August 3, 2015

Exemption No. 12293

Regulatory Docket No. FAA–2015–1348

Mr. Dennis Hahn

Cadence Valley LLC

5086 Riverside Drive South

Salem, OR 97306

Dear Mr. Hahn:

This letter is to inform you that we have granted your request for exemption. It transmits our 

decision, explains its basis, and gives you the conditions and limitations of the exemption, 

including the date it ends.

By letter dated April 18, 2015, you petitioned the Federal Aviation Administration (FAA) on 

behalf of Cadence Valley LLC (hereinafter petitioner or operator) for an exemption. The 

petitioner requested to operate an unmanned aircraft system (UAS) to conduct video filming 

by air, photographing, inspecting, and training.

1

See Appendix A for the petition submitted to the FAA describing the proposed operations and 

the regulations that the petitioner seeks an exemption.

The FAA has determined that good cause exists for not publishing a summary of the petition 

in the Federal Register because the requested exemption would not set a precedent, and any 

delay in acting on this petition would be detrimental to the petitioner.

 

1 The petitioner also requested authority to conduct UAS training. At this time, the FAA is unable to authorize 

UAS operations for training until a further assessment is completed. When the FAA completes its review, we 

will proceed accordingly and no further action will be required by the petitioner. However, the petitioner is 

permitted to train its own pilot in commands and visual observers in accordance with condition no. 14 and the 

other conditions and limitations in this exemption.
2

Airworthiness Certification

The UAS proposed by the petitioner is a 3D Robotics IRIS+.

The petitioner requested relief from 14 CFR part 21, Certification procedures for products 

and parts, Subpart H—Airworthiness Certificates. In accordance with the statutory criteria 

provided in Section 333 of Public Law 112−95 in reference to 49 U.S.C. § 44704, and in 

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

aircraft and its operation, the Secretary of Transportation has determined that this aircraft 

meets the conditions of Section 333. Therefore, the FAA finds that the requested relief from 

14 CFR part 21, Certification procedures for products and parts, Subpart H—Airworthiness 

Certificates, and any associated noise certification and testing requirements of part 36, is 

not necessary.

The Basis for Our Decision

You have requested to use a UAS for aerial data collection2

. The FAA has issued grants of 

exemption in circumstances similar in all material respects to those presented in your petition. 

In Grants of Exemption Nos. 11062 to Astraeus Aerial (see Docket No. FAA−2014−0352), 

11109 to Clayco, Inc. (see Docket No. FAA−2014−0507), 11112 to VDOS Global, LLC (see

Docket No. FAA−2014−0382), and 11213 to Aeryon Labs, Inc. (see Docket No. 

FAA−2014−0642), the FAA found that the enhanced safety achieved using an unmanned 

aircraft (UA) with the specifications described by the petitioner and carrying no passengers or 

crew, rather than a manned aircraft of significantly greater proportions, carrying crew in 

addition to flammable fuel, gives the FAA good cause to find that the UAS operation enabled 

by this exemption is in the public interest.

Having reviewed your reasons for requesting an exemption, I find that—

• They are similar in all material respects to relief previously requested in Grant of 

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

• The reasons stated by the FAA for granting Exemption Nos. 11062, 11109, 11112, and

11213 also apply to the situation you present; and 

• A grant of exemption is in the public interest.

 

2 Aerial data collection includes any remote sensing and measuring by an instrument(s) aboard the UA. 

Examples include imagery (photography, video, infrared, etc.), electronic measurement (precision surveying, RF 

analysis, etc.), chemical measurement (particulate measurement, etc.), or any other gathering of data by 

instruments aboard the UA.
3

Our Decision

In consideration of the foregoing, I find that a grant of exemption is in the public interest. 

Therefore, pursuant to the authority contained in 49 U.S.C. 106(f), 40113, and 44701, 

delegated to me by the Administrator, Cadence Valley LLC is granted an exemption from 

14 CFR §§ 61.23(a) and (c), 61.101(e)(4) and (5), 61.113(a), 61.315(a), 91.7(a), 91.119(c), 

91.121, 91.151(a)(1), 91.405(a), 91.407(a)(1), 91.409(a)(1) and (2), and 91.417(a) and (b), to 

the extent necessary to allow the petitioner to operate a UAS to perform aerial data collection. 

This exemption is subject to the conditions and limitations listed below.

Conditions and Limitations

In this grant of exemption, Cadence Valley LLC is hereafter referred to as the operator.

Failure to comply with any of the conditions and limitations of this grant of exemption will be 

grounds for the immediate suspension or rescission of this exemption.

1. Operations authorized by this grant of exemption are limited to the 3D Robotics IRIS+

when weighing less than 55 pounds including payload. Proposed operations of any 

other aircraft will require a new petition or a petition to amend this exemption.

2. Operations for the purpose of closed-set motion picture and television filming are 

not permitted. 

3. The UA may not be operated at a speed exceeding 87 knots (100 miles per hour). The 

exemption holder may use either groundspeed or calibrated airspeed to determine 

compliance with the 87 knot speed restriction. In no case will the UA be operated at 

airspeeds greater than the maximum UA operating airspeed recommended by the 

aircraft manufacturer.

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

(AGL). Altitude must be reported in feet AGL.

5. The UA must be operated within visual line of sight (VLOS) of the PIC at all times. 

This requires the PIC to be able to use human vision unaided by any device other than 

corrective lenses, as specified on the PIC’s FAA-issued airman medical certificate or 

U.S. driver’s license.

6. All operations must utilize a visual observer (VO). The UA must be operated within 

the visual line of sight (VLOS) of the PIC and VO at all times. The VO may be used 

to satisfy the VLOS requirement as long as the PIC always maintains VLOS 

capability. The VO and PIC must be able to communicate verbally at all times; 

electronic messaging or texting is not permitted during flight operations. The PIC 

must be designated before the flight and cannot transfer his or her designation for the 
4

duration of the flight. The PIC must ensure that the VO can perform the duties 

required of the VO.

7. This exemption and all documents needed to operate the UAS and conduct its 

operations in accordance with the conditions and limitations stated in this grant of 

exemption, are hereinafter referred to as the operating documents. The operating 

documents must be accessible during UAS operations and made available to the 

Administrator upon request. If a discrepancy exists between the conditions and 

limitations in this exemption and the procedures outlined in the operating documents, 

the conditions and limitations herein take precedence and must be followed. 

Otherwise, the operator must follow the procedures as outlined in its operating 

documents. The operator may update or revise its operating documents. It is the 

operator’s responsibility to track such revisions and present updated and revised 

documents to the Administrator or any law enforcement official upon request. The 

operator must also present updated and revised documents if it petitions for extension 

or amendment to this grant of exemption. If the operator determines that any update 

or revision would affect the basis upon which the FAA granted this exemption, then 

the operator must petition for an amendment to its grant of exemption. The FAA’s 

UAS Integration Office (AFS−80) may be contacted if questions arise regarding 

updates or revisions to the operating documents.

8. 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 prior to conducting further operations under this exemption. 

Functional test flights may only be conducted by a PIC with a VO and must remain at 

least 500 feet from other people. The functional test flight must be conducted in such 

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

9. The operator is responsible for maintaining and inspecting the UAS to ensure that it is 

in a condition for safe operation.

10. Prior to each flight, the PIC must conduct a pre-flight inspection and determine the 

UAS is in a condition for safe flight. The pre-flight inspection must account for all 

potential discrepancies, e.g., inoperable components, items, or equipment. 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.

11. The operator must follow the UAS manufacturer’s maintenance, overhaul, 

replacement, inspection, and life limit requirements for the aircraft and 

aircraft components.

12. Each UAS operated under this exemption must comply with all manufacturer 

safety bulletins.
5

13. Under this grant of exemption, a PIC must hold either an airline transport, 

commercial, private, recreational, or sport pilot certificate. The PIC must also hold a 

current FAA airman medical certificate or a valid U.S. driver’s license issued by a 

state, the District of Columbia, Puerto Rico, a territory, a possession, or the Federal 

government. The PIC must also meet the flight review requirements specified in 

14 CFR § 61.56 in an aircraft in which the PIC is rated on his or her pilot certificate.

14. The operator may not permit any PIC to operate unless the PIC demonstrates the 

ability to safely operate the UAS in a manner consistent with how the UAS will be 

operated under this exemption, including evasive and emergency maneuvers and 

maintaining appropriate distances from persons, vessels, vehicles and structures. PIC 

qualification flight hours and currency must be logged in a manner consistent with 

14 CFR § 61.51(b). Flights for the purposes of training the operator’s PICs and VOs 

(training, proficiency, and experience-building) and determining the PIC’s ability to 

safely operate the UAS in a manner consistent with how the UAS will be operated 

under this exemption are permitted under the terms of this exemption. However, 

training operations may only be conducted during dedicated training sessions. During 

training, proficiency, and experience-building flights, all persons not essential for 

flight operations are considered nonparticipants, and the PIC must operate the UA 

with appropriate distance from nonparticipants in accordance with 14 CFR § 91.119.

15. UAS operations may not be conducted during night, as defined in 14 CFR § 1.1. All 

operations must be conducted under visual meteorological conditions (VMC). Flights 

under special visual flight rules (SVFR) are not authorized.

16. The UA may not operate within 5 nautical miles of an airport reference point (ARP) as 

denoted in the current FAA Airport/Facility Directory (AFD) or 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. The letter of agreement with the airport management must be made available 

to the Administrator or any law enforcement official upon request.

17. 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 PIC.

18. 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.

19. The PIC must abort the flight in the event of unpredicted obstacles or emergencies.

20. The PIC is prohibited from beginning a flight unless (considering wind and forecast 

weather conditions) there is enough available power for the UA to conduct the 
6

intended operation and to operate after that for at least five minutes or with the reserve 

power recommended by the manufacturer if greater.

21. Air Traffic Organization (ATO) Certificate of Waiver or Authorization (COA). All 

operations shall be conducted in accordance with an ATO-issued COA. The 

exemption holder may apply for a new or amended COA if it intends to conduct 

operations that cannot be conducted under the terms of the attached COA.

22. All aircraft operated in accordance with this 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.

23. Documents used by the operator to ensure the safe operation and flight of the UAS and 

any documents required under 14 CFR §§ 91.9 and 91.203 must be available to the 

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

These documents must be made available to the Administrator or any law enforcement 

official upon request.

24. The UA must remain clear and give way to all manned aviation operations and 

activities at all times. 

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

26. All 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 the UA and/or debris in the event of an accident. The operator must ensure 

that nonparticipating persons remain under such protection. If a situation arises 

where nonparticipating persons leave such protection and are within 500 feet of 

the UA, flight operations must cease immediately in a manner ensuring the safety 

of nonparticipating persons; and

b. The owner/controller of any vessels, vehicles or structures has granted permission 

for operating closer to those objects and the PIC has made a safety assessment of 

the risk of operating closer to those objects and determined that it does not 

present an undue hazard.

The PIC, VO, operator trainees or essential persons are not considered 

nonparticipating persons under this exemption.

27. All operations shall be conducted over private or controlled-access property with 

permission from the property owner/controller or authorized representative. 

Permission from property owner/controller or authorized representative will be 

obtained for each flight to be conducted.
7

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.

If this exemption permits operations for the purpose of closed-set motion picture and 

television filming and production, the following additional conditions and limitations apply.

29. The operator must have a motion picture and television operations manual (MPTOM) 

as documented in this grant of exemption.

30. At least 3 days before aerial filming, the operator of the UAS affected by this 

exemption must submit a written Plan of Activities to the local Flight Standards 

District Office (FSDO) with jurisdiction over the area of proposed filming. The 3-day 

notification may be waived with the concurrence of the FSDO. The plan of activities 

must include at least the following:

a. Dates and times for all flights;

b. Name and phone number of the operator for the UAS aerial filming conducted 

under this grant of exemption;

c. Name and phone number of the person responsible for the on-scene operation of 

the UAS;

d. Make, model, and serial or N−Number of UAS to be used;

e. Name and certificate number of UAS PICs involved in the aerial filming;

f. A statement that the operator has obtained permission from property owners 

and/or local officials to conduct the filming production event; the list of those 

who gave permission must be made available to the inspector upon request;

g. Signature of exemption holder or representative; and

h. A description of the flight activity, including maps or diagrams of any area, city, 

town, county, and/or state over which filming will be conducted and the altitudes 

essential to accomplish the operation.

31. Flight operations may be conducted closer than 500 feet from participating persons 

consenting to be involved and necessary for the filming production, as specified in the 

exemption holder’s MPTOM.

Unless otherwise specified in this grant of exemption, the UAS, the UAS PIC, and the UAS 

operations must comply with all applicable parts of 14 CFR including, but not limited to, 

parts 45, 47, 61, and 91.
8

This exemption terminates on August 31, 2017, unless sooner superseded or rescinded.

Sincerely,

/s/

John S. Duncan

Director, Flight Standards Service

Enclosures
Dennis Hahn

Cadence Valley LLC

5086 Riverside Dr S

Salem, OR 97306

dennis.hahn@mac.com 

858.603.2164 (cell) 

 18 April 2015

 

U.S. Department of Transportation, Docket Operations 

West Building Ground Floor, Room w12-140

1200 New Jersey Ave., SE Washington, DC 20590 

Re: Exemption Request Under Section 333 of the Federal Aviation Administration 

Modernization and Reform Act of 2012 

Dear Exemption Manager:

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 and 14 CFR Part 11, 

I hereby submit this application for an exemption from the Federal Aviation Regulations (FARs) 

identified within this request to allow commercial operations of small unmanned aerial vehicles, 

so long as the operations are conducted within and under the conditions described below or as 

may be established by the FAA as required by Section 333.

This requested exemption would permit my company, Cadence Valley, to operate small, 

unmanned aerial vehicles, commonly referred to as sUAS, under controlled conditions in the 

national airspace. Operations would be conducted using the 3D Robotics IRIS+ in accordance 

with aircraft operating procedures described in the IRIS+ Operation Manual and the IRIS+ flight 

checklist, both of which are attached herein. 

TYPE OF OPERATIONS 

The limited, predetermined operations would focus on the following: 

 (a) Video filming by air and photographing for public and private purposes, including: 

television, cinematography, advertising, promotions, public or news mass events. 

(b) Video filming by air and photographing to support professional operations in 

engineering, land surveying, architecture, real estate and other related professional 

activities. 

(c) Inspections by air of agricultural areas. 

(d) Inspections by air of infrastructure such as bridges, highways, electrical installations, 

dams, aqueducts, photovoltaic power stations, wind farms and pipes. These inspections 

will only be done under contract with property and facility owners or with applicable 
local government authority. 

(e) Inspection by air of land and residential, commercial and industrial structures, only 

under contract with the owners or with applicable local government authority. 

(f) Inspections by air to detect sources of pollution and gas emissions, under contract with 

the owners in the area or with applicable local government authority. 

(g) Inspections conducted specifically to support search and rescue operations and 

reconnaissance in cases of need, emergency or natural disasters and only when 

government authorities have requested it by contract or donation. 

(h) Operations conducted for the purpose of training to persons, private and public 

entities interested in the safe use of UASs, for purposes of enhancing the skills and safety 

controls that make the NAS safer and for the protection of persons and property. 

PUBLIC BENEFITS

Environmental and quality of life benefits: The IRIS+ is a relatively inexpensive sUAS that 

operates on rechargeable batteries. The sUAS is able to collect data and images previously only 

available through the operation of aircraft using fossil fuels, the use of which includes 

concomitant effects such as greenhouse gas emissions and loud engine noises that are often 

perceived as louder in rural areas. The targeted nature of sUAS operations can help to reduce 

flights over private landowners’ homes. 

Economic benefits: The operations described above provide competitive advantages to 

agricultural, real estate, engineering and other industries by offering aerial inspections that are 

high-quality, highly-controlled, more reliable, and accessible in real-time. Further, these 

operations are less costly, and would be available to businesses, including small businesses and 

individual farmers, that heretofore would have had to pursue more expensive alternatives or go 

without these types of services. For governments, being able to conduct activities critical to 

public safety using a more streamlined and less costly alternative frees up money in increasingly 

strapped public sector budgets for other services. 

Public safety and safety of the national airspace benefits: sUAS operations provide an 

obvious benefit to both those in need and those participating, on either a paid or volunteer basis, 

in search and rescue efforts. The portability and responsiveness of sUASs can provide necessary 

information quickly and efficiently during emergency situations. Training by professional pilots 

related to the safe operation of sUASs benefits individual operators seeking a pathway for 

professional, targeted education and is critical to the safe integration of UASs into the national 

airspace. Finally, this potential exemption supports the broader national goal of establishing 

requirements for the safe operation of sUAS in the national airspace. A grant exemption would 

support a broader review of the types of aircrafts that can operate in the national airspace safely, 

which is a necessary step for rulemaking required under Section 333 of the FAA Modernization 

and Reform Act of 2012.
PIC BACKGROUND 

In addition to my experience serving as the pilot-in-command of the sUAS described above, I am 

a military and FAA-rated civilian pilot: Commercial and Instrument Rated in Single Engine 

Fixed Wing and Rotary Wing Aircraft, Helicopter Airline Transport Pilot (ATP) and Certified 

Flight Instrument Instructor (CFI & CFII). I also hold and receive an annual medical flight “UpChit” from the U.S. Marine Corps and 2nd class or greater FAA medical certificate. 

My aviation background means that I prioritize safe aircraft operations above all else. I am 

conditioned to following pre-flight inspections and maintenance and repair procedures. If this 

exemption is approved, I understand I would be responsible for maintaining and inspecting the 

IRIS+ to ensure it is ready for safe operation and following all manufacturer safety bulletins. 

ADDITIONAL LEVEL OF SAFETY 

Further, if this exemption is granted, I would adhere at the very least to the following limitations 

and conditions: 

- Operations conducted at an altitude of no more than 400’ AGL.

- Operations conducted using an sUAS weighing less than 55 lbs. 

- Operations conducted within visual line of sight of the PIC.

- Operations conducted in conjunction with a safety observer who provides visual 

observations and is within communicable distance with the PIC at all times. 

- Operations conducted during daylight hours under visual meteorological conditions 

(VMC).

- No operations conducted within 5 nautical miles of an airport, unless prior approval has 

been granted from the appropriate airport and ATC facilities. 

- Operations conducted only after a weather assessment considering current and forecasted 

conditions is completed to ensure the sUAS can be operated within its limitations and 

provide enough power to ensure a 5 minute reserve. 

- All sUAS flights that occur over private or controlled access property will do so with the 

property owner's prior consent and knowledge. 

EXEMPTIONS AND SAFETY 

To build on the above, I seek exemption from the following FAA regulations: part 21, subpart H; 

and Sections 45.23, 45.29, 91.7(a), 91.9(b)(2), 91.103(b), 91.109, 91.119, 91.121, 91.151(a), 

91.203(a) and (b), 91.405(a), 91.407(a)(1), 91.409(a)(2), and 91.417(a) and (b) of Title 14, Code 

of Federal Regulations (14 CFR).

14 CFR Part 21, Airworthiness Certificates.
This part establishes the procedures for the issuance of an airworthiness certificate. While the 

FAA continues to work to develop airworthiness standards for sUAS, I request an experimental 

certificate be issued for the IRIS+ under either or both of the following provisions: 

21.191 Experimental certificates.

Experimental certificates are issued for the following purposes: 

(a) Research and development. Testing new aircraft design concepts, new aircraft equipment, 

new aircraft installations, new aircraft operating techniques, or new uses for aircraft.

(b) Showing compliance with regulations. Conducting flight tests and other operations to show 

compliance with the airworthiness regulations including flights to show compliance for issuance 

of type and supplemental type certificates, flights to substantiate major design changes, and 

flights to show compliance with the function and reliability requirements of the regulations. 

Since the experimental certificate can be used for commercial purposes such as market surveys, 

sales demonstrations, and customer crew training, I would expect that an experimental certificate 

would permit my proposed commercial purposes as well. The aircraft will not carry persons or 

property, will not carry fuel, and will only fly under strict operational requirements. Combined 

with the sUASs’ light weight, I propose that the sUAS will be at least as safe, if not safer, than a 

conventionally certificated aircraft performing the same mission. If an experimental 

airworthiness certificate is not appropriate for this application, then I request an exemption of 14 

CFR Part 21, Subpart H, and the requirement for an airworthiness certificate in general, citing 

the equivalent level of safety outlined above. 

14 CFR 45.23 Display of marks; general and 45.29 Size of marks. 

These regulations provide that each aircraft must display "N" and the aircraft's registration 

number in letters at least 3 inches high. Additionally, the aircraft must display the word 

"EXPERIMENTAL" in letters at least 2 inches high near the entrance to the cabin, cockpit, or 

pilot station. The sUAS does not have an entrance in which the word "EXPERIMENTAL" can be 

placed, and may not have a registration number assigned to it by the FAA. I propose to achieve 

an equivalent level of safety by including the word "EXPERIMENTAL" or FAA approved “N” 

number on a placard on the top of the aircraft where the PIC, VO and others in the vicinity of the 

aircraft while it is preparing for launch will be able to see the designation. 

14 CFR 91.7 Prohibits the Operation of an aircraft without an airworthiness certificate. 

I requests relief from this regulation on the basis that there is no FAA regulatory standard for determining the airworthiness of a UAS. The PIC will conduct preflight mission and maintenance 

inspection of UAS prior to any flight. Flights will be terminated and maintenance action initiated 

to troubleshoot and repair the sUAS if the PIC decides at any time the sUAS in not in a safe for 

flight condition. 

14 CFR 91.9 Civil 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. I assume that the intent of this requirement is to ensure that flight 
manual information is available to the aircrew while operating the aircraft. I 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 achieve an 

equivalent level of safety and meet the intent of 91.9, I propose that a current, approved sUAS 

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

preparing for, flight. 

14 CFR 91.103(b) Runway lengths at airports of intended use. 

I request relief from this regulation due to the nature of operating an sUAS. Runways will not be 

used. The PIC will conduct preflight planning using current satellite imagery such as “Google 

Earth” and current VFR Sectionals for the area and routing to be flown. PIC will also do a “walk 

through” of the area to be flown to verify obstacles and hazards that may exist. 

14 CFR 91.109 Flight Instruction; Simulated instrument flight and certain flight tests 

The regulation states, "No person may operate a civil aircraft that is being used for flight 

instruction unless that aircraft has fully functioning dual controls." The sUAS 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 "hands-on" the controls during flight, 

this technique meets the intent 91.109 and provides an equivalent level of safety. 

14 CFR 91.119 Minimum safe altitudes: General. 

The regulation states that over sparsely populated areas the aircraft cannot be operated closer 

than 500 feet to any person, vessel, vehicle, or structure. Since one typical mission of the sUAS 

would be photography or survey of persons, vessels, vehicles or structures, it would be necessary 

to operate closer than 500 feet to the items listed. Operations will only be flown over property or 

persons where permission has been obtained and careful pre-planned has been performed. The 

aircraft will be operated at a low altitude allowing, if a power unit fails, an emergency landing 

without undue hazard to persons or property on the surface. I respectfully submit that due to the 

small size of the sUAS, the hazard to persons, vehicles and structures is minimal compared to 

manned aircraft, which should be considered in granting the exemption. 

14 CFR 91.121 Altimeter settings. 

The regulation requires that aircraft shall maintain cruising altitudes by reference to an altimeter 

setting available within 100 NM of the aircraft. I requests relief from this regulation due to the 

UAS’s ability to use barometric and GPS derived altitude. AGL altitude will be used and sUAS 

will remain below 400’ AGL at all times. An Above Ground Level altimeter measurement above 

the takeoff point is transmitted via radio from the sUAS on-board computer to the display screen 

held by the PIC, providing a constantly updated AGL readout. 

14 CFR 91.151 Fuel requirements for flight in VFR conditions. 
I request relief from this regulation due to the UAS’s ability to only fly for 20-25 minutes with 

available battery life. I will not begin a flight unless (considering wind and forecast weather conditions) there is enough power for the UAS to conduct the intended flight and to operate after 

that for at least 5 minutes. Along with the “Return to Home” safety feature (which will automatically return the UAS to a predetermined safety landing area, we believe this will satisfy the “intent” of the regulation. The risk of fuel starvation (or total battery discharge) will be mitigated. 

The UAS also has warning displays to indicate battery “life”. I will only operate during day time 

hours (the hours between official sunrise and sunset) and only in VFR conditions as defined in 

FAR Part 91. 

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 IRIS+ is too small to carry documentation, does not 

have an entrance, and is not capable of carrying passengers or crew. To obtain an equivalent level 

of safety and meet the intent of 91.203, I 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. 

14 CFR Subpart E (91.401- 91.417) - Maintenance, Preventive Maintenance, Alterations 

The regulation provides that the operator is primarily responsible for maintaining the aircraft in 

an airworthy condition, including compliance with part 39 and 43. Paragraphs 91.407 and

91.409 require that the aircraft be "approved for return to service by a person authorized under 

43.7" after maintenance and inspection. As previously stated, the PIC will perform maintenance 

and inspection of the aircraft. The PIC will ensure that the aircraft is in an airworthy condition 

prior to every flight and conduct detailed inspections after every two hours of flight. 

Maintenance performed by the PIC is limited to repairing small cracks, replacing a propeller, 

checking electrical connections and updating software and firmware for the on-board computer. 

All other maintenance will be performed by the manufacturer or its designated repair facility. 

The PIC will document work performed in accordance with 91.417. I feel that due to the size, 

construction, and simplicity of the aircraft, the PIC can ensure an equivalent level of safety. 

Thank you for your consideration of this application. This exemption request is similar in scope 

to previously approved Grants of Exemption Nos. 11062, 11109, 1112, and 11213, and the 

information provided is intended to satisfy the requirements laid out by the FAA. I welcome any 

questions or requests for additional information to help expedite this exemption request. 

Respectfully, 

Dennis Hahn