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IN THE MATTER OF THE PETITION FOR EXEMPTION OF:

PRICE AVIATION GROUP FOR AN EXEMPTION SEEKING RELIEF FROM THE 

REQUIREMENTS OF

TITLE 14 OF THE CODE OF FEDERAL REGULATIONS

CONCERNING OPERATION OF SMALL

UNMANNED AIRCRAFT SYSTEMS PURSUANT TO SECTION 333 OF

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

Submitted on December 6, 2014

Christopher Lawler

Price Aviation Group

422 Blossom Ln. 

Frederick, MD 21701
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GLOSSARY

AGL Above Ground Level

ATC Air Traffic Control

COA Certificate of Authorization

FAA Federal Aviation Administration

FAR Federal Aviation Regulation

GCS Ground Control Station

NAS National Airspace System

PIC Pilot In Command

sUAS Small Unmanned Aircraft System

VFR Visual Flight Rules

VMC Visual Meteorological Conditions

VO Visual Observer

VLOS Visual Line of Sight
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TABLE OF CONTENTS

GLOSSARY 2

SUMMARY 3

BACKGROUND 3

BASIS FOR PETITION 5

NAME AND ADDRESS OF PETITIONER 5

THE SPECIFIC SECTIONS OF 14 C.F.R. FROM WHICH PRICE AVIATION 

GROUP SEEKS EXEMPTION 5-9

THE EXTENT OF RELIEF PRICE AVIATION GROUP SEEKS AND THE 

REASON PRICE AVIATION GROUP SEEKS THE RELIEF 9-11

THE REASONS WHY GRANTING PRICE AVIATION GROUPS REQUEST 

WOULD BE IN THE PUBLIC INTEREST 11

THE REASONS WHY GRANTING THE EXEMPTION WOULD NOT 

ADVERSELY AFFECT SAFETY 11-15

SUMMARY THAT CAN BE PUBLISHED IN THE FEDERAL REGISTER 15

CONCLUSION 15
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SUMMARY

Price Aviation Group (PAG) seeks exemption to operate a sUAS under Section 

333 of the FAA Modernization and Reform Act of 2012. This exemption will allow PAG 

to operate a UAS for the purposes of aerial photography and inspection in a controlled, 

sterile environment. PAG will be operating a proven airframe to accomplish flights with 

an equivalent or better level of safety to manned operations. 

BACKGROUND

PAG is a company focused on cost-effective, safe solutions to aerial inspections 

and photography. The company principal is an Airline Transport Pilot and former Line 

Check airmen with an accreditation from the American Association of Airport Executives 

as a Certified Member. Having firsthand knowledge of the National Airspace system 

from the ground and in the air gives PAG an advantage in operating small UAS. In 

addition to flying professionally and understanding airport management, the principal 

also has experience in Radio Control (R/C) operations. R/C operations similar to 

professional flying require a standard of care to operate safely from checklists to postflight review. The standards in PAG operations will mirror Part 121 operations. 

Each flight will be carefully coordinated to ensure safe operations as described in 

exemptions that have been granted and included in this petition. In any aviation 

operation, the discipline to ensure a safe operation needs to the first priority. PAG will 

only conduct flights where the environment can be controlled and no hazard to the public 

can occur. This will be accomplished through use of the procedures detailed in this 

document. 

PAG will be using tried and true technology from 3DR to perform appropriate 

missions. The 3DR product includes redundancy required by previous exemptions. 

Information on the sUAS will be included as an appendix to this document. The 

technology that is available from this company includes the necessary restrictions on 

performance to comply with FAA requirements: 

X8+ Operating Limits

Maximum Altitude* 100'm'(328 ft)

Range* 300'm'(984'ft)'from'launch point

GPS Lock GPS'lock'required'at'all times

Maximum'estimated'flight' time 15min
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Payload capacity 800 g (1.7 lbs)

 (Appendix)

BASIS FOR THE PETITION

In accordance with 14 C.F.R. § 11.81, PAG provides the following information in 

support of its petition for exemption:

A. Name And Address Of The Petitioner.

The name and address of the Petitioner is:

Price Aviation Group

422 Blossom Ln. 

Frederick, MD 21701

Specific contact information:

Christopher Lawler

422 Blossom Ln.

Frederick, MD 21701

Tel: 570-850-8924

Email: clawler@priceav.com

B. The Specific Sections Of 14 C.F.R. From Which PAG Seeks Exemption

1. Section 61.113(a) and (b) prescribesthat—

(a) No person who holds a private pilot certificate may act as a pilot in 

command of an aircraft that is carrying passengers or property for 

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

act as pilot in command of an aircraft.

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

of an aircraft in connection with any business or employment if:

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

and

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

2. Section 91.103 prescribes, in pertinent part, that each pilot in command shall,

before beginning a flight, become familiar with all available information 

concerning that flight, to include—

(a) For a flight under IFR or a flight not in the vicinity of an airport,

weather reports and forecasts, fuel requirements, alternatives available 

if the planned flight cannot be completed, and any known traffic 

delays ofwhich the pilot in command has been advised by ATC;

(b) For any flight, runway lengths at airports of intended use, and the

following takeoff and landing distance information:

(1) For civil aircraft for which an approved Airplane or

Rotorcraft Flight Manual containing takeoff and landing 

distance data is required, the takeoff and landing distance 

data contained therein; and

(2) For civil aircraft other than those specified in paragraph 

(b)(1) of this section, other reliable information appropriate 

to the aircraft, relating to aircraft performance under 

expected values of airport elevation and runway slope, 

aircraft gross weight, and wind and temperature.

3. Section 91.119 prescribes that, except when necessary for takeoff or landing, 

noperson may operate an aircraft below the following altitudes:

(a) Anywhere. An altitude allowing, if a power unit fails, an

emergency landing without undue hazard to persons or property 

on the surface.

(b) Over congested areas. Over any congested area of a city, town, or 

settlement, or over any open air assembly of persons, an altitude of

1,000 feet above the highest obstacle within a horizontal radius of 

2,000 feet of the aircraft.

(c) Over other than congested areas. An altitude of 500 feet above the

surface, except over open water or sparsely populated areas. In those 

cases, the aircraft may not be operated closer than 500 feet to any 

person,vessel, vehicle, or structure.

(d) Helicopters, powered parachutes, and weight-shift-control aircraft. 
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Ifthe operation is conducted without hazard to persons or property 

on the surface—

(1) A helicopter may be operated at less than the minimums

prescribed in paragraph (b) or (c) of this section, provided 

each person operating the helicopter complies with any routes 

or altitudes specifically prescribed for helicopters by the FAA;

and

(2) A powered parachute or weight-shift-control aircraft may be 

operated at less than the minimums prescribed in paragraph 

(c) of this section.

4. Section 91.121 requires, in pertinent part, each person operating an aircraft to

maintain cruising altitude by reference to an altimeter that is set “to the 

elevation of thedeparture airport or an appropriate altimeter setting available 

beforedeparture.”

5. Section 91.151(a) prescribes that no person may begin a flight in an airplane

under VFR conditions unless (considering wind and forecast weather 

conditions) thereis enough fuel to fly to the first point of intended landing 

and, assumingnormal 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. 

[emphasis added]

6. Section 91.405(a) requires, in pertinent part, that an aircraft operator or owner

shall have that aircraft inspected as prescribed in subpart E of the same part 

and shall, between required inspections, except as provided in paragraph (c) of 

the same section, have discrepancies repaired as prescribed in part 43 of the

chapter.

7. Section 91.407(a)(1) prohibits, in pertinent part, any person from operating an

aircraft that has undergone maintenance, preventive maintenance, rebuilding, 

or alteration unless it has been approved for return to service by a person 

authorized under § 43.7of the same chapter.

8. Section 91.409(a)(2) prescribes, in pertinent part, that no person may operate an

aircraft unless, within the preceding 12 calendar months, it has had an 

inspection for the issuance of an airworthiness certificate in accordance with 

part 21 of this chapter.

9. Section 91.417(a) and (b) prescribes, in pertinent part, that—
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(a) Each registered owner or operator shall keep the following records 

forthe 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 

otherrequired or approved inspections, as appropriate, 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.
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(vi) Copies of the forms prescribed by § 43.9(d) of this 

chapterfor 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 

aircraftis 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 PAG Seeks And The Reason PAG Seeks The Relief.

A. Section&61.113(a)&and&(b):

a. Due&to&the&fact&that&there&are&no&standards&for&private&or&commercial&sUAS&

operations,&

b. Knowledge&of&flight&characteristics&and&the&Federal&Aviation&Regulations&

(FARs),&along&with&the&ability&to&physically&manipulate&the&controls&of&the&

sUAS&are&the&critical&aspects&of&the&requested&operation.&

c. The&risks&associated&with&the&operation&of&the&sUAS&are&so&diminished&from&

the&standards&that&Part&61&was&written&for&an&equivalent&level&of&safety&can&

be&maintained&with&a&private&pilot&certificate.&&

d. 4.& FAA&has&authority&to&waive&pilot&requirements&for&commercial&operations&

under&49&U.S.C&§44701(f).

B. 14&CFR&§&91.103&– Preflight&Action

1. The&PIC&shall&perform&a&preflight&inspection&in&accordance&with&the&

manufacturers&recommendations&of&the&UAS,&controller,&and&
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ground&control&station&prior&to&each&flight&to&ensure&it&is&free&of&all&

discrepancies.

2. Equivalent&safety&levels&will&be&met&through&preparation&and&

compliance&with&the&operator’s manual&and&site&preparation.&

C. 14&CFR&91.119(c)&– Requirements&for&Minimum&Safe&Altitudes&for&Civil&

Aircraft&Operation

1. The&sUAS&will&be&operated&only&within&a&predetermined&area&below&

400 feet AGL.

2. 2.&An&equivalent level&of&safety&will&be&maintained.&

D. 14&CFR&91.121&– Altimeter&Settings

1. SUAS&may¬&have&a&barometric&altimeter,&and&may&use&a&GPS&

altitude&read&out&indication&instead,&so&an&exemption&may&be&

needed.

2. The&operator&will&achieve&an&equivalent&level&of&safety as&the&sUAS&

uses&AGL&height&from&its&initialization&(launch)&point,&cross^

referenced&with&Mean&Sea&Level&(MSL)&altitude&of&the&launch&point.

E. CFR&91.151&(a)(1)&– Fuel&Requirements&for&Flights&in&VFR&Conditions

1. An&equivalent&level&of&safety&can&be&obtained&by&terminating&the&

flight&prior&to&30&minutes&or&25%&battery&power,&whichever&occurs&

first.

2. The&UAS&will¬&be&operated&at&night.&

F. 14&CFR&91.405&(a)&Maintenance&Required

1. This§ion&and&Part&43&apply&only&to&aircraft&with&an&

airworthiness&certificate,&therefore&these§ions&will¬&apply.

2. Maintenance will be accomplished by PAG pursuant to the 

manufacturer’s recommendations.

3.&Maintenance,&preventive&maintenance,&rebuilding,&and&alteration&

will&be&successfully&accomplished&by&trained&personnel.

4.&The&sUAS&shall&be&discrepancy&free&prior&to&initiating&flight.&
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5.&If&a&mechanical&issue&arises&the&sUAS&can&land&safely&within&the&“Safe&

Zone.”

G. 14&CFR&91.407&(a)&(1)&– Operation&After&Maintenance,&Preventive&Maintenance,&

Rebuilding,&or&Alteration

1. This§ion&and&Part&43&apply&only&to&aircraft&with&an&

airworthiness&certificate,&therefore&these§ions&will¬&apply.

H. 14&CFR&91.409&(a)&(1)&and&(2)&^ Inspections.

1. This§ion&and&Part&43&apply&only&to&aircraft&with&an&

airworthiness&certificate,&therefore&these§ions&will¬&apply.&

I. 14&CFR&91.417(a)&and&(b)&– Maintenance&Records.

1. This§ion&and&Part&43&apply&only&to&aircraft&with&an&

airworthiness&certificate,&therefore&these§ions&will¬&apply.

D. Reasons why granting this request would be in the public interest. 

• PAG&is&a&small&business&that&is&using&the&latest&sUAS&technology.&&&

• PAG&will&operate&with&an&equivalent&or&better&level&of&safety.&

• PAG&will&use&a&sUAS&that&has&proven&operational&history.&

• PAG&will&use&available&technology&and&knowledge&to&ensure&public&safety&

continuously&updating&procedures.&&

• PAG&will&only&conduct&flights&where&a&controlled, sterile&environment&can&be&

assured.&&

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 PAG Seeks Exemption.

1. PIC and Visual Observer

a. The PIC shall possess at least a private pilot certificate and at least a 

current driver’s license.

i. The PIC shall also meet the flight review requirements 
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specified in 14 CFR § 61.56 in an aircraft in which the PIC is 

rated on their pilot certificate.

ii. The PIC shall be trained in the operation of the specific Make

and Model of the UAS being piloted.

iii. The PIC must have:

1. A minimum of 200 flight cycles and 25 hours of total 

time as a sUAS rotorcraft pilot 

2. Five hours logged with the make and model utilized

b. The PIC and Visual Observer (VO) will be designated before each

flight

i. Minimum crew for each operation will consist of the PIC and 

the VO.

c. The PIC and VO will always be within visual line of sight (VLOS) of

each other and in direct verbal communication at all times.

d. Safety Briefings prior to each flight:

i. Designated roles of PIC and VO

ii. Risk Management and Mitigation

iii. PIC and VO will inspect site for safety issues. 

iv. PIC&will operate the&UAS&with&appropriate&distance&from&non^

participants in&accordance&with&14&CFR&§ 91.119.

2. SUAS Specifications and Design:

a. All sUAS flown under this exemption shall be less than 55 pounds 

including aircraft and payload. 

b. The radio frequency spectrum used for operation and control of the

sUAS shall comply with the Federal Communications Commission 

(FCC) or other appropriate government oversight agency requirements.

c. Maximum speed shall be no more than 50 knots.

d. The sUAS shall be equipped with Inertial Navigation

Sensor(s) (IRS/IRU/Accelerometer).

e. The sUAS shall be equipped with a Compass

(Magnetometer/Heading Source).
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f. The sUAS shall be equipped with a Global Positioning System

(GPS) guidance system.

g. The sUAS shall have a return to home feature

3. Maintenance

a. The UAS shall be maintained in accordance with the

manufacturer’s recommendations with appropriate 

recordkeeping. 

b. The PIC shall perform a preflight inspection of the sUAS, controller,

and ground control station prior to each flight to ensure it is 

operational with no discrepancies. If the preflight inspection has any 

discrepancies that may affect a safe operation, repairs or maintenance 

shall be performed prior to flight. The sUAS will only be operated if it 

is free of all discrepancies.

Any UAS that has undergone maintenance or alterations that affect the 

UAS operationor 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 conductsthe functional test 

flight must make an entry in the UAS aircraft records of the flight.The 

requirements and procedures for a functional test flight and aircraft 

record entry mustbe added to the operator’s manual.

c. PAG shall follow the manufacturer’s sUAS maintenance, overhaul, 

replacement, inspection, and life limit requirements. When not

specified at a minimum, the following shall be included:

i. Actuators / Servos

ii. Powerplant(s) (motors)

iii. Propellers

iv. Electronic speed controller(s)

v. Batteries

vi. Remote controllers and Ground control station

d. All sUAS shall 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, except with respect to the 

size of the markings. Markings shall be as large as practicable.
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3. Permissions and Permitting

a. All required permissions and permits shall be obtained from

territorial, state, county or city jurisdictions, including local law 

enforcement, or other appropriate governmental agencies.

b. At least three days before a scheduled operational flight, PAG shall

submit a written Plan of Activities to the local flight standards district

office (FSDO) with jurisdiction over the area of the proposed flight. The

3-day notification may be waived with the concurrence of the FSDO.

i. The plan of activities shall include at least the following:

1. Dates and times for all requested flights

2. Name and phone number of the PIC responsible for 

operation of the sUAS

3. Make, model, and serial or N-number of sUAS to be

used

4. Name and certificate number of sUAS PICs involved in

the flight

5. Signature of exemption-holder or representative

6. A description of the flight activity, including maps or 

diagrams of any area over which flights will be

conducted, the relationship of that area to any nearby 

city, town, etc., and the altitudes essential to accomplish 

the operation

c. Documents required under 14 CFR § 91.9 and § 91.203 shall be readily 

available to the PIC any time the aircraft is in operation. These

documents shall be made available to the Administrator or any law

enforcement official upon request.

d. PAG shall obtain an Air Traffic Organization (ATO) issued Certificate

of Waiver or Authorization (COA) prior to conducting any operations

under this grant&of&exemption.&Dow&shall&also&request&a&Notice&to&Airman&

(NOTAM)¬ more&than&72&hours&in&advance,&but¬&less&than&48&hours&

prior&to&the operation.

4. Operations

a. The sUAS shall not operate in Class B, C, or D airspace without written 
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approval from the FAA. The sUAS shall not operate within 5 nautical 

miles of the geographic center of a non-towered 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. This letter of agreement with the airport management shall be 

made available to the Administrator upon request.

b. Flights shall be conducted under day visual meteorological

conditions (VMC).

i. In addition, the sUAS shall 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.

ii. sUAS operations shall not be conducted during night, as defined in

14 CFR § 1.1.

iii. Flights shall not be conducted under special visual flight

rules (SVFR).

c. Flights shall be operated at an altitude of no more than 400 feet

above ground level (AGL).

d. The PIC shall be prohibited from operating the sUAS from any

moving device or vehicle.

e. The sUAS shall be operated within visual line of sight (VLOS) of the

PIC.

i. The PIC shall maintain VLOS without the aid of

telescopes, cameras or other devices.

ii. The PIC will maintain VLOS with their own vision, which 

includes the use of eyeglasses or corrective lenses.

f. The sUAS shall remain clear and yield the right of way to manned 

operations and activities at all times 

g. Prior to any flight operations authorized by this grant of exemption, the

PIC and VO must have successfully completed a qualification process, 

as outlined in the operator’smanual. As this is a requirement stipulated 

by the operator, the test must be developed and implemented by a 
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qualified person designated at the sole discretion of the operator.A 

record of completion of this qualification process must be documented 

and made available to the Administrator upon request.

h. The UAS must abort the flight in the event of unpredicted obstacles 

or emergenciesin accordance with the operator’s manual.

i. 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 reportedto the FAA’s UAS Integration Office 

(AFS-80) within 24 hours. Accidents must bereported to the National 

Transportation Safety Board (NTSB) per instructions contained on the 

NTSB Web site: www.ntsb.gov. Further flight operations may not be 

conducted untilthe incident, accident, or transgression is reviewed by 

AFS-80 and authorization to resume operations is provided.

5. Flight Time

a. Each sUAS operation shall be completed within 30 minutes flight time

or with 25% battery power remaining, whichever occurs first.

F. Summary for Federal Register publication. 

The Rules From Which PAG Seeks Exemption: 14 CFR 61.113(a) 

and (b), 14 CFR 91.103, 14 CFR 91.119, 14 CFR 91.121, 14 CFR 

91.151(a), 14 CFR 91.405(a), 14 CFR 91.407(a)(1), 14 CFR 

91.409(a)(2), 14 CFR 91.417(a) and (b)

A. Brief Description Of The Nature Of The Exemption PAG Seeks:

Price Aviation Group (PAG) seeks exemption to operate a UAS under 

Section 333 of the FAA Modernization and Reform Act of 2012. This 

exemption will allow PAG to operate a UAS for the purposes of aerial 

photography and inspection in a controlled, sterile environment. PAG will 

be operating a proven airframe to accomplish flights with an equivalent or 

better level of safety to manned operations. 
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CONCLUSION

PAG seeks to operate sUAS in a manner that will ensure an equivalent level of 

safety to the general public. The flights will be conducted to a high standard using 

proven technology complying with FAA regulations and the conditions of the requested 

exemption. 

Specific information on the sUAS is included as an appendix, and any other 

information needed to fulfill necessary requirements will be gladly given upon request. 

Submitted By:

Christopher Lawler

Price Aviation Group

December 6, 2014