Unmanned Services, Inc.

314 S. Main St.

Suite 1

Versailles, KY 40383

Phone: (267) 614-1345 

August 05, 2015 

U. S. Department of Transportation, Docket Operations  

West Building Ground Floor, Room W12-140

1200 New Jersey Ave, SE

Washington, DC 20590

Re: Amendment to Exemption 12033 issued pursuant to Section 333 of the FAA Reform Act and 

Part 11 of the Federal Aviation Regulations in Regulatory Docket No. FAA-2015-1302

Dear Exemption Manager,

Unmanned Services, Inc. (USI), is an operator of small Unmanned Aircraft Systems (sUAS) or 

Unmanned Aircraft (UA). USI is an aviation technology and services company that was issued 

an Exemption numbered 12033 (hereinafter the 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 the extent necessary to allow the 

petitioner to operate a UAS to perform aerial data collection. USI herby requests an amendment 

to the Exemption to revise conditions 4, 6, 13, 15, and 25 of the Conditions and Limitations set 

forth in Exemption 12033. 

Condition 4 states that 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. USI’s request is that exemption be 

made in that UA altitude reports may also be reported in meters (m) for which 121.92 meters is 

the equivalent of 400 feet. 

Condition 6 states that 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 VLSO 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. USI’s request is that exemption be made in 

that the PIC may be able to transfer his or her designation during flight operations. The 

stipulations will be that the transferring PIC will properly log the name of the new PIC and time 

of transfer, and ensure that the transferee PIC is qualified and current to perform PIC duties 

before conducting transfer of control.
Condition 13 states that 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 which the PIC is rated on his or her pilot 

certificate. USI has found that most pilots with any one of the above piloting certificates do not 

usually have the best aptitude for learning to fly complex UA aircraft. This problem is most 

prominent when flying in more manual stick modes of flight that require intensive finite stick 

controls or when fast reactions to the aircraft are required since they are not used to flying from 

the perspective of being on the ground. This problem is most pervasive in dealing with 

emergency situations or a pilot’s inaptitude for troubleshooting aircraft conditions remotely. The 

training required to get these pilots to our high operating and proficiency standards is time and 

money intensive, especially when crashes and losses of UAS happen frequently when training 

these types of pilots. USI’s request is that exemption be made in that the PIC may also be 

someone who does not hold any of the above piloting certificates as long as the PIC has had prior 

military UAS rated piloting experience of at least 150 hours and has passed a FAA ground 

school knowledge test associated with a FAA pilot certificate program within the last 24 months. 

All military UAS PICs go through aviator training similar to a FAA rated pilot’s training with 

the exception of flying manned aircraft. They receive similar training in aerodynamics, airspace, 

airport operations, ATC communications, aviation weather, aeromedicine and crew-coordination. 

Having a PIC fly in this manner increases safety of the operation as the UA will be controlled by 

a skilled UAS operator instead of a newly trained UA pilot. USI is willing to provide a standard 

of tracking and security clearance for its non-FAA-certificated UA pilots, such as a TWIC card

or method preferred by the Administrator. This condition for exemption is only intended to be 

temporary until the FAA establishes its new system for certificating UA PICs. USI will also 

follow all future directives from the FAA on moving our PICs to the new UA pilot rating system

once established.

Condition 15 states that 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. USI’s request is that 

exemption be made in that UA flights may be conducted during night. Nighttime flights, which 

are absolutely necessary for certain uses, are frequently conducted with manned helicopters. 

Granting this exemption will provide safer operations than using a helicopter. In addition to the 

PIC and VO, USI will require a second VO for these operations who will use an assisted-vision 

device such as a set of binoculars or a monocle with night vision technology. Additionally, USI 

PICs and VOs will familiarize themselves with the intended flight location during daylight hours 

in a preflight scout. The UA will also be well lit with an anti-collision light system including 

navigation lights and position strobe lights and never flown over 200 feet AGL in approved COA 

locations

Condition 25 states that the UAS may not be operated by the PIC from any moving device or 

vehicle. USI’s request is that exemption be made in that UA flights may be conducted from 

moving devices or vehicles. USI has significant experience operating UASs from moving 

platforms such as boats, cars, and golf carts. This is often done to help the pilot maintain greater 

visibility and directionality of the aircraft over long distances. Neither the PIC nor the VO will 

be tasked with operating the moving platform, will only operate from platforms that provide full 

unimpeded visibility of the sky and will remain completely focused on the operation of the UAS. 
If a safety of flight issue occurs, the moving platform will be halted immediately and the PIC 

will land the UA in a safe manner and as expeditiously as possible.

USI respectfully submits that good cause exists for not publishing a summary of the petition in 

the Federal Register because the requested amendment to the Exemption would not set a 

precedent, and any delay in acting on this petition would be detrimental to the petitioner.

USI submits that the same conditions and reasons relative to public interest and safety that were 

the basis for granting the original Exemption still apply. Thusly, a grant of an amendment is in 

the public interest.

Further, the petitioner agrees to be subject to all conditions and limitations as may be set forth 

under an approved amendment to Exemption, and unless otherwise specified in a grant of 

exemption, the UAS, the UAS PIC, and the UAS operations will comply with all applicable parts

of 14 CFR including, but not limited to, parts 45, 47, 61, and 91.

The name and address of the petitioner is:

Unmanned Services, Inc.

Attn: Manfred M. Marotta

314 S. Main St.

Suite 1

Versailles, KY 40383

Phone: (267) 614-1345 

Email: mmarotta@unmannedservicesinc.com

Please contact the undersigned should you have any questions concerning this request for an 

amendment to the Exemption.

Sincerely,

Manfred M. Marotta

CEO, Unmanned Services, Inc. 

cc:

John S. Duncan

Jake Troutman

Margaret Sandkam