~ SKINNERLAWGROUP 

July 28, 2015 Will S. Skinner 

818.710.7708 direct 

VIA FEDERAL EXPRESS 

U.S. Department of Transportation 

Docket Management System 

1200 New Jersey Ave., SE 

Washington, DC 20590 

skinner@skinnerlawgroup.com 

Re: Exemption Requests Submitted Pursuant to Section 333 of the FAA 

Modernization and Reform Act of2012 and 14 C.F.R. § 11 

Dear Sir or Madam: 

Pursuant to Section 3 3 3 of the FAA Modemization and Reform Act of 2012 ("FAA 

Reform Act") and 14 C.P.R. Part 11, Unmanned Aerial Enterprises, LLC. ("UAE"), a 

Califomia limited liability company, hereby requests exemptions from provisions of 

the Federal Aviation Regulations ("FAR"); namely portions of 14 C.P.R. Parts 45, 61, 

and 91 to allow commercial operations of unmanned aerial vehicles in remote and 

rural areas of the United States, as further defined herein, by a Pilot-in-Command 

("PIC") holding a private pilot certificate. 1 

I. SUMMARY OF SECTION 333 EXEMPTION REQUESTS 

1. Aero Vironment Puma AE 

2. Precision Hawk 

3. DJI S 1000, S800 

4. DJI S900 

5. DJI F550 

6. DJI F450 

7. DJI Phantom 2 + 

8. Mulit-Rotor G4 

1 Public Law (P.L) 112-95, 126 Stat 11, February 14 2012 

21600 Oxnard Street I Suite 1760 I Woodland Hills CA 91367 I 818.710.7700 I 818.710.7701 fax I skinnerlawgroup.com 
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Page 2 

II. AEROVIRONMENT PUMA AE EXEMPTION REQUEST 

The Aero Vironment Puma AE ("Puma") is an all-environment, electric-powered, 

hand-launched, small UAS ("UAS"). Depending on its payload, it is capable of 

transmitting live airborne video images and location information to a Ground Control 

Station ("GCS"), conducting high-resolution photogrammetry, or Light Detection and 

Ranging ("LIDAR") data collection. When used for high resolution photographs and 

LIDAR data, the Puma stores the photographs and data via onboard non-volatile 

memory (i.e. "memory card" or equivalent). The Puma has a maximum weight of 

15.5 pounds, a wingspan of9.2 feet, a length of 4.7 feet, a minimum cruising speed of 

36 ft/s and maximum speed of 69 ft/s. It is battery-powered with flight endurance 

between 2.0 to 3.5 hours, with operating range between -22°F to 122°F ambient 

temperature, and can be either hand or rail-launched. The Puma's omnidirectional 

antenna has a range of 6.2 miles, and its directional antenna has a range of 12.4 

miles. 2 

The Puma's capabilities make it ideally suited to conduct commercial operations in 

agriculture, aerial surveying, and remote-area patrols (i.e. patrols over non-congested 

areas) under Class E or Class G airspace within Visual Line of Sight ("VLOS"). 

Some Class D airspace may be used on a case-by-case basis and would be further 

defined during the Certificate of Authorization ("COA") process. The Puma reduces 

the need to operate manned aircraft, thereby decreasing the risk to the pilot, crew, and 

those on the ground as the Puma is simply carried as opposed to being flown to the 

site with a load of flammable fuel. 

The Puma is unique amid the exemption applications under Section 333 because it 

has received a restricted category type certificate from the FAA based on its 

acceptance for use by the US Military.3 Accordingly, the Puma has an unparalleled 

safety record. When its experience is considered within the proposed remote and/or 

rural areas, it is clear that the Puma has demonstrated, and will in this context again 

demonstrate, that it can operate safely within the confines of the National Airspace 

System ("NAS"). 

UAE's exemption request encompasses the following regulations: 4 

2 For more detailed information on the Puma's specification, UAE directs the FAA to AeroVironment's type certificate data sheet 

QOOO 18LA. U AE also incorporates by reference all of the materials submitted in support of Aero Vironment' s application for a 

Restricted Category Type Certificate, Q00018LA, and Certificate of Waiver or Authorization, 2014-AHQ-100. 3 FAA, Press Release, FAA Approves First Commercial UAS Flights over Land (June 10, 2014 ), 

http://www .faa.gov/news/press _releases/news _story .cfm?newsid= 16354. 4 Based on a recent legal interpretation, UAE does not believe that it needs an exemption from 14 C.F.R.§§ 91.9(b), 91.203(a), 

and 91.203(b) because the Puma's flight manual, airworthiness exemption, and registration certificate will be maintained at the 

pilot's control station. FAA Legal Interpretation from Mark W. Bury, Assistant Chief Counsel for International Law, Legislation 

and Regulations (August 8, 2014 ). Should the FAA determine that an exemption is required, UAE respectfully requests one on 

the basis that similar exemptions have been granted on numerous occasions. See Exemptions 8607, 8737, 9299, 9565, 9665, 9789, 

9797 10167, 10602, 10700, and 32827. 
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14 C.F.R. § 45.23(b) 

14 C.F.R. § 61.113(a) and (b) 

14 C.F.R. § 61.133(a) 

14 C.F.R. § 91.7(a) and (b) 

14 C.F.R. § 91.109(a) 

14 C.F.R. § 91.119 

14 C.F.R. § 91.151(a 

14 C.F.R. § 91.405(a) 

14 C.F.R. § 91.407(a)(1) 

14 C.F.R. § 91.409(a)(2) 

14 C.F.R. § 91.417(a) 

Section 333's Mandate and the Federal Aviation Act 

Grant of this exemption application for use of the Puma in agriculture, precision 

aerial surveys, and patrols, pursuant to the exemption requested herein, will advance 

the Congressional mandate in Section 3 3 3 of the FAA Reform Act to accelerate the 

introduction of UAS into the NAS. Section 333 directs the Secretary of 

Transportation to consider whether certain UASs may operate safely in the NAS 

before completion of the rulemaking required under Section 332 of the FAA Reform 

Act. To make that determination, the Secretary must evaluate which types of UASs 

do not create a hazard to users of the NAS or the public or pose a threat to national 

security in light of several criteria: 

• 

• 

• 

The UAS's size, weight, speed, and operational capability; 

Operation of the UAS in close proximity to airports and populated areas; and 

Operation of the UAS within visual line of sight of the operator . 

FAA Reform Act§ 333(b)(1). Once the Secretary determines that such vehicles "may 

operate safely in the national airspace system, the Secretary shall establish 

requirements for the safe operation of such aircraft in the national airspace system." 

!d. § 333(c) (emphasis added).5 

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

49 U.S.C. § 44701(f). This statutory authority, by its terms, includes exempting civil 

aircraft, as the term is defined under §40 101 of the Act, from the requirements that all 

civil aircraft must have a current airworthiness certificate, 49 U.S.C. § 44711(a), and 

those used in commercial service must be piloted by commercial pilots. 14 C.F.R. §§ 

91.61.113(a) and (b), 61.133. 

The grant of the requested exemption is in the public interest based on (i) the clear 

direction in Section 333 of the FAA Reform Act; (ii) additional authority in the 

Federal Aviation Act, as amended; (iii) the strong equivalent level of safety 

surrounding the proposed operations; and (iv) the significant public benefit, including 

enhanced safety and cost savings associated with utilizing UASs for agriculture, 

5 UAE submits that this provision places a duty on the Administrator not only to process applications for exemptions under 

Section 333, but for the Administrator to supply conditions for the safe operation of the Puma if he deems the conditions 

proposed herein require modification necessary to allow approval. 
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aerial survey photography, and patrolling. Accordingly, UAE respectfully requests 

that the FAA grant the requested exemption without delay. 

Airworthiness 

The Puma is safe for operation in the NAS under the conditions listed herein. The 

FAA has deemed the Puma safe because the US Military has accepted it for use. The 

US Military has flown the Puma since 2007, amassing over one million flight hours 

on the AeroVironment family ofUAS. Based on the US Military's acceptance of the 

Puma, the FAA issued the Restricted Category Type Certificate QOOO 18LA and also 

recently granted Aero Vironment a Certificate of Waiver or Authorization to conduct 

commercial operations over land in Alaska. 

Should you deem necessary, UAE is prepared to submit, in support of this application 

under separate cover and with a request for confidentiality, the following documents: 

the FAA-approved Airplane Flight Manual ("AFM") for the Puma, accepted May 20, 

2014 by the FAA; the Puma's Maintenance Manual dated July 18, 2013; the North 

Slope Standard Operating Procedures Manual ("SOP") dated May 2014;6 the AV 

Training Conduct Support Document dated May 4,2012; and the AeroVironment 

Remote Area UAS Operations Safety Case Assessment dated September 13,2014. 

Mandatory Operating Conditions 

UAE proposes that the grant of the exemption be subject to the following mandatory 

conditions, which are based upon operating conditions set forth for operation ofUAS 

by public entities pursuant to Certificates of Waiver or Authorization, the conclusions 

of the Remote Area UAS Safety Case Assessment, and with additional restrictions: 

• All operations to occur in Class E or Class G airspace over areas with a 

population density of 360 persons per square mile or less. 7 Some Class D 

airspace may be used on a case-by-case basis and would be further defined 

during the COA process. 

• Operations to be conducted over private or controlled-access property to limit 

the number of persons not associated with the operations placed at risk. 

• Permission from land owner/controller required before commencing any flight. 

6 The North Slope SOP identifies requirements and describes procedures for the AeroVironment Digital Imaging and Mapping 

team to coordinate, plan, and conduct imaging operations for services in support of BP Exploration Alaska Nmih Slope, Alaska. 

AeroVironment's submission of the North Shore SOP indicates how seriously it takes the safety of its Puma operations. 

AeroVironment intends to supplement its application with a Standard Operating Procedures manual for operations in other remote 

areas as soon as possible. 7 See Section 2.2.5 ofthe AeroVironment Remote Area UAS Operations Safety Case Assessment dated September 13, 2014 for 

an explanation of the "remote area" definition. The benefits of operating in "remote areas" are discussed in further detail in the 

Section below entitled "Proposed Operations Locations." 
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• Operations to occur during Visual Flight Rules Meteorological Conditions. 

• Aircraft to remain within VLOS. 

• Operations to occur during daylight hours. 

• Above Ground Level ("AGL") altitude to be restricted to 400 feet. 

• Flights over sensitive infrastructure such as pipelines or roads will be 

minimized to reduce the time the infrastructure is placed at risk. 

• Flights over sensitive infrastructure will be offset appropriately for the wind at 

the time of flight to reduce the risk to the infrastructure. 

• Launch and recovery areas will be cordoned off to limit access only to 

personnel associated with the flight operation. 

• A dedicated Visual Observer (usually, but not always the PIC) will be utilized 

to Maintain overall operation situational awareness; maintain VLOS and scan 

for intruder traffic; monitor all radio communication to include "Guard" in 

accordance with any COA; and report on Common Traffic Advisory Frequency 

("CT AF") and other frequencies as appropriate. 

• All operations conducted in vicinity of airport to remain more than 2.5 NM 

from 

• Centerline azimuth of runway centerline measured from runway thresholds. 

• Operator will file a Notice to Airman ("NOT AM") for each flight. 

• All required authorizations and permits will be obtained from territorial, state, 

county, or city jurisdictions, including local law enforcement, fire, or other 

governmental agencies. 

Proposed Operations Locations 

UAE proposes to operate in areas where the population density is less than 360 

people per square mile. Operating in these "remote areas" lowers the risk posed to 

third parties to 1 x 10-9

. Section 2.2.5 of the Aero Vironrnent Remote Area UAS 

Operations Safety Case Assessment dated September 13, 2014 describes the 

methodology for determining the suitability of operational areas for these proposed 

commercial operations. Operations in such sparsely populated areas and at low 

altitudes do not create hazards for users of the NAS or the public. 

Operator Requirements 

UAE proposes that operator requirements should take into account the characteristics 

of the particular UAS. The Puma is an inherently stable, light-weight aircraft that 

weighs 15.5 pounds and will be operated in remote areas. The safety concerns 

addressed by requiring a commercial pilot certificate are simply not present. 

Moreover, the Puma has an advanced autopilot that flies the aircraft, while managing 

altitude and flight path within the intended flight envelope at all times when that 

flight mode is engaged. The autopilot limits maneuvering to minor airspeed, altitude, 

and rate-of-tum changes. These limits are hard coded into the autopilot and define 

the aircraft's normal flight operating envelope. The autopilot manages pitch, bank, 
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and throttle to maintain target airspeed, target turn rate, and target altitude. For inflight modes that do not use GPS, the operator manually guides the flight path by 

controlling target airspeed, target altitude, and target turn rate directly. In flight 

modes that use GPS, the autopilot controls target turn rate to fly to waypoints. The 

system does not allow commands that are outside of the nom1al operating envelope, 

and the operator never affects control surface movements directly. 8 

Low Risk Index 

The Puma is a modular structure, comprised of composite materials, several of which 

disassemble on impact to decrease risk of injury to people, absorb energy, and reduce 

damage to the Puma during landing. To that end, the Puma's wing is composed of 

Styrofoam laminated with a thin layer of Kevlar that disassembles into its subcomponents upon impact. 

The Puma Autoland feature enables landings in confined areas. Once Autoland 

begins, power is cut to the motor, the gimbaled payload is stowed (if installed), and 

the stabilator deflects fully trailing-edge upward. As a result, the aircraft pitches 

nose-up, with wings level, and begins a descent to the ground with approximately a 

1:1 glide ratio. The pilot can steer during the Auto land phase, if required. Impact 

with the ground usually causes the Puma's components to separate. As noted above, 

this helps alleviate the impact of the landing and protects the airframe. During water 

landings, lanyards prevent separated parts from floating away from the fuselage, 

which too will float. Landing pads on the bottom of the fuselage also provide impact 

protection. 

During Loss of Link ("LOL"),9 the Puma has three options-finish the programmed 

flight, land immediately, or go to a rally point. If link is re-established during LOL, 

the aircraft operator can simply press the enter button on the hand controller to 

resume the indicated flight mode or change to a desired flight mode. Setting the LOL 

action prior to launch is a mandatory check on the pre-flight check list. During loss 

of GPS, the pilot should use the Puma's last known bearing or tenain association to 

fly toward a landing site or select a suitable landing site and command the Puma to 

auto land. 

Given these safety features, UAE proposes that operators of the Puma should not be 

required to possess a commercial pilot certification. Instead, operators should be 

required to meet the following criteria: 

• Possess private pilot ce1iificate; 

8 See Puma AFM, at 55-56. 9 Loss of Link is identified by unchanging video and unchanging data and time, as well as the appearance of a clock symbol on 

the Link Status Bar. Loss of Link does not necessarily mean that the Puma has lost GPS. 
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• Maintain, at a minimum, a valid FAA third-class medical certificate; and 

• Complete the manufacturer's US Military-approved training program for 

operation of the UAS. 

UAE notes that the FAA has found that safety factors have permitted operation of 

UAS by operators with these qualifications pursuant to COAs for public aircraft when 

the mandatory operating conditions specified above were present. See Federal 

Aviation Administration, Notice N8900.227, Unmanned Aircraft Systems (UAS) 

Operational Approval, at 20-21 (July 30, 2013). 

Specific Exemption Requests and Equivalent Level of Safety Showings 

14 C.F.R. § 45.23(b)- Display of marks; general 

Section 45.23(b) provides as follows: 

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. 

The Puma has no entrance to the cabin, cockpit, or pilot station on which the word 

"Restricted" can be placed as required by this provision. Two-inch lettering also is 

not possible given the overall size of the Puma. UAE, therefore, requests an 

exemption to display, with one-inch lettering, the word "Restricted" on the forward 

fuselage in compliance with § 45.29(f). 

The equivalent level of safety will be achieved by having the Puma marked with oneinch lettering on its forward fuselage because the pilot, observer, and others working 

with the UA V will see the identification of the UAS as "Restricted." The FAA has 

issued similar exemptions to this regulation, including to Pioneer Hi-Bred 

International, Inc., Exemption No. 10810; Raytheon Missile Systems/Advanced 

Programs, Exemption Nos. 10167 and 8738; and Trimble Navigation Limited, 

Exemptions No. 10700 and 11042. 

14 C.F.R. §§ 61.113(a) and (b), 61.133(a) - Private Pilot Privileges and 

Limitations: Pilot in Command; Commercial Pilot Privileges and Limitations 

Subsections (a) and (b) of § 61.113 prohibit private pilots from operating aircraft in 

commercial operations, and Section 61.133(a) requires an individual operating an 

aircraft for compensation or hire to hold a commercial pilot certificate. As mentioned 
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above, the FAA has the statutory authority to wmve the pilot requirements for 

conunercial operations. 49 U.S.C. § 44701(£). 

UAE requests an exemption from 14 C.F.R. §§ 61.113(a) and (b) and 14 C.F.R. § 

61.133(a) so that the Puma may be operated by individuals who (a) have a private 

pilot certificate, and (b) have completed Aero Vironment' s US Military -approved 

training program for operation of the Puma. 

Based upon the design features of the Puma, its autopilot system, and safety factors, 

the FAA should permit operation ofUAS by operators with a private pilot certificate 

when the conditions described above have been satisfied. The above-described 

conditions are in-line with those set forth in FAA Order 8900.1, Volume 16, Chapter 

4, Section 1. 

UAE proposes to conduct operations in accordance with these restrictions. Given 

these conditions and restrictions, an equivalent level of safety will be provided by 

allowing operation of the Puma with a private pilot certificate. The risks associated 

with the operation of the Puma (given its size, speed, operational capabilities, and 

lack of combustible fuel) are so much less than the level of risk associated with fixed 

wing and rotorcraft operations, both private and commercial, as contemplated by Part 

61, that allowing operations of the Puma, as set forth above, meets or exceeds the 

present level of safety provided under 14 C.F.R. §§ 61.113(a) & (b) and 61.133(a). 

14 C.F.R. § 91.7(a) and (b): Civil aircraft airworthiness. 

Sections 91.7(a) and (b) prohibit operation of a civil aircraft unless it is in airworthy 

condition. UAE requests an exemption from this regulation because the Puma would 

not operate with an airworthiness certificate under the proposal set forth in this 

filing. 10 Given the size of the aircraft and the requirements that have already been 

met in approval of AeroVironment's Restricted Category Type Certificate and 

Certificate of Waiver or Authorization, an equivalent level of safety will be achieved 

by ensuring compliance with Aero Vironment' s manuals prior to each flight. 

14 C.F.R. § 91.109(a): Flight Instruction 

Sections 91.1 09( a) 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. 

The Puma is a remotely piloted aircraft, and, by design, it does not have fully 

functional dual controls. Flight control is accomplished through the use of a control 

box that communicates with the aircraft via radio communications. Completing 

10 The restricted category type certificate that AeroVironment has received for the Puma is limited to Alaska. 
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instruction through AeroVironment's training program will ensure an equivalent level 

of safety. 

The FAA has approved exemptions for flight training without fully functional dual 

controls for a number of aircraft and for flight instruction in experimental aircraft. See 

Exemption Nos. 5778K and 9862A. 

14 C.F.R. § 91.119: Minimum Safe Altitudes 

Section 91.119 establishes safe altitudes for operation of civil aircraft. Specifically, 

Section 91.119( c) limits aircraft flying over areas other than congested areas to 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 set forth herein, the Puma will never operate 

at higher than 400 feet AGL. It will, however, be operated in a manner that avoids 

congested or populated areas as described in the Proposed Operations Locations 

section above. Because agriculture, aerial survey work, and patrolling must be 

accomplished at relatively low altitudes, i.e., less than 500 feet AGL, an exemption 

from Section 91.119( c) is needed. 

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

material with which the Puma is built. Also, no flight will be taken without the 

permission of the landowner or the party controlling the land. With advance notice to 

the landowner, all affected individuals will be aware of the agriculture, survey, and 

patrolling flights. Compared to similar operations conducted with conventional 

aircraft or rotorcraft, which weigh thousands of pounds and carry flammable fuel, any 

risk associated with these operations will be far less than those currently allowed with 

such conventional aircraft operating at or below 500 feet AGL. 

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

Section 91.151 (a) prohibits an individual from begi1ming "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. § 91.151(a). 

The Puma's batteries provide between 2 and 3.5 hours of powered flight. Without an 

exemption from 14 C.F.R. § 91.151, the Puma's flights would be limited to 

approximately 1.5 hours in length. Given the limitations on its proposed operations 

and the location of those proposed operations, a longer time frame for flight in 

daylight VFR conditions is reasonable. 
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An exemption from 14 C.F.R. § 91.151(a) is safe and consistent within the scope of a 

prior exemption. See Exemption 10673 (allowing Lockheed Martin Corporation to 

operate without compliance with 91.151(a)). Operating the Puma, a UAS, without 30 

minutes of reserve fuel does not create the type of risks that Section 91.151(a) was 

meant to prevent. The fact that the Puma neither carries persons nor cargo only 

enhances its safety. Additionally, limiting Puma flights to 1.5 hours would greatly 

reduce its utility and capability. In the unlikely event that the Puma should run out of 

fuel, it would simply land. Given its weight and materiel construction, the risks are 

less than contemplated by the current regulation. 

An equivalent level of safety can be achieved by maintaining 10 minutes of reserve 

fuel, which, allowing one hour and 50 minutes of flight time, would be more than 

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

operating area. 

Similar exemptions have been granted to other applicants, including but not limited to 

Exemptions 2689F, 5745, 10673, and 10808. 

14 C.F.R. §§ 91.405(a); 91.407(a)(l); 91.409(a)(2); 91.417(a): Maintenance 

Inspections 

Section 91.405(a) requires 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." Section 91.407 similarly makes 

reference to requirements in Part 43; Section 91.409(a)(2) requires an mmual 

inspection for the issuance of an airworthiness certificate. Section 91.417(a) requires 

that an owner or operator keep records showing certain maintenance work that has 

been accomplished by certificated mechanics, under Pm·t 43, or licensed pilots and 

records of approval of the aircraft for return to service. 

Maintenance of the Puma will be accomplished only by UAE trained staff pursuant to 

the manufacture's supplied manuals and training program. An equivalent level of 

safety will be achieved because the Puma is small in size, will carry no external 

payload, will operate only in restricted predetermined areas, and is not a complex 

mechanical device. As provided in the Maintenance Manual and the SOP, the 

operator of the Puma will ensure that it is in working order prior to initiating flight, 

perform required maintenance, and keep a log of any maintenance that is 

perforn1ed. 11 Moreover, the operator is the person most familiar with the aircraft and 

is best suited to maintain the aircraft in an airworthy condition and to ensme an 

equivalent level of safety. 

11 Although the remote area SOP will differ in some respects from the North Slope SOP, it will include the identical requirements 

that the Puma operator ensure the Puma is in working order prior to flight, perform required maintenance, and keep a log of any 

maintenance performed. 
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The Puma comes with one Field Repair Kit ("FRK"). The FRK includes the items 

necessary to conduct field repairs or routine maintenance. 

Federal Register Summary 

Pursuant to 14 C.F.R. § 11.81(£), the following summary is provided for publication 

in the Federal Register, should the FAA determine that publication is needed: 

Docket No.: No. FAA-2015-

Petitioner: Unmanned Aerial Enterprises, LLC ("UAE"). 

Section of 14 CFR: 14 C.F.R. § 45.23(b), 14 C.F.R. § 61.113(a) and (b); 14 C.F.R. § 

61.133(a), 14 C.F.R. § 91.7(a) and (b), 14 C.F.R. § 91.109(a), 14 C.F.R. § 91.119, 14 

C.P.R. § 91.151(a), 14 C.F.R. § 91.405(a), 14 C.F.R. § 91.407(a)(1), 14 C.F.R. § 

91.409(a)(2), 14 C.F.R. § 91.417(a). 

Description of Relief Sought: Unmanned Aerial Enterprises, LLC is seeking an 

exemption to conduct commercial agriculture, aerial survey, and patrol operations 

using a small unmmmed vehicle (55lbs or less) in remote and rural areas of the 

United States using private pilots. 

UAE will file an application for COA approval of specific flight locations. Should 

the FAA need or require identification of such location in this application, UAE will 

supplement the record as requested. 

Based upon the foregoing, UAE requests that the FAA grant it the necessary 

exemptions under Section 333 of the FAA Reform Act and 49 U.S.C. §44701(£) as 

requested herein to allow commercial operations of the Puma within the areas defined 

above. 

* * * 
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Ill. EXEMPTION REQUESTS FOR PREVIOUSLY APPROVED UAS 

UAE hereby respectfully requests exemptions to operate the following UAS based on 

like and similar exemptions already granted: 

Fixed "Ving Aircraft 

Precision Hawk 

Multi-Rotor Aircraft 

DJI S 1000, S800 

DJI S900 

DJI F550 

DJI F450 

DJI Phantom 2 + 

Mulit-Rotor G4 

Previously Approved Exemption Number 

11345 

Previously Approved Exemption Number 

11401 

11256 

11397 

11287 

11138 

11306 

The requested exemptions would permit UAE to pursue its commercial interests in 

providing services to clients using UAS in rural or sparsely populated areas of the 

United States. 

Contact Information 

Unmanned Aerial Enterprises, LLC 

Attn: Will S. Skinner 

21600 Oxnard Street, Suite 1760 

Woodland Hills, CA 91367 

(818) 710-7708 Direct 

(818) 710-7701 Fax 

skinner@skim1erlawgroup.com 

Very truly yours, 

Will S. Skinner