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09/09/2015

Nathaniel Sean Johnson

Magna Electronics Inc.

2050 Auburn Road

Auburn Hills, MI 48326 USA

nate.johnson@magna.com

248-696-6492

09/09/2015

Attention: 

U.S. Department of Transportation

Docket Management System 

1200 New Jersey Ave., SE 

Washington DC 20590

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

Regulations from: 14 CFR Part 21 subpart H; 14 CFR 45.23 (b); 14 CFR 61.113; 14 CFR 61.133; 14; 14 CFR 

91.7 (a); 14 CFR 91.9 (b) (2); 14 CFR 91.103; 14 CFR 91.109; 14 CFR 91.119; 14 CFR 91.121; 14 CFR 

91.151; 14 CFR 91.203 (a) and (b); 14 CFR 91.405 (a); 14 CFR 91.407 (a) (1); 14 CFR 91.409 (a) (2); 14 CFR 

91.417 (a) and (b), FAA 8900.227 Paragraph 16 (c) (4) PIC Medical and Paragraph 16 (e) (l) Observer 

Medical

To whom it may concern:

I am writing in regards to the FAA Modernization and the FAA Reform Act and the procedures contained 

in 14 C.F.R. 11, to request that Magna Electronics Inc. be exempted from the Federal Aviation 

Regulations ("FARs") listed below so that it may operate its small unmanned aircraft / lightweight 

unmanned aircraft systems ("UAS") commercially in airspace regulated by the Federal Aviation 

Administration so long as such operations are conducted within and under the conditions outlined 

herein by the FAA as required by Section 333. Magna Electronics Inc.’s exemption request would permit 

its operation of lightweight, unmanned (remotely controlled in line of sight) UASs in tightly controlled 

and limited airspace.

As Magna is a Tier 1 automotive manufacturing company, the purpose of drone operation is to record 

media of Magna’s products. This will include collecting test data at proving grounds and creating 

promotional material. Thus, Magna Electronics Inc. respectfully requests the grant of an exemption 

allowing it to operate lightweight, remote controlled UAS's.

The Specific Sections of Title 14 of the Code of Federal Regulations, Magna Electronics Inc. requests 

exemptions are:

14 CFR Part 21 subpart H

The UAS to be operated carries neither pilot nor passenger and carries no explosive materials or 

flammable liquids. Given the size, weight, speed, and limited operating area associated with the aircraft 

to be utilized, we request exception. In the restricted environment and under the conditions proposed 

operation will be at least as safe, or safer, than a conventional aircraft operating with an airworthiness 

certificate without said restrictions.

14 CFR 45.23 (b)
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Due to the size of this UAS it does not have a cockpit, cabin, or pilot station on which to mark certain 

words or phrases. Due to the size of the craft we do not expect to write any information on it.

14 CFR 61.113 Private pilot privileges and limitations: Pilot in Command and 14 CFR 61.133 

Commercial pilot privileges and limitations

There are no means available for the pilot of a UAS to gain the experience in an equivalent category and 

class in order to apply for a commercial pilot's license. Since the aircraft cannot carry passengers or 

property, we feel we meet the intent of 61.113 Subparagraph (b) even though the intent of this 

application is to conduct business.

14 CFR 91.7 (a)

As there will be no airworthiness certificate for the aircraft, should this exemption be granted, no FAA 

regulatory standard will exist for determining airworthiness. Given the size of the aircraft for 

maintenance and use of safety, check list prior to each flight or an equivalent level of safety will be 

conducted.

14 CFR 91.9 (b) (2)

Given the size and configuration, the UAS has no ability to carry a flight manual on the aircraft. There is 

no room, capacity, or pilot on board to adequately carry flight manual. An equivalent level of safety will 

be maintained by keeping the flight manual at ground control point where the pilot will have immediate 

access to it.

14 CFR 91.103

As FAA approved flight manuals will not be provided for the aircraft an exemption will be needed. The 

Pilot In Command (PIC) will take all actions under normal procedures including but not limited to; 

reviewing weather, flight battery requirement, and landing and takeoff distances. An equivalent level of 

safety will be provided by preflight protocol to properly match the machine.

14 CFR 91.109

UAS and remotely piloted aircraft do not have fully functional dual controls. Flight control is achieved 

through the use of a control box that communicates with the aircraft via radio communications. The 

equivalent level of safety provided because neither a pilot nor passenger will be carried in the aircraft, 

and by the speed and size of the aircraft.

14 CFR 91.119

Since the UAS will be operating at a maximum of 400 feet Above Ground level (AGL), we cannot comply 

with this requirement. The UAS will be operated at a low altitude allowing, if a power unit fails, an 

emergency landing without undue hazard to persons or property on the surface. Therefore we maintain 

that due to the small size of the UAS, the hazard to persons, vehicles and structures is minimal 

compared to manned aircraft, which should be considered in granting the exemption.
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14 CFR 91.121

The UAS may not have a barometric altimeter, but instead does have a GPS altitude read out. An 

equivalent level of safety is achieve by the operator receiving live flight data monitoring and confirming 

current altitude along with altitude of launch site shown on GPS altitude indicator. 

14 CFR 91.151

The UAS will not travel so far from the take off point that it cannot return before the battery reaches its 

reserve. The word “fuel” should be replaced with the word “energy” in this case.

14 CFR 91.203 (a) and (b)

Similar to, 14 CFR 91.9 (b) (2), given the size and configuration, the UAS has no ability to carry certificate 

and registration documents on the aircraft. There is no room, capacity, or pilot on board to adequately 

contain such documents. An equivalent level of safety will be achieved by keeping these documents at 

the ground control point where pilot has immediate access to them, to the extent they are applicable to 

the UAS.

14 CFR 91.405 (a), 14 CFR 91.407 (a) (1), 14 CFR 91.409 (a) (2), 14 CFR 91.417 (a) and (b)

Given these sections only apply to aircraft with an airworthiness certificate, theses sections do not 

apply. As a safety precaution, operator will perform preflight inspections and ensure UAS is in working 

condition before initiating each flight.

FAA 8900.227 Paragraph 16 (c) (4) PIC Medical and Paragraph 16 (e) (l) Observer Medical

This policy provides that both the PIC and Visual Observer (VO) must have a valid FAA second class 

medical certificate in order to perform as a pilot or observer. Both the PIC and the VO are required to be 

in Visual Line Of Sight (VLOS). Given the unlikely event that both the PIC and VO become medically 

incapacitated while the aircraft is in flight, the UAS will return autonomously to the (a predetermined 

location) site of launching and land without crew intervention. Therefore, requiring the PIC and VO to 

meet the same medical requirements as a commercial pilot who is carrying passengers in a large aircraft 

is an unnecessary burden. We propose that the minimum medical requirements for the PIC and VO be 

vision corrected to 20/20. The 20/20 vision requirement will ensure that the PIC and VO can see and 

avoid air traffic.

AIRCRAFT AND EQUIVALENT LEVEL OF SAFETY

The operation limitations proposed for an equivalent or higher level of safety because operations will 

further enhance the safety of the persons and/or property using conventional aircraft. These limitations 

and conditions to which the applicant agrees to adhere to when conducting commercial operations 

under the FAA include: 

 The UAS will weigh less than 55 lbs. 

 The UAS will have a maximum operating speed of no more than 70mph. 
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 Flights will be operated within line of sight of the Pilot in Command (PIC) and Visual Observer (VO). 

 Flights will be operated at an altitude below 400 feet Above Ground Level (AGL) and at least 100 feet 

above any elevated platform, unless the PIC or VO have access to that platform.

 Minimum crew for each operation will consist of the UAS Pilot, the Visual Observer (VO) and may 

include but not limited to a Camera Operator. 

 A briefing will be performed regarding the planned UAS operations prior to each day’s flight consisting 

of all the days’ activities. 

 The flights will occur no closer than a 5 mile radius of the geographic center/Airport Reference Point 

(ARP) of a tower controlled or uncontrolled airport. 

 If operations will be within a 5 mile radius of the geographic center/Airport Reference Point (ARP) of a 

tower controlled or uncontrolled airport the respective airports will be contacted advising them of the 

estimated flight time, flight duration, elevation of flight and other pertinent information. 

 The PIC and VO will have been trained and tested in operation of UAS and receive up-to-date 

information for the particular UAS to be operated. 

 The PIC and VO will be able to communicate by voice, radio, and/or text at all times. 

 If the UAS loses communications with the remote controller or loses GPS signal, the UAS will have the 

capability to return to a pre-determined location within a designated location and land autonomously. 

 The pilot will have the capability to abort a flight in case of unpredicted obstacles, weather, or 

emergencies.

 All flight operations will be entered into a log.

Commercial and Public Benefits:

Granting Magna Electronics Inc. exemption request furthers the public interest. First, Congress has 

already pronounced that it is in the public's interest to integrate commercially flown UASs into the 

national airspace system, hence the passing of the Reform Act. Second, Magna Electronics Inc. will 

conduct research into safe UAS operations every time it flies one of its UASs. Flight data, visual 

inspections, recorded observations and flight analyses will be compiled to further enhance current 

safety protocols. Allowing Magna Electronics Inc. to log more flight time directly relates to its research 

and its ability to further enhance current safety measures. Third, the public has an interest in reducing 

the danger and emission associated with current aerial cinematic capture methods, namely, full size 

helicopters. 

We may need to take the UAS out of the country to Canada because we have a portion of our company 

located there.(possible reword)
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09/09/2015

Thank you very much for your time and consideration of this request. Please advise us if any additional 

information is required.