Stealth	Resource	Solutions,	LLC. P.O.	Box	1448,	Plainfield,	IL	60544 www.stealthresourcesolutions.com

January	7,	2016

U.S.	Department	of	Transportation

Docket	Management	Systems

1200	New	Jersey	Ave.,	SE

Washington,	DC	20590

Re:	Exemption	Request	Pursuant	to	Section	333	of	the	FAA	Reform	Act	and	Part	11	of	the	Federal	

Aviation	Regulations	from: 14	C.F.R.	21	Subpart	H;	14	C.F.R.	§45.23(b);	14	C.F.R.	§61.113(a)	and	(b);	14	

C.F.R.	§91.7(a);	14	C.F.R.	§91.9(b) (2);	14	C.F.R.	§91.103(b)(2);	14	C.F.R.	§91.109;	14	C.F.R.	§91.119(c);	14

C.F.R.	§91.121;	14	C.F.R.	§91.151(a);	14 C.F.R.	§91.203	(a)	and	(b);	14	C.F.R.	§91.405	(a);	14	C.F.R.	§91.407	

(a)	(1)	14	C.F.R.	§91.409	(a)(1)	and	(2);	14 C.F.R.	§91.417(a)	and	(b)

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,	Stealth	Resource	Solutions,	LLC,	(Stealth	Resource	Solutions),	operator	of	Small	Unmanned	Aircraft	

Systems	(sUAS),	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.

Commercial	operation	of	a	sUAS,	as	described	herein,	which	are	equipped	with	camera(s)	and	sensors,	

would	operate	in	the	following	manner:

• Aerial	photography	and/or	video	for	public	and/or	private	use	including	real	estate,	architecture,	

land	surveying,	engineering,	and	other	related	professional	activities.

• Aerial	video	and/or	photography	for	public	and/or	private	use	including	closed-set	motion	picture	

and	television	filming,	public	events,	cinematography,	and	news	gathering.

• Aerial	data	collection	applications,	which	include	mapping,	topographical	surveying,	3D	modeling,	

and	precision	agriculture.

• Aerial	inspection/photography	of	residential/commercial	structures.

• Aerial	inspection/photography	of	residential/commercial	utility	infrastructure	including	but	not	

limited	to electrical	power	lines,	wind	turbines,	and	cell	towers.

• Aerial	video/photography	or	providing	live	video	feed	to	assist	with	search	and	rescue	operations	

in	cases of	an	emergency	or	natural	disaster	only	when	the	local	authorities	or	government	has	

requested	it	by	contract or	donation.

• The	ability	to	offer	training	to	persons	individually	or	belonging	to	both	private	and/or	public	

organizations that	have	interests	in	the	use	and	application	of	a	sUAS	for	the	purpose	of	the	safe	

operation	of	a	sUAS	to enhance	the	safety	of	the	National	Airspace	System	(NAS)	as	well	as	for	the	

protection	of	the	persons	and	property.

The	requested	exemption	would	permit	the	operation	of	a	sUAS	under	controlled	conditions	in	the	NAS	

that	would	be	a)	limited	b)	controlled	c)	predetermined,	and	d)	will	provide	safety	enhancements	to	the	

already	safe	operations	in	the	industry	presently	using	conventional	aircraft.	Approval	of	this	exemption	
Stealth	Resource	Solutions,	LLC | P.O.	Box	1448	Plainfield,	IL	60544 | www.stealthresourcesolutions.com

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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.”

The	name and	address	of	the	applicant	is:

Stealth	Resource	Solutions,	LLC

Attn:	Emmit	Q.	Hoosman,	Chief	Pilot

Phone:	312-656-5940

Email:	ehoosman@stealthrs.com

Address:	P.O.	Box	1448,	Plainfield,	Illinois	60544

Regulations	from	which	the	exemptions	are	requested:

• 14	C.F.R. Part	21,	Subpart H	– Airworthiness	Certificates

• 14	C.F.R. Part	36	Subpart	A,	F	&	O

• 14	C.F.R. 45.23	(b)	– Aircraft	Marking	

• 14	C.F.R. 61.113	(a) (B) – Pilot	in	Command	

• 14	C.F.R. 91.7	(a)	– Civil	Aircraft	Airworthiness	

• 14	C.F.R. 91.9	(b)	(2)	– Document/Flight	Manuals	

• 14	C.F.R. 91.103 (b)	(2) – Preflight	Action	

• 14	C.F.R. 91.109	– Flight	Instruction	

• 14	C.F.R. 91.119 (c) – Minimum	Safe	Altitude	

• 14	C.F.R. 91.121	– Altimeter	Setting	

• 14	C.F.R. 91.151	(a) – Fuel	Requirements	for	VFR	Flight	

• 14	C.F.R. 91.203	(a)	& (b)	– Civil	Aircraft:	Certifications	Required	

• 14	C.F.R. 91.405	(a);	407	(a)	(1);	409	(a) (2);	417	(a)	&	(b)	– Maintenance	and	Maintenance Inspections

Description	of	Type,	Make	and	Models	of	sUAV/UAS	Requested:	

The	Stealth	Resource	Solutions is	seeking	an	exemption	to	commercially	operate	sUAV’s	makes	and	modes	

as	follows:	

DJI	- Phantom	2,	DJI	- Phantom	3,	DJI	- Inspire	1,	DJI	– Spreading	Wings-S800,	DJI	– Spreading	Wings-S900,	

DJI	– Spreading	Wings-S1000,	DJI	– Matrice	100,	Blade	350	QX3,	3DRobotics	X8,	3DRobotics	Solo,	Yuneec	

Q500	Typhon.

Each	separately	weighs	55	lbs.	or	less,	with	imaging	payload	and	applicable	equipment.	

Equipment	operation	manuals	for	each	sUAV	are	included	for	your	reference	and	are	considered	

confidential	information	for	each	respective	company’s	UAS	and	are	affixed	separately	in	these	documents	

labeled	Appendix B.

Similarly	sized	sUASs	have	been	approved	for	use	in	prior	Section	333	Grants	of	Exemption	from	the	FAA.	

See	e.g., Grant	of	Exemption	to	Shotover	Camera Systems	L.P.	(Exemption	No.	11159);	Grant	of	Exemption	

to	VDOS	Global, LLC	(Exemption	No.	11112);	Grant	of	Exemption	to	LowCountryRC,	Corp.	(Exemption	No.	

11184);	Grant	of Exemption	to	Alan	Purwin	(Exemption	No.	11161);	Grant	of	Exemption	to	Helinet	

Aviation	Services	(Exemption No.	11160);	Grant	of	Exemption	to	Total	Safety	U.S.,	Inc.	(Exemption	No.	

11156).

Given	the	small	size	of	the	sUASs	and	the	controlled	environment	provided,	the	proposed	operations	will	

adhere	to the	Reform	Act’s	safety	requirements.	The	approval	of	this	application	presents	no	national	

security	issues.	Regarding the	level	of	safety	surrounding	the	proposed	operations	and	the	public	benefit,	
Stealth	Resource	Solutions,	LLC | P.O.	Box	1448	Plainfield,	IL	60544 | www.stealthresourcesolutions.com

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reduction	in	environmental	impacts, including	but	not	limited	to	reduced	emissions	and	noise, the	grant	of	

the	requested	exemption	is	in	the	public interest.	Accordingly,	the	applicant	requests	that	the	FAA	grant	the	

requested	exemption	with	minimum	delay.

AIRCRAFT	AND	EQUIVALENT	LEVEL	OF	SAFETY

The	applicant	seeks	to	have	this	exemption	cover	the	sUASs	used	to	carry	out	the	commercial	operations	

described herein	which	are	subject	to	the	limitations	proposed	in	this	petition.	Stealth	Resource	Solutions

proposes	and	agrees	to	the following	limitations	and	conditions	for	commercial	sUAS	operations	conducted	

under	a	granted	FAA	exemption:

• The	sUASs	will	weigh	less	than	55	lbs.

• The	sUASs	will	have	a	maximum	operating	speed	of	no	more	than	55kts.

• Flights	will	be	operated	within	line	of	sight	of	the	Pilot	in	Command	(PIC)	and/or	Visual	Observer	

(VO).

• Maximum	flight	time	for	a	multi-rotor	sUAS	operational	flight	will	be	30	minutes.	Flights	will	be	

terminated	at	25%	battery	power	reserve	or	25	minutes	of	flight	time	whichever	occurs	first.

• Maximum	flight	time	for	a	fixed	wing	sUAS	operational	flight	will be	40	minutes.	Flights	will	be	

terminated	at	25%	battery	power	reserve	or	30	minutes	of	flight	time	whichever	occurs	first.

• Flights	will	be	operated	at	an	altitude	of	no	more	than	400	feet	Above	Ground	Level	(AGL).	In	cases	

where	the	sUAS	is	used	to	survey,	inspect,	or	photograph	a	structure	that	exceeds	400	feet	AGL,	the	

sUAS	will	not	be	operated	more	than	200	feet	above	the	highest	point	of	that	structure.

• Minimum	crew	for	each	operation	will	consist	of	the	sUAS	Pilot,	the	Visual	Observer	(VO)	and	may	

include	but	not	limited	to	a	Camera	Operator.

• The	sUAS	pilot	will	be	a	designated	Pilot	in	Command	(PIC)	and	hold	either	an	airline	transport,	

commercial,	private,	recreational,	or	sport	pilot	certificate.	The	PIC	will	also	hold	a	current	FAA	

airman	medical	certificate	or	a	valid	U.S.	driver’s	license	issued	by	a	state,	District	of	Columbia,	

Puerto	Rico,	a	territory,	a	possession,	or	the	Federal	government	of	the	United	States.	The	PIC	will	

also	meet	the	flight	review	requirements	specified	in	14	C.F.R.	§61.56	in	an	aircraft	in	which	the	PIC	

is	rated	on	his	or	her	pilot	certificate.

• A	briefing	will	be	performed	regarding	the	planned	sUAS	operations	prior	to	each	day’s	flight	

operations, which	will	outline	the	individual	flight	activities	and	safety	measures.

• All	flights	will	occur	under	Visual	Meteorological	Conditions	(VMC)	only.

• The	flights	will	occur	no	closer	than	a	5-mile radius	of	the	geographic	center/Airport	Reference	

Point	(ARP)	of a	tower	controlled	or	uncontrolled	airport.

• If	operations	will	be	within	a	5	mile	radius	of	the	geographic	center/Airport	Reference	Point	(ARP)	

of	a	tower controlled	or	uncontrolled	airport	the	respective	airports	will	be	contacted	advising	

them	of	the	estimated	flight time,	flight	duration,	elevation	of	flight	and	other	pertinent	information.

• The	operator	will	file	FAA	Form	7711-1,	or	its	equivalent,	as	modified	in	light	of	the	requested	

exemption,	with the	appropriate	local	Flight	Standards	District	Office	(FSDO)	no	more	than	72	

hours	but	no	less	than	48 hours	from	planned	operation.

• The	operator	will	obtain	verbal/written	consent	of	all	persons	involved	with	the	planned	operation	

and	ensure that	only	consenting	persons	will	be	allowed	within	100	feet	of	the	flight	operation,	and	

the	radius	may	be reduced	to	30	feet	based	upon	an	equivalent	level	of	safety	determination.	With	

the	advanced	permission	of the	FSDO,	operations	at	closer	range	may	be	approved.

• The	PIC	and	VO	will	have	been	trained	in	operation	of	sUAS	and	receive	up-to-date	information	for	

the	particular sUAS	to	be	operated.

• The	PIC	and	VO	will	be	able	to	communicate	by	voice	or	radio	at	all	times.

• Written	and/or	verbal	permission	and	necessary	permits	will	be	obtained	from	territorial,	state,	

county,	or	city jurisdictions,	including	law	enforcement,	fire,	or	other appropriate	governmental	

agencies.

• If	the	sUAS	loses	communications	with	the	remote	controller	or	experiences	GPS	signal	
Stealth	Resource	Solutions,	LLC | P.O.	Box	1448	Plainfield,	IL	60544 | www.stealthresourcesolutions.com

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degradation,	the	sUAS will	have	the	capability	to	return	to	a	pre-determined	location.

• When	applicable,	GPS	Geo-Fencing	technology	will	be	used	to	place	limits	on	the	aircraft’s	

maximum	vertical and	horizontal	displacement	from	the	ground	control	point.

• The	sUAS	will	have	the	capability	to	abort	a	flight	in	case	of	unpredicted	obstacles,	weather,	or	

emergencies.

• The	sUAS	will	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.

• A	Motion	Picture	and	Television	Operations	Manual	(MPTOM)	will	be	used	to	help	govern	all	

closed-set	motion	picture	and	television	filming	operations.

14	C.F.R.	Part	21,	Subpart	H:	Certification	Procedures	- 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	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	(fixed	wing	or	rotorcraft)	operating	with	an	airworthiness	certificate	

without	the	restrictions	and	conditions	proposed.

The	sUAS	to	be	operated	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	secured	and	designated	

area. Unlike	other	civil	aircraft,	operations	under	this	exemption	will	be	tightly	controlled	and	monitored	

by	the	operator in	compliance	with	local	public	safety	requirements.	These	enhancements	provide	a	

greater	degree	of	safety	to	the public	and	property	owners	than	conventional	civil	aircraft	operations	

conducted	with	airworthiness	certificates issued	under	14	C.F.R.	Part	21,	Subpart	H.	Lastly,	there	is	no	

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

operation,	lack	of	explosive	materials	or	flammable	liquid	fuels,	and	its inability	to	carry	a	substantial	

external	load.	There	have	been	exemptions	granted	by	the	FAA	to	petitioners	seeking identical	relief;	See	

Grant	of	Exemption	No.	11062	to	Astraeus	Aerial	(FAA-2014-0352	at	pgs.	13-14,	22).

14	C.F.R.	Part	36,	Subparts	A,	F	and	O:	Noise	Standards	- Aircraft	Type	and	Airworthiness	

Certification Pursuant	to	14	C.F.R.	Part	36,	Subparts	A,	F	and	O,	establish	certain	noise	standards	for	

certification	of	various aircraft	types.	Because	the	Subject	sUAS	would	not	have	an	airworthiness	

certificate,	and	given	its	small	size	and negligible	noise	impact,	the	petitioner	requests	an	exemption	from	

14	C.F.R.	Part	36.

14	C.F.R.	§	45.23	(b):	Display	of	Marks;	General.

Pursuant	to	14	C.F.R.	45.23(b);	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.

While	the	sUAS	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,	two-inch	lettering	will	be	impractical.	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	sUAS	

marked	on	its fuselage	as	required	by	§45.29(f)	where	the	pilot,	observer,	and	others	working	with	the
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sUAS will	see	the identification	of	the	sUAS	as	“Experimental.”	In	a	previous	Grant	of	Exemption,	the	FAA	

determined	that exemption	from	these	requirements	was	warranted	provided	that	the	aircraft	“have	

identification	(N-Number) markings	in	accordance	with	14	C.F.R	Part	45,	Subpart	C	if	the	markings	are	as	

large	as	practicable.” See	FAA	Docket	No.	FAA-2014-0352.	All	sUASs	flown	by	Stealth	Resource	Solutions

will	bear	N-number markings	that	are	as	large	as	practicable	in	accordance	with	14	C.F.R.	Part	45,	Subpart	

C.

14	C.F.R.	§	61.113	(a)	and	(b):	Private	Pilot	Privileges	and	Limitations	- Pilot	in	Command.

Pursuant	to	14	C.F.R.	61.113	(a)	&	(b);	No	person	who	holds	a	private	pilot	certificate	may	act	as	a	pilot	in	

command of	an	aircraft	that	is	carrying	passengers	or	property	for	compensation	or	hire.	Because	the	

applicant’s	sUAS does not	carry	any	pilots,	passengers,	or	property,	Stealth	Resource	Solutions may	achieve	

an	equivalent	level	of	safety	as achieved	under	current	regulations.	The	risks	attendant	to	the	operation	of	

a	sUAS	is	far	less	than	the	risk	levels inherent	in	the commercial	activities	outlined	in	14	C.F.R.	61.	The	PIC	

of	the	sUAS	will	have	either	an	airline	transport, commercial,	private,	recreational,	or	sport	pilot	certificate.	

The	PIC	will	also	hold	a	current	FAA	airman	medical certificate	or	a	valid	U.S.	driver’s	license	issued	by	a	

state,	District	of	Columbia,	Puerto	Rico,	a	territory,	a possession,	or	the	Federal	government	of	the	United	

States.	In	meeting	those	limitations	as	listed	in	previous FAA	exemption	approvals,	the	PIC	of	Stealth	

Resource	Solutions sUASs	will	exceed	current	safety	levels	in	relation	to14	C.F.R.	61.113	(a)	&	(b).

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

Pursuant	to	14	C.F.R.	91.7(a);	No	person	may	operate	a	civil	aircraft	unless	it	is	in	airworthy	condition.	As	

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

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

maintenance	requirements	detailed	in the	sUAS	User	and/or	Operations	Manual	combined	with	safety	

checklists prior	to	each	flight,	an	equivalent	level of	safety	will	be	provided.	See	Grant	of	Exemption	No.	

11671	to	Dronair	Solutions	(FAA–2015–0648	page	18)	for previous	FAA	granted	exemption.

14	C.F.R.	§	91.9	(b)	(2):	Civil	Aircraft	Flight	Manual,	Marking,	and	Placard	Requirements.

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.	Given	the	size	and	configuration	of	the	sUAS	used	by	Stealth	Resource	

Solutions,	there	is	no capacity	to	carry	such	a	flight	manual	on	the	aircraft.	An	equivalent	level	of	safety	will	

be	achieved	by	keeping	the sUAS	Operation	Manual	at	the	ground	control	point	where	the	pilot	in	

command	will	have	immediate	access.	See Memorandum	from	Mark Bury,	FAA	Assistant	Chief	Counsel	for	

International	Law,	Legislation	and	Regulation,	to John	Duncan,	FAA	Flight	Standards	Service	(Aug.	8,	2014);	

see	also	Docket	No.	FAA-2014-0352	at	16-18.

14	C.F.R.	§	91.103(b)(2):	General	Operating	and	Flight	Rules	- Preflight	Action.

Pursuant	to	14	C.F.R.	91.103(b)(2);	For	civil	aircraft	other	than	those	specified	in	paragraph	(b)(1)	of	this	

section, other	reliable	information	appropriate	to	the	aircraft,	relating	to	aircraft	performance	under	

expected	values	of	airport elevation	and	runway	slope,	aircraft	gross	weight,	and	wind	and	temperature.	An	

equivalent	level	of	safety	will	be provided	by	a	preflight	checklist	and	other	safety	measures	detailed	in	the	

sUAS	Operation	Manual.	The	PIC	will	take actions	including	reviewing	weather,	flight	battery	requirements,	

landing	and	takeoff	distances,	aircraft	performance data,	and	setting	the	pre-determined	safe	landing	area	

in	case	of	loss	of	GPS	communication	before	initiation	of	flight. See	Grant	of	Exemption	No.	11671	to	

Dronair	Solutions	(FAA–2015–0648	page	18)

14	C.F.R.	§91.109:	Flight	instruction;	Simulated	Instrument	Flight	and	Certain	Flight	Tests.

Section	91.109	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.	Remotely	piloted	

aircraft	and	sUAS,	by their	design,	do	not	have	fully	functional	dual	controls.	Flight	control	is	accomplished	
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through	the	use	of	a	control box	that	communicates	with	the	aircraft	via	radio.	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.	Due	to	the	size and	speed	of	the	sUAS	and	the	fact	that	neither	a	pilot	

nor	passengers	will	be	carried	in	the	aircraft,	and	all	persons will	be	a	safe	distance	away	in	the	event	that	

the	UAS	experiences	any	difficulties	during	flight	instruction,	an equivalent	level	of	safety	is	provided.	The	

FAA	has	granted	exemption	for	the	same	operation,	See	Grant	of	Exemption No.	11671	to	Dronair	Solutions	

(FAA–2015–0648	page	19)

14	C.F.R.	§91.119:	General	Operating	and	Flight	Rules	- 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	sUAS	

operation	at	altitudes	up	to	400	feet AGL, an	exemption	may	be	needed.	In	cases	where	the	sUAS	is	used	to	

survey,	inspect,	or	photograph	a	structure that	exceeds	400	feet	AGL,	the	sUAS	will	not	be	operated	more	

than	200	feet	above	the	highest	point	of	that	structure. An	exemption	was	granted	by	the	FAA	for	like	

operations	- See	Grant	of	Exemption	No.	11138	to	Douglas	Trudeau (FAA-2014-0481	page	19)

An	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. Compared	to	flight	operations	with	aircraft	or	rotorcraft	operating	below	500	feet	AGL,	weighing	

far	more	than	the proposed	55-pound maximum,	and	carrying	flammable	fuel,	the	sUASs	employed	by	

Stealth	Resource	Solutions provide a	much	safer	alternative.	In	addition,	the	low-altitude	operations	of	the	

sUAS	will	ensure	safe	separation	from	those of	conventional	aircraft	that	must	comply	with	Section	91.119.

14	C.F.R.	§91.121:	General	Operating	and	Flight	Rules	- Altimeter	settings.

Section	91.121	requires	each	person	operating	an	aircraft	to	maintain	cruising	altitude	by	reference	to	an	

altimeter that	is	set	“...to	the elevation	of	the	departure	airport	or	an	appropriate	altimeter	setting	available	

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

exemption	may	be	needed. An	equivalent	level	of	safety	will	be	achieved	by	the	operator,	pursuant	to	the	

safety	check	list	and	live	flight	data monitoring,	confirming	the	altitude	of	the	launch	site	shown	on	the	GPS	

altitude	indicator	before	flight.	See	e.g., Grant	of	Exemption	No.	11062	to	Astraeus	Aerial	(FAA-2014-0352

at	21).

14	C.F.R.	§	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.”	For	similarly	FAA	granted	exemption,	see	

Grant	of	Exemption	to	Alan	Purwin	(Exemption	No. 11161).	The	battery	powering	the	sUAS	provides	

approximately	30	minutes	of	powered	flight.	Because	the	30-minute reserve	requirement	in	14	C.F.R.	

§91.151	cannot	be	met	by	the	sUAS,	an	exemption	is	needed.	With	a	limited	flight time	of	25	minutes	or	

25%	battery	power	and	line	of	sight	operation	in	a	limited	area,	an	equivalent	level	of	safety	is achieved.	

This	time/power	restriction	is	more	than	adequate	to	safely	return	the	sUAS	to	its	planned	landing	zone	

from anywhere	in	its	limited	operating	area.

14	C.F.R.	§91.203	(a)	and	(b):	Civil	Aircraft:	Certifications	Required

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	sUAS	fully	loaded	weighs	no	more	than	55	lbs.	and	is	

operated	without	an	onboard	pilot. As	such,	it	is	impractical	to	carry	certification	and	registration	
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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	in command	will	have	immediate	access.	The	FAA	

has	granted	exemption	for	same,	See	Grant	of	Exemption	No. 11671 to	Dronair	Solutions	(FAA–2015–0648	

page	18)

14	C.F.R.	§91.405	(a);	§91.407	(a)	(1);	§91.409	(a)	(2);	§91.417(a)	&	(b):	Maintenance	required.

Sections	91.405(a),	407(a)(1),	409(a)(2),	417(a)(b)	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.	Stealth	

Resource	Solutions proposes	that	the	maintenance of	the	sUAS	will	be	accomplished	by	the	

owner/operator	according	to	the	operation	manual.	As	provided	in	the attached	manuals,	the	operator	will	

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

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

aircraft	and	is	best	suited	to	maintain	the	aircraft	in	an	airworthy	condition	thereby	ensuring an	equivalent	

level	of	safety.	See	e.g.,	Grant	of	Exemption	No.	11671	to	Dronair	Solutions	(FAA–2015–0648	page	15)

PUBLIC	INTEREST

Stealth	Resource Solutions is	convinced	approvals	of	the	exemptions	requested	in	this	petition	are in	the	

public’s	interest. Our	conviction	stems	from	the	thorough	survey	of	the	applications	and	safety	

enhancements	that	sUAS	operations offer	to	a	wide	variety	of	existing	and	future	markets.	Many	of	the	

current	flight	operations	that	are	addressed	using manned	civil	aircraft	can	be	performed	by	smallunmanned aircraft	systems	with	reduced	environmental	impact, lower	cost,	and	increased	safety.	Consider	

the	following	comparison	between	the	sUAS	and	manned	civil	aircraft:

• The sUAS	is	smaller	and	weighs	considerably	less	than	manned	civil	aircraft.

o Reduces	hazard	to	property,	livestock,	and	the	general	population.

o The	sUAS	can	operate	in	smaller	areas	not	possible	with	large	aircraft.

• The	sUAS	uses	batteries	rather	than	combustible	fuel.

o Reduces	environmental	impact	by	eliminating	hydrocarbon	emissions.

o Non-flammable	power	source	reduces	fire	risk.

• The	sUAS	does	not	require	onboard	crewmembers flying	at	low	altitudes.

o Reduces	risk	of	injury	to	flight	operations	personnel.

Emerging	in	the	marketplace	are	many	applications	that	are	well	suited	for	sUAS	operations.	Stealth	

Resource	Solutions has	positioned	itself	to	provide	professional	sUAS	services	that	will	benefit	the	public	in	

support	of	commercial,	private,	and	governmental	sectors.	Examples	of	these	areas	may	include:

Although	video	and	photography	are	main	features	of	sUAS	operations,	there	are	a	multitude	of	other	

applications that	will	come	to	benefit	the	public.	In	addition	to	providing	videography/photography	for	

markets	like	real	estate and	public/private	events,	there	are	others	that	address	the	needs	of	far-reaching	

markets.	Examples	include:

Closed-Set	Filmmaking	and	Cinematography: Typically,	the	motion	picture	and	television	industry	uses	

manned airplanes	and	helicopters	to	carry	out	aerial	filming	of subject	matter.	They	are	usually	large,	

Local	Infrastructure	&	Agencies Solar	Power

Land	Planning	and	Development Power	Generation	and	Distribution

Agriculture Environmental	Research

Architecture	and	Engineering Search	and	Rescue

Training
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heavy,	and	powered	by combustible	fuel.	Using	a	sUAS	offers	a	level	of	safety	that	cannot	be	provided	by	its	

larger	counterparts.	The	small size,	light	weight	aircraft	are	powered	by	batteries	giving	them	the	

advantage	to	film	in	more	confined	areas	while reducing	risk	to	structure	and	persons.	Closed-Set	filming	

using	sUAS	is	in	the	interest	of	the	public	as	it	takes	place in	a	controlled	area,	away	from	spectators	and	

persons	not	involved	in	the	filming.

Agriculture: Special	lenses	fitted	to	the	sUAS	camera	allow	data	to	be	collected	from	images	that	

determine	the	health of	plants	growing	in	a	field.	That	data	is	used	to	calculate	more	precise	application	of	

pesticide,	fertilizer,	and	water thereby	limiting	and	conserving	resources.	This	can	ultimately	lead	to	

increased	crop	yield	at	reduced	cost.

Structural	Inspection: Image	data	collected	using	a	sUAS	can	be	utilized	to	create	3-dimensional	models	of	

structures. Engineers	can	use	these	3D	models	to	navigate	and	make	measurements	using	their	own	inhouse	CAD	software. A	considerable	advantage	is	gained	in	being	able	to	determine	repair	costs	and	design	

modifications	in	office	without having	to	make	measurements	that	rely	on	costly	high-risk	methods.	

Engineering	firms	can	benefit	by	reduced	cost and	enhanced	safety.

Environmental	Conservation: Images	collected	from	sUAS	flights	over	areas	of	interest	can	be	used	to	

create accurate	maps	and	models	of	parks,	reserves,	and	nature	conservation	areas	in	an	efficient	and

affordable	way.	Rather than	collecting	data,	personnel	can	spend	their	time	analyzing	the	maps	and	models	

for	various	actions	like	assessing environmental	regulation	adherence	or	creating	extensive	inventories	of	

natural	resources.

Accident	Scene	Reconstruction: A	traffic	accident	is	a	good	example	where	the	sUAS	size	and	

maneuverability	can provide	a	timely	and	accurate	method	of	data	collection.	Following	a	traffic	accident,	

there	is	a	limited	amount	of time	to	gather	information	for	use	in	reconstruction	of	the	event.	The	sUAS	can	

capture	ground	and	aerial	imagery to	be	used	in	constructing	3-dimensional	representations	of	the	

accident	scene.	The	resulting	models	can	be	used	at any	given	time	to	perform	accurate	measurements	and	

to	view	every	conceivable	angle	of	the	scene.	The	use	of	sUAS data	collection	provides	an	immediate	

response,	saves	expense,	and	offers	highly	accurate	output.

Solar	Power	Land	Development: Development	of	a	potential	solar	farm	site	requires	a	topographic	

survey	to	help plan	the	placement	of	the	photovoltaic	cells.	A	sUAS	can	serve	as	a	valuable	data	collection	

tool	for	rendering	complex 3-dimensional	models	of	the	land	under	consideration	or	development.	Slope	

angles	and	height	measurements	can be	made	using	the	image	data	collected	by	the	sUAS	cameras.	The	use	

of	sUAS	technology	reduces	time	and	cost compared	with	traditional	surveying	methods	while	providing	

increased	accuracy	and	accessibility.

Search	and	Rescue	(SAR): In	regard	to	search	and	rescue	operations,	the	public	stands	to	benefit	from	the	

use	of sUAS	technology.	The	sUAS	aircraft	are	able	to	perform	missions	with	a	high	level	of	complexity	and,	

at	the	same time,	require	less	human	operator	involvement	due	to	their	autonomous	behavior.	Because	the	

search	phase	in	SAR missions	is	critical	to	guarantee	broad	coverage	of	wide	areas,	the	sUAS	can	execute	

missions	autonomously	repeating area	coverage	multiple	times	when	needed.	During	the	rescue	phase,	the	

sUAS	can	be	used	to	deliver	medicine,	food, water,	etc.	to a	temporarily	non-accessible	person	or	persons.

The	applications	and	services	discussed	above	are	only	a	small	sample	of	a	virtually	limitless	set	of	

potential	benefits the	public; private,	and	governmental	sectors	stand	to	gain.	Stealth	Resource	Solutions is	

purposeful	in	providing	safe	and valuable	services	and	are	convinced	that	approval	of	the	exemptions	

requested	in	this	petition	are,	without	a	doubt, in	the	public’s	interest.

Stealth	Resource	Solutions would	like	to	thank	the	FAA	for	considering	this	request.	We	look	forward	to	

working	with the	FAA	in	its	determination,	and	to	being	part	of	the	discussions	as	the	FAA	considers	how	to	
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expand,	certify,	test, register,	track,	and	control	commercial	sUAS	use	in	the	United	States.

Respectfully	Submitted,

Emmit	Q.	Hoosman

Chief	Pilot	&	President,

On	behalf	of	Stealth	Resource	Solutions,	LLC.

Attachments:	19
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APPENDIX	A

SUMMARY	OF	SECTION	333	EXEMPTION	REQUEST

Stealth	Resource	Solutions,	LLC,	hereby	provides,	pursuant	to	14	C.F.R.	Part 11	Subpart	A	§11.81,	a	

summary	of	our exemption	petition	to	allow	commercial	operation	of	sUAS	for	aerial	video	and	

photography,	precision	aerial mapping,	3D	modeling,	surveying,	cataloguing,	and	inspection	services.	Our	

pursuit	for	exemption	is	intent	on benefiting	both	public	and	governmental	sectors	some	of	which	include:

• Agriculture

• Land	Planning	&	Development

• Local	Infrastructure

• Solar	Power

• Power	Generation	and	Distribution

• Architecture	and	Engineering

• Environmental

• Search	&	Rescue

• Training

Stealth Resource	Solutions is	poised	to	provide	service	in	support	of	these	and	future	applications	with	the	

utmost attention	to	quality	and	safety.	Therefore,	we	respectfully	request	exemption	from	the	following	

regulations:

14	C.F.R.	Part	21	Subpart	H	 Certification	Procedures	for	Products	and	Parts	– Airworthiness	

Certificates.

14	C.F.R.	Part	36	Subpart	A,	F	&	O	 Noise	Standards:	Aircraft	Type	and	Airworthiness	Certification.

14	C.F.R.	§45.23	(b) Display	of	Marks;	General.

14	C.F.R.	§61.113	(a)	&	(b)	 Private	Pilot	Privileges	and	Limitations:	Pilot	In	Command.

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

14	C.F.R.	§91.9	(b)	(2) Civil	Aircraft	Flight	Manual,	Marking,	and	Placard	Requirements.

14	C.F.R.	§91.103(b)(2) General	Operating	and Flight	Rules	- Preflight	Action.

14	C.F.R.	§91.109 Flight	Instruction;	Simulated	Instrument	Flight	and	Certain	Flight	

Tests.

14	C.F.R.	§91.119	(c)	 General	Operating	and	Flight	Rules	- Minimum	Safe	Altitudes.

14	C.F.R.	§91.121	 General	Operating	and	Flight	Rules	- Altimeter	settings.

14	C.F.R.	§91.151	(a)	 Fuel	Requirements	for	Flight	in	VFR	Conditions.

14	C.F.R.	§91.203	(a)	&	(b)	 Civil	Aircraft:	Certifications	Required.

14	C.F.R.	§91.405	(a)	 Maintenance	Required.
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14	C.F.R.	§91.407	(a)	(1) Operation	After	Maintenance,	Rebuilding,	or	Alteration.

14	C.F.R.	§91.409	(a)	(2) Inspections.

14	C.F.R.	§91.417	(a)	&	(b)	 Maintenance	Records.