U.S. DEPARTMENT OF TRANSPORTATION

DOCKET MANAGEMENT SYSTEM

1200 NEW JERSEY AVE. SE

WASHINGTON, DC 20590

RE: Petition for Exemption from 14 CFR Part 21, Subpart H; 14 CFR § 

91.203(a)(1); 14 CFR Part 27: 14 CFR §§ 91.9(c), 45.23(b) and 45.27(a);14 CFR § 

61.113 (a) & (b);14 CFR § 91.7(a); 91.9(b)(2); 91.103; 91.109(a); 91.119; 91.121; 

91.151(a); 91.203 (a) & (b); 91.405(a); 91.407(a)(1); 91.409(a)(2); 91.417 (a) & 

(b)

Dear Sir or Madam,

Soutex Inc., doing business as Soutex Surveyors & Engineers (SOUTEX) is 

applying for an exemption from regulations detailed below in order to conduct 

high definition surveys (HDS) and inspections with a small-unmanned aircraft 

system (sUAS) manufactured by Aibotix, the model Aibot X-6 V2 (X6). The 

manufacturer states that it has developed the X6 for survey of challenging sites 

such as quarries, sand pits, landfills, coal stockpiles, industrial and commercial 

developments, and bridge inspections all of which SOUTEX intends to pursue. In 

addition SOUTEX would like to offer services to local emergency management 

teams, fire departments, and law enforcement to assist in disaster recovery or 

emergency situations. These uses could include aerial scanning after a natural 

disaster to identify persons in need of assistance, assess damage to property, and 

scouting of usable ground transportation routes.

I. Company Background

Soutex, Inc. (Soutex), based in Port Arthur, Texas was founded in 1959 to 

provide residential, commercial, and industrial surveying and engineering services 

to southeast Texas. Today the owner-operated company is a premier provider of 

services to both the public and private sector. Soutex is a full service company, 

assisting our clients in almost every step of their development process. With 

services that include boundary surveying, topographic surveying, engineering 

design, architectural design, construction staking, inspection, and construction 

management, Soutex stands poised to meet its client’s needs whatever they may be. 

TBPE Firm No. 5755

TBPLS Firm No. 10123800

3737 Doctors Drive 

Port Arthur, Texas 77642 

Office (409) 983.2004

Fax (409) 983.2005 
As new technologies are developed, Soutex explores new, more efficient means of 

serving its clients. As the use of unmanned aircraft has expanded commercially 

and recreationally throughout the world, Soutex has prepared to put this new 

technology to use in conducting survey and inspection work. Soutex has created 

an operations manual it hopes will demonstrate its commitment to conducting work 

in a matter that will ensure the safety of people and property. Aibotix, a smallunmanned aircraft manufacturer, has trained Soutex personnel in the use of its 

product.

II. Business Climate

Texas in general and southeast Texas in particular is a cornerstone of the oil and 

gas business in the United States. Southeast Texas is the number one refiner of jet 

fuel in the nation and refines a minimum of 13% of the country’s daily fuel 

consumption1. The area also retains 55% of the nation’s strategic petroleum 

reserves and is linked to an extensive energy pipeline system1. While southeast 

Texas is home to some of the nation’s largest refineries, the backbone of the 

industrial and commercial sectors of the economy lies with its position along the 

Sabine-Neches Waterway. The waterway is the nation’s number one bulk liquid 

cargo waterway, and the third largest by cargo volume, moving over 100 million 

tons of cargo annually1. Being the nation’s number one commercial military out 

load port, the Sabine-Neches Waterway is an integral component of U.S. energy & 

military transportation infrastructure1.

On June 10, 2014, the President signed H.R. 3080(113th): Water Resources 

Reform and Development Act of 2014 in to law. Included in this package was the 

authorization to deepen the Sabine-Neches Waterway from 40 to 48 feet, allowing 

larger ships to reach ports along the waterway. This can only serve to speed the 

growth of industry in the area. Plans for expansion of local refineries are in the 

works, railroad infrastructure is being expanded, and new developments to increase 

the capacity of the areas import and export have begun. The region is poised for an 

era of unprecedented growth, and Soutex wants to be ready to meet any survey, 

inspection, and engineering needs that may arise. 

Surveying is a unique business with specialized equipment, methods, and 

personnel. While its roots go back as far as ancient Egypt, and its American 

history includes the likes of George Washington, Thomas Jefferson, and Abraham

Lincoln, surveying has steadily changed as new technologies have become 

available. In times past, distances would be measured with a chain and directions 

with a compass. Now surveyors use a total station that measures both distance and 

 

1 Based on information obtained in Fact Sheet: The Sabine-Neches Waterway, An American Asset available online 

at http://www.navigationdistrict.org/projects/deepening-project
direction, in a much safer and more efficient manner. Over the previous two 

decades, the use of global positioning systems has increased that efficiency even 

more and allowed surveyors to locate a piece of property relative to the entire 

world rather than just those pieces of property that adjoin it. The use of laser 

scanners has also had an impact on the industry of surveying. Detailed scans of 

complex environments can be taken at a distance rather than putting the safety of 

personnel at risk by having them physically climb or otherwise interact with the 

subject of the scan. 

The newest technology available to the surveyor is that of the sUAS. This 

technology has the potential to revolutionize the way some surveying and 

inspection tasks are accomplished. Some tasks previously performed by laser 

scanners, such as determining the quantity of a stockpile, can be performed to 

greater accuracy at a fraction of the cost. Whereas a land based laser scanner 

would have to be moved to various locations around the pile to obtain all of the 

data needed to generate a quantity, a sUAS can be used to measure the pile from 

above and at oblique angles, giving it access to contours obscured from the view of 

ground based scanners and performing the task in a fraction of the time. 

Inspections are another area where the use of sUAS will be of great benefit. 

Bridge inspections for example can be assisted by using sUAS to perform visual 

inspections of bridge infrastructure that would normally require a human being to 

be dangerously suspended high above the ground or water the bridge is crossing or 

the bridge decking itself. There are many other environments, such as refineries, 

wetlands, and marine sites, in which use of a sUAS would be safer, more 

environmentally friendly, and more efficient than having personnel on the ground 

or in the water collecting data. The use of sUAS for low altitude survey and 

inspection would improve accuracy, reduce risk to personnel, and improve 

efficiency by reducing reliance on watercraft and on-the ground operations.

III. Benefit to the Public

The public will benefit from SOUTEX receiving this exemption in three 

different ways. Survey projects in which use of a sUAS is practical will be 

completed in a manner much safer than current methods, with better accuracy, and 

a reduced cost to the consumer.

The proposed exemption will allow the operator to mitigate safety risks for 

those who must conduct regular surveys of roofs, bridges, towers and of hazardous 

stockpiles; will reduce the risk of climb and fall during equipment inspection; will 

reduce the number of flights of manned aircraft for regular survey thereby 

diminishing the danger of such use, both to those onboard as well as to people and 

property under the flight path; and will reduce the environmental impact of fossil 

fuel use in aircraft. SOUTEX has also developed the Soutex Flight Operations and 
Safety Manual (SFOSM), which outlines procedures that will insure surveys, and 

inspections are performed in a safe manner, lowering risk to participants, 

bystanders, and the environment.

Another benefit to the public is that of providing the consumer with more 

accurate data than can be obtained using traditional methods of surveying. The 

quantity of a stockpile for example can be determined with greater accuracy by 

scanning from the air using both overhead and oblique angle shots to obtain 

contours that are currently unable to be observed using ground based scanners. 

Having more accurate data such as this can help the consumer to better estimate 

the cost of projects, or to generate more accurate bills to their client for material 

used. Land development is another good example of the benefit of HDS with a 

sUAS. Scans of a work site before and after dirt work has been done will provide 

more accurate quantities of material that was used to fill in or build up the work 

site. This would potentially save the developer from overpaying for materials.

In addition to safety, and accuracy, cost is another benefit to the public of 

performing surveys and inspections using a sUAS as opposed to other methods. 

When surveying using ground based methods, equipment must be set up, torn 

down, and set up again multiples times to be able to collect data due to line of sight 

issues. Use of a sUAS would save a tremendous amount of time in data collection, 

reducing the cost of the consumer. When performing inspections, on a bridge for 

example, progress is very slow, utilizes large teams of personnel, and requires the 

use of expensive equipment to insure the safety of the inspectors. Use of a sUAS

reduces the number of personnel needed, does not require specialized equipment, 

and drastically cuts the time needed to perform the inspections. All of these 

savings equate to lower costs to the consumer.

IV. CFR Code from which exemption is requested

The Federal Aviation Act expressly grants the FAA the authority to issue 

exemptions. By its terms, this statutory authority includes exempting civil aircraft, 

as the term is defined under §40101 of the Act, including sUAS, from its safety 

regulations and minimum standards when the Administrator decides a requested 

exemption is in the public interest.

Petitioner seeks an exemption from several interrelated provisions of 14 

CFR Parts 21, 45 and 91 for purposes of conducting aerial surveys and inspections 

using sUAS. Listed below are: (1) the specific sections of 14 CFR for which 

exemption is sought; and (2) the operating procedures and safeguards that 

Petitioner has established which will ensure a level of safety equal to or better than 

the rules from which exemption is sought.

Petitioner acknowledges that some of the below cited requests were 

addressed in FAA Order 11062 (Grant of Exemption to Astraeus Aerial, Docket 
FAA-2014- 0352) and for which no action was taken by the FAA. The FAA’s 

analysis did, however, recite the petitioner’s information as the basis for the no 

action; this Petition recites all of the previous sections for which exemptions were 

requested therein.

A. 14 C. F.R. Part 21, Subpart H -Airworthiness Certificates & 14 C. F.R. §

91.203(a) (1).

This petition seeks an exemption from 14 CFR Part 21, Subpart H, which 

establishes the procedural requirements for the issuance of airworthiness 

certificates as required by 14 CFR §91.203(a)(1). Given the size, weight, speed 

and limited, obstructed and unpopulated operating area associated with the 

Aibot X6 V2 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.

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.

The Aibot X6 V2 to be operated hereunder is less than 14.55 pounds fully 

loaded, carries neither a pilot nor passenger, carries no explosive materials or 

flammable liquid fuels, and operates exclusively within a sterile area adjacent to 

structures that are considered obstructions to manned aircraft. Unlike other 

civil aircraft, aircraft operations will be tightly controlled and monitored by the 

PIC and SO pursuant to the SFOSM requirements and in compliance with local 

public safety requirements. Site security measures for areas of operation are

consistent with existing requirements for maintaining public safety. The 

operation has been reviewed by a panel of subject matter experts to identify 

risks and safety requirements, and mitigate those risks per the SFOSM. 

Equivalent Level of Safety

In all cases, an analysis of these criteria demonstrates that the Aibot X6 V2 

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 rotorcraft operating with an airworthiness certificate issued under 

14 CFR Part 21, Subpart H. without the restrictions and conditions of the 
proposed Aibot X6 V2 operations. The same criteria demonstrate that there is 

no credible threat to national security posed by the Aibot X6 V2, due to its size, 

speed of operation, location of operation, lack of explosive materials or 

flammable liquid fuels and inability to carry a substantial external load.

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

Rotorcraft.

14 CFR Part 27 sets forth the procedural requirements for airworthiness 

certification of normal category rotorcraft. To the extent the Petitioner's Aibot 

X6 V2 would otherwise require certification under Part 27, as a rotorcraft, 

Petitioner requests an exemption from Part 27's airworthiness standards for the 

same reasons identified in the exemption request from item A. 14 CFR Part 21, 

Subpart H.

C. 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 CFR §§ 91.9(c), 45.23(b) and 45.27(a).

14 CFR § 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 CFR § 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 nor more than 6 inches high, the 

words "limited," "restricted," "light-sport," "experimental," or "provisional," 

as applicable.

14 CFR § 45.27(a), Rotorcraft, states:

Each operator of a rotorcraft must display on that rotorcraft horizontally on 

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

Exemption from § 45.23(b) is warranted because the Aibot X6 V2 has no cabin, 

cockpit, or pilot station or entrance of any kind on which the word 

"Experimental" can be placed. Moreover, given the size of the Aibot X6 V2, 

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).

Equivalent Level of Safety

An equivalent level of safety for exemptions to the aircraft marking and 

identification requirements of §§ 91.9(c), 45.23(b) and 45.27(a), will be 

provided by having the sUAS marked on its fuselage as required by §45.29(f) 

where the pilot, observer, and others working with the sUAS will see the 

identification of the sUAS as "Experimental." Additionally, Petitioner will 

ensure compliance with any requests of sUAS marking by the FAA.

The FAA has issued the following exemptions to the aircraft marking 

requirements of § 45.23(b): Exemptions Nos. 10700, 8738, 10167 and 10167A.

D. 14 C. F.R. § 61.113 (a) & (b): Private Pilot Privileges and Limitations: 

Pilot in Command.

This petition seeks an exemption from the private pilot privileges and 

limitations of §61.113 (a) & (b), which states:

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. Private Pilot Privileges and Limitations: Pilot in Command.

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

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

aircraft in connection with any business or employment if:

The flight is only incidental to that business or employment; and the aircraft 

does not carry passengers or property for compensation or hire. Section 

61.113(a) limits private pilots to being in command of non-commercial flights. 

Section 61.113(b) (1) provides an exception that allows a private pilot to 

command an aircraft without passengers or property, in connection with 

business or employment if “the flight is only incidental to that business or 

employment." That exception likely does not apply to the proposed operations 

under this petition for exemption, as the flights are not incidental to the 

proposed aerial surveys and inspections but rather essential to it. Accordingly, 

this petition seeks an exemption to § 61.113(a)'s commercial limitation and/or § 

61.113(b) (1)'s requirement that the flight be incidental to the business to 

benefit from the exception.

Equivalent Level of Safety

As required by the SFOSM, Petitioner's Aibot X6 V2 operators acting as PIC 

will hold a private pilot license and manufacturers flight training specific to the 

Aibot X6 V2. Because the Aibot X6 V2 will not carry a pilot or passengers, 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 a private pilot license 

or sUAS certificate and flight training specific to the Aibot X6 V2.

Unlike a conventional aircraft that carries the pilot and passengers, the Aibot X6 

V2 is remotely controlled with no living being on board. Moreover, the area of 

operation is controlled and restricted, and all flights are planned and 

coordinated in advance as set forth in the SFOSM.
The level of safety provided by the requirements included in the SFOSM 

exceeds that provided by a single individual holding a commercial pilot's 

certificate operating a conventional aircraft in accordance with § 61.113 (a) & 

(b). The risks associated with the operation of small, lightweight sUAS in an 

airspace adjacent to obstructions are diminished from the level of risk 

associated with commercial operations contemplated by Part 61 when drafted, 

that allowing the proposed operations in this petition for exemption with a PIC 

holding a private pilot exceeds the present level of safety achieved by §61.113 

(a) & (b).

E. 14 C. F.R. § 91.7(a): Civil Aircraft Airworthiness.

This petition seeks an exemption from 14 CFR § 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.

Equivalent Level of Safety

The Aibot X6 V2 has over 200 commercial operators around the world and a 

stellar safety record. Given the size of the sUAS, the requirements contained in 

the SFOSM, Aibot X6 V2 User Manual (X6UM), the training requirements of 

the PIC and SO and use of safety checklists prior to each flight, an equivalent 

level of safety will be provided.

The FAA has issued the following exemptions to this regulation: Exemption 

Order 11062.

F. 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 

CFR § 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.
Given its size, configuration, and load capacity, the Aibot X6 V2 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.

Equivalent Level of Safety

The safety related purpose of this manual requirement can be equally satisfied 

by maintaining the Aibot X6 V2 User Manual (X6UM) at the ground control 

point where the pilot flying the Aibot X6 V2 will have immediate access to it. 

Accordingly, Petitioner requests an exemption from § 91.9(b) (2)'s flight 

manual requirements, on the condition that the Aibot X6 V2 flight manual be 

available at the control point during each operation.

The FAA has issued the following exemptions to this regulation: Exemption 

Order 11062.

G. 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. Inasmuch as an FAA approved flight manual will not be provided for 

the sUAS, an exemption will be needed.

Equivalent Level of Safety

An equivalent level of safety will be provided by following the Aibot X6 V2 

User Manual comprehensive preflight checklist and SOUTEX General Preflight 

Checklist. The PIC will take all actions, including reviewing weather and 

NOTAMs, flight battery requirements, landing and takeoff distances, and 

aircraft performance data, before initiation of flight.

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

This petition seeks an exemption from 14 CFR § 91.109(a), which provides 

that:

(a) 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...

sUAS’s 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.

Equivalent Level of Safety

Given the size and speed of the Aibot X6 V2, an equivalent level of safe 

training can still be performed without dual controls because no pilot or 

passengers are aboard the Aibot X6 V2, the system is equipped with an 

automatic come home feature that can be triggered at any time to respond to 

unpredicted challenges and all persons will be a safe distance away should the 

Aibot X6 V2 experience any difficulties during flight instruction. Additionally, 

the aircraft’s light weight and slow speeds with no pilot or passengers on board 

create less of a danger to the public than aircraft equipped with dual controls.

The FAA has approved exemptions for flight training without fully functional 

dual controls for a number of aircraft and for flight instruction in experimental 

aircraft (See Exemption Nos. 5778K & 9862A) and other SUASs (See FAA 

Order 11062). 

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

This petition seeks an exemption from the minimum safe altitude requirements 

of 14 CFR § 91.119. Section 91.119 prescribes the minimum safe altitudes 

under which aircraft may not operate, including 500 feet above the surface and 

away from any person, vessel, vehicle, or structure in non-congested areas. See 

14 CFR § 91.119(c). Section § 91.119(d) (1) allows for a helicopter to operate 

at less than those minimum 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."

To provide the intended High Definition Surveys (HDS) and inspections, the 

Aibot X6 V2 will normally need to be operated within a range of 75 feet 

laterally from the structures being inspected and under 400’ AGL. Accordingly, 

due to the nature of the proposed operations, the PIC and the SO will be less 

than 100 feet away from structures during the operation, and an exemption is 
therefore required.

Equivalent Level of Safety

Compared to flight operations with rotorcraft weighting far more than the 

maximum 14.55 lbs. proposed herein, and the lack of flammable fuel, any risk 

associated with these operations is far less than those presently presented with 

conventional aircraft. An equivalent level of safety will be achieved given the 

size, weight, speed of the UAS as well as the location where it is operated. As 

set forth in the SFOSM, the Aibot X6 V2 will be operated in a geo-fenced 

sterile area, where buildings and people will not be exposed to operations 

without their pre-obtained consent. No flight will be taken without the 

permission of the property owner and/or local officials. Because of the advance 

notice to the property owner and participants, all affected individuals will be 

aware of the planned flight operations as set forth in the SFOSM. Furthermore, 

by operating at such lower altitudes adjacent to obstructions, the Aibot X6 V2 

will not interfere with other aircraft that are subject to the minimum safe 

altitude regulations.

J. 14 C. F.R. § 91.121 Altimeter Settings.

This petition seeks an exemption from 14 CFR § 91.121, which requires a 

person operating an aircraft to maintain cruising altitude or flight 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 Aibot X6 V2 does 

not have a barometric altimeter, but rather a GPS altitude read out.

Equivalent Level of Safety

An equivalent level of safety will be achieved by following the procedures set 

forth in the General Preflight Checklist in SFOSM. As prescribed in the 

SFOSM, the operator will confirm the altitude of the launch site shown on the 

GPS altitude indicator before flight. The flight plan will be programmed to 

maintain appropriate altitude above ground and under 400’ AGL. Moreover, the 

PIC will use the GPS altitude indicator to constantly monitor the Aibot X6 V2 

height, thus ensuring operation at safe altitudes.
K. 14 C. F.R. § 91.151(a): Fuel Requirements for Flight in V F R 

Conditions.

This petition seeks an exemption from 14 CFR § 91.151(a)'s fuel requirements 

for flight 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.

The battery powering the Aibot X6 V2 provides approximately 30 minutes of 

powered flight. An exemption from the 30 minute reserve requirement in 14 

CFR §91.151 is therefore required.

Equivalent Level of Safety

An equivalent level of safety can be achieved by limiting flights to 30 minutes 

or 25% of battery power, whichever happens first. This restriction would be 

more than adequate to return the Aibot X6 V2 to its launch location from 

anywhere within its limited operating area. Operation of the Aibot X6 V2 with 

less than 30 minutes of reserve fuel does not engender the type of risks that 

Section 91.151(a) was intended to alleviate given the size and speed of the 

Aibot X6 V2. Moreover, operation will be limited to controlled areas where 

only people and property owners, or official representatives who have signed 

waivers will be allowed.

This request for exemption falls within the scope of prior exemptions. See e.g. 

Exemption Order 11062 

L. 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 CFR § 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....

(b)No person may operate a civil aircraft unless the airworthiness certificate 

required by paragraph (a) of this section or a special flight authorization 

issued under §91.715 is displayed at the cabin or cockpit entrance so that 

it is legible to passengers or crew.

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 Aibot X6 V2 load capacity and size does not allow it to carry 

Certification and registration documents; 

(2)The Aibot X6 V2 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.

Equivalent Level of Safety

An equivalent level of safety will be achieved by keeping these documents, to 

the extent they are applicable to the Aibot X6 V2, at the ground control point 

where the pilot flying the Aibot X6 V2 will have immediate access to them.

The FAA has issued numerous exemptions to this regulation. See, inter alia, 

Exemption Order 11062 

M.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 CFR §§ 91.405(a); 91.407(a) (1); 91.409(a) (2); 91.417 (a) & (b). Which 

state:

These regulations specify maintenance and inspection standards in reference to 

14 CFR Part 43. See, e.g., 14 CFR § 91.405(a) (stating that each owner or 

operator of an aircraft "[s]hall 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 Aibot X6 V2 will not have.

Equivalent Level of Safety

An equivalent level of safety will be achieved because maintenance and 

inspections will be performed in accordance with the Aibot X6 V2 User 

Manual. The operator will ensure that the Aibot X6 V2 is in working order prior 

to initiating flight, perform required maintenance, and keep a log of any 

maintenance performed. The operator is most familiar with the aircraft and best 

suited to maintain the aircraft in an airworthy condition to provide the 

equivalent level of safety.

If mechanical issues arise, the Aibot X6 V2 can land immediately and will be 

operating no higher than 400 feet AGL. Moreover, the Aibot X6 V2 small size, 

carrying capacity, and the fact that flight operations will only take place in 

restricted areas for limited periods of time, create less risk than the same factors 

associated with conventional fixed-wing aircraft and rotorcraft performing the 

same operation.

V. Privacy

All flights will occur over Petitioner's property or the customer's property 

with the customer's prior knowledge and consent.

VI. Federal Register Summary 

Pursuant to 14 CFR Part 11, the following summary is provided for 

publication in the FEDERAL REGISTER, should it be determined that publication 

is needed:

Soutex, Inc. seeks an exemption from the following rules:

14 CFR Part 21, Subpart H; 14 CFR § 91.203(a)(1); 14 CFR Part 27; 14 CFR §§ 

91.9(c), 45.23(b) and 45.27(a); 14 CFR § 61.113 (a) & (b); 14 CFR § 91.7(a); 

91.9(b)(2); 91.103; 91.109(a); 91.119; 91.121; 91.151(a); 91.203 (a) & (b); 

91.405(a); 91.407(a)(1); 91.409(a)(2); 91.417 (a) & (b)

Approval of exemptions allowing commercial operations of small and 

lightweight unmanned aircraft (sUAS) in the surveying and engineering industry 

will enhance safety by reducing risk to human life. Conventional operations in this 

industry using personnel to climb stockpiles, quarries, sand pits, or other type 

structures present the risks associated with unknown hazards that often lead to 
accidents, incidents and fatalities.

In contrast, the Aibot X6 V2 weighing fewer than 14.55 lbs. and powered by 

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

combustible fuel carried on board. The Aibot X6 V2 is transported, not flown, to 

the designated survey area and set up. The Aibot X6 V2 carries no passengers or 

crew and provides the inspection services eliminating the requirement for 

personnel to climb the structure and, therefore does not expose personnel to the 

risks associated with unknown hazards.

The operation of sUAS like the Aibot X6 V2, weighing less than 14.55 lbs., 

provides an equivalent level of safety and thus supports the grant of the exemptions 

requested herein, including exempting the applicant from the requirements of Part 

21 and allowing commercial operations. The lightweight sUAS operate at slow 

speeds, close to the ground, and in a sterile environment adjacent to obstructions. 

As a result, they are far safer than conventional aerial survey and inspection 

operations conducted with fixed-wing aircraft or helicopters or manned tower 

climbs.

VII. Conclusion 

The Aibotix X6 V2 as a result of its size, weight, speed, and operational capability, 

does not create a hazard to users of the national airspace system or pose a threat to 

national security. The Aibotix X6 V2 will be operated in accordance with safety 

protocols defined in the SFOSM, for which we request approval by the FAA 

according to its authority granted by Congress in Section 333 of the FAA 

Modernization and Reform Act of 2012. When operated by licensed pilots over 

quarries, stockpiles, landfills, and marsh land the sUAS used for survey and 

inspection will reduce the risk and duration of exposure to risk for employees, 

contractors, and nearby communities. Adequate justification exists for the grant of 

the requested exemptions allowing commercial operation of sUAS by Soutex, Inc.

Submitted separately as confidential documents under 14 CFR Section 11.35 (b) 

are:

Aibotix X6 Spec Sheet

Aibotix X6 User Manual

Soutex Flight Operations and Safety Manual (SFOSM)

These documents contain proprietary information that is not available to the 

public and are protected from release under the Freedom of Information Act 5 USC 

552et.seq.