U.S. Department of Transportation

Docket Management System

1200 New Jersey Avenue, SE

Washington, D.C. 20590

August 10, 2015

RE: Exemption Request Section 333 of the FAA Reform Act of the Federal Aviation Regulations from

14 CFR 91.7(a); 91.9(B)(2); 91.103; 91.109; 91.119 (c); 91.121; 91.151(a)(1); 91.203(a)(b); 91.405(a);

91.407(a)(1); 91.409(a)(1)and (2); 91.417(a)&(b); 45.23(b); Part 21; 61.113(a)&(b)

Dear Sir or Madam:

Pursuant to the FAA Modernization and Reform Act of 2012 (Reform Act), and the procedures contained 

in 14 C.F.R. 11, Xtreme Aeropix, Inc. (“Aeropix”), an owner and pilot of small unmanned aircraft, hereby 

applies for an exemption from the Federal Aviation Regulations (FARs) listed above so that Aeropix may 

operate its small unmanned aircraft / lightweight unmanned aircraft systems (sUAS) commercially in 

airspace regulated by the Federal Aviation Administration (FAA); as long as such operations are 

conducted within and under the conditions outlined herein or as may be established by the FAA as 

required by Section 333. As detailed in this document, the requested exemption would permit the 

operation of sUAS under controlled conditions in airspace that is 1) limited, 2) predetermined, and 3) 

access controlled. The use of sUAS in these applications will help enhance the safety, quality, and 

efficiency of many similar activities which are currently performed manually. Approval of this exemption 

would thereby enhance safety and fulfill the Secretary of Transportation’s (the FAA Administrator’s) 

responsibilities to “...establish requirements for the safe operation of such aircraft systems in the 

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

The name and address of the petitioner is:

Xtreme Aeropix Inc.

Anthony Jones / President

2643 George Washington Memorial Hwy

Suite B

Yorktown, VA 23693

757-806-6412

Email tony.j@XtremeAeropix.com

It is the request of Aeropix for exemptions listed above in order to legally and safely operate the DJI 

Inspire 1, DJI Phantom 3 Professional, 3D Robotics X8+, and 3D Robotics Aero-M UAS, in the National 

Airspace System, supporting construction, insurance, utility, telecommunications, and agriculture 

applications through aerial photography and videography.

Description of Flight Operations

 

Aeropix will primarily utilize its UAS for construction and agriculture mapping applications. UAS mapping 

is performed in a slow and methodical manner with flight profiles planned and programmed in advance 
while maintaining LOS and override capability during flight. Although mapping applications and 

environmental risks can differ greatly, the mechanics of flight planning and execution remain very 

similar. The use of sUAS can reduce the risk to workers while inspecting, surveying, or monitoring 

installation of work that requires ladders, scaffolds or other potentially hazardous means of elevated 

access. Aeropix will obtain permission to access these secure and/or remote sites by the property 

owners/managers prior to conducting flight operations. Flight operations will be performed at low 

altitudes and always within VLOS. Most mapping flights are conducted under 200 feet AGL. Construction 

site mapping benefits the public by providing more consistent and detailed over site of costly 

construction projects. In addition to providing accountability and saving the public money, the same 

outputs can be used to conduct safety surveys or detect structural or environmental concerns much 

sooner. Agricultural mapping services benefit the public by helping increase crop yield while lowering 

environmental impacts of chemicals and water usage.

Another purpose for Aeropix’s exemption request is to conduct manual flight inspections for special 

applications, such as cellular tower equipment checks and structural damage assessments for insurance

companies. In these applications, Aeropix will receive written consent to access these Secure / Sterile 

sites by the property owners / managers prior to conducting flight operations. Site access allows Aeropix

to perform all inspections at low altitude and always within VLOS. Most inspection flights will be under 

200ft. AGL, and all flight operations will remain below 400 feet AGL. 

Aeropix will cordon off aerial photography/videography sites to add a buffer to keep the public/nonparticipants safe. This will be done by using cones and signs advising of the possible hazard. Not only is 

public safety of utmost concern but also the safety of the climbing crews tasked with routine inspection 

of the towers. Aeropix and its UAS operations will alleviate the day to day height exposure of inspection 

services and allow them to concentrate on service and repairs. Climbers have one of the highest 

incidents of death in the labor force. UAS used to inspect cell towers allows the cell carriers to enhance 

operability to its clients; reducing down time and increasing signal strength by proactively inspecting 

towers and making repairs before failures or damages occur. UAS operations in support of insurance 

claim inspections will help reduce the number of falls and deaths associated with this type of operation.

Some of the operations listed above require flight within 100 feet of buildings and structures. Aeropix

has instituted several safety measures to limit and avoid collision or damage to such buildings or

structures and / or minimize risks and exposures:

- Written permission from property / building owners outlining operations and describing potential 

hazards.

- General Liability insurance to cover any damages.

- All flight operations follow operation manual, guidelines and procedures listed herein.

- Manual UAS operations within 50 feet of a structure requires the Visual Observer(s) to be positioned in 

manner that allows reliable distance to hazard approximations and remain in constant communication 

with the pilot.

Aeropix’ exemption will permit its operation of lightweight (less than 55 lbs.), UAS in tightly controlled 

and limited airspace. Predetermined, specifically marked areas of operation, cordoned off locations and 

corresponding enhancements to operate within current safety parameters and new ones to be 

implemented by the FAA Exemption relief.
Safety is paramount for Aeropix. We wish to help integrate UAS into the NAS by performing our services 

with the utmost concern for the safety of our pilots, the general public and property. To achieve this,

Aeropix has instituted several flight parameters, conditions, guidelines and limitations to adhere to 

before, during and after flight operations all of which are outlined in the UAS Pilot’s Operating 

Handbook. These conditions are based off of Part 333 exemptions that have already been approved by 

the FAA and have been integrated into our operations:

- The UAS will not exceed a ground speed of 30 knots.

-All operations will remain below 400 ft AGL.

-The UAS will weigh less than 55 lbs.

-All operations will remain in visual line of sight (VLOS).

- All flight operations requiring dedicated camera control will utilize a separate Visual Observer (VO). The

VO will provide additional situational awareness and support sense and avoid functions, always with 

verbal communications with the Pilot in Command (PIC).

- The pilot must follow the procedures as outlined in the UAS Pilot’s Operating Handbook. (Protocols & 

Procedures for UAS Operations, UAS Manufacturer’s User Manuals, and UAS Flight & Maintenance 

Logs).

- Prior to each flight, the PIC must inspect the UAS to ensure it is in a condition for safe operation.

- Any UAS that has undergone maintenance or alterations that would affect the UAS operation or flight

characteristics must undergo a functional test flight in accordance with operators manual.

- The PIC must follow the manufacturer's UAS aircraft / component, maintenance, overhaul,

replacement, inspection and life limit requirements.

- Prior to operations, the PIC will undergo UAS specific training for type (multi-rotor/plane/wing) make 

and model aircraft and log hours appropriately. The PIC will also maintain proficiency and currency 

(every 90 days) with UAS in a manner consistent with 14 CFR 61.51(b).

- PIC & VO will have successfully completed a qualification process, as outlined in the Protocols & 

Procedure for UAS Operations. Completion of this qualification process will be documented by the Chief 

Pilot.

- The UAS will not be operated directly over any person, except authorized and consenting flight

personnel.

- The PIC & VO will ensure that no persons are allowed within 100 feet of the flight area except those

consenting flight personnel.

- If UAS loses communication or experiences a loss of sufficient GPS signal, the UAS must return to a predetermined location within the security perimeter and land or be recovered in accordance with 

operator's manual.

- The UAS must abort the flight in the event of unpredicted obstacles or emergencies in accordance with

operators manual.

- All aircraft will be identified by a serial number, registered in accordance with 14 CFR part 47, and have

identification (N- Number) markings in accordance with CFR part 45(c). Markings will be as large as

possible.

- All pilots will comply with all manufacturers Safety Bulletins.

- Before conducting operations, the radio frequency spectrum used for operation and control of UAS will

comply with Federal Communications Commission (FCC).

- The documents required under 14 CFR 91.9 and 91.203 will be available to the PIC at the ground

station during all operations.

- The UAS will remain clear and yield the right of way to all other manned operations and activities at all

times.
- All operations will be conducted under visual meteorological conditions (VMC) and no night operations 

as defined in 14CFR 1.1.

- The UAS will not be operated by the PIC from any moving device or vehicle.

- The UAS will not be operated within 5 nautical miles of an airport reference point unless a letter of 

agreement with that airport’s management is obtained or otherwise permitted by an issued COA.

- Accidents will be reported to the National Transportation Safety Board (NTSB) per instructions

contained on the NTSB website.

REQUESTS FOR EXEMPTION BY PART AND SUBPART

14 CFR 21, Sub Part H Airworthiness Certificates

Entitled Airworthiness Certificates, set forth requirements for procurement of necessary airworthiness 

certificates in relation to FAR 91.203(a)(1). The size, weight and enclosed operational area of Aeropix’

UAS permits exemption from Part 21 because Aeropix’ UAS meet an 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 USC 44701(f)) and Section 333 of the Reform Act. Both 

pieces of the legislation permit the FAA to exempt UAS from the airworthiness certificate requirement in 

consideration of the weight, size, speed, maneuverability and proximity to areas such as airports and 

dense populations. Aeropix’ UAS meet or exceed each of the elements.

14 CFR 45.23(b) Marking of the Aircraft

Applicable codes of Federal Regulation require aircraft to be marked according to certain specifications. 

Aeropix’ UAS are, by definition, unmanned. They therefore do not have a cabin, cockpit or pilot station 

on which to mark certain words or phrases. Further, two inch lettering is difficult to place on such small 

aircraft. Regardless, Aeropix will mark its UAS in the largest possible lettering by placing the "N "number 

on its fuselage as required by 14 CFR 45.29 (f) so that the pilot, technician, spotter and others working 

with the UAV will see the markings. The FAA has previously issued exemptions to this regulation through 

Reference Exemption No 10167 and 10700

14 CFR 61.113(a)(b) Private Pilot Privileges and Limitations / PIC

Private pilots are limited to non-commercial operations. Aeropix can achieve an equivalent level of 

safety as achieved by current Regulations because Aeropix’ UAS do not carry any personnel. Further, 

while helpful, a pilot license will not ensure remote control piloting skills, though Aeropix’ pilot vetting 

and training program will require prospective PICs to demonstrate airman knowledge and proficiency 

prior to PIC certification. Applying manned commercial pilot certification requirements does not 

significantly add to the safety of sUAS operations. Further, the risk in operation of Aeropix’ UAS (<30 kts 

and <55 lbs) is far less than the risk levels inherent in the commercial activities outlined in CFR 61. Thus, 

allowing Aeropix to conduct operations with internally trained and certified pilots in command will 

achieve equivalent level of safety to manned aircraft.

Reference Exemption No. 12357

14 CFR 91.7(A) Civil Aircraft Airworthiness Certificate

Prohibits the operation of a civil aircraft without an airworthiness certificate. Aeropix requests

exemption based on previous Exemption No. 11138. The FAA has ruled that similar make and model of

aircraft (UAS) do not require an airworthiness certificate.
14 CFR 91.9 (B) (2) Aircraft Flight Manual in the aircraft

Requires an aircraft flight manual in the aircraft. As there are no pilots or passengers, and given the size 

of the UAS, this regulation is inapplicable. An equivalent level of safety will be achieved by maintaining a 

manual at the flight operations center. The FAA has previously issued exemptions to this regulation in 

Reference Exemption No. 10700 and 32827

14 CFR 91.103 Pre-Flight

No approved Airplane Flight Manual are maintained on board the aircraft. Aeropix asserts that an

equivalent level of safety will be achieved by the PIC taking all preflight actions set forth in the operating 

documents, including reviewing weather, flight battery requirements, landing and take-off distances, 

and aircraft performance data before initiation of flight.

14 CFR 91.109 Flight Instruction

Dual controls are not available for flight instruction.

14 CFR 91.119(C) Minimum Safe Altitudes

States that no person may operate an aircraft below the following altitudes: over other than congested 

areas, an altitude of 500 feet above the surface, except over open water or sparsely populated areas. In 

those cases, the aircraft may not be operated closer than 500 feet to any person, vessel, vehicle, or 

structure.

Aeropix will not operate any UAS over an altitude of 400 AGL. The majority of the operations proposed 

will be conducted between 50 to 200 feet AGL as this usually provides the best angle of capture for the 

type of photography and videography operations proposed.

The UAS’ utilized for this exemption are of exceptionally light weight and are not capable of speeds over 

50 knots. The UAS are all equipped with GPS guided auto pilot with a return home function in case of 

loss of control by the PIC and is powered by sealed batteries thereby reducing the chance of post impact 

fire to nearly zero.

There will be cases when the 500 foot distance from structures will need to be exempted.

(Example: Aerial Video of a 2 story home roof to determine and/or document extent of storm damage.) 

In this type of operation every assurance will be made to keep persons outside of a reasonable, safe, 

clear area of operations and will only be conducted with the express permission of the property owner. 

See Protocols and Procedures for UAS Operations section.

Aeropix will implement procedures and policies to ensure that any person in the general vicinity of 

operations will be aware of such operations and ensure that all non-essential personnel are cleared of 

the area of operations. See Protocols and procedures Section 3.

14 CFR 91.121 Altimeter Settings

Aeropix requests relief from 91.121 for the following reason. The UAS is equipped with GPS derived 

altitude capability, however due to the limited altitude requested in this exemption, the

FAA has previously granted Exemption for these types of operations. 

Reference Exemption No.11138

14 CFR 91.151(a) Fuel for Flight;
No person may begin a flight in an airplane under VFR conditions unless (considering wind and forecast 

weather conditions) unless there is enough fuel to fly to the first point of intended landing and, 

assuming normal cruise speeds

(a)(1)During the day to fly for at least 30 minutes.

Aeropix requests relief from 91.151(a) due to the fact that the UAS is equipped with a battery and 

remaining charge indicator system. The UAS have a flight capability on full charge of approximately 15-

40 minutes depending on sUAS in use, camera, and wind/speed variables. Aeropix will limit flight 

operations based on minimum voltage thresholds monitored by the PIC to ensure appropriate reserve 

battery charge and equivalent level of safety. Should the PIC fail to land the aircraft prior to reaching 

minimum voltage limits, the aircraft will autonomously return to its home point and land.

14 CFR 91.203(a)(b) Carrying of civil aircraft Certifications and Registrations

Provides for the carrying of civil aircraft certifications and registrations. They are inapplicable for the 

same reasons described above. The equivalent level of safety will be achieved by maintaining such 

certifications and registrations at the Aeropix flight operations center.

14 CFR 91.405(a) Maintenance required

Aeropix requests relief in part from 91.405(a)(1) based on the Protocols and Procedures

Section on Maintenance and Maintenance Records. 

Also Reference Exemption No. 11138

14 CFR 91.407(a)(1) Operation after maintenance, preventive maintenance, rebuilding, or alteration

Aeropix requests relief from 91.407(a)(1) based on the Protocols and Procedures Section on 

Maintenance, Return to service after maintenance, and Maintenance records. 

Reference Exemption No. 11138

14 CFR 91.409(a)(1)(2) Inspections

Aeropix requests relief from 91.409(a)(1)(2) based on the Protocols and Procedures

Section on Inspections. 

Reference Exemption No. 11138

14 CFR 91.417(a)(b) Maintenance records

Aeropix requests relief from 91.417(a)(b) based on the Protocols and Procedures Section on 

Maintenance records.

Protocols and Procedures for UAS operations

A. Qualifications and Proficiency

1. UAS must be operated by a current Pilot in Command for that model aircraft, as certified by 

the Chief Pilot. UAS Pilot in Command certifications shall be required to complete a training 

curriculum as determined by the Chief Pilot. 

2. Pilot in Command training shall include, as a minimum:

a. Aeronautical knowledge test. Successfully completing an FAA approved ground 

school shall satisfy this requirement.

b. Satisfactory demonstration of knowledge and flight proficiency for the applicable 

UAS model and applications as determined by the UAS Flight Instructor. Pilot in 
Command certification records shall specify which UAS and applications have been 

successfully completed.

c. Proficiency on each UAS will be maintained consistent with 14 CFR 61.51(b).

d. Satisfactory completion of biennial aeronautical knowledge testing.

e. Recent flight experience and proficiency requirements for each type of UAS 

certification shall be maintained consistent with 14 CFR 61.57. 

f. Prior to operations for which exemption is requested, the Pilot in Command must 

have accumulated and logged a minimum of 10 hours of total time as a UAV pilot

with at least 5 hours on the make and model to be used. The Pilot in Command

must have logged a minimum of 3 takeoffs and landings in the preceding 90 days

and a total flight time of 1 hour. Flight hours shall be logged in a manner consistent 

with 14 CFR 61.51.

B. Medical Conditions

1. In lieu of a medical certificate, Aeropix will require that each pilot and visual observer have a 

valid driver’s license and are trained in the functionality and procedures for initiating a 

“Return to Home” command.

2. In the event that the PIC experiences condition that impacts (or could impact) their ability to 

safely continue flight operations, the PIC or VO will immediately initiate a Return to Home 

command and secure all flight operations until conditions return to safe state as determined 

by the PIC.

C. Preflight Inspection of UAS

1. UAS preflight procedures outlined in the associated manufacturer user manual will be followed 

in a checklist manner. 

2. The Pilot in Command will certify that a complete preflight inspection has been accomplished 

with the date, time, and signature in the UAS logbook. 

3. Preflight checks may vary according to aircraft but shall include inspection and/or verification of 

the aircraft, transmitter, batteries, motors, rotors, landing gear, camera, and gimbal mounts.

4. The Pilot in Command shall ensure that weather conditions, area safety and security, and 

contingency planning has been adequately considered and incorporated into the operations 

plan prior to flight.

5. The Chief Pilot is responsible for ensuring that preflight procedures reflect the most recent 

guidance and that each Pilot in Command accomplishes required preflight checks prior to each 

flight.

D. Safety and Security

1. The Pilot in Command shall ensure that the operational area for the purposes of UAS flight 

remain clear of all nonessential personnel at all times while the UAS is in flight. Additionally, the 

Pilot in Command shall be responsible for ensuring all nonessential personnel shall be required 

to remain clear of flight operations. 

2. Physical barriers and/or signs will be used as necessary to restrict access in the vicinity of flight 

operations. The applicable safe distance may vary according to aircraft, altitude, and speed 

parameters.
3. In the event of a breach by nonessential personnel into the operations area during flight, the 

Pilot in Command shall immediately terminate flight operations until the breach and any 

associated cause has been corrected.

4. The UAS area of operation is defined as the horizontal flight path(s) of the UAS as well as the 

vertical flight path with an associated area of uncertainty proportional to aircraft size, weight, 

speed, and altitude. 

5. All nonessential personnel shall be maintained a minimum distance of 50 feet away from a 

relatively stationary aircraft and 100 feet away from the flight path of any aircraft operating 

above 10 feet/sec. 

E. Limitations of Operations

1. The UAS shall only be operated during daylight hours.

2. The Pilot in Command shall maintain the ability to regain flight control when operating in a preprogrammed flight mode.

3. The UAS shall remain within radio controller communication range at all times. The UAS shall 

have a Return to Home (RTH) feature set to initiate an automated recovery upon loss of control 

signal. Return parameter settings shall be verified by the Pilot in Command during preflight 

checks. 

4. No operations are allowed if the RTH function and/or autopilot are suspected to be 

malfunctioning.

5. The UAS shall be operated within VLOS. A Visual Observer in direct communication with the 

Pilot in Command may be used to extend the VLOS while operating in pre-programmed flight 

mode providing flight control signal connectivity is maintained and the UAS flight path can be 

monitored via telemetry while VLOS is obstructed from the Pilot in Command and a RTH feature 

is enabled in the event of a loss of communications scenario.

6. A Visual Observer shall be utilized during flights requiring manual camera and/or gimbal 

operation, pre-programmed mode where VLOS may be temporarily obstructed, or manual flight 

within 50 feet of a physical hazard. 

7. The UAS will have an altitude restriction of 400ft AGL.

8. The UAS will not be operated at a speed exceeding 30 Knots (50.6 fps, 15.4 mps)

9. All applicable operations manuals shall be available to the Pilot in Command on location.

10. The Pilot in Command must inspect and ensure that aircraft and ground control stations are in 

airworthy condition prior to each operation; if airworthiness is in question, all operations will be 

suspended until necessary repairs have been made and adequately tested.

11. An operational flight test shall be performed following any maintenance or alteration which 

could affect UAS operation or flight.

12. UAS maintenance shall be conducted in accordance with the manufacturer’s documented 

guidance.

13. All aircraft use, maintenance, and alteration activity shall be recorded in the aircraft records; 

including total flight hours, description of work performed, and the signature of the person 

authorizing return to service.

14. The Chief Pilot shall ensure that each UAS aircraft complies with all Manufacturer’s Safety 

Bulletin’s and that all pilots are kept informed of applicable updates. 
15. UAS must be operated by a current Pilot in Command for that model aircraft, as certified by the 

Chief Pilot. 

16. No UAS operations shall occur within 5 nautical miles of an airport except under the following 

conditions.

a. All flights within 5 nautical miles of an airport shall remain under 200 feet AGL.

b. No UAS operations above 100 feet AGL shall occur within 1 nautical mile of an airport 

reference point as denoted on a current FAA chart. 

c. All flights within 5 nautical miles of an airport shall require programmed altitude and 

range limitations preventing an uncontrolled fly-away situation. 

d. All flights within 5 nautical miles of an airport shall require a Visual Observer in constant 

communications with the Pilot in Command.

F. UAS Airworthiness

1. The PIC shall ensure that the UAS is in an airworthy condition before each flight.

2. Airworthiness shall be determined by a preflight inspection in accordance with the UAS 

manufacturer’s operating documents and any and all applicable Federal Aviation Regulations, 

and any additional requirements as defined by the Chief Pilot. 

3. The PIC shall document each preflight inspection by date, Aircraft total Flight time to date, any 

discrepancies noted, and signature and certificate number. Any discrepancy noted shall be 

addressed before UAS operation.

G. UAS Maintenance and Records

1. Each UAS shall have its own and separate maintenance log book.

2. Maintenance log books shall updated by the pilot following each flight. 

3. All failed preflight inspection checks shall be recorded in these logbooks. 

4. All flight log entries signoff shall include at least the following information: date of operation, 

Aircraft Total time, aircraft serial or operating number, PIC signature and certificate number.

Example: 

31JUL15, XAX801, ACFTT 50.1 hours, Preflight inspection completed, No defects noted, Jim 

Smith, PIC, XAPIC0001

5. Manufacturer documents, handbooks, user manuals, supplements, Safety Bulletins, etc., shall 

be the only approved documents for performing repairs, maintenance, inspections, overhauls, 

or replacement of life limited components. 

6. Any required maintenance, inspection, alteration or repair must be completed by an approved 

repair authority. At the completion of this work the approved person must make an entry in the 

aircraft log book that at least includes: Date, Aircraft serial or operating number, brief

description of the discrepancy, inspection, alteration or repair, the reference material used as 

guidance for the repair, statement approving the aircraft for return to service, and signature of 

person who completed the work.

Example: 

31JUL15, XAX801, ACFTT 50.1 hours, replaced number 3 motor with new motor, All testing 

completed satisfactory. Aircraft returned to service by Ed Smith, Chief Pilot.

7. Maintenance records shall be kept with the UAS at all times and shall be made available to any 

authorized agency or the Administrator upon request.
H. Pilot in Command Requirements

1. The Pilot in Command shall have accumulated and logged a minimum of 50 flight cycles and 10

hours of UAV flight time before performing any operation for which exemption is requested.

2. The Pilot in Command shall have at least 5 hours in make and model before performing any 

operation for which exemption has been requested.

3. The Pilot in Command shall perform a pre-flight inspection before each flight is conducted.

4. The Pilot in Command shall observe all Federal Aviation Regulations at all times with the

exceptions of the exemptions requested by the pilot. In those cases the Pilot in Command shall 

adhere to company operating standards or Federal Aviation Administration Limitations placed 

upon exemptions, whichever is more stringent.

5. The Pilot in Command must have 3 takeoff and landings within the preceding 90 days.

6. The Pilot in Command must maintain a record of flight information to establish currency and 

that he or she meets the requirements of this section.

7. The Pilot in Command will utilize eye protection in the event that sun glare would reduce VLOS 

operations.

I. Visual Observer Responsibilities and Requirements

1. A Visual Observer shall be utilized during flights requiring manual camera and/or gimbal 

operation, pre-programmed mode where VLOS may be temporarily obstructed, or manual flight 

within 50 feet of a physical hazard. 

2. The Visual Observer shall maintain verbal communication with the PIC at all times during UAS 

operation.

3. The Visual Observer shall maintain Visual Contact with the UAS at all times. 

4. In the event that Visual Contact is lost the VO will notify the PIC who will immediately cease

operations and land the aircraft.

5. The Visual Observer shall also help the PIC maintain area of operations security and ensure that 

all nonessential persons remain clear of the area of operations. In the event of a breach by 

unauthorized person(s) the VO shall notify the PIC and operations will cease immediately.

6. The Visual Observer shall also assist the PIC in looking for other aircraft traffic near the 

operations area. If another aircraft, manned or unmanned, is observed near the operations 

area, the VO will notify the PIC immediately. 

7. If a manned aircraft is detected near UAV operations, the PIC will cease operations and land the 

UAV immediately. The PIC shall assess the situation and safety risks associated with continued 

flight operations in the vicinity of other unmanned aircraft before determining if the UAV should 

be landed.

8. The VO will utilize eye protection in the event that sun glare would reduce VLOS operations.

J. Reporting of Incidents and/or Accidents

Any incident or accident, or flight operation that transgresses the lateral or vertical boundaries of 

the operational area as defined by the applicable COA will be reported within 24 hours to:

FAA UAS Integration Office (AFS-80)

Accidents: National Transportation Safety Board

www.ntsb.gov
Unmanned Aircraft Systems and Uses

A. Aeropix will operate the following aircraft:

a. DJI Inspire 1

b. DJI Phantom 3 Professional

c. 3D Robotics X8

d. 3D Robotics Aero-M

B. These shall be the only systems operated by Aeropix. 

C. The Inspire 1, Phantom 3, and X8 are each of ultra-light weight, quad-rotor design with built-in 

return to home features for flight.

D. The Aero-M is a light weight, foam based plane (under 10 lbs) with a built-in return to home feature 

for flight.

E. The manufacturers have built in several features to make operations safer: in the event of lost signal

the aircraft will return to its pre-determined location within the security perimeter and land; PIC has

ability to take over / abort flight manually in the event of loss to GPS; and the UAS has built-in

software that limits operations near airports and restricted airspace. 

F. Aeropix has attached the hyperlinks for the operating and user documents for the system as 

additional supplements for this petition. No modification to the factory system is to be utilized other 

than the dorsal surface area of the aircraft will be painted a bright safety orange to help manned 

aircraft see the unit while in flight. 

G. Please see attached supplemental documents.

1. http://www.dji.com/product/inspire-1/download

2. http://www.dji.com/product/phantom-3/download

3. http://3drobotics.com/kb/x8/

4. http://3drobotics.com/kb/aero-m/

The Public Interest

The request for this exemption is in the Public Interest as there are many consumer applications for the 

services that can be provided by UAS. It is clear that the Congress of the United States, the business 

sector, and the consumer want to integrate UAS into the NAS and utilize their unique and cost effective 

capabilities. It is also in the Public Interest that many of the low level flight operations now conducted by 

manned aircraft could be accomplished with these light, fire resistant and environmentally friendly 

unmanned aircraft that can operate at a fraction of the cost to both the pilot and consumer. These 

aircraft can be operated without risk of loss of life or limb, and without significant financial impact to the 

pilot or any person or property on the ground in the event of the loss of an aircraft. Utilizing these UAS 

will create a safer more productive work environment, reduce environmental pollution and have a 

positive impact on the local community which is in the Public Interest. Finally, Aeropix believes that 

granting this exemption would help to further by Administrators process of integration of UAS systems 

and possibility help to create additional regulations and guidance to be used as these systems become 

more widely utilized.
Abbreviations

VLOS - VISUAL LINE OF SIGHT

PIC - PILOT IN COMMAND

VO - VISUAL OBSERVER

UAS - UNMANNED AIRCRAFT SYSTEM

NAS - NATIONAL AIRSPACE SYSTEM

Please forward any questions or concerns to the address or email below.

Sincerely,

Anthony Jones / President

Xtreme Aeropix Inc.

2643 George Washington Memorial Hwy

Suite B

Yorktown, VA 23693

757-806-6412

Email: tony.j@XtremeAeropix.com