Wright Aerial LLC

2831 Eldorado Parkway, Ste. 103-137

Frisco, Texas

Tel: (972) 821-6207

Chris@WrightAerial.com

August 20, 2015

Dear FAA,

This petition is being submitted on our own behalf without legal counsel or consulting 

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

Reform Act), and 14 C.F.R. Part 11, Wright Aerial LLC ("Wright Aerial"}, a Texas based 

limited liability company, operating a Small Unmanned Aircraft System ("sUAS") equipped 

to conduct aerial photography and survey for various industries, hereby applies for an 

exemption from the Federal Aviation Regulations (FARs) listed below to allow operation 

of our sUAS commercially in airspace regulated by the Federal Aviation Administration

(FAA), so long as such operations are conducted with and under the conditions outlined 

herein or as may be established by the FAA as required by Section 333.

The requested exemption would permit Wright Aerial to pursue its commercial interests 

in providing services to consumers interested in aerial data capture using a small 

advanced sUAS in the following areas:

• Media Production

• Real Estate Photography

• Agricultural & Land Surveying

• Aerial Mapping

• Search and Rescue Operations
• sUAS Operator Training

• Product Demonstrations

• Research and Development

WRIGHT AERIAL states that all sUAS flights that will occur over private or controlled 

access property will do so with the property owner's prior consent and knowledge and 

that only people who have consented or otherwise have agreed to be in the area where 

photography and videography will take place will be captured in identifiable form.

Additionally, Wright Aerial PIGs (Pilot-In-Command) will hold, at minimum, a Recreational 

or sport pilot certificate. If observers are not qualified pilots, they will be trained by Wright

Aerial pilots to understand the proper roles of an observer, communication procedures, 

proper visual scan techniques, operations at non-towered airports, and appropriate 

sections of the Aeronautical Information Manual.

Regulations from which the exemption is requested:

14 C.F.R. Part 21

14 C.F.R. 45.23 (b)

14 C.F.R. 61.113(a) and (b)

14 C.F.R. 91.7 (a)

14 C.F.R. 91.9 (b) (2)

14 C.F.R. 91.109

14 C.F.R. 91.119

14 C.F.R. 91.121

14 C.F.R. 91.151(a)

14 C.F.R. 91.203 (a) & (b)

14 C.F.R. 91.205 (b)

14 C.F.R. 91.215

14 C.F .R. (91.401 - 91.417)
Small Unmanned Aircraft System (sUAS)

sUAS are a feasible method to obtain information of agricultural cropland to determine 

optimum inputs that result in cost savings to farmers, yield security, and reduce 

environmental impact of excess fertilizers and chemicals in the soil. sUAS are a feasible 

method to perform valuable commercial media, film and photography functions more 

safely and effectively than other methods. sUAS are a feasible method for capturing 

imagery for survey and 3D mapping. sUAS are a feasible method of assisting in 

coordinated Search-And-Rescue operations with the authorization of local authorities.

We are petitioning for exemption to enable Wright Aerial to operate a DJI Phantom 3

multi-rotor equipped with a three-axis gimbaled camera, and a DJI Inspire 1 multi-rotor 

equipped with a three-axis gimbaled camera. These sUAS all weigh less than 55 lbs., all 

have a built-in capability to limit the height flown above the ground and to limit the radius 

of the distance flown from the operator and to exclude the sUAS from Class B, C and D 

airspace including a no fly zone feature. Each system also has the failsafe function of the 

autopilot system, which means that when the communication between the Main Controller 

and the transmitter is lost, the system will automatically trigger Return to Home and will 

land safely at the original launch point.

Each Wright Aerial sUAS utilizes four or eight counter-rotating propellers for balance, 

control and stability in all segments of flight. Each craft weighs less than 55 pounds, 

including cinematic and other equipment. Each small unmanned aircraft is designed to 

primarily hover in place and operate at less than a 50 knot maximum speed. They are 

capable of vertical and horizontal operations but operate only within the line of sight of 

the remote control pilot. 

The above specifications meet standards listed below, some derived in accordance with 

the Model Aircraft Operating Standards:

• The petitioner will only operate its sUAS in line of sight of a pilot and/or observer 

and will operate at a 'sufficient distance' from populated areas. Such operations 

will insure that the sUAS will "not create a hazard to users of the national 

airspace system or the public."

• When flying sUAS within 3 miles of an airport, airport operators will be notified 

and the operator will give the right of way to avoid flying in the proximity of fullscale aircraft.

• During sUAS operations, the petitioner will place visual notifications at the 

operation site to alert any nearby persons that sUAS operations are in progress.

• Maximum flight time for each operational flight will be 60 minutes.

• Flights will be terminated at 25% battery power reserve should that occur prior to 

the 60 minute limit.
• The sUAS will be programmed so that it will not be operated at an altitude of no 

more than 600 feet AGL, and not more than 200 feet above an elevated platform 

from which filming is planned.

• Minimum crew for sUAS operations will consist of the sUAS Pilot and the Visual 

Observer.

• The sUAS PIC's (Pilot in Command) will hold a FAA Recreational or Sport, 

Private Pilot or Commercial Pilot Certificate.

• The sUAS operated by the petitioner weighs less than 55 pounds, including the 

payload (i.e. camera, lens, and gimbal).

• The sUAS will operate at speeds of no more than 55 knots.

• Given the small size of the sUAS and the restricted sterile environment within 

which they will operate, our sUAS operations adhere to the Reform Act's safety 

requirements.

Wright Aerial operation of its fleet of small unmanned aircraft will not "create a hazard to 

users of the national airspace system or the public." 112 P.L. 95 § 3 3 3 (b). Given the 

small size and weight of Wright Aerial sUAS, combined with their safety focused 

operation standards, Wright Aerial flight operations fall within Congress's contemplated 

safety zone when it disseminated the Reform Act and the corresponding directive to 

integrate UASs into the national airspace system. Wright Aerial sUAS have a 

demonstrable safety record and do not pose any threat to the general public or national 

security.

Wright Aerial operators have extensive knowledge of and experience with sUAS 

systems, and have a high regard to safety and coordination with general aviation. 

Additionally, the fact that the Wright Aerial pilots hold FAA Recreational or Sport Pilot 

certificates demonstrates that they have a high regard to safe operations with an 

understanding of FARs, preflight inspections, maintenance and repair, operations within 

airspace, as well as being trained to high safety standards.

Under the requested exemption, Wright Aerial ensures that all operators have 

completed a small unmanned aircraft systems (UAS) education and training program 

including all applicable regulations and guidance documents; including aeronautical 

background information such as charts, NOTAMS and Aircraft Circulars; Radio 

Communications Procedures; Human Factors and Crew Resource Management; Basic 

Small UAS Aerodynamics; Weather factors; Airmanship and Decision-making and Safe 

Operating Procedures.

We respectfully request exemption under Section 333 to enable Wright Aerial to operate 

safe, low-risk commercial sUAS operations for the activities stated. Wright Aerial, at all 
times, will respect the space and privacy of citizens and property whilst keeping our 

skies safe.

Sincerely

Christopher Moore

CEO

Wright Aerial LLC

2831 Eldorado Parkway

Suite 103-137

Frisco, Texas 75033

972.821.6207
EXEMPTION REQUESTS AND EQUIVALENT LEVEL OF SAFETY

Wright Aerial requests an exemption from the following regulations as well as any 

additional regulations that may technically apply to the operation of the sUAS System:

14 CFR Part 21, Airworthiness Certificates

Section 91.203(a)(1) requires all civil aircraft to have a certificate of airworthiness. 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 ). Given the size of the aircraft and the limited operating area associated with 

its utilization, it is unnecessary to go through the certificate of airworthiness process under 

Part 21 Subpart H to achieve or exceed current safety levels. Such an exemption meets 

the requirements of an equivalent level of safety under Part 11 and Section 333 of the 

Reform Act. The Federal Aviation Act 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 UAS involved. In this case, an analysis of these criteria 

demonstrates that the Wright Aerial UASs operated without an airworthiness certificate, 

under the conditions proposed herein, will be at least as safe, or safer, than a conventional 

aircraft (fixed wing or rotorcraft) with an airworthiness certificate. The UASs will remain 

less than 55 lbs. GTOW, will not carry a pilot or passenger, will not carry flammable fuel, 

and will operate exclusively within an area predisclosed and in compliance with conditions 

set forth herein. Operations under this exemption will be tightly controlled and monitored 

by both the operator, pursuant to the conditions set forth above, and by local public safety 

requirements. The FAA will have advance notice of all operations through the filings with 

the FSDO. Receipt of the prior permission of the land owner, or controlling authority, the 

size of the aircraft, the lack of flammable fuel, and the fact that the aircraft is carried to 

the location and not flown there all establish the equivalent level of safety. The UASs 

construction with absorbent material provides at least an equivalent level of safety to that 

of such operations being conducted with conventional aircraft that would be orders of 

magnitude larger and would be carrying passengers, cargo, and flammable fuel.

14 CFR 45.23 Display of marks; general and 45.29 Size of marks.

These regulations provide that each aircraft must display "N" and the aircraft's registration 

number in letters at least 3 inches high. Additionally, the aircraft must display the word

"EXPERIMENTAL" in letters at least 2 inches high near the entrance to the cabin, cockpit, 

or pilot station. The sUAS does not have an entrance in which the word 

"EXPERIMENTAL" can be placed, and may not have a registration number assigned to 

it by the FAA. We propose to achieve an equivalent level of safety by including the word 

"EXPERIMENTAL" in the placard on the top of the aircraft, as shown above, where the 

PIC, VO and others in the vicinity of the aircraft while it is preparing for launch will be able

to see the designation. Additionally, we feel that the permanent placard discussed in the 

previous paragraph will provide the aircraft's registration information at the ground station. 

Finally, we will display at the ground station a high contrast flag or banner that contains 
the words "Unmanned Aircraft Ground Station" in letters 3 inches high or greater. Since 

the aircraft will operate within 3/4 NM of the ground station, the banner should be visible 

to anyone that observes the aircraft and chooses to investigate its point of origin.

14 CFR 61.113 Private pilot privileges and limitations: Pilot in Command and 61.133 

Commercial pilot privileges and limitations.

The regulation provides that no person that holds a Private Pilot certificate may act as 

pilot in Command of an aircraft for compensation or hire. Subparagraph (b) allows a 

private pilot to act as pilot in command of an aircraft in connection with any business or 

employment if: (1) The flight is only incidental to that business or employment; and (2) 

The aircraft does not carry passengers or property for compensation or hire. Our 

proposed operations require that the PIC must hold at least a Recreational or Sport Pilot 

Certificate issued by the FAA and since the aircraft cannot carry passengers or property, 

we feel we meet the intent of 61.113 Subparagraph (b) even though the intent of this 

application is to conduct a business.

14 CFR 91.7 Prohibits the Operation of an aircraft without an airworthiness 

certificate.

As no such certificate will be applicable in the form contemplated by the FARs, this 

Regulation is inapplicable.

14 CFR 91.9 Civil aircraft flight manual, marking, and placard requirements.

This regulation provides that no person may operate an aircraft unless a current, 

approved flight manual is in the aircraft. We assume that the intent of this requirement is 

to ensure that flight manual information is available to the aircrew while operating the 

aircraft. We request an exemption to this requirement since the aircraft is not only too 

small to carry documentation, the documentation would not be available to the crew 

during flight operations. To obtain an equivalent level of safety and meet the intent of 

91.9, we propose that a current, approved sUAS Flight Manual must be available to the

crew at the ground station anytime the aircraft is in, or preparing for, flight.

14 CFR 91.109 Flight Instruction; Simulated instrument flight and certain flight tests

The regulation states that "No person may operate a civil aircraft that is being used for 

flight instruction unless that aircraft has fully functioning dual controls." The sUAS System 

ground-based control station consists of a small hand-held radio transmitter and while it 

does not offer a second set of "controls", both the student and instructor can, and will, 

operate the single set of controls simultaneously. With both student and instructor having 

"hands-on" the controls during flight, we feel that this technique meets the intent 91.109 

and provides an equivalent level of safety.
14 CFR 91.119 Minimum safe altitudes: General.

The regulation states that over sparsely populated areas the aircraft cannot be operated 

closer than 500 feet to any person, vessel, vehicle, or structure. Since the typical mission 

of the sUAS would be photography or survey of persons, vessels, vehicles or structures 

it would be necessary to operate closer than 500 feet to the items listed. Operations will 

only be flown over property or persons where permission has been obtained and careful 

pre-planned has been performed. The aircraft will be operated at a low altitude allowing, 

if a power unit fails, an emergency landing without undue hazard to persons or property 

on the surface. Therefore we maintain that due to the small size of the UAS, the hazard 

to persons, vehicles and structures is minimal compared to umanned aircraft, which 

should be considered in granting the exemption.

14 CFR 91.121 Altimeter settings.

The regulation requires that aircraft shall maintain cruising altitudes by reference to an 

altimeter setting available within 100 NM of the aircraft. The sUAS will always fly below 

600 feet AGL and will not need to maintain cruising altitudes in order to prevent conflict 

with other aircraft. An Above Ground Level altimeter measurement above the takeoff point 

is transmitted via radio from the sUAS on-board computer to the display screen held by 

the PIC, providing a constantly updated AGL readout.

14 CFR 91.151 Fuel requirements for flight in VFR conditions.

The regulation provides that no person may begin a flight in an airplane under day-VFR 

conditions unless there is enough fuel to fly to the first point of intended landing and to fly 

after that for at least 30 minutes. We feel the intention of this paragraph is to provide an 

energy reserve as a safety buffer for delays to landing. The sUAS are battery operated 

and the maximum duration of flight from a single battery charge is 12-45 (depending on 

which sUAS) minutes with a 20% reserve. Since the aircraft will never fly more than 1/2 

NM from the point of intended landing, a full battery charge at launch will ensure that we 

meet the reserve energy requirement of this paragraph. We request an exemption to the 

word "fuel" and ask for an equivalent interpretation with the word "energy". We also

request exemption from the 30 min reserve and ask that our reserve will be to fly the 

mission to the point of intended landing and have at least a 20% battery reserve after 

that.

14 CFR 91.203(a) & (b) Civil aircraft: Certifications required.

The regulation provides that an airworthiness certificate, with the registration number 

assigned to the aircraft and a registration certificate must be aboard the aircraft. 

Additionally, subparagraph (b) provides that the airworthiness certificate be "displayed at 

the cabin or cockpit entrance so that it is legible to passengers or crew." With our largest 

vehicle, the RF-70, at a maximum gross weight of 13 pounds, the sUAS is too small to 

carry documentation, does not have an entrance, and is not capable of carrying 

passengers or crew. To obtain an equivalent level of safety and meet the intent of 91.203,
we propose that documents deemed appropriate for this aircraft by the FAA will be 

collocated with the crew at the ground control station and available for inspection upon 

request. In order to identify the aircraft, we propose that the information found on 

airworthiness and registration certificates be permanently affixed to the aircraft via placard 

containing the following information plus the word "EXPERIMENTAL" to satisfy the 

requirement of 14 CFR 45.23.

14 CFR Subpart E (91.401- 91.417)- Maintenance, Preventive Maintenance, 

Alterations.

The regulation provides that the operator is primarily responsible for maintaining the 

aircraft in an airworthy condition, including compliance with part 39 and 43. Paragraphs 

91.407 and 91.409 require that the aircraft be "approved for return to service by a person 

authorized under 43.7" after maintenance and inspection. It is our intention that the PIC 

perform maintenance and inspection of the aircraft and "be authorized to approve the 

aircraft for return to service." The PIC will ensure that the aircraft is in an airworthy 

condition prior to every flight and in addition, conduct detailed inspections after every two 

hours of flight. Maintenance performed by the PIC is limited to repairing small cracks, 

replacing a propeller, checking electrical connections and updating software and firmware 

for the on-board computer. All other maintenance will be performed by the manufacturer 

or their designated repair facility. The PIC will document work performed in accordance 

with 91.417. We feel that due to the size, construction, and simplicity of the aircraft, the 

PIC can ensure an equivalent level of safety.