1

RED SPIDER Drone Consultants, LLC.

10409 Packer Drive

Wausau, WI. 54401

Robert E. Hughes

President/CEO

March 1, 2016

U.S. Department of Transportation

Docket Management System

1200 New Jersey Ave., SE 

Washington, D.C. 20590

Re: Exemption Request Pursuant to Section 333 of the FMRA and Part 11 of the

Federal Aviation Regulations, Seeking Exemption from 14 C.F.R. Part 21 

Subpart H; 14 C.F.R. § 45.23(b); 14 C.F.R. § 45.27; 14 C.F.R. §§ 61.113(a) and 

(b); 14 C.F.R. § 91.119(c); 14 C.F.R. § 91.121; 14 C.F.R. § 91.151(a); 14 C.F.R.

§ 91.405(a); 14 CF.R. § 91.407(a)(l); 14 C.F.R. §§ 91.409(a)(l ) and (2); 14

C.F.R. §§ 91.417(a) and (b).

Dear Sir or Madam:

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

·C:F.R. Part 11, RED SPIDER Drone Consultants, LLC. ("Petitioner" or "RED SPIDER") 

herby applies for an exemption from the listed Federal Aviation Regulations ("FARs") and any 

other necessary to allow its operation of small Unmanned Aircraft Systems ("UAS")to conduct 

roof inspections, tower inspections, real estate marketing, and agricultural areal surveys so 

long as such operations are conducted within and under the conditions outlined herein. The 

requested exemption would permit the operation of the UAS to obtain up-close images of RED 

SPIDER client policyholder’s roofs, towers and agricultural areas and perform an in-depth 

analysis of the images to determine the nature and extent of damage without placing claim 

adjusters at risk. The RED SPIDER representative will be able to share promptly with the 

claim representative and customer the report and inspection images and reduce claim payment

time.
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I. REQUEST FOR EXEMPTION TO USE UAS FOR INSPECTION OF 

INFRASTRUCTURE, REAL ESTATE AND PROPERTY MARKETING, 

SPECIAL EVENTS, SEARCH AND RESCUE, AND AGRICULTURAL 

AREAL SURVEYS

A. Overview of Request to Use UAS for Inspection of Infrastructure, 

Real Estate and Property Marketing, Special Events, Search and Rescue,

and Agricultural Areal Surveys

RED SPIDER proposes to conduct roof inspections, tower inspections, real estate and property

marketing, and agricultural areal surveys using small UAS including the DJI Phantom 3 Professional 

and the DJI Phantom 3 Standard. As described more fully below, the requested exemption would

permit the operation of small UAS under controlled conditions in airspace that is I ) limited, 

2) predetermined, and 3) controlled as to access. Operations will be limited to the customer's 

property and always occur within the line of sight of the UAS operator. The property owner will 

be notified in advance of the date and time for inspection. The customer's privacy and their 

neighbors' privacy will be fully protected. RED SPIDER's use of UAS for inspection of infrastructure, 

real estate and property marketing, special events, search and rescue, and agricultural areal surveys

does not create a hazard to users of the national airspace or the public or pose a threat to national

security. 

Grant of this request is warranted, specific to inspection of infrastructure, as use of UAS will 

improve safety for RED SPIDER's client claim representatives and customers. Currently, our 

customer’s need to physically climb onto a roof, towers or high infrastructure using ladders for 

inspection. Inspecting roofs and towers and high infrastructure is dangerous as evidenced by 

annual industry wide worker compensation claims. Each year, claim handlers throughout the 

industry are injured in falls while performing the task. By utilizing UAS, the claim handlers will 

be able to reduce their exposure to hazards and obtain accurate assessments of the roof while

remaining safely on the ground.

B. Main Public Interest Benefits of Permitting Use of UAS for Inspection of 

Infrastructure

Grant of RED SPIDER's request to use UAS for roof, tower and high infrastructure inspections is in 

the public interest. Inspection of roof, towers or high infrastructure conducted by human beings 

carries with it certain risks. Currently, customers need to physically climb onto the roof using

ladders and other safety gear to conduct inspections. Sometimes, a two-story/steep team is used, 

requiring two inspectors and special safety harnesses. The dangers of inspecting any roof, towers or 

high infrastructure include losing one's footing, having a ladder slip, and being blown off a roof 

from wind shear. A recent news article noted that fatalities rates among roofers and tower inspectors 

are the highest in the construction trades.1 In addition to safety concerns, inspecting a roof or tower 

by physically climbing on it has the potential to damage the roof. Using UAS for roof, towers or 

high infrastructure avoids all of these risks. By utilizing UAS, RED SPIDER's customer will be able 

to reduce their exposure to hazards and rapidly obtain accurate assessments of the roof, towers or 

high infrastructure while remaining safety on the ground. Faster roof, towers or high infrastructure 

assessments will result in faster identification of potential need for repairs to avoid injury to 

unsuspecting individuals and reduce the need to file claims in the event of an accident or damage to 

the structure.

1 Alexandra Berzon and Kris Hudson, Fight Erupts Over Protecting Rooftop Workers, Wall Street Journal,

Sept. 28, 2014 available at http://online.wsj.com/articles/builders-osha-square-off-on-rooftop-safety-141 1947843.
3

In addition, as described in more detail below, operation will not create a hazard to aviation or 

the public. Flights will be conducted under 200 feet AGL-avoiding interference with users of 

the national airspace system. Operation will also not create a hazard to the public, as RED 

SPIDER will only operate the UAS only over private property with the owner's consent. In 

addition, the UAS will utilize waypoints and operational means around the owner's property 

line to prevent the UAS from flying where it should not be. Finally, operation will not pose a 

threat to national security. The UAS poses no credible threat to national security due to its size, 

speed, of operation, location of operation, lack of explosive materials or flammable jet fuels,

and inability to carry a substantial external load.

II. THE FAA'S LEGAL AUTHORITY TO GRANT THIS EXEMPTION REQUEST

This exemption request will help the FAA to fulfill Congress' goal in passing Section 333 of the 

FMRA. Section 333 directs the Secretary of Transportation to consider whether certain UAS may 

operate safely in the national airspace system (NAS) before completion of the rulemaking required 

under Section 332 of the FMRA. The Secretary is required to determine which types of UAS do not 

create a hazard to users of the NAS or the public or pose a threat to national security in light of the 

UAS’s size, weight, speed, and operational capability and whether operation will occur near 

airports or populated areas and within the visual line of sight of the operator.2 The

FMRA illustrates Congress' intent to have the FAA issue exemptions and allow civil UAS, so 

long asthey operate within the necessary safety parameters.

In addition, the Federal Aviation Act expressly grants the FAA the authority to issue exemptions. 

This statutory authority by its terms includes exempting civil aircraft, as the term is defined 

under § 40101 of the Act, which includes UAS, from the requirement that all civil aircraft must 

have a current airworthiness certificate. The Administrator may grant an exemption from a 

requirement of a regulation prescribed under §§ 44701(a) or (b) or in §§ 44702-44716 of the Act

if the Administrator finds the exemption in the public interest.2

III. APPLICATION INFORMATION

The name and address of the applicant is: 

Robert E. Hughes

President/CEO

RED SPIDER Drone Consultants, LLC. 

10409 Packer Drive

Wausau, WI. 54401

houseofhughes@ymail.com

708-945-2957

2 FAA Modernization and Reform Act of 2012, Pub. L. No. 112-95, 126 Stat. 75-76 (codified as a 

Note to49 u.s.c. § 40101).

3 49 U.S.C. § 44701(t). See also 49 U.S.C. § 4471 l (a); 49 U.S.C. § 44704; 14 C.F.R. § 91.203(a)(l).
4

Regulations from which the exemption is requested:

14 C.F.R. Part 21 Subpart

H; 14 C.F.R. §45.23(b);

14 C.F.R. §45.27;

14 C.F.R. §§ 61.113(a) and (b);

14 C.F.R. §91.119(c);

14 C.F.R. §91.121;

14 C.F.R. §91.151(a);

14 C.F.R. §91.405(a);

14 C.F.R. § 91.407(a)(l);

14 C.F.R. §§ 91.409(a)(l ) and(2);

14 C.F.R. §§ 91.417(a) and (b).

IV. THEAIRCRAFTS

RED SPIDER specifically proposes to conduct UAS operations using small UAS including the

DJI Phantom 4, DJI Phantom 3 Professional and the DJI Phantom 3 Standard.

The DJI Phantom 4 is a multi-rotor aircraft with an approximate a 3.1 lbs. takeoff weight including 

batteries, propellers and standard camera. The DJI Phantom 4 carriesa 5350 mAh LiPo 4S battery, which

facilitates up to 28 minutes offlight time with standard payload. In addition, the DJI Phantom 4 has 

incorporated into its system an optical sensing system. The system is capable of constantly scans for 

obstacles in front of it, allowing it to avoid collisions by going around, over or hovering. The optical sensing 

system can detect obstacles from a range of 2–49 feet. The minimum pixel size that the obstacle sensing 

system can see is 500 pixels. The DJI Phantom 4 has amaximum cruise speed of 20 m/s.

TheDJI Phantom 3 Professional and the DJI Phantom 3 Standard are is amulti-rotor aircraft. TheDJI 

Phantom 3 Professional and the DJI Phantom 3 Standard has approximately a 2.8 lbs. takeoff weight

including batteries, propellers and standard camera. TheDJI Phantom 3 Professional and the 

DJI Phantom 3 Standard carriesa 4480 mAh LiPo 4S battery, which facilitates up to 23 minutes of

flight time with standard payload. Theycan be flown with either a radio or tablet and carries a

variety ofpayloads. The DJI Phantom 3 Professional and the DJI Phantom 3 Standard has amaximum

cruise speed of 16 m/s. They feature auto-takeoff and landing, auto go home and landing, point-of-interest 

and waypoint navigation. 
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RED SPIDER agrees that any UAS it uses for inspection of infrastructure, real estate and property

marketing, special events, search and rescue, and agricultural areal surveys will include, at minimum: 

waypoints and maximum ceiling of 200' AGL, flight programming capabilities, a flight termination 

link available to the operator to prevent a "fly away," and safe abort procedures. If the UAS loses

communications or its GPS signal, the UAS will return to a pre-determined location and land or be 

recovered in accordance with the Operations Manual. The UAS will have markings identifying the

serial number and identification (N-number) markings as large as practicable.

Further, RED SPIDER's UAS operation will comply with all manufacturer Safety Bulletins. Any UAS to 

be used will weigh less than 55 pounds and would be specifically authorized by the FAA. UAS operations

will occur only during daytime.

V. OPERATING PARAMETERS

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

characteristics and that operate with the limitations listed herein. These limitations provide for at 

least an equivalent 'or even higher level of safety to operations under the current regulatory 

structure because the proposed operations represent a safety enhancement to the already safe 

operations conducted with conventional aircraft. Further details about the aircraft and operating 

procedures are available in the Operations Manual and Training Syllabus.

The limitations and conditions to which RED SPIDER agrees to be bound when conducting 

commercial operations under an FAA issued exemption include:

A. UAS Pilot and Observer

1. UAS operations will be conducted by, at minimum, pilot and third-class medical 

certification or sports pilot’s license and a valid U.S. driver’s license.

2. All UAS operations must utilize a visual observer ("VO").

3. The pilot-in-command ("PIC") and VO must be able to communicate 

verbally at all times.

4. The PIC will be wearing a safety vest that identifies him or her asthe pilot.

5. Prior to operations, the pilot must have accumulated and logged a minimum

of 200 flight cycles, or more as required by the FAA, and 25 hours of total 

time as a UAS rotorcraft pilot. The pilot must also have accumulated and

logged prior to operations at least ten hours as a UAS pilot with a similar 

UAS type (single blade or multi-rotor). Prior documented flight experience 

that was obtained in compliance with applicable regulations may satisfy this

requirement.

a. Training, proficiency, and experience-building flights can also be 

conducted under the FAA' s grant of exemption to accomplish the required 

flight cycles and flight time.

b. During training, proficiency, and experience-building flights, all persons 

not essential for flight operations are considered nonparticipants, and the 

pilot must operate the UAS with appropriate distance from 

nonparticipants in accordance with 14

C.F.R. §91.119.
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6. RED SPIDER will require all pilots conducting UAS operations to 

provide proof of pilot and third-class medical certification or sports pilot’s 

license and a valid U.S. driver’s license.

B. Operational Parameters

1. Aircraft will not carry pilots or passengers, and aircraft will not carry 

explosive materials or flammable liquid fuels.

2. UAS must be operated within visual line of sight of the pilot at all times.

3. UAS may not be flown at ground speeds exceeding 87 knots. The UAS will 

not be operated in excess of aircraft manufacture’s recommended maximum speed.

4. Flights will be operated at an altitude of no more than 200 feet above 

ground level.

5. Each UAS operation will be completed within 18 minutes flight time or 

with 25% battery power remaining, whichever occurs first. At 20% battery

the UAS will enter a return and land sequence; at 15% it will land 

immediately.

6. UAS will not be operated over any person (other than participating RED 

SPIDER personnel) at an altitude that is hazardous to persons or property 

on the surface in the event of a UAS failure or emergency.

a. Distance from participating persons will be specified in the 

Operations Manual.

b. Operations will be conducted as far as practicable from 

non-participating persons.

7. The UAS will abort the flight in the event of unpredicted obstacles or emergencies in 

accordance with the Operations Manual.
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8. The operator must obtain an Air Traffic Organization (ATO) issued 

Certificate of Waiver or Authorization (COA) prior to conducting any 

operations under this grant of exemption.

a. This COA will also require the operator to request a Notice to 

Airmen (NOTAM) not more than 72 hours in advance, but not less 

than 48 hours prior to the operation.

9. Operations will be limited to the property of consenting RED 

SPIDER clients.

10. Petitioner will display signage notifying the public of UAS operations 

before beginning operations. Signs will be approximately 18" x 24" in 

size and will be placed in locations that will be visible from adjacent 

roadways at least 5 minutes prior to UAS operations. An area will be

marked off as the UAS "landing zone." Petitioners will also display 

signage notifying the public that UAS operation is in progress once 

operations begin.

11. Before conducting operations, the radio frequency spectrum used for 

operation and control of the UAS will comply with the FCC or other 

appropriate government oversight agency requirements.

12. The documents required under 14 C.F.R. § 91.9 must be available to the 

PIC at the Ground Control Station of the UAS any time the aircraft is 

operating. These documents must be made available to theAdministrator 

or any law enforcement official upon request.

13. The UAS must remain clear and yield the right of way to all other manned 

operations and activities at all times (including, but not limited to, ultra 

light vehicles, parachute activities, parasailing activities, hang gliders, 

etc.).

14. RED SPIDER will ensure safety to first responder aircraft and 

helicopter traffic. Upon notification from manned aircraft controllers 

or through visual identification of manned aircraft, RED SPIDER 

will immediately suspend the UAS flight until the airspace is cleared.

15. UAS operations may not be conducted during night, as defined in 14

C.F.R. § 1.1. All operations must be conducted under visual 

meteorological conditions (VMC). Flights under special visual flight rules 

(SVFR) are not authorized.

16. The UAS may not be operated by the PIC from any moving device or 

vehicle.
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17. The UAS may not be operated less than 500 feet below or less than 2,000 

feet horizontally from a cloud or when visibility is less than 3 statute miles 

from the PIC.

18. The UAS may not operate in Class B, C, or D airspace without approval 

from the FAA. The UAS may not operate within 5 nautical miles of the 

geographic center of a non-towered airport as denoted on a current FAApublished aeronautical chart unless an agreement with that airport's 

management is obtained, and the operation is conducted in accordance 

with a NOTAM as required by the Operator's COA. The letter of 

agreement with the airport management should be made available to the 

Administrator upon request.

19. Altitude information will be provided to the UAS pilot via a digitally 

encoded telemetric data feed, which downlinks from the aircraft to a 

ground-based on-screen display. The UAS may have a GPS altitude 

readout. Prior to each flight, a zero altitude initiation point will be 

established and confirmed for accuracy by the PIC.

20. Any incident, accident, or flight operation that transgresses the lateral or

vertical boundaries of the operational area as defined by the applicable COA 

must be reported to the FAA's UAS Integration Office (AFS-80) within 24 

hours. Accidents must be reported to the National Transportation Safety Board 

(NTSB) per instructions contained on the NTSB Web site: www.ntsb.gov.

Further flight operations may not be conducted until the incident, accident, or 

transgression is reviewed by AFS-80 and authorization to resume operations is 

provided.
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C. Operations Manual

1. The Operator must follow the procedures as outlined in its Operations 

Manual, which is under development at this time.

2. The Operations Manual must be maintained and made available to the 

Administrator upon request.

D. Pre-Flight Inspections and Maintenance

1. Prior to each flight, pilot will inspect UAS to ensure it is in condition for 

safe flight. If the inspection reveals a discrepancy, 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.

2. All maintenance and alterations will be properly documented in the 

aircraft records.

3. Any UAS that undergoes maintenance or alterations that affect the UAS 

operation or flight characteristics will undergo a functional flight test in 

accordance with the Operations Manual.

4. Petitioner will institute a rigorous maintenance program to ensure 

airworthiness of UAS. Operator will follow the manufacturer's UAS 

aircraft/component, maintenance, overhaul, replacement, inspection, and 

life limit requirements.

a. When unavailable, requirements will be established, 

including for the following:

1. Actuators I Servos;

11. Transmission (singlerotor);

111. Powerplant (motors);

1v. Propellers;

v. Electronic speed controller;
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v1. Batteries;

v11. Mechanical dynamic components (single rotor);

v111. Remote command and control;

1x. Ground control station (if used); and

x. Any other components as determined by the operator.

5. Operator will develop procedures to document and maintain a record of the 

UAS maintenance, preventative maintenance, alterations, status of 

replacement/overhaul component parts, and the total time in service of the 

UAS. 

VI. SPECIFIC SECTIONS OF 14 C.F.R. FROM WHICH PETITIONERS SEEK AN 

EXEMPTION

RED SPIDER requests exemption from the following Federal Aviation Regulations ("FARs") to

the extent necessary to enable the requested UAS operations for the reasons detailed below.

A. 14C.F.R. Part 21 Subpart H Airworthiness Certificates

Subpart H, entitled Airworthiness Certificates, establishes the procedural requirements for the 

issuance of airworthiness certificates. Given the size and limited operating area associated with 

the aircraft to be utilized, an exemption from Part 21 Subpart H meets the requirements of an 

equivalent level of safety under Part 11 and Section 333 of the Reform Act. The Federal

Aviation Act4 and Section 333 of the FMRA both authorize the FAA to exempt aircraft from the

requirement for an airworthiness certificate, upon consideration of the size, weight, speed, 

operational capability, and proximity to airports and populated areas of the particular UAS. In 

all cases, an analysis of these criteria demonstrates that the UAS operated without an 

airworthiness certificate, in the proposed environments and under the conditions proposed will 

be at least as safe, or safer, than a conventional aircraft (fixed wing or rotorcraft) operating with 

an airworthiness certificate without the restrictions and conditions proposed.

The DJI Phantom 3 Professional and the DJI Phantom 3 Standard UAS to be operated 

hereunder are less than 15 pounds including payload, carries neither a pilot nor passenger, 

carries no explosive materials or flammable liquid fuels, and will operate exclusively within the 

parameters stated in the Operations Manual. Unlike other civil aircraft, operations under this 

exemption will be tightly controlled and monitored by both the operator and under the 

requirements and in compliance with local public safety requirements,to provide security for 

the area of operation. The FAA will have advance notice of all operations via notices to airmen 

(NOTAMS). Finally, these UAS, as a result of their size, weight,speed,

4 49 u.s.c. § 44701(t).
12

operational capability, and operation within visual line of sight do not create a hazard to users of 

the national airspace system or the public or pose a threat to nationalsecurity.

B. 14 C.F.R. § 45.23(b) Display of marks; general; 14 C.F.R. § 45.27 Location of 

marks; non-fixed wing aircraft

Section 45.23(b) requires markings in letters not lessthan 2 inches nor more than 6 inches high 

the words such as "limited, "restricted," and "experimental," as applicable. Section 45.27 

requires that each operator of a rotorcraft must display on that rotorcraft horizontally on both 

surfaces of the cabin, fuselage, boom, or tail the marks required by §45.23.

Given the size of the UAS, two-inch lettering will not be feasible. The UAS will also have no 

entrance to the cabin, cockpit, or pilot station on which the applicable words can be placed. An 

equivalent level of safety will be achieved by having any required words displayed on the aircraft, 

as applicable, in letters of legible size, in a location where the pilot, observer, and others working 

with the UAS will see the identification. The FAA has issued exemptions to § 45.23 in Exemptions 

Nos. 10700, 8738, 10167, 10167A, and 11062. The FAA issued an exemption to

45.27 in Exemption No. 8496B.

C. 14 C.F.R. § 61.l 13(a) and (b) Private pilot/Sports pilot privileges and limitations

Sections 61.113 (a) and (b) limit private/sports pilots to non-commercial operations. Because the 

UAS will not carry a pilot or passengers, the proposed operations can achieve the equivalent level 

of safety of current operations by requiring the PIC operating the aircraft to have a private pilot’s 

license or sports pilot’s rather than a commercial pilot's license to operate this small UAS. Unlike a 

conventional aircraft that carries the pilot and passengers, the UAS is remotely controlled with no 

living thing on board. The area of operation will be controlled and restricted. The level of safety 

provided by the requirements exceeds that provided by a single individual holding a commercial 

pilot’s certificate operating a conventional aircraft. The risks associated with the operation of the 

UAS are so diminished from the level of risk associated with commercial operations contemplated 

by Part 61 when drafted, that allowing operations of the UAS as requested with a private/sports 

pilot as the PIC exceeds the present level of safety achieved by 14 C.F.R. §§ 61.113 (a) and (b). 

The FAA issued an exemption to this regulation in Exemption No. 11062.

D. 14 C.F.R. § 91.119(c) Minimum safe altitudes over congested and other areas

Section 91.119(c) establishes safe altitudes for operation of civil aircraft over areas other than 

congested areas. RED SPIDER requests relief from this section with respect to those 

participating persons, vehicles, and structures directly involved with the operations. The UAS 

will never operate at higher than 200 AGL. It will be operated in a restricted area, where 

buildings and people will not be exposed to operations without their pre-obtained consent or 

notification of UAS operations. Relief from this provision is warranted, as operations will be 

conducted with the safety provisions as previously outlined. The FAA issued an exemption to 

this regulation in Exemption No. 11062.

E. 14 C.F.R. § 91.121 Altimeter Settings
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This regulation requires each person operating an aircraft to maintain cruising altitude by reference 

to an altimeter that is set "...to the elevation of the departure airport or an appropriate altimeter 

setting available before departure." As the UAS may not have a barometric altimeter, but instead a 

GPS altitude read out, an exemption may be needed. An equivalent level of safety will be achieved 

by the operator, pursuant to the Operations Manual, confirming the altitude of the launch site shown 

on the GPS altitude indicator before flight. The FAA issued an exemption to this regulation in 

Exemption No. 11062.

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

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

conditions unless (considering wind and forecast weather conditions) there is enough fuel to fly to 

the first point of intended landing, and, assuming normal cruising speed -(1) During the day, to fly 

after that for at least 30 minutes; or (2) At night, to fly after that for at least 45minutes."

Complying with the 30 minute reserve requirement in 14C.F.R. § 91.151, would unnecessarily 

limit the length of RED SPIDER's UAS flights. The battery powering the DJI Phantom 3 

Professional and the DJI Phantom 3 Standard provides approximately 23 minutes of flight time. 

To meet the 30 minute reserve requirement in 14 C.F.R. § 91.151, UAS flights would be limited 

to approximately 18 minutes in length. Given the limitations on the UAS's proposed flight area

and the location of its proposed operations within a predetermined area, a longer time frame for

flight in daylight conditions isreasonable.

Operating the small UAS in a tightly controlled area where only personnel and property owners will be

present does not engender the type of risks that § 91.151(a) was intended to alleviate given the size

and speed of the small UAS. Additionally, limiting UAS flight minutes would reduce the utility of the 

flights for the roof and tower inspections for which the exemption will be granted. RED SPIDER 

believes that an equivalent level of safety can be achieved by limiting flights to 18 minutes or 25% of 

battery power, whichever happens first. The FAA issued an exemption to this regulation in Exemption 

No. 11062 and 10673 .

G. 14 C.F.R. § 91.405(a) Maintenance required; 14 C.F.R. § 91.407(a)(l) Operation 

after maintenance, preventive maintenance, rebuilding or alteration; 14 C.F.R. §§ 

91.409(a)(l ) and (2) Inspections; 14 C.F.R. §§ 91.417(a) and (b) Maintenance 

records

These regulations require that an aircraft operator or owner "shall have that aircraft inspected as 

prescribed in subpart E of this part and shall between required inspections, except as provided in 

paragraph (c) of this section, have discrepancies repaired as prescribed in part 43 of this chapter...," 

and others shall inspect or maintain the aircraft in compliance with Part 43.

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

sections will not apply to the Petitioner. The operator pursuant to the manufactures requirements and 

recommendations will accomplish maintenance. An equivalent level of safety will be achieved 

because these small UAS are very limited in size and will carry a small payload and operate only in 

restricted areas for limited periods of time. If mechanical issues arise, the UAS can land 

immediately and will be operating from no higher than 200 feet AGL. The operator will ensure that

the UAS isin working order prior to initiating flight, perform required
14

maintenance, and keep a log of any maintenance performed. Moreover, the operator isthe person 

most familiar with the aircraft and best suited to maintain the aircraft inan airworthy condition to 

provide the equivalent level of safety. The FAA issued an exemption to these regulations in 

Exemption No. 11062.

H. Such other relief asthe FAA deems appropriate to enable the requested operations

RED SPIDER also requests exemption from such other FARs as the FAA deems appropriate to 

enable the requested operations. If, during the effective dates of any Grant of Exemption issued 

pursuant to this Petition, the FAA issues interim or final rules for small UAS, RED SPIDER 

requests that it be relieved of the requirements of any conditions and limitations of said exemption 

and allowed to comply with any less burdensome applicable regulations that may have become

effective.

VII. SUMMARY TO BE PUBLISHED IN FEDERAL REGISTER

Petitioner: RED SPIDER Drone Consultants, LLC.

Sections of 14 C.F.R. Affected: Part 21 Subpart H; § 45.23(b); § 45.27; §§ 61.113(a) and (b); § 

91.119(c); § 91.121; § 91.151(a); § 91.405(a); § 91.407(a)(l ); §§ 91.409(a)(l ) and (2); §§

91.417(a) and (b).

Description ofRelief Sought:Petitionerseeksrelieffromtherequirements of 14C.F.R.Part21 

Subpart H;14C.F.R. §21.191(a); 14C.F.R. §45.23(b); 14C.F.R. §45.27; 14C.F.R. §§

61.113(a) and (b); 14C.F.R. § 91.119(c); 14C.F.R. § 91.121; 91.151(a); 14 C.F.R. § 91.405(a);

14 C.F.R. § 91.407(a)(l ); 14 C.F.R. §§ 91.409(a)(l ) and (2); 14 C.F.R. §§ 91.417(a) and (b) to

conduct small unmanned aircraft systems (UAS) roof inspections subject to operating procedures that 

meet or exceed those that FAA requires for similar operations.

VIII. CONCLUSION

Satisfaction of the criteria provided in Section 333 of the FMRA regarding size, weight, speed, 

operating capabilities, proximity to airports and populated areas, operation within visual line of sight, 

and national security, provide more than adequate justification for the grant of the requested 

exemption allowing operation of Petitioner's UAS for roof inspections, tower inspections, real estate 

marketing, and agricultural areal surveys. 
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NOTE:

Substantially similar exemptions have been recently granted by the FAA, including:

(1) Pelican Drones, LLC Exemption No. 11634 Regulatory Docket No. FAA–2015–0571

(2) Aero Photos Exemption No. 15019 Regulatory Docket No. FAA–2015–3681

(3) 323 Unmanned Flight Services LLC Exemption No. 15055 Regulatory Docket No. FAA–2015–

6037

(4) Matthew Dutcher Exemption No. 15002 Regulatory Docket No. FAA–2015–6113

(5) Jordan Leigh Wildlife Imagery Exemption No. 14992 Regulatory Docket No. FAA–2015–4392

(6) Drago Entertainment Inc Exemption No. 14971 Regulatory Docket No. FAA–2015–5048

(7) Drone University USA Exemption No. 14950 Regulatory Docket No. FAA–2015–3684

(8) John M Buvala â Airfox Photography Exemption No. 14973 Regulatory Docket No. FAA–

2015–5010

(9) Insight Aerial Concepts LLC Exemption No. 14960 Regulatory Docket No. FAA–2015–5451

 (10) Rod Cambridge Exemption No. 14978 Regulatory Docket No. FAA–2015–3690

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