Unmanned Systems, Inc.

May 30th, 2015

2709 Cyrano Street 

Henderson, NV 89044

Cell (406)471.3996

U.S. Department of Transportation

Docket Management System

1200 New Jersey Ave., SE

Washington, DC 20590

Dear sir or Madam,

As you are aware, as of February 2012, with the passage of Public Law 112-95, Unmanned Aircraft 

Systems (UAS) are considered aircraft, therefore their operation is subject to Title 14 of the Code of 

Federal Regulations (14 CFR) Parts 91 & 61. Due to the design of UAS and nature of their operations, 

operators are either unable to comply or in some cases it’s simply impractical to comply with certain 

regulatory requirements, resulting in, as in this case, the UAS operator requesting an exemption from 

the rule.

Unmanned systems Inc. (USI) hereby request exemptions from the following regulations for Its 

Sandstorm electric (E), turbine (T) and gas (G) models.

14 CFR §61.113 

(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: flight is only incidental to that business or 

employment;

USI is requesting an exemption from 61.113 (a) & (b) to allow USI pilots to operate the Sandstorm UAS

as PIC and holding only a private pilot certificate, for compensation or hire. 
14 CFR § 91.119

(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. 

USI is requesting an exemption from 91.119 (c) to allow USI to operate the Sandstorm UAS below 500 

feet Above Ground Level (AGL)

14 CFR §91.121:

(a) Each person operating an aircraft shall maintain the cruising altitude or flight level of that 

aircraft, as case may be, reference to an altimeter that is set, when operating 

USI is requesting an exemption from the altimeter setting requirements of 91.121

14 CFR §91.151 

(a) prescribes that no person may begin a flight in an airplane under VFR conditions unless 

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

point of intended landing and, assuming normal cruising speed, (1) during the day, to fly 

after that for at least 30 minutes [emphasis added]. 

USI is requesting an exemption to the fuel / power reserves required by 14 CFR §91.151 

The FARs

The Petitioner seeks exemption from the above mentioned FARs for the following

reasons;

14 CFR §61.113(a) & (b);

The Petitioner requests relief in order to facilitate the utilization of an experienced UAS pilot with the 

addition of a trained observer. All pre-flight inspection, maintenance and flight logs will be saved and 

made available to the FAA and Secretary of Transportation (SoT) for review; with the purpose of safely 

integrating civil UAS operation in the National Airspace System. Currently Sandstorm Pilots have at least 

a private pilot Certificate and second class medical.

14 CFR §91.119(c)

As discussed in Exemption 11138 (DOUGLAS TRUDEAU), operations conducted closer than 500 feet to 

the ground may require that the UA be operated closer than 500 feet to essential persons, or objects 

that would not be possible without additional relief. The Petitioner requests modification, waiver or 

exemption and clarification concerning the terms “congested areas” and “densely populated”. The 
Petitioner requests waiver for this condition to allow reasonable and responsible operations in areas of 

subdivisions and neighborhoods if required. The Petitioner will primarily operate the UAS between 

ground level and 400 feet. The UAS will be operated over designated properties with the owner’s 

consent and while maintaining a safe distance from persons. The Petitioner will compile flight data from 

the logs. This data may assist the FAA in development of regulations for commercial operations in lowrisk, controlled environments.

14 CFR §91.121

As discussed in Exemption 11138 (DOUGLAS TRUDEAU) is inapplicable since the UAS does not have an 

altimeter and instead utilizes electronic GPS with a barometric sensor for altitude information. It is reset 

to zero prior to flight. The safety pilot is a backup reference for altitude as he is in line of sight of the 

UAV.

14 CFR §91.151(a)

As discussed in Exemption 11136 (ADVANCED AVIATION SOLUTIONS LLC) prior relief has been granted 

for manned aircraft to operate at less than the prescribed minimums, including Exemption Nos. 2689, 

5745, and 10650. In addition, similar UAS specific relief has been granted an Exemption Nos. 8811, 

10808, and 10673 for daytime, VFR conditions. The UAS provides battery power remaining in percent to 

the PIC. The batteries for the Sandstorm E model provide approximately 40 minutes of powered flight.

The Sandstorm T and G models have approximately 4 hours of flight. Information provided in the 

operating documents discusses procedures regarding remaining battery power management. Those 

documents contain a condition in which the PIC will initiate a landing procedure when battery remaining 

reaches a specified level. Given the limitations on proposed operations and the location of those 

proposed operations, The FAA found that a reduced minimum power reserve for flight in daytime VFR

conditions was reasonable.

History/Public Interest

Sandstorms E, T and G models have been used in USI’s companion trainer program for 4 years. It has 

had its experimental certifications for 4 years. It has had great success with N441NS keeping many UAS

operators current. Sandstorm has now been approved by the government for Predator qualification 

training. We are now exploring opportunities in the commercial market. We would like to give the 

opportunity to all people who have an interest in Flying UAS commercially. I for one have seen its 

positive influences as I am bound to a wheelchair it has given me the opportunity to fly once again. The 

primary purpose of seeking this exemption is to obtain that capability to offer those services while 

remaining in compliance.

Respectfully submitted

Justin Sands