Dale Greer

January 6th, 2016

8200 Southwestern Blvd.

1303

Dallas TX 75206

U.S. Department of Transportation

Docket Management System

1200 New Jersey Ave., SE

Washington, DC 20590

Dear Sir or Madam:

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

C.F.R. Part 11, Dale Greer (DG) seeks an exemption from Federal Aviation Regulations (“FARs”) detailed 

below to allow commercial operation of his small unmanned aircraft systems (hereafter referred to as 

“sUAS” or “Drone”), for the purposes of aerial photography, videography, mapping, crop surveying, 

inspections, and other flight operations, so long as such operations are conducted within and under the 

conditions outlined herein or as may be established by the FAA as required by Section 333 of the FAA 

Modernization and Reform Act of 2012.

The requested exemption would permit the operation of small, unmanned and UAV’s under controlled 

conditions in airspace that is 1) limited 2) predetermined 3) controlled as to access. 

DG is currently taking instruction to obtain a Sport Pilot certificate, and at this point near first solo flight. 

UAV flights performed by DG, in all scenarios, will readily be protected with secured access by the staff of 

DG. DG plans to offer videographic, photogrammetric, and photographic services for commercial purposes 

initially including: 

1. Aerial mapping and photogrammetry of commercial and residential land;

2. Agricultural crop assessment and growth patterns;

3. Golf course management;

4. Construction site and ecological impact assessment;

5. 3-dimensional scanning and modeling of factories and other construction;

6. Real estate video showcasing of residential and commercial grade properties for the purpose of 

resale;

7. Aerial photography;

8. Pipeline inspection;

9. Cell tower inspection.

The UAV applications listed above are closed to the general public, providing the opportunity to operate 

only in an area where informed, consenting participants and personnel are present. 

Where factories and other construction are concerned, DG will be operating within airspace previously 

reviewed by the FAA for the construction of the factory, therefore the airspace of the controlled operations 

area creates no additional hazard to the national airspace. Approval of this exemption would therefore 

create no safety concerns regarding national airspace 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. 
Additionally, all DG staff pilots will hold an airline transport, commercial, private, recreational, or sport 

pilot certificate and also hold a current FAA airman medical certificate or a valid U.S. driver’s license issued

by a state, the District of Colombia, Puerto Rico, a territory, a possession, or the Federal government. If an 

observer is not a qualified pilot, they will be trained by DG staff 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. 

The name and address of the applicant is: 

Dale Greer 

8200 Southwestern, 1303 

Dallas TX 75206 

Phone: 1-469-569-4155 

Email: dmgreer@airmail.net 

Regulations from which the exemption is requested: 

14 C.F.R. Part 21 

14 C.F.R. 45.23 (b) 

14 C.F.R. 45.29 

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

14 C.F.R. 61.133 

14 C.F.R. 91.7 (a) 

14 C.F.R. 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 C.F.R. 91.151 (a) 

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

14 C.F.R. 91.215

14 C.F.R. 91.405 (a) 

14 C.F.R. 407 (a) (1) 

14 C.F.R. 409 (a) (2) 

14 C.F.R. 417 (a) & (b) 

Grants of exemption in circumstances similar in all material respects, In

Grants of Exemption Nos. 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), 11213 to Aeryon Labs, Inc. (see Docket No.

FAA−2014−0642), and 12645 to Allied Drones (see Docket No. FAA2014-0804) Exemption Nos. 11062, 11109, 11112, 11213, and 12645;

Nos. 11062, 11109, 11112, 11213, and 12645.
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 UAV 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 UAV size, weight, speed, and operational capability; 

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

• Operation of the UAV 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." Applicant interprets this provision to place the duty on the Administrator

to not only process applications for exemptions under section 333, but for the Administrator to craft 

conditions for the safe operation of the UAS, if it should be determined that the conditions set forth herein 

do not fulfill the statutory requirements for approval. 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 §401 01 of the Act that includes UAV, 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). 

Dale Greer UAV’s consist of manufacturer built 4 to 8 engine multirotor craft, weighing 55 or fewer lbs. 

including payload, that have been previously approved by exemption, namely:

DDJI Spreading Wings S900; DJIS1000; DJI Phantom 1, DJI Phantom 2, DJI Phantom 3; 

DJI Inspire; SenseFly eBee; SenseFly eXom; 3D Robotics X8; 3D Robotics Solo; 3D 

Robotics Aero; 3D Robotics Iris+; Yuneec Q500 Typhoon.

These sUAS all weigh less than 55 lbs,, have a built- in capability to limit the height flown 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. 

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 will operate only within a small controlled area described in the Confidential Operations Procedures, 

attached as Exhibit A (hereinafter "Procedures") Such operations will insure that the UAV will "not create 

a hazard to users of the national airspace system or the public.'' 

Applicant submits this Procedure as a Confidential and Proprietary document under 14 CFR 11 .35 (b) as 

the entire Procedures contains proprietary information that the applicant has not and will not share with 

others. The Procedures contains operating conditions and procedures that are not available to the public 

and are protected from release under the Freedom of Information Act 5 USC 552 et.seq. Given the small 

size of the UAV’s involved and the restricted controlled 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 UAV’s to commence 
immediately. Also due to the size of the UAV’s and the controlled areas in which the relevant UAV’s will 

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

How this Request is to the Betterment of our Community 

We believe that the use of UAS to perform agricultural land imaging creates a benefit to the public. The 

ability to use an onboard geo-referenced still camera to collect high-resolution data that can be used to 

increase crop production and reduce unnecessary chemical use will provide a less expensive and healthier

food supply to the public. The unmanned aircraft does not carry any persons or flammable liquids, 

reducing public exposure in the event of an incident. Finally, the unmanned aircraft can be launched and 

recovered from the property which we have been contracted to image. The ability to avoid overflying 

private and public properties provides the public with the benefit of privacy from aircraft flying overhead. 

Unmanned Aircraft Systems (sUAS) are also a feasible method to obtain information of agricultural 

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

environmental impact of excess fertilizers and chemicals in the soil. 

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

AIRCRAFT AND EQUIVALENT LEVEL OF SAFETY

The operation limitations proposed for an equivalent or higher level of safety because operations will 

further enhance the safety of the persons and/or property using conventional aircraft. These limitations 

and conditions to which the applicant agrees to adhere to when conducting commercial operations under 

the FAA issued exemption as set forth in the Flight Operations Manual (FOM) include:

1. The UAS will weigh significantly less than 55 lbs. It weighs less than 4 pounds with battery and 

camera.

2. The UAS, depending on the model in operation, will have a maximum operating speed of no more 

than 50mph.

3. Flights will be operated within line of sight of the Pilot in Command (PIC) and/or Visual Observer 

(VO).

4. Maximum flight time for each operational flight will be depending on the UAS model in operation, 

but will not exceed 30 minutes. Flights will be terminated at 25% battery power reserve or 30 

minutes of flight time whichever occurs first.

5. Flights will be operated at an altitude of no more than 400 feet Above Ground Level (AGL) and not 

more than 200 feet above an elevated platform from which filming is planned.

6. Minimum crew for each operation will consist of the UAS Pilot and at least one Visual Observer 

(VO), and may include a third, but separate, Camera Operator (CO).

7. The UAS pilot will be a designated Pilot in Command (PIC). The PIC will have logged a minimum of 

20 hours on the designated UAS.

8. A safety briefing will be performed prior to each day's flights consisting of all the days' Production 

activities.

9. All flight activities will be logged.

10. All flights will occur under Visual Flight Rules Meteorological Conditions (VMC) only.

11. The flights will occur in Class G airspace no closer than a mile radius of the geographic 

center/Airport Reference Point (ARP) of a tower controlled or uncontrolled airport, unless a letter 

of agreement with that airport’s management is obtained or otherwise permitted by a COA issued 

to DG.

12. Flights will not be closer than a 5-mile radius of the geographic center/Airport, as denoted in the 

current FAA Airport/Facility Directory (AFD), unless a letter of agreement with that airport’s 

management is obtained or otherwise permitted by a COA issued to DG. 

13. The operator will do a pre check of aircraft prior to each flight, and log each flight.

14. The operator will obtain verbal/written consent of all persons involved with the planned 
operation and ensure that only consenting persons will be allowed within 100 feet of the flight 

operation, and the radius may be reduced to 30 feet based upon an equivalent level of safety 

determination, as U.S. Department of Transportation required under the FOM. With the advanced 

permission of the FSDO, operations at closer range may be approved.

15. The PIC and VO will have been trained in operation of UAS and receive up to date information for 

the particular UAS to be operated.

16. The PIC and VO will be able to communicate by voice and/or radio at all times.

17. The PIC will abide by all FAA airspace rules.

18. The PIC will yield right of way to all manned aircraft.

19. If the UAS loses communications with the remote controller or loses GPS signal, the UAS will have 

the capability to return to a predetermined location within a designated location and land 

autonomously.

20. The UAS will have the capability to abort a flight in case of emergencies with an automated "Return

Home and Land" function.

21. The UAS will have the capability to abort a flight in case of unpredicted obstacles, weather, or 

emergencies such as low battery.

Pre-flight Requirements 

The PIC will follow a comprehensive pre-flight checklist to ensure that the sUAS is in a condition of safe 

flight. This plan will be improved as needed to to incorporate precautions and safety suggestions issued by

the manufacturer. 

A. Pre-flight Inspection 

1. Check that the transmitter, sUAS and camera batteries are all fully charged. 

2. Verify that the sUAS battery is not swollen or damaged in any way. 

3. Turn the motor shafts with your fingers and verify that are smooth without excessive play 

or binding. 

4. Verify that the propellers are mounted correctly and free from signs of damage. 

5. Run finger along the edge of blade to check for any rough edges. 

6. Flex both sides of the propellers’ blades to check for hairline cracks where the blades 

connect in the center of the propeller. 

7. Verify that the landing gear is secure and free from damage, broken or loose. 

8. Verify that the camera is secure and clean. Inspect the camera connections and gimbal for 

tears and/or signs of wear. 

9. Verify that the damping absorbers are not broken and/or worn. 

10. Verify that the Micro-SD card has been inserted and formatted. 

11. Verify that the remote camera link is enabled. 

B. Power Up 

1. Power on the transmitter with the flight mode set to the appropriate setting the throttle 

stick down and the throttle trim at neutral. 

2. Install a charged battery in the UAS, plug it in and close the hatch. 

3. Wait for the GPS signal to be acquired, which is indicated by a solid LED. It may take from 

30-90 seconds to acquire a GPS signal. 

4. Move the aircraft to the desired home location and orient the aircraft pointed away from 

the pilot. 

5. Step back approximately 15 feet (5 meters) from the home location. 

C. Ready to Fly 

1. Power on camera and acquire camera link. 

2. Verify that the aircraft still has GPS lock. 

3. Start the motors. 

4. Verify that the motors are functioning normally, are not making any unusual noises, and are

all spinning the same speed. 

5. Verify that the area is still clear of obstructions, people, power lines, etc. 
6. Take off and hover about 6-8 feet above the takeoff point to verify that the aircraft still has 

a solid GPS lock. If any abnormalities are noticed (drifting, flying in circles, etc.), land 

immediately and repeat the “Pre-flight Inspection” and Power Up” sequences. 

7. Verify that the aircraft holds a steady position while yawing 360 degrees. 

8. Verify that the aircraft responds appropriately to all controls – yaw, pitch, roll and throttle. 

Post Flight Requirements 

A. After Flight 

1. Turn off the power switch on the aircraft. 

2. Turn off the power to the transmitter. 

3. Turn off the camera power. 

4. Unplug and remove battery from aircraft. 

5. Secure flight operations area. 

Preventive Maintenance

A comprehensive preventative maintenance plan will be followed in accordance with the manufacturer’s 

specifications to ensure the sUAS software is up-to-date, the batteries are ingood health, and the aircraft 

itself is always ready for safe flight. 

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

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 and limited operating area associated with the aircraft to be utilized by the Applicant, 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 UAV. In all cases, an analysis of these criteria demonstrates that the 

UAV 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 aircraft (fixed wing or rotorcraft) operating 

with an airworthiness certificate without the restrictions and conditions proposed. 

The UAV’s to be operated hereunder is less than 55 lbs. fully loaded, carries neither a pilot nor passenger, 

carries no explosive materials or flammable liquid fuels, and operates exclusively within a controlled area 

as set out in the Procedures. Unlike other civil aircraft, operations under this exemption will be tightly 

controlled and monitored by the operator, pursuant to the Procedures requirements. Lastly, application of 

these same criteria demonstrates that there is no credible threat to national security posed by the UAV, 

due to its size, speed of operation, location of operation, lack of explosive materials or flammable liquid 

fuels, and inability to carry a substantial external load. 

14 C.F.R. §45.23 Display of markings; GENERAL AND §45.29 Size of marks.

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

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

least 2 inches high near the entrance to the cabin, cockpit, or pilot station. The sUAV does not have an 

entrance in which the word "EXPERIMENTAL" can be placed, and may not have a registration number 

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

"EXPERIMENTAL" in the placard on the top of the aircraft, as shown above, where the PIC (Pilot In 

Control), VO (Visual Observer) and others in the vicinity of the aircraft while it is preparing for launch will 

be able to see the designation. Additionally, I feel that the permanent placard discussed in the previous 

paragraph will provide the aircraft's registration information at the ground station. Finally, I will display at
the ground station a high contrast flag or banner that contains the words "Unmanned Aircraft Ground 

Station" in letters 3 inches high or greater. Since the aircraft will operate within 3/4 NM of the ground 

station, the banner should be visible to anyone that observes the aircraft and chooses to investigate its 

point of origin. 

14 C.F.R. §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. My proposed operation requires that the PIC must hold at least a Private Pilot Certificate with a valid 

drivers license from any state and since the aircraft cannot carry passengers or property, I feel that I meet 

the intent of 61.113 Subparagraph (b) even though the intent of this application is to conduct a business. 

14 C.F.R. §91.7(a): Civil aircraft airworthiness. 

The regulation requires that no person may operate a civil aircraft unless it is in airworthy condition. As 

there will be no airworthiness certificate issued for the aircraft, should this exemption be granted, no FAA 

regulatory standard will exist for determining airworthiness. 

Given the size of the aircraft and the requirements contained in the Procedures for maintenance and use of

safety checklists prior to each flight, an equivalent level of safety will be provided. 

14 C.F.R. § 91.9 (b) (2): Civil Aircraft Flight Manual in the Aircraft. 

Section 91.9(b)(2) 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. 5

(3) The UAV, given its size and configuration 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 maintained by keeping the flight manual at the ground control point 

where the operator flying the UAV will have immediate access to it. The FAA has issued the following 

exemptions to this regulation: Exemption Nos. 8607, 8737, 8738, 9299, 9299A, 9565, 95658, 10167, 

10167A, 10602, 32827, and 10700. 

14 C.F.R. § 91.103: Preflight action 

This regulation requires each operator 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 Procedures. The operator will take all actions 

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

performance data before initiation of flight. 

14 C.F.R. §91.109: Flight instruction: 

Section 91.103 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. 

UAV’s and remotely piloted aircraft, by their design do 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 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 provided by the fact that neither a pilot nor passengers 
will be carried in the aircraft and by the size and speed of the aircraft. 

14 C.F.R. §91.119: Minimum safe altitudes 

Section 91.119 establishes safe altitudes for operation of civil aircraft. Section 91.119 (d) allows 

helicopters to be operated at less than the minimums prescribed, provided the person operating the 

helicopter complies with any route or altitudes prescribed for helicopters by the 

FAA. 

As this exemption is for a UAV that is a helicopter and the exemption requests authority to operate at 

altitudes up to 400 AGL, an exemption may be needed to allow such operations. 

As set forth herein, except for the limited conditions stated in the Procedures, the UAV will never operate 

at higher than 400 AGL. 

The equivalent level of safety will be achieved given the size, weight, and speed of the UAV as well as the 

location where it is operated. In addition, the low-altitude operations of the UAV will ensure separation 

between these small-UAS operations and the operations of conventional aircraft that must comply with 

Section 91.119. 

14 C.F.R. §91.121 Altimeter Settings 

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

available within 100 NM of the aircraft. The sUAS will always fly below 400 feet AGL and will not need to 

maintain cruising altitudes in order to prevent conflict with other aircraft. An Above Ground Level 

altimeter measurement above the takeoff point is transmitted via radio from the sUAS on-board computer 

to the display screen held by the PIC, providing a constantly updated AGL readout. 

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

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

there is enough fuel to fly to the first point of intended landing and to fly after that for at least 30 minutes. 

We feel the intention of this paragraph is to provide an energy reserve as a safety buffer for delays to 

landing. The sUAS are battery operated and the maximum duration of flight from a single battery charge is 

12-45 (depending on which sUAS) minutes with a 20% reserve. Since the aircraft will never fly more than 

1/2 NM from the point of intended landing, a full battery charge at launch will ensure that we meet the 

reserve energy requirement of this paragraph. 

Applicant believes that an exemption from 14 CFR §91 .151 (a) falls within the scope of prior exemptions. 

See Exemption 10673 (allowing Lockheed Martin Corporation to operate without compliance with FAR 

91.151 (a)). Operating the small UAS, in a tightly controlled area, 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 UAS.

We request an exemption to the word "fuel" and ask for an equivalent interpretation with the word 

"energy". We also request exemption from the 30 min reserve and ask that our reserve will be to fly the 

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

exemptions have been granted to other operations, including Exemptions 2689F, 5745, 10673, and 10808. 

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

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. 

The UAV fully loaded weighs no more than 55 lbs and is operated without an on board pilot. As such, there 

is no ability or place to carry certification and registration documents or to display them on the UAV. An 

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

the operator flying the UAV will have immediate access to them, to the extent they are applicable to the 

UAV. 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 C.F.R. §91.215: ATC transponder and altitude reporting equipment and use

This regulation states all aircraft operating within 30 nautical miles of class A, B and C airspace must be 

equipped with automatic pressure altitude reporting equipment having a Mode C capability that 

automatically replies to Mode C interrogations. Due to the small size and lifting capabilities of our UASs we

cannot carry a traditional transponder. All of our operations will be under 250’ if we are operating within 

the 30mi reach of a mode c veil. 

14 C.F.R. §91.405 (a); 407 (a) (1); 409 (a) (2); 417(a) & (b): Maintenance Inspections 

These regulations require 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." and 

others shall inspect or maintain the aircraft in compliance with Part 43. 

Given that these section and Part 43 apply only to aircraft with an airworthiness certificate, these sections 

will not apply to the applicant. The operator will accomplish maintenance pursuant to the flight manual 

and operating handbook as referenced in the Procedures. An equivalent level of safety will be achieved 

because these small UAV’s are very limited in size and will carry a small payload and operate only in 

controlled areas for limited periods of time. If mechanical issues arise the UAV can land immediately and 

will be operating from no higher than 400 feet AGL. The operator will ensure that the UAV is in working 

order prior to initiating flight, perform required maintenance, and keep a log of any maintenance 

performed. Moreover, 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. 

Pursuant to 14 C.F.R. Part 11, the following summary is provided for publication in the Federal Register, 

should it be determined that publication is needed. Applicant seeks an exemption from the following rules:

14 C.F.R. §21, subpart H; 14 C.F.R 45.23(b); 14 C.F.R. §§ 61.113(a) & (b); 91.7(a); 91.9(b) (2); 91.103(b); 

91.109; 91.119; 91.121; 91.151(a); 91.203(a) and (b); 91.215; 91.405 (a); 91.407 (a) (1); 91.409 (a) (2); 

91.409 (a) (2) and 91.417 (a) & (b) to operate commercially a small unmanned vehicle (55lbs or less) for 

the purpose of inspection, monitoring, mapping, and photographing attached equipment and engineering 

studies involving communication tower operations. 

Approval of exemptions allowing commercial operations of UAV’s will create a level of safety by reducing 

risk. Conventional tower structure inspections and associated tasks involve extreme risks to personnel 

physically climbing such structures and/or utilizing high rise equipment both of which create numerous 

and extreme risk to such personnel. In contrast, a UAV weighing fewer than 55 lbs. and powered by 

batteries eliminates virtually all of that risk. The UAV will carry no passengers or crew and, therefore, will 

not expose personnel to any of the risks described above. 

The operation of small UAV’s, weighing less than 55 lbs., conducted in the strict conditions outlined above, 

will provide a level of safety supporting the grant of the exemptions requested herein, including exempting

the applicant from the requirements of Part 21 and allowing commercial operations. These lightweight 

aircraft operate at slow speeds, close to the ground, and in a controlled environment. 
Privacy 

All flights will occur over private or controlled access property with the property owner's prior consent 

and knowledge. The granting of this exemption request will provide innovative safety operations. 

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

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

and national security - provide more than adequate justification for the grant of the requested exemptions 

allowing commercial operation of applicant's UAV in and pursuant to the Procedures appended hereto. 

Request for Blanket COA Approval 

On March 24, 2015, the FAA announced that it has implemented a new policy of granting "blanket" COAs to

applicants requesting exemptions from the Federal Aviation Regulations under Section 333 of the FAA 

Modernization and Reform Act of 2012. 

The Applicant hereby requests that a "blanket" COA that conforms to the terms set forth in 

https://www.faa.gov/news/updates/?newsId=82245 upon approval of AUAV’s exemption request. 

Respectfully, 

Dale Greer 

8200 Southwestern Blvd, 1303

Dallas, TX 75206

Phone: 1-469-569-4155 

Email: dmgreer@airmail.net