BOSTON CONNECTICUT NEW JERSEY NEW YORK WASHINGTON, DC 

RICHARD H. BROWN

Attorney at Law

1 Jefferson Road

Parsippany, New Jersey 07054

T: (973) 966-8119 F: (973) 206-6129

rbrown@daypitney.com

Page 1 of 10 

 March 4, 2015 

U. S. Department of Transportation 

Docket Management System 

1200 New Jersey Ave., SE 

Washington, DC 20590 

Re: Exemption Request Section 333 of FAA Reform Act and Title 14, Code of Federal 

Regulations (14 CFR): §§ 61.113(a) and (b); 91.119; 91.121; 91.151(a); 91.405(a); 

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

Dear Sir or Madam: 

Pursuant to 14 CFR part 11 and Section 333 of the FAA Modernization and Reform Act of 2012 (“the 

Reform Act”), Principia, Inc. (referred to herein as “Applicant”), developer and operator of small 

Unmanned Aircraft Systems (“sUASs”) equipped to conduct aerial photography/filming operations for a 

range of business including insurance, real estate, agriculture, infrastructure inspection, and motion picture 

and television production, hereby applies for an exemption from the listed Federal Aviation Regulations 

(“FARs”) to allow commercial operation of its sUAS, so long as such operations are conducted within and 

under the conditions outlined herein or as may be established by the FAA as required by Section 333. 

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

controlled conditions in airspace that is 1) limited, 2) predetermined, 3) controlled as to access, and 4) 

would provide safety enhancements to the already safe businesses presently using conventional aircraft. 

Approval of this exemption would thereby enhance safety and fulfill the Secretary of Transportation’s (the 

FAA Administrator’s) responsibilities to “...establish requirements for the safe operation of such aircraft 

systems in the national airspace system,” Section 333(c) of the Reform Act. 

The name and address of the Applicant is: 

Principia, Inc. 

Attn: George Finlay 

71 South Orange Avenue 

South Orange, NJ 07079 

(917) 841-2362 

george@principiainc.com 

The Applicant requests exemption under the following Regulations: 
U. S. Department of Transportation 

March 4, 2015 

 

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14 CFR § 61.113(a) and (b) 

14 CFR § 91.119 

14 CFR § 91.121 

14 CFR § 91.151(a) 

14 CFR § 91.405(a) 

14 CFR § 91.407(a)(1) 

14 CFR § 91.409(a)(2) 

14 CFR § 91.417(a) and (b)1

This exemption application is expressly submitted to fulfill Congress’ goal in passing Section 333(a) 

through (c) of the Reform Act. This law directs the Secretary of Transportation to consider whether certain 

unmanned aircraft systems may operate safely in the national airspace system (NAS) before completion of 

the rulemaking required under Section 332 of the Reform Act. In making this determination, the Secretary 

is required to determine which types of unmanned aircraft system(s) (UASs) do not create a hazard to users 

of the NAS or the public or pose a threat to national security in light of: 1) the sUAS’s size, weight, speed, 

and operational capability; 2) operation of the sUAS in close proximity to airports and populated areas; and 

3) operation of the sUAS within visual line of sight (VLOS) of the operator. 

If the Secretary determines that such vehicles “may operate safely in the national airspace system, the 

Secretary shall establish requirements for the safe operation of such aircraft in the national airspace 

system.” Reform Act § 333(a) and (c). The Federal Aviation Act expressly grants the FAA the authority to 

issue exemptions. This statutory authority by its terms includes exempting civil aircraft, as the term is 

defined under § 40101 of the Act, which includes sUAS, from the requirement that all civil aircraft must 

have a current airworthiness certificate. 

The Administrator may grant an exemption from a requirement of a regulation prescribed under subsection 

(a) or (b) of this section or any sections 44702-44716 of this title if the Administrator finds the exemption 

in the public interest, 49 United States Code (U.S.C.) § 44701(f). See also 49 U.S.C. § 44711(a), 49 U.S.C. 

§ 44704, and 14 CFR § 91.203(a)(1). 

Principia’s sUAS is a rotorcraft, weighing 55 pounds or less including payload. It operates at an airspeed of 

no more than 55 knots and has the capability to hover and move in the vertical and horizontal planes 

simultaneously. It will be operated only within VLOS of the operator and will operate only within a 

secured area to ensure that the sUAS will “not create a hazard to users of the national airspace system or 

the public,” Reform Act, Section 333(b). 

Given the small size of the sUAS at issue and the secured environment within which it will operate, the 

applicant falls within that zone of safety (an equivalent level of safety) in which Congress envisioned that 

the FAA should, by exemption, allow commercial operations of UASs to commence immediately. Also 

due to the size of the sUAS and the restricted areas in which it will operate, approval of the application 

 

1

 Applicant understands that if it satisfies the requirements under Section 333, then there is no need for relief under 

14 CFR part 21 (airworthiness certificate), and under 14 CFR §§ 45.23(b) and 91.7(a). Applicant further understands 

that operation of sUAS does not require exemptions under 14 CFR § 91.9(b)(2) (civil aircraft marking and manual 

requirements) and based on the FAA memorandum “Interpretation regarding whether certain required documents 

may be kept on unmanned aircraft’s control station.” If the Administrator determines that the Applicant may be 

subject to those requirements, the Applicant reserves the right to supplement this request. 
U. S. Department of Transportation 

March 4, 2015 

 

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presents no national security issue. Given the clear direction in Section 333 of the Reform Act, the 

authority contained in the Federal Aviation Act as amended, the equivalent level of safety surrounding the 

proposed aerial photography/filming operations, and the significant public benefit, including enhanced

safety, reduction in environmental impacts such as reduced emissions associated with allowing UASs for

operations currently performed by larger manned aircraft, granting of the requested exemptions is in the 

public interest. Accordingly, Applicant respectfully requests that the FAA grant the requested exemption 

without delay. 

Specific regulations for which relief is sought by the Applicant: 

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

Sections 61.113(a) and (b) limit private pilots to non-commercial operations. Because the sUAS 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 sUAS. Unlike a conventional aircraft that carries the pilot and 

passengers, this sUAS is remotely controlled with no living thing on board. The area of operation is 

controlled and restricted, and all flights are planned and coordinated in advance as set forth in the General 

Operations Manual (GOM). The level of safety provided by the requirements included in the GOM and 

Aircraft Flight Manual (AFM) exceeds that provided by a single individual holding a commercial pilot’s

certificate operating a conventional aircraft. The risks associated with the operation of the sUAS are so 

diminished from the level of risk associated with commercial operations contemplated by part 61 when 

drafted, that allowing operations of the sUAS as requested with a private pilot as the PIC exceeds the

present level of safety achieved by 14 CFR § 61.113(a) and (b). 

14 CFR § 91.119 Minimum Safe Altitudes 

Section 91.119 establishes safe altitudes for operation of civil aircraft. Section 91.119(d) allows helicopters 

to be operated at less than the minimums prescribed, provided the person operating the helicopter complies 

with any route or altitudes prescribed for helicopters by the FAA. As this exemption request is for a sUAS 

that is a helicopter and requests the authority to operate at altitudes up to 400 feet above ground level 

(AGL), or for filming operations not more than 200 feet above an elevated platform from which filming is 

planned, an exemption may be needed to allow such operations. As set forth herein, except for the limited 

conditions stated in the GOM, the sUAS will never operate at higher than 400 feet AGL. It will be operated 

in a restricted area with security perimeter, where buildings and people will not be exposed to operations 

without their consent. 

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

location where it will be operated. No flight will be taken without the permission of the property owner or 

local officials. Because of the advance notice to the property owner and participants in the aerial 

photography/filming operations area, all affected individuals will be aware of the planned flight operations 

as set forth in the GOM. Compared to flight operations with aircraft or rotorcraft weighing far more than 

the maximum 55 pounds proposed herein and the lack of flammable fuel, any risk associated with these 

operations is far less than those presented with conventional aircraft operating at or below 400 feet AGL. 

In addition, the low-altitude operations of the sUAS will help ensure separation between these aerial 

photography/filming operations and the operations of conventional aircraft that must comply with Section 

91.119. 
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March 4, 2015 

 

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14 CFR § 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 sUAS does 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 operator, pursuant to 

the GOM and AFM, confirming the altitude of the launch site shown on the GPS altitude indicator before

flight. 

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

Section 91.151(a) prohibits an individual from beginning “a flight in an airplane under VFR conditions

unless (considering wind and forecast weather conditions) there is enough fuel to fly to the first point of 

intended landing, and, assuming normal cruising speed 1) during the day, to fly after that for at least 30 

minutes; or 2) at night, to fly after that for at least 45 minutes.” 

The battery powering the Applicant’s sUAS provides approximately 40 minutes of powered flight. To 

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

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

location of its proposed aerial photography/filming operations within a predetermined area, a longer time 

frame for flight in daylight or VFR conditions is reasonable. 

Applicant believes that an exemption from 14 CFR § 91.151(a) falls within the scope of prior exemptions. 

See Exemption 10673 (allowing Lockheed Martin Corporation to operate without compliance with FAR 

91.151(a)). Operating the sUAS in a tightly controlled area where only people and property owners or 

official representatives who have signed waivers will be allowed, with less than 30 minutes of reserve fuel, 

does not present the type of risks that Section 91.151(a) is intended to alleviate given the size and speed of 

the sUAS. Additionally, limiting sUAS flights to 10 minutes would greatly reduce the utility for the aerial 

photography/filming operations for which the exemption is sought. 

Applicant submits that an equivalent level of safety can be achieved by limiting flights to 30 minutes or 25 

percent of battery power, whichever happens first. This restriction would be adequate to return the sUAS to 

its planned landing zone from anywhere in its limited operating area. Similar exemptions have been 

granted to other operations, including Exemptions 2689F, 5745, 10673, and 10808. 

14 CFR §§ 91.405(a); 91.407(a)(1); 91.409(a)(2); 91.417(a) and (b) Maintenance Inspections 

These regulations require that an aircraft operator or owner “shall have that aircraft inspected as prescribed 

in subpart E of this part and shall between required inspections, except as provided in paragraph (c) of this 

section, have discrepancies repaired as prescribed in part 43 of this chapter...,” and others shall inspect or 

maintain the aircraft in compliance with part 43. 

Given that these sections and part 43 apply only to aircraft with an airworthiness certificate, these sections 

will not apply to the Applicant. Maintenance will be accomplished by the operator pursuant to the AFM 

and GOM. As provided in the GOM, the operator will ensure that the sUAS is in working order prior to 

initiating flight, perform required maintenance, and keep a log of any maintenance performed. 
U. S. Department of Transportation 

March 4, 2015 

 

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Limitations and conditions to which Principia agrees to be bound when conducting commercial sUAS 

operations under the requested exemption include those listed below: 

AIRCRAFT 

1. Operations authorized by this grant of exemption are limited to the following aircraft described in 

the attached AFM: DJI S1000 serial number Q2Q0021602, registration N68FG. Proposed 

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

2. The sUAS will weigh less than 55 pounds (25 kg), including energy source(s) and equipment. 

3. All aircraft operated in accordance with this exemption will be identified by serial number, 

registered in accordance with 14 CFR part 47, and have identification (N-Number) markings in 

accordance with 14 CFR part 45, subpart C. Markings will be as large as practicable. 

4. The sUAS may not be flown at an airspeed exceeding 55 knots. 

5. The sUAS will be programmed to return to a predetermined location within the Security 

Perimeter to land or be recovered in the event manual control is lost. 

MANUALS 

1. The AFM and GOM will be maintained and made available to the Administrator upon request. If 

a discrepancy exists between the conditions and limitations in this exemption and the procedures 

outlined in either of those documents, the conditions and limitations herein take precedence and 

must be followed. Otherwise, Principia will follow the procedures as outlined in the AFM and 

GOM. 

2. Principia will track revisions to the AFM and GOM and present updated and revised documents 

to the Administrator upon request. It will also present updated and revised documents if we 

petition for extension or amendment. If it determines that any update or revision would affect the 

basis for which the FAA granted this exemption, then it will petition for amendment to the 

exemption. The FAA’s UAS Integration Office (AFS-80) will be contacted if questions arise 

regarding updates or revisions to the AFM and GOM. 

CREW 

1. Minimum crew for each operation will consist of pilot, visual observer (VO), and the camera 

operator. The VO may be used to satisfy the VLOS requirement as long as the PIC always 

maintains VLOS capability. The VO and PIC will be able to communicate verbally at all times. 

2. The PIC will possess at least a private pilot certificate and at least a current third-class medical 

certificate. The PIC will also meet the flight review requirements specified in 14 CFR § 61.56 in 

an aircraft in which the PIC is rated on his or her pilot certificate. Prior to conducting commercial 

aerial photography/filming operations, the PIC will have accumulated and logged, in a manner 

consistent with 14 CFR § 61.51(b), a minimum of 25 hours of total time as a UAS rotorcraft pilot 

and at least 10 hours logged as a UAS pilot with a similar UAS type. 
U. S. Department of Transportation 

March 4, 2015 

 

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3. Prior to conducting commercial aerial photography/filming flight operations, the PIC will be 

required to have accumulated and logged, in a manner consistent with 14 CFR § 61.51(b), a 

minimum of five hours as an UAS pilot operating the make and model of UAS to be utilized for 

operations under the exemption and three takeoffs and three landings in the preceding 90 days. 

4. During training, proficiency, experience-building, and takeoff and landing currency flights, all 

persons not essential for flight operations will be considered nonparticipants, and the PIC will be 

required to operate the sUAS with appropriate distance from nonparticipants in accordance with 

14 CFR § 91.119. 

5. Prior to any commercial aerial photography/filming flight operations, the crew will have 

successfully completed the qualification process detailed in the GOM. As this is a requirement 

stipulated by Principia, the test has been developed and implemented by a qualified person 

designated at the sole discretion of Principia. A record of completion of this qualification process 

will be documented and made available to the Administrator upon request. 

6. Prior to commercial aerial photography/filming flight operations, a flight demonstration, 

administered by an operator-approved and qualified pilot will be successfully completed and 

documented. This documentation will be available for review upon request by the Administrator. 

Because the knowledge and airmanship test qualifications have been developed by the operator, 

and there are no established practical test standards that support a jurisdictional FAA Flight 

Standards District Office (FSDO) evaluation and approval of company designated examiners, 

Principia will conduct these tests in accordance with the GOM. 

7. The documents required under 14 CFR §§ 91.9 and 91.203 will be available to the PIC any time 

the aircraft is operating. These documents will be made available to the Administrator or any law 

enforcement official upon request. 

MAINTENANCE 

1. If any part of the sUAS has undergone maintenance or alterations that affect operation or flight 

characteristics, for example, replacement of a flight critical component, then the entire sUAS will 

undergo a functional test flight in accordance with the GOM. The PIC who conducts the 

functional test flight will make an entry in the sUAS aircraft records of the flight, as required by 

the GOM. 

2. The AFM will include updated current maintenance procedures, inspection requirements, and life 

limits for aircraft systems including servos, motors, propellers, electronic speed controllers, 

batteries, and remote control. 

3. All technicians performing maintenance and inspection on the sUAS will meet technician 

qualification criteria developed by Principia and included in the GOM. 

4. Each sUAS operated under this exemption will comply with all manufacturer safety bulletins. 
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March 4, 2015 

 

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5. The GOM includes procedures to document and maintain a record of the sUAS maintenance, 

preventative maintenance, alterations, status of replacement/overhaul of component parts, and the 

total time in service of the sUAS. 

OPERATIONS 

1. Prior to each flight, the PIC will inspect the sUAS to ensure it is in a condition for safe flight. If

the inspection reveals a condition that affects the safe operation of the sUAS, the aircraft is 

prohibited from operating until the necessary maintenance has been performed and the sUAS is 

found to be in a condition for safe flight. The remote control will be included in the preflight 

inspection. All maintenance and alterations will be properly documented in the aircraft records. 

2. Flights will be operated at an altitude of no more than 400 feet AGL, except for limited 

conditions outlined in the GOM. All altitudes reported to Air Traffic Control (ATC) will be in 

feet AGL. 

3. The sUAS will be operated within VLOS of the PIC at all times. This requires the PIC to be able 

to use human vision unaided by any device other than corrective lenses, as specified on the PIC’s 

FAA-issued medical certificate. 

4. Before conducting commercial aerial photography/filming flight operations, the radio-frequency 

spectrum used for operation and control of the sUAS will be checked to comply with Federal 

Communications Commission (FCC) or other appropriate government-oversight agency 

requirements. 

5. Regarding distance from nonparticipating persons, the operator will ensure that no persons in 

open areas are allowed within 500 feet of the aircraft except those consenting to be involved and 

necessary for the aerial photography/filming operations. If barriers or structures are present that 

can sufficiently protect nonparticipating persons from debris in the event of an accident then the 

UA may operate closer than 500 feet to persons afforded such protection. The operator must 

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

nonparticipating persons leave such protection and are within 500 feet of the UA, flight 

operations must cease immediately. 

6. Regarding the distance from participating persons, the GOM has safety mitigations for authorized 

and consenting production personnel. At all times, those persons must be essential to the aerial 

photography/filming operations. Because these procedures are specific to participating persons, 

no further FSDO or aviation-safety inspector approval will be considered necessary for reductions 

to the distances specified in the GOM, consistent with the manned aircraft procedures described 

in FAA Order 8900.1, V3, C8, S1. 

7. Each sUAS operation will be completed within 30 minutes flight time or with 25% battery power 

remaining, whichever occurs first. 

8. The sUAS will remain clear and yield the right of way to all other manned operations and 

activities at all times (including, but not limited to, ultralight vehicles, parachute activities, 

parasailing activities, hang gliders, etc.). 
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March 4, 2015 

 

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9. UAS operations will not be conducted during night, as defined in 14 § CFR 1.1. All operations 

will be conducted under visual meteorological conditions (VMC). Flights under special visual 

flight rules (SVFR) are not authorized. 

10. The sUAS will not be operated from any moving device or vehicle. 

11. The sUAS will not be operated fewer than 500 feet below or fewer than 2,000 feet horizontally 

from a cloud or when visibility is less than three statute miles from the PIC. 

12. The sUAS will not operate in Class B, C, or D airspace without written approval from the FAA. 

The sUAS will not operate within five nautical miles of the geographic center of a non-towered 

airport as denoted on a current FAA-published aeronautical chart unless a letter of agreement 

with that airport’s management is obtained. The letter of agreement with the airport management 

will be made available to the Administrator upon request. 

13. The sUAS will only operate only within a confined “Secured Area” as defined in the GOM, 

which requires the establishment of a “Security Perimeter” for the flight operations area. 

14. A briefing will be conducted in regard to the planned operation prior to each day’s flight 

activities. It will be mandatory that all personnel who will be performing duties within the 

boundaries of the safety perimeter be present for this briefing. 

15. Accidents will be reported to the National Transportation Safety Board (NTSB) per instructions 

contained on the NTSB website: www.ntsb.gov. Further flight operations will not be conducted 

until the incident, accident, or transgression is reviewed by AFS-80 and authorization to resume 

operations is provided. 

16. Unless otherwise specified in this grant of exemption, the sUAS, the sUAS PIC, and the sUAS 

operations will comply with all applicable parts of 14 CFR including, but not limited to, parts 45, 

47, 61, and 91. 

17. Applicant agrees that failure to comply with any of the conditions and limitations of this grant of 

exemption will be grounds for the immediate suspension or rescission of this exemption. 

********* 

Pursuant to 14 CFR part 11, the following summary is provided for publication in the Federal Register,

should it be determined that publication is needed:

Applicant seeks an exemption from the following rules: 14 CFR §§ 61.113(a) and (b); 91.119; 91.121; 

91.151(a); 91.405(a); 91.407(a)(1); 91.409(a)(2), and 91.417(a) and (b) to operate commercially a sUAS

(55 pounds or less) in aerial photography/filming operations. 

Approval of exemptions allowing commercial operations of sUASs will enhance safety by reducing risk. 

Conventional manned flight operations, using jet or piston power aircraft, sometimes operate at low in

close proximity to people and structures; and present the risks associated with vehicles that weigh 

approximately 6,000 pounds, carrying large amounts of fuel or other flammable liquid. Such aircraft must 

fly to and from the job location. In contrast, a sUAS weighing less than 55 pounds and powered by 
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March 4, 2015 

 

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

board. The sUAS is carried to the job location, not flown. The sUAS will carry no passengers or crew and, 

therefore, will not expose them to the risks associated with manned aircraft flights. 

The operation of sUASs, weighing less than 55 pounds, conducted in accordance with the conditions 

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

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

and, as a result, are safer than conventional operations conducted with helicopters operating in close

proximity to the ground and people. 

Privacy 

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

and knowledge. Photography/filming will be of people who have also consented to being photographed or 

otherwise have agreed to be in the area where the aerial photography/filming operations will take place. All 

operations will be compliant with applicable local and state laws. 

The Applicant’s request satisfies the criteria set forth in Section 333 of the Reform Act. The size, weight, 

speed, operating capabilities of the sUAS, the limitations on operations proximate to airports and populated 

areas, and the operation within VLOS do not create a hazard to users of the national airspace system and 

do not pose any national security threats or concerns. The foregoing easily meets the criteria for granting 

the requested exemptions allowing commercial operations of Applicant’s sUAS pursuant to the GOM and 

AFM appended hereto. 

Respectfully submitted, 

/s/ Richard H. Brown 

Richard H. Brown 

Day Pitney LLP 

Counsel for Principia, Inc. 

John McGraw 

John McGraw Aerospace Consulting, LLC 

Agent for Principia, Inc. 

Encls. 
U. S. Department of Transportation 

March 4, 2015 

 

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Glossary of Acronyms 

AFM: Aircraft Flight Manual, also known as a Pilot’s Information Manual; a document for a specific 

make and model laid out in the same format familiar to pilots in an FAA-approved PIH, Pilot Information 

Handbook. The 10 sections are: 1) General, 2) Limitations, 3) Emergency Procedures, 4) Normal 

Procedures, 5) Performance, 6) Weight and Balance, 7) Airplane and Systems Description, 8) Handling, 

Servicing, and Maintenance, 9) Supplements, and 10) Safety and Operational Tips. 

AGL: above ground level; this is one of two ways in which pilots and air traffic control refer to altitude, 

and it is the most useful way for operations close to the ground. 

ATC: Air Traffic Control 

CFR: Code of Federal Regulations 

FARs: Federal Aviation Regulations 

FSDO: Flight Standards District Office 

GOM: General Operations Manual; a document that details company-wide operating procedures not 

specific to one of the aircraft that company operates. It includes details on company organization, job 

responsibilities, and procedures for training, operating, maintenance, safety, and security. 

NAS: national airspace system 

NTSB: National Transportation Safety Board 

PIC: Pilot in Command 

sUAS: small unmanned aerial system, defined as 55 pounds (24 kg) or less 

SVFR: special visual flight rules 

UAS: unmanned aerial system, includes the ground control equipment as well as the aircraft itself 

USC: United States Code 

VFR: visual flight rules 

VLOS: visual line of sight 

VMC: visual meteorological conditions 

VO: visual observer