2517 Sayles Place S.E. Unit 11 

Washington, D.C. 20020 

(888) 618-9124 

Website: craftandtheoryllc.com 

Email: info@craftandtheoryllc.com 

U.S. Department of Transportation 

Docket Management System 

1200 New Jersey Avenue, SE 

Washington, DC 20590 

October 26, 2015 

Re: Exemption Request Under Section 333 of the FAA Modernization and Reform Act of 

2012 and 14 C.P.R. Part 11 

Attn: To whom it may concern 

Pursuant to Section 333 of the FAA Modernization and Reform Act of2012 and 14 

C.F.R. Part 11, Craft and Theory, LLC, ("C&T") an operator ofUnmanned Aircraft 

Systems ("UAS") hereby applies for an exemption from the listed Federal Aviation 

Regulations ("F ARs") to allow commercial operation of its UAS. C&T is eligible for a 

summary exemption for aerial data collection. Specifically, C&T's UAS would be 

operated for the purpose of conducting aerial acquisitions and research, videography, 

gathering of agricultural data, natural resources, conservation, construction, infrastructure 

management and inspections, monitoring assessments, search and rescue operations, and 

reconnaissance in support of disaster or emergency situations. 

• Types of aircraft to be flown: 

o DJI Phantom 2 and 3 series 

o DJI Inspire 1 

o DJI Spreading Wings Series: S800, S900, S1000 

o DJI Matrice 100 

o Yuneec Q500 

o 3DR IRIS+ 

o 3DR Solo 

o Parrot Bebop 

o senseFly eXom 

The UAS listed above can provide the PIC with altitude, speed, battery life, and direction, 

among other flight parameters. The flight controllers of the aircraft listed above utilize 

GPS to limit the altitude above the ground and limit the radius of the distance it flies from 

the PIC. The flight controllers have failsafe functions (GPS, battery, RC controller) 

allowing the aircraft to return to the launch site automatically. 
Introduction and Public Interests 

C&T is a full service engineering company specialized in customer-centric solutions. 

C&T' s current thrust is in the development and testing of technologies related to the 

automation ofUAS flight, with a particular focus on onboard and off-board systems to 

enhance the UAS safety of flight. As such, C&T needs to operate in a variety of 

operational scenarios in order to validate the applicability of its systems on a large scale. 

C&T is well versed in the maintenance and operation of both off-the-shelf and custom 

designed UAS. 

C&T was a registered participant of the UAS Airspace Operations Challenge (one of the 

NASA Centennial Challenges). A purpose-built quadcopter platform was designed and 

tested in restricted airspace, and matched procedures for qualification required by an 

airworthiness audit conducted by AFRL and compliant with the airworthiness criteria for 

Air Force Group 1 and 2 (below 55lbs GTOW) UAS. 

C&T remains in contact with the UAS COE and the F ANDoD/NASA/DHS UAS 

Science and Research Panel (SARP) and plays a role in informing those entities about the 

technologies and capabilities available for safe operation ofUAS in the NAS. It is in the 

public's interest to have these FAA standard advising entities informed about the latest 

technological developments and tests performed on UAS. The SARP is specifically in 

need ofUAS flight data in representative use cases as to establish encounter models for 

UAS operating in the NAS. C&T, through its own operations, is in a position to provide 

such data to the SARP. 

C&T is also advancing technology initiatives related to near-obstacle detection sensors 

and automatic obstacle avoidance algorithms which would greatly enhance the UAS 

safety of flight during low altitude and landing phases. Near-obstacle detection sensors 

must inherently be flown close to the ground and other obstacles, therefore these flight 

tests would be extremely risky and cumbersome if performed by a manned aircraft. 

Manned aircraft aerial data acquisition creates a greater risk because the aircraft are much 

larger, have combustible fuel, and carry an onboard human pilot. In contrast, UAS 

weighing 55 pounds or less and powered by batteries eliminates virtually all of that risk 

given the reduced mass and lack of combustible fuel carried on board. The UAS carry no 

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

manned aircraft flights. Use ofUAS reduces safety concerns when gathering data from 

inaccessible or unstable/unsafe areas. Operation ofUAS will substantially reduce the risk 

to life and property in the air, and on the ground, which is commonly associated with 

traditional manned aircraft flight operations or use of elevated work platforms (aka 

bucket lift, cherry-picker). 

The proposed exemption, if granted, would allow C&T to safely, efficiently, and 

economically conduct commercial operations ofUAS meeting or exceeding all of the 

operational and safety requirements Congress has set forth in Section 3 3 3. Statutory 

Authority Section 333, titled "Special Rules for Certain Unmanned Aircraft Systems", 
provides a mechanism for seeking expedited FAA authorization of safe civil UAS 

operations in the NAS. Section 333(a) states that the FAA "shall determine if certain 

unmanned aircraft systems may operate safely in the national airspace system before 

completion of the (comprehensive) plan and rulemaking required by section 332(b)(1) of 

this Act or the guidance required by section 334 of this Act." In Section 332(b)(1), 

Congress made it clear that Section 333 provides a mechanism for "expedited operation 

authorization" if several factors are met. Petitioner meets all requirements to permit FAA 

approval of commercial UAS operations. 

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

small and relatively inexpensive UAS under controlled conditions in airspace that is: (1) 

limited; (2) predetermined; (3) controlled as to access, and; (4) would provide an 

equivalent or increased level of safety beyond that existing when manned aircraft are 

used to accomplish the same purpose. Approval of this exemption would thereby enhance 

saf~ty and fulfill the Secretary of Transportation's responsibilities to" ... establish 

requirements for the safe operation of such aircraft systems in the national airspace 

system." 

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 and noise levels 

associated with allowing UAS operations, the grant of the requested exemptions is in the 

public interest. Accordingly, the applicant respectfully requests that the FAA grant the 

requested exemption without delay. 

14 CFR 11.81 (a)- Name and address of the Petitioner 

Craft and Theory, LLC 

2517 Sayles Place S.E. Unit 11 

Washington, D.C. 20020 

(888) 618-9124 

info@craftandtheoryllc.com 

14 CFR 11.81 (b)- Exemptions Requested 

C&T is requesting an exemption from certain parts of 14 CFR cited below in addition to 

such further exemptions and relief as the FAA may determine is necessary to permit the 

operations described herein. 

§21, Subpart H 

§61.23(a) and (c) 

§61.101(e)(4) and (5) 

§61.113(a) 

§61.315(a) 

§91.7(a) 

§91.119(c) 
§91.121 

§91.151(a)(1) 

§91.405(a) 

§91.407(a)(1) 

§91.409(a)(l) and (2) 

§91.417(a) and (b) 

14 CFR 11.81 (c)- The extent of relief sought, and the reason the relief is sought 

§21, Subpart H: Airworthiness Certification 

The size, weight and enclosed operational area of the proposed UAS meet (and exceed) 

an equivalent level of safety pursuant to Section 333 ofthe Reform Act. Therefore, no 

airworthiness certificate is required in accordance with 14 C.F .R. Part 21, Subpart H. 

§61.23(a_) and (c): Medical Certificates 

Exemption# 11221, # 11284, and many others have provided that a U.S. driver's license 

could be used in lieu of the medical certificate. 

§ 61.101(e)(4) & (5): Recreational Pilot Privileges and Limitations & § 

61.315(a): Sport Pilot Limitations 

Exemption# 11221, # 11284, and many others have declared that there is an equivalent 

level of safety as the F ARs by requiring the PIC to "hold either an airline transport, 

commercial, private, recreational, or sport pilot certificate." Likewise, C&T is also 

performing commercial UAS work and is asking for the same restrictions which have 

been previously deemed to provide an equivalent level of safety. 

§ 61.113 (a): Private Pilot Privileges and Limitations: Pilot in Command 

Because the UAS will not carry a pilot or passengers, the proposed operations can 

achieve the equivalent level of safety of current operations by requiring the PIC operating 

the aircraft to have a private pilot's license rather than a commercial pilot's license to 

operate this small UAS. Unlike a conventional aircraft that carries the pilot and 

passengers, the UAS is remotely controlled with no living thing on board. 

§ 91.7(a): Civil Aircraft Airworthiness 

As no such certificate will be applicable in the form contemplated by the F ARs, this 

Regulation is inapplicable. Given the size of the UAS and the previous exemptions issued 

for similar UAS, an equivalent level of safety will be achieved by ensuring compliance 

with the UAS operating procedures, manuals, and safety checklists prior to each flight. 

§ 91.119: Minimum Safe Altitudes 

Because of the lack of flammable fuel, any risk associated with these operations is far 

less than those presently presented with conventional aircraft operating at or below 500 

AGL. In addition, the low-altitude operations of the UAS will ensure separation between 

these small UAS operations and the operations of conventional aircraft that must comply 

with Section 91.119. 
§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 UAS may not have a 

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

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

manuals. 

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

The U AS will not begin a flight 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, to fly after that for at least 2 minutes. 

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

Maintenance Inspections 

An exemption from these maintenance requirements is warranted because the U A will 

not have an airworthiness certificate, and the FAA has not developed equivalent part 91 

maintenance requirements for UAS. More specifically, no individuals are authorized by 

the FAA to approve a UAS for return to service under 91.407(a) or to conduct initial 

airworthiness inspections. 

Conclusion 

C&T seeks an exemption pursuant to 14 C.F.R. and Section 333 of the FAA 

Modernization and Reform Act of2012, which will permit safe operation of its UAS 

commercially, without an airworthiness Certificate. Due to its size, weight, speed, limited 

operating area, and lack of cargo, fuel or combustible materials in general, C&T's UAS 

present no major risk to individuals, nor poses any threat to National Security, and 

alleviates the need for manned aircraft. By granting this Petition, the FAA Administrator 

will be fulfilling the Congressional mandate of the FAA Modernization and Reform Act 

of2012, while also advancing the interests of the public, by allowing C&T to safely, 

efficiently, and economically operate its UAS commercially within the NAS. 

Sincerely, 

Florent Martel 

Manager