Integra Tower, LLC | 11771 Spruce Run Dr, San Diego, CA 92131 | www.integratower.com 1

January 30, 2015

U.S. Department of Transportation, Docket Operations

West Building Ground Floor, Room w12-140

1200 New Jersey Avenue, SE

Washington, DC 20590

Re: Exemption Request Section 333 of the FAA Reform Act and Part 11 of the Federal Aviation Regulations 

from 14 C.F.R. 45.23(b); 14 CFR Part 21; 14 CFR 61.3(a) & (c); 61.113(a) & (b); 91.7 (a); 91.9 (b) (2); 91.103(b); 

91.109; 91.119; 91.121; 91.151(a); 91.203(a) & (b); 91.405 (a); 91.407(a) (1 ); 91.409 (a) (2);91.417 (a) & (b).

Dear Sir or Madam:

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the Reform Act) and 14 

C.F.R. Part 11, Integra Tower, LLC, (heretofore “Integra”) an operator of Small Unmanned Aircraft Systems 

(sUAS) equipped to conduct aerial infrastructure inspections and surveys for the tower, bridge, utility, and 

building construction and maintenance industries hereby applies for an exemption from the listed Federal 

Aviation Regulations (FARs) to allow commercial operation of its sUAS, 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 333.1

As described in detail below, the requested exemption would permit the operation of small, 

unmanned and relatively inexpensive sUAS under controlled conditions in airspace that is 1) limited, 2) 

predetermined, 3) has controlled access, and 4) provides enhanced safety advancements to hazardous 

inspection and surveying work currently performed manually. Approval of this exemption would enhance 

safety and eliminate workplace accidents and deaths for these industrial tasks. This meets the requirements 

in 14 CFR Part 11.81 as being in the public interest as well as not adversely affecting safety.

The name and address of the Applicant is:

Integra Tower, LLC

Attn: Eric DaVersa

Phone: (858) 245-6702

Email: eric@integratower.com

Address: 11771 Spruce Run Dr, San Diego, CA 92131
Integra Tower, LLC | 11771 Spruce Run Dr, San Diego, CA 92131 | www.integratower.com 2

Regulations from which the exemption is requested:

14 CFR Part 21

14 CFR 45.23(b)

14 CFR 61.3(a) & (c)

14 CFR 61.113 (a) & (b)

14 CFR 91.7 (a)

14 CFR 91.9 (b) (2)

14 CFR 91.103

14 CFR 91.109

14 CFR 91.119

14 CFR 91.121

14 CFR91.151 (a)

14 CFR 91.203 (a) & (b)

14 CFR 91.405 (a)

14 CFR 407 (a) (1)

14 CFR 409 (a) (2)

14 CFR 417 (a) & (b)

This exemption application is expressly submitted to fulfill Congress' goal in passing Section 333(a) 

through (c) of the Reform Act. This law directs the Secretary of Transportation to consider whether certain 

unmanned aircraft systems may operate safely in the national airspace system (NAS) before completion of 

the rulemaking required under Section 332 of the Reform Act. In making this determination, the Secretary is 

required to determine which types of UAS do not create a hazard to users of the NAS or the public or pose a 

threat to national security in light of the following:

 The UAS's size, weight, speed, and operational capability;

 Operation of the UAS in close proximity to airports and populated areas; and

 Operation of the UAS within visual line of sight of the operator.

Reform Act § 333 (a). Lastly, if the Secretary determines that such vehicles "may operate safely in the 

national airspace system, the Secretary shall establish requirements for the safe operation of such aircraft in 

the national airspace system." ld. §333(c) (emphasis added) 1.

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

authority by its terms includes exempting civil aircraft, as the term is defined under §40101 of the Act, that 

includes sUAS, from the requirement that all civil aircraft must have a current airworthiness certificate.

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

subsection (a) or (b) of this section or any sections 44702-44716 of this title if the Administrator finds the 

exemption in the public interest. 49 U.S.C. §44701 (f) See also 49 USC §44711(a); 49 USC §44704; 14 CFR 

§91.203 (a) (1).

Integra uses sUAS that are rotorcraft, weighing 55 or fewer lbs. including payload. They operate, under 

normal conditions at a speed of no more than 2 knots and have the capability to hover, and move in the 

vertical and horizontal plane simultaneously. The sUAS will operate only within the sterile area described in 

 

1

Applicant interprets this provision to place the duty on the Administrator to not only process applications 

for exemptions under section 333, but for the Administrator to craft conditions for the safe operation of the 

sUAS.
Integra Tower, LLC | 11771 Spruce Run Dr, San Diego, CA 92131 | www.integratower.com 3

the Confidential Flight Operations and Procedures, (hereinafter "the Manual")2. Such operations will ensure 

that the sUAS will "not create a hazard to users of the national airspace system or the public."3

Given the small size of the sUAS involved, the “electronic fence”, the industrial environment in which the 

sUAS is designed to operate, and the structural “shield” created by an existing obstacle, the Applicant falls 

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 sUAS to commence immediately. Also, due to the size 

of the sUAS and the restricted areas in which the relevant 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 workplace personal safety, more 

frequent infrastructure inspections leading to enhanced industrial maintenance and safety, the grant of the 

requested exemptions is in the public interest. Accordingly, the Applicant respectfully requests that the FAA 

grant the requested exemption without delay.

AIRCRAFT AND EQUIVALENT LEVEL OF SAFETY

The Applicant proposes that the exemption requested herein apply to civil aircraft that have the 

characteristics and that operate with the limitations listed herein. These limitations provide for at least an 

equivalent level of safety to operations under the current regulatory structure because the proposed 

operations represent a safety enhancement to workforce personal safety for certain types of industrial 

inspection and surveying work.

These limitations and conditions to which Integra agrees to be bound when conducting commercial 

operations under an FAA issued exemption include:

1. The sUAS will weigh approximately 10 lbs. in most flight and payload configurations, but no more 

than 55 lbs.

2. Flights will be operated within line of sight of the operator technician.

3. Flights will be operated at a typical altitude of 40 – 250 feet, but no more than 400 feet AGL.

4. The sUAS will only operate within a confined "safety perimeter" as defined in the Manual. Safety 

cones and/or tape will define the safety perimeter when operating in areas that could pose a hazard 

to the general public. Integra will post signage on site indicating aircraft audit/inspection in progress 

along with appropriate company contact information.

5. A briefing will be conducted in regard to the planned sUAS operations prior to each day's inspection 

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

boundaries of the safety perimeter be present for this briefing.

6. As with any other industrial workplace setting, appropriate safety gear will be worn by all personnel 

within the safety perimeter including, but not limited to, hardhats and brightly colored safety vests, 

and all personnel will have completed OSHA-10 certification at a minimum.

7. Each operator technician will have been trained in operation of sUAS and received up-to-date 

information on the particular sUAS to be operated as required in Section E of the Manual.

 

2

Applicant will submit this Manual as a Confidential document under 14 CFR 11.35 (b) as the entire manual 

contains proprietary information that the Applicant has not and will not share with others. The Manual 

contains operating conditions and procedures that are not available to the public and are protected from 

release under the Freedom of Information Act 5 USC 552 et.seq. Reform Act Section 333 (b).

3

Reform Act § 333 (b).
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8. Operator technician and other workers within the safety perimeter will at all times be able to 

communicate by voice or hand signals.

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

10. All required permissions and permits will be obtained from territorial, state, county or city 

jurisdictions, including local law enforcement, fire, or other appropriate governmental agencies for 

the work being done on site.

11. If the sUAS loses communications or loses its GPS signal, the sUAS will have capability to return to a 

pre-determined location within the Security Perimeter and land.

12. The sUAS and operator will have the capability to abort a flight in case of unpredicted obstacles or

emergencies.

13. The operator will obtain a FAA Form 7711-1, or its equivalent, as modified in light of the requested 

exemption, with the appropriate Air Traffic Organization for certain sUAS operations that are 

substantially outside the immediate shielding vicinity of tower, bridge, or building work locations 

TECHNICAL/OPERATIONAL LIMITATIONS AND PUBLIC SAFETY

Another aspect relating to public safety in regards to the operation of the Applicants sUAS is the 

environment in which it is designed to operate. The sUAS does not pose a hazard to other aircraft in the 

vicinity when performing its intended mission, which is a close-range inspection of various infrastructure 

assets such as towers, bridges, and buildings. The ”electronic fence” combined with the close proximity in 

which the proposed surveys are done, almost certainly means that the tower, bridge, or building under 

inspection by the sUAS is an equal, or even more hazardous obstacle to passing aircraft than the sUAS itself. 

The Applicant's proposal is to operate "shielded by existing structures of a permanent and substantial 

character"4.

Finally, the location of the various infrastructure assets at which the sUAS operates are generally not 

in publicly accessible places. Much of the infrastructure is on private property, behind fences, in remote

sparsely populated locations, or in industrial settings that are not open to the public. The safety procedures 

described in the Manual, combined with the limitations and conditions outlined above would provide an

equivalent level of public safety for the operation in the NAS.

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

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

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

area associated with the aircraft to be utilized by the Applicant, an exemption from Part 21 Subpart H meets 

the requirements of an equivalent level of safety under Part 11 and Section 333 of the Reform Act. The 

Federal Aviation Act (49 U.S.C.§44701 (f)) and Section 333 of the Reform Act both authorize the FAA to 

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

speed, operational capability, and proximity to airports and populated areas of the particular sUAS. In all 

cases, an analysis of these criteria demonstrates that the sUAS 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 (fixed wing or rotorcraft) operating with an airworthiness certificate without the 

restrictions and conditions proposed.

 

4

14 CFR §77.15
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The sUAS to be operated hereunder is less than 55 lbs. fully loaded, carries neither a pilot nor 

passenger, carries no explosive materials nor flammable liquid fuels, and operates exclusively within a 

secured area as described in the Manual. Unlike other civil aircraft, operations under this exemption will be 

tightly controlled and monitored by the operator, pursuant to the Manual's requirements, and under the 

requirements and in compliance with local public safety requirements when in operation where the general 

public could be a factor. The FAA will have advance notice of all operations where the sUAS is operating 

outside the immediate vicinity of an existing tower, bridge, or building. Lastly, application of these same

criteria demonstrates that there is no credible threat to national security posed by the sUAS, due to its size, 

speed of operation, location of operation, “fenced” limited range, lack of explosive materials or flammable 

liquid fuels, and inability to carry a substantial external load.

14 C.F.R. § 45.23 {b). Marking of the Aircraft

The regulation requires:

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. Even though the sUAS will have no airworthiness certificate, 

an exemption may be needed as the sUAS will have no entrance to the cabin, cockpit or pilot station on 

which the word "Experimental" can be placed. Given the size of the sUAS, two-inch lettering will be

impossible. However, Integra will post the registration number in a size as large as practicable. The word 

"Experimental" will be placed on the fuselage in compliance with §45.29 (f).

The equivalent level of safety will be provided by having the sUAS marked on its fuselage as required 

by §45.29 (f) where the pilot, observer and others working with the sUAS will see the identification of the 

sUAS as "Experimental." The FAA has issued the following exemptions to this regulation to Exemptions Nos. 

10700, 8738, 10167 and 10167 A.

14 C.F.R. §61.3{a) and {c): Requirements for certificates, ratings, and authorizations.

Section 61.3 (a) & (c) requires that a person must possess a valid pilot certificate as well as an 

appropriate medical certificate in order to act as pilot in command of a civil aircraft.

The equivalent level of safety will be maintained by equipment-specific training and knowledge for 

the sUAS as outlined in the Manual Section E. The training combined with the Integra pilot vetting process, 

we feel will exceed the equivalent level of safety required by the current regulations. We contend pilots that 

have learned flying techniques in manned aircraft have a potentially negative transfer when operating small 

sUAS. Therefore, by initially flying models and sUAS the operator can positively “practice” on the ground 

with acute attention on “external operation” unique to sUAS operations then transfer that into manned 

training. The amount of training will be sufficient for operators to understand the level of safety required to 

operate in the NAS safely. All flights will be “dispatched” with in-house flight following procedures as 

outlined in section E in the Manual. We will require that all operators/observers are required to complete a 

rigorous training course as outlined in the Manual:

 5* hours dual instruction fixed wing model aircraft with successful solo

 5* hours dual instruction multirotor aircraft with successful solo

 15 hours solo quad/airplane

 5 hours instruction programming sUAS
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 5 hours trouble shooting sUAS

 10 hours of dual instruction in manned aircraft from a certificated flight instructor

 25 hours ground training for Pvt. Pilot Written Exam

 80% or better corrected to 100% on Pvt. Pilot Written Exam

 III class medical certificate

*3 hours may be on pc based synthetic trainer.

Integra is open to finding a workable solution that puts this sUAS inspection tool into the hands of 

trained survey and inspection technicians without requiring every field level technician to become a certified 

pilot. If the request to operate without private pilot certification is denied, Integra will operate with persons

that hold a private pilot certificate. 

14 C.F.R. § 61.113 (a) & (b): Private Pilot Privileges and Limitations: Pilot in Command.

Sections 61.113 (a) & (b) limit private pilots to non-commercial operations. If an exemption is denied 

for section 61.3(a) and (b) mentioned above, then because the sUAS will not carry a pilot or passengers, the 

proposed operations can achieve the equivalent level of safety of current operations by requiring the PIC 

operating the aircraft to have a private pilot's license rather than a commercial pilot's license to operate this 

sUAS. Unlike a conventional aircraft that carries the pilot and passengers, the sUAS is remotely controlled 

with no living thing on board. The area of operation is controlled and restricted, and all flights are planned

and coordinated in advance as set forth in the Manual. The level of safety provided by the requirements 

included in the Manual exceeds that provided by a single individual holding a commercial pilot's certificate 

operating a conventional aircraft. The risks associated with the operation of the sUAS are so diminished from 

the level of risk associated with commercial operations contemplated by Part 61 when drafted, that allowing 

operations of the sUAS as requested with a private pilot as the PIC exceeds the present level of safety 

achieved by 14 C.F.R. §61.113 (a) & (b).

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

The regulation requires that no person may operate a civil aircraft unless it is in airworthy condition.

As there will be no airworthiness certificate issued for the aircraft, should this exemption be granted, no FAA 

regulatory standard will exist for determining airworthiness. Given the size of the aircraft and the 

requirements contained in the Manual for maintenance and use of safety check lists prior to each flight, an 

equivalent level of safety will be provided.

14 C.F.R. § 91.9 (b) (2): Civil Aircraft Flight Manual in the Aircraft.

Section 91.9 (b) (2) provides:

No person may operate a U.S.-registered civil aircraft...

(2) For which an Airplane or Rotorcraft Flight manual is not required by §21.5 of this chapter, unless there is 

available in the aircraft a current approved airplane or Rotorcraft Flight Manual, approved manual material, 

markings, and placards, or any combination thereof.

The sUAS, given its size and configuration, has no ability or place to carry such a flight manual on the 

aircraft, not only because there is no pilot on board, but because there is no room or capacity to carry such 

an item on the aircraft.
Integra Tower, LLC | 11771 Spruce Run Dr, San Diego, CA 92131 | www.integratower.com 7

The equivalent level of safety will be maintained by keeping the flight manual at the ground control 

point where the operator flying the sUAS will have immediate access to it. The FAA has issued the following 

exemptions to this regulation: Exemption Nos. 8607, 8737, 8738, 9299, 9299A, 9565, 95658, 10167, 10167A, 

10602, 32827, and 10700.

14 C.F.R. § 91.103: Preflight action

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

safety of flight. As FAA approved flight manuals will not be provided for the aircraft an exemption will be 

needed, an equivalent level of safety will be provided as set forth in the Manual. The operator will take all 

actions including reviewing weather, power source requirements, landing and takeoff distances and aircraft 

performance data before initiation of flight.

14 C.F.R. §91.109: Flight instruction:

Section 91.103 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.

sUAS and remotely piloted aircraft, by their design, do not have fully functional dual controls.

Primary flight control is accomplished through the use of a control box that communicates with the aircraft 

via radio communications. The Manual outlines procedures for new operator training and certification using 

a single set of controls during instruction. 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 & 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.

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

Section 91.119 establishes safe altitudes for operation of civil aircraft. The Exemption requests

authority to operate at altitudes from 0 AGL up to 400 AGL, an exemption may be needed to allow such 

operations. As set forth herein, the sUAS will never operate at higher than 400 AGL. It will however be 

operated in restricted areas with a safety perimeter, where the general public will not be exposed to 

operations.

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

location where it is operated. No flight will be taken without the permission of the property owner. Because 

of the advance notice to the property owner and participants in the inspection activity, all affected 

individuals will be aware of the planned flight operations as set forth in Section C of the Manual. Compared 

to flight operations with aircraft or rotorcraft weighing far more than the maximum 55lbs. proposed herein 

and the lack of flammable fuel, any risk associated with these operations is far less than those presently

presented with conventional aircraft operating at or below 500 AGL in surveying and inspection work. In 

addition, the low-altitude operations of the sUAS will ensure separation between these small-UAS operations 

and the operations of conventional aircraft that must comply with Section 91.119.
Integra Tower, LLC | 11771 Spruce Run Dr, San Diego, CA 92131 | www.integratower.com 8

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 sUAS may only have a digital barometric sensor and/or a GPS altitude 

read out, an exemption may be needed. An equivalent level of safety will be achieved by the operator, 

pursuant to the Manual and Preflight Checklist, confirming the altitude of the launch site shown on the 

ground station altitude indicator before flight.

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

Section 91.151 (a) 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 sUAS proposed flight area and the location of its proposed operations 

within a predetermined area, a 30 minute fuel reserve for flight in daylight is reasonable.

Integra’s sUAS operations will be conducted in a controlled closed-perimeter environment, with UA

under 55 pounds, at speeds below 50 Knots, and within VLOS. Integra intends to terminate flights after 30

minutes or with 25% remaining battery power (whichever occurs first). Integra believes this provides an

equivalent level of safety and is practical considering the limited power supply available for operations.

Limiting flights to thirty minutes would greatly reduce the operational utility of the platform.

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

The regulation provides in pertinent part:

(a) Except as provided in § 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 §91. 715 is displayed at the cabin or cockpit entrance so 

that it is legible to passengers or crew.

The sUAS fully loaded weighs no more than 55 lbs. and is 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 

sUAS.

An equivalent level of safety will be achieved by keeping these documents at the ground control 

point where the operator flying the sUAS will have immediate access to them, to the extent they are 

applicable to the sUAS. 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.

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 
Integra Tower, LLC | 11771 Spruce Run Dr, San Diego, CA 92131 | www.integratower.com 9

(c) of this section, have discrepancies repaired as prescribed in part 43 of this chapter...," and others shall 

inspect or maintain the aircraft in compliance with Part 43.

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

sections will not apply to the Applicant. Maintenance will be accomplished by the operator pursuant to the 

Flight Operations and Procedures as referenced in the Manual. An equivalent level of safety will be achieved 

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

areas for limited periods of time. If mechanical issues arise the sUAS can land immediately and will be 

operating from no higher than 400 feet AGL. As provided in the Manual, the operator will ensure that the 

sUAS is in working order prior to initiating flight, perform required basic maintenance, and 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.

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

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

national security - provide more than adequate justification for the grant of the requested exemptions 

allowing commercial operation of Applicant's sUAS in the infrastructure inspection survey industry pursuant 

to the Manual.

Sincerely,

Eric DaVersa

CEO

Integra Tower, LLC