UNITED STATES OF AMERICA 

DEPARTMENT OF TRANSPORTATION 

FEDERAL AVIATION ADMINISTRATION 

DOCKET MANAGEMENT SYSTEM 

1200 NEW JERSEY AVE., SE 

WASHINGTON, DC 20590 

IN THE MATTER OF THE PETITION FOR EXEMPTION OF: 

Aerial Solutions PNW, LLC. 

FOR AN EXEMPTION SEEKING RELIEF FROM 

·-,--. 

THE REQUIREMENTS OF THE FAA REFORM ACT AND 

PART 11 OF THE FEDERAL AVIATION REGULATIONS FROM 

TITLE 14 OF THE CODE OF FEDERAL REGULATIONS 

-'· 

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

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

CONCERNING COMMERCIAL OPERATION OF UNMANNED AIRCRAFT SYSTEMSD 

PURSUANT TO SECTION 333 OFD THE FAA MODERNIZATION 

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

Submitted on Nov 30th, 2015 

Aerial Solutions PNW, LLC. 

Slvylane 

Pasco, Wa 99301 

Table of Contents 

GLOSSARY OF ABBREVIATIONS ........................................................................................... 3 

INTRODUCTION AND INTERESTS OF THE PETITIONER ............................................. .4 

Executive Summary .................................................................................................................. 4 

Expeditious Summary Grant Approval Request ...................................................................... 4 

Description of Type, Make and Models of sUAV /UAS Requested: ............................................ 5 

Commercial (Mission, Operation) Purpose: ....................................................................................... 5 

Regulations from which the Exemption Relief is requested: ...................................................... 6 

The name and address of the Petitioner: ............................................................................................. 6 

Background .......................................................................................................................................... 7 

Commitment to Safety ................................................................................................................................. 7 

Expertise & Experience ............................................................................................................................... 7 

Aerial Solutions PNW, LLC 5 Ivy Lane Pasco, Wa 99301 www.Aerialsolutionspnw.com 509-308-4580 

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The Exemption Request .......................................................................................................... 8 

Operator Requirements ................................................................................................................. 1 0 

Aircraft and Equivalent Level of Safety .................................................................................... 12 

Specific Uses Public Benefits ........................................................................................................ 17 

Equivalent Level of Safety ............................................................................................................. 18 

14 C.F.R. § 91.7(a): Civil aircraftairworthiness .............................................................................. 19 

14 C.F.R. §91.119: Minimum safe altitudes ....................................................................................... 19 

14 C.F.R. §91.121 Altimeter Settings ................................................................................................... 20 

14 C.F.R. § 91.151(a): Fuel Requirements for Flight in VFR Conditions ............................... 20 

14 C.F.R. §91.405 (a); 91.407 (a) (1); 91.409(a) (2); 91.417(a) & (b): Maintenance 

Inspections ..................................................................................................................................................... 21 

Federal Register Publication ............................................................................................. 22 

Privacy and National Security ........................................................................................... 22 

Summary ................................................................................................................................... 2 3 

Aerial Solutions PNW, LLC 5 Ivy Lane Pasco, Wa 99301 www.Aerialsolutionspnw.com 509-308-4580 

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patrolling, aerial inspection, photography and videography of residential and 

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

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

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

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

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

construction site inspection and monitoring, public entity support operations, Aerial 

imaging for safety, monitoring and comparing work efforts and completion 

percentages, and security of controlled environment of various sites, aerial video 

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

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

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

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

public organizations to increase awareness and improve safety for current and 

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

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

and assessment, motion picture production3, surface mining, closed set filming4, 

disaster and catastrophe events. 

Regulations from which the Exemption Relief is requested: 

14 C.F.R. § 61.113 (a) & (b) 

14 C.F.R. § 61.133(a) 

14 C.F.R. § 91.7(a) 

14 C.F. R.§ 91.119 

14 C.F.R. § 91.121 

14 C.F.R. § 91.151 (a) 

14 C.F.R. § 91.405 (a) 

14 C.F.R. § 407 (a) (1) 

14 C.F.R. § 409 (a) (2) 

14 C.F.R. § 417 (a) & (b) 

See Appendix E 

The name and address of the Petitioner: 

Aerial Solutions PNW, LLC 

Attn: Ed Bass 

5 Ivy Lane 

Pasco, Wa 99301 

3 Motion Picture and Television Flight Operations Manual is herein attached as 

Appendix G. 

4 Motion Picture and Television Flight Operations Manual for closed set filming is 

herein attached as Appendix G. 

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

immediate landing, 

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

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

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

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

execute a return to home and land, 

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

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

flight path, 

5) The aircraft, weighs less than 55lbs., fully loaded, 

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

7) The aircraft will operate for the Purposes at no more than 87 kts (while 

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

maximum of 400 feet AGL. 

See Federal Aviation Administration, Notice N-8900.227, Unmanned Aircraft 

Systems (UAS) Operational Approval, at 20-21 (July 30, 2013); As the FAA has 

determined in Exemptions 11062 thru 11067,11080 and 11110 (the "Exemptions"), 

in comparing the requirements for private pilot knowledge and the knowledge 

required for a commercial pilot, that knowledge associated with a private pilot 

license, and therefore private pilot ground school, was sufficient to allow private 

pilots to operate sUAV's under those exemptions. 

Based upon that analysis, ASPNW believes successful completion of FAA private 

pilot ground school is a suitable predicate to operating the sUAV under this 

exemption. ASPNW proposes that the Operator accumulate required sUAV flight 

training hours through the operation of sUAV's rather than flight hours in 

conventional aircraft. Those hours are more relevant to the operations proposed 

herein than hours gained in obtaining a private pilot's certificate in conventional or 

rotor aircraft. Those aircraft are orders of magnitude heavier than the sUAS and 

carry not only the pilot himself, but also passengers and fuel, none of which is 

carried in the sUAS. These conventional aircraft fly over all sorts of airspace without 

the permission or knowledge of the landowner. 

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

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

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

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

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

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

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

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

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

offs and landings at controlled and uncontrolled airports. 

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The Petitioner proposes that the exemption requested herein apply to civil aircraft 

that have the characteristics and that operate with the limitations listed herein. 

These limitations provide for at least an equivalent or even higher level of safety to 

operations under the current regulatory structure because the proposed operations 

represent a safety enhancement to the operations conducted with conventional 

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

drawn from Exemptions 11136, 11138, 11172, 11174 and 11177, 11062, 11109, 

11112, and 11213 and as recent as 11857. 

These limitations and conditions to which ASPNW (referred to as "Operator") agrees 

to be bound when conducting commercial operations under an FAA issued 

exemption include: 

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

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

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

this grant. 

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

mph (5 mph during inspections). 

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

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

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

must be in feet AGL. 

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

Aircraft Operator at all times. This requires the Aircraft Operator 

to be able to use human vision unaided by any device other than 

corrective lenses, as specified on the Operator's FAA-issued 

airman medical certificate. 

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

conditions and limitations required by the FAA. The Manuals 

must be maintained and made available to the Administrator 

upon request. If a discrepancy exists between the conditions and 

limitations in the exemption and the procedures outlined in the 

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

limitations in the exemption take precedence and must be 

followed. Otherwise, the Aircraft Operator must follow the 

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

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

Holder's responsibility to track such revisions and present 

updated and revised documents to the Administrator upon 

request. The Exemption Holder must also present updated and 

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

moving device or vehicle. 

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

14 CFR 1.1. 

23) All operations must be conducted under visual meteorological 

conditions (VMC). The UA may not be operated less than 500 

feet below or less than 2,000 feet horizontally from a cloud or 

when visibility is less than 3 statute miles from the Operator. 

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

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

current FAA-published aeronautical chart unless a letter of 

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

operation is conducted in accordance with a NOTAM, if as 

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

airport management must be made available to the 

Administrator upon request. 

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

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

These populated areas include but are not limited to the yellow 

areas depicted on World Aeronautical Charts (WAC), Sectional 

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

However, aeronautical charts may not reflect pertinent local 

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

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

(1). 

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

nonparticipating persons, vessels, vehicles, and structures 

unless: 

a. Barriers or structures are present that sufficiently protect 

nonparticipating persons from debris in the event of an 

accident. The Aircraft Operator must ensure that 

nonparticipating persons remain under such protection. If a 

situation arises where nonparticipating persons leave such 

protection and are within 30 feet of the UA, flight 

operations must cease immediately and/or; 

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

where the land owner I controller has granted permission 

and/ or the Aircraft Operator has made a safety assessment 

of the risk of operating closer to those objects and; 

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

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

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

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

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

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

the permission of the property owner, facility owner, andjor local officials. Because 

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

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

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

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

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

below 500 AGL in the aerial photography industry. In addition, the low-altitude 

operations of the sUAS will ensure separation between these small-UAS operations 

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

The FAA has granted exemptions to conduct similar operations in Exemptions 

11062 through 11067, 11080 and 11110. 

14 C.F.R. §91.121 Altimeter Settings 

This regulation requires each person operating an aircraft to maintain cruising 

altitude by reference to an altimeter that is set " ... to the elevation of the departure 

airport or an appropriate altimeter setting available before departure." As the 

ASPNW sUAV, in manual or emergency mode, will not have a barometric altimeter 

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

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

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

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

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

Section 91.151(a) prohibits an individual from beginning "a flight in an airplane 

under VFR conditions unless (considering wind and forecast weather conditions) 

there is enough fuel to fly to the first point of intended landing, and, assuming 

normal cruising speed- (1) During the day, to fly after that for at least 30 minutes; 

or (2) At night, to fly after that for at least 45 minutes." 

The battery powering the sUAS provides approximately 40 minutes of powered 

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

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

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

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

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

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

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

tightly controlled area where only people and property owners or official 

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

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

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

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

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

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

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

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

Exemptions 11062, through11067, 11080 and 11110. 

14 C.F.R. §91.405 (a); 91.407 (a) (1); 91.409(a) (2}; 91.417(a) & (b): Maintenance 

Inspections 

These regulations require that an aircraft Operator or owner "shall have that 

aircraft inspected as prescribed in subpart E of this part and shall between required 

inspections, except as provided in paragraph (c) of this section, have discrepancies 

repaired as prescribed in part 43 of this chapter ... ," and others shall inspect or 

maintain the aircraft in compliance with Part 43. 

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

certificate, these sections will not apply to the Petitioner. Maintenance will be 

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

operating handbook as referenced in the Manuals attached as confidential Exhibits 

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

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

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

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

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

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

maintenance performed. Moreover, the Operator and manufacturer are most 

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

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

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

********* 

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

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

Satisfaction of the criteria provided in Section 333 of the Reform Act of 2012 -size, 

weight, speed, operating capabilities, proximity to airports and populated areas and 

operation within visual line of sight and national security - provide more than 

adequate justification for the grant of the requested exemptions allowing 

commercial operation of Petitioner's UAS for the Purposes outlined herein and are 

consistent with exemptions already granted, including Exemptions number 11171 

through 11174, 11176, 11177, 11062, 11109, 11112, and 11213 and as recent as 

11857. 

Sincerely, 

Ed Bass 

Aerial Solutions PNW, LLC 

5 Ivy Lane 

Pasco, Wa 99301 

509-308-4580 

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