u. s. Department of 

Transportation Docket Management 

system 1200 New Jersey Ave., SE 

washington, DC 20590 

SatStellar, LLC 

a minority company ... 

April 17, 2015 

Re: Exemption Request section 333 of the FAA Reform Act and Part 

11 of the Federal Aviation Regulations from 14 CFR 61 .113 (a) & 

(b); 91.103(b); 91.119; 91.121; 91.151(a); 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 (the Reform Act) and 14 C. F.R. Part 11, satstellar LLC 

hereby applies for an exemption from the listed Federal Aviation 

Regulations ("FARs") to allow commercial operation of its small 

unmanned Aircraft systems ("sUAS") for aerial imaging for safety 

and monitoring of secured and controlled environment construction 

sites, 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 . 

Satstellar will perform many different airborne solutions 

such as: mapping data, sensing, construction, photography, real 

estate, agricultural, environmental, inspections, and FAA 

certifications. These techniques and procedures and often require 

our employees to be put in situations that require Satstellar to 

accept risk. we have found that by using a small unmanned 

aircraft system "sUAS" with a high resolution camera mounted on 

it, often times we can accomplish the same inspection and 

alleviate the need to put our employees and public in danger. 

www.satstellar.com 
SatStellar, LLC 

a minority ~::ompany ... 

satstellar shares congress's goal of getting sUAS flying 

commercially in the united states safely and soon. In the FAA 

Modernization and Reform Act of 2012, congress directed the FAA 

"to safely accelerate the integration of civil unmanned aircraft 

systems into the national airspace system" and, under Section 

333 of that law, gave the FAA power to grant innovators 

"expedited operational authorization" to do so. By this 

petition, satstellar is seeking authorization to conduct sUAS 

commercial operations. 

Further, granting this request will do nothing more than 

allow satstellar to do what thousands of hobbyists and 

manufacturers of model aircraft do every day, except we will 

abide by much stronger safety measures . under supervision of a 

certified pilot we would provide a safer level of operation that 

is superior to current regulations. This invaluable experience 

applied to Satstellar UAS program equates to safe sUAS use on 

our projects with no confliction with manned aircraft. 

Information supporting this Petition as Specified in 14 C.F.R. §11.81 

A. Mailing address and other contact information: 

satstellar, LLC 

109 Janwall St. 

Annapolis, Maryland 21403 

Christian Nieves 

301-785-2260 

contact@satstellar . com 

www.satstellar.com 
SatStellar, LLC 

a minority company ... 

B. The soecific section or sections of 14 C.F.R from which satstellar 

seeks exemption. 

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. 91.203 (a) & (b) 14 C.F.R. 91 .405 

(a) 14 C. F.R. 407 (a) (1) 14 C.F.R. 409 (a) 

(2) 14 C.F.R. 417 (a) & (b) 

I. STATUTORY AUTHORITY FOR EXEMPTIONS 

The Federal Aviation Act expressly grants the FAA authority to 

issue exemptions. This statutory authority includes exempting 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 u.s.c. §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 

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 the visual line of sight of the 

operator 

• whether the sUAS operates outside of highly populated areas and 

away from close proximity to airports 

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SatStellar, LLC 

a minority company ... 

Reform Act §333(a). If the secretary determines that a sUAS "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). 

satstellar sUAS, weighing less than 55 lbs. includind payload, 

and will operate under normal conditions at a speed of no more than 50 

knots. The sUAS will operate only in the Pilot's visual line of sight 

at all times and will operate only within the preplanned area . such 

operations will insure that the sUAS will ''not create a hazard to 

users of the national airspace system or the public." Reform Act 

section 333 (b). 

Given the small size of the sUAS involved and the restricted 

and preplanned area within which they will operate, our application 

falls squarely within the 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. Also due to the small size of the sUAS and the low 

altitudes and restricted areas in which the sUAS will operate, 

approval of the application presents no national security issue. 

Given the clear direction in section 333 of the Reform Act, 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, the grant of the requested exemptions is in the public 

interest . Accordingly , Satstellar respectfully requests that the FAA 

grant the requested exemption without delay. 

II. PUBLIC INTEREST 

This exemption application is expressly submitted to fulfill 

congress' goal 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 

NAS before completion of the rulemaking required under Section 332 

of the Reform Act. By granting an exemption the FAA will fulfill 

congress's intent of allowing UAS to operate with significant safety 

www.satstellar.com 
SatStellar, LLC 

a minority company ... 

precautions 1 n low risk envi r.onments. 

The use of sUAS on a various site conditions can significantly 

reduce the risk to workers of falls wh i le inspecting, surveying, or 

monitoring site progress. sUAS can inspect, photograph, and collect 

data on hard to get to areas that otherwise would require worker 

inspection. Falls are a leading source of workplace fatality and 

ln]ury on construction sitesl , and reducing falls through sUAS use 

for site imaging could save workers lives. 

Additionally, sUAS could replace the use of helicopters and 

small aircraft to perform our intended tasks. The sUAS we propose to 

fly in this application are under fifty-five pounds, and carry no 

combustible material on board, as opposed to the much larger 

conventionally powered small aircraft. shifting to sUAS from 

helicopters and airplanes presents a marked safety increase for our 

workers and the public. 

Lastly, sUAS reduce the environmental impact by dramatically 

decreasing the energy used for aerial imaging and data collection. 

our sUAS use rechargeable lithium ion batteries, as opposed to 

fossil fuels burned in operation of small aircraft t hat are many 

hundreds of times heavier. 

III. EQUIVALENT LEVEL OF SAFETY 

satstellar sUAS operations will provide a level of safety 

that far exceeds the level of safety required by the FAA for 

hobbyists and manufacturers of model aircraft. The following 

operating procedures will apply during the sUAS inspection 

operations under this exemption request. 

1. Satstellar operations will be conducted: 

i. Within the visual line of sight of the Pilot in 

command (PIC) and one or more visual Observers 

(VO). 

ii. at less than 400 feet AGL 

ii i .Within class G airs pace . 

2 . Satstellar inspection operations will be conducted in a 

1 "Commonly Used Statistics", Occupational Safety & Health Administration. Available at: 

https://www.osha.gov/oshstats/commonstats.html 

www.satstellar.com 
SatStellar, LLC 

a minority company ... 

confined area over isolated private property located at 

least 5 miles away from any airport, heliport, seaplane 

base, spaceport or other location with aviation 

activities, and any military or u.s. government 

installations or airfields. If we are within the 5 mile 

radius of any of the above installations Satstellar will 

seek written approval from that installation's owner 

before sUAS operations take place. If said installation 

owner requires stricter guidelines for operation then 

Satstellar will comply. 

3 . All sUAS operations will remain within the lateral and 

vertical boundaries of the operating area, taking into 

account all factors, including wind , gross weight and 

glide distances, that may affect the capability of the 

sUAS to remain within the airspace boundary; moreover, 

the ceiling height will be no more than 400 feet AGL. 

4. Satstellar sUAS inspection operations under this 

exemption will be conducted under the supervision 

designated PIC who ultimately has final responsibility 

for the operation i n accordance with 14 C.F.R. 91.3 and 

either holds a current FAA private pilot certificated, a 

higher FAA pilot certification, or a FAA- recognized 

equivalent or has completed FAA private pilot ground 

instruction and passed the FAA private pilot written 

exam. 

s. PIC will maintain the sUAS system in a condition for 

safe operation, and conduct a pre-flight inspection 

prior to each flight so as to ensure that the sUAS, 

control station, data link equipment, camera, and 

support equipment are in a condition for safe operation 

and in a configuration appropriate for the purpose of 

the intended flight. 

6 . The PIC and vo will maintain two-way communications with 

each other during all operations ; if unable to maintain 

two-way communications, or if any condition occurs that 

may otherwise cause the operation to be unsafe, the 

operator will immediately conclude the operation. 

7. Each sUAS that 

exemption wi 11 

www.satstellar.com 

Satstellar will employ under this 

safely return automatically to a home 
SatStellar, LLC 

a minority company ... 

location designated by the PIC if the communications link 

is lost. 

8 . The aircraft documentation required by 14 C.F.R. §§ 91.9 

and 91.203(b), as applicable, will be available to the 

PIC refer red to above at any time Satste ll a r sUAS are 

operating. 

satstellar will effectively operate under our own 

standard operating procedures that will provide additional 

safeguards that go far beyond the level of safety for public 

model airplane fields. 

IV. DESCRIPTION OF SPECIFIC REGULATIONS 

14 CFR 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 will not carry a pilot or passengers, 

the proposed operations can achieve the equivalent level of safety 

of current operations by requiring the Pilot operating the aircraft 

to have completed a sUAS flight training course of 100 hours before 

flying a sUAS. unlike a conventional aircraft that carries the pilot 

and passengers, the sUAS is remotely controlled with no living thing 

or cargo on board. The sUAS are also operated by an autopilot, which 

greatly reduces the danger of human error. The area of operation 1s 

controlled and restricted areas, and all flights are planned and 

coordinated in advance. 

The sUAS to be operated hereunder is less than 55 lbs. fully 

loaded, carries neither a pilot nor passenger, carries no explosive 

materials or flammable liquid fuels, and operates exclusively within 

a secured area as set out in the operation plan. Like other civil 

aircraft, operations under this exemption will be tightly controlled 

and monitored by the operator, and in compliance with local public 

safety requirements, to provide security for the area of operation. 

The FAA will have advance notice of all operations. 

The risks associated with the operation of the sUAS are 

therefore diminished from the level of risk associated with 

commercial operations contemplated by Part 61 when drafted, and 

allowing operations of the sUAS as requested with a Pilot who has the 

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SatStellar, LLC 

a minority company ... 

level of safety contemplated by 14 C.F.R. §61.113 (a) & (b). 

14 C.F.R. 91.103: Preflight Action 

This regulation requires each pilot in command take certain 

actions before flight to ensure the safety of flight. An exemption is 

needed from this requirement as the Pilot will take separate 

preflight actions, including checking for weather conditions, 

checking flight battery requirements, checking takeoff and landing 

distances, and all other actions in the Preflight checklist in the 

Manual. These actions will provide an equivalent level of safety. 

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 sUAS to be operated at less than 

the minimums prescribed, provided the person operating complies with 

any route or altitudes prescribed by the FAA. The sUAS will never 

operate at altitude higher than 400 AGL and will be in a restricted 

area with security perimeter, where buildings and people will not be 

exposed to operations without their pre- obtained consent. 

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 any onsite personnel, all affected individuals will be aware of the 

planned flight operations. unlike flight operations with aircraft or 

rotorcraft weighing far more than the maximum 55 lbs. proposed herein, 

our sUAS will not carry flammable fuel . In addition, the low-altitude 

operations of the sUAS will ensure separation between 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 confirming the altitude of the launch site 

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shown on the GPS altitude indicator before flight. 

14 CFR 91.151 (a): Fuel requirements for flight in VFR conditions 

section 91.151 (a) outlines fuel requirements for beginning a 

flight in VFR conditions. our sUAS is limited to operations in 

sterile and controlled environments , and has a limited range and 

flight time which require an exemption from 14 CFR 91.151(a). 

The battery powering the sUAS provides approximately 35 minutes 

of powered flight. To meet the 30 minute reserve requirement in 14 

CFR §91.151, sUAS flights would be limited to approximately 5 minutes 

in length. Given the limitations on the sUAS's proposed flight area 

and the location of its proposed operations within a predetermined 

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

conditions is reasonable. 

Satstellar 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 small sUAS, in a tightly 

controlled area where only people and property owners or official 

representatives who have signed waivers will be allowed, with less 

than 30 minutes of reserve fuel, does not engender the type of risks 

that section 91.151(a) was intended to alleviate given the size and 

speed of the small UAS. Additionally, limiting sUAS flights to 10 

minutes would greatly reduce the utility for which the exemption will 

be granted. 

An equivalent level of safety can be achieved by limiting 

flights to 30 minutes, or enough battery reserve to ensure that the 

sUAS lands at the ground station with at least 20% of battery power 

(as determined by the onboard monitoring system and the Pilot), 

whichever happens first. This restriction would be more than adequate 

to return the sUAS to its planned landing zone from anywhere in its 

limited operating area. 

similar exemptions have been granted to other operations , 

including Exemptions 2689F, 5745, 10673, and 10808. 

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SatStellar, LLC 

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14 CFR 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 sections and Part 43 apply only to 

aircraft with an airworthiness certificate, these sections will 

not apply to Satstellar. Maintenance will be accomplished by the 

operator pursuant to the flight manual and operating handbook 

from the manufactural. An equivalent level of safety will be 

achieved because these small sUAS are very limited in size and 

will carry a small payload and operate only in restricted areas 

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

can land immediately and will be operating from no hi9her than 

400 feet AGL. The Pilot will ensure that the sUAS is 1n working 

order prior to initiating flight, perform required maintenance, 

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

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. 

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: 

Applicant 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 small unmanned vehicle (SSlbs or less). 

Approval of exemptions allowing commercial operations of sUAS in the 

construction industry enhances safety while reducing risk. Manned 

aircraft monitoring and surveying creates a greater risk because the 

craft are much larger, have combustible fuel, and carry an onboard 

human pilot. In contrast, a sUAS weighing fewer than 55 lbs. and 

powered by batteries eliminates virtually all of that risk given the 

reduced mass and lack of combustible fuel carried on board. The sUAS 

will carry no passengers or crew and, therefore, will not expose 

them to the risks associated with manned aircraft flights. 

www.satstellar.com 
SatStellar, LLC 

a minority company ... 

The operation of small sUAS, weighing less than 55 lbs., 

conducted in the strict conditions outlined above, will provide an 

equivalent level of safety supporting the grant of the exemptions 

requested herein, including exempting the applicant from the 

requirements of Part 21 and allowing commercial operations. These 

lightweight aircraft operate at slow speeds, close to the ground, 

and in a sterile environment and, as a result , are far safer than 

conventional operations conducted with turbine helicopters operating 

in close proximi ty to the ground and people. 

Privacy 

All flights will occur over private or controlled access 

property with the property owner's prior consent and knowledge . Images taken will be of individuals who have also consented to 

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

aerial photography will take place . 

Satisfaction of the criteria provided in Section 333 of the 

Reform Act of 2012--size, weight, speed, operating capabilities, 

proximity to airports and populated areas and operation within 

visual line of sight and national security - provide more than 

adequate justification for the grant of the requested exemptions 

allowing commercial operation of applicant's sUAS. 

sincerely, 

Joseph Agenbroad Satstellar, LLC 

109 Janwall St. 

Annapolis, MD 21403 

410-353-1684 

contact@satstellar. com 

www.satstellar.com