GLE Associates, Inc.

5405 Cypress Center Drive, Suite 110 | Tampa, Florida 33609 | 813-241-8350 | Fax: 813-241-8737

Orlando | Ft. Lauderdale | Miami | Jacksonville | Gainesville | Atlanta | Nashville

Architecture AA 0002369 • Engineer CA 5483 • Asbestos ZA 0000034 • Geology GB 0000297

January 19, 2016

U.S. Department of Transportation 

Docket Management System 

1200 New Jersey Avenue SE 

Washington, DC 20590

RE: Exemption Request Pursuant to Section 333 of the FAA Modernization and

Reform Act of 2012, 49 U.S.C. § 44701(f), and Part 11 of the Federal Aviation Regulations

Dear Sir or Madam: 

Pursuant to Section 333 of the FAA Modernization and Reform Act, GLE Associates, Inc. 

(GLE) hereby applies for an exemption from the listed Federal Aviation Regulations (“FARs”) 

to allow commercial operation of its UAS(s), so long as such operations are conducted within 

and under the conditions outlined herein or as may be established by the FAA as required by 

Section 333. 

Applicant Information:

The name of the applicant: GLE Associates, Inc.

The primary contact for this application:

Robert B. Greene

GLE Associates, Inc.

5405 Cypress Center Drive, Suite 110

Tampa, Florida 33609

GLE Associates, Inc. is a corporation formed under the State laws of Florida on September 9, 

1989, and Robert B. Greene is an Officer of the corporation.

Pursuant to Section 333 of the FMRA, GLE hereby requests a determination by the Secretary of 

Transportation authorizing commercial operations of a UAS for the purposes of aerial 

photography & videography, mapping, infrared photography of facilities, agricultural crop 

surveillance, aerial inspections, data collection, commercial videos and other work related to 

aerial photography in the United States. GLE does not intend to use for closed set filming. Flight 

operations will utilize the off the shelf DJI family of unmanned aircraft. Conduct of UAS

operations will be with respect to FMRA Section 333(c) and the UAS “Blanket COA”.
U.S. Department of Transportation

Exemption Request

January 19, 2016; Page 2

Exemption is necessary to effect the determination requested pursuant to FMRA Section 333. 

The attached documentation includes detailed exemption requests that demonstrate how these 

exemptions are in the public interest and will maintain at least an equal level of safety to existing 

regulations. Authorizing GLE to conduct commercial UAS operations will result in less 

disruptive, safer, and more cost effective solutions than manned aviation equivalents due to the 

low altitude environment, given the size, speed and inherent risk of traditional commercial 

helicopter and airplane operations. These commercial operations often occur in the unsafe areas 

of the height-velocity diagram requiring special precision and skill. GLE will conduct the 

commercial UAS operation in a manner that will meet, and in many cases exceed, the current 

level of safety of commercial airplane and helicopter operations. UAS that are less than 10 

pounds have a low noise signature, and carry no volatile fuel, will limit collateral damage in the 

event of catastrophic failure. The low expense of operation compared to cost prohibitive manned 

aviation alternatives allows a greater economic benefit to businesses. For these reasons, granting 

an exemption under FMRA Section 333(c) is in the public interest. UAS technology used for 

these commercial purposes benefit the public interest in the following ways: 

• Reduces the collateral damage risks to life and property associated with low 

altitude airplane and helicopter operations in undesirable portions of the 

height-velocity envelope.

• Increased economic wellbeing to local businesses via cost reductions.

• Enabling aerial business solutions to be available to a larger market.

• Infrared photography of facilities allows owners to increase the energy 

efficiency of their buildings resulting in less energy usage.

Table of Contents

I. Exemptions Requested

II. UAS Operating Procedures

III. Unmanned Aircraft System

IV. UAS Pilot-in-Command

V. Public Interest

VI. Summary
U.S. Department of Transportation

Exemption Request

January 19, 2016; Page 3

I. Exemptions Requested

Pursuant to 14 C.F.R. § 11.81(e), GLE requests exemption from the following regulations:

• 14 C.F.R. Part 21 Subpart H – Airworthiness Certificates

o Establishes: The procedural requirements for the issuance of 

airworthiness certificates as required by 14 C.F.R. § 91.203(a)(1). 

Given the small size of the UAS and the safeguards that will be taken 

as outline below, an exemption from Part 21 Subpart H meets the 

requirements of an equivalent level of safety under Part 11 and Section 

333 of the FMRA with consideration “of the size, weight, speed, 

operational capability, and proximity to airports and populated areas of 

the particular UAS.”

• 14 C.F.R. § 45.23(b) – Aircraft Marking and Identification Requirements

o Given the small size of the sUAS, two-inch lettering will be 

impossible. The UAS 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.

GLE will ensure compliance with § 45.29(f) to meet the intent of the regulation by displaying the 

registration number in the largest practicable lettering.

• 14 C.F.R. 61.113 (a)(b) §61.113 Private pilot privileges and limitations: 

Pilot in command.

o 14 C.F.R. § 61.113: (a) Except as provided in paragraphs (b) through 

(g) 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 that business or employment; and

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

compensation or hire.

GLE anticipates initially using a cadre of 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, buildings, equipment, right-of-way, assets, bridges and tunnels and property in 

furtherance of GLE’s client’s business, however, the employees’ operation of the sUAS will not 

be incidental to their employment with GLE, 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 
U.S. Department of Transportation

Exemption Request

January 19, 2016; Page 4

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 control of GLE clients. Accordingly, the risk would be limited to GLE personnel, who 

will be appropriately outfitted in safety gear, and GLE client’s property on the ground. Requiring 

a commercial pilot certificate would provide no appreciable safety benefit and would needlessly 

impose additional cost on GLE. 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. 91.7(a) – Civil Aircraft Airworthiness

GLE’s request is based on the fact that no airworthiness certificate will be issued for the sUAS. 

GLE’s sUAS 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.

• 14 C.F.R. 91.9(b) – Civil Aircraft Flight Manual, Marking, and Placard 

Requirements

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.

• 14 C.F.R. 91.103 (b) – Preflight Instruction

This regulation requires each pilot in commend to take certain actions before 

flight to insure the safety of flight. As FAA approved rotorcraft flight manuals 

will not be provided for the aircraft, an exemption will be needed. The 

petitioner 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

o 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.

The majority of sUAS by design are developed with single operational control, through the use 

of pre-determined GPS enabled waypoints, programmed before or during flight, in addition to 

the use of a single hand held transmitter or control station controlled by the PIC. The design does 

not allow for dual controls during flight training and therefore the exemption is requested to train 
U.S. Department of Transportation

Exemption Request

January 19, 2016; Page 5

operators, build experience, and maintain proficiency. An equal level of safety will be achieved 

by conducting all training in sterile environments. Training sessions will be accomplished 

separately from flights conducted for compensation or hire.

• 14 C.F.R. 91.119 (c) – Minimum Safe Altitudes

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

an aircraft below the following altitudes: (b) Over any congested area 

of a city, town, or settlement, or over any open air assembly of 

persons, an altitude of 1,000 feet above the highest obstacle within a 

horizontal radius of 2,000 feet of the aircraft. (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. (d) Helicopters, powered parachutes, and weight-shiftcontrol aircraft. If the operation is conducted without hazard to persons 

or property on the surface— (1) A helicopter may be operated at less 

than the minimums prescribed in paragraph (b) or (c) of this section, 

provided each person operating the helicopter complies with any 

routes or altitudes specifically prescribed for helicopters by the FAA.

Commercial sUAS operations will be conducted at or below the maximum altitude authorized by 

COA. Given the size, weight and lack of fuel; combined with operation limitations listed below, 

the operation will be conducted with a greater level of safety than exists with current manned 

aviation operations.

• 14 C.F.R. 91.121 – Altimeter Settings

Each person operating an aircraft shall maintain the cruising altitude or flight 

level of that aircraft, as the case may be, by reference to an altimeter that is 

set, when operating. 

sUAS are equipped with Global Positioning System (GPS), which provide altitude and geolocation data to the operator without utilizing an altimeter. Due to this fact, an exemption is 

required. GPS are precise within a few feet and combined with fail-safes and a visual observer. 

The operation will meet an equivalent level of safety.

• 14 C.F.R. 91.151(a) – Fuel Requirements for Flight in VFR Conditions

o 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;

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 
U.S. Department of Transportation

Exemption Request

January 19, 2016; Page 6

conditions. GLE 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, GLE 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. 91.203 (a) (b) – Carrying Civil Aircraft Certification and 

Registration

o No person may operate a civil aircraft unless it has an appropriate and 

current airworthiness certificate.

o 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 19.715 is displayed at the cabin or cockpit 

entrance so that it is legible to passengers or crew.

Reason for Exception: To obtain an equivalent level of safety and meet the intent of 91.203, 

documentation will be housed at a ground control point where the pilot is flying the sUAS for 

immediate access; to the extent they are applicable to the sUAS's. 

• 14 C.F.R. 91.405(a), 91.407(a)(1), 91.409(a)(2) and 91.417(a) & (b) –

Maintenance Inspections

o 91.405(a) States: 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

GLE shall inspect the aircraft prior to every flight. GLE also will follow the manufacturer's 

recommended preflight checklist and make any repair necessary before flights occur. GLE will 

also maintain a log of any maintenance or repairs performed.

o 91.407(a)(1) States: (a) No person may operate any aircraft that has 

undergone maintenance, preventive maintenance, rebuilding, or 

alteration unless—(1) It has been approved for return to service by a 

person authorized under § 43.7.

GLE has the responsibility for the operation and safety of the UAS and will follow the 

manufacturer’s suggested replacement parts. 

o 91.409(a)(2) States: (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—(2) An inspection for the issuance of 

an airworthiness certificate in accordance with part 21 of this chapter. 
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Exemption Request

January 19, 2016; Page 7

No inspection performed under paragraph (b) of this section may be 

substituted for any inspection required by this paragraph unless it is

performed by a person authorized to perform annual inspections and is 

entered as an ‘‘annual’’ inspection in the required maintenance 

records.

GLE will follow manufacturer's recommendations to ensure that the sUAS is in a condition for 

safe flight at all times.

o 91.417(a) & (b) States: (a) Except for work performed in accordance with 

§§ 91.411 and 91.413, each registered owner or operator shall keep the 

following records for the periods specified in paragraph (b) of this section: 

(paragraphs 1 (i-iii), 2 (i–vi)); (b) The owner or operator shall retain the 

following records for the periods prescribed: (paragraphs 1 – 3)

GLE will keep a record of all repairs and modifications. The Petitioner also proclaims to use 

approved manufactured parts for all repairs and modifications.

II. UAS Operating Procedures

Any sUAS flown under this exemption will be controlled by a trained PIC. 

For each flight, GLE:

• Will conduct a comprehensive worksite inspection and analysis, identifying 

limits of customer property or authorized access areas.

• Will conduct preflight planning in accordance with Section 91.103 Preflight 

Action.

• Will operate in those areas only with the consent of the landowner or 

designated representative.

• Will identify potential obstructions or other hazards to safe operation.

• Will clear the area of personnel or bystanders that are non-essential to the 

operation, maintaining at a minimum, 500 feet away from non-participating 

persons.

• Will conduct a preflight safety briefing to Visual Observer (VO) and 

participating persons.

• Will at all times yield to manned air traffic.

• Will operate within VLOS of both PIC and VO during daylight hours only.

• Will maintain voice communications with VO and participating persons.

• Will operate under visual flight rules, in visual meteorological conditions, for 

the airspace in which the flight is conducted.

• Will not exceed the maximum altitude as defined in the COA under which 

flight authorized, as determined by the installed GPS.

• Will keep operating documents, manuals, authorizations and exemptions in a 

binder co-located with the GCS.
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Exemption Request

January 19, 2016; Page 8

• Will immediately terminate flight, in the safest manner possible, when safety 

to persons or property becomes compromised.

• Will terminate flight, in the safest manner possible, when unable to comply 

with these limitations or any other limitations granted as part of this 

exemption.

In order to remain at an altitude at or below the attitude prescribed by the applicable COA, relief 

is needed from Section 91.119 (c). By following these operating standards, the commercial 

operation will meet an equivalent level of safety to the regulation in which relief is sought.

III. Unmanned Aircraft System

GLE seeks exemption to operate DJI UAS. Other sUAS types may be requested in future 

amendments. The DJI Inspire 1 and DJI Phantom-3-Pro are the primary aircrafts in our operation 

for which we seek exemption. The sUAS will be flown via a combination of RC control and 

tablet GCS. These UA types are GPS equipped multirotor helicopters. They are quad-copter type 

rotorcraft, utilizing four motors. Lithium-polymer batteries power the UAS. The DJI Inspire 1 

has a gross weight of approximately 6.5 pounds and a maximum airspeed of 22 m/s. The DJI 

Phantom 3 has a gross weight of approximately 3.5 pounds and a maximum airspeed of 16 m/s.

The UAS also has several fail-safes for loss of RC signal, loss of GPS, and low battery as 

outlined in the respective Operation Manuals. The UAS display visual and emit an audible low 

battery alerts at which time the UAS will automatically engage the landing sequence. Based 

upon those safeguards, we request exemption from Section 91.151(b) Fuel requirements for 

flight in VFR conditions. 

Given the size, weight, speed, and controlled operating area associated with the UAS to be 

utilized, an exemption from 14 CFR part 21, Subpart H (Airworthiness Certificates) and § 

91.203 (a) and (b) is requested. Exemption is sought from § 45.23 Marking of the aircraft. The 

UA will display the registration number in the largest practicable lettering. GLE seeks to be 

exempt from § 91.405(a), 91.407(a)(1), 91.409(a)(2) and 91.417(a) and (b) Maintenance 

inspections will be conducted according to operations manual and prudent judgment as 

previously outlined to determine the integrity and safety of the UAS and associated equipment. 

Further, relief is required from 91.7(a), which prohibits the operation of an aircraft without an 

airworthiness certificate and 91.9(b) (2) requiring an approved flight manual in the aircraft. The 

UAS will not be operating with an airworthiness certificate therefore, this would be 

inappropriate. The UAS are too small to carry the operating documents so an equivalent amount 

of safety can be achieved through keeping the operating documents and manuals at the GCS.

IV. UAS Pilot in Command

Under part § 61, recreational, sport and private pilots are limited to non-commercial operations, 

however GLE can ensure sUAS operations will achieve an equivalent level of safety as current 

regulation because sUAS do not carry any pilots or passengers. A commercial pilot certificate 

will not ensure RC piloting ability, as the psychomotor skills are different. The inherent risks of 
U.S. Department of Transportation

Exemption Request

January 19, 2016; Page 9

operating a sUAS are far less than in the commercial activities outlined in 14 CFR part 61, et 

seq., thus exemption is requested from § 61.101 Recreational Pilot Privileges and Limitations. 

PICs will maintain recent flight experience on the sUAS. Training and experience flights will be 

conducted separate from commercial operations. 

V. Public Interest

Given the above stated evidence, procedures, and precautions operating UAS commercially for 

the purposes of aerial photography & videography, mapping, infrared photography of facilities, 

aerial inspections, data collection, commercial videos and other work related to aerial 

photography will ultimately be in the public interest. These operations, when executed with 

prudence, will exceed the current level of safety as the regulations from which exemption is 

sought. sUAS operations will allow greater access to commercial aerial services that were not 

previously economically feasible for many firms. This will provide a much needed economic 

uplift to the community and hence the public. Infrared photography of facilities can result in 

increased energy efficiency resulting in energy savings. sUAS operations are associated with less 

risk of collateral damage to persons and property while limiting disruptive noise pollution 

associated with low altitude aviation operations.

VI. Summary

Pursuant to Section 333 of PL 112-95 commonly known as the “FAA Modernization and Reform 

Act of 2012”, GLE hereby applies for authorization to conduct commercial unmanned aerial 

systems (UAS) operations for the purposes of aerial photography & videography, mapping, 

infrared photography of facilities, agricultural crop surveillance, aerial inspections, data 

collection, commercial videos and other work related to aerial photography. Rules for which 

exemption is sought:

• 14 C.F.R. Part 21 Subpart H

• 14 C.F.R. § 45.23(b)

• 14 C.F.R. § 61.113 (a) (b), 61.113

• 14 C.F.R. § 91.7(a)

• 14 C.F.R. 91.9(b)

• 14 C.F.R. § 91.103

• 14 C.F.R. § 91.109(a)

• 14 C.F.R. § 91.119

• 14 C.F.R. § 91.121

• 14 C.F.R. § 91.151(a)

• 14 C.F.R. § 91.203 (a) (b)

• 14 C.F.R. § 91.405(a)

• 14 C.F.R. § 91.407(a)(1)

• 14 C.F.R. § 91.409(a)(2)

• 14 C.F.R. § 91.417(a) & (b)
U.S. Department of Transportation

Exemption Request

January 19, 2016; Page 10

Thank you for your prompt attention and consideration. GLE is committed to safe UAS 

operation. Please do not hesitate to contact me directly with any questions or concerns at 888-

453-4531, extension 223. 

Sincerely,

GLE Associates, Inc.

Robert B. Greene, PE

President

bgreene@gleassociates.com