January 8, 2015

U.S. Department of Transportation

Docket Operations

West Building Ground Floor, Room 

w12-140

1200 New Jersey Ave. SE

Washington, DC 20590

Exemption Request Section 333 of the FAA Reform Act and Part 11 of the Federal Aviation Regulations from 14 

CFR 45.23(b); 14 CFR Part 21; CFR 61.113 (a) & (b); 91.7 (a); 91.9 (b) (2); 91.103 (b); 91.109.119; 91.121; 91.151 

(a); 91.203 (a) & (b); 91.405 (a); 91.407 
Corporate Headquarters 4900 Seminary Road, Ste. 1200 | Alexandria, Virginia 22311 | 703.578.5566

Western Regional Office 777 Rainbow Blvd., Ste. 380 | Las Vegas, Nevada 89107 | 702.816.5087

ArrowData is a subsidiary within the UIC Government Services Division 

of the Ukpeaġvik Iñupiat Corporation, an Alaska Native Corporation.

January 8, 2015

U.S. Department of Transportation

Docket Operations

West Building Ground Floor, Room w12-140

1200 New Jersey Ave. SE

Washington, DC 20590

Re: Exemption Request Section 333 of the FAA Reform Act and Part 11 of the Federal 

Aviation Regulations from 14 CFR 45.23(b); 14 CFR Part 21; CFR 61.113 (a) & (b); 91.7 (a); 

91.9 (b) (2); 91.103 (b); 91.109.119; 91.121; 91.151 (a); 91.203 (a) & (b); 91.405 (a); 91.407 

INTRODUCTION

Pursuant to Section 333 of the FAA Modernizations and Reform Act of 2012 and 14 CFR Part 11, 

ArrowData, LLC, operator of Small Unmanned Aircraft Systems (“sUASs”) equipped to conduct aerial 

photography for KLAS-TV for the purpose of electronic news gathering in Las Vegas, NV, hereby applies 

for an exemption from the listed Federal Aviation Regulations (“FARs”) to allow commercial operation of 

sUASs under the conditions outlined here or modified by the FAA.

In the detailed explanation to follow, the series of exemptions being requested would allow 

operation of the commercially procured, off-the-shelf Cinestar 8 Okto XL, an eight engine and blade, 

light weight, relatively slow (<50 knots) unmanned rotary aircraft (or like platform) in and around the 

city of Las Vegas during active news, traffic and weather events using very controlled conditions and 

operational procedures to provide robust safety buffers both vertically and horizontally to ensure 

personnel and property safety. These flights would only fly within 150 feet of the control vehicle with a 

dismounted pilot and safety team using an auto-pilot system that would control speed, vectoring and 

hovering. At no time would the vehicle fly directly over locally assembled crowds or over any ongoing 

fires or crime scenes. The launch and recovery point would be cordoned off by the safety team in 

coordination with law enforcement and/or first response units. Approval of this exemption would help 

to prove the safe concept of UAS activity while conducting electronic news gather (ENG) during active 

news, weather or traffic events in a major metropolitan environment with safety controls to provide 

proactive risk management that is technically within the National Airspace System, but realistically 

segregated well below any other air traffic and well clear of the McCarran Class B airspace (beneath the 

lateral confines). ArrowData, LLC is a partner with Bowhead Business and Technology Solutions who is 

currently providing contract support as the PMO to one of the six FAA approved commercial UAS test 

ranges operated by the Nevada Institute for Autonomous Systems (NIAS). The composition of this team 

is unparalleled in the unmanned aviation industry, uniquely qualified to leverage the collective

capabilities of UAS operations, FAA approved range testing and Analytical Risk Management. This 

exemption application will be accompanied with an Operations Plan, Maintenance Plan, and Risk 

Assessment that will depict all contingencies.
Corporate Headquarters 4900 Seminary Road, Ste. 1200 | Alexandria, Virginia 22311 | 703.578.5566

Western Regional Office 777 Rainbow Blvd., Ste. 380 | Las Vegas, Nevada 89107 | 702.816.5087

ArrowData is a subsidiary within the UIC Government Services Division 

of the Ukpeaġvik Iñupiat Corporation, an Alaska Native Corporation.

The following is contact information for the applicant:

ArrowData, LLC.

777 N. Rainbow Boulevard, Suite 380

Las Vegas, NV 89107

Attn: Michael Bradshaw

Tel: 702-816-5088

EXEMPTIONS (Regulations from which the exemption is requested)

 14 CFR Part 21, Subpart H– Airworthiness Certificates

 14 CFR 45.23 (b), , 

o Aircraft Marking

o Certification and Registration

 14 CFR 61.113 (a) & (b)

o Pilot in Command

 14 CFR 91.7 (a)

o Civil aircraft airworthiness

 14 CFR 91.9 (b) (2)

o Document/Flight Manuals

 14 CFR 91.103 (b)

o Preflight action

 14 CFR 109

o Flight instruction

 14 CFR 91.113

o Right-of-way rules

 14 CFR 91.119

o Minimum safe altitude

 14 CFR 91.121

o Altimeter setting

 14 CFR 91.131 (a) (1) (c) (2) (d) (1)

o Operations in Class B airspace

 14 CFR 91.145 (b)

o Management of aircraft operations in the vicinity of aerial demonstrations and 

major sporting events.

 14 CFR 91.151 

o Fuel requirements for VFR flight

 14 CFR 91.203 (a) & (b)

o Civil Aircraft: Certifications required

 14 CFR 91.405 (a); 407 (a) (1); 409 (a); 417 (a) & (b)
Corporate Headquarters 4900 Seminary Road, Ste. 1200 | Alexandria, Virginia 22311 | 703.578.5566

Western Regional Office 777 Rainbow Blvd., Ste. 380 | Las Vegas, Nevada 89107 | 702.816.5087

ArrowData is a subsidiary within the UIC Government Services Division 

of the Ukpeaġvik Iñupiat Corporation, an Alaska Native Corporation.

o Maintenance and maintenance inspections

 14 CFR 407 

o Operation after Maintenance, preventive maintenance, rebuilding and 

inspections 

 14 CFR 409

o Inspections

 14 CFR 417

o Maintenance records

 NOTAM 9/5151

o Flying Around Sporting Events

AIRCRAFT OPERATIONS AND EQUIVALENT LEVEL OF SAFETY

Section 333 refers to exemptions for sUASs for commercial operations. Those operations could include a 

vast array of events such as electronic news gathering (ENG). Much like the movie industry, aerial news 

and traffic/weather information gathering is both useful and entertaining to the general public. The 

quick deployment and less restrictive weather constraints will create a safer environment, while 

delivering a superior and timelier product to the general public, providing near real time information for 

traffic, severe weather and crime scene avoidance considerations. 

The sUAS aircraft to be employed by ArrowData, LLC has a number of safety features that make it ideal 

for use in this environment. The state of the art Cinestar 8 Okto XL with dual 21,000 mAh, 22.2 volt 

battery technology and the ability to fly with two engines inoperable. It is well under 55 pounds with a 

top speed of approximately 50 knots. Additionally, there is redundancy in the power system to the data 

link, motherboard, and wireless communications within the sUAS team operating the system. The 

mobile vehicle to be used with the UAS is already fitted with redundant power sources for satellite and 

camera operations and would be available to the UAS safety team as well. The aircraft would be 

employed utilizing Line-of Sight (LOS) operations not to exceed 150 and launched from a sterile area 

created upon arrival at the news event by the safety team in coordination with local law enforcement 

and first responders. Any vertical obstructions would be noted upon arrival and the pilot and safety 

team would ensure operations remained well clear of those obstructions. The pilot would launch the 

aircraft and navigate to an acceptably safe hover point at which time a waypoint would be designated 

and the auto-pilot would be engaged in an auto-hover mode while filming commences. A loss of 

communication “return to base” fail-safe system is integrated as well. The battery life is approximately 

45 minutes with a planned flight time of not more than 25 minutes. ArrowData, LLC will file a FAA Form 

7711-1 or any such form deemed appropriate with the local Flight Standards District Office (FSDO). 

Additionally, an Operations Plan would be submitted on a mutually agreed periodical basis to the FSDO.

All sUAS pilots being employed by ArrowData, LLC for this mission will have a FAA Commercial Pilot 

Certificate with Instrument Rating and a second class FAA medical certificate with additional experience 

in unmanned aircraft operations. Pilots will be required to have a minimum of 200 hours of manned 

flight time and 500 hours of unmanned flight time. The team composition will consist of a minimum of 
Corporate Headquarters 4900 Seminary Road, Ste. 1200 | Alexandria, Virginia 22311 | 703.578.5566

Western Regional Office 777 Rainbow Blvd., Ste. 380 | Las Vegas, Nevada 89107 | 702.816.5087

ArrowData is a subsidiary within the UIC Government Services Division 

of the Ukpeaġvik Iñupiat Corporation, an Alaska Native Corporation.

one pilot, one camera operator and one Safety Observer during all mobile news events, giving 

redundancy to the human element as well. Pilots will be well trained in areas of both normal and 

abnormal operations equipped with checklists and operations and maintenance manuals to be able to 

contend with any scenario. After extensive range testing and pilot training, the sUAS team will perform 

“dry-runs” to simulate and practice actual news events and situations. Additionally, a simulation 

evaluation will be completed by using the Monte Carlo modeling program. This program simulates 

10,000 flights and provides a failure expectation value. To help prepare for actual flight and news 

gathering with a UAS, the team would deploy with the mobile news team and observe conditions and 

scenarios where future operations might take place. This would give the team a feel for the “cadence” 

of an active news event to allow them to be able to plan timing and coordination issues. Unlike other 

uses for sUASs, these flights would be mostly shorter in length, obviating the need for a backup pilot. 

The designated Safety Observer would help to provide greater situational awareness for the team in 

order maintain alertness and vigilance at all times. A radio frequency spectrum assessment will be 

conducted before the first operational mission. Additionally, an environmental assessment will be 

performed to measure such parameters as noise and hazardous material concerns.

14 CFR Part 21, Subpart H– Airworthiness Certificates 14 CFR 91.203 (a) (1)

Subpart H (Airworthiness Certificates) defines the requirements for airworthiness certificate 

issuance IAW FAR 91.203 (a) (1). Existing law (49 USC 44701 (f)), Part 11 and Section 333 allow the FAA 

to exempt aircraft from the requirements of an airworthiness certificate upon consideration of the size, 

weight, speed, operational capability and proximity to airports and populated areas of the identified 

sUAS. Unlike a manned helicopter, the sUAS being employed is lightweight, has no flammable fuel or 

other lubricants, operates at very slow speeds and stays well below any conflicting air traffic thereby 

providing, an equivalent level of safety when compared to currently employed manned aircraft.

The proposed sUAS to be employed is under 55 lbs. when outfitted with all equipment and 

batteries. There are no flammable liquids or other hazardous materials that would propose a danger to 

the public or event participants. Accordingly, no threat to national security exists due to the inability of 

carriage of any external stores or ordnance. Additionally, there is exhaustive vetting of team personnel, 

most of whom possess a current or recent DoD/government security clearance. All activities will be 

closely monitored by a team of aviation professionals and using a system with redundancies in all areas. 

14 CFR 45.23 (b) Display of Marks; general

CFR 45.23 states:

When marks include only the Roman capital letter “N” and the registration number is 

displayed on limited, restricted or light-sport category aircraft or experimental or provisionally 
Corporate Headquarters 4900 Seminary Road, Ste. 1200 | Alexandria, Virginia 22311 | 703.578.5566

Western Regional Office 777 Rainbow Blvd., Ste. 380 | Las Vegas, Nevada 89107 | 702.816.5087

ArrowData is a subsidiary within the UIC Government Services Division 

of the Ukpeaġvik Iñupiat Corporation, an Alaska Native Corporation.

certificated aircraft, the operator must also display on that aircraft near each entrance to the cabin, 

cockpit, or pilot station, in letters not less than 2 inches nor more than 6 inches high, the words 

“limited,” “restricted,” “light-sport,” “experimental,” or “provisional,” as applicable.

An exemption to this section is needed due to the lack of a cabin, cockpit or pilot station where 

any reference to the term “Experimental” could be affixed. Accordingly, the wording will be placed on 

the fuselage. This equivalent level of safety will allow the team to clearly see “Experimental.” Previous 

precedence exists within Exemptions 10700, 10167, and 10167A.

CFR 61.113 (a) & (b) Private Pilot Privileges and Limitations: Pilot in Command

CFR 61.113 (a) & (b) states:

(a) Except as provided in paragraphs (b) through (h) of this section, no person who holds a 

private pilot certificate may act as 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.

To reach an equivalent level of safety, the self-imposed experience and training requirements 

would more than offset any risk introduced by using private pilots to fly an unmanned aircraft in very 

restricted and controlled areas.

CFR 91.7 (a) Civil aircraft worthiness

CFR 91.7 (a) states:

No person may operate a civil aircraft unless it is in an airworthy condition.

Assuming no airworthiness certificate will be required due to relief from Subpart H, no 

regulatory standard exists for determining airworthiness. The equivalent level of safety will be achieved 

through the employment of flight manual and maintenance manual procedures, pilot training and 

analytical risk management for each event.
Corporate Headquarters 4900 Seminary Road, Ste. 1200 | Alexandria, Virginia 22311 | 703.578.5566

Western Regional Office 777 Rainbow Blvd., Ste. 380 | Las Vegas, Nevada 89107 | 702.816.5087

ArrowData is a subsidiary within the UIC Government Services Division 

of the Ukpeaġvik Iñupiat Corporation, an Alaska Native Corporation.

CFR 91.9 (b) (2) Civil Aircraft Flight Manual in the Aircraft

CFR 91.9 (b) (2) states:

No person may operate a U.S.-registered civil aircraft—

For which an Airplane or Rotorcraft Flight Manual is not required by § 21.5 of this 

chapter, unless there is available in the aircraft a current approved Airplane or Rotorcraft Flight Manual, 

approved manual material, markings, and placards, or any combination thereof.

Given the size of the sUAS being utilized in this endeavor, there is no room onboard for an 

aircraft flight manual.

The equivalent level of safety will be achieved by keeping the flight manual with the pilot/team 

on the ground with easy access. Previous precedence is resident in Exemptions 8607, 8737, f8738, 9299, 

9299A, 9565, 9565B, 10167, 10167A, 10602, f32827, and 10700.

CFR 91.103 (b) Preflight action

CFR 91.103 (b) states:

Each pilot in command shall, before beginning a flight, become familiar with all available 

information concerning that flight. This information must include—

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

landing distance information:

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

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

and

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

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

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

This regulation dictates that a pilot conduct preflight activities. Without an FAA approved flight 

manual, relief is required from this regulation. Extensive pre-flight planning will provide an equivalent 

level of safety by using the operations plan, aircraft flight manual, maintenance manual and available 

weather and NOTAM information.

CFR 91.109 Flight instruction
Corporate Headquarters 4900 Seminary Road, Ste. 1200 | Alexandria, Virginia 22311 | 703.578.5566

Western Regional Office 777 Rainbow Blvd., Ste. 380 | Las Vegas, Nevada 89107 | 702.816.5087

ArrowData is a subsidiary within the UIC Government Services Division 

of the Ukpeaġvik Iñupiat Corporation, an Alaska Native Corporation.

CFR 91.109 states:

No person may operate a civil aircraft (except a manned free balloon) that is being used for 

flight instruction unless that aircraft has fully functioning dual controls.

sUASs clearly have no onboard flight controls. An equivalent level of safety will be accomplished 

by conducting pilot training via the control system that communicates with the aircraft from the ground. 

ArrowData, LLC intends to conduct this training on the Nevada test site under controlled conditions.

CFR 91.113 Right-of-way rules: Except water operations.

CFR 91.113 deals with the many scenarios whereby different types of aircraft in different states must 

give way to other aircraft.

Because the sUAS PIC does not have “see and avoid” capability, the petitioner requests relief 

from this regulation. All operations will be within LOS of the pilot and well below any airspace where

other flight activity is taking place.

CFR 91.119 (d) (1) Minimum safe altitudes; general

CFR 91.119 states:

(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.

Recognizing that this relief is unprecedented, the petitioner asks that the FAA recognize the 

inherent capability of the ArrowData, LLC/BBTS/NIAS team. With a proven leader in risk management 

(ArrowData, LLC) and a leading FAA test site (NIAS/Nevada), we feel that an acceptable level of safety 

can be achieved. Extensive range testing and additional on-site testing in a benign environment would 

be conducted in real or near-real time conditions. The current altitude and/or horizontal restrictions on 

rotorcraft assumes a much heavier manned aircraft loaded with fuel and possible external stores. The 

light-weight sUAS being proposed for use in this activity along with its precise guidance and redundant 

systems create an entirely different paradigm that should be considered by regulatory bodies. 

The activities being proposed by this petitioner are in a very controlled and open area. The 

flights would be confined to the immediate area of the mobile control center (MCC). Given these 
Corporate Headquarters 4900 Seminary Road, Ste. 1200 | Alexandria, Virginia 22311 | 703.578.5566

Western Regional Office 777 Rainbow Blvd., Ste. 380 | Las Vegas, Nevada 89107 | 702.816.5087

ArrowData is a subsidiary within the UIC Government Services Division 

of the Ukpeaġvik Iñupiat Corporation, an Alaska Native Corporation.

considerations, ArrowData, LLC proposes allowing flights to operate no more than 150 feet from the 

MCC and well clear of the Class B airspace and attendant manned air traffic.

CFR 91.121 Altimeter settings

CFR 91.121 states:

Each person operating an aircraft shall maintain the cruising altitude or flight level of that 

aircraft, as the case may be, by reference to an altimeter that is set, when operating—

Below 18,000 feet MSL, to—

The current reported altimeter setting of a station along the route and within 100 nautical miles 

of the aircraft;

The sUAS aircraft intended for this activity will not be equipped with a barometric altimeter. 

Instead it will incorporate radio altimetry via the onboard GPS. An equivalent level of safety will be 

achieved through use of the operations and maintenance manuals governing altitude control. A preflight 

calibration of launch site altitude will be accomplished.

CFR 91.131 (a) (1) (c) (2) & (d) (1) Operations in Class B airspace

CFR 91.131 states:

(a) Operating rules. No person may operate an aircraft within a Class B airspace area except in 

compliance with § 91.129 and the following rules:

(1) The operator must receive an ATC clearance from the ATC facility having jurisdiction 

for that area before operating an aircraft in that area.

(c) Communications and navigation equipment requirements. Unless otherwise authorized by 

ATC, no person may operate an aircraft within a Class B airspace area unless that aircraft is equipped 

with—

(2) For all operations. An operable two-way radio capable of communications with ATC 

on appropriate frequencies for that Class B airspace area.

(d) Other equipment requirements. No person may operate an aircraft in a Class B airspace area 

unless the aircraft is equipped with—

(1) The applicable operating transponder and automatic altitude reporting equipment specified in 

§ 91.215 (a), except as provided in § 91.215 (e).
Corporate Headquarters 4900 Seminary Road, Ste. 1200 | Alexandria, Virginia 22311 | 703.578.5566

Western Regional Office 777 Rainbow Blvd., Ste. 380 | Las Vegas, Nevada 89107 | 702.816.5087

ArrowData is a subsidiary within the UIC Government Services Division 

of the Ukpeaġvik Iñupiat Corporation, an Alaska Native Corporation.

Much of the city of Las Vegas lies within the limits of the Class B airspace. Because the planned 

sUAS to be employed lacks an onboard transponder or two way communication capability, relief from 

this regulation is required. An equivalent level of safety will be achieved by limiting the operating ceiling 

of the sUAS to altitudes well below any conflicting manned aircraft traffic (no higher than 150 feet). This 

assures de-confliction with all other traffic and specifically traffic within the Class B airspace.

Additionally, the sUAS will remain clear of the McCarran Class B airspace at all times. ArrowData, LLC will 

periodically report to the FSDO on operations and risk management issues.

CFR 91.145 (b) Management of aircraft operations in the vicinity of aerial demonstrations and major 

sporting events.

CFR 91.145 states:

In deciding whether a temporary flight restriction is necessary for an aerial demonstration or 

major sporting event not listed in paragraph (a) of this section, the FAA considers the following factors:

(1) Area where the event will be held.

(2) Effect flight restrictions will have on known aircraft operations.

(3) Any existing ATC airspace traffic management restrictions.

(4) Estimated duration of the event.

(5) Degree of public interest.

(6) Number of spectators.

(7) Provisions for spectator safety.

(8) Number and types of participating aircraft.

(9) Use of mixed high and low performance aircraft.

(10) Impact on non-participating aircraft.

(11) Weather minimums.

(12) Emergency procedures that will be in effect.

If KLAS intends to use the sUAS to cover sporting events from the outside of the activity, 

coordination will be completed by contacting the FSDO prior to the event to ascertain the presence of 

any other unmanned activities. Flight activity will be conducted using the same operations plan as with 

any other ENG activity with particular attention to the avoidance of overflight of large concentrations of 

people. All of the concerns in the above twelve subparagraphs have been or will be addressed in other 
Corporate Headquarters 4900 Seminary Road, Ste. 1200 | Alexandria, Virginia 22311 | 703.578.5566

Western Regional Office 777 Rainbow Blvd., Ste. 380 | Las Vegas, Nevada 89107 | 702.816.5087

ArrowData is a subsidiary within the UIC Government Services Division 

of the Ukpeaġvik Iñupiat Corporation, an Alaska Native Corporation.

portions of this exemption application. However, specific relief from this regulation is still necessary to 

ensure compliance with FARs.

CFR 91.151 (b) Fuel requirements for flight in VFR conditions.

CFR 91.151(b) states:

No person may begin a flight in a rotorcraft under VFR conditions unless (considering wind and 

forecast weather conditions) there is enough fuel to fly to the first point of intended landing and, 

assuming normal cruising speed, to fly after that for at least 20 minutes.

The batteries that power the Cinestar 8 Okto XL have a mission life of approximately 45 minutes.

To meet the 20 minute reserve requirement, the airborne mission would be limited to approximately 25 

minutes. Given the limitation of the proposed flight area during any ENG, a more liberal flight time is a 

reasonable request. The aircraft would never be further than 150 feet from the recovery area. In no case 

would the aircraft be operated with less than 25% battery life remaining. 

No night time operations are currently planned.

CFR 91.203 (a) & (b) Civil Aircraft: Certifications required

CFR 91.203 (a) & (b) states:

(a) Except as provided in § 91.715, no person may operate a civil aircraft unless it has 

within it the following:

(1) An appropriate and current airworthiness certificate. Each U.S. airworthiness certificate used to 

comply with this subparagraph (except a special flight permit, a copy of the applicable operations 

specifications issued under § 21.197(c) of this chapter, appropriate sections of the air carrier manual 

required by parts 121 and 135 of this chapter containing that portion of the operations specifications 

issued under §21.197(c), or an authorization under § 91.611) must have on it the registration number 

assigned to the aircraft under part 47 of this chapter. However, the airworthiness certificate need not 

have on it an assigned special identification number before 10 days after that number is first affixed to 

the aircraft. A revised airworthiness certificate having on it an assigned special identification number 

that has been affixed to an aircraft, may only be obtained upon application to an FAA Flight Standards 

district office.

(2) An effective U.S. registration certificate issued to its owner or, for operation within the United States, 

the second copy of the Aircraft registration Application as provided for in § 47.31(c), or a registration 

certification issued under the laws of a foreign country.

(b) No person may operate a civil aircraft unless the airworthiness certificate required by paragraph (a) 

of this section or a special flight authorization issued under § 91.715 is displayed at the cabin or cockpit 

entrance so that it is legible to passengers or crew.
Corporate Headquarters 4900 Seminary Road, Ste. 1200 | Alexandria, Virginia 22311 | 703.578.5566

Western Regional Office 777 Rainbow Blvd., Ste. 380 | Las Vegas, Nevada 89107 | 702.816.5087

ArrowData is a subsidiary within the UIC Government Services Division 

of the Ukpeaġvik Iñupiat Corporation, an Alaska Native Corporation.

The sUAS to be employed has no cockpit or pilot and therefore has no ability to carry onboard 

any certification or registration documentation.

The equivalent level of safety will be achieved by keeping these documents with the pilot/team 

on the ground at the event. Previous precedence is resident in Exemptions 9565, 9665, 9789, 9789A, 

9797, 9797A, 9816A and 10700.

CFR 91.405 (a); 407 (a) (1) (2); 409 (a) (2); & 417 (a) & (b) Maintenance

These CFRs state:

Each owner or operator of an aircraft—

(a) 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;

Operation after maintenance, preventive maintenance, rebuilding, or alteration.

(a) No person may operate any aircraft that has undergone maintenance, preventive maintenance, 

rebuilding, or alteration unless—

(1) It has been approved for return to service by a person authorized under § 43.7 of this chapter; and

(2) The maintenance record entry required by § 43.9 or § 43.11, as applicable, of this chapter has been 

made.

Except as provided in paragraph (c) of this section, no person may operate an aircraft unless, 

within the preceding 12 calendar months, it has had—

(2) An inspection for the issuance of an airworthiness certificate in accordance with part 21 of this 

chapter.

The 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
Corporate Headquarters 4900 Seminary Road, Ste. 1200 | Alexandria, Virginia 22311 | 703.578.5566

Western Regional Office 777 Rainbow Blvd., Ste. 380 | Las Vegas, Nevada 89107 | 702.816.5087

ArrowData is a subsidiary within the UIC Government Services Division 

of the Ukpeaġvik Iñupiat Corporation, an Alaska Native Corporation.

(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.

These FARs only concern aircraft with an airworthiness certificate and therefore would not apply in this 

situation. All maintenance and inspections will be conducted IAW the maintenance manual and 

operations manual. The ability for an almost immediate safe recovery and landing if a malfunction 

occurs and the eight engine configuration with the ability to fly with loss of thrust on 2 engines provides 

a comfortable operating envelope and ensures an equivalent level of safety.

The reasons why granting ArrowData, LLC’s request would be in the public interest; that is, how it 

would benefit the public as a whole:

Granting the exemption to ArrowData, LLC would allow the public to safely view breaking news from a 

dynamic and unprecedented aerial perspective. ArrowData, LLC has created a unique way to view news 

events that benefits the general public socially and economically. ArrowData, LLC sets the industry 

standard in using purpose built Small Unmanned Aircraft Systems (sUAS) with multiple redundant 

features that enhance safety. ArrowData, LLC builds and engineers its Cinestar 8 Okto XL platform with 
Corporate Headquarters 4900 Seminary Road, Ste. 1200 | Alexandria, Virginia 22311 | 703.578.5566

Western Regional Office 777 Rainbow Blvd., Ste. 380 | Las Vegas, Nevada 89107 | 702.816.5087

ArrowData is a subsidiary within the UIC Government Services Division 

of the Ukpeaġvik Iñupiat Corporation, an Alaska Native Corporation.

dual electronic motherboards and flight control systems, dual high-capacity batteries rated at 21,000 

mAh each, and the ability to maintain controlled flight with the loss of 2 engines. 

The reasons why granting the exemption would not adversely affect safety:

ArrowData, LLC is leading the sUAS industry by using a safe and beneficial business model. ArrowData, 

LLC is a partner with Bowhead Business and Technology Solutions, LLC (BBTS). BBTS currently provides 

contract support as the Program Management Office (PMO) contractor to one of the six FAA approved 

commercial UAS test ranges operated by the Nevada Institute for Autonomous Systems (NIAS). The 

composition of this team is unparalleled in the unmanned aviation industry, uniquely qualified to 

leverage the collective capabilities of UAS operations, FAA approved range testing and Analytical Risk 

Management.

In addition, enhanced safety is achieved by using an unmanned aircraft that does not carry passengers 

or crew and does not carry flammable fuel.

IAW 14 CFR Part 11.81, the following summary is provided for publication in the Federal 

Register, should it be deemed necessary:

Applicant seeks relief from the following rules:

14 CFR Part 21, Subpart H– Airworthiness Certificates, 14 CFR 45.23 (b),14 CFR 61.113, 

(a) & (b), 14 CFR 91.7 (a), 14 CFR 91.9 (b) (2), 14 CFR 91.103 (b), 14 CFR 109, 14 CFR 

91.119, 14 CFR 91.113, 14 CFR 91.121, 14 CFR 91.131 (a) (1) (c) (2) (d) (1), 14 CFR 91.145 

(b), 14 CFR 91.151, 14 CFR 91.203 (a) & (b), 14 CFR 91.405 (a); 407 (a) (1); 409 (a); 417 

(a) & (b), 14 CFR 407, 14 CFR 409, 14 CFR 417, NOTAM 9/5151

The unparalleled operational and testing capabilities created by the partnership between 

ArrowData, LLC, Bowhead Business and Technology Solutions (Program Management Office contractor 

for NIAS), and the Nevada Institute for Autonomous Systems (the Nevada test range) will enable the 

Federal Aviation Administration to allow for the introduction of sUASs into environments not previously 

allowed with an acceptable level of safety. This is an opportunity to use highly dependable, multiredundant unmanned aircraft in a major metropolitan area, but to do so with stringent controls, 

pervasive risk management and detailed mitigation strategies to ensure that the public is not at any 

time exposed to unsafe conditions. Extensive range testing, “dry-run” testing under benign conditions 

and simulated emergencies will demonstrate that this activity can be accomplished without hazard to 

the general public. Additionally, a simulation evaluation will be completed by using the Monte Carlo 

modeling program. This program simulates 10,000 flights and provides a failure expectation value. The 

rotorcraft being proposed for this operation has redundancy in every conceivable area: thrust, 

communications, and electrical power for both the aircraft itself and the supporting system. Eight 

engines powered by two separate 21,000 mAh batteries and a data link system with “fly home” 

capability ensure that at no time will the aircraft not be able to land safely should that need arise. Preplotted waypoints using Geographic Instrument System coordinates and auto-pilot “fly to” commands 
Corporate Headquarters 4900 Seminary Road, Ste. 1200 | Alexandria, Virginia 22311 | 703.578.5566

Western Regional Office 777 Rainbow Blvd., Ste. 380 | Las Vegas, Nevada 89107 | 702.816.5087

ArrowData is a subsidiary within the UIC Government Services Division 

of the Ukpeaġvik Iñupiat Corporation, an Alaska Native Corporation.

provide extremely precise navigation. A Safety Management System will be employed and will address 

such issues as environmental impact (noise and hazardous material) and coordination with local 

Emergency Services/Incident Management personnel to include:

 Fire fighting

 Medical response

 Incident investigation

These capabilities, in total, provide a level of safety that should be satisfactory to the FAA and general 

public.

In view of the beneficial advantages to public safety, we respectfully submit our Section 333 exemption 

request.

Sincerely,

Michael S. Bradshaw

President

ArrowData, LLC

777 N. Rainbow Blvd, Suite 380

Las Vegas, NV 89107