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Atif R. Aleemi 

DBA Dulles One Consultants, LLC 

44329 Lord Fairfax Place 

Ashburn, VA 20147 

Phone: 703-798-7918 

Email: Atif.Aleemi@yahoo.com 

May 8, 2015 

U.S. Department of Transportation 

Docket Management System 

1200 New Jersey Ave., SE 

Washington DC 20590 

Re: Atif R. Aleemi DBA Dulles One Consultants, LLC Exemption Petition Pursuant to Section 

333 of the FAA Reform Act 

Dear Sir or Madam: 

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the “Reform Act”) 

and 14 CFR Part 11, Atif R. Aleemi DBA Dulles One Consultants, LLC (DON) , hereafter 

referred to as the “petitioner”, operator of Small Unmanned aircraft Systems (“sUAS”), hereby 

applies for an exemption from the listed Federal Aviation Regulations (“FARs”) to allow 

commercial operation of sUAS, 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 333.1. 

The proposed exemption, if granted, would allow the petitioner to conduct commercial 

operations of sUAS meeting or exceeding operational and safety requirements Congress has 

set forth in Section 333. Statutory Authority Section 333, titled “Special Rules for Certain 

Unmanned Aircraft Systems”, provides a mechanism for seeking expedited FAA authorization of 

safe civil UAS operations in the National Airspace System (NAS). Section 333(a) states that the 

FAA “shall determine if certain unmanned aircraft systems may operate safely in the national 

airspace system before completion of the (comprehensive) plan and rulemaking required by 

section 332(b)(1) of this Act or the guidance required by section 334 of this Act.” In Section 

332(b)(1), Congress made it clear that Section 333 provides a mechanism for “expedited 

operation authorization” if several factors are met. Petitioner meets all requirements to permit 

FAA approval of commercial UAS operations. 

The petitioner requests relief from the following regulations: 

14 C.F.R. Part 21 

14 C.F.R. 45.23 (b) 

14 C.F.R. 91.7 (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. 91.215 

14 C.F.R. 91.405 

14 C.F.R. 91.407 

14 C.F.R. 91.409 
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14 C.F.R. 91.417 

14 C.F.R. 91.109 

This petition for exemption would allow DON to operate sUAS to conduct aerial 

photography and/or video, inspections, training, and closed-set filming. We intend to 

operate the DJI Phantom 3 and 3D Robotics SOLO to perform these activities. We are 

proposing two sUAS, with similar form and characteristics, to avoid burdening the FAA 

for a separate exemption or amendment at a later time. This will also provide our 

proposed commercial operations with flexibility and enhance safety as we can match the 

sUAS to the specific task. 

Both sUAS are commercially produced by their respective companies, with long history of 

actively supporting their machines as well as extensive commitment to safe operations. The 

proposed sUAS have built in safety features utilizing GPS and failsafe functions. Our sUAS are 

multi-rotor craft weighing no more than 55lbs. including payload. Under normal conditions they 

operate at speeds of no more than 50kts and have the ability to hover and move along a vertical 

and horizontal plane simultaneously. They will operate in line of sight and will operate within a 

closed off and predetermined area owned and/operated by the property representative. 

As described fully below, the requested exemption would permit the operation of sUAS that are 

a) limited, b) controlled, c) predetermined, and d) will provide safety enhancements to the 

already safe operations in the industry presently using conventional aircraft. Approval of this 

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

Administrator’s) responsibilities to “....establish requirements for the safe operation of such 

aircraft systems in the national airspace system.” 

The pilot in command (PIC), Atif R. Aleemi DBA Dulles One Consultants, LLC (DON), holds a 

Private Pilot Certificate originally issued 11/24/1987 (reissued on 4/4/2015 to replace social 

security number as the certificate number) with a third-class medical certificate recently issued 

on 4/4/2015. With a high commitment to safety and compliance, the PIC has recently completed 

several courses via the FAA Safety Team Aviation Learning Center including covering rotary 

aircrafts. Also the PIC has been engaged with the Radio Control (RC) hobby since 1980, with 

significant experience in operating fixed wing and rotary RC crafts. 

Specifically, our commercial activities would include: 

1. Aerial photography and/or video for public and/or private use including real estate, 

architecture, land surveying, engineering and other related professional activities. 

2. Aerial video and/or photography for public and/or private use including television, public 

events, cinematography and news gathering. 

3. Aerial video and/or photography for closed-set filming. 

4. Aerial inspection/photography of residential/commercial structures under contract with 

the owners or local government authority. 
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5. Aerial video/photography or providing live video feed to assist with search and rescue 

operations in cases of an emergency or natural disaster only when the local authorities 

or government has requested it by contract or donation. 

6. The ability to offer training to persons individually or belonging to both private and/or 

public organizations that have interests in the use and application of sUAS for the 

purpose of the safe operation of sUAS to enhance the safety of the NAS as well as for 

the protection of the persons and property. 

The remainder of this petition follows the FAA’s Public Guidance for Petitions for Exemption 

Filed under Section 333, Rev. 9/25/2014: 

1. Information Regarding the Unmanned Aircraft System – Page 3 

2. Information Regarding the Unmanned Aircraft PIC – Page 11 

3. Information Regarding the Operation of the Unmanned Aircraft – Page 12 

4. Discussion of Requested Regulation Exemptions – Page 15 

1. Information Regarding the Unmanned Aircraft System 

The sUAS subject of this petition are: (1) Phantom 3 manufactured and supported by DJI. (2) 

SOLO manufactured and supported by 3D Robotics. We are proposing two sUAS, with similar 

form and characteristics, to avoid burdening the FAA for a separate exemption or amendment at 

a later time. This will also provide our proposed commercial operations with flexibility and 

enhance safety as we can match the sUAS to the specific task. 

Both crafts include safety features and their respective companies are committed safety. DJI 

enforces no-fly zones in compliance with guidance from the FAA. For example, Phantom 3 

does not operate within 5 miles of large airports. It also enforces altitude limits of 400 feet, as 

does the SOLO. Both UASs provide automated features enhance safety such as auto-takeoff, 

auto-return to home, and failsafe. The description of these features for Phantom 3 includes: 

Auto-Takeoff: With one tap in the DJI Pilot app, Phantom 3 will turn on its motors and 

rise to a pre-set height. It will then hover perfectly in place until you direct it where to go. 

Auto-Return Home: When GPS is available, Phantom 3 remembers the exact spot that 

it took off from. Wherever your aircraft is flying, tap a button to have it return right back 

home. 

Failsafe: If the Intelligent Flight Battery is running low, or if your Phantom 3 loses the 

connection with your remote controller for any reason, the aircraft will automatically 

return to the takeoff point and land safely. 

The description of the safety features for 3D Robotics SOLO includes: 

One-Button Flying: Take off, land, and return home automatically. 

Pause: If release controls for a moment or wish to capture a static shot, simply press 

the "Pause" button for the Solo to hold in a fixed hover. When ready, just press "Pause" 

again to resume flying. 
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Safety Net: This flying mode limits the range and altitude the Solo can fly. Typically, the 

maximum flight ceiling is restricted to less than 400 feet and the aircraft is limited to 

flying within a user-specified radius 

The PIC will employ all safety features, while being fully in command of the sUAS. The PIC and 

VO will be an integral team and employ this checklist to ensure safety of operations: 

Flight-Planning 

1. Survey the area subject to sUAS operation 

2. Review any potential hazards and plan mitigations with Visual Observer (VO) 

3. Seek any necessary authorizations from property owners 

4. Review compliance with Grant of Exemption, Conditions and Limitations 

5. Conduct a briefing regarding the planned UAS operations 

Pre-Flight 

6. Inspect the sUAS for any lose parts or wires 

7. Remote controller charged fully (confirm level on remote) 

8. Aircraft battery charged fully (confirm level on remote) 

9. Mobile device charged fully (confirm level on device) 

10. Propellers are mounted correctly and firmly 

11. Micro-SD card has been inserted if necessary 

12. Gimbal is functioning as normal 

13. Announce “clear” before starting the motors 

14. Motors can start and are functioning as normal 

15. Pilot app connected to the aircraft 

During-Flight 

16. PIC to follow the light plan 

17. VO to review monitor flight and environment 

Post-Flight 

18. Turn-off and disconnect all power 

19. Remove propellers 
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20. Log sUAS operations 

21. Communicate completion of operations as necessary 

22. Remove equipment from field 

As both the Phantom 3 and SOLO are produced for the U.S. consumer market, these devices 

comply with FCC rules and regulations. Specific frequency and features information is included 

in the manufacturer’s tables provided in this section, while other detailed product information is 

provided as separate documents. 

DJI Phantom 3 Specifications

Aircraft WEIGHT (INCLUDING BATTERY AND PROPELLERS)

1280 g 

DIAGONAL SIZE (INCLUDING PROPELLERS)

590 mm 

MAX ASCENT SPEED

5 m/s 

MAX DESCENT SPEED

3 m/s 

HOVER ACCURACY

 Vertical: +/- 10cm 

 Horizontal: +/- 1m 

MAX SPEED

16 m/s (ATTI mode, no wind) 

MAX ALTITUDE ABOVE SEA LEVEL

6000 m 

OPERATING TEMPERATURE

0°C to 40°C 

GPS MODE

GPS/GLONASS 

Camera SENSOR

Sony EXMOR 1/2.3” Effective pixels: 12.4 M (total pixels: 12.76 M) 
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LENS

FOV 94° 20 mm (35 mm format equivalent) f/2.8, focus at ∞

ISO RANGE

100-3200 (video) 100-1600 (photo) 

SHUTTER SPEED

8s -1/8000s 

IMAGE MAX SIZE

4000 x 3000 

STILL PHOTOGRAPHY MODES

 Single Shot 

 Burst Shooting: 3/5/7 shots 

 Auto Exposure Bracketing (AEB): 3/5 

 Bracketed Frames at 0.7EV Bias 

 Time-lapse 

VIDEO RECORDING MODES

Phantom 3 Professional 

 UHD: 4096x2160p 24/25, 3840x2160p 24/25/30 

 FHD: 1920x1080p 24/25/30/48/50/60 

 HD: 1280x720p 24/25/30/48/50/60 

Phantom 3 Advanced 

 FHD: 1920x1080p 24/25/30/48/50/60 

 HD: 1280x720p 24/25/30/48/50/60 

SUPPORTED SD CARD TYPES

Micro SD 

Max capacity: 64 GB. Class 10 or UHS-1 rating required 

MAX BITRATE OF VIDEO STORAGE

60 Mbps 

SUPPORTED FILE FORMATS

 FAT32/exFAT 
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 Photo: JPEG, DNG 

 Video: MP4, MOV (MPEG-4 AVC/H.264) 

OPERATING TEMPERATURE

0°C to 40°C 

Gimbal CONTROLLABLE RANGE

Pitch -90° to +30° 

STABILIZATION

3-axis (pitch, roll, yaw) 

Vision 

Positioning

MAX VELOCITY

Less than 8 m/s (when 2 m above ground) 

ALTITUDE RANGE

30 cm-300 cm 

OPERATING RANGE

30 cm-300 cm 

OPERATING ENVIRONMENT

Surface with clear pattern and adequate lighting (Lux > 15) 

Remote 

Controller

OPERATING FREQUENCY

2.400 GHz-2.483 GHz 

MAX DISTANCE

2000m (outdoors and unobstructed) 

VIDEO OUTPUT PORT

USB 

OPERATING TEMPERATURE

0°C- 40°C 

BATTERY

6000 mAh LiPo 2S 

MOBILE DEVICE HOLDER

For tablet or phone 

RECEIVER SENSITIVITY (1%PER)

-101 dBm ±2 dBm 

TRANSMITTER POWER (EIRP)
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 FCC: 20 dBm 

 CE: 16 dBm 

WORKING VOLTAGE

1.2 A @7.4 V 

Battery 

Charger

VOLTAGE

17.4 V 

RATED POWER

Phantom 3 Professional 

 100 W 

Phantom 3 Advanced 

 57 W 

Intelligent 

Flight Battery

CAPACITY

4480 mAh 

VOLTAGE

15.2 V 

BATTERY TYPE

LiPo 4S 

ENERGY

68 Wh 

NET WEIGHT

365 g 

MAX FLIGHT TIME

Approximately 23 minutes 

OPERATING TEMPERATURE

-10°C to 40°C 

MAX CHARGING POWER

100 W 

App / Live 

View

MOBILE APP
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DJI Pilot 

EIRP

100mW 

LIVE VIEW WORKING FREQUENCY

2.4GHz ISM 

LIVE VIEW QUALITY

720P @ 30fps (depending on conditions and mobile device) 

LATENCY

220ms (depending on conditions and mobile device) 

REQUIRED OPERATING SYSTEMS

 iOS 8.0 or later 

 Android 4.1.2 or later 

RECOMMENDED DEVICES

 iOS: iPhone 5s, iPhone 6, iPhone 6 Plus, iPad Air, iPad Air Wi-Fi + 

Cellular, iPad mini 2, iPad mini 2 Wi-Fi + Cellular, iPad Air 2, iPad Air 2 

Wi-Fi + Cellular, iPad mini 3, and iPad mini 3 Wi-Fi + Cellular. This app 

is optimized for iPhone 5s, iPhone 6, and iPhone 6 Plus 

 Android: Samsung S5, Note 3, Sony Xperia Z3, Google Nexus 7 II, 

Google Nexus 9, Mi 3, Nubia Z7 mini 

 *Support for additional Android devices available as testing and 

development continues 

3D Robotics SOLO Specifications 

Performance 

Maximum Speed 55 mph / 88.5 km/h 

Maximum Altitude 400' / 121.9 m AGL 

Flight Time Up to 25 minutes (20 with camera and Solo Gimbal) 

Flight Control System 
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Model Pixhawk 2 

Software APM flight control software 

GPS Yes 

Handheld Transmitter 

Frequency 

Remote 

2.400 GHz-2.483 GHz 

MAX DISTANCE 

Display Color Screen for menu and live flight telemetry 

Battery 

Chemistry: Lithium-polymer 

Capacity: 5200 mAh 

Voltage: 14.8 VDC 

Life: Up to 4 hours 

Mobile App 

System Requirements Wi-Fi enabled iOS or Android mobile device 

Wi-Fi Range Up to 2640' / 805 m (depending on environment) 

FPV and Monitoring 

Video Downlink Latency: 180 ms 

Connectivity 1 x HDMI output on Transmitter 

Components 

Rotors 4 x 10 x 4.5" / 25.4 x 11.4 cm self-tightening props 

Motors Velocity Constant: 880 kV 

Gimbal Compatibility Solo Gimbal for HERO3+ and HERO4 (gimbal and camera 

available separately) 

Flight Battery 

Model Solo Battery 
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Chemistry Lithium-polymer 

Capacity 5200 mAh 

Voltage 14.8 VDC 

General 

Running Lights Customizable color LEDs to assist orientation 

Dimensions Not specified by manufacturer 

Weight Unladen: 3.3 lb / 1.5 kg 

With Solo Gimbal and GoPro: 4 lb / 1.8 kg 

Shipping Info 

Shipping Weight 8.4 lb 

Box Dimensions 

(WxHxD) 0.0 x 0.0 x 0.0 

2. Information Regarding the Unmanned Aircraft PIC 

The pilot in command (PIC), Mr. Atif R. Aleemi DBA Dulles One Consultants LLC, holds a 

Private Pilot Certificate (No. 3799100) issued 11/24/1987 (reissued on 4/4/2015 to replace 

social security number as the certificate number). As required, PIC has a third-class medical 

certificate recently issued on 4/4/2015 by Aviation Medical Examiner (AME) James Koch, MD. 

With a high commitment to safety and compliance, the PIC has recently completed several 

courses via the FAA Safety Team Aviation Learning Center including covering rotary aircrafts. 

Also the PIC has been engaged with the Radio Control (RC) hobby since 1980, with over 200 

hours experience in operating fixed wing and rotary RC crafts. 

We will utilize a visual observer (VO) in all operations covered by this requested exemption. The 

VO will be trained for the following responsibilities: 

• Before each operations, check to ensure compliance with all “conditions and 

limitations” as provided in the Grant of Exemption letter. 

• After PIC establishes the area of operations, validate and identify any additional 

potential hazards that must be mitigated. 

• Review compliance with the pre-flight checklist, while the PIC performs the pre-flight 

check 
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• While PIC is operating the sUAS, VO will deal with any distractions such as 

onlookers or curious bystanders 

• sUAS operations will only commence when both the PIC and VO agree to proceed 

3. Information Regarding the Operation of the Unmanned Aircraft 

The UAS operations covered by this petition include the following: 

1. Aerial photography and/or video for public and/or private use including real estate, 

architecture, land surveying, engineering and other related professional activities. 

2. Aerial video and/or photography for public and/or private use including television, public 

events, cinematography and news gathering. 

3. Aerial video and/or photography for closed-set filming. 

4. Aerial inspection/photography of residential/commercial structures under contract with 

the owners or local government authority. 

5. Aerial video/photography or providing live video feed to assist with search and rescue 

operations in cases of an emergency or natural disaster only when the local authorities 

or government has requested it by contract or donation. 

6. The ability to offer training to persons individually or belonging to both private and/or 

public organizations that have interests in the use and application of sUAS for the 

purpose of the safe operation of sUAS to enhance the safety of the NAS as well as for 

the protection of the persons and property. 

The operation limitations proposed by the petitioner as set forth in the Flight Operations Manual 

(FOM) include: 

1. UASs will weigh less than 55 pounds including payload. 

2. UASs will operate under the maximum airspeed recommended by the manufacturer, and 

in will not exceeding 87 knots (100 miles per hour). 

3. Maximum flight time for each operational flight will be 30 minutes. Flights will be 

terminated at 25% battery power reserve or 30 minutes of flight time whichever occurs 

first. 

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

(AGL). 

5. The UA will operate within visual line of sight (VLOS) of the PIC at all times. 

6. All operations will utilize a visual observer (VO). The UA will operate within the visual line 

of sight (VLOS) of the PIC and VO at all times. 

7. The VO and PIC will be able to communicate verbally at all times; electronic messaging 

or texting is not permitted during flight operations. 

8. The PIC will be designated before the flight and cannot transfer his or her designation for 

the duration of the flight. 

9. The PIC will ensure that the VO can perform the duties required of the VO. 
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10. Operating documents including Grant of Exemption will be accessible during UAS 

operations and made available to the authorities upon request. 

11. The operator will maintain documents and track changes as necessary, and present to 

authorities for inspections as required. 

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

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

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

13. Functional test flights will be conducted by a PIC with a VO and must remain at least 500 

feet from other people, and pose no undue hazard to persons and property. 

14. The operator will maintain and inspect the UAS to ensure that it is in a condition for safe 

operation. 

15. Prior to each flight, the PIC will conduct a pre-flight inspection and determine the UAS is 

in a condition for safe flight. The pre-flight inspection will account for all potential 

discrepancies, e.g. inoperable components, items, or equipment. 

16. If the inspection reveals a condition that affects the safe operation of the UAS, the 

aircraft will not be operated until the necessary maintenance has been performed and 

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

17. The operator will follow the UAS manufacturer’s maintenance, overhaul, replacement, 

inspection, and life limit requirements for the aircraft and aircraft components. 

18. The UAS receiving Grant of Exemption will comply with all manufacturer safety bulletins. 

19. The designated PIC will hold either an airline transport, commercial, private, 

recreational, or sport pilot certificate. The PIC will hold a current FAA airman medical 

certificate or a valid U.S. driver’s license. 

20. The operator wil 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 

the granted exemption, including evasive and emergency maneuvers and maintaining 

appropriate distances from persons, vessels, vehicles and structures. 

21. PIC qualification flight hours and currency will be logged in a manner consistent with 14 

CFR § 61.51(b). 

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

flight operations are considered nonparticipants, and the PIC will operate the UA with 

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

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

operations will be conducted under visual meteorological conditions (VMC). 

24. The UA wil 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 will be made available to the Administrator or 

any law enforcement official upon request. 

25. The UA will 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. 
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26. If the UAS loses communications or loses its GPS signal, the UA will return to a predetermined location within the private or controlled-access property. 

27. The PIC will abort the flight in the event of unpredicted obstacles or emergencies. 

28. The PIC will not begin a flight unless (considering wind and forecast weather conditions) 

there is enough available power for the UA to conduct the intended operation and to 

operate after that for at least five minutes or with the reserve power recommended by 

the manufacturer if greater. 

29. 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 will be available to the PIC 

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

30. The UA will remain clear and give way to all manned aviation operations and activities at 

all times. 

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

32. All Flight operations will be conducted at least 500 feet from all nonparticipating persons, 

vessels, vehicles, and structures unless. 

33. All operations will 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. 

34. For the purpose of closed-set motion picture and television filming and production, the 

operator will implement a motion picture and television operations manual (MPTOM) 

35. At least 3 days before aerial filming, will submit a written Plan of Activities to the local 

Flight Standards District Office (FSDO) with jurisdiction over the area of proposed 

filming, including 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. 

36. Flight operations will be conducted closer than 500 feet from participating persons only if 

they consent to be involved and necessary for the filming production as specified in the 

MPTOM. 

BETTERMENT OF OUR COMMUNITY: Our UAS are powered by batteries, smaller, lighter and 

more maneuverable than larger aircraft running on combustible fuel, it operates at lower 
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altitudes with no people on board and will thereby reduce current risk levels associated with 

traditional aircraft, enhance safety and diminish the likelihood of death or serious bodily injury. 

Also with a small payload and typical flight time of only 20 minutes, there is little or no risk to 

national security. Low level photos and video are far more effective than ground or high altitude 

manned aircraft imagery for displaying detailed characteristics of ground based objects. The 

applicant in the past has chartered full-sized helicopters for this purpose, which has proven 

more costly than many potential clients have been able to afford. The benefits of reduced cost 

and improved quality of presentation from the UAS will be incredibly valuable to future clients. 

Aerial sightseeing will be conducted safely over coastal Massachusetts water ways and 

underpopulated areas. This new form of tourism will allow all individuals including children, 

elderly and disabled to enjoy the feeling of flight and see the area from above without the noise, 

danger and cost associated with traditional helicopters. Additionally, we will make our sUAS 

available to first responders in our community who might require assistance, including fire 

fighters, police, sheriff, et al., while remaining subject to all limitations cited in this application. 

4. Discussion of Requested Regulation Exemptions 

The petitioner requests an exemption from the following regulations as well as any additional 

regulations that may technically apply to the operation of the sUAS System. 

14 CFR Part 21, Airworthiness Certificates: 

This part establishes the procedures for the issuance of an airworthiness certificate. While the 

FAA continues to work to develop airworthiness standards for Unmanned Aerial Systems, we 

request an experimental certificate be issued for our UAS’s under either or both of the following 

provisions: 21.191 Experimental certificates. Experimental certificates are issued for the 

following purposes: (a) Research and development. Testing new aircraft design concepts, new 

aircraft equipment, new aircraft installations, new aircraft operating techniques, or new uses for 

aircraft. 

(b) Showing compliance with regulations. Conducting flight tests and other operations to 

show compliance with the airworthiness regulations including flights to show compliance for 

issuance of type and supplemental type certificates, flights to substantiate major design 

changes, and flights to show compliance with the function and reliability requirements of the 

regulations. Since the experimental certificate can be used for commercial purposes such as 

market surveys, sales demonstrations, and customer crew training, we would expect that an 

experimental certificate would permit our commercial purpose as well. The aircraft will not carry 

persons or property, will not carry fuel, and will only fly under strict operational requirements. 

Combined with the UAS lightweight, being constructed primarily of carbon fiber and plastic in 

conjunction with the ability to utilize emergency parachute systems. We propose that the UAS 

will be at least as safe, if not safer, than a conventionally certificated aircraft performing the 

same mission. If an experimental airworthiness certificate is not appropriate for this application, 

then we request an exemption of 14 CFR Part 21, Subpart H, and the requirement for an 

airworthiness certificate in general, citing the equivalent level of safety outlined in the previous 

paragraph. 

14 CFR 45.23 Display of marks; general and 45.29 Size of marks: 

These regulations provide that each aircraft must display "N" and the aircraft's registration 

number in letters at least 3 inches high. Additionally, the aircraft must display the word 

"EXPERIMENTAL" in letters at least 2 inches high near the entrance to the cabin, cockpit, or 

pilot station. The sUAS does not have an entrance in which the word "EXPERIMENTAL" can 
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be placed, and may not have a registration number assigned to it by the FAA. We propose to 

achieve an equivalent level of safety by including the word "EXPERIMENTAL" in the placard 

on the top of the aircraft, as shown above, where the PIC (Pilot In Control), VO (Visual 

Observer) and others in the vicinity of the aircraft while it is preparing for launch will be able to 

see the designation. Additionally, we feel that the permanent placard discussed in the previous 

paragraph will provide the aircraft's registration information at the ground station. Finally, we 

will display at the ground station a high contrast flag or banner that contains the words 

"Unmanned Aircraft Ground Station" in letters 3 inches high or greater. Since the aircraft will 

operate within 3/4 NM of the ground station, the banner should be visible to anyone that 

observes the aircraft and chooses to investigate its point of origin. 

14 CFR 91.7 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. 

91.119 Minimum safe altitudes: 

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 careful pre-planned flight path has been performed. In the event of a 

system malfunction or emergency landing with or without a deployed parachute. The hazard to 

persons or property on the surface will be very limited. 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. 

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. The flight controller can be configured to geo-fence the UAS under the 

400 feet maximum altitude. 

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. The purpose of this is to provide an energy reserve as a safety 

buffer for delays to landing. Since the aircraft will never fly more than 3/4 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. 

14 CFR 91.203(a) & (b) Civil aircraft: Certifications required: 

The regulation provides that an airworthiness certificate, with the registration number assigned 

to the aircraft and a registration certificate must be aboard the aircraft. Additionally, 

subparagraph (b) provides that the airworthiness certificate be "displayed at the cabin or cockpit 

entrance so that it is legible to passengers or crew." At a maximum gross weight of 55 pounds, 

the sUAS is too small to carry documentation, does not have an entrance, and is not capable of 

carrying passengers or crew. To obtain an equivalent level of safety and meet the intent of 
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91.203, we propose that documents deemed appropriate for this aircraft by the FAA will be with 

the crew at the ground control station and available for inspection upon request. In order to 

identify the aircraft, we propose that the information found on airworthiness and registration 

certificates be permanently affixed to the aircraft via placard containing the following information 

plus the word "EXPERIMENTAL" to satisfy the requirement of 14 CFR 45.23. 

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 five hours of flight. All maintenance will be performed 

by the PIC in accordance with the manufactures manual. If required maintenance is beyond the 

ability of the PIC the 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. 

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

Section 91.103 provides 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. sUAS and remotely piloted aircraft, by their 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 FAA has approved exemptions for flight training 

without fully functional dual controls for a number of aircraft and for flight instruction in 

experimental aircraft. The equivalent level of safety provided by the fact that neither a pilot nor 

passengers will be carried in the aircraft and by the size and speed of the aircraft. 

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 

under 250 feet if we are operating within the 30mi reach of a mode c vail. 

In conclusion, by granting the requested exemptions, the FAA will help drive development of 

safe and successful commercial UAS operations and will advance the public knowledge base 

for such operations of UAS. We are committed to promoting the UAS research efforts of 

policymakers by sharing data from its commercial UAS operations and serving as a resource for 

future UAS research operations. 

As described above, all the sUASs which our company would use, under authorization by the 

US DOT-FAA, are small, light-weight devices operated within the line of sight of the Pilot-inCommand (PIC), less than 400 feet above the ground and outside 5 miles from any airport or 
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location with aviation activities, unless the air traffic control authorities (ATC) have been notified 

and have authorized each flight within a radius of this distance. 

We are seeking an exemption pursuant to 14 C.F.R. and Section 333 of the FAA Modernization 

and Reform Act of 2012 (FMRA), which will permit safe operation of our UAS commercially, 

without an airworthiness Certificate. By granting this Petition, the FAA Administrator will be 

fulfilling the Congressional mandate of the FAA Modernization and Reform Act of 2012, while 

also advancing the interests of the public, by allowing DON to safely, efficiently, and 

economically operate sUASs commercially within the NAS. Wherefore, in accordance with the 

Federal Aviation Regulations and the FAA Modernization and Reform Act of 2012, Section 333, 

we respectfully requests that the Administrator grant this Petition for an exemption from the 

requirements of 14 C.F.R Sections. 

Sincerely, 

/s/ 

Atif R. Aleemi 

General Partner 

Dulles One Consultants, LLC 

Phone: 703-798-7918 

Email: Atif.Aleemi@yahoo.com