UNITED STATES OF AMERICA

DEPARTMENT OF TRANSPORTATION

FEDERAL AVIATION ADMINISTRATION

WASHINGTON, DC

Reg. Docket No.

In the Matter of Petition for Exemption of:

Frederick H. Meek

For an Exemption from the requirements of the

Code of Federal Regulations Sections

Concerning operation of an Unmanned Aircraft System

Pursuant to Section 333 of the

 FAA Modernization and Reform Act of 2012
2

CONTENTS

I. PETITIONER’S DESCRIPTION............................................................................................... 3

II. PROPOSED OPERATIONS ..................................................................................................... 4

III. RELEVANT AUTHORITY TO PETITIONER’SEXEMPTION REQUEST ................................... 7

IV. QUALIFICATION FOR APPROVAL UNDER SECTION 333 OF THE REFORM ACT................. 8

V. REGULATIONS FROM WHICH EXEMPTION IS REQUESTED.............................................. 11

VI. PUBLIC INTEREST .............................................................................................................. 22

VII. PRIVACY ............................................................................................................................ 23

VIII. FEDERAL REGISTER SUMMARY ........................................................................................ 24

IX. CONCLUSION ..................................................................................................................... 25
3

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

Act”)

1 and 14 C.F.R. 11, Frederick H. Meek (“Petitioner”) hereby applies for an exemption

from Federal Aviation Regulations (“FARs”) identified below, to allow commercial operation of

small unmanned aerial vehicles (i.e. small unmanned aircraft systems or “sUAS”).

This exemption is in accordance with protocols outlined in this petition for exemption, the 

enclosed UAS Operations Manual (“Manual”)

2

, the UAS manufacturers operations and

maintenance manual (“Aircraft Operations Manual”), and any other requirements established by

the FAA pursuant to Section 333 of the Reform Act.

I. PETITIONER’S DESCRIPTION

Petitioner is a Private Individual based in Harmony, FL that has flown R/C Aircrafts 

and Quadcopters for 2 years. Petitioner has experience in aerial photography and videography for 

sole use or complimentary use to other individuals. In addition, petitioner is an experienced 

commercial diver, bridge inspector with NBIS Qualification, and exercises proper judgement, 

erring on the side of safety. The Petitioner has also attended courses taught by FAA Flight 

Standards Contract Instructors in UAV Piloting, Safety, and understands the regulations in the 

operations of controlled and uncontrolled airspace. 

The petioner’s intent is to utitilize his sUAS in the engineering fields (bridges and 

structures), real estate, photography and videography across the United States. 

The Petitioner’s use of sUAS in the engineering field of expertise such as bridge 

inspection, drastically reduces overall risk to the public while conducting infrastructure

inspection operations.

1 Codified at 49 U.S.C. § 40101, as amended by Pub. L. 112-95 Feb. 14, 2012, 126 Stat. 11.

2 Petitioner submits this manual as a confidential document under 14 C.F.R. § 11.35(b), as the entire

Manual contains confidential commercial and proprietary information the Petitioner has not and will not 

share with others. The Manual contains operating conditions and procedures that are not available to the 

public and are protected from release under the Freedom of Information Act 5 U.S.C. § 552.
4

Consistent with the requirements of 14 C.F.R. § 11.81(a), Petitioner provides the

following information in support of its petition of exemption:

 The name and address of the Petitioner’s representative is: 

Attn: Frederick H. Meek

6848 Sundrop Street

Harmony, FL 34773

(407)902-7100

Email: mrfhm@aol.com

 II. PROPOSED OPERATIONS

The Petitioner proposes to conduct sUAS flight operations in support of bridge

inspection across the United States. The Petitioner also proposes to conduct sUAS flight 

operations to inspect High Mast Light Towers (HMLT’s) when geographic locations and 

distance from roadway and active traffic permit use.

Prior to conducting a bridge inspection with the sUAS, the Petitioner will conduct

a visual inspection utilizing traditional climbing and inspection techniques. Armed with this

information, the Petitioner can then conduct a proof of concept - collecting data and

information via sUAS to improve the inspection process and test new methods and 

techniques.

Prior to conducting HMLT inspections with the sUAS, the petitioner will conduct a 

site study, identifying potential hazards (close proximity to roadway traffic, pedestrians, 

powerlines) at the location of the HMLT. An engineering and safety judgement will be made 

at the public’s best interest. 

The Petitioner also proposes to conduct sUAS flight operations to document real 

estate by use of video (with permission from owner or owner’s agent) for use in enhancement 

of advertisement, listing, with the ultimate outcome of selling real estate. 
5

Enclosed in this waiver is the Petitioner’s sUAS Manual (Exhibit “A”). The

enclosed Manual describes, in detail, the policies and procedures for Petitioner’s proposed

sUAS operations. To assist the FAA in its safety assessment of the Petitioner’s proposed 

sUAS operations, below is a summary of the operational limitations and conditions which will

ensure an equivalent or higher level of safety to operations conducted under current

regulatory guidelines:

1. The sUAS weighs less than 15 pounds including payload.

2. Flights will be operated within line-of-sight of a pilot and/or observer during

daylight hours only.

3. Maximum total flight time for each operational flight will be 45 minutes. Flights will

be terminated at 25% battery power reserve should that occur prior to the 45 minute 

limit.

4. Flights will be operated at an altitude of no more than 400 feet above ground

level.

5. Minimum crew for each operation will consist of the sUAS Pilot, observer/spotter

and inspection team leader directing the inspection.

6. Operations will be conducted by personnel with rotorcraft experience and annual 

physical.

7. The sUAS pilot will be Pilot in Command (PIC). If a pilot certificate holder other

than the sUAS Pilot is present and possesses the necessary PIC qualifications, that

person can also be designated as PIC.

8. The UAS will only operate within a confined “Sterile Area” immediate and 

adjacent to boundaries close to the bridge, HMLT, real estate, or other subject. 

9. A briefing will be conducted in regard to the planned sUAS operations prior to

each day’s 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.
6

10. Pilot and Observer will have been trained in operation of UAS generally and will

have received up-to-date information on the particular UAS to be operated, as

required in the Manual.

11. Observer and Pilot will at all times be able to communicate by voice and

text.

12. All required permission and permits will be obtained from territorial, state, county

or city jurisdictions, including local law enforcement, fire, or other appropriate

governmental agencies.

13. If the sUAS loses communications or loses its GPS signal, the sUAS is equipped

with advanced safety features that will allow the sUAS to automatically return to

a pre- determined location.

14. The sUAS will have the capability to abort a flight in case of unpredicted obstacles

or emergencies.

15. The sUAS will only operate in optimal weather conditions for

flight.
7

III. RELEVANT AUTHORITY TO PETITIONER’SEXEMPTION REQUEST

This petition for exemption is submitted to advance Congress’ goal of integrating sUAS 

safely into the NAS. In the Reform Act, Congress directed the FAA “to safely accelerate the 

integration of civil unmanned aircraft systems in the national airspace system,” and, under Section

333 of that law, directed the Secretary of Transportation (“FAA Administrator”) to consider 

whether certain unmanned aircraft systems may operate safely in the National Airspace System 

(“NAS’) before completion of the rule making required under Section 332 of the Reform Act.

4

In making this determination, the FAA Administrator is required to determine which types 

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

security in light of the following:

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

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

• Operation of the UAS within visual line-of-sight of the operator.

5

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.”

6

The FAA Administrator has general authority to grant exemptions from FAA safety 

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

the public interest.

7 A party requesting an exemption must explain the reasons why the exemption: 

(1) would benefit the public as a whole and; (2) would not adversely affect safety or how it would 

provide a level of safety at least equal to the existing rules.8 Therefore, the Petitioner will 

demonstrate how the proposed sUAS infrastructure inspection will benefit the public and that the 

proposed operation will not adversely affect safety of the public and to those operating in the NAS.

4 Reform Act, supra note 1.

5 Id. at § 333(b)(1).

6 Id. § 333(c)(emphasis added).

7 See 49 U.S.C. § 44701(f) (authorizing the grant of exemptions from a requirement of regulations 

prescribed pursuant to section 44701 (a) - (b) and sections 44702-44716).

8 See 14 C.F.R. § 11.81; FAA, Petition for Exemptions.
8

IV. QUALIFICATION FOR APPROVAL UNDER SECTION 333 OF THE REFORM ACT

A. The Petitioner’s Proposed Usage Does not Create a Hazard to Users of the

NAS or the Public Because of the Reduced Size, Weight, Speed, and Operational

Capability of the sUAS.

The proposed operations in this petition for exemption qualify for expedited approval under 

Section 333 of the Reform Act. Each of the statutory criteria and other potential relevant factors 

are satisfied.

The proposed operations would permit use 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 pose an increased level of safety beyond what exists when climbers are asked to 

inspect infrastructure.

Petitioner’s sUAS is a rotorcraft aircraft, weighing less than 15 pounds, including payload. 

It operates, under normal weather conditions, at a speed of no more than 29 knots and has the 

capability to hover, and move in vertical and horizontal planes simultaneously.

Petitioner’s sUAS will operate in line-of-sight and only in a confined, sterile area

described in the Proposed Operations section outline here and in the Petitioner’s Manual.9 

Such operations will insure that the sUAS will “not create a hazard to users of the National

Airspace System or the public.”

10

Given the small size of the sUAS involved and the restricted, confined, sterile

environments within which it will operate, this petition for exemption falls squarely within that

zone of safety in which Congress envisioned that the FAA must, by exemption, allow

commercial operations of UASs to commence immediately.

B. The Petitioner’s Proposed Usage Does not Create a Hazard to Users of the

NAS or the Public because the Operation of the sUAS will be conducted in a Remote

Location not in Close Proximity to Airports and Populated Areas. Furthermore, 

engineering judgement and safety to the public will be paramount to the operational 

function of the sUAS. 

9 See Manual Section 6.1.2.1.

10 Reform Act, supra note 1 at § 333 (b)(1).
9

The potential use and integration of an sUAS in bridge, HMLT inspection, real estate, 

videography to test new methods and techniques will give engineers, inspectors, realtors, and 

other interested parties a different perspective.

C. The Petitioner’s Proposed Usage Does not create a Hazard to Users of the NAS

or the Public because the Operation of the sUAS will be conducted within visual lineof- sight of the operator.

The Petitioner will remain within visual line-of-sight of the operator. At no time will the

sUAS endanger the public, or will be allowed to operate over roadways or populated areas.. The 

petitioner’s flight operations will remain below 400 AGL for the duration of any inspection.

The Petitioner will use the sUAS to visually inspect the support structures of bridges. 

Each bridge is unique in its own characteristics. Because the petitioner will not allow operations 

over a roadway or populated area, In the rare occurrence that a malfunction occurs to the sUAS, 

the sUAS would fall to the ground or waterway below the bridge rather than onto a roadway.

Moreover, the structure of the bridge and the space between the members of the bridge allow the

Pilot and observer to maintain line of sight on the sUAS for the duration of the flight. Thus, the

risk to the public is greatly reduced because the Pilot will be able to avoid any obstacles and 

other aircrafts in real time.

The Petitioner will use the sUAS to visually inspect High Mast Light Towers (HMLT’s) 

ONLY in cases provided that the HMLT is 100’ or more away from a traveled roadway, accessed 

by vehicular traffic or in areas that are not populated. In the rare occurrence that a malfunction

occurs to the sUAS, the sUAS would fall to the ground

D. The sUAS will remain below 400 AGL at all times during the operation.

The Petitioner’s sUAS will not fly above 400 AGL at any time during the course of a 

bridge or HMLT inspection (Most HMLT’s are between 100’ to 200’ in height).

The Petitioner will launch, operate, and recover the sUAS from a predetermined 

location close the the bridge and maintain visual line-of-sight at all times. The inspection method

that Petitioner will utilize will not require the sUAS to pass above 400 feet AGL to

successfully complete the inspection. Therefore, the Petitioner’s proposed usage will not pose

a hazard to the NAS because the sUAS will not operate above 400 AGL at any time during the 

duration of any flight.
10

Given the foregoing, the Petitioner’s proposed usage does not pose a hazard to the NAS or 

to the public. Considering the clear statutory language in Section 333 of the Reform Act, the 

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

public and to the men and women conducting infrastructure inspections, and the reduction in 

environmental effects, the grant of the requested exemptions is in the public interest. Accordingly, 

Petitioner respectfully requests that the FAA grant the requested exemption without delay.

V. REGULATIONS FROM WHICH EXEMPTION IS REQUESTED

The Federal Aviation Act expressly grants the FAA Administrator the authority to issue 

exemptions. By its terms, this statutory authority includes exempting civil aircraft, as the term is 

defined under § 40101 of the Act, including sUASs, from its safety regulations and minimum 

standards when the Administrator decides a requested exemption is in the public interest.

12

Petitioner asks an exemption from several interrelated provisions of 14 C.F.R. Parts 21, 45 

and 91 for purposes of conducting aerial surveys and inspections using sUAS. Listed below are: 

(1) the specific sections of 14 C.F.R. for which exemption is sought; and (2) the operating 

procedures and safeguards that Petitioner has established which will ensure a level of safety equal 

to or better than the rules from which exemption is sought.

13

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

91.203(a)(1).

The Petitioner seeks an exemption from 14 C.F.R. Part 21, Subpart H, which establishes 

the procedural requirements for the issuance of airworthiness certificates as required by 14 C.F.R

§ 91.203(a)(1). Given the size and limited operating area associated with the sUAS to be utilized 

by the Petitioner, an exemption from Part 21, Subpart H meets the requirements of an equivalent 

level of safety under Part 11 and Section 333 of the Reform Act.

12 See 49 U.S.C. § 44701(f) authorizing the grant of exemptions from requirements of regulations 

prescribed pursuant to §§ 44710(a) and (b), §§ 44702 – 44716.

13 See 14 C.F.R. § 11.81(e) which requires a petition for exemption to include: “the reasons why granting 

the exemption would not adversely affect safety, or how the exemption would provide a level of safety at

least equal to that provided by the rule from which you seek exemption.”
11

The Federal Aviation Act14and Section 333 of the Reform Act

15

both authorize the FAA 

to exempt aircraft from the requirement for an airworthiness certificate, upon consideration of the 

size, weight, speed, operational capability, and proximity to airports and populated areas of the 

particular UAS. In all cases, an analysis of these criteria demonstrates that the sUAS operated 

without an airworthiness certificate, in the restricted environment and under the conditions 

proposed will be at least as safe, or safer, than a conventional rotorcraft operating with an 

airworthiness certificate without the restrictions and conditions of the proposed sUAS operations

Equivalent Level of Safety

The sUAS to be operated hereunder is less than 15 lbs. fully loaded, carries neither a pilot 

nor passenger, carries no explosive materials nor flammable liquid fuels, and operates

exclusively within close proximity to the bridge or HMLT being inspected. Unlike other civil

aircraft, the proposed operations in this petition for exemption will be controlled and monitored

by the operator, pursuant to the Manual's requirements. Moreover, the FAA will have advance

notice of all operations conducted under this exemption.

These safety enhancements, which already apply to civil aircraft operated in connection 

with existing inspection operations, provide a greater degree of safety to the public and property 

owners than conventional operations conducted with airworthiness certificates issued under 14

C.F.R. Part 21, Subpart H. Lastly, application of these same criteria demonstrates that there is no 

credible threat to national security posed by the sUAS, due to its size, speed of operation, location 

of operation, lack of explosive materials or flammable liquid fuels, and inability to carry a 

substantial external load.

14 See 49 U.S.C. § 44701(f).

15 See Reform Act, supra note 1.
12

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

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

normal category rotorcraft. To the extent the Petitioner's sUASs would otherwise require 

certification under Part 27, as a rotorcraft, Petitioner requests an exemption from Part 27’s 

airworthiness standards for the same reasons identified in the exemption request from 14 C.F.R. 

Part 21, Subpart H.

C. Aircraft Marking and Identification Requirements: 14 C.F.R. §§ 91.9(c),

45.23(b), and 45.27(a).

This petition seeks an exemption from the aircraft marking and identification requirements 

of 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 that:

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

aircraft is identified in accordance with part 45 of this chapter.

16

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.

17

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 §45.23.18

16 14 C.F.R. § 91.9(c).

17 14 C.F.R. § 45.23(b).

18 14 C.F.R. § 45.27(a).
13

Exemption from § 45.23(b) is warranted because the sUAS has no entrance to the cabin, 

cockpit, or pilot station on which the registration number can be placed. Moreover, given the size 

of the sUAS, two-inch lettering would be impossible. The aircraft registration, or “N Number’” 

will be placed on the fuselage in compliance with § 45.29(f).

Given the nature of the specific relief sought by this exemption request, Petitioner requires 

relief from the associated marking and identification requirements of § 45.27(a) and § 91.9(c), 

which would require compliance with § 45.23(b).

Equivalent Level of Safety

An equivalent level of safety for exemptions to the aircraft marking and identification 

requirements of §§ 91.9(c), 45.23(b), and 45.27(a), will be provided by having the sUAS marked 

on its fuselage as required by § 45.29(f) where the pilot, observer, and others working with the 

sUAS will see the identification of the UAS as "Experimental." Additionally, Petitioner will ensure 

compliance with any requests of sUAS marking by the FAA.

The FAA has issued the following exemptions to the aircraft marking requirements of §

45.23(b): Exemptions Nos. 10700, 8738, 10167 and 10167A.

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

Command.

This petition seeks an exemption from the private pilot privileges and limitations of §§

61.113 (a) and (b), which states:

(a) Except as provided in paragraphs (b) through (h) of this section, 

no person who holds a private pilot certificate may act as pilot in 

command of an aircraft that is carrying passengers or property for 

compensation or hire; nor may that person, for compensation or hire, 

act as pilot in command of an aircraft.

(b) A private pilot may, for compensation or hire, act as pilot in 

command of an aircraft in connection with any business or 

employment if:

(1) The flight is only incidental to that business or employment; and

(2) The aircraft does not carry passengers or property for 

compensation or hire.

19
14

14 C.F.R. § 61.113(a) limits private pilots to being in command of non-commercial flights.

14 C.F.R. § 61.113(b)(1) provides an exception that allows a private pilot to command an aircraft 

without passengers or property, in connection with business or employment if "[t]the flight is only 

incidental to that business or employment."

20 The stated exception likely does not apply to the 

proposed operations under this petition for exemption, as the flights are not incidental to the 

proposed aerial surveys and inspections but rather essential to it. Accordingly, the Petitioner seeks 

an exemption to 14 C.F.R. § 61.113(a)'s commercial limitation and/or 14 C.F.R. § 61.113(b)(1)'s 

requirement that the flight be incidental to the business to benefit from the exception.

Equivalent Level of Safety

As required by the Manual, Petitioner's sUAS operators acting as PIC will have extensive 

experience in conducting flight operations with various sUAS and have rotorcraft experience.

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

equivalent level of safety to 14 C.F.R. §§ 61.113 (a) and (b).

Unlike a conventional aircraft that carries the pilot and passengers, the sUAS is remotely 

controlled with no passengers on board. Moreover, the area of operation is controlled and 

restricted close the bridge or HMLT. All flights will be planned, coordinated, and briefed to the

appropriate official in advance as set forth in the Manual.

IEI can achieve or exceed an equivalent level of safety as achieved by current Regulations

because the sUASs do not carry any pilots or passengers. Further, while helpful, a pilot license

will not ensure remote control piloting skills. However, IEI’s sUAS pilots will attend 

comprehensive training programs that will ensure the PIC has substantial experience on the

airframe. IEI’s sUAS pilots will operate sUASs with the same skill. The risks attendant to

the operation of IEI’s sUASs are far less than the risk levels inherent in the commercial

activities outlined in 14 C.F.R. § 61, et seq. Thus, allowing IEI to operate its UASs with a

trained pilot as the PIC and will exceed current safety levels in relation to 14 C.F.R. §§ 61.113 

(a) and (b).

19 14 C.F.R. § 61.113 (a) and (b).

20 14 C.F.R. § 61.113(b)(1).
15

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

The Petitioner seeks an exemption from the flight manual requirements of 14 C.F.R. §

91.9(b)(2), which states:

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

(2) For which an Airplane or Rotorcraft Flight Manual is not 

required by § 21.5 of this chapter, unless there is available in the 

aircraft a current approved airplane or Rotorcraft Flight Manual, 

approved manual material, markings, and placards, or any 

combination thereof.

21

Given its size, configuration, and load capacity, the sUAS has no ability to carry such a 

manual on the aircraft, not only because there is no pilot on board, but because there is simply no 

room or capacity to carry such an item on the aircraft.

Equivalent Level of Safety

The safety related purpose of this manual requirement can be equally satisfied by 

maintaining the sUAS flight manual at the ground control point where the pilot flying the sUAS 

will have immediate access to it. Accordingly, Petitioner requests an exemption from § 91.9(b)(2)'s 

flight manual requirements, on the condition that the sUAS flight manual be available at the control 

point during each operation.

The FAA has issued the following exemptions to this regulation: Exemption Nos. 8607,

8737, 8738, 9299, 9299A, 9565, 9565B, 10167, 10167A, 10602, 32827, and 10700.

21 14 C.F.R. § 91.9(B)(2).
16

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

This petition seeks an exemption from 14 C.F.R. § 91.7(a), which requires that a civil 

aircraft be in an airworthy condition to be operated. Inasmuch there will be no airworthiness 

certificate issued for the sUAS, should this exemption be granted, no FAA regulatory standard will 

exist for determining airworthiness.

Equivalent Level of Safety

The Petitioner’s PIC has over 600 flight hours and a stellar safety record. Given the size of

the sUAS and the requirements contained in the Manual for maintenance and use of safety 

checklists prior to each flight, an equivalent level of safety will be provided.

The FAA has issued the following exemptions to this regulation: Exemption Nos. 8607,

8737, 8738, 9299, 9299A, 9565, 9565B, 10167, 10167A, 10602, 32827, and 10700.

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

This petition seeks an exemption from § 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.

22 Inasmuch as an FAA approved flight manual will not be 

provided for the sUAS, an exemption is requested.

Equivalent Level of Safety

An equivalent level of safety will be provided by following the Aircraft Operations 

Manual comprehensive preflight checklist. The PIC will take all actions, including reviewing 

weather, flight battery requirements, landing and takeoff distances, and aircraft performance data, 

before initiation of flight.

22 14 C.F.R. § 91.103.
17

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

The Petitioner seeks an exemption from 14 C.F.R. § 91.109(a), which provides that “no 

person may operate a civil aircraft (except a manned free balloon) that is being used for flight 

instruction unless that aircraft has fully functional dual controls.”

23 sUASs and remotely piloted 

aircraft, by their design do not have fully functional dual controls. Instead, flight control is 

accomplished through the use of a control box communicating with the sUAS via radio 

communications.

Equivalent Level of Safety

Given the size and speed of the sUAS, an equivalent level of safe training can still be 

performed without dual controls because no pilot or passengers are aboard the sUAS, and all 

persons will be a safe distance away should the sUAS experience 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.

24

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

This petition seeks an exemption from the minimum safe altitude requirements of 14 C.F.R.

§ 91.119. This Section 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 

non-congested areas.

25 Section § 91.119(d)(1) 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.

To provide the intended inspections, the sUAS will normally need to be operated within a range

of approximately 50 feet from the infrastructure being inspected. Accordingly, due to the nature

of the proposed operations, the PIC and the designated observer may at times be less than 500 

feet away from structures during the operation, and an exemption is therefore required.

23 14 C.F.R. § 91.109(a).

24 See Exemption Nos. 5778K and 9862A.

25 See 14 C.F.R. § 91.119(c).
18

Equivalent Level of Safety

Compared to flight operations with rotorcraft weighting far more than the maximum 15 

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

is far less than those presently presented with conventional aircraft. An equivalent level of safety 

will be achieved given the size, weight, speed of the UAS as well as the location where it is 

operated. Asset forth in the Manual, the sUAS will be operated in an adjacent, restricted area,

where buildings and people will not be exposed to operations. The sUAS will not operate 

over roadways or populated areas. All affected individuals will be aware of the planned flight 

operations as set forth in the Manual. Furthermore, by operating at such lower altitudes, the sUAS

will not interfere with other aircraft that are subject to the minimum safe altitude regulations.

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

The Petitioner 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.

26 An exemption is required 

because the sUAS does not have a barometric altimeter, but rather a GPS altitude read out.

Equivalent Level of Safety

An equivalent level of safety will be achieved by following the procedures set forth in the 

Manual. As prescribed in the Manual, the operator will confirm the altitude of the launch site 

shown on the GPS altitude indicator before flight. Prior to each flight, the PIC will reset the 

altimeter to zero and will fly the sUAS below 400 feet AGL. Moreover, the PIC will use the GPS 

altitude indicator to constantly monitor the sUASs height, thus ensuring operation at safe altitudes.

26 See 14 C.F.R. § 91.121.
19

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

The Petitioner seeks an exemption from 14 C.F.R. § 91.151(a)'s fuel requirements for flight 

in VFR conditions. Section 91.151(a) states:

(a) No person may begin 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.27

The battery powering the sUAS provides approximately 25 minutes of powered flight. An 

exemption from the 30 minute reserve requirement in 14 CFR § 91.151 is therefore required.

Equivalent Level of Safety

An equivalent level of safety can be achieved by limiting flights to 45 minutes or 25% of 

battery power, whichever happens first. This restriction would be more than adequate to return the 

sUAS to its planned landing zone from anywhere within its limited operating area. Operation of 

the sUAS with less than 30 minutes of reserve fuel does not engender the type of risks that Section

91.151(a) was intended to alleviate given the size and speed of the small UAS. Moreover, 

operations will be limited to controlled areas where only inspectors or official representatives who 

have signed waivers will be allowed.

This request for exemption falls within the scope of prior exemptions.

28

27 14 C.F.R. § 91.151(a).

28 See e.g. Exemption 10673 (allowing Lockheed Martin Corporation to operate without compliance with

§ 91.151 (a)); see also FAA Exemptions 2689F, 5745, 10673, and 10808.
20

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

Registration.

This petition seeks an exemption from civil aircraft certification and registration 

requirements of 14 C.F.R. §§ 91.203 (a) and (b). The regulations provide in pertinent part:

(a) Except as provided in § 91.715, no person may operate a civil 

aircraft unless it has within it the following:

(1) An appropriate and current airworthiness certificate

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

certificate 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.

29

In addition to the fact that Petitioner is seeking an exemption from the airworthiness 

certificate requirements, an exemption to this regulation is necessary because: (1) the sUAS’s load 

capacity and size does not allow it to carry certification and registration documents; (2) the sUAS 

does not have a cabin or cockpit entrance at which the documents could be displayed; and (3) there 

are no passengers or crew for whom the certificates need be displayed.

Equivalent Level of Safety

To the extent these regulations are applicable to the proposed sUAS operations, an 

equivalent level of safety will be achieved by keeping these documents at the ground control point 

where the pilot flying the sUAS will have immediate access to them.

The FAA has issued numerous exemptions to this regulation. A representative sample of 

other exceptions includes Exemption Nos. 9565, 9665, 9789, 9789A, 9797, 9797A, 9816A, and

10700.
21

M. 14 C.F.R. §§ 91.405(a)(1); 91.407(a)(1); 91.409(a)(1); 91.417(a) and 

(b): Maintenance Inspections

The Petitioner seeks an exemption from the maintenance inspection requirements of 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.

30 An exemption to these

regulations is needed because Part 43 and the stated sections apply only to aircraft with an 

airworthiness certificate, which the sUAS will not have.

Equivalent Level of Safety

An equivalent level of safety will be achieved because maintenance and inspections will 

be performed in accordance with the Aircraft Operations Manual.

31 As provided in the Manual, 

the PIC will ensure that the UAS is in working order prior to initiating flight, oversee and assist in 

performance of required maintenance, and keep a log of any maintenance performed. The PIC is 

the person most familiar with the aircraft and best suited to maintain the aircraft in an airworthy 

condition to provide the equivalent level of safety.

If mechanical issues arise, the sUAS can land immediately and will be operating from no 

higher than 400 feet AGL. Moreover, the sUAS's small size, carrying capacity, and the fact that 

flight operations will only take place in restricted areas for limited periods of time, create less risk 

than the same factors associated with conventional fixed-wing aircraft and rotorcraft performing 

the same operation.

29 14 C.F.R. §§ 91.203 (a) and (b).

30 See e.g. 14 C.F.R. § 91.405(a) (stating that each owner or operator of an 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”).
22

VI. PUBLIC INTEREST

Consistent with the requirements of 14 C.F.R. § 11.81(d), Petitioner offers the following 

reasons why granting this petition for exemption isin the public interest, i.e., how granting it would 

benefit the public as a whole. Approval of exemptions allowing commercial operations of small 

and lightweight sUAS in the infrastructure inspection industry benefits the public as a whole in 

several ways.

First, granting the Petitioner’s exemption helps fulfill Congress' goal in passing Section

333(a) through (c) of the Reform Act, namely, the FAA Administrator's assessment of whether 

certain UAS may operate safely in the National Airspace System before completion of the rule 

making required under Section 332 of the Reform Act.

Next, the Petitioner’s proposed operation significantly improves safety and reduces risk 

concerning infrastructure inspection by alleviating human exposure to dangers associated with 

current aerial survey and inspection methods. Manned helicopters performing utility-power 

generation inspections and patrols have experienced an exceedingly high number of accidents and 

fatalities.

Other bridge inspection methods include utilizing a mobile inspection platform to lower 

inspectors over the side of the bridge. To employ this method, inspectors coordinate with the state 

department of transportation to close a lane of traffic for the length of the bridge. Placing a static 

vehicle in a lane next to moving traffic is particularly hazardous to motorists and the inspectors 

alike and has caused serious traffic incidents in the past.

Petitioner's sUASs are battery powered and create no emissions. If Petitioner's sUAS 

crashes, there is no fuel to ignite and explode. Any impact of Petitioner's lightweight sUASs is far 

less than a full size helicopter. The public's interest is furthered by minimizing ecological impact 

of an accident and by reducing human exposure to potentially harmful emissions associated with 

manned aircraft.

31 See Manual section 4.
24

Finally, aerial surveys are valuable tools for utility-power generation inspections. 

However, problems with safety, cost, statistical integrity, and logistics continue to impede aerial 

surveys and inspections from conventional manned aircraft. The use of sUAS addresses these 

problems and is a powerful tool for performing a wide-range of utility-power generation inspection 

and patrol applications. The public as a whole will benefit from the safer and more cost-effective 

utility aerial services that sUAS operations provide.

VII. PRIVACY

All flights will occur over Operations to be conducted over public or controlled access 

property. Additionally, all flight operations will be conducted in a “Sterile Area” adjacent to the 

bridge as described by the Manual, in which all permissions will be gained by all official

personnel and organizations present in the Sterile Area.

Additionally, the U.S. Supreme Court has held that “‘[a] person traveling in an automobile 

on public thoroughfares has no reasonable expectation of privacy . . . .’”

32 Therefore, Petitioners 

use of sUAS does not pose a privacy threat to motorists traveling on the roadway inadvertently 

captured on video because they have no reasonable expectation of privacy. However, to further 

protect individuals who have had their image captured during an inspection, the Petitioner will 

sanitize the likenesses of individuals from the final product provided to the customer.
25

VIII. FEDERAL REGISTER SUMMARY

A. 14 C.F.R. Part 21, Subpart H - Airworthiness Certificates and 14 C.F.R. § 91.203(a)(1). 

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

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

45.27(a).

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

Command.

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

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

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

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

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

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

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

` L. 14 C.F.R. § 91.203(a) and (b): Carrying Civilian Aircraft Certification and Registration.

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

Inspections

32 U.S. v. Jones, 132 132 S.Ct. 945 (2012) quoting U.S. v. Knotts, 460 U.S. 276, 281 (1983).
26

IX. CONCLUSION

The Petitioner moves the FAA Administrator to grant this exemption. Given the foregoing, 

the Petitioner’s proposed usage does not pose a hazard to the NAS or to the public. Considering 

the clear statutory language in Section 333 of the Reform Act, the authority contained in the 

Federal Aviation Act, as amended, the equivalent level of safety to the public and to the men and 

women conducting infrastructure inspections, and the reduction in environmental effects, the grant 

of the requested exemptions is in the public interest. Accordingly, Petitioner respectfully requests 

that the FAA grant the requested exemption without delay.

Submitted on June 29, 2015 by:

Frederick H. Meek

Frederick H. Meek,

6848 Sundrop Street

Harmony, FL 34773

407-902-7100