Petition for Exemption to 

the FAA

Augmented Sport Pilot Certification for sUAS 

operations

Prepared by Robert R. Murrell

CIO Aerialspecs, Inc.

48675 Jefferson Drive

Macomb, MI 48044

+1 (248) 845-8365

info@aerialspecs.com
Petition for Exemption to the FAA

Augmented Sport Pilot Certification for sUAS operations

TABLE OF CONTENTS

Summary...............................................................................................................................................................1

Exemption.............................................................................................................................................................1

Scope ....................................................................................................................................................................1

Specific Exemptions..............................................................................................................................................1

14 CFR §61.311 (c), (d), (e), (f), (g), (h), (i), and (j): What flight proficiency requirements must I meet to 

apply for a sport pilot certificate?...................................................................................................................1

14 CFR §61.313: What aeronautical experience must I have to apply for a sport pilot certificate?...............2

Glossary of Terms.................................................................................................................................................3

AGL........................................................................................................................................................................3

GPS........................................................................................................................................................................3

IMU.......................................................................................................................................................................3

SFC ........................................................................................................................................................................3

sUAS......................................................................................................................................................................3

UAV.......................................................................................................................................................................3

References............................................................................................................................................................4
Petition for Exemption to the FAA

Augmented Sport Pilot Certification for sUAS operations

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Copyright © Aerialspecs, Inc, 2015. All Rights Reserved

SUMMARY

Pursuant to 14 CFR Part 11, the following summary is provided by Aerialspecs, Inc. for publication in the Federal 

Register:

Aerialspecs, Inc. is seeking exemption from the following regulations to assist in the operation of small Unmanned 

Aerial Systems for the purposes of remote visual line-of-sight videography, data collection, sensing, and visual 

inspection:

 14 CFR §61.311 (c), (d), (e), (f), (g), (h), (i), and (j): What flight proficiency requirements must I meet to 

apply for a sport pilot certificate?

 14 CFR §61.313: What aeronautical experience must I have to apply for a sport pilot certificate?

Aerialspecs, Inc. is committed to the safety of the everyday worker and believes that through our services and this 

exemption we can provide safe, quality operations of sUAS to reduce the risk to employees, improve our 

customers OSHA ratings, and protect the public.

Douglas Sigler

CEO and Owner - Aerialspecs, Inc.

+1 (586) 745-4503

info@aerialspecs.com

Robert R. Murrell

CIO and Owner - Aerialspecs, Inc.

+1 (248) 845-8365

info@aerialspecs.com
Petition for Exemption to the FAA

Augmented Sport Pilot Certification for sUAS operations

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Copyright © Aerialspecs, Inc, 2015. All Rights Reserved

EXEMPTION

SCOPE

The scope of this exemption includes Aerialspecs, Inc. employees, affiliates, partners, vendors, or any 

other person or entity operating in a flight capacity on behalf of Aerialspecs, Inc. for the purpose of 

commercial visual line-of-sight sUAS operations pursuant to exemption 119651 as listed in regulatory 

document number FAA-2015-02222.

Employees, affiliates, partners, vendors, or any other person or entity operating in a flight capacity on 

behalf of Aerialspecs, Inc. who already possess a full pilots certificate pursuant to part 13 of exemption 

119651will be out of scope for this exemption.

SPECIFIC EXEMPTIONS

14 CFR §61.311 (C), (D), (E), (F), (G), (H), (I), AND (J): WHAT FLIGHT PROFICIENCY REQUIREMENTS 

MUST I MEET TO APPLY FOR A SPORT PILOT CERTIFICATE?

These regulations state:

“To apply for a sport pilot certificate you must receive and log ground and flight training from an authorized 

instructor on the following areas of operation, as appropriate, for airplane single-engine land or sea, glider, 

gyroplane, airship, balloon, powered parachute land or sea, and weight-shift-control aircraft land or sea 

privileges:

(c) Airport, seaplane base, and gliderport operations, as applicable.

(d) Takeoffs (or launches), landings, and go-arounds.

(e) Performance maneuvers, and for gliders, performance speeds.

(f) Ground reference maneuvers (not applicable to gliders and balloons).

(g) Soaring techniques (applicable only to gliders).

(h) Navigation.

(i) Slow flight (not applicable to lighter-than-air aircraft and powered parachutes).

(j) Stalls (not applicable to lighter-than-air aircraft, gyroplanes, and powered parachutes).”

Aerialspecs, Inc. is seeking exemption from flight training in these regulations as the skills imparted by 

flight training are not applicable to the operation of sUAS pursuant to exemption 119651 granted to 

Aerialspecs, Inc. for the following reasons:

1. The outlines for most performance maneuvers violate the maximum altitude and airspeeds 

defined in exemption 119651 which define a maximum altitude of 400 ft. (121.92 m) AGL and a 

maximum ground speed of 100 mph (44.704 m/s).

2. Most traffic patterns defined cover distances that violate operating an sUAS within visual line of 

sight of the pilot pursuant to exemption 119651.

3. Ground reference maneuvers are irrelevant as the pilot in command is not stationed in the 

vehicle and has no visual frame of reference from the vehicles perspective.

4. All sUAS listed in exemption 119651 operate in computer aided modes that use GPS, IMU, and 

compass heading to compensate for drift, encourage slow flight as the norm, and reduce or 

prevent stalls.

Aerialspecs, Inc. will maintain the level of safety to the public intended by these regulations by still 

requiring ground training from an authorized instructor. Aerialspecs, Inc. will also validate pilot 

proficiency pursuant to part 14 of exemption 119651 which states:
Petition for Exemption/Rulemaking to the FAA

Commercial visual line-of-sight sUAS operations

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Copyright © Aerialspecs, Inc, 2015. All Rights Reserved

“The operator may 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 under this exemption, including evasive and 

emergency maneuvers and maintaining appropriate distances from persons, vessels, vehicles and structures. 

PIC qualification flight hours and currency must be logged in a manner consistent with 14 CFR § 61.51(b). 

Flights for the purposes of training the operator’s 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 permitted under the terms of this exemption. However, training operations 

may only be conducted during dedicated training sessions. During training, proficiency, and experiencebuilding flights, all persons not essential for flight operations are considered nonparticipants, and the PIC must 

operate the UA with appropriate distance from nonparticipants in accordance with 14 CFR § 91.119.”

14 CFR §61.313: WHAT AERONAUTICAL EXPERIENCE MUST I HAVE TO APPLY FOR A SPORT PILOT 

CERTIFICATE?

This regulation defines the number of flight hours required to apply for a sport pilot certificate.

Aerialspecs, Inc. is seeking exemption from flight time requirements on the following grounds:

1. The pilot in command is not stationed inside the vehicle and therefore has a different frame of 

reference not taught during traditional flight instruction such as flight requiring reverse control 

input when the UAV is flying toward the pilot.

2. No standards or guidelines exists for authorized flight instructors to impart flight skills for sUSA.

Aerialspecs, Inc. will maintain the level of safety to the public intended by these regulations by still 

requiring ground training from an authorized instructor. Aerialspecs, Inc. will also validate pilot 

proficiency pursuant to part 14 of exemption 119651 which states:

“The operator may 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 under this exemption, including evasive and 

emergency maneuvers and maintaining appropriate distances from persons, vessels, vehicles and structures. 

PIC qualification flight hours and currency must be logged in a manner consistent with 14 CFR § 61.51(b). 

Flights for the purposes of training the operator’s 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 permitted under the terms of this exemption. However, training operations 

may only be conducted during dedicated training sessions. During training, proficiency, and experiencebuilding flights, all persons not essential for flight operations are considered nonparticipants, and the PIC must 

operate the UA with appropriate distance from nonparticipants in accordance with 14 CFR § 91.119.”

In addition, Aerialspecs, Inc. will require the same logged flight time on the sUAS as defined by the 

aeronautical experience table defined in 14 CFR 61.313 for the equivalent vehicle before commercial

operations are allowed pursuant to part 14 of exemption 119651. The following table defines the logged 

flight times required:

sUAS Vehicle Classification Logged Flight Hours

Instructor Lead Solo (With VO)

Fixed Wing 15 5

Multi-Rotor 15 5
Petition for Exemption/Rulemaking to the FAA

Commercial visual line-of-sight sUAS operations

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Copyright © Aerialspecs, Inc, 2015. All Rights Reserved

GLOSSARY OF TERMS

AGL

Above Ground Level: The altitude above ground level for any given location.

GPS

Global Positioning System: A device used to determine geographic position I latitude, longitude and 

altitude above sea level.

IMU

Inertial Measurement Unit: Sometimes referred to as a solid state gyro, an IMU determines position and 

orientation or an object through a technique known as dead reckoning by detecting the gravitational 

force, or G, on a particular axis.

SFC

Surface or Ground Level.

SUAS

Small Unmanned Aircraft System: A UAV and all its supporting systems for operations. Usually includes 

the remote controller and ground stations used for communication, imagery, and telemetry.

UAV

Unmanned Aerial Vehicle: An unmanned, remotely operated, aerial vehicle in a fixed wing or multiple 

rotor copter configuration.
Petition for Exemption/Rulemaking to the FAA

Commercial visual line-of-sight sUAS operations

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Copyright © Aerialspecs, Inc, 2015. All Rights Reserved

REFERENCES

1. Aerialspecs, Inc. Exemption

http://aes.faa.gov/AES.NET/GetPDFDocument.aspx?ExemptNo=11965

2. Regulatory Docket Number FAA-2015-0222

http://www.regulations.gov/#!searchResults;rpp=25;po=0;s=faa-2015-0222;fp=true;ns=true