August 27, 2015

U.S. Department of Transportation

Docket Management System

1200 New Jersey Avenue, SE

Washington, DC 20590

Re: Request for exemption from multiple regulatory provisions to allow the

use of small unmanned aerial systems on land controlled by clients of 

Unknown Drones, LLC. to assist in the safe evaluation of infrastructure and

operations for our clients.

Unknown Drones, LLC. respectfully requests an exemption from several

provisions of Title 14 of the Code of Federal Regulations (C.F.R.) to permit the 

use of small unmanned aerial systems (sUAS) to assist in the evaluation of 

infrastructure and operations for our clients. This request is motivated primarily

by the desire to maximize safety in infrastructure and operations. While an

exemption would not eliminate the current need for in-person visual inspection

required by various federal regulatory departments, it would allow Unknown 

Drones, LLC. to broadly evaluate assets and operations with sUAS, resulting in

a safer and more efficient infrastructure network. Accordingly, the grant of an

exemption is consistent with Congress’ intent, reflected in Section 333 of the

FAA Modernization and Reform Act of 2012 (Modernization Act) that safe

systems be permitted in the national airspace prior to the issuance of final

regulations governing general use of these systems.

The name and contact information of the applicant are:

Robert W. Hammers

Unknown Drones, LLC

9924 HWY 79 E

Henderson, Texas 75652

(903) 720-8931

unknowndrones@yahoo.com
Background Information

Unknown Drones, LLC. is in the business of providing aerial imaging to perform site 

inspections and photographs and videos to various companies. 

Infrastructure Safety Inspection Operations: 

Utility Inspection

Railroad Inspection

Pipeline Inspection Oil-Field Inspection 

Petro/Chemical/Manufacturing Inspection 

Construction Site Inspection

Agriculture Inspection

As part of this Unknown Drones, LLC. is requesting FAA Exemption for sUAS operations

for safety, inspection and video capture usage.

Regulatory Basis for Exemption Request

In addition to the waiver authority provided in §333 of the Modernization Act, the FAA may

grant an exemption under 49 U.S.C. §44701(f) if it has determined that such an exemption is in

the public interest. The FAA has imposed a separate requirement in its procedural regulations,

providing that the petitioner shall explain why granting the exemption would not adversely

affect safety or how the exemption would provide at least an equivalent level of safety as

compliance with the underlying regulation. In this case, approval of this exemption would

advance the public interest by significantly enhancing the safety and efficiency of infrastructure

operations and by providing the FAA with valuable user experience on sUAS in a context with

appreciable economic and societal benefits. As described more fully below, the requested

exemption would permit the operation of sUAS under tightly controlled conditions, thus

ensuring that operations will not have an adverse impact on safety. To the contrary, as explained

below, Unknown Drones, LLC. anticipates that use of sUAS will enhance safety in

infrastructure operations. Granting an Exemption is in the Public Interest. The safety and

efficiency of infrastructure operations is heavily dependent upon constant analysis of assets,

right-of-way, infrastructure and other assets/facilities. There are a wide variety of factors that

can affect conditions and cause problems for infrastructure. Even relatively small objects or 

minor failures can lead to accidents or other incidents causing downtime of infrastructure.

Extreme weather events can lead to flooding or overheating infrastructure. For example

earthquakes, landslides, and abandoned vehicles at grade crossings can block infrastructure. The 

potential for sabotage and terrorism – or even just trespassing – are also among the many risks

that modern infrastructure faces.

As a result, pursuant to federal regulations and company policy, our client’s maintenance 

employees routinely inspect the infrastructure, such as bridges, tunnels, support structures, and

signals. At present, this work is done primarily by company personnel in motor vehicles, on 

foot, in specialized equipment. This is often a labor-intensive and sometimes arduous job.

While our clients do all they can to make these inspections as safe as possible, there is an

irreducible element of risk involved whenever employees are required to go out on structures.

Employees may need to climb over or onto structures, which can be slippery, rough, and/or
exposed to the elements. Some structures, such as bridges, are high above the ground. 

Equipment moving through inspection zones can increase risk as well, especially in high-traffic

areas. While the use of sUAS for supplemental infrastructure and general asset evaluation

would not eliminate

these risks entirely (as it is an additive safety measure), it would reduce the risks to 

employees by allowing for remote aerial review.

Additionally, the sheer amount of assets and the widely dispersed locations – in many instances

far from sizeable population centers – means that visual inspection in all instances by company

personnel can be inefficient. Aerial analysis by traditional fixed wing aircraft is impractical

because the required altitudes for safe flight reduce visibility below meaningful levels – it is

simply not possible to see all asset anomalies from such heights. Helicopters present better

vantage points; however manned helicopters are much more costly, subject to human safety and

carry highly explosive jet fuel making them impractical for deployment. By using sUAS for 

supplemental asset evaluation, Unknown Drones, LLC. will be able to substantially upgrade its

capacity to detect and address issues with the right-of-way and other assets before they become

a problem for safe operations. Thus, the use of sUAS has the potential to improve efficiency,

resulting in faster and safer delivery of goods, energy & natural resources vital to the U.S. 

economy.

Granting an Exemption will not Adversely Affect Safety

Unknown Drones, LLC. notes that there is no applicable standard for an equivalency

determination. Some have argued that the appropriate standard is that for model aircraft, noting

that their operations, if conducted for recreational purposes, would fall completely within the 

allowable operations for model aircraft. We believe it is difficult to argue that there is sufficient

correlation between model operations controlled by the Academy of Model Aeronautics and the

ones contemplated by Unknown Drones, LLC. At the same time, it is clear that equivalency

cannot be established for traditional, manned civil aircraft because the design and use profiles

between traditional aircraft and sUAS are simply too different. As such, we believe it makes

more sense to focus on why the contemplated operations would not adversely affect safety,

which is all that §11.81(e) requires.

Granting an exemption will not adversely affect safety. Unknown Drones, LLC. contemplates

conducting sUAS operations over client owned or controlled land, solely during daylight

hours, at altitudes well below that which would pose a risk to other aircraft. In general, sUAS 

operations are intended to be conducted in areas distant from both congested areas and 

airports. Moreover, because of the inherent risks presented by standard infrastructure 

operations, our clients have already taken steps to secure property against unauthorized public

access. For example, substantial stretches of pipeline, utilities, railroad track and oil

production sites are fenced, elevated, or otherwise secured to prevent access. Other long

stretches of infrastructure are, as noted above, in very remote wilderness areas. The nature of 

operations anticipated by Unknown Drones, LLC. requires that the sUAS be flown at

relatively low altitudes and relatively low speeds. Unknown Drones, LLC. expects that in

most instances, the sUAS will be flown less than 75 feet from the highest structure along the

path of the sUAS. Accordingly, the risk of interference with another aircraft is minimal.

Unknown Drones, LLC. also plans to conduct sUAS operations at least three miles from any

public airports (including heliports). In the event an operation needs to be conducted closer to
an airport, Unknown Drones, LLC. will inform the airport operator and airport air traffic

control tower of the contemplated operation and will comply with any directions issued by air

traffic control at that airport.

Approval of exemptions allowing commercial operations of sUASs in the infrastructure aerial

inspection industry will enhance safety by reducing risk. Conventional operations, 

using jet or piston power aircraft, operate at extremely low altitudes just feet from the subject

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

associated with vehicles that weigh in the neighborhood of 4,000lbs., carrying large amounts

of jet A or other fuel (140 gallons for jet helicopters). Such aircraft must fly to and from the

inspection site. In contrast, a sUAS weighing fewer than 55 lbs. and powered by batteries

eliminates virtually all of that risk given the reduced mass and lack of combustible fuel carried

on board. The sUAS is carried to the inspection site. The sUAS will carry no passengers or 

crew and, therefore, will not expose them to the risks associated with manned aircraft flights.

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

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

exemptions requested herein, including 333 Aircraft Exemption Status exempting the applicant

from conventional aircraft requirements and allowing commercial operations. These

lightweight aircraft operate at slow speeds, close to the ground, and in a controlled

environment and, as a result, are far safer than conventional operations conducted with turbine

helicopters operating in close proximity to the ground and people.

The safety of those on the ground is protected by the fact that no one will be allowed into the

area without the permission of the company. Security will be established for the flight area as

part of the pre-flight control. Each individual within the secure area will be

briefed prior to flight and will consent to being in the area. All others will be excluded

from the area.

Unknown Drones, LLC. initially intends to use a dedicated staff for sUAS operations. All

operations will be within visual line-of-sight (i.e., no more than approximately 0.5 miles from

the manipulator of the controls, or pilot in command (PIC)). Each PIC will conduct at least 

three take-offs and landings with the sUAS on which he or she is trained every 90 days. PIC’s 

will establish their qualifications thru a combination of aeronautical knowledge, UAS

airmanship skills, and verification through testing of flight ability before infrastructures

operations have commenced. Depending on the type of operation, additional ground-based

visual observers may be employed as well. These observers will be within constant visual line

of sight and in constant contact with the PIC. The visual observers will assist the PIC in

avoiding objects near the sUAS.

There are no standards for either Private or Commercial sUAS pilot certificates. The safe 

operation and control of the UAS as described in this application does not depend on the type

of FAA license held by the PIC. Given the restricted and controlled airspace within which

operations will take place, the key factors needed by the PIC are knowledge of the airspace

within which the operation will take place and how that airspace fits into the National Airspace
System (NAS). That knowledge can be and is gained primarily

through ground school and not through flight training in fixed wing or rotor aircraft, nor

is it dependent on the acquisition of a commercial or private pilot’s certificate. Those 

certificates demonstrate knowledge of the factors and skills needed for the safe operation of 

those types of aircraft (fixed wing or rotorcraft). It cannot be assumed that a commercial pilot,

approved to operate a helicopter or fixed wing aircraft, has the skill or ability to safely operate a

small unmanned aerial vehicle, operating at 400 AGL or lower, within strictly controlled preapproved airspace. Besides knowledge of airspace regulations, dexterity in the control and

operation of the sUAS acquired from actual operation of the aircraft is the most important

factor in establishing an equivalent level of safety.

If the PIC has acquired the necessary knowledge of airspace requirements, the relevant issues

are (1) where the aircraft will be flown, (2) the size of the aircraft relative to what is being used

today to accomplish the same mission, and (3) what precautions will be taken to ensure the

safety of those in the area of operation. We propose that the PIC has at least an FAA Private

Pilots Certificate and a Class III medical; the aircraft be operated within a secure environment;

and that no one be allowed to enter the secure environment unless they are part of the

operation, have been fully briefed of the risks prior to operation of the sUAS, and have

consented to the risks associated with being in the operating area. Should there be a mishap, the

sUAS being flown pose significantly less of a threat than the helicopters and fixed wing

aircraft now being employed because they are a fraction of the size, carry no flammable fuel,

do not carry crew or passengers, and pose an infinitesimal risk to others. This is in stark

contrast to conventional aircraft that are flown to the site, carry explosive fuel, carry passengers

and crew, and operate in a much larger area.

From a practical standpoint, there are relatively few licensed full-scale aircraft pilots who are

also qualified to fly the type of sUAS that are utilized for infrastructure image-capture 

operations. There are even fewer commercial pilots that can fly these sUAS – to the point that

to do both is considered rare. Assuming that it is unlikely for a company to find a

pilot that has both qualifications, that company would either have to source a qualified

sUAS pilot to train and obtain a commercial certificate, or find a commercial certificated pilot

who would be willing to learn to fly a sUAS to the competency level required for professional

use.

Minimum requirements for the PIC include:

1) Private Pilot’s license and a Class III medical;

2) A minimum of 200 flight cycles and 25 hours of total time as a sUAS rotorcraft pilot

and at least 10 hours logged as a sUAS pilot with a similar sUAS type

(single blade or multirotor);

3) A minimum of 5 hours as sUAS pilot with the make and model of sUAS to be

utilized for operations under the exemption and 3 take offs and landings in the 

preceding 90 days;

4) Have undergone a qualification process as specified in the Flight Operations & 

Procedures Manual consisting of a knowledge & skill test of the aircraft to be

used.
Another consideration supporting the certificate requirement is that pilots holding a private

pilot certificate are subject to security screening by the Department of Homeland Security.

This requirement should ameliorate security concerns over UAS operations under this

exemption.

Unknown Drones, LLC. intends to use commercially available sUAS Components for sUAS. 

These sUAS systems will be tested for quality & safety in our test facility before being 

deployed to the field. The sUAS is less than 55 lbs. fully loaded, carries neither a pilot nor 

passenger, and operates exclusively within a secured area. We have a routine maintenance

schedule to verify that the sUAS will remain in safe and operational condition.

Notes Regarding: 14 C.F.R. Part 21, Subpart H

In accordance with the statutory criteria provided in Section 333 of PL 112--‐95 in reference

to 49 USC 44704, and in consideration of the size, weight, speed, and limited operating area

associated with the aircraft and its operation, we request that this aircraft exemption meets

the conditions of Section 333. Therefore, if granted Section

333 relief of 14 CFR part 21, and any associated noise certification and testing

requirements of part 36, is not necessary.

Notes Regarding: 14 C.F.R. § 45.23 (b). Marking of the Aircraft

Given the size of the sUAV, two-inch lettering will be impossible. UA 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.

Notes Regarding: 14 CFR § 91.7(a) Civil Aircraft Airworthiness

UNKNOWN DRONES, LLC..’s request is based on the fact that no airworthiness certificate

will be issued for the UAS. Unknown Drones, LLC.’s UAS will not require an airworthiness

certificate in accordance with 14 CFR part 21, Subpart H. Based on the fact that an

airworthiness certificate will not be issued, exemption from § 91.7(a) is not necessary.

Notes Regarding: 14 CFR § 91.9(b)(2) Civil aircraft flight manual, marking & placard

Certifications required, the original intent of these regulations was to display an aircraft’s 

airworthiness, certification, and registration documents so they would be easily available to

inspectors and passengers. Based on the FAA Memorandum subject “Interpretation regarding

whether certain required documents may be kept at an unmanned aircraft’s control station,”

dated August 8, 2014, the requested relief from 14 CFR §§ 91.9(b)(2) and 91.203(a) and (b) is

not necessary.

Notes Regarding: §91.109 Flight instruction; Simulated instrument & certain flight tests Small

UASs, by their design, do not have fully functional dual controls. Flight control is 
accomplished through the use of a control box that communicates with the aircraft via radio

communications. Aircraft being considered for use by Unknown Drones, LLC. allow the UAS 

Instructor to place the aircraft into ‘loiter’ mode (fixed altitude stationary hold). In the event of 

the student losing control, the UAS Instructor can quickly and via alternate equipment

(equipment not in the hands of the student) place the aircraft into a mode that then allows the

instructor to bring the aircraft back into control and back to the pre- determined and/or safe

landing location.

Unknown Drones, LLC. does not describe training scenarios in which a dual set of controls

would be utilized or required, i.e. dual flight instruction, provided by a flight instructor or other 

company-designated individual, that would require that individual to have fully functioning

dual controls. Rather, Unknown Drones, LLC. evaluates the qualification of its PICs based on 

their experience with the UAS to be operated and verifies through testing, in lieu of formalized

training. As such, Unknown Drones, LLC. does not seek relief from 14 CFR § 91.109.

Notes Regarding § 14 CFR 91.119(b)

Relief from § 14 CFR 91.119(b), operation over congested areas, is not applicable, because the

Unknown Drones, LLC.’s operations will only be conducted within the secured area described 

herein.

UNKNOWN DRONES, LLC.. Safety Operations & Procedures Overview:

Technology Considerations:

Best-in-class, tried and proven technologies that are in advanced iterations. Software from 

highly-reputable industry partners will include features -

1. Auto descent (landing) if communication signal were to be severed. If the sUAS loses

communications, the sUAS will have capability to return to a pre-determined location

within the Security Perimeter and land.

2. Auto descent (landing) if battery were to drop lower than nominal level.

3. Flights will be terminated at 25% battery power reserve.

4. Live video for operator gives real-time positioning feedback. In other words, we can

monitor the scene from the vehicle's perspective for collision avoidance, and to maintain

spatial orientation.

5. The sUAS will have the capability to abort a flight in case of unpredicted obstacles

or emergencies.

6. On-Screen-Display (OSD) contains operating information to ascertain vehicle health

at all times: speed, altitude, number of GPS satellites (when available), heading and

voltage.

7. GPS lock supplies for return-to-home (RTH). Should Command and Control (C2) link

failures occur (highly improbable), vehicle returns automatically to the point of launch.

8. Altitude information will be provided to the sUAS pilot via a digitally encoded 

telemetric data feed, which downlinks from the aircraft to a ground-based on-screen 

display. This altitude information will be generated by equipment installed on board the

aircraft, using GPS triangulation, or digitally encoded barometric altimeter, or radio

altimeter, or any combination thereof. Prior to each flight, a zero altitude initiation point
will be established and confirmed for accuracy by the pilot.

Mechanical/Physical:

1. We will fly line-of-sight (LOS) only. The vehicle will always remain in direct LOS to the

pilot, thus eliminating the concern of signal severance (flying behind objects/walls).

2. The sUAS will weigh less than 55 lbs and travel at less than 50 knots.

3. Batteries should far exceed the capacity required for actual flight time.

4. Flights will be operated at an altitude of no more than 400 feet AGL.

5. Fireproof bags for storage and charging of high capacity Lipo batteries on-site.

6. UA operated under this exemption will be marked in accordance with 14 CFR

part 45 or as otherwise authorized by the FAA.

Personnel:

1. Spotters ensure safe operation and act as a redundant set of eyes for operators

(pilot, gimbal op, director)

2. Radio spectrum analysis for interference on the frequencies utilized for vehicle 

control/communication.

3. A briefing will be conducted in regard to the planned sUAS operations prior to each

day’s activities. It will be mandatory that all personnel who will be performing duties

within the boundaries of the safety perimeter be present for this briefing.

4. The operator will obtain the consent of all persons involved in the sUAS operations

and ensure that only consenting persons will be allowed within 100 feet of the flight 

operations.

5. Observer and pilot will at all times be able to communicate by voice.

6. Written and/or oral permission from the relevant property holders will be obtained.

7. Pilot and observer will have been trained in operation of UAS generally and 

received up-to-date information on the particular UAS to be operated.

Operations:

1. The unmanned aircraft (UA) must weigh less than 55 pounds (25 Kg),

including energy source(s) and equipment. Operations authorized by this petition of 

exemption are limited to the following aircraft described in Appendix B. Proposed

operations of any other aircraft will require a new petition or a petition amendment to

this request.

2. The UA may not be flown at a ground speed exceeding 50 knots.

3. Flights must be operated at an altitude of no more than 400 feet above ground level

(AGL), as indicated by the procedures specified in the operator’s manual. All altitudes

reported to ATC must be in feet AGL.

4. The UA must be operated within visual line of sight (VLOS) of the PIC at all times.

This requires the PIC to be able to use human vision unaided by any device other than

corrective lenses, as specified on the PIC’s FAA-issued medical certificate.

5. All operations must utilize a visual observer (VO). The VO may be used to satisfy

the VLOS requirement as long as the PIC always maintains VLOS capability. The
VO and PIC must be able to communicate verbally at all times.

6. The operator’s manual included as Appendix C and this petition of exemption must

be maintained and made available to the Administrator upon request. If a discrepancy

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

outlined in the operator’s manual, the conditions and limitations herein take

precedence and must be followed. Otherwise, the operator must follow the procedures

as outlined in its operator’s manual.

The operator may update or revise its operator’s manual. It is the operator’s 

responsibility to track such revisions and present updated and revised documents to the

Administrator upon request. The operator must also present updated and revised

documents if it petitions for extension or amendment. If the operator determines that

any update or revision would affect the basis for which the FAA grants this petition for 

exemption, then the operator must petition for amendment to their exemption. The

FAA’s UAS Integration Office (AFS-80) may be contacted if questions arise regarding

updates or revisions to the operator’s manual.

7. Prior to each flight the PIC must inspect the UAS to ensure it is in a condition for safe

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

aircraft is prohibited from operating until the necessary maintenance has been performed

and the UAS is found to be in a condition for safe flight. The Ground Control Station, if

utilized, must be included in the preflight inspection. All maintenance and alterations

must be properly documented in the aircraft records.

8. Any UAS that has undergone maintenance or alterations that affect the UAS 

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

undergo a functional test flight in accordance with the operator’s manual. The PIC who 

conducts the functional test flight must make an entry in the UAS

aircraft records of the flight. The requirements and procedures for a functional test

flight and aircraft record entry must be added to the operator’s manual.

9. The operator must follow the manufacturer’s UAS aircraft/component, 

maintenance, overhaul, replacement, inspection, and life limit requirements. When

unavailable, aircraft maintenance/component/overhaul, replacement, and 

inspection/maintenance requirements must be established and identified in the 

operator’s manual. At a minimum, requirements for the following must be included in

the operator’s manual:

a. Actuators / Servos;

b. Transmission (single rotor);

c. Powerplant (motors);

d. Propellers;

e. Electronic speed controller;

f. Batteries;

g. Mechanical dynamic components (single rotor);

h. Remote command and control;

i. Ground control station (if used); and
j. Any other components as determined by the operator;

10. The Pilot In Command (PIC) must possess at least a private pilot certificate and at

least a current third-class medical certificate. The PIC must also meet the flight review

requirements specified in 14 CFR § 61.56 in an aircraft in which the PIC is rated on his

or her pilot certificate.

11. Prior to operations conducted for the purpose of infrastructure inspections, the

PIC must have accumulated and logged, in a manner consistent with 14 CFR §

61.51(b), a minimum of 200 flight cycles and 25 hours of total time as a UAS 

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

(single blade or multirotor). Prior documented flight experience that was obtained in

compliance with applicable regulations may satisfy this requirement. Training,

proficiency, and experience-building flights can also be conducted

under this petition of exemption to accomplish the required flight cycles and flight

time. During training, proficiency, and experience-building flights, all persons not 

essential for flight operations are considered nonparticipants, and the PIC must operate

the UA with appropriate distance from nonparticipants in accordance with

14 CFR § 91.119.

12. Prior to operations conducted for the purpose of infrastructure inspection, the

PIC must have accumulated and logged, in a manner consistent with 14 CFR §

61.51(b), a minimum of five hours as UAS pilot operating the make and model of

UAS to be utilized for operations under the exemption and three take-offs and three

landings in the preceding 90 days. Training, proficiency, experience- building, and

take-off and landing currency flights can be conducted under this petition of exemption

to accomplish the required flight time and 90 day currency. During training,

proficiency, experience-building, and take-off and landing currency flights all persons

not essential for flight operations are considered nonparticipants, and the PIC must

operate the UA with appropriate distance from nonparticipants in accordance with 14 

CFR § 91.119.

13. Prior to any flight operations authorized by this petition of exemption, the PIC and

VO must have successfully completed a qualification process, as outlined in the

operator’s manual. As this is a requirement stipulated by the operator, the test must be

developed and implemented by a qualified person designated at the sole discretion of the

operator. A record of completion of this qualification process must be documented and

made available to the Administrator upon request.

14. Prior to operations conducted for the purpose of infrastructure inspection, a flight 

demonstration, administered by an operator-approved and -qualified pilot must be 

successfully completed and documented. This documentation must be available for review

upon request by the Administrator. Because the knowledge and airmanship test

qualifications have been developed by the operator, and there are no established practical

test standards that support a jurisdictional FAA FSDO evaluation and approval of company

designated examiners, the petitioner will conduct these tests in accordance with the

operator’s manual.
15. The UA may not be operated directly over any person, except authorized and 

consenting personnel, below an altitude that is hazardous to persons or property on the

surface in the event of a UAS failure or emergency.

16. Regarding the distance from participating persons, the operator’s manual has safety

mitigations for authorized and consenting personnel. At all times, those persons must

be essential to the operations.

17. Regarding distance from nonparticipating persons, the operator must ensure that no

persons are allowed within 500 feet of the area except those consenting to be involved and

necessary for the infrastructure inspection operations. This provision may be reduced to no

less than 200 feet if it would not adversely affect safety and the Administrator has approved

it. For example, an equivalent level of safety may be determined by an aviation safety

inspector’s evaluation of the infrastructure inspection area to note terrain features,

obstructions, buildings, safety barriers, etc. Such barriers may protect nonparticipating

persons (observers, the public, news media, etc.) from debris in the event of an accident.

18. If the UAS loses communications or loses its GPS signal, the UA must return to a predetermined location within the security perimeter and land or be recovered in accordance

with the operator’s manual.

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

emergencies in accordance with the operator’s manual.

20. Each UAS operation must be completed with 25% battery power remaining.

21. The operator must obtain an Air Traffic Organization (ATO) issued Certificate of 

Waiver or Authorization (COA) prior to conducting any operations under this petition of

exemption. This COA will also require the operator to request a Notice to Airman 

(NOTAM) not more than 72 hours in advance, but not less than 48 hours prior to the 

operation.

22. All aircraft operated in accordance with this exemption must be identified by serial

number, registered in accordance with 14 CFR part 47, and have identification (N-Number)

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

practicable.

23. The operator must develop procedures to document and maintain a record of the UAS

maintenance, preventative maintenance, alterations, status of replacement/overhaul

component parts, and the total time in service of the UAS. These procedures must be

added to the operator’s manual.

24. Each UAS operated under this exemption must comply with all manufacturer

Safety Bulletins.

25. The operator must develop UAS technician qualification criteria. These criteria must

be added to the operator’s manual.
26. The preflight inspection section in the operator’s manual must be amended to include

the following requirement: The preflight inspection must account for all discrepancies,

i.e. inoperable components, items, or equipment, not covered in the relevant preflight

inspection sections of the operator’s manual.

27. Before conducting operations, the radio frequency spectrum used for operation and

control of the UA must comply with the Federal Communications Commission (FCC) or

other appropriate government oversight agency requirements.

28. At least three days before scheduled infrastructure inspection, the operator of the UAS

affected by this exemption must submit a written Plan of Activities to the local FSDO with

jurisdiction over the area of proposed infrastructure inspection. The 3-day notification may

be waived with the concurrence of the FSDO. The plan of activities must include at least the

following:

a. Dates and times for all flights;

b. Name and phone number of the operator for the UAS infrastructure

inspection operations conducted under this petition of exemption;

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

operation of the UAS;

d. Make, model, and serial or N-number of UAS to be used;

e. Name and certificate number of UAS PICs involved in the infrastructure 

inspection event;

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

and/or local officials to conduct the infrastructure inspection event; the list of those

who gave permission must be made available to the inspector upon request;

g. Signature of exemption-holder or representative; and

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

town, county, and/or state over which infrastructure inspection will be conducted

and the altitudes essential to accomplish the operation.

29. The documents required under 14 CFR §§ 91.9 and 91.203 must be available to the

PIC at the Ground Control Station of the UAS any time the aircraft is operating. These

documents must be made available to the Administrator or any law enforcement official

upon request.

30. The UA must 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.).

31. UAS operations may not be conducted during night, as defined in 14 CFR § 1.1. All

operations must be conducted under visual meteorological conditions (VMC). Flights

under special visual flight rules (SVFR) are not authorized.

32. The UAS may not be operated by the PIC from any moving device or vehicle.

33. 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.
34. The UA may not operate in Class B, C, or D airspace without written approval from the

FAA. The UA may not operate within 5 nautical miles of the geographic center of a nontowered airport as denoted on a current FAA-published aeronautical 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 operator’s COA. The letter of agreement with

the airport management must be made available to the Administrator upon request.

35. Any incident, accident, or flight operation that transgresses the lateral or vertical 

boundaries of the operational area as defined by the applicable COA must be reported to the

FAA’s UAS Integration Office (AFS-80) within 24 hours. Accidents must be reported to the

National Transportation Safety Board (NTSB) per instructions contained on the NTSB Web

site: www.ntsb.gov. Further flight operations may not

be conducted until the incident, accident, or transgression is reviewed by AFS-80 and 

authorization to resume operations is provided.

Support for Petition for Exemption

In accordance with the procedural requirements of 14 C.F.R. §11.81, Unknown Drones, LLC. 

provides the following information:

Contact Information:

Robert W. Hammers

Unknown Drones, LLC

9924 HWY 79 E

Henderson, Texas 75652

(903) 720-8931

unknowndrones@yahoo.com

Regulatory Provisions from which Unknown Drones, LLC. seeks an Exemption

Unknown Drones, LLC. believes it may need an exemption from the following provisions to 

conduct the contemplated operations. In some instances, relief is needed because relief from

another provision renders compliance with the regulation at hand infeasible.

333 Aircraft Exemption Status

14 C.F.R. §61.113(a) and (b)

14 C.F.R. §91.119(c)

14 C.F.R. §91.121

14 C.F.R. §91.151

14 C.F.R. §91.405(a)

14 C.F.R. §91.407(a)

14 C.F.R. §91.409(a)(1)&(2)

14 C.F.R. §91.417(a)&(b)

Unknown Drones, LLC. believes an exemption is only needed from the above-listed regulatory 
provisions. To the extent that the FAA believes that additional relief is required for Unknown 

Drones, LLC. to conduct the operations described here, we request an exemption from any such 

regulatory provisions as well.

The Extent of Requested Relief and the Reasons Relief is Needed

Section 333 Aircraft Exemption Status:

Section 333 of the Modernization Act authorizes the FAA to exempt aircraft from the requirement

for an airworthiness certificate based on a consideration of the size, weight, speed, operational

capability of the particular UAS, as well as its proximity to airports and populated areas. An

analysis of these criteria demonstrates that the sUAS operated without an airworthiness certificate in

the areas and under the conditions contemplated by Unknown Drones, LLC. Will be at least as

safe, or safer, than a conventional aircraft (fixed wing or rotorcraft) operating with an airworthiness

certificate without the conditions proposed in this request.

The sUAS is less than 55 lbs. fully loaded, carries neither a pilot nor passenger, and operates 

exclusively within a secured area. Unlike other civil aircraft, operations under this exemption will

be tightly controlled and monitored by the operator and observer. Operations will be conducted in

compliance with the FAA and with local public safety requirements to provide security for the area

of operation as is now done with conventional equipment, infrastructure, bridge and out building

evaluation. These safety enhancements provide an expanded degree of safety to the inspectors over

conventional operations. Lastly, application of these same criteria demonstrates that there is no

credible threat to national security posed by the sUAS, due to its size, speed of operation, location

of operation, lack of explosive materials and inability to carry a substantial external load.

Given the size and limited operating area associated with the aircraft to be utilized by the 

Applicant, this meets the requirements of an equivalent level of safety under Part 11 and 

Section 333 of the Reform Act. The Federal Aviation Act (49 U.S.C.§44701 (f)) 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 particular sUAS. In all cases, an analysis

of these criteria demonstrates that the UAS operated without an airworthiness certificate, in the

restricted environment and under the conditions proposed will be at least as safe, or safer, than

a conventional aircraft (fixed

wing or rotorcraft) operating with an airworthiness certificate without the restrictions and

conditions proposed.

14 C.F.R. §61.113(a) and (b)

§61.113 Private pilot privileges and limitations: Pilot in command.

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

holds a private pilot certificate may act as pilot in command of an aircraft that is

carrying passengers or property for compensation or hire; nor may that person, for 

compensation or hire, act as pilot in command of an aircraft.

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

aircraft in connection with any business or employment if:

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

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

hire.
Unknown Drones, LLC. anticipates initially using a unit of specially trained staff to conduct the 

sUAS operations. While these individuals will not hold commercial pilot licenses. The sUAS will

not carry property for compensation or hire since they will be used solely to assist in evaluation of 

the infrastructure, equipment, right-of-way, assets, bridges, tunnels and out-buildings in

furtherance of Unknown Drones, LLC.’s client’s primary business, the successful operation of a

infrastructure; however, the employees’ operation of the sUAS will not be incidental to their

employment with Unknown Drones, LLC., and they will be compensated for such work. Without

an exemption, the pilot would be required to hold a commercial pilot certificate under §61.133. 

However, the risk associated with the contemplated operations is less than the risk posed by a

traditional aircraft. The sUAS will fly at altitudes well below the permissible limits for other civil

aircraft, eliminating the risk to other aircraft, and within a geographical envelope under the sole

control of Unknown Drones, LLC. clients. Accordingly, the risk would be limited to Unknown 

Drones, LLC. personnel, who will be appropriately outfitted in safety gear, and Unknown 

Drones, LLC. client’s property on the ground. Requiring a commercial pilot certificate would

provide no appreciable safety benefit and would needlessly impose additional cost on Unknown 

Drones, LLC. Because the contemplated operations would not comply with §61.113(b)(1) and

none of the other exceptions to paragraph (a) apply, relief is needed from both paragraphs (a) and

(b).

14 C.F.R. 91.119(c)

§91.119 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.

*****

Unknown Drones, LLC. submits that the only relief it requires from §91.119 is from the

minimum altitudes listed in paragraph (c). Relief is required from paragraph (c) for fixed

wing operations because asset evaluation conducted at 500 feet or higher is insufficiently 

distinct to be meaningful. Since operations at this altitude also pose a heightened risk of 

collision with another aircraft, safety can only be assured through the grant of an 

exemption. The anticipated rotorcraft operations should be adequately addressed by 

paragraph (d) (1). Additionally, relief should not be needed from paragraph (a) because 

an emergency landing of the aircraft due to a power failure will not create an undue 

hazard to persons or property on the surface. As noted in the explanation of why an 

exemption will not adversely affect safety, Unknown Drones, LLC. clients has exclusive

use of the land over which the sUAS will be operated, and public access is restricted. It

also has exclusive use of significant portions of land adjacent to the infrastructure and

structures that will be the objects of evaluation and analysis. Unknown Drones, LLC.’s 

Clients tightly control access to land and have the ability to assure that no individuals

unassociated with the planned operations are on the affected land. As such, the risk of 

injury is minimal. Unknown Drones, LLC. does not contemplate conducting operations

over congested areas, so relief is not requested from paragraph (b).
14 C.F.R. 91.121

14 C.F.R. §91.121 Altimeter Settings

This regulation requires each person operating an aircraft to maintain cruising

altitude by reference to an altimeter that is set “...to the elevation of the departure 

airport or an appropriate altimeter setting available before departure.”

*****

As the sUAS may not have a barometric altimeter, but instead a GPS altitude read

out, an exemption may be needed. An equivalent level of safety will be achieved by the 

operator, pursuant to the Manual and Safety Check list, confirming the altitude of the launch

site shown on the GPS altitude indicator before flight.

Altitude information will be provided to the sUAS pilot via a digitally encoded telemetric data

feed, which downlinks from the aircraft to a ground-based on-screen display. This altitude

information will be generated by equipment installed on board the aircraft, using GPS

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

thereof. Prior to each flight, a zero altitude initiation point will be established and confirmed for

accuracy by the pilot.

14 C.F.R. 91.151

§91.151 Fuel requirements for flight in VFR conditions.

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

(considering wind and forecast weather conditions) there is enough fuel to fly to the

first point of intended landing and, assuming normal cruising speed – (1) During the

day, to fly after that for at least 30 minutes.

(b) No person may begin a flight in a rotorcraft under VFR conditions unless

(considering wind and forecast weather conditions) there is enough fuel to fly to the

first point of intended landing and, assuming normal cruising speed, to fly after that

for at least 20 minutes.

*****

Operating the sUAS in a pre-defined area with less than 30 minutes of reserve

fuel does not raise the type of risk contemplated by §91.151, i.e., that an aircraft could run out

of fuel in the event it has to be flown to an alternate airport or circle the planned airport in the

event of unanticipated conditions. Unknown Drones, LLC. does not intend to use the sUAS for 

point-to-point flights and will not operate the sUAS beyond visual line of sight. Nor will the

sUAS require an airport in order to land. Rather, Unknown Drones, LLC. will operate the

sUAS using pre-planned flight paths (taking into account weather conditions) designed to

allow the sUAS to fly to the point of intended landing. As such, there is no need for a timebased excess fuel requirement. Rather it should be sufficient to require only as much additional

excess flight capacity as necessary to safely land the sUAS. We believe that a 25% battery

reserve is more than sufficient to meet this objective.

14 C.F.R. 91.405(a), 91.407(a) (1), 14 C.F.R. 91.409(a) (1)&(2) and 14 C.F.R. 91.417(a) & (b)

§91.405 Maintenance required.

Each owner or operator of an aircraft –

(a) Shall have that aircraft inspected as prescribed in subpart E of this part and

shall between required inspections, except as provided in paragraph (c) of this 

section, have discrepancies repaired as prescribed in part 43 of this chapter;
§91.407 Operation after maintenance, preventive maintenance,

rebuilding, or alteration.

(a) No person may operate any aircraft that has undergone 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 Inspections.

(a) Except as provided in paragraph (c) of this section, no person may operate

an aircraft unless, within the preceding 12 calendar months, it has had

(1) An annual inspection in accordance with part 43 of this chapter and has

been approved for return to service by a person authorized by §43.7 of this 

chapter; or

(2) An inspection for the issuance of an airworthiness certificate in 

accordance with part 21 of this chapter.

*****

§91.417 (a) & (b)

*****

Unknown Drones, LLC. believes that an exemption from these three maintenance requirements 

is appropriate because the FAA has not developed maintenance standards that would allow an 

operator to meet the part 91 maintenance requirements. In particular, there are no individuals 

authorized by the FAA to approve a sUAS for return to service under§91.407(a) or to conduct 

the initial airworthiness and annual return to service inspections required by §91.409(a). 

Unknown Drones, LLC. will maintain the aircraft as instructed in the owner’s manual and 

ASTM F2909, where applicable, and will not operate the aircraft until it has reasonably 

determined that any needed repairs have been made. However, because of the technical 

impossibility of meeting the requirements of §91.405(a), 407(a), 409(a) and 417(a)&(b), we 

believe an exemption from these provisions is appropriate.

Please do not hesitate to contact me at the phone number or via the e-mail address 

provided above should you have any questions or concerns.

Respectfully submitted,

Robert W. Hammers

Unknown Drones, LLC.
Appendix A

Summary for Federal Register Publication

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

Federal Register should the FAA determine that publication is needed.

Petitioner: Unknown Drones, LLC.

Sections of 14 C.F.R. Affected:

333 Aircraft Exemption Status

14 C.F.R. §61.113(a) and (b)

14 C.F.R. §91.119(c)

14 C.F.R. §91.121

14 C.F.R. §91.151

14 C.F.R. §91.405(a)

14 C.F.R. §91.407(a)

14 C.F.R. §91.409(a)

14 C.F.R. §91.417(a)&(b) 

Description of Relief Sought:

Petitioner seeks relief from the requirements of 333 Aircraft Exemption Status, 14

C.F.R., 61.113(a)&(b)), 91.119(c), 91.121, 91.151, 91.405(a), 91.407(a), 91.409(a), and

91.417(a)&(b) to conduct sUAS operations over UNKNOWN DRONES, LLC.. Client’s

owned or controlled land, solely during daylight hours, to assist in the safe evaluation and

analysis of infrastructure and operations. In general, sUAS operations are intended to be

conducted in areas remote from both congested areas and airports. The nature of operations 

anticipated by Unknown Drones, LLC. requires that the sUAS be flown at relatively low

altitudes. Unknown Drones, LLC. expects that in most instances, the sUAS will be flown less

than 75 feet from the highest structure along the path of the sUAS and in no instances will be

flown higher than 400 feet above the ground. Accordingly, the risk of interference with other

aircraft is minimal.