Lester Forsythe 

President and Operations Manager Oct. 27, 2015 

Volant Unmanned Aerial Solutions 

360 Pinellas Bayway S. Unit A 

Saint Petersburg, FL 33715 

U.S. Department of Transportation 

Docket Management System 

1200 New Jersey Ave., SE 

Washington, DC 20590 

Dear Sir or Madam: 

Attached, please find Volant Unmanned Aerial Solutions, hereinafter referred to as Volant, request 

for an exemption from certain stated Federal Aviation Regulations to allow commercial operation 

of its small unmanned aircraft systems (hereafter referred to as “SUAS” or “Drone”) for the 

purposes of aerial photography, cinematography, videography, mapping, crop surveying, aerial 

inspections, data collection, security monitoring, public safety, first responder and emergency 

response, SUAS training, flight demonstrations, and other flight operations, 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 of the FAA Modernization and Reform Act of 2012. 

Please be advised that the FAA has previously issued grants of exemption in circumstances 

similar in all material aspects to those requested in this petition, most recently in Exemption Nos. 

13313 to Sentera, LLC, 11442 & 11487 to HAZON Solutions, 11157 to Likeonatree Aerial, 

11446 to Trumbull Unmanned LLC, 11552 to Sinclair Community College, 11110 to Trimble 

Navigation Ltd. for fixed wing SUAS similar to the fixed wing SUAS proposed herein, and 

11925 to James Michael Hourihan for VTOL SUAS-based emergency response support 

operations. Therefore, Volant respectfully requests this exemption be considered under the 

“summary grant” process. 

As detailed in this document, a granted exemption would permit the commercial operation of 

SUAS under controlled conditions in airspace that is limited and controlled via subsequent COA 

applications. Predominantly, Volant seeks to operate under the “Blanket 200ft COA” guidance 

that was issued by the FAA in March 2015 and respectfully requests the “Blanket 200ft COA” be 

granted in concert with these exemptions. 

The requested exemptions and proposed limitations provide for at least an equivalent or higher 

level of safety to operations under the current regulatory structure, specifically safety 

enhancements to personnel climbing vertical infrastructure and create a low-risk alternative to 

certain manned aviation operations. 

As outlined in this request for exemption, the SUAS Volant proposes to use are:

 DJI Phantom II, III

 DJI Inspire I

 Sentera Phoenix 

 Lockheed Martin Procerus Technologies (LMPT) Indago 
Name and address of the petitioner: 

Volant Unmanned Aerial Solutions 

360 Pinellas Bayway S. Unit A 

Saint Petersburg, FL 33715 

If I can provide any additional information in support of your review of this petition, please do 

not hesitate to call me at 727-202-1516 or send an email to les.forsythe@volantuas.com. 

Sincerely, 

/s/ 

Lester Forsythe

President and Operations Manager

Volant Unmanned Aerial Solutions

2
Section 1: Introduction & Interest of Volant 

Volant Unmanned Aerial Solutions provides professional-grade Small Unmanned Aerial Systems 

(SUASs), state-of-the-art cameras and sensors, along with SUAS consulting and training services. 

We are also an authorized reseller for Sentera, designer, manufacturer and distributor of durable, 

high-quality sensors, unmanned aerial vehicles, and imaging software. Volant’s staff is comprised 

of qualified personnel with decades of aeronautical experience including radio-controlled 

aircraft, general aviation aircraft, as well as flight test experience with high-performance military 

aircraft. The staff and leadership at Volant have several years of experience in the SUAS industry 

and have flown several-thousand flight hours on various unmanned aircraft systems. Volant has 

the background and team to safely integrate SUAS within the NAS and provide low-risk, costeffective systems and airborne data and photography to its customers. 

Volant proposes to commercially operate its SUAS platforms for the purposes of aerial 

photography, cinematography, videography, mapping, crop surveying, aerial inspections, data 

collection, security monitoring, public safety, first responder and emergency response, SUAS 

training, flight demonstrations and other flight operations conforming to the proposed limitations 

and restrictions. Volant holds that commercially operating an SUAS within the NAS under these 

same limitations and restrictions will not pose a hazard to manned aircraft, and that operation of 

its SUAS is in the public best interest by providing an inexpensive, low-risk alternative to 

manned flight survey and inspection operations. 

Section 2: Regarding the Unmanned Aircraft System

The FAA’s public guidance on filing an exemption under Section 333 is reprinted below. This 

section intends to fulfill each requirement of this guidance. 

1. Petitioners should describe how the proposed UAS operation will be safely conducted to 

minimize risk to the NAS or to persons and property on the ground. Specifically, petitioners 

should describe the design and operational characteristics for the type(s) of UAS they intend to 

operate, e.g. aircraft performance and performance limitations, operating procedures, and 

aircraft loading information in as much detail as possible. This could be provided in the petition 

or in an Aircraft Flight Manual or similar document. 

NOTE: The FAA will consider all information and data submitted by the petitioner that describes 

the UAS developmental and operational history. This could include statistical data or other 

documentation for the specific design and performance characteristics of the UAS, including the 

operational history and operational failure modes, obtained through previous Research & 

Development (R&D) and/or flight test activities, e.g. operations conducted under a COA, with a 

civil airworthiness certificate, or under other authorized operating conditions. 

2. Petitioners should describe any procedures they would implement, such as pre-flight 

inspections, maintenance, and repair, to ensure that the UAS is in a condition for safe flight. This 

could be provided in the petition, an Aircraft Flight Manual, a Maintenance and Inspection 

Manual, or similar document. 

NOTE: The Aircraft Flight Manual and Maintenance and Inspection Manual may 

be separate documents or combined in a single document. 

3. The petitioner should describe the Radio Frequency (RF) spectrum used for control of the UAS 

and associated equipment that is part of the UAS (i.e., sensors, cameras, etc.), and whether it 

3
complies with Federal Communications Commission (FCC) or other appropriate government 

oversight agency requirements. 

NOTE: Petitioners should be able to provide the FCC approval letter or show compliance with 

FCC requirements upon request. 

Volant intends to commercially operate SUAS weighing less than 55 lbs, during daylight hours, 

within visual line of sight of the Pilot In Command (PIC), at altitudes less than 400 ft AGL and at 

speeds less than 100 mph. As described later, Volant PICs shall be fully qualified airmen, holding 

at least a sport pilot certificate and associated medical clearance. The proposed SUAS are 

equipped with GPS-enabled autopilots, capable of safe, steady autonomous flight and guided by 

the PIC. The proposed SUAS are commercially available, “off the shelf” products that have 

accumulated innumerable flight hours across the world, and they have proven themselves lowrisk, safe aircraft. Given the small size and weight, low altitudes, slow speeds, a qualified PIC, a 

GPS-equipped autopilot, data-link and countless flight hours, Volant holds that commercially 

operating these SUAS under the limitations and restrictions set forth is a safe alternative to the 

current regulatory structure and minimizes risk to the NAS or to persons and property on the 

ground. 

2.1 Proposed SUAS

Volant intends to operate the DJI Phantom and Inspire family of SUAS (VTOL), the 

Sentera Phoenix family of SUAS (fixed-wing) and the Lockheed Martin Procerus 

Technologies (LMPT) Indago family of SUAS (VTOL). These aircraft have the ability 

to carry payloads such as cameras, sensors and other equipment necessary to complete its 

aerial photography, cinematography, videography, mapping, crop surveying, aerial 

inspections, data collection, security monitoring, public safety, first responder and 

emergency response, SUAS training, and flight demonstration tasks. Each SUAS is 

described below. 

DJI Phantom 

The Phantom system is comprised of a four-rotor unmanned aircraft and 

handheld controller, which is responsible for both operation and camera 

functions. The maximum gross weight of the Phantom is 1250g, and it measures 

350mm across rotor-to-rotor. Its maximum horizontal, ascent and descent speeds 

are 15 m/s, 6m/s and 2m/s respectively. The Phantom is powered with a Lithium 

Ion battery and flies for approximately 20 minutes. More detailed specifications 

are available in the DJI Phantom Operations Manuals, which are attached as 

Appendix 1 and 2. 

DJI Inspire 

The Inspire system is comprised of a four-rotor unmanned aircraft and handheld 

controller, which is responsible for both operation and camera functions. The 

maximum gross weight of the Inspire is 3000g, and it measures 438 x 451 x 

301mm. The Inspire’s maximum horizontal, ascent and descent speeds are 22m/s, 

5m/s and 4m/s respectively. The Inspire is powered by a Lithium Ion battery and 

flies for approximately 20 minutes. More detailed specifications are available in 

the DJI Inspire Operations Manual, which is attached as Appendix 3.

4
Sentera Phoenix 

The Sentera Phoenix is comprised of a fixed wing, hand-launched, propeller 

driven unmanned aircraft and a laptop or tablet based ground controller, 

responsible for both vehicle operation and camera functions, along with a 

communications data link providing bi-directional communications between the 

air vehicle and the ground control station. The Phoenix SUAS has the ability to 

conduct hand-launched takeoffs, precision landings in varied terrain and execute 

standard horizontal flight maneuvers. The maximum gross weight of the Phoenix 

is 3.5 pounds (1588g), and it measures 8 inches (203mm) tall, 22-26 inch 

(559-660mm) long (depending on the model) and has either a 38 inch (965mm) 

or a 48 inch (1219mm) wingspan (again depending on the model). Its standard 

cruise speed is 29-35 mph (25-30 ktas, 13-15 m/sec) and maximum ascent and 

decent speeds are 800 ft/min (4.1 m/sec) and 400 ft/min (2.0 m/sec) respectively. 

The Phoenix is powered with a Lithium Ion battery and flies for approximately 

60 minutes. Detailed specifications are available in the Sentera Phoenix UAS 

pilot operational handbook attached as Appendix 9. 

The Sentera Phoenix system has been proven to be a reliable and effective system 

for operations such as those proposed herein and has previously been approved 

for similar uses by the FAA. The Sentera Phoenix is an evolution of the Vireo 

UAS, originally produced by UTC Aerospace Systems by the team that now 

forms the core engineering team of Sentera. The Sentera Phoenix’s immediate 

predecessor, the Vireo is currently operating in numerous FAA-approved Public 

COAs as identified below: 

• 2013-ESA-46 COA Hyde (Proponent: NC State University) 

• 2013-ESA-65 COA Butner (Proponent: NC State University)

• 2013-ESA-69 COA Caratoke (Proponent: NC State University)

• 2014-ESA-93 COA Vernon James (Proponent: NC State University)

• 2014-ESA-114 COA Lake Wheeler (Proponent: NC State University)

• 2015-CSA-24 COA Springfield Airpark (Proponent: Sinclair Community 

College)

• 2015-CSA-56 COA Wilmington Airpark (Proponent: Sinclair Community 

College) 

Lockheed Martin Procerus Technologies (LMPT) Indago

The Indago system is comprised of a four-rotor Vertical Takeoff and Landing 

(VTOL) unmanned aircraft and ground control station, either a handheld 

controller or a laptop/tablet-based control station, which is responsible for both 

vehicle operation and camera functions, along with a communications data-link 

providing bi-directional communications between the air vehicle and the ground 

control station. The Indago SUAS has the ability to conduct vertical takeoffs and 

landings, hover and execute standard horizontal flight maneuvers. The maximum 

gross weight of the indigo is 4.85 pounds (2200g) and it measures 32 x 32 x 

9” (813 x 813 x 229mm). The Indago’s maximum horizontal speed is 30 mph 

(13.4 m/sec), maximum ascent speed is 800 ft/m (4.1 m/sec), and maximum 

decent speed is 400 ft/m (2.0 m/sec). The Indago is powered by a Lithium Ion 

battery and flies for approximately 45 minutes. More detailed specifications are 

available in the Indago user’s guide attached as Appendix 11. 

The Indago System has been proven to be a reliable and effective system for 

operations such as those proposed herein and has previously been approved for 

5
similar uses by the FAA in the form of numerous Section 333 Exemptions, such 

as those outlined on page 1 of the cover letter above. 

2.2 Maintenance & Inspection 

Volant shall follow the manufacturer’s maintenance, overhaul, inspection and 

record-keeping guidelines as specified in both the maintenance manuals and 

operations manuals, attached as Appendices 1 - 12 . Volant will conduct 

inspections and maintenance, which shall be noted in the aircraft’s logbook 

including total flight hours and the nature of maintenance performed. 

Comprehensive maintenance will be performed in conformance with the 

manufacturer’s guidelines. 

In advance of every flight operation, the Pilot In Command (PIC) will thoroughly 

inspect the SUAS to ensure it is safe to fly as described in the relevant 

manufacturer user manuals and checklists, attached as appendices. Furthermore, 

the PIC will conduct a pre-flight checklist as described in the Operations Manual. 

With both inspections completed and passed, the SUAS shall be deemed safe to 

fly. 

All SUAS proposed under this request for exemption will be in compliance with 

all manufacturer maintenance, system and safety bulletins. 

 2.3 Radio Communications 

All radio systems used in the proposed SUAS comply with FCC regulations and 

have earned FCC approval. Volant shall operate the SUAS in compliance with 

those approvals. Certificates of compliance may be found in Operations manuals 

in Appendices 1 - 3, 9, and 11. 

Section 3: Regarding the Unmanned Aircraft PIC

The FAA’s public guidance on filing an exemption under Section 333 is reprinted below. This 

section intends to fulfill each requirement of this guidance. 

Regarding the Unmanned Aircraft PIC 

4. Petitioners should describe the qualifications required of any PIC(s) who will be directly 

responsible for the operation of the UAS, including information such as: the level of airman 

certificate held; any applicable training related to the operation; and any minimum hours of 

flight experience required by the PIC(s), both total flight time and the time with the particular 

UAS. If the operation would use visual observers, petitioners should describe their roles and 

qualifications. 

5. Petitioners should describe the medical standards and certification of the PIC(s) directly 

responsible for the operation of the UAS. 

Volant PICs shall possess a current airline transport, commercial, private, recreational or sport 

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

Driver’s License. The PIC shall 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. 

6
Prior to commercial operations, Volant PICs shall have accumulated and logged a minimum of 25 

hours total time as an SUAS pilot. Flights for the purposes of training Volant’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 requested under the terms of this exemption. Training operations shall only be conducted 

during dedicated training sessions. During training, proficiency, and experience-building flights, 

all persons not essential for flight operations shall be considered nonparticipants, and the PIC 

shall operate the UA with appropriate distance from nonparticipants in accordance with 14 CFR § 

91.119. 

Section 4: Regarding the Operation of the Unmanned Aircraft

The FAA’s public guidance on filing an exemption under Section 333 is reprinted below, along 

with Volant’s proposal. This section intends to fulfill each requirement of this guidance. 

Regarding the Operation of the Unmanned Aircraft 

6. Petitioners should fully describe their intended UAS operation(s). Petitioners should 

describe how the proposed operation(s) would not adversely affect safety, or how they 

would provide a level of safety at least equivalent to that provided by the rule from which 

exemption is sought. Petitioners should address any plans to implement clearly defined 

operational borders and procedures to ensure public safety, which includes persons and 

property both in the air and on the ground. This can be described in the petition, in an 

Operations Manual, or similar document. 

NOTE: The FAA will closely examine the proposed operation(s) with respect to safety of 

flight, NAS safety considerations, and the safety of the non-participating persons and 

property during the operational period and within the operational area. 

7. Petitioners should specify the proposed maximum operating speed and altitude, and 

describe minimum flight visibility and distance from clouds for their intended 

operation(s). Petitioners should describe potential hazards and safety mitigations 

associated with these proposed conditions. These issues can be addressed in the petition, 

an Operations Manual, or similar document. 

Each SUAS will be operated during daylight hours, in compliance with visual flight rules, and 

flown within direct visual line of sight of the PIC at all times and never over congested or densely 

populated areas unless specifically authorized by the Air Traffic Organization-issued COA. The 

PIC shall 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. 

Each SUAS shall be operated at an altitude of no more than 400ft AGL, unless specifically 

authorized and operating under the terms of the COA, at speeds less than 87 knots (100 mph) or 

at airspeeds greater than the maximum operating airspeed recommended by the manufacturer. The 

SUAS will not be operated less than 500ft below or less than 2000ft horizontally from a cloud, or 

when visibility is less than 3 statute miles. 

Prior to beginning a flight, the PIC shall clearly establish the limits in latitude, longitude and 

altitude AGL to ensure compliance with the COA under which the SUAS is flown and establish 

the “sterile area” for operations. If at any time, this area is breached by unpredicted obstacles 

(manned aircraft or otherwise), the PIC shall abort the flight. Manned aircraft shall have right of 

way at all times. 

7
In case of a reduced or diminished control link, the SUAS will automatically return to a 

predetermined point within the private or controlled-access property. 

The PIC shall not begin a flight unless there is sufficient available power for the SUAS to 

complete the intended mission and to operate for at least five minutes after that. 

By operating within the limitations and guidelines set forth herein, Volant shall provide an 

equivalent level of safety to operations under the existing regulatory structure. 

8. Petitioners should describe the characteristics of the area of intended operation(s) and 

the associated potential hazards, in accordance with the statutory mandate under Section 

333 regarding proximity to populated areas. These issues can be addressed in the 

petition, an Operations Manual, or similar document. 

9. Petitioners should describe if they intend to operate in the proximity of any airports, in 

accordance with the statutory mandate under Section 333 regarding proximity to 

airports. 

All flight operations will be conducted at least 500ft from all nonparticipating persons, vessels, 

vehicles and structures on private or controlled access property with permission from the property 

owner/controller or authorized representative. In some cases due to mission requirements, the 

SUAS will be operated closer than 500ft to commercial and industrial infrastructure and facilities. 

In these instances, Volant shall have the authorization of the property owner/controller or from an 

authorized representative, and the PIC shall have conducted a safety assessment and determined 

that it does not present an undue hazard. Permission from the property owner/controller or 

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

Accordance with the “Blanket 200 ft COA” guidance that was issued by the FAA in March 2015, 

flight operations will not take place within: 

• five nautical miles from an airport having an operational control tower; or 

• three nautical miles from an airport with a published instrument flight procedure, but not 

an operational tower; or 

• two nautical miles from an airport without a published instrument flight procedure or an 

operational tower; or 

• two nautical miles from a heliport with a published instrument flight procedure 

unless a letter of agreement with that airport’s management is obtained and/or otherwise 

permitted by an Air Traffic Organization-issued COA. 

Foreseen hazards include encroachment of manned aviation operations and non-participants on 

the ground. Both of these hazards are mitigated by choice of location (non-congested areas) and 

strict limits on range (visual line of sight) and altitude established herein. Operation under these 

limits effectively mitigates these risks. 

10. The UAS must be operated within visual line-of-sight (VLOS), in accordance with the 

statutory mandate under Section 333(b)(1). Petitioners should describe how they intend 

to comply with his mandate. 

11. Petitioners should describe any procedures they would implement for conducting a 

preflight safety risk assessment to determine that the UAS is in a condition for safe flight 

(14 CFR § 91.7(b)) and that the planned operation can be completed safely. These 

procedures can be addressed in the petition, an Aircraft Flight Manual, Operations 

8
Manual, or similar document. 

As described above, all SUAS will be operated during daylight hours, in compliance with visual 

flight rules, and flown within direct visual line of sight of the PIC at all times. The PIC shall use 

human vision unaided by any device other than corrective lenses, as specified on the PIC’s FAAissued airman medical certificate or U.S. driver’s license. 

In advance of every flight operation, the Pilot In Command (PIC) will thoroughly inspect the 

SUAS to ensure it is safe to fly as described in Appendices 1 - 9 and 11. Furthermore, the PIC 

will conduct a pre-flight checklist as described in Appendices 1 - 3, 10 and 12, and ensure the 

planned operation can be completed safely with sufficient battery reserves (including wind and 

terrain limitations). With both inspections completed and passed, the SUAS shall be deemed safe 

to fly. 

12. If petitioners intend to conduct operations which have existing requirements to notify 

Flight Standards District Offices (FSDOs) prior to operations – such as motion picture 

and television filming, or pipeline and powerline patrol – petitioners should describe 

their intended coordination in this regard for their proposed operation(s). 

Volant’s aerial infrastructure inspections, cinematography/videography or agricultural operations 

do not require notification to FSDOs. 

13. The FAA intends to require entities who obtain an exemption under this process to also 

obtain a Certificate of Waiver or Authorization (COA) from the FAA Air Traffic 

Organization prior to conducting operation(s) in the NAS. The COA application is 

available here.

As stated previously, Volant shall obtain an Air Traffic Organization-issued COA prior to 

conducting any operations under this requested grant of exemption. Volant seeks primarily to 

operate under the “Blanket 200ft COA” guidance offered by the FAA in March, 2015 and 

respectfully requests that COA be issued concurrently with these exemptions. For operations not 

conforming to the “Blanket 200ft COA” guidance, Volant will seek separate and additional COAs 

to operate its SUAS.

Section 5: Requested Exemptions

14 C.F.R Part Summary of Regulation Proposed Action

21, Subpart H Airworthiness Certification In consideration of the size, 

weight, speed, and limited 

operating area associated with 

the aircraft and its operation, 

the FAA has previously held 

that this aircraft meets the 

conditions of Section 333, 

therefore, requested relief 

from 14 CFR part 21, and any 

associated noise certification 

and testing requirements of 

part 36, is not necessary.

9
45.23(b) Display of Marks Volant SUAS shall be 

identified by serial number 

and N-number, in markings as 

large as practical given the 

small size of the aircraft. 

However, the 2 inch minimum 

set forth in this rule is 

impractical, therefore relief is 

requested.

61.23(a)

61.101(e)(4&5)

61 113(a) & (b)

61.133(b)

61.315(a)

Certification: Pilots, Light 

Instructors and Ground 

Instructors

In previous petitions for 

exemption, the FAA has held 

that a PIC of an SUAS 

holding at least a Sport Pilot 

certificate and a U.S. Driver’s 

License, or greater medical 

certification, would not 

adversely affect safe 

operations within the NAS or 

present a hazard to people or 

structures on the ground. 

Relief, subject to the 

limitations provided in this 

document, is requested.

91.7(a) Civil Aircraft Airworthiness PICs operating on behalf of 

Volant shall perform preflight 

inspections and ensure 

airworthiness prior to flight as 

described in this document, 

manuals and appropriate 

appendices. Relief from this 

requirement is not necessary.

91.9(b)(2) & (c) Civil aircraft flight manual, 

marking, and placard 

requirements

Volant shall provide a current 

SUAS Flight Manual, and 

operational instruction 

material at the location of the 

PIC and/or Ground Station. 

The FAA has previously 

determined that, given this, 

relief from this requirement is 

not necessary.

91.103 Preflight Action Volant will perform. Relief is 

not necessary.

91.105 Flight Crewmembers at 

Stations

No human will be aboard the 

SUAS operated by Volant, 

however, the FAA has held in 

previous petitions that relief is 

not necessary.

14 C.F.R Part Summary of Regulation Proposed Action

10
91.109(a) Flight Instruction Volant will conduct flight 

training in accordance with 

the guidance and limitations 

offered in this document, as 

well as the Operations & 

Flight Manuals attached as 

appendices to this document. 

The FAA has held in previous 

petitions that relief is not 

necessary.

91.119 Minimum Safe Altitudes Request relief within 

limitations and restrictions 

proposed herein, specifically 

in Section 4.

91.121 Altimeter Settings Each of the SUAS Volant 

proposes to operate measure 

altitude with both barometric 

pressure sensors and GPS. 

Prior to each flight, the 

barometric altimeter will be 

set to 0ft AGL instead of the 

setting of the nearest reporting 

station. Volant holds that by 

counting altitude in AGL, 

zeroed at the point of 

departure, will ensure 

conformance to the COA 

restrictions under which the 

SUAS is operating. Given the 

low operating altitudes of 

system and operating within 

the proposed restrictions, 

relief is requested.

91.151 Fuel Requirements in VFR 

Conditions

As described in this 

document, the SUAS Volant 

proposes to operate have total 

endurance of between 20 and 

60 minutes. Volant will ensure 

missions are conducted with 

sufficient reserve to operate 

for at least five minutes after 

the intended mission is 

complete. The short flight 

time makes the reserves 

specified in 91.151 

impractical and therefore 

relief is requested. 

14 C.F.R Part Summary of Regulation Proposed Action

11
Section 6: Public Interest & Equivalent Level of Safety

Though this is addressed in pieces of this petition, a more complete answer is provided in this 

section. 

Volant proposes certain 14 CFR exemptions to allow commercial operation of its small unmanned 

aircraft systems for the purposes of aerial photography, cinematography, videography, mapping, 

crop surveying, aerial inspections, data collection, security monitoring, public safety, first 

responder and emergency response, SUAS training, flight demonstrations, and other flight 

operations, so long as such operations are conducted within and under the conditions outlined 

herein. 

Traditional agricultural operations such as crop inspections and data collections under the current 

regulatory structure include the use of manned aircraft, which are expensive, inefficient and 

cannot be safely operated in close proximity to the ground. By using Drones to complete these 

missions the public interest is served by increasing safety to pilots, passengers and nonparticipants on the ground. 

91.203 Certifications Required Volant will place these 

documents at the location of 

the ground station and/or with 

the PIC. The FAA has 

previously held that this is 

sufficient to provide an 

equivalent level of safety, and 

therefore, relief is requested.

91.405 Maintenance Required Relief is requested within the 

limitations and conditions set 

forth in Section 2.2 of this 

document.

91.407 Operation After Maintenance Relief is requested within the 

limitations and conditions set 

forth in Section 2.2 of this 

document.

91.409 Inspections Relief is requested within the 

limitations and conditions set 

forth in Section 2.2 of this 

document.

91.417 Maintenance Records Relief is requested within the 

limitations and conditions set 

forth in Section 2.2 of this 

document.

14 C.F.R Part Summary of Regulation Proposed Action

12
Traditional industrial infrastructure inspection operations under the current regulatory structure 

are often performed 1) from the ground, where high detail is impossible 2) by a climber at great 

risk to his or her personal safety, or 3) by a manned aircraft where flying close to elevated 

infrastructure is extremely dangerous, and not permitted by 14 CFR 91.119.

Public safety, security (such as facility parameter monitoring), first responder, natural resource 

management and emergency response/emergency management flight operations under the current 

regulatory structure include the use of manned aircraft, which are expensive, inefficient and can 

pose significant risks to the aircrew, property and structures and persons on the ground when 

being operated in close proximity to the ground. By using drones to complete these missions the 

public interest is served by increasing safety to pilots, passengers and nonparticipants on the 

ground while increasing availability and responsiveness due to the lower cost of equipment and 

operations.

Grant of exemption, with the conditions and limitations set forth herein, to Volant will provide for 

at least an equivalent or better level of safety, reduce risk to life and property, thereby serving the 

public interest. 

Section 7: Summary of Exemption Request for the Federal Register

In accordance with 14 CFR 11.81 and Section 333 of the FAA Modernization and Reform Act of 

2012, P.L. 112-95, Volant seeks exemption from the requirements of 14 C.F.R §§Part 21, Subpart 

H, 45.23(b), 61.23(a), 61.101(e)(4&5), 61.113(a) & (b), 61.133(b), 61.315(a), 91.7(a), 91.9(b)(2) 

& (c ), 91.103, 91.105, 91.109(a), 91.119, 91.121, 91.151, 91.203, 91.405, 91.407, 91.409 and 

91.417 to operate small unmanned vehicles weighing 55lbs or less for commercial purposes. 

Approval of these exemptions will allow Volant to conduct safe, commercial operation of small 

unmanned aircraft for the purposes of aerial photography, cinematography, videography, 

mapping, crop surveying, aerial inspections, data collection, security monitoring, public safety, 

first responder and emergency response, SUAS training, flight demonstrations, and other flight 

operations. 

Section 8: Compliance with 14 CFR 11.81

14 CFR 11.81a – Published on Cover Page. 

14 CFR 11.81b – Please see Section 5. 

14 CFR 11.81c – Please see Sections 2, 3, 4 and 5. 

14 CFR 11.81d – Please see Section 6. 

14 CFR 11.81e – Please see Section 6. 

14 CFR 11.81f – Please see Section 7. 

14 CFR 11.81g – Please see Appendices 1-12. 

14 CFR 11.81h – Not applicable. 

13
List of Appendices 

Appendix 1: DJI Phantom 3 Professional User Manual

Appendix 2: DJI Phantom 2 User Manual 

Appendix 3: DJI Inspire 1 Operations Manual 

Appendix 4: DJI Inspire 1 Maintenance Manual 

Appendix 5: DJI Inspire 1 Safety Guidelines 

Appendix 6: DJI Phantom 3 Safety Guidelines 

Appendix 7: DJI Intelligent Flight Battery Safety Guidelines 

Appendix 8: DJI Phantom Pilot Training Guide

Appendix 9: Sentera Phoenix UAS Pilot Operational Handbook 

To make these documents available for review, they have been sent to 333exemptions@faa.gov 

with the comment tracking number included in the email. Please contact 

les.forsythe@volantuas.com with questions or concerns. Sentera has classified these documents 

to be proprietary information and prefers to keep this confidential. Please do not publish. 

Appendix 10: Sentera Phoenix A1, Phoenix M1, Vireo Pre-flight Checklist

To make these documents available for review, they have been sent to 333exemptions@faa.gov 

with the comment tracking number included in the email. Please contact 

les.forsythe@volantuas.com with questions or concerns. Sentera has classified these documents 

to be proprietary information and prefers to keep this confidential. Please do not publish.

Appendix 11: Lockheed Martin Procerus Technologies (LMPT) Indago User Guide v1.1 

To make these documents available for review, they have been sent to 333exemptions@faa.gov 

with the comment tracking number included in the email. Please contact 

les.forsythe@volantuas.com with questions or concerns. Lockheed Martin has classified these 

documents to be proprietary information and prefers to keep this confidential. Please do not 

publish.

Appendix 12: Lockheed Martin Procerus Technologies (LMPT) Indago Flight Checklist

To make these documents available for review, they have been sent to 333exemptions@faa.gov 

with the comment tracking number included in the email. Please contact 

les.forsythe@volantuas.com with questions or concerns. Lockheed Martin has classified these 

documents to be proprietary information and prefers to keep this confidential. Please do not 

publish.

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