December	3,	2015

Docket	Operations,	M-30;	

U.S.	Department	of	Transportation	

(DOT),	1200	New	Jersey	Avenue,	SE.

Room	W12-140

West	Building	Ground	Floor

Washington,	DC	20590-0001

Re:	Request	for	exemption	from	multiple	regulatory	provisions	to	allow	the	use	of	small	

unmanned	aerial	systems	on	land	and	over	yachts	controlled	by	clients	of	Katherine	Lovelace

to	assist	in	the	safe	evaluation	of	infrastructure	and	operations	for	those	clients.		Aerial	video	

and	photography	are	to	be	used	to	perform	these	evaluations.

Dear	Ma’am	or	Sir:

Katherine	Lovelace	respectfully	requests	an	exemption	from	several	provisions	of	Title	14	of	the	

Code	of	Federal	Regulations	(C.F.R.)	to	permit	the	use	of	small	unmanned	aerial	systems	(sUAS)	

to	assist	in	the	evaluation	of	infrastructure	and	aerial	photography	operations	for	my clients.	

This	request	is	motivated	primarily	by	the	desire	to	maximize	safety	in	infrastructure	and	aerial	

photography	operations.	While	an	exemption	would	not	eliminate	the	current	need	for	inperson	visual	inspection	required	by	various	federal	regulatory	departments,	it	would	allow	

Katherine	Lovelace to	broadly	evaluate	assets	and	conduct	aerial	photography	operations	with	

sUAS,	resulting	in	a	safer	and	more	efficient	infrastructure	network and	asset	display.	

Accordingly,	the	grant	of	an	exemption	is	consistent	with	Congress’	intent,	reflected	in	Section	

333	of	the	FAA	Modernization	and	Reform	Act	of	2012	(Modernization	Act),1	that	safe	systems	

be	permitted	in	the	national	airspace	prior	to	the	issuance	of	final	regulations	governing	general	

use	of	these	systems.2	A	summary	of	this	request	suitable	for	publication	in	the	Federal	Register	

is	provided	as	Appendix	A.

Appendix	B	provides	the	manufacturers	information	regarding	the	design,	aircraft	

performance, and fail-safe features. We have provided manufacturer information related

to	operating	limitations,	normal	and	emergency	procedures,	and	maintenance	and	

inspection	procedures.	As	we	add	aircraft	designs,	we	will	update	this	appendix

appropriately.

1	P.L.	112-95,	126	Stat	11,	February	14, 2012.

2	Section	333(b)	(2)	specifically	contemplates	that	the	FAA	may	issue	a	certificate	of	waiver	

upon	a	finding	that	a	type	of	UAS,	as	a	result	of	its	size,	weight,	speed,	operational	capacity,	

proximity	to	airports	and	populated	areas,	and	operations	within	visual	line	of	sight	do	not	

create	a	hazard	to	users	of	the	NAS	or	the	public	or	pose	a	threat	to	national	security.

Katherine	Lovelace	

135	Hilton	St.	Unit	#2

Tiverton,	RI	06878

(203) 550-5845

klovelace84@gmail.com
Background	Information

Katherine	Lovelace is	in	the	business	of	developing	photographic	strategies	and Maintaining	

Mission	Specific	sUAS	for	clients.	Katherine	Lovelace’s clients	look	to	her for	Safe	Operations	of	

sUAS.	Specific	Safe	UAV	Operational	Procedures have	been	developed	to	ensure	the	safety	of	

clients	and	the	public.	Increasingly, clients	have	been	looking	to	operate	sUAS	for	Infrastructure	

Safety	&	Maintenance	Inspections carriesd	out	by	successful	Aerial	Photography	Operations.

Infrastructure	Safety	Inspection	Operations:	

Construction	Site	Inspection

Solar	Panel	Inspection

Yacht	Inspection

Real	Estate	Inspection

Roofing	Inspection

Agriculture	Inspection

As	part	of	this, Katherine	Lovelace is	requesting	FAA	Exemption	for	sUAS	operations	for	

safety,	inspection	and	video	capture	usage.

Regulatory	Basis	for	Exemption Request

In	addition	to	the	waiver	authority	provided	in	§333	of	the	Modernization	Act,	the	FAA	may	

grant	an	exemption	under	49	U.S.C.	§44701(f)	if	it	has	determined	that	such	an	exemption is	in	

the	public	interest.	The	FAA	has	imposed	a	separate	requirement	in	its	procedural	regulations,	

providing	that	the	petitioner	shall	explain	why	granting	the	exemption	would	not	adversely	

affect	safety	or	how	the	exemption	would	provide	at	least	an	equivalent	level	of	safety	as	

compliance	with	the	underlying	regulation.	In	this	case,	approval	of	this	exemption	would	

advance	the	public	interest	by	significantly	enhancing	the	safety	and	efficiency	of	infrastructure	

and	over-sea	operations	and	by	providing	the	FAA	with	valuable	user	experience	on	sUAS	in	a	

context	with	appreciable	economic	and	societal	benefits.	As	described	more	fully	below,	the	

requested	exemption	would	permit	the	operation	of	sUAS	under	tightly	controlled	conditions,	

thus	ensuring	that operations	will	not	have	an	adverse	impact	on	safety.	To	the	contrary,	as	

explained	below,	Katherine	Lovelace anticipates	that	use	of	sUAS	will	enhance	safety	in	

infrastructure	and	over-water	operations.	Granting	an	Exemption	is	in	the	Public	Interest.	The	

safety	and	efficiency	of	infrastructure	operations	and	over-water	observation	operations	is	

heavily	dependent	upon	constant	analysis	of	assets,	right-of-way,	infrastructure	and	other	

assets/facilities.	There	are	a	wide	variety	of	factors	that	can	affect	conditions	and	cause	

problems	for	infrastructure and	yachts.	Even	relatively	small	objects	or	minor	failures	can	lead	

to	accidents	or	other	incidents	causing	downtime	of	infrastructure or	danger	on	board	a	yacht.	

Extreme	weather	events	can	lead	to	flooding both	and	on	land	and	over-sea	or	overheating	

infrastructure.	For	example	earthquakes,	landslides,	and	abandoned	vehicles	at	grade	crossings	

can	block	infrastructure.	The	potential	for	sabotage	and	terrorism	– or	even	just	trespassing	–

are	also	among	the	many	risks	that	modern	infrastructure and	yachts	face.

As	a	result,	pursuant	to	federal	regulations	and	company	policy,	our	client’s	maintenance	

employees	routinely	inspect	the	infrastructure,	such	as	bridges,	tunnels,	support	structures,	

and	signals,	masts	and	rigging.	At	present,	this	work	is	done	primarily	by	company	personnel	in

motor	vehicles,	on	foot,	in	small	vessels,	via	being	suspended	in	the	rigging	or	in	other	

specialized	equipment.	This	is	often	a	labor-intensive	and	sometimes	arduous	job,	while	also	

being	inherently	dangerous.	While	our	clients	do	all	they	can	to	make	these	inspections	as	safe	
as	possible,	there	is	an	irreducible	element	of	risk	involved	whenever	employees	are	required	

to	go	out	on	structures or	up	in	the	rigging	over	water.	Employees	may	need	to	climb	over	or	

onto	structures,	which	can	be	slippery,	rough,	and/or	exposed	to	the	elements.	Some	

structures,	such	as	bridges or	masts,	are	high	above	the	ground or	water.	Equipment	moving	

through	inspection	zones	can	increase	risk	as	well,	especially	in	high-traffic	areas.	While	the	use	

of	sUAS	for	supplemental	infrastructure	and	general	asset	evaluation	would	not	eliminate

these	risks	entirely	(as	it	is	an	additive	safety	measure),	it	would	reduce	the	risks	to	

employees	by	allowing	for remote	aerial	review.

Additionally,	the	sheer	amount	of	assets	and	the	widely	dispersed	locations	– in	many	instances	

far	from	sizeable	population	centers	– means	that	visual	inspection	in	all	instances	by	company	

personnel	can	be	inefficient and	extremely	costly.	Aerial	analysis	by	traditional	fixed	wing	

aircraft	is	impractical	because	the	required	altitudes	for	safe	flight	reduce	visibility	below	

meaningful	levels	– it	is	simply	not	possible	to	see	all	asset	anomalies	from	such	heights.	

Helicopters	present	better	vantage	points;	however	manned	helicopters	are	much	more	costly,	

subject	to	human	safety	and	carry	highly	explosive	jet	fuel	making	them	impractical	for	

deployment.	By	using	sUAS	for	supplemental	asset	evaluation,	Katherine	Lovelace will	be	able

to	substantially	upgrade	its	capacity	to	detect	and	address	issues	with	the	right-of-way	and	

other	assets	before	they	become	a	problem	for	safe	operations.	Thus,	the	use	of	sUAS	has	the	

potential	to	improve	efficiency,	resulting	in	faster	and	safer	delivery	of	goods,	energy	&	natural	

resources	vital	to	the	U.S.	economy.

Granting	an	Exemption	will	not	Adversely	Affect Safety

Katherine	Lovelace notes	that	there	is	no	applicable	standard	for	an	equivalency	determination.	

Some	have	argued	that	the	appropriate	standard	is	that	for	model	aircraft,	noting	that	their	

operations,	if	conducted	for	recreational	purposes,	would	fall	completely	within	the	allowable	

operations	for	model	aircraft.	We	believe	it	is	difficult	to	argue	that	there	is	sufficient	

correlation	between	model	operations	controlled	by	the	Academy	of	Model	Aeronautics	and	the	

ones	contemplated	by	Katherine	Lovelace.	At	the	same	time,	it	is	clear	that	equivalency	cannot	

be	established	for	traditional,	manned	civil	aircraft	because	the	design	and	use	profiles	between	

traditional	aircraft	and	sUAS	are	simply	too	different.	As	such,	we	believe	it	makes	more	sense	

to	focus	on	why	the	contemplated	operations	would	not	adversely	affect	safety,	which	is	all	that	

§11.81(e)	requires.

Granting	an	exemption	will	not	adversely	affect	safety.	Katherine	Lovelace contemplates	

conducting	sUAS	operations	over	client	owned	or	controlled	land or	property,	solely	during	

daylight	hours,	at	altitudes	well	below	that	which	would	pose	a	risk	to	other	aircraft.	In	

general,	sUAS	operations	are	intended	to	be	conducted	in	areas	distant	from	both	congested	

areas	and	airports.	Moreover,	because	of	the	inherent	risks	presented	by	standard	

infrastructure	operations,	our	clients	have	already	taken	steps	to	secure	property	against	

unauthorized	public	access.	For	example,	substantial	stretches	of	pipeline,	utilities,	railroad	

track	and	yacht	docking	facilities are	fenced,	elevated,	or	otherwise	secured	to	prevent	access.	

Other	long	stretches	of	infrastructure	are,	as	noted	above,	in	very	remote	wilderness	areas.	

The	nature	of	operations	anticipated	by	Katherine	Lovelace requires	that	the	sUAS	be	flown	at	

relatively	low	altitudes	and	relatively	low	speeds.	Katherine	Lovelace expects	that	in	most	

instances,	the	sUAS	will	be	flown	less	than 75	feet	from	the	highest	structure	along	the	path	of	

the	sUAS.	Accordingly,	the	risk	of	interference	with	another	aircraft	is	minimal.	Katherine	

Lovelace also	plans	to	conduct	sUAS	operations	at	least	five miles	from	any	public	airports	

(including	heliports).	In	the	event	an	operation	needs	to	be	conducted	closer	to	an	airport,	

Katherine	Lovelace will	inform	the	airport	operator	and	airport	air	traffic	control	tower	of	the	

contemplated	operation	and	will	comply	with	any	directions	issued	by	air	traffic	control	at	that	
airport.

Approval	of	exemptions	allowing	commercial	operations	of	sUASs	in	the	infrastructure	aerial	

inspection and	photography industry	will	enhance	safety	by	reducing	risk.	Conventional	

operations,	using	jet	or	piston	power	aircraft,	operate	at	extremely	low	altitudes	just	feet	from	

the	subject	being	inspected	and	in	extreme	proximity	to	people	and	structures;	and	present	

the	risks	associated	with	vehicles	that	weigh	in	the	neighborhood	of	4,000lbs.,	carrying	large	

amounts	of	jet	A	or	other	fuel	(140	gallons	for	jet	helicopters).	Such	aircraft	must	fly	to	and	

from	the	inspection	site.	In	contrast,	a	sUAS	weighing	fewer	than	55	lbs.	and	powered	by	

batteries	eliminates	virtually	all	of	that	risk	given	the	reduced	mass	and	lack	of	combustible	

fuel	carried	on	board.	The	sUAS	is	carried	to	the	inspection	site.	The	sUAS	will	carry	no	

passengers	or	crew	and,	therefore,	will	not	expose	them	to	the	risks	associated	with	manned	

aircraft	flights.

The	operation	of	small	UASs,	weighing	less	than	55	lbs.,	conducted	in	the	strict	conditions	

outlined	above,	will	provide	an	equivalent	level	of	safety	supporting	the	grant	of	the	

exemptions	requested	herein,	including	333	Aircraft	Exemption	Status	exempting	the	applicant	

from	conventional	aircraft	requirements	and	allowing	commercial operations.	These	

lightweight	aircraft	operate	at	slow	speeds,	close	to	the	ground,	and	in	a	controlled	

environment	and,	as	a	result,	are	far	safer	than	conventional	operations	conducted	with	

turbine	helicopters	operating	in	close	proximity	to	the	ground	and	people.

The	safety	of	those	on	the	ground	is	protected	by	the	fact	that	no	one	will	be	allowed	into	the	

area	without	the	permission	of	the	company.	Security	will	be	established	for	the	flight	area	as	

part	of	the	pre-flight	control.	Each	individual	within	the	secure	area	will	be	briefed	prior	to	flight	

and	will	consent	to	being	in	the	area.	All	others	will	be	excluded	from	the	area.

Katherine	Lovelace initially	intends	to	use	a	dedicated	staff	for	sUAS	operations.	All	operations	

will	be	within	visual	line-of-sight	(i.e.,	no	more	than	approximately	0.5	miles	from	the	

manipulator	of	the	controls,	or	pilot	in	command	(PIC)).	Each	PIC	will	conduct	at	least	three	

take-offs	and	landings	with	the	sUAS	on	which	he	or	she	is	trained	every	90	days.	PIC’s	will	

establish	their	qualifications	thru	a	combination	of	aeronautical	knowledge,	UAS	airmanship	

skills,	and	verification	through	testing	of	flight	ability	before	infrastructures	operations	have	

commenced.	Depending	on	the	type	of	operation,	additional	ground-based	visual	observers	

may	be	employed	as	well.	These	observers	will	be	within	constant	visual	line	of	sight	and	in	

constant	contact	with	the	PIC.	The	visual	observers	will	assist	the	PIC	in	avoiding	objects	near	

the	sUAS.

There	are	no	standards	for	either	Private	or	Commercial	sUAS	pilot	certificates.	The	safe	

operation	and	control	of	the	UAS	as	described	in	this	application	does	not	depend	on	the	type	

of	FAA	license	held	by	the	PIC.	Given	the	restricted	and	controlled	airspace	within	which	

operations	will	take	place,	the	key	factors	needed	by	the	PIC	are	knowledge	of	the	airspace	

within	which	the	operation	will	take	place	and	how	that	airspace	fits	into	the	National	Airspace	

System	(NAS).	That	knowledge	can	be	and	is	gained	primarily	through	ground	school	and	not	

through	flight	training	in	fixed	wing	or	rotor	aircraft,	nor	is	it	dependent	on	the	acquisition	of	a	

commercial	or	private	pilot’s	certificate.	Those	certificates	demonstrate	knowledge	of	the	

factors	and	skills	needed	for	the	safe	operation	of	those	types	of	aircraft	(fixed	wing	or	

rotorcraft).	It	cannot	be	assumed	that	a	commercial	pilot,	approved	to	operate	a	helicopter	or	

fixed	wing	aircraft,	has	the	skill	or	ability	to	safely	operate	a	small	unmanned	aerial	vehicle,	

operating	at	400	AGL	or	lower,	within	strictly	controlled	pre-approved	airspace.	Besides	

knowledge	of	airspace	regulations,	dexterity	in	the	control	and	operation	of	the	sUAS	acquired	

from	actual	operation	of	the	aircraft	is	the	most	important	factor	in	establishing an	equivalent	
level	of	safety.

If	the	PIC	has	acquired	the	necessary	knowledge	of	airspace	requirements,	the	relevant	issues	

are	(1)	where	the	aircraft	will	be	flown,	(2)	the	size	of	the	aircraft	relative	to	what	is	being	used	

today	to	accomplish	the	same	mission,	and	(3)	what	precautions	will	be	taken	to	ensure	the	

safety	of	those	in	the	area	of	operation.	We	propose	that	the	PIC	has	at	least	an	FAA	Private	

Pilots	Certificate	and	a	Class	III	medical;	the	aircraft	be	operated	within	a	secure	environment;	

and	that	no	one	be	allowed	to	enter	the	secure	environment	unless	they	are	part	of	the	

operation,	have	been	fully	briefed	of	the	risks	prior	to	operation	of	the	sUAS,	and	have	

consented	to	the	risks	associated	with	being	in	the operating	area.	Should	there be	a	mishap,	

the	sUAS	being	flown	pose	significantly	less	of	a	threat	than	the	helicopters	and	fixed	wing	

aircraft	now	being	employed	because	they	are	a	fraction	of	the	size,	carry	no	flammable	fuel,	

do	not	carry	crew	or	passengers,	and	pose	an	infinitesimal	risk	to	others.	This	is	in	stark	

contrast	to	conventional	aircraft	that	are	flown	to	the	site,	carry	explosive	fuel,	carry	

passengers	and	crew,	and	operate	in	a	much	larger	area.

From	a	practical	standpoint,	there	are	relatively	few	licensed	full-scale	aircraft	pilots	who	are	

also	qualified	to	fly	the	type	of	sUAS	that	are	utilized	for	infrastructure	image-capture	

operations.	There	are	even	fewer	commercial	pilots	that	can	fly	these	sUAS	– to	the	point	that	

to	do	both	is	considered	rare.	Assuming	that	it	is	unlikely	for	a	company	to	find	a	pilot	that	has	

both	qualifications,	that	company	would	either	have	to	source	a	qualified	sUAS	pilot	to	train	and	

obtain	a	commercial	certificate,	or	find	a	commercial	certificated	pilot	who	would	be	willing	to	

learn	to	fly	a	sUAS	to	the	competency	level	required	for	professional	use.

Minimum	requirements	for	the	PIC	include:

1) Private	Pilot’s	license	and	a	Class	III	medical;

2) A	minimum	of	200	flight	cycles	and	25	hours	of	total	time	as	a	sUAS	rotorcraft	pilot	

and	at	least	10	hours	logged	as	a	sUAS	pilot	with	a	similar	sUAS	type	(single	blade	or	

multirotor);

3) A	minimum	of	5	hours	as	sUAS	pilot	with	the	make	and	model	of	sUAS	to	be	utilized	

for	operations	under	the	exemption	and	3	take	offs	and	landings	in	the	preceding	90	

days;

4) Have	undergone	a	qualification	process	as	specified	in	the	Flight	Operations	&	

Procedures	Manual	consisting	of	a	knowledge	&	skill	test	of	the	aircraft	to	be	used.

Another	consideration	supporting	the	certificate	requirement	is	that	pilots	holding	a	private	

pilot	certificate	are	subject	to	security	screening	by	the	Department	of	Homeland	Security.	

This	requirement	should	ameliorate	security	concerns	over	UAS	operations	under	this	

exemption.

Katherine	Lovelace intends	to	use	commercially	available	sUAS	Components	for	sUAS.	These	

sUAS	systems	will	be	tested	for	quality	&	safety	in	our	test	facility	before	being	deployed	to	

the	field.	The	sUAS	is	less	than	55	lbs.	fully	loaded,	carries	neither	a	pilot	nor	passenger,	and	

operates	exclusively	within	a	secured	area.	We	have	a	routine	maintenance	schedule	to	verify	

that	the	sUAS	will	remain	in	safe	and	operational	condition.		Please	see	Appendix	B,	for	

Specific	Types	of sUAS.

Notes	Regarding:		14	C.F.R.	Part	21,	Subpart	H

In	accordance with the	statutory criteria	provided in	Section 333 of	PL	112---95 in	reference	

to	49	USC	44704,	and	in	consideration	of	the	size,	weight,	speed,	and	limited	operating	area	

associated	with	the	aircraft	and	its	operation,	we	request	that	this				aircraft	exemption	

meets	the	conditions	of	Section	333.	Therefore,	if granted	Section					333	relief	of	14	CFR	
part	21,	and	any	associated	noise	certification	and	testing	requirements	of	part	36,	is	not

necessary.

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

Given	the	size	of	the	sUAV,	two-inch	lettering	will	be	impossible.	UA	will	be	identified	by	serial	

number,	registered	in	accordance	with	14	CFR	part	47,	and	have	identification	(N---Number)

markings in	accordance with 14	CFR part 45, Subpart C.	Markings will be			as		large		as

practicable.

Notes	Regarding:		14	CFR	§	91.7(a)	Civil	Aircraft	Airworthiness

Katherine	Lovelace’s request	is	based	on	the	fact	that	no	airworthiness	certificate	will	be	issued	

for	the	UAS.	Katherine	Lovelace’s UAS	will	not	require	an	airworthiness	certificate	in	

accordance	with	14	CFR	part	21,	Subpart	H.	Based	on	the	fact	that	an	airworthiness	certificate	

will	not	be	issued,	exemption	from	§	91.7(a)	is	not necessary.

Notes	Regarding:	14	CFR	§	91.9(b)(2)	Civil	aircraft	flight	manual,	marking	&	placard	

Certifications	required,	the	original	intent	of	these	regulations	was	to	display	an	aircraft’s	

airworthiness,	certification,	and	registration	documents	so	they	would	be	easily	available	to	

inspectors	and	passengers.	Based	on	the	FAA	Memorandum	subject	“Interpretation	regarding	

whether	certain	required	documents	may	be	kept	at	an	unmanned	aircraft’s	control	station,”	

dated	August	8,	2014,	the	requested	relief	from	14	CFR	§§	91.9(b)(2)	and	91.203(a)	and	(b)	is	

not	necessary.

Notes	Regarding:	§91.109	Flight	instruction;	Simulated	instrument	&	certain	flight	tests	Small	

UASs,	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.	Aircraft	being	considered	for	use	by	Katherine	Lovelace allow	the	UAS	

Instructor	to	place	the	aircraft	into	‘loiter’	mode	(fixed	altitude	stationary	hold).	In	the	event	of	

the	student	losing	control,	the	UAS	Instructor	can	quickly	and	via	alternate	equipment	

(equipment	not	in	the	hands	of	the	student)	place	the	aircraft	into	a	mode	that	then	allows	the	

instructor	to	bring	the	aircraft	back	into	control	and	back	to	the	pre- determined	and/or	safe	

landing	location.

Katherine	Lovelace does	not	describe	training	scenarios	in	which	a	dual	set	of	controls	would	

be	utilized	or	required,	i.e.	dual	flight	instruction,	provided	by	a	flight	instructor	or	other	

company-designated	individual,	that	would	require	that	individual	to	have	fully	functioning	

dual	controls.	Rather,	Katherine	Lovelace	evaluates	the	qualification	of	its	PICs	based	on	their	

experience	with	the	UAS	to	be	operated	and	verifies	through	testing,	in	lieu	of	formalized	

training.	As	such,	Katherine	Lovelace	does	not	seek	relief	from	14	CFR	§	91.109.

Notes	Regarding	§	14	CFR	91.119(b)

Relief	from	§	14	CFR	91.119(b),	operation	over	congested	areas,	is	not	applicable,	because	the	

Katherine	Lovelace’s	operations	will	only	be	conducted	within	the	secured	area	described	

herein.

Katherine	Lovelace’s	Safety	Operations	&	Procedures	Overview:

Technology Considerations:

Best-in-class, tried and proven technologies that are in advanced iterations. Software

from	highly-reputable industry partners will include features -
1. Auto	descent	(landing)	if	communication	signal	were	to	be	severed.	If	the	sUAS	

loses	communications,	the	sUAS	will	have	capability	to	return	to	a	predetermined	location	within	the	Security	Perimeter	andland.

2. Auto descent (landing) if battery were to drop lower than nominal level.

3. Flights will be terminated at 25% battery power reserve.

4. Live	 video	 for	 operator	 gives	 real-time	 positioning	 feedback.	In	 other	 words,	

we	can monitor the scene from the vehicle's perspective for collision avoidance,

and to	maintain	spatialorientation.

5. The sUAS will have the capability to abort a flight in case of unpredicted obstacles	

or emergencies.

6. On-Screen-Display (OSD) contains operating information to ascertain vehicle	

health	at	all	times:	speed,	altitude,	number	of	GPS	satellites	(when	available),	

heading	and voltage.

7. GPS lock supplies for return-to-home (RTH). Should Command and Control (C2)	

link	 failures	occur	 (highly	improbable),	vehicle	 returns	automatically	 to	 the	point

of	launch.

8. Altitude	information	will	be	provided	to	the	sUAS	pilot	via	a	digitally	encoded	

telemetric data feed, which downlinks from the aircraft to a ground-based onscreen	display. This altitude information will be generated by equipment installed

on board	the	aircraft,	using	GPS	triangulation,	or	digitally	encoded	barometric	

altimeter,	or	radio	altimeter,	or	any	combination	thereof.	Prior	to	each	flight,	a	

zero	altitude	initiation point will be established and confirmed for accuracy by the

pilot.

Mechanical/Physical:

1. We will fly line-of-sight (LOS) only. The vehicle will always remain in direct LOS	to	

the	pilot,	thus	eliminating	the	concern	of	signal	severance	(flying	behind	

objects/walls).

2. The sUAS will weigh less than 55 lbs and travel at less than 50 knots.

3. Batteries should far exceed the capacity required for actual flight time.

4. Flights will be operated at an altitude of no more than 400 feet AGL.

5. Fireproof bags for storage and charging of high capacity Lipo batteries on-site.

6. UA operated under this exemption will be marked in accordance with 14 CFR	

part 45 or as otherwise authorized by the FAA.

7.

Personnel:

1. Spotters ensure safe operation and act as a redundant set of eyes for

operators	(pilot,	gimbal	op, director)

2. Radio spectrum analysis for interference on the frequencies utilized for

vehicle	control/communication.

3. A	briefing	will	be	conducted	in	regard	to	the	planned	sUAS	operations	prior	to	

each day’s activities. It will be mandatory that all personnel who will be

performing	duties within the boundaries of the safety perimeter be present for

this briefing.

4. The operator will obtain the consent of all persons involved in the sUAS operations

and ensure that only consenting persons will be allowed within 100 feet of the flight	

operations.

5. Observer and pilot will at all times be able to communicate by voice.

6. Written and/or oral permission from the relevant property holders will be
obtained.

7. Pilot and observer will have been trained in operation of UAS generally and	

received up-to-date information on the particular UAS to be operated.

Operations:

1. The	unmanned	aircraft	(UA)	must	weigh	less	than	55	pounds	(25	Kg),	including	

energy	source(s)	and	equipment.	Operations	authorized	by	this	petition	of	exemption	

are	limited	to	the	following	aircraft	described	in	Appendix	B.	Proposed	operations	of	

any	other	aircraft	will	require	a	new	petition	or	a	petition	amendment	to	this	request.

2. The	UA	may	not	be	flown	at	a	ground	speed	exceeding	50	knots.

3. Flights	must	be	operated	at	an	altitude	of	no	more	than	400	feet	above	ground	

level	(AGL),	as	indicated	by	the	procedures	specified	in	the	operator’s	manual.	All	

altitudes	reported	to	ATC	must	be	in	feet	AGL.

4. The	UA	must	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	medical	certificate.

5. All	operations	must	utilize	a	visual	observer	(VO).	The	VO	may	be	used	to	satisfy	

the	VLOS	requirement	as	long	as	the	PIC	always	maintains	VLOS	capability.	The	VO	

and	PIC	must	be	able	to	communicate	verbally	at	all	times.

6. The	operator’s	manual	included	as	Appendix	C	and	this	petition	of	exemption	must	

be	maintained	and	made	available	to	the	Administrator	upon	request.	If	a	discrepancy	

exists	between	the	conditions	and	limitations	in	this	exemption	and	the	procedures	

outlined	in	the	operator’s	manual,	the	conditions	and	limitations	herein	take	

precedence	and	must	be	followed.	Otherwise,	the	operator	must	follow	the	

procedures	as	outlined	in	its	operator’s	manual.

The	operator	may	update	or	revise	its	operator’s	manual.	It	is	the	operator’s	

responsibility	to	track	such	revisions	and	present	updated	and	revised	documents	to	

the	Administrator	upon	request.	The	operator	must	also	present	updated	and	revised	

documents	if	it	petitions	for	extension	or	amendment.	If	the	operator	determines	that	

any	update	or	revision	would	affect	the	basis	for	which	the	FAA	grants	this	petition	for	

exemption,	then	the	operator	must	petition	for	amendment	to	their	exemption.	The	

FAA’s	UAS	Integration	Office	(AFS-80)	may	be	contacted	if	questions	arise	regarding	

updates	or	revisions	to	the	operator’s	manual.

Prior	to	each	flight	the	PIC	must	inspect	the	UAS	to	ensure	it	is	in	a	condition for	safe	

flight. If	the	inspection	reveals	a	condition	that	affects	the	safe	operation	of	the	UAS,	the	

aircraft	is	prohibited	from	operating	until	the	necessary	maintenance	has	been	

performed	and	the	UAS	is	found	to	be	in	a	condition	for	safe	flight.	The	Ground	Control	

Station,	if	utilized,	must	be	included	in	the	preflight	inspection.	All	maintenance	and	

alterations	must	be	properly	documented	in	the	aircraft	records.

7. Any	UAS	that	has	undergone	maintenance	or	alterations	that	affect	the	UAS	

operation	or	flight	characteristics,	e.g.	replacement	of	a	flight	critical	component,	must	

undergo	a	functional	test	flight	in	accordance	with	the	operator’s	manual.	The	PIC	who	

conducts	the	functional	test	flight	must	make	an	entry	in	the	UAS	aircraft	records	of	the	

flight.	The	requirements	and	procedures	for	a	functional	test	flight	and	aircraft	record	
entry	must	be	added	to	the	operator’s	manual.

8. The	operator	must	follow	the	manufacturer’s	UAS	aircraft/component,	

maintenance,	overhaul,	replacement,	inspection,	and	life	limit	requirements.	When	

unavailable,	aircraft	maintenance/component/overhaul,	replacement,	and	

inspection/maintenance	requirements	must	be	established	and	identified	in	the	

operator’s	manual.	At	a	minimum,	requirements	for	the	following	must	be	included	

in	the	operator’s	manual:

a. Actuators	/	Servos;

b. Transmission	(single	rotor);

c. Powerplant	(motors);

d. Propellers;

e. Electronic	speed	controller;

f. Batteries;

g. Mechanical	dynamic	components	(single	rotor);

h. Remote	command	and	control;

i. Ground	control	station	(if	used);	and

j. Any	other	components	as	determined	by	the	operator;

9. The	Pilot	In	Command	(PIC)	must	possess	at	least	a	private	pilot	certificate	and	at	

least	a	current	third-class	medical	certificate.	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.

10. Prior	to	operations	conducted	for	the	purpose	of	infrastructure	inspections,	the	PIC	

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

minimum	of	200	flight	cycles	and	25	hours	of	total	time	as	a	UAS	rotorcraft	pilot	and	at	

least	10	hours	logged	as	a	UAS	pilot	with	a	similar	UAS	type	(single	blade	or	multirotor).	

Prior	documented	flight	experience	that	was	obtained	in	compliance	with	applicable	

regulations	may	satisfy	this	requirement.	Training,	proficiency,	and	experience-building	

flights	can	also	be	conducted	under	this	petition	of	exemption	to	accomplish	the	

required	flight	cycles	and	flight	time.	During	training,	proficiency,	and	experiencebuilding	flights,	all	persons	not	essential	for	flight	operations	are	considered	

nonparticipants,	and	the	PIC	must
operate	the	UA	with	appropriate	distance	from	nonparticipants	in	accordance	with	14	

CFR	§	91.119.

11. Prior	to	operations	conducted	for	the	purpose	of	infrastructure	inspection,	the	PIC	

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

minimum	of	five	hours	as	UAS	pilot	operating	the	make	and	model	of	UAS	to	be	utilized	

for	operations	under	the	exemption	and	three	take-offs	and	three	landings	in	the	

preceding	90	days.	Training,	proficiency,	experience- building,	and	take-off	and	landing	

currency	flights	can	be	conducted	under	this	petition	of	exemption	to	accomplish	the	

required	flight	time	and	90	day	currency.	During	training,	proficiency,	experiencebuilding,	and	take-off	and	landing	currency	flights	all	persons	not	essential	for	flight	

operations	are	considered	nonparticipants,	and	the	PIC	must	operate	the	UA	with	

appropriate	distance	from	nonparticipants	in	accordance	with	14	CFR	§	91.119.

12. Prior	to	any	flight	operations	authorized	by	this	petition	of	exemption,	the	PIC	and	

VO	must	have	successfully	completed	a	qualification	process,	as	outlined	in	the	

operator’s	manual.	As	this	is	a	requirement	stipulated	by	the	operator,	the	test	must	be	

developed	and	implemented	by	a	qualified	person	designated	at	the	sole	discretion	of	

the	operator.	A	record	of	completion	of	this	qualification	process	must	be	documented	

and	made	available	to	the	Administrator	upon	request.

13. Prior to operations conducted for the purpose of infrastructure inspection, a

flight	demonstration,	administered	by	an	operator-approved	and	-qualified	pilot	

must	be	successfully	completed	and	documented.	This	documentation	must	be	

available	for	review	upon	request	by	the	Administrator.	Because	the	knowledge	

and	airmanship	test	qualifications	have	been	developed	by	the	operator,	and	there	

are	no	established	practical	test	standards	that	support	a	jurisdictional	FAA	FSDO	

evaluation	and	approval	of	company	designated	examiners,	the	petitioner	will	

conduct	these	tests	in	accordance	with	the	operator’smanual.

14. The	UA	may	not	be	operated	directly	over	any	person,	except	authorized	and	

consenting personnel, below an altitude that is hazardous to persons or property

on	the surface in the event of a UAS failure or emergency.

15. Regarding the distance from participating persons, the operator’s manual

has	safety	mitigations	for	authorized	and	consenting	personnel.	At	all	times,	

those	persons	must	be	essential	to	theoperations.

16. Regarding	distance	from	nonparticipating	persons,	the	operator	must	ensure	

that	no	persons	are	allowed	within	500	feet	of	the	area	except	those	consenting	to	

be	involved	and	necessary	for	the	infrastructure	inspection	operations.	This	

provision	may be reduced to no less than 200 feet if it would not adversely affect

safety and the	Administrator	has	approved	it.	For	example, an	equivalent	level	of	

safety	may	be	determined	by	an	aviation	safety	inspector’s	evaluation	of	the	

infrastructure	inspection	area	to	note	terrain	features,	obstructions,	buildings,	

safety	barriers,	etc.	Such	barriers	may	protect	nonparticipating	persons	(observers,	

the	public,	news	media, etc.) from debris in the event of an accident.
17. If the UAS loses communications or loses its GPS signal, the UA must return to a	

pre-determined	location	within	the	security	perimeter	and	land	or	be	recovered	in	

accordance	with	the	operator’smanual.

18. The UAS must abort the flight in the event of unpredicted obstacles

or	emergencies in accordance with the operator’s manual.

19. Each UAS operation must be completed with 25% battery power remaining.

20. The	operator	must	obtain	an	Air	Traffic	Organization	(ATO)	issued	Certificate	of	

Waiver or Authorization (COA) prior to conducting any operations under this petition	

of	exemption.	This	COA	will	also	require	the	operator	to	request	a	Notice	to	Airman	

(NOTAM)	not	more	than	72	hours	in	advance,	but	not	less	than	48	hours	prior	to	

the	operation.

21. All	aircraft	operated	in	accordance	with	this	exemption	must	be	identified	by	

serial	number,	registered	in	accordance	with	14	CFR	part	47,	and	have	identification	

(N-Number) markings in accordance with 14 CFR part 45, Subpart C. Markings must	

be	as	large	as practicable.

22. The operator must develop procedures to document and maintain a record of

the	UAS	maintenance,	preventative	maintenance,	alterations,	status	of	

replacement/overhaul	component	parts,	and	the	total	time	in	service	of	the	UAS.	

These	procedures	must	be	added	to	the	operator’smanual.

23. Each UAS operated under this exemption must comply with all

manufacturer	Safety Bulletins.

24. The operator must develop UAS technician qualification criteria. These criteria	

must	be	added	to	the	operator’smanual.

25. The	preflight	inspection	section	in	the	operator’s	manual	must	be	amended	

to	include	the	following	requirement:	The	preflight	inspection	must	account	for	

all	discrepancies, i.e. inoperable components, items, or equipment, not covered

in the	relevant preflight inspection sections of the operator’s manual.

26. Before	conducting	operations,	the	radio	frequency	spectrum	used	for	

operation	and control of the UA must comply with the Federal Communications

Commission	(FCC) or other appropriate government oversight agency

requirements.

27. At	least	three	days	before	scheduled	infrastructure inspection,	the	operator	of	

the	UAS	affected	by	this	exemption	must	submit	a	written	Plan	of	Activities	to	the	

local	FSDO with jurisdiction over the area of proposed infrastructure inspection. The

3-day	notification	may	be	waived	with	the	concurrence	of	the	FSDO.	The	plan	of	

activities	must	include	at	least	thefollowing:

a. Dates	and	times	for	allflights;

b. Name and phone number of the operator for the UAS infrastructure
inspection operations conducted under this petition of exemption;

c. Name and phone number of the person responsible for the onscene	operation	of	the UAS;

d. Make,	model,	and	serial	or	N-number	of	UAS	to	beused;

e. Name and certificate number of UAS PICs involved in the infrastructure	

inspection event;

f. A	statement	that	the	operator	has	obtained	permission	from	property	

owners	and/or	local	officials	to	conduct	the	infrastructure	inspection	event;	

the list of those who gave permission must be made available to the

inspector	upon request;

g. Signature	of	exemption-holder	or	representative;and

h. A description of the flight activity, including maps or diagrams of any area,	

city,	town,	county,	and/or	state	over	which	infrastructure	inspection	will	be	

conducted and the altitudes essential to accomplish the operation.

28. The	documents	required	under	14	CFR	§§	91.9 and	91.203	must	be	available	

to	the PIC at the Ground Control Station of the UAS any time the aircraft is

operating.	These	documents	must	be	made	available	to	the	Administrator	or	any	

law	enforcement	official	uponrequest.

29. The	UA	must	remain	clear	and	yield	the	right	of	way	to	all	other	manned	

operations and activities at all times (including, but not limited to, ultralight

vehicles,	parachute	activities,	parasailing	activities,	hang	gliders,etc.).

30. UAS operations may not be conducted during night, as defined in 14 CFR § 1.1.	

All	operations	must	be	conducted	under	visual	meteorological	conditions	(VMC).	

Flights under special visual flight rules (SVFR) are not authorized.

31. The UAS may not be operated by the PIC from any moving device or vehicle.

32. The	UA	may	not	be	operated	less	than	500	feet	below	or	less	than	2,000	feet	

horizontally from a cloud or when visibility is less than 3 statute miles from the PIC.

33. The	UA	may	not	operate	in	Class	B,	C,	or	D	airspace	without	written	approval	

from	the	FAA.	The	UA	may	not	operate	within	5	nautical	miles	of	the	geographic	

center	of	a	non-towered	airport	as	denoted	on	a	current	FAA-published	

aeronautical	chart	unless	a	letter	of	agreement	with	that	airport’s	management	is	

obtained,	and	the	operation	is	conducted	in	accordance	with	a	NOTAM	as	required	

by	the	operator’s	COA. The letter of agreement with the airport management must

be made available to	the	Administrator	upon request.

34. Any	incident,	accident,	or	flight	operation	that	transgresses	the	lateral	or	

vertical	boundaries of the operational area as defined by the applicable COA must

be reported	to	the	FAA’s	UAS	Integration	Office	(AFS-80)	within	24	hours.	Accidents	

must	be	reported	to	the	National	Transportation	Safety	Board	(NTSB)	per	

instructions	contained	on	the	NTSB	Web	site:	www.ntsb.gov. Further	flight	

operations	may	not	be conducted until the incident, accident, or transgression is

reviewed by AFS-80 and	authorization	to	resume	operations	isprovided.
Support	for	Petition	for Exemption

In	accordance	with	the	procedural	requirements	of	14	C.F.R.	§11.81,	Katherine	Lovelace

provides	the	following	information:

Contact	Information:

Katherine	Lovelace

135	Hilton	St.	#2

Tiverton,	RI	02878

(203)	550-5845

klovelace84@gmail.com

Regulatory	Provisions	from	which	Katherine	Lovelace seeks	an Exemption

Katherine	Lovelace	believes	it	may	need	an	exemption	from	the	following	provisions	

to	conduct	the	contemplated	operations.	In	some	instances,	relief	is	needed	because	relief	

from	another	provision	renders	compliance	with	the	regulation	at	hand	infeasible.

333	Aircraft	Exemption	Status	14	

C.F.R.	§61.113(a)	and	(b)

14	C.F.R.	§91.119(c)

14	C.F.R.	§91.121

14	C.F.R.	§91.151

14	C.F.R.	§91.405(a)

14	C.F.R.	§91.407(a)

14	C.F.R.	§91.409(a)(1)&(2)

14	C.F.R.	§91.417(a)&(b)

Katherine	Lovelace believes	an	exemption	is	only	needed	from	the	above-listed	

regulatory	provisions.	To	the	extent	that	the	FAA	believes	that	additional	relief	is	required	for	

Katherine	Lovelace to	conduct	the	operations	described	here,	we	request	an	exemption	from	

any	such	regulatory	provisions	as well.3

3	For	example,	14	C.F.R.	§91.417(a)	imposes	certain	maintenance	record	keeping	

requirements	“as	applicable”.	Since	none	of	the	underlying	requirements	(e.g.,	inspection	

intervals)	can	be	met	and	will	require	an	exemption,	Katherine	Lovelace believes	a	separate	

exemption	should	not	be	required	for §91.417(a).
The	Extent	of	Requested	Relief	and	the	Reasons	Relief	is Needed

Section	333	Aircraft	Exemption Status:

Section	333	of	the	Modernization	Act	authorizes	the	FAA	to	exempt	aircraft	from	the	

requirement	for	an	airworthiness	certificate	based	on	a	consideration	of	the	size,	weight,	

speed,	operational	capability	of	the	particular	UAS,	as	well	as	its	proximity	to	airports	and	

populated areas. An analysis of these criteria demonstrates that the sUAS operated without

an	airworthiness	certificate	in	the	areas	and	under	the	conditions	contemplated	by	

Katherine	Lovelace will	be	at	least	as	safe,	or	safer,	than	a	conventional	aircraft	(fixed	wing	

or	rotorcraft)	operating	with an airworthiness certificate without the conditions proposed in

this request.

The	sUAS	is	less	than	55	lbs.	fully	loaded,	carries	neither	a	pilot	nor	passenger,	and	operates	

exclusively within a secured area. Unlike other civil aircraft, operations under this exemption	

will	be	tightly	controlled	and	monitored	by	the	operator	and	observer.	Operations	will	be	

conducted	in	compliance	with	the	FAA	and	with	local	public	safety	requirements	to	provide	

security for the area of operation as is now done with conventional equipment,

infrastructure,	bridge,	yacht	and	out	building	evaluation.	These	safety	enhancements	

provide	an	expanded	degree	of	safety	to	the	inspectors	over	conventional	operations.	

Lastly,	application	of	these	same	criteria	demonstrates	that	there	is	no	credible	threat	to	

national	security	posed	by	the	sUAS,	due	to	its	size,	speed	of	operation,	location	of	

operation,	lack	of	explosive	materials	and	inability	to	carry	a	substantial	externalload.

Given	the	size	and	limited	operating	area	associated	with	the	aircraft	to	be	utilized	by	the	

Applicant,	this	meets	the	requirements	of	an	equivalent	level	of	safety	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	requirement	for	an	

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

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

these	criteria	demonstrates	that	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.

14	C.F.R.	§61.113(a)	and	(b)

§61.113	Private	pilot	privileges	and	limitations:	Pilot	in	command.

(a) Except	as	provided	in	paragraphs	(b)	through	(h)	of	this	section,	no	person	who	

holds	a	private	pilot	certificate	may	act	as	pilot	in	command	of	an	aircraft	that	is	

carrying	passengers	or	property	for	compensation	or	hire;	nor	may	that	person,	for	

compensation	or	hire,	act	as	pilot	in	command	of	an	aircraft.

(b) A	private	pilot	may,	for	compensation	or	hire,	act	as	pilot	in	command	of	an	

aircraft	in	connection	with	any	business	or	employment	if:

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

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

hire.

*****

Katherine	Lovelace anticipates	using	specially	trained	staff	to	conduct	the	sUAS	

operations.	While	these	individuals	will	not	hold	commercial	pilot	licenses,	the sUAS will	not	

carry	property	for	compensation	or	hire	since	they	will	be	used	solely	to	assist	in	evaluation	of	

the	infrastructure,	equipment,	right-of-way,	assets,	bridges,	tunnels,	yachts	 and	out-buildings	
in	furtherance	of	Katherine	Lovelace’s client’s	primary	business,	the	successful	operation	of

infrastructure or	yachts;	however,	the	employees’	operation	of	the	sUAS	will	not	be	incidental	

to	their	employment	with	Katherine	Lovelace,	and	they	will	be	compensated	for	such	work.	

Without	an	exemption,	the	pilot	would	be	required	to	hold	a	commercial	pilot	certificate	under	

§61.133.	However,	the	risk	associated	with	the	contemplated	operations	is	less	than	the	risk	

posed	by	a	traditional	aircraft.	The	sUAS	will	fly	at	altitudes	well	below	the	permissible	limits for	

other	civil	aircraft,	eliminating	the	risk	to	other	aircraft,	and	within	a	geographical	envelope	

under	the	sole	control	of	Katherine	Lovelace’s	clients.	Accordingly,	the	risk	would	be	limited	to	

Katherine	Lovelace’s personnel,	who	will	be	appropriately	outfitted	in	safety	gear,	and	

Katherine	Lovelace’s client’s	property	on	the	ground.	Requiring	a	commercial	pilot	certificate	

would	provide	no	appreciable	safety	benefit	and	would	needlessly	impose	additional	cost	on	

Katherine	Lovelace.	Because	the	contemplated	operations	would	not	comply	with	§61.113(b)(1)	

and	none	of	the	other	exceptions	to	paragraph	(a)	apply,	relief	is	needed	from	both	paragraphs	

(a)	and	(b).

14	C.F.R.	91.119(c)

§91.119	Minimum	safe	altitudes:	General.

Except	when	necessary	for	takeoff	or	landing,	no	person	may	operate	an	

aircraft below	the	following	altitudes:

***

(c) Over	other	than	congested	areas.	An	altitude	of	500	feet	above	the	surface,	

except	over	open	water	or	sparsely	populated	areas.	In	those	cases,	the	aircraft	

may	not	be	operated	closer	than	500	feet	to	any	person,	vessel,	vehicle,	or	

structure.

*****

Katherine	Lovelace submits	that	the	only	relief	it	requires	from	§91.119	is	from	the	

minimum	altitudes	listed	in	paragraph	(c).	Relief	is	required	from	paragraph	(c)	for	fixed	wing	

operations	because	asset	evaluation	conducted	at	500	feet	or	higher	is	insufficiently	distinct	to	

be	meaningful.	Since	operations	at	this	altitude	also	pose	a	heightened	risk	of	collision	with	

another	aircraft,	safety	can	only	be	assured	through	the	grant	of	an	exemption.	The	anticipated	

rotorcraft	operations	should	be	adequately	addressed	by	paragraph	(d)	(1).	Additionally,	relief	

should	not	be	needed	from	paragraph	(a)	because	an	emergency	landing	of	the	aircraft	due	to	a	

power	failure	will	not	create	an	undue	hazard	to	persons	or	property	on	the	surface.	As	noted	

in	the	explanation	of	why	an	exemption	will	not	adversely	affect	safety,	Katherine	Lovelace’s	

clients	have exclusive	use	of	the	land	and	yachts	over	which	the	sUAS	will	be	operated,	and	

public	access	is	restricted.	It	also	has	exclusive	use	of	significant	portions	of	land	adjacent	to	the	

infrastructure	and	structures	that	will	be	the	objects	of	evaluation	and	analysis.	Katherine	

Lovelace’s	clients tightly	control	access	to	land	and	waterfront	and	have	the	ability	to	assure	

that	no	individuals	unassociated	with	the	planned	operations	are	on	the	affected	land.	As	such,	

the	risk	of	injury	is	minimal.	Katherine	Lovelace does	not	contemplate	conducting	operations	

over	congested	areas,	so	relief	is	not requested	from	paragraph	(b).

14	C.F.R.	91.121

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	sUAS	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	Manual	and	Safety	Check	list,	confirming	the	altitude	of	the	launch	site	shown	

on	the	GPS	altitude	indicator	before	flight.

Altitude	information	will	be	provided	to	the	sUAS	pilot	via	a	digitally	encoded	telemetric	

data	feed,	which	downlinks	from	the	aircraft	to	a	ground-based	on-screen	display.	This	

altitude	information	will	be	generated	by	equipment	installed	on	board	the	aircraft,	using	

GPS	triangulation,	or	digitally	encoded	barometric	altimeter,	or	radio	altimeter,	or	any	

combination thereof. Prior to each flight, a zero altitude initiation point will be established	

and	confirmed	for	accuracy	by	thepilot.

14	C.F.R.	91.151

§91.151	Fuel	requirements	for	flight	in	VFR	conditions.

(a) 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	–

(1) During	the	day,	to	fly	after	that	for	at	least	30	minutes.

(b) 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.

*****

Operating	the	sUAS	in	a	pre-defined	area	with	less	than	30	minutes	of	reserve	fuel	does	

not	raise	the	type	of	risk	contemplated	by	§91.151,	i.e.,	that	an	aircraft	could	run	out	of	fuel	in	

the	event	it	has	to	be	flown	to	an	alternate	airport	or	circle	the	planned	airport	in	the	event	of	

unanticipated	conditions.	Katherine	Lovelace does	not	intend	to	use	the	sUAS	for	point-to-point	

flights	and	will	not	operate	the	sUAS	beyond	visual	line	of	sight.	Nor	will	the	sUAS	require	an	

airport	in	order	to	land.	Rather,	Katherine	Lovelace will	operate	the	sUAS	using	pre-planned	

flight	paths	(taking	into	account	weather	conditions)	designed	to	allow	the	sUAS	to	fly	to	the	

point	of	intended	landing.	As	such,	there	is	no	need	for	a	time- based	excess	fuel	requirement.	

Rather	it should	be	sufficient	to	require	only	as	much	additional	excess	flight	capacity	as	

necessary	to	safely	land	the	sUAS.	We	believe	that	a	25%	battery	reserve	is	more	than	sufficient	

to	meet	this	objective.
14 C.F.R. 91.405(a), 91.407(a) (1), 14 C.F.R. 91.409(a) (1)&(2) and 14 C.F.R. 91.417(a) & (b)

§91.405	Maintenance	required.

Each	owner	or	operator	of	an	aircraft	–

(a)	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	discrepancies	repaired	as	prescribed	in	part	43	of	this	chapter;

*****

§91.407	Operation	after	maintenance,	preventive	maintenance,	

rebuilding,	or	alteration.

(a) No	person	may	operate	any	aircraft	that	has	undergone	maintenance,	

rebuilding,	or	alteration	unless	–

(1) It	has	been	approved	for	return	to	service	by	a	person	authorized	under

§43.7	of	this	chapter;

*****

§91.409	Inspections.

(a) Except	as	provided	in	paragraph	(c)	of	this	section,	no	person	may	operate	an	

aircraft	unless,	within	the	preceding	12	calendar	months,	it	has	had	

(1) An	 annual	 inspection	 in	 accordance	 with	 part	 43	 of	 this	 chapter	 and	 has	

been	 approved	 for	 return	 to	 service	 by	 a	 person	 authorized	 by	 §43.7	 of	 this	

chapter;	or

(2) An	inspection	for	the	issuance	of	an	airworthiness	certificate	in	

accordance	with	part	21	of	this	chapter.

*****

§91.417	(a)	&	(b)

*****

Katherine	Lovelace believes	that	an	exemption	from	these	three	maintenance	

requirements	is	appropriate	because	the	FAA	has	not	developed	maintenance	standards that	

would	allow	an	operator	to	meet	the	part	91	maintenance	requirements.	In	particular,	there	

are	no	individuals	authorized	by	the	FAA	to	approve	a	sUAS	for	return	to	service	under

§91.407(a)	or	to	conduct	the	initial	airworthiness	and	annual	return	to	service	inspections	

required	by	§91.409(a).	Katherine	Lovelace will	maintain	the	aircraft	as	instructed	in	the	

owner’s	manual	and	ASTM	F2909,	where	applicable,	and	will	not	operate	the	aircraft	until	it	

has	reasonably	determined	that	any	needed	repairs	have	been	made.	However,	because	of	the	

technical	impossibility	of	meeting	the	requirements	of	§§91.405(a),	407(a),	409(a)	and	

417(a)&(b),	we	believe	an	exemption	from	these	provisions	is	appropriate.

Please	do	not	hesitate	to	contact	me	at	the	phone	number	or	via	the	e-mail	address	

provided	above	should	you	have	any	questions	or	concerns.

Respectfully	submitted,

Katherine	Lovelace
Appendix A

Summary	for	Federal	Register	Publication

Pursuant	to	14	C.F.R.	Part	11,	the	following	summary	is	provided	for	publication	in	the	Federal	

Register	should	the	FAA	determine	that	publication	is	needed.

Petitioner:	Katherine	Lovelace

(Katherine	Lovelace)	Sections	of	14	C.F.R.	Affected:

333	Aircraft	Exemption	Status

14	C.F.R.	§61.113(a)	and	(b)

14	C.F.R.	§91.119(c)

14	C.F.R.	§91.121

14	C.F.R.	§91.151

14	C.F.R.	§91.405(a)

14	C.F.R.	§91.407(a)

14	C.F.R.	§91.409(a)

14	C.F.R.	§91.417(a)&(b)

Description	of	Relief	Sought:

Petitioner	seeks	relief	from	the	requirements	of	333	Aircraft	Exemption	Status,	14	C.F.R.,	

61.113(a)&(b)),	91.119(c),	91.121,	91.151,	91.405(a),	91.407(a),	91.409(a),	and

91.417(a)&(b)	to	conduct	sUAS	operations	over	Katherine	Lovelace’s	client’s	owned	or	

controlled	land or	yacht,	solely	during	daylight	hours,	to	assist	in	the	safe	evaluation	and	

analysis	of	infrastructure	and	operations.	In	general,	sUAS	operations	are	intended	to	be	

conducted	in	areas	remote	from	both	congested	areas	and	airports.	The	nature	of	operations	

anticipated	by	Katherine	Lovelace requires	that	the	sUAS	be	flown	at	relatively	low	altitudes.	

Katherine	Lovelace expects	that	in	most	instances,	the	sUAS	will	be	flown	less	than	75	feet	from	

the	highest	structure	along	the	path	of	the	sUAS	and	in	no	instances	will	be	flown	higher	than	

400	feet	above	the	ground.	Accordingly,	the	risk	of	interference	with	other	aircraft	is	minimal.
Appendix	B

Specific	type(s),	make	and	model

#1---DJIPhantom3

See	Attached	Flight Manuals:

DJI	Phantom	3 User Manual

#2 – DJI	Inspire	Pro	1
See	Attached	Flight Manuals:

DJI	Inspire	Pro	1 User Manual