Scott Randall

2555 Hot Springs Court

Colorado Springs, CO 80919

(405) 494-1169

email: info@pikespeakaerial.com

U.S. Department of Transportation

Docket Management System

1200 New Jersey Ave., SE

Washington, DC 20590

April 28th, 2015

RE: Exemption Request Under Section 333 of the FAA Reform Act of 2012 and Part 11 

of the Federal Aviation Regulations

Attachments: (A) S900 Pilot Operating Manual; (B) S900 User Manual; (C) S900 Preflight 

Checklist; (D) Inspire 1 Pilot Operating Manual; (E) Inspire 1 User Manual; (F) F550 User 

Manual; (G) NAZA-M Flight Controller Manual; (H) A2 Flight Controller Manual

References: 1) FAA Exemption No. 11256, Regulatory Docket No. FAA-2014-0908 in the 

 matter of petition of SkyPhilly, Inc.

 2) FAA Exemption No. 11359, Regulatory Docket No. FAA-2014-1128 in the 

 matter of petition of Celestial Imaging, LLC

 3) FAA Exemption No. 11397, Regulatory Docket No. FAA-2015-0144 in the

 matter of petition of Colorado Cartographics, LLC

 4) FAA Exemption No. 11221, Regulatory Docket No. FAA-2014-0557 in the

 matter of petition of Microcopter Professional Services, Inc.

 5) FAA Exemption No. 11336, Regulatory Docket No. FAA-2014-1056 in the

 matter of petition of Pacific Aviation, LLC

Attn: To whom it may concern

Pursuant to Section 333 of the Federal Aviation Administration (FAA) Modernization and 

Reform Act of 2012, Pub. L. No. 112-95 (2012), 126 Stat. 11 (“Section 333”) and the FAA 

general exemption authority under 49 U.S.C. section 44701(f), Pikes Peak Aerial LLC, a licensed 

business in the state of Colorado (“Petitioner”) hereby petitions for exemptions from 14 C.F.R 

Part 21, Subpart H (Airworthiness Certificates), 14 C.F.R. Part 27 (Airworthiness Standards: 

Normal Category Rotorcraft), 14 C.F.R sections 61.113(a)-(b), 91.103(b)(1), 91.119(c), 91.121, 

91.151, 91.203, 91.405(a), 91.407(a)(1), 91.409(a)(2), and 91.417(a)-(b). 

The proposed exemption, if granted, would allow the petitioner to conduct commercial operations 

of small Unmanned Aircraft Systems (“UAS”) meeting or exceeding all of the operational and 

safety requirements Congress has set forth in Section 333. An approved exemption would also 

mitigate the risk to manned aircraft carrying crew and flammable fuel since many operations that 

have traditionally required such manned aircraft can now be accomplished with a specially 

equipped UAS.

The exemptions, as requested by the petitioner Pikes Peak Aerial LLC, are similar to already 

approved exemption numbers (referenced above) 11256, 11359, 11397, 11221, and 11336 with 

respect to the services performed and the UAS platforms utilized. 
The petitioner requests these exemptions in order to perform commercial flights in the following 

areas:

• Aerial Surveying & Mapping

• Agriculture & crop surveying

• Real estate photography & videography

• Aerial filmmaking and photography

• Development, Building Site, & Pipeline inspections and monitoring

• UAS Training and Safety Operations

• Event photography and videography

• Search and Rescue Operations

• Aerial Surveillance in Fire Prevention

STATUTORY AUTHORITY

Section 333, titled “Special Rules for Certain Unmanned Aircraft Systems”, provides a

mechanism for seeking expedited FAA authorization of safe civil UAS operations in the NAS. 

Section 333(a) states that the FAA “shall determine if certain unmanned aircraft systems may

operate safely in the national airspace system before completion of the (comprehensive) plan and 

rulemaking required by section 332(b)(1) of this Act or the guidance required by section 334 of 

this Act.” In Section 332(b)(1), Congress made it clear that Section 333 provides a mechanism for 

“expedited operation authorization” if several factors are met. Petitioner meets all requirements to 

permit FAA approval of commercial UAS operations.

UNMANNED AIRCRAFT SYSTEMS (UAS)

The petitioner states that the UASs to be operated under this request are less than 55 pounds 

including the payload and flies at a speed of no more than 50 knots. The UASs carries neither a 

pilot nor passenger, carries no explosive materials or flammable liquid fuels, and operates 

exclusively within a secured area.

1. DJI S900 Multi-rotor (6-propeller hexagonal frame, carbon fiber):

a. Total weight with maximum allowable payload: 18lbs

b. Dimensions: Width: 900mm (35.43in), Height (with landing gear): 24”

c. Maximum speed: 50kts

d. Battery system (6-cell, 22.2 volt, 22,000 mAh lithium-polymer) provides 

approximately twenty two (22) minutes of flight time

e. DJI A2 Flight Controller

f. Use of First-Person View (“FPV”) for advanced flight safety; provides real-time 

video-downlink from sUAS to video monitor on transmitter.

g. Reference FAA Exemption No. 11256, Regulatory Docket No. FAA-2014-0908 

in the matter of petition of SkyPhilly, Inc. This already approved exemption 

granted permission of the DJI S900 for commercial use.

2. DJI Inspire 1 Multi-rotor (4-propeller quad frame, carbon fiber): 

a. Total weight with maximum allowable payload: 6.8lbs, 
b. Dimensions: Width: 451mm (17.75in), Height (with landing gear): 301mm 

(11.85”)

c. Maximum speed: 30kts

d. Battery system (6-cell, 22.8 volt, 5,700 mAh lithium-polymer) provides eighteen 

(18) minutes of flight time

e. DJI A2 Technology-based Flight Controller

f. Use of First-Person View (“FPV”) for advanced flight safety; provides real-time 

video-downlink from sUAS to video monitor on transmitter.

g. Reference FAA Exemption No. 11359, Regulatory Docket No. FAA-2014-1128 

in the matter of petition of Celestial Imaging, LLC. This already approved 

exemption granted permission of the DJI Inspire 1 for commercial use.

3. DJI F550 Flamewheel Multi-rotor (6-propeller hexagonal frame, plastic/metals): 

a. Total weight with maximum allowable payload: 6.5lbs,

b. Dimensions: Width: 550mm (21.65in), Height (with landing gear): 10.5”

c. Maximum speed: 30kts

d. Battery system (2x 6-cell, 22.2 volt, 10,000 maH lithium-polymer) provides 

fifteen (20) minutes of flight time

e. DJI NAZA-M V2 Flight Controller

f. Use of First-Person View (“FPV”) for advanced flight safety; provides real-time 

video-downlink from sUAS to video monitor on transmitter.

g. Reference FAA Exemption No. 11397, Regulatory Docket No. FAA-2015-0144. 

This already approved exemption granted permission of the DJI F550 for 

commercial use.

4. Tarot 690 Multi-rotor (6-propeller hexagonal frame, carbon fiber): 

a. Total weight with maximum allowable payload: 9.3lbs, 

b. Dimensions: Greatest width: 810mm (31.9in), Height (with landing gear): 14.25”

c. Maximum speed: 30kts

d. Battery system (2x 6-cell, 22.2 volt, 10,000 maH lithium-polymer) provides 

fifteen (20) minutes of flight time

e. DJI NAZA-M V2 Flight Controller

f. Use of First-Person View (“FPV”) for advanced flight safety; provides real-time 

video-downlink from sUAS to video monitor on transmitter.

g. Reference FAA Exemption No. 11221, Regulatory Docket No. FAA-2014-0557 

in the matter of petition of Microcopter Professional Services, Inc. This already 

approved exemption granted permission of the Tarot 690 for commercial use.

PILOT IN COMMAND AND OBSERVER OPERATIONS & QUALIFICATIONS

The Pilot in Command (PIC) and Visual Observer (VO) will operate all Unmanned Aircraft (UA) 

while adhering to the following:

• The UA will not be operated at a speed exceeding 87 knots (100 miles per hour) nor will 

the UA be operated at airspeeds greater than the maximum UA operating airspeed 

recommended by the aircraft manufacturer.

• The UA will be operated at an altitude of no more than 400 feet above ground level.

• The UA will be operated within Visual Line of Sight (VLOS) of the PIC at all times.

• All operations will utilize a VO. The UA will be operated within the VLOS of the PIC 

and VO at all times. The PIC will be designated before the flight and will not transfer his 
or her designation for the duration of the flight. The PIC will ensure that the VO can 

perform the duties required of the VO.

• All operating documents attached to this application will be accessible during UAS 

operations and made available to an administrator upon request.

• Any UAS that has undergone maintenance or alterations that affect the UAS operation or 

flight characteristics will undergo a functional test flight prior to conducting further 

operations. Functional test flights will only be conducted by a PIC with a VO and will 

remain at least 500 feet from other people. The functional test flight will be conducted in 

such a manner so as to not pose an undue hazard to persons and property.

• The operator will be responsible for maintain and inspecting the UAS to ensure that it is 

in a condition for safe operation.

• Prior to each flight, the PIC must conduct a pre-flight inspection and determine the UAS 

is in a condition for safe flight. If the inspection reveals a condition that affects the safe 

operation of the UAS, the aircraft will be prohibited from operating until the necessary 

maintenance has been performed and the UAS is found to be in a condition for safe 

flight.

• The operator will follow the UAS manufacturer’s maintenance, overhaul, replacement, 

inspection, and life limit requirements for the aircraft and aircraft components.

• All UAS operations will comply with all manufacturer safety bulletins.

• The Pilot in Command (PIC) will maintain a private pilot license and current FAA 

airman medical certificate or a valid U.S. driver’s license issued by the federal 

government. In addition, the PIC will maintain 40 hours cumulative flying time for the 

UAS utilized in operations. In addition, two (2) hours flying time and three (3) takeoffs 

and landings within thirty (30) days of the type of UAS utilized in operations will also be 

maintained. 

• The operator will not permit any PIC to operate unless the PIC has demonstrated the 

ability to safely operate the UAS.

• UAS operations will not be conducted during night.

• The UA will not operate within 5 nautical miles of an Airport Reference Point (ARP).

• 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.

• If the UAS loses communication or loses its GPS signal, the UA will return to a predetermined location within the private or controlled-access property.

• The PIC will abort the flight in the event of unpredicted obstacles or emergencies.

• The PIC will ensure at least a 5 minute reserve powered flight time when completing all 

flight operations.

• All operations will be conducted in accordance with an Air Traffic Organization (ATO) 

Certificate of Waiver or Authorization (COA).

• All UA operated will be identifiable by serial number and/or equivalent marking

• All documents used by the operator to ensure the safe operation and flight of the UAS 

will be available to the PIC (and administrator or any law enforcement upon request) any 

time the aircraft is operating.

• The UA will remain clear and give way to all manned aviation operations and activities at 

all times.

• The UAS will not be operated by the PIC from any moving device or vehicle.

• All flight operations will be conducted at least 500 feet from all non-participating 

persons, vessels, vehicles, and structures unless protective barriers or structures are in 

place to protect such persons or 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 to determine that it does not present an undue hazard.

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

permission from the property owner/controller or authorized representative.

• 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 within 24 hours. Accidents will also be reported to 

the National Transportation Safety Board (NTSB).

UAS PILOT IN COMMAND BACKGROUND & INTENT

Petitioner’s UAS Pilot-in-Command (PIC), and owner of Pikes Peak Aerial LLC, is Scott 

Randall. At the time of this application for exemption submission, Scott Randall is a Major in the 

United States Air Force with an approved retirement date of 30 September 2015 and 20+ years 

active duty service. He has more than 5 years of experience as an enlisted aircraft maintainer on 

B1-Bombers and KC-135 Stratotankers. Scott Randall earned his commission as an Air Force 

officer in 2000 and has since maintained his experience in the aircraft industry as a remote 

controlled aircraft enthusiast. He has logged over 1000+ hours in the current UAS platforms 

identified in this exemption request. Scott Randall is currently on track to earn his Private Pilot’s 

License in August 2015. 

With an approved Section 333 exemption, Scott Randall is planning to work closely with his 

community in Colorado Springs, CO and assist the Park and Recreational Services in much

needed aerial services for future park projects. There has also been an increasing need in fire 

prevention services due to devastating forest fires in the past two years that were responsible for 

destroying over 800 homes and a number of deaths. As a result, development of homes and key 

infrastructure has an even greater need for UAS services in the area of survey and inspection type 

work. Pikes Peak Aerial LLC is one of the very few companies in the Colorado Springs and 

Denver surrounding area specializing in professional grade UASs and aerial data capture 

capability.

CONCLUSION

Pikes Peak Aerial LLC (the petitioner) seeks an exemption pursuant to 14 C.F.R. and Section 333 

of the FAA Modernization and Reform Act (FMRA) of 2012, which will permit the safe 

operation of our UASs for commercial and business use. By granting these exemptions, the FAA 

Administrator will be fulfilling the Congressional mandate of the FMRA while also providing a 

community critical UAS services and resources necessary for its future growth and development. 

The petitioner respectfully requests that the Administrator grants these exemptions under Section 

333.

Sincerely,

Scott Randall

Pikes Peak Aerial LLC

2555 Hot Springs Ct.

Colorado Springs, CO 80919
Exemption Requests and Equivalent Level of Safety:

Section 61.113(a) and (b) prescribes that—

(a) no person who holds a private pilot certificate may act as a 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

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

Section 91.103 prescribes, in pertinent part that each pilot in command shall, before beginning a 

flight, become familiar with all available information concerning that flight, to include—

(a) For a flight under IFR or a flight not in the vicinity of an airport, weather reports and 

forecasts, fuel requirements, alternatives available if the planned flight cannot be 

completed, and any known traffic delays of which the pilot in command has been advised 

by ATC;

(b) For any flight, runway lengths at airports of intended use, and the following takeoff 

and landing distance information:

(1) For civil aircraft for which an approved Airplane or Rotorcraft Flight Manual 

containing takeoff and landing distance data is required, the takeoff and landing 

distance data contained therein;

(2) For civil aircraft other than those specified in paragraph (b)(1) of this section, 

other reliable information appropriate to the aircraft, relating to aircraft 

performance under expected values of airport elevation and runway slope, 

aircraft gross weight, and wind and temperature.

Section 91.119 prescribes that, except when necessary for takeoff or landing, no person may 

operate an aircraft below the following altitudes: “Over other than congested areas. An altitude 

of 500 feet above the surface, except over open water or sparsely populated areas. In those cases, 

the aircraft may not be operated closer than 500 feet to any person, vessel, vehicle, or structure.”

Section 91.121 requires, in pertinent part, 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.”

Section 91.151(a) prescribes that 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.

Section 91.203 prohibits, in subpart (a), any person from operating a civil aircraft unless it has 

within it (1) an appropriate and current airworthiness certificate; and (2) an effective U.S. 
registration certificate issued to its owner or, for operation within the United States, the second 

copy of the Aircraft Registration Application as provided for in § 47.31(c). Section 91.203 

prescribes, in subpart (b), that no person may operate a civil aircraft unless an airworthiness 

certificate or a special flight authorization issued under § 91.715 legible to passengers or crew is 

displayed at the cabin or cockpit entrance.

Section 91.405(a) requires, in pertinent part, that an aircraft operator or owner shall have that 

aircraft inspected as prescribed in subpart E of the same part and shall, between required 

inspections, except as provided in paragraph (c) of the same section, have discrepancies repaired 

as prescribed in part 43 of the chapter.

Section 91.407(a)(1) prohibits, in pertinent part, any person from operating an aircraft that has 

undergone maintenance, preventive maintenance, rebuilding, or alteration unless it has been 

approved for return to service by a person authorized under § 43.7 of the same chapter.

Section 91.409(a)(2) prescribes, in pertinent part, that no person may operate an aircraft unless, 

within the preceding 12 calendar months, it has had an inspection for the issuance of an 

airworthiness certificate in accordance with part 21 of this chapter.

Section 91.417(a) and (b) prescribes, in pertinent part, that—

(a) 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 100-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

(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:

(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.

The petitioner will execute according to the attached user manual, operating manuals, and 

included checklists.