Washington, DC 20590 

Subject: Exemption Request Section 333 of the FAA Reform Act and Part 11 of the Federal 

Aviation Regulations 

Dear Sir or Madam: 

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the "Reform Act") and 14 

C.F.R. Part 11, Proxy Technologies, Inc. ("Proxy"), the operator of Small Unmanned Aircraft Systems 

("sUASs"), including the following Proxy selected sUAS platforms: 

Manufacturer Model 

CineStar X8 MK Heavy Lift RTF 

Aerial Technology International ThorX4 

Kespry Kespry Drone System 

Trimble UX5 

3DR AERO 

PrecisionHawk Lancaster 

Table 1 Proxy Selected sUAS Platforms 

seeks an exemption from the Federal Aviation Regulations ("FARs") listed below and discussed in 

1 

Appendix A Proxy seeks exemption from the listed FARs to allow its use of the sUAS Platforms listed in 

Table 1 above in commercial operations, developing control software for testing and use in for precision 

aerial surveys, including agriculture as well as flight demonstrations, tower inspections, surface mining, 

roof inspections, telecommunications and utility structure inspection, construction, maintenance services, 

flood control, first responders, bridge inspections, dam inspections, special events, and structural 

assessments (hereafter collectively grouped and known as aerial surveys), so long as such operations are 

conducted within and under the conditions outlined herein or as established by the FAA in an exemption 

granted under either Section 333 or Section 49 U.S.C. § 44 701 (f).2 

As highlighted in pages 4-7 below, Proxy is willing to abide by conditions the FAA has required in 

issuing recent Section 333 exemptions, specifically Exemptions 11109 (Ciayco, Inc.), 11110 (Trimble 

Navigation Ltd.), 11215 (B.E.V. Roof Inspections), 11171 (Asymmetric Technologies), 11230 (Montico 

Inc.), and 11241 (Phoenix Air Unmanned). This agreement on Proxy's part and the strong similarity of 

its operations to those approved in Exemptions 11109, 11110, 11215, 11171, 11230 and 11241 should 

give the FAA a basis for prompt consideration and processing of this request. 

1 See Pub. Law 112-95, 126 Stat. 11, § 333 (2012). 

2 Proxy relies upon the following exemptions where specific reference to an exemption is not provided: Exemptions 

11062 through 11067, 11080, 11109 through 11112 software that identifies disease and insects, nutrient deficiencies, 

and materials for increasing yields with fewer resources. Expedite damage assessments and infrastructure 

maintenance in support of a variety of industries, including but not limited to, telecommunications, mining companies, 

local and federal emergency responders and companies that require aerial survey of property(s). 

1840 Michael Faraday Dr., Suite 220, Reston, VA 20190 Tel: 703·485-1035 Fax: 301- 216-2852 
y 

y p

g 

g

q

y 

sUAS Platforms listed in Table 1 above would contribute to various social goods, from environmental 

protection to improved crop yields, safety inspections, property damage assessment, and search and 

rescue. In providing these services, Proxy could empower crop researchers and farmers to make better 

management decisions through software that identifies disease and insects, nutrient deficiencies, and 

materials for increasing yields with fewer resources. Additional uses includes expedite damage 

assessments and infrastructure maintenance in support of a variety of industries, including but not limited 

to, telecommunications, mining companies, local and federal emergency responders and companies that 

require aerial survey of property(s). 

The use of sUASs on a construction site can significantly reduce the risk to workers of falls while 

inspecting, surveying, or monitoring site progress. sUASs can inspect, photograph, and collect data on 

hard to get to areas that otherwise would require worker inspection. Falls are the leading source of 

workplace fatality and injury on construction sites, and reducing falls through sUAS use for site imaging 

could save workers lives. 

The petitioner states that, performing infrastructure inspections with unmanned systems is a benefit to 

the public for the following reasons: 

1) the operation significantly improves safety and reduces risk by alleviating human exposure to 

the dangers associated with aerial survey and inspection; 

2) it will not be necessary to close a lane on the bridge while the inspection is being conducted; 

this significantly improves traffic flow and safety; 

3) the UAS being operated is very small and contain no flammable fuel and in the remote event 

of an accident, will cause no damage or injuries; and 

4) given that the cost to conduct an inspection using a UAS is considerably less than available 

alternatives, this important task can be accomplished which will benefit everyone utilizing this 

infrastructure. 

Operations under the exemption will be subject to strict operating requirements and conditions to ensure 

at least an equivalent level of safety to currently authorized operations using manned aircraft and under 

conditions as may be modified by the FAA as required by Section 333. 

As described more fully below, the requested exemption would authorize commercial operations of 

aerial surveys using the sUAS Platforms listed in Table 1 above; all of which are below a maximum 

take-off weight of 55 lbs. in size. The sUAS Platforms listed in Table 1 above will be operated under 

controlled conditions at low altitude in airspace that is limited in scope, as described more fully herein; 

they will have automated control features, as described herein. The sUAS Platforms listed in Table 1 

above also will be operated by an individual possessing a minimum of a private pilot certificate. Finally, 

the airspace in which the UAS will operate will be disclosed to the FAA in advance. 

Proxy respectfully submits that because these small, unmanned aerial vehicles - the sUAS Platforms 

listed in Table 1 above- will be used in lieu of comparatively hazardous operations now conducted with 

fixed wing and rotary conventional aircraft, the FAA can have confidence that the operations will achieve 

at least an equivalent level or greater level of safety. Approval of this exemption would thereby enhance 

safety and fulfill the Secretary of Transportation's (the FAA Administrator's) responsibilities under 

1840 Michael Faraday Dr., Suite 220, Reston, VA 20190 Tel: 703·485-1035 Fax: 301- 216-2852 2 
Office: 703-485-1035 

Mobile: 240-454-2053 

Email: rdavis@proxytechnologies.com 

The regulations from which the exemption is requested are as follows: 

14 C.F.R. §61 .113(a) & (b); 

14 C.F.R. § 61.133(a); 

14 C.F. R. § 91.7(a); 

14 C.F.R. § 91 .119(c); 

14 C.F.R. § 91 .151(a); 

14 C.F.R. § 91.405(a); 

14 C.F.R. § 91.407(a)(1) 

14 C.F.R. § 91.409(a)(1)(2) 

14 C.F.R. § 91.417(a) & (b) 

Appendix A discusses each rule listed above and explains why exemptions pursuant to the proposal 

set forth in this letter are appropriate, provide an equivalent level of safety, and are in the public 

interest. Appendix B provides the requisite Federal Register summary. 

THE APPLICABLE LEGAL STANDARD UNDER SECTION 333 

Proxy submits that granting of this exemption application for use of the sUAS Platforms listed in Table 1 

above in precision aerial surveys will advance the Congressional mandate in Section 333 of the Reform 

Act to accelerate the introduction of UASs into the national airspace system ("NAS") if it can be 

accomplished safely. This law directs the Secretary of Transportation to consider whether certain UASs 

may operate safely in the NAS before completion of the rulemaking required under Section 332 of the 

Reform Act. In making this determination, the Secretary is required to determine which types of UASs do 

not create a hazard to users of the NAS or the public or pose a threat to national security in light of the 

following: 

)> The UAS's size, weight, speed, and operational capability; 

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

)> Operation of the UAS within visual line of sight of the operator. Reform Act §333(a)(1 ). If the 

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

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

airspace system." /d. § 333(c) (emphasis added). The Federal Aviation Act expressly grants the 

FAA the authority to issue exemptions. This statutory authority, by its terms, includes exempting 

civil aircraft, as the term is defined under § 40101 of the Act, from the requirement that all civil 

aircraft must have a current airworthiness certificate and those regulations requiring commercial 

pilots to operate aircraft in commercial service. The Administrator may grant an exemption from 

1840 Michael Faraday Dr., Suite 220, Reston, VA 20190 Tel: 703-485-1035 Fax: 301- 216-2852 3 
49 U.S.C. § 44701(f). See also 49 U.S.C. § 44711(a); 49 U.S.C. § 44704; 14 C.F.R. §91.203(a)(1). 

The grant of the requested exemption is in the public interest based on the clear direction in Section 

333 of the Reform Act; the additional authority in the Federal Aviation Act, as amended; the strong 

equivalent level of safety surrounding the proposed operations; and the significant public benefit, 

including enhanced safety and cost savings associated with transitioning to UASs for aerial surveying. 

Accordingly, the applicant respectfully requests that the FAA grant the requested exemption without 

delay.3 

AIRCRAFT AND EQUIVALENT LEVEL OF SAFETY 

The applicant proposes that the exemption requested herein apply to civil aircraft that have the 

characteristics and that operate with the limitations listed herein. These limitations provide for at least 

an equivalent or even higher level of safety to operations under the current regulatory structure 

because the proposed operations represent a safety enhancement to operations that would be 

conducted with conventional aircraft. These conditions are drawn from Exemptions 11062 through 

11067, 11080, 11109, 11110, 11215, 11171, 11230 and 11241. 

These limitations and conditions to which Proxy (or "operator'') agrees to be bound when conducting 

commercial operations under an FAA issued exemption include: 

1. Operations of the sUAS Platforms listed in Table 1 above are limited to the aircraft described 

in the attached manuals, which is a miniature propeller airplane built by the manufacturer 

listed in Table 1 above that weighs less than fifty five (55) pounds (the "UA" or "UAS"). 

Proposed operations of any additional aircraft will require a new petition or a petition to 

amend this grant.4• 

2. Operations of the sUAS Platforms listed in Table 1 above are limited to the aircraft described 

in the attached manuals, which is a miniature propeller quadcopter bui lt by manufacturer 

listed in Table 1 above that weighs less than fifty five (55) pounds (the "UA" or "UAS"). 

Proposed operations of any additional aircraft will require a new petition or a petition to 

amend this grant 

3. The UA may not be flown at an indicated airspeed exceeding 100 knots. 

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

3 ln filing this application, Proxy also is requesting that the FAA combine the grant of the Section 333 exemption 

with a stand-alone Certificate of Operation (COA) that will allow commercial operations of the sUAS Platforms 

listed in Table 1 above without the necessity of filing for a COA for each flight up to 400 feet. Compliance with 

the conditions agreed to herein and that may be imposed by the FAA, as set forth in prior Section 333 

exemptions, provide the separation needed from other aircraft. Notice to airmen and notice to air traffic control 

can be provided by the filing of a NOTAM as set forth within the proposed conditions 

4 Proxy is submitting under a request for confidentiality the flight operations manuals and aircraft flight manuals 

for the sUAS Platforms listed in Table 1 above (manuals). 

1840 Michael Faraday Dr., Suite 220, Reston, VA 20190 Tel: 703-485-1035 Fax: 301-216-2852 4 
6. All operations must utilize a visual observer (VO). 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. 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 functions prescribed in the operator's manual. 

7. The manuals must be amended to include all conditions and limitations required by the FAA. 

The manuals must be maintained and made available to the Administrator upon request. If a 

discrepancy exists between the conditions and limitations in the exemption and the 

procedures outlined in the manuals, the conditions and limitations in the exemption take 

precedence and must be followed. Otherwise, the operator must follow the procedures as 

outlined in the manuals. The operator may update or revise the manuals. 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 an extension or amendment of this 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 amendment to its exemption. 

8. Prior to each flight, the PIC must inspect the UAS to ensure 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. 

9. 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 in accordance with the operator's manual. The PIC who conducts the functional test flight must make an entry in the UAS aircraft records of the flight. The manuals 

include this requirement. 

10. The preflight inspection section in the manuals includes the following requirement: the 

preflight inspection must account for all discrepancies, i.e., inoperable components, items, 

or equipment, not covered in the relevant preflight inspection sections of the operator's 

manual. 

11 . The operator must follow Proxy's UA aircraft/component, maintenance, overhaul, 

replacement, inspection, and life limit requirements, with particular attention to flight critical 

components that may not be addressed in the manufacturer's manuals. 

12. Operator must carry out its maintenance, inspections, and record keeping requirements in 

accordance with the manuals. Maintenance, inspection, and alterations must be noted in the 

aircraft logbook, including total flight hours, description of work accomplished, and the 

signature of the authorized technician returning the UAS to service. 

1840 Michael Faraday Dr., Suite 220, Reston, VA 20190 Tel: 703-485-1035 Fax: 301- 216-2852 5 
between inspections. 

16. The PIC must possess at least a private pilot certificate and a third-class airman medical 

certificate. The PIC must also meet the flight review requirements specified in 14 C.F.R. 

61 .56 as to the UAS. 

17. The operator may not permit any PIC to operate unless that PIC has demonstrated through 

Proxy's training and currency requirements that the PIC is able to safely operate the UA in 

a manner consistent with how the UAS will be operated under this exemption, including 

evasive and emergency maneuvers and maintaining appropriate distances from people, 

vessels, vehicles, and structures. 

18. If the UAS loses communications or loses its GPS signal, the UA must return to a predetermined location within the private or controlled-access property and land or be 

recovered in accordance with the manuals. 

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

accordance with the manuals. 

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

weather conditions) there is enough power to fly to the first point of intended landing and, 

assuming normal cruising speed. to fly after that for at least 1 0 minutes. 

21 . The operator will file a request for a Notice to Airmen (NOTAM) not more than 72 hours in 

advance, but not less than 48 hours prior to the operation. 

22. 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. 

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

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

appropriate government oversight agency requirements. 

24. The documents required under 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 aircraft is operating. These documents 

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

25. The UA must remain clear and yield the right of way to all other manned operations and 

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

parasailing activities, hang gliders, etc.). 

1840 Michael Faraday Dr., Suite 220, Reston, VA 20190 Tel : 703-485-1035 Fax: 301-216-2852 6 
30. During operations in Class G airspace, the UA may not operate within 5 nautical miles of 

the geographic center of an airport 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. 

31 . The UA may not be operated over congested or densely populated areas unless the 

conditions set forth in #31 are satisfied. These populated areas include, but are not limited 

to, the yellow areas depicted on World Aeronautical Charts (WAC), Sectional Aeronautical 

Charts (Sectionals), or Terminal Area Charts (TAC). However, aeronautical charts may not 

reflect pertinent local information. Ultimately, it is the PIC's responsibility to maintain the 

minimum safe altitudes required by § 91.119. 

32. Operations must be conducted at least 500 feet from all nonparticipating persons (persons 

other than the those participating in the experiment such as the PIC or VO), vessels, 

vehicles, and structures unless: 

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

from debris in the event of an accident. The operator must ensure that 

nonparticipating persons remain under such protection. If a situation arises in which 

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 land 

owner/controller has granted permission and the PIC has made a safety assessment 

of the risk of operating closer to those objects; and 

c. operations near the PIC or VO do not present an undue hazard to the PIC or VO, per 

§91.119(a). 

33. 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. 

34. In the event COAs are required, 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. 

1840 Michael Faraday Dr., Suite 220, Reston, VA 20190 Tel: 703-485-1035 Fax: 301-216-2852 7 
g

p

************* 

In summary, Proxy seeks an exemption from the FARs set forth in Appendix A to operate commercially a 

small unmanned vehicle (55 lbs. or less) in aerial survey operations. 

Approval of this exemption for commercial aerial survey operations will enhance safety by reducing risk. 

Conventional operations, using jet or piston powered aircraft, operate at extremely low altitudes just feet 

from the subject being inspected and in extreme proximity to people and structures. Such manned 

operations present the risks associated with vehicles that weigh in excess of 6,000 lbs., carrying large 

amounts of jet A or other fuel. Such aircraft must fly to and from the project location. In contrast, a sUAS 

weighing fewer than fifty five pounds and powered by batteries eliminates virtually all of that risk given 

the reduced mass and lack of combustible fuel carried on board. The sUAS is carried to the target area 

and not flown. The sUAS will carry no passengers or crew and, therefore, will not expose them to the 

risks associated with manned aircraft flights. 

The operation of small UASs, weighing less than fifty five pounds, conducted in the strict conditions 

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

requested herein. These lightweight aircraft operate at slow speeds, close to the ground, and in areas 

that are under the control of the customer. As a result, they are far safer than conventional operations 

conducted with manned aircraft operating in close proximity to the ground and people. 

Satisfaction of the criteria provided in Section 333 of the Reform Act of 2012 - size, weight, speed, 

operating capabilities, proximity to airports and populated areas, and operation within visual line of sight 

and national security - provide more than adequate justification for the grant of the requested 

exemptions allowing commercial operation of applicant's UAS for the Purposes outlined herein and are 

consistent with exemptions already granted, including Exemptions 11062 through 11067, 11080, 11109 

through 11112, and 11114. 

Sincerely, 

Robert F. Davis, CEO 

Proxy Technologies Inc 

1840 Michael Faraday Dr., Suite 220, Reston, VA 20190 Tel: 703·485·1035 Fax: 301- 216-2852 8 
14 C.F.R. § 61 .113(a) & (b); 61 .133(a): Private Pilot Privileges and Limitations; Pilot in Command; 

Commercial Pilot Privileges and Limitations. 

Section 61 .113(a) & (b) limit private pilots to non-commercial operations. Unlike a conventional aircraft that 

carries a pilot, passengers, and cargo, the sUAS Platforms listed in Table 1 above are, in this case, 

remotely controlled with no passengers or property of others on board. Section 61 .133(a) requires an 

individual with a commercial pilot's license to be pilot in command of any aircraft for compensation or hire. 

Proxy respectfully proposes that operator requirements should take into account the characteristics of the 

particular sUAS. Proxy's sUAS Platforms listed in Table 1 above have a high degree of pre-programmed 

control and various built-in technical capabilities that strictly limit the potential for operation outside of the 

operating conditions set forth in the exemption application. 

The sUAS Platforms listed in Table 1 above have an autonomous navigation and control system. Flights 

are pre- programmed with precision GPS guidance and do not require human intervention. In the case of 

unplanned events, the operator can manually intervene to take one of the following actions: (i) command 

the aircraft to begin to autonomously return to the recovery area and land; (ii) command the aircraft to 

autonomously return to the recovery area where the pilot will assume control and land the aircraft; or (iii) 

manually assume control of the aircraft via the hand controller and return the craft to the recovery area 

where the operator lands it. 

Additional automated safety functions and safety enhancing features of the sUAS Platforms listed in Table 

1 above include the following: 

)> Auto-pilot detection of lost GPS or of insufficient satellites initiates a stand-by loiter pattern until 

such time as GPS is re-established or the PIC assumes manual control of the aircraft. 

)> Low battery power on the aircraft (1 0.4 volts) triggers the landing sequence and the craft will fly to 

the recovery area. 

)> If the auto-pilot detects a lost-link to the ground control station for longer than 30 seconds, landing 

procedure begins. 

)> The aircraft, weighing fewer than 55 lbs., fully loaded, is constructed of foam, which is intended to 

absorb impact energy. 

* In the event the ground station reaches a low power state, it will alert the pilot. Given these 

safety features, Proxy proposes that operators of the sUAS Platforms listed in Table 1 above 

should not be required to hold a commercial pilot certification. Instead, operators should be 

required to hold only a private pilot certification. The risks associated with the operation of the 

sUAS Platforms listed in Table 1 above (given the size, speed, operational capabilities, and 

lack of combustible fuel) are so diminished from the level of risk associated with commercial 

operations contemplated by Part 61 with conventional aircraft (fixed wing or rotorcraft) that 

allowing operations of the UAS as set forth above meets or exceeds the present level of safety 

provided under 14 C.F.R. § 61 .113(a) & (b) and does not rise to the level of requiring a 

commercial pilot to operate the aircraft under § 61.133(a). 

1840 Michael Faraday Dr., Suite 220, Reston, VA 20190 Tel: 703-485-1035 Fax: 301- 216-2852 9 
Should the exemption be granted allowing commercial operation of the sUAS Platforms listed in Table 1 

above without an airworthiness certificate, no standard will exist for airworthiness of the sUAS Platforms 

listed in Table 1 above. Given the size of the aircraft and the requirements that the operator has agreed 

to as relates to airworthiness, as set forth in the attached manuals, an equivalent level of safety will be 

achieved by ensuring compliance with the Proxy manuals prior to each flight. The FAA has granted 

exemptions to conduct similar operations in Exemptions 11062 through 11067, 11080, 11109, and 

11110. 

14 C.F.R. § 91 .119(c): Minimum Safe Altitudes 

Section 91.119 establishes safe altitudes for operation of civil aircraft. Specifically, 91.119(c) limits 

aircraft flying over areas other than congested areas to "an altitude of 500 feet above the surface, except 

over open water or sparsely populated areas. In those cases, the aircraft may not be operated closer 

than 500 feet to any person, vessel, vehicle, or structure." 

As set forth herein, the sUAS Platforms listed in Table 1 above will never operate at higher than 400 feet 

AGL. It will, however, be operated to avoid congested or populated areas that are depicted in yellow on 

VFR sectional charts. Because aerial survey work must be accomplished at relatively low altitudes and 

at altitudes less than 500 feet AGL, an exemption from Section 91 .11 9(c) is needed. 

The equivalent level of safety will be achieved given the size, weight, speed, and material with which the 

sUAS Platforms listed in Table 1 above are built. Also, no flight will be taken without the permission of 

the landowner or those who control the land as well as local officials. Because of advance notice to the 

landowner, all affected individuals will be aware of the survey flights. Compared to aerial survey 

operations conducted with aircraft or rotorcraft weighing far more than 5.5 lbs. and carrying flammable 

fuel, any risk associated with these operations will be far less than the risks currently posed by 

conventional aircraft operating at or below 500 feet AGL. Indeed, the low-altitude operations of the UAS 

will maintain separation between these smaii-UAS operations and the operations of conventional aircraft 

that must comply with Section 91 .119. The FAA has granted exemptions to conduct similar operations in 

Exemptions 11062 through 11067, 11080, and 1110. 

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

This regulation prohibits an individual from beginning "a flight in an airplane under VFR conditions unless 

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

landing and, assuming normal cruising speed - (1) During the day, to fly after that for at least 30 

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

The batteries powering the sUAS Platforms listed in Table 1 above provide approximately 40 to60 

minutes of powered flight. Without an exemption from§ 14 C.F.R. 91.151, the UAS's flights would be 

limited to approximately 30 minutes in length. Given the limitations on its proposed operations and the 

location of those proposed operations, a longer time frame for flight in daylight VFR conditions is 

reasonable. 

1840 Michael Faraday Dr., Suite 220, Reston, VA 20190 Tel: 703-485-1035 Fax: 301-216-2852 10 
Proxy believes that an equivalent level of safety can be achieved by maintaining 15 minutes of reserve 

fuel, which, allowing 45 minutes of flight time, would be more than adequate to return the UAS to its 

planned landing zone from anywhere in its operating area. 

Similar exemptions have been granted to other operators, including Exemptions 2689F, 5745, 10673, 

10808, and Exemptions 11062 through 11067, 11080, 11109, 1110, and 11112. 

14 C.F.R. § 91.405(a); 407(a)(1); 409(a)(2); 417(a) & (b): Maintenance Inspections 

Section 91 .405(a) requires that an aircraft operator or owner "shall have that aircraft inspected as 

prescribed in subpart E of this part and shall between required inspections, except as provided in 

paragraph (c) of this section, have discrepancies repaired as prescribed in part 43 of this chapter .. .. " 

Section 91.407 similarly makes reference to requirements in Part 43; 

Section 91.409(a)(2) requires an annual inspection for the issuance of an airworthiness certificate. 

Section 91.417(a) requires the owner or operator to keep records showing certain maintenance 

work that has been accomplished by certificated mechanics, under Part 43, or licensed pilots and 

records of approval of the aircraft for return to service. 

Maintenance of the sUAS Platforms listed in Table 1 above will be accomplished by the owner/operator 

pursuant to the manuals attached as confidential exhibits. An equivalent level of safety will be achieved 

because the UAS is small in size, will carry a small payload, will operation only in restricted 

predetermined areas and is not a complex mechanical device. As provided in the attached manuals, the 

operator will ensure that the UAS is in working order prior to initiating flight, perform required 

maintenance, and keep a log of any maintenance that is performed; moreover, the operator is the 

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

and to ensure an equivalent level of safety. The FAA has granted exemptions for similar operations in 

Exemptions 11062 through 11067, 11080, 11109, 

11110, and 11112. 

1840 Michael Faraday Dr., Suite 220, Reston, VA 20190 Tel : 703·485-1035 Fax: 301- 216-2852 11 
14 C.F.R. § 61 .113(a) & (b); 14 C.F.R. § 61.133(a); 14 C.F.R. § 91.7(a); 14 C.F.R. § 91.119(c); 

14 C.F.R. § 91 .151(a); 14 C.F.R. § 91.405(a); 14 C.F.R. § 91.407(a)(1); 14 C.F.R. § 91.409(a)(2); 

14 C.F.R. § 91.417(a) & (b) 

1840 Michael Faraday Dr., Suite 220, Reston, VA 20190 Tel: 703-485-1035 Fax: 301-216-2852 12