Dear Sir or Madam:

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

C.F.R. Part 11, Space Coast Aerial Surveillance LLC (SCAS), operator of small Unmanned Aircraft 

Systems (“sUAS”) to conduct aerial surveillance, cinematography and photography, hereby applies for an 

exemption from the listed Federal Aviation Regulations (“FARs”) to allow commercial operation of its 

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

As described more fully below, the requested exemption would permit the operation of sUAS under 

controlled conditions in airspaces that are 1) limited 2) predetermined and 3) controlled in regards to 

access and 4) would provide safety enhancements to the already best practices safety protocols followed 

by Space Coast Aerial Surveillance. 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.” Section 333(c) of the 

Reform Act. 

The name and address of the pursuant is as follows:

Ryan S. Eaton

Space Coast Aerial Surveillance LLC

2160 Judge Fran Jamieson Way APT 113

Melbourne, FL 32940

772-485-4643

info@spacecoastuas.com

Regulations from which the exemption is requested:

14 CFR Part 21

14 C.F.R. 45.23(b)

14 CFR 61.113 (a) & (b)

14 C.F.R. 91.7 (a)

14 CFR 91.9 (b) (2)

14 C.F.R. 91.103

14 C.F.R. 91.109

14 C.F. R. 91.119

14 C.F.R. 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)

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AUTHORITY FOR EXEMPTIONS

The Federal Aviation Act expressly grants the FAA authority to issue exemptions. This statutory

authority includes exempting civil aircraft, as the term is defined under §40101 of the Act, including 

sUASs, from the requirement that all civil aircraft must have a current airworthiness certificate.

The Administrator may grant an exemption from a requirement of a regulation prescribed under 

subsection (a) or (b) of this section or any sections §44702-44716 of this title if the Administrator 

finds the exemption in the public interest. 49 USC §44701(f). See also 49 USC §44711(a); 49 USC

§44704; 14 CFR 91.203(a)(1).

Section 333(b) of the Reform Act assist the Secretary in determining whether sUASs may operate in 

the national airspace system without creating a hazard to the user, the public, or a threat to national 

security. In making this determination, the Secretary must consider:

A. The sUAS’ size, weight, speed and operational capability;

B. Whether the sUAS operates within the visual line of sight of the operator;

C. Whether the sUAS operates outside of highly populated areas and away from close proximity 

to airports.

Reform Act 333(a). If the Secretary determines that a sUAS “may operate safely in the national airspace 

system, the Secretary shall establish requirements for the safe operation of such aircraft in the national 

airspace system.” Id. 333(c).

The Tarot 680 Pro is a multirotor aircraft weighing up to 10 pounds, including payload (camera and 

battery). Likewise, the Tarot 960 Multirotor operates at a maximum of 30 pounds, due to battery 

options. Both multirotors have the ability to operate under normal conditions at a speed of no more than 

50 mph and has the capability to hover and move in the vertical and horizontal plane simultaneously. 

The sUAS will operate only in the pilot’s or observer’s visual line of sight at all times. Such operations 

will insure that the sUAS will “not create a hazard to users of the national airspace system or the 

public.” Reform Act Section 333(b).

Given the small size of the sUAS involved and the restricted environment within which they will operate, 

our application falls squarely within the zone of safety (an equivalent level of safety) in which Congress 

envisioned that the FAA must, by exemption, allow commercial operations of sUASs to commence 

immediately. Also due to the small size of the UAS and the low altitudes in which our sUAS will operate, 

approval of the application presents no national security issue.

VEHICLE DESCRIPTION

The sUAS Space Coast Aerial Surveillance proposes are constructed from two separate classes of

multirotor craft (Tarot 680 Pro and Tarot 960), each having a maximum of 6 propellers. The Tarot 680 

Pro has an "all up weight" (AUW), meaning the total amount of weight with camera payload and lithium 

polymer batteries of 10 pounds (lbs). The Tarot 960 has an AUW with camera payload and lithium 

polymer batteries up to 30 pounds (lbs). Each multirotor can be operated up to a wind threshold of 35 

miles per hour (mph), with gusts up to 55. Additionally, each multirotor is equipped with GPS and 

ground station equipment, which allows the operator to pre-program designated flight paths, respecting 

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defined no fly zones, legal flight ranges and altitude ceilings so the system cannot enter areas deemed

unsafe or unnecessary to flyover. 

Both sUAS craft maintain the ability to take full manual control at any time during semi or 

autonomous flight. If communication is lost with the control transmitter, regardless of semi or 

autonomous flight modes, the on board flight controller will immediately start a return-to-home 

procedure and arrive at the original source point of lift off. The same return to home feature is also 

configured for low battery levels and wind thresholds that exceed limits during the planned flight. Should 

battery become critically low during flight, the sUAS will begin a self landing procedure, while its GPS 

will remain online to transmit telemetry data for recovery.

All flight operations are global positioning system (GPS) controlled, making the system easyto

navigate. At any point if the operator is not explicitly commanding the system to move, the system 

automatically holds its GPS position. The flight control system employs not onlyGPS positioning but a

variety of sensors including sonar, barometric pressure, temperature, wind speed and others to ensure 

stability so long as wind thresholds are not exceeded. Also a flight termination link – to prevent a “fly 

away” or other potentially dangerous situation – is available to theoperator.

DESCRIPTION OF SPECIFIC REGULATIONS

14 CFR Part 21, Subpart H: Airworthiness certificates

Subpart H, 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 Space Coast Aerial Surveillance, 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 USC §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 sUAS 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 operating with an airworthiness certificate without 

the restrictions and conditions proposed.

14 CFR 45.23(b): Marking of the aircraft

This regulation requires that certain experimental, provisionally certified aircraft, or light-sport 

category aircraft to be marked with letters between 2 inches and 6 inches high “limited”, “restricted,” 

“light-sport,” “experimental,” or “provisional,” near each entrance to a cabin, cockpit or pilot station.

Even though the UAS will have no airworthiness certificate, an exemption may be needed as the sUAS

will have no entrance to the cabin, cockpit or pilot station on which the word “Experimental” can be 

placed. Given the size of the sUAS, 2 inch lettering will be impossible. Space Coast Aerial 

Surveillance will mark the sUAS with the organization’s name and address. An insurance barcode 

attached to the aircraft will also be linked to Space Coast Aerial Surveillance.

14 CFR 61.113(a) & (b): Private pilot privileges and limitations: Pilot in command

Sections 61.113(a) and (b) limit private pilots to non-commercial operations. Because the sUAS will 

not carry a pilot or passengers, the proposed operations can achieve the equivalent level of safety of 

current operations by requiring the pilot operating the aircraft to have completed at least 20 hours of 

sUAS observation time, as well as 50 hours flying a sUAS for non-commercial or government use, but 

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strictly as hobby use (as not to endanger civilians or property whilst learning pilot skills). Unlike a 

conventional aircraft that carries the pilot and passengers, the sUAS is remotely controlled with no 

living thing or cargo on board. The area of operation is controlled and restricted, and all flights are 

planned and coordinated in advance with Space Coast Aerial Surveillance staff and the services 

customer, referred to as "pre-flight planning". The risks associated with the operation of the small UAS 

are so diminished from the level of risk associated with commercial operations contemplated by Part 61 

when drafted, that allowing operations of the sUAS as requested exceeds the present level of safety 

achieved by 14 CFR 61.113(a) and (b).

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. Safety checklists will be performed 

to validate that an equivalent level of safety has be conducted before and after each flight.

14 CFR 91.9(b)(2): Civil aircraft flight manual, marking and placard requirements

The sUAS, 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 User Manual at the ground control 

point where the pilot flying the sUAS will have immediate access to it.

14 CFR 91.103: Preflight action

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

of flight. An exemption is needed from this requirement as the pilot will take separate preflight 

actions, including checking for weather conditions, checking flight battery requirements, validating 

GPS connectivity and fail safes, checking takeoff and landing distances, and all other actions listed in 

safety checklists. These actions will provide an equivalent level ofsafety.

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. By design, sUASs 

and remotely piloted aircraft 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 

equivalent level of safety is provided by the fact that neither a pilot nor passengers will be carried in the 

aircraft, the ability to control the sUAS via radio signals from the controller 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. This exemption is 

for a multirotor craft that flies similarly to a helicopter, with vertical takeoff and vertical landing, which 

will typically operate at altitudes of 200 feet above ground level (AGL), so an exemption may be 

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needed to allow such operations. The sUAS will never operate at altitude higher than 400 AGL and all 

operations will occur during daylight hours under Visual Meteorological Conditions (VMC)only.

The equivalent level of safety will be achieved given the size, weight and speed of the sUAS as well as 

the location where it is operated. No flight will be taken without the permission of the property owner or 

local officials. Because advance notice to the property owner and any onsite personnel, as well as the 

precautions outlined below, all affected individuals will be aware of the planned flight operations.

Flight operations will be conducted at least 500 feet from all non-participating persons (persons other 

than the pilot in command (PIC) or visual observer (VO)), vessels, vehicles and structures, unless:

A. Barriers or structures are present that sufficiently protect non-participating persons from

debris in the event of an accident. The PIC will ensure that non-participating persons remain

under such protection. If a situation arises where non-participating persons leave such

protection and are within 500 feet of the sUAS, flight operations will cease immediately

and/or;

B. The aircraft is operated near vessels, vehicles or structures where the land

owner/controller has granted permission and the PIC has made a safety assessment

of the risk of operating closer to those objects and;

C. Operations near the PIC or VO do not present an undue hazard to the PIC or VO, per 

14 CFR 91.119(a).

The sUAS will remain within visual line of sight of the PIC or VO. Flight operations will be 

conducted at least 5 miles from an airport and at least 3 miles from any city or densely populated 

area. The PIC or VO will provide notification to the local Flight Standards District Office and 

airport controller of all operations within 5 miles of an airport. The FAA will have advance 

notice of all operations through the filing of notices-to-airmen.

Compared to flight operations with aircraft or rotorcraft weighing far more than the sUAS 

proposed herein and carrying flammable fuel, any risk associated with our operations is far less

than those presently presented with helicopters and other conventional aircraft operating at or

below 500 feet AGL. In addition, the low-altitude operations of the sUAS will ensure

separation between these 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 the 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 PIC confirming the altitude of the launch site shown on the GPS altitude indicator 

beforeflight.

14 CFR 91.151(a): Fuel requirements for flight in VFR conditions

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Section 91.151(a) outlines fuel requirements for beginning a flight in VFR conditions. Our sUAS is 

limited to operations in controlled environments and has a limited flight time which require an 

exemption from 14 CFR 91.151(a).

The battery powering the sUAS provides approximately 25 minutes of powered flight. This would 

render the sUAS unable to meet the 30 minute reserve requirement in 14 CFR 91.151. Given the 

limitations on the sUAS’s proposed flight area and the location of its proposed operations within a 

predetermined area, a longer time frame for flight in daylight VFR conditions isreasonable.

An equivalent level of safety can be achieved by limiting flights to 20 minutes, or enough battery 

reserve to ensure that the sUAS lands at the ground station with at least 20% of battery power (as 

determined by the onboard monitoring system and the PIC), whichever happens first. This restriction 

would be more than adequate to return the sUAS to its planned landing zone from anywhere in its 

limited operatingarea.

14 CFR 91.203(a) & (b): Carrying civil aircraft certification and registration

The sUAS has no cabin, cockpit or pilot station and is operated without an onboard pilot. 

Therefore, there is no ability or place to carry certification and registration documents or to 

display them on the sUAS.

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

point where the pilot flying the sUAS will have immediate access to them, to the extent they are 

applicable to the sUAS.

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 sections and Part 43 apply only to aircraft with an airworthiness certificate,

these sections will not apply to Space Coast Aerial Surveillance. Maintenance will be accomplished by

the operator pursuant on an as needed basis, subject to validation after each flight. An equivalent level 

of safety will be achieved because these sUAS are very limited in size and will carry a small payload 

and operate only in restricted areas for limited periods of time. If mechanical issues arise, the sUAS can 

land immediately and will be operating from no higher than 400 feet AGL. The operator pursuant will 

ensure that the sUAS is in working order prior to initiating flight, validate all post flight checks are 

inversely performed from preflight checks, perform required maintenance of sUAS and additional 

ground station equipment 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.

PUBLIC INTEREST

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Granting the present Petition will further the public interest by allowing Space Coast Aerial 

Surveillance LLC to safely, efficiently, and economically perform aerial video and photography of 

special events, film sets, and landscape over certain areas of the United States. sUAS Visual Observers 

are also Certified Protected Species Observers. Additionally, use of the Tarot T680/T960 UAS will 

reduce risk to older conventional methods of aerial surveying, reduce pollution and decrease congestion 

of the NAS. Notably, the benefits of Space Coast Aerial Surveillance LLC’s proposed operation of the 

Tarot T680/T960 UAS will be realized without implicating any privacy issues.

Conducting aerial acquisitions with the Tarot T680/T960 UAS, instead of manned aircraft, will 

greatly benefit the public by drastically reducing the levels of air and noise pollution generated during 

traditional aerial video and still photography flight operations. By using battery power and electric 

motors, the Tarot T680/T960 sUAS produce no air pollution, and is the most viable environmentally 

conscious alternative to the cabin class, six cylinder internal combustion engine aircraft that are 

typically utilized for aerial video and photography, while burning approximately 20-30 gallons per hour

of leaded aviation fuel. The Tarot T680/T960, while reducing the carbon footprint of aerial acquisitions, 

also eliminates noise pollution, as the UAs are propelled by battery powered electric motors, rather than 

an internal combustion engine.

By using the Tarot T680/T960 UAS to perform aerial acquisitions, the substantial risk to life 

and property in the air and on the ground, which is usually associated with traditional manned aircraft 

flight operations, will be substantially reduced or completely eliminated. Aside from the lack of flight 

crew members located onboard the aircraft, the Tarot T680/T960 has less physical potential for 

collateral damage to life and property on the ground, and in the air, compared to the manned aircraft that 

typically conduct similar operations (weighing approximately 6,000 pounds with a wingspan of 

approximately 42 feet, a length of 34 feet, and a fuel capacity of 180 gallons).

By reducing the number of manned aircraft operating in the NAS, congestion around airports 

caused by arriving and departing aircraft will be reduced. Likewise, a reduction of manned aircraft 

conducting aerial video and photography missions would result in fewer aircraft that must be handled by 

air traffic control during the ground, takeoff, departure, arrival, and landing phases of flight operations.

The visual observers (VO) that will be participating in Space Coast Aerial Surveillance's 

operations are certified Protected Species Observers. In addition to providing visual awareness and 

observations respective to sUAS operations, it is the VO's responsibility to report any observations that 

are deemed life-threatening to a protected or critically endangered species to the corresponding local 

wildlife agencies as well as Federal agencies.

EQUIVALENT LEVEL OF SAFETY

Space Coast Aerial Surveillance LLC operates Tarot T680/T960 professional grade multirotors in 

its inventory of sUAS. These limitations provide for at least an equivalent or even higher level of safety to 

operations under the regulator structure because the proposed operations are enhancements to already safe 

protocols defined for aerial survey operations regarding helicopters and other conventional aircraft.

Space Coast Aerial Surveillance sUASs will abide and adhere to the following limitations during all 

operations under an FAA issues exemption:

1. The maximum weight of proposed sUAS will weigh less than 55 pounds.

2. Minimum crew for each operation will consist of the sUAS pilot (Pilot-in-Command) and Visual

Observer (VO).

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3. PIC will hold either a private or sport pilot certificate

4. Observer and pilot will at all times be able to communicate verbally

5. Flights will be operated within visual line of sight (VLOS) of the UAS pilot and aircrew 

(Spotter/Observer)

6. Maximum total flight time is limited to 30 minutes, during daylight only. Flights will be 

terminated at 25% battery power reserve should that occur prior to the 30 minute limit.

7. The pilot and visual observer will have been trained in the operation of the sUAS 

8. Flights will be operated at an altitude of no more than 400 feet AGL or, not more than 200 feet 

above an elevated platform from which filming is planned.

9. Flight operations will be conducted 5 nautical miles from an airport and at least 3 statute miles 

from any city or densely populated area.

10. Flight operations will not proceed when wind conditions exceed 20 mph consistently

11. Proposed sUAS will have a governed top speed of 50 mph

12. Proposed sUAS will be equipped with GPS fail safes, programmed to avoid restricted Airspaces 

and No-Fly zones 

13. Proposed sUAS will return to home on radio control signal loss if sustained for more than 10 

seconds

14. Proposed sUAS will have the capability to abort flight in case of unpredicted obstacles or 

emergencies. 

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

16. The operator will submit a written Plan of Activities to the FSDO three days before the proposed 

shoot as required in Section E and F of the Manual.

17. The sUAS PIC is required to have and maintain an active Academy of Model Aeronautics 

(AMA) membership.

PRIVACY

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

consent and knowledge. Images taken will be of individuals who have also consented to being filmed or 

otherwise have agreed to be in the area where aerial photography will take place.

FEDERAL REGISTER SUMMARY

Ryan S. Eaton, Aerial Surveyor and Cinematographer, Space Coast Aerial Surveillance LLC, 2160 Judge 

Fran Jamieson Way APT 113, Melbourne, Florida 32940 petitioned the FAA on behalf of Space Coast 

Aerial Surveillance LLC, (Space Coast Aerial Surveillance) for an exemption from part 21 and §§ 

45.23(b), 61.113(a) and (b), 91.7(a), 91.9(b)(2), 91.103, 91.109, 91.119, 91.121,91.151(a), 91.203(a) and 

(b), 91.405(a), 407(a)(1), 409(a)(2), 417(a) and (b) of Title 14, Code of the Federal Regulations (14 

CFR). The exemption would allow commercial operation of T680 Pro and T960 small Unmanned 

Aircraft Systems (sUAS) for aerial surveillance and observations, cinematography and photography.

CONCLUSION

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 Space Coast Aerial Surveillances’ sUAS for aerial 

surveys, cinematography and photography.

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My intent is to expand into a new and emerging market that utilizes sUAS in ways that not only reduce 

risk of human life and injury, but to also expand into already existing surveillance fields, such as 

protected species observation for off-shore and terrestrial species, as well as teach the value and 

effectiveness of sUAS use to the general public. I have been flying model aircraft and sUAS since 2008, 

closely following all FAA and AMA negotiations regarding sUAS and have abided by the rules as a 

hobbyist accordingly. I thank you for your consideration of the requested exemptions and look forward to 

the future integration of sUAS in the NAS. I am currently pursuing my Sport Pilot License, however until

such time that I attain my said certificate, the PIC will be hired friend who holds a Private Pilot License.

If you require any additional information, or if I can be of assistance in clarification of items in this 

document, please contact me immediately.

Very Respectfully,

Ryan S. Eaton

Space Coast Aerial Surveillance LLC

Owner/Operator, Aerial Surveyor and Cinematographer

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