August 24, 2015

Exemption No. 12580

Regulatory Docket No. FAA−2015−2366

Mr. Reed Frick

CEO

Griffin Aerial, LLC

182 West Rock Avenue

New Haven, CT 06515

Dear Mr. Frick:

This letter is to inform you that we have granted your request for exemption. It transmits our 

decision, explains its basis, and gives you the conditions and limitations of the exemption, 

including the date it ends.

By letter dated May 29, 2015, you petitioned the Federal Aviation Administration (FAA) on 

behalf of Griffin Aerial, LLC (hereinafter petitioner or operator) for an exemption. The 

petitioner requested to operate an unmanned aircraft system (UAS) to conduct aerial 

surveying, remote sensing, telecommunications, agriculture, aerial filmmaking and 

photography, energy systems inspections and asset management, construction site inspections 

and monitoring, wildlife and forestry monitoring, educational and research operations, 

pipeline inspection and patrolling.

See Appendix A for the petition submitted to the FAA describing the proposed operations and 

the regulations that the petitioner seeks an exemption.

The FAA has determined that good cause exists for not publishing a summary of the petition 

in the Federal Register because the requested exemption would not set a precedent, and any 

delay in acting on this petition would be detrimental to the petitioner.

Airworthiness Certification

The UAS proposed by the petitioner are the DJI S900, DJI S1000, 3D Robotics Iris +, 3D 

Robotics X8-M, 3D Robotics Aero-M, and 3D Robotics Solo.
2

In accordance with the statutory criteria provided in Section 333 of Public Law 112−95 in 

reference to 49 U.S.C. § 44704, and in consideration of the size, weight, speed, and limited 

operating area associated with the aircraft and its operation, the Secretary of Transportation 

has determined that this aircraft meets the conditions of Section 333. Therefore, the FAA 

finds that relief from 14 CFR part 21, Certification procedures for products and parts, 

Subpart H—Airworthiness Certificates, and any associated noise certification and testing 

requirements of part 36, is not necessary.

The Basis for Our Decision

You have requested to use a UAS for aerial data collection1. The FAA has issued grants of 

exemption in circumstances similar in all material respects to those presented in your petition. 

In Grants of Exemption Nos. 11062 to Astraeus Aerial (see Docket No. FAA−2014−0352), 

11109 to Clayco, Inc. (see Docket No. FAA−2014−0507), 11112 to VDOS Global, LLC (see

Docket No. FAA−2014−0382), and 11213 to Aeryon Labs, Inc. (see Docket No. 

FAA−2014−0642), the FAA found that the enhanced safety achieved using an unmanned 

aircraft (UA) with the specifications described by the petitioner and carrying no passengers or 

crew, rather than a manned aircraft of significantly greater proportions, carrying crew in 

addition to flammable fuel, gives the FAA good cause to find that the UAS operation enabled 

by this exemption is in the public interest.

Having reviewed your reasons for requesting an exemption, I find that—

 They are similar in all material respects to relief previously requested in Grant of 

Exemption Nos. 11062, 11109, 11112, and 11213;

 The reasons stated by the FAA for granting Exemption Nos. 11062, 11109, 11112, and 

11213 also apply to the situation you present; and 

 A grant of exemption is in the public interest.

Our Decision

In consideration of the foregoing, I find that a grant of exemption is in the public interest. 

Therefore, pursuant to the authority contained in 49 U.S.C. 106(f), 40113, and 44701, 

delegated to me by the Administrator, Griffin Aerial, LLC is granted an exemption from 

14 CFR §§ 61.23(a) and (c), 61.101(e)(4) and (5), 61.113(a), 61.315(a), 91.7(a), 91.119(c), 

91.121, 91.151(a)(1), 91.405(a), 91.407(a)(1), 91.409(a)(1) and (2), and 91.417(a) and (b), to 

the extent necessary to allow the petitioner to operate a UAS to perform aerial data collection. 

This exemption is subject to the conditions and limitations listed below.

 

1 Aerial data collection includes any remote sensing and measuring by an instrument(s) aboard the UA. 

Examples include imagery (photography, video, infrared, etc.), electronic measurement (precision surveying, RF 

analysis, etc.), chemical measurement (particulate measurement, etc.), or any other gathering of data by 

instruments aboard the UA.
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Conditions and Limitations

In this grant of exemption, Griffin Aerial, LLC is hereafter referred to as the operator.

Failure to comply with any of the conditions and limitations of this grant of exemption will be 

grounds for the immediate suspension or rescission of this exemption.

1. Operations authorized by this grant of exemption are limited to the DJI S900, DJI 

S1000, 3D Robotics Iris +, 3D Robotics X8-M, 3D Robotics Aero-M, and 3D 

Robotics Solo when weighing less than 55 pounds including payload. Proposed 

operations of any other aircraft will require a new petition or a petition to amend this 

exemption.

2. Operations for the purpose of closed-set motion picture and television filming are 

not permitted. 

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

exemption holder may use either groundspeed or calibrated airspeed to determine 

compliance with the 87 knot speed restriction. In no case will the UA be operated at 

airspeeds greater than the maximum UA operating airspeed recommended by the 

aircraft manufacturer.

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

(AGL). Altitude must be reported in feet AGL.

5. The UA must be operated within visual line of sight (VLOS) of the PIC at all times. 

This requires the PIC to be able to use human vision unaided by any device other than 

corrective lenses, as specified on the PIC’s FAA-issued airman medical certificate or 

U.S. driver’s license.

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

the visual line of sight (VLOS) of the PIC and VO at all times. The VO may be used 

to satisfy the VLOS requirement as long as the PIC always maintains VLOS 

capability. The VO and PIC must be able to communicate verbally at all times; 

electronic messaging or texting is not permitted during flight operations. The PIC 

must be designated before the flight and cannot transfer his or her designation for the 

duration of the flight. The PIC must ensure that the VO can perform the duties 

required of the VO.

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

operations in accordance with the conditions and limitations stated in this grant of 

exemption, are hereinafter referred to as the operating documents. The operating 

documents must be accessible during UAS operations and made available to the 
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Administrator upon request. If a discrepancy exists between the conditions and 

limitations in this exemption and the procedures outlined in the operating documents, 

the conditions and limitations herein take precedence and must be followed. 

Otherwise, the operator must follow the procedures as outlined in its operating 

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

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

documents to the Administrator or any law enforcement official upon request. The 

operator must also present updated and revised documents if it petitions for extension 

or amendment to this grant of exemption. If the operator determines that any update 

or revision would affect the basis upon which the FAA granted this exemption, then 

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

UAS Integration Office (AFS−80) may be contacted if questions arise regarding 

updates or revisions to the operating documents.

8. Any UAS that has undergone maintenance or alterations that affect the UAS operation 

or flight characteristics, e.g., replacement of a flight critical component, must undergo 

a functional test flight prior to conducting further operations under this exemption. 

Functional test flights may only be conducted by a PIC with a VO and must remain at 

least 500 feet from other people. The functional test flight must be conducted in such 

a manner so as to not pose an undue hazard to persons and property.

9. The operator is responsible for maintaining and inspecting the UAS to ensure that it is 

in a condition for safe operation.

10. Prior to each flight, the PIC must conduct a pre-flight inspection and determine the 

UAS is in a condition for safe flight. The pre-flight inspection must account for all 

potential discrepancies, e.g., inoperable components, items, or equipment. If the 

inspection reveals a condition that affects the safe operation of the UAS, the aircraft is 

prohibited from operating until the necessary maintenance has been performed and the 

UAS is found to be in a condition for safe flight.

11. The operator must follow the UAS manufacturer’s maintenance, overhaul, 

replacement, inspection, and life limit requirements for the aircraft and 

aircraft components.

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

safety bulletins.

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

commercial, private, recreational, or sport pilot certificate. The PIC must also hold a 

current FAA airman medical certificate or a valid U.S. driver’s license issued by a 

state, the District of Columbia, Puerto Rico, a territory, a possession, or the Federal 

government. The PIC must also meet the flight review requirements specified in 

14 CFR § 61.56 in an aircraft in which the PIC is rated on his or her pilot certificate.
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14. The operator may not permit any PIC to operate unless the PIC demonstrates the 

ability to safely operate the UAS in a manner consistent with how the UAS will be 

operated under this exemption, including evasive and emergency maneuvers and 

maintaining appropriate distances from persons, vessels, vehicles and structures. PIC 

qualification flight hours and currency must be logged in a manner consistent with 

14 CFR § 61.51(b). Flights for the purposes of training the operator’s PICs and VOs 

(training, proficiency, and experience-building) and determining the PIC’s ability to 

safely operate the UAS in a manner consistent with how the UAS will be operated 

under this exemption are permitted under the terms of this exemption. However, 

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

training, proficiency, and experience-building flights, all persons not essential for 

flight operations are considered nonparticipants, and the PIC must operate the UA 

with appropriate distance from nonparticipants in accordance with 14 CFR § 91.119.

15. UAS operations may not be conducted during night, as defined in 14 CFR § 1.1. All 

operations must be conducted under visual meteorological conditions (VMC). Flights 

under special visual flight rules (SVFR) are not authorized.

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

denoted in the current FAA Airport/Facility Directory (AFD) or for airports not 

denoted with an ARP, the center of the airport symbol as denoted on the current 

FAA-published aeronautical chart, unless a letter of agreement with that airport’s 

management is obtained or otherwise permitted by a COA issued to the exemption 

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

to the Administrator or any law enforcement official upon request.

17. The UA may not be operated less than 500 feet below or less than 2,000 feet 

horizontally from a cloud or when visibility is less than 3 statute miles from the PIC.

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

pre-determined location within the private or controlled-access property.

19. The PIC must abort the flight in the event of unpredicted obstacles or emergencies.

20. The PIC is prohibited from beginning a flight unless (considering wind and forecast 

weather conditions) there is enough available power for the UA to conduct the 

intended operation and to operate after that for at least five minutes or with the reserve 

power recommended by the manufacturer if greater.

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

operations shall be conducted in accordance with an ATO-issued COA. The 

exemption holder may apply for a new or amended COA if it intends to conduct 

operations that cannot be conducted under the terms of the attached COA.
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22. All aircraft operated in accordance with this exemption must be identified by serial 

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

(N−Number) markings in accordance with 14 CFR part 45, Subpart C. Markings must 

be as large as practicable.

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

any documents required under 14 CFR §§ 91.9 and 91.203 must be available to the 

PIC at the Ground Control Station of the UAS any time the aircraft is operating. 

These documents must be made available to the Administrator or any law enforcement 

official upon request.

24. The UA must remain clear and give way to all manned aviation operations and 

activities at all times. 

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

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

persons, vessels, vehicles, and structures unless:

a. Barriers or structures are present that sufficiently protect nonparticipating persons 

from the UA and/or debris in the event of an accident. The operator must ensure 

that nonparticipating persons remain under such protection. If a situation arises 

where nonparticipating persons leave such protection and are within 500 feet of 

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

of nonparticipating persons; and

b. The owner/controller of any vessels, vehicles or structures has granted permission 

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

the risk of operating closer to those objects and determined that it does not 

present an undue hazard.

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

nonparticipating persons under this exemption.

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

permission from the property owner/controller or authorized representative. 

Permission from property owner/controller or authorized representative will be 

obtained for each flight to be conducted.

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

boundaries of the operational area as defined by the applicable COA must be reported 

to the FAA's UAS Integration Office (AFS−80) within 24 hours. Accidents must be 

reported to the National Transportation Safety Board (NTSB) per instructions 

contained on the NTSB Web site: www.ntsb.gov.
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If this exemption permits operations for the purpose of closed-set motion picture and 

television filming and production, the following additional conditions and limitations apply.

29. The operator must have a motion picture and television operations manual (MPTOM) 

as documented in this grant of exemption.

30. At least 3 days before aerial filming, the operator of the UAS affected by this 

exemption must submit a written Plan of Activities to the local Flight Standards 

District Office (FSDO) with jurisdiction over the area of proposed filming. The 3-day 

notification may be waived with the concurrence of the FSDO. The plan of activities 

must include at least the following:

a. Dates and times for all flights;

b. Name and phone number of the operator for the UAS aerial filming conducted 

under this grant of exemption;

c. Name and phone number of the person responsible for the on-scene operation of 

the UAS;

d. Make, model, and serial or N−Number of UAS to be used;

e. Name and certificate number of UAS PICs involved in the aerial filming;

f. A statement that the operator has obtained permission from property owners 

and/or local officials to conduct the filming production event; the list of those 

who gave permission must be made available to the inspector upon request;

g. Signature of exemption holder or representative; and

h. A description of the flight activity, including maps or diagrams of any area, city, 

town, county, and/or state over which filming will be conducted and the altitudes 

essential to accomplish the operation.

31. Flight operations may be conducted closer than 500 feet from participating persons 

consenting to be involved and necessary for the filming production, as specified in the 

exemption holder’s MPTOM.

Unless otherwise specified in this grant of exemption, the UAS, the UAS PIC, and the UAS 

operations must comply with all applicable parts of 14 CFR including, but not limited to, 

parts 45, 47, 61, and 91.
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This exemption terminates on August 31, 2017, unless sooner superseded or rescinded.

Sincerely,

/s/

John S. Duncan

Director, Flight Standards Service

Enclosures
U.S. Department of Transportation May 29, 2015

Docket Management System

1200 New Jersey Ave., SE

Washington, DC 20590

Griffin Aerial, LLC

Section 333 Petition to Operate Small Unmanned Aerial Systems

Prepared by:

Reed Frick

CEO Griffin Aerial, LLC

182 W Rock Ave

New Haven, CT 06515

978-994-5448

reed.frick@gmail.com
Petition Summary:

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012, Pub. L. No. 112-95

(2012), 126 Stat. 11 (“Section 333”) and the Federal Aviation Administration’s (“FAA”) general

exemption authority under 49 U.S.C. section 44701(f), Griffin Aerial, LLC (“Petitioner”) hereby 

petitions for exemptions from 14 C.F.R Part 21, Subpart H (Airworthiness Certificates), 14 

C.F.R. Part 27 (Airworthiness Standards: Normal Category Rotorcraft), 14 C.F.R sections 

61.113(a)-(b), 91.103(b)(1), 91.119(c), 91.121, 91.151, 91.405(a), 91.407(a)(1), 91.409(a)(2), and 

91.417(a)-(b).

The proposed exemption, if granted, would allow Petitioner to conduct commercial operations of

small unmanned aircraft systems (“UAS”) meeting or exceeding all of the operational and safety

requirements Congress has set forth in Section 333.

Petitioner is an aerial service and technology company that plans to exploit the capabilities of 

Unmanned Aerial Systems to offer a multitude of services, including:

- Aerial surveying

- Remote sensing

- Telecommunications

- Agriculture

- Aerial filmmaking and photography

- Energy systems inspections and asset management

- Construction site inspections and monitoring

- Wildlife and forestry monitoring

- Educational and research operations

- Pipeline inspection and patrolling

Statutory Authority

Section 333, titled “Special Rules for Certain Unmanned Aircraft Systems”, provides a

mechanism for seeking expedited FAA authorization of safe civil UAS operations in the NAS.

Section 333(a) states that the FAA “shall determine if certain unmanned aircraft systems may

operate safely in the national airspace system before completion of the (comprehensive) plan and 

rulemaking required by section 332(b)(1) of this Act or the guidance required by section 334 of 

this Act.” In Section 332(b)(1), Congress made it clear that Section 333 provides a mechanism for 

“expedited operation authorization” if several factors are met. Petitioner meets all requirements to 

permit FAA approval of commercial UAS operations.

The Petitioner Requests Relief From the Following:

Section 61.113(a) and (b) prescribes that—

(a) no person who holds a private pilot certificate may act as a pilot in command of an aircraft 

that is carrying passengers or property for compensation or hire; nor may that person, for 

compensation or hire, act as pilot in command of an aircraft.

(b) a private pilot may, for compensation or hire, act as pilot in command of an aircraft in

connection with any business or employment if:

(1) The flight is only incidental to that business or employment; and

(2) The aircraft does not carry passengers or property for compensation or hire.
Section 91.103 prescribes, in pertinent part, that each pilot in command shall, before beginning a 

flight, become familiar with all available information concerning that flight, to include—

(a) For a flight under IFR or a flight not in the vicinity of an airport, weather reports and

forecasts, fuel requirements, alternatives available if the planned flight cannot be completed, and 

any known traffic delays of which the pilot in command has been advised by ATC;

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

landing distance information:

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

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

therein;

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

information appropriate to the aircraft, relating to aircraft performance under expected values of 

airport elevation and runway slope, aircraft gross weight, and wind and temperature.

Section 91.119 prescribes that, except when necessary for takeoff or landing, no person may

operate an aircraft below the following altitudes:

(a) Anywhere. An altitude allowing, if a power unit fails, an emergency landing without undue 

hazard to persons or property on the surface.

(b) Over congested areas. Over any congested area of a city, town, or settlement, or over any 

open air assembly of persons, an altitude of 1,000 feet above the highest obstacle within a 

horizontal radius of 2,000 feet of the aircraft.

(c) Over other than congested areas. An altitude of 500 feet above the surface, except over open 

water or sparsely populated areas. In those cases, the aircraft may not be operated closer than 500 

feet to any person, vessel, vehicle, or structure.

(d) Helicopters, powered parachutes, and weight-shift-control aircraft. If the operation is

conducted without hazard to persons or property on the surface—

(1) A helicopter may be operated at less than the minimums prescribed in paragraph (b) or (c) of 

this section, provided each person operating the helicopter complies with any routes or altitudes 

specifically prescribed for helicopters by the FAA; and

(2) A powered parachute or weight-shift-control aircraft may be operated at less than the 

minimums prescribed in paragraph (c) of this section.

Section 91.121 requires, in pertinent part, 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.”

Section 91.151(a) prescribes that no person may begin a flight in an airplane under VFR

conditions unless (considering wind and forecast weather conditions) there is enough fuel to fly to 

the first point of intended landing and, assuming normal cruising speed, (1) during the day, to fly 

after that for at least 30 minutes; or (2) At night, to fly after that for at least 45 minutes.

[emphasis added]

Section 91.405(a) requires, in pertinent part, that an aircraft operator or owner shall have that

aircraft inspected as prescribed in subpart E of the same part and shall, between required

inspections, except as provided in paragraph (c) of the same section, have discrepancies repaired 

as prescribed in part 43 of the chapter.

Section 91.407(a)(1) prohibits, in pertinent part, any person from operating an aircraft that has

undergone maintenance, preventive maintenance, rebuilding, or alteration unless it has been

approved for return to service by a person authorized under § 43.7 of the same chapter.
Section 91.409(a)(2) prescribes, in pertinent part, that no person may operate an aircraft unless,

within the preceding 12 calendar months, it has had an inspection for the issuance of an

airworthiness certificate in accordance with part 21 of this chapter.

Section 91.417(a) and (b) prescribes, in pertinent part, that—

(a) Each registered owner or operator shall keep the following records for the periods specified in 

paragraph (b) of this section:

(1) Records of the maintenance, preventive maintenance, and alteration and records of the 100-

hour, annual, progressive, and other required or approved inspections, as appropriate, for each 

aircraft (including the airframe) and each engine, propeller, rotor, and appliance of an aircraft. 

The records must include—

(i) A description (or reference to data acceptable to the Administrator) of the work performed; 

and

(ii) The date of completion of the work performed; and

(iii) The signature, and certificate number of the person approving the aircraft for return to 

service.

(2) Records containing the following information:

(i) The total time in service of the airframe, each engine, each propeller, and each rotor.

(ii) The current status of life-limited parts of each airframe, engine, propeller, rotor, and 

appliance.

(iii) The time since last overhaul of all items installed on the aircraft which are required to be 

overhauled on a specified time basis.

(iv) The current inspection status of the aircraft, including the time since the last inspection 

required by the inspection program under which the aircraft and its appliances are maintained.

(v) The current status of applicable airworthiness directives (AD) and safety directives including, 

for each, the method of compliance, the AD or safety directive number and revision date. If the 

AD or safety directive involves recurring action, the time and date when the next action is 

required.

(vi) Copies of the forms prescribed by § 43.9(d) of this chapter for each major alteration to the 

airframe and currently installed engines, rotors, propellers, and appliances.

(b) The owner or operator shall retain the following records for the periods prescribed:

(1) The records specified in paragraph (a)(1) of this section shall be retained until the work is 

repeated or superseded by other work or for 1 year after the work is performed.

(2) The records specified in paragraph (a)(2) of this section shall be retained and transferred with 

the aircraft at the time the aircraft is sold.

(3) A list of defects furnished to a registered owner or operator under § 43.11 of this chapter shall

be retained until the defects are repaired and the aircraft is approved for return to service.

The Petitioner has supplied the Following Additional Information:

DJI S900 Pilot Operating Handbook (POH) and S900 User Manual (linked as file is too large to 

submit online): http://www.dji.com/product/spreading-wings-s900/download

DJI S1000 Pilot Operating Handbook (POH) and S1000 User Manual

3D Robotics Iris + Operation Manual and Flight Checklist

3D Robotics X8-M Operation Manual and Flight Checklist

3D Robotics Aero-M Operation Manual found here (linked as file is too large to submit online): 

http://3drobotics.com/wp-content/uploads/2015/04/AeroM-Operation-Manual-v3.pdf
Unmanned Aircraft Systems requested to operate under this request:

DJI S900

DJI S1000

3D Robotics Iris +

3D Robotics X8-M

3D Robotics Aero-M

The petitioner states that the unmanned aircraft (UA) to be operated under this request are less

than 55 lbs. fully loaded, fly at a speed of no more than 50 knots, carry neither a pilot nor

passenger, carry no explosive materials or flammable liquid fuels, and operate exclusively within 

a secured area as set out in the POHs. 

The S900 is a six-rotor manufactured by DJI. The VTOL hexarotor-type design has six motors, 

GPS, full autonomous autopilot capabilities, telemetry and manual ground control. In addition, 

the craft has integrated safety features built into the design of the UAS, as described in the POH, 

to ensure the safety of persons and property within and surrounding the limited operating area. 

The petitioner further describes that, in the event the UAS loses communications or its GPS 

signal, the UA will have the capability to return to a pre-determined location within the Security 

Perimeter and land. It will also have the capability to abort a flight in the event of unpredicted 

obstacles or emergencies.

The S1000 is an eight-rotor manufactured by DJI. The VTOL octarotor-type design has eight

motors, GPS, full autonomous autopilot capabilities, telemetry and manual ground control. In 

addition, the craft has integrated safety features built into the design of the UAS, as described in 

the POH, to ensure the safety of persons and property within and surrounding the limited 

operating area. The petitioner further describes that, in the event the UAS loses communications 

or its GPS signal, the UA will have the capability to return to a pre-determined location within the 

Security Perimeter and land. It will also have the capability to abort a flight in the event of 

unpredicted obstacles or emergencies.

The Iris + is a four-rotor manufactured by 3D Robotics. The VTOL quadrotor-type design has 

four motors, GPS, full autonomous autopilot capabilities, telemetry and manual ground control. 

In addition, the craft has integrated safety features built into the design of the UAS, as described 

in the POH, to ensure the safety of persons and property within and surrounding the limited 

operating area. The petitioner further describes that, in the event the UAS loses communications 

or its GPS signal, the UA will have the capability to return to a pre-determined location within the 

Security Perimeter and land. It will also have the capability to abort a flight in the event of 

unpredicted obstacles or emergencies.

The X8-M is a four-rotor manufactured by 3D Robotics. The VTOL quadrotor-type design has 

eight motors, GPS, full autonomous autopilot capabilities, telemetry and manual ground control. 

In addition, the craft has integrated safety features built into the design of the UAS, as described 

in the POH, to ensure the safety of persons and property within and surrounding the limited 

operating area. The petitioner further describes that, in the event the UAS loses communications 

or its GPS signal, the UA will have the capability to return to a pre-determined location within the 

Security Perimeter and land. It will also have the capability to abort a flight in the event of 
unpredicted obstacles or emergencies.

The Aero-M is a single motor fixed wing manufactured by 3D Robotics. The fixed wing has one 

motor, GPS, full autonomous autopilot capabilities, telemetry and manual ground control. In 

addition, the craft has integrated safety features built into the design of the UAS, as described in 

the POH, to ensure the safety of persons and property within and surrounding the limited 

operating area. The petitioner further describes that, in the event the UAS loses communications 

or its GPS signal, the UA will have the capability to return to a pre-determined location within the 

Security Perimeter and land. It will also have the capability to abort a flight in the event of 

unpredicted obstacles or emergencies.

Petitioner’s UAS will be identified by serial number, registered in accordance with 14 C.F.R. Part

47, and have identification (N-Number) markings in accordance with 14 C.F.R. Part 45, Subpart

C. Markings will be as large as practicable.

Pre-flight Inspection, Maintenance

Before each flight the PIC will perform a series of pre-flight and takeoff checks as defined by the

POH supplied. After each 60 minutes of airtime, the craft will undergo a thorough inspection of

all aircraft components, including, but not limited to:

a. Actuators / Servos

b. Motors, wiring and connectors

c. Propellers, smooth, no chips

d. Electronic speed controller, wiring and connectors

e. Batteries, wiring and connectors

f. Remote command and control

g. Ground control station

UAS Operating Parameters

The petitioner states that all flights will be operated within visual line of sight (VLOS) of pilot, in

daytime VFR flight conditions and all operations will be conducted with the assistance of a

second spotter/observer. The UAS flights will be limited to a maximum altitude of 400 feet AGL.

Altitude is accurately measured by GPS. The petitioner further states that an operator will ensure 

that only consenting production personnel will be allowed within 100 feet of the UA operation, 

and UAS will be kept at least 100’ from any inhabited structure. Generally the petitioner’s UAS 

will be operated in rural or suburban areas that will permit significantly larger safety zones.

Flight Standards District Offices (FSDOs) will be notified as required prior to operations to

describe intended coordination for proposed operation(s). Petitioner will obtain an Air Traffic

Organization (“ATO”) issued Certificate of Waiver or Authorization (“COA”) prior to 

conducting any operations under this grant of exemption. In fulfilling its requirements under the 

COA, Petitioner will be required to request a NOTAM not more than 72 hours in advance, but not 

less than 48 hours prior to the operation.

Petitioner’s UAS will remain clear and yield the right of way to all manned operations and

activities at all times (including, but not limited to, ultralight vehicles, parachute activities,

parasailing activities, and hangliders). Petitioner will not conduct UAS operations within 5

nautical miles of the geographic center of a non-towered airport unless a letter of agreement with 

that airport’s management is obtained and the operation is conducted in accordance with a

Notice to Airmen (“NOTAM”).
Pilot in Command (PIC)

The pilot in command will be Griffin Aerial’s CEO, Reed Frick. Mr. Frick received his airman’s

Private Certificate in 2007, number 3239456, and has logged over 70 hours in single engine

aircraft. He is a holder of a valid driver’s license, CT License number 058791058, Expiring 

05/19/2017. In addition to PIC experience in manned aircraft, Mr. Frick has approximately 12 

years of experience with R/C fixed wing and rotor wing aircraft.

Regarding Petitioner’s requested relief from 14 C.F.R. § 91.103(b)(1), Petitioner will comply 

with the other applicable procedures and requirements stated in § 91.103(a) and (b). Specifically, 

the PIC will take all actions including reviewing weather, flight battery requirements, aircraft

performance data, and landing and takeoff distances before initiation of a flight. The PIC will also 

account for all relevant site-specific conditions in their preflight procedures. Risks presented by 

sun glare will be mitigated by the PIC’s and VO’s ability to see other air traffic and initiate a 

return-to-home sequence if needed.

Radio Frequencies

Radio frequencies used will be those allotted by the FCC for data transmission and vehicle

control in unlicensed frequency bands. All devices used will comply with FCC usage and

emissions regulations.

Safety and Benefits of the UAS

The petitioner will be using the UAS in a variety of applications that generally require expensive

full-size manned aircraft to complete. Small, light, unmanned aerial vehicles offer a myriad of 

benefits over the use of full-sized manned aircraft for electric power line inspection, oil/gas

pipeline inspection, advanced agriculture, film and still photography, just to name a few.

Replacing significantly larger manned aircraft carrying crew and flammable fuel with small UAS

carrying no passengers or crew creates a much greater margin of safety for the pilots and crew.

By granting Petitioner’s requested exemptions, the FAA will help drive development of safe and

successful commercial UAS operations and will advance the public knowledge base for such

operations. Petitioner is committed to promoting the UAS research efforts of policymakers

including the FAA, NASA, DOD and DARPA by sharing data from its commercial UAS

operations and serving as a resource for future UAS research operations. Thus, the FAA has good 

cause to grant this Petition.

Conclusion

For the foregoing reasons, the exemptions requested herein should be granted and Petitioner

should be permitted to conduct small UAS operations in accordance with its manuals and all

other operating parameters deemed necessary and appropriate by the FAA.