U.S Department of Transportation October 23, 2015

Docket Management System

1200 New Jersey Ave., SE

Washington, DC. 20590

Petitioner:

Cutting Edge Drone Solutions, LLC

Owner: Kevin Lyle Cutting

1870 Stout Rd. 

Cantonment, FL. 32533

Email: KCutting42@gmail.com

Dear Sir or Madam,

Summary

I, Kevin Lyle Cutting, (Petitioner) am seeking exemption from the listed Federal Aviation Regulations 

(FARs) under Section 333 of the FAA Modernization and Reform Act of 2012 from the requirements of 

14 C.F.R. Part 21, subpart H and 14 C.F.R. §91.203, 14 C.F.R. Part 27,14 C.F.R. §91.9(c), 45.23(b) and 

45.27(a), §61.113(a) & (b),§91.9(b)(2), §91.7(a), §91.119,§91.121, §91.151(a), §91.405(a), §91.407(a)(1), 

§91.409(a)(2), §91.417(a)&(b), §91.203(a)&(b),§91.103, §91.109(A), in order to commercially operate 

the Iris+ small Unmanned Aircraft Systems (sUAS) for the purpose of aerial photography and 

videography in support of road and bridge construction services, survey and mapping operations as well 

as real estate services.

Operator, Equipment and Procedures

For the commercial (sUAS) operations, a Visual line of site (VLOS) must and will be kept at all times 

during the flight as per the Visual Flight Rules (VFR) as well as the use of a live view monitor (FPV) 

mounted on the radio control for an increase in safety. For the (sUAS) equipment the petitioner will 

utilize the Iris+ quadcopter that is less than 25 pounds including payload. The Iris+ quadcopter has 

several built in safety features such as, on screen telemetry for instant data as you fly including height 

above ground (AGL), airspeed, distance from takeoff location, integrated LEDs on all 4 arms for direction 

awareness and line of site, flight protection as it can land itself automatically, or return to home point if 

it travels out of range or runs low on battery. The Iris+ also monitors the battery level and GPS signal 

which further increases situational awareness. For procedures, the sUAS flight time (16 to 22 minutes) 

will be logged appropriately and maintenance procedures will be followed using all available resources 

including the user manuals provided by 3D Robotics. 

Specific Exemptions and Extent of Relief Sought:

14 C.F.R. Part 21 Subpart H, Airworthiness Certificates & 14 C.F.R. §91.203(a)(1)

The petition seeks an exemption from 14 C.F.R. Part 21, Subpart H, Which establishes the procedural 

requirements for the issuance of airworthiness certificates as required by 14 C.F.R. §91.203(a)(1). Given 

the size and limited operating area associated with the sUAS to be utilized by the Petitioner, an
exemption from Part 21 Subpart H meets the requirements of an equivalent level of safety under Part 

11 and section 333 of the Reform Act.

In all cases, an analysis of these criteria demonstrates that the sUAS operated without an airworthiness 

certificate, in the restricted environment and under the conditions proposed will be as safe, or safer, 

than a conventional rotorcraft operating with an airworthiness certificate without the restrictions and 

conditions of the proposed sUAS operations.

The sUAS to be operated hereunder is less than 25 lbs. fully loaded, carries neither a pilot nor 

passengers, and carries no explosive materials or flammable liquid fuels. 

The safety enhancements, which already apply to civil aircraft operated in connection with existing 

inspection operations, provide a greater degree of safety to the public and property owners then 

conventional operations conducted with airworthiness issued under 14 C.F.R. Part 21, Subpart H.

14 C.F.R. Part 27 Airworthiness Standards: Normal Category Rotorcraft. 

14 C.F.R. Part 27 sets forth the procedural requirements for airworthiness certification of normal 

category rotorcraft. To the extent the petitioner’s sUAS would otherwise require certification under Part 

27, as a rotorcraft, Petitioner requests an exemption from Part 27’s airworthiness standards for the 

same reason identified in the exemption request from 14 C.F.R. Part 21, Subpart H.

14 C.F.R. §91.9(c), 45.23(b) and 45.27(a): Aircraft Marking and Identification Requirements

This petition seeks an exemption from the aircraft marking and identification requirements of 14 C.F.R. 

§91.9(c), 45.23(b) and 45.27(a).

14 C.F.R. §91.9(c), Civil aircraft flight manual, marking and placard requirements, provides that:

No person may operate a U.S. –registered civil aircraft unless that aircraft is identified in accordance 

with part 45 of this chapter.

14 C.F.R. §45.23(b), Markings of the Aircraft, states:

When marks include only the Roman capital letter “N” and the registration number is displayed on 

limited, restricted or light-sport category aircraft or experimental or provisionally certificated aircraft, 

the operator must also display on that aircraft near each entrance to the cabin, cockpit, or pilot station, 

in letters not less than 2 inches no more than 6 inches high, the words “limited,” “restricted,” “lightsport,” “experimental,” or “provisional,” as applicable. 

14C.F.R. §45.27(a), Rotorcraft, States: 

Each operator of a rotorcraft must display on that rotorcraft horizontally on both surfaces of the cabin, 

cockpit, or pilot station on which the word “Experimental” can be placed. Moreover, given the size of 

the sUAS, two-inch lettering would be impossible. The word “Experimental” will be placed on the 

fuselage in compliance with §45.29(f). 

Extent of relief sought:
Exemption from §45.23(b) is warranted because the sUAS has no entrance to the cabin, cockpit, or pilot 

station on which the word “Experimental” can be placed. Moreover, given the size of the sUAS, two-inch 

lettering would be impossible. The word “Experimental” will be placed on the fuselage in compliance 

with §45.29(f).

Given the nature of the specific relief sought by this exemption request, Petitioner

Requires relief from the associated marking and identification requirements of §45.27(a) and §91.9(c), 

which would require compliance with §45.23(b).

14 C.F.R. §61.113(a) & (b) 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 a pilot in command of on aircraft that is carrying passengers or property for 

compensation or hire; nor may that person, for compensation or hire, act as a pilot in command of an 

aircraft.(b) A private pilot may, for compensation or hire, act as a 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.

Extent of relief sought: Because the sUAS will not carry a pilot or passengers and is inherently stable, 

with sophisticated computer and GPS controls, the proposed operations can achieve the equivalent level 

of safety to §61.113(a) and (b), by requiring the PIC operating the sUAS to have significant, unlike a 

conventional aircraft that carries the pilot and passengers, the sUAS is remotely controlled with no living 

thing on board. Moreover, the area of operation is controlled and restricted, and all flights are planned 

and coordinated in advanced in accordance with the manual, and flights are limited in duration and 

altitude. 

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

This petition seeks an exemption from the flight manual requirements of 14 C.F.R §91.9 (b)(2), which 

states:

(b) No person may operate a U. S. –registered civil aircraft

(2)For which an Airplane or Rotorcraft Flight Manual is not required by §21.5 of this chapter, unless 

there is available in the aircraft a current approved airplane or Rotorcraft Flight Manual, approved 

manual material, markings, and placards, or any combination thereof.

Extent of relief sought: Given its size, configuration, and load capacity, the sUAS has no ability to 

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

simply no room or capacity to carry such an item on the aircraft. Petitioner requests an exemption from 

§91.9(b)(2)’s flight manual requirements, on the condition that the sUAS flight manual be available at 

the control point during each operation. 

14 C.F.R. §91.7(a): Civil Aircraft Airworthiness
This petition seeks an exemption from 14 C.F.R. §91.7(a), which requires that a civil aircraft be in an 

airworthy condition to be operated. Inasmuch there will be no airworthiness certificate issued for the 

sUAS should this exemption be granted, no FAA regulatory standard will exist for determining 

airworthiness. 

14 C.F.R. §91.103: Preflight Action

This petition seeks an exemption from §91.103, which requires a PIC to become familiar with specific

information before each flight, including information contained in the FAA approved Flight Manual on 

board the aircraft. 

Extent of relief sought: Inasmuch as an FAA approved Flight Manual will not be provided for the sUAS, 

an exemption will be needed. 

An equivalent level of safety will be provided by following the Aircraft Operations Manual 

comprehensive preflight checklist. The PIC will take all actions, including reviewing weather, flight 

battery requirements, landing and takeoff distances, and aircraft performance data, before initiation of 

flight. 

14 C.F.R §91.109(a): Flight Instruction

This petition seeks an exemption from 14 C.F.R. §91.109(a), which provides 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.

Extent of relief sought: sUAS and remotely piloted aircraft, by their design do not have fully 

functional dual controls. Instead, flight control is accomplished through the use of a control box that 

communicates with the sUAS via radio communications. 

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

This petition seeks an exemption from the minimum safe altitude requirements of 14 C.F.R §91.119. 

Section 91.119 prescribes the minimum safe altitudes under which aircraft man not operate, including 

500 feet above the surface and away from any person, vessel, vehicle, or structure in non-congested 

areas. C.F.R. §91.119(c). Section §91.119 (d)(1) allows for a helicopter to operate at less than those 

altitudes when it can be operated “without hazard to persons or property on the surface,” provided that 

“each person operating the helicopter complies with any routes or altitudes specifically prescribed for 

helicopters by the FAA. 

Extent of relief sought: To the extent necessary for the petitioner to conduct commercial operations 

at or below 400 feet AGL over other than congested areas. Due to the sUAS unique capabilities and 

small size, emergency landings conducted at or below 400 feet AGL will pose minimal hazards to persons 

or property on the surface. 

14 C.F.R. §91.121 Altimeter Settings

This petition seeks an exemption from 14 C.F.R. §91.121, which requires a person operating an 
aircraft to maintain cruising altitude or light level by reference to an altimeter that is set to the elevation 

of the departure airport or barometric pressure. An exemption is required because the sUAS does not 

have a barometric altimeter, but rather a GPS altitude read out. 

Extent of relief sought: An equivalent level of safety will be achieved by following the procedures set 

forth in the Manual. As prescribed in the Manual, the operator will confirm the altitude of the launch 

site shown on the GPS altitude indicator before flight. Moreover, the PIC will use the GPS altitude 

indicator to constantly monitor the sUAS height, thus ensuring operation at safe altitudes. 

14 C.F.R. §91.151(a): Fuel Requirements for Flight in V FR Conditions

This petition seeks an exemption from 14 C.F.R. §91.151(a)’s fuel requirements for light in VFR 

conditions. Section 91.151 states:

(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; or

(2)At night, to fly after that for at least 45 minutes.

Extent of relief sought: To the extent that the petitioner’s sUAS are unable to comply with the VFR 

fuel requirements for airplanes or helicopters. Wind and weather conditions will be considered before 

each flight and no flight will begin unless there is enough power available to conduct the intended 

operation and to operate after that for at least five minutes or with the reserve power recommended by 

the manufacturer, if greater. 

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

This petition seeks an exemption from civil aircraft certification and registration requirements of 14 

C.F.R §91.203 (a) and (b). The regulation provides in pertinent part:

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

following:

(1)An appropriate and current airworthiness certificate

(a)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.

Extent of relief sought: In addition to the fact that Petitioner is seeking an exemption from the 

airworthiness certificate requirements, an exemption to this regulation is necessary because: (1) the 

sUAS’s load capacity and size does not allow it to carry certification and registration documents; (2) the 

sUAS does not have a cabin or cockpit entrance at which the documents could be displayed; and (3) 

there are no passengers or crew for whom the certificates need be displayed. 
14 C.F.R. §91.405 (a); 91.407 (a)(1); 91.409(a)(2); 91.417(a) & (b): Maintenance Inspections

This petition seeks an exemption from the maintenance inspection requirements of 14 C.F.R. §91.405(a); 

91.407(a)(1); 91.409(a)(2); 91.417(a) & (b). These regulations specify maintenance and inspection 

standards in reference to 14 C.F.R. Part 43. See, e.g., 14 C.F.R. §91.405(a) (stating that each owner or 

operator of an aircraft “shall have that aircraft inspected as prescribed in subpart E of this part and shall 

between required inspections...have discrepancies repaired as prescribed in part 43 of this chapter”). 

An exemption to these regulations is needed because Part 43 and these sections apply only to aircraft 

with an airworthiness certificate, which the sUAS will not have. 

Extent of relief sought: To the extent that the petitioner’s sUAS have not been issued Airworthiness 

Certificates. The petitioner will use trained technicians to perform maintenance, alterations and 

preventive maintenance on the sUAS using the methods, techniques, and practices prescribed in the 

sUAS operating documents. Furthermore, the petitioner will document and maintain all maintenance 

records for the sUAS. 

HOW MY REQUEST WILL BENEFIT THE PUBLIC AS A WHOLE:

The operation significantly improves safety and reduces risk by alleviating human exposure to danger 

associated with current aerial survey and inspection methods, namely, full size helicopters. Manned 

helicopters performing aerial photography have experienced an exceedingly high number accidents and 

fatalities. The public’s interest is furthered by reducing human exposure to death or serious injury 

associated with manned aircraft performing photography, inspections and patrols. 

Petitioner’s sUAS are battery powered and create no emissions. If Petitioner’s sUAS crashes, there is no 

fuel to ignite and explode. Any impact of Petitioner’s lightweight sUAS is, obviously, far less than a full 

size helicopter. The public’s interest is furthered by minimizing ecological impact of an accident and by 

reducing human exposure to potentially harmful emissions associated with manned aircraft. 

There are numerous reasons why granting this exemption will benefit the public as a whole. First and 

foremost, sUAS operations will benefit the economy by creating jobs and reducing costs for customers 

that, up until now, have had to rely on manned aircraft for the same operations. UAS operational costs 

are much lower than manned aircraft and those savings will benefit our nation’s economy on many 

different levels. Jobs will be created in manufacturing, Research and Development, logistics, and 

education, operations and maintenance, just to name a few. Using sUAS in lieu of manned aircraft will 

enhance safety and reduce environmental impact as well. Without a crew on board like a traditional 

aircraft, sUAS can take over some of the dangerous operations that manned aircraft once held, such as 

powerline inspections or work in confined areas. Also, sUAS are much less dangerous to persons on the 

ground if a catastrophe does happen. They are much smaller and lighter and most do not carry 

flammable fuel onboard. Aerial surveying and inspections can increase work site efficiency, improve 

volumetric estimations and reduce risks. Liability insurance will be obtained commensurate with the 

granting of this request for exemption. 

GRANTING THIS EXEMPTION WILL NOT ADVERSELY AFFECT PUBLIC SAFETY:

The petitioner firmly believes not only will this exemption not adversely affect public safety, but 

integrating sUAS into the National Airspace System will actually enhance public safety. Operations that 
utilize traditional manned aircraft put the public at risk of a much larger vehicle travelling at a much 

higher rate of speed. Also, traditional aircraft have the ability to carry many gallons of flammable fuel 

that makes an accident that much more dangerous. Furthermore, many of those manned operations 

contribute to congestion in the NAS resulting in an increased risk of collision with other aircraft. 

Because the petitioner’s sUAS will be operated away from the airport environment, where the highest 

risk of collision occurs, using this aircraft in place of a manned aircraft enhances safety. 

A SUMMARY YOU CAN PUBLISH IN THE FEDERAL REGISTER STATING –

The rules from which I seek the exemption:

Kevin Lyle Cutting seeks an exemption from the following rules:

14 C.F.R. Part 21, subpart H and 14 C.F.R. §91.203, 14 C.F.R. Part 27,14 C.F.R. §91.9(c), 45.23(b) 

and 45.27(a), §61.113(a) & (b),§91.9(b)(2), §91.7(a), §91.119,§91.121, §91.151(a), §91.405(a), 

§91.407(a)(1), §91.409(a)(2), §91.417(a)&(b), §91.203(a)&(b),§91.103, §91.109(A)

and

A brief description of the exemption I seek:

Kevin Lyle Cutting seeks an exemption from the following rules:

14 C.F.R. Part 21, subpart H and 14 C.F.R. §91.203, 14 C.F.R. Part 27,14 C.F.R. §91.9(c), 45.23(b) 

and 45.27(a), §61.113(a) & (b),§91.9(b)(2), §91.7(a), §91.119,§91.121, §91.151(a), §91.405(a), 

§91.407(a)(1), §91.409(a)(2), §91.417(a)&(b), §91.203(a)&(b),§91.103, §91.109(A)

For the purposes of conducting aerial photography and videography in support of road and 

bridge construction services, survey and mapping operations as well as real estate services.

ADDITIONAL INFORMATION TO SUPPORT MY REQUEST:

The user manual for the Iris+ sUAS can be found at https://3drobotics.com

Kevin Lyle Cutting does NOT intend to operate the sUAS outside of the United States. 

Respectfully,

Kevin Lyle Cutting