August 11, 2015

Exemption No. 12410

Regulatory Docket No. FAA–2015–2185

Mr. Timothy Ford

President and CEO

UAS Innovators, LLC

11523 Palmbrush Trail, Suite 353

Lakewood Ranch, FL 34202

Dear Mr. Ford:

This letter is to inform you that we have granted your request for exemption. It transmits our 

decision, explains its basis, and gives you the conditions and limitations of the exemption, 

including the date it ends.

By letter dated May 20, 2015, you petitioned the Federal Aviation Administration (FAA) on 

behalf of UAS Innovators, LLC (hereinafter petitioner or operator) for an exemption. The 

petitioner requested to operate an unmanned aircraft system (UAS) to conduct aerial 

photography and videography, agricultural surveying and application, sUAS operator 

training1, product demonstrations, and research and development.

See Appendix A for the petition submitted to the FAA describing the proposed operations and 

the regulations that the petitioner seeks an exemption.

The FAA has determined that good cause exists for not publishing a summary of the petition 

in the Federal Register because the requested exemption would not set a precedent, and any 

delay in acting on this petition would be detrimental to the petitioner.

 

1 The petitioner requested authority to conduct UAS training. At this time, the FAA is unable to authorize UAS 

operations for training until a further assessment is completed. When the FAA completes its review, we will 

proceed accordingly and no further action will be required by the petitioner. However, the petitioner is permitted 

to train its own pilot in commands and visual observers in accordance with condition no. 14 and the other 

conditions and limitations in this exemption.
2

Airworthiness Certification

The UAS proposed by the petitioner are the DJI Phantom 2, DJI Phantom 2 Vision, DJI 

Phantom 2 Vision+, DJI Inspire, DJI S1000, DJI S900, DJI Flamewheel 550, eBee AG, 

3DRobotics IRIS+, RF-70, DJI Phantom 3 Professional, and DJI Phantom 3 Advanced.

In accordance with the statutory criteria provided in Section 333 of Public Law 112−95 in 

reference to 49 U.S.C. § 44704, and in consideration of the size, weight, speed, and limited 

operating area associated with the aircraft and its operation, the Secretary of Transportation 

has determined that this aircraft meets the conditions of Section 333. Therefore, the FAA 

finds that relief from 14 CFR part 21, Certification procedures for products and parts, 

Subpart H—Airworthiness Certificates, and any associated noise certification and testing 

requirements of part 36, is not necessary.

The Basis for Our Decision

You have requested to use a UAS for aerial data collection2. The FAA has issued grants of 

exemption in circumstances similar in all material respects to those presented in your petition. 

In Grants of Exemption Nos. 11062 to Astraeus Aerial (see Docket No. FAA−2014−0352), 

11109 to Clayco, Inc. (see Docket No. FAA−2014−0507), 11112 to VDOS Global, LLC (see

Docket No. FAA−2014−0382), and 11213 to Aeryon Labs, Inc. (see Docket No. 

FAA−2014−0642), the FAA found that the enhanced safety achieved using an unmanned 

aircraft (UA) with the specifications described by the petitioner and carrying no passengers or 

crew, rather than a manned aircraft of significantly greater proportions, carrying crew in 

addition to flammable fuel, gives the FAA good cause to find that the UAS operation enabled 

by this exemption is in the public interest.

Having reviewed your reasons for requesting an exemption, I find that—

 They are similar in all material respects to relief previously requested in Grant of 

Exemption Nos. 11062, 11109, 11112, and 11213;

 The reasons stated by the FAA for granting Exemption Nos. 11062, 11109, 11112, and 

11213 also apply to the situation you present; and 

 A grant of exemption is in the public interest.

Our Decision

In consideration of the foregoing, I find that a grant of exemption is in the public interest. 

Therefore, pursuant to the authority contained in 49 U.S.C. 106(f), 40113, and 44701, 

 

2 Aerial data collection includes any remote sensing and measuring by an instrument(s) aboard the UA. 

Examples include imagery (photography, video, infrared, etc.), electronic measurement (precision surveying, RF 

analysis, etc.), chemical measurement (particulate measurement, etc.), or any other gathering of data by 

instruments aboard the UA.
3

delegated to me by the Administrator, UAS Innovators, LLC is granted an exemption from 

14 CFR §§ 61.23(a) and (c), 61.101(e)(4) and (5), 61.113(a), 61.315(a), 91.7(a), 91.119(c), 

91.121, 91.151(a)(1), 91.405(a), 91.407(a)(1), 91.409(a)(1) and (2), and 91.417(a) and (b), to 

the extent necessary to allow the petitioner to operate a UAS to perform aerial data collection. 

This exemption is subject to the conditions and limitations listed below.

Conditions and Limitations

In this grant of exemption, UAS Innovators, LLC is hereafter referred to as the operator.

Failure to comply with any of the conditions and limitations of this grant of exemption will be 

grounds for the immediate suspension or rescission of this exemption.

1. Operations authorized by this grant of exemption are limited to the DJI Phantom 2, 

DJI Phantom 2 Vision, DJI Phantom 2 Vision+, DJI Inspire, DJI S1000, DJI S900, 

Flamewheel 550, eBee AG, 3DRobotics IRIS+, RF-70, DJI Phantom 3 Professional, 

and DJI Phantom 3 Advanced when weighing less than 55 pounds including payload. 

Proposed operations of any other aircraft will require a new petition or a petition to 

amend this exemption.

2. Operations for the purpose of closed-set motion picture and television filming are 

not permitted. 

3. The UA may not be operated at a speed exceeding 87 knots (100 miles per hour). The 

exemption holder may use either groundspeed or calibrated airspeed to determine 

compliance with the 87 knot speed restriction. In no case will the UA be operated at 

airspeeds greater than the maximum UA operating airspeed recommended by the 

aircraft manufacturer.

4. The UA must be operated at an altitude of no more than 400 feet above ground level 

(AGL). Altitude must be reported in feet AGL.

5. The UA must be operated within visual line of sight (VLOS) of the PIC at all times. 

This requires the PIC to be able to use human vision unaided by any device other than 

corrective lenses, as specified on the PIC’s FAA-issued airman medical certificate or 

U.S. driver’s license.

6. All operations must utilize a visual observer (VO). The UA must be operated within 

the visual line of sight (VLOS) of the PIC and VO at all times. The VO may be used 

to satisfy the VLOS requirement as long as the PIC always maintains VLOS 

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

electronic messaging or texting is not permitted during flight operations. The PIC 

must be designated before the flight and cannot transfer his or her designation for the 
4

duration of the flight. The PIC must ensure that the VO can perform the duties 

required of the VO.

7. This exemption and all documents needed to operate the UAS and conduct its 

operations in accordance with the conditions and limitations stated in this grant of 

exemption, are hereinafter referred to as the operating documents. The operating 

documents must be accessible during UAS operations and made available to the 

Administrator upon request. If a discrepancy exists between the conditions and 

limitations in this exemption and the procedures outlined in the operating documents, 

the conditions and limitations herein take precedence and must be followed. 

Otherwise, the operator must follow the procedures as outlined in its operating 

documents. The operator may update or revise its operating documents. It is the 

operator’s responsibility to track such revisions and present updated and revised 

documents to the Administrator or any law enforcement official upon request. The 

operator must also present updated and revised documents if it petitions for extension 

or amendment to this grant of exemption. If the operator determines that any update 

or revision would affect the basis upon which the FAA granted this exemption, then 

the operator must petition for an amendment to its grant of exemption. The FAA’s 

UAS Integration Office (AFS−80) may be contacted if questions arise regarding 

updates or revisions to the operating documents.

8. Any UAS that has undergone maintenance or alterations that affect the UAS operation 

or flight characteristics, e.g., replacement of a flight critical component, must undergo 

a functional test flight prior to conducting further operations under this exemption. 

Functional test flights may only be conducted by a PIC with a VO and must remain at 

least 500 feet from other people. The functional test flight must be conducted in such 

a manner so as to not pose an undue hazard to persons and property.

9. The operator is responsible for maintaining and inspecting the UAS to ensure that it is 

in a condition for safe operation.

10. Prior to each flight, the PIC must conduct a pre-flight inspection and determine the 

UAS is in a condition for safe flight. The pre-flight inspection must account for all 

potential discrepancies, e.g., inoperable components, items, or equipment. If the 

inspection reveals a condition that affects the safe operation of the UAS, the aircraft is 

prohibited from operating until the necessary maintenance has been performed and the 

UAS is found to be in a condition for safe flight.

11. The operator must follow the UAS manufacturer’s maintenance, overhaul, 

replacement, inspection, and life limit requirements for the aircraft and 

aircraft components.

12. Each UAS operated under this exemption must comply with all manufacturer 

safety bulletins.
5

13. Under this grant of exemption, a PIC must hold either an airline transport, 

commercial, private, recreational, or sport pilot certificate. The PIC must also hold a 

current FAA airman medical certificate or a valid U.S. driver’s license issued by a 

state, the District of Columbia, Puerto Rico, a territory, a possession, or the Federal 

government. The PIC must also meet the flight review requirements specified in 

14 CFR § 61.56 in an aircraft in which the PIC is rated on his or her pilot certificate.

14. The operator may not permit any PIC to operate unless the PIC demonstrates the 

ability to safely operate the UAS in a manner consistent with how the UAS will be 

operated under this exemption, including evasive and emergency maneuvers and 

maintaining appropriate distances from persons, vessels, vehicles and structures. PIC 

qualification flight hours and currency must be logged in a manner consistent with 

14 CFR § 61.51(b). Flights for the purposes of training the operator’s PICs and VOs 

(training, proficiency, and experience-building) and determining the PIC’s ability to 

safely operate the UAS in a manner consistent with how the UAS will be operated 

under this exemption are permitted under the terms of this exemption. However, 

training operations may only be conducted during dedicated training sessions. During 

training, proficiency, and experience-building flights, all persons not essential for 

flight operations are considered nonparticipants, and the PIC must operate the UA 

with appropriate distance from nonparticipants in accordance with 14 CFR § 91.119.

15. UAS operations may not be conducted during night, as defined in 14 CFR § 1.1. All 

operations must be conducted under visual meteorological conditions (VMC). Flights 

under special visual flight rules (SVFR) are not authorized.

16. The UA may not operate within 5 nautical miles of an airport reference point (ARP) as 

denoted in the current FAA Airport/Facility Directory (AFD) or for airports not 

denoted with an ARP, the center of the airport symbol as denoted on the current 

FAA-published aeronautical chart, unless a letter of agreement with that airport’s 

management is obtained or otherwise permitted by a COA issued to the exemption 

holder. The letter of agreement with the airport management must be made available 

to the Administrator or any law enforcement official upon request.

17. The UA may not be operated less than 500 feet below or less than 2,000 feet 

horizontally from a cloud or when visibility is less than 3 statute miles from the PIC.

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

pre-determined location within the private or controlled-access property.

19. The PIC must abort the flight in the event of unpredicted obstacles or emergencies.

20. The PIC is prohibited from beginning a flight unless (considering wind and forecast 

weather conditions) there is enough available power for the UA to conduct the 
6

intended operation and to operate after that for at least five minutes or with the reserve 

power recommended by the manufacturer if greater.

21. Air Traffic Organization (ATO) Certificate of Waiver or Authorization (COA). All 

operations shall be conducted in accordance with an ATO-issued COA. The 

exemption holder may apply for a new or amended COA if it intends to conduct 

operations that cannot be conducted under the terms of the attached COA.

22. All aircraft operated in accordance with this exemption must be identified by serial 

number, registered in accordance with 14 CFR part 47, and have identification 

(N−Number) markings in accordance with 14 CFR part 45, Subpart C. Markings must 

be as large as practicable.

23. Documents used by the operator to ensure the safe operation and flight of the UAS and 

any documents required under 14 CFR §§ 91.9 and 91.203 must be available to the 

PIC at the Ground Control Station of the UAS any time the aircraft is operating. 

These documents must be made available to the Administrator or any law enforcement 

official upon request.

24. The UA must remain clear and give way to all manned aviation operations and 

activities at all times. 

25. The UAS may not be operated by the PIC from any moving device or vehicle. 

26. All Flight operations must be conducted at least 500 feet from all nonparticipating 

persons, vessels, vehicles, and structures unless:

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

from the UA and/or debris in the event of an accident. The operator must ensure 

that nonparticipating persons remain under such protection. If a situation arises 

where nonparticipating persons leave such protection and are within 500 feet of 

the UA, flight operations must cease immediately in a manner ensuring the safety 

of nonparticipating persons; and

b. The owner/controller of any vessels, vehicles or structures has granted permission 

for operating closer to those objects and the PIC has made a safety assessment of 

the risk of operating closer to those objects and determined that it does not 

present an undue hazard.

The PIC, VO, operator trainees or essential persons are not considered 

nonparticipating persons under this exemption.

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

permission from the property owner/controller or authorized representative. 

Permission from property owner/controller or authorized representative will be 

obtained for each flight to be conducted.
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28. Any incident, accident, or flight operation that transgresses the lateral or vertical 

boundaries of the operational area as defined by the applicable COA must be reported 

to the FAA's UAS Integration Office (AFS−80) within 24 hours. Accidents must be 

reported to the National Transportation Safety Board (NTSB) per instructions 

contained on the NTSB Web site: www.ntsb.gov.

If this exemption permits operations for the purpose of closed-set motion picture and 

television filming and production, the following additional conditions and limitations apply.

29. The operator must have a motion picture and television operations manual (MPTOM) 

as documented in this grant of exemption.

30. At least 3 days before aerial filming, the operator of the UAS affected by this 

exemption must submit a written Plan of Activities to the local Flight Standards 

District Office (FSDO) with jurisdiction over the area of proposed filming. The 3-day 

notification may be waived with the concurrence of the FSDO. The plan of activities 

must include at least the following:

a. Dates and times for all flights;

b. Name and phone number of the operator for the UAS aerial filming conducted 

under this grant of exemption;

c. Name and phone number of the person responsible for the on-scene operation of 

the UAS;

d. Make, model, and serial or N−Number of UAS to be used;

e. Name and certificate number of UAS PICs involved in the aerial filming;

f. A statement that the operator has obtained permission from property owners 

and/or local officials to conduct the filming production event; the list of those 

who gave permission must be made available to the inspector upon request;

g. Signature of exemption holder or representative; and

h. A description of the flight activity, including maps or diagrams of any area, city, 

town, county, and/or state over which filming will be conducted and the altitudes 

essential to accomplish the operation.

31. Flight operations may be conducted closer than 500 feet from participating persons 

consenting to be involved and necessary for the filming production, as specified in the 

exemption holder’s MPTOM.

Unless otherwise specified in this grant of exemption, the UAS, the UAS PIC, and the UAS 

operations must comply with all applicable parts of 14 CFR including, but not limited to, 

parts 45, 47, 61, and 91.
8

This exemption terminates on August 31, 2017, unless sooner superseded or rescinded.

Sincerely,

/s/

John S. Duncan

Director, Flight Standards Service

Enclosures
UAS Innovators LLC 11523 Palmbrush Trail Suite 353 Lakewood Ranch, FL 34202

May 20, 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

Dear Sir/Madam,

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the Reform Act), and 14

C.F.R. Part 11, UAS Innovators LLC (UASI), a Florida based limited liability company operating Small 

Unmanned Aircraft System (sUAS) equipped to conduct aerial photography and survey for various 

industries, hereby applies for an exemption from the Federal Aviation Regulations (FARs) listed below to 

allow operation of our sUAS commercially in airspace regulated by the Federal Aviation Administration 

(FAA) so long as such operations are conducted with and under the conditions outlined herein or as may

be established by the FAA as required by Section 333. The requested exemption is similar to previous 

FAA issued grants of exemption including but not limited to Exemption Nos. 11062, 11109, 11112, 

11213 and 11295.

Our commercial activities would include:

The requested exemption would permit UAS Innovators LLC to pursue its commercial interests in 

providing services to consumers interested in training, research, and aerial data capture using a small 

advanced sUAS in the following areas:

 Aerial Photography and Videography for the real estate, construction, and utilities industries

 Agricultural Surveying and Application

 sUAS Operator Training

 Product Demonstrations

 Research and Development

All UASI sUAS flights that will occur over private or controlled access property will do so with the 

property owner's prior consent and knowledge. Only people who have consented or otherwise have agreed 

to be in the area where photography and videography will take place will be captured in any photos or 

videos.
UAS Innovators LLC 11523 Palmbrush Trail Suite 353 Lakewood Ranch, FL 34202

Additionally, all UAS Innovators pilots will hold an airline transport, commercial, private, recreational, or 

sport pilot certificate and also hold a current FAA airman medical certificate or a valid U.S. driver’s 

license issued by a state, the District of Colombia, Puerto Rico, a territory, a possession, or the Federal 

government. If an observer is not a qualified pilot, they will be trained by UASI pilots to understand the 

proper roles of an observer, communication procedures, proper visual scan techniques, operations at nontowered airports, and appropriate sections of the Aeronautical Information Manual.

The Petitioner Requests Relief From the following regulations:

Regulations from which the exemption is requested: 14 CFR §§ 61.23(a) and (c), 61.101(e)(4) and (5), 

61.113(a), 61.315(a), 91.7(a), 91.109, 91.119(c), 91.121, 91.151(a)(1), 91.215, 91.405(a), 91.407(a)(1), 

91.409(a)(1) and (2), and 91.417(a) and (b), to the extent necessary to allow UASI to operate a UAS to 

perform training, research, and aerial data collection.

We are petitioning for exemption to enable UASI to operate a series of UAS platforms that have been 

previously approved by exemption. Namely:

DJI Phantom 2 - Exemption 11398

DJI Phantom 2 Vision - Exemption 11310

DJI Phantom 2 Vision+ - Exemption 11398

DJI Inspire - Exemption 11398

DJI S1000 - Exemption 11416

DJI S900 - Exemption 11401

Flamewheel 550 - Exemption 11397

eBee AG - Exemption 11339

3DRobotics IRIS+ - Exemption 11419

RF-70 - Exemption 11295

DJI Phantom 3 Professional - Similar to Exemption 11310

DJI Phantom 3 Advanced - Similar to Exemption 11398

These sUAS all weigh less than 55 lbs,, have a built- in capability to limit the height flown above the

ground, to limit the radius of the distance it flies from the operator and to exclude it from Class B, C and

D airspace including a no fly zone feature. Each system also has the failsafe function of the autopilot

system, which means when the communication between the Main Controller and the transmitter is lost,

the system will automatically trigger Return to Home and will land safely.

This submission does not include the Operating Manuals for each model requested above, as they have 

been reviewed by the Administrator in granting previous exemptions. Model specifics are listed in the 

UASI Operating Manual which is included with this submission. Copies of all Operating Manuals for the 

individual models listed will be submitted on request. It should be noted, that while the FAA has not 

previously granted an exemption for the DJI Phantom 3 series, it is an upgraded version of the DJI 

Phantom 2 including components pioneered by DJI with the Inspire 1.
UAS Innovators LLC 11523 Palmbrush Trail Suite 353 Lakewood Ranch, FL 34202

The above specifications meet standards listed below:

• UASI will only operate its sUAS in line of sight of a pilot and/or observer and will operate at sites 

that are a 'sufficient distance' from populated areas within the sterile area described in the operator’s

manual. Such operations will insure that the sUAS will "not create a hazard to users of the national 

airspace system or the public."

• UASI will not operate sUAV within 5 nautical miles of an airport reference point (ARP) as denoted 

in the current FAA Airport/Facility Directory (AFD), unless a letter of agreement with that airport’s 

management is obtained or otherwise permitted by a COA issued to UASI. 

• Maximum flight time for each operational flight will be 60 minutes.

• Flights will be terminated at 25% battery power reserve should that occur prior to the 60 minute limit.

• The sUAV will be programmed so that it will not be operated at an altitude of no more than 400 feet

AGL.

• Minimum crew for each operation will consist of the sUAS Pilot and the Visual Observer.

• The sUAS PIC's (Pilot in Command) will be an airline transport, commercial, private, recreational, or 

sport pilot certificate and also hold a current FAA airman medical certificate or a valid U.S. driver’s 

license issued by a state, the District of Colombia, Puerto Rico, a territory, a possession, or the 

Federal government.

• The sUAS operated by the petitioner weighs less than 55 pounds, including the payload (i.e. camera,

lens, and gimbal).

• The sUAS will operate at speeds of no more than 55 knots.

• Given the small size of the sUAS and the restricted sterile environment within which they will

operate, our sUAS operations adhere to the Reform Act's safety requirements.

Additionally, the fact that the UASI pilots hold FAA Pilot certificates demonstrates that they have a high 

regard to safe operations with an understanding of FARs, pre-flight inspections, maintenance and repair,

operations within airspace, as well as being trained to high safety standards .

Under the requested exemption, UASI will ensure that all operators have completed a small unmanned 

aircraft systems (UAS) education and training program including all applicable regulations and guidance

documents; including aeronautical background information such as charts, NOTAMS and Aircraft

Circulars; Radio Communications Procedures; Human Factors and Crew Resource Management; Basic 

Small UAS Aerodynamics; Weather factors; Airmanship and Decision-making and Safe Operating

Procedures.

We respectfully request exemption under Section 333 to enable UASI to operate safe, low-risk 

commercial sUAV operations for the activities stated. RFS at all times will respect the space and privacy

of citizens and property whilst keeping our skies safe.

Exemption Requests and Equivalent Level of Safety

UASI requests an exemption from the following regulations as well as any additional regulations that may

technically apply to the operation of the sUAV System:
UAS Innovators LLC 11523 Palmbrush Trail Suite 353 Lakewood Ranch, FL 34202

14 CFR 61.23 Medical Certificates

The regulation provides that a person requires a first or second class medical to act as pilot in Command 

of an aircraft for compensation or hire. Our proposed operations require that the PIC must hold a current 

FAA airman medical certificate or a valid U.S. driver’s license issued by a state, the District of Colombia, 

Puerto Rico, a territory, a possession, or the Federal government. Since the aircraft cannot carry

passengers or property, we feel we meet the intent of 61.23 even though the intent of this application is to 

conduct a business.

14 CFR 61.101, 14 CFR 61.113, and 14 CFR 61.315 Pilot privileges and Limitations

The regulation provides that no person that holds a Recreational Pilot, Sport Pilot, or Private Pilot

certificate may act as pilot in Command of an aircraft for compensation or hire. Our proposed operations 

require that the PIC must hold at least airline transport, commercial, private, recreational, or sport pilot 

certificate. Since the aircraft cannot carry passengers or property, we feel we meet the intent of 61.113

Subparagraph (b) even though the intent of this application is to conduct a business.

14 CFR 91.7 Civil Aircraft Airworthiness

This Section prohibits the operation of an aircraft without an airworthiness certificate. As no such 

certificate will be applicable in the form contemplated by the FARs, this Regulation is inapplicable.

14 CFR 91.109 Flight Instruction; Simulated instrument flight and certain flight tests

The regulation states that "No person may operate a civil aircraft that is being used for flight Instruction 

unless that aircraft has fully functioning dual controls." Training will be conducted by Aerial Optics we 

have the ability to provide dual controls utilizing two Spektrum transmitters with a wireless link between 

the transmitters. One transmitter is designated the master transmitter and the other transmitter is 

designated as a slave. The PIC instructor, utilizing the master transmitter, will be at all times be able 

assume control of the sUAS.

14 CFR 91.119 Minimum safe altitudes: General

The regulation states that over sparsely populated areas the aircraft cannot be operated closer than 500 feet

to any person, vessel, vehicle, or structure. Since the typical mission of the sUAS would be photography

or survey of persons, vessels, vehicles or structures it would be necessary to operate closer than 500 feet

to the items listed. Operations will only be flown over property or persons where permission has been 

obtained and careful pre-planned has been performed. The aircraft will be operated at a low altitude 

allowing, if a power unit fails, an emergency landing without undue hazard to persons or property on the 

surface. Therefore we maintain that due to the small size of the UAS, the hazard to persons, vehicles and 

structures is minimal compared to manned aircraft, which should be considered in granting the exemption.
UAS Innovators LLC 11523 Palmbrush Trail Suite 353 Lakewood Ranch, FL 34202

14 CFR 91.121 Altimeter settings

The regulation requires that aircraft shall maintain cruising altitudes by reference to an altimeter setting 

available within 100 NM of the aircraft. The sUAS will always fly below 400 feet AGL and will not need 

to maintain cruising altitudes in order to prevent conflict with other aircraft. An Above Ground Level 

altimeter measurement above the takeoff point is transmitted via radio from the sUAS on-board computer

to the display screen held by the PIC, providing a constantly updated AGL readout.

14 CFR 91.151 Fuel requirements for flight in VFR conditions

The regulation provides that no person may begin a flight in an airplane under day-VFR conditions unless 

there is enough fuel to fly to the first point of intended landing and to fly after that for at least 30 minutes.

We feel the intention of this paragraph is to provide an energy reserve as a safety buffer for delays to 

landing. The sUAS are battery operated and the maximum duration of flight from a single battery charge 

is 12-45 (depending on which sUAS) minutes with a 20% reserve. Since the aircraft will never fly more

than 1/2 NM from the point of intended landing, a full battery charge at launch will ensure that we meet

the reserve energy requirement of this paragraph. We request an exemption to the word "fuel" and ask for

an equivalent interpretation with the word "energy". We also request exemption from the 30 min reserve 

and ask that our reserve will be to fly the mission to the point of intended landing and have at least a 20%

battery reserve after that.

14 C.F.R. 91.215 ATC transponder and altitude reporting equipment and use:

This regulation states all aircraft operating within 30 nautical miles of class A, B and C airspace must be 

equipped with automatic pressure altitude reporting equipment having a Mode C capability that 

automatically replies to Mode C interrogations. Due to the small size and lifting capabilities of our UASs 

we cannot carry a traditional transponder. All of our operations will be under 250’ if we are operating 

within the 30mi reach of a mode c vail.

14 CFR Subpart E (91.401- 91.417) - Maintenance, Preventive Maintenance, Alterations 

The regulation provides that the operator is primarily responsible for maintaining the aircraft in an 

airworthy condition, including compliance with part 39 and 43. Paragraphs 91.407 and 91.409 require that

the aircraft be "approved for return to service by a person authorized under 43.7" after maintenance and 

inspection. It is our intention that the PIC perform maintenance and inspection of the aircraft and "be 

authorized to approve the aircraft for return to service."

The PIC will ensure that the aircraft is in an airworthy condition prior to every flight and in addition, 

conduct detailed inspections after every two hours of flight. Maintenance performed by the PIC is limited 

to repairing small cracks, replacing a propeller, checking electrical connections and updating software and 

firmware for the on-board computer. All other maintenance will be performed by the manufacturer or

their designated repair facility. The PIC will document work performed in accordance with 91.417. We

feel that due to the size, construction, and simplicity of the aircraft, the PIC can ensure an equivalent level

of safety.
UAS Innovators LLC 11523 Palmbrush Trail Suite 353 Lakewood Ranch, FL 34202

How this Request is to the Betterment of our Community

We believe that the use of UAS to perform agricultural land imaging creates a benefit to the public. The 

ability to use an onboard geo-referenced still camera to collect high-resolution data that can be used to 

increase crop production and reduce unnecessary chemical use will provide a less expensive and healthier 

food supply to the public. The unmanned aircraft does not carry any persons or flammable liquids, 

reducing public exposure in the event of an incident. Finally, the unmanned aircraft can be launched and 

recovered from the property which we have been contracted to image. The ability to avoid overflying 

private and public properties provides the public with the benefit of privacy from aircraft flying overhead.

Unmanned Aircraft Systems (sUAS) are also a feasible method to obtain information of agricultural 

cropland to determine optimum inputs that result in cost savings to farmers, yield security, and reduce 

environmental impact of excess fertilizers and chemicals in the soil.

Request for Blanket COA Approval

On March 24, 2015, the FAA announced that it has implemented a new policy of granting "blanket" 

COAs to applicants requesting exemptions from the Federal Aviation Regulations under Section 333 of 

the FAA Modernization and Reform Act of 2012.

The Applicant hereby requests that a "blanket" COA that conforms to the terms set forth in 

https://www.faa.gov/news/updates/?newsId=82245 upon approval of UASI’s exemption request.

Sincerely

Timothy Ford

President and CEO

UAS Innovators, LLC

11523 Palmbrush Trail Suite 353

Lakewood Ranch, FL 34202

(314) 397-1110