May 7, 2015

U.S. Department of Transportation

Docket Management System

1200 New Jersey Ave., SE Washington, DC 20590

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

Federal Aviation Regulations

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, Unlimited Aerial Systems (“Unlimited Aerial Systems”), the developer 

and operator of the Scout and Boomerang small Unmanned Aircraft Systems ( “sUAS”), seeks an 

exemption from the Federal Aviation Regulations (“FARs”) listed below and discussed in 

Appendix A. Details of Unlimited Aerial Systems and the Boomerang sUAS are described in 

Appendix B. Attached as Appendix C is a summary of this request.

The requested exemption would permit Unlimited Aerial Systems commercial operation of 

Unlimited Aerial System’s Boomerang (see details in Appendix B), which weighs 6 lbs. with 

imaging payload, to perform market research, aerial surveys, mapping, and inspections that 

consist of still photographs, video, and other data taken by onboard sensors. The Boomerang 

produces high quality imagery and data that can be used independently - or in the case of 

surveying and modeling, can be combined to produce precision digital point clouds, triangle 

models, and contour maps of the surveyed area. Applications for these sUAS’s include:

surveillance for Law Enforcement and Public Safety, intelligence and real-time imagery to aid in 

firefighting and investigative actions, inspection of sensitive infrastructure including oil and 

gases pipelines and flare stacks, power lines and towers, wind turbines, and surveying tasks such 

as precision agriculture, mining, transportation, and forestry. Use of the Boomerang for these 

inspection and surveying applications reduces the need to operate conventional aircraft, 

providing data more quickly, accurately, economically, safely, and with reduced environmental 

impact.

Operations under the exemption will be subject to strict operating requirements and conditions to 

ensure at least an equivalent level of safety to currently authorized operations using manned 

aircraft and under conditions as may be modified by the FAA as required by Section 333.

While Unlimited Aerial Systems is filing this exemption request on its own behalf, it anticipates 

that its customers, in the future, will file exemption applications to allow them to operate the 

Boomerang in commercial operations at their own facilities, farms, mines, and other sites that 
require aerial data for inspections and surveys. Wherever possible, those filings will be 

substantially similar to this exemption application.

As described more fully below, the requested exemption would authorize Unlimited Aerial 

Systems to perform market research and commercial operations of aerial inspections and surveys 

using the Boomerang, which at 6 lbs. is small in size and powered electrically by battery. The 

Boomerang will be operated under controlled conditions at low altitude in airspace that is limited 

in scope, as described more fully herein; It will have automated control features, as described 

below. The Unlimited Aerial Systems Boomerang is designed to be operated by one person but 

flight operations generally involve two people: an operator and an observer. The operator is 

responsible for flying the sUAS, monitoring its status and flight dynamics while maintaining 

visual line of sight, and keeping the flight within the specified factory limits (in terms of wind, 

flight range, battery life, etc.) to ensure safe operation of the sUAS itself. The observer is 

responsible for monitoring the airspace for other aircraft and hazards and instructing the operator 

before and during flight as necessary to ensure safe separation/de-confliction with these aircraft 

and hazards. The operator also will be an individual who has passed an FAA approved or 

equivalent ground training exam and authorized Unlimited Aerial Systems training program for 

the Boomerang. Finally, the airspace in which the Boomerang will operate will be disclosed to 

and approved, as needed, by the FAA in advance.

Unlimited Aerial Systems respectfully submits that because this small, unmanned aerial system –

the Boomerang – will be used in lieu of comparatively hazardous operations now conducted with 

fixed wing and rotary conventional aircraft, the FAA can have confidence that the operations 

will achieve at least an equivalent level or greater level of safety. Approval of this exemption 

would thereby enhance safety and fulfill the Secretary of Transportation’s (the FAA 

Administrator’s) responsibilities under Section 333(c) of the Reform Act to “establish 

requirements for the safe operation of such aircraft systems in the national airspace system.”

The name and address of the applicant are: 

Unlimited Aerial Systems 

Attn: Chad Swan

Ph: 850-332-7022

Fax: 850-477-2127

Email: Chad@CreativeDevSol.com

Address: 5945 Creek Side Circle, Pensacola, FL 32504

The primary contact for this application is:

Unlimited Aerial Systems

David Sweeney, Sweeneyusmc@gmail.com, 318-332-7192

The regulations from which the exemption is requested are as follows:

14 C.F.R. Part 21;

14 C.F.R. 45.23(b);

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. 91.9(b)(2) & (c);

14 C.F.R. 91.103;

14 C.F.R. 91.109(a);

14 C.F.R. 91.119;

14 C.F.R. 91.151(a);

14 C.F.R. 91.203(a) & (b);

14 C.F.R. 91.405(a);

14 C.F.R. 91.407(a)(1);

14 C.F.R. 91.409(a)(2);

14 C.F.R. 91.417(a)

Appendix A discusses each rule listed above and explains why exemptions pursuant to the 

proposal set forth in this letter are appropriate, provide an equivalent level of safety, and are in 

the public interest. 

THE APPLICABLE LEGAL STANDARD UNDER SECTION 333

Unlimited Aerial Systems submits that grant of this exemption application for use of the 

Boomerang in market research, surveying, mapping and inspection operations will advance the 

Congressional mandate in Section 333 of the Reform Act to accelerate the introduction of sUASs 

into the national airspace system (“NAS”) if it can be accomplished safely. This law directs the 

Secretary of Transportation to consider whether certain sUASs may operate safely in the 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 sUASs 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 sUAS’s size, weight, speed, and operational capability;

● Operation of the sUAS in close proximity to airports and populated areas; and

● Operation of the sUAS within visual line of sight of the operator.

Reform Act § 333(a)(1). 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).

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

statutory authority, by its terms, includes exempting civil aircraft, as the term is defined under 

§40101 of the Act, from the requirement that all civil aircraft must have a current airworthiness

certificate and those regulations requiring commercial pilots to operate aircraft in commercial 

service:

The Administrator may grant an exemption from a requirement of a regulation prescribed under 

subsection (a) or (b) of this section or any of sections 44702-44716 of this title if the 

Administrator finds the exemption is in the public interest.
49 U.S.C. §44701(f). See also 49 USC §44711(a); 49 USC §44704; 14 CFR §91.203(a)(1).

The grant of the requested exemption is in the public interest based on the clear direction in 

Section 333 of the Reform Act; the additional authority in the Federal Aviation Act, as amended; 

the strong equivalent level of safety surrounding the proposed operations; and the significant 

public benefit, including enhanced safety and cost savings associated with transitioning to 

sUASs for aerial surveying, mapping and inspection applications. Accordingly, the applicant 

respectfully requests that the FAA grant the requested exemption without delay.

Airworthiness of the Boomerang

A critical element of the exemption application involves evidence of the airworthiness of 

Unlimited Aerial Systems sUAS including the Boomerang. Unlimited Aerial Systems believes 

that it has shown compliance through successful flights - including many operations with public 

agencies. There have been numerous successful flights with University of Louisiana, Monroe, 

University of California, Davis, numerous state government entities of Louisiana and 

commercial service providers such as VDOS LLC.

Applicant submits that this provision places a duty on the Administrator to not only process 

applications for exemptions under Section 333, but for the Administrator, if he deems the 

conditions proposed herein require modification in order to allow approval, to supply conditions 

for the safe operation of the sUAS. Unlimited Aerial Systems welcomes the opportunity to 

consult with FAA staff in order to address any issues or concerns that this proposal may raise 

that they believe may require modification. The Boomerang also has a significant set of 

automated features to ensure safe takeoff, flight and landing in many conditions, further details 

of operation can be found in Appendix B.

Mandatory Operating Conditions

Grant of the exemption to Unlimited Aerial Systems will be subject to the following mandatory

conditions, which are based upon operating conditions set forth for operation of sUAS by public 

entities pursuant to Certificates of Authorization, with additional restrictions:

● All operations to occur in Class G airspace

● Operations to avoid congested or populated areas, which are depicted in yellow on VFR 

charts

● Operations to be conducted over private or controlled access property

● Permission from land owner/controller required before commencing any flight

● Operations to occur during Visual Flight Rules Meteorological Conditions (“VMC”)

● Aircraft to remain within Visual Line of Sight (“VLOS”)

● VLOS guaranteed with a cylinder of operation around operator of 1⁄2 nautical miles (“NM”)

● Cylinder walls may be expanded by observer with ability to control aircraft

● Operations to occur during daylight hours
● Above Ground Level (“AGL”) altitude to be restricted to 400 feet

● All operations conducted in vicinity of airport to remain more than 2.5 NM from centerline 

azimuth of runway centerline measured from runway thresholds

● Operator will file a NOTAM for each flight

● All required permissions and permits will be obtained from territorial, state, county or city 

jurisdictions, including local law enforcement, fire, or other appropriate governmental agencies.

● All operations will include one pilot for flight control and one observer for VLOS 

enhancement of surrounding area near the aircraft

Operator Requirements:

Unlimited Aerial Systems respectfully proposes that operator requirements should take into 

account the characteristics of the particular sUAS. Certain sUASs, such as the Unlimited Aerial 

Systems Boomerang, are characterized by a high degree of pre-programmed control and various 

built-in technical capabilities that limit the potential for operation outside of the operating 

conditions set forth above. The Boomerang sUAS also provides many built-in functional and 

safety features to assist the operator in safe and reliable operation. Unlimited Aerial Systems can

submit under confidentiality the following documents in support of this exemption application 

for the Boomerang: 1) Unlimited Aerial Systems Boomerang User Guide (Exhibit 1) which 

includes Safety and Pre-Flight Checklists; and 2) Training Manual (Exhibit 2).

As of May 2015, Unlimited Aerial Systems staff and customers have performed over 200 flights, 

logging 120 hours of flight time with the Boomerang with both development and release versions. 

The previous generation product, Scout, achieved over 7,197 flights and 839 hours of flight time 

globally by Unlimited Aerial Systems and its customers. This is a significant amount of flight 

time collected to understand and refine the Unlimited Aerial Systems sUAS products. 

The Unlimited Aerial Systems Boomerang provides two semi-autonomous flight modes using a 

point-and-click map and video interface. The user clicks on a map to direct the Boomerang to fly 

to the point on the map where the operator is pointing, or programmed flight plans may be 

entered for a series of waypoints or grid-based area. Additional navigation aids including landing 

zones and flight areas may be designated to ensure the Boomerang operates only within user 

specified flight parameters. All flight operations are GPS controlled making the system easy to 

navigate, and the flight control system also employs a variety of sensors including sonar, 

barometric pressure, temperature, wind speed and others to ensure the high stability and 

reliability in challenging weather conditions. At all times during flight operations, the operator 

can intervene a programmed flight and take immediate control.

Additional automated safety functions and safety enhancing features of the Boomerang include 

the following:

● Automated pre-flight system performance checks

● User pre-flight checklist

● Automated condition or fault detection, warnings, and pre-defined responses to a number of 

flight and system conditions.

◦ High winds with system and user defined safety thresholds

◦ Low battery with system and user defined safety thresholds

◦ High temperature or other system safety thresholds
◦ Lost-link communication

● Pre-defined responses include behavior such as attempting to re-establish radio 

communication, return to home position and hover, return to home position and land, or land in 

current position

● In the case of lost GPS, a manual user flight mode is enabled which allows the operator to 

provide manual navigation inputs to assist in landing the vehicle.

Given these safety features, Unlimited Aerial Systems proposes that operators of the Boomerang 

should not be required to hold a commercial or private pilot certification. Instead, operators 

should be required to:

● have successfully completed, at a minimum, FAA private pilot ground instruction and passed 

the FAA Private Pilot written examination or FAA-recognized equivalents including commercial 

or private license and ground school issued from an ICAO recognized country;

● have completed Unlimited Aerial System’s authorized training program for operation and 

maintenance of the sUAS.

Unlimited Aerial Systems notes that the FAA has found that safety factors permitted operation of 

sUASs by operators with these qualifications in the case of operations pursuant to public COAs 

when the mandatory operating conditions specified above were present. See Federal Aviation 

Administration, Notice N-8900.227, Unmanned Aircraft Systems (UAS) Operational Approval, 

at 20-21 (July 30, 2013). The FAA has the statutory authority to grant exemptions to the 

requirements for and privileges associated with the grant of airmen’s certificates. 49 USC 

§44701 (f).

In summary, applicant seeks an exemption from the FARs set forth above and in Appendix C to 

allow market research and commercial operations of a small unmanned vehicle in surveying, 

mapping and inspection operations.

Approval of the exemption allowing commercial operations of the Boomerang for surveying, 

mapping and inspection operations will enhance safety by reducing risk. Conventional aerial 

survey and inspection operations using manned aircraft involve very heavy aerial vehicles 

carrying significant quantities of combustible fuels, and a militiaperson crew in piloting and 

observation roles. These operations require transit to and from the location of the activity, and 

often take place in congested environments including proximity to physical obstacles and/or 

presence of the general public. By contrast, the Boomerang weighs 6 lbs. including payloads and 

uses a battery for power, is carried to/from the area of activity, removes the need for airborne 

pilots/observers, and poses less risk to people and infrastructure on the ground.

Additionally, no national security issue is raised by the grant of the requested exemptions. Given 

the size, load carrying capacity, speed at which it operates, and the fact that it carries no 

explosives or other dangerous materials, the Boomerang poses no threat to national security.

The operation of the Boomerang for market research, surveying, mapping and inspection 

operations in accordance with the strict conditions outlined above, will provide an equivalent 
level of safety supporting the grant of the exemptions requested herein, including exempting 

Unlimited Aerial Systems from the requirements of Part 21.

The Boomerang’s satisfaction of the criteria set forth in Section 333 of the Reform Act—size, 

weight, speed, operating capabilities, lack of proximity to airports and populated areas, operation 

within visual line of sight, and national security – and its showing of an equivalent level of safety 

as it may relate to the requirement for a pilot’s license, provide more than adequate justification 

for the grant of the requested exemptions allowing Unlimited Aerial Systems commercial 

operation of the Boomerang in market research, surveying, mapping and inspection operations.

Very truly yours,

Chad D. Swan

Unlimited Aerial Systems 
APPENDIX A

EXEMPTION REQUEST AND EQUIVALENT LEVEL OF SAFETY SHOWINGS UNDER 

APPLICABLE RULES SUBJECT TO EXEMPTION

Unlimited Aerial Systems requests an exemption from the following regulations as well as any 

additional regulations that may technically apply to the operation of the Boomerang:

14 C.F.R. Part 21, Subpart H: Airworthiness Certificates

14 CFR § 91.203(a)(1)

Section 91.203(a)(1) requires all civil aircraft to have a certificate of airworthiness. Part 21, 

Subpart H, entitled Airworthiness Certificates, establishes the procedural requirements for the 

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

aircraft (6 lbs.) and the limited operating area associated with its utilization, it is unnecessary to 

go through the certificate of airworthiness process under Part 21 Subpart H to achieve or exceed 

current safety levels.

Such an exemption meets the requirements of an equivalent level of safety under Part 11 and 

Section 333 of the Reform Act. The Federal Aviation Act 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 sUAS involved.

In this case, an analysis of these criteria demonstrates that the Boomerang operated without an 

airworthiness certificate, under the conditions proposed herein, will be at least as safe, or safer, 

than a conventional aircraft (fixed wing or rotorcraft) with an airworthiness certificate. The 

Boomerang weighs 6 lbs. fully loaded. It will not carry a pilot or passenger, will not carry

flammable fuel, and will operate exclusively within an area pre-disclosed and in compliance with 

conditions set forth herein. Operations under this exemption will be tightly controlled and 

monitored by both the operator, pursuant to the conditions set forth above, and by local public 

safety requirements. The FAA will have advance notice of all operations through the filing of 

NOTAMs. Receipt of the prior permission of the land owner, the size of the aircraft, the lack of 

flammable fuel, and the fact that the aircraft is carried to the location and not flown there all 

establish the equivalent level of safety. The Boomerang provides at least an equivalent, and most 

likely exceeds, a level of safety to that of such operations being conducted with conventional 

aircraft that would be exponentially larger and would be carrying passengers, cargo, and 

flammable fuel. The automated safety features including redundant sensor systems as described 

in Appendix B and throughout this document highlight the design intentions towards safety and 

reliability on Boomerang.

An Unlimited Aerial Systems internal report compares the crash kinetic energy dissipation rate 

of a commercial airline versus the Unlimited Aerial Systems Boomerang. The report found the 

MTTF of Boomerang needs to only be > 2.3 hours to equal the energy dissipation of the gold 
standard commercial aircraft. Transport Canada has issued a report on low energy RPA and 

determined the Unlimited Aerial Systems Scout, at a typical max kinetic energy of 1.45 J/cm2, to 

be well below the recommended peak energy level of 12 J/cm2on impact. Since the Boomerang 

is similar in construction, it could be considered to be below this threshold as well. 

14 C.F.R. § 45.23 & 91.9(c): Marking of the Aircraft Regulation 45.23 provides:

(a) Each operator of an aircraft must display on that aircraft marks consisting of the Roman 

capital letter “N” (denoting United States registration) followed by the registration number of the 

aircraft. Each suffix letter used in the marks displayed must also be a Roman capital letter.

(b) When marks include only the Roman capital letter “N” and the registration number is 

displayed on limited, restricted or light sport category aircraft or experimental or provisionally

certificated aircraft, the operator must also display on that aircraft near each entrance to the cabin, 

cockpit, or pilot station, in letters not less than 2 inches nor more than 6 inches high, the words 

“limited,” “restricted,” “light sport,” “experimental,” or “provisional,” as applicable.

Regulation 91.9(c) provides:

No person may operate a US registered civil aircraft unless that aircraft is identified in 

accordance with part 45 of this chapter.

The Boomerang has no entrance to the cabin, cockpit, or pilot station on which the markings can 

be placed. Given the size of the sUAS, two-inch lettering will be impossible. Official marking 

systems for small UAS have not yet been established for operations inside the NAS. The 

Boomerang is currently marked with a fixed label containing “Unlimited Aerial Systems Labs 

Boomerang” measuring 1.5” x 0.5” as well as a serial number located under the removable 

camera payload. Unlimited Aerial Systems is prepared to mark the inspection system with the 

name of the organization and location or origin and fulfill any other request by the FAA to this 

topic in accordance to § 45.29(f) where the pilot, observer, and others working with the sUAS 

will see the identification of the sUAS.

The FAA has issued the following exemptions to this regulation; see Exemption Nos. 8738, 

10167, 10167A and 10700.

14 C.F.R. § 61.113(a) & (b); 61.133(a): Private Pilot Privileges and Limitations; Pilot in

Command; Commercial Pilot Privileges and Limitations.

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

aircraft that carries a pilot, passengers, and cargo, the Boomerang in this case 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. Unlimited Aerial Systems respectfully proposes that operator requirements 

should take into account the characteristics of the particular sUAS. Unlimited Aerial Systems’s 

Boomerang 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.
The Boomerang has an all-digital software platform with advanced features previously restricted 

to full size unmanned aircraft. Automated features and advanced fly-safe controls enable safe, 

reliable operation, as well as advanced networking capabilities and system extensibility.

● Plan your flight or fly manually: The system can autonomously fly a programmed flight path 

or fly in manual mode

● Smart batteries and charger: Flight time and battery minutes are displayed at all times. The 

system will return home and land automatically if user configurable limits are reached. 

Flight safety is a priority, no matter the operating environment or project. The Boomerang offers 

superior safety over manned aircraft by removing the need for people to be onboard in 

potentially dangerous situations. With multiple built-in safety features, the Unlimited Aerial 

Systems platform leads other sUAS with respect to safety.

● Intelligent fault handling: The system automatically detects potential issues - with 

configurable automated response behavior such as a return-home-and-land routine

● Automatic pre-flight checks: The system self-calibrates all of its sensors and performs 

self-tests prior to takeoff to check for errors

● No-fly zones: The system has the ability to set up visual no-fly zones

● Self-monitoring: Monitoring battery levels, in-flight wind speeds, and other system and 

environmental conditions are automatically handled by the system

● Battery communication: Battery minutes and flight time are displayed at all times. The system 

will return home and land automatically if user-configurable limits are reached.

Additional automated safety functions and safety enhancing features of the Boomerang include 

the following:

● Auto detection of lost GPS warns the pilot and initiates an immediate landing.

● Low battery on the Boomerang triggers a Non-Fatal Warning alarm to return home, land and 

replace the battery

● Very low battery on the Boomerang triggers a Fatal Error alarm and initiates an emergency

high speed descent landing.

● If the Boomerang detects a lost-link to the base station the vehicle will perform its pre-defined

Non-Fatal, Condition Response.

Given these safety features, Unlimited Aerial Systems proposes that operators of the Boomerang 

should not be required to hold a commercial or private pilot certification. Instead, operators 

should be required to:

● have successfully completed, at a minimum, FAA private pilot ground instruction and passed 

the FAA Private Pilot written examination or FAA-recognized equivalents including ICAO 

issued commercial, private license and ground school;

● have completed Unlimited Aerial Systems’s training program for operation of the sUAS.

Unlimited Aerial Systems notes that the FAA has found that safety factors permitted operation of 

sUASs by operators with these qualifications in the case of operations pursuant to public COAs 

where the mandatory operating conditions specified above are present. See Federal Aviation 

Administration, Notice N-8900.227, Unmanned Aircraft Systems (UAS) Operational Approval, 
at 20-21 (July 30, 2013). The FAA has the statutory authority, granted at 49 U.S.C.§44701(f) to 

waive the pilot requirements for commercial operations.

Given these conditions and restrictions, an equivalent level of safety will be provided by

allowing operation of the Boomerang without a private pilot’s certificate or a commercial pilot’s 

certificate, under the conditions set forth herein.

The risks associated with the operation of the Boomerang (given its size, speed, operational 

capabilities, and lack of combustible fuel) are so diminished from the level of risk associated 

with private pilot operations or commercial operations contemplated by Part 61 with 

conventional aircraft (fixed wing or rotorcraft), that allowing operations of the sUAS as set forth 

above meets or exceeds the present level of safety provided under 14 C.F.R. § 61.113(a) & (b) 

and does not rise to the level of requiring a commercial pilot to operate the aircraft under § 

61.133(a). 

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 Boomerang 

without an airworthiness certificate, no standard will exist for airworthiness of the Boomerang. 

Given the size of the aircraft and the previous COAs issued for Unlimited Aerial Systems’s 

Scout and Boomerang, an equivalent level of safety will be achieved by ensuring compliance 

with the Unlimited Aerial Systems manuals prior to each flight.

14 C.F.R. § 91.9(b)(2): Civil Aircraft Flight Manual in the Aircraft.

The regulation provides:

No person may operate a US registered civil aircraft ...

(2) For which an Airplane or Rotorcraft Flight Manual is not required by §21.5 of this chapter, 

unless there is available in the aircraft a current approved airplane or Rotorcraft Flight Manual, 

approved manual material, markings, and placards, or any combination thereof.

Given the size and configuration of the Boomerang, it 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 achieved by keeping the flight manual (see, e.g., User 

Guide, Exhibit 1) at the ground control point where the pilot flying the sUAS will have 

immediate access to it. The FAA has issued to others the following exemptions to this regulation: 

Exemption Nos. 8607, 8737, 8738, 9299, 9299A, 9565, 9565B, 10167, 10167A, 10602, 32827, 

and 10700.
14 C.F.R. § 91.103: Preflight action

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

safety of flight. As FAA approved rotorcraft flight manuals will not be provided for the aircraft,

an exemption will be needed. An equivalent level of safety will be provided as set forth in the 

Boomerang User Manual (exhibit 1) under the ‘Getting Ready to Fly’ section. The PIC will take 

all actions including reviewing weather, flight battery requirements, landing and takeoff 

distances and aircraft performance data before initiation of flight.

14 C.F.R. § 91.109(a) & 91.319(a)(1): Flight Instruction

These regulations provide 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.

The Boomerang is a remotely piloted aircraft and by design, does 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 flight plan is either manually controlled through 

point-and-click touchscreen navigation or pre-programmed as waypoints or an Auto Grid into the 

auto pilot before or during flight and only in unusual circumstances will the pilot input control 

functions to alter the pre-programmed flight. If instruction is accomplished through a training 

program, as set forth in Exhibit 2, an equivalent level of safety will be assured. The FAA has 

approved exemptions for flight training without fully functional, dual controls for a number of 

aircraft and for flight instruction in experimental aircraft. See Exemption Nos. 5778K & 9862A. 

The equivalent level of safety will be achieved by the manufacturer providing the training as 

outlined, for example, in Exhibit 2 and through the use of experienced and qualified pilots 

familiar with the Boomerang.

14 CFR § 91.119: Minimum Safe Altitudes

Section 91.119 establishes safe altitudes for operation of civil aircraft. Specifically, 91.119(c) 

limits aircraft flying over areas other than congested areas to an altitude of 500 feet above the 

surface, except over open water or sparsely populated areas. In those cases, the aircraft may not 

be operated closer than 500 feet to any person, vessel, vehicle, or structure.

As set forth herein, the Boomerang will never operate at higher than 500 feet AGL. It will, 

however, be operated to avoid congested or populated areas that are depicted in yellow on VFR 

sectional charts. Because aerial survey, mapping and inspection work must be accomplished at 

relatively low altitudes and at altitudes less than 500 feet AGL, an exemption from Section 

91.119(c) is needed.

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

which the Boomerang is built. Also, no flight will be taken without the permission of the 

landowner or those who control the land. Because of the advance notice to the landowner, all 
affected individuals will be aware of the flights. Compared to aerial survey operations conducted 

with aircraft or rotorcraft weighing far more than 6 lbs. and carrying flammable fuel, any risk 

associated with these operations will be far less than those currently allowed with conventional 

aircraft operating at or below 500 feet AGL. Indeed, the low altitude operations of the sUAS will 

maintain separation between these sUAS operations and the operations of conventional aircraft 

that must comply with Section 91.119.

14 C.F.R. § 91.151(a): Fuel Requirements for Flight in VFR Conditions

This regulation 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 Boomerang batteries provide approximately 50 minutes of powered flight. Without an 

exemption from § 14 CFR 91.151, the sUAS’s flights would be limited to approximately 20 

minutes in length. Given the limitations on its proposed operations and the location of those 

proposed operations, a longer time frame for flight in daylight VFR conditions is reasonable.

Unlimited Aerial Systems believes that an exemption from 14 CFR § 91.151(a) is safe and 

within the scope of a prior exemption. See Exemption 10673 (allowing Lockheed Martin 

Corporation to operate without compliance with 91.151(a)). Operating the sUAS, without 30 

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

prevent given the size and speed at which the sUAS operates. The fact that it carries no pilot, 

passenger, or cargo also enhances its safety. Additionally, limiting Boomerang flights to 20 

minutes would greatly reduce their utility. In the unlikely event that the Boomerang should run 

out of fuel, it would simply land. Given its weight and construction material, the risks are less 

than contemplated by the current regulation.

Unlimited Aerial Systems believes that an equivalent level of safety can be achieved by 

maintaining 10 minutes of reserve fuel, which, allowing 40 minutes of flight time, would be 

more than adequate to return the sUAS to its planned landing zone from anywhere in its 

operating area.

The FAA has granted similar exemptions to others, including Exemptions 2689F, 5745, 10673 

and 10808.

14 C.F.R. § 91.203 (a) & (b): Carrying Civil Aircraft Certification and Registration

This regulation provides as follows:

(a) ... no person may operate a civil aircraft unless it has ... an appropriate and current 

airworthiness certificate.
(b) No person may operate a civil aircraft unless the airworthiness certificate required by

paragraph (a) of this section or a special flight authorization issued under §91.715 is displayed at 

the cabin or cockpit entrance so that it is legible to passengers or crew.

The Boomerang fully loaded weighs approximately 6 lbs. As such, there is no ability or place to 

carry certification and registration documents or to display them on the sUAS. In addition, there 

is no pilot on board the aircraft.

An equivalent level of safety will be achieved by keeping these documents at the ground control 

point where the pilot flying the sUAS will have immediate access to them. The FAA has issued 

numerous exemptions to this regulation. A representative sample of other exceptions includes 

Exemption Nos. 9565, 9665, 9789, 9789A, 9797, 9797A, 9816A, and 10700.

14 C.F.R. § 91.405(a); 407(a)(1); 409(a)(2); 417(a): Maintenance Inspections

Section 91.405(a) requires that an aircraft operator or owner “shall have that aircraft inspected 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 

chapter ...” Section 91.407 similarly makes reference to requirements in Part 43; Section 

91.409(a)(2) requires an annual inspection for the issuance of an air-worthiness certificate. 

Section 91.417(a) requires the owner or operator to keep records showing certain maintenance 

work that has been accomplished by certificated mechanics, under Part 43, or licensed pilots and 

records of approval of the aircraft for return to service.

The Boomerang is nearly maintenance free, it performs automatic pre-flight checks and the 

failure of any check will prevent take-off. Checks, which cannot be done by the system, will be 

performed by a qualified person prior to each flight and at predefined intervals as part of the 

Maintenance Schedule in the User Manual (see Exhibit 1).

Pre-flight checklist includes:

1. Visual inspection of the airframe

2. Visual inspections of rotor integrity

3. Check charge of all batteries (aerial vehicle, command station, radio repeater station)

An equivalent level of safety will be achieved because the sUAS is small in size, will carry no 

external payload, will operate only in restricted predetermined areas and is not a complex 

mechanical devise. As provided in the attached User Guide (System Maintenance section), the 

operator of Boomerang will ensure that the sUAS is in working order prior to initiating flight, 

perform required maintenance, and keep a log of any maintenance that is performed. Moreover, 

the operator is the person most familiar with the aircraft and is best suited to maintain the aircraft 

in an airworthy condition and to ensure an equivalent level of safety.

The Boomerang’s Maintenance guidelines ensure an equivalent level of safety to the 

maintenance requirements in Part 91. In addition, any component failure detectable by the 

system will be reported to the control station and will cause the UAV to perform a Fatal 
Condition Response (“FCR”) or Non-Fatal Conditioned Response (“NFCR”), depending on the 

type of failure. 
APPENDIX B

SMALL UNMANNED AERIAL SYSTEM DESCRIPTION

Unlimited Aerial Systems Corporate Overview: Unlimited Aerial Systems is a US based

company located in Natchitoches, LA. Unlimited Aerial Systems is focused on providing a micro 

unmanned aerial system that is globally recognized as the market and technology leader in this 

sector, with customers ranging from state government agencies to commercial operators. Also, 

United Aerial Systems is engaging world leading universities in the unmanned space, such as 

University of Louisiana, Monroe and University of California, Davis; Police agencies such as the 

Lafayette and New Orleans Police Department agencies; And global enterprises such as Tekever

and Fortune 500 companies in the chemical, oil/gas and security markets. Unlimited Aerial 

Systems’ systems have accumulated over 5,000 hours in global flight operations. This number 

does not include military flight hours, which inevitably would increase the numbers further.

Boomerang Overview: Unlimited Aerial Systems unmanned systems have been used to 

investigate power grid issues in Natchitoches, LA and provide imagery for Public Safety

operations. 

The Unlimited Aerial Systems Boomerang can carry payloads up to 500 g. The Boomerang flies 

with a maximum wind threshold of 15 mph for sustained winds and wind gusts up to 20 mph. 

What is unique about the Unlimited Aerial Systems Boomerang is the system automatically

compensates for wind versus relying on the operator’s sense of feel’ for what the impact of the 

wind is at the altitude, in which the system is flying. The end result is a system capable of 

gathering high quality aerial intelligence, at much higher wind thresholds. A trait that is 

imperative for many aerial inspection operations.

The Boomerang has an operational range of up to 1.8 km (1 NM) with the standard offering and 

up to 3.7 km (2 NM).

All flight operations are GPS controlled, making the system extremely easy to navigate. At any

point, if the operator is not explicitly commanding the system to move, the system automatically

holds its GPS position (i.e. GPS hold for reliable location hover). Camera positioning is also 

GPS controlled allowing for the most sophisticated camera targeting available. The flight control 

system employs not only GPS positioning, but also a variety of sensors including sonar, 

barometric pressure, temperature, wind speed and others to ensure the most stability of any

system in its class, regardless of the wind.

The Unlimited Aerial Systems Boomerang can be operated in both semi and fully autonomous 

flight modes. Creating preplanned flight paths to fly in autonomous mode is as simple as clicking 

on the map to create a preplanned flight path. In semi-autonomous mode, the operator clicks on 

the map and the Unlimited Aerial Systems Boomerang automatically flies to the point on the 

map, where the operator is pointing. Pre-mission waypoints, landing zone points and flight area 

dimensions can all be entered during preflight, ensuring the Boomerang operates only within 

specified parameters. 
The Unlimited Aerial Systems Boomerang includes many advanced safety features that makes it 

the safest choice for both urban and non-urban environments. Built-in intelligent fault handling 

allows the Boomerang to detect a system fault while in the air, and to automatically fly back to 

its take-off location and successfully land. Faults that can be detected include: loss of 

communication, pre-set wind thresholds exceeded, and low battery levels. In addition, the 

operator can create no fly zones or maximum flight ranges and altitudes, so the system cannot 

enter areas deemed unsafe or unnecessary to fly over. And before every take-off, automated 

flight checks ensure that the system is flight ready before it takes off.

The Unlimited Aerial Systems Boomerang can be operated entirely by a touch-screen, mapbased interface. This means the operator only needs to command the system where to go, and the 

system does all the flying for the operator. Maps can be saved and flight plans can be made or 

recalled with no internet connection being required.

Boomerang Operating Manual - System user manual available upon request.

Physical Characteristics

Measurements – 48” diameter 

Weight (without payload) – 2.84 kg (6 lbs.)

Fuel – Lithium polymer batteries are self-contained high duration systems with “SMART” 

intelligence on-board. This includes cycle charge times, locations, GPS antenna, chemical 

management, and real-time data feeds to ensure maximum flight duration and sub-system safety 

processes. Charging is done in the included Unlimited Aerial Systems Battery charger and can be 

charged via standard wall outlet, or via a vehicle.

Landing style/type – Autonomous vertical lift

Propulsion System

● Engines – The Boomerang is powered by 4 electric brushless DC motors.

● Batteries – Lithium polymer batteries are self-contained high duration systems with SMART 

intelligence on-board. This includes cycle charge times, locations, GPS antenna, chemical 

management, and real-time data feeds to ensure maximum flight duration and sub-system safety 

processes. Charging is done in the included Unlimited Aerial Systems Battery charger and can be 

charged via standard wall outlet, or via a vehicle.

Performance Characteristics

● Maximum Altitude – 2000 ft.

● Maximum Endurance – 35 minutes

● Maximum Range – 3.21 km or Visual Line of Sight 

● Weather Minimums - 1,000 ft Ceiling, 3 Miles V isability

● Winds Maximum – 15 mph sustained, 20 mph gusts
● Minimum ceiling: 500 ft.

● Minimum visibility: 1 SM

● Icing conditions – no icing conditions

● Precipitation – no visible moisture

Maintenance – The UAS is nearly maintenance free, it performs automatic pre-flight checks and 

the failure of any check will prevent take-off. A qualified person prior to each flight will perform 

checks, which cannot be done by the system.

Pre-flight checklist includes:

● Visual inspection of the airframe

● Visual inspections of rotor integrity

● Check charge of all batteries (aerial vehicle, command station, radio repeater station)

Reliability – The system is designed for maximum reliability and to maintain performance over 

its life. The only components experience routine wear are rotors, batteries, motors, and legs. 

Battery and motor conditions are monitored by the system with deviations reported to the 

operator.

Contact with other objects during flight may cause other components, particularly rotors, and 

motor arms, to become damaged. Damaged components are likely to be detected during the full 

visual inspection of the airframe, performed before each flight. On-board sensors will detect 

structural damage affecting flight characteristics.

The UAV system detects numerous conditions, which may make flying unsafe, such as reduced 

GPS accuracy, magnetic anomalies, low battery charge, battery cell imbalances, and temperature 

fluctuations. Automatic pre-flight checks prevent the UAV from taking off if such conditions are 

present and/or if the condition is detected during flight, the system will trigger a Fatal 

Conditioned Response.

Fault Tolerance - The key feature of the UAV fault tolerance is its mechanical simplicity. It uses 

four fixed pitched rotors, each mounted on a separate motor. No control surfaces or other 

actuators are required for the UAS to fly. Any component failure detectable by the system will 

be reported to the control station and will cause the UAV to perform a Fatal Condition Response 

(FCR) or Non-Fatal Conditioned Response (NFCR), depending on the type of failure.

Command and Control Systems

The Boomerang Ground Control station allows the operator simultaneous control over aircraft 

and payloads. The touch screen control allows for quick navigation and data entry while the 

display screen provides all essential flight data to the operator. Telemetry data is transmitted to 

the command station at least once per second.

Displayed on GCS:

● UAS Position

● Navigation Route
● UAS Tail Number

● UAS Position

● UAS Altitude

● UAS Heading

● North Seeking Arrow

● Range to Target

● Calculated target position

● Date/time

● Sensor heading and orientation relative to UAS

On-board Flight Instruments – The UAV is equipped with an Inertial Navigation System (3-axis 

gyroscope, 3-axis magnetometer, GPS receiver, and static pressure sensor) and a sonar sensor for 

precision AGL altitude measurement. 

On–board computer systems – The UAS is equipped with an on-board computer systems to 

monitor (sensors, battery, etc.), control (speeds, altitude, position, etc.), and communicate 

(control, telemetry, etc.).

On-board guidance and navigation equipment – The UAS can operate autonomously and does 

not require any input from ground based equipment, or from the pilot to hover in place.

Frequency Allocations – 915 MHz, 2.4 GHz, 5.8 GHz, 1.2 GHz, custom

Flight termination link – to prevent a “fly away” or any other potentially dangerous situation, a 

flight termination link is available to the operator at the GCS.

Takeoff and Landing – The Boomerang has vertical lift autonomous launch and recovery. A 

Landing Zone “LZ”, is designated by the operators and identified in the GCS software. For 

launch procedures, the aircraft will takeoff and hover 3 meters directly above the LZ and hold 

until further operator instruction is given. The aircraft will automatically adjust for wind during 

this period.

Navigation System – Specific maps can be downloaded to the display screen (such as air 

sectional and geographic maps), which are overlaid with GPS positional data. Waypoints can be 

created before and during flight operation, creating specific locations and sequences for the 

aircraft.

Redundant Systems – The UAS combines the input from a multitude of sensors. Even though the 

data from all sensors are required for optimal system performance, a single sensor malfunction is 

likely to result in degraded performance rather than leading to a catastrophic failure.

Emergency Procedures and System Failures

Failure Handling – The UAS has extensive failure detection and handling capabilities. All 

failures are deeded to be either fatal or non-fatal. Failures classified as fatal result in a Fatal 

Condition Response (FCR), while failures classified as non-fatal result in a Non-Fatal Condition 

Response (NFCR).
Sensor Failure – Failure of on-board flight instruments/sensors will degrade the UAS 

performance and will result in either a FCR or NFCR, depending on their severity. If the UAS 

becomes unstable due to sensor failure, it will stop all four motors and free fall to avoid a fly 

away condition.

Motor Failure – The UAS flight performance will degrade significantly if one or more motors 

fail.

Airframe Failure – If airframe is damaged in ways that impacts flight characteristics, the UAS 

will behave similar as if an on-board flight instrument failed.

Navigation System Failure – In a navigation system failure, degraded GPS will result in FCR or

NFCR‘s depending on failures.

Power Failure – A complete battery failure that results in power loss to the UAS, will result in 

degraded flight performance.

Low Battery Condition – The Operator will be alerted of a low battery condition and will land 

the aircraft as soon as able.

Low Battery Condition – The Operator will be alerted of a low battery condition and will land 

the aircraft as soon as able.

Line-of-Sight Loss – All flight operations with the UAS will be conducted within visual sight of 

the pilot. If the pilot’s view becomes obstructed and line-of-sight is lost, the pilot may instruct 

the UAS to hover in place until line-of-sight is reestablished, to return to the take-off position, or 

to land at the current position.

Security

The manufacturer’s proprietary software encrypts the system and communication links. 
APPENDIX C

SUMMARY OF UNLIMITED AERIAL SYSTEMS SECTION 333 EXEMPTION REQUEST

Unlimited Aerial Systems hereby provides pursuant to Part 11, a summary of its exemption 

application to allow commercial operation of the Boomerang small unmanned system in market 

research, precision aerial survey work, mapping and inspections. An exemption is requested 

from the following regulations:

14 C.F.R. Part 21;

14 C.F.R. 45.23(b);

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. 91.9(b)(2) & (c);

14 C.F.R. 91.103;

14 C.F.R. 91.109(a);

14 C.F.R. 91.119;

14 C.F.R. 91.151(a);

14 C.F.R. 91.203(a) & (b);

14 C.F.R. 91.405(a);

14 C.F.R. 91.407(a)(1);

14 C.F.R. 91.409(a)(2);

14 C.F.R. 91.417(a)