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U.S. Department of Transportation 

Docket Management System 

1200 New Jersey Ave. SE 

Washington, DC 20590

January 21, 2016

Dear Sir/Madam, 

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

and 14 C.F.R. Part 11, 327 UAV Survey Consulting LLC.( referred to as 327 USC ) operating 

and providing a service with the use of Small Unmanned Aircraft System (sUAS) equipped to 

conduct aerial photography and videography surveys 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. of 14 C.F.R §§ 61.113(a) & (b), 91.7(a), 

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

operation of sUAS commercially in airspace regulated by the 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. This exemption will permit 327 UAV SURVEY CONSULTING LLC. 

to operate its various Unmanned Aircraft Vehicles (“UAV”) aerial video and photography

inspections of electrical infrastructure, precision agricultural, storm restoration projects, civil 

locations, real estate residential/commercial and inspections, construction and educational and 

training events, while keeping the documents required by the regulations at the ground control 

station and immediately accessible to the pilot in command. Furthermore, the exemption will 

relieve 327 UAV SURVEY CONSULTING LLC.,. from the airworthiness certificate standards 

and the requirement to have a certificate of airworthiness issued for its UAV. 
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This exemption will also permit any required markings concerning the operational status of its 

UAV to be displayed on the main section of the unmanned aircraft.

The requested exemption would permit 327 UAV Survey Consulting LLC to pursue its 

commercial interests in providing services to consumers interested aerial data capture using a 

sUAS in the following areas:

Electrical infrastructure, 

Storm restoration projects 

Precision agricultural 

Real estate residential/commercial 

Construction sites 

Pipeline inspections 

Educational and Training events 

Accident reconstruction 

327 USC, 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. Additionally, 327 USC pilots hold FAA Commercial and Private 

Pilot Licenses and valid driver’s license Medical Certificates and if observers are not qualified 

pilots, they will be trained by 327 USC 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.
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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)

327 USC, a survey and research company possesses over 10 years of electrical industry training

and knowledge. Providing an expertise to Central and Eastern States electrical utilities consisting 

of projects in: inventory and reliability inspections and recommendations to construction types 

providing details of equipment, structures. Logging all findings in digital spreadsheet which also 

includes photo documentation of utility assets. 327 USC, a participate in storm restoration

projects, safely conducting a survey of decimated circuits providing power to commercial and 

residential customers. 327 USC, with this exemption use of a sUAV a functional tool to be used 

in survey platform of aerial photography and videography. This would save time and monies 

toward safety of personnel, reliability and restoration efforts providing aerial view of damaged 

assets so power can be restored a few days or hours to the public. Conducting preventative 

maintenance aerial inspections with a UAV will be detrimental to the success of reliability issues

increasing compliance to 95%. Safety First Always the motto a 327 USC, always following safe 

protocols established by FMRA. During operations of preflight/ flight/ post operations.
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A. 327 USC, developed refined safety protocols to follow while operating a UAV in public 

air space providing a better understanding of the interpreted value of how the aircraft 

reacts to environmental variables. 

B. Safety Guidelines

Pre-Flight Safety Protocols

1. Check surroundings for Pedestrians, Commercial/Residential properties, vehicular, air and 

land traffic, obstructions, and environmental hazards.

2. Check-in with local authorities/agencies to inform them of operations in their area.

3. Check with visual observer to maintain communication and line of sight via voice.

4. Check geographical area of the designated flight path for active Airports and restricted or 

private airspace.

5. Always have onsite emergency plan and contacts available for any occurrence of abnormal 

operations.

6. Insure all involved in UAV field site adhere to safety protocols throughout full duration of 

flight mission.

327 USC, created a flight log containing information such as flight location, weather and 

environmental info, flight issues, statistics of all flight matrices from pre to post flight, and any 

findings on subject of inspection. 

327 USC, created a maintenance log spreadsheet that serves as a record of all changes to aircraft 

configuration or settings. Ex. - Changing out propellers, replacement of Electronic Speed 

Controllers (ESC’s), or any other issues that could affect flight safety for the aircraft or public

We are petitioning for exemption to enable 327 USC, to operate a DJI Inspire 1 Pro multi-rotor 

equipped with a three-axis gimbaled camera, Walkera Talia H500 a multi-rotor equipped with a 

three-axis gimbaled camera. The sUAS all weigh less than 10 lbs., have a built- in capability to 

limit the height it flies above the ground, to limit the radius of the distance it flies from the 

operator and to exclude it 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 when the 

communication between the Main Controller and the transmitter is lost, the system will 

automatically trigger Return to Home and will land safely.
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The previously mention 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 sites that are a 'sufficient distance' from populated areas within the sterile 

area described in the operator’s manual. Such operations will insure that the sUAS will 

"not create a hazard to users of the national airspace system or the public." 

 When flying sUAV 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 full-scale aircraft. 

 Maximum flight time for each operational flight will be 22 minutes. 

 Flights will be terminated at 25% battery power reserve should that occur prior to the 22-

minute limit. 

 The sUAV will be programmed so that it will not be operated at an altitude of no more 

than 400 feet AGL, and not more than 200 feet above an elevated platform from which 

filming is planned. 

 Minimum crew for each operation will consist of the sUAS Pilot and the Visual 

Observer. 

 The sUAS PIC's (Pilot in Command) will be an FAA licensed airman holding a FAA 

Private Pilot or Commercial Certificate and FAA Medical Certificate/ and or Valid 

driver’s license 

 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.

Additionally, the fact that the 327 USC operator hold FAA Pilot certificates demonstrates that 

they have a high regard to safe operations with an understanding of FARs, pre-flight inspections, 

maintenance and repair, operations within airspace, as well as being trained to high safety

standards. Under the requested exemption 327 USC 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, Notice To Airman (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. 
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We respectfully request exemption under Section 333 to enable 327 USC to operate safe, lowrisk commercial sUAV operations for the activities stated. 327 USC at all times will respect the 

space and privacy of citizens and property.

Similar exemptions have been granted to other operations, including Exemptions No. 11295, 

11472, 13944, 14347, 12853A, 14318, 12646

Thank you 

327 UAV Survey Consulting LLC. 

Jon C. Taliaferro 

CEO 

123 Millcreek Drive 

Dover, DE. 19904 

(302) 480-3185