for exemption / rule-making 

Contact information:

Brian Gaudet, d.b.a. Strategic Designs

39 Tiffany Cir.

Millbury, MA 01527

bgflyer@icloud.com

508-754-5664

This is an exemption request pursuant to FMRA Section 333 and Part 11 of 

the FAA Reform Act of 2012 for Mr. Brian Gaudet, d.b.a., Strategic Designs. 

The proposed exemption, if granted, would allow Strategic Designs to conduct 

commercial operations of small unmanned aircraft systems (“UAS”) meeting or 

exceeding all of the operational and safety requirements Congress has set forth 

in Section 333. 

Petitioner is an aerial service and technology company that plans to exploit the 

capabilities of Unmanned Aerial Systems to offer a multitude of services, 

including: 

- Aerial surveying / inspections - Remote sensing - Telecommunications -

Agriculture - Aerial filmmaking and photography - Energy systems inspections 

and asset management / wind turbine inspection 

- Construction site inspections and monitoring - Wildlife and forestry monitoring

- Educational and research operations - Pipeline / cell tower inspections

Pilot in Command (PIC) The pilot in command will be the owner of Strategic 

Designs, Mr. Brian Gaudet. Mr. Gaudet received his airman’s Private Pilot 

Certificate in 1977, number 3638364 and holds a current FAA-issued 3rd class 

airman medical certificate has a current bi-annual fight review. Mr. Gaudet has 

logged over 150 hours in single engine aircraft. Mr. Gaudet is also currently a 

part owner of a Cessna Cardinal 177B which he flies regularly as PIC. Mr. 

Gaudet is current for both day and night operation as PIC. 

Petitioner will comply with the applicable procedures and requirements stated in 

§ 91.103. Specifically, the PIC will take all actions including reviewing weather, 

flight battery requirements, aircraft performance data, and landing and takeoff 

distances before initiation of a flight. The PIC will also account for all relevant 

site-specific conditions in their preflight procedures. 
Petition Exemption Summary: 

Regulations from which the exemption is requested:

- 14 C.F.R. Part 21 (H)

- 14 C.F.R. Part 27

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

- 14 C.F.R. 61.23(a) and (c),

- 14 C.F.R. 61.101(e)(4) and (5)

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

- 14 C.F.R. 61.315(a)

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

- 14 C.F.R. 91.103(b)(2)

- 14 C.F.R. 91.105

- 14 C.F.R. 91.109

- 14 C.F.R. 91.119(c)

- 14 C.F.R. 91.121

- 14 C.F.R. 91.151 (a)(1)

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

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

- 14 C.F.R. 91.409 (a)(1) - (2)

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

Description of UAS and Equivalent Level of Safety

The primary UAS system that will be used is the DJI Inspire 1 quadcopter 

(model T600). The UAS will be safely operated in the NAS by maintaining line of 

sight visual contact, flown only during daylight, and less than 400ft above the 

ground. Flights will be operated at a lateral distance of no less than 100 feet from 

any persons or property not associated with the operation. Additional safety

features on the DJI Inspire 1 include return to home functionality when GPS is 

available and failsafe technology that return the aircraft to the takeoff point if the 

batteries run low. Additionally, the max flight time for the UAS will be limited to 

maintain a reserve of 25% battery power. At all times, the UAS will be operated in 

accordance with the safety and operational requirements of the manual (see link 

below.)

The specifications for the UAS DJI Inspire 1 are as follows: 

Weight: 2935 g

Diagonal Size: 438 x 451 x 301 mm

Max Ascent Speed: 5 m/s

Max Descent Speed: 4 m/s Max Speed: 22 m/s (no wind)
The Petitioner has supplied the following additional information on the DJI 

Inspire 1 UAS:

Inspire 1 Specs http://www.dji.com/product/inspire-1/spec

Inspire 1 Quick Start Guide

http://download.dji-innovations.com/downloads/inspire_1/en/Inspire_1_Quick_Sta

rt_Guide_v1.4_en.pdf

Inspire 1 User Manual

http://download.dji-innovations.com/downloads/inspire_1/en/Inspire_1_User_Man

ual_v1.4_en.pdf

Inspire 1 Safety Guidelines

http://download.dji-innovations.com/downloads/inspire_1/en/Inspire_1_Safety_G

uidelines_en.pdf

Inspire 1 Maintenance Manual

http://download.dji-innovations.com/downloads/inspire_1/en/Inspire_1_Maintena

nce_ManualV1.0_en.pdf

UAS Operations

Preflight would include checking the operation of the UAS to include the battery 

in both the transmitter and the UAS, the condition of the body of the UAS and its 

propellers. Updates to the firmware will be done as they become available and 

maintenance will be performed pursuant to the manufacturers recommendations. 

The area in which the drone will be flown will be checked for power lines, 

antennas, and other obstructions. The weather conditions will be monitored 

throughout the flight. Wind conditions will be reviewed and the UAS will only be 

flown in daylight. As the pilot, Brian would ensure that he is safe to operate the 

drone as though he were flying in the aircraft himself.

UAS Operating Parameters The petitioner states that all flights will be 

operated within visual line of sight (VLOS) of pilot, in daytime VFR flight 

conditions and all operations will be conducted with the assistance of a second 

spotter/observer. The UAS flights will be limited to a maximum altitude of 400 feet 

AGL. Altitude is accurately measured by GPS. The petitioner further states that 

an operator will ensure that only consenting production personnel will be allowed 

within 100 feet of the UA operation, and UAS will be kept at least 100’ from any 

inhabited structure. Generally the petitioner’s UAS will be operated in rural or 

suburban areas that will permit significantly larger safety zones. Flights would 

be conducted within the borders of the the United States.

Flight Standards District Offices (FSDOs) will be notified as required prior to 

operations to describe intended coordination for proposed operation(s). Petitioner 

will obtain an Air Traffic Organization (“ATO”) issued Certificate of Waiver or 

Authorization (“COA”) prior to conducting any operations under this grant of 
exemption. In fulfilling its requirements under the COA, Petitioner will be required 

to request a NOTAM not more than 72 hours in advance, but not less than 48 

hours prior to the operation. 

Petitioner’s UAS will remain clear and yield the right of way to all manned 

operations and activities at all times (including, but not limited to, ultralight 

vehicles, parachute activities, parasailing activities, and gliders / hang gliders). 

Petitioner will not conduct UAS operations within 5 nautical miles of the 

geographic center of a non-towered airport unless a letter of agreement with that 

airport’s management is obtained and the operation is conducted in accordance 

with a Notice to Airmen (“NOTAM”). 

Safety and Benefits of the UAS The petitioner will be using the UAS in a 

variety of applications that generally require expensive full-size manned aircraft 

to complete. Small, light, unmanned aerial vehicles offer a myriad of benefits over 

the use of full-sized manned aircraft for electric power line inspection, oil/gas 

pipeline inspection, advanced agriculture, film and still photography, just to name 

a few. Replacing significantly larger manned aircraft carrying crew and flammable 

fuel with small UAS carrying no passengers or crew creates a much greater 

margin of safety for the pilots and crew. By granting Petitioner’s requested 

exemptions, the FAA will help drive development of safe and successful 

commercial UAS operations and will advance the public knowledge base for such 

operations. Petitioner is committed to promoting the UAS research efforts of 

policymakers including the FAA, NASA, DOD and DARPA by sharing data from 

its commercial UAS operations and serving as a resource for future UAS 

research operations. Thus, the FAA has good cause to grant this Petition. 

Conclusion For the foregoing reasons, the exemptions requested herein 

should be granted and Petitioner should be permitted to conduct small UAS 

operations in accordance with its manuals and all other operating parameters 

deemed necessary and appropriate by the FAA. 

Thank you for your consideration. 

Sincerely,

Brian Gaudet, d.b.a. Strategic Designs

Owner/Pilot

39 Tiffany Cir.

Millbury, MA 01527

bgflyer@icloud.com

508-754-5664