BEFORE THE 

FEDERAL AVIATION ADMINISTRATION

___________________________________________________

Autel Robotics USA, LLC,

Petitioner.

Docket No. FAA-2016-_____

AUTEL ROBOTICS USA, LLC PETITION FOR EXEMPTION FROM CERTAIN FEDERAL 

AVIATION REGULATIONS TO OPERATE UNMANNED AIRCRAFT SYSTEMS (UAS) 

PURSUANT TO SECTION 333 OF THE FAA MODERNIZATION 

AND REFORM ACT OF 2012

Lisa Ellman

Matthew Clark

Hogan Lovells US LLP

555 13th Street, N.W.

Washington, DC 20004

Phone: 202-637-6934 

Fax: 202-637-5910

lisa.ellman@hoganlovells.com

matt.clark@hoganlovells.com

Counsel for Autel Robotics USA, LLC 

DATE: February 15, 2016
i

TABLE OF CONTENTS

1. INTRODUCTION AND SUMMARY OF PROPOSED SMALL UAS 

OPERATIONS.........................................................................................................................1

2. BACKGROUND OF PETITIONER .........................................................................................2

3. RELEVANT STATUTORY AUTHORITY................................................................................2

4. AUTEL’S PROPOSED UAS OPERATIONS MEET THE 

REQUIREMENTS OF SECTION 333 OF FMRA ....................................................................3

4.1 Approval is warranted based on the UAS's size, weight, 

speed, and operational capability ...........................................................................3

4.2 Approval is warranted based on the proposed conditions 

and limitations...........................................................................................................4

5. REQUEST FOR DETERMINATION UNDER SECTION 333 OF FMRA ................................10

6. INFORMATION REQUIRED BY 14 C.F.R. § 11.81 TO SUPPORT A 

PETITION FOR EXEMPTION .................................................................................................10

6.1 Contact information:.................................................................................................10

6.2 The specific section or sections of the FAR from which 

Autel seeks an exemption........................................................................................11

6.3 The extent of relief sought and the reason relief is sought..................................12

6.4 Exemption request catch-all provision...................................................................23

6.5 Reasons why granting the request would be in the public 

interest .......................................................................................................................23

6.6 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 

exemption is sought.................................................................................................24

6.7 Summary that can be published in Federal Register, 

including the rule from which exemption is sought, and a 

brief description of the nature of the exemption sought ......................................26

6.8 Additional information that supports request........................................................27

6.9 Request to exercise the privileges of the exemption outside 

the U.S........................................................................................................................27

6.10 Attachments ..............................................................................................................27

7. CONCLUSION ........................................................................................................................27
1

1. INTRODUCTION AND SUMMARY OF PROPOSED SMALL UAS OPERATIONS

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (“FMRA”) 

and 14 C.F.R. (“FAR”) Part 11, Autel Robotics USA, LLC (“Autel”) hereby applies for a 

Summary Grant of Exemption from the Federal Aviation Regulations (“FAR”) identified 

below, to allow commercial operation of small unmanned aircraft systems (i.e., “small 

unmanned aircraft” or “UAS”) for aerial data collection, including outdoor research and 

development testing of Autel’s UAS platforms, testing of newly refurbished UAS, product 

demonstration and marketing flights, aerial photography / videography, aerial surveys, 

inspections, and mapping activities. Autel also seeks an exemption which would permit 

flights closer than 500 feet to, but not directly over, people directly participating in the 

intended purposes of the operation, in a controlled access environment, similar to a closed 

set, and consistent with the conditions and limitations imposed by the FAA in its recent Grant 

of Amendment to Cape Productions, Inc. Exemption No. 11433A (December 29, 2015; 

Docket FAA-2015-0223 (“Amended Cape Exemption”). Specifically, Autel requests that it be 

allowed to operate three of its UAS models, including, the Autel Robotics X-Star, X-Star Go 

and X-Star Premium, as well as the previously approved vehicles identified in Attachment 1 

and Attachment 2 to the Amended Measure Exemption (and attached to this Petition as 

Appendix A). See, e.g., Exemption No. 12646A (November 19, 2015; Docket FAA-2015-

1602) (“Amended Measure Exemption”). 

In addition to this Petition for Exemption, Autel will also submit a UAS Operations 

Manual addressing the items as specified in limitation No. 28 of the Amended Cape 

Exemption, and as proposed herein, for operations closer than 500 feet to, but not directly 

over, people directly participating in the intended purpose of the operation. Autel submits 

this UAS Operations Manual as a confidential document under separate cover pursuant to 

14 C.F.R. § 11.35(b), as the material contains confidential commercial and proprietary 

information that Autel has not and will not share with others. The information contained in the 
2

UAS Operations Manual is not generally available to the public and is protected from release 

under the Freedom of Information Act, 5 U.S.C. § 552 et seq.

Autel respectfully submits that this Petition for Exemption qualifies for expedited 

approval, as the FAA has previously issued grants of exemption in circumstances similar in 

all material respects to those presented herein. 

2. BACKGROUND OF PETITIONER 

Autel Robotics USA, LLC, which was established in November, 2015 and is 

headquartered in Bothell, Washington, is the North American sales and service subsidiary of 

Autel Intelligent Technology Corp. in Shenzhen, China. Autel has been a leader in 

automotive diagnostics hardware and software for over a decade and began developing 

small UAS platforms in early 2014. Autel currently has a line of small camera-carrying 

consumer quadcopters (the X-Star series), and is currently developing solutions to extend 

battery life utilizing vertical-takeoff fixed-wing products (the Kestrel series), that automatically 

transition to forward flight after taking off. The core transitioning technology won secondplace in the United Arab Emirates’ 2015 Drones for Good competition, and was developed in 

cooperation with Quantum Systems and the Technische Universität München.

Autel USA's leadership team have worked in the UAS retail sector since 2013 and 

during that period, have developed extensive customer education programs on the safe 

operation, maintenance, and repair of multiple small UAS platforms from several leading 

manufacturers. To meet growing customer demand and expand available services, Autel 

seeks an exemption to allow commercial operation of small UAS. Given that some aerial 

data collection activities will need to occur within the customers’ presence, Autel also seeks 

permission to conduct operations closer than 500 feet to, but not directly over, consenting 

customers that are directly participating in the intended purpose of the operation 

3. RELEVANT STATUTORY AUTHORITY 

This Petition for Exemption is submitted pursuant to Section 333(a) through (c) of 

FMRA. Congress has directed the FAA "to safely accelerate the integration of civil 
3

unmanned aircraft systems into the national airspace system." Pursuant to Section 333 of 

FMRA, the FAA Administrator is to permit unmanned aircraft systems to operate in the NAS 

where it is safe to do so based on the following considerations:

• 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 the visual line of sight of the operator. 

Additionally, the FAA Administrator has general authority to grant exemptions from 

the agency's safety regulations and minimum standards when the Administrator decides a 

requested exemption is in the public interest. See 49 U.S.C. § 106(f) (defining the authority 

of the Administrator); 49 U.S.C. § 44701(f) (permitting exemptions from §§ 44701(a), (b) and 

§§ 44702 – 44716, et seq.). 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). See FAR 

§ 11.81 (petitions for exemption).

4. AUTEL’S PROPOSED UAS OPERATIONS MEET THE REQUIREMENTS 

OF SECTION 333 OF FMRA 

Autel’s proposed operations in this Petition for Exemption qualify for expedited 

approval via the summary grant process pursuant to Section 333 of FMRA, as each of the 

statutory criteria and relevant factors is satisfied, and the FAA has previously issued grants 

of exemption in circumstances similar in all material respects to those presented in this

Petition for Exemption. See e.g., Amended Cape Exemption; Exemption No. 12958 

(September 22, 2015; Docket FAA-2015-2717) (“Aeronautic Imagery Exemption”); 

Exemption No. 11692 (May 26, 2015; Docket FAA-2015-0220) (“OpenSky Exemption”).

4.1 Approval is warranted based on the UAS's size, weight, speed, and 

operational capability 

All of the UAS vehicles chosen by Autel meet the requirements of Section 333 of 

FMRA due to their weight, speed and operational capabilities. Autel intends to operate a 

variety of small, lightweight, battery-powered UAS under the requested exemption, including 
4

those approved in previously granted exemptions and are set out in Attachment 1 and 

Attachment 2 to the Amended Measure Exemption (and attached to this Petition as Appendix 

A). Autel also seeks to operate three proprietary micro-size UAS platforms, including the 

Autel Robotics X-Star, X-Star Go and X-Star Premium. The following shared characteristics 

of the Autel Robotics X-Star, X-Star Go and X-Star Premium make them appropriate for 

aerial data collection activities and would warrant approval for a grant of exemption under 

Section 333 of FMRA: 

• They all weight less than 55 pounds including payload;

• They all have the capability to operate safely after experiencing certain in-flight

contingencies or failures and uses an auto-pilot system to maintain UAS stability and 

control. The UAS is also able to respond to a loss of GPS or a lost-link event with a 

pre-coordinated, predictable, automated flight maneuver. These safety features 

provide an equivalent level of safety compared to a manned aircraft performing a 

similar operation and mitigate the risk of command and control link failures;

• The radio frequencies used for operations and control of the UAS comply with the 

Federal Communications Commission (FCC) and other appropriate government 

oversight agency requirements; and

• The UAS all operate at a speed of 87 knots or less.

Details on the technical specifications and operating capabilities of the Autel 

Robotics X-Star, X-Star Go and X-Star Premium are attached as Appendix B. 

4.2 Approval is warranted based on the proposed conditions and 

limitations 

To expedite the FAA’s safety assessment of Autel’s proposed UAS operations, Autel 

will consent to conditions and limitations No.’s 2 through 29 of the Amended Cape 

Exemption.

1 Specifically, Autel will conducted the proposed operations in accordance with 

the following conditions and limitations which will ensure that the proposed operations can be 

conducted safely. 

1. Operations authorized by the grant of exemption will be limited to the Autel Robotics XStar, Autel Robotics X-Star Go, Autel Robotics X-Star Premium, and the UAS approved 

 1 Limitation No. 1 of the Amended Cape Exemption addressed the specific small UAS model 

Cape Productions sought operate. All UAS operated by Autel will also weigh less than 55 pounds 

including payload and equipment. 
5

by the Secretary of the Department of Transportation under Section 333 (Appendix A) 

when weighing less than 55 pounds including payload. Proposed operations of any other 

UAS will require a new petition or a petition to amend this exemption.2 

2. If operations under this exemption involve the use of foreign civil aircraft3 the operator 

would need to obtain a Foreign Aircraft Permit pursuant to 14 CFR § 375.41 before 

conducting any commercial air operations under this authority. Application instructions 

are specified in 14 CFR §375.43. Applications should be submitted by electronic mail to 

the DOT Office of International Aviation, Foreign Air Carrier Licensing Division. Additional 

information can be obtained via https://cms.dot.gov/policy/aviationpolicy/licensing/foreign-carriers.

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

operator 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. This limitation is in addition to any altitude 

restrictions that may be included in the applicable COA.

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

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

holder must apply for a new or amended COA if it intends to conduct operations that 

cannot be conducted under the terms of the attached COA.

6. The PIC must have the capability to maintain visual line of sight (VLOS) 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 that individual’s FAA-issued airman medical certificate 

or valid U.S. driver’s license issued by a state, the District of Columbia, Puerto Rico, a 

territory, a possession, or the Federal Government, to see the UA.

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

visual line of sight (VLOS) of the VO at all times. The VO must use human vision unaided 

by any device other than corrective lenses to see the UA. The VO and the 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.

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

operations in accordance with the conditions and limitations stated in this 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, the 

applicable ATO-issued COA, and the procedures outlined in the operating documents, 

 2 See Amended Measure Exemption Limitation No. 1.

3 Foreign civil aircraft means (a) an aircraft of foreign registry that is not part of the armed forces 

of a foreign nation, or (b) a U.S.-registered aircraft owned, controlled or operated by persons who 

are not citizens or permanent residents of the United States. 14 CFR §375.1.
6

the most restrictive conditions, limitations, or procedures apply and must be followed. 

The operator may update or revise its operating documents as necessary. The operator 

is responsible for tracking revisions and presenting 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 

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 exemption. The FAA’s UAS Integration Office may be contacted if 

questions arise regarding updates or revisions to the operating documents.

9. 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 must be conducted by a PIC with a VO and other personnel 

required to conduct the functional flight test (such as a mechanic or technician) and must 

remain at least 500 feet from all 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.

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

a condition for safe operation.

11. 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.

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

inspection, and life limit requirements for the aircraft and aircraft components. Each UAS 

operated under this exemption must comply with all manufacturer safety bulletins.

13. PIC certification: Under this 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.

14. PIC qualifications: The PIC must demonstrate the ability to safely operate the UAS in a 

manner consistent with how it will be operated under this exemption, including evasive 

and emergency maneuvers and maintaining appropriate distances from persons, 

vessels, vehicles and structures before operating non-training, proficiency, or 

experience-building flights under this exemption. PIC qualification flight hours and 

currency may be logged in a manner consistent with 14 CFR § 61.51(b), however UAS 

pilots must not log this time in the same columns or categories as time accrued during 

manned flight. UAS flight time must not be recorded as part of total time.

Under all situations, the PIC is responsible for the safety of the operation. The PIC is also 

responsible for meeting all applicable conditions and limitations as prescribed in this 

exemption and ATO-issued COA, and operating in accordance with the operating 

documents. All training operations must be conducted during dedicated training sessions 

and may or may not be for compensation or hire. The operation must be conducted with 

a dedicated VO who is no collateral duties and is not the PIC during the flight. The VO 
7

must maintain visual sight of the aircraft at all times during flight operations without

distraction in accordance with the conditions and limitations below. Furthermore, the PIC 

must operate the UA not closer than 500 feet to any nonparticipating person without 

exception.

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 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.

17. For UAS operations where GPS signal is necessary to safely operate the UA, the PIC 

must immediately recover/land the UA upon loss of GPS signal.

18. If the PIC loses command or control link with the UA, the UA must follow a predetermined route to either reestablish link or immediately recover or land.

19. The PIC must abort the flight operation if unpredicted circumstances or emergencies that 

could potentially degrade the safety of persons or property arise. The PIC must terminate 

flight operations without causing undue hazard to persons or property in the air or on the 

ground.

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. 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 (NNumber) markings in accordance with 14 CFR part 45, Subpart C. Markings must be as 

large as practicable.

22. 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.

23. The UA must remain clear of and give way to any manned aircraft at all times.

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

25. All flight operations must be conducted at least 500 feet from all persons, vessels, 

vehicles, and structures unless when operating:

a. Over or near people directly participating in the operation of the UAS. People 

directly participating in the operation of the UAS include the PIC, VO, and other 

consenting personnel that are directly participating in the safe operation of the 

UA.

b. Near but not over people directly participating in the intended purpose of the UAS 

operation. People directly participating in the intended purpose of the UAS 
8

includes [customers]4 who must be briefed on the potential risks and 

acknowledge and consent to those risks. Operators must notify the local Flight 

Standards District Office (FSDO) with a plan of activities at least 24 hours prior to 

flight operations.

c. Near nonparticipating persons. Except as provided in subsections (a) and (b) of 

this section, a UA may only be operated closer than 500 feet to a person when 

barriers or structures are present that sufficiently protect that person from the UA 

and/or debris or hazardous materials such as fuel or chemicals in the event of an 

accident. Under these conditions, the operator must ensure that the person 

remains under such protection for the duration of the operation. If a situation 

arises where the person leaves such protection and is within 500 feet of the UA, 

flight operations must cease immediately in a manner that does not cause undue 

hazard to persons.

d. Near vessels, vehicles and structures. Prior to conducting operations the 

operator must obtain permission from a person with the legal authority over any 

vessels, vehicles or structures that will be within 500 feet of the UA during 

operations. The PIC must make a safety assessment of the risk of operating 

closer to those objects and determined that it does not present an undue hazard.

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

permission from a person with legal authority to grant access. Permission will be 

obtained for each flight to be conducted.

27. 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 within 24 hours. Accidents must be reported to the 

National Transportation Safety Board (NTSB) in accordance with its UAS accident 

reporting requirements.

For operations conducted closer than 500 feet to people directly participating in the intended 

purpose of the operation, not protected by barriers, the following additional conditions and 

limitations apply:

28. The operator must have an operations manual that contains at least the following items, 

although it is not restricted to these items.

a. Operator name, address, and telephone number.

b. Distribution and Revision. Procedures for revising and distributing the operations 

manual to ensure that it is kept current. Revisions must comply with the 

applicable conditions and limitations in this exemption.

c. Persons Authorized. Specify criteria for designating individuals as directly 

participating in the safe operation of the UAS. The operations manual must 

 4 In Limitation No. 25(b) of the Amended Cape Exemption, people directly participating in the 

intended purpose of the UAS operation included “athletes.” Consistent with the FAA’s analysis 

contained therein and in the Amended Kansas State Exemption, the risk posed to participating 

customers within 500 feet of the operation is similar to the risk posed to athletes in the Amended 

Cape Exemption, as well as the observing KSU students in the Amended Kansas State 

Exemption. See Amended Cape Exemption at 5. 
9

include procedures to ensure that all operations are conducted at distances from 

persons in accordance with the conditions and limitations of the exemption.

d. Plan of Activities. The operations manual must include procedures for the 

submission of a written plan of activities.

e. Permission to Operate. The operations manual shall specify requirements and 

procedures that the operator will use to obtain permission to operate over 

property or near vessels, vehicles, and structures in accordance with this 

exemption.

f. Security. The manual must specify the method of security that will be used to 

ensure the safety of nonparticipating persons. This should also include 

procedures that will be used to stop activities when unauthorized persons, 

vehicles, or aircraft enter the operations area, or for any other reason, in the 

interest of safety.

g. Briefing of persons directly participating in the intended operation. Procedures 

must be included to brief personnel and participating persons on the risks 

involved, emergency procedures, and safeguards to be followed during the 

operation.

h. Personnel directly participating in the safe operation of the UAS Minimum 

Requirements. In accordance with this exemption, the operator must specify the 

minimum requirements for all flight personnel in the operating manual. The PIC 

at a minimum will be required to meet the certification standards specified in this 

exemption.

i. Communications. The operations manual must contain procedures to provide 

communications capability with participants during the operation. The operator 

can use oral, visual, or radio communications as along as the participants are 

apprised of the current status of the operation.

j. Accident Notification. The operations manual must contain procedures for 

notification and reporting of accidents in accordance with this exemption.

In accordance with this exemption, the operating manual and all other operating 

documents must be accessible to the PIC during UAS operations.

29. At least 24 hours prior to operations, the operator must submit a written Plan of Activities 

to the local Flight Standards District Office having jurisdiction over the proposed 

operating area.

The Plan of Activities must include at least the following:

a. Dates and times for all flights. For seasonal or long-term operations, this can 

include the beginning and end dates of the timeframe, the approximate frequency 

(e.g. daily, every weekend, etc.), and what times of the day operations will occur. 

A new plan of activities must be submitted prior to each season or period of 

operations.

b. Name and phone number of the on-site person responsible for the operation.

c. Make, model, and serial or N-Number of each UAS to be used.

d. Name and certificate number of each UAS PIC involved in the operations.
10

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

Upon request, the operator will make available a list of those who gave 

permission.

f. Signature of exemption holder or representative stating the plan is accurate.

g. A description of the flight activity, including maps or diagrams of the area over 

which operations will be conducted and the altitudes essential to accomplish the 

operation

In accordance with this exemption, the Plan of Activities and all other operating 

documents must be accessible to the PIC during UAS operations. A new Plan of 

Activities must be submitted should there be any changes to items (a) through (g).

The above conditions and limitations are the same as those contained in the 

Amended Cape Exemption. Collectively, these conditions and limitations, in combination with 

requirements in Autel’s UAS Operations Manual, and the manufacturer’s manuals for the 

selected UAS, ensure that the proposed UAS operations will not adversely affect safety and 

will provide at least an equivalent level of safety to the rules from which exemption is sought.

5. REQUEST FOR DETERMINATION UNDER SECTION 333 OF FMRA

In accordance with FMRA Section 333, Autel requests that the Secretary of 

Transportation determine that its proposed small UAS operations (i) do not create a hazard 

to users of the National Airspace System or the public, and (ii) do not pose a threat to 

national security. Autel further requests that, based on the Secretary’s determination, the 

FAA determine – as it did in the Amended Cape Exemption, Aeronautic Imagery Exemption

and the OpenSky Drones Exemption – that relief from FAR Part 21 and any associated noise 

certification and testing requirements of FAR Part 36 is not necessary for the UAS operations 

proposed in this Petition.

6. INFORMATION REQUIRED BY 14 C.F.R. § 11.81 TO SUPPORT A PETITION FOR 

EXEMPTION

As required by FAR § 11.81, Autel provides the following information in support of 

this Petition:

6.1 Contact information:

_____________ Name: Autel submits this Petition for Exemption, through counsel, 

Lisa Ellman and Matthew Clark.

_____________Mailing address: Lisa Ellman 
11

 Counsel for Autel Robotics USA, LLC

 Hogan Lovells US LLP

 555 13th Street, NW

 Washington, DC 20004

 Telephone number: 202-637-6934 (Ellman)

 703-610-6154 (Clark)

 Facsimile number: 202-637-5910 

 E-mail addresses: lisa.ellman@hoganlovells.com

 matt.clark@hoganlovells.com

6.2 The specific section or sections of the FAR from which Autel seeks an 

exemption:

FAR Description

§ 61.23(a) and (c)

Medical certificates: Requirement and 

Duration.

§ 61.101(e)(4) and (5) Recreational pilot privileges and limitations.

§ 61.113(a) and (b)

Private pilot privileges and limitations: Pilot 

in command.

§ 61.315(a), (c)(2), and (c)(3)

What are the privileges and limits of my sport 

pilot certificate?

§ 91.7(a) Civil aircraft airworthiness.

§ 91.119(c), (d) Minimum safe altitudes: General.

§ 91.121 Altimeter settings.

§ 91.151

Fuel requirements for flight in VFR 

conditions.

§ 91.405(a) Maintenance required.

§ 91.407(a)(1)

Operation after maintenance, preventive 

maintenance, rebuilding, and inspections.

§ 91.409(a)(1) and (2) Inspections.

91.417(a) and (b) Maintenance records.
12

6.3 The extent of relief sought and the reason relief is sought:

Autel intends to conduct aerial data collection by operating the small UAS models 

described herein. If granted, the proposed operations would allow Autel to conduct aerial 

data collection, including outdoor research and development testing of Autel’s UAS 

platforms, testing of newly refurbished UAS, product demonstration and marketing flights, 

aerial photography / videography, aerial surveys, inspections, and mapping activities. The 

proposed operations would also allow Autel to conduct UAS flights closer than 500 feet to, 

but not directly over, people directly participating in the intended purposes of the operation, 

in a controlled access environment, similar to a closed-set, and consistent with the conditions 

and limitations imposed by the FAA in the Amended Cape Exemption. Autel petitions the 

FAA, pursuant to FAR §§ 11.61(b), 11.63(a), and 11.81(b), for an exemption from the 

following FAR sections for the reasons noted:

FAR § 61.23(a) and (c) -– Medical certificates: Requirement and Duration.

FAR § 61.101(e)(4) and (5) – Recreational pilot privileges and limitations.

The regulation states, in relevant part:

(e) Except as provided in paragraphs (d) and (i) of this section, a recreational pilot 

may not act as pilot in command of an aircraft—

(4) For compensation or hire;

(5) In furtherance of a business; . . . .

FAR § 61.113(a) and (b) – Private pilot privileges and limitations: Pilot in 

command.

The regulation states, in relevant part:

(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. 

(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. 
13

(c) ****. 

FAR § 61.315(a) and (c)(2), (c)(3) – What are the privileges and limitations of my 

sport pilot certificate? 

The regulation states, in relevant part:

(a) If you hold a sport pilot certificate you may act as pilot in command of a light-sport 

aircraft, except as specified in paragraph (c) of this section. . . . 

. . . .

(2) For compensation or hire.

(3) In furtherance of a business. . . . 

Autel requests an exemption from these regulations to the extent necessary to permit 

Autel to conduct UAS operations using PICs who hold (i) an FAA private pilot, recreational 

pilot, or a sport pilot certificate, and (ii) an FAA airman medical certificate or a state driver’s 

license. While Autel recognizes that the FAA normally requires a PIC to hold a commercial 

pilot certificate where there is compensation either to the pilot or for the operation, Autel 

requests that the FAA exempt Autel and its PICs from this requirement since the use of at 

least a sport pilot as the PIC for the UAS operations under this exemption will be more safe 

than the use of a commercial pilot for manned aircraft operations. Unlike conventional 

aircraft, Autel’s UAS are lightweight, remotely controlled, battery-powered (not fuel/gas), and 

carry no crew or passengers. The fulfillment of the additional requirements for a sport, 

recreational or private pilot to become qualified as a commercial pilot would not lead to any 

additional safety benefits when UAS operations are involved. 

The differences between the aeronautical knowledge and aeronautical experience

requirements for sport pilots and for commercial pilots are significant in the traditional world 

of manned aircraft. However, no aspect of this incremental additional knowledge or 

aeronautical experience is significant for the daytime, VMC, low-altitude, VLOS, small UAS 

operations over private or controlled access properties with property owner/controller 

permission as proposed in this Petition. Put another way, there are stark and fundamental 

differences between the type of experience and aeronautical knowledge that the PIC of a 
14

commercial manned aircraft with passengers and property should have, versus the type of 

experience and aeronautical knowledge that the PIC of a small UAS should have, in order to 

avoid imperiling passengers or property. In Autel’s case, the small amount of property 

carried aboard the UA will be Autel’s property. While the PIC will be compensated, all risk of 

damage to the property (in fact to the UAS itself) will be borne by Autel. There is no 

expectation or need for the PIC of the small UA to have the type of experience or 

aeronautical knowledge that a commercial pilot for a manned aircraft would have. Similarly, 

the differences between the flight proficiency requirements for sport pilots and commercial 

pilots are not substantively significant here where the operations will be conducted strictly 

during daylight VMC conditions, within VLOS, at altitudes no higher than 400 feet AGL. 

Accordingly, there is no reason to require the UAS PIC to have more aeronautical 

knowledge, experience, and flight proficiency than that required for a sport pilot certificate.

Given that Autel plans to operate its UAS over private or controlled-access property 

and at low altitudes during daytime in VMC, the parallel nature of sport pilot aeronautical 

knowledge requirements to those of commercial requirements, the limited airmanship skills 

necessary to operate this small UAS, and the lack of additional safety benefits for the 

proposed UAS operations here resulting from commercial pilot experience, the PIC under 

this exemption should only be required to hold, at most, a sport pilot certificate. Such a 

condition would be consistent with the certificate requirements imposed on the PIC in the 

Amended Cape Exemption, Aeronautic Imagery Exemption and the OpenSky Drones 

Exemption.

For these reasons, and consistent with recent summary grant exemptions, Autel 

requests that the FAA grant an exemption to permit Autel to use as PIC of its proposed UAS 

operations pilots who hold at least a sport pilot certificate and either an FAA third-class 

airman medical certificate or a state driver’s license, so long as they satisfy the conditions 

and limitations proposed in this Petition, including the PIC qualification and training 

requirements.
15

FAR § 91.7(a) – Civil aircraft airworthiness.

The regulation states in relevant part: 

(a) No person may operate a civil aircraft unless it is in an airworthy condition. . . . 

To the extent necessary for the proposed operations in this Petition, Autel requests 

an exemption from this provision.5 The UAS will not require an airworthiness certificate 

under FAR Part 21, Subpart H, and thus relief is requested from this regulation. See

Exemption No. 11110 (December 10, 2014; Docket FAA-2014-0367) (“Trimble Exemption”),

at 16. An exemption is warranted because Autel understands that, notwithstanding the lack 

of an airworthiness certificate, the FAA will consider its “compliance with [Autel’s Manuals] to 

be sufficient means for determining an airworthy condition” and that Autel must still 

determine the UA’s airworthiness prior to each flight based on compliance with such 

Manuals. Trimble Exemption, at 16.

FAR § 91.119(c) and (d)(1) – Minimum safe altitudes: General.

The regulation states:

Except when necessary for takeoff or landing, no person may operate an aircraft 

below the following altitudes: 

...

(b) Over congested areas. Over any congested area of a city, town, or settlement, or 

over any open air assembly of persons, an altitude of 1,000 feet above the highest 

obstacle within a horizontal radius of 2,000 feet of the aircraft.

(c) Over other than congested areas. An altitude of 500 feet above the surface, 

except over open water or sparsely populated areas. In those cases, the aircraft may 

not be operated closer than 500 feet to any person, vessel, vehicle, or structure. 

(d) Helicopters, powered parachutes, and weight-shift-control aircraft. If the operation 

is conducted without hazard to persons or property on the surface—

(1) A helicopter may be operated at less than the minimums prescribed in 

paragraph (b) or (c) of this section, provided each person operating the 

helicopter complies with any routes or altitudes specifically prescribed for 

helicopters by the FAA; and

...

 5

 Autel requests exemption from FAR § 91.7(a) based on the relief granted in the Trimble 

Exemption, at 16, 21. However, Autel notes that the FAA determined that no such exemption 

was needed in Exemption No. 11062 (September 25, 2014; Docket FAA-2014-0352) (“Astraeus 

Exemption”) at 19, 22. 
16

Autel requests an exemption from this regulation to the extent necessary to permit it 

to conduct UAS operations at altitudes lower than those permitted by FAR § 91.119, since 

the ability to operate at those altitudes are one of the key benefits of using small UAS for 

these flights. Even at these low altitudes, Autel’s UAS operations will be conducted at a level 

of safety at least equal to that which would be achieved if larger manned aircraft were to be 

used at the altitudes required by FAR § 91.119. 

With respect to paragraph (a), Autel intends to comply with this requirement to the 

same extent as would a manned aircraft, meaning that the UA must operate at an altitude 

such that the loss of a single power unit aboard the UA or used by the UAS would still permit 

an emergency landing “without undue hazard to persons or property on the surface.” Autel 

agrees with the FAA’s reasoning on this issue in the Astraeus Exemption, at 20, and 

therefore does not believe that relief is required from paragraph (a). 

Regarding paragraph (b), Autel plans to operate these small UAS over properties 

that Autel owns or controls and other private or controlled-access properties (with 

owner/controller permission) in areas that are not congested or densely populated. 

Accordingly, Autel does not believe that an exemption is necessary from this paragraph (b) 

covering “congested areas”. 

Finally, with respect to paragraph (c), Autel requests an exemption to allow UAS 

operations down to the surface, both in sparsely populated areas and in “other than 

congested” areas. Autel’s UAS operations require lower-level flying, but have a number of 

self-imposed restrictions to ensure at least an equivalent level of safety. 

Even with a grant of this exemption, the UAS operations will be at least as safe as 

operations by manned aircraft that comply with this paragraph. Flying a manned aircraft, 

given its weight, size, speed, and fuel load, would pose a significant risk relative to the use of 

a small UA, with a much smaller size and lighter weight, operating at much slower speeds, 

with batteries rather than a significant fuel load, at all times within VLOS of the PIC on the 

ground who has a wide view. Accordingly, as the FAA determined in the Trimble Exemption, 
17

at 17-18, relief is warranted here provided that Autel adheres to its Manuals and the 

conditions and limitations proposed herein. For these reasons, Autel requests relief from the 

entirety of paragraph (c), as was recently granted in the Aeronautic Imagery Exemption, at 2, 

and the OpenSky Drones Exemption, at 2.

To the extent necessary, Autel also requests relief from paragraph (d)(1), which 

applies only to helicopters and allows operation at lower altitudes only if on a prescribed 

helicopter route. Flying a manned helicopter would pose a significantly greater risk than 

using a small UA for the proposed operations, even if the helicopter is on a specific route or 

at a specific low altitude prescribed by the FAA. A manned helicopter is much heavier, 

larger, and faster than a small UA. Moreover, unlike Autel’s small UA, the helicopter has 

people on-board and a fuel load. The operation of a small UA at all times within the VLOS of 

the PIC on the ground would be at least as safe as a manned helicopter operation operating 

in conformity with the requirements of paragraph (d)(1), and therefore an exemption from 

Section 91.119(d)(1) is warranted.

FAR § 91.121 – Altimeter settings.

The regulation states, in relevant part:

(a) Each person operating an aircraft shall maintain the cruising altitude or flight level 

of that aircraft, as the case may be, by reference to an altimeter that is set, when 

operating—

(1) Below 18,000 feet MSL, to—

(ii) The current reported altimeter setting of a station along the route 

and within 100 nautical miles of the aircraft; 

(ii) If there is no station within the area prescribed in paragraph 

(a)(1)(i) of this section, the current reported altimeter setting of an 

appropriate available station; or 

(iii) In the case of an aircraft not equipped with a radio, the elevation 

of the departure airport or an appropriate altimeter setting available 

before departure; or 

(2) At or above 18,000 feet MSL, to 29.92′′ Hg. 

(b) * * * *.
18

To the extent necessary to conduct the proposed operations, Autel requests an 

exemption from the altimeter setting requirements of FAR § 91.121. Autel recognizes the 

critical importance of ensuring that any UA it operates maintains altitude to an accurate 

reference point. The PIC will check the UA altitude reading prior to each takeoff, and will 

effectively zero the UA’s altitude at the point of takeoff, to ensure that measurements of the 

UA’s altitude are as accurate as possible relative to the local elevation. To the extent that 

this methodology does not satisfy FAR § 91.121 or any other regulation, Autel requests an 

exemption to permit UAS operations using this methodology.

FAR § 91.151 – Fuel requirements for flight in VFR conditions.

The regulation 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 45 minutes. 

(b) No person may begin a flight in a rotorcraft 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, to fly after that 

for at least 20 minutes. 

Autel requests an exemption from FAR § 91.151’s fuel requirements for flight in VFR 

conditions. Technological and durational limitations on UAS battery power means that no 

meaningful flight operations can be conducted while still maintaining a 30-minute battery 

reserve. An exemption from the fuel requirements of FAR § 91.151 is therefore required. 

The FAA has previously granted relief from the fuel requirements of § 91.151(a) for flight in 

daytime VFR conditions in circumstances similar to those presented in this Petition for 

Exemption. See e.g., Aeronautic Imagery Exemption Limitation No. 20 and OpenSky Drones 

Exemption Limitation No. 20.

In the OpenSky Drones Exemption, the FAA determined that a requirement 

prohibiting the PIC from beginning a UAS flight unless (considering wind and forecast 

weather conditions) there was enough available power for UAS to operate for the intended 
19

operational time and to operate after that for at least five minutes or with the reserve power 

recommended by the manufacturer if greater, would ensure an equivalent level of safety to 

the fuel requirements of FAR § 91.151. Autel will adhere to the same reserve power 

condition and limitation and an exemption from FAR § 91.151’s fuel requirements for flight in 

VFR conditions is therefore appropriate. 

FAR § 91.405(a) – Maintenance required. 

The regulation states, in relevant part:

Each owner or operator of an aircraft—

(a) 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;

(b) ****.

Autel requests an exemption from the maintenance and inspection requirements of 

FAR § 91.405(a). In the Astraeus Exemption and the Trimble Exemption, the FAA 

determined that the proposed UAS operations required exemption from FAR § 91.405(a), 

and that the achievement of an adequate level of safety required certain conditions and 

limitations. Autel has proposed several conditions and limitations related to maintenance 

and inspections which it believes provide a level of safety at least equivalent to that provided 

by FAR § 91.405(a). For this reason, and consistent with the exemptions granted from this 

section in the Aeronautic Imagery Exemption and the OpenSky Drones Exemption, Autel 

requests an exemption from FAR § 91.405(a) to permit Autel to conduct UAS operations as 

proposed in this Petition, subject to the conditions and limitations proposed above, without 

having to perform the inspections and discrepancy repairs required by FAR § 91.405(a). 

Autel does not believe that an exemption from the remaining paragraphs of FAR § 

91.405 is required, since Autel will make appropriate logbook entries in aircraft maintenance 

records in accordance with paragraph (b), appropriately mark any inoperative instrument or 

item of equipment for which maintenance has been properly deferred in compliance with 
20

paragraph (c), and appropriately placard listed discrepancies that include inoperative 

instruments or equipment in compliance with paragraph (d). 

FAR § 91.407(a)(1) – Operation after maintenance, preventive maintenance, 

rebuilding or alteration.

The regulation states:

(a) No person may operate any aircraft that has undergone maintenance, preventive 

maintenance, rebuilding, or alteration unless—

(1) It has been approved for return to service by a person authorized under 

§43.7 of this chapter; and 

(2) The maintenance record entry required by §43.9 or §43.11, as applicable, 

of this chapter has been made. 

. . . . 

Autel requests an exemption from FAR § 91.407(a)(1) to allow the proposed 

operations without having to have the UAS approved for return to service by a person 

authorized under FAR § 43.7. In the Astraeus Exemption, the FAA determined that the 

proposed UAS operations required exemption from FAR § 91.407(a)(1), subject to certain 

conditions and limitations. Autel has proposed in this Petition maintenance-related 

conditions and limitations which it believes provide a level of safety at least equivalent to that 

provided by FAR § 91.407(a)(1). For this reason, and consistent with the exemptions 

granted from this section in the Aeronautic Imagery Exemption and the OpenSky Drones 

Exemption, Autel requests an exemption from FAR § 91.407(a)(1) to permit Autel to conduct 

UAS operations as proposed in this Petition, subject to the proposed conditions and 

limitations, without having to have the UAS approved for return to service by a person 

authorized under FAR § 43.7.

Autel does not believe that an exemption from the remaining paragraphs of FAR § 

91.407 is required, since Autel will require that maintenance record entries are made as 

required, in compliance with paragraph (a)(2), and since no persons will be carried following 

maintenance performed on the UAS, making paragraphs (b) and (c) moot. 
21

FAR § 91.409(a)(1) and (2) – Inspections.

The regulation states, in relevant part:

(a) Except as provided in paragraph (c) of this section, no person may operate an 

aircraft unless, within the preceding 12 calendar months, it has had—

(1) An annual inspection in accordance with part 43 of this chapter and has 

been approved for return to service by a person authorized by §43.7 of this 

chapter; or 

(2) An inspection for the issuance of an airworthiness certificate in 

accordance with part 21 of this chapter.

No inspection performed under paragraph (b) of this section may be substituted for 

any inspection required by this paragraph unless it is performed by a person 

authorized to perform annual inspections and is entered as an “annual” inspection in 

the required maintenance records. 

(b)  .

Autel requests an exemption from the inspection requirements of FAR § 91.409(a)(1) 

and (2). In the Astraeus Exemption, the FAA determined that the proposed UAS operations 

required exemption from FAR § 91.409(a)(1) and (2), and that achieving an adequate level of 

safety required certain conditions and limitations. Autel has proposed in this Petition 

maintenance and inspection-related conditions and limitations which it believes provide a 

level of safety at least equivalent to that provided by FAR § 91.409(a)(1) and (2). For this 

reason, and consistent with the exemptions granted from this section in the Aeronautic 

Imagery Exemption and the OpenSky Drones Exemption, Autel requests an exemption to 

permit Autel to conduct UAS operations as proposed in this Petition, subject to the conditions 

and limitations outlined herein, without having to comply with the inspection requirements in 

FAR § 91.409(a)(1) and (2). 

FAR § 91.417(a) and (b) – Maintenance records.

The regulation states, in relevant part:

(a) Except for work performed in accordance with §§91.411 and 91.413, each 

registered owner or operator shall keep the following records for the periods 

specified in paragraph (b) of this section: 

(1) Records of the maintenance, preventive maintenance, and alteration and 

records of the 100-hour, annual, progressive, and other required or approved 

inspections, as appropriate, for each aircraft (including the airframe) and 
22

each engine, propeller, rotor, and appliance of an aircraft. The records must 

include—

(i) A description (or reference to data acceptable to the Administrator) 

of the work performed; and 

(ii) The date of completion of the work performed; and 

(iii) The signature, and certificate number of the person approving the 

aircraft for return to service. 

(2) Records containing the following information: 

(i) The total time in service of the airframe, each engine, each 

propeller, and each rotor. 

(ii) The current status of life-limited parts of each airframe, engine, 

propeller, rotor, and appliance. 

(iii) The time since last overhaul of all items installed on the aircraft 

which are required to be overhauled on a specified time basis. 

(iv) The current inspection status of the aircraft, including the time 

since the last inspection required by the inspection program under 

which the aircraft and its appliances are maintained. 

(v) The current status of applicable airworthiness directives (AD) and 

safety directives including, for each, the method of compliance, the 

AD or safety directive number and revision date. If the AD or safety 

directive involves recurring action, the time and date when the next 

action is required.

(vi) Copies of the forms prescribed by §43.9(d) of this chapter for 

each major alteration to the airframe and currently installed engines, 

rotors, propellers, and appliances.

(b) The owner or operator shall retain the following records for the periods 

______prescribed: 

(1) The records specified in paragraph (a)(1) of this section shall be retained 

until the work is repeated or superseded by other work or for 1 year after the 

work is performed. 

(2) The records specified in paragraph (a)(2) of this section shall be retained 

and transferred with the aircraft at the time the aircraft is sold. 

(3) A list of defects furnished to a registered owner or operator under §43.11 

of this chapter shall be retained until the defects are repaired and the aircraft 

is approved for return to service.

(c) ** **.
23

Autel requests an exemption from the maintenance record requirements in FAR § 

91.417(a) and (b). The FAA determined in the Astraeus Exemption that the proposed UAS 

operations required exemption from FAR § 91.417(a) and (b), and that an adequate level of 

safety required certain conditions and limitations. Autel has proposed in this Petition 

maintenance, inspection, and records-related conditions and limitations which it believes 

provide a level of safety at least equivalent to that provided by FAR § 91.417(a) and (b). For 

this reason, and consistent with the exemptions granted from this section in the Aeronautic 

Imagery Exemption and the OpenSky Drones Exemption, Autel requests an exemption from 

FAR § 91.417(a) and (b) to allow the proposed operations, subject to the conditions and 

limitations outlined herein, without having to keep the records described in FAR § 91.417(a) 

and (b). 

6.4 Exemption request catch-all provision 

This Petition does not seek exemption from certain regulations based on the 

reasoning and analysis in prior FAA grants of exemption. To the extent that the FAA 

concludes that an exemption from one or more other provisions of the FAR would be 

required to allow the proposed operations in this Petition, Autel also seeks an exemption 

from those FAR provisions. 

6.5 Reasons why granting the request would be in the public interest: 

The public interest will be served in several ways by granting Autel’s Petition. First, 

Congress has established a national policy that favors early integration of UAS into the 

National Airspace System in controlled, safe working environments such as those proposed 

in this Petition. Granting this Petition helps fulfill Congress’ goal in passing Section 333(a) 

through (c) of the FMRA; namely, the FAA Administrator's assessment of whether certain 

UAS may operate safely in the NAS before completion of the rulemaking required under 

Section 332 of the FMRA.

The proposed UAS operations in this Petition will also improve safety and reduce risk 

by reducing the public’s exposure to danger associated with aerial data collection activities 
24

utilizing full-size fixed-wing aircraft and rotorcraft. Most of the UAS Autel intends to use for 

the proposed operations are battery-powered and create no emissions, as compared to the 

much faster, larger, and fuel-powered manned aircraft. Any accident involving Autel’s 

lightweight UAS will present significantly less danger to the pilot and other individuals on the 

ground than one involving a full-size helicopter or fixed-wing aircraft.

6.6 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 exemption is sought:

Throughout this Petition, Autel has discussed how it will ensure the safety of other 

manned aircraft and persons and property on the ground if the FAA grants the requested 

exemption. Consistent with the FAA’s findings in previously granted exemptions, the 

conditions and limitations proposed in this Petition, coupled with the operational protocols for 

the selected UAS platforms, and, when applicable, the requirements of Autel’s UAS 

Operations Manual, ensure a level of safety that is equal to or better than that provided by 

the rules from which exemption is sought. 

In general, the risks of any small UAS operation proposed in this Petition interfering 

with a manned aircraft would be minimized by numerous factors, including but not limited to: 

• the low altitude at which the UAS would operate;

• the locations at which the UAS would operate (e.g., remote areas; private or 

controlled access property; away from airports); 

• the small size, light weight, and relatively slow speed of Autel’s UAS;

• the restriction on UAS operations to VMC and daytime conditions; and

• the requirement for the UA to be operated within VLOS of the PIC and VO at all 

times. 

Moreover, Autel’s UAS have the capability to operate safely after experiencing 

certain in-flight contingencies or failures, and they use an auto-pilot system to maintain UAS 

stability and control. The UAS are also able to respond to a loss of GPS or a lost-link event 

with a pre-coordinated, predictable, automated flight maneuver. These safety features 
25

provide an equivalent level of safety compared to a manned aircraft performing a similar 

operation and mitigate the risk of command and control link failures.

The risks to persons or property on the ground would be substantially mitigated – if 

not eliminated – by these same factors, as well as the 500-foot set-off from non-participating 

persons, vehicles, and structures absent additional safeguards. Per the conditions and 

limitations proposed in this Petition, (i) the PIC will suspend/abort the UAS operation and UA 

flight in the event of unpredicted obstacles or emergencies in accordance with the Manuals; 

and (ii) Autel will coordinate extensively, as warranted, with the FAA, with local airports, and 

with property owners to ensure that all UAS operations under the exemption are at least as 

safe as would be manned aircraft operations used for similar purposes.

Consistent with the FAA’s findings and analysis in the Amended Cape Exemption, 

the operational safety measures required by Autel’s UAS Operations Manual will mitigate the 

risks associated with operating UAS closer than 500 feet to, but not over, consenting Autel 

customers who are directly participating in the intended purposes of the operation.6 These 

 6 The proposed operations are also consistent with the FAA’s Grant of Amendment to Kansas 

State University, Exemption No. 13465A (November 20, 2015; Docket FAA-2014-1088 

(“Amended Kansas State Exemption”):

“Additionally, the FAA recognizes that there are additional risks when operating a UA close to 

people, whether for the purpose of closed-set filming or otherwise. As such the FAA has 

determined that when conducting these types of operations, the operator must have an 

operations manual addressing the items as specified in the conditions and limitations below. 

Unmanned aircraft operations conducted in close proximity to people (less than 500 feet) invoke 

added safety risks. Regardless of the operation type (closed set film-making or other operation 

types), the operations manual requirement helps ensure that safety will not be adversely 

affected because the operator must document and address operational safety practices 

relevant to its operation. An operations manual must include items such as; the operator’s 

contact information, distribution and revision information, persons authorized, plan of activities, 

permission to operate, security methodology, briefing instructions, essential flight personnel 

minimum requirements, communications information, and accident notification plan. Documented 

operational safety practices and procedures help ensure a safe and repeatable process for 

conducting flight operations. Formal procedures ensure adequate safety guidelines are available 

and adhered to in normal operational environments, but also during emergency circumstances. 

The operations manual is considered part of the operating documents and must be accessible to 

the PIC during operations. This operations manual is based on the requirement in previous 

exemptions for a MPTOM for closed-set filming. (emphasis added)” Amended Kansas State 

Exemption at 13. 
26

flights will occur in a controlled access environment, similar to a closed-set, which prevents 

unauthorized people from entering the flight / filming area. As required by proposed 

condition and limitation no. 28, Autel’s UAS Operations Manual includes, among other 

things, requirements to develop a written Plan of Activities, a security plan to ensure the 

safety of nonparticipating persons, communication procedures for participants, and briefing 

procedures for persons directly participating in the intended purpose of the operation. 

The conditions and limitations proposed in this Petition, which are identical to those 

imposed in the Amended Cape Exemption, the operational safety features of the selected 

UAS platforms, and the requirements of Autel’s UAS Operations Manual ensure that the 

proposed operations will not interfere with manned aircraft and will ensure the safety of 

persons and property on the ground. For these reasons, granting an exemption from each 

section of the FAR from which relief is sought would not adversely affect safety, and would 

provide a level of safety at least equal to, or greater than, that provided by the rule from 

which exemption is sought. 

6.7 Summary that can be published in Federal Register, including the rule 

from which exemption is sought, and a brief description of the nature of 

the exemption sought:

Autel proposes that the FAA use the following as the summary:

Docket No.: FAA-2016-______

Petitioner: Autel Robotics USA, LLC

Sections of 14 CFR: 61.23(a) and (c), 61.101(e)(4) and (5), 61.113(a) and (b), 61.315(a), 

(c)(2), and (c)(3), 91.7(a), 91.119(c) and (d)(1), 91.121, 91.151, 91.405(a), 91.407(a)(1), 

91.409(a)(1) and (2), and 91.417(a) and (b).

Description of Relief Sought: Petitioner seeks an exemption to conduct small UAS 

operations for aerial data collection.
27

6.8 Additional information that supports request:

Autel is prepared to provide additional information that the FAA might find helpful, or 

to answer questions in response to any FAA requests. 

6.9 Request to exercise the privileges of the exemption outside the U.S.: 

Autel does not request to exercise the privileges of this exemption outside the United 

States.

6.10 Attachments:

A list of previously approved vehicles from Attachment 1 and Attachment 2 of the 

Amended Measure Exemption that Autel may operate under the requested exemption is 

attached as Appendix A. Details on specifications and operating capabilities of the Autel 

Robotics X-Star, X-Star Go and X-Star Premium as Appendix B. Autel will also submit UAS 

Operations Manual as a confidential document under separate cover pursuant to 14 C.F.R. § 

11.35(b), as the material contain confidential commercial and proprietary information that 

Autel has not and will not share with others. The information contained in the Operations 

Manual is not generally available to the public and is protected from release under the 

Freedom of Information Act, 5 U.S.C. § 552 et seq.

7. CONCLUSION 

For the foregoing reasons, Autel respectfully requests that the FAA grant this Petition 

for Exemption. Should you have any questions, or if you need additional information to 

support the Autel’s Petition for Exemption, please do hesitate to contact the undersigned.

Respectfully submitted, 

Lisa Ellman

Matthew J. Clark7

 7 Matthew Clark is only licensed to practice law in the Commonwealth of Virginia and his practice 

is limited consistent with Rule 49(c) of the D.C. Court of Appeals.
28

Hogan Lovells US LLP

Counsel for Autel Robotics USA, LLC
29

Appendix A 

Attachment 1

1. 3D Robotics Aero-M or Aero-M

2. 3D Robotics Iris

3. 3D Robotics Iris+

4. 3D Robotics X8

1. 3DRobotics Fixed Wing

2. 3DRobotics Multirotor

3. 3DRobotics Quadrotor

4. 3DRobotics Spektre or 3D Robotics Spektre Industrial Multi-Rotor Aerial Vehicle

5. 3D Robotics Solo or 3DR Solo

6. 3DRobotics X8+

7. 3D Robotics X8-M or X8-M

8. 3D Robotics Y6

9. Aerial Mob Heavy Lifter

10. Aerial Mob Light Lifter

11. Aerial Remote Mineral Detection System (ARMDS)

12. Aerialtronics Altura Zenith ATX8 or Aerialtronics Zenith with integrated Airware 

system

13. Aerigon

14. Aerobo

15. AeroCine Kopterworx Hammer X12 or Kopterworx Hammer X12

16. AeroLogix GeoStar

17. Aeromao AeroMapper 300

18. Aeromao Talon

19. Aeromao Aeromapper EV-2

20. AeroVironment Shrike or Shrike

21. AeroVironment Puma or Puma AE DDL

22. Aerovironment Qube

23. Aeronavics X4 Titanium

24. Aervonics Sky Jib

25. Aeryon Scout

26. Aeryon SkyRanger or Aeryon Sky Ranger

27. AgEagle

28. AgEagle Robotic

29. AgScout

30. AgScout Mini

31. Agribotix Hornet Drone

32. Agribotix Enduro Quad

33. AgriView VK Ranger EX or Viking Unmanned Aerial Systems, LLC AgriView VK 

Ranger EX or VK- Ranger EX- SAR Fixed Wing UAS

34. Aibotix Aibot X-6 or Aibot

35. Air Rover AR-300

36. AirCover QR-425s
30

37. AirRobot AR 180

38. AirRobot AR 100

39. AirRobot AR200

40. Air-X

41. Align M690

42. Altavian Nova F6500

43. Altavian Nova R8400

44. Altus X-4

45. Altus X-8

46. American Drones, LLC Eagle

47. Apprentice

48. Arch Aerial OCTO multi-rotor UAS

49. Arris hexacoper

50. AR-960 Hex Rotor

51. AR-540 Quad Rotor

52. ARF-MikroKopter OktoXL

53. ARF-MikroKopter OktoXL 6S12

54. ArrowLite

55. AscTec Falcon 8 or AscTec Falcon

56. Astraeus Aerial Cinema System V.3CS

57. Atlantic RC Aircraft LC047

58. Auburn War Eagle

59. Auburn EasyStar

60. AV44

61. Birdseyeview Firefly 6 or Fire Fly 6

62. Blade 350QX

63. Bixler 2

64. Boomerang Carbon Fiber Frame

65. Bormatec Maja UAV

66. BOSH Technologies Super Swiper

67. Bumblebee-S

68. C-Astral Bramor gEO

69. CarbonCore Octocopter 1000

70. Carbon Core Cortex Quadcopter

71. CCO w/Wkm M

72. Cinestar 6

73. Cinestar X8

74. Cinestar 8

75. Cinestar 8 HL

76. Cinestar 8 Okto XL

77. Coaxial Quad Multirotor VAO1-V1

78. Coaxial Quad Multirotor VAO2-V2

79. CopelandRED LLC Delta Wing Aircraft

80. CyberQuad Maxi
31

81. DJI Flame Wheel F450 or DJI F-450

82. DJI Flame Wheel F550

83. DAx8

84. DJI Inspire

85. DJI Inspire 1or DJI Inspire T600 or Q1

86. DJI Inspire 2

87. DJI Phantom

88. DJI Phantom 1

89. DJI Phantom 2

90. DJI Phantom 2+

91. DJI Phantom 2 Vision

92. DJI Phantom 2 Vision+

93. DJI Phantom Vision +

94. DJI Phantom 3

95. DJI Phantom FC40

96. DJI Spreading Wings S900

97. DJI Spreading Wings S1000

98. DJI Spreading Wings S1000+

99. DJI S800

100. DJI S800 EVO

101. Draganflyer Guardian

102. Draganflyer X4ES

103. Draganflyer X4P

104. Draganflyer X6

105. DT-18

106. DYS D800-X8

107. Eagle VTOL

108. E-Flite Apprentice

109. Event 38 E384

110. Falcon VTOL

111. First Aerial Responder - Sight

112. Flame Wheel G4 7.8 Skycrane or Multirotor G4 7.8 Skycrane

113. Flying-Cam 3.0 SARAH

114. Foxtech Kraken 130 V2 or K130 Octocopter

115. FreeFly Systems ALTA RTF

116. G4 Eagle

117. GerMAP G220

118. GerMAP G180

119. goFarm GF-1

120. Gryphon Dynamics X8

121. GT80X

122. Harris 18 HL

123. HEFF

124. Helios 960
32

125. HexaCrafter HC-1100

126. HexaCrafter HO-1250

127. HH Blade 350QX2 AP

128. Hobbyking “Bixler” Fixed Wing Trainer

129. HoneyComb AgDrone

130. Hoverfly LiveSky

131. Hoverfly BigSky 60

132. Hoverfly H-Frame

133. Hubsan X4 micro drone

134. HVP 14301 Multi Rotor

135. InovalDrone:Inova One

136. InspecTools X-8 or ITX8

137. InstantEye Mk-2

138. InstantEye Mk-2 Gen2

139. Intuitive Aerial Aeragon

140. KongCopter X8

141. Latitude HQ-4 Hybrid Multirotor

142. LB700

143. Leading Edge Precision Vision 10

144. Leptron Avenger

145. Lewis Realty Associates Hexacopter 650

146. Liberty 1

147. Lockheed Martin Desert Hawk III

148. Lockheed Martin Indago or Indago

149. MaxFlight

150. MD4-200

151. MD4-1000 or Frame Ronin Edition Microdrones:MD4-1000

152. Mikrokopter 2.5

153. MLB Company Super Bat

154. MU-1H

155. Multirotor G4 7.8 Skycrane

156. Nighthawk VTOL or Nighthawk

157. PAG X4

158. Parkzone Radian RTF

159. Parrot Bebop drone

160. Parrot PF 725100 Bebop Drone 14MP

161. Patriot X4

162. Patriot X8

163. Finwing Penguin V2

164. Phoenix VTOL or Phoenix

165. Phoenix 60

166. Phoenix 60LE

167. Pinnacl X Chameleon Pro

168. Precision Drone Pacesetter
33

169. PrecisionHawk

170. PrecisionHawk Hawkeye Mk-III or Hawkeye Mk-III

171. PrecisionHawk Lancaster

172. Precision Lancaster MK3

173. Prioria Hex

174. Prioria’s Maveric

175. Pulse Aerospace, PA 01 Vapor

176. Pulse Aerospace Pulse Vapor 35

177. Pulse Vapor

178. PV 14817 Multi Rotor

179. PV HL1

180. PV HL2

181. Quadcopter LLC MikroKopter

182. Quiet UAV

183. R/C Rotors and Aerial Media: Matrix Prof. Multi Rotor Frame & Octo Heavy 

Lift Prof. Multi Rotor

184. RCTimer Hexacopter

185. RDASS

186. REHawk 500

187. REHawk 680

188. Roboflight RF-70

189. Riegl RiCopter

190. RITEWING Z3 Spade 47”

191. Ritewing Drake 60”

192. RITEWING Z3 Spade 70”

193. RITEWING Z4 Spade 52”

194. Rotomotion SR-15

195. RV Jet

196. Scout X4

197. SD02

198. Seahawk 1.2

199. SelectTech Geospacial’s EH-4

200. SenseFly eBee

201. SenseFly eBee RTK

202. SenseFly eXom

203. Sensurion Magpie MP-1

204. Service-Drone Recon One

205. Service-Drone Blackbird

206. SH 900

207. ShadowHawk

208. Sirius

209. SkyCatch

210. SkyJib 8 v.2 Heavy Lifter

211. SkyPhilly M1
34

212. Skywalker Aero

213. Skywalker Flying Wing X8

214. SnapRoll Media SUAS

215. Solutions Phoenix 30

216. SteadiDrone

217. Steadidrone QU4D

218. Steadidrone Mavrik

219. SuperX/P2 Multirotor

220. Swift Radioplanes Lynx

221. Tali 500

222. Talon 120LE

223. Tarot FY690S Hexacopter

224. Tarot quadcopter

225. Tarot 680pro

226. Tarot 690

227. Tarot 900

228. Tarot 960

229. Tarot T-15 or Tarot T15 C/F Folding Octocopter

230. Tarot T18 UAV

231. Tarot T810

232. Tarsier Systems MoAC

233. Tayzu Robotics Titan X8

234. Team Black Sheep Discovery Pro or TBS Discovery Pro

235. T-Rex 700E F3C

236. TREX 800E DFC PRO

237. Trimble UX5

238. Trimble UX5 hp

239. Trimble ZX5

240. Turnigy Talon 500

241. TUP X8-800

242. Turbo Ace CINEWING 6

243. TurboAce Matrix-G quadcopter

244. Turbo Ace matrix-E

245. Turbo Ace MATRIX-1

246. UAV Solutions Phoenix 60

247. Universeye Penguin

248. Unmanned Flying Rolling Orb “UFRO”

249. US2 GreenHawk

250. VA03-v1

251. VA04-v1

252. VA07-v1

253. Viking UAS Multicopter (VTOL)

254. Viking UAS FF-X4/X8 or VK-Patriot X4/X8 or Viking VK-FF-X4

255. VK-Patriot X4/X8
35

256. Viking UAS Patriot X4/X8 Multirotor

257. Viking UAS X6 Model 800

258. Viking UAS Viking ONE

259. VK-450

260. Viking Unmanned Aerial Systems, LLC AgriView VK Ranger EX

261. Viking VK-FF-X4

262. Volantex Raptor

263. Volt Aerial Robotics Octane

264. Vulcan frame controlled by a DJI A2 flight controller

265. Vulcan Mantis

266. Vulcan Raven

267. Walkera TALI H500 or Tali 500

268. Walkera Scout X4 or Scout X4

269. Wookong DJI 5800

270. xCel Drones XD550CDR

271. xFold Cinema

272. XFold Rig with four configurations: Quadcopter, Hexcopter, Octocopter and 

x12 Copter
36

Attachment 2

1. A2Tech RV-02

2. Adaptive Flight, Inc. Hornet Maxi

3. Advanced UAV Technology AT-100

4. Aero Composites Innovations R^2 / AS 20

5. Aero Composites Innovations V 250

6. Aerocon Inspector-201

7. Aerocon Inspector-301

8. Aeroland UAV, Inc. AL-4

9. Aeronautics Defense Systems Orbiter I

10. Aeronautics Defense Systems Orbiter II

11. AeroTactix Ltd. Skyzer 100

12. AeroTactix Ltd. Skyzer 450

13. Aerotekniikka UAV Oy M-011

14. Aeroterrascan Indonesia Ai-450

15. AeroVironment RQ-11A Raven

16. AeroVironment RQ-11B Raven

17. AeroVironment RQ-14A DragonEye

18. AGX Tecnologia Ltda Tiriba

19. AiDrones, GmbH AiD-H14

20. Airbus Defence and Space DVF 2000 (aka CARD)

21. Airbus Defence and Space Tracker (formerly DRAC)

22. Albatross Applied Aeronautics

23. Alcore Technologies Azimut 2

24. Alcore Technologies Biodrone

25. Allied Drones AW1 EOS

26. Alpha Unmanned Systems Commando

27. Alpi Aviation Strix

28. Altavian, Inc. Condor

29. Altavian, Inc. Nova Block III

30. Applewhite Aero Jago B

31. Applewhite Aero MILO

32. Applied Research, Inc. Mantra Bihrle

33. ARCTURUS UAV T-15e (JUMP 15)

34. AttoPilot, LLC Devil Ray

35. AttoPilot, LLC Jackaroo

36. AttoPilot, LLC Mini Devil Ray

37. AttoPilot, LLC. Foamaroo

38. Aurora Flight Sciences Corporation Skate SUAS

39. Aurora Integrated Systems Urban View

40. Autonomous Flight Technologies HIRRUS

41. Baykar Makina Malazgirt

42. Beijing Always Flying Technology Co., Ltd Free Bird
37

43. Beijing Always Flying Technology Co., Ltd Single Soldier I

44. Beijing Chunyi Aviation Technology Co., Ltd. CY-01H Huaying

45. Beijing Chunyi Aviation Technology Co., Ltd. CY-01V Huaying

46. Beijing Chunyi Aviation Technology Co., Ltd. CY-04 Raven

47. Beijing Creaton Tech Co., Ltd.T10 Hornet

48. Beijing Creaton Tech Co., Ltd.T10S

49. Beijing Creaton Tech Co., Ltd.T15

50. Beijing Creaton Tech Co., Ltd.T20

51. Beijing Creaton Tech Co., Ltd.T-EZ

52. Beijing Pilotless UAV Technology Co., Ltd PLT05.

53. BlueBird Aero Systems MicroB

54. BlueBird Aero Systems SpyLite

55. BlueBird Aero Systems WanderB

56. Bonn Hungary Electronics Ltd. BXAP15

57. Bormatec MAJA

58. BOSH Technologies Condor/Condor A

59. BOSH Technologies Swiper

60. Brandebury Tool Company, Inc. Scythe

61. Brican Flight Systems, Inc. TD100E

62. Brock Technologies, Inc. BT20 EEL

63. Brock Technologies, Inc. SPEAR

64. Carbon-Based Technology, Inc. Avian

65. C-ASTRAL, Inc. Bramor C4EYE

66. CATUAV Argos Electric

67. CATUAV Atmos-6

68. Chuguev Aircraft Repair Plant Strepet-LK

69. CiS GmbH Ikarus

70. Codarra Advanced Systems AVATAR

71. Composites Technology Research Malaysia Sdn. Bhd ALUDRA SR-08

72. Cranfield Aerospace Cassius

73. CyberFlight CyberEye I

74. CyberFlight E-Swift Eye

75. CyberFlight Zygo

76. Defence Research and Development Organisation Imperial Eagle

77. Defence Research and Development Organisation Slybird A

78. Defence Research and Development Organisation Slybird B

79. Delair-Tech DT-26

80. Dragonfly Pictures, Inc.DP-6XT Whisper

81. Drone America, Inc. Muninn

82. Drone Aviation Corp WATT-200

83. DroneMetrex Pty, Ltd.TopoDrone-100

84. Dronetech, LLC.AV-2 Pelican

85. Dutch Space BV Man-Portable Aerial Terrain Explorer (MATE)

86. Echar 20A XMobots Robotics Systems
38

87. Ejercito de Chile Lascar

88. Elbit Systems Skylark 1-LE

89. ELIMCO E100

90. ELIMCO E200 Scan

91. ELIMCO E300 Viewer

92. Embention W200

93. ENICS JSC T10E "Eleron-10"

94. ENICS JSC T23E "Eleron-3"

95. EXPACE SHEPHERD

96. EXPACE SHEPHERD-MIL

97. Falcon UAV Falcon UAV

98. Fiberflight Systems S.L.Victor Mk II

99. Fiberflight Systems S.L.Victor Mk III

100. Fibre Flight Ltd. SENTINEL

101. Flying Production, Ltd.Da Vinci

102. Fly-N-Sense Seeker 1300

103. FlyTop Srl FlyMax

104. FlyTop Srl FlySecur

105. Fuji Imvac Inc. D-5

106. GeoScan GeoScan 101

107. GeoScan GeoScan 201

108. GeoScan GeoScan 401

109. Global Flight Systems Eos-alpha

110. Global Flight Systems Eos-beta

111. Global Teknik Havacilik GLOBIHA

112. GreenX Bald Eagle

113. Guangzhou Walkera Technology Co. LTD QR X800

114. Guided Systems Technologies, Inc.SiCX-12

115. Hanseatic Aviation Solutions GmbH S180Mk.2

116. Hawkeye UAV RQ-84Z AreoHawk

117. Hobby UAV Techpod

118. Autels Aerial Technologies KIWITWide

119. Ideon BSK Defense

120. IDETEC Unmanned Systems Stardust II

121. IDS Ingegneria Dei Sistemi S.p.A. IA-17C Manta

122. INDRA SISTEMAS SA Mantis

123. Ingenieurgesellschaft ALADIN EMT

124. Innocon MicroFalcon LP

125. Innocon Spider

126. Instytut Techniczny Wojsk Lotniczych Nietoperz-3L (Bat-3L)

127. Integrated Dynamics Spirit

128. Irkut Irkut-2M

129. Irkut Irkut-3

130. Israel Aerospace Industries Bird Eye 400
39

131. Israel Aerospace Industries Bird Eye 650

132. Kadet Defence Systems FireBee

133. KWT-X6L

134. Lockheed Martin Corporation Stalker

135. Lockheed Martin Corporation Stalker XE (eXtreme Endurance)

136. Luch Design Bureau / KB Lutch Swallow

137. Marcus UAV Zephyr 2

138. Maryland Aerospace, Inc.VectorWing 100

139. MAVTech Microhawk MH850

140. Mission Technology Systems, LLC. Blacklight (E-BUSTER)

141. MKU Pvt. Ltd. TERP-2

142. NELK Lapwing

143. Northern Virginia OmniVersatile Solutions NVOS UAV (N-Cognito)

144. Nostromo Defensa Cabure

145. Nostromo Defensa Centinela

146. Nostromo Defensa Yagua

147. OJSC Grusha Izhmash

148. OM UAV Systems Baaz

149. Optimum Solutions Condor 300

150. Oto Melara SPA Oto-Horus

151. Patria Oy MASS Mini-UAV

152. QuestUAV Ltd.QuestUAV 300

153. Raytheon Company Coyote

154. Reference Technologies, Inc. HUMMINGBIRD I

155. RoboFlight Systems, Inc.RF70

156. Robota, LLC. Supernova

157. Robota, LLC. Triton

158. Rotomotion, LLC SR 20

159. RP Flight Systems Spectra SkyCamo

160. Santos Lab Orbis

161. Selex ES S.p.A Crex-B

162. Sensintel Silver Fox

163. Sierra Pacific Innocations E2 Micro-UAV

164. Silent Falcon UAS Technologies Silent Falcon

165. Singapore Technologies Aerospace Skyblade III

166. Siralab Robotics S.r.l. H3

167. Skycam UAV NZ Limited Kahu

168. SmartPlanes AB Personal Area Mapping System (PAMS)

169. SmartPlanes AB SmartOneC

170. Surveillance and Target Unmanned Aircraft Stingray

171. Surveillance and Target Unmanned Aircraft Stingray

172. SurVoyeur mk-II

173. Swallow Systems Skimmer MK-I

174. Swallow Systems Skimmer MK-II
40

175. System Consultancy Services AGAS 2.0

176. Tasuma (UK) Ltd. CSV-15

177. Tasuma (UK) Ltd. Hawkeye II

178. Tasuma (UK) Ltd. Hawkeye III

179. TATA Advanced Systems Limited Aquilon

180. TEKEVER AR1 Blue Ray

181. TEKEVER AR2 Carcará (formerly AR2 Power Ray)

182. TEKEVER AR4 Light Ray

183. Threod Systems, Ltd. EOS

184. Threod Systems, Ltd. X8

185. Top I Vision Casper 250

186. Trigger Composites Pteryx

187. UAS Europe AB Spy Owl 100

188. UAS Europe AB Spy Owl 200 (formerly mX-Sight)

189. UAV Factory, Ltd. Penguin BE

190. UAV Inc. E950 Challis Heliplane

191. UAV Research Lab. Silhouette

192. UAV Solutions, Inc. Talon 120

193. UAVision WINGO S

194. Uconsystem RemoEye-002B

195. Uconsystem RemoEye-006

196. Ukrspecexport Sokil-2

197. Universal Target Systems Ltd Vigilant (Spotter)

198. University of Colorado at Boulder DataHawk

199. Unmanned Systems Pioneer

200. Unmanned Systems Supercam S350 / Photobot

201. Utah State University Minion

202. Utah State University Titan

203. UTC Aerospace Systems Option

204. UTC Aerospace Systems Vireo

205. Vestel Defence Industries EFE

206. Volt Aerial Robotics WaveSight

207. VTOL Technologies Urban Eagle

208. WB Electronics S.A.FlyEye

209. Wide Autels Aerial Technologies

210. Wildau Bully/ATISS TFH

211. Wuhan AI Bird UAV Co., Ltd KC-09

212. Wuhan AI Bird UAV Co., Ltd KC-1600 Sky Hawk

213. Xi'an ASN Technology Group ASN-217

214. Zala Aero Group ZALA 421-04M

215. Zala Aero Group ZALA 421-04M2F

216. Zala Aero Group ZALA 421-08

217. Zala Aero Group ZALA 421-08M / ZALA 421-08F

218. Zala Aero Group ZALA 421-16E
40

219. Zala Aero Group ZALA 421-16EM

220. Zero UAV (Beijing) Intelligence Technology Co. Ltd. ZERO1600
41

Appendix B
42
43
44
45
46