C C I

An Audio Visual

Company

 

Communications 

Concepts, Inc.

7980 North Atlantic Ave.

Cape Canaveral, FL 32920

Office 321-783-5232

FAX (321) 799 1016

August 30, 2015

U.S. Department of Transportation

Docket Operations, M-30

1200 New Jersey Avenue, SE

Room W12-140, West Building Ground Floor

Washington, DC 20590-0001

Dear Sir or Madam:

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the "Reform Act") and 

14 C.F.R. Part 11, Communications Concepts, Inc. (CCI) hereby applies for an exemption from the 

Federal Aviation Regulations identified herein to allow for the commercial operation of an 

Unmanned Aircraft System (UAS) for the purposes of providing high quality aerial imaging and 

data services for a variety of commercial, public, and residential uses, so long as such operations 

are conducted within and under the conditions outlined herein or as may be established by the 

Federal Aviation Administration ("FAA").

CCI has provided expert communications, video, and photographic services since 1978 and wish 

to add efficient and low-cost aerial services to our company’s ability to continue providing highvalue services to our clients. The advancement of small, light weight, high resolution video and 

photographic cameras and equipment provides the opportunity to use ultralight and unmanned 

UAS to quickly provide these services at a much lower cost than traditional manned helicopters 

and aircraft.

The use of UASs to perform these tasks dramatically reduces costs and increases worker and 

public safety, lowers inspection costs, increases maintenance reliability of facilities and 

infrastructure and can provide better, faster, more thorough film making and inspections than 

through the use of manned aircraft. These facts, among others, provide a significant and definitive 

public benefit and are in the public interest.

A grant of our exemption request, by the FAA, would permit us to conduct flight operations in 

strict compliance and safety protocols as mandated and required by regulations and best 

practices in order to offer our services to private and government entities.

Conditions for UAS operation as described in this application are consistent with and based upon 

proposed FAA UAS regulations as outlined by the FAA on the 15th of February, 2015. Any 

additional conditions included herein have been included by Communications Concepts, Inc. to 

add to and enhance the safe operation of UASs when used for aerial videography and

utility/infrastructure inspection and management.

CCI contends that this application satisfies the conditions and criteria set forth in Section 333 of 

the Reform Act, that the operations described herein benefit the public interest as a whole in 

many ways and that the use of UASs for power line and utility inspection meets or exceeds the 

level of safety currently experienced by traditional manned aircraft utilized for these purposes. 

The applicant is thankful for the Federal Aviation Administration's time and consideration.

Respectfully yours,

James C. Lewis, Jr.

President
Communications Concepts, Inc.

Page 1

I. Regulations for which Exemption is Requested

Communications Concepts, Inc. requests exemption from the following regulations:

• Part 21, Subpart H.

• 45.23 (b)

• 45.25

• 45.27 (a)

• 45.29

• 61.113 (a) & (b)

• 61.133 (a)

• 91.7(a)

• 91.9 (b)(2) &(c)

• 91.103

• 91.105

• 91.109(a)

• 91.119

• 91.121

• 91.151 (a)(1) & (b)

• 91.203 (a) & (b)

• 91.405 (a)

• 91.407(a)(1)

• 91.409(a)(2)

• 91.417 (a) & (b)

A discussion of each FAR and the methods by with Communications Concepts, Inc. will maintain a level of 

safety equivalent to or exceeding the rules from which exemption is sought is detailed in Section VI of this 

petition.

II. Statutory Authority for Requested Exemptions

This petition for exemption is submitted in accordance with Section 333 of the Reform Act. Congress has 

directed the FAA "to safely accelerate the integration of civil unmanned aircraft systems into the national 

airspace system." Pursuant to Section 333 of the Reform Act, the FAA Administrator is to permit operation 

of an unmanned aircraft system where it does not create a hazard to users of the national airspace system 

("NAS") or the public or pose a threat to national security based on the following considerations:

• The size, weight, speed and operational capability;

• Operation in proximity to airports and populated areas; and

• Operation within visual line of sight of the operator.

Furthermore, the Federal Aviation Act grants the FAA Administrator general authority to grant exemptions 

from the agency's safety regulations and minimum standards wh1`en the Administrator decides a requested 
Communications Concepts, Inc.

Page 2

exemption is in the public interest. See 49 U.S.C. §§ 106(f), 44701-44716, et seq. A party requesting an 

exemption must explain the reasons why the exemption: (l) 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 14 C.F.R. § 11.81.

III. Communications Concepts, Inc. Background Information

Communications Concepts, Inc. (hereafter referred to as “CCI”) is an audio visual production company 

specializing in video and digital media production, training systems and documentation. Founded in 1978, 

CCI is an established Type C Florida Corporation and recognized leader in imaging in Central Florida. The 

founder, James Lewis, has logged hundreds of hours in aerial film and video production. This commercial

work has included everything from aerial documentation of most of the property in Hobe Sound, Florida 

for conversion land use to aerial production for music videos in Jacksonville, Florida to aerial survey of 

sand deposits for Port Canaveral. In the last few years, CCI has shot aerials with traditional helicopters for 

two major motion pictures (Transformers 3 and Space Brothers) and for a number of tourism destination 

videos. CCI has a perfect track record and is known for providing safe, efficient, reliable and high quality

aerial imaging services to its diverse groups of clients. 

Communications Concepts, Inc. believes utilizing Unmanned Aerial Systems (UASs) rather than manned 

aircraft will improve safety, efficiency and effectiveness for many of these applications. Because of CCI’s 

"real world" knowledge of planning and capturing aerial images and documentation, Communications 

Concepts, Inc. is well versed and prepared for safe and efficient operation of their own UASs should this 

petition be granted.

IV. Proposed Operations

Communications Concepts, Inc. is requesting exemptions from the Federal Aviation Regulations (the 

"FARs") stated herein pursuant to Section 333 of the Reform Act in order to perform Aerial video, 

photography, live feed, and other sensor operations utilizing UASs to provide high quality aerial imaging 

and data for a variety of commercial, public, and residential uses, specifically targeting:

• Aerial video/photography for motion picture and commercial filming/imaging/video recording

• Aerial video/photography to support the recording real estate listings for marketing properties

• Aerial video/photography or providing environmental and system monitoring and inspection

• Aerial mapping (photogrammetry) and video documentation, such as new and existing 

construction, transportation and utilities, land development, environmental mitigation projects, 

etc.

• Aerial video/photography or providing live video feed to support tower inspections and 

maintenance support such as aerial viewing, video recording, signal analysis, laser measurements, 
Communications Concepts, Inc.

Page 3

etc.

• Aerial video/photography or providing live video feed for assessment of other tall structures such 

as wind turbines, smoke stacks, water towers, flare stacks, etc.

• Aerial video/photography or providing live video feed to assist with search and rescue operations 

in cases of an emergency or natural disasters

• Aerial data and video transmission relay for coverage and timing of broadcast, sporting and 

special events, such as relaying video from in-car cameras at motorsports events or remote 

cameras at marathons or golf events, 

A. Operation Locations and Environments

Communications Concepts, Inc. will operate its UASs in support of aerial imaging and data collection. 

Aerial video/photography for motion picture and commercial filming/imaging/video recording. To date 

CCI has performed this type of imaging work utilizing helicopters and fixed wing aircraft. Such craft are 

often required to operate for extended periods flying redundant routes and holding positions for long 

periods of time. This places the helicopter, its occupants, and possibly the public, in potential harms way.

Use of a UAS would eliminate these concerns. The lack of occupants eliminates potential harm to the pilot, 

imaging crew and onboard observers. The small size of the UAS reduces or eliminates much of the risk to 

the public, especially when you consider a UAS also does not carry flammable fuel and does not release 

emissions.

The UASs will be controlled via radio transmission from a Ground Control Station ("GCS"), augmented by 

the UASs’ internal GPS, altimeter and gyros. All remote control equipment will be off the shelf industry 

standard devices available to both professionals and consumers and utilize FCC approved transmission and 

reception components. Much like when helicopters and aircraft have been used, a UAS flight will be 

planned and flown to comply with FAA regulations, including use of the FAA B4UFLY app when it 

becomes available. The UASs used will not violate airspace restrictions for airports or airbases, 

government facilities, National Parks, sensitive structures, and so forth. All UAS flight operations will be 

under 400 feet. This planning will assure Communications Concepts, Inc.'s UASs are operated in a safe 

and secure manner. At no time will the UASs be operated over any non-participating persons or properties. 

The flight area will be monitored by the operator with live video streaming from each UAS for any changes 

in environment or encroaching individuals.

Communications Concepts, Inc. will confer with the clients and property owners and their representatives 

regarding any known hazards or abnormal operating conditions that are pertinent to UAS operations. 

Permission from all parties involved will be obtained prior to conducting commercial flight operations 

within flight path, imaging area and vicinity.

Communications Concepts, Inc. will utilize an operator specifically trained in UAS operations for all 

commercial flights. When deemed necessary by Communications Concepts, Inc. observer(s) will be 
Communications Concepts, Inc.

Page 4

utilized for added visual coverage. They may also utilize a live video feed from the UAS to monitor the 

flight area.

Any observer will be in voice contact with the operator at all times during flight via either direct contact, 

radio or equivalent methods, depending on the optimal observer position as determined by operator and 

observer. The observer, when used, will assist the operator in identifying both air and ground hazards and 

maintaining safe operating conditions. The flight will be altered or terminated immediately should a hazard 

such as a low flying aircraft or unauthorized person in the flight area be observed by either the operator or 

observer.

UASs will be flown within a half mile line of sight radius of the operator. This reduces flight risks to very 

manageable levels. The flight area can be secured, any intruders readily spotted and flights quickly and 

safely terminated to multiple landing zones, if need be. Additionally, the UAS will not be operated over 

non-participating persons. It will remain a safe distance of all structures and will not operate higher than 

400 feet AGL.

Predetermined potential landing zones will be identified and briefed by the operator, observers and 

participating persons prior to flight. Landing zones will be selected according to proximity to obstructions, 

observed ground conditions and limited exposure to persons and property. Primary landing zone and 

launch zone will be one in the same and defined as “home”. UASs will be programmed to return home 

automatically in case of loss of signal or other anomaly. 

Aerial video/photography to support the recording real estate listings for marketing properties. 

Technically, this work is much like the imaging work CCI performs for the motion picture and commercial 

filming. In the case of video and photography of property and other real estate, flight plans will be 

performed for and coordinated with the property owner their agents. Adjacent property owners will be 

notified of the UASs filming plan prior to flight. Most flights will be relatively low level and well with 

beneath the 400 foot ceiling for UAS flight. Most requirements for real estate videos are generated by real

estate transactions and sales. Often times the cost of using traditional helicopters or other manned aircraft 

prohibitive when compared to the value of the real estate and the commissions paid on sales. The reduced 

cost of using UAS systems will allow greater use of aerial imaging that will provide for better educated 

buyers and benefit the economy and the tax base through increased real estate transactions. 

Aerial video/photography or providing environmental and system monitoring and inspection. CCI has 

already demonstrated the value quality aerial images and inspections provide based on the aerial work we 

have performed for land owners to document land usage, conditions and changes and for government 

agencies to plan for natural topography and oceanographic changes and to mitigate man-made impacts and 

conditions. Often times, this aerial work requires flying repetitive route such as track and crawl, parallel 

track and parallel sweep patterns or re-flying the same pattern over again on a regular repeated monthly or 

annual basis. This type of flying is often at low altitude which increases risks to pilot, crew and observers 

and the sound can be disturbing to people and wildlife. CCI would eliminate these risks and annoyances

with a small, safe and quiet UAS alternative which at the same time will provide highly improve data 

quality and reliability since the UAS flies on GPS based tracks and patterns which will assure accuracy and 

repeatability at a much lower cost. 

Aerial Mapping (Photogrammetry) and Video Documentation of large projects, natural disasters, and 
Communications Concepts, Inc.

Page 5

large scale emergencies. Low-level photography is far more effective than ground based imagery for 

displaying the characteristics of large, complex properties with ongoing construction, or transportation 

and/or utility corridors. Communications Concepts, Inc. as a routine part of its business have contracted 

both Helicopter and Fixed wing aircraft for this type of work. However, especially in the case of small 

projects or projects, manned aircraft prove too costly or unable to acquire data at low enough speeds or 

altitude to meet these requirements. The benefits of reduced cost and improved quality from the UAS will 

be valuable to and benefit many users of this aerial data.

Inspections and Maintenance Support of Towers and Other Tall Structures. UAS flights to achieve an 

aerial view, video recording, signal analysis, laser measurement of wireless provider antennas and lines that 

are secured to cell phone towers presents a high potential for dramatically lowering costs and increasing 

safety related to providing this service. Through mounted equipment on the UAS, we will be able to 

observe, analyze, and acquire valuable data without the risk of using a tower climber. This elimination of 

unnecessary climbs required for visual inspections, measurements, and signal analysis would result in less 

danger in making for safer working environment by reducing the frequency need to climb the towers. 

Typical servicing requires technicians to make multiple climbs up the tower before attempting any repair 

work.

Data captured from these flights will assist in determining not only the physical condition of the tower’s 

equipment, provide real-time functionality and transmission ability of the tower, and view/record open 

antenna locations on towers for potential future modifications and additions. Information gathered can 

provide indication of malfunction, damage from lightning strikes, strobe light conditions, cable condition. 

The UAS will also be used to measure signal strength and mapping of the tower’s equipment to determine 

proper functionality and/or interference created by faulty equipment.

Additionally, these towers and facilities are highly restricted areas with low potential for public bystanders 

to be in the area. The height of these structures also require the airspace in the immediate vicinity to be 

highly restricted from any and all air traffic and therefore offer a minimal likelihood of interfering with

aircraft operations.

Aerial data and video transmission relay for coverage and timing of broadcast, sporting and special 

events. Many video and data transmission systems are very directional and only work in-line of sight. For 

some events, such as television coverage of a golf event line of sight is not possible due to trees and other 

structures. Likewise, if the transmission point is moving, such as race car on a track, ground based 

reception and tracking is not dependably possible over the entire track. Until now, in those instances, CCI 

has retained a helicopter to be a reception and relay point in the sky that has clear video to both the 

transmission and reception destination. This requires the helicopter to hover in the same position for 

duration of the event. Again, UASs is well suited for this application as it can hold its position based on its 

internal GPS and altimeter. Such a solution great lowers cost and highly reduces risks to all parties 

involved. 

B. Operating Conditions and Limitations

All operations will be conducted according to and in compliance with the following conditions and 

limitations.
Communications Concepts, Inc.

Page 6

(A) All UASs utilized will weigh less than 55 lbs. (25 kg)

(B) The aircraft will remain within visual line-of-sight ("VLOS") of the operator and / or visual 

observer(s) at all times using vision unaided by any device with the exception of corrective 

lenses

(C) A visual observer ("VO") may be utilized to satisfy the VLOS and observation requirements 

as defined herein

(D) The aircraft will not operate over non-participating persons

(E) Flight operations will typically be conducted only between the period of official sunrise and 

sunset as defined in the Aeronautical Information Manual (AIM). Should a night operation be 

required, CCI will provide the FAA with a safety case that contains sufficient mitigation to 

avoid collision hazards at night. This request will be provided well in advance of any night 

operation. Night operations will be conducted only if the FAA approves the request.

(F) The UAS will yield right-of-way to other aircraft, manned or unmanned. If there is a risk of a 

collision, the operator will immediately maneuver away.

(G) Prior to flight, the UAS operator will assess weather conditions using FAA approved weather 

sources and direct weather observation, will check airspace restrictions and TFRs and will 

assess the location of people and property to lessen risks if he or she loses control of the UAS.

(H) Flight operations will be conducted only with flight visibilities at or exceeding 3 statute miles.

(I) The UAS will not be operated in airport flight paths, restricted airspace, or areas under current 

Temporary Flight Restrictions (TFRs). 

(J) The operator will discontinue the flight when continuing would pose a hazard to other aircraft, 

people or property. 

(K) The UAS will not exceed an airspeed of 87 knots (100 mph).

(L) The UAS will not be operated at an altitude exceeding 400 feet above ground level ("AGL"). 

(M) Operations will not be conducted in Class A airspace. 

(N) ATC permission will be obtained prior to operations in Class B, Class C, Class D or Class E 

airspace. 

(O) The operator / observer(s) will operate / observe only one UAS at a time. 

(P) A thorough preflight of the UAS will be conducted by the designated operator in command 

("OIC") prior to the first flight of the day or after any suspected or observed anomalies or 

damage. 

(Q) The OIC will follow the suggested preflight actions as outlined in the UAS operator's manual 

or, if available, Communications Concepts, Inc.'s UAS operation guidelines. 

(R) The operator will not operate an UAS should he or she know or has any reason to know of 

any physical or mental condition that would interfere with their safe operation of the aircraft. 

(S) The UAS will not be operated in a careless or reckless manner.

C. Operator Certification and Requirements

All Communications Concepts, Inc. operators will abide by the following conditions and requirements.

(A) The OIC must have accumulated and logged, in a manner consistent with 14 CFR § 61.51 (b), 

a minimum 10 hours of total time as a UAS pilot and at least 5 hours logged as a UAS pilot 
Communications Concepts, Inc.

Page 7

with a similar UAS type

(B) All operators will be 18 years of age or older.

(C) Operators, or a designated Communications Concepts, Inc. official will make available to the 

FAA, upon request, the UAS for inspection or testing.

(D) Operators or a designated Communications Concepts, Inc. official will maintain a log of 

flights as practicable for future currency or flight logging requirements.

(E) An operator or a designated Communications Concepts, Inc. official will report an accident to 

the FAA within 10 days of any operation that results in damage to property, other than the 

aircraft, estimated to exceed $25,000 for repair (including materials and labor) or fair market 

value in the event of total loss, whichever is less and / or results in significant injury or death.

D. UAS Registration, Markings and Requirements

Applicable Codes of Federal Regulation require aircraft to be marked according to certain specifications. 

Communications Concepts’ UAS, by definition, is unmanned. Therefore the UAS does not have a cabin, 

cockpit or pilot station on which to mark certain words or phrases. Further, two-inch lettering is difficult to 

place on such small aircraft with dimensions smaller that minimal lettering requirement. The FAA has 

previously issued exemptions to this regulation through Exemptions Nos. 8738, 10167, 10167A and 

10700.C. 14 C.F.R. 91.119: Minimum Safe Altitudes.

V. Public Benefit and Public Interest

Currently, the services listed in Section IV. Proposed Operations are performed via helicopter or fixedwinged aircraft. The aircraft are typically flown at low altitude and in relative close proximity to the 

facilities and structures or components being imaged. The use of a UAS rather than a manned aircraft in 

such applications will further the public interest in several areas including but not limited to the following:

• The UAS carries no passengers, pilot or crew, thereby increasing pilot, passenger and worker 

safety

• The UAS can often eliminate the need for workers to climb a towers, poles or other structures in 

order to inspect components thereby increasing worker safety.

• The UAS carries no flammable fuel thereby increasing safety to the general public.

• The UAS has a lower noise signature than a typical helicopter or aircraft thereby improving public 

welfare.

• The UAS has no emissions thereby reducing the environment impact over traditional manned 

aircraft.

• The UAS is less expensive to operate than a traditional manned aircraft thereby decreasing the 

cost of obtaining these services.

• The UAS is less expensive to acquire than a manned aircraft thereby allowing for more inspection 

crews to operate concurrently. This can result in better-maintained infrastructure, more reliable 

power or celluar distribution for the public and better knowledge base to make educated decisions.

• The UAS may respond to natural disasters and storm-related damage quicker than mannedaircraft. This results in faster response and restoration of utility service such as power restoration 
Communications Concepts, Inc.

Page 8

and lower outage time for the public.

VI. Discussion of Requested FAR Exemptions

Communications Concepts, Inc. seeks an exemption from the following regulations including provisions of 

Part 21, 45, 61 and 91 for the purposes of conduction the operations described herein. Presented here are 

the specific FAR sections for which exemption is requested and the methods and safeguards by which 

Communications Concepts, Inc. will ensure a level of safety equivalent to exceeding the regulations from 

which exemption is sought. See 14 C.F.R. § 11.81(e).

A. 14 C.F.R. Part 21, Subpart H — Airworthiness certificates

Section 91.203(a)(1) requires civil civil aircraft to have "an appropriate and current airworthiness 

certificate." Part 21, Subpart H ("Airworthiness Certificates") establishes the procedural requirements and 

applicability for the issuance of airworthiness certificates as directed by 14 C.F.R. § 91.203(a)(1).

Equivalent level of safety: The UASs operated will be have a gross weight less than 55 lbs. and will be 

flown at speeds less than 87 knots (100 mph). They do not carry a pilot or passengers, do not carry 

flammable fuels and will be operated in well-defined locations using an operator and, if deemed required 

by Communications Concepts, Inc., a visual observer(s). All operations will be conducted in compliance 

with the limitations and conditions stated in this petition for exemption. The Federal Aviation Act and 

Section 333 of the Reform Act both authorize the FAA to exempt aircraft from the requirement of an 

airworthiness certificate upon consideration of the UAS' size, weight, speed, operational capability and 

proximity to airports and populated areas.

The UASs will not have an airworthiness certificate, and there is no FAA regulatory standard for 

determining airworthiness of the UASs. Additionally, Communications Concepts’ operating documents set 

forth inspection and maintenance procedures to ensure airworthiness.The characteristics and conditions 

under which the UASs will be operated, as outlined in this petition, given the size, weight, speed, operation 

capability and proximity to airports and populated areas, achieve or exceed the equivalent level of safety 

over a manned aircraft with an airworthiness certificate used for the purposes outlined in this petition.

The FAA has stated that no exemption is required from this section if a finding is made under the Reform 

Act that an UAS provides an equivalent level of safety when compared to aircraft normally used for the 

same application. See granted exemptions 11138, 11062, 11067, 11080, 11114 and 11112.

B. 14 C.F.R § 45.23 (b) - Display of marks; general

Regulation 14 C.F.R. § 45.32 (b) states: "...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."

Equivalent level of safety: These UAS does not have a "cabin, cockpit or pilot station entrance" therefore 

the required marks cannot be displayed "near each entrance." Additionally, letters not less than 2 inches nor 

more than 6 inches may not be practical given the small size of the UAS. If the UAS is too small to display 
Communications Concepts, Inc.

Page 9

markings in the size described in regulation § 45.23 (b), then markings will be displayed in the largest 

practicable manner.

C. 14 C.F.R. § 45.25 — Location of marks on fixed winged aircraft

Regulation 14 C.F.R. 45.25 describes the marking requirements on fixed winged aircraft. It states that the 

aircraft, "...must display the required marks on either the vertical tail surfaces or the sides of the 

fuselage...". It continues to describe the specific locations on which marks may be displayed.

Equivalent level of safety: An UAS does not carry a pilot or passengers, does not have a cabin and may 

have a design that is significantly different than traditional manned aircraft. As such, the markings 

requirements of 14 C.F.R. § 45.25 may not be feasible given the design and layout of the aircraft. To 

provide an equivalent level of safety, the UAS will display required markings on conspicuous locations of 

the aircraft.

D. 14 C.F.R. § 45.27 (a) — Location of marks; nonfixed-wing aircraft

Regulation 14 C.F.R. 45.27 (a) states: "Each operator of a rotorcraft must display on that rotorcraft 

horizontally on both surfaces of the cabin, fuselage, boom, or tail the marks required by §45.23."

Equivalent level of safety: An UAS does not carry a pilot or passengers, does not have a cabin and may 

have a design that is significantly different than traditional manned aircraft. As such, the markings 

requirements of 14 C.F.R. § 45.25 may not be feasible given the design and layout of the aircraft. To 

provide an equivalent level of safety, the UAS will display required markings on conspicuous locations of 

the aircraft.

E. 14 C.F.R. § 45.29 - Size of marks

Regulation 14 C.F.R. 45.29 describes the required size of marks and the characteristic of lettering for 

aircraft. In many cases it dictates that marks must be at least 12 inches high.

Equivalent level of safety: An UAS is, by definition, significantly smaller and may have a design and 

layout significantly different than traditional manned aircraft. As such, the size and layout of markings as 

stated in 14 C.F.R. § 45.29 may not be feasible due to the inherent characteristics of UASs. To provide an 

equivalent level of safety, the UAS will display required markings on conspicuous locations of the aircraft. 

If the aircraft is too small to display markings in standard size, then the aircraft will display markings in the 

largest practicable manner.

F. 14 C.F.R § 61.113 (a) & (b) and 14 C.F.R. § 61.133 (a) - Private pilot privileges and limitations; 

pilot in command; commercial pilot privileges and limitations

Regulation 14 C.F.R. § 61.113 restricts private pilots from flying aircraft for compensation or hire and 

would require a second class medical certificate. Regulation 14 C.F.R. § 61.133 requires a pilot to hold a 

commercial pilot's license when acting as pilot in command of an aircraft used for compensation or hire. 

This is intended to ensure that the skill and competency of any PIC matches the airspace in which the PIC 

will be operating, as well as requiring certifications if the pilot is carry passengers or cargo for hire.

Equivalent level of safety: Communications Concepts, Inc. UASs will be operated as part of a commercial 
Communications Concepts, Inc.

Page 10

operation, however they do not carry passengers or cargo. Additionally, they remain below 400 feet AGL, 

are operated at less than 87 knots (100 mph), will not be operated over non-participating individuals, are 

under 55 lbs. and do not carry flammable fuel. In FAA Docket No. FAA-2014-0352, the FAA determined 

that UAS operations did not warrant the additional cost and restrictions imposed by requiring the operator 

to have a commercial pilot certificate and class II medical certificate.

Additionally, the operators will participate in UAS specific online training provided by the manufacturer 

including, basic UAS check out, first flight instruction, advanced flight instruction and other programs as 

they become available. CCI will also provide a custom designed in-house program specifically tailored to 

Communications Concepts, Inc.'s operations, UASs and operating environment. This program will be 

developed using input and guidance from currently operating UAS training programs and will follow 

industry standard processes and procedures. The program will consist of industry standard ground based 

and hands on training in a controlled flight environment.

Section 333 also requires operations to not pose a threat to national security. The security screening 

conducted by the Transportation Security Administration ("TSA") of certificated airmen satisfies this 

requirement and applies to all Communications Concepts, Inc.'s operators.

Using these processes, procedures and restrictions, the level of safety of UAS operations for the uses as 

outlined herein is equivalent to or significantly exceed those as regulated by §61.113 and §61.133.

G. 14 C.F.R. § 91.7 (a) — Civil aircraft airworthiness

The regulations states: "No person may operate a civil aircraft unless it is in airworthy condition."

Equivalent level of safety: The FAA has stated that no exemption is required to the extent that the 

requirements of Part 21 are waived or found inapplicable. Communications Concepts, Inc. requests that the 

requirements for § 91.7 be treated in accordance with FAR Part 21 Subpart H. Additionally, 

Communications Concepts, Inc. operators will inspect the aircraft prior to flight in order to ensure it is in a 

condition that is safe for flight. See granted exemption 11062.

H. 14 C.F.R. § 91.9 (b)(2) & (c) - Approved flight manual in the aircraft

Regulation 14 C.F.R. § 91.9 (b)(2) states: "No person may operate a U.S.-registered civil aircraft ... 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."

Regulation 14 C.F.R. § 91.9 (c) states: "No person may operate a U.S.-registered civil aircraft unless that 

aircraft is identified in accordance with part 45 of this chapter."

Equivalent level of safety: Communications Concepts, Inc. requests an exemption from this regulation in 

part as outlined in the request for exemption from regulation 14 C.F.R. § 91.203 (a) and (b). An equivalent 

level of safety will be achieved by maintaining the proper documentation at the location of the Ground 

Control Station readily available to the operator. This includes the UAS operation manual as provided by 

the manufacturer or equivalent documents as created by Communications Concepts, Inc.

Additionally, the FAA, in accordance with FAA Office of Chief Counsel's Opinion dated August 8, 2014, 
Communications Concepts, Inc.

Page 11

the UAS flight manual, registration certificate and other documentation will be kept at the control station 

with the operator during flight. The Chief Counsel's Office has held that for all UAS operations, this 

alternate method constitutes full compliance with the regulations. See granted exemption 11062.

I. 14 C.F.R. § 91.103 - Preflight action

14 C.F.R. § 91.103 requires the PIC to become familiar with specific information before each flight, 

including information contained in the FAA-approved Flight Manual on board the aircraft.

Equivalent level of safety: The UAS does not have a Flight Manual on board because of its inherent design 

and lack of on board pilot. The operator will review information prior to flight to maintain the safety of the 

operation, including but not limited to, the weather, battery levels, landing and takeoff distances and 

aircraft performance data. The operator will refer to the manufacturer supplied UAS manual for technical 

data and information as provided. The manual will be kept at the ground station during operations.

The FAA has stated that no exemption is required (see Grant of Exemption No. 11062, p. 20) however, an 

exemption is requested to the extent that an FAA-approved Flight Manual is required.

J. 14 C.F.R. § 91.105 - Flight crewmembers at stations

This section contains requirements for crewmembers during takeoff and landing of the aircraft. The 

regulation requires crewmembers to be at the crewmember's station unless absence is necessary to perform 

their duties. It also requires crewmembers to keep safety belt(s), including their shoulder harness if so 

equipped, fastened.

UASs do not carry pilots or passengers and therefore do not have a "crewmember station." However UASs 

do have a Ground Control Station from which an operator controls the aircraft via radio signals. The 

Ground Control Station may be at a fixed location or may be movable. However, because it is not a 

physical part of the aircraft, the Ground Control Station may not have a seat(s) and does not utilize safety 

belts.

Visual observers, when deemed necessary by Communications Concepts, Inc., may be at various locations 

in the vicinity of the flight operations area in order to provide the best line of sight view of the UAS during 

flight. The visual observers may or may not be at a fixed location and may or may not utilize a seat. The 

seat will not be equipped with safety belts.

Equivalent level of safety: The UAS operator will remain at the Ground Control Station where the control 

of the aircraft takes place for the duration of the flight. Visual observers, when deemed necessary by 

Communications Concepts, Inc., will be positioned in the flight operations area according to the operator's 

determination of the optimal viewing area given the planned flight. The use of safety belts is not feasible 

because the crewmember stations are not physically a part of the aircraft and are not in motion.

K. 14 C.F.R. § 91.109 (a) - Flight instruction

14 C.F.R. § 91.109 (a) states that, "No person may operate a civil aircraft (except a manned free balloon) 

that is being used for flight instruction unless that aircraft has fully functioning dual controls." UASs do not 

have functioning dual controls by design. They are piloted using a Flight Control System/Ground Control 

Station that communicates with the aircraft via radio signals.
Communications Concepts, Inc.

Page 12

Equivalent level of safety: During flight instruction, there are no pilots or passengers on the aircraft and the 

Ground Control Station will be a safe distance from the aircraft. The aircraft will remain a safe distance 

from non-participating individuals causing no safety hazard.

Given the size and speed of the UAS, an equivalent level of safe training can be performed without dual 

controls because no pilot or passengers are aboard the aircraft and it is a safe distance from the public and 

structures.

The FAA has previously approved exemptions for flight training without dual controls for a number of 

aircraft. See Granted Exemptions: 11109, 11138 and 11110.

L. 14 C.F.R. § 91.119 - Minimum safe altitudes

14 C.F.R. § 91.119 prescribes that an aircraft may not be operated closer than 500 feet to any person, 

vessel, vehicle or structure. The nature of the operations described herein may require operation in 

relatively close proximity to items such as power line towers or poles. However, operations will not be 

conducted over non-participating individuals.

Equivalent level of safety: The UASs operated by Communications Concepts, Inc. are far smaller than 

manned aircraft, such as rotorcraft and fixed winged aircraft, used for similar operations. Additionally, the 

UASs do not carry a pilot or passengers, weigh less than 55 lbs., do not carry flammable fuel, will not 

exceed 87 knots (100 mph) and will not be operated over non-participating persons. The UASs will be 

operated below 500 feet AGL with the use of an operator and, if determined to be required by 

Communications Concepts, Inc., a visual observer(s) to avoid risk to aircraft, persons and property. This 

provides an equivalent or greater level of safety than achieved with conventional aircraft currently 

performing similar operations.

M. 14 C.F.R. § 91.121 - Altimeter settings

14 C.F.R. § 91.121 requires an aircraft to be operated by reference to an altimeter that is set to the elevation 

of the departure airport or barometric pressure when operating below 18,000 feel MSL. Some UAS contain 

a barometric pressure sensor. Others utilize GPS sensors to determine altitude. Typically barometric 

pressure sensors are corrected to the point of takeoff; not a departure airport.

Equivalent level of safety: The operator will confirm the elevation of the launch site prior to launch. This 

will be compared to the GPS sensor or barometric sensor derived altitude as displayed on the UAS

telemetry reading at the Ground Control Station. The operator will then determine the maximum 

permissible altitude to maintain flight below 400 feet AGL and will not exceed this altitude. The maximum 

permissible altitude will also be monitored and estimated by visual means through the use of the operator 

and / or visual observer(s) as a secondary backup to UAS telemetry data. This provides a level a safety 

equal to or exceeding the regulation.

N. 14 C.F.R. § 91.151 (a)(1) & (b) - Fuel requirements for flight in VFR conditions

14 C.F.R. § 91.151 (a) (l) states: "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 — (l) During the day, to fly after that for at least 30 
Communications Concepts, Inc.

Page 13

minutes..."

14 C.F.R. § 91.151 (b) states: "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."

The UAS will be operated only during daylight hours in VFR conditions. The technical limitations of most 

UASs limit total flight time to approximately 40 minutes before the battery is depleted. This means that no 

meaningful flight time would be possible given the limitations of § 91.151 (a) (l) and (b).

Equivalent level of safety: The UAS flight will be terminated with at least 20% reserve power. This allows 

the UAS to return to its landing zone with adequate power remaining to conduct a safe and controlled 

landing. Given the UAS’ size, weight and speed, the UAS when operated with this limitation provides an 

equivalent or greater level of safety than manned aircraft represented by this regulation.

Additionally, flights will be safely landed when the battery falls below its nominal voltage, should that 

occur prior to completion of the operation. The 3D Robotics Solo UASs that CCI will utilize offers a Smart 

Battery System that not only monitors Solo’s remaining battery charge but also helps to account for 

location, so that the mobile app provides the Pilot in Command (PIC) relevant warnings about when to start 

to return to home based on the UASs’ distance from home. The battery communicates with UAS 

controller, which displays not only remaining flight time but also present power usage. If the PIC 

continues flying after initial warning, the UAS controller will begin vibrating to further alert the pilot of the 

need to land ASAP.

O. 14 C.F.R. § 91.203 (a) & (b) — Carry civil aircraft certification and registration

The regulation states: (a) "...no person may operate a civil aircraft unless it has ... an appropriate and 

current airworthiness certificate." Furthermore: (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."

Equivalent level of safety: In regard to 14 C.F.R. § 91.203 Part (a), an equivalent level of safety is 

achieved through the methods and characteristics as outlined in the request for exemption from 14 C.F.R. 

Part 21, Subpart H.

In regard to 14 C.F.R. § 91.203 Part (b), the UAS does not carry a pilot or passengers, does not have a 

"cabin or cockpit entrance" and does not have onboard storage in which to carry certification and 

registration documents. An equivalent level of safety will be achieved by maintaining the proper 

documentation at the Ground Control Station readily available to the operator. The FAA has issued 

numerous exemptions to this regulation. See granted exemptions 9565A, 9565B, 9789, 9789A, 9797, 

9797A, 9816A and 9816.

Additionally, the FAA, in accordance with FAA Office of Chief Counsel's Opinion dated August 8, 2014, 

the UAS flight manual, registration certificate and other documentation will be kept at the control station 

with the operator during flight. The Chief Counsel's Office has held that for all UAS operations, this 

alternate method constitutes full compliance with the regulations. See granted exemption 11062.
Communications Concepts, Inc.

Page 14

P. 14 C.F.R. §§ 91.405 (a), 91.407 (a)(1), 91.409 (a)(2), 91.417 (a) & (b) - Maintenance inspections

The regulations 14 C.F.R. §§ 91.405 (a), 91.407 (a)(l), 91.409 (a)(2) and 91.417 (a) & (b) specify 

maintenance and inspection standards in reference to 14 C.F.R. Part 43. Specifically, 14 C.F.R. § 91.405 (a) 

requires that each owner or operator of an aircraft, "...shall have the aircraft inspected as prescribed in 

subpart E of this part and shall between required inspection ... have discrepancies repaired as prescribed in 

part 43 of this chapter." An exemption is required from these regulations because Part 43 and these sections 

apply only to aircraft with an airworthiness certificate, which the UASs will not have.

Equivalent level of safety: The UASs will be maintained and inspected in accordance with the 

manufacturer-supplied manual. This includes maintenance, overhaul, replacement and inspection 

requirements for the UASs. The operator, prior to the first flight of the day and as deemed necessary 

otherwise, will undertake preflight inspection procedures in order to ensure the UAS is in a condition for 

safe operation. Discrepancies that may affect the safety of flight will be addressed and repaired if required. 

The operator, and Communications Concepts, Inc., will maintain the UASs in a condition for safe 

operation. Given the size, characteristics and operating limitations of UASs as described herein, this 

provides a level of safety equivalent to or greater than manned aircraft performing similar operations.