Industrial Networks LLC.

www.inetlp.com

281-419-0796

October 22, 15

U.S. Department of Transportation

Docket Management System

1200 New Jersey Ave., SE

Washington, DC 20590

Re: Exemption Request Under Section333 of the FAA Reform Act and Part 11 of the Federal 

Aviation Regulations

Dear Sir or Madam:

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

14 CFR Part 11, Industrial Networks LLC” (“INET”), the developer and operator of the INDF1 small

Unmanned Aircraft Systems (“sUAS”) seeks an exemption from the Federal Aviation Regulations 

(“FARs”) listed below and discussed in Appendix A. Details of INDF1 sUAS are described in 

Appendix B. [Attached as Appendix C is a summary of this request.]

The requested exemption would permit INET commercial operation of INDF1 (see details in 

Appendix B), in the RAILCAR INVENTORY AND INSPECTION market space. The Air Vehicle weighs 

22 lbs. with imaging payload, to perform market research, aerial surveys, mapping, and inspections 

that consist of still photographs, video, and other data taken by onboard sensors. The INDF1

produces high quality imagery and data that can be used independently - or in the case of surveying 

and thermal modeling, can be combined to produce precision charts, and contour maps. 

Applications for this sUAS include the location and inspection of railcars using video and RFID 

scanning technology. Use of the INDF1 for location and inspection of railcars using video and RFID 

scanning enhances rail shipment and receiving operations, providing data more quickly, accurately, 

economically, safely, and with reduced environmental impact.

Operations under the exemption will be subject to strict operating requirements and conditions to 

ensure at least an equivalent level of safety to currently authorized operations using manned 

aircraft and under conditions as may be modified by the FAA as required by Section 333. 

While INET is filing this exemption request on its own behalf, it anticipates that its customers, in the 

future, will file exemption applications to allow them to operate the INDF1 in commercial 

operations at their client’s facilities and other sites that require low aerial data for inspections and 

railcar inventory surveys. Wherever possible, those filings will be substantially similar to this 

exemption application.

As described more fully below, the requested exemption would authorize INET to perform market 

research and commercial operations of aerial inspections and surveys using the INDF1, which at 22

lbs. is small in size and powered electrically by a Li-Po battery. 

The INDF1 will be operated under controlled conditions at low altitude (<500’ AGL) in Class G 

airspace that is limited in scope, as described more fully herein. It will have automated control 
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features, as described below. The INDF1 is designed to be operated by one person but flight 

operations generally involve two people, an operator and an observer. The operator is responsible 

for flying the sUAS, monitoring its status and flight dynamics while maintaining visual-line-of-sight 

(VLOS), and keeping the flight within the specified factory limits (in terms of wind, flight range, 

battery life, etc.) to ensure safe operation of the sUAS itself. The observer is responsible for 

monitoring the airspace for other aircraft and hazards and instructing the operator before and 

during flight as necessary to ensure safe launching and deconfliction with ANY aircraft or identified 

hazards. The operator also will be an individual who has passed the FAA approved or military 

equivalent ground training exam and authorized DJI training program for the INDF1. Finally, the 

airspace in which the INDF1 will operate will be disclosed to and approved, as needed, by the FAA 

in advance.

INET respectfully submits that because this small, unmanned aerial system – the INDF1 – will be 

used at above ground altitudes less than fifty (50) feet, the FAA can have confidence that the 

operations will achieve at least an equivalent-level or greater, of safety. Approval of this exemption 

would thereby enhance safety and fulfill the Secretary of Transportation’s (the FAA 

Administrator’s) responsibilities under Section 333(c) of the Reform Act to “establish requirements 

for the safe operation of such aircraft systems in the national airspace system.”

The name and address of the applicant are:

Industrial Networks LLC

Attn: Ryan Bradley, Director of Operations

240 Spring Hill Drive

Suite 400

Spring, TX 77386

Phone 281-419-0796

The primary contact for this application is:

Ryan Bradley

rbradley@inetlp.com

The regulations from which the exemption is requested are as follows:

14 CFR 21;

14 CFR 45.23(b);

14 CFR 61.113(a) & (b);

14 CFR 61.133(a);

14 CFR 91.7(a);

14 CFR 91.9(b)(2) & (c);

14 CFR 91.103; 

14 CFR 91.109(a);

14 CFR 91.119;

14 CFR 91.151(a);

14 CFR 91.203(a) & (b);

14 CFR 91.405(a);

14 CFR 91.407(a)(1);

14 CFR 91.409(a)(2);

14 CFR 91.417(a)
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Appendix A discusses each rule listed above and explains why exemptions pursuant to the proposal 

set forth in this letter are appropriate, provide an equivalent level of safety, and are in the public 

interest. 

THE APPLICABLE LEGAL STANDARD UNDER SECTION 333

INET submits that grant of this exemption application for use of the INDF1 in location and 

inspection of railcars using video and RFID scanning technology will advance the Congressional 

mandate in Section 333 of the Reform Act to accelerate the introduction of sUAS’s into the national 

airspace system (“NAS”) if it can be accomplished safely. This law directs the Secretary of

Transportation to consider whether certain sUAS’s may operate safely in the NAS before

completion of the rulemaking required under Section 332 of the Reform Act. In making this 

determination, the Secretary is required to determine which types of sUAS’s 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 sUAS’s size, weight, speed, and operational capability;

 Operation of the sUAS in close proximity to airports and populated areas; and

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

Reform Act § 333(a)(1). If the Secretary determines that such vehicles “may operate safely in the 

National Airspace System, the Secretary shall establish requirements for the safe operation of such 

aircraft in the national airspace system.” Id. §333(c).

The Federal Aviation Act expressly grants the FAA the authority to issue exemptions. This statutory 

authority, by its terms, includes exempting civil aircraft, as the term is defined under §40101 of the 

Act, from the requirement that all civil aircraft must have a current airworthiness certificate and

those regulations requiring commercial pilots to operate aircraft in commercial service:

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

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

Administrator finds the exemption is in the public interest.

49 USC §44701(f). See also 49 USC §44711(a); 49 USC §44704; 14 CFR §91.203(a)(1).

The grant of the requested exemption is in the public interest based on the clear direction in

Section 333 of the Reform Act; the additional authority in the Federal Aviation Act, as amended; the 

strong equivalent level of safety surrounding the proposed operations; and the significant public

benefit, including enhanced safety and cost savings associated with transitioning to sUASs for aerial 

surveying, mapping and inspection applications. Accordingly, the applicant respectfully requests 

that the FAA grant the requested exemption without delay.

Airworthiness of the INDF1

A critical element of the exemption application involves evidence of the airworthiness of INDF1

sUAS and the Operators. INET believes that it has shown compliance through a history of 70 hours 

and 15 flights of safe operation of INDF1.
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The criteria set forth in the Order specify the substantive showings of the device’s safety and fitness

for operation to ensure that the FAA has sufficient basis to evaluate the aircraft’s safety. The INDF1

also has a significant set of automated features to ensure safe takeoff, flight and landing in many 

conditions, further details of operation can be found in Appendix B. 

Mandatory Operating Conditions

Grant of the exemption to INET will be subject to the following mandatory conditions, which are 

based upon operating conditions set forth for operation of sUAS by public entities pursuant to 

Certificates of Authorization, with additional restrictions:

 All operations to occur in Class G airspace.

 Operations to avoid congested or populated areas, which are depicted in yellow on VFR 

charts.

 Operations to be conducted over private or controlled-access property.

 Permission from land owner/controller required before commencing any flight.

 Operations to occur during Visual Flight Rules Meteorological Conditions (VMC).

 Aircraft to remain within Visual Line of Sight (VLOS).

 VLOS guaranteed with a cylinder of operation around operator of 1⁄2 nautical miles (NM).

 Observer may expand cylinder walls with ability to control aircraft.

 Operations to occur during daylight hours.

 Above Ground Level (AGL) altitude to be restricted to 200 feet.

 All operations conducted in vicinity of airport to remain more than 2.5 NM from 

centerline azimuth of runway centerline measured from runway thresholds.

 Operator will file a NOTAM for each flight.

 All required permissions and permits would be obtained from territorial, state, county or

city jurisdictions, including local law enforcement, fire, or other appropriate governmental 

agencies.

Operator Requirements

INET respectfully proposes that operator requirements should take into account the characteristics 

of the particular sUAS. Certain sUASs, such as the INDF1, are characterized by a high degree of 

pre-programmed control and various built-in technical capabilities that limit the potential for 

operation outside of the operating conditions set forth above. The INDF1 sUAS also provides many 

built-in functional and safety features to assist the operator in safe and reliable operation.

The INDF1 provides two semi-autonomous flight modes using a point-and-click map and video

interface.

The user clicks on a map to direct the INDF1 to fly to the point on the map where the operator is 

pointing, or programmed flight plans may be entered for a series of waypoints or grid based area.

Additional navigation aids including landing zones and flight areas may be designated to ensure the

INDF1 operates only within user specified flight parameters. All flight operations are GPS

controlled making the system easy to navigate, and the flight control system also employs a variety 

of sensors including; barometric pressure, temperature, wind speed and others to ensure the high
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stability and reliability in challenging weather conditions. At all times during flight operations, the 

operator can intervene a programmed flight and take immediate control.

Additional automated safety functions and safety enhancing features of the INDF1 include the 

following:

 - Automated pre-flight system performance checks 

 - User pre-flight checklist 

 - Automated condition or fault detection, warnings, and pre-defined responses to a number of

flight and system conditions.

 - High winds with system and user defined safety thresholds 

 - Low battery with system and user defined safety thresholds 

 - High temperature or other system safety thresholds 

 - Lost-link communication

 - Pre-defined responses include behavior such as attempting to re-establish radio 

communication, return to home position and hover, return to home position and land, or land in 

current position

 - In the case of lost GPS, a manual user flight mode is enabled which allows the operator to provide 

manual navigation inputs to assist in landing the vehicle.

Given these safety features, INDF1 proposes that operators of the INDF1 should not be required to 

hold a commercial or private pilot certification. Instead, operators should be required to:

- have successfully completed, at a minimum, FAA private pilot ground instruction and passed the

FAA Private Pilot written examination or FAA-recognized equivalents including commercial or 

private license and ground school issued from an ICAO recognized country;

- have completed DJI authorized training program for operation and maintenance of the sUAS.

INET notes that the FAA has found that safety factors permitted operation of sUASs by operators 

with these qualifications in the case of operations pursuant to public COAs when the mandatory

operating conditions specified above were present. See Federal Aviation Administration, Notice 

N-8900.227 [FAA ORDER 8900.1, VOL 16], Unmanned Aircraft Systems (UAS) Operational

Approval, at 20-21 (July 30, 2013). The FAA has the statutory authority to grant exemptions to the

requirements for and privileges associated with the grant of airmen’s certificates. 49 USC §44701 

(f).

In summary, applicant seeks an exemption from the FARs set forth above and in Appendix C to 

allow market research and commercial operations of a small unmanned vehicle in surveying,

mapping and inspection operations.

Approval of the exemption allowing commercial operations of the INDF1 for location and 

inspection of railcars using video and RFID scanning technology will enhance safety by reducing 

risk. Conventional aerial survey and inspection operations using manned aircraft involve very 

heavy aerial vehicles carrying significant quantities of combustible fuels, and a multi-person crew 

in piloting and observation roles. These operations require transit to and from the location of the 

activity, and often take place in congested environments and include close proximity to physical 

obstacles and/or presence of the general public. By contrast, the INDF1 weighs 22 lbs including 

payloads and uses a battery for power, is transported or carried to/from the area of activity, 
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removes the need for airborne pilots/observers, and poses less risk to people and infrastructure on 

the ground.

Additionally, no national security issue is raised by the grant of the requested exemptions. Given 

the size, load carrying capacity, speed at which it operates, and the fact that it carries no explosives 

or other dangerous materials, the INDF1 poses no threat to national security.

The operation of the INDF1 for location and inspection of railcars using video and RFID scanning 

technology in accordance with the strict conditions outlined above, will provide an equivalent level 

of safety supporting the grant of the exemptions requested herein, including exempting INET from

the requirements of Part 21.

The INDF1’s satisfaction of the criteria set forth in Section 333 of the Reform Act (i.e. size, weight, 

speed, operating capabilities, operation within VLOS and lack of proximity to airports, populated or 

areas national security) and demonstrated equivalent level of safety as it relates to the requirement

for FAA pilot certification, provide more than adequate justification for the grant of the requested 

exemptions allowing INET commercial operation of the INDF1 in location and inspection of railcars 

using video and RFID scanning technology. 

In conclusion, the safe operation of the INDF1 is of utmost concern and safety remains paramount. 

INET intends to operate within the spirit of all applicable FAA regulations and will adhere to any 

further refinements. The operation of INET’s sUAS’s in railyards across the country are literally of 

little safety concern, provided the operators and observers maintain integrity of the flight, pose no 

risk to airborne platforms, and/or mitigate all risk to ground personnel and property. 

Very truly yours, 

 

Ryan Bradley

Industrial Networks LLC
Industrial Networks LLC.

www.inetlp.com

281-419-0796

APPENDIX A

EXEMPTION REQUEST AND EQUIVALENT LEVEL OF SAFETY SHOWINGS UNDER APPLICABLE 

RULES SUBJECT TO EXEMPTION

INET requests an exemption from the following regulations as well as any additional regulations 

that may technically apply to the operation of the INDF1:

14 CFR Part 21, Subpart H: Airworthiness Certificates

14 CFR § 91.203(a)(1)

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 (22 lbs.)

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 sUAS involved.

In this case, an analysis of these criteria demonstrates that the INDF1 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 INDF1

weighs 22 lbs. fully loaded. It will not carry a pilot or passenger, will not carry flammable fuel, and 

will operate exclusively within an area pre-disclosed 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 filing of NOTAMs. Receipt of the prior 

permission of the land owner, 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 INDF1 provides at least an equivalent, and most likely exceeds5, level of safety to that of such 

operations being conducted with conventional manned aircraft that would be significantly larger 

and would be carrying additional personnel, cargo, and flammable fuel. The automated safety 

features including redundant sensor systems as described in Appendix B and throughout this 

document highlight the design intentions towards safety and reliability on the INDF1.

14 CFR § 45.23 & 91.9(c): Marking of the Aircraft

Regulation 45.23 provides:

(a) Each operator of an aircraft must display on that aircraft marks consisting of the 
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Roman capital letter “N” (denoting United States registration) followed by the registration 

number of the aircraft. Each suffix letter used in the marks displayed must also be a Roman 

capital letter.

 (b) When marks include only the Roman capital letter “N” and the registration number is 

displayed on limited, restricted or light-sport category aircraft or experimental or 

provisionally certificated aircraft, the operator must also display on that aircraft near each

entrance to the cabin, cockpit, or pilot station, in letters not less than 2 inches nor more than 

6 inches high, the words “limited,” “restricted,” “light­sport,” “experimental,” 

or“provisional,” as applicable.

 

Regulation 91.9(c) provides: 

 No person may operate a U.S.-registered civil aircraft unless that aircraft is identified in 

accordance with part 45 of this chapter. 

The INDF1 has no entrance to the cabin, cockpit, or pilot station on which the markings can be 

placed. Given the size of the sUAS, two inch lettering will be impossible. Official marking systems for 

small UAS have not yet been established for operations inside the NAS. The INDF1 is currently 

marked with a fixed label containing INDF1 measuring 1” x 0.5” as well as a serial number located

between M3 and M4 on the power distribution board. INET is prepared to mark the inspection 

system with the name of the organization and location or origin and fulfill any other request by the

FAA to this topic in accordance to § 45.29(f) where the pilot, observer, and others working with the

sUAS will see the identification of the sUAS.

The FAA has issued the following exemptions to this regulation; see Exemption Nos. 8738, 10167, 

10167A and 10700.

14 CFR § 61.113(a) & (b); 61.133(a): Private Pilot Privileges and Limitations; Pilot in 

Command; Commercial Pilot Privileges and Limitations.

Section 61.113(a) & (b) limit private pilots to non-commercial operations. Unlike a conventional 

aircraft that carries a pilot, passengers, and cargo, the INDF1 in this case is remotely controlled with

no passengers or property of others on board. Section 61.133(a) requires an individual with a 

commercial pilot’s license to be pilot in command of an aircraft for compensation or hire. INET

respectfully proposes that operator requirements should take into account the characteristics of

the particular sUAS. INET’s INDF1 has a high degree of pre-programmed control and various 

built-in technical capabilities that strictly limit the potential for operation outside of the operating 

conditions set forth in the exemption application.

The INDF1 has an all-digital software platform with advanced features previously restricted to full 

size unmanned aircraft. Automated features and advanced fly-safe controls enable safe, reliable 

operation, as well as advanced networking capabilities and system extensibility.

 Plan your flight or fly ad-hoc: The system can autonomously fly a programmed flight path or 

fly in manual mode 

 Smart batteries and charger: Flight time and battery minutes are displayed at all times. The 

system will return home and land automatically if user-configurable limits are reached. 
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Flight safety is a priority, no matter the operating environment or project. The INDF1 offers 

superior safety over manned aircraft by removing the need for people to be onboard in potentially 

dangerous situations. With multiple built-in safety features, the INDF1 platform leads other sUAS 

with respect to safety. 

 Intelligent fault handling: The system automatically detects potential issues - with 

configurable automated response behavior such as a return-home-and-land routine 

 Automatic pre-flight checks: The system self-calibrates all of its sensors and performs 

self-tests prior to takeoff to check for errors 

 No-fly zones: The system has the ability to set up visual no-fly zones 

 Self-monitoring: Monitoring battery levels, in-flight wind speeds, and other system and 

 Environmental conditions are automatically handled by the system 

 Battery communication: Battery minutes and flight time are displayed at all times.The

system will return home and land automatically if user-configurable limits are reached. 

Additional automated safety functions and safety enhancing features of the INDF1 include the 

following:

 Auto detection of lost GPS warns the pilot and initiates an immediate landing.

 Low battery on the INDF1 triggers a Non-Fatal Warning alarm to return home, land and

replace the battery.

 Very low battery on the INDF1 triggers a Fatal Error alarm and initiates an emergency highspeed descent landing. 

 If the INDF1 detects a lost-link to the base station the vehicle will perform its pre-defined 

Non-Fatal Condition Response. 

Given these safety features, INET proposes that operators of the INDF1 should not be required to 

hold a commercial or private pilot certification. Instead, operators should be required to:

 have successfully completed, at a minimum, FAA private pilot ground instruction and

passed the FAA Private Pilot written examination or FAA-recognized equivalents including 

ICAO issued commercial, private license and ground school;

 have completed DJI training program for operation of the sUAS.

INET notes that the FAA has found that safety factors permitted operation of sUASs by operators 

with these qualifications in the case of operations pursuant to public COAs where the mandatory

operating conditions specified above are present. See Federal Aviation Administration, Notice 

N-8900.227 [FAA ORDER 8900.1, VOL 16], Unmanned Aircraft Systems (UAS) Operational

Approval, at 20-21 (July 30, 2013). The FAA has the statutory authority, granted at 49 USC

§44701(f) to waive the pilot requirements for commercial operations.

Given these conditions and restrictions, an equivalent level of safety will be provided by allowing 

operation of the INDF1 without a private pilot’s certificate or a commercial pilot’s certificate, under 

the conditions set forth herein.

The risks associated with the operation of the INDF1 (given its size, speed, operational capabilities,

and lack of combustible fuel) are so diminished from the level of risk associated with private pilot

operations or commercial operations contemplated by Part 61 with conventional aircraft (fixed

wing or rotorcraft), that allowing operations of the sUAS as set forth above meets or exceeds the 
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present level of safety provided under 14 CFR § 61.113(a) & (b) and does not rise to the level of

requiring a commercial pilot to operate the aircraft under § 61.133(a).

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

This regulation requires that no person may operate a civil aircraft unless it is in airworthy 

condition. Should the exemption be granted allowing commercial operation of the INDF1 without

an airworthiness certificate, no standard will exist for airworthiness of the INDF1. Given the size of 

the aircraft and the previous COAs issued for INDF1 an equivalent level of safety will be achieved by 

ensuring compliance with the OEM manuals prior to each flight. 

14 CFR § 91.9(b)(2): Civil Aircraft Flight Manual in the Aircraft.

The regulation provides:

 No person may operate a U.S.­registered civil aircraft ...

(2) For which an Airplane or Rotorcraft Flight Manual is not required by §21.5 of this chapter,

unless there is available in the aircraft a current approved airplane or Rotorcraft 

Flight Manual, approved manual material, markings, and placards, or any combination thereof. 

Given the size and configuration of the INDF1, it has no ability or place to carry such a flight manual

on the aircraft, not only because there is no pilot on board, but because there is no room or capacity 

to carry such an item on the aircraft.

The equivalent level of safety will be achieved by keeping the flight manual (see, e.g., User Guide, 

Exhibit 1) at the ground control point where the pilot flying the sUAS will have immediate access to

it. The FAA has issued to others the following exemptions to this regulation: Exemption Nos. 8607, 

8737, 8738, 9299, 9299A, 9565, 9565B, 10167, 10167A, 10602, 32827, and 10700.

14 CFR § 91.103: Preflight action

This regulation requires each pilot in command to take certain actions before flight to insure the 

safety of flight. As FAA approved rotorcraft flight manuals will not be provided for the aircraft an 

exemption will be needed. An equivalent level of safety will be provided as set forth in the INDF1

User Manual (exhibit 1) under the ‘Getting Ready to Fly’ section. The PIC will take all actions

including reviewing weather, flight battery requirements, landing and takeoff distances and aircraft

performance data before initiation of flight.

14 CFR § 91.109(a) & 91.319(a)(1): Flight Instruction

These regulations provide that no person may operate a civil aircraft (except a manned free

balloon) that is being used for flight instruction unless that aircraft has fully functioning dual 

controls.

The INDF1 is a remotely piloted aircraft and by design, does not have fully functional dual controls. 

Flight control is accomplished through the use of a control box that communicates with the aircraft 

via radio communications. The flight plan is either manually controlled through point-and-click 
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touchscreen navigation or pre-programmed as waypoints or an AutoGrid into the auto pilot before

or during flight and only in unusual circumstances will the pilot input control functions to alter the

pre-programmed flight. If instruction is accomplished through a training program, as set forth in

Exhibit 2, an equivalent level of safety will be assured. The FAA has approved exemptions for flight

training without fully functional dual controls for a number of aircraft and for flight instruction in

experimental aircraft. See Exemption Nos. 5778K & 9862A. The equivalent level of safety will be

achieved by the manufacturer providing the training as outlined and through the use of

experienced and qualified pilots familiar with the INDF1.

14 CFR § 91.119: Minimum Safe Altitudes

Section 91.119 establishes safe altitudes for operation of civil aircraft. Specifically, 91.119(c) limits 

aircraft flying over areas other than congested areas to an altitude of 500 feet above the surface, 

except over open water or sparsely populated areas. In those cases, the aircraft may not be 

operated closer than 500 feet to any person, vessel, vehicle, or structure.

As set forth herein, the INDF1 will never operate at higher than 500 feet AGL. It will, however, be 

operated to avoid congested or populated areas that are depicted in yellow on VFR sectional charts. 

Because aerial survey, mapping and inspection work must be accomplished at relatively low 

altitudes and at altitudes less than 500 feet AGL, an exemption from Section 91.119(c) is needed.

The equivalent level of safety will be achieved given the size, weight, speed, and material with

which the INDF1 is built. Also, no flight will be taken without the permission of the land owner or

those who control the land. Because of the advance notice to the landowner, all affected individuals 

will be aware of the flights. Compared to aerial survey operations conducted with aircraft or

rotorcraft weighing far more than 10,000 lbs. and carrying flammable fuel, any risk associated with 

these operations will be far less than those currently allowed with conventional aircraft operating

at or below 500 feet AGL. Indeed, the low-altitude operations of the sUAS will maintain separation

between these sUAS operations and the operations of conventional aircraft that must comply with 

Section 91.119.

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

This regulation prohibits an individual from beginning “a flight in an airplane under VFR conditions 

unless (considering wind and forecast weather conditions) there is enough fuel to fly to the first 

point of intended landing and, assuming normal cruising speed – (1) During the day, to fly after that 

for at least 30 minutes; or (2) At night, to fly after that for at least 45 minutes.”

The INDF1 batteries provide approximately 50 minutes of powered flight. Without an exemption 

from § 14 CFR 91.151, the sUAS’s flights would be limited to approximately 20 minutes in length. 

Given the limitations on its proposed operations and the location of those proposed operations, a 

longer time frame for flight in daylight VFR conditions is reasonable.

INET believes that an exemption from 14 CFR § 91.151(a) is safe and within the scope of a prior 

exemption. See Exemption 10673 (allowing Lockheed Martin Corporation to operate without 

compliance with 91.151(a)). Operating the sUAS, without 30 minutes of reserve fuel does not 

engender the type of risks that Section 91.151(a) was meant to prevent given the size and speed at
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which the sUAS operates. The fact that it carries no pilot, passenger, or cargo also enhances its

safety. Additionally, limiting INDF1 flights to 20 minutes would greatly reduce their utility. In the 

unlikely event that the INDF1 should run out of fuel (battery power), it would simply land. Given its 

weight and construction material, the risks are less than contemplated by the current regulation.

INET believes that an equivalent level of safety can be achieved by maintaining 5 minutes of reserve 

fuel, which, allowing 15 minutes of flight time, would be more than adequate to return the sUAS to

its planned landing zone from anywhere in its operating area.

The FAA has granted similar exemptions to others, including Exemptions 2689F, 5745, 10673 and

10808.

14 CFR § 91.203 (a) & (b): Carrying Civil Aircraft Certification and Registration

This regulation provides as follows:

(a) ... no person may operate a civil aircraft unless it has ... an appropriate and current 

airworthiness certificate.

(b) No person may operate a civil aircraft unless the airworthiness certificate required by 

paragraph (a) of this section or a special flight authorization issued under §91.715 is displayed at 

the cabin or cockpit entrance so that it is legible to passengers or crew.

The INDF1 fully loaded weighs approximately 22 lbs. As such, there is no ability or place to carry 

certification and registration documents or to display them on the sUAS. In addition, there is no 

pilot on board the aircraft.

An equivalent level of safety will be achieved by keeping these documents at the ground control

point where the pilot flying the sUAS will have immediate access to them. The FAA has issued 

numerous exemptions to this regulation. A representative sample of other exceptions includes 

Exemption Nos. 9565, 9665, 9789, 9789A, 9797, 9797A, 9816A, and 10700.

14 CFR § 91.405(a); 407(a)(1); 409(a)(2); 417(a): Maintenance Inspections

Section 91.405(a) requires that an aircraft operator or owner “shall have that aircraft inspected as 

prescribed in subpart E of this part and shall between required inspections, except as provided in 

paragraph (c) of this section, have discrepancies repaired as prescribed in part 43 of this chapter ...” 

Section 91.407 similarly makes reference to requirements in Part 43; Section 91.409(a)(2) requires 

an annual inspection for the issuance of an air-worthiness certificate. Section 91.417(a) requires 

the owner or operator to keep records showing certain maintenance work that has been 

accomplished by certificated mechanics, under Part 43, or licensed pilots and records of approval of

the aircraft for return to service.

The INDF1 is nearly maintenance free, it performs automatic pre­flight checks and the failure of any

check will prevent take-off. Checks which cannot be done by the system will be performed by a 

qualified person prior to each flight and at predefined intervals as part of the Maintenance Schedule 

in the User Manual (see Exhibit 1).

Commented [CS1]: Put most recent or applicable 

exemptions.
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Pre­flight checklist includes:

 1. Visual inspection of the airframe

 2. Visual inspections of rotor integrity

 3. Check charge of all batteries (aerial vehicle, command station, radio repeater station)

An equivalent level of safety will be achieved because the sUAS is small in size, will carry no 

external payload, will operate only in restricted predetermined areas and is not a complex

mechanical devise. 

As provided in the attached User Guide (System Maintenance section), the operator of INDF1 will 

ensure that the sUAS is in working order prior to initiating flight, perform required maintenance,

and keep a log of any maintenance that is performed. Moreover, the operator is the person most

familiar with the aircraft and is best suited to maintain the aircraft in an airworthy condition and to

ensure an equivalent level of safety.

The INDF1‘s Maintenance guidelines ensure an equivalent level of safety to the maintenance 

requirements in Part 91. In addition, any component failure detectable by the system will be 

reported to the control station and will cause the UAV to perform a Fatal Condition Response (FCR) 

or Non-Fatal Conditioned Response (NFCR), depending on the type of failure.
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APPENDIX B

SMALL UNMANNED AERIAL SYSTEM DESCRIPTION

 

DJI Corporate Overview: DJI is a Chinese company located in Shenzhen, China. 

DJI is focused on providing micro unmanned aerial system and is globally recognized as the market 

and technology leader in this space.

DJI systems have been approved by the FAA for research COAs and have a demonstrated safety

track record.

INDF1 Overview: DJI unmanned systems have been used to locate and inspect railcars using video 

and RFID scanning technology.

The INDF1 can carry payloads up to 22 lbs. The INDF1 flies at a maximum wind threshold of 25

M.P.H. for sustained winds and wind gusts up to 35 M.P.H.. What is unique about the INDF1 is the

system automatically compensates for wind versus relying on the operator’s ‘sense of feel’ for what 

the impact of the wind is at the altitude the system is flying. The end result is a system capable of 

gathering high quality aerial intelligence at much higher wind thresholds. A trait that is imperative 

for many aerial inspection operations. 

The INDF1 has an operational range of up to 2 km (1 NM) with the standard offering. 

All flight operations are GPS controlled making the system extremely easy to navigate. At any point

if the operator is not explicitly commanding the system to move, the system automatically holds its 

GPS position (i.e. GPS hold for reliable location hover). Camera positioning is also GPS controlled 

allowing for the most sophisticated camera targeting available. The flight control system employs 

not only GPS positioning but a variety of sensors including, barometric pressure, temperature, wind 

speed and others to ensure the most stability of any system in its class - regardless of the wind. 

The INDF1 can be operated in both semi and fully autonomous flight modes. Creating preplanned

flight paths to fly in autonomous mode is as simple as clicking on the map to create a preplanned

flight path. In semi-autonomous mode, the operator clicks on the map and the INDF1 automatically

flies to the point on the map where the operator is pointing. Pre-mission waypoints, Landing zone 

points and flight area dimensions can all be entered during preflight ensuring the INDF1 operates 

only within specified parameters. 

The INDF1 includes many advanced safety features that makes the INDF1 the safest choice for both 

urban and non-urban environments. Built-in intelligent fault handling allows the INDF1 to detect a

system fault while in the air, and to automatically fly back to its take-off location and land. Faults 

that can be detected include: loss of communication; pre­set wind thresholds exceeded; and low

battery levels. In addition, the operator can create no fly zones or maximum flight ranges and

altitudes so the system cannot enter areas deemed unsafe or unnecessary to fly over. And before 

every take-off automated flight checks ensure the system is flight ready before it takes off. 

The INDF1 can be operated entirely by a touch-screen, map based interface. This means the

operator only needs to command the system where to go, and the system does all the flying for the
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operator. Maps can be saved and flight plans can be made or recalled with no Internet connection 

required. 

INDF1 Operating Manual - System user manual available upon request. 

Physical Characteristics: 

Measurements –

Wingspan – 56”

Height – 25” (including landing gear and GPS antenna)

Weight (without payload) – 13.5

Weight with payload (T/O weight) - 22

Propulsion System 

 ● Engines – The INDF1 is powered by 8 electric brushless DC motors. 

 ● Batteries – Lithium polymer batteries are self-contained high duration systems.

Performance Characteristics 

 ● Maximum Altitude – 400

 ● Maximum Endurance – 15

 ● Maximum Range – VLOS

 ● Weather Minimums - 1000/3

 ● Winds Maximum – 35 KTS

 ● Minimum ceiling: 500’

 ● Minimum visibility: 3 mi

 ● Icing conditions – no icing conditions 

 ● Precipitation – no visible moisture 

Maintenance – The sUAS is nearly maintenance free, it performs automatic pre-flight checks and the 

failure of any check will prevent take-off. A qualified person prior to each flight will perform checks, 

which cannot be done by the system. 

Pre-flight checklist includes: 

 ● Visual inspection of the airframe 

 ● Visual inspections of rotor integrity 

 ● Check charge of all batteries (aerial vehicle, command station, radio repeater station) 

Reliability – The system is designed for maximum reliability and to maintain performance over its 

life. 

The only components experience routine-wear are rotors, batteries, motors, and legs. 

Contact with other objects during flight may cause other components, particularly rotors, and

motor arms, to become damaged. Damaged components are likely to be detected during the full

visual inspection of the airframe performed before each flight. On-board sensors will detect 

structural damage affecting flight characteristics. 
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The sUAS detects numerous conditions, which may make flying unsafe, such as reduced GPS 

accuracy, magnetic anomalies, and low battery charge. Automatic pre-flight checks prevent the UAV

from taking off if such conditions are present; or, if the condition is detected during flight, the 

system will trigger a Fatal Conditioned Response. 

Fault Tolerance - the key feature of the sUAS fault tolerance is its mechanical simplicity. It uses 

eight fixed pitched rotors, each mounted on a separate motor. No control surfaces or other 

actuators are required for the sUAS to fly. Any component failure detectable by the system will be

reported to the control station and will cause the sUAS to perform a Fatal Condition Response

(FCR) or Non-Fatal Conditioned Response (NFCR), depending on the type of failure. 

Command and Control Systems 

The INDF1 Ground Control station allows the operator simultaneous control over aircraft and 

payloads. The touch screen control allows for quick navigation and data entry while the display 

screen provides all essential flight data to the operator. Telemetry data is transmitted to the 

command station at least once per second. 

Displayed on GCS: 

 ● UAS Position 

 ● Navigation Route 

 ● UAS Altitude 

 ● UAS Heading 

 ● North Seeking Arrow 

 ● Range to Target 

 ● Calculated target position 

 ● Date/time 

 ● Sensor heading and orientation relative to UAS 

On-board Flight Instruments – The UAV is equipped with an Inertial Navigation System (3-axis

gyroscope, and 3-axis magnetometer, GPS receiver, and static pressure sensor). 

On–board computer systems – The sUAS is equipped on-board computer systems to monitor 

(sensors, battery, etc.), control (speeds, altitude, position, etc.), and communicate (control, 

telemetry, etc.). 

On-board guidance and navigation equipment – The sUAS can operate autonomously; it does not 

require any input from ground-based equipment, or from the pilot to hover in place. 

Frequency Allocations – 900 MHz, 2.4 GHz, 5.8 GHz, custom 

Flight termination link – to prevent a “fly away” or other potentially dangerous situation a flight 

termination link is available to the operator at the GCS. 

Takeoff and Landing – The INDF1 has vertical lift autonomous launch and recovery. A Landing Zone 

“LZ” is designated by the operators and identified in the GCS software. For launch procedures the 

aircraft will takeoff and hover 3 meters directly above the LZ and hold until further operator 

instruction is given. The aircraft will automatically adjust for wind during this period. 
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Navigation System – Specific maps can be downloaded to the display screen (such as air sectional 

and geographic maps) which are overlaid with GPS positional data. Waypoints can be created 

before and during flight operation creating specific locations and sequences for the aircraft. 

Redundant Systems – The UAS combines the input from a multitude of sensors. Even though the 

data from all sensors is required for optimal system performance, a single sensor malfunction is 

likely to result in degraded performance rather than leading to a catastrophic failure.

Emergency Procedures and System Failures 

Failure Handling – The UAS has extensive failure detection and handling capabilities. All failures are 

deeded to be either fatal or non-fatal. Failures classified as fatal result in a Fatal Condition Response

(FCR); and failures classified as non­fatal result in a Non­Fatal Condition Response (NFCR). 

Sensor Failure – Failure of sensors will not degrade the sUAS performance and will result in a NFCR

which flight can be continued to safe landing.

Motor Failure – The UAS flight performance will degrade significantly if one or more motors fail. 

Airframe Failure – If airframe is damaged in ways that impacts flight characteristics, the UAS will 

behave similar to if an on-board flight instrument failed. 

Navigation System Failure – In a navigation system failure, degraded GPS will result in FCR or 

NFCR‘s depending on failures. 

Power Failure – A complete battery failure which results in power loss to the sUAS, will result in 

degraded flight performance. 

Low Battery Condition – Operator will be alerted of a low battery condition and will land the 

aircraft as soon as able.

Line-of-Sight Loss – All flight operations will be conducted with the UAS within visual sight of the 

pilot. If the pilot’s view becomes obstructed and line-of-sight is lost, the pilot may instruct the sUAS 

to hover in place until line-of-sight is reestablished, to return to the take-off position, or to land at 

the current position. 

Security 

The system and communication links are encrypted by the manufacturer’s proprietary software.
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APPENDIX C

SUMMARY OF INET SECTION 333 EXEMPTION REQUEST

INET hereby provides pursuant to Part 11, a summary of its exemption application to allow 

commercial operation of the INDF1 small unmanned system in: data collection, scouting, and 

inspections. An exemption is requested from the following regulations:

14 CFR 21;

14 CFR 45.23(b);

14 CFR 61.113(a) & (b);

14 CFR 61.133(a);

14 CFR 91.7(a);

14 CFR 91.9(b)(2) & (c);

14 CFR 91.103; 

14 CFR 91.109(a);

14 CFR 91.119; 

14 CFR 91.151(a);

14 CFR 91.203(a) & (b);

14 CFR 91.405(a);

14 CFR 91.407(a)(1);

14 CFR 91.409(a)(2);

14 CFR 91.417(a)
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