.]

3.4.7 The Sirius UAS maintenance personnel maintaining and servicing Juniper Unmanned’ 

UAS must receive, and document, the training called for in the Manuals. [Trimble 

Exemption Limitation No. 12.]

3.4.8 Each UAS operated under the exemption will comply with all manufacturer System and 

Safety Bulletins, and that requirement is set forth in the Manuals. [Trimble Exemption 

Limitation No. 13.] Juniper Unmanned will maintain copies of all manufacturer System 

and Safety Bulletins, and will make them available to the FAA upon request.

3.4.9 Juniper Unmanned will follow the manufacturer’s UAS aircraft/component, 

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

Exemption Limitation No. 10.]

3.4.10 The Manuals contain procedures for performing and documenting of maintenance, 

preventive maintenance, alterations, status of replacement/overhaul component parts, 

and the total time in service of the UAS (and for maintaining the corresponding records).

4. REQUEST FOR DETERMINATION UNDER SECTION 333 OF FMRA

In accordance with FMRA Sec. 333, Juniper Unmanned requests that the Secretary of Transportation 

determine that Juniper Unmanned’ proposed small UAS operations (i) do not create a hazard to users of 

the National Airspace System or the public, and (ii) do not pose a threat to national security. Juniper 

Unmanned further requests that, based on the Secretary’s determination, the FAA determine – as it did 

in the Astraeus Exemption, Clayco Exemption, and AAS Exemption – that relief from FAR Part 21 and any 

associated noise certification and testing requirements of FAR Part 36 is not necessary for the UAS 

operations proposed in this Petition.1

1Astraeus Exemption, at 14, 22; Clayco Exemption, at 10, 16; AAS Exemption, at 12, 18. If the FAA concludes that the UAS 

operations proposed in this Petition require an exemption from FAR Parts 21 and/or 36, then TPS requests that the FAA 

include that in the exemption.
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5. INFORMATION REQUIRED BY 14 C.F.R. § 11.81 TO SUPPORT A PETITION FOR EXEMPTION

As required by FAR § 11.81, Juniper Unmanned provides the following information in support of this 

Petition:

5.1 Contact information:

Name: Juniper Unmanned, Inc.

Mailing address: Jeff Cozart 3490 

3490 Parfet Street

Wheat Ridge, Colorado 80033

Telephone: 303-907-6163

Email: jeff.cozart@juniperunmanned.com

5.2 The specific section or sections of the FAR from which Juniper Unmanned seeks an exemption:

FAR § 61.113(a) and (b) – Private pilot privileges and limitations: Pilot in command.

FAR § 91.7(a) – Civil aircraft airworthiness.

FAR § 91.119(b) and (c) – Minimum safe altitudes: General.

FAR § 91.121 – Altimeter settings.

FAR § 91.151 – Fuel requirements for flight in VFR conditions.

FAR § 91.405(a) – Maintenance required.

FAR § 91.407(a)(1) – Operation after maintenance, preventive maintenance, rebuilding, and 

inspections.

FAR § 91.409(a)(1) and (2) – Inspections.

FAR § 91.417(a) and (b) – Maintenance records.

5.3 The extent of relief sought and the reason relief is sought:

Juniper Unmanned proposes to conduct small UAS operations, as described herein, for aerial surveying,

product demonstration flights for potential customers, UAS product training for customers, and

research and development for future product improvements related to these small UAS. In order to be 

able to conduct these UAS operations, Juniper Unmanned petitions the FAA, pursuant to FAR §§ 

11.61(b), 11.63(a), and 11.81(b), for an exemption from the following FAR for the reasons noted:

FAR § 61.113(a) and (b) – Private pilot privileges and limitations: Pilot in command. The 

regulation states, in relevant part:
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(a) Except as provided in paragraphs (b) through (h) of this section, no person who holds 

a private pilot certificate may act as pilot in command of an aircraft that is carrying 

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

compensation or hire, act as pilot in command of an aircraft.

(b) A private pilot may, for compensation or hire, act as pilot in command of an aircraft 

in connection with any business or employment if:

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

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

(c) ****.

Juniper Unmanned requests an exemption from this regulation to the extent necessary to 

permit Juniper Unmanned to conduct UAS operations using PICs who hold an FAA private pilot 

certificate. While Juniper Unmanned recognizes that the FAA normally requires a PIC to hold a 

commercial pilot certificate where there is compensation either to the pilot or for the operation, Juniper 

Unmanned requests that the FAA exempt Juniper Unmanned and its PICs from this requirement since 

the use of a private pilot as the PIC for the UAS operations under this exemption will be more safe than 

the use of a commercial pilot for manned aircraft operations. Unlike conventional aircraft, the Sirius UAS 

is remotely controlled, with no crew or passengers, and battery-powered. The fulfillment of the 

additional requirements for a private pilot to become qualified as a commercial pilot would not lead to 

any additional safety benefits when UAS operations are involved.

The differences between the aeronautical knowledge requirements for private pilots and for

commercial pilots are significant in the traditional world of manned aircraft. A pilot who wishes to

operate flights that involve the carriage of persons or property for compensation or hire is typically

expected to improve his or her aeronautical knowledge with respect to the operation of those larger

manned aircraft. For instance, the prospective commercial pilot is expected to be able to operate more 

complex aircraft and in conditions other than VMC. Pilots seeking to become commercial pilots for 

manned aircraft must acquire additional aeronautical knowledge about the use of performance charts 

and aeronautical charts (beyond that which a private pilot must obtain for VFR), night operations, and 

the use of air navigation aids/facilities.2 However, no aspect of this 2 FAR § 61.125, Aeronautical 

knowledge for commercial pilots, paras. (b)(7) (use of performance charts), (b)(9) (use of aeronautical 

charts beyond that necessary for flight under VFR), (b)(10) (use of air navigation aids), and (b)(14) (night

and high-altitude operations) incremental additional knowledge is significant for the daytime, VMC small 

UAS operations over private or controlled access properties proposed in this Petition. The differences 

between the aeronautical experience requirements for private pilots and for commercial pilots are also 

significant. However, the additional experience required for a commercial pilot certificate is required to 

2FAR § 61.125, Aeronautical knowledge for commercial pilots, paras. (b)(7) (use of performance charts), (b)(9) (use of 

aeronautical charts beyond that necessary for flight under VFR), (b)(10) (use of air navigation aids), and (b)(14) (night and

high-altitude operations)
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a great extent to allow the upgrading pilot to acquire experience of a type that a commercial PIC of a 

manned aircraft must obtain in order to safely conduct commercial operations in a larger manned 

aircraft. For instance, the applicant for a commercial certificate with a single-engine land rating must 

obtain 50 hours of cross-country flight, 10 hours of instrument training, 10 hours of time in a complex 

aircraft, 10 hours of solo time, and 5 hours in night VFR conditions.3 In addition, a great deal of time is 

required for a pilot of a larger manned aircraft seeking to become a commercial pilot to ensure that the 

pilot’s takeoffs and landings can be conducted safely enough so as not to imperil the passengers and 

property aboard the manned aircraft. In this regard, there is a fundamental difference between the type 

of experience that the PIC of a manned aircraft should have, versus the type of experience that the PIC 

of a small UAS should have, in order to avoid imperiling passengers or property. In Juniper Unmanned’ 

case, the small amount of property carried aboard the UA will be Juniper Unmanned property. While the 

pilot will be compensated, all risk of damage to the property (in fact to the UAS itself) will be borne by 

Juniper Unmanned. There is no expectation or need for the PIC of the UA to have the type of experience 

that a commercial pilot for a manned aircraft would have. In short, almost none of the aeronautical 

experience requirements, beyond those necessary for private pilots and as set forth in the Sirius UAS 

manufacturer’s written authorized training program, is relevant to the PIC who will operate the small 

UAS over private or controlled access property as proposed in this Petition. Accordingly, there is no 

reason to require the UAS PIC to have more experience than that required for the private pilot 

certificate.

The differences between flight proficiency requirements for private pilots and for commercial

pilots involve areas such as “[h]igh-altitude operation” and other areas that have no bearing on the

small UAS operations at issue in this Petition.4 To the extent that differences exist between the 

standards of performance for flight proficiency as demonstrated by prospective private versus

prospective commercial pilots, those standards are not significant here where the operations will be

conducted strictly during daylight VMC conditions, within VLOS, at altitudes no higher than 400 feet

AGL.

Given that Juniper Unmanned plans to operate its Sirius UAS in Class G airspace over private or

controlled-access property at altitudes of 400 feet AGL or less, the parallel nature of private pilot

aeronautical knowledge requirements to those of commercial requirements, the limited airmanship

skills necessary to operate the Sirius UAS, and the lack of additional safety benefits for the proposed

UAS operations here resulting from commercial pilot experience, the PIC under this exemption should 

only be required to hold a private pilot certificate and third-class airman medical certificate. Such a 

condition would be consistent with the certificate requirements imposed on the PIC in the Astraeus 

Exemption, Trimble Exemption, AAS Exemption, and Clayco Exemption.

For these reasons, Juniper Unmanned requests that the FAA grant an exemption to permit 

Juniper Unmanned to use as PIC of the proposed UAS operations pilots who hold a private pilot 

certificate and a third-class airman medical certificate, so long as they satisfy the conditions and 

limitations proposed in this Petition, including the PIC qualification and training requirements.

3See FAR § 61.129.

4Compare FAR § 61.127, flight proficiency for commercial pilots (in particular §§ 61.127(b)(1)(x) and (b)(2)(x)), with FAR § 

61.107, flight proficiency for private pilots.
14

FAR § 91.7(a) – Civil aircraft airworthiness.

The regulation states in relevant part:

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

Compare FAR § 61.127, flight proficiency for commercial pilots (in particular §§ 61.127(b)(1)(x) and 

(b)(2)(x)), with FAR § 61.107, flight proficiency for private pilots. 

Juniper Unmanned requests an exemption from this provision to the extent necessary.5 The 

Sirius UAS will not require an airworthiness certificate under FAR Part 21, Subpart H, and thus relief is 

requested from this regulation. See Trimble Exemption, at 16. An exemption is warranted because 

Juniper Unmanned understands that, notwithstanding the lack of an airworthiness certificate, the FAA 

will consider its “compliance with [Juniper Unmanned’s] Manuals to be sufficient means for determining 

an airworthy condition” and that Juniper Unmanned must still determine the UA’s airworthiness prior to 

each flight based on compliance with such Manuals. See Trimble Exemption, at 16.

FAR § 91.119(b) and (c) – Minimum safe altitudes: General.

The regulation states:

Except when necessary for takeoff or landing, no person may operate an aircraft below the 

following altitudes:

(a) Anywhere. An altitude allowing, if a power unit fails, an emergency landing without 

undue hazard to persons or property on the surface.

(b) Over congested areas. Over any congested area of a city, town, or settlement, or 

over any open air assembly of persons, an altitude of 1,000 feet above the highest 

obstacle within a horizontal radius of 2,000 feet of the aircraft.

(c) Over other than congested areas. 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, vessel, vehicle, or structure.

(d) Helicopters, powered parachutes, and weight-shift-control aircraft. If the operation 

is conducted without hazard to persons or property on the surface—

(1) A helicopter may be operated at less than the minimums prescribed in 

paragraph (b) or (c) of this section, provided each person operating the 

helicopter complies with any routes or altitudes specifically prescribed for 

helicopters by the FAA; and

5Juniper Unmanned requests exemption from FAR § 91.7(a) based on the relief granted in the Trimble Exemption, at 16, 

21. However, Juniper Unmanned notes that the FAA determined that no such exemption was needed in the Astraeus 

Exemption, at 19, 22.
15

(2) A powered parachute or weight-shift-control aircraft may be operated at 

less than the minimums prescribed in paragraph (c) of this section.

Juniper Unmanned requests an exemption from this regulation to the extent necessary to

permit Juniper Unmanned to conduct its UAS operations at altitudes lower than those permitted by FAR 

§ 91.119, since such altitudes are one of the key benefits of using small UAS for these flights. Even at 

these low altitudes, Juniper Unmanned’ UAS operations will be conducted at a level of safety at least 

equal to that which would be achieved if larger manned aircraft were to be used at the altitudes 

required by FAR § 91.119.

With respect to paragraph (a), Juniper Unmanned intends to comply with this requirement to 

the same extent as would a manned aircraft, meaning that the UA must operate at an altitude such that 

the loss of a single power unit aboard the UA or used by the UAS would still permit an emergency

landing “without undue hazard to persons or property on the surface.” Juniper Unmanned agrees with 

the FAA’s reasoning on this issue in the Astraeus Exemption, at 20, and therefore does not believe that 

relief is required from paragraph (a).

With respect to paragraph (b), Juniper Unmanned plans to operate these small UAS over private 

or controlled-access properties, which are not themselves congested areas, but which may be located

within a broader heavily populated and congested area. Accordingly, Juniper Unmanned does not 

believe that an exemption is warranted from this paragraph covering “congested areas”. However, as 

the FAA has noted (Trimble Exemption, at 18), there is no precise definition of “congested areas,” and 

the PIC can obtain such information from the local Flight Standards District Office; but, even if these 

small UAS operations were to operate over areas somehow construed as being “congested”, the 

proposed UAS operations will be far safer than operations by larger manned aircraft operating in 

compliance with the minimum altitude requirements (1,000 feet altitude). The operation of a much 

heavier, faster aircraft with an onboard pilot and other crewmembers, at 1,000 feet over a congested 

area, with a load of combustible fuel, unquestionably provides a lower level of safety than an operation

conducted by a very small, extremely lightweight, battery-operated UA over private or controlled access 

property that, at all times from takeoff to landing, can be safely operated well below the altitudes used 

by manned aircraft and continuously within VLOS of the PIC on the ground. To the extent necessary, 

Juniper Unmanned requests relief from paragraph (b).

With respect to paragraph (c), Juniper Unmanned requests an exemption to allow UAS operations 

down to the surface, both in sparsely populated areas and in “other than congested” areas. Juniper 

Unmanned’ UAS operations require lower-level flying, but have a number of self-imposed restrictions to 

ensure at least an equivalent level of safety. For example,

 All operations will avoid congested or populated areas.

 All operations will be conducted over private or controlled access property.

 Permission from the land owner/controller will be obtained prior to the beginning of each flight.

 Juniper Unmanned will timely file a NOTAM for each flight.

 The UA will operate at least 500 feet from all non-participating persons, vessels, vehicles, and 

structures unless:
16

o Barriers or structures are present that sufficiently protect non-participating persons 

from the UA and/or debris in the event of an accident. Juniper Unmanned must ensure 

that non-participating persons remain under such protection; and if a situation arises 

where non-participating persons leave such protection and are within 500 feet of the 

UA, flight operations will cease immediately; and/or

o The UA is operated near vessels, vehicles or structures where the land owner/controller 

has granted permission and the PIC has made a safety assessment of the risk of 

operating closer to those objects and determined that it does not present an undue 

hazard.

Even with a grant of this exemption, the UAS operations will be at least as safe as operations by 

manned aircraft that comply with this paragraph. Flying a manned aircraft, given its weight, size, speed, 

and fuel load, would pose a significant risk relative to the use of a small UA, with a smaller size and 

weight, operating at much lower speeds, with batteries rather than a significant fuel load, and at all 

times within VLOS of the PIC on the ground who has a wide view. Accordingly, as the FAA determined in 

the Trimble exemption, at 17-18, relief is warranted here provided that Juniper Unmanned adheres to 

its Manuals and the additional conditions and limitations outlined above and in the exemption. For 

these reasons, Juniper Unmanned requests relief from the entirety of paragraph (c).

Juniper Unmanned does not request relief from paragraph (d), because it applies only to 

helicopters (and allows operation at lower altitudes only if on a prescribed helicopter route) and 

powered parachute type aerial vehicles.

FAR § 91.121 – Altimeter settings.

The regulation states, in relevant part:

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

aircraft, as the case may be, by reference to an altimeter that is set, when operating—

(1) Below 18,000 feet MSL, to—

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

100 nautical miles of the aircraft;

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

section, the current reported altimeter setting of an appropriate available 

station; or

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

departure airport or an appropriate altimeter setting available before 

departure; or

(2) At or above 18,000 feet MSL, to 29.92′′ Hg.

(b) * * * *.

It is not clear to Juniper Unmanned that an exemption from this section is required because, 

although the regulation expressly applies only to aircraft maintaining a “cruising altitude” and dictates 
17

the altimeter setting that must be used while at that cruising altitude, cruising altitudes for VFR flights 

do not begin – according to FAR § 91.159 – until “more than 3,000 feet above the surface”.6 

Nonetheless, Juniper Unmanned requests an exemption from FAR § 91.121 to the extent necessary to 

permit Juniper Unmanned to conduct the small UAS operations described in this Petition. See Astraeus

Exemption, at 21-22 (granting relief from this section with conditions and limitations).

Juniper Unmanned recognizes the critical importance of ensuring that any UAS operated by 

Juniper Unmanned maintain altitude to an accurate reference such that other aircraft and the FAA may 

rely on Juniper Unmanned’s UAS to be operating as proposed. The Sirius UAS does not use a barometric 

altimeter. Instead, it determines altitude based on a GPS signal. To ensure the accuracy of the GPS 

signal, the PIC will check the UA altitude reading prior to each takeoff, and will effectively zero the UA’s 

altitude at the point of takeoff, to ensure that measurements of the UA’s altitude are as accurate as 

possible relative to the local elevation. To the extent that this methodology does not satisfy FAR § 

91.121 or any other regulation, Juniper Unmanned requests an exemption to permit UAS operations 

using this methodology.

FAR § 91.151 – Fuel requirements for flight in VFR conditions.

The regulation 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.

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

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

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

Juniper Unmanned requests an exemption from FAR § 91.151 to permit Juniper Unmanned to 

plan its UAS operations as described above. The proposed small UAS operations in this Petition will (i) 

involve operations in which one or more UAS is transported by means other than its own power to the 

operational location, and (ii) begin and end at the operational site, with the takeoff, entire flight, and 

landing all taking place within the immediate proximity to each other while remaining at all times within 

VLOS of the PIC.

6FAR § 91.159; see also Aeronautical Information Manual, at Chpt. 3, Sec. 1, Tbl. 3-1-1para. 3-1-2. (Jul. 24, 2014).
18

The goal of FAR § 91.151 is to ensure that pilots plan for an extra 20 or 30 minutes of fuel at

their first intended point of landing in order to account for unexpected possible delays en route and at 

the first planned destination. Many of these delays that plague manned aircraft are simply not an issue 

with the proposed small UAS operations over private or controlled access property, because there is 

virtually no “en route” portion of the flight, and any problems at the point of landing are extremely 

unlikely to cause delays, since a UA can always land just a few feet away if the intended point of landing 

becomes unusable.

Given the relatively short operating time for the Sirius UAS (50 minutes), requiring a full 30 

minutes of reserve “fuel” (battery power) could take up nearly all of the available time for UAS

operations. Juniper Unmanned believes that using a smaller reserve for UAS flight planning purposes will 

be at least as safe as using the reserves required by FAR § 91.151 for manned aircraft. Using a reserve of 

30% battery power for a daylight UA flight, for instance, will be adequate where the UA is essentially at 

its first point of landing from the moment it takes off (since there is no en-route phase of flight), since 

the risks for delay at the intended landing area are not as great as for manned aircraft landings. To that 

end, and consistent with AAS Exemption Limitation No. 22, the PIC under the requested exemption will 

be prohibited from beginning a UAS flight unless (considering wind and forecast weather conditions) 

there is enough power to fly at normal cruising speed to the intended landing point and land the UA 

with at least 30% battery power remaining. Juniper Unmanned believes that these limitations will 

further ensure that the proposed reserve planning and operational requirements that Juniper 

Unmanned is requesting to use under the exemption will provide at least an equivalent level of safety.

For these reasons, Juniper Unmanned requests an exemption from FAR § 91.151(a) to permit it 

to plan and conduct UAS operations such that only 30% of the battery power (instead of 30 minutes) is 

available at the end of the planned UAS operation. FAR § 91.151(b) covers only rotorcraft and thus is not

applicable to the small UAS operations Juniper Unmanned is proposing.

FAR § 91.405(a) – Maintenance required.

The regulation states, in relevant part:

Each owner or operator of an aircraft—

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

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

repaired as prescribed in part 43 of this chapter;

(b) ****.

Juniper Unmanned requests an exemption from FAR § 91.405(a) to permit Juniper Unmanned to 

conduct the UAS operations proposed in this Petition without having to perform the inspections and 

discrepancy repairs required by FAR § 91.405(a). In the Astraeus Exemption and the Trimble Exemption, 

the FAA determined that the proposed UAS operations required exemption from FAR § 91.405(a), and

that the achievement of an adequate level of safety required certain conditions and limitations, some of 
19

which were proposed by the petitioner and some of which were imposed by the FAA. These included 

requirements to develop and document maintenance, overhaul, replacement, and inspection 

requirements in the absence of manufacturer’s requirements; procedures to document and maintain 

maintenance records with regard to the petitioner’s UAS; UAS technician qualification criteria; and 

requirements to document comprehensive preflight inspection procedures.

Juniper Unmanned has proposed several conditions and limitations in Section 3 of this Petition 

related to maintenance and inspections consistent with those in the Astraeus Exemption and the 

Trimble Exemption. Juniper Unmanned believes that these conditions and limitations provide a level of 

safety at least equivalent to that provided by FAR § 91.405(a), the Astraeus Exemption, and the Trimble

Exemption. For this reason, Juniper Unmanned requests an exemption from FAR § 91.405(a) to permit 

Juniper Unmanned to conduct UAS operations as proposed in this Petition, subject to the conditions and 

limitations proposed above, without having to perform the inspections and discrepancy repairs required 

by FAR § 91.405(a).

Juniper Unmanned does not believe that an exemption from the remaining paragraphs of FAR § 

91.405 is required, since Juniper Unmanned will make appropriate logbook entries in aircraft 

maintenance records in accordance with paragraph (b), appropriately mark any inoperative instrument 

or item of equipment for which maintenance has been properly deferred in compliance with paragraph 

(c), and appropriately placard listed discrepancies that include inoperative instruments or equipment in

compliance with paragraph (d).

FAR § 91.407(a)(1) – Operation after maintenance, preventive maintenance, rebuilding or alteration.

The regulation states:

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

maintenance, rebuilding, or alteration unless—

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

chapter; and

(2) The maintenance record entry required by §43.9 or §43.11, as applicable, of this 

chapter has been made.

(b)  .

(c) ** **.

Juniper Unmanned requests an exemption from FAR § 91.407(a)(1) to permit Juniper Unmanned

to conduct UAS operations as proposed in this Petition without having to have the UAS approved for 

return to service by a person authorized under FAR § 43.7. In the Astraeus Exemption and the Trimble 

Exemption, the FAA determined that the proposed UAS operations required exemption from FAR § 

91.407(a)(1), and that achieving an adequate level of safety required conditions and limitations similar 

to those in the Trimble Exemption and the Astraeus Exemption.
20

Juniper Unmanned has proposed maintenance-related conditions and limitations in this 

Petition, which it believes provide a level of safety at least equivalent to that provided by FAR § 

91.407(a)(1) and the conditions and limitations in the Trimble Exemption and Astraeus Exemption. For 

this reason, Juniper Unmanned requests an exemption from FAR § 91.407(a)(1) to permit Juniper 

Unmanned to conduct UAS operations as proposed in this Petition, subject to the proposed conditions 

and limitations, without having to have the UAS approved for return to service by a person authorized 

under FAR § 43.7.

Juniper Unmanned does not believe that an exemption from the remaining paragraphs of FAR § 

91.407 is required, since Juniper Unmanned will require that maintenance record entries are made as 

required, in compliance with paragraph (a)(2), and since no persons will be carried following 

maintenance performed on the UAS, making paragraphs (b) and (c) moot.

FAR § 91.409(a)(1) and (2) – Inspections.

The regulation states, in relevant part:

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

within the preceding 12 calendar months, it has had—

(1) An annual inspection in accordance with part 43 of this chapter and has been

approved for return to service by a person authorized by §43.7 of this chapter; or

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

21 of this chapter. No inspection performed under paragraph (b) of this section may be 

substituted for any inspection required by this paragraph unless it is performed by a 

person authorized to perform annual inspections and is entered as an “annual” 

inspection in the required maintenance records.

(b)  .

Juniper Unmanned requests an exemption from FAR § 91.409(a)(1) and (2) to permit Juniper Unmanned

to conduct UAS operations as proposed in this Petition without having to obtain the annual inspection 

and airworthiness certificate inspection required by FAR § 91.409(a)(1) and (2). In the Trimble

Exemption and the Astraeus Exemption, the FAA determined that the proposed UAS operations

required exemption from FAR § 91.409(a)(1) and (2), and that achieving an adequate level of safety 

required conditions and limitations similar to those set forth in those previously-granted exemptions. 

Juniper Unmanned has proposed maintenance and inspection-related conditions and limitations in this

Petition, which it believes provide a level of safety at least equivalent to that provided by FAR §

91.409(a)(1) and (2), the Trimble Exemption, and the Astraeus Exemption. For this reason, Juniper 

Unmanned requests an exemption from FAR § 91.409(a)(1) and (2) to permit Juniper Unmanned to 

conduct UAS operations as proposed in this Petition, subject to the proposed conditions and limitations, 

without having to obtain the annual inspection and airworthiness certificate inspection required by FAR 

§ 91.409(a)(1) and (2).
21

FAR § 91.417(a) and (b) – Maintenance records.

The regulation states, in relevant part:

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

or operator shall keep the following records for the periods specified in paragraph (b) of this 

section:

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

the 100-hour, annual, progressive, and other required or approved inspections, as 

appropriate, for each aircraft (including the airframe) and each engine, propeller, rotor, 

and appliance of an aircraft. The records must include—

(i) A description (or reference to data acceptable to the Administrator) of the 

work performed; and

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

(iii) The signature, and certificate number of the person approving the aircraft 

for return to service.

(2) Records containing the following information:

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

each rotor.

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

rotor, and appliance.

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

required to be overhauled on a specified time basis.

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

inspection required by the inspection program under which the aircraft and its 

appliances are maintained.

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

directives including, for each, the method of compliance, the AD or safety 

directive number and revision date. If the AD or safety directive involves 

recurring action, the time and date when the next action is required.

(vi) Copies of the forms prescribed by §43.9(d) of this chapter for each major 

alteration to the airframe and currently installed engines, rotors, propellers, and

appliances.

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

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

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

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

transferred with the aircraft at the time the aircraft is sold.
22

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

chapter shall be retained until the defects are repaired and the aircraft is approved for 

return to service.

(c) ** **.

Juniper Unmanned requests an exemption from FAR § 91.417(a) and (b) to permit Juniper 

Unmanned to conduct UAS operations as proposed in this Petition without having to keep the records 

described in FAR § 91.417(a) and (b). The FAA determined in the Trimble Exemption and the Astraeus 

Exemption that the proposed UAS operations required exemption from FAR § 91.417(a) and (b), and 

that an adequate level of safety required conditions and limitations similar to those set forth in those 

previously-granted exemptions.

Juniper Unmanned has proposed maintenance, inspection, and records-related conditions and 

limitations in this Petition, which it believes provide a level of safety at least equivalent to that provided 

by FAR §91.417(a) and (b), the Trimble Exemption, and the Astraeus Exemption. For this reason, Juniper 

Unmanned requests an exemption from FAR § 91.417(a) and (b) to permit Juniper Unmanned to 

conduct UAS operations as proposed in this Petition, subject to the proposed conditions and limitations, 

without having to keep the records described in FAR § 91.417(a) and (b).

Additional FAR Provisions.

The Petition does not seek exemption from certain regulations based on the reasoning and

FAA precedent outlined below in the footnote.7

However, Juniper Unmanned also requests that, to the extent that the FAA concludes that an 

exemption from one or more other provisions of the FAR would be required to permit the UAS 

7This Petition does not seek exemption from:

> FAR Part 21 or 36, based on the reasoning in the Astraeus Exemption, at 14, and Clayco Exemption, at 10. 

> FAR § 91.7(b), based on the reasoning in the Trimble Exemption, at 17. 

> FAR §§ 91.9(b)(2) and 91.203(a) and (b), based on the reasoning in the FAA’s August 8, 2014 Memorandum titled 

“Interpretation regarding whether certain required documents may be kept at an unmanned aircraft’s control station” 

(“FAA’s August 8, 2014 Memorandum”), the Astraeus Exemption, at 19-20, 22, and the Trimble Exemption, at 17, 20.

> FAR §§ 45.23(b) and 91.9(c), based on the reasoning in the Astraeus Exemption, at 14, and Trimble Exemption, at 14, 

related to FAR § 45.23(b), and assuming that the markings on the UA used to comply with FAR Part 45, Subpart C 

requirements are as large as practicable.

> FAR §§ 47.3(b)(2) and 47.31(c), based on the reasoning in the FAA’s August 8, 2014 Memorandum, and assuming that 

all UA are registered in accordance with FAR Part 47.

> FAR § 91.103(b)(2), based on the FAA’s reasoning in the Astraeus Exemption, at 20, and Clayco Exemption, at 14, which 

concluded that an exemption from the preflight action requirements is not necessary when the grant of an exemption for 

UAS operations includes conditions that satisfy preflight action requirements. Juniper Unmanned proposes such 

conditions in this Petition.

> FAR § 91.109, based on the FAA’s reasoning in the Astraeus Exemption, at 20, and Clayco Exemption, at 14, which 

concluded that an exemption from the requirement for dual flight controls for flight or simulator training or for flight 

testing is not necessary when there is no indication that dual flight controls will be used during any flight or simulator 

training or flight testing 
23

operations described in this Petition, the FAA grant an exemption from those FAR provisions as 

necessary to permit the UAS operations described in this Petition.8

5.4 Reasons why granting the request would be in the public interest:

A grant of the exemption would be in the public interest because it would enhance safety for the 

general public, Juniper Unmanned employees, and Juniper Unmanned customers.

First, the ability to use a small UAS to conduct the operations described herein, subject to the 

conditions and limitations proposed in this Petition, will enable Juniper Unmanned to have access to 

more complete data about aerial surveys, topography, demonstration flights, and maintenance flights, 

which

– in turn – will enable Juniper Unmanned to conduct safe and effective aerial survey, demonstration or 

maintenance/repair flights that minimize the risk of harm to the general public, Juniper Unmanned

employees, and Juniper Unmanned customers.

Second, given Juniper Unmanned’ primary objective of providing a functional and safe UAS, this 

exemption would allow Juniper Unmanned to provide a comprehensive training, repair/service, and 

testing program for its customers who operate, or seek to operate, the small Sirius UAS. It is in the 

public interest for Juniper Unmanned to offer these types of programs so that (i) owners/operators of 

these small Sirius UAS are properly educated about safe flight operations and (ii) repairs done to the 

Sirius UAS are appropriately tested.

Third, the use of the small, lightweight, battery-powered Sirius UAS for these topographical 

aerial surveys and related operations is far less risky than undertaking those operations with a much

heavier, much faster, much larger, manned helicopter or other aircraft loaded with fuel and a crew. As 

the FAA acknowledged in the Trimble Exemption, at 13:

“The [Juniper Unmanned] pilot and crew will be remotely located from the aircraft. The limited

weight and construction with impact absorbent materials significantly reduces the potential 

harm to persons or damage to property in the event of an incident or accident. The risk to an 

onboard pilot and crew during an incident or accident is eliminated with the use of a UAS for the 

aerial surveying operation. Manned aircraft are at risk of fuel spillage and fire in the event of an 

incident or accident. [The Sirius UAS] carries no fuel [it is battery-powered] and therefore the

risk of fire following an incident or accident due to fuel spillage is eliminated.”

These distinctions, coupled with the safety-related features of the Sirius UAS such as Loss Link

Procedures, redundant flight control systems, real-time telemetry, airspace awareness system, and 

terrain following, demonstrate that the Sirius UAS operations proposed in this Petition are far less risky 

than if operated by larger and heavier manned aircraft.

8Juniper Unmanned would be happy to provide follow-on documentation providing the rationale 

underlying any such additional exemptions.
24

5.5 Reasons why granting the exemption would not adversely affect safety, or how the exemption 

would provide a level of safety at least equal to that provided by the rule from which exemption is 

sought:

Throughout this Petition, Juniper Unmanned has explained many reasons why granting an 

exemption from each section of the FAR from which relief is sought would result in UAS operations that 

provide a

level of safety at least equal to, or greater than, that provided by the rule from which exemption is

sought. Moreover, the many conditions and limitations proposed in this Petition also ensure at least

an equivalent level of safety, as the FAA concluded in the Trimble Exemption and the Astraeus

Exemption.

In general, the risks of any proposed UAS operation interfering with a manned aircraft is

minimized by the low altitude at which the UAS will operate; the locations at which the UAS will operate 

(e.g., Class G airspace, private or controlled access property, away from airports); the small size/low

weight and relatively slow speed of the Sirius UAS; the restriction of UAS operations to VMC and 

daytime conditions; the requirement for the PIC to maintain VLOS of the UA at all times; and the 

condition to obtain a NOTAM before each UAS flight, among other conditions and limitations. The risks 

to persons or property on the ground are also minimized by the small size/low weight of the Sirius UAS; 

the 500-foot set-off from non-participating persons or structures; the prohibition on flights over 

congested or densely populated areas; the PIC’s VLOS requirement; and limiting operations to private or 

controlled access property, among others. These parameters, conditions, and limitations proposed in 

the Petition provide substantial protection against interference with manned aircraft operations or with 

the safety of persons or property on the ground. In addition, under the proposed conditions and 

limitations in Section 3 of this Petition, Juniper Unmanned will coordinate extensively, as warranted, 

with the FAA, with local airports, and with property owners to ensure that all UAS operations under the 

exemption are at least as safe as would be manned aircraft operations used for similar purposes.

The Sirius UAS also has several safety-related protocols in case there is any lost link between the 

UA and the operator. These Lost Link Procedures are covered in the Operator’s Manual and can handle 

lost links alone or in combination. As an example, if a GNSS link is lost, the autopilot sends an error 

message to the computer notifying the computer operator, who can notify the PIC to take control of the 

UAS and land. If the PIC does not take over control within a preset time, the UAS will begin to circle 

slowly and descend to land. If an RC link and data link are both lost, the UAS will return to the takeoff 

position and circle. The “return home command” can return the UA to its takeoff position or to another 

location established as “home” during the creation of the flight plan at any time during a flight. Juniper 

Unmanned can also end a UAS flight via a command from the computer telling the UA to land at a 

defined area automatically, or the PIC can take control of the UA using the RC controller.

In addition, another key safety feature of the MAVinci System is its dual control links. The

MAVinci Ground Control Station (“GCS”) and MAVinci Remote Control (“RC”) consoles are dual, robust, 

and independent systems, affording a redundant means of controlling the UA – significantly increasing 

operational security. The 2.4 GHz RC console is connected wirelessly to the Sirius UA for piloting in 

autopilot assisted and fully manual modes. The MAVinci GCS functions from the laptop through the 2.4 

GHz Connector antenna, providing fully autonomous flight. Should either system fail, the other system 

remains fully operational and is capable of providing safety of flight for the UAS.
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For these reasons, granting an exemption from each section of the FAR from which relief is 

sought would not adversely affect safety, and would provide a level of safety at least equal to, or greater 

than, that provided by the rule from which exemption is sought. 

5.6 Summary that can be published in Federal Register, including the rule from which exemption is 

sought, a brief description of the nature of the exemption sought:

Juniper Unmanned proposes that the FAA use the following as the summary:

Docket No.: FAA-2015-______

Petitioner: Juniper Unmanned, Inc.

Sections of 14 CFR: 61.113(a) and (b), 91.7(a), 91.119(b) and (c), 91.121, 91.151,

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

Description of Relief Sought: Petitioner seeks an exemption to conduct small UAS commercial 

operations for aerial surveying, product demonstration flights for potential customers, UAS product 

training for customers, and research and development for future product improvements related to 

these small UAS.

5.7 Additional information that supports request:

Juniper Unmanned is prepared to provide additional information that the FAA might find helpful, or to

answer questions in response to any FAA requests. A confidential copy of each of the Manuals and the 

Juniper Unmanned Certified Training Program will be submitted to the FAA Assistant Chief Counsel for

International Law, Legislation, and Regulations as supporting documentation for this Petition. The

Manuals and Juniper Unmanned Certified Training Program contain information that is highly 

proprietary to Juniper Unmanned and/or MAVinci, and Juniper Unmanned requests that the FAA treat 

the Manuals and Juniper Unmanned Certified Training Program as confidential and not disclose them to 

the public.

5.8 Request to exercise the privileges of the exemption outside the U.S.:

Juniper Unmanned does not request to exercise the privileges of the exemption outside the United 

States.

5.9 Attachments:

In support of this Petition, Juniper Unmanned will provide copies of the Manuals and the Juniper 

Certified Training Program to the FAA Assistant Chief Counsel for International Law, Legislation, and 

Regulations. As noted above, Juniper Unmanned requests confidential treatment by the FAA of the 
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Manuals and Certified Training Program. These documents contain non-public, confidential information 

that is highly proprietary to Juniper Unmanned and/or MAVinci. These confidential documents are also 

submitted under 14 C.F.R. § 11.35(b), and are exempt from public disclosure under the Freedom of 

Information Act, 5 U.S.C. § 552 et seq.

6. CONCLUSION 

For the foregoing reasons, Juniper Unmanned respectfully requests that the FAA grant this Petition for 

Exemptions.

Respectfully Submitted, 

Jeff Cozart

Dave White

Juniper Unmanned INC