Douglas R. Dorrer 204 E. Main Street, Clarksburg, West Virginia, 26301 

January 26, 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 Reform Act and Part 11 of the Federal

Aviation Regulations

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, Douglas R. Dorrer, the Operator of a Small Unmanned Aircraft 

System (“sUAS”), including the 3DRobotics IRIS+ (“IRIS+”), seeks an exemption from

the Federal Aviation Regulations (“FARs”) listed below and discussed in Appendix A.

1 

Douglas R. Dorrer seeks exemption from the listed FARs to allow its use of the IRIS+ in

commercial operations, such as educational community outreach, aerial real property and 

pre/post environmental remediation surveys, and not-for-profit Search and Rescue (SAR) 

operations supporting local law enforcement, so long as such operations are conducted within

and under the conditions outlined herein or as established by the FAA in an exemption granted

under either Section 333 or Section 49 U.S.C. § 44701(f).

2

As discussed below, Douglas R. Dorrer is willing to abide by conditions the FAA has required

in issuing recent Section 333 exemptions. This agreement on Douglas R. Dorrer’s part and the

strong similarity of its operations to those approved in Exemptions 11109 and 11110 should

give the FAA a basis for prompt consideration and processing of this request.

Douglas R. Dorrer is an employee of the National Aeronautics and Space Administration 

(NASA) which provides educational outreach to students throughout the sparsely 

populated State of West Virginia, a former FAA-licensed Air Traffic Controller, and a 

state-licensed Realtor® with several University degrees in Professional Aeronautics and Airway 

Sciences. He proposes to use a small, lightweight (less than 4.5lbs/2kg) UAV – the 

IRIS+ – and software to collect, process, and analyze aerial data principally for purposes of

UAV educational outreach instruction, commercial aerial real property and pre/post 

environmental remediation surveying as well as not-for-profit Search and Rescue (SAR) 

operations supporting local law enforcement. Indeed, use of the IRIS+ would contribute to

various social goods, from education through Science, Technology, Engineering, and 

Mathematics (STEM); to real property marketing and environmental protection; to 

emergency support of First Responders. In providing these services, Douglas R. Dorrer would 

empower students, law enforcement, and businessmen

______________________

1 See Pub. Law 112-95, 126 Stat. 11, § 333 (2012).

2 Douglas R. Dorrer relies upon the following exemptions where specific reference to an exemption is not

provided: Exemptions 11062 through 11067, 11080, 11109 through 11112, and 11114.
Douglas R. Dorrer 204 E. Main Street, Clarksburg, West Virginia, 26301 

U.S. Department of Transportation

January 26, 2015

Page Two

to make better management decisions through software and cameras that identifies aerial 

perspectives of STEM initiatives, real property environmental conditions as well as life saving 

opportunities.

Operations under the exemption will be subject to strict operating requirements and conditions 

to ensure at least an equivalent level of safety to currently authorized operations using manned 

aircraft and under conditions as may be modified by the FAA as required by Section 333. 3

As described more fully below, the requested exemption would authorize commercial operations

using the IRIS+, which with a maximum take-off weight of less than 4.5 lbs. and is small in

size. The IRIS+ will be operated under controlled conditions at low altitude in Class G airspace

that is limited in scope, as described more fully herein; it will have automated control features,

as described herein. The IRIS+ also will be operated by an individual formerly trained under 

FAA Order JO 7110.65 4 as an Air Traffic Controller (“ATC”) 5

, within the National Airspace 

System (“NAS”) with several aviation-related university degrees transversing education directly 

related to aircraft operations.6 Finally, the Class G airspace in which the UAS will operate will

be coordinated with the local Fixed-Based Operator (FBO) or ATC facility as applicable. 

Additionally, a Notice to Airmen (“NOTAM”) will be filed in accordance with FAA Order JO 

7930.2P 7 prior to operations; if required.

Douglas R. Dorrer respectfully submits that because this small, unmanned aerial vehicle – the 

IRIS+– will be used in lieu of comparatively hazardous operations now conducted with 

fixed wing and rotary conventional aircraft, the FAA can have confidence that the 

operations will achieve at least an equivalent level or greater level of safety. Approval of this 

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

Administrator’s) responsibilities under Section 333(c) of the Reform Act to “establish 

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

The name and address of the applicant are: 

Douglas R. Dorrer

204 E. Main Street

Clarksburg, West Virginia 26301

(304) 629-7077

Wv_mba@earthlink.net

_____________________

3

While Douglas R. Dorrer is filing this exemption request on its own behalf, he anticipatesthat purchasers of the

IRIS+ in the future will file exemption applicationsto allow them to operate the IRIS+ in commercial operations on

their own. Those filings will be substantially similar to this exemption request. 4 Reference FAA Order Jo 7110.65, Air Traffic Control Handbook 5 See attached FAA license.

6 See attached Embry-Riddle Aeronautical University transcripts. 7 Reference FAA Order JO 7930.2P, Notices to Airmen.
Douglas R. Dorrer 204 E. Main Street, Clarksburg, West Virginia, 26301 

U.S. Department of Transportation

January 26, 2015

Page Three

The regulations from which the exemption is requested are as follows:

14 C.F.R. § 61.113(a) & (b);

14 C.F.R. § 61.133(a);

14 C.F.R. § 91.7(a);

14 C.F.R. § 91.119(c);

14 C.F.R. § 91.151(a);

14 C.F.R. § 91.405(a);

14 C.F.R. § 91.407(a)(1);

14 C.F.R. § 91.409(a)(2);

14 C.F.R. § 91.417(a) & (b)

Appendix A discusses each rule listed above and explains why exemptions pursuant to the 

proposal set forth in this letter are appropriate, provide an equivalent level of safety, and are in 

the public interest. Appendix B provides the requisite Federal Register summary.

THE APPLICABLE LEGAL STANDARD UNDER SECTION 333

Douglas R. Dorrer submits that grant of this exemption application for use of the IRIS+ in 

commercial and not-for-profit operations will advance the Congressional mandate in Section

333 of the Reform Act to accelerate the introduction of UASs into the NAS if it can be 

accomplished safely. This law directs the Secretary of Transportation to consider whether 

certain UASs may operate safely in the NAS before completion of the rulemaking required 

under Section 332 of the Reform Act. In making this determination, the Secretary is required to 

determine which types of UASs 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:

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

• Operation of the UAS in close proximity to airports and populated areas; and

• Operation of the UAS within visual line of sight of the Operator.

Reform Act § 333(a)(1). If the Secretary determines that such vehicles “may operate safely in 

the national airspace system, the Secretary shall establish requirements for the safe operation 

of such aircraft in the national airspace system.” Id. § 333(c) (emphasis added). 8

The Federal Aviation Act expressly grants the FAA the authority to issue exemptions. This 

statutory authority, by its terms, includes exempting civil aircraft, as the term is defined under

8 Applicant submits that this provision places a duty on the Administrator to not only process applicationsfor

exemptions under Section 333, but for the Administrator, if he deems the conditions proposed herein require

modification to allow approval, to supply conditionsfor the safe operation of the UAS. Douglas R. Dorrer

welcomes the opportunity to consult with FAA staff in order to address any issues or concernsthat this proposal

may raise that they believe may require modification.
Douglas R. Dorrer 204 E. Main Street, Clarksburg, West Virginia, 26301 

U.S. Department of Transportation

January 26, 2015

Page Four

§ 40101 of the Act, from the requirement that all civil aircraft must have a current airworthiness 

certificate and those regulations requiring commercial pilots to operate aircraft in commercial 

service:

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

under subsection (a) or (b) of this section or any of Sections 44702-44716 of this title if the

Administrator finds the exemption is in the public interest.

The grant of the requested exemption is in the public interest based on the clear direction in 

Section 333 of the Reform Act; the additional authority 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 and cost savings associated with

transitioning to UASs for aerial surveying. Accordingly, the applicant respectfully requests

that the FAA grant the requested exemption without delay. 9

AIRCRAFT AND EQUIVALENT LEVEL OF SAFETY

The applicant proposes that the exemption requested herein apply to civil aircraft that have the 

characteristics and that operate with the limitations listed herein. These limitations provide for at 

least an equivalent or even higher level of safety to operations under the current regulatory 

structure because the proposed operations represent a safety enhancement to operations that 

would be conducted with conventional aircraft. These conditions are drawn from Exemptions

11062 through 11067, 11080, 11109, and 11110.

These limitations and conditions to which Douglas R. Dorrer (or “Operator”) agrees to be

bound when conducting commercial operations under an FAA issued exemption include:

1. Operations of the IRIS+ are limited to the aircraft described in the attached 

manuals, which is a quadcopter (“Quad”) aircraft built by 3D Robotics, Inc. that weighs

less than 4.5 pounds (the “UAV” or “UAS”). Proposed operations of any other

operationally or technically similar aircraft shall be considered.

2. The UAV may not be flown at an indicated airspeed exceeding 25 knots.

9 In filing this application, Douglas R. Dorrer also is requesting that the FAA combine the grant of the Section 333

exemption with a stand-alone Certificate of Operation (“COA”) that will allow commercial operations of the IRIS+

without the necessity of filing for a COA for each flight. Compliance with the conditions agreed to herein and that

may be imposed by the FAA, as set forth in prior Section 333 exemptions, provide the separation needed from other

aircraft. NOTAM and notice to air traffic control can be provided by the filing of a NOTAM as set forth within the

proposed conditions.
Douglas R. Dorrer 204 E. Main Street, Clarksburg, West Virginia, 26301 

U.S. Department of Transportation

January 26, 2015

Page Five

3. The UAV may be operated at an altitude of no more than 150 feet above ground

level (“AGL”), as indicated by the procedures specified in the attached manuals. All

altitudes reported to ATC must be in feet AGL.

4. The UAV must be operated within visual line of sight (“VLOS”) of the Operator. 

5. All operations must utilize a visual observer (“VO”). The VO may be used to

satisfy the VLOS requirement as long as the Operator always maintains VLOS

capability. The VO and Operator must be able to communicate verbally at all times. 

The Operator must be designated before the flight and cannot transfer his or her

designation for the duration of the flight. The Operator must ensure that the VO can

perform the functions prescribed in the Operator’s manual.

6. The manuals must be amended to include all conditions and limitations required by

the FAA. The manuals must be maintained and made available to the Administrator

upon request. If a discrepancy exists between the conditions and limitations in the

exemption and the procedures outlined in the manuals, the conditions and limitations in

the exemption take precedence and must be followed. Otherwise, the Operator must

follow the procedures as outlined in the manuals.

The Operator may update or revise the manuals. It is the Operator’s responsibility

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

upon request. The Operator must also present updated and revised documents if it 

petitions for an extension or amendment of this 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 amendment to its exemption.

7. Prior to each flight, the Operator must inspect the UAS to ensure it is in a

condition for safe flight. 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. The ground control station must be included in the preflight inspection. All

maintenance and alterations must be properly documented in the aircraft records.

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 in accordance with the Operator’s manual. The

Operator who conducts the functional test flight must make an entry in the UAS aircraft

records of the flight. The manuals include this requirement.

9. The preflight inspection section in the manuals includes the following requirement: 

the preflight inspection must account for all discrepancies, i.e., inoperable
Douglas R. Dorrer 204 E. Main Street, Clarksburg, West Virginia, 26301 

U.S. Department of Transportation

January 26, 2015

Page Six

components, items, or equipment, not covered in the relevant preflight inspection 

sections of the Operator’s manual.

10. The Operator must follow 3D Robotics IRIS+ aircraft/component, maintenance, 

overhaul, replacement, inspection, and life limit requirements, with particular attention

to flight critical components that may not be addressed in the manufacturer’s manuals.

11. All maintenance and aircraft inspections shall be completed in accordance with the

manuals. A lterations must be noted in the aircraft logbook, including total flight hours,

description of work accomplished, and the signature of the authorized technician

returning the UAS to service.

13. Each UAS operated under the exemption must comply with all 3D Robotics

system and safety bulletins.

14. Operator’s maintenance personnel must make a record entry in the UAS logbook

or equivalent document of the corrective action taken against discrepancies discovered 

between inspections.

15. The Operator is not required to obtain a private pilot certificate or a third-class

airman medical certificate in accordance with 14 CFR Part 103. 10

16. The Operator shall 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 people, vessels, vehicles, and

structures.

17. The Operator shall only operate the UAS in the immediate vicinity of the subject 

educational outreach, aerial real property or environmental surveys, or within 

designated SAR operations with First Responder oversight.

18. The Operator shall conspicuously post signage indicating UAS operations are in 

progress and to remain clear. 11

19. If the UAS loses communications or loses its GPS signal, the UAS must return to a

pre- determined location within the private or controlled-access property and land or

be recovered in accordance with the manuals.

20. The Operator must abort the flight in the event of unpredicted obstacles or

emergencies in accordance with the manuals.

_____________________

10 See Reference 14 CFR 103, Ultralight Vehicles 11 See Attached Proposed Sign
Douglas R. Dorrer 204 E. Main Street, Clarksburg, West Virginia, 26301 

U.S. Department of Transportation

January 26, 2015

Page Seven

21. The Operator is prohibited from beginning a UAS flight unless (considering wind

and forecast weather conditions) there is enough power to fly to the first point of

intended landing and, assuming normal cruising speed, to fly after that for at least 10

minutes.

22. The Operator will file a request for a Notice to Airmen (NOTAM) not more than 72

hours in advance, but not less than 48 hours prior to the operation.

23. Before conducting operations, the radio frequency spectrum used for operation and 

control of the UA must comply with the Federal Communications Commission (“FCC”)

or other appropriate government oversight agency requirements.

24. The Operator and VO shall monitor ATC emergency radio frequencies VHF 121.5

Mhz or UHF 243.0 Mhz.

25. The documents required under 14 C.F.R. 91.9 and 91.203 must be available to the

Operator 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.

26. The UAS must 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.).

27. The UAS may not be operated by the Operator from any moving device or vehicle.

28. All operations shall be conducted in Class G airspace 150 feet or less AGL.

29. All operations must be conducted under visual meteorological conditions (“VMC”).

The UAS 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

Operator.

30. During operations in Class G airspace, the UAS may not operate within 5 nautical

miles of the geographic center of an 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 NOTAM as required by the

Operator’s COA. The letter of agreement with the airport management must be made

available to the Administrator upon request.
Douglas R. Dorrer 204 E. Main Street, Clarksburg, West Virginia, 26301 

U.S. Department of Transportation

January 26, 2015

Page Eight

30. The UAS may not be operated over congested or densely populated areas unless the 

conditions set forth in #31 are satisfied. These populated areas include, but are not 

limited to, the yellow areas depicted on World Aeronautical Charts (“WAC”), Sectional 

Aeronautical Charts (“Sectionals”), or Terminal Area Charts (“TAC”). However, 

aeronautical charts may not reflect pertinent local information. Ultimately, it is the

Operator’s responsibility to maintain the minimum safe altitudes required by § 91.119.

31. Operations must be conducted at least 150 feet from all nonparticipating persons

(person’s other than the Operator or VO), vessels, vehicles, and structures

unless:

a. Barriers or structures are present that sufficiently protect nonparticipating persons 

from debris in the event of an accident. The Operator must ensure that nonparticipating

persons remain under such protection. If a situation arises in which nonparticipating

persons leave such protection and are within 150 feet of the UAS, flight operations must

cease immediately; and/or

b. the aircraft is operated near vessels, vehicles, or structures where the land 

owner/controller has granted permission and the Operator has made a safety

assessment of the risk of operating closer to those objects; and

c. operations near the Operator or VO do not present an undue hazard to the

Operator or VO, per § 91.119(a).

32. All operations shall be conducted over private or controlled-access property with 

permission from the land owner/controller or authorized representative. Permission from 

land owner/controller or authorized representative will be obtained for each flight to be 

conducted.

33. In the event COAs are required, any incident, accident, or flight operation that 

transgressesthe 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.

********

Privacy. All flights will occur over private or controlled access property with the

property owner’s prior consent and knowledge. Inspection will be in areas where the owners

will have consented to the inspections or otherwise have agreed to allow the UAS and the

Operator to be in the area where inspection will take place.
Douglas R. Dorrer 204 E. Main Street, Clarksburg, West Virginia, 26301 

U.S. Department of Transportation

January 26, 2015

Page Nine

National Security. No national security issue is raised by the grant of this exemption. Given 

the size, load carrying capacity, speed at which it operates, and the fact that it carries no 

explosives or other dangerous materials, the IRIS+ poses no threat to national security.

********

In summary, Douglas R. Dorrer seeks an exemption from the FARs set forth in Appendix

A to operate commercially a small unmanned vehicle (4.5lbs. or less) in educational outreach, 

aerial real property and pre/post environmental remediation surveys as well as not-for-profit 

Search and Rescue operations.

Approval of this exemption for commercial operations will enhance safety by reducing risk. 

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

altitudes just feet from the subject being inspected and in extreme proximity to people and

structures. Such manned operations present the risks associated with vehicles that weigh in

excess of 6,000 lbs., carrying large amounts of jet A or other fuel. Such aircraft must fly to

and from the project location. In contrast, a sUAS weighing fewer than 4.5 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 is carried to the target area and not flown. The 

sUAS will carry no passengers or crew and, therefore, will not expose them to the risks 

associated with manned aircraft flights.

The operation of small UASs, weighing less than 4.5 lbs., conducted in the strict conditions 

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

exemptions requested herein. These lightweight aircraft operate at slow speeds, close to the 

ground, and in sparsely-populated West Virginia Class G airspace not under the authority of 

ATC 12. As a result, they are far safer than conventional operations conducted with manned

aircraft operating in close proximity to the ground and people.

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 UAS for the 

Purposes outlined herein and are consistent with exemptions already granted, including

Exemptions 11062 through 11067, 11080, 11109 through 11112, and 11114.

Sincerely,

Douglas R. Dorrer, MBA, Pro Se

__________________________

12 FAA Order JO 7110.65v – Chapter 12.1.1.2, Airspace Classification, Class G - Uncontrolled airspace

within which ATC has neither the authority nor responsibility for exercising control over air traffic.
Douglas R. Dorrer 204 E. Main Street, Clarksburg, West Virginia, 26301 

APPENDIX A

EXEMPTION REQUEST AND EQUIVALENT LEVEL OF SAFETY SHOWINGS

UNDER APPLICABLE RULES SUBJECT TO EXEMPTION

Douglas R. Dorrer requests an exemption from the following regulations as well as any

additional regulationsthat may technically apply to the operation of the IRIS+:

14 C.F.R. § 61.113(a) & (b); 61.133(a): Private Pilot Privileges and Limitations; Pilot in

Command; Commercial Pilot Privileges and Limitations.

Section 61.113(a) & (b) limit private pilots to non-commercial operations. Unlike a

conventional aircraft that carries a pilot, passengers, and cargo, the IRIS+ in this case is

remotely controlled with no passengers or property of others on board. Section 61.133(a)

requires an individual with a commercial pilot’s license to be pilot in command of any aircraft

for compensation or hire. Douglas R. Dorrer respectfully proposes that Operator requirements

should take into account the characteristics of the particular UAS. Douglas R. Dorrer’sIRIS+

has a high degree of pre-programmed control and various built-in technical capabilities that

strictly limit the potential for operation outside of the operating conditions set forth in the

exemption application.

The IRIS+ has an autonomous navigation and control system. Flights are pre- programmed

with precision GPS guidance and do not require human intervention. In the case of unplanned

events, the Operator can manually intervene to take one of the following actions:

(i) command the aircraft to begin to autonomously return to the recovery area and land;

(ii) command the aircraft to autonomously return to the recovery area where the pilot will

assume control and land the aircraft; or (iii) manually assume control of the aircraft via the

hand controller and return the craft to the recovery area where the Operator lands it.

Additional automated safety functions and safety enhancing features of the IRIS+ include the

following:

• Auto-pilot detection of lost GPS or of insufficient satellites initiates a stand-by loiter

pattern until such time as GPS is re-established or the PIC assumes manual control of the

aircraft.

• Low battery power on the aircraft (10.4 volts) triggers the landing sequence and the

craft will fly to the recovery area.

• If the auto-pilot detects a lost-link to the ground control station for longer than 30

seconds, landing procedure begins.

• The aircraft, weighing fewer than 4.5 lbs., fully loaded, is constructed of plastic,

which is intended to absorb impact energy.

• In the event the ground station reaches a low power state, it will alert the

pilot.
Douglas R. Dorrer 204 E. Main Street, Clarksburg, West Virginia, 26301 

The FAA has long-established regulations found in 14 CFR 103 (“Part 103”) that do not require 

an operator of Ultralight Vehicles weighing less than 254 lbs to obtain an airman or medical 

certificate:

1. § 103.7 Certification and registration.

(b) Notwithstanding any other section pertaining to airman certification, operators of 

ultralight vehicles are not required to meet any aeronautical knowledge, age, or 

experience requirements to operate those vehicles or to have airman or medical 

certificates.

2. Interim Operational Approval Guidance 08-01 1

9.1.1.1 Operations not requiring a pilot certificate: The PIC may not be 

required to hold a pilot certificate for operations approved and conducted 

solely within visual line of sight in Class G airspace. For the PIC to be exempt 

from the pilot certificate requirement the following conditions must exist and 

the alternate compliance method described below must be followed:

• The operation is conducted in a sparsely populated location, and, 

• The operation is conducted from a privately owned airfield, military 

installation, or off-airport location. 

• Visual line of sight operations conducted no further than 1 NM laterally 

from the UAS pilot and at an altitude of no more than 400 feet above 

ground level (AGL) at all times. 

• Operations shall be conducted during daylight hours only. 

• Operations shall be conducted no closer than 5 NM from any airport or 

heliport.

Given these safety features as well as established FAA regulatory guidance, Douglas R. Dorrer

proposesthat Operators of the IRIS+ should not be required to hold an airmen or medical 

certification.

The risks associated with the operation of the IRIS+ (given its size, speed, operational 

capabilities, and lack of combustible fuel) are so diminished from the level of risk associated with 

commercial operations contemplated by Part 61 with conventional aircraft (fixed wing or

rotorcraft) that allowing operations of the UAS as set forth above meets or exceeds the present

level of safety provided under 14 C.F.R. § 61.113(a) & (b) and does not rise to the level of

requiring a commercial pilot to operate the aircraft under § 61.133(a).

_________________

1 See Reference Interim Operational Approval Guidance 08-01; Unmanned Aircraft Systems 

Operations in the U. S. National Airspace System, 2008.
Douglas R. Dorrer 204 E. Main Street, Clarksburg, West Virginia, 26301 

Given these conditions and restrictions, an equivalent level of safety will be provided by

allowing operation of the IRIS+ without a private pilot’s certificate, under the conditions set

forth in the exemption request. The FAA has granted exemptions to conduct similar

operations in Exemptions 11062 through 11067, 11080, 11109, and 11110.

14 C.F.R. § 91.7(a): Civil Aircraft Airworthiness.

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

condition. Should the exemption be granted allowing commercial operation of the IRIS+

without an airworthiness certificate, no standard will exist for airworthiness of the IRIS+. Given

the size of the aircraft and the requirementsthat the Operator has agreed to as relates to 

airworthiness, as set forth in the attached manuals, an equivalent level of safety will be achieved

by ensuring compliance with the 3D Robotics manuals prior to each flight. The FAA has granted 

exemptions to conduct similar operations in Exemptions 11062 through 11067, 11080, 11109,

and 11110.

Furthermore, 14 CFR 103.7 (a) , Ultralight Vehicles weighing less than 254 lbs. do not require 

an airworthiness certificate.

(a) Notwithstanding any other section pertaining to certification of aircraft or their parts 

or equipment, ultralight vehicles and their component parts and equipment are not 

required to meet the airworthiness certification standards specified for aircraft or to have 

certificates of airworthiness.

14 C.F.R. § 91.119(c): Minimum Safe Altitudes.

Section 91.119 establishes safe altitudes for operation of civil aircraft. Specifically, 91.119(c)

limits aircraft flying over areas other than congested areas to 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.

As set forth herein, the IRIS+ will never operate at higher than 150 feet AGL. It will, however,

be operated to avoid congested or populated areas that are depicted in yellow on VFR sectional

charts. Because aerial survey work must be accomplished at relatively low altitudes and at

altitudes less than 500 feet AGL, an exemption from Section 91.119(c) is needed.

The equivalent level of safety will be achieved given the size, weight, speed, and material with 

which the IRIS+ is built. Also, no flight will be taken without the permission of the landowner

or those who control the land as well as local officials. Because of advance notice to the

landowner, all affected individuals will be aware of the survey flights. Compared to aerial 

survey operations conducted with aircraft or rotorcraft weighing far more than 4.5 lbs. and

carrying flammable fuel, any risk associated with these operations will be far less than the risks

currently posed by conventional aircraft operating at or below 500 feet AGL. Indeed, the lowaltitude operations of the UAS will maintain separation between these small-UAS operations

and the operations of conventional aircraft that must comply with Section 91.119. The FAA has

granted exemptions to conduct similar operations in Exemptions 11062 through 11067, 11080,

and 1110.
Douglas R. Dorrer 204 E. Main Street, Clarksburg, West Virginia, 26301 

Douglas R. Dorrer further believes that ATC does not have the authority to control aircraft 

within Class G airspace according to FAA Order JO 7110.65v.

12.1.1.2-Airspace Classification; Class G - Uncontrolled airspace within which ATC has 

neither the authority nor responsibility for exercising control over air traffic. (Emphasis 

Noted)

Furthermore, while operating within Class G airspace under the doctrine of “See and Avoid” in 

accordance with 14 CFR 91.113- Right of Way Rules, manned-aircraft must give way to a lesser 

maneuverable or unmanned aircraft. A 4.5lb. UAS and a piloted fuel-powered aircraft are 

obviously not of the same category.

(b) General. When weather conditions permit, regardless of whether an operation is 

conducted under instrument flight rules or visual flight rules, vigilance shall be 

maintained by each person operating an aircraft so as to see and avoid other aircraft.

(d) Converging. When aircraft of the same category are converging at approximately the 

same altitude (except head-on, or nearly so), the aircraft to the other's right has the rightof-way. If the aircraft are of different categories—

(1) A balloon has the right-of-way over any other category of aircraft;

(2) A glider has the right-of-way over an airship, powered parachute, weightshift-control aircraft, airplane, or rotorcraft.

(3) An airship has the right-of-way over a powered parachute, weight-shiftcontrol aircraft, airplane, or rotorcraft.

14 C.F.R. § 91.151(a): Fuel Requirementsfor Flight in VFR Conditions

This regulation 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 batteries powering the IRIS+ provide approximately 10-15 minutes of powered flight. 

Without an exemption from § 14 C.F.R. 91.151, the UAS’s flights would be limited to

approximately 5-7 minutes in length. Given the limitations on its proposed operations and the

location of those proposed operations, a longer time frame for flight in daylight VFR conditions

is reasonable.

Douglas R. Dorrer believes that an exemption from 14 C.F.R. § 91.151(a) is safe and within the

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

operate without compliance with 91.151(a)). Operating the small UAS without 5-7 minutes of

reserve fuel does not engender the type of risks that Section 91.151(a) was meant to prevent

given the size and speed at which the UAS operates. The fact that it carries no pilot, passenger,

or cargo also enhances its safety. Limiting IRIS+ flights to 5-7 minutes would greatly reduce

their utility. In the unlikely event that the IRIS+ achieves a low battery state (10.4 volts), it

would simply land. Given its weight and construction material, the risks are less than
Douglas R. Dorrer 204 E. Main Street, Clarksburg, West Virginia, 26301 

contemplated by the current regulation.

Douglas R. Dorrer believes that an equivalent level of safety can be achieved by maintaining

5 minutes of battery life, which, allowing 15 minutes of flight time, would be more than

adequate to return the UAS to its planned landing zone from anywhere in its operating area.

Similar exemptions have been granted to other Operators, including Exemptions 2689F, 5745,

10673, 10808, and Exemptions 11062 through 11067, 11080, 11109, 1110, and 11112.

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

Section 91.405(a) requires 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 discrepanciesrepaired as prescribed in part 43 of

this chapter . . . .” Section 91.407 similarly makes reference to requirements in Part 43;

Section 91.409(a)(2) requires an annual inspection for the issuance of an airworthiness

certificate. Section 91.417(a) requires the owner or Operator to keep records showing certain

maintenance work that has been accomplished by certificated mechanics, under Part 43, or

licensed pilots and records of approval of the aircraft for return to service.

Maintenance of the IRIS+ will be accomplished by the owner/Operator pursuant to the manuals

attached as confidential exhibits. An equivalent level of safety will be achieved because the

UAS is small in size, will carry a small payload, will operation only in restricted predetermined 

areas and is not a complex mechanical device. As provided in the attached manuals, the

Operator will ensure that the UAS is in working order prior to initiating flight, perform required

maintenance, and keep a log of any maintenance that is performed; moreover, the Operator is the

person most familiar with the aircraft and is best suited to maintain the aircraft in an airworthy

condition and to ensure an equivalent level of safety. The FAA has granted exemptions for

similar operations in Exemptions 11062 through 11067, 11080, 11109, 11110, and 11112.
APPENDIX B 

SUMMARY OF DOUGLAS R. DORRER SECTION 333 EXEMPTION REQUEST

For publication in the Federal Register, Douglas R. Dorrer hereby provides pursuant to Part 11 a 

summary of its exemption application to allow commercial operation of the IRIS+ unmanned

aircraft in educational outreach, aerial real property and pre/post environmental remediation

survey work as well as not-for-profit search and rescue operations. An exemption is requested

from the following regulations:

14 C.F.R. § 61.113(a) & (b);

14 C.F.R. § 61.133(a);

14 C.F.R. § 91.7(a);

14 C.F.R. § 91.119(c);

14 C.F.R. § 91.151(a);

14 C.F.R. § 91.405(a);

14 C.F.R. § 91.407(a)(1);

14 C.F.R. § 91.409(a)(2);

14 C.F.R. § 91.417(a) & (b)