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Law Office of Daryl Crouse 

920 Orizaba Ave. 

Long Beach, CA 90804 

(562) 342-4246 

daryl@darylcrouse.com 

:l . 

Before the 

FEDERAL AVIATION ADMINISTRATION 

Washington, DC 

.... ~ 

' ' 

IN THE MATTER OF RADFLIGHT, INC. 

PETITION FOR EXEMPTION TO 

OPERATE SMALL UNMANNED 

AIRCRAFT SYSTEMS 

FAA Regulatory Docket No. ____ _ 

I. SUMMARY 

RadFlight, Inc., a California company ("RadFlight"), located at 5684 Spinnaker Bay Dr., 

Long Beach, CA 90803 seeks authority to commercially operate a unmanned aircraft system 

fleet pursuant to Federal Aviation Regulations (14 C.F.R. § 1.61) and Section 333 of the FAA 

Modernization and Reform Act of 2012, Special Rules for Certain Unmanned Aircraft Systems. 

RadFlight also seeks exemption from the requirements of certain provisions of14 C.F.R. Parts 

21, 36, 45.23(b), 61.23(a) and (c), 61.101(e)(4) and (5), 61.113(a) and (b), 61.133(b), 61.315(a), 

91.7(a), 91.9 (b)(2), 91.103(b)(1), 91.109(a), 91.119(c), 91.121, 91.151, 91.203(a) and (b) 

91.405(a), 91.407(a)(l), 91.409(a)(l) and (2), and 91.417(a) and (b). The proposed 

exemptions, if granted, would allow RadFlight to conduct commercial operations of small 

unmanned aircraft systems ("UAS") weighing 55 pounds or less. 

II. BACKGROUND 

RADFLIGHT, INC. PETITION FOR EXEMPTION TO OPERATE SMALL UAS- 1 
RadFlight is a cutting edge engineering, cinematography and drone design company. 

2 Consistent with Congressional intent in enacting Section 222, RadFlight seeks to utilize 

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remote flying and viewing technology to achieve new heights of creativity and production cost 

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5 savings. RadFlight seeks the requested exemptions and a Certificate of Authorization 

6 permitting RadFlight to offer a suite of services, such as: 

7 • Closed-set filming and aerial photography; 

• Aerial data collection; 

• Drone pilot and instructor training; 8 

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III. STATUTORY AUTHORITY 

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Section 333, Special Rules for Certain Unmanned Aircraft Systems, provides a procedure 

12 for seeking expedited FAA authorization for UAS operations in the NAS. Subpart A states the 

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

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airspace system before completion of the plan and rulemaking required by 332(b )(1) of this act 

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16 or the guidance required by section 334 of this Act." In Section 332(b )(1), Congress made it 

17 clear that section 333 provides a procedure for "expedited operational authorization." 

18 Section 333(b) identifies factors that the FAA should consider in determining whether 

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commercial US operations should be approved when, "as a result of their size, weight, speed, 

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21 operational capability, proximity to airports and populated areas, and operation within the 

22 visual line of sight do not create a hazard to users of the [NAS] or the public or pose a threat to 

23 national security." 

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In addition, Section 44701(f) confers a general authority to grant exemptions from the 

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26 FAA's safety regulations and minimum standards when the administrator decides a requested 

exemption is in the public interest. 

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IV.RADFLIGHT EXEMPTIONS REQUESTED 

RadFlight requests relief from: 

14 C.F.R. Part 21 prescribes, in pertinent part, procedural requirements for issuing and 

changing design approvals; production approvals; airworthiness certificates; and airworthiness 

approvals. 

14 C.F.R. Part 36 sets forth noise standards for aircraft type and airworthiness 

certification. 

14 C.F.R. Part 45.23(b) sets forth the requirement, if applicable, that the word 

"Restricted" be displayed on the unmanned aircraft near each entrance to the cabin, cockpit 

or pilot station. 

14 C.F.R. Part 61.23(a) and (c) sets forth requirements for medical certificates. 

14 C.F.R. Part 61.101(e)( 4) and (5) prescribes recreational pilot privileges and 

limitations. 

14 C.F.R. Part 61.113(a) and (b) prescribes private pilot privileges and limitations. 

14 C.F.R. Part 61.133(b) prescribes commercial pilot privileges and limitations. 

14 C.F.R. Part 91.7(a) prescribes, in pertinent part, that no person may operate a civil 

aircraft unless it is in an airworthy condition. 

14 C.F.R. Part 91.9 (b)(2) prohibits operation of US registered civil aircraft unless 

there is available in the aircraft a current approved Airplane or Rotorcraft Flight Manual, 

approved manual material, markings, and records, or any combination thereof. 

14 C.F.R. Part 91.103(b)(1) prescribes, in pertinent part, that each pilot in command 

shell, before beginning a flight, become familiar with all available information concerning that 

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flight, include, "for any flight, runway lengths at airports of intended use, and the following 

takeoff and landing distance: ... For civil aircraft forwards and approved Airplane or Rotorcraft 

Flight Manual containing takeoff and landing distance data is required, the takeoff and landing 

distance data contained therein." 

14 C.F.R. Part 91.109(a) provides that "no person may operate a civil aircraft (except 

in manned free balloon) that is being used for flight instruction unless the aircraft has fully 

functioning dual controls." 

14 C.F .R. Part 91.119( c) prescribes that, except when necessary for takeoff or landing, 

no person may operate an aircraft below the certain altitudes under certain conditions. 

14 C.F.R. Part 91.121 requires, in pertinent part, 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 ultimate setting available before departure." 

14 C.F.R. Part 91.151 prescribes that 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; or (2) at night, to fly after that for at 

least 45 minutes. 

14 C.F.R. Part 91.203(a) and (b) prohibits, in subpart (a), any person operating a civil 

aircraft unless it has within it (1) an appropriate concurrent airworthiness certificate; and (2) 

an effective US registration certificate issued to its owner or, for operation within the United 

States, the second copy of the Aircraft Registration Application as provided for in §43.3 7(c). 

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Section 91.203 prescribes, in subpart (b), that no person may operate a civil aircraft unless and 

airworthiness certificate or a special flight authorization issued under §91. 715 legible to 

passengers or crew is displayed at the capital cockpit. 

14 C.F.R. Part 91.407(a)(1) prohibits, in pertinent part, any person from operating an 

aircraft that has undergone maintenance, inventive maintenance, rebuilding, or alteration 

unless it has been approved for return to service by a person authorized under §43.7 of the 

same chapter. 

14 C.F.R. Part 91.409(a)(1) and (2) prescribes, in pertinent part, that no person may 

operate aircraft unless, within the preceding 12 calendar months, it has had an inspection for 

the issuance of an airworthiness certificate in accordance with part 21 of this chapter. 

14 C.F.R. Part 91.417(a) and (b) prescribes, in pertinent part, that each registered 

owner or operator shall keep the following records for the periods specified in paragraph (b) of 

this section: (1) Records of the maintenance, preventive maintenance, and alteration and 

records of the 100-hour, annual, progressive, and other required or approved inspections, as 

appropriate, for each aircraft (including the airframe) and each engine, propeller, rotor, and 

appliance of an aircraft. The records must include- (i) A description (or reference to data 

acceptable to the Administrator) of the work performed; and (ii) The date of completion of the 

work performed; and (iii) The signature, and certificate number of the person approving the 

aircraft for return to service. (2) Records containing the following information: (i) the total 

time in service of the airframe, each engine, each propeller, and each rotor. (ii) The current 

status of life-limited parts of each airframe, engine, propeller, rotor, and appliance. (iii) The 

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time since last overhaul of all items installed on the aircraft which are required to be 

overhauled on a specified time basis, (iv) the current inspection status of the aircraft, including 

the time since the last inspection required by the inspection program under which the aircraft 

and its appliances are maintained, and (v) The current status of applicable airworthiness 

directives (AD) and safety directives including, for each, the method of compliance, the AD or 

safety directive number and revision date. If the AD or safety directive involves recurring 

action, the time and date when the next action is required, and (vi) copies of the forms 

prescribed by §43.9(d) of this chapter for each major alteration to the airframe and currently 

installed engines, rotors, propellers, and appliances. 

The records specified in paragraph (a)(l) of this section shall be retained until the work 

is repeated or superseded by other work or for 1 year after the work is performed. 

The records specified in paragraph (a)(2) of this section shall be retained and transferred with 

the aircraft at the time the aircraft is sold. 

A list of defects furnished to a registered owner or operator under §43.11 of this 

chapter shall be retained until the defects are repaired and the aircraft is approved for return to 

service. 

V. RADFLIGHT'S OPERATIONS SATISFY SECTION 333 REQUIREMENTS 

a. RadFlight's UAS Fleet 

RadFlight proposes to operate three small UAS under this exemption. 

Phantom2 

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RadFlight seeks an exemption to operate a DJI Phantom 2 for compensation or hire. 

The DJI Phantom 2is comprised of a multi-rotor unmanned aircraft and two handheld ground 

control stations. The DJI Phantom 2 has a maximum gross weight of approximately 2.86 

pounds, diagonal wheelbase ofl3.78 inches, and height of approximately 7.5 inches. The DI 

Phantom 2 is equipped with four rotors driven by four lithium polymer battery powered 

electric motors. Design and operational characteristics are provided in DJI Phantom 2 

Operating Manual (Page 35). 

Phantom3 

RadFlight seeks an exemption to operate a DJI Phantom 3 for compensation or hire. 

The DJI Phantom 3 is comprised of a multi-rotor unmanned aircraft and two handheld ground 

control stations. The DJI Phantom 3 has a maximum gross weight of approximately 2.821 

pounds, diagonal wheelbase of13.78 inches, and height of approximately 7.5 inches. The DI 

Phantom 3 is equipped with four rotors driven by four lithium polymer battery powered 

electric motors. Design and operational characteristics are provided in DJI Phantom 3 

Operating Manual (Page 53). 

DJIInspire 

RadFlight seeks an exemption to operate a DJI Inspire for compensation or hire. The 

DJI Inspire is comprised of a multi-rotor unmanned aircraft and two handheld ground control 

stations. The DJI Inspire has a maximum gross weight of approximately 6.5 pounds, diagonal 

wheelbase of22.88 inches, and height of approximately 11.85 inches. The DJI- SlOOO is 

equipped with four rotors driven by four lithium polymer battery powered electric motors. 

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Design and operational characteristics are provided in DJI Inspire Operating Manual (Page 

57). 

DJI-81000 

RadFlight seeks an exemption to operate a DJI-S1000 for compensation or hire. The 

DJI-S1000 is comprised of a multi-rotor unmanned aircraft and two handheld ground control 

stations. The DJI-S1000 has a maximum gross weight of approximately 24.25 pounds, 

diagonal wheelbase of 41.14 inches, and height of approximately 22 inches. The DJI- S1000 is 

equipped with eight rotors driven by eight lithium polymer battery powered electric motors. 

Design and operational characteristics are provided in DJI S1000 Operating Manual (Page 22). 

b. Pilot In Command (PIC) and Operations 

All RadFlight Flight Crews, including PIC and Visual Observers (VO), will be qualified 

as directed by FAA and RadFlight Standard Operating Procedure (SOP). 

All flight crewmembers, including PIC and VO, will have an understanding of, and 

comply with, Title 14 Code ofFederal Regulations, and/or Agency directives and regulations, 

applicable to the airspace where the UAS will operate. Specifically all flight crew members will 

receive training on the rules and responsibilities described in 14 CFR Part 91 Sections 91.111, 

91.113 and 91.115 regarding cloud clearance, flight visibility and the pilot controller glossary, 

including standard A TC phraseology and communication. 

The PIC must possess at least a current private pilot certificate and third class medical 

certificate. The PIC must also meet the flight review requirements specified in 14 CFR 

Section 61.56 in an aircraft in which the PIC is rated on his/her pilot certificate. 

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Prior to operations, the PIC must have accumulated and logged, in a manner consistent 

with 14 CFR Section 61.51(b), a minimum of25 hours of total time as a UAS pilot and at least 

ten hours logged as a UAS pilot with similar UAS type (fixed wing or rotary). Prior 

documented flight experience that was obtained in compliance with applicable regulations may 

satisfy this requirement. Training, proficiency, and experience building flights are requested to 

be conducted under this grant of exception to accomplish the required flight cycles and flight 

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

flight operations will be considered non-participants and the PIC will operate the UAS with 

appropriate distance from non-participants in accordance with 14 CFR Section 91.119. 

The UAS shall remain clear and yield the right of way to all other manned aviation 

operations and activities at all times. 

The U AS shall be operated at an altitude of no more than 400 feet above ground level 

(AGL). All altitudes reported to ATC will be in feet. 

The multi-rotor UAS shall not be flown at a ground speed exceeding 30 mph. 

Fixed wing and hybrid UAS shall be flown at a ground speed not to exceed the 

maximum design limitation air speed of 57 mph as stated in the operating manuals. 

UAS Operations will be conducted under visual meteorological conditions (VMC). 

The UAS will not be operated less than 500 feet below or less than 2000 feet horizontally from 

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

If the UAS loses communications or loses its GPS signal, it must return to a predetermined location within the planned operating area and land or be recovered in accordance 

with RadFlight SOP. 

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The UAS PIC must abort the flight in the event ofunpredicted obstacles or 

emergencies in accordance with operating documents. 

The UAS PIC is prohibited from beginning a flight unless (considering wind and 

forecast weather conditions) there is enough power to fly at normal cruising speed to the 

intended landing point and land the UAS with 25% battery power remaining. 

c. RadFlight's UAS Operating Parameters 

The UAS operated in accordance with this proposed exemption shall be identified by 

serial numbers, registered in accordance with 14 CFR part 47, and have identification (NNumber) markings in accordance with 14 CFR part 45, Subpart C. Markings will be as large as 

practicable. 

The UAS documents required under 14 CFR 91.9 and 91.203 shall be available to the 

PIC at the Ground Control Station of the UAS anytime the aircraft is operating. Those 

documents shall be available to the Administrator or any law enforcement official upon 

request. 

Any UAS incidents, accidents or flight operations that transgress the lateral or vertical 

boundaries of the operational area as defined by the applicable COA shall be reported to the 

FAA's UAS Integration Office (AFS-80) within 24 hours. Accidents shall be reported to the 

National Transportation Safety Board (NTSB) per instructions contained on the NTSB Web 

site: www.ntsb.gov. 

Unless otherwise specified in this petition, the UAS PIC, and the UAS operations shall 

comply with all applicable parts of14 CFR including, but not limited to, parts 45, 47, 61 and 

91. 

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The UAS shall not be operated over congested or densely populated areas. These areas 

include but are not limited to the yellow areas depicted on World Aeronautical Charts (WAC), 

Sectional Aeronautical Charts (Sectionals), or Terminal Area Charts (TAC). Each work site 

will also be evaluated based on local conditions. 

Operations ofUAS may be conducted at distances less than 500 feet from participating 

persons, vessels, vehicles or structures that perform an essential function in connection with 

these special purpose operations. Operations closer than 500 feet from the PIC, VO, operator 

trainees and essential persons are permitted when operationally necessary; but never so close 

to present an undue hazard. This is consistent with Exemption No. 11138. 

Operations ofUAS may be conducted at distances less than 500 feet from unoccupied 

vessels, vehicles or structures owned by the land owner I controller when the land 

owner I controller grants such permission, and the PIC makes a safety assessment of the risk 

from operations and determines that it does not present an undue hazard to persons or 

property. This is consistent with Exemption No. 11138. 

Flight operations will be conducted at least 500 feet from all nonparticipating persons 

unless barriers or structures are present that sufficiently protect nonparticipating persons from 

the UAS and/ or debris in the event of an accident. RadFlight shall 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 will cease immediately. This is consistent with Exemption No. 11138. 

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All operations ofUAS shall be conducted with the permission from the land 

owner I controller or authorized representative. Permission from the land owner I controller or 

authorized representative will be obtained for each flight to be conducted. 

The UAS will not operate within 5 nautical miles of an airport reference point 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 

NOT AM as required by the operator's COA. The letter of agreement with the airport 

management will be made available to the Administrator upon request. This is consistent with 

Exemption No 11159. 

The UAS must be operated within VLOS of the PIC and VO at all times. This requires 

the PIC to be able to use human vision to see the UAS unaided by any device other than 

corrective lenses, as specified on the PIC's FAA issued medical certificate. 

All UAS operations must utilize aVO. 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. The PIC and VO 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 functions prescribed in RadFlight's SOP. 

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

Operations will not be conducted during night as defined in 14 CFR 1.1. 

RadFlight will conduct preflight safety risk assessments to determine that the U AS is 

in a condition for safe flight (14 CFR Section 91.7(b)) and that the planned operation can be 

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completed safely. Specific procedures are addressed in RadFlight's SOP, and UAS Operation 

Manuals. 

RadFlight' s operations do not require a notification to Flight Standards District 

Offices (FSDOs). 

RadFlight shall obtain an Air Traffic Organization (ATO) issued Certificate of Waiver 

or Authorization (COA) prior to conducting any operations under this requested grant of 

exemption. Additionally, RadFlight will request a Notice to Airmen (NOT AM) not more than 

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

Prior to operations conducted for the purpose of precision agriculture (or similar 

operations), the PIC must have accumulated and logged in a manner consistent with 14 CFR 

Section 61.51(b), a minimum of five hours as a UAS PIC operating the make and model of the 

UAS to be utilized for operations under this requested exemption, and three take-offs and 

landings in the preceding 90 days. Training, proficiency, experience-building, and take-off and 

landing currency flights are requested to be conducted under this grant of exemption to 

accomplish the required flight time and 90 day currency. During training, proficiency, 

experience building, and take-off and landing currency flights all personnel 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 Section 91.119. 

All operations must utilize aVO. The VO may be used to satisfy the Visual Line of 

Sight (VLOS) requirement as long as the PIC always maintain VLOS capability. The VO and 

PIC must be able to communicate verbally at all times. This condition and limitation is 

consistent with all FAA approved Exemptions. 

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VI. Rad.Flight's Requested Exemption Promotes the Public Interest 

Granting RadFlight' s petition for exemption will further the public interest because 

RadFlight seeks to perform necessary and vital services for public and private organizations. 

Such services include research, education, agricultural, search and rescue. The RadFlight 

unmanned aircraft fleet are battery-powered UAS that serve as a safe, efficient, and 

economical alternative to the demand aircraft traditionally utilized in obtaining aerial imagery 

within these industries. An exemption allowing RadFlight's UAS fleet to operate would 

reduce the amount of manned aircraft operating in the NAS, reduce noise and air pollution. In 

addition, the safety oflife and property both in the air and on the ground would be improved. 

By reducing the number of manned aircraft operating in the NAS airport congestion 

caused by arriving and departing aircraft will be reduced. The RadFlight UIS fleet does not 

require an airport to take off or land. A reduction of manned aircraft conducting aerial imagery 

flights would mean air traffic control handling less traffic during the ground, takeoff, 

departure, arrival and landing phases of flight operations. 

Aerial imagery missions using the RadFlight UAS fleet, instead of manned aircraft, 

benefits the public by drastically reducing air and noise pollution generated during manned 

aircraft operations. The RadFlight UAS fleet, a battery powered electric motor, is the most 

viable environmentally conscious alternative to internal combustion aircraft. The maximum 

gross weight of 5 pounds per UAS has less physical mass for collateral damage to life and 

property whether on the ground or in the air. 

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a. Exemption From The Requirements Of Section 91. 9(b) Would Not Adversely 

Affect Safety 

This exemption would maintain the level of safety established by Section 91.9(b) 

because RadFlight will keep the approved Airplane Flight Manual at the ground control 

station where the pilot in command will have immediate access to the document. 

Previous exemptions granted by the FAA concerning Section 91.9(b) establish that 

safety is not adversely affected when the approved Aircraft Flight Manual is kept at the ground 

control station of a UAS, where it can be immediately accessed by the pilot in command. 

Section 91.9(b) "requires aircraft to carry the flight manual so the pilot would have ready 

access to the aircraft limitations while in flight." Exemption No. 8607. However, the FAA has 

also found that U AS will always be operated without any passengers or crew on board, and that 

"requiring these special-use aircraft [UAS] to carry superfluous paper documents may present 

a safety hazard to the integrity of the [U AS]." Id. The FAA has previously granted 

exemptions in circumstances similar, in all material respects, to those presented herein (e.g., 

Exemption Nos. 8607, 8737, 8738, 9299, 9430, 9554, 9564, 9565, 10167, 10602, 10673, 10835, 

10869, 10968). 

b. Exemption From The Requirements Of Section 91.203( a) and (b) Would Not 

Adversely Affect Safety 

This exemption would maintain the level of safety established by Sections 91.203(a) 

and (b) because RadFlight will keep the required documents at the ground control station 

where the pilot in command will have immediate access. 

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Previous exemptions granted by the FAA concerning Sections 91.203(a) and (b) 

establish that safety is not adversely affected when the Airworthiness Certificate and U.S. 

registration certificate are kept at the ground control station of the UAS, where it can be 

immediately accessed by the pilot in command. Specifically, the FAA has held that the intent 

of Sections 91.203( a) and (b) is better served by having the required documents in the control 

of the UAS operator (pilot in command), reasoning as follows: "The original intent of the 

subject regulation was to display the airworthiness and registration documents so they would 

be easily available to FAA inspectors and passengers for inspection and verification of the 

airworthiness and registration of the aircraft ... In this case, the aircraft will always be 

operated without any passengers or crew." 

The missions for which UASs are intended will prevent the need for aircraft normally 

prescribed for civil aircraft. Further, it will be operated on strictly confined missions from a 

known departure and arrival point, under the constant control of a pilot-in-command. 

Requiring these special-use aircraft to carry superfluous paper documents may present a safety 

hazard to the integrity of the [UAS]. FAA operating limitations and special arrangements 

with Air Traffic Control (ATC) for surveillance of [UAS] flights adequately compensate for 

the requirements for carrying airworthiness and registration documents. The intent of the 

regulation is better served by having the required documents in the control of the aircraft 

operator and available for inspection under the special conditions prescribed in this 

exemption. 

RADFLIGHT, INC. PETITION FOR EXEMPTION TO OPERATE SMALL UAS- 16 
The FAA has previously granted exemptions in circumstances similar, in all material 

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respects, to those presented herein (e.g., Exemption Nos. 8607, 8737, 8738, 9299,9564, 9565, 

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10167, 10602, 10673, 10835, 10869, 10968). 

5 VII. CONCLUSION 

6 As set forth above, RadFlight seeks an exemption pursuant to 14 C.F.R. § 11.61 and 

7 Section 333 of the FAA Modernization and Reform Act of 2012, which will permit safe 

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operation of the RadFlight UAS fleet commercially, without an airworthiness certificate, for 

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the purposes described above. By granting this Petition, the FAA Administrator will be 

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

12 the public, by allowing RadFlight to safely, efficiently, and economically operate the UAS fleet 

13 commercially within the NAS. 

14 

WHEREFORE, in accordance with the Federal Aviation Regulations and the FAA 

15 

16 

Modernization and Reform Act of 2012, Section 333, RadFlight respectfully requests that the 

17 Administrator grant this Petition for an exemption from the requirements of14 C.F.R. Parts 

18 21, 36, 45.23(b), 61.23(a) and (c), 61.101(e)(4) and (5), 61.113(a) and (b), 61.133(b), 61.315(a), 

19 91.7(a), 91.9 (b)(2), 91.103(b)(1), 91.109(a), 91.119(c), 91.121, 91.151, 91.203(a) and (b) 

20 

91.405(a), 91.407(a)(1), 91.409(a)(1) and (2), and 91.417(a) and (b). 

21 

22 Dated this 2July 2015. 

23 

24 

25 

26 

RADFLIGHT, INC. PETITION FOR EXEMPTION TO OPERATE SMALL UAS- 17