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December 16, 2015

U.S. Department of Transportation

Docket Management System

1200 New Jersey Ave., SE

Washington, DC 20590

Re: Exemption Petition under Section 333 of the FAA Modernization & Reform 

Act, and Title 14 Part 11 of the Code of Federal Regulations (CFR)

14 CFR 61.113, 

14 CFR 91.7, 91.119, 91.121, 91.151

14 CFR 91 Subpart E (91.405, 91.407, 91.409, 91.417)

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, FlyTek Systems, Inc. files this petition to commercially 

operate a variety of airframes (both fixed wing and multi-rotor configurations) heretofore 

referred to as Unmanned Aerial Vehicle(s) or Unmanned Aircraft System (UAS).

The requested exemption would support an application for a commercial Certificate of 

Authorization (COA) to utilize the various UAS airframes to offer Aerial Data Collection 

and Surveying services for all appropriate commercial industries. A few examples of 

such industries include, but not limited to, real estate properties, construction site 

surveys, mapping, 3D modeling, Oil & Gas industry, structure inspections, Search and 

Rescue Organizations, agriculture and other potential industries that need aerial data 

collection.

The UAV consists of a lightweight (all under 17 lbs) battery operated, fixed wing

unmanned aircraft, onboard camera and associated communications equipment. All 

specifications of each airframe is listed on pages 11 and 12 of this document.

The various UASs has previously been demonstrated to have successfully met the 

safety and operational requirements resulting in previous grants of section 333 

exemption requests by other commercial UAS operators.

The President of FlyTek Systems, Inc. Mr. Chad Frazer, the designated UAV Flight 

Operations Lead, has extensive military training (over 2.5 years with 700+ UAV 

launches/recoveries) with other UAV platforms and has conducted safe non commercial 

flight operations with multiple UAV platforms in the NAS pursuant to AC 91-57 and its 

variants.

The various UAVs carry an onboard camera system that allows it to perform aerial data 

collection, and surveying.

By approving the exemption, FlyTek Systems, Inc. UAS operations will create benefits 

to both the economy and the environment which are ultimately in the public interest.
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The aircraft will be operated by an FAA licensed Pilot in Command for as long as an 

FAA Airman certificate is required by regulation, and a Visual Observer for as long as 

required by FAA regulations in accordance with the limitations set forth in the grant. In 

addition the following applicable restrictions will be followed:

- All operations will occur at no more than 400' above ground level (AGL)

- The aircraft will be operated with the permission of the property owner

- When necessary, applicable permits will be acquired from local authorities

- Operations will be limited to daytime with good visual meteorological conditions

- Aircraft will remain within Visual Line of Sight of the PIC at all times

- While the aircraft is airborne, the VO (Visual Operator) will be able to communicate 

verbally with the PIC

- When necessary and applicable, FlyTek Systems, Inc. will file a NOTAM providing 

radial/DME, radius, and a date/time group for each operation

- The UA will not be operated from any moving vehicle

- The proposed operations will not be conducted during night time

For certain complex operations, FlyTek Systems, Inc. may assign sensor or software 

operators to assist the operations. 

We submit that the combination of:

- UAV’s light weight and historically demonstrated safe operations

- A fully qualified flight crew

- Restricted operations under the guidelines established within the grant,

that the FAA can have confidence that FlyTek Systems, Inc. UAS the operations

will have an equivalent or greater level of safety of manned aircraft performing the same 

mission.

We are prepared to modify or amend any part of this request to satisfy the need for an 

equivalent level of safety. Additional documents supporting this petition will be 

submitted following this request. 

We look forward to working with your office.

Please contact us at any time if you require additional information or clarification.

Respectfully,

Chad Frazer, President

FlyTek Systems, Inc.

606 Brookfield Dr.

Garland, TX 75040

Tel: (980) 333-2301

Email: chad@flyteksys.com
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TABLE OF CONTENTS

NAME, ADDRESS CONTACT INFORMATION OF PETITIONER .............................Page 4 

THE SPECIFIC SECTIONS OF 14 C.F.R. FROM WHICH FLYTEK SYSTEMS, INC. SEEKS 

EXEMPTION......................................................................................................................Page 4 

THE EXTENT OF RELIEF FLYTEK SYSTEMS, INC. SEEKS AND THE REASONS 

FLYTEK SYSTEMS, INC. SEEKS THE RELIEF....................................................Pages 4 to 6

THE REASONS WHY GRANTING FLYTEK SYSTEMS, INC.S REQUEST WOULD BE 

IN THE PUBLIC INTEREST..............................................................................................Page 7

THE REASONS WHY GRANTING FLYTEK SYSTEMS, INC. THE EXEMPTION WOULD 

NOT ADVERSELY AFFECT SAFETY ............................................................................Page 8

SUMMARY THAT CAN BE PUBLISHED IN THE FEDERAL REGISTER..................Page 9

ANY ADDITIONAL INFORMATION, VIEWS, OR ARGUMENTS AVAILABLE TO 

SUPPORT FLYTEK SYSTEMS, INC. REQUEST...................................................Page 10 

AIRFRAME PERFORMANCE CHART..................................................................Pages 11 & 12

ACRONYMS.............................................................................................................Pages 13 & 14
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NAME, ADDRESS AND CONTACT INFORMATION OF PETITIONER 

Chad Frazer

FlyTek Systems, Inc.

606 Brookfield Dr.

Garland, TX 75040

Tel: (980) 333-2301

Email: chad@flyteksys.com

THE SPECIFIC SECTIONS OF 14 CFR TO BE RELIEVED FROM 

14 CFR 61.113, 

14 CFR 91.7, 91.119, 91.121, 91.151

14 CFR 91 Subpart E (91.405, 91.407, 91.409, 91.417)

THE EXTENT OF RELIEF FLYTEK SYSTEMS, INC. SEEKS AND THE REASONS 

FLYTEK SYSTEMS, INC. SEEKS THE RELIEF 

14 CFR 61.113 Private pilot privileges and limitations: 

Part 61.113 provides that no person that holds a private pilot certificate may act as pilot 

in command of an aircraft for compensation or hire. Subparagraph (b) allows a private 

pilot to act as pilot in command of an aircraft in connection with any business or 

employment if;

(1) Flight is only incidental to that business or employment; and 

(2) The aircraft does not carry passengers or property for compensation or hire.

Since the aircraft cannot carry passengers or property, we request to be relieved from 

this regulation if our pilots at minimum, 

(1) hold at least a current private pilot certificate and,

(2) hold a current third class medical certificate.

By meeting conditions (1) and (2), we believe that equivalent level of safety can be 

achieved by complying with 61.113 Subparagraph (b) even though the intent of this 

application is to conduct a business.
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14 CFR 91.7 Civil Aircraft Airworthiness.

14CFR 91.7 (a) states,

“No person may operate a civil aircraft unless it is in an airworthy condition.”

This rule prohibits the operation of an aircraft without an airworthiness certificate. 

Since there is no such existing certificate that is applicable for any of the airframes 

sought within this grant to properly comply with the FARs, we request that FlyTek 

Systems, Inc. to be relieved from this regulation.

To provide equivalent level of safety, we will ensure that the UAV is in airworthy 

condition prior to every flight by following necessary safety procedures and check 

lists. 

14 CFR 91.119 Minimum safe altitudes: General 

This regulation provides that over sparsely populated areas the aircraft cannot be 

operated closer than 500 feet to any person, vessel, vehicle, or structure. Since the 

aircraft will be operating at a maximum of 400 feet AGL, we cannot comply with this 

requirement.

To provide an equivalent level of safety we will only fly over private property with the 

permission of the land owner. The land owner will be briefed of the expected route of 

flight and the associated risks to persons and property on the ground. We maintain that 

due to the small size of the UAVs, the hazard to persons, vessels, vehicles, and 

structures is not comparable to manned aircraft and should be considered in granting 

the exemption. 

14 CFR 91.121 Altimeter Settings 

This regulation provides that aircraft shall maintain cruising altitudes by reference to an 

altimeter setting available within 100 nautical miles of the aircraft. 

The UAVs aircraft will fly below 400 feet AGL and will not need to maintain 

hemispherical cruising altitudes in order to de-conflict with other aircraft.

 

To provide an equivalent level of safety, the PIC will check and confirm the UAV’s GPS

and the barometric instrument's indicated altitude read out before each flight.

14 CFR 91.151 Fuel requirements for flight in VFR conditions. 

The regulation provides that no person may begin a flight in an airplane under dayVFR conditions unless there is enough fuel to fly to the first point of intended landing 

and to fly after that for at least 30 minutes. We believe the intention of this rule is to 

provide a reserve of energy as a safety buffer for go-arounds and other delays to 

landing.
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The UAVs are battery operated and the maximum duration of flight with full payload, 

from a single battery charge is approximately 30 to 120 minutes depending on the 

airframe selected (see full spec sheet at the end of this document for all airframe data). 

We believe that an equivalent level of safety can be achieved by limiting our flight time 

to 90% of rated flight minutes with a reserved energy of 10% of rated flight minutes on 

the battery.
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14 CFR 91 Subpart E ( 91.405, 91.407, 91.409, 91.417 )

Maintenance, Preventive Maintenance, and Alterations

The regulation provides that the operator is primarily responsible for maintaining the 

aircraft in an airworthy condition, including compliance with part 39 and 43. Paragraphs 

91.407 and 91.409 require that the aircraft be "approved for return to service by a 

person authorized under 43.7" after maintenance and inspection. It is our intention that 

the PIC, Visual Observer (VO) or authorized personnel who performs maintenance and 

inspection of the aircraft "be authorized to approve the aircraft for return to service."

FlyTek Systems, Inc. requests that exemptions to the stated regulations under 

conditions below:

(1) FlyTek Systems, Inc. will follow UAV’s manufacturer maintenance instructions, 

techniques and procedures .

(2) FlyTek Systems, Inc. will designate, train, and document the personnel who will be 

authorized to perform Inspection, Maintenance and Alterations.

Such designated personnel may include PIC, VO or other equivalent trained persons.

(3) To ensure equivalent level of safety, PIC will inspect the UA before each flight 

looking for any structural or mechanical malfunctions.

Due to the small size, light weight and simplicity of the UAV, we believe that the 

equivalent safety will be achieved by permitting any PIC, VO or equivalent trained 

personnel to perform maintenance, inspection and alterations of the aircraft and " be 

authorized to approve the aircraft for return to service. "
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THE REASONS WHY GRANTING FLYTEK SYSTEMS, INC.'S REQUEST WOULD BE IN 

THE PUBLIC INTEREST:

We believe that granting our exemption request from:

14 CFR Part 21.191

14 CFR Part 45.23, 45.29

14 CFR 61.113, 61.133

14 CFR 91.9, 91.119, 91.121, 91.151

14 CFR 91 Subpart E (91.405, 91.407, 91.409, 91.417)

is in the public’s interest and will benefit the public as a whole for the following 

reasons.

1- The UAV is battery operated and free from the harmful emissions associated 

with the manned aircraft that are currently used for aerial photography and 

videography. As recently proven by several grants of section 333 petitions, UASs 

offer equivalent level of safety while reducing environmental impacts, which is in 

the public interest.

2- FlyTek Systems, Inc. UAS operations will contribute to a positive aggregate 

economic impact resulting in creation of jobs both direct and indirectly. 

Economic Research estimates that the UAS market will grow from $6 billion to 

$94 billion over the next decade resulting in a new workforce development. 

3- Because FlyTek Systems, Inc. operations will create new jobs such as pilots, 

flight operation staff, and administrative supporting staff, it will directly cause

positive economic impact, hence granting FlyTek Systems, Inc. petition will 

benefit the public as a whole.

4- Congress has already proclaimed that it is in the public’s interest to integrate

Commercially flown UAS(s) into the national airspace system, hence the passing 

of the FAA Modernization and Reform Act of 2012. Granting FlyTek Systems, Inc. 

petition furthers the public’s interest as a demonstrated progression of integrating 

Unmanned Aircraft Systems into National Air Space, thus it will benefit the public 

as a whole. 

 5- As a unique community service, FlyTek Systems, Inc. will offer, free of charge in 

most cases, various Search and Rescue flights designed to find missing persons, 

homicide victims as well as disaster relief intelligence gathering. This would 

result in an enormous public benefit.
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THE REASONS WHY GRANTING FLYTEK SYSTEMS, INC. THE EXEMPTION 

WOULD NOT ADVERSELY AFFECT SAFETY:

FlyTek Systems, Inc. believes that the grant of exemption from:

14 CFR 61.113, 

14 CFR 91.7, 91.119, 91.121, 91.151

14 CFR 91 Subpart E (91.405, 91.407, 91.409, 91.417),

will not adversely affect safety by a combination of the reasons listed below.

(a) We have stated in the above section “ THE EXTENT OF RELIEF FLYTEK 

SYSTEMS, INC. SEEKS AND THE REASONS FLYTEK SYSTEMS, INC.

SEEKS THE RELIEF ” by describing how we intend to mitigate risk and 

accomplish FAA equivalent and acceptable level of safety for each 14 CFR part.

 

(b) As a result of UAVs unmanned aircraft’s size, weight, speed, operational 

capability, proximity to airports and populated areas, operation within visual line 

of sight combined with the implementing of FAA required safety procedures, we 

believe that granting FlyTek Systems, Inc. exemption request will not adversely

affect safety.

(c) The various UAV Systems selected has been demonstrated to satisfy necessary 

safety risk mitigation by FAA thus resulting in multiple grants of section 333 

petitions of similar fixed wing UAS. Because of the combination of UAV’s proven 

success and the conditions and limitations of our operations, we believe granting 

FlyTek Systems, Inc. request will not adversely safety. 
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SUMMARY THAT CAN BE PUBLISHED IN THE FEDERAL REGISTER:

Department of Transportation

Federal Aviation Administration

Petitioner: FlyTek Systems, Inc.

Petition of exemption from sections of:

14 CFR 61.113, 

14 CFR 91.7, 91.119, 91.121, 91.151

14 CFR 91 Subpart E (91.405, 91.407, 91.409, 91.417)

Description of relief sought;

FlyTek Systems, Inc. seeks an exemption for commercial operation of the following 

UAS. The UAVs listed may have an onboard camera system capable of acquiring high 

resolution data.

Proposed operations will offer aerial data collection and surveying services for

appropriate commercial industries.

Aircraft Name Manufacturer

Albatross Applied Aeronautics

Buffalo FX79 SkyWalker

Air Titan Finwing

Penguin V2 Finwing

Phantom FX61 Zeta

Anaconda RMRC

Skua X-UAV

SkyObserver X-UAV

SkyHunter Origin

X8 SkyWalker

TechPod Wane Garris

Phantom 2 DJI

Phantom 3 DJI

Inspire 1 DJI
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ANY ADDITIONAL INFORMATION, VIEWS, OR ARGUMENTS AVAILABLE TO 

SUPPORT FLYTEK SYSTEMS, INC. REQUEST

 Unmanned Aircraft Systems Section

General Features of All Airframes Proposed:

 ST Micro L3GD20 3-axis 16-bit gyroscope

 ST Micro LSM303D 3-axis 14-bit accelerometer / magnetometer

 Invensense MPU 6000 3-axis accelerometer/gyroscope

 MEAS MS5611 barometer

 20 to 120 minutes of Flight Time 

 Auto Return-to-Home & Landing

 Advanced Power Management

 Integrated backup system for in-flight recovery and manual override with 

dedicated processor and stand-alone power supply

 Backup system integrates mixing, providing consistent autopilot and manual 

override mixing modes

 Redundant power supply inputs and automatic failover

 External safety button for easy motor activation and deactivation

 Multicolor LED indicator to visually display Autopilot Status

 High-power, multi-tone piezo audio indicator 

 microSD card for long-time high-rate logging

 Easy Battery Replacement

 CAN-Bus Expansion Module

 Control Link radio operating frequency 2.4 GHz ISM
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Aircraft Performance Chart

Aircraft 

Name

Manufacturer Empty 

Weight

Max Take 

Off Weight

Max 

Flight 

Speed

Wing Span Flight 

Time

Albatross Applied

Aeronautics

14lbs 17.6lbs 60mph 8ft 120min

Buffalo FX79 SkyWalker 6lbs 9lbs 60mph 79in 90min

Air Titan Finwing 8lbs 15lbs 60mph 8ft 45min

Penguin V2 Finwing 3lbs 5lbs 45mph 68in 60min

Phantom 

FX61

Zeta 3.1lbs 4.5lbs 45mph 61in 60min

Anaconda RMRC 5lbs 8lbs 60mph 7ft 60min

Skua X-UAV 4.2lbs 8lbs 50mph 7ft 120min

SkyObserver X-UAV 4.5lbs 6.5lbs 45mph 79in 60min

SkyHunter Origin 6lbs 9lbs 55mph 71in 60min

X8 SkyWalker 4.5lbs 8lbs 60mph 84in 90min

TechPod Wane Garris 2.75 5lbs 64mph 102in 120min

Phantom 2 DJI 4lbs 6lbs 30mph Multi-Rotor 20min

Phantom 3 DJI 4lbs 6lbs 30mph Multi-Rotor 20min

Inspire 1 DJI 4lbs 6lbs 30mph Multi-Rotor 20min
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No Privacy Issues

FlyTek Systems, Inc. proposed operations will create no privacy issues because the 

UAV will be operating in the areas within the boundaries of the properties with the land 

owner’s permission. 

When necessary, FlyTek Systems, Inc. will also obtain any permits or authorizations 

from local authorities.

ACRONYMS

AGL Above Ground Level

ALoS Acceptable Level of Safety

AMOC Alternative Method of Compliance

ASI Aviation Safety Inspector

ATC Air Traffic Control

ATCAA Air Traffic Control Assigned Airspace

ATS Air Traffic Service

AVS Aviation Safety

CFR Code of Federal Regulations

COA Certificate of Waiver or Authorization

CRM Crew Resource Management

CS Control Station

CRS Certified Repair Station

DCP Divert/Contingency Point

DHS Department of Homeland Security

DME Distance Measuring Equipment

DOD Department of Defense

DSA Detect, Sense, and Avoid System

FAA Federal Aviation Administration

FCC Federal Communications Commission

FARs Federal Aviation Regulations

FIR Flight Information Region

FL Flight Level

FSIMS Flight Standards Information Management 

System

FTP Flight Termination Point

FTS Flight Termination System

Crosstimbers FlyTek Systems, Inc., LLC

GHz Gigahertz

GCS Ground Control Station

MHz Megahertz

MTOW Maximum Takeoff Weight

NAS National Airspace System

NM Nautical Mile
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NOTAM Notice To Airman 

OPA Optionally Piloted Aircraft

PIC Pilot in Command

UAVs UAVs Unmanned Aircraft System

UAVs UAVs Unmanned Aircraft

R&D Research and Development

RF Radio Frequency

RM Risk Management

RNAV Area Navigation

RTB Return to Base

RVSM Reduced Vertical Separation Minimum

TAS Traffic Advisory Systems

TC Type Certificate

UA Unmanned Aircraft

UAS Unmanned Aircraft System(s)

UAV Unmanned Aerial Vehicle

VFR Visual Flight Rules

VMC Visual Meteorological Conditions

VO Visual Observer