July 14, 2015 

US Department of Transportation 

Docket Management System 

1200 New Jersey Ave. SE 

Washington, DC 20590 

Re: Exemption Request Pursuant to Section 333 of the FAA Reform Act and Part 11 of 

the Federal Aviation Regulations from: 14 CFR Part 21; 14 CFR 45.29(b)(3); 14 CFR 

91.29(b)(3); 14 CFR 91.9(b)(2); 14 CFR 91.121; 14 CFR 91.151(a)(1) and 14 CFR 

91.405. 

Dear Director, Flight Standards Service 

In accordance with Section 333 of the Modernization and Reform Act of 2012 and 14 

CFR, Part 11, Jeff Flanagan, dba Osprey Aeronautics submits this petition for 

exemption from the several FARs, as noted in Appendix A of this letter in order to begin 

commercial operations using sUAS in the National Airspace governed by the FAA. 

Osprey Aeronautics wishes to begin market research on and begin commercial 

operations in the following areas: 

-Aerial Inspection of Structures 

-Real Estate Photography -General Photography -Special Events -Aerial Security Observation -Adding Local Police & Fire Department Search & Rescue Operations 

-Environmental & Shoreline Erosion Observation -Agriculture -Surveying 

Public Benefit. Being in the public interest, an approved exemption would permit 

Osprey Aeronautics to conduct market research in one or more of the above listed 

operational areas, establish a small business and initiate commercial flight operations; 

the ability to offer services to aid local city and county governments; to introduce sUAS 

aircraft to the public in order to educate and inform the community; to demonstrate 

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-Phantom 3 -Inspire 1 -S900 

30 Robotics: 

-Iris+ -Solo *Note. These aircraft have previous approvals as documented in Exemption Numbers: 

11925, 11976, 11859, 11861, 11969 and 11935. 

Safety. These sUAS weigh less than 55 pounds, including the payload (i.e. camera, 

lens, and gimbal). They operate at speeds of no more than 50 knots, can hover, and 

can simultaneously move vertically and horizontally. The Pilot In Command (PIC) will 

only operate the sUASs in line of sight and will operate only within the restrictions as 

described in previously approved COAs. Such operations will insure that the sUAS will 

not create a hazard to users of the national airspace system or the public. 

Training. The Osprey Aeronautics PIC has over 27 years experience in military 

helicopter flight operations ranging from the maintenance level to rated aviator and PIC 

of single and dual engine helicopters. The PIC currently holds an FAA Commercial 

Rotorcraft, Helicopter, Instrument Certificate and a Class 3 FAA Medical Certificate. 

The PIC has reviewed previously approved Section 333 COAs and will comply with, and 

is capable of conducting flight operations within these restrictions. 

sUAS pilot training will consist of the following stages and topics*: 

1) Ground School 

Flight within COA restrictions 

Airspace and flight regulations 

Aircraft controller and GUI 

Radio link 

Aircraft Operating Limitations 

Emergency Procedures via flight simulator 

Maintenance inspection requirements 

2) Primary Flight Instruction 

Pre-Flight Inspection 

Visual Observer (VO) Briefing and Customer 

Flight Tasks w/GPS 

2 
Aircraft control w/out GPS 

Free Flight 

Camera and Gimbal Operation 

Using the aircraft and camera as a PhotographyNideography system 

4) Three Practice PictureNideo sessions will be successfully completed by 

candidate PIC prior to graduation. 

*Note. At this time these stages and topics are general and will be developed into 

more detailed instruction as experience in flight operations is obtained. 

In regards to privacy, all flights will occur over private, city, county or controlled access 

areas with the property owner's prior consent. Recognizable images will only be 

recorded of people who have given their consent or otherwise have agreed to be in the 

area where active image acquisition will take place. 

Enclosures: 

Appendix A: 14 CFR Sections for Exemption and Equivalent Levels of Safety. 

Appendix B: Summery for Federal Registry 

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a. I request relief in accordance with previously approved petitions which concluded 

that the aircraft requested in the petition meet the statutory criteria provided in 

Section 333. 

b. Public safety will not be jeopardized due to the size, weight and power (SWAP) 

of these aircraft and their manufacture's designed inherent safety features. 

2) 45.29 (b)(3), Size of marks. 

a. Relief is requested in that due to the small size of the aircraft in this petition, the 

section's 12-inch lettering for rotorcraft requirement will not fit on any surface of the 

sUAS. Instead it is recommended that the N-number will be displayed in the 

largest font size permitted by the sUAS structure and fuselage. 

b. No adverse effect on safety is anticipated and the intent of the section will be 

fulfilled. 

3) 91.7 (a), Aircraft airworthiness. 

a. The aircraft in this petition are sUAS and have not been submitted to the FAA 

aircraft airworthiness standards. Relief from this requirement is requested and is 

evident that the aircraft have demonstrated their airworthiness from current 

manufacturing standards and history. Additionally, the aircraft in this petition have 

received exemption from Section 333, per Exemption No.: 11925, 11976, 11400 

(DJI Phantom 3, Inspire 1 & S900), 11859, 11861 (3DR Iris+), 11935 (3DR Solo). 

b. An equivalent level of safety is ensured by following the manufacture's 

operation/maintenance manual, pre-flight inspections and maintenance inspections 

as listed below in paragraph 7. 

4) 91.9 (b)(2), Civil aircraft flight manual, marking and placard requirement. 

a) Relief is sought from placing the flight manual in the aircraft, but to co-locate the 

flight manual near the hand-held flight control device. The intent of the section is 

to provide for in-flight reference to the flight manual, and this same ability by the 

aircraft Pilot in Command (PIC) of the sUAS, on the ground, will be ensured by its 

location near the flight controller. Additionally, sUAS are software (SW) centric 

and a majority of the PIC required in-flight performance data and emergency 

procedures are viewable only by interfacing with the Graphic User Interface (GUI) 

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5) 91.121, Altimeter setting. 

a. Relief is sought from this requirement to set cruising altitude or flight level by 

reference of an altimeter as the sUAS in this petition are GPS position and altitude 

initiated on the ground, with no on board radio present, therefore the current 

location's GPS altitude (in effect, the local airfield altitude) is set prior to flight and 

the sUAS are restricted via SW to no higher altitude then 400 feet; sUAS will not be 

conducting cross country flights, but in essence will be conducting in and out of 

ground effect hovering operations. 

b. No increased risk to public safety is incurred as all participating aircraft at low 

altitudes should be concerned with obstacle avoidance and using prescribed visual 

scans to avoid traffic. 

6) 91.151 (a)(1 ), Fuel requirements for flight in VFR conditions. 

a. Relief is sought for the requirement of a 30 minute fuel (Battery power) reserve. 

The sUAS in this petition are battery powered and have current battery level 

indications present on the controller screens, also these aircraft are SW controlled 

and have manufacturer mandated automatic "Return to home" commands when 

minimum battery power is reached. Intent of this section is to allow a manned 

aircraft time to reach an airport/heliport for a successful landing, however with the 

small size of these aircraft, a low battery induced landing may be successfully 

achieved in nearly any open area of only several feet in diameter. 

b. An equivalent or superior level of safety will be achieved by the manufacture's 

SW requiring an automatic return to take-off point upon reaching a low battery level 

if the PIC fails to act, also that the aircraft in this petition have the ability to land 

nearly anywhere without disrupting other local flight operations, interfering with 

ground traffic or endangering human life. 

7) 91.405, 91.407, 91.409 and 91.417, Maintenance required, Inspections and 

Records. 

a. Relief is sought from this section's maintenance requirement for having FAA 

certified repairman conduct aircraft inspections and certified aircraft repairs. The 

aircraft in this petition are mechanically simple and lightweight and minor repairs 

are capable of being performed by the PIC/ aircraft owner. Software and firmware 

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reliability are incorporated into these sUAS. Adherence to the manufactures 

maintenance manual will ensure proper aircraft operations and in cases of poorly 

written manuals, the designated PIC will perform a pre-flight, thru-flight and/or postflight inspection, also a designated PIC or maintainer will perform the following: a 

monthly mechanical inspection, corrosion inspection and aircraft cleaning (Aircraft 

wash), and every 365-days a comprehensive mechanical inspection. 

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Airspace governed by the FAA: 14 CFR Part 21; 14 CFR 45.29(b)(3); 14 CFR 

91.29(b)(3); 14 CFR 91.9(b)(2); 14 CFR 91.121; 14 CFR 91.151(a)(1) and 14 CFR 

91.405. 

Benefiting the public interest, an approved exemption would permit Osprey Aeronautics 

to conduct commercial flight operations using sUAS which will provide for establishing a 

small business opportunity; the ability to offer services to aid local city and county 

governments; and to introduce sUAS aircraft to the public in order to educate and inform 

the community of locally manned aviation operations how sUAS can safely interact with 

them in the National Airspace. 

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