April 20, 2015 

 Exemption No. 11394 

 Regulatory Docket No. FAA–2015–0160 

Mr. Craig E. Bryan 

Chief Pilot 

Cirrus Exploration Company 

3423 South Soncy Road, Suite 200 

Amarillo, TX 79119 

Dear Mr. Bryan: 

This letter is to inform you that we have granted your request for exemption. It transmits our 

decision, explains its basis, and gives you the conditions and limitations of the exemption, 

including the date it ends. 

The Basis for Our Decision 

By letter posted January 23, 2015, you petitioned the Federal Aviation Administration (FAA) 

on behalf of Cirrus Exploration Company (hereinafter petitioner or operator) for an 

exemption. The exemption would allow the petitioner to operate an unmanned aircraft system 

(UAS) to conduct flight instruction, commercial aerial work flight operations, student 

instruction, aerial photography and survey, and power line or pipeline patrol. 

See Appendix A for the petition submitted to the FAA describing the proposed operations and 

the regulations that the petitioner seeks an exemption. 

The FAA has determined that good cause exists for not publishing a summary of the petition 

in the Federal Register because the requested exemption would not set a precedent, and any 

delay in acting on this petition would be detrimental to the petitioner. 
2 

Airworthiness Certification 

The UAS proposed by the petitioner are the DJI Phantom 2 Vision+ and a DJI Inspire 1. 

In accordance with the statutory criteria provided in Section 333 of Public Law 112−95 in 

reference to 49 U.S.C. § 44704, and in consideration of the size, weight, speed, and limited 

operating area associated with the aircraft and its operation, the Secretary of Transportation 

has determined that this aircraft meets the conditions of Section 333. Therefore, the FAA 

finds that relief from 14 CFR part 21, Certification procedures for products and parts, 

Subpart H—Airworthiness Certificates, and any associated noise certification and testing 

requirements of part 36, is not necessary. 

The Basis for Our Decision 

You have requested to use a UAS for aerial data collection. The FAA has issued grants of 

exemption in circumstances similar in all material respects to those presented in your petition. 

In Grants of Exemption Nos. 11062 to Astraeus Aerial (see Docket No. FAA−2014−0352), 

11109 to Clayco, Inc. (see Docket No. FAA−2014−0507), 11112 to VDOS Global, LLC (see

Docket No. FAA−2014−0382), and 11213 to Aeryon Labs, Inc. (see Docket No. 

FAA−2014−0642), the FAA found that the enhanced safety achieved using an unmanned 

aircraft (UA) with the specifications described by the petitioner and carrying no passengers or 

crew, rather than a manned aircraft of significantly greater proportions, carrying crew in 

addition to flammable fuel, gives the FAA good cause to find that the UAS operation enabled 

by this exemption is in the public interest. 

Having reviewed your reasons for requesting an exemption, I find that— 

 They are similar in all material respects to relief previously requested in Grant of 

Exemption Nos. 11062, 11109, 11112, and 11213; 

 The reasons stated by the FAA for granting Exemption Nos. 11062, 11109, 11112, and 

11213 also apply to the situation you present; and 

 A grant of exemption is in the public interest. 

Our Decision 

In consideration of the foregoing, I find that a grant of exemption is in the public interest. 

Therefore, pursuant to the authority contained in 49 U.S.C. 106(f), 40113, and 44701, 

delegated to me by the Administrator, Cirrus Exploration Company is granted an exemption 

from 14 CFR §§ 61.23(a) and (c), 61.101(e)(4) and (5), 61.113(a), 61.315(a), 91.7(a), 

91.119(c), 91.121, 91.151(a)(1), 91.405(a), 91.407(a)(1), 91.409(a)(1) and (2), and 91.417(a) 

and (b), to the extent necessary to allow the petitioner to operate a UAS to perform aerial data 

collection. This exemption is subject to the conditions and limitations listed below. 
3 

Conditions and Limitations 

In this grant of exemption, Cirrus Exploration Company is hereafter referred to as 

the operator. 

Failure to comply with any of the conditions and limitations of this grant of exemption will be 

grounds for the immediate suspension or rescission of this exemption. 

1. Operations authorized by this grant of exemption are limited to the DJI Phantom 2 

Vision+ and DJI Inspire 1 when 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 feet above ground level 

(AGL). Altitude must be reported in feet AGL. 

5. 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. 

6. All operations must utilize a visual observer (VO). The UA must be operated within 

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

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

capability. The VO and PIC must be able to communicate verbally at all times; 

electronic messaging or texting is not permitted during flight operations. The PIC must 

be designated before the flight and cannot transfer his or her designation for the 

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

required of the VO. 

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

operations in accordance with the conditions and limitations stated in this grant of 

exemption, are hereinafter referred to as the operating documents. The operating 

documents must be accessible during UAS operations and made available to the 

Administrator upon request. If a discrepancy exists between the conditions and 
4 

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 may only be conducted by a PIC with a VO and must remain at 

least 500 feet from other people. The functional test flight must be conducted in such 

a manner so as to not pose an undue hazard to persons and property. 

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

in a condition for safe operation. 

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

UAS is in a condition for safe flight. The pre-flight inspection must account for all 

potential discrepancies, e.g. inoperable components, items, or equipment. If the 

inspection reveals a condition that affects the safe operation of the UAS, the aircraft is 

prohibited from operating until the necessary maintenance has been performed and the 

UAS is found to be in a condition for safe flight. 

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

replacement, inspection, and life limit requirements for the aircraft and 

aircraft components. 

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

safety bulletins. 

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

commercial, private, recreational, or sport pilot certificate. The PIC must also hold a 

current FAA airman medical certificate or a valid U.S. driver’s license issued by a 

state, the District of Colombia, Puerto Rico, a territory, a possession, or the Federal 

government. The PIC must also meet the flight review requirements specified in 

14 CFR § 61.56 in an aircraft in which the PIC is rated on his or her pilot certificate. 
5 

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 VOs 

(training, proficiency, and experience-building) and determining the PIC’s ability to 

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

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

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

training, proficiency, and experience-building flights, all persons not essential for 

flight operations are considered nonparticipants, and the PIC must operate the UA 

with appropriate distance from nonparticipants in accordance with 14 CFR § 91.119. 

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

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

under special visual flight rules (SVFR) are not authorized. 

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 3 statute miles from the PIC. 

18. If the UAS loses communications or loses its GPS signal, the UA must return to a 

pre-determined location within the private or controlled-access property. 

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

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

weather conditions) there is enough available power for the UA to conduct the 

intended operation and to operate after that for at least five minutes or with the reserve 

power recommended by the manufacturer if greater. 

21. 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 attached COA. 
6 

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

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

(N−Number) markings in accordance with 14 CFR part 45, Subpart C. Markings must 

be as large as practicable. 

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

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

PIC at the Ground Control Station of the UAS any time the aircraft is operating. These 

documents must be made available to the Administrator or any law enforcement 

official upon request. 

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

activities at all times. 

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

26. All Flight operations must be conducted at least 500 feet from all nonparticipating 

persons, vessels, vehicles, and structures unless: 

a. Barriers or structures are present that sufficiently protect nonparticipating persons 

from the UA and/or debris in the event of an accident. The operator must ensure 

that nonparticipating persons remain under such protection. If a situation arises 

where nonparticipating persons leave such protection and are within 500 feet of 

the UA, flight operations must cease immediately in a manner ensuring the safety 

of nonparticipating persons; and 

b. The owner/controller of any vessels, vehicles or structures has granted permission 

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

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

present an undue hazard. 

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

nonparticipating persons under this exemption. 

27. 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. 

28. 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. 
7 

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. 

29. The operator must have a motion picture and television operations manual (MPTOM) 

as documented in this grant of exemption. 

30. 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-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. 

31. 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. 

 
8 

This exemption terminates on April 30, 2017, unless sooner superseded or rescinded. 

Sincerely, 

/s/ 

John S. Duncan 

Director, Flight Standards Service 

 
Petition for Exemption 

(Pursuant to 14 CFR Section 11.81) 

Identification of Petitioner 

This petition for exemption is submitted on behalf of Cirrus Exploration Company including its chief pilot, Craig 

E Bryan (collectively referred to as "Cirrus"), 3423 S Soncy Road, Suite 200, Amarillo, Texas 79119-4972, (via 

email at cbryan@cirrushelicopter.com ). 

Petition Based Upon Prior Exemption 

This petition is based, in part, upon prior exemption granted pursuant to In the matter of Douglas Trudeau, 

Realtor (Regulatory Docket No. FAA-2014-0481, Exemption issued lanuary 5, 2015). 

Request for Exemption 

Cirrus respectfully requests relief from the following regulations for the purpose of conducting flight instruction 

and commercial "aerial work" flight operations (as defined by 14 CFR Section 119.1(e)(1) Student instruction, 

Section 119.1(e)(4)(iii) Aerial photography or survey, and Section 119.1(e)(4)(vi) Powerline or pipeline patrol) 

utilizing DJI Phantom 2 Vision + and DJI Inspire 1 Unmanned Aerial Systems ("UAS"): 

Part 21 prescribing the procedural requirements for issuing and changing design approvals, productions 

approvals, airworthiness certificates, and airworthiness approvals. (Cirrus believes relief from this section 

is not necessary under the statutory criteria provided in Section 333 of Public Law 112-95 [P.L. 112-95] in 

reference to 49 USC Section 44794 given the size, weight, speed, and limited operating area associated 

with the proposed UAS) 

Section 45.23(b) prescribing that when marks include only the Roman capital letter "N" and the 

registration number is displayed on limited, restricted or light-sport category aircraft or experimental or 

provisionally certificated aircraft, the operator must also display on that aircraft near each entrance to 

the cabin, cockpit, or pilot station, in letters not less than 2 inches nor more than 6 inches high, the 

words "limited," "restricted," "light-sport," "experimental," or "provisional," as applicable. (Cirrus 

believes relief from this section is not necessary as the proposed UAS is not certificated under Section 

21.191 and this petition is submitted in connection with proposed operations as a Civil UAS) 

Section 61.31(a) prescribing that a person who acts as a pilot in command of any of the following aircraft 

must hold a type rating for that aircraft for other aircraft specified by the Administrator through aircraft 

type certificate procedures: 

(1)Large aircraft (except lighter-than-air). 

(2)Turbojet-powered airplanes. 

(3)Other aircraft specified by the Administrator through aircraft type certificate procedures. 

(Cirrus believes relief from this section is not necessary under the statutory criteria provided in Section 

333 of P.L. 112-95 in reference to 49 USC Section 44794 given the size, weight, speed, and limited 

operating area associated with the proposed UAS) 

Page 1 of 13 
Section 61.31(c) prescribing that unless a person holds a category, class, and type rating (if a class and 

type rating is required) that applies to the aircraft, that person may not act as pilot in command of an 

aircraft that is carrying another person, or is operated for compensation or hire. That person also may 

not act as pilot in command of that aircraft for compensation or hire. (Cirrus believes relief from this 

section is not necessary under the statutory criteria provided in Section 333 of P.L. 112-95 in reference to 

49 USC Section 44794 given the size, weight, speed, and limited operating area associated with the 

proposed UAS) 

Section 61.31(d) prescribing that to serve as the pilot in command of an aircraft, a person must— 

(1) Hold the appropriate category, class, and type rating (if a class or type rating is required) for 

the aircraft to be flown; or 

(2) Have received training required by this part that is appropriate to the pilot certification level, 

aircraft category, class, and type rating (if a class or type rating is required) for the aircraft to be 

flown, and have received an endorsement for solo flight in that aircraft from an authorized 

instructor. 

(Cirrus believes relief from this section is not necessary under the statutory criteria provided in Section 

333 of P. L. 112-95 in reference to 49 USC Section 44794 given the size, weight, speed, and limited 

operating area associated with the proposed UAS or, alternatively, requests relief from this section by 

Pilot in Command (PlC) compliance with the applicable operational documents published by the 

manufacturer and the Proposed Conditions and Limitations set forth in this petition) 

Section 91.7(a) prescribing that no person may operate a civil aircraft unless it is in an airworthy 

condition. (Cirrus requests relief from this section by Pilot in Command (PlC) compliance with the 

applicable operational documents published by the manufacturer and the Proposed Conditions and 

Limitations set forth in this petition) 

Section 91.7(b) prescribing that the pilot in command of a civil aircraft is responsible for determining 

whether that aircraft is in condition for safe flight and that the PIC shall discontinue the flight when 

unairworthy mechanical, electrical, or structural conditions occur. (Cirrus requests relief from this 

section by Pilot in Command (P1C) compliance with the applicable operational documents published by 

the manufacturer and the Proposed Conditions and Limitations set forth in this petition) 

Section 91.9(b)(2) prohibits operation of U.S.-registered civil aircraft 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. (Cirrus believes relief from this section is not necessary as the 

FAA has previously determined relief is not required provided the relevant materials published by the 

manufacturer are kept in a location accessible to the PIC in compliance with the regulations) 

Section 91.103(b) prescribing that a pilot shall for any flight, become familiar with runway lengths at 

airports of intended use, and takeoff and landing distance information. (Cirrus believes relief from this 

section is not necessary provided the PIC complies with the Proposed Conditions and Limitations set forth 

in this petition) 

Page 2 of 13 
Section 91.109(a) prescribing, in pertinent part, that no person may operate a civil aircraft (except a 

manned free balloon) that is being used for flight instruction unless that aircraft has fully functioning 

dual controls. (Cirrus believes relief from this section is not necessary provided the P1C complies with the 

Proposed Conditions and Limitations set forth in this petition or utilizes the Dll Inspire 1 UAS dual control 

feature) 

Section 91.119 prescribing that, except when necessary for takeoff or landing, no person may operate 

an aircraft below the following altitudes: 

(a) Anywhere. An altitude allowing, if a power unit fails, an emergency landing without undue 

hazard to persons or property on the surface. (Cirrus believes relief from this section is not 

necessary provided the Pilot in Command (PIC) complies with the applicab/e operational 

documents published by the manufacturer and the Proposed Conditions and Limitations set 

forth in this petition) 

(b) Over congested areas. Over any congested area of a city, town, or settlement, or over any 

open air assembly of persons, an altitude of 1,000 feet above the highest obstacle within a 

horizontal radius of 2,000 feet of the aircraft. (Cirrus believes relief from this section is not 

necessary provided the Pilot in Command (PIC) complies with the applicable operational 

documents published by the manufacturer and the Proposed Conditions and Limitations set 

forth in this petition) 

(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. (Cirrus requests relief from 

this section by Pilot in Command (PIC) compliance with the applicable operational 

documents published by the manufacturer and the Proposed Conditions and Limitations set 

forth in this petition) 

Section 91.121 requires, in pertinent part, each person operating an aircraft to maintain cruising altitude 

by reference to an altimeter that is set "...to the elevation of the departure airport or an appropriate 

altimeter setting available before departure." (Cirrus believes relief from this section is not necessary 

provided the PIC complies with the Proposed Conditions and Limitations set forth in this petition) 

Section 91.151(a) prescribing that 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 [emphasis added]. (Cirrus requests relief from this section by Pilot in Command (PIC) compliance 

with the applicable operational documents published by the manufacturer ond the Proposed Conditions 

and Limitations set forth in this petition) 

Section 91.203(a) prohibits, in pertinent part, any person from operating a civil aircraft unless it has 

within it (1) an appropriate and current airworthiness certificate; and (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 § 47.31(c). (Cirrus believes relief from this section is not 

Page 3 of 13 
necessary as the FAA has previously determined relief is not required provided the relevant materials 

published by the manufacturer and the Proposed Conditions and Limitations are kept in a location 

accessible to the PIC in compliance with the regulationsJ 

Section 91.203(b) prescribing, in pertinent part, that no person may operate a civil aircraft unless the 

airworthiness certificate or a special flight authorization issued under § 91.715 is displayed at the cabin 

or cockpit entrance so that it is legible to passengers or crew. (Cirrus believes relief frorr► this section is 

not necessary as the FAA has previously determined relief is not required provided the relevant materials 

published by the manufacturer and the Proposed Conditions and Limitations are kept in a location 

accessible to the PIC in compliance with the regulations) 

Section 91.405(a) requires, in pertinent part, that an aircraft operator or owner shall have that aircraft 

inspected as prescribed in subpart E of the same part and shall, between required inspections, except as 

provided in paragraph (c) of the same section, have discrepancies repaired as prescribed in part 43 of 

the chapter. (Cirrus requests relief from this section by Pilot in Command (PIC) compliance with the 

applicable operational documents published by the manufacturer and the Proposed Conditions and 

Limitations set forth in this petition) 

Section 91.407(a)(1) prohibits, in pertinent part, any person from operating an aircraft that has 

undergone maintenance, preventive maintenance, rebuilding, or alteration unless it has been approved 

for return to service by a person authorized under § 43.7 of the same chapter. (Cirrus requests relief 

from this section by Pilot in Command (PIC) compliance with the applicable operational documents 

published by the manufacturer and the Proposed Conditions and Limitations set forth in this petition) 

Section 91.409(a) prescribing that 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 §43.7 of this chapter; or (2) that no 

person may operate an aircraft unless, within the preceding 12 calendar months, it has had an 

inspection for the issuance of an airworthiness certificate in accordance with part 21 of this chapter. 

(Cirrus requests relief from this section by Pilot in Command (PIC) compliance with the applicable 

operational documents published by the manufacturer and the Proposed Conditions and Limitations set 

forth in this petition) 

Section 91.417(a) and (b) prescribing, in pertinent part, that— 

(a) 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 100- 

hour, 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 

Page 4 of 13 
(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 life-limited 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 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. 

(Cirrus requests relief from this section by Pilot in Command (PIC) compliance with the applicable 

operational documents published by the manufacturer and the Proposed Conditions and Limitations set 

forth in this petition) 

Extent of and Reasons for Relief Soujzht 

Cirrus intends to operate two commercially available UAS types (DJI Phantom 2 Vision + and DJI Inspire 1) for the 

purpose of providing flight demonstration and instruction and aerial work under the provisions of 14 CFR 

Section 119.1 (e)(1) Student instruction, Section 119.1 (e)(4)(iii) Aerial photography or survey, and Section 119.1 

(e)(4)(vi) Powerline or pipeline patrol. Cirrus currently holds Air Carrier Certificate 3CXA478M effective May 10, 

2011 operating both fixed-wing and rotorcraft (helicopter) aircraft. Cirrus intends to offer commercial "aerial 

work" services utilizing UAS under the exemptions to 14 CFR Section 135 granted under 14 CFR 119.1(e) as set 

forth above. Additionally, Cirrus chief pilot, Craig E Bryan, holds a Commercial Pilot Certificate No. 3226654 

(Airplane Single & Multiengine Land, Instrument Airplane, Rotorcraft-Helicopter, and Glider along with Flight 

Instructor Certificate No. 3226654CF1 (Airplane Single & Multiengine and Glider). 

Page 5 of 13 
Public Interest and Benefit 

The above "aerial work" services, normally provided in manned aircraft, may be provided with increased safety 

and at significantly lower cost in situations where the use of unmanned UAS aircraft would supplement or 

replace the use of manned aircraft as a result of safety or economic considerations in certain applications where 

extended operational range and limited time aloft are not a factor. The proposed UAS operations will pose no 

threat to the public given its small size and lack of combustible fuel when compared to larger manned aircraft, 

minimize potential ecological affects or damage, and promote economic growth by providing data information 

to individuals or companies requiring aerial survey or imaging data. Additionally, the growth of the UAS industry 

has precipitated a large influx of "recreational" UAS pilots without formal knowledge or training regarding the 

effects or potential danger of UAS flight with the National Airspace System (NAS). While it is unclear what, if 

any, pilot certification requirements will ultimately apply to UAS pilots operating for commercial purposes under 

the final rulemaking process, there is a present need for training and dissemination of the applicable federal 

aviation regulations and flight characteristics of UAS to the general public; specifically current and potential UAS 

operators. UAS flight and ground demonstration and instruction for compensation utilizing the current system 

of certificated flight instructors provides economic incentive to accomplish the public goal of integration of both 

recreational and commercial UAS into the NAS while promoting safety and maintenance public awareness of 

current regulations affecting UAS operation. 

Exemptions Provide a Level of Safety Equal to or Greater than the Existing Level under Current Regulations 

The use of UAS operated under the requested exemptions as set forth above have the capacity to operate with 

less risk of accident or injury and the associated loss of property or life while performing the same aerial work 

services offered in manned aircraft in certain situations where extended operational range and limited time aloft 

are not a factor. Likewise, UAS flight and ground demonstration and instruction for compensation promote and 

encourage the existing system of certificated flight instructors to participate in the public educational process 

utilizing UAS rather than manned aircraft. 

Manned aircraft are at risk of fuel spillage and fire in the event of an incident or accident. The DJI Phantom 2 

Vision+ and Inspire 1 carry no fuel, and therefore the risk of fire following an incident or accident due to fuel 

spillage is eliminated. 

This petition for exemption does not propose an electronic means to monitor and communicate with other 

aircraft, such as transponders or sense and avoid technology. Rather the risk is mitigated by placing limits on 

altitude, requiring stand-off distance from clouds, permitting daytime operations only, and requiring that the 

UAS be operated within VLOS and yield right of way to all manned operations. Additionally, the Proposed 

Conditions and Limitations provide that the Cirrus will request a notice to airmen (NOTAM) prior to operations 

to alert other users of the NAS. 

Cirrus' UAS has the capability -to operate safely after experiencing certain in-flight contingencies or failures and 

uses an auto-pilot system to maintain UAS stability augmentation and control. The UAS is also able to respond 

to a loss of GPS or a lost-link event with pre-coordinated automated flight maneuvers. These safety features 

provide an equivalent or higher level of safety compared to a manned aircraft holding an airworthiness 

certificate (restricted or otherwise) performing a similar operation. 

Page 6 of 14 
Federal Register Summary 

Cirrus Exploration Company, including its chief pilot Craig E Bryan, seeks exemption from the following 

regulations for the purpose of conducting flight instruction and commercial "aerial work" flight operations 

utilizing Unmanned Aerial Systems ("UAS") as set forth under the provisions of 14 CFR Section 119.1 (e)(1) 

Student instruction, Section 119.1 (e)(4)(iii) Aerial photography or survey, and Section 119.1 (e)(4)(vi) Powerline 

or pipeline patrol: 

Relief considered (14 CFR) FAA Consideration or Action Requested 

Part 21 Relief not necessary pursuant to prior exemption 

45.23(b) Relief not necessary pursuant to prior exemption 

61.31(a) Relief not necessary (Section 333 of P.L. 112-95) 

61.31(c) Relief not necessary (Section 333 of P.L. 112-95) 

61.31(d) Relief not necessary (Section 333 of P.L. 112-95) 

91.7(a) Relief granted in prior exemption with conditions and limitations 

91.7(b) Relief not necessary pursuant to prior exemption 

91.9(b)(2) Relief not necessary pursuant to prior exemption 

91.103(b) Relief not necessary pursuant to prior exemption 

91.109(a) Relief not necessary pursuant to prior exemption 

91.119 Relief [paragraph (c)] granted in prior exemption with conditions 

and limitations 1 

91.121 Relief granted in prior exemption with conditions and limitations 

91.151(a) Relief [paragraph 91.151(a)(1), day] granted in prior exemption 

with conditions and limitations l 

91.203(a) and (b) Relief not necessary pursuant to prior exemption 

91.405(a) Relief granted in prior exemption with conditions and limitations 

91.407(a)(1) Relief granted in prior exemption with conditions and limitations 

91.409(a)(1) and (2) Relief granted in prior exemption with conditions and limitations 

91.417(a) and (b) Relief granted in prior exemption with conditions and limitations 

Additional Information Offered in Support of this Petition for Exemption 

Cirrus chief pilot, Craig E Bryan ("Bryan"), operated various manned aircraft, including fixed-wing and rotorcraft, 

for commercial purposes including aerial work and flight instruction since 1983. Additionally, Bryan has 

operated commercially available UAS vehicles for the past three years for non-commercial personal use in order 

gain flight experience and familiarity with the operating characteristics and limitations of the UAS and its 

videography and photography systems. As a result it is believed there are certain aerial work situations, where 

the range and time aloft limitations of UAS are not a factor, whereby aerial work may be conducted with greater 

safety and less risk to persons or property on the ground while offering the same or improved level of aerial 

work product. Manned aircraft platforms such as airplanes and helicopters often subject the occupants as well 

as persons and property on the ground to higher levels of risk for accident or injury even while being operated 

pursuant to all of the applicable federal aviation regulations. 

1 In the matter of Douglas Trudeau, Realtor, Regulatory Docket No. FAA-2014-0481 

2 Relief from this section is not necessary under the statutory criteria provided in Section 333 of P.L. 112-95 in reference to 

49 USCSection 44794 given the size, weight, speed, and limited operating area associated with the proposed UAS 

Page 7 of 13 
The DJI Phantom 2 Vision+ and the DJI Inspire 1 UAS are both commercially produced and widely available aerial 

videography and photography platforms utilizing advanced GPS enabled stability augmentation and control 

systems including "failsafe" features allowing the operator to manually take control of the aircraft or initiate an 

automated "return to home" feature in the event of adverse inflight events. The UAS also incorporates 

automated "failsafe" features to initiate "return to home" or "autoland" commands in the event of loss of 

control signal link or diminished battery output or capacity. 

The manufacturer, DJI, provides comprehensive operational and safety manuals for both UAS and all flights will 

be conducted in accordance with the requirements and guidance issued in these manuals. 

Cirrus states that § 91.7(a) prohibits the operation of an aircraft without an airworthiness certificate. Cirrus 

asserts that since there is currently no certificate applicable to his operation, this regulation is inapplicable. 

Cirrus states that § 91.9(b)(2) requires an aircraft flight manual in the aircraft, however since there are no pilots 

or passengers on board his aircraft and given its size, this regulation is inapplicable. Cirrus further indicates an 

equivalent level of safety will be achieved by maintaining a safety/flight manual with the UAS ground station. 

Proposed Conditions and Limitations 

Cirrus (also hereafter referred to as the operator) proposes the following Proposed Conditions and Cimitations in 

the form of a proposed Grant of Exemption: 

The following documents, including any updates or revision by the manufacturer, provided by the operator in its 

petition are incorporated by reference, and are hereinafter referred to as operating documents: 

1) DJI Inspire 1 User Manual (EN) v1.0 

2) DJI Inspire 1 Safety Guidelines v1.0 

3) DJI Intelligent Flight Battery Safety Guidelines v1.0 

4) DJI Phantom 2 Vision+ User Manual (EN) v1.6 

5) DJI Phantom 2 Vision+ Pilot Training Guide (EN) v1.1 

6) DJI Smart Flight Battery Safety Guidelines(EN, FR, DE and JP) 

Failure to comply with any of the conditions and limitations of this grant of exemption will be grounds for the 

immediate suspension or rescission of this exemption. 

1) Operations authorized by this grant of exemption are limited to the following aircraft described in 

the operating documents which are quad-rotor aircraft weighing less than 55 pounds: 

DJI PHANTOM 2 Vision+ Unmanned Aircraft System (manufacturer published gross weight 2.74 

pounds) ; and, 

DJI Inspire 1 Unmanned Aircraft System (manufacturer published gross weight 6.47 pounds). 

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

grant. 

Page 8 of 13 
2) The UAS may not be flown at an indicated airspeed exceeding 43 knots. 3 

3) The UAS must be operated at an altitude of no more than 500 feet above ground level (AGL), as 

indicated by the procedures specified in the operating documents. AII altitudes reported to ATC 

must be in feet AGL. 

4) The UAS must be operated within visual line of sight (VLOS) of the Pilot in Command (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. 

5) AII operations commercial "aerial work" flight operations [as defined by 14 CFR Section 119.1 (e)(1) 

Student instruction, Section 119.1 (e)(4)(iii) Aerial photography or survey, and Section 119.1 

(e)(4)(vi) Powerline or pipeline patrol] must utilize a visual observer (VO). The UAS must be operated 

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

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

communicate verbally at all times. The PIC must be designated before the flight and cannot transfer 

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

the functions prescribed in the operating documents. 

6) AII flight instruction operations must be conducted such that the flight instructor has immediate 

access to the master ground control station (either through physical proximity or electronic access 

through a slave ground controller) for the purpose of assuming positive control of the UAS in the 

event of loss of control by a trainee or person acting under the provisions of a student pilot 

certificate issued by the FAA. 

7) The operating documents and this grant of exemption 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 tal(e 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 upon request. The 

operator must also present updated and revised documents if he 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 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) Prior to each flight, the PIC must inspect the UAS to ensure it is in a condition for safe flight. If the 

inspection reveals a condition that affects the safe operation of the UAS, the UAS is prohibited from 

3 Maximum published velocity [DJI Phantom 2 Vision+ (29.16 knots), DJI Inspire 1(42.76 knots)] 

Page 9 of 13 
operating until the necessary maintenance has been performed and the UAS is found to be in a 

condition for safe flight. The Ground Control Station must be included in the preflight inspection. AII 

maintenance and alterations must be properly documented in the aircraft records. 

9) Any UAS 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. The PIC who 

conducts the functional test flight must make an entry in the aircraft records. 

10) The pre-flight inspection section in the operating documents must account for all discrepancies, i.e. 

inoperable components, items, or equipment, not already covered in the relevant sections of the 

operating documents. 

11) The operator must follow the UAS manufacturer's aircraft/component, maintenance, overhaul, 

replacement, inspection, and life limit requirements. 

12) The operator must carry out its maintenance, inspections, and record keeping requirements, in 

accordance with the operating documents. Maintenance, inspection, and alterations must be noted 

in the aircraft records, including total flight hours, description of work accomplished, and the 

signature of the authorized person returning the UAS to service. 

13) Each UAS operated under this exemption must comply with all manufacturer Safety Bulletins. 

14) The authorized person must make an entry in the aircraft record of the corrective action taken 

against discrepancies discovered between inspections. 

15) UAS operations must be conducted by a PIC possessing at least a private pilot certificate and at least 

a current third-class medical certificate. The PIC must also meet the flight review requirements 

specified in 14 CFR 61.56 in an aircraft in which the PIC is rated on his or her pilot certificate. 

16) Prior to operations conducted for the purpose of flight instruction or aerial work as defined by 14 

CFR Section 119.1 (e)(1) Student instruction, Section 119.1 (e)(4)(iii) Aerial photography or survey, 

and Section 119.1 (e)(4)(vi) Powerline or pipeline patrol, the PIC must have accumulated and logged, 

in a manner consistent with 14 CFR 61.51(b), a minimum of 25 hours of total time as a UAS 

rotorcraft pilot including at least 10 hours logged as a UAS pilot with a multi-rotor UAS. Prior 

documented flight experience that was obtained in compliance with applicable regulations may 

satisfy this requirement. Training, proficiency, and experience-building flights can also be conducted 

under this grant of exemption to accomplish the required flight time. However, said training 

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

and experience-building flights the PIC is required to operate the UAS with appropriate distances in 

accordance with 14 CFR 91.119. 

Page 10 of 13 
17) Prior to operations conducted for the purpose of flight instruction or aerial work as defined by 14 

CFR Section 119.1 (e)(1) Student instruction, Section 119.1 (e)(4)(iii) Aerial photography or survey, 

and Section 119.1 (e)(4)(vi) Powerline or pipeline patrol, the PIC must have accumulated and logged, 

in a manner consistent with 14 CFR 61.51(b), a minimum of 5 hours as UAS pilot operating the make 

and model of the UAS to be used in operations under the exemption; 5 hours make and model time 

may be included in the 10 hours of multi-rotor time prescribed above. The PIC must accomplish 3 

take-offs and landings in the preceding 90 days (for currency purposes). Training, proficiency, 

experience-building, and take-off and landing currency flights can be conducted under this grant of 

exemption to accomplish the required flight time and 90 day currency. However, said training 

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

and experience-building flights the PIC is required to operate the UAS with appropriate distances in 

accordance with 14 CFR 91.119. 

18) The operator may not permit the PIC to operate the UAS for the purpose of flight instruction or 

aerial work as defined by 14 CFR Section 119.1 (e)(1) Student instruction, Section 119.1 (e)(4)(iii) 

Aerial photography or survey, and Section 119.1 (e)(4)(vi) Powerline or pipeline patrol, unless the 

PIC has demonstrated and logged in a manner consistent with 14 CFR 61.51(b), 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 people, 

vessels, vehicles and structures. 

19) UAS operations may not be conducted during night, as defined in 14 CFR 1.1. AII operations must be 

conducted under visual meteorological conditions (VMC). 

20) The UAS may not operate within 5 nautical miles of an airport reference point as denoted on a 

current FAA-published aeronautical chart unless, prior to such operation, the PIC coordinates and 

obtains authorization and airspace clearance from any National Airspace System (NAS) controlling 

authority having jurisdiction over the affected airspace and establishes and maintains continuous 

verbal communication or contact with said authority (ATC) through radio or telephonic methods for 

the duration of flight. 

21) The UAS 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 3 statute miles from the PIC. 

22) If the UAS loses communications or loses its GPS signal, it must return to a pre-determined location 

within the planned operating area and land or be recovered in accordance with the operating 

documents. 

23) The PIC must abort the flight in the event of unpredicted obstacles or emergencies in accordance 

with the operating documents. 

Page 11 of 13 
24) The PIC is prohibited from beginning a flight unless (considering wind and forecast weather 

conditions) there is enough power to fly at normal cruising speed to the intended landing point and 

land the UAS with 30% battery power remaining. 

25) The operator must obtain an Air Traffic Organization (ATO) issued Certificate of Waiver or 

Authorization (COA) prior to conducting any operations under this grant of exemption. This COA will 

also require the operator to request a Notice to Airman (NOTAM) not more than 72 hours in 

advance, but not less than 48 hours prior to the operation. 

26) AII aircraft operated in accordance with this exemption must be identified by serial number, 

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

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

27) Before conducting operations, the radio frequency spectrum used for operation and control of the 

UAS must comply with the Federal Communications Commission (FCC) or other appropriate 

government oversight agency requirements. 

28) The documents required under 14 CFR 91.9 and 91.203 must be available to the PIC at the Ground 

Control Station of the UAS any time the UAS is operating. These documents must be made available 

to the Administrator or any law enforcement official upon request. 

29) The UAS must remain clear and yield the right of way to all manned aviation operations and 

activities at all times 

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

31) The UAS may not be operated over congested or densely populated areas. 

32) 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 

UAS 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 UAS, flight operations must cease immediately 

and/or; 

b. The aircraft is operated near vessels, vehicles or structures where the owner/controller of 

such vessels, vehicles or structures has granted permission 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, and; 

c. Operations nearer to the PIC, VO, operator trainees or essential persons do not present an 

undue hazard to those persons per § 91.119(a). 

Page 12 of 13 
33) AII operations shall be conducted over private or controlled-access property with permission from 

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

authorized representative will be obtained for each flight to be conducted. 

34) 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 Nationa) Transportation Safety 

Board (NTSB) per instructions contained on the NTSB Web site: www.ntsb.gov. 

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. 

Respectfully submitted, 

Cirrus Exploration Company 

~ 

Craig E Bryan, Chief Pilot 

Attachments: 

Note: A11 attachments provided by hyperlink to insure document revision currency and compliance with manufacture's copyright policy 

1) DJI Inspire 1 User Manual (EN) v1.0 

http://download.dii-innovations.com/downloads/inspire 1/en/Inspire 1 User Manual v1.0 en.pdf 

2) DJI Inspire 1 Safety Guidelines v1.0 

http://download.dii-innovations.com/downloads/inspire 1/en/Inspire 1 Safety Guidelines en.pdf 

3) DJI Intelligent Flight Battery Safety Guidelines v1.0 

http://download.dii-innovations.com/downloads/inspire 1/en/Intelligent Flight Battery Safety Guidelines en.pdf 

4) DJI Phantom 2 Vision+ User Manual (EN) v1.6 

http://download.dii-innovations.com/downloads/phantom 2 vision plus/en/Phantom 2 Vision Plus User Manual v1.6 en.pdf 

5) DJI Phantom 2 Vision+ Pilot Training Guide (EN) v1.1 

http://download.dii-innovations.com/downloads/phantom 2 vision plus/en/Phantom 2 Vision Plus Pilot Training Guide v1.1 en.pdf 

6) DJI Smart Flight Battery Safety Guidelines(EN, FR, DE and JP) 

http://download.dii-innovations.com/downloads/phantom 2 vision plus/Smart Flight Battery Safety Guidelines.pdf 

Page 14 of 14