August 10, 2015

Exemption No. 12402

Regulatory Docket No. FAA–2015–1536

Mr. Stephen C. Gowdy

Gowdy Brothers Aerospace

1540 Yorkshire Lane

Shakopee, MN 55379

Dear Mr. Gowdy:

This letter is to inform you that we have granted your request for exemption. It transmits our 

decision, explains its basis, and gives you the conditions and limitations of the exemption, 

including the date it ends.

By letter dated April 30, 2015, you petitioned the Federal Aviation Administration (FAA) on 

behalf of Gowdy Brothers Aerospace (hereinafter petitioner or operator) for an exemption. 

The petitioner requested to operate an unmanned aircraft system (UAS) to conduct aerial 

videography, photography, and inspections.

See Appendix A for the petition submitted to the FAA describing the proposed operations and 

the regulations that the petitioner seeks an exemption.

The FAA has determined that good cause exists for not publishing a summary of the petition 

in the Federal Register because the requested exemption would not set a precedent, and any 

delay in acting on this petition would be detrimental to the petitioner.

Airworthiness Certification

The UAS proposed by the petitioner is a Carbon Core Octocopter and HH Blade 350QX3.

In accordance with the statutory criteria provided in Section 333 of Public Law 112−95 in 

reference to 49 U.S.C. § 44704, and in consideration of the size, weight, speed, and limited 

operating area associated with the aircraft and its operation, the Secretary of Transportation 

has determined that this aircraft meets the conditions of Section 333. Therefore, the FAA 
2

finds that relief from 14 CFR part 21, Certification procedures for products and parts, 

Subpart H—Airworthiness Certificates, and any associated noise certification and testing 

requirements of part 36, is not necessary.

The Basis for Our Decision

You have requested to use a UAS for aerial data collection1. The FAA has issued grants of 

exemption in circumstances similar in all material respects to those presented in your petition. 

In Grants of Exemption Nos. 11062 to Astraeus Aerial (see Docket No. FAA−2014−0352), 

11109 to Clayco, Inc. (see Docket No. FAA−2014−0507), 11112 to VDOS Global, LLC (see

Docket No. FAA−2014−0382), and 11213 to Aeryon Labs, Inc. (see Docket No. 

FAA−2014−0642), the FAA found that the enhanced safety achieved using an unmanned 

aircraft (UA) with the specifications described by the petitioner and carrying no passengers or 

crew, rather than a manned aircraft of significantly greater proportions, carrying crew in 

addition to flammable fuel, gives the FAA good cause to find that the UAS operation enabled 

by this exemption is in the public interest.

Having reviewed your reasons for requesting an exemption, I find that—

 They are similar in all material respects to relief previously requested in Grant of 

Exemption Nos. 11062, 11109, 11112, and 11213;

 The reasons stated by the FAA for granting Exemption Nos. 11062, 11109, 11112, and 

11213 also apply to the situation you present; and 

 A grant of exemption is in the public interest.

Our Decision

In consideration of the foregoing, I find that a grant of exemption is in the public interest. 

Therefore, pursuant to the authority contained in 49 U.S.C. 106(f), 40113, and 44701, 

delegated to me by the Administrator, Gowdy Brothers Aerospace is granted an exemption 

from 14 CFR §§ 61.23(a) and (c), 61.101(e)(4) and (5), 61.113(a), 61.315(a), 91.7(a), 

91.119(c), 91.121, 91.151(a)(1), 91.405(a), 91.407(a)(1), 91.409(a)(1) and (2), and 91.417(a) 

and (b), to the extent necessary to allow the petitioner to operate a UAS to perform aerial data 

collection. This exemption is subject to the conditions and limitations listed below.

Conditions and Limitations

In this grant of exemption, Gowdy Brothers Aerospace is hereafter referred to as the operator.

 

1 Aerial data collection includes any remote sensing and measuring by an instrument(s) aboard the UA. 

Examples include imagery (photography, video, infrared, etc.), electronic measurement (precision surveying, RF 

analysis, etc.), chemical measurement (particulate measurement, etc.), or any other gathering of data by 

instruments aboard the UA.
3

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.

1. Operations authorized by this grant of exemption are limited to the Carbon Core 

Octocopter and HH Blade 350QX3 when weighing less than 55 pounds including 

payload. Proposed operations of any other aircraft will require a new petition or a 

petition to amend this exemption.

2. Operations for the purpose of closed-set motion picture and television filming are 

not permitted. 

3. The UA may not be operated at a speed exceeding 87 knots (100 miles per hour). The 

exemption holder may use either groundspeed or calibrated airspeed to determine 

compliance with the 87 knot speed restriction. In no case will the UA be operated at 

airspeeds greater than the maximum UA operating airspeed recommended by the 

aircraft manufacturer.

4. The UA must be operated at an altitude of no more than 400 feet above ground level 

(AGL). Altitude must be reported in feet AGL.

5. The UA must be operated within visual line of sight (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 airman medical certificate or 

U.S. driver’s license.

6. All operations must utilize a visual observer (VO). The UA must be operated within 

the visual line of sight (VLOS) of the PIC and VO at all times. The VO may be used 

to satisfy the VLOS requirement as long as the PIC always maintains VLOS 

capability. The VO and PIC must be able to communicate verbally at all times; 

electronic messaging or texting is not permitted during flight operations. The PIC 

must be designated before the flight and cannot transfer his or her designation for the 

duration of the flight. The PIC must ensure that the VO can perform the duties 

required of the VO.

7. This exemption and all documents needed to operate the UAS and conduct its 

operations in accordance with the conditions and limitations stated in this grant of 

exemption, are hereinafter referred to as the operating documents. The operating 

documents must be accessible during UAS operations 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 the operating documents, 

the conditions and limitations herein take precedence and must be followed. 

Otherwise, the operator must follow the procedures as outlined in its operating 

documents. The operator may update or revise its operating documents. It is the 

operator’s responsibility to track such revisions and present updated and revised 
4

documents to the Administrator or any law enforcement official upon request. The 

operator must also present updated and revised documents if it petitions for extension 

or amendment to this grant of exemption. If the operator determines that any update 

or revision would affect the basis upon which the FAA granted this exemption, then 

the operator must petition for an amendment to its grant of exemption. The FAA’s 

UAS Integration Office (AFS−80) may be contacted if questions arise regarding 

updates or revisions to the operating documents.

8. Any UAS that has undergone maintenance or alterations that affect the UAS operation 

or flight characteristics, e.g., replacement of a flight critical component, must undergo 

a functional test flight prior to conducting further operations under this exemption. 

Functional test flights may only be conducted by a PIC with a VO and must remain at 

least 500 feet from other people. The functional test flight must be conducted in such 

a manner so as to not pose an undue hazard to persons and property.

9. The operator is responsible for maintaining and inspecting the UAS to ensure that it is 

in a condition for safe operation.

10. Prior to each flight, the PIC must conduct a pre-flight inspection and determine the 

UAS is in a condition for safe flight. The pre-flight inspection must account for all 

potential discrepancies, e.g., inoperable components, items, or equipment. If the 

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

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

UAS is found to be in a condition for safe flight.

11. The operator must follow the UAS manufacturer’s maintenance, overhaul, 

replacement, inspection, and life limit requirements for the aircraft and 

aircraft components.

12. Each UAS operated under this exemption must comply with all manufacturer 

safety bulletins.

13. Under this grant of exemption, a PIC must hold either an airline transport, 

commercial, private, recreational, or sport pilot certificate. The PIC must also hold a 

current FAA airman medical certificate or a valid U.S. driver’s license issued by a 

state, the District of Columbia, Puerto Rico, a territory, a possession, or the Federal 

government. The PIC must 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.

14. The operator may not permit any PIC to operate unless the PIC demonstrates the 

ability to safely operate the UAS in a manner consistent with how the UAS will be 

operated under this exemption, including evasive and emergency maneuvers and 

maintaining appropriate distances from persons, vessels, vehicles and structures. PIC 

qualification flight hours and currency must be logged in a manner consistent with 
5

14 CFR § 61.51(b). Flights for the purposes of training the operator’s PICs and VOs 

(training, proficiency, and experience-building) and determining the PIC’s ability to 

safely operate the UAS in a manner consistent with how the UAS will be operated 

under this exemption are permitted under the terms of this exemption. However, 

training operations may only be conducted during dedicated training sessions. During 

training, proficiency, and experience-building flights, all persons not essential for 

flight operations are considered nonparticipants, and the PIC must operate the UA 

with appropriate distance from nonparticipants in accordance with 14 CFR § 91.119.

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

operations must be conducted under visual meteorological conditions (VMC). Flights 

under special visual flight rules (SVFR) are not authorized.

16. The UA may not operate within 5 nautical miles of an airport reference point (ARP) as 

denoted in the current FAA Airport/Facility Directory (AFD) or for airports not 

denoted with an ARP, the center of the airport symbol as denoted on the current 

FAA-published aeronautical chart, unless a letter of agreement with that airport’s 

management is obtained or otherwise permitted by a COA issued to the exemption 

holder. The letter of agreement with the airport management must be made available 

to the Administrator or any law enforcement official upon request.

17. The UA may not be operated less than 500 feet below or less than 2,000 feet 

horizontally from a cloud or when visibility is less than 3 statute miles from the PIC.

18. If the UAS loses communications or loses its GPS signal, the UA must return to a 

pre-determined location within the private or controlled-access property.

19. The PIC must abort the flight in the event of unpredicted obstacles or emergencies.

20. The PIC is prohibited from beginning a flight unless (considering wind and forecast 

weather conditions) there is enough available power for the UA to conduct the 

intended operation and to operate after that for at least five minutes or with the reserve 

power recommended by the manufacturer if greater.

21. Air Traffic Organization (ATO) Certificate of Waiver or Authorization (COA). All 

operations shall be conducted in accordance with an ATO-issued COA. The 

exemption holder may apply for a new or amended COA if it intends to conduct 

operations that cannot be conducted under the terms of the attached COA.

22. All aircraft operated in accordance with this exemption must 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 must 

be as large as practicable.
6

23. Documents used by the operator to ensure the safe operation and flight of the UAS and 

any documents required under 14 CFR §§ 91.9 and 91.203 must be available to the 

PIC at the Ground Control Station of the UAS any time the aircraft is operating. 

These documents must be made available to the Administrator or any law enforcement 

official upon request.

24. The UA must remain clear and give way to all manned aviation operations and 

activities at all times. 

25. The UAS may not be operated by the PIC from any moving device or vehicle. 

26. All Flight operations must be conducted at least 500 feet from all nonparticipating 

persons, vessels, vehicles, and structures unless:

a. Barriers or structures are present that sufficiently protect nonparticipating persons 

from the UA and/or debris in the event of an accident. 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 in a manner ensuring the safety 

of nonparticipating persons; and

b. The owner/controller of any vessels, vehicles or structures has granted permission 

for operating closer to those objects and the PIC has made a safety assessment of 

the risk of operating closer to those objects and determined that it does not 

present an undue hazard.

The PIC, VO, operator trainees or essential persons are not considered 

nonparticipating persons under this exemption.

27. All operations shall be conducted over private or controlled-access property with 

permission from the property owner/controller or authorized representative. 

Permission from property owner/controller or authorized representative will be 

obtained for each flight to be conducted.

28. Any incident, accident, or flight operation that transgresses the lateral or vertical 

boundaries of the operational area as defined by the applicable COA must be reported 

to the FAA's UAS Integration Office (AFS−80) within 24 hours. Accidents must be 

reported to the National Transportation Safety Board (NTSB) per instructions 

contained on the NTSB Web site: www.ntsb.gov.

If this exemption permits operations for the purpose of closed-set motion picture and 

television filming and production, the following additional conditions and limitations apply.

29. The operator must have a motion picture and television operations manual (MPTOM) 

as documented in this grant of exemption.
7

30. At least 3 days before aerial filming, the operator of the UAS affected by this 

exemption must submit a written Plan of Activities to the local Flight Standards

District Office (FSDO) with jurisdiction over the area of proposed filming. The 3-day 

notification may be waived with the concurrence of the FSDO. The plan of activities 

must include at least the following:

a. Dates and times for all flights;

b. Name and phone number of the operator for the UAS aerial filming conducted 

under this grant of exemption;

c. Name and phone number of the person responsible for the on-scene operation of 

the UAS;

d. Make, model, and serial or N−Number of UAS to be used;

e. Name and certificate number of UAS PICs involved in the aerial filming;

f. A statement that the operator has obtained permission from property owners 

and/or local officials to conduct the filming production event; the list of those 

who gave permission must be made available to the inspector upon request;

g. Signature of exemption holder or representative; and

h. A description of the flight activity, including maps or diagrams of any area, city, 

town, county, and/or state over which filming will be conducted and the altitudes 

essential to accomplish the operation.

31. Flight operations may be conducted closer than 500 feet from participating persons 

consenting to be involved and necessary for the filming production, as specified in the 

exemption holder’s MPTOM.

Unless otherwise specified in this grant of exemption, the UAS, the UAS PIC, and the UAS 

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

parts 45, 47, 61, and 91.

This exemption terminates on August 31, 2017, unless sooner superseded or rescinded.

Sincerely,

/s/

John S. Duncan

Director, Flight Standards Service

Enclosures
Gowdy	Brothers	Aerospace,	LLC						Section	333	Exemption	Submission	version	1.0						April	30,	2015 Page	1

UNITED	STATES	OF	AMERICA	

DEPARTMENT	OF	TRANSPORTATION	

FEDERAL	AVIATION	ADMINISTRATION

WASHINGTON,	DC

IN	THE	MATTER	OF	THE	PETITION	FOR	EXEMPTION	OF:	

GOWDY	BROTHERS	AERSPACE

FOR	AN	EXEMPTION	SEEKING	RELIEF	FROM	

THE	REQUIREMENTS	OF	TITLE	14	OF	

THE	CODE	OF	FEDERAL	REGULATIONS	

SECTIONS	61.113(a)	&	(b),	91.7(a),	91.121,	91.151(b),	91.405(a),	91.407(a)(1), 91.409(a)(1)	&	

(a)(2),	AND	91.417(a)	&	(b)	CONCERNING	

COMMERCIAL	OPERATION	OF	CARBON	CORE	OCTOCOPTER/HH	BLADE	350QX3 AP	

UNMANNED AIRCRAFT	SYSTEMSPURSUANT	TO	SECTION	333	OFTHE	FAA	MODERNIZATION	

AND	REFORM	ACT	OF	2012	(PUBLIC	LAW	112-95)

Submitted	on	April	30,	2015	

Gowdy	Brothers	Aerospace	

1540	Yorkshire	Lane,	

Shakopee,	MN	55379	

763-496-9551

Steve@GowdyBrothers.com
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TABLE	OF	CONTENTS	 																					Page	

GLOSSARY	OF	ABBREVIATIONS................................................................................................................................. 3

SUMMARY............................................................................................................................................................................. 4

INTRODUCTION	AND	INTERESTS	OF THE	PETITIONER................................................................................ 4

BACKGROUND..................................................................................................................................................................... 5

BASIS	FOR	PETITION....................................................................................................................................................... 5

Name	and	Address	of	Petitioner ................................................................................................................................. 7

A.	Name	And	Address	Of	The	Petitioner................................................................................................................................. 7

B.	The	Specific	Sections	Of	14	C.F.R.	From	Which	Gowdy	Brothers	Aerospace	seeks	Exemption ................ 7

1.	Gowdy	Brothers	Aerospace	Seeks	Exemption	From	The	Requirements	Of	Section	61.113(a)	And	

(b)....................................................................................................................................................................................................... 7

2.	Gowdy	Brothers	Aerospace	Seeks	Exemption	From	The	Requirements	Of	Section	91.7(a). ................ 8

3.	Gowdy	Brothers	Aerospace	Seeks	Exemption	From	The	Requirements	Of	Section	91.121.................. 8

4.	Gowdy	Brothers	Aerospace	Seeks	Exemption	From	The	Requirements	Of	Section	91.151(b). .......... 8

5.	Gowdy	Brothers	Aerospace	Seeks	Exemption	From	The	Requirements	Of	Section	91.405	(a)........... 9

6.	Gowdy	Brothers	Aerospace	Seeks	Exemption	From	The	Requirements	Of	Section	91.407(a)(1)..... 9

7.	Gowdy	Brothers	Aerospace	Seeks	Exemption	From	The	Requirements	Of	Sections	91.409(a)(1)	

And	91.409(a)(2)........................................................................................................................................................................ 9

8.	Gowdy	Brothers	Aerospace	Seeks	Exemption	From	The	Requirements	Of	Sections	91.417(a)	And	

91.417(b)........................................................................................................................................................................................ 9

C.	The	Extent	Of	Relief	Gowdy	Brothers	Aerospace	Seeks	And	The	Reason	Gowdy	Brothers	Aerospace	

Seeks	The	Relief..............................................................................................................................................................................10

D.	The	Reasons	Why	Granting	Gowdy	Brothers	Aerospace	Request	Would	Be	In	The	Interest;	That	Is,	

How	It	Would	Benefit	The	Public	As	A	Whole. ................................................................................................................13

E.	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	Gowdy	Brothers	Aerospace	Seeks	Exemption..................................................................................................15

F.	A	Summary	That	Can	Be	Published	In	The	Federal	Register	stating:	The	Rules	From	Which	Gowdy	

Brothers	Aerospace	Seeks	Exemption: ...............................................................................................................................25

G.	Any	Additional	Information,	Views,	Or	Arguments	Available	To	Support	Gowdy	Brothers	Aerospace's	

Request. ..............................................................................................................................................................................................25

CONCLUSION.....................................................................................................................................................................25

APPENDICES:.....................................................................................................................................................................27

A	- CCO	w/Wkm	M	TECHNICAL	SPECIFICATIONS .....................................................................................28

B	- HH	Blade	350QX3	AP	TECHNICAL	SPECIFICATIONS .........................................................................29

C	- DJI	Wkm	M	– Manufacturer's	User	Manual..............................................................................................30

D	- HH	Blade	350QX3	AP	Manufacturer’s	User	Manual............................................................................31

E	- Gowdy	Brothers	Aerospace	Monthly	Maintenance	and	Repair	Log.............................................32
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GLOSSARY	OF	ABBREVIATIONS

AGL

AOI

ATC

ATO

AV

CCO

CFR

COA

FAA

FAR

GCS

GPS

HH

LOL

NAS

NOTAM

PIC

Section	333

SO

SOP

UA

UAS

VFR

VLOS

VMC

VTOL

Wkm	M

Above	Ground	Level

Area	of	Interest

Air	Traffic	Control

Air	Traffic	Organization

Aerial	Vehicle

Carbon	Core	Octocopter

Code	of	Federal	Regulations

Certificate	Of	Authorization

Federal	Aviation	Administration

Federal	Aviation	Regulation

Ground	Control	Station

Global	Positioning	System

Horizon	Hobby	Blade	350QX3AP

Loss	Of	Link

National	Airspace	System

Notice	To	Airman

Pilot	In	Command

FAA	Modernization	and	Reform	

Act	of 2012	(FMRA)	Section	333

Safety	Observer

Standard	Operating	Procedures

Unmanned	Aircraft

Unmanned	Aircraft	System

Visual	Flight	Rules

Visual	Line	Of	Site

Visual	Meteorological	Conditions

Vertical	Take-Off	and	Landing

DJI	Flight	Control	System
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SUMMARY

Gowdy	Brothers	Aerospace	seeks	exemption	from	the	requirements	of	14	C.F.R	§§	61.113(a)	&	(b),	

91.7(a),	91.121,	91.151(b),	91.405(a),	91.407(a)(1),	91.409(a)(1)	&	(a)	(2),	and	91.417(a)	&	(b),	to	

operate	an	Unmanned	Aircraft	System	pursuant	to	Section	333	of	the	FAA	Modernization	and	Reform	

Act	of	2012	(FMRA).	This	exemption	will	permit	to	operate	an	Unmanned	Aircraft	System	(UAS)	for	

the	 commercial	 purposeof	 inspecting	 bridges	 and	 conducting	 aerial	 video	 and	 photography	 of	

construction	sites,	real	estate	and	landscape	over	certain	areas	of	the	United	States.	

INTRODUCTION	AND	INTERESTS	OF	THE	PETITIONER

Gowdy	Brothers	Aerospace,	LLC	is	made	up	of	four	Gowdy	Brothers,	additional	family,	friends	and	

employees,	who	between	them	have	 education	 and	 experience	 as	follows:	 an	MBA,	two	Doctorate	

degrees	in	Business	Administration	and	Education,	an	FAA	Certified	Private	Pilot	since	1997	and	a	

past	owner	of	a	1972	Cessna	Skyhawk	172,	and	a	FAA	Certified	Airframe	and	Powerplant	Mechanic,	

30+	years	experience,	Air	Force,	Air	National	Guard,	Department	of	Homeland	Security	and	over	50+	

years	 of	 mentoring	 and	 coaching	 experience. http://www.gowdybrothers.com/experience-weoffer.html for	additional	experience	and	company	information.

Gowdy	 Brothers	 Aerospace	 has	 a	 relationship	 to assist	 Clark	 Engineering,	 a	 75-year	 old	 civil	 and	

structural engineering	 firm,	 with	 over	 60	 engineers	 in	 staff	 and	 offices	 in	 Minnesota	 and	 South	

Dakota.	 	 Clark	Engineering	has	an	agreement	with	the	 State	of	South	Dakota	to	provide	 structural	

engineering	inspection	reports on	more	than sixty	percent	of	the	State	of South	Dakota’s	bridges.		At	

present	 these	 inspections	 are	 time	 consuming and	 require expensive equipment	 and	 lifts	 to	 be	

moved	 from	 bridge	 to	 bridge	 with	 re-calibration	 required	 at	 each	 bridge	 site.	 	 Today,	 Clark	

Engineering	is	able	to	complete	an	average of	only	two	bridge	inspections	per	day.		Clark	Engineering	

estimates	using	Gowdy	Brothers	Aerospace UAV’s,	the	engineering	firm	could	complete	at	least	four	

bridge	inspections	per	day.	Completing	twice	the	amount	of	inspections	during	the	same	amount	of	

time	saves	the	taxpayers of	South	Dakota	and	creates	less	disruption	for	South	Dakota	traffic	having	

to	be	re-routed	for	shorter	periods	of	time.

Gowdy	 Brothers	 Aerospace	 provides	 our clients	 with	 expertise	 and	 knowledge	 in	 advanced	

photography	 and	 video	 solutions	 to	 increase	 efficiency,	 productivity	 and	 effectiveness.	 Gowdy	

Brothers	Aerospace	has	many	years	experience in	Photographic	and	Video	Technology.	
Gowdy	Brothers	Aerospace,	LLC						Section	333	Exemption	Submission	version	1.0						April	30,	2015 Page	5

The	 objective	 of	 Gowdy	 Brothers	 Aerospace's	 Bridge	 Inspections,	 Aerial	 Video	 and	 Photography

operations	is	to	provide	high	quality	imaging	for	a	variety	of	commercial,	public,	and	residential	uses,	

specifically	targeting:	

• Structural	engineering	bridge	inspections	

• Construction sites

• Appraisals	

• Real-estate	marketing	

• Aerial	acquisitions	used	for	inspections	of	public	and	private	structures.	

• Search	and	Rescue	operations

BACKGROUND

Unmanned	Aircraft	Systems:	

 CCO	w/Wkm	M,	

 HH	Blade	350QX3 AP	UAS's	

Gowdy	Brothers	Aerospace	seeks	an	exemption	to	operate	DJI	&	HH	Blade	systems	for	compensation	

or	 hire within	 the	 NAS.	 The	 CCO	 w/Wkm	 M	 and	 HH	 Blade	 350QX3 AP	 are	 vertical	 take	 offand	

landing	(VTOL)	 Unmanned	 Aircraft	(UA)	 with	 a	 Ground	 Control	 Station	(GCS)Utilizing	 a	 2.8Mhz	

Remote	Control	system.	

The	CCO	w/Wkm	M	has	a	maximum	gross	weight	of	approximately	15	pounds	0	ounces,	while	having	

a	width	of	40inches	and	a	height	of	19	inches,	and	a	maximum	speed	of	approximately	43	knots.

The	 HH	 Blade	 350QX3 AP	 has	 a	 maximum	 gross	 weight	 of	 4	 pounds	 0	 ounces,	 a	 length	 of18.3	

inches,	 width	 of	 17.7	 inches,	 height	 of	 7.48	 inches,	 and	 a	 maximum	 speed	 ofApproximately	 29	

knots.	

The	CCO	w/Wkm	M	is	equipped	with	8	main	 rotors,	and	the	HH	Blade	350QX3 AP	with	four	main	

rotors;	utilizing	Lithium	Polymer	batteries	to	power	the	electric	motors.	

The	 CCO	 w/Wkm	 M	 and	 HH	 Blade	 350QX3 AP	 UAS's	 that	 will	 be	 operated	 by	 Gowdy	 Brothers	

Aerospace	will	be	 registered	in	accordance	with	49	U.S.C.	44103,	Registration	of	Aircraft,	as	well	as	

14	 C.F.R	 Part	 47,	 Aircraft	 Registration,	 and	 marked	 in	 accordancewith	 14	 C.F.R.	 Part	 45,	

Identification	and	Registration	Marking.	

BASIS	FOR	PETITION

Petitioner,	 Gowdy	 Brothers	 Aerospace,	 pursuant	 to	 the	 provisions	 of	 the	 Federal	 Aviation	

Regulations	(14	C.F.R.	§	11.61)	and	the	FAA	Modernization	and	Reform	Act	of	2012	(FMRA),	Section	
Gowdy	Brothers	Aerospace,	LLC						Section	333	Exemption	Submission	version	1.0						April	30,	2015 Page	6

333,	 Special	 Rules	 for	 Certain	 Unmanned	 Aircraft	 Systems,	 hereby	 petitions	 the	 Administrator	 to	

commercially	operate	the	CCO	w/Wkm	MAnd	HH	Blade	350QX3 AP	UAS's	in	the	National	Airspace	

System	(NAS),	and	for	an	exemption	from	the	requirements	of	14	C.F.R	§§	61.113(a)	&	(b),	91.7(a),	

91.121,	91.151(b),	91.405(a),	91.407(a)(1),	91.409(a)(1)	&	(a)(2),	and	91.417(a)	&	(b).	

In	consideration	of	the	speed,	weight,	size,	and	limited	operating	area	associated	with	the	unmanned	

aircraft	and	its	operation,	Gowdy	Brothers	Aerospace's	operation	of	CCO	w/Wkm	M	and	HH	Blade

350QX3 AP	 UAS's	 meets	 the	 conditions	 of	 FMRA	 Section	 333	 and	 therefore,	 will	 not	 require	 an	

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

Accordingly,	 Gowdy	 Brothers	 Aerospace	 requests	 relief	 from	 Sections	 91.405(a),	 91.407(a)(1),	

91.409(a)(1)	&	(a)(2),	and	91.417(a)	&	(b),	as	these	sections	set	forth	requirements	for	maintenance	

that	only	apply	to	aircraft	with	an	airworthiness	certificate.	

Gowdy	Brothers	Aerospace	submits	that	the	requested	relief	is	proper	since	anequivalent	level	of	

safety	will	be	ensured.	Gowdy	Brothers	Aerospace	will	use	experienced	personnel	or	technicians	to	

perform	 maintenance,	 alterations,	 or	 preventive	 maintenanceon	 the	 UAS's	 using	 the	 methods,	

techniques,	and	practices	prescribed	in	the	operating	documents	(i.e.,	Monthly	Maintenance	Log,	and	

CCO	 w/Wkm	 M	 and	 HH	 Blade	 350QX3 AP	 Instruction	 Manual).	 Furthermore,	 Gowdy	 Brothers	

Aerospace	 will	 document	 and	 maintainall	 maintenance	 records	 for	 the	 CCO	 w/Wkm	 M	 and	 HH	

Blade	350QX3 AP	UAS's.	

Relief	 from	 certain	 requirements	 of	 Section	 61.113(a)	 and	(b),	 entitled	 Private	pilot	privileges	and	

limitations:	Pilot	in	command,	is	requested	by	Gowdy	Brothers	Aerospace	to	the	extent	necessary	to	

allow	a	Pilot	in	Command	(PIC)	holding	a	private	pilot	or	higher	level	certificate,	as	well	as	an	airman	

medical	 certificate,	 and	 who	 has	 demonstrated,	 by	 meeting	 minimum	 flight- hour	 and	 current	

requirements,	that	the	PIC	is	 able	to	 safely	operate	the	CCO	w/Wkm	M	 and	HH	Blade	350QX3 AP	

UAS's	in	a	manner	consistent	with	this	exemption,	including	evasive	and	emergency	maneuvers	and	

maintaining	appropriate	distances	from	people,	vessels,	vehicles	and	structures.	

Gowdy	 Brothers	 Aerospace	 seeks	 relief	 from	 Section	 91.7(a),	 entitled	 Civil	aircraft	airworthiness,	

because	 the	 CCO	 w/Wkm	 M	 and	 HH	 Blade	 350QX3 AP	 UAS's	 do	 not	 require	 an	 airworthiness	

certificate	 in	 accordance	 with	 14	 C.F.R.	 Part	 21,	 Subpart	 H.	 As	 such,Gowdy	 Brothers	 Aerospace	

submits	 that	 he	 will	 ensure	 that	 the	 CCO	 w/Wkm	 M	 and	 HH	 Blade	 350	 QX3 AP	 UAS's	 are	 in	 an	

airworthy	condition,	prior	to	every	flight,	by	determining	that	the	UAS's	are	in	compliance	with	the	

operating	documents	(i.e.,	Monthly	Maintenance	Log,and	CCO	w/Wkm	M	and	HH	Blade	350QX3 AP	

Instruction	 Manual),	 and	 that	 the	 aircraft	 are	 in	 a	 condition	 for	 safe	 flight.Gowdy	 Brothers	

Aerospace	 also	 seeks	 an	 exemption	 from	 the	 requirements	 of	 Section	 91.121,	 entitled	 Altimeter	
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Settings,	as	the	CCO	w/	Wkm	M	and	HH	Blade	350QX3 AP	UAS'swill	not	have	a	typical	barometric	

altimeter	onboard.	However,	altitude	information	of	the	CCO	w/	Wkm	M and	HH	Blade	350QX3 AP	

UAS's	 will	 be	 provided	 to	 the	 PIC	 via	 Global	 Positioning	 System	 (GPS)	 equipment	 and	 radio	

communications	 telemetry	 data	 link,which	 downlinks	 from	 the	 UAS	 to	 the	 GCS	 for	 active	

monitoring	of	the	flight	path.	This	altitude	information,	combined	with	Gowdy	Brothers	Aerospace's	

operation	of	the	CCOW/	Wkm	M	and	HH	Blade	350QX3 AP	UAS's	within	visual	line	of	sight,	at	or	

below	400feet	AGL,	will	ensure	a	level	of	safety	equivalent	to	Section	91.121.	

Additionally,	 Gowdy	 Brothers	 Aerospace	 seeks	 an	 exemption	 from	 the	 requirementsof	 Section	

91.151(b),	entitled	Fuel	requirements	for	flight	in	VFR	conditions.	Gowdy	Brothers	Aerospace submits	

that	safety	will	not	be	affected	by	operation	of	the	CCO	w/	Wkm	M	and	HH	Blade	350QX3 AP	UAS's	

during	daylight	hours	in	visual	meteorological	conditions	(VMC)	under	visual	flight	rules	(VFR),	with	

enough	battery	power	to	fly	for	a	total	duration	of	approximately	10	minutes	for	the	intended	photo	

shoot	or	inspection	and,	assuming	normalcruising	speed,	to	fly	after	that	for	at	least	2.5	minutes	for	

recovery	and	landing.	

In	accordance	with	14	C.F.R.	§	11.81,	Gowdy	Brothers	Aerospace	provides	the	following	information	

in	support	of	its	petition	for	exemption:

Name	and	Address	of	Petitioner

A.	Name	And	Address	Of	The	Petitioner

The	name	and	address	of	the	Petitioner	and	point	of	contact	is:	

Gowdy	Brothers	Aerospace	

Attention:	Steve	Gowdy,	Private	Pilot

1540	Yorkshire	Lane,	

Shakopee,	MN	55379	

763-496-9551	

Email:	Steve@GowdyBrothers.com

B.	The	Specific	Sections	Of	14	C.F.R.	From	Which	Gowdy	Brothers	Aerospace	

seeks	Exemption

1.	Gowdy	Brothers	Aerospace	Seeks	Exemption	From	The	Requirements	Of	

Section	61.113(a)	And	(b).
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Section	61.113,	entitled	Private	pilot	privileges	and	limitations:	Pilot	in	command,	subsections	(a)	and	

(b)	prescribe	the	following,	in	relevant	part:	

(a)	No	person	who	holds	a	private	pilot	certificate	may	act	as	a	pilot	in	command	(PIC)	of	an	

aircraft	 that	 is	 carrying	 passengers	 or property	 for	 compensation	 or	 hire;	 nor	 may	 that	

person,	for	compensation	or	hire,	act	as	PIC	of	an	aircraft.	

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

2.	Gowdy	Brothers	Aerospace	Seeks	Exemption	From	The	Requirements	Of	

Section	91.7(a).

Section	91.7,	entitled	Civil	aircraft	airworthiness,	subsection	(a),	states	the	following:	

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

3.	Gowdy	Brothers	Aerospace	Seeks	Exemption	From	The	Requirements	Of	

Section	91.121.

Section	91.121,	entitled	Altimeter	settings,	subsection	(a),	states	the	following,	in	part:	

(a)	 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--

(1)	Below	18,000	feet	MSL,	to--

(i)	 The	 current	 reported	 altimeter setting	 of	 a	 station	 along	 the	 route	 and	 within	 100	

nautical	miles	of	the	aircraft;	

(ii)	If	there	is	no	station	within	the	area	prescribed	in	paragraph	(a)(1)(i)	of	this	section,	the	

current	reported	altimeter	setting	of	an	appropriate	available	station; or	

(iii)	 In	 the	 case	 of	 an	 aircraft	 not	 equipped	 with	 a	 radio,	 the	 elevation	 of	 the	 departure	

airport	or	an	appropriate	altimeter	setting	available	before	departure.	

4.	Gowdy	Brothers	Aerospace	Seeks	Exemption	From	The	Requirements	Of	

Section 91.151(b).

Section	 91.151,	 entitled	 Fuel	 requirements	 for	 flight	 in	 VFR	 conditions,	 subsection	 (b),	 states	 the	

following:	

(b)	No	person	may	begin	a	flight	 in	a	 rotorcraft	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,	to	fly	after	that	for	at	least	20	minutes.	
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5.	Gowdy	Brothers	Aerospace	Seeks	Exemption	From	The	Requirements Of	

Section 91.405 (a).

Section	91.405,	entitled	Maintenance	required,	subsection	(a),	states	the	following:	

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.

6.	Gowdy	Brothers	Aerospace	Seeks	Exemption	From	The	Requirements	Of	

Section	91.407(a)(1)

Section	 91.407,	 entitled	 Operation	 after	 maintenance,	 preventive	 maintenance,	 rebuilding,	 or	

alteration, subsection	(a)(1),	states	the	following:	

(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.	

7.	Gowdy	Brothers	Aerospace	Seeks	Exemption	From	The	Requirements	Of	

Sections	91.409(a)(1)	And	91.409(a)(2).

Section	91.409,	entitled	Inspections,	 subsection	(a),	 states	the	following:(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	--

(1)	An	annual	inspection	in	accordance	with	part	43	of	this	chapter	and	has	been	approved	for	return	

to	service	by	a	person	authorized	by	§	43.7	of	this	chapter	or	

(2)	An	inspection	for	the	issuance	of	an	airworthiness	certificate	in	accordance	with	part	21	of	this	

chapter.	

8.	Gowdy	Brothers	Aerospace	Seeks	Exemption	From	The	Requirements	Of	

Sections	91.417(a)	And	91.417(b).

Section	91.417,	entitled	Maintenance	records,	subsections	(a)	and	(b),	states the	following:	

(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:	

(1)	Records	of	the	maintenance,	preventive	maintenance,	and	alteration	and	records	of	the	

100-hour,	annual,	progressive,	and	other	required	or	approved	inspections,	as	appropriate,	
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for	each	aircraft	(including	the	airframe)	and	each	engine,	propeller,	rotor,	and	appliance	of	

an	aircraft.	The	records	must	include--

(i)	A	description	(or	reference	to	data	acceptable	to	the	Administrator)	of	the	work	

performed;	and	

(ii)	The	date	of	completion	of	the	work	performed;	and	

(iii)	The	signature,	and	certificate	number	of	the	person	approving	the	aircraft	for	

return	to	service.	

(2)	Records	containing	the	following	information:	

(i)	The	total	time	in	service	of	the	airframe,	each	engine,	each	propeller,	and	each	

rotor.	

(ii)	The	current	status	of	life-limited	parts	of	each	airframe,	engine,	propeller,	rotor,	

and	appliance.	

(iii)	 The	 time	 since	 last	 overhaul	 of	 all	 items	 installed	 on	 the	 aircraft	 which	 are	

required	to	be	overhauled	on	a	specified	time	basis.	

(iv)	The	 current	 inspection	 status	of	the	 aircraft,	including	the	time	 since	the	last	

inspection	 required	 by	 the	 inspection	 program	 under	 which	 the	 aircraft	 and	 its	

appliances	are	maintained.	

(v)	 The	 current	 status	 of	 applicable	 airworthiness	 directives	 (AD)	 and	 safety	

directives	including,	for	each,	the	method	of	compliance,	the	AD	or	Safety	directive	

number	and	revision	date.	If	the	AD	or	safety	directive	involves	recurring	action,	the	

time	and	date	when	the	next	action	is	required.	

(vi)	 Copies	 of	 the	 forms	 prescribed	 by	 §	 43.9(d)	 of	 this	 chapter	 for	 each	 major	

alteration	 to	 the	 airframe	 and	 currently	 installed	 engines,	 rotors,	 propellers,	 and	

appliances.	

(b)	The	owner	or	operator	shall	retain	the	following	records	for	the	periods	prescribed:	

(1)	The	records	specified	in	paragraph	(a)(1)	of	this	section	shall	be	retained	until	

the	work	is	 repeated	or	superseded	by	other	work	or	for	1	year	after	the	work	is	

performed.	

(2)	The	 records	specified	in	paragraph	(a)(2)	of	this	section	shall	be	 retained	and	

transferred	with	the	aircraft	at	the	time	the	aircraft	is	sold.	

(3)	A	list	of	defects	furnished	to	a	registered	owner	or	operator	under	§	43.11	of	this	

chapter	shall	be	retained	until	the	defects	are	repaired	and	the	aircraft	is	approved	

for	return to	service.	

C.	The	Extent	Of	Relief	Gowdy	Brothers	Aerospace	Seeks	And	The	Reason	

Gowdy	Brothers	Aerospace	Seeks	The	Relief.
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1. Extent	Of	Relief	Gowdy	Brothers	Aerospace	Seeks	And	The	Reason	Gowdy	Brothers	

Aerospace	Seeks	Relief	From	Section	61.113(a)	And (b).

Relief	 from	 Section	 61.113(a)	 and	 (b)	 entitled	 Private	 pilot	 privileges	 and	 limitations:	 Pilot	 in	

command,	is	requested	to	the	extent	necessary	to	allow	a	PIC	holding	a	private	pilot	or	higher	level	

certificate,	as	well	as	a	current	and	valid	airman medical	certificate,	and	who	has	met	certain	flighthour	and	currency	requirements,	to	conduct	the	proposed	UAS	flight	operations	for	compensation	or	

hire.	

This	relief	is	requested	since	the	limitations	set	forth	in	Section	61.113(a)	and	(b)	state	that	a	private	

pilot	 may,	 for	 compensation	 or	 hire,	 act	 as	 PIC	 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.	

As	set	forth	more	fully	below,	Gowdy	Brothers	Aerospace	submits	that	an	equivalent	level	of	safety	

will	 be	 maintained	 because	 no	 PIC	 will	 be	 allowed	 to	 operate	 the	 CCO	 W/Wkm	 M	 or	 HH	 Blade	

350QX3 AP	 UAS's	 unless	 that	 PIC	 has	 met	 certain	 flight-hour	 and	 And	 current	 requirements,	

demonstrating	that	the	PIC	is	able	to	safely	operate	either	the	CCO	w/Wkm	M	or	HH	Blade	350QX3

AP	UAS's	in	a	manner	consistent	with	the	operations	specifications	as	described	in	this	exemption,	

including	 evasive	 and	 emergency	 maneuvers,	 as	 well	 as	 maintaining	 appropriate	 distances	 from	

people,	vessels,	vehicles	and	structures.	

Further,	Gowdy	Brothers	Aerospace	submits	that	all	flights	of	the	CCO	w/Wkm	MAnd	HH	350QX3

AP	UAS's,	conducted	by	the	PIC	pursuant	to	the	grant	of	this	Petition:	(1)	will	be	incidental	to	Gowdy	

Brothers	Aerospace's	business;	and	(2)	will	not	 carry	passengers	or	property	for	 compensation	or	

hire.	

2.Extent	Of	Relief	Gowdy	Brothers Aerospace	Seeks	And	The	Reason	Gowdy	Brothers	

Aerospace	Seeks	Relief	From	Section	91.7(a).

Relief	from	Section	91.7(a)	entitled	Civil	aircraft	airworthiness,	is	requested	to	the	extent	required	to	

allow	Gowdy	Brothers	Aerospace	to	determine	that	the	CCO	w/Wkm	Mand	HH	Blade350QX3 AP	

UAS's	are	in	airworthy	condition	prior	to	every	flight	by	ensuring	that	the	UAS	is	in	compliance	with	

the	 operating	 documents	(i.e.,	the	 Monthly	 Maintenance	 Log	 and	 CCO	w/Wkm	 M	 and	 350QX3 AP	

manuals.	

Gowdy	 Brothers	 Aerospace	 seeks	the	 requested	 relief	 because	the	 CCO	 w/Wkm	 M	 and	HH	 Blade	

350QX3 AP	UAS's	do	not	 require	an	airworthiness	certificate	in	accordance	with	14	C.F.R.	Part	21,	

Subpart	H.	Therefore,	Gowdy	Brothers	Aerospace	will	ensure	that	the	CCO	w/Wkm	M	and	HH	Blade	

350QX3 AP	 UAS's	 are	 in	 airworthy	 condition	 based	 upon	 its	 compliance	 with	 the	 operating	
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documents	(i.e.,	Monthly	Maintenance	Log,	and	CCO	w/Wkm	M	and	HH	Blade	350QX3 AP	Instruction	

Manual)	prior	to	every	flight,	and	further,	determine	that	the	aircraft	are	in	condition	for	safe	flight,	

as	stated	in	the	conditions	and	limitations	below.	

3.	Extent	Of	Relief	Gowdy	Brothers	Aerospace	Seeks	And	The	Reason	Gowdy	Brothers	

Aerospace	Seeks	Relief	From	Section	91.121.

Relief	from	Section	91.121,	entitled	Altimeter settings,	may	be	required	to	allow	flight	operations	of	

the	CCO	w/Wkm	M	and	HH	Blade	350QX3 AP	UAS's,	which	utilize	a	barometric	pressure	sensor,	GPS	

equipment,	and	a	radio	communications	telemetry	data	link	to	downlink	altitude	information	from	

the	 UA	 to the	 PIC	 at	 the	 ground	 control	 station	 (GCS).	 Since	 the	 FAA	 requires	 that	 any	 altitude	

information	concerning	UAS	operations	be	reported	to	air	traffic	control	(ATC)	in	feet	above	ground	

level	(AGL),	Gowdy	Brothers	Aerospace	seeks	the	requested	relief	because	the	CCO	w/Wkm	M	and	

HH	Blade	350QX3 AP	UAS’s	altimeter	may	be	set	on	the	ground	to	zero	feet	AGL,	rather	than	the	local	

barometric	pressure	or	field	altitude,	before	each	flight.	

Considering	the	limited	altitude	of	the	proposed	operations,	relief	from 14	CFR	91.121	is	sought	to	

the	extent	necessary	to	comply	with	the	applicable	conditions	and	limitations	stated	below.	As	more	

fully set	forth	herein,	an	equivalent	level	of	safety	willbe	maintained	since	the	CCO	w/Wkm	M	and	

HH	Blade	350QX3 AP	UAS's	 are	 equipped	with	 a	 barometric	 pressure	 sensor	 and	GPS	 equipment,	

which	 automatically	 ensures	that	 a	 ground	level	pressure	 setting	will	be	 established	prior	to	 each	

flight,	and	provides	the	PIC	with	altitude	information	of	the	UA	on	the	heads-up	display	of	the	GCS.	

4.	Extent	Of	Relief	Gowdy	Brothers	Aerospace	Seeks	And	The	Reason	Gowdy	Brothers	

Aerospace	Seeks	Relief	From	Section	91.151(b).

Relief	from	Section	91.151(b)	entitled	Fuel	requirements	for	flight	in	VFRconditions,	is	requested	to	

the	extent	required	to	allow	flights	of	the	battery	powered	CCOCO	w/Wkm	M	and	HH	Blade	350QX3

AP	UAS's	during	daylight	hours	in	visual	meteorological	conditions	(VMC),	under	visual	flight	rules	

(VFR),	for	a	total	duration	of	10	minutes	tothe	first	point	of	intended	landing	and,	assuming	normal	

cruising	 speed,	 to	 fly	 after	 that	 forat	 least	 2.5	 minutes.	 Gowdy	 Brothers	 Aerospace	 seeks	 the	

requested	relief	because	without	an	exemption	from	Section	91.151(b),	the	flight	time	duration	of	the	

battery	 powered	 CCO	 W/Wkm	 M	 and	 HH	 Blade	 350QX3 AP	 UAS's	 will	 severely	 constrain	 the	

practicality	 of	 any	 aerial	 video	 or	 still	 photo	 flight	 operations	 that	 Gowdy	 Brothers	 Aerospace	

proposes	to	conduct	pursuant	to	this	Petition.	

Significantly,	 as	 set	forth	 below,	the	technical	 specifications	 of	the	 CCO	w/Wkm	 Mand	HH	Blade	

350QX3 AP	UAS's,	the	CCO	w/Wkm	M	and	HH	Blade	350QX3 AP	operating	documents	and	Gowdy	

Brothers	Aerospace's	 proposed	 operating	 limitations,	 ensure	that	 Gowdy	 Brothers	Aerospace	 will	

safely	operate	the	battery	powered	CCO	w/Wkm	M	and	HH	Blade	350QX3 AP	UAS's	during	daylight	

hours	in	visual	meteorological	conditions	(VMC),	under	visual	flight	rules	(VFR),	with	enough	battery	
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power	to	fly	for	a	total	duration	of	10	minutes	to	the	firstpoint	of	intended	landing	and,	assuming	

normal	cruising	speed,	to	fly	after	that	for	at	least2.5	minutes.	

5.Extent	Of	Relief	Gowdy	Brothers	Aerospace	Seeks	And	The	Reason	Gowdy	Brothers	

Aerospace	Seeks	Relief	From	Sections	91.405(a), 91.407(a)(1),

91.409(a)(1)	&	(a)(2),	And	91.417(a)	&	(b).

Since	 Sections	 91.405(a),	 91.407(a)(1),	 91.409(a)(1)	&	(a)(2),	 and	 91.417(a)	&	(b)only	 apply	to	

aircraft	 with	 an	 airworthiness	 certificate,	 Gowdy	 Brothers	 Aerospace	 requestsrelief	 from	 these	

Sections	because	the	CCO	w/Wkm	M	and	HH	Blade	350QX3 AP	UAS's	donot	require	airworthiness	

certificates.	As	set	forth	more	fully	below,	the	CCO	w/Wkm	Mand	HH	Blade	350QX3 AP	UAS's	meet	

the	conditions	of	FMRA	Section	333	for	operation	without	an	airworthiness certificate.	Accordingly,	

Gowdy	 Brothers	 Aerospace	 will	 use	 trained	 technicians	 to	 perform	 maintenance,	 alterations,	 or	

preventive	maintenance	on	the	UAS'susing	the	methods,	techniques,	and	practices	prescribed	in	the	

UAS	operating	 documents(i.e.,	the	Aerial	Operations	 Manual,	Monthly	Maintenance	Log,	 and	CCO	

w/Wkm	M	and	HH	Blade	350QX3 AP	Instruction	Manual).	Furthermore,	Gowdy	Brothers	Aerospace	

will	documentand	maintain	all	maintenance	records	for	the	CCO	w/Wkm	M	and	HH	Blade	350QX3

AP	UAS's.	

D.	The Reasons	Why	Granting	Gowdy	Brothers	Aerospace	Request	Would	Be	

In	The	Interest;	That	Is,	How	It	Would	Benefit	The	Public	As	A	Whole.

Granting	the	present	Petition	will	further	the	public	interest	by	allowing	Gowdy	Brothers	Aerospace	

to	 safely,	efficiently,	and	 economically	perform	aerial	video	and	photography	of	 construction	 sites,	

real	 estate,	 and	 landscape	 over	 certain	 areas	 of	 the	 United	 States.Additionally,	 use	 of	 the	 CCO	

w/Wkm	M	and	HH	Blade	350QX3 AP	UAS's	will	decrease	 congestion	of	the	NAS,	 reduce	pollution,	

and	 provide	 significant	 benefits	 to	 the	 the	 economy.	 Notably,	 the	 benefits	 of	 Gowdy	 Brothers	

Aerospace's	 proposed	 operation	 of	 the	 CCO	 w/Wkm	 M	 and	 HH	 Blade	 350QX3 AP	 UAS's	 will	 be	

realized	without	implicating	any	privacy	issues.	

1.The	Public	Will	Benefit	From	Decreased	Congestion	Of	The	NAS.

The	 CCO	 w/Wkm	 M	 and	 HH	 Blade	 350QX3 AP	 UAS's	 are	 battery	 powered	 and	 serve	 as	 a	 safe,	

efficient,	 and	 economical	 alternative	to	the	 manned	 aircraft	 traditionally	 utilizedto	 obtain	 aerial	

imagery.	 By	 reducing	 the	 amount	 of	 manned	 aircraft	 needed	 to	 perform	 aerial	 acquisitions,	 an	

exemption	allowing	the	use	of	the	CCO	w/Wkm	M	and	HH	Blade	350QX3AP	UAS's	would	reduce	the	

amount	of	manned	aircraft	in	the	NAS,	reduce	noise	and	air	pollution,	as	well	as	increase	the	safety	of	

life	and	property	in	the	air	and	on	the	ground.	

Furthermore,	by	 reducing	the	number	of	manned	aircraft	operating	in	the	NAS,	congestion	around	

airports	caused	by	arriving	and	departing	aircraft	will	be	reduced.	The	CCO	w/Wkm	M	and	HH	Blade	
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350QX3 AP	 UAS's	 do	 not	 require	 an	 airport	 to	 takeoff	 or	 land.	 Likewise,	 a	 reduction	 of	 manned	

aircraft	conducting	aerial	video	and	photography	missions	would	result	in	fewer	aircraft	that	must	

be	handled	by	air	traffic	control	during	the	ground,	takeoff,	departure,	arrival,	and	landing	phases	of	

flight	operations.	

2.	The	Public	Will	Benefit	From	The	Safety	And	Efficiency	Of	The	CCO	W/Wkm M	and	HH	Blade	

350QX3 AP	UAS's.

Conducting	aerial	acquisitions	with	the	CCO	w/Wkm	M	and	HH	Blade	350QX3 AP	UAS's	instead	of	

manned	 aircraft,	will	 greatly	 benefit	the	 public	 by	 drastically	 reducingthe	 levels	 of	 air	 and	 noise	

pollution	generated	during	traditional	aerial	video	and	still	photography	flight	operations.	By	using	

battery	power	and	electric	motors,	the	CCO	w/Wkm	M	and	HH	Blade	350QX3 AP	UAS's	produce	no	

air	 pollution,	 and	 is	 the	 most	 viable	 environmentally	 conscious	 alternative	 to	 the	 cabin	 class,	 six	

cylinder	 internal	 combustion	 engine	 aircraft	 that	 are	 typically	 utilized	 foraerial	 video	 and	

photographywhile	burning	approximately	20-30	gallons	per	hour	of	leaded	aviation	fuel.	The	CCO	

w/Wkm	 M	 and	 HH	 Blade	 350QX3 AP	 UAS's,	 while	 reducing	 the	 carbon	 footprint	 of	 aerial	

acquisitions,	also	 eliminates	noise	pollution,	as	the	UA's	are	propelled	by	battery	powered	 electric	

motors,	rather	than	an	internal	combustion	engine.	

By	 using	the	 CCO	 w/Wkm	 M	 and	 HH	 Blade	 350QX3 AP	 UAS's	to	 perform	 aerial	 acquisitions,	the	

substantial	 risk	to	life	and	property	in	the	air	and	on	the	ground,	which	is	usually	associated	with	

traditional	manned	aircraft	flight	operations,	will	be	substantially	reduced	or	completely	eliminated.	

Aside	from	the	lack	of	flight	crew	members	located	onboard	the	aircraft,	the	CCO	w/Wkm	M	and	HH	

Blade	 350QX3 AP	 UAS's	 (weighing	 approximately	 15	 pounds	 0	 ounces	 and	 4	 pounds	 0	 ounces	

respectively,	at	their	maximum	gross	weights	with	respectively	(and	with	no	fuel	on	board)	has	less	

physical	potential	for	collateral	damage	to	life	and	property	on	the	ground,	and	in	the	air,	compared	

to	 the	 manned	 aircraft	 that	 typically	 conduct	 similar	 operations	 (weighing	 approximately	 6,000	

pounds,	and	a	fuel	capacity	of	180	gallons.	

3.	Performing	Bridge	Inspections	and	Aerial	Video	and	Photography	Operations	With	The	CCO	

w/Wkm	M	and	HH	Blade	350QX3 AP	UAS's	Will	Benefit	The	Economy.

In	addition	to	being	safe	and	efficient,	the	CCO	w/Wkm	M	and	HH	Blade	350QX3 AP	UAS's	are	also	an	

economical	 alternative	 to	 using	 manned	 aircraft	 to	 conduct	 similar	 aerial	 operations.	 As	 such,	

operation	 of	 the	 CCO	 w/Wkm	 M	 and	 HH	 Blade	 350QX3 AP	 UAS's	 will	 allow	 United	 States	 based	

companies,	like	Gowdy	Brothers	Aerospace's	to	remain	competitiveand	contribute	to	growth	of	the	

U.S.	 economy.	 Specifically,	 with	the	 rising	 cost	 of	 aviationfuel	 and	the	 Environmental	 Protection	

Agency	 (“EPA”)	 regulatory	 actions	 phasing	 outleaded	 aviation	 fuels,	 U.S.	 owned	 and	 operated	

companies	must	adopt	new	and	alternative	technology	in	order	to	remain	competitive.	Operating	the	

battery	powered	CCO	w/Wkm	Mand	HH	Blade	350QX3 AP	UAS's	is	one	such	technology	that	not
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only	allows	companies	greater	operational	flexibility	compared	to	manned	aircraft,	but	provides	such	

flexibility	withoutthe	high	operational	cost	of	a	traditional	manned	aircraft.	

By	 operating	 the	 CCO	 w/Wkm	 M	 and	 HH	 Blade	 350QX3 AP	 UAS's,	 companies	 such	 as	 Gowdy	

Brothers	 Aerospace's	 can	 remain	 competitive	 and	 profitable	 and	 therefore,	 provide	 greater	 job	

stability	 to	 employees	 and	 contractors,	 which	 will	 ultimately	 contribute	 togrowth	 of	 the	 U.S.	

economy.	 Improved	 financial	 performance	 of	 U.S.	 companies,	 through	 commercial	 use	 of	 the	 CCO	

w/Wkm	M	 and	HH	Blade	350QX3 AP	UAS's,	provides	 a	 stable	workforce	that	 increases	 consumer	

spending,	improves	local,	state,	and	federal	taxrevenues	and	allows	companies	to	invest	in	research	

and	development	in	order	to	remain	competitive	both	in	the	United	States	and	abroad.	

4.There	Are	No	Privacy	Issues.

Similar	 to	 the	 manned	 aerial	 acquisition	 flight	 operations	 that	 have	 been	 conducted	 for	 decades,	

Gowdy	Brothers	Aerospace's	proposed	operation	of	the	CCO	w/Wkm	M	and	HH	Blade	350	

QX3 AP	UAS's	will	not	implicate	any	privacy	issues.	Specifically,	the	CCO	w/Wkm	MAnd	HH	Blade	

350QX3 AP	 UAS's	 will	 be	 operated	 only	 in	 compliance	 with	 operating	 documents	 (i.e.	 Aerial	

Operations	Manual,	Monthly	Maintenance	Log,	 and	the	CCO	w/Wkm	M	And	HH	Blade	350QX3 AP	

Instruction	Manual's)	which	requires	property	owner	involvement as	well	as	local	law	enforcement	

notification,	 and	 in	 accordance	 with	 the	 Federal	 Aviation	 Regulations,	 including	 the	 minimum	

altitude	requirements of	14	C.F.	R.	§	91.119.	

E.	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	Gowdy	Brothers	Aerospace	Seeks	

Exemption.

1.	Reasons	Why	The	CCO	w/Wkm	M	and	HH	Blade	350QX3 AP	UAS's	Meet	The	Conditions	Of	

The	FAA	Modernization	and	Reform	Act	of	2012	(FMRA)	Section	333.

In	consideration	of	the	size,	weight,	speed,	and	limited	operating	area	associated	with	the	unmanned	

aircraft	 and	 its	 operation,	 Gowdy	 Brothers	 Aerospace's	 operation	 of	 the	 CCO	 w/Wkm	 M	 and	 HH	

Blade	 350QX3 AP	 UAS's	 meet	 the	 conditions	 of	 FMRA	 Section	 333,	 and	 will	 not	 require	 an	

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

Section	 333	 provides	 authority	 for	 a	 UAS	 to	 operate	 without	 airworthiness	 certification	 and	 sets	

forth	 requirements	for	 considering	whether	 a	UAS	will	 create	 a	hazard	to	users	of	the	NAS	or	the	

public,	 or	 otherwise	 pose	 a	 threat	 to	 national	 security.	 Specifically,	 FMRA	 Section	 333	 states	 the	

following,	in	part:	

(a)	In	General.--Notwithstanding	any	other requirement	of	this	subtitle,	and	not	later	than	180	

days	after	the	date	of	enactment	of	this	Act,	the	Secretary	of	Transportation	shall	determine	if	
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certain	unmanned	aircraft	systems	may	operate	safely	in	the	national	airspace	system	before	

completion	 of the	 plan	 and	 rulemaking	 required	 by	section	 332	 of	this	 Act	 or	the	 guidance	

required	by	section	334	of	this	Act.	

(b)	Assessment	of	Unmanned	Aircraft	Systems.--In	making	the	determination	under	subsection	

(a),	the	Secretary	shall	determine,	at	a	minimum--

(1)	which	types	of	unmanned	aircraft	systems,	if	any,	as	a	 result	of	their	size,	weight,	speed,	

operational	capability,	proximity	to	airports	and	populated	areas,	and	operation	within	visual	

line	of	sight	do	not	create	a	hazard	to	users	of	the	national	airspace	system	or	the	public	or	

pose	a	threat	to	national	security;	and	

(2)	whether	a	certificate	of	waiver,	certificate	of	authorization,	or	airworthiness	certification	

under	section	44704	of	title	49,	United	States	Code,	is	required	for	the	operation	of unmanned	

aircraft	systems	identified	under	paragraph	(1).	

(c)	 Requirements	 for	 Safe	 Operation.--If	 the	 Secretary	 determines	 under	 this	 section	 that	

certain	 unmanned	 aircraft	systems	 may	 operate	safely	 in	 the	 national	 airspace	system,	 the	

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

national	airspace	system.	

In	seeking	this	exemption,	Gowdy	Brothers	Aerospace	submits	that	the	CCO	w/Wkm	M	And	HH	Blade	

350QX3 UAS's	can	operate	safely	in	the	NAS	pursuant	to	FMRA	Section	333,	as	demonstrated	by:	(a)	

the	characteristics	of	the	CCO	w/Wkm	M	and	HH	Blade	350QX3 AP	UAS's;	(b)	the	pilot	certification	

requirement;	and	(c)	the	specific	operating	limitations.	

a. The	Specifications	Of	The	CCO	w/Wkm	M	and	HH	Blade	350QX3 AP	UAS's	Demonstrate	

Its	Safe	Characteristics.

The	CCO	w/Wkm	M	and	350QX3 AP	UAS's	do	not	create	a	hazard	to	users	of	the	NAS	or	the	public,	or	

otherwise	 pose	 a	 threat	 to	 national	 security	 considering	 its	 size,	 weight,	 speed,	 and	 operational	

capability.	

i.	Technical	Specifications	Of	The	CCO	w/Wkm	M	and	HH	Blade	350QX3 AP	UAS's.

The	technical	specifications	of	the	CCO	w/Wkm	M	and	HH	Blade	350QX3 AP	UAS's	are	set	forth	by	

the	 CCO	 w/Wkm	 M	 and	 HH	 Blade	 350QX3 AP	 Specifications	 and	 Data	 Sheet,	 attached	 hereto	 as	

Exhibit	A	and	B.	

ii.	The	CCO	w/Wkm	M	and	HH	Blade	350QX3 AP	UAS's	Autonomous	Flight	And	Navigation	

Modes	Enable	The	UAS's	To	Remain	Within	A	Defined	Operational	Area.

The	CCO	w/Wkm	M	may	 be	operated	 in	 both	 manual	 and	fully	 autonomous	flight	modes. The	HH	

Blade	350QX3 AP	may	be	operated	in	manual	flight	mode	only.	A	complete	description of	the	flight	

and	navigational	modes	of	the	CCO	w/Wkm	M	and	HH	Blade	350QX3 AP	UAS's	is	provided	at	pages	

23-32	of	the	DJI	Wkm	M	and	pages	8	&	11	of	the	HH	Blade	350QX3 AP	User	Manuals,	attached	hereto	

as	Exhibit	C	and	D.	

iii.	The	CCO	w/Wkm	and	HH	Blade	350QX3 AP	UAS's	Are	Designed	For	Automatic	Return	To	

Home	Point	Or	Hover	In	The	Event	Of	Loss	Of	The	Control	Link	Or	Navigation.	
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When	 the	 Control	 Link	 is	 lost,	 the CCO	 w/Wkm	 M	 UAS	 and	 HH	 Blade	 350QX3 AP	 will	 remain	

stationary	 in	 flight,	 for	 3	 seconds	 or	 more.	If,	 after	 3	 seconds,	the	 CCO	w/Wkm	 M	 andHH	 Blade	

350QX3 AP	due	not	reacquire	control	link	data	from	the	GCS,	the	UAS	will	assume	that	the	Control	

Link	 is	 lost	 and	 the	 UAS	 will	 return	 to	 the	 home position	 (i.e.,	 failsafe	 mode)	 viaGPS,	 and	 will	

descend	to	the	takeoff	position	and	shutdown.	

A	 complete	description	of	the	Failsafe	Functions	of	the	CCO	w/Wkm	M	and	HH	Blade	350	QX3 AP	

UAS's	are	set	forth	at	pages	23	through	32	and	for	the	Blade	350QX3 AP	at	pages	8and	11	of	the	

CCO	w/Wkm	M	and	HH	Blade	350QX3 AP	User	Manuals,	attached	hereto	as	Exhibit	C	and	D.	

iv.	The	CCO	w/Wkm	M	and	HH	Blade	350QX3 AP	GCS	And	Its	Operation.

A	 complete	 description	 of	 the	 operation	 and	 specifications	 of	 the	 CCO	 w/Wkm	 M	 and	 HH	 Blade	

350QX3 AP	GCS	and	flight	 control	 software	is	provided	at	pages	23	through	32	of	the	DJI	Wkm	M	

User	Manual	and	pages	8	and	11	of	the	HH	Blade	350QX3 AP	User	Manual.	The	CCO	w/Wkm	M	and	

HH	Blade	350QX3 AP	User	Manuals	are	attached	hereto	as Exhibits	C	and	D.	

b.	Flight	Operations	Of	CCO	w/Wkm	M	and	HH	Blade	350QX3 AP	UAS's	Are	Limited	To	The	

Line	Of	Sight	Of	A	Certificated	Pilot	in	Command	With	A	Safety	Observer.

Gowdy	 Brothers	 Aerospace	 will	 only	 utilize	 certificated	 pilots	 who	 possess	 a	 current	 and	 valid	

airman	medical	certificate	to	act	as	a	pilot	in	command	(PIC)	of	the	CCO	w/Wkm	M	And	HH	Blade	

350QX3 AP	UAS's.	Additionally,	a	safety	observer	will	assist	all	pilots	during	flight	time.	

c.	Flights	Of	CCO	w/Wkm	M	and	HH	Blade	350QX3 AP	UAS's	Will	Be	Conducted	Pursuant	To	

Specific	Operating	Limitations.

In	 seeking	 this	 exemption,	 Gowdy	 Brothers	 Aerospace	 proposes	 to	 commercially	 operate	 CCO	

w/Wkm	 M	 and	 HH	 Blade	 350QX3 AP	 UAS's	 for	 the	 special	 purpose	 of	 bridge	 inspections	 and	

conducting	 aerial	 video	 and	 photography	 over	 certain	 areas	 of	 United	 States,	 pursuant	 to	 the	

following	specific	operating	limitations:	

1. Operations	 authorized	 by	this	 grant	 of	 exemption	will	 be	 limited	to	the	following	 aircraft	

described	 in	 the	 operating	 documents,	 rotorcraft	 UAS's	 weighing	 less	 than	 55	 pounds	

maximum	 gross	 weight:	 CCO	 w/Wkm	 M	 and	 HH	 Blade	 350QX3 AP	 Unmanned	 Aircraft	

Systems.	Proposed	operations	of	any	other	aircraft	will	require	a	new	petition	or	a	petition	

to	amend	this	grant.	

2. UAS	 operations	 under	 this	 exemption	 will	 be	 limited	 to	 conducting	 operations	 for	 the	

purpose	of	aerial	video	and	photography.	

3. The	UA	may	not	be	flown	at	an	indicated	airspeed	exceeding	20	knots.	

4. The	UA	must	be	operated	at	an	altitude	of	no	more	than	400	feet	above	ground	level (AGL),	

as	indicated	by	the	procedures	specified	in	the	operating	documents	unless	a	special	request	

is	made	and	approved	by	ATC.	All	altitudes	reported	to	ATC	must	be	in	feet	AGL.	

5. The	UA's	 must	 be	 operated	within	 visual	 line	 of	 sight	(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	airman	medical	certificate.	

6. The	use	of	first	person	view	(FPV)	by	the	PIC	or	safety	observer	(SO)	is	not	permitted.	
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7. All	operations	must	utilize	a	safety	observer	(SO).	The	SO	may	be	used	to	satisfy	the	VLOS	

requirement	as	long	as	the	PIC	always	maintains	VLOS	capability.	The	SO	and	PIC	must	be	

able	to	communicate	verbally	at	all	times.	Electronic	messaging	or	texting	is	not	permitted	

during	flight	operations.	The	PIC	must	be	designated	before	the	flight	and	cannot	transfer	his	

or	her	designation	for	the	duration	of	the	flight.	The	PIC	must	ensure	that	the	SO	can	perform	

the	functions	prescribed	in	the	operating	documents.	

8. The	SO	must	not	perform	any	other	duties	beyond	assisting	the	PIC	with	seeing	and	avoiding	

other	 air	 traffic	 and	 other	 ground	 based	 obstacles/obstructions	 and	 is	 not	 permitted	 to	

operate	the	camera	or	other	instruments.	

9. The	 operating	 documents	 and	 the	 grant	 of	 exemption	 must	 be	 accessible	 during	 UAS	

operations	 and	 made	 available	to	the	Administrator	 upon	 request.	If	 a	 discrepancy	 exists	

between	 the	 conditions	 and	 limitations	 contained	 in	 the	 grant	 of	 exemption	 and	 the	

procedures	outlined in	the	operating	documents,	the	conditions	and	limitations	contained	in	

the	grant	of	exemption	take	precedence	and	must	be	followed.	Otherwise,	the	operator	must	

follow	the	procedures	as	outlined	in	its	operating	documents.	The	operator	may	update	or	

revise	its	operating	documents.	It	is	the	operator’s	responsibility	to	track	such	revisions	and	

present	 updated	 and	 revised	 documents	to	the	Administrator	 upon	 request.	 The	 operator	

must	also	present	updated	and	revised	documents	if	it	petitions	for	extension	or	amendment	

to	the	 grant	 of	 exemption.	 If	the	 operator	 determines	 that	 any	 update	 or	 revision	 would	

affect	the	basis	upon	which	the	FAA	granted	the	exemption,	then	the	operator	must	petition	

for	amendment	to	its	grant	of	exemption.	The	FAA’s	UAS	Integration	Office	(AFS-80)	may	be	

contacted	if	questions	arise	regarding	updates	or	revisions	to	the	operating	documents.	

10. Prior	to	each	flight	the	PIC	must	inspect	the	UAS	to	ensure	that	it	is	in	a	condition	for	safe	

flight.	If	the	 inspection	 reveals	 a	 condition	that	 affects	the	 safe	 operation	 of	the	 UAS,	the	

aircraft	is	prohibited	from	operating	until	the	necessary	maintenance	has	been	performed	

and	the	UAS	is	found	to	be	in	a	condition	for	safe	flight.	The	Ground	Control	Station	must	be	

included	 in	 the	 preflight inspection.	 All	 maintenance	 and	 alterations	 must	 be	 properly	

documented	in	the	aircraft	records.	

11. Any	UAS	that	 has	 undergone	 maintenance	 or	 alterations	that	 affect	the	UAS	 operation	 or	

flight	 characteristics,	 e.g.	 replacement	 of	 a	 flight	 critical	 component,	 must	 undergo	 a	

functional	test	flight.	The	PIC	who	conducts	the	functional	test	flight	must	make	an	entry	in	

the	aircraft	records.	

12. The	 pre-flight	 inspection	 must	 account	 for	 all	 potential	 discrepancies,	 e.g.	 inoperable	

components,	 items,	 or	 equipment,	 not	 already	 covered	 in	 the	 relevant	 sections	 of	 the	

operating	documents.	

13. The	 operator	 must	 follow	 the	 UAS	 manufacturer’s	 aircraft/component,	 maintenance,	

overhaul,	replacement,	inspection,	and	life	limit	requirements.	

14. The	operator	must	carry	out	its	maintenance,	inspections,	and	record	keeping	requirements,	

in	 accordance	 with	 the	 operating	 documents,	 maintenance,	 inspection,	 alterations,	 and	

status	 of	 replacement/overhaul	 component	 parts	 must	 be	 noted	 in	 the	 aircraft	 records,	

including	total	time	in	 service,	description	of	work	accomplished,	and	the	 signature	of	the	

authorized	person	returning	the	UAS	to	service.	

15. Each	 UAS's	 operated	 under	 this	 exemption	 must	 comply	 with	 all	 manufacturer	 Safety	

Bulletins.	

16. The	 authorized	 person	 must	 make	 an	 entry	 in	the	 aircraft	 record	 of	the corrective	 action	

taken	against	discrepancies	discovered	between	inspections.	

17. The	 PIC	 must	 possess	 at	 least	 a	 private	 pilot	 certificate	 and	 at	 least	 a	 current	third-class	

medical	certificate.	

18. The	 operator	 may	 not	 permit	 any	 PIC	 to	 operate	 unless	 the	 PIC	 meets	 the	 operator’s	

qualification	 criteria	 and	 demonstrates	the	 ability	 to	 safely	 operate	the	 UAS	 in	 a	 manner	

consistent	with	how	the	UAS	will	be	operated	under	the	exemption,	including	evasive	and	

emergency	 maneuvers	 and	 maintaining	 appropriate	 distances	 from	 persons,	 vessels,	

vehicles	and	structures.	PIC	qualification	flight	hours	must	be	logged	in	a	manner	consistent	

with	 14	 C.F.R.	 §61.51(b).	 Flights	 for	 the	 purposes	 of	 training	 the	 operator’s	 PIC's	 are	

permitted	 under	 the	 terms	 of	 the	 exemption.	 However,	 training	 operations	 may	 only	 be	

conducted	during	dedicated	training	sessions.	During	training,	proficiency,	and	experience-
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building	 flights,	 all	 persons	 not	 essential	 for	 flight	 operations	 are	 considered	

nonparticipants,	 and	 the	 PIC	 must	 operate	 the	 UA	 with	 appropriate	 distance	 from	

nonparticipants	in	accordance	with	14	C.F.R.	§	91.119.	

19. UAS	 operations	 may	 not	 be	 conducted	 during	 night,	 as	 defined	 in	 14	 C.F.R.	 §	 1.1.	 All	

operations	 must	 be	 conducted	 under	 visual	 meteorological	 conditions	 (VMC).	 If	 flight	 at	

night	is	required,	a	special	request	will	be	made	at	the	FAA	office	closest	to	proposed	area	of	

operations.	Flights	under	special	visual	flight	rules	(SVFR)	are	not	authorized.	

20. The	UA	may	not	operate	within	5	nautical	miles	of	an	airport	reference	point	as	denoted	on	a	

current	 FAA	 published	 aeronautical	 chart	 unless	 a	 letter	 of	 agreement	with	that	 airport’s	

management	 is	obtained,	 and	the	operation	is	 conducted	 in	 accordance	with	 a	NOTAM	 as	

required	by	the	operator’s	COA.	The	letter	of	agreement	with	the	airport	management	must	

be	made	available	to	the	Administrator	upon	request.	

21. The	UA	may	not	be	operated	less	than	500	feet	below	or	less	than	2,000	feet	horizontally	

from	a	cloud	or	when	visibility	is	less	than	3	statute	miles	from	the	PIC.	

22. If	the	UA	loses	communications	or	loses	its	GPS	signal,	it	must	return	to	a	pre- determined	

location	within	the	planned	operating	area	and	land	or	be	recovered	in	accordance	with	the	

operating	documents.	

23. The	 PIC	 must	 abort	 the	 flight	 in	 the	 event	 of	 unpredicted	 obstacles	 or	 emergencies	 in	

accordance	with	the	operating	documents.	

24. The	PIC	is	prohibited	from	beginning	a	flight	unless	(considering	wind	and	forecast	weather	

conditions)	there	is	enough	power	to	fly	at	normal	 cruising	 speed	to	the	intended	landing	

point	and	land	the	UAS	with	25%	battery	power	remaining.	

25. The	operator	must	obtain	an	Air	Traffic	Organization	(ATO)	issued	Certificate	of	Waiver	or	

Authorization	(COA)	prior	to	conducting	any	operations	under	the	grant	of	exemption.	This	

COA	will	also	require	the	operator	to	request	a	Notice	to	Airman	(NOTAM)	not	more	than	72	

hours	in	advance,	but	not	less	than	48	hours	prior	to	the	operation.	All	operations	shall	be	

conducted	in	accordance	with	airspace	requirements	in	the	ATO	issued	COA	including	class	

of	airspace,	altitude	level	and	potential	transponder	requirements.	

26. All	aircraft	operated	in	accordance	with	the	exemption	must	be	identified	by	serial	number,	

registered	 in	 accordance	 with	 14	 C.F.R.	 part	 47,	 and	 have	 identification	 (N-Number)	

markings in	 accordance	 with	 14	 C.F.R.	 part	 45,	 Subpart	 C.	 Markings	 must	 be	 as	 large	 as	

practicable.	

27. Before	conducting	operations,	the	radio	frequency	spectrum	used	for	operation	and	control	

of	 the	 UAS	 must	 comply	 with	 the	 Federal	 Communications	 Commission	 (FCC)	 or	 other	

appropriate	government	oversight	agency	requirements.	

28. The	documents	required	fewer	than	14	C.F.R.	91.9	and	91.203	must	be	available	to	the	PIC	at	

the	Ground	Control	Station	of	the	UAS	any	time	the	UAS	is	operating.	These	documents	must	

be	made	available	to	the	Administrator	or	any	law	enforcement	official	upon	request.	

29. The	UAS	must	remain	clear	and	yield	the	right	of	way	to	all	manned	aviation	operations	and	

activities	at	all	times.	

30. The	UAS	may	not	be	operated	by	the	PIC	from	any	moving	device or	vehicle.	

31. Flight	 operations	 must	 be	 conducted	 at	 least	 500	 feet	 from	 all	 nonparticipating	 persons	

(persons	 other	than	the	 PIC,	 SO,	 operator	trainees	 or	 essential	 persons),	 vessels,	 vehicles,	

and	structures	unless:	

a. Barriers	or	structures	are	present that	sufficiently	protect	nonparticipating	persons	

from	the	UAS	and/or	debris	in	the	event	of	an	accident.	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	and/or;	

b. The	 aircraft	 is	 operated	 near	 vessels,	 vehicles	 or	 structures	 where	 the	

owner/controller	of	such	vessels,	vehicles	or	structures	has	granted	permission	and	

the PIC	has	made	a	safety	assessment	of	the	risk	of	operating	closer	to	those	objects	

and	determined	that	it	does	not	present	an	undue	hazard,	and;	

c. Operations	 nearer	 to	 the	 PIC,	 SO,	 operator	 trainees	 or	 essential	 persons	 do	 not	

present	an	undue	hazard	to	those	persons	per	§	91.119(a).	
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32. All	 operations	 shall	 be	 conducted	 over	 private	 or	 controlled-access	 property	 with	

permission	from	the	land	owner/controller	or	authorized	 representative.	Permission	from	

land	 owner/controller	 or	 authorized	 representative	will	 be	 obtained	 for	 each	 flight	to	 be	

conducted.	

33. Any	incident,	accident,	or	flight	operation	that	transgresses	the	lateral	or	vertical	boundaries	

of	the	operational	area	as	defined	by	the	applicable	COA	must	be	reported	to	the	FAA's	UAS	

Integration	 Office	(AFS-80)	 within	 24	 hours.	 Accidents	 must	 be	 reported	 to	 the	 National	

Transportation	 Safety	 Board	 (NTSB)	 per	 instructions	 contained	 on	 the	 NTSB	 Web	 site:	

www.ntsb.gov.	

2.	Reasons	Why	An	Exemption	From	The	Requirements	Of	Section	61.113(a)	And	(b)	Would	

Not	Adversely	Affect	Safety.

Gowdy	 Brothers	 Aerospace	 submits	 that	 the	 equivalent	 level	 of	 safety	 established	 by	 Section	

61.113(a)	and	(b)	will	be	maintained	because	no	PIC	will	be	allowed	to	operatethe	CCO	w/Wkm	M	

and	HH	Blade	350QX3 AP	UAS's	unless	that	PIC	has	demonstrated,	by	meeting	minimum	flight-hour	

and	 currency	 requirements,	that	the	PIC	is	able	to	 safely	operate	the	CCO	w/Wkm	M	or	HH	Blade	

350QX3 AP	 UAS	 in	 a	 manner	 consistent	 with	 the	 exemption,	 including	 evasive	 and	 emergency	

maneuvers	and	maintaining	appropriate	distances	from	people,	vessels,	vehicles	and	structures.	

Considering	Gowdy	Brothers	Aerospace's	proposed	area	of	operations,	and	the	operating	limitations	

set	forth-above;	the	parallel	nature	of	private	pilot	aeronautical	knowledge	requirements	to	those	of	

commercial	pilot	 requirements	(See	Exemption	No.	11062);	and	the	airmanship	skills	necessary	to	

safely	operate	the	CCO	w/Wkm	M	or	HH	Blade	350QX3 AP	UAS,	Gowdy	Brothers	Aerospace	submits	

that	the	 additional	 manned	 airmanship	 experience	 of	 a commercially	 certificated	 pilot	 would	 not	

correlate	to	the	airmanship	skills	necessary	for	Gowdy	Brothers	Aerospace's	specific	proposed	flight	

operations.	

The	 FAA	 has	 previously	 granted	 relief	 from	 Section	 61.113(a)	 and	 (b)	 specific	 to	 UAS,	 in	

circumstances	similar,	in	all	material	respects,	to	those	presented	herein	(e.g.	Exemption	Nos.	11062,	

11063,	 11064,	 11065,	 11066,	 11067,	 11080,	 11109,	 11110,	 11112,	 11136,	 11138,	 11150,	 11153,	

11156,	11158,	11159,	11160,	11161,	11445).	

Gowdy	Brothers	Aerospace	will	not	allow	any	PIC	to	operate	the	CCO	w/Wkm	M	or	HH	Blade	350QX3

AP	UAS	unless	that	PIC	has	demonstrated,	by	meeting	minimum	flight-hour	requirements	of	the	CCO	

w/Wkm	M	or	HH	Blade	350QX3 AP	UAS	training	and	currency	requirements,	that	the	PIC	is	able	to	

safely	operate	the	CCO	w/Wkm	M	orHH	Blade	350QX3 AP	UAS	in	a	manner	 consistent	with	this	

exemption,	including	evasive	and	emergency	maneuvers	and	maintaining	appropriate	distances	from	

people,	vessels,	vehicles	and	structures.	

Specifically,	 the	 PIC	 must	 have	 accumulated	 and	 logged,	 in	 a	 manner	 consistent	 with	 14	 C.F.R.	 §	

61.51(b),	25	hours	of	total	time	as	a	UAS	rotorcraft	pilot	(with	a	minimum	of	5	hours	of	those	hours	

as	 a	 UAS	 pilot	 operating	 the	 same	 make	 and	 model	 of	 UAS	 to	 be	 used	 for	 operations	 under	 the	

exemption).	In	addition	to	the	hour	requirements,	the	PIC	must	accomplish	3	takeoffs	and	landings	in	

the	preceding	90	days	(for	currency	purposes).	
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As	 in	 Exemption	 Nos.	 11062,	 11138,	 and	 11153,	 prior	 documented	 flight	 experience	 that	 was	

obtained	in	compliance	with	applicable	 regulations	will	ensure	an	equivalent	level	of	safety	during	

Gowdy	 Brothers	 Aerospace's	 proposed	 operations.	 The	 Administrator	 has	 held	 that	 prior	

documented	 flight	 experience	that	was	 obtained	 in	 compliance	with	 applicable	 regulations	 would	

ensure	safe	operations,	stating	as	follows:	

In	Exemption	No.	11062,	the	FAA	 required	that	prior	to	 conducting	 operations	for	the	 purpose	of	

motion	 picture	 filming	 (or	 similar	 operations),	 the	 PIC	 must	 have	 accumulated	 and	 logged,	 in	 a	

manner	consistent	with	14	CFR	61.51(b),	25	hours	of	total	time	as	a	UAS	rotorcraft	pilot	including	at	

least	10	hours	logged	as	a	UAS	pilot	with	a	multi-rotor	UAS.	Prior	to	operations	under	Exemption	No.	

11062,	 the	 PIC	 must	 also	 have	 accumulated	 and	 logged	 a	 minimum	 of	 5	 hours	 as	 a	 UAS	 pilot	

operating	the	 same	 make	 and	 model	 of	 UAS	to	 be	 used	 for	 operations	 under	the	 exemption.	 For	

clarification,	 the	 FAA	 considers	 these	 minimum	 hour	 requirements	 to	 be	 inclusive	 rather	 than	

additive;	i.e.	5	hours	make	and	model	time	may	be	included	in	the	10	hours	of	multi-rotor	time	and	

the	10	hours	may	be	included	in	the	total	25	hours	of	UAS	 rotorcraft	time.	In	addition	to	the	hour	

requirements,	 the	 PIC	 must	 accomplish	 3	 takeoffs	 and	 landings	 in	 the	 preceding	 90	 days	 (for	

currency	purposes).	The	FAA	finds	that	at	a	minimum,	the	flight-hour	requirements	in	Exemption	No.	

11062	are	appropriate	to	practice	and	build	proficiency	in	the	skills	necessary	to	safely	conduct	the	

petitioner’s	 proposed	 operations.	The	FAA	 also	finds	that	prior	documented	flight	 experience	that	

was	 obtained	 in	 compliance	 with	 applicable	 regulations	 would	 satisfy	this	 requirement.	 Training,	

proficiency,	and	experience-building	flights	can	also	be	 conducted	under	the	grant	of	exemption	to	

accomplish	the	required flight	time.	During	training,	proficiency,	and	experience-building	flights	the	

PIC	is	required	to	operate	the	UA	with	appropriate	distances	in	accordance	with	14	C.F.R	91.119.	

Exemption	No.	11138	at	page	15.	

Accordingly,	 Gowdy	 Brothers	 Aerospace	 will	 ensure	 safe	 operations	 by	 not	 allowing	 any	 PIC	 to	

operate	 the	 CCO	 w/Wkm	 M	 or	 HH	 Blade	 350QX3 AP	 UAS	 unless	 that	 PIC	 has	 demonstrated,	 by	

meeting	minimum	flight-hour	and	currency	 requirements,	that	the	PIC	is	able	to	safely	operate	the	

CCO	w/Wkm	M	or	HH	Blade	350QX3 AP	UAS	in	a	manner	consistent	with	the	exemption,	including	

evasive	 and	 emergency	 maneuvers	 and	 maintaining	 appropriate	 distances	 from	 people,	 vessels,	

vehicles	and	structures.	

3.	Reasons	Why	An	Exemption	From	The	Requirements	Of	Section	91.7(a) Would	Not	

Adversely	Affect	Safety.

The	 equivalent	 level	 of	 safety	 established	 by	 Section	 91.7(a)	 will	 be	 maintained	 because	 prior	to	

every	flight,	Gowdy	Brothers	Aerospace	will	ensure	that	the	CCO	w/Wkm	M	or	HH	Blade	350QX3 AP	

UAS	is	in	an	airworthy	condition	based	upon	the	UAS’s	compliance	with	its	operating	documents	and	

as	stated	in	the	conditions	and	limitations	herein.	Additionally,	the	FAA	has	previously	granted	relief	

from	 Section	 91.7(a)	 specific	 to	 UAS,	 in	 circumstances	 similar,	 in	 all	 material	 respects,	 to	 those	
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presented	herein	(e.g.	Exemption	Nos.	11062,	11063,	11064,	11065,	11066,	11067,	11080,	11109,	

11110,	11112,	11136,	11138,	11150,	11153,	11156,	11157,	11158,	11159,	11160,	11161).	

4.	Reasons	Why	An	Exemption	From	The	Requirements	Of	Section	91.121	Would	Not	

Adversely	Affect	Safety.

The	equivalent	level	of	safety	established	by	Section	91.121	will	be	maintained	because	the	altitude	

information	of	the	CCO	w/Wkm	M	and	HH	Blade	350QX3 AP	UAS's	will	be	provided	to	the	PIC	via	

GPS	equipment	and	a	radio	communications	telemetry	data	link,	which	downlinks	from	the	UA	to	the	

GCS	for	active	monitoring	of	the	flight	path	and	altitude.	This	altitude	information,	 combined	with	

Gowdy	Brothers	Aerospace's	operation	of	the	CCO	w/Wkm	M	and	HH	Blade	350QX3 AP	UA's	within	

visual	line	of	sight,	at	or	below	400	feet	AGL,	will	ensure	a	level	of	safety	equivalent	to	Section	91.121.	

The	altitude	information	will	be	generated	by	GPS	equipment	installed	on	board	the	aircraft.	Prior	to	

each	 flight,	 a	 zero	 altitude	 initiation	 point	 is	 automatically	 established	 by	 the	 UAS's	 at	 ground	

level.The	FAA	has	previously	granted	 relief	from	Section	91.121	specific	to	UAS,	in	circumstances	

similar,	in	all	material	respects,	to	those	presented	herein	(e.g.	Exemption	Nos.	11062,	11063,	11064,	

11065,	 11066,	 11067,	 11080,	 11109,	 11112,	 11136,	 11138,	 11150,	 11153,	 11156,	 11157,	 11158,	

11159,	11160,	11161,	11445).	

5.	Reasons	Why	An	Exemption	From	The	Requirements	Of	Section	91.151(b)	Would	Not	

Adversely	Affect	Safety.

A	grant	of	this	exemption	would	ensure	an	equivalent	level	of	safety	established	by	14	C.F.R.	Section	

91.151(b)	as	a	result	of	(1)	the	technical	specifications	of	the	CCO	W/Wkm	M	and	HH	Blade	350QX3

AP	UAS's;	(2)	the	limitations	on	the	proposed	flight	operations;	and	(3)	the	location	of	the	proposed	

flight	operations.	Accordingly,	Gowdy	Brothers	Aerospace will	ensure	that	he	will	safely	operate	the	

battery	 powered	 CCO	 w/Wkm	 M	 and	 HH	 Blade	 350QX3 AP	 UA's	 during	 daylight	 hours	 in	 VFR	

conditions,	with	enough	battery	power	to	fly	for	a	total	duration	of	10	minutes	to	the	first	point	of	

intendedlanding	and,	assuming	normal	cruising	speed,	to	fly	after	that	for	at	least	2.5	minutes.	

Here,	as	in	Exemption	No.	11109,	the	technical	specifications	of	the	CCO	w/WkmM	and	HH	Blade

350QX3 AP	UAS's	the	limitations	on	the	proposed	flight	operations	and	the location	of	the	proposed	

operations,	 will	 ensure	 an	 equivalent	 level	 of	 safety	 established	 by	 14	 C.F.R.	 Section	 91.151(b).	

Furthermore,	safety	will	be	ensured	as	the	CCO	w/WkmM	and HH	Blade	350QX3 AP	UAS's	provide	

audible	and	visual	warnings	to	the	PIC	at	the	GCS	when	the	UA's	experiences	low	battery	voltage,	the	

first	warning	occurring	at	approximately	33%	remaining	battery	power,	and	again	at	approximately	

10%	remaining	battery	power.	At	the	critically	low	battery	level,	the	CCO	w/Wkm	M	and	HH	Blade	

350QX3 AP	UAS's	will	descend	and	land	automatically.	

Significantly,	 previous	 exemptions	 granted	 by	 the	 FAA	 concerning	 Section	 91.151	 establish	 that	

safety	is	not	 adversely	 affected	when	the	technical	 characteristics	 and	operating	limitations	 of	the	
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UAS	 are	 considered.	 Relief	 has	 been	 granted	 for	 manned	 aircraft	 to	 operate	 at	 less	 than	 the	

minimums	 prescribed	 in	 Section	 91.151,	 including	 Exemption	 Nos.	 2689,	 5745,	 and	 10650.	

Moreover,	 the	 FAA	 has	 previously	 granted	 relief	 from	 Section	 91.151	 specific	 to	 UAS	 in	

circumstances	similar	in	all	material	respects	to	those	presented	herein	(e.g.	Exemption	Nos.	8811,	

10808,	 10673,	 11042,	 11062,	 11063,	 11064,	 11065,	 11066,	 11067,	 11080,	 11109,	 11110,	 11136,	

11138,	11150,	11153,	11156,	11157,	11158,	11159,	11160,	11161,	11445).	

6.	Reasons	Why	An	Exemption	From	The	Requirements	Of	Sections	91.405(a),	91.407(a)(1),	

91.409(a)(1)	&	(a)(2),	And	91.417(a)	&(b)	Would	Not	Adversely	Affect	Safety.

In	seeking	this	exemption,	Gowdy	Brothers	Aerospace	submits	that	the	equivalent	level	of	safety	with	

regard	to	the	regulatory	maintenance	and	alteration	requirements	established	by	Sections	91.405(a),	

91.407(a)(1),	 91.409(a)(1)	 &	 (a)(2),	 and	 91.417(a)	 &	 (b)	 will be	 met	 because	 Gowdy	 Brothers	

Aerospace	 will	 use	 trained	 technicians	 to	 perform	 maintenance,	 alterations,	 or	 preventive	

maintenance	on	the	UAS's	using	the	methods,	techniques,	and	practices	prescribed	in	the	operating	

documents	i.e.,	the	Operations	Manual,	Monthly	Maintenance	Log,	and	CCO	w/Wkm	M	and	HH	Blade	

350QX3 AP	 Instruction	 Manual.	 Furthermore,	 Gowdy	 Brothers	 Aerospace	 will	 document	 and	

maintain	all	maintenance	records	for	the	CCO	w/Wkm	M	and	HH	Blade	350QX3 AP	UAS's.	

Since	the	 CCO	w/Wkm	 M	 and	HH	Blade	 350QX3 AP	UAS's	will	 be	 inspected	 as	 prescribed	 by	the	

operating	 documents,	 Gowdy	 Brothers	 Aerospace	 will	 maintain	 the	 equivalent	 level	 of	 safety	

established	by	Sections	91.405(a),	91.409(a)(1),	and	91.409(a)(2).	A	copy	of	the	CCO	w/Wkm	M	and	

HH	Blade 350QX3 AP	User	Manuals	are	attached	hereto	as	Exhibit	C	and	D;	a	copy	of	the	CCO	w/Wkm	

M	and	HH	Blade	350QX3 AP	UAS	Maintenance	LOG	is	attached	hereto	as	Exhibit	E.	

Likewise,	the	exemption	sought	will	not	adversely	affect	safety	because	Gowdy	Brothers	Aerospace	

will	use	trained	technicians	to	perform	maintenance,	alterations	or	preventive	maintenance	on	the	

UAS	using	the	methods,	techniques,	and	practices	prescribed	by	the	operating	documents.	

Furthermore,	 the	 exemption	 sought	 would	 maintain	 an	 equivalent	 level	 of	 safety	 Established	 by	

Sections	91.407,	91.417(a)	 and	91.417(b),	because	all	maintenance	of	the	CCO	w/Wkm	M	and	HH	

Blade	350QX3 AP	UAS's	will	be	performed	by	trained	technicians.	Maintenance	will	be	documented	

and	maintained	utilizing	the	monthly	maintenance	log.	

Significantly,	previous	exemptions	granted	by	the	FAA	concerning	Sections	91.405(a),	91.407(a)(1),	

91.409(a)(1)	&	(a)(2),	and	91.417(a)	&	(b)	establish	that	safety	is	not	adversely	affected	when	the	

technical	characteristics	and	operating	limitations	of	the	UAS	are	considered.	

In	 consideration	 of	 Gowdy	 Brothers	 Aerospace's	 proposed	 operating	 limitations,	 the	 operating	

documents,	and	the	technical	aspects	of	the	CCO	w/Wkm	M	and	HH	Blade	350	QX3 AP	UAS's,	Gowdy	

Brothers	Aerospace	submits	that	safety	will	not	be	adversely	affected	by	granting	exemption	from	14	
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C.F.R.	Sections	91.405(a),	91.407(a)(1)	and	(a)(2),	91.409(a)	(2),	and	91.417(a)	and	(b).	The	FAA	has	

previously	granted	 relief	specific	to	UAS	in	circumstances	similar,	in	all	material	 respects,	to	those	

presented	herein	(e.g.	Exemption	Nos.	11062,	11063,	11064,	11065,	11066,	11067,	11080,	11109,	

11110,	11112,	11136,	11138,	11150,	11153,	11156,	11157,	11158,	11159,	11160,	11161,	11445).	

7.	The	FAA	May	Prescribe	Any	Other	Conditions	For	Safe	Operation.

In	accordance	with	Section	333	of	the	FAA	Modernization	and	Reform	Act	of	2012	(FMRA)	and	14	

C.F.R.	§	21.16	entitled	Special	Conditions,	Gowdy	Brothers	Aerospace	requests	that	the	FAA	prescribe	

special	conditions	for	the	intended	operation	of	the	CCO	w/Wkm	M	And	HH	Blade	350QX3 AP	UAS's,	

which	 contain	 such	 safety	 standards	that	the	 administrator	 finds	 necessary	to	 establish	 a	 level	 of	

safety	equivalent	to	that	established	by	14	C.F.R.	Part	21,	Subpart	H,	and	14	C.F.R	§§	61.113(a)	&	(b),	

91.7	(a),	91.121,	91.151(b),	91.405(a),	91.407(a)(1),	91.409(a)(1)	&	(a)(2),	and	91.417(a)	&	(b).	Such	

special	conditions	will	permit	safe	operation	of	the	UA's	for	the	limited	purpose	of	conducting	aerial	

video	 and	 photography	 over	 certain	 areas	 of	 the United	 States	 for	 compensation	 or	 hire.	 FMRA	

Section	333	sets	forth	the	requirements	for	considering	whether	a	UAS	will	create	a	hazard	to	users	

of	the	NAS	or	the	public,	or	otherwise	pose	a	threat	to	national	 security	and	further,	provides	the	

authority	 for	 such	 UAS	 to	 operate	 without	 airworthiness	 certification	 in	 accordance	 with	 any	

requirements	that	must	be	established	for	the	safe	operation	of	the	UAS	in	the	NAS.	

Likewise,	 the	 Administrator	 may	 prescribe	 special	 conditions	 pursuant	 to	 14	 C.F.R.	 §21.16,	 for	

operation	of	the	CCO	w/Wkm	M	and	HH	Blade	350QX3 AP	UAS's,	since	the	airworthiness	regulations	

of	 14	 C.F.R.	Part	 21	 do	 not	 contain	 adequate	 or	 appropriate	 safety	 standards,	 due	to	the	 novel	 or	

unusual	 design	 features	 of	 the	 aircraft.	 Section	 21.16,	 entitled	 Special	 Conditions,	 states	 the	

following:	

If	the	 FAA	finds	that	the	 airworthiness	 regulations	 of	this	 subchapter	 do	 not	 contain	 adequate	 or	

appropriate	 safety	 standards	 for	 an	 aircraft,	 aircraft	 engine,	 or	 propeller	 because	 of	 a	 novel	 or	

unusual	design	feature	of	the	aircraft,	aircraft	engine	or	propeller,	it	may	prescribe	special	conditions	

and	amendments	thereto	for	the	product.	The	special	conditions	are	issued	in	accordance	with	Part	

11	of	this	chapter	and	contain	such	safety	standards	for	the aircraft,	aircraft	engine	or	propeller	as	

the	FAA	finds	necessary	to	establish	a	level	of	safety	equivalent	to	that	established	in	the	regulations.	

See	14	C.F.R.	§	21.16.Therefore,	in	accordance	with	FMRA	Section	333	and	14	C.F.R.	§	21.16,	the	

FAA	

may	 prescribe	 special	 conditions	 for	 Gowdy	 Brothers	 Aerospace's	 intended	 operation	 of	 the	 CCO	

w/Wkm	 M	 and	 HH	 Blade	 350QX3 AP	 UAS's,	 which	 contain such	 safety	 standards	 that	 the	

administrator	finds	necessary	to	establish	a	level	of	safety	equivalent	to	that	established	by	14	C.F.R.	

Part	 21,	 Subpart	 H,	 and	 14	 C.F.R	 Sections	 61.113(a)	 &	(b),	 91.7(a),	 91.121,	 91.151(b),	 91.405(a),	

91.407(a)(1),	91.409(a)(1)	&	(a)(2),	and	91.417(a)	&	(b).	
Gowdy	Brothers	Aerospace,	LLC						Section	333	Exemption	Submission	version	1.0						April	30,	2015 Page	25

F.	A	Summary	That	Can	Be	Published	In	The	Federal	Register	stating:	The	

Rules	From	Which	Gowdy	Brothers	Aerospace	Seeks	Exemption:

Gowdy	Brothers	Aerospace	seeks	exemption	from	the	requirements	of	14	C.F.R	Sections	61.113(a)&(b),	

91.7(a),	91.121,	91.151(b),	91.405(a),	91.407(a)(1),	91.409(a)(1)	&	(a)(2),	and	91.417(a)	&	(b).	

A	Brief	Description	Of	The	Nature	Of	The	Exemption	Gowdy	Brothers	

Aerospace	Seeks:

This	exemption	will	permit	Gowdy	Brothers	Aerospace	to	commercially	operate	an	Unmanned	Aircraft	

System	(UAS)	for	the	purpose	of	bridge	inspections	and	conducting	aerial	video	and	photography	over	

certain	areas	of	the	United	States.	

G.	Any	Additional	Information,	Views,	Or	Arguments	Available	To	Support	

Gowdy	Brothers	Aerospace's	Request.

This	Petition	is	made	pursuant	to	the	FAA	Modernization	and	Reform	Act	of	2012	(FMRA)	Section	

333,	which	directs	the	Secretary	of	Transportation	to	determine	if	certain	UAS	may	operate	safely	in	

the	NAS.	As	such,	Gowdy	Brothers	Aerospace	request	for	exemption	may	be	granted	pursuant	to	the	

authority	of	FMRA	Section	333	and	14	C.F.R.	Part	11,	as	set	forth	above.	

FMRA	Section	333	sets	forth	the	requirements	for	considering	whether	a	UAS	will	create	a	hazard	to	

users	of	the	NAS	or	the	public,	or	otherwise	poses a	threat	to	national	security	and	further,	provides	

the	authority	for	such	UAS	to	operate	without	airworthiness	certification.	

As	 discussed	 in	 detail	 above,	Gowdy	Brothers	Aerospace	will	 operate	the	 CCO	w/Wkm	 M	 and	HH	

Blade	 350QX3 AP	 UAS's	 safely	 in	the	NAS,	 without	 creating	 a	 hazard	to	 users	 of	 the	NAS,	 or	the	

public,	or	otherwise	pose a	threat	to	national	security.	

CONCLUSION

As	set	forth	herein,	Gowdy	Brothers	Aerospace	seeks	an	exemption	pursuant	to	14	C.F.R.	§	11.61	and	

Section	 333	 of	 the	 FAA	 Modernization	 and	 Reform	 Act	 of	 2012	 (FMRA),	 which	 will	 permit	 safe	

operation	 of	 the	 CCO	 w/Wkm	 M	 and	 HH	 Blade	 350QX3 AP	 UAS's	 commercially,	 without	 an	

airworthiness	certificate,	for	the	limited	purposeof	conducting	aerial	video	and	photography	over	

certain	areas	of	the	United	States.By	granting	this	Petition,	the	FAA	Administrator	will	be	fulfilling	

the	 Congressional	 mandate	 of	 the	 FAA	 Modernization	 and	 Reform	 Act	 of	 2012,	 while	 also	

advancingthe	 interests	 of	 the	 public,	 by	 allowing	 Gowdy	 Brothers	 Aerospace	 to	 safely,	

efficiently,and	 economically	 operate	 the	 CCO	 w/Wkm	 M	 and	 HH	 Blade	 350QX3 AP	 UAS's	

commercially	within	the	NAS.	
Gowdy	Brothers	Aerospace,	LLC						Section	333	Exemption	Submission	version	1.0						April	30,	2015 Page	26

WHEREFORE,	in	accordance	with	the	Federal	Aviation	Regulations	and	the	FAA	Modernization	and	

Reform	 Act	 of	 2012,	 Section	 333,	 Gowdy	 Brothers	 Aerospace	 respectfully	 requests	 that	 the	

Administrator	 grant	 this	 Petition	 for	 an	 exemption	 from	 the	 requirementsof	 14	 C.F.R	 Sections	

61.113(a)	 &	 (b),	 91.7(a),	 91.121,	 91.151(b),	 91.405(a),	 91.407(a)(1),	 91.409(a)(1)	 &	 (a)(2),	 and	

91.417(a)	&	(b),	and	permit	Gowdy	Brothers	Aerospace	to	operate	the	CCO	w/Wkm	M	and	HH	Blade	

350QX3 AP	UAS's	 commercially	for	the	purpose	of	bridge	 inspections	 and	 conducting	 aerial	 video	

and	photography	over	certain	areas	of	the	United	States.	

Dated:	April	30,	2015	

Respectfully	submitted,	

Stephen	C.	Gowdy

Gowdy	Brothers	Aerospace
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APPENDICES:

A	- CCO	w/Wkm	M	Specifications

B	– HH	Blade	350QX3 AP	Specifications

C	- DJI	Wkm	M	User	Manual

D	– HH	Blade	350QX3 AP	User	Manual

E	- Monthly	Maintenance	Log
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APPENDIX	–A

CCO	w/Wkm	M	TECHNICAL	SPECIFICATIONS

Gowdy	Brothers	Aerospace	only utilizes	safe	and	reliable	UAS's.	DJI	is	an	industry	leader	in	small	UAS	

production.	DJI	UAS's	are	loaded	with	ground	breaking	software	enabling	the	user	to	set	parameters	

which	will	not	allow	flight	into	controlled	airspace.	Parameters	can	also	be	set	to limit	flight	to	no	

higher	 than	 a	 predetermined	 and	 set	 altitude	 as	 well	 as	 limit	 flight	 to	 a	 predetermined	 and	 set	

distance.	In	addition,	DJI	software	provides	real-time	altitude	and	location	information	to	the	PIC	via	

the	linked	monitor,	Spektrum	DX	9	Radio	Control	Transmitter	

1.1	CCO	w/Wkm	M	

1.1.1	Aircraft

1.1.1.1	Batteries	–(2)Thunder	Power	5000mAH	LiPo	Battery	

1.1.1.2	Weight,	Flight	–7	lbs. 6	oz. (3345g)

1.1.1.3	Hover	Accuracy–Vertical:	+/-.5m;	Horizontal:	+/-2m	

1.1.1.4	Max	Tilt	Angel	-35deg

1.1.1.5	Max	Ascent/Descent	Speed	–6m/s

1.1.1.6	Max	Flight	Speed	–15m/s	(NOT	RECOMMENDED)	

1.1.2	Gimbal

1.1.2.1	Photohigher	AV200	w/360	Pan

1.1.2.2	Controller	– Hoverfly	Gimbal	3Axis	Control	Board	

1.1.2.3	Battery	2700mAh	2s1.1.2.4	Pan	- Controllable	360deg

1.1.2.5	Pitch	- Controllable	-90deg1.1.2.6	Horizon	– Automatic	

1.1.3	Transmitter	FPV	(CAMERA	OPERATOR	ONLY)

1.1.3.1	Immersion	RC	5.8GHz	AV

1.1.3.2	Power	Out-put	600mW	28dBm	+/- 1dBm

1.1.3.3	Frequencies	5740,	5760,	5780,	5800,	5820,	5840	and	5860MHz

1.1.4	 Camera	

1.1.4.1	Canon	

1.1.4.2	EOS	60	D

1.1.4.3	Effective	Pixels	–18M1.1.4.4	Operating	Temperature	Range	-32deg	F	/	

104deg	F	

1.1.5	 Transmitter	1	Aircraft

1.1.5.1	Spektrum	DX9

1.1.5.2	Operating	Frequency	2.400GHz	– 2.4835GHz

1.1.5.3	Communication	Distance	(unobstructed)	FCC	Compliance	800m	

1.1.5.4	Transmitter	Power	FCC	Compliance	100mW

1.1.5.5	Battery	2000mAh	Li-lon	2S

1.1.5.6	Operating	Temperature	-14deg	to	104deg	F	

1.1.6	Transmitter	2	Gimbal

1.1.6.1	Spektrum	DX81.1.6.2	Operating	Frequency	2.400GHz	– 2.4835GHz

1.1.6.3	Communication	Distance	(unobstructed)	FCC	Compliance	800m	

1.1.6.4	Transmitter	Power	FCC	Compliance	100mW

1.1.6.5	Battery	2000mAh	NiMH	4S

1.1.6.6	Operating	Temperature -14deg	to	104deg	F	
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APPENDIX	–B

HH	Blade	350QX3	AP	TECHNICAL	SPECIFICATIONS

Gowdy	Brothers	Aerospace	 only	utilizes	 safe	 and	 reliable	UAS's.	HH	is	 an	industry	 leader	in	 small	

UAS	 production.	 HH	 UAS's	 are	 loaded	 with	 ground	 breaking	 software	 enabling	 the	 user	 to	 set	

parameters	which	will	not	allow flight	into	controlled	airspace.	Parameters	can	also	be	set	to	limit	

flight	to	no	higher	than	a	predetermined	and	set	altitude	as	well	as	limit	flight	to	a	predetermined	

and	set	distance.	In	addition,	HH	software	provides	real-time	altitude	and	location	information	to	the	

PIC	via	the	linked	RC	Control	Transmitter.	

2.2	HH	Blade	350QX3 AP	

2.2.1	Aircraft2.2.1.1	Battery	– Thunderpower	3300	mAh	LiPo

2.2.1.2	Weight	(Battery	Included)	– 2	lbs	3.5oz	(1006g)

2.2.1.3	Hovering	Accuracy	(GPS	Mode)	–Vertical:	0.5m;	Horizontal:	2.5m	

2.2.1.4	Max	Angular	Velocity	–Pitch:	3000/s;	Yaw:	1500/s

2.2.1.5	Max	Tilt	Angle	-3502.2.1.6	Max	Ascent	Speed	–5m/s

2.2.1.7	Max	Descent	Speed	–4m/s

2.2.1.8	Max	Speed	–22m/s	(ATTI	mode,	no	wind	–NOT	RECOMMENDED)	

2.2.1.9	Max	Flight	Altitude	–4500m

2.2.1.10	Max	Wind	Resistance	–10m/s

2.2.1.11	Max	Flight	Time	–Approximately	13	minutes	

2.2.2	Gimbal

2.2.2.1	Model	– Blade	GB200	2	Axis	Brushless	Gimbal	

2.2.2.2	Controllable	Range	0	deg	to	-90deg

2.2.2.3	Horizon	- Automatic

2.2.2.4	Operating	Temp	-32deg	to	140	F	

2.2.3	Camera

2.2.3.1	Name	– GoPro	

2.2.3.2	Model	– Hero	3	Silver	

2.2.3.3	Pixel	11M	

2.2.4	Transmitter

2.2.4.1	Spektrum	DX9

2.2.4.2	Operating	Frequency	2.400GHz	to	2.4835	GHz

2.2.4.3	Communication	Distance	(unobstructed)	FCC Compliance	800M	

2.2.4.4	Transmitter	Power	FCC	Compliance	100mW

2.2.4.5	Battery	2000mAh	2S	Li-lon	2S

2.2.4.6	Operating Temperature	-14deg	to	104deg	F	
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APPENDIX	– C

DJI	Wkm	M	– Manufacturer's	User	Manual

http://www.dji.com/product/wookong-m
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APPENDIX	– D

HH	Blade	350QX3	AP	Manufacturer’s	User	Manual

http://www.horizonhobby.com/pdf/BLH8100-Manual-EN.pdf
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APPENDIX	– E

Gowdy	Brothers	Aerospace	Monthly	Maintenance	and	Repair	Log

Gowdy	Brothers	Aerospace	will	be	using	and	individual	fight	time,	monthly	maintenance	and	repair	

log	book	for	each	unit	in	operation	the	following	is	an	example	of	the	minimum	logged	information:

Aircraft:	

N-Number:

Hours:	

Date:	

Date	Issue	

Discovered	

Date	Issue	

Resolved	

Issue	Description/

Maintenance Conducted	

Repair/Maintance	

Performed	By	

Airframe	

Motors	

Propellers	

Flight	Control	Update	

Gimbal	

Misc