U.S. Department of Transportation 

Docket Management System 

1200 New Jersey Ave., SE 

Washington, D.C. 20590

Petitioner:

SunSweep

Manny Teran

President and CEO

2102 N. Forbes Blvd., Suite 101

Tucson, AZ 85745

manny.teran@aztera.com

Submitted On: 7/21/2015

Dear Sir or Madam: 

With regards to Section 333 of the FAA Modernization and Reform Act of 2012, SunSweep hereby 

applies for an exemption from Federal Aviation Regulations (FARs) to allow commercial operation of its 

small Unmanned Aerial Systems (sUAS). SunSweep will use said sUAS to monitor and gather data on 

solar farms, using infrared imaging, in order to detect inefficiencies of photovoltaic cells, so long as such 

operations are conducted within and under the conditions outlined herein or as may be established by the 

FAA as required by Section 333.

Exemption	sought:

SunSweep respectfully requests the grant of an exemption to the following specific sections of the Title 

14 Code of Federal Regulations (14 CFR) allowing it to operate lightweight UASs for commercial use:

§§ 61.23(a)(3); 61.101(e)(4) and (5); 61.113(a); 61.315(a); 91.7(a); 91.9 (b)(2); 91.119(c); 

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

Proposed	Aircraft:

If chosen for exemption, SunSweep will use the following sUAS to perform necessary operations:

 AirRobot AR200 (see Figure 1.0)

The AirRobot AR200 is a multi-rotor, vertical takeoff and landing, small UAS, with a gross weight of 

18.5 lb. With a maximum payload capacity of 7 lb., the maximum possible weight of the UAS (with 

infrared camera and other payloads attached) will be much less than 55 lb. The AR200’s maximum 

commanded airspeed, under GPS control, is 35 mph, with a cruise speed of 18 mph. The AR200 utilizes 

six maintenance-free brushless and gearless electric motors. With a modular payload concept, the AR200 
utilizes digital data transmission and control on a real-time basis. An example of what the flight path may 

look like, as well as the software used to operate the sUAS, can be found in the appendix (see figure 2.0).

AirRobot	AR200	Safety	Features:

Lost CC Uplink - User selectable. Under GPS – Wait 20 sec, Climb to highest altitude 

reached on way to current position, Turn towards Home (Take Off 

Position or Custom Position), Fly Home. ALTERNATIVE: Initiate auto 

landing. Without GPS availability -initiate auto landing.

Battery Failure - In case of battery failure, unit will initiate a slow (0.5 m/s) auto landing. 

Unit always preserves enough battery power to ensure safe landing with 

all sensors and stabilization systems working.

Processing and Stabilization - All processing for auto positioning and auto stabilization is built into the 

unit. The unit does not need radio communication to maintain this 

functionality. No processing is performed on the ground station. 

Waypoints are pre fed onto onboard memory.

Operator Error - Unit has envelope protection and does not allow maneuvers, which could 

lead to crash like over steering or exceeding maximum angle of 25 

degrees.

Safety Ring - Flexible protection ring allows for operation extremely close to subjects 

of interest without risk of damage to the rotors.

Black Box - All AirRobot systems have onboard flight data recorder (black box). 

Data is stored on MicroSD memory card. Data contains all flight relevant 

data, including Link quality, Orientation, Altitude, Speed, Direction and 

in addition battery status, engine rotation speed for each engine, GPS 

position. All data is time stamped with GPS time.

Public	Benefit:

Manned aircraft conducting aerial surveying operations can weigh thousands of pounds or more and are 

operated by an onboard pilot, in addition to other crewmembers as necessary. SunSweep will only use 

UASs that weigh less than 19 pounds. The pilot/operator will control the aircraft remotely, from a 

location on the ground. The aircraft’s light weight and the absence of an on-board pilot reduces the 

potential for personal harm or damage to property in the event of an accident or malfunction. 

The UAS is also an environmental benefit to the public. Seeing as it is purely electronically powered, no 

fossil fuels will be used, leading to the non-use of unrenewable resources and the elimination of harmful 

emissions or spillages.

Finally, the service that SunSweep plans on providing using the AR200 will positively benefit the 

public’s energy demands. Solar fields continue to provide an increasing amount of renewable, electric 
power to the public, however, the solar panels can malfunction or be damaged which leads to

inefficiencies in generating power. With the use of the AR200, SunSweep will identify these 

inefficiencies and allow for necessary repairs to be made in a timely fashion, leading to the most efficient 

solar power grid possible. 

Relief	sought and	reason	for	relief:

SunSweep intends to use a sUAS for commercial purposes, which will include thermal imaging of solar 

panels, and digital surveying of solar fields. This relief is sought because civil/commercial use of UASs is 

currently prohibited by FAA laws and regulations, unless granted an exemption. 

§61.23 (a) (3): Medical certificates: Requirement and duration

(a) Operations requiring a medical certificate. Except as provided in paragraphs (b) and (c) of this section, 

a person— (3) Must hold at least a third-class medical certificate— (i) When exercising the privileges of 

a private pilot certificate; (ii) When exercising the privileges of a recreational pilot certificate.

SunSweep may use a pilot with either their recreational or private pilot’s license. SunSweep believes that 

the herein proposed operations of the AR200 falls into the category of §61.23 (b), which does not require 

a medical certificate for operation, much like a sport pilot operating a balloon or glider. Because there 

will be minimal inherent medical risks during the operation of the aircraft – on private, unpopulated 

property, with only company employees being involved in operations – requiring the pilot to obtain a 

medical certificate beyond their appropriate operational tasks is not necessary. SunSweep’s pilot will 

maintain the appropriate medical certificate requirements in correspondence with the type of pilot’s 

license he/she holds. 

§61.101 (e) (4) and (5): Recreational pilot privileges and limitations

(e) Except as provided in paragraphs (d) and (i) of this section, a recreational pilot may not act as pilot in 

command of an aircraft— (4) For compensation or hire; (5) In furtherance of a business.

This regulation prevents someone with a recreational pilot’s license from operating an aircraft for 

compensation, or in the furtherance of a business. SunSweep seeks relief from this regulation so it can

hire or contract a qualified pilot to operate the AR200 for compensation. Concurrently, the pilot’s 

operation of the aircraft will contribute towards the furtherance of SunSweep as a for-profit entity. 

§61.113 (a): 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.

This regulation, much like the previous, prevents a person with a private pilot certificate from operating 

an aircraft for compensation as pilot in command of that aircraft. While SunSweep will not be using the 

AR200 to carry either passengers or property (only SunSweep-owned payload sensors), the pilot in 

command will be receiving compensation for their efforts. 
§61.315 (a): What are the privileges and limits of my sport pilot certificate?

(a) If you hold a sport pilot certificate you may act as pilot in command of a light-sport aircraft, except as 

specified in paragraph (c) of this section. 

(c) You may not act as pilot in command of a light-sport aircraft: (2) For compensation or hire. (3) In 

furtherance of a business.

Similar to rule §61.101, this regulation prevents a person with a sport pilot certificate from operating a 

light-sport aircraft for compensation for in the furtherance of a business. SunSweep may hire a pilot in 

command with a sport pilot certificate in order to operate the AR200. Therefore, exemption is sought so 

SunSweep may utilize the pilot’s skills to further the business, while compensating the pilot through 

payroll or contracted funds.

§91.7 (a): Civil aircraft airworthiness

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

This regulation states that no person may operate a civil aircraft unless it is in an airworthy condition. 

Because SunSweep intends to operate the AR200 without an airworthiness certificate, there will be no 

recognized FAA standard for determining airworthiness, merely the PIC’s judgement during inspection 

before flight operations. 

§91.9 (b) (2): Civil aircraft flight manual, marking, and placard requirements

b) No person may operate a U.S.-registered civil aircraft— (2) For which an Airplane or Rotorcraft Flight 

Manual is not 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.

This rule requires the on-board presence of a rotorcraft flight manual (seeing as the AR200 is a multirotor aircraft). SunSweep cannot comply with this requirement for the operation of the AR200 because 

the AR200 is too small to carry any information or approved materials on-board during operations. 

However, the AR200 comes with access to online manuals that provide instructions for the safe operation 

and maintenance of the aircraft. In addition, the pilot on the ground will maintain a hard copy of the 

aircraft operations manual, as well as documents regarding proposed flight patterns.

§91.119 (c): Minimum safe altitudes: General

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

altitudes: (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.

This requirement restricts the operation of an aircraft below 500 feet above surface level over areas that 

are not classified as congested areas. It does grant an exemption for the operation below 500 feet in areas 

over sparsely populated areas, as long as the aircraft remains 500 feet away from any persons or 

structures. In the case of SunSweep, all operations will take place in sparsely populated areas, on 

privately owned land. The maximum altitude of operation will remain below 500 feet AGL, and there will 

be instances when the AR200 will come within 500 feet or less of the PIC, other company personnel, and 

structures such as solar panel arrays. For example, the AR200 will be within inches or feet of the PIC 

during inspection and take-off, and most likely within 500 feet of the designated visual observer at all 
times during operation. In these instances, and any instances where the AR200 comes within 500 feet of 

employees not involved in the operation, a proper audio alert system will be used to notify any employees 

of the aircraft’s proximity, to ensure proper safety and operation. Due to the nature of the aerial data 

SunSweep will collect, it will be necessary to operate the AR200 anywhere between 10 and 400 feet away 

from a solar panel, which qualifies as a structure. For these reasons, SunSweep requests exemption. 

§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.

(b) The lowest usable flight level is determined by the atmospheric pressure in the area of operation as 

shown in the following table:

(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.

This regulation requires the operator of an aircraft not equipped with a radio to maintain a cruising 

altitude by referencing an altimeter that is set to the elevation of the departure airport or an appropriate 

altimeter setting. The AR200 is not equipped with an altimeter, but is instead controlled via GPS signals. 

The pilot in command will operate the aircraft using a hand-help control and visual displays – the altitude 

of the AR200 will be shown on a screen to the operator and thus referenced. SunSweep seeks an 

exemption for this reason. 

§91.151 (b): Fuel requirements for flight in VFR conditions

(a) No person may begin a flight in an aircraft 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.

This regulation requires that an aircraft carry enough fuel to reach the first point of its intended landing 

and fly for at least 30 minutes during daylight hours. The AR200 does not use gas but instead utilizes

electric power using Lithium polymer batteries of 34 V and 746 Wh capacity. The AR200 has a 

maximum endurance of 50 minutes using a full charge, and once drained the batteries have a recharging 

time of two hours for full capacity. If SunSweep was to follow this rule, it would only be able to operate 

for 20 of its total 50 minutes of battery charge in order to meet the required 30 minute cushion. For this 

reason, SunSweep seeks exemption in order to fly the AR200 for the maximum possible duration 

recommended in the operations manual, in order to collect the maximum possible data during the fewest 

number of flights, before returning it to charge. The aircraft will not be flown beyond its battery 

capability, allowing it ample time to safely return to its planned landing position – prior to full batter 

drain – to begin recharging. 
* §91.405 (a): 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.

* §91.407 (a) (1): 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— (1) It has been approved for return to service by a person authorized 

under §43.7 of this chapter.

* §91.409 (a) (1) and (2): Inspections

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

rebuilding, or alteration unless— (1) It has been approved for return to service by a person authorized 

under §43.7 of this chapter; and (2) The maintenance record entry required by §43.9 or §43.11, as 

applicable, of this chapter has been made.

* §91.417 (a) and (b): 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— (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.

* An exemption to these above regulations of required maintenance is sought because the above 

mentioned sections require an inspection either by an authorized person under 14 C.F.R. Part 43 or 

pursuant to the acquisition of an airworthiness certificate. SunSweep will be using the Pilot in Command 

to maintain and inspect the AR200 before, after, and between all flights, which includes visual inspection 
and pre-flight testing, rather than using an authorized agent (seeing as the UAS will lack an airworthiness 

certificate). The operator will comply with the operations manual provided by AirRobot regarding the 

proper maintenance and inspection of a small multi-rotored UAS. The operator will also keep records on 

flight operations and maintenance to the AR200, in accordance with the operations manual. In an event 

that maintenance is necessary, but operator maintenance is not advised, the aircraft will be sent back to 

AirRobot for servicing. 

Equivalent	Level	of	Safety:

SunSweep proposes operations of the AR200 under the following limitations, which provide at least an 

equivalent (or higher) level of operational safety to the current regulatory structure. Many of these 

limitations are referenced from Exemption No. 11800, Regulatory Docket No. FAA–2015–1020, because 

they are also applicable to the situation(s) proposed for exemption by SunSweep. 

 Safety will be the primary consideration during any operation of the AR200

 The operator is an FAA licensed pilot, and will be designated Pilot in Command whether 

operating or supervising the AR200. 

 Flights will be operated within the visual line of sight of the PIC or visual observer.

 The AR200 weighs less than 55 pounds in total, with payload.

 The aircraft will be operated strictly within Class G airspace during all operations, at a 

maximum altitude of 200 feet AGL (or below).

 Flights will be operated under visibility and cloud clearance requirements equivalent to 

Visual Flight Rules (VFR).

 The AR200 will strictly be flown during the hours between esunrise and sunset, with

night or inclement weather use. 

 Minimum crew for each operation will consist of the sUAS PIC and if necessary, a visual 

observer (VO). The visual observer and PIC will at all times be able to communicate by 

voice if both are operating.

 All personnel, including contractors in the arrays also carry UHF MURS radios to 

accommodate communications between flight team and site personnel at any time.

 There is no general public area over which the UAV would be flown, only privately 

owned land where the solar farms are located. All personnel who may be near the flight 

operation will be company employees.

 In the event that the minimum operating distance of 500’ from any unsheltered personnel 

is unable to be maintained, the operations will be immediately ceased as safely as 

possible. .All personnel will be briefed on the operational areas and associated hazards 

during daily job hazard analysis briefings.

 Prior to an AR200 flight, an area of operation will be established. This area of operation 

will include a defined lateral and vertical area, where the sUAS will operate. Safety 

procedures will be established for persons, property and applicable airspace within the 

area of operation.

 The sUAS aircraft used will utilize GPS navigation

 A briefing will be conducted in regard to the planned sUAS operations prior to operation 

at each new location. All personnel who will be performing duties within the boundaries 

of the area of operation will be present for this briefing.
 Written permission from the relevant property owners will be obtained prior to an 

operation.

 Prior to each flight, the PIC will inspect the AR200 to ensure it is in a condition for safe 

flight. If the inspection reveals a condition that affects the safe operation of the sUAS, the 

sUAS will not be operated until the necessary maintenance has been performed and the 

sUAS is found to be in a condition for safe flight. All maintenance and alterations will be 

properly documented in the aircraft records.

 The operator will follow the sUAS manufacturer’s aircraft/component, maintenance, 

overhaul, replacement, inspection, and life limit requirements.

 If multiple AR200’s are used in SunSweep’s services, each aircraft operated under this 

exemption will comply with all manufacturer Safety Bulletins.

Summary

SunSweep wishes to utilize Unmanned Aerial System technology to perform aerial imaging of solar fields 

with a commercial intent. The specific UAS that will be used in the AirRobot AR200, which, based on its 

official specifications, qualifies as a small UAS. SunSweep believes that the AR200’s size and speed, 

operating environment, limitations, and level of PIC’s experience provide an “equivalent level of safety” 

or better when operating a sUAS for the public interest as outlined in Section 333 in the FAA 

Modernization and Reform Act of 2012. It is requested that the FAA issue an exemption to permit safe, 

legal, commercial sUAS operation by SunSweep as soon as possible. The specific sections of the Title 14 

Code of Federal Regulations (14 CFR) that SunSweep requests exemption from are as listed below:

§§ 61.23(a)(3); 61.101(e)(4) and (5); 61.113(a); 61.315(a); 91.7(a); 91.9 (b)(2); 91.119(c); 

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

Thank you, 

Manny Teran

President and CEO

SunSweep / Aztera
Appendix:

Figure 1.0

Figure 2.0