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Exemption #11307

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BASIS FOR THE AMENDMENT TO EXEMPTION #11307

Price Aviation Group (PAG) received a 333 Exemption #11307 to operate a 3DR 

X8+ for aerial data collection. The aircraft is appropriate for missions that require a 

heavy payload. PAG is requesting an amendment to Exemption #11307 to operate a 

Fixed-Wing UAS for missions that require a longer duration. The platform will be a 

Bormatec MAJA with a 3DR Pixhawk control package. 

PAG will continue to use 3DR X8+and PAG X4 technology when necessary. 

PAG is requesting this amendment to operate a fixed wing UAS when the mission 

requires. The technology that is available from this company includes the necessary

restrictions on performance to comply with FAA requirements:

Maximum Altitude* 200ft

Range* 984ft from launch point

GPS Lock GPS lock required at all times

Maximum estimated flight time 30 min

Payload capacity 1 Kg (2.2 lbs.)

Bormatec’s design utilizes the same flight controller and R/C system as the X8+. 

Details of this design are included at the end of this document. 

All operations manuals approved for the 3DR X8+ will continue to be followed 

for the including recommended safety and maintenance checks. Modified checklist and 

design information is included in the Appendix. 

Summary for Federal Register publication.

The Rules From Which PAG Seeks Exemption: Conditions 

and Limitations #1 of Exemption #11307.

A. Brief Description Of The Nature Of The Amendment PAG Seeks:

Price Aviation Group (PAG) seeks an amendment to exemption 

#11307 to operate a small UAS with an equivalent level of safety. 

The amendment requests use of a fixed wing design to perform 

aerial data collection. 

CONCLUSION
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PAG is requesting an amendment to #1 of the Conditions and Limitations issued 

with Exemption #11307 included as an appendix to this document which states PAG will 

only operate a 3DR X8+. Allowing PAG to operate a Bormatec MAJA will allow an 

equivalent level of safety using a proven design and the reliability of proven 3DR 

technology. 

Submitted By:

Christopher Lawler

Price Aviation Group 

July 21, 2015
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Amendment

APPENDIX

Conditions and Limitations

In this grant of exemption, Price Aviation Group 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 3DR 

X8+ 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 PICmust 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 
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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, 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 
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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.

14. The operator may not permit any PIC to operate unless the PIC demonstratesthe 

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
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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.

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.
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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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Technical data:

Wingspan: 180 cm

Length: 120 cm

Weight without LiPo: 1,5 kg

Payload: 1,5 kg

Electronics: 3DR Pixhawk, Spektrum Radio Control Equipment. 

Failsafe:

The AFS failsafe system supports five of types of failsafe events:

 Geofence breach

 Maximum pressure altitude breach

 GPS loss

 Ground station or Radio Control communication loss

 Barometer failure