6723 Odyssey Drive NW / Huntsville, AL / 256.270.4024 leidos.com

October 25, 2015

U.S. Department of Transportation

Docket Management System

1200 New Jersey Avenue, SE

Washington, DC 20590

Re: Exemption request under Section 333 of the FAA Reform Act and Part 11 of the Federal 

Aviation Requirements

Dear Sir or Madam:

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 and 14 C.F.R Part 

11, Leidos seeks an exemption from the Federal Aviation Regulations detailed below for the 

SteadiDrone Vader. The proposed UAS is a multi-rotor aircraft with electric propulsion. The 

maximum weight will not exceed 55 lbs and the maximum speed will not exceed 87 knots. The

SteadiDrone Vader is a commercial platform with a proven track record. SteadiDrone 

quadcopters include advanced avionics designed to protect the quadcopter and property in the 

event of lost communications. The SteadiDrone Vader is controlled by remote in the 2.4 GHz 

band and complies with FCC requirements. Leidos will operate the sUAS within visual line of 

sight of the pilot in command (PIC) at all times.

The requested exemption would allow Leidos to pursue research and development for the 

Government and commercial interests in aerial data collection using small unmanned aircraft 

systems. The system proposed will be used to conduct data gathering for aerial imagery and 

sensor payloads, mapping, and surveying. The FAA has previously granted similar exemption 

requests for aerial data collection in exemption numbers 11062, 11109, 11112, and 11213.

The UAV will be operated under controlled conditions at low altitude (<400’ AGL). It will have 

automated control features aiding flight operations. The UAV is designed to be operated by 

one person, but Leidos will require a certified pilot in command and a visual observer. The 

pilot is responsible for flying the UAV, monitoring its status and flight dynamics while 

maintaining visual-line-of-sight (VLOS), and keeping the flight within the specified factory limits 

(in terms of wind, flight range, battery life, etc.) to ensure safe operation. The visual 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 launching and avoidance of any 

aircraft or identified hazards. The pilot in command and visual observer will be able to 

communicate verbally at all times. The pilot in command will hold either an airline transport, 

commercial, private, recreational, or sport pilot certificate. The PIC will also hold a current FAA 

airman medical certificate or a valid U.S. driver’s license issued by a state, the District of 

Columbia, Puerto Rico, a territory, a possession, or the Federal government.
6723 Odyssey Drive NW / Huntsville, AL / 256.270.4024 leidos.com

The name and address of the applicant are:

Leidos

Attn: Jonathan Wetherbee

6723 Odyssey Drive, NW

Huntsville, AL 35806

The primary contact information for this application is:

jonathan.d.wetherbee@leidos.com or 256.270.4024.

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

14 C.F.R. 61.23(a)

14 C.F.R. 61.101(e)(4)

14 C.F.R. 61.113(a): Private pilot privileges and limitations.

14 C.F.R. 61.315(a)

14 C.F.R. 91.7(a) : Civil Aircraft Airworthiness

14 C.F.R. 91.119(c) : Minimum safe altitudes

14 C.F.R. 91.121 : Altimeter settings

14 C.F.R. 91.151(a)(1) : Fuel requirements for flight in VFR conditions

14 C.F.R. 91.405(a) : Maintenance Inspections

14 C.F.R. 91.407(a)(1) : Maintenance Inspections

14 C.F.R. 91.409(a)(1) & (2) : Maintenance Inspections

14 C.F.R. 91.417(a) & (b) : Maintenance Inspections

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.

Sincerely,

Jonathan Wetherbee
6723 Odyssey Drive NW / Huntsville, AL / 256.270.4024 leidos.com

Appendix A: Exemptions from 14 C.F.R. Requested:

1) 14 CFR 61.23(a) Medical Certification

This regulation specifies the level of medical certificate required by a pilot in command.

Leidos requests that a valid U.S. driver’s license issued by a state, the District of 

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

sufficient to demonstrate medical certification to fly the sUAS.

The FAA has issued numerous grants of exemptions specifying that “the pilot will hold 

either an airline transport, commercial, private, recreational, or sport pilot certificate.The 

PIC will also hold a current FAA airman medical certificate or a valid U.S. driver’s 

license issued by a state, the District of Columbia, Puerto Rico, a territory, a 

possession, or the Federal government.”

These licensing and certifications have already been determined by the FAA to maintain 

safe commercial operations of sUAS.

2) 14 CFR 61.101(e)(4) & (5) Private pilot may not fly for compensation or hire

This regulation restricts a person possessing a private pilot license from acting as pilot 

in command for compensation or hire or for furtherance of a business.

Leidos requests an exemption permitting a private pilot to fly an sUAS commercially.

A private pilot license demonstrates air safety knowledge and capabilities exceeding 

that necessary to operate a sUAS safely. Given that the sUAS is not manned, 

permitting an individual with a private pilot license to act as pilot in command for 

compensation or hire does not significantly increase the risk of damage to life or 

property.

3) 14 CFR Section 61.113 (a): Private pilot privileges and limitations: Pilot in Command

These regulations limit private pilots to non-commercial operations only. 

Whereas the FAA has previously acknowledged a private pilot license provides 

sufficient knowledge to safely operate sUAS commercially, Leidos requests an 

exemption to permit individuals holding a private pilot license to operate as the PIC.

4) 14 CFR Section 61.315(a) Limitations on aircraft for Sport Pilot License

This regulation specifies the limitations on the aircraft that an individual possessing a 

sport pilot license can act as pilot in command of.

The training requirements for a sport pilot license exceeds those necessary to safely fly 

a small quadcopter. Given that the proposed sUAS is significantly smaller than the 

allowable sport planes and unmanned, Leidos is seeking relief from this regulation.
6723 Odyssey Drive NW / Huntsville, AL / 256.270.4024 leidos.com

5) 14 CFR 91.7 (a): Civil Aircraft Airworthiness

This regulation requires a civil aircraft to be in an airworthy condition for a person to 

operate.

Leidos is seeking an exemption from 14 CFR 91.7(a) because no FAA regulatory 

standard exists for determining airworthiness for such vehicles. Leidos will follow 

manufacturer recommended maintenance and safety check lists prior to each flight. 

6) 14 CFR 91.119(c): Minimum safe altitudes

This regulation limits operations below 500 ft AGL over non-congested areas.

Leidos is seeking an exemption on the grounds that the proposed aircraft are designed 

to fly at low altitudes and travel short distances. Leidos will restrict operations to flights 

only over private land with permission of the land owner. The visual observer will watch 

for potential hazards and aid the pilot in command in maintaining a safe flight avoiding 

any collisions.

7) 14 CFR 91.121: Altimeter Settings

This regulation requires a pilot to maintain cruising altitude by referencing an altimeter.

Leidos is seeking an exemption from this regulation on the grounds that the sUAS 

avionics uses GPS to maintain altitude. Leidos will ensure a sufficiently accurate GPS 

fix is acquired prior to takeoff.

8) 14 CFR 91.151(a)(1): Fuel Requirements for Flight in VFR Conditions

This regulation specifies time limits on remaining fuel usage when operating in VFR 

conditions. 

Leidos is seeking an exemption from 14 CFR 91.151(a)(1) on the grounds that the 

proposed sUAS is relatively not limited in its potential landing sites. Additionally, the 

battery limits are typically around 20 to 60 minutes, which would enable very short 

operational times if this regulation was required.

Leidos will maintain an equivalent level of safety by flying over private land away from 

the public. The sUAS will not carry hazardous or explosive cargo. The pilot will land 

the sUAS when the battery is within manufacturer recommendations on safe operations.

9) 14 CFR 91.405(a), 91.407(a)(1), 91.409(a)(1) & (2), 91.417(a) & (b): Maintenance 

Inspections

This regulation specifies the inspections necessary for aircraft.

Leidos is seeking an exemption from these regulations on the grounds that they are 

intended for aircraft with airworthiness certificates. 
6723 Odyssey Drive NW / Huntsville, AL / 256.270.4024 leidos.com

Leidos will ensure an equivalent level of safety by operating the proposed sUAS by 

performing routine and scheduled inspections as recommended by the manufacturer. 

Leidos will maintain a log of all maintenance and repairs. Additionally, all flights will 

perform a pre-flight and post-flight checklist to ensure the safety of the equipment.