Iron Bay Model Company Section 333 UAV Exemption Request

1

February 29, 2016

U.S. Department of Transportation

Docket Management System

1200 New Jersey Ave., SE 

Washington, DC 20590

RE: Exemption Request Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 

(FMRA), 49 U.S.C. § 44701(f), and Part 11 of the Federal Aviation Regulations 

Dear Madam/Sir,

Pursuant to Section 333 of PL 112-95 commonly known as the “FAA Modernization and Reform Act of 

2012”, Iron Bay Model Company hereby applies for authorization to conduct commercial unmanned aerial 

systems (UAS) operations for the purposes of aerial photography & videography, aerial inspection, 

mapping, agricultural surveillance, data collection, real estate marketing, and other non-recreational

activities.

Respectfully submitted,

John Craig

President 

Iron Bay Model Company

155 Redwood Drive

Washington, PA 15301

724-554-8879

jcraig@iron-bay
Iron Bay Model Company Section 333 UAV Exemption Request

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Table of Contents

I. Operators Name and Address

II. Exemptions Requested and Reasons for Relief

III. Public Interest 

IV. Proposed Operation 

V. Make and Model, Unmanned Aircraft System (UAS) 

VI. Summary 

VII. Glossary of Abbreviations
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I. Operators Name and Address

John Craig

Iron Bay Model Company

155 Redwood Drive

Washington, PA 15301

724-554-8879

jcraig@iron-bay

II. Exemptions Requested

Pursuant to 14 C.F.R. § 11.81(e), Iron Bay Model Company requests exemption from the following 

regulations:

 14 C.F.R. Part 21 Subpart H

 14 C.F.R. § 45.23(b)

 14 C.F.R. § 61.101, 61.113 and 61.133(a)(1)(ii)

 14 C.F.R. § 91.7(a)

 14 C.F.R. 91.9(b)

 14 C.F.R. § 91.103

 14 C.F.R. § 91.109(a)

 14 C.F.R. § 91.119

 14 C.F.R. § 91.121

 14 C.F.R. § 91.151(a)

 14 C.F.R. § 91.203(a) & (b)

 14 C.F.R. § 91.215(b)

 14 C.F.R. § 91.405(a)

 14 C.F.R. § 91.407(a)(1)

 14 C.F.R. § 91.409(a)(2)

 14 C.F.R. § 91.417(a) & (b)

 14 C.F.R. Part 21 Subpart H – Airworthiness Certificates

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

91.203(a)(1).

Given the characteristics of the UAS and safeguards outlined below, with consideration of the 

size, weight, speed, operational capability of the particular UAS, as well as location of operation, 

lack of explosive materials, lack of flammable liquid fuels, inability to carry a substantial load, 

operation exclusively within a secured area, carrying neither a pilot nor passenger, tightly 

controlled and monitored by both the operator and observer; a greater degree of safety is 

provided to the public and property owners than conventional operations conducted with 

airworthiness certificates issued under 14 C.F.R. Part 21, Sub part H.

 14 C.F.R. § 45.23(b) – Aircraft Marking and Identification Requirements

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 
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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. 

Compliance with § 45.29(f) to meet the intent of the regulation will be achieved by displaying the 

registration number in the largest practicable lettering.

 14 C.F.R. 61.113 (a)(b) and 61.133(a)(1)(ii) and 61.101 – Recreational, Private and

Commercial Pilot Privilege and Limitations 14 C.F.R. § 61.113

(a) Except as provided in paragraphs (b) through (g) 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 14 C.F.R. § 61.133: (a) Privileges – (1) General. A person 

who holds a commercial pilot certificate may act as pilot in command of an aircraft – (ii) For 

compensation or hire, provided the person is qualified in accordance with this part and with the applicable 

parts of this chapter that apply to the operation. 14 C.F.R. § 61.101: (a) A person who holds a recreational 

pilot certificate may not act as pilot in command of an aircraft:

The inherent risks of operating a UAS are far less than in commercial activities outlined in 14 

CFR part 61, et seq., due to the size, weight, speed, operational capability, etc. Currently there 

are no pilot licenses specific to UAS operators, and no current FAA sanctioned pilot license of 

any type requires training with and knowledge of UAS equipment greater than the requirements 

Iron Bay Model Company uses to certify its PICs. Further, a recreational, private, or 

commercial pilot certificate will not ensure RC piloting ability (necessary for remote control UAS 

operation) as the psychomotor skills are different. Therefore, the requirement of any available 

FAA sanctioned pilot license to operate a SUAS does not make a PIC a more competent operator 

than one meeting the requirements of Iron Bay Model Company. Consequently, the very same 

UAS can be legally operated with absolutely no experience, training, license, or certification by 

the average person in the same NAS as long as the flight is of a non-commercial (for hire or 

financial compensation) nature. Therefore the method of operation and safeguards imposed 

provide a greater degree of safety to the public and property owners than conventional 

operations conducted by a certified PIC, or for non-commercial use of UAS. Thus exemption is 

requested from 14 C.F.R. 61.113 (a)(b) and 61.133(a)(1)(ii) and 61.101 – Recreational, Private 

and Commercial Pilot Privilege and Limitations 14 C.F.R. § 61.113:

 14 C.F.R. 91.7(a) – Civil Aircraft Airworthiness

No person may operate a civil aircraft unless it is in an airworthy condition. 

The PIC will conduct daily pre and post flight inspections in accordance with manufacturer’s

maintenance manual(s) and guidance.

During flight, the PIC will adhere to § 91.7(b) and abort air operations immediately upon 

identification of an in-flight emergency or other unsafe condition. By complying with procedures 

outlined by the manufacturer, an equivalent level of safety will be achieved.

 14 C.F.R. 91.9(b) Civil aircraft flight manual, marking, and placard requirements
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(b)(2) prohibits operation of U.S.-registered civil aircraft 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. 

Due to the small size and limited payload capacity of the SUAS, it is not feasible to carry the 

relevant materials on-board the aircraft, therefore to meet the intent of the regulations and 

achieve an equivalent level of safety, all operating documents, manuals, authorizations and 

exemptions will be maintained in a binder co-located with the GCS.

 14 C.F.R. 91.109(a) – Flight Instruction

No 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. 

The majority of SUAS by design are developed with single operational control through the use of 

pre-determined GPS enabled waypoints programmed before or during flight in addition to the 

use of a single hand held transmitter or control station controlled by the PIC. The design does 

not allow for dual controls during flight training and therefore the exemption is requested to train 

operators, build experience, and maintain proficiency. An equal level of safety will be achieved 

by conducting all training in sterile environments. Training sessions will be accomplished 

separately from flights conducted for compensation or hire.

 14 C.F.R. 91.119 (c) – Minimum Safe Altitudes

Except when necessary for takeoff or landing, no person may operate an aircraft below the following 

altitudes: (b) Over any congested area of a city, town, or settlement, or over any open air assembly of 

persons, an altitude of 1,000 feet above the highest obstacle within a horizontal radius of 2,000 feet of the 

aircraft. (c) Over other than congested areas. An altitude of 500 feet above the surface, except over open 

water or sparsely populated areas. In those cases, the aircraft may not be operated closer than 500 feet to 

any person, vessel, vehicle, or structure. (d) Helicopters, powered parachutes, and weight-shift-control 

aircraft. If the operation is conducted without hazard to persons or property on the surface— (1) A 

helicopter may be operated at less than the minimums prescribed in paragraph (b) or (c) of this section, 

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

prescribed for helicopters by the FAA. 

Commercial UAS operations will be conducted at or below the maximum altitude authorized by 

COA. Given the size, weight and lack of fuel; combined with operation limitations listed below, 

the operation will be conducted with a greater level of safety than exists with current manned 

aviation operations.

 14 C.F.R. 91.121 – Altimeter Settings

Each person operating an aircraft shall maintain the cruising altitude or flight level of that aircraft, as the 

case may be, by reference to an altimeter that is set, when operating...

SUAS are equipped with Global Positioning System (GPS), which provide altitude and 

geolocation data to the operator without utilizing an altimeter. Due to this fact, an exemption is

required. GPS are precise within a few feet and combined with fail-safes and a visual observer 

the operation will meet an equivalent level of safety.
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 14 C.F.R. 91.151(a) – Fuel Requirements for Flight in VFR Conditions

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; 

This regulation is written based on the capabilities of a traditional aircraft, which have flight 

times of several hours or greater; therefore, with the majority of SUAS which have flight times of

an hour or less, this regulation would effectively deny the ability of the air vehicle to operate. The 

PIC will achieve an equivalent level of safety by complying with all manufacturer guidelines 

including a low battery failsafe system.

 14 C.F.R. § 91.203 (a) & (b) - Carrying Civil Aircraft Certification and Registration

The regulation provides 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. 

Due to the small size and limited payload capacity of the SUAS, it is not feasible to carry the 

relevant materials on-board the aircraft, therefore to meet the intent of the regulations and 

achieve an equivalent level of safety, the certification and registration documents, will be 

maintained in a binder co-located with the GCS.

 14 C.F.R. 91.215(b) – ATC Transponder and Altitude Reporting Equipment and Use

All airspace. Unless otherwise authorized or directed by ATC, no person may operate an aircraft in the 

airspace described in paragraphs (b)(1) through (b)(5) of this section, unless that aircraft is equipped with 

an operable coded radar beacon transponder having either Mode 3/A 4096 code capability, replying to 

Mode 3/A interrogations with the code specified by ATC, or a Mode S capability, replying to Mode 3/A 

interrogations with the code specified by ATC and intermode and Mode S interrogations in accordance 

with the applicable provisions specified in TSO C-112, and that aircraft is equipped with automatic 

pressure altitude reporting equipment having a Mode C capability that automatically replies to Mode C 

interrogations by transmitting pressure altitude information in 100-foot increments. This requirement 

applies— (1) All aircraft. In Class A, Class B, and Class C airspace areas; (2) All aircraft. In all airspace 

within 30 nautical miles of an airport listed in appendix D, section 1 of this part from the surface upward 

to 10,000 feet MSL; (3) Notwithstanding paragraph (b)(2) of this section, any aircraft which was not 

originally certificated with an engine-driven electrical system or which has not subsequently been 

certified with such a system installed, balloon or glider may conduct operations in the airspace within 30 

nautical miles of an airport listed in appendix D, section 1 of this part provided such operations are 

conducted— (i) Outside any Class A, Class B, or Class C airspace area; and (ii) Below the altitude of the 

ceiling of a Class B or Class C airspace area designated for an airport or 10,000 feet MSL, whichever is 

lower; and (4) All aircraft in all airspace above the ceiling and within the lateral boundaries of a Class B 

or Class C airspace area designated for an airport upward to 10,000 feet MSL; and (5) All aircraft except 

any aircraft which was not originally certificated with an engine-driven electrical system or which has not 

subsequently been certified with such a system installed, balloon, or glider— (i) In all airspace of the 48 

contiguous states and the District of Columbia at and above 10,000 feet MSL, excluding the airspace at 

and below 2,500 feet above the surface; and (ii) In the airspace from the surface to 10,000 feet MSL 

within a 10-nautical-mile radius of any airport listed in appendix D, section 2 of this part, excluding the 

airspace below 1,200 feet outside of the lateral boundaries of the surface area of the airspace designated 
Iron Bay Model Company Section 333 UAV Exemption Request

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for that airport. The SUAS to be used in the proposed operation does not come equipped with a 

transponder. No transponder exists for the SUAS, which can be installed. 

The petitioner requests relief from the exemption to the extent required to operate in areas in 

which a transponder is required according the applicable regulations in this part. The PIC will 

achieve an equivalent level of safety by complying with all provisions of the COA under which 

operations are to be conducted. By ATO coordination and issuing appropriate prior NOTAMS, 

an equivalent level of safety can be achieved as other manned aircraft, which receive 

authorization to fly in airspace where a transponder is required but not operable. In order to give 

proper notice to the ATO, the PIC will comply with the provisions of 91.215(d)(3). The SUAS 

flown under this exemption will comply with all altitude limits and airport standoff distances 

required by COA, which mitigate hazards to aircraft controlled by the ATO in congested 

airspace.

 14 C.F.R. 91.405(a), 91.407(a)(1), 91.409(a)(2) and 91.417(a) & (b) – Maintenance

Inspections 91.405(a) States: Each owner or operator of an aircraft—(a) 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 91.407(a)(1) States: (a) No person may operate any aircraft that has undergone maintenance, 

preventive maintenance, rebuilding, or alteration unless—(1) It has been approved for return to service by 

a person authorized under § 43.7 of this chapter o 91.409(a)(2) States: (a) Except as provided in 

paragraph (c) of this section, no person may operate an aircraft unless, within the preceding 12 calendar 

months, it has had—(2) An inspection for the issuance of an airworthiness certificate in accordance with 

part 21 of this chapter. No inspection performed under paragraph (b) of this section may be substituted for 

any inspection required by this paragraph unless it is performed by a person authorized to perform annual 

inspections and is entered as an ‘‘annual’’ inspection in the required maintenance records. o 91.417(a) & 

(b) States: (a) Except for work performed in accordance with §§ 91.411 and 91.413, each registered 

owner or operator shall keep the following records for the periods specified in paragraph (b) of this 

section: (paragraphs 1 (i – iii), 2 (i – vi)); (b) The owner or operator shall retain the following records for 

the periods prescribed: (paragraphs 1 – 3)

The PIC will conduct Pre/Post flight inspections and maintenance in accordance with the 

manufacturer’s guidance as stated in the operations manual. If maintenance is required, the PIC 

will conduct a dedicated test flight to ensure safety before resuming commercial operations. All 

inspection, maintenance and alterations will be documented and maintained in a record. These 

actions will meet the intent of the regulations from which exemption is being requested and lead 

to an equivalent level of safety.

III. Public Interest

Traditionally, aerial filming for the television and film industries has relied primarily on the use of 

traditional aircraft. These larger combustible-fueled aircraft pose significant risk to the crew, passengers 

and the public in general due to their inherent dangers and the proximity of use to participants. Small 

unmanned aircraft are ideal for the television and film industries, as well as industrial and commercial 

applications because they reduce and/or eliminate much of the inherent danger. SUAS do not carry 

combustible fuel, they have a significantly lesser impact on the environment, are less disruptive, smaller, 

more maneuverable and safer than conventional video and photographic aircraft. When operated 

responsibly, a SUAS utilizes lower altitudes within visual line of sight of the PIC in a predetermined

airspace, and are piloted with aid of high resolution positioning sensors for very high accuracy and 
Iron Bay Model Company Section 333 UAV Exemption Request

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repeatability. These protocols and methods further reduce the risk of personal injury or property damage. 

Since SUASs are unmanned, risk to pilots and crew are practically impossible. In many ways SUASs are 

ideal for the film and television industries and they will likely be responsible for enhancing production 

value in unexpected ways. Granting a 333 exemption to Iron Bay Model Company will reduce the 

reliance on traditional large aircraft for aerial video work and advance safe integration of additional 

SUASs into the NAS, further reducing risk and enhancing public safety. The exemptions requested have 

already been granted to other entities for the same and/or similar purposes, i.e., Exemption No’s.: 11062, 

11109, 11112, 11213, 12645, 13696, 13987, 13999, and 14001. Given the stated evidence, procedures, 

and precautions operating UAS commercially, these operations, when executed with prudence, will 

exceed the current level of safety as the regulations from which exemption is sought. The low expense of 

operation compared to cost prohibitive manned aviation alternatives allow a greater economic benefit to 

businesses. UAS technology used for commercial purposes benefit the public interest by reducing the 

collateral damage risks to life and property and noise associated with low altitude fixed wing and 

helicopter operations, increased economic well-being to local businesses via cost reductions, and enabling 

aerial business solutions to be available to a larger market. For these reasons, granting an exemption 

under FMRA Section 333(c) is in the public interest.

IV. Proposed Operation:

Iron Bay Model Company is seeking 333 exemption for use of a SUAS for closed-set film operations for 

film and television production, on-location film or television operations, aerial video support for films 

and commercials in controlled environments; augmentation of real-estate listing videos, creation of visual 

and topographical layout videos for state and local agencies, academic activities, special event coverage, 

emergency and first responder situations, agricultural inspections, building and construction zone 

inspections, and other commercial applications. The SUAS will be flown via a combination of RC 

control and tablet, laptop, or smart phone based GCS. This SUAS type is a GPS/Autopilot equipped, 

multirotor helicopter, utilizing electric motors and lithium-polymer batteries. The SUAS has several failsafes for loss of RC signal, loss of GPS, and low battery. The SUAS displays visual, and emits an audible 

low battery alert. If the SUAS loses communication with the PIC or loses its GPS signal, the SUAS 

automatically returns to a pre-determined location within the Security Perimeter and lands autonomously. 

The SUAS also has the ability to perform an emergency abort in case of unpredicted obstacles, weather, 

or other situations which may compromise safety.

Operating Standards

1. All operating documents, flight logs, manuals, authorizations, certifications, exemptions, etc., 

will be maintained and co-located with the GCS to provide full transparency to the FAA, 

State, and Local authorities.

2. The PIC designated for any operation will have at least a Class 2 medical certificate or valid 

Driver’s License.

3. Minimum crew for each operation will consist of the PIC, and the Visual Observer.

4. PIC and Visual Observer will have been trained in the operation of the specific SUAS 

equipment used and have up-to-date information on the particular SUAS to be operated.

5. Potential obstructions or other hazards to safe operation will be identified by the crew at each 

location. 

6. A comprehensive worksite inspection and analysis, identifying limits of customer property or 

authorized access areas will be conducted. 

7. Flights will be operated at an altitude of no more than 400 feet AGL or, not more than 200 

feet above an elevated platform from which filming is planned. If a structure being filmed or 
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photographed has a height which exceeds 400 feet AGL, the UAS will not exceed 100 feet in 

height above the highest point on that structure. 

8. Flights will be operated at a lateral distance of at least 100 feet from any inhabited structures, 

buildings, vehicles, vessels, or people not associated with the operation or who have not 

signed a waiver in advance of the operation.

9. The operator will obtain the consent of all persons involved in the filming and ensure that 

only consenting persons will be allowed within 100 feet of the flight operation. This radius 

may be reduced for specific circumstances based upon an equivalent level of safety 

determination.

10. The PIC will coordinate all activity with the controlling air traffic organization to issue 

appropriate prior NOTAM, and advise the appropriate FSDO with relevant details of the 

intended activity.

11. The PIC will conduct a preflight safety briefing with all personnel involved with the 

operational duties of the flight.

12. The PIC will operate in those areas only with the consent of the landowner or designated 

representative.

13. The PIC will at all times yield to manned air traffic.

14. The PIC will operate within VLOS of both PIC and VO during daylight hours only.

15. The PIC will maintain voice communications with VO and participating persons.

16. The PIC will operate under visual flight rules, in visual meteorological conditions, for the 

airspace in which the flight is conducted.

17. The PIC will not exceed the maximum altitude as defined in the COA under which flight 

authorized, as determined by the installed GPS.

18. The PIC will terminate flight, in the safest manner possible, when unable to comply with 

these limitations or any other limitations granted as part of this exemption.

19. The PIC will terminate flight, in the safest manner possible, when safety to persons or 

property become compromised.

20. All required permissions and permits will be obtained from territorial, state, county or city 

jurisdictions including local law enforcement, fire or other appropriate government agencies. 

21. If the SUAS loses communication with the PIC or loses its GPS signal, the SUAS will have 

the capability to return to a pre-determined location within the Security Perimeter and land 

autonomously.

22. The SUAS will have the capability to perform an emergency abort in case of unpredicted 

obstacles, weather, or other situations which may compromise safety.

By following these operating standards, the commercial operation will meet an equivalent level of 

safety to the regulation in which relief is sought.

V. Make and Model Unmanned Aircraft System (UAS) 

The petitioner seeks exemption to operate a commercially produced Arris M1100 UAS. The Arris

M1100 is vertical takeoff and landing (VTOL) Unmanned Aircraft (UA) with a Ground Control Station 

(GCS) utilizing a conventional R/C Transmitter, and electronic tablet, laptop computer system, or smart 

phone. The ARRIS M1100 has a maximum gross weight of approximately 12 lbs., a diagonal dimension 

of 1100mm, and maximum speed of approximately 16 fps. The Arris M1100 is equipped with eight 

rotors positioned equidistant around the perimeter; driven by Lithium Polymer battery powered electric 

motors. Octocopters such as the Arris M1100 are typically safer than comparable quadcopters due to the 

reduced effect that a motor failure causes. Octocopters can remain aloft and controllable even with the 

loss of two motors, while a single motor failure will immediately ground a quadcopter. The Arris M1100 

utilizes the popular ArduPilot APM UAV controller and Mission Planner software. The controller is a 
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mature, commercially produced, full-featured, open source multicopter UAV controller capable of a full 

range of flight requirements including multiple fail-safes which can be programmed through one of the 

ground station systems described. For instance: safety functions such as auto-return to launch point, 

emergency hover, emergency stop etc., can be programmed through any one of these systems.

Controller Specifications

 14 PWM/servo outputs (8 with failsafe and manual override, 6 auxiliary, high-power compatible)

 Abundant connectivity options for additional peripherals (UART, I2C, CAN)

 Integrated backup system for in-flight recovery and manual override with dedicated processor and 

stand-alone power supply

 Backup system integrates mixing, providing consistent autopilot and manual override mixing 

modes

 Redundant power supply inputs and automatic failover

 External safety button for easy motor activation

 Multicolor LED indicator

 High-power, multi-tone piezo audio indicator

 microSD card for long-time high-rate logging

Microprocessors (2)

 ATMEGA2560 

 ATMEGA32U-2 

Sensors

 ST Micro L3GD20 3-axis 16-bit gyroscope

 ST Micro LSM303D 3-axis 14-bit accelerometer / magnetometer

 Invensense MPU 6000 3-axis accelerometer/gyroscope

 MEAS MS5611-01BA03 barometer

 Neo-6M GPS module with compass ic

Programming of the autopilot is accomplished through Mission Planner software. Mission Planner is a 

full-featured ground station application for the ArduPilot family of open source autopilot projects. Rather 

than rely on a traditional printed Operation Manual, extensive documentation and resources in the form of 

video tutorials, operation manuals, discussion groups etc., are available on the internet for the ArduPilot 

family of products, software, and development tools.

 

Mission Planner features: 

 Point-and-click waypoint entry, using Google Maps/Bing/Open street maps/Custom WMS.

 Select mission commands from drop-down menus

 Download mission log files and analyze them

 Configure APM settings for your airframe

 Interface with a PC flight simulator to create a full hardware-in-the-loop UAV simulator.

 Output can be seen through APM’s serial terminal

VI. Summary

Pursuant to 14 C.F.R. Part 11, the following summary is provided for publication in the Federal Register, 

should it be determined that publication is needed: 
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Applicant seeks an exemption from the following rules: 14 C.F.R. § 21, subpart H; 14 C.F.R 45.23 (b); 14 

C.F.R. § 61.101, 61.113 and 61.133(a)(1)(ii); 91.7 (a); 91.9 (b); 91.103; 91.109(a); 91.119; 91.121; 

91.151(a); 91.203 (a) and (b); 91.405 (a); 91.407 (a)(1); 91.409 (a)(2); and 91.417 (a) & (b) to operate 

commercially a small unmanned aircraft (55 lbs. or less) for airborne activities including video and 

inspection services. The SUASs will carry no passengers or crew and, therefore, will not expose them to 

the risks associated with manned aircraft flights. The operation of small UASs, weighting less than 55 

lbs., conducted in the strict conditions outlined will provide an equivalent level of safety supporting the 

grant of the exemptions requested herein, including exempting the applicant from the requirements of Part 

21 and allowing commercial operations. Satisfaction of the criteria provided in Section 333 of the 

Reform Act of 2012--size, weight, speed, operating capabilities, proximity to airports and populated areas 

and operation within visual line of sight and national security – provide more than adequate justification 

for the grant of the requested exemptions allowing commercial operation of applicant’s SUAS equipment 

for commercial purposes.

VII. Glossary of Abbreviations: 

AGL Above Ground Level 

AOI Area of Interest 

ATC Air Traffic Control 

ATO Air Traffic Organization 

AV Aerial Vehicle 

CFR Code of Federal Regulations 

COA Certificate of Authorization 

FAA Federal Aviation Administration 

FAR Federal Aviation Regulation 

FMRA Section 333 FAA Modernization and Reform Act of 2012

GCS Ground Control Station 

GPS Global Positioning System 

LOL Loss of Link 

NAS National Airspace System 

NOTAM Notice to Airman 

PIC Pilot In Command 

SO Safety Observer 

SOP Standard Operating Procedures

SUAS Small Unmanned Aircraft System

UA Unmanned Aircraft 

UAS Unmanned Aircraft System 

VFR Visual Flight Rules 

VLOS Visual Line of Site 

VMC Visual Meteorological Conditions

VTOL Vertical Takeoff and Landing