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UNITED STATES OF AMERICA 

DEPARTMENT OF TRANSPORTATION 

FEDERAL AVIATION ADMINISTRATION

DOCKET MANAGEMENT SYSTEM

1200 NEW JERSEY AVE., SE

WASHINGTON, DC 20590

IN THE MATTER OF THE PETITION FOR EXEMPTION OF: 

Advanced Research and Engineering Integrated Solutions, 

LLC

(AREIS)

FOR AN EXEMPTION SEEKING RELIEF FROM 

THE REQUIREMENTS OF THE FAA REFORM ACT AND 

PART 11 OF THE FEDERAL AVIATION REGULATIONS FROM

TITLE 14 OF THE CODE OF FEDERAL REGULATIONS 

SECTIONS C.F.R. §§ 61.23(a) and (c), 61.101(e)(4) and (5), 61.113(a) & (b), 61.133(a), 61.315(a), 

91.7(a), 91.119(c), 91.121, 91.151(a)(1) and (b), 91.405(a), 91.407(a)(1), 91.409(a)(1) and (2), and 

91.417(a) and (b) of Title 14, Code of Federal Regulations (14 CFR)

CONCERNING COMMERCIAL OPERATION OF UNMANNED AIRCRAFT SYSTEMS 

PURSUANT TO SECTION 333 OF  THE FAA MODERNIZATION 

AND REFORM ACT OF 2012 (PUBLIC LAW 112-95)

Submitted on December 11, 2015

Advanced Research and Engineering Integrated Solutions, LLC (AREIS)

111 Bailey Drive, Ste. 3

Niceville, FL 32578

mark.denney@areisllc.com

areisllc.com
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Table of Contents

GLOSSARY OF ABBREVIATIONS...........................................................................................3

INTRODUCTION AND INTERESTS OF THE PETITIONER..............................................4

The name and address of the Petitioner: .............................................................................................4

Background ...............................................................................................................................................4

Expertise & Experience................................................................................................................................5

Commitment to Safety..................................................................................................................................5

Regulations from which the Exemption Relief is requested........................................................5

Description of Type, Make and Models of UASs Requested: ........................................................6

Commercial (Mission, Operation) Purpose:........................................................................................6

Description of Proposed Operations......................................................................................................7

The Exemption Request .........................................................................................................7

Operator Requirements..................................................................................................................... 10

Aircraft and Equivalent Level of Safety ........................................................................................ 13

Specific Uses Public Benefits ............................................................................................................ 17

Equivalent Level of Safety ................................................................................................................. 18

14 C.F.R. § 91.7(a): Civil aircraft airworthiness..............................................................................19

14 C.F.R. §91.119: Minimum safe altitudes ......................................................................................19

14 C.F.R. §91.121 Altimeter Settings...................................................................................................20

14 C.F.R. § 91.151(a): Fuel Requirements for Flight in VFR Conditions ..............................20

14 C.F.R. §91.405 (a); 91.407 (a) (1); 91.409(a) (2); 91.417(a) & (b): Maintenance 

Inspections.....................................................................................................................................................21

Federal Register Publication............................................................................................. 21

Privacy and National Security........................................................................................... 22

Summary................................................................................................................................... 22

APPENDIX A – UAS SPECIFICATIONS.............................................................................................. 25

APPENDIX B – USAF UAS SAFETY QUESTIONNAIR.................................................................... 33

APPENDIX C – FLIGHT LOG................................................................................................................ 34
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GLOSSARY OF ABBREVIATIONS

AGL Above Ground Level

AOI Area of Interest

ATC Air Traffic Control

ATO Air Traffic Organization

AV Aerial Vehicle

CFR Code of Federal Regulations

COA Certificate of Authorization

FAA Federal Aviation Administration

FAR Federal Aviation Regulation

GCS Ground Control Station

GPS    Global Positioning System

LOL Loss of Link

NAS National Airspace System

NOTAM Notice To Airman

PIC Pilot In Command

Section 333 FAA Modernization and Reform Act of 2012 (FMRA) Section 333

SO Safety Observer

SOP Standard Operating Procedures

UA Unmanned Aircraft

UAS Unmanned Aerial System

UAV Unmanned Aerial Vehicle

VFR Visual Flight Rules

VLOS Visual Line of Site

VMC Visual Meteorological Conditions

VTOL Vertical Take-Off and Landing
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INTRODUCTION AND INTERESTS OF THE PETITIONER

Dear Sir or Madam:

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the 

“Reform Act”) and 14 C.F.R. Part 11, Advanced Research and Engineering Integrated 

Solutions, LLC (AREIS) developer and operator of Unmanned Aerial Systems (UASs) 

equipped to offer on-demand commercial UAS operations for a host of industries 

and applications and to perform the purposes listed below, hereby applies for an 

exemption from the listed Federal Aviation Regulations (FARs) to allow commercial 

operation of its UASs, so long as such operations are conducted within and under 

the conditions outlined herein or as may be established by the FAA in an exemption 

granted under either Section 333 or Section 49 U.S.C. §44701(f) 

As described more fully below, the requested exemption would permit the 

operation of a UAS under controlled conditions in airspace that is 1) limited; 2) 

predetermined; and 3) would provide safety enhancements in the fields in which it 

will operate, which now depend upon conventional aircraft or humans climbing 

high on dangerous structures, walking in insect laden swamps, and working 

adjacent to treacherous infrastructure. Approval of this exemption would thereby 

enhance safety and fulfill the Secretary of Transportation’s (the FAA 

Administrator’s) responsibilities to “... establish requirements for the safe operation 

of such aircraft systems in the national airspace system.” Section 333(c) of the 

Reform Act.

The name and address of the Petitioner:

Petitioner: AREIS 

111 Bailey Drive, Ste. 3

Niceville, FL 32578

Owner: Mark Denney

ph. (850) 974-2160

mark.denney@areisllc.com

Background

The Petitioner, AREIS is under the direction of Mr. Mark Denney. Mr. Denney is a 

highly accomplished, capable, experienced and trusted unmanned systems 

professional with over eighteen years’ experience with unmanned systems design, 

development, integration, testing, training, mission support, and manufacturing.

AREIS is an engineering company primarily supporting the military’s use of 

unmanned systems for the warfighters as well as weapons testing events, and 
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emergency response. AREIS is expanding its unmanned system support capability 

into the commercial and public safety markets. ARIES years of experience in flight 

preparation and safety procedures will be duplicated in our UAS work in the NAS. 

AREIS pushes state-of-the-art in equipment to provide the best sensor data for our 

customer as well as safety for the environments that we fly. AREIS staff of 

engineers/pilots is intimately familiar with all aspects of each UAS and have 

hundreds of flight hours and missions with the above mentioned systems as well as 

a wide variety of UAS systems ranging from micro class to Class II. In addition each 

of our non-licensed pilots have complete the FAA Ground School

AREIS is experienced in aircraft and airspace safety. Each mission that is flown in 

the restricted airspace requires de-confliction with frequency control and the 

airspace control tower. This requires a pre-flight approval processes and mission 

time contact with the control tower. AREIS is always in constant contact with the 

control tower during flights in case of emergency air traffic entering mission 

airspace.

Expertise & Experience

In addition to the years of AREIS staff UAS flight experience AREIS has a group of 

licensed private pilots that will provide the pilot in charge (PIC) role for all drone 

flight operations within the NAS. The pilots are each employed as commercial pilots 

therefore; the pilot in charge will vary based on availability. Each of these pilots will 

have the necessary training on the UAV to perform pre-flight inspections, address 

tower communications, safety, and unexpected events.

Commitment to Safety

As part of its commitment to safety and innovation, AREIS is asking for this 

exemption in part, to reduce the risk of contractors who participate in the proposed 

activities the petitioner requests, including but not limited to damage to agriculture, 

natural habitat, buildings and other structures within the United States. 

Regulations from which the Exemption Relief is requested

14 C.F.R. § 61.23 (a) & (c)

14 C.F.R. § 61.101 (e)(4) and (5)

14 C.F.R. § 61.113 (a) & (b)

14 C.F.R. § 61.133(a)

14 C.F.R. § 61.315(a)

14 C.F.R. § 91.7(a)
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14 C.F. R.§ 91.119(c)

14 C.F.R. § 91.121

14 C.F.R. § 91.151 (a)(1) and B

14 C.F.R. § 91.405 (a)

14 C.F.R. § 91.407 (a) (1)

14 C.F.R. § 91.409 (a) (1) and (2)

14 C.F.R. § 91.417 (a) & (b)

Description of Type, Make and Models of UASs Requested:

The petitioner is seeking an exemption to commercially operate UAVs makes and 

models as follows: 

AREIS MRF-4 (DJI Autopilot), MRF-4 (Pixhawk Autopilot), AREIS MRF-6 (DJI 

Autopilot), AREIS MRF-6 (Pixhawk Autopilot), AREIS Nighthawk (Lockheed Martin 

(Procerus) Kestrel Autopilot), AREIS G2R (Lockheed Martin (Procerus) Kestrel 

Autopilot)

Appendix A is a brief summary of each UAS listed above.

Each separately weighs 55 lbs. or less, with imaging/sensor payloads and applicable 

equipment.

See Appendix B for an example safety questionnaire required to operate the UAS in 

DoD restricted air space. This type of safety questionnaire is required for all UASs

owned and/or operated by AREIS when operated in the DoD restricted airspace. In 

addition AREIS can provide operating procedural manuals for each UAS if requested.

Commercial (Mission, Operation) Purpose: 

This exemption request, once granted would allow the petitioner to operate a 

unmanned aerial vehicle (UAV), unmanned aircraft system (UAS) to collect aerial 

video and provide a live video feed and/or other sensor data to assist with 

situational awareness support for emergency responders and search and rescue

operations under the authority and support of local authority officials, commercial 

bridge inspections, flare stack inspection, utility-power generation system 

inspections and patrolling, aerial inspection, photography and videography of utility 

infrastructure including but not limited to electrical power lines, wind turbines and 

cell towers, pipelines,, precision agriculture with on board sensors, wildlife and 

forestry monitoring and mosquito and insect control, aerial surveying, construction 

site inspection and monitoring, aerial imaging for safety, monitoring and comparing 

work efforts and completion percentages, surface mining, and security of a 

controlled environment for various sites , aerial video and photography for public 
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and private use including television, public events, and cinematography live feed 

and live newsgathering, training to persons individually or belonging to both 

private and public organizations to increase awareness and improve safety for 

current and future UAS operations within the NAS, photography and videography of 

residential and commercial real estate, disaster and catastrophe events. AREIS 

would like to facilitate safe integration of UASs into mainstream USA in the 

following areas.

Description of Proposed Operations

To assist the FAA in its safety assessment of AREIS proposed UAS operations, below 

is a summary of operational limitations and conditions that will ensure an 

equivalent or higher level of safety to operations conducted under current

regulatory guidelines:

1. The UAS will weigh less than 55 pounds.

2. Flights will be operated within line of sight of the PIC and visual observer.

3. Maximum total flight time for each operational flight will be limited to the amount 

of time the UAS can be flown and still maintain a reserve battery power of no less 

than 30%.

4. Flights will be operated at an altitude of no more than 400 feet AGL.

5. Flights will be operated at a lateral distance of least 100 feet from any inhabited

structures, buildings, vehicles, vessels, people not associated with the operation or 

who have not signed a waiver in advance of the operation.

6. Minimum crew for each operation will consist of the UAS PIC (and a Visual

Observer/Camera Operator when appropriate).

7. The UAS PIC will be the petitioner Derick Travis Jack.

8. AREIS will designate a Pilot in Command ("PIC") for each mission.

9. The UAS will operate only within a confined safe and uncongested area.

10. Prior to the operations at a particular location, a site inspection will be 

conducted. On the day of the mission the management person with operational 

control and the PIC will concur on performing the mission after reviewing all safety 

issue compliance.

11. Prior to initiating each mission a briefing will be conducted in regard to the 

planned

The Exemption Request

AREIS proposes the use of the sUAV’s will be for capture of high resolution imagery 

and video, chemical plums data, radiological materials, etc. for commercial 

applications and purposes to a level of quality that allows the Petitioner to use the 

data to identify, record, memorialize events and objects according to the purposes 

noted. 
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The sensor data will be used to identify the condition of events, disasters and 

infrastructure.

 Emergency Response

AREIS has been working with the military in the areas of emergency response 

for fire, search and rescue, active shooter, airplane down, natural disaster, 

infrastructure assessment, etc. It is AERIS desire to take the lessons learned and

introduce/demonstrate the UAS reliability and capabilities in extreme situations. 

The ability to offer real time HD and IR video facilitates placing personnel and 

equipment in the right places and keeping them out of harm’s way. AREIS’s 

mission is to assist governmental agencies safely into the NAS.

 Commercial Energy/Utility Sector

AREIS has been in discussions with energy companies regarding UAS uses and 

would like to demonstrate UAS capabilities for, utility-power generation system 

inspections and patrolling, aerial inspection, pipeline inspection and patrolling,

including but not limited to electrical power lines, wind turbines and cell towers, 

and flare stack inspection.

 Agriculture, Conservation, Environmental

AREIS will introduce and demonstrate to the farming community that the UAS 

can aid in commercial agriculture, land management and conservation efforts by 

assessing crops, mapping flood zones, and more. The UAS can fly pre-configured 

missions via the fully automated ground station, which allows for time-lapse 

photos of fields, crops and known land tracts. It also can accurately recreate the 

same pattern during all seasons, providing invaluable data for land and soil 

management. Using HD video, HD photos, multi-spectral cameras, and IR 

cameras allows for detailed analysis and recording. With photo rendering 

software, 3D maps and topography can be used in conjunction with time-lapse

photos to create highly detailed maps for erosion, flood mapping and other 

critical aspects of land management.

AREIS will also work with the forestry services in introducing and 

demonstrating UAS capabilities for combating brush and forest fires and wildlife 

management. AREIS has successfully demonstrated the usefulness of UASs 

finding and monitoring forest fires on military restricted areas and would like to 

expand that into the national parks.

 Real Estate

AREIS will use UASs in all areas of real estate, including agricultural, vacant land,

commercial, residential and industrial properties, aerial surveying, construction 

site inspection and monitoring, monitoring and comparing work efforts and 

completion percentages. Using a UAS, real estate professionals can create 

promotional videos, photos and unique shots that normal camera aspects cannot 

capture. The remote platform is great for new planning, zoning and large 
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developments. Simple and easy-to-use video and photos allow for multiple

height pictures and elevation views.

 Training

AREIS would like to investigate providing training to persons individually or 

belonging to both private and public organizations to increase awareness and 

improve safety for current and future UAS operations within the NAS. AREIS 

staff has provided hundreds of hours of UAS training to military personnel over 

the years that include pre-flight inspections, mission planning, data gathering, 

data analysis, UAS repair and preventative maintenance.

In all missions the UAS will be operated by AREIS and or contracted operators on 

occasion to capture sensor data for all the applications listed above. Given the small 

size of the UAVs involved, no more than 55 lbs., majority of the speed of operation 

be less than 15 mph and the restricted environment within which they will operate, 

the Petitioner falls squarely within that zone of safety (an equivalent level of safety) 

in which Congress envisioned that the FAA must, by exemption, allow commercial 

operations of UASs to commence immediately.

This exemption application is submitted to fulfill Congress’ express goal in passing

Sections 333(a) through (c) of the Reform Act. This law directs the Secretary of 

Transportation to consider whether certain unmanned aircraft systems may 

operate safely in the national airspace system (NAS) before completion of the 

rulemaking required under Section 332 of the Reform Act. In making this 

determination, the Secretary is required to determine which types of UASs do not 

create a hazard to users of the NAS or the public or pose a threat to national security 

in light of the following:

 The UAS size, weight, speed, and operational capability;

 Operation of the UAS in close proximity to airports and populated areas; and

 Operation of the UAS within visual line of sight of the Operator.

Reform Act § 333 (a). Lastly, if the Secretary determines that such vehicles “may 

operate safely in the national airspace system, the Secretary shall establish 

requirements for the safe operation of such aircraft in the national airspace system.” 

Id. §333(c) (emphasis added).1

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

exemptions. This statutory authority, by its terms, includes exempting civil aircraft, 

 

1 Applicant interprets this provision to place a duty on the Administrator to not only 

process applications for exemptions under section 333, but for the Administrator to 

craft conditions for the safe operation of the UAS, if it should be determined that the 

conditions set forth herein do not fulfill the statutory requirements for approval.
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as the term is defined under §40101 of the Act: The Administrator may grant an 

exemption from a requirement of a regulation prescribed under subsection (a) or 

(b) of this section or any of sections 44702-44716 of this title if the Administrator 

finds the exemption is in the public interest. 49 U.S.C. §44701(f). See also 49 USC 

§44711(a); 49 USC §44704; 14 CFR §91.203(a)(1) This authority to grant 

exemptions reaches such issues as authorization of commercial operation of aircraft 

without an FAA issued pilot’s license.

AREIS in filing this application is requesting that the FAA combine the grant of the 

Section 333 exemption with a standard Certificate of Operation (COA) that will 

allow commercial operations of its AREIS’ sUAV without the necessity of filing for a 

COA for each flight, unless such flight is to be conducted in an area not approved in 

the exemption. Compliance with the conditions agreed to herein and that may be 

imposed by the FAA, as set forth in prior Section 333 exemptions, provide the 

separation needed from other aircraft.

In addition, given that all operations will be conducted below 400 AGL feet and no 

closer than 5 nautical miles of the geographic center of an airport as denoted on a 

current FAA published aeronautical chart, unless a letter of agreement with that 

airport’s management is obtained, AREIS requests that operations over congested or 

densely populated areas be allowed. The new sUAV’s do have GPS geo-fencing, it will 

operate at a very low altitude, within confined areas, at low speed and weighs no 

more than 55 lbs. Such operations will only be under-taken with the approval of the 

land or home owner, as set forth herein, and will comply with the requirements that 

operations be no closer than 400 feet to the adjacent building unless the land owner 

has provided permission, and the Operator has made a safety assessment of the risk 

from such operations. 

Operator Requirements

Given the UAVs proposed by AREIS, Operators should not be required to hold a

private pilot license. AREIS believes that 1) the operator, instead of understanding 

how to operate a passenger carrying aircraft, should have knowledge and 

experience that enables the safe operation of a small, remotely piloted sUAV and 

should understand airspace restrictions and know how to ensure separation from 

other aircraft as well as non-participants and property; 2) the sUAV has built-in 

technical capabilities that limit the potential for unsafe operation and 3) there are 

other security screening mechanisms already in existence that AREIS will utilize to 

ensure the operators are acting consistently with national security interests. 

Given the UAV safety features outlined below, AREIS proposes that its operators

under this Exemption request should not be required to hold a commercial or 

private pilot certification. Instead, Operators should be required to: have 

successfully completed, at a minimum, FAA private pilot ground instruction and
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passed the FAA Private Pilot written examination or FAA-recognized equivalents; 

have completed AREIS’s training program for operation of the UAS.

AREIS notes that 1) the FAA has found that safety factors permitted operation of 

UAV’s by Operators with these qualifications in the case of operations pursuant to 

public COAs when the mandatory operating conditions specified above were 

present; and 2) that the Notice of Proposed Rulemaking entitled Operation and 

Certification of Small Unmanned Aircraft Systems, 80 F.R. 9544 (February 23, 2015) 

(“NPRM”), does not require the operator to hold a private pilot license or a third 

class medical.

AREIS UAV’s have advanced autopilot systems for navigation and control that allow

it to execute very accurate pre-programed flights. Flights are pre-programmed with 

GPS waypoint to establish perimeters beyond which the aircraft will not operate. 

Flights under auto-pilot are not directed by positive manual input, but through preprogrammed flight parameters that are executed by the auto-pilot. In the case of 

unplanned events, the Operator inputs preprogrammed evasive maneuvers from the 

control unit, and the autopilot executes those maneuvers. Pre-programmed 

Operator interventions include: initiation of holding at present position; suspension 

of mission; fly back to launch point; abort mission and land immediately; and 

emergency power cut off and land (flight termination system). Additional 

automated safety functions and safety enhancing features of the AREIS UAV’s may 

include the following:

1) Auto-pilot detection of lost GPS or of insufficient satellites initiates an 

immediate landing, 

2) Low power on the aircraft triggers escalating alarms at GCS at 35% and 10% 

levels. Low power below 10% triggers an immediate landing, 

3) If the auto-pilot detects a lost-link to the ground controller, the UAS will hold 

position at its current location for 5 seconds and if the signal is not restored, 

execute a return to home and land, 

4) Redundant “kill switches” that enable completely shutting the aircraft down 

in flight in the event of a loss of control or un-commanded deviation from the 

flight path, 

5) The aircraft, weighs less than 55 lbs., fully loaded, 

6) The motors are driven by pulse width modulated signals, not analog signals, 

7) The aircraft will operate for the Purposes at no more than 35 mph (while 

imaging) nor above 200 feet above the structure (imaging altitude) or a 

maximum of 400 feet AGL.

See Federal Aviation Administration, Notice N-8900.227, Unmanned Aircraft 

Systems (UAS) Operational Approval, at 20-21 (July 30, 2013); As the FAA has 

determined in Exemptions 11062 thru 11067,11080 and 11110 (the “Exemptions”), 

in comparing the requirements for private pilot knowledge and the knowledge 

required for a commercial pilot, that knowledge associated with a private pilot 
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license, and therefore private pilot ground school, was sufficient to allow private 

pilots to operate UAV’s under those exemptions. 

Based upon that analysis, AREIS believes successful completion of FAA private pilot 

ground school is a suitable predicate to operating the UAV under this exemption.

AREIS proposes that the Operator accumulate required UAV flight training hours 

through the operation of UAV’s rather than flight hours in conventional aircraft. 

Those hours are more relevant to the operations proposed herein than hours gained 

in obtaining a private pilot’s certificate in conventional or rotor aircraft. Those 

aircraft are orders of magnitude heavier than the UAS and carry not only the pilot 

himself, but also passengers and fuel, none of which is carried in the UAS. These 

conventional aircraft fly over all sorts of airspace without the permission or 

knowledge of the landowner. 

A handheld radio controller controls the UAV and the vehicle is operated within the 

line of sight. The requirements of Part 61.127 (commercial flight proficiency) and 

§61.107 (private flight proficiency), to the extent they are relevant to UAS 

operations, can be taught in the training proposed herein. As a review of the 

requirements of part 61.127 and 107 demonstrate, the issues presented as they 

relate to a 55 pound aircraft, operating at less than 35 mph during data collection

operations are those taught in ground school and in flight training with the 

particular UAS and not gained from accumulating flight hours in a fixed wing or 

rotorcraft gas or jet A powered aircraft completing cross country flights and take 

offs and landings at controlled and uncontrolled airports.

As to national security review of pilots, each of AREIS’ pilots/operators will obtain 

internally provided certified training (Ground and Practical) from AREIS to operate

the UAV. This review and certification could reasonably vet the Operators against 

any known terrorist or no fly listings that are relevant and publically available. . In 

addition because we work closely with the military, most of our employees are 

vetted through the security clearance processes.

AREIS additionally asks that the exemption be issued without the requirement for a 

visual observer. As set forth herein, an equivalent level of safety is provided by the 

size, speed and control capabilities of the aircraft, as well as the operational 

procedures that will be applicable to all flight hereunder. These obviate the need for 

the visual observer. 

The Operator will be operating the aircraft, always within line of sight. He or she will 

walk and follow the aircraft around the inspection area so that while it is flying its 

pre-programed and at times, manual flight path, the UAS will always be directly in 

his or her line of sight. The Operator will not be distracted by viewing the pictures 

taken during the flight. Rather, once the UAV is launched, the Operator’s only duty 

will be to watch the flight of the UAS over the structure and intervene to address 

flight path deviations or other issues that arise during the flight. The functions that 

an observer performs where the aircraft is flown at long distances from the launch 
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area will not be necessary as the Operator will always have the aircraft in his or her 

direct sight. The observer also will not be necessary because the Operator will 

conduct a pre-flight inspection of the area, will and if needed, cordon off the area 

and will perform frequent visual scans of the area while the vehicle is operating.

AREIS again notes that the NPRM does not require the use of a visual observer. 

Given the clear direction in Section 333 of the Reform Act; the authority contained 

in the Federal Aviation Act, as amended; the strong equivalent level of safety 

surrounding the proposed operations, and the significant public benefit, including 

enhanced safety, reduction in environmental impacts, including reduced emissions 

associated with allowing battery powered UAV’s for these functions instead of 

turbine or gas power aircraft/rotorcraft and operations with pilots having at least a 

private pilot license, the grant of the requested exemptions is in the public interest. 2

Aircraft and Equivalent Level of Safety

The Petitioner proposes that the exemption requested herein apply to civil aircraft 

that have the characteristics and that operate with the limitations listed herein. 

These limitations provide for at least an equivalent or even higher level of safety to 

operations under the current regulatory structure because the proposed operations 

represent a safety enhancement to the operations conducted with conventional 

aircraft or with humans climbing up and around structures. 

These limitations and conditions to which AREIS (referred to as “Operator”) agrees 

to be bound when conducting commercial operations under an FAA issued 

exemption include:

1) Operations authorized by this grant of exemption are limited to the aircraft 

described in the Operator’s manual, which is are multi-rotors and/or fixed 

wing weighing up to 55 pounds: Proposed operations of any other aircraft 

will require a new petition or a petition to amend this grant.

2) The UA may not be flown at an indicated airspeed exceeding 35 mph (multirotors 10 mph during inspections).

3) The UA must be operated at an altitude of no more than 400 feet above 

ground level (AGL), as indicated by the procedures specified in the 

Operator’s manual. All altitudes reported to ATC must be in feet AGL.

 

2 Should the FAA determine that it cannot grant such an exemption for operations 

without a FAA licensed private pilot, despite the showing made herein, under the 

statutory authority the FAA already has, AREIS will operate its aircraft with pilots 

holding at least a private pilot certificate issued by the FAA. 
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4) The UA must be operated within visual line of sight (VLOS) of the Aircraft

Operator at all times. This requires the Aircraft Operator to be able to use 

human vision unaided by any device other than corrective lenses..

5) The Exemption Holder’s Manuals must be amended to include all conditions 

and limitations required by the FAA. The Manuals must be maintained and 

made available to the Administrator upon request. If a discrepancy exists 

between the conditions and limitations in the exemption and the procedures 

outlined in the Exemption Holder’s Operator’s manual, the conditions and 

limitations in the exemption take precedence and must be followed. 

Otherwise, the Aircraft Operator must follow the procedures as outlined in 

its Aircraft’s manual. The Exemption Holder may update or revise its 

Manuals. It is the Exemption Holder’s responsibility to track such revisions 

and present updated and revised documents to the Administrator upon 

request. The Exemption Holder must also present updated and revised 

documents if it petitions for an extension or amendment of this exemption. If 

the Exemption Holder determines that any update or revision would affect 

the basis upon which the FAA granted this exemption, then the Exemption 

Holder must petition for amendment to its exemption.

6) Prior to each flight, the Aircraft Operator must inspect the UAS to ensure it is 

in a condition for safe flight. If the inspection reveals a condition that affects 

the safe operation of the UAS, the aircraft is prohibited from operating until 

the necessary maintenance has been performed, and the UAS is found to be 

in a condition for safe flight. The Ground Control Station must be included in 

the preflight inspection. All maintenance and alterations must be properly 

documented in the aircraft records.

7) Any UAS that has undergone maintenance or alterations that affect the UAS

operation or flight characteristics, e.g., replacement of a flight critical 

component, must undergo a functional test flight in accordance with the 

Exemption holder’s Manuals. The Aircraft Operator who conducts the 

functional test flight must make an entry in the UAS aircraft records of the 

flight. The requirements and procedures for a functional test flight and 

aircraft record entry must be added to the Exemption Holder’s Operator’s 

manual.

8) The Exemption Holder must follow the manufacturer’s UAS 

aircraft/component, maintenance, overhaul, replacement, inspection, and life 

limit requirements, with particular attention to flight critical components 

that may not be addressed in the manufacturer’s manuals.

9) The Exemption Holder must carry out its maintenance, inspections, and 

record keeping requirements in accordance with the Operator’s Manuals. 

Maintenance, inspection, and alterations must be noted in the aircraft 
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logbook, including total flight hours, description of work accomplished, and 

the signature of the authorized technician returning the UAS to service.

10) The authorized technicians must receive and document training referenced 

in the Exemption Holder’s Manuals.

11) Each UAS operated under this exemption must comply with all manufacturer

System and Safety Bulletins.

12) The Exemption Holder’s maintenance personnel must make a record entry in 

the UAS logbook or equivalent document of the corrective action taken 

against discrepancies discovered between inspections.

13) Prior to commencing operations, the Aircraft Operator shall have logged at 

least 25 hours of total time as a UA pilot and at least ten hours logged as a UA 

pilot with a similar UA type and 5 hours in the make and model.

14) If the UAS loses communications or loses its GPS signal, the UA must return

to a pre-determined location within the private or controlled-access property

and land or be recovered in accordance with the Exemption Holder’s 

Manuals.

15) The Aircraft Operator must abort the flight in the event of unpredicted 

obstacles or emergencies, including unauthorized people entering the flight 

area, in accordance with the Exemption Holder’s Manuals.

16) The Aircraft Operator is prohibited from beginning a UAS flight unless

(considering wind and forecast weather conditions) there is enough power 

to fly to the first point of intended landing and, assuming normal cruising 

speed, to fly after that for at least 10 minutes.

17) All aircraft operated in accordance with the exemption must be identified by

serial number, registered in accordance with 14 CFR part 47, and have

identification (N- Number) markings in accordance with 14 CFR part 45, 

Subpart C. Markings must be as large as practicable.

18) Before conducting operations, the radio frequency spectrum used for

operation and control of the UA must comply with the Federal

Communications Commission (FCC) or other appropriate government

oversight agency requirements.

19) The documents required under 14 CFR 91.9 and 91.203 must be available to

the Operator at the Ground Control Station of the UAS any time the aircraft is

operating. These documents must be made available to the Administrator or

any law enforcement official upon request. 
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20) The UA must remain clear and yield the right of way to all other manned

operations and activities at all times (including, but not limited to, ultra-light

vehicles, parachute activities, parasailing activities, hang gliders, etc.).

21) The UA may not be operated by the Aircraft Operator from any moving 

device or vehicle.

22) UAS operations may not be conducted during night, as defined in 14 CFR 1.1.

23) All operations must be conducted under visual meteorological conditions 

(VMC). The UA may not be operated less than 400 feet below or less than 

2,000 feet horizontally from a cloud or when visibility is less than 3 statute 

miles from the Operator.

24) During operations the UA may not operate within 5 nautical miles of the

geographic center of an airport as denoted on a current FAA-published

aeronautical chart unless a letter of agreement with that airport’s 

management is obtained, and the operation is conducted in accordance with 

a NOTAM, if as required by the Operator’s COA. The letter of agreement with 

the airport management must be made available to the Administrator upon 

request.

25) The UA may not be operated over congested or densely populated areas 

unless the conditions set for in #26 are satisfied. These populated areas 

include but are not limited to the yellow areas depicted on World 

Aeronautical Charts (WAC), Sectional Aeronautical Charts (Sectionals), or 

Terminal Area Charts (TAC). However, aeronautical charts may not reflect 

pertinent local information. Ultimately, it is the Operator’s responsibility to 

maintain the minimum safe altitudes required by § 91.119 (d) (1).

26) Flight operations must be conducted at least 400 feet from all 

nonparticipating persons, vessels, vehicles, and structures unless:

a. Barriers or structures are present that sufficiently protect nonparticipating 

persons from debris in the event of an accident. The Aircraft Operator must 

ensure that nonparticipating persons remain under such protection. If a 

situation arises where nonparticipating persons leave such protection and 

are within 30 feet of the UA, flight operations must cease immediately 

and/or;

b. The aircraft is operated near vessels, vehicles or structures where the land 

owner/controller has granted permission and/or the Aircraft Operator has 

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

and;

c. Operations near the Aircraft Operator do not present an undue hazard to 

the Operator per § 91.119(a).
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27) All operations shall be conducted over private or controlled-access property

with permission from the land owner/controller or authorized 

representative. Permission from land owner/controller or authorized 

representative will be obtained for each flight to be conducted.

28) Any incident, accident, or flight operation that transgresses the lateral or 

vertical boundaries of the operational area as defined by the applicable COA 

must be reported to the FAA’s UAS Integration Office (AFS-80) within 24 

hours. Accidents must be reported to the National Transportation Safety 

Board (NTSB) per instructions contained on the NTSB Web site: 

www.ntsb.gov.

Specific Uses Public Benefits

AREIS proposes use of its UAV provided equivalent or augmented levels of safety for 

each of the uses proposed herein:

The present systems of photography and videography and mapping of inspecting 

the roofs, agriculture land, buildings and large structures site surveys, wild life 

monitoring, mosquito and insect control are now conducted by either humans 

wading through swamps, climbing on the roofs and structures that are steep, tall, 

slippery, weakened or otherwise hazardous or by the use of conventional aircraft. 

The current procedures can result in significant injuries to the people who must 

climb on the roofs or require the use of aircraft that are orders of magnitude greater 

in size than the UAV. Either method, manual inspection or large conventional 

aircraft, results in increased risk of injury due to personnel falling off roofs or 

ladders, carrying heavy ladders and dealing with confined and dangerous spaces, or 

increased risk from low altitude flyovers with helicopters or fixed wing aircraft 

inspecting buildings after damage from storms or other disasters, such as 

earthquakes or fires. Such flights are, of course, significantly more expensive than 

those undertaken with a UAV. 

The present system exposes those not only in the immediate area of inspection, but 

those who are along the path of flight associated with the arrival and departure of 

the conventional aircraft at the inspection site because the aircraft must be flown to 

and from the site. By contrast, the UAV is carried to the site and transits no other

property. Conventional aircraft carry flammable fuels that are not carried by the 

UAS and emit pollutants associated with internal combustion engines. The UAV’s 

proposed herein are battery powered and have no emissions.
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Equivalent Level of Safety

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

Command;

Section 61.113(a) & (b) limit private pilots to non-commercial operations. Unlike a 

conventional aircraft that carries a pilot, passengers, and cargo, the AREIS’s UAVs

are remotely controlled with no passengers or property of others on board. Section 

61.133(a) requires an individual with a commercial pilot’s license to be pilot in 

command of an aircraft for compensation or hire. 

AREIS respectfully proposes that Operator requirements should take into account 

the characteristics of the particular UAS. AREIS’s UAVs have a high degree of preprogrammed control and various built-in technical capabilities that strictly limit the 

potential for operation outside of the operating conditions set forth in the 

exemption application. The AREIS’s UAVs have navigation and control system 

comprised of a Ground Control Station (GCS) and auto-pilot system that can be preprogrammed to set operational boundaries. All flights are pre-programmed with 

precision GPS guidance. In the case of unplanned events, the Operator may input 

pre-programmed evasive maneuvers from the control unit, and the onboard 

autopilot executes those maneuvers. Pre-programmed Operator interventions 

include initiation of holding at present position; suspension of mission; fly back to 

launch point; abort mission and land immediately; and emergency power cut off and 

land (Flight Termination System).

Additional automated safety functions and safety enhancing features of the AREIS’s

UAV’s may include the following:

1) Auto-pilot detection of lost GPS or of insufficient satellites initiates an 

immediate landing.

2) Low power on the aircraft triggers escalating alarms at GCS at 35% and 

10% levels. Low power below 10% triggers an immediate landing.

3) If the auto-pilot detects a lost-link to the ground controller, the UAS will 

hold position at its current location for 5 seconds and if the signal is not 

restored, execute a return to home and land.

4) Redundant “kill switches” that enable completely shutting the aircraft 

down in flight in the event of a loss of control or un-commanded deviation 

from the flight path.

5) The aircraft, weighs less than 55 lbs., fully loaded.

6 ) The motors are driven by pulse width modulated signals, not analog 

signals.

7) The aircraft will operate for the Purposes at no more than 35 mph (while 

imaging) nor above 200 feet above the structure (imaging altitude) or a 

maximum of 400 AGL.
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Given these safety features, AREIS proposes that Operators of the AREIS’s UAV

should not be required to hold a commercial or private pilot certification. 

Instead, Operators should be required to: have successfully completed, at a 

minimum, FAA private pilot ground instruction and passed the FAA Private Pilot 

written examination or FAA-recognized equivalents; have completed the 

manufacturer’s or AREIS’s training program for operation of the UAS.

AREIS notes that the FAA has found that safety factors permitted operation of UASs 

by Operators with these qualifications in the case of operations pursuant to public 

COAs where the mandatory operating conditions specified above were present. See, 

Federal Aviation Administration, Notice N-8900.227, Unmanned Aircraft Systems 

(UAS) Operational Approval, at 20-21 (July 30, 2013). Likewise, AREIS notes that the

NPRM does not require that the Operator hold a private pilot license issued by the 

FAA.

Given these conditions and restrictions, an equivalent level of safety will be 

provided by allowing operation of the AREIS’s UAV without a private pilot’s 

certificate or a commercial pilot’s certificate, under the conditions set forth herein.

The risks associated with the operation of the AREIS’s UAV (given its size, speed, 

operational capabilities, and lack of combustible fuel) are so diminished from the 

level of risk associated with private pilot operations or commercial operations 

contemplated by Part 61 with conventional aircraft (fixed wing or rotorcraft), that 

allowing operations of the UAS as set forth above meets or exceeds the present level 

of safety provided under 14 C.F.R. § 61.113(a) & (b) and does not rise to the level of 

requiring a commercial pilot to operate the aircraft under § 61.133(a).

14 C.F.R. § 91.7(a): Civil aircraft airworthiness.

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

airworthy condition. Should the exemption be granted allowing commercial 

operation of the UAS without an airworthiness certificate, no standard will exist for 

airworthiness of the UA. Given the size of the aircraft and the requirements that the 

Operator has agreed to as it relates to airworthiness, as contained in the flight 

manual, an equivalent level of safety will be achieved by insuring compliance with 

the manuals prior to each flight..

14 C.F.R. §91.119: Minimum safe altitudes

Section 91.119 establishes safe altitudes for operation of civil aircraft. Section 

91.119 (d) allows helicopters to be operated at less than the minimums prescribed, 

provided the person operating the helicopter complies with any route or altitudes 
Page 20

prescribed for helicopters by the FAA. As this exemption is for a UAS that is a 

helicopter and the exemption requests authority to operate at altitudes up to 400

AGL, an exemption may be needed to allow such operations. 

The equivalent level of safety will be achieved given the size, weight, and speed of 

the UAS as well as the location where it is operated. No flight will be taken without 

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

of the advance notice to the property owner and participants, all affected individuals 

will be aware of the planned flight operations as set forth in the Manuals. Compared

to flight operations with aircraft or rotorcraft weighing far more than the maximum 

55 lbs. and the lack of flammable fuel, any risk associated with these operations is 

far less than those presently presented by conventional aircraft operating at or 

below 400 AGL in the aerial photography industry. In addition, the low-altitude

operations of the UAS will ensure separation between these small-UAS operations 

and the operations of conventional aircraft that must comply with Section 91.119. 

14 C.F.R. §91.121 Altimeter Settings

This regulation requires each person operating an aircraft to maintain cruising 

altitude by reference to an altimeter that is set “...to the elevation of the departure 

airport or an appropriate altimeter setting available before departure.” As the 

AREIS’ UAV, in manual or emergency mode, will not have a barometric altimeter 

display, but instead a GPS altitude display, an exemption will be needed. The 

Operator, pursuant to the procedures set forth in the Manuals as indicated before 

flight, will achieve an equivalent level of safety. 

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

Section 91.151(a) prohibits an individual from beginning “a flight in an airplane 

under VFR conditions unless (considering wind and forecast weather conditions) 

there is enough fuel to fly to the first point of intended landing, and, assuming 

normal cruising speed – (1) During the day, to fly after that for at least 30 minutes; 

or (2) At night, to fly after that for at least 45 minutes.”

The battery powering the UAS provides approximately 40 minutes of powered 

flight. To meet the 30-minute reserve requirement in 14 CFR §91.151, UAS flights 

would be limited to approximately 10 minutes in length. Given the limitations on the 

UAS’ proposed flight area and the location of its proposed operations within a 

predetermined area, a longer time frame for flight is reasonable.

Petitioner believes that an exemption from 14 CFR §91.151(a) falls within the scope 

of prior exemptions. See Exemption 10673 (allowing Lockheed Martin Corporation 

to operate without compliance with FAR 91.151 (a)). Operating the small UAS, in a 

tightly controlled area where only people and property owners or official 
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representatives who have signed waivers will be allowed, with less than 30 minutes 

of reserve fuel, does not engender the type of risks that Section 91.151(a) was 

intended to alleviate given the size and speed of the small UAS.

Petitioner believes that an equivalent level of safety can be achieved by limiting 

flights to 30 minutes or 25% of remaining battery power whichever happens first. 

This restriction would be more than adequate to return the UAS to its planned 

landing zone from anywhere in its limited operating area.

14 C.F.R. §91.405 (a); 91.407 (a) (1); 91.409(a) (2); 91.417(a) & (b): Maintenance

Inspections

These regulations require that an aircraft Operator or owner “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...,” and others shall inspect or 

maintain the aircraft in compliance with Part 43.

Given that these sections and Part 43 apply only to aircraft with an airworthiness

certificate, these sections will not apply to the Petitioner. Maintenance will be 

accomplished by the Operator or manufacturer pursuant to the flight manual and 

operating handbook as referenced in the Manuals attached as confidential Exhibits 

An equivalent level of safety will be achieved because these small UASs are very 

limited in size and will carry a small payload and operate only in defined areas for 

limited periods of time. If mechanical issues arise, the UAS can land immediately and 

will be operating from no higher than 400 feet AGL. As provided in the Aircraft 

Flight Operations Manual the Operator will ensure that the UAS is in working order

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

maintenance performed. Moreover, the Operator and manufacturer are most 

familiar with the aircraft and best suited to maintain the aircraft in an airworthy 

condition to provide the equivalent level of safety. 

*********

Federal Register Publication

Pursuant to 14 C.F.R. Part 11, the following summary is provided for publication in 

the Federal Register, should it be determined that publication is needed:

Petitioner seeks an exemption from the following rules:

14 C.F.R. §§ 61.23(a) and (c);, 61.101(e)(4) and (5); 61.113(a) & (b); 61.133(a); 

61.315(a); 91.7(a); 91.119(c); 91.121; 91.151(a)(1); 91.405(a); 91.407(a)(1); 
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91.409(a)(2) and 91.417 (a) & (b) to operate commercially a small unmanned 

vehicle (55 lbs. or less) for the following purposes: to conduct bridge inspections, 

flare stack inspection, utility-power generation system inspections and patrolling, 

aerial inspection and photography of residential and commercial utility 

infrastructure including but not limited to electrical power lines, wind turbines and 

cell towers, pipeline inspection and patrolling, filmmaking, cinematography, and 

videography, precision agriculture with on board sensors, wildlife and forestry 

monitoring and mosquito and insect control, aerial surveying, construction site 

inspection and monitoring, public entity support operations, aerial video and live 

video feed to assist with search and rescue operations under the authority and 

support of local authority officials, aerial video and photography for public and 

private use including television, public events, and cinematography live feed and 

live newsgathering, training to persons individually or belonging to both private and 

public organizations to increase awareness and improve safety for current and 

future UAS operations within the NAS, special events: including high schools, 

colleges, professional sports, open air events and fairs, research, risk management 

and assessment, motion picture production, surface mining, closed set filming, 

disaster and catastrophe events.

Privacy and National Security

All flights will occur over private or controlled access property with the property 

owner’s prior consent and knowledge. Inspection will be of inanimate objects in 

areas where the owners will have consented to the inspections or otherwise have 

agreed to allow the UAS and the Operator to be in the area where operations will 

take place. 

The size of the UAS, its speed and restricted area of operation do not raise national

security issues.

Summary

Approval of exemptions allowing commercial operations of UAV’s for petitioner to 

operate an unmanned aircraft system (UAS) to provide aerial video and live video 

feed to assist with situational awareness support for emergency responders and 

search and rescue operations under the authority and support of local authority 

officials, commercial bridge inspections, flare stack inspection, utility-power 

generation system inspections and patrolling, aerial inspection, photography and 

videography of utility infrastructure including but not limited to electrical power 

lines, wind turbines and cell towers, pipelines,, precision agriculture with on board 

sensors, wildlife and forestry monitoring and mosquito and insect control, aerial 

surveying, construction site inspection and monitoring, aerial imaging for safety, 

monitoring and comparing work efforts and completion percentages, surface 
Page 23

mining, and security of a controlled environment for various sites , aerial video and 

photography for public and private use including television, public events, and 

cinematography live feed and live newsgathering, training to persons individually or

belonging to both private and public organizations to increase awareness and 

improve safety for current and future UAS operations within the NAS, photography 

and videography of residential and commercial real estate, disaster and catastrophe 

events, will enhance safety by reducing risk.

Conventional operations, using jet or piston powered aircraft, ladders or placing 

people in swamps, on roofs or tall, hazardous or weakened structures, exposes them 

to higher risks than those created by use of a UAVs. Conventional aircraft that 

operate at extremely low altitudes just feet from the subject being inspected and in 

extreme proximity to people and structures present the risks associated with 

vehicles that weigh in excess of 6,000 lbs., carrying large amounts of jet A or other 

fuel (140 gallons for jet helicopters). Such aircraft must fly to and from the project 

location. In contrast, a UAV weighing fewer than 55 lbs. and powered by batteries 

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

fuel carried on board. The UAV is carried to the target area and not flown. The UAV

will carry no passengers or crew and, therefore, will not expose them to the risks 

associated with manned aircraft flights.

The operation of small UASs, weighing less than 55 lbs., conducted under the strict

conditions outlined above, will provide an equivalent level of safety supporting the 

grant of the exemptions requested herein. These lightweight aircraft operate at slow 

speeds, close to the ground, and in areas that are under the control of the customer 

for the operations and, as a result, are far safer than conventional operations 

conducted with turbine helicopters operating in close proximity to the ground and 

people or the use of individuals to climb the structures to conduct the operations.

Satisfaction of the criteria provided in Section 333 of the Reform Act of 2012 –size, 

weight, speed, operating capabilities, proximity to airports and populated areas and 

operation within visual line of sight and national security – provide more than 

adequate justification for the grant of the requested exemptions allowing 

commercial operation of Petitioner’s UAS for the purposes outlined herein.

Sincerely,

Mark Denney

AREIS LLC

111 Bailey Drive, Ste. 3

Niceville, FL 32578
Page 24
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APPENDIX A – UAS SPECIFICATIONS
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APPENDIX B – USAF UAS SAFETY QUESTIONNAIR

Petitioner submits the Appendix and Documents marked “CONFIDENTIAL,” as they contain 

proprietary confidential business information that is not released to the public and is 

protected under the Freedom of Information Act 5 USC §552 et. seq. 5 Reform Act Section 

333 (b). 

Submitted under separate cover.
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APPENDIX C – FLIGHT LOG