May 11, 2015

Exemption No. 11546

Regulatory Docket No. FAA–2015–0422

Mr. Ben Van Lare

Raecon Industries Ltd.

1685 H Street #318

Blaine, WA 98230

Dear Mr. Van Lare:

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 February 16, 2015, you petitioned the Federal Aviation Administration (FAA) 

on behalf of Raecon Industries, Ltd. (hereinafter petitioner or operator) for an exemption. The 

exemption would allow the petitioner to operate an unmanned aircraft system (UAS) to 

conduct aerial inspections of industrial assets and power structures.

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.

Airworthiness Certification

The UAS proposed by the petitioner is a Microdrone MD4-1000.

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 
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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, Raecon Industries, Ltd. 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.

Conditions and Limitations

In this grant of exemption, Raecon Industries, Ltd. is hereafter referred to as the operator.
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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 Microdrone MD4-

1000 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 

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 
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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.

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 
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(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 five 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.

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.
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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.

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.
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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 May 31, 2017, unless sooner superseded or rescinded.

Sincerely,

/s/

John S. Duncan

Director, Flight Standards Service
FAA SECTION 333 

Prepared for: Federal Aviation Association 

Prepared by: Reacon Industries USA 

February 16, 2015

Page 1 of 30
TABLE OF CONTENTS 

Section 1. 

1.1 FAA Section 333 Petition 

Section 2. 

Section 2.1 Policies and Procedures 

Section 2.2 Random Site Evaluation 

Section 2.3 Operations Tailboard 

Section 2.4 UAV Flight Time Sheet

Section 2.5 Pre-Flight & Takeoff Safety

Section 3. 

3.1 Microdrone MD4-1000 UAS Operator Manuel

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RAECON INDUSTRIES LTD.
Section 1 

Federal Aviation Association 

 Section 333 Petition 

Prepared for: Federal Aviation Association 

Prepared by: Reacon Industries USA

Page 3 of 30

RAECON INDUSTRIES LTD.
Dear Sir or Madam, 

We, Raecon Industries, are writing pursuant to the FAA Modernization and Reform Act of 2012 and 

the procedures contained with 14 C.F.R. 11, to request, that we, Raecon Industries, a company and 

operator of a small unmanned aerial system, be exempted from the Federal Avaiations Regulations 

(FARs) that we have listed below. So that we, Raecon Industries, may operate our small quadcopter unmanned aerial system (UAS) commercially in airspace that is regulated by the Federal 

Aviation Association (FAA). 

We, Raecon Industries Ltd., are a US subsidiary company of Canadian based Raecon Industries 

located in Vancouver Canada. We specialize in UAS photography and video inspections. We have 

worked with Transport Canada in filing commercial Special Flight Operation Certificates (SFOC) for 

the last 13 months, since January 2014. We have been awarded a blanket SFOC with Transport 

Canada, by showing our practices regarding public safety, manned aircraft safety, and conducting 

safe commercial flights within Canadian Airspace. 

We, Raecon Industries, request the permission to conduct safe aerial inspections of industrial 

assets and power structures with our quad-copter Microdrone MD4-1000. These operations will be 

conducted in areas that are typically rural, with low vehicle and human traffic, and below an altitude 

of 300ft, well within the 400ft permissible ceiling set by the FAA. We have created and implemented 

safety protocols and controls to avoid public and manned aircraft hazards. We have created 

preflight site assessments, onsite tailboard meetings, safety and environmental safety plans, and 

Pilot in Command (PIC) and ground observer training. 

Granting our, Raecon Industries request, accords with the Secretary of Transportation’s 

responsibilities and authority to integrate UAS's into the national airspace system (NAS), and to 

“...establish requirements for the safe operation of such aircraft systems [UAS's] in the national 

airspace system” under Section 333(c) of the Reform Act specific to the use of UAS's for real 

estate/Realtor purposes. We, Raecon Industries, will perform our operations in compliance with the 

protocols described herein or as otherwise established by the FAA. 

We, Raecon Industries, respectfully request the permit of an exemption to allow our company, 

Raecon Industries USA, to operate our Microdrone MD4-1000 to help public utility companies and 

industries increase safety and affordability for public and private asset inspections. 

Contact Information: 

Page 4 of 30

RAECON INDUSTRIES LTD.
Raecon Industries 

CC: Ben Van Lare 

Raecon Industries Ltd.

1685 H Street #318

Blaine, Washington, USA, 98230

Office: (360)325.5723 

Email: ben@raeconindustries.com

The Specific Sections of Title 14 of the Code of Federal Regulations From Which Raecon 

Industries Requests Exemptions are: 

14 CFR 21;

14 C.F.R. 91, et seq.;

14 CFR 407 (a) (1);

14 CFR 409 (a) (2); and, 14 CFR 417 (a) & (b). 

The Extent of relief Raecon Industries seek and the Reason we seek such relief: 

We, Raecon Industries, submit this application seeking relief from current applicable Federal 

Aviation Regulations (FARs) that restrict us, Raecon Industries, from utilizing Unmanned Aerial 

System technology within the national airspace system. The Reform Act in Section 332 provides 

for such integration of civil unmanned aircraft systems into the national airspace system as it is 

in the public’s interest to do so. Our, Raecon Industries, small UAS meets the definition as 

defined in Section 331 and therefore the integration of our light weight UAS prior to the time in 

which the Reform Act requires the FAA to define and promote rules that will govern such 

unmanned aerial crafts. With our exemption, we will be able to work with the Federal Aviation 

Association to introduce our UAS safely into the national airspace. We operate our UAS within 

line of sight and under 400 feet elevation away from populated areas. When working in areas 

where people or vehicles may be present, we have set guidelines in place that are implemented 

prior to any performance of operation (see section 2). Along with this we will be operating 

outside of air traffic controlled (ATC) areas, typically 5-8 miles in diameter from airports. Our UAS

is equipped with GPS and is outfitted with auto return to home safety technology.

We at Raecon Industries, consider safety as the most important part of any flight operation. 

Safety for manned aircraft, public safety, and our UAS operations teams are held at the utmost 

precedent. We have invested in one of the most trusted UAS suppliers worldwide, Microdrone, 

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RAECON INDUSTRIES LTD.
because of the safety aspects their units are equipped with. Prior to each flight operation, 

preflight safety assessments are processed (see section 2). They are signed off by our Pilot-InCommand, Operations Manager, and Ground Observer. We, Raecon Industries operate our 

UAS safely insuring that we will not “create a hazard to users of the national airspace system or 

the public.” 112 P.L 95 Section 333 (b). Given that our UAS falls within the weight and size 

regulations and our safe and successful commercial UAS operations in Canada, we believe our 

UAS does not pose a threat to the general public, national security, or national airspace. 

How Raecon Industries Request Will Benefit the Public As A Whole: 

Aerial asset inspections using fixed wing aircraft and helicopters have been used to assess 

unsafe and difficult to reach areas for many years. The use of UAS technology for these types of 

inspections bring a new level of increased safety to personnel and industries involved in these 

inspections. The high cost of using manned aircraft for power line inspections and tower 

inspections can be significantly reduced by using UAS technology. Manned aircraft have 

liabilities that pose a threat to the public, pilots, and crew involved in operations. The use of 

combustible fuel and the size of aircraft cause significant liabilities and if crashed can cause 

severe environmental and public damage and could result in the loss in life. Our UAS does not 

pose such a threat since it is battery operated with batteries secured in protective cases within 

the UAS. 

With these increased liabilities and costs of traditional inspections, industries often cannot afford 

much needed inspections and neglect to inspect viable assets on a regular basis. This neglect 

can have major consequences on the public. For example, overgrowth or dead vegetation along 

power lines can lead to power outages and/or fires. This poses a major risk to the public that 

could be affected in these regions. Utilizing our, Raecon Industries UAS, inspections can be 

completed in a safer and more cost effective way, thus, leading industries to not neglect much 

needed asset inspections and have the ability to keep their assets safe and performing optimally. 

Reasons Why Raecon Industries Exemption Will Not Adversely Affect Safety or How the 

Exemption Will Provide A Level of Safety at Least Equal to the Existing Rule: 

Raecon Industries exemption will not adversely affect the safety of the public or of manned 

aircraft. Quite the contrary, we, Raecon Industries are dedicated to ensuring all it's procedures 

and operations have safety as the highest priority. The most important details before we take off 

are to ensure public safety, air safety, environmental safety, and the safety of our Operations 

team. With these procedures in place we can judge what is safe/not safe/or safe with some risks 

when evaluating sites that are known and random. With our operators trained in manned aircraft 

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RAECON INDUSTRIES LTD.
and unmanned aircraft operations, we are insuring that our intention is to reduce risk to airspace 

users as well as to people and property on the ground. By granting us, Raecon Industries, an 

exemption, we will be allowed to work with the FAA to monitor and safely deploy unmanned 

aerial systems into the national airspace and the public. Below are a few key safety procedures 

that insures our UAS will not adversely affect safety: 

• Our UAS will not exceed 300 feet in altitude during operation and stay within 1000 feet of 

the Pilot and Ground Observer. 

• Our UAS operates with redundant batteries, thus insuring that if one battery falters the 

other one is there to ensure safe return to home. 

• Our UAS has the ability to operate for 88 minutes, however we cap all our operations at 

25 minutes to ensure battery power is sufficient. 

• If GPS communication is lost, our UAS has an automatic return to home function 

programmed for each flight. 

• All flights are operated with a Pilot-In-Command and Ground Observer, ensuring safety of 

manned aircraft and the public. 

• Before each flight operation, we carry out extensive pre-flight inspections of the 

operations area. 

Our, Raecon Industries, safety policies and procedures provide a level of safety equal to or 

exceeding existing rules and regulations. Today most visual inspection of power poles and hard 

to reach assets are done using manned helicopters or by having technicians climb dangerous 

areas for the inspection. Both these options can be highly dangerous and environmentally 

taxing. It can also lead to a lack of thorough inspections because cost is relatively high, thus, 

leading to unknowingly defective assets or vegetation overgrowth that can lead to environmental 

damage, such as forest fires. Our UAS operations can mitigate these potential high-risk 

situations. 

• Our UAV is certified in Germany to work around 500KV power line structures, thus 

ensuring that there is no electro-magnetic frequency that will affect performance of the 

UAS while in the air or cause it to go rouge. 

• There is no combustible fuel on board the UAS, thus the potential for fire or explosion is 

greatly reduced. 

• There is a far less environmental impact then conventional inspection techniques, insuring 

that safety of public and industrial infrastructure is maintained more efficiently and cost 

effectively.

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RAECON INDUSTRIES LTD.
VI. Summary The FAA Can Publish in the Federal Register: 

We, Raecon Industries, seek the exemption of the following: 

14 C.F.R. 21 and 14 C.F.R. 91: Airworthiness Certificates and Manuals. 

14 C.F.R. 21, Subpart H, entitled Airworthiness Certificates, sets forth requirements for 

procurement of necessary airworthiness certificates in relation to FAR § 91.203(a)(1). The size, 

weight and enclosed operational area of our UAS allows exemption from Part 21 because our 

UAS meets the equivalent level of safety pursuant to Section 333 of the Reform Act. The FAA is 

authorized to exempt aircraft from the airworthiness certificate requirement under both the Act 

(49 U.S.C. § 44701 (f)) and Section 333 of the Reform Act. Both pieces of legislation permit the 

FAA to exempt UAS's from the airworthiness certificate requirement in consideration of the 

weight, size, speed, maneuverability and proximity to areas such as airports and dense 

populations. 

14 C.F.R. 91.7(a) prohibits the operation of an aircraft without an airworthiness certificate. As no 

such certificate will be applicable in the form contemplated by the FARs, this Regulation is not 

relevant. 

14 C.F.R. § 91.9 (b) (2) requires an aircraft flight manual in the aircraft. Since there are no on 

board pilots or passengers in regard to UAS’s, this Regulation is also not relevant. A similar level 

of safety will be achieved by maintaining a safety/flight manual that will be on hand for operations 

crew during all operations. The FAA has previously issued exemptions to this regulation in 

Exemption Nos. 8607, 8737, 8738, 9299, 9299A, 9565, 9565B, 10167, 10167A, 10602, 10700 

and 32827. 

14 C.F.R. § 91.121 in regards to altimeter settings, this is inapplicable insofar as our UAS utilizes 

global positioning systems that monitor flight conditions for all flight operations 

14 C.F.R. § 91.203 (a) and (b) provides for the carrying of civil aircraft certifications and 

registrations. They are inapplicable for the same reasons described above.

14 C.F.R. 91.119: Minimum Safe Altitudes. 

Ensure safe altitudes for the operation of civil aircraft. It allows helicopters to operate at lower 

altitudes in certain conditions. Reacon Industries UAS will never operate at an altitude greater 

than 400 AGL; while most operations take place under 100-200 feet AGL. We will operate our 

UAS only in areas deemed safe and away from people and vehicle traffic, providing a level of 

safety at least equivalent to or below those in relation to minimum safe altitudes.

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

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RAECON INDUSTRIES LTD.
This regulation requires that aircraft owners and operators “have the aircraft inspected and 

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..” Before each operation we run a full inspection of the UAS checking all critical surface 

areas

Summary:

We, Raecon Industries, seek an exemption from the aforementioned Regulations to operate 

our unmanned aerial system commercially and lawfully, while at the same time working with the FAA 

to develop safe protocols and procedures for UAS usage. We seek relief of FAA restrictions for 

commercial UAS use to have the ability to offer asset inspections for the power and industrial 

industry. By granting our request, we Raecon Industries, will be able to provide a safer more 

environmentally friendly approach for asset management compared to standard practices, thus, 

alleviating conventional dangerous inspections of hard to reach and highly energized assets. Our 

UAS pilots are trained in manned aircraft and unmanned aircraft operations having completed 

manned aircraft ground school and/or pilot licensing. Our UAV is certified to work around 500KV 

power structures while maintaining limits of approach set by the power line trade. We have 

successfully and safely flown power line and energy assets for the last 13 months in Canada 

working along side Transport Canada. We, Raecon Industries, respectfully request that the FAA 

grant our exemption request and we are willing to work with and share all information to benefit the 

FAA to keep the national airspace, manned aircraft and public at large safe and informed. 

Kind Regards, 

Ben Van Lare 

Raecon Industries Ltd.

1685 H Street #318

Blaine, Washington

USA, 98230

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RAECON INDUSTRIES LTD.