U.S. Department of Transportation, Docket Operations 

West Building Ground Floor, Room w 12-140 

1200 New Jersey Avenue, S.E. 

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Washington, DC 20590 , .. ....._ r· .. .r~ r; 

Petition for Exemption Under 14 CFR 11.81 

to Allow Commercial Use of Unmanned Aircraft System 

October 23, 2015 

Petitioner: 

Steven Michael Rupp 

1150 Darlene Lane #332 

Eugene, OR 97401 

541-731-2171 

Email: flywithsteve@gmail.com 

Greetings, 

... l.~ 

This application is.substantially based on the FAA's findings in Exemption No. 11062 granted to 

Astraeus Aerial on September 25, 2014, and in .relian~;:~ on the analysis provided therein. 

1. Sections from which exemptions are sought: Application is hereby m,ade for exemption 

from: . , 

a. FAA Modernization an<;J Reform Act of 2012, PL112-95 F,EB. 14, 2012, Section 333 

b. 14 CFR Part 21, subpart H 

c .. 14 CFR Part 61.113(a) and (b) 

d. 14 CFR Part 91: 

i.. 91.103(b)(2} 

ii. 91.105 

iii. 91.109 

iv. 91.119 

v. 91.121 

vi. 91.151 

vii. 91.40~ 

viii. ~1.407 '. 

ix. 91.409···· 

X •. '91.417 

Relief sought: 

a. I, Steven M. Rupp wish to operate Unmanned Aircraft Systems for commercial purposes 

to include, (but not limited to); land survey!ng, photogramm~try,videography, 

photography, inspections and analyses. This relief is sought because commercial use of 

.UAS are currently prohibited by law unJess performed under an exemption. 

b. This exemption will cover any a,irframe that weighs less than 55 pounds, including 

payload and energy sources: . _ . . .. , . · 

i. MULTIROTOR service-drone G4 models 
ii. DJI Phantom and Inspire models 

iii. Altavian Nova models 

iv. Other models to be added by future amendment to this exemption. 

c. I wish to contract commercial services as an independent contractor and a qualified 

pilot, to operate UAS within limits of exemption 333. 

Public benefit: 

a. UAS technology to obtain imagery, information and data currently obtained by use of 

manned flight or manual methods: 

i. Reduces statistical risk to human life due to manned aircraft accidents, (e.g., 

powerline inspections) and due to other dangerous activities that can be 

avoided, (e.g., scaffolding/rigging failures during stack or bridge inspections). 

ii. Reduces the cost of obtaining such information, which benefits consumers and 

the economy. 

iii. Reduces environmental impact by eliminating sources of hydrocarbon emissions 

from manned aircraft. 

iv. Allows for companies to contract rather than having to employ a specific person 

within their company to perform work. 

Safety not adversely affected: 

a. I will only operate aircraft registered and marked in accordance with Section 44711 and 

Part 47 and part 45, subpart C. It will be my responsibility to ensure this before service is 

rendered as the pilot in command. 

b. Aircraft will comply with maintenance and inspection requirements of the 

manufacturer. All repair and maintenance work will be conducted or approved by 

qualified personnel. Records of all maintenance and repair work will be kept in a 

maintenance log for each aircraft. 

c. Operations will be conducted by Steven M. Rupp whom will maintain visual capability at 

all time during flight. 

i. I, Steven M. Rupp, Pilot In Command, possess the following credentials: 

1. An Airman Certificate issued under 14 CFR 61 (At least an Airline Transport 

Certificate) screened by TSA. 

2. A Second Class medical certificate issued under 14 CFR 67. 

3. A Bi-annual flight review under 14 CFR 61.56 

4. A completion of a course of instruction in safe UAS flying conducted by 

Unmanned Experts Inc. (or equivalent instruction). 

5. At least 200 cycles and 25 hours of flight experience in a UAS rotorcraft (or 

UAS fixed-wing in the case of fixed-wing flight operations under this 

exemption). Such cycles and hours may be gained during flights under this 

exemption if a safe distance is maintained from persons in accordance with 

14 CFR 91.119. 

6. At least 5 hours of flight experience and 3 takeoffs and landings in make and 

model being flown in the prior 90 days. Such cycles and hours may be gained 

during flights under this exemption if a safe distance is maintained from 

persons in accordance with 14 CFR 91.119. 
d. All flight operations will be conducted in accordance with valid Certificates of 

Authorization. 

e. All flight operations will comply with the following: 

i. The manufactures' Aircraft Flight Manuals and operation guidelines 

ii. Operations polices including lost communication and other emergency and 

safety procedures. 

iii. Conducted in VMC conditions during daylight hours 

iv. PIC will maintain VLOS at all times. 

v. Pre-flight inspections (including ground control station, if any} and safety risk 

assessments will be conducted prior to each flight. 

vi. Flight altitudes will remain below 400 AGL 

vii. Flight ground speeds will not exceed 50 knots. 

viii. Not intrude intoCiass B, C, or D airspace1 or published approach, SID or STAR, or 

· take place within 5 miles of an airport unless prior approval is issued by the 

respective controlling agency and a NOT AM has been issued. 

ix. Not be made near persons as required in CFR 91.119 and not over persons on 

the ground without their prior permission. 

x. Each flight will be logged in PIC's logbook and the aircraft logbook 

xi. Not exceed 75% of the battery or fuel capacity of the aircraft, or 30 minutes, 

whichever occurs first. 

xii. Any incidents will be reported within 24 hours of occurrence. 

xiii. Steven Rupp will maintain liability insurance of at least 1,000,000. 

xiv. Any applicable local FSDO requirements. 

xv. All other applicable regulations concerned with the operation of aircraft. 

Please advise me of any additional information or changes that are required. 

Sincerely, 

Steven Michael Rupp 

Certificate# 3127531 CFI/CFII/MEI/ATP l