This petition and revision is being submitted on our behalf without legal counsel or 

consulting services.

Granting the present Petition of ExplAura LLC will further the public interest by 

allowing ExplAura to safely, efficiently, and economically perform agricultural surveying, 

sUAS operator training, real estate photography, product demonstrations, research and 

development, civil construction surveying, and marketing over certain areas of the 

United States.

Additionally, use of our fleet of sUAS will decrease congestion of the NAS, reduce 

pollution, and provide significant benefits to the economy. The benefits of ExplAura’s 

proposed operation of sUAS will be realized without implicating any privacy issues.

sUAS, as described from now on will include our fleet of unmanned aerial vehicles:

Turbo Ace Matrix-S Rotorcraft

DIJ S800 EVO Rotorcraft

DJI Inspire 1

Skywalker X8 fixed wing aircraft

Horten Ventis fixed wing aircraft

Benefits to Mankind

1. The public will benefit from decreased congestion of the NAS.

ExplAura’s sUAS 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 sUAS would reduce the amount of 

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. Furthermore, by reducing the number 

of manned aircraft, operating in the NAS, congestion around airports caused by arriving 

and departing aircraft will be reduced. The sUAS do not require an airport to takeoff or 

land. Likewise, a reduction of manned aircraft conducting aerial video and 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 ExplAura’s sUAS.

Conducting aerial acquisitions with the sUAS, instead of manned aircraft, will 

greatly benefit the public by drastically 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 sUAS produce no air pollution, and is the most 

viable environmentally conscious alternative to the average Cessna 150 typically utilized 

for aerial video and photography, while burning approximately 5-10 gallons per hour of 
leaded aviation fuel. Our sUAS, while reducing the carbon footprint of aerial 

acquisitions, also eliminates noise pollution, as the UAS are propelled by battery 

powered electric motors, rather than internal combustion engines. By using the sUAS to 

perform aerial acquisitions, the substantial risk to life and property in the air and on the 

ground, which is usually associated with traditional manned aircraft flight operations, 

will be substantially reduced or completely eliminated. Aside from the lack of crew 

members located on-board the aircraft, the sUAS has less physical potential for collateral 

damage to life and property on the ground, and in the air, compared to the manned 

aircraft that typically conduct similar operations. It should be noted that ExplAura also 

carries full insurance with up to $2 million liability.

3. Performing aerial video and photography operations with sUAS will benefit the 

economy.

In addition to being safe and efficient, the sUAS are also an economical 

alternative to using manned aircraft to conduct similar aerial operations. As such, 

operation of the sUAS will allow United States based companies, like ExplAura, to remain 

competitive and contribute to 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 our battery 

powered sUAS 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. By operating sUAS, companies 

such as ExplAura, 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 

commercial use of the sUAS, provides a stable workforce that 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, ExplAura’s proposed operation of sUAS will not implicate any 

privacy issues. Specifically, the sUAS will be operated only in compliance with all involved 

property owners as well as in accordance with the Federal Aviation Regulations, 

including the minimum altitude requirements of 14 C.F.R. § 91.119.
Additional information

I. SAFE OPERATIONS

ExplAura Pilots have over 20 years of experience in model aircraft technology. We 

have a complete grasp of the limitations of these systems. Our experience in building, 

testing and flying these systems gives us full knowledge of safe operations.

ExplAura is concerned with conducting safe operations. Last year upon learning 

the requirements for a 333 exemption, we took to the skies and became licensed pilots. 

As pilots, we fully understand the risks sUAS could impose on manned aircraft. We 

understand the different classes of airspace, and we have experience working with local 

airports. We rented a commercial pilot, and commercial mapping equipment to test 

aerial mapping from a Cessna. We found each method has its benefits, and that an 8lbs 

sUAS is much safer than a fully loaded Cessna with 2 souls on board.

II. AGRICULTURAL SURVEYING

With the projected increase in world population, producers must find a way to 

drastically increase agricultural output. sUAS are a feasible method to obtain 

information of agricultural cropland to determine optimum inputs that result in higher 

yields, cost savings to farmers, reduce environmental impact of excess fertilizers, and the 

overall benefit of society.

III. sUAS OPERATOR TRAINING

As the number of drone operators increases drastically, operators need to know 

safe operating procedures in the NAS. As licensed pilots, and lifelong model aviation 

enthusiasts, we will be able to provide our expertise to potential sUAS operators.

IV. REAL ESTATE PHOTOGRAPHY

To further the economic drive of commercial and residential real estate, aerial 

photos and video tours are a huge asset. Our central Iowa location has a large amount of 

new and old buildings entering the market. ExplAura would like to enter this market to 

help both sides of the sale share information of the properties. 

V. PRODUCT DEMONSTRATIONS,
Many potential contracts ask to see what they are paying for. These demo flights 

would occur away from office buildings, most likely on an agriculture field, or landfill 

site. While live demonstrations are more powerful than video clips, they are very 

dependent on location and safety factors. These facts would remain primary to the 

location decision making process.

VI. RESEARCH AND DEVELOPMENT

We have possible airframes which would require research, development and 

testing. These actions would be performed at a local AMA field under their safety guild 

lines. 

VII. CIVIL CONSTRUCTION SURVEYING

Our sUAS provide engineers in the quarry, mine, and landfill industries, highly 

detailed and accurate data. This data will work to prevent material theft, cross check 

inventories and monitor compaction rates. Our services will provide geologists and 

engineers the data needed to plan future mining sites, and improve existing sites.

This allows plant managers to make better business decisions, save company money, 

reduce waste and environmental impact all while flying a lightweight, unmanned, 

electric vehicle. 

VIII. AERIAL MARKETING VIDEOGRAPHY

Unmanned Aircraft System are often seen as superior to helicopters as an aerial 

video gathering platform due to the smaller footprint, personnel cost, reduced noise, 

and a much smaller environmental and public safety impact. Granting ExplAura this 

exemption will befit the local film making and marketing economy by lessening the cost 

and risk of using a full sized Rotorcraft. 

Regulations from which the exemption is requested: 

14 C.F.R. § 45.23(b) 

14 CFR Part 21 

14 C.F.R. § 91.7 (a) 

14 CFR § 91.9 (b) (2) 

14 C.F.R. § 91.103 

14 C.F.R. § 91.109 

14 C.F. R. § 91.119 

14 C.F.R. § 91.121 

14 CFR § 91.151 (a) 

14 CFR § 91.203 (a) & (b) 
14 CFR § 91.205(b) 

14 CFR § 91.215 

14 CFR § 91.405 (a) 

14 CFR § 407 (a) (1) 

14 CFR § 409 (a) (2) 

14 CFR § 417 (a) & (b)

FAR section Subject Justification 

14 CFR § 45.23(b) Requirement to display registration number on vehicle Insufficient space on vehicle 

14 CFR Part 21 Aircraft certification requirements and procedures Designed for manned aircraft; not suitable for offthe-shelf sUAS 

14 CFR § 91.7 (a) Airworthiness requirement Designed for manned aircraft; not suitable for offthe-shelf sUAS 

14 CFR § 91.9 (b) (2) Requirement for manual to 

be available in the cockpit 

No one aboard to read manual 

14 CFR § 91.103(b) Requirement for crew members to be onboard Unmanned vehicle 

14 CFR § 91.109 Requirement for dual controls during flight instruction No one aboard to operate 

controls 

14 CFR § 91.119 Minimum altitudes for safe 

flight 

Safety requires operation 

below these altitudes 

14 CFR § 91.121 Altimeter settings No one aboard to read altimeter 

14 CFR § 91.151(a) Fuel requirements Vehicle does not use fuel 

14 CFR § 91.203 (a) & (b) Requirement for registration 

and airworthiness certificates to be onboard 

No one aboard to read certificates 

14 CFR § 91.205(b) Cockpit instruments No one aboard to read 

14 CFR § 91.215 Transponder requirement Vehicle has insufficient useful load; will be operated below ATC radar coverage 

14 CFR § 91.405 (a) Inspection requirements Designed for manned aircraft; not suitable for offthe-shelf sUAS 

14 CFR § 91.407(a) (1) Inspection approval requirements Designed for manned aircraft; not suitable for offthe-shelf sUAS 

14 CFR § 91.409 (a) (2) Airworthiness inspection Designed for manned aircraft; not suitable for offthe-shelf sUAS 
14 CFR § 91.417 (a) & (b) Maintenance records requirements 

Designed for manned aircraft; not suitable for offthe-shelf sUAS