Keystone UAS LLC keystoneuas@gmail.com

225 Church St 7H (267) 858-1157

Philadelphia PA, 19106

Page 1 of 17

November 27, 2015

UNITED STATES OF AMERICA

DEPARTMENT OF TRANSPORATION

FEDERAL AVIATION ADMINISTRATION

DOCKET MANAGEMENT STSTEM

1200 NEW JERSEY AVE., SE

WASHINGTON, D.C. 20590

IN THE MATTER OF THE PETITION FOR EXEMPTION OF:

KEYSTONE UAS LLC

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), 91.19 (c), 91.121, 91.151(a), 91.405(a), 91.407(a)(1),

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

CONCERNING COMMERCIAL OPERATIONS OF SMALL UNMANNED AIRCRAFT SYSTEMS

PURSUANT TO SECTION 333 OF

THE FAA MODERNIZATION AND REFORM ACT OF 2012

PUBLIC LAW 112-95

Keystone UAS LLC

Aaron Quesnoy, Owner

225 Church St 7H

Philadelphia, PA 19106

(267) 858-1157

keystoneuas@gmail.com

Title Page
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225 Church St 7H (267) 858-1157

Philadelphia PA, 19106

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TABLE OF CONTENTS

Title Page.......................................................................................................................................................1

TABLE OF CONTENTS.....................................................................................................................................2

Acronyms......................................................................................................................................................3

Introduction ..................................................................................................................................................4

UA/UAS Type Requested ..............................................................................................................................4

Performed Operations..................................................................................................................................5

Exemption from Regulations ........................................................................................................................7

Name and Address of Petitioner:..................................................................................................................8

Background and Experience .........................................................................................................................8

Commitment to Safety..................................................................................................................................8

Exemption Request.......................................................................................................................................9

Proposed Exemptions.................................................................................................................................10

Proposed Conditions and Limitations.....................................................................................................11

Specific Uses Public Benefits.......................................................................................................................15

Federal Register Publication .......................................................................................................................15

Privacy and National Security .....................................................................................................................16

Summary .....................................................................................................................................................16
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Acronyms

AFS-80 FAA UAS Integration Office

AGL Above Ground Level

AHRS Automatic Heading and Reference System

ATC Air Traffic Control

CFR Code Federal Regulation

C/W Complied With

CFR Code of Federal Regulations

DL Driver License

EME Emergency Medical Service

ESC Electronic Speed Controller

FAA Federal Aviation Administration

FCC Federal Communication Commission

FSDO Flight Standards District Office

GPS Global Positioning System

KUAS Keystone UAS LLC

LiPo Lithium-Polymer battery

MTOW Maximum Takeoff Weight

Nm Nautical Mile

NTSB National Transportation Safety Board

PIC Pilot in Command

R&D Research and Development

RTL Return to Launch

UA Unmanned Aircraft

UAS Unmanned Aircraft System

VDL Video Data Link

VFR Visual Flight Rules

VHF Very High Frequency

VLOS Visual Line of Sight

VO Visual Observer
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Introduction

To whom it may concern:

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the “Reform Act”) and 14 

C.F.R. Part 11, Keystone UAS LLC, Operator of Unmanned Aircraft Systems equipped to offer on-demand 

commercial UAS operations for a host of industries and applications and to perform the purposes listed 

below, hereby applies for an exemption from the listed Federal Aviation Regulations (“FARs”) to allow 

commercial operation of its UA/UAS, so long as such operations are conducted within and under the 

conditions outlined herein or as may be established by the FAA in an exemption granted under either 

Section 333 or Section 49 U.S.C. §44701(f).

As described more fully below, the requested exemption would permit the operation of an UAS under 

controlled conditions in airspace that is 1) limited; 2) predetermined; and 3) would provide safety 

enhancements in the fields in which it will operate, which now depend upon conventional aircraft or 

humans climbing high on dangerous structures, and working adjacent to treacherous infrastructure. 

Approval of this exemption would thereby enhance safety and fulfill the Secretary of Transportation’s 

(the FAA Administrator’s) responsibilities to “... establish requirements for the safe operation of such 

aircraft systems in the national airspace system.” Section 333(c) of the Reform Act.

UA/UAS Type Requested

The petitioner is seeking an exemption to commercially operate UA makes and models as follows:

The following are commercially available UA have been previously approved by the Secretary. The 

same UAS platforms are listed in Exemption 12646 granted to Measure on August 28, 2015 and 

Exemption 11318B granted to Micro Drone Vision, Inc on July 23, 2015.

3DR Aero-M, 3DR Iris+, 3DR X8, 3DR X8+, 3DR X8-M, 3DR Y6, 3DR Fixed Wing, 3DR Multirotor, 3DR 

Quadrotor, 3DR Solo, 3DR Spektre, AgEagle, AgScout, AR-960 Hex Copter, CinesStar, Cinestra 6, Cinestar 

X8, DJI Flame Wheel F450, DJI Flame Wheel F550, DJI Inspire1, DJI Inspire 2, DJI Inspire 3, DJI Phantom 1, 

DJI Phantom 2, DJI Phantom 3, DJI Phantom 4, DJI Spreading Wings S900, DJI Spreading Wings S1000+, 

Multirotor G4, Nighthawk, Pixhawk, Parrot Bebop, Tarot quadcopter, Tarot FY690S, Tarot 680pro, Tarot, 

690, Tarot 900, Tarot 960, Tarot T15, Tarot T18, Trimble UX5, Trimble UX5hp, Trimble ZX5, Walkera Tali 

H500, Walkera Scout X4, Yuneec Typhoon G, Yuneec Typhoon Q500+, Yuneec Typhoon Q500 4G.

The following commercially available UA are currently under review for approval by the Secretary. 

These UA have been a commercially available for less than 120 days, less than the time it takes for a 333 

Exemption, and are still under review. Current Docket submissions include, but not limited to, FAA2015-6694, FAA-2015-0315, FAA-2015-0170, and FAA-2015-5551

Walkera Voyager 3, Walkera QRX350 Primium, Walkera QRX350 Pro, Walkera QRX900, Walkera Runner 

250, Yuneec Tornado.
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KUAS also requests the operation of a KUAS-180. The KUAS-180 similar to the previously approved 3DR 

Y6 or DJI Spreading Wings. See similarity report of critical components. KUAS meets all UA safety 

requirements on the FAA. Each criteria is the same, or of less severity that then compared equipment. 

Components meet FCC requirements.

Item KUAS-180 3DR-Y6 DJIS800

Approval TBD 1274 11252

Frame 

Wheelbase 180MM 320MM 800mm

Motor 400KV 850KV 40000KV

# of Motor 6 6 6

ESC 10A 20A 40A

Propeller 3x30 Apr-40 15-5.2

MTOW 1.2KG 5.5KG 8KG

Max Speed 20 Knots 30 Knots 31 Knots

Radio FlySky (Any 6+ CH) ANY 6+ Ch Futabe (Any 6+ Chanel)

Auto-Pilot APM 2.6 APM2.6, Pixhawk DJI A2 

(opt: WooKong-M, APM 2.6, Pixhawk)

Radio Frequency 2.4Ghz 2.4GHz 2.4GHz

Each UA has a MTOW of 55 lbs. or less, and cannot exceed 87 knots.

Performed Operations

This exemption request, once granted would allow the petitioner to operate small unmanned aircraft for 

aerial data collection, research and development, and closed-set motion picture and television filming. 

Aerial data collection includes any remote sensing and measuring by an instrument(s) aboard the UA.

Examples of operations performed include, but not limited to, bridge Inspections, flare stack inspection, 

utility-power generation system inspections and patrolling, aerial inspection, photography and 

videography of residential and commercial real estate, weddings, aerial inspection, photography and 

videography of utility infrastructure including but not limited to electrical power lines, wind turbines and 

cell towers, pipeline inspection and patrolling, filmmaking, cinematography, and videography, precision 

agriculture with on board sensors, wildlife and forestry monitoring and mosquito and insect control, 

aerial surveying, construction site inspection and monitoring, public entity support operations, Aerial 

imaging for safety, monitoring and comparing work efforts and completion percentages, and security of 

controlled environment of various sites, aerial video and live video feed to assist with search and rescue 

operations under the authority and support of local authority officials, aerial video and photography for 

public and private use including television, public events, and cinematography live feed and live 

newsgathering, training to persons individually or belonging to both private and public organizations to 

increase awareness and improve safety for current and future UAS operations within the NAS, special 

events: including high schools, colleges, professional sports, open air events and fairs, research, risk 
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management and assessment, motion picture production, surface mining, closed set filming, disaster 

and catastrophe events.

The requested operations have been previously approved by the FAA as follows:

• Aerial Data Collection:

1109A, 12299, 11682, 11432

• Bridge Inspections: 

11603, 11564, 11422, 11171

• Flare stack inspection: 

11251, 11581, 11241, 11156

• Utility-power generation system inspections and patrolling: 

11581, 11512, 11238, 11467

• Aerial inspection, photography and videography of residential and commercial real estate, 

weddings and wedding receptions:

11784, 11786, 11787, 11789

• Aerial inspection, photography and videography of utility infrastructure including but not limited 

to electrical power lines, wind turbines and cell towers: 

11787, 11512, 11581, 11238

• Pipeline inspection and patrolling: 

11467, 11422, 11554, 11561, 11564

• Filmmaking, cinematography, and videography: 

11581, 11251, 11256, 11659

• Precision agriculture with on board sensors: 

11759, 11222, 11673, 11769

• Wildlife and forestry monitoring and mosquito and insect control: 

11684, 11648, 11790, 11551

• Aerial surveying: 

11593, 11600, 11567, 11581

• Construction site inspection and monitoring: 

11591, 11508, 11535, 11469

• Public entity support operations: 

11471, 11426, 11412, 11389

• Aerial imaging for safety, monitoring and comparing work efforts and completion percentages,

and security of controlled environment of various sites: 

11649, 11524, 11522, 11481

• Aerial video and live video feed to assist with search and rescue operations under the authority 

and support of local authority: 

11327, 11282, 11558, 11842

• Aerial video and photography for public and private use including television, public events, and 

cinematography live feed and live newsgathering: 

11408, 11406, 11787, 11760

• Training to persons individually or belonging to both private and public organizations to increase 

awareness and improve safety for current and future UAS operations within the NAS: 

11789, 11663, 11668, 11683

• Special Events (including High Schools, Colleges, Professional Sports, open air and fairs): 

11787, 11792, 11777, 11757
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• Research: 

11424, 11389, 11370, 11368

• Risk Management and Assessment: 

11293, 11494, 11481, 11293

• Motion Picture Production: 

11312, 11289, 11284, 11308, 12299, 11432

• Surface Mining: 

11272, 11257, 11227, 11508

• Closed Set Filming: 

11541, 11488, 11477, 11065

• Disaster and Catastrophe events: 

11309, 11487, 11370, 11327

Exemption from Regulations

Keystone UAS LLC requests exceptions from the following regulations. Also included is a list or prior 

approved exemptions grated by the FAA.

14 C.F.R. § 61.113 (a) & (b) :

11062, 11109, 11112, and 11213;

Exemption would allow any FAA licensed pilot to pilot a UAS for compensation or hire.

14 C.F.R. § 61.133(a) :

11062, 11109, 11112, and 11213;

Exemption would allow any FAA licensed pilot to pilot a UAS for compensation or hire.

14 C.F.R. § 91.7(a) :

11062, 11109, 11112, and 11213;

Exemption allows the operator to determine airworthiness and inspection requirements when none 

exist from the OEM.

14 C.F. R.§ 91.119 :

11062, 11109, 11112, and 11213;

Exemption allows the UA to fly below 500 feet AGL.

14 C.F.R. § 91.121: 

11062, 11109, 11112, and 11213;

Exemption allows the UA to operate without an altimeter.

14 C.F.R. § 91.151 (a) :

11062, 11109, 11112, and 11213;

Exemption allows the UA to fly without fuel, relying on battery power.

14 C.F.R. § 91.405 (a) : 14 C.F.R. § 407 (a) (1) : 14 C.F.R. § 409 (a) (2) : 14 C.F.R. § 417 (a) & (b) :
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11062, 11109, 11112, and 11213;

Exemption allows the operator to perform maintenance, where no approvals exist.

Name and Address of Petitioner:

Keystone UAS LLS

Attn: Aaron Quesnoy

225 Church St 7H

Philadelphia, PA 19106

Keystoneuas@gmail.com

(267) 858-1157

Background and Experience

Keystone UAS LLC is owned and operated by Aaron Quesnoy. Aaron Quesnoy is a highly experienced 

professional in aerospace, with over 20 years in the industry. Aaron Quesnoy began flying hobby aircraft 

in the late 1980’s. Aaron Quesnoy is a licensed private pilot with several hundred hours as PIC with 

multiple endorsements. Aaron Quesnoy was a member of the US Air Force for over 7 years, serving 3 

tours, working on F-16 Fighters and Predator Drones. Aaron Quesnoy has also been working with a 

helicopter OEM as a System Engineer for over 8 years, with experience in P21 aircraft builds and 

certification, P135 aircraft maintenance, and certifying major upgrades via 337 and STC, including 

creation and certification of STCs.

Commitment to Safety

As part of its commitment to safety and innovation, Keystone UAS LLC is asking for this exemption in 

part, to reduce the risk of injury to its employees and contractors who participate in the proposed 

activities the petitioner requests, including but not limited, to damage to agriculture, natural habitat, 

buildings and other structures within the United States.

Advanced UA have an auto-pilot that allows it to execute pre-programmed maneuvers. Preprogrammed maneuvers include: initiation of holding at present position; suspension of mission; fly 

back to launch point; and abort mission and land immediately. These automated maneuvers enhance

safety of the UAV. Fail-safe operations include:

1) Loss of GPS solution initiates a hover, if signal is not reestablished, auto-land is initiated.

2) Low power on the aircraft triggers alarms, the UA will return to home and land.

3) If the signal from the ground station is lost, the UAS will hold position at its current location for 5 

seconds and if the signal is not restored, execute a return to home and land, 

Additional safety margins for normal operation include:

1) The MTOW is less than 55 lbs. 
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2) VLOS with the pilot is maintained.

3) The max ground speed is 87 knots.

4) No operation within 500 feet of people.

5) Altitude restricted to 400 feet AGL.

Exemption Request

Keystone UAS LLC will operate unmanned aircraft for aerial data collection, R&D, and closed-set motion 

picture and television filming. Aerial data collection includes any remote sensing and measuring by an 

instrument(s) aboard the UA. Given the small size of the sUAV’s involved, no more than 55 lbs., speed 

of operation be less than 87 knots and the restricted environment within which they will operate, the 

Petitioner falls squarely within that zone of safety (an equivalent level of safety) in which Congress 

envisioned that the FAA must, by exemption, allow commercial operations of UASs to commence 

immediately.

This exemption application is submitted to fulfill Congress’ express goal in passing Sections 333(a) 

through (c) of the Reform Act. This law directs the Secretary of Transportation to consider whether 

certain unmanned aircraft systems may operate safely in the national airspace system (NAS) before 

completion of the rulemaking required under Section 332 of the Reform Act. In making this 

determination, the Secretary is required to determine which types of UASs do not create a hazard to 

users of the NAS or the public or pose a threat to national security in light of the following:

• The UAS’ size, weight, speed, and operational capability;

• Operation of the UAS in close proximity to airports and populated areas; and

• Operation of the UAS within visual line of sight of the Operator.

Reform Act § 333 (a). Lastly, if the Secretary determines that such vehicles “may operate safely in the 

national airspace system, the Secretary shall establish requirements for the safe operation of such 

aircraft in the national airspace system.” Id. §333(c) (emphasis added).

The Federal Aviation Act expressly grants the FAA the authority to issue exemptions. This statutory 

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

The Administrator may grant an exemption from a requirement of a regulation prescribed under 

subsection (a) or (b) of this section or any of sections 44702-44716 of this title if the Administrator finds 

the exemption is in the public interest. 49 CFR §44701(f). See also 49 CFR §44711(a); 49 CFR §44704; 14 

CFR §91.203(a)(1) This authority to grant exemptions reaches such issues as authorization of commercial 

operation of aircraft without an FAA issued pilot’s license.

Keystone UAS LLC in filing this application is requesting that the FAA combine the grant of the Section 

333 exemption with a Certificate of Operation (COA) that will allow commercial operations of its UA

without the necessity of filing for a COA for each flight, unless such flight is to be conducted in an area 

not approved in the exemption. Compliance with the conditions agreed to herein and that may be 

imposed by the FAA, as set forth in prior Section 333 exemptions, provide the separation needed from 

other aircraft.
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Keystone UAS LLC requests that operations over congested or densely populated areas be allowed. Also 

requested is operation within 5nm of an airport when operating within 250 feet of a structure and 

approval of the local ATC and FSDO, and above 400 feet AGL when within 2500 feet of a structure with 

local ATC and/or FSDO approval. The new sUAV’s do have GPS geo-fencing, it will operate at a very low 

altitude, within confined areas, at low speed and weighs no more than 55 lbs. Such operations will only 

be under-taken with the approval of the land or home owner, as set forth herein, and will comply with 

the requirements that operations be no closer than 500 feet to the adjacent building unless the land 

owner has provided permission, and the Operator has made a safety assessment of the risk from such 

operations.

A handheld radio controller controls the sUAV and the vehicle is operated within the line of sight. The 

requirements of Part 61.127 (commercial flight proficiency) and §61.107 (private flight proficiency), to 

the extent they are relevant to UAS operations, can be taught in the training proposed herein. As a 

review of the requirements of part 61.127 and 107 demonstrate, the issues presented as they relate to a 

55 pound aircraft, operating at less than 30 mph during filming operations are those taught in ground 

school and in flight training with the particular UAS and not gained from accumulating flight hours in a 

fixed wing or rotorcraft gas or jet A powered aircraft completing cross country flights and take offs and 

landings at controlled and uncontrolled airports.

Keystone UAS LLC additionally asks that the exemption be issued without the requirement for a visual 

observer. As set forth herein, an equivalent level of safety is provided by the size, speed and control 

capabilities of the aircraft, as well as the operational procedures that will be applicable to all flight 

hereunder. These obviate the need for the visual observer. 

The PIC will be operating the aircraft, always within line of sight. He or she will follow the aircraft around 

the inspection area so that while it is flying at times. 

Keystone UAS LLC again notes that the NPRM does not require the use of a visual observer. Given the 

clear direction in Section 333 of the Reform Act; the authority contained in the Federal Aviation Act, as 

amended; the strong equivalent level of safety surrounding the proposed operations, and the significant 

public benefit, including enhanced safety, reduction in environmental impacts, including reduced 

emissions associated with allowing battery powered sUAV’s for these functions instead of turbine or gas 

power aircraft/rotorcraft and operations with pilots having at least a private pilot license, the grant of 

the requested exemptions is in the public interest.

Proposed Exemptions

The Petitioner proposes that the exemption requested herein apply to civil aircraft that have the 

characteristics and that operate with the limitations listed herein. These limitations provide for at least 

an equivalent or even higher level of safety to operations under the current regulatory structure 

because the proposed operations represent a safety enhancement to the operations conducted with 

conventional aircraft or with humans climbing up and around structures. These conditions are drawn 

from Dockets FAA-2015-0170, FAA-2015-0315, FAA-2015-5551, FAA-2015-6694 and Exemptions 11136, 

11138, 11172, 11174 and 11177, 11062, 11109, 11112, 11213, 11318, and 11857.
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These limitations and conditions to which Keystone UAS LLC (referred to as “Operator”) agrees to be 

bound when conducting commercial operations under an FAA issued exemption include: 

Proposed Conditions and Limitations

1. Operations authorized by this grant of exemption are limited to the 3DR Aero-M, 3DR Iris+, 3DR 

X8, 3DR X8+, 3DR X8-M, 3DR Y6, 3DR Fixed Wing, 3DR Multirotor, 3DR Quadrotor, 3DR Solo, 3DR 

Spektre, AgEagle, AgScout, AR-960 Hex Copter, CinesStar, Cinestra 6, Cinestar X8, DJI Flame 

Wheel F450, DJI Flame Wheel F550, DJI Inspire1, DJI Inspire 2, DJI Inspire 3, DJI Phantom 1, DJI 

Phantom 2, DJI Phantom 3, DJI Phantom 4, DJI Spreading Wings S900, DJI Spreading Wings 

S1000+, KUAS-180, Multirotor G4, Nighthawk, Pixhawk, Parrot Bebop, Tarot quadcopter, Tarot 

FY690S, Tarot 680pro, Tarot, 690, Tarot 900, Tarot 960, Tarot T15, Tarot T18, Trimble UX5, 

Trimble UX5hp, Trimble ZX5, Walkera Tali H500, Walkera Scout X4, Yuneec Typhoon G, Yuneec 

Typhoon Q500+, Yuneec Typhoon Q500 4G, Walkera Voyager 3, Walkera QRX350 Primium, 

Walkera QRX350 Pro, Walkera QRX900, Walkera Runner 250, and Yuneec Tornado, when 

weighing less than 55 pounds including payload. Proposed operations of any other aircraft will 

require a new petition or a petition to amend this exemption.

2. Operations for the purpose of closed-set motion picture and television filming are permitted. 

3. The UA may not be operated at a speed exceeding 87 knots (100 miles per hour). The exemption 

holder may use either groundspeed or calibrated airspeed to determine compliance with the 87 

knot speed restriction. In no case will the UA be operated at airspeeds greater than the 

maximum UA operating airspeed recommended by the aircraft manufacturer. 

4. The UA must be operated at an altitude of no more than 400 feet above ground level (AGL).

Altitude must be reported in feet AGL. Flights above 400’ AGL require ATC and/or FSDO 

approval, must remain within 250 feet of any structure, and have an operational aviation VHF 

radio.

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, as 

specified on the PIC’s FAA-issued airman medical certificate or U.S. driver’s license. 

6. This exemption and all documents needed to operate the UAS and conduct its operations in 

accordance with the conditions and limitations stated in this grant of exemption, are hereinafter 

referred to as the operating documents. The operating documents must be accessible during 

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

between the conditions and the limitations in this exemption and the procedures outlined in the 

operating documents, the conditions and limitations herein 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 or any law enforcement official upon request. The operator must also present 

updated and revised documents if it petitions for extension or amendment to this grant of 

exemption. If the operator determines that any update or revision would affect the basis upon 
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which the FAA granted this exemption, then the operator must petition for an amendment to its 

grant of exemption. The FAA’s UAS Integration Office (AFS−80) may be contacted if questions 

arise regarding updates or revisions to the operating documents. 

7. 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 prior to conducting further operations under this exemption. Functional test flights may 

only be conducted by a PIC and must remain at least 500 feet from other people. The functional 

test flight must be conducted in such a manner so as to not pose an undue hazard to persons 

and property. 

8. The operator is responsible for maintaining and inspecting the UAS to ensure that it is in a 

condition for safe operation. 

9. Prior to each flight, the PIC must conduct a pre-flight inspection and determine the UAS is in a 

condition for safe flight. The pre-flight inspection must account for all potential discrepancies, 

e.g., inoperable components, items, or equipment. If the inspection reveals a condition that 

affects the safe operation of the UAS, the aircraft is prohibited from operating until the 

necessary maintenance has been performed and the UAS is found to be in a condition for safe 

flight. 

10. The operator must follow the UAS manufacturer’s maintenance, overhaul, replacement, 

inspection, and life limit requirements for the aircraft and aircraft components. 

11. Each UAS operated under this exemption must comply with all manufacturer safety bulletins. 

12. Under this grant of exemption, a PIC must hold either an airline transport, commercial, private, 

recreational, or sport pilot certificate. The PIC must also hold a current FAA airman medical 

certificate or a valid U.S. driver’s license issued by a state, the District of Columbia, Puerto Rico, 

a territory, a possession, or the Federal government. The PIC must also meet the flight review 

requirements specified in 14 CFR § 61.56(a)(1).

13. The operator may not permit any PIC to operate unless the PIC demonstrates the ability to 

safely operate the UAS in a manner consistent with how the UAS will be operated under this 

exemption, including evasive and emergency maneuvers and maintaining appropriate distances 

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

be logged in a manner consistent with 14 CFR § 61.51(b). Flights for the purposes of training the 

operator’s PICs (training, proficiency, and experience-building) and determining the PIC’s ability 

to safely operate the UAS in a manner consistent with how the UAS will be operated under this 

exemption are permitted under the terms of this 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 CFR § 91.119. 
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14. All operations must be conducted under visual meteorological conditions (VMC) 14 CFR § 

61.56(b)(1). Flights under special visual flight rules (SVFR) are not authorized. 

15. The UA may not operate within 5 nautical miles of an airport reference point (ARP) as denoted 

in the current FAA Airport/Facility Directory (AFD) or for airports not denoted with an ARP, the 

center of the airport symbol as denoted on the current FAA-published aeronautical chart, unless 

a letter of agreement with that airport’s management is obtained or otherwise permitted by a 

COA issued to the exemption holder. The letter of agreement with the airport management 

must be made available to the Administrator or any law enforcement official upon request. 

16. 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 1 statute miles from the PIC. 

17. For tethered operations, the tether line must have colored pennants of streamers attached at 

not more than 50 intervals beginning at 150 feet above the surface of the earth and visible from 

at least one mile. This requirement for pennants or streams is not applicable when operating 

exclusively below the top of and within 250 feet of any structure.

18. If the UAS loses communications or loses its GPS signal, the UA must return to a pre-determined 

location within the private or controlled-access property. 

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

20. The PIC is prohibited from beginning a flight unless (considering wind and forecast weather 

conditions) there is enough available power for the UA to conduct the intended operation and 

to operate after that for at least five minutes or with the reserve power recommended by the 

manufacturer if greater. 

21. Air Traffic Organization (ATO) Certificate of Waiver or Authorization (COA). All operations shall 

be conducted in accordance with an ATO-issued COA. The exemption holder may apply for a 

new or amended COA if it intends to conduct operations that cannot be conducted under the 

terms of the attached COA. 

22. 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 (N−Number) markings in 

accordance with 14 CFR part 45, Subpart C. Markings must be as large as practicable. 

23. Documents used by the operator to ensure the safe operation and flight of the UAS and any 

documents required under 14 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 give way to all manned aviation operations and activities at all 

times. 
Keystone UAS LLC keystoneuas@gmail.com

225 Church St 7H (267) 858-1157

Philadelphia PA, 19106

Page 14 of 17

25. The UAS may not be operated by the PIC from any moving device or vehicle without approved 

procedures. 

26. All Flight operations must be conducted at least 500 feet from all nonparticipating 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 in a manner ensuring the safety of nonparticipating persons; 

and

b. The owner/controller of any vessels, vehicles or structures has granted permission for 

operating closer to those objects 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. 

The PIC, operator trainees or essential persons are not considered nonparticipating persons under 

this exemption. 

27. All operations shall be conducted over private or controlled-access property with permission 

from the property owner/controller or authorized representative. Permission from property 

owner/controller or authorized representative will be obtained for each flight to be conducted. 

28. 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. 

If this exemption permits operations for the purpose of closed-set motion picture and television filming 

and production, the following additional conditions and limitations apply. 

29. The operator must have a motion picture and television operations manual (MPTOM) as 

documented in this grant of exemption. 

30. At least 3 days before aerial filming, the operator of the UAS affected by this exemption must 

submit a written Plan of Activities to the local Flight Standards District Office (FSDO) with 

jurisdiction over the area of proposed filming. The 3-day notification may be waived with the 

concurrence of the FSDO. The plan of activities must include at least the following: 

a. Dates and times for all flights; 

b. Name and phone number of the operator for the UAS aerial filming conducted under 

this grant of exemption; 

c. Name and phone number of the person responsible for the on-scene operation of the 

UAS; 

d. Make, model, and serial or N−Number of UAS to be used; 

e. Name and certificate number of UAS PICs involved in the aerial filming; 
Keystone UAS LLC keystoneuas@gmail.com

225 Church St 7H (267) 858-1157

Philadelphia PA, 19106

Page 15 of 17

f. A statement that the operator has obtained permission from property owners and/or 

local officials to conduct the filming production event; the list of those who gave permission 

must be made available to the inspector upon request; 

g. Signature of exemption holder or representative; and 

h. A description of the flight activity, including maps or diagrams of any area, city, town, 

county, and/or state over which filming will be conducted and the altitudes essential to 

accomplish the operation. 

31. Flight operations may be conducted closer than 500 feet from participating persons consenting 

to be involved and necessary for the filming production, as specified in the exemption holder’s 

MPTOM. 

Unless otherwise specified in this grant of exemption, the UAS, the UAS PIC, and the UAS operations 

must comply with all applicable parts of 14 CFR including, but not limited to, parts 45, 47, 61, and 91.

Specific Uses Public Benefits

Keystone UAS LLC proposes use of its sUAV provided equivalent or augmented levels of safety for each 

of the uses proposed herein: 

The present systems of photography and videography and mapping of inspecting the roofs, agriculture 

land, buildings and large structures site surveys, wild life monitoring, mosquito and insect control are 

now conducted by either humans wading through swamps, climbing on the roofs and structures that are 

steep, tall, slippery, weakened or otherwise hazardous or by the use of conventional aircraft. 

The current procedures can result in significant injuries to the people who must climb on the roofs or 

require the use of aircraft that are orders of magnitude greater in size than the sUAV. Either method, 

manual inspection or large conventional aircraft, results in increased risk of injury due to personnel 

falling off roofs or ladders, carrying heavy ladders and dealing with confined and dangerous spaces, or 

increased risk from low altitude flyovers with helicopters or fixed wing aircraft inspecting buildings after 

damage from storms or other disasters, such as earthquakes or fires. Such flights are, of course, 

significantly more expensive than those undertaken with a sUAV. 

The present system exposes those not only in the immediate area of inspection, but those who are 

along the path of flight associated with the arrival and departure of the conventional aircraft at the 

inspection site because the aircraft must be flown to and from the site. By contrast, the sUAV is carried 

to the site and transits no other property. Conventional aircraft carry flammable fuels that are not 

carried by the UAS and emit pollutants associated with internal combustion engines. The sUAV’s 

proposed herein are battery powered and have no emissions.

Federal Register Publication

Pursuant to 14 C.F.R. Part 11, the following summary is provided for publication in the Federal Register, 

should it be determined that publication is needed:
Keystone UAS LLC keystoneuas@gmail.com

225 Church St 7H (267) 858-1157

Philadelphia PA, 19106

Page 16 of 17

Petitioner seeks an exemption from the following rules:

14 C.F.R. §§ 61.113(a) & (b); 91.7(a); 91.119; 91.121; 91.151(a); 91.405(a);

91.407(a)(1); 91.409(a)(2) and 91.417 (a) & (b) to operate commercially a small unmanned vehicle (55 

lbs. or less) for the following purposes: to conduct bridge inspections, flare stack inspection, utilitypower generation system inspections and patrolling, aerial inspection and photography of residential 

and commercial utility infrastructure including but not limited to electrical power lines, wind turbines 

and cell towers, pipeline inspection and patrolling, filmmaking, cinematography, and videography, 

precision agriculture with on board sensors, wildlife and forestry monitoring and mosquito and insect 

control, aerial surveying, construction site inspection and monitoring, public entity support operations, 

aerial video and live video feed to assist with search and rescue operations under the authority and 

support of local authority officials, aerial video and photography for public and private use including 

television, public events, and cinematography live feed and live newsgathering, training to persons 

individually or belonging to both private and public organizations to increase awareness and improve 

safety for current and future UAS operations within the NAS, special events: including high schools, 

colleges, professional sports, open air events and fairs, research, risk management and assessment, 

motion picture production, surface mining, closed set filming, disaster and catastrophe events

Privacy and National Security

All flights will occur over private or controlled access property with the property owner’s prior consent 

and knowledge. Inspection will be of inanimate objects in areas where the owners will have consented 

to the inspections or otherwise have agreed to allow the UAS and the Operator to be in the area where 

operations will take place. 

The size of the UAS, its speed and restricted area of operation do not raise national security issues.

Summary

Approval of exemptions allowing commercial operations of sUAV’s for petitioner to operate an 

unmanned aircraft system (UAS) to conduct aerial data collection, television and motion picture 

operation, R&D and training. Examples include, but not limited to: bridge Inspections, flare stack 

inspection, utility-power generation system inspections and patrolling, aerial inspection and 

photography of residential and commercial utility infrastructure including but not limited to electrical 

power lines, wind turbines and cell towers, pipeline inspection and patrolling, filmmaking, 

cinematography, and videography, precision agriculture with on board sensors, wildlife and forestry 

monitoring and mosquito and insect control, aerial surveying, construction site inspection and 

monitoring, public entity support operations, aerial video and live video feed to assist with search and 

rescue operations under the authority and support of local authority officials, aerial video and 

photography for public and private use including television, public events, and cinematography live feed 

and live newsgathering, training to persons individually or belonging to both private and public 

organizations to increase awareness and improve safety for current and future UAS operations within 

the NAS, special events: including high schools. colleges, professional sports, open air events and fairs, 
Keystone UAS LLC keystoneuas@gmail.com

225 Church St 7H (267) 858-1157

Philadelphia PA, 19106

Page 17 of 17

research, risk management and assessment, motion picture production, surface mining, closed set 

filming, disaster and catastrophe events, will enhance safety by reducing risk. 

Conventional operations, using jet or piston powered aircraft, ladders or placing people in swamps, on 

roofs or tall, hazardous or weakened structures, exposes them to higher risks than those created by use 

of a sUAV’S. Conventional aircraft that operate at extremely low altitudes just feet from the subject 

being inspected and in extreme proximity to people and structures present the risks associated with 

vehicles that weigh in excess of 6,000 lbs., carrying large amounts of jet A or other fuel (140 gallons for 

jet helicopters). Such aircraft must fly to and from the project location. In contrast, a sUAV weighing 

fewer than 55 lbs. and powered by batteries eliminates virtually all of that risk given the reduced mass 

and lack of combustible fuel carried on board. The sUAV is carried to the target area and not flown. The 

sUAV will carry no passengers or crew and, therefore, will not expose them to the risks associated with 

manned aircraft flights.

The operation of small UASs, weighing less than 55 lbs., conducted under the strict conditions outlined 

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

herein. These lightweight aircraft operate at slow speeds, close to the ground, and in areas that are 

under the control of the customer for the operations and, as a result, are far safer than conventional 

operations conducted with turbine helicopters operating in close proximity to the ground and people or 

the use of individuals to climb the structures to conduct the operations.

Satisfaction of the criteria provided in Section 333 of the Reform Act of 2012 –size, weight, speed, 

operating capabilities, proximity to airports and populated areas and operation within visual line of sight 

and national security – provide more than adequate justification for the grant of the requested 

exemptions allowing commercial operation of Petitioner’s UAS for the Purposes outlined herein and are 

consistent with exemptions already granted, including Exemptions number 11171 through 11174, 

11139, 11138, 11177, 11062, 11109, 11112, 11213, 11318, 11857,12646, 11318B and pending dockets

FAA-2015-6694, FAA-2015-0315, FAA-2015-0171 and FAA-2015-5551.

Sincerely,

Aaron Quesnoy

Keystone UAS LLC

225 Church St 7H

Philadelphia, PA 19106