DUAV

1704 Edgewood Drive

Milford IA. 51351

712.330.6417

Petitti@duav.org

DUAV

Okoboji Iowa

712.330.6417

Petitti@duav.org

March 23rd, 2015

 

Request for exemption under FAA Modernization & Reform Act of 

2012, Section 333, to operate an Unmanned Aerial System for Aerial 

Photography and Aerial Inspections.

Petitioner’s information 

Thomas Petitti

1704 Edgewood Drive

Milford, IA 51351

712.330.6417

Petitti@duav.org

DUAV LLC,

U.S. Department of Transportation 

Docket Management System 1200 

New Jersey Ave, SE Washington, 

DC 20590 

Petition for Exemption of CFR 14:

45.23(a)&(b);61.113(a),(b),&(2);

91.7(a)&(b); 91.119(a),(b),&(c); 

91.151(a),(1),&(b); 91.405(a); 

91.407(a)&(1); 91.409(a),(1),&(2); 

91.417(a)&(b)
DUAV

Okoboji, Iowa

712.330.6417

Petitti@duav.org

Dear Sir or Madam,

Request for relief from an airworthiness certification requirements under the FAA 

Modernization and Reform Act of 2012, Public Law 112-95 FEB. 14, 2012, Section 333.

Section 14 CFR §45.23 Display of marks; general.

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

capital letter “N” (denoting United States registration) followed by the registration number of the 

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

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

displayed on limited, restricted or light-sport category aircraft or experimental or provisionally

certificated aircraft, the operator must also display on that aircraft near each entrance to the 

cabin, cockpit, or pilot station, in letters not less than 2 inches nor more than 6 inches high, the 

words “limited,” “restricted,” “light-sport,” “experimental,” or “provisional,” as applicable.

The UAS aircraft, will be permanently marked in multiple places with contact information 

containing P.I.C & owner’s Name, Address, & Phone Number. In compliances with 14 CFR 

Section 45.29 (f), the UAS will also be marked with “Experimental” in as large as practical size 

of print on at least two surfaces. 

Section 14 CFR §61.113 Private pilot privileges and 

limitations: Pilot in command.

(a) Except as provided in paragraphs (b) through (h) of this section, no person who holds a 

private pilot certificate may act as pilot in command of an aircraft that is carrying passengers or 

property for compensation or hire; nor may that person, for compensation or hire, act as pilot in 

command of an aircraft. 

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

connection with any business or employment if: 

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

Although no souls will be aboard, the UAS operations will be planned with the same level of 

safety as a commercial operation, under the command of a private pilot, holding an up to date 

medical certificate and photo I.D. All operations will follow a Standard weather Briefing, a 

preflight check, and a run up. All flights will follow a predetermined route, and maneuvers within 

clear airspace. The level of risk associated with the operation of the UAS are so diminished form 
DUAV

Okoboji, Iowa

712.330.6417

Petitti@duav.org

the level of risk associated with commercial operations contemplated by part 61 when drafted, 

that allowing operations of the UAS as requested with a private pilot as the operator exceeds 

the present level of safety achieved by 14 CFR Section 61.113 (a) &(b).

Section 14 CFR §91.7 Civil aircraft airworthiness.

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

(b) The pilot in command of a civil aircraft is responsible for determining whether that aircraft is 

in condition for safe flight. The pilot in command shall discontinue the flight when unairworthy 

mechanical, electrical, or structural conditions occur. 

As there is no Airworthiness certificate issued for this aircraft, should this exemption be granted, 

no FAA regulatory standard will exist for determining the airworthiness. Given the size of the 

aircraft and the requirements contained in the manual of maintenance, and use of safety

checklists prior to each flight as set forth in Section B, and Section G, an equivalent level of 

safety will be provided. 

Section 14 CFR §91.119 Minimum safe altitudes: General.

Except when necessary for takeoff or landing, no person may operate an aircraft below the 

following altitudes: 

(a) Anywhere. An altitude allowing, if a power unit fails, an emergency landing without undue 

hazard to persons or property on the surface. 

(b) Over congested areas. Over any congested area of a city, town, or settlement, or over any 

open air assembly of persons, an altitude of 1,000 feet above the highest obstacle within a 

horizontal radius of 2,000 feet of the aircraft. 

(c) Over other than congested areas. An altitude of 500 feet above the surface, except over open 

water or sparsely populated areas. In those cases, the aircraft may not be operated closer than 500 

feet to any person, vessel, vehicle, or structure

The equivalent level of safety will be achieved given the size, weight, and speed of the UAS as 

well as the location of operated. No flight will be taken without the permission of the property 

owner or local officials. Because of the advance notice to the property owner and participants in 

the filming activity, attempts will be made to contact all affected individuals regarding the 

planned flight operations. Compared to flight operations with aircraft or rotorcraft weighting far 

more than the maximum 551bs. UAV limit Proposed herein, and the lack of flammable fuel, any 
DUAV

Okoboji, Iowa

712.330.6417

Petitti@duav.org

risk associated with these operations is far less than those presently presented with conventional 

aircraft. In addition, the low-altitude operations of the UAV will ensure separation between these 

UAS operations and the operations of conventional aircraft that must comply with Section 

91.119.

Section 14 CFR §91.121 Altimeter settings.

(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 feet 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; or 

(2) At or above 18,000 feet MSL, to 29.92′′ Hg. 

(c) To convert minimum altitude prescribed under §§91.119 and 91.177 to the minimum flight 

level, the pilot shall take the flight level equivalent of the minimum altitude in feet and add the 

appropriate number of feet specified below, according to the current reported altimeter setting:

The UAS does not operate by use of Barometric Altimeter but instead a digital GPS altitude read 

out for AGL. An equivalent level of safety will be achieved by the operator, pursuant to the 

Manual and Safety Check list, confirming the altitude of the launch site shown on the GPS 

altitude indicator before flight.

Section 14 CFR §91.151 Fuel requirements for flight in 

VFR conditions.

(a) No person may begin a flight in an airplane under VFR conditions unless (considering wind 

and forecast weather conditions) there is enough fuel to fly to the first point of intended landing 

and, assuming normal cruising speed—
DUAV

Okoboji, Iowa

712.330.6417

Petitti@duav.org

(1) During the day, to fly after that for at least 30 minutes; or 

(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. 

The battery(s) powering the UAS varying time from 8 minutes to 12 minutes per battery. In 15 

degree Celsius, low wind, VFR conditions flight will last approximately 12 minutes with all 

powered components functioning. Given the limitations on the UAS proposed flight area and the 

location of its proposed operations within a predetermined area, a longer time frame for flight in 

daylight VFR conditions is reasonable.

An equivalent level of safety can be achieved by limiting flights to have enough battery reserve 

to ensure the UAS lands at a safe ground station with at least 20% of battery power determining 

by onboard monitoring and by the pilot. A notice in a decline of power performance or the 20% 

reserve mark has been met enough time will be adequate to return the UAS to a safe landing 

station within the predetermining route. 

Section 14 CFR §91.405 Maintenance required.

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;

Although this sections apply only to aircraft with an airworthiness certificate; route and preflight inspections and maintenance will be accomplished by the P.I.C and owner. An equivalent 

level of safety will be meet due to the lack of size and payload of the UAS, as well as operating 

in restricted areas for short limited periods of time in only VFR conditions will ensure extreme 

precaution and safety. 

Section 14 CFR §91.407 Operation after maintenance, 

preventive maintenance, rebuilding, or alteration.

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

rebuilding, or alteration unless—
DUAV

Okoboji, Iowa

712.330.6417

Petitti@duav.org

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

All preventive maintenance will be performed by a licensed private pilot and owner operator. 

Although there are no engines, electric motor and amplifier component, replacement will be 

done with equivalent safety as an aircraft power plant. Camera equipment alterations will also be 

done with equal caution concerning balance, power, and weight. Any major airframe work, or 

electrical (circuit board, reprograming, or calibrating) will be done by professional UAS 

builders.

Section 14 CFR §91.409 Inspections.

(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.

All Inspections will be performed in the pre-flight check and run up check near initial take off 

for each battery. No commercial UAS operation will occur after any form of maintenance unless 

a test flight in a sparsely populated areas away from any person or property has been conducted 

involving every maneuver and all electrical components. 

Section 14 CFR §91.417 Maintenance records.

(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—
DUAV

Okoboji, Iowa

712.330.6417

Petitti@duav.org

(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: 

(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. 

Equal level of safety and records in accordance with CFR 14 Section 91.405. All records will be 

included in a maintenance record folder as well as a designated log book. Including date of 

maintenance started and finished, name of qualified person or company who performs the 

maintenance, and type of maintenance performed on UAS.
DUAV

Okoboji, Iowa

712.330.6417

Petitti@duav.org

Public Summary

Pursuit to 14 CFR Part 11 the following summary is provided for the publication in the Federal 

Register, should it be determined that publication is needed. 

Applicant request an exemption from the following rules Code of Federal Regulations, Title 14, 

Chapter 1; Volumes 1 & 2:

45.23(a) & (b); 61.113(a), (b), & (2); 91.7(a) & (b); 

91.119(a), (b) & (c); 91.151(a), (1), & (b); 91.405(a);

91.407(a), & (1); 91.409(a), (1), & (2); 91.417(a) & (b)

Approval for exemptions allowing commercial operations of a UAS for aerial photography and 

videography intended for inspection and video reproductions in the following industries: Real 

Estate, Advertising, Environmental Research along with Water Quality and Shoreline Research, 

and Inspection of Wind Turbines, Bridges, or other large industrial buildings. Over open and 

moving waters, dangerous or hazardous places, and unreachable places by any other category of 

aircraft.

Intended to Reduce heavy lead based pollutants in the air and reduce risk of injury to pilots and 

passenger photographers. The limited size, weight, and distance of the UAS will also protect

people and property on the ground. Compared to tradition forms of aerial photography involving 

large engine powered aircraft at low altitudes, over populated condensed areas, making abrupt 

sharp maneuvers we’ve removed almost all negative aspects with this new and growing 

technology that we hope to promote and share with the public to build a positive image and make 

the airspace safer. 

In my small and growing community in the northwest Iowa’s great lakes; we bring in millions of 

tourist each year. In efforts to promote my community with new safer technology then 

traditionally done in the area. The UAS will be used to help nonprofit organization in the local 

area such as: Historic Arnolds Park Inc., Keep Okoboji Blue, and Iowa great lakes water safety 

council. All these organizations will benefit from the future use of a UAS. Allowing closer 

steadier footage, but also reducing noise greatly over natural wildlife refuges, parks, and forests 

that surround our lakes area. Reducing bird strike issues, and insuring other large wild life safety. 

Efforts to promote real estate sale and grow the local year round community. I hope to help local 

business advertise themselves with new footage that could never be achieved before. 
DUAV

Okoboji, Iowa

712.330.6417

Petitti@duav.org

Privacy

All commercial UAS operations will be conducted over private and controlled access property 

with property owner’s prior consent knowledge with respect to any temporary flight restrictions. 

Only those who have giving prior consent and have agreed to be photographed or filmed and to 

be involved in the area of operation may be near the P.I.C., subject of filming, and along 

predetermined route of UAS. Any person or owner of property (public or private) ask to have 

images removed will be allowed. All compliances will be meet by any state or local privacy

laws.

Accident & Indecent Reporting

In the event of an accident or incident all insurance or damages will be covered by DUAV LLC. 

The PIC of the UAS shall file a report on board form 6120.1/2 within 10 days after an accident. 

A report of an incident for which immediate notification is required (830.5) shall be filed only 

when requested by an authorized representative of the board. 

Drug and Alcohol 

No person may act as PIC or separate spotter/crewmember of UAS/aircraft while having a .04 

percent by weight or more alcohol in the blood or if any alcoholic beverages have been 

consumed within the preceding 8 hours. No person my act as crewmember of UAS if using any

drug the affects the persons faculties in any way contrary to safety. Any operation or attempt to 

operation under either of these conditions is grounds for denial of application for a certificate, 

rating, or authorization issued under 14 CFR Part 91.

Conclusion

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 operations within 

visual line of sight and national security - provide more than adequate justification for the grant 

of the requested exemptions allowing commercial operation of applicant’s UAS in photography 

and inspection industry pursuant to the Manual appended hereto.
DUAV

Okoboji, Iowa

712.330.6417

Petitti@duav.org

Thank you for your time and consideration.

Sincerely,

Thomas J Petitti, Esq. PPL

DUAV LLC,

Flight Manual & Operating Procedures

Flight Restrictions

 No commercial operation will occur with a UAS gross weight exceeding 55 pounds.

 No UAS operation in any controlled airspace.

 All UAS operations will have a secondary spotter on location at all times.

 Complete logo book of flights time and safety track records 

 All UAS flight operations will never exceed 400’ AGL and will never lose visual contact 

with the PIC.

 All commercial operations will take place over private property with prior consent from 

property owner.

 All required permits and licenses will be obtained form the local county and state of the 

commercial UAS operation. 

 The UAS will not operate over densely populated areas.

 The UAS will not operate at airshows.

 The UAS will not operate over any open air assembly of people.

 The UAS will not operate within 5 nautical miles of any airport without prior notice and 

radio communication.

 UAS operations will be restricted to civil daylight hours and VFR weather conditions.

 The PIC will brief anyone involved with or near the UAS operation on proposed route 

and maneuvers for each flight, along with any possible risks in the operating area. 
DUAV

Okoboji, Iowa

712.330.6417

Petitti@duav.org

 No flight will be conducted without a full pre-flight inspection by the PIC before each 

operation or change to weight and balance of the UAS. 

 UAS operations will never be conducted for the purpose of hunting, trapping, or spotting. 

Pre-Flight Checklist

 Test each battery with a voltmeter before powering UAS, and check batteries periodically 

in 5 minute intervals.

 Check all wiring for loss connections and any issues.

 Check propellers for any cracks or chips, assure leading edge of blades are smooth.

 Make sure all electric motors are clean and move freely.

 Assure all structural plastic appendages are strong and screwed fully.

UAS Start Up

 Power Devo7 transmitter and first person view system and insure full battery power.

 Power any addition gimbal and camera.

 Power DJI F550

 Wait for DJI F500 to connect with GPS, and find its home point

 Recalibrate DJI F500 compass if operating in a new location. 

UAS Run Up

 Check all flight controls make sure they are free and correct.

 Check all propellers with an optical tachometer from equal power distribution.

 Throttle 50% insure UAS is properly balanced while in air.

 Check flight controls while hovering and make sure controls are correct. 

UAS Shut Down

 Idle controls and propellers

 Unplug UAS
DUAV

Okoboji, Iowa

712.330.6417

Petitti@duav.org

 Turn off camera and gimbal

 Turn off first person viewing system

 Turn off Devo 7 Transmitter

TO REGAIN CONTROL AFTER LOST RADIO 

CONTACT

1. Failsafe = ON

2. Throttle = 50%

3. Mode = ATTI

4. Failsafe = OFF

5. Mode = GPS

DeVention 7 Transmitter

If radio contact is not restored, the UA

will automatically continue at 60 ft.

above its last elevation before losing

contact toward its takeoff point, then

descend and land there autonomously
DUAV

Okoboji, Iowa

712.330.6417

Petitti@duav.org
DUAV

Okoboji, Iowa

712.330.6417

Petitti@duav.org

DJI F550 Rotorcraft

F550_User_Manual_

v1.9_en.pdf

Figure 1 DJI F550 Manual 

Click to Expand

Specifications

Frame

Diagonal Wheelbase 550mm

Frame Weight 478g

Takeoff Weight 1200g ~ 2400g

ESC

Current 30A OPTO

Signal Frequency 30Hz ~ 450Hz

Battery 3S ~ 4S LiPo

Motor

Stator size 22×12mm

KV 920rpm/V

Propeller 10 × 3.8in (@3S); (Optional 8 × 4.5in (@4S))