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UNITED STATES OF AMERICA 

DEPARTMENT OF TRANSPORTATION 

FEDERAL AVIATION ADMINISTRATION

DOCKET MANAGEMENT SYSTEM

1200 NEW JERSEY AVE., SE

WASHINGTON, DC 20590

IN THE MATTER OF THE PETITION FOR EXEMPTION OF: 

S-E-A, Limited.

FOR AN EXEMPTION SEEKING RELIEF FROM 

THE REQUIREMENTS OF THE FAA REFORM ACT AND 

PART 11 OF THE FEDERAL AVIATION REGULATIONS FROM

TITLE 14 OF THE CODE OF FEDERAL REGULATIONS 

SECTIONS C.F.R. §§ 61.113 (a) & (b); 91.7(a); 91.119 (c); 91.121; 91.151(a); 

91.405 (a); 91.407(a) (1); 91.409 (a) (2); 91.417 (a) & (b).

CONCERNING COMMERCIAL OPERATION OF UNMANNED AIRCRAFT SYSTEMS

PURSUANT TO SECTION 333 OF THE FAA MODERNIZATION 

AND REFORM ACT OF 2012 (PUBLIC LAW 112-95)

Submitted	on	August	28, 2015

S-E-A,	Limited.

7349	Worthington	Galena	Road

Columbus,	OH	43085

S-E-A,	LTD’s	Consultant

Gowdy	Brothers	Aerospace,	LLC

8170	Old	Carriage	Court	N.	Suite	#200

Shakopee,	MN	55379

www.GowdyBrothersAerospace.com

Info@GowdyBrothers.com
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Table of Contents

GLOSSARY	OF	ABBREVIATIONS...........................................................................................3

INTRODUCTION	AND	INTERESTS	OF	THE	PETITIONER..............................................4

Executive	Summary .................................................................................................................4

Expeditious	Summary	Grant	Approval	Request......................................................................4

Description	of	Type,	Make	and	Models	of	sUAV/UAS	Requested:.............................................5

Commercial	(Mission,	Operation)	Purpose:........................................................................................5

Regulations	from	which	the	Exemption	Relief	is	requested:.......................................................6

The	name	and	address	of	the	Petitioner: .............................................................................................7

Background...........................................................................................................................................7

The	S-E-A	Difference.....................................................................................................................................7

Commitment	to	Safety..................................................................................................................................8

Expertise	&	Experience................................................................................................................................8

S-E-A,	LTD	Applicable	Uses........................................................................................................................8

Visualization	(Models,	Scenes,	Mapping,	Photogrammetry)........................................................8

Hail	Damage	Evaluations .........................................................................................................................10

Storm................................................................................................................................................................10

Terrestrial	Mapping...................................................................................................................................10

Accident	Reconstruction..........................................................................................................................11

Fire	Investigations......................................................................................................................................11

The	Exemption	Request ...................................................................................................... 12

Operator	Requirements ................................................................................................................ 14

Aircraft	and	Equivalent	Level	of	Safety.................................................................................... 16

Specific	Uses	Public	Benefits ....................................................................................................... 21

Equivalent	Level	of	Safety............................................................................................................. 22

14	C.F.R.	§	91.7(a):	Civil	aircraft	airworthiness..............................................................................23

14	C.F.R.	§91.119:	Minimum	safe	altitudes ......................................................................................23

14	C.F.R.	§91.121	Altimeter	Settings...................................................................................................24

14	C.F.R.	§	91.151(a):	Fuel	Requirements	for	Flight	in	VFR	Conditions ..............................24

14	C.F.R.	§91.405	(a);	91.407	(a)	(1);	91.409(a)	(2);	91.417(a)	&	(b):	Maintenance	

Inspections.....................................................................................................................................................25

Federal	Register	Publication............................................................................................. 26

Privacy	and	National	Security........................................................................................... 26

Summary................................................................................................................................... 26

APPENDIX	A	- EXEMPTION	PATTERN....................................................................................... 29

APPENDIX	B	- TECHNICAL	MANUALS	AND	SPECIFICATIONS............................................ 30

APPENDIX	C	- COMMERCIAL	(MISSION/OPERATION)	PURPOSE	- FAA	PREVIOUS	

APPROVED	EXEMPTION	NUMBERS........................................................................................... 31

APPENDIX	D	- EQUIPMENT	- FAA	PREVIOUS	APPROVED	EXEMPTION	NUMBERS.... 32

APPENDIX	E	- EXEMPTION	14	C.F.R	- FAA	PREVIOUS	APPROVED	EXEMPTION	

NUMBERS............................................................................................................................................ 33

APPENDIX	F	- MONTHLY	MAINTENANCE	AND	REPAIR	LOG............................................. 34

APPENDIX	G	–FLIGHT	OPERATIONS	MANUAL	VERSION	1.0............................................. 35
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GLOSSARY OF ABBREVIATIONS

AGL Above	Ground	Level

AOI Area	of	Interest

ATC Air	Traffic	Control

ATO Air	Traffic	Organization

AV Aerial	Vehicle

CFR Code	of	Federal	Regulations

COA Certificate	of	Authorization

FAA Federal	Aviation	Administration

FAR Federal	Aviation	Regulation

GCS Ground	Control	Station

GPS Global	Positioning	System

LOL Loss	of	Link

NAS National	Airspace	System

NOTAM Notice	To	Airman

PIC Pilot	In	Command

Section	333 FAA	Modernization	and	Reform	Act	of	2012	(FMRA)	Section	333

SO Safety	Observer

SOP Standard	Operating	Procedures

sUAS Small	Unmanned	Aircraft	System

sUAV Small	Unmanned	Aircraft	Vehicle

UA Unmanned	Aircraft

UAS Unmanned	Aircraft	System

UAV Unmanned	Aircraft	Vehicle

VFR Visual	Flight	Rules

VLOS Visual	Line	of	Site

VMC Visual	Meteorological	Conditions

VTOL Vertical	Take-Off	and	Landing
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INTRODUCTION AND INTERESTS OF THE PETITIONER

Dear	Sir	or	Madam:

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

“Reform	Act”)	and	14	C.F.R.	Part	11,	S-E-A,	Limited.,	(“S-E-A,	LTD”)	Operator	of	Small	

Unmanned	 Aircraft	 Systems	 (“sUASs”)	 equipped	 to	 offer	 on-demand	 commercial	

UAS	 operations	 for	 a	 host	 of	 industries	 and	 applications and	 to	 perform	 the	

purposes	 listed	 below, hereby	 applies	 for	 an	 exemption	 from	 the	 listed	 Federal	

Aviation	Regulations	(“FARs”)	to	allow	commercial	operation	of	its	sUAVs/UASs,	so	

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

herein	or	as	may	be	established	by	the	FAA	in	an	exemption	granted	under	either	

Section	333	or Section	49	U.S.C.	§44701(f)	

As	 described	 more	 fully	 below,	 the	 requested	 exemption	 would	 permit	 the	

operation	 of	 UASs under	 controlled	 conditions	 in	 airspace	 that	 is	 1)	 limited;	 2)	

predetermined;	and	3)	would	provide	safety	enhancements	in	the	fields	in	which	it	

will	 operate,	 which	 now	 depend	 upon	 conventional	 aircraft	 or	 humans	 climbing	

high	 on	 dangerous	 structures,	 walking	 in	 insect	 laden	 swamps,	 and	 working	

adjacent	to	treacherous	infrastructure. Approval	 of	this	 exemption	would	thereby	

enhance	 safety	 and	 fulfill	 the	 Secretary	 of	 Transportation’s	 (the	 FAA	

Administrator’s)	responsibilities	to	“... establish	requirements	for	the	safe	operation	

of	 such	 aircraft	 systems	 in	 the	 national	 airspace	 system.”	 Section	 333(c)	 of	 the	

Reform	Act.1

Executive Summary

Expeditious Summary Grant Approval Request

The	 petitioner	 requests	 the	 agency	 issue	 a	 summary	 grant	 process	 for	 this	

application.	Petitioner	has	provided	in	a	confidential	document	attachment	labeled	

as	petitioner	proprietary	information,	specific	exemption	numbers	whereby	the	FAA	

has	 already	 granted	 a	 previous	 exemption	 similar	 or	 identical	 to	 each	 and	 every	

request,	herein.	

For	the	FAA’s	benefit,	Petitioner’s	Consultant,	Gowdy	Brothers	Aerospace,	LLC,	has	

researched,	 categorized	 and	 arranged	 all	 631	 exemptions	 granted	 as	 of	 June	 23,	

																																																							

1		S-E-A,	LTD	relies	upon	the	following	exemptions	where	specific	reference	to	an	

exemption	is	not	provided:	Exemptions	11062	thru	11067,	11080,	11109	through	

11112,	11114,	11213,	11062	and	as	recent	as	11857.
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2015	 into	 a	 usable	 searchable	 database,	 based	 upon	 the	 following	 criteria:	 date	

submitted,	 date	 grant	 issued,	 time	 to	 petition	 grant,	 petitioner,	 petitioner’s	 state,	

exemption	 number,	 sUAV	 equipment	 type,	 grant	 purpose	 (mission/operation),

along	with	other	supporting	data.		

Petitioner	 has	 identified	 four	 previous	 approved	 exemptions for	 each	 of	 the	

Petitioners	FAA	submission	requests:

 Commercial	(mission/operation)	purposes;

 Type	of	sUAV’s	(UAS);

 Title	14	Exemptions	(exemption	pattern	referenced	in	appendix	A)2

Description of Type, Make and Models of sUAV/UAS Requested:

The	petitioner	is	seeking	an	exemption	to	commercially	operate	sUAV’s	makes	and	

modes	as	follows:	

DJI	- Phantom	2,	DJI	- Phantom	3,	DJI	- Inspire	1,	DJI	– Spreading	Wings	S800,	DJI	–

Spreading	Wings	S900,	DJI	– Spreading	Wings	S1000,	DJI	– Matrics 100,	Cinestar	8	

Octo,	Altavian	Nova	F6500,	Blade	350	QX3,	AgEagle,	3DRobotics	X8,	3DRobotics	Iris,	

3DRobotics	Solo,	SenseFly	eBee,	Yuneec	Q500	Typhon,	DraganFlyer	X4-ES,	Trimble	

UX5,	Microdrones	MD4.

Each	 separately	 weighs	 55	 lbs.	 or	 less,	 with	 imaging	 payload	 and	 applicable	

equipment.

Equipment	 operation	manuals	for	 each	 sUAV	 are	 included	for	 your	 reference	 and	

are	considered	confidential	information	for each	respective	company’s UAS	and	are	

affixed	separately	in	these	documents labeled Appendix.

Commercial (Mission, Operation) Purpose: 

This	exemption	 request, once	granted	would	allow	the	petitioner	to	operate	 small	

unmanned	 aerial	 vehicles (sUAVs),	 unmanned	 aircraft	 systems (UASs)	to	 conduct	

bridge	 Inspections,	 flare	 stack	 inspection,	 utility-power	 generation	 system	

inspections	 and	 patrolling,	 aerial	 inspection,	 vehicle	 and	 roadway	 inspections,	

photography	 and	 videography	 of	 residential	 and	 commercial	 real	 estate,	 aerial	

																																																							

2 Petitioner	 submits	the	Appendix	 and	 Manuals	 marked	“CONFIDENTIAL,”	 as	they	

contain	 proprietary	 confidential	 business	 information	 that	 is	 not	 released	 to	 the	

public	and	is	protected	under	the	Freedom	of	Information	Act	5	USC	§552	et.	seq.	5	

Reform	Act	Section	333	(b).	
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inspection,	photography	and	videography	of	utility	infrastructure	including	but	not	

limited	to	electrical	power	lines,	wind	turbines	and	cell	towers,	pipeline	inspection	

and	patrolling,	filmmaking,	cinematography,	and	videography,	precision	agriculture	

with on	 board	 sensors,	wildlife	 and	 forestry	 monitoring and	 mosquito	 and	 insect	

control, aerial	surveying,	construction	site	inspection	and	monitoring,	public	entity	

support	 operations,	 Aerial	 imaging	 for	 safety,	 monitoring	 and	 comparing	 work	

efforts	 and	 completion	 percentages,	 and	 security	 of	 controlled	 environment	 of	

various	 sites,	 aerial	 video	 and	 photography	 for	 public	 and	 private	 use	 including	

television,	 public	 events,	 and	 cinematography	 live	 feed	 and	 live	 newsgathering,	

training	 to	 persons	 individually	 or	 belonging	 to	 both	 private	 and	 public	

organizations	to	increase	awareness	and	improve	safety	for	current	and	future	UAS	

operations	 within	 the	 NAS,	 special	 events:	 including	 high	 schools, colleges,	

professional	 sports,	 open	 air	 events	 and	 fairs,	 research,	 risk	 management	 and	

assessment,	 surface	 mining,	 disaster	 and	 catastrophe	 events, aerial	 imagery	 and	

videos	in	conjunction with	 accident	response	and	evidence	documentation.

Regulations from which the Exemption Relief is requested:

14	C.F.R.	§	61.113	(a)	&	(b)

14	C.F.R.	§	61.133(a)

14	C.F.R.	§	91.7(a)

14	C.F.	R.§	91.119

14	C.F.R.	§	91.121

14	C.F.R.	§	91.151	(a)

14	C.F.R.	§	91.405	(a)

14	C.F.R.	§	407	(a)	(1)

14	C.F.R.	§	409	(a)	(2)

14	C.F.R.	§	417	(a)	&	(b)

See	Appendix	E
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The name and address of the Petitioner:

S-E-A,	Limited.

Attn:	Ronny	Wahba,	P.E.

Mechanical	Engineer

795	Cromwell	Park	Drive,	Suite	N

Glen	Burnie,	MD	21061

800.635.9507

Please	direct	any	question	or	comment	regarding	this	petition	to	Petitioners	

Consultant:	Gowdy	Brothers	Aerospace,	LLC.	

8170	Old	Carriage	Court	N.,	Suite	#200

Shakopee,	MN	55379

www.GowdyBrothersAerospace.com

Info@GowdyBrothers.com

Background

The	 Petitioner, S-E-A,	 Ltd.	 is	 a	 recognized	 worldwide	 leader	 in	 forensic	 analysis,

research	 and	 testing.	 A	 full-time,	 court-qualified	 staff	 provides	 a	 wide	 range	 of	

services	to	reveal	the	cause	of	failures—or	to	mitigate	the	risk	of	them	happening	in	

the	first	place.

Biomechanical, civil, electrical, material and	mechanical engineers, fire	

investigators, chemists and	industrial interact	in	a	multi-disciplined	environment	to	

provide	thorough	and	independent	analyses.

The S-E-A Difference

Since	its	inception	in	1970,	S-E-A	has	continued	to	grow	each	and	every	year.	S-E-A’s

accumulation of	 experience	 and	 expertise	 coupled	 with	 access	 to	 the	 latest	

technology—some	of	which	was created	 and	developed	by	S-E-A—have	made	the

staff	and	facilities	among	the	most	sophisticated	in	the	world.

From	S-E-A’s Research	Center to	full-service chemical	laboratory;	from	S-E-A’s Roll	

Simulator to 3D	 laser	 scanners —the professionals	 have	 the	 technologies	 they	

require	 in	 order	 to	 reveal	 the	 cause	 of	 some	 of	 the	 most	 complex	 failures	

imaginable.

With ten	offices,	a research	center and	over	two-hundred	professionals,	S-E-A	is	able	

to	provide	immediate	response	to	their clients'	needs	regardless	of	location.	
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Commitment to Safety

As	 part	 of	 its	 commitment	to	 safety	 and	 innovation,	S-E-A,	 LTD is	 asking	 for	this

exemption	in	part,	to	reduce	the	risk	of	injury	to	its	employees	and	contractors	who	

participate	 in	 the proposed	 activities	 the	 petitioner	 requests,	 including	 but	 not	

limited	to	damage	to	agriculture,	natural	habitat,	land,	vehicles,	roadways,	buildings	

and	other	structures	within	the	United States.	

Expertise & Experience

S-E-A,	 LTD,	 due	 to	 the	 company’s vast	 professional experience including	

professional	engineers	and	certified	safety	professionals, is	extremely	qualified	and	

is	considered	an	up	and	coming	 subject	matter	expert	in	UAS’ of	all	types,	models	

and	makes.	

S-E-A, LTD Applicable Uses 

UASs will	assist	and	offer	increased	safety	and	capabilities	for	nearly	all	engineering	

disciplines,	S-E-A’s visualization	 department,	 and	S-E-A’s marketing	 staff. Specific	

examples	of	use	include:

Visualization (Models, Scenes, Mapping, Photogrammetry)

UASs would	 serve	to	provide	 videos	 and	photographs,	that	 could	not	be	obtained	

with	 conventional	 methods,	 to	 our	 visualization	 department	 and	 engineers	 for	

geometric	 analysis. Structure	 From	 Motion	 (SFM) technology allow	 3D	 models	

to be	constructed	from	photographs	of	an	object. These	capabilities,	especially	for	

environments,	would	compliment	models	built	from	scan	data	as	well,	or	for	autobuilding	 realistic	 backdrops	for	 animations. These	 models	 of	 environments	 could	

also	 be	 used	 to	 construct	 3D	 terrains	 of	 roadways,	 buildings,	 and	 even	 indoor	

facilities	 for	 use	 with	 simulation	 programs	 such	 as	Human,	 Vehicle,	 Environment	

(HVE) for	increased	analytical	detail	and	accuracy. Examples	of	3D	models	created	

through	 the	 use	 of	 drone	 captured	 images	 and	 SFM	 can	 be	 seen	 on	 YouTube,	

including	 the	 following	 video	 published	 by	

Autodesk: https://www.youtube.com/watch?v=5lQVH3hSh0c. Screen	 shots	 from	

the	this	video	are	shown	below.	
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Drone	in	flight

3D	Model

Drone	in	flight
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3D	Model

Hail Damage Evaluations

Clients	 have	 asked	 repeatedly	 about	 introducing	 technology	 (and	 the	 associated	

costs)	for	hail	damage	evaluations. Typically,	a	large	commercial	roof	is	“sampled”	

for	 detailed	 documentation	 of	 hail	 strikes	 to	 extrapolate	 out	 percentage	 of	 roof	

and/or	extent	of	hail	damage. High	resolution	video	and/or	photography	captured	

via	UAs may	 provide	for	 higher	 level	 detail	 and	 improved	 client	 deliverables	 and	

preferred	services	only	accessible	by	UASs	with	increased	safety.

Storm

High	definition	photos	/	video	of	subject	property	from	“bird’s	eye”	view	will	help	

on	 large	 loss	 storm	 damage	 claims	 to	 better	 communicate	 extent	 of	 structural	

damage	to	roof	assembly	and/or	extent	of	damage	to	roof	finish. The	same	type	of	

photos	and	video	or	surrounding	properties,	to	be	captured	from	insured’s	property	

will	highlight	similarity	and/or	differences	in	damage	profiles	of	subject	property	to	

adjacent	 assets. This	 can	help	provide	more	 affirmative	 commentary	on	localized	

wind	forces	experienced	at	subject	properties	during	a	storm.

Terrestrial Mapping

Use	 of	 123D	 Catch	 and	 interval	 time	 photos	 taken	 from	 drone-mounted	 camera	

would	 allow	 for	 terrestrial	 mapping	 and	 creating	 models	 of	 large	 areas	 of	

terrain. Output	 can	 create	 a	 meshed	 surface	 of	 terrain,	 which	 can	 then	 have	 a	

hydrological	 model	 (storm	 water	 watershed	 model)	 created	 for	 comparison	 to	

design	(as-built	versus	design	versus	maintenance)	for	storm-water	 runoff	 related	

construction	 defect	 claims. These	 types	 of	 claims	 are	 prevalent	 around	 roadway	

construction	sites,	land	development	sites,	water	retention	ponds,	etc.
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Accident Reconstruction

Documenting	 roadway	 evidence	 and	 relative	 positions	 of	 accident	 site	 points	 of	

interest	 (Tire	 marks,	 vehicle	 final	 rest	 positions,	 point	 of	 impact,	 street	 lights,	

roadway	dimensions,	roadway	curvature,	etc.). Top	view	of	vehicles	establish	crush	

patterns	and	dimensions as	well	as	fill	out	scan	data which	usually	does	not	safely	

capture	 to	 the	 tops	 of	 tractor-trailers,	 construction	 equipment,	 and	 other	 large	

vehicles.

Fire Investigations

Large	fire	scenes	typically	required	low-level	planes	to	take	aerial	photos following	

a	fire	in	order	to	gather	aerial	data. UASs would	eliminate	the	need	to	subcontract	

this	service	and	allow	a process	for	immediate	deployment and	reduced	air traffic	

from	full	sized	aircraft.
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The Exemption Request

S-E-A,	 LTD proposes the	 use	 of	 the	 sUAVs	 will	 be	 for capture	 of	 high	 resolution	

imagery	and	video	of	residential	or	commercial	applications	and	purposes	to	a	level	

of	 quality	 that	 allows	 the	 Petitioner	 to	 use	 the	 imagery	 to	 identify,	 record,	

memorialize	events	and	objects	according	to	the	purposes	noted.	

The	 imagery	 and	 video	 will	 be	 used	 to	 identify	 the	 condition	 of	 landscapes,	

agriculture,	events,	disasters	and	infrastructure	to	conduct	bridge	inspections,	flare	

stack	inspection,	utility-power	generation	system	inspections	and	patrolling,	aerial	

inspection,	photography	and	videography	of	residential	and	commercial	real	estate,	

aerial	inspection,	vehicle	and	roadway	inspections,	photography	and	videography	of	

utility	 infrastructure	 including	 but	 not	 limited	 to	 electrical	 power	 lines,	 wind	

turbines	 and	 cell	 towers,	 pipeline	 inspection	 and	 patrolling,	 filmmaking,	

cinematography,	 and	 videography,	 precision	 agriculture	 with	 on	 board	 sensors,	

wildlife	and	forestry	monitoring and	mosquito	and	insect	control, aerial	surveying,	

construction	site	inspection	and	monitoring,	public	entity	support	operations,	aerial	

imaging	 for	 safety,	 monitoring	 and	 comparing	 work	 efforts	 and	 completion	

percentages,	 and	 security	 of	 controlled	 environment	 of	 various	 sites,	 aerial	 video	

and	photography	for	public	and	private	use	including	television,	public	events,	and	

cinematography	live	feed	and	live	newsgathering,	training	to	persons	individually	or	

belonging	 to	 both	 private	 and	 public	 organizations	 to	 increase	 awareness	 and	

improve	 safety	 for	 current	 and	 future	 UAS	 operations	 within	 the	 NAS,	 special	

events:	 including	 high	 schools,	 colleges,	 professional	 sports,	 open	 air	 events	 and	

fairs research,	risk	management	and	assessment,	,	surface	mining,	closed	set	filming,	

disaster	 and	 catastrophe	 events,	 aerial	 imagery	 and	 videos	 in	 conjunction with		

accident	response	and	evidence	documentation.

The	UASs will	be	operated	by	a	S-E-A,	LTD and	or	contracting	operators on	occasion	

to	capture	high-resolution	imagery/video	of	large	structures	(wide	and	tall)	such	as	

warehouses,	 high	 rise buildings,	 bridges,	 and	 construction	 sites,	 as	well	 as	“birds	

eye”	views	of	fire	and	explosion sites. Given	the	small	size	of	the sUAV’s	involved,	no	

more	than	55 lbs.,	majority	of	the	speed	of	operation	be	between	5-15	mph and	the	

restricted	environment	within	which	they	will	operate,	the	Petitioner falls squarely	

within	 that	 zone	 of	 safety	 (an	 equivalent	 level	 of	 safety)	 in	 which	 Congress	

envisioned that	the	FAA	must,	by	exemption,	allow	commercial	operations	of	UASs	

to	commence immediately.

This	exemption	application	is	submitted	to	fulfill	Congress’	express	goal	in	passing

Sections	 333(a)	 through	(c)	 of	 the	 Reform	 Act.	 This	 law	 directs	 the	 Secretary	 of	

Transportation to	 consider	 whether	 certain	 unmanned	 aircraft	 systems	 may	

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

rulemaking	 required	 under	 Section	 332	 of	 the Reform	 Act.	 In	 making	 this	

determination,	the	Secretary	is	 required	to	determine	which	types	of UASs	do	not	
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create	a	hazard	to	users	of	the	NAS	or	the	public	or	pose a	threat	to	national security	

in	light	of	the	following:

 The	UAS’ size,	weight,	speed,	and	operational	capability;

 Operation	of	the	UAS	in	close	proximity	to	airports	and	populated	areas;	and

 Operation	of	the	UAS	within	visual	line	of	sight	of	the	Operator.

Reform	Act	 §	 333	(a).	 Lastly,	 if	the	Secretary	 determines	that	 such	 vehicles	“may	

operate safely	 in	 the	 national	 airspace	 system,	 the	 Secretary	 shall	 establish	

requirements	for	the	safe operation	of	such	aircraft	in	the	national	airspace	system.”	

Id.	§333(c)	(emphasis	added).3

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: The	Administrator	 may	 grant	 an	

exemption	from	a	 requirement	of	a	 regulation prescribed	under	 subsection	(a)	or	

(b)	of	this	section	or	any	of	sections 44702-44716	of	this	title	if	the	Administrator	

finds	the	 exemption	is	in	the public	interest. 49	U.S.C.	 §44701(f).	See	 also	49 USC	

§44711(a);	 49	 USC	 §44704;	 14	 CFR	 §91.203(a)(1) This	 authority	 to	 grant	

exemptions	reaches	such	issues	as	authorization	of	commercial operation	of	aircraft	

without	an	FAA	issued	pilot’s	license.

S-E-A,	LTD in	filing	this	application	is	requesting	that the	FAA	combine	the	grant	of

the	Section	333	exemption	with	a	standard	Certificate	of	Operation	(COA)	that	will	

allow commercial	operations	of	its	S-E-A,	LTD’ sUAVs without	the	necessity	of	filing	

for	 a	 COA	 for	 each flight,	 unless	 such	 flight	 is	 to	 be	 conducted	 in	 an	 area	 not	

approved	 in	the	 exemption. Compliance	with	the	 conditions	 agreed	to	 herein	 and	

that	 may	 be	 imposed	 by	 the	 FAA,	 as	 set forth	 in	 prior	 Section	 333	 exemptions,	

provide	the	separation	needed	from	other	aircraft.

In	addition,	given	that	all	operations	will	be	conducted	below	400	AGL	feet	and	no	

closer than	5	nautical	miles	of	the	geographic	center	of	an	airport	as	denoted	on	a	

current	 FAA published aeronautical	 chart,	 unless	 a	 letter	 of	 agreement	 with	 that	

airport’s	 management	 is obtained, S-E-A,	 LTD requests	 that	 operations	 over	

congested	 or	 densely	 populated	 areas	 be allowed.	The	new	Phantom	 3 sUAV’s	 do

have	GPS	geo-fencing,	it	will	operate	at	a	very	low	altitude,	within confined	areas,	at	

low	 speed	 and	 weighs	 no	 more	 than 55 lbs.	Such	 operations	 will	 only	 be undertaken	with	the	 approval	 of	the	 land	 or	 home	 owner,	 as	 set	forth	 herein,	 and	will	

comply with	 the	 requirements	 that	 operations	 be	 no	 closer	 than	 500	 feet	 to	 the	

																																																							

5 Applicant	interprets	this	provision	to	place	a	duty	on	the	Administrator	to	not	only	

process	applications	for	exemptions	under	section	333,	but	for	the	Administrator	to	

craft	conditions	for	the	safe	operation	of	the	UAS,	if	it	should	be	determined	that	the	

conditions	set	forth	herein do	not	fulfill	the	statutory	requirements	for	approval.
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adjacent	building	unless the	land	owner	has	provided	permission,	and the	Operator	

has	made	a	safety	assessment	of the	risk	from	such	operations.	

Operator Requirements

Given	the	sUAVs proposed	by	S-E-A,	LTD,	Operators	should	not	be	required	to	hold	a

sport pilot	 license.	 S-E-A,	 LTD believes	 that	 1)	 the	 operator,	 instead	 of	

understanding	how to	operate	a	passenger	carrying	aircraft,	should	have	knowledge	

and	 experience	that	 enables the	 safe	 operation	 of	 a	 small,	 remotely	 piloted	 sUAV	

should	understand	airspace	 restrictions and know	how	to	ensure	 separation	from	

other	 aircraft	 as	 well	 as	 non-participants	 and	 property;	 2)	 the sUAV has	 built-in	

technical	capabilities	that	limit	the	potential	for	unsafe	operation	and 3)	there	are	

other	 security	 screening	 mechanisms	 already	 in	 existence	 that	 S-E-A,	 LTD will

utilize	 to	 ensure	 the operators	 are	 acting	 consistently	 with	 national	 security	

interests.	

Given	 the	 sUAV safety	 features	 outlined	 below,	 S-E-A,	 LTD proposes	 that	 its

operations	 under	 this	 Exemption	 request	 should	 not	 be	 required	 to	 hold a	

commercial	 or	 sport pilot	 certification.	 Instead,	 Operators	 should	 be	 required	to:

have	successfully	completed,	at	a	minimum,	FAA	sport pilot	ground	instruction	and

passed	the	FAA	Sport Pilot	written	examination	or	FAA-recognized	equivalents;	or	

have completed	S-E-A,	LTD’ training	program	for	operation	of	the	UAS.

S-E-A,	LTD notes	that	1)	the	FAA	has	found	that	safety factors	permitted	operation	

of	sUAVs	by	Operators	with	these	qualifications	in	the	case	of	operations	pursuant	

to	 public	 COAs when	 the	 mandatory	 operating	 conditions	 specified	 above	 were	

present; and	 2)	 that	 the	 Notice of	 Proposed	 Rulemaking	 entitled	 Operation	 and	

Certification	of	Small	Unmanned	Aircraft Systems,	80	F.R.	9544	(February	23,	2015)	

(“NPRM”),	does	not	require	the	operator	to	hold	a sport pilot	license	or	a	third	class	

medical.

Advanced	sUAVs have	a	navigation	and	control	system	and	auto-pilot	that	allows it	

to execute	 very	 accurate	 pre-programed	flights.	 Flights	 are	 pre-programmed	with	

GPS	waypoint	to	 establish	 perimeters	 beyond	which	the	 aircraft	will	 not	 operate.

Flights	under	auto-pilot	are not	directed	by	positive	manual	input,	but	through	preprogrammed	flight	 parameters	that	 are executed	 by	the	 auto-pilot.	In	the	 case	 of	

unplanned	events,	the	Operator	inputs	preprogrammed evasive	maneuvers	from	the	

control	 unit,	 and	 the	 autopilot	 executes	 those maneuvers.	 Pre-programmed	

Operator	interventions	include:	initiation	of	holding	at	present position;	suspension	

of	 mission;	 fly	 back	 to	 launch	 point;	 abort	 mission	 and	 land	 immediately; and	

emergency	 power	 cut	 off	 and	 land	 (flight	 termination	 system). Additional	

automated	 safety	functions	and	 safety	enhancing	features	of	the	Advanced	 sUAV’s

may	include	the	following:
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1)	 Auto-pilot	 detection	 of	 lost	 GPS	 or	 of	 insufficient	 satellites	 initiates	 an	

immediate landing,	

2)	 Low	power	on	the	aircraft	triggers	escalating	alarms	at	GCS	at	35%	and	10%	

levels. Low	power	below 10%	triggers	an	immediate	landing,	

3)	 If	the	auto-pilot	detects	a	lost-link	to	the	ground	controller,	the	UAS	will	hold	

position at	its	current	location	for	5	seconds	and	if	the	signal	is	not	restored,	

execute	a	return to	home	and	land,	

4)	 Redundant	“kill	switches”	that	enable	completely	shutting	the	aircraft	down	

in	flight	in the	event	of	a	loss	of	control	or	un-commanded	deviation	from	the	

flight	path,	

5) The	aircraft,	weighs less	than	55	lbs.,	fully	loaded,	

6)	 The	motors	are	driven	by	pulse	width	modulated	signals,	not	analog	signals,	

7)	 The	 aircraft	 will	 operate	 for	the	 Purposes	 at	 no	 more	than	 30 mph (while	

imaging)	 nor above	 200	 feet	 above	 the	 structure	 (imaging	 altitude)	 or	 a	

maximum	of	400	feet AGL.

See	 Federal	 Aviation	 Administration,	 Notice	 N-8900.227,	 Unmanned	 Aircraft	

Systems	 (UAS) Operational	 Approval,	 at	 20-21	 (July	 30,	 2013);	 As	 the	 FAA	 has	

determined	 in	 Exemptions	 11062	 thru	 11067, 11080 and	 11110	 (the

“Exemptions”),	 in	 comparing	the	 requirements	 for	 sport pilot	 knowledge	 and	the	

knowledge	required	for	a	commercial	pilot,	that	knowledge	associated	with	a	sport

pilot	license,	and therefore	sport pilot	ground	school,	was	sufficient	to	allow sport

pilots	to	operate	sUAVs under	those	exemptions.	

Based	upon	that	analysis,	S-E-A,	LTD believes	 successful completion	of	 sport pilot	

ground	school	is	a	suitable predicate	to	operating	the	sUAV	under	this	exemption. SE-A,	LTD proposes	that	the	Operator	accumulate	required	sUAV flight	training hours	

through	 the	 operation	 of	 sUAVs	 rather	 than	 flight	 hours	 in	 conventional	 aircraft.	

Those hours	are	more	relevant	to	the	operations	proposed	herein	than	hours	gained	

in	obtaining	a sport pilot’s	certificate	in	conventional	or	rotor	aircraft.	Those	aircraft	

are	orders	of	magnitude heavier	than	the	sUAS	and	carry	not	only	the	pilot	himself,	

but	 also	 passengers	 and	 fuel,	 none of	 which	 is	 carried	 in	 the	 sUAS.	 These	

conventional	 aircraft	 fly	 over	 all	 sorts	 of	 airspace	 without the	 permission	 or	

knowledge	of	the	landowner.	

A	handheld	radio	controller	controls	the	sUAV and	the	vehicle	is	operated	within	the	

line	of	 sight.	The	 requirements	of	Part	61.127 (commercial	flight	proficiency)	and	

§61.107	(sport flight	proficiency),	to	the	extent	they	are relevant	to	UAS	operations,	

can	be	taught	in	the	training	proposed	herein.	As	a	 review	of	the	 requirements	of	

part	61.127	and	107	demonstrate,	the	issues	presented	as	they	relate	to	a	55	pound	

aircraft,	operating	at	less	than	30	mph during	filming	operations	are	those	taught	in

ground	 school	 and	 in	flight	training	with	the	 particular	UAS	 and	 not	 gained	from	

accumulating flight	hours	in	a	fixed	wing	or	rotorcraft	gas	or	jet	A	powered	aircraft	

completing	 cross	 country flights	 and	 take	 offs	 and	 landings	 at	 controlled	 and	

uncontrolled	airports.
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As	 to	 national	 security	 review	 of	 pilots,	 each	 of	S-E-A,	 LTD’ pilots/operators	 will	

obtain	internally	provided	certified	training	 (Ground	and	Practical)	from	S-E-A,	LTD

to	 operate the	 sUAV.	 This	 review and	 certification could	 reasonably vet	 the	

Operators	 against	 any	 known	 terrorist	 or	 no	 fly	 listings	 that	 are	 relevant and	

publically	available.

S-E-A,	LTD additionally	asks	that	the	exemption	be	issued	without	the	requirement	

for	a	visual	observer.	As	set	forth	herein,	an	equivalent	level	of	safety	is	provided	by	

the	 size, speed	 and	 control	 capabilities	 of	 the	 aircraft,	 as	 well	 as	 the	 operational	

procedures	that	will	be applicable	to	all	flight	hereunder.	These	obviate	the	need	for	

the	visual	observer.	

The	Operator will	be	operating	the	aircraft,	always	within	line	of	sight.	He	or	she	will	

walk	and	follow	the aircraft	around	the	inspection	area	so	that	while	it	is	flying	its	

pre-programed	and	at	times,	manual	flight	path,	the	UAS will	always	be	directly	in	

his	or	her	line	of	sight.	The	Operator	will	not	be	distracted	by	viewing the	pictures	

taken	during	the	flight.	Rather,	once	the	sUAV is	launched,	the	Operator’s	main	duty	

will	be	to	watch	the	flight	of	the	UAS	over	the	 structure	and	intervene	to	address	

flight	path deviations	or	other	issues	that	arise	during	the	flight.	The	functions	that	

an	observer	performs where	the	aircraft	is	flown	at	long	distances	from	the	launch	

area	will	not	be	necessary	as	the Operator	will	always	have	the	aircraft	in	his	or	her	

direct	 sight.	 The	 observer	 also	 will	 not	 be necessary	 because	 the	 Operator	 will	

conduct	a	pre-flight	inspection	of	the	area,	will	and	if	needed,	 cordon	off the	area	

and	will	perform	frequent	visual	scans	of	the	area	while	the	vehicle	is	operating.

S-E-A,	LTD again	notes	that	the	NPRM	does	not	require	the	use	of	a	visual	observer.	

Given	the	clear	direction	in	Section	333	of	the	Reform	Act;	the	authority	contained	

in	 the Federal	 Aviation	 Act,	 as	 amended;	 the	 strong	 equivalent	 level	 of	 safety	

surrounding	the proposed	operations,	 and	the	 significant	public	benefit,	including	

enhanced	safety,	reduction	in environmental	impacts,	including	reduced	emissions	

associated	 with	 allowing	 battery	 powered sUAV’s	 for	 these	 functions	 instead	 of	

turbine	or	gas	power	aircraft/rotorcraft	and	operations	with pilots	having	at	least	a	

sport pilot	license,	the	grant	of	the	requested	exemptions	is	in	the public	interest.	4

Aircraft and Equivalent Level of Safety

																																																							

4 Should	the	FAA	determine	that	it	cannot	grant	such	an	exemption	for	operations	

without	 a	 FAA	 licensed	 sport pilot,	 despite	 the	 showing	 made	 herein,	 under	 the	

statutory	 authority	 the	 FAA	 already	 has,	S-E-A,	 LTD	 will	 operate	 its	 aircraft	 with	

pilots	holding	at	least	the	minimum	license	required	by	the	FAA.	
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The	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 operations	 conducted	 with	 conventional	

aircraft	 or	with	 humans	 climbing	 up	 and	 around structures.	These	 conditions	 are	

drawn	 from	 Exemptions	 11136,	 11138,	 11172,	 11174	 and 11177,	 11062,	 11109,	

11112,	and	11213 and	as	recent	as	11857.

These	 limitations	 and	 conditions	to	 which	S-E-A,	 LTD (referred	to	 as	“Operator”)	

agrees	to	be	bound	when	 conducting	commercial	operations	under	an	FAA	issued	

exemption include:

1) Operations	authorized	by	this grant	of	exemption	are	limited	to	

the	type	of	aircrafts described	in	the	Operator’s	manual,	which	is	

a	multi-rotor weighing	up to	55 pounds:	Proposed	operations	of	

any	other type	of aircraft	will require	a	new	petition	or	a	petition	

to	amend	this	grant.

2) The	UA	may	not	be	flown	at	an	indicated	airspeed	exceeding	30

mph (10 mph during	inspections).

3) The	UA	must	be	operated	at	an	altitude	of	no	more	than	400	feet	

above	 ground level	 (AGL),	 as	 indicated	 by	 the	 procedures	

specified	in	the	Operator’s	manual. All altitudes	reported	to	ATC	

must	be	in	feet	AGL.

4) The	UA	must	be	operated	within	visual	line	of	sight	(VLOS)	of	the	

Aircraft Operator	at	all	times.	This	requires	the	Aircraft	Operator	

to	be	able	to	use	human vision	unaided	by	any	device	other	than	

corrective	lenses..

5) The	Exemption	Holder’s	Manuals	must	be	amended	to	include	all	

conditions	 and limitations	 required	 by	 the	 FAA.	 The	 Manuals	

must	 be	 maintained	 and	 made available	 to	 the	 Administrator	

upon	request.	If	a	discrepancy	exists	between	the conditions	and	

limitations	in	the	exemption	and	the	procedures	outlined	in	the

Exemption	 Holder’s	 Operator’s	 manual,	 the	 conditions	 and	

limitations	 in	 the exemption	 take	 precedence	 and	 must	 be	

followed.	 Otherwise,	 the	 Aircraft Operator	 must	 follow	 the	

procedures	 as	 outlined	 in	 its	Aircraft’s	 manual. The	Exemption	

Holder	 may	 update	 or	 revise	 its	 Manuals.	 It	 is	 the	 Exemption

Holder’s	 responsibility	 to	 track	 such	 revisions	 and	 present	

updated	 and	 revised documents	 to	 the	 Administrator	 upon	

request.	The	Exemption	Holder	must	 also present	updated	 and	

revised	documents	if	it	petitions	for	an	extension	or amendment	
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of	this	exemption.	If	the	Exemption	Holder	determines	that	any

update	 or	 revision	 would	 affect	the	 basis	 upon	 which	the	 FAA	

granted	 this exemption,	 then	 the	 Exemption	 Holder	 must	

petition	for	amendment	to	its exemption.

6) Prior	to	each	flight,	the	Aircraft	Operator	must	inspect	the	UAS	to	

ensure	it	is	in	a condition	for	safe	flight.	If	the	inspection	reveals	

a	condition	that	affects	the	safe operation	of	the	UAS,	the	aircraft	

is	 prohibited	 from	 operating	 until	 the	 necessary maintenance	

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

safe	flight.	The	Ground	Control	Station	must	be	included	in	the	

preflight inspection.	 All	 maintenance	 and	 alterations	 must be	

properly	documented	in	the aircraft	records.

7) Any	 UAS	 that	 has	 undergone	 maintenance	 or	 alterations	 that	

affect	 the	 UAS operation	 or	 flight	 characteristics,	 e.g.,	

replacement	 of	 a	 flight	 critical	 component, must	 undergo	 a	

functional	test	flight	in	accordance	with	the	Exemption	holder’s

Manuals.	The	Aircraft	Operator	who	conducts	the	functional	test	

flight	 must	 make an	 entry	 in	 the	 UAS	 aircraft	 records	 of	 the	

flight.	 The	 requirements	 and procedures	 for	 a	 functional	 test	

flight	and	aircraft	record	entry	must	be	added	to the	Exemption	

Holder’s	Operator’s	manual.

8) The	 Exemption	 Holder	 must	 follow	 the	 manufacturer’s	 UAS	

aircraft/component, maintenance,	 overhaul,	 replacement,	

inspection,	and	life	limit	requirements,	with particular	attention	

to	 flight	 critical	 components	that	 may	 not	 be	 addressed	 in	the

manufacturer’s	manuals.

9) The	 Exemption	 Holder	 must	 carry	 out	 its	 maintenance,	

inspections,	 and	 record keeping	 requirements	 in	 accordance	

with	 the	 Operator’s	 Manuals.	 Maintenance, inspection,	 and	

alterations	must	be noted	in	the	aircraft	logbook,	including	total	

flight	hours,	description	of	work	accomplished,	and	the	signature	

of	the authorized	technician	returning	the	UAS	to	service.

10) The	authorized	technicians	must	receive	and	document	training	

referenced	in	the Exemption	Holder’s	Manuals.

11) Each	UAS	operated	under	this	exemption	must	 comply	with	all	

manufacturer System	and	Safety	Bulletins.

12) The	 Exemption	 Holder’s	 maintenance	 personnel	 must	 make	 a	

record	entry	in	the UAS	logbook	or	equivalent	document	of	the	

corrective	 action	 taken	 against discrepancies	 discovered	

between	inspections.
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13) Prior	to	commencing	operations,	the	Aircraft	Operator	shall	have	

logged	at	least 25	hours	of	total	time	as	a	UA	rotorcraft	pilot	and	

at	least	ten	hours	logged	as	a UA	pilot	with	a	similar UA	type	and	

5	hours	in	the	make	and	model.

14) If	the	UAS	loses	communications	or	loses	its	GPS	signal,	the	UA	

must	 return to	a	pre-determined	location	within	the	private or	

controlled-access	 property and	 land	 or	 be	 recovered	 in	

accordance	with	the	Exemption	Holder’s	Manuals.

15) The	 Aircraft	 Operator	 must	 abort	 the	 flight	 in	 the	 event	 of	

unpredicted	 obstacles or	 emergencies,	 including	 unauthorized	

people	 entering	 the	 flight	 area,	 in accordance	 with	 the	

Exemption	Holder’s	Manuals.

16) The	Aircraft	Operator	is	prohibited	from	beginning	a	UAS	flight	

unless (considering	wind	and	forecast	weather	conditions)	there	

is	enough	power	to	fly to	the	first	point	of	intended	landing	and,	

assuming	normal	cruising	speed,	to	fly after	that	for	at	least	10	

minutes.

17) All	aircraft	operated	in	accordance	with	the	exemption	must	be	

identified	 by serial	 number,	 registered	 in	 accordance	 with	 14	

CFR	 part	 47,	 and	 have identification	(N- Number)	 markings	 in	

accordance	with	14	CFR	part	45,	Subpart C.	Markings	must	be	as	

large	as	practicable.

18) Before	 conducting	 operations,	 the	 radio	 frequency	 spectrum	

used	for operation	and	control	of	the	UA	must	comply	with	the	

Federal Communications	 Commission	 (FCC)	 or	 other	

appropriate	government oversight	agency	requirements.

19) The	documents	required	under	14	CFR	91.9	and	91.203	must	be	

available	 to the	 Operator	 at	 the	 Ground	 Control	Station	 of	 the	

UAS	any	time	the	aircraft	is operating.	These	documents	must	be	

made	 available	 to	 the	 Administrator	 or any	 law	 enforcement	

official	upon	request.	

20) The	UA	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.).

21) The	UA	may	not	be	operated	by	the	Aircraft	Operator	from	any	

moving	device	or vehicle.
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22) UAS	operations	may	not	be	conducted	during	night,	as	defined	in	

14	CFR	1.1.

23) All	 operations	 must	 be	 conducted	 under	 visual	 meteorological	

conditions	(VMC). The	 UA	 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 Operator.

24) During	 operations	 the	 UA	 may	 not	 operate	 within	 5	 nautical	

miles	 of	 the geographic	 center	 of	 an	 airport	 as	 denoted	 on	 a	

current	 FAA-published aeronautical	 chart	 unless	 a	 letter	 of	

agreement	with	that	airport’s	management	is obtained,	and	the	

operation	 is	 conducted	 in	 accordance	 with	 a	 NOTAM,	 if	 as

required	by	the	Operator’s	COA.	The	letter	of	agreement	with	the	

airport management	 must	 be	 made	 available	 to	 the	

Administrator	upon	request.

25) The	 UA	 may	 not	 be	 operated	 over	 congested	 or	 densely	

populated	areas	unless the	conditions	set	for	in	#26	are	satisfied.	

These	populated	areas	include	but are	not	limited	to	the	yellow	

areas	 depicted	 on	 World	 Aeronautical	 Charts (WAC),	Sectional	

Aeronautical	Charts	(Sectionals),	or	Terminal	Area	Charts (TAC).	

However,	 aeronautical	 charts	 may	 not	 reflect	 pertinent	 local	

information. Ultimately,	 it	 is	 the	 Operator’s	 responsibility	 to	

maintain	the	 minimum	 safe altitudes	 required	 by	 §	 91.119	(d)	

(1).

26) Flight	 operations	 must	 be	 conducted	 at	 least	 500	 feet	 from	 all	

nonparticipating persons,	 vessels,	 vehicles,	 and	 structures	

unless:

a. Barriers	or	 structures	 are	present	that	 sufficiently	protect

nonparticipating	 persons	 from	 debris	 in	 the	 event	 of	 an	

accident.	 The Aircraft	 Operator	 must	 ensure	 that	

nonparticipating	persons	remain under	such	protection.	If	a	

situation	arises	where	nonparticipating persons	leave	such	

protection	 and	 are	 within	 30	 feet	 of	 the	 UA,	 flight

operations	must	cease	immediately	and/or;

b. The	aircraft	is	operated	near	vessels,	vehicles	or	structures	

where the	 land	 owner/controller	 has	 granted	 permission	

and/or	the	Aircraft	Operator	has	made	a	safety	assessment	

of	the	risk	of operating	closer	to	those	objects	and;

c. Operations	 near	 the	 Aircraft	 Operator	 do	 not	 present	 an	

undue	hazard to	the	Operator	per	§	91.119(a).
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27) All	 operations	 shall	 be	 conducted	 over	 private or	 controlledaccess	property with	permission	from	the	land	owner/controller	

or	 authorized	 representative. Permission	 from	 land	

owner/controller	or	authorized	 representative	will	be obtained	

for	each	flight	to	be	conducted.

28) 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.

Specific Uses Public Benefits

S-E-A,	LTD proposes	use	of	its	 sUAVs provided	 equivalent	or	 augmented	levels	of

safety	for	each	of	the	uses	proposed	herein:

The	 present	 systems	 of	 photography	 and	 videography	 and	 mapping	 of	 inspecting	

the	 roofs,	 agriculture	land,	buildings,	 roadways,	 vehicles, and	large structures	 site	

surveys,	 wild	 life	 monitoring,	 mosquito	 and	 insect	 control	 are	 now	 conducted	 by	

either	humans	wading	through	 swamps,	 climbing	on	the	 roofs and	 structures	that	

are	 steep,	 tall,	 slippery,	 weakened	 or	 otherwise	 hazardous	 or	 by	 the	 use	 of

conventional	aircraft.	

The	 current	 procedures	 can	 result	 in	 significant	 injuries	to	 the	 people	 who must	

climb	on	the	roofs	or	require	the	use	of	aircraft	that	are	orders	of	magnitude	greater	

in	 size than	 the	 sUAV.	 Either	 method,	 manual	 inspection	 or	 large	 conventional	

aircraft,	 results	 in increased	 risk	 of	 injury	 due	 to	 personnel	 falling	 off	 roofs	 or	

ladders,	carrying	heavy	ladders	and dealing	with	confined	and	dangerous	spaces,	or	

increased	 risk	 from	 low	 altitude	 flyovers	 with helicopters	 or	 fixed	 wing	 aircraft	

inspecting	 buildings	 after	 damage	 from	 storms	 or	 other disasters,	 such	 as	

earthquakes	or	fires.	Such	flights	are,	of	 course,	 significantly	more expensive	than	

those	undertaken	with	a	sUAV.	

The	present	system	exposes	those	not	only	in the	immediate	area	of	inspection,	but	

those	who	are	along	the	path	of	flight	associated	with	the arrival	and	departure	of	

the	conventional	aircraft	at	the	inspection	site	because	the	aircraft	must be	flown to	

and	from the	site.	By	contrast,	the	sUAVs are	carried	to	the	site	and	transits	no	other

property.	 Conventional	 aircraft	 carry	 flammable	 fuels	 that	 are	 not	 carried	 by	 the	

UAS	and	emit pollutants	 associated	with	internal	 combustion	engines.	The	 sUAV’s	

proposed	herein	are battery	powered	and	have	no	emissions.
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Equivalent Level of Safety

14	C.F.R.	§	61.113(a)	&	(b);:	Sport Pilot	Privileges	and	Limitations;	Pilot	in	

Command;

Section	 61.113(a)	&	(b)	 limit	 sport pilots	to	 non-commercial	 operations.	Unlike	 a	

conventional aircraft	 that	 carries	 a	 pilot,	 passengers,	 and	 cargo,	 the	 S-E-A,	 LTD’

sUAV is	 remotely	 controlled	 with no	 passengers	 or	 property	 of	 others	 on	 board.	

Section	61.133(a)	requires	an	individual	with	a commercial	pilot’s	license	to	be	pilot	

in	command	of	an	aircraft	for	compensation	or	hire.	

S-E-A,	 LTD respectfully	 proposes	 that	 Operator	 requirements	 should	 take	 into	

account	the characteristics	of	the	particular	UAS.	S-E-A,	LTD’ sUAV has	a	high	degree	

of	 pre-programmed control	 and	 various	 built-in	technical	 capabilities	that	 strictly	

limit	the	potential	for	operation outside	of	the	operating	conditions	set	forth	in	the	

exemption	 application. The	 S-E-A,	 LTD’ sUAV has	 navigation	 and	 control	 system	

comprised	of	a	Ground	Control	Station (GCS)	and	auto-pilot	system	that	can	be	preprogrammed	 to	 set	 operational	 boundaries.	 All flights	 are	 pre-programmed	 with	

precision	GPS	 guidance..	In	the	 case	of	unplanned	 events,	the	Operator	may	input	

pre-programmed evasive	 maneuvers	 from	 the	 control	 unit,	 and	 the	 onboard	

autopilot	 executes	 those	 maneuvers. Pre-programmed	 Operator	 interventions	

include	initiation	of	holding	at	present	position; suspension	of	mission;	fly	back	to	

launch	point;	abort	mission	and	land	immediately;	and emergency	power	cut	off	and	

land	(Flight	Termination	System).

Additional	 automated	 safety	functions	 and	 safety	 enhancing	features	of	the	S-E-A,	

LTD’ sUAV’s may	include	the following:

1.1.	Auto-pilot	detection	of	lost	GPS	or	of	insufficient	 satellites	initiates	an	

immediate landing.

1.2.	Low	power	on	the	aircraft	triggers	escalating	alarms	at	GCS	at	35%	and	

10%	levels.	Low	power	below 10%	triggers	an	immediate	landing.

1.3.	If	the	auto-pilot	detects	a	lost-link	to	the	ground	controller,	the	UAS	will	

hold	position	at	its	current	location	for	5	seconds	and	if	the	signal	is	not	

restored, execute	a	return	to	home	and	land.

1.4.	Redundant	“kill	 switches”	that	 enable	 completely	 shutting	the	 aircraft	

down	 in	 flight	 in	 the	 event	 of	 a	 loss	 of	 control	 or	 un-commanded	

deviation	from	the	flight	path.

1.5.	The	aircraft,	weighs	less	than	55	lbs.,	fully	loaded.

1.6.	 The	 motors	 are	 driven	 by	 pulse	 width	 modulated	 signals,	 not	 analog	

signals.

1.7.	 The	 aircraft	 will	 operate	 for	 the	 Purposes at	 no	 more	 than	 30 mph

(while	 imaging) nor	 above	 200	 feet	 above	 the	 structure	 (imaging	

altitude)	or	a	maximum	of	400 AGL.
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Given	these	safety	features,	S-E-A,	LTD proposes	that	Operators	of	the	 S-E-A,	LTD’

sUAV should not	be	required	to	hold	a	commercial	or	sport pilot	certification.	

Instead,	 Operators	 should	 be required to: have	 successfully	 completed,	 at	 a	

minimum,	 FAA	 sport pilot	 ground	 instruction	 and passed	 the	 FAA	 Sport Pilot	

written	 examination	 or	 FAA-recognized	 equivalents;	 have	 completed	 the	

manufacturer’s	or	S-E-A,	LTD’ training	program	for	operation	of the	UAS.

S-E-A,	LTD notes	that	the	FAA	has	found	that	safety	factors permitted	operation	of	

UASs	by	Operators	with	these	qualifications	in	the	 case	of	operations	pursuant	to	

public	 COAs	 where	 the mandatory	 operating	 conditions	 specified	 above	 were	

present.	 See,	 Federal	 Aviation Administration,	 Notice	 N-8900.227,	 Unmanned	

Aircraft	Systems	(UAS)	Operational	Approval,	at 20-21	(July	30,	2013).	Likewise,	SE-A,	LTD notes	that	the NPRM	does	not	require	that	the	Operator	hold	a	sport pilot	

license	issued	by	the	FAA.

Given	 these	 conditions	 and	 restrictions,	 an	 equivalent	 level	 of	 safety	 will	 be	

provided	 by	 allowing operation	 of	 the	 S-E-A,	 LTD’ sUAV without	 a	 sport pilot’s	

certificate	or	a	commercial	pilot’s certificate,	under	the	conditions	set	forth	herein.

The	 risks	 associated	 with	 the	 operation	 of	 the	 S-E-A,	 LTD’ sUAV (given	 its	 size,	

speed,	operational	capabilities,	and	lack	of	combustible	fuel)	are	so	diminished	from	

the	 level	 of	 risk	 associated with	 sport pilot	 operations	 or	 commercial	 operations	

contemplated	by	Part	61	with conventional	aircraft	(fixed	wing	or	rotorcraft),	that	

allowing	operations	of	the	UAS	as	set	forth above	meets	or	exceeds	the	present	level	

of	safety	provided	under	14	C.F.R.	§	61.113(a)	&	(b) and	does	not	rise	to	the	level	of	

requiring	a	commercial	pilot	to	operate	the	aircraft	under §	61.133(a).

14 C.F.R. § 91.7(a): Civil aircraft airworthiness.

This	 regulation	 requires	that	no	person	may	operate	 a	 civil	 aircraft	unless	it	is	in	

airworthy	 condition.	 Should	 the	 exemption	 be	 granted	 allowing	 commercial	

operation	of	the	UAS	without an	airworthiness	certificate,	no	standard	will	exist	for	

airworthiness	of	the	UA.	Given	the	size	of the	aircraft	and	the	requirements	that	the	

Operator	has	agreed	to	as	it	relates	to	airworthiness, as	contained	in	the	manual,	an	

equivalent	level	of	safety	will	be	achieved	by	insuring compliance	with	the	manuals	

prior	to	each	flight.	The	FAA	has	granted	exemptions	to	conduct similar	operations	

in	Exemptions	11062	through	11067,	11080	and	11110.

14 C.F.R. §91.119: Minimum safe altitudes

Section	 91.119	 establishes	 safe	 altitudes	 for	 operation	 of civil	 aircraft.	 Section	

91.119	(d)	allows	helicopters	to	be	operated	at	less	than	the	minimums	prescribed,	
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provided	the	person operating	the	helicopter	complies	with	any	route	or	altitudes	

prescribed	 for	 helicopters	 by	 the FAA.	 As	 this	 exemption	 is	 for	 a	 sUAS	 that	 is	 a	

helicopter	and	the	exemption	 requests	authority to	operate	at	altitudes	up	to	400	

AGL,	an	exemption	may	be	needed	to	allow	such	operations.	

The	equivalent	level	of safety	will	be	achieved	given	the size,	weight,	and	speed of	

the	UAS	as	well	as	the	location	where	it	is	operated.	No	flight	will	be	taken	without	

the	permission	of	the property	owner,	facility	owner,	and/or	local	officials.	Because	

of	the	advance	notice	to	the property	owner	and	participants,	all	affected	individuals	

will	be	aware	of	the	planned	flight	operations	as	set	forth	in	the	Manuals.	Compared	

to	flight	operations	with	aircraft	or	rotorcraft weighing	far	more	than	the	maximum	

55	lbs.	and	the	lack	of	flammable	fuel,	any	risk	associated with	these	operations	is	

far	 less	 than	 those	 presently	 presented	 by	 conventional	 aircraft operating	 at	 or	

below	 500	 AGL	 in	 the	 aerial	 photography	 industry.	 In	 addition,	 the	 low-altitude

operations	of	the	sUAS	will	ensure	separation	between	these	small-UAS	operations	

and	the operations	of	conventional	aircraft	that	must	 comply	with	Section	91.119.	

The	 FAA	 has	 granted exemptions	 to	 conduct	 similar	 operations	 in	 Exemptions	

11062	through	11067,	11080	and 11110.

14 C.F.R. §91.121 Altimeter Settings

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	S-E-A,	

LTD’ sUAV,	 in	 manual	 or	 emergency mode,	 will	 not	 have	 a	 barometric	 altimeter	

display,	 but	 instead	 a	 GPS	 altitude	 display,	 an exemption	 will	 be	 needed.	 The	

Operator,	pursuant	to	the	procedures	 set	forth	in	the	Manuals	as	indicated	before	

flight,	will	achieve	an	equivalent	level	of	safety.	The	FAA	has granted	exemptions	to	

conduct	similar	operations	in	Exemptions	11062	through	11067,	11080 and	11110.

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	45 minutes.”

The	 battery	 powering	 the	 sUAS	 provides	 approximately	 40	 minutes	 of	 powered	

flight.	To meet	the	30-minute	reserve	requirement	in	14	CFR	§91.151,	sUAS	flights	

would	be	limited	to approximately	10	minutes	in	length.	Given	the	limitations	on	the	

UAS’ proposed	 flight	 area	 and the	 location	 of	 its	 proposed	 operations	 within	 a	

predetermined	area,	a	longer	time	frame	for flight	is	reasonable.
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Petitioner believes	that	an	exemption	from	14	CFR	§91.151(a)	falls	within	the	scope	

of prior	exemptions.	See	Exemption	10673	(allowing	Lockheed	Martin	Corporation	

to	operate without	compliance	with	FAR	91.151	(a)).	Operating	the	small	UAS,	in	a	

tightly	 controlled	 area where	 only	 people	 and	 property	 owners	 or	 official	

representatives	who	have	signed	waivers	will be	allowed,	with	less	than	30	minutes	

of	 reserve	 fuel,	 does	 not	 engender	 the	 type	 of	 risks	 that Section	 91.151(a)	 was	

intended	to	alleviate	given	the	size	and	speed	of	the	small	UAS.

Petitioner believes	 that	 an	 equivalent	 level	 of	 safety	 can	 be	 achieved	 by	 limiting	

flights	to 30	minutes	or	25%	of	remaining	battery	power	whichever	happens	first.	

This	 restriction	 would	 be	 more	 than	 adequate	 to	 return	 the	 sUAS	 to	 its	 planned	

landing	zone	from	anywhere	in	its	limited operating	area. Similar	exemptions	have	

been	granted	to	other	operations,	including	Exemptions	2689F, 5745,	10673,	10808	

and	Exemptions	11062,	through11067,	11080	and	11110.

14 C.F.R. §91.405 (a); 91.407 (a) (1); 91.409(a) (2); 91.417(a) & (b): Maintenance

Inspections

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.	 Maintenance	 will	 be	

accomplished	by the	Operator	or	manufacturer	pursuant	to	the	flight	manual	 and	

operating	handbook	as referenced	in	the	Manuals	attached	as	confidential	Exhibits	

An	 equivalent	 level	 of	 safety	 will	 be achieved	 because	these	 small	UASs	 are	 very	

limited	in	size	and	will	carry	a	small	payload	and operate	only	in	defined	areas	for	

limited	periods	of	time.	If	mechanical	issues	arise,	the	UAS can	land	immediately	and	

will	 be	 operating	 from	 no	 higher	 than	 400	 feet	 AGL.	 As	 provided	 in the	 Aircraft	

Flight	Operations	Manual	the	Operator	will	ensure	that	the	UAS	is	in	working	order

prior	 to	 initiating	 flight,	 perform	 required	 maintenance,	 and	 keep	 a	 log	 of any	

maintenance performed.	 Moreover,	 the	 Operator	 and	 manufacturer	 are	 most	

familiar	with	the	 aircraft	 and best	 suited	to	 maintain	the	 aircraft	 in	 an	 airworthy	

condition	to	provide	the	equivalent	level	of safety.	The	FAA	has	granted	exemptions	

for	similar operations	in	Exemptions	11062	through 11067,	11080	and	11110.

*********
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Federal Register Publication

Pursuant	to	14	C.F.R.	Part	11,	the	following	summary	is	provided	for	publication	in	

the	Federal	Register,	should	it	be	determined	that	publication	is	needed:

Petitioner seeks	an	exemption	from	the	following	rules:

14	C.F.R.	§§	61.113(a)	&	(b);	91.7(a);	91.119;	91.121;	91.151(a);	91.405(a);

91.407(a)(1);	 91.409(a)(2)	 and	 91.417	(a)	&	(b)	to	 operate	 commercially	 a	 small	

unmanned	 vehicle	(55	 lbs.	 or	 less)	 for	the	 following	 purposes:	to	 conduct bridge	

inspections,	flare	stack	inspection,	utility-power	generation	system	inspections	and	

patrolling,	aerial	inspection	and	photography	of	 residential	and	commercial	utility	

infrastructure	including	but	not	limited	to	electrical	power	lines,	wind	turbines	and	

cell	 towers,	 pipeline	 inspection	 and	 patrolling,	 filmmaking,	 cinematography,	 and	

videography,	 precision	 agriculture	 with	 on	 board	 sensors,	 wildlife	 and	 forestry	

monitoring and	 mosquito	 and	 insect	 control,	 aerial	 surveying,	 construction	 site	

inspection	 and	 monitoring,	 public	 entity	 support	 operations,	 aerial	 video	 and	 live	

video	 feed	 to	 assist	 with	 search	 and	 rescue	 operations	 under	 the	 authority	 and	

support	 of	 local	 authority	 officials,	 aerial	 video	 and	 photography	 for	 public	 and	

private use	 including	 television,	 public	 events,	 and	 cinematography	 live	 feed	 and	

live	newsgathering,	training	to	persons	individually	or	belonging	to	both	private and	

public	 organizations	 to	 increase	 awareness	 and	 improve	 safety	 for	 current	 and	

future	 UAS	 operations	 within	 the	 NAS,	 special	 events:	 including	 high	 schools.	

colleges,	professional	sports,	open	air	events	and	fairs,	research,	risk	management	

and	assessment,	,	surface	mining,	closed	set	filming,	disaster	and	catastrophe	events,	

aerial	 imagery	 and	 videos	 in	 conjunction with	 	 accident	 response	 and	 evidence	

documentation.

Privacy and National Security

All	flights	will	occur	over	private or	controlled	access	property	with	the	property	

owner’s	prior	consent	and	knowledge.	Inspection	will	be	of	inanimate	objects	in	

areas	where	the	owners will	have	consented	to	the	inspections	or	otherwise	have	

agreed	to	allow	the	UAS	and	the Operator	to	be	in	the	area	where	operations will	

take	place.	

The	size	of	the	UAS,	its	speed	and	restricted	area	of	operation	do	not	raise	national

security	issues.

Summary
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Approval	of	exemptions	allowing	commercial	operations	of	sUAV’s	for	petitioner	to	

operate	 an	 unmanned	 aircraft	 system	 (UAS)	 to	 conduct	 bridge	 Inspections,	 flare	

stack	inspection,	utility-power	generation	system	inspections	and	patrolling,	aerial	

inspection	 and	 photography	 of	 residential	 and	 commercial	 utility	 infrastructure	

including	 but	 not	 limited	to	 electrical	 power	 lines,	wind	turbines	 and	 cell	towers,	

pipeline	 inspection	 and	 patrolling,	 filmmaking,	 cinematography,	 and	 videography,	

precision	 agriculture	with	 on	 board	 sensors,	wildlife	 and	forestry	monitoring and	

mosquito	 and	 insect	 control,	 aerial	 surveying,	 construction	 site	 inspection	 and	

monitoring,	 public	 entity	 support	 operations,	 aerial	 video	 and	 live	 video	 feed	 to	

assist	with	 search	and	 rescue	operations	under	the	authority	and	 support	of	local	

authority	officials,	aerial	video	and	photography	for	public	and	private	use	including	

television,	 public	 events,	 and	 cinematography	 live	 feed	 and	 live	 newsgathering,	

training	 to	 persons	 individually	 or	 belonging	 to	 both	 private	 and	 public	

organizations	to	increase	awareness	and	improve	safety	for	current	and	future	UAS	

operations	 within	 the	 NAS,	 special	 events:	 including	 high	 schools.	 colleges,	

professional	 sports,	 open	 air	 events	 and	 fairs,	 research,	 risk	 management	 and	

assessment,	,	surface	mining,	closed	set	filming,	disaster	and	catastrophe	events,	will	

enhance safety	 by	 reducing	 risk,	 aerial	 imagery	 and	 videos	 in	 conjunction with		

accident	response	and	evidence	documentation.

Conventional	 operations,	 using	 jet	 or	 piston	 powered	 aircraft,	 ladders	 or placing	

people	in	swamps,	on	roofs	or	tall,	hazardous	or	weakened	structures,	exposes	them	

to	 higher	 risks than	 those	 created	 by	 use	 of	 a	 sUAV’s.	 Conventional	 aircraft	 that	

operate	at	extremely	low altitudes	just	feet	from	the	subject	being	inspected	and	in	

extreme	 proximity	 to	 people	 and structures	 present	 the	 risks	 associated	 with	

vehicles	that	weigh	in	excess	of	6,000	lbs.,	carrying large	amounts	of	jet	A	or	other	

fuel	(140	gallons	for	jet	helicopters).	Such	aircraft	must	fly	to	and from	the	project	

location.	In	contrast,	a	sUAV weighing	fewer	than	55 lbs.	and	powered	by batteries	

eliminates	virtually	all	of	that	risk	given	the	reduced	mass	and	lack	of	combustible	

fuel carried	 on	 board.	 The	 sUAV is	 carried	to	the	target	 area	 and	 not	 flown.	 The	

sUAV will	carry	no passengers	or	crew	and,	therefore,	will	not	expose	them	to	the	

risks	associated	with	manned aircraft	flights.

The	operation	of	small	UASs,	weighing	less	than	55 lbs.,	conducted	under	the	strict

conditions	outlined	above,	will	provide	an	equivalent	level	of	safety	supporting	the	

grant	of	the exemptions	requested	herein.	These	lightweight	aircraft	operate	at	slow	

speeds,	close	to	the ground,	and	in	areas	that	are	under	the	control	of	the	customer	

for	 the	 operations and,	 as	 a result,	 are	 far	 safer	 than	 conventional	 operations	

conducted	with	turbine	helicopters	operating	in close	proximity	to	the	ground	and	

people	or	the	use	of	individuals to	climb	the	structures	to conduct	the	operations.

Satisfaction	of	the	criteria	provided	in	Section	333	of	the	Reform	Act	of	2012	–size,	

weight,	speed,	operating	capabilities,	proximity	to	airports	and	populated	areas	and	

operation within	 visual	 line	 of sight	 and	 national	 security	 – provide	 more	 than	

adequate	 justification	 for	 the grant	 of	 the	 requested	 exemptions	 allowing	

commercial	operation	of	Petitioner’s	UAS	for	the Purposes	outlined	herein	and	are	
Gowdy	Brothers	Aerospace,	LLC			8170	Old	Carriage	Court	N.,	Suite	#200,	Shakopee,	MN	55379		

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consistent	with	exemptions	already	granted,	including Exemptions number	11171	

through	 11174,	11176,	11177,	11062,	11109,	11112,	 and	11213 and	 as	 recent	 as	

11857.

Sincerely,

Ronny	Wahba,	P.E.

Mechanical	Engineer

S-E-A,	Limited.

795	Cromwell	Park	Drive,	Suite	N

Glen	Burnie,	MD	21061

and	

Stephen	Gowdy

Chief	Pilot,

Gowdy	Brothers	Aerospace,	LLC

Consulting	Agent	for	S-E-A,	Limited.
Gowdy	Brothers	Aerospace,	LLC			8170	Old	Carriage	Court	N.,	Suite	#200,	Shakopee,	MN	55379		

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APPENDIX A - EXEMPTION PATTERN

Petitioner	 submits	 the	 Appendix	 and	 Manuals	 marked	 “CONFIDENTIAL,”	 as	 they	

contain	 proprietary	 confidential	 business	 information	 that	 is	 not	 released	 to	 the	

public	and	is	protected	under	the	Freedom	of	Information	Act	5	USC	§552	et.	seq.	5	

Reform	Act	Section	333	(b).	

Submitted	under	separate	cover.
Gowdy	Brothers	Aerospace,	LLC			8170	Old	Carriage	Court	N.,	Suite	#200,	Shakopee,	MN	55379		

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APPENDIX B - TECHNICAL MANUALS AND SPECIFICATIONS

Petitioner	 submits	 the	 Appendix	 and	 Manuals	 marked	 “CONFIDENTIAL,”	 as	 they	 contain	

proprietary	 confidential	 business	 information	 that	 is	 not	 released	 to	 the	 public	 and	 is	

protected	under	the	Freedom	of	Information	Act	5	USC	§552	et.	 seq.	5	Reform	Act	Section	

333	(b).	

Submitted	under	separate	cover.
Gowdy	Brothers	Aerospace,	LLC			8170	Old	Carriage	Court	N.,	Suite	#200,	Shakopee,	MN	55379		

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APPENDIX C - COMMERCIAL (MISSION/OPERATION) PURPOSE - FAA 

PREVIOUS APPROVED EXEMPTION NUMBERS

Petitioner	 submits	 the	 Appendix	 and	 Manuals	 marked	 “CONFIDENTIAL,”	 as	 they	

contain	 proprietary	 confidential	 business	 information	 that	 is	 not	 released	 to	 the	

public	and	is	protected	under	the	Freedom	of	Information	Act	5	USC	§552	et.	seq.	5	

Reform	Act	Section	333	(b).	

Submitted	under	separate	cover.
Gowdy	Brothers	Aerospace,	LLC			8170	Old	Carriage	Court	N.,	Suite	#200,	Shakopee,	MN	55379		

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APPENDIX D - EQUIPMENT - FAA PREVIOUS APPROVED EXEMPTION 

NUMBERS

Petitioner	 submits	 the	 Appendix	 and	 Manuals	 marked	 “CONFIDENTIAL,”	 as	 they	

contain	 proprietary	 confidential	 business	 information	 that	 is	 not	 released	 to	 the	

public	and	is	protected	under	the	Freedom	of	Information	Act	5	USC	§552	et.	seq.	5	

Reform	Act	Section	333	(b).	

Submitted	under	separate	cover.
Gowdy	Brothers	Aerospace,	LLC			8170	Old	Carriage	Court	N.,	Suite	#200,	Shakopee,	MN	55379		

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APPENDIX E - EXEMPTION 14 C.F.R - FAA PREVIOUS APPROVED 

EXEMPTION NUMBERS

Petitioner	 submits	 the	 Appendix	 and	 Manuals	 marked	 “CONFIDENTIAL,”	 as	 they	

contain	 proprietary	 confidential	 business	 information	 that	 is	 not	 released	 to	 the	

public	and	is	protected	under	the	Freedom	of	Information	Act	5	USC	§552	et.	seq.	5	

Reform	Act	Section	333	(b).	

Submitted	under	separate	cover.
Gowdy	Brothers	Aerospace,	LLC			8170	Old	Carriage	Court	N.,	Suite	#200,	Shakopee,	MN	55379		

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APPENDIX F - MONTHLY MAINTENANCE AND REPAIR LOG

Petitioner	 submits	 the	 Appendix	 and	 Manuals	 marked	 “CONFIDENTIAL,”	 as	 they	

contain	 proprietary	 confidential	 business	 information	 that	 is	 not	 released	 to	 the	

public	and	is	protected	under	the	Freedom	of	Information	Act	5	USC	§552	et.	seq.	5	

Reform	Act	Section	333	(b).	

Submitted	under	separate	cover.
Gowdy	Brothers	Aerospace,	LLC			8170	Old	Carriage	Court	N.,	Suite	#200,	Shakopee,	MN	55379		

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APPENDIX G – FLIGHT OPERATIONS MANUAL VERSION 1.0

Petitioner	 submits	 the	 Appendix	 and	 Manuals	 marked	 “CONFIDENTIAL,”	 as	 they	

contain	 proprietary	 confidential	 business	 information	 that	 is	 not	 released	 to	 the	

public	and	is	protected	under	the	Freedom	of	Information	Act	5	USC	§552	et.	seq.	5	

Reform	Act	Section	333	(b).	

Submitted	under	separate	cover.