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Richard L. Fox

8834 South 69th East Ave.

Tulsa, Oklahoma 74133

Date: July 8, 2015

U.S. Department of Transportation

Docket Management System

1200 New Jersey Ave.

Washington, DC. 20590

RE: Petition of Richard L. Fox for Exemption Pursuant to Section 333 of the FAA Reform Act

Attn: To whom it may concern

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

and 14C.F.R. Part 11 Richard L. Fox, operator of a Small Unmanned Aircraft System (sUASs) 

equipment to conduct aerial photography and videography as a service to private land owns for 

the purpose of real estate listing, property insurance claims etc., hereby applies for an 

exemption from the listed Federal Aviation Regulations (“FARs”) to allow commercial operation 

of my sUASs, so long as such operations are conducted within and under the conditions 

outlined herein or as may be established by the FAA as required by Section 333.1.

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

unmanned and relatively inexpensive sUAS under controlled conditions in airspace that is 1) 

limited 2) predetermined and 3) controlled. The proposed exemption, if granted, would allow 

Richard L. Fox to conduct commercial operations of small unmanned aircraft systems (“UAS”) 

meeting or exceeding all of the operational and safety requirements Congress has set forth in 

Section 333, Page 2.

I, Richard L. Fox, am an Aerospace Engineer with 30 years of experience in design, 

construction and operation of commercial and business aircraft. I am an FAA licensed Private 

Pilot with approximately 200 hours of flight time in fixed wing and rotary wing aircraft. I am also 

an experienced RC pilot with a back ground in fixed wing and multi-rotor RC aircraft. I plan to 

use my skills as a pilot and operator of an Unmanned Aerial System to offer services including:

 Aerial Surveying

 Real Estate Photography

 Agriculture purposes

Statutory Authority Section 333 Titled “Special Rules for Certain Unmanned Aerial Systems”, 

provides a mechanism for seeking expedited FAA authorization of safe civil UAS operation in 

the NAS. Section 333(a) states that the FAA “shall determine if certain unmanned aircraft 

systems may operate safely in the national airspace system before completion of the 

(comprehensive) plan and rulemaking required by Section 332(b)(1) of this Act or the guidance 

required by Section 334 of this Act.” In Section 332(b)(1) Congress made it clear that Section 

333 provides a mechanism for “expedited operation authorization” if several factors are met. 

Petitioner meets all requirements to permit FAA approval of commercial UAS operations:
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The Petitioner Requests Relief From the Following:

Regulations from which the exemption is requested:

14 CFR Part 21

14 CFR 45.23(b)

14 CFR 45.29

14 CFR 61.113(a) and (b)

14 CFR 61.133

14 CFR 91.7(a)

14 CFR 91.9

14 CFR 91.119

14 CFR 91.121

14 CFR 91.151

14 CFR 91.203(a) & (b)

14 CFR (91.401 – 91.417)

Unmanned Aircraft Systems sUASs are often seen as superior to the use of helicopters due to 

the fact that they are smaller, less costly equipment, lower noise impact and that the promote a 

higher degree of public safety than large manned aircraft.

I am petitioning for exemption to enable myself to operate a BLADE 350QX equipped with a 

High Definition camera. The subject sUAS has on-board capability to limit the operating height 

above ground, and to limit the radius of operation from the operator. The BLADE 350QX has a 

failsafe autopilot system. If the link between the ground control transmitter and the sUAS is 

broken, the sUAS will enter a SAFE Mode and automatically go into stable flight and return to 

the location from which it was launched. The control transmitter also incorporates a function that 

allows the operator to activate a Return to Home feature that automatically returns the sUAS to 

the launch location and lands safely at the point of launch.

While flying for commercial purpose I would be flying at a maximum altitude of 200 feet AGL in 

full visual line of site and only under VFR, Daylight conditions. I would not be operating the 

sUAS near persons on the ground, sporting events or large gatherings of people, utilities or 

other hazards to persons or property. 

Aircraft

The Petitioner operates the Blade 350 QX sUAS manufactured by Horizon Hobby,

one of the most popular wholesale RC distributors in North America. The 350QX main rotor

diameter is 22.8 in, it has a gross flying weight of 24 oz., and is18.3 in long. What makes the

350QX such a great camera platform is its advanced SAFETM (Sensor Assisted Flight 

Envelope) technology. This provides for incredible ease of use and stability. Pilots can control 

the 350QX’s movements in many directions – including pitch (forward and backward), roll (left 

and right), elevator (up and down), and yaw (turn left or right). The built-in GPS system aids in

stabilizing the aircraft and will automatically return it back to its home position if communication 

between the remote control and quad copter are lost.

The 350QX is controlled with the included DX5e full-range transmitter that utilizes the same

Spektrum 2.4GHz technology preferred by RC experts the world over. This advanced signal

processing technology provides superb range and interference protection, especially in ‘noisy’

environments where several 2.4GHz systems are in use at the same time.
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The 350QX has two flight modes that have been specially programmed for capturing aerial 

video and images. Both feature self-leveling and use GPS and altitude sensors to precisely hold

position in a hover.

The Return Home function will automatically land at the home position. This feature can be

activated at any time with the flip of a switch. When activated, the 350QX will automatically fly

itself back to the place its motors were first started and land without any help from the pilot.

As an added safety feature, the 350QX operates within geo-referenced flight boundaries. Out of

the box, its boundaries are set at 100 meters from and 50 meters above the point where the

motors were started. An intuitive PC programming interface makes monitoring systems,

adjusting settings and calibrating sensors as easy as point and click.

The Inertial Measurement Unit (“IMU”) has a built-in inertial sensor and a barometric altimeter

that measures both attitude and altitude. The inertial measurement tells the 350QX how it’s

tilted, and the gyros tell it if it’s rotating in any particular direction.

The 350QX’s compass reads geomagnetic information and assists the GPS to accurately

calculate the position and height of the aircraft.

The 350QX has LED flight indicators beneath each of its four rotor arms and in the rear. The

LEDs illuminate to indicate the status of the flight control system and alert the PIC of any

possible issues.

A Pre-flight inspection will be performed by the PIC in accordance with the factory instruction 

manual. Propellers will be inspected prior to each flight and replaced with manufacturer 

authorized replacements if damage such as cracks, nicks or blade deformation are found.

Maintenance will be in accordance with the manufacturers instruction manual and all 

manufacturer service bulletins. Only manufacturer authorized parts will be used as 

replacements. 

Please refer to the included BLADE QX Instruction Manual for performance limitations.

FCC Information

The Spectrum DX5e transmitter used for controlling the BLADE 350QX complies with part 15 of 

the FCC rules. Operation is subject o the following two conditions:

(1) This device may not cause harmful interference, and (2) this device must accept any 

interference received, including interference that may cause undesired operation.

The Spectrum radio transmitter used for the control of the sUAS is wireless technology which 

has been tested and found to be compliant with applicable regulations governing a radio 

transmitter in the 2.400GHz to 2.4835 GHz frequency range.

Antenna Separation Distance

When operating the Spectrum transmitter, the PIC will maintain a separation distance of at least 

5 cm between his body (excluding fingers, hands, wrists, ankles and feet) and the antenna to 

meet RF exposure safety requirements as determined by FCC regulations.
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Equivalent Level of Safety

In an effort to join the FAA in its mission to provide the safest, most efficient aerospace system

in the world and to minimize the risk to the NAS or to persons and property on the ground, the

Petitioner agrees to be bound by the following limitations and conditions when conducting

commercial operations under an FAA issued exemption:

1. For the purpose on ensuring the sUAS will be operated in a safe and 

professional way:

a. The sUAS will not be flown:

 In a careless or reckless manner.

 At a location where sUAS operations are prohibited.

2. sUAS PIC will:

a. Yield the right of way to all manned aircraft.

b. See and avoid all aircraft with the assistance of an observer.

c. Not fly at an altitude greater than 200 feet AGL or within 5 miles of an 

airport without notifying the airport operator.

d. Not interfere with operations and traffic patterns at any airport, heliport or 

seaplane base.

e. Not exceed a takeoff weight of 55 pounds (Including payload)

f. Ensure that the aircraft is identified by affixing the aircraft registration N 

Number on the outside of the sAUS.

g. Not operate the sUAS under the influence of alcohol or while using any 

medications that could adversely affecr the PICs ability to safely control 

the aircraft.

h. Not operate the sUAS carrying pyrotechnic devices that explode or burn, 

or any device which propels a projectile or drops any object that creates 

a hazard to persons or property.

3. The sUAS will not be flown unless:

a. The aircraft, control system and pilot skills have successfully

demonstrated all maneuvers intended or anticipated prior to the specific 

event.

b. An inexperienced pilot is assisted by an experienced pilot.

4. All pilots shall avoid flying directly over unprotected people, vessels, vehicles or

structures and shall avoid endangerment of life and property of others.
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5. A successful radio equipment ground-range check in accordance with 

manufacturer’s recommendations will be completed before the first flight of a new 

or repaired model aircraft.

6. The sUAS must use the radio-control frequencies currently allowed by the 

Federal Communications Commission (FCC).

7. The sUAS will not knowingly operate within three (3) miles of any pre-existing 

flying site without a frequency-management agreement.

8. Excluding takeoff and landing, no sUAS may be flown outdoors closer than 25 

feet to any individual, except for the PIC and the observer located at the takeoff 

site.

9. Under no circumstances may a pilot or other person touch a sUAS in flight while 

it is under power, except to divert it from striking an individual.

10. The PIC of the sUAS shall:

a. Maintain control during the entire flight, maintaining visual contact without

enhancement other than by corrective lenses prescribed for the pilot.

b. Always fly with the assistance of a ground based Observer.

General Operating Standards

In addition to the above rules, the petitioner agrees to be bound by the following limitations and 

conditions:

 Richard L. Fox will operate the sUAS in line of site of a pilot and/or an observer and will 

operate at sites that are a “sufficient distance” from populated areas. Such operations 

will insure that the sUAS will “not create a hazard to users of the National Airspace 

System or the public.

 Before operation of the sUAS within 5NM of an airport with a control tower, the control 

tower will be notified to gain permission to operate the sUAS. The PIC will give the 

position, altitude and times of operation. The sUAS will not be operated at an altitude of 

over 150 feel AGL. Weather minimums will be 3 miles visibility and 1000 foot ceiling.

Before an operation within 5NM of a non-tower controlled airport, airport operations will 

be notified and the PIC will give right of way to avoid flying in the proximity of full scale 

manned aircraft. At no time will the sUAV be operated within the final approach course 

or takeoff course of any runway. The sUAS will not be operated at an altitude of over 

150 feel AGL. Weather minimums will be 3 miles visibility and 1000 foot ceiling.

 Maximum flight time for each operational flight will be 15 minutes.

 Flights will be terminated at 20% battery power reserve should that occur prior to the 15 

minute flight time limit.
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 The sUAS will be operated in an altitude limiting mode of no more than 200 feet AGL

 The minimum crew for each operation will consist of the sUAS PIC and Visual Observer.

 The sUAS will be operated by the petitioner weights less than 55 pounds, including 

photographic payload.

 The sUAS will operate at speeds of no more than 25 knots, can hover, and can 

simultaneously move vertically and horizontally.

 Given the small size of the sUAS and the restricted sterile environment in which they will 

operate, the sUAS operations adhere to the Reform Act’s safety requirements.

The operation of the sUAS, weighing less than 5 lbs., conducted in the strict conditions as 

outlined above, will provide an equivalent level of safety supporting the grant of exemptions 

requested herein, including exempting the Petitioner from the requirements of Part 21 and 

allowing commercial operations.

These lightweight aircraft operate at slow speeds, close to the ground, and in a tightly controlled 

environment. As a result, they offer a much safer way to capture aerial photography and 

videography than with the traditional use of manned aircraft.

Pilot in Command and Observer Qualifications and Duties

As the Pilot In Command I will maintain all health and safety regulations for PIC. My FAA issued 

Private Pilot License number is 435026663. As PIC I will maintain my proficiency with a 

minimum of 1 hour total flying time and 3 takeoffs and landings within 30 days in the type of 

sUAS utilized in operations.

The PIC is responsible for all Pre-flight activities and conducting safe and efficient operation of 

the aircraft. Duties of the PIC are:

 All Pre-flight activities

 In flight operations

 Post flight activities

 Safe in flight operations in accordance to COA

 Risk mitigation to persons and property

 Flying field stability

 Aircraft maintenance

 Flight and Maintenance logs

 Required reporting to the FAA

The Observer must have the visual acuity to observe the sUAS and be able to communicate 

clearly with the PIC either vocally or by 2 way radio. Duties of the Observer are:

 Warning the PIC of any impending obstacles in the flight path of the sUAS

 Warning the PIC of any deviations in the planned flight path of the sUAS

 Warning the PIC should any unauthorized personnel appear in the area of planned flight

 The observer will have the authority to order the PIC to terminate the flight should he feel 

the flight cannot be conducted safely.
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Pre-flight Requirements

The PIC will follow a comprehensive pre-flight checklist to ensure that the sUAS is in a condition 

of safe flight. This plan will be improved as needed to to incorporate precautions and safety 

suggestions issued by the manufacturer.

A. Pre-flight Inspection

1. Check that the transmitter, sUAS and camera batteries are all fully charged.

2. Verify that the sUAS battery is not swollen or damaged in any way.

3. Turn the motor shafts with your fingers and verify that are smooth without excessive play 

or binding.

4. Verify that the propellers are mounted correctly and free from signs of damage.

5. Run finger along the edge of blade to check for any rough edges.

6. Flex both sides of the propellers’ blades to check for hairline cracks where the blades 

connect in the center of the propeller.

7. Verify that the landing gear is secure and free from damage, broken or loose.

8. Verify that the camera is secure and clean. Inspect the camera connections and gimbal 

for tears and/or signs of wear.

9. Verify that the damping absorbers are not broken and/or worn.

10. Verify that the Micro-SD card has been inserted and formatted.

11. Verify that the remote camera link is enabled.

B. Power Up

1. Power on the transmitter with the flight mode set to the appropriate setting the throttle 

stick down and the throttle trim at neutral.

2. Install a charged battery in the UAS, plug it in and close the hatch.

3. Wait for the GPS signal to be acquired, which is indicated by a solid LED. It may take 

from 30-90 seconds to acquire a GPS signal.

4. Move the aircraft to the desired home location and orient the aircraft pointed away from 

the pilot.

5. Step back approximately 15 feet (5 meters) from the home location.
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C. Ready to Fly

1. Power on camera and acquire camera link.

2. Verify that the aircraft still has GPS lock.

3. Start the motors.

4. Verify that the motors are functioning normally, are not making any unusual noises, and 

are all spinning the same speed.

5. Verify that the area is still clear of obstructions, people, power lines, etc.

6. Take off and hover about 6-8 feet above the takeoff point to verify that the aircraft still 

has a solid GPS lock. If any abnormalities are noticed (drifting, flying in circles, etc.), 

land immediately and repeat the “Pre-flight Inspection” and Power Up” sequences.

7. Verify that the aircraft holds a steady position while yawing 360 degrees.

8. Verify that the aircraft responds appropriately to all controls – yaw, pitch, roll and throttle.

Post Flight Requirements

A. After Flight

1. Turn off the power switch on the aircraft.

2. Turn off the power to the transmitter.

3. Turn off the camera power.

4. Unplug and remove battery from aircraft.

5. Secure flight operations area.

Preventive Maintenance

A comprehensive preventative maintenance plan will be followed in accordance with the 

manufacturer’s specifications to ensure the sUAS software is up-to-date, the batteries are 

ingood health, and the aircraft itself is always ready for safe flight.

Public Interest

Granting this exemption would benefit the public as a whole. SUASs offer a strong equivalent

level of safety, a reduction in environmental impacts, and are free from the harmful emission

associated with the manned aircraft that are currently used for aerial photography and

videography. Due to the size of the sUAS and the tightly controlled and limited airspace in
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which the sUAS will operate, approval of this application presents no risk to the public.

Furthermore, the public will be able to legally acquire aerial photography and videography to

help in, but not limited to, advertising homes for sale, advertising uninhabited homes, lots, use 

of photos and video as an aid when researching homes for sale on the market, or safely 

accessing high and/or awkward areas of home exterior to assess damage that needs to be 

repaired.

Privacy

Since the areas being photographed or filmed will be on private property, accessed only after

given written and/or oral consent by the property owner(s), and clear of all people, except for the

PIC and the PIC’s helper(s), approval of this application presents no risk to the public privacy.

National Security

Due to the size of the sUAS and the tightly controlled and limited airspace in which the sUAS

will operate, approval of this application presents no risk to national security.

Requested Exemptions

Richard L. Fox requests exemption from the following regulations as well as any additional 

regulations that may technically apply to the operation of the sUAV System: 

14 CFR Part 21, Airworthiness Certificates

This part establishes the procedures for the issuance of an airworthiness certificate. While the

FAA continues to work to develop airworthiness standards for Unmanned Aerial Systems, we

request an experimental certificate be issued for the Blade 350QX under either or both of the 

following provisions:

21.191 Experimental certificates. Experimental certificates are issued for the following purposes:

(a) Research and development. Testing new aircraft design concepts, new aircraft equipment,

new aircraft installations, new aircraft operating techniques, or new uses for aircraft.

(b) Showing compliance with regulations. Conducting flight tests and other operations to

show compliance with the airworthiness regulations including flights to show compliance for

issuance of type and supplemental type certificates, flights to substantiate major design

changes, and flights to show compliance with the function and reliability requirements of the

regulations. Since the experimental certificate can be used for commercial purposes such as

market surveys, sales demonstrations, and customer crew training, we would expect that an

experimental certificate would permit our commercial purpose as well. The aircraft will not carry

persons or property, will not carry fuel, and will only fly under strict operational requirements.

Combined with the UA's light weight, being constructed primarily of carbon fiber and plastic, we

propose that the UA will be at least as safe, if not safer, than a conventionally certificated

aircraft performing the same mission. If an experimental airworthiness certificate is not

appropriate for this application, then we request an exemption of 14 CFR Part 21, Subpart H,

and the requirement for an airworthiness certificate in general, citing the equivalent level of

safety outlined in the previous paragraph.
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14 CFR 45.23 Display of markings; GENERAL AND 45.29 Size of marks.

These regulations provide that each aircraft must display "N" and the aircraft's registration 

number in letters at least 3 inches high. Additionally, the aircraft must display the word 

"EXPERIMENTAL" in letters at least 2 inches high near the entrance to the cabin, cockpit, or 

pilot station. The sUAV does not have an entrance in which the word "EXPERIMENTAL" can be 

placed, and may not have a registration number assigned to it by the FAA. I propose to achieve 

an equivalent level of safety by including the word "EXPERIMENTAL" in the placard on the top 

of the aircraft, as shown above, where the PIC (Pilot In Control), VO (Visual Observer) and 

others in the vicinity of the aircraft while it is preparing for launch will be able to see the 

designation. 

Additionally, I feel that the permanent placard discussed in the previous paragraph will provide 

the aircraft's registration information at the ground station. Finally, I will display at the ground 

station a high contrast flag or banner that contains the words "Unmanned Aircraft Ground 

Station" in letters 3 inches high or greater. Since the aircraft will operate within 3/4 NM of the 

ground station, the banner should be visible to anyone that observes the aircraft and chooses to 

investigate its point of origin.

14 CFR 61.113 Privot pilot privileges and limitations: Pilot In Command and 61.133 

Commercial pilot privileges and limitations.

The regulation provides that no person that holds a Private Pilot certificate may act as pilot in

Command of an aircraft for compensation or hire. Subparagraph (b) allows a private pilot to act

as pilot in command 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. My proposed operation requires that the PIC

must hold at least a Private Pilot Certificate with a valid drivers license from any state and since 

the aircraft cannot carry passengers or property, I feel that I meet the intent of 61.113 

Subparagraph (b) even though the intent of this application is to conduct a business.

14 CFR 91.7 Prohibits the operation of an aircraft without an airworthiness certificate.

As no such certification will be applicable in the form contemplated by the FARs, this regulation 

is felt to be inapplicable.

14 CFR 91.9 Civil aircraft flight manual, marking and placard requirements.

This regulation provides that no person may operate an aircraft unless a current, approved flight 

manual is in the aircraft. I assume that the intent of this requirement is to ensure that flight 

manual information is available to the aircrew while operating the aircraft. I request an 

exemption to this requirement since the aircraft is not only too small to carry documentation, the

documentation would not be available to the crew during flight operations. To obtain an

equivalent level of safety and meet the intent of 91.9, I propose that a current, approved sUAS 

Flight Manual must be available to the crew at the ground station anytime the aircraft is in, or 

preparing for, flight.

91.119 Minimum safe altitudes:

General. The regulation states that over sparsely populated areas the aircraft cannot be 

operated closer than 500 feet to any person, vessel, vehicle, or structure. Since the typical 

mission of the sUAS would be photography or survey of structures it would be necessary to 

operate closer than 500 feet to the building. Operations will only be flown over property where 

permission has been obtained and careful pre-planned flight path has been performed. The 

aircraft will be operated at a low altitude allowing, if a power unit fails, an emergency landing 

without undue hazard to persons or property on the surface. Therefore I maintain that due to the 
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small size of the UAS, the hazard to persons, vehicles and structures is minimal compared to 

manned aircraft, which should be considered in granting the exemption.

CFR 91.121 Altimeter settings.

The regulation requires that aircraft shall maintain cruising altitudes by reference to an altimeter 

setting available within 100 NM of the aircraft. The sUAS will always fly below 200 feet AGL and 

will not need to maintain cruising altitudes in order to prevent conflict with other aircraft. An 

Above Ground Level altimeter measurement above the takeoff point is processed within the 

aircraft operating system.

14 CFR 91.151 Fuel requirements for flight in VFR conditions.

The regulation provides that no person may begin a flight in an airplane under day-VFR

conditions unless there is enough fuel to fly to the first point of intended landing and to fly after

that for at least 30 minutes. I feel the intention of this paragraph is to provide an energy

reserve as a safety buffer for delays to landing. The sUAV is battery operated and the maximum

duration of flight from a single battery charge is approximately 15 minutes with a 20% reserve. 

Since the aircraft will never fly more than 3/4 NM from the point of intended landing, a full 

battery charge at launch will ensure that we meet the reserve energy requirement of this 

paragraph. We request an exemption to the word "fuel" and ask for an equivalent interpretation 

with the word "energy".

14 CFR 91.203(a) & (b) Civil aircraft: Certifications required.

The regulation provides that an airworthiness certificate, with the registration number assigned

to the aircraft and a registration certificate must be aboard the aircraft. Additionally,

subparagraph (b) provides that the airworthiness certificate be "displayed at the cabin or cockpit

entrance so that it is legible to passengers or crew." At a maximum gross weight of 5.3 pounds,

the sUAS is too small to carry documentation, does not have an entrance, and is not capable of

carrying passengers or crew. To obtain an equivalent level of safety and meet the intent of

91.203, I propose that documents deemed appropriate for this aircraft by the FAA will be with 

the crew at the ground control station and available for inspection upon request. In order to 

identify the aircraft, I propose that the registration number be permanently affixed to the aircraft 

containing the aircraft N Number plus the word "EXPERIMENTAL" to satisfy the requirement of 

14 CFR 45.23.

14 CFR Subpart E (91.401- 91.417)- Maintenance, Preventive Maintenance, Alterations

The regulation provides that the operator is primarily responsible for maintaining the aircraft in 

an airworthy condition, including compliance with part 39 and 43. Paragraphs 91.407 and 

91.409 require that the aircraft be "approved for return to service by a person authorized under 

43.7" after maintenance and inspection. It is my intention that the PIC perform maintenance and

inspection of the aircraft and "be authorized to approve the aircraft for return to service." The

PIC will ensure that the aircraft is in an airworthy condition prior to every flight and in addition

conduct detailed inspections after every two hours of flight. Maintenance performed by the PIC

is limited to repairing small cracks, replacing a propeller, checking electrical connections and

updating software and firmware for the on-board computer. All other maintenance will be

performed by the manufacturer or their designated repair facility. The PIC will document work

performed in accordance with 91.417. I feel that due to the size, construction, and simplicity

of the aircraft, the PIC can ensure an equivalent level of safety.
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Safety and Benefits of the UAS

Richard L. Fox will be using the sUAS in a variety of applications that generally require 

expensive full-size manned aircraft to complete. Small, light, unmanned aerial vehicles offer 

numerous benefits over the use of full-sized manned aircraft for electric power line inspection,

oil/gas pipeline inspection, advanced agriculture, film and still photography, just to name a few.

Replacing significantly larger manned aircraft carrying crew and flammable fuel with small UAS

carrying no passengers or crew creates a much greater margin of safety for the pilots and crew.

By granting Richard L. Fox the requested exemptions, the FAA will help drive development of 

safe and successful commercial UAS operations and will advance the public knowledge base 

for such operations. As an experienced Aerospace Engineer I am committed to promoting the 

UAS research efforts of policymakers including the FAA, NASA, DOD and DARPA by sharing 

data from my commercial UAS operations and serving as a resource for future sUAS research 

operations. Thus, the FAA has good cause to grant this Petition.

Conclusion

As pointed out in this application, the sUAS which I would use, under authorization by the US 

DOT-FAA, are small, light-weight devices operated within the line of sight of the Pilot-inCommand (PIC), less than 200 feet above the ground and outside 5 miles from any airport, 

heliport, seaplane base, spaceport, or other location with aviation activities, unless the air traffic 

control authorities (ATC) have been notified and have authorized each flight within a radius of 

this distance.

My sUAS has proven capability for controlled flight. It is a device offered for general sale on the 

market around the world and has often been used as Model Aircraft in the USA. I am certain 

that the studies conducted until now by the FAA, about Section 332, Public Law 112-95, 2014, 

have already provided you with the assurances on the airworthiness of SUAs such as mine

.

For the foregoing reasons, the exemptions requested herein should be granted and Richard L. 

Fox should be permitted to conduct small UAS operations in accordance with my manuals and 

all other operating parameters deemed necessary and appropriate by the FAA. The submission 

of this application and its contents is the best demonstration that indeed it is possible to pursue 

the authorization process so that some SUAs may be responsibly used for legitimate 

commercial activities and under reasonably safe conditions.

Signed

Richard L. Fox