3GLP, Inc. dba Precision Flight Devices, 800 E Dimond Blvd, Suite 3-650, Anchorage, AK 99515 

www.PrecisionFlightDevices.com 800.756.5680 Cover Page

UNITED STATES OF AMERICA 

DEPARTMENT OF TRANSPORTATION 

FEDERAL AVIATION ADMINISTRATION

DOCKET MANAGEMENT SYSTEM

1200 NEW JERSEY AVE., SE

WASHINGTON, DC 20590

Regulatory Docket No.____________

IN THE MATTER OF THE PETITION FOR EXEMPTION OF: 

3GLP, Inc. dba Precision Flight Devices

FOR AN EXEMPTION SEEKING RELIEF FROM 

THE REQUIREMENTS OF THE FAA Reform Act and 

Part 11 of the Federal Aviation Regulations from 

TITLE 14 OF THE CODE OF FEDERAL REGULATIONS 

SECTIONS C.F.R. §§ 61.113 (a) & (b); 61.133 (a); 91.9 (b); 91.103; 97.109; 91.7(a); 91.119 (c); 

91.121; 91.151(a); 91.203 (a) & (b); 91.405 (a); 91.407(a)(1); 91.409 (a) (2); 91.417 (a) & (b).

CONCERNING COMMERCIAL OPERATION OF UNMANNED AIRCRAFT SYSTEMS

PURSUANT TO SECTION 333 OF THE FAA MODERNIZATION 

AND REFORM ACT OF 2012 (PUBLIC LAW 112-95)

January 19, 2015

Stephen Colligan

3GLP, Inc. dba Precision Flight Devices

800 E Dimond Blvd

Suite 3-650

Anchorage, AK 99515

(800)756-5680
3GLP, Inc. dba Precision Flight Devices, 800 E Dimond Blvd, Suite 3-650, Anchorage, AK 99515 

www.PrecisionFlightDevices.com 800.756.5680 Page 1

Table of Contents

GLOSSARY OF ABBREVIATIONS........................................................................................... 2

INTRODUCTION......................................................................................................................... 3

Executive Summary ................................................................................................................. 4

Expeditious Summary Grant Approval Request...................................................................... 4

Description of Type, Make and Models and 333 waiver granted of sUAV/UAS 

Requested:......................................................................................................................................................... 4

Commercial (Mission, Operation) Purpose:........................................................................................ 5

Regulations from which the Exemption Relief is requested:....................................................... 6

The name and address of the Petitioner:................................................................................... 6

Background................................................................................................................................. 7

Expertise & Experience................................................................................................................................ 7

The Exemption Request ......................................................................................................... 9

Operator Requirements ................................................................................................................ 10

Aircraft and Equivalent Level of Safety.................................................................................... 12

Specific Uses and Public Benefits............................................................................................... 16

Equivalent Level of Safety............................................................................................................. 17

14 C.F.R. § 91.9 (b) (2): Civil Aircraft Flight Manual in the Aircraft.......................................18

14 C.F.R. § 91.7(a): Civil aircraft airworthiness..............................................................................18

14 C.F.R. § 91.103: Preflight action......................................................................................................18

14 C.F.R. §91.109: Flight instruction:..................................................................................................19

14 C.F.R. §91.119: Minimum safe altitudes ......................................................................................19

14 C.F.R. §91.121 Altimeter Settings...................................................................................................19

14 C.F.R. § 91.151(a): Fuel Requirements for Flight in VFR Conditions ..............................20

14 C.F.R. §91.203 (a) and (b): Carrying Civil Aircraft Certification and Registration.....20

14 C.F.R. §91.405 (a); 91.407 (a) (1); 91.409(a) (2); 91.417(a) & (b): Maintenance 

Inspections..................................................................................................................................................... 21

Federal Register Publication............................................................................................. 21

Privacy and National Security........................................................................................... 22

Summary ................................................................................................................................... 22

Appendix A – Operations and USER Guides.................................................................. 24

Appendix B - General Safety and Maintenance Procedures ................................... 25

A) Maintenance Schedule ...................................................................................................................25

B) Record Keeping ................................................................................................................................. 26

C) Securing Flight Site ..........................................................................................................................26

D) Pre-Flight Checklist..........................................................................................................................27

E) Mid-Air Safety Protocol..................................................................................................................28

F) Participation by non-pilot staff...................................................................................................28
3GLP, Inc. dba Precision Flight Devices, 800 E Dimond Blvd, Suite 3-650, Anchorage, AK 99515 

www.PrecisionFlightDevices.com 800.756.5680 Page 2

GLOSSARY OF ABBREVIATIONS

AGL Above Ground Level

AOI Area of Interest

ATC Air Traffic Control

ATO Air Traffic Organization

AV Aerial Vehicle

CFR Code of Federal Regulations

COA Certificate of Authorization

ExtVLOS Extended Visual Line of Sight

FAA Federal Aviation Administration

FAR Federal Aviation Regulation

FCC Federal Communication Commission

FPV First Person View

FRMA FAA Modernization and Reform Act of 2012

FSDO Flight Standards District Office

GCS Ground Control Station

GPS Global Positioning System

LOL Loss of Link

NAS National Airspace System

NOTAM Notice To Airman

PIC Pilot In Command

Section 333 FAA Modernization and Reform Act of 2012 (FMRA) Section 

333

SO Safety Observer

SOP Standard Operating Procedures

STEM Science Technology Engineering and Mathematics

sUAS Small Unmanned Aircraft System

sUAV Small Unmanned Aircraft Vehicle

UA Unmanned Aircraft

UAS Unmanned Aircraft System

UAV Unmanned Aircraft Vehicle

VFR Visual Flight Rules

VLOS Visual Line of Sight

VMC Visual Meteorological Conditions

VTOL Vertical Take-Off and Landing
3GLP, Inc. dba Precision Flight Devices, 800 E Dimond Blvd, Suite 3-650, Anchorage, AK 99515 

www.PrecisionFlightDevices.com 800.756.5680 Page 3

INTRODUCTION

Dear Sir or Madam:

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

14 C.F.R. Part 11, 3GLP, Inc dba. Precision Flight Devices, (“PRECISION FLIGHT DEVICES”) 

Operator of Small Unmanned Aircraft Systems (“sUASs”) equipped to offer on-demand 

commercial UAS operations for a host of industries and applications and to perform the purposes 

listed below, hereby applies for an exemption from the listed Federal Aviation Regulations 

(“FARs”) to allow commercial operation of its sUAV’s/UAS, so long as such operations are 

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

an exemption granted under either Section 333 or Section 49 U.S.C. §44701(f)

As described more fully below, the requested exemption would permit the operation of a 

UAS under controlled conditions in airspace that is 1) limited; 2) predetermined; and 3) 

would provide safety enhancements in the fields in which it will operate, which now 

depend upon conventional aircraft or humans climbing high on dangerous structures, 

walking in wetlands, and working on or observation of steep terrain or infrastructure. To 

the extent necessary to allow PRECISION FLIGHT DEVICES to commercially operate a

UAS to perform aerial data collection to include any remote sensing and measuring by an 

instrument(s) aboard the UA. Examples include imagery (photography, video, 

infrared/thermal, etc.), electronic measurement (precision surveying, RF analysis, 3D 

mapping, multispectral imagery, LIDAR, etc.), chemical measurement (particulate 

measurement, etc.), or any other gathering of data by instruments aboard the UAS. 

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.1

 1

 Precision Flight Devices relies upon the following exemptions where specific reference 

to an exemption is not provided: Exemptions 11062, 11063, 11064, 11065, 11066, 11067, 

11080, 11109, 11110, 11111, 11112, 11114, 11213, 11062, 11857, 11398, 11277, 12515, 

12496, 11277, 11356, 11206, 11281, 12516, 12580, 11373A, 11238A, 11239, 11239A, 12505, 

12103, 12068, 12208, and 11675.

.
3GLP, Inc. dba Precision Flight Devices, 800 E Dimond Blvd, Suite 3-650, Anchorage, AK 99515 

www.PrecisionFlightDevices.com 800.756.5680 Page 4

Executive Summary

Expeditious Summary Grant Approval Request

The PRECION FLIGHT DEVICES requests the agency issue a summary grant process for this 

application. PRECION FLIGHT DEVICES has provided in a confidential document attachment 

labeled as PRECION FLIGHT DEVICES proprietary information, specific exemption numbers 

whereby the FAA has already granted a previous exemption similar or identical to each and 

every request, herein. 

PRECION FLIGHT DEVICES has identified previous approved exemptions for each of the 

PRECION FLIGHT DEVICES FAA submission requests:

• Commercial (mission/operation) purposes;

• Type of sUAV’s (UAS);

• Title 14 Exemptions applicable to each aircraft

Description of Type, Make and Models and 333 waiver granted of sUAV/UAS 

Requested:

The PRECISION FLIGHT DEVICES is seeking an exemption to commercially operate sUAV’s 

makes and models as follows:

Aircraft Flight Controller Configuration FAA 333 #

DJI - Phantom 2 DJI X Config Multi Rotor 11784. 11795, 11785, 

11767

DJI - Phantom 3 DJI X Config Multi Rotor 11783, 11788, 11711, 

11696

DJI - Inspire 1 DJI X Config Multi Rotor 11710, 11711, 11712, 

11714

DJI – Spreading Wings S800 DJI / 3DR Pixhawk, APM Hex Config Multi Rotor 

.8M

11788, 11756, 11401, 

11252

DJI – Spreading Wings S900 DJI Octo Config Multi Rotor 

.9M

11794, 11779, 11714, 

11697

DJI – Spreading Wings S1000 DJI Octo Config Multi Rotor 

1M

11671, 11672, 11677, 

11638

DJI – Matrice 100 DJI X Config Multi Rotor, 

.65M

11814

3DRobotics X8 3DR Pixhawk Coaxial X Multi Rotor 11379

3DRobotics Iris 3DR Pixhawk X Configuration Multi 

Rotor

11778, 11533, 11496, 

11673

3DRobotics Solo 3DR Pixhawk X Configuration Multi 

Rotor

11832

3DRobotics AeroM 3DR Pixhawk Fixed Wing, 1.88M 11379
3GLP, Inc. dba Precision Flight Devices, 800 E Dimond Blvd, Suite 3-650, Anchorage, AK 99515 

www.PrecisionFlightDevices.com 800.756.5680 Page 5

*1 CumulUS material equivalent to 3DRobotics AeroM

*2 Material equivalent to DJI Phantom 2 and 3DR IRIS

*3 Material equivalent to DJI 550 333# 11397 and 3DR Solo

*4 Material equivalent to 3DR X8 multi rotor

*5 Material equivalent 3DR Solo

Each separately weighs 55 lbs. or less, with imaging payload and applicable equipment.

Equipment operation manuals for each sUAV are included for your reference and are 

considered confidential information for each respective company’s UAS and are affixed 

separately in these documents labeled Appendix.

Commercial (Mission, Operation) Purpose: 

This exemption request, once granted would allow the PRECION FLIGHT DEVICES to operate 

a small unmanned aerial vehicle (sUAV), (55lbs or less) for geospatial surveying, measurement 

and inspections, collection of photographs and video and broadcast of video and telemetry data. 

for the following purposes: Geographic mapping, delineation, measuring and 3D modelling of 

terrain , infrastructure or manmade improvements, Use of sensors on UA for vegetation 

mapping environmental monitoring, quantification and calculation of area and health of 

materials, plumes, natural and mineral resources. Video capture for commercial collection and 

observation to be used in commercials, training videos, documentation, recoding of events, 

environmental observation, counting and classification of physical, natural or mineral resource 

activity or development. Training to persons individually or belonging to private or public 

organizations to increase awareness and improve safety for current and future UAS operations 

within the NAS.

PFD CumulUS 3DR Pixhawk Fixed Wing, Tracktor, 

1.7M Span

11379*1

PFD X-450 3DR Pixhawk/DJI NAZA X config Multi Rotor .45M11784. 11795, 11785, 

11767*2

PFD -550 3DR Pixhawk/DJI NAZA Octo Multi Rotor .5M 11379*3

PFD CX-850M 3DR Pixhawk CoAxial X Config .85M 11379*4

AscentAeroSystems Sprite, 3DR PixHawk/APM Single Coaxial Blades 11778, 11533, 11496, 

11673 *5

Altavian Nova F6500 Altavian Nova Fixed Wing Tracktor 11456, 11472, 11605, 

11552

SenseFly eBee Sense Fly, eMotion Fixed Wing Delta, .96M 11745, 11754, 11764, 

11673

Topcon Sirus MAVinci Fixed Wing Tracktor, 

1.63M

11368

Topcon Falcon 8 AscTec Multi Rotor 8

Trimble UX5 Trimble Fixed Wing Delta, 1M 11806, 11666, 11432, 

11329
3GLP, Inc. dba Precision Flight Devices, 800 E Dimond Blvd, Suite 3-650, Anchorage, AK 99515 

www.PrecisionFlightDevices.com 800.756.5680 Page 6

Regulations from which the Exemption Relief is requested:

14 C.F.R. § 61.113 (a) & (b)

14 C.F.R. § 61.133(a)

14 C.F.R. § 91.7(a)

14C.F.R. § 91.9 (b)

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.§ 91.203 (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)

The name and address of the Petitioner:

3GLP, Inc dba Precision Flight Devices

Attn: Stephen M Colligan

Mailing :PO Box 874294,Wasilla, AK 99687

Physical: 800 E Dimond Blvd, Suite 3-650, Anchorage, AK 99515

Phone: (800)756-5680

SColligan@PrecisionFlightDevices.com
3GLP, Inc. dba Precision Flight Devices, 800 E Dimond Blvd, Suite 3-650, Anchorage, AK 99515 

www.PrecisionFlightDevices.com 800.756.5680 Page 7

Background

3Glp, Inc was established in 1994 as a Alaska holding and investment corporation to several 

emerging technology and geospatial companies. With industry leading skills in geomatics, 

internet and cloud computing, aerial and satellite image processing, aviation safety and flight 

simulation, 3Glp formed a Unmanned Systems company to focus on the design, integration, 

application and training needs of the emerging sUAS market. 3Glp, Inc and its subsidiaries 

have mapped millions of kilometers of the earth’s surface using a variety of technologies and 

sensors to create the best geospatial data available. Most of the geographic focus has been in 

the northern and arctic regions, but also has significant experience in the continental US and 

Canada.

3GLP, Inc, Precision Flight Devices and its sister companies are made up of leaders in their field 

of Engineering, Geospatial Science, Manned Aircraft Pilots, Air Traffic Control professionals, 

Military UAS operators, Aviation Safety Management, Remote Control aircraft pilots and 

Electronics and communications equipment. 3GLP, Inc has assembled an advisory board for 

Precision Flight Devices of leaders and advisors in each area of anticipated operational areas of 

UAS to ensure that it meets or exceeds Federal Regulations and set an example for others in the 

community.

3Glp,Inc, Precision Flight Devices, founder, Steve Colligan has over 25 years’ experience in 

Geographic Information Systems, Computer Aided Design and 35 years of Remote control 

aviation building and flying experience. As a lifelong Alaskan resident he has been involved in 

the aviation industry and aviation safety, directing mapping operations and developing aviation 

safety simulation and training tools addressing and improving Alaska’s unique challenges.

Mr. Colligan has been a member of the Academy of Model Aeronautics (AMA), UAS advisory 

board working to establish best practices and training for AMA members. Mr Colligan is also one 

of the initial members on the State of Alaska’s UAS legislative task force working to protect 

public privacy and safety, while also creating opportunity for the safe and meaningful operation 

on Unmanned Aircraft Systems. Mr. Colligan is also a county level elected official, where he a 

great amount of experience in the development of municipal and state government code and 

public policy.

Expertise & Experience

Steve Colligan formed Precision Flight Devices over the past three years by developing flight 

systems, sensors, software and workflows to produce accurate geospatial data using sUAS 

platforms that extend or enhance existing geospatial business lines. Mr Colligan has built 

relationships and vendor contracts to deliver market acceptable data efficiently and safely, and 

participate in Research and Development projects to evolve the sUAS technology into the future.

Steve Colligan due to his professional industry experience in engineering, geomatics and as a 

trusted sUAV pilot is extremely qualified and is subject matter expert in Alaska and the US for 

sUAS of all types. 
3GLP, Inc. dba Precision Flight Devices, 800 E Dimond Blvd, Suite 3-650, Anchorage, AK 99515 

www.PrecisionFlightDevices.com 800.756.5680 Page 8

3GLP, Inc Precision Flight Devices has been working with NASA AMES through its relationship 

with Northern Regions Research and Development Institute (NRRDI.org pronounced “NERDY”), 

its sister company E-Terra and environmental services company Fairweather Sciences on the 

Unmanned Traffic Management System (UTM) in the Arctic. Precision Flight Devices has been 

building and integrating communications equipment and telemetry sensors to broadcast to the 

UTM cloud based reporting system.

Precision Flight Devices, has developed its own training, operations and maintenance program 

and safety management system to respond to market needs based on a solid culture of safety. 

Precision Flight Devices, employees, contractors and board members have many years of 

experience in commercial aviation, air traffic control, safety management and training. Precision

Flight Devices will meet or exceed Federal regulatory requirement of the sUAS industry.

Precision Flight Devices, has a lease agreement for a large area of land well suited for sUAS 

training which will be of great benefit to the public as a safe place to train and operate future 

operators creating economic benefit to the community and public at large. Precision Flight 

Devices intends to work with federal regulatory agencies and industry to provide market driven 

training courses that are affordable and meaningful.

Furthermore, Precision Flight Devices being an Alaskan company has been working closely with 

it Alaska Native Corporation clients to provide STEM education opportunities using sUAS. 

Precision Flight Devices, is leveraging its relationship with NASA AMES and the UTM system to 

integrate into mapping, vegetation analysis and geographic media collection curriculum and 

projects.

During the summer of 2015, Precision Flight Devices developed a project with high school 

interns to research and develop the use of haptic and audio feedback with RC transmitters for 

sUAS use. The end result was a complete library of audio messages and a framework of alarms 

and feedback to keep the sUAS pilot focused on the flying aircraft. The telemetry system is now 

used in all Precision Flight Devices custom sUAS and part of our operations and procedures 

manual.
3GLP, Inc. dba Precision Flight Devices, 800 E Dimond Blvd, Suite 3-650, Anchorage, AK 99515 

www.PrecisionFlightDevices.com 800.756.5680 Page 9

The Exemption Request

3Glp, Inc Precision Flight Devices proposes the use of the sUAV’s will be for capture of high 

resolution imagery and video of earth and developed infrastructure to a level of quality that 

allows the PRECION FLIGHT DEVICES to use the data to produce mapping, video and three 

dimensional models for commercial use.

The imagery and video will be used to identify the condition of the earth surface and developed 

infrastructure. Uses of the data will be used by a wide variety of clients from environmental 

monitoring and wetlands delineation to electrical and communications towers.

The UAS will be operated by a Precision Flight Devices and or contracting operators on 

occasion to capture high-resolution imagery/video of terrain and infrastructure. Given the small 

size of the sUAV’s involved, no more than 55 lbs., majority of the speed of operation be 

between 5-25 mph and the restricted environment within which they will operate, the PRECION 

FLIGHT DEVICES falls squarely within that zone of safety (an equivalent level of safety) in 

which Congress envisioned that the FAA must, by exemption, allow commercial operations of 

UASs to commence immediately.

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

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 national airspace 

system (NAS) before completion of the rulemaking required under Section 332 of the Reform 

Act. In making this determination, the Secretary is required to determine which types of UASs 

do not create a hazard to users of the NAS or the public or pose a threat to national security in 

light of the following:

• The UAS’ size, weight, speed, and operational capability;

• Operation of the UAS in close proximity to airports and populated areas; and

• Operation of the UAS within visual line of sight of the Operator.

Reform Act § 333 (a). Lastly, if the Secretary determines that such vehicles “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) (emphasis added).

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

statutory authority, by its terms, includes exempting civil aircraft, as the term is defined under

§40101 of the Act: The Administrator may grant an exemption from a requirement of a 

regulation prescribed under subsection (a) or (b) of this section or any of sections 44702-44716 

of this title if the Administrator finds the exemption is in the public interest. 49 U.S.C. §44701(f). 

See also 49 USC §44711(a); 49 USC §44704; 14 CFR §91.203(a)(1) This authority to grant 

exemptions reaches such issues as authorization of commercial operation of aircraft without an 

FAA issued pilot’s license.

PRECISION FLIGHT DEVICES in filing this application is requesting that the FAA combine the 

grant of the Section 333 exemption with a standard Certificate of Operation (COA) that will allow

commercial operations of its PRECISION FLIGHT DEVICES’ sUAV without the necessity of 

filing for a COA for each flight, unless such flight is to be conducted in an area not approved in 

the exemption. Compliance with the conditions agreed to herein and that may be imposed by 
3GLP, Inc. dba Precision Flight Devices, 800 E Dimond Blvd, Suite 3-650, Anchorage, AK 99515 

www.PrecisionFlightDevices.com 800.756.5680 Page 10

the FAA, as set forth in prior Section 333 exemptions, provide the separation needed from other 

aircraft.

In addition, given that all operations will be conducted below 400 AGL feet and no closer than 5 

nautical miles of the geographic center of an airport as denoted on a current FAA published

aeronautical chart, unless a letter of agreement with that airport’s management is obtained, 

PRECISION FLIGHT DEVICES requests that operations over congested or densely populated 

areas be allowed. The new sUAV’s do have GPS geo-fencing, it will operate at a very low 

altitude, within confined areas, at low speed and weighs no more than 55 lbs.. Such operations

will only be under-taken with the approval of the land or home owner, as set forth herein, and 

will comply with the requirements that operations be no closer than 500 feet to the adjacent 

building unless the land owner has provided permission, and the Operator has made a safety 

assessment of the risk from such operations. 

Operator Requirements

Given the sUAV proposed by PRECISION FLIGHT DEVICES, Operators should not be required 

to hold a private pilot license. PRECISION FLIGHT DEVICES believes that 1) the operator, 

instead of understanding how to operate a passenger carrying aircraft, should have knowledge 

and experience that enables the safe operation of a small, remotely piloted sUAV should 

understand airspace restrictions and know how to ensure separation from other aircraft as well 

as non-participants and property; 2) the sUAV has built-in technical capabilities that limit the 

potential for unsafe operation and 3) there are other security screening mechanisms already in 

existence that PRECISION FLIGHT DEVICES will utilize to ensure the operators are acting 

consistently with national security interests. 

Given the sUAV safety features outlined below, PRECISION FLIGHT DEVICES proposes that 

its operations under this Exemption request should not be required to hold a commercial or 

private pilot certification. Instead, Operators should be required to: have successfully completed, 

at a minimum, FAA private pilot ground instruction and passed the FAA Private Pilot written 

examination or FAA-recognized equivalents; have completed PRECISION FLIGHT DEVICES’

training program for operation of the UAS.

PRECISION FLIGHT DEVICES notes that 1) the FAA has found that safety factors permitted 

operation of sUAV’s by Operators with these qualifications in the case of operations pursuant to 

public COAs when the mandatory operating conditions specified above were present; and 2) 

that the Notice of Proposed Rulemaking entitled Operation and Certification of Small Unmanned 

Aircraft Systems, 80 F.R. 9544 (February 23, 2015) (“NPRM”), does not require the operator to 

hold a private pilot license or a third class medical.

Advanced sUAV’s has a navigation and control system and auto-pilot that allows it to execute 

very accurate pre-programed flights. Flights are pre-programmed with GPS waypoint to 

establish perimeters beyond which the aircraft will not operate. Flights under auto-pilot are not 

directed by positive manual input, but through pre-programmed flight parameters that are

executed by the auto-pilot. In the case of unplanned events, the Operator inputs 

preprogrammed evasive maneuvers from the control unit, and the autopilot executes those

maneuvers. Pre-programmed Operator interventions include: initiation of holding at present

position; suspension of mission; fly back to launch point; abort mission and land immediately;
3GLP, Inc. dba Precision Flight Devices, 800 E Dimond Blvd, Suite 3-650, Anchorage, AK 99515 

www.PrecisionFlightDevices.com 800.756.5680 Page 11

and emergency power cut off and land (flight termination system). Additional automated safety 

functions and safety enhancing features of the advanced sUAV’s may include the following:

1) Auto-pilot detection of lost GPS or of insufficient satellites initiates an immediate landing, 

2) Low power on the aircraft triggers escalating alarms at GCS at 35% and 10% levels. Low 

power below 10% triggers an immediate landing, 

3) If the auto-pilot detects a lost-link to the ground controller, the UAS will hold position at its 

current location for 5 seconds and if the signal is not restored, execute a return to home 

and land, 

4) Redundant “kill switches” that enable completely shutting the aircraft down in flight in the 

event of a loss of control or un-commanded deviation from the flight path, 

5) The aircraft, weighs less than 55 lbs., fully loaded, 

6) The motors are driven by pulse width modulated signals, not analog signals, 

7) The aircraft will operate for the Purposes at no more than 30 mph (while imaging) nor

above 200 feet above the structure (imaging altitude) or a maximum of 400 feet AGL.

See Federal Aviation Administration, Notice N-8900.227, Unmanned Aircraft Systems (UAS)

Operational Approval, at 20-21 (July 30, 2013); As the FAA has determined in Exemptions 

11062 thru 11067,11080 and 11110 (the “Exemptions”), in comparing the requirements for 

private pilot knowledge and the knowledge required for a commercial pilot, that knowledge 

associated with a private pilot license, and therefore private pilot ground school, was sufficient 

to allow private pilots to operate sUAV’s under those exemptions. 

Based upon that analysis, PRECISION FLIGHT DEVICES believes successful completion of 

FAA private pilot ground school is a suitable predicate to operating the sUAV under this 

exemption. PRECISION FLIGHT DEVICES proposes that the Operator accumulate required 

sUAV flight training hours through the operation of sUAV’s rather than flight hours in 

conventional aircraft. Those hours are more relevant to the operations proposed herein than 

hours gained in obtaining a private pilot’s certificate in conventional or rotor aircraft. Those 

aircraft are orders of magnitude heavier than the sUAS and carry not only the pilot himself, but 

also passengers and fuel, none of which is carried in the sUAS. These conventional aircraft fly 

over all sorts of airspace without the permission or knowledge of the landowner. 

A handheld radio controller controls the sUAV and the vehicle is operated within the line of 

sight. The requirements of Part 61.127 (commercial flight proficiency) and §61.107 (private flight 

proficiency), to the extent they are relevant to UAS operations, can be taught in the training 

proposed herein. As a review of the requirements of part 61.127 and 107 demonstrate, the 

issues presented as they relate to a 55 pound aircraft, operating at less than 30 mph during 

filming operations are those taught in ground school and in flight training with the particular UAS 

and not gained from accumulating flight hours in a fixed wing or rotorcraft gas or jet A powered 

aircraft completing cross country flights and take offs and landings at controlled and 

uncontrolled airports.

As to national security review of pilots, each of PRECISION FLIGHT DEVICES’s

pilots/operators will obtain internally provided certified training (Ground and Practical) from 

PRECISION FLIGHT DEVICES to operate the sUAV. This review and certification could 

reasonably vet the Operators against any known terrorist or no fly listings that are relevant and 

publically available.

PRECISION FLIGHT DEVICES additionally asks that the exemption be issued without the 

requirement for a visual observer. As set forth herein, an equivalent level of safety is provided 
3GLP, Inc. dba Precision Flight Devices, 800 E Dimond Blvd, Suite 3-650, Anchorage, AK 99515 

www.PrecisionFlightDevices.com 800.756.5680 Page 12

by the size, speed and control capabilities of the aircraft, as well as the operational procedures 

that will be applicable to all flight hereunder. These obviate the need for the visual observer. 

The Operator will be operating the aircraft, always within line of sight. He or she will walk and 

follow the aircraft around the inspection area so that while it is flying it’s pre-programed and at 

times, manual flight path, the UAS will always be directly in his or her line of sight. The Operator 

will not be distracted by viewing the pictures taken during the flight. Rather, once the sUAV is 

launched, the Operator’s only duty will be to watch the flight of the UAS over the structure and 

intervene to address flight path deviations or other issues that arise during the flight. The 

functions that an observer performs where the aircraft is flown at long distances from the launch 

area will not be necessary as the Operator will always have the aircraft in his or her direct sight. 

The observer also will not be necessary because the Operator will conduct a pre-flight 

inspection of the area, will and if needed, cordon off the area and will perform frequent visual 

scans of the area while the vehicle is operating.

PRECISION FLIGHT DEVICES again notes that the NPRM does not require the use of a visual 

observer. 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, reduction in

environmental impacts, including reduced emissions associated with allowing battery powered

sUAV’s for these functions instead of turbine or gas power aircraft/rotorcraft and operations with

pilots having at least a private pilot license, the grant of the requested exemptions is in the

public interest. 2

Aircraft and Equivalent Level of Safety

The PRECION FLIGHT DEVICES 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 operations conducted with conventional aircraft or with humans climbing up 

and around structures. These conditions are drawn from Exemptions 11136, 11138, 11172, 

11174 and 11177, 11062, 11109, 11112, and 11213 and as recent as 11857.

These limitations and conditions to which PRECISION FLIGHT DEVICES (referred to as 

“Operator”) agrees to be bound when conducting commercial operations under an FAA issued 

exemption include:

1) Operations authorized by this grant of exemption are limited to the aircraft described 

in the Operator’s manual, which is a aircraft weighing up to 55 pounds: Proposed 

 2 Should the FAA determine that it cannot grant such an exemption for operations 

without a FAA licensed private pilot, despite the showing made herein, under the 

statutory authority the FAA already has, Precision Flight Devices will operate its aircraft 

with pilots holding at least a private pilot certificate issued by the FAA. In that event, 

Precision Flight Devices requests that the exemption be granted with conditions similar 

to those contained in numbered paragraphs 14-15 in Exemption 11136
3GLP, Inc. dba Precision Flight Devices, 800 E Dimond Blvd, Suite 3-650, Anchorage, AK 99515 

www.PrecisionFlightDevices.com 800.756.5680 Page 13

operations of any other aircraft will require a new petition or a petition to amend this 

grant.

2) The sUAS may not be flown at an indicated airspeed exceeding 30 mph (10 mph

during inspections).

3) The sUAS must be operated at an altitude of no more than 400 feet above ground

level (AGL), as indicated by the procedures specified in the Operator’s manual. All 

altitudes reported to ATC must be in feet AGL.

4) The sUAS must be operated within visual line of sight (VLOS) of the Aircraft Operator 

at all times. This requires the Aircraft Operator to be able to use human vision 

unaided by any device other than corrective lenses..

5) The Exemption Holder’s Manuals must be amended to include all conditions and

limitations required by the FAA. The Manuals must be maintained and made available 

to the Administrator upon request. If a discrepancy exists between the conditions and 

limitations in the exemption and the procedures outlined in the Exemption Holder’s 

Operator’s manual, the conditions and limitations in the exemption take precedence 

and must be followed. Otherwise, the Aircraft Operator must follow the procedures as 

outlined in its Aircraft’s manual. The Exemption Holder may update or revise its 

Manuals. It is the Exemption Holder’s responsibility to track such revisions and 

present updated and revised documents to the Administrator upon request. The 

Exemption Holder must also present updated and revised documents if it petitions for 

an extension or amendment of this exemption. If the Exemption Holder determines 

that any update or revision would affect the basis upon which the FAA granted this

exemption, then the Exemption Holder must petition for amendment to its exemption.

6) Prior to each flight, the Aircraft Operator must 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 found to be in a condition for safe 

flight. The Ground Control Station must be included in the preflight inspection. All 

maintenance and alterations must be properly documented in the aircraft records.

7) 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 in accordance with the Exemption holder’s

Manuals. The Aircraft Operator who conducts the functional test flight must make an 

entry in the UAS aircraft records of the flight. The requirements and procedures for a 

functional test flight and aircraft record entry must be added to the Exemption 

Holder’s Operator’s manual.

8) The Exemption Holder must follow the manufacturer’s UAS aircraft/component,

maintenance, overhaul, replacement, inspection, and life limit requirements, with

particular attention to flight critical components that may not be addressed in the

manufacturer’s manuals.

9) The Exemption Holder must carry out its maintenance, inspections, and record

keeping requirements in accordance with the Operator’s Manuals. Maintenance,

inspection, and alterations must be noted in the aircraft logbook, including total flight 
3GLP, Inc. dba Precision Flight Devices, 800 E Dimond Blvd, Suite 3-650, Anchorage, AK 99515 

www.PrecisionFlightDevices.com 800.756.5680 Page 14

hours, description of work accomplished, and the signature of the authorized 

technician returning the UAS to service.

10) The authorized technicians must receive and document training referenced in the

Exemption Holder’s Manuals.

11) Each UAS operated under this exemption must comply with all manufacturer System 

and Safety Bulletins.

12) The Exemption Holder’s maintenance personnel must make a record entry in the UAS 

logbook or equivalent document of the corrective action taken against discrepancies 

discovered between inspections.

13) Prior to commencing operations, the Aircraft Operator shall have logged at least 25 

hours of total time as a UA rotorcraft pilot and at least ten hours logged as a UA pilot 

with a similar UA type and 5 hours in the make and model.

14) If the UAS loses communications or loses its GPS signal, the UA must return to a predetermined location within the private or controlled-access property and land or be 

recovered in accordance with the Exemption Holder’s Manuals.

15) The Aircraft Operator must abort the flight in the event of unpredicted obstacles or 

emergencies, including unauthorized people entering the flight area, in accordance 

with the Exemption Holder’s Manuals.

16) The Aircraft Operator is prohibited from beginning a UAS flight unless (considering 

wind and forecast weather conditions) there is enough power to fly to the first point of 

intended landing and, assuming normal cruising speed, to fly after that for at least 10 

minutes.

17) All aircraft operated in accordance with the exemption must be identified by serial 

number, registered in accordance with 14 CFR part 47, and have identification (NNumber) markings in accordance with 14 CFR part 45, Subpart C. Markings must be 

as large as practicable.

18) Before conducting operations, the radio frequency spectrum used for operation and 

control of the UA must comply with the Federal Communications Commission (FCC) 

or other appropriate government oversight agency requirements.

19) The documents required under 14 CFR 91.9 and 91.203 must be available to the 

Operator 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. 

20) The UA must remain clear and yield the right of way to all other manned operations 

and activities at all times (including, but not limited to, ultra-light vehicles, parachute 

activities, parasailing activities, hang gliders, etc.).

21) The UA may not be operated by the Aircraft Operator from any moving device or

vehicle.
3GLP, Inc. dba Precision Flight Devices, 800 E Dimond Blvd, Suite 3-650, Anchorage, AK 99515 

www.PrecisionFlightDevices.com 800.756.5680 Page 15

22) UAS operations may not be conducted during night, as defined in 14 CFR 1.1.

23) All operations must be conducted under visual meteorological conditions (VMC). 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 Operator.

24) During operations the UA may not operate within 5 nautical miles of the geographic 

center of an airport as denoted on a 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 a NOTAM, if as required by the Operator’s COA. The 

letter of agreement with the airport management must be made available to the 

Administrator upon request.

25) The UA may not be operated over congested or densely populated areas unless the 

conditions set for in #26 are satisfied. These populated areas include but are not 

limited to the yellow areas depicted on World Aeronautical Charts (WAC), Sectional 

Aeronautical Charts (Sectionals), or Terminal Area Charts (TAC). However, 

aeronautical charts may not reflect pertinent local information. Ultimately, it is the 

Operator’s responsibility to maintain the minimum safe altitudes required by § 91.119 

(d) (1).

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

persons, vessels, vehicles, and structures unless:

27) Barriers or structures are present that sufficiently protect nonparticipating persons 

from debris in the event of an accident. The Aircraft Operator must ensure that 

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

nonparticipating persons leave such protection and are within 30 feet of the UA, flight

operations must cease immediately and/or;

28) The aircraft is operated near vessels, vehicles or structures where the land 

owner/controller has granted permission and/or the Aircraft Operator has made a 

safety assessment of the risk of operating closer to those objects and;

29) Operations near the Aircraft Operator do not present an undue hazard to the Operator 

per § 91.119(a).

30) All operations shall be conducted over private or controlled-access property with 

permission from the land owner/controller or authorized representative. Permission 

from land owner/controller or authorized representative will be obtained for each flight 

to be conducted.

31) 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 Website: www.ntsb.gov.
3GLP, Inc. dba Precision Flight Devices, 800 E Dimond Blvd, Suite 3-650, Anchorage, AK 99515 

www.PrecisionFlightDevices.com 800.756.5680 Page 16

Specific Uses and Public Benefits

PRECISION FLIGHT DEVICES proposes use of its sUAV provided equivalent or augmented 

levels of safety for each of the uses proposed herein:

To commercially operate a UAS to perform aerial data collection, to include any remote 

sensing and measuring by an instrument(s) aboard a UA. Examples include imagery 

(photography, video, infrared/thermal, etc.), electronic measurement (precision surveying, 

RF analysis, 3D mapping, multispectral imagery, LIDAR, etc.), chemical measurement 

(particulate measurement, etc.), or any other gathering of data by instruments aboard the 

UAS.

To perform training and certification of other commercial UAS operators, state local and 

federal agencies on the safe operations of UAS for geospatial data collection, surveying 

and other uses that benefit the public. To educate the public about the process of 

collecting data in a safe manner and the processing of collected data and workflows that 

produce data products that are consistent with industry standards and accuracies.

To advance STEM education opportunities especially to Alaska Native and rural 

communities through the operations of sUAS contributing to multi-media communications, 

mapping and robotics curriculum’s.

To further work with NASA AMES in participation in the Unmanned Traffic Management 

System development and use cases particular to the Arctic and Northern Regions.

The present systems of photography and videography and mapping of inspecting the roofs, 

agriculture land, buildings and large structures site surveys, wild life monitoring, mosquito and 

insect control are now conducted by either humans wading through swamps, climbing on the 

roofs and structures that are steep, tall, slippery, weakened or otherwise hazardous or by the 

use of conventional aircraft. 

The current procedures can result in significant injuries to the people who must climb on the 

roofs or require the use of aircraft that are orders of magnitude greater in size than the sUAV. 

Either method, manual inspection or large conventional aircraft, results in increased risk of injury 

due to personnel falling off roofs or ladders, carrying heavy ladders and dealing with confined 

and dangerous spaces, or increased risk from low altitude flyovers with helicopters or fixed wing 

aircraft inspecting buildings after damage from storms or other disasters, such as earthquakes 

or fires. Such flights are, of course, significantly more expensive than those undertaken with a 

sUAV. All of these activities directly correlated to Workers Comp rates which will be where 

sUAS technology will gravitate to as a solution for safer operations.

The present system exposes those not only in the immediate area of inspection, but those who 

are along the path of flight associated with the arrival and departure of the conventional aircraft 

at the inspection site because the aircraft must be flown to and from the site. By contrast, the 

sUAV is carried to the site and transits no other property. Conventional aircraft carry flammable 

fuels that are not carried by the UAS and emit pollutants associated with internal combustion 

engines. The sUAV’s proposed herein are battery powered and have no emissions.
3GLP, Inc. dba Precision Flight Devices, 800 E Dimond Blvd, Suite 3-650, Anchorage, AK 99515 

www.PrecisionFlightDevices.com 800.756.5680 Page 17

Equivalent Level of Safety

14 C.F.R. § 61.113(a) & (b);: Private Pilot Privileges and Limitations; Pilot in Command; 

Section 61.113(a) & (b) limit private pilots to non-commercial operations. Unlike a conventional

aircraft that carries a pilot, passengers, and cargo, the PRECISION FLIGHT DEVICES’ sUAV is 

remotely controlled with no passengers or property of others on board. Section 61.133(a) 

requires an individual with a commercial pilot’s license to be pilot in command of an aircraft for 

compensation or hire. 

PRECISION FLIGHT DEVICES respectfully proposes that Operator requirements should take 

into account the characteristics of the particular UAS. PRECISION FLIGHT DEVICES’ sUAV

has a high degree of pre-programmed control and various built-in technical capabilities that 

strictly limit the potential for operation outside of the operating conditions set forth in the 

exemption application. The PRECISION FLIGHT DEVICES’ sUAV has navigation and control 

system comprised of a Ground Control Station (GCS) and auto-pilot system that can be preprogrammed to set operational boundaries. All flights are pre-programmed with precision GPS 

guidance.. In the case of unplanned events, the Operator may input pre-programmed evasive 

maneuvers from the control unit, and the onboard autopilot executes those maneuvers. Preprogrammed Operator interventions include initiation of holding at present position; suspension 

of mission; fly back to launch point; abort mission and land immediately; and emergency power 

cut off and land (Flight Termination System).

Additional automated safety functions and safety enhancing features of the PRECISION 

FLIGHT DEVICES’ sUAV’s may include the following:

• Auto-pilot detection of lost GPS or of insufficient satellites initiates an immediate

landing.

• Low power on the aircraft triggers escalating alarms at GCS at 35% and 10% 

levels. Low power below 10% triggers an immediate landing.

• If the auto-pilot detects a lost-link to the ground controller, the UAS will hold 

position at its current location for 5 seconds and if the signal is not restored,

execute a return to home and land.

• Redundant “kill switches” that enable completely shutting the aircraft down in 

flight in the event of a loss of control or un-commanded deviation from the flight 

path.

• The aircraft, weighs less than 55 lbs., fully loaded.

• The motors are driven by pulse width modulated signals, not analog signals.

• The aircraft will operate for the Purposes at no more than 30 mph (while imaging)

nor above 200 feet above the structure (imaging altitude) or a maximum of 400

AGL.

Given these safety features, PRECISION FLIGHT DEVICES proposes that Operators of the 

PRECISION FLIGHT DEVICES’ sUAS should not be required to hold a commercial or private 

pilot certification. 

Instead, Operators should be required to: have successfully completed, at a minimum, FAA 

private pilot ground instruction and passed the FAA Private Pilot written examination or FAArecognized equivalents; have completed the manufacturer’s or Precision Flight Devices’ training 

program for operation of the UAS.
3GLP, Inc. dba Precision Flight Devices, 800 E Dimond Blvd, Suite 3-650, Anchorage, AK 99515 

www.PrecisionFlightDevices.com 800.756.5680 Page 18

Precision Flight Devices notes that the FAA has found that safety factors permitted operation of 

UASs by Operators with these qualifications in the case of operations pursuant to public COAs 

where the mandatory operating conditions specified above were present. See, Federal Aviation

Administration, Notice N-8900.227, Unmanned Aircraft Systems (UAS) Operational Approval, at

20-21 (July 30, 2013). Likewise, Precision Flight Devices notes that the NPRM does not require 

that the Operator hold a private pilot license issued by the FAA.

Given these conditions and restrictions, an equivalent level of safety will be provided by allowing

operation of the Precision Flight Devices’ sUAV without a private pilot’s certificate or a 

commercial pilot’s certificate, under the conditions set forth herein.

The risks associated with the operation of the Precision Flight Devices’ sUAV (given its size, 

speed, operational capabilities, and lack of combustible fuel) are so diminished from the level of 

risk associated with private pilot operations or commercial operations contemplated by Part 61 

with conventional aircraft (fixed wing or rotorcraft), that allowing operations of the UAS as set 

forth above meets or exceeds the present level of safety provided under 14 C.F.R. § 61.113(a) 

& (b) and does not rise to the level of requiring a commercial pilot to operate the aircraft under § 

61.133(a).

14 C.F.R. § 91.9 (b) (2): Civil Aircraft Flight Manual in the Aircraft.

Section 91.9 (b) (2) provides: No person may operate a U.S.-registered civil aircraft ...

(2) 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 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. § 91.7(a): Civil aircraft airworthiness.

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

condition. Should the exemption be granted allowing commercial operation of the UAS without

an airworthiness certificate, no standard will exist for airworthiness of the UA. Given the size of

the aircraft and the requirements that the Operator has agreed to as it relates to airworthiness,

as contained in the manual, an equivalent level of safety will be achieved by insuring

compliance with the manuals prior to each flight. The FAA has granted exemptions to conduct

similar operations in Exemptions 11062 through 11067, 11080 and 11110.

14 C.F.R. § 91.103: Preflight action

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

safety of flight. As FAA approved rotorcraft flight manuals will not be provided for the aircraft an 
3GLP, Inc. dba Precision Flight Devices, 800 E Dimond Blvd, Suite 3-650, Anchorage, AK 99515 

www.PrecisionFlightDevices.com 800.756.5680 Page 19

exemption will be needed. An equivalent level of safety will be provided as set forth in the 

Manual. The PIC will take all actions including reviewing weather, flight battery requirements, 

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

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.

sUASs 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. 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 and by the size and speed of the 

aircraft. 

Safe simulation and practice flight will be carried out in controlled environments. All

simulations will be carried out on a computer using the drone controls. Any practice flying will 

take place in a safe environment, with no risk to human life below.

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. As this 

exemption is for a sUAS that is a helicopter and the exemption requests authority to operate at 

altitudes up to 400 AGL, an exemption may be needed to allow such operations. 

The equivalent level of safety will be achieved given the size, weight, and 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, facility owner, and/or local officials. Because of the advance notice to the

property owner and participants, all affected individuals will be aware of the planned flight 

operations as set forth in the Manuals. Compared to flight operations with aircraft or rotorcraft

weighing far more than the maximum 55 lbs. and the lack of flammable fuel, any risk associated

with these operations is far less than those presently presented by conventional aircraft

operating at or below 500 AGL in the aerial photography industry. In addition, the low-altitude

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. The FAA has granted

exemptions to conduct similar operations in Exemptions 11062 through 11067, 11080 and

11110.

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 Precision Flight Devices’ sUAV, in manual 
3GLP, Inc. dba Precision Flight Devices, 800 E Dimond Blvd, Suite 3-650, Anchorage, AK 99515 

www.PrecisionFlightDevices.com 800.756.5680 Page 20

or emergency mode, will not have a barometric altimeter display, but instead a GPS altitude 

display, an exemption will be needed. The Operator, pursuant to the procedures set forth in the 

Manuals as indicated before flight, will achieve an equivalent level of safety. The FAA has

granted exemptions to conduct similar operations in Exemptions 11062 through 11067, 11080

and 11110.

14 C.F.R. § 91.151(a): Fuel Requirements for Flight in VFR Conditions

Section 91.151(a) prohibits an individual from beginning “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; or (2) At night, to fly after that for at least 45 minutes.”

The battery powering the sUAS provides approximately 40 minutes of powered flight. To meet 

the 30-minute reserve requirement in 14 CFR §91.151, sUAS flights would be limited to

approximately 10 minutes in length. Given the limitations on the UAS’ proposed flight area and

the location of its proposed operations within a predetermined area, a longer time frame for

flight is reasonable.

PRECION FLIGHT DEVICES 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.

PRECION FLIGHT DEVICES believes that an equivalent level of safety can be achieved by 

limiting flights to 30 minutes or 25% of remaining battery power 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, 10808 and Exemptions 11062, 

through11067, 11080 and 11110.

14 C.F.R. §91.203 (a) and (b): Carrying Civil Aircraft Certification and 

Registration

The regulation provides in pertinent part:

(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. . . .

(b) No person may operate a civil aircraft unless the airworthiness certificate

(1) 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 sUAS fully loaded weighs no more than 55 lbs 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 sUAS.
3GLP, Inc. dba Precision Flight Devices, 800 E Dimond Blvd, Suite 3-650, Anchorage, AK 99515 

www.PrecisionFlightDevices.com 800.756.5680 Page 21

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 C.F.R. §91.405 (a); 91.407 (a) (1); 91.409(a) (2); 91.417(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 (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 the PRECION FLIGHT DEVICES. Maintenance will be 

accomplished by the Operator or manufacturer pursuant to the flight manual and operating 

handbook as referenced in the Manuals attached as confidential Exhibits 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 defined 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 Aircraft Flight Operations 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 and manufacturer are most familiar with the 

aircraft and best suited to maintain the aircraft in an airworthy condition to provide the equivalent 

level of safety. The FAA has granted exemptions for similar operations in Exemptions 11062 

through 11067, 11080 and 11110.

Federal Register Publication

Pursuant to 14 C.F.R. Part 11, the following summary is provided for publication in the Federal 

Register, should it be determined that publication is needed:

3GLP, INC dba: PRECION FLIGHT DEVICES seeks an exemption from the following rules:

14 C.F.R. §21, subpart H; 14 C.F.R 45.23(b);14 C.F.R. §§ 61.113( a) & (b);91.7 (a); 91.9 (b) 

(2);91.103(b);91.109; 91.119; 91.121; 91.151(a);91.203(a) and (b); 91.405 (a); 91.407 (a) (1); 

91.409 (a) (2); 91.409 (a) (2) and 91.417 (a) & (b) to operate commercially a small unmanned 

vehicle (55lbs or less) in geospatial survey. measurement and inspections, motion picture and 

television operations. For the following purposes: Geographic mapping, delineation, measuring 

of terrain , infrastructure or manmade improvements, Use of sensors on UA for vegetation 

mapping environmental monitoring, quantification and calculation of area and health of 

materials, plumes, natural and mineral resources. Video capture for commercial collection and 

observation to be used in commercials, training videos, documentation, recoding of events, 
3GLP, Inc. dba Precision Flight Devices, 800 E Dimond Blvd, Suite 3-650, Anchorage, AK 99515 

www.PrecisionFlightDevices.com 800.756.5680 Page 22

environmental observation, counting and classification of physical, natural or mineral resource 

activity or development.

Privacy and National Security

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

consent and knowledge. Inspection will be of inanimate objects in areas where the owners will 

have consented to the inspections or otherwise have agreed to allow the UAS and the Operator 

to be in the area where operations will take place. 

The size of the UAS, its speed and restricted area of operation do not raise national security 

issues.

Summary

Approval of exemptions allowing commercial operations of sUAS’s for PRECISION FLIGHT 

DEVICES to operate an unmanned aircraft system (UAS) to operate small unmanned aerial 

vehicle (sUAV), (55lbs or less) for geospatial surveying, measurement and inspections, 

collection of photographs and video and broadcast of video and telemetry data. for the following 

purposes: Geographic mapping, delineation, measuring and 3D modelling of terrain , 

infrastructure or manmade improvements, Use of sensors on UA for vegetation mapping 

environmental monitoring, quantification and calculation of area and health of materials, plumes, 

natural and mineral resources. Video capture for commercial collection and observation to be 

used in commercials, training videos, documentation, recoding of events, environmental 

observation, counting and classification of physical, natural or mineral resource activity or 

development. Training to persons individually or belonging to private or public organizations to 

increase awareness and improve safety for current and future UAS operations within the NAS.

special events: including high schools. colleges, professional sports, open air events and fairs, 

research, risk management and assessment, motion picture production, surface mining, closed 

set filming, disaster and catastrophe events, will enhance safety by reducing risk. 

Conventional operations, using jet or piston powered aircraft, ladders or placing people in 

swamps, on roofs or tall, hazardous or weakened structures, exposes them to higher risks than 

those created by use of a sUAV’S. Conventional aircraft that operate at extremely low altitudes 

just feet from the subject being inspected and in extreme proximity to people and structures 

present the risks associated with vehicles that weigh in excess of 6,000 lbs., carrying large 

amounts of jet A or other fuel (140 gallons for jet helicopters). Such aircraft must fly to and from 

the project location. In contrast, a sUAV weighing fewer than 55 lbs. and powered by batteries 

eliminates virtually all of that risk given the reduced mass and lack of combustible fuel carried 

on board. The sUAV is carried to the target area and not flown. The sUAV will carry no

passengers or crew and, therefore, will not expose them to the risks associated with manned

aircraft flights.

The operation of small UASs, weighing less than 55 lbs., conducted under the strict conditions 

outlined above, will provide an equivalent level of safety supporting the grant of the exemptions 

requested herein. These lightweight aircraft operate at slow speeds, close to the ground, and in 

areas that are under the control of the customer for the operations and, as a result, are far safer 
3GLP, Inc. dba Precision Flight Devices, 800 E Dimond Blvd, Suite 3-650, Anchorage, AK 99515 

www.PrecisionFlightDevices.com 800.756.5680 Page 23

than conventional operations conducted with turbine helicopters operating in close proximity to 

the ground and people or the use of individuals to climb the structures to conduct the 

operations.

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 and operation within 

visual line of sight and national security – provide more than adequate justification for the grant 

of the requested exemptions allowing commercial operation of PRECION FLIGHT DEVICES’s 

UAS for the Purposes outlined herein and are consistent with exemptions already granted, 

including Exemptions number 11062 thru 11067, 11080, 11109 through 11112, 11114, 11213, 

11062, 11857, 11398, 11277, 12515, 12496, 11277, 11356, 11206, 11281, 12516, 12580, 

11373A, 11238A, 11239, 11239A, 12505, 12103, 12068, 12208, and 11675.

Sincerely,

3GLP, Inc dba Precision Flight Devices

Attn: Stephen M Colligan

Physical Address:

800 E Dimond Blvd, Suite 3-650

Anchorage, AK 99515

Mailing Address:

PO Box 874294

Wasilla, AK 99687

SColligan@PrecisionFlightDevices.com
3GLP, Inc. dba Precision Flight Devices, 800 E Dimond Blvd, Suite 3-650, Anchorage, AK 99515 

www.PrecisionFlightDevices.com 800.756.5680 Page 24

Appendix A – Operations and USER Guides

Users Manuals and Guides available to the public, for Specific Aircraft and Controllers

used or referenced by PRECISION FLIGHT DEVICES

Aircraft Link to Manual

DJI Phantom 2 http://dl.djicdn.com/downloads/phantom_2/en/PHANTOM2_User_Manual_v1.4_en.pdf

DJI Phantom 3 https://dl.djicdn.com/downloads/phantom_3/en/Phantom_3_Professional_User_Manual__V1.6.pdf

DJI Inspire 1 http://www.dji.com/product/inspire-1/info#downloads

DJI Matrice 100 https://developer.dji.com/matrice-100/

DJI NAZA MV2 Controlle http://dl.djicdn.com/downloads/nazam-v2/en/NAZA-M_Quick_Start_Guide_v1.26_en.pdf

DJI S800 thru S1000 http://www.dji.com/products/prosystem

DJI A2 Controller http://www.dji.com/product/a2?www=v1

3DR X8, https://3dr.com/kb/x8/

3DR Iris https://3dr.com/kb/iris/

3DR Solo https://3dr.com/kb/solo/

3DR AeroM https://3dr.com/kb/aero-m/

3DR Pixhawk Controller https://3dr.com/kb/pixhawk/

Open Mission Planner https://www.dronecode.org/software/compatible-ground-control-stations

PFDCumulUS Similar Configuration to 3DR Aero M, with Pixhawk controller

PFD x-450/ PDF 550 DJI, 3DR Controller similar configuration to DJI Phantom 2/3 3DR Solo

PFD cx-850M Similar Configuration 3DR X8 with Pixhawk Controller

Altavian Nova F6500 https://www.altavian.com/Drones

SenseFly eBee https://www.sensefly.com/drones/ebee.html

Topcon Sirus https://www.topconpositioning.com/sites/default/files/product_files/sirius_solutions_catalog_7010_2162_revb_sm_

Topcon Falcon 8 https://www.topconpositioning.com/sites/default/files/product_files/falcon_8_brochure_7010_2183_reva_sm_0.pdf

Trimble UX5 http://uas.trimble.com/ux5 http://uas.trimble.com/faa-exemption
3GLP, Inc. dba Precision Flight Devices, 800 E Dimond Blvd, Suite 3-650, Anchorage, AK 99515 

www.PrecisionFlightDevices.com 800.756.5680 Page 25

Appendix B - General Safety and Maintenance Procedures

A) Maintenance Schedule

BEFORE & AFTER EVERY FLIGHT

 Check condition of props (inspect leading and trailing edges for 

chips, flex both blades to check for hairline cracks on prop blade 

and hub

 Check brushless motor shafts, excessive bearing play, bell housing 

and propeller mounts

 Check motors move freely when spun by hand;

 Check condition of battery connectors, balance tabs and signal 

connections, individual cell voltage

 Check camera mounts are secure 

 When powered up and idling confirm no unusual noise or vibration

from motors.

EVERY 10 FLIGHTS

 Visual inspection of shell and other plastic components for 

cracking/damage (landing skids, camera mounting plates, etc.);

 Check tightness of motor retaining screws and shell retaining 

screws

 Clean data spring pins and battery contact pads with alcohol and 

swab or proprietary electrical contact cleaner and cycle spring 

pins several times to check for spring weakness and full 

unimpeded travel

 Check batteries for number of cycles and discharge per 

manufacturers recommendations if required.

EVERY 40 FLIGHTS

 Remove upper shell and check state of all wiring - plugs fully 

seated, condition of all solder joints, condition of visible circuit 

boards and wiring runs, internals generally clean and no 

debris/loose items.

 At any time, if defects are identified that would compromise flight 

operations, communication between sUAS and controller, and/or 

camera function, repair or replace parts with Manufacture OEM or 

better quality parts sUAS.

 Perform Computer Battery Analyzer (CBA) under load tests on each 

battery, log cell and capacity health in database.
3GLP, Inc. dba Precision Flight Devices, 800 E Dimond Blvd, Suite 3-650, Anchorage, AK 99515 

www.PrecisionFlightDevices.com 800.756.5680 Page 26

B) Record Keeping

A digital record will be kept for all pre-flight, PIC documentation, flights, 

flight times, atmospheric conditions, telemetry, and maintenance records. 

Precision Flight Devices has standard forms and logs on file as standard 

operating procedures.

C) Securing Flight Site

FSDO Submissions

The sUAS PIC will notify the FAA under the current rules of notification for 

operation, with the appropriate Flight Standards District Office.

Safety Parameter

i. Before filming occurs, a 100 yard perimeter from the planned flight 

path will be identified in order to set a “sterile” environment for the

operation.

ii. sUAS operator must obtain written or oral permission from all 

landowners in sterile environment.

iii. sUAS operator will follow Federal, State and Local rules of 

notification before operation.

iv. At all times sUAS operator will follow best industry practices for 

operation and safety and will also carry a minimum of $1mm in 

general liability insurance in case of any damage to property or 

persons within the safety parameter.

Identify potential obstacles

Photographs of each flight area will be taken as part of mission 

planning and mission documentation. Before each mission, an 

inventory will be taken for all potential obstacles that must be 

avoided while in flight. Including:

1. Powerlines

2. Cell Phone Towers

3. Trees

4. Flocks of birds that may take flight

5. Heavily traveled roadways

6. Utility wires

7. Elevated structures

8. At least 5 nautical miles from the nearest airport or helipad.
3GLP, Inc. dba Precision Flight Devices, 800 E Dimond Blvd, Suite 3-650, Anchorage, AK 99515 

www.PrecisionFlightDevices.com 800.756.5680 Page 27

D) Pre-Flight Checklist

Take Off Location/ “Home”

The sUAS will mark its take off location as a safe area to return to 

should the sUAS lose signal with the control or if the pilot signals 

the craft to return to its “home” location.

Take off location will be in an area with a 25ft radius with no 

obstructions, maintaining said radius vertically 200ft.

The sUAS will take off and land in the same location.

GPS Altimeter will be marked as 0’ elevation

Flight Canceling Events

All flights will be cancelled until the area is cleared if any of the

below occur:

Police activity in the area

Low flying aircraft in the area

Medical/News Helicopters active in the area

Wind exceeding 25 mph

Any emergency requiring emergency services occurs within the 

sterile environment

PIC is unable to complete flight without losing visual of the sUAS

Any precipitation

Heavy bird presence in the area that could cause a mid-air 

collision.

Any defects or damage found during preflight exam to the UAS or 

communications equipment.

Physical Inspection

Before each flight the sUAS will be checked to ensure that it is safe for 

flight.

 Battery voltage will be checked to ensure it is >75%

 Blades will be inspected to ensure they are tightened and free of 

damage

 Camera mount and gimbal will be inspected to ensure it is fully 

attached and operating.

 sUAS will be checked for any damage that may have taken place 

in transit.

 The sUAS will be tested at a low altitude to ensure all controls are 

responding correctly.

 Battery checked for damage that could affect its charge

 If any party of the inspecting shows a damaged part or parts, the 

sUAS is deemed non-usable and must be inspected by a 

factory trained technician.
3GLP, Inc. dba Precision Flight Devices, 800 E Dimond Blvd, Suite 3-650, Anchorage, AK 99515 

www.PrecisionFlightDevices.com 800.756.5680 Page 28

Post Flight Inspections/Checklist

 After each flight, the sUAS will be thoroughly inspected for any 

damage that occurred in flight.

 Body inspected for any damage

 Blades visually checked for any damage at all

 Battery checked for damage

E) Mid-Air Safety Protocol

Max Speed

Accent: 1. 10m/s

Decent: 4m/s

Flight Speed: less than - Multi Rotor 15 m/s, Fixed Wing 21 m/s

Altitude

The sUAS is never to exceed 400ft

Emergency

If it appears that the UAS, any property or humans are at risk, the 

sUAS will be grounded immediately to a safe location.

Visual Line of Sight

The pilot must keep the sUAS within eyesight at all times 

unassisted by any technology.

F) Participation by non-pilot staff

All staff involved in the production or filming using the sUAS will 

consent to maintain a safe distance of at least 30 ft during the

operations.