Karl Mortensen

7511 Woodpalace Ct

Annandale, VA 22003

karl@dragonavionics.com

(703) 354-1340

15 May 2015

Hon. Michael Huerta 

Administrator 

Federal Aviation Administration 

U. S. Department of Transportation 

Docket Management System 

1200 New Jersey Ave., SE 

Washington, DC 20590 

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

Aviation Regulations from certain parts of the FARs. 

Dear Administrator Huerta: 

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

14 C.F.R. Part 11, Dragon Avionics LLC (“Dragon”), a small Unmanned Aircraft Systems 

(“sUAS”) operator, hereby applies for an exemption from the listed Federal Aviation 

Regulations (“FARs”) to allow Dragon to operate sUAS under the conditions and limitations set 

forth in this Petition. 

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, 

and (3) would provide safety enhancements to the already safe image gathering operations 

presently using manned helicopters and airplanes. Approval of this exemption would thereby 

enhance safety and fulfill the FAA Administrator’s responsibilities to “...establish requirements 

for the safe operation of such aircraft systems in the national airspace system.” Section 333(c) of 

the Reform Act. 
The name and address of the applicant is: 

Dragon Avionics

Attn: Karl Mortensen

Email: karl@dragonavionics.com 

Address: 7511 Woodpalace Ct. Annandale, VA 22003

Telephone: (703) 354-1340 

Regulations from which the exemption is requested: 

14 CFR Part 21 

14 C.F.R. § 45.23(b) 

14 CFR § 61.3 

14 C.F.R. § 91.7 (a) 

14 CFR § 91.9 (b) (2) 

14 C.F.R. § 91.103 

14 C.F.R. § 91.109 

14 C.F. R. § 91.119 

14 C.F.R. § 91.121 

14 CFR § 91.151 (a) 

14 CFR § 91.203 (a) & (b) 

14 CFR § 91.205(b) 

14 CFR § 91.215 

14 CFR § 91.405 (a) 

14 CFR § 407 (a) (1) 

14 CFR § 409 (a) (2) 

14 CFR § 417 (a) & (b) 3 

The Appendix describes the FARs from which an exemption is requested and summarizes the 

justification for each requested exemption. 

The Petition is submitted to fulfill Congress’ goal under Section 333(a) through (c) of the Reform 

Act, which 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

Administrator must determine which types of UASs 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). 

If the Adminstrator 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.” Id. § 333(c) (emphasis added). 
The Secretary has delegated his aviation authority to the Administrator of the FAA. The Federal 

Aviation Act expressly grants the FAA the authority to grant exemptions from its regulatory 

requirements for civil aircraft, a term defined under §40101 of the Act, which includes sUAS. 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 the Federal Aviation Act if 

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). 

The petitioner is an aerial imaging company, intending to do business imaging agricultural, real 

estate, surveying, and other needs. Dragon founders have been flying model aircraft for years 

and are prepared to sell their aerial imaging services. The founders are also familiar with 

ground-based radar, UAV-based radar, Counter-UAS radar systems, aerial imagery, digital 

signal processing, and a variety of U.S. military UAS.

The wide availability of sUAS, sometimes known as “microdrones,” capable of carrying highquality video equipment and priced at affordable levels fascinated the petitioner. Their careers 

have involved exploring new technologies and adapting them to capture good information to 

help the U.S. warfighter with lifesaving real-time information. Dragon founders have flown 

several different types of sUAS systems over the course of the last 7 years, involving locations in 

New York, Virginia, Alabama and Idaho, for recreational purposes, exploring the potential and 

the limitations of various sUAS, as well as exercising their image collection and processing 

subsystem. Dragon founders have also observed many professional UAS flights, involving 

everything from safety pre-flight checks, to mid-scenario command and control decisions, to 

controlled landing. They have seen first-hand successful and unsuccessful sUAS expeditions, 

and have learned from both. They are familar with a wide variety of sUAS systems and have 

chosen as their preferred aerial platforms those sUAS solutions that offer both low price, high 

reliability, and good operator control. They are pleased with the platforms chosen and the 

quality of the images captured, and have used imagery captured from their sUAS systems to 

provide situational awareness to farmers already.

Having prepared themselves to capture and process aerial imagery, proven that it aids farmers 

in making near-real-time decisions for their livelihood and real estate agents in displaying their 

wares, Dragon desires the ability to do this in a professional, compensated capacity. For this 

purpose, Dragon seeks special permission from the FAA by way of this document. Many 

competitors of Petitioner are actively flying sUAS to conduct aerial photography for commercial 

purposes, notwithstanding the FAA’s stated prohibition. Dragon also notes the congressional 

mandate in sections 332 and 333 of the FAA Revitalization and Reform Act of 2012 that the FAA 

move quickly to accommodate the economic and societal benefits that can result from 

widespread deployment of sUAS technology. Accordingly, Petitioner applies for authorization 

under the Federal Aviation Act, and the FARs rules to undertake the following activities for 

commercial purposes. Unless the Petition is granted, Petitioner will be at a significant 

competitive disadvantage, as Dragon intends to comply with FAA policy. 
Vehicles

The Petitioner has tested many sUAS vehicles, and intends to fly ArduPilot-compatible vehicles 

such as the 3DR Iris and those that are substantially similar. The 3DR Iris has already been 

approved by the FAA in multiple instances. The ArduPilot flight controller has built-in 

capability to limit the height the vehicle will fly above the ground, to limit the radius of the 

distance the vehicle will fly from the operator, and to exclude the vehicle from class B, C, 5 and D 

airspace. The petitioner has even designed a custom-built avionics device called Screamy that 

enables a ground operator to trigger a lost-drone alarm from their handheld controller or laptop 

ground control station. The vehicles also have built-in capability to return to the launching point 

if the wireless control link is interrupted or if the operator attempts to exceed any of the height, 

radius, or airspace limitations programmed into the vehicle during the pre-flight preparation

step.

The vehicles weigh around five pounds empty and have a maximum gross weight of up to 

approximately ten pounds. Most have a top speed around 30 knots. The vehicles are standard 

four-channel, five-channel, or six channel sUAS systems. They have standard control surfaces, 

with thrust varied by changing RPM. They are powered by lithium polymer batteries. 

Flight profiles 

The Petitioner will program the software controlling the vehicle so that it will not fly more than

400 feet above ground level, nor more than 1500 feet away from the operator. The operator will 

carefully preflight the vehicle before each mission to assure that its gyrocompass and GPS 

system are properly calibrated and that the return-to-home feature, altitude, and radius 

limitations are enabled. Operation on aerial photography missions will mainly take place in the 

early morning hours and other times when few people are out and about. The operator will fly 

only over largely unpopulated areas, where the potential of uncontrolled descent to cause injury 

or damage is low.

As part of standard pre-flight operations, Dragon operators will use the FAA’s B4UFLY mobile 

app to determine whether there are any restrictions or requirements in effect at the location 

where they want to fly.

The operator will not operate in controlled airspace. In the unlikely event that a manned aircraft 

flies below 400 feet AGL where a safety hazard could exist, the operator will keep both the 

vehicle and manned aircraft in sight and avoid the manned aircraft, deferring to manned aircraft 

at all times. More particularly, the Petitioner will fly only where invited or commissioned by the 

person in legal possession of the property to do so and where allowed by law.

All Dragon operators will undertake a period of at least twelve hours flight training with a 

simulator and actual vehicles, ensuring that the operator is proficient in anticipating and 

responding to situations or events that might interfere with safe flight, with ground operations, 

or with manned aircraft. 
The Petitioner's proposed operations satisfy the criteria provided in Section 333 of the Reform 

Act relating to size, weight, speed, operating capabilities, proximity to airports and populated 

areas and operation within visual line of sight and national security. The Petition justifies grant 

of the requested exemptions to allow the Petitioner to perform aerial imagery for compensation.

Respectfully submitted, 

Karl D. Mortensen

Founder, Dragon Avionics
Appendix FAR 

section 

Subject Justification 

14 CFR § 45.23(b) Requirement to display 

registration number on 

vehicle 

Insufficient space on 

vehicle 

14 CFR Part 21 Aircraft certification 

requirements and 

procedures 

Designed for manned 

aircraft; not suitable for offthe-shelf sUAS 

14 CFR § 61.3 Requirement for pilot 

certificate 

Part 61 requirements 

designed for manned 

aircraft, not sUAS; petition 

describes training for sUAS 

operator 

14 CFR § 91.7 (a) Airworthiness requirement Designed for manned 

aircraft; not suitable for offthe-shelf sUAS 

14 CFR § 91.9 (b) (2) Requirement for manual to 

be available in the cockpit 

No one aboard to read 

manual 

14 CFR § 91.103(b) Requirement for crew 

members to be onboard 

Unmanned vehicle 

14 CFR § 91.109 Requirement for dual 

controls during flight 

instruction 

No one aboard to operate 

controls 

14 CFR § 91.119 Minimum altitudes for safe 

flight 

Safety requires operation 

below these altitudes 

14 CFR § 91.121 Altimeter settings No one aboard to read 

altimeter 

14 CFR § 91.151(a) Fuel requirements Vehicle does not use fuel 

14 CFR § 91.203 (a) & (b) Requirement for 

registration and 

airworthiness certificates to 

be onboard 

No one aboard to read 

certificates 

14 CFR § 91.205(b) Cockpit instruments No one aboard to read