June 16, 2015 

 Exemption No. 11813 

 Regulatory Docket No. FAA–2015–1010 

Ms. Marjorie K. Conner 

Counsel for CellAntenna Corporation 

700 West View Terrace 

Alexandria, VA 22302 

Dear Ms. Conner: 

This letter is to inform you that we have granted your request for exemption. It transmits our 

decision, explains its basis, and gives you the conditions and limitations of the exemption, 

including the date it ends. 

By letter dated April 6 and May 12, 2015, you petitioned the Federal Aviation Administration 

(FAA) on behalf of CellAntenna Corporation (hereinafter petitioner or operator) for an 

exemption. The petitioner requested to operate an unmanned aircraft system (UAS) to 

conduct visual observation, inspection, and recording and RF signal extension and detection 

work. 

See Appendix A for the petition submitted to the FAA describing the proposed operations and 

the regulations that the petitioner seeks an exemption. 

The FAA has determined that good cause exists for not publishing a summary of the petition 

in the Federal Register because the requested exemption would not set a precedent, and any 

delay in acting on this petition would be detrimental to the petitioner. 

Airworthiness Certification 

The UAS proposed by the petitioner are the DJI S1000 Spreading Wings, DJI Inspire, DJI 450 

Flame Wheel Quadcopter, and DJI 550 Flame Wheel Hexacopter. 

The petitioner requested relief from 14 CFR part 21, Certification procedures for products 

and parts, Subpart H—Airworthiness Certificates. In accordance with the statutory criteria 
2 

provided in Section 333 of Public Law 112−95 in reference to 49 U.S.C. § 44704, and in 

consideration of the size, weight, speed, and limited operating area associated with the 

aircraft and its operation, the Secretary of Transportation has determined that this aircraft 

meets the conditions of Section 333. Therefore, the FAA finds that the requested relief from 

14 CFR part 21, Certification procedures for products and parts, Subpart H—Airworthiness 

Certificates, and any associated noise certification and testing requirements of part 36, is 

not necessary. 

The Basis for Our Decision 

You have requested to use a UAS for aerial data collection1. The FAA has issued grants of 

exemption in circumstances similar in all material respects to those presented in your petition. 

In Grants of Exemption Nos. 11062 to Astraeus Aerial (see Docket No. FAA−2014−0352), 

11109 to Clayco, Inc. (see Docket No. FAA−2014−0507), 11112 to VDOS Global, LLC (see

Docket No. FAA−2014−0382), and 11213 to Aeryon Labs, Inc. (see Docket No. 

FAA−2014−0642), the FAA found that the enhanced safety achieved using an unmanned 

aircraft (UA) with the specifications described by the petitioner and carrying no passengers or 

crew, rather than a manned aircraft of significantly greater proportions, carrying crew in 

addition to flammable fuel, gives the FAA good cause to find that the UAS operation enabled 

by this exemption is in the public interest. 

Having reviewed your reasons for requesting an exemption, I find that— 

 They are similar in all material respects to relief previously requested in Grant of 

Exemption Nos. 11062, 11109, 11112, and 11213; 

 The reasons stated by the FAA for granting Exemption Nos. 11062, 11109, 11112, and 

11213 also apply to the situation you present; and 

 A grant of exemption is in the public interest. 

Our Decision 

In consideration of the foregoing, I find that a grant of exemption is in the public interest. 

Therefore, pursuant to the authority contained in 49 U.S.C. 106(f), 40113, and 44701, 

delegated to me by the Administrator, CellAntenna Corporation is granted an exemption from 

14 CFR §§ 61.23(a) and (c), 61.101(e)(4) and (5), 61.113(a), 61.315(a), 91.7(a), 91.119(c), 

91.121, 91.151(a)(1), 91.405(a), 91.407(a)(1), 91.409(a)(1) and (2), and 91.417(a) and (b), to 

the extent necessary to allow the petitioner to operate a UAS to perform aerial data collection. 

This exemption is subject to the conditions and limitations listed below. 

 

1

 Aerial data collection includes any remote sensing and measuring by an instrument(s) aboard the UA. 

Examples include imagery (photography, video, infrared, etc.), electronic measurement (precision surveying, RF 

analysis, etc.), chemical measurement (particulate measurement, etc.), or any other gathering of data by 

instruments aboard the UA. 
3 

Conditions and Limitations 

In this grant of exemption, CellAntenna Corporation is hereafter referred to as the operator. 

Failure to comply with any of the conditions and limitations of this grant of exemption will be 

grounds for the immediate suspension or rescission of this exemption. 

1. Operations authorized by this grant of exemption are limited to the DJI S1000 

Spreading Wings, DJI Inspire, DJI 450 Flame Wheel Quadcopter, and DJI 550 Flame 

Wheel Hexacopter when weighing less than 55 pounds including payload. Proposed 

operations of any other aircraft will require a new petition or a petition to amend this 

exemption. 

2. Operations for the purpose of closed-set motion picture and television filming are 

not permitted. 

3. The UA may 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 400 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. This exemption and all documents needed to operate the UAS and conduct its 

operations in accordance with the conditions and limitations stated in this grant of 

exemption, are hereinafter referred 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 
4 

limitations in this exemption and the procedures outlined in the operating documents, 

the conditions and limitations herein 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 this grant of 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 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 from 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 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. 

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 this exemption must comply with all manufacturer 

safety bulletins. 

13. Under this grant of exemption, a PIC must hold either an airline transport, 

commercial, private, recreational, or sport pilot certificate. The PIC must also hold a 

current FAA airman medical certificate or a valid U.S. driver’s license issued by a 

state, the District of Columbia, Puerto Rico, a territory, 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. 
5 

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 experience-building) 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 this 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 airport 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 

pre-determined 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 from 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 terms of the attached COA. 
6 

22. All aircraft operated in accordance with this exemption must 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. 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. Barriers or structures are present that sufficiently protect nonparticipating persons 

from the UA 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 this exemption. 

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

permission from 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. 
7 

If this exemption permits operations for the purpose of closed-set motion picture and 

television filming and production, the following additional conditions and limitations apply. 

29. The operator must have a motion picture and television operations manual (MPTOM) 

as documented in this grant of exemption. 

30. At least 3 days before aerial filming, the operator of the UAS affected by this 

exemption must submit a written Plan of Activities to the local Flight Standards 

District Office (FSDO) with jurisdiction over the area of proposed filming. The 3-day 

notification may be waived with the concurrence of the FSDO. The plan of activities 

must include at least the following: 

a. Dates and times for all flights; 

b. Name and phone number of the operator for the UAS aerial filming conducted 

under this grant of exemption; 

c. Name and phone number of the person responsible for the on-scene operation of 

the UAS; 

d. Make, model, and serial or N−Number of UAS to be used; 

e. Name and certificate number of UAS PICs involved in the aerial filming; 

f. A statement that the operator has obtained permission from property owners 

and/or local officials to conduct the filming production event; the list of those 

who gave permission must be made available to the inspector upon request; 

g. Signature of exemption holder or representative; and 

h. A description of the flight activity, including maps or diagrams of any area, city, 

town, county, and/or state over which filming will be conducted and the altitudes 

essential to accomplish the operation. 

31. Flight operations may be conducted closer than 500 feet from participating persons 

consenting to be involved and necessary for the filming production, as specified in the 

exemption holder’s MPTOM. 

Unless otherwise specified in this 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. 

 
8 

This exemption terminates on June 30, 2017, unless sooner superseded or rescinded. 

Sincerely, 

/s/ 

John S. Duncan 

Director, Flight Standards Service 

Enclosures 
MARJORIE K. CONNER

ATTORNEY

700 WEST VIEW TERRACE

ALEXANDRIA, VIRGINIA 22302 

APRIL 6, 2015 

703-706-5917 

mkconner@mkconnerlaw.com 

U.S. Department of Transportation 

Docket Management System 

1200 New Jersey Ave., S.E. 

Washington, D.C. 20590 

 Re: CellAntenna Corporation Petition for Exemption 

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 and 

Section 11.81 of the FAA’s rules, 14 C.F.R. §11.81 

Dear USDOT: 

 By counsel, and pursuant to Section 333 of the FAA Modernization and Reform Act of 

2012 (“Reform Act”), and Section 11.81 of the FAA’s rules, 14 C.F.R. § 11.81, CellAntenna 

Corporation (“CellAntenna”) petitions for exemption from a number of Federal Aviation 

Regulations (“FARs”),1

 as detailed herein, to allow commercial operation of small unmanned 

aircraft systems2 (“UAS”). 

 CellAntenna’s petition for exemption (“Petition”) is supported by the information 

provided herein, as well as its appended CellAntenna UAS Operations Manual (“CellAntenna 

Manual”) and each manufacturer’s UAS Manual (“UAS Manual”).3 CellAntenna submits the 

CellAntenna Manual and UAS Manual (the “Manuals”) as confidential documents, consistent 

with Section 11.35(b) of the FAA’s rules, 14 C.F.R. §11.35(b). The Manuals contain 

confidential commercial and/or proprietary information that CellAntenna has not shared and will 

not share with others. The Manuals set forth operating conditions and procedures that are not 

generally available to the public and are protected from release under the Freedom of 

Information Act, 5 U.S.C. § 552 et. seq. and any other disclosure requirements established by the 

FAA pursuant to Section 333 of the Reform Act. 

 

1

 Specifically, CellAntenna requests exemption from Part 21, Subpart H; Part 27; Sections 45.23(b); 45.27(a); 

61.113; 91.7(a); 91.9(b)(2); 91.9(c); 91.103; 91.105; 91.109(a); 91.119; 91.121; 91.151(a); 91.203(a) and (b); 

91.405(a); 91.407(a)(1); 91.409(a)(1) and (2); 91.417(a) and (b), and any other provision which the FAA determines 

should be included in the exemption request. See Jeffrey J. Walsh, Reg. Docket No. FAA-2014-0681, at 3-4. 2

 CellAntenna envisions that its UAS services will include, but will not be limited to, motion picture filming and 

other photographic services, bridge, building, construction, and other architectural observation and inspection, 

electrical power grid inspection, telecom infrastructure inspection, disaster recovery and insurance site inspection, as 

well as agriculture observation and inspection. In addition to these video and visual observation services, 

CellAntenna will provide UAS borne communications services, consistent with FCC rules and regulations. 

3

 The UAS Manual includes all manufacturer publications relating to the device, including, without limitation, 

operations and flight manuals, user guides, component maintenance manuals, pilot training manuals, service 

information letters and safety/service bulletins. 
U.S. Department of Transportation 

Docket Management System 

April 6, 2015 

Page 2 

I. CellAntenna 

 CellAntenna is a family-owned U.S. company, based in Coral Springs, Florida. Since 

2002, CellAntenna has led the industry in marketing and servicing communications devices. In 

the course of its business, CellAntenna has developed a special interest in UAS, particularly in 

combining its wireless communications expertise with UAS devices. CellAntenna’s 

communications expertise brings added reliability and diversity to its UAS operations. 

 CellAntenna’s contact information is: 

 Sid Kopperl 

 Chief Operating Officer 

 CellAntenna Corporation 

 12453 NW 44th Street 

 Coral Springs, Florida 33065 

 sk@cellantenna.com 

Telephone: 954-340-7053 

CellAntenna’s counsel: 

Marjorie K. Conner 

700 West View Terrace 

Alexandria, Virginia 22301 

II. CellAntenna’s Proposed Operation 

CellAntenna proposes to use UAS for visual observation, inspection, and recording and RF 

signal extension and detection work. CellAntenna has tailored its operations to meet the criteria 

established in the FAA’s grant of the Astraeus Aerial exemption, Exemption No. 11062, Reg. 

Docket No. FAA-2014-0352 (“Astraeus Aerial”) and the dozens of similar exemptions granted 

based on the Astraeus Aerial precedent. CellAntenna’s UAS operations will be conducted in 

accord with the conditions and limitations set forth in the grant of this Petition, CellAntenna’s 

Manual and the UAS Manual. 

CellAntenna’s UAS operations will be conducted in controlled circumstances, away from 

spectators and persons not involved in the operation. All operations will be conducted during 

daylight, Visual Flight Rule (“VFR”) conditions, at altitudes below 400 feet Above Ground 

Level (“AGL”). CellAntenna’s operations will be conducted at a level of safety superior to that 

of fixed wing aircraft or helicopters performing the same or similar work. 

III. Relevant Statutory Authority 

This Petition is submitted pursuant to Section 333(a) through (c) of the Reform Act. In 

the Reform Act, Congress directed the FAA to “safely accelerate the integration of civil 

unmanned aircraft systems into the national airspace system.” As directed by Section 333 of the 

Reform Act, where it is safe to do so, the FAA Administrator may permit unmanned aircraft 

systems to operate in the National Air Space (“NAS”), based on specific considerations: 
U.S. Department of Transportation 

Docket Management System 

April 6, 2015 

Page 3 

 The UAS’ size, weight, speed, and operational capability; 

 Control of operation of the UAS in close proximity to airports and populated 

areas; and 

 Operation of the UAS within the visual line of sight of the operator. 

The Administrator of the FAA also has general authority to grant exemptions from its safety 

regulations and minimum standards when the Administrator determines a requested exemption is 

in the public interest.4 

IV. CellAntenna’s Proposed Operations are Consistent 

with Section 333 of the Reform Act and the Astraeus Aerial Exemption 

and the dozens of Exemptions Granted based on the Astraeus Aerial Precedent. 

CellAntenna’s proposed operations fit each of the criteria for expedited approval set forth in 

Section 333 of the Reform Act, and is consistent in its basis with the 69 Petitions granted by the 

FAA between September 25, 2014 and May 26, 2015, including Astraeus Aerial. 

A. UAS Size, Weight, Speed, and Operational Capability 

A grant of the requested exemption is appropriate because the physical properties of 

CellAntenna’s UAS meet the size, weight, speed, and operational capability criteria meet the 

parameters set forth in the Astraeus Aerial grant, and its progeny. Specifically, CellAntenna’s 

UAS 

 Weigh less than 55 lb.; 

 Will not be flown in excess of 87 knots; 

 Will not be flown above 400 ft. AGL; 

 Will be flown so that the flights may be safely terminated, including with a 

reserve of 20% of the battery’s maximum charge capacity; 

 The UAS will generate altitude information using onboard GPS triangulation 

equipment, digitally encoded barometric altimeter, radio altimeter, or a 

combination of them. Altitude information will be transmitted to the pilot in 

charge by telemetric data feed. 

 The UAS will have system redundancies and independent functionalities to ensure 

the overall safety and predictability of the system. If connection to the remote 

control or ground control station is lost, failsafe systems will permit the UAS to 

return to home or to a predetermined location and safely land without injury or 

damage. 

 The radio frequencies used for operations and control of the UAS will comply 

with Federal Communications Commission (“FCC”) and/or other controlling 

rules and specifications. 

 

4 See generally, 49 U.S.C. §§ 106(f), 44701(a), (b), and (f), and 44702-44716, et. seq., and, more specifically, 14 

C.F.R. § 11.81. 
U.S. Department of Transportation 

Docket Management System 

April 6, 2015 

Page 4 

The Administrator has noted that if the operations proposed in this petition were 

conducted using a helicopter, the aircraft’s take-off weight could “weigh thousands of pounds or 

more and [would be] operated by an onboard pilot, in addition to other onboard crewmembers.”5 

The weight difference between a helicopter and CellAntenna’s UAS significantly reduces the 

potential harm to the operator and the public, in the event of an accident or incident. Remote 

operation of the UAS eliminates the risk of harm to the onboard pilot and camera or other device 

operator. The Administrator is well-acquainted with helicopter accidents that may be avoided by 

conducting aerial filming, observation, and other activities by UAS.6

B. The Operational Restrictions set forth in the CellAntenna Manual meet the 

Administrator’s criteria. 

The CellAntenna Manual and the UAS Manual provide the procedures and limitations 

necessary to safely and successfully perform the operations contemplated by this petition. Of 

note, the CellAntenna Manual and the UAS Manual provide operational limitations and 

conditions to ensure a high level of safety to operations, consistent to or exceeding current FAA 

guidelines: 

1. The UAS weighs less than 55 lb., fully loaded. 

2. The minimum crew for each operation will include a Pilot-in-Command of the UAS, 

and one or more Visual Observers (“Observer”), as necessary to conduct a safe 

mission. 

3. The UAS shall be operated within Visual Line of Sight (“VLOS”) of the PIC and 

Observer at all times. 

4. The PIC must use human vision unaided by any device other than corrective lenses. 

5. The Observer designated for any operation will be in constant voice contact with the 

PIC. 

6. Any additional requirements set forth in the Administrator’s grant of this petition 

shall be added to the CellAntenna Manual. The CellAntenna Manual shall be 

maintained and made available to the Administrator upon request. If any discrepancy 

exists between the conditions and limitations in the exemption, as granted, and the 

CellAntenna Manual, the conditions and limitations in the exemption, as granted, 

shall take precedence and shall be followed. 

7. Maximum total flight time for each operational flight shall be limited to that amount 

of time that the UAS may be flown and still maintain a reserve battery power capacity 

of no less than 20%. 

 

5

 Singer’s Creations, Exemption No. 11191, Reg. Docket No. FAA-2014-0915, at 2. 

6

 The National Transportation Safety Board (“NTSB”) maintains a database of Aviation Accidents. It may be 

accessed at: http://www.ntsb.gov/_layouts/ntsb.aviation/month.aspx. Some of the helicopter accidents reported 

there include: NTSB Report AAR-84-14, reporting three fatalities and six injuries in a closed set helicopter filming 

operation; MIA07FAH7, reporting two fatalities and one serious injury in a photo shoot over water; and 

NIC08FA071, reporting three fatalities during a search for a lost hunter. 
U.S. Department of Transportation 

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April 6, 2015 

Page 5 

8. Flights will be operated at an altitude of no more than 400 feet AGL. Flights will 

never enter navigable controlled airspace without prior written authorization and 

approval from the FAA. 

9. Lateral distances from participating persons, as defined in FAA Order 8900.1 V3, C8, 

S1, will be maintained. 

10. Flights will be operated at a lateral distance of at least 500 feet from any nonparticipating persons, unless that person is in a position in which he or she is shielded 

from the UAS and possible debris resulting from UAS failure. Flight will be 

terminated if a non-participating person within 500 feet of the UAS leaves a shielded 

position. At no time will the UAS be conducted so close to persons or objects to 

present and undue hazard to the PIC or Observer, as prescribed in Section 91.119(a) 

of the FAA’s rules, 14 U.S.C. § 91.119(a). 

11. Flights will be limited to a speed of 78 knots. 

12. Prior to each flight the PIC shall inspect the UAS to confirm that it is in safe-flight 

condition. The PIC shall not operate the UAS if the inspection reveals a condition 

that adversely affects the safe operation of the UAS unless and until the condition has 

been removed and the UAS is found to be in safe-flight condition. The Ground 

Control Station (“GCS”) shall be included in the preflight inspection. All 

maintenance, repairs, and alterations shall be properly documented in the UAS 

records. 

13. Any UAS that has undergone maintenance, repair, or alteration that affects the UAS 

operation or flight characteristics must undergo functional test flight in accordance 

with the CellAntenna Manual. The PIC conducting the functional test flight must 

record the functional test flight and its results in the UAS aircraft records. The 

requirements and procedures for functional test flights and UAS entry are prescribed 

by the CellAntenna Manual. 

14. The UAS will be operated and maintained according to the UAS Manual. 

15. Prior to any flight, a Mission Plan shall be recorded, setting forth the operational 

limitations and conditions for the mission, as well as key personnel contact 

information and a description of any anticipated hazards on or in the vicinity of the 

planned flight path or area. 

16. Unless the FAA relieves it of this obligation, CellAntenna shall obtain a Certificate of 

Waiver or Authorization (“COA”) from an Air Traffic Organization (“ATO”) prior to 

conducting operations. As long as required or appropriate, CellAntenna shall request 

a Notice to Airmen (“NOTAM”) with the appropriate ATC facility between 48 – 72 

hours before flight. 

17. If any permissions or permits are required by territorial, state, county, or municipal 

jurisdictions before flight, CellAntenna shall obtain them. 

18. CellAntenna shall coordinate its operations with the appropriate Flight Standards 

District Office (“FSDO”), as required. 

19. If the UAS loses communication with the PIC, it shall return to a pre-determined 

location within the operational area and land safely. 
U.S. Department of Transportation 

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April 6, 2015 

Page 6 

20. CellAntenna will ensure contingency plans to safely terminate the flight if there is a 

loss of communication between the PIC and the Observer. 

21. The UAS shall have the capability to abort the flight safely in the case of flightaffecting unpredicted obstacles or emergencies. 

22. Each PIC and each Observer will hold at least a current second class medical 

Certificate. 

23. Each PIC shall have accumulated and logged at least 12 hours training hours or 24 

flights accrued before designated as a PIC on any flight. 

24. Each PIC shall have accumulated and logged a minimum of 5 hours as a UAS pilot 

operating the make and model of UAS to be utilized for operations under the 

exemption, including three take-offs and three landings within the 90 days 

immediately preceding any flight. 

25. Operations shall be conducted only during daytime VFR Meteorological Conditions; 

no flights shall be conducted under special visual flight rules (“SVFR”). 

26. The UAS shall remain clear and yield the right of way to any and all manned 

operations and activities at all times, including, without limitation, ultralight vehicles, 

parachute activities, parasailing activities, hang gliders. 

27. UAS operations under Instrument Flight Rules, at night, or beyond VLOS are 

prohibited. 

V. Regulations from which CellAntenna requests Exemption. 

CellAntenna requests exemption from several interrelated provisions of Title 14 of the CFR, 

Parts 21, 45, 61, and 91, for purposes of conducting its UAS operations. The specific code 

sections are listed below, along with operational protections demonstrating that CellAntenna will 

achieve equivalent or greater safety protections than the rule from which it seeks exemption. 

A. Certain required documents to be kept at the CGS: 

Sections 91.9(b), 91.203(a) and (b), 47.31(b)(2), and 47.31(c) of Title 14 of the CFR.

On August 8, 2014, Mark W. Bury, Assistant Chief Counsel for International Law, 

Legislation and Regulations, AGC-200, issued a Memorandum regarding the maintenance of 

certain required documents when flying UAS (“Memorandum”). Specifically, the Memorandum 

stated that maintenance of the airworthiness certificates, aircraft manuals, and aircraft 

registration certificates at the CGS would satisfy the intent of the governing FAA regulations.7

 

CellAntenna proposes to maintain the required documents at the GCS, available to the PIC. 

 

7 See also, e.g., Astraeus Aerial, 19-20; Jeffrey J. Walsh, Grant of Exemption No. 11229, Reg Docket No. FAA2014-0681, at 4 (“Walsh”). 
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B. Provisions from which Exemption may be Unnecessary.

In an abundance of caution, CellAntenna seeks exemption from the obligations of certain 

provisions with which the Administrator may find CellAntenna’s operations comply or that they 

are inapplicable to UAS operation. These sections are: 

1. Airworthiness Standards Normal Category Rotorcraft: 14 C.F.R. Part 27 

Airworthiness Certificates: 14 C.F.R. Part 21 

Part 21 of Title 14 sets for the requirements for Airworthiness Certificates for Products 

and Parts. Part 27 of Title 14 sets forth the procedural requirements for airworthiness 

certification of normal category rotorcraft. In the recent decision on the petition for 

exemption filed by Solusia Air, LLC,8

 the FAA determined that in accord with the 

statutory criteria set forth in Section 333 of Reform Act, and in consideration of the size, 

weight, speed, and limited operating area associated with UAS and its operation, the 

Secretary of Transportation has determined that the UAS meets the criteria of Section 

333 of the Reform Act. Therefore, the FAA found that relief from 14 C.F.R. Part 21, and 

27 was well as any associated noise certification and testing requirements of Part 36 was 

unnecessary. 

Similarly, the UAS proposed for CellAntenna’s operations meets the Section 333 criteria. 

CellAntenna requests a determination that relief from Parts 21, 27, and 36 is unnecessary. 

2. Aircraft Marking and Identification Requirements: 14 C.F.R. §§ 91.9(c), 

45.23(b), and 45.27(a) 

In Solusia Air, the FAA said that it has previously determined, in Astraeus Aerial, that 

relief from these sections is not necessary. Relevant materials may be kept in a location 

accessible to the PIC in compliance with the regulations, and , as in Astraeus Aerial, 

compliance with registration and marking requirements of Part 45 may be met9

 because 

the UAS is not granted experimental certificates under Section 21.191 of the FAA’s 

rules, and because the UAS may be marked, in accord with 14 C.F.R. Part 45 with 

identification markings “as large as practicable.”10

CellAntenna will mark its UAS with N-Number identifiers in a manner which is as large 

as practicable, so that and equivalent level of safety may be achieved. 

3. Preflight Action: 14 C.F.R. § 91.103 

CellAntenna requests exemption from Section 91.103 of the FAA’s rules, 14 C.F.R. § 

91.103, which requires a PIC to become familiar with specific information before each 

flight, including information contained in the FAA-approved Flight Manual on board the 

 

8

 Solusia Air, LLC, March 20, 2015, Exemption No.11216, Reg. Docket No. FAA-2014-0912, at 2. 

9

 Solusia Air, at 5. 

10 Astraeus Aerial, at 14. 
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aircraft. The FAA stated that a UAS operator can comply with the other requirements of 

Section 91.103(b)(2). Pre-flight procedures that require reviewing weather, flight battery 

requirements, landings, and take-off distances and aircraft performance data before 

initiation of flight address the FAA’s concerns regarding compliance with Section 

91.103(b).11 The CellAntenna Manual sets for exactly these pre-flight procedures and 

more. 

CellAntenna will achieve an equivalent level of safety by ensuring compliance with the 

procedures set forth in the CellAntenna Manual. The PIC will review a series of 

checklists designed to identify any defects or inoperable components in in accord with 

the CellAntenna Manual, including checklists covering Pre-Flight, Launch, Landing, and 

Post-Flight procedures. The PIC will also be required to review weather, flight 

requirements, battery charge, landing and takeoff distance, UAS performance data, and 

contingency landing areas – before initiation of flight. The PIC and the Observer will 

take into account the FAA’s stricter requirements with regard to visibility and distance 

from clouds. They will also be aware of sun glare hazards. 

C. Other Provisions from which CellAntenna Seeks Exemption. 

1. Civil Aircraft Airworthiness: 14 C.F.R. § 91.7(a) and (b) 

In Solusia Air, the FAA determined that relief from Section 91.7(a) and (b) is 

necessary.12 It determined that compliance with the UAS operating documents to be a 

sufficient means for determining an airworthy condition – based on compliance with the 

operating documents prior to every flight.13 

CellAntenna requests exemption from Section 91.7(a) of the FAA’s rules, 14 C.F.R § 

91.7(a). The CellAntenna and the UAS Manual require the PIC to perform UAS 

inspection prior to every flight. The Manuals set forth standards for test flight after repair 

or significant maintenance, and set forth the timetable for routine maintenance and 

replacement of parts. An equivalent level of safety is achieved by the degree of attention 

to the airworthiness of CellAntenna’s UAS. 

2. Flight crewmembers at stations: 14 C.F.R. § 91.105 

Section 91.105 of the FAA’s rules, 14 C.F.R. § 91.105, requires that flight crewmembers 

be at specific places aboard the aircraft. Because the UAS is unmanned, no 

crewmembers are present on UAS flights. Compliance with Section 91.105, is therefore 

impossible. 

CellAntenna will maintain a Section 91.105-equivalent level of safety because it will 

avoid the dangers sought to be ameliorated by it. As no passengers or crew will be 

 

11 Solusia Air, at 5. 

12 In contrast, in Astraeus Aerial, the FAA determined that “because an airworthiness certificate will not be issued, 

exemption from § 91.7(a) is not necessary. In an abundance of caution, CellAntenna requests an exemption of § 

91.7(a), if the FAA determines an exemption is necessary and appropriate. 

13 Solusia Air, at 2. 
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onboard, there is no need to specify the places at which the crewmembers will be 

stationed. CellAntenna will achieve an equivalent level of safety because the 

CellAntenna Manual specifies stations for the PIC and Observer for all flight phases. 

3. Minimum Safe Altitudes: 14 C.F.R. § 91.119(c) 

CellAntenna requests an exemption from the minimum safe altitude requirements set 

forth in Section 91.119 of the FAA’s rules, 14 C.F.R. § 91.119. Section 91.119 

prescribes the minimum safe altitudes under which aircraft may not operate, including 

500 feet above the surface and away from any person, vessel, vehicle, or structure in noncongested areas. (Section 91.119(c)) Section 91.119(d) allows for a helicopter to operate 

a lower altitudes when it can be operated “without hazard to persons or property on the 

surface,” provided that “each person operating the helicopter complies with any routes or 

altitudes specifically prescribed for helicopters by the FAA.” 

An exemption is appropriate because in order to conduct aerial observation and filming 

and conduct the RF applications proposed by CellAntenna, a UAS must operate at an 

altitude of lower than 400 feet AGL. Order No. 8900.1 V3, C8, S1 allows UAS 

operations to be closer than 500 feet from persons involved in the flight operations. 

CellAntenna will accomplish an equivalent level of safety by minimizing the dangers 

attendant to the flights generally controlled by Section 91.119. Helicopters, by their size, 

fuel load, and difficulty to control, are much more dangerous than UAS devices. With 

the minimal size, weight, and speed of CellAntenna’s UAS, as well as the CellAntenna 

Manual’s requirement that flights be in restricted areas, a lateral distance of at least 500 

feet from any nonparticipating unshielded person, CellAntenna’s proposed UAS flights 

are much safer than helicopter or fixed wing manned flights for the same purposes. 

If any nonparticipating person leaves a shielded position, the CellAntenna Manual 

requires that the flight be terminated. Additionally, the CellAntenna Manual requires that 

UAS operations occur at least 500 feet away from vehicles or structures for which the 

property owner or controller has not granted permission and the PIC or the Observer has 

not conducted a safety assessment. 

CellAntenna requests permission to conduct operations as close as 200 feet from nonparticipating persons with the consent of the Administrator, as granted to Astraeus 

Aerial.14

Even in the closer proximities, CellAntenna’s operations will achieve and equivalent or 

even greater level of safety than that traditionally accomplished by Section 91.119. 

4. Altimeter Settings: 14 C.F.R. § 91.121 

CellAntenna requests an exemption from Section 91.121 of the FAA’s rules, 14 C.F.R. § 

91.121, which requires a person operating an aircraft to maintain cruising altitude or 

 

14 Astraeus Aerial, at 20-21. 
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flight level by reference to an altimeter that is set to the elevation of the departure airport 

or barometric pressure. And exemption is required to the extent that UASs do not use a 

barometric altimeter. Rather UASs maintain altitude and monitor it through an onboard 

GPS altitude read out. 

In the grant of the Astraeus Aerial exemption, the FAA has stated than a Section 91.121 

equivalent level of safety can be achieved in circumstances where: 1) the UAS is 

operated at 400 feet AGL or below; 2) within VLOS; 3) where GPS based altitude 

information is relayed in real time to the operator at a ground-based on-screen display; 

and 4) where prior to each flight, a zero altitude initiation point is established for the PIC 

to confirm accuracy of the onboard GPS. 15 

CellAntenna’s UAS meets all of these described operational characteristics. As required 

by the CellAntenna Manual, the PIC will be required to calibrate the aricraft’s GPS 

compass prior to each flight. Like the grant of the Astraeus Aerial exemption, the 

CellAntenna UAS, and the CellAntenna Manual safety mitigation procedures both ensure 

a Section 91.121-equivalent level of safety. 

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

CellAntenna requests an exemption from Section 91.151(a) fuel requirements for flight in 

VFR conditions. Section 91.151 requires sufficient fuel onboard to fly to the first point 

of intended landing and then some before a flight may begin. Because UAS devices are 

not powered by “fuel” but by battery power, the fuel requirement is not meaningful in the 

UAS context. 

The FAA has recognized that an equivalent level of safety may be achieved through 

reservation of ample battery power, specified as a reserve of 20% of battery power or 

completion of the flight within 30 minutes flight time, whichever comes first.16

Not only does the CellAntenna Manual specify compliance with the FAA’s battery 

reservation requirement, but CellAntenna’s UAS uses a low battery warning system. The 

amount of battery reserve power remaining will be transmitted to the PIC via telemetric 

data feed, which downlinks from the UAS to a ground-based-on-screen display. As 

specified in the CellAntenna Manual, the PIC will immediately fly the UAS back to the 

home launch location or a pre-determined location at which the UAS may land safely, 

while still maintaining a minimum of 20% reserve battery power. The CellAntenna 

Manual procedures, combined with its flight limitations, the size, weight, speed, and 

operational capability of the UAS devices – within the VLOS of the PIC and Observer 

ensure that CellAntenna’s proposed operation will equal, and may exceed, Section 91.151 

safety levels. 

6. Maintenance Inspections: 14 C.F.R. §§ 91.405(a), 91.407(a)(1), 91.409(a)(1) 

and (2), 91.417(a) and (b) 

 

15 Astraeus Aerial, at 21. 

16 See, e.g., Astraeus Aerial, at 21; Clayco, Inc., Exemption No. 11109, Docket No. FAA-2014-0507, at 15. 
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Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) and (2), 91.417(a) and (b) of the FAA’s 

rules, 14 C.F.R. §§ 91.405(a), 91.407(a)(1), 91.409(a)(1) and (2), 91.417(a) and (b), 

require that an aircraft be inspected and have discrepancies repaired, in accord with Part 

43 of the FAA’s rules. Part 43 relates to airworthiness certification processes. 

Airworthiness certificates are not appropriately obtained for UAS devices, so that an 

exemption from the Maintenance Inspection rules is appropriate.

CellAntenna will maintain an equivalent level of safety by conducting maintenance and 

inspections in accord with the CellAntenna Manual and the UAS Manual. The PIC will 

conduct a pre-flight inspection of the UAS and all associated equipment to account for 

any discrepancies or inoperable components. CellAntenna will perform and verify 

maintenance to correct any conditions which may affect safe operation of the UAS. No 

flights will be undertaken unless and until all flight-critical components of the UAS have 

been determined to be airworthy and in a safe operation condition. CellAntenna will 

conduct a functional test flight following the replacement or repair of any flight-critical 

components. The PIC will record the functional test flight in the aircraft records upon 

successful completion. 

The CellAntenna Manual also includes requirements to follow manufacturer UAS 

aircraft/component, maintenance, overhaul, replacement, inspection, and life-limit 

specifications for essential components, including: powertrain system (power plant), 

propellers, avionics, and control surfaces (including ailerons/elevens), structures and 

airframe, camera system, electrical systems (including batteries), GCS, hazard 

accessories, and spare parts. The CellAntenna Manual also includes procedures to 

document and maintain a record of the UAS maintenance, preventative maintenance, 

alterations, status of replacement/overhaul component parts, and the total time in-service 

of CellAntenna’s UASs. As a whole, the procedures specified in the CellAntenna 

Manual ensure that maintenance inspections will be conducted in a manner to achieve an 

equivalent or higher level of safety, when compared to the FAA’s rules. 

7. Private Pilot Privileges and Limitations: 14 C.F.R. § 61.113 

Section 61.113 of the FAA’s rules, 14 C.F.R. § 61.113, restricts private pilot certificate 

holders from flying aircraft for compensation or hire. It also would require each PIC to 

hold a second class medical certificate. The restrictions and requirements of Part 61 are 

designed to protect passengers or cargo when carried for hire. Operation of a UAS for 

hire bears much less risk to life, limb, and treasure, because of the size, weight, speed, 

and operational capability of the UAS. CellAntenna’s UAS will not carry passengers or 

cargo. 

The FAA has recognized the unique characteristics of UAS, and acknowledged that UAS 

operation does not warrant the additional cost and restrictions attendant to requiring a 

PIC for hire to have a commercial pilot certificate and a second class medical certificate. 

CellAntenna will ensure Section 61.113-equivalent safety through the requirements set 

forth in the CellAntenna Manual. The CellAntenna Manual includes the restrictions 
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imposed on Astraeus Aerial in the exemption granted to it. CellAntenna will operate 

away its UAS away from persons and property not involved in its operation. Flights will 

be conducted by VLOS at 400 feet AGL or below. When required, a NOTAM will be 

issued between 48 and 72 hours before the flight will commence. As required, the flight 

will be coordinated with the appropriate FSDO. 

CellAntenna’s PICs are and will be thoroughly conversant in airspace and 

communications issues arising in all aircraft operations and, particularly, in the unique 

aspects of UAS operations. The CellAntenna Manual requires PICs to have UAS 

experience, including flight time logged with the specific make and model he or she 

deploys for each mission. These precautions ensure that CellAntenna’s operations will 

achieve a level of safety equivalent to or even higher than that achieved by the 

requirements of Section 61.113 of the FAA’s rules. 

D. Drug and Alcohol Program 

CellAntenna is an ongoing business. It is a small, family-owned company. It currently has 

policies in place to ensure that no person is under the influence of alcohol or any drug while 

conducting CellAntenna business. Its policies will extend to ensure that no person may 

participate in UAS flight operations under the influence of alcohol or any drug. 

E. Public Interest. 

The FAA recently documented the significant public interest in the grant of petitions for 

exemption so that UAS may be commercially deployed. In the process of proposing rules for 

UAS, the FAA’s Office of Aviation Policy and Plans, Economic Analysis Division issued an 

evaluation of the impact of the proposed rules (“OAPP Regulatory Evaluation”). The evaluation 

found both economic benefits and safety benefits in the operation of UAS, particularly to the 

extent UAS replaced more dangerous activities.17 

 

In the OAPP Regulatory Evaluation, the FAA specifically analyzed four UAS commercial 

uses: A) Aerial Photography; B) Precision Agriculture; C) Search and rescue/law enforcement; 

and D) Bridge Inspection. 

A. Aerial Photography 

Considering use of UAS in Aerial Photography, the FAA found that by substituting an 

unmanned aviation operation using a very light aircraft for a more complex manned aviation 

operation that uses a much heavier aircraft, dangers of an accident, to both people onboard and 

on the ground, are minimized. The FAA also recognizes that cost-savings will occur by the 

reduction in cost for aerial photography. 18 

 

17 OAPP Regulatory Evaluation, at 14-26 

18 Id., at 16-17 
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B. Precision Agriculture 

Considering use of UAS in precision agriculture, the FAA recognized the likely limited use 

of UAS in agriculture. The FAA did not expect that UAS would be used to apply pesticides or 

fertilizers, but UAS can be used to monitor application and yields. UAS may be employed to 

collect data on the hydration and general condition of crops. The information gathered allows 

farmers to manage water, insecticide application, and nutrient application. These more efficient 

uses of resources save agricultural investment, increase productivity, and may even have a 

positive impact on the environment.19

C. Law Enforcement 

Law enforcement uses of UAS are of particular interest to CellAntenna.20 In considering use 

of UAS in law enforcement and disaster recovery and relief, the FAA recognized the significant 

cost savings to federal, state, and local governmental entities. Cost savings, as compared to 

deployment of helicopters, runs up to $550/hour of governmental funds. While not all helicopter 

missions may be replaced with UAS missions, the cost savings of substitution may be 

significant. Additionally, the speed to deployment, the stealth capabilities, and the safety aspects 

of UAS substitution bring significant benefit to the public.21

D. Bridge Inspections 

In considering use of UAS in bridge inspections, the FAA noted that it is difficult for 

helicopters to get close enough to bridges for adequate inspection. Expensive, special equipment 

must be deployed, and often human beings climb the bridges to view bridge conditions up close. 

Use of UAS in bridge inspections bring cost savings and safety benefits.22

E. FAA Precedent 

Even before the FAA conducted its analysis of the public interest benefits of commercial 

deployment of UAS, the FAA recognized its benefits. In granting the dozens of exemptions 

granted so far, the FAA found that UAS operations significantly improve safety and reduce risk 

by alleviating the public’s exposure to danger and emissions associated with traditional aircraft 

and helicopter operation. CellAntenna’s proposed operations will be battery powered avoiding 

the ignition hazards attendant to fuel-powered operations. The FAA has recognized that 

accidents involving UAS are significantly less dangerous -- to pilots and the public -- than 

accidents involving full-size helicopters. 

CellAntenna’s proposed operations are similar to the operations proposed in the dozens of 

exemptions granted by the FAA. Particularly, in the recent grant to Jeffrey J. Walsh,23 the FAA 

noted that the enhanced safety achieved using an unmanned aircraft (UA), as proposed by Mr. 

 

19 Id., at 18 

20 CellAntenna’s long service to law enforcement agencies is documented, in part, in its efforts to eradicate 

contraband wireless devices from correctional facilities in FCC Docket No. 13-111. 21 OAPP Regulatory Evaluation, at 18-20 

22 Id., at 22-23 

23 Jeffrey J. Walsh, Docket No. FAA-2014-0681, granted March 24, 2015. 
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Walsh and CellAntenna, and carrying no passengers or crew, rather than a manned aircraft of 

significantly greater proportions, carrying crew, in addition to flammable fuel, gives the FAA 

good cause to find that the UAS operation enabled by [Mr. Walsh’s] exemption is in the public 

interest. 

F. Federal Register Summary 

CellAntenna notes that the relief requested in this petition is identical to the exemption 

granted to dozens of other petitioners. Pursuant to Section 11.87 of the FAA’s rules, 

CellAntenna asks that the FAA forego publication of its petition in the FEDERAL REGISTER. If the 

FAA determines that FEDERAL REGISTER publication is necessary, CellAntenna provides the 

following summary for publication in the FEDERAL REGISTER. 

CellAntenna seeks an exemption from the several provisions of Title 14 of the Code of 

Federal Regulations. Specifically: 

Part 21, Subpart H; Part 27; Sections 45.23(b); 45.27(a); 61.113; 91.7(a); 91.9(b)(2); 

91.9(c); 91.103; 91.105; 91.109(a); 91.119; 91.121; 91.151(a); 91.203(a) and (b); 

91.405(a); 91.407(a)(1); 91.409(a)(1) and (2); 91.417(a) and (b). 

The requested exemption will enhance public safety by reducing risk to the general 

public and property owners from the substantial hazards associated with performing 

equivalent work with conventional fixed-wing aircraft, rotorcraft, or other methods. 
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Page 15 

G. Conclusion 

CellAntenna’s Petition for exemption satisfies the criteria articulated in Section 333 of the 

Reform act, including size, weight, speed, and operational capability, proximity to airports and 

populated areas, operation within VLOS and national security. The proposed UAS operations 

will benefit the public as a whole by improving safety and reducing risk by alleviating human 

exposure to danger. In consideration of the foregoing, this Petition for Exemption provides the 

FAA with sufficient justification for grant of the request allowing CellAntenna to perform 

commercial operations using UAS. 

CellAntenna appreciates your prompt consideration of its Petition. Should questions arise, 

please give me a call to discuss. 

 Very truly yours, 

 

 Marjorie K. Conner 

 Counsel to CellAntenna Corporation 

Attachment A: CellAntenna Manual 

Attachment B: UAS Manual 

Attachments contain proprietary and commercial information and are exempt from disclosure 

under the Freedom of Information Act, 5 U.S.C. § 552, et. seq., and should be held in a separate 

confidential file in accord with Section 11.35(b) of the FAA’s rules, 14 C.F.R. § 11.35(b). 
Confidential Attachment A 

CellAntenna Manual 

 
Confidential Attachment B 

UAS Manual 
FAA FORM 7711-1 UAS COA Attachment

FAA-2015-1010

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DEPARTMENT OF TRANSPORTATION

FEDERAL AVIATION ADMINISTRATION

CERTIFICATE OF WAIVER OR AUTHORIZATION

ISSUED TO

CellAntenna Corporation

700 West View Terrace

Alexandria, VA 22302

 This certificate is issued for the operations specifically described hereinafter. No person shall conduct 

any operation pursuant to the authority of this certificate except in accordance with the standard and special 

provisions contained in this certificate, and such other requirements of the Federal Aviation Regulations not 

specifically waived by this certificate.

OPERATIONS AUTHORIZED

Operation of DJI S1000 Spreading Wings, DJI Inspire, DJI 450 Flame Wheel Quadcopter, and DJI 550 

Flame Wheel Hexacopter Unmanned Aircraft Systems at or below 200 feet Above Ground Level (AGL) 

for the purpose of aerial data collection.

LIST OF WAIVED REGULATIONS BY SECTION AND TITLE

N/A

STANDARD PROVISIONS

1. A copy of the application made for this certificate shall be attached and become a part hereof.

2. This certificate shall be presented for inspection upon the request of any authorized representative of the 

Federal Aviation Administration, or of any State or municipal official charged with the duty of enforcing 

local laws or regulations.

3. The holder of this certificate shall be responsible for the strict observance of the terms and provisions 

contained herein.

4. This certificate is nontransferable.

Note-This certificate constitutes a waiver of those Federal rules or regulations specifically referred to 

above. It does not constitute a waiver of any State law or local ordinance.

SPECIAL PROVISIONS

Special Provisions are set forth and attached.

This certificate FAA-2015-1010-333E is effective from June 23, 2015 to June 30, 2017 and is subject to 

cancellation at any time upon notice by the Administrator or his/her authorized representative.

BY DIRECTION OF THE ADMINISTRATOR 

 /S/

 FAA Headquarters, AJV-115 Jacqueline R. Jackson 

 (Region) (Signature)

 June 15, 2015 Manager, UAS Tactical Operations Section

 (Date) (Title)

FAA Form 7711-1 (7-74)

Small UAS Operations 200 feet and below for 

Commercial Purposes March 2015
FAA FORM 7711-1 UAS COA Attachment

FAA-2015-1010

Page 2 of 6

STANDARD PROVISIONS

A. General.

1. The approval of this COA is effective only with an approved FAA Grant of Exemption. 

2. A copy of the COA including the special limitations must be immediately available to all 

operational personnel at each operating location whenever UAS operations are being 

conducted. 

3. This authorization may be canceled at any time by the Administrator, the person 

authorized to grant the authorization, or the representative designated to monitor a 

specific operation. As a general rule, this authorization may be canceled when it is no 

longer required, there is an abuse of its provisions, or when unforeseen safety factors 

develop. Failure to comply with the authorization is cause for cancellation. The operator

will receive written notice of cancellation.

B. Safety of Flight.

1. The operator or pilot in command (PIC) is responsible for halting or canceling activity in 

the COA area if, at any time, the safety of persons or property on the ground or in the air 

is in jeopardy, or if there is a failure to comply with the terms or conditions of this 

authorization.

See-and-Avoid

Unmanned aircraft have no on-board pilot to perform see-and-avoid responsibilities; 

therefore, when operating outside of active restricted and warning areas approved for 

aviation activities, provisions must be made to ensure an equivalent level of safety exists 

for unmanned operations consistent with 14 CFR Part 91 §91.111, §91.113 and §91.115. 

a. The pilot in command (PIC) is responsible:

• To remain clear and give way to all manned aviation operations and activities at 

all times,

• For the safety of persons or property on the surface with respect to the UAS, and

• For compliance with CFR Parts 91.111, 91.113 and 91.115

b. UAS pilots will ensure there is a safe operating distance between aviation activities 

and unmanned aircraft (UA) at all times. 

c. Visual observers must be used at all times and maintain instantaneous communication 

with the PIC.

d. The PIC is responsible to ensure visual observer(s) are: 

Small UAS Operations 200 feet and below for 

Commercial Purposes March 2015
FAA FORM 7711-1 UAS COA Attachment

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• Able to see the UA and the surrounding airspace throughout the entire flight, and 

• Able to provide the PIC with the UA’s flight path, and proximity to all aviation 

activities and other hazards (e.g., terrain, weather, structures) sufficiently for the 

PIC to exercise effective control of the UA to prevent the UA from creating a 

collision hazard. 

e. Visual observer(s) must be able to communicate clearly to the pilot any instructions 

required to remain clear of conflicting traffic. 

2. Pilots are reminded to follow all federal regulations e.g. remain clear of all Temporary 

Flight Restrictions, as well as following the exemption granted for their operation.

3. The operator or delegated representative must not operate in Prohibited Areas, Special 

Flight Rule Areas or, the Washington National Capital Region Flight Restricted Zone. 

Such areas are depicted on charts available at 

http://www.faa.gov/air_traffic/flight_info/aeronav/. Additionally, aircraft operators 

should beware of and avoid other areas identified in Notices to Airmen (NOTAMS) 

which restricts operations in proximity to Power Plants, Electric Substations, Dams, 

Wind Farms, Oil Refineries, Industrial Complexes, National Parks, The Disney Resorts, 

Stadiums, Emergency Services, the Washington DC Metro Flight Restricted Zone, 

Military or other Federal Facilities.

4. All aircraft operated in accordance with this Certificate of Waiver/Authorization must 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. 

Markings must be) as large as practicable.

C. Reporting Requirements

1. Documentation of all operations associated with UAS activities is required regardless of 

the airspace in which the UAS operates. NOTE: Negative (zero flights) reports are 

required.

2. The operator must submit the following information through

mailto:9-AJV-115-UASOrganization@faa.gov on a monthly basis:

a. Name of Operator, Exemption number and Aircraft registration number

b. UAS type and model

c. All operating locations, to include location city/name and latitude/longitude

d. Number of flights (per location, per aircraft)

e. Total aircraft operational hours

f. Takeoff or Landing damage

Small UAS Operations 200 feet and below for 

Commercial Purposes March 2015
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g. Equipment malfunctions. Reportable malfunctions include, but are not limited to the 

following: 

(1) On-board flight control system

(2) Navigation system

(3) Powerplant failure in flight

(4) Fuel system failure

(5) Electrical system failure

(6) Control station failure 

3. The number and duration of lost link events (control, performance and health monitoring, 

or communications) per UA per flight.

D. Notice to Airmen (NOTAM).

A distant (D) NOTAM must be issued when unmanned aircraft operations are being 

conducted. This requirement may be accomplished:

a. Through the operator’s local base operations or NOTAM issuing authority, or

b. By contacting the NOTAM Flight Service Station at 1-877-4-US-NTMS (1-877-487-

6867) not more than 72 hours in advance, but not less than 24 hours prior to the 

operation, unless otherwise authorized as a special provision. The issuing agency will 

require the:

(1) Name and address of the pilot filing the NOTAM request

(2) Location, altitude, or operating area

(3) Time and nature of the activity.

(4) Number of UAS flying in the operating area. 

AIR TRAFFIC CONTROL SPECIAL PROVISIONS

A. Coordination Requirements.

1. Operators and UAS equipment must meet the requirements (communication, 

equipment and clearance) of the class of airspace they will operate in.

2. Operator filing and the issuance of required distance (D) NOTAM, will serve as 

advance ATC facility notification of UAS operations in an area.

3. Operator must cancel NOTAMs when UAS operations are completed or will not be 

conducted.

4. Coordination and deconfliction between Military Training Routes (MTRs) is the 

operator’s responsibility. When identifying an operational area the operator must 

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evaluate whether an MTR will be affected. In the event the UAS operational area 

overlaps (5 miles either side of centerline) an MTR, the operator will contact the 

scheduling agency 24 hours in advance to coordinate and deconflict. Approval from 

the scheduling agency is not required. Scheduling agencies are listed in the Area 

Planning AP/1B Military Planning Routes North and South America, if unable to gain 

access to AP/1B contact the FAA at email address 

mailto:9-AJV-115-UASOrganization@faa.gov with the IR/VR routes affected and the 

FAA will provide the scheduling agency information. If prior coordination and 

deconfliction does not take place 24 hours in advance, the operator must remain clear 

of all MTRs.

B. Communication Requirements.

1. When operating in the vicinity of an airport without an operating control tower,

announce your operations in accordance with the FAA Aeronautical Information 

Manual (AIM) 4-1-9 Traffic Advisory Practices at Airports without Operating Control 

Towers. 

C. Flight Planning Requirements.

Note: For all UAS requests not covered by the conditions listed below, the exemption 

holder may apply for a new Air Traffic Organization (ATO) Certificate of Waiver or

Authorization (COA) at https://oeaaa.faa.gov/oeaaa/external/uas/portal.jsp

This COA will allow small UAS (55 pounds or less) operations during daytime VFR

conditions under the following conditions and limitations: 

(1) At or below 200 feet AGL; and 

(2) Beyond the following distances from the airport reference point (ARP) of a public use 

airport, heliport, gliderport, seaplane base and military airports listed in the 

Airport/Facility Directory, Alaska Supplement, or Pacific Chart Supplement of the 

U.S. Government Flight Information Publications.

a) 5 nautical miles (NM) from an airport having an operational control tower; or

b) 3 NM from an airport having a published instrument flight procedure, but not 

having an operational control tower; or

c) 2 NM from an airport not having a published instrument flight procedure or an 

operational control tower; or

d) 2 NM from a heliport, gliderport or seaplane base

D. Emergency/Contingency Procedures.

1. Lost Link/Lost Communications Procedures:

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• If the UAS loses communications or loses its GPS signal, the UA must return to a 

pre-determined location within the private or controlled-access property and land.

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

2. Any incident, accident, or flight operation that transgresses the lateral or vertical

boundaries defined in this COA must be reported to the FAA via email at 

mailto:9-AJV-115-UASOrganization@faa.gov 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

AUTHORIZATION

This Certificate of Waiver or Authorization does not, in itself, waive any Title 14 Code of 

Federal Regulations, nor any state law or local ordinance. Should the proposed operation 

conflict with any state law or local ordinance, or require permission of local authorities or 

property owners, it is the responsibility of the operator to resolve the matter. This COA does not 

authorize flight within Special Use airspace without approval from the scheduling agency. The 

operator is hereby authorized to operate the small Unmanned Aircraft System in the National 

Airspace System.

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