1 | Page

The EXHIBITS in this petition with the exception of EXHIBIT (K) contain proprietary information, and in accordance with 14 

C.F.R § 11.35 (b), are not to be included in the Federal Docket Management System (FDMS).

UNITED STATES OF AMERICA

DEPARTMENT OF TRANSPORTATION

FEDERAL AVIATION ADMINISTRATION

WASHINGTON, DC

Regulatory Docket No. _______________

IN THE MATTER OF THE PETITION FOR EXEMPTION OF:

INTEGRATED ROBOTICS IMAGING SYSTEMS, LTD

FOR AN EXEMPTION SEEKING RELIEF FROM THE REQUIREMENTS OF

TITLE 14 OF THE CODE OF FEDERAL REGULATIONS

SECTIONS 61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & 

(a)(2), AND 91.417(a) & (b) 

CONCERNING COMMERCIAL OPERATION OF THE

ECA - INFOTRON IT180 UNMANNED AIRCRAFT SYSTEM

PURSUANT TO SECTION 333 OF THE:

THE FAA MODERNIZATION AND REFORM ACT OF 2012 (PUBLIC LAW 112-95)

Submitted on May 29, 2015

JOHN C, PARKER

Integrated Robotics Imaging Systems, Ltd

140 Main Street Loop

Kenai, Alaska 99611

Tel: (907) 283-4223
2 | Page

The EXHIBITS in this petition with the exception of EXHIBIT (K) contain proprietary information, and in accordance with 14 

C.F.R § 11.35 (b), are not to be included in the Federal Docket Management System (FDMS).

TABLE OF CONTENTS

Page

GLOSSARY OF ABBREVIATIONS ................................................................................ ......3

SUMMARY........................................................................................................................ ......4

INTRODUCTION AND INTERESTS OF PETITIONER ................................................ ......4

.

BACKGROUND ................................................................................................................ ......4

BASIS FOR PETITION ..................................................................................................... ......5

NAME AND ADDRESS OF PETITIONER................................................................ ......7

THE SPECIFIC SECTIONS OF 14 C.F.R. FROM WHICH INTEGRATED

ROBOTICS IMAGING SYSTEMS, LTD SEEKS EXEMPTION.............................. ......8

THE EXTENT OF RELIEF INTEGRATED ROBOTICS IMAGING SYSTEMS. LTD

SEEKS AND THE REASON INTEGRATED ROBOTICS IMAGING SYSTEMS, LTD 

SEEKS THE RELIEF

..................................................................................................................................... .......11

THE REASONS WHY GRANTING INTEGRATED ROBOTICS IMAGING SYSTEMS. 

LTD'S REQUEST WOULD BE IN THE PUBLIC INTEREST

..................................................................................................................................... ......14

THE REASONS WHY GRANTING THE EXEMPTION WOULD NOT

ADVERSELY AFFECT SAFETY............................................................................. ......17

SUMMARY THAT CAN BE PUBLISHED IN THE FEDERAL REGISTER......... ......30

ANY ADDITIONAL INFORMATION, VIEWS, OR ARGUMENTS AVAILABLE

TO SUPPORT INTEGRATED ROBOTICS IMAGING SYSTEMS. LTD'S REQUEST

..................................................................................................................................... ......31

CONCLUSION................................................................................................................ ......31

EXHIBITS................................................................................................33
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The EXHIBITS in this petition with the exception of EXHIBIT (K) contain proprietary information, and in accordance with 14 

C.F.R § 11.35 (b), are not to be included in the Federal Docket Management System (FDMS).

GLOSSARY OF ABBREVIATIONS

AGL Above Ground Level

AOI Area of Interest

ATC Air Traffic Control

ATO Air Traffic Organization

C.F.R. Code of Federal Regulations

COA Certificate of Authorization

FAA Federal Aviation Administration

FAR Federal Aviation Regulation

FCC Federal Communications Commission

GCS Ground Control Station

GPS Global Positioning System

NAS National Airspace System

NOTAM Notice to Airmen

PIC Pilot In Command

Section 333 FAA Modernization and Reform Act of 2012 (FMRA) Section 333

SOP Standard Operating Procedures

UA Unmanned Aircraft

UAS Unmanned Aircraft System

VFR Visual Flight Rules

VLOS Visual Line of Sight

VMC Visual Meteorological Conditions

VO Visual Observer

VTOL Vertical Takeoff and Landing
4 | Page

The EXHIBITS in this petition with the exception of EXHIBIT (K) contain proprietary information, and in accordance with 14 

C.F.R § 11.35 (b), are not to be included in the Federal Docket Management System (FDMS).

SUMMARY

Integrated Robotics Imaging Systems, Ltd seeks exemption from the requirements of 14 C.F.R 

§§ 61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 

91.417(a) & (b), to operate an Unmanned Aircraft System pursuant to Section 333 of the FAA 

Modernization and Reform Act of 2012 (FMRA). This exemption will permit Integrated Robotics 

Imaging Systems, LTD to operate an Unmanned Aircraft System (UAS) for the commercial purpose of 

conducting aerial acquisitions within the National Airspace System (NAS).

INTRODUCTION AND INTERESTS OF THE PETITIONER

Integrated Robotics Imaging Systems, Ltd (hereinafter referred to as “Integrated 

Robotics”) provides advanced mobile and aerial technologies which enable companies to operate 

more efficiently and achieve competitive advantages in their respective markets.

BACKGROUND

Unmanned Aircraft System: ECA - Infotron IT180

Integrated Robotics seeks an exemption to operate the (ECA - Infotron IT180 UAS) for 

compensation or hire within the National Airspace System (NAS). The ECA - Infotron IT180 UAS is 

comprised of a coaxial rotor, vertical takeoff and landing (VTOL) Unmanned Aircraft (UA) and a 

transportable Ground Control Station (GCS). The ECA - Infotron IT180 UA has: a maximum gross 

weight of approximately 20 kg; approximate dimensions of a length of 1,800 mm, width of 1,800 mm, 

and height of 755mm; and maximum speed of approximately 90 km/h (56 mph). The ECA - Infotron 

IT180 UA is equipped with two rotors, driven by a Lithium Polymer battery powered electric motor 

EXHIBIT (A).

The ECA - Infotron IT180 UA that will be operated by Integrated Robotics is registered in 

accordance with 49 U.S.C. 44103, Registration of Aircraft, as well as 14 C.F.R Part 47, Aircraft.

Registration, and marked in accordance with 14 C.F.R. Part 45, Identification and Registration 

Marking as (N180UV) and carries its registration on board the aircraft EXHIBIT (K).
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The EXHIBITS in this petition with the exception of EXHIBIT (K) contain proprietary information, and in accordance with 14 

C.F.R § 11.35 (b), are not to be included in the Federal Docket Management System (FDMS).

BASIS FOR PETITION

Petitioner, Integrated Robotics Imaging Systems, Ltd, pursuant to the provisions of the Federal 

Aviation Regulations (14 C.F.R. § 11.61) and the FAA Modernization and Reform Act of 2012 

(FMRA) Section 333, Special Rules for Certain Unmanned Aircraft Systems, hereby petitions the 

Administrator to commercially operate the ECA - Infotron IT180 UA within the National Airspace 

System (NAS), and for an exemption from the requirements of 14 C.F.R §§ 61.113(a) & (b), 91.7(a), 

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

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

unmanned aircraft and its operation, Integrated Robotics’ operation of the ECA - Infotron IT180 UAS 

meets the conditions of FMRA Section 333 and therefore, will not require an airworthiness certificate in 

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

Accordingly, Integrated Robotics requests relief from Sections 91.405(a), 91.407(a)(1), 

91.409(a)(1) & (a)(2), and 91.417(a) & (b), as these sections set forth requirements for maintenance that 

only apply to aircraft with an airworthiness certificate. Integrated Robotics submits that the requested 

relief is proper since an equivalent level of safety will be ensured. Integrated Robotics will perform 

maintenance, alterations, or preventive maintenance on the UA using the methods, techniques, and 

practices prescribed in the operating documents (i.e., the ECA-Infotron - Unmanned Aerial Vehicle -

IT180 UAS Technical Guide Version 3 (June 2013) EXHIBIT (B), the ECA-Infotron - Unmanned Aerial 

Vehicle - IT180 UAS Maintenance Manual (Sept 2012) with 22 Plates EXHIBIT (E), the Integrated 

Robotics IT180 – Setup for Preflight (July 2014) EXHIBIT (F), the Integrated Robotics IT180 - Preflight 

Check List - (July 2014) EXHIBIT (G) and the Integrated Robotics IT180 Operational Check List –

Flight (July 2014) EXHIBIT (H). Furthermore, Integrated Robotics will document and maintain all 

maintenance records for the Infotron IT180 UAS.

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

and limitations: Pilot in command, is requested by Integrated Robotics to the extent necessary to allow 

operation of the ECA - Infotron IT180 UAS by a Pilot in Command (PIC) who has demonstrated, by
6 | Page

The EXHIBITS in this petition with the exception of EXHIBIT (K) contain proprietary information, and in accordance with 14 

C.F.R § 11.35 (b), are not to be included in the Federal Docket Management System (FDMS).

meeting minimum flight-hour and currency requirements and who has successfully acquired a specific 

pilot certificate from the IT180 manufacturer, Infotron, based on the Infotron IT180 Pilot Syllabus

enclosed herewith as EXHIBIT (D) and that, the PIC has obtained pilot knowledge through a ground 

training course certified to provide the same level of aeronautical knowledge detailed in § 61.105 

Aeronautical Knowledge including but not limited to, (a) applicable Federal Aviation Regulations that 

relate to private pilot privileges, limitations, and flight operations, (b) accident reporting requirements of 

the National Transportation Safety Board, (c) principals of aerodynamics, power-plants and aircraft 

systems, (d) recognition of critical weather situations from the ground and in flight, wind-shear 

avoidance, collision avoidance and recognition and avoidance of wake turbulence, (e) weight and 

balance computations, (f) effects of density altitude on take-off and climb performance, (g) use of 

aeronautical charts for VFR navigation using pilotage, dead reckoning and navigations systems, (h) 

radio communication procedures, (i) use of applicable portions of the “Aeronautical Information 

Manual,” FAA Advisory Circulars and procedures for NOTAMS and that, the PIC is able to safely 

operate the ECA - Infotron IT180 UAS according to the manufacturers pilot training requirements and 

in a manner consistent with this exemption, including evasive and emergency maneuvers and 

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

Integrated Robotics seeks relief from Section 91.7(a), entitled, Civil Aircraft Airworthiness, 

because the ECA - Infotron IT180 UAS does not require an airworthiness certificate in accordance with 

14 C.F.R. Part 21, Subpart H. As such, Integrated Robotics submits that it will ensure that the ECA -

Infotron IT180 UAS is in an airworthy condition, prior to every flight, by determining that the UAS is in 

compliance with the operating documents (i.e., the ECA-Infotron - Unmanned Aerial Vehicle - IT180 

UAS Technical Guide Version 3 (June 2013) EXHIBIT (B), the ECA-Infotron - Unmanned Aerial 

Vehicle - IT180 UAS Maintenance Manual (Sept 2012) with 22 Plates EXHIBIT (E), the Integrated 

Robotics IT180 – Setup for Preflight (July 2014) EXHIBIT (F), the Integrated Robotics IT180 -

Preflight Check List - (July 2014) EXHIBIT (G) , the Integrated Robotics IT180 - Operational Check 
7 | Page

The EXHIBITS in this petition with the exception of EXHIBIT (K) contain proprietary information, and in accordance with 14 

C.F.R § 11.35 (b), are not to be included in the Federal Docket Management System (FDMS).

List - Flight - (Jul 2014) EXHIBIT (H).

Integrated Robotics also seeks an exemption from the requirements of Section 91.121, entitled 

Altimeter Settings, because the altitude reporting equipment of the ECA - Infotron IT180 UAS is set to 

zero feet above ground level (AGL), rather than local barometric pressure or field altitude, before each 

flight. The altitude information of the ECA - Infotron IT180 UA is provided to the PIC via a barometric 

pressure sensor, Global Positioning System (GPS) equipment, and a radio communications telemetry 

data link, which downlinks from the UAS to the GCS for active monitoring of the flight path. A level of 

safety equivalent to Section 91.121 will be ensured as the altitude of the ECA - Infotron IT180 UA will 

be reported to air traffic control (ATC) in feet above ground level (AGL), and Integrated Robotics will 

operate the ECA - Infotron IT180 UA within visual line of sight, at or below 400 feet AGL.

Additionally, Integrated Robotics seeks an exemption from the requirements of Section 

91.151(b), entitled Fuel requirements for flight in VFR conditions. Integrated Robotics submits that 

safety will not be affected by operation of the ECA - Infotron IT180 UAS during daylight hours in 

visual meteorological conditions (VMC) under visual flight rules (VFR), with enough battery power to 

fly for a total duration of 20 minutes to the first point of intended landing and, assuming normal cruising 

speed, to fly after that for at least 10 minutes (i.e., 33 percent battery power remaining).

In accordance with 14 C.F.R. § 11.81, Integrated Robotics provides the following 

information in support of its petition for exemption:

A. NAME AND ADDRESS OF THE PETITIONER. 

Integrated Robotics Imaging Systems, Ltd

140 Main Street Loop

Kenai, Alaska 99611

The point of contact for this Petition and specific contact information is as follows:

John C. Parker, COO

140 Main Street Loop

Kenai, Alaska 99611

Tel: (907) 283-4223

Email: iris@uav-alaska.com
8 | Page

The EXHIBITS in this petition with the exception of EXHIBIT (K) contain proprietary information, and in accordance with 14 

C.F.R § 11.35 (b), are not to be included in the Federal Docket Management System (FDMS).

B. THE SPECIFIC SECTIONS OF 14 C.F.R. FROM WHICH INTEGRATED 

ROBOTICS SEEKS EXEMPTION. 

1. Integrated Robotics seeks exemption from the requirements of Section 

61.113(a) And (b). 

Section 61.113, entitled Private pilot privileges and limitations: Pilot in command, subsections 

(a) and (b) prescribe the following, in relevant part:

(a) No person who holds a private pilot certificate may act as a pilot in command (PIC) 

of an aircraft that is carrying passengers or property for compensation or hire; nor may 

that person, for compensation or hire, act as PIC of an aircraft. 

(b) A private pilot may, for compensation or hire, act as PIC of an aircraft in 

connection with any business or employment if—

(1) The flight is only incidental to that business or employment; and 

(2) The aircraft does not carry passengers or property for compensation or hire. 

2. Integrated Robotics seeks exemption from the requirements of Section 

91.7(a). 

Section 91.7, entitled Civil Aircraft Airworthiness, subsection (a), states the following:

(a) No person may operate a civil aircraft unless it is in an airworthy condition.

3. Integrated Robotics seeks exemption from the requirements of Section 

91.121. 

Section 91.121, entitled Altimeter settings, subsection (a), states the following, in part:

(a) Each person operating an aircraft shall maintain the cruising altitude or flight level of that 

aircraft, as the case may be, by reference to an altimeter that is set, when operating--

(1) Below 18,000 m MSL, to--

(i) The current reported altimeter setting of a station along the route and within 100 

nautical miles of the aircraft; 

(ii) If there is no station within the area prescribed in paragraph (a)(1)(i) of this 

section, the current reported altimeter setting of an appropriate available station; or 

(iii) In the case of an aircraft not equipped with a radio, the elevation of the 

departure airport or an appropriate altimeter setting available before departure; 
9 | Page

The EXHIBITS in this petition with the exception of EXHIBIT (K) contain proprietary information, and in accordance with 14 

C.F.R § 11.35 (b), are not to be included in the Federal Docket Management System (FDMS).

4. Integrated Robotics seeks exemption from the requirements of Section 

91.151(b). 

Section 91.151, entitled Fuel requirements for flight in VFR conditions, subsection (b), states the 

following:

(b) No person may begin a flight in a rotorcraft 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, to fly after that for at least 20 minutes.

5. Integrated Robotics seeks exemption from the requirement of Section 

91.405(a). 

Section 91.405, entitled Maintenance required, subsection (a), states the following:

Each owner or operator of an aircraft—

(a) 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[.]

6. Integrated Robotics seeks exemption from the requirements of Section 

91.407(a)(1). 

Section 91.407, entitled Operation after maintenance, preventive maintenance, rebuilding, or 

alteration, subsection (a)(1), states the following:

(a) No person may operate any aircraft that has undergone maintenance, preventive 

maintenance, rebuilding, or alteration unless--

(1) It has been approved for return to service by a person authorized under § 43.7 of 

this chapter[.]

7. Integrated Robotics seeks exemption from the requirements of Sections 

91.409(a)(1) And 91.409(a)(2). 

Section 91.409, entitled Inspections, subsection (a), states the following:

(a) Except as provided in paragraph (c) of this section, no person may operate an aircraft 

unless, within the preceding 12 calendar months, it has had --

(1) An annual inspection in accordance with part 43 of this chapter and has been 

approved for return to service by a person authorized by § 43.7 of this chapter; or

(2) An inspection for the issuance of an airworthiness certificate in accordance with 

part 21 of this chapter.
10 | Page

The EXHIBITS in this petition with the exception of EXHIBIT (K) contain proprietary information, and in accordance with 14 

C.F.R § 11.35 (b), are not to be included in the Federal Docket Management System (FDMS).

8. Integrated Robotics seeks exemption from the requirements of Sections 

91.417(a) And 91.417(b). 

Section 91.417, entitled Maintenance records, subsections (a) and (b), state the following:

(a) Except for work performed in accordance with §§ 91.411 and 91.413, 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 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 which 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) of this chapter for each major 

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

appliances.

(b) The owner or operator shall retain the following records for the periods prescribed: 
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The EXHIBITS in this petition with the exception of EXHIBIT (K) contain proprietary information, and in accordance with 14 

C.F.R § 11.35 (b), are not to be included in the Federal Docket Management System (FDMS).

(1) The records specified in paragraph (a) (1) of this section shall be retained until the 

work is repeated or superseded by other work or for 1 year after the work is performed. 

(2) The records specified in paragraph (a) (2) of this section shall be retained and 

transferred with the aircraft at the time the aircraft is sold. 

(3) A list of defects furnished to a registered owner or operator under § 43.11 of this 

chapter shall be retained until the defects are repaired and the aircraft is approved for return to 

service. 

C. THE EXTENT OF RELIEF INTEGRATED ROBOTICS SEEKS AND 

THE REASON INTEGRATED ROBOTICS SEEKS THE RELIEF. 

1. Extent of relief Integrated Robotics seeks and the reason Integrated Robotics

seeks relief from Section 61.113(a) and (b). 

Relief from Section 61.113(a) and (b) entitled Private pilot privileges and limitations: Pilot 

in command, is requested to the extent necessary to allow a PIC holding the necessary OEM Pilot 

Certificate EXHIBIT (J), and FAA approved current Ground School Certificate and who has met 

certain flight-hour and currency requirements, to conduct the proposed UA flight operations for 

compensation or hire.

This relief is requested since the limitations set forth in Section 61.113(a) and (b) state that a 

private pilot may, for compensation or hire, act as PIC of an aircraft in connection with any business or 

employment if: (1) The flight is only incidental to that business or employment; and

(2) The aircraft does not carry passengers or property for compensation or hire.

As set forth more fully below, Integrated Robotics submits that an equivalent level of safety will be 

maintained because no PIC will be allowed to operate the ECA - Infotron IT180 UA unless that PIC

holds an OEM Pilot Certificate, has met certain flight-hour and currency requirements, demonstrating 

that the PIC is able to safely operate the ECA - Infotron IT180 UA in a manner consistent with the 

operations specifications as set forth herein, including evasive and emergency maneuvers, as well as 

maintaining appropriate distances from people, vessels, vehicles and structures. Further, Integrated 

Robotics submits that all flights of the ECA - Infotron IT180 UA, conducted by the PIC pursuant to the 

grant of this Petition: (1) will be incidental to Integrated Robotics’ business; and (2) will not carry 
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The EXHIBITS in this petition with the exception of EXHIBIT (K) contain proprietary information, and in accordance with 14 

C.F.R § 11.35 (b), are not to be included in the Federal Docket Management System (FDMS).

passengers or property for compensation or hire.

2. Extent of relief Integrated Robotics seeks and the reason Integrated Robotics

seeks relief from Section 91.7(a). 

Relief from Section 91.7(a) entitled Civil aircraft airworthiness, is requested to the extent 

required to allow Integrated Robotics to determine that the ECA - Infotron IT180 UAS is in an airworthy 

condition prior to every flight by ensuring that the UAS is in compliance with the operating documents 

(i.e., the ECA-Infotron - Unmanned Aerial Vehicle - IT180 UAS Technical Guide Version 3 (June 2013)

EXHIBIT (B), the ECA-Infotron - Unmanned Aerial Vehicle - IT180 UAS Maintenance Manual (Sept 

2012) with 22 Plates EXHIBIT (E), the Integrated Robotics IT180 – Setup for Preflight (July 2014)

EXHIBIT F), the Integrated Robotics IT180 - Preflight Check List - (July 2014) EXHIBIT (G), the 

Integrated Robotics IT180 - Operational Check List - Flight - (Jul 2014) EXHIBIT (H).

Integrated Robotics seeks the requested relief because the ECA - Infotron IT180 UAS does not 

require an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H. Therefore, 

Integrated Robotics will ensure that the ECA - Infotron IT180 UAS is in an airworthy condition based 

upon its compliance with the operating documents prior to every flight, and further, determine that the 

aircraft is in a condition for safe flight, as stated in the conditions and limitations below.

3. Extent of relief Integrated Robotics seeks and the reason Integrated Robotics

seeks relief from Section 91.121. 

Relief from Section 91.121, entitled Altimeter settings, may be required to allow flight operations 

of the ECA - Infotron IT180 UAS, because the ECA - Infotron IT180 UAS’s altitude reporting 

equipment may be set on the ground to zero feet AGL, rather than local barometric pressure or field 

altitude, before each flight. 

The ECA - Infotron IT180 UAS utilizes a ground proximity sensor, GPS equipment, and a 

radio communications telemetry data link to downlink altitude information from the UA to the PIC at 

the ground control station (GCS).

Considering the limited altitude of the proposed operations, relief from 14 C.F.R. § 91.121 is 

sought to the extent necessary to comply with the applicable conditions and limitations stated below. As 
13 | Page

The EXHIBITS in this petition with the exception of EXHIBIT (K) contain proprietary information, and in accordance with 14 

C.F.R § 11.35 (b), are not to be included in the Federal Docket Management System (FDMS).

more fully set forth herein, a level of safety equivalent to Section 91.121 will be ensured as the altitude 

of the ECA - Infotron IT180 UA will be reported to air traffic control (ATC) in feet above ground level 

(AGL), and Integrated Robotics will operate the ECA - Infotron IT180 UA within visual line of sight, at 

or below 400 feet AGL.

4. Extent of relief Integrated Robotics seeks and the reason Integrated Robotics

seeks relief from Section 91.151(b). 

Relief from Section 91.151(b) entitled Fuel requirements for flight in VFR conditions, is 

requested to the extent required to allow flights of the battery powered ECA - Infotron IT180 UAS

during daylight hours in visual meteorological conditions (VMC), under visual flight rules (VFR), for a 

total duration of 20 minutes to the first point of intended landing and, assuming normal cruising speed, to 

fly after that for at least 10 minutes (i.e., 33 percent battery power remaining). Integrated Robotics seeks 

the requested relief because without an exemption from Section 91.151(b), the flight time duration of the 

battery powered ECA - Infotron IT180 UAS will severely constrain the practicality of any aerial 

acquisition and research flight operations that Integrated Robotics proposes to conduct pursuant to this 

Petition.

Significantly, as set forth below, the technical specifications of the ECA - Infotron IT180 UAS, 

the ECA - Infotron IT180 UAS operating documents, and Integrated Robotics’ proposed operating 

limitations, ensure that Integrated Robotics will safely operate the battery powered ECA - Infotron 

IT180 UA during daylight hours in visual meteorological conditions (VMC) under visual flight rules 

(VFR), with enough battery power to fly, for a total duration of 20 minutes to the first point of intended 

landing and, assuming normal cruising speed, to fly after that for at least 10 minutes (i.e., 20 percent 

battery power remaining)

5. Extent of relief Integrated Robotics seeks and the reason integrated Robotics seeks 

relief from Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), And 91.417(a) & 

(b). 

Since Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b) only apply to 

aircraft with an airworthiness certificate, Integrated Robotics requests relief from these Section
14 | Page

The EXHIBITS in this petition with the exception of EXHIBIT (K) contain proprietary information, and in accordance with 

14 C.F.R § 11.35 (b), are not to be included in the Federal Docket Management System (FDMS).

because the ECA - Infotron IT180 UAS does not require an airworthiness certificate. As set 

forth more fully below, the ECA - Infotron IT180 UAS meets the conditions of FMRA Section 333, 

for operation without an airworthiness certificate. Accordingly, Integrated Robotics will perform 

maintenance, alterations, or preventive maintenance on the UAS using the methods, techniques, and 

practices prescribed in the operating documents (i.e., the ECA-Infotron - Unmanned Aerial Vehicle -

IT180 UAS Technical Guide Version 3 (June 2013) EXHIBIT (B), the ECA-Infotron - Unmanned 

Aerial Vehicle - IT180 UAS Maintenance Manual (Sept 2012) with 22 Plates EXHIBIT (E), the 

Integrated Robotics IT180 – Setup for Preflight (July 2014) EXHIBIT (F), the Integrated Robotics 

IT180 - Preflight Check List - (July 2014) EXHIBIT (G), and the Integrated Robotics IT180 - 

Operational Check List - Flight - (Jul 2014) EXHIBIT (H). Furthermore, Integrated Robotics will 

document and maintain all maintenance records for the ECA - Infotron IT180 UAS.

D. THE REASONS WHY GRANTING INTEGRATED ROBOTICS’ 

REQUEST WOULD BE IN THE PUBLIC INTEREST; THAT IS, HOW 

IT WOULD BENEFIT THE PUBLIC AS A WHOLE. 

Granting the present Petition will further the public interest by allowing Integrated 

Robotics to safely, efficiently, and economically perform aerial acquisitions within the NAS, 

commercially in support of: federal, state and local government agencies, land surveying, the utility

industry and the oil & gas industry. Additionally, use of the ECA - Infotron IT180 UAS will decrease 

congestion of the NAS, reduce pollution, and provide significant benefits to the economy. Notably, 

the benefits of Integrated Robotics’ proposed operation of the ECA - Infotron IT180 UAS will be 

realized without implicating any privacy issues.

1. The public will benefit from the aerial acquisitions performed. 

Integrated Robotics submits this Petition to commercially operate the ECA - Infotron IT180 

UAS and perform aerial acquisition within the NAS, in support of federal, state and local government 

agencies, land surveying, utility industry and the oil & gas industry. The ECA - Infotron IT180 UAS 

will provide safe, efficient, and economical aerial acquisition operations to further each of these 

fields, which are critical to the well-being of the general public.
15 | Page

The EXHIBITS in this petition with the exception of EXHIBIT (K) contain proprietary information, and in accordance with 

14 C.F.R § 11.35 (b), are not to be included in the Federal Docket Management System (FDMS).

The specific operations that Integrated Robotics will perform with the ECA - Infotron IT180 

UAS demonstrate how the requested exemption will directly benefit the above-referenced industries 

and the public. Government agencies such as DOI (Department of the Interior) will benefit by using 

the ECA-Infotron IT180 UAS for such things as wild land fire monitoring. NOAA (National Oceanic

& Atmospheric Administration) will benefit from using the ECA-Infotron IT180 for off coast marine 

mammal studies. In the land surveying industry, the ECA - Infotron IT180 UAS may be used in 

support of agriculture, scientific studies, wildlife monitoring, forestry operations, mining, and the oil 

and gas industries. The ECA - Infotron IT180 UAS will also be operated by Integrated Robotics to aid 

in facility inspections and the planning of new construction sites.

2. The public will benefit from decreased congestion of the NAS. 

The ECA - Infotron IT180 UA is battery powered and serves as a safe, efficient, and 

economical alternative to the manned aircraft traditionally utilized to obtain aerial imagery. By 

reducing the amount of manned aircraft needed to perform aerial acquisitions, an exemption allowing

the use of an ECA - Infotron IT180 UAS would reduce the amount of manned aircraft in the NAS, 

reduce noise and air pollution, and increase the safety of life and property in the air and on the ground.

Furthermore, by reducing the number of manned aircraft operating in the NAS, congestion 

around airports caused by arriving and departing aircraft will be reduced.

The ECA - Infotron IT180 UAS does not require an airport to takeoff or land. Likewise, a reduction 

of manned aircraft conducting aerial survey missions would result in fewer aircraft that must be 

handled by air traffic control during the ground, takeoff, departure, arrival, and landing phases of flight 

operations.

3. The public will benefit from the safety and efficiency of the ECA -

Infotron IT180 UAS. 

Conducting aerial acquisitions with the ECA - Infotron IT180 UAS, instead of manned 

aircraft, will greatly benefit the public by drastically reducing the levels of air and noise pollution 

generated during traditional aerial survey flight operations. By using battery power and electric 
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The EXHIBITS in this petition with the exception of EXHIBIT (K) contain proprietary information, and in accordance with 

14 C.F.R § 11.35 (b), are not to be included in the Federal Docket Management System (FDMS).

motors, the ECA - Infotron IT180 UAS produces no air pollution, and is the most viable 

environmentally conscious alternative to the cabin class, six cylinder internal combustion twin engine 

aircraft that are typically utilized for aerial acquisitions, and burn approximately 20-30 gallons per 

hour of leaded aviation fuel. The ECA - Infotron IT180 UA, while reducing the carbon footprint of 

aerial acquisitions, also reduces noise pollution, as the UAS is propelled by battery powered electric 

motors, rather than an internal combustion engine.

By using the ECA - Infotron IT180 UAS to perform aerial acquisitions, the substantial risk 

to life and property in the air and on the ground, which is usually associated with traditional manned 

aircraft flight operations, will be substantially reduced or completely eliminated. Aside from the lack 

of flight crew members located onboard the aircraft, the ECA - Infotron IT180 UA (weighing 

approximately 20 kg at its maximum gross weight with a length of 1,800 mm, width of 1,800 mm, and 

with no fuel on board), has less physical potential for collateral damage to life and property on the 

ground, and in the air, compared to the manned aircraft that typically conduct aerial acquisitions 

(weighing approximately 6,500 pounds with a wingspan of approximately 40 feet, a length of 34 feet, 

and a fuel capacity of 180 gallons).

4. Performing aerial acquisition operations with the ECA - Infotron IT180 

UAS will benefit the economy. 

In addition to being safe and efficient, the ECA - Infotron IT180 UAS is also an economical 

alternative to using manned aircraft to conduct aerial acquisitions. As such, operation of the ECA -

Infotron IT180 UAS will allow United States based companies, like Integrated Robotics, to remain 

competitive and contribute to growth of the U.S. economy. Specifically, with the rising cost of 

aviation fuel and the Environmental Protection Agency (“EPA”) regulatory actions phasing out leaded 

aviation fuels, U.S. owned and operated companies must adopt new and alternative technology in 

order to remain competitive. Operating the battery powered ECA - Infotron IT180 UAS is one such 

technology that not only allows companies greater operational flexibility compared to manned 

aircraft, but provides such flexibility without the high operational cost of a traditional manned aircraft.
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The EXHIBITS in this petition with the exception of EXHIBIT (K) contain proprietary information, and in accordance with 

14 C.F.R § 11.35 (b), are not to be included in the Federal Docket Management System (FDMS).

By operating the ECA - Infotron IT180 UAS, companies such as Integrated Robotics, can 

remain competitive and profitable, and therefore, provide greater job stability to employees and 

contractors, which will ultimately contribute to growth of the U.S. economy. Improved financial 

performance of U.S. companies, through commercial use of the ECA - Infotron IT180 UAS, provides 

a stable workforce that increases consumer spending; improves local, state, and federal tax revenues; 

and allows companies to invest in research and development in order to remain competitive both in 

the United States and abroad.

5. There are no privacy issues. 

Similar to the manned aerial acquisition flight operations that have been conducted for 

decades, Integrated Robotics’ proposed operation of the ECA - Infotron IT180 UAS will not implicate 

any privacy issues. Specifically, the ECA - Infotron IT180 UAS will be operated pursuant to the 

specific conditions and limitations set forth herein, and in accordance with the Federal Aviation 

Regulations, including the minimum altitude requirements of 14 C.F.R. § 91.119. Most significantly, 

the ECA - Infotron IT180 UA will not be operated closer than 500 feet to any person, vessel, vehicle, 

or structure, which is not directly involved in the operation.

E. THE REASONS WHY GRANTING THE EXEMPTION WOULD NOT 

ADVERSELY AFFECT SAFETY, OR HOW THE EXEMPTION WOULD 

PROVIDE A LEVEL OF SAFETY AT LEAST EQUAL TO THAT PROVIDED 

BY THE RULE FROM WHICH INTEGRATED ROBOTICS SEEKS 

EXEMPTION. 

1. Reasons why the ECA - Infotron IT180 UAS meets the conditions of 

The FAA Modernization and Reform Act of 2012 (FMRA) Section 

333. 

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

unmanned aircraft and its operation, Integrated Robotics’ operation of the ECA - Infotron IT180

UAS meets the conditions of FMRA Section 333, and will not require an airworthiness 

certificate in accordance with 14 C.F.R. Part 21, Subpart H.

Section 333 provides authority for a UAS to operate without airworthiness certification
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The EXHIBITS in this petition with the exception of EXHIBIT (K) contain proprietary information, and in accordance with 

14 C.F.R § 11.35 (b), are not to be included in the Federal Docket Management System (FDMS).

and sets forth requirements for considering whether a UAS will create a hazard to users of the

NAS or the public, or otherwise pose a threat to national security. Specifically, FMRA Section

333 states the following, in part:

(a) In General.--Notwithstanding any other requirement of this subtitle, and not later than 

180 days after the date of enactment of this Act, the Secretary of Transportation shall 

determine if certain unmanned aircraft systems may operate safely in the national airspace 

system before completion of the plan and rulemaking required by section 332 of this Act or the 

guidance required by section 334 of this Act.

(b) Assessment of Unmanned Aircraft Systems.--In making the determination under 

subsection (a), the Secretary shall determine, at a minimum--

(1) which types of unmanned aircraft systems, if any, as a result of their size, weight, 

speed, operational capability, proximity to airports and populated areas, and 

operation within visual line of sight do not create a hazard to users of the national 

airspace system or the public or pose a threat to national security; and 

(2) whether a certificate of waiver, certificate of authorization, or airworthiness 

certification under section 44704 of title 49, United States Code, is required for the 

operation of unmanned aircraft systems identified under paragraph (1). 

(c) Requirements for Safe Operation.--If the Secretary determines under this section that 

certain unmanned aircraft systems may operate safely in the national airspace system, the 

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

national airspace system.

In seeking this exemption, Integrated Robotics submits that the ECA - Infotron IT180 UAS 

can operate safely in the NAS pursuant to FMRA Section 333, as demonstrated by: (a) the

characteristics of the ECA - Infotron IT180 UAS; (b) the pilot certification requirement; (c) the 

specific operating limitations; and (d) the Integrated Robotics “Standard Operational Procedures (SOP) 

and Policies.”

a. The specifications of The ECA - Infotron IT180 UAS 

demonstrate its safe characteristics. 

The ECA - Infotron IT180 UAS does not create a hazard to users of the NAS or the public, or

otherwise pose a threat to national security considering its size, weight, speed, and operational

capability.
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The EXHIBITS in this petition with the exception of EXHIBIT (K) contain proprietary information, and in accordance with 

14 C.F.R § 11.35 (b), are not to be included in the Federal Docket Management System (FDMS).

i. Technical specifications of the ECA - Infotron IT180 UAS. 

The technical specifications of the ECA - Infotron IT180 UAS are set forth at pages 3 through 

7 of the ECA - Infotron IT180 Product Specifications and the ECA-Infotron IT180 Technical Guide 

Pages 27 through 29, attached hereto as EXHIBITS (A) & (B). 

ii. The ECA - Infotron IT180 UAS Autonomous Flight and 

Navigation Modes enable the UAS to remain within a defined 

operational area. 

The ECA - Infotron IT180 UAS may be operated in both manual and autonomous flight 

modes. A complete description of autonomous flight modes is provided at pages 46 through 64 of 

ECA – Infotron IT180 Cockpit Application Manual, attached hereto as EXHIBIT (C). 

iii The ECA - Infotron IT180 UAS Is Designed For Automatic 

Return To Home Point Or Automatic Landing In The Event Of 

Loss Of The Control Link Or Navigation. 

A complete description of the Failsafe Functions of the ECA - Infotron IT180 UAS is 

set forth at pages 74 through 81 of the ECA - Infotron IT180 Cockpit Application Manual, 

attached hereto as EXHIBIT (C). 

iv. The ECA - Infotron IT180 GCS and its operation. 

The ECA - Infotron IT180 ground control station (GCS) is comprised of at least one remote 

controller, as well as a mobile device (GCS) supporting the system software, known as the “Cockpit 

Application Manual, EXHIBIT (C). A complete description of the operation and specifications of the 

ECA - Infotron IT180 remote controller is provided at pages 30 through 32 of the ECA - Infotron 

IT180 Cockpit Application Manual, EXHIBIT (C). A complete description of the operation of the 

Flight Data Recorder is provided at page 73 of the ECA - Infotron IT180 Technical Guide, EXHIBIT 

(B). The ECA - Infotron IT180 UAS is compliant with all Federal Communications Commission 

(FCC) requirements, and the radio frequency spectrum used for operation and control of the UA.
20 | Page

The EXHIBITS in this petition with the exception of EXHIBIT (K) contain proprietary information, and in accordance with 

14 C.F.R § 11.35 (b), are not to be included in the Federal Docket Management System (FDMS).

b. Flight operations of the ECA - Infotron IT180 UAS are limited 

to the line of sight of a certificated pilot in command with a 

safety observer. 

Integrated Robotics will only utilize certificated pilots, trained and certified in accordance with 

the ECA-Infotron Pilot Training Syllabus EXHIBIT (D), to act as a pilot in command (PIC) of the 

ECA - Infotron IT180 UAS. Additionally, a safety observer will assist all pilots during flight 

operations and have a separate operational Spektrum DX-8 remote controller in the event of an 

emergency. A description of the safety observer’s Spektrum DX-8 remote controller is found on page 

35 of the ECA-Infotron Technical Guide, Exhibit (C). 

c. Flights of the ECA - Infotron IT180 UAS will be conducted 

pursuant to specific operating limitations. 

In seeking this exemption, Integrated Robotics proposes to commercially operate the ECA -

Infotron IT180 UAS for the special purpose of conducting aerial acquisitions within the NAS, pursuant 

to the following specific operating limitations:

1. Operations authorized by this grant of exemption are limited to the following 

aircraft described in the operating documents, a rotorcraft weighing 24kg or less at 

maximum gross weight: ECA - Infotron IT180 Unmanned Aircraft System. Proposed 

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

grant. 

2. UAS operations under this exemption will be limited to conducting operations 

for the purpose of aerial acquisitions. 

3. The UA may not be flown at an indicated airspeed exceeding 90km/h. 

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

ground level (AGL), as indicated by the procedures specified in the operating 

documents. All altitudes reported to ATC must be in feet AGL. 

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

times. This requires the PIC to be able to use human vision unaided by any device 

other than corrective lenses.

6. The use of first person view (FPV) by the PIC or visual observer (VO) is not 

permitted. 

7. All operations must utilize a visual observer (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. Electronic 
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The EXHIBITS in this petition with the exception of EXHIBIT (K) contain proprietary information, and in accordance with 

14 C.F.R § 11.35 (b), are not to be included in the Federal Docket Management System (FDMS).

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

designated before the flight and cannot transfer his or her designation for the duration 

of the flight. The PIC must ensure that the VO can perform the functions prescribed in 

the operating documents. 

8. The VO must not perform any other duties beyond assisting the PIC with 

seeing and avoiding other air traffic and other ground based obstacles/obstructions and 

is not permitted to operate the camera or other instruments. 

9. The operating documents and the grant of exemption must be accessible 

during UAS operations and made available to the Administrator upon request. If a 

discrepancy exists between the conditions and limitations contained in the grant of 

exemption and the procedures outlined in the operating documents, the conditions and 

limitations contained in the grant of exemption take precedence and must be followed. 

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

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

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

documents to the Administrator upon request.

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

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

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

then the operator must petition for amendment to the 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.

10. 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. 

11. 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. The PIC who conducts the functional test flight must 

make an entry in the aircraft records. 

12. The pre-flight inspection must account for all potential discrepancies, e.g. 

inoperable components, items, or equipment, not already covered in the relevant 

sections of the operating documents. 

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

maintenance, over haul, replacement, inspection, and life limit requirements. 

14. The operator must carry out its maintenance, inspections, and record keeping 

requirements, in accordance with the operating documents. Maintenance, inspection, 

alterations, and status of replacement/overhaul component parts must be noted in the 

aircraft records, including total time in service, description of work accomplished, and 

the signature of the authorized person returning the UAS to service. 
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The EXHIBITS in this petition with the exception of EXHIBIT (K) contain proprietary information, and in accordance with 

14 C.F.R § 11.35 (b), are not to be included in the Federal Docket Management System (FDMS).

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

Safety Bulletins. 

16. The authorized person must make an entry in the aircraft record of the 

corrective action taken against discrepancies discovered between inspections. 

17. The operator may not permit any PIC to operate unless the PIC meets the 

operator’s qualification criteria and demonstrates the ability to safely operate the UAS 

in a manner consistent with how the UAS will be operated under the exemption, 

including evasive and emergency maneuvers and maintaining appropriate distances 

from persons, vessels, vehicles and structures. PIC qualification flight hours must be 

logged in a manner consistent with 14 C.F.R. § 61.51(b). The VO is also required to 

complete the operator’s training requirements. A record of training must be 

documented and made available upon request by the Administrator. Flights for the 

purposes of training the operator’s PICs and VOs (training, proficiency, and 

experience-building), are permitted under the terms of the exemption. However, 

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

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

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

with appropriate distance from nonparticipants in accordance with 14 C.F.R. § 91.119.

18 UAS operations may not be conducted during night, as defined in 14 C.F.R. § 

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

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

19. The UA may not operate within 5 nautical miles of an airport reference point 

as denoted on a current FAA-published aeronautical chart unless a letter of agreement 

with that airport’s management is obtained, and the operation is conducted in 

accordance with a NOTAM as required by the operator’s COA. The letter of 

agreement with the airport management must be made available to the Administrator 

upon request. 

20. 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. 

21. If the UA loses communications or loses its GPS signal, it must return to a 

pre-determined location within the planned operating area and land or be recovered in 

accordance with the operating documents. 

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

emergencies in accordance with the operating documents. 

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

forecast weather conditions) there is enough power to fly at normal cruising speed to 

the intended landing point and land the UA with 25% battery power remaining. 

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

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

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

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

operation. All operations shall be conducted in accordance with airspace requirements 
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The EXHIBITS in this petition with the exception of EXHIBIT (K) contain proprietary information, and in accordance with 

14 C.F.R § 11.35 (b), are not to be included in the Federal Docket Management System (FDMS).

in the ATO issued COA including class of airspace, altitude level and potential 

transponder requirements. 

25 All aircraft operated in accordance with the exemption must be identified by 

serial number, registered in accordance with 14 C.F.R. part 47, and have identification 

(N-Number) markings in accordance with 14 C.F.R. part 45, Subpart C. Markings 

must be as large as practicable. 

26. 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. 

27. The documents required under 14 C.F.R. 91.9 and 91.203 must be available to 

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

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

official upon request.

28. The UA must remain clear and yield the right of way to all manned aviation 

operations and activities at all times. 

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

30. The UA may not be operated over congested or densely populated areas. 

31. Flight operations must be conducted at least 500 feet from all nonparticipating 

persons (persons other than the PIC, VO, operator trainees or essential persons), 

vessels, vehicles, and structures unless: 

a. Barriers or structures are present that sufficiently protect nonparticipating 

persons from the UA and/or debris in the event of an accident. The operator must 

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

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

UA, flight operations must cease immediately and/or; 

b. The aircraft is operated near vessels, vehicles or structures where the 

owner/controller of such vessels, vehicles or structures has granted permission and the 

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

determined that it does not present an undue hazard, and; 

c. Operations nearer to the PIC, VO, operator trainees or essential persons do not 

present an undue hazard to those persons per § 91.119(a). 

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

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

Permission from land owner/controller or authorized representative will be obtained 

for each flight to be conducted. 

33. 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 
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The EXHIBITS in this petition with the exception of EXHIBIT (K) contain proprietary information, and in accordance with 

14 C.F.R § 11.35 (b), are not to be included in the Federal Docket Management System (FDMS).

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.

d. Operation of the ECA - Infotron IT180 UAS will be in 

accordance with standard operating procedures and 

policies. 

e.

“Standard Operating Procedures (SOP) And Policies” as defined in the “Technical Guide” 

EXHIBIT (B) and “Using the Cockpit Program” EXHIBIT (C), will regulate Integrated

Robotics’ operation of the ECA - Infotron IT180 UAS and will significantly contribute to maintaining 

the level of safety contemplated by the regulations from which Integrated Robotics now seeks relief.

2. Reasons why an exemption from the requirements of Section 61.113(a) and (b) 

would not adversely affect safety. 

Integrated Robotics submits that the equivalent level of safety established by Section 61.113(a) 

and (b) will be maintained because no PIC will be allowed to operate the ECA - Infotron IT180 UAS 

unless that PIC has demonstrated, by meeting minimum flight-hour and currency requirements, that the 

PIC is able to safely operate the ECA - Infotron IT180 UAS in a manner consistent with the 

exemption, including evasive and emergency maneuvers and maintaining appropriate distances from 

people, vessels, vehicles and structures.

Considering Integrated Robotics’ proposed area of operations, and the operating limitations 

set forth-above; the parallel nature of private pilot aeronautical knowledge requirements and those of 

commercial pilot requirements (See Exemption No. 11062); and the airmanship skills necessary to 

safely operate the ECA - Infotron IT180 UAS, Integrated Robotics submits that the additional manned 

airmanship experience of a private or commercially certificated pilot would not correlate to the 

airmanship skills necessary for Integrated Robotics’ specific proposed flight operations.

The FAA has previously granted relief from Section 61.113(a) and (b) specific to UAS, in 

circumstances similar, in all material respects, to those presented herein (e.g. Exemption Nos. 11062, 

11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 11112, 11136, 11138, 11150, 11153, 
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The EXHIBITS in this petition with the exception of EXHIBIT (K) contain proprietary information, and in accordance with 

14 C.F.R § 11.35 (b), are not to be included in the Federal Docket Management System (FDMS).

11156, 11158, 11159, 11160, 11161, 11170, 11171, 11172).

Integrated Robotics will not allow any PIC to operate the ECA - Infotron IT180 UAS unless 

that PIC has demonstrated, by meeting minimum flight-hour requirements or the ECA - Infotron 

IT180 UAS training and currency requirements, that the PIC is able to safely operate the ECA -

Infotron IT180 UAS in a manner consistent with this exemption, including evasive and emergency 

maneuvers and maintaining appropriate distances from people, vessels, vehicles and structures.

Specifically, the PIC must have accumulated and logged, in a manner consistent with 14 

C.F.R. § 61.51(b), 25 hours of total time as a UAS rotorcraft pilot including at least 10 hours logged 

as a UAS pilot with a multi-rotor UAS (with a minimum of 5 hours of those hours as a UAS pilot 

operating the same make and model of UAS to be used for operations under the exemption). In 

addition to the flight hour requirements, the PIC must accomplish 3 take-offs and landings of the 

ECA - Infotron IT180 UA in the preceding 90 days (for currency purposes).

As in Exemption Nos. 11062, 11138, and 11153, prior documented flight experience that was 

obtained in compliance with applicable regulations will ensure an equivalent level of safety during 

Integrated Robotics’ proposed operations. The Administrator has held that prior documented flight 

experience that was obtained in compliance with applicable regulations would ensure safe operations, 

stating as follows:

In Exemption No. 11062, the FAA required that prior to conducting operations for the purpose 

of motion picture filming (or similar operations), the PIC must have accumulated and logged, 

in a manner consistent with 14 C.F.R. 61.51(b), 25 hours of total time as a UAS rotorcraft pilot 

including at least 10 hours logged as a UAS pilot with a multi-rotor UAS. Prior to operations 

under Exemption No. 11062, the PIC must also have accumulated and logged a minimum of 5 

hours as a UAS pilot operating the same make and model of UAS to be used for operations 

under the exemption. For clarification, the FAA considers these minimum hour requirements 

to be inclusive rather than additive; i.e. 5 hours make and model time may be included in the 

10 hours of multi-rotor time and the 10 hours may be included in the total 25 hours of UAS 

rotorcraft time. In addition to the hour requirements, the PIC must accomplish 3 take-offs and 

landings in the preceding 90 days (for currency purposes). The FAA finds that at a minimum, 

the flight-hour requirements in Exemption No. 11062 are appropriate to practice and build 

proficiency in the skills necessary to safely conduct the petitioner’s proposed operations. The 

FAA also finds that prior documented flight experience that was obtained in compliance with 

applicable regulations would satisfy this requirement. Training, proficiency, and experiencebuilding flights can also be conducted under the grant of exemption to accomplish the required 

flight time. During training, proficiency, and experience-building flights the PIC is required to 

operate the UA with appropriate distances in accordance with 14 C.F.R 91.119.
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The EXHIBITS in this petition with the exception of EXHIBIT (K) contain proprietary information, and in accordance with 

14 C.F.R § 11.35 (b), are not to be included in the Federal Docket Management System (FDMS).

Exemption No. 11138 at page 15.

Accordingly, Integrated Robotics will ensure safe operations by not allowing any PIC

to operate the ECA - Infotron IT180 UAS unless that PIC has demonstrated, by meeting minimum 

flight-hour and currency requirements, that the PIC is able to safely operate the ECA - Infotron IT180 

UAS in a manner consistent with the exemption, including evasive and emergency maneuvers and 

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

3. Reasons why an exemption from the requirements of Section 91.7(a) would 

not adversely affect safety. 

The equivalent level of safety established by Section 91.7(a) will be maintained because 

prior to every flight, Integrated Robotics will ensure that the ECA - Infotron IT180 UAS is in an 

airworthy condition based upon the UAS’s compliance with its operating documents and as stated in 

the proposed conditions and limitations herein.

Additionally, the FAA has previously granted relief from Section 91.7(a) specific to UAS, in 

circumstances similar, in all material respects, to those presented herein (e.g. Exemption

Nos. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 11112, 11136, 11138, 

11150, 11153, 11156, 11157, 11158, 11159, 11160, 11161, 11166, 11167, 11170, 11171, 11172).

4. Reasons why an exemption from the requirements of Section 91.121 would 

not adversely affect safety. 

The equivalent level of safety established by Section 91.121 will be maintained because the 

altitude of the ECA - Infotron IT180 UA will be reported to air traffic control (ATC) in feet above 

ground level (AGL), and Integrated Robotics will operate the ECA - Infotron IT180 UA within visual 

line of sight, at or below 400 feet AGL. Furthermore, the altitude information of the ECA - Infotron 

IT180 UA will be provided to the PIC via GPS equipment and a radio communications telemetry data 

link, which downlinks from the UA to the GCS for active monitoring of the flight path and altitude. 

Prior to each flight, a zero altitude initiation point is automatically established by the UAS at ground 

level.
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The EXHIBITS in this petition with the exception of EXHIBIT (K) contain proprietary information, and in accordance with 

14 C.F.R § 11.35 (b), are not to be included in the Federal Docket Management System (FDMS).

The FAA has previously granted relief from Section 91.121 specific to UAS, in circumstances 

similar, in all material respects, to those presented herein (e.g. Exemption Nos. 11062, 11063, 11064, 

11065, 11066, 11067, 11080, 11109, 11112, 11136, 11138, 11150, 11153, 11156, 11157, 11158, 

11159, 11160, 11161, 11166, 11167, 11170, 11171).

5. Reasons why an exemption from the requirements of Section 

91.151(b) would not adversely affect safety. 

A grant of this exemption would ensure an equivalent level of safety established by 14 

C.F.R. Section 91.151(b) as a result of (1) the technical specifications of the ECA - Infotron IT180 

UAS; (2) the limitations on the proposed flight operations; and (3) the location of the proposed flight 

operations. Accordingly, Integrated Robotics will ensure that it will safely operate the battery 

powered ECA - Infotron IT180 UA during daylight hours in VFR conditions, with enough battery 

power to fly for a total duration of 20 minutes to the first point of intended landing and, assuming 

normal cruising speed, to fly after that for at least 10 minutes (i.e., 33 percent battery power 

remaining).

Here, as in Exemption No. 11109, the technical specifications of the ECA - Infotron IT180 

UAS; the limitations on the proposed flight operations; and the location of the proposed operations, 

will ensure an equivalent level of safety established by 14 C.F.R. Section 91.151(b).

Furthermore, safety will be ensured as the ECA - Infotron IT180 UAS provides visual and audible 

warnings to the PIC at the GCS when the UAS experiences low battery voltage, and if no action is 

taken in response to the warnings, the UAS will automatically return to its starting point, land and shut 

its motor down. A full description of the low battery level fail safes is provided at page 81 of the ECA 

- Infotron IT180 Cockpit Application Manual, attached hereto as EXHIBIT (C). 

Additionally, the ECA-Infotron IT180 UAS has provisions for “critical battery” in that if, a battery 

condition exists that prevents the ECA-Infotron IT180 UAS from returning to its starting point due to a 

“critical battery,” after warnings to the PIC and GCS, the UAS will initiate a very slow descent 

(emergency return to ground). The PIC can control the camera (in photo NADIR mode – looking 
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The EXHIBITS in this petition with the exception of EXHIBIT (K) contain proprietary information, and in accordance with 

14 C.F.R § 11.35 (b), are not to be included in the Federal Docket Management System (FDMS).

straight down) to evaluate the terrain the aircraft will land on and can control the movement of the 

UAS to make sure it lands safely. A full description of the critical battery fail safes is provided at page 

79 of the ECA - Infotron IT180 Cockpit Application Manual, attached hereto as EXHIBIT (C).

Significantly, previous exemptions granted by the FAA concerning Section 91.151 establish 

that safety is not adversely affected when the technical characteristics and operating limitations of the 

UAS are considered. Relief has been granted for manned aircraft to operate at less than the minimums 

prescribed in Section 91.151, including Exemption Nos. 2689, 5745, and 10650. Moreover, the FAA 

has previously granted relief from Section 91.151 specific to UAS, in circumstances similar, in all 

material respects, to those presented herein (e.g. Exemption Nos. 8811, 10808, 10673, 11042, 11062, 

11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 11136, 11138, 11150, 11153, 11156, 

11157, 11158, 11159, 11160, 11161, 11166, 11167, 11170, 11171, 11172). 

6. Reasons why an exemption from the requirements of Sections 91.405(a), 

91.407(a)(1), 91.409(a)(1) & (a)(2), And 91.417(a) & (b) would not adversely 

affect safety. 

In seeking this exemption, Integrated Robotics submits that the equivalent level of safety with 

regard to the regulatory maintenance and alteration requirements established by Sections 91.405(a), 

91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b) will be met because Integrated Robotics will 

perform maintenance, alterations, or preventive maintenance on the UAS using the methods, 

techniques, and practices prescribed in the operating documents (i.e., the ECA - Infotron IT180 UAS 

Maintenance Manual, EXHIBIT (E), the ECA-Infotron IT180 UAS Technical Manual, EXHIBIT (B), 

or will utilize manufacturer authorized support services to perform maintenance, alterations, or 

preventive maintenance on the UAS.

Furthermore, Integrated Robotics will document and maintain all maintenance records for the 

ECA - Infotron IT180 UAS.

Since the ECA - Infotron IT180 UAS will be inspected as prescribed by the operating 

documents, Integrated Robotics will maintain the equivalent level of safety established by Sections 
29 | Page

The EXHIBITS in this petition with the exception of EXHIBIT (K) contain proprietary information, and in accordance with 

14 C.F.R § 11.35 (b), are not to be included in the Federal Docket Management System (FDMS).

91.405(a), 91.409(a)(1), and 91.409(a)(2). The following operating documents are attached hereto, 

identified as the following Exhibits: the ECA - Infotron IT180 UAS Maintenance Manual, EXHIBIT

(E), the ECA-Infotron IT180 UAS Technical Manual, EXHIBIT (B), ECA-Infotron IT180 UAS 

Maintenance Contract EXHIBIT (F).

Likewise, the exemption sought will not adversely affect safety because Integrated Robotics

will perform maintenance, alterations or preventive maintenance on the UAS using the methods, 

techniques, and practices prescribed by the operating documents, or will utilize the manufacturer’s

authorized support services to perform maintenance, alterations, or preventive maintenance on the 

UAS.

Furthermore, the exemption sought would maintain an equivalent level of safety 

established by Sections 91.407, 91.417(a) and 91.417(b), because Integrated Robotics will 

document and maintain maintenance records for the ECA - Infotron IT180 UAS.

In consideration of Integrated Robotics’ proposed operating limitations, the operating 

documents, and the technical aspects of the ECA - Infotron IT180 UAS, Integrated Robotics submits 

that safety will not be adversely affected by granting exemption from 14 C.F.R. Sections 91.405(a), 

91.407(a)(1) and (a)(2), 91.409(a)(2), and 91.417(a) and (b). The FAA has previously granted relief 

specific to UAS in circumstances similar, in all material respects, to those presented herein (e.g. 

Exemption Nos. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 11112, 11136, 

11138, 11150, 11153, 11156, 11157, 11158, 11159, 11160, 11161, 11166, 11167, 11170, 11171, 

11172).

7. The FAA may prescribe any other conditions for safe operation. 

In accordance with Section 333 of the FAA Modernization and Reform Act of 2012 (FMRA) 

and 14 C.F.R. § 21.16 entitled Special Conditions, Integrated Robotics requests that the FAA prescribe 

special conditions for the intended operation of the ECA - Infotron IT180 UAS, which contain such 

safety standards that the Administrator finds necessary to establish a level of safety equivalent to that 

established by 14 C.F.R. Part 21, Subpart H, and 14 C.F.R §§ 61.113(a) & (b), 91.7 (a), 91.121, 
30 | Page

The EXHIBITS in this petition with the exception of EXHIBIT (K) contain proprietary information, and in accordance with 

14 C.F.R § 11.35 (b), are not to be included in the Federal Docket Management System (FDMS).

91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b). Such special conditions 

will permit safe operation of the UA for the limited purpose of conducting aerial acquisitions within 

the NAS for compensation or hire. FMRA Section 333 sets forth the requirements for considering 

whether a UAS will create a hazard to users of the NAS or the public, or otherwise pose a threat to 

national security; and further, provides the authority for such UAS to operate without airworthiness 

certification in accordance with any requirements that must be established for the safe operation of the 

UAS in the NAS.

Likewise, the Administrator may prescribe special conditions pursuant to 14 C.F.R.

§ 21.16, for operation of the ECA - Infotron IT180 UAS, since the airworthiness regulations of 14 

C.F.R. Part 21 do not contain adequate or appropriate safety standards, due to the novel or unusual 

design features of the aircraft. Section 21.16, entitled Special Conditions, states the following:

If the FAA finds that the airworthiness regulations of this subchapter do not contain 

adequate or appropriate safety standards for an aircraft, aircraft engine, or propeller because 

of a novel or unusual design feature of the aircraft, aircraft engine or propeller, he 

prescribes special conditions and amendments thereto for the product. The special 

conditions are issued in accordance with Part 11 of this chapter and contain such safety 

standards for the aircraft, aircraft engine or propeller as the FAA finds necessary to 

establish a level of safety equivalent to that established in the regulations.

See 14 C.F.R. § 21.16.

Therefore, in accordance with FMRA Section 333 and 14 C.F.R. § 21.16, the FAA may 

prescribe special conditions for Integrated Robotics’ intended operation of the ECA-Infotron 

IT180UAS, which contain such safety standards that the Administrator finds necessary to 

establish a level of safety equivalent to that established by 14 C.F.R. Part 21, Subpart H, and 

14 C.F.R Sections 61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 

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

F. A SUMMARY THAT CAN BE PUBLISHED IN THE FEDERAL REGISTER,

STATING: THE RULES FROM WHICH INTEGRATED ROBOTICS SEEKS 

EXEMPTION: 

Integrated Robotics Imaging Systems, LTD seeks exemption from the requirements of 14 C.F.R 

Sections 61.113(a)&(b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & 

(a)(2), and 91.417(a) & (b). 
31 | Page

The EXHIBITS in this petition with the exception of EXHIBIT (K) contain proprietary information, and in accordance with 

14 C.F.R § 11.35 (b), are not to be included in the Federal Docket Management System (FDMS).

A brief description of the nature of the exemption Integrated Robotics seeks: 

This exemption will permit Integrated Robotics Imaging Systems, LTD to commercially 

operate an Unmanned Aircraft System (UAS) for the purpose of conducting aerial 

acquisitions within the National Airspace System (NAS).

G. ANY ADDITIONAL INFORMATION, VIEWS, OR ARGUMENTS 

AVAILABLE TO SUPPORT INTEGRATED ROBOTICS’ REQUEST. 

This Petition is made pursuant to the FAA Modernization and Reform Act of 2012 (FMRA) 

Section 333, which directs the Secretary of Transportation to determine if certain UAS may 

operate safely in the NAS. As such, Integrated Robotics’ request for exemption may be 

granted pursuant to the authority of FMRA Section 333 and 14 C.F.R. Part 11, as set forth 

above.

FMRA Section 333 sets forth the requirements for considering whether a UAS will create a 

hazard to users of the NAS or the public, or otherwise, pose a threat to national security; and further, 

provides the authority for such UAS to operate without airworthiness certification.

As discussed in detail above, Integrated Robotics will operate the ECA - Infotron IT180 

UAS safely in the NAS, without creating a hazard to users of the NAS, or the public, or 

otherwise pose a threat to national security. Further, granting the request for exemption will allow 

Integrated Robotics to conduct further research into Patented SAA (Sense and Avoid) technology 

currently being pursued by Integrated Robotics.

CONCLUSION

As set forth herein, Integrated Robotics seeks an exemption pursuant to 14 C.F.R. § 11.61 

and Section 333 of the FAA Modernization and Reform Act of 2012 (FMRA), which will permit safe 

operation of the ECA - Infotron IT180 UAS commercially, without an airworthiness certificate, for 

the limited purpose of conducting aerial acquisitions within the National Airspace System (NAS). By 

granting this Petition, the FAA Administrator will be fulfilling the Congressional mandate of the 

FAA Modernization and Reform Act of 2012, while also be advancing the interests of the public, by 

allowing Integrated Robotics to safely, efficiently, and economically operate the ECA - Infotron 
32 | Page

The EXHIBITS in this petition with the exception of EXHIBIT (K) contain proprietary information, and in accordance with 

14 C.F.R § 11.35 (b), are not to be included in the Federal Docket Management System (FDMS).

IT180 UAS commercially within the NAS.

WHEREFORE, in accordance with the Federal Aviation Regulations and the FAA

Modernization and Reform Act of 2012, Section 333, Integrated Robotics respectfully requests that 

the Administrator grant this Petition for an exemption from the requirements of 14 C.F.R Sections 

61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 

91.417(a) & (b), and permit Integrated Robotics to operate the ECA - Infotron IT180 UAS 

commercially for the purpose of conducting aerial acquisitions within the NAS.

Dated: May 29, 2015

Respectfully submitted,

Integrated Robotics Imaging Systems, Ltd.

John C. Parker, Chief Operating Officer

140 Main Street Loop

Kenai, Alaska 99611

Phone: (907) 283-4223

Email: iris@uav-alaska.com

cc: Mr. Greg Stein, Esq.

James H. Williams, AFS-80

Jay Skaggs, FAA Anchorage

 
33 | Page

The EXHIBITS in this petition with the exception of EXHIBIT (K) contain proprietary information, and in accordance with 

14 C.F.R § 11.35 (b), are not to be included in the Federal Docket Management System (FDMS).

EXHIBITS

(A) ECA-Infotron – IT180 UAS – Product Specifications

(B) ECA-Infotron -IT180 UAS - Technical Guide Version 3 (June 2013)

(C) ECA-Infotron - IT180 UAS - Using the Cockpit Application - Version 8.1.6 (June 2014)

(D) ECA-Infotron - IT180 UAS - Pilot Training Syllabus - Version 1-2 (Aug 2013)

(E) ECA-Infotron - IT180 UAS - Maintenance Manual with 22 Plates (Sept 2012)

(F) Integrated Robotics - IT180 - Setup for Preflight (July 2014)

(G) Integrated Robotics - IT180 - Preflight Check List - (July 2014)

(H) Integrated Robotics - IT180 - Operational Check List - Flight - (July 2014) 

(I) Integrated Robotics - IT180 - Operational Check List - Simulator (July 2014)

(J) Infotron Pilot Certificate issued to John C Parker on 27 June 2014

(K) FAA Registration – IT180 - (N180UV) issued (Feb 11, 2015)