June 8, 2015

Exemption No. 11774

Regulatory Docket No. FAA–2015–0870

Mr. Joshua Furnald

Ramaker & Associates, Inc.

1120 Dallas Street

Sauk City, WI 53583

Dear Mr. Furnald:

This letter is to inform you that we have granted your request for exemption. It transmits our 

decision, explains its basis, and gives you the conditions and limitations of the exemption, 

including the date it ends.

By letter dated March 25, 2015, you petitioned the Federal Aviation Administration (FAA) on 

behalf of Ramaker & Associates, Inc. (hereinafter petitioner or operator) for an exemption. 

The petitioner requested to operate an unmanned aircraft system (UAS) to conduct aerial 

photography, mapping, surveying, videography, and inspections.

See Appendix A for the petition submitted to the FAA describing the proposed operations and 

the regulations that the petitioner seeks an exemption.

The FAA has determined that good cause exists for not publishing a summary of the petition 

in the Federal Register because the requested exemption would not set a precedent, and any 

delay in acting on this petition would be detrimental to the petitioner.

Airworthiness Certification

The UAS proposed by the petitioner are the DJI Phantom 2 Vision+, DJI Inspire 1, 

Draganflyer X4-P, and Draganflyer X4ES.

The petitioner requested relief from 14 CFR part 21, Certification procedures for products 

and parts, Subpart H—Airworthiness Certificates. In accordance with the statutory criteria 

provided in Section 333 of Public Law 112−95 in reference to 49 U.S.C. § 44704, and in 
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consideration of the size, weight, speed, and limited operating area associated with the 

aircraft and its operation, the Secretary of Transportation has determined that this aircraft 

meets the conditions of Section 333. Therefore, the FAA finds that the requested relief from 

14 CFR part 21, Certification procedures for products and parts, Subpart H—Airworthiness 

Certificates, and any associated noise certification and testing requirements of part 36, is 

not necessary.

The Basis for Our Decision

You have requested to use a UAS for aerial data collection1. The FAA has issued grants of 

exemption in circumstances similar in all material respects to those presented in your petition. 

In Grants of Exemption Nos. 11062 to Astraeus Aerial (see Docket No. FAA−2014−0352), 

11109 to Clayco, Inc. (see Docket No. FAA−2014−0507), 11112 to VDOS Global, LLC (see

Docket No. FAA−2014−0382), and 11213 to Aeryon Labs, Inc. (see Docket No. 

FAA−2014−0642), the FAA found that the enhanced safety achieved using an unmanned 

aircraft (UA) with the specifications described by the petitioner and carrying no passengers or 

crew, rather than a manned aircraft of significantly greater proportions, carrying crew in 

addition to flammable fuel, gives the FAA good cause to find that the UAS operation enabled 

by this exemption is in the public interest.

Having reviewed your reasons for requesting an exemption, I find that—

• They are similar in all material respects to relief previously requested in Grant of 

Exemption Nos. 11062, 11109, 11112, and 11213;

• The reasons stated by the FAA for granting Exemption Nos. 11062, 11109, 11112, and 

11213 also apply to the situation you present; and 

• A grant of exemption is in the public interest.

Our Decision

In consideration of the foregoing, I find that a grant of exemption is in the public interest. 

Therefore, pursuant to the authority contained in 49 U.S.C. 106(f), 40113, and 44701, 

delegated to me by the Administrator, Ramaker & Associates, Inc. is granted an exemption 

from 14 CFR §§ 61.23(a) and (c), 61.101(e)(4) and (5), 61.113(a), 61.315(a), 91.7(a), 

91.119(c), 91.121, 91.151(a)(1), 91.405(a), 91.407(a)(1), 91.409(a)(1) and (2), and 91.417(a) 

and (b), to the extent necessary to allow the petitioner to operate a UAS to perform aerial data 

collection. This exemption is subject to the conditions and limitations listed below.

 

1 Aerial data collection includes any remote sensing and measuring by an instrument(s) aboard the UA. 

Examples include imagery (photography, video, infrared, etc.), electronic measurement (precision surveying, RF 

analysis, etc.), chemical measurement (particulate measurement, etc.), or any other gathering of data by 

instruments aboard the UA.
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Conditions and Limitations

In this grant of exemption, Ramaker & Associates, Inc. is hereafter referred to as the operator.

Failure to comply with any of the conditions and limitations of this grant of exemption will be 

grounds for the immediate suspension or rescission of this exemption.

1. Operations authorized by this grant of exemption are limited to the DJI Phantom 2 

Vision+, DJI Inspire 1, Draganflyer X4-P, and Draganflyer X4ES 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.

2. Operations for the purpose of closed-set motion picture and television filming are 

not permitted. 

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

exemption holder may 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 must be operated at an altitude of no more than 400 feet above ground level 

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

5. The UA must 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 or 

U.S. driver’s license.

6. All operations must utilize a visual observer (VO). The UA must be operated within 

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

to satisfy the VLOS requirement as long as the PIC always maintains VLOS 

capability. The VO and PIC must be able to communicate verbally at all times; 

electronic messaging or texting is not permitted during flight operations. The PIC 

must be designated before the flight and cannot transfer his or her designation for the 

duration of the flight. The PIC must ensure that the VO can perform the duties 

required of the VO.

7. This exemption and all documents needed to operate the UAS and conduct its 

operations in accordance with the conditions and limitations stated in this grant of 

exemption, are hereinafter referred to as the operating documents. The operating 

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

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

limitations in this exemption and the procedures outlined in the operating documents, 
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the conditions and limitations herein take precedence and must be followed. 

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

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

operator’s responsibility to track such revisions and present updated and revised 

documents to the Administrator or any law enforcement official upon request. The 

operator must also present updated and revised documents if it petitions for extension 

or amendment to this grant of exemption. If the operator determines that any update 

or revision would affect the basis upon which the FAA granted this exemption, then 

the operator must petition for an amendment to its grant of exemption. The FAA’s 

UAS Integration Office (AFS−80) may be contacted if questions arise regarding 

updates or revisions to the operating documents.

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

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

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

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

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

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

9. The operator is responsible for maintaining and inspecting the UAS to ensure that it is 

in a condition for safe operation.

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

UAS is in a condition for safe flight. The pre-flight inspection must account for all 

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

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

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

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

11. The operator must follow the UAS manufacturer’s maintenance, overhaul, 

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

aircraft components.

12. Each UAS operated under this exemption must comply with all manufacturer 

safety bulletins.

13. Under this grant of exemption, a PIC must hold either an airline transport, 

commercial, private, recreational, or sport pilot certificate. The PIC must also hold a 

current FAA airman medical certificate or a valid U.S. driver’s license issued by a 

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

government. The PIC must also meet the flight review requirements specified in 

14 CFR § 61.56 in an aircraft in which the PIC is rated on his or her pilot certificate.
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14. The operator may not permit any PIC to operate unless the PIC demonstrates the 

ability to safely operate the UAS in a manner consistent with how the UAS will be 

operated under this exemption, including evasive and emergency maneuvers and 

maintaining appropriate distances from persons, vessels, vehicles and structures. PIC 

qualification flight hours and currency must be logged in a manner consistent with 

14 CFR § 61.51(b). Flights for the purposes of training the operator’s PICs and VOs 

(training, proficiency, and experience-building) and determining the PIC’s ability to 

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

under this exemption are permitted under the terms of this exemption. However, 

training operations may only 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 must operate the UA 

with appropriate distance from nonparticipants in accordance with 14 CFR § 91.119.

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

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

under special visual flight rules (SVFR) are not authorized.

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

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

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

FAA-published aeronautical chart, unless a letter of agreement with that airport’s 

management is obtained or otherwise permitted by a COA issued to the exemption 

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

to the Administrator or any law enforcement official upon request.

17. The UA may not be operated less than 500 feet below or less than 2,000 feet 

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

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

pre-determined location within the private or controlled-access property.

19. The PIC must 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 UA 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.

21. Air Traffic Organization (ATO) Certificate of Waiver or Authorization (COA). All 

operations shall be conducted in accordance with an ATO-issued COA. The 

exemption holder may apply for a new or amended COA if it intends to conduct 

operations that cannot be conducted under the terms of the attached COA.
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22. All aircraft operated in accordance with this exemption must be identified by serial 

number, registered in accordance with 14 CFR part 47, and have identification 

(N−Number) markings in accordance with 14 CFR part 45, Subpart C. Markings must 

be as large as practicable.

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

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

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

These documents must be made available to the Administrator or any law enforcement 

official upon request.

24. The UA must remain clear and give way to all manned aviation operations and 

activities at all times. 

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

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

persons, vessels, vehicles, and structures unless:

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

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

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

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

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

of nonparticipating persons; and

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

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

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

present an undue hazard.

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

nonparticipating persons under this exemption.

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

permission from the property owner/controller or authorized representative. 

Permission from property owner/controller or authorized representative will be 

obtained for each flight to be conducted.

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

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

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

reported to the National Transportation Safety Board (NTSB) per instructions 

contained on the NTSB Web site: www.ntsb.gov.
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If this exemption permits operations for the purpose of closed-set motion picture and 

television filming and production, the following additional conditions and limitations apply.

29. The operator must have a motion picture and television operations manual (MPTOM) 

as documented in this grant of exemption.

30. At least 3 days before aerial filming, the operator of the UAS affected by this 

exemption must submit a written Plan of Activities to the local Flight Standards 

District Office (FSDO) with jurisdiction over the area of proposed filming. The 3-day 

notification may be waived with the concurrence of the FSDO. The plan of activities 

must include at least the following:

a. Dates and times for all flights;

b. Name and phone number of the operator for the UAS aerial filming conducted 

under this grant of exemption;

c. Name and phone number of the person responsible for the on-scene operation of 

the UAS;

d. Make, model, and serial or N−Number of UAS to be used;

e. Name and certificate number of UAS PICs involved in the aerial filming;

f. A statement that the operator has obtained permission from property owners 

and/or local officials to conduct the filming production event; the list of those 

who gave permission must be made available to the inspector upon request;

g. Signature of exemption holder or representative; and

h. A description of the flight activity, including maps or diagrams of any area, city, 

town, county, and/or state over which filming will be conducted and the altitudes 

essential to accomplish the operation.

31. Flight operations may be conducted closer than 500 feet from participating persons 

consenting to be involved and necessary for the filming production, as specified in the 

exemption holder’s MPTOM.

Unless otherwise specified in this grant of exemption, the UAS, the UAS PIC, and the UAS 

operations must comply with all applicable parts of 14 CFR including, but not limited to, 

parts 45, 47, 61, and 91.
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This exemption terminates on June 30, 2017, unless sooner superseded or rescinded.

Sincerely,

/s/

John S. Duncan

Director, Flight Standards Service

Enclosures
Table of Contents 

APPLICATION FOR CERTIFICATE OF AUTHORIZATION 

I. The Unmanned Aircraft ("UA V"): ......................................................................................... i 

A. UAV Model #1 ..................................................................................................................... i 

B. UA V Model #2 .................................................................................................................... ii 

c. UAV Model #3 ................................................................................................................... iii 

D. UA V MODEL #4 ................................................................................................................ iv 

II. Proposed Commercial Uses of U A V s .................................................................................. iv 

III. Safety is Increased and Danger Reduced by the Proposed UAV Usage ............................... v 

IV. The Applicant will Follow Restrictions Dictated by N 8900.227 ........................................ vi 

v. Application Summary ........................................................................................................... vi 

ADDENDUM 

I. Introduction to Petitioner ....................................................................................................... 1 

II. Relevant Authority Related to Petitioner's Certificate of Authorization .............................. 1 

III. Qualification for Approval Under Section 333 of the Reform Act ....................................... 2 

A. The Petitioner's Proposed Usage Does not Create a Hazard to Users of the NAS or the 

Public Because of the Reduced Size, Weight, Speed and Operational Capability of the U A V. 2 

B. The Petitioner's Proposed Usage Does not Create a Hazard to Users of the NAS or the 

Public because the Operation of the UA V will be conducted in Controlled or Sterile Locations, 

Away from Airports and in Unpopulated Areas ......................................................................... 3 

C. The Petitioner's Proposed Usage Does not Create a Hazard to Users of the NAS or the 

Public because Operation of UAVs will be conducted within VLOS of the PIC or 

VO at all Times ....................................................................................................................... 3 

D. The UAV will remain below 400 AGL at all times during the operation ........................... 4 

IV. Regulations From Which Exemption Is Requested ............................................................... 4 

A. 14 C.F.R. Part 21, Subpart H- Airworthiness Certificates and 14 C.F.R. §91.203(a)(l) ... 5 

B. 14 C.F.R. Part 27: Airworthiness Standards: Normal Category Rotorcraft. ....................... 6 

C. Aircraft Marking and Identification Requirements: 14 C.F.R. §§ 91.9(c), 45.23(b) and 

45.27(a) ....................................................................................................................................... 6 

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

Command .................................................................................................................................... 7 

E. 14 C.F.R. § 91.9(B)(2): Civil Aircraft Flight Manual in the Aircraft. ................................ 9 
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F. 14 C.F.R. § 91.7(a): Civil Aircraft Airworthiness .............................................................. 9 

G. 14 C.F.R. § 91.103: Preflight Action ................................................................................ 10 

H. 14 C.F.R. § 91.109(a): Flight Instruction .......................................................................... 10 

I. 14 C.F.R. § 91.119: Minimum Safe Altitudes .................................................................. 11 

J. 14 C.F.R. § 91.121: Altimeter Settings ............................................................................. 12 

K. 14 C.F.R. § 91.151(a): Fuel Requirements for Flight in VFR Conditions ........................ 12 

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

M. 14 C.F.R. §§ 91.405(a)(l); 91.407(a)(l); 91.409(a)(l); 91.417(a) and (b): 

Maintenance Inspections .......................................................................................................... 14 

V. Public Interest ....................................................................................................................... 15 

VI. Privacy .................................................................................................................................. 16 

VII. Federal Register Summary .................................................................................................. 16 

VIII. Conclusion ........................................................................................................................... 17 

Exhibits 1-4 also attached 
March 25, 2015 

U.S. Dept. of Transportation, Docket Operations 

West Building Ground Floor, Room w12-140 

1200 New Jersey Avenue, SE. 

Washington, DC 20590 

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

Aviation Regulations 

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, Ramaker & Associates, Inc. ("Ramaker") seeks an exemption from 

Federal Aviation Regulations ("FARs") detailed below for the following described Unmanned 

Aerial System, which includes an Unmanned Aircraft (UA V) and ground station-based 

equipment and crew: 

I. THE UNMANNED AIRCRAFT ("UA V"): 

A. UA V Model #1 

• A lightweight (3.5 lb. gross weight with all on-board equipment), battery 

operated 4-motor rotorcraft in the form of a quadcopter that takes off and 

lands vertically. Manufactured by DJI, Model - Phantom 2 Vision+ 

SEE ATTACHED HERETO: Phantom2 Vision+, Pilot Training Guide, Quick Start 

Guide, Release Notes, User Manual, Battery Safety Guidelines ("Exhibit 1") 

THEUAV 

• An on-board flight computer with GPS navigation and location ability that 

receives signals for flight controls from a ground-based transmitter/controller; 

• An on-board camera capable of capturing imagery in the form of full color, high 

definition still photos and video; 

• An on-board telemetry system that delivers flight data from the on-board flight 

computer to the on-board radio transmitter including altitude AGL, horizontal 

and vertical speed, compass direction of flight and direction back to its launch 

site; 

• Various safety systems including return to launch point in case of 

communication or mechanical failure. 
THE GROUND STATION BASED PART OF THE SYSTEM 

• A Pilot in Command (PIC) in operational control of a flight operation from 

beginning to end and who controls the UAV while in the air; 

• A Handheld 100 mW, 5.8 GHZ radio transmitter/controller operated by the PIC 

to control the UAV while in flight; 

• A 20 dBm Range Extender operating at 2.4 MHz. 

• A Visual Observer (VO) is a person who provides a second pair of eyes to 

visually track the UA V while in flight. 

B. UA V MODEL #2 

• A lightweight UAV (7.5 lb. gross weight with all on-board equipment), 

battery operated 4-motor rotorcraft in the form of a quadcopter that takes off 

and lands vertically. Manufactured by DJI, Model- Inspire 1 

SEE ATTACHED HERETO FOR DETAILS: Inspire 1 - Maintenance Manual, Quick Start 

Guide, Safety Guidelines, User Manual with Features, Intelligent Flight Battery Safety 

Guidelines ("Exhibit 2") 

THE UAV SUMMARY 

• An on-board flight computer with GPS navigation and location ability that 

receives signals for flight controls from a ground-based transmitter/controller; 

• An on-board camera capable of capturing imagery in the form of full color, high 

definition still photos and video; 

• An on-board telemetry system that delivers flight data from the on-board flight 

computer to the on-board radio transmitter including altitude AGL, horizontal 

and vertical speed, compass direction of flight and direction back to its launch 

site; 

• Various safety systems including return to launch point in case of 

communication or mechanical failure. 

SUMMARY OF THE GROUND STATION BASED PART OF THE SYSTEM 

• A Pilot in Command (PIC) in operational control of a flight operation from 

beginning to end and who controls the UAV while in the air; 

• A 100mW, 2.4GHz radio transmitter/controller operated by the PIC to control 

the UAV while in flight; 

• A 20 dBm Ranger Extender operating at 2412MHZ- 2462 MHZ 

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• A radio receiver receiving live video and flight data from the on-board camera 

and computer projects it all together onto a screen for the PIC to view during 

flight; 

• A Visual Observer (VO) is a person who provides a second pair of eyes to 

visually track the UA V while in flight. 

C. UA V MODEL #3 

• A lightweight UAV (5.5 lb. gross weight with all on-board equipment), 

battery operated 4-motor rotorcraft in the form of a quadcopter that takes off 

and lands vertically. Manufactured by Draganflyer, Model- X4-P 

SEE ATTACHED HERETO FOR DETAILS: X4-P User Manual ("Exhibit 3") 

THE UA V SUMMARY 

• An on-board flight computer with GPS navigation and location ability that 

receives signals for flight controls from a ground-based transmitter/controller; 

• An on-board camera capable of capturing imagery in the form of full color, high 

definition still photos and video; 

• An on-board telemetry system that delivers flight data from the on-board flight 

computer to the on-board radio transmitter including altitude AGL, horizontal 

and vertical speed, compass direction of flight and direction back to its launch 

site; 

• Various safety systems including return to launch point in case of 

communication or mechanical failure. 

SUMMARY OF THE GROUND STATION BASED PART OF THE SYSTEM 

• A Pilot in Command (PIC) in operational control of a flight operation from 

beginning to end and who controls the UAV while in the air; 

• A lOOmW, 2.4GHz radio transmitter/controller operated by the PIC to control 

the UAV while in flight; 

• A radio receiver receiving live video and flight data from the on-board camera 

and computer projects it all together onto a screen for the PIC to view during 

flight; 

• A Visual Observer (VO) is a person who provides a second pair of eyes to 

visually track the UA V while in flight. 

• Data Link Type: 2.4 GHz two way 

• Data Transmission Power: 50 m W (18 dBm) 

• Video Link Type: 5.8 GHz two way 

• Video Transmission Power - 19 dBm 

111 
D. UAVMODEL#4 

• A lightweight UA V (6.0 lb. gross weight with all on-board equipment), 

battery operated 4-motor rotorcraft in the form of a quadcopter that takes off 

and lands vertically. Manufactured by Draganflyer, Model- X4ES 

See attached hereto for details: User Manual ("Exhibit 4") 

THE UA V SUMMARY 

• An on-board flight computer with GPS navigation and location ability that 

receives signals for flight controls from a ground-based transmitter/controller; 

• An on-board camera capable of capturing imagery in the form of full color, high 

definition still photos and video; 

• · An on-board telemetry system that delivers flight data from the on-board flight 

computer to the on-board radio transmitter including altitude AGL, horizontal 

and vertical speed, compass direction of flight and direction back to its launch 

site; 

• Various safety systems including return to launch point in case of 

communication or mechanical failure. 

• Advanced Flight Data Control- recorded to Gb mirco SD card on UAV 

SUMMARY OF THE GROUND STATION BASED PART OF THE SYSTEM 

• A Pilot in Command (PIC) in operational control of a flight operation from 

beginning to end and who controls the UAV while in the air; 

• Data Link Type: 2.4 GHz two way 

• Data Transmission Power: 50 mW (18 dBm) 

• Video Link Type: 5.8 GHz two way 

• Video Transmission Power - 19 dBm 

• Flight Data Controller - saved to internal memory 

• A Visual Observer (VO) is a person who provides a second pair of eyes to 

visually track the UA V while in flight. 

II. PROPOSED COMMERCIAL USE OF UA V 

The requested exemption would support an application for a commercial Certificate of 

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Authorization to use the above described UAV to support the following: 

• Aerial inspection of cellular, television or radio towers and related equipment affixed to 

the towers ("Communication Facilities") 

• Aerial mapping of uninhabited parcels of land exceeding two acres 

• Aerial surveying and inspection of large-scale, commercial construction projects 

• Aerial Videography of real estate 

• Aerial inspection of commercial structures 

Ill. SAFETY IS INCREASED AND DANGER REDUCED BY THE PROPOSED UA V USAGE 

The UAVs are safer than full-scale aircraft because UAVs are powered by batteries, are smaller, 

lighter and more maneuverable than larger aircraft running on combustible fuel. Additionally, 

UAVs operate at lower altitudes with no people on board and will thereby reduce current risk 

levels and enhance safety and diminish the likelihood of death or serious bodily injury. With a 

small payload, flights below 400 feet AGL, and a maximum flight time of only 45 minutes, 

U A V s offer little or no risk to national security, the public, air safety or communication. 

The proposed UAV use to inspect Communication Facilities will reduce hazards to persons in general. 

For instance, individuals who currently conduct Communication Facility inspections by physically 

climbing, inspecting and photographing Communication Facilities is thought to be the most dangerous 

occupation in America. Thirteen climbers died working on Communication Facilities in 2013. All but 

two of the accidents were on cell or cell-related sites. 1 According to OSHA, tower climbing was the 

most dangerous job in America in 2006.2 More fatalities occurred in 2013 than the previous two years 

combined. Similarly, the petitioner has agreed to refrain from piloting the UA V over non-participants 

of the commercial activity or in populated areas. 3 

The UA V' s are effective and preferable tools for the type of photography proposed by Petitioner. 

Low level, aerial, oblique photos and video from several angles are far more effective than 

ground-based imagery for displaying the characteristics of large, complex properties, commercial 

properties, construction sites and land parcels. Companies in the past have chartered 2-seat fullsized helicopters or small piloted aircraft for this purpose, which has proven to be both costly 

1 Probulica, Feds to Look Harder at Cell Carriers When Tower Climbers Die, http://www.propublica.org/article/fedsto-look -harder-at-cell-carriers-when-tower -climbers-die, accessed March 15, 2015. 2 United States Department of Labor- Occupational Safety & Health Administration 

("OSHA"),https://www .osha.gov/pls/oshaweb/owadisp.show _document?p_table=SPEECHES&p_id= 1267, accessed 

March 15, 2015. 

3 OSHA, https://www.osha.gov/doc/topics/communicationtower/index.html, accessed March 15, 2015. 

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and dangerous. The benefits of reduced cost and improved quality of presentation and safety 

from the UA V will be valuable to and benefit the Petitioner and the public. 

Additionally, we request that we be allowed to use our system to benefit first responders nearby 

when practicable who might require assistance, including fire fighters, the police, the sheriff, et 

al., while remaining subject to all limitations cited in this application as we do so. 

IV. THE APPLICANT WILL FOLLOW RESTRICTIONS DICTATED BY N 8900.227 

The UA V will be operated with both a PIC and aVO in accordance with FAA Policy N 

8900.227 "Operational Requirements for UAV" and with the following Restrictions: 

(a) No flight shall be made with a UAV Gross weight exceeding 50 pounds; 

(b) All operations shall occur in FAA Class G airspace at no more than 400 feet AGL, at an 

airspeed of no more than 25 knots and no further than 3/4 Nautical Miles (NM) from the 

PIC; 

(c) All operations shall utilize a visual observer (VO). The VO and PIC must be able to 

communicate by voice at all times during a flight operation; 

(d) Flights over private property shall obtain the permission of the property owner prior to 

commencement of site inspection, videography etc. 

(e) The PICs must have a private pilot's license or a commercial pilot's license, and at 

minimum, a Class III medical certificate. PICs must have accumulated and logged, in a 

manner consistent with 14 CFR §61.51 (b), a minimum of 100 flight cycles and 25 hours 

of total time as a UA V rotorcraft pilot and at least ten hours logged as a UA V pilot with a 

similar UA V type; 

(f) All required permits will be obtained from state and local government prior to operation; 

(g) The UAV will not be operated over densely populated areas or at air shows; 

(h) The UAV shall be observable by the PIC or VO at all times without any visual aids other 

than prescription glasses or contact lenses 

(i) The UA V will not be operated over any open-air assembly of people; 

(j) The UAV will not be operated over heavily trafficked roads; 

(k) The UAV will be operated below 200 feet AGL when 5 nautical miles or less from an 

airport or heliport; 

(m) Operations will be restricted to day only and weather conditions equivalent to VFR; 

(n) The PIC will brief the VO and property owner about the operation and risk before the first 

flight at each new location; 

(o) No flight may be made without a Pre-Flight Inspection by the PIC before each 

operation to ascertain that the UAV is in a condition safe for flight. 

V. APPLICATION SUMMARY 

Vl 
The PIC and VO will meet the requirements outlined in FAA PolicyN 8900.227 §16 Personnel 

Qualifications. Additionally, the PIC and VO will perform maintenance on the system and will 

complete a course of maintenance instruction as part of their initial training. 

Petitioner submits that the combination of the UA V's light weight, flight performance and ability, 

fully qualified flight crew and strict operation under the guidelines established inN 8900.227, 

and under all of the Restrictions (a) through (o) listed above, the FAA can have full confidence 

that the operation will have an equivalent or greater level of safety than manned aircraft 

performing the same mission. 

The name and contact information of the applicant: 

Ramaker & Associates, Inc. 

1120 Dallas Street 

Sauk City, WI 53583 

(608) 643-4100 

www.Ramaker.com 

The regulations from which the exemption is requested are listed below. Beside each regulation 

number is the page of the attached Addendum upon which each may be found together with our 

proposed equivalent level of safety for each regulation: 

- 14 CFR Part 21 ...................................................................... Addendum Page 4 

- 14 CFR 91.203 .................................................................................. Addendum Page 12 

- 14 CFR 45.23, 45.27 ................................................................ Addendum Page 6 

- 14 CFR 91.9 ....................................................................................... Addendum Page 8 

- 14 CFR 61.113 .................................................................................... Addendum Page 7 

- 14 CFR 91.109, 91.119, ................................................................. Addendum Page 10 

-14CFR91.121 ...................................................................... AddendumPage 11 

- 14 CFR 91.151 ................................................................................... Addendum Page 11 

- 14 CFR Subpart E (91.401- 91.417) ............................................... Addendum Page 13 

-FAA Policy 8900.227 Paragraph 16(c)(4) and Paragraph 16(e)(l) .... See Above, Section IV 

This COA follows all precedent established by the FAA and breaks no new legal ground. This 

COA is in accordance with protocols outlined in this petition for exemption, the enclosed 

manuals for respective UAVs ("Aircraft Operations Manual"), and any other requirements 

established by the FAA pursuant to Section 333 of the Reform Act. 

The Petitioner is prepared to modify or amend any part of this request to satisfy the need for an 

equivalent level of safety. Please contact us at any time if you require additional information or 

clarification. We look forward to working with your office. 

Vll 
i 

l 

l 

~ 

Sincerely, 

Joshua Furnald, Esq. 

In-House Counsel for Ramaker & Associates, Inc. 

viii 
Addendum 

Ramaker & Associates, Inc. requests an exemption from the aforementioned 

regulations as well as any additional regulations that may technically apply to the 

operation of the VA V. 

I. INTRODUCTION TO PETITIONER 

Ramaker and Associates, Inc. ("Ramaker") is an engineering and consulting firm 

based in Sauk City, Wisconsin. Ramaker is an employee owned entity with more than 

20 years of experience successfully designing, monitoring and completing complex 

engineering projects in all of the United States. Ramaker's primary focus is on aquatic 

design, architecture, civil, environmental, MEP, surveying, technology and 

telecommunications. 

II. RELEVANT AUTHORITY RELATED TO PETITIONER'S CERTIFICATE OF 

AUTHORIZATION 

This petition for exemption is submitted to advance Congress' goal of 

integrating UAV safely into the National Airspace System ("NAS"). In the Reform 

Act, Congress directed the FAA "to safely accelerate the integration of civil 

unmanned aircraft systems in the national airspace system," and, under Section 333 of 

that law, directed the Secretary of Transportation ("FAA Administrator") to 

consider whether certain unmanned aircraft systems may operate safely in the NAS 

before completion of the rule making required under Section 332 of the Reform Act.4 

In making this determination, the FAA Administrator is required to determine 

which types of UAV 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 VA V size, weight, speed, and operational capability; 

• Operation of the VA V in close proximity to airports and populated areas; 

and 

• Operation of the VA V within visual line-of-sight of the operator. 5 

4 Reform Act, Supra Note 1 

5 !d. at§ 333(b)(l). 

1 
If 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."6 

The FAA Administrator has general authority to grant exemptions from 

FAA safety regulations and minimum standards when the Administrator decides a 

requested exemption is in the public interest.7 A party requesting an exemption must 

explain the reasons why the exemption: (1) would benefit the public as a whole and; (2) 

would not adversely affect safety or how it would provide a level of safety at least 

equal to the existing rules.8 Therefore, the Petitioner will demonstrate how the 

proposed UA V infrastructure inspection will benefit the public and that the proposed 

operation will not adversely affect safety of the public and to those operating in the 

NAS. 

III. QUALIFICATION FOR APPROVAL UNDER SECTION 333 OF THE REFORM 

ACT 

A. The Petitioner's Proposed Usage Does not Create a Hazard to Users 

of the NAS or the Public Because of the Reduced Size, Weight, Speed and 

Operational Capability of the UAV. 

The proposed operations in this petition for exemption qualify for expedited 

approval under Section 333 of the Reform Act. Each of the statutory criteria and other 

potentially relevant factors are satisfied. 

The proposed operations would permit use of small and relatively inexpensive 

UAVs under controlled conditions in airspace that is: (1) limited; (2) predetermined; 

(3) controlled as to access, and; (4) would pose an increased level of safety beyond 

what exists when the proposed services are completed by manned, full size 

aircraft or physical accessing and/or climbing the Communication Facilities, 

construction sites or buildings. 

6 !d. § 333(c)(emphasis added). 7 See 49 U.S.C. § 44701 (f) (authorizing the grant of exemptions from a requirement of regulations 

prescribed purUAnt to section 44701 (a)- (b) and sections 44702-44716). 8 See 14 C.F.R. § 11.81; FAA, Petition for Exemptions 

2 
Petitioner's UAVs weigh less than 50 pounds (including payload). Petitioner's 

UAV's operate at a speed of no more than 25 knots and have the capability to hover 

and move in vertical and horizontal planes simultaneously. 

Such operations will insure that the UAV will "not create a hazard to users of 

the National Airspace System or the public" given the small size of the UAV involved 

and the restricted environment within which it will operate. This petition for 

exemption falls squarely within that zone of safety in which Congress envisioned that 

the FAA must, by exemption, allow commercial operations of U A V to commence 

immediately. 

B. The Petitioner's Proposed Usage Does not Create a Hazard to Users 

of the NAS or the Public because the Operation of the UA V will be 

conducted in Controlled or Sterile Locations, A way from Airports and in 

Unpopulated Areas. 

The Petitioner's proposed usage does not create a hazard to users of the NAS or 

the public because the UAV's shall be flown on Private Property after permission is 

secured from the Landlord or Agent. All concerned parties will be given notice prior 

to the operations. Additionally, Petitioner envisions UAV operations be limited to 

Aerial inspection of Communication facilities, large-scale, commercial construction 

projects and commercial structures. 

C. The Petitioner's Proposed Usage Does not Create a Hazard to Users 

of the NAS or the Public because Operation of UAVs will be 

conducted within VLOS of the PIC or VO at all Times 

Petitioner's UAV will operate in line-of-sight and only in an area described 

here and in Exhibits 1, 2, and 3. Petitioner shall not utilize visual aids other than 

prescribed glasses or contact lenses. Petitioner shall always: 

• Determine the UAV's proximity to all aviation activities (and other hazards) 

and 

• Exercise effective control of the UAV and 

• Comply with§§ 91.111, 91.113., 91.115, and 

• Prevent the UAV's from creating a collision hazard and 

• VO will inform the PIC when losing sufficient visual contact with the UAV. 

3 
D. The UAV will remain below 400 AGL at all times during the 

operation. 

The Petitioner's UAV will not fly above 400 AGL at any time. The 

Petitioner will launch, operate and recover the UAV from the ground level. 

Petitioner will not launch, operate or recover the UAV from a structure or building. 

The inspection method that Petitioner will utilize will not require the UAV to pass 

above 400 feet AGL to successfully complete any inspection. Therefore, 

Petitioner's proposed usage will not pose a hazard to the NAS because the UAV will 

not operate above 400AGL at any time during the duration of the flight. 

Given the foregoing, the Petitioner's proposed usage does not pose a hazard to 

the NAS or to the public. Considering the clear statutory language in Section 333 

of the Reform Act, the authority contained in the Federal Aviation Act, as amended, 

the equivalent level of safety to the public and to the men and women conducting 

infrastructure inspections, and the reduction in environmental effects, the grant of the 

requested exemptions is in the public interest. Accordingly, Petitioner respectfully 

requests that the FAA grant the requested exemption without delay. 

IV. REGULATIONS FROM WHICH EXEMPTION IS REQUESTED 

The Federal Aviation Act expressly grants the FAA Administrator the 

authority to issue exemptions. By its terms, this statutory authority includes 

exempting civil aircraft, as the term is defined under the Act, including UAV, from 

its safety regulations and minimum standards when the Administrator decides a 

requested exemption is in the public interest. 9 

Petitioner asks an exemption from several interrelated provisions of 14 C.P.R. 

Parts 21,45 and 91 for purposes of conducting aerial surveys and inspections using 

UAV. Listed below are: (1) the specific sections of 14 C.P.R. for which 

exemption is sought; and (2) the operating procedures and safeguards that Petitioner 

9 See 49 U.S.C. § 44701 (t) authorizing the grant of exemptions from requirements of regulations 

prescribed pursuant to§§ 44710(a) and (b),§§ 44702-44716. 

4 
has established which will ensure a level of safety equal to or better than the rules from 

which exemption is sought. 10 

A. 14 C.F.R. Part 21, Subpart H- Airworthiness Certificates and 14 

C.F.R. §91.203(a)(1). 

The Petitioner seeks an exemption from 14 C.P.R. Part 21, Subpart H, which 

establishes the procedural requirements for the issuance of airworthiness certificates as 

required by 14 C.F.R§ 91.203(a)(l). Given the size and limited operating area 

associated with the UAV to be utilized by the Petitioner, 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 Act11 and Section 333 of the Reform Act12 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 UAV. In all cases, an 

analysis of these criteria demonstrates that the UAV 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 rotorcraft 

operating with an airworthiness certificate without the restrictions and conditions of 

the proposed UA V operations. 

Equivalent Level of Safety 

The UAV to be operated hereunder is less than 50 lbs. fully loaded, carries 

neither a pilot nor passenger, carries no explosive materials or flammable liquid fuels, 

and operates exclusively within a secured area as set out in the Manual. Unlike other 

civil aircraft, the proposed operations in this petition for exemption will be controlled 

and monitored by the operator, pursuant to the Manual's requirements. Moreover, the 

FAA will have advance notice of all operations conducted under this exemption. 

10 See 14 C.P.R. § 11.81 (e) which requires a petition for exemption to include: "the reasons why granting 

the exemption would not adversely affect safety, or how the exemption would provide a level of safety at 

least equal to that provided by the rule from which you seek exemption." 11 See 49 U.S.C. § 44701(±). 12 See Reform Act, Supra note 1 

5 
These safety enhancements, which already apply to civil aircraft operated in 

connection with existing inspection operations, provide a greater degree of safety to 

the public and property owners than conventional operations conducted with 

airworthiness certificates issued under 14 C.P.R. Part 21, Subpart H. Lastly, 

application of these same criteria demonstrates that there is no credible threat to 

national security posed by the UAV, due to its size, speed of operation, location of 

operation, lack of explosive materials or flammable liquid fuels, and inability to 

carry a substantial external load. 

B. 14 C.F.R. Part 27: Airworthiness Standards: Normal Category 

Rotorcraft. 

14 C.P.R. Part 27 sets forth the procedural requirements for airworthiness 

certification of normal category rotorcraft. To the extent the Petitioner's UAV 

would otherwise require certification under Part 27, as a rotorcraft, Petitioner 

requests an exemption from Part 27's airworthiness standards for the same reasons 

identified in the exemption request from 14 C.P.R. Part 21, Subpart H. 

C. Aircraft Marking and Identification Requirements: 14 C.F.R. §§ 

91.9(c), 45.23(b) and 45.27(a). 

This petition seeks an exemption from the aircraft marking and identification 

requirements of 14 C.P.R.§§ 91.9(c), 45.23(b), and 45.27(a). 

14 C.P.R. § 91.9(c), Civil aircraft flight manual, marking, and placard 

requirements, provides that: 

No person may operate a U.S.-registered civil aircraft unless that 

aircraft is identified in accordance with part 45 of this chapter. 13 

14 C.P.R.§ 45.23(b), Markings of the Aircraft, states: 

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," 

13 14 C.F.R. § 91.9(c). 

6 
"restricted " "light-sport," "experimental," or "provisional," as 

applicable: 14 

14 C.P.R. § 45.27(a), Rotorcraft, states: 

Each operator of a rotorcraft must display on that rotorcraft 

horizontally on both surfaces of the cabin, fuselage, boom, or tail the 

marks required by §45.23. 15 

Exemption from§ 45.23(b) is warranted because the UAV has no entrance to 

the cabin, cockpit, or pilot station on which the registration number can be placed. 

Moreover, given the size of the UAV, two-inch lettering would be impossible. 

Given the nature of the specific relief sought by this exemption request, 

Petitioner requires relief from the associated marking and identification requirements 

of§ 45.27(a) and § 91.9(c), which would require compliance with§ 45.23(b). 

Equivalent Level of Safety 

An equivalent level of safety for exemptions to the aircraft marking and 

identification requirements of§§ 91.9(c), 45.23(b), and 45.27(a), will be provided by 

having the UAV marked on its fuselage as required by§ 45.29(f) where the pilot, 

observer, and others working with the U A V will see the identification of the U A V as 

"Experimental." Additionally, Petitioner will ensure compliance with any requests of 

UAV marking by the FAA. 

The FAA has issued the following exemptions to the aircraft marking 

requirements of§ 45.23(b): Exemptions Nos. 10700, 8738, 10167 and 10167A. 

D. 14 C.F.R. § 61.113 (a) and (b): Private Pilot Privileges and 

Limitations: Pilot in Command. 

This petition seeks an exemption from the private pilot privileges and 

limitations of§§ 61.113 (a) and (b), which states: 

(a) Except as provided in paragraphs (b) through (h) of this section, no 

person who holds a private pilot certificate may act as pilot in 

command of an aircraft that is carrying passengers or property for 

compensation or hire; nor may that person, for compensation or hire, act 

as pilot in command of an aircraft. 

14 14 C.F.R. § 45.23(b). 15 14 C.F.R. § 45.27(a). 

7 
(b) A private pilot may, for compensation or hire, act as pilot in 

command of an aircraft in connection with any business or 

employment if: 

(1) The flight is only incidental to that business or employment; 

and 

(2) The aircraft does not carry passengers or property for 

compensation or hire. 16 

14 C.P.R.§ 61.113(a) limits private pilots to being in command of noncommercial flights. 

14 C.P.R. § 61.113(b )(1) provides an exception that allows a private pilot to command 

an aircraft without passengers or property, in connection with business or employment 

if "[t]the flight is only incidental to that business or employment. "

17 

The stated 

exception likely does not apply to the proposed operations under this petition for 

exemption, as the flights are not incidental to the proposed aerial surveys and 

inspections but rather essential to it. Accordingly, the Petitioner seeks an exemption to 

14 C.P.R. § 61.113(a)'s commercial limitation and/or 14 C.P.R. § 61.113(b)(1)'s 

requirement that the flight be incidental to the business to benefit from the exception. 

Equivalent Level of Safety 

As required by the Manual, Petitioner's UA V operators acting as PIC will hold 

a commercial and/or private pilot certification and have rotorcraft experience. 

Because the UAV will not carry a pilot or passengers, the proposed operations can 

achieve the equivalent level of safety to 14 C.P.R.§§ 61.113 (a) and (b). 

Unlike a conventional aircraft that carries the pilot and passengers, the UAV 

is remotely controlled with no passengers on board. Moreover, the area of operation is 

controlled and restricted, and all flights are planned, coordinated, and briefed to the 

appropriate official in advance. 

Petitioner can achieve an equivalent level of safety as achieved by current 

Regulations because the UA V does not carry any pilots or passengers. Further, while 

helpful, a pilot license will not ensure remote control piloting skills, though 

16 14 C.F.R. § 61.113 (a) and (b). 17 14 C.F.R. §61.113 (b)(l) 

8 
Petitioner's pilot vetting and training programs will ensure the PIC has substantial 

experience on the airframe. Further, private pilot licensees will operate Petitioner's 

UAV with the same skill. The risks attendant to the operation of Petitioner's UAV are 

far less than the risk levels inherent in the commercial activities outlined in 14 C.F.R. 

§ 61, et seq. Thus, allowing Petitioner to operate its UAV with a private pilot as the 

PIC will exceed current safety levels in relation to 14 C.F.R. §§ 61.113 (a) and (b). 

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

The Petitioner seeks an exemption from the flight manual requirements of 

14 C.F.R. § 91.9(b)(2), which states: 

(b) 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. 18 

Given its size, configuration, and load capacity, the UAV has no ability to 

carry such a manual on the aircraft, not only because there is no pilot on board, but 

because there is simply no room or capacity to carry such an item on the aircraft. 

Equivalent Level of Safety 

The safety related purpose of this manual requirement can be equally 

satisfied by maintaining the UAV flight manual at the ground control point where 

the pilot flying the UA V will have immediate access to it. Accordingly, Petitioner 

requests an exemption from § 91.9(b )(2)'s flight manual requirements, on the condition 

that the U A V flight manual be available at the control point during each operation. 

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. 

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

This petition seeks an exemption from 14 C.F.R. § 91.7(a), which requires 

that a civil aircraft be in an airworthy condition to be operated. Inasmuch there 

18 14 C.F.R. §91.8 (b)(2) 

9 
will be no airworthiness certificate issued for the UA V, should this exemption be 

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

Equivalent Level of Safety 

Given the size of the UAV and the requirements contained in the Manual for 

maintenance and use of safety checklists prior to each flight, an equivalent level of 

safety will be provided. 

The FAA has issued exemptions to this regulation in the following 

situations: Exemption Nos. 8607, 8737, 8738, 9299, 9299A, 9565, 9565B, 

10167, 10167A, 10602, 32827, and 10700. 

G. 14 C.F.R. § 91.103: Preflight Action. 

This petition seeks an exemption from§ 91.103, which requires a PIC to 

become familiar with specific information before each flight, including information 

contained in the FAA approved Flight Manual on board the aircraft. 19 Inasmuch as an 

FAA approved flight manual will not be provided for the UAV, an exemption is 

requested. 

Equivalent Level of Safety 

An equivalent level of safety will be provided by following the Aircraft 

Operations Manual comprehensive preflight checklist. The PIC will take all 

actions, including reviewing weather, flight battery requirements, landing and takeoff 

distances, and aircraft performance data, before initiation of flight. 

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

The Petitioner seeks an exemption from 14 C.P.R. § 91.109(a), which 

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 functional dual 

controls."20 UA V and remotely piloted aircraft, by their design do not have fully 

functional dual controls. Instead, flight control is accomplished through the use 

of a control box communicating with the UAV via radio communications. 

19 14 C.F.R. §91.03 20 14 C.F.R. § 91.109(a). 

10 
Equivalent Level of Safety 

Given the size and speed of the UAV, an equivalent level of safe training 

can still be performed without dual controls because no pilot or passengers are 

aboard the UAV, and all persons will be a safe distance away should the UAV 

experience any difficulties during flight instruction. 

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.21 

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

This petition seeks an exemption from the minimum safe altitude requirements 

of 14 C.P.R.§ 91.119. This Section prescribes the minimum safe altitudes under which 

aircraft may not operate, including 500 feet above the surface and away from any 

person, vessel, vehicle, or structure in non-congested areas?2 Section§ 91.119(d)(1) 

allows for a helicopter to operate at less than those minimum altitudes when it can be 

operated "without hazard to persons or property on the surface," provided that "each 

person operating the helicopter complies with any routes or altitudes 

specifically prescribed for helicopters by the FAA. 

To provide the intended inspections, the UAV will normally need to be 

operated within a range of approximately 50 feet from the infrastructure being 

inspected. Accordingly, due to the nature of the proposed operations, the PIC and the 

VO may at times be less than 500 feet away from structures during the operation, and 

an exemption is therefore required. 

Equivalent Level of Safety 

Compared to flight operations with rotorcraft weighing far more than the 

maximum 50 pounds proposed herein, and the lack of flammable fuel, any risk 

associated with these operations is far less than those presently presented with 

conventional aircraft. An equivalent level of safety will be achieved given the size, 

weight, speed of the U A V as well as the location where it is operated. As set forth 

21 See Exemption Nos. 5778K and 9862A. 22 See 14 C.F.R. § 91.119(c). 

11 
in the Manual, the U A V will be operated in a restricted area, where buildings and 

people will not be exposed to operations. Because of the advance notice, all 

affected individuals will be aware of the planned flight operations as set forth in the 

Manual. Furthermore, by operating at such lower altitudes, the UAV will not interfere 

with other aircraft that are subject to the minimum safe altitude regulations. 

J. 14 C.F.R. § 91.121: Altimeter Settings. 

The Petitioner seeks an exemption from 14 C.P.R. § 91.121, which 

requires a person operating an aircraft to maintain cruising altitude or flight level by 

reference to an altimeter that is set to the elevation of the departure airport or 

barometric pressure. 23 An exemption is required because the UAV does not have a 

barometric altimeter, but rather a GPS altitude read out. 

Equivalent Level of Safety 

An equivalent level of safety will be achieved by following the procedures set 

forth in the Manual. As prescribed in the Manual, the operator will confirm the 

altitude of the launch site shown on the GPS altitude indicator before flight. Prior 

to each flight, the PIC will reset the altimeter to zero and will fly the UAV below 

400 feet AGL. Moreover, the PIC will use the GPS altitude indicator to constantly 

monitor the UA V height, thus ensuring operation at safe altitudes. 

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

Conditions. 

The Petitioner seeks an exemption from 14 C.P.R.§ 91.151(a)'s fuel 

requirements for flight in VFR conditions. Section 91.151 (a) states: 

(a) No person may begin a flight in an airplane under VFR 

conditions unless (considering wind and forecast weather 

conditions) there is enough fuel to fly to the first point of intended 

landing and, assuming normal cruising speed 

(1) During the day, to fly after that for at least 30 minutes; or 

(2) At night, to fly after that for at least 30 minutes?4 

23 See 14 C.F.R. § 91.121. 24 14 C.F.R. § 91.151(a). 

12 
The battery powering the UAVs described provide less than one half-hour of 

powered flight. An exemption from the 30 minute reserve requirement in 14 CFR § 

91.151 is therefore required. 

Equivalent Level of Safety 

An equivalent level of safety can be achieved by limiting flights to 30 minutes 

or 25% of battery power, whichever happens first. This restriction would be more than 

adequate to return the UAV to its planned landing zone from anywhere within its 

limited operating area. Operation of the UA V with less than 30 minutes of reserve fuel 

does not engender the type of risks that Section 91.151(a) was intended to alleviate 

given the size and speed of the small UAV. Moreover, operations will be limited 

to controlled areas where permission to perform UAV services has been obtained and 

all concerned parties given notice. 

This request for exemption falls within the scope of prior exemptions?5 

L. 14 C.F.R. §§ 91.203(a) and (b): Carrying Civilian Aircraft 

Certification and Registration. 

This petition seeks an exemption from civil aircraft certification and 

registration requirements of 14 C.P.R.§§ 91.203 (a) and (b). The regulations provide 

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?6 

In addition to the fact that Petitioner is seeking an exemption from the 

airworthiness certificate requirements, an exemption to this regulation is necessary 

25 See e.g. Exemption 10673 (allowing Lockheed Martin Corporation to operate without compliance 

with§ 91.151 (a)); see also FAA Exemptions 2689F, 5745, 10673, and 10808. 

26 14 C.F.R. §§ 91.203 (a) and (b). 

13 
because: (1) the UAV's load capacity and size does not allow it to carry certification 

and registration documents; (2) the UAV does not have a cabin or cockpit entrance at 

which the documents could be displayed; and (3) there are no passengers or crew for 

whom the certificates need be displayed. 

Equivalent Level of Safety 

To the extent these regulations are applicable to the proposed UAV 

operations, an equivalent level of safety will be achieved by keeping these documents 

at the ground control point where the pilot flying the UAV will have immediate access 

to them. 

The FAA has issued numerous exemptions to this regulation. A representative 

sample of other exceptions include Exemption Nos. 9565, 9665, 9789, 9789A, 9797, 

9797 A, 9816A, and 10700. 

M. 14 C.F.R. §§ 91.405(a)(l); 91.407(a)(l); 91.409(a)(l); 91.417(a) 

and (b): Maintenance Inspections 

The Petitioner seeks an exemption from the maintenance inspection requirements of 

14 C.P.R. §§ 91.405(a); 91.407(a)(l); 91.409(a)(2); 91.417 (a) and (b). These 

regulations specify maintenance and inspection standards in reference to 14 C.P.R. 

Part 43.27 An exemption to these regulations is needed because Part 43 and the 

stated sections apply only to aircraft with an airworthiness certificate, which the 

UAV will not have. 

Equivalent Level of Safety 

An equivalent level of safety will be achieved because maintenance and 

inspections will be performed in accordance with the Aircraft Operations Manual. 28 

As provided in the Manual, the PIC will ensure that the U A V is in working order prior 

to initiating flight, oversee and assist in performance of required maintenance, and 

keep a log of any maintenance performed. The PIC is the person most familiar with 

27 See e.g. 14 C.F.R. § 91.405(a) (stating that each owner or operator of an aircraft inspected as 

prescribed in subpart E of this part and shall between required inspections .... have discrepancies 

repaired as prescribed in part 43 of this chapter"). 28 See Manual 

14 
the aircraft and best suited to maintain the aircraft in an airworthy condition to 

provide the equivalent level of safety. 

If mechanical issues arise, the UAV can land immediately and will be 

operating from no higher than 400 feet AGL in an unpopulated area. Moreover, the 

UAV's small size, carrying capacity, and the fact that flight operations will only take 

place in restricted areas for limited periods of time, create less risk than the same 

factors associated with conventional fixed-wing aircraft and rotorcraft performing the 

same operation. 

V. PUBLICINTEREST 

Consistent with the requirements of 14 C.P.R. § 11.81 (d), Petitioner offers the 

following reasons why granting this petition for exemption is in the public interest, i.e., 

how granting it would benefit the public as a whole. Approval of exemptions 

allowing commercial operations of small and lightweight UA V in the infrastructure 

inspection industry benefits the public as a whole in several ways. 

First, granting the Petitioner's exemption helps fulfill Congress' goal in 

passing Section333(a) through (c) of the Reform Act, namely, the FAA 

Administrator's assessment of whether certain UAV may operate safely in the 

National Airspace System before completion of the rule making required under 

Section 332 of the Reform Act. 

Next, the Petitioner's proposed operation significantly improves safety and 

reduces risk concerning infrastructure inspection by alleviating human exposure to 

dangers associated with current aerial survey and inspection methods. Manned 

helicopters performing utility-power generation inspections and patrols have 

experienced an exceedingly high number of accidents and fatalities. 

Other Communication Facility inspection methods include utilizing a climber 

or team of climbers. To employ this method, human beings must physically climb the 

Communication Facility and document the condition of the Facility using hand-held cameras. 

In 2013 approximately one individual perished per month while conducting these activities. 

These deaths and injuries can be completely avoided by replacing this work with a UA V, PIC 

andVO. 

Further, Petitioner's UAV are battery powered and create no emissions. If 

Petitioner's U A V crashes, there is no fuel to ignite and explode. Any impact of 

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