Petition for Exemption / 

Rulemaking to the FAA

Commercial visual line-of-sight sUAS Operations

Prepared by Robert R. Murrell

CIO Aerialspecs, Inc.

48675 Jefferson Drive

Macomb, MI 48044

+1 (248) 845-8365

info@aerialspecs.com
Petition for Exemption/Rulemaking to the FAA

Commercial visual line-of-sight sUAS operations

TABLE OF CONTENTS

Summary .............................................................................................................................................................. 1

Exemption............................................................................................................................................................. 1

Scope............................................................................................................................................................... 1

Specific Exemptions......................................................................................................................................... 1

14 CFR Part 61: Certification: Pilots, Flight Instructors, and Ground Instructors .......................................... 1

14 CFR §61.113 (a) & (b): Private pilot privileges and limitations: Pilot in command ................................... 1

14 CFR Part 21, Subpart H: Airworthiness Certificates 14 CFR §91.203 (a) (1) ............................................. 2

14 CFR §45.23 (b): Marking of the Aircraft.................................................................................................. 2

14 CFR §91.7(a): Civil aircraft airworthiness................................................................................................ 2

14 CFR §91.9 (b) (2): Civil Aircraft Flight Manual in the Aircraft................................................................... 2

14 CFR §91.103(b)(2): Preflight action ........................................................................................................ 3

14 CFR §91.105: Flight Crewmembers at Stations....................................................................................... 3

14 CFR §91.109: Flight instruction .............................................................................................................. 3

14 CFR §91.119: Minimum safe altitudes.................................................................................................... 4

14 CFR §91.121: Altimeter Settings............................................................................................................. 4

14 CFR §91.151: Fuel requirements for flight in VFR conditions.................................................................. 4

14 CFR §91.203 (a) & (b): Carrying Civil Aircraft Certification and Registration............................................ 5

14 CFR §91.405 (a); 407 (a) (1); 409 (a) (2); 417(a) & (b): Maintenance Inspections.................................... 5

Public Safety ......................................................................................................................................................... 6

Safety of our Employees .................................................................................................................................. 7

Safety of our Customers................................................................................................................................... 7

Operational Roles ................................................................................................................................................. 7

Chief Equipment Operator............................................................................................................................... 7

Equipment Operator........................................................................................................................................ 8

Spotter............................................................................................................................................................. 8

Flight Operations Certification .............................................................................................................................. 8

Flight Certification ........................................................................................................................................... 8

Equipment Operator and Spotter Flight Time Requirements ...................................................................... 9

Chief Equipment Operator Flight Time Requirements............................................................................... 10

TSA Equivalent Background Check ............................................................................................................ 10

Medical Examination ................................................................................................................................ 10

Basic First Aid Certification ....................................................................................................................... 10
Petition for Exemption/Rulemaking to the FAA

Commercial visual line-of-sight sUAS operations

Operating Standards........................................................................................................................................... 10

Fly-off Procedures.......................................................................................................................................... 12

Flight Standards District Offices Notification.................................................................................................. 13

Equipment Specification ................................................................................................................................ 13

Maintenance and Repair................................................................................................................................ 14

Specific Use Cases............................................................................................................................................... 15

Wind Turbine Construction and Inspection .................................................................................................... 15

Operational Area ...................................................................................................................................... 15

Additional Safety Measures...................................................................................................................... 17

Payload..................................................................................................................................................... 17

Electric Generation, Transmission, Sub Transmission, and Distribution Facilities Inspection .......................... 18

Operational Area ...................................................................................................................................... 18

Additional Safety Measures...................................................................................................................... 19

Payload..................................................................................................................................................... 20

Building, Bridge, Structure or Span Inspection ............................................................................................... 20

Operational Area ...................................................................................................................................... 20

Additional Safety Measures...................................................................................................................... 22

Payload..................................................................................................................................................... 22

Agriculture Inspection.................................................................................................................................... 22

Operational Area ...................................................................................................................................... 23

Additional Safety Measures...................................................................................................................... 23

Payload..................................................................................................................................................... 23

Industrial / Mining Environmental Inspection ................................................................................................ 23

Operational Area ...................................................................................................................................... 23

Additional Safety Measures...................................................................................................................... 24

Payload..................................................................................................................................................... 24

Municipal Police, Fire, and Search and Rescue ............................................................................................... 25

Operational Area ...................................................................................................................................... 25

Additional Safety Measures...................................................................................................................... 26

Payload..................................................................................................................................................... 27

Appendix............................................................................................................................................................. 28

A. General Flight Process ............................................................................................................................... 28

B. Fly-off Process............................................................................................................................................ 29

Glossary of Terms ............................................................................................................................................... 30
Petition for Exemption/Rulemaking to the FAA

Commercial visual line-of-sight sUAS operations

AGL................................................................................................................................................................ 30

AIRMET.......................................................................................................................................................... 30

ATC................................................................................................................................................................ 30

C2 .................................................................................................................................................................. 30

EM................................................................................................................................................................. 30

Fly-Off............................................................................................................................................................ 30

FSDO.............................................................................................................................................................. 30

GPS................................................................................................................................................................ 30

IMU ............................................................................................................................................................... 30

IR ................................................................................................................................................................... 31

NIR................................................................................................................................................................. 31

NTSB.............................................................................................................................................................. 31

SFC................................................................................................................................................................. 31

SIGMET.......................................................................................................................................................... 31

sUAS .............................................................................................................................................................. 31

TFR ................................................................................................................................................................ 31

UAV ............................................................................................................................................................... 31

UV.................................................................................................................................................................. 31

VFR ................................................................................................................................................................ 31

References.......................................................................................................................................................... 32
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Copyright © Aerialspecs, Inc, 2015. All Rights Reserved

SUMMARY

Pursuant to 14 CFR Part 11, the following summary is provided by Aerialspecs, Inc. for publication in the Federal 

Register:

Aerialspecs, Inc. is seeking exemption from the following regulations to operate small Unmanned Aerial Systems 

for the purposes of remote visual line-of-sight videography, data collection, sensing, and visual inspection:

 14 CFR PART 61: Certification: Pilots, Flight Instructors, and Ground Instructors 

 14 CFR §61.113 (a) & (b): Private pilot privileges and limitations: Pilot in Command

 14 CFR Part 21, Subpart H: Airworthiness Certificates 14 CFR §91.203 (a) (1)

 14 CFR §45.23 (b). Marking of the Aircraft

 14 CFR §91.7(a): Civil Aircraft Airworthiness

 14 CFR §91.9 (b) (2): Civil Aircraft Flight Manual in the Aircraft

 14 CFR §91.103 (b)(2): Preflight Action 

 14 CFR §91.105: Flight Crewmembers at Stations

 14 CFR §91.109: Flight Instruction

 14 CFR §91.119: Minimum safe altitudes

 14 CFR §91.121: Altimeter Settings

 14 CFR §91.151: Fuel requirements for flight in VFR conditions

 14 CFR §91.203 (a) & (b): Carrying Civil Aircraft Certification and Registration

 14 CFR §91.405 (a); 407 (a) (1); 409 (a) (2); 417(a) & (b): Maintenance Inspections

It is the position of Aerialspecs, Inc. that a new license class be created for the commercial visual line-of-sight of 

sUAS. Many industries needlessly place the lives of employees in harm’s way every day to keep the general public 

safe and deliver products to their customers. Requiring reasonable everyday workers in hazardous jobs to obtain a 

Pilot’s license is too costly and time consuming. The rigor and cost associated to achieving a private pilots 

certificate is typically $10,000 USD and 50 - 60 hours of an individual’s time. This far exceeds the training necessary

to achieve a CDL with a Hazmat endorsement required to transport dangerous cargo over land.

Aerialspecs, Inc. believes it has created training, certifications, operational standards, and equipment specifications 

that represent reasonable guidelines for operation of sUAS comparable to risk sUAS poses and similar to CDL, 

forklift, or other hazardous equipment employees are entrusted to operate every day. Aerialspecs, Inc. is willing to 

partner with the FAA to create a new license class leveraging this exemption as its springboard. Until then we 

believe or training and certification standards, the type of equipment, operating standards, fly-off procedures, and 

clear areas of operation defined herein exceed the standards set forth in FAA Advisory Circular AC 91-57 for hobby 

operations and provide an equivalent level of safety supporting the grant of the exceptions requested herein. This 

satisfies the criteria provided in Section 333 of the Reform Act of 2012 providing adequate justification for these 

exceptions allowing for commercial operations of sUAS within visual line-of-sight by Aerialspecs, Inc.

Aerialspecs, Inc. is committed to the safety of the everyday worker and believes that through our services and this 

exemption we can provide safe, quality operations of sUAS to reduce the risk to employees, improve our 

customers OSHA ratings, and protect the public.

Douglas Sigler

CEO and Owner - Aerialspecs, Inc.

+1 (586) 745-4503

info@aerialspecs.com

Robert R. Murrell

CIO and Owner - Aerialspecs, Inc.

+1 (248) 845-8365

info@aerialspecs.com
Petition for Exemption/Rulemaking to the FAA

Commercial visual line-of-sight sUAS operations

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Copyright © Aerialspecs, Inc, 2015. All Rights Reserved

EXEMPTION

SCOPE

The scope of this exemption includes Aerialspecs, Inc. employees, affiliates, partners, vendors, or any 

other person or entity operating in a flight capacity on behalf of Aerialspecs, Inc. for the purpose of 

commercial visual line-of-sight sUAS operations leveraging both manual command and control, and auto 

piloted flight.

SPECIFIC EXEMPTIONS

14 CFR PART 61: CERTIFICATION: PILOTS, FLIGHT INSTRUCTORS, AND GROUND INSTRUCTORS

The regulations set forth in 14 CFR Part 61 require a pilot certificate and medical certificate for anyone 

operating as a required pilot of a civil aircraft.

Aerialspecs, Inc. is seeking exemption from 14 CFR Part 61 on the grounds that the FAA does not require a 

pilot certificate for recreational use of aerial vehicles with the same configurations hereunder today as 

defined by FAA Advisory Circular AC 91-57, Model Aircraft Operating Standards1. Also, the operation of 

sUAS is far simpler than large scale aircraft, especially with modern flight control and stabilization 

systems, requiring less training and experience to be safe and effective. Finally, there is no evidence to 

support the rigor of a pilot certificate, or lack thereof, makes the operations of sUAS more or less safe.

Aerialspecs, Inc. exceeds the voluntary standards defined in FAA Advisory Circular AC 91-57 as well as 

maintains the equivalent level of safety intended by 14 CFR Part 61 by strictly following the Flight 

Operations Certification and General Operational Guidelines herein. Equipment Operators will have a 

minimum number of total flight hours overall, minimum number of total flight hours per sUAS type, 

minimum number of flight hours per year, knowledge of airspace and restrictions, aviation background 

checks, medical certification, and basic first aid training.

14 CFR §61.113 (A) & (B): PRIVATE PILOT PRIVILEGES AND LIMITATIONS: PILOT IN COMMAND

These regulations limit private pilots to non-commercial operations only. Although Aerialspecs, Inc. is 

seeking exemption from certificates, ratings, and authorizations, it may still leverage licensed pilots to 

operate a sUAS. To not violate the regulations set forth in 14 CFR §61.113 (a) & (b), an exemption is 

required.

Aerialspecs, Inc. is seeking exemption from 14 CFR §61.113 (a) & (b) on the grounds that the level of risk 

associated with the operation of a sUAS compared to commercial operations of a piloted aircraft when 

Part 61 was conceived is so negligible that having a private pilot as the Pilot In Command exceeds the 

present level of safety achieved by 14 CFR §61.113 (a) & (b).

Aerialspecs, Inc. will maintain an equivalent level of safety by operating a sUAS hereunder in specific 

operational areas away from the general public that will not carry passengers or crew, not exceed an 

operational weight of 24.9476 kg (55 lbs.) including payload, and not exceed ground speeds of 25 m/s (56 

mph).
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Commercial visual line-of-sight sUAS operations

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Copyright © Aerialspecs, Inc, 2015. All Rights Reserved

14 CFR PART 21, SUBPART H: AIRWORTHINESS CERTIFICATES 14 CFR §91.203 (A) (1)

This regulation requires that aircraft have a current certificate of airworthiness. It also requires that the 

airworthiness certificate be displayed in the cabin or cockpit entrance so that it is legible to passengers 

and crew.

Aerialspecs, Inc. is seeking exemption from 14 CFR Part 21, Subpart H: Airworthiness Certificates 14 CFR 

§91.203 (a) (1) on the grounds that a sUAS operated hereunder does not carry passengers or crew, will 

not weigh more than 24.9476 kg (55 lbs.) including payload, and will not exceed ground speeds of speeds 

of 25 m/s (56 mph). A sUAS hereunder will fly under strict guidelines in narrow operational areas. This 

combined with the safety measures herein provide a greater degree of safety to the public than 

conventional operations conducted with airworthiness certificates issued under 14 CFR Part 21, Subpart 

H. See Public Safety and General Operational Guidelines for more information. 

The Federal Aviation Act (49 USC §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.

14 CFR §45.23 (B): MARKING OF THE AIRCRAFT

This regulation requires: 

“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 Equipment 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.”

Aerialspecs, Inc. is seeking exemption from 14 CFR § 45.23 (b) on the grounds that sUAS operated 

hereunder do not have a cabin, cockpit or pilot station. Their size makes it impossible to fit the word

“Experimental” in letting no smaller than 2 inches high. To maintain compliance with §45.29 (f), 

Aerialspecs, Inc. will require the word “Experimental” on sUAS fuselages so that the operator, spotter, or 

supporting personnel working with the vehicle will see the identification. 

Precedence has been set by the following exemptions issued by the FAA2: Exemptions Nos. 10700, 10167,

and 10167A.

14 CFR §91.7(A): CIVIL AIRCRAFT AIRWORTHINESS

This regulation requires that no person may operate a civil aircraft unless it is in airworthy condition. 

Aerialspecs, Inc. is seeking exemption from 14 CFR §91.7(a) on the grounds that there will be no 

airworthiness certificate issued for the aircraft. Should this exemption be granted, no FAA regulatory 

standard will exist for determining airworthiness for such vehicles. 

Given the size of the aircraft, the requirements contained in the equipment maintenance manuals, and 

use of safety check lists prior to each flight, an equivalent level of safety will be provided.

14 CFR §91.9 (B) (2): CIVIL AIRCRAFT FLIGHT MANUAL IN THE AIRCRAFT

This regulation requires that an approved Flight Manual, manual materials, markings, and place cards, or 

any combination thereof be placed in the aircraft and available to the pilot.
Petition for Exemption/Rulemaking to the FAA

Commercial visual line-of-sight sUAS operations

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Copyright © Aerialspecs, Inc, 2015. All Rights Reserved

Aerialspecs, Inc. is seeking exemption from 14 CFR §91.9 (b) (2) on the grounds that the sUAS operated 

hereunder have no cockpit and are not large enough to carry a Pilot or the Flight Manual.

The equivalent level of safety will be maintained by keeping the flight manual at the ground control point 

where the Equipment Operator controlling the sUAS or the Observer will have immediate access to it. 

Precedence has been set by the following exemptions issued by the FAA3: Exemption Nos. 8607, 8737, 

8738, 9299, 9299A, 9565, 9565B, 10167, 10167A, 10602, and 10700.

14 CFR §91.103(B)(2): PREFLIGHT ACTION 

This regulation requires the pilot in command to take certain action before a flight, specifically:

“(b) For any flight, runway lengths at airports of intended use, and the following takeoff 

and landing distance information: 

(1) For civil aircraft for which an approved Airplane or Rotorcraft Flight Manual containing 

takeoff and landing distance data is required, the takeoff and landing distance data 

contained therein; and

(2) For civil aircraft other than those specified in paragraph (b)(1) of this section, other 

reliable information appropriate to the aircraft, relating to aircraft performance under 

expected values of airport elevation and runway slope, aircraft gross weight, and wind 

and temperature.”

Aerialspecs, Inc. is seeking exemption from 14 CFR §91.103 on the grounds that there is no FAA approved 

Rotorcraft Flight Manual for the UAV. The Equipment Operator will follow a preflight checklist provided by 

the UAV manufacturer as well as validating UAV performance, battery requirement for the specific flight, 

landing and takeoff distances, area of operations, and weather conditions appropriate for VFR. See 

General Operational Guidelines for more information.

14 CFR §91.105: FLIGHT CREWMEMBERS AT STATIONS

This regulation requires that crewmember be at flight stations, presumably in the aircraft, wearing safety 

belts or harnesses during takeoff, landing, and while en route.

Aerialspecs, Inc. is seeking exemption from 14 CFR §91.105 on the grounds that sUAS operated hereunder 

have no cockpit and are not large enough to carry a Pilot. Aerialspecs, Inc. will provide the equivalent level 

of safety by requiring an Equipment Operator and Spotter for each sUAS in operation and require a 

securing strap between the C2 remote and the Equipment Operator.

14 CFR §91.109: FLIGHT INSTRUCTION

This regulation requires any civil aircraft (except a manned free balloon) to have dual flight controls when 

used for flight instruction.

Aerialspecs, Inc. is seeking exemption from 14 CFR §91.109 on the grounds that sUAS are remotely 

controlled within line-of-sight and by design do not have dual controls. Flight control is accomplished 

through a microcontroller accepting human and/or software input that communicates flight commands 

via radio to the UAV. Aerialspecs, Inc. will provide the equivalent level of safety by the fact that neither 

Equipment Operator nor instructor will be onboard the UAV. It will also follow the General Operational 

Guidelines defined herein where the sUAS will be operated is specific, predefined areas, and the flight 

instruction behaving in the role of Chief Equipment Operator, will be present during instruction and have 

access to the controller.
Petition for Exemption/Rulemaking to the FAA

Commercial visual line-of-sight sUAS operations

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Copyright © Aerialspecs, Inc, 2015. All Rights Reserved

Precedence has been set by the following exemptions issued by the FAA4: Exemption Nos. 5778K & 

9862A.

14 CFR §91.119: MINIMUM SAFE ALTITUDES

This regulation specifies the minimum altitudes of operation under various conditions including restricting 

operations below 152.4 m (500 Ft. AGL) over non-congested areas.

Aerialspecs, Inc. is seeking exemption from 14 CFR §91.119 under special circumstances on the grounds 

that many of the specific use cases defined herein have structures below 152.095 m (499 ft.) AGL and to 

gather relevant information on said structure the UAV must operate well below specified minimums.

Aerialspecs, Inc. will provide the equivalent level of safety by flying in specific areas of operation away 

from the general public. The equipment will not carry any hazardous or explosive cargo, travel no more 

than 25 m/s (56 mph), and not exceed 24.9476 kg (55 lbs.) in operational weight including payload. The 

Equipment Operator and Spotter will also be equipped with aviation radios to communicate with nearby 

traffic. The details of the flight will be publicly publish on the Aerialspecs, Inc. corporate web site 

indicating the location, two dimensional operational area, maximum altitude, start time, and expected 

duration.

14 CFR §91.121: ALTIMETER SETTINGS

This regulation requires each person operating an aircraft to maintain cruising altitude by reference to an 

altimeter that is set:

“(iii) In the case of an aircraft not equipped with a radio, the elevation of the departure 

airport or an appropriate altimeter setting available before departure; “

Aerialspecs, Inc. is seeking exemption from 14 CFR §91.121 on the grounds that some of the aircraft used 

rely strictly on GPS for altitude and those aircraft that have an altimeter will auto calibrate ground level to 

the atmospheric pressure at time of startup.

Aerialspecs, Inc. will provide an equivalent level of safety by including in the preflight checklist verification 

that GPS fix is sufficient to maintain altitude within a reasonable margin of error, that the GPS altitude is 

correct before flight, or in case of barometric altimeter based aircraft, that the altimeter reads 0 m (0 ft.) 

AGL before flight.

14 CFR §91.151: FUEL REQUIREMENTS FOR FLIGHT IN VFR CONDITIONS

This regulation requires:

“(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. 

(b) No person may begin a flight in a rotorcraft 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, to fly after that for at least 20 

minutes.”

Aerialspecs, Inc. is seeking exemption from 14 CFR §91.151 on the grounds that sUAS operated hereunder 

generally have battery limits of approximately 20-60 minutes depending on atmospheric conditions, 
Petition for Exemption/Rulemaking to the FAA

Commercial visual line-of-sight sUAS operations

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Copyright © Aerialspecs, Inc, 2015. All Rights Reserved

make, model, and age of the battery. In some cases this would provide no reserve capability, in others, 

leaving not enough flight time to gather the information required for the visual inspection of the wind 

turbine.

Aerialspecs, Inc. will maintain an equivalent level of safety by flying in specific areas of operation away 

from the general public. The equipment will not carry any hazardous or explosive cargo, travel no more 

than 25 m/s (56 mph), and not exceed 24.9476 kg (55 lbs.) in operational weight including payload. Flight 

operations will cease when battery levels reach 15% of their startup capacity. This restriction will provide 

ample battery life for the UAV to return to its designated landing area.

Precedence has been set by the following exemptions issued by the FAA5: Exemptions Nos. 10673, 2689F, 

5745, 10673, and 10808.

14 CFR §91.203 (A) & (B): CARRYING CIVIL AIRCRAFT CERTIFICATION AND REGISTRATION

This regulation requires in 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.”

Aerialspecs, Inc. is seeking exemption from 14 CFR §91.203 (a) & (b) on the grounds that the sUAS at full 

operations weight will be less than 24.9476 kg (55 lbs.) including payload, has no cockpit, and has no 

room to carry a pilot onboard.

Aerialspecs, Inc. will maintain an equivalent level of safety by keeping these documents at the ground 

control point where the pilot flying the sUAS will have immediate access to them; to the extent they are 

applicable to the sUAS.

Precedence has been set by the following exemptions issued by the FAA6: Exemption Nos. 9565, 9665, 

9789, 9789A, 9797, 9797A, 9816A, and 10700.

14 CFR §91.405 (A); 407 (A) (1); 409 (A) (2); 417(A) & (B): MAINTENANCE INSPECTIONS

These regulations require that each owner or operator: 

“Shall have that aircraft inspected as prescribed in subpart E of this part and shall between 

required inspections, except as provided in paragraph (c) of this section, have 

discrepancies repaired as prescribed in part 43 of this chapter;”

Aerialspecs, Inc. is seeking exemption from 14 CFR §91.405 (a), 407 (a) (1), 409 (a) (2), and 417(a) and (b) 

on the grounds that these regulations and the regulations set forth in Part 43 are intended for aircraft 

with airworthiness certificates and a sUAS hereunder will not be issued an airworthiness certificate.

Aerialspecs, Inc. will maintain an equivalent level of safety by operating a sUAS hereunder in specific 

operational areas away from the general public that will not carry passengers or crew, not exceed an 

operational weight of 24.9476 kg (55 lbs.) including payload, and not exceed ground speeds of 25 m/s (56 

mph). Should a mechanical issue arise the sUAS can immediately land within the operational area.
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Commercial visual line-of-sight sUAS operations

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Copyright © Aerialspecs, Inc, 2015. All Rights Reserved

Aerialspecs, Inc. will also perform routine and scheduled inspections of all sUAS and follow the 

maintenance recommendations of the equipment manufacturer. A log of all maintenance and repair will 

be kept for each sUAS to ensure the highest operational performance. 

Per the Operational Procedures herein, all flights will perform a pre-flight and post-flight checklists which 

will include visual inspection of the equipment to identify anomalies before they become an issue. See 

Maintenance and Repair for more information on the maintenance and repair of sUAS by Aerialspecs, Inc.

PUBLIC SAFETY

Aerialspecs, Inc. will follow these specific safety measures to ensure the safety of our employees and the 

general public:

 A sUAS operated hereunder will remain confined to an operational area.

 No flight operations will occur inside restricted or special use, airspace.

 No flight operations will occur inside Class B, C, or D airspace with the following conditions:

o No flight operations will occur within a 5 nm (9260 m) radius of a Class A airport in Class 

B, C, or D airspace with a floor of SFC.

o Flight operations will be restricted to a maximum altitude of 400 ft. (121.92 m) AGL 

outside the 5 nm (9260 m) radius of a Class A airport in Class B, C, or D airspace with a 

floor of SFC.

Figure 1.1 depicts the area of operations in Class B, C, or D airspace with floor of SFC new a Class 

A airport.

 No UAV will operate or cross over a roadway designated as a highway by the Federal or State 

government the roadway is in with the exception of the specific use case of Municipal Police, 

Fire, and Search and Rescue or specific situations during Bridge Inspection. See Municipal Police, 

Fire, and Search and Rescue and Building, Bridge, Structure, or Span Inspection below for more 

information.

 All operations will be performed by a trained two-man crew: Equipment Operator and Spotter. 

The Equipment Operator will be responsible for piloting the UAV while the Spotter will focus on 

ground and air hazard identification.

 No UAV operated hereunder will exceed an operational Weight 24.9476 kg (55 lbs.) including 

payload.

 No UAV operated hereunder will exceed a ground speed of 25 m/s (56 mph).

 All UAV operated hereunder will be battery operated with no more than 60 minutes of minutes 

of flight time on a single charge.

 All UAV operated hereunder will have “Return to Home” capability to return to a predetermined 

point should the sUAS Equipment Operator lose C2 communications.

 No UAV operated hereunder will carry flammable, explosive or otherwise hazardous material.

For more information on Equipment Operator and Spotter see the Operational Roles below, for more 

information on equipment, see Equipment Specification below. Additional information on Aerialspecs, 

Inc. operating standards is available in Operating Standards and Appendix A. General Flight Process below.
Petition for Exemption/Rulemaking to the FAA

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Copyright © Aerialspecs, Inc, 2015. All Rights Reserved

SAFETY OF OUR EMPLOYEES

Employees with operational roles will be issued and minimally required to wear during operations the 

following personal protection equipment:

 ANSI Z89.1-2009 Type I Class C Helmet with chin strap.

 Safety Glasses.

 Safety Gloves.

 Hard sole steel toe safety boots that cover the ankle.

 ANSI Class 2 Safety Vest.

Addition safety equipment may be required depending on the specific use case or environment. The 

Equipment Operator is accountable for safety equipment beyond the minimum specified above.

During operations the Equipment Operator or Spotter will have immediately available the following safety 

equipment:

 ABC fire extinguisher.

 5 person first aid kit.

SAFETY OF OUR CUSTOMERS

 All nonessential customer personnel we be prohibited from entering the defined operational 

area.

 All essential customer personnel we be required to use the same safety equipment as the 

Equipment Operator and Spotter while inside the operational area.

 All essential customer personnel we be briefed by Aerialspecs, Inc. on the associated health and 

safety hazards of being in close proximity of a sUAS.

OPERATIONAL ROLES

Aerialspecs, Inc. will utilize the following operational roles to provide safe operations of sUAS. All 

operational roles will be required to maintain Flight Operations Certification status as defined below. 

Employees in Equipment Operator or Spotter roles will be used interchangeably.

CHIEF EQUIPMENT OPERATOR

The Chief Equipment Operator is in charge of and accountable for all flight operations hereunder and is 

accountable for the Equipment Operators and Spotters. 

The Chief Equipment Operator will have knowledge of and authorize all sUAS flight operations hereunder 

and will monitor weather, VFR conditions, Restricted, TFR, or SUA airspace, and AIRMET/SIGMET zones. 

The Chief Equipment Operator will manage the operational relationship between Aerialspecs, Inc. and the 

FAA, FDSO, NTSB, State of Michigan, and local municipalities, obtaining permits and permission for 

operations where required. 

The Chief Equipment Operator will have full authority to cancel or abort any flight, any time, for any 

reason. The Chief Equipment Operator will also conduct the daily Mission Briefing for all employees with 

operational roles.
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Copyright © Aerialspecs, Inc, 2015. All Rights Reserved

EQUIPMENT OPERATOR

The Equipment Operator is accountable for the safe operation of the sUAS and is effectively the Pilot-InCommand. The Equipment Operator will have full authority to cancel or abort any flight, any time, for any 

reason.

SPOTTER

The Spotter is responsible for the safe operation of the sUAS. The job of the Spotter is to assist the 

Equipment Operator in “see and avoid,” monitoring the operational area for hazards, and/or incursions by 

unauthorized personnel or the general public on land, sea, or in the air. The Spotter will have full 

authority to cancel or abort any flight, any time, for any reason. A Spotter will maintain the same level of 

proficiency as an Equipment Operator.

FLIGHT OPERATIONS CERTIFICATION

Failure to comply with the terms of this Petition for Exemption, the process and procedures established 

by Aerialspecs, Inc., as well as local, State, and Federal laws may result in the revocation of certification 

for flight and termination from Aerialspecs, Inc.

FLIGHT CERTIFICATION

To be eligible for an operational role an employee must be 21 years of age or older, pass a TSA equivalent 

background check, pass a Third Class medical examination, maintain basic first aid certifications, have a 

valid driver’s license in the State of Michigan, and have not been convicted of a DUI or DWI or have

refused an alcohol or drug test in the 60 working days prior to flight operations certification training.

All operational roles will receive an 8 hour training course one the basics of safe operations of sUAS used 

by Aerialspecs, Inc. This course will include the following:

 Health and safety hazards to employees and the general public.

o Required Personal Protection Equipment.

o Cutting hazards.

o Fall hazards.

o High speed collision hazards.

o Electric shock hazards.

o Fire hazards.

o Safe handling and disposal of batteries.

 Additional hazards to other land, sea, and air traffic.

o Potential issues encountering traffic.

o “See and avoid” tactics.

 Identifying hazards on the job site.

o Obstacle Identification.

o Overhead utility lines. 

o Ropes, cables, and guy wires.

o Areas designated for the public.

o Avian hazards.

 Potential issues during operations, including:
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o Equipment Failure.

o Operational Area incursion.

o RF Interference.

o Fly-offs or un-commanded flight.

o Unexpected changes in weather.

o Fires.

 Aerialspecs, Inc. operating standards.

 General flight procedures.

o Roles and responsibilities.

o SUA checks.

o TFR checks.

o Airspace checks.

o Weather verification.

o Effective pre and post-mission briefings.

o Pre and post-flight checklists.

 Emergency flight procedures.

o Fly-off or un-commanded flight.

o Operational Area incursions.

o Crashes.

o Aborting a flight.

o Communicating with pilots over Aviation Radio.

 Reporting incidents to the FAA.

Upon completion of the training all operational roles will be given a test on the materials. Failure to pass 

the test with an 80% score or better will require the employee to retake the course. All operational roles 

will be required to take this course annually or sooner should major operational changes be required. 

Should major operations changes be required inside the annual period, operational roles may only be 

required to take a bridge course with appropriate testing designed around the changes.

Each operational role must obtain 8 hours of combined flight and equipment training for each type of 

equipment before being certified to operate the equipment.

Aerialspecs, Inc. will keep a record of training, certification, logged operational hours, and equipment 

certified, for each person in an operational role.

EQUIPMENT OPERATOR AND SPOTTER FLIGHT TIME REQUIREMENTS

The equipment operator and spotter must 8 hours of flight time logged checked off by a Chief Equipment 

Operator to obtain a Flight Operation Certification. Once certified an Equipment Operator or Spotter will 

have an 8 hour flight time probation where they cannot be partnered with another Equipment Operator 

or Spotter who is on probation. Those 8 hours of flight will be logged and checked off by the experienced 

Equipment Operator or Spotter not on probation.

To maintain Flight Operations Certification an Equipment Operator or Spotter must log at least 10 hours 

of operational time, either on-the-job or practice, annually, excluding the flight time logged during the 

initial Flight Operations Certification checks.
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CHIEF EQUIPMENT OPERATOR FLIGHT TIME REQUIREMENTS

In addition to the Equipment Operator and Spotter Flight Time Requirements above, A Chief Equipment 

Operator must have at least 20 hours of operational time in the field and no incidents where he or she 

was deem “at fault” in the last 12 calendar months.

TSA EQUIVALENT BACKGROUND CHECK

Aerialspecs, Inc. employees, affiliates, partners, vendors, or any other person or entity operating in a flight 

capacity on behalf of Aerialspecs, Inc. must pass an annual Aviation Background Check pursuant to FAA 

Regulations 14 CFR Parts 121, 125 and 135. Aerialspecs, Inc. will contract UniversalTM 13, to provide

Aviation Background Checks.

MEDICAL EXAMINATION

All roles will be required to maintain annually a Third Class Medical certification from a local Aviation 

Medical Examiner.

BASIC FIRST AID CERTIFICATION

All roles will be required to maintain annual Basic CPR, Basic First Aid, and Basic AED certifications from 

the American Red Cross.

OPERATING STANDARDS

The following are a set of operational standards Aerialspecs, Inc. will use upon approval of the exemption. 

These standards are intended to replicate the level of safety intended during the drafting of many of the 

regulations Aerialspecs, Inc. is seeking exemption for. These standards are not all inclusive and will likely 

change as Aerialspecs, Inc. matures this capability.

 No flight operations will occur inside restricted or special use, airspace.

 No flight operations will occur inside Class B, C, or D airspace with the following conditions:

o No flight operations will occur within a 5 nm (9260 m) radius of a Class A airport in Class 

B, C, or D airspace with a floor of SFC.

o Flight operations will be restricted to a maximum altitude of 400 ft. (121.92 m) AGL 

outside the 5 nm (9260 m) radius of a Class A airport in Class B, C, or D airspace with a 

floor of SFC.

Figure 1.1 depicts the area of operations in Class B, C, or D airspace with floor of SFC new a Class 

A airport.

 No UAV will operate outside visual line-of-sight of the Equipment Operator or Spotter.

 No UAV will operate outside the range of the C2 transceiver of the Equipment Operator.

 No UAV will operate or cross over a roadway designated as a Highway by the Federal or State 

government the roadway is in with the exception of the specific use case of Municipal Police, 

Fire, and Search and Rescue or specific situations during Bridge Inspection. See Municipal Police, 

Fire, and Search and Rescue and Building, Bridge, Structure, or Span Inspection below for more 

information.

 All planned operations will have an on-site survey done by an Equipment Operator or Spotter 

prior to operations.

 No flight operations will occur without the knowledge and permission of a Chief Equipment 

Operator.
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 There will be a daily Mission Briefing conducted by a Chief Equipment Officer evaluating weather,

AIRMET/SIGMET, SUA, TFR, and other factors to determine flights and flight windows for the day.

 A Chief Equipment Operator will monitor all restricted or Special Use Airspace, TFR, and 

AIRMET/SIGMET restrictions taking the appropriate actions with the Equipment Operator.

 All planned flight operations will be made publically available on the Aerialspecs, Inc. corporate 

web site with the exception of Municipal Police operations of extreme circumstance. The 

information published will include:

o The date, time, and duration of the operations.

o The geographical position of the operational area.

o The type of equipment being used.

 There will be an Equipment Operator and Spotter for each UAV during flight operations.

 A Chief Equipment Operator, Equipment Operator, or Spotter may cancel or abort a flight at any 

time for any reason. The Equipment Operator and Spotter have the responsibility to abort the 

flight should the situation arise.

 All flight operations require a Chief Equipment Operator or Equipment Operator, and Spotter 

present per sUAS in operation.

 The Equipment Operator and Spotter will have in their possession the ability to communicate 

with aircraft in the area via Aviation Radio.

 A Mission briefing will be conducted to identify local hazards and plan of action to meet the 

objectives of the flight.

 A designated takeoff and landing point will be identified and clearly marked as a hazard with 

cones, flags, or some other obvious means. This point will also be set as the “return to home” 

point of the UAV.

 A pre-flight check will be conducted per the equipment manufacturer and any standards set 

forth by Aerialspecs, Inc.

 The Equipment Operator and Spotter will remain in constant communication during operations 

via voice or radio. In the event that communications between the Equipment Operator and 

Spotter are lost, flight operations shall cease with a controlled landing of the UAV until 

communications can be established.

 Should unauthorized personnel or a member of the general public enter the operational area, 

either on land, sea, or in the air during sUAS operations, flight operations shall cease with a safe, 

controlled landing of the UAV until the hazard has cleared.

o All other air traffic in or near the operational area will have the right of way and 

appropriate action will be taken by the Equipment Operator to avoid the traffic.

 sUAS operations hereunder will comply with FAA §91.155 Basic VFR weather minimums7for 

daytime operations for Class G airspace and follow typical “see and avoid” standards during 

operations.

 No sUAS will be flown in weather conditions that exceed FAA §91.155 Basic VFR weather 

minimums7for daytime operations for Class G airspace or the operational envelope set forth by 

the equipment manufacture.

 Flight operations will cease with a safe, controlled landing of the UAV at the designated landing 

point when battery onboard the UAV reaches 15% of its capacity.

 The Equipment Operator and Spotter will conduct a Mission Debriefing when flight operations 

have been completed to document and share any learnings during the flight.
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 The Equipment Operator will log the flight when operations have been completed.

For detailed information on the process see Appendix A. General Flight Process below. Figure 1.1 depicts 

the area of operations in Class B, C, or D airspace with floor of SFC neear a Class A airport.

Fig. 1.1 Example area of operations inside Class B, C, or D airspace with a Class A airport. No flight operations are permitted within 5 

nautical miles. Flight operations within the 12 nautical mile Class B airspace SFC to 10,000 ft. (3048 m) AGL will be restricted to 

maximum altitude of 400 ft. (121.92 m) AGL.

FLY-OFF PROCEDURES

In the unlikely event of loss of control or communications with a UAV resulting in un-commanded flight 

outside the operational area where all other attempts to abort the flight have failed, the following 

procedures will be followed:

 The Equipment Operator will immediately contact the ATC responsible for the airspace the 

operations are in to notify them of the hazard. The Equipment Operator will provide ATC with 

the following information:

o Last known position of the UAV.

o The last known situation: altitude AGL, ground speed, and heading.

o The operational weight of the UAV.

o The estimated flight time remaining.

o Any defining characteristics of the UAV to help in locating and identifying the vehicle in 

flight.

 The Equipment Operator will contact the Chief Equipment Operator to log the incident.

 The Equipment Operator will provide periodic updates the ATC responsible for the airspace 

providing information, if telemetry is available, until UAV is recovered or the estimated flight 

time remaining has expired.

 The Equipment Operator will contact the ATC responsible for the airspace once the UAV is 

recovered or the estimated flight time remaining has expired to inform them the hazard no 

longer exists.

 The Equipment Operator will contact the Chief Equipment Operator once the UAV is recovered,

or the estimated flight time remaining has expired, to close the incident.
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 The FSDO will be notified of the incident.

 A safety incident will be logged with Aerialspecs, Inc. with a follow-up investigation in an attempt 

to learn from the incident.

For detailed information on the process see Appendix B, Fly-Off Process below. Similar to the General 

Operating Standards above, these procedures are not all inclusive and will likely change as Aerialspecs, 

Inc. matures this capability.

FLIGHT STANDARDS DISTRICT OFFICES NOTIFICATION

Aerialspecs, Inc. will report weekly to the FSDO the planned flights for the coming business week in 

electronic document format. This document will include the following information:

 Date, time, and duration of the mission.

 Location of the operations.

 Operational area.

 Nature or objective of the mission.

 Planned equipment to be used.

 How to contact the Equipment Operator and Spotter for the mission.

Aerialspecs, Inc. will also create a special webpage on its corporate website specifically for the FSDO 

containing the information above and allowing for additional comments or request. Ad-hoc or emergency 

services will be reported to the FSDO within one business week. Any fly-off, aerial operational area 

incursion, or crash will be reported to the FSDO in accordance to current guidelines.

The company is currently focusing on business operations in the State of Michigan. The Michigan FSDO 

locations are:

East Michigan

8800 Beck Road-Eastside, Belleville, Michigan, 48111

Phone: (734) 487-7222 

Fax: (734) 487-7221

Grand Rapids

3196 Kraft Avenue Southeast, Grand Rapids, Michigan, 49512

Phone: (616) 954-6657

Fax: (616) 940-3140

Aerialspecs, Inc. will establish a relationship with the FSDO East Michigan and Grand Rapids offices 

following the approval of this Petition for Exemption.

EQUIPMENT SPECIFICATION

Aerialspecs, Inc. will limit operations of a UAV hereunder to light weight, battery operated configuration 

with following minimum specifications: 

 Fixed wing or multi-rotor craft

 Maximum operational Weight 24.9476 kg (55 lbs.) including payload.

 Maximum ground speeds of 25 m/s (56 mph).

 Battery operated with no more than 60 minutes of minutes of flight time on a single charge.

 “Return to Home” capability.
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 A flight controller leveraging any combination of the following: GPS, IMU, altimeter, computer 

vision, magnetic compass, or ultrasonic ranging and stabilization.

 Remotely operated in the public 2.4 GHz, 5.8 GHz, or 900 MHz FCC Part 15 bands as well as nonC2 information from the cellular bands in the GSM, CDMA, and LTE spectrums depending on 

carrier or service availability.

 External GPS tracker with cellular transmitter in the GSM, CDMA, and LTE spectrums, depending 

on carrier or service availability, to send periodic location updates.

MAINTENANCE AND REPAIR

Aerialspecs, Inc. will keep a maintenance log of all sUAS operated hereunder and make available this log 

to the FAA or NTSB upon written request. This log will include:

 The uniquely identifiable sUAS requiring maintenance or repair.

 The date and time of the maintenance or repair.

 The nature of the maintenance or repair.

 The motivation for the maintenance or repair.

o Equipment Failure.

o Crash.

o Manufacturer recall or request.

o Chief Equipment Operator, Equipment Operator, or Spotter service request.

o Mandate by a regulating body at the Federal, state, or local level.

 The company, organization, and/or individual who performed the maintenance or repair.

 The actions taken to validate the maintenance or repair was complete and successful and the 

equipment is in operational order as defined by the equipment manufacturer.

Aerialspecs, Inc. will minimally follow the maintenance and repair recommendations set forth by the sUAS 

equipment manufacturer.
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SPECIFIC USE CASES 

Below are the specific use cases Aerialspecs, Inc. is intending to operate under. Each use case describes 

how the sUAS will be used as well as the operational area, and any additional safety measures unique to 

the use case. In the event that a specific use cases operational area conflicts with the constraints defined 

in the Operating Standards herein, those constraints defined in the Operating Standards will take 

precedence.

In the event the size of an operational area exceeds the range constraints defined in the Operational 

Standards herein the mission will be broken up into multiple sorties.

WIND TURBINE CONSTRUCTION AND INSPECTION

Using sensors, video and still image surveillance, a sUAS will be used to visually inspect the easements, 

tower, nacelle, blades, and hub in multiple EM spectrums for the purposes of routine inspection, damage 

verification, restoration planning, 3D site mapping, and flood and drainage monitoring of easements on 

privately owned farms.

Aerialspecs, Inc. will also experiment with probes that can take measurements on engineering points on 

wind turbine blades. These measurements will typically be impedance measurement to validate that

blade lightning arrester systems are in good operating condition.

Prior to turbine construction a sUAS will be used to fly the complete blade sweeping area of a planned 

turbine. Leveraging an attached strobe light, aerial and ground video, point clouds, and computer 

simulation, Aerialspecs, Inc. can ensure the visibility of a wind turbine to the property owners before 

committing to an agreement with the operator.

OPERATIONAL AREA

For inspection of an existing turbine the UAV will operate within a 600 ft. (182.88 m) horizontal radius of 

the wind turbine center with a maximum altitude of 400 ft. (1221.92 m) AGL. If the wind turbine is over 

400 ft. (121.92 m) AGL, then the maximum altitude will be no more than 50 ft. (15.24 m) above the tip of 

the airfoil fully extended above the nacelle. In the State of Michigan, that is typically no more than 550 ft. 

(167.64 m) AGL as the majority of wind turbines are no more than 499 ft. (152.1 m) AGL. The UAV will also 

operate over the easements designated as access to the wind turbine. In such a case the UAV will not fly 

more 50 ft. (15.24 m) on either side from the center line of the easement and no more than 100 ft. (30.48

m) AGL in height. Figure 2.1 depicts the operational area for a wind turbine inspection.
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Fig. 2.1 Operational area for wind turbine inspection.

During turbine construction planning, the operational area will be limited to the property it is planned to 

reside on and no more than 400 ft. (121.92 m) AGL. Figure 2.2 depicts the operational area for a proposed 

wind turbine.

Fig. 2.2 Operational area for wind turbine construction planning.

In the case of validating the visibility of turbine prior to construction the UAV will operate within a 600 ft. 

(182.88 m) horizontal radius of the wind turbine center with a maximum altitude of 400 ft. (1221.92 m) 

AGL. If the wind turbine is over 400 ft. (121.92 m) AGL, then the maximum altitude will be no more than 

50 ft. (15.24 m) above the tip of the airfoil fully extended above the nacelle. In the State of Michigan, that 

is typically no more than 550 ft. (167.64 m) AGL as the majority of wind turbines are no more than 499 ft. 

(152.1 m) AGL in height. Figure 2.3 depicts the operational area for validating the visibility of a wind 

turbine.
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Fig. 2.3 Operational area for wind turbine visibility validation.

ADDITIONAL SAFETY MEASURES

 The wind turbine must be shut down, in a locked configuration to prevent wing feathering, 

nacelle, or blade rotation, and tagged as “personnel on site” or other relevant protective tagging 

that would prevent the turbine or its operators from starting it up during sUAS operations.

 Under certain circumstances the nature of the fault may prevent the turbine from being 

completely passivated. In those situations operations may commence provided that:

o The hub, blades, or nacelle are damaged in a manner that would likely prevent the 

blades rotation.

o The tower has collapsed.

o The nacelle is directed into the wind and the wings are feathered to minimize rotation.

o The operator has physically secured the turbine on sight.

 No members of the general public will be permitted in the operational area during operations 

with appropriate signage on display. 

PAYLOAD

 Passive video and/or still imaging equipment in various electromagnetic spectrums including IR, 

NIR, visible light, terahertz, and UV.

 Environmental Monitoring Sensors including but not limited to radiological, biological, chemical, 

gas, noise, light, vibration, and range sensors.

 Impedance Measurement Probe

 Other sample probes requiring direct or indirect contact with structure or equipment.

 Strobe light.
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ELECTRIC GENERATION, TRANSMISSION, SUB TRANSMISSION, AND DISTRIBUTION 

FACILITIES INSPECTION

Using sensors, video and still image surveillance a sUAS will be used to inspect transformers, insulators, 

switches, breakers, fuses, lines, enclosures, towers, poles and any other supporting equipment at 

substations and generating facilities.

In addition, sUAS will be used to inspect high voltage transformers, insulators, switches, breakers, fuses, 

lines, enclosures, towers, poles and any other supporting equipment. A sUAS will also be used to generate 

3D maps and validate construction of new equipment.

Using sensors, video and still image surveillance a sUAS will be used to document and provide live video 

feeds to utilities to validate issues, assess damage to transformers, insulators, switches, breakers, fuses, 

lines, enclosures, towers, poles and any other supporting equipment, and generate 3D maps to plan 

repairs after large storms or other incident severely impacting the distribution grid.

OPERATIONAL AREA

The operational area for substations and generation facilities is no more than 100 ft. (30.48 m) 

horizontally from the building or structures property line and a maximum altitude of 400 ft. (121.92 m) 

AGL. If the substation or generating facility has equipment over 400 ft. (121.92 m) AGL then the 

operational area will be a maximum altitude of 50 ft. (15.24 m) above the tallest part of the substation or 

generation facility and 100 ft. (30.48 m) horizontally from the building or structure down to 400 ft. 

(121.92 m) AGL. Below 400 ft. (121.92 m) AGL, the horizontal operational area will then extend to 100 ft. 

(30.48 m) from the building or structures property line. Figure 3.1 depicts the operational area for a 

substation or generation facility.

Fig. 3.1 Operational area for transmission and sub transmission Towers.

The operational area for transmission, sub transmission, and tie lines will be 100 ft. (30.48 m) from the 

utility easement and a maximum altitude of 400 ft. (1221.92 m) AGL. 
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Fig. 3.2 Operational area for transmission and sub transmission Towers.

For distribution assets, the operational area will be localized to job sites or incident areas with due 

diligence of focusing on the utility easement defined with a maximum altitude of 400 ft. (121.92 m) AGL.

Figure 3.3 depicts the operational area of operations on the distribution grid.

Fig. 3.3 Operational area for the distribution grid. In most cases on residential property.

ADDITIONAL SAFETY MEASURES

 sUAS will be tested at a utility training facilities to validate safe operations near energized 

equipment.

 A representative will be present during any utility operations inside the property of a substation 

or generation facility.

 Employees will be trained in the health and safety hazards of electrical equipment and power 

lines.
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PAYLOAD

 Passive video and/or still imaging equipment in various electromagnetic spectrums including IR, 

NIR, visible light, terahertz, and UV.

 Environmental Monitoring Sensors including but not limited to radiological, biological, chemical, 

gas, noise, light, vibration, and range sensors.

BUILDING, BRIDGE, STRUCTURE OR SPAN INSPECTION

Using video and still image surveillance, a sUAS will be used to visually inspect commercial, industrial, or 

residential buildings, church spires, bridges, structures, or spans and their supporting equipment for 

routine inspection, damage assessment, 3D site mapping, or construction or repair verification. This 

inspection may include, but not limited to, piping, ductwork, conduit, cabling, expansion joints, smoke 

stacks or chimneys, storage containers, boilers, pressure vessels, and other equipment for industrial 

purposes may be inspected as well. In the case of smoke stacks or chimneys, a UAV may be used to mount 

and retrieve inspection rigs for internal inspection.

A UAV equipped with a rudimentary de-nesting rod may be used on industrial equipment that requires 

the area to be free of debris such as pressure relief values, inspection ports, intake or exhaust ports, or 

transceiver equipment.

OPERATIONAL AREA

In the case of buildings or structure the operational area is no more than 100 ft. (30.48 m) horizontally 

from the building or structures property line and a maximum altitude of 400 ft. (121.92 m) AGL. If the 

building or structure is over 400 ft. (121.92 m) AGL then the operational area will be a maximum altitude 

of 50 ft. (15.24 m) above the tallest part of the building or structure and 100 ft. (30.48 m) horizontally 

from the building or structure down to 400 ft. (121.92 m) AGL. Below 400 ft. (121.92 m) AGL, the 

horizontal operational area will then extend to 100 ft. (30.48 m) from the building or structures property 

line. Figure 4.1 depicts the operational area around a large building above 400 ft. (121.92 m) AGL. Figure 

4.2 depicts the operational area around a structure below 400 ft. (121.92 m) AGL.

Fig. 4.1 Operational area around a building taller than 400 ft. (121.92 m) AGL. Note the area around the perimeter of the property 

only extends to 400 ft. (121.92 m) AGL. Also note the North side of the operational area does not extend over the highway.
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Fig. 4.2 Operational area around a structure below 400 ft. (121.92 m) AGL limit.

The operational area for bridges or spans is no more than 100 ft. (30.48 m) horizontally from the span or 

bridges property or outer most structure, where appropriate and a maximum altitude of 400 ft. (121.92 

m) AGL. If the bridge or span is above 400 ft. (121.92 m) AGL then the maximum altitude is 50 ft. (15.24

m) above the tallest part of the bridge or span. The area underneath the bridge to the ground or water 

level will be considered the operational area as well. For bridges carrying vehicle traffic, no UAV will be 

flown over the roadway except around tower sections. Figure 4.3 depicts the operational area around a 

bridge or span.

The operational area around the tower section of a bridge or span when over roadways is no more than 

50 ft. (15.24 m) horizontally from the tower section, a minimum altitude of 50 ft. (15.24 m) above the 

roadway, and a maximum altitude of 400 ft. (121.92 m) AGL. If the tower section of a bridge or span is 

above 400 ft. (121.92 m) AGL, including the 50 ft. (15.24 m) buffer, then the maximum altitude is 50 ft. 

(15.24 m) above the tallest part of the bridge or span.

Fig. 4.3 Operational area around a bridge or span, minus the towers. Note no area over roadway.
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ADDITIONAL SAFETY MEASURES

 No sUAS will operate in an explosive atmosphere environment.

 No bridge, span, or structure that crosses over a roadway designated as a Highway by the Federal 

or State government the roadway is in will be inspected unless the highway has been closed in 

the operational area.

 The EM spectrum of antennas, buildings, bridges, structures, or spans containing transmitting 

equipment will be evaluated for interference of the C2 systems of the sUAS and vice versa.

 Equipment with intake or exhaust ports, or transmitters will be shut down before de-nesting 

operations will occur.

 Equipment tied to smoke stacks or chimneys to be inspected will be shut down before internal 

inspections occur.

 Due to the nature of visibility in major metropolitan areas special handling of heliports will be 

taken. No sUAS operations in a major metropolitan area will occur within 1 statute mile (1.6 km) 

of a heliport without informing the owner of the heliports of the sUAS operations. This 

communication will include:

o Date, time, and duration of the mission.

o Location of the operations.

o Operational area.

o Planned equipment to be used.

o How to contact the Equipment Operator and Spotter for the mission.

 Sidewalks, bike paths, and any other pedestrian pathways inside the operational area will have 

appropriate warning signs, rope, tape, or other signaling methods to cordon off the area.

 If a bridge or span can carry pedestrian traffic, the bridge or span must be closed to pedestrians.

 If a bridge or span is for vehicle traffic the UAV will not be flown over the roadway with the 

exception of the tower sections. It will be flown outside the guardrail, main cables, hangers, or 

underneath the roadway.

 Operations over roadways around bridge or span tower sections will not be conducted if wind 

gusts exceed 20 MPH (8.94 m/s).

PAYLOAD

 Passive video and/or still imaging equipment in various electromagnetic spectrums including IR, 

NIR, visible light, terahertz, and UV.

 Environmental Monitoring Sensors including but not limited to radiological, biological, chemical, 

gas, noise, light, vibration, and range sensors.

 De-Nesting or debris removal probes for removing animal nests or other debris.

 Other sample probes requiring direct or indirect contact with structure or equipment.

AGRICULTURE INSPECTION

Using video and still image surveillance, a sUAS will be used to gather visible, NIR, and IR photos of crops 

to establish crop health for farmers. Aerialspecs, Inc. may also experiment with using other sensors to 

evaluate air, water, and soil conditions of crops.
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OPERATIONAL AREA

UAV operations will be limited to a no more than 100 ft. (30.48 m) horizontally from the property line

with a maximum altitude of 400 ft. (121.92 m) AGL. Figure 5.1 depicts the operational area for agriculture 

inspection.

Fig. 5.1 Operational area for agriculture inspection.

ADDITIONAL SAFETY MEASURES

 No farm equipment will be manned or operational in the operational area.

PAYLOAD

 Passive video and/or still imaging equipment in various electromagnetic spectrums including IR, 

NIR, visible light, terahertz, and UV.

INDUSTRIAL / MINING ENVIRONMENTAL INSPECTION

Using video and still image surveillance, a sUAS will monitor stockpiles, ash piles, run-off, storage ponds, 

erosion, and document the environmental impact of those areas. 3D mapping will be leveraged to 

measure volume and traversal of the environment over time. Aerialspecs, Inc. will experiment with other 

sensors including radiological, biological, and chemical as well.

OPERATIONAL AREA

UAV operations will be limited to a no more than 100 ft. (30.48 m) horizontally from the property line 

with a maximum altitude of 400 ft. (121.92 m) AGL. Figure 6.1 and Figure 6.2 depict operational areas for 

environmental inspection. In the case of a quarry, pit, or hole, AGL will be measure from the base.
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Fig. 6.1 Operational area for environmental monitoring, in this case a stockpile.

Fig. 6.2 Operational area for environmental monitoring, in this case a quarry.

ADDITIONAL SAFETY MEASURES

 No sUAS will operate in an explosive atmosphere environment.

PAYLOAD

 Passive video and/or still imaging equipment in various electromagnetic spectrums including IR, 

NIR, visible light, terahertz, and UV.

 Environmental Monitoring Sensors including but not limited to radiological, biological, chemical, 

gas, noise, light, vibration, and range sensors.

 De-Nesting or debris removal probes for removing animal nests or other debris.

 Other sample probes requiring direct or indirect contact with structure or equipment.
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MUNICIPAL POLICE, FIRE, AND SEARCH AND RESCUE

Using audio, video, and still image surveillance a sUAS will be used to provide live visual, audio, telemetry

information to Police, Fire, Search and Rescue personnel during major incidents such as bomb threats, 

major vehicle accident involving hazardous materials, infrastructure or building collapse, flooding, 

mudslide, landslide, hostage situation, or any other incident that poses an immediate threat to the health, 

lives, or safety of the general public or emergency response personnel. When equipped, the sUAS may 

also be used to provide live audio via directional microphone or active laser listening device where 

allowed by law. Aerialspecs, Inc. will experiment with other sensors including radiological, biological, and 

chemical as well.

A sUAS will be used to generate point clouds for 3D mapping and monitoring of flood zones, rubble piles, 

or measuring spills.

Aerialspecs, Inc. will experiment with using a sUAS to tow a rescue rope or drop flotation devices to 

people during water or ice rescue.

OPERATIONAL AREA

The operational area will be defined by the Incident Commander handling the response. A typical 

operational area for a Police or Fire incident will be any suburban or metropolitan public, commercial,

industrial, or residential property. In the case of buildings or structure the operational area is no more 

than 100 ft. (30.48 m) horizontally from the building or structures property line and a maximum altitude 

of 400 ft. (121.92 m) AGL. If the building or structure is over 400 ft. (121.92 m) AGL, including the 50 ft. 

(15.24 m) buffer, then the operational area will be a maximum altitude of 50 ft. (15.24 m) above the 

tallest part of the building or structure and 100 ft. (30.48 m) horizontally from the building or structure 

down to 400 ft. (121.92 m) AGL. Below 400 ft. (121.92 m) AGL, the horizontal operational area will then 

extend to 100 ft. (30.48 m) from the building or structures property line. For the safety of the Equipment 

Operator and Spotter the horizontal area may be extended to 1000 ft. (304.8 m) from the incident area. 

Figure 7.1 depicts the operational are for a Police or Fire incident. Figure 7.2 depicts the operational area 

for search and rescue.

Fig. 7.1 Operational area for Police and Fire.
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Fig. 7.2 Operational area for search and rescue.

For broader operations such as damage assessment, impact analysis, or search and rescue the operational 

area will be defined by the Incident Commander handling the response with a maximum altitude of 400 ft. 

(121.92 m) AGL.

Over a highway, the operational area will be 1000 ft. (304.8 m) radius around the approximate center of 

the Incident area with a maximum altitude of 400 ft. (121.92 m) AGL. Per the Additional Safety Measures

defined hereunder, a 300 foot (91.44 m) barrier or buffer must be established and the highway must be 

closed.

Fig. 7.3 Operational area over highway. Due to the nature of hazardous or explosive cargo sometimes shipped over highways, an 

sUAS may have to enter anywhere from up to 1000 ft. (304.8 m) away for increased safety to the Equipment Operator and Spotter. 

Note the 300 ft. (91.44) barrier established in the Incident Area depicted in red.

ADDITIONAL SAFETY MEASURES

 No sUAS will operate in an explosive atmosphere environment.

 No operations will occur while any other police, fire, or search and rescue aerial vehicles are 

operating in response to the incident. 
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 The agency handling the response to the incident will designate the Incident Commander on 

scene as the liaison between the agency and the Equipment Operator and Spotter. 

o The Incident Commander will be responsible for obtaining the necessary warrants, 

permits, exemptions, authorizations, or licenses to operate sUAS for the situation.

o The Incident Commander will have the same authority to abort or cancel a flight as the 

Equipment Operator and Spotter.

o The Incident Commander must be in constant communication with the Equipment 

Operator and Spotter via voice or radio during Operations. In the event that 

communications between the Equipment Operator and Incident Commander are lost, 

flight operations shall cease with a controlled landing of the UAV until communications 

can be established.

 The Equipment Operator and Spotter will operate under the guidelines of the National Incident 

Management System as governed by the United States Department of Homeland Security.

 Personal protection equipment appropriate for the situation will be specified by the liaison and 

used by employees at all times during operations. Examples include respirators, flame retardant 

clothing, or ballistics vests.

 Due to the nature of visibility in major metropolitan areas special handling of heliports will be 

taken. No sUAS operations in a major metropolitan area will occur within 1 statute mile (1.6 km) 

of a heliport without informing the owner of the heliports of the sUAS operations. This 

communication will include:

o Date, time, and duration of the mission.

o Location of the operations.

o Operational area.

o Planned equipment to be used.

o How to contact the Equipment Operator and Spotter for the mission.

 A UAV will never be used to restrain, detain, subdue, or physically engage an individual. In the 

case of water or ice rescue, a UAV may be used to tow a lead line to, or drop a flotation device 

near an individual in a manner that minimizes the risk of contact with the individual.

 Every attempt will be made by the Equipment Operator to access the incident area with the UAV 

via easements or public property, avoiding flying over private property except in extreme cases.

 No sUAS operations will occur over any roadway designated a Highway by Federal or State 

Government the roadway is in unless the Highway has been closed at the point of the incident 

and a minimum 300 ft. (91.44 m) safety zone has been established around the incident.

PAYLOAD

 Passive video and/or still imaging equipment in various electromagnetic spectrums including IR, 

NIR, visible light, terahertz, and UV.

 Environmental Monitoring Sensors including but not limited to radiological, biological, chemical, 

gas, noise, light, vibration, and range sensors.

 Active and/or passive listening devices (in accordance with local, State, and Federal laws).

 Rescue Lead lines or life preservers for search and rescue.

 Audio speaker, siren, or bull horn.
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APPENDIX

A. GENERAL FLIGHT PROCESS
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B. FLY-OFF PROCESS
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GLOSSARY OF TERMS

AGL

Above Ground Level: The altitude above ground level for any given location.

AIRMET

AIRman's METeorological Information: An AIRMET is a weather advisory issued by the NOAA that advises 

of weather that maybe hazardous, other than convective activity, to single engine, other light aircraft, and 

Visual Flight Rule (VFR) pilots.

ATC

A service provided by ground-based controllers who direct aircraft on the ground and through controlled 

airspace, and can provide advisory services to aircraft in non-controlled airspace.9

C2

Command and Control: Telemetry used to control the vehicle including manual commands from the 

controller.

EM

Electromagnetic Radiation: radiation consisting of electromagnetic waves, including radio waves, 

infrared, visible light, ultraviolet, x-rays, and gamma rays.15

FLY-OFF

The un-commanded flight of an UAV due to interference or malfunction that typically resulting in loss of 

the vehicle.

FSDO

Flight Standards District Office: pronounced FIZ-doe, is a regional office of the United States Federal 

Aviation Administration.14

GPS

Global Positioning System: A device used to determine geographic position I latitude, longitude and 

altitude above sea level.

IMU

Inertial Measurement Unit: Sometimes referred to as a solid state gyro, an IMU determines position and 

orientation or an object through a technique known as dead reckoning by detecting the gravitational 

force, or G, on a particular axis.
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IR

Infrared: is invisible radiant energy, electromagnetic radiation with longer wavelengths than those of 

visible light, extending from the nominal red edge of the visible spectrum at 700 nanometers (frequency 

430 THz) to 1 mm (300 GHz).10

NIR

Near Infrared: Infrared region of the electromagnetic spectrum (from about 800 nm to 2500 nm).

11

NTSB

National Transportation and Safety Board: The independent Federal Agency Charged with determining 

the probable cause of transportation accidents and promoting transportation safety, and assisting victims 

of transportation accidents and their families.

SFC

Surface or Ground Level.

SIGMET

SIGnificant METeorological Information: A SIGMET is a weather advisory issued by the NOAA that 

contains meteorological information concerning the safety of all aircraft.

SUAS

Small Unmanned Aircraft System: A UAV and all its supporting systems for operations. Usually includes 

the remote controller and ground stations used for communication, imagery, and telemetry.

TFR

Temporary Flight Restriction: The pertinent sections of the FAR (14 CFR Sections 91.137, 91.138, 91.139, 

91.141, 91.143, 91.145, 99.7) describe temporary flight restrictions. A TFR is a geographically-limited, 

short-term, airspace restriction, typically in the United States. Temporary flight restrictions often 

encompass major sporting events, natural disaster areas, air shows, space launches, and Presidential 

movements.8

UAV

Unmanned Aerial Vehicle: An unmanned, remotely operated, aerial vehicle in a fixed wing or multiple 

rotor copter configuration.

UV

Ultraviolet: Ultraviolet (UV) light is electromagnetic radiation with a wavelength from 400 nm to 10 nm, 

shorter than that of visible light but longer than X-rays.12

VFR

Visual Flight Rules: A set of regulations which allow a pilot to operate an aircraft in weather conditions 

generally clear enough to allow the pilot to see where the aircraft is going.
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REFERENCES

1. FAA Advisory Circular AC 91-57, Model Aircraft Operating Standards

http://rgl.faa.gov/Regulatory_and_Guidance_Library/rgAdvisoryCircular.nsf/0/1acfc3f689769a56862569e70077c9cc/$FIL

E/ATTBJMAC/ac91-57.pdf

2. Exemptions relating to 14 CFR §45.23 (b): Marking of the Aircraft

http://aes.faa.gov/Form/Doc.asp?SelExemptID=15968&ExemptNo=10700

http://aes.faa.gov/Form/Doc.asp?SelExemptID=15071&ExemptNo=10167

3. Exemptions relating to 14 CFR §91.9 (b) (2): 

http://aes.faa.gov/Form/Doc.asp?SelExemptID=12862&ExemptNo=8607

http://aes.faa.gov/Form/Doc.asp?SelExemptID=13111&ExemptNo=8737

http://aes.faa.gov/Form/Doc.asp?SelExemptID=13119&ExemptNo=8738

http://aes.faa.gov/AES.NET/GetPDFDocument.aspx?ExemptNo=9299

http://aes.faa.gov/AES.NET/GetPDFDocument.aspx?ExemptNo=9565

http://aes.faa.gov/Form/Doc.asp?SelExemptID=15071&ExemptNo=10167

http://aes.faa.gov/AES.NET/GetPDFDocument.aspx?ExemptNo=10602

http://aes.faa.gov/AES.NET/GetPDFDocument.aspx?ExemptNo=10700

4. Exemptions relating to 14 CFR §91.109: Flight Instruction

http://aes.faa.gov/AES.NET/GetPDFDocument.aspx?ExemptNo=5778K

http://aes.faa.gov/AES.NET/GetPDFDocument.aspx?ExemptNo=9862A

5. Exemptions relating to 14 CFR §91.151: Fuel requirements for flight in VFR conditions

http://aes.faa.gov/AES.NET/GetPDFDocument.aspx?ExemptNo=10673

http://aes.faa.gov/AES.NET/GetPDFDocument.aspx?ExemptNo=2689F

http://aes.faa.gov/AES.NET/GetPDFDocument.aspx?ExemptNo=5745

http://aes.faa.gov/AES.NET/GetPDFDocument.aspx?ExemptNo=10673

http://aes.faa.gov/AES.NET/GetPDFDocument.aspx?ExemptNo=10808

6. Exemptions relating to 14 CFR §91.203 (a) & (b): Carrying Civil Aircraft Certification and 

Registration

http://aes.faa.gov/AES.NET/GetPDFDocument.aspx?ExemptNo=9565

http://aes.faa.gov/AES.NET/GetPDFDocument.aspx?ExemptNo=9665

http://aes.faa.gov/AES.NET/GetPDFDocument.aspx?ExemptNo=9789

http://aes.faa.gov/AES.NET/GetPDFDocument.aspx?ExemptNo=9797

http://aes.faa.gov/AES.NET/GetPDFDocument.aspx?ExemptNo=9816A

http://aes.faa.gov/AES.NET/GetPDFDocument.aspx?ExemptNo=10700

7. FAA Code of Federal Regulations, Part 91 General Operating and Flight Rules, Subpart B - Flight 

Rules, Sec. 91.155 Basic VFR weather minimums: 

http://rgl.faa.gov/Regulatory_and_Guidance_Library/rgFAR.nsf/0/074608a2fa18b48a86256eeb006704ef!OpenDocumen

t

8. TFR Definition

http://en.wikipedia.org/wiki/Federal_Aviation_Regulations#Temporary_flight_restrictions

9. ATC Definition

http://en.wikipedia.org/wiki/Air_traffic_control

10. Infrared Definition

http://en.wikipedia.org/wiki/Infrared

11. Near Infrared Definition

http://en.wikipedia.org/wiki/Near-infrared_spectroscopy

12. Ultraviolet Definition

http://en.wikipedia.org/wiki/Ultraviolet

13. UniversalTM Aviation Background Check

http://www.universalbackground.com/solutions/aviation.asp

14. FSDO Definition

http://en.wikipedia.org/wiki/Flight_Standards_District_Office
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15. EM Definition

http://dictionary.reference.com/browse/electromagnetic+radiation