2

Frank Taylor

Community Safety Consulting Group (CSCG)

42-215 Washington St. suite A #386

Palm Desert, CA 92211

U.S. Department of

Transportation Docket 

Management System

1200 New Jersey Ave., SE 

Washington, DC 20590

Dear Sir or Madam:

Attached, please find the request for an exemption, for Community Safety 

Consulting Group (also known as CSCG) owned by Frank Taylor, from certain 

stated Federal Aviation Regulations to allow commercial operation of its Small

Unmanned Aircraft Systems (hereafter referred to as “SUAS”) for the purposes of 

aerial photography, cinematography, videography, mapping, crop surveying, aerial 

inspections, data collection, security monitoring, public safety, first responder, 

search and rescue, emergency response support and other flight operations, so long 

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

as may be established by the FAA as required by Section 333 of the FAA 

Modernization and Reform Act of 2012.

Please be advised that the FAA has previously issued grants of exemption in 

circumstances similar in all material aspects to those requested in this petition, 

notably in Exemption Nos. 11487 to HAZON Solutions, 11552 to Sinclair 

Community College, and 11110 to Trimble Navigation Ltd. for fixed wing SUAS 

similar to the fixed wing SUAS proposed herein, in Exemption No. 11446 to 

Trumbull Unmanned LLC which includes the specific VTOL SUAS proposed

herein, Exemption No. 11925 to James Michael Hourihan for VTOL SUAS based 

emergency response support operations. Therefore, CSCG respectfully requests this 

exemption be considered under the “summary grant” process.

As detailed in this document, a granted exemption would permit the commercial

operation of SUAS under controlled conditions in airspace that is limited and 

controlled via subsequent COA applications. Predominantly, CSCG seeks to operate 

under the “Blanket 200ft COA” guidance that was issued by the FAA in March 2015 

and respectfully requests the “Blanket 200ft COA” be granted in concert with these

exemptions.

The requested exemptions and proposed limitations provide for at least an equivalent

or higher level of safety to operations under the current regulatory structure, 

specifically safety enhancements to personnel climbing vertical infrastructure and 

create a low-risk alternative to certain manned aviation operations.
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As outlined in this request for exemption, the SUAS’s CSCG proposes to use are:

Sentera Phoenix

Lockheed Martin Procerus Technologies (LMPT)Indago

DJI Phantom II, III

DJI Inspire

If I can provide any additional information in support of your review of this petition, 

please do not hesitate to call me at 760-250-8358 or send an email to 

ftaylor@dc.rr.com. 

Sincerely,

Frank Taylor

Owner 

Community Safety Consulting Group (CSCG)
4

Section 1: Introduction & Interest of Community Safety Consulting Group (CSCG)

Community Safety Consulting Group (CSCG) is headed by Frank Taylor, a retired Captain 

from the Riverside County Sheriff’s Department of California, with almost 29 years of public 

safety experience. During his law enforcement career, retired Captain Taylor was involved in 

a multitude of regular law enforcement duties including, but not limited to, criminal and 

forensic investigations, Administrative Management, along with search and rescue operations. 

Additionally, his expertise was enhanced through his involvement in numerous technology

related projects. These included Automated License Plate Readers, Body Worn Cameras, 

along with research and development of major databases used to help organize major criminal 

investigations. After retiring from his public safety career, he began to enhance his experience 

level by educating himself in the operations of Unmanned Aerial Systems (UAS). This was 

enhanced by becoming a member of the Association for Unmanned Vehicle Systems 

International (AUVSI), a member of the American Modelers Association (AMA), a member 

of the Airborne Law Enforcement Association (ALEA), along with attending a multitude of 

conferences and seminars related to UAS operations. In 2013, he founded and is the owner of 

CSCG located in Palm Desert California.

Frank Taylor is currently involved in the Certificate of Authorization process for a public 

agency, slated to use the Sentera Phoenix UAS, under COA 2015-WSA-157-COA. He has 

also been involved with Sentera LLC of Minnesota, the manufacturer of the Phoenix, for an 

extended period of time.

CSCG also consults with law enforcement, public agencies, agricultural businesses and 

clients involved in Research and Development, by providing expertise during the 

complicated process of integrating Unmanned Aerial Systems (UAS) into the National 

Airspace. (NAS) Whether focusing upon domestic usage, ground-truthing of crops, or R&D 

related to UAS applications, CSCG provides a service to help navigate the process to operate 

in the NAS. Educating governmental stakeholders and the public, working through the FAA 

application process, are all parts of how CSCG help’s our clients. 

CSCG’s staff includes current and retired aircraft pilots with hundreds of hours of flight 

experience, retired law enforcement personnel, along with several other personnel with 

extensive knowledge and expertise in the SUAS field and operations.

CSCG proposes to commercially operate the Sentera Phoenix, the Lockheed Martin 

Procerus Technologies (LMPT) Indago, the DJI Phantom II & III, and the DJI Inspire

SUAS platforms for the purposes of aerial inspections, crop and agricultural surveys,

aerial photography, videography, data collection, security monitoring, public safety, 

search and rescue, first responder and emergency response support and other flight 

operations conforming to the proposed limitations and restrictions. CSCG holds that 

commercially operating an SUAS within the NAS under these same limitations and 

restrictions will not pose a hazard to manned aircraft, and that operation of its SUAS is in 

the public best interest by providing an inexpensive, low-risk alternative to manned survey

operations.
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Section 2: Regarding the Unmanned AircraftSystem

The FAA’s public guidance on filing an exemption under Section 333 is reprinted below. 

This section intends to fulfill each requirement of this guidance.

1. Petitioners should describe how the proposed UAS operation will be safely conducted 

to minimize risk to the NAS or to persons and property on the ground. Specifically, 

petitioners should describe the design and operational characteristics for the type(s) of

UAS they intend to operate, e.g. aircraft performance and performance limitations, 

operating procedures, and aircraft loading information in as much detail as possible. 

This could be provided in the petition or in an Aircraft Flight Manual or similar

document.

NOTE: The FAA will consider all information and data submitted by the petitioner that 

describes the UAS developmental and operational history. This could include statistical

data or other documentation for the specific design and performance characteristics of 

the UAS, including the operational history and operational failure modes, obtained 

through previous Research & Development (R&D) and/or flight test activities, e.g. 

operations conducted under a COA, with a civil airworthiness certificate, or under other

authorized operating conditions.

2. Petitioners should describe any procedures they would implement, such as pre-flight 

inspections, maintenance, and repair, to ensure that the UAS is in a condition for safe

flight. This could be provided in the petition, an Aircraft Flight Manual, a 

Maintenance and Inspection Manual, or similar document.

NOTE: The Aircraft Flight Manual and Maintenance and Inspection Manual

may be separate documents or combined in a singledocument.

3. The petitioner should describe the Radio Frequency (RF) spectrum used for control of 

the UAS and associated equipment that is part of the UAS (i.e., sensors, cameras, etc.),

and whether it complies with Federal Communications Commission (FCC) or other

appropriate government oversight agency requirements.

NOTE: Petitioners should be able to provide the FCC approval letter or show compliance

with FCC requirements upon request.

CSCG intends to commercially operate SUAS weighing less than 55lbs, during daylight 

hours, within visual line of sight of the PIC, at altitudes less than 400ft AGL and at speeds 

less than 100 mph or 87 knots (depending on the system, see Section 2.1 below). As 

described later, CSCG’s PICs shall be fully qualified airmen, holding at least a sport pilot 

certificate and associated medical clearance. The proposed SUAS are equipped with GPSenabled autopilots, capable of safe, steady autonomous flight and guided by the PIC. The 

proposed SUAS are commercially available, “off the shelf” products that have accumulated 

innumerable flight hours and they have proven themselves, low-risk, safe aircraft. Given
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the small size and weight, low altitudes, slow speeds, a qualified PIC, a GPS-enabled 

autopilot, data-link and countless flight hours, CSCG holds that commercially operating

these SUAS under the limitations and restrictions set forth is a safe alternative to the current 

regulatory structure and minimizes risk to the NAS or to persons and property on the ground.

2.1 Proposed SUAS

CSCG intends to operate the Sentera Phoenix family of SUAS, the Lockheed 

Martin Procerus Technologies (LMPT) Indago family of SUAS, along with the 

DJI Phantom and Inspire families of SUAS. All of these types of systems have 

been proven to be reliable and effective SUAS with the ability to carry payloads

such as cameras, sensors and other equipment necessary to complete CSCG’s 

aerial photography, cinematography, videography, mapping, crop surveying, 

inspection, search and rescue and public safety tasks. Each SUAS is described

below.

Sentera Phoenix

The Sentera Phoenix system is comprised of a fixed wing, hand-launched, 

propeller driven unmanned aircraft and a laptop or tablet based ground control, 

responsible for both vehicle operation and camera functions, along with a 

communications data-link providing bi-directional communications between 

the air vehicle and the ground control station. The Phoenix SUAS has the 

ability to conduct hand-launched takeoffs, precision landings in varied terrain 

and execute standard horizontal flight maneuvers. The maximum gross weight 

of the Phoenix is 3.5 lb. (1588g), and it measures 8in (203mm) tall, 22-26in 

(559-660mm), long (depending on the model) and has a 38in (965mm) or 48

in (1219mm) wingspan (again, depending on the model). Its standard cruise 

speed is 29-35 mph (25-30 ktas, 13-15 m/s), maximum horizontal speed of 

52 mph (45 ktas, 23 m/s) and maximum ascent and descent speeds are 800 

ft/min (4.1m/s) is 400 ft/min (2.0 m/s) respectively. The Phoenix is powered 

with a Lithium Ion battery and flies for approximately 60 minutes. Detailed 

specifications are available in the Sentera Phoenix UAS Pilot Operational

Handbook attached as Appendix 1.

The Sentera Phoenix system has been proven to be a reliable and effective 

system for operations such as those proposed herein and has previously 

been approved for similar uses by FAA. The Sentera Phoenix is an 

evolution of the Vireo UAS, originally produced by UTC Aerospace

Systems by the team that now forms the core engineering team of Sentera. 

The Sentera Phoenix’s immediate predecessor, the Vireo is currently

operating in numerous FAA - approved Public COAs as identified below:

 2013-ESA-46 COA Hyde (Proponent: NC State University)

 2013-ESA-65 COA Butner (Proponent: NC State University)

 2013-ESA-69 COA Caratoke (Proponent: NC State University)

 2014-ESA-93 COA Vernon James (Proponent: NC State University)
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 2014-ESA-114 COA Lake Wheeler (Proponent: NC State University)

 2015-CSA-24-COA Springfield Airpark (Proponent: Sinclair 

Community College)

 2013-CSA-56 Wilmington Airpark (Proponent: Sinclair Community

College)

Lockheed Martin Procerus Technologies (LMPT)Indago

The Indago system is comprised of a four-rotor Vertical Takeoff and Landing 

(VTOL) unmanned aircraft and ground control station – either a handheld 

controller or a laptop/tablet based control station – which is responsible for 

both vehicle operation and camera functions, along with a communications 

data-link providing bi-directional communications between the air vehicle 

and the ground control station. The Indago SUAS has the ability to conduct 

vertical takeoffs and landings, hover and execute standard horizontal flight 

maneuvers. The maximum gross weight of the Indago is 4.85 lb (2200g), 

and it measures 32 x 32 x 9 in (813 x 813 x 229mm). The Indago’s

maximum horizontal speed is 30mph (13.4 m/s), maximum ascent speed is 

800 ft/min (4.1 m/s), and maximum descent speed is 400 ft/min (2.0 m/s). 

The Indago is powered by a Lithium Ion battery and flies for approximately 

45 minutes. More detailed specifications are available in the Indago User 

Guide attached as Appendix 3.

The Indago system has been proven to be a reliable and effective system for 

operations such as those proposed herein and has previously been approved 

for similar uses by FAA in the form of numerous Section 333 Exemptions, 

such as those outlined on page 1 of the cover letter above.

DJI Phantom

The Phantom system is comprised of a four-rotor unmanned aircraft and 

handheld controller, which is responsible for both operation and camera 

functions. The maximum gross weight of the Phantom is 1250g, and it 

measures 350mm across rotor-to-rotor. Its maximum horizontal, ascent and 

descent speeds are 15 m/s, 6m/s and 2m/s respectively. The Phantom is 

powered with a Lithium Ion battery and flies for approximately 20 minutes. 

More detailed specifications are available in the DJI Phantom Operations 

Manual, which is attached as Appendix 5.

DJI Inspire

The Inspire system is comprised of a four-rotor unmanned aircraft and 

handheld controller, which is responsible for both operation and camera 

functions. The maximum gross weight of the Inspire is 3000g, and it 

measures 438 x 451 x 301mm. The Inspire’s maximum horizontal, ascent

and descent speeds are 22m/s, 5m/s and 4m/s respectively. The Inspire is 

powered by a Lithium Ion battery and flies for approximately 20 minutes. 
8

More detailed specifications are available in the DJI Inspire Operations 

Manual, which is attached as Appendix 6.

2.2 Maintenance & Inspection

CSCG shall follow the manufacturer’s maintenance, overhaul, inspection

and record-keeping guidelines as specified in the relevant manufacturer user 

manuals, attached as Appendices 1, 3, 5 & 7. CSCG will conduct 

inspections and maintenance, which shall be noted in the aircraft’s logbook

including total flight hours and the nature of maintenance performed. 

Comprehensive maintenance will be performed in conformance with the 

manufacturer’s guidelines.

In advance of every flight operation, the Pilot In Command (PIC) will 

thoroughly inspect the SUAS to ensure it is safe to fly as described in the 

relevant manufacturer user manuals and checklists, attached as Appendices 

2 (Sentera Phoenix), 4 (LMPT Indago), 5 & 9 (DJI Phantom) and 7 & 8 (DJI 

Inspire). Furthermore, the PIC will conduct a pre-flight checklist as described

in the Operations Manual’s and Safety Guidelines. With both inspections

completed and passed, the SUAS shall be deemed safe to fly.

All SUAS proposed under this request for exemption will be in compliance 

with all manufacturer maintenance, system and safety bulletins.

2.3 Radio Communications

All radio systems used in the proposed SUAS comply with FCC regulations 

and have earned FCC approval. CSCG shall operate the SUAS in 

compliance with those approvals. Certificates of compliance may be found

in Operations manuals in Appendices 1, 3, 5 and 6.

Both the Phantom and Inspire SUAS operate in two different FCC-approved 

bands. The remote control operates between 5.728 and 5.85GHz, and the 

video/data-link operates between 2412MHz and 2462MHz.

Section 3: Regarding the Unmanned AircraftPIC

The FAA’s public guidance on filing an exemption under Section 333 is reprinted below. 

This section intends to fulfill each requirement of this guidance.

Regarding the Unmanned AircraftPIC

4. Petitioners should describe the qualifications required of any PIC(s) who will be 

directly responsible for the operation of the UAS, including information such as: the 

level of airman certificate held; any applicable training related to the operation; and any 

minimum hours of flight experience required by the PIC(s), both total flight time and the

time with the particular UAS. If the operation would use visual observers, petitioners 
9

should describe their roles and qualifications.

5. Petitioners should describe the medical standards and certification of the PIC(s)

directly responsible for the operation of theUAS.

CSCG PICs shall possess a “current airline transport, commercial, private, recreational or 

sport pilot certificate.” The PIC shall also hold a current FAA airman medical certificate 

or a valid U.S. Driver’s License. The PIC shall also meet the flight review requirements

specified in 14 CFR § 61.56 in an aircraft in which the PIC is rated on his or her pilot

certificate.

Prior to commercial operations, CSCG PICs shall have accumulated and logged a 

minimum of 25 hours total time as an SUAS pilot. Flights for the purposes of training 

CSCG PICs and VOs (training, proficiency, and experience-building) and determining the

PIC’s ability to safely operate the UAS in a manner consistent with how the UAS will be 

operated under this exemption, are requested under the terms of this exemption. Training

operations shall only be conducted during dedicated training sessions. During training,

proficiency, and experience-building flights, all persons not essential for flight operations

shall be considered nonparticipants, and the PIC shall operate the UA with appropriate

distance from nonparticipants in accordance with 14 CFR § 91.119.

Section 4: Regarding the Operation of the Unmanned Aircraft

The FAA’s public guidance on filing an exemption under Section 333 is reprinted below, 

along with CSCG’s proposal. This section intends to fulfill each requirement of this 

guidance.

Regarding the Operation of the UnmannedAircraft

6. Petitioners should fully describe their intended UAS operation(s). Petitioners 

should describe how the proposed operation(s) would not adversely affect safety,

or how they would provide a level of safety at least equivalent to that provided by 

the rule from which exemption is sought. Petitioners should address any plans to

implement clearly defined operational borders and procedures to ensure public 

safety, which includes persons and property both in the air and on the ground.

This can be described in the petition, in an Operations Manual, or similar 

document. NOTE: The FAA will closely examine the proposed operation(s) with 

respect to safety of flight, NAS safety considerations, and the safety of the nonparticipating persons and property during the operational period and within the 

operational area.

7. Petitioners should specify the proposed maximum operating speed and altitude,

and describe minimum flight visibility and distance from clouds for their 

intended operation(s). Petitioners should describe potential hazards and safety 

mitigations associated with these proposed conditions. These issues can be 

addressed in the petition, an Operations Manual, or similar document.

The SUAS will be operated during daylight hours, in compliance with visual flight rules, and 
10

flown within direct visual line of sight of the PIC at all times and never over congested or 

densely populated areas unless specifically authorized by the Air Traffic Organizationissued COA. The PIC shall use 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 SUAS shall be operated at an altitude of no more than 400ft AGL, unless specifically 

authorized and operating under the terms of the COA, at speeds less than 23m/s (52mph). 

The SUAS will not be operated less than 500ft below or less than 2000ft horizontally from

a cloud, or when visibility is less than 3 statute miles.

Prior to beginning a flight, the PIC shall clearly establish the limits in latitude, longitude 

and altitude AGL to ensure compliance with the COA under which the SUAS is flown 

and establish the “sterile area” for operations. If at any time, this area is breached by 

unpredicted obstacles (manned aircraft or otherwise), the PIC shall abort the flight.

Manned aircraft shall have right of way at all times. In case of a reduced or diminished 

control link, the SUAS will automatically return to a predetermined point within the private

or controlled-access property.

The PIC shall not begin a flight unless there is sufficient available power for the SUAS to 

complete the intended mission and to operate for at least five minutes after that.

By operating within the limitations and guidelines set forth herein, CSCG shall provide an

equivalent level of safety to operations under the existing regulatory structure.

8. Petitioners should describe the characteristics of the area of intended operation(s)

and the associated potential hazards, in accordance with the statutory mandate 

under Section 333 regarding proximity to populated areas. These issues can be 

addressed in the petition, an Operations Manual, or similardocument.

9. Petitioners should describe if they intend to operate in the proximity of any

airports, in accordance with the statutory mandate under Section 333 regarding 

proximity to airports.

All flight operations will be conducted at least 500ft from all nonparticipating persons, 

vessels, vehicles and structures on private or controlled access property with permission 

from the property owner/controller or authorized representative. In some cases due to 

mission requirements, the SUAS will be operated closer than 500ft to commercial and 

industrial infrastructure and facilities. In these instances, CSCG shall have the

authorization of the property owner/controller or from an authorized representative, and 

the PIC shall have conducted a safety assessment and determined that it does not present

an undue hazard. Permission from the property owner/controller or authorized 

representative will be obtained for each flight to be conducted.

In accordance with the “Blanket 200ft COA” guidance that was issued by the FAA in

March 2015, flight operations will not take place within,
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 5 nm from an airport having an operational control tower; or

 3 nm from an airport with a published instrument flight procedure, but not an 

operational tower; or

 2 nm from an airport without a published instrument flight procedure or an 

operational tower; or

 2 nm from a heliport with a published instrument flight procedure

unless a letter of agreement with that airport’s management is obtained and/or otherwise 

permitted by an Air Traffic Organization-issued COA.

Foreseen hazards include encroachment of manned aviation operations and nonparticipants on the ground. Both of these hazards are mitigated by choice of location (noncongested areas) and strict limits on range (visual line of sight) and altitude established 

herein. Operation under these limits effectively mitigates these risks.

10. The UAS must be operated within visual-line-of-sight (VLOS), in accordance with 

the statutory mandate under Section 333(b) (1). Petitioners should describe how 

they intend to comply with this mandate.

11. Petitioners should describe any procedures they would implement for

conducting a preflight safety risk assessment to determine that the UAS is in a 

condition for safe flight (14 CFR § 91.7(b)) and that the planned operation can 

be completed safely. These procedures can be addressed in the petition, an 

Aircraft Flight Manual, Operations Manual, or similar document.

As described above, the SUAS will be operated during daylight hours, in compliance with 

visual flight rules, and flown within direct visual line of sight of the PIC at all times. The

PIC shall use 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.

In advance of every flight operation, the Pilot In Command (PIC) will thoroughly inspect

the SUAS to ensure it is safe to fly as described in Appendices 1-4. Furthermore, the PIC 

will conduct a pre-flight checklist as described in Appendix 5 (Sentera Phoenix), Appendix 

6 (LMPT Indago), Appendix 7 (DJI Phantom) and Appendix 8 (DJI Inspire) and ensure 

the planned operation can be completed safely with sufficient battery reserves (including 

wind and terrain limitations). With both inspections completed and passed, the SUAS 

shall be deemed safe to fly.

12. If petitioners intend to conduct operations which have existing requirements to

notify Flight Standards District Offices (FSDOs) prior to operations – such as 

motion picture and television filming, or pipeline and powerline patrol –

petitioners should describe their intended coordination in this regard for their

proposed operation(s).

CSCG’s aerial infrastructure inspections, cinematography/videography, agricultural 
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operations, security monitoring, public safety, search and rescue, first responder and 

emergency response support operations do not require notification to FSDOs.

13. The FAA intends to require entities who obtain an exemption under this process to 

also obtain a Certificate of Waiver or Authorization (COA) from the FAA Air 

Traffic Organization prior to conducting operation(s) in the NAS. The COA 

application is available here.

As stated previously, CSCG shall obtain an Air Traffic Organization-issued COA prior to 

conducting any operations under this requested grant of exemption. CSCG seeks 

primarily to operate under the “Blanket 200ft COA” guidance offered by the FAA in 

March, 2015 and respectfully requests that COA be issued concurrently with these

exemptions. For operations not conforming to the “Blanket 200ft COA” guidance, CSCG 

will seek separate and additional COAs to operate its SUAS.

Section	5:	RequestedExemptions

14	C.F.R Part Summary	ofRegulation Proposed Action

21, Subpart H Airworthiness

Certification

In consideration of the size, weight, speed, 

and limited operating area associated with 

the aircraft and its operation, the FAA has 

previously held that this aircraft meets the 

conditions of Section 333, therefore, 

requested relief from 14 CFR part 21, and 

any associated noise certification and 

testing requirements of part 36, is not 45.23(b) Display of Marks CSCG SUAS shall be identified by serial 

number and N-number, in markings as large 

as practical given the small size of the 

aircraft. However, the 2 inch minimum set 

forth in this rule is impractical, therefore 

61.23(a) relief isrequested.

61.101(e)(4&5)

61 113(a) & (b)

61.133(b)

61.315(a)

Certification: 

Pilots, Light 

Instructors and 

Ground Instructors

In previous petitions for exemption, the 

FAA has held that a PIC of an SUAS 

holding at least a Sport Pilot certificate and 

a U.S. Driver’s License, or greater medical 

certification, would not adversely affect 

safe operations within the NAS or present a 

hazard to people or structures on the 

ground. Relief, subject to the limitations 

provided in this document, is requested. 91.7(a) Civil Aircraft

Airworthiness

PICs operating on behalf of CSCG shall 

perform preflight inspections and ensure 

airworthiness prior to flight as described in 

this document, manuals and appropriate 

appendices. Relieffrom this requirement is 

not necessary.
13

91.9(b)(2) & (c) Civil aircraft flight manual, 

marking, and placard 

requirements

CSCG shall provide a current SUAS 

Flight Manual, and operational 

instruction material at the location of 

the PIC and/or Ground Station. The

FAA has previously determined that, 

given this, relief from this 

requirement is not necessary. 91.103 Preflight Action CSCG will perform. Relief is not 

necessary.

91.105 Flight Crewmembers at 

Stations

No human will be aboard the 

SUAS operated by CSCG, 

however, the FAA has held in 

previous petitions that relief is 

not necessary. 91.109(a) Flight Instruction CSCG will conduct flight 

training in accordance with the 

guidance and limitations offered 

in this document, as well as the 

Operations & Flight Manuals 

attached as appendices to this 

document. The FAA has held in

previous petitions that relief is 91.119 Minimum Safe Altitudes Request relief within limitations 

and restrictions proposed herein,

specifically in Section 4.

91.121 Altimeter Settings Each of the SUAS CSCG proposes 

to operate measure altitude with 

both barometric pressure sensors 

and GPS. Prior to each flight, the 

barometric altimeter will be set to 

0ft AGL instead of the setting of 

the nearest reporting station. 

CSCG holds that by counting 

altitude in AGL, zeroed at the 

point of departure, will ensure 

conformance to the COA 

restrictions under which the SUAS 

is operating. Given the low 

operating altitudes of system and 

operating within the proposed 

restrictions, relief is requested.
14

91.151 Fuel Requirements in VFR 

Conditions

As described in this 

document, the SUAS CSCG 

proposes to operate have total 

endurance of between 20 and 

30 minutes. CSCG will 

ensure missions are 

conducted with sufficient 

reserve to operate for at least 

five minutes after the 

intended mission is complete. 

The short flight time makes 91.203 Certifications

Required

CSCG LLC will place these

documents at the location of the 

ground station and/or with the 

PIC. The FAA has previously held 

that this is sufficient to provide an

equivalent level of safety, and 91.405 Maintenance Required Relief is requested within the

limitations and conditions set forth 

in Section 2.2 of this document.

91.407 Operation After

Maintenance

Relief is requested within the

limitations and conditions set forth 

in Section 2.2 of this document.

91.409 Inspections Relief is requested within the

limitations and conditions set forth 

in Section 2.2 of this document.

91.417 Maintenance Records Relief is requested within the

limitations and conditions set forth 

in Section 2.2 of this document.

Section 6: Public Interest & Equivalent Level ofSafety

Though this is addressed in pieces of this petition, a more complete answer is provided in 

this section.

CSCG proposes certain 14 CFR exemptions to allow commercial operation of its small 

unmanned aircraft systems for the purposes of aerial photography, cinematography, 

videography, mapping, crop surveying, inspections, data collection, security monitoring, 

search and rescue, public safety, search and rescue, first responder and emergency

response support and other flight operations, so long as such operations are conducted

within and under the conditions outlined herein.

Traditional agricultural operations such as crop inspections and data collections under

the current regulatory structure include the use of manned aircraft, which are expensive, 

inefficient and cannot be safely operated in close proximity to the ground. By using

SUAS to complete these missions the public interest is served by increasing safety to 

pilots, passengers and non-participants on the ground.
15

Traditional industrial infrastructure inspection operations under the current regulatory 

structure are often performed 1) from the ground, where high detail is impossible 2) by a 

climber at great risk to his or her personal safety, or 3) by a manned aircraft where flying 

close to elevated infrastructure is extremely dangerous, and not permitted by 14 CFR 

91.119.

Traditional public safety, security (such as facility perimeter monitoring), first responder, 

natural resource management, search and rescue, and emergency response/emergency 

management flight operations under the current regulatory structure include the use of

manned aircraft, which are expensive, inefficient and can pose significant risks to the 

aircrew, property and structures and persons on the ground when being operated in close 

proximity to the ground. By using SUAS to complete these missions the public interest is 

served by increasing safety to pilots, passengers and non-participants on the ground while

increasing availability and responsiveness due to the lower cost of equipment and

operations.

Grant of exemption, with the conditions and limitations set forth herein, to CSCG, will 

provide for at least an equivalent or better level of safety, reduce risk to life and property, 

thereby serving the public interest.

Section 7: Summary of Exemption Request for the Federal Register

In accordance with 14 CFR 11.81 and Section 333 of the FAA Modernization and Reform Act 

of 2012, P.L. 112-95, Community Safety Consulting Group (CSCG) seeks exemption from 

the requirements of 14 C.F.R §§Part 21, Subpart H, 45.23(b), 61.23(a), 61.101(e)(4&5),

61 113(a) & (b), 61.133(b), 61.315(a), 91.7(a), 91.9(b)(2) & (c ), 91.103, 91.105,

91.109(a), 91.119, 91.121, 91.151, 91.203, 91.405, 91.407, 91.409 and 91.417 to operate

small unmanned vehicles weighing 55lbs or less for commercial purposes.

Section 8: Compliance with 14 CFR11.81 

14 CFR 11.81a – Published on Cover Page. 

14 CFR 11.81b – Please see Section 5.

14 CFR 11.81c – Please see Sections 2, 3, 4 and

5. 14 CFR 11.81d – Please see Section 6.

14 CFR 11.81e – Please see Section 6. 

14 CFR 11.81f – Please see Section 7.

14 CFR 11.81g – Please see Appendices 1---4.

14 CFR 11.81h – Not applicable.

Approval of these exemptions will allow CSCG to conduct safe, commercial operation of 

small unmanned aircraft for the purposes of aerial photography, cinematography, 

videography, mapping, crop surveying, inspections, data collection, security monitoring, 

public safety assistance, search and rescue, first responder and emergency response support

and other flight operations.
16

Appendix 1: Sentera Phoenix UAS Pilot Operational Handbook 

Appendix 2: Sentera Phoenix A1, Phoenix M1, Vireo Pre-Flight Checklist

Appendix 3: Lockheed Martin Procerus Technologies Indago User Guide v1.1 

Lockheed Martin considers these documents to be proprietary information and prefers 

to keep this confidential. To make it available for review, it has been sent to 

333exemptions@faa.gov with the comment tracking number included in the email.

Please contact ftaylor@dc.rr.comwith questions or concerns.

Appendix 4: Lockheed Martin Procerus Technologies Indago Flight Checklist 

Lockheed Martin considers these documents to be proprietary information and prefers to 

keep this confidential. To make it available for review, it has been sent to 

333exemptions@faa.gov with the comment tracking number. Please contact 

ftaylor@dc.rr.com with questions or concerns.

Appendix	5:	DJI	Phantom	OperationsManual	

Appendix	6:	DJI	Inspire	Operations	Manual	

Appendix	7:	DJI	Inspire	MaintenanceManual	

Appendix	8:	DJI	Inspire	Safety	Guidelines	

Appendix	9:	DJI	Phantom	SafetyGuidelines

Appendix	10:	DJI	Intelligent	Flight	Battery	SafetyGuidelines	

Appendix	11:	DJI	Phantom	Pilot	TrainingGuide