Request for Exemption: Global Positions, LLC Page 1

Global Positions, LLC, Montana – Petition for Section 333 Exemption 

July 4, 2015

U. S. Department of Transportation 

Docket Management System

1200 New Jersey Avenue S.E.

Washington, DC 20590

Reference: Request for Exemption under Section 333 of the FAA Modernization and 

Reform Act of 2012 from 14 CFR. Part 21; 14 CFR. 43.7; 14 CFR. 43.11; 14 CFR. 

45.11; 14 CFR. 45.27; 14 CFR. 45.29; 14 CFR. 61.113; 14 CFR. 91.7(a); 14 CFR. 

91.9(b)(2); 14 CFR. 91.9(c); 14 CFR. 91.103(b)(2); 14 CFR. 91.105; 14 CFR. 91.109; 14 

CFR. 91.119; 14 CFR. 91.121; 14 CFR. 91.151; 14 CFR. 91.203(a) & (b); 14 CFR. 

91.215; 14 CFR. 91.403; 14 CFR. 91.405; 14 CFR. 91.407; 14 CFR. 91.409; 14 CFR. 

91.417 and 14 CFR 61.195.

Dear Sir or Madam,

Global Positions, a Montana Limited Liability Company (LLC), seeks an exemption to 

certain Federal Aviation Regulations (FARs) pursuant to Section 333 of the FAA 

Modernization and Reform Act of 2012 (the Reform Act) and Part 11 of Title 14 of the 

CFR. The requested exemption would support a claim for a Commercial Certificate of 

Authorization to use the system to perform aerial photography, spatial data collection for 

mapping and GIS, academic research, and video capture (aerial data collection). 

Approval of exemptions for Global Positions, LLC will permit commercial unmanned 

aircraft system (UAS) operations. By approving these exemptions, the FAA will create 
Request for Exemption: Global Positions, LLC Page 2

benefits through safer survey methods by UAS, resulting in decreased potential for loss 

of life and enhanced efficiency and productivity for the affected activities, which are all 

ultimately in the public interest.

Global Positions, LLC submits this application in accordance with the Reform Act, 112 

P.L. 95 §§ 331-334, pursuing reprieve from any currently applicable FARs operating to 

inhibit Global Positions, LLC proposed aerial data collection within the national airspace 

system. 

This exemption request should be granted because the use of the aircraft utilized by 

Global Positions, LLC under the limitations and conditions anticipated will meet or 

exceed an equivalent level of safety as Congress has intended. 

Sincerely,

Jere Folgert

Principal, Global Positions, LLC
Request for Exemption: Global Positions, LLC Page 3

Overview: Pursuant to 14 CFR. Part 11, the following overview 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 CFR. Part 21; 14 CFR. 43.7; 14 CFR. 43.11; 14 CFR. 45.11; 14 CFR. 45.27; 14 

CFR. 45.29; 14 CFR. 61.113; 14 CFR. 91.7(a); 14 CFR. 91.9(b)(2); 14 CFR. 91.9(c); 14 

CFR. 91.103(b)(2); 14 CFR. 91.105; 14 CFR. 91.109; 14 CFR. 91.119; 14 CFR. 91.121; 

14 CFR. 91.151; 14 CFR. 91.203(a) & (b); 14 CFR. 91.215; 14 CFR. 91.403; 14 CFR. 

91.405; 14 CFR. 91.407; 14 CFR. 91.409; and 14 CFR. 91.417.

Approval of these exemptions for Global Positions, LLC will permit commercial 

operations of UAS for the purpose of obtaining vertical and oblique aerial images and 

video. Images will be post-processed (orthorectification will be performed to create 

planimetrically-correct image) and used predominantly in geographic information system 

(GIS) for mapping and analysis. Global Positions, LLC does not intend to operate sUAS

for the purpose of closed-set motion picture filming. 

This petition for exemption is submitted to fulfill the objective of congress in 

passing Section 333(a) through (c) of the Reform Act. Congress has directed the 

FAA "to safely accelerate the incorporation of civil unmanned aircraft systems into 

the national airspace system." Pursuant to Section 333 of the Reform Act, the 

FAA Administrator is to contemplate whether certain unmanned aircraft systems 

may maneuver safely in the National Airspace ("NAS") before completion of the 

formal UAS rulemaking, based on If the Secretary supports 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". 

The exemption should be granted because the operations proposed by Global Positions, 

LLC, using unmanned UAS weighing less than 10 pounds, conducted according to the 

conditions and limitations deliberated in this document will deliver a level of safety 

exceeding that of traditional aerial operations - operating as manned aircraft. No flights 

will be conducted without the acquisition of adequate GPS signals to enable GPS-aided 

flight. Flights will be constrained to class G airspace at altitudes less than 400 feet 

Above Ground Level (AGL) and at controlled speeds. Each of the factors identified by 

the Congress in approving this exemption process under Section 333 including weight, 
Request for Exemption: Global Positions, LLC Page 4

speed, size, operational capability, proximity to airports, operation within visual line of 

light and proximity to densely populated areas, supports confirmation of the exemptions 

desired by Global Positions, LLC.

Description of the Petitioner: Global Positions, LLC is a Montana Limited Liability 

Company established in 1997 and specializes in geographic information systems, 

professional mapping, cartography, data collection, education and outreach. Global 

Positions, LLC has completed numerous GIS projects around the globe and has 

received the Small Business Innovation Research (SBIR) Award from the National 

Science Foundation. Global Positions, LLC has performed numerous sUAS flights in 

remote areas under different weather conditions.

Contact Information:

Mr. Jere Folgert, Principal

Global Positions, LLC

3215 Warbler Way #5

Bozeman, MT 59718

(406) 580 1314

Jfolgert@GlobalPositions.com

www.GlobalPositions.com
Request for Exemption: Global Positions, LLC Page 5

Qualifications for Exemption Under Section 333 of FMRA: The proposed 

operations would permit the use of a small UAS (sUAS) under controlled 

conditions in airspace where: (1) flights are limited in vertical elevation and 

horizontal distance travelled; (2) flights are prearranged and preplanned; (3) 

sUAS are operated in line of sight and will only operate within those areas 

designated in the enclosed Flight Operations Manual; (4) Controller conduct its 

own operations in compliance with the protocols described herein or as otherwise 

established by the FAA. 

Global Positions, LLC currently operates the DJI Inspire 1. Due to the rapid 

advancements in technology and improvements in aircraft safety, Global 

Positions, LLC requests that any exemption granted extend not only to the DJI 

Inspire 1 currently owned by Global Positions, LLC, but also to any future sUASs 

owned by Global Positions, LLC that are manufactured by DJI; (2). Have a flight 

weight less than 10 pounds at takeoff; (3). Have built-in global positioning system 

(GPS) receiver that aids in its flight, position, and elevation. (4). Have improved 

safety features as compared to the DJI Inspire 1.

If the request for exemption cannot be fulfilled for future sUASs owned by Global 

Positions, LLC - Global Positions, LLC explicitly requests the exemption allowing

the operation of the DJI Inspire 1. 

Characteristics of the Aircraft: The DJI Inspire 1 is a battery-powered UAV 

utilizing electric motors and blade rotors. It has a maximum gross weight of 

approximately six and one half (6.5) pounds. The DJI Inspire 1, model number

T600 has a weight (battery included) of 2935 grams. It has a hovering accuracy 

(GPS mode) vertical of 0.5 meters and Horizontal accuracy of 2.5 meters. Its

maximum angular velocity pitch is 300 degrees per second and its maximum 

ascent speeds is 5 meters per second. The maximum flight time is approximately 

18 minutes. Its operating temperature range is between -10° C to 40° C. It has 
Request for Exemption: Global Positions, LLC Page 6

an overall dimensions of 438 m x 451 mm x 301 mm.

Image of the DJI Inspire 1.

The DJI Inspire 1 has a built-in flight control system that utilizes GPS, an inertial 

measurement unit, and electronic compass. This unit has a maximum flight 

speed of approximately 40 knots and uses a 22.2 volt, 4500 milliampere-hour 

battery, which provides an energy source to power the craft’s motors and 

electronics for approximately 15 minutes of flight. This aircraft has distinctive

failsafe capabilities including an ability to determine the amount of battery power 

required to fly the aircraft back to a pre-designated home point. The DJI Inspire 

1 has limited range due to the physical limitations of the Light Bridge transmission 

system from the remote controller. In addition, this aircraft has the capability for a 

maximum altitude to be set prior to each flight. DJI Inspire 1 has programmed 

into the firmware “no-fly zones” which will prevent flights in restricted airspace. 

Please refer to the respective user manual for the DJI Inspire 1 aircraft for 

additional information.

Considering the authority contained in the Federal Aviation Act, as amended in 

Section 333 of the Reform Act, the equivalent level of safety surrounding the 
Request for Exemption: Global Positions, LLC Page 7

proposed operations, and the significant public benefit, the grant of the requested 

exemptions is also in the public interest. 

Granting Global Positions, LLC request conforms with the Secretary of Transportation’s 

(FAA Administrator’s) responsibilities and authority to not only integrate UAS's into the 

national airspace system, but to “...establish requirements for the safe operation of such 

aircraft systems [UAS's] in the national airspace system” under Section 333(c) of the 

Reform Act specific to the use of UAS's for real estate/Realtor purposes. 

Global Positions, LLC Request Will Benefit the Public: Congress has declared 

that it is in the public’s interest to integrate commercially flown UAS's into the 

national airspace system, henceforth passing of the Reform Act. Granting Global 

Positions, LLC exemption request furthers the public interest. National policy set 

by Congress favors early integration of UAS into the national airspace in 

controlled, safe working environments such as those proposed in this petition. 

Aerial photography, remote sensing for geographical analysis and inventory, aerial 

videography and filmmaking, mapping, and photogrammetry have been made possible 

through the use of manned fixed wing aircraft and helicopters. The public’s interest is 

advanced by diminishing potentially fatal crashes of manned aircraft and helicopters by 

permitting aerial video, and photography capture through UAS's. Permitting Global 

Positions, LLC to fly within national air space furthers economic growth by offering costeffective aerial photography, mapping products, and videography. Granting Global 

Positions, LLC exemption request furthers the public interest through awareness of the 

spatial connections of natural and human-made features on the ground and 

geographical assessment and analysis of said features using GIS and mapping 

technologies.

Granting the exception will help federal agencies gain a greater understanding and 

knowledge base for conducting commercial UAS operations. This valuable information 

has the potential to facilitate future rules and regulations, UAS flight operations, and 

operator qualifications. The UAS operated by the Petitioner are light weight and do not 

carry any flammable fuel, further reducing the risk from any potential accident and harm 

to humans, animals, and property. Global Positions, LLC agrees to follow best safety 

practices when operating a battery-powered sUAS.
Request for Exemption: Global Positions, LLC Page 8

Proposed Flight Conditions and Operations: Global Positions, LLC would like to 

operate sUAS prior to the time period by which the Reform Act requires the FAA to 

promulgate rules governing such craft. The Reform Act in Section 332 provides for 

incorporation of unmanned aircraft systems into our national airspace system as it is in 

the public’s interest to do so. Global Positions, LLC, sUAS meets the definition of “small 

unmanned aircraft” as defined in Section 331 and therefore the integration of Global 

Positions, LLC sUAS is expressly contemplated by the Reform Act. 

Global Positions, LLC intends sUAS operation locations to be primarily in unpopulated 

areas in Montana, Wyoming and Idaho. Global Positions, LLC is requesting operations 

of sUAS in the United States and understands that this request may result in an increase 

in the FAA’s oversight tasks. 

Global Positions, LLC has no intention in creating a hazard to humans, non-human life 

forms, private property or manned aircraft, and has no desire to risk the loss of the 

Petitioner’s sUAS. Global Positions, LLC has performed numerous flights in remote 

areas under different weather conditions. Global Positions, LLC also performs simulated 

flights in order to maintain suitable skills for the sake of safety. Global Positions, LLC is 

extremely cautious when operating any UAS and will not “create a hazard to users of the 

national airspace system or the public.” 112 P.L. 95 § 333 (b). Given the small size and 

weight of Global Positions, LLC sUAS, it falls well within Congress’s contemplated safety 

zone when it promoted and published the Reform Act and the corresponding directive to 

integrate UAS's into the national airspace system. The sUAS used by Global Positions, 

LLC has a many safety features and does not pose a threat to the general public or 

national security. The sUAS operated by Global Positions, LLC is equipped with a GPS 

receiver, electronic compass, auto return safety technology (if communication is lost 

between the UAS and the controller), and Real-Time Fight Data Display. 

Global Positions, LLC proposes that the exemption requested herein apply to all civil 

aircraft that have the characteristics and that operate with the limitations listed in this 

document. These limitations deliver an equivalent or higher level of safety to operations 

under the current regulatory structure. Global Positions, LLC agrees to be bound to 

these limitations and conditions when piloting commercial operations under an FAA 
Request for Exemption: Global Positions, LLC Page 9

issued-exemption. What follows are twenty (20) proposed operational limitations and 

flight conditions, where Global Positions, LLC (Operator) which will safeguard flight 

operations conducted under current regulatory guidelines: 

1. Flights will be operated within line-of sight of the Operator. 

2. A Visual Observer (VO) will provide observation of the sUAS while in flight 

to alert the Operator of any risk factors inflight such as traffic or obstructions in 

the flight area. The VO will maintain communication with the Operator at all 

times. 

3. No flight shall occur within 5 miles of an established airport as noted and 

published on FAA published aeronautical charts, unless a letter of agreement 

with that airport’s manager is obtained.

4. The Operator will have sufficient training in operations of sUAS and will 

have received and reviewed up-to-date material on the specific sUAS 

operations and protocol as per the manufacture and Flight Operation Manual. 

5. The Operator of the sUAS will use eye protection (safety gear) when 

operating sUAS.

6. The sUAS will weigh less than 55 pounds. 

7. Before conducting any operations, the Operator will inspect components 

of the sUAS for any visible indications of damage, to include but not limited to 

the propeller blades, motors, aircraft frame and landing apparatus.

8. Prior to each sUAS flight, Operator will conduct extensive pre-flight 

planning including observations of weather conditions, weather forecasts, 

population density, and location of potentially hazardous flying conditions. Preflight checks using established protocols carries primary importance.

9. While sUAS is in flight, Operator will actively analyze flight data, wind 

speeds, weather conditions, forecasts and other sources of information to 

constantly update and enhance safety protocols.

10. Maximum flight time for each operational flight will be limited to a duration, 

where no less than 25% of battery life remains to power the sUAS. Battery life

information is displayed on the remote controller’s display, and is coded on the 

sUAS using different color flashing light-indicators.

11. sUAS operations will not be conducted during the night.
Request for Exemption: Global Positions, LLC Page 10

12. The Operator will operate said sUAS at an altitude not greater than 400 

feet above ground level.

13. The sUAS will not be operated less than 500 feet below or less than 

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

the Operator.

14. Contingency plans will be in place to safely terminate a flight if there is a 

loss of transmitter communications or a loss of GPS signal. 

15. Auto return-to-home and landing function will be utilized to increase safe 

return of the UAS to the ground.

16. The aircraft will be flown only in class G airspace. Each operation will be 

conducted in a way that avoids conflict with other ongoing operations in the 

NAS. 

17. The sUAS Pilot will be minimum holder of Private Pilot Certificate with a 

Class 3 Medical or State issued Driver License.

18. During the planning phase of each operation, the Operator will ensure that 

the sUAS, controller, and intelligent batteries have valid firmware updates from 

the manufacturer. Electronic compass and sensors will be recalibrated after 

each firmware update.

19. All Flight operations must be conducted at least 500 feet from all 

nonparticipating persons, vessels, vehicles, power lines, transformers, elevated 

lights and structures unless barriers or structures are existing that satisfactorily 

protect nonparticipating persons, or, the Operator has been granted permission 

for operating closer to those objects and has determined that it does not 

present a hazard.

20. The sUAS will not be used for the purpose of closed-set motion picture

filming.

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

weight, speed, size, safety measures, operating capabilities, operation within visual 

line-of sight, operation under certain weather conditions, proximity to airports and 

populated areas, provide adequate justification for the grant of the requested 

exemptions, allowing commercial operation applicant’s sUASs pursuant to the 

conditions and operations described above.
Request for Exemption: Global Positions, LLC Page 11

Safety and Public Interest: Global Positions, LLC has produced safety protocols that 

afford a level of safety equal to or exceeding existing rules. Benefits of using sUAS over 

conventional gasoline-powered fix-wing aircraft or helicopters include:

 UAS's do not carry humans on the aircraft therefor potential loss of life is diminished. 

Global Positions, LLC will only operate its UAS in specific areas away from mass 

populations.

 Flammable fuel is not used to power sUAS and the potential for fire or explosions is 

greatly diminished as compared to an aircraft using flammable fuel.

 Modern GPS-enabled UAS’s can be controlled and maneuvered with great 

precision, and can be controlled to avoid hazards quickly.

Use of the sUASs will reduce the need to have a manned aircraft provide a platform for 

obtaining video and/or photographs resulting in safety for life and property. Manned 

aircraft often carry combustible fuel and can weigh in excess of 900 pounds. The sUASs 

in this grant petition do not carry combustible fuel and weigh less than 10 pounds, 

significantly lessening the potential for damage to life and property. The amount of 

energy required to obtain aerial photographs or aerial video is significantly less than the 

energy required to obtain the same data using conventional fixed wing aircraft. These 

environmental factors are in the public interest and in favor of granting the exemption.

Because of the relative low noise levels produced by sUAS, data collection (photos and 

video) can be obtained in a relatively quiet manner (as compared to conventional fixedwing aircraft), which has the potential reduce potential disturbance levels for humans 

and other non-human life. Additionally, operating a sUAS in flight has a negligible 

environmental impact as compared to conventional manned aircraft which consume 

fossil fuel, and produce airborne pollution.
Request for Exemption: Global Positions, LLC Page 12

Attachments: Attachments listed are referenced in the request for exemption and 

contain trade secret and commercial proprietary information that Global Positions, LLC

has not and will not share with others except under appropriate confidentiality 

agreements. Global Positions, LLC is requesting that these attachments be preserved as 

proprietary information pursuant to 14 C.F.R. Section 11.35, and maintains that they are 

protected from release under the Freedom of Information Act. See 5 U.S.C. 552 et seq.

1. Standard Operating Procedures and Checklist for DJI Inspire 1

2. DJI Inspire 1 Operating Manual

Exemption Request: What follows are the sections of Title 14 of the Code of Federal 

Regulations from Which Global Positions, LLC Requests Exemption:

14 CFR. Part 21; 14 CFR. 43.7; 14 CFR. 43.11; 14 CFR. 45.11; 14 CFR. 45.27; 14 CFR. 

45.29; 14 CFR. 61.113; 14 CFR. 91.7(a); 14 CFR. 91.9(b)(2); 14 CFR. 91.9(c); 14 CFR. 

91.103(b)(2); 14 CFR. 91.105; 14 CFR. 91.109; 14 CFR. 91.119; 14 CFR. 91.121; 14 

CFR. 91.151; 14 CFR. 91.203(a) & (b); 14 CFR. 91.215; 14 CFR. 91.403; 14 CFR. 

91.405; 14 CFR. 91.407; 14 CFR. 91.409; 14 CFR. 91.417; and CFR 61.195.

Description of Specific Regulations that Global Positions, LLC Requests and 

Exemption From: 14 CFR. Part 21, and particularly Part 21(h). Part 21 prescribes, in 

pertinent part, the procedural requirements for issuing and changing design approvals, 

production approvals, airworthiness certificates, and airworthiness approvals. An 

equivalent level of safety with airworthiness certification can be achieved by the use of 

sUASs and the conditions and limitations imposed on operations which have been 

proposed in this petition.

14 CFR. 43.7: Persons authorized to approve aircraft, airframes, aircraft engines, 

propellers, appliances, or component parts for return to service after maintenance, 

preventive maintenance, rebuilding, or alteration. Global Positions, LLC has experience

repairing and modifying sUASs included in this grant. An equivalent level of safety will 

be obtained by Global Positions by conducting inspections and maintenance to ensure 

safe operation of sUAS.

14 CFR. 43.11: Content, form, and disposition of records for inspections conducted 

under parts 91 and 125 and §§ 135.411(a)(1) and 135.419 of this chapter. Because 
Request for Exemption: Global Positions, LLC Page 13

there are no certificated maintenance workers or inspectors for sUAS anticipated by this 

section, § 43.11 provides for no extra safety in flight. Global Positions, LLC proposes an 

equal level of safety will be attained by testing and inspecting the sUAS before and after 

each flight.

14 CFR. 45.11: Marking of products. The sUASs have a small size and footprint and do 

not have adequate space for required identification cards. Additional weight from the 

identification cards could depreciate the flight stability and performance of the aircraft.

An equivalent level of safety will be obtained by Global Positions by storing and 

archiving information related to the sUASs, including the serial number, user manual, 

and nomenclature at the ground station and affix the N-Numbers, once obtained from 

the FAA Registration Office.

14 CFR. 45.27: Location of marks; non-fixed-wing aircraft where each operator of a 

rotorcraft must display on that rotorcraft horizontally on both surfaces of the cabin, 

fuselage, boom, or tail the marks required by § 45.23. The sUASs used by Global 

Positions, LLC has a small size and do not have a cabin for humans. An equivalent level 

of safety will be obtained by Global Positions by displaying its N-Number(s) (when 

received by the FAA); they will be displayed on the fuselage of the aircraft as large as 

possible. This exemption provides an equivalent level of safety to 14 CFR. 45.27 

14 CFR. 45.29: Size of marks on aircraft. Global Positions, LLC requests an exemption 

from 14 CFR. 45.29. as the UASs have very little, if any surface areas large enough to 

allow placement of markings of that size. Further, two-inch lettering is difficult to place 

on such small aircraft with dimensions smaller that minimal lettering requirement. An 

equivalent level of safety will be obtained by Global Positions after they receives the NNumber(s). N-Numbers will be displayed on the UAS’s body or fuselage. The FAA has 

previously issued exemptions to this regulation through Exemptions Nos. 8738, 10167, 

10167A and 10700.

14 CFR. 61.113: Private pilot privileges and limitations: Pilot in command. This part 

prohibits persons with private pilot certificates from operating an aircraft for hire. Global 

Positions, LLC requests an exemption from 14 CFR. 61.113. Global Positions, LLC 

understands that the intent of necessitating a commercial certificate before operating an 
Request for Exemption: Global Positions, LLC Page 14

aircraft for hire is to protect human lives as most flights for hire are manned. Instead, 

Global Positions, LLC will attain an equal level of safety by ensuring all Operators go 

through a rigorous training program including flight simulation, practice flights, and a 

minimum of ten (10) flight hours in a multirotor sUAS. 

14 CFR. 91.7(a): Civil aircraft airworthiness. The FAA has previously stated that no 

exemption is required for a member of the DJI Phantom 2 family. Global Positions, LLC 

requests a similar for its sUASs: the DJI Inspire 1. The Inspire 1 is significantly similar to 

the Phantom 2 in structure and operation, but with additional safety features. Since there 

will be no airworthiness certificate issued for the aircraft at issue in this petition, it is not 

possible to comply with this regulation.

14 CFR. § 91.9 (b) (2) requires an aircraft flight manual in the aircraft. Global Positions, 

LLC requests exemption from 14 CFR. § 91.9 (b) (2) as there are no on board pilots or 

passengers, and given the size of the UAS, this regulation is inapplicable. An equivalent 

level of safety will be achieved by maintaining a safety and flight manual easily 

accessible to the Controller. The FAA has previously issued exemptions to this 

regulation in the past.

14 CFR. 91.9(c): Civil aircraft flight manual marking, and placard requirements. Global 

Positions, LLC requests an exemption from 14 CFR. 91.9(c). An equivalent level of 

safety will be obtained by Global Positions when they place on the aircraft, an N-Number 

obtained from the FAA.

14 CFR. 91.103(b)(2): Preflight action. The FAA has previously determined that relief 

from this section is not necessary. Global Positions, LLC requests that a similar 

determination be made with respect to this petition as Global Positions, LLC requires 

specific preflight actions to be followed prior to each flight including the review of maps, 

and charts, weather data including wind speed, calibrating the compass and verifying the 

aircraft has adequate GPS satellite signals for flight.

14 CFR. 91.105: Flight crewmembers at stations. Global Positions, LLC requests an 

exemption from 14 CFR. 91.105 since this section is not applicable due to the sUASs 

carrying no flight crewmembers. Global Positions, LLC will not operate the aircraft 
Request for Exemption: Global Positions, LLC Page 15

unless someone is at the controls at all times. An equivalent level of safety will be 

obtained by Global Positions, as the Operator will always remain at the ground station in 

control of the sUAS. This will result in an equivalent level of safety as the requirements 

of § 91.105.

14 CFR. 91.109 Flight instruction; simulated instrument flight and certain flight tests. 

Global Positions, LLC requests an exemption from 14 CFR. 91.109. This regulation 

requires dual controls for aircraft when conducting flight instruction. The remote 

controller can be easily transferred to another person midflight. 

14 CFR. 91.119: Prescribes safe altitudes for the operation of civil aircraft. Global 

Positions, LLC requests an exemption from 14 CFR. 91.119. Global Positions, LLC 

intends to operate its sUAS at an altitude no greater than 400 AGL; safely within the 

standard 400 AGL as recommended by the FAA Modernization and Reform Act of 2012. 

The sUAS operated by Global Positions, LLC have GPS-aided flight stability integrated 

into the flight control system which permits the sUASs to preserve their location when 

there are no inputs given through the remote controller.

14 CFR. 91.121: Altimeter settings. Global Positions, LLC requests an exemption from 

14 CFR. 91.121. This regulation states that setting the altimeter of an aircraft 

referenced to mean sea level (MSL) is required. The sUAS operated by Global 

Positions, LLC uses GPS to determine altitude, which is displayed to the operator as a 

digital readout to the video screen. GPS sensor is accurate to approximately 2.6 feet 

Vertical and 8.2 feet Horizontal. Global Positions, LLC intends to maintain flight in class 

G airspace within VLOS during VMC at altitudes less than 400 feet AGL which will 

safeguard that the sUASs do not impede with the flight of other aircraft.

14 CFR. 91.151: Fuel requirements for flight in VFR conditions. This regulation requires 

aircraft to have an amount of fuel that would carry the aircraft either 20 or 30 minutes 

beyond the intended landing point. Global Positions, LLC requests an exemption from 

14 CFR. 91.151. It is difficult to comply with this regulation due to the face that the sUAS 

in this petition use an onboard battery as power, and carry no liquid fuel at all
Request for Exemption: Global Positions, LLC Page 16

14 CFR. 91.203(a) & (b): Civil aircraft: Certifications required.

The FAA has previously determined that exemption from 14 CFR. 91.203(a) and (b) is 

not necessary. Global Positions, LLC requests an exemption from 14 CFR. 91.203(a) & 

(b). This regulation cannot be complied with due to there being no certification process in 

place for aircraft of this type. Global Positions, LLC will reach an equivalent level of 

safety by confirming that the Operator perform its responsibilities in accordance with the 

manufacturer’s instructions and recommendations, including, but not limited to, 

prescribed firmware and software updates, visual inspections of the equipment, and 

regular test flights and simulated flights.

14 CFR. 91.215: ATC transponder and altitude reporting equipment and use. Global 

Positions, LLC requests an exemption from 14 CFR. 91.215 as it is virtually not possible 

to comply with the requirement of this section at this time as sUASs are not equipped 

with radio equipment that can transmit electromagnetic signals produced by a 

transponder. Adding a third-party digital transponder would add an additional weight 

burden to the existing lightweight sUAS jeopardizing it’s flight performance and safety.

An equivalent level of safety will be achieve by Global Positions, LLC by limiting all 

sUAS flights to altitudes no greater than 400 feet AGL within class G airspace only. 

Additionally, flights will not be piloted within 5 nautical miles of an airport reference point 

as denoted on a current FAA-published aeronautical charts. These measures will 

diminish the risk of impact with another aircraft to a minor level.

14 CFR. 91.403: Aircraft must maintain it in an airworthy manner and any maintenance 

performed on an aircraft must be done in a manner consistent with Part 43 of Title 14 of 

the CFR. Global Positions, LLC requests an exemption from 14 CFR. 91.403. An 

equivalent level of safety and care will be attained by inspecting sUAS and testing sUAS 

after each and every repair, firmware update, or alteration by Global Positions, LLC or 

DJI, Inc. An equivalent level of safety will be obtained by Global Positions as the

Controller will pilot a test flight prior to each operation in order to confirm appropriate 

functioning of the flight operations.
Request for Exemption: Global Positions, LLC Page 17

14 CFR. 91.405: This regulation necessitates maintenance personnel to make repairs in 

accordance with Part 43 of Title 14 CFR. and to make entries in the maintenance 

records consequently. Global Positions, LLC requests an exemption from 14 CFR. 

91.405. These Regulations only apply to aircraft with an airworthiness certificate. They 

will not, therefore, apply to Global Positions, LLC sUAS. However, as a safety 

precaution Global Positions, LLC will inspect Global Positions, LLC sUAS before and 

after each flight. Standard industry standard and guidelines do not exist for sUAS; 

Manufactures provide suggestions as to when components of the aircraft be replaced 

based on usage, damage, and the number of hours of operation. Global Positions will 

inspect, on a regular basis, the four electric motors which power the propellers. Repairs

or replacements of said motors will be based on necessity, pre scheduled maintenance 

or on manufactures recommendations.

14 CFR. 91.407: This regulation provides, in part, that no one may operate an aircraft 

after maintenance has been conducted upon it, unless the maintenance was in 

conformity with Part 43 of Title 14 CFR. Global Positions, LLC requests an exemption to 

14 CFR. 91.407. An equivalent level of safety will be obtained by Global Positions

personnel as they will inspect the physical parts of the sUAS for wear, damage, 

malformations, and other defects prior to and after each flight. The self-diagnostic 

software of the sUAS will be used as an aid to determine flightworthiness as well 

resulting in an equivalent level of safety.

14 CFR. 91.409: This section provides detailed requirements for inspections of aircraft, 

including annual inspections for airworthiness certification. Global Positions, LLC 

requests an exemption from 14 CFR. 91.409. Although Global Positions, LLC strongly 

believes that airworthiness is critically important, the certification of this is largely 

unsuitable to sUASs given there are no standard or approved certification process in 

existence for sUASs. An equivalent level of safety will be obtained by Global Positions, 

LLC by performing inspections of the sUASs prior to and after each flight operation. 

Inspections of the sUASs will be much more frequent as compared to the interval of

inspections required by § 91.409.
Request for Exemption: Global Positions, LLC Page 18

14 CFR. 91.417: This section is only applicable for aircraft with an 

airworthiness certificate. Global Positions, LLC requests exemption from 14 CFR. 

91.417 because sUASs will not have airworthiness certificates. The FAA is authorized to 

exempt aircraft from the airworthiness certificate requirement under both the Act (49 

U.S.C. § 44701 (f)) and Section 333 of the Reform Act. Both pieces of legislation permit 

the FAA to exempt UAS's from the airworthiness certificate requirement in consideration 

of the weight, size, speed, maneuverability and proximity to areas such as airports and 

dense populations. An equivalent level of safety will be achieved by Global Positions, 

LLC by keeping maintenance records for its sUAS and following manufacture’s 

recommendations for service and repair.

14 CFR 61.195: Defines the requirements for flight instructors and states flight instructor 

limitations and qualifications. Global Positions, requests an exemption from 14 CFR 

61.195 because it is our understanding that none of the sUAS operations proposed by 

Global Positions, LLC require such flight instruction as § 61.31(l) permits operation of the 

UAS by an individual who is up-to-date per 14 CFR § 61.56 (Flight Review) without a 

category and class rating. Instruction provided toward obtaining the pilot certificate 

required by this exemption would need to be provided by a certificated flight instructor. 

Global Positions, LLC will reach an equivalent level of safety by reviewing and 

understanding maneuvers and procedures necessary for the pilot to demonstrate the 

safe exercise of sUAS flight. DJI’s flight simulator may be used to for flight review and 

training for performing practical flight tests and general procedural flight operations.

Conclusions: Currently, knowledge of geography, spatial awareness, aerial filming, 

aerial videography/photography, and data collection for mapping relies primarily on the 

use of larger aircraft running on combustible fuel. Because these aircraft are heavy and 

carry combustible fuel, they pose potential risk to the humans, other forms of life, and 

property.

Granting Global Positions, LLC request for exemption will reduce existing risk levels and 

thereby enhance safety. Global Positions, LLC sUAS does not contain potentially 

explosive fuel, is lighter, smaller, and more controllable than conventional fixed-wing

aircraft. There are no humans or animals on board Global Positions, LLC UAS and the 

likelihood of death or serious bodily injury is significantly diminished. Global Positions, 
Request for Exemption: Global Positions, LLC Page 19

LLC operation of its UAS, weighing less than 10 pounds and travelling at lower speeds 

within limited areas will deliver an equivalent level of safety as that attained under 

current FARs. The sUAS piloted by Global Positions, LLC will operate at lower altitudes 

and in controlled airspace therefore removing potential risk to the public. 

Global Positions, respectfully request the grant of an exemption allowing Global 

Positions, LLC to operate remote controlled UAS’s. Granting the requested exemption 

will benefit the public interest as a whole in many ways. Global Positions, LLC is willing 

to cooperate in sharing information and experiences to benefit the FAA.

Respectfully submitted,

Jere P Folgert 

Global Positions, LLC 

3215 Warbler Way, #5

Bozeman, MT 59718

(406) 580 1314

Jfolgert@GlobalPositions.com