Section of 14 CFR which we seek exemption from:

Pursuant to the provisions of the Federal Aviation Regulations (14 C.F.R. § 11.61) and the FAA 

Modernization and Reform Act of 2012 (FMRA), Section 333, Special Rules for Certain 

Unmanned Aircraft Systems, hereby petitions the Administrator to commercially operate 

various, UAS in the National Airspace System (NAS), and for an exemption from the 

requirements of 14 C.F.R §§ 61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 91.405(a), 

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

In consideration of the speed, weight, size, and limited operating area associated with the 

unmanned aircraft and its operation, The operation of various UAS meets the conditions of 

FMRA Section 333 and therefore, will not require an airworthiness certificate in accordance with 

14 C.F.R. Part 21, Subpart H. 

Accordingly, we requests relief from Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 

91.417(a) & (b), as these sections set forth requirements for maintenance that only apply to 

aircraft with an airworthiness certificate. 

We submit that the requested relief is proper since an equivalent level of safety will be ensured. 

We will use experienced personnel or technicians to perform maintenance, alterations, or 

preventive maintenance on the UAS using the methods, techniques, and practices prescribed in 

the operating documents (i.e., Monthly Maintenance Log, Op Specs, etc). Furthermore, we will 

document and maintain all maintenance records for the individual UAS we operate. 

Relief from certain requirements of Section 61.113(a) and (b), entitled Private pilot privileges 

and limitations: Pilot in command, is requested to the extent necessary to allow a Pilot in 

Command (PIC) holding a private pilot or higher level certificate, as well as an airman medical 

certificate, and who has demonstrated, by meeting minimum flight hour and currency 

requirements, that the PIC is able to safely operate the various UAS in a manner consistent with 

this exemption, including evasive and emergency maneuvers and maintaining appropriate 

distances from people, vessels, vehicles and structures. 

We seeks relief from Section 91.7(a), entitled Civil aircraft airworthiness, because the various 

UAS do not require an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart 

H. As such, We submit that we will ensure that the various UAS are in an airworthy condition, 

prior to every flight, by determining that the UAS are in compliance with the operating 

documents (i.e., Monthly Maintenance Log, and Op Specs, etc), and that the aircraft are in a 

condition for safe flight. 

We also seek an exemption from the requirements of Section 91.121, entitled Altimeter 

Settings, as the various UAS will not have a typical barometric altimeter onboard. However, 

altitude information of the UAS will be provided to the PIC via Global Positioning System (GPS) 

equipment and radio communications telemetry data link, which downlinks from the UA to the 

GCS for active monitoring of the flight path. This altitude information, combined with our 
operation of the UAS within visual line of sight, at or below 400 feet AGL, will ensure a level of 

safety equivalent to Section 91.121. 

Additionally, we seek an exemption from the requirements of Section 91.151(b), entitled Fuel 

requirements for flight in VFR conditions. We submit that safety will not be affected by operation 

of the UAS during daylight hours in visual meteorological conditions (VMC) under visual flight 

rules (VFR), with enough battery power to fly for a total duration of less than 30 minutes. Battery 

power indicators are also able to show exactly how much battery power is left, as well as how 

much time is needed to return safely back to point of take off. 

SIMILAR EXEMPTIONS 

This request is similar in all/or many material respects to relief previously requested in Grant of 

Exemption Nos. 11062, 11109, 11112, 11213, and 12701

Benefit to Public Interest

Granting these exemptions would benefit the public, by giving additional opportunities to 

educate other UAS operators, such that they would be able to operate safely in the NAS. In 

addition to education, the UAS may be used for aerial monitoring. Visual and other sensors will 

allow monitoring from the air with minimum endangering of the public, or the situation being 

monitored. The small craft are able to get into places where manned aircraft cannot, and are 

able to be carefully maneuvered without contacting structures. 

Should the UAS detect and unsafe condition, it will either return to the launch site, or drop to the 

ground. Modern UAS controller systems such as the Pixhawk controller have enabled a new 

level of safety greatly reducing the workload on the UAS operator. The operator will be in control 

at all times, the controller will only augment that control. 

A majority of our planned operations will be for training of other UAS operators. Keeping other 

operators aware of the current situation of the UAS and NAS developments will greatly enhance 

the NAS keeping other pilots safe. Keeping the operators and pilots safe will help the general 

public avoid being injured from poor operations. 

Prior to any flight, the UAS will be inspected for potential points of failure, and other damage. If 

the system is not deemed safe for flight, the defect will be logged for maintenance personnel to 

make suitable repairs. As part of the pre-flight inspection maintenance logs will be reviewed to 

insure any prior issue has been properly repaired. 

All operations will be conducted with two or more operators, a pilot and an observer. Using two 

operators will enhance safety allowing the pilot to concentrate on current situation, and the 

observer to any threats to the UAS or anyone in the vicinity. Additional crew (IE sensor 

operator) will be used when mission dictates.

These specifications meet with the Model Aircraft Operating Standards as set below: 
● The petitioner will only operate its UAS in line-of-sight of a pilot and/or observer and will 

operate at sites that are `sufficient distance' from populated areas within the sterile area 

described in the FOPM. 

● Such operations will ensure that the UAS will "not create a hazard to users of the 

national airspace system or the public." 

● When flying the UAS within three (3) miles of an airport, airport operators will be notified 

and the operator will give the right-of-way to avoid flying in the proximity of full-scale

aircraft. Maximum flight time for each operation will be 30 minutes. 

● Flights will be terminated when battery levels reach 25%, allowing sufficient reserve 

flight time to safely land the UAS. 

● Minimum crew for each operation shall consist of: UAS pilot, a visual UAS observer, and 

if using any cameras, the camera operator. 

● The UAS PIC will be an FAA licensed airman holding a minimum of a Private Pilot 

certificate and a current FAA medical certificate. 

● The UAS operated by the petitioner weighs less than 25 pounds, including all payload 

(i.e. camera, lens, and stabilized gimbal). 

● The UAS will operate at speeds of no more than 50 knots, can hover, and can 

simultaneously move vertically and horizontally. 

● Given the small size of the UAS and the restricted sterile environment within which it will 

operate, operations adhere to the Reform Act's safety requirements.