Eric Williams

CEO 

UdroneAir dba

7315 Wilcox Drive

Dallas, Texas 75232

469-212-6804

June 4, 2015

U. S. Department of Transportation 

Docket Management System 

1200 New Jersey Ave., 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. 45.23(b);14 CFR Part 

21;14 CFR61.113 (a) & (b); 91.7 (a); 91.9 (b) (2); 91.103(b); 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: Secretary of Transportation

UdroneAir dba hereby petitions the Secretary of Transportation and Federal Aviation 

Administration ("FAA") for exemption to the above referenced and below more fully 

described Federal Aviation Regulations, ("FARs") that currently may or may not apply to 

the recreational/ business operations of model aircraft including small unmanned aerial 

vehicles/systems ("sUAS"). 

UdroneAir is aware the FAA has granted similar exemptions for aerial photography and 

is on the verge of granting similar exemptions. 

2. Petition for Exemption 

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

and 14 C.F.R. Part 11, UdroneAir developer and operator of small unmanned aerial 

vehicles ("sUAS ") equipped to conduct aerial photography/Inspection/ included but not 

limited to the following; 
1. Safety & Education training RC UAS flight simulators

2. Television productions, music video productions, advertising and news 

gathering.

3. Marketing of residential and commercial real estate 

4. Inspection surveys i.e. agricultural land for farmers, roofing, oil & gas 

companies, shoreline protection for ecological concerns

5. Assist local law enforcement in emergency matters, over land, water-ways, and 

oceans, disaster relief, medical supplies delivery and missing persons.

6. State side virtual tours

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

sUAS under controlled conditions in airspace that is 1) limited 2) predetermined; and 3) 

controlled as to access. 

This exemption will also provide safety enhancements to the already safe operations 

within the aerial photography industry presently using conventional aircraft and small, 

unmanned and relatively inexpensive sUAS.

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 FMRA. 

3.

UdroneAir

Eric Williams

7315 Wilcox Drive

Dallas, Texas 75232

udroneair@yahoo.com

www.udroneair.com

460-212-6904

4. Regulations Petitioner Petitions for Exemption, If Such Regulations Apply to sUAS.

14 CFR Part 21 

14 C.F.R. 91.109 

14 CFR 91.405 (a) 

14 C.F.R. 45.23(b) 

14 C.F. R. 91.119 

14 CFR 407 (a) (1) 

14 CFR 61.113 (a) & (b) 

14 C.F.R. 91.121 

14 CFR 409 (a) (2) 

14 C.F.R. 91.7 (a) 

14 CFR 91.151 (a) 

14 CFR 417 (a) & (b) 

14 CFR 91.9 (b) (2) 

14 CFR 91.203 (a) & (b) 

14 C.F.R. 91.103 
This exemption application is expressly submitted to fulfill the goals in passing 

Section 333 (a) through (c) of the Reform Act. 

This law directs the Secretary of Transportation to consider whether certain unmanned 

aircraft systems may operate safely in the national airspace system ("NAS") before 

completion of the rulemaking required under Section 332 of the FMRA. In making this 

determination, the Secretary is required to determine which types of sUAVS/UAS do not 

create a hazard to users of the NAS, or the public, or pose a threat to national security in 

light of the following:

A. The s sUAS s size, weight, speed, and operational capability; 

B. Operation of the s sUAS in close proximity to airports and populated areas; 

and 

C. Operation of the s sUAS within visual line of sight of the operator. FMRA § 

333 (a)

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." /d. §333(c) (emphasis added). 

UdroneAir interprets this provision to place the duty on the Secretary/FAA 

Administrator to not only process applications for exemptions under section 333, but for 

the Secretary/Administrator to affirmatively craft conditions for the safe operation of the 

s sUAS, if it should be determined that the conditions set forth herein do not fulfill the 

statutory requirements for approval. 

The Federal Aviation Act expressly grants the Secretary/FAA Administrator the authority 

to issue exemptions. This statutory authority, by its terms, includes exempting civil 

aircraft, as the term is defined under §401 01 of the Act, which currently may or hereafter 

may include s sUAS, from the requirement that all civil aircraft must have a current 

airworthiness certificate. 

The Secretary/FAA 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 Secretary/FAA Administrator finds the exemption in the public 

interest. 49 U.S.C. §44701 (f) See also 49 USC §44711 (a); 49 USC §44704; 14 CFR 

§91.203 (a) (1). 

UdroneAir sUAS are small multi-rotorcraft equipped with an on board NAZA computer 

stabilization controller and GPS, weighting 55 lbs or less and most 

typically less than 10 lbs., including camera/payload. They operate, under normal 

conditions, at speeds of 5-40 KIAS and at speed of no more than 50 KIAS and have the 

capability to hover and move in the vertical and horizontal plane 

independently/simultaneously. 

They will operate in line of sight and will operate only within the areas described herein. 

Such operations will insure that the s sUAS will "not create a hazard to users of the NAS 

or the "public" as described in the FMRA §333(b).
Given the small size of the sUAS involved, and the limited environment within which 

they will operate, UdroneAir falls squarely within that zone of safety in which Congress 

envisioned that the FAA must, by exemption, allow commercial operations of sUAS to 

commence immediately. 

Also, due to the size of the sUAS and the restricted areas in which the relevant sUAS

will operate, approval of the application presents nonational security issue. 

Given the clear direction in FMRA §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 (including reduced emissions associated with allowing sUAS for 

filming operations rather than full-sized aircraft, the grant of the requested exemptions is 

in the public interest. 

Accordingly, UdroneAir respectfully requests that the FAA grant the requested 

exemption without delay.

5. Limitations and Conditions 

UdroneAir proposes that the exemption requested herein be issued pursuant the 

limitations and conditions listed herein. These conditions/limitations provide for an even 

higher level of safety to operations under the current regulatory structure which apply to 

actual certificated aircraft because the proposed operations represent a safety 

enhancement to the already very safe sUAS filming operations conducted by recreational 

sUAS and conventional aircraft. 

UdroneAir primary mission includes but are not limited to marketing of residential and 

commercial real estate, inspection/survey of agricultural land for Farmers, Shoreline 

protection for ecological concerns, television and news coverage, assist local law 

enforcement in emergency matters. 

UdroneAir business locations shall be primarily in the US. These conditions to which 

UdroneAir agrees to be bound when conducting business/commercial operations under 

this FAA issued exemption are consistent with the administrators grant of exemption to 

the MPAA, include: 

1. The sUAS weighs less than 55 pounds (25 Kg), including energy source(s) and 

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

aircraft: Cheerson CX 20 quadcopter.

2. The sUAS will not be flown at a speed exceeding a ground speed of 50 knots. 

3. Flights will be operated at an altitude of no more than 400 feet above ground level 

(AGL), as indicated by the procedures specified in the operator's manual. All altitudes 

reported to ATC must be in feet AGL. 
4. The sUAS will be operated within visual line of sight (VLOS) of the Operator at all 

times. This will require the operator to be able to use human vision unaided by any 

device other than corrective lenses, as specified on the PIC's FAA-issued medical 

certificate.

5. All UdroneAir operations will utilize a visual observer (VO). 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. 

6. The operator's checklist is considered acceptable to the FAA, provided the additional 

Requirements identified in these conditions and limitations are added or amended. The 

operator's checklist and this grant of exemption must be maintained and made available 

to the administrator upon request. If a discrepancy exists between the conditions and 

limitations in this exemption and the procedures outlined in the checklists the conditions 

and limitations herein take precedence and must be followed. Otherwise, the operator 

will follow the procedures as outlined in its checklists.

The operator will update or revise its operator's checklists. It will be the operator's 

Responsibility to track such revisions and present updated and revised documents to the 

administrator upon request. The operator will present updated and revised 

documents if UdroneAir petitions for extension or amendment. If the operator 

determines that any update or revision would affect the basis for which the FAA granted 

this exemption, then the operator must petition for amendment to their exemption. The 

FAA's sUAS Integration Office (AFS-80) may be contacted if questions arise regarding 

updates or revisions to the operator's manual. 

7. Prior to each UdroneAir flight the PIC will inspect the sUAS to ensure it is in a 

condition for safe flight. If the inspection reveals a condition that affects the safe 

operation of the sUAS, the aircraft will be prohibited from operating until the necessary 

maintenance has been performed and the sUAS is found to be in a condition for safe 

flight. The Ground Control Station, will be utilized, and included in the preflight 

inspection. All maintenance and alterations will be properly documented in the aircraft 

records. 

8. Any UdroneAir sUAS that has undergone maintenance or alterations that affect the 

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

will undergo a functional test flight in accordance with the operator's manual. The PIC 

will conduct the functional test flight and will make an entry in the sUAS aircraft records 

of the flight. The requirements and procedures for a functional test flight and aircraft 

record entry must be added to the operator's manual. 

9. UdroneAir operators will follow the manufacturer's sUAS aircraft/component, 

maintenance, overhaul, replacement, inspection, and life limit requirements. When 

unavailable, aircraft maintenance/ component/overhaul, replacement, and 

inspection/maintenance requirements will be established and identified in the operator's 

manual. At a minimum, the following must be included in the operator's manual: 
a. Actuators I Servos 

b. Transmission (single rotor) 

c. Powerplant (motors) 

d. Propellers 

e. Electronic speed controller 

f. Batteries 

g. Mechanical dynamic components (single rotor) 

h. Remote command and control 

i. Ground control station (if used) 

j. Any other components as determined by the operator 

10. The operator in command (OIC) will own a certificate for the satisfactory completion 

of the ground-flight school portion.

11. Prior to UdroneAir operations conducted for the purpose of motion picture filming 

(or similar operations), the OIC will have accumulated and logged, in a manner 

consistent with 14 CFR § 61.51 (b), a minimum of 25 hours of total time as a sUAS

rotorcraft pilot and at least ten hours logged as a sUAS pilot with a similar sUAS type 

(single blade or multi rotor). Prior documented flight experience that was obtained in 

compliance with applicable regulations may satisfy this requirement. Training, 

proficiency, and experience-building flights can also be conducted under this grant of 

exemption to accomplish the required flight cycles and flight time. During training, 

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

will be considered non-participants, and the PIC will operate the sUAS with appropriate 

distance from non-participants in accordance with 14 CFR § 91.119. Prior to operations 

conducted for the purpose of motion picture filming (or similar operations), the OIC must 

have accumulated and logged, in a manner consistent with 14 CFR § 61.51 (b), a 

minimum of five hours as sUAS pilot operating the make and model of sUAS to be 

utilized for operations under the exemption and three take-offs and three landings in the 

preceding 90 days. Training, proficiency, experience-building, and take-off and landing 

currency flights will be conducted under this grant of exemption to accomplish the 

required flight time and 90 day currency. During training, proficiency, experiencebuilding, and take-off and landing currency flights all persons not essential for flight 

operations are considered non-participants, and the PIC must operate the UA with 

appropriate distance from non-participants in accordance with 14 CFR § 91.119. 

12. Prior to UdroneAir operations conducted for the purpose of motion picture filming 

(or similar operations), a flight demonstration, administered by an operator-approved and 

-qualified pilot must be successfully completed and documented. 

13. The sUAS will not be operated directly over any person, except authorized and 

consenting production personnel, below an altitude that is hazardous to persons or 

property on the surface in the event of a sUAS failure or emergency. 
14. Regarding the distance from participating persons, the operator's manual has safety 

mitigations for authorized and consenting production personnel. At all times, these 

persons will be essential to the closed-set film operations. Because these procedures 

are specific to participating persons, no further FSDO or Aviation Safety Inspector (ASI) 

approval is necessary for reductions to the distances specified in the petitioner's 

manuals. This is consistent with the manned aircraft procedures described in FAA Order 

8900.1, V3, C8, S1 Issue a Certificate of Waiver for Motion Picture and Television 

Filming. 

15. The sUAS will not be operated directly over any person, except authorized and 

consenting production personnel, below an altitude that is hazardous to persons or 

property on the surface in the event of a sUAS failure or emergency. 

16. Regarding distance from non-participating persons, UdroneAir operators will ensure 

that no persons are allowed within 500 feet of the area except those consenting to be 

involved and necessary for the filming production. This provision may be reduced to no 

less than 200 feet if it would not adversely affect safety and the Administrator has 

approved it. For example, an equivalent level of safety may be determined by an aviation 

safety inspector's evaluation of the filming production area to note terrain features, 

obstructions, buildings, safety barriers, etc. Such barriers may protect non-participating 

persons (observers, the public, news media, etc.) from debris in the event of an 

accident. This is also consistent with the same FAA Order 8900.1, V3, C8, S1. 

17 .If the sUAS loses communications or loses its GPS signal, the sUAS will return to a 

pre-determined GPS location within the security perimeter and land or be recovered. 

18. The sUAS OIC will abort the flight in the event of unpredicted obstacles or 

emergencies. The Operator will carry/use appropriate LIPO battery protective bags 

and fire extinguishing equipment. 

19. Each sUAS operation will be completed within 30 minutes flight time or with 25% 

battery power remaining, whichever occurs first. 

20.1n addition to the conditions and limitations proposed by the operator, the FAA has 

determined that any operations conducted under this grant of exemption must be done 

pursuant to the following conditions and limitations: 

21.UdroneAir operators will obtain an Air Traffic Organization (ATO) issued Certificate 

of Waiver or Authorization (GOA) prior to conducting any operations under this grant of 

exemption. This GOA will also require the operator to request a Notice to Airman (NOT 

AM) not more than 72 hours in advance, but not less than 48 hours prior to the operation. 

22. All UndroneAir aircraft operated in accordance with this exemption will 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 will be as large as practicable. 
23. The OIC will develop procedures to document and maintain a record of the sUAS

maintenance, preventative maintenance, alterations, status of replacement/overhaul 

component parts, and the total time in service of the sUAS. These procedures must be 

added to the operator's manual/checklists. 

24. Each sUAS operated under this exemption will comply with all manufacturer Safety 

Bulletins. 

25. The OIC will develop sUAS technician qualification criteria. These criteria will be 

added to the operator's manual/Checklists. 

26. The preflight inspection section in the operator's checklists manual will be amended 

to include the following requirement: The preflight inspection will account for all 

discrepancies, i.e. inoperable components, items, or equipment, not covered in the 

relevant preflight inspection sections of the operator's manual. 

27. Before conducting UdroneAir operations, the radio frequency spectrum used for 

operation and control of the sUAS will comply with the Federal Communications 

Commission (FCC) or other appropriate government oversight agency requirements. 

28. At least three days before scheduled filming, the OIC of the sUAS affected by this 

exemption will submit a written Plan of Activities to the local 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 will include at least the following: 

a. Dates and times for all flights 

b. Name and phone number of the operator for the sUAS filming production conducted 

under this grant of exemption 

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

sUAS

d. Make, model, and serial or N-number of sUAS to be used 

e. Name and certificate number of sUAS PICs involved in the filming production event 

f. A statement that the UdroneAir 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 

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 

29. The documents required under 14 CFR § 91.9 and § 91.203 will be available to the 

OIC at the ground control station of the sUAS any time the aircraft is operating. These 

documents will be made available to the administrator or any law enforcement official 

upon request. 

30. The sUAS will remain clear and yield the right of way to all other manned operations 

and activities at all times (including, but not limited to, ultralight vehicles, parachute 

activities, parasailing activities, hang gliders, etc.). 
31. UdroneAir sUAS operations may be conducted during night, as defined in 14 CFR § 

1.1. All operations will be conducted under visual meteorological conditions (VMC). 

Flights under special visual flight rules (SVFR) will not be permitted.. 

32. The sUAS will not be operated by the OIC from any moving device or vehicle.

33. The sUAS will not be operated less than 200 feet below or less than 2,000 feet 

horizontally from a cloud or when visibility is less than 3 statute miles from the PIC. 

34.The sUAS will not operate in Class B, C, or D airspace without written approval from 

the FAA. The sUAS will not operate within 5 nautical miles of the geographic center of a 

non-towered airport as denoted on a current FAA-published aeronautical chart unless a 

letter of agreement with that airport's management is obtained, and the operation is 

conducted in accordance with a NOT AM as required by the operator's GOA The letter 

of agreement with the airport management will be made available to the Administrator 

upon request. 

35.Any 1) incident, 2) accident, or 3) flight operation that transgresses the lateral or 

vertical boundaries of the operational area as defined by the applicable GOA will be 

reported to the Federal Aviation Administration's (FAA) UAS Integration Office (AFS80) within 24 hours. Accidents will be reported to the National Transportation Safety 

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

flight operations will not be conducted until the incident, accident, or transgression is 

reviewed by AFS-80 and authorization to resume operations is provided. Unless 

otherwise specified in this grant of exemption, the SUAV, and operator must comply 

with all applicable parts of 14 CFR including, but not limited to, parts 45, 47, 61, and 91.

6. 

Description of Regulations Which May Apply From Which Petitioner Requests 

Exception 14 C.F.R. Part 21, Subpart H: Airworthiness Certificates 14 C.F.R. §91.203 

(a) (1) 

Subpart H, entitled Airworthiness Certificates, establishes the procedural requirements 

for the issuance of airworthiness certificates as required by FAR §91.203 (a) (1). Given 

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

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

level of safety under Part 11 and Section 333 of the FMRA. The Federal Aviation Act (49 

U.S.C.§44701 (f)) and Section 333 of the FMRA both authorize the FAA to exempt 

aircraft from the requirement for an airworthiness certificate, upon consideration of the 

size, weight, speed, operational capability, and proximity to airports and populated areas 

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

UAS operated without an airworthiness certificate, in the restricted environment and 

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

aircraft (fixed wing or rotorcraft) operating with an airworthiness certificate without the 

restrictions and conditions proposed. 
The sUAS to be operated hereunder is less than 55 lbs. fully loaded, is by definition 

unmanned and carries neither a pilot nor passenger, carries no explosive materials or 

flammable liquid fuels, and operates exclusively within a limited flight area. Unlike other 

civil aircraft, operations under this exemption will be tightly controlled and monitored by 

the PIC/Operator and will also remain within the requirements of, and in compliance 

with, local public safety requirements. These safety enhancements, which already apply 

to civil aircraft provide a greater degree of safety to the public and property owners than 

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

Part 21, Subpart H. Lastly, application of these same criteria demonstrates that there is no 

credible threat to national security posed by the UAS due to its size, speed of operation, 

location of operation, lack of explosive materials or flammable liquid fuels, and inability 

to carry a substantial external load. 

14 C.F.R. § 45.23 (b). Marking of the Aircraft 

The regulation requires; When marks include only the Roman capital letter "N" and the 

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

experimental or provisionally certificated aircraft, the operator must also display on that 

aircraft near each entrance to the cabin, cockpit, or pilot station, in letters not less than 2 

inches nor more than 6 inches high, the words "limited," "restricted," "light-sport," 

"experimental," or "provisional," as applicable. Even though the sUAS will have no 

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

to the cabin, cockpit or pilot station on which the word "Experimental" can be placed. 

Given the size of the sUAS, two-inch lettering will be impossible. The word 

"Experimental" will be placed on the fuselage in compliance with §45.29 (f). The 

equivalent level of safety will be provided by having the sUAS marked on its fuselage as 

required by §45.29 (f) where the pilot, observer and others working with the sUAS will 

see the identification of the sUAS as "Experimental." The FAA has issued the following 

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

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

Command. 

Sections 61.113 (a) & (b) limit private pilots to non-commercial operations. Because the 

sUAS is unmanned and 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 FAA ground school rather than a commercial pilot's license to 

operate this small sUAS Unlike a conventional aircraft that carries the pilot and 

passengers, the sUAS is remotely controlled with no living thing on board. The area of 

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

advance. The level of safety provided by the requirements included herein exceed that 

provided by a single individual holding a commercial pilot's certificate operating a 

conventional aircraft. The risks associated with the operation of the sUAS are so 

diminished from the level of risk associated with commercial operations contemplated by 

Part 61 when drafted, that allowing operations of the sUAS as requested with a private 

pilot as the PIC exceeds the present level of safety achieved by 14 C.F.R. §61.113 (a) & 

(b). 
14 C.F.R. §91.7(a): Civil aircraft airworthiness. 

The regulation requires that no person may operate a civil aircraft unless it is in 

airworthy condition. As there will be no airworthiness certificate issued for the aircraft, 

should this exemption be granted, no FAA regulatory standard will exist for determining 

airworthiness. Given the size of the aircraft and the requirements contained herein for the 

use of safety check lists prior to each flight, an equivalent level of safety will be 

provided. 

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

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 its size and configuration has 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. 

The equivalent level of safety will be maintained by keeping the sUAS operation 

manual and appropriate checklists at the ground control point where the pilot flying the 

sUAS will have immediate 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 

This regulation requires each pilot in command to take certain actions before flight to 

insure the safety of flight. As FAA approved rotorcraft flight manuals will not be 

provided for the aircraft an exemption will be needed. An equivalent level of safety will 

be provided as set forth hereinabove. The PIC will take all actions including reviewing 

weather, flight battery requirements, landing and takeoff distances and aircraft 

performance data before initiation of flight using appropriate checklists. 

14 C.F.R. §91.109: Flight instruction: 

Section 91.103 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 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 Nos.5778K & 

9862A.

The equivalent level of safety provided by the fact that neither a pilot nor passengers will 

be carried in the aircraft and by the size and speed of the aircraft. 

14 C.F.R. §91.119: Minimum safe altitudes 

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 200 AGL underneath navigable airspace and in 

class E and G airspace maintaining safe separation from actual 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 location where it is operated. No flight will be taken without the permission 

of the property owner or local officials. Because of the advance notice to the property 

owner and participants in the filming activity, attempts will be made to contact all 

affected individuals regarding the planned flight operations. 

Compared to flight operations with aircraft or rotorcraft weighting far more than the 

maximum 551bs. proposed herein, and the lack of flammable fuel, any risk associated 

with these operations is far less than those presently presented with conventional aircraft. 

In addition, the low-altitude operations of the sUAS will ensure separation between these 

sUAS operations and the operations of conventional aircraft that must comply with 

Section 91.119. 

14 C.F.R. §91.121 Altimeter Settings 

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 may not have a 

barometric altimeter, but instead a GPS altitude read out, an exemption may be needed. 

An equivalent level of safety will be achieved by the operator, pursuant to the Manual 

and Safety Check list, confirming the altitude of the launch site shown on the GPS 

altitude indicator before flight. 

The requirements are that altitude information be provided to the sUAS pilot via digitally 

encoded telemetric data feed, which downlinks from the aircraft to a ground-based onscreen display. This altitude information will be generated by equipment installed on 

board the aircraft, using GPS triangulation, or digitally encoded barometric altimeter, or 

radio altimeter, or any combination thereof. Prior to each flight, a zero altitude initiation 

point will be established and confirmed for accuracy by the pilot.
14 C.F.R. § 91.151 (a): Fuel Requirements for Flight in VFR Conditions 

Section 91.151 (a) prohibits an individual from beginning "a flight in an airplane under 

VFR conditions unless (considering wind and forecast weather conditions) there is 

enough fuel to fly to the first point of intended landing, and, assuming normal cruising 

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

after that for at least 45 minutes." 

The battery powering the sUAS provides approximately between 40 minutes of 

powered flight. To meet the 30 minute reserve requirement in 14 CFR §91.151, sUAV

flights would be limited to approximately 10 minutes in length. Given the limitations on 

the sUAS proposed flight area and the location of its proposed operations within 

predetermined area, a longer time frame for flight in daylight or night VFR conditions is 

reasonable. 

Petitioner believes that an exemption from 14 CFR §91.151 (a) falls within the scope of 

prior exemptions. See Exemption 10673 (allowing Lockheed Martin Corporation to 

operate without compliance with FAR 91.151 (a)). Operating the sUAS in controlled area 

where only people and property owners or official representatives who have signed 

waivers will be allowed, with less than 30 minutes of flight operation time, does not give 

rise to the type of risks that Section 91.151 (a) was intended to alleviate particularly 

given the size and speed of the sUAS. Additionally, limiting sUAS flights to 20 minutes 

would greatly reduce the utility for which the exemption will be granted. 

Petitioner believes that an equivalent level of safety can be achieved by limiting flights 

to 30 minutes or no less than 25% of battery power, whichever happens first. This 

restriction would be more than adequate to return the sUAS to its planned landing zone 

from anywhere within its limited operating area. 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 

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 

passengers or crew. 

The sUAS fully loaded weighs no more than 55 lbs and typically less than 20 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 pilot flying the sUAS 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 Nos. 9565, 

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

14 C.F.R. §91.405 (a); 407 (a) (1); 409 (a) (2); 417(a) & (b): Maintenance Inspections 

These regulations require that an aircraft operator or owner "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 ... ," and others shall inspect or maintain the aircraft 

in compliance with Part 43. 

Given that these section and Part 43 apply only to aircraft with an airworthiness 

certificate, and the requirements of pre-flight inspection required herein, these sections 

will not apply to the applicant. Routine and pre-flight maintenance will be accomplished 

by the operator. An equivalent level of safety will be achieved because these sUAS are 

very limited in size and will carry a very small payload and operate only in restricted 

areas for limited periods of time. If mechanical issues arise the sUAS can land 

immediately and given its small size poses very little risk to persona or property. The 

operator will ensure that the sUAS is in working order prior to initiating flight, perform 

required maintenance, and keep a log of any maintenance performed. Moreover, the 

operator is the person most familiar with the aircraft and best suited to maintain the 

aircraft in an airworthy condition to provide the equivalent level of safety. 

7. Publication Summary 

Pursuant to 14 C.F.R. Part 11, the following summary is provided for publication in the 

Federal Register, should it be determined that publication is needed: 

Petitioner seeks an exemption from the following rules: 14 C.F.R. §21, subpart H; 14 

C.F.R 45.23(b);14 C.F.R. §§ 61.113( a) & (b);91.7 (a); 91.9 (b) (2);91.103(b);91.109; 

91.119; 91.121; 91.151(a);91.203(a) and (b); 91.405 (a); 91.407 (a) (1); 91.409 (a) (2); 

91.409 (a) (2) and 91.417 (a) & (b) to operate commercially a sUAV vehicle (551bs or 

less) for Aerial Photography & Motion Picture television Operations. 

Approval of exemptions allowing commercial operations of sUAS for Aerial 

Photography & Motion Picture television Operations for the following; Business 

Operations: over land, water-ways, and oceans; operation over/in non restricted National 

Parks, National Forests, flight in non-navigable airspace, using non-intrusive recording 

devices, operation in otherwise unrestricted US States/Territories will enhance safety by 

reducing risk. 

Conventional film operations, using jet or piston power aircraft, operate at extremely low 

altitudes, just feet from the subject being filmed, and in extreme proximity to people and 
structures; and present the risks associated with vehicles that weigh in the neighborhood 

of 4,0001bs, carrying large amounts of jet A or other fuel. In addition such actual 

certificated aircraft must fly to and from the film location. In contrast, a sUAS weighing 

fewer than 55 lbs., and powered by batteries rather than fuel, eliminates virtually all of 

that risk. The sUAS is driven/carried to the film set, not flown. The sUAS will carry no 

passengers or crew and, therefore, will not expose any crew to the risks associated with 

manned aircraft flights. 

The operation of sUAS, weighing less than 55 lbs., conducted in the strict conditions 

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

the 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 line of sight, relatively sterile 

environment and are, as a result, far safer than conventional operations conducted with 

actual aircraft/helicopters operating in close proximity to the ground and people. 

8. Privacy 

All business/commercial flights which occur over private or controlled access property 

will be with the property owner's prior consent and knowledge. Filming will be of people 

who have also consented to being filmed or otherwise have agreed to be in the area where 

filming will take place. Petitioner will not infringe on any individual or landowner 

privacy rights. 

Limited nighttime operations may be conducted. nighttime as defined FAR's in section 

is as follows 1.1. "Night means the time between the end of evening civil twilight and the 

beginning of morning civil twilight, as published in the American Air Almanac, 

converted to local time.

" Night operations may be conducted by the sUAS following the guidelines above and 

provided such operations have sufficient lighting so that Petitioner/Operator maintains 

visual line of sight. Allowing sUAS this exemption will provide a far safer nighttime 

filming alternative to the current full size aircraft operations. 

9. Conclusion 

The FAA's purported "ban" on business/commercial Model Aircraft sUAS operations 

has actually had the current effect of causing American skies to be less safe. There are 

many actual certificated pilots who are exceptionally qualified to fly model aircraft sUAS 

with their model aircraft sUAS experience, private, commercial or ATP pilot training, 

licenses and instructor ratings. However, these experienced operators and licensed pilots 

familiar with the FARs, airspace and safe operating procedures are currently reluctant to 

commercially operate model aircraft sUAS or be involved, for fear of the FAA seeking 

an enforcement action against them or their actual pilot's licenses. 

Presently, during the pendency of these issues in the Pirker case, it defies safety or 

regulatory logic that according to the FAA's current alleged "ban" on business operations 

of sUAS, your average enthusiastic 12 year old, who's well meaning Father bought him a 

quadcopter s sUAS equipped with a camera, can operate his sUAS wherever he wants 

and take whatever recreational video/pictures subject only to the suggestions of FAA AC 
91-57 and yet an FAA certificated private/commerciai/ATP pilot cannot be paid to use a 

far higher quality and equipped sUAS to take an aerial photo or aerially inspect a farmers 

field, despite the significant improvement in safety over non-pilots operating sUAS

recreationally and real aircraft used for aerial photography. 

Satisfaction of the criteria provided in Section 333 of the FMRA of 2012, and requiring 

the sUAS PIC to have or obtain medical certificate and a actual pilots license and 

considering the small size, weight, speed, operating capabilities, limited operations in 

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

national security-all of which provide more than adequate justification for the grant of the 

requested exemptions allowing business /commercial operation of applicant's sUAS for 

aerial photography/ motion picture/television productions as requested herein. 

Ex. 1. 

UdroneAir Checklists Preflight Checklists 

Inspect Vehicle 

1. Check props 

2. Check screws 

3. Check Radio 

4. Check body/arms for cracks 

5. Prepare log book 

6. Review mission/Check review weather 

7. Check/test batteries record voltages 

8. Prepare nav/gps system 

9. Radio RX/TX distance test/Check timers 

10. Satellite localization/lock 

Narrative Descriptions.

Inspect the vehicle for previous damage like cracked chassis, loose props, motors and 

wires, this will ensure the safe operation of the vehicle and not a catastrophic failure of 

parts. 

Tighten all screws and record which ones are becoming loose over time. This will 

indicate problems with the vehicle structure and you should use more CA or thread 

locking liquid to keep this problem to a minimal. If you are repeatedly tightening the 

screws in the same spot then there is a problem with the screw hole and should be tapped 

or corrected. 

Prepare a logbook, this will ensure that you are recording the proper flight times and will 

indicate battery health, saving you from a failure and possible loss of vehicle. Pull out the 
document you use for logging your flight fill out the information that is most important: 

date, time, and mission information. 

Weather affects the performance of a vehicle and should be calculated to ensure proper 

weights given to your flight and battery time totals. Weather information to include as 

follows: Temperature, wind speed, maximum gusts, ambient temperature, humidity, dew 

point, barometric pressure, and any solar information that can effect your GPS. Review 

your mission so that you know exactly what you plan to do and what data you will gather. 

Check and test your batteries so that you have sufficient power for your mission. If you 

followed this checklist your batteries should have been charged the last time you put your 

vehicle away. Turn on the navigation system if applicable and verify the appropriate 

settings to localize the satellite signal. Check for solar flare information and gps outages 

in your area connected to your mission. 

II. Before Flight 

1. Turn on transmitter; Check set flight mode 

2. Set throttle down 

3. Clear flight area 

4. Connect battery on the vehicle 

5. Start motors 

6. Verify indicator lights for proper indications/GPS locks 

7. Throttle up slowly 

8. Maintain visual separation from all obstructions 

Narrative Descriptions:

You should always be near your transmitter so that in the case of a failure you can control 

the vehicle to the best of your abilities and get the vehicle safely to the ground. First turn 

the transmitter on, with the throttle turned all the way down. 

Next walk over to the vehicle that you plan to fly clear area and connect the battery. You 

should connect the battery in a way that does not disturb the vehicle from sitting on the 

ground, when you plug the vehicle up it is calibrating the flight system and powering up 

safely. 

When the lights give proper indications it is safe to either pick up the vehicle safely and 

move it or walk away from it with your controller in your hand. To begin your flight 

move the sticks up slowly until the vehicle leaves the ground maintain visual separations 

from people, buildings, obstructions, other UAS/aircraft. 
Ill. Post Flight/After Landing 

1. Unplug battery on vehicle while near the controller 

2. After battery is unplugged turn off the controller 

3. Fill out log books 

Narrative Descriptions: 

Once the vehicle has returned to the ground, walk over with your controller and 

disconnect the wire to the vehicle battery, this will essentially kill the power and render 

the vehicle in the safe to transport mode. 

Next you can power the controller off to save the battery life. Return the vehicle to a safe 

place and then locate your logbooks and recover your data. 

IV. Debrief 

1. Fill out logs 

2. Complete calculations for batteries and flight times 

3. Put away gear, vehicle and log books

Our Aircraft: Cheerson CX20 with autopathfinder GPS