U.S. Department of Transportation Docket Management System

1200 New Jersey Ave. SE Washington, DC 20590

Re: Exemption Request Section 333 of the FAA Reform Act

Dear Sir/Madam,

This petition is being submitted on our own behalf without legal counsel or consulting services. Pursuant

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

and 14 C.F.R. Part 11 , Springwise Facilities Management (SWFM) operating a Small Unmanned Aircraft 

System (sUAS)equipped to conduct aerial photography and survey for various industries, hereby applies 

for an exemption from the Federal Aviation Regulations (FARs) listed below to allow operation of our 

sUAS commercially in airspace regulated by the Federal Aviation Administration (FAA) so long as such 

operations are conducted with and under the conditions outlined herein or as may be established by the 

FAA as required by Section 333.

The requested exemption would allow Springwise Facilities Management to pursue its commercial 

interests in providing services to business interested aerial inspections using a small advanced sUAS in 

the following areas:

Thermal imaging

sUAS Operator Training

Facility inspections (including but not limited to roof, hvac, tower, gutter/downspot)

Parking lot survey

Landscaping survey

Product Demonstrations/Marketing for services

Research and Development

SWFM will be responsible to insure all sUAS flights that will occur over private or controlled access 

property will do so with the property owner's prior consent and knowledge and that only people who 

have consented or otherwise have agreed to be in the area where photography and videography will 

take place.

Regulations from which the exemption is requested:

14 C.F.R. Part 21

14 C.F.R. 45.23 (b)

14 C.F.R. 61.113(a) and (b) 14 C.F.R. 91.7 (a)

14 C.F.R. 91.9 (b) (2)

14 C.F.R. 91.109

14 C.F.R. 91.119
14 C.F.R. 91.121

14 C.F.R. 91.151(a)

14 C.F.R. 91.203 (a) & (b) 14 C.F.R. 91.205 (b)

14 C.F.R. 91.215

14 C.F.R. (91.401 - 91.417)

Unmanned Aircraft System

sUAS are a safer and more cost effective alternative to having a person climb onto a roof or in a 

manned vehicle to perform an inspection.

We are petitioning for exemption to enable SWFM to operate a multi-rotor equipped with a fixed 

camera (DJI Phantom 2 Vision) and DJI S-1000 multi-rotor equipped with a three-axis gimbaled camera. 

These sUAS all weigh less than 25 lbs, have the capability to limit the height it flies above the ground, to 

limit the radius of the distance it flies from the operator and to exclude it from Class B, C and D airspace 

including a no fly zone feature. Each system also has the failsafe function which means when the 

communication between the Main Controller and the transmitter is lost, the system will automatically 

trigger Return to Home.

The above specifications meet standards listed below, some derived in accordance with the Model 

Aircraft

Operating Standards:

The petitioner will only operate its sUAS in line of sight of a pilot and/or observer and will operate at 

sites that are a 'sufficient distance' from populated areas within the sterile area described in the 

operator’s manual. Such operations will insure that the sUAS will "not create a hazard to users of the

national airspace system or the public."

When flying sUAV within 3 miles of an airport, airport operators will be notified and the operator will 

give the right of way to avoid flying in the proximity of full-scale aircraft.

Maximum flight time for each operational flight will be 25 minutes.

~ Flights will be terminated at 20% battery power reserve should that occur prior to the 25 minute limit.

• The sUAS will be programmed so that it will not be operated at an altitude of no more than 400 feet

AGL.

• The sUAS operated by the petitioner weighs less than 55 pounds, including the payload {i.e. camera, 

lens, and gimbal).

• The sUAS will operate at speeds of no more than 55 knots.

• Given the small size of the sUAS and the restricted sterile environment within which they will operate, 

our sUAS operations adhere to the Reform Act's safety requirements.
Under the requested exemption SWFM ensures that all operators have completed a small unmanned

aircraft systems {UAS) education and training program including all applicable regulations and guidance 

documents; including aeronautical background information such as charts, NOTAMS and Aircraft 

Circulars; Radio Communications Procedures; Human Factors and Crew Resource Management; Basic 

Small UAS Aerodynamics; Weather factors; Airmanship and Decision-making and Safe Operating 

Procedures.

We respectfully request exemption under Section 333 to enable SWFM to operate safe, low-risk

commercial sUAS operations for the activities stated. SWFM at all times will respect the space and

privacy of citizens and property while keeping our skies safe.

Sincerely

Ryan Mullet

Lead UAS Operator

Information Systems 

Springwise Facilities Management

(574)855-5475

EXEMPTION REQUESTS AND EQUIVALENT LEVEL OF SAFETY

Springwise Facilities Management (SWFM) requests an exemption from the following regulations as well 

as any additional regulations that may technically apply to the operation of the sUAVS System:

14 CFR Part 21, Airworthiness Certificates

This part establishes the procedures for the issuance of an airworthiness certificate. 

While the FAA continues to work to develop airworthiness standards for Unmanned Aerial Systems, we 

request an experimental certificate be issued for the DJI Phantom 2 Vision and DJI S-1000 sUAS under 

either or both of the following provisions:

21.191 Experimental certificates.

Experimental certificates are issued for the following purposes:

(a) Research and development. Testing new aircraft design concepts, new aircraft equipment, new 

aircraft installations, new aircraft operating techniques, or new uses for aircraft.

(b) Showing compliance with regulations. Conducting flight tests and other operations to show 

compliance with the airworthiness regulations including flights to show compliance for issuance of type 
and supplemental type certificates, flights to substantiate major design changes, and flights to show 

compliance with the function and reliability requirements of the regulations. Since the experimental 

certificate can be used for commercial purposes such as market surveys, sales demonstrations, and 

customer crew training, we would expect that an experimental certificate would permit our commercial 

purpose as well. The aircraft will not carry persons or property, will not carry fuel, and will only fly under 

strict operational requirements. Combined with the UA's light weight, being constructed primarily of 

foam, carbon fiber, and/or plastic, we propose that the UA will be at least as safe, if not safer, than a 

conventionally certificated aircraft performing the same mission. If an experimental airworthiness 

certificate is not appropriate for this application, then we request an exemption of 14 CFR Part 21, 

Subpart H, and the requirement for an airworthiness certificate in general, citing the equivalent level of 

safety outlined in the previous paragraph.

14 CFR 45.23 Display of marks; general and 45.29 Size of marks.

These regulations provide that each aircraft must display "N" and the aircraft's registration number in

letters at least 3 inches high. Additionally, the aircraft must display the word "EXPERIMENTAL" in letters 

at least 2 inches high near the entrance to the cabin, cockpit, or pilot station. 

The sUAS does not have an entrance in which the word "EXPERIMENTAL" can be placed, and may not 

have a registration number assigned to it by the FAA. We propose to achieve an equivalent level of 

safety by including the word "EXPERIMENTAL" in the placard on the top of the aircraft, as shown above, 

where the PIC, VO and others in the vicinity of the aircraft while it is preparing for launch will be able to 

see the designation. Additionally, we feel that the permanent placard discussed in the previous 

paragraph will provide the aircraft's registration information at the ground station. Finally, we will 

display at the ground station a high contrast flag or banner that contains the words "Unmanned Aircraft 

Ground Station" in letters 3 inches high or greater. Since the aircraft will operate within 3/4 NM of the 

ground station, the banner should be visible to anyone that observes the aircraft and chooses to 

investigate its point of origin.

14 CFR 61 .113 Private pilot privileges and limitations: Pilot in Command and 61.133 Commercial pilot

privileges and limitations.

The regulation provides that no person that holds a Private Pilot certificate may act as pilot in Command 

of an aircraft for compensation or hire. Subparagraph (b) allows a private pilot to 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. 

Our proposed operations require that the PIC must hold at least a Private Pilot Certificate issued by the 

FAA and since the aircraft cannot carry passengers or property, we feel we meet the intent of 61.113

Subparagraph (b) even though the intent of this application is to conduct a business.

14 CFR 91.7 Prohibits the Operation of an aircraft without an airworthiness certificate.

As no such certificate will be applicable in the form contemplated by the FAA, this Regulation is

inapplicable.

14 CFR 91.9 Civil aircraft flight manual, marking, and placard requirements.
This regulation provides that no person may operate an aircraft unless a current, approved flight manual 

is in the aircraft. 

We assume that the intent of this requirement is to ensure that flight manual information is available to 

the aircrew while operating the aircraft. We request an exemption to this requirement since the aircraft 

is not only too small to carry documentation, the documentation would not be available to the crew

during flight operations. To obtain an equivalent level of safety and meet the intent of 91.9, we propose 

that a current, approved sUAS Flight Manual must be available to the crew at the ground station 

anytime the aircraft is in, or preparing for, flight.

14 CFR 91.109 Flight Instruction; Simulated instrument flight and certain flight tests 

The regulation states that "No person may operate a civil aircraft that is being used for flight instruction

unless that aircraft has fully functioning dual controls." 

The sUAS System ground-based control station consists of a small hand-held radio transmitter and while 

it does not offer a second set of "controls", both the student and instructor can, and will, operate the 

single set of controls simultaneously. With both student and instructor having "hands-on" the controls 

during flight, we feel that this technique meets the intent 91.109 and provides an equivalent level of 

safety.

14 CFR 91 .119 Minimum safe altitudes: General.

The regulation states that over sparsely populated areas the aircraft cannot be operated closer than 500

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

Since the typical mission of the sUAS would be photography or survey of persons, vessels, vehicles or 

structures it would be necessary to operate closer than 500 feet to the items listed. Operations will only 

be flown over property or persons where permission has been obtained and careful pre-planned has 

been performed. The aircraft will be operated at a low altitude allowing, if a power unit fails, an 

emergency landing without undue hazard to persons or property on the surface. Therefore we maintain 

that due to the small size of the UAS, the hazard to persons, vehicles and structures is minimal 

compared to manned aircraft, which should be considered in granting the exemption.

14 CFR 91.121 Altimeter settings.

The regulation requires that aircraft shall maintain cruising altitudes by reference to an altimeter setting

available within 100 NM of the aircraft. 

The sUAS will always fly below 400 feet AGL and will not need to maintain cruising altitudes in order to 

prevent conflict with other aircraft. An Above Ground Level altimeter measurement above the takeoff 

point is transmitted via radio from the sUAS on-board computer to the display screen held by the PIC, 

providing a constantly updated AGL readout.

14 CFR 91.151 Fuel requirements for flight in VFR conditions.

The regulation provides that no person may begin a flight in an airplane under day-VFR conditions unless

there is enough fuel to fly to the first point of intended landing and to fly after that for at least 30 

minutes.
We feel the intention of this paragraph is to provide an energy reserve as a safety buffer for delays to

landing. The sUAS are battery operated and the maximum duration of flight from a single battery charge 

is approximately 12-45 (depending on which sUAS) minutes with a 20% reserve. Since the aircraft will 

never fly more than 1⁄2 NM from the point of intended landing, a full battery charge at launch will ensure 

that we meet the reserve energy requirement of this paragraph. We request an exemption to the word 

"fuel" and ask for an equivalent interpretation with the word "energy". We also request exemption from 

the 30 min reserve and ask that our reserve will be to fly the mission to the point of intended landing 

and have at least a 20% battery reserve after that.

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

The regulation provides that an airworthiness certificate, with the registration number assigned to the

aircraft and a registration certificate must be aboard the aircraft. Additionally, subparagraph (b) 

provides that the airworthiness certificate be "displayed at the cabin or cockpit entrance so that it is 

legible to passengers or crew." 

With our largest vehicle, the S-1000, at a maximum gross weight of 22 pounds, the sUAS is too small to 

carry documentation, does not have an entrance, and is not capable of carrying passengers or crew. To 

obtain an equivalent level of safety and meet the intent of 91.203, we propose that documents deemed 

appropriate for this aircraft by the FAA will be co- located with the crew at the ground control station 

and available for inspection upon request. In order to identify the aircraft, we propose that the 

information found on airworthiness and registration certificates be permanently affixed to the aircraft

via placard containing the following information plus the word "EXPERIMENTAL" to satisfy the 

requirement of 14 CFR 45.23.

14 CFR Subpart E (91.401- 91.417)- Maintenance, Preventive Maintenance, Alterations

The regulation provides that the operator is primarily responsible for maintaining the aircraft in an

airworthy condition, including compliance with part 39 and 43. Paragraphs 91.407 and 91.409 require 

that the aircraft be "approved for return to service by a person authorized under 43.7" after

maintenance and inspection. 

It is our intention that the PIC perform maintenance and inspection of the aircraft and "be authorized to 

approve the aircraft for return to service." The PIC will ensure that the aircraft is in an airworthy 

condition prior to every flight and in addition, conduct detailed inspections after every two hours of 

flight. Maintenance performed by the PIC is limited to repairing small cracks, replacing a propeller, 

checking electrical connections and updating software and firmware for the on-board computer. All 

other maintenance will be performed by the manufacturer or their designated repair facility. The PIC will 

document work performed in accordance with 91.417. We feel that due to the size, construction, and 

simplicity of the aircraft, the PIC can ensure an equivalent level of safety.