August 5, 2015 

Unmanned Aircraft Systems Integration Office Federal Aviation Administration 

800 Independence Avenue, SW 

Washington, DC 20591 

U.S. Department of Transportation Docket Operations 

West Building Ground Floor, Room W 12-140 

1200 New Jersey Ave. SE 

Washington DC 20590 

Re: Exemption Request Pursuant to Section 333 of the FAA Reform Act and Part I 1 of the Federal 

Aviation Regulations from: 14 CFR 21 subpart H; 14 CFR 45.23(b); 14 CFR 61.113(a); 14 CFR 91.7(a); 

14 CFR 91.9(b)(2); 14 CFR 91.103;14 CFR 91.109; 14 CFR 91.119(c); 14 CFR 91.121; 14 CFR 

91.151(a); 14 CFR 91.203 (a) and (b); 14 CFR 91.405 (a); 14 CFR 91.407 (a) (1) 14 CFR 91.409 (a)(1) 

and (2); 14 CFR 91.417(a) and (b) 

To whom it may concern, 

Pursuant to Section 333 of the FAA Modemization and Reform Act of 2012 and 14 CFR Part 11, Excel 

Aerial, LLC herein after also known as the operator, hereby applies for an exemption fi•om the listed 

Federal Aviation Regulations to allow for commercial operation of Small Unmanned Aircraft Systems 

(UAS), so long as such operations are conducted within and under the conditions outlined herein or as 

established by the FAA as required by Section 333. 

Commercial operation of UAS, as described herein, which are equipped with cameras and sensors, 

would operate in the following manner: 

• Aerial surveying, mapping and data collection 

• Remote sensing 

• Educational and research operations 

• Wildlife and forestry monitoring 

• Aid in disaster and emergency management and monitoring, civil first response, communications 

relay, search and rescue, monitoring fire hazards, cleanup effort supeivision, damage assessment 

and estimation 

• Aid civil engineering: watertivays and shipping, forestry, fishery protection, pollution control and 

air sampling and crop performance 

• Railroad and motor-vehicle road inspection 

• Telecommunications infrastructure inspection 

• Utility, Energy systems and electrical engineering inspections and asset management 
• Agricultural surveying and produce field management 

• Livestock management and accountability 

• Unmanned aircraft flight school 

• Aerial filmmaking and photography 

• Construction site inspections and monitoring 

• Oil and gas pipeline inspection/patrolling and oil-field inspection 

• Real estate and marketing 

• Aerial event security, surveillance and crowd management 

• Aerial imagery evidence for property insurance claims 

As described fully below, the requested exemption would permit the operation of UAS under controlled 

conditions in the NAS that would be a) limited b) controlled c) predetermined and d) will provide safety 

enhancements to the already safe operations in the industry presently using conventional aircraft. 

Approval of this exemption would thereby enhance safety and fulfill the Secretary of Transportation's 

(the FAA Administrator's) responsibilities to "....establish requirements for the safe operation of such 

aircraft systems in the national airspace system." 

The name and address of the applicant is: 

Excel Aerial, LLC 

Attn: Mark Uminn 

9376 E. H Ave 

Kalamazoo, MI 49048 

Ph: (269) 567-0538 

Email: markuminn@gmail.com 

Regulations from which the exemption is requested: 

14 CFR Part 21 subpart H 

14 CFR 45.23 (b) 

14 CFR 61.113(a) 

14 CFR 91.7 (a) 

14 CFR 91.9 (b) (2) 

14 CFR 91.103 

14 CFR 91.109 

14 CFR 91.119(c) 

14 CFR 91.121 

14 CFR 91.151 (a) 

14 CFR 91.203 (a) & (b) 

14 CFR 91.405 (a) 

14 CFR 91.407 (a) (1) 

14 CFR 91.409 (a) (2) 
14 CFR 91.417 (a) & (b) 

Regulatory Basis for Exemption Request 

This exemption application is expressly submitted to fulfill Congress' goal in passing Section 333(a) 

through (c) of the Reform Act. This law directs the Secretary of Transportation to consider whether 

certain unmanned aircraft systems may operate safely in the national airspace system (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 UA 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 UA's size, weight, speed, and operational capability; 

• Operation of the UA in close proximity to airporls and populated areas 

• Operation of the UA within visual line of sight of the operator. 

The aircraft intended for use by the operator includes the DJI Inspire 1 and 3d Robotics X8+. All of 

these aircraft have previously been approved by the FAA in other applicant's Section 333 exemptions. 

Reform Act § 333 (a). Lastly, 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." Id. §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, 

which includes UA, fi•om the requirement that all civil aircraft must have a cuiyent airworthiness 

certificate. 

The Administrator may grant an exemption from a requirement of a regulation prescribed under 

subsection (a) or (b) of this section or any sections 44702-44716 of this title if the Administrator finds 

the exemption in the public interest. 49 U.S.C. §44701(t) See also 49 USC §44711(a); 49 USC §44704; 

14 CFR §91.203 (a) (1). 

Excel Aerial, LLC's UAS are rotorcraft, weighting 55 or fewer pounds including payload. The UA 

operate under normal conditions at a speed of no more than 50 knots and have the capability to hover 

and move in the vertical and horizontal plane simultaneously. The UA will be operated only in line of 

sight and will be operated only within a predetermined and protected flight area under the permission of 

the property representative. The UA will be operated under the below listed limitations and conditions 

to which the operator agrees to be bound when conducting commercial operations under an FAA issued 

exemption, as well as any other limitations the FAA may place on future operations. Such operations 

will insure that the UA will "not create a hazard to users of the national airspace system or the public as 

per the Reform Act Section 333 (b). 

Given the clear direction in Section 333 of the Reform Act, the authority contained 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, reduction in environmental impacts, 

including reduced emissions associated with allowing UA for aerial data collection, the grant of the 
requested exemptions is in the public interest. Accordingly, the applicant respectfully requests that the 

FAA grant the requested exemption without delay. 

The FAA has issued grants of exemption in circumstances similar in material respects to those presented 

in this petition. In Exemptions Nos, 11280, 11279, 11278, 11275, 11273, 11271, 11269, 11267, 11260, 

11253, 11250, 11230, 11213, 11112, 11109 

AIRCRAFT AND EQUIVALENT LEVEL OF SAFETY 

14 C.F.R. Part 21, Subpart H, entitled Airworthiness Certificates, establishes the procedural 

requirements for the issuance of airworthiness certificates as required by FAR §91.203 (a) (1). The 

Federal Aviation Act (49 U.S.C.§44701 (f)) and Section 333 of the Reform Act both authorize the FAA 

to exempt aircraft from the requirement for an airworthiness certificate, upon consideration of the size, 

weight, speed, operational capability, and proximity to airports and populated areas of the particular 

UAS. In all cases, an analysis of these criteria demonstrates that the UAS operated without an 

airworthiness certificate, in the restricted environment and under the conditions proposed will be at least 

as safe, or safer, than a conventional aircraft (fixed wing or rotorcraft) operating with an airworihiness 

certificate without the restrictions and conditions proposed. 

The UAS to be operated hereunder are rotorcraft weighing less than 55 pounds including payload, 

caTies neither a pilot nor passenger. Carries no explosive materials or flammable liquid fuels, and 

operates exclusively within visual line of sight of the pilot in command (PIC) and a visual observer 

(VO). They operate at a speed of less than 50 knots and have the capability to hover and move in the 

vertical and horizontal plane simultaneously within a predetermined and protected flight area as 

described below. Such operations will insure that the UASs will not create a hazard to the users of the 

national airspace system. Unlike other civil aircraft, operations under this exemption will be tightly 

controlled and monitored by both the operator and under the requirements and in compliance with local 

public safety requirements, to provide security for the area of operation. The FAA will have advance 

notice of all operations. These safety enhancements provide a greater degree of safety to the public and 

properly owners than conventional operations conducted with airworthiness certificates issued under 14 

C.F.R. Part 21, Subpart H. Lastly, application of these same criteria demonstrates that there is no 

credible threat to national security posed by the UA, due to its size, speed of operation, location of 

operation, lack of explosive materials or flammable liquid fuels, and inability to carry a substantial 

externalload. 

The Secretary of Transportation has previously deterrnined that these aircraft meets the conditions of 

Section 333. Therefore, the FAA has found that request of relief from 14 CFR part 21, and any 

associated noise certification and testing requirements of part 36, is not necessary. This has been stated 

in exemptions to this regulation in Exemptions Nos. 11280, 11279, 11278, 11275, 11273, 11271, 11269, 

11267, 11260, 11253, 11250 and 11230 

The applicant proposes that the exemption requested herein apply to 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. 
These limitations and conditions to which the operator agrees to be bound when conducting commercial 

operations under an FAA issued exemption include: 

1. The UA; DJI Inspire 1 and 3d Robotics X8+ will weigh less than 55 pounds including 

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

amend the exemption. 

2. Operations for the purpose of closed-set motion picture and television filming are not 

permitted. 

3. The UA will 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 200 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. The exemption and all documents needed to operate the UAS and conduct its operations in 

accordance with the conditions and limitations stated in the grant of exemption, are 

hereinafter refen•ed 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 the exemption and the 

procedures outlined in the operating documents, the conditions and limitations therein 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 or any law enforcement official 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 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 

fi•om 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 aircra8 is prohibited fi•om 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 the exemption must comply with all manufacturer safety bulletins. 

13.A PIC must hold either an airline transport, commercial, private, recreational, or spoil pilot 

certificate. The PIC must also hold a current FAA aiiman medical certificate or a valid U.S. 

driver's license issued by a state, the District of Colombia, Puerto Rico, a ter7•itory, 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 14 CFR § 61.51(b). Flights for the 

purposes of training the operator's PICs and VOs (training, proficiency, and experiencebuilding) 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 the 

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 aitport 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 

predetermined 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 fi•om 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 terrns of the attached COA. 

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

registered in accordance with 14 CFR part 47, and have identification (N- 6 Number) 

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

practicable. 

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. Ban•iers 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 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 the exemption. 

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

fi•om 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. 

Unless otherwise specified in the 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. 

14 CFR § 61.23 (a) &(c): Medical certificates: Requirements and duration. 

This regulation sets forth medical certificate requirements for pilots-in-command of aircraft in that a 

holder must have a first-class medical certificate when exercising the PIC privileges of an airline 

transport pilot certificate. Furtheimore, the requirement states that the PIC must hold at least a secondclass medical certificate when exercising PIC privileges of a commercial pilot certificate, or must hold at 

least a third-class medical certificate when exercising PIC privileges of a private pilot certificate, 

recreational pilot certificate, or flight instructor certificate. It also states that a person must hold and 

possess either a medical certificate issued under § 61.67 or a U.S. driver's license when exercising the 

privileges of a PIC of a sport pilot certificate in a light-sport aircraft other than a glider or balloon. 

The FAA is granting relief from § 61.23(a) to allow any pilot that holds one of the pilot's certificates 

(discussed above) to operate a UAS with a U.S. issued driver's license, in lieu of an FAA-issued medical 

certificate. The FAA is also granting relief from § 61.23(c) to allow sport pilot certificate holders to 

operate aircraft other than LSA with a U.S. issued driver's license. The FAA has issued the following 

exemptions to this regulation: Exemption Nos.11278, 11275, 11269, 11267, 11260, 11256, 11253, 

11252, 11240 and 11230. 

14 CFR § 61.101 (e) (4) &(5): Recreational pilot privileges and limitations. 

This section limits recreational pilots to non-commercial operations and that they may not act as pilot in 

command of a recreational aircraft for compensation or hire, or in the furtherance of a business. Unlike 

a conventional aircraft that carries the pilot and passengers, the UA is remotely controlled with no living 

thing on board. The area of operation will be predetermined and in a protected flight area under the 

peimission of the property representative, and all flights are planned and coordinated in advance. The 

FAA has issued the following exemptions to this regulation: Exemption Nos.11278, 11275, 11269, 

11267, 11260, 11256, 11253, 11252, 11240 and 11230. 

14 CFR § 61.113 (a): Private Pilot Privileges and Limitations: Pilot in Command. 

This section limits private pilots to non-commercial operations and that they may not act as pilot in 

command of an aircraft that is carrying passengers or property for compensation or hire. Unlike a 

conventional aircraft that car7•ies the pilot and passengers, the UA is remotely controlled with no living 

thing on board. The area of operation will be predetermined and in a protected flight area under the 
peimission of the property representative, and all flights are planned and coordinated in advance. The 

FAA has issued the following exemptions to this regulation: Exemption Nos.11278, 11275, 11269, 

11267, 11260, 11256, 11253, 11252, 11240 and 11230. 

14 CFR § 61.315 (a): What are the privileges and limits of my sport pilot certificate? 

This section limits sport pilots to non-commercial operations and that they may not act as pilot in 

command of an aircraft that is catTying passengers or property for compensation or hire, or in the 

furlherance of a business. They also may not carry more than one passenger, fly at night, and under 

other restrictions that are outside of the scope of intended flights of the UA. Unlike a conventional 

aircraft that carries the pilot and passengers, the UA is remotely controlled with no living thing on 

board. The area of operation will be predetermined and in a protected flight area under the permission of 

the property representative, and all flights are planned and coordinated in advance. The FAA has issued 

the following exemptions to this regulation: Exemption Nos.l 1278, 11275, 11269, 11267, 11260, 

11256, 11253, 11252, 11240 and 11230. 

14 CFR § 91.7(a): Civil aircraft airworthiness. 

The regulation requires that no person may operate a civil aircraft unless it is in airworthy condition. As 

there will be no airworthiness certificate issued for the aircraft, should this exemption be granted, no 

FAA regulatory standard will exist for determining airworthiness. Given the size of the aircraft for 

maintenance and use of preflight actions as prescribed by the aircraft's manufacturer prior to each flight, 

and given the FAA's prior approval of the same types of aircraft to be used in previous exemptions to 

this requirement (as set forth in Exemptions Nos. 11278, 11275, 11267, 11260, 11253 and 11230) we 

believe we can maintain a high standard of safety and due regard as to the aircraft's airworthiness during 

flight operations. The FAA has issued the following exemptions to this regulation: Exemption 

Nos.11278, 11275, 11269, 11267, 11260, 11256, 11253, 11252, 11240 and 11230. 

14 CFR § 91.119 (c): Minimum safe altitudes. 

Section 91.119 establishes safe altitudes for operation of civil aircraft. Section 91.119 (d) allows 

helicopters to be operated at less than the minimums prescribed, provided the person operating the 

helicopter complies with any route or altitudes prescribed for helicopters by the FAA. As this exemption 

is for UAS that are rotorcraft and the exemption requests authority to operate at altitudes up to 200 feet 

AGL, an exemption may be needed to allow such operations. As set forth herein, the UA will never 

operate at higher than 200 feet AGL, will always be operated under VLOS of both the PIC and VO, its 

area of operation will be predetermined and in a protected flight area under the permission of the 

property representative, all flights are planned and coordinated in advance and the UA will remain clear 

of, and give way to all manned aviation operations and activities at all times. 

The equivalent level of safety will be achieved given the size, weight, speed of the UA as well as the 

location where it is operated and under the conditions previously stated. Compared to flight operations 
with aircraft or rotorcraft weighting far more than the maximum 55pounds proposed herein and the lack 

of flammable fuel, any risk associated with these operations is far less than those presently presented 

with conventional aircraft operating at or below 500 feet AGL. In addition, the low-altitude operations 

of the UA will ensure separation between these small- UAS operations and the operations of 

conventional aircraft that must comply with Section 91.119. The FAA has issued the following 

exemptions to this regulation: Exemptions Nos. 11278, 11275, 11269, 11267, 11260, 11256, 11253, 

11252, 11240 and 11230. 

14 CFR § 91.121: Altimeter Settings. 

This regulation requires each person operating an aircraft to maintain ciruising altitude by reference to an 

altimeter that is set "...to the elevation of the departure airport or an appropriate altimeter setting 

available before departure." As the UA may not have a barometric altimeter, but instead a GPS altitude 

read out, an exemption may be needed. An equivalent level of safety will be achieved by the operator, 

pursuant to the manufacturer's published procedures and live flight data monitoring, confirming the 

altitude of the launch site shown on the GPS altitude indicator before flight. In the event that the GPS 

altitude read out system becomes none functional during flight, the UA will also have a pre-programmed 

maximum flight limit of 200 feet programmed into them so that they may not fly above unapproved 

altitude limits. The FAA has issued the following exemptions to this regulation: Exemptions Nos. 

11278, 11275, 11269, 11267, 11260, 11256, 11253, 11252, 11240 and 11230. 

14 CFR § 91.151(a) (1): Fuel Requirements for Flight in VFR Conditions. 

Section 91.151 (a) 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 LiPo battery powering the DJI Inspire 1 and the 3D Robotics X8+ provides approximately 20 

minutes of powered flight. The PIC will not begin a flight unless 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. 

Applicant believes that an exemption from 14 CFR §91.151(a) falls within the scope of prior 

exemptions, and that flight with less than 30 minutes of reserve fuel, does not engender the type of risks 

that Section 91.151(a) was intended to alleviate given the size and speed of the small UAS. Similar 

exemptions have been granted to other operations, including Exemptions Nos. 11278, 11275, 11269, 

11267, 11260, 11256, 11253, 11252, 11240 and 11230. 

14 CFR § 91.405 (a); 407 (a) (1); 409 (a) (1) & (2); 417(a) & (b): Maintenance Inspections. 
These regulations require 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...," and 

others shall inspect or maintain the aircraft in compliance with Part 43. Given that these sections and 

Part 43 apply only to aircraft with an airworthiness certificate, these sections will not apply to the 

applicant. 

An equivalent level of safety will be achieved because these small UASs are very limited in size and 

will carry a small payload and operate only in restricted areas for limited periods of time. If inechanical 

issues arise the UA can land immediately and will be operating from no higher than 200 feet AGL and 

within VLOS of the PIC and VO. 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 fi•om operating until the 

necessary maintenance has been performed and the UAS is found to be in a condition for safe flight. The 

operator must follow the UAS manufacturer's maintenance, overhaul, replacement, inspection, and life 

limit requirements for the aircraft and aircraft components. The FAA has issued the following 

exemptions to this regulation: Exemptions Nos. 11278, 11275, 11269, 11267, 11260, 11256, 11253, 

11252, 11240 and 11230. 

Privacy 

All flights will occur over private or controlled access property with the property representative or 

owner's prior consent and knowledge. Filming will be of people who have also consented to being 

filmed or otherwise have agreed to be in the area where filming will take place. 

All flights will occur in accordance with any state or local laws regarding privacy. 

UAS Information 

sUAS's to be used are as follows but not limited to providing they are within the scope of the exemption 

granted by the FAA: 

1. DJI Inspire 1 

• Weight (Battery Included) 2935g 

• Hovering Accuracy (GPS Mode) Vertica10.5m, Horizonta12.5m 

• Max Angular Velocity Pitch: 300deg/s; Yaw 150degJs 

• Max Tilt Angle 30deg1s 

• Max Ascent Speed 5m/s 

• Max Decent Speed 4m/s 

• Max Speed 22m/s 
• Diagonal Distance 559mm (Landing gear lowered), 581mm (Landing gear raised) 

a. DJI Inspire Gimbal 

• Operating Current - Station: 750mA, Motion: 900mA 

• Controllable Range - Pitch: -90deg to +30deg 

• Max Controllable Speed — Pitch: 120degls, Pan: 180deg/s 

b. DJI Inspire Battery 

• Model (Standard) TB47 

• Voltage 22.2v 

• Capacity 4500mAh 

• Energy 99.9Wh 

• Net Weight 570g 

c. DJI Inspire Remote Controller 

• Frequency 

• 5.725GHz-5.850GHz (Remote Controller to Remote Controller) 

• 2.400GHz-2.483GHz (Remote Controller to Aircraft) 

• Battery Capacity 6000mAh 

• Working CurTent/Voltage 1.2A a,7.4V 

2. 3D Robotics X8+ 

• Battery: 4S 14.8V 10,000 mAh 10C 

• Battery Dimensions: 6.6 in x 2.6 in x 1.4 in (16.7 em x 6.5 cm x 3.5 cm) 

• Battery Weight: 803 g 

• Autopilot hardware: Pixhawk v2.4.5 

• Autopilot firmware: ArduCopter 3.2 

• GPS: 3DR u-blox GPS with Compass (LEA-611 module, 5 Hz update) 

• Ground Station Radio: 3DR Radio v2 (915 MHz or 433 MHz) 

• Motors: SunnySky V2216-12 KV800 II 

• Controller: F1ySky FS-TH9X with FrSky telemetry module 

• Frame Type: X 

• Propellers: APC Propeller l 1x4.7 SF (4), APC Propeller l 1x4.7 SFP (4) 

• Vehicle Dimensions: 13.7 in x 20.1 in x 11.8 in (35 cm x 51 cm x 20 cm) 

• Payload Capacity: 800 g(1.71bs). Additional payload possible up to over lkg 

with reduced flight time. 

• Vehicle Weight with Battery: 2.56 kg (5.61bs) 

• Maximum Estimated Flight Time: 15 min 

Conclusion 
The use of UAS provide many benefits to the general public, such as: Decreased air pollution due to the 

enormous amount of leaded fuel needed to fly manned aerial vehicles, decreased noise pollution when 

near the public, Decreased air traffic congestion at airports and provides a more affordable and 

reasonable alternative to cunent options available to the consumer. As for safety, Small Unmanned 

Aerial Systems do not carry people or property so it provides less of a chance of injury in the case of an 

accident and because of the size and weight of manned aircraft the ground casualties can be far less or 

nonexistent in the case of a downed UAS vs a manned aircraft. 

Thank you for the consideration of these exemptions. 

Sincerely, 

Mark Uminn 

Excel Aerial, LLC 

9376 E. H Ave 

Kalamazoo, MI 49048 

269-567-0538 

Email: MarkUminn@gmail.com