Date August 17, 2015

Petitioner

Name Joel Williams

UAS Operating Parameters 

The petitioner states that he will abide by the following additional operating conditions under this 

exemption: 

• operate his UAS below 400 feet and within a radius distance of 1000 feet from the controller 

to both aid in direct line of sight visual observation;

• maintain a safe stand-off distance to structures (30 feet) and non-participating observers 

(150 feet).

• operate the UAS for no more than 15 minutes per flight; 

• operate his UAS only within visual line of sight (VLOS) of himself and/or visual observer 

(VO);

• land his UAS prior to the consumption of 80% of rated battery capacity as measured by 

onboard sensors;

• enable automated safety features to alert the PIC to low battery levels beginning at 60% 

consumption and initiating automated landing procedures at 70% consumption;

• install and calibrate a global positioning system (GPS) in accordance with the flight controller 

manufacturer’s recommendations to enable flight safety features whereby the UA will 

automatically hover and then slowly descend and land if communication with the remote 

control pilot is lost; 

• conduct all operations under his own personal and flight safety protocols (including posting a 

warning sign reading: “Attention Aerial Photography in Progress – Remain Back 150 feet”) 

contained in the operating documents and will actively analyze flight data and other sources 

of information to constantly update and enhance his safety protocols; 

• contact respective airports if operations will be within 5 miles to advise them of his estimated 

flight time, flight duration, elevation of flight and other pertinent information; 

• always obtain all necessary permissions prior to operation; and 

• have procedures in place to abort flights in the event of safety breaches or potential danger. 
Petitioner states that § 91.7(a) prohibits the operation of an aircraft without an airworthiness 

certificate. The petitioner asserts that since there is currently no certificate applicable to his 

operation, this regulation is inapplicable. Petitioner states that § 91.9(b)(2) requires an aircraft flight 

manual in the aircraft, however since there are no pilots or passengers on board his aircraft and 

given its size, this regulation is inapplicable. He further indicates an equivalent level of safety will be 

achieved by maintaining a safety/flight manual with the UAS ground station.

Petitioner states that § 91.119 prescribes safe altitudes for the operation of civil aircraft, but that it 

allows helicopters to be operated at lower altitudes in certain conditions. Petitioner states he will not 

operate his UAS above the altitude of 400 feet above ground level (AGL), and will also only operate 

in safe areas away from the public and traffic, thus providing a level of safety at least equivalent to 

those in relation to minimum safe altitudes. The petitioner asserts that given the size, weight, 

maneuverability, and speed of his UAS, an equivalent or higher level of safety will be achieved. 

Petitioner indicates that § 91.121 Altimeter settings is inapplicable since he UAS utilizes electronic 

GPS with a barometric sensor.