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Specialized Helicopters LLC Section 333 Petition 

UNITED STATES OF AMERICA

DEPARTMENT OF TRANSPORTATION

FEDERAL AVIATION ADMINISTRATION

WASHINGTON, DC

Regulatory Docket No. _______________

IN THE MATTER OF THE PETITION FOR EXEMPTION OF:

SPECIALIZED HELICOPTERS LLC FOR AN EXEMPTION SEEKING RELIEF FROM 

THE REQUIREMENTS OF TITLE 14 OF THE CODE OF FEDERAL REGULATIONS 

(14 CFR) PART 21 SECTIONS; § 61.113(a) and (b), 91.7(a), 91.121, 91.151(b), 

91.203(a) and (b), 91.405(a), 91.407(a)(1), 91.409(a)(2), and 91.417(a) and (b).

CONCERNING OPERATION OF AN UNMANNED AIRCRAFT SYSTEM

PURSUANT TO SECTION 333 OF THE

FAA MODERNIZATION AND REFORM ACT OF 2012

Submitted on December 22, 2015 

Specialized Helicopters LLC

Chris Gularte

Specialized Helicopters, LLC

150 Aviation Way

Watsonville, CA 95076

(831) 763-224

chris@spheli.com
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Specialized Helicopters LLC Section 333 Petition 

TABLE OF CONTENTS

Glossary of abbreviations 3

Summary 4

Introduction and interests of the petitioner 4

Background 5

Proven operational history of DJI T600 in 

the NAS

6

Basis for petition 7

Name and address of petitioner 7

Specific sections of C.F.R. from which 

Specialized Helicopters seeks exemption

8

Reasons why granting Specialized 

Helicopters request would be in the public 

interest

10

Flight Operations 11

Flight operations of Specialized 

Helicopters UAV is limited to line of sight 

of the PIC with a Visual Observer

12

Conclusion 12
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Specialized Helicopters LLC Section 333 Petition 

GLOSSARY OF ABBREVIATIONS

AGL Above Ground Level 

ATC Air Traffic Control 

COA Certificate of Authorization 

FAA Federal Aviation Administration 

FAR Federal Aviation Regulation 

NAS National Airspace System 

PIC Pilot In Command

Section 333 FAA Modernization and Reform Act of 2012, Section 333 

SOP Standard Operating Procedures

UAS Unmanned Aircraft System 

UAV Unmanned Aerial Vehicle

UH Unmanned Helicopter

VFR Visual Flight Rules 

VMC Visual Meteorological Conditions 

VO Visual Observer

VTOL Vertical Take Off and Landing
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Specialized Helicopters LLC Section 333 Petition 

SUMMARY

Specialized Helicopters LLC seeks exemption from the requirements of 14 

C.F.R. §§ 61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 

91.409(a)(1) & (2), and 91.417(a) & (b), to operate an Unmanned Aircraft System 

pursuant to Section 333 of the FAA Modernization and Reform Act of 2012. In 

consideration of the speed, weight, size, and limited operating area associated with the 

unmanned aircraft and its operation, Specialized Helicopters LLC's operation of the DJI 

T600 "Inspire 1" and similar Unmanned Helicopters meets the conditions of FMRA 

Section 333 and therefore, will not require an airworthiness certificate in accordance 

with 14 C.F.R. Part 21, Subpart H. This exemption will permit Specialized Helicopters

LLC to operate an Unmanned Aircraft System for the commercial purpose of conducting 

aerial data collection and research within the National Airspace System.

INTRODUCTION AND INTERESTS OF THE PETITIONER

Specialized Helicopters LLC (Hereinafter referred to as “Specialized Helicopters”) 

is owned and managed by professional, highly experienced commercial helicopter pilots 

who are Part 141, 135, and have FAA Authorized Movie and film production Manuals 

and pilots. Specialized Helicopters pilots have an extensive history of power line and 

utility patrol, wildlife survey, electronic news gathering, search & rescue, and movie 

production work across the Pacific Northwest. Specialized Helicopters has recently 

acquired and been flight testing a DJI Inspire 1 Unmanned Helicopter which it plans to 

use for commercial operations including aerial filming, power line and public utility

inspections, aerial surveys, electronic news gathering, and aid in search & rescue 

operations. Specialized Helicopters lead pilot on the project has over 3000 hours 

helicopter flight time, as well as over 20 years experience and thousands of hours of 

UAV flight time as a hobbyist. Specialized Helicopters plans to work side by side with its 

sister company to diversify their fleet of aircraft with an unmanned helicopter in order to 

meet the needs of a continually evolving market while striving for an ever increasing 

level of safety to their employees and customers.
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Specialized Helicopters LLC Section 333 Petition 

BACKGROUND

Specialized Helicopters seeks an exemption to operate a UAV that operates

under 100 MPH and operates at less than 55 pounds max gross weight.

OPERATIONAL SAFTY OF UAV’s USED UNDER THIS EXEMPTION

Any UAV used will have a proven record of safely within the NAS both as hobby 

and commercially. The UH will have onboard stability systems, location finding, and 

GPS systems for navigation. All of these allow the UH to hover with pinpoint precision 

and also take off and land autonomously. There is a failsafe built into the system 

allowing the UH to return to a predetermined point (known as "home") at a 

predetermined altitude in the event of a control link failure between the aircraft and PIC.

It will also automatically return home when the battery has reached a predetermined 

level, which ensures the aircraft will land before the battery level becomes critical.

Specialized Helicopters will use only industry standard UAV’s that have proven records

of safety.

BASIS FOR PETITION

Petitioner, Specialized Helicopters, pursuant to the provisions of the Federal 

Aviation Regulations (14 C.F.R. § 11.61) and the FAA Modernization and Reform Act of 

2012, Section 333, Special Rules for Certain Unmanned Aircraft Systems, hereby 

petitions the Administrator for an exemption from the requirements of 14 C.F.R. §§ 

61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (2), 

and 91.417(a) & (b), to operate an Unmanned Aircraft System pursuant to Section 333 

of the FAA Modernization and Reform Act of 2012. In consideration of the speed, 

weight, size, and limited operating area associated with the unmanned aircraft and its 

operation, Specialized Helicopters operation of the DJI Inspire 1 UAS meets the 

conditions of FMRA Section 333 and therefore, will not require an airworthiness 

certificate in accordance with 14 C.F.R. Part 21, Subpart H. In accordance with 14 

C.F.R. § 11.81, Specialized Helicopters provides the following information in support of 

its petition for exemption: 
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Specialized Helicopters LLC Section 333 Petition 

NAME AND ADDRESS OF THE PETITIONER

Specialized Helicopters LLC

150 Aviation Way

Watsonville, CA 95076

The point of contact for Specialized Helicopters petition and specific contact information 

is as follows: 

Chris Gularte

Specialized Helicopters LLC

150 Aviation Way

Watsonville, CA 95076

(831) 763-2244 | chris@spheli.com

THE SPECIFIC SECTIONS OF 14 C.F.R. FROM WHICH SPECIALIZED 

HELICOPTERS SEEKS EXEMPTION

14 C.F.R. § 61.113(a) & (b): Private pilot privileges and limitations: Pilot in 

command.

Sections 61.113(a) & (b) limit private pilots to non-commercial operations. 

Because the UAV will not carry a pilot or passengers, the proposed operations can 

achieve the equivalent level of safety of current operations by requiring the PIC 

operating the aircraft to have a private pilot’s license rather than a commercial pilot’s 

license to operate the small UAV. Unlike a conventional aircraft that carries the pilot and 

passengers, Specialized Helicopters UAV is remotely controlled with no living thing on 

board. The area of operation shall be controlled and restricted, and all flights are 

planned and coordinated in advance as set forth in the Specialized Helicopters SOP. 

The level of safety provided by the requirements included in the SOP exceeds that 

provided by a single individual holding a commercial pilot’s certificate operating a 

conventional aircraft. The risks associated with the operation of the UAV is so 

diminished from the level of risk associated with commercial operations contemplated 

by Part 61 when drafted, that allowing operations of this UAV as requested with a 
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Specialized Helicopters LLC Section 333 Petition 

private pilot as the PIC exceeds the present level of safety achieved by 14 C.F.R. 

§61.113(a) & (b). 

14 C.F.R. §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, 

should Specialized Helicopters's exemption be granted, no FAA regulatory standard will 

exist for determining airworthiness. Given the small size and simplicity of the aircraft 

and the requirements contained in the SOP and Maintenance Manual for maintenance 

and use of preflight check lists prior to each flight, an equivalent level of safety will be 

provided. 
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Specialized Helicopters LLC Section 333 Petition 

14 C.F.R. §91.121 Altimeter settings.

The 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 UAS does 

not have a barometric altimeter, but instead a GPS height AGL read out and a sonic 

ground proximity sensor, an exemption may be needed. An equivalent level of safety 

will be achieved by way of the UAS recording its position as zero feet AGL upon 

powering on, and during flight the height AGL is displayed in real time to the PIC's 

display. The UH is also equipped with a sonic ground proximity sensor which detects 

height AGL and automatically corrects the flight altitude to help prevent inadvertent flight 

into terrain.

14 C.F.R. § 91.151(b): Fuel requirements for flight in VFR conditions.

Section 91.151(b) prohibits an individual from beginning “a flight in a rotorcraft

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, to fly after that for at least 20 minutes.” The batteries powering the Inspire 1 

provide approximately 18 minutes of powered flight, therefore meeting the 20 minute 

reserve requirement is not possible. Specialized Helicopters believes that an equivalent 

level of safety can be achieved by limiting flights to 25% of remaining battery power.

The UAS is also equipped with an audio warning which is set to notify the pilot at a 

predetermined battery level remaining. If the battery drops below this level, the UH will 

automatically return home and land, preventing the UH from being in the air when the 

battery reaches critically low levels. Specialized Helicopters 25% restriction and the 

UAS's automated systems would be more than adequate to return the UH to its planned 

landing zone from anywhere in their limited operating area. 

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

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

certificate, these sections will not apply to Specialized Helicopters. Maintenance will be 

accomplished by Specialized Helicopters pursuant to the SOP, User Manual, and 
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Specialized Helicopters LLC Section 333 Petition 

Maintenance Manual. An equivalent level of safety will be achieved because the UAS 

will still receive both scheduled and preventative maintenance. As provided in the SOP, 

Specialized Helicopters will ensure that the Inspire 1 is in working order prior to initiating 

flight, perform required maintenance, and keep a log of any maintenance performed. 

Moreover, the operator 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. 

REASONS WHY GRANTING SPECIALIZED HELICOPTERS REQUEST WOULD BE 

IN THE PUBLIC INTEREST

Granting the present petition will further the public interest by allowing 

Specialized Helicopters to safely, efficiently, and economically assist in performing

movie and film production, aerial inspection services of power transmission towers, lines 

and other public utilities, along with conducting aerial surveys, electronic news 

gathering, wildland fire perimeter patrols, and aiding is search & rescue operations. 

Use of the Specialized Helicopters UH for aerial filming will increase air safety by 

reducing human exposure to low level helicopter flights and reduce the need to fly 

manned helicopters close to transmission towers persons and property. 

Conducting aerial surveys with the UH will reduce the need to fly biologists low 

and slow over sometimes heavily forested or oceanic areas in order to take accurate 

counts or surveys. This will also greatly reduce harassment to wildlife due to the UH

having a much smaller, almost imperceptible, noise signature. 

Smaller news stations often don't have the budget to pay full sized helicopters to 

perform aerial work. Utilizing Specialized Helicopters UAS will allow local stations to 

better gather information and provide the public with more timely and accurate news.

Specialized Helicopters works in conjunction with many government agencies 

including local, state, and federal who are very interested in the benefits of a UAS to 

provide better understandings of surrounds projects and conditions. This can greatly 

benefit fire and law enforcement agencies by allowing them to quickly get aerial views of 

the surroundings, allowing them to make faster, more informed decisions. 
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Specialized Helicopters LLC Section 333 Petition 

Specialized Helicopters also works with several public agencies conducting 

search and rescue operations. These operations can be enhanced with a UAS by 

allowing an "eye in the sky" to quickly and efficiently aid in searches.

FLIGHT OPERATIONS

Operations will only be conducted in the continental United States.

Proposed areas of aerial operations include areas that are: 

1. Not over congested areas or near large gatherings of people.

2. Not within 5 miles of any airport without airport manager's permission.

3. Not within 100 yards of persons or property non-essential to the mission.

5. UH will remain within visual line of sight of the PIC and VO.

6. No flight above 400 feet AGL.

14 C.F.R. §1.1 defines rotorcraft as "a heavier-than-air aircraft that depends 

principally on its support in flight on the lift generated by one or more rotors." It also 

defines helicopter as "a rotorcraft that, for its horizontal motion, depends principally on 

its engine driven rotors." The Inspire 1 meets these criteria and therefore should not 

require a waiver to operate under §91.119 since it can fulfill the requirements of 

§91.119(d). However, Specialized Helicopters will take an added level of safety and not 

operate over any congested are.

Specialized Helicopters will operate its UAV by regulations such as the ICAO 

(International Civil Aviation Organization) and the FAA’s own national airspace 

regulations. In order to increase flight safety and prevent accidental flights in restricted 

areas, thorough preflight action will be taken to ensure no airspace violations will occur. 

Measures will also be taken to ensure operations are always conducted in class G 

airspace in day VMC with 3 miles visibility. Specialized Helicopters customers often 

require flights to occur with as little as 2-3 hours notice, therefore a requirement to 

obtain a NOTAM prior to each flight will greatly hinder the ability of Specialized 

Helicopters to fulfill its customers' needs. These are jobs which are normally performed 

by Specialized Helicopters sister company with a manned helicopter, and being able to 

do these missions with an unmanned helicopter will not only provide an equivalent level 
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Specialized Helicopters LLC Section 333 Petition 

of safety, but introduce an added level of safety and service to Specialized Helicopters

customers.

FLIGHT OPERATIONS OF SPECIALIZED HELICOPTERS UAV IS LIMITED TO LINE 

OF SIGHT OF THE PIC WITH A VISUAL OBSERVER

Specialized Helicopters will only utilize PIC’s with a valid Private Pilot rating 

certificate issued by the FAA for operation of the UAS and a valid Class II Medical 

Certificate along with extensive company training. Additionally, all pilots will be assisted 

by a Visual Observer. Both the VO and PIC will remain within line of sight of the UH 

during the operation.

CONCLUSION

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 

applicant’s UAS pursuant to the manual's appended hereto. 

_____________________________ 

Submitted on April 13, 2015 

Chris Gularte

Specialized Helicopters LLC

150 Aviation Way

Watsonville, CA 95076

(831) 763-2244 | chris@spheli.com