Flightline Geographics LLC

150 Sunset Ridge, Dripping Springs, Texas 78620

www.flightlinegeographics.com

512.264.3246

May 14, 2015

U.S. Department of Transportation

Docket Management System

1200 New Jersey Ave., SE

Washington, DC 20590

Re: Flightline Geographics LLC Petition for Section 333 Exemption for RPA Technologies RQ-265 

Dear Sir or Madam,

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (FMRA) and 14 

C.F.R. Part 11, Flightline Geographics LLC (Flightline) is petitioning the Federal Aviation 

Administration (FAA) for an exemption from the Federal Aviation Regulations (FARs) requested 

below concerning small unmanned aerial systems (UAS). Section 333 of the FMRA promotes 

UAS integration into the national airspace by granting the FAA authority to allow for the safe 

operation of certain UAS within the national airspace.

Flightline specializes in aerial data collection for Geographic Information Systems (GIS). Flightline 

is the U.S. reseller for RPA Technologies Ltd (RPA) RQ-265 small UAS. Our team has attended 

factory training by RPA and continues to practice missions through the RQ-265 X-Planes 

Simulator plug-in, which provides a realistic mission planning and execution environment for 

rehearsing missions and gaining additional experience.

Flightline employs flight crews consisting of factory-trained or factory-supplied UAS pilots, FAAlicensed pilots, visual observers and post-processing GIS technicians. Flightline has participated 

in several government and university-run research projects under COAs in Texas since 2012, by 

providing aerial image capture consulting and processing. In addition, Flightline is aligned with the 

Lone Star UAS Center for Excellence and Innovation at Texas A&M University and plans to 

perform safe and controlled UAS operational testing for GIS applications under a variety of 

conditions and is willing to share the flight data with the FAA.

Flightline proposes to operate small UAS subject to restrictions and conditions thatwill ensure an 

equivalent level of safety and that are at least as stringent as those that FAA has found to be

acceptable in its most recent grants of petitions under Section 333, including numbers 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 DocketNo.FAA−2014−0642). Further, this petition raises no national 

security or privacy concerns. Flightline therefore respectfully submits that prompt grant of this 

petition is warranted.

As a GIS data content provider, Flightline will capture Remote Sensing data in a safe and 

effective manner for multiple industries and governmental uses. Forthis reason, Flightline will use 

the RPA Technologies RQ-265 with off-the-shelf Digital SLR cameras and other similar 

lightweight sensor technologies, as they become available. This aircraft weighs less than 55 

pounds and has been operated safely for several years with the approval of civil aviation 

authorities in several other countries including New Zealand, Australia, Canada and others. This 

aircraft, due to its advanced safety features, including the MILSPEC autopilot and emergency 
parachute landing mode, has even been approved for operation over urban areas in New 

Zealand by their CAA. The detailed specifications of the aircraft are listed in a section below.

Flightline will use experienced pilots and visual observers (VOs) for all of its UAS operations. All 

pilots and VOs will receive factory UAS training and flight hours in accordance with manufacturer 

operational manuals before approval to fly is given.

Flightline is requesting this exemption in order to provide services for many industries, including 

but not limited to:

1. Mapping and GIS – High definition image data for small-scale project locations that are 

not currently cost-effective or safe for manned capture (environmental studies, utilities, 

energy exploration, emergency management, wetlands delineation, storm damage 

assessment, pipeline inspection, etc.)

2. Government Agencies – Federal, State and Local (Local governments with small scale 

project areas and limited budgets will be better able to afford UAS services, as opposed 

to manned flights)

3. Engineering – Site assessment, construction, documentation

4. Insurance – Damage assessment and verification

5. Agriculture – NDVI processing of aerial imagery for vegetative health and general range 

management

Flightline is requesting to use the UAS in rural locations only for GIS data collection for a variety 

of end user customers. These project locations will fall outside of heavily populated areas when 

plotted onVFR Sectional Aeronautical Charts and other map-based GIS sources and will not be 

within five (5) miles of any airport (unless FAA has approved such operations and Flightline has a 

written agreement with the airport manager).

Flightline’s initial work will take place near its main office in Dripping Springs, TX. Projects will be 

pursued initially within Texas and surrounding states, and may expand to other locations that are 

economically suitable. 

Flightline is submitting the manufacturer’s Flight Operations Manual, Maintenance Manual and 

sample SOP Flight Ops Checklist confidentially pursuant to 14 CFR Section 11.35(b). The

Manuals contain confidential, proprietary and commercially sensitive information that has not 

been made available to the public and that is protected under the Freedom of Information Act, 5

U.S.C. § 552, et seq.

Petitioner Name and Address: 

Flightline Geographics LLC

150 Sunset Ridge

Dripping Springs, TX 78620

Devon Humphrey – CEO

devon@flightlinegeographics.com
Exemptions Requested:

Flightline Geographics LLC is requesting this waiver as it applies to the following FARs:

• 14 CFR Section 61.113 (a) and (b): Private pilot privileges and limitations

• 14 CFR Section 61.23 (a) and (c): Operation with a driver’s license in lieu of FAA medical 

certificate

• 14 CFR Section 61.101 (e)(4) and (5): Allow private pilot certificate holder to operate UAS for 

compensation

• 14 CFR Section 61.113(a): Allow sport pilot certificate holder to operate UAS for 

compensation 

• 14 CFR Section 61.315(a): Allowing holder of sport pilot certificate to serve as PIC of UAS

• 14 CFR Section 91.7(a): Civil aircraft airworthiness

• 14 CFR Section 91.119(c): Minimum altitude requirements

• 14 CFR Section 91.121: Altimeter requirements

• 14 CFR Section 91.151(a)(1): Fuel requirements

• 14 CFR Section 91.405(a): Maintenance requirements

• 14 CFR Section 91.407(a): Maintenance requirements

• 14 CFR Section 91.409(a)(1)(2): Inspection frequency

• 14 CFR Section 91.417(a)(b): Maintenance records

Flightline’s History

Flightline has been processing and delivering GIS data in the form of aerial visual intelligence 

from manned and unmanned platforms since 2012. Flightline has participated on previous 

projects for Federal Agencies and major Public Universities under FAA COAs. Flightline’s role 

has been as a GIS subject matter expert and data processing service provider working with UAS 

data for agricultural and emergency management applications. This has provided exposure to 

and participation in professionally-run and safe UAS flight operations since 2012. With the growth 

of the UAS industry and recent commercial exemptions that have been granted, Flightline is 

petitioning to safely and legally operate its own UAS in the National Airspace.

Flightline is the U.S. reseller for the RQ-265 UAS manufactured in New Zealand. This aircraft has 

been accepted by civil aviation authorities in New Zealand, Australia, Canada and many other 

modern countries. The aircraft can carry true color (RGB), infrared (IR) and other lightweight 

sensors for specialized imagery applications for GIS and mapping, including agriculture, 

engineering, environmental and energy transmission line right-of-way monitoring. The system is 

hand-launched and parachute-landed and its safety features are recognized by civil aviation 

authorities in the countries listed above. 

The RQ-265 includes a MILSPEC DTA autopilot which incorporates many recognized safety 

features, including automated flight termination system by parachute under a variety of fault 
conditions, maintenance of a Minimum Safe Altitude (MSA) and terrain collision avoidance 

measures using the world-wide SRTM elevation model. While the system is designed to be able 

to operate beyond line-of-sight, Flightline will not operate in this mode, always remaining within 

line-of-sight of the PIC and VO.

Summary of operations

1. All flights will be conducted in accordance with the manufacturer’s Flight Operations 

Manual (FOM), following Visual Flight Rules (VFR).

2. The UAS with payload will weigh less than 55 pounds.

3. All flights will include a Pilot in Command (PIC) and Visual Observer (VO). Flights will be 

operated within visual line of sight of the PIC and VO. The PIC and VO will be able to

communicate verbally at all times.

4. The PIC and VO will have manufacturer’s training and flight hours with the RQ-265 in

accordance with the manufacturer’s requirements. 

5. The PIC must hold at least an FAA Sport Pilot Certificate. The PIC must also hold a 

current valid U.S. driver’s license issued by a state, the District of Columbia, Puerto Rico, 

a territory, a possession, or the Federal government.

6. Prior to each flight, the PIC will inspect the UAS to confirm that it meets manufacturer 

specifications for safe flight. The UAS ground control system software requires that all 

items on the pre-flight checklist be completed prior to initiating a launch. 

7. After a maintenance event involving a critical component of the UAS, a test flight will be 

performed and logged in the aircraft maintenance logs.

8. A pre-flight briefing will be conducted describing the planned UAS mission prior to each

flight. This pre-flight briefing is delivered by the PIC and is mandatory for all VOs. 

9. All flights will be conducted within a defined “sterile area” containing a security perimeter 

for the flight operations area. These areas, along with any identified “UAS no fly zones” 

around tall structures or elevation features will be clearly identified on the flight ground 

control station computer, where the location and status of the aircraft is also monitored in 

real time.

10. All required permissions and notifications to federal, state and local governments, 

including law enforcement, fire or other appropriate governmental agencies. 

11. Written or verbal permission from the property owner will be obtained.

12. In accordance to the manufacturer’s FOM, both primary and alternate landing areas will 

be designated before any UAS flight is attempted.

13. The UAS will not be flown at night or when weather conditions may prevent a visual

observation of the vehicle throughout the duration of the flight.

14. Maximum flight time will be less than 90 minutes per the manufacturer’s recommendation. 

The UAS autopilot monitors battery charge in real time and will enter return mode and 

land at the pre-designated landing location with 20% battery remaining.

15. Airspeed will not exceed 87 knots

16. Flights will be operated at an altitude of 400 feet AGL or less and more than 100 feet 

above any building or structure to be imaged or inspected.

17. The UAS will remain clear and yield to all manned aircraft.

18. If GPS signal is lost but communications link remains, the PIC will manually return the 

aircraft to one of the pre-determined landing zones or perform an immediate landing as 

per the manufacturer’s FOM.

19. In the unlikely event of a lost link/communication loss, the RQ-265 is preprogrammed to 

return to a pre-designated landing location within the security perimeter and to perform a 

safe automated landing procedure by parachute. 
20. Flightline will follow all manufacturer maintenance and inspection procedures, schedules

and documents for the UA and log each event in the aircraft maintenance logs in 

accordance with the manufacturer’s FOM.

Aircraft to be Used

Flightline Geographics will be operating the RQ-265 UAS from RPA Technologies Ltd. The RQ265 is an all-electric aircraft that provides precision 3D mapping and real- time thermal infrared 

and full motion video capabilities. The system is hand-launched and parachute landed. A detailed 

pre-flight procedure is prescribed by the manufacturer in its FOM and must be confirmed prior to 

any flight within the flight control software. (A launch will not be allowed by the software if any 

items from the pre-flight checklist are missed.) The RQ-265 is the 2015 version of the RQ-84Z, 

which has aproven safety record in several countries throughout the modern world, including New 

Zealand, Australia, Canada, Mexico, Mongolia, Turkey, among others. 

The RQ-265 is landed by parachute and provides an excellent platform for aerial sensing 

operations. The parachute is both an emergency and automated primary landing method for the 

RQ-265. A skid landing is also an option, though not the preferred method. The RQ-265 is well 

suited for collection of larger project areas (i.e. approximately one square mile, or slightly more, 

per flight) due to its long endurance.

RPA RQ-265 Specifications include:

•Wing Span: 102”

•Length: 43.2”

•Weight 11 lbs with standard camera payload

•Top speed: 45 knots

•Cruise Speed: 32 knots

•Endurance: 1.5 hours

Extent of relief

Flightline seeks an exemption from several provisions of 14 CFR Part 91 as part of the UAS 

exemption. The following list details the exemptions requested and the mitigation procedures that 

will ensure an equivalent level of safety to the public and the national airspace. FAA has granted 

similar exemptions to those requested below in, for example, Exemption Nos. 11136, 11138, 

11150 and11153.

14 CFR Section 61.113 (a) and (b)

Section 61.113 (a & b) limits private pilots to non-commercial flight operations. Since Flightline’s 

primary business is commercial GIS data acquisition during flight, an exemption from this section 

is necessary.

Equivalent Level of Safety

Because the UAS does not carry crew or persons, the equivalent level of safety can be 

achieved by pilots who have completed the Manufacturer’s required training course and 

who hold a minimum of a Sport Pilot certificate. The FAA itself, in Exemption No. 11462, 

concluded that Sport Pilot certificate will ensure that the PIC has proper knowledge and 

training. Flightline agrees that the awareness of airspace restrictions, communication with 

ATC and situational awareness concerns to safely operate within the National Airspace 

are satisfied by a minimum of a Sport Pilot certificate. 
The RQ-265 UAS is remotely piloted with no passengers or crew on board and the 

MILSPEC autopilot and parachute primary and emergency landing procedures provide an 

added measure of safety against human error in flying the UAS. For these reasons, 

Flightline is certain that an equivalent level of safety will be maintained with this

exemption.

14 CFR Section 61.23(a)&(c), 61.101(e)(4)&(5), 61.315(a): Who can Operate a UAS 

commercially

The FAA has previously allowed operation with a federal or state-issued driver’s license in lieu of 

an FAA-medical certificate, to allow the holder of a private pilot certificate to operate a UAS for 

compensation, and to allow holder of a sport pilot certificate to serve as PIC of a UAS. 

Equivalent Level of Safety

It has been previously recognized that the holder of a minimum of a Sport Pilot Certificate 

can provide an equivalent level of safety to a Private Pilot certificate.

Flightline is requesting exemption to the above regulations as only holders of a minimum

of a sport pilot certificate will be operating our UAS.

14 CFR Section 91.7(a): Airworthiness

Section 91.7(a) requires that no person may operate a civil aircraft unless it is in an airworthy 

condition. To the extent that this regulation would require an airworthiness certificate for the 

aircraft, Flightline requests an exemption.

Equivalent Level of Safety

All UAS operated by Flightline will be under 55 pounds, including payload, and will 

operate in a defined area made known to local ATC. Furthermore, the vehicles Flightline 

will operate do not carry personnel, explosive materials or flammable liquid fuels or other 

potentially hazardous materials. The vehicles to be used will be maintained to the strict

tolerances of Flightline’s Director of Maintenance and the guidelines set out in the 

operations manuals of the manufacturer‘s Flight Operations Manual (FOM). The RQ-265 

and its predecessor, the RQ-84Z have many thousands of successfulflight hours logged. 

This UAS, piloted by Flightline’s pilots, does not represent a risk to the national airspace 

or the public.

14 CFR Section 91.119(c): Minimum altitude requirements

Flightline requests an exemption from the minimum safe altitude requirements specified in 14

CFR 91.119(c). The altitude required by this section is 500 feet above the surface and persons,

vehicles, etc. Flightline plans to operate the UAS at or below 400 feet AGL (but not less than 100 

feet above structures, buildings, vehicles, etc.) in order to properly collect imagery data and to 

avoid entering the national airspace at an altitude that could possibly conflict with manned aircraft.

Equivalent Level of Safety

As explained in this document, the manufacturer’s FOM, every precaution will be taken to 

assure that the UAS is operating safely with existing air traffic and poses no risk to ground 

assets and persons.
14 CFR Section 91.121: Altimeter requirements

This section requires that the pilot of the aircraft use an altimeter on board the aircraft to 

determine altitude. The altimeter must be set based on the barometric pressure of the departing 

airport and airports in route. Petitioner seeks an exemption from 14 CFR Part 91.121 as GPS is 

instead used by the autopilot to provide altitude measurements in feet AGL. 

Equivalent Level of Safety

As part of the flight monitoring software of each UAS, the GPS altitude is displayed within 

the Ground Control Station display and audible feedback prompts will be given during 

flight when altitude approaches 400 feet. Pre-flight checks will confirm the correlation of 

the GPS altitude of the location of the flight compared to the flight plan to confirm the 

plan’s accuracy and make any necessary changes (including the abort of the mission). As 

an additional safety measure, the manufacturer’s FOM and flight control software both 

require a minimum of 7 GPS satellites to be in view in order to proceed with pre-flight and 

launch, ensuring a valid GPS location and altitude.

14 CFR Section 91.151: Fuel requirements

Petitioner requests exemption from 14 CFR Part 91.151 which states:

“(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”

The remaining section does not apply, as the UAS will not be flown at night. Since most UAS

flights will be 60-90 minutes in duration, another method of determining safe flight limits must be 

considered.

Equivalent Level of Safety

Flightline and the flight control software will require that in order for the pilot to take off 

(initiate a mission), the battery charge displayed by the system must be a full charge 

(>97%) and the aircraft will end its mission suchthat the total flight time does not exceed 

90 minutes, in accordance with the manufacturer’s recommendation. This will ensure that 

the UAS lands safely at one of the designated landing areas before battery life becomes 

critical or unstable. The flight control software includes battery monitoring and reserve 

charge features, ensuring a safe return with sufficient battery to make a parachute 

landing. There is a separate power supply that provides power to the parachute-based 

Flight Termination System, even if main power is lost. Sufficient reserve battery power is 

always maintained as recommended by the manufacturer and is monitored by the flight 

control system at the Ground Control Station. Audible warnings are issued to the PIC as 

the lower limit of operation is reached.
14 CFR Section 91.405, 14 CFR Section 91.407, 14 CFR Section 91.409, 14 CFR Section

91.417: Maintenance Reporting and Maintenance Inspection frequency

Petitioner seeks an exemption from the above regulations and their references to 14 CFR Part 

43. 14 CFR 91.405(a) states that each owner or operator of an aircraft “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”.

Since the UAS will not have an airworthiness certification, these regulations will not apply to these 

aircraft. Additionally, the nature of the vehicles is that of easily replaced off-the-shelf parts and a 

much smaller number of parts that can be replaced – making inspection schedules less fixed and 

field repairs possible.

Equivalent Level of Safety

Using the manufacturer’s FOM and maintenance manual, an inspection and preventative 

maintenance schedule will be followed for the RQ-265. Because the UAS is dismantled 

for storage and shipment after each flight, a thorough inspection will be performed after 

the reassembly of the vehicle and before each flight. The maintenance will be overseen 

by Flightline’s Director of Maintenance (DOM) who will ensure that the inspections and 

preventative maintenance are performed and logged and signed in the UAS log book. It is 

Flightline’s intention to keep maintenance logs for each of its UAS, as prescribed by the 

manufacturer, and to make these available to FAA inspection at any time. The DOM will 

ensure that any PIC or VO is able to perform field repairs and replacements as 

necessary. All field repairs and replacements will be correctly logged and signed on site 

by the PIC.

Public Interest

Granting Flightline this waiver is in the public interest for several reasons. The aerial imagery and 

geospatial data add to the public’s benefit including agricultural analysis, environmental studies, 

construction monitoring, safe and rapid disaster response, damage assessment, emergency 

response planning and a wide range of other GIS uses to be determined by the customers. Many 

of these applications are not cost-effectively or safely performed by manned aircraft and the lower 

cost and more rapid turn-around times for the data and imagery means that customers are more 

able to utilize this capability for projects in the public interest and on a more frequent basis. 

Flightline’s use of UAS will decrease the need for manned aircraft in the air and thus reduce

pollution, airspace congestion, and risk to crews and others. Flightline recognizes and supports 

the need to establish standards for UAS operators, which will safeguard the NAS. Flightline will 

offer and conductUAS operations using skilled professionals who will adhere to the required 

safety standards.

The UAS operated by Flightline will be under 55 pounds including payload, will operate in a 

defined area made known to local ATC, and will not carry personnel, explosive materials or 

flammable liquid fuels or other potentially hazardous materials – only cameras and related 

imaging sensors.
Summary to be Published in the Federal Register (if necessary)

Petitioner: Flightline Geographics LLC

Sections of 14 CFRAffected: 14CFR Section 61.113,14CFR Section 91.7,14CFR Section

91.119,14CFR Section 91.121,14CFR Section 91.151,14CFR Section 91.405,14CFR

Section 91.407, 14CFR Section 91.409, 14 CFR Section 91.417.

Description of Relief Sought: Petitioner seeks relief from the requirements of 14 CFR Section 

61.113, 14 CFR Section 91.7, 14CFR Section 91.119, 14CFR Section 91.121,14 CFR Section

91.151,14CFR Section 91.405, 14 CFR Section 91.407, 14 CFR Section 91.409 and 14 CFR 

Section 91.417 in order to conduct aerial data collection missions for GIS using small 

unmanned aerial systems for commercial uses in the service of many business and 

governmental sectors.

Conclusion

Flightline Geographics LLC believes that the criteria provided in Section 333 of the FMRA

regarding size, weight, speed, operating capabilities, proximity to airports and populated

areas, operation within visual line of sight, and national security have been satisfied.

Flightline's commitment to follow these criteria in a professional manner should justify the

granting of this exemption request. Please contact Devon Humphrey at Flightline 

Geographics LLC with any questions or for more information.

Devon Humphrey

Flightline Geographics LLC

150 Sunset Ridge

Dripping Springs, TX 78620

512-264-3246

devon@flightlinegeographics.com

Attachments: RPA RQ-265 Flight Operations Manual (including sample SOPs, flight logs 

and check lists), Flight Operations Checklist and Maintenance Manual. These 

documents are submitted as Confidential Documents under 14 CFR 11.35(b) and 

exempt from disclosure under the Freedom of Information Act.