Saltuarius RPA LLC, Tulsa, OK Section 333 exemption Petition

July 23, 2015

U. S. Department of Transportation

Document Management System

1200 New Jersey Ave, SE

Washington, DC 20590

Re: Exemption Request Section 333 of the FAA Reform Act of the Federal Aviation Regulations from 

14 CFR Part 21 

14 C.F.R. 45.23(b) 

14 CFR 61.113 (a) & (b) 

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 91.405 (a) 

14 CFR 407 (a) (1) 

14 CFR 409 (a) (2) 

14 CFR 417 (a) & (b)

The name and address of the applicant is:

Saltuarius RPA LLC

Attn: Jeffrey Spatz

Ph:918-521-9778

Email: jeff@spatzenterprises.com

Address 7110 S. Mingo Rd., Suite 105, Tulsa, OK 74133

Dear Sir,

I, Jeffrey L. Spatz writing as Director of Operations for Saltuarius RPA LLC pursuant to the FAA 

Modernization and Reform Act of 2012 and the procedures contained within 14 C.F.R. 11, to request 

that Saltuarius RPA LLC, the owner and operator of small unmanned aircraft, be exempted from the

Federal Aviation Regulations (“FARs”) cited so that Saltuarius RPA LLC, its principals and properly trained 

and certified employees, may operate company owned small ultra light weight unmanned aircraft 

system (“UAS”) commercially in airspace regulated by the Federal Aviation Administration (“FAA”).

As described herein, SaltuariusRPA LLC is a small business domiciled in the state of Oklahoma. Company 

President Josh O’leary is experienced in designing, building and flying various hobby multi-copters for 

recreational purposes.Mr. O’leary and I founded Saltuarius RPA LLC with the desire to expand Mr. 

O’Leary’s hobby to a business providing services to the Oklahoma community. 
Mr. O’Leary has a Bachelor of Science degree in mechanical engineering from the University of Tulsa and 

a long history of interest in the mechanics of flight. I, Jeffrey Spatz have a Bachelor of Science in Business 

Administration and have been employed as a photojournalist and news operations manager in the 

television industry since 1989.

As described more fully below, the requested exemption would permit the operation of small, 

unmanned and relatively inexpensive sUAS under controlled conditions in airspace that is 1) limited 2) 

predetermined 3) controlled as to access and 4) would provide safety enhancements to the already safe 

operations in the industry presently using conventional aircraft. Approval of this exemption would 

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

Mr. O’Leary currently owns three flying UAS’, a 250mm1quad-copter and a 450mm2quad-copter, a 960 

mm size hexa-copter3. All UAS are built using commercially sourced airframes and components and 

extensively flight tested in the course of Mr. O’Leary’s hobby. All are equipped with various imaging 

systems including but not limited to GoPro and Sony A7 digital cameras with the intent of using them for

aerial photography/cinematography to enhance academic community awareness of geography and 

landscapes of Oklahoma and surrounding areas and to augment the visual awareness of real estate 

listings in said area following exemption and approval by the FAA; thereby enhancing the research 

experience for the Oklahoma area. Upon granting of this exemption petition ownership of Mr. O’Leary’s 

UAS will be transferred to Saltuarius RPA LLC for exclusive flight use by the company.

In the future Saltuarius RPA intends to expand its inventory by designing and building additional UASs. 

All additional UAS will have comparable safety capabilities.

Josh O’Leary, as a hobbyist, has built and flown numerous small remotely controlled electric multicopters for over 100 flight hours without incident and Saltuarius RPA LLC is committed to safety with 

each flight. The exemption requested by Saltuarius RPA LLC would permit operation of ultra light weight, 

unmanned (piloted by remote control) and inexpensive UAS(s) in tightly controlled and limited airspace. 

Predetermined flights in areas away from general public, airports, heliports and vehicular traffic

for community videos, and within property boundaries for individual real estate videos/photos. 

Currently, similar lightweight, remote controlled UAS's are legally operated by unmonitored amateur 

hobbyists with no safety plan or controls in place to prevent incidents or accidents involving public 

property or person. 

Josh O’leary has personally instilled safety as UAS pilot on every flight as a hobbyist and Saltuarius RPA 

has consistently instilled a company culture stressing safety protocols in all its operations. Mr. O’Leary 

and Saltuarius RPA LLC have designed and published operations manuals1and procedures to prevent 

public hazard, as well as avoid interference, hazard or catastrophe to manned aircraft. This will act to 

further safety protocols exclusive to lightweight UAS specific to community video and photography as 

Mr. O’Leary and the company record flight data and other information gained through the permitted 

flight operations to share with the FAA through any required FAA reports to assist with future 

development of regulations relating to use of UAS in the national airspace.

Granting this request of Saltuarius RPA LLC is in accordance with the Secretary of Transportation’s (FAA 

Administrator’s) responsibilities and authority to not only integrate UAS into the national airspace 
system, but to “...establish the requirements for the safe operation of aircraft systems (UAS) in the 

national airspace system,” under Section 333(c) of the Reform Act specific to the use of UAS for real 

estate purposes. Saltuarius RPA LLC will conduct all operation in compliance with the protocols 

described herein or as established by the FAA.

For the reasons stated herein I, Jeffrey Spatz on behalf of Saltuarius RPA LLC, respectively request the 

grant of an exemption allowing Saltuarius RPA LLC to operate ultra light weight remote controlled UAS 

for the community awareness to benefit/stimulate interest in the topography, culture and industry of 

Oklahoma and NAS areas and to enhance videos for citizens who cannot afford expensive manned 

aircraft for the same purpose. Both of which will promote local economic growth through increased 

employment and increased tax base. Both with public safety in mind by keeping manned aircraft of 

greater weight and carrying combustible fuel that poses a potential public hazard.

Regulations from which the exemption are being requested:

14 CFR Part 21 

14 C.F.R. 45.23(b) 

14 CFR 61.113 (a) & (b) 

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 91.405 (a) 

14 CFR 407 (a) (1) 

14 CFR 409 (a) (2) 

14 CFR 417 (a) & (b)

This exemption application is expressly submitted to fulfill Congress’ goal in passing Section 333(a) 

through (c) of the Reform Act. This law 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 Secretary is required to 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

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

Reform Act § 333 (a). Lastly, 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) (emphasis added)2 . 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, that includes sUASs, from the 

requirement that all civil aircraft must have a current airworthiness certificate.
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 this title if the 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). 

Saltuarius RPA LLC’s sUASs are:

 Muli-rotorcraft, weighting 55 or fewer lbs. including payload. 

 They operate, under normal conditions at a speed of no more than 50 knots and 

 Have the capability to hover, and move in the vertical and horizontal plane 

simultaneously. 

 They will operate only in line of sight and in accordance with the attached flight 

operations 

manual. 

Such operations will insure that the sUAS will “not create a hazard to users of the national airspace 

system or the public.” Given the small size of the sUASs involved and the restricted environment within 

which they will operate, the applicant falls squarely within that zone of safety (an equivalent level of 

safety) in which Congress envisioned that the FAA must, by exemption, allow commercial operations of 

UASs to commence immediately. Also due to the size of the UASs and the areas in which the relevant 

sUASs will operate, approval of the application presents no national security issue. 

Given the clear direction in Section 333 of the Reform Act, the authority contained 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, reduction in environmental impacts, 

including reduced emissions associated with allowing UASs for video acquisition operations, the grant of 

the requested exemptions is in the public interest. 

Accordingly, the applicant respectfully requests that the FAA grant the requested exemption without 

delay. The applicant proposes that the exemption requested herein apply to civil aircraft that have the 

characteristics and that operate with the limitations listed herein. These limitations provide for at least 

an equivalent or even higher level of safety to operations under the current regulatory structure 

because the proposed operations represent a safety enhancement to the already safe video acquisition

operations conducted with conventional aircraft.
Regulations From Which Exemption is Requested: 

Saltuarius RPA LLC seeks an exemption from several interrelated provisions of 14 C.F.R. Parts 21, 45 and 

91 for purposes of conducting aerial photography and video using sUAS. Listed below are: (1) the 

specific sections of 14 C.F.R. for which exemption is sought; and (2) the operating procedures and 

safeguards that Petitioner has established which will ensure a level of safety equal to or better than the 

rules from which exemption is sought.

1. 14 C.F.R. Part 21, Subpart H Airworthiness Certificates & 14 C.F.R. § 91.203(a)(1).

This petition seeks an exemption from 14 C.F.R. Part 21, Subpart H, which establishes the procedural 

requirements for the issuance of airworthiness certificates as required by 14 C.F.R. §91.203(a)(1). Given 

the size and limited operating area associated with the sUAS to be utilized by the Petitioner, an 

exemption from Part 21 Subpart H meets the requirements of an equivalent level of safety under Part 

11 and Section 333 of the Reform Act. 

The Federal Aviation Act (49 U.S.C.§ 44701(f)) 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 particular 

sUAS. In all cases, an analysis of these criteria demonstrates that the sUAS operated without an 

airworthiness certificate, in the restricted environment and under the conditions proposed will be at 

least as safe, or safer, than a conventional rotorcraft operating with an airworthiness certificate without 

the restrictions and conditions of the proposed sUAS operations

2. 14 C.F.R. Part 27: Airworthiness Standards: Normal Category Rotorcraft.

14 C.F.R. Part 27 sets forth the procedural requirements for airworthiness certification of normal 

category rotorcraft. To the extent the Petitioner's sUASs would otherwise require certification under 

Part 27, as a rotorcraft, Petitioner airworthiness standards for the same reasons identified in the 

exemption request from 14 C.F.R. Part 21, Subpart H

3. Aircraft Marking and Identification Requirements: 14 C.F.R. §§ 91.9(c), 45.23(b) and 

45.27(a). 

This petition seeks an exemption from the aircraft marking and identification requirements of 14 C.F.R. 

§§ 91.9(c), 45.23(b) and 45.27(a). 

14 C.F.R. § 91.9(c), Civil aircraft flight manual, marking, and placard requirements, provides that: No 

person may operate a U.S.-registered civil aircraft unless that aircraft is identified in accordance with 

part 45 of this chapter. 

14 C.F.R. § 45.23(b), Markings of the Aircraft, states: 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," "light-sport," "experimental," or "provisional," as 

applicable. 

14 C.F.R. § 45.27(a), Rotorcraft, states: Each operator of a rotorcraft must display on that rotorcraft 

horizontally on both surfaces of the cabin, fuselage, boom, or tail the marks required by §45.23. 

Exemption from § 45.23(b) is warranted because the sUAV has no entrance to the cabin, cockpit, or pilot 

station on which the word "Experimental" can be placed. Moreover, given the size of the sUAV, two-inch 

lettering would be impossible. The word "Experimental" will be placed on the fuselage in compliance 

with § 45.29(f). Given the nature of the specific relief sought by this exemption request, Petitioner 

requires relief from the associated marking and identification requirements of § 45.27(a) and § 91.9(c), 

which would require compliance with § 45.23(b). 

Equivalent Level of Safety

An equivalent level of safety for exemptions to the aircraft marking and identification requirements of 

§§ 91.9(c), 45.23(b) and 45.27(a), will be provided by having the sUAV marked on its fuselage as 

required by §45.29(f) where the pilot, observer, and others working with the sUAV will see the 

identification of the sUAS as "Experimental." Additionally, Petitioner will ensure compliance with any 

requests of sUAS marking by the FAA. 

The FAA has issued the following exemptions to the aircraft marking requirements of § 45.23(b): 

Exemptions Nos. 10700, 8738, 10167 and 10167A.

4. PILOT REQUIREMENTS 

14 C.F.R. § 61.113 (a) & (b): 14 CFR 61.113 Private pilot privileges and limitations: Pilot in Command and 

61.133 Commercial pilot privileges and limitations. The regulation provides that no person that holds a 

private pilot certificate may act as pilot in command of an aircraft for compensation or hire. 

Subparagraph (b) allows a private pilot to act as pilot in command of an aircraft in connection with any 

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

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

require that the PIC must either 1. Hold a Sport Pilot Certificate issued by the FAA, and have logged 25 

hours of flight experience in this type of UA, or 2. Meet the requirements of 8900.227 para 16(c)(2)(c) 

"Operations without a pilot certificate" in which the PIC is required to complete "FAA private pilot 

ground instruction" and pass "the FAA Private Pilot written examination." Since there are currently no 

means available for the pilot of a UAS to gain the experience in an equivalent category and class in order 

to apply for a commercial pilot's license, we propose to generate an equivalent level of safety by 

requiring our pilots to complete, at a minimum, FAA commercial pilot ground instruction and pass the 

FAA Commercial Pilot written examination in addition Appendix A to completing the private pilot 

requirements. Since the aircraft cannot carry passengers or property, we feel we meet the intent of 

61.113 Subparagraph (b) even though the intent of this application is to conduct a business.
4. 14 C.F.R. § 91.9(b)(2): Civil Aircraft Flight Manual in the Aircraft. 

This petition seeks an exemption from the flight manual requirements of 14 C.F.R. § 91.9(b)(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 its size, configuration, and load capacity, the sUAS has no ability to carry such a manual on the 

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

carry such an item on the aircraft. 

Equivalent Level of Safety

The safety related purpose of this manual requirement can be equally satisfied by maintaining the sUAS 

flight manual at the ground control point where the pilot flying the sUAS will have immediate access to 

it. Accordingly, Petitioner requests an exemption from § 91.9(b)(2)'s flight manual requirements, on the 

condition that the sUAS flight manual be available at the control point during each operation. The FAA 

has issued the following exemptions to this regulation: Exemption Nos. 8607, 8737, 8738, 9299, 9299A, 

9565, 9565B, 10167, 10167A, 10602, 32827, and 10700.

5. 14 C.F.R. § 91.7(a): Civil Aircraft Airworthiness. 

This petition seeks an exemption from 14 C.F.R. § 91.7(a), which requires that a civil aircraft be in an 

airworthy condition to be operated. Inasmuch there will be no airworthiness certificate issued for the 

sUAS, should this exemption be granted, no FAA regulatory standard will exist for determining 

airworthiness.

Equivalent Level of Safety

Given the size of the sUAS and the requirements contained in the sUAS manual for maintenance and 

use of safety checklists prior to each flight, an equivalent level of safety will be provided. The FAA has 

issued the following exemptions to this regulation: Exemption Nos. 8607, 8737, 8738, 9299, 9299A, 

9565, 9565B, 10167, 10167A, 10602, 32827, and 10700.

6. 14 C.F.R. § 91.103: Preflight Action.

This petition seeks an exemption from § 91.103, which requires a PIC to become familiar with specific 

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

board the aircraft. Inasmuch as an FAA approved flight manual will not be provided for the sUAS, an 

exemption will be needed. 

Equivalent Level of Safety

An equivalent level of safety will be provided by following the sUAS comprehensive preflight checklist. 

The PIC will take all actions, including reviewing weather, flight battery requirements, landing and 
takeoff distances, and aircraft performance data, before initiation of flight. Pilot shall conduct preflight 

in accordance with company operations manual attached.

7. 14 C.F.R. § 91.109(a): Flight Instruction. 

This petition seeks an exemption from 14 C.F.R. § 91.109(a), which provides 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. sUASs and remotely piloted aircraft, by their design do not have fully 

functional dual controls. Instead, flight control is accomplished through the use of a control box that 

communicates with the sUAS via radio communications. 

Equivalent Level of Safety

Given the size and speed of the sUAS, an equivalent level of safe training can still be performed without 

dual controls because no pilot or passengers are aboard the sUAS, and all persons will be a safe distance 

away should the sUAS experience any difficulties during flight instruction. 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

8. 14 C.F.R. § 91.119: Minimum Safe Altitudes. 

This petition seeks an exemption from the minimum safe altitude requirements of 14 C.F.R. § 91.119. 

Section 91.119 prescribes the minimum safe altitudes under which aircraft may not operate, including 

500 feet above the surface and away from any person, vessel, vehicle, or structure in non-congested 

areas. See 14 C.F.R. § 91.119(c). Section § 91.119(d)(1) allows for a hazard to persons helicopter 

complies with any routes or altitudes specifically prescribed for helicopters by the FAA. 

To provide the intended video and photographs, the sUAS will normally need to be operated within a 

range of approximately 50 to 100 feet from the subject being photographed or recorded. Accordingly, 

due to the nature of the proposed operations, the PIC and the designated spotter may at times be less 

than 500 feet away from structures during the operation, and an exemption is therefore required. 

Additionally, the sUAS is prohibited from being flown at an altitude greater than 400 feet, so an 

exemption is therefore required. 

Equivalent Level of Safety

Compared to flight operations with rotorcraft weighting far more than the maximum 55 lbs. proposed 

herein, and the lack of flammable fuel, any risk associated with these operations is far less than those 

presently presented with conventional aircraft.

Equivalent level of safety 

Given the size, weight, speed of the sUAS as well as the location where it is operated. The sUAS will be 

operated in a restricted area, where buildings and people will not be exposed to operations without 

their pre-obtained consent. No flight will be taken without the permission of the property owner and/or 
local officials. Because of the advance notice to the property owner and participants, all affected 

individuals will be aware of the planned flight operations. Furthermore, by operating at such low 

altitudes, the sUAS will not interfere with other aircraft that are subject to the minimum safe altitude 

regulations.

9. 14 C.F.R. § 91.121 Altimeter Settings. 

This petition seeks an exemption from 14 C.F.R. § 91.121, which requires a person operating an aircraft 

to maintain cruising altitude or flight level by reference to an altimeter that is set to the elevation of the 

departure airport or barometric pressure. An exemption is required because the sUAS does not have a 

barometric altimeter, but rather a GPS altitude read out. 

Equivalent Level of Safety

An equivalent level of safety will be achieved by following the procedures set forth in the Manual. As 

prescribed in the Manual, the operator will confirm the altitude of the launch site shown on the GPS 

altitude indicator before flight. Moreover, the PIC or observer will use the GPS altitude indicator to 

constantly monitor the sUASs height, thus ensuring operation at safe altitudes.

10. 14 C.F.R. § 91.151(a): Fuel Requirements for Flight in VFR Conditions. 

This petition seeks an exemption from 14 C.F.R. § 91.151(a)'s fuel requirements for flight in VFR 

conditions. Section 91.151 states: (a) No person may begin 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 battery powering the sUAS provides approximately 30 minutes of powered flight. An exemption 

from the 30 minute reserve requirement in 14 CFR §91.151 is therefore required. 

Equivalent Level of Safety

An equivalent level of safety can be achieved by limiting flights to 30 minutes or 25% of battery power, 

whichever happens first. This restriction would be more than adequate to return the sUAS to its planned 

landing zone from anywhere within its limited operating area. Operation of the sUAS with less than 30 

minutes of reserve fuel does not engender the type of risks that Section 91.151(a) was intended to 

alleviate given the size and speed of the small sUAS. Moreover, operation will be limited to controlled 

areas where only people and property owners, or official representatives will be allowed. This request 

for exemption falls within the scope of prior exemptions. See e.g. Exemption 10673 (allowing Lockheed 

Martin Corporation to operate without compliance with § 91.151 (a)); see also Exemptions 2689F, 5745, 

10673, and 10808.

12. 14 C.F.R. § 91.203 (a) & (b): Carrying Civil Aircraft Certification and 

Registration. 
This petition seeks an exemption from civil aircraft certification and registration requirements of 14 

C.F.R. § 91.203 (a) and (b). The regulation provides in pertinent part: (a) Except as provided in §91.715, 

no person may operate a civil aircraft unless it has within it the following: (1) 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. 

In addition to the fact that Petitioner is seeking an exemption from the airworthiness load capacity and 

size does not allow it to carry certification and registration documents; (2) the sUAS does not have a 

cabin or cockpit entrance at which the documents could be displayed; and (3) there are no passengers 

or crew for whom the certificates need be displayed. 

Equivalent Level of Safety 

To the extent these regulations are applicable to the proposed sUAS operations, 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.

13. 14 C.F.R. §§ 91.405(a); 91.407(a)(1); 91.409(a)(2); 91.417 (a) & (b): Maintenance 

Inspections. 

This petition seeks an exemption from the maintenance inspection requirements of 14 C.F.R. §§ 

91.405(a); 91.407(a)(1); 91.409(a)(2); 91.417 (a) & (b). These regulations specify maintenance and 

inspection standards in reference to 14 C.F.R. Part 43. See, e.g., 14 C.F.R. § 91.405(a) (stating that each 

owner or operator of an aircraft as prescribed in subpart E of this part.

An exemption to these regulations is needed because Part 43 and these sections apply only to aircraft 

with an airworthiness certificate, which the sUAS will not have.

Equivalent Level of Safety 

An equivalent level of safety will be achieved because maintenance and inspections will be performed in 

accordance with the Aircraft Operations Manual as referenced in the sUAS manual. As provided in the 

manual, the operator will ensure that the sUAS is in working order prior to initiating flight, perform 

required maintenance, and keep a log of any maintenance performed. The operator is the person most 

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

equivalent level of safety. 

If mechanical issues arise, the sUAS can land immediately and will be operating from no higher than 400 

feet AGL. Moreover, the sUAS's small size, carrying capacity, and the fact that flight operations will only 

take place in restricted areas for periods of time not to exceed 30 minutes or until 25% battery power 

remains, create less risk than the same factors associated with conventional fixed-wing aircraft and 

rotorcraft performing the same operation.

Federal Register Summary Pursuant to 14 C.F.R. Part 11T

The following summary is provided for publication in the FEDERAL REGISTER, should it be determined 

that publication is needed: SaltuariusRPA LLC. seeks an exemption from the following rules: 14 CFR Part 

21, Subpart H; 14 CFR Part 27; 14 CFR 45.23(b); 14 C.F.R. § 61.113 (a) & (b); 14 CFR 91.7(a); 14 CFR 

91.9(b)(2); 14 CFR 91.103; 14 CFR 91.109(a); 14 CFR 91.119; 14 CFR 91.121; 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) & (b). 

Approval of exemptions allowing commercial operations of small and lightweight unmanned aircraft 

("sUAS") in the photography and videography industry will enhance safety by reducing risk. 

Conventional operations in this industry using rotorcraft or fixed-wing aircraft present the risks 

associated with vehicles that weigh several thousand pounds and carrying large amounts of volitile fuel. 

Such aircraft must fly to and from the survey or inspection location and operate at low altitudes. 

In contrast, a sUAS weighing fewer than 55 lbs. and powered by batteries eliminates virtually all of that 

risk, given the reduced mass and lack of combustible fuel carried on board. The sUAS is transported, not 

flown, to the designated imaging area and set up. The sUAS carries no passengers or crew and, 

therefore, does not expose them to the risks associated with manned aircraft flights. 

The operation of small sUAS, weighing less than 55 lbs., provides an equivalent level of safety and thus 

supports the grant of the exemptions requested herein, including exempting the applicant from the 

requirements of Part 21 and allowing commercial operations. These lightweight sUAS operate at slow 

speeds, close to the ground, and in a sterile environment. As a result, they are far safer than 

conventional aerial photography or videography operations conducted with conventional fixed wing 

aircraft or helicopters.
Conclusion

Satisfaction of the criteria provided in Section 333 of the Reform Act of 2012. The size, weight, speed, 

operating capabilities, proximity to airports and populated areas, and operation within visual line of 

sight and national security provides more than adequate justification for the grant of the requested 

exemptions allowing commercial operation of Saltuarius RPA LLC. 

If additional information is required, or if you have any questions regarding this Petition for Exemption, 

please contact the undersigned:

Very truly yours, 

_____________________________ 

Jeffrey L. Spatz

Director of Operations

Managing Member
Attachments (All Subject to Non-Disclosure Under the Freedom of 

Information Act, 5 U.S.C. § 552 et. seq.): 

Attachment A: Saltuarius RPA Flight Operations Manual

Phantom Vision 2 Plus operators manual ATTACHMENT A This 

document is available online at 

http://download.djiinnovations.com/downloads/phantom_2

_vision_plus/en/Phantom_2_Vis 

ion_Plus_User_Manual_v1.1.1_en.pdf