720 S. Colorado Blvd

Penthouse North

Denver, CO 80246

Tel: +1 (334) 578 2900

Fax: +1 (334) 460 8111

www.unmannedexperts.com

E-Mail: operations@unmannedexperts.com

April 20, 2015

U.S. Department of Transportation, Docket Operations

West Building Ground Floor, Room w12-140

1200 New Jersey Avenue, S.E.

Washington, DC 20590

Petition for Exemption Under 14 CFR § 11.81 

to Allow Commercial Use of Unmanned Aircraft Systems

Petitioner:

Unmanned Experts, Inc.

Drew A. Jurkofsky, CKO

720 S. Colorado Blvd, Penthouse North

Denver, CO 80246

Cell: 970-237-1902

Email: drew.j@unmannedexperts.com

Website: www.unmannedexperts.com

Dear Sir or Madam,

This application is substantially based on the FAA’s findings in Exemption No. 11062 granted to 

Astraeus Aerial (FAA-2014-0352), Exemption No. 11109 Clayco, Inc. (FAA-2014-0507), Exemption No. 

11208, Sky-Futures UAS, Inc. (FAA-2014-0641), Exemption No. 11252, Nixon Engineering Solutions, 

LLC. (FAA-2014-0763), Exemption No. 11306, Hawk Aerial, LLC. (FAA-2014-1023), Exemption No. 

11380, First Team Real Estate, (FAA-2015-0052), and in reliance on the analysis provided therein. 

1. Sections from which exemptions are sought: Application is hereby made for exemption from:

a. FAA Modernization and Reform Act of 2012, PL 112-95 FEB. 14, 2012, Section 333

b. 14 CFR Part 21, subpart H

c. 14 CFR Part 61.113(a) and (b)
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d. 14 CFT Part 91:

i. 91.103(b)(2)

ii. 91.105

iii. 91.109

iv. 91.119

v. 91.121

vi. 91.151

vii. 91.405

viii. 91.407

ix. 91.409

x. 91.417

2. Relief sought:

a. Unmanned Experts, Inc. (UMEX) wishes to operate small Unmanned Aircraft Systems 

(UAS) for commercial purposes to include (but not limited to) videography, 

photography, inspections and analyses. This relief is sought because commercial use 

of UAS is currently prohibited by law unless performed under an exemption.

b. This exemption will cover use of the following airframes, all of which will weigh less 

than 55 pounds including payload and energy sources:

i. DJI S800 EVO;

ii. DJI Phantom 2 and Inspire models;

iii. Tarsier Systems MoAC;

iv. GerMAP G220;

v. AscTec Falcon 8;

vi. Other models to be added by future amendment to this exemption.

3. Public benefit:

a. Use of UAS technology to obtain imagery, information and data currently obtained by 

use of manned flight or manual methods:

i. Reduces statistical risk to human life due to manned aircraft accidents (e.g., 

power line inspections) and due to other dangerous activities that can be 

avoided (e.g., scaffolding/rigging failures during stack or bridge inspections).

ii. Reduces the cost of obtaining such information, which benefits consumers and 

the economy.
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iii. Reduces environmental impact by eliminating sources of hydrocarbon 

emissions from manned aircraft.

4. Safety not adversely affected:

a. Aircraft will be registered and marked in accordance with Section 44711 and Part 47 

and Part 45, Subpart C.

b. Aircraft will comply with maintenance and inspection requirements of the 

manufacturer. All repair and maintenance work will be conducted or approved by 

qualified personnel such as those authorized by Robotic Skies (or equivalent), and will 

require a test flight after such work. Records of all maintenance and repair work will 

be kept in a maintenance log for each aircraft.

c. All flight operations will be conducted by two individuals who will maintain verbal 

communication capability with each other at all times during the flight, and who will 

remain stationary on the ground during the flight operations:

i. A Pilot In Command (PIC) who possess the following credentials:

1. An airline transport, commercial, private, recreational, or sport pilot 

certificate.

2. A Third Class medical certificate issued under 14 CFR 67 or valid U.S. 

driver license.

3. A Bi-annual flight review under 14 CFR 61.56

4. A certificate of competency for UAS issued by UMEX (or equivalent 

certification).

5. At least 200 cycles and 25 hours of flight experience in a UAS rotorcraft 

(or UAS fixed-wing in the case of fixed-wing flight operations under this 

exemption). Such cycles and hours may be gained during flights under 

this exemption if a safe distance is maintained from persons in 

accordance with 14 CFR 91.119.

6. At least 5 hours of flight experience and 3 takeoffs and landings in make 

and model being flown in the prior 90 days. Such cycles and hours may 

be gained during flights under this exemption if a safe distance is 

maintained from persons in accordance with 14 CFR 91.119.

ii. A Visual Observer (VO).
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d. All flight operations will be conducted in accordance with valid Certificates of 

Authorization.

e. All flight operations will comply with the following:

i. The manufacturers’ Aircraft Flight Manuals and operation guidelines.

ii. UMEX flight operations policies including lost communication and other 

emergency and safety procedures.

iii. Conducted in VMC conditions during daylight hours.

iv. PIC and VO will maintain visual line of sight (VLOS) at all times.

v. Pre-flight inspections (including ground control station, if any) and safety risk 

assessments will be conducted prior to each flight.

vi. Flight altitudes will remain at or below 400 feet above ground level.

vii. Flight speeds will not exceed 87 knots.

viii. Not take place over urban areas or within 5 miles of an airport.

ix. Not be made near persons as required in 14 CFR 91.119 and not over persons 

on the ground without their prior permission.

x. Each flight will be logged in both the PIC’s logbook and the aircraft logbook.

xi. Not exceed 80% of the battery capacity of the aircraft.

xii. Any incidents will be reported within 24 hours of occurrence.

xiii. Any applicable local FSDO requirements.

xiv. All other applicable regulations concerned with the operation of aircraft.

Please advise us of any additional information or changes that are required.

Very Respectfully,

Drew A. Jurkofsky

Chief Knowledge Officer

Unmanned Experts, Inc.