June 3, 2015

U.S. Department of Transportation Docket Management System

1200 New Jersey Ave., SE Washington DC 20590 

Dear Sir or Madam: 

Attached please find Sean M. Shortall’s (V2 Flow Controls, LLC)request for an 

exemption from the listed Federal Aviation Regulations to allow commercial operation of 

its Small Unmanned Aircraft Systems (“sUASs”) for Commercial Inspections and 

Surveying.

Thank you for your time and consideration, and please let me know if you have any 

questions. Sincerely, 

Sean M. Shortall

V2 Flow Controls, LLC.

President

June 3, 2015

U.S. Department of Transportation Docket Management System

1200 New Jersey Ave., SE Washington DC 20590 

Re: Exemption Request Section 333 of the FAA Reform Act and Part 11 of the Federal 

Aviation Regulations from 14 C.F.R. 45.23(b); 14 CFR Part 21; 14 CFR 61.113(a) & (b); 

91.7(a); 91.9(b) (2); 91.103(b); 91.109; 91.119; 91.121; 91.151(a) & (b);

91.405 (a); 91.407(a) (1); 91.409 (a) (2); 91.417 (a) & (b). 

Dear Sir or Madam: 

The aircraft being used for UAS operations is: Make/Model: DJI Inspire 1, multi-rotor 

SN#W13DCC23020438. Payload: 6.46 lbs. Power: 22.2V LiPo 6S high voltage battery.

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

Act) and 14 C.F.R Part 11, Sean M. Shortall, hereby applies for an exemption from the 

listed Federal Aviation Regulations (“FARs”) to allow commercial operation of its Small 

Unmanned Aircraft Systems (“sUASs”) for commercial inspections and surveying, so 

long as such operations are conducted within and under the conditions outlined herein or 

as may be established by the FAA as required by Section 333. 

As detailed in this document the requested exemption would permit the operation of 

sUAS under controlled conditions in airspace that is 1) limited 2) predetermined 3) 

controlled as to access and 4) would provide safety enhancements to the already best 

practices safety protocols followed by Sean M. Shortall. Approval of this exemption 

would thereby enhance safety and fulfill the Secretary of Transportation’s (the FAA 

Administrator’s) responsibilities to “..establish requirements for the safe operation of 

such aircraft systems in the national airspace system.” Section 333 (c) of the Reform Act. 
The name and address of the applicant is: Sean M. Shortall

PHONE # 630-962-6870

Email: sshortall@v2flowcontrols.com

Address: 1333 Burr Ridge Parkway Suite 200, Burr Ridge, IL 60527

Regulations from which the exemption is requested: 

14 C.F.R. Part 21

14 C.F.R. 45.23(b)

14 C.F.R. 61.113 (a) & (b) 14 C.F.R. 91.7 (a)

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

14 C.F.R 91.103

14 C.F.R. 91.109 

14 C.F.R. 91.119

14 C.F.R. 91.121

14 C.F.R. 91.151 (a) 14 C.F.R. 203 (a) & (b) 14 C.F.R. 91.405 (a) 14 C.F.R. 407 (a) (1) 

14 C.F.R. 409 (a) (2) 14 C.F.R. 417 (a) & (b) 

1. STATUTORY AUTHORITY FOR EXEMPTIONS 

The Federal Aviation Act expressly grants the FAA authority to issue exemptions. This 

statutory authority includes exempting civil aircraft, as the term is defined under 40101 of 

the Act, including sUASs, from the requirement that all civil aircraft must have a current 

airworthiness certificate. 

The Administrator may grant an exemption from a requirement of a regulation prescribed 

under subsection (a) or (b) of this section or any sections 44702-44716 of this title if the 

Administrator finds the exemption ion the public interest. 49 U.S.C. 44701(f) See also 49 

USC 44711(a); 49 USC 44704; 14 CFR 91.203(a)(1). 

Section 333(b) of the Reform Act assists the Secretary in determining whether sUASs 

may operate in the National Airspace System (NAS) without creating a hazard to the 

user, the public, or a threat to national security. In making this determination, the 

Secretary must consider: 

  The sUAS’s size, weight, speed, and operational capability; 

  Whether the sUAS operates within the visual line of sight of the operator 

  Whether the sUAS operated outside of highly populated areas and away from 

close proximity to airports.

Reform Act 333(a). If the Secretary determines that a sUAS “may operate safely 
in the national airspace system, the Secretary shall establish requirements for the 

safe operation of such aircraft in the national airspace system.” Id. 333(c). 

Sean M. Shortall’s sUASs are multirotator vehicles, weighing 10 or fewer lbs. 

including payload. He operate under normal conditions at a speed of no more than 

50 knots and have the capability to hover, and move in the vertical and horizontal 

plane simultaneously. The sUASs will operate only in the pilot’s visual line of 

sight at all times. Such operations will insure that the sUASs will “not create a 

hazard to users of the national airspace system or the public. “Reform Act Section 

333 (b). 

Given the small size of the sUASs involved and the restricted environment within 

which they will operate, our application falls squarely within the zone of safety

(an equivalent level of safety) in which Congress envisioned that the FAA must, 

by exemption, allow commercial operations of sUASs to commence immediately. 

Also due to the small size of the sUASs and the low altitudes and restricted areas 

in which our sUASs will operate, approval of the application presents no national 

security issue. 

Given the clear direction in Section 333 of the Reform Act, the authority 

contained in the Federal Aviation Act, as amended; the strong equivalent level of 

safety surrounding the proposed 

operations, and the significant public benefit, including enhanced safety, the grant of the 

requested exemptions is in the public interest. Accordingly, Sean M. Shortall respectfully 

requests that the FAA grant the requested exemption without delay. 

II. PUBLIC INTEREST 

This exemption application is expressly submitted to fulfill Congress’ goal in passing 

Section 333(a) through (c) of the Reform Act. This law directs the Secretary of 

Transportation to consider whether certain unmanned aircraft systems may operate safely 

in the NAS before completion of the rulemaking required under Section 332 of the 

Reform Act. By granting an exemption the FAA will fulfill Congress’ intent of allowing 

UAS to operate with significant safety precautions in low risk environments. 

The use of sUASs have numerous applications and benefits where we will no longer need 

to risk human lives to complete basic tasks at high altitudes, environmentally friendly as 

there are no combustible fuels to exhaust.

Additionally, sUASs could replace the use of helicopters and small aircraft to 

inspect/survey sites. The sUASs we propose to fly in this application are under five 

pounds, as opposed to the much larger conventionally powered small aircraft. Shifting to 

sUASs from helicopters presents a marked safety increase for workers and the public. 
Lastly, sUASs reduce the environmental impact by dramatically reducing the energy used 

for aerial imaging and data collection over a construction site. Our sUASs use 

rechargeable lithium ion batteries, as opposed to fossil fuels burned in operation of small 

aircraft that are many hundreds of times heavier. 

III. EQUIVALENT LEVEL OF SAFETY 

Sean M. Shortall proposes that the exemption requested herein apply to civil aircraft that 

have the characteristics and that operate with the limitations listed herein. These 

limitations provide for at least an equivalent or even higher level of safety to operations 

under the current regulatory structure because the proposed operations represent a safety 

enhancement to the already safe protocols followed on construction sites and imaging and 

surveying operations conducted with helicopters and other conventional aircraft. 

Sean M. Shortall will be bound by the following limitations when conducting its sUAS 

operations under an FAA issued exemption: 

1. The sUAS will be less than 10 pounds. 

2. Flights will be operated within visual line of sight of a pilot. 

3. Maximum total flight time for each operational flight will be less than 30 minutes. 

The UAS calculates the battery reserve in real time and will return with at least 

25% of battery charge remaining.

4. Flights will be operated at an altitude of 300 feet AGL, never exceeding 400 feet 

AGL. 

5. Crew for each operation will consist of the sUAS pilot who will keep the sUAS 

within his visual line of sight at all times. 

6. The sUAS pilot will be trained in flight, operations, and safety procedures. 

7. The sUAS will only operate within a confined area. 

8. A briefing/scope of operation will be conducted in regard to the planned sUAS 

operations prior to each flight.

9. All onsite personnel will consent to the UAS flyover on site by waiver, and the 

operator will obtain additional written consent of all persons who will be allowed 

within 50 feet of the flight operation. 

10. The pilot will have been trained in operation of UASs generally and received upto-date information on the particular UAS to be operated. 

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

obtained. 

12. All required permissions and permits will be obtained from territorial, state, 

county, or city officials including but not limited to: Law Enforcement and other 

Government Agencies.

13. If the sUAS loses communications or loses its GPS signal, it will have the 

capability to 

return to a pre-determined location within the security perimeter and land. 
14. The sUAS will have the capability to abort a flight in case of unpredicted 

obstacles or emergencies.

IV. DESCRIPTION OF SPECIFIC REGULATIONS 

14 CFR Part 21, Subpart H: Airworthiness Certificates 14 C.F.R 91.203(a)(1) 

Subpart H, entitled Airworthiness Certificates, establishes the procedural requirements 

for the issuance of airworthiness certificates as required by FAR 91.203 (a)(1). Given the 

size and limited operating area associated with the aircraft to be utilized by Sean M. 

Shortall, an exemption from Part 21 Subpart H meets the requirements of an equivalent 

level of safety under Part II and Section 333 of the Reform Act. The Federal Aviation Act 

(49 U.S.C 44701 (f) and Section 333 of the Reform Act both authorize the FAA to 

exempt aircraft from the requirement for an airworthiness certificate, upon consideration 

of the size, weight, speed, operational capability, and proximity to airports and populated 

areas of the particular UAS. Our small UAS will be operated at low speed in a controlled 

environment, at least five miles from an airport or densely populated area. An analysis of 

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

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

safer, than conventional aircraft (fixed wing or helicopter) operating with an 

airworthiness certificate without the restrictions and conditions proposed. 

The sUAS to be operated hereunder is less than 10 lbs. fully loaded, carries neither a pilot 

nor passenger, carries no explosive materials or flammable liquid fuels, and operates 

exclusively within a secured area. Like other civil aircraft, operations under this 

exemption will be tightly controlled and monitored by the operator, and under the 

requirements and in compliance with 

local public safety requirements, to provide security for the area of operation as is 

currently done on active construction sites. The FAA will have advance notice of all 

operations. 

These safety enhancements, which already apply to civil aircraft operated in connection 

with construction sites, provide a greater degree of safety to the public and property 

owners than conventional operations conducted with airworthiness certificates issued 

under 14 C.F.R. Part 21, Subpart H. Lastly, application of these same criteria 

demonstrates that there is no credible threat to national security posed by the UAS, due to 

its size, speed of operation, location of operation, lack of explosive materials or 

flammable liquid fuels, and ability to carry and external load no greater than two lbs. 

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

This regulation requires certain experimental, provisionally certified aircraft, or lightsport category aircraft to be marked with letters between 2 inches and 6 inches high 

“limited”, “restricted”, “light-sport”, “experimental”, or “provisional”, near each entrance 

to a cabin, cockpit, or pilot station. 
Even though the UAS will have no airworthiness certificate, an exemption may be 

needed as the UAS will have no entrance to the cabin, cockpit, or pilot station on which 

the word “Experimental” can be placed. Given the size of the sUAS, two-inch lettering 

will be impossible. The word “Experimental” will be placed on the fuselage in 

compliance with 45.29(f). 

The equivalent level of safety will be provided by having the sUAS marked on its 

fuselage as required by 45.29(f) where the pilot, observers and others working with the 

sUAS will see the identification of the UAS as “Experimental” The FAA has issued the 

following exemptions to this regulation. Exemptions Nos. 10700, 8738, 10167 and 

10167A. 

14 CFR 61.113 (a) & (b): Private pilot privileges and limitations: Pilot in command 

Sections 61.113 (a) & (b) limit private pilots to non-commercial operations. 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 pilot operating the 

aircraft to have completed a UAS flight training course of 100 hours before flying a UAS. 

Unlike a conventional aircraft that carries the pilot and passengers, the sUAS is remotely

controlled with no living thing or cargo on board. The area of operation is controlled and 

restricted, and all flights are planned and coordinated in advance. The risks associated 

with commercial operations contemplated by Part 61 when drafted, that allowing 

operations of the sUAS as requested with a pilot who has met the minimum requirements 

exceeds the present level of safety achieved by 14 C.F.R. 61.113 (a) & (b). 

14 C.F.R. 91.7 (a): Civil aircraft airworthiness 

The regulation requires that no person may operate a civil aircraft unless it is in airworthy

condition. As there is no airworthiness certificate issued for the aircraft, should this 

exemption be granted, no FAA regulatory standard will exist for determining 

airworthiness. Given the size of 

the aircraft and the use of safety checklists prior to each flight, as set forth in Section B 

and Section G, an equivalent level of safety will be provided. 

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

The sUAS, given its 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 aircraft. 

The equivalent level of safety will be maintained by keeping the flight manual at the 

ground control point where the pilot flying the sUAS will have immediate access to it. 

The FAA has issued the following exemptions to this regulation: Exemption Nos. 8607, 

8737, 8738, 9299, 9299A, 9565, 9565B, 10167, 10167A, 10602, 32827, and 10700. 
14 C.F.R. 91.103: Preflight Action 

This regulation requires each pilot in command to take certain actions before a flight to 

ensure the safety of flight. An exemption is needed from this requirement as the pilot will 

take separate preflight actions, including checking for weather conditions, checking flight 

battery requirements, checking takeoff and landing distances, and all other actions in the 

Preflight Checklist in the Manual. These actions will provide an equivalent level of 

safety. 

14 C.F.R. 91.109 Flight Instruction 

Section 91.103 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. 

By design, sUAS and remotely piloted aircraft 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 previously approved exemptions for 

aircraft without fully functional dual controls. See Exemption Nos. 5778K & 9862A. The 

equivalent level of safety provided by the fact that neither a pilot nor passengers will be 

carried in the aircraft, the ability to control the uUAS via radio signals from the 

controller, and by the size and speed of the aircraft. 

14 C.F.R. 91.119: Minimum Safe Altitudes 

Section 91.119 establishes safe altitudes for operation of civil aircraft. Section 91.119 (d) 

allows helicopters to be operated at less than the minimums prescribed, provided the 

person operating the helicopter complies with any route or altitudes prescribed for 

helicopters by the FAA. This exemption is for a multirotor craft that flies similarly to a 

helicopter, with vertical takeoff and vertical landing, which will typically operate at 

altitudes of 300 AGL, so an exemption may be needed to allow such operations. The 

UAS will never operate at altitude higher than 500 AGL and will be in a restricted area 

with security perimeter, where buildings and people will not be exposed to operations 

without their pre-obtained consent. 

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

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

of the property owner or local officials. Because of the advance notice to the property 

owner and any onsite personnel, all affected individuals will be aware of the planned 

flight operations. Compared to flight operations with aircraft or rotorcraft weighing far 

more that the maximum 10 lbs. proposed herein and carrying flammable fuel, any risk 

associated with our operations of the sUAS will ensure separation between these small 

UAS operations and the operations of conventional aircraft that must comply with 

Section 91.119. 

14 C.F.R. 91:121: Altimeter Settings 
This regulation requires each person operating an aircraft to maintain cruising altitude by 

reference to an altimeter that is set “..to the elevation of the departure airport or an 

appropriate altimeter setting available before departure.” As the sUAS may not have a 

barometric altimeter, but instead a GPS altitude read out, an exemption may be needed. 

An equivalent level of safety will be achieved by the operator, pursuant to the Safety 

Checklist, confirming the altitude of the launch site shown on the GPS altitude indication 

before flight. 

14 C.F.R. 91.151 (a): Fuel requirements for flight in VFR conditions 

Section 91.151 (a) outlines fuel requirements for beginning a flight in VFR conditions. 

Our UAS is limited to operations in sterile and controlled environments as outlined above 

and has a limited range and flight time which require an exemption from 14 CFR 91.151 

(a). 

The battery powering the sUAS provides approximately 35 minutes of powered flight. To 

meet the 30 minute reserve requirement in 14 CFR 91.151, sUAS flights would be 

limited to approximately 5 minutes in length. Given the limitations on the UAS’s 

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

area, a longer time frame for flight in daylight or night VFR conditions is reasonable. 

Sean M. Shortall believes that an exemption from 14 CFR 91.151 (a) falls within the 

scope of prior exemptions. See Exemption 10673 (allowing Lockheed Martin 

Corporation to operate without compliance with FAR 91.151 (a)). Operating the small 

UAS, in a tightly controlled area where only people and property owners or official 

representatives who have signed waivers will be allowed, with less than 30 minutes of 

reserve fuel, does not engender the type of risks that Section 91.151 (a) was intended to 

alleviate given the size and speed of the small UAS. Additionally, limiting sUAS flights 

to 10 minutes would greatly reduce the utility for which the exemption will be granted. 

An equivalent level of safety can be achieved by limiting flights to 30 minutes, or enough 

battery reserve to ensure that the sUAS lands at the ground station with at least 20% of 

battery power (as determined by the onboard monitoring system and the pilot), whichever 

happens first. This restriction would be more than adequate to return the sUAS to its 

planned landing zone from anywhere in its limited operating area. 

Similar exemptions have been granted to other operations, including Exemptions 2689F, 

5745, 10673, and 10808. 

14 CFR 91.203 (a) & (b): Carrying civil aircraft certification and registration. 

The regulation provided in part: 

1. (a) Except as provided in 91.715, no person may operate a civil aircraft unless it 

has within it the following: 
(1) An appropriate and current airworthiness certificate.... 

2. (b) No person may operate a civil aircraft unless he 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 no more than 10 lbs and is operated without an onboard

pilot. Therefore there is no ability or place to carry certification and registration 

documents or to display them on the sUAS. 

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

control point where the pilot flying the sUAS will have immediate access to them, to the 

extent they are applicable to the sUAS. The FAA has issued numerous exemptions to this 

regulation. A representative sample of other exceptions includes Exemption Nos. 9565, 

9665, 9789, 9789A, 9797, 9797A, 9816A, and 10700. 

14 CFR 91.405 (a); 407 (a)(1); 409 (a)(2); 417 (a) & (b): Maintenance inspections 

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 © 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 Sean M. Shortall. Maintenance will be 

accomplished by the operator pursuant to the flight manual and operating handbook as 

referenced in the Manual. An equivalent level of safety will be achieved because these 

small UASs are very limited in size and will carry a small payload and operate only in 

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 AGL. As provided in the 

Manual, 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 aircraft and best suited to 

maintain the aircraft in an airworthy condition to provide the equivalent level of safety. 

Thank you for your time and consideration on this matter.

Respectfully,

Sean M. Shortall