11768 Atwood Rd, Suite 20 

January 24, 2015 Auburn, CA 95603

 Tel: (530) 823-6546 

U.S. Department of Transportation 

Docket Management System 

1200 New Jersey Ave, SE 

Washington, DC 20590 

Re: Exemption Request Under Section 333 of the FAA Reform Act and Part 11 of the Federal Aviation 

Regulations 

Dear Sir or Madam: 

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

CFR Part 11, Precision Design & Drafting, Inc. (“PDND”) a professional civil engineering firm hereby 

applies for an exemption from the listed Federal Aviation Regulations ("FARs") to allow commercial 

operation of its UASs, so long as such operations are conducted within and under the conditions 

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

As described more fully below, the requested exemption would support an application for a commercial 

Certificate of Authorization and permit the operation of small, unmanned and relatively inexpensive 

UAS under controlled conditions in airspace including: 

1. Tower structural inspections to existing tower structures – These operations would take 

place with express written permission from the owner of the property for the purpose of 

obtaining detailed structural information. These operations would be conducted in airspace 

previously reviewed by the FAA for the initial construction of the tower and therefore the 

airspace of the controlled area would create no additional hazard to the NAS. 

2. Precision Photogrammetry and Mapping – These operations would take place with express 

written permission from the owner of the property for the purpose of obtaining detailed terrain 

and topographic imagery of land features. These operations would be conducted in airspace no 

more than 400’ AGL and the UAS will remain within Visual Line of Sight of the Pilot in Command 

at all times. 

3. Aerial Imagery of Commercial and Residential Properties – These operations would take 

place with express written permission from the owner of the property for the purpose of 

obtaining quality aerial photos of real estate. These operations would be conducted in airspace 

no more than 400’ AGL and the UAS will remain within Visual Line of Sight of the Pilot in 

Command at all times.

PDND will operate the following drones: 

1. DJI Phantom Vision 2+ 

2. DJI Phantom Vision 3 

3. DJI Phantom Inspire 1 

Precision Design

Drafting, Inc.

&&
We can insure that the combination of the UASs lightweight, historically demonstrated flight 

performance, on board GPS system, fully qualified flight personnel, and strict operation under the 

guidelines established, the FAA can have confidence that PDND’s operation will have an equivalent or 

greater level of safety of manned aircraft performing the same missions. 

Also, given the small size of the UAS’s involved and the restricted controlled environment within which 

they will operate, the applicant fits within that zone of safety (an equivalent level of safety) in which 

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

commence immediately. Also due to the size of the UASs and the controlled areas in which the relevant 

UASs will operate, approval of the application presents no national security issue. Given the following, 

the grant of the requested exemptions is clearly in the public interest: 

PDND proposes that the exemption requested herein apply to civil aircraft that have the characteristics 

and that operate with the limitations listed herein. These limitations provide for an exceptional level of 

safety to operations. These limitations and conditions to which PDND agrees to be bound when 

conducting commercial operations under an FAA issued exemption including: 

1. The UAS will weigh less than 55 lbs. 

2. Flights will be operated within line of sight of operator. 

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

4. Flights will be terminated at 15% battery power reserve. 

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

6. UAS operator will be trained and certified in the proper safety and operations of the UAS. 

7. The UAS will only operate within a controlled area as defined in the Procedures. 

8. The operator will post advisor notice around the controlled area. 

9. The operator will have been trained in operation of UAS generally and received up-to-date 

information on the particular UAS to be operated as required. 

10. If the UAS loses communications or loses its GPS signal, the UAS will have capability to return to a 

pre-determined location within the Security Perimeter and land.

11. The UAS will have the capability to abort a flight in case of unpredicted obstacles or emergencies. 

The public interest will be served by granting PDND’s petition for exemption. Granting this petition for 

exemption will improve safety and reduce risk by minimizing the public’s exposure to danger and 

emissions associated with personnel performing a similar tasks. 

- Tower structural inspections; conventional tower structure inspections and associated tasks 

involve extreme risks to personnel physically climbing such structures and/or utilizing high rise 

equipment both of which create numerous and extreme risk to such personnel which can be 

reduced utilizing a UAS performing similar aerial data collections. 

- Photogrammetry and mapping; steep terrain often poses a risk to personnel which can be 

reduced utilizing a UAS performing similar data collections. 

- Aerial imagery; The UAS’s are battery powered and create no emissions. Also, any accident 

involved a UAS will present a significantly less danger to the pilot or other individuals on the 

ground than one involving a full size aircraft performing similar photos. 
The name and contact information of the applicant are: 

Precision Design & Drafting, Inc. 

11768 Atwood Rd, Suite 20 

Auburn, CA 95603 

Bret McComb, PE 

530-823-6546 

bret@pdnd.com 

Regulations from which the exemption is requested are as follows: 

14 CFR Part 21 

14 CFR 45.23(b) 

14 CFR 91.7(a) 

14 CFR 91.9(b)(2) 

14 CFR 91.103(b)(2) 

14 CFR 91.109 

14 CFR 91.119 

14 CFR 91.121 

14 CFR 91.151(a) 

14 CFR 91.203(a) & (b) 

14 CFR 91.405(a) 

14 CFR 407(a) (1) 

14 CFR 409(a) (2) 

14 CFR 417(a) & (b) 

Accordingly, the applicant respectfully requests that the FAA grant the requested exemption and are 

prepared to modify or amend any part of this request to satisfy the need for an equivalent level of 

safety. We look forward to working with your office. Please contact us at any time if additional 

information or clarifications are needed.

Sincerely, 

Precision Design & Drafting, Inc. 

Bret McComb, PE 

President, CEO 

Appendices: 

A. Exemption Request and Equivalent Level of Safety 

B. Permission Form 
Appendix A 

EXEMPTION REQUESTS AND EQUIVALENT LEVEL OF SAFETY 

Precision Design & Drafting, Inc. requests an exemption from the following regulations as well as any 

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

14 CFR Part 21, Subpart H: Airworthiness Certificates 

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

of airworthiness certificates as required by FAR §91.203(a) (1).

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

Applicant, an exemption from Part 21 Subpart H 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 UAS. 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. 

The UAS to be operated hereunder is less than 55 lbs fully loaded, carries neither a pilot nor 

passenger, carries no explosive materials or flammable liquid fuels, and operates exclusively within a 

controlled area as set out in the Procedures. Unlike other civil aircraft, operations under this exemption 

will be tightly controlled and monitored by the operator, pursuant to the Procedures requirements. 

Lastly, application of these same criteria demonstrates that there is no credible threat to national 

security posed by the UAS, due to its size, speed of operation, location of operation, lack of explosive 

materials or flammable liquid fuels, and inability to carry a substantial external load. 

14 CFR § 45.23 (b). Marking of the Aircraft 

The regulation requires: 

When marks include only the Roman capital letter "N" and the registration number is displayed on 

limited, restricted or light-sport category aircraft or experimental or provisionally certificated aircraft, the 

operator must also display on that aircraft near each entrance to the cabin, cockpit, or pilot station, in 

letters not less than 2 inches nor more than 6 inches high, the words "limited," "restricted," "light-sport," 

"experimental," or "provisional," as applicable. Even though the UAS will have no airworthiness 

certificate, an exemption may be needed as the UAS will have no entrance to the cabin, cockpit or pilot 

station on which the word "Experimental" can be placed. Given the size of the UAS, two-inch lettering 

will be impossible. The word "Experimental" will be placed on the fuselage in compliance with §45.29(f). 

The equivalent level of safety will be provided by having the UAS marked on its fuselage as required by 

§45.29(f) where the operator working with the UAS will see the identification of the UAS as 

"Experimental." The FAA has issued the following exemptions to this regulation to Exemptions Nos. 

10700, 8738, 10167 and 10167 A 

14 CFR §91.7(a): Civil aircraft airworthiness. 

The regulation requires that no person may operate a civil aircraft unless it is in airworthy condition. As 

there will be no airworthiness certificate issued for the aircraft, should this exemption be granted, no 

FAA regulatory standard will exist for determining airworthiness. Given the size of the aircraft and the 

requirements contained in the Procedures for maintenance and use of safety check lists prior to each 

flight, an equivalent level of safety will be provided. 
14 CFR § 91.9(b) (2): Civil Aircraft Flight Manual in the Aircraft. 

Section 91.9(b) (2) provides: 

No person may operate a U.S.-registered civil aircraft ... (2) for which an Airplane or Rotorcraft Flight 

Manual is not required by §21.5 of this chapter, unless there is available in the aircraft a current 

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

any combination thereof. The UAS, given its size and configuration has no ability or place to carry such 

a flight manual on the aircraft, not only because there is no pilot on board, but because there is no room 

or capacity to carry such an item on the aircraft. The equivalent level of safety will be maintained by 

keeping the flight manual at the ground control point where the operator flying the UAS will have 

immediate access to it. The FAA has issued the following exemptions to this regulation: Exemption 

Nos. 8607, 8737, 8738, 9299, 9299A, 9565, 95658, 10167, 10167A, 10602, 32827, and 10700.

14 CFR § 91.103(b): Preflight action 

This regulation requires that each pilot in command shall, before beginning a flight, become familiar with all 

available information concerning that flight. This information must include — (b) for any flight, runway lengths at 

airports of intended use, and the following takeoff and landing distance information... As FAA approved 

rotorcraft flight manuals will not be provided for the aircraft and because runways are not needed for 

takeoff and landing operations, an exemption will be needed. An equivalent level of safety will be 

provided as set forth in Procedures. The operator will take all actions including reviewing weather, flight 

battery requirements, landing and takeoff locations and aircraft performance data before initiation of 

flight. 

14 CFR §91.109: Flight instruction: 

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. UASs 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. See Exemption 

Nos.5778K & 9862A. 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 CFR §91.119: Minimum safe altitudes 

Section 91.119 establishes safe altitudes for operation of civil aircraft. Section 91.119 (d) allows 

helicopters to be operated at less than the minimums prescribed, provided the person operating the 

helicopter complies with any route or altitudes prescribed for helicopters by the FAA. As this exemption 

is for a UAS that is a helicopter and the exemption requests authority to operate at altitudes up to 400 

AGL, an exemption may be needed to allow such operations. As set forth herein, except for the limited 

conditions stated in the Procedures, the UAS will never operate at higher than 400 AGL. The equivalent 

level of safety will be achieved given the size, weight, speed of the UAS as well as the location where it 

is operated. In addition, the low-altitude operations of the UAS will ensure separation between these 

small-UAS operations and the operations of conventional aircraft that must comply with Section 91.119.

14 CFR §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 UAS 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 Procedures and Safety Check list, confirming the altitude of the launch site 

shown on the GPS altitude indicator before flight. 
14 CFR § 91.151(a): Fuel Requirements for Flight in VFR Conditions 

Section 91.151(a) prohibits an individual from beginning "a flight in an airplane under VFR conditions 

unless (considering wind and forecast weather conditions) there is enough fuel to fly to the first point of 

intended landing, and, assuming normal cruising speed - (1) During the day, to fly after that for at least 

30 minutes; or (2) At night, to fly after that for at least 45 minutes." The battery powering the UAS 

provides approximately 40 minutes of powered flight. To meet the 30 minute reserve requirement in 14 

CFR §91.151, UAS flights would be limited to approximately 10 minutes in length. Given the limitations 

on the UAS's proposed flight area and the location of its proposed operations within a predetermined 

area, a longer time frame for flight in daylight or night VFR conditions is reasonable. Applicant believes 

that an exemption from 14 CFR §91.151(a) falls within the scope of prior exemptions. See Exemption 

10673 (allowing Lockheed Martin Corporation to operate without compliance with FAR 91.151(a)). 

Operating the small UAS, in a tightly controlled area, with less than 30 minutes of reserve fuel, does not 

engender the type of risks that Section 91.151(a) was intended to alleviate given the size and speed of 

the small UAS. Additionally, limiting UAS flights to 10 minutes would greatly reduce the utility for which 

the exemption will be granted. Applicant believes that an equivalent level of safety can be achieved by 

limiting flights to 30 minutes or 15% of battery power whichever happens first. This restriction would be 

more than adequate to return the UAS to its planned landing zone from anywhere in its limited

operating area. Similar exemptions have been granted to other operations, including Exemptions 

2689F, 5745, 10673, and 10808. 

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

The regulation provides in pertinent part: 

(a) Except as provided in § 91 .715, no person may operate a civil aircraft unless it has within it the 

following: (1) an appropriate and current airworthiness certificate ... (b) No person may operate a civil 

aircraft unless the airworthiness certificate required by paragraph (a) of this section or a special flight 

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

passengers or crew. The UAS fully loaded weighs no more than 55 lbs and is operated without an on 

board pilot. As such, there is no ability or place to carry certification and registration documents or to 

display them on the UAS. An equivalent level of safety will be achieved by keeping these documents at 

the ground control point where the operator flying the UAS will have immediate access to them, to the 

extent they are applicable to the UAS. The FAA has issued numerous exemptions to this regulation. A 

representative sample of other exceptions includes Exemption Nos. 9565, 9665, 9789, 9789A, 9797, 

9797A, 9816A, and 10700. 

14 CFR §91.405(a); 407(a) (1); 409(a) (2); 417(a) & (b): Maintenance Inspections 

These regulations require that an aircraft operator or owner "shall have that aircraft inspected as 

prescribed in subpart E of this part and shall between required inspections, except as provided in 

paragraph (c) of this section, have discrepancies repaired as prescribed in part 43 of this chapter... ," 

and others shall inspect or maintain the aircraft in compliance with Part 43. Given that these section 

and Part 43 apply only to aircraft with an airworthiness certificate, these sections will not apply to the 

applicant. Maintenance will be accomplished by the operator pursuant to the flight manual and 

operating handbook as referenced in the Procedures. An equivalent level of safety will be achieved 

because these small UASs are very limited in size and will carry a small payload and operate only in 

controlled areas for limited periods of time. If mechanical issues arise the UAS can land immediately 

and will be operating from no higher than 400 feet AGL. As provided in the Procedures, the operator 

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

keep a log of any maintenance performed. Moreover, the operator is the person most familiar with the 

aircraft and best suited to maintain the aircraft in an airworthy condition to provide the equivalent level 

of safety. Pursuant to 14 CFR Part 11, the following summary is provided for publication in the Federal 

Register, should it be determined that publication is needed: 
Applicant seeks an exemption from the following rules: 14 CFR §21, subpart H; 14 CFR 45.23(b); 14 

CFR §§ 61.113(a) & (b); 91.7(a); 91.9(b) (2); 91.103(b); 91.109; 91.119; 91.121; 91.151(a); 91.203(a) & 

(b); 91.405(a); 91.407(a) (1); 91.409(a) (2); 91.409(a) (2) & 91.417(a) & (b) to operate commercially a 

small unmanned vehicle (55lbs or less) for the purpose of inspection, monitoring, mapping and 

photographing attached equipment and engineering studies involving communication towers, wind 

turbine tower facilities and power transmission tower operations. 

Approval of exemptions allowing commercial operations of UASs will create a level of safety by 

reducing risk. Conventional tower structure inspections and associated tasks involve extreme risks to 

personnel physically climbing such structures and/or utilizing high rise equipment both of which create 

numerous and extreme risk to such personnel. In contrast, a UAS weighing fewer than 55 lbs and 

powered by batteries eliminates virtually all of that risk. The UAS will carry no passengers or crew and, 

therefore, will not expose personnel to any of the risks described above. 

The operation of small UASs, weighing less than 55 lbs, conducted in the strict conditions outlined 

above, will provide a level of safety supporting the grant of the exemptions requested herein, including 

exempting the applicant from the requirements of Part 21 and allowing commercial operations. These 

lightweight aircraft operate at slow speeds, close to the ground, and in a controlled environment. 

Privacy 

All flights will occur over private or controlled access property with the property owner's prior consent 

and knowledge. The granting of this exemption request will provide innovative safety operations. 

Satisfaction of the criteria provided in Section 333 of the Reform Act of 2012 - size, weight, speed, 

operating capabilities, proximity to airports and populated areas and operation within visual line of sight 

and national security - provide more than adequate justification for the grant of the requested 

exemptions allowing commercial operation of applicant's UAS in and pursuant to the Procedures 

appended hereto.