U. S. Department of Transportation Docket Management System 1200 New Jersey Ave., SE Washington, 

DC 20590 

Re: Exemption Request Section 333 of the FAA Reform Act and Part 11 of the Federal Aviation 

Regulations 

Dear Sir or Madam: 

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

E. Rivera, (the “Applicant”), planned operator of Small Unmanned Aircraft Systems (“sUAS”) seeks an 

exemption from Federal Aviation Regulations (“FARs”) listed below and discussed in Appendix A. 

Attached, as Appendix C, is a summary of this request. 

The requested exemption would allow the Applicant to safely, efficiently, and economically use 

commercial sUAS in the National Airspace System (NAS), 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. 

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

commercial operations with sUAS that will provide the following benefits: 

1. Commercial use of sUAS to perform aerial acquisition and research in support of government entities, 

agriculture industry, utility companies, local infrastructure, scientific studies, wildlife monitoring, mining, 

surveying, forestry, and much more. All of which are critical to the well-being of the general public. 2. 

The use of sUAS will decrease congestion in the NAS along with reducing the noise and air pollution 

generated during traditional manned aircraft flight operations. 3. Operation of sUAS will substantially 

reduce the risk to life and property in the air, and on the ground, which is commonly associated with 

traditional manned aircraft flight operations. 4. Similar to the current manned aircraft flight operations 

that have been conducted for many decades, sUAS used for similar tasks will not generate any new 

privacy issues. 

Approval of this exemption would thereby enhance safety and fulfill the Secretary of Transportation’s 

(the FAA Administrator's) responsibilities under Section 333(c) of the Reform Act to "establish 

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

The name and address of the applicant are: 

Attn: Thomas E. Rivera Ph: 610-937-9909 Email: tom.rivera@outlook.com Address: 473 Glenn Rose 

Circle, King of Prussia, PA 19406

The regulations from which the exemption is requested are as follows: 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. 61.133(a); 14 C.F.R. 91.7(a); 14 C.F.R. 91.9(b)(2) & (c); 14 

C.F.R. 91.103; 14 C.F.R. 91.109(a); 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. 91.405(a); 14 C.F.R. 

91.407(a)(1); 14 C.F.R. 91.409(a)(2); 14 C.F.R. 91.417(a) 
Appendix A discusses each rule listed above and explains why exemptions pursuant to the proposal set 

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

 

QUALIFICATION FOR APPROVAL UNDER SECTION 333 OF THE REFORM ACT 

The proposed operations in this petition for exemption qualify for expedited approval under Section 333 

of the Reform Act. Each of the statutory criteria and other potentially relevant factors are satisfied. 

The proposed operations would permit the use of small and relatively inexpensive UAS under controlled 

conditions in airspace that is: (1) limited; (2) predetermined; (3) controlled as to access, and; (4) would 

provide an increased level of safety beyond that existing when fixed or rotor wing aircraft are used to 

accomplish the same purpose. 

The sUAS's planned to be operated are rotorcraft and fixed wing aircraft, each weighing 15 lbs. or fewer 

including payload. They would operate, under normal conditions, at a speed of no more than 50 knots. 

The principal construction material of the sUAS aircraft would typically be foam and/or plastic. 

Operations will be performed by a qualified sUAS Pilot in Command (PIC), as outlined below, to 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 sUAS involved and the pre-planned environment within which they will operate, the 

applicant believes that these operations fall 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 

sUAS to commence immediately. Also, due to the size of the sUAS and the pre-defined, restricted area 

in which the sUAS will operate, approval of the application presents no national security issue. The 

operation of sUAS by knowledgeable professionals will serve to enhance safety, add to the public 

benefit, and reduce environmental impacts related to current methods of manned aircraft flight 

operations. 

These limitations and conditions to which the operator, or its employees, acting as sUAS PIC agrees to 

be bound when conducting commercial operations under an FAA issued exemption: 

1. Safety will be the first and foremost consideration in any sUAS operation. 2. The sUAS pilot will have, 

at a minimum, a third class medical certificate and completed FAA private ground instruction and passed 

the FAA private pilot written examination or FAA recognized equivalent. 3. The sUAS pilot will be 

considered Pilot in Command (PIC), whether flying or supervising, and will be responsible for safe 

operation of the flight. 4. Flights will be operated within line of sight of the PIC and/or an observer. 5. 

The sUAS will weigh less than 15 lbs. total. 6. Flights will be operated in Class G airspace whenever 

possible. If operation in other airspace is required, the relevant controlling agency will be notified at 

least 24 hours prior to the operation and, if required, any necessary permission obtained. 7. Flights will 

be operated under visibility and cloud clearance requirements equivalent to Visual Flight Rules (VFR). 8. 

The sUAS will at all times give way to any aircraft carrying persons. 9. Minimum crew for each operation 

will consist of the sUAS PIC. An observer will be utilized if the sUAS will be flown beyond line of sight of 

the PIC. The observer and PIC will at all times be able to communicate by voice and/or text. 10. Prior to a 

sUAS flight, an area of operation will be established. This area of operation will include a defined lateral 

and vertical area, where the sUAS will operate. Safety procedures will be established for persons, 

property and applicable airspace within the area of operation. 11. The sUAS shall operate from on-site 
takoff/landing locations directly next to the PIC and/or Observer. 12. Flight planning will include flight 

completion with at least 20% battery power remaining as measured by the sUAS or appropriate timing. 

13. The sUAS identified as a DJI Phantom 3 Advanced will be equipped with an autopilot system which 

will be equivalent to or better than a Pixhawk, Mikrokopter, WooKong, Sensefly, or Gatewing system. 

For example, the sUAS will utilize GPS navigation, failsafe’s, return-to-home (RTH), and flight abort 

safety 

 

features, among other built-in safety features. 14. A Ground Station will be connected, by radio 

communication, to the sUAS during the entire flight, which will give the PIC flight information such as 

GPS Position, Altitude, Battery Remaining, and other telemetry information. 15. A briefing will be 

conducted in regard to the planned sUAS operations prior to operation at each new location. All 

personnel who will be performing duties within the boundaries of the area of operation will be present 

for this briefing. 16. All required permissions and permits will be obtained from appropriate state, 

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

agencies. 17. Written, to include electronic, and/or oral permission from the relevant property owners 

will be obtained prior to an operation. 18. The sUAS pilot will be trained in advance for the safe 

operation of the sUAS to be operated. This will include operation of the sUAS both in normal and 

emergency modes of operation, and will include familiarization with the operation manual (or similar) if 

published by the sUAS manufacturer. Training will also include types of maneuvers to be performed 

and the safe operation in relation to persons, property and applicable airspace. 

It is the applicant's belief that the size, weight, speed, operating environment, and operating capabilities 

provide an "equivalent level of safety" or better when operating a sUAS for the public interest as 

outlined in Section 333 of the Reform Act. It is requested that the FAA issue an exemption to permit 

safe, legal, commercial sUAS operation by the applicant as soon as possible. 

Respectfully submitted, 

Thomas E. Rivera, Address: 473 Glenn Rose Circle, King of Prussia PA 19406 (610)937-9909

 

Appendix A 

EXEMPTION REQUESTS AND EQUIVALENT LEVEL OF SAFETY 

The applicant requests an exemption from the following regulations as well as any additional regulations 

that may technically apply to the operation of sUAS’s: 

14 CFR Part 21, Subpart H: Airworthiness Certificates 14 CFR § 91.203(a)(1) Section 91.203(a)(1) requires 

all civil aircraft to have a certificate of airworthiness. Part 21, Subpart H, entitled Airworthiness 

Certificates, establishes the procedural requirements for the issuance of airworthiness certificates as 

required by FAR § 91.203(a)(1). Given the size of the aircraft (less than 15 lbs.) and the limited operating 

area associated with its utilization, it is unnecessary to go through the certificate of airworthiness 

process under Part 21 Subpart H to achieve or exceed current safety levels. 
Such an exemption meets the requirements of an equivalent level of safety under Part 11 and Section 

333 of the Reform Act. The Federal Aviation Act and Section 333 of the Reform Act both authorize the 

FAA to exempt aircraft from the requirement for an airworthiness certificate, upon consideration of the 

size, weight, speed, operational capability, and proximity to airports and populated areas of the sUAS 

involved. 

In this case, an analysis of these criteria demonstrates that the sUAS operated without an airworthiness 

certificate, under the conditions proposed herein, will be at least as safe, or safer, than a conventional 

aircraft (fixed wing or rotorcraft) with an airworthiness certificate. The sUAS weighs less than 15 lbs. 

fully loaded. It will not carry a pilot or passenger, will not carry flammable fuel, and will operate 

exclusively within an area pre-disclosed and in compliance with conditions set forth herein. Operations 

under this exemption will be tightly controlled and monitored by both the operator, pursuant to the 

conditions set forth above, and by local public safety requirements. The FAA will have advance notice of 

all operations through the filing of NOTAMs. Receipt of the prior permission of the land owner, the size 

of the aircraft, the lack of flammable fuel, and the fact that the aircraft is carried to the location and not 

flown there all establish the equivalent level of safety. The sUAS provides at least an equivalent, and 

most likely exceeds, level of safety to that of such operations being conducted with conventional aircraft 

that would be orders-of-magnitude larger and would be carrying passengers, cargo, and flammable fuel. 

14 CFR. § 45.23 & 91.9(c): Marking of the Aircraft Regulation 45.23 provides: (a) Each operator of an 

aircraft must display on that aircraft marks consisting of the Roman capital letter “N” (denoting United 

States registration) followed by the registration number of the aircraft. Each suffix letter used in the

marks displayed must also be a Roman capital letter. (b) When marks include only the Roman capital 

letter “N” and the registration number is displayed on limited, restricted or light-sport category aircraft 

or experimental or provisionally certificated aircraft, the operator must also display on that aircraft 

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

6 inches high, the words “limited,” “restricted,” “light-sport,” “experimental,” or “provisional,” as 

applicable. 

Regulation 91.9(c) provides: No person may operate a U.S.-registered civil aircraft unless that aircraft is 

identified in accordance with part 45 of this chapter. 

 

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

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

not yet been established for operations inside the NAS. The applicant is prepared to mark the sUAS with 

the name of the organization and location or origin and fulfill any other request by the FAA to this topic 

in accordance to § 45.29(f) where the pilot, observer, and others working with the sUAS will see the 

identification of the sUAS. 

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

10167A and 10700. 

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

Commercial Pilot Privileges and Limitations. Section 61.113(a) & (b) limit private pilots to noncommercial operations. Unlike a conventional aircraft that carries a pilot, passengers, and cargo, the 
sUAS in this case is remotely controlled with no passengers or property of others on board. Section 

61.133(a) requires an individual with a commercial pilot’s license to be pilot in command of an aircraft 

for compensation or hire. The applicant respectfully proposes that operator requirements should take 

into account the characteristics of the particular sUAS. Most sUAS autopilot’s have a high degree of preprogrammed control and various built-in technical capabilities that strictly limit the potential for 

operation outside of the operating conditions set forth in the exemption application. Hands-on 

experience with the sUAS are a far more effective guarantee of flight safety than a commercial pilot 

certificate would be, until the FAA Pilot Certificate requirements catch up to the sUAS technology. 

The sUAS autopilots have an all-digital software platform with advanced features previously restricted to 

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

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

● The system can autonomously fly a programmed flight path or fly in manual mode ● Flight me and 

battery minutes are displayed at all times. The system will return home and land automatically if userconfigurable limits are reached. 

Flight safety is a priority, no matter the operating environment or project. sUAS offer superior 

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

situations. With multiple built-in safety features, sUAS platforms lead manned operations with respect 

to safety. 

● The sUAS automacally detects potenal issues - with configurable automated response behavior 

such as a return-home-and-land routine ● The sUAS self-calibrate all of their sensors and perform 

required failsafe pre-flight tests prior to takeoff to check for errors ● The sUAS have the ability to set up 

visual no-fly zones or create a virtual fence so the sUAS can’t fly horizontally or vertically beyond the 

pre-planned flight area ● The sUAS have baery minutes and flight me displayed at all mes. The 

system will return home and land automatically if user-configurable limits are reached ● The sUAS auto 

detect a lost GPS, warns the pilot and initiates an immediate landing. ● Low baery on the sUAS triggers 

a Non-Fatal Warning alarm to return home, land and replace the battery ● If sUAS detect a lost-link to 

the Ground Station the vehicle will perform its pre-defined Non-Fatal Condition Response. 

Given these safety features, the applicant proposes that operators of sUAS with these features should 

not be required to hold a commercial or private pilot certification. Instead, 

 

operators should be required to: ● have successfully completed, at a minimum, FAA private pilot ground 

instruction and passed the FAA Private Pilot written examination or FAA-recognized equivalents 

including ICAO issued commercial, private license and ground school; operators will therefore receive 

instruction in aeronautical navigation, meteorology, and aviation regulations prior to conducting 

commercial sUAS operations. ● have completed a training program for operation of the sUAS, if 

available. ● have completed 15 hours (or 150 flights) of training on the sUAS and/or simulator before 

commencing commercial operations. 

The applicant notes that the FAA has found that safety factors permitted operation of sUASs by 

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

mandatory operating conditions specified above are present. See Federal Aviation Administration, 
Notice N-8900.227, Unmanned Aircraft Systems (UAS) Operational Approval, at 20-21 (July 30, 2013). 

The FAA has the statutory authority, granted at 49 U.S.C.§44701(f) to waive the pilot requirements for 

commercial operations. 

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

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

conditions set forth herein. 

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

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

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

rotorcraft), that allowing operations of the sUAS as set forth above meets or exceeds the present level 

of safety provided under 14 C.F.R. § 61.113(a) & (b) and does not rise to the level of requiring a 

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

14 CFR § 91.7(a): Civil aircraft airworthiness. This regulation requires that no person may operate a civil 

aircraft unless it is in airworthy condition. Should the exemption be granted allowing commercial 

operation of sUAS without an airworthiness certificate, no standard will exist for airworthiness of the 

sUAS. Given the size of the sUAS and the previous COAs issued for similar sUAS, an equivalent level of 

safety will be achieved by ensuring compliance with the given sUAS manuals and use of safety checklists 

prior to each flight. 

14 CFR § 91.9(b)(2): Civil Aircraft Flight Manual in the Aircraft. The regulation provides: No person may 

operate a U.S.-registered civil aircraft O 

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

there is available in the aircraft a current approved airplane or Rotorcraft Flight Manual, approved 

manual material, markings, and placards, or any combination thereof. 

Given the size of sUAS, they have no ability or place to carry such a flight manual on the aircraft, not 

only because there is no pilot on board, but because there is no room or capacity to carry such an item 

on the aircraft. 

The equivalent level of safety will be achieved by keeping the flight manual at the ground control point 

where the pilot flying the sUAS will have immediate access to it. The FAA has issued to others the 

following exemptions to this regulation: Exemption Nos. 8607, 8737, 8738, 9299, 9299A, 9565, 9565B, 

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

 

14 CFR § 91.103: Preflight action This regulation requires each pilot in command to take certain actions 

before flight to insure the safety of flight. As FAA approved rotorcraft flight manuals will not be provided 

for the aircraft an exemption will be needed. An equivalent level of safety will be provided by following 

a 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. 
14 CFR § 91.109(a) & 91.319(a)(1): Flight Instruction These regulations provide that no person may 

operate a civil aircraft (except a manned free balloon) that is being used for flight instruction unless that 

aircraft has fully functioning dual controls. 

The sUAS are remotely piloted aircraft and by 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 flight plan is either manually controlled through pointand-click navigation or 

preprogrammed as way points into the auto pilot before or during flight and only in unusual 

circumstances will the pilot input control functions to alter the pre-programmed flight. 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. 

14 CFR § 91.119: Minimum Safe Altitudes Section 91.119 establishes safe altitudes for operation of civil 

aircraft. Specifically, 91.119(c) limits aircraft flying over areas other than congested areas to an altitude 

of 500 feet above the surface, except over open water or sparsely populated areas. In those cases, the 

aircraft may not be operated closer than 500 feet to any person, vessel, vehicle, or structure. 

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

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

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

sUAS are built. Also, no flight will be taken without the permission of the land owner or those who 

control the land. Because of the advance notice to the landowner, all affected individuals will be aware 

of the flights. Compared to aerial survey operations conducted with aircraft or rotorcraft weighing 

far more than 15 lbs. and carrying flammable fuel, any risk associated with these operations will be far 

less than those currently allowed with conventional aircraft operating at or below 500 feet AGL. Indeed, 

the low-altitude operations of the sUAS will maintain separation between these sUAS operations and 

the operations of conventional aircraft that must comply with Section 91.119. 

14 CFR § 91.121: Altimeter Settings Section 91.121 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. Some sUAS have a barometric pressure sensor, while others only use 

GPS for elevation or altitude. When a barometric pressure sensor is on the sUAS, it is typically “zeroed” 

at the point of take-off; this is right next to the PIC and not at a departure airport. The altitude reading 

will be relative to that point and not a known elevation. 

The equivalent level of safety will be achieved by the PIC confirming the elevation or altitude of 

 

the launch site. The altitude of the sUAS will also be displayed via telemetry on the Ground Station and 

will be constantly monitored by the PIC during the entire flight operation. 

14 CFR § 91.151(a): Fuel Requirements for Flight in VFR Conditions This regulation prohibits an 

individual from beginning “a flight in an airplane under VFR conditions unless (considering wind and 
forecast weather conditions) there is enough fuel to fly to the first point of intended landing and, 

assuming normal cruising speed – (1) During the day, to fly after that for at least 30 minutes; or (2) At 

night, to fly after that for at least 45 minutes.” 

The different sUAS batteries provide a variety of powered flight times. An exemption from § 14 CFR 

91.151 is therefore required. 

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

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

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

the type of risks that Section 91.151(a) was meant to prevent given the size and speed at which the 

sUAS operates. The fact that it carries no pilot, passenger, or cargo also enhances its safety. In 

the unlikely event that the sUAS should run out of fuel, it would simply land. Given its weight and 

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

The applicant believes that an equivalent level of safety can be achieved by maintaining 20% of reserve 

fuel (or battery), which would be more than adequate to return the sUAS to its planned landing zone 

from anywhere in its operating area. 

The FAA has granted similar exemptions to others, including Exemptions 2689F, 5745, 10673 and 10808. 

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

follows: 

(a) O no person may operate a civil aircraft unless it has O 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 sUAS fully loaded weigh less than 15 lbs. As such, there is no ability or place to carry certification 

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

aircraft. 

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

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

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

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

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

that an aircraft operator or owner “shall have that aircraft inspected as prescribed in subpart E of this 

part and shall between required inspections, except as provided in paragraph (c) of this section, have 

discrepancies repaired as prescribed in part 43 of this chapter ...” Section 91.407 similarly makes 

reference to requirements in Part 43; Section 91.409(a)(2) requires an annual inspection for the 

issuance of an air worthiness 

 
certificate. Section 91.417(a) requires the owner or operator to keep records showing certain 

maintenance work that has been accomplished by certificated mechanics, under Part 43, or licensed 

pilots and records of approval of the aircraft for return to service. 

The sUAS are nearly maintenance free, they perform automatic pre-flight checks and the failure of any 

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

person prior to each flight and at predefined intervals as part of a maintenance schedule. 

Pre-flight checklist includes: 1.Visual inspection of the airframe 2.Visual inspections of rotor integrity 

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

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

payload, will operate only in restricted predetermined areas and is not a complex mechanical devise. 

The operator of aUAS will ensure that it is in working order prior to initiating flight, perform required 

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

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

condition and to ensure an equivalent level of safety. 

If mechanical issues arise, the UAS can land immediately due to the pre-determined area of operation. 

Moreover, the UAS's small size, carrying capacity, and the fact that flight operations will only take place 

in restricted areas for limited periods of time, create less risk than the same factors associated with 

conventional fixed-wing aircraft and rotorcraft performing the same operation. 

 

APPENDIX C 

SUMMARY OF SECTION 333 EXEMPTION REQUEST 

Thomas E. Rivera, hereby provides pursuant to Part 11 a summary of its exemption application to 

allow commercial operation of sUAS for aerial acquisition and research in support of government 

entities, agriculture industry, utility companies, local infrastructure, scientific studies, wildlife 

monitoring, mining, surveying, forestry, and much more. All of which are critical to the well-being of the 

general public. An exemption is requested from the following regulations: 

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. 61.133(a); 14 C.F.R. 91.7(a); 14 

C.F.R. 91.9(b)(2) & (c); 14 C.F.R. 91.103; 14 C.F.R. 91.109(a); 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. 91.405(a); 14 C.F.R. 91.407(a)(1); 14 C.F.R. 91.409(a)(2); 14 

C.F.R. 91.417(a