HOGAN LOVELLS US LLP 

BEFORE THE 

FEDERAL AVIATION ADMINISTRATION 

lnspecTools, LLC, 

Petitioner. Docket No. FAA-2015---

PETITION OF INSPECTOOLS, LLC 

FOR AN EXEMPTION FROM CERTAIN FEDERAL AVIATION REGULATIONS 

TO PERMIT UNMANNED AIRCRAFT SYSTEMS (UAS) OPERATIONS 

DATE: June 3, 2015 

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E. Tazewell Ellett 

Patrick R. Rizzi 

Hogan Lovells US LLP 

555 131

h Street, N.W. 

Washington, DC 20004 

Phone: 202-637-8644 I -5659 

Fax: 202-637-5910 

tazewell.ellett@hoganlovells.com 

patrick. rizzi@hoganlovells. com 

COUNSELFORINSPECTOOLS,LLC 
HOGAN LOVELLS US LLP 

TABLE OF CONTENTS 

Page 

1. BACKGROUND INFORMATION: THE PETITIONER ................................................................... -1-

2. PROPOSED UAS OPERATIONS: THE EXEMPTION REQUEST ............................................... -1-

3. PROPOSED CONDITIONS AND LIMITATIONS ............................................................................ - 2-

3.1 Conditions and limitations regarding the proposed UAS ............................................ - 2-

3.2 Conditions and limitations regarding the proposed UAS operations ......................... - 4-

3.3 Conditions and limitations regarding the Pilot in Command and other 

crewmember qualifications and training ....................................................................... - 9-

3.4 Conditions and limitations regarding lnspecTools manuals related to 

UAS operations ................................................................................................................. -11-

4. REQUEST FOR DETERMINATION UNDER SECTION 333 OF FMRA ........................................ -13-

5. INFORMATION REQUIRED BY 14 C.F.R. § 11.81 TO SUPPORT A PETITION 

FOR EXEMPTION ........................................................................................................................... - 14-

5.1 Contact information ......................................................................................................... - 14-

5.2 The specific section or sections of the FAR from which lnspecTools 

seeks an exemption ......................................................................................................... - 14-

5.3 The extent of relief sought and the reason relief is sought ......................................... - 15 -

5.4 Reasons why granting the request would be in the public interest. ........................... - 29-

5.5 Reasons why granting the exemption would not adversely affect 

safety, or how the exemption would provide a level of safety at least 

equal to that provided by the rule from which exemption is sought .......................... - 32-

5.6 Summary that can be published in Federal Register, including the rule 

from which exemption is sought, and a brief description of the nature 

of the exemption sought. ................................................................................................. - 34 -

5.7 Additional information that supports request ............................................................... - 34-

5.8 Request to exercise the privileges of the exemption outside the U.S ........................ - 34 -

5.9 Attachments ...................................................................................................................... - 34 -

6. CONCLUSION ................................................................................................................................. - 35-

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1. BACKGROUND INFORMATION: THE PETITIONER 

lnspecTools, LLC ("lnspecTools"), headquartered in Santa Cruz, California, designs and 

deploys systems, including aerial platforms, to acquire and provide useful data to meet the various 

needs of its customers. Such assignments include inspections of wind turbines, the corresponding 

blades, and solar panels, asset risk mitigation, and/or wildlife/wilderness conservation. 

2. PROPOSED UAS OPERATIONS: THE EXEMPTION REQUEST 

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 ("FMRA") and 14 

C.F.R. ("FAR") §§ 11.61(b), 11.63(a), and 11.81, lnspecTools requests that the FAA grant 

lnspecTools an exemption from certain sections of the FAR (detailed below in Sections 5.2 and 5.3) 

so that lnspecTools may commercially operate one or more small UAS for aerial inspections and 

assessments of the condition of utility-scale wind and solar farms and power distribution facilities on 

behalf of the owners and operators of such farms and facilities, as well as wilderness/wildlife 

conditions. These proposed operations involve aerial data collection, consistent with previously 

granted summary grant exemptions. As explained below, lnspecTools' proposed UAS operations, 

as conditioned and limited herein, will not adversely affect safety, but rather will provide an 

equivalent or greater level of safety than that provided by the current rules, large manned aircraft 

operations, and other current inspection methods. See FAR§ 11.81. 

lnspecTools respectfully requests that the FAA grant the requested exemption. As detailed 

below, lnspecTools agrees to the conditions and limitations imposed in recent summary grant 

exemptions for its exemption. 

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3. PROPOSED CONDITIONS AND LIMITATIONS 

The small UAS operations proposed in this Petition will be subject to the following conditions 

and limitations. Each of these conditions and limitations is consistent with conditions and limitations 

in previously granted small UAS Section 333 exemptions, including recent summary grant 

exemptions, and with FAA guidance. See,~. Exemption No. 11277 (April1, 2015; Docket FAA2014-0873) ("AAIR Exemption"\ Exemption No. 11525 (May 11, 2015; Docket FAA-2015-0338) 

("Pro Drones Canada Exemption"). To facilitate the FAA's review of this Petition, lnspecTools 

provides a chart at the end of this Section 3 cross-referencing the conditions and limitations from the 

AAIR Exemption and the Pro Drones Canada Exemption with the corresponding conditions and 

limitations outlined below. Collectively, these conditions and limitations ensure that the proposed 

small UAS operations will not adversely affect safety and will provide at least an equivalent level of 

safety to that provided by the current rules, large manned aircraft operations, and other current 

inspection methods. 

3.1 Conditions and limitations regarding the proposed UAS 

lnspecTools intends to operate the small ITX8 UAS and 3DR Solo UAS under the requested 

exemption. 

The ITX8 is a battery-powered, multi-rotor, conventional, proven design built from proven 

commercial components. It has a nylon framework with carbon fiber struts and reinforcements with 

carbon fiber blades. The flying unmanned aircraft part of the UAS ("the UA") will carry a combination 

of electro-optical and infra-red sensors, GPS receivers, and ultrasonic and laser distance measuring 

devices. The 3DR Solo UAS is a quadcopter powered by four brushless motors and four propellers. 

The corresponding UA typically carries a fixed camera. 

1 AAIR stands for Advanced Aerial Inspection Resources, LLC. 

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Each UAS operated under the exemption will be subject to the following conditions and 

limitations: 

3.1.1 Operations under the exemption will be limited to the ITX8 UAS and 

3DR Solo UAS. The UA will have a gross weight of not more than 55 

pounds, including energy sources, equipment, and payload. [AAIR 

Exemption Limitation No. 1; Pro Drones Canada Exemption Limitation 

No.1.] 

3.1.2 The ITX8 UA has maximum dimensions of approximately 31 inches (I) 

x 31 inches (w) x 16-17 inches (h). The 3DR Solo UA is approximately 

10 inches in height with a motor-to-motor dimension of about 18 inches. 

3.1.3 The UA will not be operated at airspeeds greater than the maximum UA 

operating speed recommended by the UA manufacturer, and in no 

event will it be operated at a speed exceeding 87 knots (1 00 miles per 

hour). [AAIR Exemption Limitation No. 3; Pro Drones Canada 

Exemption Limitation No. 3.] 

3.1.4 The ITX8 UA will have a maximum total flight time of approximately 45 

minutes. The 3DR Solo UA will have a maximum total flight time of 

about 25 minutes. 

3.1.5 The UA will be identified by its serial number and registered with the 

FAA in accordance with FAR Part 47. [AAIR Exemption Limitation No. 

22; Pro Drones Canada Exemption Limitation No. 22.] 

3.1.6 The UA will have identification markings in accordance with FAR Part 

45, with the markings being as large as practicable. [AAIR Exemption 

Limitation No. 22; Pro Drones Canada Exemption Limitation No. 22.] 

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3.2 Conditions and limitations regarding the proposed UAS operations 

All UAS operations under the exemption will be subject to the following conditions and 

limitations: 

3.2.1 All UAS operations will be covered by an Air Traffic Organization 

("ATO")-issued Certificate of Waiver or Authorization ("GOA"). All UAS 

operations will be conducted in accordance with the airspace 

requirements in the A TO-issued GOA, including class of airspace, 

altitude level, and any potential transponder requirements. [AAIR 

Exemption Limitation No. 21; Pro Drones Canada Exemption Limitation 

No. 21.] Should lnspecTools want to conduct operations that cannot be 

conducted under the terms of the blanket GOA accompanying this 

exemption, lnspecTools will apply for a new or amended GOA. [AAIR 

Exemption Limitation No. 21; Pro Drones Canada Exemption Limitation 

No. 21.] 

3.2.2 Operations for the purpose of closed-set motion picture and television 

filming are not permitted under this exemption. [AAIR Exemption 

Limitation No. 2; Pro Drones Canada Exemption Limitation No. 2.] 

3.2.3 The UA will not operate within 5 nautical miles of an airport's reference 

point ("ARP") as denoted in the current FAA Airport/Facility Directory, 

or for airports not denoted with an ARP, the center of the airport symbol 

as denoted on the current FAA-published aeronautical chart, unless a 

letter agreement with that airport's management is obtained or such an 

operation is otherwise permitted by a GOA issued to lnspecTools. 

lnspecTools will make the letter agreement available to the FAA or any 

law enforcement official upon request. [AAIR Exemption Limitation No. 

16; Pro Drones Canada Exemption Limitation No. 16.] 

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3.2.4 The minimum crew for each UAS operation will consist of one Pilot in 

Command ("PIC") and one Visual Observer ("VO"). The PIC will be 

designated before the flight, and cannot transfer his or her designation 

for the duration of the flight. The PIC must ensure that the VO can 

perform the functions prescribed for the VO. [AAIR Exemption 

Limitation No. 6; Pro Drones Canada Exemption Limitation No. 6.] 

3.2.5 The UA will be operated within visual line of sight ("VLOS") of the PIC 

at all times. The PIC will maintain VLOS with human vision unaided by 

any device other than corrective lenses as specified on the PIC's FAAissued airman medical certificate or driver's license. [AAIR Exemption 

Limitation No. 5; Pro Drones Canada Exemption Limitation No. 5.] The 

VO may be used to satisfy the VLOS requirement as long as the PIC 

always maintains VLOS capability. [AAIR Exemption Limitation No. 6; 

Pro Drones Canada Exemption Limitation No. 6.] 

3.2.6 During each UAS operation, the PIC and the VO must be able to 

communicate verbally with each other at all times. Electronic 

messaging or texting by the PIC and the VO is not permitted during 

UAS flight operations. [AAIR Exemption Limitation No. 6; Pro Drones 

Canada Exemption Limitation No. 6.] 

3.2.7 The PIC is prohibited from beginning a UAS flight unless (considering 

wind and forecast weather conditions) there is enough available power 

for the UA to conduct the intended operation and to operate after that 

for at least five minutes or, if greater, with the reserve power 

recommended by the UA manufacturer. [AAIR Exemption Limitation 

No. 20; Pro Drones Canada Exemption Limitation No. 20.] 

3.2.8 Prior to each UA flight, the PIC will conduct a pre-flight inspection and 

determine that the UAS (including the Ground Control Station) is in a 

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condition for safe flight. The pre-flight inspection will account for all 

potential discrepancies, e.g., non-functioning components, items or 

equipment. If the inspection reveals a condition that affects the safe 

operation of the UAS, the UA is prohibited from operating until the 

necessary maintenance has been performed and documented, and the 

UAS is found to be in a condition for safe flight. [AAIR Exemption 

Limitation No. 10; Pro Drones Canada Exemption Limitation No. 10.] 

The operator is responsible for maintaining and inspecting the UAS to 

ensure that it is in a condition for safe operation. [AAIR Exemption 

Limitation No. 9; Pro Drones Canada Exemption Limitation No. 9.] 

3.2.9 Prior to each UAS operation, the PIC will review the weather, the UAS 

battery requirements, the UA takeoff and landing distances, and the 

UAS performance, and will account for all relevant site-specific 

conditions per the Operating Documents (defined below). 

3.2.1 0 During each UAS operation, the UA will remain at or below 400 feet 

above ground level ("AGL"). [AAIR Exemption Limitation No. 4; Pro 

Drones Canada Exemption Limitation No. 4.] 

3.2.11 Altitude reports made to A TC or other persons must be reported in feet 

AGL. [AAIR Exemption Limitation No. 4; Pro Drones Canada 

Exemption Limitation No. 4.] 

3.2.12 All UAS operations will be conducted over private or controlled-access 

property with permission from the property owner/controller or 

authorized representative. Permission from the property 

owner/controller or authorized representative will be obtained for each 

flight to be conducted. [AAIR Exemption Limitation No. 27; Pro Drones 

Canada Exemption Limitation No. 27.] 

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3.2.13 The UA will operate at least 500 feet from all non-participating persons, 

vessels, vehicles, and structures unless: 

(a) Barriers or structures are present that sufficiently protect nonparticipating persons from the UA and/or debris in the event 

of an accident. lnspecTools must ensure that nonparticipating persons remain under such protection; and if a 

situation arises where non-participating persons leave such 

protection and are within 500 feet of the UA, flight operations 

must cease immediately in a manner ensuring the safety of 

non-participating persons; and/or 

(b) The owner/controller of any vessels, vehicles or structures 

has granted permission for operating closer to those objects 

and the PIC has made a safety assessment of the risk of 

operating closer to those objects and determined that it does 

not present an undue hazard. 

The PIC, VO, operator trainees, and essential persons are not 

considered non-participating persons under this exemption. 

[AAIR Exemption Limitation No. 26; Pro Drones Canada Exemption 

Limitation No. 26.] 

3.2.14 All UAS operations will take place during visual meteorological 

conditions (VMC) only. [AAIR Exemption Limitation No. 15; Pro Drones 

Canada Exemption Limitation No. 15.] 

3.2.15 lnspecTools will not operate UAS flights under Special Visual Flight 

Rules (SVFR). [AAIR Exemption Limitation No. 15; Pro Drones Canada 

Exemption Limitation No. 15.] 

3.2.16 All UAS operations will take place during daylight hours. UAS 

operations will not be conducted during night, as defined in 14 C.F.R. § 

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1.1. [AAIR Exemption Limitation No. 15; Pro Drones Canada 

Exemption Limitation No. 15.] 

3.2.17 During each UAS operation, the UA will avoid, remain clear of, and 

yield right-of-way to all manned aviation operations and activities at all 

times. [AAIR Exemption Limitation No. 24; Pro Drones Canada 

Exemption Limitation No. 24.] 

3.2.18 The UA will 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 PIC. [AAIR Exemption Limitation No. 17; Pro Drones 

Canada Exemption Limitation No. 17.] 

3.2.19 The UAS will not be operated by the PIC from any moving device or 

vehicle. [AAIR Exemption Limitation No. 25; Pro Drones Canada 

Exemption Limitation No. 25.] 

3.2.20 Any UAS that has undergone maintenance or alterations that affect the 

UAS operation or UA flight characteristics (e.g., replacement of a flight 

critical component) must undergo a functional test flight prior to 

conducting further operations under this exemption. Functional test 

flights will only be conducted by a PIC with a VO, and must remain at 

least 500 feet from other people. The functional test flight must be 

conducted in such a manner so as to not pose an undue hazard to 

persons and property. [AAIR Exemption Limitation No. 8; Pro Drones 

Canada Exemption Limitation No. 8.] 

3.2.21 If the UAS loses communications or its GPS signal during any 

operation, the UA must return to a pre-determined location within the 

private or controlled-access property. [AAIR Exemption Limitation No. 

18; Pro Drones Canada Exemption Limitation No. 18.] 

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3.2.22 The PIC will adhere to the written emergency procedures in the 

Manuals, and will abort the UAS operation and UA flight in the event of 

unpredicted obstacles or emergencies. [AAIR Exemption Limitation No. 

19; Pro Drones Canada Exemption Limitation No. 19.] 

3.2.23 The documents used by the operator to ensure the safe operation and 

flight of the UAS and any documents required under 14 C.F.R. §§ 91.9 

and 91.203 will be available to the PIC at the Ground Control Station of 

the UAS at any time the UA is operating, and will be made available to 

the FAA or any law enforcement official upon request. [AAIR Exemption 

Limitation No. 23; Pro Drones Canada Exemption Limitation No. 23.] 

3.2.24 Any incident, accident or flight operation that transgresses the lateral or 

vertical boundaries of the operational area as defined by the applicable 

COA will be reported to the FAA's UAS Integration Office (AFS-80) 

within 24 hours. Accidents will be reported to the National 

Transportation Safety Board ("NTSB") per instructions contained on the 

NTSB website: www.ntsb.gov. [AAIR Exemption Limitation No. 28; Pro 

Drones Canada Exemption Limitation No. 28.] 

3.3 Conditions and limitations regarding the Pilot in Command and other 

crewmember qualifications and training 

The PIC and other crewmembers for each UAS operation under the requested exemption 

will be subject to the following conditions and limitations: 

3.3.1 The PIC must hold (i) either an ATP, commercial, private, recreational 

or sport pilot certificate; and (ii) a current FAA airman medical 

certificate or a valid driver's license issued by a State, the District of 

Columbia, Puerto Rico, a U.S. territory/possession, or the Federal 

Government. The PIC must satisfy the flight review requirements of 14 

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C.F.R. § 61.56 in an aircraft for which the PIC is rated on his or her pilot 

certificate. [AAIR Exemption Limitation No. 13; Pro Drones Canada 

Exemption Limitation No. 13.] 

3.3.2 The operator will not permit any PIC to operate the UAS unless the PIC 

demonstrates the ability to safely operate the UAS in a manner 

consistent with how the UAS will be operated under this exemption, 

including evasive and emergency maneuvers and maintaining 

appropriate distances from persons, vessels, vehicles, and structures. 

PIC qualification flight hours and currency must be logged in a manner 

consistent with 14 C.F.R. § 61.51 (b). Flights for the purposes of 

training lnspecTools' PICs and VOs (training, proficiency, and 

experience-building) and determining the PIC's ability to safely operate 

the UAS in a manner consistent with how the UAS will be operated 

under this exemption are permitted under the terms of this exemption. 

These training operations, however, may only be conducted during 

dedicated training sessions. [AAIR Exemption Limitation No. 14; Pro 

Drones Canada Exemption Limitation No. 14.] 

3.3.3 During training, proficiency, and experience-building flights, all persons 

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not essential for flight operations are considered non-participants, and 

the PIC must operate the UA with appropriate distance from nonparticipants in accordance with 14 C.F.R. § 91.119. [AAIR Exemption 

Limitation No. 14; Pro Drones Canada Exemption Limitation No. 14.] 

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3.4 Conditions and limitations regarding lnspecTools manuals related to UAS 

operations 

lnspecTools has manuals for the ITX8 UAS and the 3DR Solo UAS, as well as a training 

program (collectively, the "Manuals"). The Manuals will be subject to the following limitations and 

conditions: 

3.4.1 The Operating Documents2 must be accessible during UAS operations 

and made available to the FAA upon request. If a discrepancy exists 

between the conditions and limitations in the exemption and the 

procedures outlined in the other Operating Documents, the conditions 

and limitations in the exemption take precedence and must be followed. 

Otherwise, lnspecTools must follow the procedures as outlined in the 

Operating Documents. [AAIR Exemption Limitation No. 7; Pro Drones 

Canada Exemption Limitation No. 7.] 

3.4.2 lnspecTools may update or revise its Operating Documents, and it is 

lnspecTools' responsibility to track such revisions and present updated 

and revised documents to the FAA or any law enforcement official upon 

request. lnspecTools must also present updated and revised 

documents if it petitions for an extension or amendment of the 

exemption. If lnspecTools determines that any update or revision 

would affect the basis upon which the FAA granted the requested 

exemption, then lnspecTools must petition for an amendment to the 

exemption. lnspecTools will contact the FAA's UAS Integration Office 

(AFS-80) if questions arise regarding updates or revisions to the 

2 This exemption, the Manuals, and all other documents needed by lnspecTools to operate the 

UAS and conduct its operations in accordance with the conditions and limitations stated in this grant of 

exemption are hereinafter referred to as the Operating Documents. [AAIR Exemption Limitation No. 7; 

Pro Drones Canada Exemption Limitation No. 7.] 

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Operating Documents. [AAIR Exemption Limitation No. 7; Pro Drones 

Canada Exemption Limitation No. 7.] 

3.4.3 Each UAS operated under the exemption will comply with all 

manufacturer safety bulletins. [AAIR Exemption Limitation No. 12; Pro 

Drones Canada Exemption Limitation No. 12.] 

3.4.4 lnspecTools will follow the UAS manufacturer's maintenance, overhaul, 

replacement, inspection, and life limit requirements for the UAS and 

UAS components. [AAIR Exemption Limitation No. 11; Pro Drones 

Canada Exemption Limitation No. 11.] 

CROSS-REFERENCES 

AAIR Exemption Limitation No. Petition Limitation No. 

Pro Drones Canada Exemption Limitation No. 

1 3.1.1 

2 3.2.2 

3 3.1.3 

4 3.2.1 0, 3.2.11 

5 3.2.5 

6 3.2.4, 3.2.5, 3.2.6 

7 3.4.1, 3.4.2 

8 3.2.20 

9 3.2.8 

10 3.2.8 

11 3.4.4 

12 3.4.3 

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13 3.3.1 

14 3.3.2, 3.3.3 

15 3.2.14, 3.2.15, 3.2.16 

16 3.2.3 

17 3.2.18 

18 3.2.21 

19 3.2.22 

20 3.2.7 

21 3.2.1 

22 3.1.5, 3.1.6 

23 3.2.23 

24 3.2.17 

25 3.2.19 

26 3.2.13 

27 3.2.12 

28 3.2.24 

4. REQUEST FOR DETERMINATION UNDER SECTION 333 OF FMRA 

In accordance with FMRA Sec. 333, lnspecTools requests that the Secretary of 

Transportation determine that lnspecTools' proposed small UAS operations (i) do not create a 

hazard to users of the National Airspace System or the public, and (ii) do not pose a threat to 

national security. 

lnspecTools further requests that, based on the Secretary's determination, the FAA 

determine - as it did in the AAIR Exemption and the Pro Drones Canada Exemption - that relief 

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from FAR Part 21 and any associated noise certification and testing requirements of FAR Part 36 is 

not necessary for the UAS operations proposed in this Petition. 3 

5. INFORMATION REQUIRED BY 14 C.F.R. § 11.81 TO SUPPORT A PETITION FOR 

EXEMPTION 

As required by FAR § 11.81, lnspecTools provides the following information in support of this 

Petition: 

5.1 Contact information: 

Name: lnspecTools, LLC submits this Petition for Exemption, through counsel, E. 

Tazewell Ellett and Patrick R. Rizzi. 

Mailing address: E. Tazewell Ellett 

Patrick R. Rizzi 

Counsel for lnspecTools, LLC 

Hogan Lovells US LLP 

555 131

h Street, NW 

Washington, DC 20004 

Telephone/Facsimile number: 

(T) 202-637-8644 (Ellett) I 202-637-5659 (Rizzi) 

(F) 202-637-5910 

E-mail addresses: 

tazewell.ellett@hoganlovells.com 

patrick.rizzi@hoganlovells.com 

5.2 The specific section or sections of the FAR from which lnspecTools seeks an 

exemption: 

FAR§ 61.23(a) and (c)- Medical certificates: Requirement and Duration. 

FAR§ 61.101(e)(4) and (5)- Recreational pilot privileges and limitations. 

FAR§ 61.113(a) and (b)- Private pilot privileges and limitations: Pilot in command. 

FAR§ 61.315(a), (c)(2), and (c)(3)- What are the privileges and limitations of my 

sport pilot certificate? 

FAR§ 91.7(a)- Civil aircraft airworthiness. 

FAR§ 91.119(c)- Minimum safe altitudes: General. 

FAR§ 91.121 -Altimeter settings. 

3 AAIR Exemption, at 6; Pro Drones Canada Exemption, at 2. If the FAA concludes that the UAS 

operations proposed in this Petition require an exemption from FAR Parts 21 and/or 36, then lnspecTools 

requests that the FAA include that relief in the exemption. 

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FAR§ 91.151- Fuel requirements for flight in VFR conditions. 

FAR§ 91.405(a)- Maintenance required. 

FAR§ 91.407(a)(1)- Operation after maintenance, preventive maintenance, 

rebuilding, and inspections. 

FAR§ 91.409(a)(1) and (2) -Inspections. 

FAR§ 91.417(a) and (b)- Maintenance records. 

5.3 The extent of relief sought and the reason relief is sought: 

lnspecTools proposes to conduct commercial small UAS operations, as described herein, by 

operating one or more small UAS for aerial inspections and assessments of the condition of utilityscale wind turbines, solar farms, and power distribution facilities on behalf of the owners and 

operators of such farms and facilities, as well as wilderness/wildlife conditions. In order to be able to 

conduct these UAS operations, lnspecTools petitions the FAA, pursuant to FAR §§ 11.61 (b), 

11.63(a), and 11.81 (b), for an exemption from the following FAR for the reasons noted: 

FAR§ 61.23(a) and (c)- Medical certificates: Requirement and Duration. 

FAR§ 61.101(e)(4) and (5)- Recreational pilot privileges and limitations. 

The regulation states, in relevant part: 

(e) Except as provided in paragraphs (d) and (i) of this section, a 

recreational pilot may not act as pilot in command of an aircraft- ... 

(4) For compensation or hire; 

(5) In furtherance of a business; .... 

FAR§ 61.113(a) and (b)- Private pilot privileges and limitations: Pilot in command. 

The regulation states, in relevant part: 

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(a) Except as provided in paragraphs (b) through (h) of this section, 

no person who holds a private pilot certificate may act as pilot in 

command of an aircraft that is carrying passengers or property for 

compensation or hire; nor may that person, for compensation or hire, 

act as pilot in command of an aircraft. 

(b) A private pilot may, for compensation or hire, act as pilot in 

command of an aircraft in connection with any business or 

employment if: 

(1) The flight is only incidental to that business or 

employment; and 

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(2) The aircraft does not carry passengers or property for 

compensation or hire. 

FAR§ 61.315(a) and (c)(2), (c)(3)- What are the privileges and limitations of my sport 

pilot certificate? 

The regulation states, in relevant part: 

(a) If you hold a sport pilot certificate you may act as pilot in 

command of a light-sport aircraft, except as specified in paragraph (c) 

of this section .... 

(c) You may not act as pilot in command of a light-sport aircraft: ... 

(2) For compensation or hire. 

(3) In furtherance of a business .... 

lnspecTools requests an exemption from these regulations to the extent necessary to permit 

lnspecTools to conduct UAS operations using PICs who hold (i) an FAA private pilot, recreational 

pilot, or a sport pilot certificate, and (ii) an FAA airman medical certificate or a state driver's license. 

While lnspecTools recognizes that the FAA normally requires a PIC to hold a commercial pilot 

certificate where there is compensation either to the pilot or for the operation, lnspecTools requests 

that the FAA exempt lnspecTools and its PICs from this requirement since the use of at least a sport 

pilot as the PIC for the UAS operations under this exemption will be more safe than the use of a 

commercial pilot for manned aircraft operations. Unlike conventional aircraft, the ITX8 UAS and the 

3DR Solo UAS are lightweight, remotely controlled, and battery-powered (not fuel/gas), and they 

have no crew or passengers. The fulfillment of the additional requirements for a sport, recreational 

or private pilot to become qualified as a commercial pilot would not lead to any additional safety 

benefits when UAS operations are involved. 

The differences between the aeronautical knowledge and aeronautical experience 

requirements for sport pilots and for commercial pilots are significant in the traditional world of 

manned aircraft. However, no aspect of this incremental additional knowledge or aeronautical 

experience is significant for the daytime, VMC, low-altitude, visual-line-of-sight, small UAS 

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operations over private or controlled access properties with property owner/controller permission as 

proposed in this Petition. Put another way, there are stark and fundamental differences between the 

type of experience and aeronautical knowledge that the PIC of a commercial manned aircraft with 

passengers and property should have, versus the type of experience and aeronautical knowledge 

that the PIC of a small UAS should have, in order to avoid imperiling passengers or property. In 

lnspecTools' case, the small amount of property carried aboard the UA will be lnspecTools' property. 

While the PIC will be compensated, all risk of damage to the property (in fact to the UAS itself) will 

be borne by lnspecTools. There is no expectation or need for the PIC of the small UA to have the 

type of experience or aeronautical knowledge that a commercial pilot for a manned aircraft would 

have. Similarly, the differences between the flight proficiency requirements for sport pilots and 

commercial pilots are not substantively significant here where the operations will be conducted 

strictly during daylight VMC conditions, within VLOS, at altitudes no higher than 400 feet AGL. And, 

lnspecTools has a training program to ensure that the experience, knowledge, and flight proficiency 

needed to operate the ITX8 UAS and the 3DR Solo UAS safely are achieved for its PICs. 

Accordingly, there is no reason to require the UAS PIC to have more aeronautical knowledge, 

experience, and flight proficiency than that required for a sport pilot certificate. 

Given that lnspecTools plans to operate its ITX8 UAS and 3DR Solo UAS over private or 

controlled-access property and at low altitudes during daytime in VMC, the parallel nature of sport 

pilot aeronautical knowledge requirements to those of commercial requirements, the limited 

airmanship skills necessary to operate these small UAS, and the lack of additional safety benefits for 

the proposed UAS operations here resulting from commercial pilot experience, the PIC under this 

exemption should only be required to hold, at most, a sport pilot certificate. Such a condition would 

be consistent with the certificate requirements imposed on the PIC in the AAIR Exemption and the 

Pro Drones Canada Exemption. 

For these reasons, and consistent with recent summary grant exemptions, lnspecTools 

requests that the FAA grant an exemption to permit lnspecTools to use as PIC of its proposed UAS 

operations pilots who hold at least a sport pilot certificate and either an FAA third-class airman 

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medical certificate or a state driver's license, so long as they satisfy the conditions and limitations 

proposed in this Petition, including the PIC qualification and training requirements. 

FAR§ 91.7(a)- Civil aircraft airworthiness. 

The regulation states in relevant part: 

(a) No person may operate a civil aircraft unless it is in an airworthy 

condition .... 

lnspecTools requests an exemption from this provision to the extent necessary. 4 Neither the 

ITX8 UAS nor the 3DR Solo UAS will require an airworthiness certificate under FAR Part 21, 

Subpart H, and thus relief is requested from this regulation. See Exemption No. 11110 (December 

10, 2014; Docket FAA-2014-0367) ("Trimble Exemption"), at 16. An exemption is warranted 

because lnspecTools understands that, notwithstanding the lack of an airworthiness certificate, the 

FAA will consider its "compliance with [lnspecTools' Manuals] to be sufficient means for determining 

an airworthy condition" and that lnspecTools must still determine the UA's airworthiness prior to 

each flight based on compliance with such Manuals. Trimble Exemption, at 16. 

FAR§ 91.119(c)- Minimum safe altitudes: General. 

The regulation states: 

Except when necessary for takeoff or landing, no person may operate 

an aircraft below the following altitudes: 

(a) Anywhere. An altitude allowing, if a power unit fails, an emergency 

landing without undue hazard to persons or property on the surface. 

(b) Over congested areas. Over any congested area of a city, town, 

or settlement, or over any open air assembly of persons, an altitude 

of 1 ,000 feet above the highest obstacle within a horizontal radius of 

2,000 feet of the aircraft. 

(c) Over other than congested areas. An altitude of 500 feet above 

the surface, except over open water or sparsely populated areas. In 

4 lnspecTools requests exemption from FAR § 91.7(a) based on the relief granted in the Trimble 

Exemption, at 16, 21. However, lnspecTools notes that the FAA determined that no such exemption was 

needed in Exemption No. 11062 (September 25, 2014; Docket FAA-2014-0352) ("Astraeus Exemption") 

at19,22. 

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those cases, the aircraft may not be operated closer than 500 feet to 

any person, vessel, vehicle, or structure. 

(d) Helicopters, powered parachutes, and weight-shift-control aircraft. 

If the operation is conducted without hazard to persons or property on 

the surface-

(1) A helicopter may be operated at less than the minimums 

prescribed in paragraph (b) or (c) of this section, provided 

each person operating the helicopter complies with any 

routes or altitudes specifically prescribed for helicopters by 

the FAA; and 

(2) A powered parachute or weight-shift-control aircraft may 

be operated at less than the minimums prescribed in 

paragraph (c) of this section. 

lnspecTools requests an exemption from this regulation to the extent necessary to permit 

lnspecTools to conduct its UAS operations at altitudes lower than those permitted by FAR§ 91.119, 

since such altitudes are one of the key benefits of using small UAS for these flights. Even at these 

low altitudes, lnspecTools' UAS operations will be conducted at a level of safety at least equal to that 

which would be achieved if larger manned aircraft were to be used at the altitudes required by FAR§ 

91.119. 

With respect to paragraph (a), lnspecTools intends to comply with this requirement to the 

same extent as would a manned aircraft, meaning that the UA must operate at an altitude such that 

the loss of a single power unit aboard the UA or used by the UAS would still permit an emergency 

landing "without undue hazard to persons or property on the surface." lnspecTools agrees with the 

FAA's reasoning on this issue in the Astraeus Exemption, at 20, and therefore does not believe that 

relief is required from paragraph (a). 

With respect to paragraph (b), lnspecTools plans to operate these small UAS over private or 

controlled-access properties (with owner/controller permission) in areas that are not congested or 

densely populated. Accordingly, lnspecTools does not believe that an exemption is necessary from 

this paragraph (b) covering "congested areas". 

With respect to paragraph (c), lnspecTools requests an exemption to allow UAS operations 

down to the surface, both in sparsely populated areas and in "other than congested" areas. 

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lnspecTools' UAS operations require lower-level flying, but have a number of self-imposed 

restrictions to ensure at least an equivalent level of safety. For example, 

• All operations will be conducted over private or controlled access property. 

• Permission from the property owner/controller will be obtained prior to the beginning 

of each UA flight. 

• The UA will operate at least 500 feet from all non-participating persons, vessels, 

vehicles, and structures unless: 

o Barriers or structures are present that sufficiently protect non-participating 

persons from the UA and/or debris in the event of an accident. lnspecTools 

will ensure that non-participating persons remain under such protection; and 

if a situation arises where non-participating persons leave such protection 

and are within 500 feet of the UA, flight operations will cease immediately in 

a manner ensuring the safety of the non-participating persons; and/or 

o The UA is operated near vessels, vehicles or structures where the property 

owner/controller has granted permission, and the PIC has made a safety 

assessment of the risk of operating closer to those objects and determined 

that it does not present an undue hazard. 

Even with a grant of this exemption, the UAS operations will be at least as safe as operations 

by manned aircraft that comply with this paragraph. Flying a manned aircraft, given its weight, size, 

speed, and fuel load, would pose a significant risk relative to the use of a small UA, with a much 

smaller size and lighter weight, operating at much slower speeds, with batteries rather than a 

significant fuel load, at all times within VLOS of the PIC on the ground who has a wide view. 

Accordingly, as the FAA determined in the Trimble Exemption, at 17-18, relief is warranted here 

provided that lnspecTools adheres to its Manuals and the additional conditions and limitations 

outlined above and in the exemption. For these reasons, lnspecTools requests relief from the 

entirety of paragraph (c), as was recently granted in the AAIR Exemption, at 6, and the Pro Drones 

Canada Exemption, at 2. 

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lnspecTools does not request relief from paragraph (d), because it applies only to helicopters 

(and allows operation at lower altitudes only if on a prescribed helicopter route) and powered 

parachute-type aerial vehicles. 

FAR§ 91.121- Altimeter settings. 

The regulation states, in relevant part: 

(a) Each person operating an aircraft shall maintain the cruising 

altitude or flight level of that aircraft, as the case may be, by reference 

to an altimeter that is set, when operating-

(1) Below 18,000 feet MSL, to-

(i) The current reported altimeter setting of a station along 

the route and within 100 nautical miles of the aircraft; 

(ii) If there is no station within the area prescribed in 

paragraph (a)(1 )(i) of this section, the current reported 

altimeter setting of an appropriate available station; or 

(iii) In the case of an aircraft not equipped with a radio, 

the elevation of the departure airport or an appropriate 

altimeter setting available before departure; or 

(2) At or above 18,000 feet MSL, to 29.92" Hg. 

(b) . 

It is not clear to lnspecTools that an exemption from this section is required, because, 

although the regulation expressly applies only to aircraft maintaining a "cruising altitude" and dictates 

the altimeter setting that must be used while at that cruising altitude, cruising altitudes for VFR flights 

do not begin - according to FAR § 91.159 - until "more than 3,000 feet above the surface". 5 

Nonetheless, lnspecTools requests an exemption from FAR § 91.121 to the extent necessary to 

permit lnspecTools to conduct the small UAS operations described in this Petition. See, !;UL, AAIR 

Exemption, at 6; Pro Drones Canada Exemption, at 2; Astraeus Exemption, at 21-22. 

lnspecTools recognizes the critical importance of ensuring that any UAS operated by 

lnspecTools maintains altitude to an accurate reference such that other aircraft and the FAA may 

FAR§ 91.159; see also Aeronautical Information Manual, at Chpt. 3, Sec. 1, Tbl. 3-1-1, para. 3-1-

2. (July 24, 2014). 

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rely on lnspecTools' UAS to be operating as proposed. The PIC will check the UA altitude reading 

prior to each takeoff, and will effectively zero the UA's altitude at the point of takeoff, to ensure that 

measurements of the UA's altitude are as accurate as possible relative to the local elevation. To the 

extent that this methodology does not satisfy FAR§ 91.121 or any other regulation, lnspecTools 

requests an exemption to permit UAS operations using this methodology. 

FAR§ 91.151- Fuel requirements for flight in VFR conditions. 

The regulation states: 

(a) No person may begin 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. 

(b) No person may begin 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. 

lnspecTools requests an exemption from FAR § 91.151 to permit lnspecTools to plan its 

UAS operations as described above. The proposed small UAS operations in this Petition will (i) 

involve operations in which one or more UAS is transported by means other than its own power to 

the operational location, and (ii) begin and end at the operational site, with the takeoff, entire flight, 

and landing all taking place within the immediate proximity of each other while remaining at all times 

within VLOS of the PIC. 

The goal of FAR § 91.151 is to ensure that pilots plan for an extra 20 or 30 minutes of fuel at 

their first intended point of landing in order to account for unexpected possible delays en route and 

at the first planned destination. Many of these delays that plague manned aircraft are simply not an 

issue with the proposed small UAS operations over private or controlled access property, because 

there is virtually no "en route" portion of the flight, and any problems at the point of landing are 

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extremely unlikely to cause delays, since a UA can always land just a few feet away if the intended 

point of landing becomes unusable. 

Given the relatively short operating time for the ITX8 UAS (45 minutes) and the 3DR Solo 

UAS (25 minutes), requiring a full 30 minutes of reserve "fuel" (battery power) could take up (i) 

nearly all of the available time for ITX8 UAS operations and (ii) all of the time available for 3DR Solo 

UAS operations. lnspecTools believes that using a smaller reserve for UAS flight planning purposes 

will be at least as safe as using the reserves required by FAR § 91.151 for manned aircraft. To that 

end, and consistent with AAIR Exemption Limitation No. 20 and Pro Drones Canada Exemption 

Limitation No. 20, the PIC under the requested exemption will be prohibited from beginning a UAS 

flight unless (considering wind and forecast weather conditions) there is enough power available 

power for the UA to conduct the intended operation and to operate after that for at least five minutes 

or, if greater, with the reserve power recommended by the UA manufacturer. See Proposed 

Limitation 3.2.7. Such a battery reserve is more than sufficient, particularly in light of the FAA's 

acceptance of a 5-minute reserve in the AAIR Exemption and the Pro Drones Canada Exemption. 

lnspecTools believes that these limitations will further ensure that the proposed reserve planning 

and operational requirements that lnspecTools is requesting to use under this exemption will provide 

at least an equivalent level of safety. 

For these reasons, lnspecTools requests an exemption from FAR § 91.151 (a) to permit it to 

plan and conduct UAS operations subject to the reserve power limitation explained above. FAR § 

91.151 (b) covers only rotorcraft, and thus is not applicable to the small UAS operations lnspecTools 

is proposing. 

FAR § 91.405(a)- Maintenance required. 

The regulation states, in relevant part: 

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Each owner or operator of an aircraft-

(a) 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; 

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(b) ** **. 

lnspecTools requests an exemption from FAR § 91.405(a) to permit lnspecTools to conduct 

the UAS operations proposed in this Petition without having to perform the inspections and 

discrepancy repairs required by FAR § 91.405(a). In the Astraeus Exemption and the Trimble 

Exemption, the FAA determined that the proposed UAS operations required exemption from FAR§ 

91.405(a), and that the achievement of an adequate level of safety required certain conditions and 

limitations. lnspecTools has proposed in Section 3 of this Petition several conditions and limitations 

related to maintenance and inspections which it believes provide a level of safety at least equivalent 

to that provided by FAR § 91.405(a). For this reason, and consistent with the exemptions granted 

from this section in the AAIR Exemption and the Pro Drones Canada Exemption, lnspecTools 

requests an exemption from FAR § 91.405(a) to permit lnspecTools to conduct UAS operations as 

proposed in this Petition, subject to the conditions and limitations proposed above, without having to 

perform the inspections and discrepancy repairs required by FAR§ 91.405(a). 

lnspecTools does not believe that an exemption from the remaining paragraphs of FAR § 

91.405 is required, since lnspecTools will make appropriate logbook entries in aircraft maintenance 

records in accordance with paragraph (b), appropriately mark any inoperative instrument or item of 

equipment for which maintenance has been properly deferred in compliance with paragraph (c), and 

appropriately placard listed discrepancies that include inoperative instruments or equipment in 

compliance with paragraph (d). 

FAR § 91.407(a)(1) - Operation after maintenance, preventive maintenance, rebuilding 

or alteration. 

The regulation states: 

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(a) No person may operate any aircraft that has undergone 

maintenance, preventive maintenance, rebuilding, or alteration 

unless-

( 1) It has been approved for return to service by a person 

authorized under §43.7 of this chapter; and 

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(2) The maintenance record entry required by §43.9 or §43.11, as 

applicable, of this chapter has been made. 

(b) . 

(c)** **. 

lnspecTools requests an exemption from FAR § 91.407(a)(1) to permit lnspecTools to 

conduct UAS operations as proposed in this Petition without having to have the UAS approved for 

return to service by a person authorized under FAR § 43.7. In the Astraeus Exemption, the FAA 

determined that the proposed UAS operations required exemption from FAR § 91.407(a)(1 ), subject 

to certain conditions and limitations. lnspecTools has proposed in this Petition maintenance-related 

conditions and limitations which it believes provide a level of safety at least equivalent to that 

provided by FAR§ 91.407(a)(1). For this reason, and consistent with the exemptions granted from 

this section in the AAIR Exemption and the Pro Drones Canada Exemption, lnspecTools requests an 

exemption from FAR § 91.407(a)(1) to permit lnspecTools to conduct UAS operations as proposed 

in this Petition, subject to the proposed conditions and limitations, without having to have the UAS 

approved for return to service by a person authorized under FAR§ 43.7. 

lnspecTools does not believe that an exemption from the remaining paragraphs of FAR § 

91.407 is required, since lnspecTools will require that maintenance record entries are made as 

required, in compliance with paragraph (a)(2), and since no persons will be carried following 

maintenance performed on the UAS, making paragraphs (b) and (c) moot. 

FAR§ 91.409(a)(1) and (2) -Inspections. 

The regulation states, in relevant part: 

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(a) Except as provided in paragraph (c) of this section, no person 

may operate an aircraft unless, within the preceding 12 calendar 

months, it has had-

(1) An annual inspection in accordance with part 43 of this chapter 

and has been approved for return to service by a person authorized 

by §43.7 of this chapter; or 

(2) An inspection for the issuance of an airworthiness certificate in 

accordance with part 21 of this chapter. 

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No inspection performed under paragraph (b) of this section may be 

substituted for any inspection required by this paragraph unless it is 

performed by a person authorized to perform annual inspections and 

is entered as an "annual" inspection in the required maintenance 

records. 

(b)  . 

lnspecTools requests an exemption from FAR § 91.409(a)(1) and (2) to permit lnspecTools 

to conduct UAS operations as proposed in this Petition without having to obtain the annual 

inspection and airworthiness certificate inspection required by FAR § 91.409(a)(1) and (2). In the 

Astraeus Exemption, the FAA determined that the proposed UAS operations required exemption 

from FAR § 91.409(a)(1) and (2), and that achieving an adequate level of safety required certain 

conditions and limitations. lnspecTools has proposed in this Petition maintenance and inspectionrelated conditions and limitations which it believes provide a level of safety at least equivalent to that 

provided by FAR § 91.409(a)(1) and (2). For this reason, and consistent with the exemptions 

granted from this section in the AAIR Exemption and the Pro Drones Canada Exemption, 

lnspecTools requests an exemption from FAR § 91.409(a)(1) and (2) to permit lnspecTools to 

conduct UAS operations as proposed in this Petition, subject to the proposed conditions and 

limitations, without having to obtain the annual inspection and airworthiness certificate inspection 

required by FAR§ 91.409(a)(1) and (2). 

FAR§ 91.417(a) and (b)- Maintenance records. 

The regulation states, in relevant part: 

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(a) Except for work performed in accordance with §§91.411 and 

91.413, each registered owner or operator shall keep the following 

records for the periods specified in paragraph (b) of this section: 

(1) Records of the maintenance, preventive maintenance, and 

alteration and records of the 1 00-hour, annual, progressive, 

and other required or approved inspections, as appropriate, 

for each aircraft (including the airframe) and each engine, 

propeller, rotor, and appliance of an aircraft. The records 

must include-

(i) A description (or reference to data acceptable to the 

Administrator) of the work performed; and 

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(ii) The date of completion of the work performed; and 

(iii) The signature, and certificate number of the person 

approving the aircraft for return to service. 

(2) Records containing the following information: 

(i) The total time in service of the airframe, each engine, 

each propeller, and each rotor. 

(ii) The current status of life-limited parts of each airframe, 

engine, propeller, rotor, and appliance. 

(iii) The time since last overhaul of all items installed on 

the aircraft which are required to be overhauled on a 

specified time basis. 

(iv) The current inspection status of the aircraft, including 

the time since the last inspection required by the 

inspection program under which the aircraft and its 

appliances are maintained. 

(v) The current status of applicable airworthiness 

directives (AD) and safety directives including, for each, 

the method of compliance, the AD or safety directive 

number and revision date. If the AD or safety directive 

involves recurring action, the time and date when the next 

action is required. 

(vi) Copies of the forms prescribed by §43.9(d) of this 

chapter for each major alteration to the airframe and 

currently installed engines, rotors, propellers, and 

appliances. 

(b) The owner or operator shall retain the following records for the 

periods prescribed: 

(c)** **. 

(1) The records specified in paragraph (a)(1) of this section 

shall be retained until the work is repeated or superseded by 

other work or for 1 year after the work is performed. 

(2) The records specified in paragraph (a)(2) of this section 

shall be retained and transferred with the aircraft at the time 

the aircraft is sold. 

(3) A list of defects furnished to a registered owner or 

operator under §43.11 of this chapter shall be retained until 

the defects are repaired and the aircraft is approved for return 

to service. 

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lnspecTools requests an exemption from FAR§ 91.417(a) and (b) to permit lnspecTools to 

conduct UAS operations as proposed in this Petition without having to keep the records described in 

FAR § 91.417(a) and (b). The FAA determined in the Astraeus Exemption that the proposed UAS 

operations required exemption from FAR § 91.417(a) and (b), and that an adequate level of safety 

required certain conditions and limitations. lnspecTools has proposed in this Petition maintenance, 

inspection, and records-related conditions and limitations which it believes provide a level of safety 

at least equivalent to that provided by FAR§ 91.417(a) and (b). For this reason, and consistent with 

the exemptions granted from this section in the AAIR Exemption and the Pro Drones Canada 

Exemption, lnspecTools requests an exemption from FAR § 91.417(a) and (b) to permit lnspecTools 

to conduct UAS operations as proposed in this Petition, subject to the proposed conditions and 

limitations, without having to keep the records described in FAR§ 91.417(a) and (b). 

Additional FAR Provisions. 

The Petition does not seek exemption from certain regulations based on the reasoning and 

FAA precedent outlined below in the footnote. 6 However, lnspecTools also requests that, to the 

6 This Petition does not seek exemption from: 

> FAR Part 21 or 36, based on the reasoning in the Astraeus Exemption, at 14. 

> FAR§ 91.7(b), based on the reasoning in the Trimble Exemption, at 17. 

> FAR §§ 91.9(b)(2) and 91.203(a) and (b), based on the reasoning in the FAA's August 8, 2014 

Memorandum titled "Interpretation regarding whether certain required documents may be kept at an 

unmanned aircraft's control station" ("FAA's August 8, 2014 Memorandum"), the Astraeus Exemption, at 

19-20, 22, and the Trimble Exemption, at 17, 20. 

> FAR §§ 45.23(b) and 91.9(c), based on the reasoning in the Astraeus Exemption, at 14, and the 

Trimble Exemption, at 14, related to FAR§ 45.23(b), and assuming that the markings on the UA used to 

comply with FAR Part 45, Subpart C requirements are as large as practicable. 

> FAR§§ 47.3(b)(2) and 47.31(c), based on the reasoning in the FAA's August 8, 2014 Memorandum, 

and assuming that all UA are registered in accordance with FAR Part 47. 

> FAR§ 91.1 03(b)(2), based on the FAA's reasoning in the Astraeus Exemption, at 20, which concluded 

that an exemption from the preflight action requirements is not necessary when the grant of an exemption 

for UAS operations includes conditions that satisfy preflight action requirements. lnspecTools proposes 

such conditions in this Petition. 

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extent that the FAA concludes that an exemption from one or more other provisions of the FAR 

would be required to permit the UAS operations described in this Petition, the FAA grant an 

exemption from those FAR provisions as necessary to permit the UAS operations described in this 

Petition. 7 

5.4 Reasons why granting the request would be in the public interest: 

A grant of the requested exemption for small UAS commercial inspection and assessment 

operations would be in the public interest for several reasons. As discussed below, these operations 

would support cost-effective and safe renewable energy sources, and would enhance safety for the 

general public, lnspecTools' employees, its customers, and their employees. 

First, the ability to use a small UAS as described herein, subject to the conditions and 

limitations proposed in this Petition, would enable lnspecTools to inspect and evaluate wind turbines 

and solar energy panels, thereby directly supporting the development, use, and safety of renewable 

energy. These UAS operations would support a critical element of President Obama's Advancing 

Clean Energy program. 

Second, these battery-powered UAS operations would have a net positive impact on the 

environment by replacing inspections conducted by larger, fuel-powered, and noisier manned aircraft 

and by supporting clean energy that can displace other sources of power generation which create far 

more pollution. 

Third, lnspecTools' small UAS operations under the requested exemption would reduce the 

operational costs of such renewable energy facilities (as compared to current inspection methods), 

thereby helping renewable energy be competitive in the market long term. In addition, the cost of 

> FAR§ 91.109, based on the FAA's reasoning in the Astraeus Exemption, at 20, which concluded that 

an exemption from the requirement for dual flight controls for flight or simulator training or for flight testing 

is not necessary when there is no indication that dual flight controls will be used during any flight or 

simulator training or flight testing. 

lnspecTools would be happy to provide follow-on documentation providing the rationale 

underlying any such additional exemptions. 

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these inspections by the small, battery-powered ITX8 UAS and/or 3DR Solo UAS would be much 

lower than the cost of such inspections performed with combustible fuel-consuming manned aircraft. 

By using the small UAS to conduct these inspections, the number of man-hours and the downtime 

necessary for inspections would also be significantly reduced. 

Fourth, the reduced cost of inspection services resulting from the use of the small ITX8 UAS 

and/or 3DR Solo UAS would likely result in more inspections taking place, which, in turn, would lead 

to the earlier identification of faults in wind turbine blades that could otherwise potentially result in a 

catastrophic failure and a public safety threat. 

Fifth, the small ITX8 UAS, with electro-optical and infra-red sensors, as well as ultrasonic 

and laser-distance measuring devices, and the small 3DR Solo UAS with its camera would collect 

more accurate data, thereby enabling the operators of the renewable energy facilities to make better, 

more timely, and well-informed decisions about maintenance and repair issues. Additionally, the 

efficiency of the inspection process, through use of UAS and the data delivery method, would enable 

decision-makers to address issues more quickly, which, in turn, would result in more production, 

whether it is replacing a broken or underperforming solar module or repairing a wind turbine blade 

and increasing its power performance. 

Sixth, the use of the small, extremely lightweight, battery-powered ITX8 UAS and 3DR Solo 

UAS to perform these aerial inspections of wind turbines and solar panels and related operations 

would be far less risky than undertaking those operations with much heavier, much faster, much 

larger, manned helicopters or other aircraft loaded with combustible fuel and a crew. 

As the FAA acknowledged in the Total Safety Exemption, Exemption No. 11156 (January 29, 

2015; Docket FAA-2014-0610) at 11-12: 

'The [lnspecTools] pilot and crew will be remotely located from the aircraft. The 

limited weight and restricted sterile area significantly reduces the potential for harm 

to participating and nonparticipating individuals or property in the event of an incident 

or accident. The risk to an onboard pilot and crew during an incident or accident is 

eliminated with the use of a UA for the inspection operation. In addition, utilizing 

UAS to conduct flare stack inspections will reduce the need for inspection personnel 

to perform this hazardous [inspection] activity. 

Manned aircraft are at risk of fuel spillage and fire in the event of an incident or 

accident. [The ITX8 UAS, as well as the 3DR Solo UAS,] carries no fuel [it is battery-

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powered], and therefore the risk of fire following an incident or accident due to fuel 

spillage is eliminated." 

Seventh, these small UAS operations would also be much less risky than having employees 

undertake the inspections directly by climbing the wind turbines. In addition, the use of the small 

UAS for these inspections would reduce the safety risks for workers who are currently in the field 

performing these inspections on-site, and their exposure to environmental and other hazards specific 

to the site and scope of work. To this point, the FAA has concluded - in the context of bridge 

inspections (which are "typically conducted by personnel who physically inspect the bridge") -that an 

appropriately tailored and limited exemption for commercial UAS operations would be in the public 

interest because "utilizing UAS to conduct bridge inspections will reduce the need for inspection 

personnel to perform this hazardous activity as well as traffic hazards related to blocking lanes on 

the roadway." Asymmetric Technologies Exemption, 8 at 8-9. The FAA has reached similar 

conclusions in the context of tower/structure inspections and flare stack inspections. 

'Tower and structure inspections are hazardous and present unique difficulties for 

persons conducting inspections and maintenance of this infrastructure. The 

inspections are normally conducted utilizing personnel to physically inspect the tower 

and structure. Manned helicopters may also be used to transport inspection 

personnel to the top of the tower so that a physical inspection may be conducted. 

The petitioner plans to utilize a UAS to provide high definition aerial photography to 

minimize the need for inspectors to personally climb such structures. Manned 

helicopters assisting in tower and structure inspections can weigh 6,000 pounds or 

more and are operated by an onboard pilot, in addition to other onboard 

crewmembers, as necessary .... [U]tilizing UAS to conduct tower inspections will 

reduce the need for inspection personnel to perform this hazardous activity .... " 

LowCountryRC Exemption, 9 at 2-3; see also Total Safety Exemption, at 11-12 ("utilizing UAS to 

conduct flare stack inspections will reduce the need for inspection personnel to perform this 

hazardous [inspection] activity"). 

8 Exemption No. 11171 (February 10, 2015; Docket FAA-2014-0816) ("Asymmetric Technologies 

Exemption"). 

9 Exemption No. 11184 (February 23, 2015; Docket FAA-2014-0803) ("LowCountryRC 

Exemption"). 

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These distinctions, coupled with the safety-related features of the ITX8 UAS (as described 

in the next Section), such as Lost Link Procedures, backup redundant communications links, "return 

home" modes, and real-time telemetry, demonstrate that the ITX8 UAS inspection and assessment 

operations proposed in this Petition would be far less risky than if conducted with larger, faster, 

heavier, combustible fuel-powered manned aircraft or by personnel climbing wind turbines or 

inspecting solar panels. 

The 3DR Solo UAS also has safety features, including "Pause", "Return Home", and 

emergency motor shut-off features. In addition, it has a substantial alert system for various types of 

errors and an altitude limit mechanism. 

In sum, lnspecTools' proposed approach would allow renewable power generation 

equipment to be inspected and assessed in a safer, more reliable, more economical, and timely 

manner. 

5.5 Reasons why granting the exemption would not adversely affect safety, or 

how the exemption would provide a level of safety at least equal to that 

provided by the rule from which exemption is sought: 

Throughout this Petition, lnspecTools has explained many reasons why granting an 

exemption from each section of the FAR from which relief is sought would result in UAS operations 

that provide a level of safety equal to, or greater than, that provided by the rule from which 

exemption is sought. Moreover, the many conditions and limitations proposed in this Petition, 

coupled with the operational protocols for these small UAS, also would ensure at least an equivalent 

level of safety, as the FAA concluded in the LowCountryRC Exemption, the Total Safety Exemption, 

the AAIR Exemption, the Pro Drones Canada Exemption, and the Trimble Exemption, among others. 

In general, the risks of any small UAS operation proposed in this Petition interfering with a 

manned aircraft would be minimized by numerous factors, including but not limited to: 

? the low altitude at which the UAS would operate; 

? the locations at which the UAS would operate (e.g., remote areas; private or controlled 

access property; away from airports; and, with respect to wind turbine towers, designated 

"no fly" zones); 

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";;- the small size, light weight, and relatively slow speed of the ITX8 UAS and the 3DR Solo 

UAS; 

> the restriction on UAS operations to VMC and daytime conditions; and 

";;- the requirement for the PIC to maintain VLOS of the UA at all times. 

Importantly, the ITX8 UAS has several other safety-related protocols in case there is any lost link 

between the UA and the operator; the Lost Link Procedures are set out in the Manuals and can 

handle lost links alone or in combination. The ITX8 UAS also has backup communications links. 

The primary control interface is via Spread Spectrum Frequency Hopping technology for an 

extremely robust radio RF link; the backup system is via a telemetry link to the Ground Station. The 

ITX8 UAS also has several return home modes - Return to Launch, Land at nearest specified 

landing zone, or land immediately. The "return home" mode is selected based on pre-programmed 

criteria. 

The 3DR Solo UAS also has several important safeguards. It has an altitude limit 

mechanism and battery power alerts. It has a "pause" feature whereby the 3DR Solo UAS can be 

stopped mid-air, as well as an emergency motor shut-off. And, like the ITX8 UAS, the 3DR UAS has 

a "return home" capability. 

The risks to persons or property on the ground would be substantially mitigated - if not 

eliminated - by these same factors, as well as the 500-foot set-off from non-participating persons, 

vehicles, and structures absent additional safeguards. Per the conditions and limitations proposed 

in this Petition, (i) the PIC will adhere to the written emergency procedures in the Manuals and 

suspend/abort the UAS operation and UA flight in the event of unpredicted obstacles or emergencies 

in accordance with the Manuals; and (ii) lnspecTools will coordinate extensively, as warranted, with 

the FAA, with local airports, and with property owners to ensure that all UAS operations under the 

exemption are at least as safe as would be manned aircraft operations used for similar purposes. 

These conditions and limitations proposed in this Petition and the operational safety features 

of the ITX8 UAS and the 3DR Solo UAS provide substantial protection against interference with 

manned aircraft operations or with the safety of persons or property on the ground. For these 

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reasons, granting an exemption from each section of the FAR from which relief is sought would not 

adversely affect safety, and would provide a level of safety at least equal to, or greater than, that 

provided by the rule from which exemption is sought. 

5.6 Summary that can be published in Federal Register, including the rule from 

which exemption is sought, and a brief description of the nature of the 

exemption sought: 

lnspecTools proposes that the FAA use the following as the summary: 

Docket No.: FAA-2015-__ _ 

Petitioner: lnspecTools, LLC 

Sections of 14 CFR: 61.23(a) and (c), 61.101(e)(4) and (5), 61.113(a) and (b), 

61.315(a), (c)(2), and (c)(3), 91.7(a), 91.119(c), 91.121, 91.151, 91.405(a), 

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

Description of Relief Sought: Petitioner seeks an exemption to conduct small UAS 

commercial operations for inspections of wind turbines, the corresponding blades, 

and solar panels, asset risk mitigation, and/or wildlife/wilderness conservation. 

5.7 Additional information that supports request: 

lnspecTools is prepared to provide additional information that the FAA might find helpful, or 

to answer questions in response to any FAA requests. 

5.8 Request to exercise the privileges of the exemption outside the U.S.: 

lnspecTools does not request to exercise the privileges of this exemption outside the United 

States. lnspecTools plans to undertake UAS inspection operations outside of the USA, but 

understands that the requested exemption applies only to the USA, where the FAA has jurisdiction, 

and that areas outside the USA would be regulated by other entities. 

5.9 Attachments: 

There are no attachments accompanying this Petition. 

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6. CONCLUSION 

For the foregoing reasons, lnspecTools respectfully requests that the FAA grant this Petition 

for Exemption. 

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Respectfully submitted, 

E. Tazewell Ellett 

Patrick R. Rizzi 

Hogan Lovells US LLP 

COUNSELFORINSPECTOOLS