September 5, 2015

U.S. Department of Transportation, Docket Operations

West Building, Ground Floor, Room W12-140

1200 New Jersey Avenue, SE

Washington, DC 20590

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, Airstrike Aerial Photography, LLC (“Airstrike”) owners and operators of the AEE AP10 

Toruk, seeks an exemption from the Federal Aviation Regulations (“FARs”) listed below and discussed in 

Appendix A. Details of Airstrike and the specifics of the sUAS are described in Appendix B. A summary 

of this request is attached as Appendix C.

The requested exemption would permit Airstrike commercial operation of Airstrike’s AEE AP10 Toruk 

(see details in Appendix B), which weighs less than 5 pounds with battery and factory installed imaging 

payload, to perform bank owned and FDIC owned real property inspections for maintenance and 

erosion control compliance, aerial photo services to the real estate market, and municipality 

infrastructure inspections that consist of still photographs, video, and other data taken by factory 

installed, onboard cameras.

The AEE AP10 Toruk produces high quality (16MP) still photographs and video that can be used in the 

assessment of current property conditions and the development and design of erosion remediation 

plans as required by the Georgia Soil and Water Conservation Commission (GSWCC) and in compliance 

with the National Pollution Discharge Elimination System (NPDES) of which the owner is certified as 

“Level-1A Certified Personnel”.

Applications for this sUAS include inspection of municipal and privately owned infrastructure including 

water holding towers, reservoir inlets and sensitive wetlands, emergency transmission antennas, bridge 

structures, farming facilities and other difficultly accessible areas. Use of the AEE AP10 Toruk for these 

inspection and surveying applications reduces the need to operate conventional aircraft, providing data 

more quickly, accurately, economically, safely, and with reduced environmental impact. Additionally, all 

of these services can be performed at low altitudes and mostly, away from the public.

Operations under the exemption will be subject to strict operating requirements and conditions to 

ensure at least an equivalent level of safety to currently authorized operations using manned aircraft 

and under conditions as may be modified by the FAA as required by Section 333. Additionally, Airstrike 

will distribute a flight plan/intent to any adjacent residences and/or businesses advising the time and 

scope of its operation, allowing ample feedback and necessary mediation.

(PAGE 1 OF 15)
As described more fully below, the requested exemption would authorize Airstrike to perform 

commercial operations of aerial inspections and photography using the AEE AP10 Toruk which weighs

less than 5 pounds in size and is powered electrically by battery. The AEE AP10 Toruk will be operated 

under controlled conditions at low altitudes with automated control features in airspace that is limited 

in scope. It is equipped as described in detail throughout this request. The AEE AP10 Toruk is a 

commercial rated craft and designed to be operated by one person but, flight operations generally 

involve two people including an operator and an observer.

The operator is responsible for flying the sUAS, monitoring its status and flight dynamics while 

maintaining a visual line of sight, and keeping the flight within the specified factory limits (in terms of 

wind, flight range, battery life, etc.) to ensure safe operation of the sUAS. The observer is responsible 

for monitoring the airspace for other aircraft and hazards and instructing the operator before and during 

flight as necessary to ensure safe operation and proper separation of any hazards. The operator also 

will be an individual who has passed an FAA approved or equivalent ground training exam and have 

passed an authorized Airstrike training program for the AEE AP10 Toruk. Finally, the airspace in which 

the AEE AP10 Toruk will operate will be disclosed to and approved as may be required by the FAA in 

advance. Under no circumstance will the AEE AP10 Toruk be operated within 5 miles of any public or 

private airport facility, without proper notification to that respective facility and proper authorization by 

that respective facility, as required by FAA.

Airstrike respectfully submits that because this small, commercial rated AEE AP10 Toruk will be used in 

lieu of comparatively hazardous operations now conducted with fixed wing, rotary conventional aircraft

and humans placed in very dangerous positions, the FAA can have confidence that the operations will 

achieve at least an equivalent level or greater level of safety. Approval of this exemption would thereby 

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

under Section 333(c) of the Reform Act to “establish requirements for the safe operation of such aircraft 

systems in the national airspace system.” Additionally, and in the interest of the public, there is a rising 

demand for this type exposition in photography quality and exterior home inspections by both real 

estate companies and home buyers.

The contact and responsible party for this request is:

Airstrike Aerial Photography, LLC

Donald L. Gordon

197 Shields Road

Stockbridge, GA 30281

(678) 428-1684

don.gordon@airstrikephotography.com

(PAGE 2 OF 15)
The regulations from which the exemption is requested are as follows:

14 C.F.R. Part 21

14 C.F.R. 45.23(b)

14 C.F.R. 61.113(a) & (b)

14 C.F.R. 61.133(a)

14 C.F.R. 91.7(a)

14 C.F.R. 91.9(b)(2) & (c)

14 C.F.R. 91.103

14 C.F.R. 91.109(a)

14 C.F.R. 91.119;

14 C.F.R. 91.151(a)

14 C.F.R. 91.203(a) & (b)

14 C.F.R. 91.405(a)

14 C.F.R. 91.407(a)(1)

14 C.F.R. 91.409(a)(2)

14 C.F.R. 91.417(a)

Appendix A discusses each rule listed above and explains why exemptions pursuant to the proposal set 

forth in this letter are appropriate, provide an equivalent level of safety, and are in the public interest.

THE APPLICABLE LEGAL STANDARD UNDER SECTION 333

Airstrike submits that grant of this exemption application for use of the AEE AP10 Toruk in general 

property compliance inspections, local municipality infrastructure inspections and its use in 

identification and reduction of serious erosion issues, will advance the Congressional mandate in Section 

333 of the Reform Act to accelerate the introduction of sUASs into the national airspace system (“NAS”) 

if it can be accomplished safely. This law directs the Secretary of Transportation to consider whether 

certain sUASs may operate safely in the NAS before completion of the rulemaking required under

Section 332 of the Reform Act. In making this determination, the Secretary is required to determine 

which types of sUASs do not create a hazard to users of the NAS or the public or pose a threat to 

national security in light of the following:

● The sUAS’s size, weight, speed, and operational capability

● Operaon of the sUAS in close proximity to airports and populated areas

● Operaon of the sUAS within visual line of sight of the operator

Reform Act § 333(a) (1)

If the Secretary determines that such vehicles “may operate safely in the national airspace system, the 

Secretary shall establish requirements for the safe operation of such aircraft in the national airspace 

system.” Id. §333(c) (emphasis added).2

(PAGE 3 OF 15)
The Federal Aviation Act expressly grants the FAA the authority to issue exemptions. This statutory 

authority, by its terms, includes exempting civil aircraft, as the term is defined under §40101 of the Act, 

from the requirement that all civil aircraft must have a current airworthiness certificate and those 

regulations requiring commercial pilots to operate aircraft in commercial service: The Administrator 

may grant an exemption from a requirement of a regulation prescribed under subsection (a) or (b) of 

this section or any of sections 44702-44716 of this title if the Administrator finds the exemption is in the 

public interest.

49 U.S.C. §44701(f). See also 49 USC §44711(a); 49 USC §44704; 14 CFR §91.203(a)(1).

The grant of the requested exemption is in the public interest based on the clear direction in Section

333 of the Reform Act; the additional authority in the Federal Aviation Act, as amended; the strong

equivalent level of safety surrounding the proposed operations; and the significant public benefit,

including enhanced safety and cost savings associated with transitioning to sUASs for aerial surveying,

mapping and inspection applications. Accordingly, the applicant respectfully requests that the FAA

grant the requested exemption without delay.

Airworthiness of the AEE AP10 Toruk

A critical element of the exemption application involves evidence of the airworthiness of AEE AP10 

Toruk sUAS. The AEE AP10 Toruk is manufactured by AEE Technology Co., LTD. The AEE AP10 Toruk is 

commercially rated and has a significant set of automated features to ensure safe takeoff, flight and 

landing in many conditions. Further details of operation and fail-safe features can be found in Appendix 

B. Airstrike welcomes the opportunity to consult with FAA staff in order to address any issues or 

concerns that this proposal may raise regarding the safe operation of this sUAS and the relative 

commercial rating.

Mandatory Operating Conditions

Grant of the exemption to Airstrike will be subject to the following mandatory conditions, which are 

based upon operating conditions set forth for operation of sUAS by public entities pursuant to

Certificates of Authorization, with additional restrictions:

● All operaons to occur in Class G airspace

● Operaons to avoid congested or populated areas, which are depicted in yellow on VFR charts

● Operaons to be conducted over private or controlled access property

● Permission from land owner/controller required before commencing any flight

● Operaons to occur during Visual Flight Rules Meteorological Conditions (VMC)

● Aircra to remain within Visual Line of Sight (VLOS) by both operator and observer

● VLOS guaranteed with a cylinder of operaon around operator of 1⁄2 nautical miles (NM)

● Cylinder walls may be expanded by observer with ability to control aircraft

● Operaons to occur during daylight hours

● Above Ground Level (AGL) altude to be restricted to 400 feet

● No operations to be conducted with 5 miles of any private or public airport

● All required permissions and permits will be obtained from territorial, state, county or city 

jurisdictions, including local law enforcement, fire, or other appropriate governmental agencies

● All operaons will include one pilot for flight control and at least one observer for VLOS enhancement 

of surrounding area near the aircraft

(PAGE 4 OF 15)
Operator Requirements

Airstrike respectfully proposes that operator requirements should take into account the characteristics 

of the particular sUAS. Certain sUASs, such as the AEE AP10 Toruk, are characterized by a high degree of 

preprogrammed control and various built-in technical capabilities that limit the potential for operation 

outside of the operating conditions set forth above. The AEE AP10 Toruk sUAS also provides many builtin functional, fail-safe and safety features to assist the operator in safe and reliable operation.

All flight operations are GPS controlled making the system easy to navigate, and the flight control 

system also employs a feature whereby, should the operator encounter an emergency during flight and

lose or release control of the transmitter, the AEE AP10 Toruk will stop in flight and hold its exact 

position until the operator regains control manually. If the signal from the operator controls is lost for 

more than 8 seconds, the AEE AP10 Toruk will program a return route and slowly return to the original 

launch position. The operator at any time during this descend can regain control of the sUAS.

Airstrike notes that the FAA has found that safety factors permitted operation of sUASs by operators

with these qualifications in the case of operations pursuant to public COAs when the mandatory 

operating conditions specified above were present. See Federal Aviation Administration, Notice

N8900.227, Unmanned Aircraft Systems (UAS) Operational Approval, at 2021 (July 30, 2013). The

FAA has the statutory authority to grant exemptions to the requirements for and privileges associated 

with the grant of airmen’s certificates. 49 USC §44701 (f).

In summary, Airstrike seeks an exemption from the FARs set forth above and in Appendix C to allow 

commercial operations of a small unmanned vehicle in surveying, aerial property inspections and aerial 

photo services to the real estate market.

Approval of the exemption allowing commercial operations of the AEE AP10 Toruk for these services 

outlined herein will enhance safety by reducing risk. Conventional aerial survey and inspection 

operations using manned aircraft involve very heavy aerial vehicles carrying significant quantities of 

combustible fuels, and a multi-person crew in piloting and observation roles. These operations require 

transit to and from the location of the activity, and often take place in congested environments 

including proximity to physical obstacles and/or presence of the general public. By contrast, the AEE 

AP10 Toruk, weighing less than 5 pounds including payloads and uses a battery for power, is carried 

to/from the area of activity, removes the need for airborne pilots/observers, and poses less risk to 

people and infrastructure on the ground.

Additionally, no national security issue is raised by the grant of the requested exemptions. Given the 

size, zero load carrying capacity, speed at which it operates, and the fact that it carries no explosives or 

other dangerous materials, the AEE AP10 Toruk poses no threat to national security. The operation of 

the AEE AP10 Toruk for photography and inspection operations in accordance with the strict conditions 

outlined above will provide an equivalent level of safety supporting the grant of the exemptions 

requested herein, including exempting Airstrike from the requirements of Part 21.

(PAGE 5 OF 15)
The AEE AP10 Toruk’s satisfaction of the criteria set forth in Section 333 of the Reform Act—size, weight,

speed, operating capabilities, lack of proximity to airports and populated areas, operation within visual 

line of sight, and national security and its showing of an equivalent level of safety as it may relate to the 

requirement for a pilot’s license, provide more than adequate justification for the grant of the requested 

exemptions allowing Airstrike commercial operation of the AEE AP10 Toruk in the services and 

inspection operations as outlined herein.

Respectfully Submitted,

Donald L. Gordon

Airstrike Aerial Photography, LLC - Owner

(PAGE 6 OF 15)
APPENDIX A

EXEMPTION REQUEST AND EQUIVALENT LEVEL OF SAFETY SHOWINGS UNDER

APPLICABLE RULES SUBJECT TO EXEMPTION

Airstrike requests an exemption from the following regulations as well as any additional regulations that 

may technically apply to the operation of the AEE AP10 Toruk:

14 C.F.R. Part 21, Subpart H: Airworthiness Certificates

14 CFR § 91.203(a)(1)

Section 91.203(a)(1) requires all civil aircraft to have a certificate of airworthiness. Part 21, Subpart H, 

entitled Airworthiness Certificates, establishes the procedural requirements for the issuance of 

airworthiness certificates as required by FAR § 91.203(a)(1). Given the size of the aircraft (6 lbs.) and the 

limited operating area associated with its utilization, it is unnecessary to go through the certificate of 

airworthiness process under Part 21 Subpart H to achieve or exceed current safety levels.

Such an exemption meets the requirements of an equivalent level of safety under Part 11 and Section 

333 of the Reform Act. The Federal Aviation Act 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 sUAS 

involved.

In this case, an analysis of these criteria demonstrates that the AEE AP10 Toruk operated without an 

airworthiness certificate, under the conditions proposed herein, will be at least as safe, or safer, than a 

conventional aircraft (fixed wing or rotorcraft) with an airworthiness certificate. The AEE AP10 Toruk 

weighs less than 5 pounds fully loaded and has no additional load bearing capabilities. It will not carry a 

pilot or passenger or flammable fuel, and will operate exclusively within areas disclosed herein and in 

compliance with conditions set forth herein. Operations under this exemption will be tightly controlled 

and monitored by both the operator, pursuant to the conditions set forth above, and by local public 

safety requirements. The automated safety features including redundant sensor systems as described in 

Appendix B and throughout this document highlight the design intentions towards safety and reliability 

of the AEE AP10 Toruk.

14 C.F.R. § 45.23 & 91.9(c): Marking of the Aircraft

Regulation 45.23 provides:

(a) Each operator of an aircraft must display on that aircraft marks consisting of the Roman capital letter 

“N” (denoting United States registration) followed by the registration number of the aircraft. Each suffix 

letter used in the marks displayed must also be a Roman capital letter.

(b) When marks include only the Roman capital letter “N” and the registration number is displayed on 

limited, restricted or light sport category aircraft or experimental or provisionally certificated aircraft, 

the operator must also display on that aircraft near each entrance to the cabin, cockpit, or pilot station, 

in letters not less than 2 inches nor more than 6 inches high, the words “limited,” “restricted,” “light 

sport,” “experimental,” or “provisional,” as applicable.

Regulation 91.9(c) provides:

No person may operate a U.S. registered civil aircraft unless that aircraft is identified in accordance with 

part 45 of this chapter.

(PAGE 7 OF 15)
The AEE AP10 Toruk has no entrance to the cabin, cockpit, or pilot station on which the markings can be 

placed. Given the size of the sUAS, two inch lettering will be impossible. Official marking systems for 

small UAS have not yet been established for operations inside the NAS. The AEE AP10 Toruk is currently 

marked with a fixed label containing Manufacture ID and Serial Number. Airstrike is prepared to mark 

the inspection system with the name of the organization with contact information and fulfill any other 

request by the FAA to this topic in accordance to § 45.29(f) where the pilot, observer, and others 

working with the sUAS will see the identification of the sUAS.

The FAA has issued the following exemptions to this regulation (see Exemption Nos. 8738, 10167,

10167A and 10700)

.

14 C.F.R. § 61.113(a) & (b); 61.133(a): Private Pilot Privileges and Limitations; Pilot in Command; 

Commercial Pilot Privileges and Limitations.

Section 61.113(a) & (b) limit private pilots to noncommercial operations. 

Unlike a conventional aircraft that carries a pilot, passengers, and cargo, the AEE AP10 Toruk is remotely 

controlled with no passengers or property of others on board. Section 61.133(a) requires an individual 

with a commercial pilot’s license to be pilot in command of an aircraft for compensation or hire. 

Airstrike respectfully proposes that operator requirements should take into account the characteristics 

of the particular sUAS. Airstrike’s AEE AP10 Toruk has a high degree of preprogrammed control and 

engineered technical capabilities that strictly limit the potential for operation outside of the operating 

conditions set forth in the exemption application. The AEE AP10 Toruk has an all-digital software 

platform with advanced features previously restricted to full size unmanned aircraft. Automated 

features and advanced fly safe controls enable safe, reliable operation, as well as advanced networking 

capabilities and system extensibility.

● The AEE AP10 Toruk is equipped with a series of flashing lights at start up signaling the operator of 

certain conditions and will not fly until the operator calibrates and or corrects these conditions.

-Compass Calibration

-Accelerometer Calibration

-Gyro Calibration

-Barometric Calibration

-GPS satellite downloads 

● Smart baeries and charger: Flight time and battery condition is monitored at all times. The system 

will default to a fail-safe, return home mode and land automatically if user control signals are lost or if 

battery capabilities have been exceeded by extended flight of operator.

● Controller Signal loss: The AEE AP10 will return to original launch position if the operator signal is lost 

during flight. 

● Automatic preflight checks: The system self-calibrates all of its sensors and performs a self-test prior 

to takeoff. 

● FPV: The operator has a “bird’s eye” view via attachment of a smart phone/device to the controls. 

The operator does not have to rely solely on line of sight view from the ground.

Given these safety features, Airstrike proposes that operators of the AEE AP10 Toruk should not be 

required to hold a commercial or private pilot certification. Instead, operators should be required to:

(PAGE 8 OF 15)
● have successfully completed, at a minimum, FAA private pilot ground instruction and passed the FAA 

Private Pilot written examination or FAA recognized equivalents including ICAO issued commercial, 

private license and ground school.

● have completed Airstrike’s training program for operation of the sUAS.

● have completed a minimum of 10 hours operation of the AEE AP10 Toruk in an open, safe 

environment away from any people, structures or obstacles.

Airstrike notes that the FAA has found that safety factors permitted operation of sUASs by operators 

with these qualifications in the case of operations pursuant to public COAs where the mandatory 

operating conditions specified above are present. See Federal Aviation Administration, Notice 

N8900.227, Unmanned Aircraft Systems (UAS) Operational Approval, at 2021 (July 30, 2013).

The FAA has the statutory authority, granted at 49 U.S.C. §44701(f) to waive the pilot requirements for 

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

provided by allowing operation of the AEE AP10 Toruk without a private pilot’s certificate or a 

commercial pilot’s certificate, under the conditions set forth herein. The risks associated with the 

operation of the AEE AP10 Toruk (given its size, speed, operational capabilities, and lack of combustible 

fuel) are so diminished from the level of risk associated with private pilot operations or commercial 

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

operations of the sUAS as set forth above meets or exceeds the present level of safety provided under 

14 C.F.R. § 61.113(a) & (b) and does not rise to the level of requiring a commercial pilot to operate the 

aircraft under § 61.133(a).

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

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

Should the exemption be granted allowing commercial operation of the AEE AP10 Toruk without an 

airworthiness certificate, no standard will exist for airworthiness of the AEE AP10 Toruk. Given the size 

of the aircraft and the COAs issued for Airstrike’s AEE AP10 Toruk, an equivalent level of safety will be 

achieved by ensuring compliance with the Airstrike’s manuals prior to each flight.

14 C.F.R. § 91.9(b)(2): Civil Aircraft Flight Manual in the Aircraft.

The regulation 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.

Given the size and configuration of the AEE AP10 Toruk, it 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 achieved by keeping 

the flight manual (see, e.g., User Guide, Exhibit 1) at the ground control point where the pilot flying the 

sUAS will have immediate access to it.

The FAA has issued to others the following exemptions to this regulation: Exemption Nos. 8607, 8737, 

8738, 9299, 9299A, 9565, 9565B, 10167, 10167A, 10602, 32827, and 10700.

(PAGE 9 OF 15)
14 C.F.R. § 91.103: Preflight action

This regulation requires each pilot in command to take certain actions before flight to insure the safety 

of flight. As FAA approved rotorcraft flight manuals will not be provided for the aircraft an exemption 

will be needed. An equivalent level of safety will be provided as set forth in the AEE AP10 Toruk’s User 

Manual (exhibit 1) under the ‘Getting Ready to Fly’ section. The PIC will take all actions including 

reviewing weather, flight battery requirements, landing and takeoff distances and aircraft performance 

data before initiation of flight.

14 C.F.R. § 91.109(a) & 91.319(a)(1): Flight Instruction

These regulations provide 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 AEE AP10 Toruk is a remotely piloted aircraft and by design, does not have fully functional dual 

controls. Flight control is accomplished through the use of a control box that communicates with the 

aircraft via a WIFI radio repeater. The flight plan is manually controlled by the operator as the sUAS is

operated. If instruction is accomplished through a training program, as set forth in Exhibit 2, an 

equivalent level of safety will be assured. The FAA has approved exemptions for flight training without 

fully functional dual controls for a number of aircraft and for flight instruction in experimental aircraft. 

See Exemption Nos. 5778K & 9862A. The equivalent level of safety will be achieved by the 

manufacturer providing the training as outlined, for example, in Exhibit 2 and through the use of 

experienced and qualified pilots familiar with the AEE AP10 Toruk.

14 CFR § 91.119: Minimum Safe Altitudes

Section 91.119 establishes safe altitudes for operation of civil aircraft. Specifically, 91.119(c) limits 

aircraft flying over areas other than congested areas to an altitude of 500 feet above the surface, except 

over open water or sparsely populated areas. In those cases, the aircraft may not be operated closer 

than 500 feet to any person, vessel, vehicle, or structure.

As set forth herein, the AEE AP10 Toruk will never operate at higher than 400 feet AGL. It will, however, 

be operated to avoid congested or populated areas that are depicted in yellow on VFR sectional charts.

Because aerial survey, mapping and inspection work must be accomplished at relatively low altitudes 

and at altitudes less than 500 feet AGL, an exemption from Section 91.119(c) is needed.

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

the AEE AP10 Toruk is built. Also, no flight will be taken without the permission of the land owner or 

those who control the land. Because of the advance notice to the landowner, all affected individuals will 

be aware of the flights. Compared to aerial survey operations conducted with aircraft or rotorcraft 

weighing far more than 5 lbs. and carrying flammable fuel, any risk associated with these operations will 

be far less than those currently allowed with conventional aircraft operating at or below 500 feet AGL. 

Indeed, the low altitude operations of the sUAS will maintain separation between these sUAS operations 

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

(PAGE 10 OF 15)
14 C.F.R. § 91.151(a): Fuel Requirements for Flight in VFR Conditions

This regulation 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 AEE AP10 Toruk battery system provides approximately 25 minutes of powered flight. Without an 

exemption from § 14 CFR 91.151, the sUAS’s flights would be limited to approximately 20 minutes in 

length. Given the limitations on its proposed operations and the location of those proposed operations, 

a longer time frame for flight in daylight VFR conditions is reasonable. Airstrike believes that an 

exemption from 14 CFR § 91.151(a) is safe and within the scope of a prior exemption. See Exemption 

10673 (allowing Lockheed Martin Corporation to operate without compliance with 91.151(a)). 

Operating the sUAS, without 30 minutes of reserve fuel does not engender the type of risks that Section 

91.151(a) was meant to prevent given the size and speed at which the sUAS operates. The fact that it 

carries no pilot, passenger, or cargo also enhances its safety. Additionally, limiting AEE AP10 Toruk

flights to 20 minutes would greatly reduce their utility. In the unlikely event that the AEE AP10 Toruk 

should run out of fuel (low battery), it would simply land. Given its weight and construction material, 

the risks are less than contemplated by the current regulation.

Airstrike believes that an equivalent level of safety can be achieved by maintaining 10 minutes of 

reserve fuel, which, allowing 40 minutes of flight time, would be more than adequate to return the sUAS 

to its planned landing zone from anywhere in its operating area. The FAA has granted similar 

exemptions to others, including Exemptions 2689F, 5745, 10673 and 10808.

14 C.F.R. § 91.203 (a) & (b): Carrying Civil Aircraft Certification and Registration

This regulation provides as follows:

(a) ... no person may operate a civil aircraft unless it has ... an appropriate and current airworthiness 

certificate.

(b) No person may operate a civil aircraft unless the airworthiness certificate required by paragraph (a) 

of this section or a special flight authorization issued under §91.715 is displayed at the cabin or cockpit 

entrance so that it is legible to passengers or crew.

The AEE AP10 Toruk fully loaded weighs less than 5 pounds. As such, there is no ability or place to carry 

certification and registration documents or to display them on the sUAS. In addition, there is no pilot on 

board the aircraft. An equivalent level of safety will be achieved by keeping these documents at the 

ground control point where the pilot flying the sUAS will have immediate access to them. The FAA has 

issued numerous exemptions to this regulation. A representative sample of other exceptions includes 

Exemption Nos. 9565, 9665, 9789, 9789A, 9797, 9797A, 9816A, and 10700.

14 C.F.R. § 91.405(a); 407(a)(1); 409(a)(2); 417(a): Maintenance Inspections

Section 91.405(a) requires that an aircraft operator or owner “shall have that aircraft inspected as 

prescribed in subpart E of this part and shall between required inspections, except as provided in 

paragraph (c) of this section, have discrepancies repaired as prescribed in part 43 of this chapter ...”

(PAGE 11 OF 15)
Section 91.407 similarly makes reference to requirements in Part 43; Section 91.409(a) (2) requires an 

annual inspection for the issuance of an air worthiness certificate. Section 91.417(a) requires the owner 

or operator to keep records showing certain maintenance work that has been accomplished by 

certificated mechanics, under Part 43, or licensed pilots and records of approval of the aircraft for return 

to service.

The AEE AP10 Toruk is nearly maintenance free, it performs automatic preflight checks and the failure of

any check will prevent takeoff. Checks which cannot be done by the system will be performed by a 

qualified person prior to each flight and at predefined intervals as part of the Maintenance Schedule in

the User Manual (see Exhibit 1).

Preflight checklist includes:

1. Visual inspection of the airframe

2. Visual inspections of rotor integrity

3. Check charge of all batteries (aerial vehicle, command station, radio repeater station)

4. Visual inspection of all lights for proper operation

An equivalent level of safety will be achieved because the sUAS is small in size, will carry no external 

payload, will operate only in restricted predetermined areas and is not a complex mechanical device.

As provided in the attached User Guide (System Maintenance section), the operator of AEE AP10 Toruk 

will ensure that the sUAS is in working order prior to initiating flight, perform required maintenance, and 

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

with the aircraft and is best suited to maintain the aircraft in an airworthy condition and to ensure an 

equivalent level of safety.

The AEE Ap10 Toruk’s maintenance guidelines and pre-flight checklist ensure an equivalent level of 

safety to the maintenance requirements in Part 91. In addition, any component failure detectable by

the system will be indicated and will cause the UAV to perform a Fatal Condition Response (FCR) or NonFatal Conditioned Response (NFCR), depending on the type of failure.

APPENDIX B

SMALL UNMANNED AERIAL SYSTEM DESCRIPTION

Airstrike’s Corporate Overview: Airstrike Aerial Photography, LLC is a U.S. company located in 

Stockbridge, GA. Airstrike is focused on providing micro unmanned aerial system services and captured 

images to local municipalities, construction companies, real estate service providers and other private 

parties as the needs develop. Airstrike’s owner, (through another company) has provided inspection 

and property maintenance services for the FDIC, banks and private land owners on vacant acreage for 

several years and recognizes the need for better, more thorough inspection processes beyond where a 

person can travel. Many properties border streams and bodies of water whereby shorelines are 

impossible to reach. The AEE AP10 Toruk will enable accurate, low flight images of these areas and 

better aid owners in developing a sustainable erosion remediation program. The real estate market has 

proven aerial photography is a huge sale booster. With low-flight aerial images, a potential buyer can 

get a better “3-D” image of a property from all angles.

(PAGE 12 OF 15) 
AEE AP10 Toruk Overview: AEE Technology Co., LTD is a global leader and provider of recording 

equipment, body cameras, multi-rotor UAV Systems and Unmanned Aircraft technology. The 

development of the F-100 auto tracking UAV system allows law enforcement and the military to lock 

onto moving or stationery targets and monitors them from a ground station. These systems are used for 

anti-terrorism, anti-rioting, traffic monitoring and disaster, relief and rescue situations. This technology 

and experience has transformed into the AEE AP10 Toruk. Many features have already been covered in 

this Exemption Request. The AEE AP10 Toruk is a very sophisticated, commercial rated, digital 

computerized sUAS encompassing a series of operational sensors that aid in stability, compensation for 

temperature and barometric pressure, stabilization via GPS control and fail-safe, return home features 

which minimize any possible hazard to the environment or people on the ground

 

All flight operations are GPS controlled making the system extremely easy to navigate. At any point if

the operator is not explicitly commanding the system to move, the system automatically holds its GPS

position (i.e. GPS hold for reliable location hover). Camera positioning is also GPS controlled allowing for 

the most sophisticated camera targeting available. The flight control system employs not only GPS

positioning but a variety of sensors including sonar, barometric pressure, temperature, wind speed and

others to ensure the most stability of any system in its commercial class.

The AEE AP10 Toruk can be operated in both manual and GPS flight modes. While Airstrike has issued 

strict compliance to GPS operational mode, the manual mode is available as a backup in the event of 

signal loss whereby adequate control can be maintained and not have the sUAS return on its own.

The series of lights on the motorized arms have distinct flashing sequence modes that indicate to the 

operator current flight and equipment conditions, allowing ample time to recover and abort a mission 

prior to any problems. Equally, the linked smart device attached to the controls indicates these 

conditions as well. The battery life remaining is divided into equal thirds and the lights blink in a specific 

sequence indicating same.

The AEE AP10 is a 6 axis system allowing very stable operation. The handheld transmitter operates at 

915 MHz and includes a safety lanyard to prevent accidental dropping of the unit while in flight.

Propulsion System

● Engines - The AEE AP10 Toruk is powered by 4 electric brushless DC motors.

● Batteries - 5400mAh Lithium Polymer batteries are removable and lock in place during operation.

● Propellers – 4 each, 10” heavy plastic with stainless steel reverse directional threaded mounts 

Performance Characteristics

● Maximum Altude – 1,680 feet

● Maximum Endurance - 28 minutes

● Wheelbase – 1.48 feet

● Maximum Tilt Angle – 35 degrees

● Winds Maximum – 8-10 MPH sustained

● Hover Accuracy – Horizontal=6.5 feet, Vertical=3.2 feet (GPS Mode)

● Camera Resolution – 4608 X 3456

● Icing conditions – light snow

● Precipitation – light drizzle

● Temperature Operating Range - 32-122F

(PAGE 13 OF 15)
Maintenance

The UAS is nearly maintenance free, it performs automatic preflight checks and the failure of any check 

will prevent takeoff. Checks not performed (visual) by the system will be performed by a qualified 

person prior to each flight.

Preflight Checklist

● Visual inspecon of the airframe

● Visual inspecons of rotor integrity

● Check charge of all baeries (aerial vehicle, command staon, radio repeater station)

● Check all landing gear and motor mount screws

Reliability

The system is designed for maximum reliability and to maintain performance over its life.

The only components that experience routine wear are rotors, batteries and motors. Battery conditions 

are monitored by the system with deviations reported to the operator. Motors will be check each 

month or every 10 hours for proper amperage. Rotors are protected by mounted propeller guards

which will prevent a fatal crash in the event of light contact with objects. Any damaged components are 

likely to be detected during the full visual inspection of the airframe performed before each flight. 

The UAV system detects numerous conditions which may make flying unsafe, such as reduced GPS

accuracy, magnetic anomalies, low battery charge, battery cell imbalances, and temperature

fluctuations.

 .

Takeoff and Landing

The AEE AP10 Toruk has vertical lift autonomous launch and recovery. A Landing Zone “LZ” is 

designated by the operators and identified in the GPS software. For launch procedures the aircraft will 

power up and hold until further operator instruction is given. 

Navigation System

The navigation system is manually controlled by the operator with the assistance and stability of GPS

sensors. Only during a signal loss or power reduction will the sUAS return safely to its original launch 

site and slowly land, shutting down.

Redundant Systems

The UAS combines the input from a multitude of sensors. Even though the data from all sensors is 

required for optimal system performance, a single sensor malfunction is likely to result in degraded 

performance rather than leading to a catastrophic failure.

Loss of Line of Sight

All flight operations will be conducted with the sUAS within visual sight of the pilot. If the pilot’s view 

becomes obstructed and line of sight is lost, the pilot may instruct the sUAS to hover in place until line of

sight is reestablished, to return to the takeoff position, or to land at the current position.

(PAGE 14 OF 15)
APPENDIX C

SUMMARY OF AIRSTRIKE AERIAL PHOTOGRAPHY, LLC SECTION 333 EXEMPTION REQUEST

Airstrike hereby provides pursuant to Part 11 a summary of its exemption application to allow

commercial operation of the AEE AP10 Toruk small unmanned system in precision aerial photography

and inspections. An exemption is requested from the following regulations:

14 C.F.R. Part 21;

14 C.F.R. 45.23(b);

14 C.F.R. 61.113(a) & (b);

14 C.F.R. 61.133(a);

14 C.F.R. 91.7(a);

14 C.F.R. 91.9(b)(2) & (c);

14 C.F.R. 91.103;

14 C.F.R. 91.109(a);

14 C.F.R. 91.119;

14 C.F.R. 91.151(a);

14 C.F.R. 91.203(a) & (b);

14 C.F.R. 91.405(a);

14 C.F.R. 91.407(a)(1);

14 C.F.R. 91.409(a)(2);

14 C.F.R. 91.417(a).

(PAGE 15 OF 15)