May 21, 2015

Exemption No. 11637

Regulatory Docket No. FAA–2015–0599

Mr. Greg Graham

Chief Executive Officer

AMK Services LLC

9291 Crouse Willison Road

Johnstown, OH 43031

Dear Mr. Graham:

This letter is to inform you that we have granted your request for exemption. It transmits our 

decision, explains its basis, and gives you the conditions and limitations of the exemption, 

including the date it ends.

By letter posted March 10, 2015, you petitioned the Federal Aviation Administration (FAA) 

on behalf of AMK Services LLC (hereinafter petitioner or operator) for an exemption. The 

exemption would allow the petitioner to operate an unmanned aircraft system (UAS) to 

conduct inspections and monitoring for the public safety, pipeline construction, and 

communications industries.

See Appendix A for the petition submitted to the FAA describing the proposed operations and 

the regulations that the petitioner seeks an exemption.

The FAA has determined that good cause exists for not publishing a summary of the petition 

in the Federal Register because the requested exemption would not set a precedent, and any 

delay in acting on this petition would be detrimental to the petitioner. The FAA received one 

individual comment in opposition to the petition. In granting this exemption, the FAA has 

determined that the proposed operations can safely be conducted under the conditions and 

limitations of this exemption. As with exemptions issued to Aeryon Lab, Astraeus Aerial, 

Clayco, Inc., and VDOS Global, LLC, failure to comply with the document’s conditions and 

limitations is grounds for immediate suspension or rescission of the exemption.
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Airworthiness Certification

The UAS proposed by the petitioner is a DJI Phantom 2.

The petitioner requested relief from 14 CFR part 21, Certification procedures for products 

and parts, Subpart H—Airworthiness Certificates. In accordance with the statutory criteria 

provided in Section 333 of Public Law 112−95 in reference to 49 U.S.C. § 44704, and in 

consideration of the size, weight, speed, and limited operating area associated with the 

aircraft and its operation, the Secretary of Transportation has determined that this aircraft 

meets the conditions of Section 333. Therefore, the FAA finds that the requested relief from 

14 CFR part 21, Certification procedures for products and parts, Subpart H—Airworthiness 

Certificates, and any associated noise certification and testing requirements of part 36, is 

not necessary.

The Basis for Our Decision

You have requested to use a UAS for aerial data collection. The FAA has issued grants of 

exemption in circumstances similar in all material respects to those presented in your petition. 

In Grants of Exemption Nos. 11062 to Astraeus Aerial (see Docket No. FAA−2014−0352), 

11109 to Clayco, Inc. (see Docket No. FAA−2014−0507), 11112 to VDOS Global, LLC (see

Docket No. FAA−2014−0382), and 11213 to Aeryon Labs, Inc. (see Docket No. 

FAA−2014−0642), the FAA found that the enhanced safety achieved using an unmanned 

aircraft (UA) with the specifications described by the petitioner and carrying no passengers or 

crew, rather than a manned aircraft of significantly greater proportions, carrying crew in 

addition to flammable fuel, gives the FAA good cause to find that the UAS operation enabled 

by this exemption is in the public interest.

Having reviewed your reasons for requesting an exemption, I find that—

 They are similar in all material respects to relief previously requested in Grant of 

Exemption Nos. 11062, 11109, 11112, and 11213;

 The reasons stated by the FAA for granting Exemption Nos. 11062, 11109, 11112, and 

11213 also apply to the situation you present; and 

 A grant of exemption is in the public interest.

Our Decision

In consideration of the foregoing, I find that a grant of exemption is in the public interest. 

Therefore, pursuant to the authority contained in 49 U.S.C. 106(f), 40113, and 44701, 

delegated to me by the Administrator, AMK Services LLC is granted an exemption from 

14 CFR §§ 61.23(a) and (c), 61.101(e)(4) and (5), 61.113(a), 61.315(a), 91.7(a), 91.119(c), 

91.121, 91.151(a)(1), 91.405(a), 91.407(a)(1), 91.409(a)(1) and (2), and 91.417(a) and (b), to 
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the extent necessary to allow the petitioner to operate a UAS to perform aerial data collection.

This exemption is subject to the conditions and limitations listed below.

Conditions and Limitations

In this grant of exemption, AMK Services LLC is hereafter referred to as the operator.

Failure to comply with any of the conditions and limitations of this grant of exemption will be 

grounds for the immediate suspension or rescission of this exemption.

1. Operations authorized by this grant of exemption are limited to the DJI Phantom 2

when weighing less than 55 pounds including payload. Proposed operations of any 

other aircraft will require a new petition or a petition to amend this exemption.

2. Operations for the purpose of closed-set motion picture and television filming are 

not permitted. 

3. The UA may not be operated at a speed exceeding 87 knots (100 miles per hour). The 

exemption holder may use either groundspeed or calibrated airspeed to determine 

compliance with the 87 knot speed restriction. In no case will the UA be operated at 

airspeeds greater than the maximum UA operating airspeed recommended by the 

aircraft manufacturer.

4. The UA must be operated at an altitude of no more than 400 feet above ground level 

(AGL). Altitude must be reported in feet AGL.

5. 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 airman medical certificate or

U.S. driver’s license.

6. All operations must utilize a visual observer (VO). The UA must be operated within 

the visual line of sight (VLOS) of the PIC and VO at all times. 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; 

electronic messaging or texting is not permitted during flight operations. The PIC 

must be designated before the flight and cannot transfer his or her designation for the 

duration of the flight. The PIC must ensure that the VO can perform the duties 

required of the VO.

7. This exemption and all documents needed to operate the UAS and conduct its 

operations in accordance with the conditions and limitations stated in this grant of 

exemption, are hereinafter referred to as the operating documents. The operating 

documents must be accessible during UAS operations and made available to the 
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Administrator upon request. If a discrepancy exists between the conditions and 

limitations in this exemption and the procedures outlined in the operating documents, 

the conditions and limitations herein take precedence and must be followed. 

Otherwise, the operator must follow the procedures as outlined in its operating 

documents. The operator may update or revise its operating documents. It is the 

operator’s responsibility to track such revisions and present updated and revised 

documents to the Administrator or any law enforcement official upon request. The 

operator must also present updated and revised documents if it petitions for extension 

or amendment to this grant of exemption. If the operator determines that any update 

or revision would affect the basis upon which the FAA granted this exemption, then 

the operator must petition for an amendment to its grant of exemption. The FAA’s 

UAS Integration Office (AFS−80) may be contacted if questions arise regarding 

updates or revisions to the operating documents.

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 prior to conducting further operations under this exemption. 

Functional test flights may only be conducted by a PIC with a VO and must remain at 

least 500 feet from other people. The functional test flight must be conducted in such 

a manner so as to not pose an undue hazard to persons and property.

9. The operator is responsible for maintaining and inspecting the UAS to ensure that it is 

in a condition for safe operation.

10. Prior to each flight, the PIC must conduct a pre-flight inspection and determine the 

UAS is in a condition for safe flight. The pre-flight inspection must account for all 

potential discrepancies, e.g., inoperable components, items, or equipment. 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.

11. The operator must follow the UAS manufacturer’s maintenance, overhaul, 

replacement, inspection, and life limit requirements for the aircraft and 

aircraft components.

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

safety bulletins.

13. Under this grant of exemption, a PIC must hold either an airline transport, 

commercial, private, recreational, or 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 Columbia, Puerto Rico, a territory, a possession, or the Federal 

Government. 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.
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14. The operator may not permit any PIC to operate unless the PIC demonstrates the 

ability to safely operate the UAS in a manner consistent with how the UAS will be 

operated under this exemption, including evasive and emergency maneuvers and 

maintaining appropriate distances from persons, vessels, vehicles and structures. PIC 

qualification flight hours and currency must be logged in a manner consistent with 

14 CFR § 61.51(b). Flights for the purposes of training the operator’s PICs and VOs 

(training, proficiency, and experience-building) and determining the PIC’s ability to 

safely operate the UAS in a manner consistent with how the UAS will be operated 

under this exemption are permitted under the terms of this exemption. However, 

training operations may only be conducted during dedicated training sessions. 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.

15. 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.

16. The UA may 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.

17. 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.

18. If the UAS loses communications or loses its GPS signal, the UA must return to a 

pre-determined location within the private or controlled-access property.

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

20. The PIC is prohibited from beginning a flight unless (considering wind and forecast 

weather conditions) there is enough available power for the UA to conduct the 

intended operation and to operate after that for at least 5 minutes or with the reserve 

power recommended by the manufacturer if greater.

21. Air Traffic Organization (ATO) Certificate of Waiver or Authorization (COA). All 

operations shall be conducted in accordance with an ATO-issued COA. The 

exemption holder may apply for a new or amended COA if it intends to conduct 

operations that cannot be conducted under the terms of the attached COA.
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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. Documents used by the operator to ensure the safe operation and flight of the UAS and 

any 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.

24. The UA must remain clear and give way to all manned aviation operations and 

activities at all times. 

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

26. All Flight operations must be conducted at least 500 feet from all nonparticipating 

persons, vessels, vehicles, and structures unless:

a. Barriers or structures are present that sufficiently protect nonparticipating persons 

from the UA and/or debris in the event of an accident. The operator must ensure 

that nonparticipating persons remain under such protection. If a situation arises 

where nonparticipating persons leave such protection and are within 500 feet of 

the UA, flight operations must cease immediately in a manner ensuring the safety 

of nonparticipating persons; and

b. The owner/controller of any vessels, vehicles or structures has granted permission 

for operating closer to those objects and the PIC has made a safety assessment of 

the risk of operating closer to those objects and determined that it does not 

present an undue hazard.

The PIC, VO, operator trainees or essential persons are not considered 

nonparticipating persons under this exemption.

27. All operations shall be conducted over private or controlled-access property with 

permission from the property owner/controller or authorized representative. 

Permission from property owner/controller or authorized representative will be 

obtained for each flight to be conducted.

28. 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.
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If this exemption permits operations for the purpose of closed-set motion picture and 

television filming and production, the following additional conditions and limitations apply.

29. The operator must have a motion picture and television operations manual (MPTOM) 

as documented in this grant of exemption.

30. At least 3 days before aerial filming, the operator of the UAS affected by this 

exemption must submit a written Plan of Activities to the local Flight Standards 

District Office (FSDO) with jurisdiction over the area of proposed filming. 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 aerial filming conducted 

under this grant 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 aerial filming;

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

and/or local officials to conduct the filming production 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 filming will be conducted and the altitudes 

essential to accomplish the operation.

31. Flight operations may be conducted closer than 500 feet from participating persons 

consenting to be involved and necessary for the filming production, as specified in the 

exemption holder’s MPTOM.

Unless otherwise specified in this grant of exemption, the UAS, the UAS PIC, and the UAS 

operations must comply with all applicable parts of 14 CFR including, but not limited to, 

parts 45, 47, 61, and 91.
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This exemption terminates on May 31, 2017, unless sooner superseded or rescinded.

Sincerely,

/s/

John S. Duncan

Director, Flight Standards Service
 U.S Department of Transportation 

 May 21, 2015

From: AMK Services, 

To: U.S. Department of Transportation

 Attn: Docket Operations

 Secretary of Transportation

 West Building Ground Floor, Room w12-140

 1200 New Jersey Avenue, SE. Washington, DC 20590-001

SUBJECT: SMALL UNMANNED AIRCRAFT FOR USE IN TOWER AND PIPELINE 

CONSTRUCTION EXEMPTION REQUEST

AMK Services is respectfully requesting and applying for Exemptions by Section 333 – FAA Reform 

and Modernization Act of 2012 and Part 11- Federal Aviation Regulations from 14 C.F.R. § 21, 

Subpart H; 14 C.F.R. § 43.7; 14 C.F.R. § 43.11; 14 C.F.R. § 45.21; 14 C.F.R. § 45.23(b); 14 C.F.R. § 

45.25; 14 C.F.R. § 45.27; 14 C.F.R. § 45.29; 14 C.F.R. § 47.3(b)(2); 14 C.F.R. § 61, Subpart E; 14 

C.F.R. § 91.7(a); 14 C.F.R. § 91.9(b)(2); 14 C.F.R. § 91.9(c); 14 C.F.R. § 91.103; 14 C.F.R. § 91.105; 

14 C.F.R. § 91.109; 14 C.F.R. § 91.113(b); 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; 14 C.F.R. § 91.215; 14 C.F.R. § 91.405(a) and (d); 14 C.F.R. § 

91.407(a)(1); 14 C.F.R. § 91.409(a)(2); 14 C.F.R. § 417(a) and (b). 

Dear Sir/Ma’am:

On behalf of the AMK Services, LLC. (“AMK Services”), we submit to you this Request and 

Application for Exemptions from certain requirements of the FAA Reform and Modernization Act of 

2012 and Regulations described above and in our proposal. In support of our Request and 

Application, we will describe the operations and equipment to be used by AMK Services, the 

necessity and reasons for exemptions as well as the precautions that AMK Services will implement 

and commit to follow.

We seek an exemption from the aforementioned Regulations to operate our unmanned aerial system 

commercially and lawfully. We seek relief of FAA restrictions for commercial UAS use to have the 

ability to offer asset inspections for the Public Safety Industry, Pipeline Construction and 

Communications Industry. By granting our request, we will be able to provide a safer and more 

economical approach to the inspection of communication towers, and pipelines associated with our 

industry. Our UAV is certified to work around communication towers, pipelines and power 

structures while maintaining a safe distance from the structures as set forth in federal, state and local 

regulations. 

AMK Services respectfully request that the FAA grant our exemption request and are willing to work 

with and share all information to benefit the FAA to ensure that lessons learned and procedures are 

reported back to the FAA for future use in guidelines and regulations. 
U.S. Department of Transportation May 21, 2015

Request for Exemption

For use of UAV Page 2

Table of Contents

1. Applicant information - AMK Services, LLC................................................................................3

2. Description of Operations...............................................................................................................4

2.1 Description of UAS................................................................................................................4

2.2 Limited and Predetermined Use .............................................................................................8

2.3 Preflight Inspection ................................................................................................................8

2.4 Flight Functional Test.............................................................................................................8

2.5 Manufacturing Requirements.................................................................................................8

2.6 Operating and Flight Precautions...........................................................................................9

2.7 COA........................................................................................................................................9

2.8 Maintenance ...........................................................................................................................9

2.9 Safety Bulletins ......................................................................................................................9

2.10 Radio Frequency.....................................................................................................................9

2.11 Plan of Activities..................................................................................................................10

2.12 Documents............................................................................................................................10

2.13 Right of Way ........................................................................................................................10

2.14 Operations ............................................................................................................................10

2.15 Accident Reports..................................................................................................................11

3. AMK Services’ Request for Exemptions .....................................................................................11

3.1 Exemption Requests.............................................................................................................11

4. Privacy..........................................................................................................................................18

5. Conclusion....................................................................................................................................18

6. Exhibits Enclosed.........................................................................................................................19

6.1 Exhibit A - DJI – Phantom 2 User Training Guide ..............................................................19

6.2 Exhibit B - DJI – Phantom 2 User Manual...........................................................................19

6.3 Exhibit C - DJI-Phantom 2 Release Noted Dated Feb 2015 ................................................19

6.4 Exhibit D - Training Course Materials from Unmanned Experts Training Facility.............19

6.5 Exhibit E - License and Pilot Information for Robert Bailey. Pilot for AMK Services......19
U.S. Department of Transportation May 21, 2015

Request for Exemption

For use of UAV Page 3

1.Applicant Information - AMK Services, LLC.

AMK Services, LLC is a full service communications company with over 50 combined years of sales, 

engineering, implementation, project management and ongoing maintenance of Public Safety Grade 

communication systems. We have substantial experience in the engineering, implementation and 

maintenance of public safety grade, manufacturing and construction company communication 

systems. We extensive experience in microwave backhaul solutions, Project 25 solutions, UHF/VHF 

solutions and the integration of, camera systems and fiber backhaul. 

AMK Services is in the business of providing complete communications solutions to customers 

throughout the Midwest. It is our belief that by providing our customers with more cost effective 

tower and pipeline communications solutions we can ensure that the police, fire and utility companies 

reduce potential safety issues and receive a better return on investment of their ever shrinking tax 

dollars. 

AMK staff qualifications include a number of Degreed System Engineers, Senior System 

Technicians, P25 System Technicians, Project Managers, Vehicle Specialist, and Journeymen 

Technicians. All AMK personnel are background checked through a national screening process and 

then a local background check for each customer project. All AMK employees are required to 

complete a pre-employment drug screening. AMK also has instituted a monthly random drug 

screening policy for all employees and incorporated a companywide safety program. 

The name and address of the applicant is: AMK Services LLC.

Attn: Greg Graham.

Chief Executive Officer

9291 Crouse Willison Road

Johnstown, Ohio 43031

740-975-1127

Greg@amk-services.com

www.AMK-Services.com
U.S. Department of Transportation May 21, 2015

Request for Exemption

For use of UAV Page 4

2.Description of Operations

AMK Services requests permission to operate a small, unmanned, lightweight and relatively 

inexpensive aircraft system, the DJI Phantom 2 Quadcopter (“Phantom 2”) under controlled 

conditions in airspace that is limited and predetermined. This will enable AMK Services to safely 

and efficiently inspect and monitor Public Safety Towers and Pipeline Right of ways and other 

customers managed by AMK Services

One of the major costs and pitfalls in any communication business is the hiring and monitoring of 

tower climbers. Although necessary for the installation of much of our equipment, there is an 

extensive cost and risk that is associated with tower climbs for the sole purpose of inspecting lines, 

cables and microwave dishes. In particular, the recent damages incurred to our customer’s towers and 

their equipment during the winter storms required tower crews and AMK personnel to make decisions 

about structural integrity from the ground without a way to perform up close inspections prior to 

climbing. Ice and snow build up on the towers as well as lightning strikes during the summer require 

visual inspection by tower climbers that must ascend towers after storms to determine line, antenna 

and microwave dish damage and misalignment. These costs and risks can be significantly reduced if 

not eliminated by the use of Unmanned Arial Vehicles to determine the extent of damage and 

misalignment prior to towers crews being dispatched. Additionally, by understanding what 

equipment and replacement parts are needed ahead of time, AMK personnel can reduce the number of 

climbs by half. This process would significantly reduce the cost to local municipalities whose 

budgets are already strapped while at the same limit climbs by inspecting tower structures remotely. 

The Unmanned drone is ideal for this industry and has unlimited potential in reducing cost while 

significantly reducing the need for tower climbs 

Your approval of AMK Services’ request of the Exemptions stated herein will benefit the public, 

Tower Climbing personnel. The Exemptions will also reduce direct and indirect financial impacts on 

each of our customers and reduce or eliminate expensive surveying and aerial photography by 

conventional manned aircraft. The Exemptions will enable AMK Services to perform and provide 

real time data to Towers Crews, Cities and Counties to determine tower and antenna integrity and 

repair solutions without potentially dangerous climbs.

2.1 Description of UAS

AMK Services requests the Exemptions for use of the Phantom, a small unmanned aircraft system 

(“UAS”), for nonprofit land and conservation easement management, site inspections, monitoring, 

conducting necessary aerial surveying, mapping, and aerial photography.

2.1.1 Flight Time and Weight

The high capacity, high performance 5200mAh Lithium Polymer battery offers up to 25 minutes of 

flight time. It provides battery capacity data, over charge/discharge protection, as well as maintenance 

reminders making the battery extremely safe and reliable. 

The Phantom weighs less than three pounds.
U.S. Department of Transportation May 21, 2015

Request for Exemption

For use of UAV Page 5

2.1.2 Live GPS Feedback

The Phantom is equipped with GPS that displays the current position of the Phantom in relation to the 

operator. Exceeding the control range of the remote control triggers the Phantom to automatically fly 

back to the original takeoff point and land safely.

2.1.3 Precision Flight and Stable Hovering

An integrated GPS auto-pilot system that offers position holding, altitude lock and stable hovering 

allows you to focus attention to be focused on shooting.

2.1.4 Mobile Vision

The operator may track the current flight and see what the Phantom sees through a mobile device.

2.1.5 Manufacturer Updates

The Phantom can connect to computers to receive manufacturer (DJI) firmware and applications, 

updates, news, alerts, and support.

2.1.6 Remote Control

The remote control contains a gimbal control dial, a trainer port, a built-in rechargeable LiPo battery 

with a capacity of 2000mAh, battery level LED indicators, and a throttle locking feature.

2.1.7 Antistatic Compass

The Phantom has an anti-static compass with a protective shell. Together, these equipment features 

ensure AMK Services and the UAS will “not create a hazard to users of the national airspace system 

or the public.”

2.1.8 Flight Limitation Application

In order to increase flight safety and prevent accidental flights in restricted areas, the firmware for the 

Phantom 2 series includes a No Fly Zone feature. These zones have been divided into two categories 

that prevent inadvertent flyover of restricted areas that are uploaded into the onboard computer prior 

to flight and as part of the pre-flight checklist

The Phantom has software to prevent the UAS from flying into restricted areas, such as airports. The 

software creates a five mile safety zone around the restricted area. The operator is notified when the 

Phantom is 330 feet away from a safety zone. If the Phantom is five miles from an airport, the UAS 

cannot fly higher than 400 feet. This height limit decreases as the UAS moves closer to the airport so 

that when the UAS is 1.5 miles away, the Phantom may not fly higher than 35 feet. If this occurs, the 

operator has full control of the Phantom’s movement, except that the Phantom will automatically 

descend to the restricted height. The operator is prevented from initiating flight if the Phantom is 

within 1.5 miles from a restricted area. If the operator accidentally flies into a safety zone due to a 

loss of GPS signal, the Phantom will land immediately once the signal returns. If this occurs, the 

operator may control the Phantom, with the exception that the operator cannot make the UAS ascend 

in altitude. In addition, the Phantom has features that allow the operator to manually set height 

limitations and limit how close a Phantom may fly to a safety zone.
U.S. Department of Transportation May 21, 2015

Request for Exemption

For use of UAV Page 6

2.1.9 Phantom Equipment Factory Specifications

2.1.9.1 Key Features

 Stabilization Gimbal 3- axis Camera Stabilization Gimbal

 Video Downlink Max 700m Wi-Fi Connection

 Camera 14 Megapixels/1080p

 Controllable Range -90° – 0° (Vertical)

 Ground Station Built into the DJI Phantom App

 Remote ControlNew version (left dial, built-in LiPo battery)

 800m (FCC), 5,8 Ghz preinstalled smartphone holder

 Max Flight Time 25 minutes

2.1.9.2 Aircraft

 Weight (Battery & Propellers included): 1284g (approximately 2.8 lbs)

 Battery 5200mAh LiPo Battery

 Max Ascent/Descent Speed: Ascent: 6 m/s

 Descent: 2m/s

 Max Flight Speed: 15 m/s

 Max Yaw Angular Velocity: 200°/s

 Max Tilt Angle: 35°

 Diagonal Length: 350mm

2.1.9.3 Camera

 Gimbal Pitch Control Range: 0°-90°

 Operating Environment Temperatures: 0°C-40°C

 Sensor Size: 1/2.3”

 Effective Pixels: 14 Megapixels

 FOV: 110°/85°

Information from www.dji.com/products/compare-phantom. See also DJI – Phantom 2 

Specifications “Exhibit B” attached hereto.
U.S. Department of Transportation May 21, 2015

Request for Exemption

For use of UAV Page 7

2.1.9.4 Remote Control

 Operating Frequency: 5.728 GHz-5.85 GHz

 Communication Distance (Open Area): CE: 400m

 FCC: 800m

 Receiver Sensitivity (1% PER): -93dBm

 Transmitter Power (EIRP): CE: 25mw

 FCC: 100mw

 Working Voltage: 120 mA@V

 Battery LiPo Battery: 3.7V 2000mAH

 Left Dial: Available

 Throttle Lock: Available

 Trainer Port: Available

2.1.9.5 Range Extender

 Operating Frequency: 2412-2462 MHz

 Communication Distance (Open Area): 500-700m

 Transmitter Power: 20dBm

 Power Consumption: 2W
U.S. Department of Transportation May 21, 2015

Request for Exemption

For use of UAV Page 8

2.2 Limited and Predetermined Use

AMK Services agrees to be bound by the following limitations and conditions when conducting 

management, inspection, mapping, surveying, and monitoring operations under an FAA issued 

exemption:

 Phantom Weight: The UAS will weigh less than three pounds including energy source(s) and 

equipment. Operations authorized by this grant of exemption are limited to the following 

aircraft: DJI Phantom 2. [See “Exhibit B” attached hereto.]

 Limited Flight Speed: The UAS will not be flown at a speed exceeding a ground speed of 30 

knots.

 Flight Altitude Limit: Flights will be operated at an altitude of no more than 400 feet above

ground level.

 VLOS: The UAS will be operated within the visual line of sight (“VLOS”) of the pilot in 

command at all times. This requires the pilot in command (“PIC”) to be able to use human 

vision unaided by any device other than corrective lenses.

 VO: All operations will use a visual observer (“VO”). The VO may be used to satisfy the 

visual line of sight requirement, as long as the PIC always maintains VLOS capability. The 

VO and PIC must be able to communicate verbally at all times.

2.3 Preflight Inspection

Prior to each flight, the PIC will 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 re-inspected and 

found to be in a condition for safe flight.

If there is a ground control station, it must be included in the preflight inspection. All maintenance 

and alterations will be properly documented in the UAS records.

2.4 Flight Functional Test

Any UAS that has undergone maintenance or alterations that affect UAS operations or flight 

characteristics such as the replacement of a flight critical component will undergo a flight functional 

test. The PIC who conducts the flight functional test will make an entry in the UAS aircraft records 

of the flight.

2.5 Manufacturing Requirements

AMK Services will follow the manufacturer’s aircraft/component, maintenance, overhaul, 

replacement, inspection, and life limit requirements. At a minimum, this will include requirements 

for the following: actuators, transmission (single rotor), power plant (motors), propellers, electronic 

speed controller, batteries, mechanical dynamic components (single rotor), remote command and 

control, and ground control station (if used).
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2.6 Operating and Flight Precautions

 The UAS will not be operated directly over any person, except authorized and consenting 

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

event of a UAS failure or emergency.

 Regarding the distance from participating persons, those persons must be essential to the 

mandatory conservation and environmental monitoring operations and any surveying 

operations. Because these procedures are specific to participating persons, no further Flight 

Standards District Office (“FSDO”) or Aviation Safety Inspector approval is necessary for 

reductions to the distances specified.

 Regarding the distance from non-participating persons, AMK Services will ensure that no 

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

necessary for the mandatory conservation and environmental monitoring operations and any 

surveying operations. This provision may be reduced to no less than 200 feet if it would not 

adversely affect safety and the Administrator has approved the reduction.

 If the UAS loses communications or loses the GPS signal, the UAS will return to the original 

takeoff point.

 The UAS will abort the flight in the event of unpredicted obstacles or emergencies. Each 

UAS operation must be completed within 25 minutes flight time or with 25% battery power 

remaining, whichever occurs first.

2.7 COA

AMK Services will obtain an Air Traffic Organization (“ATO”) issued Certificate of Waiver or 

Authorization (“COA”) prior to conducting any operations. This COA will require AMK Services to 

request a Notice to Airmen (“NOTAM”) not more than 72 hours in advance, but not less than 48 

hours prior to operations.

2.8 Maintenance

AMK Services will 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.

2.9 Safety Bulletins

The UAS will be operated by AMK Services in compliance with all manufacturer Safety Bulletins.

2.10 Radio Frequency

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

UAS will comply with the Federal Communications Commission (“FCC”) or other appropriate 

government oversight agency requirements.
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2.11Plan of Activities

At least three days before scheduled use, AMK Services will submit a written Plan of Activities to the 

local FSDO with jurisdiction over the area of proposed UAS use. The three-day notification may be 

waived with the concurrence of the FSDO. The Plan of Activities will include at least the following:

 Date and times for all flights.

 Name and phone number of the operator of the UAS under this grant.

 Make, model, and serial or FAA issued N-number or registered number of UAS to be used.

 Name and age of the UAS’s PIC involved.

 Statement that the operator has obtained permission from property owners and/or local 

officials.

 The signature of exemption-holder or representative.

 Description of the flight activity, including maps and diagrams of any area, city, town, county 

and/or state over which UAS use will be conducted and the altitudes essential to accomplish 

the operation. UAS operations will not be conducted during night, as defined in 14 C.F.R. § 

1.1.

 All operations will be conducted under visual meteorological conditions (“VMC”).

2.12 Documents

The manufacturer’s Flight User Manual will be available to the PIC at the ground control station or 

ground control point of the UAS any time the aircraft is operating.

2.13 Right of Way

The UAS will remain clear of and yield the right of way to all manned aircraft operations and 

activities at all times.

2.14 Operations

 The UAS operations will not be conducted at night, as defined in 14 C.F.R. § 1.1. All 

operations will be conducted under VMC.

 The UAS will not be operated by the PIC from any moving device or vehicle. 

 The UAS will not be operated less than 500 feet below or less than 2,000 feet horizontally 

from a cloud or when visibility is less than three statute miles from the PIC.

 The UAS will not be operated in Class B, C, or D airspace. The UAS will not be operated 

within five nautical miles of the geographic center of a non-towered airport as denoted on 

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 Notice to Airmen 

as required by the Applicant’s COA. The letter of agreement with the airport management 

will be made available to the Administrator upon request.
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2.15Accident Reports

Any incident, action, 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 Integration Office 

(AFS-80) within 24 hours. Accidents will be reported to the National Transportation Safety Board 

(“NTSB”). Further flight operations will not be conducted until the incident, accident, or 

transgression is reviewed by the AFS-80 and authorization to resume is provided.

3. AMK Services’ Request for Exemptions

AMK Services understands that the government is readying rules largely favorable to companies that 

want to use small drones for commercial purposes, according to a federal analysis, potentially leading 

to the widespread flights by unmanned aircraft performing aerial photography, crop monitoring, 

inspections of cell towers and bridges and other work. Due to the Phantom’s small size, light weight 

(less than three pounds), built-in safety features, and the remote, rural, and restricted locations where 

the Phantom will be operated, AMK Services can meet all requirements of safe UAS operations 

envisioned by Congress.

The UAS’s size, weight, limited range and flight capacity, and restricted use on towers and pipelines

managed, inspected, and monitored by AMK Services in no way presents a national security issue. 

The Exemptions requested by AMK Services provide for the equivalent, if not a higher, level of 

safety than the current regulatory scheme provides due to the dangers associated with much larger, 

heavier, and faster conventional manned aircraft.

In the alternative, AMK Services’ operations meet the “special purpose operations” descriptions of

14 C.F.R. § 21.25 (b)(3)Aerial Surveys, Photography, and Mapping.

3.1 Exemption Requests

Based on the facts and descriptions we have provided for you on behalf of AMK Services, we 

respectfully request that the FAA grant the following requested exemptions:

14 C.F.R. § 21, Subpart H; 14 C.F.R. § 43.7; 14 C.F.R. § 43.11; 14 C.F.R. §

45.21; 14 C.F.R. § 45.23(b); 14 C.F.R. §45.25; 14 C.F.R. § 45.27; 14

C.F.R. § 45.29; 14 C.F.R. § 47.3(b)(2); 14 C.F.R. § 61, Subpart E; 14 C.F.R.

§ 91.7(a); 14 C.F.R. § 91.9(b)(2); 14 C.F.R. § 91.9(c); 14 C.F.R. § 91.103;

14 C.F.R. § 91.105; 14 C.F.R. § 91.109; 14 C.F.R. § 91.113(b); 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; 14

C.F.R. § 91.215; 14 C.F.R. § 91.405(a) and (d); 14 C.F.R. § 91.407(a)(1); 14

C.F.R. § 91.409(a)(2); 14 C.F.R. § 417(a) and (b).

3.1.1 14 C.F.R. 21, Subpart H: Airworthiness Certificate

AMK Services requests an exemption from 14 C.F.R. 21, Subpart H. This Subpart establishes the 

procedures for the issuance of an airworthiness certificate. AMK Services requests an exemption 

from Part 21, Subpart H because the Phantom meets an equivalent level of safety pursuant to Section 

333 of the Reform Act due to its small size, light weight, and remote rural operating environment.
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3.1.2 14 C.F.R. 43

3.1.2.1 43.7: Persons Authorized to Approve Maintenance, Rebuilding, and

Operation

AMK Services requests an exemption from 14 C.F.R. 43.7. This part provides that the holder of a 

mechanic certificate or a repair station certificate may approve an aircraft, airframe, aircraft engine, 

propeller, appliance, or component part for return to service. AMK Services operators will conduct 

inspections and maintenance based on maintenance guidelines provided by DJI, the manufacturer of 

the Phantom. The capabilities of AMK Services operators to maintain and repair the UAS will meet 

the requirements for an equivalent level of safety pursuant to Section 333 for this type of UAS, its 

intended use, and the remote rural operating environment.

3.1.2.2 43.11: Records for Inspections

AMK Services requests an exemption from 14 C.F.R. 43.11. This part provides that maintenance 

record entries be maintained, that the inspector list discrepancies, and to affix placards to the aircraft. 

This UAS, due to its small size, does not have room for placards to be placed in or on it and no 

inspections for UAS have been certified by FAA at the present time. However, as a condition to the 

grant of the exemption, AMK Services is willing to keep records and log books of all maintenance 

and repairs.

3.1.3 14 C.F.R. 45

3.1.3.1 45.21: General

AMK Services requests an exemption from 14 C.F.R. 45.21. This part provides that except as 

provided in § 45.22, no person may operate a U.S.-registered aircraft unless that aircraft displays 

nationality and registration marks in accordance with the requirements of this section and §§ 45.23 

through 45.33. There are no current procedures for obtaining a registration mark for UAS by the 

FAA.

However, as a condition to the grant of the exemption, AMK Services is willing to be assigned a 

registration number and to display it where practicable as addressed in this Request and Application 

for Exemptions relative to Parts 45.23, 45.27, and 45.29, below.

3.1.3.2 45.23 (b): Marking of the Aircraft

AMK Services requests an exemption from 14 C.F.R. 45.23(b). This regulation requires: When 

marks include only the Roman capital letter "N" and the registration number is displayed on limited, 

restricted or light-sport category aircraft or experimental or provisionally certificated aircraft, the 

operator must also display on that aircraft near each entrance to the cabin, cockpit, or pilot station, in 

letters not less than 2 inches nor more than 6 inches high, the words "limited," "restricted," "lightsport," "experimental," or "provisional," as applicable.

Even though the UAS will have no airworthiness certificate, AMK Services requests an exemption 

from this requirement since the Phantom will have no entrance to the cabin (no cabin), cockpit (no 

cockpit), or pilot station on which the word “Experimental” or such other required description can be 

placed. Given the size of the UAS, two-inch lettering will be impossible, AMK Services is willing to 

place the word “Experimental” on the UAS in compliance with § 45.29(f). The equivalent level of 

safety will be provided by having the UAS marked as required by § 45.29(f) where the pilot, observer 
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and others working with the UAS will see the identification of the UAS as “Experimental” or such 

other required lettering.

3.1.3.3 45.25: Location of Marks on Fixed-Wing Aircraft

AMK Services requests an exemption from 14 C.F.R. 45.25. The UAS is a multirotor, quadcopter, 

model-sized aircraft and is not a fixed-wing aircraft. Therefore, 14 C.F.R. 45.25 by its terms does not 

apply.

3.1.3.4 45.27: Location of Marks: Nonfixed-Wing Aircraft

AMK Services requests an exemption from 14 C.F.R. 45.27. This part provides that each operator of 

a rotorcraft must display on that rotorcraft horizontally on both surfaces of the cabin, fuselage, boom, 

or tail the marks required by § 45.23. The UAS, due to its small size, does not have a cabin, fuselage, 

boom or tail to display the marks required by § 45.23.

3.1.3.5 45.29: Size of Marks

AMK Services requests an exemption from 14 C.F.R. 45.29. This part provides at subpart (3) that the 

registration marks for rotorcraft must be at least 12 inches high. The UAS, due to its small size, does 

not have any surface area large enough to display marks anywhere near 12 inches high. However, as 

a condition to the grant of the exemption, AMK Services is willing to place an aircraft mark on one or

more of the "arms" of the UAS. The size of the marking will be determined by the size of the "arm" 

being used and may be less than one inch in size.

3.1.4 14 C.F.R. 47.3(b)(2): Registration Required

AMK Services requests an exemption from 14 C.F.R. 47.3(b)(2). This part provides: (b) No person 

may operate an aircraft that is eligible for registration under 49 U.S.C. 44101-44104, unless the 

aircraft:

 Has been registered by its owner; [or]

 Is carrying aboard the temporary authorization required by § 47.31(c).

There are no current procedures for obtaining a registration mark for UAS by the FAA. However, as a 

condition to the grant exemption, AMK Services is willing to be assigned a registration number 

provided by FAA and to display it where practicable as addressed in this Request and Application for 

Exemptions relative to Parts 45.23, 45.27, and 45.29, above.

3.1.5 14 C.F.R. 61, Subpart E – Certification: Private Pilots

AMK Services requests an exemption from 14 C.F.R. 61, Subpart E. Section 61, Subpart E describes 

the requirements for issuance of private pilot certificates and the general operating rules for persons 

who hold those certificates and ratings. Because the UAS will not carry a pilot or passengers, the 

proposed operations can achieve the equivalent level of safety of current operations by requiring the 

PIC operating the UAS to have completed a UAS flight training course before flying the UAS (See 

DJI – Phantom Pilot Training Guide, Phantom 2 User Manual, and Courses of Training fro 

Certification).

Unlike a conventional manned aircraft that carries the pilot and passengers, the UAS is small in size, 

weighs three pounds or less, is remotely controlled, and has no humans on board. The area of 

operation is controlled and restricted, and all flights are planned and coordinated in advance. The 

level of safety exceeds that provided by a single individual holding a commercial pilot’s certificate 
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operating a conventional manned aircraft. The risks associated with the operation of the UAS are 

much reduced from the level of risk associated with conventional manned aircraft operations 

contemplated by Part 61. Allowing the Exemptions and special purpose operations of the UAS as 

requested by AMK Services with an operator who has met the requirements of safety and training as 

stated in the DJI – Phantom Training Guide and User Manual. AMK has also completed the 

Scheduled DJI Phantom Training Course, and will have completed the Pilot Training program 

Certificate from The Unmanned Experts Training Academy which exceeds the present level of safety 

prescribed by 14 C.F.R. § 61.113 (a) and (b). Additionally, in the interim, AMK Services has on staff 

a fully licensed Commercial pilot. His license and information is presented in Exhibit “E”

3.1.6 14 C.F.R. 91

 See DJI – Phantom 2 Training Guide, “Exhibit “A” attached hereto.

 See DJI – Phantom 2 User Manual, “Exhibit “B” attached hereto.

 See DJI – Phantom 2 Release Notes Dates Feb 2015l, “Exhibit “C” attached hereto.

 See List of Training Courses from Unmanned Experts, “Exhibit “D” attached hereto;

http://www.unmannedexperts.com/wp-content/uploads/140610-UMEX-Training-CourseBrochure-US.pdf

AMK Services requests an exemption from 14 C.F.R. 91.7(a). The regulation requires that no person 

may operate a civil aircraft unless it is in airworthy condition. Given the small size, light weight, and 

low noise level output of the UAS, the requirements for maintenance, and the use of safety checklists 

prior to each flight, an equivalent level of safety will be provided.

3.1.6.1 91.9(b)(2): Civil Aircraft Flight Manual [in the Aircraft], Marking, and

Placard Requirements

AMK Services requests an exemption from 14 C.F.R. 91.9(b)(2). Section 91.9(b)(2) provides:

No person may operate a U.S.-registered civil aircraft for which an Airplane or Rotorcraft Flight 

Manual is not required by § 21.5 of this chapter, unless there is available in the aircraft a current 

approved Airplane or Rotorcraft Flight Manual, approved manual material, markings, and placards, or 

any combination thereof.

The UAS, given its small size and configuration, has no ability or place to carry such a flight manual 

on the aircraft, not only because there is no pilot on board, but because there is no room or capacity to 

carry such an item on the UAS.

The equivalent level of safety will be maintained by keeping the manufacturer’s Training Guide and 

User Manual at the ground control point where the operator flying the UAS will have immediate 

access to it.

3.1.6.2 91.9(c): Civil Aircraft Flight Manual, Marking, and Placard Requirements

AMK Services requests an exemption from 14 C.F.R. 91.9(c). This part provides: No person may 

operate a U.S.-registered civil aircraft unless that aircraft is identified in accordance with part 45 of 

this chapter.

As stated above, there is no current registration process for UAS; and the UAS, due to its small size, 

does not have room to contain a fireproof placard or to display aircraft marks in a conventional size. 

However, as a condition to the grant of the exemption, AMK Services is willing to affix an aircraft 
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mark to one or more of the "arms" of the UAS. The size of the marking will be determined by the 

size of the "arm" being used and may be less than one inch in size.

3.1.6.3 91.103: Preflight Action

AMK Services requests an exemption from 14 C.F.R. 91.103. This regulation requires each

PIC to take certain actions before flight to insure the safety of flight. As FAA approved rotorcraft 

flight manuals will not be provided for the UAS, an exemption is needed. The PIC will take all 

actions following the DJI preflight inspection including reviewing weather, flight battery 

requirements, landing and takeoff distances and aircraft performance data before initiation of flight.

3.1.6.4 91.105: Flight Crewmembers at Stations

AMK Services requests an exemption from 14 C.F.R. 91.105. AMK Services requests an exemption 

from 14 C.F.R. 91.105 since this part is not applicable due to the UAS carrying no flight 

crewmembers. However, to achieve an equivalent level of safety, AMK Services will not operate the 

aircraft unless the same PIC is at the controls at all times.

3.1.6.5 91.109: Flight Instruction; Simulated Instrument Flight and Certain Tests

AMK Services requests an exemption from 14 C.F.R. 91.109. Section 91.109 provides that no person 

may operate a civil aircraft (except a manned free balloon) that is being used for flight instruction 

unless that aircraft has fully functioning dual controls. UAS and remotely piloted aircraft, 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. The FAA has approved 

exemptions for flight training without fully functional dual controls for a number of aircraft and for 

flight instruction in experimental aircraft. The equivalent level of safety is provided because the UAS 

will not carry pilots or passengers, and relevant landowners will have prior notice of each flight.

3.1.6.6 91.113(b): Right-of-Way Rules

AMK Services requests an exemption from 14 C.F.R. 91.113(b) to the extent that it applies to 

overhead aircraft operating at or above 500 feet above ground level as the UAS will be operating no 

higher than 400 feet above ground level. This part provides:

 General. When weather conditions permit, regardless of whether an operation is conducted 

under instrument flight rules or visual flight rules, vigilance shall be maintained by each 

person operating an aircraft so as to see and avoid other aircraft. When a rule of this section 

gives another aircraft the right-of-way, the pilot shall give way to that aircraft and may not 

pass over, under, or ahead of it unless well clear.

For example, if another aircraft is operating overhead at 10,000 feet above ground level, there is no 

danger posed to that other aircraft if the UAS is operating beneath 400 feet above ground level. 

However, as a condition to the approval of exemption, AMK Services will operate its UAS to see and 

avoid and give way to other aircraft that should enter airspace at or below 400 feet above ground 

level.

3.1.6.7 91.119: Minimum Safe Altitudes

AMK Services requests an exemption from 14 C.F.R. 91.119. Section 91.119 establishes safe 

altitudes for operation of civil aircraft. Section 91.119(c) prevents flying an aircraft at an altitude of 

less than 500 feet or operating an aircraft closer than 500 feet to any person, vessel, vehicle, or 
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structure. As this exemption requests authority to operate at altitudes up to 400 feet, an exemption is 

needed to allow such operations. As set forth herein, the UAS will never operate at higher than 400 

feet above ground level. It will however be operated in a remote area on private property with the 

landowner’s consent.

The equivalent level of safety will be achieved given the size, weight, limited speed of the UAS as 

well as the remote location where it is operated. No flight will be taken without the permission of the 

landowner or local officials. Because of the advance notice given to the landowner, all affected 

individuals will be aware of the planned flight. Compared to flight operations with aircraft or 

rotorcraft weighing far more than the three pounds proposed herein and the lack of flammable fuel on 

the UAS, any risk associated with the UAS operations is far less than those presently presented with 

conventional aircraft operating at or below 500 feet above ground level for environmental monitoring. 

In addition, the low-altitude operations of the UAS will ensure separation between these small-UAS 

operations and the operations of conventional manned aircraft that must comply with Section 91.119.

3.1.6.8 91.121: Altimeter Settings

AMK Services requests an exemption from 14 C.F.R. 91.121. 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 UAS may not have a barometric altimeter, but instead a GPS altitude read out, an exemption is 

requested. An equivalent level of safety will be achieved by the operator confirming the altitude of 

the launch site shown on the GPS altitude indicator before flight as well as the operator receiving live 

feedback information about the UAS, including the height of the UAS, its forward velocity, and 

compass heading. The operator will be able to observe and control the maximum height of the UAS. 

Additionally, the UAS will be operated within the line of sight of the PIC.

3.1.6.9 91.151(a): Fuel Requirements for Flight in Visual Flight Rules (“VFR”) 

Conditions

AMK Services requests an exemption from 14 C.F.R. 91.151(a). Section 91.151(a) prohibits an 

individual from beginning “a flight in an airplane under visual flight rules 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:

 During the day, to fly after that for at least 30 minutes; or

 At night, to fly after that for at least 45 minutes.”

The battery powering the UAS provides approximately 25 minutes of powered flight making it 

impossible to meet the 30 minute reserve requirement in 14 C.F.R. §91.151. Given the limitations on 

the UAS’s proposed flight area and the location of its proposed operations within a predetermined and 

remote area, a lower minimum battery power requirement in daylight or night VFR conditions is 

reasonable. AMK Services believes that an equivalent level of safety can be achieved by limiting 

flights to 25 minutes or 25 percent of battery power, whichever happens first. This restriction would 

be more than adequate to return the UAS to its planned landing zone from anywhere in its limited and 

remote operating area.

3.1.6.1091.203(a) & (b): Carrying Civil Aircraft Certification and Registration

AMK Services requests an exemption from 14 C.F.R. 91.203 (a) and(b). The regulation provides in 

pertinent part:
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Except as provided in § 91.715, no person may operate a civil aircraft unless it has within it the 

following:

 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 UAS fully loaded weighs less than 3 pounds and is operated without an onboard pilot. As such, 

there is no ability or place to carry certification and registration documents or to display them on the 

UAS. An equivalent level of safety will be achieved by keeping these documents at the ground 

control point where the pilot flying the UAS will have immediate access to them, to the extent they 

are applicable to the UAS.

3.1.6.1191.215: ATC Transponder and Altitude Reporting Equipment and Use

AMK Services requests an exemption from 14 C.F.R. 91.215. This section requires that installed Air 

Traffic Control (“ATC”) transponder equipment must meet specific performance and environmental 

requirements, and aircraft must be equipped with an operable coded radar beacon transponder.

There are presently no known commercially available ATC transponders that meet the payload 

requirements of a small UAS and are available at reasonable cost. However, because the UAS used 

by AMK Services will not be flying into or near airports, and will fly no higher than 400 feet above 

ground level, there is very low risk of collision with any manned aircraft. In addition, because there 

will be no need to have contemporaneous communication with Air Traffic Control, due to the short 

distances, short flight times, and restricted altitude the UAS will operate within, AMK Services

requests an exemption from this section. Additionally, the UAS is too small to contain ATC 

transponder equipment in any form that is known to be available commercially.

3.1.6.1291.405 (a) & (d); 407 (a)(1); 409 (a)(2); 417(a) & (b): Maintenance 

Inspections

AMK Services requests an exemption from 14 C.F.R. 91.405 (a) and (d); 407 (a)(1), 409(a)(2), and 

417 (a) and (b). These regulations require that an aircraft operator or owner “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 . . .,” and others shall inspect or maintain the aircraft in compliance with Part 43.

Given that these sections and Part 43 apply only to aircraft with an airworthiness certificate, these 

sections will not apply to AMK Services. Maintenance will be accomplished by the operator 

pursuant to the manufacturer’s Phantom 2 User Manual and Phantom Pilot Training Guide. An 

equivalent level of safety will be achieved because these small UAS are very limited in size and will 

carry a small camera and operate only in remote and restricted areas for limited periods of time. If 

mechanical issues arise, the UAS can land immediately and will be operating from no higher than 400 

feet above ground level. The operator will ensure that the UAS is in working order prior to initiating 

flight, perform required maintenance, and keep a log of any maintenance performed. Moreover, the 

operator is the person most familiar with the UAS and best suited to maintain the UAS in an 

airworthy condition to provide the equivalent level of safety.
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3.1.7 Summary for the Federal Register

The following summary is provided for publication in the Federal Register in accord with 14

C.F.R. Part 11:

AMK Services requests exemptions from the following rules:

14 C.F.R. 21, Subpart H; 14 C.F.R. § 43.7; 14 C.F.R. § 43.11; 14 C.F.R. §

45.21; 14 C.F.R. § 45.23(b); 14 C.F.R. §45.25; 14 C.F.R. § 45.27; 14

C.F.R. § 45.29; 14 C.F.R. § 47.3(b)(2); 14 C.F.R. § 61, Subpart E; 14 C.F.R.

§ 91.7(a); 14 C.F.R. § 91.9(b)(2); 14 C.F.R. § 91.9(c); 14 C.F.R. § 91.103;

14 C.F.R. § 91.105; 14 C.F.R. § 91.109; 14 C.F.R. § 91.113(b); 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; 14

C.F.R. § 91.215; 14 C.F.R. § 91.405(a) and (d); 14 C.F.R. § 91.407(a)(1); 14

C.F.R. § 91.409(a)(2); 14 C.F.R. § 417(a) and (b)

To operate commercially a small unmanned aircraft vehicle (three pounds or less) to monitor, map, 

aerially photograph, survey and perform usual inspections by air of Communications Towers, 

Pipelines and other structures maintained and monitored by AMK Services.

Allowing small UAS to be used for monitoring and inspection purposes enhances safety by 

eliminating risks associated with conventional surveillance operations, which traditionally use larger 

manned aircraft and must operate at low altitudes, weigh thousands of pounds, and carry large 

amounts of fuel. Approval of the Exemptions, in contrast, would allow a battery operated small UAS 

weighing less than three pounds and no human passengers to complete the same job with virtually no 

risk. Under these conditions, the Phantom will provide an equivalent, if not higher, level of safety in 

the environmental surveillance field, which supports the grant of this Request and Application for 

Exemptions.

4.Privacy

All flights will occur over private or controlled access property with the landowner’s prior consent 

and knowledge. Because overflight areas will be remote and rural, there is little to no chance that 

there will be inhabited houses in the visual area or other people who have not consented to being in 

close proximity with the Phantom. No attempt will be made to identify any individuals filmed during 

the flights except in cases where those persons are conducting unauthorized activities, are trespassing 

upon the AMK Services conservation easement lands, or are damaging any towers or resources under 

the management responsibility of AMK Services, or interfering with any of AMK Services’ 

inspection or monitoring operations.

5.Conclusion

Satisfaction of the criteria provided in Section 333 of the Reform Act of 2012 – size, weight, speed, 

operating capabilities, proximity to airports and populated areas, operation within visual line of sight, 

and national security – provide more than adequate justification for the grant of the requested 

Exemptions allowing AMK Services to use the Phantom for and during the management, research, 

and educational operations of AMK Services.
U.S. Department of Transportation May 21, 2015

Request for Exemption

For use of UAV Page 19

6.Exhibits Enclosed

6.1 Exhibit A - DJI – Phantom 2 User Training Guide

6.2 Exhibit B - DJI – Phantom 2 User Manual

6.3 Exhibit C - DJI-Phantom 2 Release Noted Dated 

Feb 2015

6.4 Exhibit D - Training Course Materials from 

Unmanned Experts Training Facility

6.5 Exhibit E - License and Pilot Information for

Robert Bailey. Pilot for AMK Services