July 30, 2015

Nathan Rea

Owner/Operator

Squadron Optics LLC

3220 Honey Locust Dr.

Loveland, CO 80538

(970)685-7602

squadronoptics@gmail.com

Requests exemption from multiple regulatory provisions to allow the use of small unmanned aerial 

systems on land, controlled by clients of Squadron Optics LLC, to assist in the safe evaluation of 

infrastructure and property for our clients.

Squadron Optics LLC respectfully requests an exemption from several provisions of Title 14 of the Code 

of Federal Regulations (C.F.R.), to permit the use of small unmanned aerial systems (sUAS) to assist in 

the evaluation and documentation of infrastructure and property for our clients. This request is 

motivated primarily by the desire to maximize safety in inspection operations. It would allow Squadron 

Optics LLC, to broadly evaluate assets and property with sUAS, resulting in a safer and more efficient 

work environment. Accordingly, the grant of an exemption is consistent with Congress’ intent, reflected 

in Section 333 of the FAA Modernization and Reform Act of 2012 (Modernization Act)1, that safe 

systems be permitted in the national airspace prior to the issuance of final regulations governing general 

use of these systems.2 A summary of this request suitable for publication in the Federal Register is 

provided as Appendix A.

Appendix B provides the manufacturer’s information regarding: the design, aircraft performance, and 

fail-safe features. We have provided manufacturer information related to: operating limitations, normal

and emergency procedures, and maintenance and inspection procedures. As we add aircraft designs, 

we will update this appendix appropriately.

 

1

P.L. 112-95, 126 Stat 11, February 14, 2012

2

Section 333(b)(2) specifically contemplates that the FAA may issue a certificate of waiver upon a finding that a type of UAS, as a result of its 

size, weight, speed, operational capacity, proximity to airports and populated areas, and operations within visual line of sight do not create a 

hazard to users of the NAS or the public or pose a threat to national security.
Background Information

Squadron Optics LLC is an up and coming company in Northern Colorado that specializes in the safe 

operation of sUAS. Our clients look to Squadron Optics LLC for us to be the sUAS experts, and to fly 

them in the safest possible way. We have developed our SOPs and work environment to reflect and 

promote safe sUAS operations. 

Infrastructure Safety Inspection Operations:

Utility Inspection

Agriculture Inspections

Oil-Field Inspections 

Pipeline Inspections

Railroad Inspections 

Construction site Inspections

Real Estate Inspections

Site Planning Aerial assessments

As part of this, Squadron Optics LLC is also requesting FAA Exemption for sUAS operations for safety 

inspections and video capture usage.

Regulatory Basis for Exemption Request

In addition to the waiver authority provided in §333 of the Modernization Act, the FAA may grant an 

exemption under 49 U.S.C. §44701(f), if it has determined that such an exemption is in the public 

interest. The FAA has imposed a separate requirement in its procedural regulations, providing that the 

petitioner shall explain why granting the exemption would not adversely affect safety, or how the 

exemption would provide at least an equivalent level of safety as compliance with the underlying 

regulation. In this case, approval of this exemption would advance the public interest by significantly 

enhancing the safety and efficiency of infrastructure operations, and by providing the FAA with valuable 

user experience on sUAS in a context with appreciable economic and societal benefits. As described 

more fully below, the requested exemption would permit the operation of sUAS under tightly controlled 

conditions, thus ensuring that operations will not have an adverse impact on safety. To the contrary,

the use of large aircraft with fuels and personnel are at a greater safety risk than the use of sUAS. 

Granting an Exemption is in the public interest because the safety and efficiency of inspection 

operations is heavily dependent upon constant analysis of: right-of-way, inspection, and other 

assets/facilities. Even relatively small objects, or minor failures, can lead to accidents or other incidents 

causing downtime of infrastructure. Extreme weather events can lead to flooding, or overheating 

infrastructure. For example: tornados, floods, landslides, wildland fires, and abandoned vehicles at 

grade crossings, can block infrastructure. The potential for trespassing is also among the many risks that 

modern infrastructure faces.

As a result, pursuant to federal regulations and company policy, our client’s maintenance employees 

routinely inspect the infrastructure, such as: bridges, tunnels, support structures, and signals. At 

present, this work is done primarily by company personnel in motor vehicles, on foot, or in specialized 

equipment. This is often a labor-intensive and sometimes arduous job. While our clients do all they can 

to make these inspections as safe as possible, there is an irreducible element of risk involved whenever 

employees are required to go out on structures. Employees may need to climb over or onto structures, 

which can be slippery, rough, and/or exposed to the elements. Some structures, such as bridges, are 
high above the ground. Equipment moving through inspection zones can increase risk as well, especially 

in high-traffic areas. While the use of sUAS for supplemental infrastructure and general asset evaluation 

would not eliminate these risks entirely (as it is an additive safety measure), it would reduce the risk to 

employees by allowing for remote aerial review. 

Additionally, the sheer amount of assets and the widely dispersed locations – in many instances far from 

sizeable population centers - means that visual inspection in all instances by company personnel can be 

inefficient. Aerial analysis by traditional fixed wing aircraft, is impractical because the required altitudes 

for safe flight reduce visibility below meaningful levels; it is simply not possible to see all asset anomalies 

from such heights. Helicopters present better vantage points. However, manned helicopters are much 

more costly, subject to human safety and carry highly explosive jet fuel, making them impractical for 

deployment. By using sUAS for supplemental asset evaluation, Squadron Optics LLC will be able to 

substantially upgrade its capacity to detect and address issues with the right-of-way and other assets,

before they become a problem for safe operations. Thus, the use of sUAS has the potential to improve 

efficiency, resulting in faster and safer delivery of goods, energy, and natural resources vital to the U.S. 

economy.

Granting an Exemption will not adversely affect Safety

Squadron Optics LLC notes that there is no applicable standard for an equivalency determination. Some 

have argued that the appropriate standard is that for model aircraft, noting that their operations, if 

conducted for recreational purposes, would fall completely within the allowable operations for model 

aircraft. We believe it makes more sense to focus on why the contemplated operations would not 

adversely affect safety, which is all that §11.81(e) requires.

Granting an exemption will not adversely affect safety. Squadron Optics LLC contemplates conducting 

sUAS operations over client owned or controlled land, solely during daylight hours, at altitude well 

below that which would pose risk to other aircrafts. In general, sUAS operations are intended to be 

conducted in areas distant from both congested areas and airports. Moreover, because of the inherent 

risks presented by standard infrastructure operations, our clients have already taken steps to secure 

property against unauthorized public access. For example, agricultural farms, railroad track, and 

pipeline are elevated, fenced or otherwise secure from unauthorized access. Other long stretches of 

track and pipeline are in such remote parts of the wilderness that interaction with people is unlikely. 

The nature of operations anticipated by Squadron Optics LLC requires that the sUAS be flown at low 

speeds and low altitudes. Squadron Optics LLC expects that in most instances, the sUAS will be flown 

less than 75ft from the highest structure along the path of the sUAS. Accordingly, the risk of 

interference with another aircraft is minimal. Additionally, Squadron Optics LLC has also worked out 

agreements with local airports. If a flight is within the 5 mile radius of the airport, a flight plan will be 

submitted to the director of operations for approval before flights will take place. Squadron Optics LLC 

will comply with any directions issued by air traffic control at the airport. 

Approval of exemption, allowing commercial operations of sUAS in the infrastructure and agricultural 

aerial inspection industry, will enhance safety by reducing risk. Conventional operations, using jet or 

piston power aircraft, operating at extremely low altitudes, just feet from the subject being inspected,

and in extreme proximity to people and structures present a risk associated with vehicles that weigh in 

the neighborhood of 4,000lbs and carrying large amounts of jet A or other fuel (140 gallons for jet

helicopters); such aircrafts must fly to and from the inspection site. In contrast, a sUAS weighing fewer 

than 55lbs and powered by batteries eliminates virtually all of that risk, given the reduced mass and lack 

of combustible fuel carried on board. The sUAS is carried to the inspection site. The sUAS will carry no 
passengers or crew and, therefore, will not expose them to the risks associated with manned aircraft 

flights. 

The operation of sUAS, weighing less than 55lbs, conducted in the strict conditions outlined above, will 

provide an equivalent level of safety supporting the grant of the exemptions requested herein, 

including: 333 Aircraft Exemption Status, exempting the applicant from conventional aircraft 

requirements, and allowing commercial operations. These lightweight aircrafts, operate at slow speeds, 

close to the ground, and in a controlled environment. As a result, they are far safer than conventional 

operations conducted with turbine helicopter operations, in close proximity to the ground and people. 

The safety of those on the ground, is protected by the fact that no one will be allowed in the area,

without the permission of the company and pilot in charge (PIC). Security will be established for the 

flight area as part of the pre-flight control. Each individual, within the secure area, will be briefed prior 

to flight and will consent to being in the area. All others will be excluded from the area.

Squadron Optics LLC initially intends to use a dedicated staff for sUAS operations. All operations will be 

within visual line-of-sight (i.e. no more than  ̃0.5 miles from the PIC). Each PIC will conduct at least 

three take-offs and landings with sUAS, on which he or she is trained every ninety (90) days. PICs will 

establish their qualifications threw a combination of: aeronautical knowledge, sUAS airmanship skills, 

and verification, threw testing of flight ability before infrastructure operations have commenced; 

Depending on the type of operation. Additional ground-based visual observers may be employed as 

well. These observers will be within constant visual line-of-sight, and in constant contact with the PIC. 

The visual observers will assist the PIC in avoiding objects near the sUAS.

There are no standards for either Private or Commercial sUAS pilot certificates. The safe operation and 

control of the sUAS, as described in this application, does not depend on the type of FAA license held by 

the PIC. Given the restricted and controlled airspace within which operations will take place, the key 

factors needed by the PIC are: knowledge of the airspace within which the operation will take place,

how that airspace within which the operation will take place, and how that airspace fits into the 

National Airspace System (NAS). That knowledge can be, and is gained primarily through, ground school 

and not through flight training in fixed wing or rotor aircraft. Nor is it dependent on the acquisition of 

the factors and skills needed for the safe operation of those types of aircraft (fixed wing or rotorcraft). It 

cannot be assumed that a commercial pilot, approved to operate a helicopter of fixed wing aircraft, has 

the skill or ability to safely operate a sUAS, operating at 400AGL or lower, within strictly controlled preapproved airspace. Besides knowledge of airspace regulations, dexterity in the control and operation of 

the sUAS, acquired from actual operation of the aircraft, is the most important factor in establishing an 

equivalent level of safety. 

If the PIC has acquired the necessary knowledge of airspace requirements, the relevant issues are: one 

(1) where the aircraft will be flown, two (2) the size of the aircraft relative to what is being used today to 

accomplish the same mission, and three (3) what precautions will be taken to ensure the safety of those 

in the area of operation. We propose that the PIC has at least an FAA 3rd class medical certificate, and a 

working knowledge of the NAS. The aircraft will be operated within a secure environment; and that no 

one be allowed to enter the secure environment unless they are part of the operation, have been fully 

briefed of the risks prior to operation of the sUAS, and have consented to the risks associated with being 

in the operating area. Should there be a mishap, the sUAS being flown will pose significantly less of a 

threat than the helicopters and fixed wing aircraft now being employed, because: they are a fraction of 

the size, carry no flammable fuel, do not carry crew or passengers, and pose an infinitesimal risk to 
others. This is in stark contrast to conventional aircrafts that are: flown to the site, carry, explosive fuel, 

carry passengers and crew, and operate in a much larger area. 

From a practical standpoint, there are relatively few licensed full-scale aircraft pilots, who are also 

qualified to fly the type of sUAS that are utilized for infrastructure image-capture operations. There are 

even fewer commercial pilots that can fly these sUAS – to the point that to do both is considered rare. 

Assuming that it is unlikely for a company to find a pilot that has both qualifications, the company would 

either have to source a qualified sUAS pilot to train and obtain a commercial certificate, or find a 

commercial certified pilot who would be willing to learn to fly a sUAS to the competency level required 

for professional use. 

Minimum Requirements for PIC include:

1) 3

rd Class Medical certificate 

2) A minimum of 200 flight cycles and 25 hours of total time as a sUAS rotorcraft pilot and at 

least 10 hours logged as a sUAS pilot with a similar sUAS type. 

3) A minimum of 5 hours as sUAS pilot with the make and model of sUAS to be utilized for 

operations under the exemption and 3 take offs and landings in the preceding 90 days.

4) Have undergone a qualification process as specified in the Standard Operating Procedures 

consisting of a knowledge & skills test of the aircraft to be used. 

Another consideration supporting the certificate requirement, is that pilots operating sUAS will all pass a 

Colorado Bureau of Investigation background investigation. This requirement should ameliorate 

security concerns over sUAS operations under this exemption. 

Squadron Optics LLC intends to use commercially available sUAS components for sUAS. These sUAS 

systems will be tested for quality and safety in our maintenance shop before being deployed to the field. 

The sUAS is less than 55lbs, fully loaded, carries neither a pilot nor passenger, and operates exclusively 

within a secured area. We will maintain logs of all flights to verify that the sUAS will remain in safe and 

operational conditions. Please see Appendix B, for specific types of sUAS. 

Notes Regarding: 14 C.F.R. Part 21 Subpart H

In accordance with the statutory criteria provided in Section 333 of PL 112-95 in reference to 49 USC 

44704, and in consideration of the size, weight, speed, and limited operating area associated with the 

aircraft and its operations, we request that this aircraft exemption meet the conditions of section 333. 

Therefore, if granted Section 333 relief of 14 CFR part 21, and any associated noise certification and 

testing requirements of part 36, is not necessary.

Notes Regarding: 14 C.F.R. §45.23 (b) Marking of the Aircraft 

Given the size of the sUAS, two – inch lettering will be impossible. sUAS will be identified by serial 

number, registered in accordance with 14 C.F.R. part 47, and have identification (N-Number) markings in 

accordance with 14 C.F.R. part 45, Subpart C. Marking will be as large as practicable.

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

Squadron Optics LLC is based on the fact that no airworthiness certificate will be issued for sUAS. 

Squadron Optics LLC will not require an airworthiness certificate in accordance with 14 C.F.R. part 21, 

subpart H. Based on the fact that an airworthiness certificate will not be issued, exemption from § 91.7 

(a) is not necessary. 
Notes Regarding: 14 C.F.R. §91.9(b)(2) Civil aircraft flight manual, marking, and placard 

Certifications required:

The original intent of these regulations was to display an aircraft’s airworthiness, certification, and 

registration documents so they would be easily available to inspectors and passengers. Based on the 

FAA Memorandum subject “interpretation regarding whether certain required documents may be kept 

at an unmanned aircrafts control station,” dated August 8, 2014, the requested relief from §14 C.F.R. 

91.9(b) (2) and §91.203(a) and (b) is not necessary.

Notes Regarding: 14 C.F.R. §1.109 Flight instruction; Simulated instrument, and certain flight tests

Small sUASs, 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 or wireless fidelity (WiFi) 

communication. Aircrafts, being considered for use by Squadron Optics LLC, allow the sUAS Instructor to 

place the aircraft into ‘LTR’ or loiter mode (fixed altitude stationary hold). In the event of the student 

losing control, the sUAS Instructor is trained to put the sUAS in to ‘LTR mode’ in a quick and safe 

manner. The instructor will then take command of the sUAS and bring it back to a safe pre-determined 

location. Squadron Optics LLC does not describe training scenarios in which a dual set of controls would 

be utilized or required, i.e. dual flight instruction, provided by a flight instructor or other companydesignated individual, which would require that individual to have fully functioning dual controls. 

Rather, Squadron Optics LLC evaluates the qualification of its PICs based on their experience with the 

sUAS to be operated and verifies through testing, in lieu of their experience with the sUAS to be 

operated and verifies through testing, in lieu of formalized training. As such, Squadron Optics LLC does 

not seek relief from 14 C.F.R. § 91.109.

Notes Regarding: 14 C.F.R. §91.119(b)

Relief from 14 C.F.R. § 91.119(b), operation over congested areas, is not applicable because Squadron 

Optics LLC operations will only be conducted within the secured area described herein. 

Squadron Optics LLC Safety Operations & Procedures Overview:

Technology Considerations:

Best-in-class, tried and proven technologies that are in advanced iterations. Software from highlyreputable industry leaders will include features –

1. Auto descent (landing) if communication signal were to be severed. If the sUAS loses 

communications, the sUAS will have capability to return to a pre-determined location within 

the Security Perimeter and land. This is known as ‘RTL’ or Return-to-launch. 

2. Auto descent (landing) if battery were to drop lower than nominal level.

3. Flights will be terminated at 25% battery power reserve. 

4. Live video for operator gives real-time positioning feedback. In other words, we can 

monitor the scene from the vehicles perspective for collision avoidance, and to maintain 

spatial orientation. 

5. The sUAS will have the capability to abort a flight in case of unpredicted obstacles or 

emergencies. 

6. On-screen-displays (OSD) contain operating information to a certain vehicle health at all 

times: speed, altitude, number of GPS satellites (when available), heading and voltage.

7. GPS lock supplies for return-to-launch (RTL). Should Command and Control link failures 

occur (highly improbable), vehicle returns automatically to the point of launch. 

8. Altitude information will be provided to the sUAS pilot via a digitally encoded telemetric 

data feed, which downlinks from the aircraft to a ground-based on-screen display. This 
altitude information will be generated by equipment installed on board the aircraft, using 

GPS triangulation, digitally encoded barometric altimeter, or radio altimeter, or a

combination thereof. Prior to each flight, a zero altitude initiation will be established and 

confirmed for accuracy by the pilot. 

Mechanical/Physical: 

1. We will fly line-of-sight (LOS) only. The vehicle will always remain in direct LOS to the pilot, 

thus eliminating the concern of signal severance (flying behind objects/walls)

2. The sUAS will weigh less than 55lbs and travel at less than 50 knots (57 mph).

3. Batteries should far exceed the capacity required for actual flight time. 

4. Flights will be operated at an altitude of no more than 400 feet AGL.

5. Fireproof bags for storage and charging of high capacity Lipo batteries on-site.

6. sUAS operated under this exemption will be marked in accordance with 14 C.F.R. part 45 or 

otherwise authorized by the FAA. 

Personnel:

1. Spotters ensure safe operation and act as a redundant set of eyes for operators (pilot, 

gimbal op, director)

2. Radio spectrum analysis for interference on the frequencies utilized for vehicle 

control/communication. 

3. A briefing will be conducted in regard to the planned sUAS operations prior to each day’s 

activities. It will be mandatory that all personnel who will be performing duties within the 

boundaries of the safety perimeter be present for this briefing. 

4. The operator will obtain the consent of all persons involved in the sUAS operations and 

ensure that only consenting persons will be allowed within 100 feet of the flight operations. 

5. Observer and pilot will at all times be able to communicate by voice or radio. 

6. Written and/or oral permission from the relevant property holders will be obtained. 

7. Pilot and observer will have been trained in operation of sUAS generally and received up-todate information on the particular sUAS to be operated.

8. Squadron Optics LLC will be CPR and first responder qualified for the unlikely event a mishap 

happens. 

Operations:

1. The unmanned aircraft (UA) must weigh less than 55 pounds (25Kg), including energy 

source(s), and equipment. Operations authorized by this petition of exemption are limited 

to the following aircraft described in Appendix B. Proposed operations of any other aircraft 

will require a new petition or a petition amendment to this request. 

2. The US may not be flown at ground speeds exceeding 50 knots.

3. Flights must be operated at an altitude of no more than 400 feet above ground level (AGL), 

as indicated by the procedures specified in the operator’s manual. All altitude reported to 

ATC must be in feet AGL.

4. The US must be operated within visual line of sight (LOS) of the PIC at all times. 

5. All operations will utilize a visual observer (VO). This roll can be fill by a second person or by 

the PIC during an autonomous mission. 

6. The operator’s manual included in Appendix B and this petition of exemption must be 

maintained 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 

operator’s manual, the conditions and limitations herein take precedence and must be 

followed. Otherwise, the operator must follow the procedures as outlined in its operator’s 

manual.
The operator may update or revise its operator’s manual. It is the operator’s responsibility 

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

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

for extension or amendment. If the operator determines that any update or revision would 

affect the basis for which the FAA grants this petition for exemption, then the operator must 

petition for an amendment to their exemption. The FAA’s UAS Integration Office (AFS-80) 

may be contacted if questions arise regarding updates or revisions to the operator’s manual. 

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

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

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

UAS is found to be in a condition for safe flight. The Ground Control Station, if utilized, must 

be included in the preflight inspection. All maintenance and alterations must be properly 

documented in the aircraft records. 

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

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

functional test flight in accordance with the operator’s manual. The PIC, who conducts the 

functional test flight, must make an entry in the UAS aircraft records of the flight. The 

requirements and procedures for a functional test flight and aircraft record entry must be 

added to the operator’s manual. 

9. The operator must follow the manufacturer’s UAS aircraft/component: maintenance, 

overhaul, replacement, inspection, and life limit requirements. When unavailable, aircraft 

maintenance/component/overhaul, replacement, and inspection/maintenance 

requirements must be established and identified in the operator’s manual. At a minimum, 

requirements for the following must be included in the operator’s manual: a. 

Actuators/Servos; b. Transmission (single rotor); c. Power plant (motors); d. Propellers; e. 

Electronic speed controller; f. Batteries; g. Mechanical dynamic components (single rotor); 

h. Remote command and control; i. Ground control station (if used); and j. Any other 

components as determined by the operator. Any 2m micro/miniature repair maintenance 

that is conducted on the sUAS will be in accordance with aviation standards. 

10. The Pilot In Command (PIC) must possess, at least, a current third-class medical certificate. 

11. Prior to operations conducted for the purpose of infrastructure inspections, the PIC must 

have accumulated and logged, in a manner consistent with 14 CFR § 61.51(b), a minimum of 

200 flight cycles and 25 hours of total time as a UAS rotorcraft pilot and at least 10 hours 

logged as a UAS pilot with a similar UAS type (single blade or multirotor). Prior documented 

flight experience that was obtained in compliance with applicable regulations, may satisfy 

this requirement. Training, proficiency, and experience-building flights can also be 

conducted under this petition of exemption to accomplish the required flight cycles and 

flight time. 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. 

12. Prior to any flight operations authorized by this petition of exemption, the PIC and VO must 

have successfully completed a qualification process, as outlined in the standard operating 

procedures manual. As this is a requirement stipulated by the operator, the test must be 

developed and implemented by a qualified person designated at the sole discretion of the 

CEO. A record of completion of this qualification process must be documented and made 

available to the Administrator upon request. 
13. Prior to operations conducted for the purpose of infrastructure inspection, a flight 

demonstration, administered by an operator-approved/qualified pilot must be successfully 

completed and documented. This documentation must be available for review upon request 

by the Administrator. Once the knowledge and airmanship test qualifications have been 

developed by the operator, and there are no established practical test standards that 

support a jurisdictional FAA FSDO evaluation and approval of company designated 

examiners, the petitioner will conduct these tests in accordance with the operator’s manual. 

14. The UA may not be operated directly over any person, except authorized and consenting 

personnel, below an altitude that is hazardous to persons or property on the surface in the 

event of a UAS failure or emergency. 

15. Regarding the distance from participating persons, the operator’s manual has safety 

mitigations for authorized and consenting personnel. At all times, those persons must be 

essential to the operations. 

16. Regarding distance from nonparticipating persons, the operator must ensure that no 

persons are allowed within 500 feet of the area, except those consenting to be involved and 

necessary for the infrastructure inspection operations. This provision may be reduced to no 

less than 200 feet if it would not adversely affect safety, and the Administrator has 

approved it. For example, an equivalent level of safety may be determined by an aviation 

safety inspector’s evaluation of the infrastructure inspection area to note terrain features, 

obstructions, buildings, safety barriers, etc. Such barriers may protect nonparticipating 

persons (observers, the public, news media, etc.) from debris in the event of an accident. 

17. If the UAS loses communications, or loses its GPS signal, the UAS must return to a predetermined location within the security perimeter, and land or be recovered in accordance 

with the operator’s manual. 

18. The UAS must abort the flight in the event of unpredicted obstacles or emergencies in 

accordance with the operator’s manual. 

19. Each UAS operation must be completed with 25% battery power remaining. 

20. The operator must obtain an Air Traffic Organization (ATO) issued Certificate of Waiver, or 

Authorization (COA), prior to conducting any operations under this petition of exemption. 

This COA will also require the operator to request a Notice to Airman (NOTAM) not more 

than 72 hours in advance, but not less than 48 hours prior to the operation. 

21. 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. 

22. The operator must develop procedures to document and maintain a record of the UAS:

maintenance, preventative maintenance, alterations, status of replacement/overhaul 

component parts, and the total time in service of the UAS. These procedures must be added 

to the operator’s manual. 

23. Each UAS operated under this exemption, must comply with all manufacturer Safety 

Bulletins. 

24. The operator must develop UAS technician qualification criteria. These criteria must be 

added to the operator’s manual. 

25. The preflight inspection section in the operator’s manual must be amended to include the 

following requirements: the preflight inspection must account for all discrepancies, i.e. 

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

inspection sections of the operator’s manual. 
26. Before conducting operations, the radio frequency spectrum used for operation and control 

of the UA must comply with the Federal Communications Commission (FCC) or other 

appropriate government oversight agency requirements. 

27. At least three days before scheduled infrastructure inspection within the 5 mile radius of an 

airport, the operator of the UAS affected by this exemption must submit a written Plan of 

Activities to the local FSDO with jurisdiction over the area of proposed infrastructure 

inspection. 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 infrastructure inspection 

operations conducted under this petition 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 infrastructure inspection 

event

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

local officials to conduct the infrastructure inspection event; the list of those who gave 

permission must be made available to the inspector upon request

g. Signature of exemption-holder or representative

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

county, and/or state over which infrastructure inspection will be conducted, and the 

altitudes essential to accomplish the operation. 

28. The 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. 

29. The UA must remain clear and yield the right of way to all other manned operations and 

activities at all times. Including, but not limited to: ultralight vehicles, parachute activities, 

parasailing activities, hang gliders, etc... 

30. 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. 

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

predesignated routes are used and the PIC is not operating the vehicle. 

32. The UAS may not be operated less than 500 feet below or less than 2,000 feet horizontally 

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

33. The UAS may not operate in Class B, C, or D airspace without written approval from the FAA. 

The UAS may not operate within 5 nautical miles of the geographic center of a non-towered 

airport, as denoted on a current FAA-published aeronautical chart, unless a letter of 

agreement with that airport’s management is obtained, and the operation is conducted in 

accordance with a NOTAM as required by the operator’s COA. The letter of agreement with 

the airport management must be made available to the Administrator upon request. 
34. 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. Further flight operations may not be conducted until the incident, accident, 

or transgression is reviewed by AFS-80 and authorization to resume operations is provided. 

 

Support for Petition for Exemption

In accordance with the procedural requirements of 14 C.F.R. §11.81, Squadron Optics LLC 

provides the following information: 

Contact Information: 

Nathan Rea

Owner/ Operator 

Squadron Optics LLC

3220 Honey Locust Dr. 

Loveland, CO 80538

(970)685-7602

squadronoptics@gmail.com

Regulatory Provisions from which Squadron Optics LLC seeks an Exemption

Squadron Optics LLC believes it may need an exemption from the following provisions to 

conduct the contemplated operations. In some instances, relief is needed because relief 

from another provision renders compliance with the regulation at hand infeasible. 

333 Aircraft Exemption Status 

14 C.F.R. §61.113(a) and (b) 

14 C.F.R. §91.119(c) 

14 C.F.R. §91.121 

14 C.F.R. §91.151

14 C.F.R. §91.203 (a) and (b)

14 C.F.R. §91.405(a) 

14 C.F.R. §91.407(a) 

14 C.F.R. §91.409(a)(1)&(2) 

14 C.F.R. §91.417(a)&(b) 

Squadron Optics LLC believes an exemption is only needed from the above-listed regulatory 

provisions. To the extent that the FAA believes that additional relief is required for 

Squadron Optics LLC to conduct the operations described here, we request an exemption 

from any such regulatory provisions as well.3

3

For example, 14 C.F.R. §91.417(a) imposes certain maintenance record keeping requirements “as applicable”. 

Since none of the underlying requirements (e.g., inspection intervals) can be met and will require an exemption, 

Squadron Optics LLC believes a separate exemption should not be required for §91.417(a). 
The Extent of Requested Relief and the Reasons Relief is Needed

Section 333 Aircraft Exemption Status: 

Section 333 of the Modernization Act authorizes the FAA to exempt aircraft from the requirement for an 

airworthiness certificate based on a consideration of the size, weight, speed, operational capability of 

the particular UAS, as well as its proximity to airports and populated areas. An analysis of these criteria 

demonstrates that the sUAS operated without an airworthiness certificate in the areas, and under the

conditions contemplated by Squadron Optics LLC will be at least as safe, or safer, than a conventional 

aircraft (fixed wing or rotorcraft) operating with an airworthiness certificate, without the conditions 

proposed in this request. 

The sUAS is less than 55 pounds fully loaded, carries neither a pilot nor passenger, and operates 

exclusively within a secured area. Unlike other civil aircrafts, operations under this exemption will be 

tightly controlled and monitored by the operator and observer. Operations will be conducted in 

compliance with the FAA and with local public safety requirements to provide security for the area of 

operation, as is now done with conventional equipment, infrastructure, bridge and out building 

evaluation. These safety enhancements provide an expanded degree of safety to the inspectors over 

conventional operations. Lastly, application of these same criteria demonstrates that there is no credible 

threat to national security posed by the sUAS, due to its: size, speed of operation, location of operation, 

lack of explosive materials, and inability to carry a substantial external load. 

Given the size and limited operating area associated with the aircraft to be utilized by the Applicant, this 

meets the requirements of an equivalent level of safety under Part 11 and Section 333 of the Reform 

Act. The Federal Aviation Act (49 U.S.C.§44701 (f)) 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 

particular sUAS. In all cases, an analysis of these criteria demonstrates that the UAS operated without an 

airworthiness certificate, in the restricted environment, and under the conditions proposed will be at 

least as safe, or safer, than a conventional aircraft (fixed wing or rotorcraft) operating with an 

airworthiness certificate without the restrictions and conditions proposed. 

 

14 C.F.R. §61.113(a) and (b) §61.113

Private pilot privileges and limitations: Pilot in command. 

(a) Except as provided in paragraphs (b) through (h) of this section, no person who holds a 

private pilot certificate may act as pilot in command of an aircraft that is carrying passengers 

or property for compensation or hire; nor may that person, for compensation or hire, act as 

pilot in command of an aircraft. 

(b) A private pilot may, for compensation or hire, act as pilot in command of an aircraft in 

connection with any business or employment if: 

(1) The flight is only incidental to that business or employment; and 

(2) The aircraft does not carry passengers or property for compensation or hire. 

***** 

Squadron Optics LLC anticipates initially using a cadre of specially trained staff to conduct 

the sUAS operations. These individuals will not hold pilot licenses. The sUAS will not carry 

property for compensation or for hire since they will be used solely to assist in evaluation of 

the infrastructure, equipment, right-of-way, assets, bridges, tunnels and out-buildings in 

furtherance of Squadron Optics client’s primary business. However, the employees’ 
operation of the sUAS will not be incidental to their employment with Squadron Optics LLC, 

and they will be compensated for such work. Without an exemption, the pilot would be 

required to hold a commercial pilot certificate under §61.133. However, the risk associated 

with the contemplated operations is less than the risk posed by a traditional aircraft. The 

sUAS will fly at altitudes well below the permissible limits for other civil aircraft, eliminating 

the risk to other aircraft, and within a geographical envelope under the sole control of 

Squadron Optics clients. Accordingly, the risk would be limited to Squadron Optics

personnel, who will be appropriately outfitted in safety gear, and Squadron Optics client’s 

property on the ground. Requiring a commercial pilot certificate would provide no 

appreciable safety benefit, and would needlessly impose additional cost on Squadron 

Optics. Relief is needed from both paragraphs (a) and (b) because the contemplated 

operations would not comply with §61.113(b)(1) and none of the other exceptions to 

paragraph (a) apply.

14 C.F.R. 91.119(c) §91.119

Minimum safe altitudes: General.

Except when necessary for takeoff or landing, no person may operate an aircraft below the 

following altitudes: 

*** 

(c) Over other than congested areas. An altitude of 500 feet above the surface, except over 

open water or sparsely populated areas. In those cases, the aircraft may not be operated 

closer than 500 feet to any person, vessel, vehicle, or structure. 

*****

Squadron Optics submits that the only relief it requires from §91.119 is from the minimum 

altitudes listed in paragraph (c). Relief is required from paragraph (c) for fixed wing operations because 

asset evaluation conducted at 500 feet or higher is insufficiently distinct to be meaningful. Since 

operations at this altitude also pose a heightened risk of collision with another aircraft, safety can only 

be assured through the grant of an exemption. The anticipated rotorcraft operations should be 

adequately addressed by paragraph (d) (1). Additionally, relief should not be needed from paragraph (a) 

because an emergency landing of the aircraft, due to a power failure, will not create an undue hazard to 

persons or property on the surface. As noted in the explanation of why an exemption will not adversely 

affect safety, Squadron Optics clients have exclusive use of the land over which the sUAS will be 

operated, and public access is restricted. It also has exclusive use of significant portions of land adjacent 

to the infrastructure and structures that will be the objects of evaluation and analysis. Squadron Optics

Clients tightly control access to land and have the ability to assure that no individuals unassociated with 

the planned operations are on the affected land. As such, the risk of injury is minimal. Squadron Optics

does not contemplate conducting operations over congested areas, so relief is not requested from 

paragraph (b). 

14 C.F.R. 91.121 

14 C.F.R. §91.121 Altimeter Settings

This regulation requires each person operating an aircraft to maintain cruising altitude by 

reference to an altimeter that is set “...to the elevation of the departure airport or an 

appropriate altimeter setting available before departure.” 

***** 

As the sUAS may not have a barometric altimeter, but instead a GPS altitude read out, an 

exemption may be needed. An equivalent level of safety will be achieved by the operator, pursuant to 
the Manual and Safety Check list, confirming the altitude of the launch site shown on the GPS altitude 

indicator before flight. 

Altitude information will be provided to the sUAS pilot via a digitally encoded telemetric data 

feed, which downlinks from the aircraft to a ground-based on-screen display. This altitude information 

will be generated by equipment installed on board the aircraft, using GPS triangulation, or digitally 

encoded barometric altimeter, or radio altimeter, or any combination thereof. Prior to each flight, a zero 

altitude initiation point will be established and confirmed for accuracy by the pilot. 

14 C.F.R. 91.151 

§91.151 Fuel requirements for flight in VFR conditions.

(a) No person may begin 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. 

(b) No person may begin a flight in a rotorcraft 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, to fly after that for at least 20 minutes. 

***** 

Operating the sUAS in a pre-defined area, with less than 30 minutes of reserve fuel, does not 

raise the type of risk contemplated by §91.151, i.e., that an aircraft could run out of fuel in the event it 

has to be flown to an alternate airport, or circle the planned airport in the event of unanticipated 

conditions. Squadron Optics does not intend to use the sUAS for point-to-point flights, and will not 

operate the sUAS beyond visual line of sight. Nor will the sUAS require an airport in order to land. 

Rather, Squadron Optics will operate the sUAS using pre-planned flight paths (taking into account 

weather conditions) designed to allow the sUAS to fly to the point of intended landing. As such, there is 

no need for a time based excess fuel requirement. Rather it should be sufficient to require only as much 

additional excess flight capacity as necessary to safely land the sUAS. We believe that a 25% battery 

reserve is more than sufficient to meet this objective. 

 

14 C.F.R. 91.405(a), 91.407(a) (1), 14 C.F.R. 91.409(a) (1)&(2) and 14 C.F.R. 91.417(a) & (b) 

§91.405 Maintenance required.

Each owner or operator of an aircraft –

(a) 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; 

***** 

§91.407 Operation after maintenance, preventive maintenance, rebuilding, or alteration.

(a) No person may operate any aircraft that has undergone maintenance, rebuilding, or 

alteration unless –

(1) It has been approved for return to service by a person authorized under §43.7 of this 

chapter.

***** 

§91.409 Inspections.

(a) Except as provided in paragraph (c) of this section, no person may operate an aircraft 

unless, within the preceding 12 calendar months, it has had __ 

(1) An annual inspection in accordance with part 43 of this chapter and has been approved 

for return to service by a person authorized by §43.7 of this chapter; or 
(2) An inspection for the issuance of an airworthiness certificate in accordance with part 21 

of this chapter. 

***** 

§91.417 (a) & (b)

***** 

Squadron Optics believes that an exemption from these three maintenance requirements is 

appropriate because the FAA has not developed maintenance standards that would allow an operator to 

meet the part 91 maintenance requirements. In particular, there are no individuals authorized by the 

FAA to approve a sUAS for return to service under §91.407(a) or to conduct the initial airworthiness and 

annual return to service inspections required by §91.409(a). Squadron Optics will maintain the aircraft 

as instructed in the owner’s manual and ASTM F2909, where applicable, and will not operate the aircraft 

until it has reasonably determined that any needed repairs have been made. However, because of the 

technical impossibility of meeting the requirements of §§91.405(a), 407(a), 409(a) and 417(a) and (b), 

we believe an exemption from these provisions is appropriate. 

Please do not hesitate to contact me at the phone number or via the e-mail address provided above 

should you have any questions or concerns. Respectfully submitted,

 

Nathan A. Rea 

Owner/Operator 

Squadron Optics LLC
Appendix A

Summary for Federal Register Publication

 

Pursuant to 14 C.F.R. Part 11, the following summary is provided for publication in the Federal Register 

should the FAA determine that publication is needed. 

Petitioner: Squadron Optics LLC

 

Sections of 14 C.F.R. Affected: 

333 Aircraft Exemption Status 

14 C.F.R. §61.113(a) and (b) 

14 C.F.R. §91.119(c) 

14 C.F.R. §91.121 

14 C.F.R. §91.151

14 C.F.R. §91.203 (a) and (b)

14 C.F.R. §91.405(a) 

14 C.F.R. §91.407(a) 

14 C.F.R. §91.409(a) (1) & (2)

14 C.F.R. §91.417(a)&(b)

 

Description of Relief Sought:

 

Petitioner seeks relief from the requirements of 333 Aircraft Exemption Status, 14 C.F.R., 

61.113(a)&(b), 91.7 (a), 91.119(c), 91.121, 91.151, 91.203 (a)&(b), 91.405(a), 91.407(a), 

91.409(a)(1)&(2), and 91.417(a)&(b) to conduct sUAS operations over Squadron Optics LLC 

client owned or controlled land, solely during daylight hours, to assist in the safe evaluation 

and analysis of infrastructure and operations. In general, sUAS operations are intended to 

be conducted in areas remote from both congested areas and airports. The nature of 

operations anticipated by Squadron Optics LLC requires that the sUAS be flown at relatively 

low altitudes. Squadron Optics LLC expects that in most instances, the sUAS will be flown 

less than 100 feet from the highest structure along the path of the sUAS and in no instances 

will be flown higher than 400 feet above the ground. Accordingly, the risk of interference 

with other aircraft is minimal. 
Appendix B

3D Robotics X8+

See link to manual for X8

http://3drobotics.com/wp-content/uploads/2014/03/RTF-X8-Manual-V2.pdf