December 17th, 2015 

U.S. Department of Transportation 

Docket Management System 

1200 New Jersey Avenue, SE Washington, DC 20590 

we define, design & deliver 

the places where you play, live & work 

pierson land works LLC 

www.piersonlandworks.com 

SUBJECT: Request for Exemption under Section 333 of the FAA Modernization and Reform Act of 2012 and Part 11 of 

the Federal Aviation Regulations from Certain Provisions of 14 C.F.R. 

Petition Summary 

Pursuant to Section 333 of the Federal Aviation Administration (FAA) Modernization and Reform Act of 

2012 (FMRA), Pierson Land Works, LLC (PLW) hereby petitions for expedited approval and exemption from FAA 

authorizing commercial operation of its small unmanned aircraft systems (sUAS) for remote sensing, aerial surveys, data 

and imagery collection for the industries and functions listed in Table 1. 

Table 1: Industries Served: 

Aerial Photography Mining 

Agriculture Planning & Asset Management 

Bridges & Roads Promotion & Marketing 

Engineering Services Real Estate & Land Development 

Environmental Monitoring Training & Education 

Inspections Transportation & Infrastructure 

Land Surveying Other Flight Operations 

If granted, the exemption would permit PLW to conduct commercial operations of small unmanned aircraft systems 

(sUAS) that meet or exceed operational and safety requirements set forth by Congress in Section 333. PLW is a land 

surveying, landscape architecture, GIS mapping, and land planning company based in Jackson, Wyoming, with satellite 

offices in Idaho Falls and Driggs, Idaho. Our staff members are highly trained and specialize in providing high-resolution, 

accurate spatial data and offer consulting services to our clients. PLW strives to provide innovative products to our 

clients who demand these types of services to accelerate in their industry. 

Unmanned Aerial Vehicle (UAV) technology and the data it can provide have become highly sought after in the land 

surveying industry. Traditional GPS data collection, available imagery, and surface models lack resolution and accuracy 

necessary for elite project planning, assessments and hazard identification. UAV collected data allows a consultant to 

depict the project area with greater accuracy, resolution and efficiency to better help clients with project design and 

analysis. Equally as important, the UAV aspect reduces the amount of time employees must spend in perilous 

environments. 

Given the technical specifications of the sUAS and the rural, sparsely populated environments of our workspace, PLW 

believes it is relevant to use the Academy of Model Aeronautics (AMA) rules to meet the required level of safety of all 

operations. The AMA has a proven track record in supervising operations conducted by operators using remote 

controlled aircrafts and provides the most relevant expertise in terms of providing safety guidelines for operators using 

ultra-light remote controlled aircraft. Operations will be conducted under controlled conditions in airspace that is 

limited, predetermined, and access controlled. 

PLW requests operations granted under like conditions and limitations set forth in previous, and similar, Section 333 

summary exemptions granted by FAA. 

wyoming office po box 1143 180 south willow street jackson, wy 83001 tel307.733.5429 fax 307.733.9669 

idaho offices 151 n. ridge ave., suite 117, idaho falls, id 83402 tel208.529.5429l pobox 680 driggs, id 83422 tel208.354.5429 

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Statutory Authority 

Section 333 (a) states that the FAA "shall determine if certain unmanned aircraft systems (UAS) may operate safely in 

the national airspace system before completion of the plan and rulemaking required by Section 332". Section 333 (b) 

then lists several factors that should be considered in determining which UAS' would be eligible for expedited 

integration into the National Airspace System (NAS). Specifically UAS' that "as a result of their size, weight, speed, 

operational capability, proximity to airports and populated areas, and operation within visual line of sight do not create 

a hazard to the users of the national airspace system or the public, or pose a threat to national security." If a UAS meets 

the criteria laid forth in Section 333 (b), Section 333 (c) FAA has the authority to decide if an airworthiness certification 

as specified by Title 49 United States Code, Section 44704 is required for operation. Section 333 (c) specifically states 

that the FAA can determine "whether a certificate of waiver, certificate of authorization, or airworthiness certification 

under section 44704 of Title 49, United States Code, is required for the operation of unmanned aircraft systems." Thus, 

the FAA has the ability to allow a UAS that meets the criteria put forth in Section 333 (b) to operate within the NAS 

without an airworthiness certification as long as the UAS does not pose any hazard or threat to the NAS, public, and 

national security. 

Request for Relief 

In meeting the aforementioned requirements, PLW requests relief and exemption from the regulations summarized 

below: 

14 C.F.R. 21 

14 C.F.R. 45.23 

14 C.F.R. 45.29 

14 C.F.R. 61.3 

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

14 C.F.R. 61.133 (a) & (b) 

14 C.F.R. 91.7 (a) & (b) 

14 C.F.R. 91.9 (b)(2) 

14 C.F.R. 91.103 (b) 

14 C.F.R. 91.109 (a) & 91.319 (a)(1) 

14 C.F.R. 91.119 

14 C.F.R. 91.121 

14 C.F.R. 91.151(a) 

14 C.F.R 91.203 (a) & (b) 

14 CFR Subpart E (91.401- 91.417) 

Unmanned Aircraft Systems 

PLW is requesting an exemption to operate a DJI Phantom 3 and Inspire, Trimble UX5 & UX5 HP and eBee senseFiy. 

PLW's sUAS proposed for operations through this request, all weigh less than 55 pounds, fly at speeds of no more than 

100 miles per hour (MPH), carry neither a pilot nor passenger, carry no explosive materials or flammable liquid fuels, 

and will operate within approved flight areas and heights through coordination and communication with the Flight 

Standards District Office (FSDO), Air Traffic Organization (ATO), air traffic control facilities and personnel, and any other 

entities or persons to satisfy terms set forth by the FAA for this exemption request. 

DJI Phantom 3 Professional & Inspire 

The DJI Phantom 3 Professional Quadcopter (P3P) and Inspire are vertical takeoff and landing (VTOL) Unmanned Aircraft 

Vehicles (UAV) with a Ground Control Station (GCS) utilizing electronic tablet or smart phone systems. 

The P3P is a small (23 x 23 inches) and ultra-light (maximum take-off weight of 2.82 lbs.) quadcopter made of lightweight 

plastic with a maximum speed of approximately 16.4 fps. The P3P performs pre-programmed precision aerial mapping 

missions with the on-board GPS and the related flight management software (DJI go) that allows the operator to plan 

safely and efficiently a mission in 3D, and monitor it in real-time. With an attached camera, the P3P takes a collection of 

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high-definition still images and video. It is equipped with four main rotors, powered by lithium polymer batteries 

manufactured by DJI. GPS and GLONASS combine to make the P3P completely aware of its location. It hovers precisely, 

moves accurately, and locks onto satellites faster and with the DJI GO app, we can track its location on a live map, and 

record the takeoff point so we can bring it back with the tap of a finger, providing us a worry-free flight experience. 

The OJ I Inspire's dimensions are 22 x 23 inches. It is lightweight and flexible built from carbon fiber and has a fully 

integrated intelligent battery powered system that virtually manages itself. When in flight, the battery power is shown 

live, indicating how long you can continue to fly. Advanced algorithms calculate the distance of your aircraft and 

estimated time to return home, letting you know when it's time to fly back. It is also equipped with an Inertial 

Measurement Unit (IMU), which keeps the Inspire stable and steady during flight. The IMU incorporates both a 6-axis 

gyroscope and an accelerometer to monitor miniscule changes in tilt and movement. This allows the aircraft to 

compensate and adjust immediately, holding its position at all times. The Inspire 1 can be placed on autopilot when 

needed. lfthe battery runs low or connection with the remote is lost, the inspire uses its positioning system and smart 

flight technology to return back to home. 

The following is representative of failsafe emergency procedures available with both of the DJI sUAV's. 

• Loss of Communication: If the communication link with the PIC/operators ground control station is lost, the 

platforms will initiate a return to home mode after three seconds of transmission loss. 

• Low Battery: Initiated automatically based on remaining battery life, altitude, and distance from home pointwhen the battery level is low a warning alerts the PIC/operator and the aircraft will automatically begin a return 

to home procedure. 

• Loss of GPS: Losing a GPS signal while flying autonomously will trigger the aircraft to hover using on board 

altitude sensing. The PIC can then land the aircraft as soon as possible. 

DJI is a global leader in the sUAS market with thousands oftheir products in use for professional and recreational 

purposes. Given their extensive use and reliability, PLW asserts that the P3P and Inspire platforms can operate safely in 

the National Airspace System {NAS) through their appropriate use and operations in accordance with PLW's training and 

operating parameters. 

The Petitioner has supplied the following additional Information as appendices for consideration of this request: 

• DJI Phantom 3 Professional User Manual (Appendix A) 

• DJI Phantom 3 Professional Intelligent Flight Battery Safety Guidelines (Appendix A) 

• DJI Phantom 3 Professional Safety Guidelines (Appendix A) 

• Inspire 1 User Manual (Appendix B) 

• Inspire 1 Safety Guidelines (Appendix B) 

• Inspire 11ntelligent Flight Battery Safety Guidelines {Appendix B) 

• Inspire 1 Maintenance Manual (Appendix B) 

Trimble UXS/UXS HP 

The Trimble UXS/UXS HP are small (39 inches by 26 inches) and light weight (5.51lbs) fixed wing UAS's built with foam 

and carbon frame materials. They are catapult launched and require no runway for take-off or landing. The Trimble 

UXS and UXS HP set the standard for fast and safe aerial data collection by offering a complete system with powerful 

technologies such as a robust design, a radically simplified workflow and reversed thrust & automatic failsafe 

procedures. The UXS/UXS HP has extensive flight experience and a history of operational success. 

The UXS/UXS HP functions primarily to provide aerial imagery and remote sensing capabilities using one of a selection of 

interchangeable camera lenses. High resolution imagery enable data collection, extraction, and analysis from imagery 

produced by the camera with application to numerous industries such as surveying, architecture, engineering, 

agriculture, planning, and transportation. Information gleaned from the imagery will help in countless ways like 

maximizing crop yields, improving response times and coordination following natural disasters, enhanced decision 

making and overall efficiencies among several industries ranging from real estate, planning, asset management, and 

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more important, will provide us with higher quality data compared to what is available to us now. Practically 

speaking, all of these provide great benefit to the economy and the overall public. 

Prior to each flight, the Pilot in Command {PIC) will set dimensions of a designated flight area and relevant flight 

parameters to ensure the UXS/UXS HP operates within the lateral, not to exceed visual line- of-sight {VLOS), and vertical, 

not to exceed 400 feet AGL, geographic limits of an approved site for operation. In the event a critical issue is detected 

i.e: a low battery state or loss of data link, the UXS/UXS HP will immediately initiate a return-to-launch/home sequence. 

Each of the sUAS platforms described above is equipped with advanced sensors and high definition cameras. They also 

have built-in capabilities to limit flight altitude above ground level {AGL) and the radius distance flown from the 

pilot/operator. 

In addition, each of the UXS/UXS HP's integrated safety features designed to help ensure the safety of persons and 

property within and surrounding an active operation area. For instance, as described above, if one of the aircraft loses 

communication with its ground control station or global positioning system {GPS) the aircraft can autonomously return 

to a pre-determined location. 

The Petitioner has supplied the following additional Information as appendices for consideration of this request: 

• Trimble UXS Aerial Imaging User Guide (Appendix C) 

• Trimble UXS Data Sheet (Appendix C) 

• Trimble UXS HP Data Sheet (Appendix C) 

eBee senseFiy 

The eBee is a small {37.8 inches wingspan) and ultra-light (maximum take-off weight of 1.7 pounds) platform made of 

flexible foam that performs pre-programmed precision aerial mapping missions thanks to the on-board GPS and the 

related flight management software (eMotion). eMotion allows the operator to plan safely and efficiently a mission in 

3D, and then monitors it in real-time. The embedded camera, protected by a foam envelope takes a collection of highdefinition still images that are used later to generate maps and contour lines of the surveyed area. 

The four main characteristics ofthe eBee are: 

• Very light weight: The ebee is so light that the PIC can launch it by hand and it will land on almost any surface 

without requiring a parachute or landing net. Its low impact energy also significantly reduces the risk of 

hazardous situations. The wings of the eBee are detachable and made of flexible foam with no sharp or hard 

edges and almost no internal strengthening structure. 

• Electric-Powered: The eBee is electric powered. The propeller is attached with a rubber band to the body of the 

plane so that it can easily flex away in case of contact with any object. The engine is silent and reliable. 

• Semi-Automatic Flight: The artificial intelligence incorporated within the eBee autopilot system continuously 

analyzes data from the Inertial Measurement Unit and from the on board GPS and takes care of all of the 

aspects of the flight under the supervision of the operator. 

• Option for Manual Control: The eBee provides an override capability that allows the operator to take manual 

actions during the flight {Go to Home, Go Land, Hold, and Resume the mission) and also suspend automated 

operations and take manual control of the aircraft should it become necessary to respond in an emergent 

circumstance, thanks to the ground control station provided with the system. 

The Petitioner has supplied the following additional Information as appendices for consideration of this request: 

• eBee senseFiy User Manual (Appendix D) 

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Aircraft Marking 

Each of PLW's sUAS will be identified by a serial number, registered in accordance with 14 C.F.R. Part 47, and have an 

identification (N-Number) marking displayed as large as practicable in accordance with 14 C.F.R. Part 45. 

Pre-flight Inspection, Maintenance 

Before each flight a PLW PIC will perform a series of pre-flight and takeoff checks as defined by the manufacturer noted 

in the Appendices provided. 

Routine inspection of all aircraft components, including, but not limited to the items listed below will take place: 

• Motors, wiring and connectors 

• Propellers, smooth (no chips) 

• Batteries, wiring and connectors 

• Remote command and control 

• Ground control station 

UAS Operating Parameters 

PLW PICs and visual observers, present during any and all flights, will ensure all operation remain within VLOS. Flights 

will be limited to 400 feet AGL- which is accurately measured by GPS. PLW's sUAS operators and PICs are well 

equipped and trained for operations sought in this exemption. 

Communication and coordination with the appropriate FSDO will take place prior to operations, as needed. Further 

coordination will take place, as required, with the Air Traffic Organization to obtain a Certificate of Authorization (COA) 

prior to any operations granted in this requested exemption. PLW's sUAS will not operate within 5 nautical miles of an 

airport reference point (ARP) as denoted in the current FAA Airport/Facility Directory (AFD) or for airports not denoted 

with an ARP, the center of the airport symbol as denoted on the current FAA published aeronautical chart, unless a 

letter of agreement with that airport's management is obtained or otherwise permitted by a COA issued to the 

exemption holder. The letter of agreement with the airport management must be made available to the Administrator 

or any law enforcement official upon request. 

PLW's sUAS operations will remain clear and yield to the right of way of all manned aircraft operations and activities 

(including, but not limited to, ultralight vehicles, parachute activities, parasailing activities, and hangliders). 

Additionally, a grant of the exemption to PLW to operate their sUAS will be subject to the following operating 

conditions. These are based in part on the operating conditions set forth by the Academy of Model Aeronautics. 

• Operations to be conducted over private, controlled-access, or public property where approved; 

• Permission from the land owner/authority required before commencing any flight; 

• Operations over congested areas shall be avoided to the extent possible; 

• Operations must not interfere with manned aircraft operations, must yield the right of way to manned aircraft, 

and operators must See & Avoid other aircraft and obstacles at all times; 

• Operations limited to Visual Flight Rules Meteorological Conditions (VMC) and daylight hours 

• Aircraft operations must remain within Visual Line of Sight (VLOS) and will be visually monitored by the PIC 

and/or Visual Observer at all times; 

• All operations conducted within 5 miles from an airport shall only be initiated after verbal coordination with the 

airport authority, or air traffic control when a control tower is present at the airport; 

Pilot in Command (PIC) 

Any PLW PIC/operator under this grant of exemption will hold, at a minimum, a sport pilot certificate. The PIC must also 

hold a current FAA airman medical certificate or a valid U.S. driver's license issued by a state, the District of Colombia, 

Puerto Rico, a territory, a possession, or the Federal government. The PIC will also meet flight review requirements 

specified in 14 CFR § 61.56 in an aircraft in which the PIC is rated on his or her pilot certificate. 

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Regarding PLW's requested relief from 14 C.F.R. § 91.103(b)(1), the unmanned aircraft PIC/operator will comply with 

applicable procedures and requirements stated in§ 91.103{a) and (b). Specifically, PLW PIC/operators will initiate all 

necessary actions including review of weather conditions, flight time and battery requirements, aircraft performance 

data, and landing and takeoff distances before each flight. Any site-specific conditions will also be planned and 

considered during preflight procedures and considerations. 

Radio Frequencies 

Radio frequencies used will be those allotted by the Federal Communications Commission (FCC) for data transmission 

and vehicle control in unlicensed frequency bands. All devices used will comply with FCC usage and emissions 

regulations. 

Safety and Benefits of the UAS 

PLW plans to operate their sUAS in a variety of applications that generally would require flying expensive, full-size 

manned aircraft to successfully conduct a mission or project. 

Small, light, unmanned aircraft vehicles and their systems offer countless benefits over the use of full- sized manned 

aircraft to numerous industries leveraging products from aerial surveys, remote sensing, data and imagery collection. 

Replacing significantly larger manned aircraft carrying flights crews and flammable fuel with sUAS that do not carry 

people creates a much greater margin of safety for sUAS operators and visual observers by contrast to a manned 

aircrafts flight crew and passengers. The lower acquisition, operational, and personnel costs, in addition to reduced 

environmental impacts such as reduced noise and emissions, through the use of batteries for power- in lieu of fuel and 

combustion engines, are reasons why it is beneficial to the public for PLW to receive FAA authorization to operate its 

unmanned aircraft. 

Conclusion 

For the foregoing reasons, and public benefit, the exemption requested herein should be granted and PLW permitted to 

conduct small UAS operations in accordance with its manuals and all other operating parameters deemed necessary and 

appropriate by the FAA. 

Respectfully, 

Scott R. Pierson, PLS, President 

Pierson Land Works, LLC 

PO Box 1143 

Jackson, Wyoming 83001 

307.733.5429 

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PIERSON LAND WORKS, LLC: EXEMPTION REQUESTS AND EQUIVALENT LEVEL OF SAFETY 

SHOWINGS UNDER APPLICABLE RULES SUBJECT TO EXEMPTION 

PLW requests an exemption from the following regulations as well as any additional regulations that may technically 

apply to the operation of the sUAS: 

14 C.F.R. Part 21, Subpart H: Airworthiness Certificates 

14 CFR § 91.203(a)(1) 

Section 91.203 requires all civil aircraft to have a certificate of airworthiness. Part 21, Subpart H, entitled Airworthiness 

Certificates, establishes the procedural requirements for the issuance of airworthiness certificates as required by FAR§ 

91.203(a). Given the size of the sUAS's, their weight (the maximum take-off weight is 5.51 pounds) and the limited 

operating area associated with their utilization, it is unnecessary to go through the certificate of airworthiness process 

under Part 21 Subpart H in order to achieve or exceed current safety levels. 

Such an exemption meets the requirements of an equivalent level of safety under Part 11 and Section 333 of the Reform 

Act. The Federal Aviation Act and Section 333 of the Reform Act both authorize the FAA to exempt aircraft from the 

requirement for an airworthiness certificate, upon consideration of the size, weight, speed, operational capability, and 

proximity to airports and populated areas of the UAS involved. An analysis of these different criteria demonstrates that 

the sUAS operated without an airworthiness certificate, under the conditions proposed in that exemption, will be at 

least as safe, or safer, than a conventional aircraft with an airworthiness certificate. A proprietary risk assessment for 

operations with the sUAS, which demonstrates that assertion, is also being submitted to the FAA as part of this 

application. PLW requests the FAA treat the sUAS risk assessment as proprietary under 14 C.F.R. 11.35(b) and not 

include this document in the public docket. 

14 C.F.R. § 45.23 & 14 C.F.R. § 45.29: Display of marks; size of marks 

These regulations provide that each aircraft must display "N" and the aircraft's registration number in letters at 

least 3 inches high. Additionally, the aircraft must display the word "EXPERIMENTAL" in letters at least 2 inches high 

near the entrance to the cabin, cockpit, or pilot station. 

Given the size of the sUAS, this requirement is impossible to match. 

14 C.F.R. § 61.3: Requirements for certificates, ratings and authorizations 

14 C.F.R. § 61.113(a) & (b); 61.133(a): Private Pilot Privileges and Limitations; Pilot in Command; Commercial Pilot 

Privileges and Limitations 

The regulation provides that no person may serve as a required pilot flight crewmember of a civil aircraft of the United 

States, unless that person: 

(1) Has a pilot certificate or special purpose pilot authorization issued under this part in that person's physical possession 

or readily accessible in the aircraft when exercising the privileges of that pilot certificate or authorization. However, 

when the aircraft is operated within a foreign country, a pilot license issued by that country may be used. 

The regulation provides also that no person that holds a private pilot certificate may act as pilot in command of an 

aircraft for compensation or hire. Subparagraph (b) allows a private pilot to act as pilot in command of an aircraft in 

connection with any business or employment if: 

(1) The flight is only incidental to that business or employment; 

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

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Given the safety features of the sUAS and the fact that the missions are pre-programmed and monitored in real-time 

with a specific flight management software, PLW proposes that operators of the sUAS should not be required to hold a 

commercial pilot certification. Instead, operators should be required to: 

Have at a minimum a sport or recreational pilot license, and be familiar with the operation and safety guidelines 

provided by respective UAS's manufacturers. 

14 C.F.R. § 91.7(a) and (b): 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 an unairworthy mechanical, electrical, or structural 

condition occurs. 

Sections 91.7 (a) and (b) prohibit operation of a civil aircraft unless it is in airworthy condition. PLW requests an 

exemption from this regulation because their sUAS would not operate with an airworthiness certificate under the 

proposal set forth in this filing. Given the size of the aircraft and requirements contained in the manuals for 

maintenance and use of safety check lists prior to each flight, as set forth in in the operators manual, an equivalent level 

of safety will be provided. 

The FAA has issued similar exemptions to this regulation, including to Tradecraft LLC, Exemption No. 11303. 

14 C.F.R. § 91.9(b)(2): Civil aircraft flight manual, marking, and placard requirements. 

This regulation provides that no person may operate an aircraft unless a current, approved flight manual is in the 

aircraft. PLW assumes that the intent of this requirement is to ensure that flight manual information is available to the 

aircrew while operating the aircraft. PLW requests an exemption to this requirement since the aircraft is not only too 

small to carry documentation; the documentation would not be available to the crew. 

The equivalent level of safety will be achieved by keeping a hard copy of the flight manual in the sUAS transportation 

box. 

14 C.F.R. § 91.103 (b): Preflight Action 

This regulation requires each pilot in command take certain actions before flight to ensure the safety of the flight. An 

exemption is needed from this requirement, as the pilot will take separate preflight actions, including checking for 

weather conditions and checking flight battery, and all other actions in the Operating Manual and safety checklists that 

accompany the sUAS's. These actions will provide an equivalent level of safety. 

14 C.F.R. § 91.109(a) & 91.319(a)(1): Flight Instruction 

The regulation provides that "No person may operate a civil aircraft that is being used for flight instruction unless that 

aircraft has fully functioning dual controls." 

Flight instruction will be accomplished through an elaborated training program, using first the simulation mode of the 

flight management software. The equivalent level of safety during the training will be achieved by the manufacturer or 

authorized distributor providing the training and through the use of experienced and qualified operators familiar with 

the sUAS. 

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14 CFR § 91.119: Minimum Safe Altitudes 

The regulation provides that over sparsely populated areas the aircraft cannot be operated closer than 500 feet to any 

person, vessel, vehicle, or structure. Since the aircraft will be operating at a maximum of 400 feet AGL, the sUAS cannot 

comply with this requirement. 

The equivalent level of safety will be achieved because the sUAS will only fly over private property with the permission 

of the landowner. The operator will define before every flight a working area radius and a flight area ceiling, preventing 

the sUAS to go beyond the flight area. 

The landowner and the persons who may be on the ground in the flight area will be briefed of the expected route of 

flight and the associated risks to persons and property on the ground. Due to the small size ofthe sUAS and the material 

with which the sUAS is built, the hazard to persons, vessels, vehicles, and structures is not comparable to manned 

aircraft and should be considered in granting the exemption. 

Moreover, the aircraft will not be operated over congested areas or over any open-air assembly of persons. The aircraft 

will be operated at an altitude allowing, if a power unit fails, an emergency landing without undue hazard to persons or 

property on the surface. 

14 CFR 91.121 -Altimeter settings 

This section requires that 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 below 18,000 feet MSL to: 

• The current reported altimeter setting of a station along the route and within 100 nautical miles of the aircraft; 

• 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; 

• 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. 

To provide an equivalent level of safety, the UAS's autopilot calculates the reference altitude (ground level) with the onboard GPS during the pre-flight tests. The GPS and barometer data are merged with respect to their respective 

precisions. The GPS provides reliable information to correct potential barometric bias, while rapid variations in altitude 

are detected through the barometer. Hence, barometric bias induced by environmental factors is rejected. 

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

The regulation provides that no person may begin a flight in an airplane under day-vFR conditions unless there is enough 

fuel to fly to the first point of intended landing and to fly after that for at least 30 minutes. 

Given the area of operation for the sUAS, PLW believes that an equivalent level of safety is already achieved with the 

specific procedure preventing the sUAS to accept a take-off order when the battery level is below a given value. 

Moreover, the sUAS have integrated "low" and "critical" battery level warnings and implement a "return to Home" 

(and "Go Land") actions in these situations. 

The Phantom and Inspire series battery life provides at most 25 minutes of powered flight. Without an exemption from 

14 C.F.R. §91.151, flights would be limited to 5 minutes or less. 

Given the limitations on PLW's proposed operations, a lesser reserve for flight in VFR conditions is reasonable. PLW 

believes that an exemption from 14 C.F.R. § 91.151 (a) is safe and consistent with the scope of a prior exemption. See 

Exemption 10673 (allowing Lockheed Martin Corporation to operate without compliance with 91.151 (a)). Operating the 

Phantom and Inspire sUAS without 20 minutes of reserve fuel does not produce the type of risks Section 91.151 (a) 

intended to prevent. Given its weight and construction material, the risks are less then contemplated by the current 

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regulation. PLW believes that an equivalent level of safety can be achieved by the fact that their sUAS can safely utilize 

VTOL capability to quickly and safely land within 3 minutes of an area within VLOS once alerted of a low battery. 

Similar exemptions have been granted to others, including Exemptions 2689F, 5745, 10673, and 10808. 

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

This regulation provides as follows: 

• No person may operate a civil aircraft unless it has an appropriate and current airworthiness certificate. 

• 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. 

The sUAS's all weigh under 5.511bs, (max take-off weight). As such, there is no ability or place to carry certification and 

registration documents or to display them on the UAS. In addition, there is no pilot or passengers on board the aircraft. 

To obtain an equivalent level of safety and meet the intent of 91.203, PLW proposes that documents deemed 

appropriate for this aircraft by the FAA will be co-located with the operator at the ground control station and at our 

office, available for inspection upon request. 

14 CFR Subpart E (91.401- 91.417}- Maintenance, Preventive Maintenance, and Alterations 

The regulation provides that the operator is primarily responsible for maintaining the aircraft in an airworthy condition, 

including compliance with Parts 39 and 43. Paragraphs 91.407 and 91.409 require that the aircraft be "approved for 

return to service by a person authorized under 43.7" after maintenance and inspection. Section 91.409(a)(2) requires an 

annual inspection for the issuance of an airworthiness certificate. Section 91.417(a) requires the owner or operator to 

keep records showing certain maintenance work that has been accomplished by certificated mechanics, under Part 43, 

or licensed pilots and records of approval of the aircraft for return to service. 

PLW proposes that the maintenance of the sUAS's will be accomplished by the owner/operator according to the 

maintenance manual, provided by the sUAS's manufacturers. PLW requests the FAA treat the sUAS training program as 

proprietary under 14 C.F.R. 11.35(b) and not include this document in the public docket. 

An equivalent level of safety will be achieved because the sUAS are small in size, not complex mechanical devices, 

carries no external payload, and will operate only in restricted predetermined areas. Moreover, the operator is the 

person most familiar with the aircraft and is best suited to maintain the aircraft in an airworthy condition and to ensure 

an equivalent level of safety. Finally, before every flight, the sUAS runs automatically a sequence of pre-flight tests to 

make sure that every sensor and every critical part is running properly. If a problem is detected, the sUAS will not be 

able to be switched-on and a message error is displayed on the main screen of the flight management software. The 

operator can then refer to the maintenance manual to troubleshoot this issue. 

Similar exemptions have been granted to others such as TradeCraft, Exemption 11303, Toledo Aerial 

Media, Exemption 11288, and Skyphilly, Exemption 11256. 

10 I Page 
Appendix A- DJI Phantom 3 Professional 

• User Manual: 

https://dl.d jicdn.com/ downloads/phantom 3/ en/ Phantom 3 Professional User Manual Vl.G.pdf 

• Flight Battery Safety Guidelines: 

http://dl.diicdn.com/downloads/phantom 3/en/Phantom 3 Intelligent Flight Battery Safety Guidelines en . 

.Pf!f 

• Safety Guidelines: 

• http://dl.djicdn.com/downloads/phantom 3/ en/Safety Guidelines Disclaimer en 201509.pdf 

Appendix B- DJI Inspire 1 

• User Manual: 

https://dl.diicdn.com/downloads/inspire 1/en/lnspire%20 1 User Manual Vl.8.pdf 

• Safety Guidelines: 

http://dl.djicdn.com/downloads/inspire 1/en/lnspire 1 Safety Guidelines and Disclaimer vl.2 en.pdf 

• Flight Battery Safety Guidelines: 

http://dl.djicdn.com/downloads/inspire lien/Intelligent Flight Battery Safety Guidelines en.pdf 

• Maintenance Manual: 

http://dl.djicdn.com/downloads/inspire 1/en/lnspire 1 Maintenance ManuaiVl.O en.pdf 

Appendix C- Trimble UXS/UXSHP 

• UX5 Aerial Imaging User Guide 

http://kmcgeo.com/Products/Gatewing/UX5AeriallmagingUserGuide lOOA.pdf 

• UX5 Data Sheet: 

http://uas.trimble.com/sites/default/files/downloads/022543-576b trimbleux5 ds 0615 lr l.pdf 

• UX5HP Data Sheet: 

http://uas.trimble.com/sites/default/files/downloads/022516-131e trimbleuxS hp ds a4 1115 lr.pdf 

Appendix D- eBee senseFiy 

eBee senseFiy Manual 

• http://www.manualslib.com/manuai/944170/Sensefly-Ebee.html 

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