27 September, 2015 Resilient Solutions Ltd 

6198 Manchester Park Cir 

Alexandria, VA 22310 

U.S. Dept. of Transportation, Docket Operations 

West Building Ground Floor, Room w12-140 

1200 New Jersey Avenue, SE., 

Washington, DC 20590 

VIA FEDERAL DOCUMENT MANAGEMENTSYSTEM 

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

Regulations 

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, 

Resilient Solutions Ltd (RSL), seeks an exemption from the Federal Aviation Regulations (FARs) detailed below and 

any other necessary to allow commercial operation of its Unmanned Aircraft Systems (UAS). Our UAS fleet 

would be used for photography, videography, training, surveys and inspections, and providing targetry in the 

development of a tracking system for counter-UAS systems. 

Contact Information: 

Arthur W Finehout 

Chief Operating Officer 

Resilient Solutions Ltd 

6198 Manchester Park Cir 

Alexandria, VA 22310 

Finehout@resilientsolutionsltd.com 

703-655-8764 

List of Specific Sections of 14 CFR for which exemption issought. Each regulation may befound on pages 

5-8 together with our proposed equivalent level of safetyfor each regulation. 

14 CFR 21, Subpart H—Airworthiness Certificates 

14 CFR 61.113(a) and (b), Certification: Pilots, Flight Instructors, and Ground Instructors 14 CFR 

91.7 (a), Airworthiness required for operation 

14 CFR 91.9, Aircraft Flight Manual, Marking, and Placard requirements 

14 CFR 91.103 (b) (2), Preflight action 

14 CFR 91.105, Flight crewmembers at stations 14 CFR 

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91.109, Flight instruction 

14 CFR 91.119 (c), Minimum safe altitudes 14 CFR 

91.121, Altimeter settings 

14 CFR 91.151, Fuel requirements for flights in VFR conditions 

14 CFR 91.203 (a) &(b) Civil Aircraft: Certifications required 

14 CFR 91.405 (a), Maintenance required 

14 CFR 91.407 (a) (1), Operation after maintenance 

14 CFR 91.409 (a) (2), Inspections 

14 CFR 91.417 (a) and (b), Maintenance records 

In accordance with the outline given in the FAA's "Public Guidance for Petitions Filed under Section 333", the 

following information is provided for each numbered item listed in thatguidance: 

1. Aircraft Description: Design and Operational Characteristics: 

Resilient Solutions plans to operate a D11 Phantom 3 Professional quadcopter and a Bixier 1.1 fixed wing UAS 

in it's operations. 

The DJI Phantom 3 Professional is a quadcopter configuration with a weight of 44 ounces (2.8 pounds), 

designed primarily to carry a high definition camera aloft. Powered by 4 electric motors it has an advertised 

maximum speed of less than 30 knots and a maximum climb rate of less than 1200 fpm. It utilizes an 

internal inertial measuring unit (IMU) with integrated barometric sensor augmented with Global 

Positioning System (GPS) to maintain its geospatial orientation and position. Real time video and telemetry 

information is transmitted back to a ground control station allowing the operator and/or PIC to monitor 

battery level, GPS signal strength, altitude (AGL), and distance from the PIC. It has failsafe modes of 

operation for either loss of RC or GPS signal. Altitude can be limited by the onboard flight controller and 

maximum altitude can be preprogrammed by the PIC. Battery life limits flight times to approximately 25 

minutes. The onboard flight controller will warn the pilot via telemetry data and external lighting cues 

before reaching a low battery state. More information is available in Attachment A. 

The Bixler 1.1, from (HobbyKing), is a fixed wing UAS with a weight of 33 ounces (2.06 pounds) designed 

primarily for Radio Controlled aircraft hobbyists. It has a limited ability to carry sensors or cameras. Built of 

foam construction and powered by a single electric motor the Bixler 1.1 has a wingspan of 55 inches and a 

length of 36.5 inches. Battery life is approximately 20 minutes and the pilot receives a notice on the flight 

controller when there is five minutes remaining. Resilient Solutions will use the Bixler as a target aircraft to 

test and develop counter-UAS detection systems, it will be operated primarily on government controlled 

ranges and airspace. The telemetry from the radar of the counter UAS systems will provide real time altitude 

and location information to the pilot and visual observer. More information is available in Attachment B. 
2. Procedures for Ensuring UAS Is In a Condition Safe for Flight 

AII sUAS flight operations will be conducted in accordance with the Resilient Solutions Flight Operations 

Manual (Attachment C) and the Resilient Solutions Safety Program (Attachment D). 

The RSL Flight Operations Manual (FOM) thoroughly covers the information needed for a safe, effective flight 

program. It includes the areas of Pilot and Visual Observer Training, Pilot in Command (PIC) selection and 

qualification, aircrew training records, currency requirements, flight planning, crew duty limitations, weather 

requirements, pre and post-flight inspections and briefings, maintenance and emergency procedures. 

3. Radio Frequency (RF) Spectrum For Control 

DJI Phantom 3 Professional: The Ground Control station operating frequency is 2.400 GHz to 2.48 GHz and 

is compliant with Part 15 of the FCC rules. 

Bixler 1.1: The Ground Control station is the SPEKTRUM DX7s with an operating frequency of 2.400 GHz to 

2.4835 GHz and is compliant with Part 15 of the FCC rules. 

4. Qualifications For The Pilot in Command (PIC) 

Selection: RSL PICs will be selected on their ability to meet current FAA and RSL required qualifications, 

demonstrated ability to safely operate RSL UAS IAW the exemption granted by the FAA, and their experience. 

Prior to designation as a PIC, the pilot will have logged a minimum of 10 hours as a UAS rotorcraft / fixed wing 

pilot, with at least 5 being in the type UAS operated by RSL that he/she will fly as a PIC. 

Certification: All RSL PIC's must hold an airline transport, commercial, private, recreational, or sport pilot 

certificate and hold a current FAA airman medical certificate or a valid U.S. driver's license. The PIC must also 

meet the flight review requirements specified in 14 CFR 61.56 in an aircraft in which he/she is rated on his/her 

pilot certificate. 

To remain current, PICs must accomplish three takeoffs and landings and log three flight hours per 90 days in the 

UAS which they are qualified to operate. 

Emergency and Evasive Maneuvers: The PIC will have demonstrated the ability to safely operate the UAS in a 

manner consistent with how it will be operated in conducting expected RSL missions, including evasive and 

emergency maneuvers and maintaining appropriate distances from people, vessels, vehicles and structures. 

S. Medical Standards and Certification Of The PIC 

As described in 4 above, the PIC will possess a current FAA airman medical certificate or a valid U.S. driver's 

license. 

6. Description Of Intended UAS Operations 

Our sUAS fleet will be used for photography, videography, training, surveys and inspections, and 

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providing targetry in the development of a tracking system for counter-UAS systems. In all cases 

our operations will be conducted in areas with designated geographic boundaries, within visual line 

of sight of the PIC and visual observer, and in accordance with the RSL Flight Operations Manual. 

Flight operations will not be conducted within five nautical miles of an airport reference point (ARP) as denoted 

in the current FAA AirportJFacility Directory. For airports not denoted with an ARP, the center of the airport 

symbol as denoted on the current FAA-published aeronautical chart, unless a letter of agreement with that 

airport's management is obtained or otherwise permitted by a COA issued to the exemption holder. 

Resilient Solutions wil) use the Bixler fixed wing UAS as a target aircraft to test and develop counter-UAS 

detection systems, it will be operated primarily on government controlled ranges and airspace. 

7. Proposed Speed, Altitude, Visibility and Distances 

Speed: Groundspeed will not exceed 40 Knots. 

Altitude: Altitudes below 400 ft. AGL are adequate for the complete range of expected missions. The 

integral Flight Control System will be set to limit the altitude to always be below that level. 

RSL UAS will not be operated less than 500 feet below or less than 2,000 feet horizontally from a cloud 

or when visibility is less than 3 statute miles from the PIC. 

Operations will be aborted immediately if the PIC encounters unpredicted obstacles or emergencies. Safe 

descent and landing procedures will be followed in accordance with operatingdocuments. 

8. Description of The Area Of Intended Operations: 

Paragraph 5-12 of the RSL Flight Operations Manual mandates an Operating Site Location Assessment be 

completed by the crew prior to flight. 

9. Proximity of Airports: 

No operations will occur within 5 miles of a non-towered airport reference point as denoted on a current FAApublished aeronautical chart, unless a letter agreement with the airport's management is obtained, and the 

operation is conducted in accordance with a Notice to Airman (NOTAM) as required by the Certificate of 

Waiver or Operation (COA). 

10. Operation Within Visual Line-of-Sight(VLOS) 

In addition to the Pilot in Command (PIC), all operations will include a Visual Observer (VO). The VO will assure 

that the UAS is always within their visual line-of-sight (VLOS), as well as the PIC's, at all times. The VO and the 

PIC will be able to communicate verbally at all times. 

11. Procedures for Preflight SafetyAssessment 

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Prior to each flight the PIC must inspect the UAS IAW the applicable RSL preflight checklist. 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. AII maintenance and alterations must be properly 

documented in the aircraft records. 

Completed Preflight checklists will be signed and dated by the PIC. 

To begin a flight the PIC must ensure (considering wind and forecast weather) that there is enough available 

power for the UAS to conduct the intended operation and to operate after that for at least 5 minutes, or with 

the reserves recommended by the manufacturer, whichever is greater. 

The PIC will conduct a post-flight inspection IAW the applicable RSL checklist, looking for any changes in the 

airworthiness of the system overall. 

12. Notifications 

If required, and in accordance with the COA, a Notice to Airmen (NOTAM) will be requested not more than 72 

hours in advance and not less than 48 hours prior to an operation. 

In addition, any notifications required by the FAA Flight Standards District Office will be made. 

13. Certificate Of Waiver Or Authorization (COA) 

Prior to conducting any operations, an Air Traffic Organization (ATO) issued Certificate of Waiver or Operation 

(COA) will be obtained for each aircraft. Each UAS aircraft will be identified with its 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 will be as large as practicable. 

SPECIFIC REGULATIONS FOR WHICH EXEMPTION IS SOUGHT: 

1. 14 CFR 21, Subpart H—Airworthiness Certificates 

Part 21 covers certification procedures for products and parts. Subpart H specifies requirements for 

Airworthiness Certificates for various aircraft types. Small unmanned aircraft systems are not specifically called 

out and addressed in these rules. 

RSL will, in lieu of airworthiness certification by aforementioned rule, if exemption is granted, ensure that our 

UAS are in compliance with its operating documents as described herein. The PIC will assure that all Preflight 

Checks are completed and documented and there is full compliance with all manufacturer's operation and 

maintenance documents. 

Due to consideration of the size, weight, speed, and limited operating area associated with RSL's proposed 

UAS, we believe it will not create a hazard to users of the National Airspace System (NAS) or the public. 

Therefore, a request is made for exemption from 14 CFR part 21, and any associated noise certification and 

testing requirements of part36. 
2. 14 CFR 61.113(a) and (b), Certification: Pilots, Flight Instructors, and Ground Instructors 

14 CFR 61.113 (a) and (b) prohibit private pilots from fulfilling the role of PIC if the aircraft is carrying property 

for compensation, unless the flight is only incidental to that business oremployment. 

RSL believes that due to the size, weight, speed, and limited operating area associated with our proposed 

UAS operation, a PIC possessing a private pilot certificate and a current third-class medical certificate, and 

also having the aforementioned training and logged hours, would ensure safety and prevent creating any 

hazard to users of the National Airspace System (NAS) or the public. We therefore request an exemption 

from these parts of 14CFR. 

3. 14 CFR 91.7 (a), Airworthiness required foroperation 

If the exemption from 14 CFR 21, Subpart H(item 1 above) is granted, no airworthiness certificate will be 

required. On this basis, exemption from 14 CFR 91.7 (a) is requested, presuming that airworthy condition by 

definition in the rule means having an airworthiness certificate. RSL will, in lieu of airworthiness certification 

by 14 CFR 21, ensure that our UAS is in compliance with its operating documents as described herein. The PIC 

will assure that all Preflight Checks are completed and documented and execute full compliance with all 

manufacturer's operation and maintenance documents. 

4. 14 CFR 91.9, Aircraft Flight Manual, Marking, and Placard requirements 

This regulation provides that no person may operate an aircraft unless a current, approved flight manual is in 

the aircraft. We assume that the intent of this requirement is to ensure that flight manual information is 

available to the aircrew while operating the aircraft. We request an exemption to this requirement since the 

aircraft is not only too small to carry documentation, the documentation would not be available to the crew 

during flight operations. 

To obtain an equivalent level of safety and meet the intent of 91.9, we propose that a current, approved 

UAS Flight Manual must be available to the crew at the ground station anytime the aircraft is in, or 

preparing for flight. 

S. 14 CFR 91.103 (b) (2), Preflight action 

14 CFR 91.103 (b) (2) specifies that the PIC be familiar with aircraft performance under expected values of 

airport elevation and runway slope, aircraft gross weight, and wind and temperature. 

Since the RSL UAS will not be operating out of airports this rule is not applicable. On this basis, and on the basis 

that the operating documents cover requirements for operation safety, an exemption from this rule is 

requested. 

6. 14 CFR 91.105, Flight crewmembers atstations 
This part requires certain actions by onboard crewmembers. Since our UAS are unmanned, an 

exemption from this rule is requested. 

7. 14 CFR 91.109, Flight instruction 

14 CFR 91.109 describes requirements for flight instruction and requires that the aircraft used for flight 

instruction have fully functioning dual controls. The details pertain to manned airplanes and are not 

applicable to a small unmanned aircraft system. 

The UAS ground-based control station consists of a small hand-held radio transmitter and while it does not 

offer a second set of "controls", both the student and instructor can, and will, operate the single set of 

controls simultaneously. With both student and instructor having the ability to "hands-on" the controls 

during flight, we feel that this technique meets the intent 91.109 and provides an equivalent level of safety. 

S. 14 CFR 91.119 (c), Minimum safe altitudes 

14 CFR 91.119 (c) requires that no operation is permitted below 500 feet above the surface, except over open 

water and sparsely populated areas. The proposed use of our UAS is specifically for altitudes that range from 

the surface to maximum 400 feet AGL. On the basis of the aforementioned safety procedures, we believe 

there will be no increased hazard to users of the National Airspace System (NAS) or the public. 

9. 14 CFR 91.121, Altimetersettings 

14 CFR 91.121 provides specific rules for altimeter settings for cruising altitude and flight level of aircraft 

and speaks of altimeter stations along the route and the elevation of the departure airport. The UAS will 

always fly below 400 feet AGL and will not need to maintain cruising altitudes in order to prevent conflict 

with other aircraft. An Above Ground Level altimeter measurement above the takeoff point is transmitted 

via radio from the UAS on-board computer to the display screen held by the PIC, providing a constantly 

updated AGLreadout. 

On this basis, an exemption from this rule is requested. 

10. 14 CFR 91.151, Fuel requirements for flights in VFRconditions 

14 CFR 91.151(a) requires that no person may begin a flight under Visual Flight Rule (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. 

Our UAS have a built-in battery monitoringfunctions: 

(1) If the smart battery is depleted to the point that may affect the safe return ofthe aircraft, 

the low battery level warning notifies the PIC to take action. 

(2) The thresholds for these warnings are automatically determined based on the current 

aircraft altitude and its distance from the Home Point. 

(3) A color coded battery level indicator shows battery level, and an estimated remaining 

flight time in minutes is displayed. 

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As standard operating procedure, the PIC will immediately return the UAS to the Home Point for a battery 

swap when the battery level reaches259'o. 

On the basis of these specific safety features of battery power level monitoring, and operating 

procedures, an exemption from this rule is requested. 

11. 14 CFR 91.203 (a) &(b) Civil Aircraft: Certifications required 

The regulation provides that an airworthiness certificate, with the registration number assigned to the aircraft 

and a registration certificate must be aboard the aircraft. Additionally, subparagraph 

(b) provides that the airworthiness certificate be "displayed at the cabin or cockpit entrance so that it is 

legible to passengers or crew." 

The UAS that Resilient Solutions will use are too small to carry documentation, do not have an entrance, and are 

not capable of carrying passengers or crew. To obtain an equivalent level of safety and meet the intent of 91.203, 

we propose that documents deemed appropriate for this aircraft by the FAA will be co-located with the crew at 

the ground control station and available for inspection upon request. 

12. 14 CFR 91.405 (a), Maintenance required 

Please see exemption request explanation in item 15 below (14 CFR91.417). 

13. 14 CFR 91.407 (a) (1), Operation after maintenance 

Please see exemption request explanation in item 15 below (14 CFR91.417). 

14. 14 CFR 91.409 (a) (2), Inspections 

Please see exemption request explanation in item 15 below (14 CFR91.417). 

15. 14 CFR 91.417 (a) and (b), Maintenance records 

Parts 91.405 (a), 91.407 (a) (1), 91.409 (a) (2), and 91.417 (a) and (b), contain requirements for maintenance of 

larger aircraft. In lieu of adapting these rules for our UAS, RSL is requesting an exemption on the basis that it 

will inspect the UAS and ensure that it is in a condition for safe flight prior to beginning any operation. We 

propose that adherence to the operating documents describing the requirements for maintenance, 

inspection, and recordkeeping, are sufficient to ensure that safety is not adverselyaffected. 

REASONS SAFETY NOT ADVERSELY AFFECTED AND IS AT LEAST EQUIVALENT TO EXISTING RULE 

Following are some key features of Resilient Solutions UAS operations that assure thatsafety to the public and 

safety of the National Airspace System (NAS) is not adversely afFected: 

• Credentials and training for the Pilot in Command (PIC), along with detailed operating 

procedures in the Flight Operations Manual assure that the level of competency required for 

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successful and safe flight operations is achieved. 

• The built-in Flight Control System assures proper flight control data feedback to the Pilot in Command 

(PIC), and the FailSafe system ensures immediate return to the Home Point and safe landing for the D11 

Phantom 3 Professional under failure scenarios, thereby preventing injury ordamage. The FailSafe 

system for the Bixler ensures motor cutoff or assumption of a designated orbit in the event of a lost link. 

• Visual Line-of-Sight (VLOS) operation provided by the PIC and the Visual Observer (VO), and their 

ability to communicate verbally at all times, assures full operational control. 

• Detailed operations and maintenance procedures, including a Preflight Checklist, provide assurance of 

mechanical integrity and full functioning of our unmanned aircraft system prior to commencement of 

any operation. 

PUBLIC BENEFIT 

The current aircraft alternative to accomplish the tasks that Resilient Solutions envisions is a manned 

helicopter or fixed wing aircraft. The UAS, powered by batteries, is smaller, lighter and more maneuverable 

than manned aircraft running on combustible fuel. It operates at lower altitudes with no people on board 

and will thereby reduce current risk levels, enhance safety and diminish the likelihood of death or serious 

bodily injury to the pilots and the public. Reduction in the use of manned aircraft burning combustible fuel 

saves energy and reduces emissions from combustion engines. With a small payload and limited flight time, 

these aircraft offer little or no risk to national security. 

We submit that because of our UAS light weight, flight performance, ouradherence to the operating 

guidelines and restrictions in the Resilient Solutions Flight Operations Manual, and our structured, 

formal safety program, that the FAA can have full confidence that our UAS operation will have an 

equivalent or greater level of safetythan manned aircraft performingthe same mission. 

We are prepared to modify or amend any part of this request to satisfy the need for an equivalent 

level of safety. Please contact us at anytime if you require additional information or clarification. We 

lookforward to workingwith your office. 

SUMMARY FOR PUBLICATION IN FEDERALREGISTER 

Petition for Exemption 

Docket No.: FAA-2015-xxxx 

Petitioner: Resilient Solutions Ltd 

Section of 14 CFR 14 CFR 21 Subpart H, 61.113(a) and (b), 91.7 (a), 91.9, 91.103 (b) (2), 91.105, 

91.109, 91.119 (c), 91.121, 91.151, 91.203, 91.405 (a), 91.407 (a) (1), 91.409 (a) (2), 91.417 (a) 

and (b). 

Description of Relief Sought: The petitioner is seeking an exemption to utilize an unmanned aircraft 

system (UAS) to conduct photography, videography, training, surveys and inspections, and to 

provide targetry in the development of a tracking system for counter-UAS systems. 

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Sincerely, 

Arthur W Finehout 

Chief Operating Officer 

Resilient Solutions Ltd 

finehout@resilientsolutionsltd.com 

703-655-8764 

Attachment A— DJI Phantom 3 Professional Users Manual 

Attachment B— Bixler 1.1 Users Manual 

Attachment C: Resilient Solutions UAS Flight Operations Manual 

Attachment D: Resilient Solutions UAS Safety Program 

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