U.S. Department of Transportation

Docket Management System

1200 New Jersey Ave., SE 

Washington DC 20590

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

Regulationsfrom: 14 CFR 21 subpart H; 14 CFR 45.23(b); 14 CFR 61.113(a) and (b); 14 CFR 91.7(a); 14 CFR

91.9(b)(2); 14 CFR 91.103; 14 CFR 91.109; 14 CFR 91.119(c); 14 CFR 91.121; 14 CFR 91.151(a); 14 CFR 91.203 (a) and (b);

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

Dear Sir or Madam:

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the “Reform Act”) and 14 CFR Part 11, Olympic 

Aerial Solutions, LLC., operator of an Unmanned Aircraft System (UAS), hereby appliesfor an exemption from the listed

Federal Aviation Regulations(“FARs”) to allow commercial operation of its UAS, so long as such operations are conducted

within and under the conditions outlined herein or as may be established by the FAA as required by Section 333.

Name and Contact Information of Applicant:

Olympic Aerial Solutions, LLC

PO Box 2468

Sequim, WA. 98382

360.460.4200

olyaerial@gmail.com

Regulationsfrom which the exemption is requested:

14 CFR Part 21 subpart H

14 CFR 45.23 (b)

14 CFR 61.113 (a) & (b)

14 CFR 91.7 (a)

14 CFR 91.9 (b) (2)

14 CFR 91.103

14 CFR 91.109

14 CFR 91.119 (c)

14 CFR 91.121

14 CFR 91.151 (a)

14 CFR 91.203 (a) & (b)

14 CFR 91.405 (a)

14 CFR 91.407 (a) (1)

14 CFR 91.409 (a) (2)

14 CFR 91.417 (a) & (b)

Scope of Operations:

Commercial operation of an UAS, as described herein, which are equipped with camera(s) and sensors, would operate in

the following manner:

 Aerial photography and/or video for public and/or private use including real estate, architecture, land

surveying, engineering and other related professional activities.
 Aerial photography and/or video for public and/or private use including television, public events, 

cinematography and news gathering

 Aerial inspection/photography of residential/commercialstructures under contract with the owners or

local government authority.

 Aerial inspection/photography of residential/commercial utility infrastructure including but not 

limited to electrical power lines, wind turbines and cell towers.

 Aerial video/photography or providing live video feed to assist with search and rescue operationsin cases

of an emergency or natural disaster when local authorities or government has requested it by contract

or donation.

 The ability to offer training to personsindividually or belonging to both private and/or public 

organizationsthat have interestsin the use and application of a UAS for the purpose of the safe 

operation of a UAS to enhance the safety of the National Airspace System (NAS) as well as for the 

protection of the persons and property.

As detailed below, the requested exemption would permit the operation of a UAS under controlled conditionsin the

NAS that would be a) limited b) controlled c) and will provide safety enhancementsto the already safe operationsin the

industry presently using conventional aircraft. Approval of this exemption would thereby enhance safety and fulfill the

Secretary of Transportation’s(the FAA Administrator’s)responsibilitiesto “....establish requirementsfor the safe

operation of such aircraft systems in the national airspace system.

 UAS to be Used

Olympic Aerial Solutions, LLC will operate the DJI Phantom series of remote control model aircraft. Specifically the 

Phantom 1 v.1.1.1, Phantom 2 Vision +, and Phantom 3 Advanced/Pro. (Note: All Phantom models are based upon the same 

airframe and control technology with similar specifications and performance.) And, the DJI Inspire 1.

UAS Model Specifications

Phantom 1 Phant. 2 Vision + Phantom 3 Inspire 1

Weight (w/ Batt. And Props) 1250g 1242g 1280 g 2935 g

Diagonal Size (motor-motor) 350mm 350mm 350mm 581 mm

Max Ascent Speed 6m/s 6m/s 5 m/s 5 m/s

Max Descent Speed 6m/s 2m/s 3 m/s 4 m/s

Max Speed 10m/s 15m/s 16 m/s 22 m/s

Operating Temperature 0°C-50°C 0°C-40°C 0°C - 40°C 0°C - 40°C

Operating Freq. Band 2.4 GHz 5.8 GHz 2.4 GHz 2.4 GHz

Battery 2200 mAh 5200 mAh 4480 mAh 4500 mAh

 

Manufacturers Operating Manuals:

Phantom 1 v.1.1.1 Manual 

 http://download.dji-innovations.com/downloads/phantom/en/PHANTOM_Advanced_Manual_en.pdf

Phantom 2 Vision + Manual

 http://download.djiinnovations.com/downloads/phantom_2_vision_plus/en/Phantom_2_Vision_Plus_User_Manual_v1.8_en.pdf

Phantom 3 Advanced/Pro Manual

 http://download.dji-innovations.com/downloads/phantom_3/jp/Phantom_3_Professional_User_Manual_v1.0_jp.pdf

Inspire 1 Manual

 http://download.dji-innovations.com/downloads/inspire_1/en/Inspire_1_User_Manual_v1.2_en.pdf
National Security

The small size of these UAS and the limited scale of operations in conjunction with adherence to the Reform Act’s safety

requirements present no national security issues.

Public Interest

Services utilizing small UAS for aerial photography, videography, surveying, mapping, equipment inspections and 

auditing provides a much lower cost and higher level of safety to the public due to the small scale of aircraft relative to 

full scale aircraft operations.

 Operational Safety

 The UAS will not be operated at a speed exceeding 50 mph.

 The UASwill be operated at an altitude of no more than 400 feet above ground level (AGL). 

 The UAS will be operated within visual line of sight (VLOS) of the PIC at all times. This requires the PIC to be able to use 

human vision unaided by any device other than corrective lenses, as specified on the PIC’s FAA-issued airman medical 

certificate or U.S. driver’s license.

 All operations must utilize a visual observer (VO). The UA must be operated within the visual line of sight (VLOS) of the PIC 

and VO at all times.

 The operator is responsible for maintaining and inspecting the UAS to ensure that it isin a condition for safe operation.

 Prior to each flight, the PIC must conduct a pre-flight inspection and determine the UAS is in a condition for safe flight.

 PIC will hold either an airline transport, commercial, private, recreational, or sport pilot certificate. The PIC will also hold a 

current FAA airman medical certificate or a valid U.S. driver’s license issued by a state, the District of 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.

 No operations will be conducted at night, as defined in 14 CFR § 1.1. All operations will be conducted under visual 

meteorological conditions (VMC).

 No operations will be conducted within 5 nautical miles of an airport reference point (ARP) as denoted in the current FAA 

Airport/Facility Directory (AFD) or for airports not denoted with an ARP, the center of the airport symbol as denoted on the 

current FAA-published aeronautical chart, unless a letter of agreement with that airport’s management is obtained or 

otherwise permitted by a COA issued to the exemption holder.

 All operations shall be conducted over private or controlled-access property with permission from the property 

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

will be obtained for each flight to be conducted.
 14 C.F.R. Part 21, Subpart H: Airworthiness Certificates 14 C.F.R. §91.203 (a) (1)

Subpart H, entitled Airworthiness Certificates, establishesthe procedural requirementsfor the issuance of 

airworthiness certificates as required by FAR §91.203 (a) (1). Given the size and limited operating area associated

with the aircraft to be utilized by the Applicant, an exemption from Part 21 Subpart H meets the requirements of an

equivalent level ofsafety under Part 11 and Section 333 of the Reform Act. The Federal Aviation Act (49

U.S.C.§44701 (f)) and Section 333 of the Reform Act both authorize the FAA to exempt aircraft from the

requirementfor an airworthiness certificate, upon consideration of the size, weight, speed, operational capability,

and proximity to airports and populated areas of the particular UAS. In all cases, an analysis of these criteria

demonstratesthat the UAS operated without an airworthiness certificate, in the restricted environment and under

the conditions proposed will be at least as safe, or safer, than a conventional aircraft (fixed wing or rotorcraft)

operating with an airworthiness certificate without the restrictions and conditions proposed.

The UAS to be operated hereunder is less than 55 lbs. fully loaded, carries neither a pilot nor passenger, carries no

explosive materials or flammable liquid fuels, and operates exclusively within a secured and designated area. Unlike

other civil aircraft, operations under this exemption will be tightly controlled and monitored by both the operator and

under the requirements and in compliance with local public safety requirements. These safety enhancements provide a

greater degree ofsafety to the public and property owners than conventional operations conducted with airworthiness

certificatesissued under 14 C.F.R. Part 21, Subpart H.

Lastly, application of these same criteria demonstratesthat there is no credible threat to national security posed by the

UAS, due to its size, speed of operation, location of operation, lack of explosive materials or flammable liquid fuels, and

inability to carry a substantial external load.

14 C.F.R. § 45.23 (b). Marking of the Aircraft

The regulation requires:

When marksinclude only the Roman capital letter "N" and the registration number is displayed on limited, restricted

or light-sport category aircraft or experimental or provisionally certificated aircraft, the operator must also display on

that aircraft near each entrance to the cabin, cockpit, or pilot station, in letters not less than 2 inches nor more than 6 

inches high, the words "limited," "restricted," "light-sport," "experimental," or "provisional," as applicable.

Even though the UAS will have no airworthiness certificate, an exemption may be needed as the UAS will have no

entrance to the cabin, cockpit or pilotstation on which the word “Experimental” can be placed. Given the size of

the UAS, two-inch lettering will be impossible. The word “Experimental” will be placed on the fuselage in

compliance with §45.29 (f).

The equivalentlevel of safety will be provided by having the UAS marked on itsfuselage asrequired by

§45.29 (f) where the pilot, observer and others working with the UAS will see the identification of the UAS as

“Experimental.”

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

Pursuant to 14 CFR 61.113 (a) & (b), no person who holds a private pilot certificate may act as a pilot in command of an 

aircraft that is carrying passengers or property for compensation or hire. V-Tail Aviation Inc. may achieve an equivalent

level of safety as achieved by current Regulations because the applicant’s UAS do not carry any pilots or passengers nor

property. The risks attendant to the operation of UAS is far less than the risk levels inherent in the commercial activities

outlined in 14 CFR 61. The PIC of the UAS will have a Commercial Pilot’s License along with a current Third Class or higher

Medical exceeding the current safety levels in relation to 14 CFR 61.113 (a) & (b). I feel the operation and limitations set

forth in the FOM will equate to the safe operation of the UAS.
14 C.F.R. §91.7(a): Civil Aircraft Airworthiness.

The regulation requiresthat no person may operate a civil aircraft unlessit is in airworthy condition. As there will be

no airworthiness certificate issued for the aircraft, should this exemption be granted, no FAA regulatory standard will

exist for determining airworthiness. Given the size of the aircraft for maintenance and use of safety check lists prior to

each flight an equivalentlevel of safety will be provided.

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

Section 91.9 (b) (2) provides: No person may operate a U.S.-registered civil aircraft ... (2) For which an Airplane or

Rotorcraft Flight Manual is not required by §21.5 of this chapter, unless there is available in the aircraft a current

approved airplane or Rotorcraft Flight Manual, approved manual material, markings, and placards, or any

combination thereof. The UAS, given its size and configuration has no ability or place to

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

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

manual at the ground control point where the pilot flying the UAS will have immediate access to it.

14 C.F.R. § 91.103: Preflight Action.

This regulation requires each pilot in command to take certain actions before flight to insure the safety of flight. As

FAA approved rotorcraftflight manuals will not be provided for the aircraft an exemption will be needed. The PIC will

take all actions as stated in the manufactures operating manuals.

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

Section 91.103 providesthat no person may operate a civil aircraft (except a manned free balloon) that is being used

for flight instruction unlessthat aircraft hasfully functioning dual controls. UAS and remotely piloted aircraft, by their

design do not have fully functional dual controls. Flight control is accomplished through the use of a control box that

communicates with the aircraft via radio communications. The FAA has approved exemptionsfor flight training

without fully functional dual controlsfor a number of aircraft and for flight instruction in experimental aircraft. The

equivalent level of safety is provided by the fact that neither a pilot nor passengers will be carried in the aircraft and

by the small size and low speed of the aircraft.

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

Section 91.119 establishes safe altitudesfor operation of civil aircraft. Section 91.119 (d) allows helicopters to be operated

at less than the minimums prescribed, provided the person operating the helicopter complies with any route or altitudes

prescribed for helicopters by the FAA. As this exemption is for a UAS that is a helicopter and the exemption requests

authority to operate at altitudes up to 400 AGL, or not more than 200 above an elevated platform from which filming is

planned, an exemption may be needed to allow such operations. As set forth herein, the UAS will never operate at higher

than 400 AGL with the exception that in circumstances where the UAS is used to survey or photograph a structure whose

height exceeds 400 feet AGL, the UAS will not be operated more than 200 feet above the highest point on the structure. It

will however be operated in a restricted area with security perimeter, where buildings and people will not be exposed to

operations without their pre-obtained consent.

The equivalentlevel of safety will be achieved given the size, weight, speed of the UAS as well as the location where it 

is operated. No flight will be taken without the permission of the property owner or local officials. Because of the

advance notice to the property owner and participantsin any operational activity, all affected individuals will be aware

of the planned flight operations. Compared to flight operations with aircraft or rotorcraft weighting far more than the

maximum 55lbs. proposed herein and the lack of flammable fuel, any risk associated with these operationsis far less

than those presently presented with conventional aircraft operating at or below 500 AGL. In addition, the low-altitude

operations of the UAS will ensure separation between these UAS operations and the operations of conventional

aircraft that must comply with Section

91.119.
14 C.F.R. §91.121 Altimeter Settings.

This regulation requires each person operating an aircraft to maintain cruising altitude by reference to an altimeter that is

set “...to the elevation of the departure airport or an appropriate altimeter setting available before departure.” As the UAS

may not have a barometric altimeter, but instead a GPS altitude read out, an exemption may be needed. An equivalent

level of safety will be achieved by the operator, pursuant to the safety check list and live flight data monitoring, confirming

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

14 C.F.R. § 91.151(a): Fuel Requirementsfor Flight in VFR Conditions

Section 91.151 (a) prohibits an individual from beginning “a flight in an airplane under VFR conditions unless 

(considering wind and forecast weather conditions) there is enough fuel to fly to the first point of intended landing,

and, assuming normal cruising speed – (1) During the day, to fly after that for at least 30 minutes; or (2) At night, to fly

after that for at least 45 minutes.”

The battery powering the UAS provides approximately 30 minutes of powered flight. To meet the 30 minute reserve

requirementin 14 CFR §91.151, UAS flights would be limited to approximately 10 minutesin length. Given the limitations

on the UAS’s proposed flight area and the location of its proposed operations within a predetermined area, a longer time

frame for flight in daylight or twilight VFR conditionsisreasonable. Applicant believesthat an exemption from 14 CFR 

§91.151(a) falls within the scope of prior exemptions. Operating the UAS, in a tightly controlled area where only people and

property owners or official representatives who have signed waivers will be allowed, with less than 30 minutes of reserve

fuel, does not engender the type of risks that Section 91.151(a) was intended to alleviate given the size and speed of the 

small UAS. Additionally, limiting UAS flights to 10 minutes would greatly reduce the utility for which the exemption will be

granted. Applicant believesthat an equivalent level of safety can be achieved by limiting flights to 30 minutes or 25% of

battery power— whichever happensfirst. Thisrestriction would be more than adequate to return the UAS to its planned

landing zone from anywhere in itslimited operating area.

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

The regulation providesin pertinent part:

(a) Except as provided in § 91.715, no person may operate a civil aircraft unless it has within it the following: (1) An

appropriate and current airworthiness certificate. . . .

(b) No person may operate a civil aircraft unless the airworthiness certificate required by paragraph (a) of this section

or a special flight authorization issued under §91.715 is displayed at the cabin or cockpit entrance so that it is legible

to passengers or crew.

The UAS fully loaded weighs no more than 55 lbs. and is operated without an onboard pilot. As such, there is no

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

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

pilot flying the UAS will have immediate access to them; to the extent they are applicable to the UAS.

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

These regulationsrequire that an aircraft operator or owner “shall have that aircraft inspected as prescribed in

subpart E of this part and shall between required inspections, except as provided in paragraph (c) of this section,

have discrepanciesrepaired as prescribed in part 43 of this chapter...,” and others shall inspect or maintain the

aircraft in compliance with Part 43. Given that these section and Part 43 apply only to aircraft with an airworthiness

certificate, these sections will not apply to the applicant. Maintenance will be accomplished by the operator

pursuant to the flight manual and operating handbook. An equivalent level of safety will be achieved because the

UAS is very limited in size and will carry a small payload and operate only in restricted areas for a limited period of

time. If mechanical issues arise the UAS can land immediately and will be operating from no higher than 400 feet

AGL. The operator will ensure that the UAS is in working order prior to initiating flight, perform required

maintenance, and keep a log of any maintenance performed. Moreover, the operator is the person most familiar

with the aircraft and best suited to maintain the aircraft in an airworthy condition to provide the equivalent level of

safety. An equivalentlevel of safety will be achieved because maintenance and inspections will be performed in
accordance with the UAS Manufacturer'sUser Manual. As provided in the FOM, the operator will ensure that the

UAS is in working order prior to initiating flight and perform required maintenance needed.

This application for exemption respectfully submitted by:

Olympic Aerial Solutions, LLC

 PO Box 2468

 Sequim, WA. 98382

 360.460.4200

 olyaerial@gmail.com

 David Pitman

 Managing Member,