Exemption Request Pursuant to Public Law 112-95, Section 333 of the FAA 

Reform Act and Part 11 of the Code of Federal Regulations from: 14 CFR 21 

subpart H; 14 C.F.R. 45.23; 14 C.F.R. 45.29; 47.3(b)(2); 14 CFR 47.31(c);14 C.F.R 

§§ 61.113(a) & (b); 14 C.F.R. 91.103(b); 14 CFR 91.109(a); 14 CFR 91.119(d)(1); 

14 CFR 91.121; 14 CFR 91.131(b)(1); 14 CFR 91.131(d)(1)&(2); 91.151(b), CFR 

91.203(a)&(b); 14 C.F.R. 91.403(b)&(c); 14 CFR 91.405; 14 CFR 91.407; 14 CFR 

91.409; 14 CFR 91.417; 14 C.F.R. 91.7; CFR 91.9(b)(2) 

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

"Reform Act") and 14 CFR Part 11, Slope Control LLC of Virginia, operator of a 

small Unmanned Aircraft System (UAS), hereby applies for an exemption from the 

listed Federal Aviation Regulations ("FARs") to allow commercial operation of its 

UAS, so long as such operations are conducted within and under the conditions 

outlined herein or as may be established by the FAA as required by Section 333. 

Intended applications of UAS: 

 1. Right of Way inspection. 

 2. Infrastructure monitoring of gas lines, damns, bridges and buildings, towers 

and power lines.

 3. Clean Air Act and Clean Water Act monitoring of point source emission of 

solids, liquids and gases.

 4. Agriculture and Timber - Mapping and evaluation of geography, flora, and 

fauna. 

 5. Construction Site Visual Inspection and mapping - Enables better site 

planning and more precise autonomous machine control.

 6. Emergency Observation - Assist police and fire personnel with 

reconnaissance in a support capacity and as directed under official 

supervision.

 7. Environmental Monitoring - Applicant can provide visual evidence of 

pollution, construction, development impact on surrounding wildlife, and 

other man made effects on land. 
8. Flood Monitoring - Provide visual evidence of flood, rising water, and 

 drainage impact on client’s land over a period of time at specific elevations 

and coordinates unreachable by foot or vehicle. 

9. Real Estate - Aerial photography and/or video for public and/or private use 

 including real estate, architecture, land surveying, engineering and other 

 related professional activities. 

10. Research and Development of engine powered utility quadcopter which will 

 have extend range, duration, and payload. One anticipated benefit to the 

 public is transmission line right of way maintenance with an aerial side 

 trimming saw.

Benefit to the Public

All ten of the activities mentioned above can be successfully performed with UAS 

while using less fuel and endangering fewer pilots and people on the ground, than 

can be achieved by traditional aircraft. 

Research and development of an engine powered machine provides a template for 

a gas turbine powered quadcopter, which will have a much smaller size than a 

traditional helicopter. A single engine and variable pitch rotors is a template the 

petitioner thinks is viable on a larger scale machine. Variable pitch rotor 

quadcopters like the Curtis Youngblood Stingray 500, HobbyKing Reaper 500 and 

the WL Toys V383 Gallop 500 use single electric motors rather than multiple 

electric motors and the power is distributed mechanically. The central power plant 

and mechanical distribution to the rotors is a platform which the petitioner thinks is 

suited to much bigger machines that the common multi out runner motor layout. 

Petitioner’s patent number US6957731 B2 entitled Drive System for Stability and 

Directional Control of Vehicles and Aircraft can allow for broader operating 

parameters than variable pitch rotors can offer on their own. 6957731 anticipates a 

hybrid drive of engine and motors. 

As described fully below, the requested exemption would permit the operation of a 

UAS under controlled conditions in the NAS that would be a) limited b) controlled 

c) predetermined and d) will provide safety enhancements to the already safe 

operations in the industry presently using conventional aircraft. Approval of this 

exemption would thereby enhance safety and fulfill the Secretary of 

Transportation's and the FAA Administrator's responsibilities to "....establish 

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

Regulations from which the exemption is requested:

14 CFR 21 subpart H; 

14 C.F.R. 45.23; 

14 C.F.R. 45.29; 

14C.F.R 47.3(b)(2); 

14 CFR 47.31(c)

14 C.F.R §§ 61.113(a) & (b)

14 C.F.R. 91.103(b)

14 CFR 91.109(a) 

14 CFR 91.119(d)(1) 

14 CFR 91.121 

14 CFR 91.131(b)(1)

14 CFR 91.131(d)(1)&(2) 

14 C.F.R. 91.151(b) 

14 CFR 91.203(a)&(b) 

14 C.F.R. 91.403(b)&(c) 

14 CFR 91.405 

14 CFR 91.407 

14 CFR 91.409

14 CFR 91.417 

 14 CFR 91.9(b)(2) 

The Petitioner will operate the UAS in line of sight within a predetermined area 

owned and/operated by the property representative. Given the small size of the 
UAS and the controlled environment provided, the proposed operations will adhere 

to the Reform Act's safety requirements. The approval of this application presents 

no national security issues. Regarding the level of safety surrounding the proposed 

operations and the public benefit, reduction in environmental impacts, including 

but not limited to reduced emissions and noise. The grant of the requested 

exemption is in the public interest. Accordingly, the Petitioner requests that the 

FAA grant the requested exemption with minimum delay. 

AIRCRAFT AND EQUIVALENT LEVEL OF SAFETY 

The operation limitations proposed for an equivalent or higher level of safety 

because operations will further enhance the safety of persons, property and also 

manned aircraft in the NAS. These limitations and conditions to which the 

Petitioner, hereafter referred to as the operator, agrees to adhere to when 

conducting commercial operations under the FAA issued exemption limitations, 

and as set forth in the Flight Operations Manual (FOM) include:

1. The small UAS, as specifically designated and described in this petition, will 

weigh less than 55 lbs including payload.

2. The UAS will be operated within visual line of sight (VLOS) at all times by the 

operator or visual observers. (VO).

3. The UAS will remain close enough to the operator so that human vision unaided 

by any device other than corrective lenses will be used.

4. The UAS will not be operated over persons not directly involved in the 

operation unless those persons remain under a covered structure.

5. The UAS will only be operated during daylight (official sunrise to official sunset 

of local operation area) unless specific authorization from the FAA is granted prior 

to operations. 

6. The operator may use VOs for certain operations and will ensure each VO is 

trained on procedures listed in the operator's FOM.

7. The UAS will not be operated at a speed exceeding 87 knots (100 miles per 

hour) using ground speed 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.

8. The UAS will be operated at an altitude of no more than 400 feet above ground 

level (AGL). Altitude will be measured in feet AGL. If an object to be inspected, 

such as an antenna, exceeds 400 feet AGL, the operator will limit the flight to 

within 200 feet higher than the structure being photographed. The operator will 

notify the FAA and local authorities of the proposed plan to include date, time, 

location and height of the object to be inspected prior to operations. The UA will 
be flown in safe manner in close proximity to the object as to not interfere with 

traffic in the NAS. 

9. The UAS will not be operated unless visibility is greater than day requirements 

listed in 14 CFR 91.155 for the Class of airspace at the operator's ground station, 

on location. 10. The UAS will not be operated in Class A airspace (18,000 feet and 

above).

11. The operator will receive ATC permission prior to operations in Class B, C, D 

and E airspace. 

12. The operator will ensure that any VOs, if used, will only monitor one UAS at 

any given time.

13. The operator will not allow operations from a moving vehicle or aircraft, 

except for watercraft on the water. 

14. The operator will not conduct any careless or reckless operations. A flight will 

be terminated immediately as possible if the safety of the operation cannot be 

maintained. 

15. Prior to each flight, the operator will 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. 

16. The operator will not operate any UA if a physical or mental condition would 

prevent the safe operation of that aircraft.

17. When using a VO or VOs, the operator and VO must be able to communicate at 

all times. Radio communications or communication-assisting devices may be used. 

Electronic messaging or texting will not be permitted during flight operations. 

Daisy- chaining of VOs for the purpose of expanding the operations area will not 

be permitted. 

18. The operator will be responsible to see and avoid all other users of the NAS in 

which the UAS is operating. 

19. The holder of this exemption will be responsible to ensure its aircraft are 

properly registered in accordance with 14 CFR Part 47, and have identification (NNumber) markings in accordance with 14 CFR Part 45, Subpart C. Markings must 

be as large as practicable. 

20. The UAS operator will be designated before the flight and cannot transfer his 

or her designation for the duration of the flight unless a medical duress or 

unforeseen emergency is preventing safe operation of the UAS. In which case the 

VO, who has been deemed qualified and trained in the operation of the UAS, will 

operate the controls to land the UA in a predetermined "emergency plan" set forth 
by the operator who was granted this exemption. The holder of this exemption 

must ensure that VOs, if used, can perform the duties required of aVO. 

21. Documents for UAS operations and maintenance will be made available to the 

FAA upon request. If a discrepancy exists between the conditions and limitations in 

this exemption and the procedures outlined in the FOM, the conditions and 

limitations herein take precedence and must be followed. Otherwise, the operator 

must follow the procedures as outlined in the FOM. The operator may update or 

revise its operating documents. It is the operator's responsibility to track such 

revisions and present revised documents to the FAA or any law enforcement 

official upon request. If the operator determines that any update or revision would 

affect the basis upon which the FAA granted an 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. 

22. Any UAS that has undergone maintenance or alterations that affect UAS 

operations or flight characteristics, e.g. replacement of a flight critical component, 

must undergo an operational check flight prior to conducting further operations 

under this exemption. Operational check flights may only be conducted by a 

qualified operator familiar with the specific UAS being checked and must remain 

500 feet from any persons unless they remain under a covered structure. (NPRM 

wording) The operational check flight must be conducted in such a manner so as to 

not pose an undue hazard to persons and property. 

23. The operator is responsible for maintaining and inspecting the UAS to ensure 

that it is in a condition for safe operation.

24. The operator must follow the UAS manufacturer's maintenance; overhaul, 

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

components. 

25. The holder of this exemption will follow manufacturer's safety bulletins for 

each UAS operated under this exemption.

26. The holder of this exemption will ensure that each operator is 17 years or older, 

a US citizen and has a state issued driver's license. 

27. The holder of this exemption will require that its operators demonstrate the 

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

operated in this petition, including evasive and emergency maneuvers and 

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

Qualification flight hours and currency may be logged in a manner consistent with 

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

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

safely operate the UAS in a manner consistent with how the UAS will be operated, 
will be permitted. However, training operations may only be conducted during 

dedicated training sessions. During training, proficiency, and experience-building 

flights will be conducted 500 feet from any persons that are not intended to be part 

of such training operations unless those persons remain under a covered structure. 

28. The operator will use UAS that have safety features allowing it to return to a 

preset location if it loses communications with its ground station. The operator will 

set this pre- determined location within the private or controlled-access property as 

to minimize any possible contact with objects. 

29. The operator is prohibited from beginning a flight (considering wind and 

forecast weather conditions) unless there is enough available power for the UA to 

conduct the intended operation and to operate after that with at least 25% energy 

reserves or with the reserve power recommended by the manufacturer, whichever 

is greater. The operator will perform training tests, in a designated training area as 

prescribed herein, to assess the true energy characteristics of the specific UAS 

battery system to determine the actual flight time for reserve battery power. Said 

energy tests will deem the "safety" operating procedure for actual emergencies and 

useful flight time.

30. The exemption holder will ensure that operators and VOs have a copy of this 

exemption, the FOM and applicable aircraft registrations located at the ground 

station during operations. These documents will be made available to the 

Administrator or any law enforcement official upon request. 

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

with permission from the property owner/controller or authorized representative.

32. The exemption holder will be responsible to report to the FAA any small UAS 

operation that results in: 

(1) any injury to a person; or (2) damage to property other than the small 

unmanned aircraft. The report would have to be made within 10 days of the 

operation that resulted in injury or damage to property. Accidents will be reported 

to the National Transportation Safety Board (NTSB) per instructions contained on 

the NTSB Web site: www.ntsb.gov. Current NTSB accident reporting is required 

when 1) Any person suffers death or serious injury. 2) Any UAS with max gross 

takeoff weight exceeding 300 pounds sustains substantial damage. 

Operations for closed-set motion picture and television filming and production 

include the following limitations:

33. The operator must have a motion picture and television operations manual 

(MPTOM) in his/her possession.
34. At least 3 days before aerial filming, the operator of the UAS 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;

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. 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;

f. Signature of operator or representative; and

g. 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.

35. Flight operations may be conducted over/near participating persons consenting 

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

operator's MPTOM.

Regulations from which the exemption is requested: 

Lastly, application of these same criteria demonstrates that there is no credible 

threat to national security posed by the UAS, due to its size, speed of operation, 

location of operation, nearly silent operation, lack of explosive materials or 

flammable liquid fuels, and inability to carry a substantial external load. 

14 CFR 45.23 and 14 CFR 45.29 : Marking 

The Diatone Blade 250 measures 10 inches diagonally and is only 2 inches tall 

with no body panels, so markings are not viable. 

The Slope Control Air Gasoline Air Tractor will be marked experimental. 

14 CFR 47.3(b)(2) and 14 CFR 47.31(c) and 14 CFR 91.203(a)(2): Registration 

required 

This regulation states in part: No person may operate an aircraft that is eligible for 

registration under 49 U.S.C. 44101- 44104 unless the aircraft is carrying aboard the 
temporary authorization required by §47.31(c). Part 91.203(a)(2) reads similar. The 

Petitioner will be operating small UAS. Placing registration paperwork inside the 

UA will be impractical. An equivalent level of safety can be achieved by the 

Petitioner ensuring that all temporary or permanent registration paperwork for the 

UAS being operated is located on site at the ground station as stated in item 30 in 

this document. 

14 C.F.R §§ 61.113(a) & (b)

14 CFR Part 61 in its current form applies to manned aircraft. 14 CFR 61.3 refers 

specifically to flight crew members who is defined in Part 1. 1 as a pilot, flight 

engineer, or flight navigator assigned to duty "in an aircraft" during flight time; 

therefore no exemptions from Part 61 is being sought for as it is not applicable at 

the time of this exemption request. 

14 CFR 91.103(b) 

Section 91.103 requires each pilot to preflight an aircraft before flight to insure the 

safety of flight. As FAA approved rotorcraft flight manuals will not be used, an 

exemption is requested. However, an equivalent level of safety will be provided. 

The PIC will take all actions, including reviewing weather, flight battery 

requirements, landing and takeoff distances, and aircraft performance data before 

commencement of flight. 

14 CFR 91.109(a): Flight Instruction 

Section 91.1 09(a) provides that no person may operate a civil aircraft (except a 

manned free balloon) that is being used for flight instruction unless that aircraft has 

fully functioning dual controls. The Petitioner will be operating small UAS that do 

not have fully functional dual controls. Flight control is accomplished through the 

use of a control box transmitter that communicates with the aircraft via radio 

communications. The equivalent level of safety is provided by the fact that neither 

a pilot nor passengers will be carried in the aircraft and by the size and speed of the 

aircraft. Flight instruction is accomplished by handing the transmitter between the 

instructor and trainee or by the use of a buddy box system. Instruction will also be 

accomplished in accordance with item 27 in this document. 

14 CFR 91.119(d)(1): Minimum Safe Altitudes 

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

91.119(d)(1) allows helicopters to be operated at less than the minimums 

prescribed, provided the person operating the helicopter complies with any route or 

altitudes prescribed for helicopters by the FAA. As this exemption is for a UAS 
that is similar to a helicopter and the exemption requests authority to operate at 

altitudes up to 400 AGL, or not more than 200 above a structure from which 

filming is planned, an exemption may be needed to allow such operations. As set 

forth herein, the UAS will never operate at higher than 400 AGL with the 

exception that in circumstances where the UAS is used to survey or photograph a 

structure whose height exceeds 00 feet AGL, the UAS will not be operated more 

than 200 feet above the highest point on the structure in accordance with 

procedures outlined in item 8 of this document. 

The equivalent level of safety will be achieved given the size, weight, 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 or local officials. Because of the advance 

notice to the property owner and participants in the filming activity, all affected 

individuals will be aware of the planned flight operations. Compared to flight 

operations with aircraft or rotorcraft weighting far more than the maximum 55 lbs. 

proposed herein and the lack of flammable fuel, noise and any risk associated with 

these operations is far less than those presently presented with conventional aircraft 

operating at or below 400 AGL. In addition, the low-altitude operations of the UAS 

will ensure separation between these UAS operations and the operations of 

conventional aircraft that must comply with Section 91.119. The procedures 

outlined in this document prohibit flight over persons not involved in operations 

unless they remain under a covered structure. 

14 CFR 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 small 

UAS does not have a barometric altimeter, but instead a GPS altitude read out, an 

exemption may be needed. An equivalent level of safety will be achieved by the 

operator, pursuant to the safety check list and live flight data monitoring, 

confirming the altitude of the launch site shown on the GPS altitude indicator 

before flight. Flights will be conducted 400 feet above that read out or within 200 

feet above the highest point of the structure being filmed as outlined in item 8 of 

this document 

14 CFR 91.131(b)(1): Pilot requirements for Class B airspace 

This regulation states that no person may operate a civil aircraft within a Class B 

airspace unless that person is a private pilot, recreational pilot, sport pilot or is a 
student pilot that meets requirements of §61.94 or §61.95 of this chapter. An 

exemption from this regulation may be required. An equivalent level of safety will 

be achieved by operating the small UAS at altitudes listed in the limitation section 

of this document. The UAS will not be landing or departing from airports in Class 

B airspace nor flying through Class B airspace. The UAS will be flown in a 

controlled environment within VLOS. The UAS operator will require ATC 

permission prior to conducting operations and will give right of way to any 

manned aircraft. 

14 CFR 91.131 (d)(1 )&(2): Equipment requirements for Class B airspace 

The regulation states that no person may operate an aircraft in Class B airspace 

unless it is equipped with a transponder and after January 1, 2020 an ADS-Bout 

system. An exemption may be required. Due to the size, weight and payload 

capacity of the small UAS, installing these systems is not practical. An equivalent 

level of safety will be achieved by operating the small UAS at altitudes listed in the 

limitations section of this document. The UAS will not be landing or departing 

from airports in Class B airspace nor flying through Class B airspace. The UAS 

will be flown in a controlled environment within VLOS. The UAS operator will 

require ATC permission prior to conducting operations and will give right of way 

to any manned aircraft. 

14 C.F.R. 91.151 Fuel Requirements for Flight in VFR Conditions 

14 C.F.R. 91.151 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 UAS provides approximately 12 minutes of 

powered flight which is less than the reserve requirement alone by FARs 

for day or night VFR flight. Given the limitations on the UAS's flight 

envelope, proposed AOR size, battery life and its ability to land 

immediately it is reasonable to allow an exception. 
An equivalent level of safety can be achieved by limiting flights to 25% 

of battery power. This restriction would be more than adequate to return 

the UAS to its planned landing zone in the AOR. 

Similar exemptions have been granted to other operations, including 

Exemptions 2689F, 5745, 10673 and 10808. 

Given the experimental nature of the the Slope Control Gasoline Air 

Tractor, the exemption allows for data accumulation in generating a 

specification sheet and safe operating instructions while the machine is 

in development.

14 CFR Part 21, Subpart H and 14 CFR §91.203(a)(1)&(b): Airworthiness 

Certificates

Subpart H, entitled Airworthiness Certificates, establishes the procedural 

requirements for the issuance of airworthiness certificates as required by 14 CFR 

91.203(a)(1 ). Given the size and limited operating area associated with the aircraft 

to be utilized by the Petitioner, an exemption from Part 21 Subpart H meets the 

requirements of an equivalent level of safety under Part 11 and Section 333 of the 

Reform Act. The Federal Aviation Act (49 U.S.C.§44701 (f)) and Section 333 of 

the Reform Act both authorize the FAA to exempt aircraft from the requirement for 

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

operational capability, and proximity to airports and populated areas of the 

particular UAS. In all cases, an analysis of these criteria demonstrates that the UAS 

operated without an airworthiness certificate, in the restricted environment and 

under the conditions proposed will be at least as safe, or safer, than a conventional 

aircraft (fixed wing or rotorcraft) operating with an airworthiness certificate 

without the restrictions and conditions proposed. 

The UAS to be operated hereunder is less than 55 lbs. fully loaded, carries neither 

a pilot nor passenger, carries no explosive materials or flammable liquid fuels, and 

operates exclusively within a secured and designated area. Unlike other civil 

aircraft, operations under this exemption will be tightly controlled and monitored 

by both the operator and under the requirements and in compliance with local 

public safety requirements. These safety enhancements provide a greater degree of 

safety to the public and property owners than conventional operations conducted 

with airworthiness certificates issued under 14 C.F.R. Part 21, Subpart H. 
14 C.F .R. 91.403(b)&(c); 91.405; 91.407; 91.409; 91.417: Maintenance and 

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, have discrepancies repaired as prescribed in part 43 of this chapter...," 

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

Part 43 only applies to aircraft with a US airworthiness certificate or foreign 

registered aircraft operating in common carriage under provisions of Part 121 or 

135. These sections will not apply to the Petitioner who will be operating a small 

UAS. An equivalent level of safety will be achieved as the UAS will be maintained 

in accordance with the UAS manufacturer's instructions and limitations listed in 

the operator's FOM. The small UAS will carry a small payload and operate in a 

controlled area for a limited period of time. If mechanical issues arise the UAS can 

land immediately and will be operating from no higher than 400 feet AGL, without 

prior FAA authorization. The operator will ensure that the UAS is in working order 

prior to initiating flight, perform required and preventative maintenance, and keep 

a log of any maintenance performed. Moreover, the operator is the person most 

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

condition to provide the equivalent level of safety. 

14 C.F.R. 91.7(a): Civil Aircraft Airworthiness: 

14 C.F.R. 91.7(a) prohibits the operation of an aircraft without an airworthiness 

certificate. As no such certificate will be applicable in the form contemplated by 

the FARs, this regulation is inapplicable. 

14 CFR 91.9(b)(2): Civil Aircraft Flight Manual in the Aircraft 

Section 91.9(b)(2) provides: No person may operate a U.S.-registered civil 

aircraft ... (2) For which an Airplane or Rotorcraft Flight Manual is not required by 

§21.5 of this chapter, unless there is available in the aircraft a current approved 

airplane or Rotorcraft Flight Manual, approved manual material, markings, and 

placards, or any combination thereof. The UAS, given its size and configuration 

has no ability or place to carry such a flight manual on the aircraft, not only 

because there is no pilot on board, but because there is no room or capacity to carry 

such an item on the aircraft. The equivalent level of safety will be maintained by 

keeping the UAS flight manual at the ground station where the UAS operator will 

have immediate access to it. 
Summary 

Petitioner hopes that satisfaction of criteria provided in Section 333 of the Reform 

Act of 2012 is justification for the grant of the requested exemptions allowing the 

commercial operation of the Petitioner's UAS. Petitioner hopes to be positive and 

safe influence in this growing part of aviation. If additional information or revision 

is needed please contact me. 

Regards, 

Towles 

Thomas Towles Lawson, Jr. 

(434) 566-2370 

towleslawson@gmail.com