U A G 

UNMANNED AVIATION GROUP 

Electronic Submission 

January 3, 2016 

U.S. Department of Transportation, Docket Operations 

West Building Ground Floor, Room W12-140 

1200 New Jersey Avenue, SE 

Washington, DC 20590 

Dear Sir or Madam: 

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (herein referred to as 

FMRA) and 14 CFR Part 11, Unmanned Aviation Group, LLC (herein referred to as UAG) hereby applies 

for an exemption from the listed Federal Aviation Regulations (FARs) to allow commercial operation 

of UAS for the acquisition of aerial data, so long as such operations are conducted within and under 

the conditions outlined herein or as may be established by the FAA. 

As detailed in this document and the attached Appendix of UAS, the requested exemption would 

permit the operation of UAS platforms previously approved by the FAA for commercial operations in 

the United States. Approval of this exemption would thereby enhance safety and fulfill the Secretary 

of TƌaŶspoƌtatioŶ’s ƌespoŶsiďilities to ͞...estaďlish ƌeƋuiƌeŵents for the safe operation of such aircraft 

sLJsteŵs iŶ the ŶatioŶal aiƌspaĐe sLJsteŵ.͟ “eĐtioŶ ϯϯϯ;ĐͿ Refoƌŵ AĐt.

The name and address of the applicant is: 

Petitioner: 

Unmanned Aviation Group, LLC 

3213 Duke St, #274 

Alexandria VA 22314 

Contact Person: 

Kiat Oboler, Esq 

The Oboler Law Firm, P.C. 

9921 4th Ave, Ste 5G 

Brooklyn NY 11209 

kobolerlaw@gmail.com 

(p) 646-522-1814
U A G 

UNMANNED AVIATION GROUP 

Regulations from which the exemption is requested: 

14 CFR Part 21 

14 CFR 45.23(b) 

14 CFR 61.113(a) & (b) 14 CFR 91.7(a) 

14 CFR 91.9(b)(2) 

14 CFR 91.103 

14 CFR 91.109 

14 CFR 91.119 

14 CFR 91.121 

14 CFR 91.151(a) 

14 CFR 91.203(a) & (b) 14 CFR 91.405(a) 

14 CFR 407(a)(1) 14 CFR 409(a)(2) 14 CFR 417(a) & (b) 

AUTHORITY FOR EXEMPTIONS 

The Federal Aviation Act expressly grants the FAA authority to issue exemptions. This statutory 

authority includes exempting civil aircraft, as the term is defined under §40101 of the Act, 

including UAS, from the requirement that all civil aircraft must have a current airworthiness 

certificate. 

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 this title if the 

Administrator finds the exemption in the public interest. 49 USC §44701(f). See also 49 USC 

§44711(a); 49 USC §44704; 14 CFR 91.203(a)(1). 

Section 333(b) of the Reform Act assists the Secretary in determining whether UAS may operate 

in the national airspace system without creating a hazard to the user, the public, or a threat to 

national security. In making this determination, the Secretary must consider: 

 i) The UA“’ size, ǁeight, speed aŶd opeƌatioŶal ĐapaďilitLJ;

 ii) Whether the UAS operates within the visual line of sight of the operator; 

 iii) Whether the UAS operates outside of highly populated areas and away from close 

proximity to airports. 

iv) Refoƌŵ AĐt ϯϯϯ;aͿ. If the “eĐƌetaƌLJ deteƌŵiŶes that a UA“ ͞ŵaLJ opeƌate safelLJ iŶ the 

national airspace system, the Secretary shall establish requirements for the safe 

operation of such aircraft iŶ the ŶatioŶal aiƌspaĐe sLJsteŵ.͟ Id. ϯϯϯ;ĐͿ.

BACKGROUND ON UAG 
U A G 

UNMANNED AVIATION GROUP 

UAG was founded in 2012 to provide clients (to include private sector business and non-profits, 

along with local state agencies) with expertise and knowledge in aerial data acquisitions, public 

relations and training using advanced technologies and solutions. The founding members of 

UAG are veterans of the armed forces and bring considerable experience to the fast growing 

unmanned aviation industry. 

Unmanned Aviation Group, LLC Board of Managers: 

Robert Kane, Managing Member 

Air Force Veteran – Robert is a military veteran pilot with 14 years of aviation experience and 

flight time in excess of 3500 incident free hours. Robert, the UAG Pilot in Command (PIC), is a 

certified commercially licensed airline pilot with the following certificates and ratings: 

ATP#3755508, FAA First Class Medical Certificate (No Restrictions), B-737, B-707, B-720, BE-400, 

MU-300 Type, USAF Senior Pilot, Flight Safety Commander, International Command Pilot. He is 

most recently tasked as Aircraft Commander, E-3A NATO AWACS (707-300). Robert was brought 

on board to UAG as our Pilot In Command and to build, manage, train and maintain our 

squadron of UAV pilot/operators. Robert ensures proper oversight on projects in the field, on

going training of our operator/pilots, and meticulous flight operations and maintenance 

records/logs of our aircraft. 

Gene Rowley, Co-Founder/Managing Member 

Army Special Forces Veteran – UAS Mission Commander, Gene has led 24/7 UAS operations in 

multiple contingency environments. He is considered one of the worlds foremost experts for the 

RQ-7B Shadow and has performed all aspects of UAV flight duties. Gene serves as UAG's chief 

UAS operations expert and works with clientele to build customized UAS solutions to their 

critical requirements. 

Cash Gordian, Co-Founder/Managing Member 

Air Force Veteran – Cash Gordian is a highly-regarded leader and acquisition expert with 20 plus 

years of experience in government procurement policy and process, he has a proven record of 

success in developing and building businesses related to public sector procurement and 

acquisition. Achieving the designation as Acquisition Professional, he held responsible positions 

as a warranted procuring and administrative contracting officer (PCO and ACO). He served for 20 

years as an officer in the US Air Force specializing in the Acquisition and Contract Management 

field. He possesses an unlimited warrant on behalf of the Department of Defense. Cash has a 

Bachelors Degree in Criminal Justice and possesses a Masters Degrees in Business 

Administration (MBA)And Master of Arts (MA) Degrees in both Procurement And Acquisitions 

Management And Organizational Security Management. 

At UAG, Cash leads strategic engagements with several federal clients in both civilian agencies 

and the Department of Defense. As a founder Cash has developed and grown UAG's capabilities 

thƌough leadeƌship aŶd suĐĐessful iŶtegƌatioŶ of the ĐoŵpaŶLJ’s AĐƋuisitioŶ, OƌgaŶizatioŶal, 

Performance and Program Management services. 

Gil Gordian, Founding/Co-Founder/Managing Member 
U A G 

UNMANNED AVIATION GROUP 

Air Force Veteran, and Juris Doctorate, Gil is an Intelligence, Surveillance, and Reconnaissance 

(ISR) Subject Matter Expert. As a former Air Force Officer he also has extensive experience in 

UAV and Fixed Wing Collection Management and Cyber Operations. Gil works closely with Mr. 

Cash Gordian by providing critical information on required sensor based systems and collection 

requirements needed to fulfill specific customer needs. He supports flight operations by 

ensuring the proper platforms are coupled with the most appropriate sensors and software to 

ensure mission success and client satisfaction. Gil also manages our compliance staff and works 

with Mr. Oboler to ensure the team is processing our clients' compliance documents in a timely 

and effective manner. Along with oversight of Section 333 Exemption submissions, he also 

overseas the continuous processing of specialized Certificate of Authorization requests and 

Notice To Airmen (NOTAM) submissions for our clientele. 

Kiat Oboler, Esq. – Managing Member 

Mr. Oboler, a New York State Attorney, has been working in the UAV industry providing legal 

compliance advice to clients since the inception of Unmanned Aviation Group in 2012. It is Mr. 

Oboler who overseas all regulatory issues for UAG and UAG clientele and ensures compliance 

via Section 333 Exemptions, Aircraft Registration, and Certificates of Waiver/Authorization. 

UAS AND OPERATIONAL DESCRIPTION 

UAG seeks to commercially operate a variety of UAS weighing less than 55 pounds including 

payload in the United States for the purpose of acquiring aerial data. The Appendix A attached 

to this exemption petition lists the aircraft that UAG contemplates operating. In prior, similar 

exemptions the Secretary has approved every UAS platform included in the Appendix A. UAG 

Flight Operations Manual is listed as Appendix B. 

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

on its operations. UAG understands that failure to comply will be grounds for the immediate 

suspension or rescission any exemption granted. 

1. Operations are limited to the UAS listed in the Appendix when weighing less than 55 

pounds including payload. 

2. Operations for the purpose of closed-set motion picture and television filming are not 

contemplated. 

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

no case will the aircraft be operated at airspeeds greater than the maximum aircraft 

operating airspeed recommended by the aircraft manufacturer. 

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

(AGL). 

5. Altitude must be reported in feet AGL. 

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

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

deǀiĐe otheƌ thaŶ ĐoƌƌeĐtiǀe leŶses, as speĐified oŶ the PIC’s U.“. dƌiǀeƌ’s liĐeŶse.
U A G 

UNMANNED AVIATION GROUP 

7. All operations will utilize a visual observer (VO). The aircraft will be operated within the 

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

8. All operating documents needed to operate the UAS and will be accessible during UAS 

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

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

9. Any UAS that has undergone maintenance or alterations that affect the UAS operation 

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

functional test flight prior to conducting further operations. 

10. UAG is responsible for maintaining and inspecting the UAS to ensure that it is in a 

condition for safe operation. 

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

in a condition for safe flight. 

12. UAG ǁill folloǁ the UA“ ŵaŶufaĐtuƌeƌ’s ŵaiŶteŶaŶĐe, oǀeƌhaul, ƌeplaĐeŵeŶt, 

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

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

bulletins. 

14. The PIC will hold a UAS flight training certificate, in some cases training directly from the

aiƌĐƌaft ŵaŶufaĐtuƌeƌ, aŶd a ǀalid U.“. dƌiǀeƌ’s liĐeŶse issued ďLJ a state, the DistƌiĐt of 

Columbia, Puerto Rico, a territory, a possession, or the Federal government. 

15. UAG will not permit any PIC to operate unless the PIC demonstrates the ability to safely 

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

aerial data, including evasive and emergency maneuvers and maintaining appropriate 

distances from persons, vessels, vehicles and structures. PIC qualification flight hours 

and currency will be logged in a manner consistent with 14 CFR § 61.51(b). UAG will 

operate flights for the purposes of training UAG PICs and VOs (training, proficiency, and 

experience-ďuildiŶgͿ aŶd deteƌŵiŶiŶg the PIC’s aďilitLJ to safelLJ opeƌate the UA“.

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

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

17. The aircraft will not operate within 5 nautical miles of an airport reference point (ARP) 

as denoted in the current FAA Airport/Facility Directory (AFD) or for airports not 

denoted with an ARP, the center of the airport symbol as denoted on the current FAApuďlished aeƌoŶautiĐal Đhaƌt, uŶless a letteƌ of agƌeeŵeŶt ǁith that aiƌpoƌt’s 

management is obtained or otherwise permitted by a COA. 

18. The aircraft will not be operated less than 500 feet below or less than 2,000 feet 

horizontally from a cloud or when visibility is less than 3 statute miles from the PIC. 

19. If the UAS loses communications or loses its GPS signal, the aircraft will return to a predetermined location. 

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

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

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

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

reserve power or fuel recommended by the manufacturer if greater. 

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

COA does not cover the intended operation. 
U A G 

UNMANNED AVIATION GROUP 

23. All aircraft operated will be identified by serial number, registered in accordance with 14 

CFR part κϳ, aŶd haǀe ideŶtifiĐatioŶ ;N−NuŵďeƌͿ ŵaƌkiŶgs iŶ aĐĐoƌdaŶĐe ǁith ϭκ CFR 

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

24. Documents used by UAG to ensure the safe operation and flight of the UAS and any 

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

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

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

activities at all times. 

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

requests will be made via subsequent COA. 

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

persons, vessels, vehicles, and structures unless barriers or structures are present that 

sufficiently protect nonparticipating persons from the aircraft or debris in the event of 

an accident; or the owner/controller/operator of any vessels, vehicles or structures has 

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

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

not present an undue hazard. 

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

nonparticipating persons under this exemption. 

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

with the permission from the property owner/controller or authorized representative. 

Permission from property owner/controller or authorized representative will be 

obtained for each flight to be conducted. 

30. Any incident, accident, or flight operation that transgresses the lateral or vertical 

boundaries of the operational area as defined by the applicable COA will be reported to 

the FAA's UAS Integration Office (AF“−ΘϬͿ ǁithiŶ Ϯκ houƌs. AĐĐideŶts ŵust ďe ƌepoƌted 

to the National Transportation Safety Board (NTSB) per instructions contained on the 

NTSB Web site: www.ntsb.gov. 

DESCRIPTION OF SPECIFIC REGULATIONS 

14 CFR Part 21, Subpart H: Airworthiness certificates Subpart H, establishes the procedural 

requirements for the issuance of airworthiness certificates as required by FAR §91.203(a)(1). 

Given the size and limited operating area associated with the aircraft to be utilized by UAG, an 

exemption from Part 21 Subpart H meets the requirements of an equivalent level of safety 

under Part 11 and Section 333 of the Reform Act. The Federal Aviation Act (49 USC §44701(f)) 

and Section 333 of the Reform Act both authorize the FAA to exempt aircraft from the 

requirement for an airworthiness certificate, upon consideration of the size, weight, speed, 

operational capability and proximity to airports and populated areas of the particular UAS. In all 

cases, an analysis of these criteria demonstrates that the UAS operated without an 

airworthiness certificate, in the restricted environment and under the conditions proposed, will 

be at least as safe, or safer, than a conventional aircraft operating with an airworthiness 

certificate without the restrictions and conditions proposed. 

14 CFR 45.23(b): Marking of the aircraft 
U A G 

UNMANNED AVIATION GROUP 

This regulation requires that certain experimental, provisionally certified aircraft, or light-sport 

ĐategoƌLJ aiƌĐƌaft to ďe ŵaƌked ǁith letteƌs ďetǁeeŶ Ϯ iŶĐhes aŶd ς iŶĐhes high ͞liŵited͟, 

͞ƌestƌiĐted,͟ ͞light-spoƌt,͟ ͞edžpeƌiŵeŶtal,͟ oƌ ͞pƌoǀisioŶal,͟ Ŷeaƌ eaĐh eŶtƌaŶĐe to a ĐaďiŶ, 

cockpit or pilot station. Even though the UAS will have no airworthiness certificate, an 

exemption may be needed as the UAS will have no entrance to the cabin, cockpit or pilot station 

oŶ ǁhiĐh the ǁoƌd ͞EdžpeƌiŵeŶtal͟ ĐaŶ ďe plaĐed. GiǀeŶ the size of the UA“, Ϯ iŶĐh letteƌiŶg ŵaLJ 

be impossible. UAG will mark the UAS as practicable. 

14 CFR 61.113(a) & (b): Private pilot privileges and limitations: Pilot in command 

Sections 61.113(a) and (b) limit private pilots to non-commercial operations. Because the UAS 

will not carry a pilot or passengers, the proposed operations can achieve the equivalent level of 

safety of current operations by requiring the pilot operating the aircraft to have completed a

UAS flight-training course. Unlike a conventional aircraft that carries the pilot and passengers, 

the UAS is remotely controlled. The area of operation is controlled and restricted, and all flights 

are planned and coordinated in advance. The risks associated with the operation of the UAS are 

so diminished from the level of risk associated with commercial operations contemplated by 

Part 61 when drafted, that allowing operations of the UAS as requested exceeds the present 

level of safety achieved by 14 CFR 61.113(a) and (b). 

14 CFR 91.7(a): Civil aircraft airworthiness 

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

condition. As there will be no airworthiness certificate issued for the aircraft UAG contemplates 

operating, should this exemption be granted, no FAA regulatory standard will exist for 

determining airworthiness. Given the size of the aircraft and the operational restrictions put on 

the aircraft, an equivalent level of safety will be provided. 

14 CFR 91.9(b)(2): Civil aircraft flight manual, marking and placard requirements 

The UAS, given its size and configuration has no ability or place to carry such a flight manual on 

the aircraft, not only because there is no pilot on board, but because there is no room or 

capacity to carry such an item on the aircraft. The equivalent level of safety will be maintained 

by keeping the Operating Manuals at the ground control point where the pilot flying the UAS 

will have immediate access to it. 

14 CFR 91.103: Preflight action 

This regulation requires each pilot in command take certain actions before flight to ensure the 

safety of flight. An exemption is needed from this requirement, as the pilot will take separate 

preflight actions, including checking for weather conditions, checking flight battery or fuel 

requirements, checking takeoff and landing distances, and all other actions in the Operating 

Manual and safety checklists. These actions will provide an equivalent level of safety. 
U A G 

UNMANNED AVIATION GROUP 

14 CFR 91.109: Flight instruction 

Section 91.103 provides that no person may operate a civil aircraft (except a manned free 

balloon) that is being used for flight instruction unless that aircraft has fully functioning dual 

controls. By design, UAS do not have fully functional dual controls. Flight control is accomplished 

through the use of a control box that communicates with the aircraft via radio communications. 

The equivalent level of safety is provided by the fact that neither a pilot nor passengers will be 

carried in the aircraft, the ability to control the UAS via radio signals from the controller and by 

the size and speed of the aircraft. 

14 CFR 91.119: Minimum safe altitudes 

Section 91.119 establishes safe altitudes for operation of civil aircraft. The UAS will never 

operate at altitude higher than 400 AGL and all operations will occur during daylight hours 

under Visual Meteorological Conditions (VMC) only. 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. Because 

advance notice to the property owner and any onsite personnel, as well as the precautions 

outlined below, all affected individuals will be aware of the planned flight operations. 

Flight operations will be conducted at least 500 feet from all non-participating persons (persons 

other than the pilot in command (PIC) or visual observer (VO)), vessels, vehicles and structures, 

unless operations do not present an undue hazard. 

The UAS will remain within visual line of sight of the PIC or VO. Flight operations will be 

conducted at least 5 miles from an airport. The PIC or VO will provide notification to the local 

Flight Standards District Office and airport controller of all operations within 5 miles of an 

airport. The FAA will have advance notice of all operations through the filing of notices-toairmen. 

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

proposed herein, any risk associated with our operations is far less than those presently 

presented with helicopters and other conventional aircraft operating at or below 500 feet AGL. 

In addition, the low-altitude operations of the UAS will ensure separation between these UAS 

operations and the operations of conventional aircraft that must comply with Section 91.119. 

14 CFR 91.121: Altimeter Settings 

This regulation requires each person operating the aircraft to maintain cruising altitude by 

reference to an altimeter that is set ͞...to the eleǀatioŶ of the depaƌtuƌe aiƌpoƌt oƌ aŶ 

appƌopƌiate altiŵeteƌ settiŶg aǀailaďle ďefoƌe depaƌtuƌe.͟ As the UA“ ŵaLJ Ŷot haǀe a 

barometric altimeter, but instead a GPS altitude read out, an exemption may be needed. An 

equivalent level of safety will be achieved by the PIC confirming the altitude of the launch site 

shown on the GPS altitude indicator before flight. 
U A G 

UNMANNED AVIATION GROUP 

14 CFR 91.151(a): Fuel requirements for flight in VFR conditions 

Section 91.151(a) outlines fuel requirements for beginning a flight in VFR conditions. Relief from 

Section 91.151(a)(1) is requested to the extent required to allow flights of a variety of UAS 

during 

daylight hours in visual flight rules (VFR) conditions to continue until 90 percent of remaining 

battery power or fuel reserves remain. UAG seeks the requested relief because without an 

exemption from Section 91.151(a)(1), the flight time duration of the selected aircraft will be 

reduced and severely constrain the practicality of any aerial acquisition of data that UAG 

proposes to conduct pursuant to this Petition. 

The teĐhŶiĐal speĐifiĐatioŶs of the pƌoposed UA“, theiƌ OpeƌatioŶs MaŶuals, aŶd UAG’s 

proposed operating limitations, ensure that UAG will safely operate the selected aircraft during 

daylight hours in VFR conditions until 90 percent of remaining battery power or fuel reserves 

remain. 

14 CFR 91.203(a) & (b): Carrying civil aircraft certification and registration 

The UAS has no cabin, cockpit or pilot station and is operated without an onboard pilot. 

Therefore, there is no ability or place to carry certification and registration documents or to 

display them on the UAS. An equivalent level of safety will be achieved by keeping these 

documents at the ground control point where the pilot flying the UAS will have immediate 

access to them, to the extent they are applicable to the UAS. 

14 CFR 91.405(a); 407(a)(1); 409(a)(2); 417(a) & (b): Maintenance inspections 

These ƌegulatioŶs ƌeƋuiƌe that aŶ aiƌĐƌaft opeƌatoƌ oƌ oǁŶeƌ ͞shall haǀe that aiƌĐƌaft iŶspeĐted 

as prescribed in subpart E of this part and shall between required inspections, except as 

provided in paragraph (c) of this section, have discrepancies repaired as prescribed in part 43 of 

this Đhapteƌ...,͟ aŶd otheƌs shall iŶspeĐt oƌ ŵaiŶtaiŶ the aiƌĐƌaft iŶ Đoŵpliance with Part 43. 

Given that these sections and Part 43 apply only to aircraft with an airworthiness certificate, 

these sections will not apply to UAG. Maintenance will be accomplished pursuant to the User 

Guide or 

Operating Manual. An equivalent level of safety will be achieved because these UASs are limited 

in size and will carry a small payload and operate only in restricted 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. The PIC 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 PIC is the person most familiar with the aircraft and best suited to maintain the aircraft in an 

airworthy condition to provide the equivalent level of safety. 

PUBLIC INTEREST 
U A G 

UNMANNED AVIATION GROUP 

Approval of exemptions allowing commercial operations of UASs for aerial acquisition of data 

enhances safety while reducing risk. Manned aircraft in certain application such as pipeline 

monitoring create a greater risk because the aircraft are much larger and carry an onboard 

human pilot. In contrast, a UAS weighing 55 pounds or less will carry no passengers or crew and, 

therefore, will not expose them to the risks associated with manned aircraft flights. In addition, 

additional streams of aerial data will allow large commercial entities to make decisions about 

how to best deploy ground resources and ensure the safety and cost-effectiveness of their 

operations. 

EQUIVALENT LEVEL OF SAFETY 

UAG proposes that the exemption requested herein apply to civil aircraft that have the 

characteristics and that operate within the limitations listed herein. These limitations provide 

for at least an equivalent or even higher level of safety to operations under the current and 

proposed regulatory structure. 

PRIVACY 

All flights ǁill oĐĐuƌ oǀeƌ pƌiǀate oƌ ĐoŶtƌolled aĐĐess pƌopeƌtLJ ǁith the pƌopeƌtLJ oǁŶeƌ’s pƌioƌ 

consent and knowledge. Images or video taken of individuals will have consented to being 

filmed or otherwise they will be made anonymous. 

NATIONAL SECURITY 

Given the small size of the UAS involved and the restricted environment within which they will 

operate, our petition presents no national security issue. 

FEDERAL REGISTER SUMMARY 

Docket No.: No. FAA-2015-____

Petitioner: Unmanned Aviation Group, LLC 

Part 21 and §§ 45.23(b), 61.113(a) and (b), 91.7(a), 91.9(b)(2), 91.103, 91.109, 91.119, 91.121, 

91.151(a), 91.203(a) and (b), 91.405(a), 407(a)(1), 409(a)(2), 417(a) and (b) of Title 14, Code of 

the Federal Regulations (14 CFR). 

Description of Relief Sought: UAG is seeking an exemption to conduct commercial acquisition of 

aerial data using unmanned aircraft systems. 

Based upon the foregoing, UAG requests that the FAA grant it the necessary exemptions under 

Section 333 of the FAA Reform Act as requested herein to allow for commercial operations of 

UAS within the United States. 

Sincerely, 
U A G 

UNMANNED AVIATION GROUP 

Kiat Oboler, Esq. 

Attorney At Law 

The Oboler Law Firm, P.C. 

9921 4th Ave, #5G 

Brooklyn NY 11209 

kobolerlaw@gmail.com 

On behalf of Petitioner: 

Unmanned Aviation Group, LLC 

3213 Duke St, #274 

Alexandria VA 22314 
U A G 

UNMANNED AVIATION GROUP 

Appendix A 

1. 3D Robotics Aero-M X8+ 

2. 3D Robotics X8+ 

3. 3D Robotics Aero-M 

4. 3D Robotics Solo 

5. DJI Phantom 3 Pro 

6. DJI Spreading Wings S1000+ 

7. DJI Spreading Wings S900 

8. DJI Inspire 

9. DraganFlyer X4-P 

10. Draganflyer X6 

11. Dragonflyer X4-ES

12. Event 38 E384 

13. PrecisionHawk Lancaster Hawkeye Mk-III

14. senseFly eBee 

15. senseFly eBee Ag 

16. senseFly eBee RTX 

17. senseFly SA eBee 

18. senseFly SA eBee RTK 

19. Tarot 690 

20. Tarot 960 

21. Tarot T-15

22. Tarot T-18

23. Tarot T810 

24. Trimble UX5 

25. UAV Factory Pelican B 

26. Yuneec Q500 
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UNMANNED AVIATION GROUP 

Appendix B 

UAG Flight Operations Manual 

The information contained in the Unmanned Aviation Group Flight Operations Manual is 

Proprietary and Confidential in nature. The UAG Flight Operations Manual has been submitted to 

the FAA for review and approval, separate and apart from submission to Regulations.gov of this 

Section 333 Petition for Exemption .