Vineyard Aviation, LLC Section 333 Exemption Petition

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May 21, 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 of the Federal Aviation 

Regulations from 14 C.F.R. 45.23(b); 14 C.F.R. Part 21; 14 C.F.R Part 27; 91.7(a);

91.9(b) (2); 91.103(b); 91.109; 91.121; 91.151(a); 91.203(a)&(b); 91.405(a);

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

Dear Sir or Madam,

I, Justin Burrell, owner of Vineyard Aviation, LLC, am writing pursuant to the FAA Modernization and 

Reform Act of 2012 and the procedures contained within 14 C. F R. 11. I, Justin Burrell, owner and 

operator of small unmanned aircraft, am requesting to be exempted from the Federal Aviation Regulations 

("FARs") as outlined in this petition. This petition for exemption is so that I, Justin Burrell, may operate 

my small light weight unmanned aircraft system ("UAS") commercially in airspace regulated by the 

Federal Aviation Administration ("FAA").

I. Description of Petitioner:

Vineyard Aviation, LLC is a single proprietor owned company operated by myself, Justin Burrell. I have 

been a full time Airline Transport Pilot since 2004 (Cert. #3289415) and maintain a first class medical 

certificate. I, Justin Burrell, have a diverse background in management and consulting in the aviation 

industry and am experienced in flying hobby unmanned aircraft systems for recreational purposes. Over the 

last five years, I have flown multiple RC airplane and quad- copter aircraft recreationally piloted by remote 

control without incident.

It is my intent via Vineyard Aviation, LLC to operate UAS, DJI Phantom 3 Professional, for aerial 

imaging to enhance individual and company awareness in relation to agricultural, geological, and real

estate survey and inspection. Traditionally, much of this type of imaging has been done with the use of 

fixed-wing aircraft and full-scale rotorcraft. The use of fixed-wing aircraft and rotorcraft in low level 

operations present risks of such vehicles carrying large amounts of combustible fuel and aircraft weights of 

thousands of pounds. The operation of a small UAS will eliminate risks associated with these traditional 

methods of agricultural, geographical and real estate survey and inspection.

Vineyard Aviation UAS operations for the purposes described above will occur under tightly controlled 

conditions mostly on privately owned property at the owner's or authorized representative's request and 

consent. Generally, these agricultural areas are located in rural settings away from buildings, people, and 

crowds. Those operations not occurring on privately owned property will occur under tightly controlled 

conditions and conducted away from congested or densely populated areas and at low levels of flight.
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Vineyard Aviation operations will be conducted in compliance with in the conditions and limitations of the 

UAS manufacturer's aircraft/component manual and limitations of this Petition for Exemption. Operations 

will be limited to VFR conditions in daytime hours at altitudes at or below 400 feet AGL and remaining 

clear and yielding the right of way to all manned aviation operations and activities at all times.

Petitioner's Contact Information:

Vineyard Aviation, LLC

c/o Justin Burrell

13253 Saint Tropez Circle

Palm Beach Gardens, Fl 33410

Tel: 504-453-8254

Email: jburr737@gmail.com

For ease of review please refer to the following table of contents found on the next page.
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Table of Contents

I. Description of Petitioner

II. Description of Proposed Operations

III. Relevant Statutory Authority

IV. Vineyard Aviation's Proposed UAS Operations meet the Requirements of Section 333 of 

the Reform Act

V. Regulations From Which Exemption is Requested

A. 14 C.F.R. Part 21, Subpart H – Airworthiness Certificates and 14 C.F.R. § 91.203 

B. 14 C.F.R. Part 27 Airworthiness Standards: Normal Category Rotorcraft 

C. 14 C.F.R. § 91.7(a): Civil Aircraft Airworthiness 

D. 14 C.F.R. § 91.9(b)(2): Civil Aircraft Flight Manual in the Aircraft and 14 C.F.R. 91.203(a) and 

(b): Carrying Civil Aircraft Certification and Registration 

E. 14 C.F.R. § 91.9(c), 45.23(b) and 45.27(a): Aircraft Marking and Identification Requirements 

F. 14 C.F.R. § 91.103: Preflight Action 

G. 14 C.F.R. § 91.109(a): Flight Instruction 

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

I. 14 C.F.R. § 91.121: Altimeter Settings 

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

K. 14 C.F.R. § 91.405(a), 91.407(a)(1), 91.409(a)(1) and (2); 91.417(a) and (b): 

Maintenance Inspections 

VI. Public Safety, Interest, and Benefit 

VII. Privacy

VIII. UAS Manufacturer's Manual

IX. Summary the FAA may Publish in the Federal Register

 

X. Conclusion
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II. Description of Proposed Operations:

Vineyard Aviation intends to use its small UAS for the purpose of conduction of aerial surveys and 

inspection of various agricultural crops inclusive of various citrus, vegetable, and grape varieties. This will 

afford farmers and growers critical information necessary to maximize crop harvest by identifying

diseases, irrigation, and drainage. The use of a small UAS will provide greater resolution and flexibility in 

imaging in this setting. Low flying UASs can deliver information that support crop analysis in a much 

safer, efficient, and cost effective manner than conventional methods using heavier, fuel filled fixedwinged or full scale rotorcraft. 

Vineyard Aviation intends to use its small UAS for the purpose of conduction of aerial surveys and 

inspection of geographical layouts and real estate listings. This will increase public and academic visual 

awareness of land layouts in specified areas of request. The use of a small UAS will provide close-up 

augmented views of real estate listings unattainable by traditional means. The UAS is battery operated and 

creates no emissions. It contains no combustible fuel source rendering it safer than conventional aerial 

photography.

I, Justin Burrell, via Vineyard Aviation intend to operate the UAS at a ground speed no greater 30 knots 

and an altitude at or below 400 feet AGL. All operations will be completed during daylight hours with a 

visual observer ("VO") and operated with in the visual line of sight ("VLOS") of the VO at all times.
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III. Relevant Statutory Authority

This Petition for Exemption is submitted pursuant to Section 333(a) through (c) of the FAA Modernization 

and Reform Act of 2012 ("Reform Act"). Congress has directed the FAA "to safely accelerate the 

integration of civil unmanned aircraft systems into the national airspace system." Pursuant to Section 333 

of the Reform Act, the FAA Administrator is to permit unmanned aircraft systems to operate in the 

National Air Space ("NAS") where it is safe to do so based on the following considerations:

 The UAS's size, weight, speed, and operational capability

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

 Operation of the UAS within the visual line of sight of the operator

In addition, the FAA Administrator has general authority to grant exemptions from the agency's safety 

regulations and minimum standards when the Administrator decides a requested exemption is in the public 

interest. (49 U.S.C § 106 (f) defining authority of the Administrator; 49 U.S.C. § 44701 (f) permitting 

exemptions from § 44701 (a), (b) and § 44702-44716) A party requesting and exemption must explain the 

why the exemption would: (1) benefit the public as a whole, and (2) not adversely affect safety or how it 

would provide a level of safety at least equal to the existing rules. (14 C.F.R. § 11.81 petitions for 

exemption)

IV. Vineyard Aviation's Proposed UAS Operations meet the Requirements of Section 333 of the 

Reform Act

The operation of a small UAS by Vineyard Aviation qualifies for approval pursuant to Section 333 of the 

Reform Act as each of the statutory criteria and relevant factors are satisfied as stated in this Petition for 

Exemption.

A. Approval is warranted based on Vineyard Aviation's small UAS's size, weight, speed, and 

operational capability.

1. The UAS will weigh less than 20 pounds (this includes all equipment and loads).

2. The UAS will not exceed a speed of 25 knots.

3. The UAS will not exceed an altitude of 400 feet AGL.

4. Altitude information will be generated by GPS triangulation that is contained within 

 the UAS. This information is transmitted to the pilot via telemetric data feed (DJI Pilot App).

5. All flights will be flown with enough power to fly at normal cruising speed to the 

 intended landing point and land the UAS with 20% battery power remaining.

6. The UAS will have system independent functionality in the event communications or GPS 

signal is lost. The UAS will return to a pre-determined location and land safely within the 

planned operating area via DJI's Return To Home feature (RTH).
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7. Radio frequencies used for operations and control of the UAS will be in compliance 

 with the Federal Communications Commission ("FCC") or other appropriate oversight agency 

 requirements.

B. Approval is warranted based on the UAS's manufacturer's operational manual and 

Vineyard Aviation's proposed operations.

1. UAS operations will be conducted with a minimum of a Pilot-In-Command ("PIC") 

 and visual observer ("VO") at all times.

2. The UAS will be operated within Visual Line of Sight ("VLOS") of the PIC and VO 

 at all times during flight. 

3. All flights will be operated during day light hours.

4. The UAS will be operated in compliance with all manufacturer Safety Bulletins in 

 addition to the UAS operational manual and firmware updates.

5. The UAS will remain clear and yield the right of way to all manned aviation 

 operations and activities at all times.

6. The PIC will abort the flight in the event of unpredicted obstacles or emergencies.

7. Vineyard Aviation will obtain an Air Traffic Organization ("ATO") issued Certificate 

 of Waiver or Authorization ("COA") prior to conducting any operations under this grant of 

 exemption. This COA will require Vineyard Aviation to request a Notice to Airman 

 ("NOTAM") with the appropriate ATC facility 48 to 72 prior to UAS operation.

8. Vineyard Aviation will obtain all required permissions from the landowner/controller 

 or authorized representative prior to operations over private or controlled-access property.

9. Prior to each flight the PIC shall do a pre-flight inspection of the UAS to ensure it is in a 

condition for safe flight. If the UAS inspection reveals a condition that affects safe 

operation of the UAS, the UAS will be grounded until the necessary maintenance has been 

performed and the UAS is found in a condition for safe flight. The Ground Control Station will 

be included in the pre-flight inspection. All maintenance and alterations will be properly 

documented in the UAS records.

10. The UAS will not be operated higher than 200 feet within a quarter mile from an airport or any 

flight path or flight operation; or 5 nautical miles (NM) from an airport having an operational 

control tower; or 3 NM from an airport with a published instrument flight procedure, but not an 

operational tower; or 2 NM from an airport without a published instrument flight procedure or 

an operational tower; or 2 NM from a heliport with a published instrument flight procedure.
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In addition, the DJI Pilot app displays warning messages and UAS altitude restrictions when the 

UAS enters within 320 feet of No-Fly Zones. Furthermore the UAS firmware will not allow the 

UAS motors to activate in No-fly Zones (Phantom 3 Professional User Manual v1.0 pages 41, 42, 

43). These features coupled with the operator's Airline Transport Pilot's airspace knowledge and 

situational awareness will thoroughly ensure the UAS does not interfere with airport and airspace 

manned aircraft operations.

11. Vineyard Aviation's PIC will be an Airline Transport Pilot ("ATP") that holds at least 

a current Third Class Medical Certificate.

V. Regulations From Which Exemption is Requested

A. 14 C.F.R. Part 21, Subpart H – Airworthiness Certificates and 14 C.F.R. § 91.203 

The FAA has stated that no exemption is needed from this section if a finding is made under the Reform 

Act that the UAS selected provides an equivalent level of safety when compared to aircraft normally used 

for the same application. These criteria are met, and therefore no exemption is needed. See Grant of 

Exemption to Astraeus Aerial, Docket No. FAA-2014-0352 at 13-14, 22. If, however, the FAA determines 

that there are some characteristics of the chosen UAS that fail to meet the requirements of the Reform Act, 

an exemption is requested. 

The DJI Phantom 3 Professional that Vineyard Aviation intends to use meets this equivalent level of safety 

taking into account its size, weight, speed, and operational capability. As set forth in the description of 

proposed operations in Section II, the UAS weighs less than 20 pounds and will be flown at less than 25 

knots and outside controlled airspace. Additionally, the UAS carries neither pilots nor passengers, no 

combustible materials or flammable liquid fuels, and operates exclusively within the parameters stated in 

the manufacturer's manual. 

Operations conducted under this exemption will be closely controlled and monitored by the operator and 

will be conducted in compliance with local public safety requirements to provide security for the area of 

operation. Vineyard Aviation will also provide the FAA with advance notice of operations via NOTAMs as 

necessary. 

Further, the UAS does not need a means to communicate with other aircraft or ATC, because those 

capabilities will be possessed by the PIC and Observer, who are not onboard the UAS. See Grant of 

Exemption, Docket FAA-2014-0352 at 13. In addition, no sense-and-avoid technology is necessary for the 

UAS because it will be operated at all times in VFR conditions and within VLOS of the PIC and Operator. 

B. 14 C.F.R. Part 27 Airworthiness Standards: Normal Category Rotorcraft 

Title 14 C.F.R. Part 27 sets forth the procedural requirements for airworthiness certification of normal 

category rotorcraft. To the extent that Vineyard Aviation's small UAS would otherwise require certification 
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under Part 27, Petitioner seeks an exemption from Part 27's airworthiness standards for the same reasons 

identified in the request for exemption from 14 C.F.R. Part 21, Subpart H, supra.

C. 14 C.F.R. § 91.7(a): Civil Aircraft Airworthiness

Vineyard Aviation seeks an exemption from 14 C.F.R. § 91.7(a), which requires that a civil aircraft be in 

airworthy condition to be operated. The FAA has stated that no exemption is required for 14 C.F.R. § 

91.7(a) to the extent that the requirements of Part 21 are waived or found inapplicable. Therefore, no 

airworthiness certificate would be issued for Vineyard Aviation's UAS. See Grant of Exemption to 

Astraeus Aerial, Docket No. FAA-2014-0352 at 13-14, 22. Accordingly, Petitioner requests that the 

requirements for § 91.7(a) be treated in accordance with Section V(A), supra.

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

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

91.9(b)(2) and § 91.203(a) and (b) require the operator to carry airworthiness documents 

and other aircraft manuals onboard the aircraft. Pursuant to 14 C.F.R. § 91.9(b)(2): 

(b) No person may operate a U.S.-registered civil aircraft –

(2) For which an Airplane or Rotorcraft Flight Manual is 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. 

Pursuant to 14 C.F.R. § 91.203(a) and (b): 

(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 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 small size and configuration of the UAS render it without a cabin or cockpit, making it impossible to 

store airworthiness documents and other aircraft manuals on board. 

In an FAA Office of Chief Counsel's Opinion dated August 8, 2014, and prepared by Dean E. Griffith, 

Attorney, AGC-220, it was acknowledged that the intent of 14 C.F.R. 91.9(b) and 91.203(a) and (b) is met

if the pilot of the unmanned aircraft has access to the UAS flight manual, registration certificate, and other 

required documents from the ground control station from which he or she is operating the aircraft. (1)
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_______________________

1 Memorandum from Mark Bury, FAA Assistant Chief Counsel for International Law, Legislation and 

Regulation, to John Duncan, FAA Flight Standards Service (Aug. 8, 2014); see also Docket No. FAA-2014-

0352 at 16-18.

As this FAA Office of Chief Counsel Opinion clarifies, the intent of the rule is to ensure the pilot has 

access to these key documents during flight. Therefore, an equivalent level of safety will be achieved by 

ensuring that the pilot has access to the documents at the ground control station from which he or she is 

piloting the UAS.

E. 14 C.F.R. § 91.9(c), 45.23(b) and 45.27(a): Aircraft Marking and Identification

Requirements

Vineyard Aviation seeks an exemption from the aircraft marking and identification requirements contained 

in 14 C.F.R. §§ 91.9(c), 45.23(b) and 45.27(a).

● 14 C.F.R. § 91.9(c), Civil Aircraft Flight Manual, Marking and Placard requirements, provides: 

No person may operate a U.S.-registered civil aircraft unless that aircraft is identified in 

accordance with Part 45 of this chapter. 

● 14 C.F.R. § 45.23(b), Markings of the Aircraft, states: 

When marks include only the Roman capital letter "N" and the registration number is 

displayed on limited, restricted or light-sport category aircraft or experimental or 

provisionally certificated aircraft, the operator must also display on that aircraft near each 

entrance to the cabin, cockpit, or pilot station, in letters not less than 2 inches nor more than 

6 inches high, the words "limited," "restricted," "light-sport, "experimental," or 

"provisional," as applicable. 

● 14 C.F.R. § 45.27(a), Rotorcraft, states: 

Each operator of a rotorcraft must display on that rotorcraft horizontally on both surfaces of 

the cabin, fuselage, boom, or tail the marks required by § 45.23. 

In a previous Grant of Exemption, the FAA determined that exemption from these requirements was 

warranted provided that the aircraft "have identification (N-Number) markings in accordance with 14 

C.F.R Part 45, Subpart C if the markings are as large as practicable." FAA Docket No. FAA-2014-0352.

Vineyard Aviation's UAS will bear N-Number markings that are as large as practicable in accordance with 

14 C.F.R. Part 45, Subpart C (2)

________________________

2 See, e.g., FAA Docket No. FAA-2014-0352, at 14. 
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F. 14 C.F.R. § 91.103: Preflight Action 

Vineyard Aviation seeks exemption from 14 C.F.R. § 91.103, which requires a PIC to become familiar 

with specific information before each flight, including information contained in the FAA-approved Flight 

Manual on board the aircraft. While the PIC will be familiar with all information necessary to safely 

conduct the flight, an exemption is requested to the extent that an FAA-approved Flight Manual is 

required.

An equivalent level of safety will be provided by Vineyard Aviation's compliance with the Manufacturer's 

Manuals and it's PIC will perform a series of checklists designed to identify any defects or inoperable 

components. These checklists will be inclusive of Pre-Flight, Launch, Landing, and Post-Flight 

procedures. The PIC will also review weather, flight requirements, battery charge, landing and takeoff 

distance, and contingency landing areas before initiation of flight. Manufacturer's Manual, and any other 

relevant manufacturer publications will be kept at the GCS and will be accessible to the PIC at all times 

while operating the UAS.

G. 14 C.F.R. § 91.109(a): Flight Instruction 

Vineyard Aviation seeks an exemption from 14 C.F.R. § 91.109(a), which provides in pertinent part that 

"[n]o 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." UASs and remotely piloted aircraft, by 

their design, do not have functional dual controls. Instead, flight control is accomplished through the use of 

a device that communicates with the aircraft via radio communications. Accordingly, an exemption will be 

required for the flight instruction requirements of 14 C.F.R. § 91.109(a).

In regards to the size and speed of the DJI Inspire that Vineyard Aviation intends to use, an equivalent 

level of safe training can be performed without dual controls because no pilot or passengers are aboard the 

UAS. All Flight training will be conducted with all persons a safe distance away in the event that the UAS 

experiences any difficulties during flight instruction.

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

Vineyard Aviation requests an exemption from the minimum safe altitude requirements of 14 C.F.R. § 

91.119. Section 91.119 prescribes the minimum safe altitudes under which aircraft may not operate, 

including 500 feet above the surface and away from any person, vessel, vehicle, or structure in noncongested areas. See 14 C.F.R. § 91.119(c). Section 91.119(d) allows for a helicopter to operate at less than 

those minimum altitudes when it can be operated "without hazard to persons or property on the surface," 

provided that "each person operating the helicopter complies with any routes or altitudes specifically 

prescribed for helicopters by the FAA." 
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An exemption is required because in order to perform the intended agricultural/real estate aerial surveys 

and inspections, the UAS will need to be operated lower than 400 feet AGL. Further, due to the nature of 

the proposed operations, the PIC and Observer may at times be less than 500 feet away from the UAS.

Compared to flight operations with rotorcraft weighing far more than the maximum weights proposed 

herein, and given the lack of flammable fuel with the UAS operated by Vineyard Aviation, any risk 

associated with these operations is far less than those that presently exist with conventional aircraft. An 

equivalent level of safety will be achieved given the size, weight, and speed of the UAS, as well the 

controlled location where the operations will occur. In order to avoid any risk to manned aircraft, flight 

operations will be restricted to 400 feet AGL or below. The UAS will be operated over private or 

controlled access property with permission from the land owner/controller or authorized representative and 

all flights will be operated at a lateral distance of at least 500 feet from any nonparticipating persons, unless 

that person is in a position where he or she is shielded from the UAS and any possible debris resulting from 

UAS failure. Further, UAS operations will occur at least 500 feet away from vehicles or structures unless 

the property owner/controller has granted permission and the PIC has made a safety assessment of the risk 

of operating closer to those objects and, operations near the PIC or Observer will not present an undue 

hazard per § 91.119(a). As a whole, these requirements ensure a level of safety better than or equal to the 

rules from which exemption is sought.

I. 14 C.F.R. § 91.121: Altimeter Settings 

Vineyard Aviation seeks an exemption from 14 C.F.R. § 91.121, which requires a person operating an 

aircraft to maintain cruising altitude or flight level by reference to an altimeter that is set to the elevation of 

the departure airport or barometric pressure. An exemption is required to the extent that the UAS does not 

have a barometric altimeter, but rather a GPS altitude read out. 

The FAA has stated that an equivalent level of safety to the requirements of 14 C.F.R. § 91.121 can be 

achieved in circumstances where: (1) the UASs will be operated at 400 feet AGL or below, (2) within 

VLOS, (3) where GPS based altitude information is relayed in real time to the operator at a ground-based 

on-screen display and, (4) where prior to each flight, a zero altitude initiation point is established for the 

PIC to confirm accuracy of the onboard GPS. See Grant of Exemption to Astraeus Aerial, Docket No. 

FAA-2014-0352 at 21. 

The UAS that Vineyard Aviation uses for performing the proposed UAS operations will meet all these 

operational characteristics. Moreover, the PIC will calibrate the aircraft's GPS compass prior to each flight 

operation. Like the Grant of Exemption to Astraeus Aerial, the UAS Vineyard Aviation intends to use

ensures that an equivalent level of safety will be achieved, and a grant of exemption to the requirements of 

§ 191.121 is therefore appropriate. See (Phantom 3 Professional User Manual v1.0 pages 44, 45 "Calibrating 

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

Vineyard Aviation requests an exemption from 14 C.F.R. § 91.151(a)'s fuel requirements for flight in VFR 

conditions. Section 91.151 states: 

(a) No person may begin a flight in an airplane under VFR conditions unless (consideringwind 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. 

Here, the technological limitations on UAS battery power means that no meaningful flight operations can 

be conducted while still maintaining a 30-minute battery reserve. An exemption from the fuel requirements 

of 14 C.F.R. § 91.151(a) is therefore required.

The FAA has stated that an equivalent level of safety can be achieved by requiring that each UAS operation be 

completed within 30 minutes flight time or with 20% battery power remaining, whichever occurs first. See 

Grant of Exemption to Clayco, Inc., Docket No. FAA-2014-0507 at 15. Vineyard Aviation intends to conform 

to this limitation, and therefore provides an equivalent level of safety. In addition, the DJI Phantom 3 

Professional utilizes many failsafe features to ensure adequate energy reserves for safe return including: Low 

Battery Warning, Critical Battery Warning, and a Low Battery Return To Home (RTH) feature (Phantom 3 

Professional User Manual v1.0 pages 12, 13). 

K. 14 C.F.R. § 91.405(a), 91.407(a)(1), 91.409(a)(1) and (2); 91.417(a) and (b): 

 Maintenance Inspections 

Vineyard Aviation seeks an exemption from the maintenance inspection requirements contained in 14 

C.F.R. § 91.405(a), 91.407(a)(1), 91.409(a)(2); 91.417(a) and (b). These regulations specify maintenance 

and inspection standards in reference to 14 C.F.R. Part 43. See, e.g., 14 C.F.R. § 91.405(a) (stating that 

each owner or operator of an aircraft shall have the aircraft inspected as prescribed in subpart E of this part 

and shall between required inspections have discrepancies repaired as prescribed in part 43 of this chapter). 

An exemption from these regulations is needed because Part 43 and these sections only apply to aircraft 

with an airworthiness certificate, which the UAS to be operated under this grant of exemption will not 

have.

An equivalent level of safety will be achieved due to maintenance and inspections performed in accordance 

with the Manufacturer's Manuals and any required manufacturer Safety or Service Bulletins. Furthermore, 

the PIC will conduct a pre-flight inspection of the UAS and all associated equipment to account for 

discrepancies and/or inoperable components. Maintenance will be performed and verified to address any 

conditions potentially affecting safe operation of the UAS and no flights will occur unless, and until all 
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flight critical components of the UAS have been found to be airworthy and in a condition safe for 

operation. A functional test flight will be conducted following the replacement of any flight-critical 

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

records of the flight.

VI. Public Safety, Interest, and Benefit 

Vineyard Aviation's Petition for Exemption will be in the interest of public safety and contribute to the 

innovation and implementation of new safety protocols for UAS operators. Congress has established a 

national policy that favors early integration of UAS into the NAS in controlled, safe working environments 

such as those proposed in this Petition. Granting this Petition for Exemption helps fulfill Congress' goal in 

passing Section 333(a) through (c) of the Reform Act—the FAA Administrator's assessment of whether 

certain UAS may operate safely in the NAS before completion of the statutorily required rulemaking. The 

granting of this petition will also help lead the way for a better controlled environment in the commercial 

use of UASs.

The proposed UAS operations in this Petition for Exemption significantly improve safety and reduce risk 

by alleviating the public's exposure to danger and emissions associated with traditional agricultural & real 

estate aerial survey and inspection methods. Specifically speaking, full size fixed-wing aircraft and 

rotorcraft are traditionally used for these types of surveys. Vineyard Aviation intends to use a battery 

powered light weight quad-copter which creates no emissions. Moreover, in the unlikely event that the 

Petitioner has a UAS crash, there is no fuel to ignite and explode. Any incident involving the Petitioner's 

lightweight UAS will present significantly less danger to the pilot and other individuals on the ground than 

one that would involve a full size helicopter or fixed-wing aircraft. 

Moreover, the agricultural modeling and imaging resulting from Vineyard Aviation's UAS will provide 

farmers and growers with valuable information needed so that they can produce more from their land while 

conserving valuable resources like water and energy. The ability to pinpoint and precision spray pesticides 

reduces human exposure to pesticides and also mitigates negative side-effects on the ecology of the farm

associated with overuse of pesticides. The public as a whole will benefit from an agricultural industry that 

can harness the power of new technologies to produce better crops in a cost-effective, sustainable and 

environmentally conscious manner. 

Vineyard Aviation's imaging capabilities will also provide builder and community geographical awareness 

in real estate development. The use of a UAS will provide a more cost-effective method of imaging that 

isn't afforded to small private business, allowing them to be more competitive in the marketplace. A small 

UAS without people on board will also allow the operator to obtain images that aren't currently able to be 

viewed without extreme measures via helicopter or fixed-winged aircraft. The small size and extreme 

maneuverability of the UAS will allow the PIC to avoid hazards quickly and safely without the risks of 

catastrophic crash associated with full scale aircraft. 
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VII. Privacy

All Vineyard Aviation's UAS operations will be conducted in accordance with applicable federal, state, or local 

laws regarding privacy. Vineyard Aviation will not conduct flight operations over property that it does not own 

or control without the prior consent and knowledge of the property owner.

VIII. UAS Manufacturer's Manual
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IX. Summary the FAA may publish in Federal Register

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: 

Petitioner seeks an exemption from the following rules in Title 14 of the Code of Federal Regulations: 

Part 21, Subpart H; Part 27; 45.23(b); 45.27(a); 91.7(a); 91.9(b)(2); 91.9(c); 91.103; 91.109(a); 91.119; 

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

The exemption will enhance safety by reducing risk to the general public and property owners from the 

substantial hazards associated with performing equivalent agricultural aerial surveys and inspections with 

conventional fixed-wing aircraft, rotorcraft, or other methods.

X. Conclusion

Vineyard Aviation's Petition for Exemption satisfies the criteria articulated in Section 333 of the 

Reform Act of 2012 including weight, speed, operating capabilities, proximity to airports and populated 

areas, operation within VLOS and national security. The proposed UAS operations will benefit the public 

as a whole by improving safety and reducing risk by alleviating human exposure to danger and having a

current FAA ATP rated PIC actively involved in the UAS business community. In consideration of the 

foregoing, this Petition for Exemption provides the FAA with more than adequate justification for granting 

the requested exemptions allowing Vineyard Aviation to use UASs for aerial imaging to enhance 

individual and company awareness in relation to agricultural, geological, and real estate survey and 

inspection.

I thank you for your prompt consideration of the requested exemptions. Should you have any 

questions, or if you need any additional information to support the requested exemptions, please feel free to

contact me at: 

Vineyard Aviation, LLC

c/o Justin Burrell

13253 Saint Tropez Circle

Palm Beach Gardens, Fl 33410

Tel: 504-453-8254

Email: jburr737@gmail.com