September 11, 2015

U.S. Department of Transportation 

Docket Management System 

1200 New Jersey Avenue SE 

Washington, DC 20590 

RE: Petition for Exemption from Certain Federal Aviation Regulations according 

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

Dear Sir or Madam: 

ULC Robotics (ULC) is applying for an exemption from the Code of Federal 

Regulations as detailed below.

The exemption would permit commercial operation of small unmanned aircraft 

systems (sUAS) in the national airspace (NAS) as regulated by the FAA for aerial data 

collection to include, but not limited to the following uses:

I. Remote sensing and measuring by an instrument(s) aboard the sUAS including

A. imagery (photography, video, infrared, etc.)

B. electronic measurement (precision inspection, RF analysis, etc.)

C. chemical measurement (particulate measurement, etc.)

D. or any other gathering of data by instruments aboard the sUAS

II. Assisting in maintaining public safety in times of emergency including

A. aerial photography and evaluation of emergency response scenes and 

operations with ULC agreement

B. aid in emergency services support and search and rescue with ULC

agreement
ULC Robotics 333 Petition 2

All operations performed by ULC are cost effective and protect the public by reducing 

the size of the aircraft from one weighing up to several tons to one weighing less than 

55 pounds. In addition, the UA does not use flammable liquid fuel. Instead, it operates 

on high-energy batteries. The UA is flown in the lower strata of controlled and 

uncontrolled airspace, at 400 ft. AGL and below. ULC commercial operations will be 

performed according to FAA regulations or amended FAA regulations as permitted

under a Section 333 Grant of Exemption.

BACKGROUND AND REFERENCES

The US Department of Transportation Pipeline and Natural Hazardous Materials 

Administration estimates that there are approximately 2.5 million miles of pipeline 

transporting natural gas and other gases. Twenty-five percent of the energy Americans 

consume travels through these pipelines. Most of the consumption comes from home 

heating, requiring a highly complex distribution system utilizing more than 210 pipeline 

networks across the United States. These pipelines contribute more than two trillion 

dollars to the American economy and provide more than nine million jobs.

Much of the pipeline infrastructure was built post World War II. Indeed, more than half 

of America’s natural gas transmission pipelines were installed before 1970. Every mile of 

this network is now susceptible to corrosion, both internal and external, fracturing, 

damage by outside parties, and tensile flaws. To mitigate the risk of environmental 

damage and enhance public safety, government regulation requires pipeline operators to 

continually audit the safety and integrity of their pipeline infrastructure.

ULC Robotics works with energy and utility companies across the United States to solve 

infrastructure, technical, and operational challenges by developing and deploying 

technology which can enable repair or inspection of hard-to-access infrastructure. ULC 

Robotics has a proven track record of delivering commercial-level innovative 

technology that is used by utility and energy customers to provide: cost savings, 

efficiency and most importantly, improved safety to utility workers, contractors and the 

general public. Typically this is achieved by repairing gas leaks through trenchless 

robotic technology which creates a safer, gas-free environment for the public. However 

gas leaks also occur above ground along protracted stretches of pipelines, in areas that 

are difficult to reach by road, high above the ground on the outside of buildings or 

utility structures, and many other hard to access areas.

Traditional methods of pipeline inspection include slowly walking the entire distance of 

the main, which may prove problematic when the pipeline enters areas that are difficult 

to traverse. For hard to reach, overhead pipelines, expensive scaffolding is erected for 
ULC Robotics 333 Petition 3

maintenance workers to scale while performing gas leak inspection. This exposes the 

utility worker to the risk of falls. Both methods put the maintenance worker in close 

proximity to gas leaks, which may be severe enough to put the worker at risk of 

encountering a leak close to rupturing. However, without a long distance means of 

inspection to discover the problem area, the maintenance worker could walk into a 

hazardous situation without even realizing it. 

ULC also works closely with a number of major utility companies to ensure the safety of 

structural and electric infrastructure systems. In order to assess the integrity of these 

systems, maintenance workers may utilize helicopter surveys to scan electrical lines or 

buildings. Helicopters are costly and utilize highly flammable jet fuel that is its own 

hazard. In more closely confined urban areas this may not be practical, so maintenance 

workers must ascend electrical towers in order to perform inspections by hand. If there 

is a problem with one of the power lines themselves, a utility worker will don a special 

suit, creating a personal faraday cage, and traverse the lines, in order to assess where the 

damage may be. This type of utility inspection is necessary, though extremely dangerous 

due to the heightened risk of electrocution and falling. 

Worker accidents, including falls, are a major concern when attempting to inspect utility 

systems in highrise locations and are a source of workplace fatality and injury on utility 

and construction sites. Utilizing sUAS for utility inspections would significantly reduce, 

if not eliminate workplace falls and accidents by reducing or eliminating the need for 

workers to carry out tasks at unsafe, risky heights. Employing sUAS in these situations 

could save workers lives. 

Utilities (water, electricity and gas) are essential services that play a vital role in economic 

and social development. Ensuring the safety and repair of the US utility systems are 

what ULC Robotics works to accomplish. Creating a sUAS utility assessment program 

with state of the art leak detection technology, cameras, and sensors would dramatically 

increase the safety of utility workers and customers by increasing the chance of locating 

gas leaks in these difficult to detect areas, decrease the risk of workers who would 

attempt to access these locations via scaffolding or high rising structures, and increasing 

the chance of repairing gas leaks before they ruptured or caused an explosion.

ULC wishes to increase its effectiveness with its clients and contracting government 

agencies, increase the safety level of its employees and contracted workers on inspection 

sites and remain competitive economically by employing a UA during many of its 

operations. Therefore, ULC is submitting this FMRA Section 333 Exemption petition.

In support of the petition and the FAA’s evaluation process, we reference previously 

granted 333 exemption petitions by the FAA with same or similar purposes as follows:
ULC Robotics 333 Petition 4

• Aerial pipeline inspection: exemption no. 12105, X-Cam Aerial 

Solutions, Inc.

• Aerial digital imagery, survey, and inspection: exemption no 11992, 

Aerial Check UAVs

• Further commercial purposes for safety and public awareness of UA 

uses; exemption no. 11409, Wade Bell

• Aerial photography and evaluation of emergency response scenes and 

operations: exemption no. 12508, Castle Rock Fire and Rescue 

Department

• Emergency services support and search and rescue exemption no. 

12515, RPA/UAS Consulting LLC

DESCRIPTION OF PETITIONER

For more than 15 years, ULC has imagined, designed and built solutions to a wide range 

of problems for some of the most well known names in the energy industry. ULC 

develops unique solutions to energy industry technical challenges; from the creation of 

simple tools to complex electromechanical systems. Beginning with the conception of 

new ideas through redesigns of existing products to commercialization and full 

production builds, ULC provides a range of technical services that support the Utilities 

Industry’s needs.

NAME OF PETITIONER

Aubrey Anderson

ULC Robotics

88 Arkay Dr

Hauppauge, NY 11788

Telephone: 631-667-9200

AGENT FOR PETITIONER

Mr. Brian Dyer

RPS-West

Email: Brian.Dyer@RemotePilotSystems.com

ULC Robotics requests a Summary Grant of Exemption for the following aircraft:
ULC Robotics 333 Petition 5

A – Aibot X-6 approved under Exemption No 11356

B – Yuneec Typhoon Q500 4K approved under Exemption No 11438

C – DJI Inspire 1 approved under Exemption No 11204

D – 3DR Solo approved under Exemption No 11832

Thank you for your time and attention..

Sincerely,

Brian Dyer
ULC Robotics 333 Petition 6

DESCRIPTION OF UNMANNED AIRCRAFT SYSTEMS

ULC requests the following aircraft:

• the Aibot X6 

• the Yuneec Typhoon Q500

• the DJI Inspire 1

• the 3DR Solo

Aibot X6

The Aibot X6 is an electric multirotor aircraft configured as a vertical take-off and 

landing hexacopter in a V-6 designed for aerial survey and inspection. Aibotix in 

Germany has delivered more than 200 aircraft since 2011. The flight control system used 

with the aircraft is designed and manufactured in Germany, has undergone continuous 

improvement and development, with all source code modules under company control.

Safety features include:

• Mitigation for loss of radio control link, through programmable emergency 

failsafe to controlled descent or, if GPS signal is sufficient, to return to point 

of takeoff.

• The pilot may override waypoint programming with manual stick control in 

case of emergency or route adjustment.

• Telemetry is displayed on the pilot’s handheld controller and maybe 

announced by voice.

• The X6 is optimized for aerial inspection with safety features to reduce pilot 

workload, such as attitude stabilization, GPS satellite-assisted navigation, 

return to home and auto land.

The aircraft is slightly less than 4 ft. in diameter, is made of carbon-fiber reinforced 

polymer in a high visibility color, with protective blade guards surrounding the six rotors, 

and is designed for a maximum takeoff weight of less than 15 pounds and a flight time of 

about 20 minutes with its dual-battery power. Maximum speed is about 55 mph, but

treats this limitation as an emergency reserve, and plans no flying at greater than 25 mph. 

The aircraft carries no flammable liquid fuel.
ULC Robotics 333 Petition 7

Radio control and video transmission systems meet FCC requirements for operation in 

the unlicensed spectrum of the 2.4 and 5.8 GHz ranges. Manufacturer warnings about 

interference from devices operating at or near these frequencies or their harmonics are 

documented in the manufacturer’s manual.

Safety features include:

• Mitigation for loss of radio control link, through programmable emergency 

failsafe to controlled descent or, if GPS signal is sufficient, to return to point 

of takeoff.

• The pilot may override waypoint programming with manual stick control in 

case of emergency or route adjustment.

• Telemetry is displayed on the pilot’s handheld controller and maybe 

announced by voice.

• The X6 is optimized for aerial inspection with safety features to reduce pilot 

workload, such as attitude stabilization, GPS satellite-assisted navigation, 

return to home and auto land.

Yuneec Typhoon Q500/Q500 +

The Typhoon Q500 series are vertical takeoff and landing unmanned aircraft of 

quadcopter design. Manufactured by Yuneec International Co. Ltd., the Typhoon Q500 

has the world's first Smart Transmitter (the "ST-10 series Ground Station" with 10 

channels) combining a 2.4GHz radio control transmitter with a 5.8GHz digital video link. 

It operates on a built-in Android touch screen. Safety features include Geo Fencing, 

Home Mode and Return Home. Geo Fencing prohibits the aircraft from exceeding a 

programmed permitted radius. When activated, Home Mode will automatically return the 

aircraft within a 10-foot radius of its starting point. Should the transmitter signal be lost 

or visual line of sight with the aircraft impaired, upon signal, Return Home will 

automatically take control of the aircraft and return it to the operator/base station. 

Takeoff weight with manufacture provided camera and gimbal payload and battery is 3.75 

lbs.

The Typhoon Q500 dimensions are 16.5 by 16.5 by 8.3 in. with a diagonal of 22.2 in.

without rotor blades attached. It can fly up to 25 minutes on its 5400mAh 3S 11.1V 
ULC Robotics 333 Petition 8

lithium polymer battery. Radio control and video transmission systems meet FCC 

requirements for operation in the unlicensed spectrum of 5.8 GHz ranges. 

DJI Inspire 1

The Inspire 1 is a remote-controlled, ultra-light weight, vertical take-off and landing 

unmanned quadcopter with a transportable ground station. It is manufactured by DJI, 

which is headquartered in the Shenzhen, Guangdong province of China.

The Inspire 1 is equipped with an onboard computer stabilization controller and GPS. 

System software allows the operator to monitor the flight’s performance via a smart 

phone or tablet providing them with a real time display of the altitude, battery life, GPS 

connections and camera view. In case of lost signal to the aircraft from the ground 

station, the Inspire 1 includes non-GPS safety features: Failsafe, Return Home and 

Dynamic Home Point to bring the flight to a safe conclusion. 

The Inspire 1 weighs approximately 6.4 lb. and is 22 in. by 22 in. by 8 in. The Inspire 1 

uses carbon fiber and plastic components in its construction. The Inspire 1 also allows 

for geo-fencing, letting the operator set safe altitude and distance limits for the flight. 

The Inspire 1’s battery reports the voltage of each cell, the total lifetime charges and 

discharges, and the overall health and battery status. Advanced algorithms calculate the 

distance of the aircraft and estimated time to return home, letting the operator know 

when to fly back. The low battery emergency procedure is triggered when the DJI smart 

battery is depleted to a point that may affect the safe return of the aircraft. The 

thresholds for these warnings are automatically determined based on the current aircraft 

altitude and its distance from the Home point.

3DR Solo

The 3DR Solo is an electric motor, ultra-light weight, vertical take-off and landing 

unmanned quadcopter. It uses the Pixhawk 2 autopilot system — two 1 GHz 

computers, one on the copter and one in the controller connected via a dedicated Wi-Fi 

signal. Radio communications are set at 2.4 GHz. It has four brushless 880 kV motors 

onto which its propellers attach. Lithium polymer batteries power the motors.
ULC Robotics 333 Petition 9

The flight controller relies on GPS for navigational coordinates, plus uses data from 

gyros, accelerators, and other sensors to keep the aircraft safely flying. Solo has 

controlled, predetermined flight patterns generated from operator input. Its control 

system is also programmed for immediate safety with pause (stable hover) and “safety 

net” (limiting range and altitude) features. It comes preprogrammed to not exceed 150 

ft. AGL. After landing or returning home, Solo will automatically detect the landing and 

stop the motors. 

Standard flight time for the Solo without a payload is approximately 25 minutes. 

Maximum speed is listed in the user manual as 33 mph. The Solo weighs 3.3 lb. with a 

maximum payload of 1.0 lb. Its dimensions are 18 in. motor to motor, with propeller 

dimensions 10 in. with a diameter of 4.5 in. The propellers are constructed with glassreinforced nylon.

EXTENT OF RELIEF SOUGHT AND WHY 

ULC asks for relief from regulations tabled below, which the authority of the FAA has 

previously granted in exemption certificates number 11062 along with six others 

described as “in commonality,” and in number 11109, which are for use of electric 

rotorcraft. This incorporates the conditions and limitations of these grants of exemption, 

and in some cases imposes stricter limits on its own operations. 
ULC Robotics 333 Petition 10

CFR CODE CITATIONS 

14 CFR 

PART 

SUMMARY OF 

REGULATION 

REASON FOR 

EXEMPTION 

REQUEST 

EQUIVALENT LEVEL OF 

SAFETY 

61.113 

(a) 

Private pilot 

privileges and 

limitations: pilot in 

command

Holder of private pilot 

certificate may not act as 

pilot in command (PIC) 

for compensation or hire. 

Flying for compensation 

on inspection missions is 

central to purpose of 

exemption request. 

Characteristics of aircraft, VLOS, 

under 400 ft. AGL, trained visual 

observer in radio communication 

with pilot; remote site, 

construction industry safety 

protocols enhanced by flight 

safety plan; PIC with airman’s 

certification, appropriate medical 

and vision qualification, currency 

in the aircraft listed on the 

certificate, pilot training, testing, 

proficiency with similar and same 

model UA; and 

inspection/maintenance are 

defined in the and will ensure 

equivalent levels of safety.

61.113 

(b) 

Private pilot 

privileges and 

limitations: Pilot in 

command

Holder of private pilot 

certificate may act as PIC 

for compensation or hire if 

flight is incidental to 

business or employment 

and does not carry 

passengers for 

compensation or hire. 

Flying for compensation 

on inspection missions is 

central to purpose of 

exemption request, not 

incidental to business or 

employment. 

There is no passenger or pilot on 

board the UA, thus safety issues 

are different from a manned flight. 

ULC’s aircraft have programmable 

automated safety features and 

emergency responses, have preflight checks for safety beyond 

commercial manned aircraft, can 

be geographically restricted by 

operator with programmable 

control points, have 

communications with the PIC 

regarding fuel loss and other flight 

hazards. PIC will have ground 

school training certificate and 

additional 25 hours logged flight 

time and 25 hours classroom and 

field instruction as stated in 

UFOM.
ULC Robotics 333 Petition 11

14 CFR 

PART 

SUMMARY OF 

REGULATION 

REASON FOR 

EXEMPTION 

REQUEST 

EQUIVALENT LEVEL OF 

SAFETY 

91.119 

(c) 

Minimum safe 

altitudes over other 

than congested 

area 

Operating closer than 500 

feet to a person, vehicle, or 

structure may be necessary 

for pipeline and equipment 

inspection. 

People will not be allowed over, 

under or within 500 feet laterally 

of the aircraft in flight. Some 

flights may require the 

participation or guidance of 

industry personnel, positioned as 

close as 200 feet. will brief them 

on safety and obtain necessary 

consent. Industry site safety rules 

will be followed. 

91.121 Altimeter settings Procedures to set and 

confirm altitude do not 

provide for operation of 

remote telemetry to SUAS 

pilot. 

An onboard air pressure sensor 

and software resolve height 

differences as small as one 

centimeter. Altitude is controlled 

by measuring air pressure and the 

z-axis accelerometer/GPS values. 

The starting point is a relative 

height measurement calculated by 

the flight controller. Altitude 

above ground is displayed on the 

pilot's handheld controller by 

telemetry, and alarms can signal 

conditions of interest. 400 feet 

AGL is the maximum permissible 

in the UFOM, which describes 

altimeter procedures. 
ULC Robotics 333 Petition 12

14 CFR 

PART 

SUMMARY OF 

REGULATION 

REASON FOR 

EXEMPTION 

REQUEST 

EQUIVALENT LEVEL OF 

SAFETY 

91.151 

(b) 

Fuel requirements 

for flight in VFR 

conditions

Rotorcraft under VFR 

must carry enough fuel to 

reach first landing point 

and then another 20 

minutes. The multirotor 

aircraft specified in this 

petition is designed to fly 

missions of 25 minute 

durations. 

On aircraft specified, battery 

voltage under load is displayed on 

the pilot's handheld controller 

during flight. Battery chemistry 

does not support adequate current 

discharge below about 3 v per cell. 

Circuitry in the onboard flight 

controller measures voltage and 

will start a failsafe procedure to 

land before summed minimums 

are reached. In the event that one 

or more cells fail, these minimums 

may be reached sooner than 

expected, due to rapid current 

drain against a smaller number of 

functioning cells. pilots are trained 

to monitor voltage and recognize 

abnormal discharge in flight and 

to land sooner than forced. If 20 

minutes of flight time or 25% of 

reserve voltage under load is 

reached, pilot must commence 

landing.

91.405 

(a) 

Maintenance 

required

Required inspections and 

discrepancies repaired 

between the required 

inspections pertain to 

certificated manned 

aircraft and procedures 

conducted by licensed 

maintenance personnel. In 

the absence of certification 

requirements for SUAS 

and SUAS maintenance 

personnel, reasonable 

alternatives must be 

developed to maintain 

equivalent levels of safety. 

ULC will document maintenance, 

overhaul, replacement and 

inspection requirements in the 

absence of manufacturer's 

requirements; will document and 

maintain maintenance records and 

technician qualification criteria in 

the UFOM. 
ULC Robotics 333 Petition 13

14 CFR 

PART 

SUMMARY OF 

REGULATION 

REASON FOR 

EXEMPTION 

REQUEST 

EQUIVALENT LEVEL OF 

SAFETY 

91.405 

(b) 

Maintenance 

records

Qualifications for 

maintenance personnel for 

SUAS were not 

contemplated by these 

regulations, and a 

reasonable alternative must 

be developed to maintain 

equivalent levels of safety. 

Qualifications, competence and 

testing for maintenance personnel 

are defined in the UFOM. 

91.407 

(a) (1) 

Operation after 

maintenance, 

preventive 

maintenance, 

rebuilding, or 

alteration

There is no authorization 

procedure for a person 

who can approve a return 

to service of an SUAS, and 

a reasonable alternative 

must be developed to 

maintain equivalent levels 

of safety. 

Procedures for the PIC to test 

then approve a return to service 

after maintenance are defined in 

the UFOM. 

91.409 

(a) (1) 

Inspections Annuals conducted by a 

qualified inspector require 

authorization criteria for 

that inspector, not yet 

defined for SUAS. A 

reasonable alternative must 

be developed to maintain 

equivalent levels of safety. 

Schedules for inspection and 

responsibilities of the PIC and 

qualified technician are described 

in the UFOM. 

91.409 

(a) (2) 

Inspections Issuance of airworthiness 

certificates for SUAS 

under 55 pounds operated 

VLOS is not contemplated 

by these regulations 

Airworthiness is the responsibility 

of the PIC and the technician as 

defined in the UFOM.
ULC Robotics 333 Petition 14

14 CFR 

PART 

SUMMARY OF 

REGULATION 

REASON FOR 

EXEMPTION 

REQUEST 

EQUIVALENT LEVEL OF 

SAFETY 

91.417 

(a) 

Maintenance 

records

Regulations do not 

contemplate requirements 

or approval processes for 

maintenance and 

inspection of 

uncertificated SUAS, 

however a reasonable 

alternative must be 

developed to maintain 

equivalent levels of safety. 

The operator will maintain records 

according to the procedures 

specified in the UFOM. 

91.417 

(b) 

Maintenance 

records

Retaining and transferring 

records of maintenance 

and defects according to 

standards prescribed for 

authorized maintenance 

and inspection is not 

contemplated in the 

regulations for SUAS. A 

reasonable alternative is 

necessary to maintain 

equivalent levels of safety. 

Records and documentation will 

be kept for all maintenance 

performed, defects, and for all 

components specified in the 

UFOM.

PILOT IN COMMAND AND CREW 

The pilot in command (PIC) must hold an airman’s certification recognized by the FAA 

such as an airline transport, commercial, private, recreational, sport pilot, or glider pilot 

(powered or non-powered). The PIC must hold a current FAA airman medical certificate

as required by the class of airman certification. In the case of the sport pilot certification, 

the PIC must possess a valid U.S. driver’s license issued by a State, the District of 

Colombia, Puerto Rico, a territory, a possession, or the Federal government. The PIC 

must comply with the training and testing specified in the operator’s manual. The PIC

must remain in radio communication with a visual observer who complies with the 

training and testing specified in the operator’s manual. The UA must be operated within 

visual line of sight (VLOS) of the PIC at all times. This requires the PIC to be able to use 
ULC Robotics 333 Petition 15

human vision unaided by any device other than corrective lenses, as specified on the 

PIC’s FAA-issued airman medical certificate or U.S. driver’s license. The PIC must 

operate within visual line of sight only, and be able to see the attitude and orientation of 

the aircraft. If GPS or magnetometer is compromised, certain safety features may not 

operate, and the pilot must understand by training and experience how to recover 

control. 

OPERATION OF THE UNMANNED AIRCRAFT 

The aircraft will be under the operational control of the ULC Robotics designated PIC. 

As the operator of these aircraft, ULC is committed to the following conditions and 

limitations on its operations. ULC understands that failure to comply will be grounds 

for the immediate suspension or rescission any exemption granted.

1. Operations are limited to the UAS listed in the Appendix when weighing less than 

55 pounds including payload.

2. Operations for the purpose of closed-set motion picture and television filming are

not approved.

3. The aircraft will not be operated at a speed exceeding 87 knots (100 miles per 

hour). In no case will the aircraft be operated at airspeeds greater than the maximum 

aircraft operating airspeed recommended by the aircraft manufacturer.

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

level (AGL). Altitude must be reported in feet AGL.

5. The aircraft will be operated within visual line of sight (VLOS) of the Pilot in

Command (PIC) at all times. This requires the PIC to be able to use human vision 

unaided by any device other than corrective lenses, as specified on the PIC’s U.S. 

driver’s license.

6. All operations will utilize a visual observer (VO). The aircraft will be operated 

within the visual line of sight (VLOS) of the PIC and VO at all times.

7. All operating documents needed to operate the UAS and will be accessible during
ULC Robotics 333 Petition 16

UAS operations and made available to the Administrator upon request. The operator 

will also present updated and revised documents if it petitions for extension or 

amendment.

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

operation or flight characteristics, e.g. replacement of a flight critical component, 

will undergo a functional test flight prior to conducting further operations.

9. ULC is responsible for maintaining and inspecting the UAS to ensure that it is in a 

condition for safe operation.

10. Prior to each flight, the PIC will conduct a pre-flight inspection and determine the

UAS is in a condition for safe flight.

11. ULC will follow the UAS manufacturer’s maintenance, overhaul, replacement, 

inspection, and life limit requirements for the aircraft and aircraft components.

12. Each UAS operated under this exemption will comply with all manufacturer 

safety bulletins.

13. The PIC will hold a UAS flight training certificate, in some cases training 

directly from the aircraft manufacturer, and a valid U.S. driver’s license issued by a 

state, the District of Columbia, Puerto Rico, a territory, a possession, or the Federal 

government.

14. ULC will not permit any PIC to operate unless the PIC demonstrates the ability to 

safely operate the UAS in a manner consistent with how the UAS will be operated to 

acquire aerial data, including evasive and emergency maneuvers and maintaining 

appropriate distances from persons, vessels, vehicles and structures. PIC qualification 

flight hours and currency will be logged in a manner consistent with 14 CFR § 

61.51(b). ULC will operate flights for the purposes of training ULC PICs and VOs 

(training, proficiency, and experience building) and determining the PIC’s ability to 

safely operate the UAS.

15. UAS operations will not be conducted during night, as defined in 14 CFR § 1.1.

All operations will be conducted under visual meteorological conditions (VMC).

16. The aircraft will not operate within 5 nautical miles of an airport reference point
ULC Robotics 333 Petition 17

(ARP) as denoted in the current FAA Airport/Facility Directory (AFD) or for airports 

not denoted with an ARP, the center of the airport symbol as denoted on the current 

FAA-published aeronautical chart, unless a letter of agreement with that airport’s 

management is obtained or otherwise permitted by a COA.

17. The aircraft 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.

18. If the UAS loses communications or loses its GPS signal, the aircraft will return 

to a pre-determined location.

19. The PIC will abort the flight in the event of unpredicted obstacles or 

emergencies.

20. The PIC will be prohibited from beginning a flight unless (considering wind and 

forecast weather conditions) there is enough available power or fuel for the aircraft to 

conduct the intended operation and to operate after that for at least five minutes or 

with the reserve power or fuel recommended by the manufacturer if greater.

21. All operations shall be conducted in accordance with an ATO-issued COA if the 

blanket COA does not cover the intended operation.

22. All aircraft operated will be identified by serial number, registered in accordance 

with 14 CFR part 47, and have identification (N−Number) markings in accordance 

with 14 CFR part 45, Subpart C. Markings will be as large as practicable.

23. Documents used by ULC to ensure the safe operation and flight of the UAS and 

any documents required under 14 CFR §§ 91.9 and 91.203 will be available to the 

PIC at the Ground Control Station of the UAS any time the aircraft is operating.

24. The aircraft will remain clear and give way to all manned aviation operations and 

activities at all times.

25. The UAS may be operated by the PIC from a moving device or vehicle; however, 

specific requests will be made via subsequent COA.

26. All flight operations will be conducted at least 500 feet from all nonparticipating 

persons, vessels, vehicles, and structures unless:
ULC Robotics 333 Petition 18

a. Barriers or structures are present that sufficiently protect nonparticipating 

persons from the aircraft or debris in the event of an accident; or

b. The owner/controller/operator of any vessels, vehicles or structures has 

granted permission for operating closer to those objects and the PIC has made an 

assessment of the risk of operating closer to those objects and determined that it does 

not present an undue hazard.

27. The PIC, VO, operator trainees or essential persons will not be considered 

nonparticipating persons under this exemption.

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

conducted with the permission from the property owner/controller or authorized 

representative. Permission from property owner/controller or authorized 

representative will be obtained for each flight to be conducted.

29. 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 must be 

reported to the National Transportation Safety Board (NTSB) per instructions 

contained on the NTSB Web site: www.ntsb.gov

BENEFIT TO THE PUBLIC 

Approval of this petition allowing commercial operations of an sUASs will enhance 

public safety by reducing public safety risk. The use of a battery operated UA for aerial 

inspection, geo-mapping and image and film capture, is more environmentally sound and 

safe compared to a conventional, liquid-fueled aircraft. It provides a smaller 

environmental footprint, decreases manpower and separates the aircraft operators from

the aircraft. The use of the specified sUASs further protects the public by used in

restricted environments and reducing impact hazards.

REASONS WHY THE EXEMPTION WOULD NOT ADVERSELY AFFECT 

SAFETY 
ULC Robotics 333 Petition 19

The inspection aircraft will be operated in accordance with ULC Robotic’s safety 

protocols. 

The inspection aircraft carries no person, cargo, or flammable liquid fuel. Its size and 

weight are a small fraction of any manned aircraft, and its safety systems reflect best 

design practices in the SUAS industry. 

In addition, ULC Robotics will keep the approved Flight Manual at its ground control 

station. The PIC will have immediate access to it. Previous exemptions granted by the 

FAA concerning Section 91.9(b) establish that safety is not adversely affected when the 

approved Aircraft Flight Manual is kept at the ground control station of a SUAS, where it 

can be immediately accessed by the PIC.

When properly operated by trained pilots, a well-designed sUAS and trained pilot can 

stay clear of people and property on the ground and in the air. Procedures, airmanship 

skills, training and testing requirements for sUAS personnel will let the operator achieve 

safety levels in the NAS and on the ground that are equivalent to or greater than that in 

manned aviation.

SUMMARY FOR PUBLICATION 

The following summary may be published in the Federal Register: 

ULC requests an exemption from: 

14 CFR Parts 61.113 (a) and (b) 

14 CFR Parts 91.119 (c), 91.121, 91.151 (b), 91.405 (a) and (b), 91.407 (a) (1), 91.409 (a) 

(1), 91.409 (a) (2), 91.417 (a) 

in order to operate a small unmanned aircraft system (sUAS) for purposes of aerial 

inspections and monitoring, aerial geo-mapping, aerial imaging and filming, aerial data 

collection and public safety in times of emergency. The PIC will be appropriately 

qualified with a current FAA approved pilot certificate for sUAS operation and 

specialized training.

Imagery, electronic measurement, chemical measurement or any other gathering of data 

to be done by instruments aboard the UA, are conventionally done by manned aircraft 

operations, which use liquid fuel and weigh upwards of 5,000 lbs. These operations must 
ULC Robotics 333 Petition 20

fly the aircraft to and from the operation’s location. The use of the Aibot X6, the Yuneec 

Typhoon Q500 4K, the DJI Inspire 1, and/or the 3DR Solo — all of which weigh less 

than 15 lbs. and are equipped electronic safety features that minimizes the safety risk to 

people and property compared to that of a manned aircraft. 

Flight operations outside the secure areas are not allowed. There are no impacts to 

privacy.