1

UNITED STATES OF AMERICA

DEPARTMENT OF TRANSPORTATION

FEDERAL AVIATION ADMINISTRATION

WASHINGTON, DC

IN THE MATTER OF THE PETITION FOR EXEMPTION OF:

FORGET ME KNOT EVENTS, LTD

d.b.a. AERONAUTIC WORKS

FOR AN EXEMPTION, SEEKING RELIEF FROM THE REQUIREMENTS OF 

TITLE 14 OF THE CODE OF FEDERAL REGULATIONS Part 21, subpart H, 

Part 27, Sections 45.23(b), 45.27(a), 61.23(a) and (c), 61.101(e)(4) and (5), 

61.113(a) & (b), 61.113(a) & (b), 61.315(a), 91.7(a), 91.9(b), 91.119(c), 91.121, 

91.151(b), 91.203(a) and (b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 

91.417(a) & (b) 

CONCERNING COMMERCIAL OPERATION OF THE FOLLOWING 

UNMANNED AIRCRAFT SYSTEMS:

1) DJI SPREADING WINGS S800 UAS

2) DJI INSPIRE 1 / INPIRE 1PRO UAS

3) DJI PHANTOM 3 UAS

4) 3DR X8 UAS

5) 3DR Solo UAS

6) BIRDSEYEVIEW AEROBOTICS FIREFLY 6 UAS

7) AERYON SKYRANGER UAS

8) AERONAUTIC WORKS Q2 UAS

9) AERONAUTIC WORKS W21/W22 UAS

10) AERONAUTIC WORKS POLAR UAS

11) AERONAUTIC WORKS BOUYANT22 UAS

PURSUANT TO SECTION 333 OF THE FAA MODERNIZATION AND REFORM 

ACT OF 2012 (PUBLIC LAW 11295)

Submitted: December 15th, 2015

Edward A. Putnam

Forget Me Knot Events, Ltd

15962 Green Springs Drive

Reno, NV 89511

Phone and Email will be sent separately for privacy
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TABLE OF CONTENTS

GLOSSARY OF ABBREVIATIONS: 3

SUMMARY: 5

INTRODUCTION AND INTERESTS OF PETITIONER: 5

UNMANNED AIRCRAFT SYSTEMS BY TYPE: 6

BASIS FOR PETITION: 7

NAME AND ADDRESS OF PETITIONER: 7

THE SPECIFIC SECTIONS OF 14 C.F.R. FROM WHICH APPLIED ART &

TECHNOLOGY, LLC SEEKS EXEMPTION: 8

THE EXTENT OF RELIEF FORGET ME KNOT EVENTS LTD. SEEKS

AND THE REASON Applied Art & Technology, LLC SEEKS THE RELIEF: 13

THE REASONS WHY GRANTING FORGET ME KNOT EVENTS LTD.

REQUEST WOULD BE IN THE PUBLIC INTEREST: 18

THE REASONS WHY GRANTING THE EXEMPTION WOULD NOT

ADVERSELY AFFECT SAFETY: 20

SUMMARY THAT CAN BE PUBLISHED IN THE FEDERAL REGISTER: 34

CONCLUSION: 36

APPENDICES:

APPENDIX A – LISTED UA DESCRITIONS:

APPENDIX B - FLIGHT OPERATIONS MANUAL:

APPENDIX C – SPECIFIC UAS CHECKLISTS AND PROCEDURES:

APPENDIX D – MAINTENANCE LOG:
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GLOSSARY OF ABBREVIATIONS

AF: Auto Flight or Automated Mission Conduct

AGL: “Above Ground Level” measurement of altitude

AOI: Area of Interest

ATC: Air Traffic Control

ATO: Air Traffic Organization

AV: Aerial Vehicle

CFR: Code of Federal Regulations

COA: Certificate of Authorization

DFO: Director of Flight Operations

FAA: Federal Aviation Administration

FAR: Federal Aviation Regulation

FCC: Federal Communications Commission

FCU: Flight Control Unit (ie, DJI Naza, Pixhawk, etc)

FOM: Flight Operations Manual

FWF: Forward Winged Flight (ie, a traditional airplane mode of flight)

GCS: Ground Control Station

GPS: Global Positioning System

HTOL: Horizontal Takeoff and Land Aircraft (ie, traditional airplane)

LOS: Loss of Signal (GCS communications fail for an unspecified time)

MC: Mission Commander

MINS: Minimum standards of operation (weather, equipment or personnel)

MSL: Altitude by Reference to Mean Sea Level
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NAS: National Airspace System

NAV: Navigation, in reference to Lateral or Vertical movement

NOTAM: Notice to Airman

NM: Distance, measured in Nautical Miles

OB: Auxiliary Observer; personnel allowed within 500 feet of operations

OPS: Flight or Ground Technical Operation in support of Commercial 

UAS Activity

OPS BAN: Halt to all UAS OPS in reaction to Personnel, technical, airspace or 

weather restrictions or challenges

PIC: Pilot In Command

RTL: Return To Launch (initial launch location) by Auto Command or 

Manual Control

SEC333: FAA Modernization and Reform Act of 2012 (FMRA) Section 333

SMS: Safety Management System

SO: Safety Observer; an official operational position required for flight

SOP: Standard Operating Procedures

UA: Unmanned Aircraft

UAS: Unmanned Aircraft System

VFR: Visual Flight Rules

VLOS: Visual Line of Site

VMC: Visual Meteorological Conditions

VTOL: Vertical Takeoff and Landing

VTOL2: VTOL capability with Forward Winged Flight (FWF) operational 

transition capability and HTOL backup landing capability

WX: Weather, referenced via actual, reported or forecast condition
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SUMMARY

Forget Me Knot Ltd. seeks exemption from the requirements of : 14C.F.R §§ Part 

21, subpart H, Part 27, 45.23(b), 45.27(a), 61.23(a) and (c), 61.101(e)(4), and 

(5), 61.113(a) & (b), 61.113(a) & (b), 61.315(a), 91.7(a), 91.9(b), 91.119(c), 

91.121, 91.151(b), 91.203(a) and (b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & 

(a)(2), and 91.417(a) & (b), in order to operate an Unmanned Aircraft System 

pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 

(FMRA).

This exemption will permit Forget Me Knot Events, Ltd. to operate an Unmanned 

Aircraft System (UAS) for the commercial purpose of conducting Aerial Video, 

Photography, Aerial Mapping, Search and Rescue Relief and Inspection Services 

over areas of the United States.

INTRODUCTION AND INTERESTS OF THE PETITIONER

Forget Me Knot Events, Ltd. provides clients with Event Planning, Event 

Management, Marketing, Advertising, Videography and Photography. Forget Me 

Knot Events plans to offer UAS services under the established high quality 

business practices of this company and also will offer exceptional aviation and 

UA services based on the Petitioner’s notable operational experience in aviation. 

We will offer services under the trade name as (registered in the state of Nevada) 

“AeroNautic Works”. (Forget Me Knot Events, Ltd. d.b.a. AeroNautic Works). 

For the purposes of this document, we will refer to ourselves as “Forget Me Knot 

Events” for simplicity and the fact that our primary legal corporation documents 

and business licenses reflect this name.

One of the managing members of Forget Me Knot Events is a current FAA Airline 

Transport Pilot with over Twenty-Five years of professional aviation experience 

both domestically and globally. Areas of experience include nearly 15,000 hours 

of flight operations, airman and crew training, safety program management and 

operational control experience via positions held in air carrier management 

(Director of flight Operations, Chief Pilot, Safety Program Specialist and Flight 

Training Officer).

In addition to this professional aviation experience, the managing member has 

been highly active in the Radio Control model aircraft community for over ThirtyFive years. Areas of long standing expertise include Vertical Takeoff and 

Landing operation (VTOL), Traditional Forward Winged Flight (FWF), Research 

& Development, Design and Flight Testing of experimental aircraft types. The 

petitioner has thousands of hours of unique design, fabrication, testing and 

documenting this kind of aeronautical activity, especially during the last Twenty 

years.
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The objective of Forget Me Knot Events Ltd planned UAS Flight Operations is to 

take part in this revolutionary merging of Commercial Aviation with modern, micro 

sized UAS systems. Forget Me Knot Events Ltd. would like to be a part of 

forming a robust, highly regarded miniature civilian UAS community while setting 

industry best practices and a sustainable set of SOP’s with a forming and later 

established training pipeline for future growth.

In the near term, Forget Me Knot Events Ltd. would like to provide high quality 

imaging and UAS services for a variety of clients including, but not limited to:

● Event Filming and Photography

● Promotions / Marketing / Advertising / Economic Development

● Science / Technology / Engineering Innovation

● Real Estate and Construction Services

● Environmental Mapping / Agriculture / Aerial Surveying

● Insurance Services

● Mining Industry

● Infrastructure Inspections

Forget Me Knot Events Ltd. Managing members have extensive experience in 

UAS and FAA Aviation industry experience. Utilizing the latest technology 

available, along with anchoring these opportunities with extensive experience in 

professional aviation of over Twenty-Five years and miniature aircraft / drone 

activity for over Thirty-Five years, will allow Forget Me Knot Events to offer new 

services to the public. We intend to become a leader in UAS safety and 

innovation while performing outstanding public & commercial service. We 

envision using special subject matter experts in areas of industry that have not 

been of long standing experience to Forget Me Knot Events Ltd in serving a 

diverse set of customers. This is to enable the safest UAS services with the 

highest caliber of product delivery to promote a sustainably established presence 

in this segment of aviation.

UNMANNED AIRCRAFT SYSTEMS:

Forget Me Knot Events Ltd. seeks an exemption to operate the following aircraft 

for compensation or hire within the NAS:

1) DJI SPREADING WINGS S800 UAS

2) DJI INSPIRE 1 / INPIRE 1PRO UAS

3) DJI PHANTOM 3 UAS

4) 3DR X8 UAS

5) 3DR Solo UAS

6) BIRDSEYEVIEW AEROBOTICS FIREFLY 6 UAS
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7) AERYON SKYRANGER UAS

8) AERONAUTIC WORKS Q2 UAS

9) AERONAUTIC WORKS W21/W22 UAS

10) AERONAUTIC WORKS POLAR UAS

11) AERONAUTIC WORKS BOUYANT22 UAS

Additional descriptions and specifications of these systems will be described in 

Appendix A. For the purposes of this document, all approved UAS systems will 

be referred to as “listed UA’s” or “Approved UAS” when referring to multiple 

aircraft types, as applicable.

BASIS FOR PETITION

Petitioner, Forget Me Knot Events Ltd., pursuant to the provisions of the

Federal Aviation Regulations (14 C.F.R. § 11.61) and the FAA Modernization and 

Reform Act of 2012 (FMRA), Section 333, Special Rules for Certain Unmanned 

Aircraft Systems , hereby petitions the Administrator to commercially operate the 

DJI INSPIRE 1 / INPIRE 1PRO UAS, DJI PHANTOM 3 UAS, 3DR X8 UAS, 3DR 

Solo UAS, BIRDSEYEVIEW AEROBOTICS FIREFLY 6 UAS, AERYON 

SKYRANGER UAS, AVALOFT Q2 UAS, AVALOFT W21/W22 UAS, AVALOFT 

POLAR UAS and AVALOFT BOUYANT22 UAS in the National Airspace System 

(NAS), and for an exemption from the requirements of 14 C.F.R §§ Part 21, 

subpart H, Part 27, 45.23(b), 45.27(a), 61.23(a) and (c), 61.101(e)(4) and (5), 

61.113(a) & (b), 61.113(a) & (b), 61.315(a), 91.7(a),

91.9(b), 91.119(c), 91.121, 91.151(b), 91.203(a) and (b), 91.405(a), 91.407(a)(1), 

91.409(a)(1) & (a)(2), and 91.417(a) & (b).

The operations outlined herein, and in the Petitioner's manuals, clearly define

UAS operations in the NAS that are under appropriately controlled conditions and 

within secure and sterile zones of operation and pose no significant safety risk to 

persons or property on the ground, no risk to National Security, and would not 

constitute as an invasion of any persons reasonable expectation of privacy.

A. Name And Address Of The Petitioner:

The name and address of the Petitioner and point of contact is:

Edward A. Putnam

Forget Me Knot Events

15962 Green Springs Drive

Reno, NV 89511

Phone and Email

Will be sent separately for privacy
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B. Specific Sections Of 14 C.F.R. Forget Me Knot Events, Ltd. 

Seeks Exemption From:

1. Forget Me Knot Events, Ltd. Seeks Exemption From The

Requirements Of 14 C.F.R. Part 21, Subpart H and Sections 91.203(a) and

91.203(b) and 14 C.F.R. Part 27.

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). Section 91.203 entitled Civil aircraft: Certifications required, 

subsections (a) and (b) state the following, in part:

(a) Except as provided in section 91.715, no person may operate a civil aircraft

unless it has within it the following, in part:

(1) An appropriate and current airworthiness certificate. Each U.S.

airworthiness certificate used to comply with this subparagraph (except a

special flight permit, a copy of the applicable operations specifications

issued under section 21.197(c) of this chapter, appropriate sections of the

air carrier manual required by parts 121 and 135 of this chapter containing

that portion of the operations specifications issued under section

21.197(c), or an authorization under section 91.611) must have on it the

registration number assigned to the aircraft under part 47 of this chapter.

However, the airworthiness certificate need not have on it an assigned

special identification number before 10 days after that number is first

affixed to the aircraft. A revised airworthiness certificate having on it an assigned 

special identification number that has been affixed to an aircraft

may only be obtained upon application to an FAA Flight Standards district

office.

(2) An effective U.S. registration certificate issued to its owner or, for

operation within the United States, the second copy of the Aircraft registration 

Application as provided for in section 47.31(c), or a registration certification 

issued under the laws of a foreign country. (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 section 91.715 is displayed 

at the cabin or cockpit entrance so that it is legible to passengers or crew. Part 

27 sets forth the procedural requirements for airworthiness certification of normal 

category rotorcraft.

2. Forget Me Knot Events Ltd. Seeks Exemption From The Requirement

Of Sections 91.9(b), 45.23(b) and and 45.27(a).

Section 91.9 entitled Civil aircraft flight manual, marking, and placard

requirements, subsection (b) states the following, in part:

(b) No person may operate a U.S. registered civil aircraft

1) For which an Airplane or Rotorcraft Flight Manual is required by

section 21.5 of this chapter unless there is available in the aircraft a

current, approved Airplane or Rotorcraft Flight Manual or the manual

provided for in section 121.141(b); and

(2) For which an Airplane or Rotorcraft Flight Manual is not required by
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section 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.

Section 45.23 entitled Display of marks; general, subsection (b), states the

following, in part:

(b) When marks include only the Roman capital letter "N" and the registration

number is displayed on limited, restricted or lightsport 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," "lightsport," "experimental," or "provisional," as applicable.

Section 45.27(a), Rotorcraft, states:

Each operator of a rotorcraft must display on that rotorcraft horizontally on both

surfaces of the cabin, fuselage, boom, or tail the marks required by section

45.23.

3. Forget Me Knot Events Ltd. Seeks Exemption From The

Requirements Of Section 61.23(a).

Section 61.23(a), entitled Operations requiring a medical certificate:

Requirements and duration, subsection (a) prescribe the following, in relevant

part: (f) Except as provided in paragraphs (d) and (i) of this section, a 

recreational pilot may not act as pilot in command of an aircraft

4. Forget Me Knot Events Ltd. Seeks Exemption From The

Requirements Of Section 61.101(e)(4) and (5).

Section 61.101, entitled Recreational pilot privileges and limitations: Pilot in

command, subsection (e)(4) and (5) prescribe the following, in relevant part:

(e) Except as provided in paragraphs (d) and (i) of this section, a recreational pilot may

not act as pilot in command of an aircraft for compensation or hire; (5) In furtherance of a 

business;

5. Forget Me Knot Events Ltd. Seeks Exemption From The Requirements

Of Section 61.113(a) and (b).

Section 61.113, entitled Private pilot privileges and limitations: Pilot in command, 

subsections (a) and (b) prescribe the following, in relevant part:

(a) No person who holds a private pilot certificate may act as a pilot in command 

(PIC) of an aircraft that is carrying passengers or property for compensation or 

hire; nor may that person, for compensation or hire, act as PIC of an aircraft. (b) 

A private pilot may, for compensation or hire, act as PIC 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.

6. Forget Me Knot Events Ltd. Seeks Exemption From The

Requirements Of Section 61.315(a).
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Section 61.315(a), entitled What are the privileges and limits of my sport pilot

certificate, subsection (a) prescribes the following in part:

(a) If you hold a sport pilot certificate you may act as pilot in command of a

lightsport aircraft, except as specified in paragraph (c) of this section

(c) You may not act as pilot in command of a lightsport aircraft:

(2) For compensation or hire.

(3) In furtherance of a business.

7. Forget Me Knot Events Ltd. Seeks Exemption From The

Requirements Of Section 91.7(a).

Section 91.7, entitled Civil aircraft airworthiness, subsection (a), states the

following:

(a) No person may operate a civil aircraft unless it is in an airworthy condition.

8. Forget Me Knot Events Ltd. Seeks Exemption From The

Requirements Of Section 91.103.

Section 91.103, entitled Preflight action, states the following:

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

available information concerning that flight. This information must include—

(a) For a flight under IFR or a flight not in the vicinity of an airport, weather

reports and forecasts, fuel requirements, alternatives available if the planned

flight cannot be completed, and any known traffic delays of which the pilot in

command has been advised by ATC;

(b) For any flight, runway lengths at airports of intended use, and the following

takeoff and landing distance information:

(1) For civil aircraft for which an approved Airplane or Rotorcraft Flight

Manual containing takeoff and landing distance data is required, the

takeoff and landing distance data contained therein; and

(2) For civil aircraft other than those specified in paragraph (b)(1) of this

section, other reliable information appropriate to the aircraft, relating to

aircraft performance under expected values of airport elevation and

runway slope, aircraft gross weight, and wind and temperature.

9. Forget Me Knot Events Ltd. Seeks Exemption From The

Requirements Of Section 91.109(a).

Section 91.109(a), entitled Flight instruction prescribes that any civil aircraft

operated for the purpose of flight instruction must have fully functioning dual

controls, states the following, in part:

(a) 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. However, instrument flight instruction may be given in an airplane that is

equipped with a single, functioning throwover control wheel that controls the

elevator and ailerons, in place of fixed, dual controls.

10 Forget Me Knot Events Ltd. Seeks Exemption From The
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Requirements Of Section 91.119(c).

Section 91.119(c), entitled Minimum safe altitudes: (c) Over other than congested 

areas, states the following, in part: Except when necessary for takeoff or landing, 

no person may operate an aircraft below the following altitudes: (c) Over other 

than congested areas. 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.

11. Forget Me Knot Events Ltd. Seeks Exemption From The

Requirements Of Section 91.121.

Section 91.121, entitled Altimeter settings, subsection (a), states the following, in 

part: (a) Each person operating an aircraft shall maintain the cruising altitude or 

flight level of that aircraft, as the case may be, by reference to an altimeter that is 

set, when operating(1) Below 18,000 feet MSL, to(i) The current reported 

altimeter setting of a station along the route and within 100 nautical miles of the 

aircraft; (ii) If there is no station within the area prescribed in paragraph (a)(1)(i) 

of this section, the current reported altimeter setting of an

appropriate available station; or (iii) In the case of an aircraft not equipped with a 

radio, the elevation of the departure airport or an appropriate altimeter setting

available before departure.

12. Forget Me Knot Events Ltd. Seeks Exemption From The

Requirements Of Section 91.151(b).

(a) No person may begin a flight in an airplane under VFR conditions unless 

(considering wind and forecast weather conditions) there is enough fuel to fly to 

the first point of intended landing and, assuming normal cruising speed—

(1) During the day, to fly after that for at least 30 minutes; or (2) At night, to fly 

after that for at least 45 minutes. (b), states the following: (b) No person may 

begin a flight in a rotorcraft 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, to fly

after that for at least 20 minutes.

13. Forget Me Knot Events Ltd. Seeks Exemption From The

Requirement Of Section 91.405(a).

Section 91.405, entitled Maintenance required , subsection (a), states the

following: Each owner or operator of an aircraft—

(a) 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.

14. Forget Me Knot Events Ltd. Seeks Exemption From The

Requirements Of Section 91.407(a)(1)

Section 91.407, entitled Operation after maintenance, preventive maintenance,

rebuilding, or alteration , subsection (a)(1), states the following:

(a) No person may operate any aircraft that has undergone maintenance,

preventive maintenance, rebuilding, or alteration unless(1) It has been approved 
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for return to service by a person authorized under § 43.7 of this chapter[.]

15. Forget Me Knot Events Ltd. Seeks Exemption From The

Requirements Of Sections 91.409(a)(1) And 91.409(a)(2).

Section 91.409, entitled Inspections , subsection (a), states the following:

(a) Except as provided in paragraph (c) of this section, no person may operate an 

aircraft unless, within the preceding 12 calendar months, it has had (1) An annual 

inspection in accordance with part 43 of this chapter and has been approved for 

return to service by a person authorized by section 43.7 of this chapter; or (2) An 

inspection for the issuance of an airworthiness certificate in

accordance with part 21 of this chapter.

16. Forget Me Knot Events Ltd. Seeks Exemption From The

Requirements Of Sections 91.417(a) And 91.417(b).

Section 91.417, entitled Maintenance records , subsections (a) and (b), state the 

following:

(a) Except for work performed in accordance with sections 91.411 and 91.413,

each registered owner or operator shall keep the following records for the periods 

specified in paragraph (b) of this section:

(1) Records of the maintenance, preventive maintenance, and alteration

and records of the 100hour, annual, progressive, and other required or

approved inspections, as appropriate, for each aircraft (including the

airframe)and each engine, propeller, rotor, and appliance of an aircraft.

The records must include(i) A description (or reference to data acceptable to the 

Administrator) of the work performed; and

(ii) The date of completion of the work performed; and

(iii) The signature, and certificate number of the person approving the aircraft for 

return to service.

(2) Records containing the following information:

(i) The total time in service of the airframe, each engine, each

propeller, and each rotor.

(ii) The current status of lifelimited parts of each airframe, engine, propeller, rotor, 

and appliance.

(iii) The time since last overhaul of all items installed on the aircraft

which are required to be overhauled on a specified time basis.

(iv) The current inspection status of the aircraft, including the time since the last 

inspection required by the inspection program under which the aircraft and its 

appliances are maintained.

(v) The current status of applicable airworthiness directives (AD) and safety 

directives including, for each, the method of compliance, the AD or safety 

directive number and revision date. If the AD or safety directive involves recurring 

action, the time and date when the next action is required.

(vi) Copies of the forms prescribed by § 43.9(d) of this chapter for each major 

alteration to the airframe and currently installed engines, rotors, propellers, and 

appliances.

(b) The owner or operator shall retain the following records for the periods
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prescribed:

(1) The records specified in paragraph (a)(1) of this section shall be

retained until the work is repeated or superseded by other work or for 1 year after 

the work is performed.

(2) The records specified in paragraph (a)(2) of this section shall be

retained and transferred with the aircraft at the time the aircraft is sold.

(3) A list of defects furnished to a registered owner or operator under §

43.11 of this chapter shall be retained until the defects are repaired and the 

aircraft is approved for return to service.

C. Extent Of Relief “Forget Me Knot Events, Ltd.” Seeks, and the 

reason “Forget Me Knot Events, Ltd.” Seeks Relief.

1. Extent Of Relief “Forget Me Knot Events, Ltd.” Seeks And The Reason

“Forget Me Knot Events, Ltd.” Seeks Relief From 14 C.F.R. Part 21,

Subpart H and Sections 91.203(a) and 91.203(b) and 14 C.F.R. Part 27.

Given the size and limited operating area associated with the sUAS to be utilized 

by the Petitioner, an exemption from Part 21 Subpart H meets the requirements 

of an equivalent level of safety under Part 11 and Section 333 of the Reform Act. 

The Federal Aviation Act (49 U.S.C.§ 44701(f)) and Section 333 of the Reform 

Act both authorize the FAA to exempt aircraft from the requirement for an 

airworthiness certificate, upon consideration of the size, weight, speed, 

operational capability, and proximity to airports and populated areas of the 

particular UAS. In all cases, an analysis of these criteria demonstrates that the 

sUAS operated without an airworthiness certificate, in the restricted environment 

and under the conditions proposed will be at least as safe, or safer, than a 

conventional rotorcraft operating with an airworthiness

certificate without the restrictions and conditions of the proposed sUAS 

operations.

To the extent the Petitioner's sUAS would otherwise require certification under

Part 27, as an airplane or rotorcraft, Petitioner requests an exemption from Part 

27's airworthiness standards for the same reasons identified in the exemption 

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

2. Extent Of Relief “Forget Me Knot Events, Ltd.” Seeks And The Reason

“Forget Me Knot Events, Ltd.” Seeks Relief From Sections 91.9(b),

45.23(b) and 45.27(a).

Exemption from section 45.23(b) is warranted because the listed UA’s

have no entrance to the cabin, cockpit, or pilot station on which the word 

"Experimental" can be placed. Moreover, given the size of the listed UA’s and 

UAS, two-inch lettering would be impossible.
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The word "Experimental" will be placed on the fuselage in compliance with § 

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

Petitioner requires relief from the associated marking and identification 

requirements of section 45.27(a) and section 91.9(c), which would require

compliance with section 45.23(b).

3. Extent Of Relief “Forget Me Knot Events, Ltd.” Seeks And The Reason

“Forget Me Knot Events, Ltd.” Seeks Relief From Section 61.23(a).

Relief from Section 61.23(a), entitled Operations requiring a medical certificate:

Requirements and duration, is requested to the extent required to necessary to 

allow a PIC holding a sport pilot certificate or higher level certificate, as well as a 

current and valid driver’s license, to conduct the proposed UAS flight operations

for compensation or hire. This relief is requested since the limitations set forth in 

Section 61.23(a) otherwise require the PIC of any flight for compensation or hire 

to hold a comprehensive FAA issued medical certificate. In Exemption No. 11213 

to Aeryon Labs, Inc., the FAA “finds that, because of the risk mitigations 

established in the conditions and limitations

of this exemption, a person that holds a U.S. issued driver’s license who is 

operating a UAS will not adversely affect safety. The FAA is granting relief from § 

61.23(a) to allow any pilot that holds one of the pilot’s certificates discussed 

above to operate a UAS under this exemption with a U.S. issued driver’s license, 

in lieu of an FAAissued medical certificate. The FAA is also granting relief from § 

61.23(c) to allow sport pilot certificate holders to operate aircraft other than LSA 

with a U.S. issued driver’s license under this exemption.”

4. Extent of Relief “Forget Me Knot Events, Ltd.” Seeks And The Reason

“Forget Me Knot Events, Ltd.” Seeks Relief From Sections 61.101(e)(4) &

(e)(5), 61.113(a), and 61.315(a).

Relief from sections 61.101(e)(4) & (e)(5), entitled Recreational pilot privileges

and limitations; section 61.113(a), entitled Private pilot privileges and limitations: 

Pilot in command; and section 61.315(a), entitled What are the privileges and 

limits of my sport pilot certificate, is requested to the extent necessary to allow a 

PIC holding a sport pilot, recreational pilot, or private pilot certificate, as well as 

an airman medical certificate or U.S. issued driver’s license, and who has met 

certain flight hour and currency requirements, to conduct the proposed UAS flight 

operations for compensation or hire, subject to the conditions and limitations 

below. This relief is requested since the limitations set forth in sections 

61.101(e)(4) & (e)(5) state that no person who holds a recreational pilot 

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

in furtherance of a business. Relief is requested from 61.113(a) since the 

limitations set forth in that section state that no

person who holds a private pilot certificate may act as pilot in command of an 

aircraft that is carrying passengers or property for compensation or hire; nor may 

that person, for compensation or hire, act as pilot in command of an aircraft.
15

Relief is requested from 61.315(a) since the limitations set forth in that section 

only allow a person who holds a sport pilot certificate to act as pilot in command 

of a lightsport aircraft. As set forth more fully below, Forget Me Knot Events Ltd. 

submits that an equivalent level of safety will be maintained because no PIC will 

be allowed to operate the listed UA’s unless that PIC has met certain flight hour 

and currency requirements, demonstrating that the PIC is able to safely operate 

the listed UA’s in a manner consistent with the operations specifications as set 

forth herein, including: Evasive and emergency maneuvers, as well as 

maintaining appropriate distances from

people, vessels, vehicles, and structures. Further, Forget Me Knot Events Ltd. 

submits that the additional airmanship experience of a commercially certified pilot 

would not correlate to the airmanship skills necessary for Forget Me Knot Events 

Ltd. specific proposed operations.

5. Extent Of Relief “Forget Me Knot Events, Ltd.” Seeks And The Reason

“Forget Me Knot Events, Ltd.” Seeks Relief From Section 91.7(a).

Relief from Section 91.7(a) entitled Civil aircraft airworthiness , is requested to 

the extent required to allow Forget Me Knot Events Ltd. to determine that the 

listed UA’s are in airworthy condition prior to every flight by ensuring that the 

UAS is in compliance with the operating documents (i.e., the Forget Me Knot 

Events Ltd. Flight Operations Manual, Maintenance Log, and Specific UA 

Operations Manual).

Forget Me Knot Events Ltd. seeks the requested relief because the listed UA’s 

do not require an airworthiness certificate in accordance with 14 C.F.R.

Part 21, Subpart H. Therefore, Forget Me Knot Events Ltd. will ensure that the 

listed UA is in an airworthy condition based upon its compliance with the 

operating documents (i.e., the Forget Me Knot Events Ltd. Flight Operations 

Manual, Maintenance Log, and Specific UA Operations Manual) prior to every 

flight. Additionally, Forget Me Knot Events Ltd. will determine that the aircraft are 

in condition for safe flight, as stated in the conditions and limitations below.

6. Extent Of Relief “Forget Me Knot Events, Ltd.” Seeks And The Reason

“Forget Me Knot Events, Ltd.” Seeks Relief From Section 91.103.

Relief from FAR 91.103 is requested, as FAA approved aircraft flight manuals will 

not be used. In the absence of the flight manuals the PIC will take all preflight 

action, including reviewing Weather, Mission Constraints, Safety Concerns, Flight 

battery requirements, Takeoff and Landing performance, environmental 

conditions as they relate to aircraft limitations and aircraft performance data 

before starting a flight.

7. Extent Of Relief “Forget Me Knot Events, Ltd.” Seeks And The Reason

“Forget Me Knot Events, Ltd.” Seeks Relief From Section 91.109(a).
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Relief from Section 91.109a is requested, as UAS and remotely piloted aircraft, 

by their design do not have fully functional dual controls. Instead, flight control is

accomplished through the use of a control box that communicates with the UA 

via radio communications.

Forget Me Knot Events Ltd. managing members have trained many first time RC 

pilots using well-established protocols using single and multiple radio transmitter 

control systems. This arrangement has proven safe and effective over the past 

50 years and using modern equipment, the system is still effective and valid.

8. Extent of Relief “Forget Me Knot Events, Ltd.” Seeks And The Reason

“Forget Me Knot Events, Ltd.” Seeks Relief From Section 91.119(c).

Relief from Section 91.119(c), entitled Minimum safe altitudes: (c) Over other

than congested areas, is required because all proposed operations of the listed 

UA’s will take place at an altitude at or below 400 feet AGL. This relief is 

requested since the limitations set forth in Section 91.119(c) state that no person 

may operate an aircraft below 500 feet above the surface. As set forth more fully 

below, Forget Me Knot Events Ltd. submits that a level of safety equivalent to 

Section 91.119(c) will be maintained because operations will be conducted in 

areas with controlled access and under the safety provisions contained within 

this petition. The listed UA SOP’s and protocols are proven safe and effective in 

maintaining an exceptional level of safety and the Forget Me Knot Events Ltd. 

Flight Operations Manual, specific US Operations Manual and effective 

aeronautical decision making create a robust level of safety management.

Additionally, relief from Section 91.119(c) is requested to the extent necessary to 

allow operations to be conducted closer than 500 feet to persons, vessels, 

vehicles, or structures, under certain conditions. This relief is requested since the 

limitations set forth in Section 91.119(c) prohibit operating an aircraft closer than 

500 feet to a person, vessel, vehicle, or structure.

Forget Me Knot Events Ltd. submits an equivalent level of safety will be 

maintained because operations closer than 500 feet to a person, vessel, vehicle, 

or structure will first require that the operator receive permission from any 

nonparticipating persons or the person who owns/controls the property. In 

addition, barriers or structures will be in place to sufficiently protect 

nonparticipating persons from debris in the event of an accident and all 

nonparticipating persons will be required to remain under such protections for the 

duration of the operation.
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9. Extent Of Relief “Forget Me Knot Events, Ltd.” Seeks And The Reason

“Forget Me Knot Events, Ltd.” Seeks Relief From Section 91.121.

Relief from Section 91.121, entitled Altimeter settings, may be required to allow

flight operations of the listed UA’s, which utilize a barometric pressure sensor,

GPS equipment, and a radio communications telemetry data link to downlink 

altitude information from the UA to the PIC at the ground control station (GCS). 

Since the FAA requires that any altitude information concerning UAS operations 

Forget Me Knot Events Ltd. seeks the requested relief because the listed UA’s 

altimeter may be set on the ground to zero feet AGL, rather than the local 

barometric pressure or field altitude, before each flight.

Considering the limited altitude of the proposed operations, relief from 14 CFR

91.121 is sought to the extent necessary to comply with the applicable conditions 

and limitations stated below. As more fully set forth herein, an equivalent level of 

safety will be maintained since the listed UA’s are equipped with a barometric 

pressure sensor and GPS equipment, which automatically ensures that a ground 

level pressure setting will be established prior to each flight, and provides the PIC 

with altitude information of the via telemetry data transmitted to the GCS.

10. Extent Of Relief “Forget Me Knot Events, Ltd.” Seeks And The Reason

“Forget Me Knot Events, Ltd.” Seeks Relief From Section 91.151(b).

Relief from Section 91.151(b) entitled Fuel requirements for flight in VFR

conditions, is requested to the extent required to allow flights of the battery 

powered, listed UA’s during daylight hours in visual meteorological conditions 

(VMC), under visual flight rules (VFR).

Forget Me Knot Events Ltd. seeks the requested relief because without an

exemption from Section 91.151(b), the flight time duration of battery powered 

listed UA’s will prohibit the practicality of any aerial video or still photo flight 

operations Forget Me Knot Events Ltd. proposes to conduct pursuant to this

Petition.

Significantly the technical specifications of listed UA’s operating documents and 

the Forget Me Knot Events Ltd. proposed operating limitations ensure that Forget 

Me Knot Events Ltd. will safely operate the battery powered listed UA during 

daylight hours in visual meteorological conditions (VMC), under visual flight rules 

(VFR), with enough battery power to fly for the entire planned mission and there 

after for an additional 4 Minutes, 30 Seconds.

11. Extent Of Relief “Forget Me Knot Events, Ltd.” Seeks And The Reason

“Forget Me Knot Events, Ltd.” Seeks Relief From Sections 91.405(a),

91.407(a)(1), 91.409(a)(1) & (a)(2), And 91.417(a) & (b).

Since Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) &
18

(b) only apply to aircraft with an airworthiness certificate, Forget Me Knot Events 

Ltd. requests relief from these Sections because listed UA does not require 

airworthiness certificates. As set forth more fully below, the listed UA meets

the conditions of FMRA Section 333 for operation without an airworthiness 

certificate. Accordingly, Forget Me Knot Events Ltd. will use trained technicians 

to perform maintenance, alterations, or preventive maintenance on the UAS 

using the methods, techniques, and practices prescribed in the UAS operating 

documents (i.e., the Forget Me Knot Events Ltd. Flight Operations Manual, 

Maintenance Log, and Specific UA Instruction Manual). Forget Me Knot Events 

Ltd. will document and retain all maintenance records for all listed UA’s.

D. The Reasons Why Granting the request to “Forget Me Knot 

Events, Ltd.” Would Be In The Public Interest and how It Would 

Benefit The Public As A Whole.

Granting the present Petition will further the public interest by allowing Forget Me 

Knot Events Ltd. to safely, efficiently, and economically perform aerial

videography and photography for its clients over areas of the United States.

Many of the proposed operations Forget Me Knot Events Ltd. plans to conduct 

cannot be economically or safely conducted with traditional, manned aircraft. 

Examples include smaller-scale aerial mapping, smaller budget special event 

coverage and certain promotional videography and photography. These services 

are a boon to choices available to the average person or small business owner 

that were not previously available. Additionally, use of listed UA’s will decrease 

congestion of the NAS, reduce pollution, and provide significant benefits to the 

economy.

Notably, the benefits of Forget Me Knot Events Ltd’s. proposed operation of the 

listed UA’s will be realized without implicating any privacy issues.

1. The Public Will Benefit From Decreased Congestion Of The NAS.

The listed UA’s are battery powered and serve as a safe, efficient, and

economical alternative to the manned aircraft traditionally utilized to obtain aerial 

imagery. By reducing the amount of manned aircraft needed to perform aerial 

acquisitions, an exemption allowing the use of listed UA’s would reduce the 

volume of unscheduled, manned aircraft in the NAS, reduce noise and air 

pollution, as well as increase the safety of life and property in the air and on the 

ground.

By reducing the number of unscheduled manned aircraft operating in the NAS 

unpredictable congestion around airports caused by arriving and departing 

aircraft will be reduced. The listed UA’s do not require an airport to takeoff or 

land. Likewise, a reduction of manned aircraft conducting aerial video and 
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photography missions would result in fewer aircraft that must be handled by air 

traffic control during the ground, takeoff, departure, arrival, and landing phases of 

flight operations.

2. The Public Will Benefit From The Safety And Efficiency Of The Listed 

UAS equipment “Forget Me Knot Events, Ltd.” will employ in serving the 

public.

Conducting aerial acquisitions with the listed UA’s, instead of manned

aircraft, will greatly benefit the public by reducing the levels of air and noise 

pollution generated during traditional aerial video and still photography flight 

operations. By using battery power and electric motors, the listed UA’s produce 

no air pollution, and are a viable and environmentally conscious alternative to the 

internal combustion engine aircraft that are typically utilized for aerial

video and photography. The listed UA’s will reduce the carbon footprint of aerial 

acquisitions and eliminate the need for leaded aviation gasoline in this type of an 

operation.

Utilizing the listed UA’s to perform aerial acquisitions will substantially reduce the 

risk to life and property in the air and on the ground compared to gasoline 

reciprocated engine light aircraft conducting on-demand aircraft operations.

Aside from the lack of flight crew members located onboard the aircraft, the listed 

UA’s clearly have significantly less physical potential for collateral damage to life 

and property on the ground in the event of a mishap compared to the manned 

aircraft that typically conduct similar operations. This is due to the small size, 

battery operation and advanced technology available to the listed UA’s. The 

result is the listed UA’s can more accurately conduct missions with many more 

options to abort safely and easily in the event of an unforeseen circumstance.

3. Performing Aerial Video and Photography Operations with the listed UAS 

Will Benefit The Economy.

In addition to being safe and efficient, listed UA’s and UAS are also an

economical alternative to using manned aircraft to conduct similar aerial 

operations. As such, operation of acceptable UAS will allow United States based 

companies, like Forget Me Knot Events Ltd., to remain competitive and 

contribute to innovation and to the growth of the U.S. economy. Specifically, with 

the rising cost of aviation fuel and the Environmental Protection Agency (“EPA”) 

regulatory actions phasing out leaded aviation fuels, U.S. owned and operated 

companies must adopt new and alternative technology in order to remain 

competitive. Operating the battery UAS is one such technology that not only 

allows companies greater operational flexibility compared to manned aircraft, but 

provides such flexibility without the high operational cost of a traditional manned 

aircraft.
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By operating the contemporary UAS, companies such as Forget Me Knot Events 

Ltd. can remain competitive and profitable, and therefore, provide greater job 

stability to employees and contractors, which will ultimately contribute to growth 

of the U.S. economy. Improved financial performance of U.S. companies, 

through innovation and commercial use of UAS, provides a stable workforce that 

results in the following the following: Increases the creativity of society, spurs 

new ideas, increases consumer spending, improves local, state, and federal tax 

revenues and allows companies to invest in research and development in order 

to remain competitive both in the United States and abroad.

4. There Are No Privacy Issues.

Similar to the manned aerial acquisition flight operations that have been

conducted for decades, Forget Me Knot Events Ltd’s. proposed operation of the 

listed UA’s will not implicate any privacy issues. Specifically, the listed UA’s

will be operated only in compliance with operating documents (i.e., the Forget Me 

Knot Events Ltd. Flight Operations Manual, Maintenance Log, and listed UA Ops 

Manuals). Flights are planned well ahead of time, require property owner 

involvement and will be conducted in accordance with the Federal Aviation 

Regulations, including the minimum distance requirements of 14 C.F.R. § 

91.119.

E. Reasons Why Granting The Exemption Would Not Adversely 

Affect Safety; How The Exemption Would Provide A Level Of 

Safety At Least Equal To That Provided By The Rule From Which 

“Forget Me Knot Events, Ltd.” Seeks Exemption.

1. Reasons Why The listed UAS Meet The Conditions Of The FAA

Modernization and Reform Act of 2012 (FMRA) Section 333.

In consideration of the size, weight, speed, and limited operating area associated 

with the unmanned aircraft and its operation, Forget Me Knot Events Ltd. 

operation of the listed UA’s meet the conditions of FMRA Section 333, and will 

not require an airworthiness certificate in accordance with 14 C.F.R. Part 21, 

Subpart H.

Section 333 provides authority for a UAS to operate without airworthiness

certification and sets forth requirements for considering whether a UAS will 

create a hazard to users of the NAS or the public, or otherwise pose a threat to 

national security.

Specifically, FMRA Section 333 states the following, in part:

(a) In General.Notwithstanding

any other requirement of this subtitle, and not later than 180 days after the date 

of enactment of this Act, the Secretary of Transportation shall determine if certain 

unmanned aircraft systems may operate safely in the national airspace system 
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before completion of the plan and rulemaking required by section 332 of this Act 

or the guidance required by section 334 of this Act. (b) Assessment of Unmanned 

Aircraft Systems. In making the determination under subsection (a), the 

Secretary shall determine, at a minimum(1) which types of unmanned aircraft 

systems, if any, as a result of their size, weight, speed, operational capability, 

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

do not create a hazard to users of the national airspace system or the public or 

pose a threat to national security; and (2) whether a certificate of waiver, 

certificate of authorization, or airworthiness certification under section 44704 of 

title 49, United States Code, is required for the operation of unmanned aircraft 

systems identified under paragraph (1). (c) Requirements for Safe Operation. If 

the Secretary determines under this section that certain unmanned aircraft 

systems may operate safely in the national airspace system, the Secretary shall 

establish requirements for the safe operation of such aircraft systems in the 

national airspace system. In seeking this exemption, Forget Me Knot Events Ltd. 

submits that the listed UA’s can operate safely in the NAS pursuant to FMRA 

Section 333, as demonstrated by: (a) the characteristics of the listed UA’s (b) the 

pilot certification requirement; and (c) the specific operating limitations.

a. The Specifications Of The listed UA’s Demonstrate Their

Characteristics.

The listed UA’s do not create a hazard to users of the NAS or the

public, or otherwise pose a threat to national security considering its size, weight, 

speed, and operational capability.

i. Technical Specifications Of The listed UAS.

The technical specifications of the listed UA’s Specifications and Data Sheet

can be found in APPENDIX A.

ii. The listed UAS Autonomous Flight And Navigation Modes

Enable The UASs To Remain Within A Defined Operational Area.

The listed UA’s may be operated in both manual and fully autonomous

flight modes. A complete description of the flight and navigational modes of the 

listed UA’s are provided via web links in Appendix A and examples can be seen 

in certain vendor websites as attached for each listed UA.

iii. The listed UA’s Are Designed For Automatic Return To Home

Point Or Hover In The Event Of Loss Of The Control Link Or

Navigation.

When the Control Link is lost, the listed UA’s with VTOL capability will remain 

stationary, in flight, for 3 seconds or more. If, after 3 seconds, the listed VTOL 

UA’s do not reacquire control link data from the GCS, the UA will operate on the 

basis that the Control Link is lost and the UA will return to the initial launch 

position (RTL) (i.e., failsafe mode) via GPS, and will descend to the

takeoff position and shutdown.
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When the control link is lost, the listed UA’s with HTOL capability will hold in a 

racetrack position. If GCS signal is not regained, the applicable UA will operate 

on the basis that the Control Link is lost and the UA will return to the initial launch 

position (RTL) (i.e., failsafe mode) via GPS. The HTOL UA will descend to the 

takeoff position with motors shutdown and perform an auto glide to landing.

iv. The listed UA’s and their Operation.

A description of the operation and specifications of the listed UA’s are found on 

links provided. In the case of self made UA’s and UAS, these systems are using 

state of the art flight controllers and navigations systems that are “off the shelf” 

technology available to experienced UAV designers like the Petitioner in this 

case. The associated links provided show the auto flight, navigation, GPS, loss 

of Signal reversion capabilities of the Pixhawk controller. The Pixhawk controller 

is a gold standard of late 2015 technology and these protocols are leading the 

way for industry best practices as of today.

The level of safety and functionality of the AVALOFT self made UA’s and UAS 

are as good or better than the off the shelf, consumer UAS that have gained 

exemption thus far.

b. Flight Operations of the listed UA’s are Limited To The Line Of Sight, and 

a certificated Pilot in Command With A Safety Observer is required to 

operate.

Forget Me Knot Events Ltd. will only utilize certificated and current pilots to act as 

a PIC’s of listed UA’s under commercial flights, while under operational control of 

Forget Me Knot Events Ltd. Additionally, a safety observer (SO) will assist all 

PIC’s during Commercial Missions and Official Training Events.

c. Flights of all listed UA’s Will Be Conducted Pursuant To Specific 

Operating Limitations.

1. Operations authorized by this grant of exemption are limited to the 

Approved listed UA’s, weighing less than 55 pounds including payload. 

Proposed operations of any other aircraft will require a new petition or a petition 

to amend this exemption.

2. Operations for the purpose of closed-set motion picture and television filming 

are not permitted.

3. The UA may not be operated at a speed exceeding 87 knots (100

miles per hour). The exemption holder may use either groundspeed or calibrated 

airspeed to determine compliance with the 87 knot speed restriction. In no case 

will the UA be operated at airspeeds greater than the maximum UA operating 

airspeed recommended by the aircraft manufacturer.

4. The UA must be operated at an altitude of no more than 400
23

feet above ground level (AGL). Altitude must be reported in feet AGL.

5. Each flight will have a Pilot in Command (PIC) designated before flight 

commences. The UA 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. The PIC, as designated before 

the flight, cannot transfer his or her designation for the duration of the flight.

6. All operations must utilize a Safety Observer (SO). The UA must be operated 

within the visual line of sight (VLOS) of the PIC and SO at all times. The SO may 

be used to satisfy the VLOS requirement as long as the PIC always maintains 

VLOS capability. The SO will not be tasked with any other duties, outside of the 

safety and observation duties of the flight environment and UA that are 

immediately required of a SO. The SO and PIC must be able to communicate 

verbally at all times. Electronic messaging or texting is not permitted during flight 

operations. The PIC must ensure that the SO is capable and able to perform the 

duties required of the SO.

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

operation 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. Any UAS that has undergone maintenance or alterations that affect the UAS 

operation or flight characteristics, e.g., replacement of a flight critical component, 

must undergo a functional test flight prior to conducting further operations under 

this exemption. Functional test flights will only be conducted by a PIC with a SO 

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.
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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.,inoperative components, systems, or 

equipment. If the inspection reveals a condition that affects, or will effect 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 14CFR §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 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 SOs (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 non-participants. The PIC must operate the UA 

with appropriate distance from non-participants in accordance with 14

CFR § 91.119.

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

CFR § 1.1. All operations must be conducted under visual meteorological 

conditions (VMC). Flights under special visual flight rules (SVFR) are not 

authorized.
25

16. 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.

17. The UA may not be operated less than 500 feet below or less than 2,000

feet horizontally from a cloud or when visibility is less than 3statute miles from 

the PIC.

18. For tethered UAS operations, the tether line must have colored pennants or 

streamers attached at not more than 50 foot intervals beginning at 150 feet 

above the surface of the earth and visible from at least one mile. This 

requirement for pennants or streamers is not applicable when operating 

exclusively below the top of and within 250 feet of any structure, so long as the 

UA operation does not obscure the lighting of the structure.

19. If the UAS loses communications with the GCS or loses its GPS signal, the 

UA must return to a pre-determined location within the private or controlledaccess property.

20. The PIC must abort the flight if obstacles or events posing a safety hazard to 

continued mission operations occur, or in all cases, in the event of any other UAS 

system emergency.

21. 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 4 minutes 

and 30 seconds, or with the reserve power recommended by the manufacturer if 

greater.

22. Air Traffic Organization (ATO) Certificate of Waiver or Authorization (COA). 

All operations shall be conducted in accordance with an ATO-issued COA. The 

exemption holder may apply for a new or amended COA if it intends to conduct 

operations that cannot be conducted under the terms of the enclosed COA.

23. All aircraft operated in accordance with this exemption must be identified by 

serial number, registered in accordance with 14CFR part 47, and have 

identification (N−Number) markings in accordance with 14CFR part 45, Subpart 

C. Markings must be as large as practicable.
26

24. Documents used by the operator to ensure the safe operation and flight of

the UAS and any documents required under 14CFR §§ 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.

25. The UA must remain clear and give way to all manned aviation operations 

and activities at all times.

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

vehicle. 

27. 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, SO, operator trainees or essential 

persons are not considered nonparticipating persons under this exemption.

28. 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.

29. 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.

If this exemption permits operations for the purpose of closed-set motion picture 

and television filming and production, the following additional conditions and 

limitations apply.

30. The operator must have a motion picture and television operations manual 

(MPTOM) as documented in this grant of exemption.

31. At least 3 days before aerial filming, the operator of the UAS affected by this 

exemption must submit a written Plan of Activities to the local Flight Standards 

District Office (FSDO) with jurisdiction over the area of proposed filming. The 3-
27

day notification may be waived with the concurrence of the FSDO. 

The plan of activities must include at least the following:

a. Dates and times for all flights;

b. Name and phone number of the operator for the UAS aerial filming conducted 

under this grant of exemption;

c. Name and phone number of the person responsible for the on-scene 

operation of the UAS;

d. Make, model, and serial or N−Number of UAS to be used;

e. Name and certificate number of UAS PICs involved in the aerial filming;

f. A statement that the operator has obtained permission from property owners 

and/or local officials to conduct the filming production event; the list of those who 

gave permission must be made available to the inspector upon request;

g. Signature of exemption holder or representative; and

h. A description of the flight activity, including maps or diagrams of any area, 

city, town, county, and/or state over which filming will be conducted and the 

altitudes essential to accomplish the operation.

32. Flight operations may be conducted closer than 500 feet from participating 

persons consenting to be involved and necessary for the filming production, as

specified in the exemption holder’s MPTOM. Unless otherwise specified in this 

grant of exemption, the UAS, the UAS PIC, and the UAS operations must comply 

with all applicable parts of 14 CFR including, but not limited to, parts 45, 47, 61, 

and 91. http://www.ntsb.gov/

2. Reasons Why An Exemption From The Requirements Of 14 C.F.R. Part

21, Subpart H and Sections 91.203(a) and 91.203(b) and 14 C.F.R. Part 27

Would Not Adversely Affect Safety.

The listed UA’s are less than 55 lbs. fully loaded. They carry neither a pilot nor

passenger, and carry no explosive materials or flammable liquid fuels. Unlike 

other civil aircraft, the proposed operations in this petition for exemption will be 

controlled and monitored by the operator in accordance with Forget Me Knot 

Events Ltd. Flight Operations Manual, Maintenance Log and specific US 

operations manual. These safety practices, which already apply to civil aircraft 

operated in connection with existing inspection operations, provide an equivalent 

of greater degree of safety to the public and property owners than conventional 

operations conducted with airworthiness certificates issued under 14 C.F.R. Part 

21, Subpart H.

Lastly, application of these same criteria demonstrates that there is no credible 

threat to national security posed by the listed UAS, 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. To the extent of Part 27's 

airworthiness standards, safety will not be adversely be affected for the same 

reasons identified in the response from 14 C.F.R. Part 21, Subpart H.
28

3. Reasons Why An Exemption From The Requirements Of Sections

91.9(c), 45.23(b) and 45.27(a) Would Not Adversely Affect Safety.

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

identification requirements of sections 91.9(c), 45.23(b) and 45.27(a), will be 

provided by having the listed UAS marked on its fuselage as required by 

§45.29(f) where the pilot, observer, and others working with the listed UAS will 

see the identification of the UAS as "Experimental." Additionally, Petitioner will 

ensure compliance with any requests of UAS rulemaking by the FAA.

4. Reasons Why An Exemption From The Requirements Of Sections

Section 61.23(a) Would Not Adversely Affect Safety.

In Exemption No. 11213 to Aeryon Labs, Inc., the FAA “finds that, because of the

risk mitigations established in the conditions and limitations of this exemption, a 

person that holds a U.S. issued driver’s license who is operating a UAS will not 

adversely affect safety. The FAA is granting relief from § 61.23(a) to allow any 

pilot that holds one of the pilot’s certificates discussed above to operate a UAS 

under this exemption with a U.S. issued driver’s license, in lieu of an FAA issued 

medical certificate. The FAA is also granting relief from § 61.23(c) to allow sport 

pilot certificate holders to operate aircraft other than LSA with a U.S. issued 

driver’s license under this exemption.”

5. Reasons Why An Exemption From The Requirements Of Sections

61.101(e)(4) & (e)(5), 61.113(a), and 61.315(a) Would Not Adversely Affect

Safety.

Forget Me Knot Events Ltd. submits that an equivalent level of safety

established by Sections 61.101(e)(4) & (e)(5), 61.113(a), and 61.315(a) will be

maintained because no PIC will be allowed to operate a listed UA unless that PIC 

has demonstrated, by meeting minimum demonstrated training currency 

requirements, that the PIC is able to safely operate the listed UA in a manner 

consistent with the exemption. This includes evasive / emergency maneuvers 

and maintaining appropriate distances from people, vessels, vehicles, and 

structures. Considering the Forget Me Knot Event Ltd. proposed area of 

operations, and the operating limitations set forth above, the shared nature of 

sport pilot through ATP certificate holder ensures appropriate aeronautical 

knowledge requirements. This will allow safe and effective flight operations with 

the listed UA’s (See Exemption Nos.11062 and 11213); and the airmanship 

skills necessary to safely operate the listed UAS. 

Forget Me Knot Events Ltd. submits that the additional manned aircraft 

experience of a commercially certificated pilot would not correlate to the 

airmanship, knowledge, skills and decision-making skills necessary for Forget Me 

Knot Event Ltd’s specific proposed flight operations. The FAA has previously 

granted relief from Sections 61.101(e)(4) & (e)(5) and

61.315(a) specific to UAS, in circumstances similar, in all material respects, to 

those presented herein (e.g. Exemption Nos. 11213, 11221, 11222, 11223, 
29

11224, 11225,11226, 11227, 11228, 11229, 11230, 11237, 11238, 11239, 

11240, 11241). Additionally, the FAA has previously granted relief from Section 

61.113(a) specific to UAS, in circumstances similar, in all material respects, to 

those presented herein (e.g. Exemption Nos. 11062, 11063, 11064, 11065, 

11066, 11067, 11080, 11109, 11110,11136, 11138, 11150, 11153, 11156, 

11158, 11159, 11160, 11161, 11170, 11171,11172, 11174, 11176, 11177, 

11178, 11184, 11185, 11188, 11189, 11191, 11192,11193, 11194, 11195, 

11204, 11206, 11208, 11209, 11213, 11215, 11216, 11217,11218, 11220, 

11221, 11222, 11223, 11224, 11225, 11226, 11227, 11228, 11229,

11230, 11237, 11238, 11239, 11240, 11241).

Forget Me Knot Events Ltd. will not allow any PIC to operate a listed

UA unless that PIC has demonstrated, by meeting minimum training and 

currency requirements that the PIC is able to safely operate the listed UA in a 

manner consistent with this exemption. This includes evasive and emergency 

maneuvers; maintaining appropriate distances from people, vessels, vehicles 

and structures; SOP’s for Preflight Planning, Mission Execution and Post Flight 

duties.

Specifically, the PIC must have accumulated and logged, in a manner consistent 

with 14 C.F.R. § 61.51(b), 25 hours of total time as a UAS pilot (with a minimum 

of 5 hours of those hours as a UAS pilot operating the same make and model of 

UAS to be used for operations under the exemption). In addition to the hour 

requirements, the PIC must accomplish 3 takeoffs and landings in the preceding 

90 days for flight currency purposes.

As in Exemption Nos. 11062, 11138, and 11153, prior documented flight

experience that was obtained in compliance with applicable regulations will 

ensure an equivalent level of safety during Forget Me Knot Events Ltd’s 

proposed operations. The Administrator has held that prior documented flight 

experience that was obtained in compliance with applicable regulations would 

ensure safe operations, stating as follows:

In Exemption No. 11062, the FAA required that prior to conducting operations for 

the purpose of motion picture filming (or similar operations), the PIC must have 

accumulated and logged, in a manner consistent with 14 CFR 61.51(b), 25 hours 

of total time as a UAS rotorcraft pilot including at least 10 hours logged as a UAS 

pilot with a multirotor UAS. Prior to operations under Exemption No. 11062, the 

PIC must also have accumulated and logged a minimum of 5 hours as a UAS 

pilot operating the same make and model of UAS to be used for operations under 

the exemption. For clarification, the FAA considers these minimum hour 

requirements to be inclusive rather than additive; i.e. 5 hours make and model 

time may be included in the 10 hours of multirotor time and the 10 hours may be 

included in the total 25 hours of UAS rotorcraft time. In addition to the hour 

requirements, the PIC must accomplish 3 takeoffs and landings in the preceding 

90 days (for currency purposes). The FAA finds that at a minimum, the flight hour 
30

requirements in Exemption No. 11062 are appropriate to practice and build 

proficiency in the skills necessary to safely conduct Forget Me Knot Event Ltd’s, 

proposed operations. The FAA also finds that prior documented flight experience 

that was obtained in compliance with applicable regulations would satisfy this 

requirement. Training, proficiency, and experience building flights can also be 

conducted under the grant of exemption to accomplish the required flight time. 

During training, proficiency, and experience building flights the PIC is required to 

operate the UA with appropriate distances in accordance with 14

C.F.R 91.119,(Exemption No. 11138 at page 15). Forget Me Knot Events will 

ensure safe operations by not allowing any PIC to operate a listed UA unless that 

PIC has demonstrated, by meeting minimum flight hour and currency 

requirements, that the PIC is able to safely operate the listed UA in a manner 

consistent with the exemption, including evasive and emergency maneuvers and 

maintaining appropriate distances from people, vessels, vehicles and structures.

6. Reasons Why An Exemption From The Requirements Of Section 91.7(a)

Would Not Adversely Affect Safety.

The equivalent level of safety established by Section 91.7(a) will be maintained

because prior to every flight, Forget Me Knot Events, Ltd. will ensure that the 

listed UA is in an airworthy condition based upon best practices and operating 

documents and as stated in the conditions and limitations herein. Additionally, 

the FAA has previously granted relief from Section 91.7(a) specific to UAS, in 

circumstances similar, in all material respects, to those presented herein

(e.g. Exemption Nos. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 

11109,11110, 11112, 11136, 11138, 11150, 11153, 11156, 11157, 11158, 

11159, 11160,11161).

7. Reasons Why An Exemption From The Requirements Of Section 91.103

Would Not Adversely Affect Safety.

An equivalent level of safety will be ensured while following Forget Me Knot 

Events Ltd. Flight Operations Manual, Maintenance Log Procedures and Specific 

UA operations manuals. The PIC will take all actions, including reviewing 

weather reports and forecasts, NOTAMS, Mission Requirements including flight 

battery requirements, landing and takeoff Requirements and aircraft performance 

calculations. This preflight planning will occur before initiation of flight. During 

the flight, a continual assessment of aeronautical decision making and mission 

status will validate progress or initiate a need to re-evaluate the mission status.

8. Reasons Why An Exemption From The Requirements Of Section

91.109(a).Would Not Adversely Affect Safety.

Given the size and speed of the listed UAS, an equivalent level of safe training 

can still be performed without dual controls because no pilot or passengers are 

aboard the UAS. All persons will be a safe distance away should the UAS 

experience any difficulties during flight instruction. Based on over 80 years of 
31

documented model aviation experience via AMA records: Safe and effective 

miniature, automated and remotely controlled aircraft training operations are 

easily and safely achieved via preflight briefings, pre planned training objectives 

and communication during training via careful instruction and supervision.

9. Reasons Why An Exemption From The Requirements Of Section

91.119(c) Would Not Adversely Affect Safety.

The equivalent level of safety established by Section 91.119(c) will be maintained 

because in any operation to be conducted closer than 500 feet from any 

nonparticipating persons, barriers or structures will be present to sufficiently 

protect any nonparticipating persons from debris in the event of an accident 

during operation of a listed UA which weighs less than 55 pounds and will be 

operated below an altitude of 400 feet AGL. The nonparticipating persons will be 

required to remain in the area of protection, and if any nonparticipating person 

leaves the area of protection and is within 500 feet of the listed UA, flight 

operations will divert and / or cease immediately.

Additionally, any operation to be conducted closer than 500 feet from persons,

vessels, vehicles, and structures would first require the permission of the land

owner/controller and a safety assessment of the risk of operating closer to those 

objects will be carried out by the PIC. See (Exemption Nos. 11204 and 11224). 

Additionally, the FAA has previously granted relief from Section 91.119(c) 

specific to UAS, in circumstances similar, in all material respects, to those 

presented herein (e.g. Exemption Nos. 11062,11063, 11064, 11065, 11066, 

11067, 11080, 11109, 11110, 11111, 11112, 11114,11136, 11138, 11150, 

11153, 11156, 11157, 11158, 11159, 11160, 11161, 11166,11167, 11170, 

11171, 11172, 11174, 11176, 11177, 11178, 11184, 11185, 11188,11189, 

11191, 11192, 11193, 11194, 11195, 11204, 11206, 11208, 11209, 

11213,11215, 11216, 11217, 11218, 11220, 11221, 11222, 11223, 11224, 

11225, 11226,11227, 11228, 11229, 11230, 11237, 11238, 11239, 11240, 

11241).

10. Reasons Why An Exemption From The Requirements Of Section 91.121

Would Not Adversely Affect Safety.

The equivalent level of safety established by Section 91.121 will be maintained

because the altitude information of listed UA will be provided to the PIC via

GPS equipment and a telemetry data link. This data communication downlinks 

from the UA to the GCS for active monitoring of the flight path and altitude. This 

altitude information, combined with operating the listed UA within visual line of 

sight, at or below 500 feet AGL, will ensure a level of safety equivalent to Section 

91.121.

The altitude information will be generated by GPS equipment installed onboard 

the aircraft. Prior to each flight, a zero altitude initiation point is automatically 
32

established by the UAS at ground level. The FAA has previously granted relief 

from Section 91.121 specific to UAS, in circumstances similar, in all material 

respects, to those presented herein (e.g. Exemption Nos. 11062, 11063, 11064, 

11065, 11066, 11067, 11080, 11109, 11112,11136, 11138, 11150, 11153, 

11156, 11157, 11158, 11159, 11160, 11161).

11. Reasons Why An Exemption From The Requirements Of Section

91.151(b) Would Not Adversely Affect Safety.

A grant of this exemption would ensure an equivalent level of safety established

by 14 C.F.R. Section 91.151(b) as a result of (1) the technical specifications the 

listed UA’s (2) the limitations on the proposed flight operations; and (3) the 

location of the proposed flight operations.

Accordingly, Forget Me Knot Events Ltd. will ensure that it will safely operate the 

listed UA during daylight hours in VFR conditions, with enough battery power to 

fly for a total planned mission duration to the first point of intended landing and, 

assuming normal cruising speed, to fly after that for at least 4.5 minutes. This will 

ensure an equivalent level of safety established by 14 C.F.R. Section 91.151(b).

Furthermore, safety will be ensured as the listed UA’s provide audible

and visual warnings to the PIC at the GCS when the UAs experiences low 

battery voltage. The first warning occurring at approximately 33% remaining 

battery power, and again at approximately 10% remaining battery power.

Significantly, previous exemptions granted by the FAA concerning Section

91.151 establish that safety is not adversely affected when the technical 

characteristics and operating limitations of the UAS are considered. Relief has 

been granted for manned aircraft to operate at less than the minimums 

prescribed in Section 91.151, including Exemption Nos. 2689, 5745, and 10650. 

Moreover, the FAA has previously granted relief from Section 91.151 specific to 

UAS, in circumstances similar, in all material respects, to those presented herein 

(e.g. Exemption Nos. 8811, 10808, 10673,

11042, 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 

11136,11138, 11150, 11153, 11156, 11157, 11158, 11159, 11160, 11161).

12. Reasons Why An Exemption From The Requirements Of Sections

91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), And 91.417(a) & (b) Would Not

Adversely Affect Safety.

In seeking this exemption, Forget Me Knot Events Ltd. submits that the

equivalent level of safety with regard to the regulatory maintenance and 

alteration requirements established by Sections 91.405(a), 91.407(a)(1), 

91.409(a)(1) & (a)(2), and 91.417(a) &(b) will be met because Forget Me Knot 

Events Ltd. will use trained technicians to perform maintenance, alterations, or 

preventive maintenance on the UAS systems using the methods, techniques, 

and practices prescribed in the operating documents (Forget Me Knot Events 
33

Ltd. Flight Operations Manual, Maintenance Log, and listed UA Operations 

Manual).

Furthermore, Forget Me Knot Events Ltd. will document and maintain all 

maintenance records for the approved UAS. Since the approved UAS will be 

inspected as prescribed by the operating documents, Forget Me Knot Events Ltd. 

will maintain the equivalent level of safety established by Sections 91.405(a), 

91.409(a)(1), and 91.409(a)(2). Likewise, the exemption sought will not 

adversely affect safety because Forget Me Knot Events Ltd. will use trained 

technicians to perform repairs, alterations or preventive maintenance on the UAS 

using the methods, techniques, and practices prescribed by the operating 

documents. The exemption sought would maintain an equivalent level of safety 

established by Sections 91.407, 91.417(a) and 91.417(b), because all 

maintenance of the approved UAS will be performed by trained technicians. 

Maintenance will be documented and maintained utilizing the Forget Me Knot 

Events Ltd. Maintenance Log.

Significantly, previous exemptions granted by the FAA concerning Sections

91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b) establish that 

safety is not adversely affected when the technical characteristics and operating 

limitations of the approved UAS are considered.

In consideration of Forget Me Knot Events Ltd’s proposed operating

limitations, the operating documents, and the technical aspects of the approved 

UAS, Forget Me Knot Events Ltd. submits that safety will not be adversely 

affected by granting exemption from 14 C.F.R. Sections 91.405(a), 91.407(a)(1) 

and (a)(2), 91.409(a)(2), and 91.417(a) and (b). The FAA has previously granted 

relief specific to UAS in circumstances similar, in all material respects, to those 

presented herein (e.g. Exemption Nos. 11062, 11063, 11064, 11065, 11066, 

11067, 11080, 11109, 11110, 11112, 11136, 11138, 11150, 11153, 11156, 

11157, 11158, 11159, 11160, 11161).

13. The FAA May Prescribe Any Other Conditions For Safe Operation.

In accordance with Section 333 of the FAA Modernization and Reform Act of

2012 (FMRA) and 14 C.F.R. § 21.16 entitled Special Conditions, Forget Me Knot 

Events Ltd. requests that the FAA prescribe special conditions for the intended

operation of listed UA’s, which contain such safety standards that the

Administrator finds necessary to establish a level of safety equivalent to that 

established by 14 C.F.R. Part 21, Subpart H, and 14 C.F.R §§ 61.113(a) & (b), 

91.7 (a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 

91.417(a) & (b).

Such special conditions will permit safe operation of the listed UA’s for the limited 

purpose of conducting aerial video and photography over certain areas of the 

United States for compensation or hire. FMRA Section 333 sets forth the 

requirements for considering whether a UAS will create a hazard to users of the 
34

NAS or the public, or otherwise pose a threat to national security; and further, 

provides the authority for such UAS to operate without airworthiness certification 

in accordance with any requirements that must be established for the safe 

operation of the UAS in the NAS. Likewise, the Administrator may prescribe 

special conditions pursuant to 14 C.F.R. § 21.16, for operation of the listed UA’s, 

since the airworthiness regulations of 14 C.F.R. Part 21 do not contain adequate 

or appropriate safety standards, due to the novel or unusual design features of 

the aircraft. Section 21.16, entitled Special Conditions, states the following:

If the FAA finds that the airworthiness regulations of this subchapter do not

contain adequate or appropriate safety standards for an aircraft, aircraft engine,

or propeller because of a novel or unusual design feature of the aircraft, aircraft

engine or propeller, he prescribes special conditions and amendments thereto for 

the product. The special conditions are issued in accordance with Part 11 of this 

chapter and contain such safety standards for the aircraft, aircraft engine or

propeller as the FAA finds necessary to establish a level of safety equivalent to

that established in the regulations. See 14 C.F.R. § 21.16.

Therefore, in accordance with FMRA Section 333 and 14 C.F.R. § 21.16, the

FAA may prescribe special conditions for Forget Me Knot Events Ltd’s intended

operation of the approved UAS, which contain such safety standards that the

Administrator finds necessary to establish a level of safety equivalent to that 

established by 14 C.F.R. Part 21, Subpart H, and 14 C.F.R Sections 61.113(a) & 

(b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), 

and 91.417(a) & (b).

F. A Summary That Can Be Published In The Federal Register, 

stating: The Rules From Which Forget Me Knot Events Ltd. 

Seeks Exemption:

Forget Me Knot Events Ltd. seeks exemption from the requirements of 14 C.F.R

Part 21, subpart H, Part 27, 45.23(b), 45.27(a), 61.23(a) and (c), 61.101(e)(4)

and (5), 61.113(a) & (b), 61.113(a) & (b), 61.315(a), 91.7(a), 91.9(b), 91.119(c),

91.121, 91.151(b), 91.203(a) and (b), 91.405(a), 91.407(a)(1), 91.409(a)(1) &

(a)(2), and 91.417(a) & (b).

A Brief Description Of The Nature Of The Exemption Forget Me Knot Events 

Ltd. Seeks:

This exemption will permit Forget Me Knot Events Ltd. to commercially operate

an Unmanned Aircraft System (UAS) for the purpose of conducting aerial video

and photography over certain areas of the United States.
35

G. Any Additional Information, Views, Or Arguments Available To Support

Applied Art & Technology, LLC’s Request.

This Petition is made pursuant to the FAA Modernization and Reform Act of 2012 

(FMRA) Section 333, which directs the Secretary of Transportation to determine 

if certain UAS may operate safely in the NAS. As such, Forget Me Knot Events 

Ltd’s request for exemption may be granted pursuant to the authority of FMRA 

Section 333 and 14 C.F.R. Part 11, as set forth above.

FMRA Section 333 sets forth the requirements for considering whether a UAS

will create a hazard to users of the NAS or the public, or otherwise pose a threat 

to national security; and further, provides the authority for such UAS to operate 

without airworthiness certification. As discussed in detail above, Forget Me Knot 

Events Ltd. will operate the listed UA’s safely in the NAS, without creating a 

hazard to users of the NAS, or the public, or otherwise pose a threat to national 

security.
36

CONCLUSION

As set forth herein, Forget Me Knot Events Ltd. d.b.a. AeroNautic Works, seeks 

an exemption pursuant to 14 C.F.R. § 11.61 and Section 333 of the FAA 

Modernization and Reform Act of 2012 (FMRA), which will permit safe operation 

of the approved UAS commercially, without an airworthiness certificate, for the 

limited purpose of conducting aerial video and photography over certain areas of 

the United States.

By granting this Petition, the FAA Administrator will be fulfilling the Congressional 

mandate of the FAA Modernization and Reform Act of 2012, while also 

advancing the interests of the public, by allowing Forget Me Knot Events Ltd. to 

safely, efficiently, and economically operate the approved UAS commercially, 

within the NAS.

Therefore, in accordance with the Federal Aviation Regulations and the FAA 

Modernization and Reform Act of 2012, Section 333, Forget Me Knot Events Ltd.

respectfully requests that the Administrator grant this Petition for an exemption 

from the requirements of 14 C.F.R Part 21, subpart H, Part 27, 45.23(b), 

45.27(a), 61.23(a) and (c), 61.101(e)(4) and (5), 61.113(a) & (b), 61.113(a) & (b), 

61.315(a), 91.7(a), 91.9(b), 91.119(c), 91.121, 91.151(b), 91.203(a) and (b), 

91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b), and permit 

Forget Me Knot Events Ltd. to operate the approved UAS commercially for the 

purpose of conducting aerial video and photography over certain areas of the 

United States.

Dated: 15 December, 2015

Respectfully submitted,

Edward A. Putnam

Forget Me Knot Events Ltd.

d.b.a AeroNautic Works

15962 Green Springs Drive

Reno, NV 89511 USA

Phone and Email will be sent separately for privacy

Appendices:

A. Listed UA’s

B. Flight Operations Manual

C. Specific UAS checklists and procedures

D. Maintenance Log
37

APPENDIX - A

LISTED UNMANNED AIRCRAFT (LISTED UA’s):

Appendix A is listed and sent in a separate document to protect proprietary 

information and processes.

APPENDIX – B

FLIGHT OPERATIONS MANUAL

Appendix B is listed and sent in a separate document to protect proprietary 

information and processes.

APPENDIX – C

SPECIFIC UAS CHECKLISTS AND PROCEDURES

Appendix C is listed and sent in a separate document to protect proprietary 

information and processes.

APPENDIX – D

MAINTENCE LOG

Appendix D is listed and sent in a separate document to protect proprietary 

information and processes.