Sept 30, 2015

U.S. Department of Transportation

Docket Management System

1200 New Jersey Ave., SE 

Washington, DC 20590

Re: Petition of Base line Land Surveyors, Inc. for an Exemption Pursuant to Section 333 of the FAA

Modernization and Reform Act of 2012

To Whom it May Concern:

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

C.F.R. Part 11, Base line Land Surveyors, Inc. (Base Line ) hereby applies for an exemption from the Federal

Aviation Regulations ("FARs") identified below to allow commercial operation of small unmanned aerial 

vehicles (i.e., "small unmanned aircraft" or "UAS") for the purpose of conducting aerial land surveying and 

photogrammetry for real property.

This petition for exemption is created based on information outlined in this Petition for Exemption, as 

well as, but not limited to, these accompanying Base Line documents; 

1. Flight Operations Manual;

2. Operations Manuals

(collectively referred to as “Operations Manuals")

3. User Guide and;

4. User Manual 

(collectively referred to as "Manufacturer's Manual").1 

Base Line submits these as well as other Base Line supporting materials as confidential documents 

pursuant to 14 C.F.R. § 11.35 (b), as the materials contain confidential commercial and/or proprietary

information that the Base Line has not and will not share with others. Additionally, these documents 

contain operating conditions and procedures that are not generally available to the public and are protected 

from release under the Freedom of Information Act, 5 U.S.C. §552 et seq.

________________________

1The term "Manufacturer's Manual" also includes all relevant manufacturer publications, including, but not

limited to: operations and flight manuals, user guides, component maintenance manuals, pilot training

manuals, service information letters and, safety/service bulletins).
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Page 2

This Petition is organized as follows:

I. Description of Petitioner

II. Description of Proposed Operations

A. Aerial Surveys and Photogrammetry for Real Property 

III. Relevant Statutory Authority

IV. Base Line’s Proposed BL-UAS Operations Meet the Requirements of Section 333 of the Reform

Act

A. Approval is Warranted Based on the UAS's Size, Weight, Speed, and Operational Capability

B. Approval is Warranted Based on the Operational Restrictions Set Forth in the Operations

Manuals

V. Regulations From Which Exemption is Requested

A. 14 C.F.R. Part 21, Subpart H – Airworthiness Certificates and 14 C.F.R. § 91.203(a)(1)

B. 14 C.F.R. Part 27 Airworthiness Standards: Normal Category Rotorcraft

C.14 C.F.R. §§ 91.9(c), 45.23(b) and 45.27(a): Aircraft Marking and Identification Requirements

D. 14 C.F.R. § 91.405(a), 91.407(a)(1), 91.409(a)(1) and (2); 91.417(a) and (b): Maintenance

Inspections

E. 14 C.F.R. Part 61, 14 C.F.R. § 61.3, 14 C.F.R. § 61.113: Private Pilot Privileges and Limitations

F. 14 C.F.R. § 91.7(a): Civil Aircraft Airworthiness

G. 14 C.F.R. § 91.9(b)(2): Civil Aircraft Flight Manual in the Aircraft and 14 C.F.R. § 91.203(a) 

and (b): Carrying Civil Aircraft Certification and Registration

H. 14 C.F.R. § 91.103: Preflight Action

I. 14 C.F.R. § 91.109(a): Flight Instruction

J. 14 C.F.R. § 91.119(c): Minimum Safe Altitudes

K. 14 C.F.R. § 91.121: Altimeter Settings

 L. 14 C.F.R. § 91.151(a): Fuel Requirements for Flight in VFR Conditions

VI. Drug and Alcohol Program

VII. Public Interest

VIII. Privacy

IX. Federal Register Summary

X. Conclusion
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Sept 30, 2015

Page 3

I. DESCRIPTION OF PETITIONER

Base Line Land Surveyors, Inc. is a licensed land surveyor based in Winter Garden, Florida. Petitioner 

operates these services as a sole proprietor and has been in business for nearly 40 years. Base Line is 

prepared to utilize currently-owned and utilized UAV equipment on which user has more than a year’s

experience operating without incident. Base Line provides topographic land surveying for the real estate 

industry for commercial, public, and private land owners, meeting their distinct sales, rentals, surveying, 

property valuation, and upgrading (construction) needs. The firm has always been on the cutting edge of 

equipment utilized and is currently specializing in ground base Lidar, Hydrographic and GPS technology.

Upon receiving a 333 Exemption Base Line will begin immediately conducting Aerial Surveys and 

Photogrammetry for Real Property.

The contact information for Petitioner is as follows:

 Christopher Lindstedt

Base Line Land Surveyors, Inc.

15351 Amberbeam Blvd. 

Winter Garden, Fl 34787

Phone: 321.377.0390

Email: clindstedt@earthlink.net 

II.DESCRIPTION OF PROPOSED OPERATION

Base Line seeks an exemption pursuant to Section 333 of the Reform Act to operate the DJI F550, 

DJI S1000, PHANTOM 2, PHANTOM 3 also known as, (BL-UAS) for the proposed operations discussed 

below. All BL-UAS operations will occur under tightly controlled conditions on private property where

Base Line has received permission to operate from the landowner, controller or authorized representatives. 

The proposed BL-UAS operations will be conducted in accordance with the conditions and limitations of 

this Petition for Exemption and Base Line’s Operations Manuals. As detailed in Base Line’s Operations 

Manuals, all BL-UAS operations will be limited to daytime VFR conditions, within visual line-of-sight 

("VLOS") of the operator, in uncontrolled airspace, and will occur at least 5 miles away from an airport. 

Moreover, Base Line’s Operations Manuals incorporate redundant safeguards to assure that the aircraft 

does not travel outside the controlled area of BL-UAS operations, including GPS "geo-fencing"

technologies.

A. Aerial Surveys and Photogrammetry for Real Property

Base Line seeks to use small UASs for the purpose of conducting aerial surveys and 

photogrammetry for real property. Base Line has tailored its operations to meet the requirements 

established by the FAA in prior grants of exemptions authorizing commercial use of BL-UAS in the aerial 

videography and photography of real estate industry, including: 
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Sept 30, 2015

Page 4

 Trudeau, Realtor® (Exemption No. 11138)

 Alon Sicherman (Exemption No. 11728)

 Sokoler Medley (Exemption No. 11341)

 RC Pro Productions Consulting, LLC d/b/a Vortex Aerial (Exemption No. 11064)

 Flying-Cam, LLC (Exemption No. 11080)

 Crossfield LLC (Exemption No. 12574)

 Ascend Aerials LLC (Exemption No. 12322)

 Mark R. Paulson, RPLS (Exemption No. 12369)

Base Line’s BL-UAS aerial survey and photogrammetry for real property operations will be 

conducted on private property in a controlled area, away from spectators and persons not involved in the

aerial videography and photography of real estate property. All BL-UAS operations will be conducted 

during daylight hours, VFR conditions, at altitudes below 400' AGL. As set forth below, Base Line’s

operations provide a superior level of safety and quality compared to performing the same survey work 

using conventional fixed-wing aircraft or helicopters.

Base Line seeks to use small UASs for the purpose of conducting aerial videography and 

photography of real estate property. Traditional aviation methods of survey operations can expose survey

crew to risk, physical harm, serious injury or death. Without the deployment of a BL-UAS real estate 

companies typically hire photographers and surveyors to climb roofs and perform other elevated work, which

exposes them to the risk of falls, electrocution, or other work-related extremes. The use of small UAS

mitigates these hazards and is ultimately is a much safer method of performing these and most other type’s 

real estate photography and data collecting.

Base Line aerial videography and photography of real estate property is safer than traditional manned 

aircraft performing the same function. Conventional operations using rotorcraft and fixed-wing aircraft in 

low level operations present risks associated with vehicles weighing thousands of pounds and carrying 

large amounts of fuel. It is important to note that the use of small BL-UAS in this area will not only be

safer and more cost effective, but the quality of collected data and information is far superior. 

Small BL-UAS inspection is more reliable, and allows for the collection, dissemination, and storage

of visual and other sensory data with greater precision and duration. Small UASs are also capable of 

accessing and inspecting areas that would otherwise be inaccessible to humans or cannot be completed 

with conventional aircraft.
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III. RELEVANT STATUTORY AUTHORITY

This Petition for Exemption is submitted pursuant to Section 333(a) through (c) of the FAA

Modernization and Reform Act of 2012 ("Reform Act"). Congress has directed the FAA "to safely

accelerate the integration of civil unmanned aircraft systems into the national airspace system." Pursuant to 

Section 333 of the Reform Act, the FAA Administrator is to permit unmanned aircraft systems to operate 

in the National Airspace System ("NAS") where it is safe to do so based on the following considerations:

●The UAS's size, weight, speed and operational capability;

●Operation of the BL-UAS in close proximity to airports and populated areas; and

●Operation of the BL-UAS within the visual line of sight of the operator.

Additionally, the FAA Administrator has general authority to grant exemptions from the agency's 

safety regulations and minimum standards when the Administrator decides a requested exemption is in the 

public interest. See 49 U.S.C. § 106(f) (defining the authority of the Administrator); 49 U.S.C. § 44701(f)

(permitting exemptions from §§ 44701(a), (b) and §§ 44702 – 44716, et seq.). A party requesting an

exemption must explain the reasons why the exemption: (1) would benefit the public as a whole, and (2)

would not adversely affect safety (or how it would provide a level of safety at least equal to the existing

rules). See 14 C.F.R. § 11.81 (petitions for exemption).

IV. BASELINE’S PROPOSED BL-UAS OPERATIONS MEET THE REQUIREMENTS

OF SECTION 333 OF THE REFORM ACT

The small BL-UAS operations proposed by Base Line in this Petition for Exemption qualify for 

expedited approval pursuant to Section 333 of the Reform Act as each of the statutory criteria and relevant 

factors are satisfied.

A. Approval is Warranted Based on the UAS's Size, Weight, Speed, and Operational Capability

A Grant of Exemption is appropriate for operations conducted using the UAS due to its size weight, speed,

and operational capability.
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 UAS have been approved for use in prior Section 333 Grants of Exemption from the FAA.

2

 The UAS weighs less than 55 pounds, including payload.

 The UAS will not be flown at a ground speed in excess of 50 knots.

 Altitude information will be generated by equipment onboard the UA as specified using GPS

triangulation, digitally encoded barometric altimeter, radio altimeter, or any combination 

thereof. This information will be transmitted to the pilot via telemetric data feed.

 The UASs will have system redundancies and independent functionality to ensure the overall

safety and predictability of the system. If connection to the remote control or ground control

station is lost, failsafe systems will permit the BL-UAS to return to a predetermined location 

and safely land without injury or damage.

 The radio frequencies used for operations and control of the BL-UAS comply with the Federal 

Communications Commission ("FCC") and other appropriate government oversight agency

requirements. The operating frequency for the BL-UAS is 2.4 GHz. 

If the same operations were conducted using a helicopter, the aircraft's take-off weight would likely exceed 

6,000 pounds carrying a pilot, survey operator and VO-visual observer- navigator. The difference in 

weight between the BL-UAS and a helicopter significantly reduces the potential harm to the participating

and non- participating individuals or property in the event of an accident or incident. In addition, the risk 

to the onboard pilot and survey operator is eliminated.

 _________________________

2

See e.g., Grant of Exemption to Shotover Camera Systems L.P. (Exemption No. 11159); Grant of

Exemption to VDOS Global, LLC (Exemption No. 11112); Grant of Exemption to Low Country RC, Corp. 

(Exemption No. 11184); Grant of Exemption to Alan Purwin (Exemption No. 11161); 

Grant of Exemption to Helinet Aviation Services (Exemption No. 11160); Grant of Exemption to Total

Safety U.S., Inc. (Exemption No. 11156).
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Sept 30, 2015

Page 7

A. Approval is Warranted Based on the Operational Restrictions Set Forth in Base Line’s

Operations Manuals

Base Line’s Operations Manuals and the Manufacturer's Manual for the selected UASs will contain 

all the procedures and limitations necessary to safely and successfully perform the operations specified in 

this Petition for Exemption. 

To assist the FAA in making a safety assessment of Base Line’s proposed operations, below is a

summary of operational limitations and conditions that Base Line will adhere to, and which will ensure an 

equivalent or higher level of safety to operations conducted under current regulatory guidelines:

1. The BL-UAS weighs less than 55 pounds, fully loaded.

2. 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 operation.

3. All UASs operated under the Grant of Exemption will 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 will be as large as practicable.

4. Minimum crew for each flight operation will consist of a pilot, who will be Pilot- in Command 

("PIC") of the UAS, and one or more Visual Observers ("Observer") as necessary to safely

conduct the mission.

5. PICs shall possess at least a Private Pilot's Certificate and current Class III Medical Certificate. 

The PIC will also meet the flight review requirements specified in 14 C.F.R 61.56 in an 

aircraft in which the PIC is rated on his or her pilot certificate.

6. The UA shall be operated within VLOS of the PIC and Observer at all times. The PIC must use 

human vision unaided by any device other than corrective lenses, as specified on the PIC's 

FAA-issued medical certificate.

7. The PIC and Observer designated for any operation will be able to communicate verbally at all 

times.

8. Electronic messaging or texting will not be permitted during flight operations.

9. The additional requirements identified in the Grant of Exemption shall be added to the Base Line’s 

Operations Manuals. 
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The Operations Manuals will be maintained and made available to the Administrator upon request. 

If a discrepancy exists between the conditions and limitations in the Grant of Exemption and Base 

Line’s Operations Manuals, the conditions and limitations in the Grant of Exemption shall take

precedence and must be followed. Otherwise, Base Line shall follow the procedures outlined in their 

Operations Manuals.

10. Base Line may update or revise its Operations Manuals. Revisions will be tracked and a revised

copy of the Manual will be provided to the Administrator upon request. Base Line will also present an

updated and revised Operations Manuals if it petitions for extension or amendment to its Grant of

Exemption. If an update or revision would affect the basis upon which the FAA grants the exemption, 

Base Line will seek an amendment to its Grant of Exemption. Base Line will contact the FAA’s BLUAS Integration Office (AFS-80) if questions arise regarding updates or revisions to the operating

documents.

11. Base Line’s Operations Manuals and its Grant of Exemption will be available to the

PIC at the ground control station anytime the BL-UAS is operating.

12. The PIC is prohibited from beginning a BL-UAS flight unless (considering wind and forecast 

weather conditions) there is enough power to fly to the first intended point of landing, and assuming

normal cruising speed, to fly after that for at least 10 minutes.

13. Maximum total flight time for each operational flight using the BL-UAS will be limited to 40 

minutes or the amount of time the BL-UAS can be flown and still maintain a reserve battery power 

of no less than 25%, whichever occurs first.

14. Flights will be operated at an altitude of no more than 400 feet AGL and will never enter 

navigable controlled airspace without prior written authorization and approval from the FAA. In 

the event the structure being inspected exceeds 400 feet AGL, the BL-UAS will not be operated 

more than 100 feet above the highest point on the structure, and no more than 50 feet horizontally

from the structure.

15. Flight operations must be conducted at least 500 feet from all nonparticipating persons. (persons 

other than the PIC, VO, operator trainees or essential personnel), 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;
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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).

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 3 statute miles from the PIC.

17. The UA may not operate within 5 nm of an airport reference point as denoted on a current FAApublished aeronautical Base Line 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 Base Line 

COA. The letter of agreement with the airport management will be made available to the 

Administrator upon request.

18. Prior to each flight the PIC shall inspect the BL-UAS to confirm that it is in a condition safe for

flight. The pre-flight inspection will account for all discrepancies, e.g. inoperable components, items,

or equipment, not already covered in the relevant sections of the operating documents. The PIC shall

not operate the BL-UAS if the inspection reveals a condition that affects the safe operation of the BLUAS until the necessary maintenance has been performed and the BL-UAS is found to be in a

condition for safe flight. The ground control station shall be included in the preflight inspection. All 

maintenance and alternations must be properly documented in the BL-UAS records as required by

Base Line’s Operations Manuals.

19. Base Line will carry out its maintenance, inspections, and record keeping requirements in 

accordance with the Operations Manuals. Maintenance, inspection, and alterations will be noted in 

the BL-UAS records, including total time in service, description of work accomplished, and the 

signature of the authorized person returning the BL-UAS to service.

20. Any BL-UAS that has undergone maintenance or alterations that affect the BL-UAS 

operation or flight characteristics (e.g., replacement of a flight critical component) must undergo a 

functional test flight in accordance with Base Line Operations Manuals. The PIC who conductsthe

functional test flight must make an entry in the BL-UAS aircraft records of the flight. The requirements

and proceduresfor a functional test flight and BL-UAS record entry shall be included in the Base 

Line’s Operations Manuals.
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Page 10

21. The BL-UAS will be operated and maintained according to the Manufacturer's Manuals and any

required manufacturer Safety/Service Bulletins.

22. Prior to the operation, a Mission Packet will be created in accordance with the requirements on 

Base Line’s Operations Manuals.

23. Base Line will obtain an Air Traffic Organization ("ATO") issued Certificate of Waiver or 

Authorization, otherwise known as a COA, prior to conducting any operations under this Grant of 

Exemption. A NOTAM will be issued as required by the COA. All operations will be conducted in

accordance with airspace requirements in the ATO issued COA including class of airspace, altitude

level and potential transponder requirements.

24. All required permissions and permits will be obtained from territorial, state, county or city

jurisdictions, including local law enforcement, fire or other appropriate governmental agencies.

25. If the BL-UAS loses communication with the pilot, it will have the capability to return to a predetermined location within the operational area and land safely.

26. Contingency plans will be in place to safely terminate flight if there is a loss of communication 

between the PIC and the Observer.

27. The BL-UAS will have the capability to safely abort flight in the case of unpredicted obstacles or

emergencies.

28. PICs and Observers will have at least a current Class III Medical Certificate.

29. Prior to conducting operations for operations, the PIC will have accumulated and logged, in a 

manner consistent with 14 CFR § 61.51(b), a minimum of 200 flight cycles and 25 hours total time as 

a BL-UAS rotorcraft pilot and at least 10 hours logged as a BL-UAS pilot with a similar BL-UAS 

type.

30. Prior to conducting operations for operations, the PIC will have accumulated and logged, in a 

manner consistent with 14 CFR § 61.51(b), a minimum of 54 CFR §61.51(b), a minimum of 10

logged hours as BL-UAS pilot operating the make and model of BL-UAS to be utilized for operations 

under the exemption and thirty take-offs and thirty landing in the preceding 90 days.
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31. Operations shall occur during daytime VFR Meteorological Conditions; flights under Special 

Visual Flight Rules ("SVFR") shall not be conducted.

32. The UA shall remain clear and yield the right of way to all other manned operations and activities 

at all times (including, but not limited to, ultralight vehicles, parachute activities, parasailing

activities, hang gliders, etc.).

33. BL-UAS Operations under Instrument Flight Rules, at night, or beyond VLOS are prohibited.

34. The UAs will not be operated from an elevated platform or moving device / vehicle.

35. Before conducting operations, the radio frequency spectrum used for operation and control of the

UA will comply with the Federal Communications Commission (FCC) or other appropriate 

government oversight agency requirements.

V. REGULATIONS FROM WHICH EXEMPTION IS REQUESTED

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,

including UASs, from its safety regulations and minimum standards when the Administrator decides a

requested exemption is in the public interest.

3

Base Line seeks an exemption from several interrelated provisions of Title 14 of the Code of Federal 

Regulations ("14 C.F.R") Parts 21, 45, 61 and 91 for purposes of conducting the requested operations using a

UAS. Listed below are: (1) the specific sections of 14 C.F.R for which exemption is sought, and (2) the 

operating procedures and safeguards that Petitioner has established which will ensure a level of safety better 

than or equal to the rules from which exemption is sought.

4

3

49 U.S.C. § 44701(f) (authorizing the grant of exemptions from requirements of regulations prescribed 

pursuant to Sections 44701(a) and (b) and Sections 44702 - 44716).

4

14 C.F.R § 11.81(e), which requires a petition for exemption to include: The reasons why granting the

exemption would not adversely affect safety, or how the exemption would provide a level of safety at that

provided by the rule from which you seek exemption.
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Page 12

UNMANNED AIRCRAFT SYSTEM

A. 14 C.F.R. Part 21, Subpart H – Airworthiness Certificates and 14 C.F.R. § 91.203(a)(1)

The FAA has stated that no exemption is needed from this section if a finding is made under the

Reform Act that the BL-UAS selected provides an equivalent level of safety when compared to aircraft 

normally used for the same application. These criteria are met, and therefore no exemption is needed.

5 If, 

however, the FAA determines that there are some characteristics of the chosen BL-UAS that fail to meet the 

requirements of the Reform Act, an exemption is requested.

Equivalent Level of Safety

Base Line’s use of BL-UAS are safe when taking into account their size, weight, speed, and

operational capability. As set forth in the description of proposed operations in Section IV (A), BL-UAS 

weighs less than 55 pounds, including payload and will not be flown at a ground speed in excess of 50 knots. 

BL-UAS is also equipped with safety features that will allow Petitioner to operate the BL-UAS safely after 

experience certain in-flight contingencies or failures.

6 7

5

See Grant of Exemption No. 11062 to Astraeus Aerial (FAA-2014-0352 at pgs. 13-14, 22).

6

See e.g., Grant of Exemption No. 11184 to Low Country RC, Corp. (FAA-2014-0803 at pg. 3): "The [BLUAS] has the capability to operate safely after experiencing certain in-flight contingencies or failures 

and uses an auto-pilot system to maintain BL-UAS stability and control. The BL-UAS is also able to

respond to a loss of global positioning system (GPS) or a lost-link event with a pre-coordinated,

predictable, automated flight maneuver, and manual flight control functionality as a backup. These

safety features provide an equivalent level of safety compared to a manned aircraft performing a

similar operation."

7

See e.g., Grant of Exemption No. 11184 to VDOS Global, LLC. (FAA-2014-0382 at pgs. 4-5): 

 The BL-UAS’s operator can operated entirely by a touch-screen, map-based interface.

This means the operator only needs to command the system where to go, and the

system does all the flying for the operator. The BL-UAS can be operated in both semi and fully

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

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

ranges and altitudes so the system cannot enter areas

{footnote continued}
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Additionally, the UASs carry neither pilots nor passengers, carry no explosive materials or flammable liquid 

fuels, and operate exclusively within the parameters stated in Base Line’s Operations Manuals.

Operations conducted under this exemption will be closely controlled and monitored by the operator

and will be conducted in compliance with local public safety requirements, to provide security for the area of 

operation. Base Line will also provide the FAA with advance notice of all operations via NOTAMs as

required by the applicable COA. In all cases, operation of the UAVs under the proposed conditions will be

at least as safe as, or safer than, conventional rotorcraft operating with an airworthiness certificate.

Lastly, the UASs do not need a means to communicate with other aircraft or ATC, because those

capabilities will be possessed by the PIC and Observer, who are not onboard the UAS.

8 In addition, no 

sense-and-avoid technology is necessary for the UASs because they will be operated at all times in VFR 

conditions and within VLOS of the PIC and Operator.

9

B. 14 C.F.R. Part 27 Airworthiness Standards: Normal Category Rotorcraft

Title 14 C.F.R. Part 27 sets forth the procedural requirements for airworthiness certification of normal 

category rotorcraft. To the extent that Base Line’s small UASs would otherwise require certification under 

Part 27, Petitioner seeks an exemption from Part 27's airworthiness same reasons identified in the request for 

exemption from 14 C.F.R. Part 21, Subpart H, supra.

{continued from previous page} 

deemed unsafe or unnecessary to fly over. The petitioner states further that the BL-UAS has built-in

intelligent fault handling which allowsthe BL-UAS to detect a system fault while in the air and

automatically fly back to its takeoff location and land. Faults that can be detected include: loss of

communication; exceeding pre-set wind thresholds; and low battery levels.

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

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

automatically holds its GPS position. The flight control system employs not only GPS positioning

but a variety of sensors including sonar, barometric pressure, temperature, wind speed and othersto

ensure stability so long as wind thresholds are not exceeded. Also a flight termination link – to

prevent a 'fly away' or other potentially dangerous situation – is available to the operator."

8

See Grant of Exemption No. 11062 to Astraeus Aerial (FAA-2014-0352 at pgs. 13-14, 22).

9

Id.
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Page 14

C. 14 C.F.R. §§ 91.9(c), 45.23(b) and 45.27(a): Aircraft Marking and Identification

Requirements

Base Line seeks an exemption from the aircraft marking and identification requirements 

contained in 14 C.F.R. §§ 91.9(c), 45.23(b) and 45.27(a).

 14 C.F.R. § 91.9(c), Civil Aircraft Flight Manual, Marking and Placard requirements, 

provides that: No person may operate a U.S.-registered civil aircraft unless that aircraft is 

identified in accordance with Part 45 of this chapter.

 14 C.F.R. § 45.23(b), Markings of the Aircraft, states:

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 two inches nor more than six inches high, the words "limited,"

"restricted," "light-sport,

"Experimental," or "provisional," as applicable.

 14 C.F.R. § 45.27(a), Rotorcraft, states: 

Each operator of a rotorcraft must display on that rotorcraft horizontally on both surfaces of

the cabin, fuselage, boom, or tail the marks required by § 45.23.

In a previous Grant of Exemption, the FAA determined that exemption from these requirements was 

warranted provided that the aircraft "have identification (N-Number) markings in accordance with 14 C.F.R 

Part 45, Subpart C if the markings are as large as practicable."

10

Equivalent Level of Safety

All UA flown by Base Line will bear N-number markings that are as large as practicable in 

accordance with 14 C.F.R. Part 45, Subpart C.

11

10

FAA Docket No. FAA-2014-0352.

 

11

See, e.g., FAA Docket No. FAA-2014-0352, at 14.

 D. 14 C.F.R. § 91.405(a), 91.407(a)(1), 91.409(a)(1) and (2); 91.417(a) and (b): 

Maintenance Inspections
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Page 15

Base Line seeks an exemption from the maintenance inspection requirements contained in 14 C.F.R. § 

91.405(a), 91.407(a)(1), 91.409(a)(2); 91.417(a) and (b). These regulations specify maintenance and 

inspection standards in reference to 14 C.F.R. Part 43. See, e.g., 14 C.F.R. § 91.405(a) (stating that each 

owner or operator of an aircraft "shall have the aircraft inspected as prescribed in subpart E of this part and 

shall between required inspections...have discrepancies repaired as prescribed in part 43 of this chapter"). 

An exemption from these regulations is needed because Part 43 and these sections only apply to aircraft with 

an airworthiness certificate, which the BL-UAS to be operated under this grant of exemption will not have.

Equivalent Level of Safety

An equivalent level of safety will be achieved because maintenance and inspections will be

performed in accordance with the Manufacturer's Manual and any required manufacturer Safety or Service

Bulletins. Further, as required by Base Line’s Operations Manuals, the PIC will conduct a pre-flight 

inspection of the BL-UAS and all associated equipment to account for all discrepancies and/or inoperable

components. Maintenance will be performed and verified to address any conditions potentially affecting safe

operation of the BL-UAS and no flights will occur unless, and until, all flight critical components of the BLUAS have been found to be airworthy and in a condition safe for operation. A functional test flight will be 

conducted following the replacement of any flight-critical components. As required by Base Line’s

Operations Manuals, the PIC who conducts the functional test flight will make an entry in the BL-UAS 

aircraft records of the flight.

Base Line’s Operations Manual also includes requirements to follow the manufacturer’s BL-UAS 

aircraft/component, maintenance, overhaul, replacement, inspection, and life limit requirements for the

following applicable components: powertrain system (powerplant), propellers, avionics and control surfaces 

(including ailerons/elevons), structures & airframe, survey system, electrical systems (including batteries),

ground control station, hazard accessories, and spare parts. Further, Base Line’s Operations Manuals also 

includes procedures to document and maintain a record of the BL-UAS maintenance, preventative 

maintenance, alterations, status of replacement /overhaul component parts, and the total time in service of the

UASs used under this Grant of Exemption. As a whole, the maintenance and inspection procedures required 

in Base Line’s Operations Manuals ensure that an equivalent or higher level of safety will be achieved.

 
U.S. Department of Transportation

Sept 30, 2015

Page 16

PILOT-IN-COMMAND OF THE UAS

E. 14 C.F.R. § 61.113: Private Pilot Privileges and Limitations

Base Line seeks exemption from 14 CFR § 61.113, which restricts private pilot certificate holders 

from flying aircraft for compensation or hire, and would also require a second class medical certificate. The

purpose of Part 61 is to ensure that the skill and competency of any PIC matches the airspace in which the 

PIC will be operating, as well as requiring certifications if the private pilot is carrying passengers or cargo for

hire. In this case, while the UASs will be operated as part of a commercial operation, it carries neither

passengers nor cargo. In the Grant of Exemption to Astraeus Aerial

12, the FAA determined that the unique 

characteristics of BL-UAS operation outside of controlled airspace did not warrant the addition cost and 

restrictions attendant with requiring a the PIC to have a Commercial Pilot Certificate and Class II Medical

Certificate. The fulfillment of the additional requirements for a private pilot to become qualified as a 

commercial pilot would not lead to any additional safety benefits when BL-UAS operations are involved.

Equivalent Level of Safety

The restrictions Base Line has placed on its BL-UAS operations meet or exceed the restrictions 

similarly imposed on Astraeus Aerial. Base Line will operate on private property away from persons and 

property not involved in the operation. Base Line will also obtain an ATO issued COA prior to conducting 

any operations under this Grant of Exemption. All operations will be conducted in accordance with airspace

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

requirements. A NOTAM will also be issued as required by the applicable COA.

In addition to these flight restrictions, Base Line will further ensure safe operation by requiring that 

any PIC be thoroughly versed not only in airspace and communication issues pertaining to all aircraft 

operators but also in the unique aspects of BL-UAS flight. As set forth in the Operations Manuals, pilots will

have experience not only in BL-UAS operations generally but have logged flight time in the specific make

and model used for the operations before they are permitted to participate in commercial flights on behalf of

Base Line . The pilot qualification, training, and currency requirements in the Operations Manuals ensure

that Base Line ’ S pilots are competent and proficient in the BL-UAS they are operating. Base Line’s

training and qualification requirements are consistent with those contained in prior FAA Section 333 Grants 

of Exemption, and will provide a higher level of competency and proficiency for its pilots and will ensure at 

least an equivalent level of safety.

12

Exemption No. 11062 (FAA Docket No. FAA-2014-0352).
U.S. Department of Transportation

Sept 30, 2015

Page 17

OPERATING PARAMETERS OF THE UAS

F. 14 C.F.R. § 91.7(a): Civil Aircraft Airworthiness

Although there will be no airworthiness certificate issued for the UASs, Base Line seeks an 

exemption from 14 C.F.R. § 91.7(a), which requires that a civil aircraft be in airworthy condition to be

operated. The FAA has stated that no exemption is required for 14 C.F.R. § 91.7(a) to the extent that the 

requirements of Part 21 are waived or found inapplicable.

13 Accordingly, Petitioner requests that the 

requirements for § 91.7(a) be treated in accordance with Section V (A), supra.

G. 14 C.F.R. § 91.9(b)(2): Civil Aircraft Flight Manual in the Aircraft and 14

C.F.R. § 91.203(a) and (b): Carrying Civil Aircraft Certification and Registration

Title 14 C.F.R. § 91.9(b)(2) and § 91.203(a) and (b) require the operator to carry airworthiness documents

and other aircraft manuals onboard the aircraft. Pursuant to 14 C.F.R. § 91.9(b)(2):

...

(2) For which an Airplane or Rotorcraft Flight Manual is required by § 21.5 of this chapter, unless 

there is available in the aircraft a current approved Airplane or Rotorcraft Flight Manual, approved 

manual material, markings, and placards, or any combination thereof.

Pursuant to 14 C.F.R. § 91.203(a) and (b):

(b) No person may operate a U.S.-registered civil aircraft –

(a) Except as provided in § 91.715, no person may operate a civil aircraft unless it has within it the

following:

(1) An appropriate and current airworthiness certificate...

(b) No person may operate a civil aircraft unless the airworthiness certificate required by paragraph

(a) of this section or a special flight authorization issued under § 91.715 is displayed at the cabin or

cockpit entrance so that it is legible to passengers or crew.

Given the small size and configuration of the UASs, it would be impossible to keep airworthiness documents

and other aircraft manuals on board the BL-UAS because there is simply no room and the BL-UAS has no 

cabin or cockpit.

13

See id. at 13-14, 22 
U.S. Department of Transportation

Sept 30, 2015

Page 18

Equivalent Level of Safety

In an FAA Office of Chief Counsel's Opinion dated August 8, 2014, and prepared by Dean E. 

Griffith, Attorney, AGC-220, it was acknowledged that the intent of 14 C.F.R. 91.9(b) and 91.203(a) and (b) 

is met if the pilot of the unmanned aircraft has access to the BL-UAS flight manual, registration certificate, 

and other required documents from the ground control station from which he or she is operating the 

aircraft.

14 As this FAA Office of Chief Counsel Opinion clarifies, the intent of the rule is to ensure the pilot

has access to these key documents during flight. Therefore, an equivalent level of safety will be achieved by

ensuring that the pilot has access to the documents at the ground control station from which he or she is 

piloting the UAS.

H. 14 C.F.R. § 91.103: Preflight Action

Base Line seeks an exemption from 14 C.F.R. § 91.103, which requires a PIC to become familiar 

with specific information before each flight, including information contained in the FAA-approved Flight 

Manual on board the aircraft. While the PIC will be familiar with all information necessary to safely conduct 

the flight, an exemption is requested to the extent that an FAA-approved Flight Manual is required.

Equivalent Level of Safety

An equivalent level of safety will be provided by following the Base Line’s Operations Manuals and 

the Manufacturer's Manual. The PIC will perform a series of checklists designed to identify any defects or 

inoperable components in accordance with the Base Line’s Operations Manuals, including checklists

covering Pre-Flight, Launch, Landing, and Post-Flight procedures. The PIC will also be required to review

weather, flight requirements, battery charge, landing and takeoff distance, UA performance data, and

contingency landing areas—before initiation of flight. Base Line’s Operations Manuals and the 

Manufacturer's Manual will be kept at the ground control station and will be accessible to the PIC at all times 

while operating the UAS.

I. 14 C.F.R. § 91.109(a): Flight Instruction

14 Memorandum from Mark Bury, FAA Assistant Chief Counsel for International Law, Legislation and 

Regulation, to John Duncan, FAA Flight Standards Service (Aug. 8, 2014); see also Docket No. FAA-2014-

0352 at 16-18.
U.S. Department of Transportation

Sept 30, 2015

Page 19

Base Line seeks an exemption from 14 C.F.R. § 91.109(a), which provides in pertinent part that 

"[n]o person may operate a civil aircraft (except a manned free balloon) that is being used for flight 

instruction unless that aircraft has fully functioning dual controls." UASs and remotely piloted aircraft, by

their design, do not have functional dual controls. Instead, flight control is accomplished through the use 

of a device that communicates with the aircraft via radio communications. Accordingly, an exemption will 

be required for the flight instruction requirements of 14 C.F.R. § 91.109(a).

Equivalent Level of Safety

Given the size and speed of the UASs that Base Line intends to use, an equivalent level of safe

training can still be performed without dual controls because no pilot or passengers are aboard the UAS, and 

as required by the Base Line’s Operations Manuals, all persons will be a safe distance away in the event that 

the BL-UAS experiences any difficulties during flight instruction. Moreover, as required by the Base Line ’ 

Operations Manuals, all flight training will be conducted in controlled and sterile environment. As a whole,

the safety procedures provided for in Base Line’s Operations Manuals ensure that the proposed BL-UAS 

operations provide an equivalent or higher level of safety than that provided by the flight instruction 

regulations.

J. 14 C.F.R. § 91.119(c): Minimum Safe Altitudes

Base Line requests an exemption from the minimum safe altitude requirements of 14 C.F.R. § 

91.119(c).

15 Section 91.119 prescribes the minimum safe altitudes under which aircraft may not operate, 

including 500 feet above the surface and away from any person, vessel, vehicle, or structure in noncongested areas. See 14 C.F.R. § 91.119(c). Section 91.119(d) allows for a helicopter to operate at less than 

those minimum altitudes when it can be operated "without hazard to persons or property on the surface,"

provided that "each person operating the helicopter complies with any routes or altitudes specific Base Line’s

prescribed for helicopters by the FAA."

An exemption is required because the proposed BL-UAS operations will normally need to occur

below 400 feet AGL. In circumstances where the BL-UAS is used to inspect a structure whose height 

exceeds 400 feet AGL, the BL-UAS will not be operated more than 100 feet above the highest point on the 

structure, and within 50 feet horizontally of the structure. Additionally, due the nature of the proposed 

operations, the Pilot and/or Observers(s) may need to be less than 500 feet away from the UAS.

15Relief from § 91.119(a) will not be necessary because Petitioner will be able to perform an emergency

landing without undue hazard to persons or property on the ground in the event of a failure. Petitioner's 

proposed BL-UAS operations will not occur over congested areas, and therefore an exemption from § 

91.119(b) will not be necessary. See e.g., Grant of Exemption No. 11157 to Slug wear, Inc., dba Like on a

tree Aerial (FAA-2014-0534 at 15)
U.S. Department of Transportation

Sept 30, 2015

Page 20

Equivalent Level of Safety

Compared to flight operations with rotorcraft weighing far more than the maximum weights proposed 

herein, and given the lack of flammable fuel with the UASs, any risk associated with these operations is far 

less than those that presently exist with conventional aircraft. An equivalent level of safety will be achieved

given the size, weight, and speed of the UASs, as well the controlled location where the operations will 

occur. In order to avoid any risk to manned aircraft, flight operations will be restricted to 400 feet AGL or 

below, or when inspecting a structure whose height exceeds 400 feet AGL, within 100 feet above the highest 

point on that structure and 50 feet horizontally of the structure.

As set forth in the Operations Manuals, the UASs will be operated in a restricted area, and all flights 

will be operated at a lateral distance of at least 500 feet from any nonparticipating persons, unless that person 

is in a position where he or she is shielded from the BL-UAS and any possible debris resulting from BL-UAS 

failure. As required by the Operations Manuals, flights will be terminated if a nonparticipating person within 

500 feet of the BL-UAS leaves a shielded position. Further, BL-UAS operations will occur at least 500 feet 

away from vehicles or structures unless the property owner/controller has granted permission and the PIC has 

made a safety assessment of the risk of operating closer to those objects and, operations near the PIC or

Observer will not present an undue hazard per § 91.119(a). Adherence to these restrictions in Base Line’s

Operations Manuals will ensure operations can be conducted without compromising safety.

16

K. 14 C.F.R. § 91.121: Altimeter Settings

Base Line seeks an exemption from 14 C.F.R. § 91.121, which requires a person operating an aircraft 

to maintain cruising altitude or flight level by reference to an altimeter that is set to the elevation of the 

departure airport or barometric pressure An exemption is required to the extent that the UASs do not have a

barometric altimeter, but rather a GPS altitude read out.

16

See e.g., Grant of Exemption No. 11138 to Douglas Trudeau (FAA-2014-0481 at 19):

"If barriers or structures are present that can sufficiently protect nonparticipating persons from the UA or

debris in the event of an accident, then the UA may operate closer than 500 feet to persons afforded such

protection. The operator must also 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. When considering how to immediately cease operations, the

primary concern is the safety of those nonparticipating persons. In addition, the FAA finds that operations

may be conducted closer than 500 feet to vessels, vehicles and structures when the owner/controller of any

such vessels, vehicles orstructures grants permission for the operation and the PIC makes a safety 

assessment of the risk of operating closer to those objects and determines that it does not present an undue

hazard.”
U.S. Department of Transportation

Sept 30, 2015

Page 21

Equivalent Level of Safety

The FAA has stated that an equivalent level of safety to the requirements of 14 C.F.R. §91.121 can be

achieved in circumstances where: (1) the UASs will be operated below 400 feet AGL or below

17

, (2) within 

VLOS, (3) where GPS based altitude information is relayed in real time to the operator at a ground-based 

on-screen display and, (4) where prior to each flight, a zero altitude initiation point is established for the 

PIC to confirm accuracy of the onboard GPS.

18

The UASs that Base Line intends to use for the proposed operations will meet all these operational 

characteristics. Moreover, as required by Base Line’s Operations Manuals, the PIC will be required to 

calibrate the aircraft's GPS compass prior to each flight operation. Like prior FAA Section 333 Grants of 

Exemption, the UASs Base Line intends to use, and the safety mitigation procedures contained in the

Operations Manuals, both ensure that an equivalent level of safety will be achieved, and a Grant of 

Exemption to the requirements of § 191.121 is therefore appropriate.

L. 14 C.F.R. § 91.151(a): Fuel Requirements for Flight in VFR Conditions

Base Line requests an exemption from 14 C.F.R. § 91.151(a)'s fuel requirements for flight in VFR

conditions. Section 91.151 states: 

(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 –

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

(2) At night, to fly after that for at least 45 minutes.

Here, the technological limitations on BL-UAS battery power means that no meaningful flight 

operations can be conducted while still maintaining a 30-minute battery reserve. An exemption from the

fuel requirements of 14 C.F.R. § 91.151(a) is therefore required.

17

If the height of the structure being inspected exceeds 400 feet AGL, the BL-UAS will not be operated more

than 100 feet above the highest point on the structure.

18

See Grant of Exemption No. 11062 to Astraeus Aerial (FAA-2014-0352 at 21).
U.S. Department of Transportation

Sept 30, 2015

Page 22

Equivalent Level of Safety 

 In the Grant of Exemption to VDOS (Exemption No. 11112), the FAA determined that an 

equivalent level of safety to the fuel requirements for flight in VFR conditions could be achieved by 

prohibiting the PIC from beginning a DJI F550 flight unless (considering wind and forecast weather 

conditions) there was enough power to fly to the first intended point of landing and, assuming normal 

cruising speed, to fly after that for at least 10 minutes. In reaching this conclusion, the FAA considered that 

the BL-UAS batteries for the DJI F550 provided provide approximately 20 minutes of powered flight (with 

payload) and provided battery level and battery time remaining in minutes and seconds to the PIC.19 The 

FAA also considered the fact that the DJI F550 operating manual states: “start every flight with a fully 

charged battery in the aerial vehicle”, and that in the event that the BL-UAS should run low on power, the 

PIC will be alerted and can land the DJI F550 as soon as possible. Like the VDOS Grant of Exemption, 

Base Line use of the DJI F550, combined with the requirements of Petitioner's Operations Manuals, ensure 

that an equivalent level of safety can be achieved. 

Similarly, in the Grant of Exemption to Alan Purwin (Exemption No. 11161), the FAA determined 

that an equivalent level of safety to the fuel requirements for flight in VFR conditions could be achieved by 

prohibiting the PIC from beginning a flight with the BL-UAS unless (considering wind and forecast 

weather conditions), there was enough power to fly at normal cruising speed to the intended landing point 

and land the UA with 25% battery power remaining. Base Line will adhere to this limitation for BL-UAS 

flights. 

The BL-UAS includes a low battery warning system and the amount of battery reserve power 

remaining is transmitted to the PIC via telemetric data feed, which downlinks from the BL-UAS to a 

ground-based-on-screen display.20 As required by Base Line’s Operations Manuals, the PIC will promptly 

fly the BL-UAS back to the home launch location or pre-determined abort location where the BL-UAS 

may safely land, while still maintaining a minimum of 25% reserve battery power. Base Line submits that 

the procedures requiring flights to be safely terminated once the batteries fall below 25% capacity, 

combined with the requirement that flights only be conducted within a secure, isolated area, using a BLUAS weighting less than 25 pounds, and within VLOS of the PIC and Observer(s), ensure that the 

proposed operation will provide an equivalent or higher level of safety to that provided by the regulations 

from which exemption is sought. 

 _____________________

19 Grant of Exemption No. 11112 to VDOS Global, LLC (FAA-2014-0382 at 10). 

20 The BL-UAS ground control station displays, the UASs position, navigation route, tail number, altitude, 

heading, north seeking arrow, range to targets, calculated target position, date/time, and sensor heading and 

orientation relative to the UAS. 
U.S. Department of Transportation

Sept 30, 2015

Page 23

VI. DRUG AND ALCOHOL PROGRAM

Base Line will have policies in place to ensure that no person may participate in BL-UAS flight 

operations if they are under the influence of alcohol or any drug. 

VII. PUBLIC INTEREST 

The public interest will be served by granting Base Line’s Petition for Exemption. Congress has 

established a national policy that favors early integration of BL-UAS into the NAS in controlled, safe 

working environments such as those proposed in this Petition. Granting this Petition for Exemption helps 

fulfill Congress' goal in passing Section 333(a) through (c) of the Reform Act—the FAA Administrator's

assessment of whether certain BL-UAS may operate safely in the NAS before completion of the statutorily 

required rulemaking.

The proposed BL-UAS operations in this Petition for Exemption significantly improves safety and 

reduces risk harm or serious injury to real estate companies, assessment teams, and surveyors. Traditional 

methods of photography, videography and surveying exposes them to the risk of dangerous falls. The use 

of small UASs can eliminate these hazards and is ultimately a much safer method of performing these 

types of inspections. 

The use of small UASs also enhances safety and reduces risk because, unlike manned aircraft weighing 

thousands of pounds, carrying crew in addition to flammable fuel, the UASs carry no passengers or crew. 

Further, in the unlikely event of an accident, Base Line’s small battery powered UASs presents 

significantly less danger to persons on the ground when compared to operations by conventional manned 

aircraft.21 As Petitioner's UASs are battery powered, the public will also benefit from a reduction in 

harmful emissions associated with conventional aircraft performing in the same functions proposed herein. 

Lastly, as recognized by the FAA in prior Section 333 Grants of Exemption to surveying, UASs provide an 

additional tool for the aerial operations industry, adding a greater degree of flexibility, which supplements 

the current capabilities offered by manned aircraft.22

_______________________

21 See Grant of Exemption No. 11158 to Team 5, LLC (FAA-2014-0783 at 12): 

"Manned helicopters conducting aerial operations can weigh 6,000 pounds or more and are operated 

by an onboard pilot, in addition to other onboard crewmembers, as necessary. The petitioner’s UAs 

will weigh less than 55 pounds with no onboard pilot or crew. The pilot and crew will be remotely 

located from the aircraft. The limited weight significantly reduces the potential for harm to 

participating and nonparticipating individuals or property in the event of an incident or accident. 

The risk to an onboard pilot and crew during an incident or accident is eliminated with the use of a 

BL-UAS for the aerial operations" 

22 See e.g., Grant of Exemption No. 11178 to Picture Factory, Inc. (FAA-2014-0794 at 18).
U.S. Department of Transportation

Sept 30, 2015

Page 24

VIII. PRIVACY 

All Base Line BL-UAS operations will be conducted in accordance with applicable federal, state, or 

local laws regarding privacy. 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. 

IX. FEDERAL REGISTER SUMMARY 

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:

Petitioner seeks an exemption from the following rules in Title 14 of the Code of Federal Regulations: 

Part 21, Subpart H; Part 27; 45.23(b); 45.27(a); 61.113; 91.7(a); 91.9(b)(2); 91.9(c); 91.103; 91.109(a); 

91.119(c); 91.121; 91.151(a); 91.203 (a) & (b); 91.405(a); 91.407(a)(1); 91.409(a)(1) & (2); 91.417 (a) 

& (b).

The exemption will enhance safety by reducing risk to the general public and property owners from 

the substantial hazards associated with performing equivalent survey work and aerial inspection and 

environmental monitoring of industrial sites, transmission and storage facilities, construction facilities and 

precision aerial surveys with conventional fixed-wing aircraft, rotorcraft, or other methods.

X. CONCLUSION

Base Line Petition for Exemption satisfies the criteria articulated in Section 333 of the Reform Act 

of 2012 including weight, speed, operating capabilities, proximity to airports and populated areas, 

operation within VLOS and national security. The proposed BL-UAS operations will benefit the public as a 

whole by improving safety and reducing risk by alleviating human exposure to danger. In consideration of 

the foregoing, this Petition for Exemption provides the FAA with more than adequate justification for 

granting the requested exemptions allowing Base Line to use small UASs for conducting aerial land 

surveying and photogrammetry for real property

22 See e.g., Grant of Exemption No. 11178 to Picture Factory, Inc. (FAA-2014-0794 at 18).
U.S. Department of Transportation

Sept 30, 2015

Page 25

We thank you for your prompt consideration of our requested exemptions. 

Respectfully Submitted,

 Christopher Lindstedt

 Base Line Land Surveyors, Inc. 

15351 Amberbeam Blvd. 

Winter Garden, Florida 34787

Phone: 321.377.0390

Email: clindstedt@earthlink.net

(The following attached items contain and commercial information exempt from disclosure under the 

Freedom of Information Act, 5 U.S.C. § 522 et seq., and should be held in a separate file pursuant to 14 

C.F.R. § 11.35(b)). 

Attachments: 

1. General Operations Manual

2. PIC Operating Manual

3. Company Protocols

4. Location Protocols

5. Flight Communications Protocols

6. Departing Location Protocols

7. Transmitter Protocols

8. Preflight Checklist

9. Post Flight Checklist

10. Equipment Checklist

11. UAS Manufacturer’s Manuals

a. User Manuals

b. UAS Maintenance Manuals