September	30,	2015

U.S.	Department	of	Transportation

Docket	Operations

1200	New	Jersey	Ave.,	SE

Washington,	DC	20590

Re:	Submission	of	Request	for	Authorization	to	Conduct	Unmanned	Aircraft	

System	Operations	Allowed	by	Section	333	of	the	FAA	Modernization	and	

Reform	Act	of	2012	Through	the	Exemption	Process	Identified	Under	14	C.F.R.	

Part	11

Dear	Mr.	Secretary,

Pursuant	to	Section	333 of	PL	112-95	commonly	known	as	the	“FAA	Modernization	and	Reform	Act	

of	2012” or	“The	Reform	Act,” Ontegrity Incorporated petitions	for	authorization	to	conduct	

commercial	unmanned	aerial	system	(UAS)	operations	for	the	telecommunications, energy	

industries,	aerial	photography	and/or	video	for	public	and/or	private	use	including	real	estate,	

architecture,	land	surveying,	engineering,	alternative	energy	and	other	related	professional	

activities,	within	the	United	States	National	Airspace	System	(NAS).	These	operations	include	but	

are	not	limited	to,	site	survey,	quality	control	data	collection,	volumetric,	geo-location	magnetic	and	

gravity	measurements,	RF	measurements,	aerial	photography,	videography,	agriculture,	scientific	

studies,	wildlife	monitoring	and	forestry.

The	name	and	address	of	the	applicant	is:

Ontegrity Incorporated

Attn:	William	A Hillegas	Jr.

Vice	President	Field	Operations

3	Speen	St, Suite	210

Framingham,	MA	01701

bhillegas@ontegrity.com

206-849-7128

Ontegrity	petitions	to	be	exempt	from	the	following	C.F.R.s	in	accordance	with	precedent	set	by	the	

following	approvals:	Exemptions	11062	through	11067,	11080,	11109,	11110	and	11213.

Ontegrity also	requests	the	secretary	determine	that	good	cause	exists	for	not	publishing	a	

summary	of	the	petition	in	the	Federal	Register	because	the	requested	exemption	would	not	set	a	

precedent,	and	any	delay	in	acting	on	this	petition	would	be	detrimental	to	the	petitioner.
2

The	regulations	from	which	the	exemption	is	requested	are	as	follows:

 14	C.F.R.	§	61.23	(a)	and	(c)

 14	C.F.R.	§	61.23	(a)	and	(c)

 14	C.F.R.	S	61.101(e)(4)	and	(5),	61.113	(a)	and	(b),	61.	3	15(a)

 14	C.F.R.	5	91.7(a)

 14	C.F.R.	5	91.103

 14	C.F.R.	5	91.109(a)

 14	C.F.R.	§	91.119(c)

 14	C.F.R.	5	91.121

 14	C.F.R.	§	91.151(a)

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

Appendix	A	discusses	each	rule	listed	above	and	explains	why	exemptions	pursuant	to	the	proposal	

set	forth	in	this	letter	are	appropriate,	provide	an	equivalent	level	of	safety,	and	are	in	the	public	

interest.

Based	out	of	Framingham,	MA, Ontegrity is	a	company	specializing	in	providing	engineering	audits,	

DC	power,	and	battery	services	and	site	monitoring	solutions	to	major	wireless	providers,	energy	

companies	and	civil	and	commercial	infrastructure	orgaanizations	across	the	continental	United	

States,	Alaska,	Hawaii	and	Puerto	Rico.	

Ontegrity’s	UAS	flights	will	be	flown	to	achieve	an	aerial	view,	video	recordings	and	RF	signal	

strength	recording	of	antennas	and	lines	that	are	secured	to	towers,	water	towers	and	other	

telecommunications	facilities.	Ontegrity’s	UAS	flights	will	also	be	used	to	view	and	record	open	

antenna	locations	on	towers	for	potential	future	modifications	and	additions.

With Ontegrity’s	UAS,	we	will	be	able	to	observe	and	acquire	valuable	data	for	our	customers	that	

would	otherwise	be	more	expensive	and	hazardous	to	individuals	including	Aerial	photography	

and/or	video	for	public	and/or	private	use	including	real	estate,	architecture,	land	surveying,	

engineering,	alternative	energy	and	other	related	activities.		The UAS	flights	will	reduce	the	labor	

hours	currently	expended	when	someone	is	performing	these	tasks	manually.		The	purpose	of	this	

petition	is	to	improve	safety	at	the	work	locations	by	eliminating	or	decreasing	the	time	a	worker	is	

in	a	hazardous	environment	thus	approval	of	this	petition	would	be	in	the	best	“public	interest.”

Equivalent	Level	of	Safety

The	applicant	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	at	

least	an	equivalent	or	even	higher	level	of	safety	to	operations	under	the	current	regulatory	

structure	because	the	proposed	operations	represent	a	safety	enhancement	to	operations	that	

would	be	conducted	with	conventional	aircraft.	These	conditions	are	drawn	from	Exemptions	

11062	through	11067,	11080,	11109,	and	11110.
3

Below	are	the	limitations	and	conditions	to	which	Ontegrity	(or	“operator”)	agrees	to	be	bound	

when	conducting	commercial	operations	under	an	FAA	issued	exemption:

1. Operations	will	be	limited	to	the	Unmanned	Aerial	Systems	(UAS)	listed	below	with	type,	

weight and	airspeeds	indicated.	All	UAS	listed	have	a	weight	of	less	than	55	pounds	

including	payload,	and	having	a	maximum	airspeed	of	less	than	87	knots	(100	miles	per	

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

amend	this	exemption.

DJI	Phantom	2	Vision+,	(Fixed	Rotor,	15 lbs,	50 mph),	DJI	Phantom	2,	(Fixed	Rotor,	15 lbs,

50 mph),	the	DJI	Inspire	1	(Fixed	Rotor,	15 lbs,	50 mph),	the	DJI	S1000+ (Fixed	Rotor	26 lb,	

60 mph),	and	the	DJI	S900	(Fixed	Rotor,	18lb,	60mph)

Additional	Documentation:

 DJI	Phantom	2	Vision+,	DJI	S-1000+,	DJI	Phantom	2,	Inspire,	DJI	S1000+,	DJSI	S900.

Operations/User	and	Maintenance	Manuals (provided	as	secondary	document	upon	

request)

2. The	UAS	will	not	be	operated	at	a	speed	exceeding	87	knots	(100	miles	per	hour).	In	no	case	

will	the	UAS	be	operated	at	airspeeds	greater	than	the	maximum	UAS	operating	airspeed	

recommended	by	the	aircraft	manufacturer.

3. The	UAS	will	be	operated	at	an	altitude	of	no	more	than	400	feet	above	ground	level	(AGL).	

Altitude	will	be	reported	in	feet	AGL.

4. The	UAS	must	be	operated	within	visual	line	of	sight	(VLOS)	of	the	pilot-in-command	(PIC)	

at	all	times.	This	requires	the	PIC	to	be	able	to	use	human	vision	unaided	by	any	device	

other	than	corrective	lenses,	as	specified	on	the	PIC's	FAA-issued	airman	medical	certificate	

or	U.S.	driver's	license.

5. All	operations	must	utilize	a	visual	observer	(VO).	The	UAS	must	be	operated	within	the	

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

VLOS	requirement	as	long	as	the	PIC	always	maintains	VLOS	capability.	The	VO	and	PIC	

must	be	able	to	communicate	verbally	at	all	times;	electronic	messaging	or	texting	is	not	

permitted	during	flight	operations.	The	PIC	must	be	designated	before	the	flight	and	cannot	

transfer	his	or	her	designation	for	the	duration	of	the	flight.	The	PIC	must	ensure	that	the	

VO	can	perform	the	duties	required	of	the	VO.

6. A	copy	of	the	FAA	approved	exemption	and	all	documents	needed	to	operate	the	UAS	and	

conduct	its operations	in	accordance	with	the	conditions	and	limitations	stated	in	the	grant	

of	exemption,	will	be	hereinafter	referred	to	as	the	operating	document.	The	operating	

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

Administrator	upon	request.	If	a	discrepancy	exists	between	the	conditions	and	limitations	
4

in	the	FAA	approved	exemption	and	the	procedures	outlined	in	the	operating	documents,	

the	conditions	and	limitations	in	the	FAA	approved	exemption	take	precedence	and	must	be

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

documents.

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

responsibility	to	track	such	revisions	and	present	updated	and	revised	documents	to	the	

administrator	or	any	law	enforcement	official	upon	request.	The	operator	must	also	present	

updated	and	revised	documents	if	it	petitions	for	extension	of	or	amendment	to	its	FAA	

approved	exemption.	If	the	operator	determines	that	any	update	or	revision	would	affect	

the	basis	upon	which	the	FAA	granted	its	exemption,	then	the	operator	must	petition	for	an	

amendment	to	its	grant	of	exemption.	The	FAA's	UAS	Integration	Office	(AFS	- 80)	may	be	

contacted	if	questions	arise	regarding	updates	or	revisions	to	the	operating	documents.

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

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

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

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

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

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

8. The	operator	is	responsible	for	maintaining	and	inspecting	the	UAS	to	ensure	that	it	is	in	a	

condition	for	safe	operation.

9. Prior	to	each	flight,	the	PIC	must	conduct	a	pre-flight	inspection	and	determine	the	UAS	is	in	

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

discrepancies,	e.g.,	inoperable	components,	items,	or	equipment.	If	the	inspection	reveals	a	

condition	that	affects	the	safe	operation	of	the	UAS,	the	aircraft	is	prohibited	from	operating	

until	the	necessary	maintenance	has	been	performed	and	the	UAS	is	found	to	be	in	a	

condition	for	safe	flight.

10. The	operator	will	follow	the	UAS	manufacturer's	maintenance,	overhaul,	replacement,	

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

11. Each	UAS	operated	under	this	petition	will	comply	with	all	manufacturer	safety	bulletins.

12. The	PIC	must	hold	either	an	airline	transport,	commercial,	private,	recreational,	or	sport	

pilot	certificate.	The	PIC	must	also	hold	a	current	FAA	airman	medical	certificate	or	a	valid	

U.S.	driver's	license	issued	by	a	state,	the	District	of	Columbia,	Puerto	Rico,	a	territory,	a	

possession,	or	the	Federal	Government.	The	PIC	must	also	meet	the	flight	review	

requirements	specified	in	14	CFR	5	61.56	in	an	aircraft	in	which	the	PIC	is	rated	on	his	or	

her	pilot	certificate.
5

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

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

petition	for	exemption,	including	evasive	and	emergency	maneuvers	and	maintaining,	

appropriate	distances	from	persons,	vessels,	vehicles	and	structures.	PIC	qualification	flight	

hours	and	currency	must	be	logged	in	a	manner	consistent	with	14CFR	5	61.51(b).

Flights	for	the	purposes	of	training	the	operator's	PICs	and	VOs	(training,	proficiency,	and	

experience-building)	and	determining	the	PIC's	ability	to	safely	operate	the	UAS	in	a	

manner	consistent	with	how	the	UAS	will	be	operated	will	adhere	to	the	conditions	and	

limitations	specified	within	this	petition	for	exemption.	Training,	operations	may	only	be	

conducted	during	dedicated	training	sessions.	During	training,	proficiency,	and	experiencebuilding	flights,	all	persons	not	essential	for	flight	operations	are	considered	

nonparticipants,	and	the	PIC	must	operate	the	UAS	with	appropriate	distance	from	

nonparticipants	in	accordance	with	14	CFR	5	91.119.

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

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

special	visual	flight	rules	(SVFR)	are	not	authorized.

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

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

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

aeronautical	chart,	unless	a	letter	of	agreement	with	that	airport's	management	is	obtained	

or	otherwise	permitted	by	a	Certificate	of	Waiver	or	Authorization	(COA) issued	to	the	

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

available	to	the	administrator	or	any	law	enforcement	official	upon	request.

16. 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.

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

predetermined	location	within	the	private	or	controlled-access	property.

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

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

conditions)	there	is	enough	available	power	for	the	UAS	to	conduct	the	intended	operation	

and	to	operate	after	that	for	at	least	5	minutes	or	with	the	reserve	power	recommended	by	

the	manufacturer	if	greater.

20. Air	Traffic	Organization	(ATO)	COA.	All	operations	shall	be	conducted	in	accordance	with	an	

ATO-issued	COA.
6

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

documents	required	under	14	CFR	5	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.

23. The	UAS	must	remain	clear	and	give	way	to	all	manned	aviation	operations	and	activities	at	

all	times.

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

25. All	Flight	operations	must	be	conducted	at	least	500	feet	from	all	nonparticipating,	persons,	

vessels,	vehicles,	and	structures	unless:	

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

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

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

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

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

nonparticipating	persons;	and	

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

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

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

undue	hazard.	The	PIC,	VO,	operator	trainees	or	essential	persons	are	not	

considered	nonparticipating	persons	under	this	exemption.

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

permission	from	the	property	owner/controller	or	authorized	representative.	Permission	

from	property	owner/controller	or	authorized	representative	will	be	obtained	for	each	

flight	to	be	conducted.

27. 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.
7

Unless	otherwise	specified	in	this	petition	for	exemption,	the	UAS,	the	UAS	PIC,	and	the	UAS	

operations will	comply	with	all	applicable	parts	of	14	CFR	including,	but	not	limited	to,	parts	45,	47,	

61,	and	91.

Conclusion

Ontegrity’s	Petition	for	exemption	demonstrates	the	appropriate	safeguards	and	criteria,	including	

weight,	speed,	operating	capabilities,	proximity	to	airports	and	populated	areas,	operation	within	

VLOS	and	national	security	concerns,		that	Congress	expressed		in	Section	333	of	the	FAA	

Modernization	and	Reform	Act	of	2012	(FMRA),	which	will	permit	safe	operation	of	the	approved	

UASs	commercially,	without	an	airworthiness	certificate,	for	the	limited	purpose	of	conducting	

aerial	video,	data	collection	and	photography	over	certain	areas	of	the	United	States.	By	granting	

this	Petition,	the	FAA	Administrator	will	be	fulfilling	the	Congressional	mandate	of	the	FAA	

Modernization	and	Reform	Act	of	2012,	while	also	advancing	the	interests	of	the	public,	by	allowing	

Ontegrity	to	safely,	efficiently,	and	economically	operate	the	SUA’s	commercially	within	the	NAS.	

Furthermore,	structural	inspections	and	data	collection	as	outlined	and	performed	by	workers,	can	

be	difficult	and	dangerous.		These	risks	can	be	mitigated	by	using	a	small	UAS,	under	controlled	

conditions	preventing	possible	human	injury	or	death	thus	it	is	in	the	public	interest	to	grant	these	

exemptions.

Thank	you	for	your	consideration	of	our	requested	exemptions,	if	you	have	any	questions,	or	if	you	

require	additional	information,	please	do	not	hesitate	to	contact	me.

Manufactures	instruction	manuals	are	available	upon	request.

Respectfully

William	A.	Hillegas	Jr.

Vice	President,	Field	Operations

Ontegrity	Inc

3	Speen	St,	Suite	210

Natick,	MA		01701

206-849-7128

bhillegas@ontegrity.com
8

Appendix	A	

Regulations	– Exemption	Requested

 14	C.F.R.	§	61.23(a)	and	(c)

 14	C.F.R.	§	61.101(e)(4)	and	(5),	61.113	(a)	and	(b),	61.315(a)

 14	C.F.R.	§	91.7(a)

 14	C.F.R.	§	91.103

 14	C.F.R.	5	91.109(a)

 14	C.F.R.	5	91.119(c)

 14	C.F.R.	§	91.121

 14	C.F.R.	§	91.151(a)

 14	C.F.R.	5	91.405(a),	5	91.407(a)(1),	§	91.409(a)(2)	and	5	91.417(a)	and	(b)

Pursuant	to	14	C.F.R.	5	11.81(e),	Ontegrity	seeks	exemption	from	the	below	mentioned	regulations	

and	provides	reason	as	to	why	the	exemption	should	be	approved	based	on	the	level	of	safety	at	

least	equal	to	that	of	which	the	rules	require.

 14	C.F.R.	§	61.23(a)	and	(c):

 States: (a)	Operations	requiring	a	medical	certificate.	Except	as	provided	in	

paragraphs	(b)	and	(c)	of	this	section,	a	person ...

and	

(c)	Operations	requiring	either	a	medical	certificate	or	U.S.	driver's	license.	

As	set	forth	within	FAA	granted	Exemptions	11062	through	11067,	11080,	11109,	11110	

and	11213	and	others,	the	minimum	requirement	to	operate	a	UAS	for	commercial	

purposes	is	to	hold	at	least	a	sport	license	and	a	valid	driver's	license.	The	granted	

exemptions	exempt	the	UAS	PIC	from	this	limitation	to	his	or	her	license.	Ontegrity	petitions	

for	the	same	exemption	as	approved	within	the	previously	listed	exemptions.

 C.F.R.	§	61.101(e)(4)	and	(5),	61.113	(a)	&(b),	61.315(a);	61.101(e)(4)	and	(5);	

 States: (4)	Except	as	provided	in	paragraphs	(d)	and	(i)	of	this	section,	a	

recreational	pilot	may	not	act	as	pilot in	command	of	an	aircraft—

(4)	For	compensation	or	hire;

(5)	In	furtherance	of	a	business

 61.113	(a)	and	(b):

States: (a)	Except	as	provided	in	paragraphs	(b)	through	(g)	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	
9

private	pilot	may,	for	compensation	or	hire,	act	as	pilot	in	command	of	an	aircraft	in	

connection	with	any	business	or	employment	if:

 61.315(a)

States: (a)	If	you	hold	a	sport	pilot	certificate	you	may	act	as	pilot	in	command	of	a	

light-sport	aircraft,	except	as	specified	in	paragraph	(c)	of	this	section.	

(c)(2)	For	compensation	or	hire;	

(c)	(3)	In	furtherance	of	a	business;

Under	the	current	limitations	of	a	private,	recreational,	or	sport	pilot	license,	a	pilot	holding	

a	valid	private,	recreational	or	sport	license	cannot	operate	for	compensation	or	hire	or	in	

the	furtherance	of	a	business.	As	set	forth	within	FAA	granted	Exemptions	11062	through	

11067,	11080,	11109,	11110	and	11213	and	others,	the	minimum	requirement	to	operate	a	

UAS	for	commercial	purposes	is	to	hold	at	least	a	sport	license	and	a	valid	driver's	license.	

The	granted	exemptions	exempt	the	UAS	PIC	from	this	limitation	to	his	or	her	license.	

Ontegrity	petitions	for	the	same	exemption	as	approved	within	the	previously	listed	

exemptions.

 14	C.F.R.	§	91.7(a)

 States: No	person	may	operate	a	civil	aircraft	unless	it is	in	an	airworthy	condition.

Currently,	there	are	no	airworthiness	certificates	for	the	proposed	UAS.	Pre- and	post-flight	

inspections	will	be	accomplished	in	accordance	with	manufacture's	maintenance	manual(s)	

and	guidance.	During	flight,	the	PIC	will	adhere	to	C.F.R.	§	91.7(b)	and	abort	air	operations	

immediately	upon	identification	of	an	in-flight	emergency.	By	applying the	prescribed	

operations,	inspection	and	maintenance	procedures	within	the	limitations	and	conditions	of	

Ontegrity's	petition	for	exemption,	an	equivalent	level	of	safety	will	be	achieved.

 14	C.F.R.	§	91.103

 States: Each	pilot	in	command	shall,	before	beginning	a	flight,	become	familiar	with	

all	available	information	concerning	that	flight.	This	information	must	include-

(paragraphs	a,	b,	I	and	2)

A	pre-flight	mission	brief (PMB) will	be	attended	by	all	crew	members. This	PMB	will	

contain	weather	and	all	flight	information	including	emergency	and	abort	procedures.	A	

signature	will	be	required	by	all	crew	members	indicating	they	have	received	the	PMB	and	

have	read	any	NOTAMs	or	other	procedural	updates	which	may	have	impact	to	standard	

operating	procedures.	In	addition,	the	PIC	will	verify	the	UAS	is	ready	for	flight	by	

conducting	a	pre-flight	inspection.	
10

The	exemption	requested	for	this	section	is	specifically	addressed	toward	the	requirements	

which	do	not	apply	to	UAS	operations	such	as	runways	and	air	traffic	control	integration.

 14	C.F.R.	§	91.109

 States: 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.

The	majority	of	UAS	by	design	are	developed	with	single	operational	control	through	the	

use	of	pre-determined	GPS	enabled	waypoints	programmed	before	or	during	flight	and/or	

the	use	of	a	single	hand	held	transmitter	or	control	station	controlled	by the	PIC.	This	

design	does	not	allow	for	dual	controls	during	flight	training	and	therefore	the	exemption	is	

requested.	To	assist	in	mitigating	this	limitation,	all	training	will	be	conducted	through	the	

use	of	a	“buddy	box” where	the	PIC/Trainer	can	regain	control	of	the	UAS	at	any	time	at	

their	discretion.

 14	C.F.R.	§	91.119	(c)

 States: 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.

As	UAS	are	inherently	safer	than	traditional	aircraft	due	to	their	small	size,	light	weight,	

battery	operation	versus	fuel	and	have	no	humans	on-board;	Ontegrity	will	not	operate	

within	500	feet	of	any	vehicles,	persons	or	structures	other	than	those	part	of	the	flight	

operation	being	conducted.	In	addition,	objects	and	hazards	identified	and	geo-located	prior	

to	flight	operations	will	be	utilized	within	the	flight	planning	stages	to	ensure	this	objective	

is	met

 14	C.F.R.	§	91.121

 States: Each	person	operating	an	aircraft	shall	maintain	the	cruising	altitude	or	fight	

level	of	that	aircraft,	as	the	case	may	be,	by	reference	to	an	altimeter	that	is	set,	

when	operating	...

UAS	are	equipped	with	Global	Positioning	System	(GPS)	which	provide	altitude	and	geolocation	data	to	the	operator	versus	utilizing	an	altimeter.	Due	to	this	fact,	an	exemption	is	

required	for	this	system	to	be	utilized	in	flight.	GPS	are	precise	within	a	few	feet	vertically	

and	therefore	meet	a	safety	level	equal	to	if	not	higher	than	regulatory	guidance.	
11

As	described	in	the	limitations	and	conditions	section	of	Ontegrity's	petition	for	exemption;	

in	the	event	the	UAS	loses	GPS	signal,	automated	landing	will	immediately	commence.	The	

flight	plan	is	built	in	such	a	way	that	hazards	are	identified	prior	to	launch	and	an	

immediate	landing	within	the	flight	plan	will	ensure	all	hazards	are	avoided.

 14	C.F.R	§	91.151(a)

 States: 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;

 This	regulation	is	based	on	the	capabilities	of	a	traditional	aircraft	which	have	flight	times	of	

several	hours	or	greater;	therefore,	with	the	majority	of	UAS,	which	have	flight	times	of	an	

hour	or	less,	this	regulation	would	effectively	deny	the	ability	of	the	UAS	to	operate.	

 Drawing	from	previously	approved	Exemptions	the	PIC	will	not	begin	a	flight	unless	

(considering	wind	and	forecast	weather	conditions)	there	is	enough	available	power	for	the	

UAS	to	conduct	the	intended	operation	and	to	operate	after	that	for	at	least	5	minutes	

thereafter	or	with	the	reserve	power	recommended	by	the	manufacturer	if	greater.	The	

ability	to	quickly	and	safely	land	UAS	in	non-traditional	environments	ensures	at	least	an	

equal	level	of	safety

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

 91.405(a)	States: 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(a)(1)	States: (a)	No	person	may	operate	any	aircraft	that	has	undergone	

maintenance,	preventive	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(a)(2)	States: (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—(2)	An	inspection	for	the	issuance	of	an	airworthiness	certificate	in	

accordance	with	part.	21	of	this	chapter.	No	inspection	performed	under	paragraph	

(b)	of	this	section	may	be	substituted	for	any	inspection	required	by	this	paragraph	

unless	it	is	performed	by	a	person	authorized	to	perform	annual	inspections	and	is	

entered	as	an	“annual” inspection	in	the	required	maintenance	records.
12

 91.417(a)	&	(b)	States: (a)	Except	for	work	performed	in	accordance	with	§§	

91.411	and	91.413,	each	registered	owner	or	operator	shall	keep	the	following	

records	for	the	periods	specified	in	paragraph	(b)	of	this	section:	[paragraphs	1 (i–

iii),	2 (i–vi)];	(b)	The	owner	or	operator	shall	retain	the	following,	records	for	the	

periods	prescribed	(paragraphs	1–3)

Due	to	the	fact	the	proposed	UAS	presently	do	not	have	airworthiness	certificates,	these	regulations	

do	not	apply	and, therefore, an	exemption	is	required.	Pre/Post	flight	and	routine	inspections	and	

maintenance	will	be	conducted	in	accordance	with	the	manufacturer's	audience	as	stated	in	the	

user/maintenance	manuals.	Ontegrity	will	maintain	logs	of	pre- and	post-flight	inspections. In	the	

event	maintenance	is	required,	the	PIC	will	verify	the	UAS	is	in	an	airworthy	status	prior	to	

operational	use.

All	inspection	and	maintenance	will	be	documented	and	maintained	in-house.	These	actions	will	

meet	the	intent	of	the	regulation	exemption being	requested	and	lead	to	the	equivalent	level	of	

safety.