April 20, 2015

U. S. Department of Transportation

Docket Management System

1200 New Jersey Ave., SE

Washington, DC 20590

Exemption Request Section 333 of the FAA Reform Act and Part 11 of the Federal Aviation 

Regulations from 14 CFR Part 21; 61.113 (a) & (b); 91.7 (a); 91.9 (b) (2); 91.103(b); 91.109;

91.119; 91.121; 91.151(a); 91.203(a) & (b); 91.405(a); 91.407(a) (1); 91.409 (a) (2); 91.417 (a) 

& (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, Daniel C. Augspurger, operator of Unmanned Aircraft

Systems (“UASs”) equipped to offer on-demand commercial UAS operations for aerial data 

collection that involves aerial surveying, construction site inspection and monitoring, and real 

estate and marketing photography/videography, hereby applies for an exemption from the listed 

Federal Aviation Regulations (“FARs”) to allow commercial operation of its microUAS, 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.

As described in this document and the attached Flight Manual, the requested exemption 

would permit the operation of small, unmanned and relatively inexpensive UAS under controlled 

conditions in airspace that is 1) limited 2) predetermined 3) controlled as to access and 4) would

provide safety enhancements to the already safe operations using conventional aircraft.

Approval of this exemption would thereby enhance safety and fulfill the Secretary of

Transportation’s (the FAA Administrator’s) responsibilities to “...establish requirements for the 

safe operation of such aircraft systems in the national airspace system.” Section 333(c) of the 

Reform Act.

The name and address of the applicant is:

Daniel C. Augspurger

1552 Progress St

North Liberty, IA

Ph: 319.333.9414

Email: daugs4@gmail.com

FAA Certificate # 2840369 ATP

Daniel C. Augspurger is a professional pilot that makes his living flying corporate jets. He 

holds an Airline Transport Pilot’s license with a first-class medical along with a Certified Flight 

Instructor Airplane (CFI) and Instrument Instructor (CFII) rating and has accumulated over 3500 

hours of flight time. He has been flying professionally for 10 years and still makes occasional 

use of his CFI and CFII licenses in single engine aircraft. 

Attachments to this exemption request include the Yuneec Q500 user manual and the 

Flight Manual which includes conditions and limitations of operations, checklists, and the 

maintenance log.
REGULATIONS FROM WHICH THE EXEMPTION IS REQUESTED:

14 CFR Part 21

14 CFR 61.113 (a) & (b)

14 C.F.R. 91.7 (a)

14 CFR 91.9 (b) (2)

14 C.F.R. 91.103

14 C.F.R. 91.109

14 C.F. R. 91.119

14 C.F.R. 91.121

14 CFR 91.151 (a)

14 CFR 91.203 (a) & (b)

14 CFR 91.405 (a)

14 CFR 407 (a) (1)

14 CFR 409 (a) (2)

14 CFR 417 (a) & (b)

STATUTORY AUTHORITY FOR EXEMPTIONS

This exemption application is expressly submitted to fulfill Congress’ goal in passing

Section 333(a) through (c) of the Reform Act. This law directs the Secretary of Transportation to 

consider whether certain unmanned aircraft systems may operate safely in the national airspace 

system (NAS) before completion of the rulemaking required under Section 332 of the Reform 

Act. In making this determination, the Secretary is required to determine 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 the following:

• 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.

Daniel C. Augspurger’s microUAS are rotorcraft, weighing 4 or fewer lbs. including 

payload. They operate, under normal conditions at a speed of no more than 15 knots and have 

the capability to hover, and move in the vertical and horizontal plane simultaneously. They will 

operate only in line of sight and will operate only within a sterile area. Such operations will 

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

public.” Reform Act Section 333 (b).

Given the small size of the UASs involved and the restricted sterile environment within

which they will operate, the applicant falls squarely within that zone of safety (an equivalent 

level of safety) in which Congress envisioned that the FAA must, by exemption, allow 

commercial operations of UASs to commence immediately. Also due to the size of the UASs 

and the restricted areas in which the relevant UASs will operate, approval of the application 

presents no national security issue. Given the clear direction in Section 333 of the Reform Act, 

the authority contained in the Federal Aviation Act, as amended; the strong equivalent level of 

safety surrounding the proposed operations, and the significant public benefit, including 

enhanced safety, reduction in environmental impacts, including reduced emissions associated 

with allowing UASs, the grant of the requested exemptions is in the public interest.
SPECIFIC AREAS THIS EXEMPTION WILL BENEFIT THE PUBLIC INTEREST:

- Real Estate and Marketing Purposes (photography/videography).

1. Aerial videography for geographical awareness and for real estate marketing has 

been around for a long time through manned fixed wing aircraft and helicopters. For 

small budget real estate companies and average homeowners the expense of such 

aerial videography is cost prohibitive.

2. Only large companies or high-end realtors or luxury homeowners can afford to 

absorb the expense of manned aircraft videography. This deprives small budget real 

estate companies and the average homeowner of a very valuable marketing tool.

3. Manned aircraft pose a threat to the public through potential catastrophic loss or 

crash of a large aircraft. Loaded with explosive hydrocarbon based fuel, a much 

larger risk is imposed on the general public than a small, less than 4 lbs, UA that is 

powered by a small battery.

4. Daniel C. Augspurger will eliminate the above problems by offering the use of a 

small, ultra-light weight UA that is powered by a no emission battery and is very 

inexpensive to operate and own as compared to a large manned aircraft. This serves 

the public interest by making such operations safer and much more affordable. 

- Construction Site Inspection and Monitoring

o The use of UA on a construction site can significantly reduce the risk to workers of 

falls while inspecting, surveying, or monitoring site progress. UAS can inspect, 

photograph, and collect data on hard to get to areas that otherwise would require 

worker inspection. Falls are a leading source of workplace fatality and injury on 

construction sites. Reducing falls through UAS use for site imaging could save 

workers lives.

UAS DESCRIPTION

Daniel C. Augspurger intends to use and operate the Yuneec Q500 UAS multirotor aircraft. All 

operations will be predominately flown under 200 feet AGL. Aircraft are pre-programmed to not 

fly within 5 miles of an airport and will have an altitude limit of 400ft AGL.

These aircraft have fail safe features that include, but are not limited to geo fencing and lost link 

return to home/transmitter capability. This has been tested by the company as well as 

personally by turning off the transmitter simulating loss of GPS. The aircraft hovers in place, 

heads toward the transmitter’s last location and will land if GPS signal is not recovered. In 

addition there are low voltage warning lights on the aircraft, and a low voltage warning vibration 

and alert on the personal ground station (controller/transmitter).

YUNEEC Q500 SPECIFICATIONS:

o Max Flight Time 25 Minutes

o Dimension 16.5x16.5x9.5in (420x420x240mm)

o Diagonal Length Without Rotor Blades 22.2in (565mm)

o Propeller/Main Rotor Diameter 13.0in (330mm)

o Takeoff Weight 60oz (1700g)
o Battery 5400mAh 3S 11.1V LiPo 

o Transmitter 10-channel 2.4GHz with 5.8GHz video downlink 

o 3 Flight Modes Smart, Angle and Home Modes 

o Max Flying Height Default 122m (400ft) Above Ground Level

o Max Rotation Rate 65°/s 

o Max Roll Angle 35° 

o Radio Control Frequency Band 2.4GHz 

o Operating Temperature Range -5°C to 80°C

o Max Climb Rate 3m/s

o Max Descent Rate: 2m/s

FCC information:

“This product contains a radio transmitter with wireless technology which has been tested and 

found to be compliant with the applicable regulations governing a radio transmitter in the 

2.400GHz to 2.4835GHz frequency range. 

AIRCRAFT AND EQUIVALENT LEVEL OF SAFETY

Daniel C. Augspurger proposes that the exemption requested herein apply to sUAS that have 

the characteristics and that operate with the limitations listed herein. These limitations provide 

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

structure because the proposed operations represent a safety enhancement to the already safe 

operations conducted with conventional aircraft.

These Operation Limitations/Specifications and conditions to which Daniel C. Augspurger 

agrees to be bound when conducting commercial operations under an FAA issued exemption at 

a minimum include:

1. Operations are limited to the Yuneec Q500, when weighing less than 55 pounds including 

payload. Proposed operations of any other aircraft will require a new petition or a petition 

to amend this exemption.

3. The UA will not be operated at a speed exceeding 87 knots (100 miles per hour). Daniel 

C. Augspurger will use either groundspeed or calibrated airspeed to determine

compliance with the 87 knot speed restriction. In no case will the UA be operated at

airspeeds greater than the maximum UA operating airspeed recommended by the aircraft 

manufacturer.

4. The UA will be operated at an altitude of no more than 400 feet above ground level

(AGL). Altitude will be reported in feet AGL.

5. The UA will be operated within visual line of sight (VLOS) of the PIC at all times.

This requires the PIC to be able to use human vision unaided by any device other than

corrective lenses, as specified on the PIC’s FAA-issued airman medical certificate.
6. All operations will utilize a visual observer (VO). The UA will be operated within the 

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

satisfy the VLOS requirement as long as the PIC always maintains VLOS capability. The 

VO and PIC will be able to communicate verbally at all times; electronic messaging or 

texting is not permitted during flight operations. The PIC will be designated before the 

flight and cannot transfer his or her designation for the duration of the flight. The PIC 

will ensure that the VO can perform the duties required of the VO.

7. All flight crew members, including PIC and VO, will have an understanding of, and 

comply with, Title 14 Code of Federal 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 ATC phraseology and 

communication.

7. All operating documents will be accessible during UA operations and made available to 

the Administrator upon request. Daniel C. Augspurger will track revisions of the operating 

procedures/limitations and present updated and revised documents to the Administrator 

or any law enforcement official upon request. 

8. Any UA that has undergone maintenance or alterations that affect the UA operation or 

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

functional test flight prior to conducting further operations. Functional test flights will 

only be conducted by a PIC with a VO and will remain at least 500 feet from other 

people. The functional test flight will be conducted in such a manner so as to not pose an 

undue hazard to persons and property.

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

condition for safe operation.

10. Prior to each flight, the PIC will conduct a pre-flight inspection and determine the

UA is in a condition for safe flight. The pre-flight inspection will account for all

potential discrepancies, e.g. inoperable components, items, or equipment. If the

inspection reveals a condition that affects the safe operation of the UAS, the aircraft is

prohibited from operating until the necessary maintenance has been performed and the

UA is found to be in a condition for safe flight.

11. Daniel C. Augspurger will follow the UA manufacturer’s maintenance, overhaul,

replacement, inspection, and life limit requirements for the aircraft and aircraft

components. All maintenance will be recorded in a maintenance log and kept with the 

operating documents at all times.

12. Each UA will comply with all manufacturer safety bulletins.
13. A PIC will 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, the District of Colombia, Puerto Rico, a 

territory, a possession, or the Federal government. The PIC will also meet the flight 

review requirements specified in 14 CFR § 61.56 in an aircraft in which the PIC is rated 

on his or her pilot certificate.

14. Daniel C. Augspurger will not permit any PIC to operate unless the PIC demonstrates the

ability to safely operate the UA in a manner consistent with these specifications, 

including evasive and emergency maneuvers and maintaining appropriate distances from 

persons, vessels, vehicles and structures. Prior to commercial operations, the PIC must 

have accumulated and logged, in a manner consistent with 14 CFR Section 61.51(b), a 

minimum of 25 hours of total time as a UAS pilot and at least 5 hours logged as a UAS 

PIC operating the make and model of the UAS to be utilized for operations under this 

requested exemption, and three takeoffs and landings in the preceding 90 days. Flights 

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

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

manner consistent with how the UA will be operated will be conducted during dedicated 

training sessions. During training, proficiency, and experience-building flights, all 

persons not essential for flight operations are considered nonparticipants, and the PIC 

will operate the UA with appropriate distance from nonparticipants in accordance with 14 

CFR § 91.119.

15. UA operations will not be conducted during night, as defined in 14 CFR § 1.1. All

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

not be conducted under special visual flight rules (SVFR).

16. The UA will not operate within 5 nautical miles of an airport reference point (ARP) as

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

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

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

obtained or otherwise permitted by a COA issued to Daniel C. Augspurger. The letter of 

agreement with the airport management will be made available to the Administrator or 

any law enforcement official upon request.

17. An Air Traffic Organization (ATO) issued Certificate of Waiver or Authorization (COA) 

will be obtained prior to conducting any operation planning to occupy any airspace 

between 200ft AGL and 400ft AGL under this requested grant of exemption.

Additionally, Daniel C. Augspurger will request a Notice to Airmen (NOTAM) not more 

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

17. The UA 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.

18. If the UAS loses communications or loses its GPS signal, the UA will return to the 

transmitter/predetermined location within the planned operating area.
19. The PIC will abort the flight in the event of unpredicted obstacles or emergencies.

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

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

intended operation and to operate after that for at least five minutes or with the reserve

power recommended by the manufacturer if greater.

22. All aircraft operated by Daniel C. Augspurger will be identified by serial number, 

registered in accordance with 14 CFR part 47, and have identification (N Number)

markings in accordance with 14 CFR part 45, Subpart C. Markings will be as large as 

practicable.

23. Documents used by Daniel C. Augspurger to ensure the safe operation and flight of the UA

and any documents required under 14 CFR §§ 91.9 and 91.203 will be available to the

PIC at the Ground Control Station of the UAS any time the aircraft is operating. These

documents will be made available to the Administrator or any law enforcement official 

upon request.

24. The UA will remain clear and give way to all manned aviation operations and activities at 

all times.

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

26. All Flight operations will be conducted at least 500 feet from all nonparticipating

persons, vessels, vehicles, and structures unless:

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

from the UAS and/or debris in the event of an accident. Daniel C. Augspurger will

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

arises where nonparticipating persons leave such protection and are within 500 

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

the safety of nonparticipating persons; and,

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

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

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

an undue hazard.

The PIC, VO, operator trainees or essential persons are not considered nonparticipating 

persons under these specifications

27. All operations will be conducted over private or controlled-access property with

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

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

flight to be conducted.
28. Any incident, accident, or flight operation that transgresses the lateral or vertical

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

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

reported to the National Transportation Safety Board.

REGULATIONS FOR WHICH EXEMPTIONS ARE REQUESTED

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

Sections 61.113 (a) & (b) limit private pilots to non-commercial operations. Because the UAS 

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

safety of current operations by requiring the PIC operating the aircraft to have a private pilot’s 

license rather than a commercial pilot’s license to operate this small UAS. Unlike a conventional 

aircraft that carries the pilot and passengers, the UAS is remotely controlled with no living thing 

on board. The area of operation is controlled and restricted, and all flights are planned and 

coordinated in advance. The level of safety provided by the requirements included in the 

Operation Specifications exceeds that provided by a single individual holding a commercial 

pilot’s certificate operating a conventional aircraft. The risks associated with the operation of the 

UAS are so diminished from the level of risk associated with commercial operations 

contemplated by Part 61 when drafted, that allowing operations of the UAS as requested with a 

private pilot as the PIC exceeds the present level of safety achieved by 14 C.F.R. §61.113 (a) & 

(b).

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

The regulation requires that no person may operate a civil aircraft unless it is in airworthy

condition. As there will be no airworthiness certificate issued for the aircraft, should this

exemption be granted, no FAA regulatory standard will exist for determining airworthiness. 

Given the size of the aircraft and the requirements contained in the Operating Specifications for 

maintenance and the use of safety check lists prior to each flight, an equivalent level of safety 

will be provided.

14 C.F.R. § 91.9 (b) (2): Civil Aircraft Flight Manual in the Aircraft.

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. The UAS, given 

its size and configuration has no ability or place to carry such a flight manual on the aircraft, not 

only because there is no pilot on board, but because there is no room or capacity to carry such 

an item on the aircraft. The equivalent level of safety will be maintained by keeping the flight 

manual/specifications at the ground control point where the pilot flying the UAS will have 

immediate access to it. The FAA has issued the following exemptions to this regulation: 

Exemption Nos. 8607, 8737, 8738, 9299, 9299A, 9565, 9565B, 10167, 10167A, 10602, 32827, 

and 10700.
14 C.F.R. § 91.103: Preflight action

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

safety of flight. As FAA approved rotorcraft flight manuals will not be provided for the aircraft an 

exemption will be needed. The PIC will take all actions including reviewing weather, flight 

battery requirements, landing and takeoff distances and aircraft performance data before 

initiation of flight.

14 C.F.R. §91.109: Flight instruction:

Section 91.103 provides that no person may operate a civil aircraft (except a manned

free balloon) that is being used for flight instruction unless that aircraft has fully functioning dual 

controls. UASs and remotely piloted aircraft, by their design do not have fully functional dual

controls. Flight control is accomplished through the use of a control box that communicates with 

the aircraft via radio communications. The 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 & 9862A. The equivalent level of safety will be 

achieved provided by the fact that neither a pilot nor passengers will be carried in the aircraft 

and by the size and speed of the aircraft.

14 C.F.R. §91.119: Minimum safe altitudes

Section 91.119 establishes safe altitudes for operation of civil aircraft. Section 91.119 (d) allows 

helicopters to be operated at less than the minimums prescribed, provided the person operating 

the helicopter complies with any route or altitudes prescribed for helicopters by the FAA. As this 

exemption is for a sUAS that is a helicopter and the exemption requests authority to operate at 

altitudes up to 400 AGL, an exemption may be needed to allow such operations. As set forth 

herein, The UAS will never operate at higher than 400 AGL. It will however be operated in a 

restricted area with security perimeter, where buildings and people will not be exposed to 

operations without their pre-obtained consent. The equivalent level of safety will be achieved 

given the size, weight, and speed of the UAS as well as the location where it is operated. No 

flight will be taken without the required permission of the property owner or local officials. 

Because of the advance notice to the property owner and participants in the aerial activity, all 

affected individuals will be aware of the planned flight operations. Compared to flight operations 

with aircraft or rotorcraft weighting far more than the maximum 55lbs. proposed herein and the 

lack of flammable fuel, any risk associated with these operations is far less than those presently 

presented with conventional aircraft operating at or below 500 AGL other industries. In addition, 

the low-altitude operations of the sUAS will ensure separation between these small UAS

operations and the operations of conventional aircraft that must comply with Section 91.119.

14 C.F.R. §91.121 Altimeter Settings

This regulation 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.” The sUAS will not have a barometric altimeter. 

However, the use of triangulation with a minimum of six satellites in use by its onboard GPS will 

be able to give accurate Height Above Ground Level (HAGL) measurements. Daniel C 

Augspurger believes that an equivalent level of safety can be achieved by the operator as the 

sUAS uses HAGL from its initialization/takeoff point. 

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.

The FAA has previously issued exemptions for fuel requirements in VFR conditions for sUAS 

aircraft. See exemptions 2689F, 5745, 10673, 10808 and 11138.

Daniel C. Augspurger believes an equivalent or higher level of safety can be obtained by 

terminating the flight prior to the following:

-Yuneec Typhoon Q500—25 minutes or 25% of battery life, whichever occurs first. The UAS 

has a second level of safety that is achieved through the use of an aircraft battery monitoring 

system. The aircraft system will alert the operator of low battery voltage through a vibration in 

the control station.

Daniel C. Augspurger will not operate at night in accordance with 14 CFR 1.1.

An equivalent level of safety will be achieved because these sUAS are limited in size, scope of 

operations, and shall only fly above approved privately owned and operated property at or 

below 400 feet HAGL, and does not bear the same risks associated with large manned aircraft 

and therefore should be exempt from this section’s requirements.

14 C.F.R. §91.203 (a) and (b): Carrying Civil Aircraft Certification and Registration

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 UAS fully loaded 

weighs no more than 55 lbs and is operated without an onboard pilot. As such, there is no ability 

or place to carry certification and registration documents or to display them on the sUAS.

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

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

applicable to the sUAS. The FAA has issued numerous exemptions to this regulation. A 

representative sample of other exceptions includes Exemption Nos. 9565, 9665, 9789, 9789A, 

9797, 9797A, 9816A, and 10700.

14 C.F.R. §91.405 (a); 407 (a) (1); 409 (a) (2); 417(a) & (b): Maintenance Inspections

These regulations require that an aircraft operator or owner “shall have that aircraft

inspected as prescribed in subpart E of this part and shall between required inspections, except 

as provided in paragraph (c) of this section, have discrepancies repaired as prescribed in part 

43 of this chapter...,” and others shall inspect or maintain the aircraft in compliance with Part 43.

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

these sections will not apply to the applicant. An equivalent level of safety will be achieved 

because these small UASs are very limited in size and will carry a small payload and operate 

only in restricted areas for limited periods of time. If mechanical issues arise the UAS can land 

immediately and will be operating from no higher than 400 feet AGL, with the vast majority of 

operations under 200 feet. As provided in this document and the Flight Manual, the operator 

will ensure that the UAS is in working order prior to initiating flight, perform required 
maintenance, and keep a log of any maintenance performed. Moreover, the operator is the 

person most familiar with the aircraft and best suited to maintain the aircraft in an airworthy 

condition to provide the equivalent level of safety.

SUMMARY

*********

Pursuant to 14 C.F.R. Part 11, the following summary is provided for publication in the

Federal Register, should it be determined that publication is needed:

Applicant seeks an exemption from the following rules:

14 C.F.R. §21, subpart H; 14 C.F.R. §§ 61.113( a) & (b);91.7 (a); 91.9 (b) (2); 91.103(b); 

91.109; 91.119; 91.121; 91.151(a);91.203(a) and (b); 91.405 (a); 91.407 (a) (1); 91.409 (a) (2); 

and 91.417 (a) & (b) to operate commercially a small unmanned vehicle (less than 4lbs).

Approval of exemptions allowing commercial operations of sUASs, will enhance safety by 

reducing risk. Conventional operations, using jet or piston power aircraft, operate at extremely 

low altitudes just feet from the subjects being filmed and in extreme proximity to people and 

structures and present the risks associated with vehicles that weigh in the neighborhood of 

4,000lbs, carrying large amounts of jet A or other fuel. Such aircraft must fly to and from the 

operational location. In contrast, a sUAS weighing fewer than 55 lbs. and powered by batteries 

eliminates virtually all of that risk given the reduced mass and lack of combustible fuel carried 

on board. The sUAS is carried to the operation site and not flown. The sUAS will carry no 

passengers or crew and, therefore, will not expose them to the risks associated with manned 

aircraft flights.

The operation of small UASs, weighing less than 55 lbs., conducted in the strict conditions 

outlined above, will provide an equivalent level of safety supporting the grant of the exemptions 

requested herein, including exempting the applicant from the requirements of Part 21 and 

allowing commercial operations. These lightweight aircraft operate at slow speeds, close to the 

ground, and in a sterile environment and, as a result, are far safer than conventional operations 

conducted with turbine helicopters operating in close proximity to the ground and people.

Privacy

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

consent and knowledge. The grant of this exemption request will provide improved safety in day 

VFR operations. Satisfaction of the criteria provided in Section 333 of the Reform Act of 2012- -

size, weight, speed, operating capabilities, proximity to airports and populated areas and 

operation within visual line of sight and national security – provide more than adequate 

justification for the grant of the requested exemptions allowing commercial operation of the 

applicant’s UAS.

Sincerely,

Daniel C. Augspurger 

319.333.9414 daugs4@gmail.com