AFS-14-323-E

Exemption No. 11112

UNITED STATES OF AMERICA

DEPARTMENT OF TRANSPORTATION

FEDERAL AVIATION ADMINISTRATION

WASHINGTON, DC 20591

 

In the matter of the petition of 

 

VDOS GLOBAL, LLC Regulatory Docket No. FAA-2014-0382

 

for an exemption from §§ 91.9 (b)(2);

91.9(c); 91.203(a) and (b); 91.207(a)(2)

91.405(a) and (b); 91.407(a)(1); 

91.409(a)(1); and 91.417(a) of Title 14, 

Code of Federal Regulations 

 

GRANT OF EXEMPTION

By letter dated June 2, 2014, Mr. Brian Whiteside, President of VDOS Global, LLC, 230 SW 

6th Street, Corvallis, Oregon 97333 petitioned the Federal Aviation Administration (FAA) for 

an exemption from §§ 91.9(b)(2); 91.9(c); 91.203(a) and (b); 91.207(a)(2); 91.405(a) and (b); 

91.407(a)(1); 91.409(a)(1); and 91.417(a) of Title 14, Code of Federal Regulations (14 CFR). 

The exemption would allow operation of unmanned aircraft systems (UAS) for the purpose of 

flare stack inspections on fourteen Shell Oil Gulf of Mexico production platforms that are

beyond 12 nautical miles (nm) from the coast of the United States. 

The petitioner requests relief from the following regulations:

Section 91.9(b)(2) prescribes that no person may operate U.S.-registered civil aircraft 

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.

Section 91.9(c) prescribes that no person may operate a U.S.-registered civil aircraft 

unless that aircraft is identified in accordance with part 45 of the chapter.
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Section 91.203(a) prohibits any person from operating a civil aircraft unless it has within 

it (1) an appropriate and current airworthiness certificate; and (2) an effective U.S. 

registration certificate issued to its owner or, for operation within the United States, the 

second copy of the Aircraft Registration Application as provided for in § 47.31(c)

Section 91.203(b) prescribes that no person may operate a civil aircraft unless the 

airworthiness certificate 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.

Section 91.207(a)(2) requires, in pertinent part, that when operating a flight other than 

one under parts 121, 125, or 135, there must be attached to the airplane an approved 

personal type or an approved automatic type emergency locator transmitter that is in 

operable condition.

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

inspected as prescribed in subpart E of the same part and shall, between required 

inspections, except as provided in paragraph (c) of the same section, have discrepancies 

repaired as prescribed in part 43 of the chapter.

Section 91.405(b) requires that an aircraft operator or owner shall ensure that 

maintenance personnel make appropriate entries in the aircraft maintenance records 

indicating the aircraft has been approved for return to service.

Section 91.407(a)(1) prescribes that no person may operate any aircraft that has 

undergone maintenance, preventive maintenance, rebuilding, or alteration unless it has

been approved for return to service by a person authorized under § 43.7 of this chapter.

Section 91.409(a)(2) prescribes that no person may operate an aircraft unless, within the 

preceding 12 calendar months, it has had an inspection for the issuance of an 

airworthiness certificate in accordance with part 21.

Section 91.417(a) prescribes that—

(a) Each registered owner or operator shall keep the following records for the 

periods specified in paragraph (b) of this section:

(1) Records of the maintenance, preventive maintenance, and alteration and 

records of the 100-hour, annual, progressive, and other required or 
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approved inspections, as appropriate, for each aircraft (including the 

airframe) and each engine, propeller, rotor, and appliance of an aircraft. 

The records must include—

(i) A description (or reference to data acceptable to the Administrator) of 

the work performed; and 

(ii) The date of completion of the work performed; and 

(iii) The signature and certificate number of the person approving the 

aircraft for return to service.

(2) Records containing the following information: 

(i) The total time in service of the airframe, each engine, each propeller, 

and each rotor. 

(ii) The current status of life-limited parts of each airframe, engine, 

propeller, rotor, and appliance.

(iii) The time since last overhaul of all items installed on the aircraft that 

are required to be overhauled on a specified time basis. 

(iv) The current inspection status of the aircraft, including the time since 

the last inspection required by the inspection program under which 

the aircraft and its appliances are maintained. 

(v) The current status of applicable airworthiness directives (AD) and 

safety directives including, for each, the method of compliance, the 

AD or safety directive number and revision date. If the AD or 

safety directive involves recurring action, the time and date when the 

next action is required.

(vi) Copies of the forms prescribed by § 43.9(d) for each major alteration 

to the airframe and currently installed engines, rotors, propellers, and 

appliances.
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The petitioner supports its request with the following information:

The petitioner has provided the following information – contained in its petition and 

proprietary supporting documentation: 1) VDOS Operations Guide, and 2) Aeryon 

SkyRangerTM User Guide (all collectively referred to as operator’s manual) – in support of its 

exemption request. 

The FAA has organized the petitioner’s information into four sections: 1) the unmanned 

aircraft system, 2) the UAS Pilot In Command (PIC), 3) the UAS operating parameters and 

4) public interest. 

Unmanned Aircraft System

The unmanned aircraft system (UAS) VDOS proposes to use is constructed by Aeryon Labs, 

Inc. and referred to as the Aeryon SkyRanger (hereafter referred to as SkyRanger). The 

SkyRanger is commonly referred to as a quad copter (4 rotors and 4 motors) which weighs a 

total of 5.3 pounds (lbs.) without payload and is powered by lithium polymer batteries. It can 

carry payloads up to 600 grams (1 lb., 5 ounces) resulting in a total weight of no more than 

61⁄2 lbs. and has an operational range of up to 1.6 nautical miles. The SkyRanger can be 

operated with a maximum wind threshold of 40 miles per hour (MPH) for sustained winds 

and wind gusts up to 55 MPH.

The SkyRanger can be operated entirely by a touch-screen, map-based interface. This means 

the operator only needs to command the system where to go, and the system does all the 

flying for the operator. The SkyRanger can be operated in both semi and fully autonomous 

flight modes, with the operator simply clicking on a map to create a pre-planned flight path 

for a flight. In addition, the operator can create no fly zones or maximum flight ranges and 

altitudes so the system cannot enter areas deemed unsafe or unnecessary to fly over. 

The petitioner states further that the UAS has built-in intelligent fault handling which allows 

the SkyRanger to detect a system fault while in the air and automatically fly back to its takeoff location and land. Faults that can be detected include: loss of communication; exceeding 

pre-set wind thresholds; and low battery levels. 

All flight operations are global positioning system (GPS) controlled, making the system easy 

to navigate. At any point if the operator is not explicitly commanding the system to move, the 

system automatically holds its GPS position. 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 stability so long as wind thresholds are not exceeded. Also a flight 
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termination link – to prevent a “fly away” or other potentially dangerous situation – is 

available to the operator.

The petitioner did not request an exemption under part 45 concerning the display of marks on 

the UAS; however it did request an exemption under § 91.9(c) which specifically references 

part 45. The petitioner requests an exemption from § 91.9(c) because no official marking 

systems for UAS have been established yet for operations inside the National airspace System 

(NAS). The petitioner has instead offered to mark the system with the name of the 

organization and location or origin.

The petitioner also requests relief from maintenance and inspection requirements under 

§§ 91.405(a) and (b), 91.407(a)(1), 91.409(a)(1) and 91.417(a). The petitioner states that an 

exemption should be granted under these sections because the UAS to be used is not a U.S.

registered civil aircraft and therefore 14 CFR 91 regulations do not apply and further a

designated official certified by the FAA to have maintenance signature authority does not 

exist. However, VDOS has indicated it will employ a maintenance and quality assurance 

program which meets or exceeds applicable regulatory standards for U.S. registered aircraft. 

No operations will take place without inspections and maintenance items being completed. 

All inspections and maintenance action items will be documented in aircraft logs, which will

be made available upon request and kept with the control station equipment during all 

operations. These inspections will occur offshore in the Gulf of Mexico, further than 12 nm

from the coast line and outside of the U.S. Air Defense Identification Zone (ADIZ).

The petitioner states further that the SkyRanger is nearly maintenance free since it performs 

automatic pre-flight checks prior to flight and the failure of any check will prevent take-off. 

The petitioner notes that checks which cannot be done by the system will be performed by a 

qualified person prior to each flight. The petitioner further states that Original Equipment 

Manufacturer (OEM) requirements will be followed in the performance of maintenance, 

inspection and record keeping for the SkyRanger as provided in the Operations Guide. Also, 

the petitioner will implement a maintenance and quality assurance program for the 

SkyRanger. 

The Petitioner states that the OEM defines the maintenance requirements for the unmanned 

aircraft and per those requirements VDOS will ensure that OEM qualified maintainers are 

performing all inspections to precise OEM standards. No operations will take place without 

required inspections and maintenance items being completed. Further, all inspections and 

maintenance action items will be documented in aircraft logs and communicated to the OEM 

as required. Aircraft maintenance logbooks will be made available upon official request. 
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UAS Pilot In Command (PIC)

The petitioner states that it has two operators who are both commercially rated pilots and have 

years of experience in multiple unmanned systems. These operators will be flight current for 

both manned and unmanned aircraft and will hold a current Class II FAA medical certificate 

with appropriate flight currency. Further, the petitioner indicates that the PICs will be 

certified to operate by the unmanned system manufacturer.

The petioner notes that for all flight operations a PIC will be designated and this person will 

be directly responsible for the operation of the UAS and the safety of the operation. It will be 

the responsibility of the PIC to ensure the operation complies with all applicable regulations 

and/or ensures professional “best practice” to all applicable regulations.

In addition, for each operation an observer/back-up pilot will be responsible to visually 

maintain contact with the SkyRanger and scan the area for undetected aircraft or obstacles. 

The observer will also handle the communications between the PIC, external crew, air safety 

officer and the platform safety officer. The observer will also be a certified and current 

system operator and will assume control of the SkyRanger should the PIC become 

incapacitated.

UAS Operating Parameters

The petitioner states that according to § 91.101, it is not subject to §§ 91.103 - 91.199 since 

all VDOS operations will be outside the 12 nm limit of the United States.

The petitioner states that all flights will remain within visual line of sight (VLOS) of the pilot 

or observer. The petitioner further states that if a pilot’s view becomes obstructed and line-ofsight is lost, the pilot may instruct the UAS to hover in place until line-of-sight is 

reestablished, to return to the take-off position, or to land at the current position. The 

petitioner notes that the UAS will operate at or below 300 feet mean sea level and will occur 

offshore in the Gulf of Mexico, further than 12 nm from the coast line. The petitioner further 

notes that it will launch and recover its unmanned aircraft vehicle from the production 

platform in international water and will not be transitioning to/from any applicable airports, 

airways or waypoints. The petitioner states that all flights will take place only under visual 

flight conditions and all applicable visual flight rules will be followed. No flights will occur 

from sunset to sunrise. Each flight will be operated in autonomous mode with manual 

operations permitted only in case of an emergency and the flights will be operated during 

periods when no helicopter traffic to or from the platform is planned or is occurring. 
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The petitioner notes that a launch operation will take place at a pre-detemined Landing Zone 

and that the Landing Zone will be clearly marked to ensure safety with ground personnel. 

The petitioner further notes that the PIC cannot launch the system without approval from the 

platform safety officer, air traffic officer, and the observer. Flights will not last any longer 

than 50 minutes.

The petitioner has requested an exemption from § 91.207(a)(2),which requires an emergency 

locator transmitter (ELT) attached to the aircraft. The petitioner states that an ELT would not 

be needed on the UAS because all operations will be conducted within VLOS of the PIC and 

observer. VDOS further states that should communications with the system be lost, the 

aircraft has a lost link protocol that returns it to a pre-planned waypoint. Its GPS location is 

saved at all times with the aircraft’s recorded telemetry and with these measures in place. The 

aircraft’slocation will be known at all times and should a mishap occur the aircraft will be 

immediately accounted for. 

Public Interest:

The petitioner states that, performing these stack inspections with unmanned systems is a 

benefit to the public for the following reasons: 1) the operation significantly improves safety 

and reduces risk by alleviating human exposure to danger; 2) there is a compelling need to 

improve such inspection processes and save operating costs; 3) this service can provide a 

means of environmental monitoring during inspections since the inspections will aid in 

documenting and ensuring the structure emissions process is working properly and that 

harmful gases are not being released into the environment; and 4) VDOS Global LLC is 

prepared to share operational data with the FAA.

Discussion of Public Comments:

A summary of the petition was published in the Federal Register on July 15, 2014 (79 FR 

16524). The petition received two supporting comments.

Of the two comments received, one was from Association of Unmanned Vehicle Systems 

International (AUVSI) and the other from an individual. The individual indicated that risk to 

current safety inspectors would be reduced by utilizing UAS with no increased risk to the 

public or environmental safety. AUSVI commented that use of the UAS would allow certain 

activities that have never before been possible while maintaining at least the same level of 

safety.
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The FAA's analysis is as follows:

Unmanned aircraft system (UAS)

Although the petitioner did not request relief from Part 21of 14 CFR, the FAA notes that 

Part 21 requires all aircraft in the NAS to hold an airworthiness certificate. However in 

accordance with the statutory criteria provided in Section 333 of P.L. 112-95 in reference to 

49 USC 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 although 

not requested, relief from 14 CFR Part 21, and any associated noise certification and testing 

requirements of part 36, is not necessary.

The petitioner’s Operations Guide reflects all maintenance of the UAS will be conducted as 

specifically required by the OEM and that all maintenance will be documented in the flight 

manual, which must be in possession of the operator at all times. The Operations Guide 

further states only qualified OEM maintainers will perform inspections and maintenance per 

OEM standards. The Operations Guide reflects that the petitioner will implement a 

maintenance and quality assurance program for the SkyRanger.

The FAA has carefully considered the petitioner’s information and determined that its UAS 

operations will not adversely affect safety with regard to the regulatory maintenance and 

alteration requirements of §§ 91.405(a)(1), 91.407(a) (1), 91.409(a)(1) and (2), and 

recordkeeping requirements of 91.417(a) and (b), provided changes are made to the 

Operations Guide as required by the conditions and limitations included in this exemption.

These changes include: requirements to develop and document the maintenance, overhaul, 

replacement, and inspection requirements, including inspection intervals, if applicable. The 

petitioner is also required to establish procedures for the documentation and retention of 

maintenance actions, alterations made, and inspections performed to the SkyRanger in the 

Operations Guide. Additionally, Operation Guide procedures will be necessary for the UAS 

technician qualification and authorization criteria. Lastly, the Operations Guide must include 

preflight inspection procedures that account for any discrepancies not already covered during 

maintenance and inspection of the SkyRanger. The FAA finds these additional requirements 

are necessary to ensure the petitioner’s proposed UAS operations do not adversely affect 

safety in the NAS and of people and property on the ground. Therefore, the FAA finds that 

exemption from §§ 91.405(a), 91.407(a)(1), 91.409(a)(1) and (2), and 91.417(a) and (b) is 

warranted subject to the conditions and limitations below.
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Pilot In Command of the UAS

As described in VDOS’ petition, the PIC will be a commercially rated pilot and hold a current 

Class II FAA medical certificate along with appropriate flight currency. The PIC must 

complete all additional manufacturers required or recommended training.

Operating parameters of the UAS

The FAA disagrees with the petitioner’s interpretation that an exemption from certain sections 

of part 91 do not apply because its operations will be outside the 12 nm limit of the United 

States. Section 91.703 requires compliance with International Civil Aviation Organization’s 

Annex 2 “Rules of the Air” when over the “high seas” (beyond the 12 nm limit) and with 

most of the requirements of part 911 over the high seas when those requriements are not 

inconsistent with the Annex 2 standards. 

In reviewing the VDOS petition, the FAA has determined that relief from § 91.119(c) is 

needed. Section 91.119(c) Minimum safe altitudes, states that no person may operate an 

aircraft below the following altitudes; over other than congested areas, 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. 

The petitioner states that it will operate pursuant to the following, self-imposed, restrictions 

the FAA has determined are related to § 91.119:

• Scheduling operations in between any scheduled departures or arrivals of helicopter 

traffic to or from the platform;

• Issuing a NOTAM 48 hours prior to the operation describing the location and times of 

the operation;

• Creating no fly zones or maximum flight ranges and altitudes so the system cannot 

enter areas deemed unsafe or unnecessary to fly over; and 

• Securing approvals prior to launch and recovery from the platform safety officer, air 

traffic officer, visual observer (VO) and PIC.

Ultimately, it is the pilot’s responsibility to maintain the minimum safe altitudes required by 

§ 91.119. Thus, all nonparticipating persons, vessels, vehicles, and structures will be required 

to be at least 500 feet from flight operations. With regard to participating persons, vessels, 

vehicles and structures closer than 500 feet from the UAS, operations are permitted when 

operationally necessary. However at no time can operations be conducted so close as to 

 1 Section 91.703(a)(3) excepts §§ 91.117(a), 91.307(b), 91.309, 91.323, and 91.711.
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present an undue hazard to the PIC or VO, per § 91.119(a). Thus, the FAA finds that relief 

from § 91.119(c) is warranted provided adherence to the procedures in the operator’s manual 

and the FAA’s additional conditions and limitations outlined below. Relief from § 91.119(a) 

is not granted.

The FAA also has determined that the petitioner will need relief from § 91.151(a), Fuel 

requirements for flight in VFR conditions. Prior relief has been granted for manned aircraft to 

operate at less than the prescribed minimums, including Exemption Nos. 2689, 5745, and 

10650. In addition, similar UAS-specific relief has been granted by Exemption Nos. 8811, 

10808, and 10673 for daytime, Visual Flight Rules (VFR) conditions. The UAS batteries 

provide approximately 50 minutes of powered flight (with payload) and provide battery level 

and battery time remaining in minutes and seconds to the PIC. Further, the SkyRanger 

operating manual states: “start every flight with a fully charged battery in the aerial vehicle.” 

Also, in the event that the UAS should run low on power, the PIC will be alerted and can land 

the SkyRanger as soon as possible. Given the location and limitations on the UAS, these 

factors provide the FAA with sufficient reason to grant the relief from § 91.151(a) in 

accordance with the conditions and limitations below.

Regarding an Air Traffic Organization (ATO) issued Certificate of Waiver or Authorization 

(COA), Section 333, in pertinent part, states that a determination must be made regarding 

which types of UAS operations do not create a hazard to users of the NAS. The majority of 

current UAS operations occurring in the NAS are being coordinated through Air Traffic 

Control (ATC) by the issuance of a COA. This is an existing process that not only makes 

local ATC facilities aware of UAS operations, but also provides ATC the ability to consider 

airspace issues that are unique to UAS operations. The COA may require the operator to 

request a Notice to Airman (NOTAM), which is the mechanism for alerting other users of the 

NAS to the UAS activities being conducted. Therefore, the FAA believes that adherence to 

this process is the safest and most expeditious way to permit VDOS to conduct its proposed 

UAS operations. The conditions and limitations below prescribe the requirement for VDOS 

to obtain an ATO-issued COA.

Regarding the petitioner’s requested relief from §§ 91.9(b)(2) Civil aircraft flight manual, 

marking, and placard requirements and 91.203(a) and (b) Civil aircraft: Certifications 

required, relief from these sections is not necessary. Relevant materials may be kept in a 

location accessible to the PIC in compliance with the regulations.

Although the petitioner did not request an exemption from Part 45, the petitioner did request 

an exemption under § 91.9(c) which specifically references Part 45 regarding identification

and registration of the aircraft. As permitted under § 45.29, if surfaces authorized for 
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displaying marks are not large enough to meet the size requirement, marks may be as large as 

practicable.

The Petitioner has also requested an exemption from § 91.207 which requires an emergency 

locator transmitter on the aircraft. However, according to § 91.207(a) which references 

§ 91.207(f)(9), no ELT is required if the aircraft is equipped to carry not more than one 

person. Thus, no exemption is required from § 91.207.

Public Interest

The FAA finds that a grant of exemption is in the public interest. The enhanced safety 

achieved using a 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. 

The table below summarizes the FAA’s determinations regarding the relief sought by the 

petitioner:

Relief sought by petitioner (14 CFR) FAA determination (14 CFR)

91.9(b)(2) Relief not necessary

91.9(c) Relief not necessary

91.109 Relief not necessary

91.119(c) Relief granted with conditions and limitations

91.151 Relief granted with conditions and limitations

91.203(a) and (b) Relief not necessary

91.207(a)(2) Relief not necessary

91.405(a) and (b) Relief granted with conditions and limitations

91.407(a)(1) Relief granted with conditions and limitations

91.409 (a)(1) Relief granted with conditions and limitations

91.417(a) Relief granted with conditions and limitations
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The FAA’s 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, VDOS Global, LLC is granted an exemption from 

14 CFR 91.9 (c); 91.119(c), 91.151, 91.405(a) and (b); 91.407(a)(1); 91.409(a)(1); and 

91.417(a) to the extent necessary to allow VDOS to operate unmanned aircraft systems for the 

purpose of flare stack inspections on 14 Shell Oil Gulf of Mexico production platforms with 

all platforms beyond 12 nm of the coast of the United States. This exemption is subject to the 

conditions and limitations listed below.

Conditions and Limitations

Relative to this grant of exemption, VDOS 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 following aircraft 

described in the operator’s manual which is a quad copter (4 blades, 4 rotors) 

weighing 61⁄2 pounds: Aeryon Labs SkyRanger (SkyRanger or UAV). Proposed 

operations of any other aircraft will require a new petition or a petition to amend this 

grant.

2. The UA may not be flown at a ground speed exceeding 87 knots or 100 mph.

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

(AGL), as indicated by the procedures specified in the operator’s manual. All 

altitudes reported to ATC must be in feet AGL.

4. The UA must be operated within visual line of sight (VLOS) of the PIC and the visual 

observer (VO) 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 FAAissued medical certificate.

5. All operations must utilize a VO. 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. The PIC must be designated before 

the flight and cannot transfer his or her designation for the duration of the flight. The 
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PIC must ensure that the VO can perform the functions prescribed in the operator’s 

manual.

6. Provided the additional requirements identified in these conditions and limitations are 

added or amended, the operator’s manual is considered acceptable to the FAA. The 

operator’s manual and this grant of exemption must be maintained 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 operator’s manual, the 

conditions and limitations herein take precedence and must be followed. Otherwise, 

the operator must follow the procedures as outlined in its operator’s manual.

7. Prior to each flight the PIC must inspect the UAS to ensure it is in a condition for safe 

flight. If the inspection reveals a condition that affects the safe operation of the UAS, 

the aircraft is prohibited from operating until the necessary maintenance has been 

performed and the UAS is found to be in a condition for safe flight. The Ground 

Control Station must be included in the preflight inspection. All maintenance and 

alterations must be properly documented in the aircraft records.

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 in accordance with the operator’s manual. The PIC who 

conducts the functional test flight must make an entry in the UAS aircraft records of 

the flight. The requirements and procedures for a functional test flight and aircraft 

record entry must be added to the operator’s manual.

9. The preflight inspection section in the operator’s manual must be amended to include 

the following requirement: The preflight inspection must account for all discrepancies, 

i.e. inoperable components, items, or equipment, not covered in the relevant preflight 

inspection sections of the operator’s manual.

10. The operator must follow the manufacturer’s UAS aircraft/component, maintenance, 

overhaul, replacement, inspection, and life limit requirements, with particular attention 

to flight critical components that may not be addressed in the manufacturer’s manuals.

11. The operator must carry out their maintenance, inspections, and record keeping 

requirements, in accordance with the operator’s manual. Maintenance, inspection, and 

alterations must be noted in the aircraft logbook, including total flight hours, 
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description of work accomplished, and the signature of the authorized SkyRanger 

technician returning the SkyRanger to service.

12. SkyRanger technicians must receive and document training referenced in the 

operator’s manual.

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

and Safety Bulletins.

14. SkyRanger maintenance personnel must make a record entry in the UAS logbook or 

equivalent document of the corrective action taken against discrepancies discovered 

between inspections.

15. The Pilot In Command (PIC) must possess at least a commercial pilot certificate and 

at least a current second-class medical certificate. 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.

16. The PIC must complete all additional manufacturers required or recommended 

training.

17. If the UAS loses communications or loses its GPS signal, the UA must return to a predetermined location within the security perimeter and land or be recovered in 

accordance with the operator’s manual.

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

accordance with the operator’s manual.

19. The PIC is prohibited from beginning a SkyRanger flight unless (considering wind 

and forecast weather conditions) there is enough power to fly to the first intended 

point of landing and, assuming normal cruising speed, to fly after that for at least 10 

minutes.

20. The operator must obtain an Air Traffic Organization (ATO) issued Certificate of 

Waiver or Authorization (COA) prior to conducting any operations under this grant of 

exemption. This COA will also require the operator to request a Notice to Airman 

(NOTAM) not more than 72 hours in advance, but not less than 48 hours prior to the 

operation.
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21. 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 (NNumber) markings in accordance with 14 CFR part 45, Subpart C. 

22. Before conducting operations, the radio frequency spectrum used for operation and 

control of the UA must comply with the Federal Communications Commission (FCC) 

or other appropriate government oversight agency requirements.

23. The documents required under14 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 yield the right of way to all other 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. UAS operations may not be conducted during night, as defined in 14 CFR 1.1.

27. All operations shall be conducted outside the U.S. 12 nm limit, but within airspace 

managed by the U.S. and within the U.S. Flight Information Region (FIR) boundary.

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

29. Operation of the UA must be conducted at least 500 feet from all nonparticipating 

persons, vessels, vehicles, and structures.

30. Operations of the UA may be conducted at distances less than 500 feet from 

participating persons, vessels, vehicles or structures that perform an essential function 

in connection with these special purpose operations. Operations closer than 500 feet 

from the PIC, VO, operator trainees and essential persons, are permitted when 

operationally necessary; but never so close as to present an undue hazard, per

§ 91.119(a). 

31. Operations of the UA may be conducted at distances less than 500 feet from 

unoccupied vessels, vehicles or structures so long as the owner/controller grants such 
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permission and the operation closer to these objects presents no safety hazard to 

nonparticipating persons or property. 

32. 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.

Unless otherwise specified in this grant of exemption, the unmanned aircraft system (UAS), 

pilot in command (PIC), and operator must comply with all applicable parts of 14 CFR 

including, but not limited to, parts 45, 47, 61, and 91.

This exemption terminates on December 31, 2016, unless sooner superseded or rescinded.

Issued in Washington, DC, on December 10, 2014.

/s/

John S. Duncan

Director, Flight Standards Service