December 18, 2015 

U.S. Department of Transportation 

Docket Management System 

1200 New Jersey Ave. SE 

Washington, DC 20590 

RE: Exemption Request under Section 333 of the FAA Reform Act and Part 11 of the Federal Aviation 

Regulations 

Dear Sir or Madam, 

Pursuant to § 333 of the Federal Aviation Administration (FAA) Modernization and Reform Act of 

2012, Pub. L. No. 112-95 (2012), 126 Stat. 11, the FAA’s general exemption authority under 49 USC § 

44701(f), and 14 CFR Part 11, Lamp Rynearson & Associates, Inc. (hereinafter, “Lamp Rynearson”) seeks an 

exemption from the following Code of Federal Regulations (CFR): 

• 14 CFR Part 21; 

• 14 CFR § 45.23(b); 

• 14 CFR § 61.113(a) & (b); 

• 14 CFR § 61.315(a) & (c); 

• 14 CFR § 91.7(a); 

• 14 CFR § 91.9(b)(2); 

• 14 CFR § 91.103(b)(1); 

• 14 CFR § 91.109(a); 

• 14 CFR § 91.119; 

• 14 CFR § 91.121; 

• 14 CFR § 91.151(a); 

• 14 CFR § 91.203 (a) & (b); 

• 14 CFR § 91.405(a); 

• 14 CFR § 91.407(a)(1); 

• 14 CFR § 91.409(a)(1) &(2); 

• 14 CFR § 91.417(a) & (b) 

These CFRs and the proposed exemption are discussed further in Section 6. The proposed 

exemption, if granted, would allow Lamp Rynearson to conduct commercial operations of small Unmanned 

Aircraft System (UAS) for purposes to include: aerial survey, aerial mapping, aerial videography and 

photography, asset inventory and management, construction site monitoring and inspections, energy 

systems inspections, industrial inspections, telecommunications inspections, pipeline inspections, utility 

inspections, precision agricultural services, UAS education and training, and disaster response/damage

assessment missions under the conditions outlined herein and as may be established by the FAA in granting 

the requested exemptions. 

 Lamp Rynearson believes that the benefits of using UAS for our business purposes are significant. 

Replacing significantly larger manned aircraft carrying crew and flammable fuel with a UAS weighing less 

than 55 pounds provides an enhanced level of safety to both the crew and to those on the ground. The 

small size and maneuverability of a UAS will also make it possible to safely and efficiently collect high 

resolution, accurate data in environments inaccessible to traditional aircraft. And because Lamp Rynearson 

will incorporate these systems into many of our contracts with public agencies, these more efficient 

operations will translate to lower project costs and increased savings for the agencies, and ultimately the 

taxpayers. Considering these points, we feel that the issuance of the proposed exemptions are in the public 

interest. 

Operations carried out under the exemption will be subject to strict operating requirements and 

conditions to ensure at least an equivalent level of safety to currently authorized operations using manned 

aircraft. The UAS proposed and described in Section 3 are manufactured commercially by experienced and

respected manufacturers. They weigh well under the maximum 55 pounds, including payload and are 

electrically powered via small, rechargeable, lithium batteries and hence, carry no fuel onboard. The UAS 
also have extensive automated control features, redundant systems, and integrated fail-safes, and will be 

operated under controlled conditions and at low altitudes in airspace that is limited in scope. 

All UAS operations will be carried out by a crew of at least two people: a pilot-in-command (PIC) 

and visual observer. The PIC is responsible for the direct and safe operation of the UAS, monitoring its status 

and flight dynamics while maintaining visual line of sight and keeping the flight within the manufacturer’s 

specified limits in terms of wind, flight range, battery life, etc. The observer will be act as a second set of 

eyes, monitoring the airspace and controlled operating area for hazards such as aircraft, structures, 

vegetation, wildlife and persons (operationally involved and uninvolved). The observer will also inform the 

PIC before and during flight of all observed risks. The PIC will be a certified airman with, at minimum, sport 

pilot privileges and limitations. The PIC will also maintain a current third-class medical certificate. 

Based on the small size of the proposed UAS, the qualifications and experience of our staff, and the 

limited, controlled operating procedure, Lamp Rynearson contends that the requested exemptions clearly 

fall within the safety parameters envisioned by Congress as set forth in § 333 of the Reform Act. Additionally, 

utilizing small, electronically powered UAS for our proposed operations instead of traditional crewed aircraft 

provide an enhanced level of safety and increased efficiencies, both of which are in the public interest. Thus, 

Lamp Rynearson respectfully requests that you grant our request for exemption. 

Kindest Regards, 

Mark R. Steele, GISP 

GIS Specialist 

Lamp Rynearson & Associates, Inc 
1 

Petition for Exemption Under Section 333 of the FAA Reform Act and Part 11 

of the Federal Aviation Regulations

For the sake of convenience, this Petition is organized as follows: 

Contents 

1. Description of Petitioner ......................................................................................................... 1

2. Proposed Applications ............................................................................................................ 1

3. UAS Descriptions ..................................................................................................................... 2

4. Public Interest and Benefits .................................................................................................... 6

5. Lamp Rynearson & Associate’s UAS Operations Manual ....................................................... 7

6. Requested Exemptions and Equivalent Level of Safety ........................................................ 11

7. Support Documentation ....................................................................................................... 15

8. Summary for Publication ...................................................................................................... 15

1. Description of Petitioner 

The name and Address of the petitioner is: 

Lamp Rynearson & Associates, Inc. 

Attn: Mark R. Steele, GISP 

14710 West Dodge Road, Ste 100 

Omaha, NE 68154 

402-496-2498 

mark.steele@lra-inc.com

Lamp Rynearson & Associates, Inc is a civil engineering, survey, planning and consulting firm 

founded and headquartered in Omaha, Nebraska in 1959. We offer design, planning, survey, construction

management, Landscape Architecture and GIS services for a variety of projects including land development, 

aviation, roadway, and water and sewer systems. In addition to our Omaha office, we have branch offices 

in Kansas City, MO, Fort Collins, CO, and Lakewood, CO. Through these offices, we offer additional expertise 

in oil and gas, waste water and water, water rights, and aquatics. 

2. Proposed Applications 

Lamp Rynearson will employ several UAS (described in Section 3) for Aerial Survey, Aerial Mapping, 

Aerial Videography and Photography, Asset Inventory and Management, Construction Site Monitoring and 

Inspections, Energy Systems Inspections, Industrial Inspections, Telecommunications Inspections, Pipeline 

Inspections, Utility Inspections, Precision Agricultural Services, UAS Education and Training, and Disaster 

Response/Damage Assessment operations. The UAS will be operated at altitudes below 400’ AGL, and at 

safe speeds with within the capabilities of the UAS for the purpose of collecting high quality aerial data, both 
2 

at nadir and oblique angles. These data will allow Lamp Rynearson to generate 2D and 3D photographs, 

orthorectified mosaics, HD video, 3D digital terrain and surface models, vegetative index maps, marketing 

videos and infrastructure inspection data. 

3. UAS Descriptions 

 Lamp Rynearson requests authorization to employ a combination of UAS platforms for our 

operations. These platforms will include the DJI Phantom 3 Professional, DJI Inspire 1, 3DR X8-M, 3DR X8+, 

and 3DR Solo multicopters and the 3DR Aero-M fixed wing. The multicopters will be used for small scale 

surveys, mapping and inspections, as well as for educational and training exercises. The fixed wing UAS will 

be used for large-scale surveys, inspections, mapping projects and training exercises. Below are descriptions 

and operational characteristics of each UAS. 

a. DJI Phantom 3 Professional 

DJI Phantom 3 Professional 

Weight 2.8 lbs 

Maximum Asscent Speed 5 m/s 

Maximum Descent Speed 3 m/s 

Maximum Horizontal Speed 31 knots (36 mph) 

Typical Flight Time 23 minutes 

Dimensions 15.35 in x 11.4 in x 7.25 in 

Aircraft Battery Lithium polymer 4S 4480 mAh 15.2 V

Remote Control Operating Frequency 2.4 GHz 

Remote Control Range 1.2 miles (2 km) 

Remote Control Battery Lithium polymer 2S 6000 mAh 

Previously Approved Exemptions 11925, 11976 

The DJI Phantom 3 Professional is a battery powered, GPS enabled, four rotor multicopter UAS. The 

Phantom can be controlled autonomously through a preprogrammed flight plan via a ground control station 

or manually by the PIC using a handheld transmitter/control. The UAS employs several safety features to 

facilitate safe integration into the NAS. The ground control software incorporates “Flight Restriction” which 

restrict operations in controlled airspace. These flight restriction areas have different levels of notification, 

from warnings on the Ground Control Station, to altitude restrictions and finally not allowing the start of the 

motors. 

The Phantom 3 has three failsafe emergency procedures: In the event the communication link with 

the operator’s ground control station is lost, the UAS will enter a Return To Home (RTH) mode after three 

seconds of transmission loss. 

In the event of a low battery, the low battery emergency procedure is triggered when the battery is 

depleted to a point that may affect the safe return of the aircraft; the PIC will land as soon as possible. The 

thresholds for these warnings are automatically determined based on the current aircraft altitude and its 

distance from the launch point. 

A loss of GPS while in guidance mode will cause the aircraft to hover using the onboard altimeter. 

This will instruct the PIC to land the aircraft as soon as possible. Additionally, the aircraft utilizes an “optical 

flow” sensor that uses ultrasonic and image data to help the aircraft identify its position. This allows for the 

aircraft to hover when GPS is lost. 
3 

b. DJI Inspire 1 

DJI Inspire 1 

Weight 6.5 lbs 

Maximum Asscent Speed 5 m/s 

Maximum Descent Speed 4 m/s 

Maximum Horizontal Speed 43 knots(49 mph) 

Typical Flight Time 18 minutes 

Dimensions 17.25 in x 17.75 in x 11.85 in 

Aircraft Battery Lithium polymer 6S 4500 mAh 22.2 V

Remote Control Operating Frequency 2.4 GHz 

Remote Control Range 3.1 miles (5 km) 

Remote Control Battery Lithium polymer 2S 6000 mAh 

Previously Approved Exemptions 11976, 11969 

The DJI Inspire 1 is a battery powered, GPS enabled, four rotor multicopter UAS that is capable of 

transmitting live airborne video images and location information to a Ground Control Station (GCS). The 

Inspire can be controlled autonomously through a preprogrammed flight plan via the GCS or manually by 

the PIC using a handheld transmitter/control. The DJI inspire 1 employs several safety features to facilitate 

safe integration into the NAS. The Inspire GCS software incorporates “Flight Restriction” areas around all B, 

C, and D airports. These flight restriction areas have different levels of notification, from warnings on the 

Ground Control Station, to altitude restrictions and finally disabling the start of the motors. 

 The Inspire has three failsafe emergency procedures: In the event the communication link with the 

operator’s ground control station is lost, the Inspire enters Return To Home (RTH) mode after three seconds 

of transmission loss. 

In the event of a low battery, the low battery emergency procedure is triggered when the DJI smart 

battery is depleted to a point that may affect the safe return of the aircraft; the PIC will Land as Soon as 

Possible. The thresholds for these warnings are automatically determined based on the current aircraft

altitude and its distance from the Home point. 

A loss of GPS while in guidance mode will cause the aircraft to hover using the onboard altimeter. This 

will instruct the PIC to land the aircraft as soon as possible. Additionally, the aircraft utilizes an “optical flow” 

sensor that uses ultrasonic and image data to help the aircraft identify its position. This allows for the aircraft 

to hover when GPS is lost. 
4 

c. 3DR X8+ 

3DR X8+ 

Weight 7.7 lbs 

Maximum Asscent Speed Undetermined by Manufacturer 

Maximum Descent Speed Undetermined by Manufacturer 

Maximum Horizontal Speed 35 knots (40 mph) 

Typical Flight Time 14 minutes 

Dimensions 13.7 in x 20.1 in x 11.8 in 

Aircraft Battery Lithium polymer 4S 10000 mAh 10C 

Remote Control Operating Frequency 915 MHz 

Remote Control Range 0.6 miles (1 km) 

Remote Control Battery 8-AA Batteries 

Previously Approved Exemptions 12646, 13643 

The 3DR X8+ is a battery powered, GPS enabled, eight rotor multicopter. The 3DR X8+ can be 

controlled autonomously through a preprogrammed flight plan via a ground control station or manually by 

the PIC using a handheld transmitter/control. The 3DR X8+ utilizes a fully redundant propulsion system that 

provides increased reliability. The X8+ depends upon GPS to determine its horizontal position, and a 

barometer in the onboard autopilot to determine its vertical position. The 3DR X8+ Aircraft has a Return to 

Home (RTH) feature that can be manually activated in the event of an inflight abnormality or emergency or 

automatically in the event of a lost Communications Signal or if the remaining battery life reaches a preprogrammed minimum level. Also, the RTH feature can be automatically activated if a pre-defined vertical 

and horizontal limit is breached. Additionally, if for some reason the aircraft battery cannot support the RTH 

feature, the aircraft can safely land at its current location. Via a graphical interface on the remote control 

and the Ground Control Station the PIC can monitor the number of GPS satellites acquired and the GPS 

signal strength, remote control signal strength, altitude, horizontal speed, the distance of the aircraft from 

the remote control, remaining life of the remote control and aircraft batteries, and total flight time, at all 

times during a flight. 

d. 3DR X8-M 

3DR X8-M 

Weight 7.7 lbs 

Maximum Asscent Speed Undetermined by Manufacturer 

Maximum Descent Speed Undetermined by Manufacturer 

Maximum Horizontal Speed 35 knots (40 mph) 

Typical Flight Time 14 minutes 

Dimensions 13.7 in x 20.1 in x 11.8 in 

Aircraft Battery Lithium polymer 4S 10000 mAh 10C 

Remote Control Operating Frequency 915 MHz 

Remote Control Range 0.6 miles (1 km) 

Remote Control Battery 8-AA Batteries 

Previously Approved Exemptions 11626, 13592 
5 

The 3DR X8-M is essentially the same platform as the 3DR X8+ with the addition of a high resolution 

camera integrated with the automatic flight control. This allows the user to program waypoints into the 

flight plan in order to acquire images at each location automatically. Just like the X8+, it is a battery powered, 

GPS enabled, eight rotor multicopter. The 3DR X8-M can be controlled autonomously through a 

preprogrammed flight plan via a ground control station or manually by the PIC using a handheld 

transmitter/control. It utilizes a fully redundant propulsion system that provides increased reliability. It 

depends upon GPS to determine its horizontal position, and a barometer in the onboard autopilot to 

determine its vertical position. 

The 3DR X8-M has a Return to Home (RTH) feature that can be manually activated in the event of 

an in-flight abnormality or emergency or automatically in the event of a lost Communications Signal or if the 

remaining battery life reaches a pre-programmed minimum level. Also, the RTH feature can be automatically 

activated if a pre-defined vertical and horizontal limit is breached. Additionally, if for some reason the 

aircraft battery cannot support the RTH feature, the aircraft can safely land at its current location. Via a 

graphical interface on the remote control and the Ground Control Station the PIC can monitor the number 

of GPS satellites acquired and the GPS signal strength, remote control signal strength, altitude, horizontal 

speed, the distance of the aircraft from the remote control, remaining life of the remote control and aircraft 

batteries, and total flight time, at all times during a flight. 

e. 3DR Aero-M 

3DR Aero-M 

Weight 6.8 lbs 

Maximum Asscent Speed Undetermined by Manufacturer 

Maximum Descent Speed Undetermined by Manufacturer 

Maximum Horizontal Speed 49 knots (56 mph) 

Typical Flight Time 40 minutes 

Dimensions 74 in (188 cm) wingspan, 51 in (129 cm) length 

Aircraft Battery Lithium polymer 4S 6000 mAh 35C 

Remote Control Operating Frequency 915 MHz 

Remote Control Range 0.6 miles (1 km) 

Remote Control Battery 8-AA Batteries 

Previously Approved Exemptions 11626, 13592 

The 3DR Aero-M is a battery powered, GPS enabled, single rotor fixed wing UAS. The 3DR Aero-M 

can be controlled autonomously through a preprogrammed flight plan via a ground control station or 

manually by the PIC using a handheld transmitter/control. The 3D Robotics Aero-M system can carry 

payloads up to 1.1 lbs. It operates with a maximum wind threshold of 25 mph. The system contains two full 

Inertial Measurement Unit (IMU) sensor suites, one acts as the primary flight sensor and the other used as 

a comparison for monitoring IMU health and full failover functionality, if it becomes necessary. The system 

also contains two barometer sensors. This eliminates the difficult portion of flying. The pilot- in-command 

(PIC) has the ability to control the speed, roll, yaw and pitch of the aircraft. 

An autonomous operations, or “Auto,” mode is available through available pre-programmed flight 

plans, which must be uploaded to the aircraft prior to take-off using the 3D Robotics Mission Planner 

software application. The PIC may set the Aero-M to either an automatic takeoff or manual takeoff setting. 

After departing the ground, the aircraft initiates the preprogramed flight. At any time during the 

programmed flight, the PIC can provide inputs to abort and/or override the programmed flight to take 
6 

immediate control of the Aero-M. For pre- programmed flight, the PIC may utilize additional navigation

settings, including landing zones and flight area (including visual no-fly zones, maximum altitude, and 

minimum altitude), so that the Aero-M operates only within operator-specified flight parameters. . 

f. 3DR Solo 

3DR Solo 

Weight 3.9 lbs 

Maximum Asscent Speed 10 m/s in stabilize mode; 5 m/s in “fly” mode 

Maximum Descent Speed 10 m/s in stabilize mode; 5 m/s in “fly” mode 

Maximum Horizontal Speed 48 knots (55 mph) 

Typical Flight Time 20 minutes 

Dimensions 10 in. tall (25 cm), 18 in. (46 cm) motor-to-motor 

Aircraft Battery Lithium polymer 5200 mAh 14.8 Vdc 

Remote Control Operating Frequency 2.4 GHz 

Remote Control Range 1.2 miles (2 km) 

Remote Control Battery 2600 mAh 7.2 Vdc rechargeable lithium ion 

Previously Approved Exemptions 11935, 13586 

The 3DR Solo is a battery powered, GPS enabled, four rotor multicopter. The 3DR Solo can be 

controlled autonomously through a preprogrammed flight plan via a ground control station or manually by 

the PIC using a handheld transmitter/control. The 3D Robotics Solo utilizes GPS data to determine its 

horizontal position and altitude. It has a Return to Home (RTH) feature that can be manually activated in the 

event of a detected abnormality or emergency or automatically in the event of a lost Communications Signal 

or if the remaining battery reaches a minimum level. 

Additionally, if for some reason the aircraft battery cannot support the RTH feature, the aircraft can

safely land at its current location. The RTH feature, when activated, commands the UAS to an altitude of 98' 

and returns to its home point. Via a Graphical In Flight Control System the GPS signal strength, remote 

control signal strength, altitude, vertical & horizontal speed, the distance of the aircraft from the remote 

control, remaining life of the remote control and aircraft batteries, and remaining flight time, can be 

monitored by the Pilot in Command (PIC) at any time during a flight. 

4. Public Interest and Benefits 

By employing UAS for Lamp Rynearson’s operations, the potential risk of serious accidents and 

injuries associated with manned rotary and fixed wing aircraft weighing thousands of pounds, will be greatly 

reduced and/or eliminated. In addition to weight, the type of manned aircraft typically used to capture the 

high resolution photography and video described herein are capable of carrying 100 or more gallons of fuel 

which creates the potential risk of spillage and fire in the event of an incident or accident, emit emissions 

harmful to the environment, and require an onboard pilot and additional crew members to operate the 

photographic and video equipment. Due to the fact that the UAS employed by Lamp Rynearson weigh less 

than 10 pounds fully loaded, carry no fuel, emit no harmful emissions, the pilot and crew are remotely

located from the aircraft, and the UAS are operated over controlled access sites/properties, a significant 

public benefit is achieved. 

Additionally, by employing UAS at altitudes well below and at speeds far less than manned aircraft, 

Lamp Rynearson will provide the Agriculture, Architecture, Civil Engineering, Construction, Real Estate, and 
7 

Building Inspection Industries; with data and imagery that possess a superior level of detail and precision 

that is impossible to acquire with manned flights or satellite imagery. And because Lamp Rynearson will 

incorporate these systems into many of our contracts with public agencies, these more efficient operations 

will translate to lower project costs, increased savings and a better product for the agencies, and ultimately 

the taxpayers. Considering these points, we feel that the issuance of the proposed exemptions are in the 

public interest. 

5. Lamp Rynearson & Associate’s UAS Operations Manual 

Lamp Rynearson shall review and update this UAS Operations Manual at least annually, or more 

frequently if necessary, to insure that the information contained herein is current, relevant to UAS 

operations, and to insure that it accurately reflects updated FAA requirements for Civil UAS operations. 

a. Safety

Safety is the main priority of Lamp Rynearson. To achieve the safest possible environment 

regarding Civil UAS operations, Lamp Rynearson’s UAS Operations Manual and the UAS 

Operations, Maintenance, and Safety Manuals shall be followed. 

Monthly safety meetings shall be conducted and documented to insure strict adherence to Lamp 

Rynearson’s UAS Operations Manual. 

A Pilot In Command (PIC) and a Visual Observer (VO) shall be utilized during every flight (training 

and mission flights). The VO shall maintain direct Visual Line of Sight (VLOS) at all times during a 

flight. The VO and PIC shall remain in verbal contact at all times during a flight. The VO shall only 

perform see and avoid duties for the purpose of identifying ground based and aerial obstacles 

and potential hazards including but not limited to other UAS and Manned Aircraft. 

The PIC and VO shall monitor weather conditions prior to and during every flight. If adverse 

weather conditions are predicted or observed, including but not limited to winds greater that the 

capabilities of the aircraft, rain, low or ominous clouds, lightning, and thunder, the flight shall be

aborted. 

Phone calls, electronic messaging, and texting shall not be permitted at any time during flight 

operations. 

To insure the safest possible environment during a flight, all nonparticipating personnel, shall 

remain at least 500 feet from the UAS unless a protective shelter has been established prior to 

the flight. 

UAS shall not be operated within 500 feet of property, or structures unless written permission 

has been granted by the owner and such operations do not create a potential safety hazard. 

All flights shall be conducted during daytime hours only, under Visual Meteorological 

Conditions (VMC). 
8 

UAS shall not be operated over crowds or congested areas. 

All UAS related incidents and/or accidents shall be immediately documented and reported 

to the FAA's UAS Integration Office within 24 hours. Accidents shall be reported to the 

National Transportation Safety Board (NTSB). 

b. Training 

Training sessions shall be conducted as needed, but no less than bi-annually, for the purpose of 

flight training, proficiency, experience building, and to review safety issues. 

Prior to being designated as a PIC for an official mission flight, the PIC must document at least 20 

hours piloting a UAS of similar configuration. The PIC shall also successfully complete a basic test 

of skills that involves at a minimum take offs and landings, hovering, evasive & emergency 

maneuvers, mock mission flights, and ground control operations. 

Prior to acting as a VO for an official mission flight, the VO must document at least 10 hours 

training to become fully aware of the responsibilities of seeing and avoiding for the purpose of 

identifying ground based and aerial obstacles and potential hazards including but not limited 

to other UAS and Manned Aircraft.

c. Flight Planning

Prior to each flight, the PIC and VO will visually survey the site/property being flown to identify 

site/property boundaries and ground based obstacles and potential hazards that may affect the 

aircraft during flight. They will also determine the safest location from which to launch the 

aircraft as well as the best vantage point from which to maintain a VLOS of the aircraft at all times 

during the flight. The location of a shelter for non-participating personnel, if needed, shall also 

be determined at this time. 

Operations shall be conducted over public, private, or limited access property only. Prior to each 

flight, Lamp Rynearson shall obtain written permission from the site/property owner authorizing 

the UAS operations over the site/property and to capture high resolution photographs and video 

of the site/property and any structures thereon. Lamp Rynearson shall strictly adhere to all privacy 

laws of the State and/or local jurisdiction in which UAS operations are conducted. 

Prior to each flight, a PIC shall be designated. That designation shall not be transferred for the 

duration of the flight. 

Prior to each flight, the PIC, VO, and other necessary participants will review and discuss the 

details and parameters of the flight to insure that all participants have a firm understanding of 

the flight objectives. 

Prior to each flight, the PIC shall determine and document the altitude of the launch site and 

calculate the maximum flight altitude allowable to remaining within 400 feet AGL during the 

flight. 
9 

Prior to each flight, the PIC shall ensure that the UAS has been programmed to automatically RTH 

if the remaining battery life reaches a minimum level of 25%. 

d. Preflight Inspections

Prior to each flight, the PIC shall inspect the UAS being flown to ensure it is safe for flight. In the 

event, any condition, including but not limited to, inoperable components, items, or equipment, 

are discovered that would affect the safe operation of the UAS, the flight shall be aborted until 

the necessary corrective maintenance has be performed and a follow up inspection has been 

completed. An inspection of the Ground Control Station shall be included in the preflight 

inspection. Additional inspections shall be conducted as prescribed by the Manufacturer. 

The UAS and Remote Control Batteries shall be inspected for defects and to insure they have a 

charge sufficient to complete the mission flight with at least 25% battery life remaining. 

The PIC shall verify that an adequate GPS signal is obtained per the Manufacturer's User Manual 

prior to launching the UAS. 

The PIC shall ensure that the remote control antenna and range extender is properly 

configured so to achieve the best possible communication link between the remote control, 

Ground Control Station, and the UAS. The Remote Control, Ground Control Station, and UAS 

connection shall be tested to ensure proper functionality. 

e. Flight Procedures

A copy of the Lamp Rynearson UAS Operations Manual and the UAS Manufacturer's User, 

Safety, and Maintenance Manuals shall be maintained with the Ground Control Station at all 

times during a flight. 

UAS shall be operated at an altitude of no more than 400 feet AGL. 

The UAS shall not exceed either the FAA defined maximum speed (87 knots) nor the maximum 

speed recommended by the manufacturer of the aircraft. 

UAS shall not be operated within 5 nautical miles of an airport unless a written agreement is 

obtained from the airport's manager. In the event a flight is conducted within 5 miles of an 

airport, a Notice to Airman (NOTAM) must be issued.

UAS shall be operated within visual line of site (VLOS) of the PIC and VO at all times. The PIC 

and VO must be able to communicate verbally at all times. 

UAS shall not be operated when visibility is less than 3 miles from the PIC. 

UAS shall not be operated less than 500 feet below or within 2000 feet horizontally from a 

cloud. 
10 

The PIC shall stay clear of and always yield the right-of-way to other UAS and manned aircraft. 

The PIC shall manually activate the UAS's RTH feature in the event of any detected 

abnormality or emergency. 

During a flight, the PIC shall monitor at a minimum the UAS's altitude, horizontal speed, distance 

of the aircraft from the remote control, and remaining battery life; and the remaining life of the 

remote control. 

During all programmed autonomous flights, the PIC shall maintain Visual Line of Site of the UAS 

and monitor the UAS controls. The PIC shall assume full manual control of the aircraft in the event 

of any detected abnormality or emergency and activate the RTH feature. 

f. Maintenance

Routine and preventive maintenance, overhaul, and replacement shall be performed on each 

UAS as specified in the Manufacturer's Maintenance Manual. The Maintenance Manual for each 

UAS shall be maintained with the Ground Control Station at all times during a flight. 

Corrective maintenance for any condition, including but not limited to, inoperable 

components, items, or equipment, that are discovered during a pre-flight inspection shall be 

completed according to the Manufacturer's recommendation. 

UAS that have undergone any maintenance or alterations that affect critical flight components 

shall undergo a functional test flight prior to being placed back into service. 

g. Record Keeping

An aircraft maintenance record shall be kept up to date for each UAS operated by Lamp 

Rynearson. 

Routine and preventive maintenance shall be recorded in the aircraft record for each UAS 

operated by Lamp Rynearson. 

Repair or corrective maintenance shall be recorded in the aircraft record for each UAS operated 

by Lamp Rynearson. 

A record shall be created and maintained for each flight that shall include at a minimum the PIC's 

and VO's names, the flight location, time of day, atmospheric conditions at the time of the flight, 

the UAS flown, the duration of the flight, and purpose of the flight. 

The original agreement granting access to the site/property must be made a part of each 

flight record. 

Training records shall be maintained for each PIC and VO that includes at a minimum, name, 

date, time of day, total training time, location of training, and training type. 
11 

6. Requested Exemptions and Equivalent Level of Safety 

14 CFR Part 21, Subpart H: Airworthiness Certificates 

This section establishes the procedural requirements for the issuance of airworthiness 

certificates and other airworthiness approvals. Given the size, weight, speed, and limited operating area 

associated with the UAS to be utilized by Lamp Rynearson, an exemption from 14 CFR Part 21, Subpart 

H (Airworthiness Certificates), subject to certain conditions and limitations, is warranted, and meets the 

requirements for an equivalent level of safety under 14 CFR Part 11 and § 333 of the Reform Act. 49 USC 

§ 44701(f) and § 333 of the Reform Act both authorize the FAA to exempt aircraft, including UAS, from 

the requirement for an airworthiness certificate upon consideration of the size, weight, speed, 

operational capabilities, proximity to airports and populated areas, and operation within visual line of 

sight. The UAS operated without an airworthiness certificate in the restricted environment and under 

the conditions and limitations proposed by Lamp Rynearson will be at least as safe, or safer, than a 

conventional aircraft (fixed wing or rotorcraft) operating with an airworthiness certificate issued under 

14 CFR Part 21, Subpart H, and not subject to the proposed limitations and conditions. 

The UAS to be operated by Lamp Rynearson all weigh much less than 55 lbs. fully loaded, will be 

operated at a speed of no more than 50 knots, will carry neither a pilot nor passengers, will carry no

explosive or flammable materials or fuel, and will be operated exclusively in predetermined, controlledaccess environments. Lamp Rynearson’s UAS will use a radio frequency spectrum for operation and 

control that complies with Federal Communications Commission (FCC) requirements, and will be 

operated only in accordance with the procedures proposed herein and as may be established by the FAA. 

Lamp Rynearson’s UAS will be equipped with redundant safety mechanisms allowing safe 

operation after experiencing certain in-flight failures. If a lost-link event occurs, including loss of ground 

communications or loss of GPS signal, Lamp Rynearson’s UAS will have the ability to perform a precoordinated, predictable, automated flight maneuver and return to a predetermined location within a 

designated security perimeter for landing. 

Unlike operations of other civil aircraft, operations under the requested exemptions will be 

tightly controlled and monitored by both the pilot in command (PIC) and a Visual Observer (VO) in order 

to ensure Lamp Rynearson’s UAS remain within operational limitations and to ensure the safety of 

operations. These enhancements to current safety practices and regulations provide a greater degree of

safety to the public and property owners than conventional aircraft operations conducted by aircraft 

with an airworthiness certificate. Lastly, there is no intrinsic credible threat to national security posed by 

UAS due to the size, speed, restricted operational environments, lack of explosive materials and 

flammable fuels or other liquids, and inability to carry passengers or a substantial external load. 

14 CFR § 45.23(b): Display of Marks 

This section requires that “[w]hen 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.” 

Even though Lamp Rynearson’s UAS will have no airworthiness certificate, an exemption may be 
12 

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

“experimental,” etc., can be placed. Also, given the size of Lamp Rynearson’s UAS, two-inch lettering will 

be impossible. Lamp Rynearson understands the need for markings and will mark all of its UAS in the 

largest possible lettering on the UAS fuselages so that anyone observing Lamp Rynearson’s UAS will be 

able to see the markings. 

14 CFR § 61.113(a) & (b): Private Pilot Privileges and Limitations: Pilot in Command (PIC) and 14 CFR § 

61.315(a) & (c): Sport Pilot Privileges and Limitations 

 

These sections limit private pilots and sport pilots to non-commercial operations. Because Lamp 

Rynearson’s UAS will not carry a pilot or passengers, the proposed operations can achieve the equivalent 

level of safety of current operations by requiring the PIC operating Lamp Rynearson’s UAS to have a 

private pilot’s or sport pilot’s license rather than a commercial pilot’s license to operate Lamp 

Rynearson’s small UAS. Unlike a conventional aircraft that carries the pilot and passengers, Lamp 

Rynearson’s UAS are remotely controlled with no persons onboard. The area of operation will be 

controlled and restricted, and all flights will be planned and coordinated in advance. The risks associated 

with the operation of Lamp Rynearson’s UAS are so diminished from the level of risk associated with 

commercial operations contemplated by 14 CFR Part 61 when drafted, that allowing operations of Lamp 

Rynearson’s UAS as requested with a private pilot or sport pilot as the PIC exceeds the present level of 

safety achieved by 14 CFR §§ 61.113(a) & (b) and 61.315(a) & (c). 

14 CFR § 91.7(a): Civil Aircraft Airworthiness 

This section prohibits any person from operating a civil aircraft unless it is in an airworthy 

condition. As there will be no airworthiness certificate issued for Lamp Rynearson’s UAS, should this 

exemption be granted, no FAA regulatory standard will exist for determining airworthiness. Given the 

size of the aircraft and the requirements contained in the UAS manufacturer’s manuals and use of safety 

checklists prior to each flight, an equivalent level of safety will be provided. In accordance with the 

pertinent part of 14 CFR § 91.7(b), the PIC for all of Lamp Rynearson’s UAS operations shall be responsible 

for determining whether the aircraft is in a safe condition for flight, including the use of pre-flight safety 

checklists. 

14 CFR § 91.9(b)(2): Civil Aircraft Flight Manual, Marking, and Placard Requirements 

This sections provides in pertinent part that “[n]o person may operate a U.S.-registered civil 

aircraft ... 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.” Lamp Rynearson’s UAS, given 

their size and configuration, have no ability to carry a physical flight manual on the aircraft. The 

equivalent level of safety will be maintained by keeping the flight manual at the ground control point

where the PIC operating Lamp Rynearson’s UAS will have immediate access to it. 

14 CFR § 91.103(b)(1): Preflight Action 

This regulation requires each PIC to take certain actions before flight to insure the safety of each 
13 

flight. As FAA approved flight manuals will not be provided for the aircraft, an exemption will be needed. 

Lamp Rynearson will comply with the other applicable procedures and requirements stated in § 

91.103(a) & (b). Specifically, the PIC will take all action including reviewing weather, flight battery 

requirements, aircraft performance data, and landing and takeoff distances before initiating a flight. The 

PIC will also account for all relevant site-specific conditions in their preflight procedures. Risks presented 

by sun glare will be mitigated by the PIC’s and VO’s ability to see other air traffic and initiate a return-tohome sequence if needed. 

14 CFR § 91.109(a): Flight Instruction 

This section 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.” UAS, by their design, do not have functional dual controls. Flight control is accomplished 

through the use of a control box that communicates with the aircraft via radio communications. Given 

the size and speed of Lamp Rynearson’s UAS, an equivalent level of safe training can be achieved without 

dual controls because no pilot or passengers are aboard the UAS and all persons will be a safe distance 

away in the event that the UAS experiences any difficulties during flight instruction. 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 e.g. Exemptions Nos. 5778K and 9862A. 

14 CFR § 91.119: Minimum Safe Altitudes 

This section establishes minimum safe altitudes for operation of civil aircraft and provides that, 

over other than congested areas, no person may operate an aircraft below an altitude of 500 AGL, except 

over open water or sparsely populated areas, and that over sparely populated areas the aircraft cannot

be operated closer than 500 feet to any person, vessel, or structure. As this exemption requests authority 

to operate at altitudes no higher than 400 feet AGL, an exemption may be needed to allow such 

operations. 

As set forth herein, Lamp Rynearson’s UAS will never operate at higher than 400 feet AGL, nor 

beyond visual line of sight (VLOS) of the PIC and VO, whichever is closer. It will, however, be operated 

in a restricted area with individuals tasked with ensuring public safety, and where buildings and people 

will not be exposed to operations without their pre-obtained consent and training. 

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

Rynearson’s UAS as well as the restricted environments within which they will be operated. No flight will 

be taken without the permission of the property owner. Because of the advance notice to the property 

owner and the participants in the UAS operation, all affected individuals will be aware of the planned

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

than Lamp Rynearson’s UAS and the lack of flammable fuels onboard, any risk associated with Lamp 

Rynearson’s operations is far less than that presently presented by conventional aircraft operating at or 

below 500 feet AGL. In addition, the low-altitude operations of Lamp Rynearson’s UAS will ensure 

separation between Lamp Rynearson’s UAS operations and the operations of conventional aircraft that 

must comply with § 91.119. Furthermore, Lamp Rynearson’s UAS will not be operated over congested 

areas nor over any open-air assembly of persons. Lamp Rynearson’s UAS will be operated at an altitude 

allowing, if a power unit fails, an emergency landing without undue hazard to persons or property on the 
14 

surface. 

14 CFR § 91.121: Altimeter Settings 

In pertinent part, this section 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 Lamp Rynearson’s UAS may not have a 

barometric altimeter, but instead a GPS altitude readout, an exemption may be needed. An equivalent 

level of safety will be achieved by the PIC confirming the altitude of the launch site shown on the GPS 

altitude indicator, and prior to each flight, a zero altitude initiation point will be established and

confirmed for accuracy by the PIC. The PIC will also ensure effective pairing with multiple GPS sources to 

guarantee accurate detection of altitude. 

14 CFR § 91.151(a): Fuel Requirements for Flight in VFR Conditions 

This section prohibits a person 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.” 

Given the limited area of operation of Lamp Rynearson’s UAS, Lamp Rynearson believes that an 

equivalent level of safety is already achieved by the various failsafe procedures built in to Lamp 

Rynearson’s UAS that will perform a RTH maneuver or automatically land the aircraft in the case of a low 

battery while in flight. Operating Lamp Rynearson’s UAS in a tightly controlled area where only people or 

property owners or official representatives who have signed waivers will be allowed, with less than 30

minutes of reserve power, does not engender the type of dangers that § 91.151(a) was intended to 

alleviate given the size and speed of Lamp Rynearson’s UAS. Lamp Rynearson believes that an equivalent

level of safety can be achieved by prohibiting Lamp Rynearson’s PIC from beginning any flights unless,

considering the wind and forecast weather conditions, there is enough available power for Lamp 

Rynearson’s UAS to conduct the intended operation and to operate after that for at least five minutes 

or with the reserve power recommended by the manufacturer, whichever is greater. This restriction 

would be more than adequate to return Lamp Rynearson’s UAS to its planned landing zone from 

anywhere in its limited operating area. FAA has granted similar exemptions in, for example, Exemption 

Nos. 2689F, 5745, 10673, 10808, 11864, and 11769. 

14 CFR § 91.203(a) & (b): Civil Aircraft: Certifications Required 

This regulation provides in pertinent part that “(a)...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 

... is displayed at the cabin or cockpit entrance so that it is legible to passengers or crew.” 

Lamp Rynearson’s UAS fully loaded weigh less than 55 pounds and are operated without a pilot, 

passengers, or crew onboard. As such, there is no is ability or place to carry certification and registration 

documents or to display them on Lamp Rynearson’s UAS. An equivalent level of safety will be achieved 

by keeping these documents at the ground control station where the PIC will have immediate access to 
15 

them, to the extent they are applicable to Lamp Rynearson’s UAS. FAA has issued numerous exemptions 

to this section; see e.g. Exemption Nos. 9565, 9665, 9789, 9789A, 9797, and 10700. 

14 CFR §§ 91.405(a), 91.407(a)(1), 91.409(a)(1) & (2), and 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 Lamp Rynearson. Lamp Rynearson will strictly adhere to the safety and 

maintenance procedures included in all applicable UAS manufacturers’ instructions and operating 

manuals. To the extent such information is not included in the guidelines as developed by the 

manufacturers, Lamp Rynearson will undertake to develop and document maintenance, overhaul, 

replacement, and inspection requirements, and procedures to document and maintain maintenance 

records with regards to Lamp Rynearson’s UAS. An equivalent level of safety will be achieved because 

Lamp Rynearson’s UAS are very limited in size and will carry small payloads and operate only in restricted 

areas for limited periods of time. If mechanical issues arise, Lamp Rynearson’s UAS can land immediately 

and will be operating from no higher than 400 AGL. Lamp Rynearson will ensure that its UAS are in 

working order prior to initiating each flight, perform regular maintenance, and keep a log of any 

maintenance performed. Moreover, Lamp Rynearson is most familiar with the aircraft and is best suited 

to maintain the aircraft in an airworthy condition in order to ensure safe operations. 

7. Support Documentation 

 

Submitted with this petition, as separate documents, are the manufacturers’ User and 

Maintenance Manuals for each of the UASs listed in Section 3. 

8. Summary for Publication 

Lamp Rynearson & Associates, Inc 

14710 West Dodge Road, Ste 100 

Omaha, NE, 68116 

402-496-2498 

mark.steele@lra-inc.com

Petition for Exemption under Section 333 of the FAA Reform Act and Part 11 of the Federal Aviation 

Regulations from 14 CFR Part 21; 14 CFR § 45.23(b); 14 CFR § 61.113(a) & (b); 14 CFR § 61.315(a) & (c); 14 

CFR § 91.7(a); 14 CFR § 91.9(b)(2); 14 CFR § 91.103(b)(1); 14 CFR § 91.109(a); 14 CFR § 91.119; 14 CFR § 

91.121; 14 CFR § 91.151(a); 14 CFR § 91.203; 14 CFR § 91.405(a); 14 CFR § 91.407(a)(1); 14 CFR § 

1.409(a)(2); 14 CFR § 91.417(a) & (b)