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June 23, 2015

Exemption No. 11888

Regulatory Docket No. FAA–2015–0735

Mr. David M. Garrett

Advanced Robotics Corporation

5901 East Lippizan Way

Hereford, AZ 85615

Dear Mr. Garrett:

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.

By letter dated March 19, 2015, you petitioned the Federal Aviation Administration (FAA) on 

behalf of Advanced Robotics Corporation (hereinafter petitioner or operator) for an 

exemption. The petitioner requested to operate an unmanned aircraft system (UAS) to 

conduct education and training, aerial survey/inspection and imaging, agricultural, forestry, 

wildlife preservation, law enforcement, and search and rescue,.

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. The FAA received one 

comment from the petitioner containing a correction to the petition.

Airworthiness Certification

The UAS proposed by the petitioner are the Advanced Robotics AR−960 and AR−540.
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The petitioner requested relief from 14 CFR part 21, Certification procedures for products 

and parts, Subpart H—Airworthiness Certificates. 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 the requested 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, Advanced Robotics Corporation 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.
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Conditions and Limitations

In this grant of exemption, Advanced Robotics Corporation 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 Advanced 

Robotics AR−960 and AR−540 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 
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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 Columbia, 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.
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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 5 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.
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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.
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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.
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This exemption terminates on June 30, 2017, unless sooner superseded or rescinded.

Sincerely,

/s/

John S. Duncan

Director, Flight Standards Service
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March 19, 2015

U.S. Department of Transportation, Docket Operations 

West Building Ground Floor, Room W12-140

1200 New Jersey Avenue, SE

Washington, DC 20590 

Re: Exemption Request; Section 333 of the FAA Modernization & Reform 

Act and Part 11 of the Federal Aviation Regulations from 14 C.F.R. Part 21; 

14 C.F.R. 45.23(b); 14 C.F.R. 61.113(a)&(b); 91.7(a); 91.9(b) (2); 91.103; 

91.109; 91.119; 91.121; 91.151(a); 91.203(a)&(b); 91.405(a); 91.407(a) (1); 

91.409(a) (2); 91.417(a)&(b)

Dear Sir or Madam,

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

(“Reform Act”) and 14 C.F.R. 11, Advanced Robotics Corporation

(“Petitioner”) hereby applies for an exemption from Federal Aviation 

Regulations (“FARs”) to allow commercial operation of small unmanned 

aircraft systems (“sUAS”) in airspace regulated by the Federal Aviation 

Administration (“FAA”) for use in a variety of commercial applications so long 

as such operations are conducted within and under the conditions outlined 

herein or as may be established by the FAA as required by Section 333.

As described more fully below, the requested exemption would permit the 

commercial operation of sUAS under controlled conditions in airspace that is: 

1) limited; 2) predetermined; and, 3) controlled as to access. The exemption

would also provide safety enhancements to the safe operations currently 

performed by those presently using conventional manned aircraft. Approval 

of this exemption would thereby enhance safety and fulfill the Secretary of 

Transportation’s (the FAA Administrator’s) responsibilities to “....establish 

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

airspace system.” Section 333(c) of the Reform Act.

1. Name and Address of the Petitioner

Advanced Robotics Corporation

Attn: David M. Garrett

5901 E. Lippizan Way

Hereford, AZ 85615

Tel: 520.227.1865

Email: david.garrett@msn.com
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2. Company Background

Advanced Robotics is a non-profit corporation based in Arizona specializing in 

education, knowledge and solutions supporting development and application 

of Unmanned Aircraft Systems and robotics to satisfy Government and 

Commercial needs. Our program assists in public awareness for new career 

paths and education tracks that are new and evolving resulting through

crossover technologies of robotics, air, ground and water. Following approval 

of this exemption request would enable Advanced Robotics the use of our

sUAS to conduct operations within a variety of industry and business 

applications such as Education and Training, Aerial Survey/Inspection and 

Imaging, Agricultural, Forestry, Wildlife Preservation, Law Enforcement, and 

Search and Rescue, 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. 

Petitioner is staffed with personnel who hold Airline Transport Pilot (ATP), 

Certified Flight Instructor (CFI) – Instrument (CFII), Commercial, Instrument,

and Private Pilot ratings, Airframe and Powerplant (A&P) Licenses. The 

Petitioner has extensive experience in UAS flight/payload operations, training,

and maintenance of UAS for the US Army. 

This airman, and UAS knowledge and experience will be leveraged to 

maintain and enhance user and public safety throughout all aspects of 

unmanned aircraft (UA) ground and flight operations conducted by Advanced 

Robotics upon approval of this exemption request.

3. Regulations from which the exemption is requested, If such 

regulations apply to sUASs.

14 C.F.R. Part 21;

14 C.F.R. 45.23(b);

14 C.F.R. 61.113(a) & (b);

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

14 C.F.R. 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 C.F.R. 91.151(a);

14 C.F.R. 91.203(a) & (b);

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

14 C.F.R. 91.407(a)(1);

14 C.F.R. 91.409(a)(2);

14 C.F.R. 91.417(a) & (b).
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4. Statutory Authority for Exemptions

The Federal Aviation Act expressly grants the FAA authority to issue 

exemptions. This statutory authority includes civil aircraft as the term is 

defined under §40101 of the Act, including sUASs, from the requirement that 

all civil aircraft must have a current airworthiness certificate.

The Administrator may grant an exemption from a requirement of a regulation 

prescribed under subsection (a) or (b) of this section or any sections 44702-

44716 of this title if the Administrator finds the exemption in the public

interest. 49 USC §44701(f). See also 49 USC §44711(a); 49 USC §44704; 

14 CFR §91.203(a)(1).

Section 333(b) of the Reform Act assists the Secretary in determining 

whether sUAS may operate in the National Airspace System (NAS) without 

creating a hazard to the user, the public, or pose a threat to national security. 

In making this determination the Secretary must consider:

• The sUAS’s size, weight, speed, and operational capability;

• Whether the sUAS operates within visual line of sight of the operator;

• Operation of the sUAS in close proximity to airports and populated 

areas.

Lastly, if the Secretary determines that such vehicles “may operate safely in 

the national airspace system, the Secretary shall establish requirements for 

the safe operation of such aircraft in the national airspace system.” Id. 

§333(c).

5. Secondary Documentation (Proprietary)

The following secondary documentation is provided for reference as 

supplemental information pertaining to this Petition:

1. AR-sUAS Flight Standards 

2. AR-Preflight Inspection & Operations Check List

3. AR-960 sUAS Manual 

4. AR-540 sUAS Manual 

These documents will be retained at the ground control point accessible by 

the pilot in command (PIC).

6. Unmanned Aircraft Systems

Advanced Robotics designs and purpose builds its sUAS for mission specific 

applications utilizing commercially available airframes, flight controllers, 

electronics, and components. They are multirotor equipped aircraft one meter 

in diameter or less, and less than 55 pounds in weight including payload.
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They operate at a speed of no more than 50 knots and have the ability to 

hover, and move in the vertical and horizontal plane simultaneously. They 

are equipped with GPS Flight Controllers and data link communications 

capability for operator control via ground control station or hand radio 

transmitter controllers and have battery-limited flight duration of less than one 

hour. The GPS Flight Controller can be programmed to limit flight duration 

with auto-land functions, and limits for flight distance and above ground level 

(AGL) altitude, and have return-to-home, loiter, and predetermined landing 

location functions in the event of lost data link communications or flight 

anomalies. Operating within visual line of sight (VLOS) of the PIC and visual 

observer (VO) at no more than 500 feet AGL and will operate only within the 

areas described herein. Such operations will ensure that the sUAS will not 

create a hazard to users of the NAS or the public as described in the FMRA 

§333(b). 

Advanced Robotics proposes within this petition the use of two different sUAS 

platforms, AR-960 and AR-540, to support varied mission, payload 

configurations, and training purposes -- see provided supplemental Manuals 

for each. General specifications are as follows: 

• AR-960 Hex Rotor: 

Airframe: Carbon Fiber Hex Rotor – 960mm Diameter

Weight: 20 pounds (maximum with payload)

Propulsion: Six 400KV Electric Motors 

Propellers: Carbon Fiber 14” – 16” 

Power: 22.2 Volt, (6S) Lithium-Polymer batteries – Dual/Redundant

Speed: 0 - 45 knots

Flight Time: 40 minutes

Autopilot: GPS Flight Controller/Autopilot

Data Link: FCC approved 2.4 GHz

Video: FCC approved 5.8 GHz

Telemetry: Voltage, Current, Altitude, GPS Lat/Long, Ground Speed

• AR-540 Quad Rotor: 

Airframe: Composite/Aluminum Quad Rotor – 540mm Diameter

Weight: 8 pounds (maximum with payload)

Propulsion: Four 740KV Electric Motors

Propellers: Carbon Fiber 10” – 12” 

Power: 14.8 Volt, (4S) Lithium-Polymer batteries – Dual/Redundant

Speed: 0 - 45 knots

Flight Time: 30 minutes

Autopilot: GPS Flight Controller/Autopilot

Data Link: FCC approved 2.4 GHz 

Video: FCC approved 5.8 GHz 

Telemetry: Voltage, Current, Altitude, GPS Lat/Long, Ground Speed
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Advanced Robotics maintains a maintenance log book for each sUAS that 

documents maintenance history. In addition to PIC pre-flight inspections 

conducted before each flight our FAA licensed A&P personnel conduct annual

aircraft inspection and maintenance checks. This includes review of system 

and telemetry data files logged from prior flights, inspection for loose or worn 

components, balancing of props, cleaning of motors, battery voltage and cell 

balancing checks, etc., and performing any needed system repair and 

upgrades to include software/firmware for the GPS, Flight Controller/Autopilot, 

Radio Transmitter, and Ground Control Station. All scheduled or 

unscheduled maintenance and repair actions are documented within the 

sUAS maintenance log book. Upon completion of any repair, modification or 

upgrade, the aircraft is test flown by a qualified PIC and documented within 

the maintenance log book prior to return to service. 

7. Operation of the Unmanned Aircraft

The PIC will be an FAA licensed airman with at least a private pilot’s 

certificate and third class medical. Additionally, the PIC will have a minimum 

of 10 hours sUAS multirotor experience of which at least 5 hours are with the 

specific make/model sUAS to be operated (AR-960, AR-540), per the 

Advanced Robotics sUAS Flight Standards document. 

Training of PICs who do not meet the sUAS multirotor experience will be 

gained within dedicated training sessions through use of a multirotor

computer simulator (ground training) and the sUAS platform(s) (logged flight 

time) as requested through this exemption. Upon meeting the sUAS flight 

hour requirements, logged in a consistent manner per 14 CFR §61.5(b), a 

flight proficiency check will be conducted by a Advanced Robotics FAA rated 

CFI prior to allowing a PIC to conduct flight operations. Flight currency will be 

maintained by the PIC having logged 30 minutes flight time within the 

proceeding 90 days with the specific make/model UAS platform. Regaining 

currency will be achieved in dedicated training/currency sessions. In addition 

to flight proficiency, the PIC will be trained in use of the radio control 

transmitter, ground control station, pre-flight inspection of the sUAS, and 

operational procedures per Advanced Robotics sUAS Flight Standards 

document paraphrased as follows.

Minimum crew for each flight operation will consist of the sUAS PIC and 

Visual Observer (VO). Flights will be conducted within VLOS of the PIC at all 

times with VO duties assisting PIC in maintaining VLOS and situational 

awareness of obstructions, hazards and avoiding other aircraft. 

Communication between the PIC and VO will be maintained through direct 

voice communications and/or through use of two-way radio or cell phone

throughout the duration of flight.

Prior to each flight the PIC will conduct a thorough pre-flight inspection, per 
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the Advanced Robotics Preflight and Operations Checklist, to ensure the 

sUAS is in safe condition for flight. The pre-flight will include physical 

inspection of components, battery voltage level checks, motor run-up, 

payload system, ground control station and communications checks in 

preparation of flight. If the inspection reveals a condition that prohibits safe 

operation, the PIC will remove the aircraft from service until the necessary 

maintenance has been performed and documented and the sUAS is found to 

be in a condition for safe flight.

The PIC will conduct pre-flight planning to include obtaining weather briefings, 

identifying hazards and obstructions, and establishing predetermined mission 

flight path and limited and controlled area for safe operation. The Petitioner

will submit to the Air Traffic Organization (ATO) a Certificate of Waiver or 

Authorization (COA) prior to conducting any flight operations. The Petitioner

will request a Notice to Airman (NOTAM) not more than 72 hours in advance, 

but not less than 48 hours prior to the operation.

All flight operations will be conducted within a limited area that is strictly 

controlled over private or controlled-access property with permission from the 

land owner or their authorized representative for each flight to be conducted. 

The PIC will conduct pre-flight safety briefings with all personnel supporting 

flight activities in regard to the planned sUAS operations and mission plan 

prior to each flight. Flight operations will typically be conducted at least 500 

feet from all nonparticipating flight operation people, vessels, vehicles, and 

structures unless there are barriers or structures that safely protects 

nonparticipating persons in event of accident. In the event nonparticipating 

persons leave such protection and are within 500 feet of the sUAS, the PIC 

will immediately cease flight operations. Additionally, if owner of vessels, 

vehicles, or structures provides permission and the PIC determines safe 

operations can be conducted with undue risk to operating personnel then 

flight operations may be conducted closer than 500 feet. 

Advanced Robotics will not conduct flight operations over congested or 

densely populated areas, or within 5 miles of an airport unless a letter of 

agreement is obtained from the airport management and per NOTAM. All 

flights will be conducted under visual meteorological conditions (VMC) during 

daylight hours, at less than 50 knots airspeed and an altitude no greater than 

500 feet AGL, and will 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. Maximum flight time for each operational flight will be 40 

minutes and allowing for no less than 20% battery as indicated by real-time 

telemetry voltage/current data relayed by the aircraft sensors to the PIC 

control station.

In event the PIC losses data link communications, the GPS equipped sUAS 

have the capability to return to a pre-determined location and land and 
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provides the PIC capability to abort flight and initiate loiter and return-to-home 

functions. If an in-flight emergency occurs, the PIC will immediately abort 

flight and initiate landing procedures. 

By adhering to these operational procedures, Advanced Robotics, will 

achieve a safety level equivalent to, or greater than that, directed by the rules 

in which they seek exemption. sUAS are inherently safer in all facets due to 

the fact they are much smaller, fly at much slower speeds, have no human 

operators or occupants on board and no flammable fuels to be concerned of 

in event of crash. As sUAS processes are further refined, and commercial 

flight experience gained, the operations will serve to enhance an already 

higher level of safety compared to manned flight operations in which serves 

the public’s best interest in the FAA’s pursuit to integrate UAS into the NAS.

Due to the small size of the sUAS involved, ability of the PIC to control and 

set flight parameters, and the controlled and limited environment in which 

they will operate, the Petitioner falls squarely within that zone of safety (an 

equivalent level of safety) in which Congress envisioned that the FAA must, 

by exemption, allow commercial operations of sUAS to commence 

immediately. Additionally, due to the Private Pilot rating of the PIC, the size 

of the sUASs, limited payload capacity and flight durations, the use of 

batteries versus flammable fuels, and the limited and tightly controlled areas 

in which the sUASs will operate, approval of the application presents no 

national security issue.

Given the clear direction in FRMA §333, the authority contained in the 

Federal Aviation Act, as amended, the strong equivalent level of safety 

surrounding the proposed operations, and the significant public benefit, 

including enhanced safety, reduction in environmental impacts due to battery 

operation, and reduced costs of sUAS aircraft assets as compared to 

conventional aircraft, the grant of the requested exemptions is in the public 

interest. Accordingly, Advanced Robotics respectfully requests that the FAA 

grant the requested exemption without delay.

8. Description of Specific Regulations 

Pursuant to 14 C.F.R. § 11.81(e), Advanced Robotics seeks exemption from 

the below mentioned regulations and provides reason as to why the 

exemption should be approved based on the level of safety at least equal to 

that of which the rules require.

• 14 C.F.R. Part 21 Subpart H – Airworthiness Certificates

Ø Establishes: The procedural requirements for the issuance of 

airworthiness certificates as required by 14 C.F.R. § 

91.203(a)(1)
8

Given the small size of the sUAS, the controlled operating areas, 

limitations and conditions Advanced Robotics will adhere to during 

flight operations, an exemption from Part 21 Subpart H meets the 

requirements of an equivalent level of safety under Part 11 and Section 

333 of the “Reform Act” with consideration “of the size, weight, speed, 

operational capability, and proximity to airports and populated areas of 

the particular UAS.”

• 14 C.F.R. § 45.23(b) – Aircraft Marking and Identification 

Requirements

Ø 14 C.F.R. § 45.23(b), Markings of the Aircraft, states: 

When marks include only the Roman capital letter "N" and the 

registration number is displayed on limited, restricted or lightsport category aircraft or experimental or provisionally 

certificated aircraft, the operator must also display on that 

aircraft near each entrance to the cabin, cockpit, or pilot station, 

in letters not less than 2 inches nor more than 6 inches high, the 

words "limited," "restricted," "light-sport, "experimental," or 

"provisional," as applicable.

The sUAS to be flown by Advanced Robotics have no airworthiness 

certificate, an exemption may be needed as the sUAS have no 

entrance to the cabin, cockpit, or pilot station on which the word 

“Experimental” can be placed. The FAA has issued the following 

exemptions to this regulation to Exemptions Nos. 10700, 8738, 10167 

and 10167A.

• 14 C.F.R. § 61.113(a) and (b): Private Pilot Privileges and 

Limitations: Pilot in Command

Ø Sections 61.113 (a) and (b) limit private pilots to noncommercial operations.

Because the sUAS will not carry a pilot or passengers, the proposed 

operations can achieve the equivalent level of safety of current 

operations by requiring the PIC operating the aircraft to have a private 

pilot’s license rather than a commercial pilot’s license to operate a 

sUAS. Unlike a conventional manned aircraft, a sUAS is remotely 

controlled by a ground-based operator. The operational area is 

controlled and restricted, and all flights are planned and coordinated in 

advance. The level of safety exceeds that provided by a single 

individual holding a commercial pilot’s certificate operating a 

conventional aircraft. The risks associated with the use of a sUAS are 

so diminished from the level of risk associated with commercial 

operations contemplated by Part 61 allowing sUAS use by a private 

pilot as the PIC exceeds the present level of safety sought by 14 
9

C.F.R. §61.113 (a) and (b). 

• 14 C.F.R. 91.7(a) – Civil Aircraft Airworthiness

Ø No person may operate a civil aircraft unless it is in an airworthy 

condition.

There is no airworthiness certificate for the sUAS to be operated by 

Advanced Robotics. To provide an equivalent level of safety, the PIC 

will conduct pre-flight inspections to ensure airworthiness. During 

flight, the PIC will adhere to § 91.7(b) and abort air operations 

immediately upon identification of an in-flight anomaly or emergency. 

Licensed A&P staff will conduct annual inspections. Maintenance log 

books will be maintained for each sUAS thereby achieving an

equivalent level of safety.

• 14 C.F.R. § 91.9 (b) (2): Civil Aircraft Flight Manual in the Aircraft. 

Ø Section 91.9 (b) (2) provides: No person may operate a U.S.-

registered civil aircraft ..(2) For which an Airplane or Rotorcraft 

Flight Manual is not required by §21.5 of this chapter, unless 

there is available in the aircraft a current approved airplane or 

Rotorcraft Flight Manual, approved manual material, markings, 

and placards, or any combination thereof.

The sUAS, given their size and configuration have no ability or place to 

carry such a flight manual on the aircraft, not only because there is no 

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

an item on the aircraft platform. The equivalent level of safety will be

maintained by keeping the sUAS documentation at the ground control 

point where the PIC will have access to it. The FAA has issued the 

following exemptions to this regulation: Exemption Nos. 8607, 8737, 

8738, 9299, 9299A, 9565, 95658, 10167, 10167A, 10602, 32827, and 

10700.

• 14 C.F.R. 91.103 – Pre-flight Action

Ø Each pilot in command shall, before beginning a flight, become 

familiar with all available information concerning that flight. This 

information must include- (paragraphs a, b, 1 and 2)

The PIC will take all actions, to include flight and mission planning, 

reviewing weather, flight battery requirements, safe take-off and 

landing areas, and aircraft performance data before commencement of 

flight. In addition, the PIC will verify the sUAS is ready for flight by 

conducting a pre-flight inspection and run up of systems and data-link

communications checks prior to each flight.

The exemption requested for this section is specifically addressed 
10

toward the requirements which do not apply to sUAS operations such 

as runways and air traffic control integration. The airport manager will 

be notified and approval obtained prior to any operations being 

executed less than five statute miles of an operating airport.

14 C.F.R. §91.109: Flight instruction

Ø Section 91.109 provides 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.

sUAS and remotely piloted aircraft, by their design do not have fully 

functional dual controls. Flight control is accomplished through the use 

of a radio transmitter or ground control station that communicates with 

the aircraft via a receiver in the sUAS. The FAA has approved 

exemptions for flight training without fully functional dual controls for a 

number of aircraft and for flight instruction in experimental aircraft. See 

Exemption numbers 5778K & 9862A. The equivalent level of safety 

provided by the fact that neither a pilot nor passengers will be 

occupants in the aircraft and by the small size and slow speed of the 

sUAS.

• 14 C.F.R. 91.119 – Minimum Safe Altitudes

Ø Except when necessary for takeoff or landing, no person may 

operate an aircraft below the following altitudes: (c) Over other 

than congested areas. An altitude of 500 feet above the surface, 

except over open water or sparsely populated areas. In those 

cases, the aircraft may not be operated closer than 500 feet to 

any person, vessel, vehicle, or structure.

Section 91.119 establishes safe altitudes for operation of civil aircraft. 

Section 91.119 (d) allows helicopters to be operated at less than the 

minimums prescribed, provided the person operating the helicopter 

complies with any route or altitudes prescribed for helicopters by the 

FAA. This exemption is for a sUAS and the exemption requests 

authority to operate at altitudes up to 500 AGL underneath navigable 

airspace and in class E and G airspace maintaining safe separation 

from manned aircraft, an exemption may be needed to allow such 

operations.

The equivalent level of safety will be achieved given the size, weight, 

speed of the sUAS as well as the limited and controlled location 

where it is operated. Compared to flight operations with manned 

aircraft weighing far more than the maximum 55 pounds proposed 

herein, and the lack of flammable fuel, any risk associated with these 

operations is far less than those presently presented with 

conventional manned aircraft. In addition, the low-altitude operations 
11

of the sUAS will ensure separation between it and operations of 

conventional manned aircraft that must comply with Section 91.119.

• 14 C.F.R. §91.121 Altimeter Settings

Ø This regulation requires 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." 

As the sUAS do not have an adjustable barometric altimeter an 

exemption is required. An equivalent level of safety will be achieved 

by the PIC, confirming the altitude of the launch site via the sUAS

GPS.

• 14 C.F.R. 91.151(a) – Fuel Requirements for Flight in VFR 

Conditions

Ø 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;

This regulation is written based on the capabilities of a traditional 

aircraft which have flight times of several hours or greater; therefore, 

with the majority of sUAS which have flight times of only an hour or 

less, this regulation would effectively deny the ability of the air vehicle 

to operate.

To meet the intent, Advanced Robotics, will limit its sUAS flights to 40 

minutes, or no less than 20% remaining battery power, which ever 

occurs first, to ensure safe landing and retrieval of the air vehicle and 

providing at least an equal level of safety. Similar exemptions have 

been granted to other operations, including Exemptions 2689F, 5745, 

10673, and 10808.

• 14 C.F.R. §91.203 (a) and (b): Carrying Civil Aircraft Certification 

and Registration

Ø The regulation provides in pertinent part:

(a) Except as provided in§ 91.715, no person may operate a 

civil aircraft unless it has within it the following: (1) An 

appropriate and current airworthiness certificate....

(b) No person may operate a civil aircraft unless the 

airworthiness certificate required by paragraph (a) of this section 

or a special flight authorization issued under §91.715 is 

displayed at the cabin or cockpit entrance so that it is legible to 
12

passengers or crew. 

The sUAS fully loaded weighs no more than 55 lbs. and is operated 

without an onboard pilot. As such, there is no ability or place to carry 

certification and registration documents or to display them on the 

sUAS. An equivalent level of safety will be achieved by keeping these 

documents at the ground control point where the PIC will have 

immediate access to them, to the extent they are applicable to the 

sUAS. The FAA has issued numerous exemptions to this regulation. A 

representative sample of other exceptions includes Exemption 

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

• 14 C.F.R. 91.405(a), 91.407(a)(1), 91.409(a)(2) and 91.417(a) & (b) –

Maintenance Inspections

Ø 91.405(a) States: Each owner or operator of an aircraft—(a) 

Shall have that aircraft inspected as prescribed in subpart E of 

this part and shall between required inspections, except as 

provided in paragraph (c) of this section, have discrepancies 

repaired as prescribed in part 43 of this chapter.

Ø 91.407(a)(1) States: (a) No person may operate any aircraft 

that has undergone maintenance, preventive maintenance, 

rebuilding, or alteration unless—(1) It has been approved for 

return to service by a person authorized under § 43.7 of this 

chapter.

Ø 91.409(a)(2) States: (a) Except as provided in paragraph (c) of 

this section, no person may operate an aircraft unless, within 

the preceding 12 calendar months, it has had—(2) An 

inspection for the issuance of an airworthiness certificate in 

accordance with part 21 of this chapter. No inspection 

performed under paragraph (b) of this section may be 

substituted for any inspection required by this paragraph unless 

it is performed by a person authorized to perform annual 

inspections and is entered as an ‘‘annual’’ inspection in the 

required maintenance records.

Ø 91.417(a) & (b) States: (a) Except for work performed in 

accordance with §§ 91.411 and 91.413, each registered owner 

or operator shall keep the following records for the periods 

specified in paragraph (b) of this section: (paragraphs 1 (i – iii), 

2 (i – vi)); (b) The owner or operator shall retain the following 

records for the periods prescribed: (paragraphs 1 – 3)

Pre-flight inspections and routine maintenance will be accomplished by 

the PIC to ensure the sUAS is in good working order prior to flight. If 

mechanical issues or emergency situations arise the sUAS can land 
13

immediately and given its small size poses very little risk to persons or 

property. Upon completion of any repair, modification or upgrade, the 

aircraft is test flown by a qualified PIC and documented within the 

maintenance log book prior to return to service. Annual inspections

and maintenance will be conducted and documented within the sUAS 

maintenance log book by licensed A&P personnel to meet the intent of 

these regulations and provide an equivalent level of safety.

9. Summary the FAA may publish in the Federal Register

Advanced Robotics seeks an exemption from the following Regulations: 14 

C.F.R. Part 21; 14 C.F.R. 45.23(b); 14 C.F.R. 61.113(a)&(b); 91.7(a); 91.9(b) 

(2); 91.103; 91.109; 91.119; 91.121; 91.151(a); 91.203(a)&(b); 91.405(a); 

91.407(a) (1); 91.409(a) (2); 91.417(a)&(b) to commercially operate its small 

unmanned aircraft systems to support a variety of industry and business 

applications, to include, but not limited to, Education and Training, Aircraft

Survey/Inspection and Imaging, Ranch and Agricultural, Forestry, Wildlife 

Preservation, Law Enforcement, and Search and Rescue. Granting 

Advanced Robotics request for exemption will reduce current risk levels and 

thereby enhance safety.

Further, Advanced Robotics sUAS operates at lower altitudes, up to 500 feet 

AGL, in predetermined and controlled airspace, weighing less than 55 pounds 

and traveling at speeds less than 50 knots. They will provide at least an 

equivalent level of safety as that achieved under current FARs.

Advanced Robotics respectfully requests that the FAA grant its exemption 

request without delay. The FAA has the authority to issue the exemption 

sought by Advanced Robotics pursuant to the Federal Aviation Act, 85 P.L. 

726 (1958), as amended (the "Act").

By__________________________ for: Advanced Robotics

David M. Garrett 5901 E. Lippizan Way

Hereford, AZ 85615

Tel: 520.227.1865

david.garrett@msn.com