1

PJ Helicopters Inc.

Attn: Seth Gunsauls

903 Langley Way

Red Bluff, Ca. 96080

US Department of Transportation

Docket Management System

1200 New Jersey Ave., SE

Washington DC 20590

RE: Exemption Request Pursuant to Section 333 of the FAA Reform Act and Part 11 of 

the Federal Aviation Regulations from: 14 CFR 61.3; 14 CFR 61.113(a) and (b); 14 CFR 

91.7(a); 14 CFR 91.119(b) and (c); 14 CFR 91.121; 14 CFR 91.151(a)(1) and (b); 14 CFR 

91.405(a); 14 CFR 91.407(a)(1); 14 CFR 91.409(a)(1) and (2); 14 CFR 91.417(a) and (b)

To Whom It May Concern,

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

Helicopters Inc. (referred to as Petitioner), herby applies for and exemption from the 

listed Federal Aviation Regulations to allow operations of a commercial Unmanned 

Aircraft System (UAS). All proposed operations will be conducted under the conditions 

outlined in this petition or set forth by the FAA by Section 333.

Background:

The Petitioner is a family-owned world class precision helicopter lift service serving all 

industries nationwide since 1971. In the over 40 year history PJ Helicopters has 

maintained a flawless safety record with ultimate customer satisfaction. PJ Helicopters 

has extensive experience in the construction and patrolling of Utility Lines and Towers. 

We have filed this petition for exemption to operate a UAS for Utility Tower and Line 

Inspections. We currently perform this service in our helicopters. By switching to a UAS 

for this specific application the Petitioner feels we can provide a safer more efficient 

way of carrying out the Utility Inspections. The lightweight UAS greatly reduces the 

potential for harm of participating and nonparticipating individuals as well as property 

on and around the worksite location.
2

Unmanned Aircraft System:

The Petitioner is proposing to use the Carbon Core Cortex Quadrocopter for their UAS 

operations. The Cortex airframe is made of carbon fiber and weighs less than 10 

pounds, completely assembled. The overall diameter of the Cortex is 1,200mm. The

UAS will feature dual flight control redundancy capable of 256 waypoints, auto flight, 

auto land, hover lock, and return home features. The Cortex will have the battery 

capacity for up to 30 minutes of uninterrupted flight. The UAS will never be operated at 

a speed higher than 50 knots, and never higher than 400 ft. AGL. Before each flight the 

UAS will be updated with failsafe landing locations for the specific operation; should the 

link be lost during flight the UAS will return safely to the predetermined location and 

land. Given the size, speed of operation, lack of flammable and explosive liquids the 

Petitioner feels this would be a great asset to their operation and increase safety 

performance. 

UAS Operator:

Each operator who will be in control of a UAS will undergo training and safety 

procedures of the UAS. Each operator will accumulate 25 hours of total time before 

operating the UAS in any commercial setting. The staff employed by the Petitioner

already has extensive knowledge of airmanship and weather forecasts which will 

translate easily to UAS operations. Recurrent training will be held by the Petitioner in 

order to assure that qualifications and skills are being met by all operators. Before each 

flight of the UAS the operator will be responsible for checking weather conditions and 

determining that safe operations may be conducted. The operator will also be 

responsible for determining the airworthiness of the UAS by conduction preflight 

inspections per the Original Equipment Manufacturer recommendations. If the preflight 

inspection, reveals any condition that may affect safe operations, the UAS will be 

grounded until proper maintenance and repairs have been made. All maintenance and 

alterations will be documented in the aircraft records. 

 

Operating Parameters:

The Petitioner has set forth the following parameters for UAS operations. The UAS shall 

always be inspected before conducting any operations. Only certified personnel with 

proper training may act as the UAS operator. The operator must be designated before 

the beginning any flight operations and cannot transfer that designation for the 
3

duration of any flight. Visual Line of Sight must be maintained at all times by the 

operator. The UAS will not be operated any faster than 50 knots and shall never reach 

an altitude higher than 400 ft. AGL. The UAS shall not fly in wind conditions any greater 

than 20mph. Flight operations will always be conducted under VFR conditions. UAS 

operations will be conducted over Utility Property, or Utility Right of Way areas. The 

UAS will remain clear of and yield the right of way to all other manned vehicles. 

The UAS will be integrated into the Petitioner’s existing Standard Operating Procedures 

and Safety Management System. By doing this the Petitioner is confident that it will be 

able to operate the UAS while being able to maintain or exceed current levels of safety.

Public Interest:

The Petitioner is requesting to operate a UAS for Utility Line and Tower inspections. 

This is a required task to ensure utility lines are in good condition and functioning 

properly. The Petitioner currently conducts this task using a fleet of helicopters. The 

introduction of a UAS will greatly reduce the risk of these operations. The UAS carries 

no flammable fuel, or liquids that fixed-wing or rotorcraft do. The UAV has no internal 

pilot or passengers so the potential for human injury is greatly reduced. The UAS is also 

significantly quieter that any fixed wing or rotorcraft airframe, reducing the public 

disturbance during operations. With the size, operational speed, and weight limits of 

the UAS it is reasonable to say that operations carried out by the Petitioner will be at 

least as safe if not safer than any conventional aircraft performing the same duty.

14 CFR 61.3 Requirements for Certificates, Ratings, and Authorizations 

14 CFR 61.113(a) and (b) Private Pilot Privileges and Limitations: Pilot in Command

The Petitioner asserts that since the UAS will not carry any pilot or passengers on board, 

the proposed operations will not adversely affect safety by requiring the operator in 

control of aircraft to have a private pilot or a commercial pilot certificate, as long as they 

have knowledge of airmanship and possess the skills to operate the UAS. In support of 

its position, the Petitioner argues that, since there are no standards for either private or 

commercial UAS pilot certificates, knowledge of airspace regulations and dexterity in 

the control and operation of the UAS acquired from actual operation of the aircraft will 

be the most important factors in establishing an equivalent level of safety. Through 

ground school and internal training the proper knowledge of airmanship can be 

achieved to maintain safe flight operations. 
4

Furthermore, the Petitioner explains that, given the restricted and controlled airspace 

within which operations will take place, the key factors needed by the operator are 

knowledge of the airspace within which the operation will take place and how that 

airspace fits into the National Airspace System (NAS). The Petitioner also states that it 

cannot be assumed that a private pilot or commercial pilot, approved to operate a 

rotorcraft or fixed wing aircraft, has the skill or ability to safely operate an unmanned 

aerial system, operating at 400 ft. AGL or lower, within strictly controlled pre-approved 

airspace.

The Petitioner is confident that with the proper training and safety measures put in 

place it can effectively carryout it’s proposed operations. Hands-on experience with the 

UAS is a far more effective guarantee of flight safety than a private pilot or commercial 

pilot certificate would be, until the FAA Pilot Certificate requirements catch up to the 

UAS technology.

The risks associated with the operation of the UAS (given its size, speed, operational 

capabilities, and lack of combustible fuel) are so diminished from the level of risk 

associated with private pilot operations or commercial operations contemplated by Part 

61 with conventional aircraft (fixed wing or rotorcraft), that allowing operations of the 

UAS as set forth in this petition meets or exceeds the present level of safety.

It is unfeasible to state that a pilot with a certification (private or commercial) would be 

able to operate the UAS to a higher level of safety than a person who does not hold any 

pilot certificate, provided they have proper knowledge of airmanship, and are familiar 

with the UAS he or she is operating. Currently there is no training included in private 

pilot or commercial pilot certification process regarding UAS operations. An equivalent 

level of safety will be provided by allowing operation of the UAS without a private pilot’s 

certificate or a commercial pilot’s certificate, under the conditions set forth herein.

14 CFR 91.7(a) Civil Aircraft Airworthiness 

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

airworthy condition. Since there is no regulatory standard for determining 

airworthiness of a UAS, there will be no certificate issued. Therefore at this time 

regulation 91.7(a) is not applicable for UAS operations and an exemption is needed. 

However, the Petitioner will follow all safety and inspection procedures outlined by the 
5

Original Equipment Manufacturer (OEM) to determine airworthiness. The operator will 

determine the airworthiness of the UAS by conducting preflight and post flight 

inspections. If at any time the operator determines the UAS not be airworthy it is to be 

grounded immediately until all proper repairs have been made. The UAS will undergo a 

test flight after any such repairs to ensure functionality before it is returned to 

commercial operations.

14 CFR 91.119(b) and (c) Minimum Safe Altitudes

The Petitioner’s requested relief from14 CFR 91.119(b) and 14 CFR 91.119(c), as there 

will be times when the UAS will operate over congested area’s to inspect utility towers 

or lines located on Utility Land or Utility Right of Way. Exemption from 91.119(b) will be 

needed to conduct operations. The regulation states, “Over any congested area of a 

city, town, or settlement, or over any open air assembly of persons, an altitude of 1,000 

ft. above the highest obstacle within a horizontal radius of 2,000 ft. of the aircraft.” 

With the UAS having an operation ceiling of 400 ft. 91.119(b) is not applicable for the 

Petitioner to conduct its proposed operations in compliance of this regulation. For the 

Petitioner working over congested areas is very common practice. The Petitioner is very 

aware of the consideration that is needed to safety during these types of operations. 

The operator will make a safety assessment of the risk of the operation under the 

proposed conditions and will determine that it does not present an undue hazard before 

flight operations are to begin. Prior to conducting UAS operations, all persons not 

essential to flight operations (nonparticipating persons) must remain at appropriate safe 

distances.

The Petitioner notes that because it requests to operate at altitudes only up to 400 ft.

AGL, an exemption is needed from 14 CFR 91.119(c) to allow for such operations. As 

discussed in Exemption No. 11109 to Clayco, Inc. (Docket No. FAA-2014-0507), 

operations conducted closer than 500 feet to the ground may require that the UAS to be 

operated closer than 500 feet to essential persons, or objects that would not be possible 

without additional relief. Operations will always be conducted in an authorized, 

controlled area. Due to the specific operation proposed the UAS will at times be closer 

than 500 ft. to the operator, essential people, vehicles, and structures therefore 

exemption is needed from 91.119(c).

The Petitioner is confident that since it currently carries out the operations described in 

this document with rotorcraft, it will be able to at least maintain or exceed current 

safety levels by utilizing a UAS. 
6

14 CFR 91.121 Altimeter Settings

The Petitioner is also requesting an exemption from regulation 91.121, as the UAS will 

have a GPS altitude readout instead of a barometric altimeter required by the 

regulation. The Petitioner and operator will achieve an equivalent level of safety via live 

flight data and preflight safety checklist set forth by OEM. The operator will confirm the 

altitude of the launch site shown on the GPS altitude indicator before flight in order to 

ensure accuracy.

14 CFR 91.151(a)(1) and (b) Fuel Requirements for flight in VFR Conditions

This regulation prohibits any person from beginning a flight in a fixed-wing aircraft 

under VFR conditions (with consideration of wind and forecast weather conditions) 

unless there is enough fuel to fly to the first point of intended landing and, assuming 

normal cruise speed – (1) During the day, to fly after that for at least another 30 

minutes. Part B of this regulation describes operation requirements for rotorcraft.

The UAS has a battery that provides up to 30 minutes of powered flight. In order to 

comply with this regulation flight times would have to be limited to 10 minutes before 

the UAS would need to be grounded in order to maintain proper battery reserve as 

described in part 91.151. This limited flight time is not feasible and would make 

operations nearly, if not completely impossible. All operations will be conducted with a 

fully charged battery. Flight time will be limited to 30 minutes or when 25% battery life 

remains; whichever is to occur first. The operator will be able to monitor battery 

percentage thorough their flight controls. With the operator maintaining VLOS and with 

25% battery remaining, there will be still be sufficient time to return the UAS to the 

planned operational landing zone. Therefore, the regulation is not applicable to the 

UAS, however the Petitioner will maintain its own safety standard as stated above. 

14 CFR 91.405(a); 91.407(a)(1); 91.409(a)(1) and (2); 91.417(a) and (b) Maintenance 

Inspections and Records

The Petitioner is also requesting relief from maintenance and inspection requirements 

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

exemption should be granted under these sections because the UAS to be used is not a 

U.S. registered civil aircraft with an airworthiness certificate and therefore 14 CFR 91 
7

regulations do not apply. Furthermore a designated official certified by the FAA to have 

maintenance signature authority does not currently exist for UAS operations. However, 

the Petitioner will employ a maintenance and quality assurance program which meets 

or exceeds applicable regulatory standards for U.S. registered aircraft. No operations 

will take place without inspections and maintenance items being completed. All 

inspections and maintenance action items will be documented in aircraft logs. The 

Petitioner further states that Original Equipment Manufacturer (OEM) requirements will 

be followed in the performance of maintenance, inspection and record keeping for the 

UAS.

The Petitioner states that the OEM defines the maintenance requirements for the 

unmanned aircraft and per those requirements, the Petitioner will ensure that it will 

conduct all inspections to precise OEM standards. Again, no flight operations will take 

place without required inspections and maintenance items being completed. Further, all 

inspections and maintenance action items will be documented in aircraft logs. The 

Petitioner will comply with the manufacturer's UAS component, maintenance, overhaul, 

replacement, inspection, and life limit requirements. The operator is responsible for a 

through preflight and post flight inspection of the UAS to ensure airworthiness. The 

inspection shall be conducted in accordance with the instructions outlined in the 

manufactures user’s manual. When necessary only qualified OEM maintainers will 

perform higher level inspections and maintenance or overhaul per OEM standards.

Review of Regulations seeking exemption from:

14 CFR 61.3

14 CFR 61.113(a) and (b)

14 CFR 91.7(a)

14 CFR 91.119(b) and (c)

14 CFR 91.121

14 CFR 91.151(a)(1) and (b)

14 CFR 91.405(a)

14 CFR 91.407(a)(1)

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

14 CFR 91.417(a) and (b)
8

Petitioner Closing Statement

The Petitioner feels that with a grant of exemption it will be able to carry out Utility 

Inspections with a new level of unprecedented safety. Inspections are inherently 

dangerous, but with the attention to detail and safety procedures already put in place 

the Petitioner has been able provide excellent service year after year to its customers. 

Safety has always been a high priority here, and with a great SMS in place we strive hard 

to asses any potential risks or hazards and reduce the chance of injury or damage to any 

persons or property. Due to the size, weight, operational speed, and lack of flammable 

fuels in the UAS the potential for injury or damage is greatly reduced. This our ultimate 

goal, to provide a more efficient and safer operation. We invite you to please look at 

our website, www.pjhelicopters.com for further information regarding our company’s 

operations.