Wednesday, February 3, 2016

Andrew Collignon, AIA

625 Bakers Bridge Avenue

Suite 105

Franklin, Tennessee 37027

acollignon@me.com

Re: Exemption Request Pursuant to Section 333 of the FAA Reform Act and Part 11 of the 

Federal Aviation Regulations from: 14 CFR 21 subpart H; 14 CFR 45.23(b); 14 CFR 61.113(a) 

and (b); 14 CFR 91.7(a); 14 CFR91.9(b)(2); 14 CFR 91.103; 14 CFR 91.109; 14 CFR 91.119(c); 

14 CFR 91.121; 14 CFR 91.151(a); 14 CFR 91.203(a) and (b); 14 CFR 91.405 (a); 14 CFR 

91.407 (a) (1) 14 CFR 91.409 (a)(1) and (2); 14 CFR 91.417(a) and (b) 

Dear Sir or Madam:

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

and 14 CFR Part 11 of Unmanned Aircraft Systems (UAS), Andrew Collignon hereby applies for 

an exemption from the listed Federal Aviation Regulations ("FARs") to allow commercial 

operation of Designated UAS, provided such operations are conducted within and under the 

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

The requested exemption would permit Andrew Collignon (Petitioner), a registered Architect in 

the State of Tennessee, to provide services to clients using a small, advanced UAS in the 

following areas:

1. Aerial Photography and Videography

2. Site and Building Inspections

3. Site Surveying and Mapping

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

UAS as set forth in this document under conditions that would be a) limited b) controlled c) 

predetermined and d) safe. Approval of this exemption would increase public awareness of UAS 

operations and enhance safety to aid in fulfilling 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." 

The following contains the list of regulations from which the Petitioner is seeking exemption, and 

a complete list of responsibilities Petitioner assumes as operator; it also contains information 

regarding the aircraft, public benefit and safety features, and similar petitions requests granted.

Page 1 of 5 Andrew Collignon - Section 333 Exemption Request
Regulations from which exemption is requested:

14 C.F.R. Part 21

14 C.F.R. 45.23(b)

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

14 C.F.R. 91.7(a)

14 C.F.R. 91.9(b) (2)

14 C.F.R. 91.109

14 C.F.R. 91.119

14 C.F.R. 91.121

14 C.F.R. 91.151(a)

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

14 C.F.R. 91.205(b)

14 C.F.R. 91.215

14 C.F.R. 91.401 - 91.417

Specific UAS for which exemption is requested:

DJI T600 Inspire 1 UAS

Similar Grants of Exemption:

As 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 and to Allied Drones (see Docket No. FAA-2014-0804) demonstrate, an enhanced 

level of safety can be achieved using an unmanned aircraft System (UAS) with the 

specifications described by the Petitioner which carries no passengers or crew, rather than a 

manned aircraft of significantly greater proportions carrying crew and fuel. This gives the FAA 

good cause to find that the UAS operation enabled by this exemption is in the public interest. 

The Petitioner assumes the following responsibilities:

1. Operations authorized by this grant of exemption are limited to the DJI T600 Inspire 1 UAS 

when weighing less than 55 pounds including payload.

2. Operations for the purpose of closed-set motion picture and television filming are not 

permitted.

3. The UAS may not be operated at a speed exceeding 43.4 knots (50 miles per hour). The 

exemption holder may use either groundspeed or calibrated airspeed to determine compliance 

with the 50 knot speed restriction. In no case will the UAS be operated at airspeeds greater than 

the maximum UAS operating airspeed recommended by the UAS manufacturer.

4. The UAS may not be operated at an altitude of more than 400 feet (121.9 meters) above 

ground level (AGL).

5. The UAS must be operated within visual line of sight (VLOS) of the PIC at all times. This 

requires the PIC to be able to use human vision unaided by any device other than corrective 

lenses, as specified on the PIC’s FAA-issued airman medical certificate or U.S. driver’s license.

Page 2 of 5 Andrew Collignon - Section 333 Exemption Request
6. All operations must utilize a visual observer (VO). The UA must be operated within the visual 

line of sight (VLOS) of the PIC and VO at all times. The VO may be used to satisfy the VLOS 

requirement as long as the PIC always maintains VLOS capability. The VO and PIC must be 

able to communicate verbally at all times; electronic messaging or texting is not permitted during 

flight operations. The PIC must be designated before the flight and cannot transfer his or her 

designation for the duration of the flight. The PIC must ensure that the VO can perform the 

duties required of the VO.

7. This exemption and all documents needed to operate the UAS and conduct its operations in 

accordance with the conditions and limitations stated in this grant of exemption, are hereinafter 

referred to as the operating documents. The operating documents must be accessible during 

UAS operations and made available to the Administrator upon request. If a discrepancy exists 

between the conditions and limitations in this exemption and the procedures outlined in the 

operating documents, the conditions and limitations herein take precedence and must be 

followed. Otherwise, the operator must follow the procedures as outlined in its operating 

documents. The operator may update or revise its operating documents. It is the operator’s 

responsibility to track such revisions and present updated and revised documents to the 

Administrator or any law enforcement official upon request. The operator must also present 

updated and revised documents if it petitions for extension or amendment to this grant of 

exemption. If the operator determines that any update or revision would affect the basis upon 

which the FAA granted this exemption, then the operator must petition for an amendment to its 

grant of exemption. The FAA’s UAS Integration Office (AFS−80) may be contacted if questions 

arise regarding updates or revisions to the operating documents.

8. If UAS has undergone maintenance or alterations that affect the UAS operation or flight 

characteristics, e.g., replacement of a flight critical component, UAS must undergo a functional 

test flight prior to conducting further operations under this exemption. Functional test flights may 

only be conducted by a PIC with a VO and must remain at least 500 feet from other people. The 

functional test flight must be conducted in such a manner so as to not pose an undue hazard to 

persons and property.

9. The operator is responsible for maintaining and inspecting the UAS to ensure that it is in a 

condition for safe operation.

10. Prior to each flight, the PIC must conduct a pre-flight inspection and determine the UAS is in 

a condition for safe flight. The pre-flight inspection must account for all potential discrepancies, 

e.g., inoperable components, items, or equipment. If the inspection reveals a condition that 

affects the safe operation of the UAS, the aircraft is prohibited from operating until the 

necessary maintenance has been performed and the UAS is found to be in a condition for safe 

flight.

11. The operator must follow the UAS manufacturer’s maintenance, overhaul, replacement, 

inspection, and life limit requirements for the aircraft and aircraft components.

12. Each UAS operated under this exemption must comply with all manufacturer safety 

bulletins.

13. Under this grant of exemption, a PIC must hold either an airline transport, commercial, 

private, recreational, or sport pilot certificate. The PIC must also hold a current FAA airman 

medical certificate or a valid U.S. driver’s license issued by a state, the District of Columbia, 

Puerto Rico, a territory, a possession, or the Federal government. The PIC must also meet the 

flight review requirements specified in 14 CFR § 61.56 in an aircraft in which the PIC is rated on 

his or her pilot certificate.

14. The operator may not permit any PIC to operate unless the PIC demonstrates the ability to 

safely operate the UAS in a manner consistent with how the UAS will be operated under this 

exemption, including evasive and emergency maneuvers and maintaining appropriate distances 

Page 3 of 5 Andrew Collignon - Section 333 Exemption Request
from persons, vessels, vehicles and structures. PIC qualification flight hours and currency must 

be logged in a manner consistent with 14 CFR § 61.51(b). Flights for the purposes of training 

the operator’s PICs and VOs (training, proficiency, and experience-building) and determining the 

PIC’s ability to safely operate the UAS in a manner consistent with how the UAS will be 

operated under this exemption are permitted under the terms of this exemption. However, 

training operations may only be conducted during dedicated training sessions. During training, 

proficiency, and experience-building flights, all persons not essential for flight operations are 

considered nonparticipants, and the PIC must operate the UA with appropriate distance from 

nonparticipants in accordance with 14 CFR § 91.119.

15. UAS operations may not be conducted during night, as defined in 14 CFR § 1.1.

16. All operations must be conducted under visual meteorological conditions (VMC).

17. The UA may not operate within 5 nautical miles of an airport reference point (ARP) as 

denoted in the current FAA Airport/Facility Directory (AFD) or for airports not denoted with an 

ARP, the center of the airport symbol as denoted on the current FAA-published aeronautical 

chart, unless a letter of agreement with that airport’s management is obtained or otherwise 

permitted by a COA issued to the exemption holder. The letter of agreement with the airport 

management must be made available to the Administrator or any law enforcement official upon 

request.

18. If the UAS loses communications or loses its GPS signal, the UAS must return to a predetermined location within the private or controlled-access property.

19. The PIC must abort the flight in the event of unpredicted obstacles or emergencies.

20. The PIC is prohibited from beginning a flight unless (considering wind and forecast weather 

conditions) there is enough available power for the UA to conduct the intended operation and to 

operate after that for at least five minutes or with the reserve power recommended by the 

manufacturer if greater.

21. All aircraft operated in accordance with this exemption must be identified by serial number, 

registered in accordance with 14 CFR part 47, and have identification (N−Number) markings in 

accordance with 14 CFR part 45, Subpart C. Markings must be as large as practicable.

22. Documents used by the operator to ensure the safe operation and flight of the UAS and any 

documents required under 14 CFR §§ 91.9 and 91.203 must be available to the PIC at the 

Ground Control Station of the UAS any time the aircraft is operating. These documents must be 

made available to the Administrator or any law enforcement official upon request.

23. The UAS must remain clear and give way to all manned aviation operations and activities at 

all times.

24. The UAS may not be operated by the PIC from any moving device or vehicle.

25. All Flight operations must be conducted at least 500 feet from all nonparticipating persons, 

vessels, vehicles, and structures unless: a. Barriers or structures are present that sufficiently 

protect nonparticipating persons from the UA and/or debris in the event of an accident. The 

operator must ensure that nonparticipating persons remain under such protection. If a situation 

arises where nonparticipating persons leave such protection and are within 500 feet of the UA, 

flight operations must cease immediately in a manner ensuring the safety of nonparticipating 

persons; and b. The owner/controller of any vessels, vehicles or structures has granted 

permission for operating closer to those objects and the PIC has made a safety assessment of 

the risk of operating closer to those objects and determined that it does not present an undue 

hazard. The PIC, VO, operator trainees or essential persons are not considered nonparticipating 

persons under this exemption.

26. All operations shall be conducted over private or controlled-access property with permission 

from the property owner/controller or authorized representative. Permission from property 

owner/controller or authorized representative will be obtained for each flight to be conducted.

Page 4 of 5 Andrew Collignon - Section 333 Exemption Request
27. Any incident, accident, or flight operation that transgresses the lateral or vertical boundaries 

of the operational area as defined by the applicable COA must be reported to the FAA's UAS 

Integration Office (AFS−80) within 24 hours. Accidents must be reported to the National 

Transportation Safety Board (NTSB) per instructions contained on the NTSB Web site: 

www.ntsb.gov.

Additional Information:

The Petitioner’s assumed responsibilities (listed above) adequately satisfy criteria provided in 

Section 333 of the Reform Act of 2012, providing sufficient justification for the granting of the 

Petitioner's UAS Exemption.

Petitioner is a student pilot with 43.3 flight hours as of the writing of this application. Petitioner 

has passed his written exam and anticipates taking his check ride in the near future.

As an Architect, the public safety benefits from use of a UAS are numerous and include 

documenting existing and ongoing building and site conditions in an economical and safe 

manner.

As a photographer and videographer, the creative and documentary benefits are unique to the 

use of UAS.

Petitioner respectfully requests the FAA grant its request for exemption without delay.

Sincerely,

Andrew Collignon, AIA

625 Bakers Bridge Avenue

Suite 105

Franklin, Tennessee 37027

acollignon@me.com

Page 5 of 5 Andrew Collignon - Section 333 Exemption Request