U.S. Department of Transportation

Docket Management System

1200 New Jersey Avenue, SE

Washington, DC 20590

RE: Exemption Request – Section 333 of the FAA Report Act and Part 11 of the Federal 

Aviation Regulations

Dear Sir/Madam, 

This petition is being submitted on our own behalf without legal counsel or consulting services. 

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

Act), and 14 C.F.R. Part 11, Green Sniper, LLC an Oklahoma based limited liability company 

operating a Small Unmanned Aircraft System (sUAS) equipped to conduct aerial photography 

and survey for various industries, hereby applies for an exemption from the Federal Aviation 

Regulations (FARs) listed below to allow operation of our sUAS commercially in airspace 

regulated by the Federal Aviation Administration (FAA) so long as such operations are 

conducted with and under the conditions outlined herein or as may be established by the FAA 

as required by Section 333. 

The requested exemption would permit Green Sniper, LLC to pursue its commercial interests in 

providing services to consumers interested in aerial data capture using a small advanced sUAS 

in the following areas: 

• Agricultural Surveying 

• Construction Surveying 

• Commercial Surveying 

• Gas and Oil Inspections and Monitoring

• Real Estate Photography 

• sUAS Operator Training 

• Product Demonstrations 

• Research and Development 

• Aerial Surveying/Inspecting

• General Video and Photography assignments

• Inspection of Wind Towers

• Damage assessments

• Event Marketing Photo and Video

• Education and Training

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

may grant an exemption under 49 U.S.C. Section 44701(f) if it has determined that such an
exemption is in the public interest.

Granting an Exemption is in the Public Interest.

Currently, various businesses must hire traditional manned aircraft in order to obtain aerial 

views of their property for inspection and advertising purposes. These manned aircraft pose 

significant risk to aircraft operators, nearby property, and persons in the area. The use of sUAS 

for general asset evaluation would reduce the risks to personnel and property by allowing for 

remote aerial review. Further, the use of sUAS have the potential to improve efficiency, 

resulting in faster and safer delivery of asset evaluation, all while significantly reducing the risk 

of human and property loss.

Regulations from which the exemption is requested: 

14 C.F.R. Part 21 

14 C.F.R. 45.23 (b) 

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

14 C.F.R. 91.7 (a) 

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

14 C.F.R. 91.109 

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 C.F.R. 91.205 (b) 

14 C.F.R. 91.215 

14 C.F.R. (91.401 - 91.417)

An exemption would allow Green Sniper, LLC to broadly evaluate assets and operations with 

sUAS, resulting in a safer and more efficient inspection and monitoring regime in the resource 

industries. 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.

This exemption would permit commercial operation by Green Sniper, LLC, which uses DJI 

Phantom 3, DJI Inspire 1, and 3D Robotics Solo sUAS’ to conduct general asset inspections. 

Green Sniper’s operation under the exemption will be subject to strict operating requirements 

and conditions to ensure an equivalent level of safety to currently authorized operations using 

manned aircraft and under conditions as maybe modified by the FAA as required by Section 

333.

Green Sniper, LLC states that all sUAS flights will occur over private or controlled access property, 

will do so with the property owner’s consent and knowledge, and only people who have 

consented or agreed will be in the area where flights will take place.
Furthermore, the petitioner will only operate its sUAS in line-of-sight (VLOS) of a pilot and/or

observer and will operate at sites in that are ‘sufficient distance’ from populated areas within 

the work area described in the Green Sniper, LLC Operations Operating Manual. Such operations 

will ensure that the sUAS will not create a hazard to users of the national airspace system or the 

public.

Additionally, Green Sniper, LLC crew will consist of a sUAS pilot who will hold a FAA private pilot 

certificate or a sports pilot license, plus a Visual Observer (VO).

In keeping with previous exemptions granted, we will ensure that operations will not occur

within 5 miles of an airport. The sUAS operated by Green Sniper, LLC all weigh less than 25 

pounds, including payload (i.e. sensors, camera, lens, and stabilized gimbal), and operate at 

speeds below 35MPH, and will not be operated at altitudes that exceed 400 feet AGL.

Given the small size of the sUAS and the restricted work environment within which it will

operate, Green Sniper, LLC operations adhere to the Reform Act’s safety

requirements. The fact the pilot holds an FAA Private Pilot license demonstrates Green Sniper’s

high regard for safe operations with an understanding of FARs, pre-flight inspections, 

knowledge of operations and differences in airspace classifications, maintenance and repair, as 

well as being trained to high safety standards.

We respectively request exemption under Section 333 to enable Green Sniper, LLC to operate 

efficient, limited, low-risk commercial sUAS operations for the activities stated, respecting at all 

times the space and privacy of citizens and property while keeping airspace safe.

Sincerely,

Todd Ballard

Green Sniper, LLC

Stillwater, OK 74074

(405) 334-8221

tab.ballard@gmail.com
EXEMPTION REQUESTS AND EQUIVALENT LEVEL OFSAFETY 

Green Sniper LLC requests an exemption from the following regulations as well as any additional 

regulations that may technically apply to the operation of the sUAV System: 

14 CFR Part 21, Airworthiness Certificates 

This part establishes the procedures for the issuance of an airworthiness certificate. While the FAA 

continues to work to develop airworthiness standards for Unmanned Aerial Systems, we request an 

experimental certificate be issued for the DJI Phantom 3, DJI Inspire 1, and the 3D Robotics Solo sUAS 

under either or both of the following provisions: 

21.191 Experimental certificates. 

Experimental certificates are issued for the following purposes: 

(a) Research and development. Testing new aircraft design concepts, new aircraft equipment, 

new aircraft installations, new aircraft operating techniques, or new uses for aircraft. 

(b) Showing compliance with regulations. Conducting flight tests and other operations to show 

compliance with the airworthiness regulations including flights to show compliance for issuance 

of type and supplemental type certificates, flights to substantiate major design changes, and 

flights to show compliance with the function and reliability requirements of the regulations. 

Since the experimental certificate can be used for commercial purposes such as market surveys, 

sales demonstrations, and customer crew training, we would expect that an experimental 

certificate would permit our commercial purpose as well. The aircraft will not carry persons or 

property, will not carry fuel, and will only fly under strict operational requirements. Combined 

with the UA's light weight, being constructed primarily of foam, carbon fiber, and/or plastic, we 

propose that the UA will be at least as safe, if not safer, than a conventionally certificated 

aircraft performing the same mission. If an experimental airworthiness certificate is not 

appropriate for this application, then we request an exemption of 14 CFR Part 21, Subpart H, 

and the requirement for an airworthiness certificate in general, citing the equivalent level of 

safety outlined in the previous paragraph. 

14 CFR 45.23 Display of marks; general and 45.29 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. The sUAV does not have 

an entrance in which the word "EXPERIMENTAL" can be placed, and may not have a registration number 

assigned to it by the FAA. We propose to achieve an equivalent level of safety by including the word 

"EXPERIMENTAL" in the placard on the top of the aircraft, as shown above, where the PIC, VO and 

others in the vicinity of the aircraft while it is preparing for launch will be able to see the designation. 

Additionally, we feel that the permanent placard discussed in the previous paragraph will provide the 

aircraft's registration information at the ground station. Finally, we will display at the ground station a 

high contrast flag or banner that contains the words "Unmanned Aircraft Ground Station" in letters 3 

inches high or greater. Since the aircraft will operate within 3/4 NM of the ground station, the banner 

should be visible to anyone that observes the aircraft and chooses to investigate its point of origin.
14 CFR 61.113 Private pilot privileges and limitations: Pilot in Command and61.133 Commercial pilot 

privileges and limitations. 

The regulation provides 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; and (2) The aircraft does not carry passengers or property 

for compensation or hire. Our proposed operations require that the PIC must hold at least a Private Pilot 

Certificate issued by the FAA and since the aircraft cannot carry passengers or property, we feel we 

meet the intent of 61.113 Subparagraph (b) even though the intent of this application is to conduct a 

business. 

14 CFR 91.7 Prohibits the Operation of an aircraft without an airworthiness certificate. 

As no such certificate will be applicable in the form contemplated by the FARs, this Regulation is 

inapplicable. 

14 CFR 91.9 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. We assume that the intent of this requirement is to ensure that flight manual 

information is available to the aircrew while operating the aircraft. We request 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 during flight operations. To obtain an equivalent level of safety and meet 

the intent of 91.9, we propose that a current, approved sUAS Flight Manual must be available to the 

crew at the ground station anytime the aircraft is in, or preparing for, flight. 

14 CFR 91.109 Flight Instruction; Simulated instrument flight and certain flight tests.

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

unless that aircraft has fully functioning dual controls." The sUAS System ground-based control station 

consists of a small hand-held radio transmitter and while it does not offer a second set of "controls", 

both the student and instructor can, and will, operate the single set of controls simultaneously. With 

both student and instructor having "hands-on" the controls during flight, we feel that this technique 

meets the intent 91.109 and provides an equivalent level of safety. 

14 CFR 91.119 Minimum safe altitudes: General. 

The regulation states that over sparsely populated areas the aircraft cannot be operated closer than 500 

feet to any person, vessel, vehicle, or structure. Since the typical mission of the sUAS would be 

photography or survey of persons, vessels, vehicles or structures it would be necessary to operate closer 

than 500 feet to the items listed. Operations will only be flown over property or persons where 

permission has been obtained and careful pre-planned has been performed. The aircraft will be 

operated at a low altitude allowing, if a power unit fails, an emergency landing without undue hazard to 

persons or property on the surface. Therefore, we maintain that due to the small size of the UAS, the 

hazard to persons, vehicles and structures is minimal compared to manned aircraft, which should be 

considered in granting the exemption. 

14 CFR 91.121 Altimeter settings. 

The regulation requires that aircraft shall maintain cruising altitudes by reference to an altimeter setting 

available within 100 NM of the aircraft. The sUAS will always fly below 400 feet AGL and will not need to 

maintain cruising altitudes in order to prevent conflict with other aircraft. An Above Ground Level 
altimeter measurement above the takeoff point is transmitted via radio from the sUAS on-board 

computer to the display screen held by the PIC, providing a constantly updated AGL readout.

14 CFR 91.151 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. We feel the intention of this paragraph is to provide an energy reserve as a safety buffer for 

delays to landing. The sUAS are battery operated and the maximum duration of flight from a single 

battery charge is 12-45 (depending on which sUAS) minutes with a 20% reserve. Since the aircraft will 

never fly more than 1/2 NM from the point of intended landing, a full battery charge at launch will 

ensure that we meet the reserve energy requirement of this paragraph. We request an exemption to 

the word "fuel" and ask for an equivalent interpretation with the word "energy". We also request 

exemption from the 30 min reserve and ask that our reserve will be to fly the mission to the point of 

intended landing and have at least a 20% battery reserve after that. 

14 CFR 91.203(a) & (b) Civil aircraft: Certifications required. 

The regulation provides that an airworthiness certificate, with the registration number assigned to the 

aircraft and a registration certificate must be aboard the aircraft. Additionally, subparagraph(b) provides 

that the airworthiness certificate be "displayed at the cabin or cockpit entrance so that it is legible to 

passengers or crew." With our largest vehicle, the RF-70, at a maximum gross weight of 13 pounds, the 

sUAS is too small to carry documentation, does not have an entrance, and is not capable of carrying 

passengers or crew. To obtain an equivalent level of safety and meet the intent of 91.203, we propose 

that documents deemed appropriate for this aircraft by the FAA will be co- located with the crew at the 

ground control station and available for inspection upon request. In order to identify the aircraft, we 

propose that the information found on airworthiness and registration certificates be permanently 

affixed to the aircraft via placard containing the following information plus the word "EXPERIMENTAL" 

to satisfy the requirement of 14 CFR45.23. 

14 CFR Subpart E (91.401- 91.417) - Maintenance, Preventive Maintenance, Alterations. The regulation 

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

including compliance with part 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. It is our intention that the PIC perform maintenance and inspection 

of the aircraft and "be authorized to approve the aircraft for return to service." 

The PIC will ensure that the aircraft is in an airworthy condition prior to every flight and in addition, 

conduct detailed inspections after every two hours of flight. Maintenance performed by the PIC is 

limited to repairing small cracks, replacing a propeller, checking electrical connections and updating 

software and firmware for the on-board computer. All other maintenance will be performed by the 

manufacturer or their designated repair facility. The PIC will document work performed in accordance 

with 91.417. We feel that due to the size, construction, and simplicity of the aircraft, the PIC can ensure 

an equivalent level of safety.