April 16, 2015

 Exemption No. 11327

 Regulatory Docket No. FAA–2015–0018

Mr. Michael Harvey

Unmanned Aerial Assessment & Video LLC

5218 S Malaya Way

Centennial CO 80015

Dear Mr. Harvey:

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.

The Basis for Our Decision

By letter dated December 31, 2014, you petitioned the Federal Aviation Administration 

(FAA) on behalf of Unmanned Aerial Assessment & Video LLC (hereinafter petitioner or 

operator) for an exemption. The exemption would allow the petitioner to operate an 

unmanned aircraft system (UAS) to conduct search and rescue, Hazmat management

(Chemical, Biological, Radiation & Nuclear), and emergency and disaster response.

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 DJI Inspires and DJI Phantom 2s or DJI Phantom 2 

Visions.
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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 

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 collection. The FAA has issued grants of 

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

In Grants of Exemption No. 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, Unmanned Aerial Assessment & Video LLC 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.
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Conditions and Limitations

In this grant of exemption, Unmanned Aerial Assessment & Video LLC 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 Inspires and DJI 

Phantom 2s or DJI Phantom 2 Visions 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 
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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 FAApublished 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 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 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.
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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 (NNumber) 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.
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If this exemption permits 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.

This exemption terminates on April, 30, 2017, unless sooner superseded or rescinded.

Sincerely,

/s/

John S. Duncan

Director, Flight Standards Service
12/31/2014

Michael Harvey

Unmanned Aerial Assessment & Video LLC

5218 S Malaya Way, Centennial CO 80015

Hon. Michael Huerta 

Administrator 

Federal Aviation Administration 

U. S. Department of Transportation 

Docket Management System 

1200 New Jersey Ave., SE 

Washington, DC 20590

Re: Exemption Request under Section 333 of the FAA Reform Act and Part 11 of the Federal Aviation 

Regulations from certain parts of the FARs.

Dear Administrator Huerta: 

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the Reform Act) and 14 

C.F.R. Part 11, Unmanned Aerial Assessment & Video, LLC, a Colorado limited liability company, hereby 

applies for an exemption from the listed Federal Aviation Regulations (“FARs”) to allow it to operate a 

small Unmanned Aircraft System (“sUAS”) under the conditions and limitations set forth in this Petition.

The requested exemption would permit the operation of small, unmanned and relatively inexpensive 

sUAS under controlled conditions in airspace that (1) is limited, (2) is predetermined, and (3) would 

provide safety enhancements to First Responders on the front lines in our communities. Approval of this 

exemption would thereby enhance safety and fulfill the FAA Administrator’s responsibilities to 

“...establish requirements for the safe operation of such aircraft systems in the national airspace 

system.” Section 333(c) of the Reform Act. 

The name and address of the applicant is: 

Unmanned Aerial Assessment & Video, LLC 

Attn: Michael Harvey 

Telephone: (720) 243-2775 

Email: MichaelHarvey100@yahoo.com 

Address: 5218 S Malaya Way, Centennial CO. 80015
Regulations from which the exemption is requested: 

14 CFR Part 21 

14 C.F.R. § 45.23(b) 

14 CFR § 61.3 

14 C.F.R. § 91.7 (a) 

14 CFR § 91.9 (b) (2) 

14 C.F.R. § 91.103 

14 C.F.R. § 91.109 

14 C.F. R. § 91.119 

14 C.F.R. § 91.121 

14 CFR § 91.151 (a) 

14 CFR § 91.203 (a) & (b) 

14 CFR § 91.205(b) 

14 CFR § 91.215 

14 CFR § 91.405 (a) 

14 CFR § 407 (a) (1) 

14 CFR § 409 (a) (2) 

14 CFR § 417 (a) & (b) 3 

Appendix 1 describes the FARs from which an exemption is requested and summarizes the justification 

for each requested exemption. 

The Petition is submitted to fulfill Congress’ goal under Section 333(a) through (c) of the Reform Act, 

which 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 Administrator must determine 

which types of UASs 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 UAS’s size, weight, speed, and operational capability; 

• Operation of the UAS in close proximity to airports and populated areas; and 

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

Reform Act § 333 (a).

If the Administrator 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).

The Secretary has delegated his aviation authority to the Administrator of the FAA.

The Federal Aviation Act expressly grants the FAA the authority to grant exemptions from its regulatory 

requirements for civil aircraft, a term defined under §40101 of the Act, which includes sUASs. 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 the Federal Aviation Act if Administrator finds 

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

14 CFR §91.203 (a) (1).
The Petitioner is a startup company, Unmanned Aerial Assessment & Video, LLC, The founder of the 

company is a retired Military Veteran with training, both academically and militarily in Emergency 

Management. Prior to starting Unmanned Aerial Assessment & Video, LLC, the founder worked as an 

Emergency Manager in both the Civilian and Military Contractor venues. He is also a certified Hazmat 

Specialist with over 15 years of experience with CBRN, (Chemical, Biological, Radiation & Nuclear) 

activities. Additionally, the founder has a strong interest in UASs and has been recreationally flying them 

for approximately 2 years, amassing over 120 hours of flight time.

The Petitioner has formulated a business plan to provide Emergency Management assistance to Local, 

State and Federal entities. The plan is to use small drones for SAR (Search & Rescue), Hazmat/CBRN 

Management and Emergency & Disaster Response. When responding to an emergency, one of the 

priorities is to understand how the most critical areas are affected and where they are situated - before 

putting any more human lives in danger. The unmanned Drone platform puts the power of aerial 

intelligence directly into the hands of the first responders. Real-time video streaming can show not only 

the extent of the damage but may also warn responders of additional hazards. Geo-tagged digital 

photographs provide an aerial record of the on-ground situation completely untouched. It is very 

improbable for First Responders to acquire, stay trained up on and be on the leading edge of technology 

with regards to UASs due to turnover and other training requirements that take priority.

Under the plan, the Drones will be DJI Inspires, DJI Phantom 2s or DJI Phantom 2 Visions, flying below

400 feet above ground level and never within 5 miles from an airport. They will operate only within the 

line of sight of the operator and will only operate in populated areas for life and safety reasons and 

under the control of the on-scene Incident Commander. Flights will be remote from noise sensitive areas 

such as parks, schools, hospitals, and churches. Flights will be only conducted in permissible weather –

rain, snow, or winds above 12 mph will terminate the flights. The Drones will only be operated by the 

Petitioner who has considerable experience flying UA Drones. Prior to operating the drones all pre-flight 

checks will be conducted as per the Petitioners SOP (Standard Operating Procedures). Safety will be the 

paramount concern in defining flight profiles. 

I am aware that this business plan is only permissible if it obtains special permission from the FAA. Many 

potential competitors of Petitioner are actively flying sUAS, notwithstanding the FAA’s stated 

prohibition. Petitioner also notes and has read the congressional mandate in sections 332 and 333 of the 

FAA Revitalization and Reform Act of 2012 that the FAA move quickly to accommodate the economic 

and societal benefits that can result from widespread deployment of sUAS technology. Accordingly, 

Petitioner applies for authorization under the Federal Aviation Act and the FARs to undertake the 

following activities for commercial purposes. Unless the Petition is granted, Petitioner will be at a 

significant competitive advantage if it, as it prefers, complies with FAA policy. 

Vehicle 

The Petitioner will fly one or more DJI Phantom 2s, DJI Phantom 2 Visions equipped with a three-axis 

gimbal and camera, small oxygen and radiation sensors and eventually a thermal FLIR for better 

situational awareness during SAR and Wild land Fire mapping missions. 

These vehicles have the built in capability to limit the height they fly above the ground, to limit the 

radius of the distance they fly from the operator, and to exclude them from class B, C, and D airspace as 

well any TFR’s (Temporary Flight Restricted) areas. The vehicles also have the built-in capability to return 

to the launching point if the wireless control link is interrupted or if the operator attempts to exceed any 

of the height, radius, or airspace limitations programmed into them.
The vehicle weighs about five pounds and has a maximum gross weight of approximately twenty 

pounds. It has a top speed of about 30 knots. It has four fixed-pitch rotors, thrust from which is varied by 

changing RPM. It is powered by a lithium polymer smart battery.

Flight profiles 

The petitioner will program the Phantom so that it will not fly more than 400 feet above ground level, or 

more than 1500 feet away from its operator. The PIC (Person in Control) will carefully preflight the 

vehicle before each mission to assure that its compass and GPS system are properly calibrated and that 

the return-to-home feature, altitude, and radius limitations work. 

It will not operate in controlled airspace. In the unlikely event that a manned aircraft flies below 400 

feet AGL where the Petitioner is operating its Phantom, the operator will keep both the vehicle and 

manned aircraft in sight and avoid the manned aircraft. 

More particularly, the Petitioner will fly the Phantom only over the hazard areas that are in control of an 

on-scene Incident Commander, most likely being a Fire Chief, SAR rep or Police rep, etc.

Public interest 

Granting the petition would be in the public interest because: 

1. The Congress of the United States has determined that early accommodation of sUAS into the 

National Airspace System advances the public interest. The Committee Report leading the House to 

adopt H.R. 658 said: 

"The successful integration of unmanned aircraft systems (UAS) into the National Airspace System (NAS) 

can support more than 23,000 high-paying jobs in the United States. . . . The absence of a plan to 

integrate UASs into the NAS is a barrier to such job creation . . . ."1

Granting the Petition represents a step toward such integration, in the absence of a comprehensive 

regulatory regime for sUAS, and thus would serve the Congressional goal and the public interest. 

2. Granting the Petition will facilitate a new era in Emergency Response activities, one in which the 

responders themselves have a tool to safely, quickly and remotely assess a situation without placing 

lives in harm’s way. In comparison, the EOD robots have saved countless lives since their inception, a 

feat that will become common place for aerial assessments.

3. Granting the Petition will enable Petitioner to demonstrate the commercial viability of creating new 

safety techniques and tactics with new aeronautical technology, thereby improving the efficiency of 

Emergency Responders around the world and making for a safer society. 

The rules from which Petitioner seeks exemption artificially and irrationally limit the effective use of 

new technologies to expand Emergency Response safety and improve the efficiency of markets, thereby 

subverting the public interest. 

_____________________________________________

1. H. R. Rep. 112-29 on H.R. 658, 112th Cong., 1st Sess. at 116. The House-Senate Conference Committee on the FAA Modernization and 

Reform Act of 2012 recommended amendments to H.R. 658 in lieu of amendments adopted by the Senate. Conference Report to Accompany 

H.R. 658, H.R. Rep. 112-381, 112th Cong., 2d Sess., at p. 1 (Feb. 1, 2012). 
4. Granting the Petition will enable the Petitioner to demonstrate that Wounded War Veterans, as I am,

can still thrive and be a part of the business community, regardless of any setbacks they may endure. 

This alone is in keeping with the Presidents stated ideology as well as the Veterans Administrations 

vision and in the public’s interest.

5. Granting the Petition will fulfill the FAA’s own declaration that encouraging new aviation technologies 

advances the public interest. The FAA itself has recognized the public interest in its role of "Encouraging 

and developing civil aeronautics, including new aviation technology."2 Granting the Petition will 

enhance FAA fulfillment of that commitment, thereby serving the public interest. Air commerce 

flourishes in the United States because of the rapid pace of innovation in aeronautical and associated 

technologies, followed by their commercialization and their introduction into the marketplace. The 

drone technology that the Petitioner uses exemplifies the latest innovative leap forward in aeronautical 

technology. Preventing it from using this in air commerce subverts achievement of the goal. 

6. Granting the Petition will fulfill the Congressional determination that integrating sUAS technology into 

the NAS serves the public interest. Section 330 of the FAA Modernization and Reform Act of 2012, 

specifically recognizes the advantages to air commerce obtainable from the deployment of sUAS 

technologies. It mandated several steps by the FAA to accelerate the availability of these technologies in 

the National Airspace System, thereby representing a congressional determination that the public 

interest is served by making these technologies more widely available at the earliest practicable date. 

The Petition represents a way for the FAA to move incrementally, while still satisfying its congressional 

mandate and meeting its obligation to enhance the public interest by making new technologies available 

by allowing the use of sUAS technologies in a manner that protects the public and the rest of the 

aviation community from significant risk. 

The commercial activities by Petitioner proposed in the Petition represent contributions to new forms of 

air commerce, thereby fulfilling the FAA’s statutory mandate under the 2012 Act. 

7. Granting the Petition will enhance aviation safety, thereby advancing the public interest. The 

Petitioner has committed itself in the Petition to safety practices that reduce or eliminate hazards to 

aircraft in the National Airspace System and to persons and property on the ground. Many others are 

flying sUAS without regard to these hazards. Granting the Petition will offer the Petitioner up as an 

example of how the FAA is willing to accommodate the new technology when it is constrained by 

appropriate limitations to enhance safety. It will also allow the Petitioner to be a role model for safe 

commercial sUAS operations. 

Users of the National Airspace System are confronted by mushrooming threats from sUAS flown in 

defiance of the FAA’s ban. Unless the FAA shows some flexibility to accommodate lawful and safe 

operation of sUAS for legitimate commercial purposes, the level of defiance will increase, intensifying 

the hazards to manned aircraft and to persons and property on the ground.

The Petitioner's proposed operations satisfy the criteria provided in Section 333 of the Reform Act 

relating to size, weight, speed, operating capabilities, proximity to airports and populated areas and 

operation within visual line of sight, and national security. The Petition justifies grant of the requested 

exemptions to allow the Petitioner to engage in Emergency Response procedures using small Drones. 

_____________________________________________

2 FAA, Safety: The Foundation of Everything We Do, 

http://www.faa.gov/about/safety_efficiency/. 
Respectfully submitted, 

Michael Harvey

Unmanned Aerial Assessment & Video LLC 

Appendix 1
FAR section Subject Justification 

14 CFR § 45.23(b) Requirement to display 

registration number on vehicle 

Insufficient space on vehicle 

14 CFR Part 21 Aircraft certification 

requirements and procedures 

Designed for manned aircraft; 

not suitable for off-the-shelf 

sUAS 

14 CFR § 61.3 Requirement for pilot 

certificate 

Part 61 requirements designed 

for manned aircraft, not sUAS; 

petition describes training for 

sUAS operator 

14 CFR § 91.7 (a) Airworthiness requirement Designed for manned aircraft; 

not suitable for off-the-shelf 

sUAS 

14 CFR § 91.9 (b) (2) Requirement for manual to be 

available in the cockpit 

No one aboard to read manual 

14 CFR § 91.103(b) Requirement for crew 

members to be onboard 

Unmanned vehicle 

14 CFR § 91.109 Requirement for dual controls 

during flight instruction 

No one aboard to operate 

controls 

14 CFR § 91.119 Minimum altitudes for safe 

flight 

Safety requires operation 

below these altitudes 

14 CFR § 91.121 Altimeter settings No one aboard to read 

altimeter 

14 CFR § 91.151(a) Fuel requirements Vehicle does not use fuel 

14 CFR § 91.203 (a) & (b) Requirement for registration 

and airworthiness certificates 

to be onboard 

No one aboard to read 

certificates 

14 CFR § 91.205(b) Cockpit instruments No one aboard to read 

FAR section Subject Justification 

14 CFR § 45.23(b) Requirement to display 

registration number on vehicle 

Insufficient space on vehicle 

14 CFR Part 21 Aircraft certification 

requirements and procedures 

Designed for manned aircraft; 

not suitable for off-the-shelf 

sUAS 

14 CFR § 61.3 Requirement for pilot 

certificate 

Part 61 requirements designed 

for manned aircraft, not sUAS; 

petition describes training for 

sUAS operator 

14 CFR § 91.7 (a) Airworthiness requirement Designed for manned aircraft; 

not suitable for off-the-shelf 

sUAS 
14 CFR § 91.9 (b) (2) Requirement for manual to be 

available in the cockpit 

No one aboard to read manual 

14 CFR § 91.103(b) Requirement for crew 

members to be onboard 

Unmanned vehicle 

14 CFR § 91.109 Requirement for dual controls 

during flight instruction 

No one aboard to operate 

controls 

14 CFR § 91.119 Minimum altitudes for safe 

flight 

Safety requires operation 

below these altitudes 

14 CFR § 91.121 Altimeter settings No one aboard to read 

altimeter 

14 CFR § 91.151(a) Fuel requirements Vehicle does not use fuel 

14 CFR § 91.203 (a) & (b) Requirement for registration 

and airworthiness certificates 

to be onboard 

No one aboard to read 

certificates 

14 CFR § 91.205(b) Cockpit instruments No one aboard to read