August 20, 2015

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Docket Operations

U.S. Department of Transportation 

1200 New Jersey Avenue, SE, Room W12-140

West Building Ground Floor

Washington, DC 20590Subject: Petition of Titan Aerospace Holdings, Inc. for Section 333 Summary 

Grant Exemption from Certain Federal Aviation Regulations to Permit Small UAS Operations 

Federal Aviation Regulations from which Exemption is requested:

Title 14 CFR Part 61 §§ 61.23(a) and (c), 61.101(e)(4) and (5), 61.113(a), 61.315(a),

Title 14 CFR Part 91 §§ 91.7(a), 91.119(c), 91.121, 91.151(a)(1), 91.405(a), 91.407(a)(1), 91.409(a)(1) 

and (2), and 91.417(a) and (b)

Dear Sir/Madam,

Titan Aerospace Holdings, Inc. (hereafter “Titan Aerospace”) is in the business of design, development, 

and manufacture of a series of several small unmanned aircraft systems (UAS) models for the purpose of 

aerial data collection, including but not limited to research and development (R&D). Titan Aerospace will 

maintain operational control of these aircraft at all times. 

Exemption Request:

Pursuant to Section 333 of Public Law No. 112-95 and 14 CFR §§ 11.61(b), 11.63, and 11.81, Titan 

Aerospace is requesting a summary grant exemption from the above-referenced regulations for the 

aircraft model series and aerial data collection operations, including R&D, described in the following 

paragraphs. As explained below, Titan Aerospace’s proposed small UAS operations, as conditioned and 

limited herein, will not adversely affect safety, but rather will provide an equivalent or greater level of 

safety than that provided by the current rules and large manned or non-exempt aircraft operations. These 

operations also will not create a hazard to users of the National Airspace System or the public, nor will 

they pose a threat to national security.

Titan Aerospace also requests that the FAA grant the requested exemption on an expedited basis. To 

that end, as detailed below, Titan Aerospace agrees to comply with the conditions and limitations 

imposed in recent Section 333 summary grant exemptions. Moreover, the proposed operations and 

requested exemptions are consistent with previously granted summary grant exemptions. See, e.g., 

Exemption No. 11345 (FAA-2015-0048; April 16, 2015) (Precision Hawk); Exemption No. 11316 (FAA2014-1063; April 9, 2015) (Precision Drone); Exemption No. 11290 (FAA-2014-0474; April 8, 2015) 

(Amazon); Exemption No. 11281 (FAA-2014-0963; April 6, 2015) (Draganfly Innovations). Given that 

Titan Aerospace agrees to comply with these conditions and limitations, given that this Petition is similar 

in all material respects to those petitions for which summary grant exemptions have been granted, and 

that the proposed UAS use falls within the category of uses permitted by numerous summary grant 

exemptions, no new precedent would be set by granting the requested exemption to Titan Aerospace. 

Accordingly, as with the Precision Hawk Exemption (No. 11345), good cause exists for the FAA to move 

forward with consideration of this Petition and the grant of this exemption without publishing a summary of 

the Petition in the Federal Register. 

The UAS: 

Operations under this exemption will be limited to Titan Aerospace-designed and manufactured multiengine, battery-powered, fixed wing, small UAS (Models M1, M2 and their variants). The UAS model 

series under this exemption currently have the following basic characteristics and limitations in their size, 

mass, and energy:

Wingspan: 25 ft (maximum)

Weight: 20 lbs (maximum)
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Speed: 20 kts (maximum)

Note: The small unmanned aircraft (UA) portion of each 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. Markings will be as large as practicable.

Operational History:

Aircraft on the smaller end of this model series (representative in terms of configuration and control 

systems) have been successfully flown within large enclosed buildings.

Preflight activities:

Preflight inspection and test of the motor and flight surfaces will be performed by the Pilot in Command 

for the flight. A preflight safety risk assessment will be performed to consider any changes to the UA, 

adherence to the limitations of this exemption request, and changes to ground and air traffic conditions. 

Scheduled maintenance is not required. Maintenance and repair actions will be documented in a sUAS 

maintenance logbook for each aircraft. 

Radio Frequency Spectrum:

A commercial remote control transceiver will be utilized for control of the aircraft. These controllers 

operate in the 2.4GHz spectrum, with relatively low power output (less than 1 Watt) and do not fall under 

FCC licensing requirements (transmitters are identified as Class B under 47 CFR Part 15 of FCC rules). 

Pilot in Command and Observer:

The Pilot in Command (PIC) for each operation will hold, at a minimum, a sport pilot certificate and a 

current FAA airmen medical certificate or valid US driver’s license issued by a state, the District of 

Columbia, Puerto Rico, a U.S. territory/possession, or the Federal government. 

A Visual Observer will be used and designated for each flight operation. Each Visual Observer will hold, 

at a minimum, a sport pilot certificate or will have completed company observer training (approved by the 

FAA). Each Visual Observer will hold a current FAA airman medical certificate or valid US driver’s license 

issued by a state, the District of Columbia, Puerto Rico, a U.S. territory/ possession, or the Federal 

government. 

Flight Operations Limitations:

Each UA will be operated clear of populated areas and airfields, at or below 200 ft AGL, in daytime VFR 

conditions, with minimum visibility of 3 statute miles, more than 500 feet below and 2,000 feet laterally 

from any clouds, within Visual Line of Sight (VLOS) of the designated PIC and Visual Observer. A Visual 

Observer will be used in all flight operations. All operations will be conducted over private or restricted 

access land with permission of the land owner or land controller. The PIC will yield right-of-way to all 

manned aircraft. In the event of air traffic entering the flight area (within one mile and 500 ft of the sUAS), 

flight operations will cease immediately in a manner ensuring the safety of nonparticipating persons or 

aircraft.

As noted above, Titan Aerospace’s small UAS operations under the requested Section 333 summary 

grant exemption will be conducted in accordance with and subject to previously granted summary grant 

exemption conditions and limitations (No. 1-28), as listed in Appendix B for reference.

Due to the factors described above, the conditions and limitations under which Titan Aerospace will 

operate its small UAS, and the explanations in Appendix A, Titan Aerospace’s operations of its low 

energy small UAS models will provide an equivalent or greater level of safety than non-exempted aircraft 

and air operations, and further will not pose a risk to either airspace users or the uninvolved public.

In Appendix A, Titan Aerospace provides the basic information required by 14 CFR § 11.81 for exemption 

petitions and further details the reasons why granting the requested Section 333 summary grant 

exemption would be in the public interest and would not adversely affect safety. Further, no new 
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precedent would be established by granting this exemption request, therefore publishing in the Federal 

Register is unnecessary and a summary grant of the exemption is respectfully requested.

We appreciate your timely review of this exemption request. Please contact me with any questions at 

505-373-7187.

Best regards,

Chris Jackman

Titan Aerospace Certification

Titan Aerospace Holdings, Inc

50 George Applebay Way, #200

Moriarty, NM 87035

cc: Rob Pappas

 FAA UAS Integration Office, AFS-80

Attachments: 

1. Appendix A – 14 CFR 11.81 Elements

2. Appendix B – Previously Granted Limitations Consistent with Authorization Requested
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Appendix A – 14 CFR 11.81 Elements

14 CFR 11.81(a) Your name and mailing address and, if you wish, other contact information such 

as a fax number, telephone number, or e-mail address;

Titan Aerospace Holdings, Inc.

c/o Chris Jackman

50 George Applebay Way, #200

Moriarty, NM 87035

Tel. 505-373-7187

Email: cjackman@google.com

14 CFR 11.81(b) The specific section or sections of 14 CFR from which you seek an exemption:

Title 14 CFR Part 61 §§ 61.23(a) and (c), 61.101(e)(4) and (5), 61.113(a), 61.315(a),

Title 14 CFR Part 91 §§ 91.7(a), 91.119(c), 91.121, 91.151(a)(1), 91.405(a), 91.407(a)(1), 91.409(a)(1) 

and (2), and 91.417(a) and (b)

14 CFR 11.81(c) The extent of relief you seek, and the reason you seek the relief:

Titan Aerospace seeks relief pursuant to this exemption request from applicable parts of the Federal 

Aviation Regulations identified above to the extent necessary to permit sUAS flight operations within the 

National Airspace within the bounds of this exemption request.1 The FAA has granted Section 333 

summary grant exemptions from these same regulatory provisions to other petitioners proposing similar 

small UAS operations subject to the same conditions and limitations. See, e.g., Exemptions No. 11345 

(Precision Hawk), No. 11316 (Precision Drone), No. 11290 (Amazon), and No. 11281 (Draganfly). 

14 CFR 11.81(d) The reasons why granting your request would be in the public interest; that is, 

how it would benefit the public as a whole:

Granting the exemption requested by Titan Aerospace would allow for safe and efficient small UAS flight 

operations without the burden to the FAA of reviewing each model and major design change to each 

model within the program under the provisions for experimental airworthiness certification. Experience 

from this program will inform Titan Aerospace’s development and later efforts with larger scale flight 

articles.

Without this exemption, each Titan Aerospace UA model and major change would be subject to FAA 

review for individual airworthiness to a degree greater than the aircraft energy and operational risk would 

warrant.

In addition, the use of these small UAS by Titan Aerospace for aerial data collection, including R&D, will 

enhance the development of these future UAS makes/models for use in various commercial roles, 

including serving as a platform for the extension of internet service to underserved areas of the world.

14 CFR 11.81(e) The reasons why granting the exemption would not adversely affect safety, or 

how the exemption would provide a level of safety at least equal to that provided by the rule from 

which you seek the exemption;

Throughout this Petition, Titan Aerospace has discussed many reasons why granting an exemption from 

each section of the Federal Aviation Regulations from which relief is sought would result in UAS operations 

that provide a level of safety equal to, or greater than, that provided by the rule from which exemption is 

sought. Moreover, the many conditions and limitations proposed in this Petition, coupled with the 

operational protocols for these small UAS, also would ensure at least an equivalent level of safety, as the 

FAA has concluded in numerous other Section 333 summary grant exemptions. In general, the risks of any 

 1 Titan Aerospace further requests that, to the extent the FAA concludes that an exemption from one or more 

other provisions of the Federal Aviation Regulations would be required to permit the small UAS operations described 

in this Petition, the FAA grant an exemption from those regulatory provisions as necessary to permit the UAS 

operations described in this Petition.
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small UAS operation proposed in this Petition interfering with a manned aircraft would be minimized by 

numerous factors, including but not limited to: 

• the low altitude at which the UAS would operate; 

• the locations at which the UAS would operate (e.g., remote areas; private or controlledaccess property; away from airports); 

• the small size, light weight, and relatively slow speed of these small UAS; 

• the restriction on UAS operations to VMC and daytime conditions; and 

• the requirement for the UA to be operated within the VLOS of the PIC and VO at all times. 

• Importantly, these small UAS have several other safety-related characteristics due to their 

extreme low weight for size.

The risks to persons or property on the ground would be substantially mitigated – if not eliminated – by 

these same factors, as well as the 500-foot set-off from non-participating persons, vehicles, and structures 

absent additional safeguards. Per the conditions and limitations proposed in this Petition, (i) the PIC will 

suspend/abort the UAS operation and UA flight in the event of unpredicted obstacles or emergencies; and 

(ii) Titan Aerospace will coordinate extensively, as warranted, with the FAA, with local airports, and with 

property owners to ensure that all of its UAS operations under the exemption are at least as safe as would 

be manned aircraft operations used for similar purposes.

The conditions and limitations proposed in this Petition (which have been found by the FAA to be acceptable 

for other summary grant exemptions) and the operational safety features of these small UAS provide 

substantial protection against interference with manned aircraft operations or with the safety of persons or 

property on the ground. For these reasons, granting an exemption from each section of the Federal Aviation 

Regulations from which relief is sought would not adversely affect safety, and would provide a level of safety 

at least equal to, or greater than, that provided by the rule from which exemption is sought. 

14 CFR 11.81(f) A summary we can publish in the Federal Register, stating:

(1) The rule from which you seek the exemption; and

(2) A brief description of the nature of the exemption you seek;

Petitioner: Titan Aerospace Holdings, Inc.

Sections of Title 14 CFR that Titan seeks and exemption:

Title 14 CFR Part 61 §§ 61.23(a) and (c), 61.101(e)(4) and (5), 61.113(a), 61.315(a), 

Title 14 CFR Part 91 §§ 91.7(a), 91.119(c), 91.121, 91.151(a)(1), 91.405(a), 91.407(a)(1), 91.409(a)(1) 

and (2), and 91.417(a) and (b)

Titan Aerospace seeks relief from existing regulations via exemption to allow for the use of certain 

operational limitations to safely and efficiently operate a series of small unmanned aircraft in secure or 

remote portions of the national airspace for aerial data collection purposes, including company research 

and development. 

14 CFR 11.81(g) Any additional information, views or arguments available to support your request; 

and

Granting this exemption request will greatly reduce the burden on the FAA and associated cost to the 

taxpayer for experimental certificate issuance (ref: 14 CFR 21.191(a)) of each model and subsequent 

major changes throughout Titan’s sUAS research and development program.

The operational and flight limitations proposed by Titan Aerospace are of the same nature as, and 

provide a level of safety equivalent to, or greater than, those granted to other applicants via exemption. 

Further, no new precedent would be established by granting this exemption request.

14 CFR 11.81(h) If you want to exercise the privileges of your exemption outside the United States, 

the reason why you need to do so.

Not requested.
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Appendix B – Previously Granted Limitations Consistent with Authorization Requested

1. Operations authorized by this grant of exemption are limited to Titan Aerospace-designed and 

manufactured multi-engine, battery-powered, fixed wing, small UAS [Models M1 M2 and variants] when 

weighing less than 55 pounds including payload. Proposed operations of any other aircraft will require a 

new petition or a petition to amend this exemption.

2. Operations for the purpose of closed-set motion picture and television filming are not permitted.

3. The UA may not be operated at a speed exceeding 87 knots (100 miles per hour). The exemption holder 

may use either groundspeed or calibrated airspeed to determine compliance with the 87 knot speed 

restriction. In no case will the UA be operated at airspeeds greater than the maximum UA operating 

airspeed recommended by the aircraft manufacturer.

4. The UA must be operated at an altitude of no more than 400 feet above ground level (AGL). Altitude must 

be reported in feet AGL.

5. 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 airman medical certificate or U.S. driver’s license.

6. All operations must utilize a visual observer (VO). The UA must be operated within the visual line of sight 

(VLOS) of the PIC and VO at all times. 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; electronic messaging or texting is not permitted during flight operations. The PIC must be designated 

before the flight and cannot transfer his or her designation for the duration of the flight. The PIC must 

ensure that the VO can perform the duties required of the VO.

7. This exemption and all documents needed to operate the UAS and conduct its operations in accordance 

with the conditions and limitations stated in this grant of exemption, are hereinafter referred to as the 

operating documents. The operating documents must be accessible during UAS operations 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 operating documents, the conditions and limitations 

herein take precedence and must be followed. Otherwise, the operator must follow the procedures as 

outlined in its operating documents. The operator may update or revise its operating documents. It is the 

operator’s responsibility to track such revisions and present updated and revised documents to the 

Administrator or any law enforcement official upon request. The operator must also present updated and 

revised documents if it petitions for extension or amendment to this grant of exemption. If the operator 

determines that any update or revision would affect the basis upon which the FAA granted this exemption, 

then the operator must petition for an amendment to its grant of exemption. The FAA’s UAS Integration 

Office (AFS−80) may be contacted if questions arise regarding updates or revisions to the operating 

documents.

8. 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 prior to 

conducting further operations under this exemption. Functional test flights may only be conducted by a PIC 

with a VO and must remain at least 500 feet from other people. The functional test flight must be conducted 

in such a manner so as to not pose an undue hazard to persons and property.
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9. The operator is responsible for maintaining and inspecting the UAS to ensure that it is in a condition for 

safe operation.

10.Prior to each flight, the PIC must conduct a pre-flight inspection and determine the UAS is in a condition for 

safe flight. The pre-flight inspection must account for all potential discrepancies, e.g., inoperable 

components, items, or equipment. 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.

11.The operator must follow the UAS manufacturer’s maintenance, overhaul, replacement, inspection, and life 

limit requirements for the aircraft and aircraft components.

12.Each UAS operated under this exemption must comply with all manufacturer safety bulletins.

13.Under this grant of exemption, a PIC must hold either an airline transport, commercial, private, recreational, 

or sport pilot certificate. The PIC must also hold a current FAA airman medical certificate or a valid U.S. 

driver’s license issued by a state, the District of Columbia, Puerto Rico, a territory, a possession, or the 

Federal government. 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.

14.The operator may not permit any PIC to operate unless the PIC demonstrates the ability to safely operate 

the UAS in a manner consistent with how the UAS will be operated under this exemption, including evasive 

and emergency maneuvers and maintaining appropriate distances from persons, vessels, vehicles and 

structures. PIC qualification flight hours and currency must be logged in a manner consistent with 14 CFR § 

61.51(b). Flights for the purposes of training the operator’s PICs and VOs (training, proficiency, and 

experience-building) and determining the PIC’s ability to safely operate the UAS in a manner consistent 

with how the UAS will be operated under this exemption are permitted under the terms of this exemption. 

However, training operations may only be conducted during dedicated training sessions. During training, 

proficiency, and experience-building 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.

15.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.

16.The UA may not operate within 5 nautical miles of an airport reference point (ARP) as denoted in the 

current FAA Airport/Facility Directory (AFD) or for airports not denoted with an ARP, the center of the 

airport symbol as denoted on the current FAA-published aeronautical chart, unless a letter of agreement 

with that airport’s management is obtained or otherwise permitted by a COA issued to the exemption 

holder. The letter of agreement with the airport management must be made available to the Administrator 

or any law enforcement official upon request.

17.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.

18.If the UAS loses communications or loses its GPS signal, the UA must return to a pre-determined location 

within the private or controlled-access property.

19.The PIC must abort the flight in the event of unpredicted obstacles or emergencies.
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20.The PIC is prohibited from beginning a flight unless (considering wind and forecast weather conditions) 

there is enough available power for the UA 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.

21.Air Traffic Organization (ATO) Certificate of Waiver or Authorization (COA). All operations shall be 

conducted in accordance with an ATO-issued COA. The exemption holder may apply for a new or 

amended COA if it intends to conduct operations that cannot be conducted under the terms of the attached 

COA.

22.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.

23.Documents used by the operator to ensure the safe operation and flight of the UAS and any 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.

24.These documents must be made available to the Administrator or any law enforcement official upon 

request.

25.The UA must remain clear and give way to all manned aviation operations and activities at all times.

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

26.All Flight operations must be conducted at least 500 feet from all nonparticipating persons, vessels, 

vehicles, and structures unless:

Barriers or structures are present that sufficiently protect nonparticipating persons from the UA and/or 

debris in the event of an accident. The operator must ensure that nonparticipating persons remain under 

such protection. If a situation arises where nonparticipating persons leave such protection and are within 

500 feet of the UA, flight operations must cease immediately in a manner ensuring the safety of 

nonparticipating persons; and

The owner/controller of any vessels, vehicles or structures has granted permission for operating closer to 

those objects and the PIC has made a safety assessment of the risk of operating closer to those objects 

and determined that it does not present an undue hazard.

The PIC, VO, operator trainees or essential persons are not considered nonparticipating persons under this 

exemption.

27.All operations shall be conducted over private or controlled-access property with permission from the

property owner/controller or authorized representative. Permission from property owner/controller or 

authorized representative will be obtained for each flight to be conducted.

28.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.