UAS Aerial Solutions, LLC

5715 Oak Hollow Ln

Oviedo, FL 32765

386-385-8436

info@turbineaircraftlogistics.com

July 23, 2015 

U.S. Department of Transportation 

Docket Management System

1200 New Jersey Ave., SE

Washington, DC 20590

UAS Aerial Solutions Petition for Exemption to Operate Unmanned Aircraft 

Systems for the Purpose of Aerial Photography, Filming, Data Collection, and 

Training. 

FAA Regulatory Docket 

NAME AND ADDRESS OF PETITIONER

UAS Aerial Solutions 

Attn: Carson Wade Lee

5715 Oak Hollow Ln

Oviedo, FL 32765

386-386-8436

carson@uasaerialsolutions.com
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RECORD OF REVISIONS

Revision No. Revision Date Signature

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LIST OF AMENDMENTS

Pages Description

All Pages No Changes
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LIST OF EFFECTIVE PAGES

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TERMS OF REFERENCE:

1. Aircraft: any contrivance invented, used, or designed to navigate, or fly in, the air 

(Title 49, United States Code (49 USC) § 40102) 

2. National Airspace System (NAS): the common network of U.S. airspace; air navigation 

facilities, equipment and services, airports or landing areas; aeronautical charts, 

information and services; rules, regulations and procedures, technical information, 

and manpower and material 

3. Operational Control: with respect to a flight, means the exercise of authority over 

initiating, conducting or terminating a flight (14 CFR § 1.1) 

4. Pilot in Command (PIC): the person who has final authority and responsibility for the 

operation and safety of the flight; has been designated as PIC before or during the 

flight; and holds the appropriate category class and type-rating, if appropriate, for 

the conduct of the flight (14 CFR § 1.1) 

5. Unmanned aircraft (UA): any aircraft that is operated without the possibility of direct 

human intervention from within or on the aircraft (P.L. 112-95, Section 331) 

6. Unmanned Aircraft System (UAS): an unmanned aircraft and associated elements, 

including communication links and the components that control the unmanned 

aircraft, that are required for the pilot in command to operate safely and 

efficiently in the national airspace system (P.L. 112-95, Section 331) 

7. UAS Certificate of Waiver or Authorization (COA): an authorization issued by the Air 

Traffic Organization to an operator for a specific unmanned aircraft activity 

8. Visual Line of Sight (VLOS): unaided (corrective lenses and/or sunglasses excepted) 

visual contact between a pilot in command and an unmanned aircraft sufficient to 

maintain safe operational control of the aircraft, know its location, and be able to 

scan the airspace in which it is operating to see and avoid other air traffic or 

objects aloft or on the ground 

9. Above Ground Level (AGL)

10. Visual Flight Rules (VFR) 
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Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012, UAS Aerial 

Solutions seeks to be exempted from the following Federal Aviation Regulations:

Pub. L. No. 112-95 (2012), 126 Stat. 11 (“Section 333”) and the Federal Aviation 

Administration’s (“FAA”) general exemption authority under 49 U.S.C. § 44701(f), UAS 

Aerial Solutions (“Petitioner or Operator”) hereby petitions for exemptions from 14 

C.F.R. Part 21, 14 C.F.R. §§ 91.7(a), §§ 91.9(b)(2), §§ 91.103(b)(2), §§ 91.105, §§

91.109, §§ 91.119(c), §§ 91.121, §§ 91.151, §§ 91.405(a), §§ 91.407, §§ 91.409(a)(1) §§

91.409(a)(2), and §§ 91.417(a) & (b).

Specific sections of 14 CFR from exemption is needed 

• FAR 21 (Certification procedures) 

• FAR 91.103(b)(2) (Preflight action)

• FAR 91.105 (Flight crewmembers at stations)

• FAR 91.109 (Flight Instruction)

• FAR 91.119(c) (Minimum safe altitudes)

• FAR 91.121 (Altimeter settings) 

• FAR 91.151 (Fuel requirements)

• FAR 91.405(a) (Maintenance Required)

• FAR 91.409(a)(1) and (a)(2) (Inspections)

• FAR 91.417 (Maintenance records)

14 C.F.R. 21 – Subpart H Certification Procedures for products and parts, 

Airworthiness Certificates

UAS Aerial Solutions seeks exemption from 14 C.F.R. 21 – Subpart H: Certification 

Procedures/Airworthiness Certificates. we seek exemption from this FAR because the 

FAA has not yet set a certification standard for UAS. The UASs that will be operated

under the exemption will be less then 55lbs, fly’s at speeds under 87 KTS, does not carry 

flammable fuels or explosives, carries no pilot or passengers, and operates within a 

secured area within the limits set forth under approved COAs. 

14 C.F.R. 91.103(b)(2) Preflight Action

UAS Aerial Solutions seeks exemption from 14 C.F.R. 91.103(b)(2) which states that 

each pilot in command shall, before beginning a flight, become familiar with all available 

information concerning that flight. We are seeking this exemption because the preflight 

action required under FAR 91.103(b)(2) that is applicable to manned aircraft is not 

applicable to UAS. UAS Aerial Solutions will preform preflight action prior to flight by

use FAA approved weather sources to review weather conditions. Operations will only be 

in VFR conditions. Aircraft operated by UAS are capable of vertical takeoff and landing, 

not require a runway. We will be using performance data contained within the 

manufactures user manual.
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14 C.F.R. 91.105 – Flight Crewmembers at Stations

UAS Aerial Solutions seeks exemption from 14 C.F.R. 91.105 because a UAS is not 

equipped with a crewmember station. The UAS is piloted from the ground with VLOS of 

a PIC and VO by direct control via wireless transceiver by the PIC. 

14 C.F.R. 91.109 – Flight Instruction

UAS Aerial Solutions seek exemption from 14 C.F.R. 91.109 because UAS are not 

configured to have dual controls. Because the FAA has not yet created rules pertaining to 

UAS flight instructors, we are requesting that our experienced UAS pilots can preform 

instruction to qualify our new pilots on our UAS. 

14 C.F.R. 91.119 – Minimum Safe Altitudes

UAS Aerial Solutions seeks exemption from 14 C.F.R. 91.119 due to COA restriction on 

operations at altitudes that would allow compliance with 91.119. Safe operations of UAS 

depends on operators conducting operations below altitudes that manned aircraft are 

operating in, as a sense and avoid solution has not yet been developed. All of our UAS 

operations will be conducted at altitudes below 400ft AGL, or at or below attitudes as 

allowed under the COA used for operations. 

14 C.F.R. 91.121 – Altimeter Settings

UAS Aerial Solutions seeks exemption from 14 C.F.R. 91.121 because UAS do not use 

traditional barometric altimeters to calculate altitude. Our UAS’s, when the motors first 

start, the altitude readout on the controller, viewable by the pilot, is automatically set to 0 

feet AGL. Altitude by the UAS is consistently calculated and displayed to the pilot via 

the controller by both GPS data and barometric aiding. All rules currently pertaining to 

UAS are applicable in AGL attitudes, therefor, good cause exist for exemption from this 

regulation. 

14 C.F.R. 91.151 – Fuel Requirements for Flights in Visual Flight Rules (VFR) 

Conditions

UAS Aerial Solutions seeks exemption from 14 C.F.R. 91.151 due to the typical 

restrictions on flight time due to battery capacity. Most UAS’s we will operate will have 

battery endurance of 30 minutes or less. Because the UAS always is within line of sight 

from its takeoff location, the time to return to that location to land is no more then 3 

minutes. We will begin navigating the UAS to it’s landing location when the battery level 

reaches 30% capacity, the UAS will be landed prior to the battery level reaching 20%. In 

the event the pilot failed to have the UAS landed by 20% battery capacity, the system 

will automatically initiate safe landing sequence and return to the marked landing 
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location and auto land. Note: the automatic safe landing sequence can be interrupted 

anytime by the PIC and manually landed under to control of the PIC. 

14 C.F.R. 91.405, 91.407, 91.409, and 91.417 – Maintenance Required, Operations

after maintenance, Inspections, maintenance records.

UAS Aerial Solutions seeks exemption from 14 C.F.R. 91.405, 91.407, 91.409, and 

91.417 because the FAA has developed no required maintenance inspection standard, 

inspection interval, or authorized personnel to preform maintenance for UAS. We are 

asking to use manufacture recommended maintenance practices and inspection intervals 

in lieu of regulations that pertain to manned aircraft. We are asking that our PICs be 

allowed to preform maintenance and inspections in accordance with the manufactures 

user or maintenance manual. Our PICs will record maintenance in a paper or electronic 

airframe logbook in a format that complies with FAR 91.417 (a)(1).

Public Best Interest

UAS!Aerial!Solutions believes!with!exemption!from!the!requested!regulations!it!can!

serve!the!public!best!interest!by!providing!filming!and!data!collection services!at!a!

fraction!of!the!cost!that!would!exist!preforming!the!same!services!in!manned!

aircraft.!With!helicopter!rental!cost!well!over!two!hundred!dollars!per!hour,!using!a!

UAS!will!accomplish!these!same!tasks!with!more!then!a!98%!reduction!is!operating!

cost.!The!public!will!befit!from!this!because the!end!consumer!will!be!charged!

considerably!less!for!a!better!quality!product.!Safety!is!the!top!goal!of!UAS!Aerial!

Solutions and!the!pubic!as!a!whole.!We!can!offer!services!in!a!much!safer!manner!to!

the!public!with!our!unmanned!aircraft!then!we!could!with!our!manned!aircraft.!If!

the!service!we!provide!was!accomplished!in!a!manned!helicopter,!the!risk!of!flying!

at!low!attitudes!inherently!increases!the!risk!to!the!public!in!the!event!of!a!

mechanical!difficulty.!The!UAS!has!very!few!moving!parts,!greatly!decreasing!the!

likelihood!of!a!mechanical!failure.!However,!even!in!the!event!of!a!mechanical!

problem!with!a!UAS,!the!likelihood!of!damage!or!injury!to!persons!or!property!is!

very!low!due!to!the!UAS’s!very!light!weight!(under!55lbs),!no!flammable!fuels!

carried!on!board,!and!plastic!propellers.!This!exemption!can!also!be!found!in!public!

interest!as!it!is!very!quite!comparatively!to!a!manned!aircraft,!low!energy!usage,!and!

zero!carbon!emissions.!

The reasons why granting the exemption would not adversely affect safety, or how 

the exemption would provide a level of safety at least equal to that provided by the 

rule from which you seek the exemption.

Equivalent(Safety(to(Regulations(Pertaining(to(Manned(Aviation(

UAS!Aerial!Solutions is!uniquely!capable!of!providing!a!level!of!safety!at!least!equal!

to!that!provided!by!the!rule!from!which!we!seek!an!exemption. Below!are!
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qualifications!and!procedures!that!show!the!ability!to!operate!UAS!with!an!

equivalent!level!of!safety!to!manned!aircraft:

• Carson!Lee,!the!chief!pilot!for!both!manned!and!UAS!operations!at!UAS!Aerial!

Solutions,!has!13!years!of!manned!aviation!experience!with!over!5000!hours!

of!flight!time!accrued!in!manned!aircraft!and!hundreds!of!hours!piloting UAS!

for!hobby!use. Carson!also!holds!an!FAA!Flight!Instructor!certificate!for!

single/multi!engine!and!instrument. Carson!also!holds!a!FAA!issued Airframe!

&!Powerplant!mechanic!certificate!with!Inspection!Authorization.!

• Because!the!FAA!has!not!developed!inspection!and!repair!methods!with!UAS,!

we!will!follow!the!manufactures!recommendation!for!inspection!intervals!

and!repair.

• UAS,!while!highly!technically!advanced,!are!very!simple!in!design!with!very!

few!moving!parts reducing!to!possibility!of!failure.!

• The!UAS we!will!operate is!capable!in!the!event!of!lost!link!to!return!to!a!

designated!safe!location!and!auto!land.!

• Return to designated point automatically with a low battery that is dynamically 

updated depending on UAS distance from the designated landing point.

• Most of the UAS we will operate will weigh less then 10lbs, however none of our 

UAS will weigh over 55lbs including payload.

• No flammable fuels carried onboard.

• UAS flights will be conducted in VFR conditions.

• UAS flight operations will be conducted during daylight hours.

• PICs designated will have accrued 25 hour total time operating UAS, with a 

minimum of 5 hours in make and model of UAS to be used for commercial 

operation.

• UAS flights will terminate before the battery has reached 20% capacity

• A pre-flight inspection will be conducted of the UAS prior to each flight in 

accordance with manufactures recommendation.

• UAS will be conducted 400 feet and below AGL, under altitudes of manned 

aircraft operations.

• UAS operations will not be conducted within 500 feet of nonparticipating 

persons, vessels, vehicles, or structures without permission from those persons or 

owners. 

• The operator to insure PICs are complying with the operations manual and 

exemption requirements logs all UAS flights that can be reviewed by 

management to insure safe operations. 

• Prior to UAS flight, we will review FAA aeronautical sectional charts and airport 

facility directory to insure that no flight operation will come within 5NM of an 

airport with a control tower, 3NM of an airport not having an operational control 

tower but having a published instrument approach procedure, 2NM of an airport 

not having an operational control tower or instrument approach procedure, or 
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2NM of a heliport having an instrument approach procedure without having an 

appropriate authorization from the ATC controlling facility and airport manager.

• All UAS operation will be conducted within VLOS from the PIC and VO

• We!are!highly!filmier!with!FARs,!aeronautical!charts,!NOTAM!research!and!

filing,!TFRs,!etc.!!We!will!conduct!preflight!planning!to!review!all!necessary!

information,!including!but!not!limited!to:!reviewing!VFR!sectionals!to!insure!

remaining!clear!of:!prohibited/restricted/MOAs/warning!areas;!airspace!

other!then!class!G!(unless!a!COA!has!been!granted).!Review!of!TFRs,!

NOTAMs,!and!submitting!a!NOTAM!for!our!proposed!flight!as!required.!
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I. Petition Summary

If granted, this exemption would allow pilots named in UAS Aerial Solutions operations

manual to act as PICs to operate small UAS (under 55lbs) with an attached camera and or 

sensors for the purpose of aerial photography, filming, data collection, and training. With 

a combination of factors below, the operator can operate the UAS in a manner equal to 

the safety standards set forth by the FARs for civilly manned aircraft: 

• No flammable fuels with be carried 

• Return to designated point in the event of a lost control link

• Return to designated point automatically with a low battery that is dynamically 

updated depending on UAS distance from the designated point

• Low weight (under 55LBS)

• Slow speed

• No passengers to be carried

• Experienced crew members

• Stringent maintenance program 

The operator will be operating the UAS for the purpose of providing photographs, video, 

data collection, and training to the public on an on demand bases. The safety that can be 

achieved operating a small (under 55lbs), carrying no passengers or crew, carrying no 

flammable fuels, and no pollution from operation, can be found to be in public interest. 

II. Exemptions Requested

The operator is requesting relief from the following FAA regulations:

• FAR 21 (Certification procedures) 

• FAR 91.103(b)(2) (Preflight action)

• FAR 91.105 (Flight crewmembers at stations)

• FAR 91.109 (Flight Instruction)

• FAR 91.119(c) (Minimum safe altitudes)

• FAR 91.121 (Altimeter settings) 

• FAR 91.151 (Fuel requirements)

• FAR 91.405(a) (Maintenance Required)

• FAR 91.409(a)(1) and (a)(2) (Inspections)

• FAR 91.417 (Maintenance records)

III. Unmanned Aircraft Systems

UAS Aerial Solution intends to operate both the DJI Inspire 1, as well as the DJI 

Phantom 3 Professional & Advanced. UAS Aerial Solutions will comply with the pre-
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flight procedures, flight operations, and maintenance procedures detailed in the following 

documents that will be attached to this exemption request:

UAS Aerial Solutions Operations Manual

Inspire 1 User Manual v1.2

Inspire 1 Maintenance Manual v1.0

Inspire 1 Safety Guidelines v1.0

Phantom 3 Professional User Manual v1.2

Phantom 3 Advanced User Manual v1.2

Phantom 3 Safety Guidelines v1.0

IV. Operational Procedures DJI Inspire 1

1.1 The UAS the operator seeks exemption for is manufactured DJI and the model 

is the Inspire 1 is a 6.47lb multi-rotor (4 rotors) UAS with approximately 18

minutes of endurance. The Inspire 1’s purpose is to carry a small camera as its

payload. The Inspire 1 has the ability to be controlled by a single crewmember

acting as pilot in command by wireless remote control on a 2.4GHz band 

having a transmitting distance of 2km (1.08nm). 

1.2 The Inspire 1 UAS is equipped with lost link protection (referred to as 

“Return To Home” (RTH) in the Inspire 1 User Manual), allowing the UAS to 

automatically climb vertically to a safe altitude to clear obstacles; then 

proceed to a pre-designated point to automatically land. At anytime the UAS 

and the controller reestablish link, the PIC can cancel the RTH and resume 

control of the UAS. In the event of lost GPS signal, control to the Inspire UAS 

is not lost. Since all operations will be conducted under Visual Line of Sight 

VLOS the PIC can control the aircraft back to a safe location to land. 

1.3 Because the Inspire 1 UAS does not have the endurance to meet the 

requirements of FAR 91.155(b), the operator is requesting exception from this 

regulation and substituted with the following standard: All flights will be

terminated at or prior to the battery level reaching 20%.

1.4 The operator will register the UAS IAW FAR part 47. The operator’s UAS 

will have identification makings in accordance with FAR 45(c). The Inspire 1 

UAS is too small to practically display registration markings IAW FAR 

45.29(a) though (e). The registration marks will be affixed as large as practical 

IAW FAR 45.29(f).

1.5 The operator is requesting relief from FAR 91.121 because the Inspire 1 UAS 

is not equipped with a standard adjustable barometric altimeter system. The 

Inspire 1 UAS collects altitude information from two sources: GPS and 

barometric aiding. Upon powering one the Inspire 1, the system will reset the 

altitude readout on the controllers base station to 0 feet above ground level 

(AGL). The PIC then will reference the digitally displayed altitude on the 

controller in AGL for the duration of the flight.
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1.6 Because of the small size, low weight, slow speed, and limited operating area 

of the Inspire 1 UAS, the operator is requesting relief from CFR part 21(h) 

(airworthiness certificates). The operator has determined that it can operate 

the Inspire 1 or Phantom UAS to an equivalent level of safety set forth under 

part 21 of the CFRs and meets the requirements set forth in the 333 

exemption.

1.7 Prior to flight the Inspire 1 UAS will be determined to be in an airworthy 

condition IAW the pre-flight checklist outlined in attached Inspire 1 User 

Manual V1.0. The operator is requesting exemption from required inspections 

of FAR 91.409(a)(1) and (2) and will adopt the manufactures recommended 

inspections program as outlined in the attached Inspire 1 Maintenance Manual 

v1.0. Because the FAA has not established an inspection standard for UAS as 

have been established for manned aircraft under FAR 43.13 appendix D, the 

operator is requesting an exemption from the maintenance scope and detail of 

FAR 43.13 appendix D and replaced with the manufactures recommended 

maintenance program detailed in the attached Inspire 1 Maintenance Manual 

v1.0. The operator will follow the manufactures recommended inspection 

interval to preform comprehensive maintenance of the Inspire 1 every 50 

flight hours or 200 flights, whichever comes first. 

1.8 The operator will adopt maintenance record requirements set forth under FAR 

91.417. Maintenance and inspection records will be maintained in a single 

airframe paper or digital logbook. 

1.9 The DJI Inspire UAS operates on the 2.4GHz frequency band for both UAS 

control as well as video downlink. Both the Inspire 1 UAS as well and the 

UAS remote controller comply with part 15 of the FCC rules (see page 

appendix A, page 62 of the DJI Inspire user manual). The Inspire 1 is 

equipped with a vision positioning system along with a sonar system in order 

to be able to fly inside a building and still remain stable. The Inspire 1’s 

primary payload is a small X3 model FC350 camera mounted with a Zenmuse 

X3 gimbal. 

1.10 Refer to the attached Inspire 1 User Manual V1.0 for more detail on the 

Inspire 1 UAS.

2. IV. Operational Procedures Phantom 3 Professional and Advanced

2.1 The UAS the operator seeks exemption for is manufactured by DJI and the 

models are the Phantom 3 profession and Advanced. The DJI Phantom 3 is a 

2.82lb multi-rotor (4 rotors) UAS with approximately 23 minutes of 

endurance. The Phantom 3’s purpose is to carry a small camera as its payload. 

The Phantom 3 has the ability to be controlled by a single crewmember acting 

as pilot in command by wireless remote control on a 2.4GHz band having a 

transmitting distance of 2km (1.08nm). 

2.2 The Phantom 3 UAS is equipped with lost link protection (referred to as 

“Return To Home” (RTH) in the Phantom 3 User Manual), allowing the UAS 

to automatically climb vertically to a safe altitude to clear obstacles; then 
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proceed to a pre-designated point to automatically land. At anytime the UAS 

and the controller reestablish link, the PIC can cancel the RTH and resume 

control of the UAS. In the event of lost GPS signal, control to the Inspire UAS 

is not lost. Since all operations will be conducted under Visual Line of Sight 

VLOS the PIC can control the aircraft back to a safe location to land. 

2.3 Because the Phantom 3 UAS does not have the endurance to meet the 

requirements of FAR 91.155(b), the operator is requesting exception from this 

regulation and substituted with the following standard: All flights will be 

terminated at or prior to the battery level reaching 20%.

2.4 The operator will register the UAS IAW FAR part 47. The operator’s UAS 

will have identification makings in accordance with FAR 45(c). The Phantom 

3 UAS is too small to practically display registration markings IAW FAR 

45.29(a) though (e). The registration marks will be affixed as large as practical 

IAW FAR 45.29(f).

2.5 The operator is requesting relief from FAR 91.121 because the Phantom 3

UAS is not equipped with a standard adjustable barometric altimeter system. 

The Phantom 3 UAS collects altitude information from two sources: GPS and 

barometric aiding. Upon powering one the Phantom 3, the system will reset 

the altitude readout on the controllers base station to 0 feet above ground level 

(AGL). The PIC then will reference the digitally displayed altitude on the 

controller in AGL for the duration of the flight.

2.6 Because of the small size, low weight, slow speed, and limited operating area 

of the Phantom 3 UAS, the operator is requesting relief from CFR part 21(h) 

(airworthiness certificates). The operator has determined that it can operate 

the Phantom 3 UAS to an equivalent level of safety set forth under part 21 of 

the CFRs and meets the requirements set forth in the 333 exemption. 

2.7 Prior to flight the Phantom 3 UAS will be determined to be in an airworthy 

condition IAW the pre-flight checklist outlined in attached Phantom 3 User

Manual V1.0. The operator is requesting exemption from required inspections 

of FAR 91.409(a)(1) and (2). DJI had not yet published a maintenance manual 

for the Phantom 3 UAS, however after review by our Airframe and 

Powerplant mechanic with Inspection Authorization, we have determined that 

DJI’s Inspire 1 Maintenance Manual can be adopted without any changes and 

archive the appropriate level of safety. We are requesting approval to adopt 

the inspection checklist outlined in the Inspire 1 Maintenance Manual for our 

Phantom 3 UAS. Because the FAA has not established an inspection standard 

for UAS as have been established for manned aircraft under FAR 43.13 

appendix D, the operator is requesting an exemption from the maintenance 

scope and detail of FAR 43.13 appendix D and replaced with the 

manufactures recommended maintenance program detailed in the attached 

Inspire 1 Maintenance Manual v1.0. The operator will follow the 

manufactures recommended inspection interval to preform comprehensive 

maintenance of the DJI Phantom every 50 flight hours or 200 flights, 

whichever comes first. 
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2.8 The operator will adopt maintenance record requirements set forth under FAR 

91.417. Maintenance and inspection records will be maintained in a single 

airframe paper or digital logbook. 

2.9 The DJI Inspire UAS operates on the 2.4GHz frequency band for both UAS 

control as well as video downlink. Both the Phantom 3 UAS as well and the 

UAS remote controller comply with part 15 of the FCC rules (see page 

appendix A, page 62 of the DJI Inspire user manual). The Phantom 3 is 

equipped with a vision positioning system along with a sonar system in order 

to be able to fly inside a building and still remain stable. The Phantom 3’s 

primary payload is a small Sony EXMOR camera mounted with a gimbal. 

2.10 Refer to the attached Phantom 3 User Manual V1.2 for more detail on the 

Phantom 3 UAS.

3. Unmanned Aircraft PIC

3.1 The operator has designated Carson Wade Lee, Airline Transport Pilot (ATP) 

as the chief pilot for its UAS operations. Carson currently holds 13 years of 

flight experience with over 5000 flight hours in manned aircraft. Carson holds

an Airline Transport Pilot Certificate for both single and multi-engine land 

aircraft. Carson also holds an Airframe & Powerplant FAA mechanic 

certificate with Inspection Authorization under FSDO-15. Carson also has 3

years of experience with hundreds of hours operating UAS for recreational 

use.

3.2 The operator is requesting that the operators chief UAS pilot be allowed to 

designate any UAS pilot to act as a PIC for UAS Aerial Solutions with the 

following experience requirements:

• Hold an FAA sport, recreational, private, commercial, or airline transport pilot 

certificate.

• Hold a state issued drivers license or a FAA first, second, or third class medical. 

• Meets the flight review requirements of FAR 61.56.

• Meets the recent flight experience for PIC of FAR 61.57 (UAS takeoff/landings)

• Has accrued 25 hour total time operating UAS

• Has a minimum of 10 hours operating similar model UAS.

• Has a minimum of 5 hours make and model of UAS

3.3 The PIC will designate a Visual Observer (VO) prior to any flight to be 

conducted. Any VO to be used by the PIC must be authorized by the UAS 

chief pilot. Further, the VO shall be familiar with UAS operations to the 

extent their designated role as VO requires. The VO will be require to be able 

to communicate with the PIC verbally at all times. 

3.4 It will be the PICs responsibility to review weather conditions, flight battery 

requirements, and UAS performance limitations prior to conducting the flight.
UAS Aerial Solutions

333 Exemption

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Federal!copyright!law!prohibits!unauthorized!reproduction!by!any!means

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4. UAS Operating Procedures

4.1 All UAS flight operations will be conducted during daylight hours.

4.2 All UAS operations will be conducted in VFR conditions.

4.3 No UAS operation will be conducted with less cloud clearance or visibly then 

is allowed by FAR 91.155. 

4.4 No UAS flight operations will be conducted beyond the visual sight of both 

the PIC and the VO.

4.5 No UAS flight operation will be conducted above a vertical height of 400ft 

AGL.

4.6 NO UAS flight operations will be conducted within highly populated areas.

4.7 The PIC will not fly the UAS at speeds to exceed 87KTS ground speed.

4.8 The PIC will insure that no person, other then those who agree to participate 

in the operation and are trained in UAS operational safety, are within 500ft of 

horizontal distance from the UAS during flight operations.

4.9 The PIC will insure that the UAS in flight comes no closer then 500ft of 

vehicles or structures, with the exception of those that are a part of the

operation. UAS Aerial Solutions will obtain a signed consent form from the 

owner or authorized representative of any vehicle or structure the UAS in 

flight will come within 500ft of.

4.10 Prior to any UAS flight operation the PIC will consult current FAA 

aeronautical sectional charts and airport facility directory to insure that no 

flight operation will come within 5NM of an airport with a control tower, 

3NM of an airport not having an operational control tower but having a 

published instrument approach procedure, 2NM of an airport not having an 

operational control tower or instrument approach procedure, or 2NM of a 

heliport having an instrument approach procedure without having an 

appropriate authorization from the ATC controlling facility and airport 

manager.

4.11 PIC will remain clear and yield right of way to all manned aircraft 

operations of all category and classes.

4.12 The PIC prior to conducting UAS flight operations will review current 

aeronautical charts, TFRs, and NOTAMS to insure that no flight operations 

will be conducted within an active restricted area, prohibited area, warning 

area, or TFR. 

4.13 Prior to UAS operations for the motion picture or television industry, the 

operator will comply with regulations set forth in FAA order 8900.1, Volume 

3, chapter 8, section 1 (Certificate of Waiver for Motion Picture and 

Television Filming).

4.14 Operator will obtain an Air Traffic Organization (ATO) certificate of 

waiver or authorization (COA) prior to conduction UAS operations that a 

COA is required.

4.15 Operator, as required by the COA, will request a NOTAM be filed for the 

UAS operation at least 48 hours in advance, but not more than 72 hours in 

advance.
UAS Aerial Solutions

333 Exemption

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Copyright!2015!by!UAS!Aerial!Solutions.!All!rights!reserved.!

Federal!copyright!law!prohibits!unauthorized!reproduction!by!any!means

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Additional(Information,(Views,(or(Arguments(to(Support(our(Request

Turbine!Aircraft!Logistics!views!our!long!experience!aviation,!working!closely!with!

the!local!FAA!FSDO!highly!qualifies!us!to!be!granted!exemption!from!the!requested!

FAR’s.!With!the!above!provided!information,!we!are!able!to!bring!a!far!higher!level!

of!safety!to!our!operations!that!few!section!333!exemption!holds!will!be!able!to!

offer.!With!our!manned!aircraft!relationship!with!the!FAA,!we!feel!confidant!we!will!

be!well!capable!of!adjusting!to!new!regulations!and!procedures!as!they!are!issued!by!

the!FAA.!

Exercising(the(Privileges(of(Requested(Exemption(Outside(the(United(States

UAS!Aerial!Solutions!at!this!time!is!not!seeking!to extend!the!privileges!of!this!

exemption!beyond!the boarders!of!the United!States!of!America.!

Sincerely,

Carson W. Lee

President

UAS Aerial Solutions, LLC