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UNITED STATES OF AMERICA 

DEPARTMENT OF TRANSPORTATION 

FEDERAL AVIATION ADMINISTRATION

DOCKET MANAGEMENT SYSTEM

1200 NEW JERSEY AVE., SE

WASHINGTON, DC 20590

IN THE MATTER OF THE PETITION FOR EXEMPTION OF: 

RoboFlicks, LLC

FOR AN EXEMPTION SEEKING RELIEF FROM 

THE REQUIREMENTS OF THE FAA REFORM ACT AND 

PART 11 OF THE FEDERAL AVIATION REGULATIONS FROM

TITLE 14 OF THE CODE OF FEDERAL REGULATIONS 

SECTIONS C.F.R. §§ 61.113 (a) & (b); 91.7(a); 91.119 (c); 91.121; 91.151(a); 

91.405 (a); 91.407(a) (1); 91.409 (a) (2); 91.417 (a) & (b).

CONCERNING COMMERCIAL OPERATION OF UNMANNED AIRCRAFT SYSTEMS

PURSUANT TO SECTION 333 OF THE FAA MODERNIZATION 

AND REFORM ACT OF 2012 (PUBLIC LAW 112-95)

Submitted	on	August	31,	2015

RoboFlicks,	LLC

413	S.	Portland	St.

Bancroft,	IA	50517

Brad	Bollig
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GLOSSARY OF ABBREVIATIONS

AGL Above	Ground	Level

AOI Area	of	Interest

ATC Air	Traffic	Control

ATO Air	Traffic	Organization

AV Aerial	Vehicle

CFR Code	of	Federal	Regulations

COA Certificate	of	Authorization

FAA Federal	Aviation	Administration

FAR Federal	Aviation	Regulation

GCS Ground	Control	Station

GPS Global	Positioning	System

LOL Loss	of	Link

NAS National	Airspace	System

NOTAM Notice	To	Airman

PIC Pilot	In	Command

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

SO Safety	Observer

SOP Standard	Operating	Procedures

sUAS Small	Unmanned	Aircraft	System

sUAV Small	Unmanned	Aircraft	Vehicle

UA Unmanned	Aircraft

UAS Unmanned	Aircraft	System

UAV Unmanned	Aircraft	Vehicle

VFR Visual	Flight	Rules

VLOS Visual	Line	of	Site

VMC Visual	Meteorological	Conditions

VTOL Vertical	Take-Off	and	Landing
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INTRODUCTION AND INTERESTS OF THE PETITIONER

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,	RoboFlicks,	LLC,	Operator	of	Small	Unmanned	

Aircraft	 Systems	 (“sUASs”)	 equipped	 to	 offer	 on-demand	 commercial	 UAS	

operations	for	 a	 host	 of	 industries	 and	 applications and	to	 perform	the	 purposes	

listed	 below, hereby	 applies	 for	 an	 exemption	 from	 the	 listed	 Federal	 Aviation	

Regulations	(“FARs”)	to	allow	 commercial	operation	of	its	 sUAV’s/UAS,	 so	long	as	

such	operations	are	conducted	within	and	under	the	conditions	outlined	herein	or	

as	may	be	established	by	the	FAA	in	an	exemption	granted	under	either	Section	333	

or Section	49	U.S.C.	§44701(f)	

As	 described	 more	 fully	 below,	 the	 requested	 exemption	 would	 permit	 the	

operation	 of	 a	 UAS	 under	 controlled	 conditions	 in	 airspace	 that	 is	 1)	 limited;	 2)	

predetermined;	and	3)	would	provide	safety	enhancements	in	the	fields	in	which	it	

will	 operate,	 which	 now	 depend	 upon	 conventional	 aircraft	 or	 humans	 climbing	

high	 on	 dangerous	 structures,	 walking	 in	 insect	 laden	 swamps,	 and	 working	

adjacent	to	treacherous	infrastructure. Approval	 of	this	 exemption	would	thereby	

enhance	 safety	 and	 fulfill	 the	 Secretary	 of	 Transportation’s	 (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.1

																																																							
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Executive Summary

Expeditious Summary Grant Approval Request

The	 petitioner	 requests	 the	 agency	 issue	 a	 summary	 grant	 process	 for	 this	

application as the	FAA	has	already	granted	a	previous	exemption	similar	or	identical	

to	each	and	every	request,	herein.	

Description of Type, Make and Models of sUAV/UAS Requested:

The	petitioner	is	seeking	an	exemption	to	commercially	operate	sUAV’s	makes	and	

modes	as	follows:	

DJI	Inspire	1,	DJI	– Spreading	Wings	S1000

Each	 separately	 weighs	 55	 lbs.	 or	 less,	 with	 imaging	 payload	 and	 applicable	

equipment.

Equipment	 operation	manuals	for	 each	 sUAV	 are	 included	for	 your	 reference	 and	

are	considered	confidential	information	for each	respective	company’s UAS	and	are	

affixed	separately	in	these	documents labeled Appendix.

Commercial (Mission, Operation) Purpose: 

RoboFlicks	 proposes	 the	 use	 of	 the	 sUAV’s	 will	 be	 for	 capture	 of	 high	 resolution	

imagery	 and	 video	 of	 residential	 or commercial	 Real	 estate,	 Photography,	

Videography/Filmaking,	 Precision	 agriculture,	 Industrial/Safety inspections,	

Insurance,	Education/Academic	research,	Search	and	Rescue,	Police	and	Fire	benefits,	

and	Survey/Mapping/GIS.

This	exemption	request, once	granted	would	allow	the	petitioner	to	operate	a	small	

unmanned	aerial	vehicle	(sUAV),	unmanned	aircraft	system	(UAS)	to	conduct	bridge	

Inspections,	flare	stack	inspection,	utility-power	generation	system	inspections	and	

patrolling,	 aerial	 inspection,	 photography	 and	 videography	 of	 residential	 and	

commercial	 real	estate,	weddings,	aerial	inspection,	photography	and	videography	

of	 utility	 infrastructure	 including	 but	 not	 limited	 to	 electrical	 power	 lines,	 wind	

turbines	 and	 cell	towers,	 pipeline	 inspection	 and	 patrolling,	 filmmaking,	 close	 set	

filmmaking,	cinematography,	and	videography,	precision	agriculture	with	on	board	

sensors,	 wildlife	 and	 forestry	 monitoring and	 mosquito	 and	 insect	 control, aerial	

surveying,	 construction	 site	 inspection	 and	 monitoring,	 public	 entity	 support	

operations,	Aerial	imaging	for	 safety,	monitoring	 and	 comparing	work	 efforts	 and	
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completion	 percentages,	 and	 security	 of	 controlled	 environment	 of	 various	 sites,	

aerial	video	and	live	video	feed	to	assist	with	 search	and	 rescue	operations under	

the	authority	and	support	of	local	authority	officials,	aerial	video	and	photography	

for	public	and	private	use	including	television,	public	events,	and	 cinematography	

live	feed	 and	 live	 newsgathering,	training	to	 persons	 individually	 or	 belonging	to	

both	private	and	public	organizations	to	increase	awareness	and	improve	safety	for	

current	 and	future	UAS	 operations	within	the	NAS,	 special	 events:	 including	 high	

schools.	 colleges,	 professional	 sports,	 open	 air	 events	 and	 fairs,	 research,	 risk	

management	and	assessment,	motion	picture	production,	surface	mining,	closed	set	

filming2, disaster	and	catastrophe	events.

Regulations from which the Exemption Relief is requested:

14	C.F.R.	§	61.113	(a)	&	(b)

14	C.F.R.	§	61.133(a)

14	C.F.R.	§	91.7(a)

14	C.F.	R.§ 91.119

14	C.F.R.	§	91.121

14	C.F.R.	§	91.151	(a)

14	C.F.R.	§	91.405	(a)

14	C.F.R.	§	407	(a)	(1)

14	C.F.R.	§	409	(a)	(2)

14	C.F.R.	§	417	(a)	&	(b)

Commitment to Safety

As	 part	 of	 its	 commitment	to	 safety	 and	 innovation,	 RoboFlicks is	 asking	 for	this

exemption	in	part,	to	reduce	the	risk	of	injury	to	its	employees	and	contractors	who	

participate	 in	 the proposed	 activities	 the	 petitioner	 requests,	 including	 but	 not	

limited	 to	 damage	 to	 agriculture,	 natural	 habitat,	 buildings	 and	 other	 structures	

within	the	United States.	

Expertise & Experience

Founded	 by	 Brad	 Bollig,	 an	 innovative	 and	 creative	 individual	 with	 past	 FAA	 Air	

Traffic	 Control	 Experience	 as	 well	 as	 RC	 Aircraft	 experience	 and	 member	 of	 the	

Academy	of	Model	Aeronautics	(AMA).		As	(PIC),	I’m	extremely	well	trained	in	FAA	

safety	 operations,	 airspace	 operations,	 as	 well	 as	 the	 future	 of	 FAA	 Air	 Traffic	

Control,	NextGen.	

RoboFlicks	 has	 been	 operating	 its	 lightweight	 sUAS	 around	 the	 Midwest	 at	

numerous	 sites	without	 incident.	 	 Roboflicks	 has	 proven	 its	 ability	time	 and	time	

																																																							
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again	to	carry	high	definition	film	quality	cameras	safely	and	effectively	in	a	variety	

of	 demanding	 and	 sensitive	 situations.	 	 I,	 Brad	 Bollig,	 founder	 of	 RoboFlicks	 LLC	

would	 like	 to	 formally	 request	 permission	 to	 fly	 its	 sUAS’s	 commercially	 in	 the	

United	States.	 	 Each	flight	will	 and	 always	has	 consisted	of	 at	least	two	dedicated	

individuals,	the	pilot	and	spotter.	

The Exemption Request

RoboFlicks	 proposes the	 use	 of	 the	 sUAV’s	 will	 be	 for capture	 of	 high	 resolution	

imagery	 and	 video	 of	 residential	 or	 commercial	 Real	 estate,	 Photography,	

Videography/Filmaking,	 Precision	 agriculture,	 industrial/Safety	 inspections,	

Insurance,	 Education/Academic	 research,	 Search	 and	 Rescue,	 Police	 and	 Fire	

benefits,	and	Survey/Mapping/GIS

The	 imagery	 and	 video	 will	 be	 used	 to	 identify	 the	 condition	 of	 landscapes,	

agriculture,	events,	disasters	and	infrastructure	to	conduct	bridge	inspections,	flare	

stack	inspection,	utility-power	generation	system	inspections	and	patrolling,	aerial	

inspection,	photography	and	videography	of	residential	and	commercial	real	estate,	

weddings,	aerial	inspection,	photography	and	videography	of	utility	infrastructure	

including	 but	 not	 limited	to	 electrical	 power	 lines,	wind	turbines	 and	 cell	towers,	

pipeline	 inspection	 and	 patrolling,	 filmmaking,	 cinematography,	 and	 videography,	

precision	 agriculture	with	 on	 board	 sensors,	wildlife	 and	forestry	monitoring and	

mosquito	 and	 insect	 control, aerial	 surveying,	 construction	 site	 inspection	 and	

monitoring,	public	entity	 support	operations,	aerial	imaging	for	 safety,	monitoring	

and	comparing	work	efforts	and	completion	percentages,	and	security	of	controlled	

environment	of	various	sites,	aerial	video	and	live	video	feed	to	assist	with	search	

and	 rescue	operations	under	the	authority	and	 support	of	local	authority	officials,	

aerial	video	and	photography	for	public	and	private	use	including	television,	public	

events,	 and	 cinematography	 live	feed	 and	 live	 newsgathering,	training	to	 persons	

individually	 or	 belonging	 to	 both	 private	 and	 public	 organizations	 to	 increase	

awareness	 and	 improve	 safety	 for	 current	 and	 future	 UAS	 operations	 within	 the	

NAS,	 special	 events:	 including	 high	 schools,	 colleges,	 professional	 sports,	 open	 air	

events	 and	 fairs research,	 risk	 management	 and	 assessment,	 motion	 picture	

production,	surface	mining,	closed	set	filming,	disaster	and	catastrophe	events.

The	 UAS	 will	 be	 operated	 by	 RoboFlicks.	 Given	 the	 small	 size	 of	 the sUAV’s	

involved,	no	more	than	55 lbs.,	majority	of	the	speed	of	operation	be	between	5-15	

mph and	the	restricted	environment	within	which	they	will	operate,	the	Petitioner

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	UASs	to	commence immediately.

This	exemption	application	is	submitted	to	fulfill	Congress’	express	goal	in	passing

Sections	 333(a)	 through	(c)	 of	 the	 Reform	 Act.	 This	 law	 directs	 the	 Secretary	 of	

Transportation to	 consider	 whether	 certain	 unmanned	 aircraft	 systems may	
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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 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’ 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.”	

Id.	§333(c)	(emphasis	added).3

RoboFlicks in	filing	this	application	is	requesting	that	the	FAA	combine	the	grant	of

the	Section	333	exemption	with	a	standard	Certificate	of	Operation	(COA)	that	will	

allow commercial	operations	of	its	RoboFlicks’ sUAV without	the	necessity	of	filing	

for	 a	 COA	 for	 each flight,	 unless	 such	 flight	 is	 to	 be	 conducted	 in	 an	 area	 not	

approved	 in	the	 exemption. Compliance	with	the	 conditions	 agreed	to	 herein	 and	

that	 may	 be	 imposed	 by	 the	 FAA,	 as set forth	 in	 prior	 Section	 333	 exemptions,	

provide	the	separation	needed	from	other	aircraft.

In	addition,	given	that	all	operations	will	be	conducted	below	400	AGL	feet	and	no	

closer than	5	nautical	miles	of	the	geographic	center	of	an	airport	as	denoted	on	a	

current	 FAA published aeronautical	 chart,	 unless	 a	 letter	 of	 agreement	 with	 that	

airport’s	 management	 is obtained,	 RoboFlicks requests	 that	 operations	 over	

congested	 or	 densely	 populated	 areas	 be allowed.	 Such	 operations	 will	 only	 be

under-taken	with	the	approval	of	the	land	or	home	owner,	as	set	forth	herein,	and	

will	comply with	the	requirements	that	operations	be	no	closer	than	500	feet	to	the	

adjacent	building	unless the	land	owner	has	provided	permission,	and	the	Operator	

has	made	a	safety	assessment	of the	risk	from	such	operations.	

Operator Requirements

RoboFlicks	sole	(PIC)	is	currently	receiving	training	for	his	Sport-Pilot	License.		As	

well	as	receiving	his	Sport-Pilot	license	in	a	few	weeks,	RoboFlicks	(PIC)	has	FAA	Air	

																																																							
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Traffic	Control	Experience	as	well	as	a	current	Air	Traffic	Control	Tower	Operator	

Written	Test	license and	Third	Class	Medical.

Advanced	sUAV’s have a	navigation	and	control	system	and	auto-pilot	that	allows it	

to execute	 very	 accurate	 pre-programed	flights.	 Flights	 are	 pre-programmed	with	

GPS	waypoint	to	 establish	 perimeters	 beyond	which	the	 aircraft	will	 not	 operate.	

Flights	under	auto-pilot	are not	directed	by	positive	manual	input,	but	through	preprogrammed	flight	 parameters	that	 are executed	 by	the	 auto-pilot.	In the	 case	 of	

unplanned	events,	the	Operator	inputs	preprogrammed evasive	maneuvers	from	the	

control	 unit,	 and	 the	 autopilot	 executes	 those maneuvers.	 Pre-programmed	

Operator	interventions	include:	initiation	of	holding	at	present position;	suspension	

of	 mission;	 fly	 back	 to	 launch	 point;	 abort	 mission	 and	 land	 immediately; and	

emergency	 power	 cut	 off	 and	 land	 (flight	 termination	 system). Additional	

automated	 safety	functions	and	 safety	enhancing	features	of	the	Advanced	 sUAV’s

may	include	the	following:

1) Auto-pilot	 detection	 of	 lost	 GPS	 or	 of	 insufficient	 satellites	 initiates	 an	

immediate landing,	

2)	 Low	power	on	the	aircraft	triggers	escalating	alarms	at	GCS	at	35%	and	10%	

levels. Low	power	beyond	10%	triggers	an	immediate	landing,	

3)	 If	the	auto-pilot	detects	a	lost-link	to	the	ground	controller,	the	UAS	will	hold	

position at	its	current	location	for	5	seconds	and	if	the	signal	is	not	restored,	

execute	a	return to	home	and	land,	

4)	 Redundant	“kill	switches”	that	enable	completely	shutting	the	aircraft	down	

in	flight	in the	event	of	a	loss	of	control	or	un-commanded	deviation	from	the	

flight	path,	

5)	 The	aircraft,	weighs less	than	14lbs.,	fully	loaded,	

6)	 The	motors	are	driven	by	pulse	width	modulated	signals,	not	analog	signals,	

7)	 The	 aircraft will	 operate	 for	the	 Purposes	 at	 no	 more	than	 15	 mph (while	

imaging)	 nor above	 200	 feet	 above	 the	 structure	 (imaging	 altitude)	 or	 a	

maximum	of	400	feet AGL.

A	handheld	radio	controller	controls	the	sUAV and	the	vehicle	is	operated	within	the	

line	of	 sight.	The	 requirements	of	Part	61.127 (commercial	flight	proficiency)	and	

§61.107	 (private	 flight	 proficiency),	 to	 the	 extent	 they	 are relevant	 to	 UAS	

operations,	 can	 be	 taught	 in	 the	 training	 proposed	 herein.	 As	 a	 review	 of	 the	

requirements	 of	 part	 61.127	 and	 107	 demonstrate,	 the	 issues	 presented	 as	 they	

relate	 to	 a	 12 pound	 aircraft,	 operating	 at	 less	 than	 5	 knots	 during	 filming	

operations	 are	 those	 taught	 in ground	 school	 and	 in	 flight	 training	 with	 the	

particular	 UAS	 and	 not	 gained	 from	 accumulating flight	 hours	 in	 a	 fixed	 wing	 or	

rotorcraft	 gas	 or	 jet	A	powered	 aircraft	 completing	 cross	 country flights	 and	take	

offs	and	landings	at	controlled	and	uncontrolled	airports.

The	Operator will	be	operating	the	aircraft,	always	within	line	of	sight.	He	or	she	will	

walk	and	follow	the aircraft	around	the	inspection	area	so	that	while	it	is	flying	it’s	
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pre-programed	and	at	times,	manual	flight	path,	the	UAS will	always	be	directly	in	

his	or	her	line	of	sight.	The	Operator	will	not	be	distracted	by	viewing the	pictures	

taken	during	the	flight.	Rather,	once	the	sUAV is	launched,	the	Operator’s	only duty	

will	be	to	watch	the	flight	of	the	UAS	over	the	 structure	and	intervene	to	address	

flight	path deviations	or	other	issues	that	arise	during	the	flight.	The	functions	that	

an	observer	performs where	the	aircraft	is	flown	at	long	distances	from	the	launch	

area	will	not	be	necessary	as	the Operator	will	always	have	the	aircraft	in	his	or	her	

direct	 sight.	 The	 observer	 also	 will	 not	 be necessary	 because	 the	 Operator	 will	

conduct	a	pre-flight	inspection	of	the	area,	will	and	if	needed,	 cordon	off the	area	

and	will	perform	frequent	visual	scans	of	the	area	while	the	vehicle	is	operating.

Aircraft and Equivalent Level of Safety

The	Petitioner 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	or	even	higher	level	of	safety	to	

operations	under	the	current regulatory	structure	because	the	proposed	operations	

represent	 a	 safety	 enhancement	 to	 the operations	 conducted	 with	 conventional	

aircraft	 or	with	 humans	 climbing	 up	 and	 around structures.	These	 conditions	 are	

drawn	from	Exemptions	11136,	11138,	11172,	and	11174

These	 limitations	 and	 conditions	to	 which	 RoboFlicks (referred	to	 as	“Operator”)	

agrees	to	be	bound	when	 conducting	commercial	operations	under	an	FAA	issued	

exemption include:

1) Operations	authorized	by	this	grant	of	exemption	are	limited	to	

the	aircraft	described	in	the	Operator’s	manual,	which	is	a	multirotor weighing	 up to	 55 pounds:	 Proposed	 operations	 of	 any	

other	aircraft	will require	a	new	petition	or	a	petition	to	amend	

this	grant.

2) The	UA	may	not	be	flown	at	an	indicated	airspeed	exceeding	15

mph (5	mph during	inspections).

3) The	UA	must	be	operated	at	an	altitude	of	no	more	than	400	feet	

above	 ground level	 (AGL),	 as	 indicated	 by	 the	 procedures	

specified	in	the	Operator’s	manual. All	altitudes	reported	to	ATC	

must	be	in	feet	AGL.

4) The	UA	must	be	operated	within	visual	line	of	sight	(VLOS)	of	the	

Aircraft Operator	at	all	times.	This	requires	the	Aircraft	Operator	

to	be	able	to	use	human vision	unaided	by	any	device	other	than	
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corrective	 lenses,	 as	 specified	 on	 the Operator’s	 FAA-issued	

airman	medical	certificate.

5) The	Exemption	Holder’s	Manuals	must	be	amended	to	include	all	

conditions	 and limitations	 required	 by	 the	 FAA.	 The	 Manuals	

must	 be	 maintained	 and	 made available	 to	 the	 Administrator	

upon	request.	If	a	discrepancy	exists	between	the conditions	and	

limitations	in	the	exemption	and	the	procedures	outlined	in	the

Exemption	 Holder’s	 Operator’s	 manual,	 the	 conditions	 and	

limitations	 in	 the exemption	 take	 precedence	 and	 must	 be	

followed.	 Otherwise,	 the	 Aircraft Operator	 must	 follow	 the	

procedures	 as	 outlined	 in its	Aircraft’s	 manual. The	Exemption	

Holder	 may	 update	 or	 revise	 its	 Manuals.	 It	 is	 the	 Exemption

Holder’s	 responsibility	 to	 track	 such	 revisions	 and	 present	

updated	 and	 revised documents	 to	 the	 Administrator	 upon	

request.	The	Exemption	Holder	must	 also present	updated	 and	

revised	documents	if	it	petitions	for	an	extension	or amendment	

of	this	exemption.	If	the	Exemption	Holder	determines	that	any

update	 or	 revision	 would	 affect	the	 basis	 upon	 which	the	 FAA	

granted	 this exemption,	 then	 the	 Exemption	 Holder must	

petition	for	amendment	to	its exemption.

6) Prior	to	each	flight,	the	Aircraft	Operator	must	inspect	the	UAS	to	

ensure	it	is	in	a condition	for	safe	flight.	If	the	inspection	reveals	

a	condition	that	affects	the	safe operation	of	the	UAS,	the	aircraft	

is	 prohibited	 from	 operating	 until	 the	 necessary maintenance	

has	been	performed,	and	the	UAS	is	found	to	be	in	a	condition	for

safe	flight.	The	Ground	Control	Station	must	be	included	in	the	

preflight inspection.	 All	 maintenance	 and	 alterations	 must	 be	

properly	documented	in	the aircraft	records.

7) Any	 UAS	 that	 has	 undergone	 maintenance	 or	 alterations	 that	

affect	 the	 UAS operation	 or	 flight	 characteristics,	 e.g.,	

replacement	 of	 a	 flight	 critical	 component, must	 undergo	 a	

functional	test	flight	in	accordance	with	the	Exemption	holder’s

Manuals.	The	Aircraft	Operator	who	conducts	the	functional	test	

flight	 must	 make an	 entry	 in	 the	 UAS	 aircraft	 records	 of	 the	

flight.	 The	 requirements	 and procedures	 for	 a	 functional	 test	

flight	and	aircraft	record	entry	must	be	added	to the	Exemption	

Holder’s	Operator’s	manual.

8) The	 Exemption	 Holder	 must	 follow	 the	 manufacturer’s	 UAS	

aircraft/component, maintenance,	 overhaul,	 replacement,	

inspection,	and	life	limit	requirements,	with particular	attention	

to	 flight	 critical	 components	that	 may	 not	 be	 addressed	 in	the

manufacturer’s	manuals.
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9) The	 Exemption	 Holder	 must	 carry	 out	 its	 maintenance,	

inspections,	 and	 record keeping	 requirements	 in	 accordance	

with	 the	 Operator’s	 Manuals.	 Maintenance, inspection,	 and	

alterations	must	be	noted	in	the	aircraft	logbook,	including	total	

flight	hours,	description	of	work	accomplished,	and	the	signature	

of	the authorized	technician	returning	the	UAS	to	service.

10) The	authorized	technicians	must	receive	and	document	training	

referenced	in	the Exemption	Holder’s	Manuals.

11) Each	UAS	operated	under	this	exemption	must	 comply	with	all	

manufacturer System	and	Safety	Bulletins.

12) The	 Exemption	 Holder’s	 maintenance	 personnel	 must	 make	 a	

record	entry	in	the UAS	logbook	or	equivalent	document	of	the	

corrective	 action taken	 against discrepancies	 discovered	

between	inspections.

13) Prior	to	commencing	operations,	the	Aircraft	Operator	shall	have	

logged	at	least 25	hours	of	total	time	as	a	UA	rotorcraft	pilot	and	

at	least	ten	hours	logged	as	a UA	pilot	with	a	similar	UA	type and	

5	hours	in	the	make	and	model.

14) If	the	UAS	loses	communications	or	loses	its	GPS	signal,	the	UA	

must	 return to	a	pre-determined	location	within	the	private	or	

controlled-access	 property and	 land	 or	 be	 recovered	 in	

accordance	with	the	Exemption	Holder’s Manuals.

15) The	 Aircraft	 Operator	 must	 abort	 the	 flight	 in	 the	 event	 of	

unpredicted	 obstacles or	 emergencies,	 including	 unauthorized	

people	 entering	 the	 flight	 area,	 in accordance	 with	 the	

Exemption	Holder’s	Manuals.

16) The	Aircraft	Operator	is	prohibited	from	beginning	a	UAS	flight	

unless (considering	wind	and	forecast	weather	conditions)	there	

is	enough	power	to	fly to	the	first	point	of	intended	landing	and,	

assuming	normal	cruising	speed,	to	fly after	that	for	at	least	10	

minutes.

17) All	aircraft	operated	in	accordance	with	the	exemption	must	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	must	be	as	

large	as	practicable.

18) Before	 conducting	 operations,	 the	 radio	 frequency	 spectrum	

used	for operation	and	control	of	the	UA	must	comply	with	the	
Page	12

Federal Communications	 Commission	 (FCC)	 or	 other	

appropriate	government oversight	agency	requirements.

19) The	documents	required	under	14	CFR	91.9	and 91.203	must	be	

available	 to the	 Operator	 at	 the	 Ground	 Control	Station	 of	 the	

UAS	any	time	the	aircraft	is operating.	These	documents	must	be	

made	 available	 to	 the	 Administrator	 or any	 law	 enforcement	

official	upon	request.	

20) The	UA	must	remain	clear	and	yield	the	right	of	way	to	all	other	

manned operations	and	activities	at	all	times	(including,	but	not	

limited	 to,	 ultra-light vehicles,	 parachute	 activities,	 parasailing	

activities,	hang	gliders,	etc.).

21) The	UA	may	not	be	operated	by	the	Aircraft	Operator	from	any	

moving	device	or vehicle.

22) UAS	operations	may	not	be	conducted	during	night,	as	defined	in	

14	CFR	1.1.

23) All	 operations	 must	 be	 conducted	 under	 visual	 meteorological	

conditions	(VMC). The	 UA	 may	 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 Operator.

24) During	 operations	 the	 UA	 may	 not	 operate	 within	 5	 nautical	

miles	 of	 the geographic	 center	 of	 an	 airport	 as	 denoted	 on	 a	

current	 FAA-published aeronautical	 chart	 unless	 a	 letter	 of	

agreement	with	that	airport’s	management	is obtained,	and	the	

operation	 is	 conducted	 in	 accordance	 with	 a	 NOTAM,	 if	 as

required	by	the	Operator’s	COA.	The	letter	of	agreement	with	the	

airport management	 must	 be	 made	 available	 to	 the	

Administrator	upon	request.

25) The	 UAS may	 not	 be	 operated	 over	 congested	 or	 densely	

populated	areas	unless the	conditions	set	for	in	#26	are	satisfied.	

These	populated	areas	include	but are	not	limited	to	the	yellow	

areas	 depicted	 on	 World	 Aeronautical	 Charts (WAC),	Sectional	

Aeronautical	Charts	(Sectionals),	or	Terminal	Area	Charts (TAC).	

However,	 aeronautical	 charts	 may	 not	 reflect	 pertinent	 local	

information. Ultimately,	 it	 is	 the	 Operator’s	 responsibility	 to	

maintain	the	 minimum	 safe altitudes	 required	 by	 §	 91.119	(d)	

(1).

26) Flight	 operations	 must	 be	 conducted	 at	 least	 500	 feet	 from	 all	

nonparticipating persons,	 vessels,	 vehicles,	 and	 structures	

unless:
Page	13

a. Barriers	or	 structures	 are	present	that	 sufficiently	protect

nonparticipating	 persons	 from	 debris	 in	 the	 event	 of	 an	

accident.	 The Aircraft	 Operator	 must	 ensure	 that	

nonparticipating	persons	remain under	such	protection.	If	a	

situation	arises	where	nonparticipating persons	leave	such	

protection	 and	 are	 within	 30	 feet	 of	 the	 UA,	 flight

operations	must	cease immediately	and/or;

b. The	aircraft	is	operated	near	vessels,	vehicles	or	structures	

where the	 land	 owner/controller	 has	 granted	 permission	

and/or	the	Aircraft	Operator	has	made	a	safety	assessment	

of	the	risk	of operating	closer	to	those	objects	and;

c. Operations	 near	 the	 Aircraft	 Operator	 do	 not	 present	 an	

undue	hazard to	the	Operator	per	§	91.119(a).

27) All	 operations	 shall	 be	 conducted	 over	 private	 or	 controlledaccess	property with	permission	from	the	land	owner/controller	

or	 authorized	 representative. Permission	 from	 land	

owner/controller	or	authorized	 representative	will	be obtained	

for	each	flight	to	be	conducted.

28) Any	incident,	accident,	or	flight	operation	that	transgresses	the	

lateral	or	vertical boundaries	of	the	operational	area	as	defined	

by	 the	 applicable	 COA	 must	 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.

Specific Uses Public Benefits

Current	procedures	can	result	in	significant	injuries	to	the	people	who must	climb	

on	the	 roofs	or	 require	the	use	of	aircraft	that	are	orders	of	magnitude	greater	in	

size than	the	sUAV.	 Either	method,	manual	inspection	or	large	conventional	aircraft,	

results	 in increased	 risk	 of	 injury	 due	 to	 personnel	 falling	 off	 roofs	 or	 ladders,	

carrying	 heavy	 ladders	 and dealing	 with	 confined	 and	 dangerous	 spaces,	 or	

increased	 risk	 from	 low	 altitude	 flyovers	 with helicopters or	 fixed	 wing	 aircraft	

inspecting	 buildings	 after	 damage	 from	 storms	 or	 other disasters,	 such	 as	

earthquakes	or	fires.	Such	flights	are,	of	 course,	 significantly	more expensive	than	

those	undertaken	with	a	sUAV.	

The	present	system	exposes	those	not	only in the	immediate	area	of	inspection,	but	

those	who	are	along	the	path	of	flight	associated	with	the arrival	and	departure	of	
Page	14

the	conventional	aircraft	at	the	inspection	site	because	the	aircraft	must be	flown	to	

and	from the	site.	By	contrast,	the	sUAV is carried	to	the	site	and	transits	no	other

property.	 Conventional	 aircraft	 carry	 flammable	 fuels	 that	 are	 not	 carried	 by	 the	

UAS	and	emit pollutants	 associated	with	internal	 combustion	engines.	The	 sUAV’s	

proposed	herein	are battery	powered	and	have	no	emissions.

Equivalent Level of Safety

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

Command;

Section	61.113(a)	&	(b)	limit	private	pilots	to	non-commercial	operations.	Unlike	a	

conventional aircraft	 that	 carries	 a	 pilot, passengers,	 and	 cargo,	 the	 RoboFlicks’

sUAV is	 remotely	 controlled	 with no	 passengers	 or	 property	 of	 others	 on	 board.	

Section	61.133(a)	requires	an	individual	with	a commercial	pilot’s	license	to	be	pilot	

in	command	of	an	aircraft	for	compensation	or	hire.	

RoboFlicks respectfully	 proposes	 that	 Operator	 requirements	 should	 take	 into	

account	 the characteristics	 of	 the	 particular	 UAS.	 RoboFlicks’ sUAV has	 a	 high	

degree	 of	 pre-programmed control	 and	 various	 built-in	technical	 capabilities	that	

strictly	limit the	potential	for	operation outside	of	the	operating	conditions	set	forth	

in	the	exemption	application. RoboFlicks’ sUAV has	navigation	and	control	 system	

comprised	of	a	Ground	Control	Station (GCS)	and	auto-pilot	system	that	can	be	preprogrammed	 to	 set	 operational	 boundaries.	 All flights	 are	 pre-programmed	 with	

precision	GPS	 guidance.	In	the	 case	 of	 unplanned	 events,	the	Operator	 may	 input	

pre-programmed evasive	 maneuvers	 from	 the	 control	 unit,	 and	 the	 onboard	

autopilot	 executes	 those	 maneuvers. Pre-programmed	 Operator	 interventions	

include	initiation	of	holding	at	present	position; suspension	of	mission;	fly	back	to	

launch	point;	abort	mission	and	land	immediately;	and emergency	power	cut	off	and	

land	(Flight	Termination	System).

Additional	 automated	 safety	 functions	 and	 safety	 enhancing	 features	 of	 the	 Sky	

Aerial	Drones’ sUAV’s may	include	the following:

1.1.	Auto-pilot	detection	of	lost	GPS	or	of	insufficient	 satellites	initiates	an	

immediate landing.

1.2.	Low	power	on	the	aircraft	triggers	escalating alarms	at	GCS	at	35%	and	

10%	levels.	Low	power	beyond	10%	triggers	an	immediate	landing.

1.3.	If	the	auto-pilot	detects	a	lost-link	to	the	ground	controller,	the	UAS	will	

hold	position	at	its	current	location	for	5	seconds	and	if	the	signal	is	not	

restored, execute	a	return	to	home	and	land.

1.4.	Redundant	“kill	 switches”	that	 enable	 completely	 shutting	the	 aircraft	

down	 in	 flight	 in	 the	 event	 of	 a	 loss	 of	 control	 or	 un-commanded	

deviation	from	the	flight	path.

1.5.	The	aircraft,	weighs	less	than	55	lbs.,	fully	loaded.
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1.6.	 The	 motors	 are	 driven	 by	 pulse	 width	 modulated	 signals,	 not	 analog	

signals.

1.7.	 The	 aircraft	 will	 operate	 for	 the	 Purposes at	 no	 more	 than	 15	 mph

(while	 imaging) nor	 above	 200	 feet	 above	 the	 structure	 (imaging	

altitude)	or	a	maximum	of	400 AGL.

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

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

airworthy	 condition.	 Should	 the	 exemption	 be	 granted	 allowing	 commercial	

operation	of	the	UAS	without an	airworthiness	certificate,	no	standard	will	exist	for	

airworthiness	of	the	UA.	Given	the	size	of the	aircraft	and	the	requirements	that	the	

Operator	has	agreed	to	as	it	relates	to	airworthiness, as	contained	in	the	manual,	an	

equivalent	level	of	safety	will be	achieved	by	insuring compliance	with	the	manuals	

prior	to	each	flight.	The	FAA	has	granted	exemptions	to	conduct similar	operations	

in	Exemptions	11062	through	11067,	11080	and	11110.

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

Section	 91.119	 establishes	 safe	 altitudes	 for	 operation	 of civil	 aircraft.	 Section	

91.119	(d)	allows	helicopters	to	be	operated	at	less	than	the	minimums	prescribed,	

provided	the	person operating	the	helicopter	complies	with	any	route	or	altitudes	

prescribed	 for	 helicopters	 by	 the FAA.	 As	 this	 exemption	 is	 for	 a	 sUAS	 that	 is	 a	

helicopter	and	the	exemption	 requests	authority to	operate	at	altitudes	up	to	200	

AGL,	an	exemption	may	be	needed	to	allow	such	operations.	.

The	equivalent	level	of	safety	will	be	achieved	given	the size,	weight,	and	speed of	

the	UAS	as	well	as	the	location	where	it	is	operated.	No	flight	will	be	taken	without	

the	permission	of	the property	owner,	facility	owner,	and/or	local	officials.	Because	

of	the	advance	notice	to	the property	owner	and	participants,	all	affected	individuals	

will	be	aware	of	the	planned	flight	operations	as	set	forth	in	the	Manuals.	Compared	

to	flight	operations	with	aircraft	or	rotorcraft weighing	far	more	than	the	maximum	

55	lbs.	and	the	lack	of	flammable	fuel,	any	risk	associated with	these	operations	is	

far	 less	 than	 those	 presently	 presented	 by	 conventional	 aircraft operating	 at	 or	

below	 500	 AGL	 in	 the	 aerial	 photography	 industry.	 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.	

The	 FAA	 has	 granted exemptions	 to	 conduct	 similar	 operations	 in	 Exemptions	

11062	through	11067,	11080	and 11110.
Page	16

14 C.F.R. §91.121 Altimeter Settings

The	RoboFlicks’ sUAV,	 in	 manual	 or	 emergency mode,	will	 not	 have	 a	 barometric	

altimeter	display,	but	instead	a	GPS	altitude	display,	an exemption	will	be	needed.	

The	 Operator,	 pursuant	 to	 the	 procedures	 set	 forth	 in	 the	 Manuals	 as	 indicated	

before	 flight,	 will	 achieve	 an	 equivalent	 level	 of	 safety.	 The	 FAA	 has granted	

exemptions	 to	 conduct	 similar	 operations	 in	 Exemptions	 11062	 through	 11067,	

11080 and	11110.

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.”

The	 battery	 powering	 the	 sUAS	 provides	 approximately	 40	 minutes	 of	 powered	

flight.	To meet	the	30-minute	reserve	requirement	in	14	CFR	§91.151,	sUAS	flights	

would	be	limited	to approximately	10	minutes	in	length.	Given	the	limitations	on	the	

UAS’ proposed	 flight	 area	 and the	 location	 of	 its	 proposed	 operations	 within	 a	

predetermined	area,	a	longer	time	frame	for flight	is	reasonable.

Petitioner believes	that	an exemption	from	14	CFR	§91.151(a)	falls	within	the	scope	

of prior	exemptions.	See	Exemption	10673	(allowing	Lockheed	Martin	Corporation	

to	operate without	compliance	with	FAR	91.151	(a)).	Operating	the	small	UAS,	in	a	

tightly	 controlled	 area where	 only	 people	 and	 property	 owners	 or	 official	

representatives	who	have	signed	waivers	will be	allowed,	with	less	than	30	minutes	

of	 reserve	 fuel,	 does	 not	 engender	 the	 type	 of	 risks	 that Section	 91.151(a)	 was	

intended	to	alleviate	given	the	size	and	speed	of	the	small	UAS.

Petitioner believes	 that	 an	 equivalent	 level	 of	 safety	 can	 be	 achieved	 by	 limiting	

flights	 to 30	 minutes	 or	 25%	 of	 battery	 power	 whichever	 happens	 first.	 This	

restriction	would	be	more	than	adequate	to	return	the	sUAS	to	its	planned	landing	

zone	 from	 anywhere	 in	 its	 limited operating	 area. Similar	 exemptions	 have	 been	

granted	to	other	operations,	including	Exemptions	2689F, 5745,	10673,	10808	and	

Exemptions	11062,	through11067,	11080	and	11110.

14 C.F.R. §91.405 (a); 91.407 (a) (1); 91.409(a) (2); 91.417(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	
Page	17

inspections,	except as	provided	in	paragraph	(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	 Petitioner.	 Maintenance	 will	 be	

accomplished	by the	Operator	or	manufacturer	pursuant	to	the	flight	manual	 and	

operating	handbook	as referenced	in	the	Manuals	attached	as	confidential	Exhibits	

An	 equivalent	 level	 of	 safety	 will	 be achieved	 because	these	 small	UASs	 are	 very	

limited	in	size	and	will	carry	a	small	payload	and operate	only	in	defined	areas	for	

limited	periods	of	time.	If	mechanical	issues	arise,	the	UAS can	land	immediately	and	

will	 be	 operating	 from	 no	 higher	 than	 400	 feet	 AGL.	 As	 provided	 in the	 Aircraft	

Flight	Operations	Manual	the	Operator	will	ensure	that	the	UAS	is	in	working	order

prior	 to	 initiating	 flight,	 perform	 required	 maintenance,	 and	 keep	 a	 log	 of	 any	

maintenance performed.	 Moreover, the	 Operator	 and	 manufacturer	 are	 most	

familiar	with	the	 aircraft	 and best	 suited	to	 maintain	the	 aircraft	 in	 an	 airworthy	

condition	to	provide	the	equivalent	level	of safety.	The	FAA	has	granted	exemptions	

for	similar	operations	in	Exemptions	11062	through 11067,	11080	and	11110.

Federal Register Publication

Pursuant	to	14	C.F.R.	Part	11,	the	following	summary	is	provided	for	publication	in	

the	Federal	Register,	should	it	be	determined	that	publication	is	needed:

Petitioner seeks	an	exemption	from	the following	rules:

14	C.F.R.	§§	61.113(a)	&	(b);	91.7(a);	91.119;	91.121;	91.151(a);	91.405(a);

91.407(a)(1);	 91.409(a)(2)	 and	 91.417	(a)	&	(b)	to	 operate	 commercially	 a	 small	

unmanned	 vehicle	(55	 lbs.	 or	 less)	 for	the	 following	 purposes:	to	 conduct bridge

inspections,	flare	stack	inspection,	utility-power	generation	system	inspections	and	

patrolling,	aerial	inspection	and	photography	of	 residential	and	commercial	utility	

infrastructure	including	but	not	limited	to	electrical	power	lines,	wind	turbines	and	

cell	 towers,	 pipeline	 inspection	 and	 patrolling,	 filmmaking,	 cinematography,	 and	

videography,	 precision	 agriculture	 with	 on	 board	 sensors,	 wildlife	 and	 forestry	

monitoring and	 mosquito	 and	 insect	 control,	 aerial	 surveying,	 construction	 site	

inspection	 and	 monitoring,	 public	 entity	 support	 operations,	 aerial	 video	 and	 live	

video	 feed	 to	 assist	 with	 search	 and	 rescue	 operations	 under	 the	 authority	 and	

support	 of	 local	 authority	 officials,	 aerial	 video	 and	 photography	 for	 public	 and	

private	 use	 including	 television,	 public	 events,	 and	 cinematography	 live	 feed	 and	

live	newsgathering,	training	to	persons	individually	or	belonging	to	both	private	and	

public	 organizations	 to	 increase	 awareness	 and	 improve	 safety	 for	 current	 and	

future	 UAS	 operations	 within	 the	 NAS, special	 events:	 including	 high	 schools.	

colleges,	professional	sports,	open	air	events	and	fairs,	research,	risk	management	
Page	18

and	 assessment,	 motion	 picture	 production,	 surface	 mining,	 closed	 set	 filming,	

disaster	and	catastrophe	events.

Privacy and National Security

All	flights	will	occur	over	private	or	controlled	access	property	with	the	property	

owner’s	prior	consent	and	knowledge.	Inspection	will	be	of	inanimate	objects	in	

areas	where	the	owners will	have	consented	to	the	inspections	or	otherwise	have

agreed	to	allow	the	UAS	and	the Operator	to	be	in	the	area	where	operations will	

take	place.	

The	size	of	the	UAS,	its	speed	and	restricted	area	of	operation	do	not	raise	national

security	issues.

Summary

Approval	of	exemptions	allowing	commercial	operations	of	sUAV’s	for	petitioner	to	

operate	 an	 unmanned	 aircraft	 system	 (UAS)	 to	 conduct	 bridge	 Inspections,	 flare	

stack	inspection,	utility-power	generation	system	inspections	and	patrolling,	aerial	

inspection	 and	 photography	 of	 residential	 and	 commercial utility	 infrastructure	

including	 but	 not	 limited	to	 electrical	 power	 lines,	wind	turbines	 and	 cell	towers,	

pipeline	 inspection	 and	 patrolling,	 filmmaking,	 cinematography,	 and	 videography,	

precision	 agriculture	with	 on	 board	 sensors,	wildlife	 and	forestry	monitoring and	

mosquito	 and	 insect	 control,	 aerial	 surveying,	 construction	 site	 inspection	 and	

monitoring,	 public	 entity	 support	 operations,	 aerial	 video	 and	 live	 video	 feed	 to	

assist	with	 search	and	 rescue	operations	under	the	authority	and	 support	of	local	

authority	officials,	aerial	video	and	photography	for	public	and	private	use	including	

television,	 public	 events,	 and	 cinematography	 live	 feed	 and	 live	 newsgathering,	

training	 to	 persons	 individually	 or	 belonging	 to	 both	 private	 and	 public	

organizations to	increase	awareness	and	improve	safety	for	current	and	future	UAS	

operations	 within	 the	 NAS,	 special	 events:	 including	 high	 schools.	 colleges,	

professional	 sports,	 open	 air	 events	 and	 fairs,	 research,	 risk	 management	 and	

assessment,	motion	picture	production,	surface	mining,	closed	set	filming,	disaster	

and	catastrophe	events,	will	enhance safety	by	reducing	risk.	

Conventional	 operations,	 using	 jet	 or	 piston	 powered	 aircraft,	 ladders	 or placing	

people	in	swamps,	on	roofs	or	tall,	hazardous	or	weakened	structures,	exposes	them	

to	 higher	 risks than	 those	 created	 by	 use	 of	 a	 sUAV’S.	 Conventional	 aircraft	 that	

operate	at	extremely	low altitudes	just	feet	from	the	subject	being	inspected	and	in	

extreme	 proximity	 to	 people	 and structures	 present	 the	 risks	 associated	 with	

vehicles	that	weigh	in	excess	of	6,000	lbs.,	carrying large	amounts	of	jet	A	or	other	

fuel	(140	gallons	for	jet	helicopters).	Such	aircraft	must	fly	to	and from	the	project	

location.	In	contrast,	a	sUAV weighing	fewer	than	14	lbs.	and	powered	by batteries	
Page	19

eliminates	virtually	all	of	that	risk	given	the	reduced	mass	and	lack	of	combustible	

fuel carried	 on	 board.	 The	 sUAV is	 carried	to	the	target	 area	 and	 not	 flown.	 The	

sUAV will	carry	no passengers	or	crew	and,	therefore,	will	not	expose	them	to the	

risks	associated	with	manned aircraft	flights.

The	operation	of	small	UASs,	weighing	less	than	55 lbs.,	conducted	under	the	strict

conditions	outlined	above,	will	provide	an	equivalent	level	of	safety	supporting	the	

grant	of	the exemptions	requested	herein.	These	lightweight	aircraft	operate	at	slow	

speeds,	close	to	the ground,	and	in	areas	that	are	under	the	control	of	the	customer	

for	 the	 operations and,	 as	 a result,	 are	 far	 safer	 than	 conventional	 operations	

conducted	with	turbine	helicopters	operating	in close	proximity	to	the	ground	and	

people	or	the	use	of	individuals	to	climb	the	structures	to conduct	the	operations.

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	Petitioner’s	UAS	for	the Purposes	outlined	herein	and	are	

consistent	with	exemptions	already	granted,	including Exemptions number	11171	

through	11174,	and	11176.

Sincerely,

Brad	Bollig

RoboFlicks,	LLC

413	S.	Portland	St

Bancroft,	IA	50517
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