1

June 23, 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”), Aerial NET Inc, 

an aerial data acquisitions company, and planned operator of an Unmanned Aircraft Systems (“UAS”) seeks an 

exemption from Federal Aviation Regulations (“FARs”) listed below and discussed in Appendix A. Attached, as 

Appendix B, is a summary of this request.

The requested exemption would allow the Applicant to safely, efficiently, and economically use commercial UAS in 

the National Airspace System (NAS), so long as such operations are conducted within and under the conditions 

outlined herein or as may be established by the FAA as required by Section 333.

As described more fully below, the requested exemption would authorize the Applicant to perform commercial 

operations with UAS that will provide the following benefits:

1. Commercial use of UAS to perform aerial data acquisition and research in support of government entities, 

agriculture industry, utility companies, local infrastructure, scientific studies, wildlife monitoring, mining, 

surveying, forestry, and much more. The aerial data will include, but not be limited to imagery, aersosol 

concentrations, temperature and humidity. All collected data will be used in ways which are critical to the 

well-being of the general public.

2. Proper operations of a UAS reducing the safety concern to the general public when performing data 

acquisition activities. The small sizes, low weights and minimal concentrations of flammables means that if 

an accident with a UAS were to occur, the impact would be significantly less than a small aircraft of 

rotorcraft, which are commonly used in similar data acquisition tasks. 

3. Operation of UAS will substantially reduce the risk to life and property in the air, and on the ground, which 

is commonly associated with traditional manned aircraft flight operations.

4. Similar to the current manned aircraft flight operations that have been conducted for many decades, UAS

used for similar tasks will not generate any new privacy issues.
2

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 requirements for the safe

operation of such aircraft systems in the national airspace system."

The name and address of the applicant are:

Attn: Nathan R. Huntoon

Ph: 972-971-6491

Email: nathan.huntoon@aerialnetinc.com

Address: 4702 Grant Ct

Frisco, TX, 75035

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

14 C.F.R. Part 21;

14 C.F.R. 45.23(b);

14 C.F.R. 61.113(a) & (b);

14 C.F.R. 61.133(a);

14 C.F.R. 91.7(a);

14 C.F.R. 91.9(b)(2) & (c);

14 C.F.R. 91.103;

14 C.F.R. 91.109(a);

14 C.F.R. 91.119;

14 C.F.R. 91.121;

14 C.F.R. 91.151(a);

14 C.F.R. 91.203(a) & (b);

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)

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 Aerial NET Operations Manual
QUALIFICATION FOR APPROVAL UNDER SECTION 333 OF THE REFORM ACT

The proposed operations in this petition for exemption qualify for expedited approval under Section

333 of the Reform Act. Each of the statutory criteria and other potentially relevant factors are

satisfied.

The proposed operations would permit the use of small and relatively inexpensive UAS under

controlled conditions in airspace that is: (1) limited; (2) predetermined; (3) controlled as to access,

and; (4) would provide an increased level of safety beyond that existing when fixed or rotor wing 

aircraft are used to accomplish the same purpose.

The UAS's planned to be operated are rotorcraft and fixed wing aircraft, each weighing less 

than 55 lbs., including payload. They would operate at a ground speed of no more than 120

knots. The principal construction material of the UAS aircraft would typically be carbon fiber, 

aluminum, foam and/or plastic. Operations will be performed by a qualified UAS Pilot in 

Command (PIC), as outlined below, to insure that the UAS will "not create a hazard to users of

the national airspace system or the public." Given the small size of the UAS involved and the

pre-planned environment within which they will operate, the applicant believes that these

operations fall squarely within that zone of safety (an equivalent level of safety) in which

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

commence immediately. Also, due to the size of the UAS and the pre-defined, restricted area in 

which the UAS will operate, and mandatory background checks for all PICs, approval of the 

application presents no national security issue. The operation of UAS by qualified

professionals will serve to enhance safety, add to the public benefit, and reduce

environmental impacts related to current methods of manned aircraft flight operations.

These limitations and conditions to which the operator, or its employees, acting as UAS PIC

agrees to be bound when conducting commercial operations under an FAA issued exemption:

1. Safety for the general public will be the primary consideration during all pre-flight 

planning, and during UAS operations.

2. Safe operations in the NAS, and the safety of other aircraft will be the secondary 

consideration during all pre-flight planning and during UAS operations. 

3. The UAS pilot will be considered Pilot in Command (PIC), and will be responsible for 

safe operation during the flight. Only a certified UAS operator as described below will 

act as a PIC.

4. Flights will be operated within line of sight of the PIC and/or an observer, which will be 

at a distance of less than one (1) mile.
5. The UAS will weigh less than 55 lbs.

6. The UAS will operate at a maximum speed of no greater than 120 knots.

7. UAS operations will only occur over land at the request of the owner. The owner will 

be involved in pre-flight planning to ensure all privacy and safety considerations are 

considered. 

8. Prior to all UAS operations, a formal notification to the Flight Standards District Office 

(FSDO) and a NOTAM will be issued.

9. Aircraft shall not be operated within 5 miles of an airport without prior written approval 

of, and establishing a line of communication for the duration of the flight operation 

with, the controlling authority of that airport. A copy of the written approval will be held 

by the PIC at all times while operating in this regime. 

10. Aircraft shall avoid areas where manned aircraft can be expected to be descending

through 400ft.

11. Aircraft shall maintain a minimum horizontal separation of no less than one (1) mile 

from all other manned or unmanned airborne aircraft unless that other aircraft is 

maintaining level flight or climbing at an altitude above 8000ft AGL.

12. If at any time the PIC or VO see or hears another aircraft and it appears that aircraft 

may come within one (1) mile of the operator’s system, or it is questionable whether or 

not it will do so, the operator shall immediately descend the system to 100 ft. AGL or 

less and direct the system on a heading toward it’s designated landing area, or 

alternate landing area if necessary, until the system has landed or it is determined the 

other aircraft has maintained a separation of one (1) mile.

13. Flights will be operated under visibility and cloud clearance requirements equivalent to 

Visual Flight Rules (VFR).

14. The UAS will at all times give way to any aircraft carrying persons.

15. Minimum crew for each operation will consist of the UAS PIC. An observer will be 

utilized if is determined to be needed during pre-flight preparations. The observer and 

PIC will at all times be able to communicate by voice.

16. Prior to a UAS flight, an area of operation will be established. This area of operation 

will include a defined lateral and vertical area, where the UAS will operate. The 

owners and occupants of the entire area of operation will be notified of UAS 

operations prior to their start. Safety procedures will be established for persons, 

property and applicable airspace within the area of operation.

17. The UAS shall operate from on-site takoff/landing locations directly next to the PIC.

18. Flight planning will include flight completion with at least 20% flight power, and at least 

20% control power remaining as measured by the UAS or appropriate timing.

19. The UAS will be equipped with an autopilot system which will be equivalent to or 

better than a, Mikrokopter, DJI, or Pixhawk system. For example, the UAS will utilize 
GPS navigation, failsafe’s, return-to-home (RTH), and flight abort safety features, 

among other built-in safety features.

20. A Ground Station will be connected, by radio communication, to the UAS during the 

entire flight, which will give the PIC flight information such as GPS Position, Altitude, 

Battery Remaining, and other telemetry information. If the link between the UAS and 

the GS is lost, the UAS will automatically return to the PIC and land. 

21. A briefing will be conducted in regard to the planned UAS operations prior to operation 

at each new location. All personnel who will be performing duties within the 

boundaries of the area of operation will be present for this briefing.

22. All required permissions and permits will be obtained from appropriate state, county or 

city jurisdictions, including local law enforcement, fire, or other appropriate 

governmental agencies.

23. Written, to include electronic, and/or oral permission from the relevant property 

owners will be obtained prior to an operation.

24. The UAS pilot will be trained in advance for the safe operation of the UAS to be 

operated. This will include operation of the UAS both ‘Auto’ and ‘Manual’ modes. 

Completion of a certification detailed below is required to be a PIC. Training will also 

include types of maneuvers to be performed and the safe operation in relation to 

persons, property and applicable airspace.

It is the applicant's belief that the size, weight, speed, operating environment, and operating 

capabilities provide an "equivalent level of safety" or better when operating a UAS for the public

interest as outlined in Section 333 of the Reform Act. It is requested that the FAA issue an 

exemption to permit safe, legal, commercial UAS operation by the applicant as soon as 

possible.

Respectfully submitted,

Attn: Nathan R. Huntoon

Ph: 972-971-6491

Email: nathan.huntoon@aerialnetinc.com

Address: 4702 Grant Ct

Frisco, TX, 750035
Appendix A

EXEMPTION REQUESTS AND EQUIVALENT LEVEL OF SAFETY

The applicant requests an exemption from the following regulations as well as any

additional regulations that may technically apply to the operation of UAS’s:

14 CFR Part 21, Subpart H: Airworthiness Certificates

14 CFR § 91.203(a)(1)

Section 91.203(a)(1) requires all civil aircraft to have a certificate of airworthiness. Part 21,

Subpart H, entitled Airworthiness Certificates, establishes the procedural requirements for the

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

aircraft (less than 55 lbs.) and the limited operating area associated with its utilization, it is

unnecessary to go through the certificate of airworthiness process under Part 21 Subpart H to

achieve or exceed current safety levels.

Such an exemption meets the requirements of an equivalent level of safety under Part 11 and

Section 333 of the Reform Act. The Federal Aviation Act and Section 333 of the Reform Act

both authorize the FAA to exempt aircraft from the requirement for an airworthiness certificate,

upon consideration of the size, weight, speed, operational capability, and proximity to airports

and populated areas of the UAS involved.

In this case, an analysis of these criteria demonstrates that the UAS operated without an 

airworthiness certificate, under the conditions proposed herein, will be at least as safe, or safer,

than a conventional aircraft (fixed wing or rotorcraft) with an airworthiness certificate. The UAS

weighs typically less than 55 lbs. fully loaded. It will not carry a pilot or passenger, and will

operate exclusively within an area pre-disclosed and in compliance with conditions set forth

herein. Operations under this exemption will be tightly controlled and monitored by both the

operator, pursuant to the conditions set forth above, and by local public safety requirements.

The FAA will have advance notice of all operations through the filing of NOTAMs. Receipt of

the prior permission of the land owner, the size of the aircraft, the minimization of flammable

fuel, and the fact that the aircraft is carried to the location and not flown there all establish the

equivalent level of safety. The UAS provides at least an equivalent, and most likely exceeds,

level of safety to that of such operations being conducted with conventional aircraft that

would be orders-of-magnitude larger and would be carrying passengers, cargo, and

flammable fuel.
14 CFR. § 45.23 & 91.9(c): Marking of the Aircraft

Regulation 45.23 provides:

(a) Each operator of an aircraft must display on that aircraft marks

consisting of the Roman capital letter “N” (denoting United States registration)

followed by the registration number of the aircraft. Each suffix letter used in

the marks displayed must also be a Roman capital letter.

(b) When marks include only the Roman capital letter “N” and the registration

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

experimental or provisionally certificated aircraft, the operator must also

display on that aircraft near each entrance to the cabin, cockpit, or pilot

station, in letters not less than 2 inches nor more than 6 inches high, the words

“limited,” “restricted,” “light­sport,” “experimental,” or “provisional,” as applicable.

Regulation 91.9(c) provides:

No person may operate a U.S.-registered civil aircraft unless that aircraft is

identified in accordance with part 45 of this chapter.

The UAS has no entrance to the cabin, cockpit, or pilot station on which the markings can be 

placed. Given the size of the UAS, two-inch lettering will be impossible. W hile official marking

systems for UAS have not yet been established for operations inside the NAS we wish to 

ensure the spirit of the regulation is still followed. All UAS operated will have an engraved 

aluminum plate with corporate contact information, and a serial number unique to each UAS 

attached. This plate will be as large as is possible without compromising the safe operation of the 

UAS. The applicant is prepared to mark the UAS with the name of the organization and

location or origin and fulfill any other request by the FAA to this topic in accordance to §

45.29(f) where the pilot, observer, and others working with the UAS will see the identification of

the UAS.

The FAA has issued the following exemptions to this regulation; see Exemption Nos. 8738,

10167, 10167A and 10700.

14 CFR § 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 UAS 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 an aircraft for compensation or hire.

The applicant respectfully proposes that operator requirements should take into account the

characteristics of the particular UAS as well as the relative risk associated with UAS operations 
vs convential aircraft. Hands-on experience with the UAS are a far more effective guarantee of 

flight safety than a commercial pilot certificate would be, until the FAA Pilot Certificate 

requirements catch up to the UAS technology.

The flight control systems on UAS provide significant safety features, such as return to home 

(RTH) during GPS loss, or Control Link Loss. In the event these features fail though, our UAS 

operators will have demonstrated manual flight capability to safely land a UAS. As UAS operations 

will never have the UAS leave the LOS of the PIC, this additional backup provides ample safety. 

A commercial pilot’s license will not provide these skills as they are unique to UAS.

As the UAS will operate in the NAS though, safe operations require a working knowledge of the 

NAS and the rules that govern it. Towards that end, we will require that any PIC have at minimum 

a working knowledge of the rules governing the NAS. Our training program will include instruction

in 14 C.F.R § 61, 71, 73, and 91. Once the FAA establishes a UAS certification, all PICs will be 

required to hold a certification. In addition, the PIC and VO will be required to either have a class 

3 medical permit from the FAA, or a state issued drivers license to ensure they are physically and 

mentally capable of operating a UAS. All operators will abide by any medical conditions on their 

license (such as corrective lenses). 

The applicant notes that the FAA has mentioned that a pilot certificate subjects the pilot to a 

security screening by the Department of Homeland Security. To satisfy this requirement, while 

not obtaining a pilot certificate, the applicant will require all UAS pilots to undergo an equivalent 

or better security screening.

The applicant notes that the FAA has found that safety factors permitted operation of UASs

by operators with these qualifications in the case of operations pursuant to public COAs

where the mandatory operating conditions specified above are present. See Federal Aviation

Administration, Notice N-8900.227, Unmanned Aircraft Systems (UAS) Operational Approval,

at 20-21 (July 30, 2013). The FAA has the statutory authority, granted at 49 U.S.C.§44701(f) to 

waive the pilot requirements for commercial operations.

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

allowing operation of the UAS without a commercial pilot’s certificate, under the conditions set

forth herein.

The risks associated with the operation of the UAS (given its size, speed, 

operational capabilities, and lack of combustible fuel) are so diminished from the level of

risk associated with private pilot operations or 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).

14 CFR § 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 UAS without an 

airworthiness certificate, no standard will exist for airworthiness of the UAS. Given the size

of the UAS and the previous COAs issued for similar UAS, an equivalent level of safety will

be achieved by ensuring compliance with the given UAS manuals and use of safety checklists 

prior to each flight.

14 CFR § 91.9(b)(2): Civil Aircraft Flight Manual in the Aircraft.

The regulation provides:

No person may operate a U.S.-registered civil aircraft ...

(2) For which an Airplane or Rotorcraft Flight Manual is not required by §21.5 of 

this chapter, unless there is available in the aircraft a current approved airplane

or Rotorcraft Flight Manual, approved manual material, markings, and

placards, or any combination thereof.

Given the size of UAS, they have no ability or place to carry such a flight manual on the

aircraft, not only because there is no pilot on board, but because there is no room or capacity

to carry such an item on the aircraft.

The equivalent level of safety will be achieved by keeping the flight manual at the ground

control point where the PIC flying the UAS will have immediate access to it. The FAA has

issued to others the following exemptions to this regulation: Exemption Nos. 8607, 8737, 8738,

9299, 9299A, 9565, 9565B, 10167, 10167A, 10602, 32827, and 10700.

14 CFR § 91.103: Preflight action

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

safety of flight. As FAA approved rotorcraft flight manuals will not be provided for the aircraft an

exemption will be needed. An equivalent level of safety will be provided by following a 

comprehensive preflight checklist. The PIC will take all actions including reviewing weather, 

flight battery requirements, landing and takeoff distances and aircraft performance data 

before initiation of flight as outlined in our Operations Manual.
14 CFR § 91.109(a) & 91.319(a)(1): Flight Instruction

These regulations provide that no person may operate a civil aircraft (except a manned free

balloon) that is being used for flight instruction unless that aircraft has fully functioning dual

controls.

The UAS are remotely piloted aircraft and by design, do not have fully functional dual controls. 

Flight control is accomplished through the use of a control box that communicates with the

aircraft via radio communications. The flight plan is either manually controlled through pointand-click navigation or preprogrammed as way points into the auto pilot before or during

flight and only in unusual circumstances will the pilot input control functions to alter the

pre-programmed flight. Given the size and speed of the UAS, an equivalent level of safe training 

can still be performed without dual controls because no pilot or passengers are aboard the UAS, 

and all persons will be a safe distance away should the UAS experience any difficulties during 

flight instruction. The FAA has approved exemptions for flight training without fully functional

dual controls for a number of aircraft and for flight instruction in experimental aircraft. See 

Exemption Nos. 5778K & 9862A.

14 CFR § 91.119: 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.

Because aerial survey, mapping and inspection 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 UAS are built. Also, no flight will be taken without the permission of the land owner

or those who control the land. Because of the advance notice to the landowner, all affected

individuals will be aware of the flights. Compared to aerial survey operations conducted 

with aircraft or rotorcraft weighing far more than 55 lbs. and carrying flammable fuel, any risk

associated with these operations will be far less than those currently allowed with

conventional aircraft operating at or below 500 feet AGL. Indeed, the low-altitude operations 

of the UAS will maintain separation between these UAS operations and the operations of

conventional aircraft that must comply with Section 91.119.
14 CFR § 91.121: Altimeter Settings

Section 91.121 requires a person operating an aircraft to maintain cruising altitude or flight level 

by reference to an altimeter that is set to the elevation of the departure airport or barometric 

pressure. While our UAS may have a barometric pressure sensor, it is “zeroed” at the point of 

take-off; this is right next to the PIC and not at a departure airport. Given the small operational 

envelope of UAS, and limiting operations to LOS of the PIC, the variance from measured AGL 

and actual AGL is either negligible, or can be compensated for by the PIC during flight 

operations. In addition, flight plans will be prepared prior to any flight using the most recent 

publicly available 3D maps. Any relevant ground attitude changes will be noted and 

accommodated for flight operations. 

The equivalent level of safety will be achieved by the PIC confirming the elevation or altitude of 

the launch site. The altitude of the UAS will also be displayed via telemetry on the Ground Station 

and will be constantly monitored by the PIC during the entire flight operation.

14 CFR § 91.151(a): Fuel Requirements for 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 different UAS batteries provide a variety of powered flight times. An exemption from § 14

CFR 91.151 is therefore required.

The applicant believes that an exemption from 14 CFR § 91.151(a) is safe and within the

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

operate without compliance with 91.151(a)). Operating the UAS, without 30 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. In the unlikely event that the UAS should run out of fuel, it

would simply land. Given its weight and construction material, the risks are less than

contemplated by the current regulation.

The applicant believes that an equivalent level of safety can be achieved by maintaining 20% of

reserve fuel (or battery) dedicated to flight and 20% reserve power dedicated to flight controls. 

This will be more than adequate to return the UAS to its planned landing zone from anywhere

in its operating area.
The FAA has granted similar exemptions to others, including Exemptions 2689F, 5745,

10673 and 10808.

14 CFR § 91.203 (a) & (b): Carrying Civil Aircraft Certification and Registration

This regulation provides as follows:

(a) ... no person may operate a civil aircraft unless it has ... an appropriate

and current airworthiness certificate.

(b) No person may operate a civil aircraft unless the airworthiness certificate

required by paragraph (a) of this section or a special flight authorization issued

under §91.715 is displayed at the cabin or cockpit entrance so that it is legible

to passengers or crew.

The UAS fully loaded weigh less than 55 lbs. As such, there is no ability or place to carry 

certification and registration documents or to display them on the UAS. In addition, there is no

pilot on board the aircraft.

An equivalent level of safety will be achieved by keeping these documents at the ground

control point where the PIC flying the UAS will have immediate access to them. The FAA has

issued numerous exemptions to this regulation. A representative sample of other exceptions

includes Exemption Nos. 9565, 9665, 9789, 9789A, 9797, 9797A, 9816A, and 10700.

14 CFR § 91.405(a); 407(a)(1); 409(a)(2); 417(a): 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 discrepancies repaired 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 air worthiness 

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.

Our UAS will undergo regular maintenance checks as dictated by their manuals. In addition to any 

manufacturer recommended checks, we will be additional checks on a fixed period bases. These 

checks will inspect any flight critical components for wear or damage, as well as operational 

checks of the flight control systems. A shake down flight will be done after each inspection in a 

controlled environment away from the general public. Written logs of each inspection and any 

maintenance done will be kept with the UAS at all dimes. 
Prior to any commercial flight, a pre-flight checklist will be completed by the PIC as described in 

the Operational Manual. 

Pre­flight checklist includes:

1. Visual inspection of the airframe

2. Visual inspections of rotor integrity

3. Check charge of all batteries (aerial vehicle, command station, radio repeater station)

An equivalent level of safety will be achieved because the UAS is small in size, will carry no

external payload, will operate only in restricted predetermined areas and is not a complex

mechanical devise. The operator of a UAS will ensure that it 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.

If mechanical issues arise, the UAS can land immediately due to the pre-determined area of 

operation. All PICs will be trained in operations of UAS suffering from the ‘common’ types of 

mechanical failure. Moreover, the UAS's small size, carrying capacity, and the fact that flight 

operations will only take place in restricted areas for limited periods of time, create less risk than 

the same factors associated with conventional fixed-wing aircraft and rotorcraft performing the 

same operation.
APPENDIX B

SUMMARY OF SECTION 333 EXEMPTION REQUEST

Aerial NET Inc hereby provides pursuant to Part 11 a summary of its exemption application to 

allow commercial operation of UAS for aerial acquisition and research in support of government 

entities, agriculture industry, utility companies, local infrastructure, scientific studies, wildlife 

monitoring, mining, surveying, forestry, and much more. All of which are critical to the well-being 

of the general public. An exemption is requested from the following regulations:

14 C.F.R. Part 21;

14 C.F.R. 45.23(b);

14 C.F.R. 61.113(a) & (b);

14 C.F.R. 61.133(a);

14 C.F.R. 91.7(a);

14 C.F.R. 91.9(b)(2) & (c);

14 C.F.R. 91.103;

14 C.F.R. 91.109(a);

14 C.F.R. 91.119;

14 C.F.R. 91.121;

14 C.F.R. 91.151(a);

14 C.F.R. 91.203(a) & (b);

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).